ML071090024

Request for Additional Information Generic Letter 2006-03 Potentially Nonconforming Hemyc and MT Fire Barrier Configuration

ML071090024
Person / Time
Site:	Hatch
Issue date:	05/08/2007
From:	Martin R NRC/NRR/ADRO/DORL/LPLII-1
To:	Madison D Southern Nuclear Operating Co
Martin R, NRR/DORL, 415-1493
References
GL-06-003, TAC MD1586, TAC MD1587
Download: ML071090024 (5)

Text

May 8, 2007 Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP) - REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING GENERIC LETTER 2006-03, POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS (TAC NOS. MD1586 AND MD1587)

Dear Mr. Madison:

The Nuclear Regulatory Commission (NRC) staff is reviewing your responses, dated June 9, and November 28, 2006, to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations, as they may apply to the HNP and find that additional information is needed as stated in the enclosure.

If you have any questions regarding this response, please contact me at 301-415-1493.

Sincerely,

/RA/

Robert E. Martin, Sr. Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosure:

RAI cc w/encl: See next page

May 8, 2007 Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP) - REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2006-03, POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS (TAC NOS. MD1586, MD1587)

Dear Mr. Madison:

The Nuclear Regulatory Commission (NRC) staff is reviewing your responses, dated June 9, and November 28, 2006, to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations, as they may apply to the HNP and find that additional information is needed as stated in the enclosure.

If you have any questions regarding this response, please contact me at 301-415-1493.

Sincerely,

/RA/

Robert E. Martin, Sr. Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION:

Public RidsAcrsAcnwMailCenter LPL2-1 R/F RidsNrrDraAfpb (DFrumpkin)

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ADAMS No: ML071090024 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA AFPB/BC NRR/LPL2-1/BC NAME RMartin:nc MOBrien SWeerakkody EMarinos DATE 04/23/07 04/23/07 04/19/07 05/8/07 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION CONCERNING FIRE BARRIER CONFIGURATIONS FOR EDWIN I. HATCH PLANT, UNIT NOS. 1 AND 2 Please provide clarifying information regarding whether the following information, based on the letter from Southern Nuclear Operating Company, Inc., dated November 28, 2006, for the Farley Nuclear Plant, also applies to the Edwin I. Hatch Plant, Unit Nos. 1 and 2 (HNP).

Item 1 - How was the Promat tested? Is the Promat testing, as described in the November 28, 2006, letter also applicable to HNP? That letter stated:

The Promat was tested and qualified to American Society of Testing Materials (ASTM) E119-88 by Performance Contracting Inc. under Omega Point Project No. 8806-90254 (Promat Report SR90-005). This testing included ASTM E119 time-temperature, full scale fire testing for the wall assembly and a small scale fire testing of the ceiling assembly. The test details are documented in Promat Report SR90-005.

If this information is not applicable to HNP, please provide the information in the Questions below.

Item 2 - What acceptance criteria were used? Were the same acceptance criteria as described in the November 28, 2006, letter, used? That letter stated:

The test acceptance criteria were that of ASTM El 19-88 Section 16 "Conditions of Acceptance," which meets the acceptance criteria of GL 86-10, Supplement 1.

The 325 degrees Fahrenheit temperature criterion was used, which assumes a maximum temperature rise of 250 degrees Fahrenheit above an ambient temperature of 75 degrees Fahrenheit.

If this information is not applicable to HNP, please provide the information in the Questions below.

Item 3 - How were installed configurations that were different from tested configurations evaluated? Were the field installations deviations evaluated similarly as described in the November 28, 2006, letter? That letter stated:

An analysis and acceptance for plant specific deviations from the tested configurations is included in Performance Contracting Inc. Fire Protection Technical Evaluation (FPTE) FPTE 2006-001, Revision 0. This evaluation received a documented review and approval by a qualified fire protection engineer within Southern Nuclear and found to be consistent with the GL 86-10, Section 3.2.2 criteria.

If this information is not applicable to HNP, please provide the information in the Questions below.

QUESTIONS, if November 28, 2006, responses do not apply to HNP Enclosure

1) For HNP, the Promat H board is described as a fire barrier that separates redundant trains within the same fire area (for example, cable tray enclosures). The response states that Promat H board is tested in accordance with Underwriters Laboratory Standard 263, ASTM Standard E119, and National Fire Protection Association Standard 251. Use of these tests and standards identifies fire testing for building members and assemblies, but does not specifically address 1- and 3-hour fire barrier systems protecting electrical raceways.

If the Promat H boards were used in accordance with a listed fire rated assembly (such as a UL listed assembly), please provide that information.

The NRC staff's current guidance for raceway protection is contained in Generic Letter 86-10, Supplement 1, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations. The NRC staff is interested in whether the Promat H fire barriers (as installed in the plant) were tested and evaluated (for deviations from the testing) in accordance with the GL 86-10, Supplement 1, guidance. If not, the NRC staff is interested in the following:

a) Is the support protection and penetrating item protection for the Promat H barriers in the plant representative of the protection provided during the testing?

b) Does the testing encompass or bound the installed configurations?

c) Is the plant cable loading (the thermal mass) of the installed configurations bounded by the tested configurations?

Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:

Laurence Bergen Mr. Jeffrey T. Gasser Oglethorpe Power Corporation Executive Vice President 2100 E. Exchange Place Southern Nuclear Operating Company, Inc.

P.O. Box 1349 P.O. Box 1295 Tucker, GA 30085-1349 Birmingham, AL 35201-1295 Mr. R. D. Baker General Manager Manager - Licensing Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc. Southern Nuclear Operating Company, Inc.

P.O. Box 1295 U.S. Highway 1 North Birmingham, AL 35201-1295 P.O. Box 2010 Baxley, GA 31515 Resident Inspector Plant Hatch Mr. K. Rosanski 11030 Hatch Parkway N. Resident Manager Baxley, GA 31531 Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant Harold Reheis, Director P.O. Box 2010 Department of Natural Resources Baxley, GA 31515 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Arthur H. Domby, Esq.

Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513