ML14132A081
| ML14132A081 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/27/2014 |
| From: | Audrey Klett Plant Licensing Branch II |
| To: | Nazar M Nextera Energy |
| Klett A DORL/LPL2-2 301-415-0489 | |
| References | |
| TAC ME8990, TAC ME8991 | |
| Download: ML14132A081 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mana Nazar Executive Vice President and Chief Nuclear Officer NextEra Energy P. 0. Box 14000 700 Universe Boulevard Juno Beach, FL 33408-0420 May 27, 2014
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4-REQUEST FOR ADDITIONAL INFORMATION ON LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION (TAC NOS. ME8990 AND ME8991)
Dear Mr. Nazar:
By letter dated June 28, 2012, as supplemented by letters dated September 19, 2012, March 18, April16, and May 15, 2013, and January 7, 2014, Florida Power & Light Company (the licensee) submitted a license amendment request for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point 3 and 4). The proposed amendment requested approval to transition the fire protection licensing basis from Title 10 of the Code of Federal Regulations ( 10 CFR},
Section 50.48(b) to 10 CFR 50.48(c}, National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided by the licensee and participated in an audit at Turkey Point 3 and 4 the week of December 10, 2012. By correspondence dated September 11, 2012, March 15, 2013, November 7, 2013, and February 10, 2014, the NRC staff requested additional information. By letters dated September 19, 2012, March 18, April16, and May 15, 2013, and January 7 and April4, 2014, the licensee responded to those requests.
The NRC staff determined that it needs additional information to complete the review. The enclosure to this letter contains the NRC staff's request for additional information (RAI). As previously discussed with Ms. Olga Hanek of the licensee's staff, the NRC is requesting responses to the RAI by June 6, 2014.
If you have any questions, please contact me at (301) 415-0489.
Enclosure:
Request for Additional Information Docket Nos. 50-250 and 50-251 cc w/encl.: Distribution via Listserv Sincerely, Audrey L. Klett, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATION UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251 BACKGROUND By letter dated June 28, 2012 (Agencywide Documents and Management System (ADAMS)
Accession No. ML12191A048), as supplemented by letters dated September 19, 2012, March 18, April16, and May 15, 2013, January 7, 2014 (ADAMS Accession Nos. ML12278A106, ML13099A441, ML13109A008, ML13157A011, and ML14030A114, respectively), and April4, 2014 (ADAMS Accession No. ML14113A176), Florida Power & Light Company (the licensee) submitted a license amendment request (LAR) for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point 3 and 4). The proposed amendment requested approval to transition the fire protection licensing basis from Title 10 of the Code of Federal Regulations (1 0 CFR), Section 50.48(b) to 10 CFR 50.48(c), National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided by the licensee and participated in an audit at Turkey Point 3 and 4 the week of December 10, 2012. By correspondence dated September 11,2012, March 15,2013, November?, 2013, and February 10, 2014 (ADAMS Accession Nos. ML12256A935, ML13038A310, ML13312A230, and ML14016A064, respectively), the NRC staff requested additional information. By letters dated September 19, 2012, March 18, April 16, and May 15, 2013, and January 7 and April 4, 2014, the licensee responded to those requests.
The NRC staff determined that it needs the following additional information to complete its review.
As previously discussed with Ms. Olga Hanek of the licensee's staff, the NRC is requesting responses to its request for additional information (RAI) by June 6, 2014.
Enclosure Fire Protection Engineering RAI 16 The staff identified a number of inconsistencies related to Turkey Point's LAR (ADAMS Accession No. ML12191A048) Attachment L, approval request 7, during the finalization of the safety evaluation, related to the Unit 3 emergency diesel generator (EDG) day tanks. The licensee quoted NFPA 30, Flammable and Combustible Liquids Code (1976 Edition), Section 2-4.4.3 as follows:
Tanks for storage of Class I or Class II liquids inside of buildings shall be provided with either:
(a) a normally closed remotely activated valve; (b) an automatic-closing heat-activated valve; or (c) another approved device on each liquid transfer connection below the liquid level, except for connections used for emergency disposal, to provide for quick cut-off in the event of a fire in the vicinity of the tank.
This function can be incorporated in the valve required in 2-4.4.2, and if a separate valve, shall be located adjacent to the valve required in 2-4.4.2.
The licensee's description of the condition requiring approval is:
NFPA 30 states that tanks inside buildings with Class II or lilA liquids shall have a valve capable of quick cut-off in the event of a fire in the vicinity of the tank. The Unit 3 [EDG] day tanks do not have valves that meet the criteria of this section.
Each Unit 3 EDG day tank is located in a small dedicated room in the Unit 3 EDG building, above their respective EDG. Each room is segregated by three hour rated fire barriers, a pre-action suppression system, and containment in the event of a tank leak. Each day tank is equipped with two drain lines which each have a normally closed shutoff valve. The other line below the liquid level is the discharge line to the engine driven fuel pump. The discharge line to the fuel pump is equipped with a normally opened ball valve outside of the day tank room.
The basis for the approval request of this deviation is:
The tanks are located in small individual and dedicated segregated rooms with automatic fire suppression, rated barriers, and limited combustibles.
The staff has identified the following inconsistencies:
- 1. There appears to be a discrepancy regarding the description of the plant configuration versus the requirement ("Class I or Class II" versus "Class II or lilA").
- 2. It is not clear whether all of the connections to the tank have been identified.
- 3. The non-conforming condition is not clearly identified; nor is there a connection made between this condition and the provided basis for approval.
- 4. The concluding discussion for the approval request (where nuclear safety capability assessment, radiation release, defense-in-depth, and safety margins are addressed) does not include details of the EDG day tanks, while discussing the diesel driven fire pump in detail.
- 5. The fire protection systems and features described in the basis for approval are not listed as required for this approval in the LAR Attachment C, C-2 Table.
- 6. The NFPA 30 Code Compliance Evaluation, referenced in the LAR Attachment A, Table B-1 identifies, for NFPA 30 Section 2-4.4.3, that the Unit 4, 4A and 48 EDG fuel oil tanks do not have a valve meeting the requirements of this section of the code, whereas the Approval Request #7 indicates that the Unit 3 EDG day tanks do not have the appropriate valves.
- 7. The justification in the Code Compliance Evaluation indicates that adding such a valve would introduce another potential failure mode that could result in loss of fuel supply to support EDG extended operation, but this was not addressed in the Approval Request #7.
To resolve these inconsistencies:
a) Identify to which tanks Approval Request #7 applies. Provide the information requested below for each tank identified.
b) Provide a clearer description of the tanks and lines with regard to the requirement.
c) Provide a clear description of the non-compliance being analyzed.
d) Provide a clearer connection between the requirement that is not being met, the plant configuration and installed fire protection systems and features, and the resulting acceptability of the current arrangement, including fire response procedures, if applicable.
e) Revise the conclusion of Approval Request #7 to address the identified tanks, not just the diesel driven fire pump.
f)
Provide a revised C-2 table that shows that the fire protection systems and features relied on for the acceptability of this approval request are required fire protection systems or features. Perform an extent of condition review to ensure that all other systems or features similarly relied on for acceptability are properly identified in the C-2 table as required.
ML14132A081 OFFICE LPLII-2/PM LPLII-2/LA NRR/AFPB/BC NAME A Klett BCiayton AKiein (FSaba for)
(CMoulton for)
DATE 5/15/14 5/12/14 5/16/14 RidsAcrsAcnw_MaiiCTR RidsNrrDraAfpb BMiller, NRR CMoulton, NRR LPLII-2/BC (A) LPLII-2/PM LRegner A Klett 5/27/14 5/27/14