ML17349A372

Describes Seismic Program to Comply W/Suppl 4 to GL 88-20, IPEEE for Severe Accident Vulnerabilities, Per NRC 920625 Ltr.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 DISTRIBUTION DEMONSTRATION SYSTEM REGULAT INFORMATION DISTRIBUTIQ YSTEM (RIDS) t ACQESS ION NBR: 920'V100020 DOC. DATE: 92/08/31 NQTAR IZED: YES DOCKET 0 FACIL: 50-250 Turkey Point Planti Unit DI Florida Power and Light C 05000250 50-251 Turkey Point Planti Unit %I Florida Power and Light C 05000251 AUTH. NAME BQHLKE> W. H.

'UTHOR AFFILIATION Florida Power 8c Light Co.

REC I P. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

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.

DISTRIBUTION CODE: AOIID COPIES RECEIVED: LTR ENCL 1 SIZE:

TITLE: Generic Ltr 88-20 re Individual Plant Evaluations NOTES: NRR RAGHAVANIL 05000256 NRR RAGHAVANIL 05000251 REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME 'TTR ENCL PD2-2 PD 1 1 AUL'UCKi R 1 1 INTERNAL: ACRS HOUSTONI M. 1 1 AEOD/DSP/TPAB NRR HER NANI 1 NRR/DREP/PRAB 1 1 2

R.'EG 1 1 1 REG 1 1 REG 1 1 REG 4 1 1 FILE 1 1 RES FL*CKIJ. 6 6 CAELLi J. 1 1 RES/DSIR/SAIB/B 7 7 EXTERNAL: NRC PDR 1 1 NSIC NOTES:

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM PI-37 (EXT. 504-'2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 28

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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 comments, on December 13, 1989 (FPL Letter L-89-441) ~

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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 describes the FPL Seismic Program, we request that also be withheld from public disclosure in accordance with 10 CFR it 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 modifications can be made to to the reduce reactor the core risk.

if cost effective 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 Shutdown Earthquake (SSE) if there is an earthquake at the Safe 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 earthquake at the SSE level.

if there is an 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, Seismic it is FPL's position that the FPL 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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AFFIDAVIT STATE OF FLORIDA )

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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%.

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NOTARY PUBLIC, Palm Beach, State i order 'and,for the County of of Florida 1g Notary Pubiic, State of Florida My Comm. Exp. Fcb. 18, 1995 BondedthruPtCHAft~tns."gency My COmmiSSiOn eXpireS Cow w,do- b 8geog

AFFIDAVIT State of Florida County of Palm Beach W. H. Bohlke being first duly sworn, deposes and says the following:

I am the Vice President Nuclear Engineering and Licensing of Florida Power and Light (FPL) Company, the Licensee herein.

2. 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.

3. The statements made in this affidavit are true and correct to the best of my knowledge, information, and belief.

4 ~ 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, s~h State of Florida Notary Public, State of Florida h'ly Comm. Exp. Feb. 18, 1995 My Commission expires: Bondso thru PICtfARD Ins. Agency Corns. Qo. npgb>

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ATTACHMENT1 THE ATTACHMENT IS SUBMITTEDAS PROPRIETARY UNDER THE PROVSIONS 1 IW FR 2.790 COMPARSON OF CRllERIA CONTAINEDIN GENERIC LETTER (GL) 8820 SUPPLEMENT4/NUREG1 407 WITH FPL (PROPRIETARY) SITE SPECIFIC SESMIC SSUE RESOLUllON PROGRAM (FPL SESMIC PROGRAM)

GENERIC lETTER (GL) 88-20 FPL SESMIC PROPOSED MODIFICATIONSTO FPL SESMIC PROGRAM TO ADDRESS SUPPLEMENT 4/NUREG-1407 PROGRAM GL 8820 SUPPLEMENT 4/NUREG-1407 A Operational Criterh 1 Equipment to Achieve and Maintain Hot Shutdovm a) lnstruments8 Control The GL 8 NUREG Do Not Contah The FPL Seismic Program 1) None- See Discussion Below b) Chemical &Volume Any Specilic Equipment Usta Contahs Specifi Equipment a) FPLs Seismic Program also Assumes Loss of Olf Site Power Due to the Control But They: Usta for Equipment to Seismic events theResulting Need tousethePhnt EmergencyPower Systems.

c) Heat Removal Achieve & Maintain Hot b) The GL 8 NUREG do not Specify Loss of Off Ste Power.

Capability 1) Refer to the Objective of Shutdown per Items a) c) FPL Considersits Program to be More Conservative and an enhancement to d) Electrical Power Achieving 8 Maintaining Hot through d) Inclusive and to the GL and NUREG.

Supply Shutdown address reactor subcrtticafity and early emergency core

2) Refer to the Objective of coofing.

Addressing Reactor Subcriticality

3) Refer to the Objective of Addressing Early Emergency Core Coofing 2 Initial Rant Status FuI Power Operating Conditions 1) None 3 Maximum Maintenance 72 Hours 8 Hours 1) None- See Discussion Below of Hot Shutdovm a) FPLs Programs to Implement the Station Bhckout Rule Provide for no more than 8 Hours at Hot Shutdown 8 have been Accepted by NRC/SER.

b) 8 Hours is Consistent with FPLs Rant Technical Specificalions.

4 Considerationof Non- NotRequestedforReducedScope None 1) None- See DiscussingBehw Design Basis Accidents Phnts a) Reduced Scope Phnts do not have to consider seismically induced LOCAs, fires, floods, HELBS and mitigating systems.

5 Consideration of 1) Passive Mechanical and NSSS None 1) None- See DiscussionBelow Failures 2) NonSelsmic a) Cannot be jusfified due to technical and economic considerations.

3) Human

2 GENERIC LEVIER (GL) 88-20 SUPPLEMENT 4/NUREG-1407 FPL SEISMIC PROGRAM GL ~

PROPOSED MODIFICATIONSTO FPL SEISMIC PROGRAM TO ADDRESS SUPPLEMENT4/NUREG-1407 B Programmatic Criteria 1 LIcensee StaN Included 1) None Participation 2 Perform Pre-Walk Dovm Included 1) None Investigations 3 Provide a Success Path Included 1) None For Equipment 4 Provide an Alternative Requested Not Included 1) None- See DiscussionBelow Success Path for a) FPLs Seismic Program Provides that Concerns Related to Equipment in Equipment the Success Path will be Checkedin the Other Train of Equipment.

5 Outliers Requested to be Evaluated Evaluated Per Normal 1) None- See DiscussionBelow Per SQUG/GIP Procedures Plant Procedures Addressing a) FPL is not a Member of SQUG 8 does not have Accessto the Potentially Non-Conforming (Proprietary) GIP Procedures.

Conditions 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 lf Required.

6 Peer Review Induded 1) None

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3 GENERIC LETTER (GL) 88-20 SUPPLEMENT 4/NUREG-1407 FPL SEISMIC PROGRAM GL ~

PROPOSED MODIFICATIONSTO FPL SEISMIC PROGRAM TO ADDRESS SUPPLEMENT 4/NUREG-1407 C Technical Criterh 1 Seismic Input Safe Shutdovm Earthquake (SSE) Same 1) None Ground Response Spectra & In-Structure Spectra 2 Wrench Tightness Checks Not Requested Not Induded 1) None For Anchor Bolts 3 Rehy Chatter Evaluation Not Requested Not Induded 1) None 4 Soih Review Not Requested Not Induded 1) None 5 Equipment FragiMes Requested to be Evahated Per Evahated Per SSRAP 1) None- See DIscussionBelow SQUG/GIP Procedures Bounding Spectra Pmcedures a) FPL is not a Member of SQUG &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 of the GIP d) SSRAP had NRC Membership 6 Containment 8 Containment Not Requested Not Induded 1) None Systems Review D Documentation Criteria 1 Waikdown Documentation Format Per EPRI NP4041 Rants'nduded Format for Reduced Scope 1) None E Other Issue Resokrtion Criteria 1 Seismic Adequacy of Decay Requested Induded (See Item A.1.c.) 1) None Heat Removal Equipment (USI A-45) 2 Seismic Spatial Systems Requested (Rping/Iubing/ Induded 1) None Interactions (USI A-17) Structures) 3 Seismic Design Criteria Not Requested Induded 1) This Item Only Induded at Turkey Point Units 3 &4, &

For Large Tanks SL Lucie Unit 1.

(USI AM) 2) St. Lucie Unit 2 is Exempted Per NUREG - 1233 (September 1889) 4 Seismic Interaction of Not Induded 1) This Issue wi8 be Induded in the Resolution of GL 88-20 Westinghouse ln-Core as a Separate Item from the FPL Seismic Program Rux Mapping System Components

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