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{{Adams
#REDIRECT [[L-95-325, Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks]]
| number = ML17228B355
| issue date = 12/04/1995
| title = Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks.
| author name = BOHLKE W H
| author affiliation = FLORIDA POWER & LIGHT CO.
| addressee name =
| addressee affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| docket = 05000335, 05000389
| license number =
| contact person =
| case reference number = FRN-60FR56359
| document report number = 60FR56359-00002, 60FR56359-2, L-95-325, NUDOCS 9512140083
| document type = LEGAL TRANSCRIPTS & ORDERS & PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
| page count = 4
}}
 
=Text=
{{#Wiki_filter:P RIDRIT'Y Z UDOCS OFFSITE FACILITY)-REGUGATOi INFORMATION DISTRIBUTIOhl'ÃPfEM (RIDS)ACCESSION NBR:9512140083 DOC.DATE:'95/12/04 NOTARIZED:
NO DOCKET¹FACIL:50-335 St.Lucie Plant, Unit 1, Florida Power&Light Co.05000335 50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.05000389 AUTH.NAME AUTHOR AFFILIATION BOHLKE,W.H.
Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Division of Freedom of Information
&Publications Services SIZE: R)-Misc Notice;Reg NOTES:
 
==SUBJECT:==
Comment opposing proposed generic communication,"Boraflex Degradation in SFP Storage Racks." DISTRIBUTION CODE: DS09DiCOPIES RECEIVED:LTR ENCL TITLE: SECY/DSB Dist: Public Comment on Propose Rule R, G p RECIPIENT ID CODE/NAME INTERNAL:>>
CENTER 0~6&/NR 1'~-18 RES/DRA/DEPY EXTERNAL: NRC PDR COPIES LTTR ENCL RECIPIENT ID CODE/NAME NMSS/IMOB T8F5 RES DIR RES/DST COPIES LTTR ENCL D 0 C u NOTE TO ALL'RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEI CONTACTTHE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.504-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS I'OR DOCUMENTS YOU DON'T iVEED!'l,'O'.I"AL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL
 
g/Sc/f~'an W+r.lc~/0 WR., Cc'5 Z'9'z/oI j%W Xl~zZ.Florida Power&Light Company, P.O.Box 14000, Juno Beach, FL 33408-tt420
~mn,~~~WZ.DEC<<~995 r L-95-325 r Chief, Rules Review and Directives Branch U.S.Nuclear Regulatory Commission Mail Stop T-6D-69 Washington, DC 20555-0001
 
==Subject:==
Proposed Generic Communication; Boraflex Degradation in Spent Fuel Pool Storage Racks 60 FR 56359 R ue t for mmen rr GiI r gl, Af-I A On November 8, 1995, the Nuclear Regulatory Commission (NRC)published for pqbTic comment,"Proposed Generic Communication; Boraflex Degradation in Spent Fuel Pool Storage Racks." These comments are submitted on behalf of Florida Power&Light (FPL), licensed operator of two nuclear power plant units in Dade County, Florida and two unifs in St.Lucie County, Florida.FPL notes that the EPRI studies reported in the draft generic letter were documented in 1993, and further investigations are ongoing.Specifically, EPRI report TR-103300 that states that the access of water to and around Boraflex panels is perhaps the most significant factor influencing the rate of Silica dissolution from Boraflex.In the"Requested Information" section of the draft, the NRC requests licensees to provide a description of the physical condition of the Boraflex, including any deterioration, on the basis of current, as well as, future projected accumulated gamma exposure and possible water ingress to the Boraflex.FPL contends that Blackness Tests and trending of Silica levels in the spent fuel pool (SFP)coolant is sufficient to monitor the performance of Boraflex in the SFPs.It is not necessary, nor is the information available, to project future degradation based on the access of water to and around the Boraflex.The NRC staff recognizes in the draft generic letter that the presence of borated water in pressurized water reactor (PWR)SFPs contribute to the margin on subcriticality.
However, the staff indicates that licensees will be requested to provide information on maintaining margin in unborated water.We believe that such a request is inconsistent with the stated benefit of borated water, particularly for PWRs.We note that the Westinghouse Owners Group (WOG)has submitted a topical report to the staff in an effort to credit boron in solution for criticality control in PWRs.In light of the WOG effort, we urge the staff to reconsider this information request to account for actual plant conditions.
We appreciate the opportunity to comment on this proposed generic'letter.
Very truly yours, W.H.Bohlke I PDR ADQCK 05000335 95i2i40083 95i204 Vice President H PDR.-+Nuclear Engineering and Licensing an FPL Group company t t 4 tt\g'k 1 f}}

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