LIC-93-0068, Provides Clarification of Util Position on Listed Points Delineated in in Response to GL 87-02

Provides Clarification of Util Position on Listed Points Delineated in in Response to GL 87-02

ML20128K555
Person / Time
Site:	Fort Calhoun
Issue date:	02/11/1993
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-87-02, GL-87-2, LIC-93-0068, LIC-93-68, TAC-M69447, NUDOCS 9302180207
Download: ML20128K555 (2)

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Omaha Pub!!c Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247 402/636-2000 i February 11, 1993 '

LIC-93-0068 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station Pl-137 Washington, DC 20555 Referonces: 1. Docket No. 50-285

2. Letter from 0 PPD (K. J. Morris) to NRC (Document Control Desk) dated December 2, 1988 (LIC-88-506)

3. Letter from OPPD (W. G. Gates) to NRC (Document Control Desk) dated July 31, 1992 (LIC-92 016R)

4. Letter from OPPD (W. G. Gates dated September 21, -1992 (LIC)-92-30lR)to NRC (Document Control. De

5. Letter from NRC November 30,1992(S. D. Bloom) to OPPD (W. G. Gates) dated Gentlemen:

SUBJECT:

Omaha Public Power District Clarification of Response to Supplement No. I to Generic Letter (GL) 87-02 (TAC No AC9447)

Reference 4 transmitted the Omaha Public Power District (0 PPD) response to Supplement 1 of GL 87-02. In Reference 5, the NRC informed OPPD that portions of Reference 4 were not clear. This letter provides clarification of OPPD's position on these points.

1. In Reference 5, the NRC stated that it was unclear whether or not OPPD intends to implement both the Seismic Qualification Utility Group (5QUG) commitments and the implementation guidance.

ORPD intends to implement both the SQUG commitments and the Generic Implementation Procedure, Revision 2 (GIP-2) Implementation Guidance.

OPPD agrees with the NRC letter dated October 2,1992, which commented on the SQUG response to Supplement I to GL 87-02 and the Supplemental Safety Evaluation No. 2 on the SQUG GIP-2.

OPFD also acknowledges that the NRC has provided some flexibility in implementing GIP-2. The NRC indicated in Supplement No. I to GL 87-02 that SQUG members who commit to GIP-2 (both the SQUG commitments and the Implementation Guidance) may deviate from GIP-2 provided such deviations are identified, documented, and justified. Al so , Supplemental Safety Evaluation Report No. 2 on GIP-2 indicates that, if a licensee uses methods that deviate from the criteria and procedures described in the

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LIC-93-0068 Page:2-

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- SQUG commitments and-in the Implementation Guidance of_ GIP-2'without-prior-approval, . the! NRCe may find the use of ;such methods unacceptable > with regard to satisfying the provision of;GL'87-02p

2. -In Reference 5, the-NRC stated thatlif OPPD does not commit-to: implement both the SQUG commitments -and the Implementation Guidance,- and10 PPD has not committed to any acceptable alternative criteria and' arocedures,- then the NRC does not believe .that- it is feasible - ate this td me,ifor: 0 PPD to change its licensing basis in the manner described..

Since OPPD has committed to implement both' the:SQUGJcommitments and: the -

GIP-2 Implementation Guidance, OPPD:mayz change- the Fort Calhoun Station licensing basis. Any: change - in :1 verify the seismic adequacy-of new,accordance

-- -with replacement and10existing CFR: 50.59, wouldL electrical. i and mechanical equipment priorito receipt- of a final plant-specific NRC:

H Safety-Evaluation: Report, resolving USI A-46.

3. In Reference 5, thef MRC concluded.that the use of- criteria and-procedures in Appendix F to the Updated Safety: Analysis Report (USAR).would result in median-centered rather than: the-- " Conservative-Design" Ein-structure-response spectra. . Thus, 0 PPD's in-structure ^ : response spectra- were '

accepted as median centered.

OPPD agrees that the~use of the criteria and procedures in Appendix.F;to' .

.the USAR are accepted-as " median-centered" rather than-the " Conservative' '

Design" in-structure response spectra. In addition,-_0 PPD may optionally, use, af ter - NRC approval, the Fortu Calhoun. Station J Alternate: Seismic' .

Criteria = and Methodology (ASCM)'(References 2 and.3) as1"medianecentered" =

Safe. Shutdown Earthquake spectra.: In the attachment toj Referenca- 4, Paragraph 2 of Section III stated that for outlier resolution and for.some:

equipment (e.g., iatake structure equipment.for which no design basis in--

structure spectra exist), OPPD intends to use.ASCM.

If you should have'any questions, please contact me.

Sincerely,

n. 5 k W. G. Gates Vice President WGG/grc ii <

c: ' aBoeuf, Lamb, Leiby & MacRae-J. L. Milhoan, _NRC Regional' Administrator, Region IV R. P. ?iullikin, NRC Senior Resident Inspector ~

S. D. Bloom,-NRC Project Manager J

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