NUREG-0843, Informs of Potential Deficiency Re 860702 Application for Amend to License NPF-16.Applicability of GDC 5 Discussed in SER (NUREG-0843) Section 9.1.2 May Need Evaluation & Analysis.Served on 861212

Informs of Potential Deficiency Re 860702 Application for Amend to License NPF-16.Applicability of GDC 5 Discussed in SER (NUREG-0843) Section 9.1.2 May Need Evaluation & Analysis.Served on 861212

ML20211L578
Person / Time
Site:	Saint Lucie
Issue date:	12/09/1986
From:	Bechhoefer C Atomic Safety and Licensing Board Panel
To:	Frantz S, Mcgurren H NEWMAN & HOLTZINGER, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#486-1862, RTR-NUREG-0843, RTR-NUREG-843 OLA, NUDOCS 8612160094
Download: ML20211L578 (2)

Text

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL ;ct wr .

W ASHINGTON, D.C. 20565 A"

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'86 DEC 12 A10:39 December 9, 1986 f0C',G .1 ir M; r:. -

Henry J. McGurren, Esq.

NRC Staff Counsel U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Steven P. Frantz, Esq. SERVED DEC 121986 Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C. 20036 In the Matter of Florida Power & Light Co., et al.

(St.LuciePlant,UnitNo72T ,

Docket No. 50-389-OLA Gentlemen:

The Licensing Board in this operating license amendment proceeding has perceived a potential deficiency in the matters submitted to NRC for the proposed amendment, and we wish to bring this matter to your-attention. We note that the Staff's October 1981 Safety Evaluation Report for St. Lucie Plant, Unit 2 (NUREG-0843), includes the following statement (19.1.2, at p. 9-3):

There is no sharing of the spent fuel storage facility between St. Lucie Units 1 and 2. Thus, the requirements of General Design Criterion 5, "f, haring of Structures, Systems and Components," which concerns the capability to maintain safe operation of two units when essential systems are shared, are not applicable.

See also I 9.1.3, at p. 9-4.

General Design Criterion 5 provides as follows:

Criterion 5--Sharing of structures, systems, and components.

Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perfom their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

8612160094 e61209 PDR ADOCK 05000389

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2 It appears to the Board that this criterion would become applicable to this facility if the proposed amendment were to be approved.

The Board has examined the file copy of the application document, dated July 2,1986, and has not located any analysis of the facility's conforvence to GDC-5. Moreover, the Federal Register notice for this .

proceeding makes no reference to Staff evaluation of any such analysis.

The Board believes that such analysis and evaluation might well constitute a legal requirement for the proposed amendment. Moreover, absent such analysis and evaluation, the failure to have demonstrated conformance to GDC-5 might be deemed to constitute "the possibility of a

' new or different kind of accident from any accident previously evaluated," within the meaning of 10 C.F.R. 6 50.92(c)(2). The Board does not at this time intend to raise this matter as an issue pursuant to 10 C.F.R. I 2.760a but believes the Staff and Applicants should be ,

informed of our concerns in this regard.

ATOMIC SAFETY AND LICENSING BOARD ,

An hn l~

Charles Bechhoefer, Chat,pman J

ADMINISTRATIVE JUDGE cc: Service List, St. Lucie, Docket No. 50-389-OLA i Rules & Records Branch Division of Rules & Records, Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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