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| number = ML110340027 | | number = ML110340027 | ||
| issue date = 02/02/2011 | | issue date = 02/02/2011 | ||
| title = | | title = EPU Fire Protection (Afpb) Request for Addition Information (Round 1) | ||
| author name = Paige J | | author name = Paige J | ||
| author affiliation = NRC/NRR/DORL/LPLII-2 | | author affiliation = NRC/NRR/DORL/LPLII-2 | ||
| addressee name = Abbatiello T | | addressee name = Abbatiello T | ||
| Line 15: | Line 15: | ||
=Text= | =Text= | ||
{{#Wiki_filter:From: Paige, Jason Sent: Wednesday, February 02, 2011 3:53 PM To: Abbatiello, Tom Cc: Abbott, Liz; Tiemann, Philip; Tomonto, Bob | {{#Wiki_filter:From: | ||
Paige, Jason Sent: | |||
Wednesday, February 02, 2011 3:53 PM To: | |||
Abbatiello, Tom Cc: | |||
Abbott, Liz; Tiemann, Philip; Tomonto, Bob | |||
==Subject:== | ==Subject:== | ||
Turkey Point EPU - Fire Protection (AFPB) Request for Additional Information - Round 1 Tom, | Turkey Point EPU - Fire Protection (AFPB) Request for Additional Information | ||
- Round 1 | |||
: Tom, Below are requests for additional information (RAIs) regarding the Turkey Point Extended Power Uprate license amendment request. On February 2, 2011, the Nuclear Regulatory Commission staff and Florida Power & Light Company discussed draft RAIs to gain a common understanding of the questions. During the call, it was concluded that there was a common understanding of all of the questions and no revisions were needed. The below RAIs reflect the questions discussed and agreed upon during the February 2, 2011, call. FPL agreed upon providing its responses within 30 days of the date of this email. If you have any questions, feel free to contact me. | |||
AFPB-1.1 Attachment 1 to Matrix 5 (Supplemental Fire Protection Review Criteria, Plant Systems), of Nuclear Reactor Regulation (NRR) RS-001, Revision 0, Review Standard for Extended Power Uprates (EPU), states that power uprates typically result in increases in decay heat generation following plant trips. These increases in decay heat usually do not affect the elements of a fire protection program related to (1) administrative controls, (2) fire suppression and detection systems, (3) fire barriers, (4) fire protection responsibilities of plant personnel, and (5) procedures and resources necessary for the repair of systems required to achieve and maintain cold shutdown. In addition, an increase in decay heat will usually not result in an increase in the potential for a radiological release resulting from a fire. However, the licensees, LAR should confirm that these elements are not impacted by the extended power uprate. | |||
The staff notes that license amendment request (LAR), Attachment 4, to L-2010-113, Licensing Report, Section 2.5.1.4.2.3, on page 2.5.1.4-3, specifically addresses only items (1) through (4) above. The staff requests that the licensee provide statements to address item (5). | |||
AFPB-1.2 LAR, Attachment 4, to L-2010-113, Section 2.5.1.4.2.3.1, on page 2.5.1.4-4, states that, The impact of plant modifications being implemented in support of EPU on Fire Protection Program will be addressed in accordance with the Plant Change/Modification process It is unclear to the NRC staff whether there are fire protection program plant modifications planned (e.g., adding new cable trays, or re-routing of existing cables, or increases in combustible loading affecting fire barrier ratings, or changes to administrative controls) at EPU conditions. Clarify whether this request involves plant modifications, or changes to the fire protection program, including any proposed modifications to implement transition to Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). If any, the staff requests the licensee to identify proposed modifications and discuss the impact of these | |||
modifications on the plants compliance with the fire protection program licensing basis, 10 CFR50.48, or applicable portions of 10 CFR 50, Appendix R. | |||
AFPB-1.3 The NRC staff notes that Attachment 4 to L-2010-113, Section 2.5.1.4.2.3.2, on page 2.5.1.4-8, Time Critical Manual Action Evaluation, identifies some additional Fire Zones 84 and 106 requiring operator manual actions as a result of EPU. | |||
AFPB-1.3 | |||
Section III.G.3 of Appendix R addresses alternative or dedicated shutdown capability independent of the fire area of origin and establishes a series of requirements to achieve and maintain safe shutdown capability. The NRC staff requests the licensee to confirm the compliance strategy for Fire Zones 84 and 106 is Appendix R, Section III.G.3. | Section III.G.3 of Appendix R addresses alternative or dedicated shutdown capability independent of the fire area of origin and establishes a series of requirements to achieve and maintain safe shutdown capability. The NRC staff requests the licensee to confirm the compliance strategy for Fire Zones 84 and 106 is Appendix R, Section III.G.3. | ||
AFPB-1.4 | AFPB-1.4 The NRC staff notes that Attachment 4 to L-2010-113, Section 2.5.1.4.2.3.2, on page 2.5.1.4-9, Time Critical Manual Action Evaluation, states that Prior to EPU, the PORV is required to be closed before leaving the Control Room and are verified closed from the Alternate Shutdown panel (ASP) within 15 minutes. | ||
Opening of these PORV breakers will be additional actions added to an already assigned position and are to be completed within 5 minutes at the local DC panel | Opening of these PORV breakers will be additional actions added to an already assigned position and are to be completed within 5 minutes at the local DC panel The NRC staff requests the licensee to discuss why opening of PORV breakers, which will be additional actions added to an already assigned staff position requiring completion within 5 minutes at the local DC panel, should be considered acceptable. | ||
AFPB-1.5 | AFPB-1.5 Some plants credit aspects of their fire protection system for other than fire protection activities, e.g., utilizing the fire water pumps and water supply as backup cooling or inventory for non-primary reactor systems. If Turkey Point Units 3 and 4, credits its fire protection system in this way, the LAR should identify the specific situations and discuss to what extent, if any, the extended power and measurement uncertainty recapture uprates affect these non-fire-protection aspects of the plant fire protection system. If Turkey Point Units 3 and 4 does not take such credit, the NRC staff requests that the licensee verify this as well. | ||
In your response discuss how any non-fire suppression use of fire protection water will impact the need to meet the fire protection system design demands. | In your response discuss how any non-fire suppression use of fire protection water will impact the need to meet the fire protection system design demands. | ||
Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888}} | Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888}} | ||
Latest revision as of 00:12, 14 January 2025
| ML110340027 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/02/2011 |
| From: | Jason Paige Plant Licensing Branch II |
| To: | Abbatiello T Florida Power & Light Co |
| Paige, Jason C, NRR/DORL,301-415-5888 | |
| References | |
| Download: ML110340027 (2) | |
Text
From:
Paige, Jason Sent:
Wednesday, February 02, 2011 3:53 PM To:
Abbatiello, Tom Cc:
Abbott, Liz; Tiemann, Philip; Tomonto, Bob
Subject:
Turkey Point EPU - Fire Protection (AFPB) Request for Additional Information
- Round 1
- Tom, Below are requests for additional information (RAIs) regarding the Turkey Point Extended Power Uprate license amendment request. On February 2, 2011, the Nuclear Regulatory Commission staff and Florida Power & Light Company discussed draft RAIs to gain a common understanding of the questions. During the call, it was concluded that there was a common understanding of all of the questions and no revisions were needed. The below RAIs reflect the questions discussed and agreed upon during the February 2, 2011, call. FPL agreed upon providing its responses within 30 days of the date of this email. If you have any questions, feel free to contact me.
AFPB-1.1 Attachment 1 to Matrix 5 (Supplemental Fire Protection Review Criteria, Plant Systems), of Nuclear Reactor Regulation (NRR) RS-001, Revision 0, Review Standard for Extended Power Uprates (EPU), states that power uprates typically result in increases in decay heat generation following plant trips. These increases in decay heat usually do not affect the elements of a fire protection program related to (1) administrative controls, (2) fire suppression and detection systems, (3) fire barriers, (4) fire protection responsibilities of plant personnel, and (5) procedures and resources necessary for the repair of systems required to achieve and maintain cold shutdown. In addition, an increase in decay heat will usually not result in an increase in the potential for a radiological release resulting from a fire. However, the licensees, LAR should confirm that these elements are not impacted by the extended power uprate.
The staff notes that license amendment request (LAR), Attachment 4, to L-2010-113, Licensing Report, Section 2.5.1.4.2.3, on page 2.5.1.4-3, specifically addresses only items (1) through (4) above. The staff requests that the licensee provide statements to address item (5).
AFPB-1.2 LAR, Attachment 4, to L-2010-113, Section 2.5.1.4.2.3.1, on page 2.5.1.4-4, states that, The impact of plant modifications being implemented in support of EPU on Fire Protection Program will be addressed in accordance with the Plant Change/Modification process It is unclear to the NRC staff whether there are fire protection program plant modifications planned (e.g., adding new cable trays, or re-routing of existing cables, or increases in combustible loading affecting fire barrier ratings, or changes to administrative controls) at EPU conditions. Clarify whether this request involves plant modifications, or changes to the fire protection program, including any proposed modifications to implement transition to Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). If any, the staff requests the licensee to identify proposed modifications and discuss the impact of these
modifications on the plants compliance with the fire protection program licensing basis, 10 CFR50.48, or applicable portions of 10 CFR 50, Appendix R.
AFPB-1.3 The NRC staff notes that Attachment 4 to L-2010-113, Section 2.5.1.4.2.3.2, on page 2.5.1.4-8, Time Critical Manual Action Evaluation, identifies some additional Fire Zones 84 and 106 requiring operator manual actions as a result of EPU.
Section III.G.3 of Appendix R addresses alternative or dedicated shutdown capability independent of the fire area of origin and establishes a series of requirements to achieve and maintain safe shutdown capability. The NRC staff requests the licensee to confirm the compliance strategy for Fire Zones 84 and 106 is Appendix R,Section III.G.3.
AFPB-1.4 The NRC staff notes that Attachment 4 to L-2010-113, Section 2.5.1.4.2.3.2, on page 2.5.1.4-9, Time Critical Manual Action Evaluation, states that Prior to EPU, the PORV is required to be closed before leaving the Control Room and are verified closed from the Alternate Shutdown panel (ASP) within 15 minutes.
Opening of these PORV breakers will be additional actions added to an already assigned position and are to be completed within 5 minutes at the local DC panel The NRC staff requests the licensee to discuss why opening of PORV breakers, which will be additional actions added to an already assigned staff position requiring completion within 5 minutes at the local DC panel, should be considered acceptable.
AFPB-1.5 Some plants credit aspects of their fire protection system for other than fire protection activities, e.g., utilizing the fire water pumps and water supply as backup cooling or inventory for non-primary reactor systems. If Turkey Point Units 3 and 4, credits its fire protection system in this way, the LAR should identify the specific situations and discuss to what extent, if any, the extended power and measurement uncertainty recapture uprates affect these non-fire-protection aspects of the plant fire protection system. If Turkey Point Units 3 and 4 does not take such credit, the NRC staff requests that the licensee verify this as well.
In your response discuss how any non-fire suppression use of fire protection water will impact the need to meet the fire protection system design demands.
Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888