ML20080L351

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Submits Part 21 Rept Re Problems & Discrepancies Identified Concerning Installation of Thermo-Lag Fire Barriers at Plant.Related Info Encl
ML20080L351
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/15/1994
From: Shukla G
DETROIT EDISON CO.
To: Colburn T
NRC
Shared Package
ML20080L318 List:
References
FOIA-94-312 NUDOCS 9503020171
Download: ML20080L351 (4)


Text

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M Ch121 atLEGEIAR11JTY EVALUATEDM Etalusiun Result and Rancunmandanon.

TM pneeneal reponable condiden represents peubleius and diswapendes idensi6ed regardine metallateus ofThermu-lag Sro barriers at Permi 2 which were seenvered Aring isnuval asal rapiscenmut of thsee barriers in the on-going fbunh re6andag outage. Desails of the discrepancass are providad in the attachment, however, they are generally relatal tu .-

the hilowing annednew U laserferos.ceer tsomt uansfer swfisen muah as pipes, conduhs, cable way ami pipe suppuns were not adequately protected whh suSdcat amount of Thanno lag material 1 0  !

Pensis wew not installai cometh O - Cable tra) wrape did seut have enough prutective msserialinstalled These identidad lasproper installarion onnetinni caneert an actnarrar a baanc comunemmer which is necesesty to ensure the capainley to shusdourn time reartor and nuunrein it in a safe shutdown condsence because these instahauons may taut be wipubis of provuhng the requeed proteccon t'resa tire to structwas, sysseuss, and worspunarias impunnat to umAsty.

These instaBanons appear to carnam deviatinnt and dcinata. as de6ned in to CFR 21, besmac they neulted in a product that dnei nor meet the requirements of the Detroir Edison procurement documents for providina qualaGed fue piotsi;tiuu barries at Ferns 2.

The dedset ofImproper instaDeslon of Thanno-lag Brc bertkrs is such that la may not provide required ilrv protecnoa to sesendal sa8my systmas This anald result in a mejnt dayadation of thsee spetanu such ther a required antisty function may nne he pednemed duries or ater a ase. Therefore. this defect could create.a sabstantial safintv hamara as denned as 10 CrK21. l Therehre, the condhien afhaproper tparan=*m of dimensend Thermo-Tag fire. berriers at ferusi 2 is reecemanded as gag l3hls umlar the rurgerements af'10 CT'R 21 l

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JUL.-15-1994 0901 ' FERMI'2 DET ED:50N 3:.3 Fe6 4200 F.02 3 (Attachanest to PRC No. 94 01, Rev.1)

IMPROPER INSTALLATION OF THERMO-LAG FIRE BARRIERS During removal and replacement of the Thermo-Lag fire barriers at Fermi 2 the following installation discrepancies were observed by the Fermi 2 Fire Protection Engineer:

1) Generic Protdeme:

Interferences / heat transfer surfaces such as insulated pipe, conduits, cable tray, and pipe supports were not encased or coated with suNicient amount of trowel grade TherW material.

Panels were not always installed uniformly (e. g. with the ribs facing out), as required.

2) Relay Room Stalrwell(El 813'4"):

Where the cable tray wrap system terminated at the two existing silicone foam sosts, the Thermo-Lag matenal stopped at the outer edge of the foam providing no protection for the cables imbedded in the foam seal, below the Thermo-Lag seal, once an inch of foam was bumed away (foam bums away at 3 inches per hour).

3) Cable Tray Vault (s. 877'-6"):

The expanded metal which is required to achievs the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating for a wall type assembly was completely omitted.

. Panels were used to support each other in lieu of support steel. In one instance a panel cantilevered out four feet to a second panel cantilevered l down about three feet forming a right angle. l

4) CCHVAC Area (s.877'4"):

. Panels were simply sitting on the floor without actually being festened to the floor, as required.

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. Outside the control room ventilation duct work, a4acent to fire dampers 4 -  !

l the duct work, support steel was installed around the dampers without th.  !

[ vendor specified clearance. The eNect of this installation on the dampers is being evaluated at th!s time. These dampers serve solely a fire barrier function and the observed condition has no effect on the operability of the  ;

control room ventilation system.

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- JUL -1T-1%4 09:32 FEFMI 2 MT ED150r4 313 586 .2209 5.03 (2) ,

l Detroit Edison is further investigating this issue with the contractor performing

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removal and replacement of Thermo-Lag material to obtain wrttten confirmation l

of potential additional disaepancies.

Thermal Science, Inc. (TSI) furnished and delivered the Thermo-La0 trowel '

grade and pro-fabricated panel material. TSI also fumished technical assistance to rievi op a procedure to support the installation requirements as defined in 8

DeuM 2dison's specifications with Detroit Edison's site contractor responsible for the installation of the material. TSI provided field service en0 i neer for on-site technical assistance and provided site visits to investigate interferences and to recommend installation provess. TSI also trained and certified the crew of the site contractor rosysible for installation and inspection of the material at Fermi

2. The installet'on e)s required to be performed by personnel certified by TSI.

Installation of the Thermo-Lag material at Fermi 2 and first line supervision of-the installation was performed by the P. R. Sussman Company of Toledo, Ohio per the contract. The P. R. Sussman Company also fumished verification records showing acceptance of the Thermo-Lag installation at Fermi 2. In addition, TSI lasued a letter to P. R. Sussman Company stating that the installation of the Thermo-Lag material at Fermi 2 was completed according to TSI's published application guide and generic test report it is not known to Detroit Edison whether the P. R. Sussman Company perfoi7ned installation of Thermo-Lag material at any other nuclear power plare..

Written by: R. J. Kilroy i

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July 13,1964 Daily News Digest i The Monroe Evenin0 News July 12,1994 - '.

p:ge 1 A Fire retardant at Fehtil.

..insta ell dimpropedy sediemims em nee.nnin

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  • tan eamim a een is es wei= = m sasha woodes blocks, 0 Indications am that afhv. I sufmed,th NRC.w. ,w deed

--su b plants a nov- m edse the lanthalande.

resistant matedalcalled ,,,, ,y suggest that the

' , ins waarb and closed circuit ties at

'Thermo I.ag:' may have - -

    • *r* of fia la semeldmid nive bas em posed a fire urest because'of ' a='r=-*P" "'"d " "' $$$o""aggan ani im perinstallation.The .

fin ing may have implications n,,,, , o,,,,g,,' idled to repair damageWhile Peredis ,ortin.gewru It a for other U.S. nuclear plants. ,,,, ,,,, 4,,,,3 ,, % p'ppean that the pamua si-e7pb .,iw o,oraos a =.wsa.

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ue uewe.t.w.tter _ =$325,000omt e

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k meanttheduplaatwas w%

very vulnerable to fire from the A=

Detroit Edison po. discovered thet from l' areas where it was start," said Michael Kagan of at at its leggi lastaud wtwo theplantwas built, Monroe, a member of an anti-acosiDovnnTsTTEs nuclear pim wasinstalled impropu y and .*As thy teamvd de Thermo- nuclear alliases group.

could haveinterfered with so safsty Wmaudd,dwy foundlasume Mr.Strasmasaid the systems. It's a sadlag that een s#wt wisere it was set properly Fermi will be reviewed 9 the comns of other utilities. ' lastalled saidJan Strsama,an NRC to seeif otherplaats to "We'relooking Wh114 riept g out se substanee called NRC be warned of the potential for ,

company intoit now as as the generic <

"Thermo La at Permi thethinner than , iniplications."

improper installation at their had spots it was planu, squissaandciberareas k we sup- As many as 60 nuclest plaats Fernaldecidedto stripthe mete-ported by wooden blocks. It also found it moundes(JnisedStates uwThor. rial boeause it only was used la was instelled in a way that woeld have so- e a fim berrier.De And-ingsa maylead to en NRC 11 areas of the last. But other kePt open some ductwork dameets that mound .S have made are meant to elone and protect b plant demand that it be ressoved from ass maserial,rW6 controlroom fhd smoks and Gre. . su miserplans. in pect that mandatory

%e utility 'still le inwestinatina the way NessadaDy what's missus here would be an sapenstys rs the matorist was lastalled ansfhopes to mFeralwethatmismaterialwas propoeilles for theindustry.

makeits fladla known to federd offi. Id sad haslmen misin. Meanwbue, a Baltimore grand according to Lewil to start of the plant" clats within 30 ~-

saidPantoustar,directorof the j . *"" late the makias K. layton, an as mufssGeg'of Dweso Lesli hermo Lag, s'concressuka paast mase, Reactor Weichdog Projwt for the conda . A principalla alabo-rial med widelv as protection for safetI. NuciantladenstrosandRascares tified to the effee-l servlee is Washington. D.C. rato 2 related electrt6al cables in the nation . gwness the rnatorialalready "Thereis no con $dence that the 2T. ,f=M'd"S'E":" fs"N'aM!ni'iME'poras auclearylants,"was deternalmed by the'#Li'.t.'s.fsMatilll"3 prduct.

than fleet thnoght after it had been i

installed in dosens of nuclear plants. '

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. q -f y Douglas A Gipson Semce v.ce 5 e s ce- ,

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February 11, 1994 NRC-94-0011 U. S. Nuclear Regulatory Commission i

' Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 l

NRC Docket No. 50-341 l NRC License No. NPF-43 l

2) NRC Generic Letter 92-08, "Therso-Las 330-1 Fire Barriers", dated December 17, 1992
3) Detroit Edison Letter to NRC, " Detroit Edison t

Response to NRC Generic Letter 92-08," NRc-93-0043, dated April 8, 1993

4) NRC Letter to Detroit Edison, " Request for Additional Information Regarding Generic Letter 92-08, Thermo-Lag 330-1 Fire Barriers," dated December 22, 1993

Subject:

Detroit Edison Response to NRC Request for Additional Information Regarding Generic Letter 92-08 The purpose of this letter is to provide Detroit Edison's response to NRC Request for Additional Information (RAI) regarding Generic Letter 92-08 (Reference 4) which was issued to obtain additional information regarding resolution of the herno-Lag issues. As requested, a copy is also being submitted to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III.

Detroit Edison provided a response to Generic Letter 92-08 via Reference 3 which stated, in part, that Detroit Edison is acnitoring industry activities to restore fire barrier integrity through programs coordinated by NUMARC. The response further stated that Detroit Edison would apply the results of these programs, if applicable, to the Therno-Lag installation at Fermi 2.

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Subsequent to the submittal of the response to Generic Letter 92-08, Detroit Edison opted not to wait for the results of the industry programs coordinated by NUMARC and decided to resolve Therno-Lag issues by either renoval or reclassification of Thermo-Lag fire

<. barriers at Fermi 2.

As stated in the response to Generic Letter 92-08, eleven areas were identified where Thermo-Lag fire barriers having a 3-hour rating are installed at Ferai-2. In the following eight of these eleven areas, Thermo-Lag fire barriers are being removed and replaced by concrete blocks and qualified 3-hour rated fire barriers such as.3M barriers, ,

UL designs U435 and 17s?. pronat boards, silicone foam and elastomer seals: ,

1. Cable Tray Enclosure for Cable Trays10-037 and 1P-070, CCHVAC Area, El. 677'-6" Two (2) cable trays 1C-037, and 1P-070 are routed between the  !

Division 1 CCMVAC Equipment Area and the Ventilation Equipment .

Area both on El. 677'-6", and have been enclosed by an envelope -

of Thermo-Lag material. The purpose-of this structure was to .

provide a three hour rated barrier to enclose and protect these.

trays as they traverse the Division II.CCHVAC area. This  !

enclosure is being replaced with an approved three hour fire rated assembly.

2. Separation Barrier Between the Redundant CCHVAC Air Handling  :

Units in the CCHVAC Area on El. 677'-6"~

I Due to the close proximity of the divisionalized CCHVAC equipment in the CCHVAC area on El. 677'-6", a three hour rated fire .

barrier was constructed of Thermo-Lag material to separate this equipment. This barrier is being replaced with an approved three -

hour fire rated assembly.

3 Electrical Blockout Closure in the Cable Tray Area on El. 631'-0" Thermo-Lag material was used to seal the electrical blockout opening between this area and the cable tunnel on elevation 613'-6". The purpose of this barrier was to provide a three hour fire rated seal in a floor opening. This penetration scal is being replaced with an approved three hour fire rated barrier. ,

4. Electrical Blockout Closure in the Cable Spreading Room on El. 630'-6' Therno-Lag material was used to seal the electrical blockout opening between this area and the Cable Tunnel on elevation 613'-6" and into the barrier separating the two (2) halves of the Cable Tunnel. The purpose of this barrier was to provide a three

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February 11. 1994 NRC-94-0011

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Page'3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated seal in a floor opening. This penetration seal is being replaced with an approved three hour fire rated terrier. ,

5. Cable Tray Enclosure for Cable Tray 1K-034 in the Relay Room Stairwell Enclosure Between El. 613'-6" and 643'-6" A three hour rated fire barrier of horno-Lag material ses constructed around cable tray 1K-034 to provide the required separation from cable tray 2K-030 both of which are located in.

the relay room stairwell. This barrier is being replaced with an J l

approved three hour rated fire barrier.

6. Ventilation Equipment Area Wall, Elevation 659'-6" The west wall of the ventilation equipment area on elevation ,

i 659'-6" contains a large 1herno-Lag material wall section/ seal between columns 9 and 10. This seal was installed above and around four (4) HVAC ducts and some support steel where the ducts travel through this wall and into a large pipe /HVAC chase to maintain the three hour fire rating of the wall. This Ibermo-Lag j seal is being replaced with an approved three hour fire rated assembly.

7 CCHVAC Equipment Area Wall Sections Elevation 677'-6" The concrete block wall enclosing the small HVAC room in the CCHVAC area on the fifth floor contains- three (3) openings and some adjacent support steel which were sealed with Thermo-Lag to saintain the fire rating of the wall. These Therno-Lag seals are ,

being replaced with approved fire rated assemblies.

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8. Cable Tray Enclosure for Trays 1C-078 and 1P-073 Elevatten 667'-6" Two (2) cable trays (1C-078 and IP-073) are routed betsmen the [

Division I CCHVAC equipment area and the SBGTS rooms hase been enclosed by a envelope of Therno-Lag. The purpose of this l l

structure was to provide a three hour rated fire barrier to .

enclose these trays as they traverse the Division II C(NAC area. The two trays were originally considered to be required for safe shutdown but subsequent reanalysis determined that the

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cables in trays IC-078 and 1P-073 are not required for safe shutdown. Hence, the cable enclosure is no longer required and is being removed.

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The openings exposed by the renoval of therno-Lag cable vault in ,

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the Division I CCHVAC enclosure wall and in the wall into the ~

SBGTS area are being filled with UL listed three hour rated and air tight seals using approved materials to restore those barriers to their original design configuration.

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.n g ' 4 USNRC February 11, 1994 NRC-94-0011-Page.4 In the remaining three areas-it was determined that the requirements of Appendix R to 10CFR50 could be set without' these Therso-Lag installations. 'Hence, the following three barriers are being reclassified as smoke and gas barriers and, thus, are not being removed _or_ replaced:

9 HVAC Chase Floor Closure, Elevation 613'-6" The HVAC chase at column H-10 extends from elevation 613'-6" to elevation 677'-6" and is crapletely devoid of combustible material for.its 64 foot verf.ical length. The walls of this chase are constructed and 1ealed as 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barriers. The floor of this chase was constrated of Therso-Lag material and was intended to be a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barrier.

Automatic fire detection is provided at both the 613'-6" and 677'-6" floor openings of this chase. The mezzanine area en elevation 603'-6" is also provided with an automatic wet pipe sprinkler system plus additional sprinkler coverage for selected cable trays on the mezzanine. Manual fire suppression capability is provided at each and of this chase.

UFSAR Section 9A 4.2 3 states that the combustible loading below the chase translates to a' fire duration of less than one hear, however, the presence of the wet pipe sprinklers and automatic detectors will ensure any fire occurring in the vicinity of the chase opening will be quickly detected and extinguished..

Therefore, any postulated fire on elevation 603'-6" will not be of sufficient intensity or duration to prorsgate up a 64 foot high HVAC chase. As documented in UFSAR 3ection 9A.4.2.16 the combustible loading at elevation 677'-6'< translates to a fire duration of less than two minutes. Also, there are no combustible materials in the HVAC chase.

Therefore, based on the above discussion, flase propagation between elevations 603'-6" and 677'-6" via the 64 foot high HVAC chase at column F-10 is not a credible event regardless of the presence of the Thermo-Lag barrier. Hence, this barrier is being reclassified as a continuous non-fire rated smoke and gas barrier as defined in NFPA 101.

10. HVAC Chase Floor Closure. Elevation 630'-6" A second HVAC chase at column F-13 extends from elevation 630'-6", directly above the southwest corner of the Relay Room, to the Control Room ceiling at elevation 654'-0"; and is completely devoid of combustibles for its approximate 23 foot length. The HVAC ducts entering this chase at and on elevation 630'-6" are provided with fire dampers. The walls and the

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USNRC t February 11, 1994- ,

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ceiling around the HVAC ducts exiting the chase on elevation 654'-6" are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barriers. However, the metal HVAC ducts exiting the chase at elevation 654'-0" are not provided with fire dampers. Two pieces of Bermo-Lag material were used to seal the floor of this chase as a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barrier.

Automatic fire detection is provided at both the 630'-6" and 654'-0" elevation of this chase. The Relay Room is also provided with an. automatic halon suppression system. Manual fire suppression capability is provided in both the Relay and Control '

rooms. Additionally, the Control Room is continually staffed by personnel trained in fire suppression.

UFSAR Section 9A.4.2.4 states that the combustible loading in the Relay Room translates to a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire duration, however, the presence of the automatic detection and halon suppression system '

will ensure that any postulated fire in this room will be quickly detected and extinguished. The area above the Control Poon .

ceiling is practically devoid of combustibles in the vicinity of

' this chase. Therefore, any postulated fire in the Relay Room will not be of sufficient intensity or duration to breach the two small Thermo-Lag floor panels and then travel up a approximate 23 '

foot high chase which itself is devoid of combustibles, breach the metal ductwork above this chase, and spread into the Control Room suspended ceiling area. The fire would have to breach the

' metal ductwork twice, once just to get into the ductwork itself, and again to break out into the 654'-0" elevation. Also, NFPA 90A gives HVAC ductwork in walls equal to a one hour fire resistance rating.

Therefore, based on the above discussion, flame propagation between the Relay Room and the Control Roon via the HVAC chase and two breaches of the metal ductwork at column F-10 is not a credible event. Hence, the Thermo-Lag barrier is being reclassified as a non-fire rated continuous smoke and gas barrier as defined in NFPA 101 used to maintain the halon concentration

- in the Relay Roon by preventing it from spreading into the chase.

11. Relay Room Stairwell Enclosure in the Northeast Corner of the Relay Room on El. 613'-6"
  • A three hour rated fire barrier was constructed of Thermo-Lag material to separate the Relay Room from the Control Center This barrier is being northwest stairwell at elevation 613'-6".

reclassified as a continuous smoke and gas barrier as defined by NFPA 101, and is no longer considered as a fire barrier. The remaining stairwell walls become the three hour rated fire barrier separating the Relay Room from the Cable Spreading and Control Rooms. To support this change the following upgrades are

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USNRC February 11, 1994 NRC-94-0011

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i being performed to the existing stairwell walls and ceiling, converting them to three hour rated fire barriers.

the doors leading into the Cable Spreading Room (RM2-4) on

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o elevation 630'-6" and the Control Room (R3-20) on elevation 643'-6" from the stairwell are being replaced with three hour rated doors.

o The underside ceiling of the stairwell will be coated with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated cementitious mixture fire barrier.

The justification for these reclassifications is being included in the Fermi 2 Fire Hazards Analysis (UFSAR Appendix 9A). All efforts to replace or reclassify Therso-Lag fire barriers at Fermi 2 are being planned for the current outage and are expected to be completed by Fall, 1994. Documentation attesting qualifications of replacements and reclassifications are available at Fermi 2 for review and inspection.

If you have any questions, please contact Nr. Girija S. Shukla at (313) 586-4270.

Sincerely, k

cc: T. G. Colburn J. B. Martin M. P. Phillips W. J. Kropp P

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USNRC-February 11, 1994 NRC-94-0011-Page 7 1, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

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DOUGLAS Al. GIPSON' Senior Vice President

'I On this I day of bN W Y , 1994, before se personally appeared Douglas R. Gipson, being first duly sworn and says that he executed the foregoing as his free act and deed.  ;

Notary Public KAREN E REED NOTAnY PUBLt.FONFCECCUNW,MICH.

WY CCht! 5SCN D?iRESW44

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