ML20034F068
| ML20034F068 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/23/1993 |
| From: | Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034F049 | List: |
| References | |
| 50-445-93-08, 50-445-93-8, 50-446-93-08, 50-446-93-8, NUDOCS 9303020239 | |
| Download: ML20034F068 (44) | |
See also: IR 05000445/1993008
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APPENDIX B-
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Inspection Report:
50-445/93-08
50-446/93-08
Operating License: NPF-87
Construction Permit: CPPR-127
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Licensee: TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
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Facility Name:
Comanche Peak Steam Electric Station, Units 1 and 2
Inspection At:
Glen Rose, Texas
Inspection Conducted: January 11-15,1993
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Inspectors:
P. Madden, Senior Fire Protection Reviewer, Plant Systems Branch,
Office of Nuclear Reactor Regulation
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M. Murphy, Reactor Inspector, Plant Support Section, Division'of
Reactor Safety, Region IV
T'. Reis, Project Engineer, Project Section B, Division of Reactor
Projects, Region IV
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A. Singh, Reactor Inspector, Plant Support Section, Division of
Reactor Safety, Region IV
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Approved:
.L. A. Yandell, Chief, Project Section B,
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Division of Reactor Projects
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Inspection Summary
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Areas Inspected (Unit I):
Inspection of Unit I was limited.to followup of
previously identified unresolved and inspection followup items.
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Areas Inspected (Unit 2):
Planned, announced inspection of followup on the
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six unresolved and six inspection followup items from the fire protection team
inspection conducted November-16-20, 1992, and the licensee's procurement,
training, quality assurance, engineering, installation, and testing activities
associated with its use of Thermo-Lag as a fire barrier system.
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ADOCK 05000445
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.Results (Unit 1):
The licensee connitted to perform hardware modifications necessary to
alleviate the susceptibility of fire induced short circuiting rendering
safe shutdown motor-operated valves (MOVs) inoperable as discussed in
NRC Information Notice 92-18, " Potential for Loss of Remote . Shutdown
Capability During a Control Room Fire," prior to startup from the third
refueling outage (Section 1.3).
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The licensee committed to take timely actions to address the completion
of the Generic Letter 86-10 associated circuit high impedance fault
study and subsequent necessary modifications and to upgrade the safe.
shutdown emergency lighting batteries (Sections 1.2 and 1.5).
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Based on the commitments and other actions taken, the licensee
adequateli addressed the impact on Unit 1 of the unresolved items
identified in NRC Inspection Report 50-445/92-49; 50-446/92-49.
The
inspection followup items, which potentially impacted Unit 1, from the
referenced report were also resolved (Sections 1.1, 1.2, 1.3, 1.6, 1.9,
1.11, and 1.12).
Implementation of all of the liceasee's commitments is considered an
inspection followup item (Section 1.13).
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Results (Unit 2):
A sampling of the adequacy of emergency lighting performed to resolve -
Inspection Followup Item 446/9249-06 resulted in a violation.
Unauthorized disconnection by the startup organization of emergency.
lights from their respective battery supplies, apparently to prevent
battery discharge during a bus outage, resulted in the emergency
lighting system being in operations custody with a significant
percentage of inoperative lights (Section 1.6).
The licensee committed to perform hardware modifications necessary to
alleviate the susceptibility of fire induced short circuiting rendering
safe shutdown MOVs inoperable as discussed in NRC Information Notice 92-18, " Potential for Loss of Remote Shutdown Capability During.a
Control Room Fire," prior to startup from the first refueling outage
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(Section 1.3).
The licensee adequately addressed, contingent upon the-
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implementation of docketed commitments, the unresolved items
pertaining to the Generic Letter 86-10 high impedance fault study;
the potential for spurious operation and subsequent damage to safe
shutdown required MOVs and the failure of an automatic turbine
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trip to occur; and the testing, maintenance, and derating of
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emergency lighting. The licensee adequately addressed, with no'
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further action required, the unresolved items pertaining to
testing and maintenance of safe shutdown circuit breakers and
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relays; the rating and positioning of certain fire suppression
sprinkler heads; and, the design adequacy of a water curtain
intended to satisfy separatson criteria.
(Sections 1.1, 1.2, 1.3,
1.5, 1.9, and 1.11).
Inspection followup items pertaining to positioning of smoke detectors
relative to air flow, and physical obstructions to sprinkler heads were
resolved contingent upon the implementation of docketed commitments.
Inspection followup items pertaining to procedural deficiencies in
Procedure ABN-803B, " Response to a Fire in the Control Room or Cable
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Spreading Room," completion of fire barriers and seals, and the impact
of missing control room ceiling tiles on smoke detection equipment were
resolved unconditionally (Sections 1.4, 1.7, 1.8, 1.10, and 1.12).
The licensee made further commitments, in docketed correspcndence dated
January 15, 1993, to upgrade the safe shutdown emergency lighting
batteries in accordance with the current replacement schedule beginning
June 1, 1993; designate and control tools and ladders required for the
performance of ABN-803B, " Response to a Fire in the Control or Cable
Spreading Room;" perform 100 percent of the preventive maintenance
procedures for emergency lighting, and complete the engineering
justifications for Thermo-Lag installations which do not conform to
tested configurations. The implementation of these commitments is an
inspecti.on followup item (Sections 1.4, 1.5, 1.6, 1.13, and 2.6).
The licensee's Thermo-Lag installation program contained all essential
elements and complied with the approved installation and specification
procedures.
A comprehensive, multitiered quality assurance / quality
control (QA/QC) program was in place and appeared to be effective.
Some
installed configurations were found that did not conform to the tested
configurations and the licensee was still in the process of preparing
engineering evaluations. These evaluations will be reviewed when
received (Section 2.0).
Implementation of all the licensee's commitments is considered an
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inspection followup item (Section 1.13).
Summary of Inspection Findings
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Violation 446/9308-01 was opened (Section 1.6).
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Inspection Followup Item 445;446/9308-02 was opened (Section 1.13).
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Unresolved Item 445;446/9249-01 was closed (Section 1.1).
Unresolved item 445;446/9249-02 was closed (Section 1.2).
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Unresolved Item 445;446/9249-03 was closed (Section 1.3).
Inspection Followup Item 446/9249-04 was closed (Section 1.4).
Unresolved Item 445;446/9249-05 was closed (Section 1.5).
Inspection Followup Item 446/9249-06 was closed (Section 1.6).
Inspection Followup Item 446/9249-07 was closed (Section.1.7).
Inspection followup Item 446/9249-08 was closed (Section 1.8).
Unresolved Item 445;446/9249-09 was closed (Section 1.9).
Inspection Followup Item 446/9249-10 was closed (Section 1.10).
Unresolved Item 445;446/9249-11 was closed (Section 1.11).
Inspection followup Item 445;446/9249-12 was closed (Section 1.12).
Inspection Followup Item 445;446/9225-03 was closed (Section 1.14).
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Inspection Followup Item 446/9227-01 was closed (Section 1.15).
Attachments: I
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Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2 - 10 Electric Letter, TXX-92640, dated December 23, 1992
Attachment 3 - TV Electric. Letter, TXX-93034, dated January 15, 1993
Attachment 4 - Areas Requiring Sprinkler Head Relocation or Addition
Attachment 5 - Detailed Review of Omega Point Laboratory Thermo-Lag fire
Test Reports
Attachment 6 - Typical Thermo-Lag Configuration Drawings
Attachment 7 - Thermo-Lag Configurations and Respective Work Documents
Inspected
Attachment 8 - Engineering Justifications for Untested Thermo-Lag
Configurations Reviewed
Attachment 9 - Other Thermo-Lag Configurations Not Bounded by Testing
Program
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DETAILS
1 FOLLOWUP (92701)
1.1
(Closed) Unresolved items 445:446/9249-01: Testing and Maintenance of
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Breakers and Relays
This item involved the testing and maintenance of circuit breakers, relays,
and power supplies required to achieve postfire safe shutdown.
During the
initial inspection, discussions with licensee personnel left the team with the
understanding that implementation of preventive maintenance and testing
procedures was limited in scope to only power supplies specifically identified
by Technical Specifications. Such implementation would not be sufficient to
encompass all breakers and relays associated with equipment necessary to
support a postfire safe shutdown.
The licensee subsequently demonstrated that
all the subject safe shutdown breakers and relays had been included into the
plant preventive maintenance program in accordance with Procedure _STA-677,
" Preventive Maintenance Program," Revision 2, dated July 14, 1992, for both
Units 1 and 2.
The team reviewed the completed packages anc. verified that' the
breaker surveillances had been performed in accordance with the established
frequency.
1.2 (Closed) Unresolved Items 445:446/9249-02:
Conservatism of Generic
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Letter 86cl0 High Impedance Fault Stud _y
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This unresolved item pertained to assumptions the licensee used in performing
the high impedance fault (fault currents of a value that is just below the
trip point of the protective device on each individual circuit) study,
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required by Generic Letter 86-10.
The Generic Letter requires that, for
circuits which are associated by a common power supply, simultaneous high
impedance faults for associated circuits in a given fire area should be
considered. The Generic Letter does not provide guidance in the' methodology
to be used in the analysis. The initial inspection found that the licensee
chose an arbitrary five, fire initiated, high impedance faults to be the
maximum that would occur, regardless of the population of circuits which
shared the common power supply.
The team considered that the number of faults assumed should be a function of
the circuit population sharing the common power-supply. The licensee examined
its five assumed faults and determined that, for high and medium voltage power
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supplies, five represented 31 percent or greater of the population, which the
team considered sufficiently conservative.
However, for low voltage power
supplies (generally 125VDC or 120VAC), the five assumed faults represented
only 14 percent of the population in at least two power supplies, which the
team considered nonconservative.
The licensee agreed that performing the analysis based on an assumed
percentage basis in lieu of the arbitrarily chosen five was an improved
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methodology.
Both the licensee and the team considered an assumption of
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25 percent failures to be sufficiently conservative.
Accordingly, the
licensee revised Calculation 2-EE-0052 to incorporate the failure rate of
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25 percent in lieu of an assumed five failures.
The reanalysis necessitated
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the uprating of three breakers in 118VAC Distribution Panel No.'2EC2, 125VDC
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Distribution Panel No. 2ED2-1, and 125VDC Distribution Panel 2EDI-1,
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respectively.
The licensee initiated Design Change Authorization (DCA) 87838
dated December 21, 1992, to replace the breakers and, as of January.12,1993,
two of the three had been replaced, with the third awaiting a Train A outage
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to be accomplished.
The team has reviewed the licensee's reanalysis of its high impedance fault
study and considers that the licensee has taken adequate corrective actions to
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address the teams concerns for Unit 2.
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However, this issue also impacts Unit 1, and the licensee's reanalysis of the
Unit I high impedance fault study incorporating the 25 percent failure rate
has not been completed.
The licensee has committed to complete the study by
May 1, 1993, submit it to NRC Region IV and complete any hardware
modifications necessitated by the reanalysis during the next available outage
that would support the changeout of any breakers requiring. upgrade.
1.3
(Closed) Unresolved Items 445:446/9249-03:
WCAP'11331 Spurious
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Operations and Potential for Fire Induced MOV Failure
A portion of this unresolved item pertained to the licensee's transient
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analyses, as identified in WCAP-11331, " Comanche Peak Steam Electric Station
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Thermal / Hydraulic Analysis of Fire Safe Shutdown Scenario," of the following
fire induced spurious operations:
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Stuck Open Pressurizer PORV
Stuck Open Steam Generator PORVs
Spurious Head Vent Operation
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Auxiliary Feedwater System Misalignment
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Spurious SI System Operation
Main Feedwater and Turbine Do Not Trip at Reactor Trip
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Backup Heaters fail On
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The team determined that the licensee's analysis, as identified in WCAP 11331,
adequately demonstrated that, with the exception of the failure to obtain P4
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(main feedwater and turbine does not isolate following reactor trip scenario),
all postulated scenarios demonstrated that no challenge to core cooling would
occur.
The WCAP recommended that further evaluation of.the transient
involving failure cf main feedwater and turbine trip following reactor trip be
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conducted. 'The licensee did not provide the team with objective evidence.that
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a further evaluation of a failure of main"feedwater and turbine trip at
reactor trip had been conducted.
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The licensee had considered the probability of this malfunction to occur to be
remote and considered manual actions of shutting-the main steam isolation
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valves to isolate.the turbine and thus prevent an uncontrolled cooldown to be
satisfactory.
There was no objective or quantitative evidence to support the
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capability of isolating the turbine in a timely manner to prevent core damage.
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In response to this unresolved item, the licensee reevaluated all of the seven
spurious operations and reconfirmed that appropriate procedural guidance was
specified in Procedure ABN-803B, " Response to a Fire in the Control Room or
Cable Spreading Room," to minimize the effects of the six postulated
transients that the team initially found acceptable.
For the postulated scenario of failure of main feedwater and turbine trip to
occur on reactor trip, the licensee has revised Procedure ABN-803B to direct
the reactor operator to manually trip the main turbine in addition to the
reactor prior to control room evacuation. Additionally, Procedure ABN-803B
instructs the reactor operator to close the main steam isolation valves from
the control room prior to evacuation if conditions permit.
The team reviewed revisions to Procedures ABN-803A (Unit 1) and ABN-803B
(Unit 2) and found that they adequately addressed the concerns raised by the
team.
Accordingly, no further action is required on this aspect of Unresolved
Item 445;446/9249-03.
The other portion of this item pertained to the potential for a control room
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or cable spreading room fire to create a single hot short in the control
circuitry of various MOVs, resulting in their spurious operation.
Additionally, .since the fault would cause the position limit 'and torque
switches to be bypassed, mechanical damage of the valve due to overtorque may
occur, thereby rendering it inoperable.
This concern is the subject of NRC
Information Notice (IN) 92-18, "Poteni bl for Loss of Remote Shutdown
Capability During a Control Room fire, " dated February 28, 1992.
The team had found that the licensee had reviewed the IN for impact on their
facility and found that they did possess circuitry configurations analogous to
those specified in the IN.
The licensee, however, in consultation with the
Nuclear Utility Management and Resources CounciT (NUMARC) determined in August
1992 that the low probability of such an occurrence did not justify any
modifications to the CPSES.
The licensee's contractor, Stone and Webster
Corporation, had identified to the licensee in July 1992 that CPSES Unit 2 did
have 53 MOV circuit configurations similar to these described as vulnerable in
the IN and recommended the control- circuitry be rewired internal to the motor
control center compartments so that the torque and limit switches in the valve
operators are electrically connected downstream of the contacts located in the
motor control center.
At the conclusion of the initial inspection, the team
could not conclude that, without modifications to the vulnerable MOV
circuitry, the existing design conformed to licensee commitments to the
requirements of 10 CFR 50, Appendix R, Section 111.L.7, which states, in part,
that the safe shutdown equipment and systems for each area shall be known to
be isolated from associated non-safety circuits in the fire area so that hot
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shorts, open circuits or shorts to ground will not prevent operation of the
safe shutdown equipment.
Accordingly, the issue remained unresolved for
Units 1 and 2.
After further review by the NRC staff, it was determined that the licensee was
not committed to meet the requirements of Section III.L.7.
In further discussions with the NRC staff, the licensee committed in docketed
correspondence dated December 23, 1992, to implement design changes in the
control circuits of the affected MOVs, as required, pursuant to those-
recommended in NRC Information Notice 92-18. The licensee committed to
perform the design changes prior to startup from the first refueling outage
for Unit 2 and prior to startup from the third refueling outage for Unit 1.
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The licensee has assessed the work to modify those MOV circuits which are
vulnerable to failure as described in the IN for Unit 2 and has determined
that 55 MOVs were potentially affected.
To date, the licensee has determined
that 29 circuit modifications will be required, while 12 circuits are still
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under review and 14 require no modification.
The Unit I study has not been
compl eted.
Based on the licensee's docketed commitments, this portion of Unresolved
Item 445;446/9249-03 is considered closed.
1.4 (Closed). Inspection Followup Item 446/9249-04:
Procedural and Physical
Deficiencies identified in Procedure ABN-803B.
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This item involved procedural and physical deficiencies identified during the
walkdown of Procedure' ABN-803B, "Responst to a Fire in the Control Room or
Cable Spreading Room." These deficiencies consisted of typographical errors,
incorrect component identification in the procedure and in the plant,
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component location errors, and missing tools, which were required -for
equipment operation, such as, T-handle wrenches and ladders.
These
deficiencies were identified in detail in Attachment 3 of the NRC Inspection
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Report 50-445/92-49; 50-446/92-49.
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In response to these issues, the licensee revised Procedure ABN-803B to
incorporate the identified deficiencies. The team reviewed the revised
version of Procedure ABN-803B and found that it properly addressed the
identified deficiencies.
Additionally, the licensee committed -in Attachment 3
to provide dedicated T-Wrenches and ladders to perform the activities required
by procedures.
. Based on the inspector's reviews and the licensee's commitments, this
inspection followup item is considered closed.
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1.5
(Closed) Unresolved Item 445:446/9249-05: Testing, Maintenance, and
Derating of Emergency Lighting
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One aspect of this unresolved item pertained to concerns with the licensee's
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testing and maintenance of emergency lighting in that the licensee opted not
to follow the guidance provided in NRC Information Notice 90-69, " Adequacy of
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Emergency and Essential Lighting," which suggests that as-found, 8-hour
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discharge testing is appropriate for safe-shutdown emergency lighting.
Instead, the licensee performs preventive maintenance on the batteries,
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adjusts the aim of the lanterns, as necessary, and performs a functional check
of the lanterns on a 6-month interval.
The literature provided by the battery
manufacturer, Eagle Picher, indicated that such deep discharge testing is
actually detrimental to the battery and will shorten its expected life.
After
further review, the inspector determined that the licensee's testing and
maintenance program is in accordance with manufacturer guidelines and meets
regulatory requirements.
The other aspect of this unresolved item pertained to the.derating and
shortened lifespan of safe-shutdown batteries which are subjected to elevated
ambient temperatures.
In the initial inspection,'the inspector found in
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literature provided .by the Halophane Company, the vendor that provided the
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majority of the safe-shutdown emergency lighting, that significant derating _of
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the wet lead-acid batteries would be expected in applications with average
ambient temperatures exceeding 90 F and that, at a temperature of 131oF the
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batteries would only be expected to last 6-9 months.
The licensee's program
called for blanket replacement of all batteries outside containment at 3-year
intervals and for those supporting safe-shutdown lighting inside containment
. at ' a refueling interval .
It could not be determined for locations such as
containment,. safeguards building steam penetration area, emergency diesel
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generator rooms, and the feedwater penetration area, where elevated ambient
temperatures would be expected, that the emergency lighting' units could
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maintain an 8-hour discharge with adequate illumination as required by
Appendix R, Section Ill.J.
In response, the licensee performed a review of operator log sheets to
determine temperatures in various areas of Unit 1 over a 1-year period of
Modes 1 and 2 operation and did find areas where average annual ambient
tev eratures approached 90 F and areas in containment where safe-shutdown
lig ting is located where average ambient temperatures of approximately 96of
exi;t,
Th( licensee provided excerpts from a study by the Electric Power Research-
Ins ;tute (EPRI) indicating that "in general, lead-acid battery life is halved
for every 16 to 18 degree Fahrenheit rise above 77 F."
Applying this
methodology, the licensee determined that battery life outside containment in
applications of 90of is just over 36 months and for batteries'inside
containment, life expectancy is approximately 22-25 months.
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Therefore, for the nominally rated 5-year Eagle Picher batteries, the
licensee's replacement interval for those areas of elevated temperatures was
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minically satisfactory.
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Due to the absence .of margin, however, the licensee has subsequently initiated
a design change, DCN 5491 dated January 8,1993, to replace the Eagle Picher
5-year batteries with Power Battery Company 10-year batteries at the scheduled
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replacement interval.
The inspector has reviewed the specifications and
determined that the upgraded batteries will provide suff aient margin to
ensure that the 8-hour illumination requirement of Appendix R is met.
The licensee has taken appropriate actions to address this concern and the
current program minimally satisfies regulatory requirements.
Therefore, this
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unresolved item is closed.
1.6
(Closed) Inspection Followup Item 446/9249-06: Blackout Testing of
This inspection followup item was identified by the fire protection team
inspection based on the need to assess the adequacy of illumination of safe
shutdown emergency lighting. The assessment, which requires removing the
power to normal and essential plant lighting, was not performed during the
initial inspection so as to not adversely impact ongoing completion
activities.
As of December 21, 1992, all preoperational testing on emergency lighting had
been completed and the system turned over to operations in accordance with
system turnover Procedure STA-802, " Acceptance of Station Systems and
Equipment."
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On January 13,' 1993, the inspector arranged with Unit 2 operations to have
normal and essential lighting turned off in eight specific areas which may
require manual remote operations to achieve a postfire safe shutdown.
In the
eight areas selected, six emergency lanterns failed to operate and one room
had no illumination.
The inspector expanded the sample size and arranged to have power turned off
to six more areas.
In this assessment, eight emergency lanterns failed to
operate, two lamps were burned out, and the four main steam penetration rooms
had no illumination.
Based on the observation of this testi..g by the inspector, this inspection
followup item is considered closed.
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The licensee promptly initiated Operations Notification and Evaluation (ONE)
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Form 93-123 to address the failures and formed a task team to investigate the
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matter.
By the end of the inspection period, the licensee had determined that
the cause of the failures was due to the startup organizations disconnecting
the positive leads from the batteries to the lamps to prevent battery
draindown during a planned essential lighting outage. However, the licensee
determined that the work had been completed in an unauthorized manner outside
the scope of the administrative work control procedures in effect for both the
operations and startup organizations. Without the appropriate administrative
controls, there was no traceability to ensure the reconnection of the leads.
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At the conclusion of the inspection, it had been determined that the startup
organization had performed the unauthorized disconnections, but it had not
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been determined whether this had occurred before or after' December 21, 1992,
when the system was accepted by the operations department.
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The licensee committed the task team to perform a root cause analysis, and
provide reasonable assurance that the unauthorized, and therefore untraceable,
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work activities were limited to emergency lighting as a condition to fuel'
-load, and to perform the preventive maintenance procedures on 100 percent of
the Unit 2 emergency lighting prior to Mode 4 operations. This commitment is.
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provided in Attachment 3.
The unauthorized work activity is a violation of 10 CFR 50, Appendix B,
Criterion V (446/9308-01).
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1.7 (Closed) Inspection Followup Item 446/9249-07:
Positioning of Smoke
Detectors Relative to Air Flow
This item involved the positioning of the smoke detectors relative.to air flow
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in the safeguard building (Elevation 773 feet), in the containment spray pump
rooms, residual heat removal pump rooms, and the safety injection pump rooms.
The automatic smoke detectors were installed in all of the above pump rooms
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and these rooms contained self-contained chiller units which start coincident
with the actuation of the respective pumps. The smoke detectors were
installed on the ceiling above the chiller units. Once the chiller starts,
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the resulting, airflow is predominately through the chiller, with the supply
air discharging from the bottom of the unit onto the pump motor.
When the
chiller is operating, the ceiling airflow pattern appears to be stagnant.
This condition could cause a delay in early detection of a fire condition if
this event were to occur during those times when the pumps were operating.
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In response to this issue, the licensee performed an evaluation which
identified the Unit 2 plant areas where heating, ventilation, and air-
conditioning airflows could affect the detection system.
The purpose of the
review was to identify areas where detectors could be adversely impacted due
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to proximity to air diffusers and excessive air flow due to spot coolers.
This. evaluation identified several vulnerable areas in the Unit 2 safeguards
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building. As a result of this evaluation, the licensee has committed to
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relocate five existing detectors and add four additional detectors.
This
commitment is provided in Attachment 3.
Based on the licensee's evaluation and the referenced commitments, this
inspection followup item is considered closed.
1.8 (Closed) Inspection Followup Item 446/9249-08:
Completion of Fire
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Barriers and Seals in Fire Area 2SA and 2SB
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This item involved the completion of the fire area barrier separating Fire
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Area 25A from 2SB.
Specif'cally, the penetration seals associated with.this
fire barrier had not been completed at the time of the initial inspection.
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During followup inspections, the team walked down the subject fire barrier and
confirmed that the penetration seals had been completed. The team also
reviewed the completed work package for the fire barrier. The inspector
determined that the penetration seals were installed in accordance with the
established procedures and that the licensee's corrective actions
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appropriately addressed the identified issue.
Based on the inspector's
review, this inspection followup item is considered closed.
1.9 (Closed) Unresolved Item 445:446/9249-09:
Fire Sprinkler Head Selection
The licensee has installed automatic fixed water fire suppression systems in
safety-related areas of the plant where a high fire hazard exists, where
redundant safe shutdown equipment or cabling outside the containment building
is located in the same fire area and is not separated by a 3-hour fire
barrier, and where there is a congestion of cabling (e.g., tray stacks of four
trays or more).
During the plant walkdowns conducted as part of NRC Inspection
Report 50-445/92-49; 50-446/92-49, the inspectors noted that the sprinklers
installed at ceiling level throughout the plant had a thermal actuation
setpoint of 212 F.
The inspectors noted that all the plant areas, provided
with sprinkler protection, were air conditioned. The inspectors viewed these
plant areas as having an average maximum ceiling temperature of 75-90oF with
an environmental profile similar to that of a typical air conditioned
commercial building. Under these conditions, the guidance of National Fire
Protection Association (NFPA) 13, recommends that, for ceiling temperature
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less than 100oF, the sprinkler temperature actuation setpoint should be in the
range 135 F to 170 F.
The inspectors reviewed the Unit 2 Environmental Data Sheets
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(Drawings M2-3000, Sheets 3, 4, 5, and 6, " Environmental Data Outside the
Containment"), which indicated that the maximum peak ceiling temperature for
the general areas outside the containment in the safeguards building was
104*F.
Using this temperature data, the licensee indicated that the guidance
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of NFPA 13 for the selection of the temperature ratings for the sprinkler
heads recommends the use of sprinklers with an actuation actuation setpoint in
the range 175of to 225cf.
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The licensee's use of 212 F rated sprinklers yields an actuation threshold of
108 F as compared to a 61 F actuation threshold for the 165of rated sprinkler
which would be used in a commercial building under similar conditions.
Fire development conditions, based on the type of combustibles present in a
nuclear power plant, is considered to be slow.
Under such conditions, due to
the increased thermal energy required to activate the 212 F sprinklers, the
inspectors were concerned that an increase in fire damage and fire
'
temperatures could be expected.
In addition, the inspectors were concerned
that the 212 F thermal actuation setpoints for the sprinklers installed at
i
significant distances below the ceiling (e.g., intermediate level sprinklers)
would cause delays in sprinkler response.
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In response to these concerns, the licensee performed an independent
engineering evaluation (ER-ME-080, Revision 0). The scope of this evaluation
I
assessed the thermal response of the type of sprinkler heads (Grinnell Model F
.
950) installed within the facility. This thermal response analysis' considered
.
the Response Time Index for the Model F 950 sprinkler head.
The analysis
determined, for a recm with a 20-foot ceiling height, the minimum fire heat
L
release rate which would be required to actuate a ceiling level sprinkler.
The minimum heat release rate required to achieve the sprinkler actuation
temperature was based on a 5-minute fire duration.
The analysis indicated
that a fire with a minimum of 1300kW heat release rate would be'requireo to-
actuate a 212 F Model F 950 sprinkler head.
To place this in perspective, a
i
lube oil pan fire of approximately 5 square feet would develop 1300kW.
The licensee, to augment the ceiling level sprinklers, has provided automatic
fixed cable tray suppression systems in areas where cable congestion is
present.
This cable tray suppression coverage is an extension of the
,
sprinklers provided for area coverage.
The current layout of these systems,
for horizontal tray stacks, has the nozzles arranged in a " vertical stand-off"
t
fashion, spaced 6-12 int' s away from the tray side rails.
The nozzles are on
only one side of the tra: stack and are offset 6-12 inches above the
horizontal plane of th , rays.
In addition, the top of the tray is protected
!
by nozzles positioned 9v2r the mid-line of the top tray. These nozzles are
provided with baffles.
These baffles have a dual function in that they
prevent " cold solder" effects and act as a heat collector to improve the
nozzle actuation time.
The licensee's design basis for these systems is to
confine a fire to the congested tray array. The licensee applied certain
aspects of NFPA 15, " Water Spray Fixed Systems For Fire Protection," to the
'
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design of the cable tray suppression systems. The licensee indicated that
they designed these systems to apply a water spray application density of 0.15
gpm per ft".
The table water spray nozzles have an actuation setpoint of
175of.
If a fire were to occur within a bank of cable trays protected by the
witer spray system, the expected response would be as follows:
as the fire
transitions from a smoldering to a flaming phase the heat generated by the
fire plume would be collected by the water spray _ nozzle baffle; this baffic,
i
acting as a heat collector, would collect the heat in the fire plume and
'
direct the heat towards the water spray nozzle fusible actuation element; and
finally, based on the design and layout of these cable tray water spray
systems, the upper level nozzles would react firs * to the fire condition to
,
provide a water spray on the cable trays.
The inspector, after reviewing
4
these systems during plant walkdowns, found them adequate to control a cable
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tray fire.
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Reviewing the Comanche Peak Unit 2 fire protection program from a " Defense-in-
Depth" fire safety perspective, the inspector found the plant areas that were
inspected to ha,' the appropriate levels of early warning fire detection
coverage, adequats distribution of manual fire fighting equipment, fire
i
barriers applied to one train of safe shutdown systems, and the appropriate
"
level of automatic fire suppression coverage to assure prompt mitigation of an
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in plant fire condition.
In addition, the plant has administrative control
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measures established that control transient combustible and ignition sources
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and has a fully trained onsite fire brigade.
Looking at.the overall level of
fire protection, even if a slow developing fire were to occur in a plant area
and was not sufficient to generate enough thermal energy to activate the
sprinkler system, the smoke generated by the fire would be detected by the
early warning fire detection devices in the area and the. appropriate fire
.
control and suppression actions will be initiated by the fire brigade.
Therefore, this issue is closed for Units 1 and 2.
'
l.10 (Closed) Inspection Followup Item 446/9249-10:
Physical Obstructions to
Sprinklers
This item involved physical obstructions to the ceiling level sprinklers in
Fire Area 2SB4 due to the presence of cable trays; piping; and heating,
ventilation, and air conditioning ducting. As a result of this issue, the
licensee initiated an engineering walkdown of the affected plant sprinkler
,
systems.
This walkdown focused on the evaluation of obstructions to
.
- sprinklers and their impact on the sprinkler system's ability to apply water
directly to a fire.
The licensee's engineering evaluation identified six areas in Unit ? which
,
required 316dditional sprinkler heads and the relocation of 10 sprinklers due
to equipment obstructions.
These areas are listed in Attachment 4.
.
The licensee also initiated modificailcn packages to correct the physical
obstructions of the sprinklers. As documented in Attachment 3, the licensee
'
committed to complete these modifications by the end of the first refueling
outage. Based on the licensee's stated commitment to modify the sprinkler
system, it was determined that appropriate corrective actions had been
.;
developed to address the identified concern and this inspection followup item
is considered closed.
]
1.11
(Closed) Unresolved Item 445:446/9249-11. Essential Chiller Room Water
Curtain Desian
r
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The Unit l 2 essential chiller area deviates from the requirements of Appendix.R
and the deviation had been approved by the NRC staff.
The chillers and pumps
,
are separated by partial height 1-hour equipment fire barrier walls.. During.
the plant walkdown, the wall was verified to extend above and along the entire
length of the chiller units.
The licensee, as part of their fire' protection
'
enhancements, has installed curbs from where the. chiller pump partial wall
terminates to the wall of the room. These curbs are installed to preclude a
combustible liquid spill fire from impacting both chiller pumps.
In addition,
l
- the licensee has installed additional smoke detectors in this area to enhance
their ability to rapidly detect a fire conditionan this area. .In the
-
overhead of this room, cable. trays _ transverse the area.
These trays are an
intervening combustible hazard to redundant' chillers and their: associated
pumps. -In order to preclude fire propagation, caused by an electrically
originated fire along these trays, the ' licensee has installed fire stops in.
the trays at the vertical extension plane of the walls.
The intent of these
3
stops is to preclude fire propagation along the tray so that a tray fire.
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presents an exposure to only one chiller or pump. The chiller area is
protected by area wide sprinklers installed at the ceiling level.
In
addition, the licensee has installed a water curtain.at the vertical extension
plane of these partial height walls. This water curtain consists of closely
spaced fast response sprinklers (212 F) designed to apply a discharge rate of
3 gpm/ linear foot of curtain length.
The inspector reviewed portions of
Design Change Notice 4338, Revision 3, and could.not confirm the use of draft
stops. The inspector was concerned that, without the installation of-draft
stops to collect heat in the area of the water curtain ceiling level
sprinklers, the actuation.of the curtain would be delayed in the event of a
fire in the area of the fire barrier walls.
During the inspection effort performed as part of NRC Inspection
Report 50-445/92-49; 50-446/92-49, the inspector could.not perform a full
assessment of the water curtain and assess its ability to perform its fire
protection function because of the construction activities (e.g., scaffolding)
in the essential chiller room.
h addition, the inspector reviewed the
licensee's Engineering Report ER-ME-080, Revision 0, " Assessment of Fire
Protection Features for Separation of Unit 2 Redundant Safety Related Chiller
Components." As part of this assessment, the inspector performed a walkdown
of the chiller area to review the placement of the water curtain and.the
ceiling level sprinklers in the area of the partial height fire barrier.
The
inspector confirmed that the water curtain heads were at ceiling level with a
level of fast response heads installed under cable tray obstructions.
The
ceiling level water curtain fast response sprinklers are spaced every 6 feet
across the ful.1 width of the room directly over the partial height fire
barrier walls.
In addition, the inspector noted the layout of the beam
pockets at the ceiling elevation.
The ceiling of the chiller room has.
30 x 60 beams running across the width of +he room. The location of these
beams has created a beam pocket over the chiller pumps and two beam pockets
nyer the chiller equipment. The significance of these beam pockets 'is that
they will aid in the collection of heat in the ceiling area directly over the
fire and will improve the response of the ceiling level' area and the water
curtain fast response sprinklers.
For example, if a fire were to involve a chiller pump, the fire plume would
develop and heat wnuld spread across the ceiling and be collected within the
beam pocket directly over the pumps.
The fire barrier wall between the' pumps
would preclude direct fire exposure to the redundant chiller pump until the
water curtain fast response and ceiling level area sprinklers reacted to the=
fire condition.
Based on the type of sprinklers used for the water curtain -
it is anticipated that they will respond to the fire condition prior to the
actuation of the ceiling level sprinklers.
The inspector's assessment of the
fire protection features provided 'for the Unit 2 essential chiller. area finds
these features to provide an adequate level of protection which will assure
that a fire would te mitigated and the potential fire damage would be limited
- i
to one train of essential chillers.
The inspector was also concerned that sprinklers over the redundant chiller
i
pump, which is not on fire, could actuate and impact the operability of this
____
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!
pump. The licensee's analysis of inadvertent or advertent effects of
sprinkler actuation indicated that all essential equipment associated with the
operation of the chillers are enclosed in NEMA Type 12 cabinets and the
chiller pump motors are fully enclosed.
In addition, the licensee's analysis
1
indicated that water shields have been 'provided on the tops of essential
electrical control panels and cabinets, and the conduit entrances to these:
panels and cabinets are sealed.
Considering the potential accumulation of
water on the floor of the chiller room as a result of fire suppression
i
discharge, the essential equipment has either been installed on concrete pads
,
sized to accommodate the postulated flood levels or the equipment is mounted
in such a manner that it is above the flood level.
In addition to the normal
.
floor drains, the essential chiller room is provided with eight 6-inch
diameter flood mitigation drain lines installed at the floor leve1~.
Based on
,
the review of the licensee's analysis, the inspector found the measures the
.
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licensee has taken to mitigate the affects of fire suppression water discharge
on the essential chiller water system components to be adequate.
'
The water curtain feature was found not to be utilizea in the Unit 1 essential
chiller area. Accordingly, the unresolved item is closed for Units 1 and 2.
1.12
(Closed) Inspection Followup Item 445:446/9249-12: Missing Ceilina
Tiles
This item involved missing ceiling tiles around the smoke detectors in the
control room behind the horseshoe area.
The licensee indicated that the
ceiling tiles Jiad been removed in order to assure the seismic qualification of
'
the control room suspended ceiling.
Initially, the team could not conclude
that the smoke detectors in their current configuration would provide rapid
,
detection of a fire in the back panel arer in that smoke from a postulated
fire could flow through these openings in the ceiling and bypass the
,
detectors.
As a result of this concern, the licensee performed-a walkdown of the system
,
and developed a technical evaluation which addressed this issue.
This
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evaluation established that the at ea above the suspended ceiling in the
control room has full-area detection coverage.
Furthermore, this evaluation
.
concluded that., although ceiling tiles were missing in~ the suspended ceiling.
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of the control room, the fire detection adequacy in the control room was
maintained due to full-area coverage at the structural ceiling level.
The
team walked down these areas to confirm the installation of the smoke
detectors at the structural ceiling level in the control room.
Based nn these
field inspections, it was determ,ned that the fire detection coverage was in
'
accordance with the requirements of National Fire Protection
Association (NFPA) 72-E. criteria.
Accordingly, this issue is closed for
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Units 1 and 2.
+
1.13 Tracking of Commitments
Inspection Followup Item 445;446/9308-02 is opened to track the licensee's
- commitments made with respect to completion of the high impedance fault study
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and hardware modifications for Unit 1; implementation of hardware
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modifications to prevent fire induced failure of safe shutdown MOVs; upgrading
of safe shutdown emergency lighting batteries; additions and relocations of
sprinkler heads; the dedication of ladders and tools. required to support
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Procedure ABN-803B; completion of preventive maintenance procedures on
'
100 percent of emergency lighting prior to Mode 4 operations; and completion
of the engineering analyses for untested Thermo-Lag configurations.
These
commitments are docketed in licensee correspondence ~ dated December 23, 1992,
and January 15, 1993. This correspondence is provided as Attachments 2 and 3,
respectively.
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1.14 (Closed) Inspection Followup Item 445:446/9225-03:
Failures of
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Thermo-Lao Configurations
,
This inspection followup item was identified to track test failures of
,
particular Thermo-Lag fire. barrier configurations.
Based on the discussion in
S:ction 2.0 below and that found in Supplement 26 to NUREG 0737, " Safety
Evaluation related to the operation of Comanche Peak Steam Electric Station,.
Units 1 and 2,"
SSER 26, Section 9.5.1.5, this item is closed for Units 1 and
2.
f
l 15 (Closed) Inspection Followup Item 446/9227-01:
Installed Thermo-Laq
which Deviates from Tested Configurations
Field verification of Thermo-Lag installations by inspectors revealed
installed Thermo-Lag applications which did not conform to tested
configurations.
Based on the discussions in Section 2 below, SSER 26,
Section 9.5.1.5, and the licensees commitment provided in Attachment 3, this
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item is considered closed.
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2 THERMO-LAG l-HOUR FIRE BARRIERS
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During this inspection, an assessment of the licensee's procurement, testing,
.;
engineering, installation, training, and quality assurance activities
'
associated with the use of Thermo-Lag as a fire barrier system was performed.
i
The details are provided below.
2.1
Procurement of Thermo-Lao Fire Barrier Materials
The inspectors reviewed the licensee's Thermo-Lag' fire barrier material
,
procurement process. The licensee's program is controlled by Appendix A,
" Receipt, Dispensing, Quality and Inspection Requirements for Thermo-Lag Fire
,
Barrier Meterials," to Procurement-Specification 2323-MS-38H.
This document-
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contains the_ receipt inspection / verification criteria imposed on_this
material. This document require's that- QC receiving verify the weight / density -
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(lbs/ft') checks of Thermo-Lag panels and conduit preshapes.
In addition,
>
this document specifies the minimum weight / density values acceptable for
panels and the various conduit preshapes sizes.
Procurement
Specification 2323-MS-38H requires QC receiving to verify the following:
material thickness; no holes or cracks exist in the material wider than
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0.05 inches; no holes or cracks exist in the material that extend through the
material to the stress skin; and no signs of visible damage (i.e., gouges,
breaks, tears, etc.).
From the Thermo-Lag material. physical verification
information contained in Specification 2323-MS-38H, Appendix A, Procurement
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Engineering developed Pre-Engineering Item Data Sheet (PEIDS) for Thermo-Lag
!
fire barrier material (PEIDS NES00ll). This document contains the physical,
weight / density, and condition criteria to be followed by the procurement QC
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personnel performing these inspections.
The inspector verified that the QC
inspection criteria established by PEIDS NES0011 was consistent with the
material physical attributes specified by Design Specification, " Procurement
,
and Installation of Fire Barrier and Fireproofing Materials," CPES-N-2032.
,
The licensee, when purchasing the Thermo-Lag fire barrier material, issues a
,
purchase order (PO) to Thermal Science, Inc. (TSI), the manufacturer of
Thermo-Lag fire barrier material .
The P0 specifies the fire barrier materials
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needed.
Once the material has been manufactured and is ready to ship, TSI
notifies the lictasae that the commodities requested by the P0 are ready to be
,
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released. Upon receiving this notification, the licensee sends a QC
representative to TSI's manufacturing facility in St. Louis, Missouri, to
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perform QC Verification Plan (VP) VP-NES0011-03, " Source Inspection
Verification Plan - Thermo-Lag Fire Barrier Materials," prior to shipment.
This VP verifies the thickness, weight / linear density, condition of the
material, and the material moisture content of the shipment.
Once the VP has
-
been satisfied, the TU Electric QC representative signs off on the
!
authorization-releasing the material for shipment.
.
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Upon receipt of the TSI shipment at the licensee's facility, the licensee
performs Verification Plan VP-NES0011-02, " Receipt Inspection Verification
,
Plan - Thermo-Lag Fire Barrier Materials." This VP verifies the part
number / identification of the material, performs a general receipt inspection
of the material, performs a review of the material to determine if the items
,
being received are substandard or fraudulent, and verifies that the quality
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authorization to ship is traceable to the PO for the material in the shipment.
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Once the fire barrier materials have satisfied the requirements' of the receipt
inspection VP, the material is released to the warehouse.
,
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The inspectors reviewed the traceability of the following Thermo-Lag related
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P0s and confirmed that the required source and receipt inspections were
'
properly documented by the licensee:
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Purchase Orders
1
B0028658-014
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80029659-008
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B0028659-010
B0029659-014
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B0029659-015
.
B0029659-016
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B0029659-017
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S0056079-705
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The shipments which were made to Omega Point were made under a Return Material
Shipping Order (RMS0). An RM50 is required by the licensee's procedures to be
-comp e el t d whenever a commodity is removed.from stock as result of being
rejected by the receipt inspection or as result of being shipped off site for
use at another facility. The inspector confirmed that the' licensee issued.an .
RMSO for those commodities which were shipped to Omega Point.
In addition,
the inspector confirmed by reviewing the above sampled P0s and VPs that the
Thermo-Lag Shipments made from Comanche Peak to Omega Point.were source land
receipt inspected using the same inspection criteria as those procured under-
P0s for Thermo-Lag used to construct the Unit 2 fire barrier assemblies. The
inspector, based on the documentation reviewed, did not identify any concerns
or discrepancies with regard to the traceability and source and receipt
inspection of fire barrier material used by the licensee in the construction
of the fire test specimens and the Unit 2 fire barrier assemblies.
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2.2 Trainina for Thermo-Lao Installers / Craftsmen / Field / Construction Enoineers
The licensee has established a specific training program for individuals
involved with the installation of Thermo-Lag material for Unit 2, which is
defined in CPSES Unit Procedure for Project Trainity Program 2PP-1.16,
Revision 2, dated February 27, 1992.
This program requires craftsmen, field
.*
engineers, construc. tion engineers, foremen, and superintendents involved in
the Thermo-Lag installation process to be trained.
1
Specifically,,this procedure established -the responsibilities for trainine the-
construction personnel involved in the installation of Thermo-Lag at Unit 2.
The construction training department for Unit 2 is responsible for developing
and scheduling the training. The installation of Thermo-Lag material is being
performed by the craftsmen employed by Peak Seals, Inc. (contractor for
TV Electric).
.
The inspectors reviewed the lesson plans for both classroom training and :
practical training.
The team also reviewed the training records of
30 randomly selected individuals.
This review indicated that the individuals
were trained and qualified in accordance with the established procedures.
'
However, one item of concern was identified by the team during the review of
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completed work packages. The team noted that- Figure 7.10,. Electrical QC
Inspection Checklist, Item 1.a (Block 7, CQP 213), .was _ signed by a Peak Seals-
!
i field engineer when no physical work was required.
Additionally, as a result
i
of the review of completed work documents, it was determined,that open/ blank-
blocks existed. - As stated by the licensee bec'ause of' the interpretation of
!
the Revision 2, Procedure CQP-213, " Construction Quality Procedure,"
requirements, a collective decision was made to sign the' subject attribute in
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lieu of leaving it $ lank. . Additionally, as stated by the licensee, the
.,
appropr; ate person to sign _for this activity was the individual; requesting the
inspection.
As determined.by the inspectors, in the majority of instances
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this individual was a Peak Seals field engineer.
Additionally, this signature-
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was backdated into all. in-process packages without including an explanation
regarding the backdating of signatures, when no actual work was performed.
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However, CQP-CV-107, " Construction / Quality Documentation Preparation Use,.
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Control and Review," Attachment 8.C, " Checklist -Instructions" for installation
,
craft, Block 7, states, in part, do not sign attributes which have not had
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work performed.
The inspectors noted that, generally, this block has been
signed by Thermo-Lag contractor personnel even when no physical work.was
!
required or performed.
In response to this issue, the licensee promptly
issued Operations Notification Evaluation Form 93-127 to resolve the
deficiency.
The licensee also issued a procedure change notice to CQP-213 to
clarify actions required when no field work was required or performed.
The
licensee also initiated supplemental training for appropriate personnel to
1
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clarify the process change regarding checklist blanks /open blocks.
Specifically, Block 7 shall remain open and no signatures are required when no
work is performed. Alternatively, an
"X" through the block- may be placed by
the Peak Seals field engineering or closure group personnel when processing
'
the work packages. A copy of this procedural change is to be inserted into
all Thermo-Lag Construction Work Documents (CWDs) during the closure process
and will be backfit into all previously vaulted packages. Although'not a
regulatory issue, the inspectors concluded that the procedure changes and
other actions taken by the licensee adequately addressed this concern.
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2.3 Quality Assurance and Control
!
The inspectors reviewed with the licensee the quality assurance and quality
control aspects of the installation of Thermo-Lag.
Attributes and acceptance
standards are incorporated in each work package as check lists from the
installation procedure. The contractor responsible for Thermo-Lag
,
installation provides the first two levels of quality control with the craft
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supervision and the contractor's quality control inspectors.
In. process
j
inspections are documented on the check lists in the official copy of- the CWD. .
The licensee provides an equivalent level of quality control on a continuous
monitoring basis.
The effectiveness of the licensee's multi-level QC program was demonstrated
i
when, in October 1992, unacceptable voids and delamination 'in Thermo-Lag 330-1
conduit sections for both 2- and 3-inch conduit were identified during .the
installation process.
The void formation was apparently caused by failure-of.
1
the manufacturer, TSI, to fill the. longitudinal stress cracks caused during
,
normal fabrication with Thermo-Lag. 330-1 trowel grade material in accordance
i
with TSI procedures. The delamination was apparently caused by TSI personnel
attempting to correct a material thickness problem.
Both conditions appear to
have originated from the conduit .section forming process.
This process,.which.
i
shapes Thermo-Lag 330-1 flat panel stock into half-round sections,. inherently
'
results in the development of cracks along the entire 3-foot _ length of each-
conduit section.
The subject samples displayed inspection marks from the TSI
in-process quality control monitoring, indicating that localized thinning-
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along the sections had been detected and required trowel grade buildup in
'
accordance with TSI procedures.
This thinning was apparently aggravated by
.the original flat panel fabrication process.
The buildup' material apparently-
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did not adhere to the base material during the curing process and attempts to-
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correct the delamination resulted in the use of staples'along the mating. edges-
,
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of the " cap" layer. Neither of these in-process corrective actions were in
accordance with the manufacturers procedures.
The licensee stopped all conduit section installation and proceeded to conduct
a thorough and comprehensive inspection and evaluation of all suspect
material. This effort covered all material not installed on site, material
that was in-process with TSI, and material at Omega Point Laboratories, the
test facility at wi.ich the licensee's fire tests were conducted. The licensee.
also conducted a visit to TSI to discuss corrective actions necessary to
prevent recurrence. TSI agreed to continue the improved flat panel forming
process and insure that procedures reflected the approved processes only.
personnel were reinstructed in the approved procedures. The licensee
established source inspection activities at the TSI site whereby TU Electric
source QC personnel are authorized to overview TSI's process for repair of
longitudinal cracks during forming of conduit sections.
The licensee, in conjunction with TSI, determined that the material affected
by the void, cracking, delamination, and stapling concern was limited to two
lots of prefabricated conduit sections.
The majority of the affected lots was
accounted for and was not installed. Any affected conduit sections that may
have been installed in Unit 2 were considered to be acceptable by the
licensee.
The basis for this determination was that representative samples of
the affected 2- and 3-inch conduit sections were satisfactorily tested at
Omega Point Laboratories.
Further discussion of fire barrier testing is found-
in paragraph 2.4.1 and Attachment 5.
The licensee's QA group provides broad programmatic oversight and periodic
installation inspections that are documented in QA audits.
The inspectors
reviewed a sample of the QA/QC documentation a )d confirmed that the licensee
has an effective in-process Thermo-Lag installation QA/QC program,
f
1
2.4 Thermo-Lag Fire Barrier Design and Installation Process
The inspectors observed the installation of Thermo-Lag 330 fire barrier
material on conduits and cable trays.
These observations were made on
October 13 and 21, 1992, and January 7, 1993.
Observations were also-made by
the resident inspectors and documented in NRC Inspection Reports 50-445/92-34;
50-446/92-34 and 50-445/92-42; 50-446/92-42.
The purpose of.these
observations was to determine if the installations conformed to the
fabrication practices developed during test specimen construction for the
I
licensee's sponsored fire tests.
Installation was found to be in accordance
I
with Procedure CQP-CV-107, " Application of Fire Barrier and Fireproofing
Materials," Revision 0, dated January 6, 1992, and Orocedure Change Notice 1
through 5, as well as Specification CPES-N-2032, "P ocurement and Installation
u
of Fire Barrier and Fireproofing Materials," Revision 0, dated February 28,
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1991, and DCA 95794.7.
These procedures were found to be maintained up to
date with fabrication improvements identified during test specimen
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development. To confirm the correlation between the test. specimen fabrication
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techniques and the installation procedure and specification, the NRC
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inspectors also observed test specimen construction and fire endurance testing
activities at Omega Point Laboratories in San Antonio, Texas.
.
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In addition to witnessing the licensee's test specimen construction and fire
testing activities at Omega Point Laboratories, the inspectors reviewed the
programmatic aspects of the CPSES, Unit 2, Thermo-Lag fire barrier design and
installation process. The inspectors, as part of this inspection process,
reviewed selected TU/0mega Point Thermo-Lag' fire barrier fire-endurance test
reports, the licensee design and installation specification, the licensee's
-
construction and installation procedure, and selec,ted Thermo-Lag fire barrier
j
installations and their associated installation work packages. The_ inspection
of the' field installations consisted of assuring that the work packages
3
reflected the programmatic process and that the construction attributes were
^
consistent with the design and construction criteria established by the
licensee's fire testing program. The following summarizes the areas
inspected:
' '
2.4.1 Fire Tested Configurations
!
The inspectors reviewed the construction attributes of the Thermo-Lag-fire
barrier test specimens described below to determine if they were properly
incorporated init the design and installation of the fire barrier. systems
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installed in Unit 2.
The following summarizes fire test reports reviewed:
Omega Point Project No. 12340-94367a, Scheme 9 - Assembly 1, Fire
Endurance Test of Thermo-Lag 330-1 Fire Protective Envelope (3/4-inch,
3-inch, and 5-inch Conduits with Radial Bends) November 23, 1992.
Omega Point Project No. 12340-94367c, Scheme 10 - Assembly 1, Fire
'
Endurance Test of Thermo-Lag 330-1 Fire Protective Envelope (Two 3-inch
Conduits with Junction Boxes) December 2, 1992.
Attachment 5 provides details of the inspector's review of the test ~ reports.
>
Using the test specimen design and installation descriptions'.documentsd in the-
'
subject test reports and verified by the supporting-QA/QC documentation, the
inspectors reviewed the licensee's design and installation specification to-
confirm that the design and construction attributes. verified by-the licensee's
'
fire endurance testing program were being properly implemented -into the design
and installation of the Unit 2 Thermo-Lag fire barrier' assemblies.
The
inspectors found that the attributes had been properly translated into the
licensee's design and installation _ procedures.
The adequacy of the licensee's
'
-fire test reports to qualify the Thermo-Lag fire barrier systems being
installed in Unit 2 is being evaluated by the Office of Nuclear Reactor
P,egulation and will be addressed in SSER 26.
.
.
2.4.2 Fire Barrier Design Specification
The inspectors reviewed Unit 2 Specification CPES-M-2032, " Procurement and
. Installation of' Fire Barrier and Fire Proofing Materials," to determine thatL
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the design and installation attributes, confirmed by the fire testing of
Scheme 9 - Assembly 1 and Scheme 10 - Assembly 1,-were properly incorporated
into the scope of this document.
Section III of the specification contains
the material and installation reouirements for the Unit 2 Thermo-Lag fire
barrier assemblies.
The inspectors confirmed that the appropriate design and
i
installation criteria, consistent with the criteria established by the testing
program (Scheme 9 - Assembly 1 and Scheme 10 - Assembly 1), were incorporated
.i
into this document.
For example, Section 3.2.5.2 to CPES-M-2032, requires the
3/4-inch preshape overlay to be applied over the 1/2-inch conduit fire barrier
,
4
preshape on 3/4-inch, 1-inch, 1 1/2-inch, and 2-inch conduits.
In_ addition,
i
this section specified the appropriate precaulking considerations and-.
)
consistent methods of fastening the conduit fire barrier assemblies in place.
The inspectors also confirmed that the appropriate design and installation -
'
attributes tested by Scheme 9 - Assembly 1 and Scheme 10 - Assembly 1, for the
radial bends, lateral bends (LBDs), and junction boxes (JBs) were incorporated
'
into this specification.
Section 3.2.5.4 to CPSES-M-2032 addresses the design
'
,
and installation of Thermo-Lag fire barrier material on radial bends while
,
Section 3.2.5.7 addresses the design and installation of Thermo-Lag fire
,
!
barrier assemblies for LBDs and JBs. The inspectors found these design and
installation attributes specified by the subject specification sections to be
consistent with those used for design and installation of the fire barrier
assemblies on fire test specimen Scheme 9 - Assembly 1 and Scheme 10 -
,
Assembly 1.
.,
In addition, to the design specification, the inspectors reviewed the
engineering drawings associated with the design and installation of the
'
Thermo-Lag fire barrier materials.
The drawings reviewed were the M2-1701
series (Sheets 1-15).
These drawings identified the typical details
associated with the installation of the harriers.
Attachment 6 provides a
summary of the typical details contained on these drawings.
!
,
The licensee has issued approximately 270 DCAs against these details.
are issued by design engineering to provide a design detail which addresses a
i
field installation condition which cannot be implemented through the
application of one of the typical installation details.
The inspectors
reviewed a sample of these DCAs to determine if they applied the required
i
design and installation attributes required by the licensee design and
installation specification. The discussion of this review is contained in
Section 2.6.
2.4.3
Fire Barrier Installatis , Procedure
,
In order to implement the design and installation criteria specified by Design
' '
Specification CPES-M-2032, the licensee established Construction / Quality
Procedure CQP-CV-107, " Application of Fire Barrier and Fire Proofing
';
Materials." This procedure establishes the instaliation instructions used by-
installers and QC. inspectors to construct and verify that the Thermo-Lag
raceway fire barrier assemblies were installed properly and that the
construction attributes associated with these barrier systems were done
-
consistently and in a similar manner to those methods use to construct the
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fire test assemblies.
The inspectors reviewed Section 6.4 to CQP-CV-107,-
4
"Thermo-Lag 330-1 Applications for Cable and Raceway," to verify that the
design and construction criteria established by Design Specification
-
CPES-M-2023,. as supported by fire tested configurations Scheme 9 - Assembly 1
,
and Scheme 10 - Assembly 1, were incorporated into this procedure. The-
,
inspectors verified that Section 6.4.4. A has the special requirements for
installing Thermo-Lag on conduits, fittings, and JBs and found the
'
installation criteria established by Section 6.4.4.A to be consistent with the.
criteria established by Sections 3.2.5.2, 3.2.5.4, and 3.2.5.7 to Design
Specification CPES-M-2032.
'
'
In order to assure that the Unit 2 Thermo-Lag raceway fire barrier systems are
being installed in accordance with the installation criteria specified by
>
Installation Procedure CQP-CV-107, this procedure establishes the use _of _
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checklists which are followed by the craftsmen performing the installation-and .
used by QC to verify that the installation is being installed in accordance
i
with the applicable sections of the installation prc edure. The. inspectors
confirmed that the major construction considerations and attributes of.these-
fire barrier assemblies were properly identified by the checklists.
Specifically,_the inspectors reviewed Procedure CQP-CV-107, figure 17.13,
"Backfit Verifications for Conduit - Checklist," and Figure.17.16, Thermo-Lag
330-1 Application on Conduit - Checklist."' The inspectors found these
checklists to provide the necessary inspection attributes which would
establish the basis for determining that the installed fire barrier design
conformed to the installation . criteria established by Procedure CQP-CV-107.
)
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2.5 Fire Barrier Installation Work Packages
!
,
The inspectors toured Unit 2 to review the ongoing installation of Thermo-Lag
fire raceway fire barriers.
During this walkdown, the inspectors selected a
.
sample of protected raceways which had the Thermo-Lag fire barrier material
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installed to review the fire barrier installation documentation.
The inspectors found that the appropriate installation checklists were
t i
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contained in the CWD packages and that the packages containeo. sufficient
detail to facilitate the implementation of the work by the craft.
In
,
addition, for those installation configurations which deviated from the
standard construction and installation guidance provided by-
'
Procedure CQP-CV-107, the inspectors verified that these packages-contained
the appropriate DCAs.
As part of the construction process: associated with _
.
'
- each installation, QC performed a surveillance of the installation while work:
was in progress.
These surveillance activities were performed daily and were
- found appropriately documented.
In addition, any rework resulting from these
QC surveillance activities was. identified and documented. A summary of fire'
barrier installations inspected, applicable components, and CWDs reviewed;is
provided as Attachment 74
From these visual inspection, the inspectors could verify that certain
'
upgrades as required by Installation Procedure CQP-CV-107 and design and
,
-Installation Specification-CPES-M2032 had been implemented. On the multitray!
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and the two-tray configuration, the inspector was able to verify that the
seams and joints were upgraded with stress skin and properly skim coated with
trowel grade material.
On the JBs inspected the inspectors could verify that
the corners and joints of these boxes were upgraded with stress skin.
The
inspection of the conduits (1 1/2-inch) in the Unit 2 essential chiller room
and on Elevation 832' of the safeguards building visually verified that these
conduits were upgraded with the required overlay.
This was done by evaluating
the diameter of the fire barrier material applied to conduits.
From this
limited visual inspection of the fire barrier assemblies identified in
Attachment 7, the inspectors found that the upgrades required by the
licensee's installation procedure and design specification were being-
implemented.
2.6 Fire Barrier Deviations and Special Configurations
The inspectors sampled conditions where the fire barrier installations
dc'/iated from the conditions of the licensee's fire test program, the design
,
and' installation procedure, and the installation procedure.
The. licensee
documents these deviations by issuing a DCA against the field condition which
deviates.
The DCA identifies the fire barrier installation problem and
.
,
provides the design detail and the applicable installation guidance to resolve
the problem.
In addition, the DCA provides the engineering basis for the
change and assesses the impact of the change on the fire rating of the
commodity being protected by the Thermo-Lag fire barrier material.
The
inspectors reviewed the DCAs listed in Attachment 8 to determine if the
licensee considered the fire barrier upgrade attributes and if the fire
barrier design considerations specified by the design and installation
specification were applied in the resolution of these fire barrier deviation
conditions.
From the DCAs reviewed the inspectors found that, as fire barrier design
- '
configurations are being. qualified by the licensee's Thermo-Lag fire Sarrier
fire testing program, these upgrade changes are being incorporated in o the
typical design details.
The inspectors also found that for the'DCAs issued to
address cases which deviate from tested configurations, the same design and.
,
installation attributes were applied.
The inspectors also reviewed eight Thermo-Lag fire barrier installations which
the inspectors viewed as not being bounded by the 1icensee's fire barrier
testing program.
This review included conducting a visual inspection of these
barriers.
At the time of this inspection, the licensee had not completed
,
their engineering evaluation justifying the fire resistance of these designs.
The adequacy of the licensee's engineering evaluations' for those conditions-
which deviate from the tested configurations is being evaluated by the Office
t
'
of Nuclear Reactor Regulation and will be addressed by the staff in SSER 26,
Attachment 9 summarizes the design of the fire barrier assemblies reviewed as
part of this inspection.
The construction and upgrade attributes used on the above configurations
i
appeared to be consistent with the design and installation requirements
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established by the licensee's design and installation specification and the
installation procedure. The inspectors found the continuity of material
application, the thickness of the material applied, and the. upgrade techniques
used to follow the same logic to those attributes applied to the fire test
specimens tested as part of Scheme 9 - Assembly 1 and Scheme 10 - Assembly 1.
2.7 Fire Brigade Use of Hose Streams
t
During the conduct of fire tests at Omega Point Laboratories in San Antonio,
i
Texas, an NRC inspector noted that the hose nozzle used for the hose stream
test produced a straight stream.
Previous tests using a straight: stream had
produced damage to the Thermo-Lag construction.
The licensee had stipulated-
that only a fog nozzle pattern would be used for the tests and suppression
practice in the plant would only allow use of a fog patte n since only E-rated :
nozzles were installed in the hose stations and these nozzles, by
construction, limit the hose stream to a minimum 30 degree fog pattern.
An NRC inspector reviewed the licensee's actions to prevent the inadvertent
use of a straight stream in areas of the plant where Thermo-Lag is installed.
The initial issues of the fire preplans for Unit 2 contain a precaution
requiring the use of a fog cattern in areas containing_Thermo-Lag
installations. The licensee has issued PCNs for the Unit 1 fire preplans that_
incorporate the same precaution.
The licensee has also incorporated this
information in the fire brigade training program, both as a current events
review and in-the initial fire brigade training. The NRC inspector conducted
a walkdown of a sampling of fire hose stations in Units 1 and 2 power blocks.
All observed hose stations were equipped with an E-rated hose nozzle that-
limits the hose stream to a minimum 30 degree fog pattern.
2.8 Conclusions
q
The inspectors found activities pertaining to the procurement, testing,
,
engineering, training, installation, and quality' assurance of Thermo-Lag as a
'
fire barrier .. ,: am to be strong. The -licensee has provided reasonable
assurance that implementation of Thermo-Lag will satisfy the intended function =
to protect fire safe shutdowa power and control circuitry.
The licensee has .
J
taken appropriate actions to preclude Thermo-tag from being damaged _by the use
_
of a straight stream suppression nozzle.
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ATTACHMENT 1
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1 PERSONS CONTACTED
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-1.]
TV ELECTRIC
T. Hope, Site Licensing Manager
H. Carmichael, Unit 2 Project Management
D. Moore, Maintenance Manager
C. Hooton, Unit 2 Engineering
J. Ayres, Operations QA Manager
D. McAfee, Manager, QA
W. Grace, Safety Services Manager, Production Division
,
R. Wakeman, Fire Protection Supervisor, Production Division
B. Taylor, Staff Assistant for Vice President, Nuclear Production
C. Beckett, Principal Engineer, Design Engineering
H. Dempsey, Electrical Engineer, Stone & Webster Engineering Corporation
M. Blevins, Director of Nuclear Overview
S. Harrison, Unit 2 Engineering Manager
R. Dible, Mechanical Engineer, Impell Corporation
C. Terry, Vice President, Nuclear Engineering and Support
H. Bruner, Senior Vice President
J. Snyder, Otartup Manager
C. Rau, Unit 2 Project Manoger
K. Williamson, Unit 2 Project Manager
J. Conly, Unit 2 Licensing Engineer
1.3 NRC Persannel
'
A. Singh, Reactor Inspector, Division of Reactor Safety (DRS)
P. Madden, Senior Fire Protection Reviewer, Office of Nuclear Reactor
Regulation
T.Reis,ProjectEngineer,DivisionofReactorProjects(DfP)
<
M. Murphy, Reactor Inspector, DRS
D. Graves, Senior Resident inspector, DRP
G. Constable, Chief,. Plant Support, DRS
.
The personnel listed above attended the exit meeting.
In addition to the
l
personnel listed above, the inspectors contacted other personnel during this
inspection period.
q
2 EXIT MEETING
An exit meeting was conducted on January 15, 1993. During f.his meeting, thel
.
inspectors reviewed the scope and findings of the report.
The licensee did
not identify as proprietary any information provided to or reviewed by the
inspectors.
.
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ATTACHitENT'2
1
M
Log # TXX-92640
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File # 10120
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1UELECTRIC
December 23, 1992
wnh.= J.c wa Jr.
o, , veam.* e
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNITS 1 & 2
DOCKET HOS. 50-445 AND 50-446
IN 92-18. PDTENTIAL FOR LOSS OF REMOTE SHUTDOWN
CAPABILITY DURING A CONTROL ROOM FIRE.
-
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Gentlemen:
The subject of matcr-operated valve (MOV) bot shorts was discussed during
the Unit 2 Fire Protection Inspection status meeting with the NRC on
December 17, 1992.
Although TV Electric considers this scenario to.have an
extremely low probability, TU Electric committed to implement design changes
in the control circuits of the affected MOVs (as required) similar to
Figures 5-and 6 of th6 subject NRC Notice.
Per our discussions-with the
Staff. TU. Electric is comMtting to implement these hardware modifications
prior to startup from the first refueling outage for Unit 2 and prior to-
>
startup from the third refueling outage for Unit 1.
Sincerely,
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W1111am J. Cahi.11 Jr.
By:
M
Roger D. Walker
.
Manager of Regulatory Affairs
for NEO
>
JTC/ds
c - Mr. J. - L-. Milhoan, Region IV
Resident Inspectors CPSES (2)
Mr. B. E. Holian, NRR
Hr. T. A. Bergman, NRR
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ATTACHMENT 3
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Log
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File # 10010
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1UELECTRIC
$gl4g
g,7,
y
January. 15, 1993
wmm J. CaMil.Jr.
am,, vw r o%w
U. 5 Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
FIRE PROTECTION INSPECTION
Gentlemen:
TU Electric hereby commits to the following corrective actions in response
to the NRC Fire Protection Inspection of Unit 2 conducted during
January 11-15, 1993.
Additions and relocations of detectors and sprinkler heads identified as
necessary by TU Electric's walkdown of Unit 2 will be completed by the end
of the fjrst refueling outage.
The high'. impedance fault study for Unit I will be reviewed to increase the
margin in the number of simultaneous cable faults assumed for low voltage
power supplies in safe shutdown circuitry by March 1, 1993. Any necessary
hardware modifications will be implemented at the next available opportunity
following issuance of the revised design, but not later than the next
refueling outage.
The existing emergency lighting batteries will be replaced in both Units
with 10-year-life batteries in accordance with the current replacement
schedule beginning June 1, 1993.
Specific Unit 2 thermolag configurations which deviate from tested
configurations have been technically justified through our design control
process.
An evaluation to compare these configurations to those tested or
provide in-depth anal) .is of these configurations is in process. The
scheduled completion date is currently under review.
Ladders and tools required for the successful performance of ABN-803B in
Unit 2 will be clearly identified and controlled to ensure their
availability as done in Unit 1.
This will be accomplished prior to entry
into Mode 4.
400 N. Olive Strm LB. 81 Dallas. Texas 75201
Pap,e 2 of 2
The preventive maintenance procedures will be performed on 100% of the Unit
2 safe shutdown emergency lighting prior to entering Mode 4.
A fornal root
cause evaluation of the emergency light failures will be performed in
accordance with existing site procedures.
,
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Sincerely,
y
William J. Cahill, Jr.
JTC/tg
c- Mr. J. L. Milhoan. Region IV
Mr. B. E. Holian, NRR
Resident Inspectors, CPSES (2)
.
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. ATTACHMENT 4
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AREAS REQUIRING SPRINKLER HEAD RELOCATION OR ADDITION
Addition and relocation of fire detectors in the various areas of the Unit 2
safeguard building are listed below:
Elevation
Room
Description
'
773
2-051
Containment Spray Pump Room 2-02/2-04
773
2-054
Containment Spray Pump Room 2-01-2-03
.
773
2-060
Safety injection Pump Room 2-02
773
2-062
Safety Injection Pump Room 2-01
852
2-100B
852
2-100C
NOTE:
The identified dimensions are from face of wall at the column line
indicated, not from the column centerline.
ROOM 2-051
CONTAINMENT SPPAY PUMP ROOM 2-02/2-04
Relocate existing detector to 9'-0"
E of A-S, 6'-4" S of 10-S.
Add new detec?or at 6'-9" W of D-S, 8'-1" N of 9-S.
.
ROOM 2-054
CONTAINMENT SPRAY PUMP ROOM 2-01/2-03
,
Relocate existing detector to 10'-3" E of C-S,
9'-6" S of 10-S.
Add new
'
detector,at 9'-0" W of D-S, 8'-0" N of 9-S.
,
ROOM 2-060
SAFETY INJECTION PUMP ROOM 2-02
,
Add new detector at 7'-0" E of A-5, 8'-0" N of 9-S.
ROOM 2-062
SAFETY INJECTION PUMP ROOM 2-01
Relocate existing detector to 5'-0" E of A-S, 5'7" N of 12.2-S.
Add new
detector at 6'-10" E of A-5, 7'-8" S of 13-S.
,
ROOM 2-100B.
FEEDWATER 150 VALVE ROOM
Relocate existing detector to 9'-4" E of D-S, 6'-10" N of 10-S.
ROOM 2-100C
FEEDWATER 150 VALVE ROOM
Relocate existing detector to 10'-0" E of D-5,
6'-0" N of Il-S.
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The following lists the areas where the licensee has identified th3 addition
and relocation of sprinklers at Unit 2.
1.
790 Corridor area
Sprinkler head modifications
Room-2-070
Add
2
.
Room 2-071
Add
8
Rel
2
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Del
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2.
810 Corridor area
!
-Sprinkler head modifications
Room 2-082
Add
2
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3.
810 Electrical equipment room .
s
Sprinkler head modifications
I
Room 2-083
Add
9
4.
831 Corridor area
Sprinkler head modifications
Room 2-094
Add
2
5. -852 Electrical equipment room
Sprinkler head modifications
Raom 2-103
Add
7
.
Rel
7
.
Del-
1
6.
Pipe penetration area
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Sprinkler head modifications
Room 2-100
Re1
1
.
Room 2-107'
Add
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. ATTACHMENT 5
DETAILED REVIEW OF OMEGA POINT LABORATORY
THERMO-LAG FIRE TEST REPORTS
.
Omega Point Project No. 12340-94367a, Scheme 9 - Assembly 1
The assembly fire endurance test, by Scheme 9 - Assembly 1, consisted of ~three
conduit loop configuration (5-inch, 3-inch, and 3/4-inch).
Each of these
loops extended through the furnace fire test deck, down into the furnace into
a 90* elbow (long side vertical) with a 8'-6" total horizontal run of conduit
which transitions to a 90* radial bend and back up through the furnace fire
test deck.
The Thermo-Lag 330-1 was applied to the test assembly (Scheme 9 - Assembly 1)
in the following manner:
Each rigid conduit was covered first with Thermo-Lag 330-1 preshaped
material sections prior to installing Thermo-Lag fire barrier material
to the trapeze conduit supporting member.
All conduit joints and seams
were precaulked (prebuttered) with Thermo-Lag 330-1 trowel grade
material and secured in place with stainless steel tie wire and banding
inateri al .
(Note - The fastener (banding / tie wire) spacing for the
prefabricated Thermo-Lag conduit sections on the vertical and horizontal
conduit runs was verified by the licensee QC inspection process not to
exceed 12 inches maximum on center.)
~
The Uni-Strut trapeze support member was covered with Thermo-Lag flat
panels. ~ The licensee's 9 inch coverage rule was applied, which treated
this support as a protruding item and required this support to be
-
protected by Thermo-Lag for a minimum distance of 9 inches from the
closest Thermo-Lag conduit preshape application.
The remaining Uni-
Strut support supporting the test specimen from the furnace fire test
deck was left unprotected from the-furnace fire source.
The joints and-
seams associated with the application of the fire barrier panels to the
trapeze support were precaulked with trowel grade material and secured
in place with stainless steel tie wire.
Each conduit 90 LBD fitting was covered with a flat panel fire barrier
material.
The fire barrier panels to cover the vertical sections of the
5-inch LBD fitting was scored in 12 places at 3-inch spacing to conform
to the LBD curvatur,e. All the joints and seams of the LDB Thermo-Lag
fire barrier box configurations were precaulked and secured in place
with stainless steel banding material.
After the initial installation of the Thermo-Lag fire barrier material
onto the surface of the test specimen, the licensee installed the
following upgrades:
The 3/4-inch conduit, after having the 1/2-inch nominal thickness
Thermo-Lag 330-1 conduit pre-shape applied, was upgraded by installing
an additional 1/4-inch nominal thickness overlay Thermo-Lag preshape
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conduit section.
The joints and seams of the 1/4-inch preshape overlay
were precaulked with trowel grade material and secured to the assembly
I
with stainless steel banding (banding used on the vertical and
horizontal conduit runs) or tie wire (tie wire used on the radial
,
bends).
For the radial bends, trowel grade material was applied to the outer
surface of the Thermo-Lag fire barrier radial bend preshape to depth of
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approximately 3/16 inch and allowed to set until tacky. Strips of
Thermo-Lag 330-69 stress skin 2 inches wide were trimmed into an
I
hourglass shape with the thinness dimension being 3/4 inch at the center
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of the shape and circumferentially wrapped around the radial bend and
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worked into the tacky trowel grade material.
The stress skin was then
secured in plac; to the Thermo-Lag radial bend preshape with 1/2-inch
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staples and stainless steel -tie wire.
Once the stress skin was properly
secured, a skim coat of trowel grade material was applied over the
stress sHn.
All the flat Thermo-Lag panels applied to-the LDBs had their joints
coated with trowel grade material (allowed to set ~ and become tacky) and
j
stress skin with a 2-inch overlap onto adjoining panels was applied to .
all LBD joints / seams. Where the conduit enters and exits the LBD,
stress skin was cut and applied in such a manner.that, when folded,
,
2-inch overlay of stress skin lapped over onto adjoining fire barrier
I
panels and preshape conduit. sections.
The stress skin was secured to
the Thermo-Lag LBD fire barrier boxes with 1/2-inch long staples. Where
the stra.s skin was attached to the conduit pre-shapes, a 2 in. stress
skin coliar was circumferentially wrapped around the conduit and stapled
in place.
Upon completion of the application of the stress skin to the
,
l
LBD seams and joints, a skim coat of Thermo-Lag trowel grade material
'
was applied over the stress skin.
Omega Point Project No. 12340-94367c, Scheme 10 - Assembly 1
The assembly fire endurance tested, by Scheme 10 - Assembly 1, consisted of
two parallel 3-inch conduit loops.
Each of these loops extended through the
l
furnace fire test deck, down into the furnace and into the 18-inch side of an
'
18 x 12 x 6-inch JB (vertically installed 21 inches above the horizontal run
of the conduits).
The two conduits exit the JB and are routed into 90' LBD
fittings (long side horizontal). The two conduits run horizontally from the -
elbows and enter a .second 18 x 12 x 6-inch JB (installed _ horizontally at the
mid span of the horizontal conduit run).
The conduits exit the JB and.are
routed horizontally.into a second. set of 90 LDB fittings- (long side vertical)
and back up through the furnace fire test deck.
The Thermo-Lag 330-1 was applied to the test assembly (Scheme 10 - Assembly 1)
in the following manner:
Each 3-inch rigid conduit was covered first with Thermo-Lag 330-1
preshaped material sections. All conduit joints and seams were
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precaulked (prebuttered) with Thermo-Lag 330-1 trowel grade material and
secured in place with stainless steel banding. material.
(Note - The .
fastener (banding wire) spacing for the prefabricated Thermo-Lag conduit
!
sections on the vertical and horizontal conduit runs was verified by the
licensee QC inspection process nct to exceed 12 inches maximum on
center.)
Each conduit 90 LBD fitting was covered with a' flat panel fire barrier
material. All the joints and seams of the LDB fitting Thermo-Lag fire
barrier box configurations were precaulked and secured in place with
stainless steel banding material.
The midplane tube steel support member supporting the JB in the
horizontal conduit run, was covered with Thermo-Lag flat single panel
sections.
The licensee's 9 inch coverage rule was applied, which
treated this support as a protruding item and required this support to
be protected by Thermo-Lag for a minimum distance of 9 inches from the.
,
JB Thermo-Lag preshape application.
The remaining tube steel support
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to the furnace fire test deck was left unprotected from .the furnace fire
source.
The joints and seams associated with the application of the:
'
fire barrier panels to the support were precaulked with trowel grade
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material and secured in place with stainless steal tie wire.
1
The JBs were covered with 1/2-inch thick flat panel material'and all
joints and seams of the fire barrier material were precaulked with
",
trowel grade material and .the assembly secured in place with stainless
steel banding,
,
After_the initial installation of the Thermo-Lag fire barrier material-
onto the surface of the test specimen, the licensee installed the
following upgrades:
Following the application of the first layer of Thermo-Lag flat panel
fire barrier material to the JBs, a second layer of Thermo-Lag' V-ribbed
panel material was applied over the first layer.
The ~ joints and seams
were precaulked and secured in place with stainless steel banding,
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After the second layer of Thermo-Lag was installed, a layer _of trowel ~
grade material was applied over all joints and seams (approximately
3/16-inch thick) and overlapping 2_ inches onto the Thermo-Lag. panels.
The trowel grade was allowed to set'until tacky to touch, then 4-inch
wide strips of. stress skin were applied to the joints (2-inch overlay in
either direction from the JBs corners) and the stress skin was worked
into the tacky trowel grade material in order to achieve proper bonding
of the stress skin to the preshape JB fire barrier panels. The stress ~
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skin overlays were secured in place using 1/2-inch long staples and a
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skim coat of trowel grade material was applied over the' stress-skin.
The1 application of-the fire barrier upgrades applied to the LBDs for
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this fire. test configuration were the same as those applied to Scheme 9
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' Assembly 1.
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ATTACHMENT 6
TYPICAL THERM 0 - LAG CONFIGURATION DRAWINGS
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H2-1701, Sheet 1
Details concerning the application of Thermo-Lag to support steel.
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M2-1701, Sheet 2
Banding and fire barrier material application details for JBs; details
for the construction of JBs with removable covers; and the installation
of fire stops in the conduits entering JBs.
M2-1701, Sheet 3
Detail for an air drop into the center of a cable tray.
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M2-1701, Sheet 3A
Detail for an air drop cable routed between two raceway protected by
Thermo-Lag fire barrier material.
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M2-1701, Sheet 3B
Detail for an air drop cable which penetrates through Thermo-Lag fire
barrier prefabricated panels.
M2-1701[ Sheet 4
Details for the installation of conduit preshapes and Thermo-Lag 660
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fire barrier material.
M2-1701, Sheet 4A
Details for Thermo-Lcg fire barrier (conduits) penetrating wall or
fl oo r.
M2-1701, Sheet 5
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Details for the installation of Thermo-Lag fire barrier prefabricated
panels on cable trays (e.g., straight runs) and_ the details associated
with the installation of a fire stop.in a cable tray.
M2-1701, Sheet 5A
Detail for the interface between Thermo-Lag fire barrier assembly and a
penetration seal.
M2-1701, Sheet 6
Details'for conduit LBDs, snug fit and box design.
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M2-1701, Sheet 7
Containment penetration /Thermo-Lag fire barrier interface detail.
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M2-1701, Sheet 8
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. Identifies additional details for Thermo-Lag protected 'JBs with
removable covers and provides a detail for a cable bundle protected with
Thermo-Lag 660 material that splits into two bundles.
M2-1701, Sheet 9
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Detail for applying Thermo-Lag fire barrier materials to a vertical
cable tray which is mounted flush to the wall.
M2-1701, Sheet 10
Thermo-Lag fire barrier shimming details.
M2-1701, Sheet 11
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Details for attaching the bottom and side Thermo-Lag panels to cable
trays.
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M2-1701,, Sheet 12
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Detail requiring the use of Sil-Temp to cover cables in tray that have a
fill within 1/2 inch of the top of the Thermo-Lag fire barrier tray
cover.
M2-1701,. Sheet 13
Details associated with fire barrier interferences (i.e., cable trays,
pipes conduits).
3
M2-1701, Sheet 14
Additional details associated with conduit / cable tray interferences.
M2-1701,. Sheet 15
Details associated with .the use of Thermo-Lag 660 material to wrap
cables routed in cable trays.
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ATTACHMENT 7
THERM 0 - LAG CONFICURATIONS AND RESPECTIVE WORK DOCUMENTS INSPECTED
TABLE
FIRE BARRIER ASSEMBLIES / CONSTRUCTION WORK DOCUMENTS
PLANT LOCATION
RACEWAY
CONSTRUCTION WORK
DOCUMENT REVIEWED
.
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Unit 2 Essential
Conduits C23G06046 and
TL-ECll5B778-COND-12
Chiller Room
CHCICE-06 and Junction
Box JB2A-0126.
Conduits C24W41899 and
TL-SB0094832-COND14
[
Safeguards Building
Junction Box JB255376W.
TL-SB0094832-SUPL-C14
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Elev. 832', Room 2-094
TLSB0083810-COND3
Safeguards Building
Conduits C22G03990 and
-COND4
Elev. 816', Electrical
C22G0627 and Junction
-COND5
Equipment Area 2-083
Box JB2S605G
-COND6
-SUPLC5
-SUPLC6
Safeguards Building
Elev. 810', Room 2-082
Tray T23GECE63 and
TLSB0082810-TRAY 3
Multi-Airdrop
-SUPLT3
Auxiliary Building
Configuration
Elev. 810', Corridor 2-
'
Multi-Tray and Air Drop
TL-AB0207810-TRAY 14
207.
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Enclosure (trays
-TRAY 15
T230ACG55, T230ACG52-
-TRAY 38
55, T230ACG75-76 and 40
conduit sleeves with
air drops into the
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trays)2
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Configuration not bounded by the licensee's fire testing program.
Engineering evaluation justifying the configuration is required.
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FIRE BARRIER ASSEMBLIES / CONSTRUCTION WORK DOCUMENTS
PLANT LOCATION
RACEWAY
CONSTRUCTION WORK
DOCUMENT REVIEWED
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Auxiliary Building
Two Tray Configuration
TL-AB0174790-TRAY 1
Elev. 790', Room 2-174
in Common Enclosure
-TRAY 2
(trays T220ABC14 and
T220ABC15)'
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Safeguards Building
Junction Box with
Elev. 832', Electrical
Removable cover (JB27-
TL-SB0096832-COND5
Equipment Area Room 2-
942)*
096.
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. ATTACHMENT 8
ENGINEERING JUSTIFICATIONS FOR UNTESTED THERM 0 - LAG CONFIGURATIONS REVIEWED
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DCA 100820 -
This DCA provided additional details for conditions
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where Thermo-Lag interfaces with penetration seals;
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revised the banding and tie wire details for cable
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tray Tee sections; and provided additional details for
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"V" groove / scoring Thermo-Lag for Raceway bends.
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DCA 101358 -
Provided details for installing Thermo-Lag fire
barrier material on structural steel used to support
the gypsum stairwell wall enclosures.
(Note - This
DCA is not applicable to raceway fire barrier
enclosures) .
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DCA 101524 -
Incorporated installation notes for structural steel
fire proofing details contained on M2-1701, Sheet 16.
DCA 101625 -
Pro" ides a detail to address the hanger plate
interference with conduit r25WO7502.
DCA 101918 -
Cable tray detail for making the transition from a
flat 330 panel to a V-ribbed 330 panel.
DCA 102729 -
Provide a detail for flex conduit protected by
Flexiblanket 660 interfacing with a penetration seal
blockout.
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DCA 102933 -
Identified a detail of the backfit of air drops of
2 inches and less with the addition of a third layer
of Flexiblanket 660 fire barrier material.
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DCA 102957 -
Detail for covering longitudinal cable tray
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joints / seams where interferences is to close to
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install stress skin and a 330 build-up.
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DCA 103061 -
Detail for enclosing two 2-inch conduits, C24Y41955
and C24W41900 into one Flexiblanket 660 enclosure.
DCA 103063 -
Provided a detail for protecting a protruding
structural steel support which interfaces with a
concrete wall (interpretation of the 9-inch rule).
DCA 103020 -
This DCA revised several of the M2-1701 typical
details to incorporate the fire barrier upgrades
qualified by the licensee fire barrier fire endurance
testing program.
The following is a summary of the
detail revisions:
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Revised JB detail, Sheet 2, Detail 2-3.3.
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Revised the flexiblanket detail to incorporate
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the third layer, Sheet 3, Detail-3-4,
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Revised the air drop into the center of a cable
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tray detail,-Sheet-3,LDetail 3-4.3 and
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Detail 3-4.4.
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. Revised the detail associated with the
transition from conduit pre-shape to ~
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Flexiblanket, Sheet 3.-Detail 3-5.2.and 3-5.2a.
Revised the detail for the installation of.
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conduit preshapes on conduits, 3-inch and
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larger, Sheet 4 Detail 4-1.
Revised.the detail for air drops protected with
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Flexiblanket, 2-inch and larger, Sheet 4,
Detail 4-2.
Revised the conduit details associated with:
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conduits less--that 2Ein. to incorporate.the
required upgrades, Sheet 4. Detail 4-1.1~.
Detail revised to incorporated the upgrade for
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flex conduit and air drops less than 2 in.,
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Sheet 4, Detail 4'.2.-l.
Revised the detail for conduits protected.by--
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pre-shape fire barrier material mounted adjacent
to a concrete surface, Sheet 4, Detail 4-3.1,.
Provided a revision to-the detail for oversized
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conduits mounted adjacent to a concrete surface,
Sheet 4, Details'4-6 and 4-7.
Revised the cable tray detail to incorporate the
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longitudinal seam upgrade, Sheet 5,
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Details 5-1.1 and 5-1 22
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provided a revision to the cable tray radial'
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bend oetail, Sheet 5, Detail 5-6,
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- Revised the details associated with banding.
cable-tray Tee f.ections, Sheet 5-7 , 5-8, 5-9.-
and 5-10.
provided a revision to the detail for cable-tray
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butt joints. Sheet 5, Detail 5-11.
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An f . bu'.
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Provided a detail associated with the transition
of cables exiting from.the end.of a cable tray
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to an air. drop, Sheet 5 , Detail 5-12.
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Provided a detail for. installing stress skin -
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overlay on cable tray splice plates, Sheet 5, .
Detail 5-14.
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Provided a detail for the stress skin upgrade'to
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LDBs, Sheet 6, Detail 6-1.
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ATTACHMENT 9
THERM 0 - LAG CONFIGURATIONS NOT BOUND U BY TESTING PROGRAM
Auxiliary Building Elevation 810', Room X-207
Configuration 1 - T'ree :able tray vertical stack assembly. This fire
barrier configuration encloses one 30-inch and two 24-inch cable trays
in a box assembly. The fire barrier box assembly encloses these trays
for a straight run of approximately 6 feet.
The box assembly is
approximately 5 feet in height. Cable trays T230ACA75 and T230ACG75 are
protected by Thermo-Lag as they enter and exit the fire barrier box
assembly. One side of the fire barrier box assembly is attached to the
concrete wall with Hilti-Bolts.
Penetrating the concrete wall inside
the fit e barrier box assembly is 40 conduit sleeves which exit the ca'le
a
spreading room and air drop their cables into the cable trays which are
enclosed by the box assembly. The-fire barrier box is constructed out
of 1/2-inch prefabricated Thermo-Lag 330-1 panels supported by a Uni-
Strut frame. The joints and seams are stitched and reinforced with
stress skin,
The top and bottom sections of the box that extend from
the tray to the wall use the score and fold method and are shaped
accordingly. The bottom panel is tie wired to every other rungs of the
bottom tray and the sides were banded through the side of Thermo-Lag
side panels to the tray:. (DCAs 103472 and 103489)
Configuration 2 - Two 24-inch tray vertical stacked configuration
similar to Configuration 1 above.
This box assembly contains nine
conduit , sleeves which exit the cable spreading room and air drop their
cables into the trays within the box.
Configuration 3 - This assembly at the time of the inspection was not
completed.
This configuration will enclose JB 2990 and a cable tray
together.
Auxiliary Building Elevation 790', Room X-174
Cordiquration 4 - This fire barrier assembly enclosed two cable trays
(1220ABC0e ana T230ACA24), en 18-inch end 12-inch, instalied parallel
running horizontally down the corridor.
This fire barrier enclosure is
approximately 60 feet in length. The enclosure is constructed in such a
manner that the trays have a Thermo-Lag partitien (except at the tray
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splice plates) separating the trays within the enclosure. The common
f
enclosure top and bottom is fabricated out of Thermo-Lag 330-1 panels
with the bottom panels being secured to the rungs of the trays with tie
wire.
This tie wire attachment is applied to every other rung, with at
least two ties per rung.
The seams of this configuration are provided
with stress skin overlays and the butt joints are stitched then overlaid
4
with stress skin (DCA 102471).
Safeguards Building, Elevation 810', Room 2-083
'
Configuration 5 - This configuration
. ncists of two vertical 24-inch
wide cable tray which air drop their cat Ns 'nto conduit sleeves which
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penetrate the concrete wall interfacing with Room 2-082.
The two cable
trays are independently protected with Thermo-Lag to the point that they
terminate and the cables air drop. At this point, a Thermo-lag box
(5 feet x 3 feet x 10 inches) enclosure has been constructed to enclose
,
the air drop cables and the conduit sleeves.
The box is secured to the
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wall with Hilti-Bolts and the joints and corners have been upgraded with
stress skin overlays (DCAs 101986, 103034, and 104124).
Configuration 6 - This configuration consists of two JBs, installed up
against a concrete wall, boxed together.
Between the JBs, only a single
layer of Thermo-Lag panel is installed.
The remaining exposed sides of
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the JBs are protected with two layers of Thermo-Lag fire barrier panel
material. The joints and seams have been overlaid with stress skin and
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trowel grade material .
The banding application could not be applied
circumferentially around the JBs.
The banding is attached to steel
angles which are bolted to the wall above and below these JBs
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(DCA 103634).
Safeguards Building, Elevation 810', Room 2-082
Configuration 7 - This configuration consists of cables air dropping out
of several embedded wall conduit sleeves and entering three short run
.
horizontal cable trays above the two service water lines running down
the corridor.
These cables exit these horizontal trays and air drop
into a 30-inch tray which runs under the service water lines. The
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cables leaving the sleeves are protected with Flexiblanket 660 fire
barrier material. When these cables enter the three horizontal trays
installed above the service water piping, they are protected in the
trays by Thermo-Lag 330-1 fire prefabricated panel system.
These trays
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are protected independently.
As these cables exit the tray segments
above the service water piping, they are protected by Flexiblanket 660
fire barrier material.
The cables enter the 30-inch tray though the top
of panel of the Thermo-Lag fire barrier system installed on this tray.
4
In order to accommodate the air drop cables entering the 30-inch tray, a
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12-inch wide x 43-inch long openint was cut into the top tray panel.
A
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6-inch high curb constructed out of Thermo-Lag 330-1 prefabricated
panels was installed around the opening and this opening was filled with
Thermo-Lag 660 trowel grade material (DCA 10301).
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Safeguards Building, Elevation 831', Room 2-088
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Configuration 8 - This configuration consists of enclosing two JBs
installed on a common support in one fire barrier enclosure.
Each JB is
enclosed in the first layer of Thermo-Lag 330 panel material separately
and the second layer was applied using the score and fold method to
enclose both JBs.
The joints and seams were either overlaid with stress
skin or are stitched (DCA 103184, 103192, and 103A81).
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