ML20035F983
| ML20035F983 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/16/1993 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2132, GL-92-08, GL-92-8, IEB-92-001, IEB-92-1, NUDOCS 9304230180 | |
| Download: ML20035F983 (7) | |
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CENTERIOR ENERGY Donald C. Shelton 300 Madison Avenue Vice Presdent Nudear Toleco, OH 436520001 Daws Besse (419)2492YJ3 April 16, 1993 Docket Number 50-346 License Number NPF-3 Serial Number 2132 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subj ect:
Fire Protection: Response to Generic Letter 92-08, j
Thermo-Lag 330-1 Fire Barriers j
Gentlemen:
Toledo Edison (TE) received the Nuclear Regulatory Commission's (NRC)
Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers," on January 6, 1993 (TE Log Number 3916). Generic Letter 92-08 requested additional information to verify that Thermo-Lag 330-1 fire barrier systems manufactured by Thermal Science, Incorporated (TSI) comply with the NRC's requirements. This letter provides TE's response to Generic Letter 92-08 as applicable to the Davis-Besse Nuclear Power Station (DBNPS).
NRC Reporting Requirement 1.
State whether Thermo-Lag 330-1 barriers are relied upon (a) to meet 10 CFR 50.48, to achieve physical independence of electrical systems, (b) to meet a condition of a plant's operating license, or (c) to satisfy a licensing commitment.
If applicable, state that Thermo-Lag 330-1 is not used at the facility. This generic letter applies to all 1-hour and all 3-hour Thermo-Lag 330-1 materials and barrier systems assembled by any assembly method such as by i
assembling preformed panels and conduit shapes, as well as spray, travel and brush-on applicat2ons.
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Docket Number 50-346 License Number NPF-3 Serial Number 2132 Page 2 Toledo Edison Response 1.
Toledo Edison uses Thermo-Lag 330-1 barriers to meet 10 CFR 50.48 requirements for protection and separation of the safe shutdown capability at DBNPS. A listing of the rooms at DBNPS using Thermo-Lag 330-1 1-hour and 3-hour fire barrier system to protect and separate the safe shutdown capability was provided in TE's response to NRC Bulletin 92-01, Supplement 1, dated September 28, 1992 (Serial Number 2088). This list is also included as of this letter. Rooms containing radiant energy shields have not been included since they are not 1-hour or 3-hour fire barriers.
IRC Reporting Requirement 2.
If Thermo-Lag 330-1 barriers are used at the facility, I
(a) State whether or not the licensee has qualified the Thermo-Lag 330-1 fire barriers by conducting fire endurance tests in.
accordance with the hRC's requirements and guidance or licensing commitments.
(b) State (1) whether or not the fire barrier configurations installed in the plant represent the materials, workmanship, methods of assembly, dimensions, and configurations.of the qualification test assembly configurations; and (2) whether or not the licensee has evaluated any deviations from the tested configurations.
(c) State (1) vhether or not the as-built Thermo-Lag 330-1 barrier configurations are consistent with the barrier configurations used during the ampacity derating tests relied upon by the licensee for the ampacity derating factors used for all raceways protected by Thermo-Lag 330-1 (for fire protection of safe shutdown capability or to achieve physical independence of electrical systems) and (2) whether or not the ampacity derating test results relied upon by the licensee are correct and applicable to the plant design.
Toledo Edison Response 2(a) Toledo Edison has not performed any independent fire endurance testing of Thermo-Lag 330-1 fire barriers. Documentation and test results provided by TSI vere relied upon to establish i
qualification of the fire barrier materials at the time of installation. Toledo Edison is working with the Nuclear Management And Resources Council (NUMARC) in the development of methodologies and acceptance criteria for fire endurance testing of Thermo-Lag 330-1 fire barriers. It is expected that this-generic fire testing vill be representative of the Thermo-Lag 330-1 applications at DBNPS. Any application not enveloped by I
the NUMARC testing vill be separately evaluated by TE.
L Docket Number 50-346 License Number NPF-3 i
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Serial Number 2132' Page 3 l
2(b) The individuals who installed Thermo-Lag 330-1 fire barriers at DENPS vere properly trained to perform this task and used installation details and materials which were approved by TSI.
l Thermo-Lag 330-1 fire barriers at DBNPS vere designed and
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' installed to the methodology recommended by TSI at that time. A Quality Assurance audit of the barrier configurations and l
installation procedures was performed and no significant l
deviations were identified.
Installation applications were l
reviewed and approved by TSI.
Deviations from TSI's tested applications vere reviewed by TE in accordance with the provision of Generic Letter 86-10.
In addition, Toledo Edison has recently reviewed the installation procedures used by the Texas Utilities Electric Company during the recent test program conducted at Omega Point Laboratories.
l In our judgement, the installation procedures used at DBNPS are consistent with those used by Texas Utilities.
l 2(c) As stated in response to Item 2(b) Thermo-Lag 330-1 barrier installations vere performed by trained individuals using design and installation criteria approved by TSI. Thermo-Lag 330-1 l
barriers were not used for protection of cable trays at DBNPS.
Ampacity derating factors for electrical conduits were obtained from TSI test reports. In addition to the TSI test reports, l
Toledo Edison reviewed an independent test funded by 3M Company and performed by Underwriters Laboratories (UL). The ampacity-derating factors supplied by TSI were more. conservative than those determined by the UL test and, as such, vere used by Toledo l
Edison. Toledo Edison vill continue to monitor the results of the NUMARC ampacity derating testing.
l NRC Reporting Requirement 3.
Vith respect to any answer to items 2(a), 2(b), or 2(c) above in
'l the negative, (a) describe all corrective actions needed and include a schedule by which such actions shall be completed and (b) describe all compensatory measures taken in accordance with the technical specifications or administrative controls. When l
corrective actions have been completed, confirm in writing their completion.
Toledo Edison Response 3.
As stated earlier, Toledo Edison is working with NUMARC in the development of methodologies and acceptance criteria for fire endurance testing of Thermo-Lag 330-1 fire' barriers.
It is l
expected that this generic fire testing vill envelop the Thermo-Lag 330-1 applications at DBNPS. As results of-the NUMARC Fire Testing i
Program and the NUMARC Ampacity Testing Program become available, TE vill determine what long term corrective actions may be necessary. Schedules for the fire and ampacity testing programs i
1 vill be provided to the NRC by NUMARC.
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Docket Number 50-346 License Number NPF-3
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Serial Number'2132 Page 4 3
In the interim, Toledo Edison has established hourly fire vatch patrols as compensatory measure in the rooms where the Thermo-Lag 330-1 fire barrier system is used as a 1-hour or-3-hour fire j
barrier for the protection and separation of safe shutdown i
capability (see Attachment 1).
These compensatory actions are 1
consistent with those that vould be implemented by DBNPS i
administrative procedures.. These compensatory actions vere f
established on September 1, 1992 in response to NRC Bulletin 92-01, l
Supplement 1.
NRC Reporting Requirement 4.
List all Thermo-Lag 330-1 barriers for which ansvers to item 2'
- l cannot be provided in the response due within 120 days from the
-l date of this generic letter, and include a schedule by which such l
ansvers shall be provided.
Toledo Edison Response 4.
There are no additional 1-hour or 3-hour Thermo-Lag 330-1 barriers for which Toledo Edison must provide a response.
Should you have any questions or require additional information, please contact Mr. Robert V. Schrauder,. Manager - Nuclear Licensing, at (419)
(
249-2366.
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Very t 1 yours, N/\\s MAT /dle l
Attachment cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC Senior Project Manager S. Stasek, DB-1 NRC Senior Resident Inspector l
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Utility Radiological Safety Board 4
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Docket Number 50-346 License Number NPF-3
' Serial Number 2132 l
Enclosure Page 1 i
l RESPONSE TO GENERIC LETTER NUMBER 92-08 Ll t
THERMO-LAG 330-1 FIRE BARRIERS L
FOR DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 l
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i Toledo Edison's response to Generic Letter Number 92-08, Thermo-Lag i
330-1 Fire Barriers, is hereby submitted under letter Serial Number 2132.
h e:
D. C. Sh61 ton, Vice President Nuclear Sworn and subscribed before me this 16th day of April,1993.
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Docket Number 50-346 License Number NPF-3
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' Serial Number 2132
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List of Rooms at the Davis-Besse Nuclear Power Station j
Using Thermo-Lag 330-1 Fire Barrier System i
to Protect and Separate the Safe Shutdovn capability t
Room No.
Description Application l
l 53 Service Water Valve Room Conduit 105 Emergency Core Cooling System Conduit Pump Room 1-1 Structural steel
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110/110A Corridor Structural steel i
113A*
Hatch Area Conduit f
Structural steel i
114 Hiscellaneous Vaste Monitor Conduit Tank and Pump Room Structural steel l
l 225 Make-up Pump Room Structural steel l
304 Corridor Structural steel 313 Hatch Area Conduit f
l 314 No. 4 Hechanical Penetration Room Conduit l
323 High Voltage Switchgear Room B Conduit 324 Auxiliary Shutdown Panel and l
Transfer Switch Room Conduit 325 High Voltage Switchgear Room A Structural steel.
l 328 Component Cooling Vater Heat Exchanger and Pump Room Conduit i
331 Auxiliary Steam Boiler Room Damper 400 Equipment Hatch Area Passage Structural steel 401 Fuel Handling Exhaust Unit Room Structural steel 404 Corridor Structural steel j
i 427 No. 2 Electrical Penetration Room Conduit 428 Lov Voltage Switchgear Room F-Bus Structural steel t
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Docket Number 50-346 i
License Number NPF-3 o
Serial--Number 2132 i
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Page 2 l
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List of Rooms at the Davis-Besse Nuclear Power Station t
Using Thermo-Lag 330-1 Fire Barrier System to Protect and Separate the Safe Shutdown Capability i
' Room No.
Description Application 431 Turbine Area Damper i
504 Control Room Kitchen Damper
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507 Shift Supervisor Office Damper 509 Control Room Passage Damper
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- Continuation of same conduit from Room 105
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