ML20199F701

Summary of 970814 Meeting W/Squg in Rockville,Maryland Re Resolution of USI A-46, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. List of Meeting Attendees & Meeting Viewgraphs Encl

ML20199F701
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 9711240305
Download: ML20199F701 (28)

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November 19, 1997 e

riEMORANDUM TO: John F. Stolz. Lead Project Director. USI A 46 Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation FROM:

Daniel H. Dorman, t.ead Project Manager. USI A-46 Project Directorate I 3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

SUMMARY

OF AUGUST 14. 1997. HEETING WITH REPRESENTATIVES OF THE SElst'IC OVALIFICATION UTILITY GROUP (SOUG)

On August 14. 1997, pursuant to notice, the NRC staff met with representatives of SOUG 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 agenda for the meeting includeu discussion of the regulatory history of USI A 46, the status of licensee implementation of the SOUG Generic Implementation Procedure (GlP). resolution of open issues, plans for program closure and continued use of the GIP for seismic adecuacy wification of new anu vplacement equipment (NARE). The list of attencees is provided as Attachment 1.

500G's slides are 3rovided as Attachment 2.

The staff presented a brief discussion of " Future iodifications and New and Replacement Equipment in USI A-46 Plants" which is provided as Attachment 3.

The 50VG rearesentatives presented a brief history of the USI A 46 issue, including t1e development of an acceptable methodology for resolving the issue and development of an implementing procedure (the GIP) to ap)1y the methodology.

It was noted that the resolution of USI A-46 t1 rough implementation of the GIP does not affect the seismic licensing basis of the affected facilities.

The SOUG members are interested in incorporating the GIP into their licensing bases for seismic adequacy verification of NARE.

The SOUG representatives proposed that the GIP could be incurporated into the facility licensing bases pursuant to 10 CFR 50.59. " Changes, tests and experiments." and presented the 50VG basis for concluding that such a change would not involve an unreviewed safety question.

The SOUG and the staff agreed, in principle, that the implementation of the GIP 2 approach for USI A 46 plants provides safety enhancement in certain aspects, beyond the original licensing basis and that the GIP-2 methodology is an acceptable evaluation method for USI A-46 plants only.

The NRC staff agreed to evaluate the appropriate method of incorporating the GIP-into facility licensing bases. Specifically, the staff will evaluate whether, in addressing the criteria of 10 CFR 50.59, licensees should address

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e Y J. Stolz -2= i the " change to the facility" as an addition of a-new methodology or through the effect of individual: component changes. The staff will also evaluate a)p11 cation of the license amendment process-for incorporation of the GIP into tie' facility licensing bases. The staff's discussion of NARE in USI A-46 plants rece;ved a significant trount of comment from the SOUG representatives. SOUG agreed to provide written comnents on the staff's notes (Attachment 3). As a separate matter. the staff identified two issues regarding cable and conduit raceways to the 50VG. It was aareed that these issues would be discussed separately. The staff and thi SOUG tentatively agreed to a follow-on meeting date of September 4, 1997. . I, Original' signed by Daniel H. Dorman. Lead Project fianager 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 M?R Associates. Inc. 320 King Street Alexandria. Virginia 22314 Mr. R. Kassawara. EPRI Program Manager 3412 Hillview Avenue P. O. Box 10412 Palo Alto, CA 94304 DISTRIBUTION - See next p\\oonumsovouro.sou age DOCUMENT NAME: G: T2 sessive e espy of tNo doeussent biasete in t%e ben:

• C* = Copy without ettschment/ enclosure
• E+ = Copy with attee(ment /enclosugg "N* = No copy 0FFICE P0l*3/PM_ h l

POI 3/LA J [/), d EMES Q m.. I D/ POI 4 l IIANE 00erenpri UO TCtark V8 V RWesemen NW JStolz N DATE 11/@/97 11/l@/97 11/tQ /97 11/ //f /97 0FFICIAL RECORD OUPY { ll

.f y ~ ry: DISTRIBUTION FOR MEETING SUMARY WITH SEISO C OUALIFICATION UTILITY GROUP i PDI-3 RF OGC. 'ACRS E-Mail S. Collins /FMiraglia (SJC1) (FJM) -R. Zimmerman (RPZ) B. Boger (BAB2 R. Eaton (RBE1 D. Dorman (DHO) T. Clark (TLCl) .D. Ross (SLM3) R. Wessman (RWH) G. Bagchi (GXB1) K. Manoly (KAM) P. Y. Chen (PYC) R. Rothman (RLR) G. Lainas (CCL) S. Hou (SNH) T. Le (NBL) E. McKenna (EMM) S. Kim (SBK) A. Lee (AJL) J. Wu J. 'loore (JEM) C. Marco (CLM)- G. Mizuno (GSM)- B. McCabe (BCM) C. Hehl, RI-(CWH) Il I na+ X 17b + l 3 6

l,. LIST OF ATTENDEES-MEETING WITH REPRESENTATIVES OF THE. SEISMIC 00ALIFICATION UTILITY GRnUP ROCKVILLE. MARYLAND { AUGUST 14. 1997-NRC Office of iniclear Reactor Reculation Gus Lainas; Dick Wessman -Goutam Bagchi-John F. Stolz-Kamal Manoly Robert Rothman Pei-Ying Chen Dan Dorman -Shou nien Hou l Sang Bo Kim Tommy Le-Arnold Lee Eileen McKenna -John Wu i >RC Office of-the General Counsel ianice Moore Geary S. Mizuno Catherine-Marco __ Commonwealth Edison Winston & Strawn Neil P. Smith Malcolm Philips MPR Associates Nuclear Enerov Institute William R. Schmidt John Butler-David A. Freed Doug Walters Richard Starck TVA _ Southern Comoany Services. Inc. Richard Cutsinger Donald P. Moore Duke Power Comoany -Omaha Public Power District -James E. Thomas Joseph Mathew IQE Southern Nuclear Oceratina Comoany )aul Baughman Deanna McCombs Greg Hardy Jeff Branum NUS Information Services SERCH Licensino/Bechtel Jerry Dozler Altheia Wyche EECQ Nebraska Public Power District George Rombold-David Nelson Madsen .GPU Nuclear Ken Whitmore -Yosh Nagai

y m = i E m,+ -, m.. .~c-,= w- -~ SQUG ProgramforResolution of USIA-46 and Maintenance ofSeismic Adequacy Presentation to USNRC l August 14,1997 1

AgendaforNRC/SQUGMeeting ~ August 14,1997 - White Flint, MD

1. History of USl A-46 program

• Process used to develop program

+ Legalframework

2. Status of utility implementation of A-46 program l

3. Discussion of issues

• Closure of USl A-46 program
• Continued use of GIP (50.59 process)
• Cable tray issue

4.. Proposed methods for resolution

5. Agenda for 9/4/97 executive-level meeting.

2 g g

.u Meeting Objectives . n. = - Determine an acceptable closure to the USI A-46 Program . Reinforce use of GIP for new and replacement equipment (NARE) l 3 .~

4 -4 i l History of USIA-46 and SQUG Resolution , - _ ~.... = l USl A-46 initiated by NRC in 1981 because of concerns j with seismic qualification (SO) licensing bases of older i operating plants (pre-lEEE 344-75). i Seismic licensing bases of A-46 plants vary widely frorn only minimal requirements to 344-71. i Use of earthquake experience data, augmented by generic test data, analysis and plant walkdowns, l proposed by SQUG, was endorsed by LLNL (NUREG l l CR-3017) and adopted.by NRC (GL 87-02). t 4 i.'

Development ofSQUGMethodologi -=n--,-=.-.,= The basic elements of the SQUG methodology were developed and accepted over the period from 1982 to 1987.

• A panel of five acknowledged seismic experts (SSRAP) was selected and concurred in by NRC to provide independent expert review of a new and l

different methodology. Technical bases for all elements of the process were reviewed and accepted by SSRAP, NRC staff and-NRC consultants. 9

Development ofSQUG Methodology j (Cont'dj Development of the GIP process occurred over the l period from 1987 to 1992. I i Two trial plant reviews were perfor med with NRC participation. Three NRC SERs were issued approving the process. i Technical review meetings were held among the NRC staff, SSRAP, SQUG and NRC technical experts over a 10 year period. I Three training classes developed and used to train over 850 engineers l'. e i.. j 4

The Scope of the GIP ..__,m~..=- Selection of safe shutdown equipment Seismic capacity vs. demand assessment based on Documented earthquake experience data Test data Real seismic vulnerabilities (caveats) Plant walkdowns Anchorage inspection, analysis and acceptance criteria interaction guidelines + Analysis methods and criteria for tanks and HXs Relay criteria System functional analysis Test data Experience with low ruggedness relays Raceway criteria Earthquake Experience & Test Data Analysis Inspection New methodology / procedures forseismic verification of equipment which are 7 different than conventional methods

i l UtilitjImplementation of the USIA-46 i Program l

• Total expenditures by the Industry to date: 883 to l

- S173 million from: l

• Approximately S15 million (~ S500 K per member) for l

developing the GIP and obtaining NRC acceptance. i 4 l

• Additional $8 million (~ S200 K per member) for

[ conducting training, conducting workshops, and i providing an information clearinghouse for members. l l i

• Additional S60 to $150.million (estimated $1 million to

$2.5 million per unit) to implement GIP by SQUG utilities. s m' m m',

Utility Implementation of the USIA-46 Program (Cont'd) . = = - Most plants have submitted their USI A-46 program Summary Reports. Many plan to implement the option of continued maintenance of seismic adequacy using the GIP method in the future as approved by SSER #2. l l

4 Lessons Leamed From USIA-46 Reviews an- ,_ -, -:,n = Category of Outliers identified by GIP

1. Anchorageinstallation Walkdown

2. Seismic interaction of equipment and Walkdown housekeeping issues i

3. Seismic interaction which could cause Walkdown relay chatter

4. Relay' chatter where capacity GERS based on tests

< demand

5. Low ruggedness relays.

" Bad actor" relay list

6. Other maintenance issues Walkdown 10

l l Conclusions to Date rr- .um m m m u m, w r:n m e m er-r The GIP methodology is new and different l

• It was thoroughly reviewed and accepted, at significant expense i

The program has been effective in finding real j problems and improving seismic safety i

• The utilities need this method for the future i

l 11 me m

i i Regulatory Basis for and Acceptance of the l GIPMethod i NRC conclusions of SSER #2 establish that the GIP-2 j method, taken as a whole, meets the standard of l adequate protection of the health and safety of the public regarding seismic adequacy. 6 Generic Letter 87-02 (Feb.1987) er.dorsed SQUG l l methodology based on: i l ~

• Technical review in NUREG 1030 and l

Regulatory analysis in NUREG 1211 l 12

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Regulatory Basis for and Acceptance of the GIPMethod (Cont'd) SSER #2 (May 1992) found that the GIP-2 ... approach for USi A-46 plants provides safety enhancements, in certain aspects, beyond the original licensing basis. Therefore, GIP-2 an acceptable evaluation method, for USl A-46 plants only, to verify the seismic adequacy of the safe shutdown i 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 100." l 1 SSER #2 found the criteria and procedures in GlP-2 an acceptable evaluation method ior verifying the seismic adequacy of future modifications and for new and replacement equipment. 13

Regulatory Basis for and Acceptance of the GIPMethodology (Cont'd) ... the staff agrees that it is impractical and inconsistent with the USI A-46 philosophy to require that new equipment shall meet current seismic qualification requirements, whereas the seismic l adequacy of all other safe shutdown eauipment... is verified through the USl A-46 procedures. Therefore, the criteria and procedures described herein are determined to be an acceptable method for verifying the seismic adequacy of new equipment in' USl A-46 plants" [SSER #2 pp. 8-9], emphasis added 14 \\ A ~~

l Regulatory Basis for and Acceptance of the GIP Method (Cont'db L i NUREG-1211 (page 16) explicitly limits the scope of 1 the backfit to the performance of a seismic adequacy TOViOW. l l t [ "The backfit analysis which is presented in the j following paragraphs presents justification for l performing the seismic adequacy review. Backfit analysis for correction of any deficiency will be l performed on a case by case basis if required following completion of the review." 4 i 15

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~. Licensee Regulatory Responsibility Under Generic Letter 87-02 ,. = Neither GL 87-02 nor implementation of the GIP change the seismic licensing basis; the A-46 review is a 50.54(f) request for information; a " snapshot in time." SQUG members are under no obligation to resolve outliers identified during the USl A-46 evaluation, other than voluntary commitments or outliers which deviate from the plant licensing basis. Other than as required by the existing licensing basis, SQUG members have no obligation to maintain equipment (existing or NARE) to the GlP or current standards. i Therefore, the existing seismic licensing bases for each plant a - will continue to govern. 16'

4 - = . r ~ l Options to Obtain Closure of USIA-46 SQUG and NRC agree on process for adopting GIP ) method and utilities implement the GlP methodology l for NARE as an option and change their licensing j bases accordingly i j Without such an agreement: SQUG utilities continue to rely on their existing licensing l bases,or

• NRC staffimposes new criteria on SQUG plants under 10 L

CFR 50.109 via backfit l i 17

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s l l Recommended Closure Process Consistent with SSER #2, licensees may adopt GIP l provided a 50.59 evaluation is cont ucted. As a new and different methodology, the GIP method should be evaluated under 50.59 as a complete, j integrated program. i i I 1 P 18 i*

l Adoption of GIP Via 50.59 Should Not Resultin a USQ _.---. m m_mm..- l Methodology reviewed by and accepted by NRC SER for l A-46 and for NARE Methodology meets applicable regulations l A NRC and SQUG agree GIP ~1ethod provides a safety \\ 7 l N enhancement over existing A-46 licensing bases Walkdown results demonstrate safety improvement is achieved New, different methodologies are not amenable to " element-by-element" margin comparison - must evaluate total program as a whole This is consistent with industry practice i i .19-4

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(. - NRC Stated Pose. ion on Use of GIP for NARE NRC

• encouraged
• future use of GIP for NARE in GL 87-02 (Feb. 87):
• If a utility replaces components for any reason each replacement (assembly, subassembly, device) must be verified for seismic adequacy either by using A46 criteria and methods or, as an option, qualdying by current licensing criteria.* This provision also applies to future modification or replacements. " Component
• in this context means equipment and assemblies (including anchorages and supports)-such as pumps and motor control centers-and subassemblies and devices-such as motors and relays that are part of assemblies.*
• It is no,ed that methods to be used for future seismic qualification cannot be imposed by a Generic Letter.

NRC Stated Position on Use of GIP for NARE (cont'd) In SSER-2 (May,1992), the NRC confirmed their acceptance of the GIP method for new and replacement equipment *with the provisions that the seismic evaluations are performed in a systematic and controlled manner so a3 to ensure that new or replacement items of equipment are property represented in the earthquake experience or generic testing equipment classes, and that applicable caveats are met. In particular, each new or replacement item of equipment and parts must be evaluated for any design changes that could reduce its seismic capacity from that reflected by the earthquake experience or generic testing equipment classes, and these evaluations must be documented.' 5 e .n.-__.____-__-____-_____-_-_____---

e. e_,. ; *- I August 14,1997 Future Modifications and New and Replacement. Equinment in USI A-46 Plants - 1.' The in-structure response spectra, submitted by the licensee and approved by the staff in the licensee's 120-day response, are acceptable for future modifications and new and replacement equipment within the USI A-46 scope or same classes of equipment outside USl A-46 scope, ll. New and Replacement Equipment Within USl A-46 Scope (Safe Shutdown Path) If it is identical to the equipment originally installed in the plant, a. the criteria and procedure in GIP-2 supplemented by the staff's SSER No. 2 (May 22,1992) apply. b. If it is not identical to the equipment originally installed in the plant, the licensee may, on a case-by-case basis, establish and document in plant records the equipment's similarity to the installed equipment. The definition of similarity must include the following two elements: (1) excitation similarity, and (2) dynamic characteristics and response similarity, including functional operability. After the similarity is established, then the criteria and procedure in GIP-2 supplemented by the staff's SSER No. 2 apply. If it is not identical to the equipment originally installed in the c. plant and the similarity can not be established, the licensee must follow its FSAR commitments (i.e., IEEE 344-1971 or 1975), or revise the FSAR to commit to other approaches acceptable to the staff, if R.G.1.100, Revision 2, is selected, the use of experience approach for equipment qualification must be on a case-by-case (i.c.., plant-specific and equipment-specific) basis. The use of certain criteria in GIP-2 is acceptable if the input parameters and provisions of GIP-2 are revised to be consistent with those in the V FSAR.

..? o 1 \\ Ill. New and Replacement Equipment Of Same Classes As USl A-46 Equipment But Outside USI A-46 Scope Perform seismic adequacy walkdown verification using the criteria and procedure in GIP-2 supplemented by the staffs SSER No.2, and follow the guidelines established in items ll.a, ll.b and ll.c above. IV. Balance Of Safety-Related Equipment Not included in items II & Ill Above Follow commitments in the FSAR. GIP-2 is not applicable. 9 s ______m.__ - - - -}}