ML20118A822
| ML20118A822 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/18/1992 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20118A823 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9209280220 | |
| Download: ML20118A822 (4) | |
Text
B ALTIM ORE GAS AND ELECTRIC 1650 CALVERT CLIFFS PARKWAY e LUSBY, MARYLAND 20067-4702 G r on a t C. C.
Frt simo ver Pae. sac t (410) 26D-M90 September 18,1992 U. S. Nuclear Regulatory Commission
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Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Generic Letter 87-02, Supplement 1 on Seismic Qualification UtiliLGroup (SQUG) Resolution of USI A-46
REFERENCES:
(a) le.ter from hir. J. G. Partlow (NRC) to hir. G. C. Creel (BG&E),
dated hiay 22,1992, Suppleme'111 to Generie Letter (GL) 87-02 that Trensmits Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on SQUG Generie Implementation Procedure, Revision 2, as corrected on February 14,199? (GIP)
(b)
Letter from SQUG to hir.
J.
G.
Partlow (NRC), dated August 21 1992, SQUG Response to Generic Letter 87-02, Supplement I and Supplemental Safety Evaluation Report No. 2 on the SQUG GIP Gentlemen:
This letter responds to Generm Letter 87-02 Supplement 1 (Reference a).
INTRODUCTION On February 19,1987, the NRC issued Generie Letter 87-02, "Verilication of Seismic Adequacy of hicchanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A46."
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 Genene hnplementation Procedure (GlP) for Seismic Verif;cMion of Nuclear Plant Equipment. On hiay 22, 1992, the NRC Staff issued Generic Letter 87-02, Supplement 1 (Reference a), which canstituted the NRC Staff's revicw of the GIP and transmitted Supplemental Safety Evaluation Report Number 2 (SSER-2) on the GIP, Revision 2, as corrected on February 14, 1992. The letter to SQUG enclosing SSER-2 requests that SQUG member utilities prmide to the NRC, within 120 days, a schedule for implementing the GIP. By letter dated k
August 21, 1992 (Reference b), SQUG clarified that the 120 days would expire on nr' September 21,1992.
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t Document Control Desk September 18,1992 Page 2 CONIMITMENT TO GIP GIP Commitments As a member of SQUG, Baltimore Gas and Eicctric Company (BG&E) commits to use the SOUG methodology as documented in the GlP, where GIP" refers to GIP Revision 2, as corrected on February 14,1992, to resolve USI A-46. 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. 11altimore Gas and Electric Comr.any recognizes and concurs with the Staft's position in SSER 2 concerning the use of other methods.
Specifically, BG&E does commit to the SQUG commitments set forth in tbc 9P, :ncluding the claritications, interpretations and exceptions identified in SSER-2 as clarified by Reference (b), with the exception of the following section.
Section 3.2.3 Safe Shutdown Defined The SOUU commitment is that safe shutdown is defined as bringing the plant to, and maintaining it in a Ilot Shutdown condition during the first 72 hot rs allowing a safe-shutdown earthquake (SSE).
r The llot Shutdown condition or Mode is defmed by o plant's Technical Specifications.
The safe shutdown definition in the GIP is in conflict with BG&E's definition. Calvert Cliffs is I; censed as a Hot Standby plant. Thus, BG&E defines the safe shutdown condition at Calvert Cliffs as bringing the units to a llot Standby condition and maintaining them there (no tim,: period is specified) following an SSE. Ilot Standby is defined in our Technical Specificatigns as having the reactors sub-critical and the average temperature equal -
't greater than 300 F, whereas llot Shutdown 's defined as sub-ciitical with the average temperature less than 300 F, but greater than 200 F. Safe shutdown for Calvert Cliffs is the 110t Standby Mode as defined in the Technical Specifications.
GIP Guidance Baltimore Gas and Electric Company will be generally guided by the remaining (non-commitment) sections of the GIP; i.e., GIP implementation guidance, which comprises suggested methods for implementing the applicable commitments. We 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 weil as for ot'c minor deviations, will be retained onsite for NRC review.
IN-STRUCTURE RESPONSE SPECTRA For defining seismic demand, we 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 equipment characteristics.
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a Document Control Desk September 18,1992
. Page 3 The licensing-basis SSE in. structure response spectra may be used as one of the options provided in~
t;1e GIP for resolution of USI A-46. The licensing basis spectra, as described in our Updated Final Safety Analysis Report, may be used and are considered to be " conservative design." The procedures and criteria which were used to generate the licensing-basis in-structure response spectra are described in Attachment (1).
l SCIIEDUI.E Given the large effort required to achieve resolution of USI A.46, final implementation must be carefully integrated with outage schedules and the seismic Individual Plant Examination of External Events (IPEEE) response. The completion of the IPEEE may be affected by the USI A-46 implementation start date, Considering the workload set forth by the criteria of the GIP, a Seismic Evaluation Report summarizing the results of the USI A-46 program at Calvert Cliffs Nuclear Power Plant Units 1 and 2 will be submitted to the NRC by June 30,1996. While this date is in excess of three years from the receipt of the final SER,it is based on our current schedule of planned refueling outages along with the necessary coordination required for our seismic IPEEE response. The
. USI A-46 program completion could be further affected by the scope and schedule for completing the necessary SOUG training and by the availability of industry resources which may be unavailable becauce of the large number of licensees implementing this program.
Regarding in-structure response spectra, we will assume that the Staff has accepted our spectra if they do not respond to us by accepting, questioning or rejecting the spectra within 60 days.
PIANT SEISMIC LICENSING IMSIS We may change our 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 P31 A-l'i. This change will be conducted under 10 CFR 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 in Reference (b).
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5 Documen'. Control Desk September 18,1992 Page 4 Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,A l,
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STATE OF MARYLAND 3
TO WIT COUNTY OF CALVERT I hereby certify that on the /7 day of _St>lt'mbf
,1992, before me, the subscriber, a Notary Public of the State of hlaryland in' and for Octio<r 1 C n.u vit/
personally appeared George C. Creel, being duly su~n and stater that he is Senior Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Alaryland; that he provides the foregoing response for the purposes thercia set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my lland and Notarial Scal:
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Notarj Public hly Commission Expires:
cn/ d [99
/Date GCC/Jh10/ dim Attachment cc:
Without Attachment D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. hicDonald, Jr., NRC T. T. h1artin, NRC P. R. Wilson, NRC R. I. hicLean, DNR J. H. Walter, PSC
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