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GLEN ELLYN, ILLINOIS 80137 July 27,1983 Mr. C. William Wagner, Director Complaint Analysis Division Bureau of Commercial Services Michigan Department of Licensing and Regulation P.O. Box 30018 Lansing, MI 48909
Dear Mr. Wagner:
This is in response to your letter dated July 8, 1983, to Mr.
J. G. Keppler, and our telephone conversation of July 26, 1983,
_ regarding_ engineering-problems-associated-with-th "'dL.c4 ecJ
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Palisades Nuclear Power Plants.
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As we discussed, the Local Public Document Rooms (LPDRs) for Midland and Palisades, located at the Grace Dow Memorial Library, 1710 South Saint Andrews Road in Midland, and the Kalamazoo Public Library, 315 South Rose Street in Kalamazoo, respectively, should contain the information you desire.
Please let me know if I may be of further assistance regarding your information needs.
incerely,
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William B. Menczer, Director State and Government Affairs i
cc: J.G. Keppler, RIII J.D.
altzman, OSP
.1 Warnick, RIII i'
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n asas a e,.. im eis som Ocl 2 9 G22' MEMORANDUM FOR:
T. Novak, Assistant Director for Licensing, Division of Licensing FROM:
R. F. Warnick, Acting Director, Office of Special Cases
SUBJECT:
REGULATORY GUIDE 1.29 EXCEPTIONS During a routine inspection of Midland the inspectors determined that one of the emergency diesel generator exhaust system hangers was not constructed according to the drawings. The welds attaching the hanger to structural support steel were found to be inadequate. This hanger is massive, is directly over the diesel, and is classified as "non Q".
If the welds failed and the hanger dropped on.he diesel, it could make the diesel inoperative.
The inspectors informed the licensee that the above condition does not meet the requirements of Regulatory Guide 1.29, Position C.4.
_ Position C.4
_ states, in part, that the quality assurance requirements of Appendix B should be applied to all those activities affecting the functions _of
_those portions of non-sitety systems whose failure could reduce the functioning of any nlant safety system. A copy of the Regulatory Guide is enclo. sed.
The licensee's position was that the FSAR, Appendix 3A,_took exception
_to Regulatory Guide 1.29. Position C.4, and therefore, this hanger does not have to be constructed under Appendix B criteria. A copy of Appendix 3A is enclosed.
Subsequently, the inspectors had discussions with Darl Hood and others of your staff about the exhaust system hangers. The inspectors were informed that not only are the hangers considered to be "Q", but the i
diesel exhaust piping itself is also considered to be a safety related component.
The licensee's position was that the exhaust piping is a non-safety related component of the emergency system.
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T. Novak,
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Region III agrees with your staff. In addition, we believe the requirements of Regulatory Guide 1.29, Paragraph C.4. should be applicable to Midland and exceptions to this position should be limited rather than plant-wide.
I We request clarification of the NRC position. Does NRR accept the FSAR, Appendix A exception to RG 1.29, C.47 Are the emergency diesel generator 1
exhaust system and hanger safety-related?
If you have any questions, please contact either Wayna Shafer or myself.
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//R.F.Warnick,ActingDirector y
Office of Special Cases
Enclosures:
As stated 9
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