ML20138R192

Forwards Safety Evaluation Re Environ Qualification of safety-related Electrical Equipment Important to Safety.Util Equipment Qualification Program in Compliance w/10CFR50.49

ML20138R192
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/15/1985
From:	Zwolinski J Office of Nuclear Reactor Regulation
To:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20138R194	List: ML20138R192 ML20138R207
References
LSO5-85-11-022, LSO5-85-11-22, NUDOCS 8511180485
Download: ML20138R192 (5)

Text

._ . _ . _

%, UNITED STATES

-8 NUCLEAR REGULATORY COMMISSION

& wasmwarom. o. c.aoses

,,,,, November 15,1985 Docket No. 50-155 LS05-85-ll-022 Mr. Kenneth W. Berry Director, Nuclear Licensing

~ Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201

SUBJECT:

SAFETY EVALUATION FOR ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT Re: Big Rock Point Plant

~

. Enclosed is the staff's Safety Evaluation (SE) which addresses the environmental qualification of electric equipment important to safety for Big Rock Point for compliance with the requirements of 10 CFR 50.49. Also addressed are your proposed resolutions for the deficiencies identified in the staff's earlier SE dated April 26, 1983, and the February 18, 1983, Franklin Research Center Technical Evaluation Report enclosed with the SE.

The staff has also reviewed the justification for continued operation (JCO) presented by Big Rock Point for selected equipment and has determined herein,

~. these JC0 to be acceptable; however, it is expected the need for JC0 will not exist after November 30, 1985.

r

! On March 14, 1984, a meeting was held with Consumers Power Company to

? - discuss their proposed method of resolution for each of the environmental e qualification deficiencies identified.- Discussions also included Consumers Power Company's general methodology for compliance with 10 CFR 50.49,

" Environmental Qualification of E ectric Equipment Important to Safety for

- Nuclear Power Plants," which became effective February 22, 1983, and +

JC0 for those equipment items for which environmental qualification is not yet completed. As a result of this meeting an audit of Consumers Power Company's Environmental Qualification files was performed by the NRC on June 5 through June 7, 1984. The licensee then provided submittals, by letters dated June 29, July 18, August 27 and October 31, 1984 January 7 and 28, 1985, and February 7 and 21, 1985, addressing the above and documenting  ;

the discussions held at the meeting and the audit. An additional meeting was  :

held on September 5, 1984 to discuss progress and define objectives.

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Mr. Kenneth W. Berry November 15, 1985 documenting the qualification of safety-related electric equipment. The October order required the establishment of a central file location for the maintenance of all equipment qualification records. The central file was mandated to be established by December 1, 1980. The staff subsequently issued a Safety Evaluation Report (SER) on environmental qualification of safety-related electrical equipment to the licensee on June 1, 1981 documenting the environmental qualification deficiencies. This SER directed the licensee to "either provide documentation of the missing qualification infonnation which demonstrates that safety-related equipment meets the 00R Guidelines or NUREG-0588 requirements or commit to a corrective action (requalification, replacement,etc.)." The licensee was required to respond to NRC within 90 days of receipt of the SER.

In response to the staff SER issued in 1981, the licensee submitted additional information regarding the qualification of safety-related electric equipment.

This information was evaluated for the staff by the Franklin Research Center (FRC)inorderto: (1) identify all cases where the licensee's response did not resolve the significant qualification issues. (2) evaluate the licensee's

. qualification documentation in accordance with established criteria to r determine which equipment had adequate documentation and which did not, and -

- (3) evaluate the licensee's qualification documentation for safety-related electric equipment located in harsh environments required for TMI Lessons Learned Implementation. A Technical Evaluation Report (TER) was issued by FRC on February 18, 1983. An SER was subsequently issued to the Consumers Power Company on April 26, 1983 with the FRC TER as an attachment.

A final rule on environmental qualification of electric equipment important to safety for nuclear power plants became effective on February 22, 1983.

~ This rule, Section 50.49 of 10 CFR Part 50, specifies the requirements to be met for demonstrating the environmental qualification of electric equipment important to safety located in a harsh environment. In accordance with this rule, equipment for Big Rock Point may be qualified to the criteria specified

- in either the D0R Guidelines or NUREG-0588, except for replacement equipment.

Replacement equipment installed subsequent to February 22, 1983 must be qualified in accordance with the provision of 10 CFR 50.49, using the guidance of Regulatory Guide 1.89, unless there are sound reasons to the contrary.

A meeting was held with each licensee of plants for which a TER had been prepared for the staff by FRC in order to discuss all remaining open issues regarding environmental qualification, including acceptability of the environmental conditions for equipment qualification purposes, if this issue had not yet been resolved. On March 14, 1984, a meeting was held to discuss Consumers Power Company's proposed method to resolve the environmental qualification deficiencies identified in the April 26, 1983 SER and February 18, 1983 FRC TER. Discussion also included Consumers Power Company's general methodology for com justificationforcontinuedoperation(JCO)pliancewith10CFR50.49,and for those equipment items for which environmental qualification is not yet completed. As a result of this meeting an audit was performed on June 5 through 7, 1984 by the'NRC. The audit consisted of a review of ten files containing information regarding the equipments environmental qualification.

Nr.KennethV. Perry November 15, 1985 Based on discussions during the meetings, the audit and a review of the licensee's submittals, we have concluded that Consumers Power Company's Equipment Qualification Program is in compliance with the reouirements of 10 CFR 50.49, that the proposed resolution for each of the environmental qualification deficiencies identified for Eig Peck Point is acceptable, and that continued operation of Big Pock Foint will not present undue risk to the public health and safety.

Sincerely.

\

f.h MM- (1

! John A. Zwolinski, Chie G)peratingReactorsBranchNo.5 ivision of Licensing

Enclosure:

- Safety Evaluation _.

cc w/ enclosure:

- See next page W

W G

t _ _ _ -

Mr. Kenneth W. Berry Consumers Power Company 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 Vichigan Avenue Jackson, Michigan 49201 Big Rock Point Plant ATTN: Mr. David P. Hoffman Plant Superintendent Route 3 Post Office Box 591 Charlevoix, Michigan 49720

. Mr. I. Lee Moerland

~

Chairman, Board of Commissioners P. O. Box 218 Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Road

- Glen Ellyn, Illinois 60137 Nuclear Facilities and Environmental Monitoring Section Office

. Division of Radiological Health P. O. Box 30035 Lansing, Michigan 48909 Resident Inspector Big Rock Point Plant c/o U.S. NRC RR #3, Pcy 600 Charlevoix, Michigan 497?0 l

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