NUREG-0834, Forwards for Record,Nrc Responses to Util 811204 Comments on SER (NUREG-0843)
| ML17213A449 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/30/1982 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| RTR-NUREG-0834, RTR-NUREG-834 NUDOCS 8209160072 | |
| Download: ML17213A449 (9) | |
Text
Docket No. 50-389 AUG 3.01982, Distribution:
<Document-Control-50-389->>
PRC Sytem NRC PDR L PDR NSIC Dr. Robert E. Uhrig Vice President Florida Power 5 Light Company Post Office Box 529100 Miami, Florida 33152 LB¹3 File FMiraglia VNerses JLee TNovak JThessin ACRS (10 cys)
Dear Dr. Uhrig:
Subject:
Responses to Florida Power 8 Light (FPSL)
Coranents.
on St. Lucie 2 SER In L-81-511 letter dated December 4, 1981, Florida Power Im Light (FP8L) provided their comments regarding the St. Lucie 2 SER, NUREG-0843, dated October 1981.
The staff has reviewed the submitted comments.
Where the staff disagreed with the FPEL comments, the staff responses were informally transmitted to your Mr. Sheetz in order to expedite resolution.
Where the staff agreed with FP8L, revisions were made in Supplement tb.
1 and Supplement No. 2 (presently being prepared for issuance) to the SER.
This letter is to put on record the staff responses Attachment 1 identifies the item number corresponding to the item inttlie attachment to your letter.
Where it is noted that the staff disagrees, a copy of the basis for the disagreement is provided in Attachment 8.
Sincerely, priBl~al sipped bY ZrarQc J MiraBlia Encl os ures:
As stated cc w/encl:
See next page Frank J. Miraglia, Chief Licensing Branch ¹3 Division of Licensing 8209l60072 820830 PDR ADOCK 0500088W E
PDR OFFICE I SURNAME$
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82 NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USG PO: 1981~5.960 ':
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ST.
LUG IE Dr. Robert E. Uhrig, Vice President Advanced Systems and Technology Florida Power
& Light Company P. 0.
Box 529100 Miami, Fl ori da 33152 Harold F. Reis, Esq.
Low nstein, Newman, Reis, Axelrad
& Toll 1025 Connecticut
- Avenue, N.M.
1'ashington, D.C.
20036 Norman A. Coll, Esq.
Steel Hector
& Davis 1400 Southeast First National Bank Building Miami, Florida 33131 Mr. Martin H. Hodder 1131 N. E. 85th Street Miami, Florida 33138 Resident Inspector St. Lucie Nuclear Pow r Station c/o U. S.
Nuclear Regulatory Commission 7900 South AlA Jensen Beach, Florida 33457 U. S. Nuclear Regulatory Commission 101 Marietta Street Sui te 3100 Atlanta, Georgia 30303
ATTACHMENT 1 NRC STAFF
RESPONSE
TO FLORIDA POWER
& LIGHT CO.
COMNENTS ON ST.
l-l thru 1-3 3-1 thru 3-4 3-5 4-1, 4-2 thru 4-6 4-7 5-1, 5-2 6-1 thru 6-12 8-1 thru 8-6 9-1 9-2 thru 9-8 9-9, 9-10 9-11 10-1 thru 10-3 10-4 thru 10-6 11-2 11-3, 11-4 12-1 14 15-1 thru 15-3 15-4 15-5, 15-6
~fff R agree except for item (1) in 1-3 agree disagree agree disagree agree agree agree agree agree staff working with FP&L to resolve comments agree disagree agree partially agree; refer to section 10.4.9 in SSER b'2 for staff response'gree disagree agree agree agree agree disagree agree
FP8L Item No.'taff Res onse 15-7 15-8 15-9 17-1 thru 17-3 17-4 17-5 23-1 C-1 disagree agree disagree agree disagree agree agree agree
Attachment 2
NRC STAFF BASES FOR DISAGREEMENT FPLL Item No.
3-5 4-2 Staff Res onse In Section 1.11 "Special Plant Features",
of the SER and/SSER gl, the staff was not making a case for "unique plant features" (FPSL comment) but rather highlighting certain plant features.
Therefore, the staff does not find the need to delete this item.
/
The SER is correct as written and the applicant's proposed revision is not acceptable.
The applicant has stated that the Category II requirements of NUREG-0588 will apply to equipment purchased and accepted prior to the issuance of IEEE Standard 323-1974.
The Commission Memorandum and Order (CLI-80-21) and NUREG-0588 require that Category I components be utilized.
We believe that the SER is correct as written with regard to the definition of SAFDLs (Specified Acceptable Fuel Design Limits).
GDC 10, 20 and the several other GDCs that incorporate the SAFDL concept are intentionally non-specific, and the SAFDLs approved in the SER (in accordance with the SRP acceptance criteria) provide needed specificity.
As indicated in the SER, an objective of the fuel system safety review is to provide assurance
.that the fuel system is not damaged as a result of normal operation and AOOs.
"Not damaged" is defined as meaning that fuel system dimensions remain within operational tolerances, and that functional capabil-ities are not reduced below these assumed in the safety analysis.
The stated safety review objective and associated definition of fuel system damage are fully consistent with the intent of GDC 10 and related GDCs that are grouped under the heading, Protection by Multiple Fission Product Barriers.
Thus, for each applicable fuel system damage mechanism, there should be a corresponding SAFDL that is in accordance with an acceptance criterion provided in the Standard Review Plan.
Under existing regulations we see no basis for restricting the SAFDLs to a few parameters while other potential fuel system damage factors are ignored.
Therefore, the cited passage in the SER should remain.
FPEL Item No.
Staff Res onse 4-3 4-5 4-6 The recommendation to add statements on cladding and fuel pellet overheating to SER Section 4.2.1.1 appears to stem from a misunderstanding of the way fuel system "damage" is categorized in the safety
~
review.
The term "damage" includes a range of fuel system component conditions, which are separated into three parts in structuring the review: (1) damage up to, but not including, fuel rod failure, (2) fuel rod failure, and (3) coolability.
Over-heating of cladding and fuel pellets is addressed in the second category, fuel rod failure, because the primary concern of such overheating is associated with fuel rod failure and the associated acceptance criteria, and SAFDLs 'address fuel rod failure. 'he cited SER section should, therefore, not b'e revised as recommended by FPKL.
No change is necessary for Section 4.2.1.2 (p.4-6}.
(See remarks on Item 4-2)
We believe that the SER is correct as written with regard to the statements on the design limit for the prevehtion of fuel failure due to cladding over-heating.
The words in question,
. that there will be at least 95 percent probability at a 955 confidence level that departure from nucleate boiling (DNB) will not occur
.." are virtually identical to"those that have been used in acceptance cri.terion l.a of SRP Section 4.4 for several years.
While deviations from the SRP are permitted as a matter of principle,'hey may he made only after careful review of documented supportirig data and after following established procedures.
There is no apparent basis for deviating from the SRP in this particular case.
The SER statements are correct as written.
The FP&L suggestions are inappropriate because of the following:
When a
CEA is fully withdrawn, several inches of the CEA's rods remain within the fuel assembly.
Through surveillance, CE has found that most CEA cladding wear occurs at the axial locate.on on the CEA where
FP&L Item No.
4-6 (continued}
9-11 11-2 15-4 15-7, 15-9 Staff Res.
onse the CEA rods enter the fuel assembly end posts.
Full-length CEAs do not have solid Inconel nose caps that extend up to this elevation.
Consequently, at this elevation, only a 0.035-inch-thick cladding
~
wall maintains CEA hermiticity.
Therefore, the SER Section 4.2,3.1 (d} should not be revised.
(Note that FP&L has mistakenly identified Item 4-6 as corresponding to SER Section 4.2.2.2)
FSAR Table 3.2-1, Note 7 states essential portions of D/G systems (necessary for D/G operation and reactor shutdown) are designed seismic category I
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and ASME Section III, Class 3.
Therefore, that portion. of the system is'ecessary.
We do not concur.
FP&L coranitted to provide two 2,300 gallon bottom tanks in their letter to NRC dated-August 4, 1981; and signed by Mr..-Uhrig of FP&L in response to NRC question 460-1.
The applicant's proposed revision is unacceptable to the staff.
We would accept the following:
"Assuming that all fuel pins which experience DNB fail, then 3.7X of the fuel pins are predicted to fail during thi.s event."
The licensee's comment suggests that a primary coolant activity limit of 5 pCi/gm, the limit associated with the main steam l,ine break (instead of the staff value of l. yCi/gm}, is appropriate for St. Lucie 2.
Because several accidents are examined using the Technical Specification limitations on primary coolant activities, one accident may not produce the limiting coolant concentration.
Use of the suggested value of 5 pCi/gm for the failure of small lines carrying primary coolant outside containment results in doses which exceed the staff guidelines.
As a result, the staff finds the comments (15-7 and 15-9) unacceptable.
FP&L Item No.
Staff Res onse 17-4 We do not agree with item 17-4 since Regulatory Guide 1.28 is not applicable to operations gA programs.