ML20081L615
| ML20081L615 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/29/1995 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, W3F1-95-0047, W3F1-95-47, NUDOCS 9503300267 | |
| Download: ML20081L615 (10) | |
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,.. e tergy Operations,Inc.
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Kdiona. LA 70066 Tel 504 739 6774 R. F. Burski oncu.
Nuclear Safety Wawtryc 3 W3F1-95-0047 A4.05 PR March 29, 1995 U.S. Nuclear Regulatory Commission ATTN: Drun>ent Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Followup to the Request for Additional Information (RAI)
Regarding Generic Letter 92-08, Issued Pursuant to 10 CFR 50.54(f) dated December 29, 1994 (TAC NO. M85621) i Gentlemen:
The Nuclear Regulatory Commission (NRC) issued the subject letter requiring Entergy Operations, Inc. to provide information demonstrating that Thermo-Lag materials and configurations, installed at Waterford 3 Steam Electric Station are representative of tested' materials and configurations.
Entergy Operations' response for Waterford 3 is provided in Attachment 2.
This information is submitted under affirmation (Attachment 1).
Please contact Mr. Oscar P. Pipkins at (504) 739-6707 if you have any questions, or require additional information.
Very truly yours, l
i R.F. Burski Director Nuclear Safety RFB/0PP/ssf Attachments l
cc:
L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office I
9503300267 950329 l
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NUCLEAR REGULATORY COMMISSION.
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Entergy Operations, Incorporated
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Docket No.'50-382-
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Waterford 3 Steam Electric Station
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~i AFFIDAVIT 6
.R.F. Burski, being duly sworn, hereby deposes and says'that he is Director, Nuclear Safety - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Followup to the Request for Additional Information Regarding NRC
-Generic Letter 92-08; that he is familiar with the content thereof;'and that.
.the matters set forth therein are true and correct to the best of.his knowledge, information and belief.
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.m R.F. Burkki Director, Nuclear Safety - Waterford 3 j
i STATE OF LOUISIANA
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PARISH OF ST. CHARLES
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i Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 2.9" day of - MM /2 c M
, 1995.
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My Commission expires O ' N i
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r to W3F1-95-0047 Response to NRC Request for Additional Information
r Attachm:nt 2 to W3F1-95-0047 Page 1 of 7 l.
Thermo-Lag Materials Required Information a.
Describe the specific tests and analyses that will be performed to verify that the Thermo-Lag fire barrier materials that are currently installed at Waterford 3, or that will be installed in the future, are representative of the materials that were used to address the technical issues associated with Thermo-Lag -
barriers and to construct the fire endurance and ampacity derating test specimens. The tests and analyses shall address the material properties and attributes that were determined or-controlled by TSI during the manufacturing process and the quality assurance program. The tests and analyses shall also address the material properties and attributes that contribute to conclusions that the Thermo-Lag materials and barriers conform to NRC regulations. These include:
(1) chemical composition (2) material thickness (3) material weight and density (4) the presence of voids, cracks, and delaminations (5) fire endurance capabilities (6) combustibility (7) flame spread rating (8) ampacity derating (9) mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength
Response
The following is a description of the specific tests and analyses that will be performed to verify that the Thermo-Lag fire barrier materials that are currently installed at Waterford-3 (none in storage at this time) are representative of the materials that were used to address the technical issues associated with Thermo-Lag barriers and to construct the fire endurance test specimens.
Note that ampacity derating is not applicable at Waterford 3 since Thermo-Lag was not the material used at the plant as a barrier for cable runs (trays, conduits, termination boxes, etc.).
It will be demonstrated that the I
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Attachment.2;to W3F1-95-0047 Page 2 of 7-
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tests;and analyses address the material properties and.
attributes that'were determined or controlled by TSI during the manufacturing process and the quality assurance program.
It will further be demonstrated' that the tests and analyses address the material properties.and attributes that contribute to conclusions that the Thermo-Lag materials and barriers conform to NRC regulations. The following discussion addresses the applicable attributes.
(1)
Chemical Composition Waterford 3 has contracted Nucon International Inc. to perform chemical analysis testing on representative samples of _Thermo-Lag taken from plant installations. Nucon will perform a pyrolysis gas chromatography test that'will be done in accordance with the guidance of ASTM D3452.
This test will-determine the chemical compositon of the samples.
(2)
Material Thickness Material thickness of the Thermo-Lag installed at Waterford 3' was determined to be acceptable by destructive examination I
during Refuel 6.(Condition Identification CI-289585).
(3)
Material Weight and Density Waterford 3 has contracted Nucon International Inc. to determine the weight and density of the above mentioned representative samples.
(4)
The Presence of Voids, Cracks and Delaminations The' presence of voids, cracks and delaminations in the Thermo-L Lag installations are verified during performance of surveillance procedure ME-003-009. This surveillance will be performed on the Waterford 3 Thermo-Lag installations prior to-declaring them operable.
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f Atttchment 2 to B
.W3F1-95-0047 6
Page 3 of.7 (5)- ' Fire Endurance Capabilities
- The fire endurance capabilities of the installed Thermo-Lag.
have been evaluated using the NEI Application Guide.for Evaluation of Thermo-Lag 330 Fire Barrier Systems.
Following verification that samples tested meet or exceed Thermo-Lag
-attributes, a re-evaluation (Generic Letter 86-10 evaluation,.
Supplement 1) will' confirm that the installed applications of.
Thermo-Lag (seven dampers) will maintain a 3. hour barrier.
l The NRC has been closely involved in the. fire' endurance testing-performed throughout the industry and is familiar with the test 1
protocols utilized and other pertinent details.
(6) and (7) Combustibility and Flame Spread Rating Combustibility and flame spread testing of Thermo-Lag have been performed as described in Thermo-Lag 330-1 Combustibility-Evaluation Methodology Plant Screening Guide prepared for NUMARC by Stone & Webster Engineering Corporation. The test-protocols utilized were ASTM E1321, Standard Test Method for-Determining Material Ignition and Flame. Spread Properties, and
.E1354, Standard Test Method for Heat and Visible ~ Smoke Release Rates for Materials and Products Using an Oxygen Consumption Calorimeter. The information is available in the NEI "Thermo-
= Lag 330-1 Combustibility Evaluation Methodology Plant Screening i
Guide. " The. values that are currently being applied in a 1
supplement (in progress) to.the Waterford 3 Thermo-Lag Generic Letter 86-10 Evaluation (originally completed 12/13/94) include:
o minimum ignition temperature 538 C, ignition radiant flux 25 Kw/m*,
2 heat release rate 100 Kw/m,
heat of combusition 16.3 MJ/Kg, minimum flame spread temperature 538 C, and 2
minimum flame. spread radiant' flux 25 Kw/m (8)
Ampacity Derating Ampacity Derating is not applicable at Waterford 3 since Thermo-Lag was not the material used at the plant as a barrier for. cable runs (trays, conduits, termination boxes, etc.).
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'Page 4 of.7 (9)
Mechanical Properties Such As Tensil Strength,-
Compressive Strength, Shear Strength, and Flexural Strength The mechanical properties of Thermo-Lag, such as tensil strength, compressive strength, etc. arelnot considered i
applicable at Waterford 3 since the Thermo-Lag is not configured to provide structural support.
In the seven damper applications at Waterford 3, the Thermo-Lag is-. receiving full contact structural support from the steel surfaces of the ductwork that is in flush contact with the Thermo-Lag.
Required Information b.
Describe tbn methodology that.will. be used to determine the sample ' size and demonstrate that the sample size will be large enough to ensure that the information and data obtained will be sufficient to assess the total population of in-plant Thermo-Lag barriers and the materials that will be installed in the future.
In determining the sample size, consider the time.of installation and manufacture-of the various in-plant materials and barrier installations. Give the number and types (e.g.,
panels, conduit preshapes, trowel-grade materials, stress skin) of samples that will be tested or analyzed.
Response
Samples were taken from three of the seven damper installations at Waterford 3.
The three samples were selected based on groupings of similar installations. The Thermo-Lag configurations of the two damper installations in the Emergency Diesel Generator Rooms (one in eacn room) were similar enough to justify one sample from the two installations.
Likewise, another grouping of three (rectangular duct) dampers and lastly a grouping of two (circular duct) damper installations resulted in the remaining two Thermo-Lag samples.
Required Information c.
Submit.the schedule for verifying the Thermo-Lag materials.
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f to W3F1-95-0047' l
Page 5 of 7 m
Response
All. of the Entergy Operations,.Inc. nuclear plants are sending their samples to Nucon-in the same time frame. Waterford 3 samples were shipped to Nucon on 3/14/95.
Discussions with Nucon' indicate that completion of the tests and a' complete:
report-to Entergy Operations, Inc. (for Waterford 3) can_be j
delivered by April 30, 1995.
Based on review of the remaining list of attributes and the-characteristics of Waterford 3's limited applications of Thermo-Lag (material in flush contact with ' steel-surfaces with no'ampacity concerns),
no additional testing would be required for Waterford 3 to determine the conclusions addressed in the NRC 50.54(f) letter.
Required Information i
d.
After the analyses and _ tests have_ been completed, submit a written supplemental report that confirms that this effort has been completed and provide the results of the tests and analyses. Describe any changes to previously submitted plans or schedules that result from the tests or analyses.
Response
Waterford 3 will provide a written supplemental report to the NRC as prescribed above when testing, to be performed by Nucon, is complete. The Supplemental Report will be submitted following completion of the supplemental Generic Letter 86-10 evaluation (Rtype A9.02), within 60 days of receipt of the Nucon testing results (tentatively by June 29,1995).
2.
Important Barrier Parameters Required Information a.
Describe the examinations and inspections that will be performed to obtain the important barrier parameters given in Section-II of the RAI of December 1993 for the Thermo-Lag fire barrier configurations installed at Waterford 3.
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~ to W3F1-95-0047 Page 6 of 7
Response
Destructive examinations of installed Thermo-Lag barriers to determine unknown installation parameters are complete (CI-289585/ WA-01121648).
Required Information b.
Describe the methodology that will be applied to determine the number and type of representative in-plant fire barrier configurations that will be examined in detail and demonstrate that the sample size is adequate to assess the total population of in-plant Thermo-Lag barriers. A large enough sample of the total population of configurations should be examined to provide reasonable assurance that the materials and important barrier parameters used to construct the in-plant barriers and any future barrier installations or modification, are representative of the parameters used to construct the fire endurance test specimens.
Response
Samples were taken from three of the seven damper installations at Waterford 3.
The three samples were selected based on groupings of similar installations. The Thermo-Lag configurations on the two damper installations in the Emergency Diesel Generator Rooms (one in each room) were similar enough to justify one sample from the two installations.
- Likewise, another grouping of three (rectangular duct) dampers and lastly a grouping of two (circular duct) damper installations resulted in the remaining two Thermo-Lag samples.
Required Information c.
Submit the schedule for obtaining and verifying all of the important barrier parameters.
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% So Attachm:nt 2 to W3F1-95-0047 a
Page 7 of 7
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Response
Destructive examinations ofiinstalled Thermo-Lag barriers to-determine unknown installation parameters are complete (CI-289585/ WA-01121648). The remaining important material properties and attributes will be obtained from the contracted Nucon testing. Based on discussions ~with Nucon concerning scheduled completion of testing of Thermo-Lag samples (chemical L.
and material weight and density testing), the barrier re-evaluation (Generic letter 86-10 evaluation, Supplement 1) should be complete by June 29, 1995.
Required Information d.
After the information has been obtained and verified, submit a I
written supplemental report that confirms that this effort has been completed and provides the.results of the examinations and inspections. Verify that the parameters of the-in-plant configurations are representative of the parameters of the fire endurance test specimens. Describe any changes.to previously submitted plans or schedules that result from the examinations.
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Response
Waterford 3 will provide a written supplemental report to the NRC as prescribed above when-testing, to be performed by Nucon, is complete. Waterford 3 will incorporate the Nucon test results into a supplement to the existing complete Generic Letter 86-10 evaluation (filed in Rtype A9.02). A copy of the supplemented 86-10 evaluation will be attached to the supplemental report to the NRC.
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