ML20082B237
| ML20082B237 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/29/1995 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, GNRO-95-00040, GNRO-95-40, NUDOCS 9504050067 | |
| Download: ML20082B237 (13) | |
Text
_ O
= ENTERGY EE"E""' "'""*'
Port Gbson, MS 39150 Tel 601437 2000 C. R. Hutchinson Voe Presdont Operatrus Grand Gulf Nxioar Staton March 29, 1995 U.S.
Nuclear Regulatory Commission Document control Desk Mail Stop P1-37 Washington, D.C.
20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Response to Follow-up to the Request for Additional Information (RAI) Regarding Generic Letter 92-08 Issued Pursuant to 10CFR50.54(f) on December 28, 1994 GNRO-95/00040 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 Grand Gulf Nuclear Station (GGNS), are representative of tested materials and configurations.
Entergy Operations' response for GGNS is provided in Attachment 1.
This information is being submitted under affirmation in accordance with 10CFR50.54(f)(Attachment 2). Please contact Charles E.
Brooks at (601) 437-6555 should you have any questions, or require additional information.
Yo r trul
^
CRH B/amb attachments.
1)
Grand Gulf Nuclear Station Response to I
the December 28, 1994 RAI concerning Thermo-Lag 040129 2)
Affirmation per 10CFR50.54(f>
^
l 9504050067 950329 PDR ADOCK 05000416 I
P____._
__ _PDR_
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' to GNRO-95/00040 1
Response to follow-up Request for Additional Information Regarding Generic Letter 92-08 Issued Pursuant to.10CFR50.54(f)
Dated December 28, 1994 i
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Narch 29, 1995 GNRO-95/00040 Page 2 of 3 1
1 l
cc:
Mr.
D.
C.
Hinti (w/a)
Mr. H.
W. Kaiser (w/a)
Mr. R.
B. McGehee (w/a)
Mr.
R.
S.
Reynolds (w/a)
Mr.
J. E. Tedrow (w/a)
Mr. H. L. Thomas (w/a)
Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.
S.
Nuclear Regulatory Commission Region II 101 Marietta St.,
N.
W.,
Suite 2900 Washington, D.
C.
20555 Mr. Paul W.
O'Connor, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.
S.
Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.
C.
20555 Mr.
S.
Varga Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Mail Stop M12-G-18 Washington, D.C.
20555 Mr. Biff Bradley (w/a)
Senior Project Manager Nuclear Energy Institute 1776 Eye Street.,
N. W.,
Suite 300 Washington, D.
C.
20555
'Aarch 29 1995 GNRO-95/00040 Page 3 of 3 bec:
Mr. T.
E. Barnett (w/a)
Mr. M. N. Bakarich (w/a)
Mr.
B.
J. Blanche (w/a)
Mr.
J.
L. Blount (w/a)
Mr.
D.
G. Bost (w/a)-
Mr.
C.
E. Brooks (w/2)
Mr.
R. W.
Byrd (w/a)
Mr. M.
R. Cumbest (w/a)
Mr.
L.
F. Dale (w/a)
Mr.
L.
I.
Daughtery (w/a)
Ms.
S.
S. Davis (w/a)
Mr.
J.
P. Dimmette (w/a)
Mr.
R.
K.
Dubey (w/a)
Mr.
J.
J. Fisicaro (w/a) (RBSES)
Mr.
D.
W.
Jeff (w/a)
Mr.
A. Khanifar (w/a)
Mr.
M.
J. Meisner (w/a)-
l Mr.
D.
C. Mims (w/a) (ANO)
Mr.
D.
L. Pace (w/a)
Mr.
E.
G. Roan (w/a) (RBSES)
Mr.
J.
C. Roberts (w/a)
Mr.
F.
W. Titus (w/a)
Mr.
D.
W. Vinci.(w/a)-(W3)
File (LCTS)
File (Hard Copy)
File (RPTS)
File (NSSRA)
File (Cential ( 16 )
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1.Thermo-Lac 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 Grand Gulf-l Nuclear Station,-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 l
(4) the presence of voids, cracks, and delaminations (5) fire endurance capabilities (6) combustibility (7) flame spread rating (a) ampacity derating (9) mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength
Response
As stated in responses to previous NRC requests for additional information regarding Thermo-Lag, GGNS is pursuing a comprehensive analysis of-in-plant Thermo-
~
Lag assemblies.
Our approach includes participation in the industry test program and plant specific initiatives to validate the applicability of-test results.
The GGNS analysis will provide reasonable assurance that installed Thermo-Lag materials and configurations are representative of the tested-materials and configurations.
With regard to material representativeness, GGNS is not aware of any compelling evidence indicative of an i
appreciable variance in the chemical or physical attributes of Thermo-Lag materials.
On the contrary, considerable evidence has been compiled that portrays j
a relative continuity of underlying chemical and physical attributes.
l A significant quantity of independent fire endurance testing has been performed utilising Thermo-Lag materials obtained.from a variety of sources.
The fire test data portrays a relatively consistent level of fire endurance when comparing similar
+
-configurations or attributes.
This consistent level of fire endurance is indicative of the chemical and physical continuity of Thermo-Lag materials'used in
,i the various fire endurance tests.
As part of the industry test program, Thermo-Lag.
samples from a variety of sources, including samples from GGNS, have been compared by pyrolysis gas chromatography using ASTM D3452.
The results of this testing, performed by an independent test laboratory, indicate no appreciable difference between the samples.
The independent laboratory's test report concluded ~that the samples are the same.
1 GGNS has submitted Thermo-Lag samples for pyrolysis gas chromatography using the same test protocol and laboratory as in the previous testing.
The additional samples included material removed from installed Thermo-Lag assemblies in different areas of the plant and from warehouse stock.
One and three hour samples of pre-formed conduit sections and panels were included, as well as cured trowel grade material taken from installed assemblies.
The test results for our i
samples will be compared with the test results for
.i samples provided by other utilities across the industry.
The scope of this testing, in addition to the previous testing, is more than sufficient to i
provide high confidence in the continuity of Thermo-Lag materials used across the industry, as well as, the representativeness of the GGNS Thermo-Lag materials when compared to tested Thermo-Lag i
materials.
I i
With GGNS' Thermo-Lag materials demonstrated to be representative of tested Thermo-Lag materials, we plan l
l to utilize the results of generic testing and industry experience to address issues such as fire endurance, combustibility, flame spread and mechanical properties.
The NRC has been closely involved in the fire endurance testing performed throughout the industry and is familiar with the test protocols utilized and other pertinent details.
Combustibility and flame spread testing of Thermo-Lag have been performed at Underwriters Laboratories as part of the industry test program.
The test protocols utilized were ASTM E1321, Lateral Flame 1
Spread, and E1354, Heat of Combustion.
F
.Thermo-Lag. mechanical properties (e.g.,
tensile e
strength, compressive strength, shear strength, and.
flexural strength), are important parameters:
1 affecting the structural. integrity of_Thermo-Lag assemblies.
The aforementioned fire endurance.
testing is sufficient to insure structural integrity _
t of Thermo-Lag assemblies when ' subjected :to, the effects of fire.
As for_the_structuralfintegrity,of Thermo-Lag assemblies:under normal plant conditions, industry experience shows Thermo-Lag assemblies to be rugged and durable.
This is evidenced _by our.
experience in destructively' removing numerous z
Thermo-Lag samples..Also, dynamic testing of Thermo-Lag has;been performed that demonstrates seismic ruggedness.
Furthermore,' the structural integrity of Thermo-Lag assemblies is not entirely dependent on the mechanical properties of Thermo '
-i Lag.
In-plant assemblies are substantially i
supported by.a variety of mechanisms including tho' protected and intervening component (s), metal banding, bolts and/or other fasteners.-
Based on the considerable testing and industry experience that.
demonstrates acceptable continuity of Thermo-Lag physical and chemical attributes, GGNS asserts that.
l site specific testing for Thermo-Lag mechanical properties is unwarranted.
With regard to installation or material anomalies (e.g., material thickness, voids, cracks, delaminations, etc.), GGNS performed visual and
'i
~;
destructive examinations of in-plant assemblies to confirm a variety of' installation parameters, as well as, identify installation or material anomalies.
The information obtained from the visual.
j and destructive examinations was used to establish detailed isometric drawings of as-built, in-plant I
assemblies.
Installation and/or material-anomalies.
are typical of the attributes that are considered when comparing tested to installed configurations and is sufficient to resolve these concerns.
i Ampacity derating is an important element in GGNS' comprehensive approach to resolve Thermo-Lag issues.-
l GGNS supports use'of the draft IEEE-P848 through industry generic testing.
Although we desire to i
proceed with ampacity testing at the earliest possible time, it is preferable to not perform such j
testing without reasonable assurance that the proposed test protocol will be acceptable to the NRC.
l As previously mentioned, Thermo-Lag samples from
}
warehouse stock are included in GGNS' pyrolysis gas chromatography testing that is presently underway.
t Positive. test results will provide. reasonable assurance with regard to the chemical and physical
. attributes of our warehouse stock in tho' event that its use becomes necessary.in the. future.. If.new materials are-procured-from Thermal Science, Inc. at some future date' we= anticipate use of our commercial grade dedication program, including an appropriate receipt inspection'and testing; to ensure material parameters.
Required Information
- b. Describe the 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 i
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 i
the time of installation and manufacture of~the various in-plant materials and barrier installations.
l Give the number and types (e.g., panels,. conduit pe-l shapes, trowel-grade materials, stress skin) of.
samples that will'be tested or analyzed.
Response
i As part of the industry test program, the Nuclear l
Energy Institute (NEI) has requested that all plants.
utilizing Thermo-Lag submit a small number of.Thermo-Lag samplas for pyrolysis gas chromatography testing.
At least.one sample representative of the various barrier types and trowel grade material utilized at the respective plant was to be included.
The broad scope of the industry samples will~ provide specimens of Thermo-Lag material representative of a wide range of manufacturing and installation dates.
As previously mentioned, Grand Gulf Nuclear Station submitted two samples of Thermo-Lag for pyrolysis gas chromatography testing that was performed in August 1993.
The samples were taken from warehouse stock at GGNS and consisted of a one hour and a three hour pre-formed conduit section.
To support the broader industry chemical testing proposed by NEI, additional samples of Thermo-Lag were submitted from Grand Gulf.
The GGNS Samples consisted of the following:
One 1-hour pre-formed conduit section taken from I
warehouse stock One 1-hour panel section taken from in-plant assemblies One 3-hour pre-formed conduit section taken warehouse stock f
)
y N
One 3-hour panel section taken from in-plant
' assemblies One sample.of trowel grade material'taken from_in-e plant assemblies Required Information
- c. Submit _ the schedule for verifying ' the Thermo-Lag, materials.
Response
GGNS submitted representative Thermo-Lag samples for.
chemical testing in March 1995.
At this time no completion date has been provided..Other attributes, Las previously discussed, will be addressed per the schedule for completion of the GGNS Comprehensive Thermo-Lag Evaluation as delineated in our letter dated December 21, 1994.
Required Information 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
l NEI submitted copies of the August 1993, pyrolysis gas chromatography test reports to--the NRC on February 8, 1994.
As has been the past practice with the industry testing initiative, NEI is expected to provide the NRC with confirmation of the completion of the industry i
wide chemical testing program, including the results-of the tests and analyses for NRC review.-
In addition, GGNS will appraise the'NRC of developments associated with the GGNS comprehensive Thermo-Lag Evaluation in accordance with previous commitments.
- 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 e
the Thermo-Lag fire barrier configurations installed at GGNS.
l-.-
Response
Please refer to Entergy Operations' response dated December 21, 1994, to the NRC's letter dated September 23, 1994,'" FOLLOW-UP TO THE' REQUEST FOR ADDITIONAL INFORMATION-(RAI) REGARDING GENERIC LETTER 92-08 ISSUED PURSUANT 1N) 10 CFR 50.54(f) ON DECEMBER 22, 1993 GRAND GULF NUCLEAR STATION" 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 fire barriers. A large enough sample of the population of configurations should be examined to provide reasonable assurance that the. material and important barrier ~ parameters used to construct the in-plant barriers and any future barrier installations or modifications, are representative of the parameters used to construct the fire endurance test specimens.
Response
GGNS has visually examined all Thermo-Lag raceway assemblies and documented on isometric drawings those attributes which can be determined without the destruction of the respective fire barriers.
In order to confirm the material and installation attributes internal to the Thermo-Lag assemblies, twenty-one assemblies were destructively examined. The configurations to be destructively examined were selected based on the following:
A minimum of one configuration was selected from each fire zone where Thermo-Lag was installed.
Sampling included both one and three hour Thermo-Lag assemblies.
A minimum of two samples were taken from each type Thermo-Lag assembly (e.g., coverage at supports, on pull and terminal boxes, conduits, cable trays and the interface between Thermo-Lag and Kaowool).
Required Information
- c. Submit the schedule for obtaining and verifying all of the important barrier parameters.
- c. 3 3
Response
Please refer to.Entergy Operations' response dated i
December 21, 1994, to the NRC's letter dated September'
)
23,.1994.
Required'Information
')
'd. Af ter the information' has been obtained and verified, submit a written supplemental report that confirms that this effort has been-completed and provides the i
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.
L examinations.
Response
By letter dated December 21, 1993 the NRC requested that GGNS describe the examinations and inspections that will be performed to verify that important barrier parameters of;the NEI test specimen are bounding for the GGNS Thermo-Lag configurations.
l Additionally, parameters that.are unique to GGNS ware to be evaluated for their fire endurance capabilities.
As stated in our letter dated December 21, 1994 (Item 1.c Response), GGNS has performed destructive and visual examinations and inspections of our.in-plant 1
Thermo-Lag assemblies. By letter dated August 26, 1994
+
(LER 94-008-00), we notified the NRC of deficiencies that were identified as a result of these examinations.
I As part of our ongoing efforts to resolve Thermo-Lag fire endurance issues, the results from the visual and destructive examinations and inspections were l
incorporated into the GGNS comprehensive Thermo-Lag i
evaluation (NEI Applications Guide).
The above information satisfies the written supplemental reporting requirement for confirming that i
this effort has been completed. Results from this effort, as required by the reporting requirements of Generic Letter 92-08 are being maintained for NRC audit and inspection.
Entergy Operations will appraise the NRC of j
developments associated with the GGNS Comprehensive Thermo-Lag Evaluation in accordance with previous commitments.
i
i 4.
to GNRO-95/00040 Affirmation Per 10CFR50.54(f)
}: 4J
'i(
L>'-
- e:
BEFORE THE
[,
UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE No. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and
~ SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
AFFIRMATION I, M.
J. Meisner, state that I am Director, Nuclear Safety & Regulatory Affairs (GGNS),
Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this response to Generic Letter 92-08 Request for Additional Information for the Grand Gulf Nuclear' Station; that I signed this response as irector, Nuclear Safety & Regulatory Affairs (GGNS), of Entergy Operations, Inc., a d that the statements made and the matters act.forth therein are true and correct to th st of y knowledge, information and balief.
g
-STATE OF MISSISSIPPI COUNTY OF CLAIBORNE S!!3 SCRIBED AND SWO TO before me a Not ry Public, in and for the County and State above utmed, this
. ((
day of z24 1994.
(SEAL)
OV72
(
Notary Public h!B fNO
$C mv COMM1 N El 26 Jtiht 5.1998
' BONDED THRU STEG&lL NOTART GEEvics