ML17229A530

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Provides Info Re St Lucie Implementation of Mods Associated W/Gl 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions
ML17229A530
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 11/17/1997
From: Wiens L
NRC (Affiliation Not Assigned)
To: Plunkett T
FLORIDA POWER & LIGHT CO.
References
GL-96-06, GL-96-6, TAC-M96870, TAC-M96871, NUDOCS 9711240243
Download: ML17229A530 (6)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 17, 1997 Mr. Thomas F. Plunkett President, Nuclear Division Florida Power and Light Company Post Office Box 14000-Juno Beach, Florida 33408-0420

SUBJECT:

INFORMATION PERTAINING TO ST. LUCIE, UNITS 1 AND 2, IMPLEMENTATIONOF MODIFICATIONSASSOCIATED WITH GENERIC LETTER 96-06, "ASSURANCE OF EQUIPMENT OPERABILITYAND CONTAINMENTINTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS" (TAC NOS. M96870 AND M96871)

Dear Mr. Plunkett:

The U.S. Nuclear Regulatory Commission (NRC) staff issued Generic Letter (GL) 96-06 on September 30, 1996.

The generic letter requested licensees to determine (1) if containment air cooler cooling water systems are susceptible to either waterhammer or two-phase flow conditions during postulated ac'cident conditions, and (2) if piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur.

By letter dated January 28,1997, as supplemented April 22, 1997, you submitted your 120-day response to GL 96-06.

The NRC staff is currently performing a detailed review of your response.

Implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources.

Some licensees have indicated that it would be prudent to take more time to better understand the specific concerns that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety.

Current issues and ongoing efforts that could influence a licensee's decision in planning corrective actions include (1) risk implications of installing relief valves to deal with the thermal overpressurization issue, (2) feasibility of using the acceptance criteria contained in Appendix P to Section III of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the permanent resolution of the GL 96-06 issues, I3I ongoing tests by the Electric Power Research Institute P

to support a generic resolution of the overpressurization of piping issue, and (4) questions regarding the staff's closure of Generic Safety Issue 150, "Overpressurization of Containment Penetrations."

Risk insights and industry initiatives that are being considered, or that may be proposed, could also influence the course of action that licensees take to resolve the GL 96-06 issues.

Licensees are responsible for assessing equipment operability, determining actions, and establishing schedules that are appropriate for resolving. the specific conditions that have been identified.

In determining the appropriate actions and schedules for resolving GL 96-06 issues, licensees should consider, for example, the continued validity of existing operability determinations, compensatory actions required to maintain operability, the safety

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I yl Thomas F. Plunkett significance associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any generic initiatives and/or plant-specific actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation),

Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code,Section III, Appendix F (or other acceptance criteria) may present viable alternatives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as applicable.

Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8, 1997, helpful in determining appropriate actions and schedules.

Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justification.

It is the staff's current position that licensees can use the ASME Code,Section III, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues.

This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues.

In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a public workshop on this topic later this fall, The workshop proceedings will be summarized by the NRC staff and made publicly available.

The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter.

Your revised response should include appropriate discussion of the considerations discussed above, the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions, please contact me at (301) 415-1495.

Project Directorate II-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc:

See next page

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Thomas F. Plunkett I

H significance associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any'generic initiatives and/or plant-specific actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation).

Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code,Section III, Appendix F (or other acceptance criteria) may present viable alternatives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as applicable..Licensees may find the revised guidance contained in GL 91-18, "Information,to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8, 1997, helpful in determining appropriate actions and schedules.

Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justification.

It is the staff's current position that licensees can use the ASME Code,Section III, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues.

This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues.

In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staff and made publicly available.

The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions, please contact me at (301) 415-1495.

Sincerely, original signed by L.wiens L. A. Wiens, Senior Project Manager Project Directorate II-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc:

See next page DOCUMENT NAME:G:)GL9606.LTR DISTRIBUTION: See next page To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" I='-,Copy with attachment/enclosure "N" = No copy OFFICE PDII-3/PM PDII-3/LA PDII-3/D NAME Lveins:

BCla ton FHebdon 11/ '97 11

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F. Plunkett Florida Power and Light Company ST.

LUCIE PLANT CC:

Senior Resident Inspector St.

Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.

Hwy A1A Jensen

Beach, Florida 34957 Joe Hyers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399=2100 H.

S.

Ross, Attorney Florida Power

& Light Company P,O.

Box 14000 Juno

Beach, FL 33408-0420 John T. Butler, Esquire
Steel, Hector and Davis 4000 Southeast Financial Center Hiami, Florida 33131-2398 Hr. Douglas Anderson County Administrator St.

Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Hr. Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Regional Administrator

.Region II U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85

Atlanta, GA 30303-3415 H. N. Paduano, Manager Licensing

& Special Programs Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420 J.

A. Stall, Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen

Beach, Florida 34957 Mr. J. Scarola Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen
Beach, Florida 34957 Hr. Kerry Landis U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85
Atlanta, GA 30303-3415 E. J.

Weinkam Licensing Hanager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen

Beach, Florida 34957

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PUBLIC St.Lucie Reading File B.

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Hebdon B. Clayton L. Wiens OGC ACRS J.

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