ML20063H591
| ML20063H591 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick  |
| Issue date: | 02/14/1994 |
| From: | Habermeyer H CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, NL&RAS-94-013, NL&RAS-94-13, TAC-M85526, TAC-M85527, TAC-M85556, NUDOCS 9402180274 | |
| Download: ML20063H591 (34) | |
Text
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A CP&L Carolina Power & Light Company P.O. Box 1551. Raleigh N.C. 27602 FEB 141994 H. W. HABERMEYER, JR.
SERIAt: NL& RAS-94-013 Vice President Nuclear Services Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk i
Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/ LICENSE NO. NPF-63 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 FIRE BARRIERS," PURSUANT TO 10 CFR 50.54(f) - BRUNSWICK STEAM E' MCTRIC PLANT, UNITS 1 AND 2, AND SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 (TAC NOS. M85526, M85527, AND M85556)
Gentlemen The purpose of this letter is to provide the NRC with information requested in the December 22, 1993, request for additional information regarding Generic Letter (GL) 92-08, "Thermo-Lag 330-1 Fire Barriers," pursuant to 10 CFR 50.54(f) for Carolina Power & Light Company's (CP&L) Brunswick Steam Electric Plant, Units 1 and 2 (BSEP) and Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP).
The NRC issued GL 92-08 on December 17, 1992. By letter dated April 16, 1993, CP&L provided a response to that GL.
On December 22, 1993, the NRC requested additional information regarding the April 16, 1993, submittal.
Enclosed is CP&L's response to the December 22, 1993, letter. The response format follows the request format to facilitate NRC review.
Should you have any questions, please call Mr. R. E. Rogan at (919) 546-6901.
Sincerely, o
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H. W. Habermeyer/, J l
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4 CP&L Response Summary CP&L has developed a three phase Thermo-Lag Action Plan to resolve the Thermo-Lag concerns. The Phases are structured as follows:
f Phase 1 Options Development -
This phase will re-evaluate compliance options identified from the original BNP and HNP Safe Shutdown Analysis 3
along with options to test and/or upgrade Thermo-Lag configurations.
This evaluation process will ensure l
the most appropriate corrective action has been identified.
Phase 2 Test Plan -
In parallel with the options Development Phase, CP&L will develop a Test Plan to address those raceway configurations currently identified as not being within the proposed NUMARC Test Program.
l Phase 3 i
Implementation -
This phase will develop and implement the selected options and test results identified from Phases 1 & 2.
Several variables are still outstanding which affect implementation of the overall CP&L Thermo-Lag Action Plan. These' items are outlined as follows:
3 A.
Completion of the NUMARC Testing Program.
B.
Issuance of an NRC approved NUMARC Application Guideline.
l C.
Issuance of the NRC Fire Test Acceptance Criteria (final version).
As identified in the following detailed response and presented on the Thermo-Lag Action Plan flow chart in Figure 1, CP&L will continue to implement this Action Plan while NUMARC completes the Testing Program. A follow-up response will be provided 90 days after completion of the NUMARC Testing Program providing an integrated schedule along with CP&L's fire test criteria and the e
approach for addressing cable ampacity derating.
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1
I.
Thermo-Lag Barrier Configurations and Amounts NRC REQUEST I.B.1.
Describe the Thermo-Lag 330-1 barriers installed in the plant to a.
meet 10 CFR 50.48 or Appendix R to 10 CFR Part 50, b,
support an exemption from Appendix R, c.
achieve physical independence of electrical systems, d.
meet a condition of the plant operating license, e.
satisfy licensing commitments.
The descriptions should include the following information:
the intended purpose and fire rating of the barrier (for example, 3-hour fire barrier, 1-hour fire barrier, radiant energy heat shield), and the type and dimension of the barrier (for example, 8-ft by 10-ft wall, 4-ft by 3-ft by 2-ft equipment enclosure, 36-inch-wide cable-tray, or 3-inch-diameter conduit).
CP&L RESPONSE I.B.1.
Brunswic< Nuclear Plant A listing Of raceways and other enclosures where Thermo-Lag 330-1 is used for meeting Appendix R or supporting an exemption is given in Table 1.
This listing provides the raceway or equipment protected, the type of enclosure, the nominal size of the raceway, the approximate length (if applicable), the barrier rating, whether or not the barrier is covered under the present NUMARC testing scope (See item III), and the approximate area of enclosure (if applicable).
In addition to the information in Table 1, Thermo-Lag 330-1 has been used in the following specialized applications:
1)
Three-hour rated panels were used in conjunction with fire dampers to protect door transoms above seven doorways in the Diesel Generator Building.
The approximate sizes are as follows:
Five - 42"x56" panels Two - 30"x40" panels 2)
Thermo-Lag 330-1 was used as a component in approximately 60 fire barrier penetration seals 2
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(cont.)
Harris Nuclear Plant i
A listing of raceways and other enclosures where Thermo-Lag 330-1 is used for meeting NUREG-0800 or supporting a ~
deviation request is given in Table 2.
This listing provides i
the raceway or equipment protected, the type _of enclosure,-
the nominal size of the raceway, the approximate length (if applicable), the barrier rating, whether or not the barrier is covered under the present NUMARC testing scope (See item III), and the approximate area of enclosure (if applicable).
In addition to the information in Table 2, Trowel grade 330-1 has been used in the following specialized applications:
1)
App]ied to both faces of 4 door transoms and mullions of f.iie door assemblies (Transoms are approximately 12'x8' and the mullions are approximately 2'x10').
2)
Applied to 2 door transoms only (transoms are approximately 4'x7').
3)
Applied to 6 door mullions only (mullions are approximately 2'x10').
NRC REQUEST I.B.2.
For the total population of Thermo-Lag fire barriers described under Item I.B.1, submit an approximation of:
a.
For cable tray barriers:
the total linear feet and square feet of 1-hour barriers and the total linear-feet and square feet of 3-hour barriers.
b.
For conduit barriers:
the total linear feet of 1-hour-barriers and the total linear feet of 3-hour barriers.
c.
For all other fire barriers:
the total square feet of 1-hour barriers and the total square-feet of 3-hour barriers.
d.
For all other barriers and-radiant energy heat shields:
the total linear or square feet of 1-hour barriers and the total linear or square feet of 3-hour barriers, as appropriate for the barrier configuration or type.
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CP&L RESPONSE I.B.2 CP&L Thermo-Lag 330-1 quantities are as follows:
BNP THERMO-LAG 330-1 QUANTITIES Type Fire Approx.
Approx.
Comment Rating Linear Square Feet Feet i
Cable Trays 1
40 600 2-20' Sections 3
0 0
No Application Conduits 1
1050 3
1410 30 One enclosure =
30ft2 Junction Boxes 1
130 3
300 Equip. Enclosures 3
820 Door Transoms 3
100 Penetration Seals 3
Total of 60 seals HNP THERMO-LAG 330-1 QUANTITIES Type Fire Approx.
Approx.
Comment Rating Linear Square Feet Feet Cable Trays 1 &3 0
No Application Conduits 1
32 3
0 No Application Area Enclosure 3
1770 Partial Height 1
200 Wall Door Fireproofing 3
1300 4
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II.
Important Barrier Parameters NRC REQUEST II.B.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 on site for NRC audit where the aforementioned parameters are known.
CP&L RESPONSE II.B.1.
In general, the parameters considered will fall into one of two categories:
1)
NUMARC tests qualify the most limiting configuration, therefore all configurations are bounded.
2)
NUMARC tests establish boundary conditions (i.e. minimum, maximum or both).
Of the following parameters, many of the criteria are "known",
(e.g.,
band spacing required by installation details) but have not been " verified" at this time (either through quality control documentation reviews or field walkdowns).
NRC Parameter Listing
Response
Raceway orientation NUMARC tests both; all orientations bounded.
Conduit conduit number and sizes known.
Junction Boxes and Lateral Junction box number and sizes known.
Bends Ladder back cable tray with NUMARC tests bound both ladder and single layer cable fill solid back tray; Cable fills known.
Cable Tray with T-section No Thermo-Lag is installed in this orientation.
Raceway Material (aluminum, NUMARC tests bound both aluminum and steel) steel.
Support protection, thermal NUMARC tests establish bounding shorts conditions.
Installation criteria known.
Air drops Location of air drops known.
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NRC Parameter Listing
Response
Baseline fire barrier panel NUMARC tests minimum (1/2" for one-thickness
- hour, 1"
for three-hour).
CP&L assumes worst case.
Preformed conduit panels Conduit wrap configurations known.
Panel rib orientation NUMARC tests worst case; all configurations bounded.
Unsupported spans NUMARC tests establish bounding conditions.
Installation criteria known.
Stress skin orientation NUMARC tests establish bounding conditions.
Configuration not known at this time.
Stress skin over joints or NUMARC tests worst case; both no stress skin over joints configurations bounded.
Stress skin ties or no NUMARC tests worst case; both stress skin ties configurations bounded.
Dry-fit, post-buttered NUMARC tests worst case; both joints or prebuttered configurations bounded.
joints Joint gap width NUMARC tests establish bounding conditions.
Configuration not known at this time.
Butt joints or grooved and NUMARC tests worst case; both scored joints configurations bounded.
Steel bands or tie wires NUMARC tests worst case; both configurations bounded.
Band / wire spacing NUMARC tests establish bounding conditions.
Installation criteria known.
Band / wire distance to NUMARC tests establish bounding joints conditions.
Configuration not known at this time.
No internal bands in trays NUMARC tests worst case; both configurations bounded.
No additional trowel NUMARC tests worst case; both material over sections and configurations bounded.
joints or additional trowel material applied No edge guards or edge NUMARC tests worst case; both guards configurations bounded.
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CP&L RESPONSE II.B.1.
(Cont.)
With regards to the NRC parameters pertaining to installed cables shown below, none with the exception of cable fill in cable trays are known.
Consideration of the remaining parameters is only required if the fire tests exceed the temperature rise.
1.
Cable size and type (power, control, or instrumentation).
2.
Cable jacket type (thermoplastic, thermoset) and materials.
3.
Cable conductor insulation type (thermoplastic, thermoset plastic) and materials 4.
Cable fill and distribution of cables within the protected conduit or cable tray.
5.
Proximity of cables to the unexposed (inside) surfaces of the fire barrier.
6.
Presence of materials between the cables and the unexposed side of the fire barrier material (for example, Sealtemp cloth, which is used in the NUMARC test specimens).
7.
Cable operating temperature.
8.
Temperatures at which the cables can no longer perform-their intended function when energized at rated voltage and current.
If fire tests demonstrate excessive cold side temperatures, one optional approach to resolution as provided 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 temperature (item 8) would be necessary, using cable performance test data or information for specific installed ( able types (items 1,2,3, and 7 of the NRC listing).
However, NRC has yet to finalize requirements for cable functionality evaluation, nor are test results yet available 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.
Items 4, 5,
and 6 of the NRC listing address issues relative to potential cable / barrier contact for cable trays.
This is an unresolved issue at this time, and barrier inspection in this regard would be difficult or impossible.
Barrier contact would be most likely to occur in situations of large 7
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cable fills.
However, the large cuale fills also provide significant thermal mass that could improve barrier system performance and mitigate the effect of cables in contact with the barrier.
NUMARC has agreed to provide additional thermocouples below the cable tray rungs in the Phase'2 cable tray tests to provide information to address NRC concerns relative to potential contact of cables with_the. cold side of the fire barriers.
Further, note that a small piece of Sealtemp cloth (NRC item 6) was used only in NUMARC test Number 1-4 (24 " steel cable tray with an air drop, three hour test) and did not impact performance or useability of the l
test.
Other unique parameters which are identified for a particular barrier will need to be addressed on a case-by-case basie.
Chemical testing performed by NUMARC on a wide variety of aged samples has not revealed significant variations in chemical composition.
NUMARC has identified that these test results will be distributed to the industry along with the i
Phase I test reports.
Phase 2 testing will include barrier materials of various ages, as well as additional chemical testing.
Unless unexpected results are encountered, CP&L does not believe plant unique chemical evaluations should be necessary.
NRC REQUEST II.B.2.
For any parameter that is not known or has not been verified, describe how you will evaluate the in-plant barrier for acceptability.
CP&L RESPONSE II.B.2.
'.t is anticipated that the NUMARC Application Guide will contain the necessary guidance on the parameters of importance. Once these parameters are known and the bounding conditions set, CP&L will perform the necessary steps to verify this information.
These steps could involve such items as :
1)
Assumption of ' worst case' conditions; 2)
Review of quality control documentation from the original installation packages; 3)
Verification walkdowns of the barriers; or 4)
Destructive examination of barriers on'a statistical sampling basis to obtain information on construction techniques.
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l NRC REQUEST II.B.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.
CP&L RESPONSE II.B.3.
Those parameters that are established as bounding conditions I
through the NUMARC Application Guide are expected to require verification.
Of those shown above, the majority are easily verifiable through either documentation reviews or field walkdowns.
The remainder (i.e. joint gap width, orientation of stress skin on 1-hour wrap) may require destructive examination for verification.
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III.
Thermo-Lag Fire Barriers Outside the Scope of the NUMARC Program NRC REQUEST III.B.1.
Describe the barriers discussed under Item I.B.1 that you have determined will not be bounded by the'NUMARC test program.
CP&L RESPONSE III.B.1.
The specific components identified in the response to I.B.1 which have been determined not to fall within the scope of the NUMARC testing program are summarized as.follows:
Brunswick Nuclear Plant
- 1) Raceway Protection 1-hour Ratina 30"x30"x12" junction boxes with Thermo-Lag directly applied.
3-hour Ratina Junction boxes of the following sizes with Thermo-Lag directly applied:
24"x24"x24" 24"x20"x24" 24"x16"x8" 6"x48"x6" Junction box enclosures of the following sizes with Thermo-Lag applied to unistrut framing:
11'-0"x11'-0"x3'-0" 5'-6"x3'-6"x2'-0"
- 2) Intervening Combustible Protection Cable tray installations with percent fill < 15%.
- 3) Barrier Protection 3-hour Ratina The Thermo-Lag applied to door transoms and fire barrier penetration seals.
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Harris Nuclear Plant i
- 1) Raceway Protection 3-hour Ratino Enclosure assembly consisting of.1" nominal. thick panels mounted to structural steel framing.
- 2) Barrier Protection 1-hour Rating l
Partial height wall assembly consisting of 0.5" nominal i
l thick panels mounted to structural steel framing.
3-hour Ratino l
Thermo-Lag applied to door transoms and mullions.
NRC REQUEST III.B.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.
CP&L RESPONSE III.B.2.
CP&L is developing an Options Development Evaluation in conjunction with a Test Plan for Thermo-Lag wrapped l
raceways to determine the best approach to dispositioning j
Thermo-Lag configurations.
(See response-to Item VI).
It is desirable to use the test results from the.lRRCUUC testing in order to take advantage of lessons learned.
Due i
to the costs associated with conducting fire tests, CP&L would not want to proceed with testing a baseline H
configuration if a planned NUMARC test indicated a high probability of failure.
Conversely, it would not be desirable to develop an upgrade process which would pass a.
fire test, but be costly and difficult to implement in the field, if the NUMARC test results suggest a simpler and more efficient approach.
11
NRC REQUEST J
III.B.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.
CP&L RESPONSE i
III.B.3.
It is anticipated that the area enclosure at-HNP will i
require fire testing, which may envelope some of the large junction box enclosures at BNP. The test specimens for any required testing are still under consideration.
For testing cable raceway fire barriers, CP&L expects to
~
use the test and acceptance criteria in the final version of Supplement 1 to Generic Letter 86-10.
This criteria, when final, would be required for establishing test methodology for qualification of cable raceway fire barriers used for protection of safe shutdown functions in accordance with Appendix R/NUREG-0800.
For non-cable raceway fire barriers, test methodology and acceptance criteria will be developed taking into account the acceptance criteria issued in Supplement 1 to Generic Letter 86-10 and standard test methods such as NFPA-251.
Test methodology and acceptance criteria will be provided with the integrated schedule (See response to item VI).
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l IV.
Ampacity Derating i
NRC REQUEST IV.B.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.
CP&L RESPONSE IV.B.1.
Ampacity derating is an issue that applies only to. cable raceways containing power cables which are continuously energized.
Ampacity derating factors determined for upgraded configurations can'be conservatively applied to baseline configurations.
The NUMARC program for ampacity derating evaluation contains the fellowing elements.
For upgraded one hour cable trays and conduits, NUMARC is reviewing the generic applicability _of ampacity derating factors derived by Texas Utility Electric Corporation (TUEC) using the methodology of IEEE P848 Draft 11.
The IEEE P848 test methodology has been extensively discussed with the NRC by NUMARC and TUEC.
However,~the NRC acceptance of the methodology is still pending.
The 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.
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 i
conducted in the second quarter of 1994, at the earliest.
To the extent that successful upgrades using alternative j
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.
Tha 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 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 13
l performance parameters must be considered.
The NUMARC program is expected to provide ampacity de*ating factors for one and three hour barriers, for cable trays and conduits.
Assuming NRC agreement with the IEEE P848 l
approach, few if any installations are expected to fall outside the generic scope.
NRC REQUEST IV.B.2 l
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.
CP&L RESPONSE IV.B.2.
As described in our response to GL 92-08, CP&L has performed a review of the derating percentages identified in that document and determined that design margin was still available.
Any additional testing or evaluaritn required will not be known until NRC approved test leeults are received from NUMARC.
NRC REQUEST IV.B.3.
For the barrier configurations that you have determined will not be bounded by the NUMARC test program, describe 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 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 submit the schedule for completing _such actions.
CP&L RESPONSE IV.B.3.
As stated above, few if any installations are expected to fall outside the generic scope.
Should any configurations be identified as being outside the final NUMARC guidance, CP&L will identify the appropriate corrective action to ensure an adequate design margin is maintained.
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1 NRC REQUEST IV.B.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 barrier system, describe the alternative actions you will take (and the schedule for performing those actions) to confirm that the ampacity derating factors were derived by valid tests and are applicable to the modified plant design.
1 Your response to Section IV.B may depend on unknown specifics of the NUMARC ampacity derating test program (for example, the final barrier upgrades).
However, your response should be as complete.as possible. In addition, your response should be updated as additional information becomes available on the NUMARC program.
CP&L RESPONSE IV.B.4.
Effects on ampacity derating are one of the factors that t
must be considered before the decision to apply more Thermo-Lag or use an alternate material is finalized.
As part of CP&L's design control process, adequate design-margin will be maintained for ampacity bei_:t any design resolution is implemented.
The schedules to address ampacity will be considered as part of the overall integrated schedule to resolve the Thermo-Lag issue.
Submittal of this integrated schedule is addressed in the response to Item VI.
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V.
Alternatives NRC REQUEST 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:
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 suppression systems to satisfy NRC fire protection requirements.
CP&L RESPONSE Options currently being considered for Thermo-Lag resolution are given in the Action Plan provided in the response to Item VI.
The alternative chosen for each specific case will be based on that which provides the required level of safety in the most cost-effective manner, while minimizing the impact to plant operation.
Some of these alternatives may be exercised before the decision to physically upgrade using Thermo-Lag.
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l VI.
Schedules NRC REQUEST 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.
Implementatic., and completion of corrective actions and.
fire barrier upgrades for fire barrier configurations within the scope of the NUMARC program.
2.
Implementation and completion of plant-specific analyses, testing, or alternative actions for fire barriers outside the scope of the NUMARC program.
CDiL RESPONSE In order to develop an integrated schedule, some of the following ractors will need to be completed:
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 criteria that could affect the scope and complexity of d
upgrades to installed barriers.
The content of the-final criteria, and the resulting impact on our specific action plan will be determined when the final j
criteria is issued by the NRC.
2.
Complete NUMARC Phase 2 test results will not be known j
until the mid-March time frame.
Results of baseline and upgraded test ccnfigurations must be considered to determine the appropr:. ate action plans to address i
specific configurations.
Moreover, further generic testing may be undertaken following Phase 2.
3.
The NUMARC Application Guide, scheduled for issuance by mid-April, will include a matrix of important performance parameters and bounding conditions.
Discussion with NRC will be necessary to reach agreement on the selection of comparison parameters and i
bounding conditions.
The results of these NRC interactions will define the final content and would directly impact the generic applicability of a given test to an installed configuration.
1 CP&L intends to implement the Action Plan as presented in and shown graphically in the flowchart presented in Figure 1.
CP&L will submit an integrated
~
schedule 90 days after completion of the NUMARC testing program.
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-m VII.
Sources and Correctness of Information NRC REQUEST Describe the sources of the information provided in response to this request for information (for example, from plant drawings, quality assurance documentation, walk downs or inspections) and how the accuracy and validity of the information was verified.
CP&L RESPONSE The following sources of information were used:
A) Design Drawings B)
Installation documents (modifications, design change notices, etc.)
C)
Preliminary engineering walkdowns D)
Cable Raceway Reports The information presented herein was developed by engineering personnel familiar with the Thermo-Lag design.
However, as stated in the response-to Item II, some of the information has not been " verified" as to its accuracy.
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ATTACHMENT 1 CP&L ACTION PLAN I.
ODtion Development Phase Perform an Optionr, Development Evaluation which considers all available options to resolve the Thermo-Lag issue.
This Evaluatioa will address the configurations bounded by the results of Phase I NUMARC Testing _along.with other alternatives such as those identified below.
The Evaluation will integrate the results of other tests as these are received.
A)
Available Alternatives for each Configuration The following are some of the available alternatives for resolution of the Thermo-Lag issue (not necessarily presented in order of preference).
The alternative chosen for each specific case will be based on that which provides the required level of safety in the most cost-effective manner, while minimizing the impact to plant operation.
1)
Re-evaluation of Safe Shutdown Methodology to provide basis for reduction in scope of protected circuits and their associated barriers.
2)
Reroute circuit.
3)
Replace with other fire barrier' materials or upgrade with Thermo-Lag / Alternate materials. This option requires implementation of the NUMARC Application Guideline.
4)
Evaluate other methods for achieving Appendix R/NUREG-0800 compliance (e.g.,
sprinklers, detection and/or exemptions / deviations, G.L.
86-10 evaluations of non raceway barriers).
Should other alternatives be identified during the Options Development Phase, these will also be considered.
B)
Upgrade considerations i
i Before an upgrade design is finalized, the following i
attributes must be considered:
1 1)
Implementation of NUMARC Application Guideline.
2)
Feasibility of installation (e.g.,
potential-field interferences).
3)
Effects on structural supports.
4)
Effects on cable ampacity derating.
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Combustibility l
6)
Other potential impacts (e.g.,
equipment qualification).
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ATTACHMENT 1 II.
Test Procram Phase Develop a CP&L Test Plan for those configurations currently identified as not being within the proposed NUMARC Test Program. This Test Plan must consider the following attributes:
A)
NRC approved acceptance criteria (expected in Supplement 1 to Generic Letter 86-10)
B)
Test Results from NUMARC Phase II and any additional future NUMARC testing.
C)
Identify potential for shared testing with other utilities which have similar configurations.
D) Availability of test labs and Thermo-Lag material.
E)
Obtaining NRC approval of enveloping test configurations / methodology, including acceptance criteria.
III.
Imolementation Phase Development and implementation of the results from the
~
Option Development and the Test Program Phases will require the following actions:
A)
Development a*.d implementation of plant modifications.
Implementation of modifications such as circuit / raceway rerouting, barrier upgrades, etc. will need to consider the following:
1)
Plant Outages Much of the work will involve safety related components.
It is anticipated that the majority of modification implementation will need to'be scheduled during plant outages.
2)
Material Availability once the type of viable upgrades are known, material will have to be ordered.
Due to the large number of utilities which may also. require upgrades, material availability remains an uncertain factor at this time.
3)
Labor Qualification Regardless of the type of upgrade material used, plant personnel will need to be trained in the proper installation criteria.
4)
ALARA l
Some of the Thermo-Lag is installed in high 20 l
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ATTACHMENT 1 1
radiation areas.
Work in these areas will need to j
be scheduled to maintain the plants' commitments to ALARA.
B)
Engineering Evaluation / Safe Shutdown Methodology Changer.
C)
Submittal of Plant Specific Exemption Request or Deviation as appropriate.
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TABLE 1 l
BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 1 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE 3CF1/CA CONDUIT 5"
10 1
YES 3CF2/CA CONDUIT 5"
10 1
YES 3HS1/CB CONDUIT 1.5" 30 3
YES 3HS2/CB CONDUIT 2"
30 3
YES 3HW1/CB CONDUIT 3"
25 1-YES F
3YN1/CB CONDUIT 1.5" 10 1
YES 3YN2/CB CONDUIT 1.5" 10 1
YES 3YN3/BB CONDUIT 1.5" 25 1
YES-45S/BA TRAY
-3"X24"-
20 SEE NOTE 1
NO TRAYS WRAPPED TO ENCLOSE COMBUSTIBLES 45S/CA.
TRAY-4"X24" 20 1
NO IN' SEPARATION ZONE.
TOTAL AREA OF 2
45S/DA TRAY 4"X24" 20 1-NO ENCLOSURE IS.300 FT.
47R/BA TRAY 3"X24" 20
-1 NO 47R/CA TRAY 4"X24" 20 1-
'NO 48R/CA TRAY 4"X24" 20
-1 NO 4YF1/CB CONDUIT 3"-
20 1
-YES 4YF2/CB CONDUIT 3"
20' 1-
'YES SMT1/CA CONDUIT 1.5" 55 1'
_YES 1
23
-l
TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 1 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE 8ZR1/CB CONDUIT 3"
38 3
YES AAH1/BB CONDUIT 3"
14 3
YES AAI1/BB CONDUIT 3"
12 3
YES ALZ1/CB CONDUIT 3"
20-1 YES HDS1/BB CONDUIT 2"
32 1
YES HDS1/BB CONDUIT 2"
38 3
YES HDT1/BB CONDUIT-2" 15 1
YES HDU1/BB CONDUIT-2" 15 1
YES HFB1/BB CONDUIT 3"
62 3
YES HFC1/BB
. CONDUIT 3"
61 3
YES TRANSFER ENCLOSURE 11'X11'X N/A--
341 3
NO ENCLOSURE AREA =.341 2
CONTACTOR 3'-
FT,
ENCLOSURE CONTAINS NINE ENCLOSURE ELECTRICAL BOXES.
TRANSFER ENCLOSURE 5.5'X3.5 N/A 67 3
NO ENCLOSURE AREA = 67 2
'X2' FT.
CONTAINS BOX L6C ENCLOSURE LAM 1/CB CONDUIT 0.75" 115
_3 YES LBB1/CB CONDUIT 1"
15 1
YES t
LBC1/CA CONDUIT' 3" -
30 1
YES 24
._-__.._m TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 1 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE LBC1/CA CONDUIT 3"
92 3
YES LBD1/CA CONDUIT 1"
25 1
YES-LBF1/CB CONDUIT 1.5" 12 1
YES LBF1/CB CONDUIT 1.5" 200 3
YES LBG1/CB CONDUIT 3"
30 1
YES LBH1/CA CONDUIT 3"
12 1
YES LBI1/CB CONDUIT 3"
30 1
YES LBJ1/CA CONDUIT 3"
20.
1 YES LBQ1/CA CONDUIT 2"
18 3
YES LBR1/CA CONDUIT
-1.5" 25 3
YES LBS1/CA CONDUIT 1.5" 70 3
YES QA6 BOX 24"X24"X N/A 27 3
NO 24" QB3 BOX 24"X24"X N/A 27 3
NO 24" QB4 BOX 24"X24"X N/A 27 3
NO 24" QC3 BOX-24"X24"X N/A 27 3
NO 24" 25
TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 1 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE QD4 BOX 24"X20"X N/A 25 3
NO 24" S1Y BOX 6"X48"X6 N/A 9
3 NO S1Z BOX 6"X48"X6 N/A.
9-3 NO W28 BOX 30"X30" N/A 23 1
NO X12" W63 BOX 18"X12"X N/A 6
1 YES 6"
X8U BOX 24"X16"X N/A 10 3
NO 8"
XQ4-BOX-30"X30"X N/A 23-1 NO 12" YAD1/CB CONDUIT 1.5 15 1
YES YAD2/CB CONDUIT 1.5-15 1
YES YAI1/CA CONDUIT 1.5 20
'l YES YAI2/CA CONDUIT 1.5 20 1
YES YAI3/CA CONDUIT 1.' 5 20 1
YES 26
~
TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 2 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE 3CF1/CA CONDUIT 5"
10 1
YES 3CF2/C CONDUIT 5"
10 1
YES 3HW1/CB CONDUIT 3
35 1
YES 3HY2/CB CONDUIT 1.5" 15 1
YES 3HY3/CB CONDUIT 1.5 15 1
YES 3HZ1/CB CONDUIT 1.5" 20 1
YES 3HZ2/CB CONDUIT 1.5" 20 1
YES 45G/BA TRAY 3"X24" 20 SEE NOTE 1
NO TOTAL ENCLOSURE AREA 2
= 300 FT.
TRAYS 45G/CA TRAY 4"X24" 20 1
NO
.WRAJ: PED TO ENCLOSE COMBUSTIBLES IN 45G/DA TRAY 4"X24" 20-1 NO SEPARATION ZONE.
47G/BA TRAY 3"X24" 20 1
NO 47G/CA TRAY 4"X24" 20 1
NO 48G/CA TRAY 4"X24" 20 1
NO
-5MT1/CA CONDUIT 1.5" 55 1
YES ALZ1/CB CONDUIT 3"
20 1
-YES-HDS1/BB CONDUIT 2"
28 1
YES' HDS1/BB CONDUIT 2"
42.
3' YES-27 i
,m.
D-j TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 2 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES i
LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE i
HDT1/BB CONDUIT 2"
15 1
YES HDU1/BB CONDUIT 2"
22 1
YES TRANSFER ENCLOSURE 11'X11'X N/A 341 3
NO ENCLOSURE AREA = 341 2
FT. ENCLOSURE CONTACTOR 3'
CONTAINS NINE ENCLOSURE ELECTRICAL BOXES TRANSFER ENCLOSURE 5.5'X3.5 N/A 67 3
NO ENCLOSURE AREA = 67 2
FT. CONTAINS BOX CONTACTOR
'X2' L6C.
ENCLOSURE LAM 1/CB CONDUIT 0.75" 115 3
YES LAM 1/CB CONDUIT 0.75" 20 1
YES LBB1/CB CONDUIT 1"
15 1
YES LBC1/CA CONDUIT 3" -
48-1 YES
-LBC1/CA CONDUIT 3"
102 3
YES LBD1/CA CONDUIT 1"
25 1
YES LBF1/CB CONDUIT 1.5" 15 l'
YES LBF1/CB CONDUIT 1.5" 203 3
YES LBG1/CB CONDUIT 3"
30 1
YES LBH1/CA
' CONDUIT 3"
12 1
YES
-28 i
__.m.
TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 2 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT-(FEET)
FEET SCOPE LBI1/CB CONDUIT 3"
38 1
YES LBJ1/CA CONDUIT 3"
20 1
YES LBQ1/CA CONDUIT 2"
18 3
YES LBR1/CA CONDUIT 1.5" 25 3
YES LBS1/CA CONDUIT 1.5" 70 3
YES QA6 BOX 24"X24"X N/A 27 3
'NO 24" QB3 BOX ~
24"X24"X
~ N/A.
27 3
NO 24" QB4 BOX 24"X24"X N/A' 27 3
NO 24" i-l QC3 BOX 24"X24"X
.N/A 27.
.3.
NO l
24" QD4 BOX 24"X20"X lN/A-25' 3
NO 24" WL9 BOX 18"X12"X
-N/A 6.
1.
YES 8"
X8B BOX 24"X16"X N/A 10 3-NO 8"
29
TABLE 1 BRUNSWICK NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING UNIT 2 REACTOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE XLO BOX 30"X30"X N/A 23 1
NO 12"
-XQ3 BOX 30"X30"X.
N/A 23 1
NO 12"
'i XQ4 BOX 30"X30"X N/A 23 1
NO 12" r
k I
30
4 TABLE 1 BRUNSWICK-NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING DIESEL GENERATOR BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE 9NI1/BA CONDUIT 1.5" 3
3 YES 9NQ1/BB CONDUIT 1.5" 3
3 YES DJZ1/BB CONDUIT 2"
3 3
YES 9MH1/BA CONDUIT 1"
SEE NOTE SEE NOTE 3
YES THESE ELEMENTS ARE IN THE SAME ENCLOSURE.
9MV3/BB CONDUIT 1.5" 3
YES ENCLOSURE AREA = 30 2
FT,
W14 BOX 12"X12"X 3
YES 8"
BUILDING SERVICE WATER INTAKE STRUCTURE ELEMENT TYPE SIZE APPROX APPROX RATING-NUMARC'S NOTES LENGTH' SQUARE (HOURS)~
SCOPE CURRENT (FEET)
FEET-MAW 1/DB CONDUIT 1"
15 1
YES i
XN3 BOX 12"X12"X N/A-5-
1 YES 12" J
V 31
TABLE 2 HARRIS NUCLEAR PLANT THERMO-LAG 330-1 WRAP
SUMMARY
BUILDING REACTOR AUXILIARY BUILDING ELEMENT TYPE SIZE APPROX APPROX RATING NUMARC'S NOTES LENGTH SQUARE (HOURS)
CURRENT (FEET)
FEET SCOPE 160200-SR2 CONDUIT 2"
6 1
YES 16020T-SR4 CONDUIT 2"
6 1
YES 16247A-SA CONDUIT 2"
8 1
YES 17144P-S2 CONDUIT 2"
-6 1
YES 17144Q-S2 CONDUIT 2"
6 1
YES AREA ENCLOSURE SEE N/A 1770 3
NO AREA ENCLOSURE SEPARATES ENCLOSURE NOTE CABLE SPREADING ROOM AREA INTO SEPARATE FIRE AREAS.
TOTAL ENCLOSURE 2
AREA = 1770 FT.
PARTIAL WALL 10' X N/A-200 1
NO A PARTIAL HEIGHT 10' X HEIGHT 20' 20' WALL CONSISTING OF ONE-HOUR PANELS MOUNTED WALL ON STEEL FRAMING WAS ERECTED TO SUPPORT A DEVIATION REQUEST. TOTAL 1
AREA = 200 FT 32 i
1