ML14115A458: Difference between revisions

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This Amended Hearing Request is supported by the attached Supplemental Declaration of Arnold Gundersen (April 24, 2014) (Supplemental Gundersen Declaration) (attached as  
This Amended Hearing Request is supported by the attached Supplemental Declaration of Arnold Gundersen (April 24, 2014) (Supplemental Gundersen Declaration) (attached as  


Exhibit 1). II. NEW INFORMATION SUPPORTING CONTENTIONS 1 AND 2  SACE hereby amends its Hearing Request to provide the following additional information from UFSAR Amendment 18:
Exhibit 1). II. NEW INFORMATION SUPPORTING CONTENTIONS 1 AND 2  SACE hereby amends its Hearing Request to provide the following additional information from UFSAR Amendment 18:
: 1. As stated in SACEs Hearing Request, in 2007, FPL replaced the Unit 2 original steam generators (OSGs) with new Replacement Steam Generators (RSGs) manufactured by  
: 1. As stated in SACEs Hearing Request, in 2007, FPL replaced the Unit 2 original steam generators (OSGs) with new Replacement Steam Generators (RSGs) manufactured by  


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At the same time that FPL submitted the 50.59 Summary to the NRC, it also submitted UFSAR Amendment 18, which updates the FSAR to reflect the changes made by FPL under 10  
At the same time that FPL submitted the 50.59 Summary to the NRC, it also submitted UFSAR Amendment 18, which updates the FSAR to reflect the changes made by FPL under 10  


C.F.R. § 50.59.
C.F.R. § 50.59.
: 2. In UFSAR Amendment 18, changes to the FSAR that resulted from Amendment 18 are marked by vertical lines in the right-hand margin of the pages. These changes include only  
: 2. In UFSAR Amendment 18, changes to the FSAR that resulted from Amendment 18 are marked by vertical lines in the right-hand margin of the pages. These changes include only  


additions or substitutions of text and do not include strikeouts. Therefore, in order to understand the nature of the changes, it is necessary to compare UFSAR Amendment 18 with the OFSAR that FPL submitted in 1980 (relevant pages of Chapter 5 of the OFSAR are attached as Exhibit 2.)  
additions or substitutions of text and do not include strikeouts. Therefore, in order to understand the nature of the changes, it is necessary to compare UFSAR Amendment 18 with the OFSAR that FPL submitted in 1980 (relevant pages of Chapter 5 of the OFSAR are attached as Exhibit 2.)
: 3. The change pages in UFSAR Amendment 18 confirm that FPL removed or altered components of the steam generators that are significant to the safe operation of St. Lucie Unit  
: 3. The change pages in UFSAR Amendment 18 confirm that FPL removed or altered components of the steam generators that are significant to the safe operation of St. Lucie Unit  


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Id. at 5.4-13. In other words, FPL now purports to avoid tube denting with the very same components it previously disavowed as contributors to tube denting. But FPL provides no explanation for this complete turnaround in its safety analysis. In fact, the substitution of broached plates for egg crate tube supports creates potential for greater vibration of tubes.   
Id. at 5.4-13. In other words, FPL now purports to avoid tube denting with the very same components it previously disavowed as contributors to tube denting. But FPL provides no explanation for this complete turnaround in its safety analysis. In fact, the substitution of broached plates for egg crate tube supports creates potential for greater vibration of tubes.   


Gundersen Declaration, ¶¶ 44, 45, and 61.    
Gundersen Declaration, ¶¶ 44, 45, and 61.
: 4. UFSAR Amendment 18 identifies a new component not previously identified in the OFSAR or described in the 50.59 Summary:  steam nozzle venturis.
: 4. UFSAR Amendment 18 identifies a new component not previously identified in the OFSAR or described in the 50.59 Summary:  steam nozzle venturis.
Id., Table 5.2-3 at page 5.2-29. As discussed in the attached Supplemental Gundersen Declaration, the purpose of steam nozzle venturis is to limit the rate at which steam (mass and energy) leaves a steam generator. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSG and RSG, resulting in reanalysis and modification from the original design. The installation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.
Id., Table 5.2-3 at page 5.2-29. As discussed in the attached Supplemental Gundersen Declaration, the purpose of steam nozzle venturis is to limit the rate at which steam (mass and energy) leaves a steam generator. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSG and RSG, resulting in reanalysis and modification from the original design. The installation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.
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UNITED STATES OF AMERICA  BEFORE THE NUCLEAR REGU LATORY COMMISSION ___________________________________  
UNITED STATES OF AMERICA  BEFORE THE NUCLEAR REGU LATORY COMMISSION ___________________________________  
         ) In the Matter of:            ) Florida Power & Light Co.                )  Docket No. 50-389 St. Lucie Plant, Unit 2              )  April 25, 2014          )
         ) In the Matter of:            ) Florida Power & Light Co.                )  Docket No. 50-389 St. Lucie Plant, Unit 2              )  April 25, 2014          )
SUPPLEMENTAL DECLARATION OF ARNOLD GUNDERSEN Under penalty of perjury, I, Arnold G undersen, hereby declare as follows:    I. INTRODUCTION  
SUPPLEMENTAL DECLARATION OF ARNOLD GUNDERSEN Under penalty of perjury, I, Arnold G undersen, hereby declare as follows:    I. INTRODUCTION
: 1. My name is Arnold Gundersen. I am Chief Engi neer for Fairewinds Associates, a paralegal services and expert witness firm. I have b een retained by Southern Alliance for Clean Energy (SACE) to evaluate safety and licensing issues related to the replacement steam generators (RSGs) that Florida Power & Light Co. (FPL) installed in the Unit 2 St. Lucie nuclear reactor in 2007.    
: 1. My name is Arnold Gundersen. I am Chief Engi neer for Fairewinds Associates, a paralegal services and expert witness firm. I have b een retained by Southern Alliance for Clean Energy (SACE) to evaluate safety and licensing issues related to the replacement steam generators (RSGs) that Florida Power & Light Co. (FPL) installed in the Unit 2 St. Lucie nuclear reactor in 2007.
: 2. On March 9, 2014, I prepared a declaration in support of SACE's Hearing Request Regarding De Facto Amendment of St. Luci e Unit 2 Operating License (March 10, 2014), including two contentions challenging the lawfulness of the U.S. Nuclear Regulatory Commission's de facto amendment of the operating license for St. Lucie Unit 2 to allow operation of Unit 2 with substantially re-designed steam generators. The statements of fact I made in that declaration continue to be true to the best of my knowle dge, and the statements of my professional opinion in that declaration co ntinue to be accurate expressions of my best professional judgment.  
: 2. On March 9, 2014, I prepared a declaration in support of SACE's Hearing Request Regarding De Facto Amendment of St. Luci e Unit 2 Operating License (March 10, 2014), including two contentions challenging the lawfulness of the U.S. Nuclear Regulatory Commission's de facto amendment of the operating license for St. Lucie Unit 2 to allow operation of Unit 2 with substantially re-designed steam generators. The statements of fact I made in that declaration continue to be true to the best of my knowle dge, and the statements of my professional opinion in that declaration co ntinue to be accurate expressions of my best professional judgment.
: 3. The purpose of this Supplemental Declaration is to support SACE's Amended Hearing Request (April 24, 2014).  
: 3. The purpose of this Supplemental Declaration is to support SACE's Amended Hearing Request (April 24, 2014).
: 4. As summarized in ¶ 31 of my March 9 Declaration, my review of correspondence and documents related to St. Lucie Unit 2 and the San Onofre steam generators shows that FPL has made at least four major design changes to the steam generators for St. Lucie Unit 2.
: 4. As summarized in ¶ 31 of my March 9 Declaration, my review of correspondence and documents related to St. Lucie Unit 2 and the San Onofre steam generators shows that FPL has made at least four major design changes to the steam generators for St. Lucie Unit 2.
Page 2 of 3 First, the RSGs no longer contained the stay cylinders that were part of the original steam generator ("OSG") design discussed in the Final Safety Analysis Report ("FSAR") as structural support for the reactor coolant system and included in the Aging Management Program (AMP). Second, documents related to subsequent inspections of the St. Lucie Unit 2 steam generators show that AREVA added 588 new tubes to the original 8,411 tubes, now  
Page 2 of 3 First, the RSGs no longer contained the stay cylinders that were part of the original steam generator ("OSG") design discussed in the Final Safety Analysis Report ("FSAR") as structural support for the reactor coolant system and included in the Aging Management Program (AMP). Second, documents related to subsequent inspections of the St. Lucie Unit 2 steam generators show that AREVA added 588 new tubes to the original 8,411 tubes, now  


totaling 8,999 tubes. The addition of 588 new t ubes changes the pattern of water circulation in the steam generator and therefore has significant safety implications. Third, FPL replaced the pre-existing eggcrate tube supports with tref oil broached plates," despite the fact that such plates were specifically excluded from the original steam generator design for safety reasons. Finally, in order to accommodate the 58 8 new tubes, it is reasonable to infer that the region of the tubesheet that ha d been directly above the stay cylinder was now perforated with 588 new holes.  
totaling 8,999 tubes. The addition of 588 new t ubes changes the pattern of water circulation in the steam generator and therefore has significant safety implications. Third, FPL replaced the pre-existing eggcrate tube supports with tref oil broached plates," despite the fact that such plates were specifically excluded from the original steam generator design for safety reasons. Finally, in order to accommodate the 58 8 new tubes, it is reasonable to infer that the region of the tubesheet that ha d been directly above the stay cylinder was now perforated with 588 new holes.
: 5. As discussed in my March 9 Declaration, all of these changes have major safety significance and exceed the reactor's design basis. In addition, these design changes increase the risk of steam generator failure and therefore have an ad verse effect on public health and safety.  
: 5. As discussed in my March 9 Declaration, all of these changes have major safety significance and exceed the reactor's design basis. In addition, these design changes increase the risk of steam generator failure and therefore have an ad verse effect on public health and safety.
: 6. At the time I prepared my March 9 Declaration, I did not have access to Amendment 18 of the updated Final Safety Analysis Report that FPL submitted to the NRC after it installed the RSGs ("UFSAR Amendment 18") (June 26, 2008) (ML14104B631). On April 15, 2014, the NRC's Public Document Room made that document publicly available. By comparing the text of the original 1980 FSAR ("OFSAR") with the text of UFSAR Amendment 18, I was able to confirm that FPL did indeed make all of the design changes described in ¶ 4 above. These changes to the text of the FSAR are discussed in more detail in SACE's Amended Hearing Request.
: 6. At the time I prepared my March 9 Declaration, I did not have access to Amendment 18 of the updated Final Safety Analysis Report that FPL submitted to the NRC after it installed the RSGs ("UFSAR Amendment 18") (June 26, 2008) (ML14104B631). On April 15, 2014, the NRC's Public Document Room made that document publicly available. By comparing the text of the original 1980 FSAR ("OFSAR") with the text of UFSAR Amendment 18, I was able to confirm that FPL did indeed make all of the design changes described in ¶ 4 above. These changes to the text of the FSAR are discussed in more detail in SACE's Amended Hearing Request.
Page 3 of 3  
Page 3 of 3
: 7. In addition, as discussed in par. 4 of SACE's Amended Hearing Request, UFSAR Amendment 18 shows that FPL made an additi onal design change I was not previously aware of:  it installed "steam nozzle venturis."  The purpose of a steam nozzle venturi is to limit the rate at which steam (mass and energy) leaves the RSG in the event of a steam line break accident. The fact that FPL included this new component in the RSG design demonstrates that the mass and energy flow rate from the RSGs is greater than the mass and energy flow rate from the OSGs. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSGs and RSGs, resulting in reanalysis and modification from the original design. The in stallation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.  
: 7. In addition, as discussed in par. 4 of SACE's Amended Hearing Request, UFSAR Amendment 18 shows that FPL made an additi onal design change I was not previously aware of:  it installed "steam nozzle venturis."  The purpose of a steam nozzle venturi is to limit the rate at which steam (mass and energy) leaves the RSG in the event of a steam line break accident. The fact that FPL included this new component in the RSG design demonstrates that the mass and energy flow rate from the RSGs is greater than the mass and energy flow rate from the OSGs. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSGs and RSGs, resulting in reanalysis and modification from the original design. The in stallation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.
: 8. In conclusion, UFSAR Amendment 18 confirms that FPL has made ma jor design changes to the steam generators for St. Lucie Unit 2 which exceed the reactor's design basis and increase the risk of steam generator failure at the reactor.
: 8. In conclusion, UFSAR Amendment 18 confirms that FPL has made ma jor design changes to the steam generators for St. Lucie Unit 2 which exceed the reactor's design basis and increase the risk of steam generator failure at the reactor.
Under penalty of perjury, I declare that the foregoing statements of fact are true and correct to the best of my knowledge and that the foregoing statements of my opinion are based on my best professional judgment.     
Under penalty of perjury, I declare that the foregoing statements of fact are true and correct to the best of my knowledge and that the foregoing statements of my opinion are based on my best professional judgment.     


(Electronically signed pursuant to 10 C.F.R. § 2.304(d)(1))
(Electronically signed pursuant to 10 C.F.R. § 2.304(d)(1))
Arnold Gundersen, MENE, RO  Fairewinds Associates, Inc Burlington, Vermont 05401  
Arnold Gundersen, MENE, RO  Fairewinds Associates, Inc Burlington, Vermont 05401  


Date: April 25, 2014}}
Date: April 25, 2014}}

Revision as of 09:29, 28 April 2019

Southern Alliance for Clean Energy'S Amended Hearing Request Re De Facto Amendment of St. Lucie Unit 2 Operating License
ML14115A458
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 04/25/2014
From: Curran D
Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy
To:
Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML14115A455 List:
References
50-389-LA, License Amendment, RAS 25862
Download: ML14115A458 (35)
v • d • e


Text

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION

___________________________________

) In the Matter of: )

Florida Power & Light Co. ) Docket No. 50-389 St. Lucie Plant, Unit 2 ) April 25, 2014

)

SOUTHERN ALLIANCE FOR CLEAN ENERGYS AMENDED HEARING REQUEST REGARDING DE FACTO AMENDMENT OF ST. LUCIE UNIT 2 OPERATING LICENSE I. INTRODUCTION On March 10, 2014, the Southern Alliance for Clean Energy (SACE) submitted a request for a hearing and two contentions regarding the U.S. Nuclear Regulatory Commission

(NRC) Staffs de facto amendment of the St. Lucie Unit 2 operating license to allow operation of the reactor with substantially re-designed steam generators. Hearing Request Regarding De Facto Amendment of St. Lucie Unit 2 Operating License (Hearing Request). The Hearing

Request was supported by the Declaration of Arnold Gunderson (March 9, 2014) (Gundersen Declaration). Pursuant to 10 C.F.R. §§ 2.309(c)(1), SACE hereby amends its Hearing Request to provide additional relevant information that is contained in Amendment 18 to the Updated Final Safety Analysis Report (UFSAR Amendment 18) (June 26, 2008) (ML14104B631). The UFSAR Amendment 18 was not publicly available at the time that SACE submitted its Hearing Request but was released by the NRCs Public Document Room (PDR) on April 15, 2014.

The newly disclosed information supports SACEs assertion in Contentions 1 and 2 that the changes to the St. Lucie steam generators that were made by Florida Power & Light Co. (FPL) in 2007 constitute major design changes that exceed the reactors design basis as described in the original 1980 Final Safety Analysis Report (OFSAR).

This Amended Hearing Request is supported by the attached Supplemental Declaration of Arnold Gundersen (April 24, 2014) (Supplemental Gundersen Declaration) (attached as

Exhibit 1). II. NEW INFORMATION SUPPORTING CONTENTIONS 1 AND 2 SACE hereby amends its Hearing Request to provide the following additional information from UFSAR Amendment 18:

1. As stated in SACEs Hearing Request, in 2007, FPL replaced the Unit 2 original steam generators (OSGs) with new Replacement Steam Generators (RSGs) manufactured by

Areva. Id. at 7. In June of 2008, pursuant to 10 C.F.R. § 50.59, FPL filed a report with the NRC that summarized the characteristics of the RSGs and asserted that FPL had made no significant changes to major component supports or piping supports.

Id. at 7-8 (citing St. Lucie Unit 2, Docket No. 50-389, Changes, Tests, and Experiments Made as Allowed by 10

C.F.R. 50.59 for the Period of June 12, 2006 through April 4, 2008 at 8 (attached to letter from Gordon L. Johnston, FPL, to NRC re: St. Lucie Unit 2 Docket No. 50-389 Report of 10 CFR 50.59 Plant Changes (June 26, 2008)) (ML081840111) (50.59 Summary)).

At the same time that FPL submitted the 50.59 Summary to the NRC, it also submitted UFSAR Amendment 18, which updates the FSAR to reflect the changes made by FPL under 10

C.F.R. § 50.59.

2. In UFSAR Amendment 18, changes to the FSAR that resulted from Amendment 18 are marked by vertical lines in the right-hand margin of the pages. These changes include only

additions or substitutions of text and do not include strikeouts. Therefore, in order to understand the nature of the changes, it is necessary to compare UFSAR Amendment 18 with the OFSAR that FPL submitted in 1980 (relevant pages of Chapter 5 of the OFSAR are attached as Exhibit 2.)

3. The change pages in UFSAR Amendment 18 confirm that FPL removed or altered components of the steam generators that are significant to the safe operation of St. Lucie Unit

2 in the following respects:

a) In contrast to the OFSAR, UFSAR Amendment 18 no longer identifies the stay cylinder (i.e., Tubesheet stay) as a component of the Unit 2 RSGs.

Compare Table 5.2-3 in OFSAR (page 5.2-27) with Table 5.2-3 in UFSAR Amendment 18 (page 5.2-29). It is reasonable to infer from this omission that the stay cylinder has been removed from both

RSGs. See Gundersen Declaration, ¶ 31.

b) UFSAR Amendment 18 confirms that the RSGs have 588 new steam generator tubes in addition to the 8,411 tubes in the OSGs, totaling 8,999 tubes.

Compare OFSAR § 5.4.2.1.2 at 5.4-11 with UFSAR Amendment 18 § 5.4.2.1.2 at 5.4-11. The addition of 588 new tubes changes the pattern of water circulation in the steam generator and therefore has significant safety implications.

See Gundersen Declaration, ¶ 62.

c) In addition, it is reasonable to infer that in order to accommodate the 588 additional tubes, the tubesheet in the RSGs contains 588 additional perforations. These additional

perforations increase the potential for tubesheet flexing.

See Gunderson Declaration, ¶¶ 31 and 61.

d) UFSAR Amendment 18 deletes all references to the eggcrate tube supports that FPL relied on in the OFSAR for the purpose of avoiding denting of tubes. Instead, Amendment 18 now states that FPL uses plate supports in order to avoid tube denting.

Compare the text of the 1980 OFSAR § 5.4.2.1.3 with UFSAR Amendment 18 § 5.4.2.1.3 as follows: In the OFSAR, FPL stated: The potential for tube denting has been reduced in the St. Lucie Unit 2 steam generators by the installation of an antivibration support system that does not use drilled support plates. Supports of the same type, egg crates, have been used to some extent in all of supplied commercial steam generators within the United

States.

The egg crate system reduces susceptibility to tube denting by providing larger clearances and increased flow area around the tubes, so that the clearances between the tubes and their supports are less likely to become plugged by

corrosion products.

St. Lucie Unit 2 has a full egg crate support system (all support plates have been eliminated).

Id. at 5.4-13. Thus, FPL clearly stated that it would eliminate the use of support plates in order to avoid tube denting.

In 2008, in FSAR Amendment 18, FPL replaced the above analysis with the following analysis: The potential for tube denting has been reduced in the St. Lucie Unit 2 steam generators by the installation of tube support plates and antivibration bars system that are stainless steel with a high chromium content that forms a tight adherent oxide layer. This combination eliminates the potential for denting.

Id. at 5.4-13. In other words, FPL now purports to avoid tube denting with the very same components it previously disavowed as contributors to tube denting. But FPL provides no explanation for this complete turnaround in its safety analysis. In fact, the substitution of broached plates for egg crate tube supports creates potential for greater vibration of tubes.

Gundersen Declaration, ¶¶ 44, 45, and 61.

4. UFSAR Amendment 18 identifies a new component not previously identified in the OFSAR or described in the 50.59 Summary: steam nozzle venturis.

Id., Table 5.2-3 at page 5.2-29. As discussed in the attached Supplemental Gundersen Declaration, the purpose of steam nozzle venturis is to limit the rate at which steam (mass and energy) leaves a steam generator. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSG and RSG, resulting in reanalysis and modification from the original design. The installation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.

Id., ¶ 7. III. CONCLUSION In conclusion, the information described in Section II above confirms that (a) FPL has made major design changes to the St. Lucie Unit 2 steam generators that increase the risk of steam generator failure at the reactor. Therefore the information supports Contentions 1 and 2. Respectfully submitted, (Electronically signed by) Diane Curran HARMON, CURRAN, SPIELBERG, & EISENBERG, L.L.P.

1726 M Street N.W., Suite 600

Washington, D.C. 20036

202-328-3500

Fax: 202-328-6918 e-mail: dcurran@harmoncurran.com April 25, 2014

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGU LATORY COMMISSION ___________________________________

) In the Matter of: ) Florida Power & Light Co. ) Docket No. 50-389 St. Lucie Plant, Unit 2 ) April 25, 2014 )

SUPPLEMENTAL DECLARATION OF ARNOLD GUNDERSEN Under penalty of perjury, I, Arnold G undersen, hereby declare as follows: I. INTRODUCTION

1. My name is Arnold Gundersen. I am Chief Engi neer for Fairewinds Associates, a paralegal services and expert witness firm. I have b een retained by Southern Alliance for Clean Energy (SACE) to evaluate safety and licensing issues related to the replacement steam generators (RSGs) that Florida Power & Light Co. (FPL) installed in the Unit 2 St. Lucie nuclear reactor in 2007.
2. On March 9, 2014, I prepared a declaration in support of SACE's Hearing Request Regarding De Facto Amendment of St. Luci e Unit 2 Operating License (March 10, 2014), including two contentions challenging the lawfulness of the U.S. Nuclear Regulatory Commission's de facto amendment of the operating license for St. Lucie Unit 2 to allow operation of Unit 2 with substantially re-designed steam generators. The statements of fact I made in that declaration continue to be true to the best of my knowle dge, and the statements of my professional opinion in that declaration co ntinue to be accurate expressions of my best professional judgment.
3. The purpose of this Supplemental Declaration is to support SACE's Amended Hearing Request (April 24, 2014).
4. As summarized in ¶ 31 of my March 9 Declaration, my review of correspondence and documents related to St. Lucie Unit 2 and the San Onofre steam generators shows that FPL has made at least four major design changes to the steam generators for St. Lucie Unit 2.

Page 2 of 3 First, the RSGs no longer contained the stay cylinders that were part of the original steam generator ("OSG") design discussed in the Final Safety Analysis Report ("FSAR") as structural support for the reactor coolant system and included in the Aging Management Program (AMP). Second, documents related to subsequent inspections of the St. Lucie Unit 2 steam generators show that AREVA added 588 new tubes to the original 8,411 tubes, now

totaling 8,999 tubes. The addition of 588 new t ubes changes the pattern of water circulation in the steam generator and therefore has significant safety implications. Third, FPL replaced the pre-existing eggcrate tube supports with tref oil broached plates," despite the fact that such plates were specifically excluded from the original steam generator design for safety reasons. Finally, in order to accommodate the 58 8 new tubes, it is reasonable to infer that the region of the tubesheet that ha d been directly above the stay cylinder was now perforated with 588 new holes.

5. As discussed in my March 9 Declaration, all of these changes have major safety significance and exceed the reactor's design basis. In addition, these design changes increase the risk of steam generator failure and therefore have an ad verse effect on public health and safety.
6. At the time I prepared my March 9 Declaration, I did not have access to Amendment 18 of the updated Final Safety Analysis Report that FPL submitted to the NRC after it installed the RSGs ("UFSAR Amendment 18") (June 26, 2008) (ML14104B631). On April 15, 2014, the NRC's Public Document Room made that document publicly available. By comparing the text of the original 1980 FSAR ("OFSAR") with the text of UFSAR Amendment 18, I was able to confirm that FPL did indeed make all of the design changes described in ¶ 4 above. These changes to the text of the FSAR are discussed in more detail in SACE's Amended Hearing Request.

Page 3 of 3

7. In addition, as discussed in par. 4 of SACE's Amended Hearing Request, UFSAR Amendment 18 shows that FPL made an additi onal design change I was not previously aware of: it installed "steam nozzle venturis." The purpose of a steam nozzle venturi is to limit the rate at which steam (mass and energy) leaves the RSG in the event of a steam line break accident. The fact that FPL included this new component in the RSG design demonstrates that the mass and energy flow rate from the RSGs is greater than the mass and energy flow rate from the OSGs. The existence of a different mass and energy flow rate in the RSGs would also require FPL to perform a new and different accident analysis for the steam generators. Thus, the installation of steam nozzle venturis indicates that an important safety parameter has been changed between the OSGs and RSGs, resulting in reanalysis and modification from the original design. The in stallation of this additional component should have been identified in the 50.59 analysis and should have resulted in a license amendment.
8. In conclusion, UFSAR Amendment 18 confirms that FPL has made ma jor design changes to the steam generators for St. Lucie Unit 2 which exceed the reactor's design basis and increase the risk of steam generator failure at the reactor.

Under penalty of perjury, I declare that the foregoing statements of fact are true and correct to the best of my knowledge and that the foregoing statements of my opinion are based on my best professional judgment.

(Electronically signed pursuant to 10 C.F.R. § 2.304(d)(1))

Arnold Gundersen, MENE, RO Fairewinds Associates, Inc Burlington, Vermont 05401

Date: April 25, 2014

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