L-92-219, Responds to NRC Bulletin 92-001, Thermo-Lag 330 Fire Barrier Sys. Compensatory Measures Implemented in Areas Containing Subj Fire Barrier Matl,Including Roving Fire Watch & Verification of Fire Detector Operability
| ML17309A686 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/27/1992 |
| From: | Sager D FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-92-001, IEB-92-1, L-92-219, NUDOCS 9207300239 | |
| Download: ML17309A686 (10) | |
Text
ACCELERATED DISTBXBUTION DEMONSTPJ!!.TION SYSTEM DOCKET ¹ 05000335 05000389 R'
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NOTES:
REGULATL.
INFORMATION DISTRIBUTION.
.STEM (RIDS) 1' ACCESSION NBR:9207300239 DOC.DATE: 92/07/27 NOTARIZED: YES FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
0,-389 St. Lucie Plant, Unit 2, Florida Power
& Light Co.
AU'i.'H.NAME AUTHOR AFFILIATION SAGER,D.A.
Flor ida Power
& pight Co.
RECIP.NAM" RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC Bulletin 92-001, "Thermo-Lag 330 Fire Barrier Sys." Compensatory measures implemented in areas containing subj fire barrier matl,including roving fire watch
& verification of fire detector operability.
DISTRIBUTION CODE:
IE49D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: NRC Bulletin 92-001, Failure of Thermal-Log 330 Fire Barrier Sys REC1PIENT ID CODE/NAME PD2-2 LA NORRIS,J INTERNAL: NBRJ3 T/SPLB REG FI Ol GN2 ILE COPIES LTTR ENCL 1
0 1
1 2
2 1
1 1
1 RECIPIENT ID CODE/NAME PD2-2 PD NRR/PD3-1 RES/EMEB COPIES LTTR ENCL 1
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EXTERNAL: NRC PDR 1
1 NSIC R
D'OTE TO ALL"RIDS" RECIPIENTS:
D D
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LINIS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 11 ENCL 10
0 P.O. Box 128, Ft. Pierce, FL 34954-0128 July 27, 1992 L-92-219 10 CFR 50.4 10 CFR 50. 54 (f)
U.
S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.
C.
20555 RE:
St. Lucie Units 1 and 2
Docket Nos.
50-335 and 50-389 NRC Bulletin 92-01 Failure of Thermo-La 330 Fire Barrier S stem The Florida Power and Light Company (FPL) response to NRC Bulletin (NRCB) 92-01 for St. Lucie Units 1 and 2 is attached.
NRC Bulletin 92-01, Failure of Thermo-Lag 330 Fire Barrier System to Maintain Cabling in Alide Cable Trays and Small Conduits Free from Fire Damage, issued on June 24, 1992, notified licensees of fire endurance test failures of Thermo-Lag 330 fire barrier systems.
The NRCB requested licensees to identify the areas of the plant which have Thermo-Lag 330 installed, implement appropriate compensatory
- measures, and within 30 days provide written notification of the actions taken and the measures being taken to restore or ensure fire barrier operability.
The attached information is provided pursuant to the requirements of Section 182a of the Atomic Energy Act of 1954, as
- amended, and 10 CFR 50.54(f).
Please contact us if there are any questions about this submittal.
Very truly yours, D. A.
Vice r St.
L ger sident ie Plant DAS/GRM/kw DAS/PSL g743-92 Attachments Zpe cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant I
an FPL Group company
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St. Lucie Units 1 and 2
Docket Nos.
50-335 and 50-389 NRC Bulletin 92-01 Failure of Thermo-La 330 Fire Barrier S stem STATE OF FLORIDA
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COUNTY OF PALM BEACH
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D. A. Sager being first duly sworn, deposes and says:
That he is Vice President, St. Lucie Plant for the Nuclear Division of Florida Power
& Light Company, the Licensee hereinr That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
D. A.
ger STATE OF FLORIDA COUNTY OF The foregoing instrument was.acknowledged before me t,h's
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by D.. A. S~ger, who is perso a ly known to me and who~ did take an oath.
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St. Lucie Units 1 and 2
Docket Nos.
50-335 and 50-389 NRC Bulletin 92-01 Failure of Thermo-La 330 Fire Barrier S stem NRC REQUEST 1:
For those plants that use either 1-or 3-hour pre-formed Thermo-Lag 330 panels and conduit
- shapes, identify the areas of the plant which have Thermo-Lag 330 fire barrier material installed and determine the plant areas which use this material for. protecting either small diameter conduit or wide trays (widths greater than 14 inches) that provide safe shutdown capability.
FPL RESPONSE:
The Appendix "R" cables required for safe shutdown of St.
Lucie Units 1 and 2 have been reviewed and evaluated in an engineering evaluation; both units use Thermo-Lag fire barrier systems.
The conduits in question for both units are all between 1-1/2 inches and 5 inches and the conduit boxes are less than 14 inches in width.
None of the Appendix "R" conduits fall into the category of the conduits mentioned in NRCB 92-01 that clearly failed the test.
Also, neither Unit 1 nor Unit 2 has any Appendix "R" wrapped cable trays.
NRC REQUEST 2:
In those plant areas in which Thermo-Lag fire barriers are used to protect wide cable trays, small conduits, or both, the licensee should implement, in accordance with plant procedures, the appropriate compensatory
- measures, such as fire watches, consistent with those that would be implemented by either the plant Technical Specifications or the operating license for an inoperable fire barrier.
FPL RESPONSE:
St.
Lucie Units 1
and 2
do have Thermo-Lag 330 fire barrier material installed.
In accordance with plant procedures, appropriate compensatory measures were verified to be in place on June 25, 1992.
The compensatory measures included a roving fire watch and verification of fire detector operability.
For the containment fire
- area, Operations monitored containment air temperature on a periodic basis since the containment is not accessible during operation.
Based on the evaluation by a fire protection engineer discussed in Response 3, the above-mentioned compensatory measures are no longer required for NRC Bulletin No.
92-01.
~ '
NRC REQUEST 3:
Each
- licensee, within 30 days of receiving this bulletin, is required to provide a written notification stating whether it has or does not have Thermo-Lag 330 fire barrier systems installed in its facilities.
Each licensee who has installed Thermo-Lag 330 fire barriers is required to inform the NRC, in writing, whether it has taken the above actions and is required to describe the measures being taken to ensure or restore fire barrier operability.
FPL RESPONSE:
St. Lucie plant does have Thermo-Lag 330 fire barriers installed in its facilities as discussed in the.response to Requested Action 1 and compensatory measures were implemented as discussed in the response to Requested Action 2.
A summary of the engineering evaluation of the Appendix "R" cables protected by the Thermo-Lag 330 fire barrier system at St. Lucie plant is provided.
Based on a
review of the test data given in NRCB 92-01 and discussions with the NRC, it can be concluded that both 4 inch and 5 inch conduits are adequately protected by Thermo-Lag 330-1.
As shown in CPSES Thermo-Iag Barrier Applications, Thermo-Iag Fire Test Condui t and J-Box Test Assembli es, Test Resul ts, (Preli minary),
dated June 2,9,
- 2992, the maximum cable surface temperatures dropped from 609'F to 463'F to 233'F by going from 3/4 inch to 1 inch to 5 inch conduit, respectively.
From the test results it can be concluded that a clear correlation exists between peak cable temperature and conduit size or peak cable temperature and Thermo-Lag outside diameter.
This correlation is attributable to the relative increase in heat sink materials within the Thermo-Lag 330-1 enclosure as the conduit size increases.
From this correlation, the expected maximum temperature of the cable, in conduit 1 1/2 inches in diameter and larger, can be anticipated to be significantly less than 463'F.
This is below the temperature degradation threshold (minimum 566'F) of cable "insulations tested by EPRI NP-1767, A Study of Damageability of Electrical Cables in Simulated Fire Environments, Final Report, dated March 2982., which are representative of the cable types used at St. Lucie.
The test data of NRCB 92-01 showed that the 1 inch conduit meets the acceptance criteria outlined in Generic Letter 86-10, Implementation of Fire Protection Requirements, which states in part:
justification should be provided for use of material which does not meet the '325'F criterion.
This may be based on an
- analysis, demonstrating that the maximum recorded temperature is sufficiently below the cable insulation ignition temperature."
The maximum cable surface temperatures for 1 inch conduit from the
CPSES Thermo-Lag Barrier Applications, Thermo-Lag Eire Test Conduit and J-Box Test Assemblies, Test Results, (Preliminary),
June 29,
- 2992, was 463'F.
Although this temperature is greater than the 325'F criterion, the minimum. degradation.
temperature from the critical energy data of the EPRI NP-1767 tests is 566'F and is representative of the St. Lucie cables.
Therefore, all Appendix "R" conduit applications at St. Lucie, which are 1 1/2 inches in diameter or greater, will be free of fire damage and remain operable.
Based on the above, no continuing compensatory measures need to be taken for NRCB 92-01 at this time.