NLS2013063, Response to Supplemental Information Request Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805
| ML13169A059 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/13/2013 |
| From: | Higginbotham K Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2013063 | |
| Download: ML13169A059 (7) | |
Text
Nebraska Public Power District Always there when you need us 50.90 NLS2013063 June 13, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Supplemental Information Request Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
- 1. Letter from Kenneth Higginbotham, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated February 12, 2013, "90-Day Response to Request For Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805" (NLS2013016)
- 2. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.
Nuclear Regulatory Commission, dated April 24, 2012, "License Amendment Request to Revise the Fire Protection Licensing Basis to NFPA 805 Per 10 CFR 50.48(c)" (NLS2012006)
Dear Sir or Madam:
The purpose of this letter is for the Nebraska Public Power District to provide supplementary information to the Nuclear Regulatory Commission (NRC) regarding the Fire Modeling-0 1a Request for Additional Information response provided in Reference 1, relating to the Cooper Nuclear Station (CNS) License Amendment Request to adopt National Fire Protection Association (NFPA) Standard 805 as the CNS Fire Protection licensing basis per 10 CFR 50.48(c) (Reference 2). This supplement is provided at NRC request pursuant to a conference call conducted on May 14, 2013. The supplement is attached. There are no commitments made in this submittal.
Should you have any questions concerning this matter, please contact Todd Stevens, CNS NFPA 805 Transition Project Manager, at (402) 825-5159.
COOPER NUCLEAR STATION P.O. Box 98 / Braownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com 1
NLS2013063 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on .. (3(D 2 (Date)I Sincerely Kenneth Higgi otham General Manager of Plant Operations KH/wv
Attachment:
Response to Supplemental Information Request Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 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/o Attachment CNS Records w/ Attachment
NLS2013063 Attachment Page 1 of 5 Attachment Response to Supplemental Information Request Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 The Nuclear Regulatory Commission supplemental request regarding the National Fire Protection Association (NFPA) Standard 805 Transition License Amendment Request is shown in italics. The Nebraska Public Power District (NPPD) response to the supplemental request is shown in block font.
Supplemental Request - RAI FM-Ola In a conference call conducted on May 14, 2013 with the Cooper Nuclear Station NFPA 805 ProjectStaff the licensee response to Request for Additional Information (RAI) Fire Modeling (FM)-Ola was discussed. It is requested that the licensee provide a supplemental response with additionaldetail regardingthe table line items provided in the responsefor Fire Compartment CB-A/Fire Zone 7A (PolyurethaneFoam Insulation) and Fire Compartment CB-D/Fire Zone JOB (Insulationand HVAC Insulation). The additionaldetail specifically requested is the description/type of the insulation material,any ignition sources that could impact the insulation (typically the nearest), the distribution/locationof the insulation in the fire zone andproximity to the ignition sources, and details of the covering material.
NPPD Response Fire Compartment CB-A/Fire Zone 7A (Polyurethane Foam Insulation and Fiberglass Insulation)
Description of the insulation material:
The 264 pounds of polyurethane foam insulation originally believed to be located on Dryers A and B is actually located at the three Station Air Compressors, SA-CPSR-A, -B, and -C.
The foam insulation is a lightweight closed air cell material. The foam insulation is part of each station air compressor unit and is located within the metal compressor housing. The station air compressors measure 55 inches wide by 100 inches long and are 66 inches tall.
Each compressor is provided with 88 pounds of insulation, comprised of a two (2) inch thick layer of the polyurethane insulation concealed within the metal housing of the compressor units.
The insulation originally identified at Dryers A and B is actually of high temperature noncombustible fiberglass insulation (50 pounds and 64 linear feet). The insulation conforms to Federal Specification HH-1-558a, Form D, Type III, Class 12, and has a factory applied glass yam reinforced fire retardant jacket. The fiberglass insulation is wrapped on the dry air tanks and piping associated with Dryers A and B. Each dry air tank measures
NLS2013063 Attachment Page 2 of 5 three (3) feet tall by two (2) feet wide. There are a total of four tanks, two provided for each dryer.
" Details of the covering material:
The polyurethane foam insulation is contained within the metal housing of the Service Air Compressors. The foam insulation is completely enclosed within the metal housing which is well sealed, with the exception of limited pipe penetrations on one side of the unit. The metal housing precludes ignition of the material and fire spread.
In addition to the fire resistive properties of the fiberglass insulation on the dryers, a factory applied glass yarn reinforced fire retardant jacket is provided over the noncombustible insulation which further precludes the possibility of ignition of the material and fire spread.
" Distribution/location of the insulation in the fire zone:
Service Air Compressors SA-CPSR-A, -B, and -C, are located in the western portion of Fire Zone 7A between columns H.7 and J.8. Compressor SA-CPSR-A is located west of column J.3-15.4, Compressor SA-CPSR-B is located west of J.3-14.6, and Compressor SA-CPSR-C is located northeast of column J.3-15.4. The station air compressors measure 55 inches wide by 100 inches long and are 66 inches tall. Each compressor is provided with 88 pounds of insulation, comprised of a two (2) inch thick layer of the polyurethane insulation concealed within the metal housing of the compressor units.
Dryers A and B are located at the south wall of the fire zone along column line 14. Dryer A is located four (4) feet from column H.7-14 and Dryer B is eight (8) feet west of Dryer A [ten (10) feet from column J.8-14]. The noncombustible fiberglass insulation is provided on the four dry air tanks and piping associated with the dryers (each dryer unit includes two dry air tanks). Each dry air tank is located four (4) feet above floor level and measures three (3) feet tall by two (2) feet wide.
- Ignition sources capable of impacting the insulation:
The closest fixed ignition sources to both types of insulation are the Service Air Compressors. The polyurethane foam insulation is part of the compressor unit, located directly on the ignition source. Compressor SA-CPSR-B is located approximately three (3) feet from the fiberglass wrapped dry air tanks and piping on Dryer A and Dryer B.
The Service Air Compressors could result in three possible fires: an electrical fire (211 kW),
a small oil fire (772 kW), or a large oil fire (85 MW). The large oil fire results in whole room damage for all three of the compressors. These conservative heat release rates would bound the additional energy provided by the polyurethane foam. The metal housing would limit involvement of the foam insulation and contribution to the overall heat release rate is considered negligible compared to the modeled fires. Additionally, a transient fire would not
NLS2013063 Attachment Page 3 of 5 spread to involve the polyurethane foam insulation due to the metal housing of the compressor units, which would prevent ignition of the material.
The fiberglass insulation at Dryers A and B could be impacted by Service Air Compressor SA-CPSR-B, as well as transient combustibles. Although the dryers are within the zone of influence of both fixed and transient ignition sources, the fiberglass insulation is noncombustible and provided with a glass yam reinforced fire retardant jacket and propagation to the insulation is not postulated.
Below is the updated Summary of Review table from the response to RAI FM-01a for Fire Zone 7A correctly identifying the insulation1 :
The tiberglass insulation is located on the air dryers in the fire zone. The insulation is high temperature noncombustible, fiberglass insulation. The insulation is covered with a factory applied glass yam reinforced fire retardant jacket which further precludes the Misc.
possibility of ignition of the material and fire CB-A 7A Fiberglass 50 lbs.
spread. There are no cable trays located in Fire Insulation Zone 7A. Although the dryers are within the zone of influence of both fixed and transient ignition sources, the fiberglass insulation is noncombustible and provided with a glass yarn reinforced fire retardant jacket and propagation to the insulation is not postulated.
The fiberglass insulation is located on the piping of the air dryers in the fire zone. The insulation is high temperature noncombustible, fiberglass insulation. The insulation is covered with a factory applied glass yarn reinforced fire retardant jacket which further precludes the Misc. possibility of ignition of the material and fire CB-A 7A 64 ft.
Fiberglass spread. There are no cable trays located in Fire Zone 7A. Although the piping is within the zone of influence of both fixed and transient ignition sources, the fiberglass insulation is noncombustible and provided with a glass yam reinforced fire retardant jacket and propagation to the insulation is not postulated.
1 The Rubatex Pipe Insulation line item for CB-A/7A is included for completeness, and is unchanged from the original RAI response.
NLS2013063 Attachment Page 4 of 5 The polyurethane loam insulation is located at the three Station Air Compressors, SA-CPSR-A,
-B, and -C. The foam insulation is a lightweight closed air cell material. The foam insulation is part of each station air compressor unit and is located within the metal compressor housing.
Polyurethane The metal housing would limit involvement of CB-A 7A Foam 264 lbs.
the foam insulation and contribution to the Insulation overall heat release rate is considered negligible compared to the modeled fires. Additionally, a transient fire would not spread to involve the polyurethane foam insulation due to the metal housing of the compressor units which would prevent ignition of the material.
The Rubatex insulation is located on long runs of 6 inch piping in the fire zone. As the quantity of insulation is only approximately 44 lbs, there is a limited amount of insulation on a specific length CB-A 7A Rubatex Pipe 44.3 lbs. of piping compared to the floor area of the fire Insulation zone. There are no cable trays routed in the fire zone. Fire propagation to the pipe insulation would not cause a significant increase in the heat release rate of the fire and therefore, no additional FPRA target failures would result.
Fire Compartment CB-D/Fire Zone 10B (Insulation and HVAC Insulation)
Description of the insulation material:
There is a total of 777.6 pounds of fiberglass HVAC insulation provided on duct runs throughout Fire Zone 10B, the Main Control Room (MCR). Of this, 273.6 pounds of the insulation is flexible type duct fiberglass insulation which is noncombustible and provided with a flame resistant vapor barrier covering. The remaining 504 pounds of insulation is rigid type fiberglass insulation which is also noncombustible and provided with a fire retardant vapor barrier facing. All joint and voids for the rigid type insulation are filled with mineral wool cement and fire retardant material and the insulation is covered with an open weave glass cloth and flooded with a final coat of insulating acoustic sealer. The fiberglass ductwork insulation conforms to the NFPA 90A standard for fire hazards requirements and the ASHRAE (American Society of Heating, Refrigeration, and Air-Conditioning Engineers) guide and data book.
NLS2013063 Attachment Page 5 of 5
- Details of the covering material:
In addition to the fire resistive properties of the fiberglass insulation, the reinforced metallic foil faced and flame resistant vapor barrier (flexible type) and the fire retardant vapor barrier facing (rigid type) are provided over the noncombustible insulation which further precludes the possibility of ignition of the material and fire spread.
- Distribution/location of the insulation in the fire zone:
The noncombustible HVAC insulation is adhered to the surface of the duct runs for the MCR HVAC system and the quantity is dispersed throughout the fire zone. There are six duct runs routed east to west within the MCR. Four (4) of the ducts (located between columns 14.6 and 17) measure 26" x 12" at the largest cross section and 24" x 6" at the smallest cross section, with lengths of approximately 50 feet. The fifth duct (routed along column 14.6) measures 30" x 24" at the largest cross section and 24" x 14" at the smallest cross section, with a length of approximately 45 feet. The sixth east to west duct run (located south of column 14.6) measures 20" x 14" at the largest cross section and 14" x 8" at the smallest cross section, with a length of approximately 54 feet.
There are two duct runs routed north to south within the MCR. Both ducts are routed west of column J.8 near the west wall of the MCR. The eastern most duct run measures 50" x 20" at the largest cross section and 26" x 12" at the smallest cross section, with a length of approximately 59 feet. The western most duct measures 30" x 40" at the largest cross section and 30" x 24" at the smallest cross section, with a length of approximately 59 feet.
In addition to these eight duct runs, there are partial runs located along the west and south walls of the MCR of varying lengths and dimensions.
" Ignition sources capable of impacting the insulation:
Ignition sources in the MCR include the main control boards, electrical panels, and transient combustibles. There are two locations where the duct runs are routed four feet above electrical panels (panels 9-18 and 9-19), however, the duct insulation is noncombustible and provided with flame resistant and fire retardant vapor barrier coverings and propagation to the insulation is not postulated. Furthermore, the MCR is continuously manned by trained operators and any fire scenario would be promptly addressed.