ML20199L227

Submits NRC Response to Ltrs, & 22 That Would Outline Staff Position Re Incorporation of GIP Methodology Into A-46 Plant Licensing Basis

ML20199L227
Person / Time
Issue date:	11/26/1997
From:	Stolz J NRC (Affiliation Not Assigned)
To:	Smith N MPR ASSOCIATES, INC., SEISMIC QUALIFICATION UTILITY GROUP
References
NUDOCS 9712010350
Download: ML20199L227 (5)

Text

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Nov mber 26, 1997 1

Mr. Neil Staith, Chairman Seismic Oustification Utility Group c/o MPR Associates, Inc, 320 King Street Alexandria, VA 22314

Dear Mr. Smith:

The Seismic Qualification Utility Group (SOUG) recent}y sent two letters to the U.S. Nuclear Regulatory Commission (NRC).' The first letter, dated October 6, 1997,is_ entitled " Guidelines for Adoption and Use of GIP [ Generic Implementation Procedure) as Licensing Basis for A 46 Plants" and the second letter, dated October 22,1997 is entitlod " Examples of Enhanced Safety Based on the Ov.ra Effect of a Change." Both letters were central to the focus of a public meeting held on October 30,1997, between members of the NRC staff and representatives of the SOUG. At that meeting the staff committed to providing the SOUG with a written response to the two letters that would t.utline the staff's position relative to the incorporation of the GIP methodology into a plant's licensing basis. Enclosed please find the N3C staff's response to the two letters.

Sincerely, i

1 Original signed by

j John F. Stolz, Director h

Project Directorate 12 gh R

ER S G

D, vision of Reactor Projects 1/11 PDR i

Office of Nuclear Reactor Regulation

Enclosure:

NRC Staff Response tj., A'T cc w/ encl: Mr. R. Kassawara, EPRI y

Progran Manager g

3412 Hillview Avenue se" egh'p P

P. O. Box 10412 Palo Alto, CA 94304 y

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NRC STAFF RESPONSE: INCORPORATION OF THE GENERIC IMPLEMENTATION PROCEDURES INTO THE LICENSING BASIS This is in response to two letters the Seismic Qualification Utility Group (SQUG) recently sent to the NRC. The first letter, dated October 6,1997, is entitled " Guidelines for Adoption and Use of GIP as Licensing Basis for A-46 Plants" and the second letter, dated October 22,1997, is entitled 5xamples of Enhanced Safety Based on the Overall Effect of a Change." Both letters were central to the focus of a public meeting held on October 30,1997, behveen members of the NRC staff and representatives of SQUG to discuss SQUG's proposed guidelines for incorporating the Generic Implementation Procedure (GIP) into the licensing basis for USI A-46 plants. This meeting was the third in a series of meetings between the NRC and SQUG on this subject; the first and second meetings were held on August 14, ar i September 4,1997, respectively. (Meeting Summariec have been issued separately.)

The October 6,1997, letter provides the SQUG interpretation of the provisions of GIP-2, as accepted and supplemented by NRC SSER No. 2 (dated May 22,1992), and the requirem9nts of applicable regulations pertainhg to changing a plar,t's licensing basis. The letter provides the SQUG position on the use of the provisions of 10 CFR 50.59 and the licensing amendment process and reflects SQUG% belief that the 50.59 process is the appropriate process to implement the change. The SQUG requests NRC concurrence with the positions stated in the attachment to the October 6,1997 letter. The October 22,1997, letter, provides a surnmary of five examples portrayed by SQUG as illustrating where NRC accepted the use of new methodolonies that improved plant safety on an overall basis. The staff has considered these examples and concluded that they do not address a'l of the issues associated with adopting the GIP as a licensing basis.

During the October 30,1997 nieeung, the NRC staff provided its views on SQUG's October 6, 1997, letter and committed t1 prowde its views in writing. The NRC staff position is provided in this correspondence which constitutes the staff reply te, the October 6,1997, letter.

The staff does not agree with SQUG's positions stated in the October 6,1997, letter regarding the use of the 50.59 process. Neither the staff nor SQUG can draw a genaric conclusion regarding a finding that no unreviewed safety question (USQ) is involved if the gip is adopted into the licensing basis for USI A-46 plants. This determination must be made by individual licensees, consequently the staff does not agree with the approach proposed by SQUG.

The provisions of 10 CFR 50.59 allow licensees the discretion to make changes ta their facilities (or procedures) without prior NRC pproval. Specifically,10 CFR 50.59, in paragraph (a), states that the holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report (SAR), make changes in procedures as described in the SAR, and conduct tests or expeiiments not described in the SAR without prior commission approval unless the proposed change, test, or experiment involves a change to the technics.1 specifications (TS) incorporated in the license, or involves an USQ.

With regard to A-46, the staff provided its position regarding 10 CFR 50.59 in Section 1.2.3 of the May 22,1992 SER. Specifically the staff " recognizes that a licensee may revise its licensing basis in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 (GIP) m0hodology for verifying the seismic adequacy of electrical and mechanical equipment covered Enciosure I

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by the GIP. The staffs approval of the implementation of the GlP does not relieve the licensees from the requirement to address all asoects (emphasis added] of unreviewed safety questions as soecified in 10 CFR 50.59." (The staff notes that SQUG's October 6,1997, letter, did not address this portion of the staff SER).

As stated during the October 30,1997 meeting, and as recognized on page 4 in the staffs GER, "the implementation of the gip-2 approach for USI A-46 plants provides safety enhancement, in certain asoects, [ emphasis added) beyond the originallicensing basis." The primary safety enhancements realized from implementing the USI A 46 resolution via the apolication of GIP-2, are attributed to the walkdown of equipment and associated resolution of identified discrepancies in the safe shutdown path. There are design related aspects in the GIP-2, however, that may not be as conservative as specific licensing basis requirements delineated for the qualification of new equipment in USI A-46 plants. Each licensee is free to conduct an analysis of the applicability of the GIP to the licensing basis in the FSAR using the provisions of 10 CFR 50.59, but the analysis cannot simply conclude that there is no USQ merely on the basis that the GIP methodology, taken as a whole, represents an improvement. Since each A 46 plant FSAF'. may contain specific or unique commitments, each licensee must review the various aspects of the GIP methodology against tne various related aspects of the plant licensing basis and determine, after reviewing the specific aspects, if the adoption of the GIP lavolves an USQ.

If the licensee concludes that a USQ is involved, adoption of the GlP into the licensing basis would require the licensee to seek an amendment under the provisions of 10 CFR 50.90.

Consistent with the steifs May 22,1992, SER, the staff intends to reach closure on USl A-46 Implementation at a facility prior to approving an amendment to incorporate the GIP into the licensing basis (should one be proposed) for that facility.

As an example of the above staff position, the staff considered the situation where equipment damping is specified in a plant's FSAR and the licensee seeks to make an evaluation under the provisions of 10 CFR 50.59. If the FSAR contains specific equipment damping values that are less than those permitted by the GIP, the licensee must review the aspec% affectad by the change and make its own determination regcrding whether or not an USQ exists at its facility.

An analogous situation (discussed with SQUG during the October 30,1997, meeting) involved the application of seismic demand criteria.

If a licensee determines that a license amendment is the viable means to approach the GIP-2 incorporation inL the licensing basis, an application should be submitted requesting the desired change. To facintate the staffs evaluation, the application should contain: 1) identification of areas in the GIP (e.g., criteria, procedures, methodologies) that the licensee proposes to incorporate in the FSAR; 2) aspects of the GIP where the proposed change is less conservative than the FSAR criteria specified for that particular aspect (e.g., non-safety vs. s$ty equipment);

3) identification of the plant's components and equipment to which the GIP will be applicable; and 4),iustification to support the adequacy of tiie proposed change. Referencing appropriato portions of the licensee's USl A 46 submitia! and the staffs plant-specific SER is suggested.

The staffs review of amendment requests should be facilitated by the review effort already expended on the licensee's USl A-46 program.

In summary, neither the staff nor SQUG can reach a generic conclusion regarding the appropriato means to incorporate the GlP-2 into a facility's licensing basis. The determination is based primarily on the specifics in the licensing basis for the particular facility. We believe that a constructive dialogue between the staff and the lead plants proposing to amend their licenses

will be productive _in establishing acceptable ground rules for other USl A-46 liansees that -

conclude an amendment is the appropriate process for incorporating the GlP in the plant's.

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licensing basis.

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