L-88-333, Summarizes Progress Re Resolution of Generic Ltr 87-02 & USI A-46 Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors.Proprietary Info Withheld
| ML17347A839 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point, 05000000 |
| Issue date: | 08/04/1988 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17347A840 | List: |
| References | |
| REF-GTECI-A-46, REF-GTECI-DC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, L-88-333, NUDOCS 8808170129 | |
| Download: ML17347A839 (17) | |
Text
ACCELEBRATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8808170129 DOC.DATE-88/08/04 NOTARIZED: YES DOCKET g FACIL:50-000 Generic Docket 05000000 50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
05000335 50-389 St. Lucie Plant, Unit 2, Florida Power
& Light Co.
05000389 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION R
Document Control Branch (Document Control Desk) 8/l7/fi'f Sea ~< 5 I
SUBJECT:
Summarizes progress re resolution of GL 87-02
& forwards proprietary "Plant Specific Sesimic Adequacy...."
D DISTRIBUTION CODE:
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Equipment Qualification I
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X 14000, JUNO BEACH, FL 3340B-0420
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KIXGMO 4 1988 L-88-3 3 3 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Re:
St. Lucie Unit 1 Docket No. 50-335 Turkey Point. Units 3 and 4
Docket Nos.
50-250 and 50-251 Verification of Seismic Adequacy of Mechanical and Electrical E ui ment in 0 eratin Reactors Unresolved Safety Issue (USI) A-46 Generic Letter GL 87-02 The purpose of this letter is to summarize the progress made to date with regard to the resolution of GL 87-02 and to submit Florida Power and Light Company's (FPL's) program for final resolution of GL 87-02.
GL 87-02 was issued by the Nuclear Regulatory Commission (NRC) on February 19, 1987.
FPL has provided responses/progress updates by letters L-87-211 (May 15, 1987);
L-87-401 (October 1,
1987);
and L-88-51 (February 1,
1988).
Each of these letters indicate that, FPL is following a
policy of achieving resolution based upon a
low probability/low intensity Safe Shutdown Earthquake (SSE) occurring at FPL's St.
Lucie and Turkey Point sites; and a
correspondingly low societal risk being associated with the concerns expressed in GL 87-02.
The technical studies conducted by FPL to date have indicated that given the national average probability of occurrence of a
Lucie and Turkey Point sites should be below the minimum value of O.lg required by 10 CFR 100.
This results in inherent seismic margin for existing safe shutdown
- systems, structures and components due to their design criteria having been 0.1g at the St. Lucie site and 0.15g at the Turkey Point site.
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L-88-333 Page 2
On June 2,
- 1988, FPL met with members of the NRC staff at which time FPL presented the technical basis to support its position of low societal risk being associated with the concerns expressed in GL 87-02, at FPL's St. Lucie and Turkey Point sites.
The FPL presentation is provided herewith in Appendix A.
The meeting was documented in NRC minutes dated June 16, 1988.
The NRC minutes reflect that FPL would not rectify anchorage problems, if found to exist; however, FPL's recollection of the dialogue is that we intend to rectify anchorage problems, if found to exist.
After the FPL presentation, the NRC staff reques.
ed that FPL could either:
(a) propose a scaled-back program; or (b) appeal the need for any program at all by invoking the backfit rule.
FPL has chosen alternative (a) and ha's developed a program within the economic and prudency constraints imposed by the value/impact analysis for GL 87-02.
Details of the program are provided herewith in Appendix B.
Pending NRC acceptance of FPL's
- program, FPL reserves the, option to exercise its right to backfit appeals under 10 CFR 50.109.
FPL. estimates that its program can be started within two months of NRC acceptance and completed within six months, for both the St. Lucie and Turkey Point sites.
Since the program is proprietary, Appendix B
is being submitted under the provisions of 10 CFR 2.790 (a)(4)
(affidavit attached).
Very truly yours, W. F.
Conw y Senior Vice President-Nuclear WFC/JRL/cm Attachment cc:
J. Nelson Grace, Regional Administrator, Region II, USNRC (2 copies)
Senior Resident Inspector, USNRC, St. Lucie Plant Senior Resident Inspector, USNRC, Turkey Point Plant
4 1
tl t
AFFIDAVIT State of Florida County of Palm Beach W.
F.
Conway being first duly
- sworn, deposes and says the following:
1.
I am Senior Vice President-Nuclear of Florida Power and 2 ~
3 ~
4 ~
5.
Light Company, the Licensee herein.
Appendix B submitted with letter L-88-333 consists of a
specific implementation procedure for the purpose of resolving Unresolved Safety Issue (USI) A-46.
The procedure includes details of organization, performance and documentation.
The procedure incorporates trade secrets and privileged and confidential commercial information which is owned by FPL.
The procedure is proprietary, has been held in confidence by
- FPL, and has never been released to the public.
The proceduxe was developed using FPL's resources.
The information contained in the procedure would unduly enrich other utilities should they be able to use it without providing compensation to FPL for that use.
I am aware that other nuclear utilities, acting through their utility group (Seismic Qualification Utility Group) also regard their implementation procedure for the purpose of resolving A-46 as being proprietary and confidential.
The statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief.
I am authorized to execute this affidavit on behalf of the said Licensee.
W. F.
Co y
Subsc ibe and sworn to before me this day of
, 1988.
Notary l c, in and for the Count f Palm Beach, State of Florida NOTARY PUBLIC STATE OF FLORIOA NY CONNISSIOR EXP JULY 30,I990 My Commission expires:
BONDEO THRU GENERAL INS, UNP, lt
APPENDIX A
,, 88081,.70-1 2g-
TABLE OF CONTENTS SECTION DESCRIPTION Summary Background Information Seismic Hazard Data Radiological Data Analysis and Conclusions
i
St.
Lucie Unit 1
and Turkey Point Units 3/4 have been in commercial operation for 12 and 16/15 years respectively, during which time they have been in compliance with applicable NRC seismic requirements and during which time they have
- provided, and still provide, adequate protection of the public health and safety.
There has been no finding that the seismic criteria for St. Lucie Unit 1 and Turkey Pdint Units 3/4 are unsatisfactory compared. to current criteria (IEEE 344-75) or to the seismic criteria created from test and experience data which are being proposed for use by Generic Letter 87-02.
Generic Letter 87-02 specifies that "the seismic adequacy of certain equipment in operating nuclear power plants must be reviewed against seismic criteria not in-use when these plants were licensed".
This resolution was determined by the. Committee to Review Generic Requirements to be a backfit within the meaning of 10CFR50.109 and consequently in late 1986 the staff was instructed to perform a
systematic and documented analysis to provide evidence that there would be a substantial increase in the overall protection of the public health and safety and that the direct and indirect costs of the implementation of the information request would be justified.
The analysis which was performed was generic and can be found in NUREG,1211, issued with the Generic Letter in February of 1987.
This generic analysis addresses the potential change in the risk to the public from the accidental off-site 'release of radioactive material using generic data and concludes that a potential risk to the public of 940 man-rem could be reduced by an order of magnitude (to effect a net risk reduction of 846 man-rem).
Page 1
FpL has reproduced the above analysis using methodology identical to that used by the NRC staff but substituting site specific data for St.
Lucie Unit 1 and Turkey Point Units 3/4 in place of the generic data.
At St. Lucie Unit 1, the potential risk reduction is only 15 man-rem and at Turkey Point Units 3/4, the potential risk reduction is only 8 man-rem.
It could well be that the collective dose to the persons responding to the information request (i.e.,
walkdown personnel) might equal these figures in which case there would be an actual exposure increase instead of a
potential exposure reduction.
Using the NRC accepted figure of
$ 1,000 per man-rem, the maximum value to St.
Lucie Unit 1 and Turkey Point Units 3/4 would be
$ 15,000 and
$8,000 respectively.
FPL also believes the actual values should be less for reasons explai.'ned in the section
'f this report documenting analysis and conclusions.
From the foregoing, FPL maintains that it would not be prudent management of FPL's resources to authorize an expenditure of at least
$750,000 per unit to satisfy an information request which has such minimal value or to commit FPL to new seismic criteria when there is no reason to believe that seismic criteria now in use at, the FPL plants do not provide adequate protection of the public health and safety.
In conclusion, FPL requests that the staff affirm, on the basis of the technical data supplied
- herein, that satisfactory resolution of Generic Letter 87-02 and USI A-46 has been achieved for St. Lucie Unit 1 and Turkey Point Units 3/4.
,Page 2
0 BACKGROUND DATA In the late 1970's, the NRC felt that operating nuclear power plants designed to seismic criteria prior to IEEE 344-75 might possibly not withstand the Safe Shutdown Earthquake (SSE).
This concern formed the basis for Unresolved Safety Issue (USI) A-46, created in 1980.
The NRC realized that requiring all operating plants to conform to IEEE 344-75 would be cost prohibitive and so the NRC agreed to a, program for the creation of new generic seismic
- criteria, (including generic floor response spectra) based on test data and experience data from heavy industrial (non-nuclear) facilities around the world.
It was the intention of the NRC when the new generic seismic criteria had been developed, to issue a 10CFR50.54(f) information request to cause the utilities to perform a
sel f evaluation against the new generic seismic criteria.
"Deficiencies" under the new generic seismic criteria would then require JCOs and engineering or plant modifications.
The cost of fixing "deficiencies" would be in addition to the cost of the self evaluation.
Also, the new generic seismic criteria would be in effect for the balance of the life of the plants.
During the 1980's, while the new generic seismic criteria were being developed, two major changes occurred in the nuclear-industry, both of which affected A-46.
The first change was the maturing of risk analysis methodology and its recognition and adoption by the NRC.
Page 1
w The second change (in October 1985) was the adoption of 10 CFR50.109, which itself recognized risk analysis methodology and recommended its use in the'alue/Impact studies which were now mandated before the NRC could implement new staff positions.
On October 16,
- 1986, the NRC staff presented the proposed final resolution of USI, A-46 to the Committee to Review Generic Requirements (CRGR).
The CRGR is chartered, among other things, to assure that the provisions of 10CFR2.204, 10CFR50.109, and 10CFR50.54(f) are met as regards generic requirements.
Tools used by the CRGR include Value/Impact analysis and risk assessment.
At the meeting, the NRC staff informed the CRGR that it intended to issue a
10CFR50.54(f) information request to implement the Generic Letter.
However the
- CRGR, supported by the Office of General
- Counsel, present at the meeting, instructed the NRC staff that the Generic Letter's request for information was subject to the 10CFR50. 109 provisions as a backfit and that a Value/Impact analysis would be required before the Generic Letter could be issued.
This analysis was subsequently prepared by the NRC staff and can be found in NUREG 1211, issued with the Generic Letter.
The CRGR also commented at the October 16, 1986 meeting that the cost to the industry to develop the new generic seismic criteria was already tens of millions of dollars and that the final cost of the proposed resolution would be in the 50 to 100 million dollar range.
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