ML17215A731
| ML17215A731 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/07/1984 |
| From: | John Miller Office of Nuclear Reactor Regulation |
| To: | Williams J FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8501080488 | |
| Download: ML17215A731 (6) | |
Text
December 7,
1984 Docket File NRC 5 L PDRs PKreutzer.
EJordan JPartlow Distribution:
Reading File Gray File DSells PMcKee ACRS 10, DEisenhut.
Docket Nos.
50-335 and 50-389 0@LD This request is a follow-up to discussions with members of your staff to clarify questions raised earlier in the review.
In order to complete this review by mid-January 1985, it is requested that you provide your response by December 28, 1984.
If you have any questions, contact the project manager D. Sells, at (301) 492-9735.
This request for additional information affects fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely
/r James R. Miller, Chief Operating Reactors Branch No.
3 Division of Licensing
Enclosure:
As stated cc w/enclosure:
See next page Mr. J.
W. Williams, Jr.
Vice Pres ide'nt Nuclear Energy Department FloridaEPower 8 Light Company P. 0.
Box 14000 Juno Beach, Florida,'3408 I
Dear Mr. Williams:
SUBJECT:
RE(VEST FOR ADDITIONAL'INFORMATION AND CLARIFICATION OF LICENSE AMENDMENT APPLICATIONS I
I Et During the course of the staff's review of your applications for amendments (letters'L-84-129 and L-84-130) to the operating licenses of St. Lucie Plant, Unit Nos.
1 and 2, the NRC 'reviewer has identified areas where additional information or clarification is required in order to complete the review.
ORB83gDL Pl+1ftzer g /g /84 0
3:DL D el';ef (g/y/84 R
DL ilier
/84 850i080488 84i207 PDR ADOCK 05000335 P
-b>>, R>>R
Vl bci ui I
h bb)
I f ff
~ $
'I
/
$ P~) j
'I, ff
~
R QQIV v II 1
fl
'fu>>
Ifu f
, t
)('"'LJ',
)b' If >> h "bu If, 1 h>>f J>>
flu J 1
p v
I v I I
v
~ ) ">>
u
'u INJ I
~
I" 1
>>)>>
~ V J
g 1
1
>> Vff II
)
~'Jl,'>>f QR)
'R ug
>> If VP" fl
>> ~
)lf
'Jvul' If
)
I
',",Ru
~ jfb g,b
~ VI g)>>>> )
)
v~
~
v)
P 1
I )
g tl ~
Vl,
II'l
.s'Florida Power 5 Light Company CC:
1 Harold F. Reis, Esquire Newman
& Holtzinger 1615 L Street, N.
W.
Wash'ington, DC 20036 Norman A. Coll, Esquire
. McCa rthy, Steel, Hector and Da vi s
'4th Floor, First National Bank Building Miami, Florida 33131 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301
~ Mr.'. Veldon B. Lewis County Admin'istrator St. Lucie County 2300 Yirginia Avenue, Room 104 Fort Pierce, Florida 33450 U.S.
Environmental Protection Agency Region IV Office ATTN:
Regional Radiation Representative 345 Courtland Street, NE Atlanta, Georgia 30308 Mr. Charles B. Brinkman Manager - Washington Nuclear Operations C-E Power Systems Combustion Engineerina, Inc.
7910 Woodmont Avenue
- Bethesda, Maryland 20014 Regional Administrator Nuclear Regulatory Commission Region II Office of Executive Director. for Operations 101 Marietta Street N.W., Suite 2900
- Atlanta, Georgia 30323 Mr. Jack Schrewe Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Resident Inspect tor c/o U.S.
NRC Senior Resident Inspector 7585 S.
Hwy AIR Jensen Beach, Florida 33457 State Planning-h Development Cl ea ringhouse Office of Planrning 5 Budget Executive Office of the Governor The Capitol Bu.ilding Tallahassee, F'lorida 32301
ENCLOSURE UNRESOLVED TECHNICAL SPECIFICATION PROPOSALS WITH NRC TECHNICAL STAFF COMtfENTS Unit 1 proposal:
Florida Power and Light (FPSL) has proposed revising the definitions of Containment Vessel Integrity and Shield Building Integrity to be consistent with Unit 2.
The proposal, however, failed to include the following in the definitions:
"The sealing mechanism associated with each penetration (e.g.,
~.bellows or 0-rings) is Operable."
Unit 2 technical specifications do include the sealing mechanism in its definitions as does the Combustion Engineering Standard Technical Specifica-tions (STS).
Therefore, due to the importance of the sealing mechanisms, the fact that these mechanisms are addressed in STS, and because Unit 1 is being revised to reflect Unit 2, the licensee is requested to submit a
supplement to their initial package to include sealing mechanisms in their definitions of Shield Building and Containment Vessel Integrity.
It is re'commended the Unit 1'efinitions read exactly -like Unit 2 definitions 1.7 and 1.28.
2.
3.
4.
Units 1 and 2 proposals:
3.4.8.d:
FPKL deleted the reporting requirements from their technical specifications with respect to Dose Equivalent I-131.
This deletion does not meet the intent of 'Generic Letter 83-43.
fechnical staff discussions with Hr.
F.
- Anderson, author of Generic Letter 83-43, have confirmed that a Special Report in accordance with section 5.9.2 is required.
This Special Report must include the information required in current technical specifications, step 3.4.8.d.
Therefore, in order for the technical specifications to reflect the reporting requirements of Generic
~e ter 83-43, the licensee is requested to submit a supplement to their initial package to reflect the Special Report requirement.
This Special Report will be required within 30 days.
Unit 1 and 2 proposals:
4.6.1.6:
FPSL deleted all reporting requirements if any change of appearance or other abnormal degradation was detected in the containment vessel.
This does not meet the intent of Generic Letter 83-43 since Containment Vessel Structural Integrity is not specifically addressed in 10 CFR 50.73.
In order for the reporting requirements of Generic Letter 83-43 to be met, the licensee is requested to submit a supplement to their initial package to reflect the fact that a Special Report pursuant to specification 6.9.2 shall be submitted to the Commission.
Based on technical staff discussions with Nr. F. Anderson of NRR, this Special Report shall be submitted within 15 days.
Unit 1 and 2 proposals:
4.6.6.3:
FPSL deleted all reporting requirements if any apparent changes in appearance of the concrete surfaces or other abnormal degradation was detected in the shield building.
This does not meet the intent of Generic Letter 83-43 since Shield Building Structural Integrity is not specifically addressed in 10 CFR 50.73.
In order for the reporting requirements of Generic Letter 83-43 to be met, the licensee is
-Encl'os ure requested to submit a supplement to their initial package to reflect the fact that a
Special Report pursuant to specification 6.9.2 shall be submitted to the Commission.
Based on technical staff discussions with Mr. F. Anderson of NRR, this Special Report shall be submitted within 15 days.
5.
Unit 2 proposal:
4.8.1. 1.3:
FP&L deleted the reporting requirement for all diesel generator failures, valid or non-valid.
The reporting requirement constituted a Special Report and therefore cannot be deleted from technical specifications due to the requirements of Generic Letter 83-43.
It is
,.requested that the licensee submit a
supplement..to the initial package
'stating that all diesel generator failures, valid or non-valid, shall be reported to the Commission in a'pecial Report pursuant to specification 6.9.2 within 30 days.
The remainder of the technical specification should read the same as the current 4.8.1.1.3.
This change will result in consistency with other PWR changes currently being approved by the Comnission.
In order for Unit 1 and Unit 2 technical specifications to be consistent, it is also recommended that diesel generator failures and
'pecial Report requirements be incorporated into Unit 1 technical specifica-tions.
6.
Units 1
and 2 proposals:
6.2.2.f:
FP&L proposed that administrative procedures shall be developed and implemented to limit the working hours of senior reactor operators and reactor operators.
The NRC had, in the past, allowed the licensee to'ave an overtime restriction policy for Ricensed operators and senior operators (Reference NRC letter to FP&L dated February 4, 1982 and Unit 2 Safety Evaluation R~eort Section 13.5.1.1 (1)f.
dated October 1981).
Since these documents were generated, the NRC has further clarified its position with respect to meeting the overtime require-ments of NUREG-0737 Action Item I.A.1.3 entitled, "Shift Manning".
Specifi-cally, Generic Letter 82-02, dated February 8, 1982, stated that overtime controls shall apply to the plant staff who perform safety-related functions (e.g.,
senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel).
Subsequently, Generic Letter 82-10 dated May 5, 1982 was issued.
The enclosure to this Generic Letter stated the following requirement for action item I.A.1.3. 1: "Revise administrative procedures to limit overtime in accordance with NRC Policy Statement issued by Generic Letter No. 82-02, dated February 8, 1982."
FP&L's response to Generic Letter 82-10 was FP&L letter L-82-272 dated July 2, 1982.
In this letter, FP&L continued to refer to Unit 2 Safety Evaluation
- Report, Section 13.5. 1.1( l)f and NRC's letter of February 4,
- 1982, as adequate justification to only limit working hours to licensed operators and senior operators.
Finally, the NRC further clarified its position on shift manning in.Generic Letter 82-12 dated June 15, 1982.
Again, this generic letter stated that overtime controls shall apply to plant staff who perform safety related functions (e.g.,
senior reactor operators, reactor operators, auxiliary operators, health physicists, and key maintenance personnel).
FP&L responded to Generic Letter 82-12 in FP&L's letter L-82-417 dated September 30, 1982.
FP&L maintained the, same position as previously stated.
'On March 14, 1983, the Commission issued an Order confirming FP&L comnitments to implement post-TMI related items.
Encl osure Attachme'nt 2 to the Order stated the requirement that the licensee revise administrative procedures to limit overtime in accordance with NRC Policy Statement issued by Generic Letter No. 82-12, dated June 15, 1982.
The licensees's status was listed as complete even though 82-12 was not met.
It has also been noted that Unit 2 technical specification 6.2.2.f states "Adminstrative procedures shall be dev'eloped and implemented to limit the working hours of unit staff who perform safety-related functions; e.g.,
senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel."
Contrary to the above, St. Lucie Administrative Operating Procedure
- 0010119, Revision 6, only applies over-
,time limitations for licensed operators.
Therefore, it is recommended the licensee submit a
supplement to. their initial package changing Unit 1
proposal Section 6.2.2.f to read exactly like Unit 2 current Section 6.2.2.f.
Also, it is recommended that the licensee delete its proposal to change Unit 2 Section 6.2.2.f since it currently fulfills all NRC requirements.
7.
Units 1 and 2 proposals:
L-84-154, dated June 19, be deleted from technical Section III.1 adequately training.
The technical recommended the licensee deleting Section 6.4.2.
6.4.2:
FPRL proposed in their letter to the
- NRC, 1984, that the Fire Brigade training requirements specifications since 10 CFR Part 50, Appendix R, specifies the requirements for Fire Brigade staff concurs with this proposal, and it is submit a
supplement to their initial package 8.
Unit 1 proposal:
6.5.1.7.a:
This section 'referred to paragraph "m" which was proposed to be deleted in Section 6.5.1.6.
This appears to be an administrative oversight.
It is recommended that FP&L submit a supplement to their initial package deleting the reference to paragraph "m" in Section 6.5.1.6.
9.
Unit 1 and 2 proposals:
6.7.l.c:
FPKL deleted the period of time a Safety Limit Violation Report must be submitted to the-Commission.
It is recommended the licensee submit a supplement to their initial change package for Section 6.7.1.c to read as follows: "The Safety Limit Violation Report shall be submitted to the Commission, the CNRB, the Vice President Nuclear Operations, and the Group Vice President Nuclear Energy within 14 days of the violation."
10.
Unit 1 proposal: 6.10.2.f:
This requirement referred to table 5.7-1.
This appears to be an administrative oversight in that the correct table is actually 5.9-1.
It is recommended the licensee submit a supplement to their initial package with the appropriate correction made.
Unit 1 proposal:
- 6. 14. 1:
It appears that an administrative oversight was made in that the proposal stated that the FRG approves the ODCN.
In fact, the Commission approves the ODCH.
It is recommended a
supplement be submitted to make the appropriate correction.