ML17333A068

Responds to RAI Re GL 95-08, Product Consistency of Thermo- Lag 330-1 Fire Barriers

ML17333A068
Person / Time
Site:	Palo Verde
Issue date:	07/29/1996
From:	Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-03744-WLS-S, 102-3744-WLS-S, GL-95-08, GL-95-8, NUDOCS 9608120059
Download: ML17333A068 (8)

Text

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REGULAT INFORMATION DISTRIBUTIO YSTEM (RIDS)

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ACCESSION BBR:9608120059 DOC.DATE: 96/07/29 NOTARIZED:

NO DOCKET I FACILE!STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION STEWART,W.L.

Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to RAI re GL 95-08, "Product Consistency of Thermo-Lag 330-1 Fire Barriers."

DISTRIBUTION CODE:

A029D COPIES RECEIVED:LTR ENCI SIZE:

TITLE: Generic Letter 92-008 Thermo-Lag 330 Fire Barrier NOTES:STANDARDIZED PLANT Standardized plant.

Standardized plant.

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RECIPIENT ID CODE/NAME PD4-2 LA CLIFFORD,J INTERNA FILE CENT Ol

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" RGN4 FILE EXTERNAL: NOAC COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD4-2 PD CLIFFORD,J.

NRR/DE/EELB NRR/DSSA/SPLB NRC PDR COPIES LTTR ENCL D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTETH CONTACT THE DOCUMENT CONTROL DESK/

ROOM OWFN SD-5(EXT. 415"2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 12 ENCL

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4 Y'ILLIAM L STEWART EXECUTIVEVICE PRESIDENT

< 'NUCLEAR Arizona Public Service PALO VEROE NUCLEARGENERATING STATION P.O, BOX 52034 PHOENIX, ARIZONA 85072.2034 102-03744-WLS/SAB/NLT July 29, 1996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

References:

1)

Letter dated December 28, 1994, from Roy P. Zimmerman, Associate Director for Projects, Office of Nuclear Reactor Regulation, USNRC, to William L. Stewart, Executive Vice President, Nuclear, APS 2)

Letter dated June 21, 1996, from James W. Clifford, Senior Project

Manager, Project Directorate IV-2, Office of Nuclear Reactor Regulation, USNRC, to William L. Stewart, Executive Vice President,

'uclear, APS 3)

Letter dated February 21, 1995, from W. H. Rasin, NEI, to W. T.

Russell, Director, Office of Nuclear Reactor Regulation, USNRC

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Request for Additional Information Regarding Generic Letter 92-08, Product Consistency of Thermo-Lag 330-1 Fire Barriers By letters dated December 28, 1994 (Reference 1), and June 21, 1996 (Reference 2), the NRC required that Arizona Public Service Company (APS), pursuant to 10 CFR 50.54(f),

submit additional information regarding Generic Letter (GL) 92-08, "Thermo-Lag 330-1 Fire Barriers."

Specifically, Question 1.d of Reference 1 requested that APS submit a supplemental report after tests and analyses of Thermo-Lag materials have been performed to verify that the materials used at PVNGS are representative of the materials used to address the technical issues associated with Thermo-Lag barriers.

APS participated in the Nuclear Energy Institute (NEI) industry test

program, communicated to the NRC in Reference 3, to evaluate chemical composition as a means of addressing product consistency.

The program consisted of pyrolysis gas chromatography (PGC) evaluations of 169 utility-provided samples to assess organic chemical composition and energy dispersive X-ray spectroscopy of 33 samples to assess

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< U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Thermo-Lag 330-1 Response to Request for Additional Information Page 2 inorganic chemical composition.

The sample population consisted of materials manufactured between 1982 and 1995.

On the basis of the above tests, NUCON International, Inc. concluded that all samples. contained the constituents identified by

'Thermal Sciences, Inc.

(TSI) as essential to fire barrier performance, and that the composition of the samples was consistent.

PVNGS supplied a total of 6 samples to the NEI industry test program.

A sample of trowel grade material and pre-fabricated board material was provided from each of the three respective PVNGS units. APS sent 13 additional samples of pre-fabricated Thermo-Lag panels to NUCON Labs, Inc. for PGC testing.

These additional samples were taken from each unit and represent Thermo-Lag installed in the plant to meet licensing commitments.

The PVNGS test results are consistent with other utility samples.

The results are summarized in NUCON International, Inc.

Iab reports NUCON 06AZ80901 and 06AZ83301. The high degree of chemical consistency exhibited adequately demonstrates that the Thermo-Lag utilized by APS is equivalent to the material utilized to perform industry tests.

The consistent chemical test results from the broad population of Thermo-Lag represented, also validates our position that 19 samples from PVNGS is sufficient.

APS does not plan to conduct any additional chemical composition testing.

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In conclusion, the NEI test program, in conjunction with the tests performed on the additional APS samples, have demonstrated product consistency which provides the basis for concluding that the materials used to address the technical concerns associated with Thermo-lag barriers are representative of the materials installed in PVNGS.

Should you have any questions, please contact Scott A. Bauer at (602) 393-5978.

Sincerely, WLS/SAB/NLT/rv Enclosure cc:

L. J. Callan K. E. Perkins J. W. Clifford K. E. Johnston

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STATE OF ARIZONA

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COUNTY OF MARICOPA )

I, W. L. Stewart, represent that I am Executive Vice President - Nuclear, Arizona Public Service Company (APS), that the foregoing document has been signed by me on behalf of APS with full authority to do so, and that to the best of my knowledge and belief, the statements made therein are true and correct.

W. L. Stewart Sworn To Before Me ThisB Day Of~~4, 1996.

Notary Public My Commission Expires MvColmbslonExpIres June12, 1997

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