ML20128D423

Forwards Safety Evaluation Re Evaluation of 120-day Response to Suppl 1 to GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactor, Uresolved Safety Issue A-46

ML20128D423
Person / Time
Site:	Fort Calhoun
Issue date:	11/30/1992
From:	Steven Bloom Office of Nuclear Reactor Regulation
To:	Gates G OMAHA PUBLIC POWER DISTRICT
Shared Package
ML20128D426	List: ML20128D423 ML20128D451
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, TAC-M69447, NUDOCS 9212070273
Download: ML20128D423 (4)

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%, ...../ November 30, 1992 Docket No. 50-285 Mr. W. Gary Gates Division Manager - Nuclear Operations Omaha Public Power District 444 South 16th Street Mall Mail Stop 8E/EP4 Omaha, Nebraska 68102-2247

SUBJECT:

EVALUATION OF FORT CALHOUN STATION, UNIT 1, 120-DAY RESPONSE TO SUPPLEMENT NO, 1 10 GENERIC LETTER 87-02 (TAC N0. M69447)

By letter dated September 21, 1992, Fort Calhoun Station responded to Supplement No. I to Generic Letter (GL) 87-02. Enclosure 1 provides the NRC's evaluation of the licensee's response.

Supplement No I to GL 87-02 required that all addressees provide, within 120-days of the issue date of the supplement, either a commitment to use both the Seismic Qualification Utility Group (SQUG) commitments and the implementation guidance described in the Generic Implementation Procedure, Revision 2 (GIP-2), as corrected on February 14, 1992, and as supplemented by the NRC's Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on GIP-2, or else provide an alternative method for responding to GL 87-02. The supplement also required that those addressees committing to implement GIP-2 provide an implementation schedule and the detailed information as to what procedures and criteria were used to generate the in-structure response spectra to be used for Unresolved Safety Issue (USI) A-46. In addition, the NRC requested in SSER No. 2, that the licensees inform the NRC in the 120-day response if they intend to change their 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 evaluatinn resolving USI A-46.

The licensee's response is unclear as to whether or not the licensee intends to implement both the SQUG commitments and the implementation guidance. The NRC interprets the licensee's response as a commitment-to the entire GIP-2 including both the SQUG commitments and the implementation guidance, and therefore considers it acceptable. If the NRC's interpretation is incorrect, then,- in accordance with Supplement No. I to GL 87-02, the licensee should provide for NRC review, as soon as practicable prior to-implementation, its alternative criteria.and procedures for responding to GL 87-02. Additionally,-

the licensee should not merely follow the August 21, 1992, SQUG letter for implementing GIP-2 as stated in its submittal, but should refer to Enclosure 2 to this letter which provides the NRC'sresponse to the SQUG 1etter. The implementation schedule proposed by the licensee is within the 3-year response period requested by the NRC in Supplement No. I to GL 87-02 and is therefore acceptable.

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, Mr. W. Gary Gates -

2-On the basis of the NRC's review of the incomplete information provided, the NRC concludes that the use of the criteria and procedure in Appendix F to the Updated Safety Analysis Report (USAR) would result in median-centered rather than the " Conservative Design" in-structure response spectra. Thus the licensee's in-structure response spectra are accepted as medium-centered spectra.

The licensee 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 equipment prior to receipt of a final plant-specific Safety Evaluation resolving USI A-46. The NRC 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.

However, if the licensee does not commit to implement both the SQUG commitments and the implementation guidance, and the licensee has not committed to any acceptable alternative criteria and procedures, then the NRC does not believe that it is feasible, at this time, for the licensee to change its licensing basis in the manner described.

Sincerely, ORIGINAL SIGNED BY:

Steven Bloom, Project Manager Project Directorate IV 1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosures:

1. Safety Evaluation

2. NRC's response to SQUG letter dated October 2, 1992 cc w/ enclosures:

See next page DISTRIBUTION:

Docket File NRC & Local PDRs PD4-1 Reading C. Tan S. Bloom M. Virgilio J. Larkins- J. Norberg P. Noonan ACRS(10) (P-315) OGC(15B18)

PD4-1 Plant File A. B. Beach, RIV- J. Roe

• See previous concurrence I 0FC LA:PD4-f) ' d PMtPD4-1 EMEB -I :D PQ M NAME PNoonan)i S b :pk JNorberg* [tMbn DATE II /My92 d/30/92 11/25/92 // /do /92 OfflCIAL RECORD COPY Document Name: FC69447.ltr

Mr. W. Gary Gates On the basis of the NRC's review of the incomplete information provided, the NRC concludes that the use of the criteria and procedure in Appendix F to the Updated Safety Analysis Report (USAR) would result in median-centered rather than the " Conservative Design" in-structure response spectra. Thus the licensee's in-structure response spectra are accepted as medium-centered spectra.

The licensee 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 equipment prior to receipt of a final plant-specific Safety Evaluation resolving USl A-46. The NRC 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 GlP.

However, if the licensee does not commit to implement both the SQUG commitments and the implementation guidance, and the licensee has not committed to any acceptable alternative criteria and procedures, then the NRC does not believe that it is feasible, at this time, fer the licensee to change its licensing basis in the manner described.

Sincerely, ORIGINAL SIGNED BY:

Steven Bloom, Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosures:

1. Safety Evaluation _

2. NRC's response to SQUG 1etter dated October 2, 1992 cc w/ enclosures:

See next page QlSTRIBUTION:

Docket-File NRC & Local PDRs PD4-1 Reading C. Tan S. Bloom M. Virgilio J. Larkins J. Norberg P. Noonan ACRS(10) (P-315) 0GC(15B18)

PD4-1 Plant File A. B. Beach, RIV J. Roe

• See previous concurrence OFC LA:PD4_ll M PMgPD4-1 EMEB D:PQA-1 NAME PNoendn) SBb:pk JNorberg* [Mns DATE 11 /T/92 d /30/92 11/25]92 // /30 /92 0FFICIAL RECORD COPY Document Name: FC69447.ltr e _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

. Mr. W.- Gary Gates On the basis of the NRC's review of the incomplete information provided, the NRC concludes that the use of the criteria and procedure in Appendix F to the Updated Safety Analysis Report (USAR) would result in median-centered rather than the " Conservative Design" in-structure response spectra. Thus the licensee's in-structure response spectra are accepted as medium-centered spectra.

The licensee indicated that it may change its licensing basis methodoiogy, via 10 CFR 50.59, for verifying tLe seismic adequacy of new, replacement, and existing electrical and mechanical equipment prior to receipt of a final plant-specific Safety Evaluation resolving USI A-46. The NRC 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.

However, if the licensee does not commit to fr plement u both the SQUG.

conmitments and the implementation guidance, and the licensee has not committed to any acceptable alternative criteria and procedures, then the NRC does not believe that it is feasible at this time, for the licensee to change its licensing basis in the manner G 3cribed.

Sincerely, Steven Bloom, Project Manger Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation Enciosures:

1. Safety Evaluation

2. NRC's response to SQUG 1etter dated October 2, 1992 cc w/ enclosures:

See next page

J Mr.-W. Gary Gates Omaha Public Power District Fort Calhoun Station, Unit No. I cc:

Harry H. Voigt, Esg.-

LeBoeuf, Lamb, Leiby & MacRae i 1875 Connecticut Avenue, NW Washington, D.C. 20009-5728 Mr. Jack Jensen, Chairman Washington County Board of Supervisors Blair, Nebraska 68008  :

Mr. Raymond P. Mullikin, Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 309 ]

Fort Calhoun, Nebraska 68023 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc. i 12300 Twinbrook Parkway, Suite 330  ;

Rockville, MD 20852 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Harold Borchert, Director Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South Post Office Box 95007 Lincoln, Nebraska 68509 Mr. T. L. Patterson, Manager Fort Calhoun Station Post Office Box 399 Fort Calhoun, Nebraska 68023