ML022770013

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Request for Additional Information, the 10 CFR Part 50, Appendix R, K1 Exemption Clarification/Request
ML022770013
Person / Time
Site: Saint Lucie 
Issue date: 10/04/2002
From: Moroney B
NRC/NRR/DLPM/LPD2
To: Stall J
Florida Power & Light Co
References
TAC MB0300
Download: ML022770013 (6)


Text

October 4, 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. On November 29, 2001, FPL submitted the Fire Hazard Assessment of Exposure to Safe Shutdown Raceways, St. Lucie Unit 1. On May 12, 2002, FPL submitted a revised version of this report in response to a March 5, 2002, Request for Additional Information (RAI) from the U.S. Nuclear Regulatory Commission (NRC) staff.

The NRC staff has reviewed your latest 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 September 18, 2002. On September 20, 2002, Mr. Ken Frehafer of your staff agreed that a response would be provided by October 31, 2002.

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

ML022770013

  • See Previous OFFICE PDII-2/PM PDII-2/LA SPLB/SC PDII-2/SC NAME BMoroney BClayton EWeiss*

AHowe DATE 10/3/02 10/3/02 10/3/02 10/3/02

Mr. J. A. Stall ST. LUCIE PLANT 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. E. Rose Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. J. T. Voorhees Acting Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. William Jefferson Vice President, Nuclear Operations Support 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

Enclosure REQUEST FOR ADDITIONAL INFORMATION 10 CFR PART 50, APPENDIX R, EXEMPTION K1 ST. LUCIE PLANT, UNIT 1 DOCKET NO. 50-335 Please provide the following information regarding the Fire Hazard Assessment of Exposure to Safe Shutdown Raceways, St. Lucie Unit 1.

1.

The staff understands that to reduce uncertainty in the analysis and model conditions conservatively, consideration is routinely given to several factors. How would the model change if the following parameters were applied:



Electric Power Research Institute [1991] reports polyethylene/polyvinyl chloride cable heat release rates (HRR) between 312 and 589 kilo-watt per meter squared (kW/m2). The evaluation uses 400 kW/m2. Use the highest HRR for the maximum expected fire scenario.



The HRR is based on burning cable surface area. Utilize cable surface area instead of plan width (WP,c) for calculating the total HRR per meter of cable tray (qtot), in equation 2.



Utilize the plan width of the fire (WP,c), instead of the cable tray width (Wt) for calculating the fire area in equation 12. Add the area of both ends of the flame (2*Fh*Wt) for calculating the emissivity.



Since the model is not linear, utilize the critical target heat flux (qt) instead of the separation distance when calculating the safety factor.

2.

The Society of Fire Protection Engineers Engineering Guide titled: Assessing Flame Radiation to External Targets from Pool Fires, June 1999, recommends a factor of safety of two for well documented radiation correlation and models derived from experimental data. What is the factor of safety if flamemastic coating on the source fire and the target cable tray is taken into account?

3.

What is the minimum thickness of flamemastic coating needed for the assumption that flamemastic increases the minimum damaging heat flux of Institute of Electronic Electrical Engineers (IEEE) 383 non-rated cable to IEEE-383 rated cable? What is the thickness of the flamemastic coating on the source fire and target cables?

4.

What controls are in place to maintain an acceptable cable loading in the future?

5.

Are the following assumptions valid:



the exemption only pertains to cable trays in containment structure and the interior biological shield between radial column lines 2 and 6;



redundant cable trays have at least 7 feet (2.1meters) horizontal separation distance;



cables intersecting redundant cable trays are in conduit and protected;



no intervening or transient combustibles are located near the cable trays;



all electrical cabinets near the cable trays are enclosed with no ventilation openings; and



the bottom cable tray in each stack and the vertical cable trays have noncombustible covers.