ML20028C838

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Comments on Science Applications,Inc Rept on Potential Steam Generator Related Generic Requirements Per Generic Ltr 82-32,in Response to NRC 821209 Request.Regulations Re Proposed Actions Unnecessary
ML20028C838
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/10/1983
From: Westafer G
FLORIDA POWER CORP.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
3F-0183-04, 3F-183-4, GL-82-32, NUDOCS 8301140205
Download: ML20028C838 (2)


Text

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9 Power C O R PO A AfIO N 3anuary 10,1983 3F-0183-04 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License bio. DPR-72 Generic Letter 82-32 Potential Steam Generator Related Generic Requirements

Dear Mr. Eisenhut:

Florida Power Corporation (FPC) has received and reviewed the SAI report on Potential Steam Generator Related Generic Requirements included with your letter dated December 9,1982. As requested, our comments on the report follow.

First, FPC agrees with the conclusion that a steam tube rupture would have a negligible effect on public health and safety.

Second, while we agree with the report's statement that "significant cost savings can be realized" by systematic testing and inspection (Section 3.0, p. ES-2), we do not agree that these actions should be regulated by law. These tests would be performed by the utilities for economic incentives alone. For example, FPC already performs the following actions proposed by the SAI report:

1)

Secondary side inservice inspection and QA for loose parts 2)

Inservice inspection 3)

Secondary water chemistry program and condenser inservice inspection program 4)

Primary to secondary leakage limits 5)

Coolant Iodine limits 6)

An improved eddy current testing technique (in conjuction with B&W Owners Group Inservice Inspection Subcommittee)

As may be noted, FPC is already implementing or participating in the development of the four most effective measures as determined by SAI. Specifically, these are numbers 1,2, 3, and 6 above.

8301140205 830110 PDR ADDCK 05000302 P

PDR General Office 3201 Thrty-foutn street soutn. P.O. Box 14042, st. Petersburg, Fbrda 33733 e 813-866-5151

Mr. Darrell G. Eisenhut

- January 10,1983 Page 2 In summary, while we do agree with the basis of the SAI evaluation, we believe that-regulations concerning the proposed actions are unnecessary.

Thank you for your time and consideration of our comments.

Sincerely, o

G. R. Westafer

~

Manager Nuclear Licensing and Fuel Management TSW:mm cc:

Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 3100 Atlanta, GA 30303 4

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