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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML20217F6171999-10-0808 October 1999 Forwards Insp Repts 50-335/99-11 & 50-389/99-11 on 990827 & 990907-09.No Violations Identified.Matl Encl Contained Safeguards Info as Defined by 10CFR73.21 & Disclosed to Unauthorized Individuals Prohibited by Section 147 of AEA ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML20209F1541999-07-0606 July 1999 Informs That NRC in Process of Conducting Operational Safeguards Response Evaluations at Nuclear Power Reactors. Plant Chosen for Such Review Scheduled for Wk of 990823-26 ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 ML20195F3871999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) IA-99-247, Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5)1999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML20207C7531999-05-17017 May 1999 Discusses Issue Identified by FPL in Feb 1998 Involving Potential for Fire to Cause Breach of Rc Sys High/Low Pressure Interface Boundary & NRC Decision for Exercise of Enforcement Discretion ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl 1999-09-28
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl ML17229B0851999-04-0505 April 1999 Requests Approval of Encl Relief Request 25 Which Proposes to Use Alternative Requirements of ASME Code Case N-613 in Lieu of Requirements of ASME Section XI Figures IWB-2500-7(a) & IWB-2500-7(b).Action Requested by Aug 1999 ML17309A9791999-03-31031 March 1999 Forwards Revised EPIPs Including Rev 2 to EPIP-00,rev 2 to EPIP-09,rev 2 to EPIP-10 & Rev 10 to HP-207.Summary of Revs Listed ML17309A9761999-03-23023 March 1999 Forwards Revised Epips,Including Rev 4 to EPIP-03, Er Organization Notification/Staff Augmentation, Rev 3 to EPIP-05, Activation & Operation of OSC & Rev 14 to HP-200, HP Emergency Organization. Changes to Epips,Discussed ML17229B0691999-03-19019 March 1999 Transmits TS Pages Requested by NRC for Use in Issuance of Proposed License Amend Re SFP Storage Capacity,Per Soluble Boron Credit ML17229B0721999-03-16016 March 1999 Requests Approval of Enclosed Relief Requests 23 & 24 Re ISI Plan for Second ten-year Interval.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML17229B0481999-03-10010 March 1999 Informs That Util Delivered Matls Requested in Encl 1 of NRC Ltr by Hand on 990308,as Requested by NRC Ltr Dtd 990218 1999-09-25
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ACCEI ERAT DOCUMENT DIST UTION SYSTEM e
REGULAT INFORMATION DISTRIBUTIO . STEM (RIDS)
ACCESSION NBR:9308260081 DOC.DATE: 93/08/23 NOTARIZED: NO DOCKET ¹ FACIL:,50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power a Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION BOHLKErW ~ HE Florida Power 6 Light Co. R RECIP.NAME RECIPIENT AFFILIATION Rules 6 Directives Review Branch (Post 920323)
SUBJECT:
Comments on Suppl to GL 86-10, "Fire Endurance Acceptance Criteria for Fire Barrier Sys Used to Separate Redundant Safe Shutdown Trains Within Same Fire Area."
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Florida Power S Lfght Company. P.O. Box 14NO, Juno Bench, FL 334M@420 August 23, 1993 L-93-207 Chief, Rules and Directives Review Branch
- .- -- U:S; Nuclear'Regulrrtory-Comrnfssiori
'ashington, DC 20555 RE: Supplement ¹), to Generic Letter 86-)0, "Fire Endurance Acceptance Criteria For Fire Barrier Systems used to Separate Redundant Safe Shutdown Trains within the Sam Fi On July 23, 1993, the Nuclear Regulatory Commission (NRC) published for public comment the referenced draft generic letter supplement. The letter disseminates to licensees the NRC position on fuc endurance test acceptance criteria for fire barrier systems used to separate redundant safe shutdown trains within the same fire ma. These comments are submitted on behalf of the Florida Power and Light Company (FPL). FPL is an investor-owned utility serving over three (3) million customers in the State of Florida. FPL is a licensed operator of two nuclear power plant units in Dade County, Florida and two units in St. Lucie County, Florida.
Comment 1)
In the event that a barrier does not meet the acceptance criteria for a specific fire rating only one option is discussed in the referenced document. This option requires qualification of the cable to the higher temperature seen in the enclosure at the completion of the fire endurance test. We propose that an additional option be provided consistent with Interpretation ¹4 of Generic Letter 86-10.
The licensee should be allowed to perform an evaluation of the adequacy of the Ore barrier to protect the redundant safe shutdown equipment and components (cable) from a design basis fire in a particular plant area, The evaluation would then be retained by the licensee for subsequent NRC audits. This is an extremely viable option, given the fire modelling techniques available in the industry today, and the inherently low combustible loading in most plant areas. One specific modelHng method (FIVE) has already been accepted by the NRC for PRA's.
an FPL Group company gio c 4 PDR F 'DR 930826008f 9308P3 ADQCK 05000335
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FKN: MJCLEAR L I CENS lhG TO: 3316528338 23> 1993 '7: 54AM tt581 L-93-207 Page?
Comments 2 through S apply to the functional testing requirements discussed in Attachment 1 to Enclosure 1 to Generic Letter 86-10, Supplement 1; Comment 2)
The proposed supplement discusseseable-insulation testing-as it mlates to engineering analyses .
that would be performed by the licensee to demonstrate functionality of the protected cable should the cable under test not meet the acceptance criteria under existing regulations. Paragraph c of the proposed supplement states in part that "Insulation resistance (Megger) testing provides an indication of the cable insulation resistance, whereas the high potential (Hi-Pot) test provides assurance that the cable has sufficient dielectric strength to withstand the applied rated voltage...."
In general, both of these tests are used to determine the condition of the insulation. The insulation resistance test is generally a non-destructive test used to determine the condition of the cable insulation; however, it does not give an indication of the total dielectric strength of the insulation. It may also reveal contamination present on the cable'in the form of moisture, dirt, or carbonization, (Note, that after the proposed testing the presence of dirt or other contaminants, particularly on the terminations. caused by testing could cause the cable to fail electrical tests to an erroneous conclusion that the cable would not have been operable in an actual 'eading installation,) The applied voltage during insulation resistance testing is generally low (e,g500 to 2500 V dc depending on the equipment being tested). Therefore, it has historically been a practice to proof-test medium voltage shielded power cable using high-potential testing.
High-potential (both ac and dc) testing is generally used to detect gross imperfections in the cable insulation, perforations of the insulation, or improper practices/materials used in splicing/teaninating the cable. High-potential testing of cables is only recommended for shielded power cables (these are generally cables rated h S000 V); however, based upon tests currently being performed by EPRI on aged cables, it appears that dc high-potential testing may significantly accelerate aging of the cable such that it may no longer be recommended as a test method. (Currently, there are at least two manufacturers of shielded power cable that state that dc high-potential tests shall not be performed on any cable that is 5 or more years old without their concmence.)
High-potential testing of non-shielded power cable is not recommended (including mediuin voltage non-shielded power cable) since it could cause the failure of an otherwise good cable (even a brand new piece of cable). Guidance for making high-potential tests on shielded power cable is provided in IEEE Std 400-1991. (Note, this standard is currently under revision to reflect the EPRI test findings as they relate to dc high-potential testing. It is likely that the revision to this standard will include alternative test methods such as low frequency e.g., 0.1 Hz testing. Once approved, it may no longer recommend dc high-potential testing of cable.) The test voltages recommended in the standard are based upon principles which relate to the cable's basic impulse level (BIL) rather than to the type and thickness of the insulation. This would then account for not only the operating voltage impressed on the cable during operation, but the surges that may be experienced by the system (and therefore the cable) during operation e.g., switching
t FRCN: MJCLEAR LICENSING TO: 38165K?638 23> 1993 7: 55CN rr581 P. 84 L-93-207 Page3 surges. In addition, the AEIC is proposing to eliminate dc high-potential testing for factory testing of cables in the draft revision of AEIC Std CS5, currently ready for ballot.
It is FPL's position that of the two tests described, only insulation resistance testing would be
- --applicable-to %ting the functionality sf a cable. that has not met the-rrcceptance.criterirrrfera test of a fire barrier. (This assumes that the test setup allows for proper and safe performance of the insulation resistance test, It is not clear that insulation resistance testing during the fire test can be done safely.) High-potential testing, even at reduced voltage levels,. would more than likely fail a cable that would have otherwise passed the test had it been subjected to only operating voltage during the test. Additionally, when examining a fire barrier or the performance of a cable during a test of the Qre barrier, it is assumed that the cable will be subject to only the maximum operating voltage.
Comment 8)
The proposed supplement, again in paragraph c., discusses the minimum acceptable insulation resistance in Mohms and then goes on to state "In addition, AC or DC high-potential (Hi-Pot) test for power cables greater than 1000 volts shall be performed after the post-fire megger tests to assess the dielectric strength. IMs test provides assurance that the cable will withstand the applied voltage during and after a fire...." ~
The high-potential test is inappropriate for this purpose as previously stated under Comment 2.
In general, the thickness of insulation on a power cable is far in excess of that necessary for the normal operating voltage applied to the cable, Mechanical strength of the insulation (e.g., that necessary to withstand handling during installation and termination) is the overriding consideration for determining the thickness, For example, based upon Table Bl in AEIC Stds CS6-87 and CS5-&7, the minimum average insulation thickness for an,8 kV rated cable, 1000 kcmil or less would be 115-140 mils for ethylene propylene rubber (EPR), thermoplastic, or crosslinked polyethylene (XLPB). Each of these insulating materials has a dielectric suength of at least 400 V/mil (ba'sed upon ASTM Std D 149). Using these numbers, the dielectric strength of the cable insulation based solely upon its minimum average thickness would range from 46-to 56-kV. It is this level of insulation that the high-potential test is designed to detect failure in, rather than whether the cable would withstand its operating voltage (i,e., the intent of the testing to be conducted under the proposed supplement).
Similarly, Table 3-1 of NEMA Std WC 7-1988 (ICEA S-66-524), and NEMA Std WC 8-1988 (ICHA S-68-516) specifies an insulation thickness of 30-45 mils, 55-80 mils and 65-95 mils for 14-9 AWG, 14/0 AWG and 225-500 kcmil cable rated 0-600 V. Again, considering the insulation has a dielectric strength of at least 400 V/rnil, these levels of insulation would correspond to 12-18 kV, 22-32 kV and 26-38 kV.
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The proposed supplement in paragraph c. presents a table of cable type, operating voltage and tests (including test voltages). The table recommends that insulation test voltages for insulation resistance testing of power cable Q 1000 Vac), power cable (< 1000 Vac) and instrument and control cable-(6-250-Vdc, 5 120 Vac) are 2500 Vdc-, 1500'Vdc and 500 Vdc, respectively.
Additionally, there is a note that states that an insulation resistance test voltage of 1000 Vdc is acceptable for power cable (< 1000 Vac), provided a high potential test be performed after the insulation resistance test. The proposed supplement states "The table below summariEes thb megger and Hi-Pot test voltages which, when applied to power, control and instrumentation cables, would constitute an acceptable cable functionality test,"
FPL disagrees with both the table and statement. For the reasons discussed in other comments high-potential testing of the cables should not be performed. In addition, recommending such tests for non-shielded low voltage power cable (i,e., c 1000 V ac) is contrary to all industry standards, even for newly installed cable. The use of a high-potential test for cables that have already sustained some damage during the fire barrier test to evaluate whether or not they would have been functional would be inappropriate.
Additionally, the test voltage for the insulation resistance measurements are too high. For example, the three industry standards that describe this testing for newly installed cable at generating stations and substations are IEBB Std 422-1986, IEEB Std 690-1984 and IBBB 525-1992. Each of these standards recommend that insulation resistance tests for low-voltage power and control cable be at a miniinum of 500 V dc. Recommendations vary on the need to insulation resistance test instrumentation cable. For example IEBB 690-1984, Appendix A, clause A10.1 (4) states "Insulation resistance measurements should be performed on instrumentation cables if circuit performance is dependent upon level of insulation resistance. Cable manufacturers'ecommendations should always be considered." If manufacturing standards are considered, both NEMA Std WC 7-1988 (ICEA S-66-524), and NEMA Std WC 8-1988 (ICEA S-68-516) recommend a test voltage of 100 to 500 V dc for insulation resistance testing of new cable at the factory.
The discussions above describe industry standards used to test new or newly installed cable. It would then seem reasonable that test voltages for the evaluation of cables that did not meet the acceptance criteria after the test of the fire barrier, be no more severe than those applied to newly installed cable.
FPL proposes the following test voltages for insulation resistance testing for the various cables tested (additionally, it is proposed that no testing be performed during the fire test unless it can be demonstrated that this testing can be done safely):
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~Cable T e Operating Megger test
~Volta ~Volta o Power Cable 21000 V ac 2500 V dc o Power Cable 1000 V ac V.dc 600 V ac S00 V dc o Power Cable 5300 V dc S00 V dc o Control Cable Cable'000
%40 V ac 5300 Y dc S00 S00 V dc V dc o Instrumentation 300 V dc Comment 5)
The high temperatures in the vicinity of the fire test chamber requires that the ends on of the cables under test be long enough to enable them to be in a satisfactory location for electrical testing (i.eaa an area cool enough for the test instruments and the test personnel). These longer cable ends may be subjected to mechanical damage, e.g., as the cable under test is moved about, which may alter test results due to damage unrelated to the specific purpose of the test.
Additionally, the use of test equipment in a high ambient temperature environment will affect the accuracy of the measurements taken as will the alternate of using long test leads (i.eaa to allow the instrument to be in a normal environment.).
Comment 6)
In paragraph c. the fourth paragraph discusses the need to "immediately" megger test all cables.
Performance of the megger test takes time, thus adding to the 1 or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> testing time since the test assembly would remain in the oven at or near'test temperature (the assembly and cable would see 1+ or 3+ hours of elevated temperatures). The additional time, at temperature, could cause a test failure. If high-potential testing as described in the proposed supplement, is also performed in the "oven" then the time of temperature exposure of the test assembly would be further increased. Ifthe'electrical cable testing is to be performed, it is more logical to complete the fire test, perform the hose stream test, then, ifnecessary, perform any electrical cable testing.
If the instrumentation cable's circuit performance is not dependent upon the level of insulation resistance, the ANS circuit integrity test shall be used as the acceptance criteria (i.e.. a test voltage of g to 10 V dc),
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L-93-207 Page 6 Comment 7)
Ideally, all terminations for the cable under test should be made before the fire test, however, due to the specific configuration of the test assembly this may not be possible. If the cable terminations are made after the test, this may also lead to misleading results. Movement of the tested cable.to enable-proper termination can-subject it.to mechanical forces that could damage the cable, causing it to fail.
Comment 8)
The proposed electrical tests used to determine functionality if the tested cable fails to meet acceptance criteria are new to the industry and should be reviewed for feasibility and personal safety implications. This process should include appropriate industry review (e.g., cable manufactures, IEEB, AEIC, ICEA, etc.).
Summary FPL considers that the cable circuit integrity and cable insulation testing described in Attachment 1 to Enclosure 1 to the proposed Generic Letter 86-10, supplement 1, will not properly demonstrate cable functionality. Instead it will demonstrate cable failure. Based on the proposed testing criteria for cables that requiie an engineering analysis to be performed to demonstrate functionality, few, if any cables would pass. In addition, the supplement, by omission appears to disallow engineering analysis previously acceptable for fire barriers in Generic Letter 86-10.
The testing proposed in the supplement is not consistent with, nor has it been approved by, the electrical cable engineering and flic test facility communities and lacks the appropriate industiy review process. For the reasons presented above, FPL requests that the cable functional testing requirements discussed in the proposed Generic Letter be revised to better test for cable functionality utilizing these and other industry comments.
FPL appreciates the opportunity to comment on the proposed Generic Letter supplement.
Should you have any questions, please contact us.
Very truly yours, W, H. Bohlke Vice President Nuclear Engineering and Licensing
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