ML18064A588
| ML18064A588 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/24/1995 |
| From: | Haas K 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 9501310186 | |
| Download: ML18064A588 (6) | |
Text
consumers Power POWERING MICHIGAN'S PROGRESS Palisades Nuclear Plant: 27780 Slue Star Memorial Highway, Covert. Ml 49043 January 24, 1995 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50.255 -
LICENSE DPR PALISADES PLANT FOLLOWUP TO REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, ISSUED PURSUANT TO 10 CFR 50.54(F), PALISADES PLANT (TAC NO. M85582)
By letter dated December 29, 1994, the NRC requested that Consumers Power Company provide additional _information regarding test and analysis of the Thermo-Lag 330-1 raceway fire barriers installed at the Palisades Plant.
Specifically, the NRC requested description of specific tests and analysis that would verify the Thermo-Lag fire barrier materials currently installed.
At this time all Thermo-lag 330-1 fire barriers have been declared inoperable and appropriate compensatory measures are being taken.
As stated in our *1etter to the NRC dated February 10, 1994, our plan is to remove the material in the next two refueling outages after that date.
At that time, the second refuelin~~utage was scheduled for 1996.
The schedule now calls for the second refueling outage to occur in 1997.
our response to the NRC request for additional information is provided in the attachment to this letter.
9501310186 950124 PPDR ~ ADOCK 05000255 PDR A CMS ENERGY COMPANY
~\\
... I CONSUMERS POWER COMPANY To the best of my knowledge, the information contained in this document concerning the testing and analysis of the Thermo-lag 330-1 raceway fire barriers installed at the Palisades Plant is truthful and complete.
By Robert A. Fenech, Vice President Nuclear Operations
/]
Sworn and subscribed to before me this o/Lf+-/\\
1995.
day of
~tlfrnlL
~tu-tuJ Norma J Fowler, Notary Public Van Bur County, Michigan My commission expires May 14, 1998
[SEAL]
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO NRC FOLLOWUP TO THE REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, ISSUED PURSUANT TO 10 CFR 50.54(F)
PALISADES PLANT {TAC NO. M85582)
January 16, 1995
p
~.
e 1
NRC Item 1, Thermo-Lag Materials
- 1.
Thermo-Lag Materials
- 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 Palisades, 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 the attributes that were determined or controlled by TSI during the manufacturing process and the quality assurance program.
The test 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.
- b.
Describe the methodology that will be used to determine the sample size and demonstrate that the sample size will be large enough to ensure that the information and data obtained will be sufficient to assess the total population of in-plant Thermo-Lag barriers and the materials that will be 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.
- c.
Submit the schedule for verifying the Thermo-Lag materials.
~ -
- d.
After analyses and tests have been completed, submit a written supplemental report that confirms that this effort has been completed and provide the results of the tests and analyses.
Describe any changes to previously submitted plans or schedules that result from the tests or analyses.
CPCo Response Thermo-Lag 330-1 preformed panels and conduit shapes were installed to protect small conduit or circuits to provide either 1 or 3-hour fire barriers in the 1-C switchgear room, component cooling water room and intake structure.
The Thermo~Lag fire barrier material has been declared inoperable and hourly fire tours have been initiated pursuant to Palisades Technical Specification 3.22.5.1.
2 Palisades plans to remove all Thermo-Lag currently installed at Palisades.
Conduits I159 and I147 are to be replaced with 1-hour fire rated cable by December 31, 1995.
Conduit X1885 and its associated pull (junction) box are to be embedded in concrete also by December 31, 1995. The Conduit X2402 and its associated pull (junction) box is to be re-routed outside the component cooling room.
This was scheduled for completion by the end of the 1996 refueling outage.
Because no refueling outage will occur in 1996, this action will be completed during the 1997 refueling outage.
CPCo does not plan to conduct tests of the Thermo-Lag material to justify its continued use.
NRC Item 2, Important Barrier Parameters
- 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 Palisades.
CPCo Response In a letter to the NRC dated February 10, 1994, Palisades responded that current plans were to remove all Thermo-Lag currently installed at Palisades.
However, based on the results of NUMARC (now the Nuclear Energy Institute, NEI) Phase 2 testing and planned expanded generic test program, Palisades could have changed the plan.
The results of the NEI's Phase 2 testing did not justify, for Palisades systems, the upgrading of currently installed Thermo-Lag, nor its return to operable status.
Therefore, Palisades will not be performing examinations and
inspections to obtain the important barrier parameters requested in Section II of the RAI of December 1993.
NRC Item 2.b, C, and d.
- b.
Describe the methodology that will be applied to determine the number and type of representative in-plant fire barrier configurations that will be examined in detail and demonstrate that the sample size is adequate to ensure that the information and data that will be obtained are adequate to assess that 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 the materials and important barrier parameters used to construct the in-plant barriers and any future barrier installations or modifications, are representative of the parameters used to construct the fire endurance test specimens.
- c.
Submit the schedule for obtaining and verifying all of the important barrier parameters.
3
- d.
After the information has been obtained and verified, submit a written supplemental report that confirms that this effort has bee completed and provides the results of the examinations and inspections. Verify that the parameters of the in-plant configurations are representative of the parameters of the fire endurance test specimens.
Describe any changes to previously submitted plans or schedules that result from the examinations.
CPCo Response Since Palisades is removing Thermo-Lag from its systems and no testing of the material is going to be performed, the important barrier information will not be obtained.