ML20036A669
| ML20036A669 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/07/1993 |
| From: | Jun Lee PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20036A664 | List: |
| References | |
| IEIN-92-082, IEIN-92-82, OLA, NUDOCS 9305130057 | |
| Download: ML20036A669 (9) | |
Text
iAY-07-1993 10:OS FFOM P.G.F. E 20th F1oor TO 912023715950 P.04 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC ___ SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
AFFIDAVIT I,
John A. Lee, being duly sworn, hereby state as follows:
1.
I am employed under contract to Pacific Gas and Electric Company as a
Fire Protection engineer in the Nuclear Engineering Services Department of the Nuclear Power Generation Business Unit.
My nuclear fire protection experience includes managing the fire protection program of an operating utility, participating in NRC Appendix R audits, functioning as the fire protection consultant on utility audits, and leading projects which concentrate on assessing and upgrading nuclear fire protection programs.
My technical expertise is in the area of fire endurance of passive fire protection features, and I have been a consultant to the Electric Power Research Institute regarding issues concerning
'Thermo-Lag fire barrier material.
2.
I am a registered fire protection engineer and registered civil engineer under the laws of the State of California.
3.
I have been asked to address question number 2 in the April 16,
- 1993, Atomic Safety and Licensing Board " Memorandum (Questions for Parties)".
Question number 2 asks what rationale, if any, explains the apparent inconsistency between the NRC Staff's evaluation of Thermo-Lag as combustible in NRC Information Notice 92-82, dated December 15, 1992, and PGEE's evaluation of Thermo-Lag as noncombustible under Underwriter Laboratories standards in its September 28, 1992, response to Supplement 1 of NRC Bulletin 92-1.
4.
I have provided the information which forms the basis forithe attached " Response to Atomic Safety and Licensing Board Question Regarding Therno-Lag combustibility."
5.
The information contained in the attached " Response to Atomic Safety and Licensing Board Question Regarding Therno-Lag 9305130057 930507' PDR ADOCK 05000275 i
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. +c TMY-07-1993 10:08' FRCr1 P. G '4 E 30th Floor-TO-912023715950.
P.05 Combustibility" is true and correct to the best of my knowledge and belief.
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' John I. Lee STATE OF CALIFORNIA ggM - -
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CITY AND COUNTY OF SAN FRANCISCO SAUNDRA V. JACKSON i
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NDERf PUEUC-OCmRTM l
Sworn and subscribed to before san Femess oxnty me this 7th day of May,-1993 W Comennm Emme m.M W98 s
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.Muu Notary Public
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MAY-07-1993 10:08 FROM P.G.?. E 20th Floor TO 912323715950 P.06 PACIFIC GAS AND ELECTRIC COMPANY RESPONSE TO ATOMIC SAFETY AND LICENSING BOARD QUESTION REGARDING THERMO-LAG COMBUSTIBILITY In its April 16, 1993, order entitled " Memorandum (Questions f or Parties)," the Nuclear Regulatory Commission Atomic Safety and Licensing Board asked the parties to address the following question at a prehearing conference, now scheduled for May 11-12, 1993:
"2.
With respect to the second late-filed contantion, what rationale, if any, explains the apparent inconsistency between the Staff's evaluation of Thermo-Lag as being
' combustible' (NRC Information Notice 92-82, dated December 15, 1992, submitted as Attachment 2 to MFP's second late-filed contention),
based on NIST tests, and the Applicant's designation of Thermo-Lag material as being ' noncombustible' under Underwriter Laboratories ctandards in its submission of its interim compensatory measures on September 28, 1992 (Enclosure, Attachment 1,
at 2) (approved by the Staff by letter dated October 27, 1992)?"
PG&E has reviewed the Thermo-Lag combustibility test results contained in NRC Information Notice (IN) 92-82 in light of: (1) the NRC's definition of a
noncombustible material under Branch Technical Position (BTP) CMEB 9.5-1, Section B.4 and Generic Letter 86-10; (2) PG&E's previous qualification of Thermo-Lag for use as a noncombustible radiant energy shicld in DCPP Units 1 and 2 l
containments based on tests performed by Underwriters Laboratories in accordance with ASTM E-84; and (3) an engineering assessment by PG&E of the specific application of Thermo-Lag in containment, to determine whether or not the Thermo-Lag, "in the form in which it is used and under the conditions anticipated" (BTP CMEB 9.5-1, Section B.4), could become a combustible material in such a way as to negate its effectiveness as a radiant energy shield and result in fire damage to safe shutdown equipment.
my-07-1993 10:09 FROri '
P.G.F. E 20th Floor-TO 912023715950 P.07 l
Based on this review, including the engineering assessment of
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the specific application of Thermo-Lag for radiant energy shields within containment, PG&E concluded that Thermo-Lag meets the NRC definition of noncombustible material (BTP CMEB 9.5-1, Section B.4) in its specific application, and continues to provide an acceptable level of protection against the anticipated fire hazard within i
containment. Therefore, there is no inconsistency between IN 92-82 and PG&E's response to supplement 1 to Bulletin 92-01, and there is no current safety concern relating to PG&E's use of Thermo-Lag as a noncombustible radiant energy shield in DCPP containment.
This
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conclusion is based on:
(1)
The NRC's definition of noncombustible material is provided in BTP CMEB 9.5-1, Section B.4 and reiterated in GL 86-10 J
as follows:
"a.
A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.
l t
b.
Material having a structural base of noncombustible material, as defined in a.,
above, with a surfacing not i
over 1/8-inch thick that has a flame spread rating not higher than 50 when measured-using ASTN E-84. Test j
' Surf ace Burning Characteristics of Building Materials.'"
'l l
In performing the testing described in IN 92-82, NIST employed the definition of noncombustible provided by the Uniform Building Code
'j (UBC).
That definition is similar to the'above NRC definition.
i i
Part b) of the UBC definition applies to flame spread, and part b) of the NRC definition is the same.
Part a) of the UBC definition, i
which addresses base material burning characteristics, prescribes.
l that the material must conform to ASTM E-136, while the NRC-1,
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f1AY-07-1993 10:09 POr1
-P.G.2 E 30th Floor TO 912023715950 P.08 i
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definition addresses base material burning characteristics under i
anticipated conditions.
Thus, the difference between the two definitions is that the NRC definition expressly allows consideration of plant unique applications, whereas the UBC definition may not.
The basis for PG&E's plant specific 1
application is summarized below under items (2) and (3).
(2) PG&E previously has qualified Thermo-Lag for use as a radiant energy shield based on reliance on Underwriters Laboratories (UL) testing in accordance with ASTM E-84.
The UL testc demonstrated that Thermo-Lag has a flame spread of 5,_well within the BTP CMEB 9.5-1, Section B.4 flame spread requirement of 50 or less.
This very low flame spread of the base material I
i (Thermo-Lag does not utilize a surface material) indicates that the material docs not exhibit a propensity to burn. Thus, parts a) and b) of BTP CMEB 9.5-1, Section B.4 were satisfied and the material l
t was considered noncombustible.
t The NRC has not prescribed a specific test as a determinant of a
material igniting, burning, or supporting combustion (Part a.
of BTP CMEB 9.5-1, Section B.4) similar to ASTM E-136 as used by NIST t
in the tests reported by IN 92-82, either in Appendix R regulations f
i or implementing guidance.
Therefore, the ASTM E-136' test results
{
reported IN 92-82 do not invalidate or contradict PG&E's application of the previous UL test results under ASTM E-84 used to i
qualify the Thermo-Lag.
ASTM E-136 tests the material in a more j
severe environment than necessary for PG&E's specific application-
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as a radiant energy shield.
In addition, as an information' notice, l
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n4Y-07-1993 10: 10 FROM P.G.4 E 201h F1cor TO 912023715950 P.09 IN 92-82 by definition does not impose now requirements on licensees to retest or requalify Thermo-Lag.
(3) PG&E's engineering assessment of the fire hazards in the vicinity of the Thermo-Lag radiant energy shicids in containment indicates that the Thermo-Lag is not expected to be subject to the extreme temperatures or the presence of large heat fluxes similar to the conditions under which the NIST tested Thermo-Lag as reported in IN 92-82.
Therefore, in its specific application by PG&E, Thermo-Lag is a noncombustible material as defined by the NRC in BTP CMEB 9.5-1, Section B.4.
For these reasons, the NIST combustibility test results reported in IN 92-82 are not inconsistent with PGLE's conclusion that its Thermo-Lag radiant energy shields are noncombustible and will perform the required function as a radiant energy shield protecting safe shutdown equipment from a fire in containment.
However, this overall combustibility issue has been mooted by PG&E's decision earlier this year to voluntarily replace the Thermo-Lag in DCPP Units 1 and 2 containments with 3M material.
The Unit 2 replacement was completed during the recent Unit 2 fifth refueling outage, and the Unit i replacement is scheduled for completion during the upcoming Unit 1 sixth refueling outage, scheduled for Spring of 1994. (See PG&E Letter No. DCL-93-109, April 30, 1993).
PG&E understands, based on communications from the Nuclear Management and Resources Council (NUMARC), that the NRC staff plans to issue a supplement to Generic Letter 92-08 in the summer of 1993 *
- 9Y--07-1993 10:10 FROi1 P.G.P E 30th Floor TO 912023715950 P.10 the generic that may include more specific information relative s-Therno-Lag combtistibility issue.
In the meantime, PG&E continues to monitor NUMARC's Thermo-Lag evaluation program, including NUMARC's evaluation of any further testing needs related to the combustibility issue.
If the NRC provides new or revised generic guidance to licensees on the applicable standards for determining combustibility of Thermo-Lag in accordance with BTP CMEB 9.5-1, PG&E will evaluate and, if necessary, upgrade its current Appendix R firo protection program in light of that guidance.
t TOTAL P.10
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'93 14: 11 FROt1 PG E-NRS TO'BISHOPCOOK PAGE.0G2/002 C
Pacific Gasand Doctric Campany 77 Beale Street.floorn 1451 GregoryM Rueger P0. Box 770000 Sernor Vce Presider 4 are San Francisco.CA 94177 General Marager 415/973-4fe4 Nuclear Power Generattori Fax 415/973 2313 i
April 30, 1993 PG&E tetter No. DCL-93-109 U.S. Nuclear Regulatory Commission i
ATTN: Document Control Desk t
Washington, D.C.
20555 j.
=
4 Re:
Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Information Relating-to Response to Supplement 1 of Bulletin 92 Gentlemen:
i PG&E submitted PG&E Letter No. DCL-92-208 (HBL-92-060), dated September 28, 1992, in response to Supplement I of Bulletin 92-01, " Failure of Thermo-Lag 330 Fire Barrier System to Perform its Specified Fire Endurance Function," dated. August 28, 1992.- In DCL-92-208. PG&E noted the fire areas at Diablo Canyon Power Plant Units'I and 2 where Thermo-Lag was used as a 1 or 3-hour fire barrier.
Also in DCL-92-208 PG&E included a discussion of the Thermo-Lag _used for radiant energy heat shields in the Units I and 2 containments.
DCL--
92-208 noted that these radiant energy heat shields are outside the scope of Bulletin-92-01 and, therefore do not require interim compensatory measures.
This is to inform you that, subsequent to DCL-92-208, PG&E has elected to replace.the Thermo-Lag used in these heat:
shields.
1 Accordingly, Thermo-Lag heat shield material in Unit 2 containment was_
replaced with 3M material during the recent Unit 2 fifth refueling outage. The Unit I containment Thenso-Lag heat shield material is scheduled for replacement with 3M material during the upcoming Unit -1 sixth refueling outage, scheduled to begin in the Spring of 1994.
Sincerely, s
n-Gregory M. Rueger cc:
Ann P. Hodgdon-John B. Martin Mary H. Miller.
Sheri R. Peterson CPUC Di.ablo Distribution 6094S/85K/ALN/2242 l
gffl@-3 M-
- TOTAL PAGE.002-**
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UNITED STATES OF AMERICA N
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING *CBOARD 10 P3 :39 Docket Nos'.'[#NO-R75-OLA". ;( 7 7 I
[
In the Matter of:
)
}
l Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Power
)
Recapture)
Plant, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " PACIFIC GAS & ELECTRIC COMPANY'S INITIAL RESPONSE TO QUESTIONS FOR PARTIES" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk (*), by hand delivery, or as indicated by the (t) symbol, by deposit for Federal Express delivery, this 7th day of May, 1993.
Charles Bechhoefer, Chairman
- Frederick J.
Shon*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jerry R. Kline*
Office of Commission Appellate Administrative Judge Adjudication Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Office of the Secretary Ann P. Hodgdon, Esq.*
U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn:
Docketing and Service Washington, DC 20555 Section (original + two copies)
Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.'Fairchild U.S. Nuclear Regulatory Commission California.Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco,_CA 94102
r-Nancy Culver, President Truman Burns Board of Directors California Public Utilities San Luis Obispo Mothers for Peace Commission P.O.
Box 164 505 Van Ness, Rm. 4103 Pismo Beach, CA 93448 San Francisco, CA 94102 Robert R. Wellington, Esq.
Christopher J. Warner, Esq.(t)
Diablo Canyon Independent Safety Richard F. Locke, Esq.
Committee Pacific Gas & Electric Company 857 Cass Street, Suite D 77 Beale Street Monterey, CA 93940 San Francisco, CA 94106 Robert Kinosian Jill ZamEk(t)
California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor MHB Technical Associates 1723 Hamilton Ave., Suite K San Jose, CA 95125 I
David A. Repka Counsel for Pacific Gas &
Electric Company L