ML20028F268
| ML20028F268 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/21/1983 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20028F269 | List: |
| References | |
| NUDOCS 8301310329 | |
| Download: ML20028F268 (2) | |
Text
l ConSURIBf5 Power COR1pany oeneral offices: 1946 West Pernell Roed, Jackson. MI 49201 * (617) 788-0550 January 21, 1983 1
Dennis M Crutchfield, Chief Operating Reactors Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - INSER7 ICE TESTING -
PUMP AND VALVE PROGRAM:
IWP-IWV (ASME -
BOILER & PRESSURE VESSEL CODE SECTION XI)
NRC letter dated December 22, 1982 requested verification that Consumers Power Company letters of February 1, 1979, December 7, 1979, August 14, 1980 and March 23, 1981 are a complete reference of our submittals related to the Big Rock Point IWP-IWV Program. This letter documents that the above referenced letters are correct and do embrace all IWP-IWV relief requests and program description as of this date.
It also appears that these submittals will suffice to describe the Big Rock Point Plant Inservice Test (IST) Programs for Pumps and Valves during the 120 month interval (specified by your letter) beginning on March 29, 1983 and ending on March 29, 1993.
It should be noted, however, that Consumers Power Company does not concur with your December 22, 1982 interpretation of 10 CFR 50.55a inservice test intervals. Regardless of the fact that we were in Phase I of our Research &
Demonstration Program, and that March 29, 1963 marked the end of the 100-Hour Full Power Demonstration Run, and not the declaration of commercial operation, the third 10-year inspection interval for Big Rock Point cannot begin on March 29, 1983 since the law which required the first interval did not become i
effective until March 15, 1976 (Reference 10 CFR 50.55a(g) - 41 FR 6256).
10 CFR 50.55a(g)(4)(iii) specifies the following:
"For a facility whose operating license was issued prior to March 1,1976 the provisions of paragraph (g)(4) of this section are effective after September 1, 1976, at the start of the next one-third of a 120 month inspection interval."
The start of the next one-third inspection interval of our ISI program after September 1, 1976 was February 25, 1979.
oc0183-0129a142 8301310329 830121
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PDR ADOCK 05000155 L
1 P
PDR I
D M Crutchfield, Chief 2
Big Rock Point Plant Inservice Testing January 21, 1983 Our first 10 year interval for the IST program will therefore expire on February 25, 1989.
If, however, the IST program must run concurrent with the ISI program interval, then the end of the current 10 year program will occur at the completion of our 1983 refueling outage whereby the next interval will begin during the 1984 refueling outage. Nevertheless, via either of the above interpretations or as presented in your December 22, 1982 letter, Consumers Power Company does not currently plan to revise the Big Rock Point IST Program.
On December 9, 1982, by telephone conference call, two sets of the Big Rock Point Plant P&ID's were requested to aid the NRC staff reviewers in the identification of the applicable pumps and valves specified by our IST program. Two up-to-date information copies have been forwarded in response to the request. Mr Richard Emch of your staff has been added to our distribution list as a controlled copy holder and will henceforth receive all subsequent updates.
The attachment is part of our procedure TV-30 which lists and describes our IWV Tests and identifies the applicable surveillance test procedures. A previous list (superceded) was included in the December 7, 1979 submittal.
w0 Thomas'0-Bord ne Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector-Big Rock Point Attachment oc0183-0129a142
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