ML17056C336
| ML17056C336 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/13/1993 |
| From: | Terry C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17056C337 | List: |
| References | |
| GL-92-08, GL-92-8, NMP1L-0751, NMP1L-751, NUDOCS 9304160004 | |
| Download: ML17056C336 (20) | |
Text
'ACCEIERA 9 DOCUMENT DIST IBUTIONSYSTEM REGULA Y INFORMATION DISTRIBUTI SYSTEM (RIDS)
ACCESSION NBR:9304160004 DOC.DATE: 93/04/13 NOTARIZED: YES DOCKET ¹ FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 AUTH.NAME AUTHOR AFFILIATION TERRY,C.D.
Niagara Mohawk Power Corp.
RECIP.NAME RECIPIENT AFFILIATION
'ocument Control Branch (Document Control Desk)
SUBJECT:
Forwards response to GL 92-08, "Thermo-Lag 330-1 Fire Barriers."
DISTRIBUTION CODE:
A029D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Generic Letter 92-008 Thermal-Log 330 Fire Barrier NOTES:
D RECIPIENT ID CODE/NAME PD1-1 LA BRINKMANgD.
INTERNAL: NRR/DET/EELB NRR/PD3-1 RGN1
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTETH CONTACT THE DOCUMENT CONTROL DESK, ROOM P1-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
D ps TOTAL NUMBER OF COPIES REQUIRED:
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U SiNRRIANK NIAGARAMOHAWKPOWER CORPORATION/301 PLAINFIELDROAD, SYRACUSE, N.Y. 13212/TELEPHONE (315) 474-1511 April 13, 1993 NMP1L 0751 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re:
Nine Mile Point Unit 1 Docket No. 50-220 DPR-63 Nine Mile Point Unit 2 Docket No. 50-410
~NP -6 Gentlemen:
SUBJECT:
RESPONSE TO GENERIC LETTER 92-08, "THERMO-LAG330-1 FIRE BARRIERS",
Generic Letter 92-08 requested that Niagara Mohawk Power Corporation submit additional information to verify that installed Thermo-Lag 330-1 fire barrier systems comply with the Staff's requirements.
Attachments 1 and 2 to this letter provide the information requested for Nine Mile Point Units 1 and 2, respectively.
Very truly yours, C. D. Terry Vice President Nuclear Engineering MC/pr 003751GG Attachments xc:
Regional Administrator, Region I Mr. W. L. Schmidt, Senior Resident Inspector Mr. R. A. Capra, Director, Project Directorate I-l, NRR Mr. D. S. Brinkman, Senior Project Manager, NRR Mr. J. E. Menning, Project Manager, NRR Records Management j.RA.Ap~
9304i'60004 930413 PDR
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UNITED STATES NUCLEARREGULATORY COMMISSION In the Matter of Niagara Mohawk Power Corporation Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 C. D. Terry, being duly sworn, states that he is Vice President, Nuclear Engineering of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the document attached hereto; and that the document is true and correct to the best of his knowledge, information, and belief.
C. D. Terry Vice President Nuclear Engineering Subscribed and Sworn before me, a Notary Public in and for the State of New York and the County of
, this Q~W dayof, 1993.
Notary Public in and for County, New York My Commission Expires:
Jo ANN BOUTHILLIER Notary public ln tyre Ctato ol rtew York Quallflad In Ononddua County tlo. 4713804 My Cornrntsslon Expires Itrercr~~ ~
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ATTACHMENT1 NIAGARAMOHAWKPOWER CORPORATION NINEMILEPOINT UNIT 1 DOCKET NO. 50-220 DPR-63 RESPONSE TO REQUEST FOR INFORMATION REGARDING THERMO-LAGFIRE BARRIERS (GENERIC LETTER 92-08)
ITEM 1 State whether Thermo-Lag 330-1 barriers are relied upon (a) to meet 10CFR50.48, to achieve physical independence of electrical systems, (b) to meet a condition of a plant's operating license, or (c) to satisfy a licensing commitment. Ifapplicable, state that Thermo-Lag 330-1 is not used at the facility. This generic letter applies to all 1-hour and 3-hour Thermo-Lag 330-1 materials and barrier systems assembled by any assembly method such as by assembling preformed panels and conduit shapes, as well as spray, trowel and brush-on applications.
RINSE AllThermo-Lag 330-1 fire barrier material at Nine Mile Point Unit 1 (NMP1) is installed to meet 10CFR50.48 for the protection of safe shutdown capability. AllThermo-Lag material at NMP1 is installed to provide a 3-hour fire barrier.
Specific installations are identified in Niagara Mohawk Power Corporation (NMPC) responses to NRC Bulletin 92-01 and Bulletin 92-01 Supplement 1 dated July 24, 1992 (NMPlL0685) and September 29, 1992 (NMP1L 0700) respectively.
ITEM2 IfThermo-Lag 330-1 barriers are used at the facility, Item 2(a) State whether or not the licensee has qualified the Thermo-Lag 330-1 fire barriers by conducting fire endurance tests in accordance with the NRC's requirements and guidance or licensing commitments.
R~S The Thermo-Lag 330-1 fire barriers installed at NMP1 were not qualified by conducting individual specific fire endurance tests for the exact installed configurations.
The governing criteria for the installations were Thermal Science Incorporated (TSI) Technical note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating 003751GG
'Plant Applications), Revision V, November 1985 and TSI Form 1082(500).
The barriers were qualified to requirements and industry practice applicable at the time of installation.
Item 2(b) State (1) whether or not the fire barrier configurations installed in the plant represent the materials, workmanship, methods of assembly, dimensions, and configurations of the qualification test assembly configurations; and (2) whether or not the licensee has evaluated any deviations from the tested configurations.
R N E Thermo-Lag 330-1 fire barrier installations at NMP1 represent the materials, workmanship, methods "of assembly, dimensions and configurations of the qualification test assembly as presented in TSI Technical note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedure Manual, Power Generating Plant Applications), Revision V, November 1985 and TSI Form 1082(500)
~ NMPC has not evaluated any deviations from tested configurations, but has documented acceptance by Pro-Tech Applications Services, Inc. (an approved Thermal Science Inc. Installer) or Thermal Science, Inc. that each installation meets the requirements for a 3-hour fire barrier.
'tem 2(c) State (1) whether or not the as-built Thermo-Lag 330-1 barrier configurations are consistent with the barrier configurations used during the ampacity derating tests relied upon by the licensee for the ampacity derating factors used for all raceways protected by Thermo-Lag 330-1 (for fire protection of safe shutdown capability or to achieve physical independence of electrical systems) and (2) whether or not the ampacity derating test results relied upon by the licensee are correct and applicable to the plant design.
R~NR (1)
The as-built Thermo-Lag 330-1 barrier configurations at NMP1 are consistent with the barrier configurations provided by TSI Technical Note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating Plant Applications), Revision V, November 1985 and TSI Form 1082(500).
(2)
Cables 171-71 and 171-151 involve power cables to which ampacity considerations apply.
The cables draw 11.9 and 16.0 full load amperes, respectively, under cyclic duty.
Both cables are 110 AWG, quadruplex, which is rated to 38 amperes when routed in conduit.
Thus, power cable 171-71 is derated 68.7% and power cable 171-151 is derated 57.9%, which far exceeds the ampacity derating of 10.9%
recommended by TSI in TSI Form 1082(500).
These deratings also exceed the 38.9% for 3-hour barrier installations as determined by Underwriters Laboratories for long stabilization periods.
003751GG
il s
Based on the above, it is concluded that the actual derating used in this application remains conservative and was based on engineering judgment that was applied at the time of the initial installation.
I~TEM With respect to any answer to items 2(a), 2(b), or 2(c) above in the negative, (a) describe all corrective actions needed and include a schedule by which such actions shall be completed and (b) describe all compensatory measures taken in accordance with the technical specifications or administrative controls.
When corrective actions have been completed, confirm in writing their completion.
(a)
Currently, all required fire barriers utilizing Thermo-Lag material have been declared inoperable in response to NRC Bulletin 92-01, Supplement
- 1. This was documented in NMPC's September 29, 1992 submittal to the NRC. NMPC intends to utilize the results of the NUMARC test program in returning these barriers to operability.
Specific schedules willbe provided to the NRC by NUMARC for conducting tests and issuing of test results.
Following the review of these test results, NMPC will develop appropriate action plans for returning the required barriers to an operable condition.
(b)
Compensatory measures taken for Thermo-Lag barriers were described in NMPC's response to NRC Bulletin 92-01 and Supplement 1.
These compensatory measures willremain in effect until fire barrier operability is restored.
ITEM 4 List all Thermo-Lag 330-1 barriers for which answers to item 2 cannot be provided in the response due within 120 days from the date of this generic letter, and include a schedule by which such answers shall be provided.
R~NR No Thermo-Lag barriers fall into this category.
003751GG
ATTACHMENT2 NIAGARAMOHAWKPOWER CORPORATION NINEMILEPOINT UNIT 2 DOCKET NO. 50-410 NFP-69 RESPONSE TO REQUEST FOR INFORMATION REGARDING THERMO-LAGFIRE BARRIERS (GENERIC LETTER 92-08)
ITEM 1 State whether Thermo-Lag 330-1 barriers are relied upon (a) to meet 10CFR50.48, to achieve physical independence of electrical systems, (b) to meet a condition of a plant's operating license, or (c) to satisfy a licensing commitment. Ifapplicable, state that Thermo-Lag 330-1 is not used at the facility. This generic letter applies to all 1-hour and 3-hour Thermo-Lag 330-1 materials and barrier systems assembled by any assembly method such as by assembling preformed panels and conduit shapes, as well as spray, trowel and brush-on applications.
R~NE AllThermo-Lag 330-1 fire barrier material at Nine Mile Point Unit 2 (NMP2) is installed to meet 10CFR50.48 for the protection of safe shutdown capability. AllThermo-Lag material at NMP2 is installed to provide a 3-hour fire barrier.
Specific installations are identified in Niagara Mohawk Power Corporation (NMPC) responses to NRC Bulletin 92-01 and Bulletin 92-01, Supplement 1 dated July 24, 1992 (NMP1L 0685) and September 29, 1992 (NMP1L 0700) respectively.
With respect to NMPC's response dated September 29, 1992, a Thermo-Lag coated cover on the Control Building dumbwaiter was identified as an installed system.
However, this installation is no longer a required fire barrier as a result of Modification PN2Y87MX208 and is not being treated as such at this time.
ITEM 2 IfThermo-Lag 330-1 barriers are used at the facility, Item 2(a) State whether or not the licensee has qualified the Thermo-Lag 330-1 fire barriers by conducting fire endurance tests in accordance with the NRC's requirements and guidance or licensing commitments.
003751GG
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RESPONSE
The Thermo-Lag 330-1 fire barriers installed at NMP2 were not qualified by conducting individual specific fire endurance tests for the exact installed configurations.
The governing criteria for the installations were Thermal Science Incorporated (TSI) Technical note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating Plant Applications), Revision V, November 1985 and TSI Form 1082(500).
The barriers were qualified to requirements and industry practice applicable at the time of installation and were addressed by the NRC in the safe shutdown inspection for NMP2 (50-410/85-34) and subsequent follow-up communication dated May 7, 1986 (NMP2L 0706).
Item 2(b) State (1) whether or not the fire barrier configurations installed in the plant represent the materials, workmanship, methods of assembly, dimensions, and configurations of the qualification test assembly configurations; and (2) whether or not the licensee has evaluated any deviations from the tested configurations.
R~BS NSE Thermo-Lag 330-1 fire barrier installations at NMP2 represent the materials, workmanship, methods of assembly, dimensions, configuration, etc. that were consistent with requirements and industry practices applicable at the time of installation and in accordance with the guidance provided by TSI Technical Note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating Plant Applications), Revision V, November 1985 and TSI Form 1082(500).
No testing or evaluations of deviations from tests of the exact installed configuration of the Thermo-Lag 330-1 fire barriers installed at NMP2 has occurred.
The Thermo-Lag 330-1 fire barrier configurations installed in the plant were designed and constructed by the Architect Engineer for NMP2, Stone and Webster Engineering Corporation (SWEC) of Cherry Hill, NJ, under a Quality Assurance Program consistent with NRC requirements.
NMPC reviewed and accepted the work of SWEC.
The fire barrier installations do not deviate from TSI's guidance.
Item 2(c) State (1) whether or not the as-built Thermo-Lag 330-1 barrier configurations are consistent with the barrier configurations used during the ampacity derating tests relied upon by the licensee for the ampacity derating factors used for all raceways protected by Thermo-Lag 330-1 (for fire protection of safe shutdown capability or to achieve physical independence of electrical systems) and (2) whether or not the ampacity derating test results relied upon by the licensee are correct and applicable to the plant design.
003751GG
'R NE (1)
The as-built Thermo-Lag 330-1 barrier configurations at NMP2 are consistent with the barrier configurations provided by TSI Technical Note 20684 (Thermo-Lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating Plant Applications), Revision V, November 1985 and TSI Form 1082(500).
The Thermo-Lag 330-1 Fire Barrier Systems were designed by SWEC of Cherry Hill, NJ, and the ampacity derating factors used are in accordance with the guidance provided by the TSI Form 1082(500).
TSI Form 1082(500) suggested a 10.9%
derating factor for a conduit applied with a 3-hour rated Thermo-Lag 330-1 Fire Barrier material.
(2)
Power Cable 2SWPAGK017 is the only cable routed through 17 feet of Thermo-Lag protected 1-1/2" diameter conduit 2CK201GL.
Cable 2SWPAGK017 provides 600v power to motor operated valve (MOV) 2SWP*MOV50A. Cable 2SWPAGK017 is a 4 conductor ¹8 AWG cable, manufactured by Okonite with CSPE jacket and EP insulation, qualified to IEEE 383 and LOCA and is rated for 48 amperes when routed in conduit.
The fullload required for operation of 2SWP"'MOVSOA is 15.6 amperes, and the MOV is considered as an intermittent load.
Thus, the power cable to MOV 2SWP*MOV50A is derated 67,5%, which far exceeds the ampacity derating of 10.9% recommended by TSI in TSI Form 1082(500).
This derating also exceeds the 38.9% for 3-hour barrier installations as determined by Underwriters Laboratories for long stabilization periods.
Based on the above, it is concluded that the actual derating used in this application remains conservative and was based on engineering judgment that was applied at the time of'the initial installation.
ITEM 3 With respect to any answer to items 2(a), 2(b), or 2(c) above in the negative, (a) describe all corrective actions needed and include a schedule by which such actions shall be completed and (b) describe all compensatory measures taken in accordance with the technical specifications or administrative controls.
When corrective actions have been completed, confirm in writing their completion.
003751GG
'RESPONSE (a)
Currently, all required fire barriers utilizing Thermo-Lag material have been declared inoperable in response to NRC Bulletin 92-01, Supplement 1.
This was documented in NMPC's September 29, 1992 submittal to the NRC. NMPC intends to utilize the results of the NUMARC test program in returning these barriers to operability.
Specific schedules willbe provided to the NRC by NUMARC for conducting tests and issuing of test results.
Following the review of these test results, NMPC will develop appropriate action plans for returning the required barriers to an operable condition.
(b)
Compensatory measures taken for Thermo-Lag barriers were described in NMPC's response to NRC Bulletin 92-01 and Supplement 1.
These compensatory measures willremain in effect until fire barrier operability is restored, except for the Thermo-Lag coated cover on the Control Building dumbwaiter.
This Thermo-Lag coated cover was identified in NMPC's response dated September 29, 1992 (NMP1L 0700).
However, this installation is no longer a required fire barrier as a result of Modification PN2Y87MX208 and is not being treated as such at this time.
ITEM4 List all Thermo-Lag 330-1 barriers for which answers to item 2 cannot be provided in the response due within 120 days from the date of this generic letter, and include a schedule by which such answers shall be provided.
RESPONSE
No Thermo-Lag barriers fall into this category.
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