ML17352A797
| ML17352A797 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/03/1994 |
| From: | Gunter P NUCLEAR INFORMATION & RESOURCE SERVICE |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9409290150 | |
| Download: ML17352A797 (5) | |
Text
P R.ICDR.IMW 1
ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9409290150 DOC.DATE: 94/08/03 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFILIATION GUNTER,P.
Nuclear Information
& Resource Service RECIP.NAME RECIPIENT AFFILIATION TAYLOR,J.
Ofc of the Executive Director for Operations
SUBJECT:
Informs of objection to FPL "Request for Exemption-Special Use of Thermo-Lag Fire Barriers in Outdoor Fire Area" re requirments of 10CFR50 App R.
DISTRIBUTION CODE:
DFOID COPIES RECEIVED:LTR 2 ENCL 0 SIZE:
TITLE: Direct Flow Distribution: 50 Docket (PDR Avail)
NOTES:
RECIPIENT ID CODE/NAME INTERNA : FILE CENTE~01 EXTERNAL: NOAC COPIES LTTR ENCL RECIPIENT ID CODE/NAME NUDOCS-ABSTRACT NRC PDR COPIES LTTR ENCL NOTE TO ALL RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE KVASTE!CONTACTTfIE DOCUMENTCONTROL DESK, ROO!i'I PI-37 (EXT. 504.2083 ) TO ELI iiIVATEYOUR NAZIE FRO.il DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON"I'EED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 4
ENCL
Nuclear Information ancI Resource service 1424 16th Street NW, Suite 601, Washington, DC 20036 202-328%002; fax: 202<62-2183; e-mail: nirsnetaol.corn August 3, 1994 Mr. James Taylor Executive Director for Operations U.S. Nuclear Regulatory Commission Mail Stop 17 G21 One White FlintNorth 11555 Rockville Pike Rockville, MD 20852-2738 Sir:
The purpose ofthis letter is to formally inform your office ofthe vigorous objection to Florida Power and Light's "Request for Exemption-Special Use ofThermo-Lag Fire Barriers in Outdoor Fire Area" as itpertains to certain requirements of 10 CFR Part 50 Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," for Turkey Point Units 3 and 4.
- 1) FPL's unique outdoor installation of essential power, control, and instrumentation cables used for safe shutdown capability constitutes an jggz~f vulnerability to fire and other hazards and failure to adequately protect these essential cables constitutes an undue risk to public safety.
Contrary to FPL's basic premise for exemption that there is no outdoor fire hazard postulated that can significantly challenge Thermo-Lag 330-1 fire barriers for essential cables and conduits used to assure safe shutdown capability or that both in-situ and transient combustibles can be controlled so as not to challenge Thermo-Lag fire barriers, NIRS enters the contention that precisely because these fire barriers are installed on essential cables outside of buildings and containment they represent an Qza~ risk due to potential fire hazards presently located at the plant 'complex as well as to potential external hazards that could enter the plant.
FPL bases its request on an application.ofthe D.C. Circuit Court ofAppeals 7'pl 6*
d f&*
"if&
p y
3 6
4 method works as well as one ofthe three stipulated by the NRC, in light ofthe identified fire 3
d 7 pl,l y 'ly& *4d."~,6733.26 334.
FPL further bases their exemption request on the analyses ofin-situ combustibles within 50 or more feet offire barriers and relatively small quantities oftransient combustibles as might be presented through work details (painting solvents), FPL further states that the basis oftheir 9409290150 940803 PDR iADOCK 05000250 P
PDR Pdnted on regaled ~r dedicated to a sound non-nuclear energy policy.
EDO 010336
e'xemption request focuses on fire barriers not being subject to fire damage Rom stratified gases or ceilingjet layers that can occur from indoor fires.
NIRS'ontends that FPL analyses ignores that the fire barriers are vulnerable to significant fire hazards that currently exist on-site through the potential rupture, spillage, transport, and ignition of large on-site transient combustibles in fuel storage bunkers as associated with natural disasters (tornadoes, hurricanes, lightning), and other external hazards as could be presented by example ofan air plane crash on-site or human motivated sabotage.
NIRS, therefore, contends that FPL has not presented suQicient postulated hazard analyses (PHA) to support the current re'quest for a thirty minute rating ofits Thermo-Lag 330-1 fire barriers through exemption &om requirements of 10 CFR 50 Appendix R.
It is ofadditional concern to NIRS that FPL did not make a suQicient presentation of these hazard analyses to NRC to warrant the granting ofthe previous exemption in wavering requirement ofdetection and suppression equipment for the one hour fire barriers currently installed out ofdoors, as required under 10 CFR 50 Appendix R.
- 2) Presence of Large Quantities of Potentially Transient Combustibles From Fuel Oil Fired Turkey Point Units 1 &2 As Based On the Hurricane Andrew Experience.
Turkey Point Units 3 and 4 are in relatively close proxcimity to Turkey Point Units 1 and 2 which are fuel oil fired units.
According to documentation prepared by Institute for Nuclear Power Operations and the U.S. Nuclear Regulatory Commission's "Report on the Effect of Hurricane Andrew on the Turkey Point Nuclear Generating Station &omAugust 20-30, 1992,"
on the morning ofAugust 24, 1992, as a result ofa wind generated missile, a metering tank containing Bunker C fuel oil for Unit 1 w'as punctured at the 25'evel resulting in "a large fuel oil spill" approximating 105,000 gallons offuel oil. The hurricane force winds then transported this combustible fuel oil over a wide area withinthe entire complex, including the Unit 4 Diesel Generator Building. It is NIRS'oncern that this spill and transport represents a very large and documented source oftransient combustibles that exists on site that is not accounted for in the FPL exemption request. An additional source ofpotential transient combustibles exists as the fuel oil storage tank for Unit 3 Emergency Diesel Generators is also not protected from missiles.
Furthermore, NIRS knows ofno effort on the part'of FPL to evaluate the fire hazard posed by the accidental or intentional rupture ofthe bunker fuel oil tanks for Units 1 and 2 and the diesel fuel storage tank for Turkey Point Unit 3 emergency diesel generators.
- 3) No Confidence in the Uniformityof Installation Practices and Certification of Installation ofThermo-L'ag 330-1 Fire Barriers at turkey Point Based on Experiences of Misapplications and Application Problems at River Bend, Grand Gulf, WPN-2, and Fermi-2.
Based on a NRC report. offact finding on River Bend Station (October 31, 1991),
installation and construction deficiencies in the Thermo-Lag fire barriers included insufficient thickness ofthe material on both one hour and three hour barriers, misinstallation ofthe material where ANCO, the subcontractor trained by TSI, removed stress skin and ribs &om the material.
The NRC report additionally noted that Thermo-Lag on floor-mounted conduits was "severely deteriorated" due to water exposure which caused the trowel-grade material to wash out ofthe seams leaving an opening for accelerated flame passage.
The NRC Trip Report further identified that the thickness ofthe ready-for-use fire barrier panels, whose manufacturer specifications for
~ 'w the one hour rated barrier required 0.5 inches, actually varied between ~ and 0.875 inches.
NIRS believes this report to have direct bearing on the FPL exemption request in part because
- 1) the large volumes ofunique out ofdoors applications ofThermo-Lag exposed to high humidity and rain at Turkey Point and, 2) documentation ofimproper installation and certification ofdeficient fire barrier materials.
The Washington Public Power Supply WPN-2 station noted in an LER dated 10/28/93 additional installation deficiencies were discovered.
As the LER describes, "The probable causes ofthese electrical separation deficiencies were less than adequate field installation procedures and as-built feedback into design drawings."
Grand Gulfon July 27, 1994, filed an LER documented improperly installed Thermo-Lag where the licensee was unable to determine ifthe improper installation "presents a significant condition at this time."
AJuly 15, 1994 filingofa 10 CFR Part 21 Report ofSignificant Safety Hazard by Detroit Edison for Thermo-Lag 330-1 installations at the Fermi-2 nuclear power station makes industry installation, training, and supervision practices, as well as certification ofinstallations even more dubious. While removing Thermo-Lag, Detroit Edison discovered shoddy Thermo-Lag installation work that involved instances of insufficient thickness'f the material,,
improper or missing structural supports (treated wood), inadequate penetration seals leaving cable ends exposed, and inadequate fastening ofThermo-Lag panels to support structures. Of particular note,.Thermal Sciences, Inc. had trained the subcontractor who installed the fire barriers, supervised the job, and certified by letter that installation had been completed according to the manufacturer's specification.
- 4) No Confidence in Licensees Analyses and Responses To NRC Warnings Pertaining to Deficiencies Identified with Thermo-Lag 330-1 Fire Barriers.
As early as March 25, 1987, as documented by a River. Bend Licensee Event Report, NRC and licensees have been aware ofimproper installation practices ofThermo-Lag fire barriers that have rendered the fire barriers inoperable. Subsequent NRC Information Notices and Bulletins, and a Generic Letter have warned the licensees of numerous deficiencies with the fire barrier. NRC further required the licensees to inspect their fire barriers and respond to a Request for Additional Information (RAI), as pursuant to 10 CFR 50.54(f), stating specific as-installed parameters as related to the resolution ofthe Thermo-Lag deficiencies.
It is ofsignificant concern that a number oflicensees in the RAI responses did not accurately depict important safety parameters of'as-installed Thermo-Lag fire barriers at respective plants. These inaccuracies serve to seriously undermine confidence that any ofthe licensees were able to accurately depict parameters ofas-is installed fire barriers.
Detroit Edison's response, February 11, 1994, did not, 'and from NIRS'osition could not, accurately depict the as-is installed barrier parameters until the aforementioned barriers were destroyed as a process ofremoval. Upon removal of the Thermo-Lag barriers, Detroit Edison discovered numerous improper installation practices and deficiencies that had been present since 1988 when the plant received its operation license &omNRC, Upon public revelation ofthese deficiencies, Detroit Edison then filed a Part 21 Report ofSignificant Safety Hazard.
Grand Gulfs response to the RAI, February 14, 1994, similarly failed to report conduit and pull box containing power cables for emergency switchgear and battery room ventilation fans with improperly installed Thermo-Lag.
Grand Gulfsubsequently filed a LER on July 27, l
~.
v
~
f r
l'994 identifying this deficiehcy and is still assessing whether the condition "presents a significant condition at this time,"
Additional examples underscore the NIRS lack ofconfidence that the licensees, including FPL, can either accurately assess the installation practices used at the plants or depend upon certification documentation to assure that installation meets even manufacturer specifications.
In conclusion, NRC and industry fire testing ofcarefully assembled and installed Thermo-Lag fire barriers have demonstrated that the supposed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated barrier lasts roughly 20 minutes. Departure from the use ofpristine Thermo-Lag samples and carefully controlled installations and testing procedures can lead to even quicker burn through times, For all ofthe above stated contentions, NIRS formally objects to FPL being granted an exemption from requirements of 10 CFR 50 Appendix R for as installed Thermo-Lag 330-1 fire barriers in special use applications as itpresents undue risk to public safety..
Sincerely, Paul Gunter, Director Reactor Watchdog Project Nuclear Information and Resource Service cc: OI OIG Honorable John Dingel