ML17349A284

Discusses Review of Response to Generic Ltr 88-20,suppl 4,re Ipeee.Alternate Methods Proposed in 911223 Response Acceptable

ML17349A284
Person / Time
Site:	Turkey Point, Saint Lucie
Issue date:	06/25/1992
From:	Norris J, Raghavan L Office of Nuclear Reactor Regulation
To:	Goldberg J FLORIDA POWER & LIGHT CO.
References
GL-88-20, TAC-M83637, TAC-M83638, TAC-M83678, TAC-M83679, NUDOCS 9207060054
Download: ML17349A284 (5)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555 June 25, 1992 Docket Nos. 50-250, 50-251 and 50-335, 50-389 Hr. J.

H. Goldberg President - Nuclear Division Florida Power and Light Company P. 0.

Box 14000 Juno

Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND 4 AND ST.

LUCIE UNITS 1

AND 2 REVIEW OF

RESPONSE

TO GENERIC LETTER NO. 88-20, SUPPLEMENT NO.

4 INDIVIDUAL PLANT EXAMINATIONS FOR EXTERNAL EVENTS (TAC NOS.

H83637, H83638, H83678 AND M83679)

Supplement 4 to Generic Letter 88-20 was issued on June 28, 1991, to require each licensee and each Construction Permit holder to conduct an individual plant examination of external events (IPEEE).

Guidance was provided with the generic letter supplement in the form of NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities."

The supplement requested a 180-day response (December 26, 1991) that would (1) identify the method and approach selected for the

IPEEE, (2) describe the method to be used if it has not previously been submitted for staff review, and (3) identify the milestones and schedule for performing the IPEEE and submittal of the results to the NRC.

Licensees were requested in the supplement to submit the IPEEE results to the NRC for review by June 28, 1994 (3 years after issuance of the supplement),

to ensure that the intent of the Commission's Severe Accident Policy Statement will be met by mid-1995.

We have reviewed your letter dated December 23,

1991, submitted in response to Generic Letter 88-20, Supplement 4.

You proposed alternate methods to satisfy the IPEEE requirements for your plant as compared to the methods described in Supplement 4 and in NUREG-1407.

acceptable.

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92070b0054 920b25 PDR ADOCK, 05000250 P

PDR You indicated in your submittal dated December 23, 1991, that:

(1) you intend to use the Electric Power Research Institute (EPRI) Fire Vulnerability Evalua-tion (FIVE) methodology for the treatment of fire in the IPEEE for St. Lucie, Units 1 and 2, and you have already submitted the fire evaluation for Turkey Point (in 1991 Turkey Point IPE submittal),

and (2) you intend to use the progressive screening approach specified in NUREG-1407 to identify potential vulnerabilities due to high winds, external

floods, and transportation and nearby facility accidents for St. Lucie.

You will also use this approach to address potential vulnerabilities from tornadoes and transportation and nearby facility accidents for Turkey Point.

The hurricane and external floods analyses for Turkey Point were included in the Turkey Point IPE submittal.

In addition, the effects of lightning strikes at these sites will be examined in accordance with NUREG-1407.

These methods are

Hr. J.

H. Goldberg June 25, 1992 You also indicated in your submittal that you intend to use the results of a proprietary site-specific program associated with USI A-46 (Generic Letter 87-02, "Verification of Seismic Adequacy of Hechanical and Electrical Equipment in Operating Reactors" ) to meet the requirements of the seismic IPEEE.

However, you did not provide any specific information about this proposed program for NRC to determine whether the proposed approach is acceptable.

The letter L-91-185, cited in your submittal, provides only the information on the results of a probabilistic seismic hazard evaluation performed for St. Lucie and Turkey Point, but did not discuss how the seismic IPEEE as specified in NUREG-1407 will be addressed.

Please provide your supporting documentation on your proposed program to the NRC within 60 days of the date of this correspondence.

We would like to point out that the purpose of the IPEEE (to systematically look for cost-effective plant improvements that could help prevent or mitigate severe accidents) is different from that of USI A-46.

The scope of the IPEEE is broader than that of USI A-46.

The USI A-46 walkdown effort needs to be expanded to cover those systems and equipment needed for the IPEEE but not required for USI A-46.

However, the information obtained through the implementation of USI A-46 program does have significant value, and you are encouraged to use the results of USI A-46 either to build your IPEEE on or to combine USI A-46 and IPEEE seismic walkdowns.

For more detailed discussions related to these

issues, please refer to NUREG-1407 (see Sections 3.2.4 and 6.3.3.3, and Appendix B).

Please also note that the staff issued the Supplemental Safety Evaluation Report (SSER) approving the USI A-46 Generic Implementation Procedure (GIP) on Hay 22, 1992 (Supplement 1 to Generic Letter 87-02).

The information requested by this letter is within the scope of the overall burden estimated in Supplement 4 to Generic Letter 88-20 for the IPEEE

program, which was a maximum of 6 person-years per licensee response over a

3-year period.

This request is covered by Office of Hanagement and Budget Clearance Number 3150-0011, which expires Hay 31, 1994.

If additional clarification of this reply is needed, the staff is available to meet with you.

(Original Signed By)

Jan A. Norris, Sr. Project Hanager

" Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:

See next page DISTRIBUTION See next page Sincerely, (Original Signed By)

L. Raghavan, Acting Project Hanager Project Directorate II-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation L

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DISTRIBUTION FOR IPEEE LETTER FOR ST.

LUCIE AND TURKEY POINT Docket File NRC 8 Local PDRs PD22 Rdg SVarga GLainas HBerkow LRaghavan JNorris DHiller ACRS (10)

OGC HSinkule, RII CAder JChen RHernan

Florida Power and Light Company cc:

Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.

Hwy AIA Jensen

Beach, Florida 33457 Mr. Robert G. Nave, Director Emergency Management Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Harold F. Reis, Esq.

Newman

& Holtzinger 1615 L Street, N.W.

Washington, DC 20036 John T. Butler, Esq.

Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. James V. Chisolm, County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering, Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 Mr. Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Regional Administrator, RII U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Mr. R.

E. Grazio Director, Nuclear Licensing Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420 Mr. J.

H. Goldberg President Nuclear Division Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420 Harold F. Reis, Esq.

Newman and Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 Mr. Thomas F. Plunkett, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 Senior Resident Inspector Tur key Point Nuclear Generating Station U.S. Nuclear Regulatory Commission P.O.

Box 1448 Homestead, Florida 33090 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Joaquin Avino, Cty. Manager of Metro.

Dade County 111 NW 1st Street, 29th Floor Miami, Florida 33128