ML20118A944

Forwards Response to GL 87-02,Suppl 1, Seismic Qualification of Util Group Resolution of USI A-46. Util Will Utilize Options Provided in Generic Implementation Procedure for median-centered in-structure Response Spectra

ML20118A944
Person / Time
Site:	Fort Calhoun
Issue date:	09/21/1992
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, LIC-92-301R, NUDOCS 9209290108
Download: ML20118A944 (4)

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Ort.aha Public Power District 444 South 16th Street Mall Omaha Nebraska 68102-2247 402/636-2000 September 21, 1992 LIC-92-30lR U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P'-137 Washington, DC 20555 i

References:

1. Docket No. 50-2G I

2. NRC Generic Letter 87-02, dated Febrt' cry 19, 1987

3. Letter from OPPD (K. J. tiorris) to NRC (Document Control Jask)

dated December 2, 1988 (LIC-88-506) i 4. NRC Generic Letter 87-02, Supplement 1, Dated May 22, 1992

5. Letter from OPPD (W. G. Gates) tc NRC (Docuent Control Desk) dated July 31, 1992 (LIC-92-016R)

, 6. Letter from Seismic Qualification Uti'ity Group (N. P. Smith) to NRC (J. G. Partlow) dated August 21, 1992

Gentlemen

J

SUBJECT:

Response to Generic letter (CL) 87-02, Supplement 1, Seismic j Qualification Utility Group (SQUG) Resolution of Unresolved Safety Issue (USI) A-46, for Fort Calhoun Station Unit No.1 ,

4 Attached is the Omaha Public Power District response to GL 87-02, Supplement 1.

This response is being submitted under oath as requ rea. i If you should have any questions, please contact me.

Sincerely, l& hl hllu

W. G. Gates i Division Manager '

Nuclear Operations .

WGG/grc >

Attachment

< c: LeBoeuf, Lamb, Leiby & MacRae J. L. Milhoan, NRC Regional Administrator, Region IV

k. P. Mullikin, NRC Senior Resident Inspector 4

S. D. Bloom, NRC Project Manager 4

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Omaha Public Power District. Docket No. 50-285 (Fort Calhoun Station Unit No. 1) )

AFFIDAVIT -

W. G. Cates, being duly sworn, hereby deposes and says that he is the Division i

Manager - Nuclear Operations of the Omaha Public Power District; that as such he l is duly authorized to sigr. and file with the Nuclear Regulatory Commission the l attached information concerning the response to Generic Letter 87-02, Supplement 1, dated May 22, 1992; that he is familiar with the content thereof: and that the matters set forth therela are true and correct to the best of his knowledge, information, and belief.

N $ JNL, W. G. Gates Division Manager

( Nuclear Operations STATE OF NESRASVA ss COUNTY OF DOUGLAS Subscribed and sworn to .before me, a Notary Public in and for the State of Nebraska on this 2 /sr day of September, 1992.

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! Att'achment i LIC-92-3CIR Page 1 l

j Omaha Public Power District Response to Generic letter (GL)lution Reso of87-02, Supplement 1 j Seismic Qualification Unresolved Utility Safety Issue Group A-46, for Fort(SQUG)lhoun Ca Station i

I, INTRCDUCTION

, On February 19, 1987, the NC 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 i

encouraged utilities to participate in a generic program to resohe the

seismic verification issues associated with USI A-46. As a result, the i

Seismic Qualification Utilit Group (SQUG) developed the Generic Implementation Procedure (GIP)yfor Seismic Verification of Nuclear Flant Equipment. On May 22, 1992, the NRC Staff issued Generic Lettar 87-02 Supplement 1, which constituted the NRC's review of the GIP and which included Supplemental Safety Evaluation Report Number 2 (SSER-2) on the i

GIP, Revision 2, corrected on February 14, 1992. This requested that SQUG i member utilities provide to the NRC, within 120 days, a schedule for 4 implementing the GIP. By letter dated August 21, 1992, to James G.

Partlow, N3R-NRC, SQUG clarified that the 120 days would expire on

. September 21, 1992.

II. COMMITMENT TO GIP ,

QF Commitments

! As a member of SQUG, Omaha Public Power District (0 PPD) comnits to use the i SQUG methodology as documented in the GIP (where " GIP" refers to GIP Revision 2, corrected Fet'ruary 14, 1992) to resolve USI A-46 at Fort Calhoun Station (FCS). The GIP, as evaluated by the NRC Staff, permits licensees to deviate from the SQUG commitments embodied in the commitment j ,

.tions, provided the NRC st,.ff is notified of substantial deviations i

pr 3r to implementation. OPPD recognizes that the NRC's position in SSER-2 "is that if licensees use other methods that deviate from the criteria

! and p:ocedures as descrii ed in SQUG commitments and in the implementation guidance of tne GIP, kevision 2, without prior NRC staff approval, the 1 method may not be acceptable to the staf f and, t' erefore, may result in a 1 deviation from the provisions of" Generic letter 87-02.

Specifically, OPPD hereby commits to the SQUG commitments set forth in the GIP in their entirety, including the clarifications, interpretations, and exceptions identified in SSER-2 as clarified by the August 21, 1992, SQUG

letter responding to SSER-2.

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Attachment 2

LIC-92-30lR -

Page 2 MP Guidance Generally, OPPD will be guided by the remaining (non-commitment) sections of the GIP, i e., GIP implementation guidance, which comprises suggested methods for implementing the applicable GIP commitments. OPPD will notify j tb NRC as soon as practicable, but no later than the final USl A-46 l- st. unary 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 by 0 PPD for NRC review.

Ill. IN-STRUCTURE RESPONSE SPECTRA l For defining seism!c demand, OPPD will use the options provided in the GIP for median-centered and conservative design in-structure response spectra,

. as appropriate, depending on the building, location of equipment in the building, and equipment characteristics.

For most equipment, OPPD intends to use the licensing-basis SSE ground or in-structure response spectra as described in the FCS Updated Safety ,

Analysis Report (USAR) Appendiy F, Section F.2.2.3, as one of the

" conservative design" spectra options provided in the GIP for resolution of USI A-46. For outlier resolution and for some equipment (e.g., intake structure equipment for which no design basis in-structure spectra exist ,

OPFD intends to optionally use, after NRC approval, the Alternate Seism}c i Criteria and Methodologies (ASCM) as " median-centered" SSE spectra for Fort Calhoun Station, as submitted by References 3 and 5. Procedures and criteria specific to the ASCM are described in these submitt.ls.

IV. SCHEDULE Given the magnitude of the effort required to achieve resolution of USI A-46, final implementation must be carefully integrated with outace schedules and the seismic IPEEE response, the completion of which will 6e 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 A-46 program at FCS will be submitted to ,

the NRC by September 29, 1995. This date is consistent with the guidance in Section II.4.2 (Page 14) of SSER-2 for. the -GIP, and corresponds to 3 years plus 60 days from the date of the Reference 5 submittal, which substantially updated the ASCM. This schedule assumes acceptability of the ASCM.

V. PLANT SEISMIC LICENSING BASIS l

OPPD may change, including adoptwa of the GIP, its licuising basis methodology for verifying the seismic adequacy of existing, new and i replacement electrical and mechanical equipment. If this is necessary, a-schedule will be provided prior to-the receipt of. a final plant-specific SER-resolving USI A-46. 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, Rcvision 2, and with the clarifications, interpretations, and Exceptions identified in SSER-2 as clarified by the August SQUG 1etter responding to SSER-2. Any necessary changes to the USAR wil21,1992, l be provided in accordance with 10CFR50.71(e).

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