ML20217M610
| ML20217M610 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/30/1998 |
| From: | Dromerick A NRC (Affiliation Not Assigned) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR TAC-M69435, TAC-M69436, NUDOCS 9805050067 | |
| Download: ML20217M610 (4) | |
Text
4 April 30, 1998 Mr. Charles H. Cruse
. Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant.
1650 Ca! vert Clifft Parkway Lusby, MD 20657
^
SUBJECT:
BALTIMORE GAS AND ELNCTRIC'S (BGEs) RESPONSE TO REQUEST FOR p
. ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY
' ISSUE A-46, CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 (TAC NOS. M69435 AND,M69436)f
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Dear Mr. Cruse:
in your letter of March 23,1998, regarding our letter of December 19,1997, requesting additional informatiori'concoming " Resolution of Unresolved Safety Iss.ue" A-46, Calvert Cliffs Nuclear Power Plant, Unit Nos.1 and 2, BGE expressed concem that a number of questions are related
. to aspects of the A-46 program that had been previously approved.
The NRC staff has generically responded to these con'coms in a letter to Mr. Neil Smith,
- Chairman, Seismic Qualification Utility Group, clo MPR Associates dated March 27,1998. For -
your information, our response to Mr. Smith is enclosed.
If you have any questions regarding this matter, please do not hesitate to contact me at (301) 415-3473.
Sincerely, 1
Original Signed by:
Alexander W. Dromerick, Senior Project Manager Project Directorate 1-1 Division of Reactor Projects - t/11 Office of Nuclear Reactor Regulation
- Docket Nos. 50-317 '.
and 50-318
Enclosure:
As stated cc w/ encl: See next page DISTRIBUTION:.
M#llW S. Bajwa.
R. Wessman -
PUBLIC S. Little ACRS g
PDl-1 R/F
- A. Dromerick C. Hehl, Region I i l J. Zwolinski OGC DOCUMENT NAME: G:\\CC1-2\\CM69435.RAI o\\
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. attachment / enclosure "E" = Copy with attachment / enclosure "N" = No coay N
OFFICE PM:PDI-1 lE LA: POI-1 R l
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April 30, 1998
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Mr. Charies H. Cruse i
Vice President - Nuclear Energy Baltimore Gas and Electric Company
(
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 i
SUBJECT:
BALTIMORE GAS AND ELECTRIC'S (BGEs) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY ISSUE A-46, CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 (TAC NOS. M69435 AND M69436)
Dear Mr. Cruse:
In your letter of March 23,1998, regarding our letter of December 19,1997, requesting additional information conceming " Resolution of Unresolved Safety issue" A-46, Calvert Cliffs Nuclear Power Plant, Unit Nos.1 and 2, BGE expressed concem that a number of questions are related to aspects of the A-46 program that had been previously approved.
l The NRC staff has generically responded to these concems in a letter to Mr. Neil Smith, Chairman, Seismic Qualification Utility Group, clo MPR Associates dated March 27,' 1998. For your information, our response to Mr. Smith is enclosed.
If you have any questions regarding this matter, please do not hesitate to contact me at (301) 415-3473.
Sincerely, Original Signed by:
Alexander W. Dromerick, Senior Project Manager Project Directorate 1-1 Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
Enclosure:
As stated cc w/ encl: See next page DISTRIBUTION:
Docket File S. Bajwa R. Wessman PUBLIC S. Little ACRS PDI-1 R/F A.' Dromerick C. Hehl, Region 1 J. Zwolinski OGC DOCUMENT NAME: G:\\CC1-2\\CM69435.RAI To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy N
OFFICE IPM:PDI 1 lE LA:PDI 1 f\\Q, l
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DE:EMEBj. /
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Official Record Copy 1
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'a UNITED STATES g-g NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D.C. 20666-0001
- % 4 **,o April 30, 1998
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Mr. Charles H. Cruse Vice President-Nuclear Energy l
Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant l
1650 Calvert Cliffs Parkway Lusby, MD 20657
SUBJECT:
BALTIMORE GAS AND ELECTRIC'S (BGEs) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON THE RESOLUTION OF UNRESOLVED SAFETY ISSUE A-46, CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 (TAC NOS. M69435 AND M69436)
Dear Mr. Cruse:
In your letter of March 23,1998, regarding our letter of December 19,1997, requesting additional information conceming " Resolution of Unresolved Safety issue" A-46, Calvert Cliffs Nuclear Power Plant, Unit Nos.1 and 2, BGE expressed concem that a number of questions are related to aspects of the A-46 program that had been previously approved.
The NRC staff has generically responded to these concems in a letter to Mr. Neil Smith, Chairman, Seismic Qualification Utility Group, c/o MPR Associates dated March 27,1998. For your information, our response to Mr. Smith is enclosed.
If you have any questions regarding this matter, please do not hesitate to contact me at (301) 415-3473.
Sincerely, Alexander W. Dromerick, Senior Project Manager Project Directorate 1-1 Division of Reactor Projects - t/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 i
Enclosure:
As stated cc w/ encl: See next page i
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~ Mr. Charles H. Cruse Baltimore Gas & Electric Company Calvert Cliffs PJclear Power Plant cc:
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President Mr. Joseph H. Walter, Cnief Engineer i
Calvert County Board of Public Service Commission of j
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. Commissioners Maryland I
175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire l
Baltimoce Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre l
Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631
' Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Bimie, Esquire i
2300 N Street, NW Co-Director l
Washington, DC 20037 Maryland Safe Energy Coalition i
P.O. Box 33111 l
- Mr. Thomas N. Pritchett, Director Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell
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1650 Calvert Cliffs Parkway NRC Technical Training Center 1
Lusby, MD 20cs7-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory l
Commission P O. Box 287 Gt. Leonard, MD 20685 Mr. Richard 1. McLean, Manager Nuclear Programs Power Piat Research Program Mary!an) Dept. of Natural Resources Tewes State OW.e Building, B3 Annapolis, MD 21401
' Regiona! Administrator, Region i U.S. Nuclea Regulatory Commission 475 A!!endt!c Poeti King of Prussia, PA 19406 1
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NUCLEAR REGULATORY COMMIS810N
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March 27, 1998 Mr. Neil Smith, Chairman Seismic Qualification Utility Group c'o MPR Associates,Inc.
320 King Street Alexandria, VA 22314
Dear Mr. Smith:
This is in respense to the Seismic Qualification Utility Group (SQUG) letters of J.anuary 22 and 26,1998, regarding the SQUG concems with NRC's recently issued requests for additional.
information (RAls) to SQUG members and the Nuclear Regulatory Commission's (NRC) approach to the Unresolved Safety issue (USI) A-46 (Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors) closure process. This is also a follow up to a telephone conversation held on March 19,1998, between Mr. Wessman and Mr.
Manoly of the NRC and yourself and Mr. John Butler of the Nuclear Energy Institute (NEI).
As you are aware, except for Millstone Unit 1, all the licensee summary reports, documenting licensee actions to address USl A-46 have been submitted and are under staff revie staffs review is to allow NRC to make an assessment oflicensee USl A 46 actions for i
consistency with SQUG's Generic implementation Procedure Revision 2 (GIP 2) and the staffs Supplemental Safety Evaluation Report (SSER) of GlP-2, issued on May 22,1992, with Generic i
Letter (GL) 87-02, Supplement 1. Consistent with GL 87-02, the staff intends to issue a site-specific SER for each USI A 46 facility. In the course of the staffs review, RAls have been issued to SQUG memberlicensees. The staffs focus in these RAls has been to clarify site j
, specific situations or individuallicensee actions addressing USl A-46; howoor, as detailed in your January 26,1998, letter, SQUG believes, in four generic areas, "the st/* is using the RAI i
process to re review the criteria and guidelines in the GIP which have already been accepted by the NRC in Supplemental Safety Evaluation Report No. 2 (SSER No. 2)." The staff does not view the RAI process as a re review of the GlP, and our response to each of SQUG's four generic issues is provided in the enclosure to this letter.
The NRC plans to move expeditiously towarus closure of the USi A-46 issue and has committed substantial resources to this effor1. Each plant specific SER will provide an assessment of the licensee's submittalin response to the NRC's request for informatier, under the provisions of 10 CFR 50.54(fi, made as part of GL 87 02. Each SER will address the following:
- description of the ed.,mittalwithin the A-46 scope
- areas where, in the staffs judgement, the licensee met GIP-2 and the staffs May 22,1992 SSER
- areas where, in the stafra judgement, the licensee did not fully meet GIP-2 and the staffs May22,1992 SSER
- whether or not the licensee has completed outlier disposition or provided a schedule for outlier disposition
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- whether or not the licensee identified any operability concems, and
- actions the licensee would have to take to incorpo' rate GIP-2 into the licensing basis for the facility.
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- Where the staff has determined that the licensee's implementation of USl A 46 has met the provisions of 10 CFR 50.54(f), the SER will conclude that the licensee's USI A-46 implemen program has, in general, met the purpose and intent of the criteria in GIP-2 and the staff's generic SSER No. 2, and that there is sufficient basis to close USl A-46 at that facility, in thes SERs, the staff expects to be able to conclude that the licensee's already completed actions a commitments to complete the disposition of remaining outliers will result in safety enhancem in certain aspects, that are beyond the originallicensing basis of the facility.
USI A-46 SERs for the first group of plants reviewed by the staff should be issued within the ne 12 months. The staff expects to move expeditiously with the A-46 reviews with a target that most reviews will be complete by mid-1999.
Please contact Richard H. Wessman, Chief of the Mechanical Engineering Branch, at l
(301) 415 3288, if you have any questions.
Sincerely, a
h n F. Stolz, Director gy Project Directorate 12 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation
Enclosure:
NRC Staff Response c w/ encl: Mr. R. Kassawara, EPRI Mr. John Butler Electric Power Research instituto Nuclear Energy institute 3412 Hillview Avenue Suite 400 P.O. Box 10412 1776 i Street, NW Palo Alto, CA 94304 Washington, DC 20006 3708
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STAFF RESPONSE TO SEISMIC QUALIFICATION UTILITY GROUP CO
- 1. Use of Ground Resoonse Sometra for Estimatino Seismic Demand The staffs RAls to SQUG members have stated the staffs concem with the lic 4
selection of demand spectra, have pointed out the cautions a chooses to apply Method "A" of the GIP, and (in some cases)pplicable in the event have requested the licensee to justify its selection of the demand spectra. In cases where a licensee elected to use differe spectra than that provided by the licensee in its 120-day response to GL 87 02, Supplement No.1, the staff has requested the licenses to provide a basis for their decision. SQUG has taken the position that (1) a licenses submittal of the in structure response spectrum (IR its 120-day response did not imply a commitment to use the IRS exclusive of Method Method A is an attemative to Method 8 for elevations up to 40 feet from plant-grade le there is no requirement to use the more conservative of Method A or Method B, and (4) th GlP 2 cautionary paragraph (Pg 416 of GIP 2) is only to aler1 the seismic review team not to use Method A for atypical nuclear power plant structures.
The staff does not agree with SQUG, for reasons previoesty provided in our letter of December 2,1997. The staff expects that the licensee must have a basis for the selection
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of a demand spectra and that the basis should include consideration of site specific factors such as soll, the plant structure, the equipment location and natural frequency, and the j
availability of an IRS. Site-specific situations cannot be disposed of solely on the basis of generic arguments. The justification for the inclusion of Method A in the GlP was that, for stiff structures such as those used in nuclear power plants, the amplification of the ground response spectrum up to the elevations of about 40 feet above plant grade level would be approximstely 1.5 and that the original design bases IRS are overty conservative. We have found in our A-46 summary reporneviews that the IRS developed specifically for this program using the latest modeling and analytical techniques can indicate amplifications greater than 1.5 at elevations below 40 feet. However, to move forward on the USI A-46 closure process, the staff intends to proceed as follows:
The staff is reviewing the use of Method A on a case-by case basis and where a licensee provides an appropriate justification, its use will be acceptable.
i
'Where a licensee's summary report indicates the use of a demand spectrum other than the licensing basis or that described in the 120-day response, the staff will continue to seek additionalinformation regarding the methodology employed for developing the new spectrum, if the basis for the methodology was not provided.
1 Where a licensee's summary report indicates the selection of a different demand spectrum than that provided in the 120-day response, and sufficient information is provided regarding the methodology employed for developing the spectrum, the staff will not seek additional information on this issue.
If, in the staffs judgement, the licensee's use of Method A is not shown'to be adequetely justified, the staff will document this finding in the USl A-46 SER.
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ENCf.OSURE
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' 2.' Lateral Load Duetility svaluation of r'=hu Travn On a site-specific basis, the staff has questioned the licensee's application of the GIP methodology with regard to the assumption of ductility of cable tray and raceway su The staff has questioned the basis for performing a limited analytical review and has various plant-specific questions regarding the evaluation of cable trays. SQUG believes certain of the staff questions are generic in nature and provided with its January 2 letter, additional material in support of the GIP 2 guidelines for the verification g
seismic adequacy.
The staff reviewed and accepted the approach provided in GIP-2. The staff concem necessaril licensees.y with the GIP-2 concept, but rather with the way it has been employed by som Consequently, licensees have been asked to explain their bases for determinations made during plant walk downs that cable tray and raceway supposts a ductile. The staff accepts SQUG's position that cable tray and raceway supports in base are inherently rugged because they generally behaved in a ductile manne for A-46 plants with cable tray or raceway configurations which are not in the experi database or those with obviously rigid support configurations the staff will continue to ask plant specific questions regarding a licensee's basis for their ductility determinations. Th plant specific aspects cannot be addressed generically,
- 3. Seismic Adeousev of Relav2 Mounted on Diesel Generators and Air Comor At one facility (Point Beach) the staff requested the licensee to justify its basis for r operability fcc certain relays mounted in control cabinets anchored on a common skid with a diesel generatcr or air compressor. SQUG assumed this was a generic issue and e concem that the staff was taking issue with the provision to accept relays mounted on equipment such as diesel generators and air compressors.
This original question was focueed at relays in control cabinets anchored to a common sk with the diesel generator or air compressor, as opposed to relays mounted directly on th equipment. This issue has not been identified at any other facility and the Point Beach
' licensee has agreed in its response of July 31,19g7, to reexamine the staff's original concem. The staff believes this issue is closed.
- 4. Justification for Schedules to Resolve GlP Ou":ra Staff RAls have asked licensees about their schedules to rusolve indeterm have inquired iflicensees have addressed possible operability issues. SQUG stated in its letter of January 26,1998, that licensees are committed to perform a seismic adequ review end report the results to the NRC in response to the NRC's 50.54(f) information request. IsQUG reminds NRC that, as stated in NUREG-1211 (Regulatory Analysis for Resolution of Unresolved Safety issue A-46, Seismic Qualification of Equipnient in Plants, February 1987) a backfit analysis for the correc6on of any deficiency will be perfo on a case-by-case basis if required.
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3-The staff agrees with SQUG that licensees would not have to correct A46 outlier there are situations where the plant does not meet the licensing basis. Licensees expected to repod and address these situations under existing regulaths. The staff's have been a consequence of uncertainty whether a licenses has addressed a issues as part of the walkdown process and that the during routine plant operations When such issues are identified, the staff continues expect that licensees will follow appropriate reporting and corrective action processes. It should be noted however, since some I;censees have indicated that they plan o
the GIP in their Final Safety Analysis Repost (FSAR), it is important that, forthese l all relevant outliers be addressed prior to proceeding with the FSAR change.
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