CPSES-200601043, 60-Day Response to NRC Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
| ML061660092 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/08/2006 |
| From: | Madden F TXU Generation Co, LP, TXU Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| +kBR1SISP20060621, CPSES-200601043, GL-06-003, TXX-06091 | |
| Download: ML061660092 (4) | |
Text
- TXU *" Power
- XU Power Mike Blevins Comanche Peak Steam Senior Vice President &
Bectric Station Chief Nuclear Officer P. 0. Box 1002 (EO1)
Glen Rose, IX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevins@txu.com CPSES-200601043 Log # TXX-06091 June 8, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 60-DAY RESPONSE TO NRC GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" REF: NRC Generic Letter (GL) 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006.
Gentlemen:
NRC Generic Letter (GL) 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006, was issued to request information from licensees regarding Hemyc and MT fire barriers, or other fire barriers using the materials and configurations described in the generic letter.
GL 2006-03 requested that all addressees provide a response that contains the following information:
- 1. JVithin 60 days of the date of this GL, provide thefollowing:
- a. A statement on whether Hemvc or MTfire barriermaterialis used at their NPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensingbasis, including whether Henmyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).:
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- South Texas Project
- Wolf Creek
TXX-06091 Page 2 of 4
- b. A descriptionof the controls that were used to ensure that otherfire barriertypes relied on for separationof redundant trains located in a singlefire area are capable ofproviding the necessaly level of protection.Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.
- 2. Within 60 days of the date of this GL, for those addressees that have installed Ilemye or MTfire barriermaterials,discuss thefollowing in detail:
- a. The extent of the installation (e.g., linearfeet of wrap, areas installed, systems protected),
- b. Whether the Hemyc and/orMT installed in their plants is conforming with their licensing basis in light of recentfindings, and if these recent findings do not apply, why not, C. The compensatory measures that have been implemented to provide protection and maintain the safe shutdown finction of affected areas of the plant in light of the recentfindings associatedwith Ilemye and MT installations,including evahlations to support the addressees' conchlsions, and
- d. A description of and implementation schedulesfor, corrective actions, including a descriptionof any licensing actions or exemption requests needed to support changes to the plant licensing basis.
- 3. No later than December 1, 2007, addressees that identified in L.a. Hemvc and/orMT configurationsare requested to provide a description ofactions taken to resolve the nonconformingconditions describedin 2.d.
Response to Ia:
CPSES uses Hemyc in limited circumstances as a radiant energy shield (RES). It is relied upon for separation and safe shutdown purposes in accordance with the CPSES licensing basis. CPSES does not use Hemyc or MT fire barrier materials as a one or three hour fire barrier for separation of redundant post fire safe shutdown circuits.
The Hemyc wrap is used in the containment building as a RES.
Response to Ib:
CPSES utilizes Thennolag as raceway fire barrier protection for redundant trains located in the same fire area to satisfy 10 CFR 50, Appendix R, III.G requirements.
Installation and inspection procedures verified that the barrier products were installed in a manner consistent with the testing and analyses to ensure test configurations and
TXX-06091 Page 3 of 4 criteria would be bounding to the installed configurations. Deviations from the tested configurations were evaluated in accordance with Generic Letter 86-10, Supplement 1, providing reasonable assurance that the installed fire barrier systems would provide the necessary level of protection. Fire tests were performed for electrical raceway fire barrier configurations which could not be bounded by the Generic Letter 86-10, Supplement 1 evaluations. CPSES inspects fire rated enclosures every 18 months to ensure ongoing integrity.
Test reports, previous correspondence, and additional information are available on site.
Response to 2a:
Hemyc is installed at CPSES in Unit I and 2 Containment Buildings as a RES. RES is a shield designed to provide protection for redundant essential raceways or fire safe shutdown equipment against the radiant energy from an exposure to fire. RES is provided in containment where redundant sets of fire safe shutdown equipment and components are separated by less than 20 feet horizontally with negligible intervening combustibles. Approximately 800 linear feet of RES is installed in Unit 1 Containment and approximately 800 linear feet of RES is installed in Unit 2 Containment. The actual linear footage of RES will be verified during the upcoming refueling outages for Unit I and Unit 2.
The systems protected by RES include the Reactor Coolant System, the Chemical and Volume Control System, the Residual Heat Removal System, and the Process Monitoring System. The actual Fire Safe Shutdown Equipment List is contained in Section III of the CPSES Fire Protection Report.
Response to 2b:
Hemyc is only used as RES in accordance with the licensing basis and not as a one-hour rated fire barrier material. The recent findings on Hemyc fire barrier material were from NRC testing which was performed to different requirements than when CPSES tested the RES configurations of Hemyc in the 1980s. Therefore, CPSES will evaluate the NRC test results and testing configurations for applicability to our existing design of Hemyc RES. This evaluation will be performed by December 1, 2006.
Response to 2c, 2d and 3:
Request for information 2c, 2d and 3 are not currently applicable to CPSES. If, as a result of the evaluation discussed above, CPSES determines that the installed Hemyc RES is nonconforming, CPSES will take compensatory action and corrective action as appropriate, and will inform the NRC of those actions.
TXX-06091 Page 4 of 4 This communication contains three new licensing basis commitments regarding CPSES Units I and 2.
Number Description of Commitment 27405 The actual linear footage of the RES in Units I and 2 Containment will be verified during the upcoming refueling outages for each unit.
27406 CPSES will evaluate the NRC test results and testing configurations for applicability to our existing design of Hemyc RES by 12/01/06.
27407 If, as a result of the evaluation discussed above, CPSES determines that the installed Hemyc RES is nonconforming, CPSES will take compensatory action and corrective action as appropriate, and will inform the NRC of those actions.
Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725.
I state under penalty of perjury that the foregoing is true and correct.
Executed on the 8 th of June, 2006.
Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner Mike Blevins By:
4Fred W. Madden Director, Regulatory Affairs jch c - B. S. Mallett, Region IV M. C. Thadani, NRR Resident Inspectors, CPSES