ML20199F540
| ML20199F540 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1997 |
| From: | Casey Smith NRC (Affiliation Not Assigned) |
| To: | Stolz J NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20199F544 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 9711240255 | |
| Download: ML20199F540 (20) | |
Text
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-k UNITED STATES NUCLEAR REGULATORY COMMISSION W ASHINGTON, D.C. SeteHOM k
November 20, 1997 NE*dRANDUMT0: -JohnF.Stolz,LeadProjectDirector.USIA46 ProjectDirectorateI2 DivisionofReactorProjects-1/11 Office of Nuclear Reactor Regulation FROM:
CraigW. Smith,ProjectManeger ProjectDirectorate13 Division of Reactor Projects 1/II Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF OCTOBER 30, 1997. HEETING WITH REPRESENTATIVES OF THE SEISMIC OUAllFICATION UTILITY GROUP (SOUG)
On October 30, 1997, members of the NRC staff met with representatives of the seismic Qualification Utility Group (50VG) in a public meeting to discuss the 50VG proposed guidelines for incor> orating the Generic Implementation Procedure (GlP) into the licensing > asis for USI A 46 plants. This meeting was the third in a series of meetings between the NRC and SOUG on this subject: the first and second meetings were held on August 14, and September 4,1997, respectively. Attachment (1) is a list of meeting attendees. Attachment (2) is a copy of view graphs and hand outs used by the 50VG during the meeting, Prior to the meeting, the 50VG had sent two letters to NRC. The first letter, dated October 6, 1997, is entitled " Guidelines for Adoption and Use of GIP as Licensing Basis for A 46 Plants." and the second letter, dated October 22, 1997, is entitled " Examples of Enhanced Safety Based on the Overall Effect of a Change." Both letters were central to the focus of the meeting. Copies of both letters were included in Attachment (2). The October 6. 1997. letter provides the 500G interpretation of the provisions of GIP-2, as accepted and supplemented by NRC Supplemental Safety Evaluation Report No. 2. dated May 22, 1992, and the requirements of applicable regulations pertaining to changing a plant's licensing basis. The letter provides the 500G position on the use of the provisions of 10 CFR 50.59 and the licensing amendment process and reflects SOUG's belief that the 50.59 process is the ap adopting the GIP methodology into the licensing basis. propriate process for The letter requested NRC concurrence on the SOUG's interpretation of the 50.59 process.
The October 22. 1997 letter provides a summar of five examples portrayed by the SOUG as illustrating where NRC accepted t,.e use of new methodologies that improved plant safety on an overall basis.
The meeting opened with a presentation by the 500G outlining their positions as stated in the October 6,1997, letter to the NRC staff. The staff had one editorial correction to the view graphs used by 50VG during the October 30, 1997 meeting. The first bulleted item on slide number 7 could be intersreted as stating that the staff concurs with the position described in the 50JG's October 6, 1997 letter.
The SOUG stated that the intent of this bullet was to show NRC concurrence as a recommended or requested course of action and was not meant to imply that the staff had concurred in the SOUG position.
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PDR REVQP ERGS e,.
J. Stolz-The staff provided its views on SOUG's October 6,1997, letter.
The staff doesnota$9 process.ree with the SOUG positions stated in the letter regarding the of the 50.
Neither the staff nor the SOUG can draw a generic conclusion regarding a finding that no Unreviewed Safety Question (US0) is involved if the GIP is adopted into the licensing basis for USI A 46 plants.
This determination must be made by individual licensees: consequently, the staff does not agree with the 500G approach.
Prior to concluding the meeting the staff and 500G briefly discussed the examples provided by SOUG in their October 22, 1997 letter.
The staff reiterated its commitment to provide the SOUG a written response to their
- 0ctober 6, 1997 and October 22, 1997 letters. Both parties agreed that it would be premature to schedule an additional meeting until after the issuance of the staff's written response to the two letters.
Original signed by CraigW. Smith,ProjectManager ProjectDirectorateI3 DivisionofReactorProjects-1/11 Office of Nuclear Reactor Regulation Attachments: As stated (2) cc w/atts:
Mr. Neil P. Smith, Chairman Seismic Qualificetion Utility Group c/o MPR Associates, Inc.
320 King Street Alexandria. VA 22314 Mr. R. Kassawara, EPRI Program Manager 3412 Hillview Avenue P, 0. Box 10412 Palo Alto, CA 94304 DISTRIBUTION See next p\\sunmsouauta suu age DOCUMENT NAME:
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r LIST OF ATTENDEES MIETING WITH REPRESENTATIVES OF THE Y !SHIC OUALIFICATION llTILITY @Q2 ROCKVILLE. MARYLAND DCTOBER 30. 1997 i
NRC Office of Nuclear Reactor Reaulation l
Jack Strosnider Goutam Bagchi Dick Wessman Kamal Manoly j
Robert Rothman Pei Ying Chen Craig Smith NRC Office of the General Counsel Geary S. Mizuno I
Commonwealth Edison Winston & Strawn Neil P. Smith Perry Robinson HPR Associates Nuclear Enerav Institute William R. Schmidt Doug Walters David A. Freed IYA Southern Comoany Services. Inc.
Richard Cutsinger Donald P. Moore Dule Power Comoany EQE Jim Thomas
~ Paul Baughman SERCH Licensina/Bechtel GPU Nuclear Altheia Wyche Kenneth Whitmore SNC - Southern Nuclear Troutman Sanders LLP Kermit Whitt Thomas Penland
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- = - m Incorporation of the GIPMethod into
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Maintenance of Seismic Adequacy I
Presentation to USNRC l
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i AgendaforNRC/SQUGMeeting October 30,1997 - White Flint, MD
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- 1. Objective
- 2. Review of SQUG Position l
- 3. Discussion of SQUG Position
- October 6,1997 Letter " Guidelines for Adopting GIP" l
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- October 22,1997 Letter " Examples of Enhanced Safety j
Based on Overall Effect of Change" l
- 4. Agreements i
- 5. Agenda for Executive-Level Meeting t
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Meeting Objective i
- Agree on acceptable method for closure of USl A-46, 1
including sdoption and use of the GIP as a licensing basis method l
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Summary ofSQUG Position 1
GIP methodology is a new and different model which was
. thoroughly ~eviewed and accepted by NRC r
NRC acknowledges that implementation of GIP method j
meets NRC seismic regulations and enhances safety l
A new procedure / methodology should be evaluated as a j
l whole; " cherry picking" elements is not appropriate 50.59 process is appropriate for adopting GIP License amendment process to adopt GIP is not l
necessary i
SQUG position is consistent with industry 50.59 j
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t Alternative of not adopting GIP is inconsistent with closure of USI A-46 i
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i Licensee Regulatory Responsibility Under
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Neither GL 87-02 nor implementation of the GIP change l
the seismic ~ licensing basis; the A-46 review is a 50.54(fi l
request for information; a " snapshot in time."
l SQUG members are under no obligation to resolve f
outliers identified during the USI A-46 evaluation, other than voluntary commitments or outliers which deviate s
from the plant licensing basis.
Other than as required by the existing licensing basis, l
SQUG members have no obligation to maintain.
equipment (existing or NARE) to the GIP or current l
standards.
- Therefore, the existing seismic licensing bases for each
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plant will continue to govern.
i 5 10/29/97 i
i ALTERNATIVES FOR THE FUTURE FOR AN A-46 PLANT I
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NRC/lixtustry, Entire GIP
> As Lic. Basis (O
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Recommended Closure Process
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NRC concurs with SQUG position described in October 6,1997 letter - including that a LB change evaluation for A46 plants should consider the GIP as a whole i
l Consistent with SSER #2, licensees adopt GIP following guidance of SQUG's October 6,1997 letter i
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Back-up Slides for October 30 Meeting
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- Action items from September 4,1997 Meeting (1)
- October 6,1997 Letter (3) 1
- October 22,1997 Letter (1)
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l SQUG: Provide write-up on how to do a 50.59 [to l
adopt the GIP] for a plant with a non-specific l
licensing basis (clarify "non-specific licensing basis).
[10/6 letter]
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SQUG: Provide write-up on proposal to do a 50.59 or l
license amendment for a plant with 344-71 Commitment. [10/6 letter]
SQUG: Provide examples of where 50.59 was used l
l for method level change vs. element change that was acceptable to NRC Staff. [10/22 letter]
NRC: Review above write-ups and have additional l
l internal discussions to determine how 50.59/ license
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L October 6,1997 Letter i
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Purpose:
Clarify ground rules in GIP-2 and SSER No. 2 I
for adoptirig GIP as LB method in A-46 plants
- A-46 Plants with General /Non-Specific LBs
- No reference to specific method or procedure for demonstration of seismic adequacy i
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- shall be designed to withstand a DB earthquake" j
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- shall be shown to be seismically adequate by I
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- No formal LB change required l
13 10/29/97
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- A-46 Plants with Specific LBs (e.a. IEEE 344-713
- 10 CFR 50.59 process i
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- New, different methodologies (models, NUREG 1211) j must evaluate margin on program as a whole -
l individual element comparison not appropriate or L
valid (this is consistent with industry practice) l t
- Methodology reviewed and accepted by SQUG l
licensees, industry experts, NRC consultants and l
l staff, and was accepted by SSER No. 2 l
- Methodology meets applicable regulations
- NRC and SQUG agree GIP method provides a safety enhancement over existing A-46 licensing bases l
- Adoption of GIP via 50.59 should not result in USO l
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October 6,1997 Letter i
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- 10 CFR 50.90,50.91 and 50.92, License Amendment j
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> Option only necessary if special LB commitments preclude use of 50.59 i
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-thus meets standard of adequate protection of public l
health and safety l
- No comparison with existing LB is required to confirm i
this (only necessary for determining timing of any l
requested public hearing vs. NRC approval)
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- Administrative effort, timing, potential for delays, cost, and proposed NRC review process preclude this option l
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15 10/29/97 t
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i October 22,1997 Letter i
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- Five examples cited where the NRC staff has i
accepted Ose of a new methodology which i
enhanced safety when taken as a whole, though individual elements seemed less conservative l
<A O Hardened Wetwell Vent (GL 89-16) i
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/ @p(9 Emergency Procedure Guidelines and Accident Management Guidelines l
- In-Service Inspection of ContainmentTendons
- BWR Mark i Containment Long-Term Criteria j
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- ASME Code Case N-411: Damping for Piping Systems j
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i DISTRIBilTION FOR MEETING SlM MRY WITH $ 1$MIC OlRLIFICATION UTILITY GROUP i
E Mail ST Collins /fHira lia (SJC1) (FJM)
R. Zimmerman (RP )
- 8. Boger (BAB2)
R. Eaton (RBEI)
D. Dorman (DHD) i C. Smith (CXS1) i T. Clark (TLCl)
D. Ross (SLM3)
R. Wessman (RWH)
G. Bagchi (GXB1)
K. Manoly-(KAM)
J. Strosnider (JRS2)
P. Y. Chen (PYC)
R.'Rothman (RLR)
E. McKenna (EMM)
G. Mizuno (GSM)
B. McCabe (GCM)
C. Hehl RI (CWH) p y<0 )
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