ML18058B103
| ML18058B103 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/21/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9210010053 | |
| Download: ML18058B103 (4) | |
Text
l consumers Power POWERIN&
MICHl&AN'S PRO&RE55 Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 September 21, ]992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO SUPPLEMENT 1 TO GENERIC LETTER 87-02 ON SQUG RESOLUTION OF USI A-46 On February 19, 1987, the NRC issued Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46." This Generic Letter encouraged utilities to participate in a generic program to resolve the seismic verification issues associated with USI A-46.
As a result, the Seismic Qualification Utility Group (SQUG) developed the "Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment."
On May 22, 1992, the NRC Staff issued Generic Letter 87-02, Supplement 1, which constituted the NRC Staff's review of the GIP and which included Supplemental Safety Evaluation Report Number 2 (SSER-2) on the GIP, Revision 2, corrected on February 14, 1992.
The letter to SQUG enclosing SSER-2 requests that SQUG member utilities provide to the NRC, within 120 days, a schedule for implementing the GIP.
By letter dated August 21, 1992, to James G. Partlow, NRR-NRC, SQUG clarified that the 120 days would expire on September 21, 1992.
This letter responds to the Staff's request.
As a member of SQUG, Consumers Power Company commits to use the SQUG methodology as documented in the Generic Implementation Procedure (GIP), where "GIP" refers to GIP Revision 2, corrected February 14, 1992, to resolve USI A-46 at the Palisades Plant.
The GIP, as evaluated by the Staff, permits licensees to deviate from the SQUG commitments embodied in the commitment sections, provided the Staff is notified of substantial deviations prior to implementation.
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2 Consumers Power Company recognizes that the Staff's position in SSER-2 is that if licensees use other methods that deviate from the criteria and procedures as described in SQUG commitments and in the implementation guidance of the GIP, Rev. 2, without prior NRC staff approval, the method may not be acceptable to the staff and, therefore, may result in a deviation from the provisions of Generic Letter 87-02.
Specifically, Consumers Power Company hereby commits to the SQUG commitments set forth in the GIP in their entirety, including the clarifications, interpretations, and exceptions identified in SSER-2 as clarified by the August 21, 1992, SQUG letter responding to SSER-2.
Consumers Power Company generally will be guided by the remaining (non-commitment) sections of the GIP, i.e., GIP implementation guidance, which comprises suggested methods for implementing the applicable commitments.
Consumers Power Company will notify the NRC as soon as practicable, but no later than the final USI A-46 summary report, of significant or programmatic -
deviations from the guidance portions of the GIP, if any.
Justifications for such deviations, as well as for other, minor deviations, will be retained on site for NRC review.
For defining seismic demand at the Palisades Plant, Consumers Power Company will use the options provided in the GIP for realistic median-centered and conservative, design in-structure response spectra, as appropriate, depending on the building, the location of equipment in the building, and equipment characteristics.
The licensing-basis Safe Shutdown Earthquake (SSE) in-structure response spectra may be used as one of the options provided in the GIP for resolution of USI A-46.
The licensing-basis spectra (Housner) as described in Section 5 of the Palisades FSAR is the design basis for the Palisades Plant and is considered to be conservative design.
Given the magnitude of the effort required to achieve resolution of USI A-46, the program completion schedule may be affected by coordination efforts with the seismic IPEEE response, the scope and schedule available for completing the necessary SQUG training and by the availability of industry resources which may be unavailable because of the large number of licensees implementing this program.
Although we have not yet finalized a schedule for completion of the A-46 program, we estimate that a Seismic Evaluation Report summarizing the results of the A-46 program at the Palisades Plant can be submitted to the NRC by May 1995.
This will allow sufficient time (approximately six months) following completion of the 1994 refueling outage to prepare and submit the seismic evaluation report.
Consumers Power Company intends to change its licensing basis methodology for verifying the seismic adequacy of new and replacement, as well as existing, electrical and mechanical equipment prior to receipt of a final plant-specific SER resolving USI A-46.
This change will be conducted under 10 CFR Part 50.59 and will be consistent with the guidance in Section 2.3.3 or Part I of the GIP, Revision 2, and with the clarifications, interpretations, and exceptions
3 SER resolving US! A-46.
This change will be conducted under 10 CFR Part 50.59 and will be consistent with the guidance in Section 2.3.3 or Part I of the GIP, Revision 2, and with the clarifications, interpretations, and exceptions identified in SSER-2 as clarified by the August 21, 1992, SQUG letter responding to SSER-2.
Any necessary changes to the FSAR will be provided in accordance with 10 CFR Part 50.71(e).
As requested by Supplement 1 to Generic Letter 87-02, this response is submitted under oath.
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
CONSUMERS POWER COMPANY Pali sades Pl ant Docket 50-255 - License DPR-20 RESPONSE TO NRC Supplement I to Generic Letter 87-02 4
At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, the accompanying Consumers Power Company response to Supplement I to Generic Letter 87-02, dated May 22, 1992, entitled, "Supplement I to Generic Letter (GL) 87-02 That Transmits Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on SQUG Generic Implementation Procedure, Revision 2, as corrected on February 14, 1992 (GIP-2)," is to the best of my knowledge, information and belief, truthful and complete.
CONSUMERS POWER COMPANY Sworn and subscribed to before me this 15th day of September 1992.
LeAnn Morse, Notary Public Van Buren County, Michigan My commission expires June 6, 1994
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