ML20107A143
| ML20107A143 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/11/1985 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton, Thompson H Office of Nuclear Reactor Regulation |
| References | |
| GL-84-24, NUDOCS 8502190302 | |
| Download: ML20107A143 (3) | |
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wisconsin Electnc eom couem 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 February 11, 1985 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D.
C..
20555 Attention:
Mr. H. Thompson, Director Division of Licensing Gentlemen:
DOCKET NOS. 50-266 AND 50-301 RESPONSE TO GENERIC LETTER 84-24 CERTIFICATION OF COMPLIANCE T_O 10 CFR 50.49 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 On January 14, 1985 Wisconsin Electric Power Company receivcd Generic Letter 84-24, " Certification of Compliance to 10 CFR 50.49, Environmental Qualification'of Electric Equipment Important To Safety For Nuclear Power Plants", dated December 27, 1984.
This letter requests, within 30 days of issuance, certification under oath or affirmation that compliance with 10 CFR 50.49 is progressing.
As discussed with~Mr. Colburn of your staff, because of the delayed receipt of this letter we were unable to respond within the specified time frame.
Although Mr. Colburn authorized a response extension until the beginning of February, we could not complete this certification prior to this date.
Certification, detailed consistent with the items of Generic Letter 84-24,_is provided below:
Wisconsin Electric has in place and is implementing an a.
Environmental Qualification (EQ) Program for Point Beach which satisfies the requirements of 10 CFR 50.49 within the currently approved schedule as clarified below:
1.
All electrical equipment at Point Beach within the scope of 10 CFR 50.49 is installed ~or being installed within the currently approved schedule.
8502190302 850211 /
PDR ADOCK 05000266 r op4I P
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s' Mr.~H. R. Denton February 11, 1985
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However, a recent internal Nuclear Quality Assurance Division audit of nuclear environmental qualification has identified certain deficiencies
-in our " Equipment Qualification Summary Sheets" and in documentation of our review and approval of qualification test and analysis reports.
We expect to resolve these deficiencies by March' 31, 1985.
Also, the calculation of accuracy requirenents for those instruments to be used in the upgraded Emergency Operating Procedures (EOP's) at Point Beach has'not yet been completed.
The incorporation of the new EOP setpoints into the EQ documentation will be completed prior.to the implementation of the
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upgraded EOP's scheduled for July 1, 1985.
In addition, the audit identified a' lack of formality in documentation of maintenance performed to maintain qualification.
-This, however,. was not found to have jeopardized the qualification status of any equipment at Point Beach.
Based on our preliminary review of these audit deficiencies, we believe they do not indicate that the installed equipment is not capable of performing its safety function when subject to the design-basis harsh environments.
2.
This certifi':ation does not apply to Regulatory f
Guide 1.97 escipment not previously listed in our
" Master List of Electrical Equipment to be Environmentally Qualified" provided to you in our November 23, 1983 submittal.
The schedule for environmental qualification of any additional Regulatory Guide 1.97 instrumentation or campling equipment to be qualified is not governad by the schedule provisions of 10 CFR 50.49 (g), but rather will be established in the Regulatory Guide 1.97 resolution process.
3.
Currently, the NRC has granted us time extensions, until June 7, 1985, for the installation and qualification.
testing of two items of equipment at Point Beach, 1.e.,
the Crosby lift indicating switch assemblies (LISA's) for direct position indication of the pressurizer code safety valves and the Veam cable connectors for the core exit thermocouples.
The June 7, 1985 date is still valid for completion i
of installation, testing, and documentation on both items.
However, due to uncertain nature of qualification testing, it may be necessary to request additional time extensions should testing difficulties ~arise which cause a delay in our schedule.
We will notify you promptly in accordance with 10 CFR 50.49 (h) of.any problems that might require a further extension of the completion date.
4.
-Rockbostos cable, which is installed at Point Beach, has several qualification documentation
' deficiencies identified by the NRC in-Information Notice 84-44.
Tests by Rockbestos and others
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February; 11, 1985'
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' indicate that the cable'is qualified.-
Rockbesto's, however,-is conducting a test'programsto reverify.
'theiqualification of their cable.
We are continuingi to monitor.the test. program to ensure that-the' previous' qualification is not invalidated.
i-b.
Thereiis at least one' path to' safe shutdown using:
z environmentally-qualified equipment at' Point. Beach, consistent.with the clarification in a.1 above.-
c.- ~ All of' the equipment within the; scope of ~10 :CFR 50.49, with-the exception:of,the--two equipment items discussed 4
in a.3 above/Lis: qualified in accordance~with thel provisionsjof that' rule,1 consistent withithe clarifications inia.1 andia.2iabove. ' Justifications for continued operation (JCO's) for. the Crosby:LISA's and Veam :thermo-j couple connectors were provided in our submittal _of November-23,11983, "nesolution'of Safety Evaluation l
Reports for Environmental' Qualification of Safety-Related l-Electrical Equipment".
The JCO's provided~at that 1
time remain valid.
}
. Generic Letter 84-24 also requested thatIthe information in IE Bulletin.82-04 and IE Notices 82-11, 82-52, 83-45, 83-72,.
84-23, 84-44, 84-47, 84-57, 84-68, and 84-78 be considered when making the above certifications.
These documents have been reviewed i
and, if applicable to Point Beach, have been incorporated in the l
operating experience program at Wisconsin Electric.
This statement is not meant to imply.that there is a formal documented mechanism by i
which all IE Bulletins and Information Notices are analyzed in i
detail.
While we do indeed routinely review such documents,.we i-note that there is no requirement in the regulations for a formal l
documented review mechanism.
l This letter is affirmed in accordance with the provisions of 10 CFR 50.54(f).
We would be-pleased to respond to any questions i
j you may have in this regard.
Very truly ours, L
66u-C. W. Fay Vice Presi t-Nuclear Power L
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I Copy to NRC Resident Inspector Subscribe 4 and sworn to before me j
this // M. day of February 1905.
bY'}. bi Notary Publici State of yisconsin ,qg;; p i My Coramission expires b V //f[. l -r y i . w,_ ..._~_.,_.m__ ,,,._._.,..,e,_y.,,m%- ,r ,_..r_. -}}