ML060860014

RAI, Regarding Exemption Request for Hemyc Fire Wrap

ML060860014
Person / Time
Site:	FitzPatrick
Issue date:	04/03/2006
From:	Boska J Plant Licensing Branch III-2
To:	Kansler M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MC7995
Download: ML060860014 (8)

Text

April 3, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING EXEMPTION REQUEST FOR HEMYC FIRE WRAP (TAC NO. MC7995)

Dear Mr. Kansler:

By letter dated July 27, 2005, Entergy Nuclear Operations, Inc. requested an exemption for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) from the requirements of Title 10 of the Code of Federal Regulations, Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," as it applies to JAFNPP for Fire Area 1C.

Specifically, the exemption request applies to the cable and equipment wrapped in Hemyc in the West Cable Tunnel (Fire Area 1C/Fire Zone CT-1) which are relied on for safe shutdown during a fire. The licensee submitted an evaluation to demonstrate that, based on the absence and/or control of ignition sources, the adequacy of detection and suppression systems, and the capability of the existing Hemyc fire wrap in this fire area, an equivalent level of protection exists in this area, as would be provided by a 1-hour rated thermal fire barrier required for the protection of safe shutdown electrical cables and equipment.

The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). During a telephone call on March 24, 2006, the Entergy staff indicated that a response to the RAI would be provided within 45 days of the date of this letter.

Please contact me at (301) 415-2901 if you have any questions on this issue.

Sincerely,

/RA/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

RAI cc w/encl: See next page

ML060860014

• See RAI memo OFFICE LPL1-1/PM LPL1-1/LA AFPB/BC LPL1-1/BC NAME JBoska SLittle SWeerakkody* RLaufer DATE 4/03/06 4/03/06 3/16/06 4/03/06 FitzPatrick Nuclear Power Plant cc:

Mr. Gary J. Taylor Resident Inspector's Office Chief Executive Officer James A. FitzPatrick Nuclear Power Plant Entergy Operations, Inc. U. S. Nuclear Regulatory Commission 1340 Echelon Parkway P.O. Box 136 Jackson, MS 39213 Lycoming, NY 13093 Mr. John T. Herron Ms. Charlene D. Faison Sr. VP and Chief Operating Officer Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Theodore A. Sullivan Mr. Michael J. Colomb Site Vice President Director of Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant 440 Hamilton Avenue P.O. Box 110 White Plains, NY 10601 Lycoming, NY 13093 Mr. David Wallace Mr. Kevin J. Mulligan Director, Nuclear Safety Assurance General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Mr. James Costedio Mr. Oscar Limpias Manager, Regulatory Compliance Vice President Engineering Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant 440 Hamilton Avenue P.O. Box 110 White Plains, NY 10601 Lycoming, NY 13093 Mr. Christopher Schwarz Mr. Travis C. McCullough Vice President, Operations Support Assistant General Counsel Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. John F. McCann Mr. Charles Donaldson, Esquire Director, Licensing Assistant Attorney General Entergy Nuclear Operations, Inc. New York Department of Law 440 Hamilton Avenue 120 Broadway White Plains, NY 10601 New York, NY 10271

FitzPatrick Nuclear Power Plant cc:

Regional Administrator, Region I Ms. Stacey Lousteau U.S. Nuclear Regulatory Commission Treasury Department 475 Allendale Road Entergy Services, Inc.

King of Prussia, PA 19406 639 Loyola Avenue Mail Stop L-ENT-15E Oswego County Administrator New Orleans, LA 70113 Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. James H. Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306

REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FOR HEMYC FIRE WRAP ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 By letter dated July 27, 2005, (Agencywide Document Access and Management System Accession Number ML052210382), Entergy Nuclear Operations, Inc. requested an exemption for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) from the requirements of Title 10 of the Code of Federal Regulations, Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," as it applies to JAFNPP for Fire Area 1C.

Specifically, the exemption request applies to the cable and equipment wrapped in Hemyc in the West Cable Tunnel (Fire Area 1C/Fire Zone CT-1) which are relied on for safe shutdown during a fire. The licensee submitted an evaluation to demonstrate that, based on the absence and/or control of ignition sources, the adequacy of detection and suppression systems, and the capability of the existing Hemyc fire wrap in this fire area, an equivalent level of protection exists in this area, as would be provided by a 1-hour rated thermal fire barrier required for the protection of safe shutdown electrical cables and equipment. The Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has the following questions:

1. The Hemyc fire wrap configuration used at FitzPatrick is described as having an inner and outer covering of aluminized Siltemp, which is coated with a reflective material. This configuration is described as reflecting more radiant energy than the non-aluminized Siltemp configuration tested by the NRC. However, the NRC staff has seen no evidence to support this conclusion.

a) Is there testing or additional information (perhaps from the manufacturer) to support the comment that aluminized Siltemp can be expected to have better heat resistive properties than non-aluminized Siltemp?

b) Also, if aluminum is used to line the inner and outer surfaces of the wrap, and aluminum is heat conductive, then what are the effects of convective heat on the performance of this fire wrap?

2. The Hemyc fire wrap configuration used at FitzPatrick is described as using overlap collars approximately 8 to 9 inches wide. This is compared to the configuration tested by the NRC, which used 6-inch collars and resulted in the Hemyc fire wrap joints separating (or opening) and exposing cable directly to the heat source. Therefore, the larger collars used at FitzPatrick for this application are described as a means for reducing the potential for openings as documented in the NRC test.

However, subsequent industry tests were done to determine whether improvements to the configuration tested by the NRC would result in improved Hemyc performance. Although the upgrades, including use of increased collar widths, double wrapped elbows, and larger overlap area at joints, resulted in a reduction in exposed conduit due to separated (opened)

Enclosure

joints; it also resulted in similar temperature readings at the thermocouples to that observed in the NRC tests, indicating similar thermal failure results. Therefore, although it is possible that the increased collar width contributed to the reduction in joint openings, thermal failure was not mitigated and remains the staff's primary concern. The staff has seen no evidence to support the conclusion that 8-inch collars would reduce the potential for thermal failure of the conduit. Is there testing or additional information to support improved performance by use of the increased collar width?

3. On page 2 of the licensee's submittal, the last paragraph states that the testing performed by the NRC supports the expectation that the installed configuration at FitzPatrick will meet or exceed a 30-minute fire rating. Although the NRC test results for a 4-inch conduit indicate failure as early as 33 minutes following the onset of a fire, when empty, and 43 minutes when full; other components of the raceway failed in less than 30 minutes. The unbanded junction boxes failed as early as 15 minutes into the event. The FitzPatrick configuration includes a pull box with stitched end pieces that are not banded. These end pieces, which could fail similarly to the stitched portion of the unbanded junction box that failed during the NRC test, are described as being secured by conduit wrap butted against them. Please provide a photograph or drawing of this pull box configuration, illustrating the security added at the end pieces. Also, please describe in detail the rationale for the statement that failure of these end pieces "is not expected to heat up the pull box to the point it would cause the cable to fail."

4. The submittal describes Hemyc wrapped structural supports. Steel supports were tested by the NRC separately from the conduit and found to fail as early as 13 minutes into the event.

The additional heat load transferred to the conduit by the steel supports was not considered in the conduit tests. The FitzPatrick configuration is described as including five structural supports, completely wrapped except for a portion of the base plate. How has it been determined that the heat transfer from the exposed base plate would not adversely affect the protected cable? In the event of a fire, what would be the impact of heat transfer from the uncovered base plate through the supports to the conduit? In responding to these questions, please include the distance from the baseplate to the conduit containing the cable, and quantify the distance into an hourly rating using the NRC testing for similar supporting structures (angle iron, unistrut). Please also include the area of the base plate that is uncovered.

5. Are the baseplates near cable trays such that, if there is a cable tray fire, they could be directly exposed?

6. The submittal identifies structural supports only. Are there any intruding steel supports in this application? Please identify any plant components, such as steel supports, pipes, conduits, trays, etc., that intrude into the fire wrap configuration that may cause additional heat transfer to the protected cable. For each configuration of an intruding component, describe the impact of heat transfer to the protected cables.

7. The structural support base plates are described as mounted in place with Hilti bolts to the concrete ceiling. Are these bolts covered by fire wrap? In the event of an intense fire, could concrete spalling compromise the ability of these bolts to function? If not, why not?

8. 3.75 feet of the 5-inch conduit near the wall of the tunnel is described as flex-conduit. Is this flex-conduit wrapped in Hemyc? The NRC staff did not test flex-conduit wrapped in Hemyc; therefore, the staff has no basis to determine the performance of Hemyc-wrapped flex-conduit. Is there any testing or additional information to support the expectation that Hemyc-wrapped flex-conduit will perform similarly to the rigid conduit tested?