ML20003B655

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Affidavit Re Fire Protection Tech Specs Issued on 781108 & Review of Facility Fire Protection Program Leading to 790321 Safety Evaluation & Suppls.Prof Qualifications & Certificate of Svc Encl
ML20003B655
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 02/19/1981
From: Grotenhuis M
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20003B648 List:
References
ISSUANCES-SP, NUDOCS 8102250099
Download: ML20003B655 (5)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Decket Nos. 50-250-SP

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50-251 -SP FLORIDA POWER & LIGHT COMPANY

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(Proposed Amendments to

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Facility Operating License (Turkey Point Nuclear Generating

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to Permit Steam Generator Units 3 and 4)

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Repairs)

AFFIDAVIT OF MARSHALL GR0TENHUIS ON CONTENTION 14 I, MARSHALL GROTENHUIS, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation.

2.

I am the Project Manager assigned to the Turkey Point Plant steam generator repair program.

3.

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.

As Project Manager. for the Turkey Point Plant Units 3 and 4, I participated in i

and supervised the preparation of the existing fire protection Technical Specifications issued on November 8,1978 and the review of the Turkey Point i

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81022 50 ogg

. Fire Protection Program which led to a Safety Evaluation Report, issued March 21, 1979 and supplemental reviews, issued on April 3 and July 9, 1930, and January 26, 1981. The sole outstanding items in the overall fire protection program for the Turkey Point facility are: (1) fire water supply adequacy, (2) auxiliary building corridor protection, (3) cable spreading room protection, and (4) fire brigade staffing and training.

An explanation and Staff position on these matters is contained in a letter from D. Eisenhut, NRC, to all pre-January 1, 1979 licensees, dated November 24,1930(AttachmentA). The Applicant's position on these matters, including resolution of item (4) is contained in a letter from R. Uhrig to D. Eisenhut, dated February 4,1981 (Attachment B).

The March 21, 1979 fire protection Safety Evaluation Report concluded that the plant could operate safely while the above outstanding items are being resolved and that adequate measures of fire protection exist at the plant.

Additional _ Technical Specifications will be developed to incorporate the program modifications accomplished since the March 21, 1979 Safety Evalua-tion Report was issued, the opea items listed above when resolved, and minor miscal'eneout changes. With the fuel removed from the reactor during the proposed steam generator repair, and the additional fire protection

measures which will be in effect during that period (NUREG-0756, E 3.23),

there is added assurance that no undue risk to the health and safety of the public will be present during the repair program as the result of fires at the facility.

LLkJl[

-$t ba c Marshall Grotenhuis l

1 and sworn to before me Subscribegdayofp this /9 1981.

Wnh Od/usn Ydtary Psblicg My Commissio6 expires:

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PROFESSf 0NAL QUALf FICATIONS OF MARSHALL GROTENHUIS OPEF.ATING REACTORS BRANCH NO.1 DIVISION OF LICENSING I am a Project Manager in Operating Reactors Branch No.1 of the Division of Licensing, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.

In my present position, I have tF.e responsibility of managing the safety and environmental reviews of actions concerning operating nuclear power plants. This includes the responsibility for planning and coordinating the efforts of other DOR personnel involved in the reviews.

I was born in Oostburg, Wisconsin and attended the Milwaukee State Teachers' College from 1937 to 1941 receiving a Bachelor of Schience degree in Physics, Mathematics and Chemistry.

I attended Marquette University Graduate School from 1945 to 1948 and received a Master of Science degree in Physics and Mathematics.

I attended the Office of Civil Defense Fallou Shielding course at Kansas State University the summer of 1962 and have attended American Management courses in " Management" and " Quality Control."

In the summer of 1971, I attended the Westinghouse School for Environmental Ma na gement.

In 1976 and 1978 I attended NRC courses on PWR and BWR Funda-mentals.

In 1948 and 1949, I was an instructor in Physics at Marquette University.

Ir.1949, I took a position as Associate Physicist at Argonne National

'acoratory'near Chicago, Illinois.

My major responsibility was the calcu-la: ion of radiation distributions for the purpose of designing shields fcr P.e protection of personnel and equipment from reactor rediations. Amon-

tter reactors and projects I had the reponsibility for the shield design of :ne Experimental Soiling Water Reactor and the Experimental Breeder

?. enc or *2.

I also served as group leader for up to six shield engineers it a radiation shield engineering group.

In the twenty-two years at Argonn National Laboratory, I also had major responsibilities in other areas, for example: program plannino for the International Institute for Nuclear Science and Engineering; Manager of the engineering and fabrication of the special nuclear equipment for the laboratory (this included the responsibility for establishing a quality asseance program); responsibility for the planning and management of the reactor experimental. facility which included two training reactors, three subcritical facilities and two neutron generators; and teaching courses in Radiation Shielding to International Institute participants, summer nuclear engineering _ faculty groups and university graduate students.

I am a member of the American Nuclear Society which I have served in many capacities including as a member of the Board of Directors and Chairman of the Sheilding Division, I have been on the Editorial Advisory Board of Nuclear Technology and am an editor and contributing author of the Engineering Co,oendi_um of Radiation Shielding as well as numerous other technical publi-cations.

In May 1971 I accepted a position as Project Analyst in the Division of Radiological and Environmental Protection, U. 5. Atomic Energy Commission.

a member of that Division and its successor the Directorate of Licensing,

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I participated in part or all of the environmental reviews of approximately seventeen nuclear power stations which were under consideration for construc-tion permits or operating licenses.

In December 1975 I transferred to the Division of Operating Reactors in the newly formed fluclear Regulatory Commission.

My new responsibilities included the management of the technical reviews of operating nuclear power pl a nts. This includes reviea's of applications for atendments to operating licenses, in particular amendments to the Technical 5;ecifications which are appendices to the licenses.

I have been the project manager for the Turkey Point Plant since about January 197E.

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION 3 bd "E wAssmcToN c c.20sss 6 s/ :

Sr.,

f Novenher 24, 195" Docket No. 50-250/251 Plant Name: Turkey Point 3 & 4 TO ALL POWER REACTOR LICENSEES WITli PLANTS LICENSED PRIOR TO JANUARY 1,1979 The Comission published on Novemoer 19,1980 (45 FR 76502), a reviset Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire prctection features of nuclear power plants.

The revised Section 50.45 and Ac;endix R will become effective February 17, 1931, which is 90 days after publication.

A copy of the Federal Recister Notice is enciesed (Enclosure 1).

The provisions of Appendix R that are applicable to the fire protection features of your f acility can be divided into two categcries.

The first cate; cry consists cf these provisions cf the Appendix that are recuired te be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific recuirements of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protec:1on of Safe Shutdown Cacability; III-J, Emergency Lighting; and III-0, Oil Collection Systems fer Reactor Coolan Pump.

The fire protection features cf your facility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exem;;ien from the Appendix R repuirements is accroved by the Comission.

You should note the provisions for telling the tire for completing the modificatiens required by these three Sections of Accendix R set forth in Paragraph 50.48(c)(6).

The second category of Appendix R provisions applicable to :ne fire prctecticn f eatures of your f acility consists of requirements concerning the "open" iter:s of previous NRC staff fire protection reviews of your facility. An open item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protec-ion safety evaluation report.

The fire protection features of your facility that are in this category nust satisfy the specific requirements of Appendix R by the dates established by Paragraph 50.48(c), unless an exemp-tich from the Appendix R requirements on those features is approved by the Comi s sion.

, is a summary listing of the ooen items concerning the fire protection features of your facility based on a review of our reccrds.

Also incluoed is our position on the specific requirements that r:ust be satisfied in order to resolve these open items.

If you have any questions or disagree-Tea.:s with this enclosure, please advise us'within 30 days.cf your receipt cf this letter.

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ATTACHMENT B

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February 4, 1981 L-81-27 Office of Nuclear Reactor Regulation Attn: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisennut:

Re: Turkey Point Units 3 & 4 Decket No. 50-250 & 50-251 FIRE PROTECTIO';

TM s letter responds to the oper ' ite s in Er.:losure 2 f j:;r Novemoer 24, 1980 letter.

The attachment addresses Fire Water Suoply (Items 3.1.2 and 3.2.3),

Auxiliary Building Corridor (Item 3.2.4), and Cable Spreadina Room (Item 3.2.5).

We intend to imolement the Fire Brigade Size and Training requirements of Section III, paragraphs H and I of Appendix R to 10 CFR 50 published in the Federal Register en November 19, 1980.

We believe that the provisions of the revised Section 10 CFR 50.48 and new Appendix R are adequately satisfied as described,in the attachment and as such demonstrate that the public health and safety is properly protected.

Very truly yours, l

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Robert E. Uhrig Vice'Presicent s

need Systems & Technology..

REU/JEM/mrs

. Attachments cc. Mr. James-P. O'Reilly, Region I!-

. Harold F..Reis, Esquire I

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