ML20199F635

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Summary of 970904 Meeting W/Squg in Rockville,Md Re Resolution of USI A-46, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. W/Attendance List,Presentation Matl & Brief Discussion
ML20199F635
Person / Time
Issue date: 11/19/1997
From: Dan Dorman
NRC (Affiliation Not Assigned)
To: Stolz J
NRC (Affiliation Not Assigned)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 9711240281
Download: ML20199F635 (30)
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Text

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s UNITED STATES -

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NUCLEAR REGULATORY COMMISSION _

2 WASHINGTON. D.C. 30046 4 001

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November 19, 1997 MEMORANDUM T0: John F. Stolz. Lead Project Director. USI A-46

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Projecc Directorate I-2 Division of Reactor Projects - I/II l

Offi e of Nuclear Reactor Regulation FROM:

Daniel H. Dorman. Lead Project Manager. USI A-46 Project Directorate I-3 i

Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF SEPTEMBER 4. 1997. MEETING WITH REPRESENTATIVES OF THE SEISHIC QUALIFICATION UTILITY GROUP (SOUG)

On September 4. 1997, pursuant to notice, the NRC staff met with representatives of SQUG at NRC headquarters in Rockville. Maryland, to discuss the resolution of Unresolved Safety Issue (USI) A 46, " Verification.of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors." The purpose of the meeting was to continue discussions held during a meeting on August 14. 1997, regarding use of the SOUC Generic Implementation Procedure.

Revision 2 (GIP-2), after completion of site specific implementation.

The list of attendees is provided as Attachment 1.

SOUG's slides are 3rovided as.

The staff presented a brief discussion of "Framevorc for Use of GIP 2 to Demonstrate Seismic Adequacy of New and Replacement Equipment (NARE) in USI A 46 Plants" which is provided as Attachment 3.

The SOUG representatives presented several examples of instances in which it believed the staff had allowed evaluation of the overall impact of a change pursuant to 10.CFR 50.59. " Changes, tests and experiments." rather than evaluation of discrete aspects of the change.

SOUG 3ro30 sed that this approach should be acceptable for incor) oration of tie CP-2 into facility liceasing bases for USI A 46 plants.

T1e staff indicated that it would need additional supporting information regarding the examples cited by SQUG.

The staff and SOUG representatives agreed in principle, that the im)lementation.of the GIP-2 approach for USI A-46 plants provides safety enlancement in certain aspects, beyond the original licensing bases.

The staff reiterated from the Su)plemental Safety Evaluation Report, No. 2. (SSER No. 2) dated May 22. 1992, t1at a 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. The staff's approval of the implementation of the GIP does not relieve the licensees from the requirement to address all aspects of anreviewed safety questions as specified in 10 CFR 50,59 (for example, those plants for which the Final Safety Analysis Report has specified damping values that differ from the GIP.) The staff summarized recent NRC staff activities regarding the 10 CFR 50.59 process, including 11ll!ll!! 14ll1ll,1!Il EM2"n?u Hua wn L

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recent action involving NUREG 1606 " Proposed Regulatory Guidance Relating to

-the Implementation of 10 CFR 50.59 (Changes. Tests or Experiments)."

S0JG agreed to provide additional information to su port their aroposed approach to incorporation of the GIP-2 into facilit licensing )ases pursuant to 10 CFR 50.59.

SOUG also agreed to provide examp es of how they would expect licensees to perform evaluations pursuant to 10 CFR 50,59 for facilities that have non-specific seismic licensing basis requirements. and for facilities that have connitted to the guidance contained in IEEE 344-71.

The SOUG also indicated they disagreed with the staff guidelines regarding NARE (Attachment 3).

The NRC staff agreed to evaluate the materials provided by SOUG and to discuss internally whether and how the provisions of 10 CFR 50.59 can be used to incorporate the GIP-2 into a facility's licensing basis.

Original signed by Daniel H. Dorman. Lead Project Manager Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Attachments: As stated (3) cc w/atts:

Mr. Neil P. Smith. Chairman seismic Qualification Utility Group c/o MPR /dsociates. Inc.

320 King Street Alexandria. V^

22314 Mr. R. Kassawara. EPRI Program Manager 3412 Hillview Avenue P. O. Box 10412 Palo Alto, CA 94304 DISTRIBUTION See next page DOCUMENT NAME: G:\\ooaumsoucura.suu Ts recobre e copy of th6s document, bidicate ki the boa:

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DJilBIBUTION FOR MEETING SUM 4ARY WITH SEISMIC OUALIFICATION UTILITY GROUP-HARD COPY PDI-3 RF OGC-ACRS E-Mail S. Collins /FMiraglia (SJCl) (FJM)

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D. Ross (SLM3)

R. Wessman (RWH)

G.'Bagcht (GXB1)

K. Manoly (KAM)

G. Kelly (GBK)

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LIST OF ATTENDEES MEETING WITH REPRESENTATIVES OF THE SEISMIC 00ALIFICATION UTILITY GROUP ROCKVILLE. MARYLAND AUGUST 14. 1997 NRC Office of Nuclear Reactor Reaulation Dick Wessman Kamal Manoly Robert Rothman Pei-Ying Chen Dan Dorman Eileen McKenna Glenn Kelly NRC Office of the Generai Qunigl Geary S. Mizuno Commonwealth Edison Winston & Strawn Neil P. Smith Malcolm Philips MPR Associate.1 Nuclear Enerav Institute William R. Schmidt Doug Walters David A. Freed Richard Starck IYA Southern Comoany Services. Inc.

Richard Cutsinger Donald P. Moore Duke Power Comoany

[QL Jim Thomas Paul Baughman SERCH Licensino/Bechtel GPU Nuclear Altheia Wyche Kenneth Whitmore Southern Nuclear Operatina Comoany Troutman Sanders LLP Deanna McCombs Thomas Penland

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Purpose andAgendafor NRCISQUGMeetmgon y

September 4,1997 -

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l Purpose ofMeeting To continue working level discussions between NRC staff and SQUG regarding use of the GIP after closure of USl A 46.

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Attachment'2 1

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Objectives of 8/14/97 Meeting

  • Determine an acceptable closure to the USI A46 Program
  • Reinforce use of GIP for new arJ replacement equipment (NARE)

Summary ofAgreementsfrom 8/14/97 Meeting

  • The application of the SQUG GIP has increased the safety margin in A46 plants.
  • Neither GL 8'7-02, nor the implementation of the GIP, changes ihe licensing basis.
  • The A46 review is a 50.54(f) request for information; a " snapshot in time."
  • A46 plants are under no obligation, other than their -

voluntary commitments, to resolve outliers unless they deviate from the plant's licensing bases.

2

SummaryofAgreementsfrom 8/14/97 Meeting (Cont'd)

  • SOUG utilities have no obligation to maintain the equipment qualification to the GIP or current standards, e.g., IEEE 344-75, except for plant specific commitments.
  • The existing seismic licensing bases for each plant will continue to govern unless licensees or NRC take action.
  • GIP can be used for NARE if equipment meets the screening criteria. Outliers ultimately not meeting GlP must be resolved in accordance with the current licensing basis.

Action Itemsfrom 8/14/97 Meeting

  • NRC OGC to further evaluate changing the plant licensing bases to allow adoption of GIP using the 50.59 process; treating the GIP at the methodology level and not at its individual element level.
  • NRC to evaluate an " efficient" licensing amendment process.
  • SOUG to provide comments on NRC's guidelines for NARE.

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Survey ofA-46 Plant Seismic Qualification LicensingBcses

  • Survey results for 75% of A-46 units showed:
  • Units with non-specific LB 62%
  • Units with specific commitments, e.g.,IEEE 344 71 38 %
  • Most of the IEEE 344-71 LBs refer only to electrical R

equipment

  • Some of the IEEE 344-71 LBs apply only to specific systems
  • Therefore, adoption of the GIP significantly increases the scope of equipment addressed by a specific methodology StaffPosition/ Practice:

New/Different Methodologies Evaluated and Adopted as Complete Programs

  • Hardenedwetwellvent(GL8916)
  • In-service inspection of containment tendon prestress force (R.G.1.35 Rev. 2 and Rev. 3)
  • Emergency Procedure Guidelines and Accident Managsment Guidelines (EPG Rev. 4 and NRC Letter 5/27/94)
  • N411 damping for piping analyses (R.G.1.84)
  • Adoption of new Code editions with less conservative parts

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t Agenda Topics ForDiscussion

1. Summary review of GIP 2 Part 1, Section 2.3.3, Revision of Plant Uconsing Basis (SOUG provide text)
2. Use of 50.59 process to adopt the GlP (SOUG to summarize)
3. Suggested changes to staff's 8/14/97 criteria for NARE (all)
4. NRC review of license amendment process to use GIP-2 methodology (staff)
5. Agreements and action items (all)
6. Future meeting (all)

Agreements & Action Items N

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AgendaforFuture Meeting 6

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Evaluation of GIP as a Complete Methodology is Consistent with Previous StaffPractice/ Position GIP method uses a "new rnodel' NRC expects GlP 2, as supplemented by SSER No. 2, to be used in its entirety:

"The third paragraph of Section 1.2 of Part I [of GIP-2] states that

'Because the NRc will document its evaluation of the GIP in a safety evaluation report (sER) the Glpprovides an NRC-accepted method to verify the seismic adequscy of equipment... ' The staff concurs with this statement, provided that GlP 2 le ueod in its entirety in conjuncen with and supplemented by the clarifications, interpretations, and exceptions identifled in this supplement, and that the application of the GIP is limited to USl A 46 plants only "

SSER No. 2, pg. 6 1

Summary ofSQUGPosition GIP methodology is a new and different model which a

was thoroughly reviewed and accepted by NRC NRC acknowledges that implementation of GIP method meets NRC seismic regulations and enhances seismic safety 50.59 process is appropriate for adopting GIP License amendment process to adopt GIP is not nececsary

" Cherry Picking" elements of GIP is not appropriate Alternative of not adopting GIP is inconsistent with closure of USl A-46 4

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Summaryof SQUG Position on Adoption ofGIPfor PlantLicensingBases Presemed to NRC September 4,1997 Rockvule, MO t

i Summary ofSQUG Position

  • GIP methodology is a new and different model which was thoroughly reviewed e,d accepted by NRC
  • NRC acknowledges the
. lementation of GIP method meets NRC seismic regulations and enhances seismic safety
  • 50.59 process is appropriate.for adopting GIP
  • Ucense amendment process to adopt GIP is not necessary
  • " Cherry Picking"_ elements of GIP is not appropriate
  • Alternative of not adopting GIP is inconsistent with closure of USI A 46 1

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$IPMethodologyIs New & Different Model Which Was ThoroughlyReviewed NRC backfit analysis associated with requiring licensees to review the seismic adequacy of equipment acknowledges that the SQUG method uses a "new model."

"The key factor in deciding if the implementation of A 46 is a backfit (as defined in 10 CFR 50.109) is the consideration that the review "model' has changed. That is, all operating plants are being required to review equipment seismic capability against a "new model" (i.e... using comparison to seismic experience or tests data as compared to the basis used for their original licensing review) "

NUREG 1 11, page 16 NRCAcknowledges That GIPMeets NRC Seismic Regulations

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"Therefore, GIP-2 methodology is an acceptable evaluation method, for USI A-46 plants only, to verify the seicmic adequacy of the safe-shutdown equipment and to satisfy 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."

SSER No. 2. pg. 5 4

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50.59 Process Is Appropriate ForAdopting GIP asPlantLicensingBasis

  • GlP meets seismic regulations
  • Improves seismic safety compared to original licensing bases (LBs)
  • GIP methodology is a new and different model
  • Mixing and matching elements from old LBs into GIP is not appropriate or practical
  • Evaluating GIP as a whole, integrated method is consistent with long standing practice i

I StaffPosition/ Practice:

New/Different Methodologies Evaluated and Adopted as Complete Programs

  • Hardenedwetwellvent(GL8916)
  • In-service inspection of containment tendon prestress force (R.G.1.35 Rev. 2 and Rev. 3)
  • Emergency Procedure Guldelines and Accident Management Guidelines (EPG Rev. 4 and NRC Letter 4

5/27/94)

BWR Mark I containment long-term criteria (NUREG-0061)

  • N411 damping for piping analyses (R.G.1.84)
  • Adoption of new Code editions with less conservative parts

50.59 Process Is Appropriate For Adopting GIP as Plant Licensing Basis

  • gip meets seismic regulations improves seismic safety compared to original e

licensing bases (LBs)

GIP methodology is a new and different model Mixing and matching elements from old LBs into GlP is not appropriate or practical Evaluating GIP as a whole, integrated method is consistent with long standing practice StaffPosition/ Practice:

New/DifJerent Methodologies Evaluated and Adopted as Complete Programs Hardened wetwellvent (GL 89-16)

In-service inspection of containment tendon prestress force (R.G.1,35 Rev 2 and Rev,3)

Emergency Procedure Guidelines and Accident Management Guidelines (EPG Rev,4 and NRC Letter 5/27/94)

BWR Mark l containment long-term criteria (NUREG-0661)

N411 damping for piping analyses (R.G 1.84)

Adoption of new Coda editions with less conservative parts Use of EPRI MOV Performance Prediction Program

- (GL 89-10, GL 96-05) 3

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Summaryof SQUGPosition on Adoption ofGIFfor PlantLicensingBases Presorted to NRC Sepomber 4,1M7 -

HockvGe, MD 1

--Summary ofSQUGPosition..

  • GIP methodology is a new and different model which was thoroughly reviewed and accepted by NRC
  • NRC acknowledges that implementation of GIP method meets NRC seismic regulations and enhances selsmic safety
  • 50,59 process is appropriate for adopting GIP
  • Ucense amendment process to adopt GlP is not necessary
  • "Ch?rry Picking" elements of GIP is not appropriate
  • AlternaNe of not adopting GIP is inconsistent with closure of USI A-46 1

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GIPMethodologyIs New & Different Model Which Was ThoroughlyReviewed NRC backfit analysis associated with requiring licensees to review the seismic adequacy of equipment acknowledges that the SOUG method uses a "new model."

"The key factor in dec' ding if the implementation of A 46 is a backfit (as defined in 10 CFR 50.109) is the consideration that the review 'model' has changed. That is, all operating plants are being required to review equipment seismic capability against u *new model" (i.e... ut,h,g comparison to seismic experience or tests data as compared to the basis used for their original licensing review)."

NUREG-1211, page 16 NRCAcknowledges That GIPMeets NRC Sei.smic Regulations "Therefore, GIP-2 methodology is an acceptable evcJuation method, for USl A-46 plants only, to verify the seismic adequacy of the safe-shutdown equipment and to satisfy 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."

SSER No. 2, pg. 5 4

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50.59 Process Is Appropriate ForAdopting GIP as Plant LicensingBasis

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  • GlP meets seismic regulations improves seismic safety compared to original licensing bases (LBs)
  • GIP methodology is a new and different model
  • Mixing and matching elements from old LBs into GlP is not appropriate or practical Evaluating GlP as a whole, integrated method is consistent with long standing practice StaffPosition/ Practice:

NewlDifferent Methodologies Evaluated and Adopted as Complete Programs

  • In-service inspection of containment tendon prestress force (R.G.1.35 Rev. 2 and Rev. 3)
  • Emergency Procedure Guidelines and Accident Management Guidelines (EPG Rev. 4 and NRC Letter S/27/94)

N411 damping for piping analyses (R.G.1.84)

  • Adoption of new Code editions with less conservative parts

4 Criteria and Guidelines from GIP-2, Part I, Section 2.3.3

" Revision of Plant Licensing Basis" Presented to NRC September 4,1997 Rockville, MD e

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2.3.3 Revision of Plant I icensing Bases. A USI A-46 licensee, in accordance with 10 C.F.R. & 50.59, may revise the plant licensing bases to reflect that the USI A 46 (GIP) methodology may henceforth be used as the methodology for verifying the seismic adequacy of mechanical and electrical equipment within the scope of equipment covered by the GIP. Licensees should include deviations from the SQUG commitments and guidance of the GIP in their unreviewed safety question analyses under 10 C.F.R. & 50.59.

.(See Example 5 and Paragraph 2.3.4, below, for extending the scope of plant equipment to which the revised licensing bases apply.)

With the exception of cable and conduit raceway systems, the USI A-46 (GIP) methodology is an equipment-level seismic verification methodology for mechanical and electrical equipment, tanks and heat exchangers. For A-46 plants, this methodology is adequate to verify the seismic adequacy of equipment within the scope of the GIP.

However, it is recognized that in some cases the plant licensing basis may address aspects of the seismic adequacy of the systems, in which this equipment is installed, that are not addressed by the GIP, Where this is true, licensees are not relieved 'of the responsibility to evaluate and adequately address such system-level seismic requirements as part of the revision of a plants' licensing bases for equipment.

2

The USI A-46 (GIP) methodology shall not supersede any seismic qualification requirements imposed or committed to in connection with the resolution of other specific issues (e.g., Regulatory Guide 1.97, TMI Action Item II.F.2, and Individual Plant Examination for External Events) unless these qualification requirements or commitments are also revised according to appropriate regulatory requirements, where applicable.

To help clarify the intent of this section for modifying the licensing bases of the plant, the following examples are provided. These examples explore some, but not all, of the possible scenarios that may be encountered by licensees when revising their licensing bases to adopt the USI A-46 (GIP) methodology (or an alternative) as the method for verifying the seismic adequacy of electrical and mechanical equipment within the scope of equipment covere.d by the GIP.

I 3

n Frample 1 Revising the plant licensing bases when the plant is not currently committed to using any specific method to verify the seismic adequacy of equipment, and there are no specific commitments to seismic qualification requirements for equipment connected with the resolution of other specific issues.

When a plant has no general commitment to methods or standards for seismic verification or qualification of equipment, i.e., the FSAR is silent, and no specific licensing commitments exist for specific issues (as discussed in Example 2, below, the plant may adopt the USI A-46 (GIP) methodology without specific notification of the NRC. This is neither a license change nor a change to the facility as described in the FSAR.

Nevertheless as with any change in the plant procedures or methodology for evaluation of plant adequacy, the basis for the change should be documented. One option available is a safety evaluation pursuant to 10 C.F.R. D 50.59 together with a formal FSAR change (if appropriate) in accordance with.10 C.F.R. & 50.71(e).

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F ample 2 Revising the plant licensing bases when the plant is not generally committed to any' specific method to verify seismic adequacy, but when specific commit-

- merits to seismic qualification requirements exist for equipment connected with the resolution of other specific issues.

(a) For equipment not covered by any specific commitment, a Section 50.59 safety evaluation should be conducted and the FSAR changed (if appropriate) tc reflect the new commitment in the manner suggested for Example 1, above.

(b) The USI A-46 (GIP) methodolo'gy will not supersede seismic qualification requirements imposed or committed to in connection with the resolution of other specific issues (e.g.,

Regulatory Guide 1.97, TMI Action Item II.F.2, and Individual Plant Examination for External Events).

To substitute the USI A-46 (GIP) methodology for specific licensing commitments such as these, licensees must follow Commission regulations, for example,10 C.F.R. 50.59 will apply in some cases.

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Frample 3 Revising the plant licensing bases when the plant is generally committed to using IEEE 344-1971 to verify the seismic adequacy of equipment, but has no specific commitments to seismic qualification requirements for equipment connected with the resolution of other specific issues.

Where the plant has a general commitment to IEEE 344-71 and no other specific licensing commitments exist, a Section 50.59 safety evaluation should be performed and documented.

In addition, if a change to tl:e FSAR is appropriate, the NRC must be notified pursuant to Section 50.71.

As stated in GIP Section 2.3.2 above, the USI A-46 (GIP) methodology is an approved alternative method for satisfying the pertinent equipment seismic requirements of all applicable regulations for plants within the scope of USI A-46.

Accordingly, unless there are some unique and unusual circumstances applicable to the plant (such as deviations from the SQUG commitments or implementation guidance of the GIP), a change of-commitment from IEEE 344-1971 to the USI A-46 (GIP) methodology should not involve an 6

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unreviewed safety question for matters related to

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verifying the seismic adequacy of electrical and mechan-ical e.quipment. This determination is subject to the previously-discussed limitation that the USI A-46 (GIP) methodology applies to equipment seismic adequacy and not to the overall adequacy of the system in which the equipment is installed. Thus, USI A-46 licensees are not relieved of the requirement to perform and document a Section 50.59 evaluation to determine whether unreviewed safety questions exist.

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Frample 4

- Revising the plant licensing bases when the plant is generally committed to using IEEE 344-1971, and in addition, has specific commitments to other guidance for equipment connected with resolution of specific issues.

(a) For equipment not subject to seismic qualification requirements imposed or committed to in connection with the resolution of otha specific issues, the plant may modify its commitment to reflect use of the USI A-46 (GIP) methodology as described for Example 3, above.

(b) For equipment subject to seismic qualification requirements imposed or committed to in connection with the resolution of other specific issues, the commitments to the specific requirements may be revised as described in paragraph (b) of Example 2, above.

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Fxample 5 This is a variation of Examples 1-4 that expands the -

scope of the USI A-46 (GIP) methodology to include equipment outside the scope of A-46, when the equipment is within the scope of equipment cove-red by the GIP.-

A change of licensing basis commitment from IEEE 344-1971, as described in above examples, will result in the application of the USI A-46 (GIP) methodology to plant equipment outside the scope of A-46. The scope of application of the USI A-46 (GIP) methodology may be expanded to include

.this additional mechanical and electrical equip-ment, provided the licensee also commits to the guidelines presented in Section 2.3.4 of Part I of the GIP, " Future Modifications and New and Replacement Equipment." The Section 50.59 safety evaluation to change the plant licensing bases (as discussed in the above examples) should also consider the effects of expanding the

-application of the USI A-46 (GIP) methodology from A-46 equipment to the new scope of equipment. However, absent unique and unusual circumstances applicable to the plant, expanding l

the scope of the A-46 methodology as noted above should not constitute an unreviewed safety question.

l-9

Subsequent to resolution of USI A-46, if licensees take exception to the GIP criteria and modify those criteria for plant-specific application, this shall be accomplished by modifying the plant licensing bases using the regulatory provisions of 10 C.F.R. 50.59. This will be considered a e

plant-specific modification of a licensing commitment, not a modification of the GIP.

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FRAMEWORK FOR USE OF GIP 2 TO DEMONSTRATE I

SEISMIC ADEQUACY OF NEW AND REPLACEMENT l

EQUIPMENT IN USl A 46 PLANTS j

4 PREREQUISITE Complete resdlution of USl A 46 at the facility and issuance of staff closure SE

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Plants whose current licensing basis do not include spscific commitments to seismic qualification approaches, methods or parameters used in conventional seismic analysis methodologies Licensees may use 50.59 to incorporate GIP-2 in the FSAR for e

equipment classes covered by GIP 2 l

Discuss GlP-2 applicability to overall population of plant e

components and equipment Specify seismic qualification approach (es) fornsw and e

replacment equipment (NARE) that are neither identical nor similar to equipment classes covered by GIP-2 B.

Plants whose current licensing basis include specific commitments to seismic qualification approaches and methods or parameters used in conventional seismic analysis methodologies o

Identify the criteria and procedures (including parameters) e specified in GlP-2 that deviate from, and are less conservative than, seismic design attributes specified in current licensing basi 6 (e.g., plant specific in-structure spectra, equipment damping values, etc)

. identify the criteria, procedures, parameters, etc., in GIP-2 that

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e deviate from, and are less conservative chan, licensing commitments (e.g., IEEE-344, Industry Standards, etc.) related to equipment specific qualification aspacts. Particular areas to be addressed include:

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1)

Use of non safety-related equipment versus safety related i

equipment or Class 1E equipment; 2)

Use of the ' Rule of Box" versus component or device testing or analysis; 3)

Use of " satisfying the intent of equipment caveat' versus actual equipment dynamic characteristics or similarity; and t

4)

Fulfillment of requirements on environmental qualification of equipment (i.e., applicable requirements such as 10 CFR 50.49, NUREG-0588, IEEE 3231974 or 1971).

e Submit a license amendment to address identified deviations

. and provide justification for future use of GIP 2 with (or without) a plant specific revision, to demonstrate seismic adequacy of l

NARE that are identical or similar to equipment classes covered i

by GIP-2 within (or outside) A-46 scope

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Discuss GlP-2 applicability to overall population of plant i

e components and equipment i

Specify seismic qualification approch(es) for NARE that are e

neither identical nor similar to equipment classes covered by GlP 2 t

STAFF REVIEW / APPROVAL PROCESS Based on supplemental staff SE on SQUG's GIP-2 and plant-

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e specific A-46 resolution SE j

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Criteria in staff guidelines presented in August 14,1997, meeting with SQUG 1

e Thorough account and adequete reconciliation of deviations

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between current licensing basis and proposed FSAR change

- Potential for requesting additional information e

e Expedient review depending on volume of amendments 7

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