ML20086A648

Forwards Suppl Response to NRC 941229 follow-up to RAI Re GL 92-08, Thermo-Lag 330-1 Fire Barriers & Rept from Nucon Intl,Inc, Pyrolysis Gas Chromatography Analysis of 5 Thermo-Lag Fire Barrier Samples

ML20086A648
Person / Time
Site:	Wolf Creek
Issue date:	06/27/1995
From:	Hagan R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086A652	List: ML20086A648 ML20086A653
References
ET-95-0061, ET-95-61, GL-92-08, GL-92-8, TAC-M85625, NUDOCS 9507030329
Download: ML20086A648 (8)

Text

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• W$LF CREEK NUCLEAR OPERATING CORPORATION Robert C. Hagan Voe Prendent Engineenng ET 95-0061

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Reference:

1) NRC Letter dated December 29, 1994, " Follow-Up to the Request for Additional Information Regarding Generic Letter 92-08, Issued Pursuant to 10 CFR 50.54 (f) ,

Wolf Creek Generating Station (TAC NO. M85625)."

2) Letter WM 95-0057 dated March 29, 1995, from.

N. S. Carns, WCNOC, to the NRC.

Subject:

Docket No. 50-482: Supplemental Response to the Follow-Up to the Request for Additional Information Regarding Generic Letter 92-08 Gentlemen:

Reference 1 required a response to be submitted to the NRC, under the requirements of 10 CFR 50.54 (f) , within 90 days of receipt of the letter.  ;

Reference 1 indicated an increased level of concern within the NRC with the reliability of information and data supplied by Thermal Science, Inc., that Wolf Creek Nuclear Operating Corporation (WCNOC) may -have relied on to validate the acceptability of Thermo-Lag 330-1 as a fire barrier material at Wolf Creek Generating. Station (WCGS), Consequently, the NRC requested WCNOC to provide additional information regarding Wolf Creek Thermo-Lag 330-1 e installations. Specifically, WCNOC was requested to provide the information previously requested in Section II of the NRC letter of December 22, 1993, l

" Request For Additional Information Regarding Generic Letter 92-08 (TAC No.

M85625)," after verifying the information through the use of detailed examinations, such as destructive examinations. Reference 1 also requested additional information concerning material chemical composition, test and analysis methods to be used, fire endurance / performance capabilities, and various mechanical properties associated with seismic capabilities.

WCNOC provided a preliminary response to Reference 1 on March 29, 1995 (Reference 2), in which WCNOC stated we would provide a supplemental response by June 27, 1995. A complete response could not be provided at that time since the results of the NEI chemical composition testing were not available.

Additional information has since become available, and the attachment provides WCNOC's response to the information requested in Reference 1.

I l-9507030329 950627 PDR ADOCK 05000482 P PDR l P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 3 i An Equal opportunny Ernployer MWHCNET [ f l

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ET 95-0061 ,

Page 2 of 2 If you have any questions concerning this matter, please ontact me at (316) 364-8831, extension 4553, or Mr. Richard D. Flannigan at extension 4500 i i

Very truly yours, s

Robert C. Hagan i RCH/j ra ,

Attachment Enclosure (NUCON International Chemical Test Report for Wolf Creek)'

cc: L. J. Callan (NRC) , w/a, w/e D. F. Kirsch (NRC) , w/a, w/e J. F. Ringwald (NRC), w/a, w/e  :

J. C. Stone (NRC), w/a, w/e 6

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STATE OF KANSAS ) l

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- COUNTY OF COFFEY )

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Robert C. Hagan, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation;. '

that he has read the foregoing document and knows the content thereof; that '

- he has executed that same for and on behalf of' said Corporation with full.

power and authority to do so; and that the' facts therein stated are true and ,

correct to the best of his knowledge, information and belief.

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,Wy Appt. Empires 9 98 Robp C C.~Hagan <

Vice President -l Engineering  ;

SUBSCRIBED and sworn to before me this day of M , 1995.

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Attachmtnt to ET 95-0061 Page 1 of 5 I

SUPPLEMENTAL RESPONSE TO THE FOLLOW-UP TO THE REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 92-08, I

THERMO-LAG 330-1 FIRE BARRIERS PURSUANT TO 10 CFR 50.54(F) i

.1. Thermo-Lag Natorials Question la.

Describe the specific tests and analyses that will be performed to verify l that the Thermo-Lag fire barrier materials that are currently installed at Wolf Creek Nuclear Generating 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 Thermal Science, Inc., (TSI) during the manufacturing process and the quality assurance program. The tests and i 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 l

(5) fire endurance capabilities  ;

(6) combustibility (7) flame spread rating (8) ampacity derating (9) mechanical properties such as tensile strength, compressive strength, sheer strength, and flexural strength.

Response

With respect to Item 1.a.(1) above, WCNOC is participating in an industry-wide effort to evaluate chemical composition as a means of addressing product consistency on a generic basis. WCNOC subtaitted five samples of Thermo-Lag 330-1 to NUCON International, Inc., for pyrolysis gas chromatography (PGC) testing in accordance with the guidance of ASTM D3452 This testing is part of the industry-wide testing _ program requested by NEI in their letter to ,

Licensee Administrative Points Of Contact dated February 3, 1995. The five WCNOC samplen were taken from a one-hour pre-formed conduit section and pre-formed panel, a three-hour pre-formed conduit section and pre-formed panel, l and from installed trowel-grade material. Prior to this, WCNOC had also submitted 152 sections of pre-formed conduit sections to NEI as part of the NEI Phase I Generic Test Program.

NEI has indicated that they will provide to t.he NRC information on product consistency, based on the results of the generic chemical composition  !

testing. The results of the Pyrolysic Gas Chomatography testing for organic materials on the five WCNOC samples indicate that the WCNOC samples are consistent, in terms of chemical composition, to the baseline results tested by NEI.

Attachment to ET 95-0061 Page 2 of 5 Inorganic testing will be completed in July, 1995, through the industry test program. A total of 18 samples will be tested. Seven of the samples will be taken from the material used in the NEI fire test program. The test results from these samples will provide baseline data to compare with the remaining l eleven samples. The remaining eleven samples will be selected from a l population of approximately 160 samples provided to NUCON by the Licensees. l WCNOC does not intend to perform any additional chemical testing at this '

time, pending evaluation of the results of the industry-wide test program currently in progress.

With respect to Item 1.a . (2) , WCNOC completed Quality Receiving Reports for original Thermo-Lag materials received on-site. These reports verify that the dimensions of the materials were inspected and found to be within the range specified by TSI.

With respect to Item 1.a . (3) and 1.a . (4) , WCNOC has obtained the important barrier parametters (24 parameters specified in Reference 3) to ensure that the Thermo-Lag installed at WCGS is bounded by industry testing. No substantial voids, cracks, or delaminations that would adversely affect barrier performance were identified during walkdowns for the 24 important barrier parameters and inspections of disassembled boxed assemblies.

With respect to Items 1.a.(5), 1. a . ( 6 ) , 1.a. (7) , and 1.a.(8) above, WCNOC has received the organic chemical test results from the NEI generic test program.

WCNOC's results conclude that the Thermo-Lag materials used at WCNOC are consistent with the material used in the NEI fire endurance tests and combustibility tests. NEI will perform inorganic chemical testing in July, 1995, on 18 samples. Seven of those samples will be taken from the material used in the NEI fire tests and will be chemically tested as a baseline.

Eleven samples will be selected from the population of samples provided to NUCON for the industry chemical test program. WCNOC will review the results of this testing for application to installed Thermo-Lag.

With respect to Item 1.a . (9) , NEI discussed shaker-table testing of cable raceway barrier installations in their letter to Licensee Administrative Points of Contact dated January 17, 1995. In that letter, NEI indicated that this testing was performed with acceptable results. Based on the results of the organic chemical test, performed on WCNOC Therme Tag, it can be concluded that the results of the shaker table test are applicable to WCNOC Thermo-Lag installations. WCNOC concurs with the NEI position that, if additional testing is required, it should be performed generically.

Question 1b.

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

Attachment to ET 95-0061 Page 3 of 5

Response

As noted in response to Item 1.a. (1) above, WCNOC submitted 5 samples of Thermo-Lag to Nucon International, Inc., as part of cn industry-wide testing program sponsored by NEI. NEI requested each licetaec to submit several samples from each plant. The Wolf Creek samples were taken from a one-hour pre-formed conduit panel, a three-hour pre-formed conduit panel, a one-hour pre-formed wall panel, a three-hour pre-formed wall pane.1, and a sample of installed trowel-grade material; one sample from each of the five types of Thermo-Lag 330-1 applications installed at Wolf Creek. Based on conversations with both NEI and personnel from other licensees, WCNOC believes this number of samples will be sufficient to assess the total population of in-plant fire barriers, given the relatively small amount of Thermo-Lag 330-1 installed at Wolf Creek. Based on communication with NEI, WCNOC anticipates that this testing will confirm reasonable assurance of Thermo-Lag material consistency at WCNOC and the industry. Chemical testing to ensure product consistency will be considered for any future Thermo-Lag 330-1 material obtained for upgrade or replacement of existing Thermo-Lag.

However, at this time WCNOC does not intend to perform any additional chemical testing.

Question ic.

Submit the schedule for verifying the Thermo-Lag materials.

Response

As indicated in the above responses, WCNOC is participating in an industry-wide effort to evaluate chemical composition of Thermo-Lag 330-1 as a means of addressing product consistency. As noted in Reference 1, NEI will provide to the NRC and the industry information on product consistency, based on the results of the chemical composition testing. It is NEI's position that the chemical composition data will provide Liceasees with the basis to independently confirm applicability of generic industry test data with respect to several attributes, including fire endurance capability, combustibility, flame spread, heat release and ampacity derating (assuming resolution of current questions on ampacity derating test methodologies). If the NRC agrees with the NEI position, then the schedule outlined in Reference 2 is still valid. If the chemical test data is not consistent, or if the Imc does not agree with the NEI position, then WCNOC's schedule may need to be revised.

Question 1d.

After the analyses and tests have been completed, submit a written l 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

As indicated in Reference 1, NEI will submit a detailed report to the NRC and Licensees providing the results of the generic testing and analysis following

Attachmant to ET 95-0061

.Page 4 of 5

. completion of the testing program. At the present time only organic material I testing has been completed. Enclosed with this letter is the report from NUCON International, Inc., " Pyrolysis. Gas Chromatography Analysis of 5  !

Thermo-Lag Fire Barrier Samples," which provides the'results of this testing. l Testing for inorganic material is~ scheduled by NEI to be completed in July, l 1995. The results of this testing will be submitted to the NRC by NEI. If additional analyses and testing are required, or if the issues outlined above i are not resolved by industry testing, WCNOC will submit a revised schedule or )

plans deemed necessary to resolve the Thermo-Lag issue at WCGS.  !

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2. Important Barrier Parameters  !

Question 2a.

Describe the examinations and inspections that will be performed to obtain-  ;

the important barrier parameters given in Section II of the RAI of l December 1993 for the Thermo-Lag fire barrier configurations installed at Wolf Creek Generating Station.

l Response  !

1 WCNOC has obtained and verified the 24 parameters listed in the Request for  :

Additional Information (RAI) for WCGS BTP CMEB 9.5-1 applications (Reference 3). This information was-obtained and/or verified through the use of general walkdowns, design drawing reviews, and review of Quality Assurance (QA) {

records of the applications. WCNOC has also performed NEI Application Guide i evaluations, comparing as-installed configurations with the tested assembly [

configurations, and is currently reviewing the results, i i

Question 2b. I i

Describe the methodology that will be a, plied 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 r ensure that the information and data that will be obtained are adequate to v ascess 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 i parameters used to construct the in-plant barriers and any future barrier j installations or modifications, are representative of the barriers used to {

construct the fire endurance test specimens.

Response

WCNOC performed a detailed examination of the entire population of Thermo-Lag l applications at WCGS required to comply with BTP CMEB 9.5-1. Therefore, the j requested statistical analysis to determine the sample size is not required ,

at WCGS. l i

Question 2c. [

Submit the schedule for obtaining and verifying all of the important ,

barrier parameters. ,

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Attachment to ET 95-0061 Page 5 of 5

Response

Important barrier parameters have been obtained and NEI Application Guide evaluations are being verified in accordance with the schedule outlined in Reference 2. However, some additional issues may arise as a result of the industry effort to evaluate chemical composition as a means to address product consistency. As noted in Reference 1, NEI will provide to the NRC and the industry information on product consistency, based on the results of i the chemical composition testing. With the assumption that the chemical composition testing results are consistent, and if the NRC agrees with the NEI position that the industry data can be used as a basis for using generic j test data with respect to Items 1.a. (2) through 1. a . ( 9) , then the schedule outlined in Reference 2 is still valid. If, however, the chemical test data I is not consistent, or if the NRC does not agree with the NEI position, then l our schedule may need to be revised. l Question 2d.

After the information has been obtained and verified, submit a 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.

Response

WCNOC is currently reviewing the NEI Application Guide evaluation report. A report reflecting WCNOC's as-built configurations will be submitted in accordance with WCNOC's schedule for resolution of the Thermo-Lag issue submitted in Reference 2, unless additional examinations and inspections are required, or if the issues outlined above are not resolved by industry testing. The schedule for resolution of the Thermo-Lag issue at Wolf Creek submitted in Reference 2 has not been changed at the present time. Should issues result from industry testing, or should additional examinations be required, WCNOC will submit a revised schedule.

LIST OF REFERENCES

1) NEI Letter dated February 21, 1995 to W. T. Russell, NRR, from W. H. Rasin, NEI

2) Letter CO 94 0013, dated July 15, 1994, from R. N. Johannes, WCNOC, to the NRC

3) Letter WO 94-0013, dated February 9, 1994, from O. L. Maynard, WCNOC, to the NRC f

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