ML17354A909

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Refers to 980323 Request for Addl Info Re Exemption Request from Section III.G.2 of App R to 10CFR50 for Turkey Point Units 3 & 4.Informs of Omission of Page 4 & Forwards Copy of Page 4 to Be Retained w/
ML17354A909
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/23/1998
From: Jabbour K
NRC (Affiliation Not Assigned)
To: Plunkett T
FLORIDA POWER & LIGHT CO.
References
TAC-M99324, TAC-M99325, NUDOCS 9805040030
Download: ML17354A909 (8)


Text

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1 23, 1998 Mr. Thomas Plunkett President - Nuclear Division Florida Power and Light Company P.

O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND4 - CORRECTION TO A REQUEST FOR ADDITIONALINFORMATIONREGARDING FLORIDA POWER AND LIGHT EXEMPTION REQUEST FROM SECTION III.G.2 OF APPENDIX R TO 10 CFR PART 50, FIRE RATING FOR ELECTRICALRACEWAYFIRE BARRIER SYSTEMS USED IN THE TURBINE BUILDINGAREAS (TAC NOS. M99324 AND M99325)

Dear Mr. Plunkett:

By letter dated March 23, 1998, the staff provided Florida Power and Light a request for additional information (RAI) regarding the above subject for Turkey Point Units 3 and 4.

Due to an administrative error, the last line on page 4 was missing from our RAI. A corrected page is enclosed for your use.

We appreciate your staff bringing this matter to our attention.

Please retain a copy of the corrected page with the March 23, 1998, letter.

Ifthere are any questions regarding this matter, please contact me at (301) 415-1496.

Sincerely, Docket Nos. 50-250 and 50-251

Enclosure:

Page 4 of RAI

/s/

Kahtan N. Jabbour, Senior Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket File PUBLIC Turkey Point r/f JZwolinski FHebdon BCLayton OGC ACRS LPlisco, Rll

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 23, 1998 Mr. Thomas Plunkett President - Nuclear Division Florida Power and Light Company P.

O. Box14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND4-CORRECTION TO A REQUEST FOR ADDITIONALINFORMATIONREGARDING FLORIDAPOWER AND LIGHT EXEMPTION REQUEST FROM SECTION III.G.2 OF APPENDIX R TO 10 CFR

'ART 50, FIRE'RATING FOR ELECTRICALRACEWAYFIRE BARRIER SYSTEMS USED IN THE TURBINE BUILDINGAREAS (TAC NOS. M99324 AND M99325)

Dear Mr. Plunkett:

By letter dated March 23, 1998, the staff provided Florida Power and Light a request for additional information (RAI) regarding the above subject for Turkey Point Units 3 and 4.

Due to an administrative error, the last line on page 4 was missing from our RAI. A corrected page is enclosed for your use.

We appreciate your staff bringing this matter to our attention.

Please retain a copy of the corrected page with the March 23, 1998, letter.

Ifthere are any questions regarding this matter, please contact me at (301) 415-1496.

Sincerely, Docket Nos. 50-250 and 50-251

Enclosure:

Page 4 of RAI Kahtan N. Jabbour, Senior Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

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Mr. T. F. Plunkett Florida Power and Light Company TURKEYPOINT PLANT 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 Mr. 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 h/letropolitan 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 Mr. 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 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415

~Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Mr. 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 Mr. Kerry Landis

'U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415

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oil fire with water, a properly designed water spray system with open head nozzles, is needed.

The system design needs to consider energy output from the burning fuel and its configuration when burning. The burning characteristics dictate the distance the nozzle can be located from the hazard, the spacing between the riozzles, the required velocity of the water spray and rate of discharge from each systems'nozzle.

FPL in their supporting analysis for the exemption references a Factory Mutual Research Corporation Report, "Fire Tests of Automatic Sprinkler Protection for Oil Spill Fires," dated'September 9, 1957, and summarized the observations made by this report. This summary suggests that sprinklers would be effective at controlling,the hot gas layer of an oil spill fire.

The staff would like 'to review this re'port'in detail iri order to unde'rsta'nd'the insights and its applicability to fire conditions resulting from a turbine failure event.

The NRC staff r'equests that the referenced report and other referenced reports (e.g., V. Babrauskas, "Temperatures in Flames and Fires," May 1997) be provided to support its for review of the exemption request.

In a letter dated August 11, 1994, the NRC advised FPL that performance based approaches would not be considered by the staff as means to resolve the Thermo-Lag fire barrier issues.

Nevertheless, FPL used fire modeling calculations to support its exemption request.

These calculations were based on a limited postulated fire condition resulting from the failure the hydrogen oil seals on the generator and that the resulting lube oil fire is confined initiallyto the area under the generator between column lines B and D. The fire modeling calculation bases are limited in that they did not recognize other contributing factors such as the hydrogen bum from the seal failure but also from the hydrogen gas cylinders installed in the area of fire influence and'from the potentially broken insulators on the generator end of the isophase bus duct.

In addition, it needs to be recognized that some level of fire damage willresult to the energized electrical equipment (MCC 3A, neutral cell, isophase bus, potential transformer 3G07) and fire and electrical contribution added by these electrical hazards are uncertain.

The staff is also concerned that FPL's postulated fire did not consider other oil leakage sites (e.g., bearing assemblies at the low pressure to low pressure turbine interface and low pressure turbine to generator interface) and the potential for fires occurring at these sites.

FPL's fire predictions were based on theoretical calculations for heat release, ceiling jet at 12'-0" and 18'-0" ceiling elevations, ceiling jet velocity, and flame height. The overall fire prediction is based on a 28-minute duration, which is based on the assumption that the oil leak willnot exceed 450 gallons per minute and that during generator coast down the 10,000 gallon oil reservoir would be depleted in 23 minutes.

FPL also assumed that manual fire control would be implemented within 5 minutes and that hose stream flowwould provide additional heat removal from the fire.

In the fire prediction, from 6 minutes to 23 minutes, FPL limits the amount of lube oil available for combustion at a constant 1667 gallons.

FPL assumed this constant rate on the basis of that additional leakage flows into to the condenser and condensate pump pits. The resulting fire yields a maximum heat release rate of

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