ML17309A668

Requests That NRC Reconsider 900830 & 1106 Denials of Amend Requests Relating to Moderator Temp Coefficient & Full Length Control Element Assembly Surveillance Requirements

ML17309A668
Person / Time
Site:	Saint Lucie
Issue date:	11/22/1991
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-91-275, NUDOCS 9112020147
Download: ML17309A668 (4)

Text

ACCELERATED DIS7RIBUTION "DEMONSTRATION SYSTEM

~ 0 REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9112020147 DOC. DATE: 91/11/22 NOTARIZED: NO DOCKET 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 SAGER,D.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Requests that, NRC reconsider 900830 & 1106 denials of amend requ'ests relating to moderator temp coefficient & full length control element assembly surveillance requirements. D DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution 3 ENCL 0 SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL D PD2-2 LA PD2-2 PD NORRIS,J D INTERNAL: ACRS NRR/DET/ECMB 7D NRR/DET/ESGB NRR/DOEA/OTSB11 NRR/DST 8E2 NRR/DST/SELB 7E NRR/DST/SICB8H7 NRR/DST/SRXB 8E NUDOCS-ABSTRACT O~C&ggCB OGC/HDS3 EG 01 RES/DSIR/EIB EXTERNAL: NRC PDR NSIC R

D D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPXES REQUIRED: LTTR 24 ENCL

p.0. Box 12o, . Pierce, FL 34954-0128 November 22, 1991 L-91-275 10 CFR 50.36 10 CFR 50.90 10 CFR 50.92 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Denial of Amendment Requests Relating to the Moderator Temperature Coefficient and Full Length Control Element Assembly Surveillance Requirements Florida Power and Light Company (FPL) requests that the NRC reconsider its denials of the Moderator Temperature Coefficient (MTC) and Full Length Control Element Assembly (FLCEA) proposed amendments transmitted to FPL by letters dated August 30, 1991, and January 31, 1991, respectively. The purpose of these amendments was discussed on November 6, 1991 in a meeting between NRC management and St. Lucie management personnel.

Since the mid-1980s, FPL has had in place a reactor trip and plant transient reduction program which has greatly reduced the number of reactor trips at St. Lucie. The MTC and FLCEA proposed amendments are .a continuation'f this program. While the associated surveillances to date have not caused reactor trips, they each have led to dropped control element assemblies, events that we consider potential reactor trip precursors. Therefore, FPL feels that important to continue efforts on these types of improvements to it is reduce challenges to safety systems.

FPL originally submitted the MTC proposed amendment on December 22,

.1987. This proposed amendment would remove the requirement for a 300 ppm boron MTC surveillance if satisfactory results were obtained earlier in the fuel cycle. This surveillance, which is an infrequent evolution, places the reactor in an abnormal configuration and exposes it to the potential for dropped CEAs. Zn fact, a CEA was dropped while moving CEAs during the most recent St. Lucie Unit 1 surveillance. The NRC has reviewed this amendment extensively, and it is our understanding that acceptable from a technical standpoint.

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Re: St. Lucie Units 1 and 2 Page,2.

Docket Nos. 50-335 and 50-389 Denial of Amendment Requests Relating to the Moderator Temperature Coefficient and Full Length Control Element Assembly Surveillance Requirements FPL submitted the FLCEA proposed amendment on February 12, 1990.

This proposed change would allow'or the extension of the surveillance interval for these requirements from once per 31 days to once per 92 days. In the past, performance of this surveillance has led to dropped CEAs on both St., Lucie units. Additionally, has demonstrated only limited value in detecting stuck CEAs since it most stuck CEAs are discovered prior to or during reactor startup and not during the performance of this surveillance. This change in frequency is supported in draft NUREG-1366 "Improvements to Technical Specification Surveillance Requirements".

FPL is continuing our improvement process for trip and transient reduction and is planning to submit other amendments that would also reduce the risk for reactor trips and transients. One amendment would provide'for bypassing of a High Startup Rate trip channel for periods longer than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> on St. Lucie Unit 1. We are also pursuing an amendment to increase the Loss of Load enable setpoint from 15% to 254.

In summary, FPL is concerned that the safety improvement associated 1

with these Technical Specification changes will. not occur if these amendments are not reviewed on their own technical merit and the overall context in which they are being submitted. FPL requests that, the NRC reconsider their denials and review the MTC and FLCEA proposed amendments.

truly yours, U'ery D. A. ger Vice esident St. ie Plant DAS:LLM:kw DAS/PSL 0568-91 cc: James G. Partlow, Associate Director for Projects, USNRC Steven A. Varga, Director Division of Reactor Projects-I/II, USNRC Gus C. Lainas, Assistant Director'or Region II Reactors,,

USNRC Stewart D. Ebneter, Regional Administrator, Region Senior Resident Inspector, USNRC, St. Lucie Plant II, USNRC