ML17354A581
| ML17354A581 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/22/1997 |
| From: | Croteau R NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| TAC-M85616, TAC-M85617, NUDOCS 9707230301 | |
| Download: ML17354A581 (32) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 Ouly 22, 1997 fo ZX>/AS (
LICENSEE:
Florida Power and Light Company FACILITY:
Turkey Point Nuclear Plant 'Units 3 and 4
SUBJECT:
SUHHARY OF HEETING ON JULY 7,
- 1997, REGARDING FIRE BARRIER HODIFICATIONS (TAC NOS.
H85616 AND H85617)
On January 7,
1997, representatives of the Florida Power and Light Company (FPL), licensee for Turkey Point Nuclear Plant Units 3 and 4, met with members of the staff to discuss the current plans to upgrade the Thermo-lag fire barriers.
Enclosure 1 is a list of attendees.
Enclosure 2 contains copies of handouts distributed at the meeting.
The meeting focussed on the U.S Nuclear. Regulatory Commission (NRC) request for additional information dated June 16, 1997, in response to the licensee's exemption request dated December 12, 1996.
The exemption request involves fire barriers in outdoor fire areas, excluding the turbine area.
The NRC staff had requested additional information regarding the specific protection scheme (e.g., barrier, separati'on) for equipment, and other details on the various fire zones to evaluate the exemption request.
FPL indicated that it appeared that the NRC was taking a cable-specific approach to the exemption request,
- however, the licensee intended a plant-attribute approach.
The licensee stated that a cable-specific approach increases cost over the life of the plant and adversely impacts the schedule for resolution of the Thermo-lag issue.
The NRC staff indicated that additional information, as indicated in the June 16 letter, was necessary in order to evaluate the adequacy of use of horizontal separation or radiant energy shields in specific areas.
The licensee indicated that they would provide the requested information in two submittals.
First, the specific zones/areas using the 25-minute barriers would be'rovided approximately 30 days from the date of the meeting.
Subsequently, information would be provided in October 1997 regarding either (1) the specific details for each use or horizontai spacing or radiant energy llflilllfllllfllllllllflflllllff[lflllff 970723030i 970722 PDR ADOCK 05000250 P
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- shields, or (2) the criteria to be used to determine if the proposed horizontal spacing or use of a radiant energy shield would be adequate.
The NRC staff indicated that it may not be possible to develop an acceptable basis for option (2).
Docket Nos.
50-250 and 50-251 Original signed by Richard P..Croteau, Project Manager Project Directorate II-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosures:
l.
Attendance List 2.
Handouts cc w/
Enclosures:
See next page DOCUMENT NAME:
G:IITURKEY/MEETG.SUM To receive a copy of this document, Indicate In the bose C
~ Copy without attachment/enclosure E
m Copy with attachment/enclosure N
m No copy OFFICE PD I I -3/PH RAHE RCroteau
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DATE 07/ / /97 PDII-3/LA BCla ton 07/
/97 SICB THarsh 07/
/97 OFFICIAL RECORD COPY PD I I-3/D i
FHebdon 07/ 797
Florida Power and Light Company CC:
M. S.
Ross, Attorney Florida Power
& Light Company P.O..Box 14000 Juno
- Beach, FL 33408-0420 John T. Butler, Esquire
- Steel, Hector and Davis
- 4000 Southeast Financial Center Miami, Florida 33131-2398 Hr. Robert J. Hovey, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Armando Vidal County Manager Metropolitan Dade County 111 NW 1 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 Mr. 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 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company
'760 SW. 344th Street Florida City, FL 33035 Hr. H. N. Paduano, Manager Licensing
& Special Programs Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420 Mr. Gary E. Hollinger Licensing Manager Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Hr. T. F. Plunkett President Nuclear Division Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408-0420 Mr. Kerry Landis U.S. Nuclear Regulatory 101 Marietta Street, NW At)anta, GA 30323-0199 Regional Administrator, U.S. Nuclear Regulatory 61 Forsyth Street, SW.,
- Atlanta, GA 30303-3415 Commi ssi on Suite 2900 Region II Commission Suite 23T85
FPL NRC IVl e in
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7997 Lis of Attendees AME OFFICE R. Kundalkar R.
Hovey
'. Fisher T. Martin S. Newberry F.
Hebdon T. Harsh G. Hollinger J.
Manso H. Ross S.
West P.
Madden H. Schoppman R. Croteau FPL FPL FPL NRC NRC NRC NRC FPL FPL FPL NRC NRC FPL NRC
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TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Nuclear Regulatory Commission and Florida Power & Light Turkey Point Plant interface Meeting July 7, 1997 EtJCLOSURE 2
TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Introduction
+ Purpose
~ o To discuss F PL's December 12, 1996 submittal requesting an Appendix R 'exemption for specified outdoor areas at Turkey Point Units 3 8 4.
o Obtain NRC concurrence that the "plant attribute based" outdoor exemption request satisfies NRC exemption criteria.
+ FPL wants to bring the Thermo-Lag program to closure quickly o Maintain an adequate level of plant safety and fire safety o Continue an aggressive implementation schedule
+ ln May, NRC indicated agreement with Plant Attribute Based exemption o No Request for Additional Information was expected o Cable Specific exemption requirements not discussed
+ Expenditure of estimated
$20 million
'+ Cable specific exemption approach increases cost over the life of plant and adversely impacts schedule
+ Turkey Point is unique in its design and application of Thermo-Lag o Outdoor application o Quantity Plant attribute based - takes into account open air configuration, low in-situ combustible load, transient combustible controls, and available suppression compared to circuit protection options
TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT
+os., ~,o Recent Progress
~996
+ Ampacity Derating resolution submitted (6/96)
+ Indoor circuit analysis and modification package completed (12/96)
+ Containments and indoor areas modification packages issued(12/96)
+ Outdoor area exemption request submitted (12/96)
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+ January 7th meeting with NRC Staff
+ Responded to RAI regarding Ampacity Derating (3/97)
+ Completed modifications inside Unit 3 containment (3/97)
+ Completed fire barrier upgrades in two indoor zones (6/97) o Unit 3 West Penetration Room o Elevator Vestibule area
-+ Fire barrier upgrades in progress in three indoor zones (6/97) o North D.C. Equipment, Room o South D.C. Equipment Room o New Electrical Equipment Room
+ Developed turbine building fire scenario and proposed upgrades
+ May 6th 8 7th meeting with NRC staff on turbine building
+ Turbine building upgrades design in progress
+ Unit 4 Containment modifications scheduled for Fall 1997 outage
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~QO POI4p TURKEY POlNT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Thermo-I ag Installed P
+Turkey Point is unique in the large quantity of outdoor Thermo-Lag applications Estimate Thermo-Lag Installed
+ Containment 685 linear feet
+ Indoor Areas 636 linear feet
+ Outdoor Area (excluding the Turbine Building) 13,225 linear feet
+ Turbine Building Outdoor Area 2,322 linear feet Total 16,868 linear feet '
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POI TURKEY POINT NUCLEAR PLANT THERINO-LAG UPGRADE PROJECT
++o)y~g Q4 Outdoor Area Exemption Methodology T~kPtt ~tt t
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+ Majority of outdoor exemptions were not cable specific
+ Selected exemptions have been cable/function specific
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+ Plant features vs. protection level
+ Establishes plant attribute specific locations o Roof Tops, platforms, open landscape o Negligible, ln-situ, Low transient Combustible Areas o interface area from Turbine Building (Column line E to J)
(Being defined by 7/97 exemption request, in progress) o Turbine building Area
+ Establishes location specific protection o Separation (20-feet or 10-feet) o Fire Barriers (1-hour, 8 25-minutes resistive ratings) o Radiant Energy Shields (30-minute fire barrier resistive rating)
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TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Outdoor Area Exemption Methodology Basis for Plant Attribute Based Exam tion Receuest
+ "B" train circuits are protected o Few exceptions o Protection/Separation is based on fire hazard/geometry o "A" train is assumed to be affected by same fire o Any "A" train separation provides additional safety margin
+ Clearly defined areas of applicability allows for future inspections
+ Minimize/eliminate future exemption requests
+ Allows plant modifications without additional exemptions 1
+ Allows flexibilityof design
" + Efficient, cost effective solution with no reduction in safety
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TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT
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~O Outdoor Area Exemption Methodology FPL requests NRC concurrence with:
Outdoor Exam tions Re uest Summarized ~bPlant ~Location Includes:
Outdoor Area Exemption Request submitted 12/96 Turbine Building Exemption Request Scheduled 7/97
+ Roof Top Locations o 25-minute fire barrier, 'or; o 10-foot horizontal separation, or; o Radiant Energy Shield
+ Low/Negligible In-situ Combustible Locations (Non-Turbine Building) o 25-minute fire barrier, or; o 20-foot horizontal separation, or; o Radiant Energy Shield
+ Turbine Building Interface (Column Lines E to J) o 25-minute fire barrier with suppression, or; o 20-foot separation with suppression, or; o Radiant Energy Shield with suppression
+ Turbine Building Analyzed Fire Location o 1-hour barrier with suppression o Separation requirements do not apply
TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Oog
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Outdoor Exemption
- Request for Additional Information (6/97)
+ Outdoor Circuit Analysis Phase o Outdoor circuit analysis results would require future exemption submittals and approvals for implementation Impact:
Final resolution of Thermo-Lag may be delayed Additional regulatory review
+ Implementation Phase o Resolution of implementation issues may result in additional exemptions Impact: -
Final resolution of Thermo-Lag may be delayed Additional regulatory review
+ Future Changes o Plant modifications affecting Safe Shutdown raceways may require specific exemptions Impact: -
Prior NRC approval required despite 10 CFR 60.59 acceptability Potential for NRC review and approval on real time basis
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TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT
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Summary P
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'+ Plant attribute based exemption basis would remain consistent with previous exemption's
+ Plant attribute based exemption would not require future new exemptions to support plant modifications
+ Enhance timely resolution of Thermo-Lag issues and maintain current schedule
+ Plant attribute based exemption assures acceptable level of protection based on fire protection attributes of the affected zone
+ Plant attribute based exemption is auditabledbased on clearly specified criteria and areas of applicability
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>oI4p TURKEY POINT NUCLEAR PLANT THERMO-LAG UP G RADE P ROJ ECT Outdoor Exemption
- Request for Additional Information (6/97)
+ Proposed RAI response based on acceptance of plant attribute exemption methodology; o Information as requested by RAI $ 2.a would be provided o Information as requested by RAI g 2.b would be provided for the existing areas where separation and radiant energy shields are applicable.
o Information as requested by RAI g 2.c would be provided
+ FPL can provide the response outlined above by July 31, 1997
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TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT
+o ao
~o)ear N Conclusion
+ Plant attribute based exemption provides adequate assurance level of plant safety and fire safety is maintained
+ Plant attribute based exemption will support efficient implementation of Thermo-Lag upgrades
+ Plant attribute based exemption allows flexibilityof design
+ Plant attribute based exemption will reduce future exemption requests
+ Plant attribute based exemption provides the most efficient use of FPL and NRC resources with no reduction in safety
>or TURKEY POINT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT Outdoor Exemption - Request forAdditional Information 2.0 Request for Additional information In order to support the staff's review of the requested exemption, the following information is requested:
- a. Confirm that redundant post-fire safe shutdown trains/functions are separated by 20 feet, and for roof top fire zones, separated by 10 feet, the intervening space is free of in-situ or transient combustibles.
b.-
Identify the redundant post-fire safe shutdown trains/functions located within each fire zone; describe by fire zone; Raceway routing for each post-fire safe shutdown function and its separation from the redundant train; Identify the conduit/raceway and the post-fire safe shutdown function being protected and by what means; And the extent they are protected in each zone C.
Describe the radiant energy shield design and construction; Address how the design of these outdoor radiant energy shields will provide an adequate level of fire safety Provide reasonable assurance that one train of post-fire safe shutdown capability will be maintained free of fire damage.
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TURKEY POlNT NUCLEAR PLANT THERMO-LAG UPGRADE PROJECT
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+4 FPL Attendees Bob Hovey Raj Kundalkar Gary Hollinger Chuck Fisher John Manso Vice President - Turkey Point Vice President - Engineering Licensing Manager - Turkey Point Fire Protection Engineer Thermo-Lag Project Engineer A
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/'k CONCLUSION Based on the above the staff concludes th..'; the revised c~iteria for nonseismic moderate-energy lines at Perry is not consistent with Position B.3.d of BTP ASB 3-1 attached to SRP Section 3.6. 1, Revision 1.
The staff further concludes that the revised criteria were not considered in the conclusions reached in the staff's 1982 SER.
The conclusions reached in the Section 3.6. 1 of the SER were based on the staff's discussions with the AE and the licensee that complete ruptures of nonseismic moderate-energy piping systems were considered in the flooding analyses at Perry.
The staff requests that the licensee provide additional information to show how the requirements of GDC 2 and the guidance of RG 1.29 are met with respect to protection against the effects of earthquakes.
Such information should provide technical justification for the leak rates assumed for the nonseismic moderate-energy piping following an SSE.
If the licensee cannot justify the assumed crack size=during a seismic event, then leak rates associated with a full circumferential rupture should be assumed.
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SUBJECT:
SUMMARY
OF MEETING ON JULY 7,
- 1997, REGARDING FIRE BARRIER MODIFICATIONS (TAC NOS.
H85616 AND H85617)
Distribution pard~Co g
- -- Docket F..ile PUBLIC Turkey Point Rdg.
ACRS OGC R. Croteau F. Miraglia (FJH)
R.
Zimmerman (RPZ)
B.
Boger (BAB2)
P.
Madden (PHH)
G. Tracy (GHT)
S.
West (KSW)
F.
Hebdon (FJH)
S. Newberry (SFN)
S.
West (KSW)
M-Mail T. Marsh (LBH)
T.. Johnson, RII (TPJ)
D.
Ross (SLH3)
B. Clayton (BAC2)
L. Tran (LNT)
P. Fredrickson, RII(PEF)
T. Hartin (TTH)
P.
Madden (PHH)