ML061530275
| ML061530275 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/30/2006 |
| From: | Edington R Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| +kBR1SISP20060621, GL-06-003, NLS2006047 | |
| Download: ML061530275 (6) | |
Text
H Nebraska Public Power District Always there when you need us 50.54 NLS2006047 May 30, 2006 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852
Subject:
Response to NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006 Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46
Reference:
NRC Generic Letter 2006-03, dated April 10, 2006, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" The purpose of this letter is for Nebraska Public Power District (NPPD) to provide the information requested by the referenced Generic Letter (GL) 2006-03. The Nuclear Regulatory Commission (NRC) issued the GL to confirm compliance with existing applicable regulatory requirements in light of information provided in the GL regarding Hemyc and MT fire barrier systems, and if appropriate, take additional actions. Specifically, although Hemyc and MT fire barriers may be relied on to protect electrical and instrumentation cables and equipment that provide safe shutdown capability during a fire, NRC testing has revealed that both materials failed to provide the protective function intended for compliance with existing regulations. The NRC requested licensees to provide a written response within 60 days describing the use of Hemyc, MT and other fire barrier systems at their nuclear power plants. The requested information is to be submitted under the requirements of 10 CFR 50.54(f).
The Cooper Nuclear Station (CNS) response to the requested information in GL 2006-03 is contained in the attachment to this submittal. NPPD is not making any commitments as a result of this response.
Should you have any questions or require additional information, please contact Paul Fleming, Licensing Manager, at (402) 825-2774.
COOPER NUCEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www-nppd.com
NLS2006047 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
5/30/0 G
Date Sincerely, Randall K. Edington Vice President-Nuclear and Chief Nuclear Officer
/js Attachment cc:
Regional Administrator w/attachment USNRC - Region IV Cooper Project Manager w/attachment USNRC - NRR Project Directorate IV-l Senior Resident Inspector w/attachment USNRC - CNS Nebraska Health and Human Services w/attachment Department of Regulation and Licensure NPG Distribution w/attachment CNS Records w/attachment
NLS2006047 Attachment Page 1 of 3 RESPONSE TO GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" NRC Requested Actions Within 60 days of the date of this letter [April 10, 2006], addressees are requested to determine whether or not Hemyc or MTfire barrier material is installed and relied upon for separation and/or safe shutdown purposes to satisfy applicable regulatory requirements. In addition, licensees are asked to describe controls that were used to ensure the adequacy of other fire barrier types, consistent with the assessment requested in GL 92-08.
Addressees that credit Hemyc or MTfor compliance are requested to provide information regarding the extent of installation, whether the material complies with regulatory requirements, and any compensatory actions in place to provide equivalent protection and maintain safe shutdown function of affected areas of the plant in light of the recent findings associated with Hemyc and MT. Licensees are requested to provide evaluations to support conclusions that they are in compliance with regulatory requirements for the Hemyc and MT applications. Licensees that cannot justify their continued reliance on Hemyc or MT are requested to provide a description of corrective actions taken or planned and a schedule for milestones, including when full compliance will be achieved.
Compensatory measures and corrective actions must be implemented in accordance with existing regulations commensurate with the safety significance of the nonconforming condition. The NRC expects all licensees to fully restore compliance with IOCFR50.48 and submit the required documentation to the NRC by December 1, 2007.
NPPD Response to Requested Actions NPPD has taken the actions requested within 60 days and the responses are provided below.
NRC Requested Information NRC Request ](a) - Within 60 days of the date of this GL [April 10, 2006], provide a statement on whether Hemyc or MTfire barrier material is used and whether it is relied upon for separation and/or safe shutdown purposes in accordance with the licensing basis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
NPPD Response to Request 1 (a):
Hemyc or MT fire barrier material is not installed at CNS. CNS does not rely on either Hemyc, MT or other fire wrap material for separation and/or safe shutdown purposes.
NLS2006047 Attachment Page 2 of 3 NRC Request 1(b) - Within 60 days of the date of this GL [April 10, 2006], provide a description of the controls that were used to ensure that other fire barrier types relied on for separation of redundant trains located in a single fire area are capable ofproviding the necessary level ofprotection. Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.
NPPD Response to Request 1(b):
Procedures that implement the CNS Fire Hazards Analysis (FHA) provide controls of fire barrier types relied upon for separation and/or safe shutdown purposes in accordance with the CNS licensing basis. Fire barriers are assigned based on the construction features associated with the barrier that meet industry acceptance criteria. Construction features such as barrier material, barrier thickness, fire damper design, fire door design and penetration seal assemblies are reviewed as part of assigning a rating to an individual barrier. All barriers are documented in the FHA along with the fire rating.
It should also be noted that the concerns in GL 92-08 were resolved for CNS per Letter from James R. Hall, U.S. Nuclear Regulatory Commission to Guy R. Horn, Nebraska Public Power District, dated May 30, 1995, "Response to NRC Generic Letter (GL) 92-08, Thermo-Lag 330-1 Fire Barriers - Cooper Nuclear Station (TAC No. M85540)".
Design changes were instituted that resulted in the removal of all Thermo-Lag 330-1 material.
NRC Request 2(a) - Within 60 days of the date of this GL letter [April 10, 2006], for those addressees that have installed Hemyc or MT fire barrier materials, discuss the extent of the installation (e.g., linear feet of wrap, areas installed, systems protected).
NPPD Response to Request 2(a):
Per the response to Request l(a), Hemyc or MT fire barrier material is not installed at CNS.
NRC Request 2(b) - Within 60 days of the date of this GL letter [April 10, 2006], for those addressees that have installed Hemyc or fT fire barrier materials, discuss whether the Hemyc and/or MT installed in their plants is conforming with their licensing basis in light of recent findings, and if these recent findings do not apply, why not.
NPPD Response to Request 2(b):
Per the response to Request 1 (a), Hemyc or MT fire barrier material is not installed at CNS.
NRC Request 2(c) - Within 60 days of the date of this GL letter [April 10, 2006], for those
NLS2006047 Attachment Page 3 of 3 addressees that have installed Hemyc or MT fire barrier materials, the compensatory measures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associated with Hemyc and MT installations, including evaluations to support the addressees' conclusions.
NPPD Response to Request 2(c):
Per the response to Request 1 (a), Hemyc or MT fire barrier material is not installed at CNS.
NRC Request 2(d) - Within 60 days of the date of this GL letter [April 10, 2006], for those addressees that have installed Hemyc or MT fire barrier materials, provide a description of and implementation schedules for, corrective actions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensing basis.
NPPD Response to Request 2(d):
Per the response to Request 1(a), Hemyc or MT fire barrier material is not installed at CNS.
NRC Request 3: - No later than December 1, 2007, addressees that identified in L.a. Hemyc or MT configurations are requested to provide a description of actions taken to resolve the nonconforming conditions described in 2. d.
NPPD Response to Request 3:
Per the response to Request 1 (a), Hemyc or MT fire barrier material is not installed at CNS.
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS0 Correspondence Number: NLS2006047 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None I
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4 PROCEDURE 0.42 1
REVISION 19 1
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