W3F1-2006-0028, Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
| ML061600210 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/07/2006 |
| From: | Ridgel J Entergy Nuclear South |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| +kBR1SISP20060621, GL-06-003, W3F1-2006-0028 | |
| Download: ML061600210 (8) | |
Text
ýEnMTe~g Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057 W3F1-2006-0028 June 7, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Waterford 3 SES Docket No. 50-382 License No. NPF-38
References:
- 1. NRC letter dated April 10, 2006, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
Dear Sir or Madam:
Per Reference 1, the NRC issued Generic Letter (GL) 2006-03 to request facilities to confirm compliance with existing applicable requirements, 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 in 2005 has revealed that both materials failed to provide the protective function intended for compliance with existing regUlations. The requested information is being provided under the requirements of 10 CFR 50.54(f).
The Waterford 3 response to the requested information in GL 2006-03 is attached.
No new commitments are contained in this submittal. If you have any questions or require additional information, please contact Oscar Pipkins at (504) 739-6707.
W3F1-2006-0028 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 7, 2006.
Sincerely,
,Y.ARdel Acting Nuclear Safety Assurance Director JAR/OPP/ssf
Attachment:
Response to Generic Letter 2006-03 for Waterford 3 SES
W3FI-2006-0028 Page 3 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Watelford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. Mel B. Fields Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004
Attachment W3F1 -2006-0028 Response to Generic Letter 2006-03 for Waterford 3 SES
Attachment to W3FI-2006-0028 Page 1 of 4 Requested Information Addressees are requested to determine whether or not Hemyc or MT fire barriermaterialis installed and relied upon for separationand/orsafe shutdown purposes to satisfy applicable regulatoryrequirements. In addition, licensees are asked to describe controls that were used to ensure the adequacy of other fire barriertypes, consistent with the assessment requested in GL 92-08.
Addressees that credit Hemyc or MT for compliance are requested to provide information regardingthe extent of installation,whether the materialcomplies with regulatoryrequirements, and any compe rsatory actionsin 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 corn oliance with regulatoryrequirementsfor the Hemyc and MT applications.
Licensees that cannotjustify theircontinued reliance on Hemyc or MT are requested to provide a descriptionof 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 regulationscommensurate with the safety significance of the nonconforming condition.
The NRC expects all licensees to fully restore compliance with 10CFR50.48and submit the requireddocumentation to the NRC by December 1, 2007.
NRC Request 01(a):
Provide a statement on whether Hemyc or MT fire barriermaterialis used and whether it is relied upon for ,;eparationand/or safe shutdown purposes in accordancewith the licensing basis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
Waterford 3 Response to Request I(a):
Waterford 3 Nuclear Station credited the Hemyc fire barrier system as a one hour fire rated barrier for Appendix R compliance purposes. Waterford 3 does not use the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated MT configuration. The Hemyc system is also used in the containment building as a radiant energy shield.
NRC Request 11(b):
A descriptionof the controls that were used to ensure that other fire barriertypes relied on for separationof redundanttrains located in a single fire area are capable of providing the necessary level of protection. Addressees may reference theirresponses to GL 92-08 to the extent that the responses address this specific issues.
Waterford 3 Rcsponse to Request 1(b):
Waterford 3 also uses the 3M Interam fire barrier system in 1 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated configurations The 3M system is qualified by various fire tests conducted by
Attachment to W3F1 -2006-0028 Page 2 of 4 independent testing laboratories consistent with the guidance provided by Generic Letter 86-10 Supplement 1. This is the only fire barrier raceway system approved by Entergy for use in future installations at Waterford 3 Nuclear Station.
NRC Request 2(a):
Forthose addresseesthat have installed Hemyc or MT fire barriermaterials,discuss the extent of the installation (e.g., linear feet of wrap, areasinstalled, systems protected).
Waterford 3 Response to Request 2(a):
Waterford 3 has approximately 2000 feet of Hemyc conduit wrap installed on conduits ranging in sizes from 3/4 to 5 inches in diameter. In addition there are approximately 1200 feet of Hemyc wrap installed on 24" wide cable trays. Hemyc wrap is installed on 7 electrical/junction boxes and 5 containment electrical penetrations. Conduits, electrical/junction boxes and containment penetration boxes are directly wrapped with Hemyc. Tray wrap is installed using the standard vendor design consisting of Hemyc wrap installed on a frame assembly that provides an air space between the wrap assembly and the raceway. The Hemyc wrap is credited in 19 fire areas/zones.
NRC Request !(b):
Forthose addressees that have installedHemyc or MT fire barriermaterials,discuss whether the Hemyc and/brMT installed in theirplants is conforming with theirlicensing basis in light of recent findings, and if these recent findings do not apply, why not.
Waterford 3 Response to Request 2(b):
The Hemyc system was NRC approved for use at Waterford 3 by NUREG-0787 Supplement 5 Section 9.5.1.4. This document stated:
"By letter dated February 14, 1983, the applicant submitted results of tests conducted by an independent testing laboratory on an insulating blanket and wrap that will be used to protect shutdown-related cable trays and conduits. This material, in conjunction with area-wide smoke detection and fire suppression systems, is in compliance with Section III G.2 of Appendix R to 10 CFR 50. The blanket and wrap were tested in configurations representative of what is to be found in the plant, with unprotected tray supports, using cables represEntative of those used in the plant. As a result of the tests, the material has been demonstrated to protect cable from visible fire damage and to maintain circuit integrity duringi an ASTM E-1 19 1-hour fire exposure. The material is not adversely affected by a water hose stream and is capable of limiting temperature rise on the un-exposed side of trays and conduits to not more than 250F above ambient, which is well below the temperature at which similar IEEE-qualified cable began to fail in tests conducted independently for NRC at Underwriters Laboratories (report to be published).
The Staff concludes that this protection, coupled with the other automatic and manual
Attachment to W3F1 -2006-0028 Page 3 of 4 fire protection available, will provide reasonable assurance that one train of safe shutdown cable remains free of fire damage and, therefore, is acceptable."
However, based on NRC testing, the Hemyc installed at Waterford 3 does not conform to the licensing basis and has been declared and remains inoperable at this time.
NRC Request ,2(c):
For those addresseesthat have installedHemyc or MT fire barriermaterials,discuss the compensatorymeasures that have been implemented to provide protection and maintain the safe shutdown Ftunction of affected areas of the plant in light of the recent findings associated with Hemyc and MT installations,including evaluationsto supportthe addressees'conclusions.
Waterford 3 Response to Request 2(c):
Waterford 3 Technical Requirements Manual (TRM) Section 3.7.11 applies to fire rated assemblies. The TRM action statement states:
'With one or more of the above required fire rated assemblies and/or sealing devices inoperable, wilhin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either establish a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of the fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol, unless the inoperable assembly is inside the containment, then inspect that containment area at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or monitor and record air temperature at least once per hour at each of the operable Containment Fan Cooler air intakes."
All credited Hemyc wrap, including Containment wrap used as a radiant energy shield, has been conservatively declared inoperable and the applicable TRM actions initiated pending resolution.
NRC Request 2(d):
For those addresseesthat have installed Hemyc or MT fire barriermaterials,provide a description of, and implementation schedules for, corrective actions, including a description of any licensing actions or exemption requestsneeded to support changes to the plant licensing basis.
Waterford 3 Response to Request 2(d):
Entergy submitted to the NRC a letter of intent (ADAMs ML060030453, December 21, 2005) to adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, "2001 edition in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.48 (c). The NRC responded in ain April 13, 2006 letter recognizing a 36 month NFPA 805 transition period that included resolution of the Hemyc issue. Accordingly, the schedule for complete resolution of the Hemyc issue is December 31, 2008. The Hemyc resolution
Attachment to W3F1-2006-0028 Page 4 of 4 plan includes qualification testing, resolution under NFPA 805, and partial replacement/upgrades.
NRC Request :
No later than December 1, 2007, addresseesthat identified Hemyc and/or MT configurations are requested to provide a description of actions taken to resolve the nonconforming conditions describedin 2.c.
Waterford 3 Response to Request 3:
The nonconforming Hemyc conditions will not be addressed prior to the December 1, 2007 date requested. As stated in the response to Request 2(d), Hemyc configurations will be addressed in the implemertation of NFPA 805. To be effective, the implementation of NFPA 805 must be performed in an integrated fashion; therefore, it is not practical to address the Hemyc issue separately in acvance of the project completion date. The complete resolution of this issue is not anticipated prior to December 2008.
Text
ýEnMTe~g Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057 W3F1-2006-0028 June 7, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations Waterford 3 SES Docket No. 50-382 License No. NPF-38
References:
- 1. NRC letter dated April 10, 2006, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
Dear Sir or Madam:
Per Reference 1, the NRC issued Generic Letter (GL) 2006-03 to request facilities to confirm compliance with existing applicable requirements, 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 in 2005 has revealed that both materials failed to provide the protective function intended for compliance with existing regUlations. The requested information is being provided under the requirements of 10 CFR 50.54(f).
The Waterford 3 response to the requested information in GL 2006-03 is attached.
No new commitments are contained in this submittal. If you have any questions or require additional information, please contact Oscar Pipkins at (504) 739-6707.
W3F1-2006-0028 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 7, 2006.
Sincerely,
,Y.ARdel Acting Nuclear Safety Assurance Director JAR/OPP/ssf
Attachment:
Response to Generic Letter 2006-03 for Waterford 3 SES
W3FI-2006-0028 Page 3 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Watelford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. Mel B. Fields Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004
Attachment W3F1 -2006-0028 Response to Generic Letter 2006-03 for Waterford 3 SES
Attachment to W3FI-2006-0028 Page 1 of 4 Requested Information Addressees are requested to determine whether or not Hemyc or MT fire barriermaterialis installed and relied upon for separationand/orsafe shutdown purposes to satisfy applicable regulatoryrequirements. In addition, licensees are asked to describe controls that were used to ensure the adequacy of other fire barriertypes, consistent with the assessment requested in GL 92-08.
Addressees that credit Hemyc or MT for compliance are requested to provide information regardingthe extent of installation,whether the materialcomplies with regulatoryrequirements, and any compe rsatory actionsin 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 corn oliance with regulatoryrequirementsfor the Hemyc and MT applications.
Licensees that cannotjustify theircontinued reliance on Hemyc or MT are requested to provide a descriptionof 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 regulationscommensurate with the safety significance of the nonconforming condition.
The NRC expects all licensees to fully restore compliance with 10CFR50.48and submit the requireddocumentation to the NRC by December 1, 2007.
NRC Request 01(a):
Provide a statement on whether Hemyc or MT fire barriermaterialis used and whether it is relied upon for ,;eparationand/or safe shutdown purposes in accordancewith the licensing basis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
Waterford 3 Response to Request I(a):
Waterford 3 Nuclear Station credited the Hemyc fire barrier system as a one hour fire rated barrier for Appendix R compliance purposes. Waterford 3 does not use the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated MT configuration. The Hemyc system is also used in the containment building as a radiant energy shield.
NRC Request 11(b):
A descriptionof the controls that were used to ensure that other fire barriertypes relied on for separationof redundanttrains located in a single fire area are capable of providing the necessary level of protection. Addressees may reference theirresponses to GL 92-08 to the extent that the responses address this specific issues.
Waterford 3 Rcsponse to Request 1(b):
Waterford 3 also uses the 3M Interam fire barrier system in 1 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated configurations The 3M system is qualified by various fire tests conducted by
Attachment to W3F1 -2006-0028 Page 2 of 4 independent testing laboratories consistent with the guidance provided by Generic Letter 86-10 Supplement 1. This is the only fire barrier raceway system approved by Entergy for use in future installations at Waterford 3 Nuclear Station.
NRC Request 2(a):
Forthose addresseesthat have installed Hemyc or MT fire barriermaterials,discuss the extent of the installation (e.g., linear feet of wrap, areasinstalled, systems protected).
Waterford 3 Response to Request 2(a):
Waterford 3 has approximately 2000 feet of Hemyc conduit wrap installed on conduits ranging in sizes from 3/4 to 5 inches in diameter. In addition there are approximately 1200 feet of Hemyc wrap installed on 24" wide cable trays. Hemyc wrap is installed on 7 electrical/junction boxes and 5 containment electrical penetrations. Conduits, electrical/junction boxes and containment penetration boxes are directly wrapped with Hemyc. Tray wrap is installed using the standard vendor design consisting of Hemyc wrap installed on a frame assembly that provides an air space between the wrap assembly and the raceway. The Hemyc wrap is credited in 19 fire areas/zones.
NRC Request !(b):
Forthose addressees that have installedHemyc or MT fire barriermaterials,discuss whether the Hemyc and/brMT installed in theirplants is conforming with theirlicensing basis in light of recent findings, and if these recent findings do not apply, why not.
Waterford 3 Response to Request 2(b):
The Hemyc system was NRC approved for use at Waterford 3 by NUREG-0787 Supplement 5 Section 9.5.1.4. This document stated:
"By letter dated February 14, 1983, the applicant submitted results of tests conducted by an independent testing laboratory on an insulating blanket and wrap that will be used to protect shutdown-related cable trays and conduits. This material, in conjunction with area-wide smoke detection and fire suppression systems, is in compliance with Section III G.2 of Appendix R to 10 CFR 50. The blanket and wrap were tested in configurations representative of what is to be found in the plant, with unprotected tray supports, using cables represEntative of those used in the plant. As a result of the tests, the material has been demonstrated to protect cable from visible fire damage and to maintain circuit integrity duringi an ASTM E-1 19 1-hour fire exposure. The material is not adversely affected by a water hose stream and is capable of limiting temperature rise on the un-exposed side of trays and conduits to not more than 250F above ambient, which is well below the temperature at which similar IEEE-qualified cable began to fail in tests conducted independently for NRC at Underwriters Laboratories (report to be published).
The Staff concludes that this protection, coupled with the other automatic and manual
Attachment to W3F1 -2006-0028 Page 3 of 4 fire protection available, will provide reasonable assurance that one train of safe shutdown cable remains free of fire damage and, therefore, is acceptable."
However, based on NRC testing, the Hemyc installed at Waterford 3 does not conform to the licensing basis and has been declared and remains inoperable at this time.
NRC Request ,2(c):
For those addresseesthat have installedHemyc or MT fire barriermaterials,discuss the compensatorymeasures that have been implemented to provide protection and maintain the safe shutdown Ftunction of affected areas of the plant in light of the recent findings associated with Hemyc and MT installations,including evaluationsto supportthe addressees'conclusions.
Waterford 3 Response to Request 2(c):
Waterford 3 Technical Requirements Manual (TRM) Section 3.7.11 applies to fire rated assemblies. The TRM action statement states:
'With one or more of the above required fire rated assemblies and/or sealing devices inoperable, wilhin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either establish a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of the fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol, unless the inoperable assembly is inside the containment, then inspect that containment area at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or monitor and record air temperature at least once per hour at each of the operable Containment Fan Cooler air intakes."
All credited Hemyc wrap, including Containment wrap used as a radiant energy shield, has been conservatively declared inoperable and the applicable TRM actions initiated pending resolution.
NRC Request 2(d):
For those addresseesthat have installed Hemyc or MT fire barriermaterials,provide a description of, and implementation schedules for, corrective actions, including a description of any licensing actions or exemption requestsneeded to support changes to the plant licensing basis.
Waterford 3 Response to Request 2(d):
Entergy submitted to the NRC a letter of intent (ADAMs ML060030453, December 21, 2005) to adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, "2001 edition in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.48 (c). The NRC responded in ain April 13, 2006 letter recognizing a 36 month NFPA 805 transition period that included resolution of the Hemyc issue. Accordingly, the schedule for complete resolution of the Hemyc issue is December 31, 2008. The Hemyc resolution
Attachment to W3F1-2006-0028 Page 4 of 4 plan includes qualification testing, resolution under NFPA 805, and partial replacement/upgrades.
NRC Request :
No later than December 1, 2007, addresseesthat identified Hemyc and/or MT configurations are requested to provide a description of actions taken to resolve the nonconforming conditions describedin 2.c.
Waterford 3 Response to Request 3:
The nonconforming Hemyc conditions will not be addressed prior to the December 1, 2007 date requested. As stated in the response to Request 2(d), Hemyc configurations will be addressed in the implemertation of NFPA 805. To be effective, the implementation of NFPA 805 must be performed in an integrated fashion; therefore, it is not practical to address the Hemyc issue separately in acvance of the project completion date. The complete resolution of this issue is not anticipated prior to December 2008.