ML17262B140
| ML17262B140 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/12/1993 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, GL-88-20, TAC-M69449, NUDOCS 9301220007 | |
| Download: ML17262B140 (8) | |
Text
ACCEI E ED DOCUMENT DIS UTION SYSTEM REGUL RY INFORMATION DISTRIBUT SYSTEM (RIDS)
ACCESSION RBR.':9301220007 DOC.DATE: 93/01/12 NOTARIZED:
NO DOCKET FACIL:5K~244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSONiA.R.
Project Directorate I-3
SUBJECT:
Submits results of review of NRC evaluation of util 920921 response to GL 87-02,Suppl 1,
"SQUG Resolution of USI A-46" a
GL 88-20,Suppl 4 re seismic events. Requests that NRC promptly respond to resolution of GL 88-20,Suppl 4.
DISTRIBUTION CODE:
A025D COPIES RECEIVED:LTR g ENCL P
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TITLE: Seismic Qualification of Equipment in Operating Plants A-46 D
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
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/IIIIIIIIIIII'OCHESTER GAS AND ELECTRIC CORPORATION o
89 EAST AVENUE, ROCHESTER N. Y. 14649.0001 ROBERT C MECREDY Vice President Clnne Nudeer Production January 12, 1993 TELEPHONE AREACODE 7t B 546 2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen R. Johnson Project Directorate I-3 Washington, D.C.
20555
Subject:
Generic Letter 87-02, Supplement 1
(SQUG Resolution of USI A-46) and Generic Letter 88-20, Supplement 4 (Seismic Events)
R. E. Ginna Nuclear Power Plant Docket No. 50-244
Reference:
(a) Letter from A.R. Johnsoni NRCP to R C Mecredy(
RG&EP
Subject:
Evaluation of Ginna Nuclear Power Plant, 120-Day
Response
to Supplement No.
1 to Generic Letter 87-02 (TAC No.
M69449),
dated November 30 P 1992.
(b) Letter from R.C. Mecredy, RG&E, to A.R. Johnson, NRCI
Subject:
Response
to Generic Letter 87-02, Supplement (SQUG Resolution of USI A-46) and Generic Letter 88-20, Supplement 4 (Seismic Events), dated September 21, 1992.
(c) Letter from N.P. Smith, SQUG, to J.G. Partlow,
- NRC,
Subject:
SQUG Position on GIP Implementation
- Guidance, dated December 23, 1992.
(d) Letter from J.G. Partlow, NRC, to N.P. Smith, SQUGP NRC Response to Seismic Qualification Utility Group (SQUG), dated October 2, 1992.
(e) Letter from D.M. Crutchfield, NRC, to J.E.
Maierg RG&E, SEP Safety Topics III 6, Seismic Design Consideration and III-11, Component. Integri ty Ginna Nuclear Power Plant, dated January. 29, '1982.
(f) Letter from D.M. Crutchfield, NRC, to J.E.
- Maier, RG&E, Status of SEP Topics III-1, III-6, III-8.A, and V-7 R.E.
Ginna, dated February 17, 1982.
Dear Mr. Johnson:
Rochester Gas and Electric has completed its review of the NRC's evaluation (Reference a) of our response (Reference b) to Generic Letter 87-02, Supplement 1 and Generic Letter 88-20, Supplement 4
(Seismic Events).
The NRC Staff's evaluation accepted, in generali RG&E's
- response, but.
based their acceptance in several areas on interpretations by the staff.
RG&E would like to provide additional clarification on several of these topics.
9301220007 930112'DR ADQCKc05000244 pros 5 r go@
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Pago 2 of 3 NRG Evaluation of Response to GL 87-02, Supp.
1, and GL 88-20, Supp.
4 (Seismic)
C~
First, the NRC Staff stated that it was,unclear whether RG&E would fully implement all provisions of the 'guidance sections of the Generic Implementation Procedure (GIP) and, if not, questioned the process that would be used for notifying the Staff of deviations.
RG&E's actions will be in accordance with Part I, Section 1.3 of the GIP, Revision 2 (as corrected February 14, 1992), which was accepted by the Staff in its SSER No.
2 on the GIP, dated May 22, 1992.
This position was also forwarded to the NRC separately by the SQUG (Reference c).
- Second, the NRC Staff's evaluation requested that RG&E use Enclosure 2 of their evaluation (Reference d) instead of the August 21, 1992 SQUG letter as guidance for implementing GIP-2.
After review of this NRC letter to
- SQUG, RG&E agrees to observe the interpretations and positions which are provided.
Third, in their evaluation, the staff discussed a
concern with respect to RG&E's revising the licensing basis of Ginna Station to use the GIP methodology for verifying the seismic adequacy of applicable electrical and mechanical equipment prior to a plant specific SER resolving USI A-46.
This concern was based on the fact that RG&E did not to commit to the guidance portions of the GIP.
However, since RG&E will notify the NRC of any deviations from the guidance sections consistent with an NRC approved document (i.e.,
GIP), we maintain that it is acceptable to revise the licensing basis using the evaluation process within 10 CFR 50.59 prior to receipt of a plant-specific SER related to USI A-46.
- Fourth, the staff's evaluation accepted the use of the options provided in the GIP for defining seismic demand and in-structure response spectra (IRS) since Ginna was a Category 2 plant.
- However, the staff added that "if more than one set of IRS appear in the licensing basis documents, the more conservative set. of spectra must be used to qualify for the definition of 'conservative, design'RS for the resolution of USI A-46 issues at Ginna".
RG&E does not agree with this position.
There are several IRS contained within licensing basis documents for Ginna Station as a result of previous industry bulletins and programs.
As an alternative to performing an extensive review of these
- IRS, RG&E plans to use the spectra developed by the Seismic Piping Upgrade Program (Engineering Work'equest No. 2512),
which was initiated. as a result of IE Bulletins 79.-02 and 79-14, and the Systematic Evaluation Program (SEP).
The Seismic Upgrade Program evaluated safety-related piping against. current criteria (e.g.,
R.G.
1.60, R.G. 1.61, Standard Review Plan) and was reviewed and accepted by the NRC (References e and f).
The IRS developed by EWR No.
2512 have been subsequently used at Ginna Station for plant modifications.
RG&E therefore. maintains that the IRS developed by EWR No. 2512 meet the definition of "conservative design" spectra as provided in Section 4.2.4 of the GIP and associated SSER No. 2.
RG&E willnotify the NRC if any alternative IRS are used in support of the USI A-46 resolution.
1J
- al l.
t E
NRC Evaluation of Response to CL 87-02, Supp.
1, and CL 88-20, Supp.
4 (Seismic)
Finally, the evaluation by the staff did not address the proposed actions in our response (Reference b) to Generic Letter 88-20, Supplement 4
(Seismic Events).
The approach that we proposed is substantially dependent upon the USI A-46 program for Ginna, and as
- such, may affect the schedule for implementing the GIP if changes are required.
Since RGGE plans to contract outside resources in order to assist in the resolution of USI A-46, and with walkdowns scheduled to begin during the next refueling outage beginning in March of 1993, we request that the NRC promptly respond (within 45 days of receipt of this letter if possible) to the proposed resolution of GL 88-20, Supplement 4 for Ginna Station.
The absence of your response to our proposed approach to GL 88-20, Supplement 4 (Seismic Events) could result in undesirable delays and major adjustments to our resource allocation for future outages.
Very truly yours, X~O Robert C. Mecredy MDF/496 xc:
Mr. Allen R. Johnson (Mail Stop 14D1)
Project Directorate I-3 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
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