ML20028C335

Submits Comments on Draft EGG-EA-6109, Identification & Ranking of Nuclear Plant Structures,Sys & Components & Graded QA Guidelines. Proposed Requirements Will Not Improve Safety of Operating Plants

ML20028C335
Person / Time
Site:	Point Beach
Issue date:	01/03/1983
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, Haass W Office of Nuclear Reactor Regulation
References
NUDOCS 8301070349
Download: ML20028C335 (2)

Text

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5* l WkSC00 Sin Ekctnc eowra coursur 231 W. MICHIGAN, P.o. BOX 2046. MILWAUKEE. WI 53201 l

4 January 3, 1983 '

i Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. NUCLEAR REGULATORY COMISSION Washington, D.C. 20555 4 Attention: Mr. Walter P. Haass, Chief Quality Assurance Branch ,

Gentlemen:

, DOCKET NOS. 50-266 AND 50-301 l

COMENTS ON DRAFT REPORT ECG-EA-6109

" IDENTIFICATION AND RANKING OF NUCLEAR PLANT STRUCTURES, SYSTEMS, AND COMPONENTS, AND GRADED i

QUALITY ASSURANCE GUIDELINES - DRAFT POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 The above Draft Report ECG-EA-6109 was recently sent to Wisconsin Electric as a member of the Edison Electric Institute (EEI) Quality Assurance Committee.

Written comments were invited by Mr. Haass of the NRC Staff by January 3, 1983.

t This letter contains Wisconsin Electric's comments on the draft report. The com-ments were written from the perspective of the owner of Point Beach Nuclear Plant (PBNP), a tw6-unit Westinghouse pressurized water reactor plant which has been in operation for over ten years.

A statement is made on page 11 of'the draft report "that new or differ-ent [ quality assurance] requirements are not being imposed. Because guidelines for the program structure are extracted from currently existing regulations, min-imal impact to existing systems currently in place in the nuclear industry should occur." We take strong exception to this statement. Earlier vintage plants such as PBNP have previously established Quality Assurance (QA) programs with specific 4 commitments to certain regulatory guides, codes, standards, and other regulatory requirements and specific commitments to the scope of systems, components, and structures included in the Program. Upgrading of the QA Program to all of the current QA-related requirements listed in the subject report would impose a sub-stantial impact on such plants in terms of manpower requirements, administrative burden, and costs. Furthermore, the considerable expansion of systems, compon-ents, and structures to be included in the QA Program, as required for QA Levels II

( and III, would also impose a tremendous impact on plants such as PBNP.

The subject draft report established definitions for QA Levels II and III that are too vague and general to differentiate between structures, systems and components that do and do not contribute substantially to plant safety. The def-initions would not be useful in establishing plant-specific programs. The "QA 01 8301070349 830103 PDR ADOCK 05000266

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Mr. H. R. Denton January 3, 1983

, Ranking" tables, on the other hand, are totally inflexible in their requirements 4

despite the claim that user flexibility was one of the objectives of the report.

The. tables do not consider differences in the vintage or design of plants.

Furthermore, the " Guidelines" for QA requirements do not imply any significant difference between the requirements for QA Levels I and II, since the maximum requirements for each level are to be met unless " reasonable justification" is established. We believe this approach would dilute the proper attention to the quality of structures, systems, and components essential to plant safety (i.e.,

those classified safety-related). Application of QA requirements to such items as meteorological instrumentation, emergency telephones, off-site power system, j reactor coolant pump function (not integrity), pressurizer function (not integrity),

normal plant control systems, condensate cleanup and treatment systems, main con-densor evacuation system, and turbine gland sealing systems does not appear to l contribute substantially to plant safety. The addition of these types of systems to the QA scope of an operating plant would, however, have a substantial impact on manpower requirements and costs. Therefore, it is recommended that the defin-itions of the QA Levels be clarified and the associated " Guidelines" and "QA Ranking" tables be revised with a view towards minimizing the requirements unless a substantial and cost effective safety benefit can be demonstrated.

The benefit in terms of improvement in safety from backfitting the

. requirements of the subject report onto operating plants has not been established l in the draft report. The Code of Federal Regulations, 10 CFR 50.109 Backfitting, specifies that required backfitting must " provide substantial, additional protec-tion which is required for the public health and safety . . ." The subject re-port does not address backfitting of operating plants to the proposed QA require-ments. The authors apparently do not recognize that plants of various vintages have different QA programs. We believe that the imposition of the proposed QA i requirements will not significantly improve the safety of operating plants and I that imposition of these requirements with the resulting substantial impact l could not be justified by a detailed cost / benefit analysis.

We would be pleased to answer any questions you may have regarding these comments.

Very truly yours, C. W. Fay Vice Presid n Nuclear Power cc: Mr. Victor Stelle, Director Regional Operations and Generic Requirements NRC Resident Inspector 1

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