ML20052G115
| ML20052G115 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/30/1982 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20052G116 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8205140322 | |
| Download: ML20052G115 (3) | |
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April 30, 1982 4
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 - STATUS REPORT SUBMITTAL - ELECTRICAL EQUIPMENT QUALIFICATON (EEQ)
Consumers Power Company by letter dated September 3, 1981 responded to a 90-g day NRC Safety Evaluation Report (SER) request concerning our Environmental N
Qualification of Safety-Related Electrical Equipment Report (hereinafter EEQ Report). The September 3,1981 letter cor.nitted by about January 5,1982 to respond to open items identified in the Franklin Research Center (FRC)
Technical Evaluation Report (ER), on which the NRC-SER was based. Consumers Power Company also committed to provide additional information by about April 5, 1982 to address the electrical equipment aging problem in detail.
Consumers Power Company, by letter dated December 17, 1981, requested additional time to complete these con.::iitments.
It was estimated that these commitments could be met by about April 30, 1982. The purpose of this letter is to provide the information that was committed to in the September 3, 1981 submittal.
Consumers Power Company resolved to address all of the open items contcined in Section 4 of the TER and to revise the EEQ Report to reflect old equipment that was replaced and new equipment that was installed because of NUREG-0737 TMI Action Plan Requirements. The September 3, 1981 letter attempted to respond to many of the TER and SER questions. FRC, which was contracted by the NRC to review these rv.ponses, determined that more information was needed to justify continued operation with unqualified equipment. Following a meeting with the NRC staff on February 19, 1982, Consumers Power Company
!g g undertook the task of addressing the open items raised in the SER with the J
j primary objective of justifying interim operation of about fif ty equipment components deemed to contain outstanding qualification deficiencies as identified in the TER. This task was completed and the information was I
N submitted to the NRC on March 15, 1982 to supplement the information that was pb oc0482-0030a142 4
8205140322 920430 PDR ADOCK 05000155 P
n 1-kh D M Crutchfield, Chief 2
Big' Rock Point Plant Status Report Submittal-EEQ April 30, 1982 previously submitted on September 3, 1981. The NRC transmitted their letter of acceptance on March 19, 1982.
Consumers Power Company was also requested by letter dated February 24, 1982-to provide additional information concerning the environmental qualification of safety-related electrical equipment identified in the TMI Action Plan.
This additional information was documented in our submittal to the NRC/FRC dated April 1, 1982.
Consumers Power Company letter dated March 15, 1982 and. April.1, 1982 encompassed numerous additions and corrections to the EEQ Report. These pages are attached as Enclosure I.
Instructions are illustrated in these pages for-incorporation of these Revision 3 pages in the Revision 2 EEQ Report, dated September 3, 1981. Enclosure I, thus, satisfies ~our commitment to provide.
i information.concerning Item I of the September 3, 1981 and December 17, 1981 letters.
l Consumers Power Company further committed, by April 30, 1982, to address the aging problem in detail.and to provide a schedule of further actions on.
4 equipment qualification.
FRC, in the equipment aging lecture given at the spring (April 21-24, 1982) seminar on " Qualification of Safety-Related Equipment for Nuclear Power Generating Stations", identified the following items as being required in the development of an accelerated aging program.
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- Define the service environment.
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- Document aging stresses including the identification of j'
maximum and minimum values of service-stresses, average i
values and frequency of variation.
- Establish a qualified-life-goal.
- Define the safety-related function including operating i
environmental during the design basis event.
- List all materials and components subject to aging.
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- Identify significant aging mechanisms.
- Identify which materials, componen'ts, and subassemblies influence ability of equipment to perform the safety function, j
- Conduct analysis to determine whether aging can be limited to 1
selected materials and components.
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- Define the maximum acceptable degradation for the device as a unit and for the components.
- Estimate the time to reach the maximum acceptable i
degradation and correlate with qualified life goal.
- Collect information on means of accelerating the aging of materials and components that must be aged.
- Collect info mation on maximum allowable overstressing.
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- Review whether any combinations of stresses are known to i
produce synergistic effects.
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- Finally,- synthesize this information into an aging program.
l-oc0482-0030a142 1
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6 D M Crutchfield, Chief 3
Big Pock Point Plant T
Status Report Submittal-EEQ i
April 30, 1982
'The main purpose of the aging program is to establish an ongoing program to assure that equipment which may be exhibiting age related degradation will be identified and properly maintained to ensure that the equipment is environmentally qualified at all times. To accomplish this purpose, Consumers Power Company is proceeding with a program compatible to the steps identified by FRC. Also, procedures are being developed to ensure that equipment of components that have reached their qualified life will be. replaced to maintain the qualified status of the equipment.
This program is an ambitious undertaking which is at the forefront of of today's aging technology.
In order to achieve the program goals, Consumers Power Company has contracted an experienced consultant (Bechtel Power Corp) to establish a sarveillance program for Big Rock Point Plant. A similar program is also being executed for Palisades Plant.
Combining these plants-into a large aging pregram will maximize efficiency in data collection for similar equipment. Due to the different ages of these plant, there should be very~
valuable baseline data for materials that have been naturally aged for as long as 20 years. It is expected that this program will optimize our effectiveness in adequately maintaining electrical equipment that will perform as required through EOL of the plants.
It is also expected that the majority of the program will be ready for implementation by the last quarter,1982. However, portions of the Big Rock Point Plant program will require baseline test data p
which will not be available until the next refueling outage in the spring, 1983.
Consumers Power Company stated in the letter dated December 17, 1981 that the replacement equipment commitments made in the September 3, 1981 letter are being evaluated against the results of the Probabilistic Risk Assessment.
It is anticipated that this evaluation will be completed and all open SER items will be resolved by early fall, 1982. The total equipment qualification plan will then be submitted to the NRC commensurate with the 90 day requirement stipulated in the proposed rule 10 CFR 50.49.
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homas C Bordine Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector-Big Rock Point Attachment oc0482-0030a142
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O ENCLOSURE I REVISIONS TO BIG ROCK POINT ENVIRONMENTAL QUALIFICATION REPORT FOR SAFETY RELATED ELECTRICAL EQUIPMENT O
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