ML20035E816
| ML20035E816 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/15/1993 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, IEB-92-001, IEB-92-1, TXX-93091, NUDOCS 9304190283 | |
| Download: ML20035E816 (4) | |
Text
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
===7 ' :::
Log
File # 10119 (NRCB 92-01) 10012
~"
10035 (GL 92-08) illELECTRIC lNggo_,g g,,_
y l
10CFR50.54 Winiam J. Cahill. Jr.
Apri1 15, 1993 Gramp t uw Presoknr U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 i
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 DOCKET NO. 50-445 RESPONSE TO GENERIC LETTER 92-08 THERM 0-LAG 330-1 FIRE BARRIERS REF:
1)
TV Electric letter logged TXX-92331 f rom l
William J. Cahill, Jr., to NRC dated July 9,1992:
Response to NRC Bulletin 92-01 2)
TU Electric letter logged TXX-92446 from William J. Cahill, Jr., to NRC dated September 18, 1992:
i l
Response to NRC Bulletin 92-01, Supplement 1 l
3)
NRC letter from Thomas A. Bergman to William J. Cahill, Jr.,
dated September 22, 1992 4)
NRC letter f rom Thomas A. Bergman to William J. Cahill, Jr.,
dated October 2, 1992 5)
TU Electric letter logged TXX-93038 from William J. Cahill, Jr., to NRC dated January 19, 1993 6)
TV Electric letter logged TXX-93136 from William J. Cahill, Jr., to NRC dated March 23, 1993 Gentlemen:
Generic Letter 92-08, dated December 17, 1992, stated that all addressees are required, pursuant to section 182(a) of the Atomic Energy Act of 1954, as amended, and 10CFR50.54(f), to submit a written report within 120 days from the date of this generic letter.
TV Electric has reviewed the actions requested and reporting requirements of this Generic Letter.
l TU Electric provided responses for CPSES Unit 2 by reference 5.
TV Electric's responses f or the Thermo-Lag fire barrier installations at CPSES Unit 1 is provided below.
As stated in response to NRC Bulletin 92-01 and Supplement I to the Bulletin (reference 1 and reference 2). Thermo-Lag 330-1 fire barriers are ht l
4on1?n i
g41gg gpgh
<=. ose s,,,, uui o.nm. m. mni j
P PDR l
i i
l l
i l
Page 2 of 3 relied upon to satisfy regulatory requirements and licensing commitments related to 10CFR50.48 at CPSES.
Thermo-Lag 330-1 fire barriers are not installed for the sole purpose of achieving physical independence of electrical systems.
However, these barriers are relied upon to achieve physical independence of electrical systems as required by Regulatory Guide 1.75 only where such systems requiring physical independence also require protection for ensuring fire safe shutdown capability.
TU Electric is currently participating in a generic effort with the rest of the nuclear industry and Nuclear Management And Resources Council (NUMARC) l to ascertain designs and installations of fire barriers which satisfy 10CFR50 Appendix A. General Design Criteria (GDC) 3.
The ampacity derating f actors used for raceways protected by Thermo-Lag 330-1 fire barriers at CPSES are conservative based on available test data and reference 6 identifies the typical conservatism included in the CPSES design.
A final i
assessment of ampacity derating will be made upon confirming all the l
installation configurations for CPSES Unit 1.
l
(
Since there are various options under consideration to resolve the issue, further assessment is needed to determine the approach that satisfies GDC-3 without causing an unjustified impact on the industry.
Some of the options being considered include (1) performing additional testing to demonstrate the acceptability of the installed configurations; (2) identifying, testing (if existing CPSES testing is not applicable) and installing
- upgrades
- for the existing configurations: (3) replacing Thermo-Lag with an alternate fire barrier system: (4) revising the barrier commitments / regulations such that some existing designs would be acceptable and GDC-3 would still be satisfied; and (5) modifying other aspects of the plant's design (e.g., addition of spr 1klers or detectors, relocation of raceway, redefining fire area bounda,ses, etc.).
The schedule to complete these actions depends upon the final course of action chosen.
For example.
rulemaking, which presently appears to be the best course of action, could take longer. TV Electric will continue to work with NUMARC, the nuclear industry and the NRC but a final completion date cannot be established at l
this time.
It is expected the specific test schedules will be provided to the NRC by NUMARC.
In the mean time, CPSES Unit 1 has implemented fire watches as compensatory measures in accordance with the Fire Protection Program as noted in reference 1.
By reference 3 and ref erence 4. the NRC accepted TU Electric's response to the NRC Bulletin 92-01 and it's supplement and requested that TV Electric m.,
. TXX-93091 Page 3 of 3 inform the NRC when corrective actions are complete.
Presently corrective actions are ongoing and test schedules will be provided by NUMARC.
As requested by Generic Letter 92-08, TV Electric will confirm in writing upon completion of the required corrective actions.
Sinc rely,
/
l l
William J. Cahill, Jr.
l JMK/0B/grp Attachment c-Mr. J. L. Milhoan. Region IV l
Mr. L. A. Yandell, Region IV l
Mr. B. E. Holian, NRR Mr. T. A. Bergman, NRR Resident inspectors, CPSES (2) i i
)
i i
1 l
l l
4
" Attachment to TXX 93091 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Texas Utilities Electric Company
) Docket No. 50-445
)
(Comanche Peak Steam Electric
)
Station. Unit 1)
)
AFF10AVIT William J. Cahill. Jr. being duly sworn, hereby deposes and-says that he is Group Vice President. Nuclear of TU Electric. the licensee herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission
~
this response to Generic Letter 92-08 for the captioned facility; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge.'information and belief.
WilliamJ.C%ill.Jr',' V Group Vice President. Nuclear STATE OF TEXAS
)
)
COUNTY OF SomesvdLL
)
d Subscribed and sworn to before me, on this
/F - day of GPF 8 8-1993.
$W 2 *- 4 Iotary PuMic V
[N~
r:. A mrca l}l q.-
- w g..
m es
- g_.'___.
- .:an.nu
. '