ML20118A702
| ML20118A702 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/14/1992 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR C321-92-2243, GL-87-02, GL-87-2, NUDOCS 9209250005 | |
| Download: ML20118A702 (3) | |
Text
.
i-e M NUCIGar
% ;'ge? 388 GPU Nuclear Corporauon forked River. New Jerr.oy J731038a 609 971-4000 Wnter's Direct Dal Numtw September 14, 1992 r321-92-2243 U. S. Nuclear Regulatory Commission
[
Attention:
Document Control 006 J
Washington, DC 20555 Gentlemen:
Subject:
Oyster Creek 14uclear Generating Station (OCNGS)
Operating License No. DPR-16 Docket No. 50-219 Response to Supplement I to Gcneric Letter d7-02 SQUG Ra;olution of US! A-46 On february 19, 1987, the NRC issuad Generic letter 87-02, " Verification of Seismic Adeouacy or Mechanical and Electrical Equipment la Operating Reactors, Unresolved Safety Is'un (USI) A-46".
This Generic Letter encouraged utilities to participate in a generic prowam to resolve the seismic-verification issues associated with USl 0 46.
As a result, the Seismic Qualification Utility -
Group ("SQUG") caveloped the " Generic Implemer.tation 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 Evaltiation 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 t
provide to the NRC, within 120 days, the following information.
By letter oated August 21, 1992, to James G. Partlow, NRR NRC, SQUG clarified that the 120 days would expire an September 21, 1992.
This letter responds to the Staf f's request.
NRC REQt)fSI:
A statement whether you commit to use both the SQUG cammitments and the-implementation guidance provided in GIP-2 as supplemented by the SSER No. ?
- for :he resolution of USI A-46.
In this case, any deviation from GIP-2, e supp aented by the SSER No. 2, must be identified, Justified, and documented.
if 3,, do not_ make such a commitment, you must provide your alternative for respi. Ming to GL 87-02.
DPU NUCLEALLhESPONSE:
As a member of SQUG, GPU Nuclear commits to use the SQUG methedology as documented in the GIP, where " GIP" refers to GIP Revision 2, corrected on N. Uod d' 9209250005 920914 PDR ADOCK 05000219
,' \\" b n
P PDR GPU Nucleur Corp; raw a is_a sutwdary of Genemi Pubhc U%te. Corporation
[
il9
m C321 92-2243 Page 2 februa'ry 14,-1992, to resolve USl A-46 at OCNGS. The GIP, as evaluated by the Staff, perr.its licensees to deviate from the SQUG commitments embodied in the Commitment sections, provided the Staff is r;otified of substantial deviations prior to implementation.
GPU Nuclear recognizes that the Staff's position in SSER 2 "is that if licensees use other methods that deviate from the crlieria and pr0cedures as described in SQUG commitments and in the implementation guidance of the GlP, Rev. 2, without prior NkC staff approval, the method may not be acceptable to the staff and, therefore, may result in a deviation from the provisions of" Generic Letter 07 02.
Specifically, GPU Nuclear hereby cLamits to the SQUG commitments set forth in the GIP including the clarifications, interpretations, and exceptions identified in SSLR-2 re clarified by the August 21, 1992, SQUG letter responding to SStR-2 with the following clarification.
SE11pn 3.1.1 "IdenUliqAtjgtoLS_jt[sthMpwn Pitttt" for the purposc cf USI A-46 resolutica " safe r.hutdown" is defined as bringing a plant to, arid maintaining it in. a hot shutdown condition during the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following ti SSE as discussed in Section 3.2.3 of GIP.
Since neither Oyster Creek Technical Specifications nor FSAR explicitly defines hot shutdown, the definition is provided belcw:
" Hot shutdown is the plant state in which the rea. tor is shut down, core cooling is maintained, and the fission aroduct decay heat and stored energy are being adequately removed from the reactor pressure vessel to the ultimate heat sink."
Our safe shutdown equipment list includes equipmsat necessary to reach the hot shutdown condition described above sIthin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an SSE.
SSIL_fiQuh_SIG1011_II 4,4-fL.9 The SSER No. 2 states that the rigid baseplate assumption should be vert fled prior to using the nNCll0R Code. We have contacted the program's author, Stevenson & Associates, crd they assert that the ANCHOR code is not formulated using a rigid baseplate assumption.
We were thformed by Stevenson & Associates that EPRl/SQUG is transmitting this information generically.
With respect to the GIP implementation guidance. GPU Nuclear generally will be guided by the rcmaining (non-commitment) sections of the GIP, i.e.,
CIP implementation guidance, which comprises suggestod meihods for implementing the arplicable commitments.
GPU Nuclear will notify the NRC as soon as practicab7e, 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.
tE.ELQESI:
, piJn-specific schedule for the imp'umentation of the gip and submission of a report to the staff that summarizes the results of the US! A-46 review, if
~ _ -. - _ -. _ _ _ _. _. _ _ - _ _ _
A C321-92-2243.
~
"Page!31 3
ELPJJN[SI (CONT'D)
.you are committing to implement GIP-2.. This schedul_e shall be such that _each affected plant will complete its implementation and submit the summary report q
within 3 yea's after the issuance of the SSER No. 2, unless otherwise justified.
GPU NUCl[f,R RESPONSf,:
q At this time, our plan is to complete and sub11t tha results of our U5! A-46 review by May 22, 1995. within three (3) year: af ter the issuanec of_ the SSER No. 2.
However, recognizing the allocation of in-hcuse resourcet ind j
availability of_ outside censultahts to support an expedited cr,mple' ion of the
-i 1MI-1 USI A-46 and IPEEE cfforts, and the currently planned wdkdowns in 15R outage (Winter 1994 and 1995) for the OCNGS US! A-46 and IEEEE, ccmpletion of 1
the OCNGS USI A-46 could be impacted. GPU Nuclear is expending ev ey effort to complete the OCNGS US: A-46 by May 22, 1995, but no later than September 30, 1995. The OCNGS Integrated Schedule is being resised accordingly.
This schedule reflects the most expeditious completion date possible considering esent outage schedules, t
clRC RE0VLSI:
The detailed information as to what procedures ai.d criteria were used to generate the in-structure response spectra to be used fo. USI A-46 as requested in the SSER No. 2.
The licensee's in-structure response spectra are considered acceptable for USI A-46 unlest the staff indicates otherwise during a 60-day review period.
fly _t[VLLEAR RESPONSE:
For defining seismic demand, GPU Nuclear will use the options provided in the-GIP-for median-centered and conservative design-in-structure response spectra,
~
as appropriate, depanding on the building, the location 'of equipment-in the l
building and characteristh ' of the specific piece ot equipment. When the l:
most appropriate option involves the use of SSE in-structure response spectra, L
GPU Nuclear intends to use newly developed in-structure response _ spectra.
These_ spectra are bcing developed) consistent with standards and guidance-alven L
i.n the NRC's Standard Review Plan and uses as input i,.te-specific ground
-response spectra approved by the NRC on May 18, 1992.
These spectra are considered by GPU. Nuclear to be conservative design responseLspectra.
If you have any questions concerning the information provided -in this letter, please call Mike Laggart, Manager, Corporate Licensing at (201) 316-7968.
Sincerely, w-s N.
1%
E John-J. Barton Vica President and Director Oyster Creek JJB/YN:1ga cc: Administrator, Reginn I NRC Oystur Creek Project Manager g
L Senior Resident-Inspector-m.
-.