Text

Provides Followup to Request for Addl Info Re GL 92-08, Thermo-Lag 330-1 Fire Barriers, Issued Per 10CFR50.54(f). Some of Installation Parameters Discussed in Section II of RAI of Dec 1993 Cannot Be Verified by Simple Walkdowns
	ML17332A501
Person / Time
Site:	Cook
Issue date:	12/29/1994
From:	Zimmerman R; Office of Nuclear Reactor Regulation
To:	Fitzpatrick E; AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO.
References
	GL-92-08, GL-92-8, IEIN-92-079, IEIN-92-79, TAC-M85538, TAC-M85539, NUDOCS 9501100294
	Download: ML17332A501 (10)
	v • d • e

I gP,S RECy

~

(4

~o

+**++

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON) D C 2055&4001 December 29, 1994 Mr. E. E. Fitzpatrick, Vice President Indiana Michigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza

Columbus, Ohio 43215 SUBJECT-FOLLOWUP TO THE RE(VEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, ISSUED PURSUANT TO 10 CFR 50.54(f),

D. C.

COOK, UNITS 1

AND 2 (TAC NOS.

M85538 AND M85539)

Dear Mr. Fitzpatrick:

In response to U.S. Nuclear Regulatory Commission (NRC) staff requests for information regarding Generic Letter (GL) 92-08, "Thermo-Lag 330-1 Fire Barriers," you indicated that D. C.

Cook planned to continue to rely on Thermo-Lag fire barriers to comply with NRC fire protection regulations.

On September 29, 1994, the U.S. Attorney for the District of Maryland and the NRC Inspector General (IG) announced the indictment of Thermal Science, Incorporated (TSI), the company that manufactures and supplies Thermo-Lag fire barrier materials, and its president, Mr. Rubin Feldman.

The indictment alleges that TSI and Mr. Feldman conspired with Industrial Testing Laboratories, Incorporated (ITL), and others to make false statements and conceal material facts within the jurisdiction of the NRC and to defraud the United States by impeding, impairing, obstructing, and defeating the NRC s

administration of the Atomic Energy Act.

ITL had pleaded guilty in U.S.

District Court in Maryland in April 1994; In a letter of November 7,

1992, TSI informed the staff that preshaped Thermo-Lag conduit sections received by Texas Utilities Electric Company (TU Electric) for Comanche Peak Steam Electric Station, Unit 2 (CPSES 2) showed signs of delamination and voids.

The NRC staff was concerned that the use of such materials could affect the results of TU Electric's fire tests and the performance of the Thermo-Lag barriers installed at CPSES 2.

In a letter of December 15,

1992, TU Electric described the actions it had taken to ensure that the fire barrier materials used in its fire test program were representative of the materials installed at CPSES 2,

and described how it had addressed the delamination and void concerns.

On the basis of its evaluation of the TU Electric submittal, the staff concluded that the fire test specimens were representative of the materials installed at CPSES 2 and that TU Electric had adequately addressed the delamination and void concerns.

The IG has informed the staff that TSI may not have implemented certain measures to correct the void and delamination problems even though it had informed TU Electric that it had done so.

Specifically, we believe that TSI representatives informed TU Electric that it had trained its employees to repair the delaminations,

cracks, and voids and that it had provided TU Electric with signed training certificates to document this training.

In fact, -.we believe that TSI may not have trained its employees to perform these repairs.

This situation calls into question the reliability of TSI's quality e50X>ooaqa

~4>a29 PDR

DOCK 05000315 P

PDR assurance program for Thermo-Lag materials, and the quality of Thermo-Lag

~I; HLE/~BI COI ~ ~if'

0 d

I

E. Fitzpatrick December 29, 1994 The NRC staff has considered the effect of the indictment on the plans of NRC

, staff and industry to resolve the technical issues associated with Thermo-Lag fire barriers.

In my letter of September 23, 1994, I informed you that the Commission was requiring that all plants with Thermo-Lag fire barriers return to compliance with existing NRC fire protection regulations.

The indictment does not alter this decision.

Licensees planned to use information and data supplied by TSI to demonstrate that Thermo-Lag fire barrier installations conform to NRC regulations.

However, the concerns and issues underlying the indictment and the TU Electric experience sharpened concerns previously expressed by the NRC staff to the licensees about the reliability of information and data supplied by TSI that have been o} could be used to make judgments regarding Thermo-Lag materials.

Therefore, the staff will request licensees to take actions to fully address the technical issues discussed in GL 92-08, independent of information and data supplied by TSI, before the staff makes any determination regarding whether the use of Thermo-Lag fire barriers complies with NRC regulations.

The NRC staff and industry have relied on the results of tests and analyses conducted by NRC staff and industry to draw conclusions regarding the performance of Thermo-Lag fire barrier materials.

However, such conclusions require that the materials tested be representative of the broad class of material actually installed in the plant.

Judgments regarding representativeness, in turn, require reasonable assurance that appropriate quality assurance measures were taken in the manufacture of the Thermo-Lag materials or, alternatively, that the licensees determine that the properties and quality of the materials are appropriate for their applications and satisfy the staff that the determinations are correct.

On the basis of the concerns underlying the indictment and the TU Electric experience, the staff has determined that reliance should not be placed on TSI's quality assurance program for the purpose of assessing the adequacy of Thermo-Lag materials that are currently installed or that are installed in, the future.

The staff has also concluded that it is not enough for licensees to rely on generic information on Thermo-Lag materials.

The licensee must also have valid information on the specific Thermo-Lag materials installed at its plant if it intends to retain or expand its Thermo-Lag fire barrier installations.

The staff previously addressed the uniformity of Thermo-Lag materials in Section II, " Important Barrier Parameters,"

of the request for additional information (RAI) of December 1993 regarding Generic Letter 92-08.

In Section II of the RAI, the staff stated:

[B]ecause of questions about the uniformity of the Thermo-Lag fire barrier materials produced over time, NUHARC [now Nuclear Energy Institute] stated in its letter of July 29, 1993, that "[c]hemical analysis of Thermo-Lag materials provided for the program, as well as samples from utility stock, will be performed, and a test report prepared comparing the chemical compositions of the respective samples."

The results of the chemical analyses may indicate that variations in the chemical properties of Thermo-Lag are significant and may require additional plant-specific information in the future.

E. Fitzpatrick December 29, 1994 Mhere the licensees plan to rely on fire endurance test results to draw conclusions regarding the qualifications of specific Thermo-Lag fire barrier installations, such conclusions require that installed materials and configurations be representative of tested materials and configurations.

This, in turn, requires that the installation parameters for the tested configuration bounded the installation parameters of the in-plant configuration and that appropriate quality assurance measures were taken in the manufacture of the Thermo-Lag materials, and the construction of the test specimen and the in-plant fire barrier.

In Section II of the RAI of December 1993, the staff listed 24 important fire barrier installations parameters and eight important cable parameters.

At least two of the parameters, panel thickness and conduit panels, are controlled by TSI at the point of manufacture.

Other parameters, such as panel rib orientation, tie-wire spacing, and proximity of cables to the unexposed surfaces of the fire

barrier, are determined during barrier design and construction.

The remaining parameters, such as cable size and type, are established by plant design.

After the RAI was issued, many licensees informed the staff that they had not verified some of the parameters and several licensees reported deviations and defects in fire barrier installations that were revealed only after destructive examination of in-plant Thermo-Lag fire barriers.

The staff informed licensees of installation deficiencies found at Enrico Fermi Atomic Power Plant, Unit 2, in Information Notice 92-79, Supplement I, "Deficiencies Found in Thermo-Lag Fire Barrier Installation," August 4, 1994.

Later, Grand Gulf Nuclear Station reported installation deficiencies found during destructive fire barrier examinations (Licensee Event Report 94-008).

On the basis of its inspections of Thermo-Lag fire barriers and industry experience finding installation defects during destructive examinations, the

.staff has concluded that some of the installation parameters discussed in Section II of the RAI of December 1993 cannot be verified or determined by simple walkdowns of in-plant barriers, or by comparing as-built barriers with installation records or with the installation procedures used to construct the barriers.

The staff has also concluded that some of the parameters can only be obtained and verified by detailed examination such as disassembling a

representative sample of in-plant fire barrier configurations.

The licensee must have valid and verifiable information on each of the parameters for its in-plant Thermo-Lag barriers if it intends to retain, modify, or expand its Thermo-Lag fire barrier installations.

The NRC staff and licensees have also relied on information, data, and calculations supplied by TSI to draw conclusions regarding the seismic capabilities of Thermo-Lag materials and barriers.

These conclusions are also being reevaluated by the staff.

You are 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 or affirmation, that contain the information specified in the enclosure to this letter in Sections l.a, I.b, I.c, 2.a, 2.b, and 2.c, within 90 days from the date of this letter.

Retain on site all information and documentation used to

E. Fitzpatrick December 29, 1994 prepare your response; these may be reviewed during future NRC audits or inspections.

You are also reminded of the following GL 92-08 reporting requirement:

"When corrective actions have been completed, confirm in writing their completion."

The information collection contained in this request is covered by the Office of Management and Budget clearance number 3150-0011, which expires on July 31, 1997.

The public reporting burden for this collection of information is covered by the previous estimate of 420 person-hours plus an increase of 120 person-hours, for a total of 540 person-hours for each addressee's response.

This includes time for reviewing instructions, searching existing data sources, gathering and maintaining the data

needed, and completing and reviewing the collection of information.

Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (T-6 F33),

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202 (3150-0011),

Office of Management and Budget, Washington, DC 20503.

If you have any questions about this matter, please contact John B. Hickman at 301-504-3017 or Edward Connell at 301-504-2838.

Docket Nos.

50-315 and 50-316 Sincerely, Originalsignedb/+y e Sar'oy P.

Zimmerman Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/encl:

See next page Distribution (w/encl):

c Docket f'iles PUBLIC PDIII-1 Rdg File OGC ACRS (4)

JHartin, RIII RZimmerman CHcCracken EConnell CBerlinger GBagchi WKropp, RIII JRoe JHannon JHickman CJamerson HGamberoni DOCUMENT NAME:

G:iWPDOCSrtDCCOOKIIC085538.RAI To receive a copy of this document, Indlcato In tho botu C

rs Copy without attachment/enclosure E" a Copy with attachment/enclosure N

~ No copy OFFICE LA:PDIII-

= PM:PDIII-1 E

BC:S D:PDIII-DATE CJamerson 12/R/94 JHi ckma 12//fII/94 CMc cken 12/< /94 JHanno 12/

/94 RZim ma OFFICIAL RECORD COPY

0 J

~ g 4 /

~awk e

hp