ML17353A384
| ML17353A384 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/29/1995 |
| From: | Croteau R NRC (Affiliation Not Assigned) |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| References | |
| GL-92-08, GL-92-8, TAC-M85616, TAC-M85617, NUDOCS 9510040128 | |
| Download: ML17353A384 (9) | |
Text
Hr. J.
H. Goldberg President - Nuclear ~ision Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420
SUBJECT:
RESPONSE
TO THE FOLLOW-UP TO THE RE(VEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 (TAC NOS.
M85616 and H85617)
Dear Hr. Goldberg:
We have reviewed your responses of December 16,
- 1994, March 24,
- 1995, and July 13, 1995, to the requests for additional information (RAI) of September 19,
- 1994, December 26,
- 1994, and Hay 19, 1995, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers" with respect to ampacity derating.
You were required, pursuant to Section 182a of the Atomic Energy Act of 1954, as
- amended, and 10 CFR 50.54(f), to submit written reports, under oath of affirmation, that provided the information specified in the RAIs.
On the basis of our review, we have determined that your responses to the RAIs are incomplete.
The specific areas where we found the responses to be incomplete are discussed in Enclosure 1.
Please submit a revised response addressing the areas described in Enclosure 1 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 me at (301) 415-1475.
Sincerely, Richard P. Croteau, Project Manager Project Directorate II-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos.
50-250 and 50-251
Enclosures:
- 1. Request for Additional Information 2.
Memorandum dated May 22, 1995 Distribution Docket File
Enclosures:
As stated PUBLIC PDII-1 RF cc w/enclosures:
See next page SVarga ACRS (4)
- Previously Concurred KLandis, RII Document Name G:(TURKEY~ITP85616.AMP OGC To receive a copy of this document, indicate in the box:
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 September 29, 1995 Hr. 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.
H85616 and H85617)
Dear Hr. Goldberg:
We have reviewed your responses of December 16,
- 1994, March 24,
- 1995, and July 13, 1995, to the requests for additional information (RAI) of September 19,
- 1994, December 26,
- 1994, and May 19, 1995, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers" with respect to ampacity derating.
You were required, pursuant to Section 182a of the Atomic Energy Act of 1954, as
- amended, and 10 CFR 50.54(f), to submit written reports, under oath of affirmation, that provided the information specified in the RAIs.
On the basis of our review, we have determined that your responses to the RAIs are incomplete.
The specific areas where we found the responses to be incomplete are discussed in Enclosure 1.
Please submit a revised response addressing the areas described in Enclosure 1 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 me at (301) 415-1475.
Sincerely, Docket Nos.
50-250 and 50-251 Richard P. Croteau, Project Manager Project Directorate II-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosures:
- 1. Request for Additional Information 2.
Memorandum dated Hay 22, 1995 cc w/enclosures:
See next page
~i
Mr. J.
H.
Gol dberg Florida Power and Light Company Turkey Point Plant CC:
J.
R.
- Newman, Esquire
- Morgan, Lewis
& Bockius 1800 H 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 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 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. 0.
Box 029100 Miami, Florida 33102 Mr. H.N.
- Paduano, Manager Licensing
& Special Programs Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420 Mr. Edward J.
Weinkam Licensing Manager Turkey Point Nuclear Plant P.O.
Box 4332 Princeton, Florida 33023-4332
TURKEY POINT PLANT UNITS 3 AND 4 DOCKET NOS. 50-250 AND 50-251 FOLLOWUP RE VEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 "THERMO-LAG 330-1 FIRE BARRIERS" ENCLOSURE 1
1.0 BACKGROUND
1.1 RE(VEST FOR ADDITIONAL INFORMATION (RAI) 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 Nuclear Energy Institute (NEI) program, ampacity derating, alternatives, and schedules.
In its submittal of December 16, 1994, the licensee asserted that all raceways containing power cables that are protected by Thermo-Lag fire barriers will fall within the scope of the NEI test program.
The licensee stated that there is substantial margin in the applicable circuits, even considering an additional 10 percent derating factor.
The licensee will evaluate the results of'future NEI tests for each application of Thermo-Lag at the Turkey Point Plant.
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., Institute of Electrical and Electronics Engineers Standard P848 (IEEE P848)]."
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.
After a review of the tests performed under the draft IEEE
- P848, the staff transmitted comments that were designed to ensure the repeatability of test results to the IEEE working group responsible for the test procedure.
1.2 RE(VEST 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 the Thermo-Lag configurations installed at Turkey Point Plant.
In its submittal of March 24, 1995, the licensee indicates its belief that there is sufficient margin based on the present design to bound known ampacity derating test results.
After an acceptable plan and test methodology have been established and agreed upon and testing has been performed, the licensee will review test results to determine if there is any impact on calculations.
On May 18,
- 1995, members of the NRC staff held a telephone conference call with Nuclear Energy Institute (NEI) on ampacity derating issues for Thermo-Lag fire barriers.
The staff indicated that the latest IEEE P848 draft procedure can be used by licensees or NEI as the basis for an ampacity derating test program.
NEI agreed to review the Comanche Peak Steam Electric Station Unit 2 Safety Evaluation (SE) in order to develop a generic test program.
The memorandum dated May 22, 1995, which documents the subject telephone conference
- meeting, is attached for your information.
1.3 RE(VEST FOR ADDITIONAL INFORMATION OF MAY 19, 1995 In the RAI of Hay 19, 1995, the NRC staff requested that the licensee submit its ampacity derating evaluations, including any applicable test reports, in order to provide an adequate response to Generic Letter 92-08, Reporting Requirement 2(c).
In its submittal of July 13, 1995, the licensee asserted that the testing performed for Comanche Peak Steam Electric Station (CPSES),
Unit 2, shows that the conduit ampacity derating values for the Turkey Point Plant are reasonable.
Based on the findings of the NRC Safety Evaluation for CPSES, Unit 2 dated June 14, 1995, the licensee stated that there exists excess ampacity margin in the applicable Thermo-Lag enclosed electrical raceways.
The licensee also stated that discussions have been proceeding for over two years between the NRC staff and NEI on an applicable test procedure for ampacity derating and the licensee is not aware of an approved generic ampacity test protocol which is authorized for use by the NRC staff.
- 2. 0 STAFF POSITION The staff recognizes that most licensee may have excess ampacity margin using valid test data.
- However, those licensees who utilize industry test data must evaluate whether installed configurations are representative of the tested configurations.
The subject evaluations should also analyze any deviations of'he installed configuration with respect to the test configuration.
The licensee did not indicate that CPSES Unit 2 Thermo-Lag fire barrier configurations were representative of Turkey Point Plant configurations.
In its submittal of July 13, 1995, the licensee implied that site specific calculations were performed.
If those calculations represent the licensee's final determination of ampacity derating parameters for Thermo-Lag fire barriers, a copy of the subject calculations should be forwarded for NRC staff review..
The NRC staff expects that the licensee will submit, in conjunction with the resolution of the fire endurance
- issues, the test procedures or alternatively, a
description of the analytical methodology including typical calculations which will be used to determine the ampacity derating parameters for the Thermo-Lag fire barriers that are installed at the Turkey Point Plant.
The licensee's final evaluation on this issue should address the items of this section.
3.0 RE VEST FOR ADDITIONAL INFORMATION The licensee is requested to provide the site-specific schedule and plans for the resolution of the ampacity derating issue for Thermo-Lag fire barriers.
If an NEI test program or analysis is expected to be utilized by the licensee, please provide specific program details and incorporate any input by NEI into the licensee's overall schedule.
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