ML18096B100
| ML18096B100 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/13/1992 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Miltenberger S Public Service Enterprise Group |
| Shared Package | |
| ML18096B101 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M69479, TAC-M69480, NUDOCS 9211230126 | |
| Download: ML18096B100 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555 Docket Nos. 50-272 and 50-311 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038
Dear Mr. Miltenberger:
November 13, 1992
SUBJECT:
EVALUATION OF 120-DAY RESPONSE TO SUPPLEMENT I TO GENERIC LETTER (GL} 87-02, SALEM NUCLEAR GENERATING STATION, UNITS l AND 2 (TAC NOS. M69479 AND M69480}
Enclosure I provide~ the NRC staff's evaluation of the Public Service Electric and Gas Company's (the licensee} response to Supplement I to GL 87-02 for the Salem Nuclear Generating Station, Units 1 and 2, which was submitted to the staff in a letter dated September 21, 1992.
Supplement 1 to GL 87-02 required that all addressees provide, within 120 days of the issue date of the supplement, either a commitment to use both the Seismic Qualification Utility Group (SQUG} commitments and the implementation guidance described in the Generic Implementation Procedure, Revision 2 (GIP-2}, as corrected on February 14, 1992, and as supplemented by the staff's Supplemental Safety Evaluation Report No. 2 (SSER No. 2} on GIP 2, or else provide an alternative method for responding to GL 87-02.
The supplement also required that those addressees committing to implement GIP-2 provide an implementation schedule, and provide the detailed information as to.what procedures and criteria were used to generate the in-structure response spectra to be used for USI A-46.
In addition, the staff requested in SSER 2 that the licensee inform the staff in the 120-day response if they intend to change their licensing basis to reflect a commitment to the USI A-46 (GIP-2}
methodology for verifying the seismic adequacy of mechanical and electrical equipment, prior to receipt of the staff's plant-specific safety evaluation resolving USI A-46.
The licensee's response is unclear as to whether or not the licensee intends to implement both the SQUG commitments and the implementation guidance.
The staff interprets the licensee's response as a commitment to the *entire GIP-2 including both the SQUG commitments and the implementation guidance and therefore considers it acceptable. If the staff's interpretation is incorrect, then in accordance with Supplement 1 to GL 87-02, the licensee should provide for staff review, as soon as practicable prior to implementation, its alternative criteria and procedures for responding to GL 87-02. Additionally, the licensee should not merely follow the August 21, 1992, SQUG letter for implementing GIP-2 as stated in its submittal, but 9211230126 921113 PDR ADOCK 05000272 P
- Mr. Steven E. Miltenb~er November 13, 1992 should refer to Enclosure 2 to this letter, which provides the staff's response to the SQUG letter. The implementation schedule proposed by the licensee is within the 3-year response period requested by the staff in Supplement No. I to GL 87-02 and is therefore acceptable.
The staff finds the licensee's in-structure response spectra to be acceptable, based on the assumption that the statements made in the submittal, including the criteria and procedures used, correctly reflect what is contained in the FSAR on seismic design and other licensing bases.
The staff disagrees with the licensee's comments regarding the timing of the staff responses to additional information requested from a licensee. The licensee should refer to Item 1.2 in Enclosure 2 for the staff's position on this issue.
The licensee indicated that it intends to augment its licensing basis methodology, via 10 CFR 50.59, to include the GIP methodology as an alternative for verifying the seismic adequacy of new, replacement, and existing electrical and mechanical equipment prior to receipt of a final plant-specific SER resolving USI A-46.
The staff recognizes that the licensee may revise its licensing basis in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 {GIP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered by the GIP.
- However, if the licensee does not commit to implement both the SQUG commitments and the implementation guidance, and the licensee has not committed to any acceptable alternative criteria and procedures, then the staff does not believe that it is feasible, at this time, for the licensee to change its licensing basis in the manner described.
In addition, since the licensee intends to augment, rather than revise, its licensing basis methodology for verifying seismic adequacy of equipment, the staff cautions that it is not acceptable to combine any part of GIP-2 with the current licensing basis methodology such that it results in a less conservative approach than if GIP-2 or the current licensing basis methodology were a_pplied separately.
Enclosures:
- 1. Safety Evaluation
- 2.
Letter to N.
S~ith, SQUG, from J. Partlow, NRC, dated October 2, 1992 cc w/enclosures:
See next page DISTRIBUTION Docket File NRC & Local PDRs PDI-2 Reading SVarga
- Previously Concurred JCalvo CMil 1 er JStone MO' Brien MO' Brien JStone:rb
\\ I i;92 Sincerely,
/SI James C. Stone, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation OGC JWhite, RGN-1 ACRS{lO)
JNorberg EWenzinger, RGN-1 EMEB B*
JNorber
Mr. Steven November 13, 1992 should refer to Enclosure 2 to this letter, which provides the staff's response to the SQUG letter. The implementation schedule proposed by the licensee is within the 3-year response period requested by the staff in Supplement No. 1 to GL 87-02 and is therefore acceptable. The staff finds the licensee's in-structure response spectra to be acceptable, based on the assumption that the statements made in the submittal, including the criteria and procedures used, correctly reflect what is contained in the FSAR on seismic design and other licensing bases. The staff disagrees with the licensee's comments regarding the timing of the staff responses to additional information requested from a licensee. The licensee should refer to Item 1.2 in Enclosure 2 for the staff's position on this issue.
The licensee indicated that it intends to augment its licensing basis methodology, via 10 CFR 50.59, to include the GIP methodology as an alternative for verifying the seismic adequacy of new, replacement, and existing electrical and mechanical equipment prior to receipt of a final plant-specific SER resolving USI A-46.
The staff recognizes that the licensee may revise its licensing basis in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 (GIP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered by the GIP.
- However, if the licensee does not commit to implement both the SQUG commitments and the implementation guidance, and the licensee has not committed to any acceptable alternative criteria and procedures, then the staff does not believe that it is feasible, at this time, for the licensee to change its licensing basis in the manner described.
In addition, since the licensee intends to augment, rather than revise, its licensing basis methodology for verifying seismic adequacy of equipment, the staff cautions that it is not acceptable to combine any part of GIP-2 with the current licensing basis methodology such that it results in a less conservative approach than if GIP-2 or the current licensing basis methodology were applied separately.
Enclosures:
- 1. Safety Evaluation
- 2.
Letter to N. Smith, SQUG, from J. Partlow, NRC, dated October 2, 1992 cc w/enclosures:
See next page*
Sincerely,
~c. 4P5 James C. Stone, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Steven E. Miltenberger Public Service Electric & Gas Company cc:
Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street NW Washington, DC 20005-3502 Richard Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, NJ 07101 Mr. Calvin A. Vondra General Manager - Salem Operations Salem Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. S. LaBruna Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Mr. Thomas P. Johnson, Senior Resident Inspector Salem Generating Station U.S.* Nuclear Regulatory Commission Drawer I Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection CN 415 Trenton, NJ 08625-0415 Maryland People's Counsel American Building, 9th Floor 231 East Baltimore Street Baltimore, Maryland 21202 Mr. J.. T. Robb, Director Joint Owners Affairs Philadelphia Electric Company 955 Chesterbrook Blvd., SlA-13 Wayne, PA 19087 Salem Nuclear Generating Station, Units 1 and 2 Richard Hartung Electric Service Evaluation Board of Regulatory Commissioners 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. Frank X. Thomson, Jr., Manager Licensing and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 Mr. J. A. Isabella MGR. - Generation Department Atlantic Electric Company P.O. Box 1500 1199 Black Horse Pike Pleasantville, NJ 08232 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899 Public Service Commission of Maryland Engineering Division ATTN:
Chief Engineer 231 E. Baltimore Street Baltimore, MD 21202-3486