ML17229A755

Comment Opposing Proposed Communication Re Augmented Insp of Pressurized Water Reactor Class 1 High Pressure Safety Injection Piping

ML17229A755
Person / Time
Site:	Saint Lucie
Issue date:	05/29/1998
From:	Rajiv Kundalkar FLORIDA POWER & LIGHT CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR15233 63FR15233-00010, 63FR15233-10, L-98-145, NUDOCS 9806090097
Download: ML17229A755 (5)

Text

CATEGORY 2 REGULATO Y INFORMATION DISTRIBUTION SYSTEM (RXDS)

'DEACCESSION NBR:9806090097 DOC.DATE: 98/05/29 NOTARIZED: NO DOCKET N FACIL:

AUTH. NAME AUTHOR AFFILIATION KUNDALKAR,R.S. Florida Power 5 Light Co.

RECIP.NAME RECIPIENT AFFXLIATION MEYER,D.L. Rules & Directives Review Branch (Post 920323)

SUBJECT:

Comment opposing proposed communication re augmented insp of pressurized water reactor class 1 high pressure safety C injection piping. A DISTRXBUTION CODE: DS09D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: SECY/DSB Dist: Public Comment on'roposed Rule (PR)-Misc Notice;Reg G T NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: ILE CENTER 1 1 NMSS/IMOB T8F5 1 1 OG DR -B-18 1 1 RES DIR 1 1 R RES/DRA/DEPY 1 1 RES/DST 1 1 EXTERNAL: NRC PDR 1 1 D

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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 7 ENCL 7

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'~ @ %AY 2 9 1998 LES 5 D!R. BRANCld US NRC Mr. David L. Meyer, Chief Chief, Rules and Directives Branch Division of Administrative Services U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001

Subject:

Florida Power & Light Company Comments Proposed Generic Communication: Augmented Inspection of Pressurized-Water Reactor Class 1 High Pressure Safety Injection Piping (63 Fed. Reg. 15233 (Mar. 30, 1998) )

Dear Mr. Meyer:

Florida Power & Light Company (FPL), the licensed operator of two nuclear power plant units in Dade County, Florida, and two units in St. Lucie Count, Florida, hereby submits the fB g h b - f* *dp p dg In summary, FPL opposes issuance of the proposed generic communication for the reasons discussed below. Alternatively, FPL suggests clarification of certain matters discussed in the generic communication.

The proposed generic communication appears to be a replication of the requirements and concerns presented and addressed as a result of NRC Bulletin 88-08, "Thermal Stresses in Piping Connected to Reactor Cooling Systems," and its supplements. This bulletin requested licensees to review systems that could be subjected to thermal cycling and to plan and implement a program to provide continuing assurance that fatigue failures could not occur for the remaining life of the plant. Bulletin 88-08 contained reporting requirements that required the licensee to provide a letter confirming completion of the requested activities. By letters dated September 16, 1991, and September 23, 1991, the NRC determined that FPL's responses were consistent with the modification and monitoring alternatives stated in the bulletin and concluded that FPL met the requirements of Bulletin 88-08.

FPL requests that, should the proposed generic letter be issued, clarification be included to explain why the efforts in the Bulletin 88-08 are no longer considered adequate or why it appears that this request for information is a duplication of Bulletin 88-08.

98Q6090097 ADGCK 05000835 980529'DR 8 PDR an FPL Group company

~ J-Mr. David Meyer Proposed Generic Communication: Augmented Inspection of Pressurized-Water Reactor Class 1 High Pressure Safety Injection Piping Page 2 This letter also raises concerns similar to those expressed in industry comments to the recently proposed change to 10CFR50.55a (Proposed Rule - "Industry Codes and Standards" (62 FR 63892 dated December 3, 1997 and 63 FR 3673 dated January 26, 1998)). NRC is required by public law to use the consensus process for national codes and standards where such a process is available. The first item listed in the proposed generic letter is to identify a discrepancy in ASME Section XI. If this issue is significant enough to warrant a generic communication and a request for information pursuant to 10 CFR 50.54(f), FPL questions why the ASME Code consensus body has not been convinced to implement the change.

Should the proposed generic letter be issued, the following issues should be clarified:

The proposed generic letter should specifically state what piping systems and configurations require reporting. The proposed rule change referenced in the draft generic letter discusses Category B-J Item Numbers B9.20, B9.21., and B9.22.

It is not clear whether these are the only configurations that must be addressed.

The generic letter seems to focus on the lack of volumetric examinations. The NRC should clarify whether other methods may be used to detect or eliminate high cycle fatigue, FPL has reviewed and endorses the comments provided by the Nuclear Energy Institute (NEI).

We appreciate the opportunity to comment on the proposed generic communication.

Sincerely yours, Rajiv S. Kundalkar Vice President Nuclear Engineering

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