ML062290503

RAI, Regarding Steam Generator Tube Integrity Technical Specifications Amendment Request

ML062290503
Person / Time
Site:	Saint Lucie
Issue date:	08/22/2006
From:	Moroney B NRC/NRR/ADRO/DORL/LPLII-2
To:	Stall J Florida Power & Light Co
Moroney B, NRR/DORL, 415-3974
References
TAC MD1382
Download: ML062290503 (7)

Text

August 22, 2006 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE NUCLEAR PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT REQUEST (TAC NO. MD1382)

Dear Mr. Stall:

By letter dated April 24, 2006, Florida Power & Light Company requested an amendment to the St. Lucie Nuclear Plant, Unit 1, technical specifications (TSs) requirements regarding steam generator tube integrity, based on TS Task Force traveler TSTF-449.

The U.S. Nuclear Regulatory Commission staff has reviewed your request and finds that a response to the enclosed Request for Additional Information is needed before we can complete the review.

This request was discussed with members of your staff and on August 15, 2006, Mr. Ken Frehafer agreed that a response would be provided within 2 weeks of the date of this letter. If you have any questions, please contact me at (301) 415-3974.

Sincerely,

/RA/

Brendan T. Moroney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-335

Enclosure:

As stated cc w/encl: See next page

August 22, 2006 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE NUCLEAR PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT REQUEST (TAC NO. MD1382)

Dear Mr. Stall:

By letter dated April 24, 2006, Florida Power & Light Company requested an amendment to the St. Lucie Nuclear Plant, Unit 1, technical specifications (TSs) requirements regarding steam generator tube integrity, based on TS Task Force traveler TSTF-449.

The U.S. Nuclear Regulatory Commission staff has reviewed your request and finds that a response to the enclosed Request for Additional Information is needed before we can complete the review.

This request was discussed with members of your staff and on August 15, 2006, Mr. Ken Frehafer agreed that a response would be provided within 2 weeks of the date of this letter. If you have any questions, please contact me at (301) 415-3974.

Sincerely,

/RA/

Brendan T. Moroney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-335

Enclosure:

As stated cc w/encl: See next page Distribution:

PUBLIC LPL2-2 R/F RidsNrrPMBMoroney RidsNrrDorlLpl2-2 RidsNrrLABClayton RidsNrrDciCsgb RidsOgcRp RidsRgn2MailCenter RidsAcrsAcnwMailCenter RidsNrrDorlDpr YDiaz-Castillo, NRR KKarwoski, NRR ADAMS ACCESSION No.: ML062290503 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA CSGB/BC LPL2-2/BC NAME BMoroney BClayton AHiser LRaghavan by memo dated DATE 8/22/06 8/22/06 7/19/06 8/22/06 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION ST LUCIE NUCLEAR PLANT, UNIT NO. 1 STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT DOCKET NO. 50-335 By letter dated April 24, 2006, Florida Power & Light Company requested an amendment to the St. Lucie Nuclear Plant, Unit 1, technical specifications (TSs) requirements regarding steam generator tube integrity, based on TS Task Force traveler TSTF-449.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed this request and finds that the following additional information is needed to complete the review.

1. On page 13 of Attachment 2 of the submittal, the proposed revision to TS 3.4.6.1 adds the statement . . . per Surveillance Requirement 4.4.6.2.c . . . . under Actions a and b.

The purpose of adding this statement is not clear, since Surveillance Requirement (SR) 4.4.6.2.c has no additional details. In addition, the action statements require the reactor coolant system water inventory balance to be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, which appears to conflict with the 72-hour requirement stated in the current SR 4.4.6.2.c. Please explain the purpose of adding this statement or discuss your plans to remove it.

The remaining questions relate to the proposed TS Bases in Attachment 4 of the submittal.

2. The current Bases for TS 3/4.4.6.2 (shown on page 11) states that the dosage contribution from the tube leakage will be limited to a small fraction of Title 10, Code of Federal Regulations (10 CFR) Part 100 dose guideline values. The proposed revisions on pages 6 and 12 state that the dose consequences are within the limits of 10 CFR Part 100 and 10 CFR 50.67. Please clarify whether your current NRC-approved accident source term is based on Part 100 (as referenced in the current TS Bases),

10 CFR 50.67 or both?

3. On page 12, in the proposed insert to B3/4.4.6.2, there appear to be two words missing from the second sentence of the third paragraph. The sentence currently reads:

Therefore, monitoring reactor coolant leakage . . . The sentence should read:

Therefore, detecting and monitoring . . . . according to the Standard TSs. Please discuss your plans to add these two words to the proposed TS Bases.

4. On page 6, the last sentence of the second paragraph currently reads: . . . or the NRC approved licensing basis (e.g., a small fraction of these limits). However, on page 12, the same sentence appears in the last paragraph but the statement included in the parentheses is missing. Please discuss your plans to add this statement in this section.

Enclosure

5. There are several proposed changes to the Bases for TS 3/4.4.6, Reactor Coolant System Leakage, that go beyond TSTF-449. Please confirm that all of the proposed changes are consistent with your current NRC-approved design and licensing bases. If they are not consistent, please provide a technical justification for the differences or discuss your plans to remove them.

6. On page 9, the proposed Bases for TS 3.4.5, Actions a.1 and a.2, indicate that the affected tubes(s) must be plugged prior to entering HOT STANDBY. However, the corresponding requirement of TS 3.4.5 is to plug the tube(s) before entering HOT SHUTDOWN. Please discuss your plans to modify this statement.

7. Under Item d on page 13, there appears to be a typographical error in the first sentence. It appears that with should be within. Please discuss your plans to correct this error.

8. On page 14, the proposed Bases associated with TS 3.4.6.2, Action b, does not address the need to be in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in the event that unidentified or identified leakage cannot be reduced to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Please discuss your plans to modify the proposed Bases to address this issue.

Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:

Mr. William E. Webster Mr. Christopher R. Costanzo Vice President, Nuclear Operations Plant General Manager Florida Power & Light Company St. Lucie Nuclear Plant P.O. Box 14000 6351 South Ocean Drive Juno Beach, FL 33408-0420 Jensen Beach, Florida 34957 Senior Resident Inspector Mr. Terry Patterson St. Lucie Plant Licensing Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Craig Fugate, Director Mark Warner, Vice President Division of Emergency Preparedness Nuclear Operations Support Department of Community Affairs Florida Power & Light Company 2740 Centerview Drive P.O. Box 14000 Tallahassee, Florida 32399-2100 Juno Beach, FL 33408-0420 M. S. Ross, Managing Attorney Mr. Rajiv S. Kundalkar Florida Power & Light Company Vice President - Nuclear Engineering P.O. Box 14000 Florida Power & Light Company Juno Beach, FL 33408-0420 P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company Mr. J. Kammel 801 Pennsylvania Avenue, NW. Radiological Emergency Suite 220 Planning Administrator Washington, DC 20004 Department of Public Safety 6000 Southeast Tower Drive Mr. Douglas Anderson Stuart, Florida 34997 County Administrator St. Lucie County Mr. Bill Parks 2300 Virginia Avenue Operations Manager Fort Pierce, Florida 34982 St. Lucie Nuclear Plant 6351 South Ocean Drive Mr. William A. Passetti, Chief Jensen Beach, Florida 34957-2000 Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Gordon L. Johnston Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000