ML20054E265
| ML20054E265 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/1982 |
| From: | Guldemond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Konklin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20054E260 | List: |
| References | |
| FRN-47FR2876, RULE-PR-50 47FR2876-79, NUDOCS 8204260333 | |
| Download: ML20054E265 (1) | |
Text
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GLEN ELLYN, ILLINOIS 60137 March 4, 1982 MD10RANDUM FOR:
J. E. Konklin, Chief, Projects Section 2A FROM:
W. G. Culdemond, Senior Resident Inspector, Point Beach Nuclear Plant
SUBJECT:
COMMENTS ON PROPOSED FULE ON ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT PUBLISHED IN VOL. 47 No. 13 FEDERAL REGISTER' DATED 20 JANUARY, 1982 I have reviewed the above referenced proposed rule and am forwarding the folicwing comments.to you for consideration and prospective transmittal to cognizant authorities.
1.
It is unclear whether the rule requires qualification for both mild (normal) and accident environments. The distinction is significant in that much safety related equipment is installed in locations not subject to adverse conditions created by an accident but susceptible to other adverse conditions.
One example is safety injection pumps.
It is not expected that such a pump would experience an adverse environment other than high radiation during an accident. However, the same pump / motor may be subjected to water / chemical sprays due to activation of fire suppression systems, pump oil leaks, or pump seal leaks.
Must these non-accident environments be taken into consideration?
Must such items as protection system relays in a cable spreading room be qualified by testing for the life of the plant under normal service conditions?
2.
Proposed section 50.49(c) requires qualification for equipment and systems that are " essential in preventing significant release of radioactive material to the en-vironment." Does this include waste processing systems and their controls?
3.
Proposed section 50.49(c) requires qualification for
" equipment needed to complete one path of achieving and maintaining a cold shutdown condition." This requirement appears ambiguous for two reasons.
First, it appears to l
allow deviation from single failure criteria requirements.
Second, must the licensee demonstrate only one qualified cooldown path or must others be considered?
4.
Proposed section 50.49(h) requires licensees to make a qualification status submittal within 90 days of the effective date of the amendment. Will a new submittal be required or l
can reliance be placed on past submittals made pursuant to l
present requirements?
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W. G. Guldemond l
Senior Resident Inspector Point Beach Nuclear Plant MAR 1 6 gg2 8'204260333 I