ML17335A692
| ML17335A692 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/02/1992 |
| From: | Partlow J Office of Nuclear Reactor Regulation |
| To: | Smith N SEISMIC QUALIFICATION UTILITY GROUP |
| Shared Package | |
| ML17335A693 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9210090325 | |
| Download: ML17335A692 (3) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 205S5 ENCLOSURE 2
OCT D2 Hr. Neil Smith, Chairman Seismic gualification Utility Group c/o EPRI 1019 19th Street, N.W.
Washington, OC 20036 SUBJECT'e:
NRC
RESPONSE
TO SEISMIC QUALIFICATION UTILITY GROUP (S(UG)
- Letter, N. Smith,
- 1992, concerning USI A-46 Issues.
Dear Hr. Smith:
This is to acknowledge the receipt of the S(UG response to Supplement No.
1 to Generic Letter (GL) 87-02, and Supplemental Safety Evaluation (SSER)
No. 2, on the SHRUG Generic Implementation Procedure for Seismic Yerification of Nuclear Plant Equipment, Revision 2, as corrected February 14, 1992 (GIP-2).
The NRC staff believes that successful implementation of the entire GIP-2, supple-mented by the staff's SSER No. 2, by each SQUG licensee will result in cost-effective plant safety enhancement for their USI A-46 plants.
The staff also believes that the positions delineated in Supplement No.
1 to GL 87-02 and SSER No.
2 are clear and correct, and should not be misinterpret-ed.
The staff's comments on S(UG's August 21, 1992, letter and attachment are provided in the enclosure to this letter. If you need further clarification concerning our response, please contact Hr. James Norberg at 504-3288.
Sincerely,
Enclosure:
As stated J
es G. Partlow Associate Director for Project s Office of Nuclear Reactor Regulation
ENCLOSURE I.
NRC' C
mm t on th S
UG et er of Au u 2.
3.
4.
II.
NRC's The second paragraph on page 2 of your letter addressed the issue of timing of staff response to additional information requested from a licensee.
Although you are correct in your statement regarding the sixty-day period for response to initial submittal of in-structure response spectra (ISRS) information, we do not agree that the same concept applies to a licensee's submittal of additional information received following a rejection or a question from the staff.
To eliminate any potential misunder-standing in this regard, the staff has determined that it will respond to any submittal of additional information received from a licensee within 60 days.
However, in this response, the staff will either state its approval (or rejection) of the information
- provided, or indicate the time duration needed for the review of such information, prior to transmitting a follow-up response of acceptance (or rejection) to the licensee.
This time duration will vary depending on the complexity of the submittal.
Regarding the EBAC and ANCHOR computer. codes, the staff's evaluations and concerns stated in the SSER No.. 2 are correct and valid.
The ANCHOR code does not consider the effects of base plate flexibilityon the anchorage capacity.
With respect to transfer of knowledge regarding major problems identified, and lessons
- learned, in the USI A-46 plant walkdowns and third-party reviews, we request that you include the NRC in the distribution of written communications to all member utilities in this regard, and inform the NRC staff of any planned workshops on A-46 implementation for possible staff participation.
n th ur iw h
Comm n
In regard to the issue of seismic qualification, the staff reiterates the position stated in the SSER No. 2, in that the GIP-2 methodology is not considered to be a seismic qualification
'method, rather, it is an acceptable evaluation method, for USI A-46 plants only, to verify the seismic adequacy of the safe-shutdown equipment and to ensure that the pertinent equipment seismic requirements of General Design Criterion 2 and the purpose of the NRC regulations relevant to equipment seismic adequacy including 10 CFR Part 100 are satisfied.
The staff supports SHRUG's establishment of a Peer Review Panel composed of seismic experts since it should serve to enhance the review process of substantive changes to the technical requirements in the GIP, prior to its submittal to NRC for approval.
However, since the NRC no longer intends to help finance a Peer Review Panel, the staff does not believe it is appropriate to participate in the selection of the Peer Review
- members, who will be financed by SHRUG/EPRI.
We would like to emphasize that staff's review of a proposed GIP change will receive thorough independent NRC evaluation and will be assessed on its merits.
With respect to the NRC review and approval of the changes to the GIP
( Item 5, page 3 of the procedure),
the staff's position on the
'ssue of its response timing is identical to that delineated in
.the response to a licensee submittal of additional information (refer to item 2 of NRC's Comments on the SHRUG letter in this enclosure).
This comment also applies to the section LICENSING CONSIDERATIONS" on page 5 of the Attachment to the SHRUG letter.
With respect to item 4, "Additional Restrictions,"
the text should be expanded to reflect that new information which indicates that existing GIP criteria and guidelines may be unconservative should be evaluated for potential 10 CFR Part 21 implications.