ML20155E891

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Responds to 880729 Generic SER on Seismic Qualification Util Group Resolution of USI A-46.Implementation Schedule for USI A-46 May Have to Be Revised to Integrate Future Requirements Into single,cost-effective Program
ML20155E891
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 10/06/1988
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Shao L
Office of Nuclear Reactor Regulation
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 8810130043
Download: ML20155E891 (3)


Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19I01 (2 s) sat.sooi JOSEPH W, G ALL AGHER u uS*

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GL 87-02 USI A-46 October 6, 1988 Docket No. 50-277 50-278 Mr. Lawrence C. Shao, Director Division of Engineering and Systems Technology Office of Nuclear Reactor Regulation U.S.

Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555 SUBJ ECT: Peach Bottom Atomic Power Station Response to Generic SER on SQUG Resolution of Unresolved Safety Issue A-46 Dear Mr. Shao On July 29, 1988, the NRC Staff issued a Safety Evaluation Report (SER) on Revision 0 of the Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment developed by the Seismic Qualification Utility Group (SQUG).

The letter to SQUG enclosing the SER requests that SQUG member utilities provide to the NRC, within 60 days, a schedule for implementing the GIP.

By letter dated August 19, 1988 to you, SQUG elarified that the 60 days would expire on October 7, 1988.

This letter responds to the NRC request for our plant-specific seismic verification plans for Peach Bottom, consistent with the requirements of Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Cafety Issues (USI) A-46."

As a member of SQUG, Philadelphia Electric has supported the many efforts on which the GIP is based.

The SER endorses the nethodology and criteria embodied in Revision 0 of the GIP, aJbject to natisfactory :esolution of a number of open issues and NHC comments.

Action by SQUG and its contractors is underway to runolve the identified open issues and comments in accordance

$f 3810130043 881006 PDR ADOCK 05000277 P

PDC

Mr.

L. C.

Shao October 6, 1988 Page 2 with the SQUG schedule presented at the August 10-11, 1988 meeting with the NHC staff and included with the SQUG 1ettar to you dated August 19, 1988.

This schedule projects completion of Revision 2 of the GIF in Spring, 1989, contingent upon SQUG and NRC agreement on the resolution of the various open issues.

Revision 2 of the GIP is the version which is scheduled to contain all of the information needed to implement the USI A-46 generic letter at SQUG member plants.

The final NRC SER Supplement on Revision 2 of the GIP is anticipated by mid-1989.

Philadelphia Electric Company's plann for implementation of the GlP at our Peach Bottom plant are preliminary given the current status of and schedule for completion of Revision 2 of t ht-CIP and NRC's SER Supplement on that revision.

Ilowever, it is ur current plan to resolve USI A-46 for our Peach Bottom plant by implemer.tation of the generic criteria and methodology included in Revision 0 of the CIP, as clarified by the SQUG responses to the NRC EER submitted to you by letter dated late September 22, 1988.

The current workscope is described in Revision 0 of the GIP, with criteria to be added for cable raceways, tanks, heat exchangers, and relaye..

Assuming no major changes in the current workscope, we plan to perform the seismic verification plant walkdown required by the GIP by the conclusion of the first refueling outage after receipt of the final SER i

Supplement and resolution of all open issues.

If the final NRC SER Supplement with no open items is issued by the second quarter of 1989, then the plant walkdown at Peach Hottom is expected to be completed on both units by about January, 1991.

Identification of safe shutdown equipment, gathering of necessary plant-speeltic data, and training of our walkdown team members will be initiated prior to the walkdowns.

Our current implementation plan and achedule, as described above, are based on the "500G Commitments" identified in each section of the GlP.

Our implementation and schedule conuul t men t is contingent upon our current understanding of the GIP.

If the ucope of the final revision of the GIP, or the cost ar.d effort required to implement it at our plant, change significantly from the current scope and cost estimates, we will need to reevaluate our commitments.

We also desire to integrate the resolution of USI A-46 with the resolution of numerous other related selumic issues (e.g.,

Eaciern Seismicity, Seismic Margins, and Severe Accident Individual Plant External Event Evaluations).

In view of the uncertainties in the requirements and schedule tor resolution of these related issues, we may need to revise the implementation schedule for USI A-46 at Peach nottom to integrate these poterdlal futute requirements into a single, cost-effective program.

This possibility has been the subject of on going discussions between SOUG and your staff, and

Mr.

l.. C. Shao Octobar 6, 1988 Page 3 further discussions are planned.

We will advise you in writing of any changes in our implementation plans and schedules.

Should you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours, cci Addressee 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 W. T.

Russell, Administrator, Region I, USNRC T.

P. Johnson, USNRC Senior Hesident Inspector T.

E.

Magette, State of Maryland J. Urban, Delmarva Power J.

T.

Boettger, Public Service Electric & Gas II. C. Schwemm, Atlantic Electric

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