ML20128B937

Safety Evaluation Accepting Licensee Response to Suppl 1 to GL 87-02

ML20128B937
Person / Time
Site:	Calvert Cliffs
Issue date:	11/20/1992
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20128B921	List: ML20128B918 ML20128B937
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9212040157
Download: ML20128B937 (4)

Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION BALTIM0RE GAS AND EI1GIRIC COMPANY .

EYAl,UATION OF CALVERT CLIFFS NUCLEAR POWE.fL PLANT. UNILMS.1 AND 2-i 120-DAY RESPONSE TO SUPPLEMENT NO. 1 TO GENERIC LETTER 87-02 DOCKET NOS. 50-317 AND 50 q

1.0 INTRODUCTION

By letter dated September 18, 1992, Baltimore Gas and Electric Company (the licensee or BG&E), submitted its response to Supplement No. I to Generic Letter (GL) 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," dated May 22, 1992, for Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2. In this supplement, the staff requested that the licensee submi' the-following information withi- 120 days of the issue date of the supplemt u..

1. A statement whether you commit to use both the Seismic Qualification Utility Group (SQUG) commitments and the implementation guidance provided.

in the Generic Implementation Procedure, Revisi w 2 (GIP-2), as .

supplemented by the staff's Supplemental Safety Evaluation Report No. 2 (SSER No. 2) for the resolution of USI A-46. In thi s case, any deviation from GIP-2, as supplemented by the SSER No. 2, must be identified, justified, and documented. If you do not make such a commitment, you must provide your alternative for responding to GL 87-02.

2. A plant-specific schedule for the implementation of the GIP and submission -

of a report to tha staff that summarizes the results of the USI A-4.6 review, if you are committing to impleceO GIP-2. This schedule shall be such that each affected plant will complete its implementationiand submit-the summary report within 3 years-after the issuance of-the SSER No.-2, unless otherwise justified.

. 3. -The detailed information as to what procedures _and criteria were used to

gen 3 rate the in-structure response spectra to be used for USI_A-46 as requestod in.the'SSER No. 2. The licensee's in-structure re g n o spectra are. considered acceptable for USI A-46 unless the staff -indicates 4

otherwise during-a 60-day review period.- '

L In addition, the. staff requested in .iSER No. 2 that the licensee -inform the-staff, in the 120-dey response, if it inteads to change its licensing basis _-to-reflect a commitment to the USI. A-46 (GIP-2) methodology for verifying ~the L seismic adequacy of mechanical and electrical equipment, prior to receipt of.

the staff's plant-specific. safety evaluation resolving USI A-46.

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2.0 EVALUATION With regard to Item 1, the licensee stated that, " Spec.fically, BG&i does commit to the SQUG commit ments set forth in the GIP, including the clarifications, interpretations, a.'d exceptions identified in SSER-2 as clarified by Reference (b) with the exception of the following section." (It is noted that Reference (b) in the licensee's submittal is an August 21, 1992, letter from SQUG to the NRC. Also, the licensee's one exception to the SQUG commitments is discussed later in this waluation.) The licensee further stated that, " Baltimore Gas and Electric Company will be generally guided by ,

. the remaining (non-commitment) sections of the gip, i.e., GlP implementation '

guidance, which comprises suggested methods for implementing the applicable commitmants."

The licensee's response is unclear as to whether or not the licensee intends to implement both the SQUG commitmer.ts and the implementatinn guidance. In accepting GIP-2 as a method foi resolving USI A-46, it was the staff's. under-standing that the SG,G members who chose to implement GIP-2 would essentially use the entire procedure, including the SQUG commitments. which contain the general programmatic objectives and coals, and the implementation guidance, which contains the specific criteria and procedures to be uted for the resolu-tion of USI A-43. This understanding was the basis for the staff's position.

which was : > ated in SSER No. 2, that if the licensee commits to use GIP-2 foi the implementation of USI A-46, it must commit to both the SQUG commitments and tha use of the entire imp'ementation guidance provided in GIP-2, unless othe- e iustified to the s uff. In order to allow some flexibility in implemanting GIP-2, tL staff acknowledged in the supplement to GL 87-02 that SQUG members who commit to GIP-2-(both the SQUG commitments and the implementation guidance) may deviate from it provided that such deviations are identified, documented, and justified. However, it was also indicated l.i SSER No. 2 that if a licensee uses methods that deviate from the criteria and pro-cedures described in the SQUG commitments and in the implementation guidance of GIP-2 without prior NRC approval, the staff-mai 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 the licensee's response to Supplement No. I to GL 87-02 as a commitment to the entire GIP-2 including both the SQUG commitments and the implementation guidance, with the exception of any deviations identified in the licensee's 120-d; 1 response, and therefore considers it acceptable. If the staff's interpretation is incorrect, then in accordance with Supplement No. I to GL 87-02, the licentee should provide fcr staff review, as soon as practicablc prior to implementation, its alternati4e criteria and procedures- for responding' to GL 87-02.

In addition, Enclosure 2 provides the staff's response, dated Ocicher 2, 1992, to the August 21, 1992, SQUG letter. The staff does not concur with all of the SQUG's clarifications and psitions stated in that letter, and thus', the licensee should nat only use the August 21,-1992, letter as gu Hance in responding to Supplement No. I to GL 87-02. The licensee should refer to Enclosure 2 for the staff's position on the SQUG letter.

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B6eE indicated that it plans to deviate from the GIP-2 commitments with regards to the defir.ition of safe shutdown which will be used for the implementation of USI A-46. Safe shutdown is defined in the GIP as bringing the plant to, and maintaining it in a Hot Shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Calvert Cliffs is licensed as a Hot Standby plant. This means that BG&E defines the safe shutdown condition at Calvert Cliffs as bringing the units to a Hot Standby condition.

Hot Standby is defined in the Calvert Cliffs Technical Specifications as having the reactor subcritical and the average temp n.ture equal-to or greater than 300 *F. After review of the submittal and discussions with the licensee, the staff understanss that all Class lE seismically-qualified equipment needad to bring the plant to Hot Standby and maintain it in that condition'for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will be included for the implar.entation of USI A-46. This will also ,

include decay heat removal equipment. Based on the above discussion, the licensee's submittal is acceptahle.

With regard to Item 2, BG&E stated that it will submit a aummary report to the NRC summarizing tha results of the USI A-46 program at Calvert Cliffs Nuc'.etr Power Plant, Units 1 and 2, by June 30, 1996. Although this submittal date exceeds the 3-year response period requested by the staff, the licensee stated that the extension is necessary due to the current schedule of planned refueling outages and the nccessary coordination required for-its IPEEE-program. Therefore, the staff finds that the licensee's proposed schedule is acceptable.

With regard to Item 3, the staff has performed the review of the licensee's in-stru:ture response spectra to be used for USI A-46. evaluations: Based on the staff's review of the licensee responte and the staff positions delineated in the SSER Na. 2, we conclude that the 14c* nsee response is adoquate and acceptable. This conclusion is based on the assumption that the statements made in the submittal, including the criteria and procedure used in the generation of the floor response spectra, correctly reflect' the FSAR on seismic design and other licensing basis. The staff may audit the process by which the in-structure respc-se spectra were generated.

l BG&E indicated that it may change its licensing basis methodology, via 10 CFR .

50.59, for verifying the seismic adequacy of new, replacement, and existing electrical and mechanical equipuent prior to- receipt of a final plant-specific SIR resolving'USI A-46. The sLF f recognizes that the-licensee may revise -its licensing basis .in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 (GIP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered by the GIP, provided that the change is consistent with~both the SQUG commitments and the implementation guidance.

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3.0- CONCLUSIONS

- The staff interprets the licensee's response to Supplement No. I to GL 87-02 as a commitment to the entire GIP-2 including .th the SQUG commitments and the implementation guidance, with the exception of any deviations identified in the licensee'; 120-day response and, therefore, considers it acceptable.

If the licensee does not commit to implement the entire GIP-2 then in accordance with Supplement No. I to GL 87-02, the licensee should provide for staff review, as soon as practicable prior to implementation, its alternative criteria and procedures for responding to GL 87-02. Additionally, the licensee should not only follow the Auss st 21, 1992, SQUG letter for implementing GIP-2, but should refer to Enclosure 2 for th staff's. response to the SQUG letter.

Althotgh BG&E's proposed implementation schedule exceeds the 1-year response period requested by the staft the licens3e provided an adequate justification for its schedule and, therefore, it is acceptable.

The staff finds that based on BtaE's submittal concerning in-structure response spectra for resolving USI A-46, is aJequate and Orceptable.

The staff recognizes that the licensee may revise its licensing basis in accordance with 10 CFR 50.59 to reflect the ccceptability of;the USI A-46 (GIP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered by the GIP, provided'that the change is consistent with both the SQUG commitments and the implementation guidance.

Principal Contributors: M. McBrearty P. Chtn C. P. Tan C. Orsini K. Desai Date: November 20, 1992 l

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OCT 0 2 g Mr. Neil Smith, Chairman 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 i;o. I to Generic 1.etter (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 Nc. 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. 1 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, r

hi James G. Partlow Associate Director fcr Projects Office of Nuclear Reactor Regulation

Enclosure:

, As stated

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ENCLOSURE I. NkC's Comments on the 50VG Letter of Auaust 21. 1992,:

1. In r1 gard 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 u an acceptable evaluation method, for USI 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 informatinn 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) Inforniation, we de 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 eliminato any potential misunder-standing in this regard, the staff has determined that it will respond to any submittal of additional information received f"om a licensee within 60 days. However, in this response, the staff ,

will either state its approval (or rejection) of the information provided, or indicate the time duration needed for the review of such information, prior to transmitting a follow-up response of acceptance (c. rejection) to thi 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 No. 2 are correct and valid. The ANCHOR code does 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 learned, in the USl A-46 plant walkdowns and third-party reviews, we request that you include the NRC in the distribution of written communications to all member utilities ir $his regard, and inform the NRC staff of any planned workshops en A-46 implementation for possible staff participation.

II. NRC's Comments on tile Procedure for Reviewina the GR

1. The staff supports SQUG's establishment of a Peer Review Panel composed of seismic experts since it should serve to enhance the review prccess 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 f 1

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l is appropriate to participate in the 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 GIP 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 SQUG 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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Mr. Robert E' Denton' , November 20, 1992 ,

should also refer to Enclosure i to this letter which provides the NRC staff's response to the SOUG letter, if the staff's interpretation regarding your commitment is incorrect, then you should provide for staff review, alternative  ;

criteria, and procedures for responding to GL 87-02 within 30 days. .

1 Your response indicated that you plan to deviate from the GIP-2 commitments l with regards to the oefinition of safe shutdown which will be used for the implementation of USI A-46. This issue was reviewed by the staff and found to be acceptable.

Although your proposed implementation schedule exceeds the 3-year response period requested by the staff, you provided an adequate justification for your -l schedule, and therefore, it is acceptable. 1 i

With respect to changes to the current licensing basis methodology, the staff l recognizes that you may revise your licensing basis in accordance with 10 CFR  ;

50.59 to reflect the acceptability of the USI A-46 (GIP) methodology for  !

verifying the seismic adequacy of electrical and mechanical equipment covered H by the GIP, provided the change is consistent with both the SQUG commitments and the implementation guidance.

The staff finds that 83&E's submittal concerning in-structure response spectra for resolving USI A-46, is acceptable.

Sincerely, Original Signed by Christopher Orsini for.

Daniel G. Mcdonald, Senior Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulacion

Enclosures:

1. Safety Evaluation

2. Staff's October 2, 1991, Response To August 21, 1992, SQUG Letter cc w/ enclosures:

See next page Distribution:

Docket File: CVogan CCowgill, RGN-1 NRC & Local PDRs W JNorberg, 7/E/23 PDI-1 Reading MScBrearty, 7/E/23 KDesai, 8/E/23 SVerga PChen, 7/E/23 .

JCalvo .CTan, 7/H/15 DMcDonald ACRS (10)

C0rsini PDl-1 Plant File

• See Previous Concurrence PDI-1:LA PDI-l _,_ PD I-),:.fM EMEB' PDI-1:D h 8 CVogan d# C0rsinkmm. DMcNaY *JNorberg RACaprak

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/ /92 'll /M/92 11 / JC92 11/19/92 :I/10/92 /. /

OFFICIAL RECORD C0fY FILENAME: CC69435.LTR i