ML20056H564
| ML20056H564 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/1993 |
| From: | Mccracken C Office of Nuclear Reactor Regulation |
| To: | Marion A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9309100087 | |
| Download: ML20056H564 (6) | |
Text
O Juiy 13.1993 O
Mr. Alex Marion Manager, Technical Division Nuclear Management and Resources Council 1776 Eye Street, N.W., Suite 300 Washington, D.C. 2006-3706
Dear Mr. Marion:
On June 28, 1993, we met to discuss the Nuclear Management and Resources Counc'l's (NUMARC's) program for resolving the fire endurance and combustibility issues associated with Thermo-Lag 330-1 fire barrier systems.
On June 22, 1993, NUMARC gave the NRC copies of its Phase 1 proposed fire endurance test plan to help prepare for this meeting. This test plan included discussion of configurations to be tested, upgrades to be performed, baseline installation details, and fire test acceptance criteria.
During this meeting NUMARC informed the NRC that the fire endurance testing program will be accomplished in two phases.
In Phase 1, a vendor-supported test program, NUMARC will test upgrades that Thermal Science, Inc. (TSI) i designed for a Thermo-Lag 330-1 baseline fire barrier system. Upon evaluating the results of an Electric Power Research Institute (EPRI) survey of Thermo-l Lag installations and applications throughout the industry, NUMARC will complete Phase 2; that is the testing of baseline fire barrier systems of similar designs to those currently installed in operating plants. During the j
meeting, NUMARC described its plans to apply the results of these tests by i
I writing an application guide and giving the industry guidance for seeking exemptions or deviations to NRC fire barrier requirements.
You also presented your plans for addressing the combustibility issue.
Upon reviewing the information presented in the meeting and the Phase 1 test plan, the staff found areas in the program that need to be clarified, as described in the enclosed request for additional information pertaining to the proposed program. To enable the staff to review the Thermo-Lag program l
consistent with your schedule, please respond to our request for additional information by July 16, 1993.
If you have any questions, please contact Mr. Steven West, at (301) 504-1220.
Sincerelyanscei e 4r l
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NRC PDR Conrad E. McCracken, Chief l
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ENCLOSURE NUMARC THERMO-LAG 330-1 FIRE BARRIER TESTING PROGRAM REQUEST FOR ADDITIONAL INFORMATION On June 22, 1993, NUMARC submitted Phase 1 of its fire test prog.za to the NRC and on June 28, NUMARC met with the NRC staff, in a meeting open tu the public, to discuss its plans to resolve the technical issues associated with the fire resistance and combustibility of Thermo-Lag 330-1 fire barrier material. Upon reviewing the NUMARC Thermo-Lag Phase I test plan and the information presented during the meeting, the staff found the following areas that need to be clarified.
I.
VENDOR AND LABORATORY RESPONSIBILITIES In the Phase I test plan, NUMARC indicated that Thermal Science, Incorporated (TSI, the vendor) wrote the test plan, designed the upgrades, and wrote the installation procedure. On page 10, Paragraph 5.1.1.2 and Page 35, Section 12.0, " Quality Assurance \\ Quality Control,"
NUMARC stated that TSI will have a consultant present during all phases of this test program.
In the neeting of June 28, 1993, NUMARC indicated that TSI would not participate in constructing the test specimens or i
performing the tests. The role of TSI in this phase of the NUMARC program is not clearly described.
1.
Clarify the role that TSI has had and will have in this program and clarify the responsibilities that the TSI consultant will have to TSI, NUMARC, and Omega Point Laboratories.
2.
Explain how NUMARC plans to maintain independence from the vendor in this test program in areas such as constructing the test specimens, conducting the tests, and analyzing the test results.
3.
Explain what independent functions (for example, quality control)
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Omega Point Laboratories will provide for the overall test program.
II.
FIRE ENDURANCE TESTING A.
SELECTION AND CONSTRUCTION OF TEST SPECIMENS 1.
Please clarify which in-plant fire barrier configurations l
will be bounded (raceway type, components, dimensions, and materials) by the Phase 1 and Phase 2 test configurations.
2.
Explain in detail the construction of Phase 1 and 2 baseline assemblies and demonstrate that the construction attributes for these baseline assemblies represent the fire barrier construction techniques used to construct the barriers currently installed.
3.
The installation procedures and the installation details are not consistent, lacking sufficient details for topics such j
as "V" stiffener locations and runs and stainless stitch i
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spacing.
Please clarify these discrepancies between the installation procedure and the design details and submit the appropriate revisions to these documents.
B.
THERM 0 COUPLE PLACEMENT 1
The method of measuring internal temperature conditions and averaging the data from thermocouples identified in the NUMARC Phase I test plan is not consistent with the proposed NRC staff position of November 19, 1992. The bare copper conductor and thermocouples used to measure the temperatures of the unexposed surface of the j
fire barrier material on the bottom of the cable tray fire barrier assembly are routed in the tray with the cables on top of the tray rungs, not along the bottom of the rungs as specified in the proposed NRC staff position.
1.
Please justify how the proposed placement of the copper conductor is equivalent to the proposed NRC staff position.
2.
The plan did not include criteria for applying thermocouples on the cables within the raceway or the junction boxes (JB).
Please explain how routing a bare coopar conductor through the JB simulates cables laying up against the JB inner surface.
C.
PHYSICAL PROPERTIES OF THE RACEWAY The test plan does not identify the physical properties of the raceway assemblies being tested, including the conduit schedule, support systems, the dimensions of each component (for example, junction boxes), and the masses of the raceway components. The plan does not describe the methods for tracing the raceway components that will be used to construct the test specimens.
i 1.
Please provide the dimensions and thermal masses of the raceway components in this test program confirm that they are representative of the raceways protected by Thermo-Lag fire barriers throughout the industry.
t 2.
Please describe the process for ensuring the traceability of the raceway and components used to construct the test I
specimens.
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D.
CABLES USED IN TEST SPECIMENS NUMARC did not propose functional testing of the cables but will include cable fill in each cable tray test specimen. However, the I
test plan does not specify the percentage of fill or the types and sizes of cable. Although NUMARC stated that cables are needed for additional thermal mass, this additional thermal mass would not j
represent worst case or conservative conditions and would absorb
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l heat from the fire barrier material. This additional thermal mass {
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1 can impiave the performance of the fire barrier material and
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decrease the internal temperature profile measured by the thermocouples inside the raceway. Thus, the ir.ternal raceway temperature profiles would be considered indeterminate.
j 1.
Please explain how the proposed test program will apply
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generically and will be a worst case test of a barrier system since the added thermal mass would improve the performance of the barrier.
i 2.
Test Plan Section 3.0, " Tests and Performance Criteria,"
I indicates that a visual inspection of the cables will be 4
performed if the temperature criteria is exceeded. However, the test plan does not identify the size and type of cable
.j going to be used in the. cable tray test specimens.
In addition, the plan does not identify the type insulation and jacket material. The conductor size, type of cable and the-material composition of the insulation and jacket have a i
influence on thermal damage. Since these tests are l
considered generic, please identify the cable fill, conductor size, insulation and jacket material, and type of cables being used in the test specimens.
In addition, please verify that the proposed cables bound ~ the thermal-degradation conditions' of the cable types currently installed within plant specific Thermo-Lag fire barrier-systems. Without making a determination as to which cables are most susceptible to thermal damage, the results of the visual inspection, could be considered indeterminate.
3.
Functionality testing of the cables installed in the cable t
tray specimens is not included in the test plan and it is the staff's understanding that NUMARC does not plan to do this type of testing.
Please explain how NUMARC plans to justify deviation conditions when the thermal limits have been exceeded and cable thermal damage has occurred or the =
barrier has been breached by the fire or the hose stream test.
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E.
TEST REPORTS i
l The test report details identified in the test plan does not specify i
l the level of detail recommended by the American Society for Testing j
l and Materials (ASTM) Standard E119.
For example, the testing laboratory is not required to report test observations.
Please clarify the format and content of the proposed test reports by comparing the report content recommended in-ASTM E119 with the laboratory reporting attributes described in the test plan. u
i III. MATERIAL PROCUREMENT, QUALITY ASSURANCE AND QUALITY CONTROL During the meeting of June 28, 1993, NUMARC stated that some aspects of its test program will be performed under an Appendix B program.
A.
Please clarify the quality assurance and quality control programs, including which aspects of the procurement, construction, inspections, and tests will be covered by an Appendix B quality assurance program.
B.
Please explain, in detail, the procurement and receipt inspection processes and the specific responsibilities of NUMARC, ABB Impell, i
Omega Point Laboratories, other contractors, TSI and other vendors, and individual licensees in these processes. These processes should i
be described for all comoonents to be used in the test program such-as raceways, cables, and' fire barrier materials.
C.
Please describe the material controls program and the NUMARC processes for ensuring that the fire barrier materials being i
supplied by TSI to support this phase of the testing program is equivalent to the chemical composition of the Thermo-Lag fire barrier material installed in the plants.
IV.
COMBUSTIBILITY During the meeting, NUMARC presented plans to address the combustibility of Thermo-Lag 330-1 fire barrier material. The data from NUMARC tests supports the conclusion that the material is combustible. The fire hazard information from tests indicates the ignition temperature, flame spread, and heat release rates of the fire barrier material. This type of information supports the combustible loading analysis in a fire i
hazard analysis.
A.
Please compare the fire hazards that may be introduced by Thermo-Lag 330-1 fire barrier material with the fire hazard characteristics derived by testing to the same test standards for I
other in-plant combustibles or fire barrier materials.
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B.
In the presentation, NUMARC did not substantiate the burning characteristics of Thermo-Lag materials under various configurations when exposed to the conditions of a full scale fire.
Please describe NUMARC plans for conducting full scale experiments to
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evaluate the burning characteristic of this fire barrier material.
For example these experiments should be based on cable tray stack configurations enclosed in Thermo-lag fire barrier spanning a 20-foot combustible free zone and should represent worst case in-plant conditions.
C.
During the meeting, NUMARC representatives presented the Thermo-Lag fire model scenario and a combustibility acceptance screening model.
j However, the results of these type of analysis may not demonstrate i
compliance with certain NRC guidelines and regulations.
Please )
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submit a description of the NUMARC combustibility program, including test results, and address how the program will demonstrate that i
current plant configurations meet NRC guidelines and regulations for the use of noncombustible radiant heat shields inside containment and 20-foot combustible free zones.
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