ML20039B506

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Provides Addl Response to Generic Ltr 81-34 Re Safety Concerns Associated W/Pipe Breaks in BWR Scram Sys.Position Established in Util 810601 Response Maintained,Based on Review of NUREG-0803.Concerns Not Applicable
ML20039B506
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/18/1981
From: Hoffman D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0803, RTR-NUREG-803 GL-81-34, NUDOCS 8112230164
Download: ML20039B506 (2)


Text

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9 Constimers Power Company oecerei offices: 212 West Michigen Avenue, Jackson, MI 492L1 * (617) 788-05tLO i

December 18, 1981 N

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Dennis M Crutchfield, Chief MS g

g 8/p Operating Reactors Branch No 5 gO Nuclear Reactor Regulation DgCp8

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US Nuclear Regulatory Commission g

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M Washington, DC 20555 N'

DOCKET 50-155 - LICENSE DPR '

BIG ROCK POINT PLANT - RESIONSE N'D"TT TO GENERIC LETTER 81 SAFETY CONCERNS ASSOCIATED WITH PIPE BREAKS IN THE BWR SCRAM SYSTEM NRC letter dated August 31, 1981 enclosed NUREG-0803, " Generic Safety Evaluation Report Regarding Integrity of EWR Scram System Piping", and requested a plant specific evaluation and response to ensure comfcrmance to the guidance contained in NRC's letter of April 10, 1981.

By letter dated June 1, 1981 Consumers Power Company provided a response to the April 10, 1981 NRC letter. After reviewing NUREG-0803, Consumers Power Company aaintains the position established in our June 1, 1981 response. The safety concerns associated with pipe breaks in the BWR scram system are not applicable to Big Rock Point as a result of the design and location of our scram system. The following facts substantiate this conclusion and are reitarated from our June 1, 1931 response.-

1.

Big Rock Point was constructed in the early 1960's using a containic.ent l

design that contains the entire hydraulic portion of the sy

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Therefore, the Big Rock Point design is not susceptible to pipe breaks j

in the scram system in which long term cooling is jeopardized due to i

loss of reactor coolant frc;n containment.

hCI 2.

Based upon the location, postulate,1 scram system pipe breaks are 3

boundad by previous Emergency Core Cooling System (ECCS) analyses i

which meet the requirements of 10CFR50.46.

ID 3.

The location of ECCS components at Big Rock Point eliminates the I

environmental effects of concern resulting from scram system pipe breaks. The ECCS water supply is provided by the fire system which is j

oc1281-0022bl42 8112230164 011218' PDR ADOCK 05000155 P

PDR

D2nnis M Crutchfield, Chief 2

Big Rock Point Plant December 18, 1981 supplied by pumps external to containment.

Post incident recircula-tion flow (long term cooling) is also provided by pumps and a heat exchanger external to containment.

In addition, all of the ECCS electrical components located inside of containment are requirad to meet Electrical Equipment Qualification requiren ents (reference:

Consumers PowerCompany letters dated October 31, 1980, January 30, 1981 and September 3, 1981).

Our position is also reinforced by General Electric letter MFN-091-81 dated April 30,1981 from Glen G Sherwood to Darrell Eisenhut, 'IRC which indicates that the safety concerns associated with ytpe breaks in the BWR scram system is not applicable to BWR 6 Mark III designs. We have discussed this evalua-tion with General Electric and have ascertained that the same conclusion of non-applicability applies to Big Rock Point for essentially the same reason.

On the basin of our evaluation, Consumers Poser Company concludes that the outlined safety concerns associated with pipe breaks in the BWR Scram System are not applicable to Big Rock Point. Therefore, this letter providc.s our response to the plant specific requests of.HC letters dated April 10, 1981 and August 31, 1931.

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David P Hoffman Nuclear Licensing Administrator CC Administrator, Region III, UCNRC NRC Resident Inspector-Big Back Point oc1281-0022bl42

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