ML20095D977

Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water

ML20095D977
Person / Time
Site:	Vogtle
Issue date:	12/08/1995
From:	Mccoy C GEORGIA POWER CO.
To:	NRC
References
FRN-60FR56359 60FR56359-00006, 60FR56359-6, LCV-0713, LCV-713, NUDOCS 9512140092
Download: ML20095D977 (2)

Text

., .- nuy p yy Georg a Power Company py 3 (,, ,/

[![/O [// ff 40 inverness Center Parkway Post Omce Box 1295 o Birmingham, Alabama 35201 Telephone 205 877 7122

// L Nh L C. K. McCoy Georgia Power Vce Presdent. Nuc: ear Vogue Pio\oct the southern electnc system December 8, 1995 Docket Nos. 50-424 LCV-0713 50-425 Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission _ ~

Mail Stop T-6D-69 r Washington, DC 20555-0001 ,

Comments on J ,

"Propo, sed Generic Communication; Boraflex Degradation in 2 - ..._ ]

Spent Fuel Pool Storage Racks (MD91447)" M  :

(60 Federal Register 56359 dated November 8.1995) e o

7

Dear Sir:

Georgia Power Company (GPC) has reviewed the proposed generic letter, "Boraflex Degradation in Spent Fuel Pool Storage Racks," published in the Federal Register on November 8,1995. In accordance with the request for comments, GPC submits the following. The safety assessment in the proposed generic letter recognizes that the presence of borated water in pressurized water reactor (PWR) spent fuel pools contributes to margin for maintaining subcriticality in spent fuel racks. However, as part of the requested information, licensees are being required to demonstrate subcriticality margin in ,

unborated water. This request appears to be inconsistent with the stated benefit of l borated water, particularly for PWRs. As you are aware, the Westinghouse Owners Group  ;

(WOG) has initiated an effort to change the kar criterion, with only limited credit for boron in solution for spent fuel pool criticality control in PWRs, and has pursued discussions with the Nuclear Regulatory Commission including submittal of a topical report with lead plant reference. Due to the potential benefits of the WOG effort, it is recommended that this initiative be considered along with expanded credit for soluble boron.

Respectfully submitted, C. K. McCoy 9512140092 951200 PDR ADOCK 05000424 l P PDR D

o e f GeorgiaPower b U. S. Nuclear Regulatory Commission Page Two l

CKM/TMM ,

I l

cc: Georgia Power Company . );

J. B. Beasley, General Manager - Vogtle Electric Generating Plant 1

U. S. Nuclear Regulatory Commission. Washington. DC L. L. Wheeler, Licensing Project Manager, Vogtle U. S. Nuclear Regulatory Commission. Region II ,

I S. D. Ebneter, Regional Administrator C. R. Ogle, Senior Resident Inspector - Vogtle l

1 LCV-0713

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