ML20034D508
| ML20034D508 | |
| Person / Time | |
|---|---|
| Site: | 07000832 |
| Issue date: | 12/18/1992 |
| From: | Marquardt J MINNESOTA MINING & MANUFACTURING CO. (3M CO.) |
| To: | Archizel R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9212280019 | |
| Download: ML20034D508 (4) | |
Text
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l Office of General Counsel i
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Merritt R. Marquardt l
Senor counsea December 18, 1992 Mr. Ralph Archizel Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.
20555 Re: Public Meeting on January 7, 1992 1
Dear Mr. Archizel:
1 i
letter to the Nuclear Regulatory Commission (NRC) l In a l
dated November 17,1992, Mr.
Richard Licht of 3M's Ceramic Materials Department requested an opportunity for 3M to review with the NRC issues relating to the revision of test procedures applicable to fire barrier products used by the commercial nuclear power industry.
The date of January 7, 1993 was established for such a meeting.
It is my understanding that you have requested 3M to provide a proposed agenda for the meeting.
As a part of such an agenda, the following outline sets forth various statements of fact regarding the current fire barrier test situation, and then poses questions of concern to 3M regarding the revisions to the testing standards and protocol.
These questions and the NRC's response are of vital concern to the commercial nuclear power industry and its fire barrier suppliers.
It is clear that the underlying issue relating to all of these questions concerns the use of a
product which will insure l
protection of the public health and safety.
3M is l
committed to be a participant in this business, and to be involved in the test standard review proceedings, because of its concern that the commercial nuclear power industry maintain the trust and confidence of the public.
The proposed agenda is as follows:
AGENDA I.
Introduction l
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II.
I Statement of Purpose for the Meeting III.
Historical Background of 3M Participation in Commercial Nuclear Power Industry IV.
Issues
[1] 3M has during the period 1981 to the present provided fire barrier product for 29 utility installations located throughout the country.
These installations were all accepted for plant l
operation.
Ouestion:
Do the letters of acceptance and license to operate issued by the NRC covering these installations remain valid?
If not,
~
why not?
[2] 3M fire barrier product has over the years been continuously tested to American Nuclear Insurers (ANI) standards, as adopted by the NRC, and by test facilities such as UL, Southwest Research Institute, CSTB in France, and Certified Testing Laboratories (CTL).
Unlike the in-house testing practice and procedure of some manufacturers, 3M's product testing was conducted in its facilities under procedures correlated with UL and Factory Mutual Insurance standards, resulting in a 3M product classified and approved by these organizations.
Question:
Does the NRC accept tests conducted under the above procedure and witnessed, approved and certified by Twin City Testing, a nationally recognized testing
- service, to be valid confirmation of the basic tests and criteria originally established for 3M product at UL and SWRI?
[3]
3M has over the years accumulated a
substantial body of data based upon use of a
specified 12 inch spacing of thermocouples during fire tests, as directed by ANI.
Current testing procedures now indicate a
6 inch spacing requirement.
It is 3M's intent to conduct all future testing in accordance with this revised procedure.
Archizel 18-92 2
l Ouestion:
Does the NRC accept the validity of previously developed data generated at the j
manufacturers expense in accordance with the established 12 inch standard?
[4]
Previously established test protocol and performance criteria placed emphasis on product capability with respect to specified areas of vital concern to public health and
- safety, including combustibility,
- toxicity, seismic performance,
- weight, and ampacity derating.
Current efforts to re-evaluate test criteria are focused on product fire performance.
Question:
Does the NRC intend to establish as part of the current test re-evaluation program an equal emphasis on all of the above areas of product performance relating to health and safety issues:
now and when will Wese areas of concern be addressed in order to enable manufacturers to respond to customer demands for qualified product?
[5]
The original NRC test standard for non-combustibility was ASTM E84.
In the current test re-evaluation process the NRC has indicated that standard ASTM E136 will now apply.
At the NRC public meeting on November 19, 1992, it was stated by NRC representatives that standard E136 would be interpreted to mean a product equivalent in non combustibility to fire rated gypsum board.
i Ouestion:
Will the E136 standard as defined in the November 19 meeting be applied against all existing installations regardless of manufacturer?
[6] The hose stream requirements of standard NFPA
- 251, ASTM E119 and ASTM E814 have long been recognized as providing the mechanical means of determining fire barrier product performance with respect to thermal shock, effects of erosion, and the ability to resist mechanical abuse.
The new test protocol allows for fog nozzle testing in lieu of the solid stream test.
Question:
What is the basis upon which the substitute fog nozzle test has been determined to provide equivalent test results regarding these critical product performance characteristics.
Archizel 18-92 1
3 i
[7] At the present time there are fire barrier systems of either one hour or three hour performance duration at the various utility plant locations.
These systems have been provided by one or the other of several manufacturers.
Question:
Does the NRC intend that both systems are subject to the entire revised testing protocol and specified performance criteria?
The method by which test criteria are currently being revised is of concern to 3M.
It shares the view expressed in a recent "Inside NRC" article where a competitor stated that testing of presently installed TSI product at the expense of the utility industry distorts the
" level playing field" of competitive suppliers ("Inside NRC". Vol. 14, No. 25, December 14, 1992, P. 2).
The management of 3M, therefore, looks forward to the meeting on January 7 and the opportunity of reviewing with the NRC these important issues.
Very truly yours, F
Merr we R. Marquardt MRM/nlw c:
Mr. George A. Mulley, Jr.
U.S. Nuclear Regulatory Commission Office of the Inspector General MNBB 6715 Washington, D.C.
20555 Mr. Richard C.
Paul U.S. Nuclear Regulatory Commission Office of Investigations 799 Roosevelt Road Glen Ellyn, IL 60137 Archizel 18-92 4