ML17311B269

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Requests Addl Info Re GL 92-08, Thermo-Lag 330-1 Fire Barriers. Response Should Be Submitted within 45 Days of Ltr Receipt
ML17311B269
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 11/03/1995
From: Thomas C
NRC (Affiliation Not Assigned)
To: Stewart W
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
GL-92-08, GL-92-8, TAC-M85583, TAC-M85584, TAC-M85585, NUDOCS 9511150209
Download: ML17311B269 (14)


Text

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November 3, 19~

Mr. William L. Stewart Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999

Phoenix, Arixona 85072-3999

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 PALO VERDE NUCLEAR GENERATING STATION (TAC NOS.

M85583, M85584, AND M85585j

Dear Mr. Stewart:

The NRC staff has reviewed Arizona Public Service Company's responses of December 22,

1994, March 28,
1995, and August 1, 1995, to the requests for additional information (RAIs) of September 23,
1994, December 7,
1994, and December 28, 1994, respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers."

As a result of the review, the staff has found that the licensee's responses to the RAIs are incomplete.

The specific areas where the responses were incomplete are discussed in the enclosure.

To assist the NRC staff in meeting its review schedule, we request that you respond to the RAI in writing within 45 days of receipt of this letter.

The requirements affect nine or fewer respondents and, therefore, are not subject to the Office of Management and Budget review under P.L.96-511.

If you have any questions, please contact me at 301-415-1325.

Sincerely, Original Signed By Docket Nos.

STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information cc w/encl:

See next page Document Name:

PV85583.RAI Charles R. Thomas,,Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation DISTR I BUTION:

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November 3,

5 Hr. William L. Stewart Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999

Phoenix, Arixona 85072-3999

SUBJECT:

RE(VEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 PALO VERDE NUCLEAR GENERATING STATION (TAC NOS. H85583,

H85584, AND H85585)

Dear Hr. Stewart:

The NRC staff has reviewed Arizona Public Service Company's responses of December 22,

1994, March 28,
1995, and August 1,. 1995, to the requests for additional information (RAIs) of September 23,
1994, December 7,
1994, and December 28, 1994, respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers."

As a result of the review, the staff has found that the licensee's responses to the RAIs are incomplete.

The specific areas where the responses were incomplete are discussed in the enclosure.

To assist the NRC staff in meeting its review schedule, we request that you respond to the RAI in writing within 45 days of receipt of this letter.

The requirements affect nine or fewer respondents and, therefore, are not subject to the Office of Management and Budget review under P.L.96-511.

If you have any questions, please contact me at 301-415-1325.

Sincerely, Original Signed By Charles R. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.

STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information cc w/encl:

See next page Document Name:

PV85583.RAI DISTR IBUTION:

Docket File PUBLIC PDIV-2 Reading JRoe WBateman EPeyton CThomas EAdensam

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 3, 1995 Mr. William L. Stewart Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999

Phoenix, Arixona 85072-3999

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 PALO VERDE NUCLEAR GENERATING STATION (TAC NOS. H85583,

H85584, AND M85585)

Dear Mr. Stewart:

The NRC staff has reviewed Arizona Public Service Company's responses of December 22,

1994, March 28,
1995, and August 1, 1995, to the requests for additional information (RAIs) of September 23,
1994, December 7,
1994, and December 28, 1994, respectively, regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers."

As a result of the review, the staff has found that the licensee's responses to the RAIs are incomplete.

The specific areas where the responses were incomplete are discussed in the enclosure.

To assist the NRC staff in meeting its review schedule, we request that you respond to the RAI in writing within 45 days of receipt of this letter.

The requirements affect nine or fewer respondents and, therefore, are not subject to the Office of Management and Budget review under P.L.96-511.

If you have any questions, please contact me at 301-415-1325.

Sincerely, Docket Nos.

STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information Charles R. Thomas, Project Hanager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation cc w/encl:

See next page

Mr. William L. Stewart November 3, 1995 cc w/encl:

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

Phoenix, Arizona 85007 T.

E. Oubre, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, California 91770 Senior Resident Inspector USNRC P. 0.

Box 40 Buckeye, Arizona 85326 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission Harris Tower 5 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064

Chairman, Board of Supervisors ATTN:

Chairman 301 W. Jefferson, 10th Floor

Phoenix, Arizona 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street
Phoenix, Arizona 85040 Mr. Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 200
Phoenix, Arizona 85004 Roy P.

Lessey, Jr.,

Esq.

Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Avenue, Suite 400 Washington; DC 20036 Ms. Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O.

Box 52034

Phoenix, Arizona 85072-2034

t l

PALO VERDE NUCLEAR GENERATING STATION UNITS 1

2 AND 3 DOCKET NOS.

50-528 50-529 AND 50-530 OLLOWUP RE VEST OR ADD TION INFO MATION REGARDING GENERIC LETTER 92-08.

THERMO-LAG 330-1 FIR BARRI S

1.

REQUEST FOR ADDITIONAL INFORMATION (RAI) 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)7" 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 reviewing the tests performed under the draft Institute of Electrical and Electronic Engineers (IEEE) Standard

P848, the staff transmitted comments that were designed 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.

REQUESTS FOR ADDITIONAL INFORMATION OF DECEMBER 7, 1994 AND DECEMBER 28, 1994 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 1,

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, after resolving NRC issues associated with the draft IEEE P848 Standard, it will determine to what extent specific details of cable,

raceway, and fire barrier features must be reconsidered to demonstrate applicability of specific tests to installed configurations.

On Hay 18,

1995, 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 Hay 22,

1995, which documents the subject telephone conference meeting, is attached for your information.

In addition, a copy of the SE dated June 14,

1995, was sent to those licensees who rely on Thermo-Lag installations.

In its submittal of August 1, 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.

In the RAI of Oecember 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 Harch 28, 1995, the licensee did not provide any further information on the ampacity derating issue.

Attachment:

Hay 22,

1995, Hemorandum

Nay 22, 1995 NOTE TO:

SrIon N. ron,

OIroctor, OE, NNN FNN:

Carl H. Serlfngcr, Chief, EELS, DE, NR

SUBJECT:

NEHORANNN OF RECORD Attachment On Nay 18, 1995, <<e<<hers of the KRC staff (B. Sheron, C. Berlfnaer, P. Cfll, N, 6aabcronf and R. Jcnkfns) held a telephone conference call eath Nr. Alex Narfon and Nr. Sfff Bradley of ihe kuclear Energy Institute (NEI) on ampacfty deratfng issues for Ther<<o-Lag fire barriers.

Nr. Narfon contacted thc staff regardfnj tvo topics (I) Status of the Safety 'Evaluation (SE) on the Coaanche Peak Stea<< Electric Station (CPSES). Vnft 2 A<<pacfty Deratfng Test Progra<<;

and (2) Staff Acceptance of the IEEE Standard P848, 'Procedure for the Deter<<fnat)on of the A<<pacity Derating of Fire Protected Cables.'r.

Berlfnger stated that the subJect SE for CPSES 2 had been co<<pleted and vc expected that it vill bc trans<<fttcd to thc licensee vithfn the next tvo weeks.

Dr. Berlingcr agreed to notify Nr. Narfon by phone after the SE had been issued by the staff.

Duc to potential generic applications thc staff vill provide a copy of the CPSES, Unit 2 SE to licensees vfth Thermo-Lag fire barriers.

The staff has been interfacing vfth the IEEE Task Force responsible for IEEE P848 over the last 2 years to f<<prove the subJect procedure.

This effort has resulted fn recent revisions to the subJect procedure which addressed thc

<<aJorfty of the concerns rafsed by EELS (reference:

Letter dated 10/l3/94 froa C.,Berlfnger to A. K. Gwal).

Although not all of the concerns vere addressed by the IEEE Task Force Dr. Berlfnger indicated that thc latest IEEE P848 draft procedure can be used by licensees or'KEI as the basis for an.

ampacfty dcrating test progra<<.

The latest procedure revision (Graft 16) addresses the <<aJor test concerns regarding inductive heating and conduit surface emfssfvftfcs effects.

The staff emphasized that licensees should submit the actual test procedures or plans to the staff for coaeent.

After discussion of the various options to develop a generic test progra<< KEI agreed to review the CPSES 2 SE and then contact the staff as necessary for further discussions or questions on this

<<atter.

cc:

Alex Narion, KEI CONTACT:

Ronaldo Jcnkins, EELB/DE 415-2985

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