ML20063G873
| ML20063G873 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/11/1994 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, NUDOCS 9402170012 | |
| Download: ML20063G873 (20) | |
Text
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Beaver Valley Power Station snippingport. PA 15077-0004 4
JOHN D. SIEBER (412) 393-5255 Senior VICe President and Fax (412) 643-8069 U."rN$r$v$[on Februnry 11, 1994
^
i l
U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Dochet No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to Request for Additional Information
{
NRC Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers" i
Provided as Enclosure 1
is the response to the request for additional information regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers" for the Bem'ar Valley Power Station (BVPS)
Unit 2.
The enclosed report provides tne information requested in your letter dated December 21, 1993, concerning the configurations and the quantity of Thermo-Lag fire barriers installed at BVPS Unit 2.
An evaluation was previously developed for the existing Thermo-Lag fire barrier material installed at BVPS Unit 1 and was determined to be acceptable, thus resolving this issue for Unit 1.
This was identified in our previous submittal response to Generic Letter 92-08 (dated April 16, 1993).
Therefore, the following discussion will address the Thermo-Lag installations at BVPS Unit 2 only.
Should you have any questions regarding this information or require additional information, please contact John Maracek at (412) 393-5232.
Sincerely, y c: p.-,
- , E ', t6 A
D. Sieber Attachment
]
cc: Mr. L. W. Rossbach, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator Mr.
G.
E.
Edison, Project Manager fhfh THE WAR j
0-9402170012 940211 ip Qh '
DR ADOCK 05000334 lt!$
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AFFIDAVIT:
I COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF BEAVER
)
Subject:
Beaver Valley Power Station, Unit No. 1;and No. 2 BV-1 Docket No. 50-334, License No..DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to Request for Additional Information 1
NRC Generic Letter.92-08, "Thermo-Lag 330-l' Fire. Barriers"-
Before me,
the undersigned notary public, in and for the County and Commonwealth aforesaid, this. day personally ' appeared J'ohn.D.
- Sieber, to me known, who being duly-sworn according to law, deposes.
and says that he is Senior Vice President and Chief Nuclear Officer.
of the Nuclear Power
- Division, Duquesne Light Company, he:-is duly authorized to execute and file the foregoing submittal on behalf.of said
- Company, and the statements set forth.in:the submittal are true and correct to the best of his knowledge, information and belief.
]
ha John D.
Sieber-Subscribed and sworn to before me
//N day of [g[gvat
/fM on this
.t
/
Notary Publ'ic-tkAxiiiSeaf Wian V. Harper. Notary Putic Srgyngport Boro,BeaverCounty My Comrremon Expnc JJne 3.1995 h,kninr.PennsytesaAssooabon of No.a'wes l
4 l*
-Responss To Request for Additional Information l
NRC Generic Letter 92-08 For Beaver Valley Power Station'(BVPS) Unit 2 ENCLOSURE 1 i
l Pursuant to 10 CFR 50.54(f),
NRC requested that licensees provide j
additional information relative to Thermo-Lag 330-1 Fire Barriers.
This enclosure provides specific responses to each of the items requested.
I.B.
Thermo-Lag Fire Barrier Configurations and Amounts 1.
Describe the Thermo-Lag 330-1 barriers installed in the plant.
2.
Provide an approximation for the. total population of the l
Thermo-Lag fire barriers.
Response
Table 1
of this. enclosure provides a description and the approximate quantities of Thermo-Lag 330-1 fire barrier.
l installations at BVPS Unit 2.
1 I
Thermo-Lag 330-1 fire barriers are relied upon at BVPS Unit 2
(
to comply with the fire protection requirements of.10 CFR i
50.48.
Our use of Thermo-Lag 330-1, in order to comply with 10 CFR 50.48, is described.in our commitment to NRC Branch Technical Position (BTP)
CMEB 9.5-1,
" Guidelines for Fire Protection for Nuclear Power Plants,"
dated July 1981.
Therefore, installed.Thermo-Lag 330-1 fire barrier material j
is used at BVPS -Unit 2
to satisfy our fire protection licensing commitments as. described-in Section 9.5.1 and-l Appendix 9.5A of the BVPS Unit 2~UFSAR.
i Thermo-Lag 330-1 fire barrier systems have been used at BVPS Unit 2
to protect electrical power and control cables for l
systems and components used for achieving and maintaining safe shutdown conditions.
]
l Thermo-Lag was not utilized at LBVPS Unit 2 for Regulatory Guide 1.75 applications or as a radiant energy shield.
.The majority of the Thermo-Lag installations involve cable in-
- conduits, electrical junction boxes and pull-' boxes.
Thermo-Lag was not utilised for protection of cable tray applications at our facility.
Page'2 of 11 l
i Thermo-Lag 330-1 fire barrier systems installedL at BVPS Unit 2
were initially qualified Lto industry-standards applicable at that time.
Subsequently,.NRC Bulletin 92-01 and Supplement No. 1 reported the existing Thermo-Lag barrier qualification testing. invalid for protection of electrical.
raceways and. the fire : resistance Lrating of the Thermo-Lag l
material indeterminate.
The fire barriers in the affected -
areas were declared potentially. inoperable.and hour 3y fire-watch patrols were instituted as an interim measure.<
1 i
Actions to' restore operability are.being developed 1through an industry program being' coordinated by NUMARC.
Ba'Jed on our review of the NUMARC test program,1many of.the' encapsulated I
electrical raceways are comparable. in size ar.d' type to.the test program and should. be bounded.:.
However, until'the NUMARC
-Application Guide is issued and.BVPS-has an.
opportunity to review-it, we cannot. determine ;the exact extent. of the BVPS Unit 2 configurations that are bounded by the NUMARC test program.
t 1
I l
i Enclosuro 1 Page 3 of 11 II.B.
Important Barrier Parameters 1.
State whether or not you have obtained and verified each of the aforementioned parameters for each Thermo-Lag barrier installed in the plant.
If not, discuss the parameters you have not obtained or verified.
Retain detailed information onsite for NRC audit where the aforementioned parameters are known.
2.
For any parameter that is not known or has not been
- verified, describe how you will evaluate the in-plant barrier for acceptability.
3.
To evaluate NUMARC's application
- guidance, an understanding of the types and extent of the unknown parameters is needed.
Describe the type and extent of the unknown parameters at your plant in this context.
l
Response
l The NUMARC Application Guideline is expected to be issued in April
- 1994, and will provide final positions with respect to bounding parameters.
Based on NUMARC testing performed to
- date, the draft application guideline would address the parameters listed in Attachment 1,
" Clarified Parameter Listing as Provided by NUMARC."
This attachment provides NUMARC's clarified parameter listing, which includes each of the 24 points listed in the NRC letter.
Note that the parameters in Attachment 1
are separated into raceway parameters and barrier parameters, and the parameter numbers are different from the 24 item NRC listing.
An evaluation was conducted at BVPS Unit 2
using the l
following methods, j
l 1
1.
Reviews of contractor work practices and procedures through documentation.
2.
Field verifications of Thermo-Lag installations.
I 3.
Destructive examinations of barriers on a' sample basis to obtain information on construction techniques.
Walkdowns were performed which examined all applicable Thermo-Lag installations at BVPS Unit 2.
These walkdowns examined the 24 parameters as identified in the NRC letter.
1 Unique configurations were also examined and evaluated.
Thermo-Lag 330-1 fire barrier systems were not utilized for protection of cable tray applications at our facility.
- However, the cable tray parameter listings in Attachment 1 would be applicable for certain multiple conduit boxed enclosures installed at BVPS Unit 2.
h3ximum spacing of bands on encapsulated conduit installations were specified as 12 inches per the vendor i
Enclosuro 1 Page 4 of 11 installation instructions.
This is consistent with the NUMARC testing program.
- However, a
requirement for band spacing distance requirements from joints was not specified
- which, for some of our installations, exceeds 2 inches from the joints.
This unbounded parameter has been identified in the list of raceway configurations which are outside the scope of the NUMARC testing program (reference Attachment 2).
Planned Phase 2
NUMARC testing could identify further parameters of importance, or demonstrate that some of the parameters listed in Attachment 1 are not significant.
Based on the preliminary nature of the parameter listing and the final content of the NUMARC Application Guide, the parameter identification efforts may be incomplete.
Until the NUMARC Application Guide is issued and BVPS has an opportunity to review it, we cannot determine the eyset extent of t
configurations that are bounded by the NUMARC testing.
A supplemental response will be provided 90 days from receipt of the NUMARC Application Guide to complete the review and evaluation of the acceptability of our installations.
The 50.54(f) letter also provides an 8
item-listing of parameters of importance concerning cable protected by fire barrielm.
To the extent that fire test results. are satisfactory on the basis of temperature, as provided for in the NRC draft test and acceptance. criteria, the' listing of cable performance parameters should be limited to. the percentage of cable fill in cable trays (subset of item 4 of the NRC 8
item listing), which relates to enclosed thermal mass and barrier performance.
If NUMARC fire tests demonstrate temperature criteria exceedances, one optional approach to resolution, as provided i
in the NRC draft test and acceptance criteria, would be to evaluate cable functionality at the elevated temperatures.
In this case, determination of cable performance at elevated j
temperature would be necessary, using cable performance test data or information for specific installed-cable types.
j
- However, NRC has yet to finalize requirements for cable functionality evaluation, nor are test results yet available j
that would clearly indicate the scope of such evaluations.
The degree and conservatism of cable functionality evaluation requirements implied by the NRC listing of cable parameters, and discussed in proposed Supplement 1
to Generic Letter 86-10, significantly exceeds the original requirements of Generic Letter 86-10.
The 50.54(f) letter also discusses chemical testing of Thermo-Lag.
Chemical testing performed to date by NUMARC on a
wide variety of aged samples has not revealed significant variations in chemical composition.
In addition, Phase 2 NUMARC testing will include barrier materials of various
- ages, as well as additional chemical testing.
Unless unexpected results are encountered, we do not believe plant unique chemical evaluations should be necessary.
1 Page 5 of 11 i
III.B.
Thermo-Lag Fire Barriers Outside the Scope of the NUMARC.
I rogram 1.
Describe the barriers discussed under Item I.B.1 that you have determined will -not be bounded by the NUMARC test program.
2.
Describe the plant-specific corrective action program or-plan you expect to use to -evaluate the fire-barrier configurations particular to the plant.
This description should include a discussion of the evaluations and-tests being considered to resolve the-fire barrier issues identified-in GL 92-08 and to demonstrate the adequacy of existing in-plant barriers.
3.
If a
plant-specific fire endurance test program is anticipated, describe the following:
a.
Anticipated test specimens.
b.
Test methodology and acceptance criteria including cable functionality.
Response
While the scope of the-NUMARC test program is known, what will ultimately be " bounded" is a function of the outcome of the t sts, and the final content of the NUMARC Application Guide.
The NUMARC generic testing program is limited to cable raceway protection applications.
A list of Thermo-Lag cable raceway fire barriers for our facility which are currently outside the scope of the NUMARC test program is provided in Attachment 2.
A supplemental response.will be provided to the
- NRC, after taking.'into consideration the results of the expanded NUMARC generic testing program, to address corrective actions for demonstrating the adequacy of these barriers.
A list of non-cable raceway barriers at_our facility is i
provided in Attachment 3.
These installations have been evaluated previously, or are in the -process of being evaluated, to demonstrate the adequacy of the existing _ fire barrier systems or fire
-barrier-penetration
-seal arrangements.
I
i Enclosuro 1 Page 6 of 11 i
l IV.B.
Ampacity Derating 1.
For the barriers described under Item I.B.1, describe those that you have determined will fall within the scope of the NUMARC program for ampacity derating, those that will not be bounded by the NUMARC program, and those for which ampacity derating does not apply.
2.
For the barriers you have determined fall within the scope of the NUMARC
- program, describe what additional testing or evaluation you will need to perform to derive valid ampacity derating factors.
3.
For the barrier configurations that you have determined will not be bounded by the NUMARC test program, describe l
your plan for evaluating whether or not the ampacity derating tests relied upon for the ampacity derating factors used for those electrical components protected by j
Thermo-Lag 330-1 (for protecting the safe-shutdown capability from fire or to achieve physical independence of electrical systems) are correct and applicable to the plant design.
Describe all corrective actions needed and i
submit the schedule for completing such actions.
4.
In the event that the NUMARC fire barrier tests indicate the need to upgrade existing in-plant barriers or to replace existing Thermo-Lag barriers with another fire' i
barrier system, describe the alternative. actions you will take (and the schedule for performing those actions) to confirm that the ampacity cerating factors were derived by valid tects and are applicable to the modified plant design.
Response
Ampacity derating is an issue that applies only to cable raceways-containing power cables.
Ampacity derating factors determined for upgraded configurations can be conservatively applied to baseline configurations.
The NUMARC program for ampacity derating evaluation contains the following elements.
For upgraded one-hour cable trays and conduits, NUMARC will be discussing with NRC the generic applicability of ampacity derating factors derived by TUEC using the methodology of IEEE P848 Draft 11, with some modifications.
The IEEE P848 test methodology has been l
extensively discussed with NRC by NUMARC and TUEC.
- However, NRC acceptance of the methodology is still pending.
NRC has informed NUMARC that they will issue a request for further information to TUEC regarding the submitted ampacity test report.
The TUEC testing provided preliminary ampacity derating factors of 32% for cable trays and 11%
for conduits, which are within the range of previously reported values.
Page 7~of 11 NUMARC will conduct ampacity testing of upgraded three-hour barriers to the requirements of-IEEE P848 following determination of appropriate barrier upgrades for three-hour installations-and -agreement with NRC on ampacity test methodology.
It.is expected that this testing would be conducted in the second quarter of 1994, at the earliest.
To the extent that successful upgrades' using alternative materials are identified, ampacity-testing of these upgrades would be considered as well.
The IEEE P848 approach provides for testing of-a single cable
- tray, and small and large conduits.. The limiting conduit derating factor -(of: the 'two sizes tested) is applied to the range of. conduit' sizes, cable fills, etc.
For cable trays, the single cable tray derating factor is
- s applied to all sizes of cable trays, cable fills,'etc.
- Thus, ampacity testing can be performed generically with broad applicability, unlike fire testing-where ~
many performance parameters must bei considered.
The NUMARC.
program is expected to provide ampacity derating factors-for one and three-hour barriers for cable traya and i
conduits.
Assuming NRC agreement with the=IEEE P848'
- approach, few if any installations are expected to fall j
outside the generic scope.
i 1
Enclosurc 1 Page 8 of 11 i
V.B.
Alternatives Describe the specific alternatives available to you for achieving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers.
Examples of possible alternatives to Thermo-Lag-based upgrades include the following-l 1.
Upgrade existing in-plant barriers using other materials.
2.
Replace Thermo-Lag barriers with other fire barrier materials or systems.
3.
Reroute cables or relocate other protected components.
4.
Qualify 3-hour barriers as 1-hour barriers and install detection and suppressien systems to satisfy NRC fire protection requirements.
Response
Three currently undefined factors must be considered in determining whether upgrades using additional Thermo-Lag materials are practical, and what alternatives would be most appropriate in case Thermo-Lag upgrades cannot be developed:
1.
Test and acceptance criteria have not been finalized and issued by NRC.
Proposed draft criteria contain new conservatisms in fire test methods and acceptance 4
criteria that could affect the scopo and complexity of upgrades to installed barriers.
The content of the final
- criteria, and the resulting impact on utility-specific action plans, is uncertain.
2.
Complete Phase 2 test results will not be known until the mid-April time frame.
Results of uaseline (as installed) and upgraded test configurations from' Phase 2 must be-i considered to determine appropriate action plans to address specific configurations.
- Moreover, further generic testing will be undertaken following Phase 2.
3.
The NUMARC Application Guideline is scheduled-to be final by mid-April and will include a
matrix of important i
performance parameters and bounding conditions.
The final content will directly impact the generic applicability of a
given test to an installed configuration.
Enclosura 1 Page 9 of 11 Each of the four NRC identified alternatives is a possible means to achieve compliance with NRC fire protection requirements in plant areas containing Thermo-Lag fire barriers.
Given the complexity of many plant barrier installations, combination of resolution approaches may be required to achieve compliance.
The
- 50. 54 (f) letter providsd only a
partial listing of resolution alternatives.
Tvo additional resolution alternatives are provided below which include:
1.
Re-evaluation of engineering analyses used for determination of safe shutdown capability for a fire event at BVPS Unit 2,
which could provide a basis for reduction in the scope of protected circuits and their associated fire barriers.
2.
Performing engineering evaluations per 10 CFR 50.59, based upon the use of fire modeling in' conjunction with baseline (non-upgraded) test
- results, to demonstrate adequate protection for the installed hazard.
10 CFR 50.59 allows the licensee to make changes as described in the UFSAR through an evaluation process.
Our use of Thermo-Lag 330-1 fire barrier systems is described in our UFSAR to satisfy the licensing commitments of the Standard RLview Plan (NUREG-0800).
In conjunction with fire
- modeling, probabilistic safety analysis may be used as a
basis for achieving compliance with fire protection requirements by demonstrating insignificant core damage frequency impacts.
Enclosuro 1 Page 10 of 11 VI.B.
Schedules Submit an integrated schedule that addresses the overall corrective action schedule for the plant.
At a minimum, the schedule should address the following aspects for the plant:
1.
Implementation and completion of corrective actions and fire barrier upgrades for fire barrier configurations within the scope of the NUMARC program.
i 2.
Implementation and completion of plant-specific analyses,
- testing, or alternative actions for fire barriers outside the scope of the NUMARC program.
Response
Because of the uncertainties noted previously in Item V.B, submittal of an integrated schedule depends on the results of' the Phase 2
NUMARC testing and the expected issuance of the NUMARC Application Guide.
Item II.B identified that a
supplemental response would be provided 90 days from receipt of the NUMARC Application Guide to address a complete review and evaluation of the acceptability of our installations.
This supplemental response will also. include an integrated schedule for addressing the overall corrective actions for resolving the Thermo-Lag fire barrier issue.
In the
- interim, BVPS Unit 2
will maintain the existing compensatory measures program identified previously in our response to Generic Letter 92-08 until the Thermo-Lag issues are resolved.
l l
I Enclosuro 1 Page 11 of 11 j
VII.B.
Sources and Correctness of Information j
Describe the sources of the information provided in response to this request for information (for example, from plant
- drawings, quality assurance documentation, walkdowns or inspections) and how the accuracy and validity of the information was verified.
j
Response
Information relative to generic Thermo-Lag fire barrier issues and the NUMARC generic testing program was provided via guidance from NUMARC.
Plant-specific information for BVPS Unit 2 was provided by plant personnel utilizing the following means:
1.
Review of contractor work practices and procedures.
2.
Review of installation details and design documents.
3.
Walkdowns ano inspections of installed configurations.
4.
Destructive examinations of specific barriers on a sample basis to verify certain installation parameters.
The plant inspections verified that-externally visible parameters matched the design documentation, and the sample destructive examinations confirmed the contractor work practices and installations.
1
l 1
R cponCo T3 Requnct fcr Additicnal Informatitn NRC Generic Letter 92-08 For Beaver Valley Power Station (BVPS) Unit 2 ATTACHMENT 1 Page 1 of 3 CLARIFIED PARAMETER LISTING AS PROVIDED BY NUMARC Raceway Parameters Tested Confiauration Bounded Installed Conficurations
- 1) Orientation (horizontal, All orientations vertical, radial bends)
- 2) Dimensions (small and large Range bounded by test specimen limits) dimensions
- 3) Conduit (No cable)
Conduits, bounded by test specimen dimensions, with any cable fill
- 4) Junction Boxes and Lateral Junction Boxes and Lateral Bends Bends bounded by test specimen dimensions
- 5) Ladder Back Cable Tray with solid back and ladder back cable single layer cable fill trays of equal or less dimensions and equal or greater cable fill (in terms of thermal mass)
- and -
Boxed Conduits, Boxed Enclosures (of equal or greater thermal mass and equal or less dimensions)
- 6) Cable Tray with T-Section Cable Tray of equal or less dimension with T-section, and equal or greater cable fill
- 7) Aluminun Steel (side by side testing of conduits and trays will be conducted to validate bounding condition)
- 8) Support protection, thermal Thermal Shorts with equivalent shorts (9" protection for or greater protection 1-hour), (18" protection for 3-hour)
l i
Responso To Requc:t for Addition 21 InformationL
{
NRC Generic Letter 92-08 For Beaver Valley Power Station -(BVPS). Unit. 2 ATTACHMENT 1 Page 2,of 3 CLARIFIED PARAMETER LISTING AS PROVIDED BY NUMARQ (Continued)
J l
Raceway Parameters (Cont'd) j Tested Confiauration-Bounded Installed Confiaurations
- 9) Air Drops Air drops of equivalenti
-construction and' dimensions
- 10) Box barrier systems attached
-Barrier systems of similar to concrete walls, ceilings, construction etc.
Fire Barrier' Parameters i
Tested Confiauration-Bounded Installed Conficurations' I
- 1) Baseline Panel' Thickness Equal or greater panel thickness (1-Hour 0.50",+0.125",-0")
l (3-Hour 1.00",+0.250",-0")
- 2) Performed conduit panels Sprayed on or troweled on i
installations of equivalent or greater thickness and. stress skin configuration l
- 3) Panel Ribs (parallel to Parallel or perpendicular to l
raceway) raceway q
l
- i
- 4) Unsupported span (typically Equal.or less-dimensions 48")
~
- 5) Stress Skin As tested, plus panels using i
(1-hour, inside)'
additional stressLskin 1
(3-hour, inside and'outside)
)
- 6) No stress skin over joints Stress skin'over joints
- 7) No stress skin ties Stress skin ties
- 8) Dry fit, post buttered Pre-buttered joints.
joints
- 9) Joint gap width Equivalent or-small gap' width
- 10) Butt joints Grooved and scored. joints-
)
Rrsponsn Ta Requ ::;t fer Additicn21 Information NRC Generic Letter 92-08 For Beaver Valley Power Station'(BVPS) Unit 2 ATTACHMENT 1 Page 3 of 3 CIARIFIED PARAMETER LISTING AS PROVIDED BY NUMARC (Continued)
Fire Barrier Parameters (Cont'd)
Tested Conficuration Bounded Installed Conficurations
- 11) Cable tray radial bends with Grooved and scored radial' bends separate mitered pieces
- 12) Steel bands-Tie wires (will be validated:
through testing)
- 13) Band / wire spacing Equivalent or closer spacing
- 14) Band / wire distance to joints Equivalent or. closer distance
- 15) No internal bands in trays Internal bands in trays
- 16) No additional trowel Additional trowel material material over sections, applied joints
- 17) No edge guards Edge guards
I Rscpons3 Ta Requnst for Additicnal'Informaticn i
NRC Generic. Letter 92-08 For Beaver Valley Power Station (BVPS) ' Unit 2 i
)
ATTACHMENT 2 Page 1 of 1 THERMO-LAG 330 I ? IRE BARRIER SYSTEMS 4
ENCAPSULATING RT RCTRICAL RACEWAY CONFIGURATIONS 1
AT BVPS UNIT 2 OUTSIDE THE SCOPE OF NUMARC TESTING PROGRAM j
Thermo-Lag Flexi-Blanket Wrap i
Flexi-Blanket material was installed on air drops, elbows and lateral bends.
4 i
Box enclosures surface-mounted to concrete (Junction Boxes, Pull Boxes, and boxed conduit runs)
Box enclosures are mounted with steel-banding..and edges / joints filled with trowel grade material vs.
flanged and hilti-bolt attachment to wall.
Size of box enclosures exceeds what is being tested by
)
i the NUMARC generic test program.
1 Encapsulated conduits surface-mounted to concrete Full circumference of Thermo-Lag pre-formed conduit sections could not physically be installed; sections were i
cut to fit and trowel grade material added to the joint and wall surface.
4 Installation anomalies i
i 1
Pre-formed conduit sections. for encapsulating conduits and condulet fittings (lateral bends) were interfaced with flat panel material, cut to size, and field-fit.
I 3M/TSI interfaces were used. on conduit runs, supports and transitions of cable from tray to conduit.
Band distance to joints a
Maximum spacing of. bands on conduit' installations is 12
- inches, which is acceptable.
- However, spacing 'from l
joints, in some cases, exceeds 2 inches.
R ::rponra To Requsst fcr Additicnal Infcrmatien NRC Generic Letter 92-08 For l
Beaver Valley Power Station (BVPS) Unit 2 ATTACHMENT-3 Page 1 of 1 THERMO-LAG 330-1 FIRE BARRIER SYSTEMS FOR NON-CABLE RACEWAY BARRIER INSTALLATIONS AT BVPS UNIT 2 OUTSIDE THE SCOPE OF NUMARC TESTING PROGRAM i
NOTE:
The Thermo-Lag installations identified below.have.been evaluated previously, or are. in the process of. being evaluated, to demormtrate the adequacy of the existing fire barrier penetration seal arrangements.
1.
Removable Floor Plugs (Service Building-745'6" and 760'6"):
4, Corrugated metal ~ decking. with 1" thick Thermo-Lag panels on' both top and bottom (for maintaining a 3-hour fire' rated floor / ceiling fire area boundary).
]
2.
Conduit Sleeve Extensions:-
l Provide a
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire wrap material, utilizing Thermo-Lag pre-formed conduit sections (1/2" thick minimum)..
The j
sections were installed on the conduit-sleeves.(> 4' inch in' i
diameter) to extend the 3-hour. fire rated penetration seal.
)
Where the fire seal could not be physically installed'at the
- barrier, the fire seal was installed at the first opening land I
the conduit sleeve was wrapped from the seal back to'the-barrier, effectively extending the fire barrier.
NOTE:
This was documented as a
deviation :in our UFSAR (Section
'l 9.5A.2,
" Conduits / Penetration Seals")
and-approved in 4
NUREG-1057 Supplement No.
.)
3.
Seismic Gap Seal for Walls:
Protecting a 2" gap seal, where the wall meets the ceiling'in
~
the Relay Room (CV-6)
Elevation 755'6", for maintaining a:
3-hour fire rated boundary.
l Protecting a
gap seal in the. Service. Building (SB-2) l Elevation 730'6",
where-an electrical ductline enclosure:
meets the
- ceiling, for maintaining a
3-hour fire > rated boundary.
4.
Fireproofing Structural Steel Support Plates Thermo-Lag is utilized as aL fireproofing material for:
protection of exposed structural ~ steel kick -plates-for floor-mounted penetration seals in various locations.
+
6 Response To Request for Additional Information NRC Generic Letter 92-08 For Beaver Valley Power Station (BVPS) Unit 2 n
TABLE 1 Page 1 of 2 DESCRIPTION /OUANTITIES OF THERMO-LAG'330-1 FIRE BARRIERS: BVPS Unit 2 APPROXIMATION OF DESCRIPTION PURPOSE TYPE / DIMENSIONS TOTAL FOOTAGE 1.
Electrical Raceway 1-Hour Fire 1/2" Thick Pre-formed Conduit 2900 Linear Ft.
Conduits Barriers Sections (3/4" diameter conduit up to 6" diameter conduit).
3-Hour Fire 1" Thick Pre-formed Conduit 1500 Linear Ft.
Barriers Sections (3/4" diameter conduit up to 5" diameter conduit).
2.
Supports Associated with 1-Hour Fire 1/2" Thick Panels (cut to size).
800 Ft.2 l
Conduit Runs Barriers
-t l
3-Hour Fire 1" Thick Panels (cut to size).
800 Ft.2 Barriers
!3.
Electrical Raceway Boxes 1-Hour Fire 1/2" Thick Panels (cut to size)._
467 Ft.2 (Junction Boxes and' Pull Barriers Sizes vary:..
Min. 4 ft.2
)
Boxes)
Max. 127 ft.2 3-Hour-Fire 1" Thick' Panels (cut to size)..
250 Ft.2 Barriers Sizes vary:
Min.14 ft.2-Max. 30 ft.2
-. 4. - -Removable' Floor Plugs 3-Hour Fire 1" Thick Panels mounted (top &
-510 Ft.2 Barriers bottom) to' corrugated steel decking.
Thermo-Lag panels are 4
.2xLB'6".
Total size of opening protected is 15' x 8'6" (2 floor levels).
~ -. -..
Response To Request for Additional Information NRC Generic Letter 92-08 For Beaver Valley Power Station (BVPS) Unit 2 TABLE 1 Page 2 of 2 DESCRIPTION /OUANTITIES OF THERMO-LAG FIRE BARRIERS (Continued)
' APPROXIMATION OF DESCRIPTION PURPOSE TYPE / DIMENSIONS TOTAL FOOTAGE 5.
Seismic Gap Seal for Walls 3-Hour Fire 1" Thick Panels (cut to size to 210 Ft.2 Barriers protect small gap openings between walls and ceilings).
60 Conduit Sleeve Extensions 1-Hour Fire 1/2" Thick (minimum) Pre-formed 104 Linear Ft.
Wrap Conduit Sections (Conduits > 4" Material in diameter).
(used to extend the Fire Rated Penetration Seal for the Wall / Floor) 7.
Structural Steel Support Fireproofing 1" Thick Panels (cut to size).
486 Ft.2 Plates for Oversized for Penetration Seals Protection of Exposed Structural Steel Kick Plates
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