ML20118A745

Responds to Suppl 1 to GL 87-02 & Sser 2 on SQUG Generic Implementation Procedure,To Resolve USI A-46 & Suppl 4 to GL 88-20 Re IPE of External Events.Seismic Evaluation Rept Will Be Submitted by 950522.Technical Repts Encl

ML20118A745
Person / Time
Site:	Cooper
Issue date:	09/21/1992
From:	Horn G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20118A746	List: ML20118A745 ML20118A747 ML20118A748
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, GL-88-20, NSD921004, NUDOCS 9209250272
Download: ML20118A745 (5)

Text

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i GENERAL 0mCE P O DOM 4M. COLUWBUS, NEBRA$KA 6800244W Nebraska Public Power District "Tain'rlSO'*

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NSD921004 September 21, 1992 U. S. Nuclear Reguintory Commission Attention: Document Control Desk  !

Washington, DC 20555  !

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Subject:

Response to Supplement 1 to Generic Letter 87 02 Cooper Nuclear Station i Docket No. 50 298, DPR 46 [

References:

1) Letter to James G. Partlow (NRR NRC) from Neil P. Smith (SQUG) dated August 21,1992, "SQUG Response to Generic Letter 87 02, ,

Supplement 1 and Supplemental Safety Evaluation Report No.-2'-

on the SQUG GIP"

2) Letter (No. NLS8800486) to the NRC Document Control Desk from

• G. A. Trevors (NPPD) dated October 7, 1988 " Response - to Generic SER for Unresolved Safety Issue A 46" ,

3) Letter (No. NLS9100826)_ to the NRC Document Control Desk from G. R. Horn dated December 19, 1991, " Response ' to Generic Letter 88 20,_ Supplement 4, Individual Plant Examination of External Events - 10CFR50.54(f)" ,

f Gentlemen:

i I. INTRODUCTION On February -19, 1987, the Nuclear Regulator Commission (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 licensed utilities to participate in a generic program to resolve the seismic verification issues- associated v' h USI A 46. As a ,

result, the Soismic Qualification Utility Gtoup (SQUG)-dseloped the " Generic '

Implementation Procedure (GIP) for Seismic . VerificationL of Nuclear - Plant  ;

Equipment."- On May 122, 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 l NRC, within 120 days.c a; schedule for implementing the G1P. By letter (Reference 1)_ dated. August 21, 1992, to James G. Partlow NRR.NRC,- SQUG clarified that the 120 days would expire i on September 21, 1992. This letter responds to the Staff's request, s

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U.S. Nuclear Regulatory Commission September 21, 1992 Page 2 of 4 II, COMMITMENT TO CIP GIP Commitments As a saember of SQUG, the Nebraska Public Power District (District) cominits to use the SQUG nethodology as. doeurnented in the GIP, where the " GIP" refers to GIP Revision 2, corrected February 14, 1992, to resolve USI A-46 at the Cooper Nuclear Station (CNS) . The GIP, as evaluated by the Staff, permits licensees to deviate froin the SQUG committnents embodied in the Committnent sections, provided the Staff is notified of substantial deviations, prior to implementation. The District recognizes that the Staff's position in SSER 2 "is that if licenstes use other methods that deviate from the criteria and procedures as oescribed 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, the District hereby commits to the SQUG comrnitments set forth in the GIP in their entirety, including the clarifications, interpretations, and exceptions identified in the SSER 2 as clarified by the August 21, 1992 SQUG 1etter (Refarence 1) responding to SSER-2.

GIP Guidance The District generally will be guided by the remaining (non commitment) sections of the GIP, i.e. , GIP impleinentation guidance, which comprises suggested inethods for implementing the applicable commitments. The District will notify the NRC as soon as practicable, but no later than the final USI A 46 Suminary 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.

III. IN-STRUCTURE RESPO:ISE SPECTRA For defining seismic demand, the District will use_the options provided in the GIP for median centered and conservative, design in structure response spectra, as appropriate, depending on the building, the location of equipment in the building, and equipoent characteristics.

The licensing basis Safe Shutdown Earthquake 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 as described in the Updated Safety Analysis Report, developed consistent with standirds and guidance applicable to the plant at the time of licensing, and approved by the NRC in the SER (issued February 14,1973),

may be used and are considered to be conservative design spectra, The procedures and criteria which were used to generate the licensing-basis in-structure

response spectra are described in Attachments 1 and 2. Attachment 1 is the l

earthquake analysis of the Reactor-Building prepared by Earth Sciences for CNS on April 17, 1968. Attachment 2 is the earthquake analysis of the Control Building prepared by Earth Sciences on January 23, 1969. In accordanen with Section 4.2.3 of the GIP, the effective grade at CNS is considered to be 903' since a controlled, compacted backfill was established during original plant construction.

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U.S. Nuclear Regulatory Commission September 21, 1992 Page 3 of 4 IV. SCllEDULE in accordance with the District's previous response to Generic Letter 87 02 (Reference 2) and to Generic Letter 88 20, Supplement 4 (Reference 3), the District intends to in*:ograte and coordinate the A-46 and the Individual Plant Examination for External Events (IPEEE) seistnic reviews to the maximuin extent possible. The District plans to perform the combined seismic walkdown portion of the IPEEE and A 46 by the cotulusion of the first refueling outage scheduled to commence at least 180 days af ter all A 46 open issues are resolved, including approval of the attached licensing basir. spectra. A Seismic Evaluation Report summarizing the results of the A 46 program at CNS will be subtnitted to the NRC approxitnately 180 days following the walkdown completion.

Given the NRC acceptance of this submittal, along with the resolution af all open items by April 1994 (180 days prior to the 1994 refueling outage), the A 46 valkdown will occur during the 1994 refueling outage, currently scheduled to commence in October 1994. The Seismic Evaluation Report will then be submitted by May 22, 1995. This submittal date is in accordance with the three year guidance given in Generic Letter 87 02, Supplement 1. Please note that the A-46 program completion schedule may be affected by coordination with the seismic IPEEE response, the scope and schedule for completing the necessary SQUG training, 9nd by the availability of industry resources which may be unavailable because of the large number of licensees implementing this program. The District will inform the NRC if the completion schedule for the resolution of A-46 cannot be achieved 180 days following the 1994 refueling outage.

Please cont:-t me if you need more information.

Sin irely, G.

/iW Nu ear Power Croup Manager CIW/GRS/dnm Attachments cc: Regional Administrator USNRC Region IV Arlington, Texas NRC Resident inspector Cooper Nuclear Station 1

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I U.S. Nucicar Regulatory Commission l September 21, 1992 )

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STATE OF NEBRASKA)

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PLATTE COUNTY ) ,

G. R. Horn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this response on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.

L G.'R. Horn Subscribed in my presence and sworn to before me this 2 l N day of d d vio d h . 1992, EKML 801ARY4talt of Iskull

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