ML20058K465
| ML20058K465 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1990 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20058K464 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 9007060109 | |
| Download: ML20058K465 (24) | |
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SUPPLEMENTAL SAFETY EVALUATION REPORT NO. 1 6
ON SEISMIC QUALIFICATION UTILITY GROUP 1
GENERIC IMPLEMENTATION PROCEDURE t
REVISION 1 FOR IMPLEMENTATION OF USI A-46 r
' VERIFICATION OF SEISMIC ADEQUACY OF OPERATING NUCLEAR PLANT EQUIPMENT l
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'9007060109 900629 PDR REVGP.ERGSOUG PDC x.
,.a SUPPLEMENTAL SAFETY EVALUATION REPORT NO. 1 BA':KGROUND -.
The Seismic Qualification Utility Group (SQUG) has ' developed a " Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment" for use by its members. The SQUG submitted the GIP, Revision 0, dated June 1988 (Reference 1) and the related documents and reports supporting
- the GIP for NRC staff review. The staff has reviewed these documents and has issued a Generic Safety Evaluation Report (GSER) on July 29, 1988 (Reference 2), recognizing that not all sections of the GIP had been developed.
Since then the SQUG has continued to develop the criteria and procedures for the new sections and to provide information for the resolution of open issues identified in Reference 2.
The SQUG submitted the GIP, Revision 1, dated December 1988 (Reference 3),
for NRC staff review. The GIP, Revision 1, contains essentially the same.
technical-topics as Revision 0 (Reference 1) except for'a new section on guidelines for evaluating the seismic adequacy of tanks and heat exchangers, and some refined and expanded information to resolve several outstanding i
issues. This Supplemental Safety Evaluation Report (SSER) No. 1 is to provide L
staff evaluation of GIP, Revision 1.
Due to the significant progress made i
after Revision 1 was submitted, some of the information provided in Part II of the GIP, Revision 1, became obsolete.
Because a complete evaluation of Part II l
- would not.be fruitful, this SSER No. I addresses only the staf f's evaluation This and positions on the issues contained in Part I of the GIP, Revision 1.
evaluation is provided in Enclosure 1.
As for Part II of the GIP. Revision 1, the' staff suggests that the SQUG should update the information to reflect the final' resolution of all open issues, should incorporate this information into Revision 2 of the GIP, and should submit the Revision 2 for staff review.
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1 PART I, GIP, REVISION 1 SQUG POSITION ON LICENSING ISSUES
1.0 INTRODUCTION
The last sentence of the " INTRODUCTION" section of Part I, GIP, Revision 1, "To the extent that the GIP differs from the Generic Letter and the NRC SER thereon, SQUG members will be guided by the GIP", is not acceptable to the staff.
If the SQUG members use the procedures or criteria described in the GIP that differ from the NRC SER, the issues will remain open and will be reflected in the plant-specific SER.
2.0
GENERAL COMMENT
S ON GENERIC LETTER 87-02 SQUG's general comments or positions on GL87-02 are listed below, followed by the NRC staff's views.
1.
- S:
"It is SQUG's understanding that the Generic Letter is intended as a guidance' document. As such, the use of what would appear to be unduly restrictive language-(e.g., "must") is confusing and would be interpreted to reduce the flexibility to effect resolution of USI A-46.
SQUG members will continue to interpret the Generic Letter as guidance."
- N: The position taken by SQUG in'this comment is acceptable to the staff.
2.
S:
"The Senior Seismic Review and Advisory Panel (SSRAP) was established to provide technical review of SQUG efforts to resolve USI A-46 by using experience data on equipment in industrial
- S Denotes SQUG comment or position.
N Denotes NRC staff comment or position.
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, facilities which had ')een subjected to strong motion seismic events. SSRAP's functions and responsibilities were. defined and agreed upon mutually by SQUG and the NRC Staff in 1982.
Its tenure was envisioned as coming to an end as a group at the completion of the development of the SQUG generic program.
SQUG may call upon SSRAP from time to time during the plant-specific implementation phase for assistance on generic matters. Use of SSRAP for such generic tasks will, however, be at the discretion of SQUG."
N:
The staff agrees.
3.
S:
" Licensees are required under 10 CFR Part 50 paragraphs 50.72 and 50.73 and by technical specifications to report any plant condition-which would have a significant adverse effect on safety.
SQUG does not believe that the Generic Letter imposes any additional reporting requirement or requires preparation of a justification for continued operation (JCO) unless necessary to meet existing regulatory requirements. Accordingly, SQUG licensees are required to report only conditions discovered during the A-46 review which meet the report thresholds of the regulations or plant-specific technical specifications, and will not provide JC0s unless warranted by the reporting requirements noted above.
Outliers discovered during implementation of the USI A-46 program will be documented as -
described in Section 9 of Part II of the GIP."
N:
The staff agrees with. the position that the Generic ' Letter does l
not itself impose any additional enforceable reporting requirements.
with the clarification that non-safety grade equipment selected by a L'
licensee.to satisfy USI A-46 requirements is not exempt from reporting.
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With respect to the provision regarding submittal of JCO's, the-L clear intent of the staff has not changed.
The objective, as stated in GL 87-02, is to provide assurance that the plant can continue to be. operated without endangering the health and safety of the public l
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S:
"The enclosure to the Generic Letter provides for the submittal of an A-46 summary report by each licensee upon the completion of the plant walkdown.
SQUG maintains that licensees which are utilizing the GIP for resolution may satisfy this report provision by referencing the GIP and providing a plant-specific summary report, including a proposed schedule for future modifications and replacements, where appropriate. Any reportable conditions discovered during the walkdown will be treated as discussed under general comment."
N:
In their plant-specific USI A-46 inspection reports. SQUG members can refer to the GIP for the procedures used for the walkdown inspection and the criteria and justifications for. these procedures.
The plant-specific report should include, as a minimum, the following:
(1) Description of earthquake input to be used for USI A-46 l
implementation.
(2) Description of shutdown path (s) chosen, operating procedures, and safe shutdown equipment list (including i
equipment floor elevation),
(3) Qualification of seismic review team (SRT) members.
i (4). All the relays identified for safe shutdown by listing the relay plant identification' numbers, the complete manu -
facturer's model numbers, and-their floor elevation.
(5) The results of-the walkdown inspection, including outliers and deficiencies.
(6) Proposed schedule for complete resolution, future modifica-tions and replacements, or a justification for not performing corrective modifications or replacements.
5.
S:
"The Generic Letter provides that in addition to the report 1
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report certifying completion of reviews and completion of resulting modifications and replacements.
The Generic Letter suggests that plant-specific SERs will not be issued until this second report is 4
submitted by the licensee. NRC has subsequently agreed, however, to
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issue plant specific SERs based upon the summary report of walkdown results. SQUG has agreed that each member utility will provide c.
j letter advising the NRC that any corrective actions identified in the walkdown report have been completed."
N:
The staff agrees. However, for some plants, the staff will either join the licensee for selected plant walkdown inspections,
,i or review the licensee's implementation summary report and conduct
. There& ter, the staff will f
plant-specific audits based on sampling.
issue a simple plant-specific evaluation.
6.
S:.
"SQUG maintains,that when a licensee has identif'ed outliers in 4
its summary walkdown report and provided justification for not performing a modification or replacement, the staff must provide a backfitting analysis before' ordering the' licensee to take such actions."
l N:
The " Regulatory Analysis for Resolution of USI A-46" (NUREG-1211) states:
"The staff concluded that the seismic adequacy review and
'the correction of all deficiencies as required by the generic letter are backfits as defined in 10 CFR 50.109." The backfit analysis justifying the seismic adequacy review was already provided in NUREG-1211. The staff will carefully review the licencee's justifications for n'ot correcting-identified deficiencies. The staff may request further information in cases where the licensee's determinations are deemed insufficient by the staff.
The staff may require correction of the deficiency when justified in accordance p
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- [ f. with the requirements of 10 CFR 50.109.
3.0. SPECIFIC COMMENTS ON GENERIC LETTER 87-02 S:
"In the section-by-section analysis below, specific SQUG positions Lare stated corresponding to specific statements in Generic Letter 87-02.
Some of the above general comments are restated in connection with specific language in the Generic Letter." The NRC staff coments for each SQUG position follow.
GENERIC LETTER STATEMENT
".,, the NRC has concluded that the seismic adequacy of certain equipment in operating nuclear power plants must be reviewed against seismic criteria not in use when these plants were licensed."
SQUG COMMENT AND NRC RESOLUTION S:
"Upon: completion of the A-46 program for a given facility the NRC staff will make a finding in its Safety Evaluation Report (SER) that the facility is considered to be in full compliance with the require-ments of General Design Criterion 2.
To be clear, SQUG maintains that after issuance of a final, plant-specific SER resolving A-46, no seismic requirement on mechanical and electrical equipment other than those imposed during the A-46 process will be necessary to provide reasonable assurance of public health and safety.
Accordingly, after issuance of the plant-specific SER resolving A-46, a licensee may revise the plant design bases relating to seismic requirements for mechanical and electrical equipment to reflect the A-46 resolution.
In. addition, it is understood that utilities completing the A-46 resolution will not be required to separately address USI A-40 f
(Seismic Design Basis), as it applies to seismic adequacy of tanks
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1 and heat exchangers, or USI A-17 (Systems Interactions), as it applies to spatial interactions.
N:
The SQUG's position is stated too broadly in several respects, e.g.:
(1) The term "... full compliance with the requirements of GD-2..."
seems to imply that the USI A-46 resolution is intended to address issues other than seismic qualification, i.e.,
including the non-seismic aspects of GDC-2; that is not the case.
)
(2) With respect to seismic qualification requirements (other than the approved USI A-46 (GIP) criteria / methodology)* that may apply to equipment within the scope identified in a plant-specific SER, except as specifically approved by the staff, the USI A-46 (GIP) criteria /methodologywouldnotsupersedeanyseismic qualification requirements imposed or committed to in connection-with the resolution of other specific issues (e.g., Regulato'ry Guide 1.97, TMI Action Item II.F.2, and Individual Plant Examination.
for External Event).
(3) With respect to revision of a plant's design bases by a licensee af ter issuance of the plant-specific SER resolving USI A-46, the licensee may in accordance with 10 CFR 50.59 revise the licensing bases (not the plant design bases, as stated by In the terminology used' currently by the NRC staff, the USI A-46 (GIP) methodology is not a " seismic qualification" procedure.
Rather, the 4
application of the USI A-46 procedure verifies the seismic adequacy of-equipment; this is an approved alternative method for satisfying the pertinent equipment seismic requirements of GDC-2 for identified equipment in the affected plants.
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8-l SQUG)'intheFSAR,toreflectthattheUSIA-46(GIP)-
methodology will henceforth be used for verifying the seismic adequacy of existing and new or replacement mechanical-and electrical equipment within the current approved experience data base. This revision is applicable only for equipment in i
the identified scope covered by the plant-specific USI A-46 SER.
(See Item 2 at pages 8 thru 10 below for extending the scope of plant equipment to which the revised licensing bases apply, and for treatment of new or replacement equipment under the revised licensing bases.)
The SQUC understanding with respect-to the last point addressed.in their position is correct, i.e., utilities successfully completing the USI'A-46 review,. including tanks and heat exchangers and seismic spatial systems interactions, will not be required to address these issues under USI A-40 and USI A-17.
SECTION 1:
SCOPE OF SEISMIC ADEQUACY REVIEW 1.
"Each licensee will determine the systems... [H]owever, the effects of transients that may result from ground shaking should be considered."...
"Offsite: power may be lost during or following a seismic event."
S:
"Section 3.3 of Part II of the GIP sets forth the assumptions to be used by SQUG members.
Transients to be considered will-be deter-mined by each licensee according'to the licensing basis for the plant. Loss of offsite power will be assumed for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />."
N:
The staff agrees.
2.
"The equipment to be included is generally limited to active mechan-ical and electrical components and cable trays."
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"Section 3.2 of Part II of the GIP identifies the scope of safe-
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shutdown equipment to be considered in the A-46 review.
Equipment within the scope of Regulatory Guide 1.97 is not required to be seismically qualified unless that equipment is also required to achieve or maintain safe shutdown for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />."
N:
The staff considers it acceptable to extend the use of USI-l
' A-46 criteria to all mechanical and electrical equipment in SQUG plants, if and only if the following conditions are satisfied:
The equipment is reviewed and/or inspected in accordance with a.
the GIP.
b.
Equipment changes and modifications are performed in accordance with the GIP.
c.
For new or replacement equipmeat:
(1)
If it is identical to the equipment originally installed in the plant, the criteria and procedures in the GIP apply.
(2)
If it is not identical to the equipment originally installed in the plant, the licensee may, on a case-by-case basis, establish the equipment's similarity to the installed equipment. The definition of similarity includes the following elements: (1) Excitation, (2) dynamic properties and operability, and(3)dynamicresponse. After the similarity is established, then the criteria and procedures in the GIP apply.
(3)
If it is not identical to the equipment originally installed in the plant and the similarity is not established, its seismic adequacy may be verified by conducting a plant and equipment specific evaluation using the approved USI A-46 procedures, or i
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..~ at'the licensee's option, application of current seismic
-qualification criteria or other means acceptable to the staff.-
The USI A-46 (GIP) methodology is acceptable and sufficient for -
verifying the seismic adequacy of commercial grade equipment to be dedicated for safety-related purposes; for other (non-seismic) critical characteristics'of equipment to be dedicated, licensees are referred to the guidance / requirements
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delineated in GL 89-02 and GL 89-09 which include applicable criteria of 10 CFR Part 50, Appendix B.
d.
The GIP is to be maintained in a usable form in the future, with-NkC.
approval of significant changes.
Except as specifically approved by the NRC staff, USI A-46'(GIP) criteria / methodology do not supersede
. any seismic qualification requirements imposed or comitted to in connection with the resolution of other specific issues (e.g.,
-Regulatory Guide 1.97, Three Mile Island Action Item II.F.2, and E
Individual Plant Examination for External Events).
3.
" Seismic system interaction is included in the scope of review to the extent that equipment within the scope must be protected from seismically induced physical interaction with all structures, piping, or equipment located nearby."
Si
'" Seismic interaction is addressed in Section 4.5 of Part II of the GIP.
SQUG members will interpret " nearby" as set forth in the m
GIP."
N:
The staff agrees with this interpretation.
4.
" Instrument air lines and electrical and instrumentation cabling must be verified to have sufficient flexibility from the connection to equipment so that relative movement of anchor points will not jeopardize
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S:
"The adequacy of instrument air-line. flexibility and cable slack j
will be observed during the walkdown and evaluated using engineering 6
judgment."
N:
The staff agrees with this comment.
5.
"Each licensee must identify equipment necessary to bring the plant to a hot shutdown condition and maintain it there for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Ifmaintainingsafeshutdownisdependentonasingle(not redundant) component whose failure...could preclude decay heat removal by the identified means, the licensee must show that at least one practical alternative for achieving and maintaining safe shutdown exists that is not dependent on that component."
S:
"a) Section 3 of Part 11 of the GIP contains guidance on identifi-cation of safe-shutdown equipment.
Application of the 72-hour criterion to some plants may be inconsistent with other aspects of their licensing basis.
Plant-specific reports will. discuss deviations from this guideline.
b) With regard to the need for equipment redundancy, special consideration should be given to plants with installed dedicated shutdown systems designed specifically to respond to abnormal events."
N:
a) _ The USI A-46 review is a backfit and is independent of the plant' licensing bases. Therefore, the plant's licensing basis being
'different from the stated 72-hour limit is not an acceptable justification for failing to meet this criterion.
Deviations from the 72-hour hot shutdown period will be considered on a case-by-case
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b) The staff agrees.
" Typical plant functions would include... (3) Maintain control 6.
room functions and instrumentation and controls necessary to monitor hot shutdown."
1 S:
"SQUG makes two observations:
(1) the reference to the control room does not preclude reliance on local instrumentation, and (2) This guidance only applies after the period of strong shaking."
N:
(1)and(2) The staff agrees.
SECTION'2:
GENERAL VERIFICATION PROCEDURE FOR PLANT-SPECIFIC REVIEW 1.
"The inspection team must consist of as a minimum, (1) an experienced structural engineer familiar with seismic anchorage requirements, (2) an experienced mechanical engineer familiar with plant mechanical equipment, and'(3) an experienced electrical engineer familiar with plant electrical equipment."
S:
'"This guidance does not allow adequate flexibility in the selection of review team members.
In many cases engineers may become experts, based on experience and training, in fields different from those in which they hold a specific degree. SQUG utilities will qualify seismic review personnel pursuant to Section 2, Part II, of the GIP."
N:
The intent of this requirement is to ensure that the inspection team members possess adequate qualifications to perform the review.
The staff is aware that in certain special cases experience and training
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.. may provide adequate qualification in lieu of a specific degree in the fields mentioned.
In those cases, the requirement for specific degrees may be waived.
However, the licensee must justify the selection of persons not meeting this criterion.
The staff continues to be concerned about the expertise of the team members, and the degree requirement should in general be met by the team members.
2.
"The walk-through inspection must cover... identification of potential ' deficiencies' and ' outliers'."
' Deficiency' in this context means equipment... identified as obviously inadequate by the A-46 criteria... and confirmed as inadequate by further engineering studies.
S:
"The only apparent need for the definition of " deficiency" is that it is later used to trigger the JC0 requirement. As explained in General Comment 3, SOUG does not agree that separate A-46 JCOs are riecessary.
SQUG licensees will report observed deviations from their licensing basis in accordance with 10 CFR Part 50.72 and 50.73 and technical specifications."
N:
See NRC staff response to General Comment 3.
3.
...the licensee will be required to verify that the appropriate data base i
spectra envelop the site free field spectra at ti.' ground surface defined for the plant.'"...
"For equipment above 40 feet, one-and-one half times the appropriate data base bounding spectrum...must envelop the floor-response spectra for the equipment.
For those cases where floor-response spectra are needed...i" S:
"If the seismic demand study being unde ~rtaken by EPRI shows that other multipliers can be justified in place of the 1.5 factor, then SQUG will submit this in a revision to the GIP for review by the SSRAP and approval by the NRC."
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The staff agrees.
4.
"The walk-through inspection must cover the following: (1)... verify equipment anchorage...using the guidance provided in paragraph 3 below..."
S:
"The spectral acceleration used in performing the anchorage verification should be taken from either -the floor-response spectra or the free field horizontal ground-response spectra, and not from the bounding curves on page 11 of the Generic Letter Enclosure."
N:
The staff agrees. This procedure is in fact stated on page 5 of the enclosure to the generic letter.
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"The licenseee must specify all equipment t
function during the period of strong shaking.
- ne licensee must demonstrate the operability of these items by means other than comparison with the experience data base; otherwise, the licensee must determine that any change of state will not compromise plant safety.
The period of strong shaking is defined to be the first 30 seconds of the seismic event and-should be considered in conjuction with the loss of offsite power. On the basis of the seismic experience data gathered to date, the only concern remaining on equipment functional capability'is the concern regarding relays.
Contactors and switches are considered as relays in this context.
In addition, mercury switches are known to malfunction during testing and should be replaced by other types of j
qualified switches. Unless the test data being collected by the Electric Power Research Institute (EPRI) and the NRC Office of Research (RES) reveal otherwise, certain types of relays are the only equipment whose-funtional capability will
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need to be verified." "In addition, credit can be taken for timely operator, action to reset the relays in case change of state occurs during an SSE, l
provided detailed relay setting procedures are developed...."
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5:
"With regard to review of relays (including contactors and switches),
additional guidance now being developed by SQUG and EPRI will be available
- a. a revision to the EPRI Relay Evaluation Procedure (Reference 8). This guidance will identify the scope of relays to be reviewed and the circum-stances under which operator action can be credited.
Section 6 of Part !!
of the GIP provides a sunenary of the relay functionality review. "
N:
The staff agrees.
Staff review of the final procedures developed by the SQUG will be covered in the future SER supplement.
6..
"If a utility replaces components for any reason, each replacement must be verified for seismic adequacy either by using A-46 criteria and methods or... qualifying by current licensing criteria."
S:
"SQUG interprets this section as follows:
1)
Some flexibility should be allowed in considering the safety function of the component; for example, an essential relay versus a relay which can be allowed to change state in an SSE and then be reset.
2)
Replacement equipment which is qualified under A-46 guidelines i
and criteria is also acceptable.
3)
A-46 criteria and methods can be used for all seismic qualification."
N:
- 1) There is indeed some flexibility in relay evaluation as described inSectionIV.4.0ofNUP.EG-1211(RegulatoryAnalysisforUSIA-46).
To summarize for the purpose USI of A-46 relay evaluation, relays in general can be classified into three categories as follows:
(a) Essential relays that are required to function during an SSE without chatter.
For these relays, the requirement is not flexible.
They
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t,_ t should be qualified by tests consistent with current licensing requirements, verified by comparison with test data base, or replaced by qualified relays.
(b) Relays that chatter during SSE will not affect hot shutdown.
For these relays, nothing is required.
(c) However, relays that may chatter and change state during SSE cre not essential.
For these relays, in addition to the requirement similar for essential relays, other options can be used.
One option is to take credit for timely operator action to reset the relays, provided reset procedures are in place and the operator has sufficient time to reset.
2)
The staff agrees with this comment, provided that conditions specified in Item 2 of Section 1 on page 8 are satisfied.
3)
The phrase " seismic qualification" should be changed to " seismic adequacy verification."
For the applicability of USI A-46 criteria and methods, see the NRC response to Item 2 of Section 1 on page 8.
SECTION 3:
VERIFICATION OF ANCHORAGE 1.
" Torque on bolts can normally '. ensured by a preventive maintenance and !nspection program."
S:
"SQUG interprets this to mean that a new inspection / maintenance program beyond that already required by 10 CFR Part 50 Appendix B is not required.
Also, during the individual plant walkdown, tightness testing f
of bolts and visual inspection to determine that bolts are not missing or i
obviously loose are covered in Section 4.4 of Part 11 of the GIP."
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The staff agrees.
SECTION 4:
GENERIC RESOLUTION 1.
"(Coments on the role of the SSRAP envisioned in this section will 1
not be repeated)."
S:
"See General Connent 2."
J N:
See the NRC staff response to General Comment 2.
2.
'"Each utility must submit an implementation schedule to the NRC within 60 days of receipt of the A-46 letter."
S:
"This guidance has already been modified."
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N:
The staff agrees.
Please see the letter from T. Murley to N. Smith, dated November 19, 1987.
3.
"Each utility must submit to the NRC an inspection report that must include... justification for continued operation (JCO) if these deficiencies dre not corrected within 30 days..."
S:
" Paragraphs 50.72 and 50.73 of 10 CFR Part 50, and technical
)
specification reporting requirements, are adequate for reporting of seismic deficiencies discovered during the A-46 reviews.
(see General Connent 3)."
N:-
SeetiieNRCstaffresponsetoGeneralComment3.
4.
" Consultants to the generic group must perform audits of plant-I
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-, specific reviews.
All plants must be audited."
S:
"S.QUG does not plan to provide for third-party audits."
N:
The NRC staff acknowledges that it is the NRC's responsibility to conduct any audits.
The staff will conduct audits on some selected l
plants.
If plant-specific implementation is found to be deficient during the audit, tbt staff may require a third party audit.
S.
"(7) Final approval of the implementation will be made by the NRC in r
the form of. a plant-specific Safety Evaluation Report for each affected plant af ter the NRC received a final report from the utility involved certifying completion of implementation reviews and equip'nent and anchorage modifi-cation and replacements."
S:
"See General Comment S."
N:
See the NRC staff response to General Comnent S.
4.0 SQUG RESPONSES TO THE NRC SER ON REVISION 0 0F THE GIP *
" Stated below are SQUG positions on certain statements made in the NRC SER issued July 29, 1988.
The responses are coded by SER paragraph."
I.A. S:
"SQUG does not agree with the SER statement that equipment "may not have been adequately qualit *d to ensure its survival and functionality in the' event of a safe shutdown earthquake (SSE)."
It is SQUG's position -
that there has been and is adequate margin in the seismic capacity of "Notethattheprevioussection(Section3.0)containsSQUGpositionswhich are addressed in the Appendix to the NRC SER."
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w equipment in older operating plants.
The two trial plant walkdowns have demonstrated that the seismic capacity of equipment in USI A-46 plants is adequate. The purpose of USI A-46 is to verify that this is the case for all US! A-46 plants."
N:
The staff believes that the unanchored equipment found during the 1
two trial plant walkdown inspections belong to the category of equipment f
described by the sentence.
1.B. 5:
"The statement regarding the " intent of GDC-2" is incorrect.
j Completion of USI A-46 implementation will verify that specific plants are in compliance with GDC-2."
N:
The successful completion of the USI A-46 implementation will verify the seismic adequacy of the equipment to which the USI A-46 methodology has been applied by the licensee; and this will constitute compliance withtherequirementsofGDC-2(inthoseniantswhereGDC-2 applies)for the identified equipment in regard to the issue of seismic qualification.**
II.A.1 S: "SQUG does not consider it necessary to address operability of the equipment identified for USI A-46 since it is censidered extremely unlikely that an earthquake would occur concurrently with having redundant components out-of-service.
NRC coments made at the SQUG meeting in Maine on August 10 and 11, 1988, appeared to concur with that position.
Accordingly.
I Sections 3.1.2.4 and 3.3.7 of the GIP will be deleted."
N:
The staff has some concern about deleting Sections 3.1.2.4 and 3.3.7 of GIP, Revision 0.
The staff agrees that it is unlikely that an earthquake
' '
- See footnote on page 7.
t
. will occur at the same time that redundant components are out of service, provided that the allowable outage time is appropriately limited or strictly controlled by plant technical specifications.
However, the statement in paragraph 3.1.2.4 of GIP, Revision 0, is important and should be retained.
In addition, the second sentence of the second paragraph in Section 3.3.6 of GIP, Revision 1, should be modified as i
fo'llows:
"If an item of equipment is taken out of service for maintenance and the allowable outage time is controlled by technical specification or appropriately limited, then that item of equipment is considered the single-failure equipment for the purposes of this procedure."
With these changes, the deletion of Section 3.3.7 of GIP, Revision 0, is acceptable.
11.D.1.1.1.
S:
"In each place where the staff states that it "is in general agreement" with the GIP's approach subject to stated exceptions, the SER should state unequivocally that the staff fully concurs with the GIP approach except as otherwise noted.
Specific utility comitments can be made only upon explicit staff concurrence with the GIP."
N:
The staff believes that the phrase used in the SER was appropriate because the caveats or exceptions identified wer: r,ct complete; no change will be made to the SER.
However, this supplement documents the progress in resolving significant regulatory issues that have been raised regarding implementation of the USI A-46 methodology.
And the staff intends to document in the SER Supplement 2 its basis for acceptance of, or exceptions to, the remaining open technical issues associated with the USI A-46 methodology.
It is intended that specific utility comitments
.may then be made and plant walkdowns may commence.
II.D.1.1.a.2.
S:
"SQUG interprets " postponement" to mean delay beyond the
+
'. '. outage the utility has agreed to complete the work."
N:
The staff interprets " postponement" to mean delay to the upcoming or next fuel outage.
!!.D.1.1.c.1.c.
S:
"SQUG interprets " postponement" to mean delay beyond the outage the utility has agreed to complete the work."
i N:
The staff interprets " postponement" to mean delay to the upcoming or next fuel outage.
II.D.1.3. S:
"SQUG's position is that the licensee shNid have the option of using plant-specific criteria or the USI A-46 criteria for new installa-tions."
N:
The staff's position is that for new installations, modifications, or replacements of equipment anchorage (anchor bolts or welds), the current licensing criteria and procedures or USI A-46 criteria and procedures, whichever is more conservative, shall be used.
II.D.1.5. S:
"SQUG understands that the NRC will permit A-46 criteria for modified or repaired anchorages; but will require meeting current allowables for new and replaced anchorages."
N:
See the NRC staff response to Item II.D.1.3.
III.C.2.1.a.
S:
"The SQUG position is stated in the section-by-section analysis of the Generic Letter, Section 3.0 above, at page 8 "
N:
This issue relates to the recognition, documentation, and reporting of the deficiencies of equipment found in the walkdown inspections.
See the NRC staff response to Item 2, Section 2 of Specific Comments, or General Comment 3.
o;.
Y
', s.
- III.C.2.1.b S:
"The SER statement that licensees can report deficiencies under 10 CFR 50.72, 73 "or file a JC0" is incorrect.
The obligation to report under the regulations is independent of whether or not a JC0 must be prepared.
In most cases, where a JC0 is warranted, it need not be filed with the NRC unless, for example, a Tech Spec change is required to permit continued operation."
N:
See the NRC sts.ff response to General Comment 3.-
g.
3 I
,. REFERENCES 1;
" Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant. Equipment," Revision 0. Seismic Qualification Utility Group, June 1988.
2.-
"NRC Generic Safety Evaluation Report on the Seismic Qualification Utility Group Generic Implementation Procedure, Revision 0, for Imple-mentation of USI A-46," July 29,1988.
3.
" Generic Iralementation Procedure (GIP) for Seismic Verification of Nuclear Plant. Equipment " Revision 1, Seismic Qualification Utility Group, December 1988.
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