L-96-285, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/96-11 & 50-251/96-11.Corrective Actions:Compensatory Measures in Form of Fire Watches for Fire Zone 64 & 143 Will Remain in Effect Until Mods Completed
| ML17354A347 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/12/1996 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-92-001, IEB-92-1, L-96-285, NUDOCS 9611210148 | |
| Download: ML17354A347 (7) | |
Text
CATEGORY Rr"..uuA RY INFORMATION DISTRIBUTI SYSTEM ACCESSION NBR:9611210148 DOC.DATE: 96/11/12 NOTARIZED:
NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C
05000251 AUDI.NAME AUTHOR AFFILIATION PLUNKETT,T.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 960818-961028 ltr re violations noted in insp rept 50-250/96-11
& 50-251/96-11.Compensatory measures will remain in place until Thermo-Log barrier upgrades are completed.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 EXTERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME CROTEAU,R ILE CE~
NRR DRCH/HHFB NRR/DRPM/PERB OE DIR RGN2 FILE 01 NOAC COPIES LTTR ENCL 1
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 17 ENCL 17
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....... ipany, P.G. -
r9000, Juno Beach, FL 33408-0420 NOV 1 2
$996 L-96-285 10 CFR 2.201 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 Re:
Turkey Point Units 3
E 4
Docket Nos.
SO-250/251 Really to Notice of Violation NRC Ins ection Re ort 96-11 Florida Power R Light Company has reviewed the subject inspection report and, pursuant to 19 CFR 2.201, the required response is attached.
If there are any questions, please contact us.
Very truly yours, T. F. Plunkett President Nuclear Division OIH Attachment cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC T..P.
- Johnson, Senior Resident Inspector, USNRC, Turkey Point Plant 96ii2iOi48 96iii2 PDR ADOCK 05000250 8
Attachment to L-96-285 Page 1
REPLY TO NOTICE OF VIOLATION RE:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 NRC Inspection Report 96-11 FINDING "During an NRC inspection conducted on August 18 to September 28,
- 1996, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions,"
(60 FR34381; June 30, 1995),
the violation is listed below:
10 CFR 50.48, Fire Protection,
- states, in part, that:
......all nuclear power plants licensed to operate prior to January 1,
1979, shall satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O.
Section III.G.2, states, in part, that:
where cables or equipment,.......,
of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area, outside of primary containment, one of the followinq means, of ensuring that one of the redundant trains is free oK fire damage shall be provided:
a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating; or
...b..
C.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
In addition, Eire detectors and an automatic fire suppression system shall be installed in the fire area; or Enclosure of cables or equipment and associated non-safety circuits of one train in a fire barrier having a one hour fire rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
10 CFR 50 Appendix B, Criterion III, Design Control,
- requires, in part, that measures shall be established to assure that applicable regulatory requirements (including 10 CFR 50, Appendix R) are correctly translated into specifi-cations.
Further< Criterion III requires that design changes be subject to design control measures which provide for verifying or checking the-adequacy of design.
Attachment to L-96-285 Page 2
Contrary to the above, Fire Zone 64 was designed and installed with a one hour barrier vice a three hour barrier in 1983.
Additionally, Fire Zone 143 was also designed and installed with a one hour barrier vice a three hour barrier in 1991.
- Further, no fire detectors andlor automatic fire suppression systems existed for either of these fire zones.
The two fire zones were required to meet 10 CFR 50, Appendix R, III.6.2, 'as delineated zn the Fire Hazards Analysis report in Updated Final Safety Analysis Report section 9.6A.
Since
- 1992, these two areas have been properly compensated for with fire watches as specified in NRC Bud.letin 92-01.
This is a Severity Level IV violation (Supplement I)."
RESPONSE
TO FINDING 1.
Florida Power
& Light Company (FPL) concurs with the finding.
2.
Reason for the violation:
A.
FPL failed to provide adeguate design control in that the design and construction of the Thermo-Lag fire barriers for these conduits did not identify Fire Zone 64 as an indoor area requiring a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrie Fire Zone 64, the control building elevator vestibule, has unique construction features.
The walls of Fire Zone 64 adjacent to the outdoor zones are not rated fire walls and the entrance into the area is open to the outdoors.
Fire Zone 64 has a ceiling which distinguishes it from the adjacent outdoor zones which have appropriate exemptions.
The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier installed on the conduits on the outdoor side of Fire Zone 64 was continued inside the Fire Zone 64 elevator vestibule.
B.
-.. FPL failed to provide adequate design control in that Fire Zone 143, the roof of the Unit 3 emergency diesel generator building, was considered to be a subdivision of the surrounding outdoor zones, which have approved exemptions to allow use of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier.
Therefore, an exemption for Fire Zone 143 was not requested.
Fire Zone 143, was created during the emergency power systems enhancement project to facilitate the safe shutdown analysis.
The essential cables were protected with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier which is consistent with the protective features that already exist in the plant for the surrounding outdoor fire zones.
Fire Zone 143 was initiated as a
convenience for the purposes of identifying the route of the new cables.
Corrective steps which have been taken and the results achieved:
Compensatory measures in the form of fire watches for Fire Zones 64 and 143 were in place at the time the deficiencies were identified.
These compensatory actions had previously been implemented as part of FPL's response to NRC Bulletin 92-01.
Attachment to L-96-285 Page 3
B.
A plant modification package has been issued to reflect the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier design requirement for essential cables located in Fire Zone 64.
C.
Fire Zone 143 was included as part of an exemption request for all outdoor areas submitted to the NRC by FPL letter L-94-146, dated June 15, 1994.
At the request of the
- NRC, FPL withdrew the exemption request on June 28,
4.
Corrective actions which will be taken to prevent further violations:
A.
B.
C.
As a result of NRC Bulletin 92-01, and consistent with FPL letter L-92-218 dated July 23,
- 1992, compensatory measures are in place for Turkey Point's Thermo-Lag fire barriers including Fire Zones 64 and 143.
These compensatory measures will remain in place until the Thermo-Lag fire barrier upgrades are completed.
Fire zones using Thermo-Lag fire barrier systems at Turkey Point are being addressed aq part of the overall Thermo-Lag upgrade program.
The Thermo-Lag upgrade program includes a review of the fire barrier design requirements for indoor and outdoor areas.
Since
- 1991, the FPL Nuclear Engineering Department has strengthened its technical expertise, ciesign production capability and involvement in the design change process.
FPL significantly reduced reliance on contractors and increased technical oversight of remaining contractor engineering work.
The date when full compliance was or will be achieved:
A.
Fire Zone 64, an indoor area, will continue to have compensatory measures in place until the indoor Thermo-Lag fire barrier upgrades are completed.
Fire Zone 64,
-.. an indoor area, will be restored to meet 10 CFR 50, Appendix R, Section III.G.2, by the end of the Unit 4 refueling outage currently scheduled for the Spring of
B.
Fire Zone 143, an outdoor area, will continue to have compensatory measures in place until the outdoor Thermo-Lacr fire barrier upgrades are completed.
Fire Zone 143 will be addressed as part of FPL's changes to the fire protection features and fire barrier design for cable raceway enclosures using Thermo-Lag for outdoor applications.
FPL's next submittal on outdoor fire barrier areas will be made by December 16, 1996.