L-2006-076, Comment (14) Submitted by Florida Power and Light Company, J.A. Stall on Proposed Rule PR-50, Risk-Informed Changes to Loss-of-Coolant-Accident Technical Requirements

Comment (14) Submitted by Florida Power and Light Company, J.A. Stall on Proposed Rule PR-50, Risk-Informed Changes to Loss-of-Coolant-Accident Technical Requirements

ML060750636
Person / Time
Site:	Saint Lucie, Seabrook, Turkey Point, Duane Arnold
Issue date:	03/15/2006
From:	Stall J Florida Power & Light Co
To:	NRC/SECY
Ngbea E S
References
70FR67598 00014, L-2006-076, PR-50, RIN 3150-AH29
Download: ML060750636 (2)

Text

Mar-15-06 03:00pm From-JPN ENGINEER+4G 561 -694-5090 T-887 P-001/002 F-078 I

Florlda Po ler& Ught Company,700 Universe Boulevard, P.O. Boxl4000,Juno Beach, FL33408-0420 0 i -March 15, 2006 ( 14 F=PL L-2006-076 DOCKETED USNRC Secretary ) March 15, 2006 (2:32pm)

U.S. Nuclear Regulatory Commission Washington, DC 20555-0O01 OFFICE OF SECRETARY-RULEMAKINGS AND ATTN: Rulemakings and Adjudications Staff ADJUDICATIONS STAFF

SUBJECT:

Comments dn Proposed Rule 10 CFR Part 50, RIN 3150-AH29, Risk-Inforrnmd Changes to Loss-of-Coolant-Accident Technical Requirements (70 Federal Register67598, November 7, 2005)

REFERENCES:

1) A. Pietrangelo (NEI) to USNRC, dated March 1, 2006, uComments on Proposed Rule 10 CFR Part 50, RIN 3150-AH29, Risk-Informed Changes to Loss-of-Coolant-Accident Technical Requirements (70 FedSralRegister 67598, November 7, 2005)"

2) J. C nen (BWROCG) to USNRC, dated March 6,2006, 'Comments on Ptoposed Rule, Risk-informed Changes to Loss-of-Coolant Accident Technical Requirements, 70 FR 67598'

3) T. S~hiffley (WOG) to USNRC, dated March 8, 2006, URIN 3150-AH29, Risk-Informed Changes to Loss-of-CoolantAccident Technical Requirements, Westinghouse Owners Group Comments on Draft Rule Change, (MUHP-3062)'

Florida Power & Light CoLpany (FPL), FPL Energy Seabrook, LLC and FPL Energy Duane Arnold, LLC appreciate the opportunity to comment on the subject rulemaking.

This rulemaking marks ah important step in the continuing efforts to apply risk Insights into the regulatory process. Because of its importance in sdtting the stage for future risk-informed changes to the technical requirements in 10 CFR Part 50, FPL encourages the Staff to work closely End openly with the industry and to capture the lessons learned" from the previous voluntary risk-Informed rulemaking on Special Treatments Requirements (10 CFR 6b.69).

In addition to endDrsing the industry comments submitted in the referenced letters, FPL provides the following comnments on the proposed rule.

The central premise of thp proposed rule is good; that overall plant safety would be Improved by the applicatibn of resources to more risk-significant plant events than the current design basis large break loss-of-coolant accident (LBLOCA). However, as currently drafted, the additional regulatory burdens imposed by the Risk-informed Integrated Safety Assessnrent Process (RISP) are impractical to implement. This includes the additional operational constraints placed upon the equipment credited to mitigate this new "beyond design basis LBLOCA that preclude the current flexibility for performing on-line maintenance under 10 CFR 50.65. FPL also believes that the an FPL Group company ren/ pge6 7

Mar-15-06 03:00pm From-JPN ENGINEER14G 561-694-5000 T-87 P.002/002 F-079 L-2006-076 Page 2 of 2 transition break size (TBS) for defining the new "beyond design basis" LBLOCA Is too conservative. In its currer t form, FPL would not be inclined to implement the voluntary rule.

We encourage the Staff f4 continue to work with NEI and the various Owners' Groups to resolve these problems with the current draft rule language, so that ultimately licensees will want to adopt this volintary rule and take advantage of the potential safety benefits originally envisioned by tie Commission in SECY-98-300, "Options for Risk-informed Revisions to 10 CFR Part 50- Domestic Licensing of Production and Utilization Facilities."

Sincerely, Senior Vice President, Nuclear and Chief Nuclear Officer