ML20035C217
| ML20035C217 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/30/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rogers, Selin, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20035C218 | List: |
| References | |
| 2.206, NUDOCS 9304060343 | |
| Download: ML20035C217 (7) | |
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March 30, 1993 i
MEMORANDUM FOR: The Chairman Comissioner Rogers Comissioner Curtiss Comissioner. Remiek
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Comissioner de Planque i
FROM:
James M. Taylor i
Executive Director for Operations
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SUBJECT:
COMANCHE PEAK UNIT 2 FULL-POWER LICENSING (SRM M930316)
On March 16, 1993, the staff briefed the Comission on the status of. the Comanche Peak Unit 2 full-power licensing review. On March 24, 1993, the plant achieved initial criticality and all low-power testing was successfully-f completed on March 28, 1993. An NRC inspection team observed initial. criti-.-
cality and low-power testing.
In a letter of March 28,.1993 (Enclosure 1)
TU Electric notified the NRC that it is ready for operation above 5% power.
Enclosures 2 and 3 provide additional information regarding current 10 CFR. 2.206 petitions related to Comanche Peak and technical-information regarding Thermo-Lag. The staff is also responding on March 30, 1993, to the Commission's Order of March 26, 1993, in the Construction Permit Extension Proceeding.
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The staff has assessed the status of the issues that the Office of l
Investigations (01) is reviewing pertaining to the Comanche Peak facility.
There is no change to OI's conclusion, stated in a memorandum of February 23*
1993, that the. subject issues "would not preclude the Comission's
'I consideration for a Full Power License."
On Mhrch 29, 1993, the Regional Administrator, Region IV, recommended to the~-
Director, Office of Nuclear Reactor Regulation, that a full-power license be issued to Comanche Peak Unit 2.
This recomendation -is enclosed for your information (Enclosure 4). On the basis of this recomendation, as well as on additional staff review, the Director of the Office of Nuclear Reactor Regulation has determined that the plant meets the' Commission's regulations,-
Contact:
Brian Holian, NRR i
504-1334 9304060343 930330 R
1 PDR ADOCK 05000446; F
PDR 1:
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Multiple Addresses' !
I and the activities authorized by a full-power license can be conducted without endangering the public health and safety. Accordingly, I recommend that the l
Commission vote to authorize the Director of the Office of Nuclear Reactor Regulation to issue a full-power license for Comanche Peak Unit 2.
Originalsignea by JIIB88 E M l
o James M. Taylor Executive Director for Operations l
Enclosures:
I.
Letter from TU Electric l
to NRC dtd. 3/28/93 2.
10 CFR 2.206 Petitions 3.
Additional Information on 4.
Memorandum from Region IV Thermo-Lag to Nep dtd. 3/I9/93 1
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10 CFR 2.206 PETITIONS The purpose of this enclosure is to provide the basis for the staff's recommendation that the full power license be issued for TU Electric's Comanche Peak Steam Electric Station (CPSES) Unit 2 with 10 CFR 2.206 petitions not finalized.
The two unresolved Comanche Peak 10 CFR 2.206 petitions are discussed below.
Comanche Peak Specific Michael Kohn, on behalf of Messrs. Macktal and Hasan, submitted a 10 CFR 2.206 petition on June 11, 1992. The petitioner alleges that the purchase agreement for Tex-La's minority interest in CPSES by TU Electric violates NRC regulations on restrictive settlement agreements. The NRC acknowledgement letter, sent to the petitioner on August 12, 1992, stated that staff review has determined that the agreements do not appear to violate the provisions of the Energy Reorganization Act or 10 CFR 50.7.
Notwithstanding, letters to TU Electric and the former co-owners of CPSES were issued on January 12, 1993, that requested information pertaining to the settlement agreements. The responses to these letters have been received and are being evaluated by the staff. The Director's Decision is expected to be issued in April 1993. The staff does not believe these issues affect issuance of a full power license for Unit 2.
Although there may have been the potential for safety information to have been withheld, the petitioner did not identify any issues with respect to which he believed information had, in fact, been withheld.
On the basis of the following, the staff concludes that there is no safety significance associated with the issues currently identified in this petition:
(1) No violation of the regulations has been identified with respect to the settlement agreements, nor were any safety issues identified, (2) About 12,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of direct inspection (since the resumption of Unit 2 construction) has been conducted at CPSES Unit 2 by NRC personnel, and (3) A recent NRC review of the licensee's SAFETEAM program (Inspection Report 50-446/92-60) concluded that the program provides both:
(a) a means for employees to bring concerns to management, and (b) plant management with a mechanism for the early identification of issues that could impact the safety of the plant.
The Commission requested additional information regarding this issue by an Order issued in the context of the construction permit amendment proceeding, dated March 26, 1993. The staff response is being filed on March 30, 1993.
. Generic Thermo-Lao The Nuclear Information and Resource Service (NIRS) submitted a 10 CFR 2.206 petition on July 21, 1992, as supplemented by addendum of August 12, 1992. On February 1, 1993, a Partial Director's Decision (DD-93-03) was issued regarding this petition.
On December 15, 1992, NIRS filed another petition pursuant to 10 CFR 2.206 regarding Thermo-Lag. This petition, which addresses numerous plants, including CPSES, Units I and 2, is being considered by the staff as a supplement to the petition filed on July 21, 1992. The acknowledgement' letter, issued on February 4, 1993, denied the requested action to shut down all plants with Thermo-Lag, stating that no immediate safety concerns were raised. The review of the petition, which reiterates items from a previous petition, and includes issues regarding Thermo-Lag voiding and stapling is expected to be complete by May 1993. The staff's evaluation of CPSES Unit 2 fire barrier acceptability is presented in SSER 26, in which the staff concluded that with several commitments, TU Electric's fire barrier program is acceptable. Thc staff specifically requested information on the stapling issue and although not explicitly discussed in SSER 26, was considered in the discussion on page 9-20 in support of this conclusion.
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4 ADDITIONAL INFORMATION ON THERMO-LAG This enclosure provides additional information regarding two issues relating to Thermo-Lag: hose stream testing and seismic concerns.
HOSE STpEAM TEST The American Society for Testing and Materials (ASTM), as part of their testing methods for determining the fire endurance for various types of building construction, adopted the current method for hose stream testing in 1933. Currently, fire testing standards are focused on building columns, walls and partitions, and floor construction.
The intent of the hose stream test is to impose a cooling, impact, and erosion effect on the building construction being evaluated. The weaknesses of a structural building system after being subjected to the hose stream test, fall into the following categories: structural failures, thermal (brittle) failures and erosion failures.
Focusing on raceway fire barrier systems, the staff, as part of their acceptance criteria development, examined the applicability of the ASTM standard hose stream test to these barrier systems. Staff consensus, during this examination, identified the need for some form of hose stream test.
The staff elected to adopt approved hose stream testing methods identified by Position 5.a to Standard Review Plan (SRP) 9.5.1, " Guidelines for Fire Protection for Nuclear Power Plants." This SRP position established the fire endurance and hose stream testing acceptance criteria for other non-structural fire resistive barrier components (penetration seals) and allowed the use of the fog nozzle method for hose stream testing.
The staff's rationale for allowing the use of the fog method is based on the following:
Structural Walls, fire doors and dampers are structural building components, whose failure could either contribute to the structural failure of the building or fire growth within the building.
Fire barrier systems used to separate safe shutdown functions within the same fire area are not considered to aid in the prevention of structural building collapse.
fire resistive construction techniques are used in the design of nuclear power facilities to prevent such structural failures.
In addition, the combustible fire loads are generally low.
Under actual in-plant fire conditions, structural collapse is unlikely.
Therefore, directional loads (simulated by the standard hose stream test) imposed on these barriers by falling structural objects during a fire is not expected.
Fire fighting activities, resulting from manual suppression can cause some level of barrier impact.
Manual fire fighting suppression operations in the areas of energized electrical equipment require the use of fog streams.
The fog nozzle test method (Pressure and Flow) simulates in-plant manual fire suppression techniques which would be employed by the fire brigade.
Cooling The fog stream method applies more water to the test specimen over a greater duration of time.
(Fog - 375 gallons vs. standard - 210 gallons) (Duration of application:
standard - 1 minute vs. Fog - 5 minutes).
The amount of water applied and the duration of application is sufficient to determine the thermal fragility of the barrier system under simulated fire fighting hose stream applications.
Erosion The Fog method is sufficient to demonstrate erosion conditions which would be encountered by the implementation of in-plant fire fighting techniques.
Experience (TV Electric tests) has demonstrated the ability of this method to impact the fire barrier material char layer, seams and joints.
This method is capable of eroding the char layer and has made openings in the areas of joints and seams. '(Scheme 12-2, 24-inch wide tray with T-Section, hose stream test damage)
Additionally, the staff considered the fact that nuclear power plant fire protection programs are based on a " defense-in-depth concept," (e.g.,
i prevention of fires; control of ignition sources; fire protection features which provide fire barrier separation between safe shutdown trains; rapid detection of a fire and smoke condition; automatic and manual fire suppression and control methods) in support of using the fog stream test method.
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- t-SEISMIC ISSUES The NRC does not require that fire protection systems, including features such as fire barriers, be formally qualified for seismic events. Such qualification is required for safety-related systems that are used to mitigate design basis events such as large pipe breaks. The NRC is requiring licensees to address the potential consequences of events beyond the design basis as part of a systematic review of plant vulnerabilities (Individual Plant Examinations for External Events). One area specifically to be examined is fires caused by earthquakes.
The staff has, however, specifically examined the potential for Thermo-Lag panels to break up during a seismic event, thereby creating a threat to nearby safety-related equipment. A 10 CFR 2.206 petition from Nuclear Information Research Service postulated such a breakup, with the panels acting as a shear (severing cables and shattering cable trays), thus jeopardizing safe shutdown.
To the NRC staff's knowledge, the Thermo-Lag vendor has not performed seismic tests of prefabricated panels. The staff has reviewed a seismic analysis (performed by a consultant to the Thermo-Lag vendor) of such panels attached to cable trays and conduit sections.
In addition, the staff visited a plant to understand more about Thermo-Lag usage, installation details, and material propertie:.
It is the staff's judgement after this review, that Thermo-Lag panels are not likely to get detached from raceways during a safe shutdown earthquake. Although the material may crumble and crack, the staff concluded that considering the material properties of Thermo-Lag and the design of raceways, shattering of raceways and severing of cables are not credible scenarios, and that the safe shutdown capability would be maintained. As i
discussed above, the beyond design basis accident scenarios of earthquake induced fires will be considered under the Individual Plant Examinations for External Events.
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