ML18011A862

Forwards Response to RAI Re GL 92-08, Thermo-Lag 330-1 Fire Barriers.

ML18011A862
Person / Time
Site:	Harris
Issue date:	03/23/1995
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-92-08, GL-92-8, HNP-95-036, HNP-95-36, TAC-M85556, NUDOCS 9503290152
Download: ML18011A862 (22)

Text

P RIDRIWY (ACCELERATED RIDS PROCESSIN 1

~ REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) aii ACCESSION NBR:9503290152 DOC.DATE: 95/03/23 NOTARIZED- YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,W.R. Carolina Power & Light Co. P RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to RAI re GL 92-08, "Thermo-Lag 330-1 Fire Barriers."

DISTRIBUTION CODE: A029D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Generic Letter 92-008 Thermal-Lag 330 Fi e Barrier 0 NOTES:Application for permit renewal filed. 05000400 R RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 ,PD2-1 PD 1 1 LE,N 1 1 1.

INTERNAL. LE CENTER 01 NRR/DRPW/PD3-1 RGN2 ....FILE 1,1'1 1

1 1 NRR/DE/EELB NRR/DSSA/SPLB 2 1

2 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

0 U

N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS I'OR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR ll ENCL 10

l.I

, ~

Carolina Power & Light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant MAR 2 5'f995 File Number: HO-950512 SERIAL: HNP-95-036 NRC TAC NO. M85556 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO THE NRC STAFF REQUEST FOR ADDITIONAL INFORMATION REGARDING NRC GENERIC LETTER 92-08,"THERMO-LAG 330-1FIRE BARRIERS" Gentlemen:

The purpose of this letter is to provide Carolina Power Ec Light Company's response to an NRC staff letter dated December 23,1994 regarding NRC Generic Letter (GL) 92-08, "Thermo-Lag 330-1 Fire Barriers," for COL's Shearon Harris Nuclear Power Plant (SHNPP). The NRC letter provided information regarding Thermal Science, Inc.'s(TSI) quality assurance program and also required the submittal of certain information within 90 days of the date of the NRC letter.

Enclosure 1 provides the 'information requested in the NRC's December 23, 1994 letter pertaining to Sections 1.a, 1.b, l.c,2.a,2.b,and 2.cof the enclosure to the letter.

Questions regarding this matter may be referred to Mr. R. W. Prunty at (919) 362-2030.

Sincerely, W. R. Robinson SDC/sdc Mr. S. D. Ebneter Mr. S. A. Elrod Mr. N. B. Le pg W. R. Robinson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of,Q~Q@,

Power & Light Company. ~~ ee"X 95032'st0152 950323 PDR ADOCK 05000tt00 Rlt O PDR Nota e~ C.

P My commission expires: Q 6- ~000 Seal)

I~

~Q PUBLIC

<> J 4 O 3O State Road 1134 New Hill- NC Tel 919 362-2502 Fax 919 362-2095 Ogpu stanssss slO

v n ENCLOSURE TO NLS-95-036 RESPONSE .TO THE NRC's DECEMBER 23, 1994 REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 FIRE BARRIERS" Section 1. Thermo-La Materials NRC Request 1.a. Describe the specific tests and analyses that will be performed to verify that the Thermo-Lag fire barrier materials that are currently installed at the Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP), or that will be installed in the future, are representative of the materials that were used to address the technical issues associated with Thermo-Lag barriers and to construct the fire endurance and ampacity derating test specimens. The tests and analyses shall address the material properties and attributes that were determined or controlled by TSI during the manufacturing process and the quality assurance program. The tests and analyses shall also address the material properties and attributes that contribute to conclusions that the Thermo-Lag materials and barriers conform to NRC regulations. These include:

(1) chemical composition (2) material thickness (3) material weight and density (4) the presence of voids, cracks, and delaminations (5) fire endurance capabilities (6) combustibility (7) flame spread rating (8) ampacity derating (9) mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength.

CPAL Response The scope of Thermo-Lag 330-1 material used at SHNPP and covered by this response includes the following:

A fire area enclosure located in the Cable Spreading and Aux. Control Panel rooms, A partial height fire wall located in the Reactor Building, Fire door transoms and mullion fire proofing protection, and

e~

ENCLOSURE TO NLS-95-036 Conduit protection. (As outlined in CP&L letter dated December 19, 1994, HNP-94-103, this material will no longer be credited for compliance to meet NUREG-0800, 9.5.1separation requirements. Therefore, Items 1,2,4, and 5 below will not be applicable to Thermo-Lag materials originally installed as conduit protection).

Future installations of Thermo-Lag to support repairs or upgrades willbe performed under CP&L's Fire Protection Quality Assurance program. Quality Attributes will be developed from industry test results which can be utilized by CP&L during receipt inspections to verify acceptability of the Thermo-Lag material.

(1) Chemical Composition CP&L is currently performing chemical testing in accordance with the guidance provided by NEI to NRC letter dated February 21, 1995. The NEI chemical testing program will use samples submitted from various nuclear plants including SHNPP. It relies on a standard test protocol (pyrolysis gas chromatography consistent with ASTM D8452) and the creation of a generic data pool to provide the most resource effective method to develop information on product consistency. Use of a generic pool of, samples will cover a larger population of lot numbers and provide assurance of material consistency.

The test program is using the chemical composition of eighteen samples obtained under the generic fire endurance test program as the basis for comparison. These samples were obtained from licensee stocks and from TSI.

It is expected that these samples will cover a wide spectrum of installation types which were installed at various times. Should this program demonstrate that there are no significant differences in Thermo-Lag 330-1 material which has been utilized in the industry, a strong basis will exist to show that there are no chemical composition problems.

If the NEI test program demonstrates variances in the chemical composition of material installed in the industry, CP&L will evaluate the results of the program to determine what additional chemical testing would be required to demonstrate the adequacy of the installed configurations at SHNPP.

ENCLOSURE TO NLS-95-036 (2) Material Thickness CP&L willperform thickness measurements in accordance with the guidance provided in ASTM E605-93 for the area enclosure and partial height wall.

Thermo-Lag applied to the door transoms and mullions will be evaluated in accordance with the guidance provided in Generic Letter 86-10. CPS'ill verify, as necessary, the attributes required to perform the re-evaluation.

(3) Material Weight and Density The NRC has requested additional information from NEI concerning the extent (i.e., organic/inorganic content) and type of material chemical composition testing being performed to ensure material consistency.

Therefore, material properties (such as weight and density) which may vary with chemical composition are an outstanding issue. The interrelationship between material chemical composition and the other material properties such as fire endurance capability, flame spread rating, combustibility, ampacity derating and mechanical properties should be moot ifconsistency of material chemical composition can be successfully demonstrated. Industry chemical composition testing being jointly conducted through NEI is currently under discussion with NRC. CPEcL will evaluate the results of the NEI chemical testing program to determine what additional material properties testing would be required to demonstrate the adequacy of the installations at SHNPP.

Issues of weight as it relates to seismic qualification of the fire barriers are addressed in 1.a.(9).

(4) Presence of Voids, Cracks, and Delaminations CPEcL understands that the presence of voids, cracks, and delaminations may result from the bending process Thermal Science, Inc. utilizes to shape flat panels into conduit halves. This bending process can create voids and cracks which are normally repaired prior to shipment The bending process may also result in delaminations internal to the conduit halves. As outlined in our December 19,1994response, the conduits protected with Thermo-Lag willno longer be credited for compliance with NUREG-0800 as qualified fire barriers; therefore, this concern is not applicable to SHNPP. The flat panel sections utilized to construct the area enclosures and partial height walls are not subject to this type of bending process. Therefore, no additional inspections, tests or analyses will be performed for this concern. Similarly, trowel grade material, either sprayed or brushed onto the protected surfaces, is not subject to induced flaws from the bending process.

ENCLOSURE TO NLS-95-036 Fire Endurance Capabilities The NEI test program has independently established the fire endurance capabilities for a variety of Thermo-Lag barrier configurations. As stated in CP&L letter dated December 19, 1994, CP&L has been participating in a joint utility fire testing program in an effort to qualify the barriers not bounded by the NEI test program. This testing, which should establish bounding conditions for the area enclosure and partial height fire wall, is still in process. Portions of this program applicable to SHNPP will be completed by December 31, 1995.

Thermo-Lag applied to the door transoms and mullions will be evaluated in accordance with the guidance provided in Generic Letter 86-10. CP&L will verify, as necessary, the attributes required to perform the re-evaluation.

Combustibility CP&L plans to utilize the information contained in the NEI Combustibility Evaluation Guideline associated with the heat release rates to document the additional effects on the combustible loading calculations associated with the Thermo-Lag configurations at SHNPP. No plant specific combustibility testing will be performed.

Flame Spread Rating CP&L plans to utilize the information contained in the NEI Combustibility Evaluation Guideline associated with the heat release rates to document the additional effects on the combustible loading calculations associated with the Thermo-Lag configurations at SHNPP. No plant specific flame spread rate testing will be performed.

Ampacity Derating As stated in CP&L letter dated December 19, 1994, a review of the ampacity calculations determined that design margin remains using the most conservative ampacity dexating available to date (i.e.,GL 92-08).

NEI letter dated January 17, 1995, to Mr. William T. Russell (NRC) identified the status of ampacity derating. As identified in the CP&L letter dated December 19, 1994, CP&L believes the scope of this item will be enveloped by the NEI program for ampacity derating. Any further evaluation will be performed upon completion of the NEI testing.

ENCLOSURE TO NLS-95-036 (9) Mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength.

CP8cL plans to pursue either the elimination of the need for the seismic qualification of the existing Thermo-Lag fire barriers or provide additional means of protection for adjacent safety-related equipment from the potential failure of the fire barrier. As a third option, CPEcL may implement a program to independently verify the mechanical properties that were based upon TSI information through testing and/or analysis. The impact of the weight, from Item l.a.(3) above, is being reviewed in the seismic evaluation.

Completion of one or more of the three options willbe incorporated into the Thermo-Lag resolution scheduled for completion by the end of Refueling Outage No. 7, currently scheduled to commence in May 1997. CP8cL will provide an update of this review process and our preliminary approach to resolving any mechanical properties concern with the Thermo-Lag fire barriers by August 31, 1995.

NRC Request 1.b. Describe the methodology that will be used to determine the sample size and demonstrate that the sample size willbe large enough to ensure that the information and data obtained willbe sufficient to assess the total population of in-plant Thermo-Lag barriers and the materials that willbe installed in the future. In determining the sample size, consider the time of installation and manufacture of the various in-plant materials and barrier installations. Give the number and types (e.g.,panels, conduit preshapes, trowel-grade material, stress skin) of samples that will be tested or analyzed.

CPAL Response (1) Chemical Composition Given that the chemical composition testing performed to date has not identified chemical or performance variations, NEI believes that chemical analysis of a small number of samples from each plant should provide reasonable assurance of the consistency of Thermo-Lag material. Use of a generic pool of samples will cover a larger population of lot numbers and provide assurance of material consistency, while minimizing the number of samples necessary per individual plant.

ENCLOSURE TO NLS-95-036 The NEI guidance identified that a single sample should be taken for each of the following product forms to the extent they are used in each plant's installations:

1. Three-hour rated pre-formed conduit sections

2. One-hour rated pre-formed conduit sections

3. Three-hour rated panels

4. One-hour rated panels

5. Trowel grade material In accordance with the NEI guidance, SHNPP has submitted to the testing lab one sample from one-hour rated panels and two samples from trowel grade material taken from field installations. These samples represent the materials used in the area enclosure, the partial height fire wall and the door transom and mullion installations. The conduit sections were not included in this testing since SHNPP does not plan to maintain credit for those installations.

The results of these tests will be compared to the NEI and CP&L fire test materials to determine if~the samples are chemically bounded by the NEI fire test program. Preliminary test results demonstrate that the samples are similar to the NEI test results. A final report is still under development.

(2) Material Thickness As described in CP&L's December 19, 1994 letter, a material thickness measurement sampling program for the area enclosure is being performed in accordance with the methodology of ASTM E605-93. The thickness measurement program will also be applied to the partial height wall fire barrier. Given the limited total area of fire barriers, CP&L has increased the number of samples over that prescribed by the ASTM Standard to ensure that a statistically significant population is obtained to ensure an appropriate confidence level. A statistical analysis will be performed on the results to ensure the area enclosure is bounded by the joint utility testing described in our response dated December 19,1994.

As described in CP&L's December 19,1994 letter, Thermo-Lag applied to the door transoms and mullions willbe evaluated in accordance with the guidance provided in Generic Letter 86-10. CP&L will verify, as necessary, the attributes required to perform the re-evaluation.

(3) Material Weight and Density No additional testing is planned unless chemical composition testing of material installed in the industry demonstrates material consistency problems.

ENCLOSURE TO NLS-95-036 (4) Presence of Voids, Cracks, and Delaminations Not applicable; refer to Section 1.a.(4)

(5) Fire Endurance Capabilities (6) Combustibility (7) Flame Spread Rating (8) Ampacity Derating, Verification of Items 5 through 8 is not done through sampling programs since generic or site specific testing will establish bounding conditions.

(9) Mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength.

Pursuant to the response to Item l.a.(9) above, the need for or type of sampling has not yet been determined.

NRC Request 1.c. Submit the schedule for verifying the Thermo-Lag materials.

COL Response 1.c Testing for chemical composition, material thickness, and fire endurance capabilities is expected to be completed by December 31, 1995. No tests or analyses are planned for voids, cracks and delaminations. Tests and analyses for combustibility, flame spread ratings, and ampacity derating are being addressed through generic industry testing being performed by NEI. CP8cL will provide an update for material weight and mechanical properties by August 31, 1995.

ENCLOSURE TO NLS-95-036 Section 2. Im ortant Barrier Parameters NRC Request 2.a. Describe the examinations and inspections that will be performed to obtain the important barrier parameters given in Section II of the RAI of December 1993 for the Thermo-Lag fire barrier configurations installed at SHNPP.

CPAL Response 2.a CPSs letter dated December 19, 1994 stated that the listing of important parameters, with the exception of material thickness which is discussed in Section 1.a.(2) above, was not applicable to the SHNPP area enclosure due to the specific nature of the installation. This statement also applies to the partial height fire wall installation. CPS'lso stated that joint utility testing was being performed, to establish the bounding conditions associated with our plant specific configurations.

The portions of this program applicable to SHNPP will be completed by December 31, 1995. Once the testing program is complete, an evaluation of the test results will be performed to determine if other important parameters require field verification.

Thermo-Lag applied to the door transoms and mullions will be evaluated in accordance with the guidance provided in Generic Letter 86-10. CPAL will verify, as necessary, the attributes required to perform the re-evaluation.

NRC Request 2.b. Describe the methodology that willbe applied to determine the number and type of representative in-plant fire barrier configurations that willbe examined in detail and demonstrate that the sample size is adequate to ensure that the information and data that willbe obtained are adequate to assess the total population of in-plant Thermo-Lag barriers. A large enough sample of the total population of configurations should be examined to provide reasonable assurance that the materials and important barrier parameters used to construct the in-plant barriers and any future barrier installations or modification, are representative of the parameters used to construct the fire endurance test specimens.

COL Response 2.b Refer to Section 1.b.(2).

I

'I t

ENCLOSURE TO NLS-95-036 NRC Request 2.c. Submit the schedule for obtaining and verifying all of the important barrier parameters.

CPRL Response 2.c As stated in CPS'etter dated December 19, 1994, the completion of the overall Thermo-Lag issue, which includes verifying the important barrier parameters, willbe accomplished by the end of Refueling Outage No. 7, currently scheduled to commence in May 1997.

P