Information Notice 1995-27, NRC Review of Nuclear Energy Institute, Thermo-Lag 330-1 Combustibility Evaluation Methodology Plant Screening Guide.
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UNITED STATES L
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C.--- 20555-0001- May 31, 199S
NRC INFORMATION NOTICE 95-27: NRC REVIEW OF NUCLEAR ENERGY INSTITUTE,
OTHERMO-LAG 330-1 COMBUSTIBILITY
EVALUATION
METHODOLOGY
PLANT
SCREENING GUIDE*
Addresse
All holders of operating licenses or construction permits for nuclear power
plants.
Pur~ose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice to inform addressees of the results of NRC staff review of the Nuclear
Energy Institute (NEI) gThermo-Lag 330-1 Combustibility Evaluation Methodology
Plant Screening Guide." It is expected that recipients will review the
information for applicability to their facilities and consider actions as
appropriate. However, suggestions contained in this information notice are
not NRC requirements; therefore, no specific action or written response is
required.
Background
On December 15, 1992, NRC issued IN 92-82, Results of Thermo-Lag 330-1 Combustibility Testing.' On the basis of its review of Thermo-Lag
combustibility tests conducted by the National Institute of Standards and
Technology (NIST), the NRC staff concluded that Thermo-Lag 330-1 is a
combustible material. NRC fire protection requirements (Section III.G,
Appendix R to 10 CFR 50) preclude the use of combustible materials to
(1) enclose other combustibles, such as cables, between redundant safe
shutdown trains to eliminate the combustibles as a fire hazard or (2) provide
radiant energy heat shield protection for shutdown components inside
containments. These types of applications are the principal NRC staff concerns
with respect to the combustibility of Thermo-Lag 330-1.
Discussion
On October 12, 1993, the Nuclear Management and Resources Council (NUMARC),
now NEI, submitted for information to the NRC its *Thermo-Lag 330-1 Combustibility Evaluation Methodology Plant Screening Guiden (Accession No.
9310210224). In that report, NEI stated that Thermo-Lag 330-1 may not
necessarily be considered a combustible material from a generic standpoint and
recommended a performance-based approach, using fire modeling techniques, to
evaluate the combustibility hazards presented by Thermo-Lag 330-1 installations. DV i4/r4 . - 027- so653 /
9505240424j % 5 /
'XI
- ?">> K> IN 95-27 May 31, 1995 The NRC staff, with technical assistance from NIST, reviewed the Thermo-Lag
combustibility evaluation methodology prepared by NEI. The results of the
staff review, which was based on existing NRC requirements and guidance, are
detailed in the attached letter of March 13, 1995, to NEI (Accession No.
9503200111). In summary, the staff informed NEI that it will not accept the
use of the NEI methodology to justify the use of Thermo-Lag materials, or
other materials such as fire retardant plywood or cable jackets, as
noncombustible where noncombustible materials are specified by NRC fire
protection requirements. Alternatives to the NEI guide are discussed in the
March 13, 1995, letter. The Commission approved the letter to NEI in a staff
requirements memorandum of March 8, 1995 (Accession No. 9505090025).
Related Generic Communications
- Generic Letter (GL) 83-33, RNRC Positions on Certain Requirements of
Appendix R,. October 19, 1983.
- GL 86-10, 'Implementation of Fire Protection Requirements,'
April 24, 1986.
- GL 86-10, Supplement 1, wFire Endurance Test Acceptance Criteria for
Fire Barriers Systems Used to Separate Redundant Safe Shutdown
Trains Within the Same Fire Area,' March 25, 1994.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
K. Grimes, rector
4ran
Division of Project Support
Office of Nuclear Reactor Regulation
Technical contact: Pat Madden, NRR
(301) 415-2854 Attachments:
1. Letter of March 13, 1995, from C. McCracken, NRC,
to A. Marion, NEI, and its enclosures
2. List of Recently Issued NRC Information Notices
K UNITED STATES K> ATTACHMENT 1 C >.js am NUCLEAR REGULATORY COMMISSION IN 5-27 WASHINGTON. D.C. 2G&5S4 My 1, 199
- March 13, 1995 Mr. Alex Marion, Manager
Technical Division
Nuclear Energy Institute
1776 "IN Street, N.W., Suite 300
Washington, DC 20006-3706 SUBJECT: THERMO-LAG 330-1 COMBUSTIBILITY EVALUATION
METHODOLOGY
PLANT
SCREENING GUIDE
Dear Mr. Marion:
The Nuclear Regulatory Commission (NRC) staff has reviewed the "Thermo-Lag
330-1 Combustibility Evaluation Methodology Plant Screening Guide" that the -
Nuclear Oanagement Resources Council, now the Nuclear Energy InstitUce (NEI),
submitted to the NRC by letter dated October 12, 1993. The NEI guide provides
a perrormance-based approach, using fire modeling techniques, for evaluating
the combustibility hazards presented by Thermo-Lag 330-1 installations.
In a Staff Requirements Memorandum (SRM) of June 27, 1994, "Options for
Resolving the Thermo-Lag Fire Barrier Issue," the Commission approved the NRC
staff recommendation to return plants to compliance with existing NRC
requirements and explained its position with respect to the use of
performance-based approaches tc resolve Thermo-Lag issues (see enclosed SRM).
The staff found that the NEI guide contains bases (interpretations) regarding
material combustibility and the use of combustible materials in nuclear power
plants that are not consistent with established staff positions. The NRC
staff responses to the NEI bases are provided in Enclosure 2.
On the basis of its combustibility tests and review, the staff concluded that
Thermo-Lag 330-1 fire barrier material has combustible characteristics similar
to those of other nuclear power plant combustible materials, such as
fire-retardant plywood and cable jackets. The staff also concluded that the
NEI method does not provide a level of fire safety equivalent to that
specified by existing NRC fire protection regulations and guidelines.
Therefore, the staff will not accept the use of the NEI guide to justify the
use of Thermo-Lag materials where noncombustible materials are specified by
NRC fire protection requirements or to assess the combustibility hazards
presented by Thermo-Lag materials.
As an alternative to the NEI guide, the staff recommends that licensees
reevaluate their use of Thermo-Lag as radiant energy heat shields inside the
containment or as an enclosure to create a 20-foot combustible-free zone
between redundant trains and seek other solutions. Examples of possible
solutions include the following: (1) reanalyze post-fire safe shutdown
circuits inside containment and their separation to determine if the
- K>
A. Marion -2- Thermo-Lag radiant energy shields are needed, (2) replace Thermo-Lag barriers
installed inside the containment with noncombustible barrier materials,
(3) replace Thermo-Lag barriers used to :reate combustible-free zones with
noncombustible barrier materials, (4) reroute cables or relocate other
protected components, or (5) request plant-specific exemptions where
technically Justified. For other Thermo-Lag applications, licensees, if they
have not already done so, should address the presence of the combustible
rhermo-Lag materials in the fire hazards analyses in accordance with existing
NRC fire protection guidance.
The NRC staff will Inform the licensees of the results of its review of the
NEI methodology. If you have any questions, please contact Mr. Steven West at
301-415-1220.
Sincerely, Conrad E. McCracken, Chief
Plant Systems Branch
Division of Systems Safety and Analysis
Office of Nuclear Reactor Regulation
Enclosures: As stated
-1 i Z
I j
UNITED STATES "2 NUCLEAR REGULATORY COMMISSION
WASHINGTON. D.C. 2555 June 27, 1994 OFFICE OF THE
SECRETARY
MEMORANDUM TO: James M. Taylor
Execut" vDire tor for Operations
FROM: John . 4!yi g Secretary
Sy¶
SUBJECTt SECY- -127 - OPTIONS FOR RESOLVING THE
THERMO-LAG FIRE BARRIER ISSUES
The Commission (with all Commissioners agreeing) has approved the
continued use of Option 1, which requires compliance with
existing NRC requirements and permits plant-specific exemptions
where justified. The Commission does not intend to limit the
staff's consideration of requests for exemptions currently
permitted by regulations.
The Commission (with the Chairman and Commissioners Remick and de
Planque agreeing) requests that the staff, in consultation with
industry, consider possible new exemptions to Appendix R based on
state-of-the-art fire protection methodology and technology and
proceed to evaluate the feasibility of developing new guidance
for rating fire barriers on the basis of representative plant
fire hazards as described in Option 2. The responsibility for
developing the technical basis for any new exemptions should rest
with the licensees.
Commissioner Rogers disapproved proceeding with Option 2. In
particular, he felt the staff should not proceed with the
development of a Regulatory Guide in support of this option.
However, he did not object to the staff's initiating a research
project to investigate the feasibility of either developing
standard fire curves or using realistic fire loads. This
information would be applicable to a performance-based approach
to a fire protection rule.
The Chairman and Commissioner Rogers approved the staff
recommendation not to proceed with the development of a
performance-based approach to resolve the Thermo-Lag issue as
SECY NOTE: SECY-94-127 WAS RELEASED TO THE PUBLIC ON MAY 20,
1994. THIS SRM AND THE VOTE SHEETS OF ALL
COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 10
WORKING DAYS FROM THE DATE OF THIS SRM.
Enclosure 1
-2- described in Option 3. They believe that the performance based
approach should be applied to support development of the fire
protection rule. Commissioner Remick and Commissioner de Planque
had no objection to pursuing Option 3 if the responsibility and
initiative came from industry.
The Commission (with all Commissioners agreeing) has approved the
staff recommendation to proceed as planned with the development
of a performance-based fire protection rule. This should be
pursued by the staff as part of its continuing program for
regulatory improvement and/or once a request for rulemaking is
received. The Commission felt that the new rule should not be
considered a means to resolve the Thermo-Lag issues.
cc: The Chairman
Commissioner Rogers
Commissioner Remick
Commissioner de Planque
Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
4.- k
Response by the Office of Nuclear Reactor Regulation
plant Systems Branch
To Nuclear Energy Institute Interpretations
of Material Combustibility
Section 3.2, "Licensing Bases,' of the "Thermo-Lag 330-1 Combustibility
Evaluation Methodology Plant Screening Guide" that Nuclear Energy Institute
(NEI) submitted to the NRC by letter dated October 12, 1993, provides NEI's
bases for assessing material combustibility. The following are the NRC staff
responses to the NEI bases.
1.0 Appendix R
1.1 NEI Basis
Appendix R does not provide a definition for combustibility. In [Information
Notice] 92-82, the NRC uses ASTM E136 as a test of combustibility but there is
no regulatory basis for the use of this standard's criteria.
1.2 NRC Response
Appendix R does not address all aspects of nuclear power plant fire protection
programs. As stated in 10 CFR 50.48, each operating nuclear power plant must
have a fire protection plan that satisfies GDC 3. Basic fire protection
guidance is provided in a number of NRC documents. Branch Technical Position
(BTP) APCSB 9.5-1 and its Appendix A was the basic fire protection guidance
used by the NRC staff to review the fire protection programs of operating
reactors at the time Appendix R was promulgated. BTP APCSB 9.5-1 defined
noncombustible materials as "materials, no part of which will ignite and burn
when subjected to fire." This definition was also used in Regulatory Guide
1.120. For plants licensed after January 1, 1979, the staff used Standard
Review Plan (SRP) 9.5.1 to review nuclear power plant fire protection
programs. This abdance defined noncombustible material as '[a] material
which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when
subjected to fire or heat." The SRP definition was derived from National Fire
Protection Association (NFPA) Standard 220, "Standard on Types of Building
Construction." NFPA 220, which is referenced in the SRP, defines
noncombustible material as "[a] material which in the form in which it is used
and under the conditions anticipated, will not ignite, burn, support
combustion, or release flammable vapors when subjected to fire or heat.
Materials which are reported as passing ASTh E136 - shall be considered
noncombustible materials." On this basis, the NRC staff used the test methods
specified in ASTM E136, an industry consensus test standard, to assess
Thermo-Lag combustibility. As reported in Information Notice 92-82, the NRC
staff concluded that Thermo-lag 330-1 is combustible as defined in the
aforementioned NRC fire protection guidelines.
Enclosure 2
-2-
2.0 Thermo-Lag Combustibility
2.1 NEI Basis
With respect to the noncombustible radiant energy shield, BTP CMEB 9.5-1 and
BTP APCSB 9.5-1 essentially have the same definition of combustible:
Combustible Material - material that does not meet the definition
of noncombustible.
Noncombustible Material - A material which in the form in which it
is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when
subjected to fire or heat.
The important part of [the SRP] definition is *in the form in which it is used
and under the conditions anticipated.' If the physical geometry of the room
(area) and the combustible loading (including combustible material geometry)
is such that Thermo-Lag will not be ignited under the conditions anticipated
then Therno-Lag can be considered non-combustible.
2.2 NRC Response
The intent of the SRP definition is to focus material combustibility
evaluations on the form in which the material is used and the conditions
anticipated. For example, steel plate, when subjected to ASTM E136 test, would not ignite, burn, support combustion, or release flammable vapors.
However, steel wool would ignite and burn.
The results of the NEI tests, ASTM E1321, NLateral Ignition and Flame Travel
Test,' and ASTM E1354, "Cone Calorimeter Test" are used to determine specific
combustion characteristics of a material. The NEI tests determined the
ignition temperature and the heat release rates of Thermo-Lag 330-1. These
combustible characteristics are similar to those of other nuclear power plant
combustible materials, such as fire-retardant plywood and cable Jackets.
Therefore, the staff expects that when exposed to a postulated fire using the
fire loadings, potential heat release rates of the known combustibles, and
predicted fire severities of representative nuclear power plant areas, Thermo-Lag 330-1 material would release flammable vapors, ignite, and burn.
In fact, it is by burning that Thermo-Lag provides Its fire resistive
capabilities.
3.1 NEI Bases
With respect to intervening combustibles, Generic Letter (GL) 86-10 provides
the following guidance:
For fire protection, "no intervening combustible" means that there
is no significant quantity of in-situ materials which will ignite
K) K
-3- and burn located between.redundaiit shutdown system. The amount of
such combustibles that has significance is a judgmental decision.
Generic Letter 86-10 provides further guidance when discussing factors to
consider when dealing with negligible combustibles. In Section 3.6.1 of GL 86-10 the NRC provides the following response as an allowable justification:
"The likely fire propagation direction of burning intervening
combustibles in relation to the location of the vulnerable
shutdown division should be considered."
Therefore, if a material such as Thermo-Lag will neither ignite nor propagate
a fire (self extinguishes) between the two paths of safe shutdown equipment
separated by the 620-ft separation' then the material can be considered a
negligible quantity of intervening combustible and the requirements of
Appendix *R or a plant's specific license are satisfied.
3.2 NL.L Response
In GL 86-10, the NRC staff also stated that if more than a negligible quantity
of combustible materials (such as isolated cable runs) exists between
redundant shutdown divisions, an exemption request should be filed. Moreover, the NRC stated that the regulation is focused on the absence of in-situ
exposed combustibles and that there is no specific definition of no
intervening combustible. In GL 86-10, the NRC staff identified cables in
cable trays which are either open or fully enclosed and cables coated with a
fire retardant material as intervening combustibles. On these bases, the
staff concluded that Thermo-Lag 330-1 material located between redundant safe
shutdown divisions should be considered an intervening combustible material.
Whether or not the amount of Thermo-Lag has significance, could be determined
by a licensee using the guidance of.GL 86-10 (and cited in the NEI guide). If
the licensee determines that the amount of Thermo-Lag has significance, it
could use guidance of GL 86-10 (and cited in the NEI guide) to evaluate the
technical merits of an exemption request.
1 I
K ttachment 2 IN 95-27 May 31, 1995 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No. Subject , Issuance Issued to
95-26 Defect in Safety- 05/31/95 All holders of OLs or CPs
Related Pump Parts due for nuclear power reactors.
to Inadequate Heat
Treatment
94-61, Corrosion of William 05/25/95 All holders of OLs or CPs
Supp. I Power Gate Valve Disc for nuclear power reactors.
Holders
95-25 Valve Failure during 05/11/95 All U.S. Nuclear Regulatory
Patient Treatment with Commission Medical
Gamma Stereotactic Licensees.
Radiosurgery Unit
95-24 Summary of Licensed 04/25/95 All holders of OLs or CPs
Operator Requalification for nuclear power reactors.
Inspection Program
Findings
95-23 Control Room Staffing 04/24/95 All holders of OLs or CPs
Below Minimum Regulatory for nuclear power reactors
Requirements and all licensed operators
and senior operators at
those reactors.
95-22 Hardened or Contaminated 04/21/95 All holders of OLs or CPs
Lubricants Cause Metal for nuclear power reactors.
Clad Circuit Breaker
Failures
95-21 Unexpected Degradation 04/20/95 All holders of OLs or CPs
of Lead Storage Batteries for nuclear power reactors.
94-64, Reactivity Insertion 04/06/95 All holders of OLs or CPs
Supp. I Transient and Accident for nuclear power reactors.
Limits for High Burnup
Fuel
OL - Operating License
CP - Construction Permit
combustibility evaluation methodology prepared by NEI. The results of the
staff review, which was based on existing NRC requirements and guidance, are
detailed in the attached letter of March 13, 1995, to NEI (Accession No.
9503200111). In summary, the staff informed NEI that it will not accept the
use of the NEI methodology to justify the use of Thermo-Lag materials, or
other materials such as fire retardant plywood or cable Jackets, as
noncombustible where noncombustible materials are specified by NRC fire
protection requirements. Alternatives to the NEI guide are discussed in the
March 13, 1995, letter. The Commission approved the letter to NEI in a staff
requirements memorandum of March 8, 1995 (Accession No. 9505090025).
Related Generic Communications
- Generic Letter (GL) 83-33, NNRC Positions on Certain Requirements of
Appendix R,. October 19, 1983.
- GL 86-10, Implementation of Fire Protection Requirements,*
April 24, 1986.
- GL 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for
Fire Barriers Systems Used to Separate Redundant Safe Shutdown
Trains Within the Same Fire Area,3 March 25, 1994.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
orig /s/'d by BEKGrimes
Brian K. Grimes, Director
Division of Project Support
Office of Nuclear Reactor Regulation
Technical contact: Pat Madden, NRR
(301) 415-2854 Attachments:
1. Letter of March 13, 1995, from C. McCracken, NRC,
to A. Marion, NEI, and its enclosures
2. List of Recently Issued NRC Information Notices
DOCUMENT NAME: 95-27.IN *See previous concurrence
OFFICE SPLB:DSSA ADM:PUB SC/SPLB:DSSA C/SPLB:DSSA D/DSSA
NAME DOudinot* Tech Ed* SWest* CMcCracken* GHolahan*
DATE 103/31/95 103/30/95 03/31/95 . 03/31/95 J 04/03/95 T .- 1 .r
OFFICE IOECB:DOPS IOECB:DOPS IC/OECB:DOPS
NAME JCarter* RKiessel* AChaffee* 1 i I
DATE 04/04/95 05/09/95 05/15/95 OS/21J9 j
rr
-- - ---- en
Irnn
UtPI1L1AL KLUKU LUMr
IN 95-XX
May xx, 1995 The NRC staff, with technical assistance from NIST, reviewed the Thermo-Lag
combustibility evaluation methodology prepared by NEI. The results of the
staff review, which was based on existing NRC requirements and guidance, are
detailed in the attached letter of March 13, 1995, to NEI (Accession No.
9503200111). In summary, the staff informed NEI that it will not accept the
use of the NEI methodology to justify the use of Thermo-Lag materials, or
other materials, as noncombustible where noncombustible materials are
specified by NRC fire protection requirements. Alternatives to the NEI guide
are discussed in the March 13, 1995, letter. The Commission approved the
letter to NEI in a staff requirements memorandum of March 8, 1995 (Accession
No. 9505090025).
Related Generic Communications
- Generic Letter (GL) 83-33, "NRC Positions on Certain Requirements of
Appendix R," October 19, 1983.
- GL 86-10, "Implementation of Fire Protection Requirements,"
April 24, 1986.
- GL 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for
Fire Barriers Systems Used to Separate Redundant Safe Shutdown
Trains Within the Same Fire Area," March 25, 1994.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
Brian K. Grimes, Director
Division of Project Support
Office of Nuclear Reactor Regulation
Technical contact: Pat Madden, NRR
(301) 415-2854 Attachments:
1. Letter of March 13, 1995, from C. McCracken, NRC,
to A. Marion, NEI, and its enclosures
2. List of recently issued NRC Information Notices
DOCUMENT NAME: G:\ATB1\ZINICOMB.DO *See previous concurrence I
OFFICE SPLB:DSSA ADM:PUB SC/SPLB:DSSA C/SPLB:DSSA D/DSSA
NAME DOudinot* Tech Ed* SWest* CMcCracken* GHolahan*
DATE 03/31/95 03/30/95 03/31/95 03/31/95 04/03/95 I I1__ ___ I 11 nFrTrr I nICRr-nnfD4 I lFrROB-DP5 XV /OFCB:DOPS I D/DOPS
NAME
DATE
JCarter*RKiessel* l
04/04/95 105/09/95 ! I AC___e_
n/ 15v/
UFFILIAL KtLUKU WHY
/95 BGrimes
! aJI
_
11
J
IN 92-82, Supp. 1 April xx, 1995 The NRC staff, with technical assistance from NIST, reviewed the Thermo-Lag
combustibility evaluation methodology prepared by NEI. The results of the
staff review, which was based on existing NRC requirements and guidance, are
detailed in the attached letter of March 13, 1995, to NEI. In summary, the
staff informed NEI that it will not accept the use of the NEI methodology to
justify the use of Thermo-Lag materials, or other materials, as noncombustible
where noncombustible materials are specified by NRC fire protection
requirements. Alternatives to the NEI guide are discussed in the March 13,
1995, letter. The Commission approved the letter to NEI in a staff
requirements memorandum of March 8, 1994.
Related Generic Communications
- Generic Letter (GL) 83-33, "NRC Positions on Certain Requirements of
Appendix R," October 19, 1983.
- GL 86-10, "Implementation of Fire Protection Requirements,"
April 24, 1986.
- GL 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for
Fire Barriers Systems Used to Separate Redundant Safe Shutdown
Trains Within the Same Fire Area," March 25, 1994.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
Brian K. Grimes, Director
Division of Project Support
Office of Nuclear Reactor Regulation
Technical contact: Pat Madden, NRR
(301) 415-2854 Attachments:
1. Letter of March 13, 1995, from C. McCracken, NRC,
to A. Marion, NEI, and its enclosures
2. List of recently issued NRC Information Notices
DOCUMENT NAME: G:\ATB1\ZINICOMB.DO *See previous concurrence
OFFICE SPLB:DSSA ADM:PUB SC/SPLB:QSSA PiS
AC/S5A: A
NAME D4a nr>t Tech Ed* SWest McMraac&W "HfaL
DATE I&S///95 103/30/95 103 /SI /95 / (/95 Jsf /Z3 /95 OFFICE IOECB:DOPS IOECB:DOPS Al,IC/OECB:DOPS ID/DOPS
NAME J JRKiessel / AChaffee BGrimes
DATE /95 6 /9 /95
6 /9/ /95 OFICIAL KLLUKR LUPY
l
IN 92-82, Supp. 1 April xx, 1995 The NRC staff, with technical assistance from NIST, reviewed the Thermo-Lag
combustibility evaluation methodology prepared NEI. The results of the staff
review, which was based on existing NRC requirements and guidance, are
detailed in the attached letter of March 13, 1995, to NEI. In summary, the
staff informed NEI that it will not accept the use of the NEI methodology to
justify the use of Thermo-Lag materials where noncombustible materials are
specified by NRC fire protection requirements or to assess the combustibility
hazards of Thermo-Lag materials. The letter to NEI was approved by the
Commission in a Staff Requirements Memorandum of March 8, 1994.
Related Generic Communications
- Generic Letter (GL) 83-33, "NRC Positions on Certain Requirements of
Appendix R," October 19, 1983.
- GL 86-10, "Implementation of Fire Protection Requirements,"
April 24, 1986.
- GL 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for
Fire Barriers Systems Used to Separate Redundant Safe shutdown Trains
Within the Same Fire Area," March 25, 1994.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contract listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
Brian K. Grimes, Director
Division of Project Support
Office of Nuclear Reactor Regulation
Technical contact: Pat Madden, NRR
(301) 415-2854 Attachments:
1. Letter of March 13, 1995, from C. McCracken, NRC,
to A. Marion, NEI, and its enclosures
2. List of recently issued NRC information otices
DOCUMENT NAME: G:\ATB1\ZINICOMB.DO
OFFICE SPLB:DSSA ADM:PUB SC/SPLB:DSSA C/SPLB:DSSA D/DSSA
NAME DOudinot Tech Ed 1 SWest CMcCracken GHolahan
DATE I /95 13/30/95 / /95 / /95 I / /95
7 7.1..
OFFICE IOECB:DOPS IOECB:DOPS IC/OECB:DOPS ID/DOPS
NAME JCarter RKiessel IAChaffee BGrimes
DATE / /95 1 /,95 , / 95 1 / /95 OFFICIAL RECORD COPY