IR 05000348/1996009

Forwards Request for Addl Info Re Kaowool Fire Barriers Installed at Farley Nuclear Plant,Identified in Insp Repts 50-348/96-09 & 50-364/96-09 & Subsequent Insp Repts 50-348/97-12 & 50-364/97-12

ML20198G204
Person / Time
Site:	Farley
Issue date:	12/24/1997
From:	Jacob Zimmerman NRC (Affiliation Not Assigned)
To:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
References
50-348-96-09, 50-348-96-9, 50-348-97-12, 50-364-96-09, 50-364-96-9, 50-364-97-12, NUDOCS 9801120271
Download: ML20198G204 (8)

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December 24, 1997 Mr. D. Vice President - Farley Project Southern Nuclear Operating Company, Inc.

Post _ Office Box 1295 Birmingham, Alabama 35201 1295 SUBJECT: REQUEST FOR ADDITIONAL INFORMATION RELATED TO KAOWOOL FIRE BARRIERS - JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2

Dear Mr. Morey:

During a routine NRC inspection (NRC Inspection Report 50-348, 364/96-09), and a subsequent follow up inspection (NRC Inspection Report 50-348,364/97-12), the NRC identified a number of technicalissues associated with the design, installation, and fire resistive performance of the Kaowool raceway fire barriers installed at the Farley Nuclear Plant. In order

> to evaluate the ability of the Kaowool fire barriers to provide the level of fire resistive protection needed to meet the fire endurance performance objectives of NRC requirements (pre- and post-Appendix R), and the approved fire protection program, the staff requires additional information. Enclosed is the staff's request for additional information conceming the Kaowool fire barriers installed at the Farley Nuclear Plant.

In order to maintain a timely review, it is requested that the information be provided within 30 days of receipt of this letter, if you require any clarification regarding this request, please call me at (301) 415-2426.

Sincerely ORIGINAL SIGNED BY:

Jacob 1. Zimmerman, Project Manager Project Directorate 112 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation ,

Docket Nos. 50-348 and 50-364 Enclosure:- Requesi for Additional information gg g g}g g@pf

.cc w/ encl: See next page Distribution: HBerkow ACRS

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PUBLIC JZimmerman PD ll-2 Rdg. MSalley BBoger OGC *See previous concurrence g To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachmentlenclosure "N" = hgcoyy OFFICE PM:PDll-2* LA:PDil-29 lJ D:PDil-2 ( }b NAME JZIMMERMAN:cn LBERRYJLQ HBERKOWh

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,DATE 12/23/97 Wr /97 /b/S2//97 / /97 DOCUMENT NAME: G:\FARLEY\KAOWOOL\M97701.RAI OFFICIAL RECORD COPY 9001120271 971224 PDR ADOCK 05000348 G PDR ,

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%...../ December 24, 1997 Mr. D. R Morey Vice President - Farley Project Southem Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201 1295 SUBJECT: REQUEST FOR ADDITIONAL INFORMATION RELATED TO KAOWOOL FIRE BARRIERS - JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2

Dear Mr. Morey:

During a routine NRC inspection (NRC Inspection Report 50 348,364/96-09), and a subsequent follow-up inspection (NRC Inspection Report 50 348,364/97-12), the NRC identified a number of technical issues associated with the oesign, installation, and fira resistive performance of the Kaowool raceway fire barriers installed at the Farley Nuclear Plant. In order to evaluate the ability of the Kaowool fire barriers to provide the level of fire resistive protection needed to meet the fire entlurance performance objectives of NRC requirements (pre and post Appendix R), and the approved fire protection program, the staff requires additional information. Enclosed is the staff's request for additional information conceming the Kaowool fire barriers installed at the Farley Nuclear Plant.

In order to maintain a timely review, it is requested that the information be provided within 30 days of receipt of this letter, if you require any clarification regarding this request, please call me at (301) 415-2426.

Sincerely,

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Jacob 1. i merman, Pro et Manager Project Directorate ll-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation l

Docket Nos. 50-348 and 50-364

, Enclosure: Request for AdditionalInformation l-cc w/enci: See next page l

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Joseph M. Farley Nuclear Plant.

cc:

Mr. R. D. Hill, Jr.

General Manager-Southem Nuclear Operating Company Post Omca Box 470 Ashford, Alabama 36312 Mr. Mark Ajiuni, Licensing Manager Southem Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 1295 Mr. M. Stanforo Blanton Balch and Bingham Law Firm

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Post Omco Box 306

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1710 Sixth Avenue North Birmingham, Alabama 35201 Mr. J. D. Woodard Executive Vice President Southem Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 State Health Officer Alabama Department of Public Health 4M Monroe Street Montgomery, Alabama 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, Alabama 36302 Regional Administrator, Region ll U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Resident inspector

. U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319

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REQUEST FOR ADDITIONAL INFORMATION KAOWOOL RACEWAY FIRE BARRIER PERFORMANCE JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 1.0 BACKGROUND During a routine NRC inspection (NRC Inspection Report 50-348,364/96-09), and a subsequent follow-up inspection (NRC Inspection Report 50-348,364/9712), the NRC identified a number of technical issues associated with the design, installation, and fire resistive performance of Knowool raceway fire barriers installed at the Farley Nuclear Plant (FNP).

2.0 LICENSING BASJS On April 13,1979, the NRC issued the FNP Fire Protection Safety Evaluation Report (SER).

- This SER documented the results of the staffs evaluation of the Alcbama Power Company's (APC's, the licensee's) FNP Fire Protection Program Reevaluation Report (dated September 15,1977), and its Amendments 1-4 (dated February 23,1978; July 14,1978; October 27,1978; and January 3,1979, respectively), in 6.d4 SER, the NRC approved APC's commitments to provide (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated barriers for one train of Component Cooling Water (CCW) cables in the CCW Pump Area for each unit; (2) 30-minute fire rated barriers on the control and power cables to the CCW pumps and on other essential cables; and (3) either a double-thick barrier consisting of two layers of 30-minule-rated enclosure around one train, or a half hour barrier around both trains for the cables located in Fire Areas 1,4,5,6,9,13,20,21, 34,41,42,51. and 72. This is in accordance with Section 4.3.5.1 of the FNP Fire Protection Reevaluation Report.

2.1 REQUEST FOR ADDITIONAL INFORMATION Please provide the following information:

2,1.1 For each fire area, provide a list of the electrical raceways protected by a fire barrier and describe the safety related and safe shutdown functions being protected.

2.1.2 For each fire arsa, identify the type of raceway (e.g.,18-inch wide aluminum ladder back cable tray), the fire barrier material used (e.g.,1 inch of Kaowool) and provide the design details (e.g., typical design and installation drawing details), and installation instructions that were in use at the time of the August 21,1980, NRC site visit.

Enclosure

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2-2.1.3 For each raceway fire barrier, provide the fire test reports, data,' and _ engineering _

evaluations that support the fire resistive rating of the fire barrier used to meet the fire protection technical requirements as documented in the April 13,1979, SER.'

3.0 TECHNICAL BASIS FOR APPENDIX R EXEMPTIONS By letters dated March 13 and May 31,1985, FNP requested exemotions to Appendix R, Section Ill.G. The licensee based its exemption requests on the Appendix R imorpretations made in Generic Letter (GL) 83-33 *NRC Positions on Certain Requirements of Appendix R to 10 CFR Part 50," October 19,1983, and Information Notice (lN) 84-09 " Lessons Leamed from NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR Part 50, Appendix R),"

February 13,1984. The NRC-approved exemptions, are based, in part, on the assumption that i

' the Knowool raceway fire barriers were accepted by the NRC and installed prior to the issuance  ;

of Appendix R.

3.1 REQUEST FOR ADDITIONAL INFORMATION

- In support of certain exemptions, the I;censee committed to install additional 1-hour rated fire barriers. Since these were new installations and were not previously approved, their design should have considered the fire barrier performance guidance identified in IN 84-09 and later in GL 86-10 ' implementation of Fire Protection Requirements," April 24,1986: In order to e evaluate the fire resistive performance of the fire barriers installed in support of the March 13 and May 31,1985, exemption requests, provide the following additional information:

3.1.1 Identify the new raceway fire barriers (i.e., installed after the effective date of Appendix R)

. and their fire resistive rating. In addition, for each of these fire barriers, identify the fire area / room where they are located, the raceway / cable tray they are protecting , and the safe shutdown or safety-related function that is being protected.

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3.1.2 For these raceway fire barriers, pmvide the design details (e.g., typical design and installation drawing details) and intJllation instructions that were developed and used to install the barriers.

3.1.3 For each fire barrier, provide the fire test reports, data, and engineering evaluations that support the fire resistive rating of the fire barriers.

3.1.4 For exemption requests 1-22,1-26, and 2-4, the licensee stated that some of the pre-existing raceway fire barrier installations were adequate based on the fact that their fire resistive rating exceeded the potential fire severity in the fire area. For these cases, provide the analysis that supports the conclusion that the protected cables would be free

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4.0 FIRE ENDURANCE TESTING

In IN 93-40,' Fire Endurance Test Results for Thermal Ceramics FP-60 Fire Barrier Material," i

= May 26,1993, the 6taff identified problems with the fire endurance performance of the Thermal. j Ceramics rackasy fire barrier system (using two FiroMaster FP-60,1-inch thick, ceramic fiber )

= blankets) installed on a 36-inch wide cable tray,: At approximately 20 minutes into the test the 1

tray developed an opening' at a butt joint which resulted in a 3-1/2-inch opening at the end of -

- the test (60 minutes). The temperature as measured on cables inside the barrier system ranged from 400 - 500 'F at the end of the test. Hosc stream tests were not performed. ,

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in IN 9341 *One Hour Fire Endurance Test Results for Thermal Ceramics Knowool 3M Company FS-195 and 3M Company Interam E-50 Fire Banier Systems,' May 28,1993, the staff also identified conditions related to the thermal performance of the Kaowool fire barrier i system when tested in a small scale fumace. The temperature as measured on the nonfire or t unexposed side of the fire barrier material on the cables reached a maximum temperature of l 800 'F at 60 minutes. (Note: Thia test attempted to follow the ASTM E-119 standard time l temperature test fire exposure but failed to do so.) The test results in IN 93-41 are further l aiscussed in the Underwriters Laboratories, Inc. (UL), report dated September 6,1978, and are I related to the cable tray fire test; Test No. 3. UL did not perform the test, classify the fire barner 1

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product, issue a listing, or claim that this test would predict full-scale fire test performance.  !

Based on a letter dateel October 1,1993, from J. E. Love, Project Enge . Bechtel, to l

. D. N. Morey, Vice President, Southem. Nuclear Operating Company, it appears that the fire l resistive rating / qualification of the Kaowool barriers installed at FNP between 1979 and 1980 l

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L are based on the Kaowool receway and cable tray fire barrier system designs documented in

. Babcock and Wilcox fire test report entitled " Tests For Fire Protection for Complete Engulfinent ,

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. . of Cable Trays and Conduits Containing grouped Electrical Conductors," dated October 24,

. 1978.' The fire barrier design tested in Test No. 3 had a cable fill of 35% and it allowed cable  ;

Jacket temperatures to reach 200 - 800 'F at 60 minutes. This cable tray fire barrier system used a tight butt joint design and appeared to perform better than the design that used an  ;

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attemative butt joint design. No hcse stream test was performed.  ;

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The NRC, in Inspection Report 50-348, 364/97-12, identified that certain FNP electrical raceway or cable tray fire barrier systems do not extend through the fire barrier wall penetration, which is not representative of the tested configuration. The FNP Knowool fire barriers typically butt up -

against a fire rated wall, floor, ceiling, or silicone penetration ' seal and are bonded to,its mating surface (e.g., wall face) with a flame-mastic type coating. The staff is concemed that this fire barrier interface may not be capable of maintaining the continuity of the fire barrier, and thus prevent it from performing its intended fire resistive function.

. __ i The Underwriters Laboratories, Inc. (UL), Report dated September 6,1978, entitled " Cable

~ Raceway Protection Systems Fire Test investigation," documents the independent observations

- made by UL during the Babcock and Wilcox Knowool fire barrier test, which were documented

. : in its report dated October 24,1978.

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, 4.1 REQUEST FOR ADDITIONAL INFORMATION l l 4.1.1 Describe the butt joint design used at FNP and discust how it meets or exceeds the design attributes used by the Babcock and Wilcox 1978 test configuration. State whether or not an analysis was performed, which evaluated the butt joint design deficiency noted ,

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IN 93-40 and its potential applicability to the designs used at FNP. Provide the analysis.

4.1.2 Discuss the design / installation attributes of the FNP Knowool fire barriers as campered to !

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those tested and for osch of the critical attributes (e.g., raceway siz6, raceway

orientation, air drops, cable fill, cable size, cable type, joint and seem design, fastener /

band spacing) and summarize how deviations between the tested and installed attributes .

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effect the fire resistive charactristics of the installed fire barriers. Provide any additional - l

, informaticn which demonstrates that the installed Knowool fire barriers meet NRC  !

i requirements and licensing commitments.

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1 4.1.3 The 1978 &abcock and Wilcox tests (4 inch diameter conduit and 18-inch wide cable tray) evaluated limited receway configurations, in addition, the raceway fire barrier I system test specimens extended through the fumaos well and terminated outside ;,w test "

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fire's zone of influence. Sechtel, in its letter dated Octcber 1,1993, indicated that the L 1978 Babcock and Wilcox test results provided sufficient test data to justify scooptance i of nontested configurations. Provide the engineering analysis which supports the ,

4 conclusions made that the 1978 tests bound the actual installations. Specifically,  ;

address the Knowool fire barrier interface with other fire barriers (e.g., fire walls). -

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4.1.4 For the FNP Knowool fire barriers installed after the effective date of Appendix R, provide the cable functionality analysis and subsequent testing which demonstrates that the protected post fire safe shutdown cables are capable of performing their intended  ;

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functions during and after a postulated fire (Refer to GL 86-10 Interpretation 3, * Fire

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Damage"), j c l 4.1.5 Provide the tests / analysis that technically assesses the required protection to raceway ;

supports and the required protection of intervening items into the Knowool fire barrier system. l f

5.0 GENERIC LETTER 92-08 ,

On Dooember 17,1992, the staff issued Generic Letter (GL) 92-08, "Thermo-Lag 3301 Fire [

Barriers," to all holders of operating licenses for nuclear power plants. GL 92-08 addressed

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fire endurance and ampacity dorating issues associated with Thermo Lag 330-1 fire barrier i materials. GL 92-08, did not request specific action for other barrier materials. However, as documented in GL 92-08, the staff expected the licensees with fire barriers constructed from i other materials to review ' . 92 08 and determine if the technicalissues applied to those other barrier materials used at their facilities and to consider actions, as appropriate, to avoid similar :

problems. ,

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5.1 REQUEST FOR ADDITIONAL INFORMATION 5.1.1 GL 92-08 identified three principal areas of concem: fire endurance capability; ampacity dorating of cables enclosed in fire barriers; and the evaluation and application of the resulte of tests conducted to determine the fire endurance ratings and the ampacity dercting factors. State whether or not an evaluation was performed to assess the Knowool fire barrier design, fire endurance performance, nr.d ampacity dorating against the insights and concems documented in GL 92-08, if an evaluation was performed, provide the results and discuss the subsequent actions taken to assess and correct any technical issues associated with the installed Knowool fire barriers.

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