ML18065A815
| ML18065A815 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/12/1996 |
| From: | Gamberoni M NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9607150140 | |
| Download: ML18065A815 (8) | |
Text
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UNITED STATES
- NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-<<>01 July 12, 1996
SUBJECT:
SUMMARY
OF JUNE 13, 1996, MEETING BETWEEN NRC STAFF.AND NUCLEAR ENERGY INSTITUTE REPRESENTATIVES ON NEI APPLICATION GUIDE TO EVALUATE THERMO-LAG FIRE BARRIERS A meeting was held at U. S. Nuclear Regulatory Co11111ission (NRC) Headquarters on June 13, 1996, between the Nuclear Energy Institute (NEI) and the NRC to discuss the latest revision to the NEI Thermo-Lag Application Guide. A list of attendees is provided as Attachment 1. Attachment 2 is the handout provided by NEI at the meeting.
BACKGROUND The application guide was developed by NEI to assist licensees with the evaluation of plant installed Thermo-Lag fire barriers. The guide has been discussed with the staff on several occasions including a March 16, 1994, working level meeting and a July 26, 1994~ senior management meeting.
In an
- October 16, 1995, letter to NE I, the NRC staff doqamented a number of concerns and coinments regarding the guide.
In an attempt tQ address the staff's concerns and to include phase 3 of the NEI-sponsored Thermo-lag test program, NEI submitted to the NRC staff Revision 2 of the Application Guide on March 12, 1996..
PRESENTATION/DISCUSSION After a brief summary regarding the process for returning to regulatory compliance, NEI presented the changes that it made to the guide to address NRC comments.
Speciific areas of discussion included thermocouple placement, smal'l conJuiL~ bou~Jlfi~ l*arge conduits, small junction boxes bounding large junction boxes, use of the guide as an alternative to Generic Letter (GL) 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains within the Same Fire Area,* structural support protection and hose stream test results~ A sUB11Jar.y of each of these discusstons is presented below.
Thermocouple Placement
. The staff stated that the use of temperature data for cable functionality evaluations from test assemblies that did not utilize the thermocouple placement criteria specified in Supplement 1 to GL 86-10, specifically the absence of a #8 bare copper conductor routed along the bottom of cable tray assemblies, may result in a nonconservative analysis. The staff informed *NEI that the technical bases could be found in a safety evaluation that it issued to TU Electric on May 22, 1996.
Licensees should not use generic industry fire test results for cable functionality evaluations where the temperature data from the #8 bare conductor routed along the bottom of the tray was not provided.
NEI stated that it would consider revising its guide to reflect this technical position.
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2 July 12, 1996 Small Diameter Conduits Bounding large Diameter Conduits The staff stated that the small differences in maximum temperatures recorded during tests for different sized conduits does not provide a sufficient technical basis to conclude generically, that the fire endurance performance of similar barrier assemblies protecting small conduits bounds the performance of larger conduits.
The staff stated that licensees should continue to utilize test data that bounds the largest and smallest conduit diameters for
, their actual plant configuration in their engineering evaluations.
NEI stated that it would consider revising its guide to reflect this technical position.
Small Junction Boxes Bounding large Junction Boxes The staff' stated that the total enclosed thennal mass*and size are not the only fact'ors important in evaluating the perfonnance of fire barrier assemblies protecting junction boxes.
The structural stresses on the fire
.barrier assembly that contribute to the failure of the assembly are dependent upon the orientation and dimensions of the test assembly.
licensees should consider the junction box orientation and maximum dimensions of the assembly
.in their engineering evaluations. Ntl stated that it would consider revising its guide to reflect this technical position.
Structural Support Protection The staff stated that in evaluating the fire endurance performance of
. electrical raceways protected with fire barrier enclosures, licensees should consider the fire endurance of raceway structural supports and ensure that the supports have a fire endurance equal to or greater than the protective assembly~ The current revision of the NEI guide is consistent with this staff position.
Hos~ Stream Result~*
.The staff stated that in order for a fire barrier assembly to meet NRC
- requirements, the assembly mu'st pass both a 'fire endurance test and a hose stream test.
To use a test assembly that deviated from the hose stream acceptanc'e criteria, licensees should prepare an engineering evaluation to provide a technical basis regarding the acceptabHity of the application of the devi~ting test assembly to the actual plant configuration.
NEI stated that it would consider revising its guide to reflect this technical position.
Use of the.Guide as an Alternative to Generic letter 86-10 Suop. l The staff stat~d that, in general, licensees can use either the test methods and acceptance criteria specified in either GL 86-10 or Supplement l to Gl 86-10 to determine the adequacy of fire barrier systems installed to satisfy N~C fire protection requirements. This decision depends on licensing commitments and the method implementation specified in the individual Gls.
(Note:
Supplement l to Gl 86-10 stated, in part, that n[t]his guidance will be used by the staff to review and evaluate the adequacy of fire endurance tests and fire barrier systems proposed by licensees or applicants in the future to satisfy existing NRC fire protection rules and regulations. This
3 July 12, 1996 guidance refines an~ clarifies the fire barrier testing acceptanca criteria specified by GL 86-10, for application in that specific (future review) context~"- The staff wrote in the "future review" criterion because it wanted to make it clear that it was not backfitting the guidance on existing in-plant fire barriers for which the industry did not have technical evidence that the barriers could not achieve their intended fire resistance design function.
At that time, the staff and industry had compelling technical evidence that Thermo-Lag fire barriers could, not achieve their intended design function. _
Therefore, it was the staff's intent that the guidance of GL 86-10, Supplement 1, would apply to upgrades of Thermo-Lag fire barriers since they would.be installed after March 25, 1994.) Licensees may also propose alternative test methods and/or acceptance criteria to demonstrate an equivalent level of protection. The staff noted that certain aspects of the NEI application guide (discussed ~bove) and some of the test results documented in the guide deviate from the guidance of both GL 86-10 and Supplement 1 to GL 86-10. Therefore, licensees that choose to use the application guide may need to develop plant-specific justifications for the deviating conditions.
SUMMARY
The staff reaffirmed its position that it would not approve the NEI guide as a generically acceptable alternative to either Supplement 1 to GL 86-10 or the previous staff guidance regarding fire endurance testing provided in GL 86-10.
The staff stated that it is not aware of any de-lay in the implementation of a licensee's Thermo-Lag corrective action plan due.to the lack of NRC staff approval of the NEI guide.
Revision 2 to the Application G~ide satisfactorily resolved the issues concerning junction boxes, structural steel, and use of the guide to address actual plant fire hazards. A number of issues are outstanding pending NEI consideration. Specifically, NEI agreed to look at the bounding of larger conduits with smaller conduits, hose stream test
- performance, and use of cable tray test data for cable functionality_
evaluations without the #8 bare copper_conductor information.
The guidance contained in Supplement 1 to GL 86-10 applies to fire tests and fire barrier systems, including upgrades of existing barriers, proposed by licensees after March 25, 1994, to meet NRC requirements.
For fire tests conducted prior to the issuance of Supplement 1 to GL 86-10, and for existing fire barrier assemblies, licensees may select either the guidance provided in Supplement 1 to GL 86-10 or the fire endurance testing criteria contained in GL 86-10 to meet NRC fire protection requirements.
As an alternative to the generic staff guidance, licensees may also propose a plant-specific alternative. The NRC staff wi 11 review such proposals on a case-by-case basis. This was the case for Comanche Peak, Units 1 and 2, for which the staff approved ~n alternative testing and lCCeptance criteria in its letter to TU Electric of October 29, 1992.
In correspondence (for example a letter of November 15, 1995) and during the meeting, NEI stated that Supplement 1 to GL 86-10 did not apply to the NEI fire test program.
In response, the staff noted that the testing and acceptance criteria specified in Supplement 1 to GL 86-10 was provided to the Nuclear Management and Resources Council *(NUMARC), the predecessor to NEI, in draft, at a meeting with the NRC staff on November 19, _1992.
After the
NAME.
fd C0nnell Steve West Ledyard Marsh Patrick Madden Mani Dey Marsha Gamberoni Cal Banning.
Alex Marion Biff Bradley George Wu Greg Schmalz Tom* Gorman Richard Barth
- Charles Bruce Brian Melly Teresa Sutter Steve Katradis Paul Gunter MEETING ATTENDEES
~
JUNE 13, 1996 AFFILIATION NRC NRC NRC NRC-
-- NRC NRC Vectra NEI NEI NEI Darchem Engrg PP&L GPU Nuclear PECO Triad Bechtel NUS CORP NIRS ATTACHMENT 1
. '.~
I...
(:.7126/19941 Starting
- ***Point
- Ope"41 License/Defense In Depth Analyses Licensing Update SSC Fire Huards Basis Analysis Analysis
\\...........................................................
Remove or Retire in Place Evaluation of Application Guide (Thermo-Lag)
- Perfonnance Analyses Additional Testing/
Analysis COMPLIANCE/RESOLUTION ALTERNATIVES Reroute SSDCkts.
Remove/
Replace With Alt. Mafl Upgrade Thenno-l.ag Regulatory Compliance Enhance Defense in Depth Measures Exemption/
Deviation ATTACHMENT :2
- /
- Application Guide
- NRC Comments:
- Hose stream results
- Thermocouple placement
-. Small conduits bounding large conduits
- Small jun.ction boxes bounding
- large junction boxes
-. Stfllctural support protection.*
. -. Use of guide to address actual
.
- plant hazards
- _* Use as alternative to GL 86~1os*1
- I
.. Application Guide
- Revision 1 Appendix D provided technical bases for *
- *.* hose stream and thermocouple..
conclusions
- Rev-isio11 2 includes additional information to address NRC comments**
'Ii-*
4 July 12, 1996
- J<'\\~Y I.'< meeting w1th NE!, the !aff noted that this information *was.included in the NUMARC Test Plan No. 72192-A, Revision: 5-, dated July 1993.
However, it was not followed, in its -entirety, in the fire test program that was initiated by NUMARC in September 1993.
Fire barrier test programs conducted by the Florid~ Power Corporation, _Tennessee Valley Authority, and Commonwealth Edison have followed the guidance provided in Supplement 1 'to GL 86-10.
If there are any question~ r;egarding this meeting summary, contact Marsha Gamberoni at (301) 415-3024hor Edw~rd Connell *at (301) 415-2838.
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Marsha Gambe'roni *! Prbjec't Manager
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- 'Office of" Nuci'ear ~Reactor Regulation
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Attachments:
As stated {2).~::**
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