ML17311B183

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Informs That Licensee Responses to Requests for Addl Info Re GL 92-08, Thermo-Lag 330-1 Fire Barriers, Incomplete
ML17311B183
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 09/15/1995
From: Calvo J
NRC (Affiliation Not Assigned)
To: Bateman W
NRC (Affiliation Not Assigned)
References
GL-92-08, GL-92-8, TAC-M85583, TAC-M85584, TAC-M85585, NUDOCS 9509200176
Download: ML17311B183 (5)


Text

September 15, 1995 MEMORANDUM TO:

FROM:

SUBJECT:

William H. Bateman, Director Project Directorate IV-2 Division of Reactor Projects III/IV Jose A

Ca) vo Chief (Original signed by J.

Cal vo)

Electrical Engineering Branch Division of Engineering

RESPONSE

TO THE FOLLOWUP TO THE REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 (TAC NOS. M85583/M85584/M85585)

Plant:

Licensee:

Review Status:

Palo Verde Nuclear Generating Station, Units 1

& 2 and 3

Arizona Public Service Company Open We have reviewed Arizona Public Service Company's responses of December 22,

1994, March 28,
1995, and August 1,

1995, to the requests for additional information (RAI) of September 23,

1994, and December 28,
1994, and December 7,

1994 respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers."

The licensee was required, pursuant to Section 182A of the Atomic Energy Act of 1954, as

amended, and 10 CFR 50.54(f), to submit written reports, under oath of affirmation, that provided the information specified in the RAIs.

On the basis of our review, we have determined that the licensee's responses to the RAIs are incomplete.

The specific areas where we found the licensee's responses to be incomplete are discussed in the attachment.

Please transmit this information to the licensee and request that it submit a revised response.

We recommend that the licensee be given 45 days to submit its revised response.

Docket Nos.:

50-528 50-529 50-530

Attachment:

As stated CONTACT:

R. Jenkins, NRR/DE 415-2985 DISTRIBUTION:

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-OG01 September 15, i995 HEMORANDUM TO:

FROM:

SUBJECT:

William H. Bateman, Director Project Directorate IV-2 Division of Reactor Projects III/IV Jose A. Calvo, Chief Electrical Engineering Branch Division of Engineering

RESPONSE

TO THE FOLLOWUP TO THE RE(UEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 (TAC NOS.

M85583/M85584/M85585)

Plant:

Licensee:.

Review Status:

Palo Verde Nuclear Generating Station, Units 1, 2 and 3

Arizona Public Service Company Open We have reviewed Arizona Public Service Company's responses of December 22,

1994, March 28,
1995, and August 1, 1995, to the requests for additional information (RAI) of September 23,
1994, and December 28,
1994, and December 7,

1994 respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers."

The licensee was required, pursuant to Section 182A of the Atomic Energy Act of 1954, as

amended, and 10 CFR 50.54(f), to submit written reports, under oath of affirmation, that provided the information specified in the RAIs.

On the basis of our review, we have determined that the licensee's responses to the RAIs are incomplete.

The specific areas where we found the licensee's responses to be incomplete are discussed in the attachment.

Please transmit this information to the licensee and request that it submit a revised response.

We recommend that the licensee be given 45 days to submit its revised response.

Docket Nos.:

50-528 50-529 50-530

Attachment:

As stated CONTACT:

R. Jenkins, NRR/DE 415-2985

ATTACHMENT PALO VERDE NUCLEAR GENERATING STATION,. UNITS 1

K 2 AND 3 DOCKET NOS. 50-528, 50-529 AND 50-530 FOLLOWUP REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 "THERMO-LAG 330-1 FIRE BARRIERS" 1.0 REQUEST FOR ADDITIONAL INFORMATION OF SEPTEMBER 23, 1994 In the RAI of September 23, 1994, the NRC staff requested information regarding important barrier parameters, Thermo-Lag barriers outside the scope of the Nuclear Energy Institute (NEI) program, ampacity derating, alternatives, and schedules.

In its submittal of December 22, 1994, the licensee stated that the power cables that are routed through raceways enclosed in Thermo-Lag 330-1 material will be reviewed to verify that the actual amperage does not exceed the derated ampacity value.

The licensee also stated that the calculation will be formatted in a manner that will permit rapid reevaluation of the results at such a time as further information becomes available from the industry.

During a public meeting on March 14, 1995, with the licensees for the four lead plants for the resolution of Thermo-Lag issues, the staff responded to the question, "Will the resolution of the ampacity derating concern be deferred until agreement is reached on the appropriate testing protocol (i.e.,

IEEE P848)2" The staff reiterated its position, which was previously stated in the September 1994 RAI, that the ampacity derating concern could be resolved independently of the fire endurance concerns.

After a review of the tests performed under the draft Institute of Electrical and Electronic Engineers (IEEE) standard

P848, the staff transmitted comments that were designated to ensure the repeatability of test results to the IEEE working group responsible for the test procedure.

The licensee is requested to submit its ampacity derating evaluations, including any applicable test reports, in order to provide an adequate response to Generic Letter 92-08 reporting requirement 2(c).

2.0 REQUEST FOR ADDITIONAL INFORMATION OF DECEMBER 7 AND 28, 1994 In the RAI of December 28, 1994, the staff requested information describing the examinations and inspections that will be performed to obtain the important barrier parameters for the Thermo-Lag configurations installed at Palo Verde Nuclear Generating Station.

In its response of March 28, 1995, the licensee did not provide any further information on the ampacity derating issue.

In the RAI of December 7,

1994, the staff requested that the licensee address several open issues and concerns regarding their original analytical approach for ampacity derating determinations.

Specifically, the staff, in conjunction

with our contractor, Sandia National Laboratories, questioned several aspects of the watts-per-foot methodology that was used to determine the ampacity derating factors of the Thermo-lag fire barriers installed at the Palo Verde Nuclear Generating Station.

In its submittal of August I, 1995, the licensee stated that it has eliminated the watts-per-foot methodology previously utilized in the electrical design calculations.

The licensee is in the process of adopting a new methodology for ampacity derating determinations as part of the design basis reconstitution effort.

The licensee stated that following the resolution of NRC issues associated with the draft IEEE P848 standard it will determine to what extent specific details of cable,

raceway, and fire bar rier features must be reconsidered to demonstrate specific test applicability to installed configurations.

On Hay 18, l995, members of the NRC staff held a telephone conference call with NEI representatives on ampacity derating issues for Thermo-Lag fire barriers.

The staff indicated that the latest IEEE P848 draft procedure can be used by licensees or NEI as the basis for an ampacity derating test program.

NEI agreed to review the Comanche Peak Steam Electrical Station Unit 2 Safety Evaluation (SE) in order to develop a generic test program.

The memorandum dated May 22, 1995, which documents the subject telephone conference

meeting, is attached for your information.

In addition, a copy of the subject SE dated June'4, 1995 was sent to those licensee who rely on Thermo-Lag installations.

In its submittal of August I, 1995, the licensee indicated that there are no plans to conduct ampacity derating tests.

Please submit a description of the anticipated analytical methodology including typical calculations that will be used to determine the ampacity derating parameters for the Thermo-Lag fire barriers installed at the Palo Verde Nuclear Generating Station.