ML17352B186
| ML17352B186 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/19/1995 |
| From: | Croteau R Office of Nuclear Reactor Regulation |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| References | |
| GL-92-08, GL-92-8, TAC-M85616, TAC-M85617, NUDOCS 9506050290 | |
| Download: ML17352B186 (6) | |
Text
Nay 19, 1995 Mr. J.
H. Goldberg President Nuclear Division Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420
SUBJECT:
RESPONSE
TO THE FOLLOW-UP TO THE REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 (TAC NOS.
M85616 and M85617)
Dear Mr. Goldberg:
We have reviewed your responses of December 16,
- 1994, and March 24, 1995, to the requests for additional information (RAI) of September 19,
- 1994, and December 26, 1994, respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers" and have determined that your responses to the RAIs are incomplete.
The specific areas where we found the responses to be incomplete are discussed in the enclosure.
Please submit a revised response addressing the areas described in the enclosure within 45 days of the receipt of this letter.
This requirement affects nine or fewer 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) 415-1475.
Sincerely,
/s/
Richard P. Croteau, Project Manager Project Directorate II-'13 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated Docket Nos.
50-250 and 50-251 Distribution Docket File PUBLIC PDII-1 RF cc w/enclosure:
See next page SVarga ACRS (4)
KLandis, RII Document Name G:)TURKEY(TP85616.RAI OGC To receive a copy of this document, indicate in the box:
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- Newman, Esquire
- Morgan, Lewis 8 Bockius 1800 M Street, NW Washington, DC 20036 1
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 ill NW 1st Street, 29th Floor Miami, 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 Turkey Point Plant Units 3 and 4
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 Hr. 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 Manager Turkey Point Nuclear Plant P.O.
Box 4332 Princeton, Florida 33032-4332
ENCLOSURE TURKEY POINT UNITS 3 AND 4 DOCKET NOS.
50-250 AND 50-251 FOLLOWUP REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 "THERMO-LAG 330-1 FIRE BARRIERS" 1.0 Request for Additional Information of September 19, 1994 In the RAI of September 19, 1994, the NRC staff requested information regarding important barrier parameters, Thermo-Lag barriers outside the scope of the NEI
- program, ampacity derating, alternatives and schedules.
The staff requested information describing the plant-specific corrective action plan for Thermo-Lag fire barriers outside the scope of the NEI program.
In its response of December 16, 1994, the licensee stated that configurations consisting
~ of banked conduits and some junction/pull boxes may be outside the scope of the NEI program.
For those
- raceways, outside the scope of the NEI program, that continue to be required for Appendix R safe
- shutdown, the licensee stated that it will have the option of upgrading the assembly to meet a qualified test configuration or pursue other options.
The licensee's response did not describe the evaluations or address the test program that will be used if these configurations are upgraded to meet the NRC's fire protection requirements.
Please provide information describing the methodology for determining the acceptable upgrades for Thermo-Lag barriers installed at Turkey Point that are outside the scope of the NEI program.
The staff requested information regarding the specific alternatives that will be utilized for achieving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers.
In its response of December 16, 1994, the licensee stated that one option was to implement compensatory measures for specific areas where redundant equipment is not available to meet the requirements of Appendix R.
In Generic Letter 92-08, the staff advised licensees to implement, in accordance with plant procedures, compensatory measures until the fire barriers could be declared operable.
The use of compensatory measures as a permanent solution to the Thermo-Lag issue is not consistent with the Staff Requirements Memorandum of June 27, 1994, which approved the NRC staff recommendation to return plants to compliance with existing NRC requirements.
Please provide additional information concerning the use of compensatory measures for achieving compliance with NRC fire protection requirements at Turkey Point Units 3 and 4.
During a public meeting on March 14, 1995, with the licensees for the four lead plants for the resolution of Thermo-Lag issues, the staff responded to the question "Will the resolution of the ampacity derating concern be deferred until agreement is reached on the appropriate testing protocol (i.e.,
IEEE P848)2" The staff reiterated its position, which was previously stated in the September 1994 RAI, that the ampacity derating concern could be resolved independently of the fire endurance concerns.
At this time the staff is not aware of any NEI initiative to address the ampacity derating issue.
After a review of the tests performed under the draft IEEE standard
- P848, the staff transmitted comments which were designed to ensure the repeatability of test results to the IEEE Working
group responsible for the test procedure.
The licensee is requested to submit its ampacity der ating evaluations, including any applicable test reports in order to provide an adequate response to Generic Letter 92-08 reporting requirement 2.(c).
In its response of December 16, 1995, the licensee stated that conduit inside containment is wrapped with a 1-hour Thermo-Lag design and that the fire protection design inside containment need only meet 10 CFR Part 50, Appendix R,
'Section III.G.2.f for radiant energy shields.
The regulation specifies that radiant energy shields be noncombustible.
The NRC staff provided information and data regarding Thermo-Lag combustibili,ty and test methods for determining the combustibility of materials in Information Notice 92-82, "Results of Thermo-Lag 330-1 Combustibility Testing;" in Generic Letter 86-10, Supplement 1;
and in a letter to NEI dated March 13, 1995.
The staff also discussed the combustibility issue during public, meetings on March 14,
- 1995, and March 29, 1995.
Please provide the methodology and schedule for resolution of the issue concerning the use of Thermo-Lag barriers as radiant energy shields at Turkey Point Units 3 and 4.
An Appendix R exemption request concerning the use of Thermo-Lag fire barriers in outdoor areas at Turkey Point was submitted by the licensee on June 15, 1994.
In a letter to the licensee dated October 12, 1994, the staff requested additional information regarding the exemption request.
To date, the licensee has not submitted a response to the RAI.
Please provide a schedule for responding to the RAI.
2.0 Request for Additional Information of December 26, 1994 In the RAI of December 26, 1994, the staff requested information describing the, examinations and inspections that will be performed to obtain the important barrier parameters for Thermo-Lag configurations installed at Turkey Point.
In its response of March 24, 1995, the licensee stated that walkdowns and destructive examinations, as discussed in the licensee's letter dated February 7,
- 1994, are being performed to verify installed configurations and important parameters.
The licensee's letters of February 7,
- 1994, and March 24, 1995, did not describe the examinations and inspections that are being performed to verify the important barrier parameters.
Please provide additional information describing the walkdowns and destructive examinations that are being performed to verify the important parameters for Thermo-Lag barriers installed at Turkey Point Units 3 and 4.
The NRC staff also requested information describing the specific tests and analyses that will be performed, including a schedule, to verify the Thermo-Lag materials at Turkey Point.
In its response of March 24, 1995, the licensee stated that it will perform chemical tests of 7 Thermo-Lag samples as part of the NEI generic chemical test program.
The licensee also stated that NEI will submit to the NRC a written report that documents the results of'the test program.
At a public meeting with NEI on March 29,
- 1995, NEI informed the staff that it was considering several options for additional testing and analysis of both organic and inorganic Thermo-Lag 330-1 constituents.
NEI will inform the staff about the revised program.
Subject to staff review and acceptance of the revised NEI
- program, and the testing of a sufficient number of samples, the staff finds licensee participation in the NEI program acceptable for obtaining the data and
information needed to evaluate the chemical consistency of Thermo-Lag 330-1 materials on a plant-specific basis.
The licensee did not submit a schedule for ve} ifying the Thermo-Lag materials at Turkey Point.
Please provide the requested schedule for completion.
In addition, after completion of the chemical testing
- program, the licensee should submit a report independent of the NEI report that is specific to the Thermo-Lag materials installed at Turkey Point.
The licensee should also submit its basis for determining that seven samples of Thermo-Lag are sufficient to ensure that the data obtained from the industry chemical test program is applicable to the total population of Thermo-Lag installed at Turkey Point.