ML20035H596
| ML20035H596 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-118, NUDOCS 9305060051 | |
| Download: ML20035H596 (13) | |
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May 3, 1993 POLICY ISSUE sect-93-ii8 (NEGATIVE CONSENT) l For:
The Commissioners From:
James H. Taylor Executive Director for Operations Sub.iect:
STATUS OF THE INDIVIDUAL PLANT EXAMINATION OF I
EXTERNAL EVENTS (IPEEE) i Purpose-I l
To inform the Commission of the status of the IPEEE program and the intent to i
allow a delay in submittals of IPEEEs until 1997.
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Backaround:
Supplement 4 to Generic Letter 88-20, issued on June 28, 1991, requested all licensees to perform IPEEEs on their plants. The Generic Letter requested all licensees to submit their plans and schedules for performing their IPEEE by December 1991. The staff reviewed licensees' submittal plans, and between June and September 1992 the staff issued its responses. The staff's responses considered both the Commission's plan to close severe accident-issues by 1995 and the delayed issuance of the Unresolved Safety Issue A-46 (Seismic Qualification of Equipment in Operating Plants) Supplemental Safety Evaluation Report. Based on these considerations, the staff extended the IPEEE submittal date to June 1995. The staff also requested certain licensees to resubmit l
their submittal plans by November 1992 because: (1) licensees' schedules extend beyond the June 1995 date which is needed to meet the Commission's goal; (2) certain licensees failed to identify selected methods or major milestones; or (3) certain licensees proposed unacceptable approaches.
The Commission was provided a status of these actions in SECY-92-363.
Discussion:
All licensees' revised IPEEE submittal plans, except Florida Power Corporation's, have been received and reviewed by the staff.
(Florida Power
Contact:
John Chen, RES NOTE: TO BE MADE PUBLICLY AVAILABLE WHEN 492-3919 THE FINAL SRM IS MADE AVAILABLE.
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I The Commissioners 2
Corporation's revised submittal plan is due in April /May 1993.)
Licensees' submittal schedules are provided in Enclosures 1-4.
Four IPEEE submittals already have been received by the staff (Enclosure 1). The following provides a brief discussion of the licensee responses.
1.
Schedule In sumary, licensees for 72 plants have indicated that they will meet the June 1995 date (Enclosure 2). Licensees for 38 plants have indicated that they will submit their IPEEE on schedules ranging from September 1995 to July 1997 (Enclosure 3). The licensees for these plants attribute their delays to one or more of the following:
a.
An intention to maximize the utilization of plant personnel, b.
Timing of refueling outages necessary for the walkdowns.
c.
Performance of multi-plant IPEEEs in series.
d.
The need to complete the internal events IPE.
e.
Coordination with USI A-46 program.
f.
1993/1994 financial restraint.
g.
Analyses planned beyond NRC specified scope.
h.
Schedule constrained by the planned steam generator replacement.
For example, Commonwealth Edison attributes its delay to: (1) the need to complete the internal event IPEs (June 1994 for Braidwood, April 1994 for Byron, and September 1993 for Quad Cities), (2) coordination with USI A-46 program (Quad Cities, Zion, and Dresden are USI A-46 plants), and (3) performance of multi-plant in series (Comonwealth Edison owns 12 plants and will perform 6 IPEEEs). All these reasons cited by Commonwealth Edison and other licensees listed in Enclosure 3 appear valid.
In addition, the staff notes that many licensees have expanded their currently ongoing IPE efforts to exceed the original envisioned objectives of the IPE program.
These include support of licensing actions, evaluation of design changes, prioritization of proposed plant improvement, and license renewal. Therefore, the staff believes that to grant schedule extensions of IPEEE submittals is reasonable and recommends that the Comission accept the schedules as proposed by the licensees. However, the Commission should note that accepting these schedules will result in an extension of the IPEEE closeout date from June 1995 to July 1997. However, the majority (72 out of 111) of the plants will have their IPEEE programs completed by June 1995 and significant benefit will have been gained by those licensees within the original timeframe.
The Comission should note that,- the licensee for Watts Bar 2 has indicated that the schedule for its IPEEE submittal will be determined before fuel load which is not certain at this time.
Furthermore, subsequent to receipt of their IPEEE Submittal plans, licensees for three plants have notified the staff that their plants will be permanently shutdown (Enclosure 4).
2.
Proposed Alternate Acoroaches All but nine licensees have proposed to use approaches described in NUREG-1407 for their IPEEEs. These nine licensees for 24 plants proposed to use alternate approaches for their seismic IPEEEs.
The staff has reviewed the
The Commissioners 3
proposed approaches, met with three of the nine licensees, and plans to meet with three other licensees in the May and June timeframe to discuss their proposed approaches. To date, the staff has found the approaches proposed by two licensees acceptable. A brief summary of the licensees' proposed approaches, staff's concerns, and anticipated licensee actions is provided in.
The staff will inform the Commission of the results of staff's additional review in a subsequent Commission update.
3.
IPEEE Submittal Review The staff, as mentioned in SECY-92-130, plans to use a 2-step process for the review of licensees' IPEEE submittals similar to that currently being used for the Individual Plant Examination Submittals.
During the Step 1 review, all licensees' IPEEE submittals will receive a short screening review. The objective is to perform an evaluation on the quality of the licensee's IPEEE process, and extract and store all important IPEEE insights.
In a Step 2 review, selected submittals will receive a more in-depth review. The objective of the Step 2 review is to evaluate the licensee's IPEEE process, methodology, and conclusions in more detail. To date, the staff has received four IPEEE submittals (Enclosure 1), and one of which (D. C. Cook) is presently undergoing a Step 1 review.
The staff will use contractors to support Step 2 reviews because of the constraints on the available resources.
In December 1992 the staff issued an announcement in the Commerce Business Daily soliciting proposals for providing such technical assistance.
Seven proposals have been received and are presently under staff evaluation.
Recommendation:
That the Commission note, unless otherwise instructed within 10 working days from the date of this paper, the staff intends to accept licensees' proposed IPEEE submittal schedules and extend the completion date of the licensees' IPEEE process from June 1995 to July 1997.
/
&X' smes M. Ta or Executive Director for Operations
Enclosures:
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1.
IPEEE Submittals Received 2.
IPEEE Submittal Scheduled by June 1995 3.
IPEEE Submittal Scheduled Beyond June 1995 4.
Planned Shutdown Plants 5.
Proposed Alternate Approaches i
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SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Tuesday, May 18, 1993 that the Commission, by negative consent, assents to the action proposed in this paper.
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IPEEE Submittal Received PLANT SUBMITTAL DATE REMARK SOUTH TEXAS 1 12/23/91 SOUTH TEXAS 2 12/23/91 MILLSTONE 3 12/23/91 COOK DC 1 04/30/92 COOK DC 2 04/30/92 SEABROOK 10/02/92 i
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IPEEE Submittal Scheduled by June 1995 ELANI SUBMITTAL DATE REMARK N
LASALLE 1 01/30/94 LASALLE 2 01/30/94 CATAWBA 1 06/28/94 CATAWBA 2 06/28/94 COOPER 06/28/94 CRYSTAL RIVER 3 06/28/94 Alternate Approach Proposed DIABLO CANYON 1 06/28/94 DIABLO CANYON 2 06/28/94 GRAND GULF 06/27/94 HADDAM NECK 06/27/94 KEWAUNEE 06/30/94 MCGUIRE 1 06/30/94 MCGUIRE 2 06/30/94 PILGRIM 07/01/94 RIVER BEND 06/28/94 SUSQUEHANNA 1 06/28/94 SUSQUEHANNA 2 06/28/94 TURKEY POINT 3 06/28/94 Alternate Approach Proposed TURKEY POINT 4 06/28/94 Alternate Approach Proposed PERRY 12/30/94 St. LUCIE 1 12/30/94 Alternate Approach Proposed St. LUCIE 2 12/30/94 Alternate Approach Proposed THREE MILE ISLAND 1 12/30/94***
WATERFORD 3 12/30/94 MONTICELLO 03/30/95 V0GTLE 1 03/30/95***
V0GTLE 2 03/30/95***
ARKANSAS 1 05/30/95 ARKANSAS 2 05/30/95 BIG ROCK POINT 05/21/95 R. E. GINNA 05/22/95 HOPE CREEK 1 05/30/95 SALEM 1 05/30/95 SALEM 2 05/30/95 BEAVER VALLEY 1 06/30/95 BRUNSWICK 1 06/30/95***
l BRUNSWICK 2 06/30/95***
CALLAWAY 06/30/95***
COMANCHE PEAK 1 06/30/95 COMANCHE PEAK 2 06/30/95 J. M. FARLEY 1 06/30/95 J. M. FARLEY 2 06/30/95 FERMI 2 06/30/95 FORT CALHOUN 06/30/95 HATCH 1 06/30/95 HATCH 2 06/30/95 i
LIMERICK 1 06/30/95 LIMERICK 2 06/30/95
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- MAINE YANKEE 06/30/95***
MILLSTONE 2 06/30/95 NINE MILE POINT 2 06/30/95***
0YSTER CREEK 06/30/95***
PALISADES 06/30/95 PALO VERDE 1 06/30/95 Alternate Approach Proposed PALO VERDE 2 06/30/95 Alternate Approach Proposed 4
PALO VERDE 3 06/30/95 Alternate Approach Proposed POINT BEACH 1 06/30/95 Alternate Approach Proposed POINT BEACH 2 06/30/95 Alternate Approach Proposed ROBINSON 06/30/95 SAN ON0FRE 2 06/30/95***
SAN ON0FRE 3 06/30/95***
SEQU0YAH 1 06/30/95***
SHEARON HARRIS 06/30/95***
VERMONT YANKEE 06/30/95***
WATTS BAR 1 06/30/95***
WNP-2 06/30/95 WOLF CREEK 06/30/95***
- Schedules improved significantly to meet June 1995 date.
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IPEEE Submittal Scheduled Beyond June 1995 Elg_1 SUBMITTAL DATE DELAY RATIONALE
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CLINTON 09/30/95 a, d, & f DAVIS BESSE 09/30/95 a, b, & e INDIAN' POINT 2 09/30/95 e
DUANE ARNOLD 11/30/95 b&e PEACH BOTTOM 1 11/30/95 a, b, c, & e PEACH BOTTOM 2 11/30/95 a, b, c, & e SEQUOYAH 2 11/30/95**
b FITZPATRICK 12/30/95 a, b, & d NORTH ANNA 1 12/30/95 b&e NORTH ANNA 2 12/30/95 b&e i
OCONEE 1 12/30/95 e
OCONEE 2 12/30/95 e
OCONEE 3 12/30/95 e
SURRY 1 05/30/96 b&e SURRY 2 05/30/96 b&e BYRON 1 06/30/96 c, d, & e BYRON 2 06/30/96' c, d, & e CALVERT CLIFF 1 06/30/96 a, b, d, & e CALVERT CLIFF 2 06/30/96 a, b, d, & e
.DRESDEN 2 -
06/30/96 c, d, & e
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DRESDEN 3 06/30/96 c, d, & e MILLSTONE 1 06/30/96-a, c, d, & e l
ZION 1 06/30/96 c, d, & e ZION 2 06/30/96 c, d, & e BROWNS FERRY I 07/30/96 a, b, e, & Restart of BF 1 BROWNS FERRY 2 07/30/96 a, b, e, & Restart of BF 1 BROWNS FERRY 3 07/30/96 a, b, e, & Restart of BF 1 NINE MILE POINT 1 08/30/96 a,c,d,&g SUMMER VC 10/30/96**
b & h' INDIAN POINT 3 12/30/96 a, b, & d
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PRAIRIE ISLAND 1 12/30/96**
a, c, d, f, & g PRAIRIE ISLAND 2 12/30/96**
a,c,d,f,&g QUAD CITIES 1 12/30/96 c, d, & e i
'The licensees' rationale for the delay-is attributed to one or more of the'following:
- a. An: intention to maximize utilization of plant personnel
- b. Timing of refueling outages necessary for the walkdowns
- c. Performance of multi-plant IPEEEs in series
- d. The need to complete the internal events IPE o
- e. Coordination with USI A-46 program
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- f. 1993/1994 financial restraint
- g. Analyses planned beyond NRC specified scope
- h. Schedule constrained by steam generator replacement i
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' QUAD CITIES 2 12/30/96 c, d, & e BRAIDWOOD 1 06/30/97 c, d, & e BRAIDWOOD 2 06/30/97 c, d, & e BEAVER VALLEY 2 07/30/97 c & Using BV1 Results WATTS BAR 2 TBD Schedules improved from original proposed dates.
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Planned Shutdown Plants PLANT SUBMITTAL DATE PLANNED SHUTDOWN DATE SAN ON0FRE 1 06/28/97 TROJAN 06/28/94 YANKEE R0WE 12/23/91 Note: Since submitting their IPEEE plans and schedules, the licensees for those plants have informed the NRC that they plan to permanently shutdown those plants.
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Proposed Alternate Approaches All but nine licensees have proposed to use approaches described in NUREG-1407 for their IPEEEs.
These nine licensees for 24 plants proposed to use alternate approaches for their seismic IPEEEs. The staff has reviewed those submittals, met with three licensees, and plans to meet with three additional licensees to discuss their proposed approaches. To date, the staff has found that the approaches proposed by two licensees acceptable. The following discussions briefly summarize those proposed approaches, staff's concerns, and anticipated licensee actions.
2.1 Dresden Station Units 2 and 3 Quad Cities Station Units 1 and 2 Zion Station Units 1 and 2 Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Commonwealth Edison's submittal, dated September 18, 1992, indicated that an alternative approach will be used for its IPEEEs.
However, the licensee did not provide enough details in its supporting documentation to allow NRC to determine whether the proposed approach is acceptable.
At the meeting of October 15, 1992, the licensee indicated that an alternative approach for the IPEEE was in the process of being developed and additional information would be provided in March 1993 for NRC review.
Commonwealth Edison informed NRC on April 15, 1993 that it will not be ready to discuss this issue until August 1993.
2.2 Crystal River Unit 3 In the staff's response to Florida Power Corp. (FPC), dated September 4, 1992, the staff stated that the FPC proposed approach was not acceptable and requested FPC to update and resubmit its IPEEE plan consistent with the Generic Letter 88-20, Supplement 4.
The new submittal should specifically discuss the project milestones, schedule, and methods selected for the seismic and high winds, floods, and transportation and nearby facility accidents (HFOS) IPEEEs. The licensee's revised IPEEE submittal plan was submitted on April 16, 1993 and is currently under staff review.
2.3 Point Beach Units I and 2 In the staff's response to Wisconsin Electric (WE) Power Company, dated July 14, 1992, the staff stated that the use of only the EPRI curve for the seismic IPEEE was not acceptable.
In a letter to NRC, dated September 11, 1992, the licensee insisted on using.only the EPRI curve for the seismic IPEEE, but failed to provide adequate supporting documentation to justify such a deviation.
In addition, the licensee planned scope for the seismic IPEEE appears to be less than that specified in NUREG-1407. The staff plans to meet with the licensee in May/ June to resolve these differences.
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2.4 Palo Verde Units 1, 2, and 3 Arizona Public Service Co. (APSC) requested that the seismic review level earthquake (RLE)-for the Palo Verde plant site be modified from 0.5g to 0.39 The staff reviewed APSC's submittals and found that the information provided was not adequate to justify such a reduction. The staff's request for additional information was issued to the licensee on February 9, 1993. A meeting was held on February 22, 1993 to discuss and clarify where necessary the staff's request. The licensee's response is expected in May.
2.5 Turkey Point Units 3 and 4 St. Lucie Units 1 and 2 Florida Power and Lights indicated that a proprietary site specific seismic program dealing with USI A-46 issue will be used to perform the seismic IPEEE. This information was submitted to NRC in July 1991. The staff is in the process of reviewing this information to determine its acceptability for USI A-46.
For those plants in the reduced-scope category, such as is Turkey Point and St. Lucie, the staff considers that an approach acceptable for USI A-46 is also acceptable for seismic IPEEE.
2.6 Big Rock Point Consumers Power stated in November 1991 that some of the issues identified in the Generic letter 88-20, Supplement 4, were adequately addressed for its plants during the Systematic Evaluation Program (SEP) and planned no further analyses or submittals on those issues.
In the staff's response to Consumers Power, dated July 30, 1992, the staff stated that licensee is encouraged to use the SEP results as a base and build the IPEEE on it. A meeting was held in September 1992 to discuss in detail the licensee's past efforts related to external event examinations and to identify additional actions required to meet the IPEEE objectives.
In a letter to NRC, dated October 1, 1992, the licensee summarized those actions. The staff finds the licensee's proposal acceptable.
i 2.7 Ginna In the staff's response to Rochester Gas and Electric Corporation, dated June 30,1992, the staff stated that the licensee is encouraged to use the SEP results as a base and build the IPEEE on it. Accordingly, the licensee should evaluate its SEP data and reports to determine whether i
the external event examinations specified in NUREG-1407 were performed i
previously.
If the licensee concludes that these examinations, performed as part of SEP review and represented the current as-built and as-operated condition of its plant, the licensee only needs to identify where in the SEP reports the information requested in the IPEEE can be found.
In letter to NRC, dated November 3,1992, the licensee _ indicated i
that it plans to use a Level 1 PRA for. fire IPEEE and to use the i
screening approach described in NUREG-1407 for high winds, floods, and i
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3 transportation and nearby facility accidents.
In an earlier letter to NRC, dated September 21, 1992, the licensee indicated that it will submit its IPEEE report on May 22, 1995. The staff finds the licensee's approach in these areas acceptable. However, in the same letter, the licensee also indicated that it plans to use an " expanded" A-46 program for its seismic IPEEE. At this time, the staff has not found this approach acceptable because of lacking supporting documentation, and plans to meet with the licensee in May or June to discuss this matter further.
2.8 Davis Besse In the staff's response to Centerior Energy, dated August 11, 1992, the staff requested that the licensee provide a submittal schedule for its seismic IPEEE, and to identify specifically the methods to be used for its IPEEE.
In a letter response to NRC, dated September 18, 1992, the licensee has provided the submittal schedule and identified the methods to be used for its IPEEE. The staff finds the proposed schedule and methods acceptable.
2.9 Vermont Yankee As indicated in the licensee's new submittal plan, dated September 18, 1992, the. licensee plans to submit its IPEEE report on June 30, 1995, and plans to use a Level 1 PRA for fire IPEEE. The licensee also plans to use the screening approach described in NUREG-1407 for high winds, floods, and transportation and nearby facility accidents. The staff finds these methods acceptable. However, the licensee also indicated that it plans to use a walkdown-based approach to address seismic events, and to provide the details of the approach to the NRC as'they are developed and finalized, but no later than three months prior to the plant walkdowns. Therefore, at this time, the staff is unable to determine whether the proposed approach is acceptable and plans to meet with the licensee in May or June to discuss this matter further.
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