ML101670490
| ML101670490 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/08/2010 |
| From: | Florida Power & Light Co |
| To: | NRC/NRR/DIRS/IRIB |
| Jeremy Bowen, 415-3471 | |
| Shared Package | |
| ML101670555 | List: |
| References | |
| Download: ML101670490 (14) | |
Text
Enclosure 5 Turkey Point Nuclear Station Presentation Meeting Summary of the 6/8/2010 Meeting with NRC/SNC/FPL/SCE&G Dated June 17, 2010
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Overview
- Purpose and Attendees
- Background
- Specific Applicability of Screening Criteria
- N FPA 805 Project Status
- Closing Remarks F=PL.
2
Purpose and Attendees The purpose is to address NRC Staff's observations regarding applicability of the eight screening criteria for Operator Manual Actions (OMAs) to Turkey Point (PTN) based on FPL's current understanding of the Staff's process FPL Attendees:
FPL.
Rich Wright - PTN Operations Manager Larry Nicholson - Corporate Licensing Director Vinny Rubano - Corporate Project Engineering Manager Virginia Barry - PTN Senior Reactor Operator Glen Blinde - Corporate PRA Engineer AI Dunstan - PTN Fire Protection Engineer 3
=
Background===
FPL.
- Submitted Letter of Intent November 15, 2005 for transitioning to NFPA 805
- Completed Safe Shutdown Analysis upgrade:
- Corrective actions in place
- Appropriate compensatory measures implemented
- Procedure upgrade in-progress
- OMAs are:
- Compensatory measures for degraded fire barriers
- Based on RIS 2006-10 guidance 4
Criterion 1 - Number of OMAs FPL.
The number of OMAs is considered low based on the following:
~ 146 fire zones associated with the nuclear power block
~ -34% of these fire zones have no OMAs
~ Seven fire zones have >20 OMAs The number of OMAs ;s low I
- Modifications are proposed and being implemented to reduce OMAs (not waiting for NFPA 805 license amendment)
Criterion 2 - Single Fire Effect on Both Units
~~
FPL.
~ Fire in >95% of fire zones would not require shutdown of both units
~ Power generation circuits and components are functionally and spatially separated between units
~ Fire in shared systems does not cause unit trip or shutdown
~ Credible fire scenarios are well below Appendix R-scale fires
- Open turbine building and outside areas promote dispersion of smoke and hot gases
- Minimal intervening combustible loading Most fires would not require both units to shutdoJ:n 6
Criterion 3 - Thermoplastic Cable Insulation I=PL
~ Most original cable has thermoplastic insulation with flame retardant overspray
- Flammastic 71 A or 77
- Reduces flame spread and radiant energy exposure effects
- Credited coating is maintained
~ Instituted requirements to install qualified cables (early 1980s)
- New non-safety bus (C-Bus)
- Emergency power upgrade
~ Deterministic nature of Appendix R fire scenarios diminishes the significance of differences between thermoplastic and thermoset insulation combustion characteristics There is no safety issue with thermoplastic cable insulation The NFPA 805 Project is conservatively addressing the issue by fire PRA assuming all unprotected cable is thermoplastic 7
Criterion 6 - Use of Complex OMAs FPL OMAs are not considered complex at PTN based on the following:
~ Actions consist of one or two steps
~ Manipulations are used in normal operation and for routine maintenance clearances
~ Actions have been validated by walkdowns and/or analysis to have time margin
~ Operator training actions are similar to actions required for Appendix R safe shutdown
~ No special tools required for access or to perform manipulations
~ No repairs required OMAs are simple and consistent with routine operations 8
Criterion 7 - Cross-Tying Systems FPL
~ No cross-ties are created to achieve safe shutdown
- Shared systems are designed as such
- Shared systems are normally aligned and operated to support either or both units
- The current Internal Events PRA shows significant risk benefits for the ability to use shared systems
~ Systems and components are operated in a manner typical for normal or emergency use and are not required to operate outside reference bounds of component design to support safe shutdown No cross-ties created to achieve safe shutdown 9
Criterion 8 - Symptom-Based and Complex OMAs
~ Off-normal procedures are event-based I=PL
~ OMAs are prescriptive and proactive
~ None of the actions are considered complex Response procedures are event-based OMAs are prescriptive and not complex NFPA 805 SSA initiatives are reducing diagnostic and decision points and increasing prescriptive actions 10
Summary of Applicability
- 1 Screening Criterion Summary Application to PTN FPL Position 1 I A relatively large number of Operator
);> Total of 146 fire zones Not Manual Actions (OMAs) used to mitigate
~ Approximately 34% of fire zones have no OMAs Applicable cable separation issues
- > Only seven fire zones have >20 OMAs 2 I A single fire that could affect more than
>- In >95% of fire zones, dual-unit shutdown not required Not one unit
..,. Fire in shared systems are not shutdown initiators Applicable
,. Open areas substantially limit common exposure 3 I The use of thermoplastic cable insulation
- > Original plant cable has thermoplastic insulation Applicable
>> Flammastic overspray reduces flame spread
- . Used only qualified cables since early 19805 4
Limited documentation of cable routing Not Applicable within the plant 5
Self-Induced Station Black-Out strategy Not Applicable 6
Use of complex OMAs
>- OMAs are simple Not
>- Operator training actions similar to OMAs Applicable
>- No special tools or repairs required 7 I Mitigation of a fire requires cross-tying No cross-ties are created to achieve safe shutdown Not electrical or mechanical systems from Applicable multiple units in order to achieve safe shutdown for a fire in a single area 8 I Symptom-based fire response procedures
>- Response procedures are event-based Not with comDlex OMAs
>- OMAs are prescriptive and not complex F=PL.
11
NFPA 805 Project Status F=PL
- The first pass review has been completed for:
fundamental fire protection program and design elements, nuclear safety performance criteria radioactive release non-power operations Fire PRA draft model is developed and undergoing validation Risk evaluations have started
- license Amendment Request submittal is planned for the first quarter of 2011
- The first modifications are scheduled for fall of 2010 12
Closing Remarks
- Seven of eight screening criteria do not apply to Turkey Point.
- There is no safety issue with thermoplastic cable insulation
OMAs are being reviewed by the NFPA 805 Project to determine the need for such actions and to quantify the risk associated with any OMAs that remain Modifications are in progress to reduce reliance on OMAs 13 FPL