L-92-222, Describes Seismic Program to Comply W/Suppl 4 to GL 88-20, IPEEE for Severe Accident Vulnerabilities, Per NRC .Implementation for Both Policy Statement on Severe Accidents & USI A-46 Employ Similar Methodologies
| ML17349A372 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/31/1992 |
| From: | Bohlke W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-88-20, L-92-222, NUDOCS 9209100020 | |
| Download: ML17349A372 (16) | |
Text
ACCELERATED DISTRIBUTIONDEMONSTRATION SYSTEM REGULAT INFORMATION DISTRIBUTIQ YSTEM (RIDS) t ACQESS ION NBR: 920'V100020 DOC. DATE: 92/08/31 NQTARIZED:
YES FACIL: 50-250 Turkey Point Planti Unit DI Florida Power and Light C 50-251 Turkey Point Planti Unit
%I Florida Power and Light C AUTH. NAME'UTHOR AFFILIATION BQHLKE> W. H.
Florida Power 8c Light Co.
REC IP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 0 05000250 05000251
SUBJECT:
Describes seismic program to comply iii/Supp 1 4 to GL 88-20.
"IPEEE for Severe Accident Vulnerabilitiesi " per NRC 920625 ltr. Implementation
%or both policy statement on severe accidents Zc USI A-46 employ similar methodologies.
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TITLE: Generic Ltr 88-20 re Individual Plant Evaluations NOTES: NRR RAGHAVANIL NRR RAGHAVANIL 05000256 05000251 REC IP IENT ID CODE/NAME PD2-2 PD COPIES LTTR ENCL 1
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I L
P.O. Box1400u, uno Beach, FL 33408-0420 AUG 3 t 3992 L-92-222 10 CFR 50.54(f)
U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.
CD 20555 Re:
Turkey Point Units 3
& 4 Docket Nos.
50-250 and 50-251 St. Lucie Units 1 and 2
Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities Generic Letter GL No. 88-20 Su lement 4
Gentlemen:
GL 88-20, Supplement 4,
issued on June 28, 1991 requested that licensees submit a description of their proposed program for completing an IPEEE to identify vulnerabilities to severe accidents.
Florida Power and Light Company (FPL), by letter L-91-336 dated December 23, 1991, provided IPEEE Program Plans for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4.
In letter L-91-336, FPL proposed alternative methods to those described in GL 88-20, Supplement 4 and in NUREG 1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities", to satisfy the intent of the IPEEE for seismic events.
By NRC letter dated June 25, 1992, the NRC stated that the methods proposed by FPL to satisfy the intent of the IPEEE are acceptable with the exception of seismic events.
By letter L-91-336, dated December 23, 1991 FPL proposed using the results of the proprietary FPL site-specific Seismic Program associated with Unresolved Safety Issue (USI) A-46 (Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors" ) to resolve the seismic aspects of GL 88-20.
The NRC's June 25, 1992 letter stated that a
determination on the acceptability of the FPL Seismic Program could not be made since specific information on the program had not been provided in FPL's December 23, 1991 response.
The staff requested that FPL submit a description of the program.
FPL's Seismic Program was submitted to the NRC on August 4, 1988 (FPL Letter L-88-333) and later revised in response to NRC
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L-92-222 Page 2 of 3 FPL is resolving the outstanding issues regarding this program with the NRC.
Attachment 1 compares the program elements requested by GL 88-20, Supplement 4/NUREG-1407 with the elements
- in FPL's Seismic Program.
By letter dated August 17,
- 1989, from Gordon E.
Edison and Jan A. Norris to C. 0.
Woody, the NRC accepted FPL's Seismic Program as proprietary under 10 CFR 2.790.
Since Attachment 1 describes the FPL Seismic Program, we request that it also be withheld from public disclosure in accordance with 10 CFR 2.790.
An affidavit supporting this request is attached.
In the NRC's June 25, 1992 letter, the staff commented that the purpose of the IPEEE is different than that of USI A-46 and that the scope of the IPEEE is broader than that of USI A-46.
FPL's position on these subjects follows.
The purpose of the IPEEE is to implement the Policy Statement on Severe Accidents.
The Policy Statement, in turn, has as its
- purpose, reduction in the risk of occurrence of a severe accident involving substantial damage to the reactor core if cost effective modifications can be made to reduce the risk.
IPEEE/GL 88-20 Supplement 4
(for Reduced Scope Plants) allows licensees to demonstrate that a seismically adequate equipment path exists to safely shut down the reactor if there is an earthquake at the Safe Shutdown Earthquake (SSE) level.'he purpose of USI A-46 is to verify the seismic adequacy of mechanical and electrical equipment in older plants at the SSE level to design criteria not in use when the plants were originally licensed.
The equipment in a path which can be used for safe shutdown must be chosen and specified.
GL 87-02 implements USI A-46 by allowing licenses to'.demonstrate that such an equipment path exists using equipment verified to be seismically adequate.
While the stated purposes of the Policy Statement on Severe Accidents and USI A-46 are different, the implementation methodology (for'Reduced Scope Plants) is'he same, i.e'., to verify that an equipment path
- exists, using seismically adequate equipment, to safely shut down the reactor if there is an earthquake at the SSE level.
If evaluations are made using a review level earthquake (RLE) above the SSE, the scope of the IPEEE can be broader than for USI A-46 because non-design basis accidents are to be considered.
These include seismically induced loss of coolant accidents (LOCAs),
- fires, floods, high energy line breaks (HELBs) and mitigating systems to address these seismically induced accidents.
L-92-222 Page 3 of 3 Since the RLE is equal to the SSE for Reduced Scope Plants, (GL 88-20, Supplement 4, Appendix 3) these non-design basis accidents do not need to be addressed, nor does the adequacy of Seismic Category I, piping systems and structures and components need to be addressed.
On the basis of the above, it is FPL's position that the FPL Seismic Program adequately meets both the IPEEE and USI A-46 generic letters.
FPL has conducted a search for vulnerabilities, in the context. of GL 88-20 Supplement 4 at Turkey Point Units 3 and 4 and St. Lucie Unit 1 by implementing the FPL Seismic Program and will do so for St. Lucie Unit 2 in September 1992.
Very truly yours, W. H. Bohlke Vice President Nuclear Engineering and Licensing WHB/rcs
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)
)
ss.
COUNTY OF PALM BEACH
)
W. H. Bohlke being first duly* sworn, deposes and says:
That he is Vice President Nuclear En ineerin and Licensin of Florida Power
& Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
W. H. Bohlke Subscribed and sworn to before me this day oe
, l9%.
NOTARY PUBLIC, i order 'and,for the County of Palm Beach, State of Florida Notary Pubiic, State of Florida My Comm. Exp. Fcb. 18, 1995 My COmmiSSiOn eXpireS BondedthruPtCHAft~tns."gency Cow w,do-b 8geog Cp
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AFFIDAVIT State of Florida County of Palm Beach W.
H.
Bohlke being first duly
- sworn, deposes and says the following:
2.
3.
4 ~
I am the Vice President Nuclear Engineering and Licensing of Florida Power and Light (FPL)
Company, the Licensee herein.
Attachment 1 submitted with letter L-92-222 describes details of FPL's Seismic Program.
By letter dated August 17, 1989 to FPL from the NRC's St.
Lucie and Turkey Point Project
- Managers, this program was accepted as proprietary to be withheld from public disclosure per 10CFR2.790 and accordingly Attachment 1 is to be withheld from public disclosure per 10CFR2.790.
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. H. Bohlke Subscribed and sworn to before me this ~3 day of Law 1992.
Notary Public, n and for th County of Palm Beach, State of Florida s~h My Commission expires:
Notary Public, State of Florida h'ly Comm. Exp. Feb. 18, 1995 Bondso thru PICtfARD Ins. Agency Corns. Qo. npgb>
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ATTACHMENT1 THE ATTACHMENTIS SUBMITTEDAS PROPRIETARY UNDER THE PROVSIONS 1 IW FR 2.790 COMPARSON OF CRllERIACONTAINEDIN GENERIC LETTER (GL) 8820 SUPPLEMENT4/NUREG1 407 WITHFPL (PROPRIETARY) SITE SPECIFIC SESMIC SSUE RESOLUllON PROGRAM (FPL SESMIC PROGRAM)
GENERIC lETTER (GL) 88-20 SUPPLEMENT 4/NUREG-1407 FPL SESMIC PROGRAM PROPOSED MODIFICATIONSTOFPL SESMIC PROGRAM TO ADDRESS GL8820 SUPPLEMENT 4/NUREG-1407 A Operational Criterh 1
Equipment to Achieve and Maintain HotShutdovm a) lnstruments8 Control b) Chemical &Volume Control c) Heat Removal Capability d) Electrical Power Supply The GL8 NUREG Do Not Contah AnySpecilic Equipment Usta But They:
- 1) Refer to the Objective of Achieving 8 Maintaining Hot Shutdown
- 2) Refer to the Objective of Addressing Reactor Subcriticality
- 3) Refer to the Objective ofAddressing Early Emergency Core Coofing The FPL Seismic Program Contahs Specifi Equipment Usta for Equipment to Achieve &Maintain Hot Shutdown per Items a) through d) Inclusive and to address reactor subcrtticafity and early emergency core coofing.
- 1) None-See Discussion Below a) FPLs Seismic Program also Assumes Loss of OlfSite Power Due to the Seismic events theResulting Need tousethePhnt EmergencyPower Systems.
b) The GL 8 NUREG do not Specify Loss of OffSte Power.
c) FPL Considersits Program to be More Conservative and an enhancement to the GLand NUREG.
2 Initial Rant Status FuI Power Operating Conditions
- 1) None 3
Maximum Maintenance 72 Hours of HotShutdovm 8 Hours
- 1) None-See Discussion Below a) FPLs Programs to Implement the Station Bhckout Rule Provide forno more than 8 Hours at HotShutdown 8 have been Accepted by NRC/SER.
b) 8 Hours is Consistent with FPLs Rant Technical Specificalions.
4 Considerationof Non-NotRequestedforReducedScope Design Basis Accidents Phnts None
- 1) None-See DiscussingBehw a) Reduced Scope Phnts do not have to consider seismically induced LOCAs,fires, floods, HELBS and mitigating systems.
5 Consideration of Failures
- 1) Passive Mechanical and NSSS
- 2) NonSelsmic
- 3) Human None
- 1) None-See DiscussionBelow a) Cannot be jusfified due to technical and economic considerations.
2 GENERIC LEVIER (GL) 88-20 SUPPLEMENT 4/NUREG-1407 FPL SEISMIC PROGRAM PROPOSED MODIFICATIONSTOFPL SEISMIC PROGRAM TO ADDRESS GL~ SUPPLEMENT4/NUREG-1407 B
Programmatic Criteria 1
LIcensee StaN Participation Included
- 1) None 2
Perform Pre-Walk Dovm Investigations Included
- 1) None 3
Provide a Success Path For Equipment Included
- 1) None 4
Provide an Alternative Success Path for Equipment Requested Not Included
- 1) None-See DiscussionBelow a) FPLs Seismic Program Provides that Concerns Related to Equipment in the Success Path willbe Checkedin the Other Train of Equipment.
5 Outliers Requested to be Evaluated Per SQUG/GIP Procedures Evaluated Per Normal Plant Procedures Addressing Potentially Non-Conforming Conditions
- 1) None-See DiscussionBelow a) FPL is not a Member ofSQUG 8 does not have Accessto the (Proprietary) GIP Procedures.
b) FPL Staff have been Trained to Use Normal Plant Procedures 8 an Infrastructure is in Place to Process Potentially Nonconforming Conditions up to 8 Induding Reporting to the NRC lfRequired.
6 Peer Review Induded
- 1) None
7
3
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C Technical Criterh GENERIC LETTER (GL) 88-20 SUPPLEMENT 4/NUREG-1407 FPL SEISMIC PROGRAM PROPOSED MODIFICATIONSTOFPL SEISMIC PROGRAM TO ADDRESS GL~ SUPPLEMENT 4/NUREG-1407 1
Seismic Input Safe Shutdovm Earthquake (SSE)
Same Ground Response Spectra &In-Structure Spectra
- 1) None 2
Wrench Tightness Checks For Anchor Bolts 3
Rehy Chatter Evaluation 4 Soih Review 5
Equipment FragiMes Not Requested Not Requested Not Requested Requested to be Evahated Per SQUG/GIP Procedures Not Induded Not Induded Not Induded Evahated Per SSRAP Bounding Spectra Pmcedures
- 1) None
- 1) None
- 1) None
- 1) None-See DIscussionBelow a) FPL is not a Member ofSQUG &Does Not Have Accessto the (Proprietary)
GIP Procedures b) The SSRAP Bounding Procedures are in the Pubhc Domain c) SSRAP Provided Oversight 8 Peer Review ofthe GIP d) SSRAP had NRC Membership 6
Containment 8 Containment Not Requested Systems Review Not Induded
- 1) None D
Documentation Criteria 1
Waikdown Documentation Format Per EPRI NP4041 E
Other Issue Resokrtion Criteria Format for Reduced Scope Rants'nduded
- 1) None 1
Seismic Adequacy of Decay Requested Heat Removal Equipment (USI A-45)
Induded (See Item A.1.c.)
- 1) None 2
Seismic Spatial Systems Interactions (USI A-17) 3 Seismic Design Criteria For Large Tanks (USI AM) 4 Seismic Interaction of Westinghouse ln-Core Rux Mapping System Components Requested (Rping/Iubing/
Structures)
Not Requested Induded Induded Not Induded
- 1) None
- 1) This Item Only Induded at Turkey Point Units 3 &4, &
SL Lucie Unit 1.
- 2) St. Lucie Unit2 is Exempted Per NUREG - 1233 (September 1889)
- 1) This Issue wi8 be Induded in the Resolution of GL 88-20 as a Separate Item from the FPL Seismic Program
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