ML17310A502

Forwards Request for Addl Info Re Licensee 930416 Response to GL 92-08, Thermo-Lag 330-1 Fire Barriers

ML17310A502
Person / Time
Site:	Palo Verde
Issue date:	07/21/1993
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
GL-92-08, GL-92-8, TAC-M85583, TAC-M85584, TAC-M85585, NUDOCS 9308110148
Download: ML17310A502 (11)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 21, 1gg3 Docket Nos. 50-528, 50-.529, and 50-530 Hr. William F.

Conway Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999

Phoenix, Arizona 85072-3999

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION RESPONSE TO GENERIC LETTER 92-08, "THERMO-LAG 330-1 FIRE BARRIERS" (TAC NOS.

M85583, M85584, AND M85585)

By letter dated April 16, 1993, you provided a response to Generic Letter (GL) 92-08 for Palo Verde, Units 1, 2, and 3.

Your response states that the Thermo-Lag fire barriers installed at Palo Verde were qualified by Industrial Testing Laboratories, Inc. for Thermal Science Incorporated (TSI) and were consistent with NRC requirements in existence at the time of installation.

However, the tests performed by Industrial Testing Laboratories, Inc. for TSI are now considered indeterminate, due to indeterminate fire test results and acceptance criteria.

Your response also states that the Thermo-Lag fire barrier systems installed at Palo Verde do not represent the methods, dimensions, and configurations of the qualification test assembly configurations.

In addition, in your response, you stated that you have evaluated deviations from the tested configurations.

Although Thermo-Lag barriers were evaluated and may have been considered qualified, the results of recent tests and inspections indicate that further actions are now necessary to address fire endurance and ampacity derating parameters of Thermo-Lag barriers.

Your response states that appropriate actions to resolve these concerns are being developed through an industry program coordinated by NUHARC and that you would apply the results of the industry program, when completed, to the Thermo-Lag 330-1 installations at Palo Verde. If additional testing or evaluation is required, APS will develop a schedule for testing, evaluation and resolution of the testing.

Compensatory measures for inoperable barriers are in place and will remain in place until the fire barriers can be declared operable.

Your response to GL 92-08, however, did not provide a schedule by which corrective actions would be completed.

In your response to GL 92-08 you indicated that the actions necessary to restore (or confirm) the operability of these barriers will be based on the results of the NUMARC program.

The staff expects that licensees referencing the NUMARC program will review the results and, within 30 days after the completion of the program, inform the NRC of the actions necessary and the schedule for restoring the operability of these fire barriers including any 9308ll0148 93072l~t PDR ADOCK>>05000528' PDR

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'r. William F.

Conway July-21, 1993 plant-specific or unique fire barrier configurations that, are not bounded by the NUHARC program.

In accordance with the reporting requirements of GL 92-08, you are also to confirm, in writing, completion of the corrective actions.

The information requested by this letter is within the scope of the overall burden estimate in Generic Letter 92-08 which wa's an average of 300 person-hours for each addressee's response.

This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1994.

Also, in reviewing your response to the Generic Letter,'e find that the additional information identified in the enclosure i's needed to continue our review.

We request that you provide a response to the request for additional information within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Management and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

Sincerely, Qriginal signed by Charles H. Trammell, Senior Project Hanager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/enclosure:

See next page DISTRIBUTION:

Docket File PDV Reading File EAdensam CTrammell

WDean, 13D18 CMcCracken, SDl MPSiemien, 15B18

PHadden, SDl NRC

& Local PDRs JRoe LTran DFoster-Curseen ACRS (10),

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KPerkins, RV See revious concurrence OFFICE PDV/LA PDV PH PDV P.

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• NAHE DFoster-Curseen LTran CTrammell WDean DATE 93

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Hr. William F.

Conway plant-specific or unique fire barrier configurations that are not bounded by the NUHARC program.

In accordance with the reporting requirements of GL 92-08, you are also to confirm, in writing, completion of the corrective actions.

The information requested by this letter is within the scope of the overall burden estimate in Generic Letter 92-08 which was an average of 300 person-hour s for each addressee's response.

This request is covered by Office of Hanagement and Budget Clearance Number 3150-0011, which expires June 30, 1994.

Also, in reviewing your response to the Generic Letter, we find that the additional information identified in the enclosure is needed to continue our review.

We request that you provide a response to the request for additional information within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Hanagement and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

Sincerely,

Enclosure:

Request for Additional Information cc w/enclosure:

See next page Charles H. Trammell, Senior Project Hanager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

Hr. William F.

Conwa the NUHARC program.

In accordance with the reporting requirements of GL 92-08, you are also to confirm, in writing, completion of the corrective actions.

The information requested by this letter is within the scope of the overall burden estimate in Generic Letter 92-08 which was an average of 300 person-hours for each addressee's response.

This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires June 30, 1

4.

Also, in reviewing your response to the Generic Letter, we find that t additional information identified in the enclosure is needed to conti ue our review.

We request that you provide a response to the request for ditional information within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents Therefore, it is not subject to Office of Management and Budget review und Pub.

L.96-511.

Please contact us should you have any questions regarding his request.

Sincerely, Charles H. Tr mell, Senior Project Manager Project Dire orate V

Division o Reactor Projects III/IV/V Office of uclear Reactor Regulati'on

Enclosure:

Request for Additional Information cc w/enclosure:

See next page DISTRIBUTION:

Docket File PDV Reading File EAdensam CTrammell

WDean, 13D18 CHcCracken, 8D1 HPSiemien, 15B18

PHadden, 8D1'RC Local PDRs JRo L

an oster-Curseen.

ACRS (10),

P-315 CBerlinger, 7E4

RJenkins, 7E4

KPerkins, RV See revious conc rence OFFICE NANE DATE PDV LA DFoster Curseen 93 PDV PH LTra h

P./

ammell 93 PD31 D A*

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TQuay 93 OFFICIAL RECORD COPY DOCUMENT NAME:PV85583.LTR

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Hr. William F.

Conway the NUHARC program.

In accordance with the reporting requirements of GL 92-08, you are also to confirm, in writing, completion of the corrective actions.

In reviewing your response to the Generic Letter, we find that the a

itional information identified in the enciosure is needed to continue our r iew. /he information requested by this letter is within the scope of the o

rail burden estimate in Generic Letter 92-08 which was an average of 300 per on-.hours for each addressee's response.

This request is covered by Office Management and Budget Clearance Number 3150-0011, which expires June 30 1994.

Sincerely,

Enclosure:

Request for Additional Information Charles H. Trammel

, Senior Project Manager Project Director e

V Division of Rea or Projects III/IV/V Office of Nuc ar Reactor Regulation cc w/enclosure:

See next page DISTRIBUTION:

Docket File PDV Reading File EAdensam CTrammell

WDean, 13D18 CHcCracken, 8Dl HPSiemien, 15B18

PHadden, 8D1 s

NRC 8

Loc 'DRs JRoe LTran DFos r-Curseen ACR (10),

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93 PDV/D TQuay 93 OFFICIAL RECORD COPY DOCUMENT NAME:PV85583.LTR

Mr. William F.

Conway Arizona Public Service Company Palo Verde CC:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street

Phoenix, Arizona 85007 James A. Beoletto, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, California 91770 Senior Resident Inspector Palo Verde Nuclear Generating Station 5951 S. Wintersburg Road

Tonopah, Arizona 85354-7537 Regional Administrator, Region V

U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear 'Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street

Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors ill South Third Avenue

Phoenix, Arizona 85003 Jack R.

Newman, Esq.

Newman

& Holtzinger, P.C.

1615 L Street, N.W., Suite 1000 Washington, D.C.

20036 Mr.. Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220

Phoenix, Arizona 85004 Roy P.

Lessey, Jr.,

Esq.

Bradley W. Jones, Esq.

Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, D.C.

20036 Mr. Thomas R. Bradish, Manager Nuclear Regulatory Affairs Arizona Public Service Company P. 0.

Box 52034

Phoenix, Arizona 85072-2034

~ ~

RE(VEST FOR ADDITIONAL INFORMATION ENCLOSURE 1.

With regards to the PVNGS Calculation 13-EC-ZA-300, "Derating of Cables in Trays," which was the basis for selecting a cable tray derating factor of 12.5X, the staff requests the following information for additional clarification:

'a ~

A copy of the PVNGS Calculation 13-EC-ZA-300, Thermal Power Organization Design Guide E2.6.4 and other related documentation which would assist in the determination that the existing PVNGS derating of 12.5X for Thermo-Lag covered cable trays is conservative when compared to the derating factors (i.e.,

28X for 1-hour barrier, 31X for 3-hour barrier) from the Underwriters Laboratories (UL) tests.

Similarly for conduits, please provide a copy of Calculation 13-EC-PA-210 which establishes the conservative basis for derating factors used in PVNGS design.

b.

Please state what industry standards (e.g.,

IPCEA, NEMA) are applicable in the ampacity determination for cables in cable trays and conduits at PVNGS.

c ~

How does the watts/foot per raceway methodology used at PVNGS compare with the methodology selected by NUMARC for future ampacity derating tests (i.e.,

IEEE Standard Procedure

'P848, Procedure for the Determination of Ampacity Derating of Fire Protected Cables)T d.

What tests have been conducted to verify the mathematical assumptions and conclusions of the subject PVNGS Calculations7 2.

In response to guestion 2(a) of the GL, the licensee indicated that the test on which they rely to support the qualifications on its fire barrier assemblies were conducted by Industrial Testing Laboratories (ITL) and that these tests were consistent with NRC requirements.

In Generic Letter (GL) 86-10, the NRC indicated the acceptance criteria for these barrier systems.

The ITL reports did not substantiate that the thermal lag fire barrier systems met the acceptance criteria identified in GL 86-10.

Please provide additional information for clarification.

3.

The licensee stated that the Thermo-Lag fire barrier systems installed do not represent the methods, dimensions, and configurations of the qualification test assembly.

The licensee did not confirm that the assemblies met the minimum manufacturer installation recommendations and that the minimum construction attributes used to construct the test specimen were incorporated in the plant specific installation procedures.

In addition, the licensee in its response did not establish a level of confidence that the "as-built" barrier assemblies are known.

Were these barriers installed under a gA/gC programs