ML20127P208
| ML20127P208 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/20/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127P189 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9212020131 | |
| Download: ML20127P208 (3) | |
Text
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ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED T0 120-DAY RESPONSE TO SUPPLEMENT NO. 1 TO GENERIC LETTER 87-02 DUOVESNE LIGHT COMPANY OHIO EDIS0N COMPANY PENNSYLVANIA POWER COMPANY BEAVER VALLEY POWER STATION. UNIT NO. 1 QOCKET NO. 50-334
1.0 INTRODUCTION
By letter dated September 22, 1992, Duquesne Light Company (DLC), submitted its response to Generic Letter 87-02, Supplement No.1 (the supplement),
" Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," dated May 22, 1992, for the Beaver Valley Power Station, Unit 1 (BVPS-1).
15 the supplement, the staff requested that licensees submit the following information within 120 days of the issue date of the supplement:
1.
A statement whether the licensee commits to use both the Selsmic Qualification Utility Group (SQUG) commitments and the implementation guidance provided in the Generic Implementation Procedure, Revision 2 (GIP-2) as supplemented by the staff's Supplemental Safety Evaluation Report No. 2 (SSER-2) for the resolution of USI A-46.
In this case, any deviatior, from GIP-2, as supplemented by the SSER No. 2, must be identified, justified, and documented.
If the licensee does not make such a commitment, it must provide its alternative for responding to GL 87-02.
2.
A plant-specific schcdule for the implementation of the GIP and submission of a report to the staff that summarizes the results of the USI A-46 review, if the licensee is committing to implement GIP-2. This schedule shall be such that each affected plant will complete its implementation and submit the summary report within 3 years after the issuance of the SSER No. 2, unless otherwise justified.
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The detailed information as to what procedures and criteria were used to generate the in-structure response spectra to be used for USl A-46 as requested in the SSER No. 2.
The l':ensee's in-structure response spectra are considered acceptable for USI A-46 unless the staff indicates otherwise during a 60-day review period.
In addition, the staff requested in SSER No. 2 that the licensee inform the staff in the 120-day response if it intends to change its licensing basis to reflect a commitment to the USI A-46 (GIP-2) methodology for verifying the seismic adequacy of mechanical and electrical equipment, prior to receipt of the staff's plant-specific safety evalua mn resolving USI A-46.
2.0 EVALV61103 With regard to item 1, DLC stated, "Specifically, DLC commits to the SQUG commitments set forth in the GIP in the<? entirety, including the clarifications, interpretations, and exceptions identified in SSER-2 as clarified by the August 21, 1092, SQUG letter responding to SSER-2." DLC stated further that "DLC generally 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 commitment."
DLC's response is not clear as to whether it intends to implement both the SQUG commitments and the implementation guidance.
In accepting GIP-2 as a method for resolving USl A-46, it was the staff's understanding that the SQUG members who chose to implement GIP-2 would use essentially the entire procedure including the SQUG commitments, which contain the general programmatic objectives and goals, and the implementation guidance, which contains the specific criteria and procedures to be used for the resolution of USI A-46.
This understanding was the basis for the staff's position which was stated in SSER No. 2 that if the SQUG member commits to use GIP-2 for the implementation of USI A-46, it must commit to both the SQUG commitments and the use of the entire implementation guidance provided in GIP-2, unless otherwise justified to the staff.
In order to allow some flexibility in implementing GIP-2, the staff acknowledged in the supplement that SQUG members who commit to GIP-2 (both the SQUG commitments and t1e implementation guidance) may deviate from it provided that such deviations are identified, documented and justified. However, it was also indicated in SSER No. 2 that if a SQUG member uses methods that deviate from the criteria and procedures described in the SQUG commitments and in the implementation guidance of GIP-2 without prior NRC approval, the staff may find the use of such methods unacceptable with regard to satisfying the provisions of GL 87-02.
In light of the above, the staff interprets DLC's response to the supplement as a commitment to the entire GIP-2 including both the SQUG commitments and the implementation guidance, and therefore considers it acceptable.
If the staff's interpretation is incorrect, then in accordance with the supplement, DLC should provide for staff review, as soon as practicable rior to implementatice, its alternative criteria and procedures for re=panding to GL 87-02.
- In addition, on October 2, 1992, the staff responded to the August 21, 1992, SQUG 1etter.
The staff does not concur with all of the SQUG's clarifications and positions stated in their letter.
Thus, DLC should not use the August 21, 1992, letter as guidance in responding to the supplement, but should instead refer to the staff's October 2, 1992, letter for the staff's position on the SQUG letter.
With regard to item 2, DLC stated that it will submit a summary report to the NRC summarizing the results of the USI A-46 program by May 21, 1995. This date is acceptable since it is within the 3-year response period requested by the staff.
With regard to item 3 DLC stated that it 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.
Since Beaver Valley, Unit 1 is identified in SSER No. 2 as a Category 1 plant without double asterisks, we find DLC's response acceptable.
Based upon the provision stipulated in SSER No. 2, the in-structure response spectra included in licensing basis documents, such as the Updated Final Safety Analysis Report, and other pertinent commitments related to in-structure response spectra may be used as conservative design spectra for resolution of USI A-46 issues.
If DLC intends to use the option of developing or using median-centered in-structure response spectra, the Commission should be informed of the approximate date that information will be available.
It is noted that DLC did not indicate in its submittal that it intended to change its licensing basis to reflect a commitment to the US! A-46 methodology prior to receipt of the staff's plant-specific safety evah ation.
3.0 CONCLUSION
S The staff interprets DLC's response to the supplement as a commitment to the cire GIP-2 including both the SQUG commitments and the implementation.
<v idance, and therefore considers it acceptable.
If DLC does not commit to o
implement the entire GIP-2, then in accordance with the supplement, DLC should provide for staff review, as soon as practicable prior to implementation, its alternative criteria and procedures for responding to GL 87-02.
Additionally, DLC should not merely follow the August 21, 1992, SQUG letter for implementing GIP-2, but should refer to the staff's October 2,1992, response to the SQUG 1etter.
The implementation schedule proposed by DLC is within the 3-year response period requested by the staff in the supplement and is therefore acceptable.
DLC's response regarding in-structure response spectra is acceptable.
l Principal Contributors:
P. Chen M. McBrearty J. Ma Date:
November 20, 1992
a ENCLOSURE 2
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OCT 0 2 g Mr. ta,1 Smith, Chairma;.
Seismic Qualification Utility Group c/o EPRI 1019 19th Street, N.W.
Washington, DC 20036
SUBJECT:
NRC RESPONSE TO SEISMIC QUALIFICATION UTILITY GROUP (SQUG)
Re:
Letter, N. Smith, EPRI, To J. Partlow, NRR, dated August 21, 1992, concerning USI A-46 Issues.
Dear Mr. Smith:
This is to acknowledge the receipt of the SQUG response to Supplement No. I to Generic Letter (GL) 87-02, and Supplemental Safety Evaluation (SSER) No. 2 on the SQUG Generic implementation Procedure for Seismic Verification of Nuclear Plant Equipment, Revision 2, as corrected February 14, 1992 (GIP-2).
The NRC staff believes that successful implementation of the entire GIP-2, supple-mented by the staff's SSER No. 2, by each SQUG licensee will result in cost-effective plant safety enhancement for their USI A-46 plants.
The staff also believes that the positions delineated in Supplement No. I to GL 87-02 and SSER No. 2 are clear and correct, and should not be misinterpret-ed.
The staff's comments on SQUG's August 21, 1992, letter and attachment are provided in the enclosure to this letter.
If you need further clarification concerning our response, please contact Mr. James Norberg at 504-3288.
Sincerely, e
%i James G. Partlow Astaciate Director for Projects Office of Nucle.ar P.4 actor Regulation
Enclosure:
As stated l
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3-ENCLOSURE 1.
NRC's Comments on the SOUG Letter of Auaust 21. 1992:
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1.
In regard to the issue of seismic qualification, the staff _
reiterates the position stated in the SSER No. 2, in that the GIP-2 methodology is not considered to be a seismic qualification method,-rather, it is an acceptable evaluation method, for US! A-46 plants only, to verify the seismic adequacy of the safe-shutdown equipment and to ensure that_the pertinent equipment-seismic requirements of General Design Criterion 2 and the purpose of the NRC regulations relevant to equipment seismic adequacy including 10 CFR Part 100 are satisfied.
2.
The second paragraph on page 2 of your letter addressed the issue of timing of staff response to additional information requested from a licensee. Although you are correct in your statement regarding the sixty-day period for response to initial submittal of in-structure response spectra (ISRS) information, we do not agree that the same concept applies to a licensee's submittal-of additional information received following a rejection or a question from the staff.
To eliminate any potential misunder-s'anding in this regard, the staff has determined that it will spond to any submittal of additional information received from a
- icensee within 60 days. However, in this response, the sto*f will either state its approval (or rejection) of the information provided, or hdicate the time duration needed for the review of such information, prior to transmitting a: follow-up response of acceptance (or rejection) to the licensee. This. time duration will vary depending on the complexity of the submittal, 3.
Regarding the EBAC and ANCHOR computer. codes, the staff's evaluations and concerns stated in'the SSER Ho. 2 are correct and valid.
The ANCHOR code doet not consider the effects of base plate flexibility on the anchorage capacity.
4.
With respect-to transfer of knowledge regarding major problems identified, and lessons letrned, in the USl A-46 plant walkdowr.s and third-party reviews, we request that you: include the NRC in the distribution of written communications to-all member utilities in this regard, and inforn the NRC staff of any planned workshops on A-46 implementation for possible staff. participation, 11.
NRC's Comments on the Procedure for Reviewina the-GIP 1.
The staff supports SQUG's establishment of a Peer Review Panel composed of seismic experts since it should serve to enhance the review process of substantive changes to the technical requirements in the GIP, prior to its-submittal to NRC for approval.
However, since the NRC no longer intends to; help finance a Peer Review Panel, the staff.does not believe it l
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.e i is appropriate to participate in tiie selection of the Peer Review members, who will be financed by SQUG/EPRI. We would like to emphasize that staff's review of a proposed GlP change will receive thorough independent NRC evaluation and will be assessed on its merits.
2.
With respect to the NRC review and approval of the changes to the GIP (item 5, page 3 of the procedure), the staff's position on the issue of its response timing is identical to that delineated in the response to a licensee submittal of additional-information (refer to item 2 of NRC's Comments on the 5000 letter in this enclosure).
This comment also applies to the section " LICENSING CONSIDERATIONS" on page 5 of the Attachment-to the SQUG letter.
3.
With respect to item 4, " Additional Restrictions," the text should be expanded to reflect that new information which indicates that existing GIP criteria and guidelines may be unconservative should be evaluated for potential 10 CFR Part 21 implications.
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