ML20082C673

Forwards Response to Followup to Request for Addl Info Re GL 92-08, Thermo-Lag 330-1 Fire Barriers

ML20082C673
Person / Time
Site:	Oyster Creek
Issue date:	03/31/1995
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-95-2114, GL-92-08, GL-92-8, NUDOCS 9504070107
Download: ML20082C673 (8)

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GPU Nuclear Corporation U (UClear gifn:;388 Forked River, New Jersey 08731-0388 3 609 971-4000 1 Writer's Direct Dial Number:

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1 March 31, 1995  ;

C321-95-2114  !

U. S. Nuclear Regulatory Commission Att: Document Control Desk l Washington, DC 20555 )

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Dear Sir:

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Subject:

Oyster Cnek Nuclear Generating Station (OCNGS)

Docket No. 50-219 Response to the Follow-up to the Request for AdditionalInformation Regarding Generic Ixtter (GL) 92-08, Issued Pursuant to 10 CFR 50.54(f).

.NRC letter dated December 29,1994, requested additional information regarding Generic Letter (GL) 92-08, "Thermo-Lag 330-1 Fire Barriers," issued pursuant to 10 CFR 50.54(f).

The attachment to this letter provides a partial OCNGS response to the NRC request for additional information. GPU Nuclear will provide the remainder of the requested information within 30 days of notification that an agreement has been reached between NRC ,

and NEI on the issues described herein. The basis for the extension to the response period is 1 our participation in the Nuclear Energy Institute (NEI) coordinated effort to assess the chemical composition of Thenno-Lag and demonstrate the equivalency of the materials tested by the NEI fire barrier test program with those installed at OCNGS. The extension is due to the time mquired for NEI and the NRC Staff to resolve issues arising fmm the March 14, 1995 meeting regarding the subject request for additional infonnation. A response to Sections 1.a (1), (3), (5), (6), (7), and (9) cannet be provided without agreement between NEI and the NRC Staff and subsequent guidanco to the industry by NEI.

I C 7003.9 9504070107 950331 PDR ADOCK 05000219 P PDR .

I GPU Nuclear Corporation is a subsidiary of the General Public Utikties Corporation g

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C321-95-2114 Page 2 l

GPU Nuclear endorses the NEI program to develop a generic data pool of chemical testing L

data which will establish an appropriate basis for comparison of the OCNGS Thermo-I2g material to the NEI test material and provide adequate assurance that OCNGS fire barriers -

are represented by the NEI test program.

Sincerely, h,c J. J. Barton

1. Vice President and Director Oyster Creek Attachment DJD/ pip c: Administrator, Region I l Oyster Creek NRC Resident Inspector l Oyster Creek NRC Project Manager

! A. Marion - NEI l

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ATTACHMENT REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08 '

"THERMO-LAG 330-1 FIRE BARRIERS" PURSUANT TO 10 CFR 50.54(f)

't. Thermo Lag Materials NRC Request

a. Describe the specific tests and analyses that will be performed to verify that the Thermo-Lag fire barrier materials that are curmntly installed at Oyster Creek Nuclear Generating Statiori, or that will be installed in the future, are repmsentative of the materials that were used to address the technical issues associated with Thermo-Lag barriers and to construct the fim endurance and ampacity derating test specimens. The tests and analyses shall addmss the -

material propenies and attributes that wem determined or contmiled by TSI  :

during the manufacturing pmcess and the quality assurance pmgram. The-tests and analyses shall also address the material propedies and attributes that contribute to conclusions that the Thermo-I2g materials and barriers conform I to NRC mgulations. These include:

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(1) chemical composition (2) material thickness ]

(3) material weight and density '. 1 (4) the presence of voids, cracks, and delaminations (5) fire endurance capabilities (6) combustibility l (7) flame spread rating  ;

(8) ampacity derating .  !

(9) mechanical propenies such as tensile strength, compressive stmngth, j shear strength, and flexural strength j

Response

(1) chemical composition GPU Nuclear intends to continue to use the Thcano-Lag installed at OCNGS.

As stated in the cover letter, GPU Nuclear supports the NEI coordinated effort .

to assess the chemical composition of Thermo-Iag and demonstrate the equivalency of the materials tested by the NEI fim barrier test pmgram with those installed at OCNGS as documented in NEI's letters of January _17,1995 and February 21,1995 to the NRC. GPU Nuclear plans on providing samples  ;

from OCNGS for pymlysis gas chromatographic analysis consistent with NEI's j coordinated approach.

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. Atfachment

[ - . C321-95-2114

Page 2 of 6 1 .

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1 (2) material thickness To ensure receipt of consistent quality material from TSI, GPU Nuclear 1' instituted quality control checks via GPU Nuclear vendor surveillance at TSI's factory prior to miease for shipment. Thomugh mceipt inspection checks were -

performed to established inspection plans to ensure they maintained engineering requirements. Inspections were documented on receipt inspection reports. Line items of the contract were inspected. These inspections consisted -

of either 100% or sampling using engineering approved inspection and sampling plans.

GPU Nuclear receipt inspections verified thickness by taking readings on each-  !

- piece. Any piece not meeting the minimum thickness was rejected and returned to TSI. These requirements provide adequate assurance of proper material thickness. Therefore, no additional consideration will be given to material thickness; l

(3) material weight and density The combination of material thickness checks and the attention given to voids -

in prefabricated sections as described below provide reasonable assurance that weight and density was within acceptable limits. - Completion of the NEI coordinated industry effort to demonstrate chemical consistency will provide assurance of pmper material weight and density. This issue will be addressed in greater detail ia a follow-up letter pending resolution of the chemical testing pmgram. . ,

(4) the presence of voids, cracks, and delaminations During receipt inspection, any material identified as containing voids or l cmcking beyond specified limits was returned. Since the material was subject to considerable field work (cut and fit) small voids were filled with TSI trowel grade material when exposed during installation. Dunng receipt inspection, gouges, crushing, and chipped edges could be repaired and accepted.

Separation of material fmm the stress skin was a cause for rejection and return of the material. These requiremer.;s adequately address the concern of-potential presence of voids, cracks, and delaminations. Therefore, no  ;

additional consideration will be given to the presence of voids, cmcks, and  !

delaminations.

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Attachment

- C321-95-2114 Page 3 of 6 e i l

'(5) fire endurance capabilities -

(6) combustibility  !

(7) flame spread rating  ;

GPU Nuclear is evaluating the results of the NH fire barrier testmg program ,

and is utilizing the information in the NEI Application Guide to establish fire  :

endurance ratings for Thermo-Lag cable raceway systems. This is considemd  !

adequate for establishing fim endurance capabilities (pending evaluation of chemical testing results). Combustibility and flame spread rating have been  !

established for materials included in the NEI fim barrier test program. The NE program is considend adequate for establishing combustibility and flame spread ratings (pending evaluation of chemical testing results). This issue will .!

be addressed in gmater detail in a follow-up letter pending resolution of the . .

chemical testmg program.  ;

(8) ampacity derating f The OCNGS plan for evaluating ampacity derating is described in GPU Nuclear letter to NRC C321-94-2279, dated December 27,1994 (9) mechanical properties such as tensile strength, compmssive strength, shear strength, and flexural strength A plan and schedule to address this issue will be pmvided in a follow-up letter i consistent with the msponse timeframe identified in 1.c.

4 NRC Reauest

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 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, tmwel-grade material, stress skin) of samples that will be tested or analyzed.

Attachment j C321-95-2114 Page 4 of 6

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i Resoonse

l. GPU Nuclear is currently planning to panicipate in the NH sponsomd chemical test l pmgram. This program is intended to establish the similarity between the materials l previously tested as part of the NH fim barrier test progam and the materials installed at operating plants and those specifically in use at OCNGS. As stated in the i response to item 1.a, GPU Nuclear currently supports the NH coordinated approach.

l Because of the outstanding issues with respect to the size of the sample population ,

identified in the March 14,1995 meeting, which requires resolution between NH and

the NRC with respect to increasing the industry sample population to support a

{ meaningful conclusion as to the material consistency, we will not provide a plant

specific pmgram to address the question. By participating in the NH program, GPU j Nuclear expects that the material chemical composition and related material weight i and density, fire endurance rating, combustibility, and flame spread issues can and

~ will be resolved by the industry action with'its sizeable sample population.

i NRC Requgg l c. Submit the schedule for verifying the Thermo-Lag materials.

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The NRC discussion during the March 14,1995 meeting with the four (4) NH pilot .

j plants, indicates to GPU Nuclear that a generic approach to the resolution of this

issue is reasonable. However, as stated by NRC in this meeting, several issues

1. remain to be resolved between the Staff and NH such as the adequacy of sample size,

, laboratory qualifications, establishment of a technical basis for important chemical j constituents and the methodology for analyzing the test results. Because GPU

Nuclear supports the NH coordinated industry effort and currently plans to participate in this program and because the aforementioned issues must be resolved before GPU Nuclear can develop plans and schedules; our actions will be limited to submitting the currently requested samples. We will pmvide further information within 30 days of i '

notification that an agreement has been reached between NRC and NH on these l issues, which will address the progress made toward development of plans and a .

schedule to resolve the chemical composition and related material weight and density,

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i fire endurance capability, combustibility and flame spread rating issues as it relates to -

OCNGS.

NRC Reauest

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. *l

• - Atischment

. C321-95-2114

. Page 5 of 6 l Resoonse GPU Nuclear will submit a written repon that confirms that the chemical tests have

, ' been completed and the msults. If any changes to our plans are made based on these

test results, we will repon our revised plans.

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2. Important Barrier Parameters .

!' . NRC Request

a. Describe the ' examinations and inspections that will be performed to obtain the ,'

imponant barrier parameters given in Section II of the RAI of December 1993 for the Thermo-Lag fire barrier configurations installed at Oyster Cmek l Nuclear Generating Station.

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Response

t The OCNGS submittal C321-94-2012, dated February 10, 1994, in msponse to I

Generic Ietter 92-08, "Thermo-Lag 330-1 Fire Barriers," Pursuant to 10 CFR j 50.54(f), provided a description of the activities to be undenaken to obtain information on the "Important Barrier Parameters" addressed by Section II. Those actions have been performed and continue in accordance with the plan described.

NRC Request

b. Describe the methodology that will be applied to determine the number and type of representative in-plant fim barrier configurations that will be examined i in detail and demonstrate that the sample size is adequate to ensum that the

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information and data that will be obtained am 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 pmvide reasonable

! assurance that the materials and impodant barrier parameters used to constmet the in-plant barriers and any future barrier installations or modifications, are i representative of the parameters used to construct the fire endurance test specimens.

Resoonse The methodology applied to determine the number and type of mpresentative in-plant fire barrier configurations examined in detail and demonstrate that the sample size is adequate to assure that the information and the data obtained are adequate to assess the total population of in-plant Thermo-Lag barriers has also been previously provided

, in Section II of C321-94-2012, dated February 10,1994 in response to Generic letter 92-08, "Thermo-Lag 330-1 Fire Barriers," Pursuant to 10 CFR 50.54(f).

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Attachment o C321-95-2114

' Page 6 of 6 j l GPU Nuclear considers the Quality Control applied to the original installation and the -

, parameters evaluated during installation as adequate assurance to pennit verification, by review of installation documents, of the mlevant pammeters not visible by

. walkdown and does not plan to perform destnictive examination of installed barriers.

d NRC Request  !

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c. Submit the schedule for obtaining and verifying all of the imponant barrier j parameters. i j

,_ Resnonse 4

GPU Nuclear letter to NRC C321-94-2279, dated December 27,1994 identified the  !

status of effons to obtain important barrier parameter information. Plant walkdowns '

are complete for the seven (7) affected fire area / zones. The comparison activity and .l j barrier acceptability determinations are complete except for five (5) elements in a l

population of over 400 elements. The detailed information is being retained and will 1 be available for NRC audit.

l NRC Reauest

d. After the infonnation has been obtained and verified, submit a written i

supplemental repon that confirms that this effon has been completed and i provides the results of the' examinations and inspections. Verify that the parameters of the in-plant configurations are representative of the parameters i of the fire endurance test specimens. Describe any changes to previously-l submitted plans or schedules that result from the examinations.

Response

4 GPU ' Nuclear does not plan to perform any additional verifications of barrier

] parameters at this time. If additional infonnation is obtained that demonstrates a neeo-i for additional verifications those results will be reponed when such verifications are completed and the results analyzed.

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