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| {{#Wiki_filter:P RIDRIT'Y Z UDOCS OFFSITE FACILITY)-REGUGATOi INFORMATION DISTRIBUTIOhl'ÃPfEM (RIDS)ACCESSION NBR:9512140083 DOC.DATE:'95/12/04 NOTARIZED: | | {{#Wiki_filter:P RIDRIT'Y Z FACILITY) |
| 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. | | UDOCS OFFSITE |
| Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Division of Freedom of Information | | -REGUGATOi INFORMATION DISTRIBUTIOhl'ÃPfEM (RIDS) |
| &Publications Services SIZE: R)-Misc Notice;Reg NOTES: | | ACCESSION NBR:9512140083 DOC.DATE:'95/12/04 NOTARIZED: NO DOCKET ¹ FACIL: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 |
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| ==SUBJECT:== | | ==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:>> | | Comment opposing proposed generic communication, "Boraflex R, Degradation in SFP Storage Racks." |
| 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: | | DISTRIBUTION CODE: DS09D iCOPIES RECEIVED:LTR ENCL SIZE: |
| 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 | | TITLE: SECY/DSB Dist: Public Comment on Propose Rule R)-Misc Notice;Reg G p |
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| | RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL:>> CENTER 0 NMSS/IMOB T8F5 |
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| | PLEASE HELP US TO REDUCE WASTEI CONTACTTHE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS I'OR DOCUMENTS YOU DON'T iVEED! |
| | 'l,'O'.I"AL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL |
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| 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
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| ~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 | | ~'an W+ r.lc~ 'z/oIXl~zZ.j%W Cc Florida Power & Light Company, P.O. Box 14000, Juno Beach, FL 33408-tt420 |
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| | 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 |
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| ==Subject:== | | ==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. | | Proposed Generic Communication; Boraflex rr Degradation in Spent Fuel Pool Storage Racks Gi I r 60 FR 56359 R ue t for mmen gl, Af-I A |
| 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. | | 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. | | 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}} | | Very truly yours, W. H. Bohlke I 95i2i40083 95i204 PDR ADQCK 05000335 Vice President H PDR.-+ |
| | Nuclear Engineering and Licensing an FPL Group company |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARL-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking L-99-052, Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs1999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP ML17354B1421998-10-21021 October 1998 Directors Decision 98-10 Granting Request That NRC Investigate 2.206 Issues & Review Settlement Agreement & Denying Addl Requested Actions L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17229A8031998-07-13013 July 1998 Confirmatory Order Modifying License Effective Immediately. Order Confirms FP&L Commitment to Complete Final Implementation of Thermo-Lag 330-1 Fire Barrier C/As by 981231 W/Three Listed Exceptions L-98-145, Comment Opposing Proposed Communication Re Augmented Insp of Pressurized Water Reactor Class 1 High Pressure Safety Injection Piping1998-05-29029 May 1998 Comment Opposing Proposed Communication Re Augmented Insp of Pressurized Water Reactor Class 1 High Pressure Safety Injection Piping ML20217P6691998-04-0202 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards,Amended Requirements ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML20216C1991998-03-0303 March 1998 Comment on Proposed Generic Communication Re Yr 2000 Readiness of Computer Sys at Npps.Util Endorses Nuclear Energy Inst Comments.Comments Submitted on Behalf of Plant ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices L-97-269, Comment on Pr 10CFR55, Initial Licensed Operator Exam Requirements1997-10-21021 October 1997 Comment on Pr 10CFR55, Initial Licensed Operator Exam Requirements L-97-265, Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Prepardness Programs Safeguards Contingency Plan & Security Programs for Np Reactors1997-10-14014 October 1997 Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Prepardness Programs Safeguards Contingency Plan & Security Programs for Np Reactors DD-97-20, Directors Decision DD-97-20 Denying Request for Enforcement Action to Modify,Suspend or Revoke Licenses & Granting Request for Public Meeting in 970423 Petition & 970511 & 17 Suppls1997-09-0808 September 1997 Directors Decision DD-97-20 Denying Request for Enforcement Action to Modify,Suspend or Revoke Licenses & Granting Request for Public Meeting in 970423 Petition & 970511 & 17 Suppls ML17229A4481997-08-14014 August 1997 Exemption from Requirements of 10CFR70.24 Re Criticality Monitors ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML17354A5851997-07-14014 July 1997 Transcript of 970714 Meeting in Rockville,Maryland Re 2.206 Petition of T Saporito.Pp 1-141 ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137R4681996-12-10010 December 1996 Transcript of 961210 Proceeding in Atlanta,Ga Re Predecisional EC Re Facility Activities.Pp 1-151.Supporting Documentation Encl DD-96-19, Directors Decision DD-96-19 Under 2.206.Petitioners Requested Commission to Issue Confirmatory Order Requiring That Licensee Not Operate Plant Above 50% of power-level Capacity.Requests Denied1996-11-18018 November 1996 Directors Decision DD-96-19 Under 2.206.Petitioners Requested Commission to Issue Confirmatory Order Requiring That Licensee Not Operate Plant Above 50% of power-level Capacity.Requests Denied L-95-325, Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks1995-12-0404 December 1995 Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks L-95-270, Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommission of NPPs1995-10-15015 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommission of NPPs L-95-252, Comment Supporting RG DG-1043,Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator License Exams1995-09-12012 September 1995 Comment Supporting RG DG-1043,Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator License Exams L-95-195, Comment Supporting Proposed Generic Communication 10CFR50.54 Re Process for Changes to Security Plans W/O Prior NRC Approval1995-07-13013 July 1995 Comment Supporting Proposed Generic Communication 10CFR50.54 Re Process for Changes to Security Plans W/O Prior NRC Approval L-95-199, Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial1995-07-10010 July 1995 Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial L-95-188, Comment Opposing Proposed GL Relocation of Pressure Temp Limit Curves & Low Temp Overpressure Protection Sys Limits1995-06-27027 June 1995 Comment Opposing Proposed GL Relocation of Pressure Temp Limit Curves & Low Temp Overpressure Protection Sys Limits L-95-187, Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style1995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style DD-95-10, Notice of Directors Decision (DD-95-10) Re Request for Enforcement Action Against FPL for Allegedly Violating Antitrust License Conditions Applicable to Plant.Due to NRC Resolution,No Proceeding Re Petition Will Be Instituted1995-05-26026 May 1995 Notice of Directors Decision (DD-95-10) Re Request for Enforcement Action Against FPL for Allegedly Violating Antitrust License Conditions Applicable to Plant.Due to NRC Resolution,No Proceeding Re Petition Will Be Instituted ML20134N0621995-01-18018 January 1995 Partially Deleted Transcript of Interview W/A De Soiza on 950118 at Jensen Beach,Fl.Pp 1-40.Supporting Documentation Encl ML20134N0421995-01-18018 January 1995 Partially Deleted Transcript of Interview W/J Kunkel on 950118 at Jensen Beach,Fl.Pp 1-40 ML20134N0281995-01-18018 January 1995 Partially Deleted Transcript of Interview W/Eo Poarch on 950118 at Jensen Beach,Fl.Pp 1-78 ML20134N0301995-01-18018 January 1995 Partially Deleted Transcript of Interview W/H Fagley on 950118 at Jensen Beach,Fl.Pp 1-63 ML20134N0331995-01-18018 January 1995 Partially Deleted Transcript of Interview W/D Jacobs on 960118 in Jensen Beach,Fl.Pp 1-50 ML17228A9851995-01-17017 January 1995 Comment Supporting Proposal to Issue GL Providing Guidance for Determining When analog-to-digital Replacement Can Be Performed Under Requirements of 10CFR50.59 L-94-325, Comment on Proposed Rule 10CFR50 Re Fracture Toughness Requirements for LWR Pressure Vessels.Endorses NEI Comments & Recommendations1994-12-29029 December 1994 Comment on Proposed Rule 10CFR50 Re Fracture Toughness Requirements for LWR Pressure Vessels.Endorses NEI Comments & Recommendations L-94-329, Comment Supporting Proposed Rule 10CFR2 Re Policy Statement Rev, Policy & Procedure for Enforcement Actions; Policy Statement,Discrimination1994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR2 Re Policy Statement Rev, Policy & Procedure for Enforcement Actions; Policy Statement,Discrimination L-94-304, Comment Supporting Proposed GL Re Reconsideration of Nuclear Power Plant Security Requirements for Internal Threat1994-12-0202 December 1994 Comment Supporting Proposed GL Re Reconsideration of Nuclear Power Plant Security Requirements for Internal Threat L-94-249, Comment Opposing Proposed Rule Re Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants1994-10-0303 October 1994 Comment Opposing Proposed Rule Re Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072S5221994-08-25025 August 1994 Comment Opposing Petition for Rulemaking 9-2 Re Request for NRC to Revise Regulations of 10CFR9 to Provide Public Access to Info Held by Licensees But Not Submitted to NRC L-94-206, Comment Opposing Proposed Change to Rule 10CFR26, Consideration of Changes to Fitness for Duty Requirements. Util Wants Current Scope of Drug Testing in 10CFR26 to Be Retained & Current Trustworthiness Programs to Be Improved1994-08-0909 August 1994 Comment Opposing Proposed Change to Rule 10CFR26, Consideration of Changes to Fitness for Duty Requirements. Util Wants Current Scope of Drug Testing in 10CFR26 to Be Retained & Current Trustworthiness Programs to Be Improved ML20072B3251994-08-0101 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Change Consideration of fitness-for-duty Requirements L-94-150, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Licensees Conduct Independent Reviews of Emergency Preparedness Program from Annually to Biennially1994-06-17017 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Licensees Conduct Independent Reviews of Emergency Preparedness Program from Annually to Biennially ML17352A3171993-11-29029 November 1993 Exemption from Requirements of 10CFR73.55 1999-09-07
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARL-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking L-99-052, Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs1999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement L-98-145, Comment Opposing Proposed Communication Re Augmented Insp of Pressurized Water Reactor Class 1 High Pressure Safety Injection Piping1998-05-29029 May 1998 Comment Opposing Proposed Communication Re Augmented Insp of Pressurized Water Reactor Class 1 High Pressure Safety Injection Piping ML20217P6691998-04-0202 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards,Amended Requirements ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML20216C1991998-03-0303 March 1998 Comment on Proposed Generic Communication Re Yr 2000 Readiness of Computer Sys at Npps.Util Endorses Nuclear Energy Inst Comments.Comments Submitted on Behalf of Plant L-97-269, Comment on Pr 10CFR55, Initial Licensed Operator Exam Requirements1997-10-21021 October 1997 Comment on Pr 10CFR55, Initial Licensed Operator Exam Requirements L-97-265, Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Prepardness Programs Safeguards Contingency Plan & Security Programs for Np Reactors1997-10-14014 October 1997 Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Prepardness Programs Safeguards Contingency Plan & Security Programs for Np Reactors L-95-325, Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks1995-12-0404 December 1995 Comment Opposing Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks L-95-270, Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommission of NPPs1995-10-15015 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommission of NPPs L-95-252, Comment Supporting RG DG-1043,Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator License Exams1995-09-12012 September 1995 Comment Supporting RG DG-1043,Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator License Exams L-95-195, Comment Supporting Proposed Generic Communication 10CFR50.54 Re Process for Changes to Security Plans W/O Prior NRC Approval1995-07-13013 July 1995 Comment Supporting Proposed Generic Communication 10CFR50.54 Re Process for Changes to Security Plans W/O Prior NRC Approval L-95-199, Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial1995-07-10010 July 1995 Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial L-95-188, Comment Opposing Proposed GL Relocation of Pressure Temp Limit Curves & Low Temp Overpressure Protection Sys Limits1995-06-27027 June 1995 Comment Opposing Proposed GL Relocation of Pressure Temp Limit Curves & Low Temp Overpressure Protection Sys Limits L-95-187, Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style1995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML17228A9851995-01-17017 January 1995 Comment Supporting Proposal to Issue GL Providing Guidance for Determining When analog-to-digital Replacement Can Be Performed Under Requirements of 10CFR50.59 L-94-325, Comment on Proposed Rule 10CFR50 Re Fracture Toughness Requirements for LWR Pressure Vessels.Endorses NEI Comments & Recommendations1994-12-29029 December 1994 Comment on Proposed Rule 10CFR50 Re Fracture Toughness Requirements for LWR Pressure Vessels.Endorses NEI Comments & Recommendations L-94-329, Comment Supporting Proposed Rule 10CFR2 Re Policy Statement Rev, Policy & Procedure for Enforcement Actions; Policy Statement,Discrimination1994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR2 Re Policy Statement Rev, Policy & Procedure for Enforcement Actions; Policy Statement,Discrimination L-94-304, Comment Supporting Proposed GL Re Reconsideration of Nuclear Power Plant Security Requirements for Internal Threat1994-12-0202 December 1994 Comment Supporting Proposed GL Re Reconsideration of Nuclear Power Plant Security Requirements for Internal Threat L-94-249, Comment Opposing Proposed Rule Re Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants1994-10-0303 October 1994 Comment Opposing Proposed Rule Re Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072S5221994-08-25025 August 1994 Comment Opposing Petition for Rulemaking 9-2 Re Request for NRC to Revise Regulations of 10CFR9 to Provide Public Access to Info Held by Licensees But Not Submitted to NRC L-94-206, Comment Opposing Proposed Change to Rule 10CFR26, Consideration of Changes to Fitness for Duty Requirements. Util Wants Current Scope of Drug Testing in 10CFR26 to Be Retained & Current Trustworthiness Programs to Be Improved1994-08-0909 August 1994 Comment Opposing Proposed Change to Rule 10CFR26, Consideration of Changes to Fitness for Duty Requirements. Util Wants Current Scope of Drug Testing in 10CFR26 to Be Retained & Current Trustworthiness Programs to Be Improved ML20072B3251994-08-0101 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Change Consideration of fitness-for-duty Requirements L-94-150, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Licensees Conduct Independent Reviews of Emergency Preparedness Program from Annually to Biennially1994-06-17017 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Licensees Conduct Independent Reviews of Emergency Preparedness Program from Annually to Biennially ML20045F2091993-06-24024 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Supports Proposed Criteria L-93-116, Comment Endorsing NUMARC Comments Re Proposed Generic Communication, Availability & Adequacy of Design Bases Info1993-04-22022 April 1993 Comment Endorsing NUMARC Comments Re Proposed Generic Communication, Availability & Adequacy of Design Bases Info ML20092A3601992-02-0303 February 1992 Comment Endorsing NUMARC Comments & Recommendations Re Compatibility of Agreement States W/Nrc Regulatory Programs ML20092C0551992-01-30030 January 1992 Comments on Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73:Clarification of NRC Sys & Guidelines for Reporting ML17223B0001990-10-29029 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty Programs.Believes Proposed Rule Unnecessary & Places Undue Restriction on Util Mgt Prerogative ML20244B3241989-04-10010 April 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20154G1351988-05-0505 May 1988 Comment on Proposed Rules 10CFR50 & 73 Re Proposed Policy Statement on Nuclear Power Plant Access Authorization Program.Commission Urged to Establish Access Authorization Through Rulemaking Procedure 1999-09-07
[Table view] |
Text
P RIDRIT'Y Z FACILITY)
UDOCS OFFSITE
-REGUGATOi INFORMATION DISTRIBUTIOhl'ÃPfEM (RIDS)
ACCESSION NBR:9512140083 DOC.DATE:'95/12/04 NOTARIZED: NO DOCKET ¹ FACIL: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
SUBJECT:
Comment opposing proposed generic communication, "Boraflex R, Degradation in SFP Storage Racks."
DISTRIBUTION CODE: DS09D iCOPIES RECEIVED:LTR ENCL SIZE:
TITLE: SECY/DSB Dist: Public Comment on Propose Rule R)-Misc Notice;Reg G p
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL:>> CENTER 0 NMSS/IMOB T8F5
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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 rr Degradation in Spent Fuel Pool Storage Racks Gi I r 60 FR 56359 R ue t for mmen 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 95i2i40083 95i204 PDR ADQCK 05000335 Vice President H PDR.-+
Nuclear Engineering and Licensing an FPL Group company
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