ML080500075
| ML080500075 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/04/2008 |
| From: | Boyce T NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Stall J Florida Power & Light Co |
| Mozafari B, NRR/ADRO/DORL, 415-2020 | |
| References | |
| TAC MD5145 | |
| Download: ML080500075 (13) | |
Text
March 4, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
ST. LUCIE NUCLEAR PLANT, UNIT 1 - SAFETY EVALUATION OF RELIEF REQUEST NO. 29 TO USE ALTERNATIVE PLANT CONDITIONS ON CLASS 1 PIPING AND VALVES (TAC NO. MD5145)
Dear Mr. Stall:
By letter dated March 22, 2007, Florida Power & Light (FPL) submitted relief request No. 29 for approval to perform the examination of select Class 1 piping and valves at plant conditions other than those required by the American Society of Mechanical Engineers Boiler and Pressure vessel Code (ASME Code) to be used at St. Lucie Unit 1 (SL-1). ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition, Table IWB-2500-1, Examination Category B-P, Items B15.51 and B15.71, require a system hydrostatic test to include all ASME Code Class 1 components within the system boundary.
FPL will use ASME Code Case N-498-4 Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems,Section XI, Division 1, with modification to Section (a)(2), which requires a system leakage test to include all ASME Code Class 1 components within the system boundary.
The Nuclear Regulation Commission (NRC) staff has reviewed and evaluated FPLs submittal and concludes that complying with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. ASME Code Case N-498-4 with modification provides reasonable assurance of structural integrity.
Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(ii), the proposed system leakage test with modification is authorized for the SL-1 third 10-year Inservice Inspection interval that ended February 10, 2008.
J. Stall Further details on the bases for the NRC staffs conclusions are contained in the enclosed safety evaluation. If you have any questions regarding this issue, please feel free to contact Brenda Mozafari at (301) 415-2020.
Sincerely,
/RA Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-335
Enclosure:
Safety Evaluation cc w/enclosure: See next page
ML080500075 NRR-084 OFFICE PDII-2/PM PDII-2/LA OGC DciCptb PDII-2/SC NAME BMozafari BClayton NLO w/ TChan TBoyce comments By memo dated MBaty DATE 03/04/08 03/04/08 02/29/08 2/15/08 03/04/08
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THIRD 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. 29 ST. LUCIE PLANT, UNIT 1 FLORIDA POWER AND LIGHT COMPANY DOCKET NUMBER 50-335
1.0 INTRODUCTION
By letter dated March 22, 2007, Florida Power & Light (FPL) submitted Relief Request (RR)
No. 29 for approval to perform the examination of select Class 1 piping and valves at plant conditions other than those required by the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) to be used at St. Lucie Unit 1 (SL-1). ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition, Table IWB-2500-1, Examination Category B-P, Items B15.51 and B15.71, require a system hydrostatic test to include all ASME Code Class 1 components within the system boundary.
FPL will use ASME Code Case N-498-4 Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 SystemsSection XI, Division 1 with modification to Section (a)(2), which requires a system leakage test to include all ASME Code Class 1 components within the system boundary. Code Case N-498-4 is approved for use in Nuclear Regulatory Commission (NRC) Regulatory Guide 1.147, Revision 14.
RR-29 is applicable to the third 10-year inservice inspection (ISI) interval for SL-1 and pertains to the system hydrostatic pressure test requirements for specified ASME Code Class 1 small bore reactor coolant system (RCS) vent and drain lines, safety injection/shutdown cooling fill, vent and drain lines and larger bore safety injection and shutdown cooling piping segments.
2.0 REGULATORY EVALUATION
Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, Rules for In-service Inspection (ISI) of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
Enclosure
The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for the current, third 10-year ISI interval at SL-1, which began February 11, 1998, and ended February 10, 2008, isSection XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, no Addenda.
Pursuant to 10 CFR 50.55a(a)(3), alternatives to requirements may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternatives provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
FPL submitted RR-29, pursuant to 10 CFR 50.55a(a)(3)(ii), which proposes to use ASME Code Case N-498-4, Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 SystemsSection XI, Division 1 with modification to Section (a)(2) in lieu of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, Items B15.51 and B15.71.
3.0 FPLs REQUEST 3.1 System/Components Affected The following table provides a brief description of SL-1 Class 1 system/components affected by this request. Also, see Tables 1 and 2 of RR-29 for a comprehensive description of affected Class 1 pressure retaining components.
ST. LUCIE - UNIT 1 CLASS 1 PIPING EXAMINATION ITEM EXAMINATION DESCRIPTION CATEGORY NUMBER Piping - Pressure Retaining Boundary, including RCS, Safety B15.51 Injection and Shutdown Cooling process piping, vents, and drains.
B-P Valves - Pressure Retaining Boundary, including RCS, Safety B15.71 Injection and Shutdown Cooling process, vent, and drain isolation valves.
3.2 Applicable Code Requirement, Edition and Addenda ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, Note 2, 1989 Edition, no Addenda. (Note 2 of Table IWB-2500-1) 3.3 Reason for the Request Pursuant to the provisions of 10 CFR 50.55a(a)(3)(ii), FPL requests approval to perform the examination of select Class 1 piping and valves at plant conditions other than those required by the ASME Code. Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii) on the basis
that hardship and unusual difficulty exists in establishing a system configuration that will subject all Class 1 components to RCS pressure during the system pressure test without a compensating increase in the level of quality and safety. Extending the pressure retaining boundary during system pressure test to all Class 1 pressure retaining components within the system boundary will require a number of temporary system alterations, temporary piping installations, and control logic alterations.
Table 1 of RR-29 identifies the Class 1 pressure retaining components associated with the requested relief that will remain in their normal operating configuration and will not be pressurized during the system leakage test. FPL states that the Class 1 vents and drains in the RCS are equipped with inboard isolation valves and outboard blind flanges that provide double isolation of the Reactor Coolant Pressure Boundary (RCPB). The valves are maintained in the closed position during normal plant operation, and the downstream pipe and blind flange are not normally pressurized. To perform the ASME Code required pressure test, it would be necessary to manually open the inboard valves to pressurize the piping and connections.
Pressurization by this method defeats the double isolation and reduces the margin of personnel safety for those performing the test.
FPL states that performing the test with the inboard isolation valves open requires several man-hours to position the valves for the test and restore the valves to their closed positions once the test is completed. These valves are located in close proximity to the RCS loop piping and thus would require personnel entry into high radiation areas within the containment and a consequent increase in radiation exposure. Since this test would be performed near the end of an outage when all RCS work has been completed, the time required to open and close these valves would impact the outage schedule. Furthermore, there is no way to depressurize the piping following test completion.
Table 2 of RR-29 identifies the Class 1 pressure retaining components associated with the requested relief that will remain in their normal operating configuration and will not be pressurized to RCS system pressure during the system leakage test, but will be examined at full operating pressures commensurate with their respective safety functions. Design of some SL-1 Class 1 process piping requires substantial effort to extend the boundary subject to RCS pressure where check valves or nonredundant components serve as the first system isolation from the RCS. Such configurations may require temporary piping installations, such as hard-pipe jumpers, and/or other unusual temporary system configurations in order to achieve test pressures at upstream piping and valves. Class 1 system pressure testing is performed in Mode 3 and the temporary configurations could conflict with technical specification requirements. Establishing and restoring such temporary configurations could also result in an unwarranted increase in worker radiation exposure.
FPL states that extension of the boundary subjected to RCS pressure during system leakage tests to include all Class 1 pressure retaining components within the system boundary represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety provided by the examination. The following is specific information pertaining to the various pipe segments for which relief has been requested; however, for a comprehensive description of affected Class 1 pressure retaining components see Tables 1 and 2 of RR-29.
3.3.1 Small Bore Class 1 RCS Vent and Drain Lines FPL states relief is requested from pressurizing piping between the first and second isolation device on small bore vent and drain lines. There are ten Class 1 vent or drain lines in the RCS identified in Table 1 of RR-29, ranging in size from 3/4-inch to 2 inches. Eight of the ten consist of an inboard isolation valve and a blind flange in series. Two 3/4-inch segments consist of two valves in series. The piping segments provide the design-required double isolation barrier for the RCPB.
3.3.2 Small Bore Class 1 Safety Injection/Shutdown Cooling Fill, Vent and Drain Lines FPL states that there are 29 vent and drain lines in the Class 1 portion of the Safety Injection (SI) system, size 3/4-inch or 1-inch. In addition, there are four 1-inch safety injection tank (SIT) fill lines, four 3/4-inch pressure transmitter root lines, and four 2-inch high-pressure safety injection (HPSI) header lines within the Class 1 portion of the SI system directly connected to the RCS, isolated by the 12-inch loop check valves.
3.3.3 Larger Bore Class 1 Safety Injection and Shutdown Cooling Piping Segments (a) Hot Leg Shutdown Cooling Suction FPL states that there are two 10-inch Hot Leg Shutdown Cooling Suction lines, one from each hot leg. The piping segments consist of short segments of piping between the two shutdown cooling suction valves on each train of the system. The valves are interlocked at a required setpoint below 350 psig, and administratively controlled to be closed at a pressure not to exceed 275 psia to avoid over-pressurization of the Shutdown Cooling System (SCS).
(b) HPSI/Low Pressure Safety Injection (LPSI) Loop Header and SIT discharge piping FPL states that these large bore piping segments provide the flow path for SIT discharge into the RCS, HPSI and LPSI and shutdown cooling return to the RCS. The primary isolation devices are the 12-inch loop check valves oriented to flow into the RCS. The piping segments provide the design-required double isolation barrier for the reactor coolant pressure boundary.
3.4 Proposed Alternative and Basis FPL will conduct the required end of interval system pressure tests as prescribed by ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, using the alternative requirements of ASME Code Case N-498-4 with boundary modifications/exceptions as stated in Tables 1 and 2 of RR-29. Those portions of the systems that are statically pressurized during normal operation will be visually VT-2 examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI System functional pressure test conducted at HPSI Pump discharge pressure.
The objective of the required visual examination at normal operating conditions is to detect evidence of leakage and thereby verify the integrity of the RCS pressure boundary. FPL believes the same evidence of leakage can be identified by visual examination of all portions of the Class 1 systems at their own normal operating pressures without subjecting the standby systems and secondary boundaries to unusual alignments and excess pressure.
3.5 Duration of the Proposed Request The proposed ASME Code Case N-498-4, with modification, will be implemented for the remainder of the third 10-year ISI Interval that ended on February 10, 2008.
4.0 NRC STAFF EVALUATION The ASME Code requires that all Class 1 components within the RCS boundary undergo a system hydrostatic test once per 10-year interval. FPL proposed to use ASME Code Case N-498-4, with modification, in lieu of the hydrostatic test requirements of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, Note 2. Table IWB-2500-1, Examination Category B-P, Note 2 states, "The pressure retaining boundary during system hydrostatic test shall include all Class 1 components within the system boundary. ASME Code Case N-498-4, Alternative Requirements for 10-Year System Hydrostatic Testing for Class 1, 2, and 3 Systems, Section (a)(2) states, "The boundary subject to test pressurization during the system leakage test shall extend to all Class 1 pressure retaining components within the system boundary." FPL requested relief from ASME Code Case N-498-4, Section (a)(2), which requires extension of the RCPB to all Class 1 pressure retaining components as stated above. FPL proposed to use a system leakage test in accordance with ASME Code Case N-498-4 with modification to Section (a)(2).
4.1 Exceptions to Modified Code Case N-498-4 4.1.1 Small Bore Class 1 RCS Vent and Drain Lines FPL requested relief from Section (a)(2) of ASME Code Case N-498-4, to exclude pressure retaining components identified in Section 3.3.1 above from the system leakage test. The subject components will remain in their normal operating configuration and will not be pressurized to RCS pressure during the system leakage test.
FPL stated that the ASME Code-required leakage test would be performed in MODE 3 (i.e., Hot Standby) at the normal operating pressure of 2250 psia and a nominal temperature of 532 °F.
The leakage testing of vent and drain piping segments in MODE 3 would require opening of the inboard isolation valve at normal operating RCS pressure and temperature conditions and, in doing so, the design requirement for two primary coolant pressure boundary isolation devices would be violated. Furthermore, FPL states that opening these valves would introduce the potential risk for spills and personnel contamination and would eliminate a way to depressurize the line segments following completion of the examination.
As an alternate means of inspection FPL notes that the small bore Class 1 RCS vent and drain piping segments are among the population of items examined in accordance with ASME Code Case N-533, Alternative Requirements for VT-2 Visual Examination of Class 1 Insulated Pressure-Retaining Bolted ConnectionsSection XI, Division 1, at the beginning of each outage and are also included in the population for VT-2 examination through their entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The leakage test will not specifically pressurize past the first isolation valve for this inspection and no external or visible leakage shall be permitted. FPL states that this type of test will assure that the combined first and second isolation devices are effective in maintaining the RCPB at normal operating pressure and temperature. Therefore, the increase in safety achieved from the ASME
Code-required leakage test does not provide proportionate benefits to the hardship of performing such testing.
The NRC staff concludes the following based on the preceding discussion: (1) that pressurization of the subject line segments would require SL-1 to override the double containment isolation design resulting in no method of depressurization without the addition of some temporary system configuration. The NRC staff believes that no compensating increase in the level of quality and safety would be gained by pressurizing these small bore vent and drain line segments when considering these line segments are not pressurized during normal system operation, (2) that structural integrity determines whether a structure is fit to withstand service conditions safely and reliably throughout its predicted lifetime and the VT-2 examinations offer reasonable assurance of line segment structural integrity, (3) that the possibility of spill, personnel contamination and increased radiation exposure would exist at SL-1 when attempting to depressurize and drain these line segments subsequent to completion of the system leakage test, and (4) that any welds as well as the bolted connections are visually examined. Therefore, the NRC staff accepts excluding the small bore Class 1 RCS vent and drain line segments from the required system leakage test pressure of ASME Code Case N-498-4 based on undue hardship without a corresponding increase in quality and safety.
4.1.2 Small Bore Class 1 Safety Injection/Shutdown Cooling Fill, Vent and Drain Lines FPL requested relief from Section (a)(2) of ASME Code Case N-498-4, to exclude Pressure-retaining components identified in Section 3.3.2 above from the system leakage test.
The subject components will remain in their normal operating configuration and will not be pressurized to RCS system pressure during the system leakage test, but will be examined at full operating pressures commensurate with their respective safety functions.
FPL stated that the SI and shutdown cooling fill (SCF), vent and drain lines are all statically pressurized during normal operation and are monitored for leakage by SIT pressure and level indications. In addition, the line segments are visually examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI system functional pressure test conducted at HPSI pump discharge pressure in accordance with the requirements of ASME Code,Section XI, IWA-5224(c) to examine systems at their highest operating pressure.
The NRC staff concludes, based on the preceding discussion, that the SI/SCF vent and drain lines are indirectly monitored for leakage throughout normal operation by pressure and level indications of the SIT and any pipe/weld/component leaking will be detected. Furthermore, visual examinations are performed on the subject line segments under augmented pressure conditions in accordance with ASME Code requirements providing an added method of leak detection and of judging structural integrity. Therefore, the NRC staff accepts excluding SI/SCF vent and drain line segments from the required system leakage test pressure of ASME Code Case N-498-4 and finds reasonable assurance that structural integrity will be maintained.
Temporary arrangements and substantial effort would be required to extend the boundary in order to achieve test pressures with no compensating increase in the level of quality and safety gained on these segments not designed to operate at RCS pressure.
4.1.3 Larger Bore Class 1 Safety Injection and Shutdown Cooling Piping Segments FPL requested relief from Section (a)(2) of ASME Code Case N-498-4, to exclude pressure retaining components identified in Section 3.3.3 above from the system leakage test. The
subject components will remain in their normal operating configuration and will not be pressurized to RCS system pressure during the system leakage test, but will be examined at full operating pressures equivalent with their respective safety functions.
(a) Hot Leg Shutdown Cooling Suction FPL states that the required interlock prevents manual opening of the valves from the Control Room with RCS pressure above the set-point and that the piping segments are VT-2 inspected through their entire length as part of the Class 1 system inspection at the conclusion of each refueling outage, as well as when the SCS is placed in service, in accordance with ASME Code,Section XI, IWA-5224(c). The system pressure test will not pressurize past the first isolation valve for this inspection; however, it is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. FPL states that no external or visible leakage will be allowed for the test to be acceptable and this test will provide assurance that the combined first and second isolation valves are effective in maintaining the RCPB at normal operating pressure and temperature.
The NRC staff concludes, based on the preceding discussion, that VT-2 examinations of the hot leg shutdown cooling suction line segments will provide reasonable assurance of structural/component/segment SCS integrity. In addition, overriding control-logic and administrative setpoints would create unusual difficulty and require violating organizational controls with no compensating increase in the level of quality and safety gained on these piping segments not designed to operate at RCS pressure. The lack of pressurizing past the first isolation valve is not necessary to determine whether the piping segment is fit to withstand its normal service conditions safely and reliably throughout its predicted lifetime. Therefore, the NRC staff accepts excluding hot leg shutdown cooling suction line segments from the required system leakage test pressure of ASME Code Case N-498-4.
(b) HPSI/LPSI Loop Header and SIT discharge piping FPL stated that the HPSI/LPSI and SIT discharge lines are all statically pressurized during normal operation and are monitored for leakage by SIT pressure and level indications. In addition, FPL states the lines are visually examined both during the RCS system leakage test as Class 1 boundary lines and during the HPSI system functional pressure test conducted at HPSI pump discharge pressure in accordance with the requirement of ASME Code,Section XI, IWA-5224(c) to examine systems at their highest operating pressure.
FPL states that leakage testing at RCS pressure would require a pressure source to be connected at each segment location by way of temporary piping connections and/or unusual temporary system configurations which would challenge both the header check valves and the loop check closure at the RCS connection. FPL notes, in doing so, the design requirement for two primary coolant pressure boundary isolation devices would be violated and for test locations overhead and away from normal personnel access areas, ladders or scaffolding would need to be installed to provide access to the piping segment and to open the valve leading to the occupational dose associated with leakage testing these lines.
FPL stated the lines are located in areas involving occupational radiation exposure and leakage testing of these lines would increase occupational radiation dose. Restoration of temporary configurations to normal operating conditions would be hazardous to personnel, lead to excess occupational dose and unnecessarily extend the outage.
The NRC staff concludes, based on the preceding discussion, that monitoring for leakage by SIT pressure/level indications and independent visual examinations would provide reasonable assurance of the HPSI/LPSI and SIT discharge line segment integrity. Overriding the design requirements for boundary isolation and installation/restoration of temporary designs would create unnecessary hardship and/or unusual difficulty with no compensating increase in the level of quality and safety gained on these piping segments not designed to operate at RCS pressure. Further, the possibility of spill, personnel contamination and increased radiation exposure would exist when attempting to access remote areas of these line segments.
Therefore, the NRC staff accepts excluding the HPSI/LPSI and SIT discharge lines from the required system leakage test pressure of ASME Code Case N-498-4.
5.0 CONCLUSION
The NRC staff determines that FPLs proposed system leakage test as discussed in RR-29 provides reasonable assurance of structural and component integrity. Complying with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes RR-29 described in FPLs letter dated March 22, 2007, for SL-1 for the remainder of the current third 10-year ISI interval, which ended February 10, 2008.
All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: David M. Tarantino Dated: March 4, 2008
Florida Power and Light Company ST. LUCIE PLANT cc:
Mr. Mano Nazar Mr. Christopher R. Costanzo Senior Vice President Plant General Manager and Nuclear Chief Operating Officer St. Lucie Nuclear Plant South Region 6351 South Ocean Drive Florida Power & Light Company Jensen Beach, Florida 34957 P.O. Box 14000 Juno Beach, FL 33408 Mr. Terry Patterson Licensing Manager Senior Resident Inspector St. Lucie Nuclear Plant St. Lucie Plant 6351 South Ocean Drive U.S. Nuclear Regulatory Commission Jensen Beach, Florida 34957 P.O. Box 6090 Jensen Beach, Florida 34957 Don E. Grissette Vice President, Nuclear Training Craig Fugate, Director and Performance Improvement Division of Emergency Preparedness Florida Power & Light Company Department of Community Affairs P.O. Box 14000 2740 Centerview Drive Juno Beach, FL 33408-0420 Tallahassee, Florida 32399-2100 Mr. Rajiv S. Kundalkar M. S. Ross, Managing Attorney Vice President - Nuclear Technical Services Florida Power & Light Company Florida Power & Light Company P.O. Box 14000 P.O. Box 14000 Juno Beach, FL 33408-0420 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Mr. J. Kammel Florida Power & Light Company Radiological Emergency 801 Pennsylvania Avenue, NW. Planning Administrator Suite 220 Department of Public Safety Washington, DC 20004 6000 Southeast Tower Drive Stuart, Florida 34997 Mr. Douglas Anderson County Administrator Mr. Bill Parks St. Lucie County Operations Manager 2300 Virginia Avenue St. Lucie Nuclear Plant Fort Pierce, Florida 34982 6351 South Ocean Drive Jensen Beach, Florida 34957-2000 Mr. William A. Passetti, Chief Department of Health Mr. Seth B. Duston Bureau of Radiation Control Training Manager 2020 Capital Circle, SE, Bin #C21 St. Lucie Nuclear Plant Tallahassee, Florida 32399-1741 6351 South Ocean Drive Jensen Beach, Florida 34957-2000 Mr. Gordon L. Johnston Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000