ML20003B650
| ML20003B650 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/19/1981 |
| From: | Harrison G Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20003B648 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8102250094 | |
| Download: ML20003B650 (5) | |
Text
'
UNITED STATES OF AMERICA a
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket Nos. 50-250-SP
)
50-251 -SP FLORIDA POWER & LIGHT COMPANY
)
(Proposed Amendments to
)
Facility Operating License (Turkey Point Nuclear Generating
)
to Permit Steam Generator Units 3 and 4)
)
Repairs)
AFFIDAVIT OF GREGORY A. HARRISON ON CONTENTION 14 I, GREGORY A. HARRISON, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Fire Protection Engineer in the Division of Engineering, Office of Nuclear Reactor Regulation.
2.
Contention 14 states:
The measures proposed to be taken to protect against fire hazards associated with the steam generator repairs are inadequate to pro-tect against radioactive releases in violation of 10 CFR Parts 20 and 50.
-I have reviewed the fire protection plan for the proposed steam generator repair contained in the Steam Generator Repair Report (p. C-4-1).
The staff review of this plan is contained in Section 3.2.3 of the Safety Eval-uation Report related to steam generator repair at Turkey Point Units No.
3 and 4 (NUREG 0756), dated December 1930. The contents of this section (copy attached) are true and correct to the best of my knowledge and I 8102250gON
2 hereby adopt it as my direct testimony on Contention 14. This section concluded, in relevant part, that the proposed repair could be conducted 4
without significantly increasing the potential for damage to safety-related systems as the result of fire hazards.
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/GregorfA,~jHarrison are -
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SubscribW and sworn to before me day of<.
...., 1981.
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'ilotary Public My Commission expires: / ^> ',
9 Gregory A. Harrison PROFESSIONAL QUALIFICATIONS I am employed as a Fire Protection Engineer in the Chemical Engineering Branch, Division of Engineering, Nuclear Regulatory Commission, Bethesda,
- Maryland, i
Ed uc a t io r.
B.S. Fire Protection Engineering, University of Maryland 196E; M.S. Civil Engineering, University of Maryland 1970; and U.S. Engineering Admini-stration, George Washingtoa, 1979.
I have received a certificate from Oak Ridge University covering the Radiation Safety Training Program.
In addition, I hold professional engineering registrations in California and Maryland in fire protection and civil engineering.
Experience k
I joined the USNL.
august,1977 as a fire protection engineer.
In this capacity I have performed inspections of power reactors during the con-struction st6ge to ascertain conformity with fire protection criteria; evaluated the adequacy of licensees' fire protection programs and its relation to the safety V operations.
Finally, I have prepared fire protection SERs for both BWF. and PWR plants.
Prior to joining the Commission I worked two years for the Arabian American Oil Company ( AP.AMCC) ir. Dhahram, Saudi Arabia.
I held the pcsition cf Chief, Fire Protection Engineer for the Facilities Enqineering Division.
From January,1973, to July,1975, I worked for the National Bureau of Standards in Gaithersburg, P.aryland as fire protection engineer in fire research testing, k
2-From July,1969, to January,1973, I worked as a general engineer with the Naval Ship Engineering Center, Washington, D.C.
From May,1967, to July,19E9, I worked as a fire protection engineer for hASA at Goddard Space Fligh: Center, Greenbelt, Maryland.
SER Dece-ber.1980 o
NUREG-0756 3.P.3 fIrc Protection fin evaluation of the fire protection progrr.m for the Turkey Point Plant Units 3 and 4 containment buildings was included in the NRC Safety Evaluation dated l' arch 21,197911 and supplemental information dated April 4. July 9, and Oct eer 9, 1980.18 This ir.4rmation is supplemented by the FPL report " Steam Generator Repair Report for the Turtcy Point Power Station, Units 3 and 4,"1 which addressed the specific fire hazards associated with the steam generator sepair outage.
In this regard it should be noted that a fire inside containment cannot cause of fsite radioactivity exposures of consequence because the fuel will be remosed from the containment of the unit ur. der repair nor can it impair the safe shutdown capability of the plant.
Nevertheless, the follcwing is a w mary of the fire protection measures to be taten during the repair opcrations.
The use of combustibles in the containment will be minimized to the extent p r.ic t ic abl e.
Fire retardant scaf folding and materials will be used.
Good houseteeping will assure that wood crates and other combustible trash are re,vsed f rom the cent ainment in a timely manner.
Me..eser, additional amounts of combustible materials will necessarily be intro-duced into containment including protective clothing, cleaning fluid, charcoal filters, and plastic sheeting, but the use of these will be minimized in those areas in which cutting and welding is being done.
The fire protection for the containment consists of fire extinguishers throughout the containment, and portable fire extinguishers will be accessible in the work areas when cutting and welding is performed.
A portable foam system suitable for use inside containment on liquid hydrocarbon fires will be onsite and promptly available upon demand throughout the repair.
The existing containment lighting system and emergency lighting are available.
Even though fPL will not provide a permanently installed fire water standpipe system in each containment before the initiation of the steam generator repair program, a fire hose of sufficient length to reach the most remote steam gener-ator compartments will be available and dedicated to fight fire inside contain-ment.
A fire watch will be continually present during all welding and cutting operations.
Administrative controls related to fire protection are presently in effect at the plant and are applicable during the steam generator repair outage.
Addi-tional fire protection personnel will be assigned to the replacement activities in the containment.
All administrative site procedures will be reviewed for the control of combustibles and these procedures will identify all known potential fire hazards.
A fire plan for the rdpair activities will be formu-lated end coordinated with the station fire plan.
Based on our review of the fire protection measures to be taken to protect safety-related structures, systems, and components, we have concluded that there is reasonable assurance that the proposed construction activities can be ceaducted without significantly increasing the potential for damage to safety-related systems.