ML20056G483

Comment on Proposed GL 86-10,suppl 1, Fire Endurance Acceptance Criteria for Fire Barrier Sys Used to Separate Redundant Safe Shutdown Trains within Same Fire Area. Util in Total Agreement W/Numarc

ML20056G483
Person / Time
Site:	Farley
Issue date:	08/23/1993
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR39572 58FR39572-00013, 58FR39572-13, GL-86-10, NUDOCS 9309030175
Download: ML20056G483 (2)

Text

r Soutnem Nuclear OperaMg Company Post Cnice Box 1235

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Docket Nos. 50-348 50-364 73 G

Mr. Samuel J. Chilk Secretary of the Comaission U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch Comments on Proposed Generic Letter 86-10, Supplement 1

" Fire Endurance Acceptance Criteria For Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area" (58 Federal Reaister 38572 of July 23. 1993)

Dear Mr. Chilk:

Southern Nuclear Operating Company has reviewed the proposed generic letter " Fire Endurance Acceptance Criteria For Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area,"

published in the Federal Register on July 23, 1993. In accordance with the request for comments, Southern Nuclear Operating Company is in total agreement with the NUMARC comments which are to be provided to the NRC.

However, it is felt that the proposed fire endurance tests and acceptance criteria are not properly focused on the cable maintaining its functional characteristics. We recommend the following changes to the acceptance criteria of section V, third column of page 39577, Federal Register Volume 58, No.140:

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... For those barriers which are not capable of performing their intended function, a deviation based on demonstrating that the functionality of thermally degraded cables was maintained and that these cables would have adequately performed their intended function during and after a postulated fire exposure may be granted..."

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l 9309030175 930823 PDR PR MISC 5BFR39522 PDR.;

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O U. S. Nuclear Regulatory Commission Page Two to read "...For those barriers which are not capable of performing their intended function, an engineering evaluation which demonstrates that the functionality of the thermally degraded cables was maintained and that these cables would have adequately perfurmed their intended function during and after a postulated fire exposure shall be performed by the licensee and maintained fcr inspection within the plant records for review..."

i Further, the basis for the requirement for hose stream testing described in section VI of the draft Supplement, appears to be applicable more to the testing of penetration seals and fire zone barriers rather than one Sour or three hour cable tray wrap. Since the integrity of the barrier is c.ot regt. ired to protect the cable from the effects of a fire hose stream, and the barrier has already served its delaying function at a time when a hose stream might be applied in combating the fire, it is recommended that the criteria for cable wrap bcirier testing he revised to delete references to hose stream testing.

Should ycu have any questions, please advise.

Respectfully submitted,

((I )7hRf J Dave Morey DNM/JDK cc: Southern Nuclear Operatino Comcany R. D. Hill, Plant Manager U. S. tJuclear Reculatory Commission. Washinoton t D. C.

T. A. Reed, Licensing Project Manager, NRR L S. Nu: lear Reoulatory Commission. Recion 11 S. D. Ebneter, Regional Administrator G. F. Maxwell, Senior Resident Inspector