ML20236Q799

Comments on Proposed Rev 2 to Reg Guide 1.100 Re Seismic Qualification of Electrical & Mechanical Equipment for Nuclear Power Plants

ML20236Q799
Person / Time
Site:	Point Beach
Issue date:	11/09/1987
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-87-111, FRN-52FR32980, REF-GTECI-A-46, REF-GTECI-SC, RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-01.100, RTR-REGGD-1.100, TASK-A-46, TASK-OR 52FR32980-00005, 52FR32980-5, GL-87-02, GL-87-2, VPNPD-87-486, NUDOCS 8711200293
Download: ML20236Q799 (2)

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Office of Administration and Resources Management US NUCLEAR REGULATORY COMMISSION Washington, DC 20555 Gentlemen:

COMMENTS ON PROPOSED REVISION 2 TO REGULATORY GUIDE 1.100, SEISMIC QUALIFICATION OF ELECTRICAL AND MECHANICAL EQUIPMENT FOR NUCLEAR POWER PLANTS In response to your letter of August 14, 1987, which forwarded proposed Revision-2 of the subject regulatory guide, the following comments.are offered:

1. The subject regulatory guide requires case by case approval for qualification of equipment, 'using earthquake experience. This is in' conflict with NRC Generic Letter 87-02, which permits generic qualification of_ equipment based on data obtained from earthquake sites,-using a. methodology developed by the Seismic Qualification Utility Group (SQUG). The regulatory

. guide should endorse the SQUG methodology being reviewed by the NRC Staff.

2. The proposed Regulatory Guide 1.100 applies IEEE-344-1987 to pipe supports, snubbers, restraints and hangers.

This proposed qualification method is inappropriate for these ,

devices and is not consistent with NUREG-0800, Standard Review J Plan, Sections 3.9.2, 3.9.3, 3.9.4 and 3.10. The ASME, ANSI and AISC codes have been demonstrated by experience to adequately address these components. For example, a hydraulic snubber's lockup velocity, bleed velocity and displacement prior to lockup are important for it to perform its design function during an earthquake. These variables are not addressed by the proposed regulatory guide. The regulatory guide should be revised to remove mechanical equipment from the scope.

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NRC, Rules & Records Div.

November 9, 1987 Page 2

3. IEEE-344-1987 requires justification of similarity of each equipment item to be seismically qualified by experience.

SQUG experience in resolution of Unresolved Safety Issue A-46 indicates that a broad and diverse data base applicable to generic types of equipment is the preferred approach. The regulatory guide should explicitly endorse the SQUG methodology now being reviewed by the NRC Staff for twenty classes of equipment.

We will be pleased to discuss these comments with you.

Very truly yours,

,v f l'wf'y C. W.

Vice / President Fay Nuclear Power l

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