L-97-114, Provides Rev to 120-day response,L-97-18 Dtd 970128,to GL-96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Plant

Provides Rev to 120-day response,L-97-18 Dtd 970128,to GL-96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Plant

ML17229A311
Person / Time
Site:	Saint Lucie
Issue date:	04/22/1997
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-06, GL-96-6, L-97-114, N97-114, NUDOCS 9704250252
Download: ML17229A311 (6)

Text

CATEGORY 1 o'

REGULAT INFORMATION DISTRIBUTION TEM (RIDS)

ACCQJSI6N NBR:9704250252 DOC.DATE: 97/04/22 NOTARIZED: NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power

& Light Co.

50-'389 St. Lucie Plant, Unit 2, Florida Power

& Light Co.

AUTH.NAME, AUTHOR AFFILIATION STALL,J.A.--

Florida Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides rev to 120-day response,L-97-18 dtd 970128,to GL-96-06,."Assurance of Equipment Operability

& Containment Integrity During Design-Basis Accident Conditions," for plant.

DOCKET 05000335 05000389 DISTRIBUTION CODE:

A072D COPIES RECEIVED:LTR 1

ENCL 0 SIZE:

T TITLE: GL 96-06, "Assurance of Equip Oprblty

& Contain.Integ.

du ing Design E

NOTES:

RECIPIENT ID CODE/NAME NRR/WETZELIB.

WIENS,L.

INTERNAL. FILE CENTER SCSB EXTERNAL: NOAC COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD2-3 PD NRR/DE/EMEB NRR/DSSA/SPLB NRC PDR COPIES LTTR ENCL 0

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO.HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 9

ENCL

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DPI Florida Power &Light Company, 650t South Ocean Drive, Jensen Beach, FL 34957 April 22, 1997 L-97-114 10 CFR 50.4 10 CFR50. 54 (f)

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE:

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Revised Commitment Generic Letter 96-06 This letter provides a revision to the Florida Power & Light Company'(FPL) 120-day response, L-97-18 dated January 28, 1997, to NRC Generic Letter (GL) 96-06 "Assurance ofEquipment Operability and Containment Integrity During Design-Basis Accident Conditions" for St. Lucie Units 1 and 2.

The GL requested that within 120 days of September 30, 1996, FPL submit a written summary report stating the actions taken in response to the GL, the conclusions that were reached relative to susceptibility for water hammer and two-phase flow in the containment air cooler cooling water system and overpressurization of piping that penetrate containment, the basis for continued operability of the affected systems and components, and the corrective actions implemented or that are planned to be implemented. Ifsystems were found to be susceptible to the conditions that were discussed in the generic letter, FPL was to identify the systems affected and describe the specific circumstances involved.

FPL did not identify any piping susceptible to water hammer or two-phase flow in the containment air cooler cooling water system.

The evaluation did identify piping sections for containment penetrations and pipe sections inside containment that could be vulnerable to thermal overpressurization.

Each of the identified cases which provide containment integrity or other safety related functions were analyzed for functional operability using the basis of the acceptance criteria contained in ASME Section IIIAppendix F, Rules forEvaluatt'on ofService Loadings with Level D Service Limits, as provided for within NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability. The results indicated that all affected piping and valves within both units will remain functional with no violation of the pressure retaining boundary under accident conditions.

FPL considered the operability assessments contained in the summary report to be valid for the current operating cycle of each unit and ifnecessary, due to NRC review schedules, the next operating cycle of each unit.

The purpose of this letter is to revise FPL's planned corrective actions.

With respect to thermal overpressurization of isolated piping, FPL committed to submit a proposed license amendment to incorporate into the Updated Final Safety Analysis Report r

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'St. Lu'hie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-97-114 Page 2 (UFSAR), the methodology ofASME Section III, Appendix F for use in analyzing isolated piping sections in containment under post accident conditions. The proposed license amendment was scheduled to be submitted by April30, 1997.

During FPL's evaluation of GL 96-06, consideration was given to the implementation of several system modifications and/or procedure changes to drain piping sections to resolve the GL 96-06 issues of thermal overpressurization of isolated piping. FPL has further considered system modifications (e.g., rupture disks, accumulators, or thermal relief valves) and is committing to implement modifications and/or procedure changes in response to GL 96-06 in lieu of the previous commitment to submit a license amendment incorporating the methodology of ASME Section III, Appendix F into the St. Lucie Unit 1 and Unit 2 UFSARs.

This strategy would restore affected piping and supports to the criteria stated in the St. Lucie UFSARs.

With respect to completing modifications at the first practical opportunity, the St. Lucie Unit 2 Spring 1997 Refueling Outage (SL2-10) commenced on April 14, 1997.

It is not prudent to implement modifications during this outage since the design packages must be prepared, material procured, construction activities planned, scheduled and implemented.

This process cannot be performed in an effective and controlled manner prior to the restart from the Spring 1997 Refueling Outage.

Based on the scheduled completion of the Unit 2 Refueling Outage, implementation of the thermal overpressurization modifications are scheduled for the Fall 1998 Unit 2 Refueling Outage (SL2-11).

Procedure changes to drain specific piping sections willbe implemented prior to power ascension from the Spring 1997 Unit 2 refueling outage (SL2-10).

Similar modifications or procedure changes are scheduled for the Fall 1997 Unit 1 Refueling Outage (SL1-15).

FPL considers the operability assessments contained in the original submittal, L-97-18 dated January 28, 1997, to be valid for the current operating cycle (cycle 14) of Unit 1 and the next operating cycle (cycle 10) of Unit 2.

Please contact us if there are any questions about this submittal.

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/GRM cc:

Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant

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