ML17352A808
| ML17352A808 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/12/1994 |
| From: | Croteau R Office of Nuclear Reactor Regulation |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| References | |
| TAC-M89668, TAC-M89669, NUDOCS 9410170193 | |
| Download: ML17352A808 (8) | |
Text
October 12, 1994 Mr. J.
H. Goldberg President Nuclear Division Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REQUEST FOR EXEMPTION SPECIAL USE OF THERMO-LAG FIRE BARRIERS IN OUTDOOR FIRE AREAS TURKEY POINT UNITS 3 AND 4 (TAC NOS.
M89668 AND M89669)
Dear Mr. Goldberg:
By letter dated June 15,
- 1994, you requested an exemption from the 1 and 3-hour fire barrier requirements of Section III.G of Appendix R to 10 CFR Part 50 for Thermo-Lag fire barriers in outdoor fire areas.
We have reviewed your request and concluded that additional information is required in order to complete our review.
Attached is our request for this additional information.
This requirement affects fewer than 10 respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
If you have any questions about this matter, please contact R.P.
Croteau at (301) 504-1475.
Sincerely, (Original Signed By)
Richard P. Croteau, Project Manager
'roject Directorate II-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated OFFICE LA:PDII-2:DRPE 6
PM:PDI I-2:DRPE
$ A:
'PE Docket Nos.
50-250 and 50-251 Distribution (Docket PlleP PUBLIC PDII-2 RF cc w/enclosure:
See next page SVarga ACRS (10)
DVerelli, RII Document Name G:)TP89668.RAI OGC To receive a copy of this document, indicate in box:
"C" = Copy without attachment/enclosure "E" = Copy with atta nclosure "N" = No copy NAME EDunnington RCroteau I adani DATE 10/ // /94 10/
I /94 1D/
/94
'FFICIAL RECORD COPY 94101701BI3 941012 PDR ADOCK 05000250 F
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Hr. J.
H. Goldberg Florida Power and Light Company Turkey Point Plant CC Harold F. Reis, Esquire Newman and koltzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036 Jack Shreve, Public Counsel Office of,the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 John T. Butler, Esquire
- Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Hr. Thomas F. Plunkett, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.
Box 029100 Miami, Florida 33102 Joaquin Avino County Manager of Metropolitan Dade County 111 NW 1st Street, 29th Floor Hiami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Generating Station U.S. Nuclear Regulatory Commission P.O.
Box 1448 Homestead, Florida 33090 Hr. Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.
Tallahassee, Florida 32399-0700 Hr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W. Suite 2900 Atlanta, Georgia 30323 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company P.O.
Box 029100 Miami, Florida 33102 Mr. H.
N. Paduano, Manager Licensing 5 Special Programs Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420 Hr.
Edward J.
Weinkam Licensing Hanager Turkey Point Nuclear Plant P.O.
Box 4332 Princeton, Florida 33032-4332
RE(VEST FOR ADDITIONAL INFORMATION In order to support the staff's review of the requested exemption, the following additional information is requested:
a ~
b.
c ~
In its submittal, the licensee stated that the as-installed Thermo-Lag fire barriers have a minimum fire rating of 30 minutes, based on the results of the Nuclear Energy Institute (NEI) Thermo-Lag fire barrier test program and the NEI application guide.
Some of the NEI test specimens in the NEI test program were not subjected to a hose stream test.
In addition, in reviewing the NEI test results (Test 2-2) and separating each fire barrier system into individual
- segments, as described by the NEI application guide, the NRC staff observed that individual conduit segments exceeded the temperature criteria prior to meeting the minimum 30-minute fire rating.=
The radial bend on the 2-inch dia'meter conduit test specimen exceeded the temperature criteria in 28 minutes and portions of the horizontal and vertical sections of the 3/4-inch diameter conduit test specimen exceeded the temperature criteria at 20 minutes.
- Thus, confidence in the barrier's fire endurance performance and its ability to resist minor external impact from falling objects or firefighting operations has not been established.
Since the specific outdoor applications that were tested by NEI were not subjected to a hose stream test, please justify how the test results establish the technical bases for accepting of the entire population of outdoor fire barrier assemblies installed at Turkey Point.
In addition, describe in detail how the results of the applicable fire test bounds the various installed outdoor raceway applications (e.g.,
conduit sizes, junction boxes, lateral
- bends, horizontal and vertical runs).
For the outdoor Thermo-Lag fire barrier assemblies installed to protect circuits needed for post-fire reactor
- shutdown, describe how the design parameters and the construction attributes used to install the fire barriers were verified to be the same as those used to construct the test specimens.
In addition, describe how the fire barrier design parameters and construction attributes (e.g., fire material thickness, caulk type used, wire tie spacing) of the field installations were bounded by the NEI test results.
For each fire barrier for which an exemption is requested, identify the barrier and describe location, the other fire protection features in the area, the amount and type of combustibles (e.g.,
fire load) in the area and its location relative to the fire barrier,'he safe shutdown function(s) being protected by the barrier assembly, and what impact its loss would have on plant safety.
In addition, provide drawings which show the routing of these fire barrier assemblies and their redundant safe shutdown function(s),
and the interrelationship (e.g., location and configuration) between the fire barrier/conduit assembly and in-situ combustibles in the fire area of concern.
d; Turbine failures (e.g.,
Salem overspeed event; Fermi blade failure) can lead to the failure of the turbine lube oil system and loss of lube oil from the turbine lube oil system.
In addition, the rupture of high pressure lube oil piping could result in a pressure-type fire.
In order to get a better understanding of the relationship of this major fire hazard to these fire barrier assemblies in the areas of concern, provide drawings that show the routing of the turbine lube oil system piping and the routing of those fire barriers assemblies that are located within 50 feet of this hazard and those which are in the immediate vicinity of but are just outside the 50-foot boundary, plant areas covered by automatic sprinklers, and the location of other major plant equipment (e.g.,
safe shutdown and safety-related).
In addition, provide an evaluation of the potential impacts turbine lube oil fires could have on these fire
- barriers, adjacent plant areas, and the safe shutdown capability.
e.
For the other major fire hazards in the vicinity of these fire
- barriers, provide a detailed fire hazard evaluation for each of these fire hazards (e.g., station transformers, potential Unit I and 2 exposure type fire hazards, hydrogen lines).
These evaluations should contain similar information to that specified for the turbine lube oil in Item d.,
above.
f.
In its explanation on how transient combustibles are controlled for outside
- areas, the licensee stated that the control of combustible program does not allow storage of combustibles in outdoor areas that contain safety-related equipment or cables.
It is not clear if this program applies to areas that contain safe shutdown cables and equipment.
In addition, plant procedures specify that flammable liquids be attended at all times and that a special permit is required for quantities greater than 5 gallons.
Does this include combustible liquids or is it limited to flammable liquids?
The licensee did not identify how transient combustibles are controlled with respect to assuring that the cumulative amount of transients and their concentration for several work activities in a given fire area does not exceed the maximum allowable heat release rate and potential fire duration which could degrade the fire-resistive rating of the subject fire barrier assemblies.
Describe and justify how the transient combustibles within a given fire area will be controlled so that the cumulative amount of combustibles will not challenge the fire-resistive rating of the barrier.
g..
The submittal stated that the transient combustible controls assure that a worst case transient.fire caused by a flammable liquids spill would be far below a hazard level that could challenge a 30-minute Thermo-Lag fire barrier.
To qualify this statement the licensee provided the following example:
the fire from a 20-gallon flammable transient spill (over a
15 square foot area) would generate a fire with a duration less than 15 minutes.
This assessment appears to equate that the burning duration of a fire is key to a fire barrier's
ability to provide protection.
In reality it is based on the fire barrier's ability to resist the intensity (energy released) of the fire itself.. Generally, flammable/combustible liquid-related fires, when they do occur, develop and propagate very quickly and their intensity is greater than a fire involving ordinary combustibles.
On that basis, a fire barrier test specimen which has been qualified by exposing it to an ASTH E-119 test fire would not obtain the same rating if it were exposed to the ASTH E-1529 Hydrocarbon fire curve.
For example,
- a. 30-minute fire barrier qualified by exposing it to ASTH E-119 standard fire would not be able to achieve a 30-minute rating if it were tested to the ASTH E-1529.
For those areas of the
- plant, where flammable and/or combustible liquid hazards could be
- present, in your fire hazard evaluations, as requested by items d
and e,
- above, please include an assessment of the effects a fire such as a hydrocarbon fire associated with a turbine failure event, a hydrocarbon fire resulting from a breakdown in the control of combustible program, etc.,
would have on the rating of ASTH E-119 tested fire barrier (30-minute Thermo-Lag fire barriers).
Your assessment should consider worst case credible fire scenarios and the interrelationship between the fire itself and the protective fire barrier system.
h.
For those outside areas of the plant not provided with automatic fire detection, please explain how a fire would be detected in these areas'f reliance is placed on the human element (outside areas harder to detect incipient smoke conditions),
has a study been done to determine what percentage of time these spaces are occupied by plant personnel?
If such a 'study does exist, please provide us with a summary of the methodology used to perform this study and its results.
The licensee's submittal indicates the fire brigade can respond to an outside fire within 15 minutes; therefore, a fire barrier safety factor of 2 exists.
This is somewhat misleading.
In order to judge the effectiveness of the fire brigade and its ability to mitigate a fire's potential impact on a fire barrier system, several factors in addition to response time must be considered (e.g., reflex time, which is the time span from the point when the fire is discovered/detected to the time the fire brigade is actually notified; fire fighting strategy development time, this is the time span where the brigade gathers and the fire brigade leader makes a
size-up of the situation and determines the best method to control and extinguish the fire; equipment deployment time, this is the time needed by the fire brigade to deploy hose lines, set up special fire fighting equipment, and get into position to attack the fire; fire control and extinguishment time, this is the time needed to control and extinguish the fire).
Considering a fire which could challenge an outdoor fire barrier system, please provide a summary of any fire brigade performance-oriented time lines evaluations which have been conducted, where individual fire brigade crews participated in actual training exercises using live fires that fully evaluated the fire brigade 'leader's ability to develop a firefighting strategy,
the deployment of firefighting equipment, and the brigade crew' ability to implement fire mitigation measures.
i.
These fire barriers are exposed to outdoor environmental conditions such as, rain, ultraviolet rays from the sun, salt spray, etc.,
which may have an effect on fire barrier performance.
Please provide a summary of the tests that you have performed and their results which confirm that the long-term effects of typical southern Florida environmental conditions will not cause a reduction in the fire-resistive performance of these barriers.
In addition, has any of the outdoor Thermo-Lag fire barrier installations ever been replaced as a result of environmental conditions?
If so, please summarize indicating what years it was replaced, how much was replaced during those years, and the reasons why it had to be replaced.
j.
Since the outdoor conduit Thermo-Lag fire barrier applications tested by HEI did not pass the acceptance criteria nor were they fully qualified as 30-minute fire resistive barriers, the cables protected by these barriers and their ability to perform their function become factors which need to be considered.
In order to "get an understanding of the thermal resistance of the cables by these barrier systems, please provide a description of the type of cables protected (i.e., control, power, instrumentation),
a description of their required function, the fire areas which these cables are routed through, the material composition of the cable insulation and jacket for each cable type, thermal properties of these insulation and jacket material types (e.g., material is thermoplastic or thermoset, short circuit temperature) and a
description of any cable functionality tests performed (e.g., air oven/hot megger tests and the results obtained by these tests.
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