ML020640534
| ML020640534 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/05/2002 |
| From: | Moroney B NRC/NRR/DLPM |
| To: | Stall J Florida Power & Light Co |
| Moroney B, NRR/DLPM, 415-3974 | |
| References | |
| TAC MB0300 | |
| Download: ML020640534 (5) | |
Text
March 5, 2002 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
ST. LUCIE PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE 10 CFR PART 50, APPENDIX R, K1 EXEMPTION CLARIFICATION/REQUEST (TAC NO. MB0300)
Dear Mr. Stall:
By letter dated October 4, 2000, Florida Power and Light Company (FPL) resubmitted Title 10, Code of Federal Regulations, Part 50, Appendix R, Exemption Request K1, which dealt with cable separation issues in the St. Lucie Unit 1 containment building. In subsequent discussions with the U.S. Nuclear Regulatory Commission (NRC) staff, the FPL staff indicated they could provide a plant-specific fire model, which would support a deterministic evaluation. On August 31, 2001, the NRC issued a Request for Additional Information (RAI) needed to continue its evaluation using a deterministic approach. In its November 29, 2001, response to the NRCs RAI, FPL enclosed the Fire Hazard Assessment of Exposure to Safe Shutdown Raceways, St. Lucie Unit 1.
The NRC staff has reviewed your submittal and finds that a response to the enclosed RAI is needed before the review can be completed.
This request was discussed with your staff on February 11, 2002. On February 27, Mr. Ken Frehafer of your staff agreed that a response would be provided within 45 days of receipt of this letter.
If you have any questions, please contact me at (301) 415-3974.
Sincerely,
/RA/
Brendan T. Moroney, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-335
Enclosure:
RAI cc w/encl: See next page March 5, 2002
ML020640534 OFFICE PDII-2/PM PDII-2/LA SPLB/SC PDII-2/SC NAME BMoroney BClayton EWeiss RCorreia DATE 2/27/02 3/1/02 3/1/02 3/4/02
Florida Power and Light Company cc:
Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Donald E. Jernigan, Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. R. G. West Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. T. L. Patterson Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. Don Mothena Manager, Nuclear Plant Support Services Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. J. Kammel Radiological Emergency Planning Administrator Department of Public Safety 6000 SE. Tower Drive Stuart, Florida 34997
REQUEST FOR ADDITIONAL INFORMATION 10 CFR PART 50, APPENDIX R, EXEMPTION K1 ST. LUCIE PLANT, UNIT 1 DOCKET NO. 50-335 Please provide the answers to the following questions regarding the Fire Hazard Assessment of Exposure to Safe Shutdown Raceways, St. Lucie Unit 1.
1.
What is the Factor of Safety built into your evaluation conclusions? Provide the critical spacing for the base case.
2.
Figure 3 shows flamemastic coating only on the cable trays. Were the individual cables completely coated also?
3.
The Institute of Electrical and Electronics Engineers (IEEE) Fire-Induced Vulnerability Evaluation (FIVE) final report, April 1992, utilizes a critical heat flux of 10 kW/m2 for qualified cable and 5 kW/m2 for non-qualified cable. Your evaluation utilized 11.7 kW/m2 for qualified cable and 5.7 kW/m2 for non-qualified cable from a 1991 IEEE report. Justify using the larger critical heat fluxes.
4.
Worst Case Fire: The modeling used cable loading from Trays M100, C100, and C101 with a total fill of 26 percent. However, at Plan Point 2307, Trays M120 and C120, has a fill total of 29.3 percent. Justify why the location chosen is the worst case fire loading?
5.
A stacked vertical tray configuration was modeled, but the drawing on page 1 of Appendix A of Attachment 3 shows the cable trays in a side-by-side configuration. The vertical height is over 9 feet and each tray is 2 feet wide giving the three trays a 54 ft2 (5 m2) surface area. The report models a 15-inch wide vertical fire at some undefined height, which doesnt seem to portray the actual configuration. In addition, wouldnt the fire grow horizontally on the lower and upper elevations at the same time? Justify in more depth the vertical cable fire scenario.
6.
Ventilation within containment can be considerable. Equation (10) assumes no wind effects, but in actual conditions in containment, mechanical ventilation produces wind-aided flame spread. Explain why the effect of wind was not considered in this analysis.
How would it effect the burning characteristics of the cable trays, the flame propagation speed, the height and location of the fire plume in respect to the target cable tray, smoke detector response time, and the evaluation conclusions?
7.
Pages 3-207 to 3-210 in the Society of Fire Protection Engineers (SFPE) Handbook of Fire Protection Engineering, 2nd Edition 1995, provide a discussion and correlation to determine the emissive power of large, sooty hydrocarbon fires. For example, Figure 3-11.10, on page 3-208 illustrates that the emissive power for liquid petroleum gas pool fires is a non-linear function of the pool diameter. Based on the experimental data, the
following correlation is provided to calculate emissive power of the fire, which is non-linear equation:
(
)
E E e E
e av m
SD s
=
+
1 Where Em = maximum emissive power of luminous spots (approximately 140 kW/m2),
Es = emissive power of smoke (approximately 20 kW/m2),
S = a parameter determined using experimental data (0.12 m-1), and D = diameter of the pool fire (m).
On page 26 of 62 of the St. Lucie Fire Hazard Assessment, Equation (12) is provided to compute the emissive power of the source fire, which is a linear function of cable tray width.
(12)
(
)
E Q
X F W
s R
s h
t
=
+
2 Where Es = emissive power of the source fire (kW/m2),
= radiant energy release rate (kW),
QR Xs = maximum flame spread distance (m),
Fh = flame height from a line fire (m), and Wt = width of the cable tray (m).
The units of emissive power are kW/m2, which are not consistent in Equation (12) as:
E kW m
m s =
+
2 Since emissive power is an important input to Equation (9) on page 26 of 62 to determine the radiative heat flux to the target (cables), explain why there is a basic difference between these two equations, i.e., linear and non-linear.
8.
Table 3 on page 30 of 62 provides the incident heat flux calculation for the maximum expected fire scenario. Provide details for the calculation of
, including values of all
qr variables, e.g., Fs-t, Es, Fh, etc. Provide the Equation Number used to calculate the values of td and
"
q r 9.
Provide the Equation Number used to calculate Target Heat Flux in the last column of the Table on page 45 of 62.
10.
Provide the values of Wp.c in Equation (2).
11.
Explain the difference between tb in Equation (4) and tdur in Equation (6).
12.
Equation (9) estimates heat flux at a target,
, but Tables 5a through 5h provide
"
q t calculations for (kW/m2). Explain the difference between these two heat fluxes.
q r 13.
The values from the SFPE Handbook appear to have been multiplied by 4 in Equation (10). Explain.