ML20198A163

SER Approving Implementation Program to Resolve USI A-46 at Facility That Has Adequately Addressed Purpose of 10CFR50.54(f) Request

ML20198A163
Person / Time
Site:	Beaver Valley
Issue date:	12/09/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198A134	List: ML20198A130 ML20198A163
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 9812160168
Download: ML20198A163 (11)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING USI A-46 PROGRAM IMPLEMENTATION DUQUESNE LIGHT COMPANY OHIO EDISON COMPM[(

PENNSYLVANIA POWER COMPANY BEAVER VALLEY POWER STATION. UNIT NO.1 DOCKET NO. 50-334

1.0 BACKGROUND

On February 19,1987, the NRC staff issued Generic Letter (GL) 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety issue (USI) A-46." In the generic letter, the NRC staff set forth the process for resolution of USl A-46, and encouraged the affected nuclear power plant licensees to participate in a generic program to resolve the seismic verification issues associated with USl A-46. As a result, the Seismic Qualification Utility Group (SQUG) developed the " Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Plant Equipment," Revision 2 (GlP-2, ,

Reference 1).

On May 22,1992, the NRC staff issued Supplement 1 to GL 87-02 including the staff's  !

' Supplemental Safety Evaluation Report No. 2 (SSER-2, Reference 2), pursuant to the provisions of 10 CFR 50.54(f), which required that all addressees provide either (1) a commitment to use both the SQUG commitments and the implementation guidance described in GlP-2, as supplemented by the staff's SSER 2, or (2) an attemative method for responding to GL 87-02. The supplement also required that those addressees committing to implement GIP 2, provide an implementation schedule and detailed information on the procedures and criteria used to generate the in-structure response spectra (IRS) to be used for USI A-46.

By letter dated September 22,1992 (Reference 3), Duquesne Light Company (DLC), the licensee, provided its response to Supplement 1 to GL 87-02 for the Beaver Valley Power Station, Unit No.1 (BVPS-1). In the letter, DLC committed to follow the SQUG commitments set forth in GIP-2, including the clarifications, interpretations, and exceptions identified in SSER-2. The NRC staff issued its evaluation of the licensee's response by letter dated November 20,1992 (Reference 4).

By letter dated January 31,1996 (Reference 5), DLC submitted a summary report containing the results of the USI A-46 program implementation at BVPS-1. By letters dated May 16,1997 (Reference 6), and June 2,1998 (Reference 7), DLC provided supplementalinformation and clarification in response to the NRC staff's requests for additional information (RAls), dated January 10,1997 (Reference 8), and March 4,1998 (Reference 9), respectively.

9812160168 981209 PDR ADOCK 05000334 p e. PDR ENCLOSURE

.  ;. - . . = _ _ -- _ _ .

l 2-l This report provides the NRC staff's evaluation of the licensee's USI A-46 implementation program. The evaluation is based on the staff's review of the summary report and of the i

supplemental information, clarifications, and documentation provided by the licensee in response to the staff's RAls.

2.0 DISCUSSION AND EVALUATION The summary report (Reference 5) provides the licensee's implementation results of the USI A 46 program at BVPS-1. The report identifies a safe shutdown equipment list (SSEL) and documents the screening verification and walkdown of mechanical and electrical equipment and the relay evaluation. The report also documents the evaluation of seismic adequacy for tanks, heat exchangers, and cable and conduit raceways, identifies outliers, and proposes resolutions including projected schedules.

2.1 Seismic Demand Determination (Ground Soectra and in-Structure Resoonse Soectral The licensee stated in Reference 5 that the seismic input ground motion used in the A-46 analysis is the plant design basis earthquake (DBE). The DBE horizontal components have a peak ground acceleration of 0.125g. The seismic input motions and the method for developing the in-structure response spectra (IRS) had been evaluated and accepted by the NRC staff.

Reference 5 stated that USNRC SER, dated May 22,1992, categorized BVPS-1 as having

" conservative design" IRS. The licensee used the IRS as discussed in the 120-day response (Reference 3) to Supplement No.1 to Generic Letter 87-02 in the A-46 walkdowns and evaluations. The method of developing the IRS was evaluated by the NRC staff and found acceptable (Reference 4).

2.2 Seismic Evaluation Personnel

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The BVPS-1 seismic evaluation was conducted by a multi-disciplined project team. The seismic review team (SRT) included members of the DLC staff and engineers from the consulting firm of EQE Intemational. The DLC SRT members included a representative from ,

the Operations Department, six seismic capability engineers (SCEs), one system engineer, and two relay engineers. The resumes of both DLC and EQE SCEs are included in Appendix 3.2 of Reference 5. All SCEs, system and relay engineers have completed SQUG training in their areas of involvement.

The licensee indicated that walkdown inspection teams comprised a minimum of two (2)

SQUG-trained SCEs and included at least one (1) licensed professional engineer. The third-party review was conducted by a member of EQE Intemational, Mr. Gregory Hardy, whose resume is included in Appendix 10.0 of Reference 5.

The NRC staff finds that the qualifications of the licensee's seismic evaluation personnel meet the provisions of GIP-2 and the staff's SSER 2, and are, therefore, acceptable.

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l 2.3 Safe-Shutdown Path i

GL 87-02 specifies that the licensee should be able to bring the plant to a hot shutdown condition and maintain it in this state for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a safe shutdown earthquake (SSE). To meet this provision, in its submittal of January 21,1996 (Reference 5), the licensee addressed the following plant safety functions: reactor reactivity control, pressure control, I inventory control, and decay heat removal. Primary and attemate safe shutdown success paths with their support systems and instrumentation were identified for each of these safety functions to ensure that the plant is capable of being brought to, and maintained in a hot j

shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an SSE. Appendix 4.3-2 of Reference 5 provides I

the safe shutdown equipment list (SSEL). l The decay heat removal function is accomplished by relieving steam from the steam generators via the residual heat removal (RHR) release valve and/or atmospheric steam dump valves. Makeup water to the steam generators will be supplied by the auxiliary feed water system (AFW) which takes suction from the demineralized water storage tank. Once the I demineralized water storage tank has been depleted after 8-10 hours, the other available non- l seismic tanks will be realigned to the AFW system. If non seismic tanks would not be available then the AFW system will be aligned to the river water by manually repositioning a few valves.

The plant Operating Department reviewed the equipment listed in Appendix 4.3-2 of Reference 5 against the plant operating procedures and operator training and concluded that the plant operating procedurer and operator training were adequate to establish and maintain the plant in a safe shutdown condition following an SSE.

The NRC staff concludes that the approach to achieve and maintain a safe shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a seismic event is acceptable.

2.4 Seismic Screenino Veri'ication and Walkdown of Mechanical and Electrical Eouipment The seismic screening and walkdown included verification of 462 equipment items which are typical of those found in the SQUG experience database in the 20 classes of equipment covered in Appendix B of GIP-2 (Reference 1). The tanks and heat exchangers are evaluated in Section 2.5 of this SE.

2.4.1 Equipment Seismic Capacity Compared to Seismic Demand The licensee stated in Reference 5 that the 5% of critical damping SQUG Bounding Spectrum (BS) enveloped the BVPS-1 DBE ground motion response spectrum, and that the 1.5 Bounding Spectrum enveloped the IRS. The licensee stated that it had used Method B in Table 4-1 of GIP-2 exclusively for the comparison of seismic capacity against seismic demand for all SSEL equipment at BVPS-1, and that no SSEL equipment failed to satisfy the capacity versus demand, except for three intake structum HVAC fans and river water pumps. These HVAC fans and river water pumps were therefere identified as outiiers (Section 5.3 of Reference 5).

4 In Reference 6, the licensee indicated that for the river water pumps, the 3% of critical damping IRS was used in the original screening and found greater than 1.5 times the 5% of critical damping BS. These pumps were later found acceptable to satisfy the capacity versus demand on the basis that 1.5 times the 3% of critical damping BS bounds the 3% of critical damping IRS. The three intake structure HVAC fans were identifed as outliers because the IRS at their elevation does not exist. These fans will remain as outliers until the IRS is established at their location. The licensee indicated it plans to resolve these outliers by the Spring of year 2000.

The NRC staff determined that the licensee has followed the GlP-2 procedures for comparing equipment seismic capacity to seismic demand, and considers the evaluation to be adequate for the resolution of USI A-46.

2.4.2 Assessment of Equipment" Caveats

• The caveats are the inclusion and exclusion rules, which specify characteristics and features particularly important for seismic adequacy of a specific class of equipment when the equipment seismic capacity is determined on the basis of experience-based data. The caveats listed in Appendix B of the GIP-2 for each equipment class were verified for BVPS-1. The phrase " meeting the intent of the caveats" applies to equipment that does not meet the specific wording in certain caveats but is deemed seismically adequate based on the judgment of the SCE.

The results for equipment whose seismic adequacy was verified bv "eesting the caveats were documented in Appendix 5.1 of Reference 5. In many cases, items of equipment which did not meet the GIP-2 caveats were considered as outliers and were documented in Table 5.3 of the BVPS 1 sumrnary report for USl A-46 resolution, in some cases, if an item of equipment - ~

was judged to meet the intent of the caveats, the equipment item was considered to have met the caveat rule, in accordance with GIP-2. Equipment items that met the intent rather than the specific wording of the caveats are documented in Table 5.2 of Reference 5.

In its response of May 16,1997 (Reference 6), to the NRC staffs RAI dated January 10,1997, the licensee provided supplemental information, for some equipment items, to demonstrate i how the intent of certain caveats was met. For instance, the licensee indicated that the

! support configuration in the original installation, and qualifcation documentation, of certain l

Westinghouse strip chart recorders, deviated from the more current compression type mounting bracket installations that are considered inherently rugged and adequate by GIP-2.

l These installations were reviewed by the SCEs and judged to meet the intent of Caveat 3 for l Class 20 in accordance with GIP-2. In its May 16,1997 rasponse, the licensee stated that testing results of the existing support configuration to the plant demand level (including GIP-2 i amplification of 7.0) showed the recorders to be seismically adequate in the as found i condition. This confirmed the SCE's judgement that the equipment met the intent of the i caveat, was reasonable and acceptable. The licensee also indicated that if a component did not meet the wording of a caveat, and was not found to be an outlier, the assessment and i justification for meeting the intent of a caveat were noted on the Screening and Evaluation

} Work Sheets (SEWS).

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l j

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{, In general, the NRC staff finds that the seismic adequacy determination for equipment

identified in Table 5.2 of the BVPS-1 summary report conforms with the GIP-2 guidance on the caveats, and is acceptable in those instances where the intent rather tnan the wording of the l caveats was met.

2.4.3 Equipment Anchorage 1 The GIP requires an inspection of the adequacy of the anchorage installation and a determination of the anchorage capacity adequacy. The licensee stated that in conducting j

the walkdowns of anchorages, the SCEs paid attention to the load path, and as a result, on several occasions, washers were replaced with a larger type to improve anchor effectiveness.

Anchorage types used for SSEL equipment include embedded bolts, concrete expansion anchors, thru bolts, Nelson studs, welds and embedded channels and angles. The sizes and locations of anchorages were recorded during the walkdowns and the information was used later for the anchor capacity analysis. Nondestructive examination was used on two occasions to determine the length of bolts. The concrete expansion anchors for certain equipment included Hilti Kwik bolt & Drop-in, and Phillips Red Head Self drilling & Drop-in. The licensee stated that all accessible anchorages were checked for tightness, and that numerous shell anchors were inspected for proper recess after the removal of the equipment base. In i

Reference 5, the licensee also stated that the walkdown inspections included observation of '

concrete cracks and construction joints near expansion anchors. Anchor analyses were performed in accordance with the GIP-2 guidelines, and anchorages that failed either the walkdown inspection or analytical review were classified as outliers. Anchorage outliers that involved installation errors or installation deficiencies were corrected as they were found during the walkdown, and other types of outliers are scheduled for rasolution by the 13th refueling outage in the Spring of year 2000.

The NRC staff determined that the licensee has,in general, followed the GIP procedures for verifying equipment anchorage adequacy. Therefore, the equipment anchorage evaluation is considered acceptable for the resolution of USl A-46.

2.4.4 Seismic SpatialInteraction Evaluation The GIP-2 requires licensees of A-46 plants to verify that there can be no ad arse seismic  ;

spatial interaction of SSEL mechanical or electrical equipment with nearby equipment,  !

systems, or structures dunng earthquakes. The licensee stated that the Seismic Review Team  ;

(SRT) had followed the GIP-2, Section 11.4.5 and Appendix D procedure to evaluata seismic i spatial interaction, and that interaction consequences that may impact credible roft targets  ;

were considered during the evaluation. Numerous instances of potentialimpact were i identified. Where simple modifications were possible, maintenance work requests were generated and corrections were made (a g., removal of unanchored storage cabinets in the  !

control room). Other more complicated potentialimpact situations were considered as outliers j as delineated in Section 5.3 of Reference 5. These identified interaction outliers were either resolved or are scheduled for resolution by analysis or physical modifications no later than the  ;

Spring of year 2000 (Reference 11). '

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The NRC staff determined that the licensee has, in general, followed the GIP-2 procedures for verifying the seismic spatialinteraction adequacy. Therefore, the NRC staff considers the licensee's evaluation acceptable for the resolution of USl A-48. ~

2.5 Tanks and Heat Exchanoers For the evaluation of tanks and heat exchangers, the GIP-2 requires A-46 licensees to perform checks for the seismic adequacy of the following: (1) tank wall stability to prevent buckling, (2) anchor bolt and bolt embedment strength, and (3) anchorage connection between bolts and the tank shell.

The lice 1see stated in Reference 5 that the adequacy of SSEL tanks and heat exchangers were evaluated to the requirements of Chapter 7 of the GIP-2 methodology, and a total of 31 tanks and heat exchangers were reviewed and 27 were identified as outliers. Most of the outliers were the result of potential anchorage deficiencies. Analyses involving detailed modeling of anchorage systems were performed foridentified outliers. The Demineralized Water Storage Tank and the Refueling Water Storage Tank are large vertical flat-bottom tanks that failed to satisfy the GIP-2 criteria. Analyses were performed for these two tanks with respect to tank wall stability, bolt strength, and anchor chair capacity. The licensee concluded that both tanks have capacities that exceed the seismic demand. Reference 11 Indicated that the recount of the number of outliers was 25 instead of 27 as reported in Reference 5 for tanks and heat exchangers, and that all 25 outliers were satisfactorily resolved by analysis.

The NRC staff finds the licensee's evaluation of the tanks and heat exchangers adequate for the resolution of USI A-46, 2.6 Cable and Conduit Raceways '~

GIP-2 requires A-46 licensees to conduct a walkdown of cable and conduit raceways and conduct an analytical evaluation of selected worst case supports. The licensee stated that it had conducted plant walkdowns and performed raceway reviews in accordance with Section 11.8 of GIP-2. All safety related cable trays and raceways were inspected as a part of the USl i

A-46 review and all records were kept at the site. The walkdown verification identified that the BVPS-1 raceways encompass most standard types and configurations referenced in GIP-2 for this class, and that they ranged from lightly to heavily loaded. Trays are typically 30-inch ladder type and are supported in GIP-2 typical connections. Conduits vary in diameter up to 6 inches, and are of both aluminum and steel. All raceways were generally well supported.

Unistrut is a common structural support, with ridge-face nuts used. No rigid boots were found, and no cast iron inserts were found. Tug tests were used to check lightly loaded fixtures. Tie-wraps were regularly checked and were found to be sound.

The licensee indicated that prior to the GIP-2 walkdowns, it had performed, during its Color-Separation Resolution Program, an inspection of all safety-related cable and conduit raceways. More than 18,000 separate items were inspected and catalogued. Identified deficiencies, such as missing bolts and clearances were corrected.

The licensee also stated that 13 representative worst case cable and conduit raceway supports were selected for analysis to satisfy the limited analytical review requirement of ,

GIP-2. Bounding samples were selected to encompass diverse and extreme configurations of '

the plant's existing raceway support systems. With the exception of one case, all other twelve analyses produced acceptable results. The non-satisfactory case was considered as an outlier forlaterresolution.

Table 7.3 of Reference 5 identifies a total of seven cable tray and conduit outliers. Six were identified during the plant walkdowns and one was identified through analysis, in Reference 11, the licensee indicated that six of the seven outliers have been resolved by analysis or physical modification. The remaining one outlier for a conduit whose supports may ,

require a minor modification, will be resolved by spring of the year 2000. l The NRC staff concludes that the licensee's evaluation of the cable and conduit raceways followed the GIP-2 criteria and is acceptable for the resolution of USI A-46.

2.7 Essential Relavs The licensee stated that relay spot checks were performed by the SRTs during the equipment walkdown and during the separate relay evaluation walkdown. According to the GIP 2 procedure, the purpose of spot checks is to verify the relay mounting, orientation, model l number, load path, possible interaction, and cable slack. Accordingly, essential relays were l checked to confirm that they were mounted in accordance with manufacturer recommendations and to identify any abnormal or atypical relay mounting configurations.

Mounting bolts were visually inspected to ensure that the relays were well secured, and relay model, manufacturer, and equipment numbers were checked against the designations listed on the electrical schematic drawings. The licensee indicated that no essential relays were '

identified to be improper 1y mounted during plant walkdowns.

l Table 2.1-1 of the USl A 46 relay evaluation report (Reference 10) identifies 20 essential relay outliers, of which three (3) bad actor relay types (the General Electric HGA and the Westinghouse COM 5 and SG) were identified in accordance with the guidelines of GIP-2.

The licensee determined that these three BVPS-1 bad actor relay types are acceptable because they have either adequate seismic cap cities (Westinghouse COM-5 ano SG) or their chatter effect could be tolerated in performing their safety functions (General Electric HGA).

Of the remaining seventeen outliers, nine 'May types were reported as outliers, as they were originally tested to the BVPS 1 licensing basis of IEEE 344-71 standard, but are not covered by the SQUG database. In Reference 11, the licensee indicated that one of these 9 relays was reevaluated to be seismically adequate and that the other 8 non-GIP-2-qualified relays were reassessed by EQE SCEs and found to be acceptable. The remaining eight outlier relays that had no seismic qualification, are in the fire protection systems for the AFW pumps, emerge 1cy diesel generators (EDG) and charcoal bed litters. In Reference 11, the licensee indicatov that these fire protection system outlier relays have been replaced by relays that are seismically qualified to IEEE 344-75. Additionally, the licensee reiterated its intention in r-.- _.. . - - - - ~

I l

i Reference 11 to replace the GE HGA " bad actor" relays and complete its commitments on the USl A-46 resolution by the end of the 13th refueling outage which is currently scheduled to end in spring of the year 2000.

The NRC staff finds the licensee's seismic relay evaluation to be acceptable for the USl A 46 resolution.

2.8 Human Factors Asoect 1

i The licensee provided information which outlined the use of the " desk-top" and simulator review methods by the Operations Department to verify that existing normal, abnormal and emergency operating procedures were adequate to mitigate the postulated transient and that operators could place and maintain the plant in a safe shutdown condition. The NRC staff verified that the licensee had considered its operator training programs and verified that its training was sufficient to ensure that those actions specified in the procedures could be accomplished by the operating crews. The Operations Department has undertaken to introduce the SQUG shutdown scenario into operator training sessions. The SQUG shutdown scenario was developed to use only the SSEL equipment, and unavailable (non SSEL) control board indications were obscured during the exercises.

In addition, the NRC staff requested verification that the licensee had adequately evaluated potential challenges to operators, such as lost or diminished lighting, harsh environmental conditions, potential for damaged equipment interfering with the operator's tasks, and the potential for placing an operator in unfamiliar or inhospitable surroundings. The licensee provided information regarding their reviews to substantiate that operator actions could be accomplished in a time frame required to mitigate the transient. Specifically, the licensee _

provided assurance that ample time existed for operators to take the required actions to safely shut down the plant. This had been accompli hed during validation of the pertinent plant 1

operating procedures related to the licensee's Updated Final Safety Analysis Report, Chapter 4

14, Accident Analysis for the Loss of Offsite Power (LOOP) transient which proceded the USl A-46 program review. The licensee stated that ;,ince these plant procedures had already been validated to ensure adequate time and resources are available for operators to respond to a LOOP transient, it was not necessary to re-validate these procedures for the USl A-46 program. Only one additional sequence of actions related to seven air-operated valves (AOV) at four locations in the plant was identified as requiring manual operator intervention in the event of a loss of the air supply. The licensee stated that current procedures provide sufficient guidance for the operators, and the pathways to the local valves were verified to be available following the postulated seismic event. However, the licensee plans to provide additional procedural guidance regarding the potential for manual action being required if the air supply is lost prior to the end of the BVPS-1 13th refueling outage.

1 The licensee verified that existing procedures, availability of lighting equipment, and operator training were adequate to ensure the operators could perform the required actions credited in the submittal. The licensee explicitly evaluated the potential for local failure of architectural features (such as ceiling tiles in the control room) and the potential for adverse special interactions in the vicinity of safe shutdown equipment, where local operator action may be

.g.

required, as part of the GIP-2 process. As a result of the review, several seismic housekeeping issues affecting the control room were noted and resolved, including the positive connection of ceiling tiles to one another and to their support grid. Furthermore, the licensee performed seismic interaction reviews which eliminated any concems with the plant components and structures located in the immediate vicinity of the components which had to be manipulated. Therefore the potential for physical barriers resulting from equipment or structural earthquake damage which could inhibit operator ability to access plant equipment was considered, and eliminated as a potential barrier to successful operator performance.

On the basis of its review of the licensee's information, the NRC staff finds that the licensee has provided sufficient information to demonstrate conformance with the NRC-approved review methodology outlined in the GlP-2 and is, therefore, acceptable.

2.9 Outlier identification and Resolutions The licensee identified 20 relays as outliers and the resolution of these relay outliers has been completed or is scheduled to be completed as defineated in Section 2.7 of this SE. Section 5.3 of Reference 5 documents the equipment outliers identified during the USI A-46 implementation effort at BVPS-1. The documentation also includes descriptions of the associated defects orinadequac!ss, and methods for resolving outliers. The significant outliers associated with seismic capacity, anchorages, tanks and heat exchangers, and cable tray and conduit raceway supports are discussed in Sections 2.4.1,2.4.3,2.5, and 2.6 of this SE, respectively.

The licensee stated in Section 5.3 of Reference 5 that 230 outliers were identifM for BVPS 1 SSEL equipment items. In Reference 11, the licensee indicated that the number of outliers was recounted to be 231, including 206 equipment items listed in Table 5 3 and 25 tanks and heat exchangers identified in Section 6.2. Of the 206 general SSEL equipment outliers,133 have been resolved and 73 are open. Of the 73 open outliers,51 are dampers and they are being analyzed and are expected to be resolved. The remaining 22 open outliers will require minor physical modifications or analyses, and they are scheduled to be completed during the 13th refueling outage.

The NRC staff review of the licensee's action regarding outliers, indicates that identifM outliers have been satisfactorily resolved or in the process of being resolved by analysis or corrective actions. The licensee indicated that resolution of all outliers has been scheduled to be completed by the end of refueling outage 13, which is planned for spring of the year 2000.

3.0

SUMMARY

OF NRC STAFF FINDINGS The NRC staffs review of the licensee's USl A 46 implementation program, as discussed above, did not identify any significant or programmatic deviation from GIP-2 regarding the walkdown and the seismic adequacy evaluations at BVPS 1.

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4.0 CONCLUSION

The licensee's USI A-46 program at BVPS-1 was established in response to Supplement 1 to GL 87-02 through a 10 CFR 50.54(f) letter. The licensee conducted the USl A-46 implementation in accordance with GIP-2. The licensee's submittal on the USl A-46 implementation indicated that the SSEL contained 528 components, of which 462 were examined during the plant walkdown to verify their seismic adequacy. A total of 231 equipment items and 20 essential relays were identified as outliers. In its May 16,1997, letter, the licensee indicated that all BVPS 1 A-46 open outliers were expected to be resolved during the 13th refueling outage (1R13) which is currently scheduled to end in spring of the year 2000. The licensee's implementation report did not identify any instance where the operability of a particular system or component was questionable. As described in Section 3.0, the NRC staff's review did not identify any areas where the licensee's program deviated from GIP-2 and the staff's SSER No. 2 on SQUG/ GIP-2 issued in 1992.

The NRC staff condudes that the licensee's USl A-46 implementation program has, in general, met the purpose and intent of the criteria in GlP-2 and the staff's SSER No. 2 for the resolution of USI A-46. The staff has determined that the licensee's already completed actions will result in safety enhancements, in certain aspects, that are beyond the originallicensing basis.

Accordingly, the licensee's actions provide sufficient basis to dose the USl A 46 review at the facility. The staff also condudes that the licensee's implementation program to resolve USl A-46 at the facility has adequately addressed the purpose of the 10 CFR 50.54(f) request.

Licensee activities related to the USl A-46 implementation may be subject to future NRC audit and inspection.

Regarding f& G use of atP 2 in licensing activities, the licensee may revise its licensing basis in accordance with the guidance in Section 1.2.3 of the NRC staff's SSER No. 2 on SQUG/ GIP 2, (Reference 2) and the staff's letter to SQUG's Chairman, Mr. Neil Smith dated June 19,1998. Where plants have specific commitments in the licensing basis with respect to seismic qualification, these commitments should be carefully considered. The overall cumulative effect of the incorporation of the GIP-2 methodology, considered as a whole, should be assessed in making a determination under 10 CFR 50.59. An overall conclusion that no USQ is involved is acceptable so long as any changes in specific commitments in the licensing basis have been thoroughly evaluated in reaching the overall condusion. if the overall cumulative assessment leads a licensee to condude a USQ is involved, irworporation of th'a GIP 2 methodology into the licensing basis would require the licensee to seek an amendment under the provisions of 10 CFR 50.90.

Prindpal Contributors: C. Wu J.Ma K. Desai G. Galletti Date: Decernber 9,1998

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5.0 REFERENCES

1. Seismic Qualification Utility Group, " Generic Implementation Procedure (GIP) for Seismic l Verification of Nuclear Power Plant Equipment," Revision 2, corrected February 14,1992.

2. U.S. NRC, " Supplemental Safety Evaluation Report No. 2 on Seismic Qualification Utility Group's Generic implementation Procedure, Revision 2, corrected February 14,1992,"

May 22,1992.

3. Duquesne Light Company letter, to USNRC," Response to Supplement 1 to Generic Letter 87-02, SQUG Resolution of USl A-46," dated September 22,1992

4. USNRC letter, to Duquesne Light Company," Safety Evaluation of Beaver Valley Power Station 1,120-Day Response to Supplement No.1 to Generic Letter 87-02" (TAC No.

M69428), November 20,1992

5. Duquesne Light Company letter, to USNRC, " Generic Letter 87-02, Summary Report for Resolution of USI A-46 (TAC No. M69428)," January 31,1996, and Attachment 1," Beaver Valley Power Station, Unit 1, USI A-46 Seismic Evaluation Report"

6. Duquesne Light Company letter, to USNRC," Response to NRC's Request for Additional Information on the Resolution of USl A BVPS-1," May 16,1997

7. Duquesne Light Company letter, to USNRC," Response to NRC's Request for Additional Information on the Resolution of USl A BVPS-1," June 2,1998

8. U 3NRC letter, to Duquesne Light Company," Request for Additional Information Resolution of US! A-46 (TAC No. M69428)," January 10,1997

9. USNRC letter, to Duquesne Light Company, " Request for Additional Information Resolution of USl A-46 (TAC No. M69428)," March 4,1998

10. "USl A-46 Relay Evaluation Report for Beaver Valley Power Station, Unit 1," January, 1996 (Attachment 2 to the BVPS-1 summary report for USI A-46 resolution (Reference 5)).

11. USNRC memorandum from Donald S. Brinkman to Docket File, " Beaver Valley Power Station, Unit 1 - Request for Additional Information Resolution of USl A-46 (TAC No.

M69428)," October 16,1998

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