ML20128C947

Forwards SE Re Util 120-day Response to Suppl 1 to GL 87-02. Clarification Re Whether SQUG Commitments & Implementation Guidance Will Be Implemented Requested

ML20128C947
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/27/1992
From:	Olshan L Office of Nuclear Reactor Regulation
To:	Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20128C952	List: ML20128C947 ML20128C962
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M69429, NUDOCS 9212070075
Download: ML20128C947 (4)

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UNITED STATES

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Docket tio. 50-155 Mr. William L. Beckman, Plant Manager Big Rock Point Plant Consumers Power Company 10269 U.S. 31 llorth Charlevoix, Michigan 49720

SUBJECT:

BIG ROCK Polfli PLAliT - RESP 0f4SE TO SUPPLEMElli fl0.1 TO GEllERIC LETTER 87-02 (TAC 110. M69429)

By letter dated September 21, 1992, you provided your response to Supplement flo. I to Generic letter (GL) 87-02. Enclosed is our Safety Evaluation (SE) of your response.

Your response is unclear as to whether or not you intend to implemont both the Seismic Qualification Utility Group (SQUG) commitments and the implementation guidance. The staff interprets your response as a commitment to the entire Generic implementation Procedure, Revision 2 (GlP-2) including both the SQUG commitments and the implementation guidance, with the exception of any deviations identified in your 120-day response and, therefore, considers it acceptable. If this interpretation is incorrect, then in accordance with Supplement flo. I to GL 87-02 you should provide, as soon as practicable prior to implementation, alternative criteria and procedures for responding to GL 87-02. Additionally, you should not merely follow the August 21, 1992, SQUG 1etter for implementing GIP-2 as stated in your submittal, but you should refer to Enclosure 2 to this letter which provides the staff's response to the SQUG letter. You indicated that you intend to deviate from the SQUG commitments in GIP-2, Section 3.1.2, Paragraph 3, and in GlP-2, Section 9.1, number 14. In your discussion of these proposed deviations, it appears you have quoted from an outdated version of GIP-2 and you should, therefore, confirm that you are implementing the version of GlP-2 which the staff reviewed and accepted in Supplemental Safety Evaluation Report fio. 2 (SSER tio.

2). The first deviation involves the plant's inability to meet the single failure criterion because it has only one automatically-started emergency diesel generator. You should provide an alternate way of achieving safe shutdown. With regard to the second deviation, your proposal to use a Probabilistic Risk approach for resolving outliers is not acceptable. You should resolve the equipment outliers by either testing, engineering analysis, physical repairs, or replacing the equipment. The implementation schedule proposed is within the three year response period requested by the staff in Supplement flo. I to GL 87-02 and is, therefore, acceptable, it is our understanding that the licensing-basis spectra for your plant are the Systematic Evaluation Program (SEP) spectra. The enclosed SE requests additional information concerning the licensing-basis spectra.

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Mr. W. L. Beckman November 27, 1992

'onsumers Power Company You indicated that you intend to change the licensing basis methodology, via 10 CIR 50.59, for verifying the seismic adequacy of now, replacement, and existing electrical and mechanical equipment prior to receipt of a final plant-specific (SE) resolving USI A-46, lhe staff recognizes that you may revise the licensing basis in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 (GlP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered bv the GlP. Ilowever, if you do not commit to implement both the SQUG commitments and the implementation guidance, and you have not committed to any acceptable alternative criteria and procedures, then the staff does not believe that it is feasible, at this time for you to change the licensing basis in the manner described. _

Sincerely, Original signed by William M. Dean for Leonard H. 01shan, Project Manager Project Directorate 111-1 Division of Reactor Projects - lil/IV/V Office of Nuclear Reactor Regulation

Enclosures:

1. Safety Evaluation

2. Staff's SQUG Response cc w/ enclosures:

See next page

• SEE PREVIOUS CONCURRENCE _

OfflCE LA:PDIllfOld N4:PDill-l* BC:SRXB* BC:EMEB* PD:PDill-1 NAME MShuttlewo'[hr L0lsan/vsb RJones JNorberg gdhrN DATE !l /)7/92 11/25/92 11/25/92 11/25/92 81 /M/92 OfflCIAL DOCUMENT NAME: GL87-02.SER i il iil mi i

1 .

Mr. William L. Beckman Big Rock Point Nuclear Plant Big Rock Point Plant CC:

Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Jane E. Brannon, County Clerk County Building Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator, Region 111 U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, 111inois 60137 #

Nuclear facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N. Logan Street P. O. Box 30195 Lansing, Michigan 48909 U.S. Nuclear Regulatory Commission Resident inspector Office Big Rock Point Plant 10253 U.S. 31 North Charlevoix, Michigan 49720 Mr. David P. Hoffman, Vice President Nuclear Operations Big Rock Point Plant 27780 Blue Star Memorial Hwy.

Covert, Michigan 49043 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.

Washington, DC 20037 I

Distribution:

(100cket file l

" HRC & Local PDRs PD 31 Reading file JRoe JZwolinski LMarsh PYChen MShuttleworth L01shan OGC ACRS (10)

Plant File WShafer Rlli cc: Plant service list 4

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