ML18059A675

Forwards Request for Addl Info Re GL 92-08, Thermo-Lag 330-1 Fire Barriers, Per 10CFR50.54(f)

ML18059A675
Person / Time
Site:	Palisades
Issue date:	02/10/1994
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-92-08, GL-92-8, TAC-M85582, NUDOCS 9402180278
Download: ML18059A675 (10)

Text

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'.. i consumers Power

~-., l'OWERINli MICHlliAN"S l'ROliRESS Palisades Nuclear Plant:

27780 Blue Star Memorial Highway, Covert, Ml 49043 February 10, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 FIRE BARRIERS, PURSUANT TO 10 CFR 50.54(f) PALISADES PLANT (TAC NO. M85582)

By letter.dated December 21, 1993, the NRC requested that Consumers Power Company provide additional information regarding the Thermo-Lag 330-1 raceway fire barriers installed at the Palisades Plant. Specifically,. the NRC requested additional information on the configurations and amounts of Thermo-Lag fire raceway barriers installed in the plant and the cable loadings within particular Thermo-Lag configurations.

The NRC also requested, for those configurations that are outside the scope of the program or for those configurations that CPCo deemed impractical to upgrade, that we provide plans and schedules for resolving the technical issues identified in GL 92-08.

Our response to the NRC's request for additional information is provided in the attachment to this letter.

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Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 9402iB0278 940210 PDR :ADOCK 05000255 p

PDR 1 G.nn.~ *J I,,, *J'*!J:.._.

A CMS' ENERGY COMPANY I

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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 RACEWAY FIRE BARRIERS, PURSUANT TO 10 CFR 50.54(f)"

PALISADES PLANT (TAC NO. M85582) 7 Pages

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 RACEWAY FIRE BARRIERS, PURSUANT TO 10 CFR 50.54(f)"

PALISADES PLANT (TAC NO. M85582)

February 10, 1994 7 Pages

1 NRC Item I.B, Thermo-Lag Fire Barrier Configurations and Amounts

1. Describe the Thermo-Lag 330-1 barriers installed in the plant to

a. meet 10 CFR 50.48 or Appendix R to 10 CFR Part 50,

b. support an exemption from Appendix R,

c. achieve physical independence of electrical systems,

d. meet a condition of the plant operating license,

e. satisfy licensing commitments.

The descriptions should include the following information:

the intended purpose and fire rating of the barrier (for example, 3-hour fire barrier, 1-hour fire barrier, radiant energy heat shield), and the type and dimension of the barrier (for example, 8-ft by 10-ft wall, 4-ft by 3~ft by 2-ft equipment enclosure, 36-inch-wide cable tray, or 3-inch-diameter conduit}.

CPCo Response

1.

The Thermo-Lag 330-1 Raceway Fire Barriers are installed in the Palisades Plant to meet Appendix R to 10CFRSO requirements.

These installations consist of the following:

a.

Conduit 1159, approximately forty feet of 2-inch-diameter electrical metallic tubing (EMT) located in the Screen House (intake structure), protected by 1-hour rated pre-shaped conduit halves.

b.

Conduit 1147, approximately one hundred feet of 1%-inch-diameter EMT and air drop located in the Screen House (intake structure),

protected by 1-hour rated pre-shaped conduit halves.

c. Conduit X1885, approximately four feet of 3-inch-diameter galvanized rigid steel (GRS) and its associated pull (junction) box located in the 1-C Switchgear Room, protected by 1-hour rated pre-shaped conduit halves and a box (approximately 16-inches by 16-inches) of pre-formed panel construction.

d.

Conduit X2402, approximately thirty feet of 1%-inch-diameter GRS and its associated pull (junction) box located in the Component Cooling Water Room, protected by 3-hour rated pre-shaped conduit halves and a box (approximately 6-inches by 12-inches) of pre-formed panel construction.

2. For the total population of Thermo-Lag fire barriers described under Item I.8.1, submit an approximation of:

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a. For cable tray barriers: the total linear feet and square feet of 1-hour barriers and the total linear feet and square feet of 3-hour barriers.

b. For conduit barriers: the total linear feet of 1-hour barriers and the total linear feet of 3-hour barriers.

c. For all other fire barriers: the total square feet of 1-hour barriers and the total square feet of 3-hour barriers.

d. For all other barriers and radiant energy heat shields: the total linear or square feet of 1-hour barriers and the total linear or square feet of 3-hour barriers, as appropriate for the barrier configuration or type.

CPCo Response

2.

For the total population of Thermo-Lag fire barriers described under Item I.B.l, submit an approximation of:

a.

N/A - No cable tray barriers at Palisades.

b.

For conduit barriers: The total linear feet of I-hour barriers is approximately 144 and the total linear feet of 3-hour barriers is approximately 30.

c.

N/A - No other Thermo-Lag barriers at Palisades.

d.

N/A - No other Thermo-Lag barriers or radiant energy heat shields at Palisades.

NRC Item II.B, Important Barrier Parameters

1. State whether or not you have obtained and verified each of the aforementioned parameters for each Thermo-Lag barrier installed in the plant. If not, discuss the parameters you have not obtained or verified.

Retain detailed information on site for NRC audit where the aforementioned parameters are known.

2. For any parameter that is not known or has not been verified, describe how you will evaluate the in-plant barrier for acceptability.

3. To evaluate NUMARC's application guidance, an understanding of the types and extent of the unknown parameters is needed.

Describe the type and extent of the unknown parameters at your plant in this context.

CPCo Response Palisades currently plans to remove all Thermo-Lag currently installed at Palisades.

However, based on the results of NUMARC Phase 2 testing and the planned expanded generic test program, we may change this plan.

Any changes to the plan to remove all the Thermo-Lag will be communicated to the NRC in a supplemental response. Specific answers to verify the eight parameters of importance listed in Item II.A would then be provided in any forthcoming supplemental response.

NRC Item III.B, Thermo-Lag Fire Barriers Outside the Scope of the NUMARC Program

1. Describe the barriers discussed under Item I.B.1 that you have determined will not be bounded by the NUMARC test program.

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2. Describe the plant-specific corrective action program or plan you expect to use to evaluate the fire barrier configurations particular to the plant.

This description should include a discussion of the.evaluations and tests being considered to resolve the fire barrier issues identified in GL 92-08 and to demonstrate the adequacy of existing in-plant barriers.

3. If a plant-specific fire endurance test program is anticipated, describe the fo11owing:

a. Anticipated test specimens.

b. Test methodology and acceptance criteria including cable functionality.

CPCO Response to Item III.B.I.

I. a.

Conduit II59, approximately forty feet of 2-inch-diameter EMT located in the screen house (intake structure), protected by I-hour rated pre-shaped conduit halves is not bounded by NUMARC Test No. I-6 as the test is an upgraded configuration.

b.

Conduit II47, approximately one hundred feet of Ii-inch-diameter EMT and air drop located in the screen house (intake structure), protected by I-hour rated pre-shaped conduit halves is not bounded by NUMARC Test No. _I-6 or No. I-4 as these tests are both upgraded configurations.

c. Conduit XI885 and its pull (junction) box, approximately four feet of 3-inch-diameter GRS located in the I-C Switchgear Room, protected by I-hour rated pre-shaped conduit halves and a box of preformed panels is not bounded by NUMARC Test No. I-6 as the test is an upgraded configuration.

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d.

Conduit X2402, approximately thirty feet of I~-inch GRS and its associated pull (junction) box located in the Component Cooling Water Room, protected by 3-hour rated pre-shaped conduit halves.and preformed panels is not bounded by NUMARC Test No. I-6 as the test is an upgraded configuration.

For all of the installed configurations described in response to information requested in 111.B.I. above, it should be noted that while the scope of the test program is known, what will ultimately be bounded is a function of the outcome of the tests and the final outcome of the application guide.

Therefore, a supplemental response may be provided after taking into consideration the results of both the Phase 2 testing and the planned expanded generic test program.

2. a.

The Palisades specific corrective action plan tentatively proposed for conduit II59 is to remove the existing Thermo-Lag barrier and replace the protected circuits with I-hour fire rated cable.

b.

The Palisades specific corrective action plan tentatively proposed for conduit II47 is to remove the existing Thermo-Lag barrier and replace the protected circuit with I-hour fire rated cable.

c.

The Palisades specific corrective action pl~n tentative~y proposed for conduit XI885 and its associate pull (junction) box is to remove the existing Thermo-Lag barrier and embed this conduit and pull (junction) box in concrete.

d.

The Palisades specific corrective action plan tentatively proposed for conduit X2402 and its associated pull (junction} box is to remove the existing Thermo-Lag Barrier and re-route the protected circuits outside of the component cooling water room.

The corrective action plans indicated above in response to required information requested in 111.B.2. are tentative. A supplemental response changing one or all of the proposed corrective actions above will be provided if other more effective alternatives, which may be based upon the outcome of Phase 2 testing and the expanded test program, are undertaken.

3. No Palisades specific fire endurance test program is anticipated at this time.

However, if warranted, based upon Phase 2 testing and the expanded generic test program, a supplemental response may be submitted.

NRC Item IV.B, Ampacity.Derating

1. For the barriers described under Item 1.8.1, describe those that you have determined wi77 fa77 within the scope of the NUMARC program for ampacity derating, those that wi77 not be bounded by the NUMARC program, and those for which ampacity derating does not apply.

2. For the barriers you have determined fall within the scope of the NUMARC program, describe what additional testing or evaluation you will need to perform to derive valid ampacity derating factors.

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3. For the barrier configurations that you have determined will not be bounded by the NUMARC test program, describe your plan for evaluating whether or not the ampacity derating tests relied upon for the ampacity derating factors used for those electrical components protected by Thermo-Lag 330-1 (for protecting the safe-shutdown capability from fire or to achieve physical independence of electrical systems) are correct and applicable to the plant design. Describe all corrective actions needed and submit the schedule for completing such actions.

4. In the event that the NUMARC fire barrier tests indicate the need to upgrade existing in-plant barriers or to replace existing Thermo-Lag barriers with another fire barrier system, describe the alternative actions you will take (and the schedule for performing those actions) to confirm that the ampacity derating factors were derived by valid tests and are applicable to the modified plant design.

Your response to Section IV.B may depend on unknown specifics of the NUMARC ampacity derating test program (for example, the final barrier upgrades).

However, your response should be as complete as possible.

In,addition, your response should be updated as additional information becomes available on the NUMARC program.

CPCO Response

1. Based upon our tentative corrective action plan, ampacity derating for Thermo-Lag Barriers does not apply.

2. N/A - Based upon 1 above.

3. N/A - Based upon 1 above.

4. As described in our response to NRC Item 111.B.2, CPCO plans to remove all installed Thermo-Lag and either replace the protected cables with a I-hour rated cable, embed the protected cable in concrete, or relocated the protected cable out of the postulated fire area. Configuration specific cable ampacity with derate, if necessary, will be evaluated as part of the design change ~ngineering. -

If the tentative corrective action plan for Palisades is changed, our response to Section IV will be revised in a supplemental submittal.

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NRC Item V.B, Alternatives Describe the specific alternatives available to you for achieving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers. Examples of possible alternatives to Thermo-Lag-based upgrades include the following:

1. Upgrade existing in-plant barriers using other materials.

2. Replace Thermo-Lag barriers with other fire barrier materials or systems.

3. Reroute cables or relocate other protected components.

4. Qualify 3-hour barriers as 1-hour barriers and install detection and suppression systems to satisfy NRC fire protection requirements.

CPCO Response See Palisades response to Section III.B.2.

NRC Item VI.B. Schedules Submit an integrated schedule that addresses the overall corrective action schedule for the plant. At a minimum, the schedule should address the following aspects for the plant:

1. implementation and completion of corrective actions and fire barrier upgrades for fire barrier configurations within the scope of the NUMARC

program,

2. implementation and completion of plant-specific analyses, testing, or alternative actions for fire barriers outside the scope of the NUMARC program.

CPCO Response I. Palisades plans to implement the following schedule to resolve Thermo-lag issues unless changes are warranted based upon Phase 2 testing and the proposed expanded generic test program.

a.

Conduit II59 - Remove Thermo-lag and replace cable with I-hour fire rated cable by December 3I, I995.

b.

Conduit II47 - Remove Thermo-Lag and replace cables with I-hour fire rated cables by December 3I, I995

c. Conduit Xl885 and associated pull (junction) box - remove Thermo-Lag, and embed conduit and pull (junction) box in concrete by December 31, 1995.

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d.

Conduit X2402 and associated pull (junction) box - remove Thermo-Lag and reroute cables to avoid the component cooling water room by the end of the 1996 Refueling outage.

Because of the uncertainties noted during discussions between the industry (NUMARC) and the NRC staff and management on this issue, a more specific schedule cannot be provided.

The potential impact of Phase 2 testing and additional generic testing if undertaken may cause the Palisades plan and schedule to change.

NRC Item VII.B. Sources and Correctness of Information Describe the sources of the information provided in response to this request for information (for example, from plant drawings, quality assurance documentation, walk downs or inspections) and how the accuracy and validity of the information was verified.

CPCO Response The information provided in this response was developed from plant drawings, modification packages, the circuit and raceway schedule, and surveillance documents.

It was verified by plant walkdowns and inspections.