ML20087E270
| ML20087E270 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/08/1995 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, TAC-M85536, TAC-M85537, NUDOCS 9508140101 | |
| Download: ML20087E270 (13) | |
Text
m i
m Log # TXX 95136
==
File # 10010 909.5 9
3 Ref. # GL 92 08 August 8, 1995 C. Lance Terry Groep Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Room Washington D.C. 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
UNIT 1 DOCKET NO. 50 445 RESPONSE.T0 REQUEST FOR ADDITIONAL INFORMATION FOLLOW UP TO GENERIC LETTER 92 08 (TAC NOS. M85536 AND 85537)
REF: 1) NRC Letter dated December 20, 1994, from Mr. Roy P. Zimmerman to Mr. C. Lance Terry
- 2) TV Electric Letter logged TXX 95004 dated February 24, 1995.
from Mr. C. Lance Terry to NRC
- 3) NRC Letter dated May 17, 1995, from Mr. Timothy J. Polich to Mr. C. Lance Terry
Mr. C. Lance Terry to NRC Gentlemen:
Reference 1 requested that Texas Utilities Electric Company (TV Electric) provide additional information regarding Thermo Lag fire barrier material received and installed at CPSES.
In Reference 2. TV Electric responded to that request.
During a teleconference on April 20, 1995, the NRC Staff orally requested l
additional information regarding Reference 2, and in a letter dated May 17.-
t 1995 (Reference 3). NRC requested further information in writing.
i provides TV Electric's response to.the Staff's oral questions,-
t and Attachment 2 provides TV Electric's response to the Staff's'. written
-questions.
In several cases, it was only necessary to identify where TV Electric previously responded to essentially the.same NRC question and the NRC previously accepted TV Electric's response. Moreover, in a conference-call with the NRC staff on July 6,1995, the NRC expanded the scope of the i
subject request for additional _ information, beyond TU Electric's understanding of. the written request for information and the earlier conference call. TV Electric requested (Reference 4) and was verbally granted an additional 35 days to respond to the new information requested i
by the NRC.
950814o1o3 950 sos '
DR -ADOCK 05000445 p
PDR l
j P. O. Box 1002 Glen Rose, Texas 76043
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l TXX-95136 Page 2 of 2 To summarize the status of the Thermo-Lag fire barrier material received and installed at CPSES Units 1 and 2. TU Electric has applied the same quality assurance (0A) program to the procurement, receipt, and installation of Thermo Lag for Units 1 and 2. and has performed numerous tests to qualify the Thermo-Lag configurations at CPSES.
Based upon the level of quality assurance placed on Thermo Lag under TU Electric QA program and tests. TV Electric's previous submittals have demonstrated that the Thermo Lag received and installed at CPSES is able to perform its fire protection function and is in conformance with the CPSES licensing basis.
Furthermore, in Inspection Report 50 445/93 08 and in Supplemental Safety Evaluation Reports (SSERs) 26 and 27 for CPSES (NUREG 0797), the NRC concluded that TV Electric's OA program as applied to Thermo Lag is strong and that the installed Thermo Lag fire barriers in CPSES Unit 2 are acceptable. Additionally, with respect to the issues discussed in this and the referenced letters. TV Electric believes that Thermo-Lag installed in CPSES Units 1 and 2 is in compliance with NRC requirements and will perform as required. Therefore. TV Electric does not feel that the compensatory measures taken to achieve compliance with Generic Letter 92-08 are applicable to CPSES Units 1 and 2.
If you have any questions regarding the information in the attachments, please contact Roger Walker at (817) 897-8233 or Obaid Bhatty at (817) 897 5839.
Si c -
y.
C. L. Te ry 08/ob 6
Attachments Enclosures c
Mr. L. J. Callan. Region IV Mr. D. F. Kirsch, Region IV Mr. K. S. West. NRR Mr. T. J. Polich NRR Mr. W. H. Rasin. NEI Resident Inspectors
Attachment I to TXX 95136 Page 1 of 7 RESPONSE TO CLARIFICATIONS REQUESTED DURING APRIL 20, 1995. TELECONFERENCE During a teleconference with the NRC staff, on April 20, 1995. TU Electric agreed to provide clarifications to reference 2 to facilitate the NRC staff's review associated with the installed CPSES Unit 1 Thermo Lag materials.
Via this letter TV Electric is providing these clarifications.
Reference 2 is enclosed to expedite your review. The NRC staff's inquiries, as we understand them, and our clarifications are provided below.
NRC Ouestion (1)
TXX 95004 provided by TV Electric to respond to the 50.54(f) letter (reference 1) does not distinguish between Unit 1 and Unit 2.
What were the controls for procurement, receipt and installation for CPSES Unit I?
TU Electric Resoonse TV Electric letter TXX 95004 did not distinguish between CPSES Unit 1 and Unit 2 because TV Electric applied the same quality assurance controls to Unit 1 and Unit 2.
In particular. TV Electric applied quality assurance controls for procurement, receipt and installation of Thermo-lag fire barriers for CPSES Unit 1.
These controls covered the attributes specified in reference 1.
These controls were applied for the licensed CPSES Unit 1 Thermo lag installation (1989-1991), and the later upgrades in the 1993-1994 design modification of the fire barriers. These aforementioned attributes are described in table 1 and table 2 of reference 2, and are applicable to both CPSES Units.
NRC has asked whether prefabricated Thermo-Lag materials installed in Unit I have delaminations and voids similar to those reported by TV Electric during the installation of Thermo-Lag in Unit 2.
During installation of Thermo-Lag barriers in Unit 2, some instances of delaminations and unfilled voids were detected for some y inch thick (nominal) prefabricated conduit section material.
These conditions were detected during site construction j
(i.e., saw cutting) and handling of conduit sections during installation.
TV Electric letter TXX-92589 dated December 15, 1992, describes the comprehensive measures taken by TV Electric to determine the extent, root cause and corrective and preventive actions for ensuring that conduit section materials installed in Unit 2 were acceptable for use and consistent with materials qualified during TU Electric's fire endurance test program.
TV Electric concluded that significant incidence of the delamination condition was limited to 4 inch thick (nominal) prefabricated conduit sections.
The review also concluded that this condition was more prevalent within two specific lots of the y inch (nominal) prefabricated sections.
These two lots were comprised entirely of material for use on 3-inch diameter conduits. The pieces that exhibited the subject condition
! to TXX 95136 Page 2 of 7 were either scrapped or repaired as specified by CPSES specif! cations and procedures. Additionally TU Electric identified that some of the conduit section materials actually tested by TU Electric on 3-inch diameter conduit were from the same two material lots demonstrating the highest incidence of the subject condition. The results of these tests were satisfactory, and an inspection of the conduit assemblies following these tests determined that significant quantities of unconsumed Thermo Lag material remained on 3 inch diameter and larger conduits. Thus, the existence of the delaminttions and voids as were identified at CPSES did not adversely impact the ability of the affected Thermo Lag to perform its fire barrier function. As described in SSER 26, the NRC staff determined that TU Electric's actions with respect to the voids and delaminations were adequate, and that Thermo-Lag conduit barriers installed in Unit 2 are acceptable.
The same site construction and handlin9 techniques and in process quality i
verification attributes that were used) an Unit 2 (and identified the delaminations and voids discussed above) were employed for the installation j
of conduit barriers in Unit 1.
No instances of delaminations and unfilled voids were identified on Unit 1.
Furthermore, the lots with the highest incidence of voids and delaminations were not used in Unit 1.
Therefore, delaminations and unfilled vofds in conduit sections are not an issue for currently installed Unit 1 barriers.
Furthermore, even if similar conditions were postulated to exist for Unit 1 conduit barriers. TXX 92589 and SSER 26 both conclude that such delaminations and voids would not lead to the failure of these qualified fire barrier configurations.
Therefore, further verification activities for these conditions for installed Unit 1 Thermo-Lag barrier configurations are not necessary.
NRC has also asked whether the samples of CPSES Thermo Lag material i
provided in support of the initial (1993) Nuclear Energy Institute (NEI) pyrolysis gas chromatography testing are sufficient to represent the chemical composition of the entire population of Thermo-Lag barriers installed at CPSES. Two samples (1 panel and 1 conduit section specimen) from TV Electric were selected and utilized by NEI, along with samples from Entergy Operations, Inc., Houston Lighting and Power Co. and Thermal Science. Incorporated (TSI) for performance of chemical testing. The results of the pyrolysis gas chromatography testing performed by NEI revealed no appreciable chemical differences between materials supplied by TU Electric and others.
It should be emphasized that TU Electric is not relying solely on these chemical testing activities by NEI to demonstrate consistency in the chemical composition of Thermo-Lag materials installed at CPSES. As described in reference 2, TU Electric has applied its CA program to the procurement and receipt of Thermo-Lag for CPSES Units 1 and 2, which included shop (at TSI) surveillances performed by TU Electric to verify the acceptability of the in process manufacturing of Thermo Lag.
Wre importantly, the results of TU Electric's extensive independent full-
- a. ale fire endurance test program, which utilized only material from CPSES stock inventory, demonstrated that Thermo-Lag barriers as installed at CPSES are capable of performing their design function: therefore, even if inconsistencies in the organic or inorganic chemical constituents of Thermo-Lag material were postulated, the numerous fire endurance tests
l to TXX 95136 Page 3 of 7 j
performed by TV Electric provide adequate confidence that such differences have no effect on the performance capability of Thermo Lag barrier systems installed in CPSES Units 1 and 2.
Additionally, the results of these tests did not identify any significant differences in the performance of the Thermo Lag material itself (i.e., the numerous pieces of Thermo-Lag material exhibited consistent performance, and test failures were attributed to factors related to configuration rather than material performance).
The CPSES tests of Thermo lag material provide adequate confidence that there are no substantive material differences in the chemical composition of the Thermo-Lag barriers installed at CPSES.
Consequently, further verification to demonstrate consistency in the chemical formulation of Thermo-Lag barrier materials installed at CPSES is 1
not warranted.
Even though TU Electric does not believe that there is a technical or regulatory bases for requiring any further chemical sampling to support the acceptability of the Thermo-Lag installed at CPSES Units 1 and 2 as qualified fire barriers TU Electric has, in response to suggestions from the NRC and to support the industry in its response to this aspect of the qualification of Thermo Lag, decided to participate in the NEI test program to assess the chemical formulation of Thermo-Lag.
In this respect TU Electric has provided an additional 10 samples to NUCON Lab, which is endorsed by NEI to perform the chemical analysis. Additionally, TV Electric performed its owr tests, under the auspices of its Quality Control program using Infrared Spectroscopy method. Ten samples of Thermo J
Lag material were analyzed using Fourier Transform Infrared spectroscopy (FTIR). These samples were obtained from various locations of the plant.
Based on FTIR testing, the samples are the same basic product formulation.
l NRC Ouestian (2)
TV Electric's response (reference 2) does not specify the extent of TU Electric's use of data provided by Thermal Science, Inc.(TSI) to support its seismic analysis.
TV Electric Resoonse As discussed in the Final Safety Analysis Report (FSAR) Table 17A 1 and TV Electric letter logged TXX 92626 dated December 22, 1992 (Enclosure S4.5.2), Thermo-Lag used for cable and raceway fire barrier and structural steel fireproofing is classified in TV Electric's design bases document DBD ME-028 es non-seismic (Seismic Category None). However, since fire barrier and fireproofing materials are installed in areas containing safety-related equipment they must meet the requirements of Regulatory Guide 1.29.
Specifically, failure of Thermo-Lag fire barrier systems and fireproofing materials during or after the design basis earthquake cannot reduce the functional capability of structures, systems, or components j
required to safely shut the plant down.
]
The CPSCS Seismic /Non-Seismic Systems Interaction Program (DBD-ME-005) has addresseo the requirements of Regulatory Guide 1.29 for the design and ope, ation of both Unit 1 and Unit 2.
In this program. Thermo Lag is not
i to TXX-95136 l
Page 4 of 7 considered to be a potentially damaging source. Gross failure / falling of the material under CPSES design basis, seismic inertial loading is not credible.
This position is supported by the following:
i Thermo Lag panels and sections are secured in place with extensive use of mechanical-fasteners, staples, additional stress skin, and steel bands.
The fasteners assure that the material is positively attached to the electrical raceway which has been seismically qualified for the i
added weight:
Earthquake studies do not indicate pross failure and falling of fire barrier materials due to seismic inertia when the material is adequately attached to'the supporting structure: and
\\
Local cracking / chipping of Thermo Lag materials used for raceway fire l
barrier and structural steel fireproofing applications may occur during i
a seismic event.
However, the resulting debris would be relatively i
light, and impact of the debris on Seismic Category 1 components would -
not adversely affect the ability of such components to perform their safety functions.
l Thus, TU Electric does not rely upon TSI data to support its conclusions that failure of Thermo-Lag will not adversely affect Seismic Category 1 structures, systems and components.
In SSER 26. the NRC accepted TV Electric's program for addressing seismic concerns for Thermo Lag materials installed at CPSES, finding that the failure of Thermo Lag will not have damaging effects on Seismic Category 1 plant features, and specifically accepted the validity of the seismic designs of the raceway at CPSES Unit 2 that include Thermo Lag as a fire barrier.
Since the same program for addressing seismic concerns (including the acceptability of the raceway and.
the impact on Seismic Category 1 features) was used on Unit 1, further verification of mechanical properties of Thermo lag is not warranted.
Thermo-Lag weights were considered in the hardware validation programs for i
electrical raceways at CPSES. The values for these weights are determined independent of TSI's input.
Based on results of these validation provams, there is adequate confidence that in the maximum postulated i
seismic event in the FSAR for-the plant. the Thermo Lag material attached to the raceways will not result in a failure of the raceways or adversely i
impact safety related components.
NRC Ouestion l
(3)
NRC recently performed an ASTM E84 flame spread rating test at National Institute for Standards and Technology which indicates that Thermo-Lag has a flame spread rating of approximately 30.
The NRC staff therefore believes that the flame spread rating that TU Electric provided during the licensing process for Unit 2 (a flame spread rating of approximately 5) may be nonconservative.
i l
i h
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1 to TXX 95136 Page 5 of 7 TU Electric Resoonse i
As stated in reference 2 (Attachment 4, pg.3). TV Electric does not use Thermo Lag to enclose intervening combustibles to achieve 20 feet i
separation, free of intervening combustibles, between safe shutdown trains.
i Additionally, TU Electric does not use Thermo Lag as a radiant energy shield inside containment.
Since the flame spread rating of Thermo Lag is I
relevant only to its use in these two applications, the flame spread rating i
of Thermo Lag is not an issue with respect to the Thermo Lag installations for Comanche Peak Steam Electric Stations Units 1 and 2.
Flame spread ratings previously provided by TU Electric were background information for the tests that had been performed for the material, and were not intended to imply that the reported rating was being credited by TV Electric for separation of fire safe shutdown raceways.
Additionally, NRC has raised questions re; rding the adequacy of the installation of Thermo-Lag at CPSES Unit 1, based upon the discovery of certain nonconformances in the Unit 2 installations. There is adequate confidence in the acceptability of the installation of Thermo Lag at CPSES Unit 1 based upon the following:
As discussed in reference 2. TU Electric applied its quality assurance program to the installation of Thermo Lag at CPSES. The NRC has inspected both the quality assurance program and the installation and has concluded that they are both acceptable.
2 In 1994, TV Electric discovered 752 visual anomalies that were suspect nonconformances in Thermo-Lag that had previously been installed and inspected in CPSES Unit 2.
This discovery was made as a consequence of evaluating Unit 2 installations by personnel involved in Unit l's Thermo Lag upgrade program. The conditions discovered were anomalous to as left Unit 2 conditions and were not wide spread. These anomalous conditions would therefore not be expected to be found in the Unit 1 installations.
Furthermore, for several reasons (as summarized below), these anomalies would not cast doubt upon the acceptability of the Thermo Lag installed at CPSES.
The actual nonconformances were relatively small in number and affected only 7% Thermo Lag installed in CPSES Unit 2.
The nonconformances were minor in nature.
For example they included:
I Please note that these subjects were previously reviceed by the NRC, as documented in NRC inspection reports:
(1) 50 445/93 08: 50 446/93 08 (11) 50 445/93 34: 50 446/93 34 (iii) 50 445/93 42; 50 446/93 42 (iv) 50 445/94 21; 50 446/94 21 i
t i to TXX 95136 Page 6 of 7 localized discontinuities in trowel grade material used to seal raceway envelopes 'against building structural surfaces,.
and localized. discontinuities in coverage installed on various l
protruding items such as supports, nonessential conduits.
etc.
The nonconformances were subject to TU Electric's corrective action program. 'Most of the nonconformances were dispositioned as Use As Is: the remaining 62 nonconformances were dispositioned as rework / repair:
245 "Not A Nonconforming Condition" Dispositions 32%
445 "Use-As Is" Dispositions 60%
57
" Repair" Dispositions 7%
5
" Rework" Dispositions 1%
752~ Total Conditions Dispositioned 100%
The root causes of those conditions specified for repair / rework' l
are' attributed to:
minor workmanship issues (approximately 87 percent).
incidental damage (approximately 13 percent)
Field assessment by engineering determined that a significant portion of workmanship related issues occurred in congested or difficult to access areas where high quality craftsmanship would be more difficult and consequently more difficult to inspect.
With respect to Unit 2, corrective action has been taken for these nonconformances, and the installed Thermo Lag is currently acceptable.
The 62 nonconformance were dispositioned as rework / repair as a matter of convenience and conservatism. TU Electric has evaluated these nonconformances and has determined that each could have been dispositioned as acce) table as is. Therefore, none of the nonconformance would lave adversely affected the fire protection function of the Thermo Lag if it had been left uncorrected.
3
1 l to TXX-95136 Page 7 of 7 In summary, only a small percent of the Thermo Lag in Unit 2 had nonconforming conditions, the nonconformances were minor, and none of the non conformances would have adversely affected the ability of the Thermo-Lag in Unit 2 to perform its safety function.
In light of the above, the nonconformances identified in the Thermo Lag in CPSES Unit 2 in 1994 do not cast doubt on the acceptability of the Thermo Lag in Unit 1.
Even if it were postulated that similar nonconformances existed in the Unit 1 Thermo-Lag, that Thermo-Lag would still be able to perform its fire protection function. As a result, additional verification of Thermo Lag installations at CPSES is not warranted.
. to TXX-95136 Page 1 of-4 RESPONSES TO NRC RAI DATED MAY 17. 1995 Responses specific to the NRC RAI dated May 17., 1995, are provided below.
The questions from the aforementioned RAI are repeated for clarity.
SECTION 1 NRC Question "The staff previously accepted the fire endurance information for CPSES Unit 2 in NUREG 0797, Supplements 26 and 27. The fire endurance information submitted by TU Electric unique to CPSES Unit 1 is still under review by the staff.
The staff also concludes that the information regarding the presence of voids, cracks and delaminations for CPSES Unit 2 is acceptable, however, additional information is requested for Unit 1.
The licensee should submit the methodology and schedule for verifying the Thermo-Lag materials at CPSES."
TV Electric Response As stated in Attachment 1 (see response to NRC Question 1) to this letter, the same site construction and handling techniques and in process quality verification attributes were employed for installation of conduit barriers in Unit 1. and no instances of delaminations and unfilled voids were identified.
Therefore, delaminations and unfilled voids in conduit sections are not an issue for currently installed Unit 1 barriers.
Furthermore, even if similar conditions were postulated to exist for Unit 1 conduit barriers. TXX-92589 and SSER 26 conclude that such delaminations
(
and voids would not lead to the failure of qualified fire barrier configurations.
Therefore, further verification activities for these conditions for installed Unit 1 Thermo Lag barrier configurations are not necessary.
NRC Question "The results of the NEI chemical testing program were transmitted to the NRC on February 8, 1994. This program tested 12 samples from industry.
TU Electric provided two of the 12 samples. The NEI testing protocol only evaluated organic components of Thermo Lag.
Inorganic components, which may be important to performance as a fire barrier, were not evaluated.
Please provide additional information that demonstrates that two samples are adequate to represent the entire population of Thermo-Lag installed at CPSES."
TV Electric Response As stated in reference 2 (Attachment 4, Pg.1), two samples (1 panel and 1
)
conduit section specimen) were selected and utilized by NEI, along with I
samples from Entergy Operations, Inc.. Houston Lighting and Power Co. and
)
TSI for performance of chemical te. ting. The results of the pyrolysis gas chromatography testing performed by NEI revealed no appreciable chemical to TXX-95136 Page 2 of 4 differences between materials supplied by TV Electric and others.
It should be emphasized that TU Electric is not relying solely on these l
chemical testing activities by NEI to demonstrate consistency in the chemical composition of Thermo-Lag materials installed at CPSES. As described in reference 2. TV Electric has applied its OA program (the program used on Unit 1 is the same program that was used on Unit 2) to procurement and receipt of Thermo Lag, which included shop (at TSI) surveillances performed by TV Electric Quality Control Inspectors to verify the acceptability of the in-process manufacturing of Thermo-Lag.
More importantly, the results of TU Electric's extensive independent full scale fire endurance test program, which utilized only material from CPSES stock inventory, demonstrated that Thermo-Lag barriers as installed at CPSES are capable of performing their design function, Therefore, even if inconsistencies in the organic or inorganic chemical constituents of Thermo-Lag material were postulated, the numerous fire endurance tests performed by TV Electric provide adequate confidence that such differences have no effect on the performance capability of Thermo-Lag barrier systems installed at CPSES.
Additionally, the results of these tests did not identify any significant differences in the performance of the Thermo Lag-material itself (i.e., the numerous pieces of Thermo-Lag material exhibited consistent performance, and test failures were attributed to factors related to configuration rather than material performance). The CPSES tests of Thermo lag material provide adequate confidence that there are no substantive material differences in the chemical composition of the Thermo-Lag barriers installed at CPSES.
Consequently, further verification to demonstrate consistency in the chemical formulation of Thermo Lag barrier materials installed at CPSES is not warranted. As noted in, at the suggestion of the NRC staff and to assist the industry TU Electric has decided to participate in the testing program on the chemical content of Thermo-Lag being conducted by NEI.
NRC Ouestion "In the RAI [Ref. 1], the staff stated its concerns about the reliability of information and data supplied by TSI and that conclusions based on the vendors information were being re evaluated.
In addition, mechanical property information for Thermo-Lag provided by the Tennessee Valley Authority conflicts with the information provided by TSI.
Therefore, additional verification of the mechanical properties of Thermo Lag installed at CPSES is requested."
TU Electric Response As discussed in detail in Attachment 1 (Response to NRC Question 2). TU Electric does not rely upon TSI data to support its conclusions that failure of Thermo-Lag will not adversely affect Seismic Category 1 structures, systems and components.
In SSER 26, the NRC accepted TU Electric's program for addressing seismic concerns for Thermo-Lag materials installed at CPSES. finding that failure of Thermo-Lag will not have damaging effects on Seismic Category 1 plant features.
Thermo-Lag weights were considered in the hardware validation programs for
. _ - _ - to TXX 95136 Page 3 of 4 electrical raceways at CPSES. The values for these weights are determined independent of TSI's input.
Based on results of the seismic validation program, there is adequate confidence that in a maximum postulated seismic event at the plant, the Thermo Lag Material attached to the raceways will not result in a failure of the electrical raceways or in any nearby safety related equipment. Therefore, verification of mechanical properties of Thermo-lag is not warranted.
NRC Question "In its submittal of February 24, 1P95, the licensee stated that a "similar position" applies for Unit 1. The licensee's response concerning combustibility for Unit 2 is acceptable, provided the NEI combustibility methodology was not used.
However, the licensee should submit its methodology for confirming its "similar position" for Unit 1.
The flame spread rating of 5 for Thermo Lag, referenced in the TV Electric submittal, is based on ASTM E 84, tests conducted by Underwriters Laboratories (UL): however, the Thermo Lag configuration tested at UL is not representative of the configurations installed at CPSES.
In the RAI, the staff stated that licensees must have valid information on the specific Thermo Lag materials installed at it's plant. Therefore, the licensee should submit additional information i
concerning the flame spread rating of Thermo Lag installed at CPSES."
TU Electric Response As discussed in reference 2 (Attachment 3. Pg. 2 and Attachment 4. Pg. 3).
TV Electric does not use Thermo Lag to enclose intervening combustibles to achieve 20 feet separations, free of intervening combustibles, between fire i
safe shutdown trains. Additionally, TU Electric does not use Thermo-Lag as a non combustible radiant energy shield inside containment nor to create combustible free zones at CPSES Units 1 and 2.
Since the flame spread rating of Thermo Lag is relevant only to its use in these two applications; the flame spread ratings of Thermo-Lag is not an issue with respect to the Thermo Lag installations for Comanche Peak Steam Electric Stations Units 1 and 2.
Flame spread ratings previously provided by TU Electric were background information for the tests that had been performed for the material, and were not intended to imply that the reported rating was teing credited by TV Electric for separation of fire safe shutdown raceways.
In a conference call with the NRC staff on July 6,1995, the NRC expanded the scope of this question beyond TU Electric's understanding of the written request for information and the earlier conference call.
The NRC staff requested that TV Electric address the combustibility of Thermo Lag and the impact of that combustibility on the Fire Hazards Analysis (in i
particular the combustible loading assumed therein). TU Electric has considered this new request and has decided to respond in a conservative manner.
Although TV Electric continues to consider the Thermo Lag installations to be fully operational, TV Electric will revise the Fire Hazardous Analysis (FHA) in accordance with the methodology of the CPSES Fire Protection Report to incorporate Thermo Lag as a combustible material.
Based on the results of the available test programs, TU Electric will treat to TXX-95136 Page 4 of 4 Thermo Lag in a manner similar to fire retardent plywood and cable jackets (Reference NRC Information Notice 95-27). TU Electric projects that this revision to the FHA will take about two years to complete.
SECTION 2 NRC Question "In the RAI [Ref.1], the staff stated that some of the installation parameters can only be verified by detailed examination such as disassembling a representative sample of installed barriers and that installation records and procedures alone were not sufficient for identifying installati defects.
Inspections of Thermo Lag barriers at CPSES by the licensee is identified 752 potential discrepancies of which 62 required corrective action.
Therefore, additional information concerning the licensee's methodology and schedule for verifying the important barrier parameters is requested."
TU Electric Response As discussed in detail in Reference 2 (Attachments 2 and 4). TU Electric applied the same quality assurance program during the installation of Thermo-Lag at CPSES Units 1 and 2, which verified the important Thermo-Lag installation attributes identified by the NRC. The NRC inspected the quality assurance program as applied to installation of Thermo-Lag at CPSES, and in Inspection Report 50 445/93 08:446/93 08 for CPSES the NRC concluded that "the licensee has an effective in process Thermo Lag installation QA/QC program." Therefore, there is adequate confidence that the installation of Thermo Lag in CPSES Units 1 and 2 is acceptable, and disassembly and additional verification of installed Thermo Lag is not warranted.
As stated in Attachment I to this letter (pages 5 and 6), the nonconformances identified in the Thermo-Lag in CPSES Unit 2 in 1994 do not cast doubt on the acceptability of the Thermo Lag in Unit 1.
Even if it were postulated that similar nonconformances existed in the Unit 1 Thermo-j Lag, that Thermo Lag would still be able to perform its fire protection function. As a result, additional verification of Thermo Lag installations at CPSES is not warranted in order to resolve these nonconformances.
mem-sammes Log # TXX-95004
==
File # 10010 909.5
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Ref. # 10CFR50.54 1UELECTRIC February 24. 1995 C. Lance Terry Group M President U. S. Nuclear Regulatory Commission Document Control Desk Washington. DC 20555
SUBJECT:
COMANCHE PEAT. STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)
FOLLOWUP TO GENERIC LETTER 92-08 (TAC NOS. M85536 AND 85537)
REF:
1)
NRC Letter dated December 20, 1994 from Mr. Roy P.
Zimmerman to Mr. C. Lance Terry Gentlemen:
The information requested by the referenced letter is provided in the attachments of this letter. Attachment 2 to this letter describes the
- ctivities which TU Electric has performed to verify the quality of procured and installed Thermo-Lag and to ensure that Thermo-Lag installed at CPSES is appropriately quali fied. to this letter provides TV Electric's answers to NRC's specific questions.
In this regard. Attachment 4 identifies the manufacturing attributes that TV Electric has verified, and identifies the installation attributes that TV Electric has controlled to ensure that the test configurations bound the as-1nstalled configurations at CPSES.
As demonstrated in the attachments to this letter. TV Electric performed quality verification of purchased and installed Thermo-Lag through l
application of the TV Electric quality assurance (QA) program to the j
procurement and installation of Thermo-Lag.
Additionally. TU Electric i
demonstrated the acceptability of the as-installed Thermo-Lag by performance of numerous full scale fire tests of Thermo-Lag raceway and cable barriers.
These tests were performed by TV Electric. independent of Thermal Science Incorporated (TSI) technical guidance and the TSI quality assurance program.
3 Therefore. TV Electric has verified the type of quality attributes identified in the referenced letter, and this verification provides adequate confidence that cablos enclosed within such barriers installed at CPSES will perform their design function during and following a postulated fire.
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P.O. Box 1002 Glen Rose.Tezu 76043
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1 TXX-95004 Page 2 of 2 TU Electric has previously provided the quality information to the staff to demonstrate the acceptability of installed Thermo-Lag configurations.
Many of the issues identified in reference 1 were previously raised by the NRC.
and were answered by TV Electric.
NRC has accepted TU Electric's answers in the CPSES Safety Evaluation Report. NUREG 0797 Supplements 26 and 27.
Even though Thermo-Lag is not generally classified as safety-related throughout the industry. TV Electric nevertheless invoked and applied its 10 CFR 50 Appendix B. 0A program to the Thermo-Lag procured and installed at CPSES.
This quality assurance program included in-process inspection of the fabrication process, receipt inspections, and a strong installation verification process, as well as extensive testing of the Thermo-Lag configurations as installed at CPSES.
Furthermore. NRC has inspected the application of TU Electric's OA program to the procurement and installation of Thermo-Lag, and has consistently concluded that the program is comprehensive and well implemented.
Therefore, additional tests and analysis are not necessary to verify that the as insti.iled Thermo-Lag Fire Barrier materials at CPSES conform to NRC regulatory requirements.
In summary. TU Electric has verified that the Thermo-Lag material installed at CPSES meets applicable regulatory requirements and our commitments.
TU Electric's accepted procurement and installation 0A program was performed independently of TSI's OA program, and TV Electric's OA program verified those quality attributes necessary to demonstrate the acceptability of the as-installed product.
Should you require additional information, please do not hesitate to contact me or contact Obaid Bhatty at (817)897-5839 to coordinate this effort.
j i
Sincere y.
/
I j
C. L. Ter OB/tg Attachments c-Mr. L. J. Callan. Region IV Mr. D. D. Chamberlain. Region IV Mr. K. S. West. NRR Mr. T. J. Polich. NRR Mr. W. H. Rasin, NEI Resident Inspectors j
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ATTACHMENT 1 TO TXX-95004 AFFIDAVIT i
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.- to TXX-95004 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Texas Utilities Electric Company
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Docket Nos. 50-445
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and 50-446 (Comanche Peak Steam Electric
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Station Unit 1 & 2)
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AFFI0AVIT Charles L. Terry being duly sworn, hereby deposes and says that he is Group V1ce President. Nuclear Production of TU Electric, the licensee herein: that h'e is duly authorized to sign and file with the Nuclear Regulatory Commission this response to followup to the Generic Letter 92-08 and request for additional information pursuant to 10 CFR 50.54(f). for the captioned facility:: that he is familiar with the content thereof; and that the matters set 'arth therein are true and correct to the best of his knowledge, int anation and belief.
'l C. L. Terry Group Vice nt, Nuclear STATE OF TEXAS
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COUNTY OF
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Subscribed and sworn to before me, on this c/Nd day of 1
1995.
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SUSAN C.GRAVATT
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CommissionExpires3-24-97 gAdd--
pgA#eA n%?##1s Notary Public i
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ATTACHMENT 2 TO TXX-95004 i
TU ELECTRIC'S QUALITY ASSURANCE PROGRAM AND TESTING FOR 1
THERMO-LAG j
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-Attachment 2 to TXX-95004 Page 1 of 10' TU ELECTRIC'S OUALITY ASSURANCE
'i PROGRAM AND TESTING FOR THERMO LAG q
1.0 INTRODUCTION
On December 20, 1994,.NRC issued a letter which requested additional information regarding Thermo-Lag procured and installed at Comanche Peak i
Steam Electric Station (CPSES).
The aforementioned letter cpncluded that reliance should not be placed on the quality assurance (0A) program of the manufacturer of Thermo-Lag, Thermal Science. Incorporated (TSI). for the.
purpose of assessing the adequacy of Thermo-Lag materials.
The letter also stated that installed Thermo-Lag must be representative of tested materials and configurations.
The purpose of this attachment is to demonstrate that there is adequate
confidence that the Thermo-Lag material at CPSES conforms with applicable i
requirements. and that the tested configurations for Thermo-Lag are representative of the as-installed configurations at CPSES.
In'particular, as described in each of the sections below TU Electric has applied its own' OA program for design. procurement receipt, installation. and testing of 5
.Thermo-Lag and the results of TU Electric's OA program provide adequate confidence that the as-installed Thermo-Lag at'CPSES is acceptable and will-perform its design function.
2.0 APPLICABILITY OF TU ELECTRIC'S OA PROGRAM Thermo-Lag does not perform a safety-related function.
Table 17A-1 in the Final Safety Analysis Report (FSAR) for CPSES classifies Thermo-Lag at CPSES as non-safety-related. Therefore, the quality assurance _ requirements in i
Appendix B of 10 CFR Part 50 are not applicable to Thermo-Lag.
Nevertheless. TV Electric applied applicable criteria of 10 CFR 50 Appendix-B and ANSI N45.2 to the procurement and installation of-Thermo-Lag i
materials. Additionally TV Electric's procurement documents required TSI i
to establish and implement an Appendix B QA program for the Thermo-Lag supplied for CPSES.
NRC's December 20, 1994. (Reference 1) request for additional informatior states that reliance should not be placed on TSI's OA program. Although, TV Electric specified that TSI'must have an approved QA program, it is not necessary to rely upon TSI's OA program to conclude that the quality of Thermo-Lag accepted and installed at CPSES is acceptable..because TU Electric utilized its own 0A program to verify the quality of Thermo-Lag.
In particular. as discussed below. TU Electric has performed source inspections, surveillances and audits to verify the quality of the Thermo-Lag being manufactured by TSI and supplied to CPSES. Therefore, independent of TSI's OA program, the application of TV Electric's OA program provides adequate confidence that the Thermo-Lag installed'at CPSES will be able to perform its intended function.
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- to TXX-95004 Page 2 of 10 NRC has inspected and reviewed the application of TU Electric's OA program to Thermo-Lag.
Based upon the results of these inspections and reviews. NRC concluded that TU Electric's quality assurance program as applied to Thermo- _
Lag materials is ' strong.2 3.0 DESIGN SPECIFICATIONS l
TV Electric has issued design specifications for Thermo-Lag.
TV Electric Specification 2323-MS-38H " Cable and Raceway Fire Barriers and Structural Steel Fireproofing r defines TV Electric's procurement, source.
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receipt, and installation inspection methodology. including verification l
criteria imposed on this material.
This specification requires that CPSES Quality Control (OC) receipt inspection verify the weight / density (lbs/ftz) of Thermo-Lag panels and preshaped conduit sections.
In addition, this 1
document specifies the minimum weight / density values acceptable for panels and the various sizes of preshaped conduit section sizes.
Specification l
2323-MS-38H also requires CPSES QC receipt inspectors to verify the following:
material thickness; I
no holes or cracks exist in the material wider than 0.05 inches:
no holes or cracks' exist in the material that extend through the i
material to the stress skin-and no signs of visible damage (e.g.. gouges. breaks. tears.
etc.).
4.0 PROCUREMENT INSPECTIONS SURVEILLANCE AND AUDITS I
From the Thermo-Lag material physical' verification information contained in i
Specification 2323-MS-38H. TU Electric Procurement Engineering developed Pre-Engineered Item Data Sheet (PEIDS)3 for'Thermo-Lag fire barrier materials.
This document contains the physical, weight / density, and condition criteria to be followed by CPSES QC personnel performing source inspections.
TV Electric, when purchasing Thermo-Lag fire barrier material. issues a purchase order (P0) to TSI. The P0 specifies the fire barrier materials i
needed.
TV Electric sends a OC representative to TSI's manufacturing facility in St. Louis. Missouri. to perform OC Verification Plan (VP) VP-t I
Refer to TU Electric letter logged TXX 92589 dated December 15. 1992: NRC IR 50-4 5/93-08: 50-u6/93-08: and NUREG-0797 sucplement 25. pg. 9-20.
2 Previously supplied to NRC via TU Electric letter logged TXX 92589 dated December 15. 1992.
3 Previously supplied to W.
'.H TU Electric letter logged TXX-92589 dated Decemeer 15. 1992.
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- to TXX-95004 Page 3 of 10 NES0011-03. " Source Inspection Verification Plan - Thermo-Lag Fire Barrier Materials," prior to shipment. This VP verifies the thickness, weight / linear density, condition of the material, and the material moisture content of the shipment. Once the VP has been satisfied, the TU Electric OC representative authorizes release of the material for shipment.
In addition to source inspections. CPSES personnel also perform audits and surveillances of TSI activities to assure that these activities are being properly performed.
In the past, these audits and surveillances have included reviews of the following attributes:
1.
Products listed in the purchase order shall be identical in formulation to those products previously tested and supplied in accordance with TU Electric Specification 2323-MS-38H. Revision 1.
2.
Prefabricated materials shipped shall be fully cured.
" Fully Cured" is defined as a moisture reading of 70 or less on the 0 to 100 scale of the delmhorst moisture meter model dp or equivalent.
3.
The dry film thickness (DFT) of Thermo-Lag prefabricated shapes are as follows:
330-1 Prefabricated panels:
1/2 in. minimum 330-1 Prefabricated conduit sections:
1/4 in,. and 1/2 in, minimum 330-660 Flex 1-blanket:
1/4 in. minimum (Unless otherwise specified in the PO line item) 4.
The weight per square foot of Thermo-Lag 330-1 prefabricated panels shall be 3.0 lbs/sq-ft minimum and 5.25 lb/sq-ft maximum.
The weights for nominal 4x6.5 foot panels shall be a minimum weight of 78 pounds per panel and a maximum weight of 136.5 pounds per panel.
5.
For 1/2 in. minimum DFT Thermo-Lag 330-1 prefabricated conduit sections (1/2 round. 3 ft. long), the following matrix shall be used for minimum / maximum weights:
Nominal Conduit Dia:
0.75" 1"
1.5" 2"
3" 4"
5" 6"
Max Weight / Piece 4.0 4.5 5.7 6.6 8.9 10.9 13 15 (Lbs/ Sections)
Min Weight / Piece 2.3 2.6 3.3 3.9 5.3 6.6 7.9 9.4 (Lbs/Section)
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, to TXX-95004
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6.
For 1/4 in.. minimum DFT Thermo-Lag 330-1 prefabricated conduit sections (1/2 round. 3 ft. long), the following matrix shall be used
- i for minimum / maximum weights
Nominal Conduit 0.75" 1"
1.5" 2"
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Dia-i Max Weight / Piece 4.0 4.3 5.1 5.9 a
(Lbs/ Sections)
Min Weight / Piece 2.1 2.3 2.6 2.9 i
(Lbs/Section) i 7.
The weight per square foot of Thermo-Lag 330-660 prefabricated I
material is 1.6 lbs/sq-ft minimum and 2.3 lb/sq-ft maximum. unless otherwise specified in the P0 line item.
8.
Prefabricated Thermo-Lag materials shall be free of damage as follows:
A)
No holes or cracks wider than 0.05".
B)
No holes or cracks extending through the material to the stress skin.
l C)
No visible mechanical damage (i.e.. gouges, breaks.' tears, etc.)
9.
Where applicable, materials.(trowel grade) shall be shipped such that.
1 at time of receipt there is not less than six months shelf life remaining.
10.
Thermal Science. Inc. shall notify TU Electric of any changes made in-formulation or fabrication of materials prior to shipment. The notification shall. as a minimum, include:
a)
Technical justification explaining why product end properties were not affected.
^
or b)
Test results or analysis which indicates that the new j
formulation meets or exceeds the requirements of the originally l
supplied product.
l 11.
Verification of in-process activities utilizing TSI procedures (which are reviewed and approved by TU Electric).
12.
Verification of personnel / training.
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, to TXX-95004 Page 5 of !
i 13.
Verification that repairs are in compliance with TSI procedures (which are.. reviewed and approved -by TV. Electric).
t Thus, TU. Electric has performed audits and surveillances of the quality of a comprehensive set of attributes associated with the manufacturing of Thermo-Lag supplied to CPSES.
NRCis request for additional information states that contrary to representations made by TSI to TV Electric. TSI may not have trained its employees to repair-delaminations, cracks, and voids. Although TV Electric did not directly verify that all applicable TSI personnel received the training in question, CPSES personnel did observe that a significant number j
of personnel received TSI training.
As a result of these observations..TU j
Electric determined that TSI personnel were being trained to repair delaminations.. cracks, and voids-and the training was adequate for its-intended purpose.
In any event, TV Electric has previously described the l
measures taken (including its own comprehensive inspections) to resolve concerns pertaining to unfilled longitudinal cracks and delamination detected in some preshaped conduit ection materials during installation in i
s Unit 2.
These measures provide adequate confidence independent of TSI that 1
these concerns do not affect Thermo-Lag material installed or procured at CPSES.
The NRC'also agreed with TV Electric's. resolution of these concerns.
a d
Therefore, even if TSI-did not train all of its employees after voids and delaminations were first detected, this would not affect the qualification of Thermo-Lag materials at CPSES, In summary, TV Electric performed source inspections, surveillances, and audits for the critical characteristics of Thermo-Lag, The results of these inspections, surveillances, and audits provide adequate confidence that the Thermo-Lag material shipped to CPSES conforms to TV Electric's specified requirements.
4 NRC has performed inspections _and reviews of TV Electric's' source inspections, surveillances, and audits for Thermo-Lag.
Based upon the results of these inspections and reviews, NRC concluded that TV Electric's-activities pertaining to the procurement and quality assurance of Thermo-Lag materials are strong..'
5.0 RECEIPT INSPECTIONS Upon receipt of TSI shipments at CPSES. TV Electric'0C performs verification Plan VP-NE50011. " Receipt Inspection Verification Plan - Thermo-Lag Fire Barrier Materials." This VP verifies the part number / identification of the material, performs a general receipt inspection of the material, performs a review of the material to determine that the items received are as specified and undamaged and verifies that the quality authorization to ship is traceable to the PO for the material in the shipment.
Additionally, TU j
Refer to R! Electric letter logged TXX.92589 dated December 15, 1992: NRC IR 50-445/93-08: 50 446/93-08: and NUREG-0797 Supplement 26. pg. 9-20.
b Attcchment 2 to TXX-95004 Page 6 of 10 Electric QC verifies the material formulation by comparison of the certificate of compliance with manufacturing documents. including weight and size.
Once the fire barrier materials have been determined to satisfy the requirements of the receipt inspection VP. the material is released to the warehouse.
l' The results of these inspections provide adequate confidence that the Thermo-Lag material accepted at CPSES conforms with specifications.
NRC has performed inspections and reviews of TV Electric's receipt inspections for Thermo-Lag.
Based upon the results of these inspections and reviews. NRC has concluded that TV Electric's quality assurance for receipt i
of Thermo-Lag is strong.5 l
6.0 INSTALLATION i
TSI did not perform the Thermo-Lag installation functions at CPSES.
Thermo-Lag at CPSES was installed by qualified TU Electric contractors in accordance with a 0A program approved by TV Electric.
TV Electric's
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installation process exceeded TSI's recommendations.
During installation, pertinent quality verifications, attributes and acceptance standards have been incorporated in work packages as check lists.
In-process and final quality inspections are also documented on applicable checklists.8 The in-process and final installation inspections (for both initial and upgraded installations) have included both material and installation attributes.
For example, these inspections check for:
I.
THERMO-LAG INSTALLATION I
a.
Surface preparation and raceway condition.
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b.
Qualification of applicators.
c.
Product identification and shelflife, d.
Surface preparation prior to Thermo-Lag application.
e.
Panel Fasteners per design.
3 Refer to TU Eleciric letter legged TXX-92539 dated December 15, 1992: NRC IR 50 445/93-08: 50-446/93 08: and NUREG 0797 Supplement 26. pg. 9-20.
6 Please note that these subjects were previously reviewed by the NRC. as d0erented in NRC inspection report (IR):
(1) 50-445/93-08: 50 446/93-0B (11) 50 445/93-34: 50 556/93-34 (iii) 50-445/93-42: 50-446/93-42 (iv) 50-445/94 21; 50-446/93 21 to TXX-95004 Page 7 of 10 f.
Band Spacing per design (internal and external) g.
Presence of fire stops per design.
h.
Thermo-Lag 330-1 application to prebutter joints.
1.
Panel Installation per design.
j.
Thermo-Lag 330-660 mixing.
k.
Flexi-blanket fastening material and installation process.
1.
Thermo-Lag on building steel per engineering documents.
II.
THERMO-LAG FIRE BARRIER FINAL ACCEPTANCE a.
Hardware / spacing - Thermo-Lag 330-1 b.
Hardware / spacing - Thermo-Lag 330-660 I
c.
Thermo-Lag Dry Film Thickness (DFT).
d.
Continuity.
e.
Visual Defects.
f.
Coverage of protruding items.
g.
Thermo-lag located per ECE-M1/M2-1700 (CPSES design drawings),
h.
Location of firestops per design.
1.
Topcoat application.
The results of the inspections described above provide adequate confidence that the as-installed Thermo-Lag at CPSES conforms with specifications.
7.0 TESTING i
TV Electric conducted its own testing independent of TSI. to qualify its as-installed Thermo-Lag configurations and to determine ampacity derating factors.
The tests were performed for TU Electric by an independent test laboratory. Omega Point Laboratories, pursuant to an Appendix B OA program.
The tests were performed on configurations installed and inspected by CPSES personnel using CPSES installation procedures.
The Thermo-Lag material used for these tests was extracted from various lots of material in stock at CPSES to assure that the tests were performed on material that is representative of the material installed at CPSES.
to TXX-95004 Page 8 of 10 TU Electric's tests involved large amounts of Thermo-Lag material and were representative of various types of Thermo-Lag used at CPSES (e.g., flat panels, ribbed panels, various sizes of preshaped conduits, flexi-blanket, trowel grade material, etc.). Approximately 1500 ftz of Thermo-Lag was used to construct 23 full scale test configurations in order to certify CPSES Thermo-Lag installations. Given the large amount of Thermo-Lag tested by TU Electric. the results of the tests are sufficient to assess the quality of the total population of Thermo-Lag used at CPSES.
As a result of these tests. TV Electric determined that the Thermo-Lag material itself, as supplied to CPSES. performs its design function if properly configured (i.e.
if Thermo-Lag joints are appropriately reinforced and an overlay is installed on the Thermo-Lag for small conduits).7 TV Electric tested a number of Thermo-Lag configurations. The test configurations were designed to envelope the various as-installed barrier configurations at CPSES.
Engineering evaluations were performed in accordance with Generic Letter 86-10 to justify those as-installed configurations that deviated from the test configurations. Therefore, there is adequate confidence that test configurations are representative of the as-installed configurations at CPSES.
TV Electric provided the results of these tests to NRC via TV Electric letter logged TXX-93023 and TXX-93353 dated January 19, 1993, and October 20, 1993 respectively.
In NLVEG-0797 Supplements 26 and 27. NRC agreed that the test configurations bound the as-installed configurations, and accepted the results of qualification tests for CPSES Unit 2.
NRC is currently reviewing qualification tests for Unit 1 (Reference NRR TAC. No. 85536).
8.0 CONCLUSION
S Based on the above, there is adequate confidence that the Thermo-Lag material supplied to CPSES conforms with specified TV Electric requirements based upon the following-Even though Thermo-Lag is not generally classified as safety related or subject to 10 CFR 50 Appendix B program by the industry. TV Electric designated Thermo-Lag as quality-related. As a result. TV Electric applied applicable criteria of 10 CFR 50 Appendix B and ANSI N45.2 to the procurement of Thermo-Lag materials.
TU Electric performed source inspections. surveillances, and audits at TSI's facility to assure the quality of Thermo-Lag.
In aggregate, these verifications address the important material attributes.
TU Electric performed receipt inspections for Thermo-Lag materials to assure that, as received on site and prior to warehouse release.
Thermo-Lag materials were acceptable for plant installation.
7 Refer to TU Electric letter logged TXX 92626 dated Jecember 23. 1992. Enclosure 5 4.2.6 and 5 9.0.
i to TXX-95004 Page 9 of 10 NRC has inspected and reviewed the application of TU Electric's Q program to Thermo-Lag and has concluded that it is acceptable.'_ A Observation of test samples both before and after testing demonstrated that no apparent differences in material composition existed.
As part of the NEI industry test program, various samples of Thermo.
Lag panel and preshaped conduit section materials were subjected to pyrolysis gas chromatography testing by an independent laboratory in accordance with ASTM D-3452.
Materials examined included stock inventory samples from TU Electric. Entergy Operations. Inc. and Houston Light and Power as well as recently manufactured materials by TSI.
The results of this testing demonstrated that no appreciable differences in material chemical composition existed between samples' There is adequate confidence that the materials tested by TV Electric were representative of materials installed at CPSES.
As discussed above. there is adequate confidence that material accepted by TU Electric conforms with specified physical and documentation requirements."
The qualification tests were performed using CPSES stock material and are therefore representative of materials installed at CPSES.
The tests involved large amounts and various types of Thermo-Lag and the test results are sufficient to assess the quality of the total population of Thermo-Lag at CPSES.
Installation of material during qualification tests and in the plant was performed in accordance with CPSES installation procedures by CPSES personnel.
The tested barrier configurations are representative of as-installed configurations of Thermo-Lag at CPSES.
1 8
Refer to NRC IR 50-445/93-08: 50-446/93-08 and NUREG-0797 Supplement 25 pg. 9-19 and 9 20.
Refer to NEI letter to Mr. William T. Russell (NRR) dated February 8,1994, i
IO Please note that these subjects were previously reviewed by the NRC. as docisnented in NRC Inspection reports:
(1) 50 445/93-08: 50-446/93 08 (11) 50-445/93-34: 50-446/93 34 (iii) 50-445/93-42; 50-446/93-42 (iv) 50-445/94-21: 50-446/94-21 1
. to TXX-95004 Page 10 of 10 i
TU has reported the test results to NRC.
NRC has witnessed the qualification tests and per. formed inspections and reviews and has concluded that the test materials are representative of tne as-
~
installed materials and that the tested configurations bound as-installed configurations."
II Refer to TU Electric letter logged TXX-92589 dated December 15, 1992; NRC IR 50-445/93-08: 50-446/93-08; and NUREG-0797 Supplement 26. pg. 9-20.
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i ATTACHMENT 3
-l TO TXX-95004 l
TU ELECTRIC RESPONSES E
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' -to 17X-95004 :
i Page 1.of 7
. TU Electric Responses To' Request for Additional Information Regarding
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Generic Letter 92 08 J
"Thermo Lag 330-1 Fire Barriers" Pursuant to 10CFR50.54(f) i QUESTION 1A i
Describe the specific tests and analyses 'that will be performed to verify that the Thermo-Lag fire barrier materials that are currently installed at
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Comanche Peak Steam Electric Station (CPSES). Units'1 and 2. or that will be installed in the future..are representative of the materialsLthat 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 processL and i
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:
t (1) chemical composition (2) material thickness (3) material weight and density
'i (4) the presence of voids, cracks, and delaminations i
(5) fire endurance capabiiities (6) combustibility (7) flame spread rating (8) ampacity derating.
(9) mechanical properties such as tensile strength, compressive strength, shear strength, and flexural strength.
I RESPONSE TO 1A There is adequate confidence that the Thermo-Lag materials installed at CPSES are representative of the materials that were used in TV Electric's 3
qualification and ampacity derating tests for Thermo-Lag. This conclusion is based on the following:
1)
As discussed in Section 4.0 and 5.0 ofEAttachment 2. TU Electric performed source inspections surveillances, audits, and receipt inspections of Thermo-Lag material.
These verification activities encompassed the'important attributes for, Thermo-Lag. As a result'of these verifications, there is adequate confidence that the Thermo-Lag material accepted at CPSES conforms with specifications.
i t
e t. 2,.. to TXX-95004 Page 2 of 7 1
1 2)
-TU Electric's fire endurance tests and ampacity derating tests used Thermo-Lag material taken from the CPSES warehouse (from various lots) l following receipt inspections Therefore, the Thermo-Lag test material is representative of the material accepted and installed at-CPSES.
3)
As discussed in Section 7.0 of Attachment 2. the tests involved large amounts and various types of Thermo-Lag and the test results are sufficient to assess the quality of the total population of Thermo-Lag at CPSES. lists each of the attributes identified in the NRC's question and describes the activities performed by TV Electric to verify the attribute in question to the extent that the attribute is important for the Thermo-Lag installed at CPSES.
As discussed in Attachment 4. TV Electric did not verify some of'the attributes identified by the NRC question because these attributes are not important for the qualification or ampacity derating factor 'of the Thermo-Lag installed at CPSES.
For example:
Some of the attributes identified by NRC (e.g., tensile strength, compressive strength, etc.) have not proven essential in determining ampacity derating properties or developing adequate structural enhancements for acceptable fire endurances performance.
With respect to CPSES, the NRC has previously concluded that voids.
cracks and delaminations would not have a significant effect on the 1
performance of properly installed Thermo-Lag.
Nevertheless, as-discussed in Section 4.0 of Attachment 2. TV Electric has taken action. including comprehensive inspections, to resolve NRC concerns in this area.
i TV Electric has previously demonstrated to NRC that density rather.
than thickness is the critical characteristic for the performance of Thermo-Lag.U Nevertheless, as discussed in Section 4.0 of Attachment
- 2. TU Electric has verified the thickness as well as the density of Thermo-Lag.
d.
U Refer to 00-93-11. 37 NRC 402, 412 413 (1993)
U Refer to TV Electric letter logged TXX-90255 dated July 13. 1990: NRC letter to TU Electric dated July 20, 1990: TU Electric letter logged TXX 'J2626 dated December 23. 1992. Enclosure $ 4.3.5.
c.
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1 to TXX-95004 Page 3 of 7 Thermo-Lag at CPSES is designated as a non-seismic commodity.2' Furthermore. TV Electric and NRC have determined that any failure of Thermo-Lag as a result of seismic event would not adversely impact the -
function of seismic Category I components because the Thermo-Lag would tend to crack, chip, and crumble and not fail in a gross manner."
Therefore. further tests and analysis pertaining to Thermo-Lag's mechanical properties are not warranted Based on its own evaluations and supported by data compiled on a generic basis by NEI. TV Electric has previously demonstrated thct combastibility and flame spread rating issues are not a sig6nificant concern for CPSES, and NRC has accepted these conclusions.
QUESTION 18 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 th8.ime of installation and manufacture of the various in-plant materials and barrier installations.
Give the number and types (e.g., panels, cond W preshapes, trowel-grade material, stress skin) of samples that will be tested or analyzed.
RESPONSE TO 1B As discussed in Attachment 2. the're is adequate confidence that Thermo-Lag materials installed at CPSES conform with specified requirements.
In particular. TV Electric took the following steps to control the quality of Thermo-Lag and to assure that the Thermo-Lag material accepted and installed at CPSES conforms with applicable requirements:
TU Electric applied its Appendix B OA program to the procurement and installation of Thermo-Lag at CPSES.
TU Electric issued specifications for Thermo-Lag including identification of important attributes for verification by TU Electric.
.i L
I' Refer to CPSES F5AR Table 17A-1.
l u
Refer to TU Electric letter logged TXX-92526 dated December 22. 1992. Enc'esure 5 4.5.2: NUREG-0797 i
Supplement 26 pg. 9-19 and 00-93-11 37 NRC 113. 128 (1993)
Refer to TU Electric letter logged Txr-93023 and TXX-93050 dated January 19. 1993. and January
- 25. 1993. respectively, and N'JREG-0797 Supplement 25 Page. 9-19.
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Attar.hment 3 to TXX-95004 Page 4 of 7 TV Electric performed source inspections, surveillances and audits of 1mportant Thermo-Lag attributes.
TU Electric performed receipt inspections for many of the important Thermo-Lag attributes.
TV Electric and its contractors performed installation inspections of a number of the important attributes. provides additional information showing how TV Electric verified the quality of Thermo-Lag material.
Additionally. as discussed in Sections 7.0 of Attachment 2. TV Electr'c's tests involved large amounts and various types of Thermo-Lag material.
' Given the large amount of Thermo-Lag tested by TU Electric, the results of-the tests are sufficient to reasonably assess the quality of-the total population of Thermo-Lag in CPSES.
As a result of these tests. TV Electric determined that the Thermo-Lag material itself, as supplied to CPSES, performs its design function if properly configured.
In summary. TU Electric has verified the important a
.ates of the Thermo-Lag procured and installed at CPSES.
Furthermore. TV tiectric tested representative materials from various CPSES stock inventory. Therefore, there is adequate confidence that the as installed Thermo-lag at CPSES is representive of the Thermo-Lag material tested for the purpose of fire I
endurance rating and ampacity derating, and there is no need for an additional sampling program.
l I
QUESTION 1C Submit the schedule for verifying the Thermo-Lag materials.
RESPONSE TO IC As discussed in Attachment 2 and the responses to question 1A and 18. TU Electric's OA program verified that the received and installed Thermo-Lag conforms with specification.
Testing has been completed, and test results have been reported to NRC. as summarized in TU Electric's Engineering Report ER-ME-067, logged via TU Electric letter TXX-94092 dated March 24, 1994 In j
NUREG-0797 Supplement 26 and 27. NRC has accepted the test results with some open items for CPSES Unit 1 (refer to NRR TAC No. 85536).
QUESTION 10
{
After the analyses and the test have been completed, submit a written supplemental report that confirms that this effort has been rompleted and provide the results of the tests and analyses.
Describe any.ianges to
6 to T7X-95004 Page 5 of 7 previously submitted plans or schedules that result from the tests or analyses.
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RESPONSE TO 1D As discussed in response to question IC, TU Electric has already reported the test results to NRC.
Thcse test reports are summarized in TU Electric's-Engineering Report ER-ME-067. logged TXX-94092 dated March 24, 1994 As discussed in this report. TV Electric's tests of Thermo-Lag were performed using material taken from various stock inventories, and the test results demonstrate that the Thermo-Lag as installed at CPSES is able to perform its design function.
QUESTION 2A Tmportant Barrier Parameters Describe the examinations and inspections that will be performed to obtain the important barrier parameters for the Thermo-Lag fire barrier configurations installed at CPSES Units 1 and 2 given below:
(1)
Raceway orientation (horizontal, vertical, radial Dends)
(2)
Conduit (3)
Junction boxes and lateral bends (4)
Ladder-back cable tray with single layer cable fill (5)
Cable tray with T-section (6)
Raceway material (aluminum.. steel)
(7)
Support protection. thermal shorts (penetrating elements)
(8)
Air drops (9)
Baseline fire barrier panel thickness (10)
Preformed conduit panels (11)
Panel rib orientation (parallel or perpendicular to the raceway)
(12)
Unsupported spans (13)
Stress skin orientation (inside or outside)
(14)
Stress skin over joints or no stress skin over joints (15)
Stress skin ties or no stress skin ties (16)
Ory-fit, post-buttered joints or prebuttered joints (17)
Joint gap width (18)
Butt joints or grooved and scored joints \\
(19)
Steel bands or tie wires (20)
Band / wire spacing (21)
Band / wire distance to joints (22)
No internal bands in trays (23)
No additional trowel material over sections and joints or additional trowel material applied (24)
No edge guards or edge guards (25)
Cable size and type (power. control or instrumentation)
(26)
Cable jacket type (thermoplastic, thermoset) and materials i
(27)
Cable conductor insulation type (thermoplastic, thermoset plastic) and materials (28)
Cable fill and distribution of cables within the protected conduit or cable tray
~ Attachment 3 to TXX-95004 Page 6 of 7 (29)
Proximity of cables to the unexposed (insiae) surfaces of the fire barrier (30)
Presence of materials between the cables and the unexposed side of the fire barrier material (for example. Sealtemp cloth, which is used in the NUMARC test specimens)
(31)
Cable operating temperature (32)
Temperatures at which the cables can no longer perform their intended function which energized at rated voltage and current.
RESPONSE TO 2A Each of the attributes listed in NRC's question was controlled as part of TU Electric's fire endurance test program to ensure that the test configurations bound the as-installed configurations at CPSES. Attachment 5 lists each of these attributes and describes the method by which the attribute was controlled by TV Electric.
As discussed in response to question 1A and 10 and Section 7.0 of Attachment 2. TU Electric has already performed tests on representative Thermo-Lag fire barrier configurations.
TV Electric reported the test results to NRC in TV Electric letters logged TXX-93023 and TXX-93353 dated January 19. 1993 and October 20, 1993 respectively.
As these letters discuss. the Thermo-Lag test configurations bound the as-installed Thermo-Lag configurations at CPSES.
TV Electric also evaluated configurations that deviated from the test configurations, and TU Electric letter logged TXX-93023 dated January 19. 1993 (Engineering Report ER-ME-082) justified the deviations as permitted by Generic Letter 86-10.
The NRC has accepted these results for Unit 2 and for Unit 1 (with some open items for Unit 1).
For example. in SSER 26 for CPSES Unit 2. NRC concluded that the fire barrier configurations tested by TV Electric " bounded the range of fire barrier sizes and configurations installed in CPSES Unit 2."
and in SSER 26 and 27 NRC concluded that the deviations from the test configurations were acceptable.
QUESTION 2B 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 ensure that the information and data that will be obtained are 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 modifications. are representative of the parameters used to construct the fire endurance test specimens.
RESPONSE TO 2B As discussed in Section 6.0 of Attachment 2. TV Elactric conducted in-process and final installation inspections to verify important installation attributes and to verify that as-installed configurations conform with i
~
l to TXX-95094 Page 7 of 7 specification. Additionally as discussed in the response to question 2A.TU Electric has tested representative Thermo-Lag fire barriers configurations and NRC has concluded that these configurations are representative.
QUESTION 2C Submit the schedule for obtaining and verifying all of the important barrier parameters.
RESPONSE TO 2C
.As discussed in response to questions 2A and 2B, the important installation parameters have been verified during installation inspections. Testing has been completed. and the tested configurations bound the as-installed configurations at CPSES.
QUESTION 2D 1
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.
RfSPONSE TO 20
~
As discussed in response to question 2A. test'results have been reported to i
NRC." NRC has concluded in SSER 26 and 27 that the tested configurations bound the as installed configurations at CPSES.
4 i
TU Electric letters Icg9ed TXX-93023 and TXX 93353 dated January 19, 1993 and October 20. 1993 respectively, i
4 6
t i
. ATTACHMENT 4 T0.
TXX-95004 MANUFACTURING ATTRIBUTES 4
i 1
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MANUFACTURING A*lTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 1 0
ITEM MANUFACTURING ATTRIBUTES VERIFIED REMARKS-NO.
HY TUE I
CIfEMICAL COMPOSITION YES Tl! ELECTRIC HAS PARTICIPATED IN THE NEIINDUSTRY TEST PROGR AM FOR CHEMICAL -
SEE REMARKS.
COMPOstilON. THE RESULTS OF Till$ TESTING DEMONSTRATED TilAT HO APPRECIARLE.
[
DIFFERENCE IN MATERIAL CHEMICAL COMPOSITION EXISTED BETWEEN VARIOUS SAMPLES COLLECTED FROM VARIOUS UTILITY STOCKS. REFER TO ATTACHMENT 2 SEC110N 4 0 ITEMS I t
AND 18, AND SECTION 5.0. TU ELECTRICQC VERIFIES VIA SURVEILLANCE THAT THE i.
PRODUCTS SHIPPED BY TSI ARE IDENTICAL IN FORMULATION TO THOSE PRODUCTS PREVIOUSLY TESTED AND SUPPLIED IN ACCORDANCE WITH TU ELECTRIC SPECIFICATION 1323-MS-3811. Tills IS PERFORMED 11Y COMPARING CERTIFICATE OF CONFORMANCES. ALSO, REFER -
10 ATTACllMENT 2 SECTION 8.0.
ADDITIONALLY, AS DISCUSSED IN SECTION 7.8 OF ATTACllMENT 2 TU ELECTRIC'S TESTS INVOLVED LARGE AMOUNTS AND VARIOUS TYPES OF THERMO. LAG MATERIALS. GIVEN THE LARGE AMOUNT OF TIIERMO-LAG TESTED RY TU ELECTRIC, THE RESULTS OF Tile TESTS ARE SUFFICIENT TO ASSESS THE QUALITY OF Tile TOTAL POPULATION OF THERMO-IAG IN CPSES.
AS A RESULT OF TilESE TESTS. TU ELECTRIC DETERMINED THAT THE THERMO-IAG MATERIAL '
ITSE! F. AS SUPPLIED TO CPSES, PERFORMS ITS DESIGN FUNCTION W PROPERLY CONFIGURED.
2 MATERIAL TillCKNESS YES MATERIAL THICKNESS IS VERIFIED AT SOURCE, RECEIPT AND INSTALLATION INSPECTION.
REFER TO ATTACllMENT 2 SECTION 4.0 ITEM 3. AND SECTION 6.8 ITEM 11 C 3
MATERIAL WEIGHT AND DENSITY '
YES.
MATERIAL WEIGHT AND DENSITY 15 VERIFIED AT SOURCE, RECEIPT INSPECTION, AUDITS AND SURVEILLANCE REFER TO ATTACHMENT 2 SECTION 4.8 ITEMS 5 AND 6. -
4 TifE PRESENCE OF VOIDS, CRACKS, AND DELAMINATIONS YES VERIFIED AT SOURCE, RECEIPT AND INSTALLATION INSPECTION. REFER TO SECTION 4 0 ITEM l
8, SECilON 5 0 AND SECTION 6.8 ITEM II D AND E.
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. to TXX-95004 Page 2 of 4 MANUFACTURING NITRIBUTES VERIFIED BY TU ELECTRIC (TUE) l TABLEI 1
ITEM MANUFACTURING ATTRIBUTES VERIFIED REMARKS NO.
BY TUE 5
FfRE ENDUR ANCE CAPABILITIES YES TU ElJECTRIC liAS DEMONSTRATED TilAT TilERMO-l.AG PERFORMS ITS FIRE ENDURANCE SEE REM ARKS FUNCTION. Tills tlAS BEEN DEMONSTRATED BY 23 TESTS PERFORMED BY TU ELECTRIC.
REFER TO ATIA(llMENT 2. SECTION 7.0.
UNIT 2 CONFIGURATIONS IIAVE BEEN ACCEPTED BY TiiE NRC(REFER TO NUREG-0797 SUPPLEMENT 26 AND 27). UNIT I 1ESTS ARE UNDER REVIEW BY TifE NRC.
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. to TXX-95004 Page 3 of 4 MANUFACTURING ATTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLEI ITEM MANUFACTURING ATTRIBUTES VERIFIED REMARKS NO.
HY TUE-6 COMBUSTIBILITY NOT APPLICABLE TU ELECTRIC llAS PREVIOUSLY SUBMITTED INFORMATRON TO THE NRC REGARDING TO CPSES.
COMBUSTIBILITY AND FLAMJ SPREAD RATING. (PLEASE REf ER TO TU ELECTRIC LETTER -
LOGGED TXx-93060 DATED 1ANUARY 25,1991 AND N,UREG-0797 $UPPLEMENT 26 PG. 9-19).
SEE REMARKS ALTilOUGliIllE INFORMATION SUBMITTED WAS FOR UNIT 2,TU ELECTRIC llAS CONFIRMED.
THAT A SIMILAR POSITION APPL.lES TO UNIT 1. Tile INFORMATION PROVIDED BY TU ELECTRIC VIA TXX-91060 iS SUMMARIZED BELOW.
.f TilERMO-LAG IS NOT UTILIZED TO ELIMINATE INTERVENING COMBUSTl8LES IN ORDER TO OBTAIN A IlORIZONTAL DISTANCE OF 29 FFET WITH NEGLIGleLE INTERVENING COMBUSTIBl.ES BETWEEN REDUNDANT [ UNIT 2] 5AFE SHUTDOWN TRAINS. THIS IS DOCUMENTED BY THE " UNIT 2 FitE SAFE SHUTDOWN ANALYSIS
- AND Tile " UNIT 2 PHYSICAL SEPARATION ANALYSIS AND UNIT 2 CASLES AND i
COMPONENTS IN COMMON AREAS *.
TilERMO LAG 15 NOT UTILIZED AS A RADIANT ENERGY SHIELD INSIDE UNIT I OR UNIT 2 CONTAINMENT STRUCTURES.
i liiERE IS NO TilERMO-LAG INSTALLED IN NON-RACEWAY APPLICATIONS FOR UNIT 2 (f.E, AS USED FOR PROTECTION OF ST RUCTURAL STEEL SUPPORTING 2 HOUR RATED GYPSUM WAS ASSEWitLIES AROUND $TAIRWAYS} WHICH COULD ACT AS AN INTERVENING COMBUSTIBLE BETWEEN REDUNDANT SAFE SHUTDOWN TRAIN $e CPSES Pl. ANT AREAS WHERE THERMO-LAG INSTALLED ON UNIT 2 SAFE SHU1DOWN RACEWAYS COULD POTENTIALLY CONSTITUTE AN INTERVENING COMBUSTIBLE BETWEEN REDUNDANT l UNIT 2) EQUIPMENT OR COMPONENTS WERE ASSESSED..
BASED ON FIRE PROTECTION FEATURES PROVIDED IN THESE AREAS,THE PROPERTIESOFTHERMO-LAG ANDOVERALLLOWQUANTITIES OFIN-SI1U -
COMBUSTIBLES TO FUEL A POSTULATED FIRE, SIGNIFICANT tlRE PROPAGATION.
BETWEEN REDUNDANT UNIT 2 SAFE SHUTDOWN EQUIPMENT OR COMPONENTS.
ALONG RACEWAYS PROTECTED WITH THERMO-LAG IS NOT CONSIDERED CREDIBLE.
P 7
FLAME SPREAD RATING YES-SEE ITEM 6 ABOVE.
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. to TXX-95004 Page 4 of 4 MANUFACTURING ATTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLEI ITEM MANUFACTURING ATTRIBUTES VERIFIED REMARKS NO.
RY TUE 8
AMPACITY DERATING YES 111 ELECTRIC IRAS PERFORMED AMPACITY DERATING TESTING. TIIE RESULTS OF Tile TESTS WERE SUBMITTTD VIA 1U El.ECTRIC LET1YR LOGGED TXX-93214 DATED MAY 26,1993.
9 MECIIANICAL PROPERTIES SUCII AS TENSELE STRENGTII, SEE REMARKS REFER TO ATTACllMENT 3 RESPONSE TO QUESTION I A. TU ELECTRIC HAS PERFORMED COMPRESSIVE STRENGTit, SilEAR STRENGill, AND FLEXURAL NUMEROUS FIRE ENDURANCE TESTS UTILIZING CPSES STOCK TilERMO-LAG MATERIALS.
STRENGTil B ARRIER UPGRADE TECilNIQUES QUALIFIED DURING TilESE TESTS IIAVE RESOLVED MECilANICAL PROPERTY ISSUES RELATED TO Tile FIRE RESISTANCE CAPABil1TY OF 11tERMO-LAG. AS DESCRIBEDIN ATTACllMENT 2. UPGRADED BARRIER CONrlGURATIONS IIAVE BEEN INSTALL.ED IN UNIT I AND UNIT 2. ADDITIONALLY,1U ELECTRIC CONCURS WIT 11 NEl RESPONSE RELATED TO TilESE A1 TRIBUTES IN ITS 1 ETTER TO Tile NRC DATED 3ANUARY 17, 1995.
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ATTACHMENT 5 TO TXX-95004-1 ATTRIBUTES VERIFIED BY TU ELECTRIC i
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4 10 TXX-95004 Page i Of 8 ATTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 2 ITEM IMPORTANT HARRIER VERIFIED REMARKS NO.
PARAMETERS BY TUE I
RACEWAY ORIENTATION (!!ORIZONTAL, VERTICAL, YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC'S INDEPENDENT FIRE RADIAL DENDS)
ENDURANCE TEST PROGRAM IIAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON llORIZONTAL AND VERTICAL RACEWAY ORIENTATIONS INCLUDING RADIAL BENDS. RACEWAY AND BARRIER MATERIAIJE UTILIZED WERE EXTRACTED FROM Ct@S STOCK INVENTORY AND TEST CONFIGURATION WERE REPRESENTIVE OF TilO3E AT CPSES.
2 CONDUIT YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE ENDURAPCE TEST PR(XiRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON CONDUIT CONFIGURATIONS REPRESENTATIVE OF TilOSE INSTALLED AT CPSES.
CONDUIT AND BARRIER MATERIALS tRILIZED WERE EXTRACTED FROM CPSES STOCK INVENTORY AND TEST CONFIGURATION WERE REPRESENTIVE OF TilOSE AT CPSES.
3 JUNCTION HOXES AND LATERAL BENDS YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRICS INDEPENDENT flRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON JUNCTION BOXES AND LATERAL DEND CONDULETS REPRESENTATIVE OF TilOSE INSTALLED AT CPSES. JUNCTION BOX, CONDULET AND BARRIER MATERIALS UTILIZED WERE EXTRACTED FROM CPSES STOCK INVENTORY AND TEST CONFIGURATION WERE REPRESENTIVE OF TilOSE AT CPSES.
f 4
- 1. ADDER-BACK CAllLE TRAY WITil SINGLE LAYER YES VERIFIED DURING INSTALL.ATION INSPECTION. TU ELECTRICS INDEPENDENT FIRE CAllLE FILL ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON CAllLE TRAYS WITil SINGLE LAYER CABLE FILL, REPRESENTA'llVE OF TilOSE INSTALLED AT CPSES. CABLE TRAY, CABLE AND BARRIER MATERIALS UTILIZED WERE EXTRACTED FROM CPSES STOCK INVENTORY AND TEST CONFIGURATION WERE REPRESENTIVE OF TilOSE AT CPSES; 1
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. 10 TXX-95004 Page 2 Of 8 ATTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 2 1
ITEM IMPORTANT HARRIER VERIFIED REMARKS NO.
PARAMETERS BY TUE 5
CABLE TRAY WITil T-SECTION YES VERIFIED DURING INSTALLATION INSPECFION. TU ELECTRICS INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-l.AG BARRIERS INSTALLED SEE FOOTNOTE I.
ON CAHLE TRAY TEE SECTIONS WillCll BOUND TiiE l ULL RANGE OF COMMODI'llES INSTALLED AT CPSES. CABLE TRAY TEE SECTION AND BARRIER MATERIALS UTILIZED WERE EXTRACTED FROM CPSES STOCK INVENTORY AND TEST CONFIGURATION WERE REPRESENTIVE OF TilOSE AT CPSES.
6 RACEWAY MATERIAL (ALUMINUM, STEEL)
YES VERIFIED DURING RECEIPT INSPECTION AND DURING INSTALLATION INSPECTION.
TU ELECTRIC'S INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED SEE FOOTNOTE I.
TIIERMO-LAD BARRIERS INSTALLED ON STEEL RACEWAYS, REPRESENTATIVE OF TilOSE INSTALLED AT CPSES. RACEWAY AND BARRIER MATERIALS UTILIZED WERE EXTRACTED FROM CPSES STOCK INVENTORY. NO ALUMINUM RACEWAY MATERIALS ARE PROTECTED Wlill TilERMO-LAG BARRIERS AT CPSES.
7 SUPPORT PROTECTION,(PENETRATING ELEMENTS)
YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON Tile FULL RANGE OF RACEWAY COMMODITY SIZES UTILIZED AT CPStiS. AS PART OF TIIESE QUAllFICATION TESTS, REPRESENTATIVE RACEWAY SUPPORT MEMBERS WERE PROTECTED IN Tile SAME MANNER AS TilOSE INSTALLED AT CPSES. ALL RACEWAY, SUPPORT AND BARRIER MATERIALS WERE EXTRACTED FROM CPSES STOCK INVENTORY.
8 AIR DROPS YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC'S INDEPENDENT FIRE ENDURANCE TEST PROGRAM IIAS QUALIFIED THERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON CADLE AIR DROPS WillCII BOUND SUCll CONFIGURATIONS INSTALLED AT CPSES. ALL CABI.E AND BARRIER MATERIALS WERE EXTRACTED FROM CPSES STOCK INVEN'IORY..'
4
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. to TXX-95004 Page 3 Of 8 ATI'RIBUTES VERIFIED llY TU ELECTRIC (TUE)
TAllLE 2 ITEM IMPORTANT llARRIER VERIFIED REMAltKS N O.
PARAM ETERS IlY TUE 9
UASELINE FIRE BARRIER PANEL TillCKNESS YES VERIFIED AT SOURCE, RECEIPT AND INSTALLATION INSPECTION. TU ELECTRICS INDEPENDENT FIRE ENDURANCE TEST PROGRAh! IIAS QUALIFIED TilERMO-LAG SEE FOOTNOTE I.
DARRIERS INSTALLED ON Tile FULL RANGE OF RACEWAY COMMODlIY SIZES UTILIZED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, TilERMO-LAG PANELS EXTRACTED FROM CPSES STOCK INVENTORY WERE LflILIZED.
TilEREFORE, TilERMO-LAG PANEL TillCKNESSES TESTED ARE REPRESENTIVE OF TilOSE INSTALLED AT CPSES.
10 PREFORMED CONDUIT PANELS YES VERIFIED AT SOURCE, RECEIPT AND INSTAI.LATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG SEE FOOTNOTE I.
HARRIERS COMPOSED OF PREFORMED CONDUIT PANELS INSTALLED ON Tile FULL RANGE OF CONDUIT SIZES INSTALLED AT CPSES. ALL CONDUIT AND PREFORMED CONDUlf PANEL MATERIALS WERE EXTRACTED FROM CPSES STOCK INVENTORY.
II PANEL RIB ORIENTATION (PARALLEL OR YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRICS INDEPENDENT FIRE PERPENDICULAR TO Tile RACEWAY)
ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON Tile FULL RANGE OF RACEWAY COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, PANEL STIFFFNER RIBS WERE ORIENTED IN Tile SAME CONFIGURATION AS TilOSE INSTALLED AT CPSES.
12 UNSUPPORTED SPANS YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRICS INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BAf:.RIERS INSTALLED SEE FOOTNOTE l.
ON Tile FULL RANGE OF RACEWAY COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, UNSUPPORTED PANEL SPANS WERE tfIll.IZED WillCil llOUND TilOSE INSTALL.ED AT CPSES.
~
. tO TXX-95004 Page 4 Of 8 NITRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 2 ITEM IMPORTANT HARRIER VERIFIED REMARKS N O.
PARAMETERS HYTUE I3 STRESS SKIN ORIENTATION (INSIDE OR OUTSIDE) '
YES VERIFIED DUklNG RECEIPT INSPECTION AND DURING INSTALLATION INSPECTION.
TU ELECTRIC *S INDEPENDENT FIRE ENDURANCE TEST PROGRAhl IIAS QUALIFIED SEE FOOTNOTE I.
TilERhlO-LAG IIARRIERS INSTALLED ON TIIE FULL RANGE OF RACEWAY COhlMODITY SIZES INSTALLED AT CPSES. AS PAR E OF TilESE QUAllFICATION TESTS, PANEL STRESS SKIN ATTRIBUTES INCLUDING ORIEN EATION (WillCll IS INSIDE AT CPSES), USE AT JOINTS AND USE OF STRESS SKIN TIES WERE CONSISTENT WITil STRESS SKIN APPLICATIONS AT CPSES..
I4 STRESS SKIN OVER JOINTS OR NO STRESS SKIN OVER YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE JOINTS ENDURANCE TEST PROGRAhl IIAS QUALIFIEI) TilERhlO-LAG DARRIERS INSTALLED SEE FOOTNOTE I.
ON Tile FUI.L RANGE OF RACEWAY COMMODITY SIZES INSTAL. LED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, PANEL STRESS SKIN ATTRIBUTES INCLUDING ORIENTATION, USE AT JOINTS AND USE OF STRESS SKIN TIES WERE CONSISTENT WITil STRESS SKIN APPLICATIONS AT CPSES.
15 STRESS SKIN TIES OR NO STRESS SKIN TIES YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TIIERMO-LAG BARRIERS INSTALLED SEE FOOTNOTE I.
ON Tile FULL RANGE OF RACEWAY COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TIIESE QUAllFICATION TESTS, PANEL STRESS SKIN ATTRillUTES INCLUDING ORIENTATION, USE AT JOINTS AND USE OF STRESS SKIN TIES WERE CONSISI'ENT WITil STRESS SKIN APPLICATIONS AT CPSES.
16 DRY FIT, POST-DUTTERED JOINTS OR PRE BUTTERED YES VERIFIED DURING INSTAL.LATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE JOINTS ENDURANCE TEST PROGRAM IIAS QUALIFIED TIIERMO-LAG IIARRIERS INSTALLED SEE FOOTNOTE I.
ON Tile FULL RANGE OF RACEWAY COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, ATERil1UTES ASSOCIATED WITil JOINTS DETWEEN PREFABRICATED TilERMO-LAG MATERIALS INCLUDING PRE-BifriERING, GAP WIDTil,IlUTT JOINTS, GROOVED / SCORED JOINTS, USE OF ADDITIONAL TROWEL GRADE MATERIAL AND USE OF ElXIE GUARDS WERE CONSISTENT WITII JOINT CONFIGURATIONS AND APPLICATIONS INSTALLED AT CPSES.
17 IOINT GAP WIDTil YES REFER TO ITEM NO.16 ABOVE.
. 10 TXX-95004 Page 5 Of 8 A'ITRIBUTES VERIFIED BY TU EL.ECTRIC (TUE)
TABLE 2 ITEM IMPORTANT HARRIER VERIFIED REMARKS N O.
PARAMETERS BY TUE la litIIT JOINTS OR GROOVED AND SCORED JOINTS YES REFER TO ITEh! NO.16 ADOVE.
19 STEEL llANDS OR TIE WIRES YES VERIFIED DURING INSTALLATION INSPECTION. TU ELECTRIC *S INDEPENDENT FIRE ENDURANCE TEST PROGRAM llAS QUALIFIED TilERMO-LAG BARRIERS INSTALLED ON TiiE FULL RANGE OF RACEWAY COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TilESE QUALIFICATION TESTS, ATTRIBUTES ASSOCIATED WITil BARRIER FASTENERS INCL.UDING FASTENER TYPE, MATERIAL, SPACING, DISTANCE FROM JOINTS, USE OF INTERNAL DANDS IN CABLE TRAYS WERE CONSIS'IENT WITil FASTENER APPLICATIONS AT CPSES.
20 D AND/WIRii SPACING YES REFER TO ITEM NO.19 ADOVE.
21 DAND/ WIRE DISTANCE TO JOINTS YES REFER TO ITEM NO 19 AllOVE.
22 NO INTERNAL DANDS IN TRAYS YES REFER TO ITEM NO.19 AllOVE.
23 NO ADDITION AL TROWEL MATERIALS OVER YES REFER TO IFEM NO.16 AllOVE.
SECTIONS AND JOINTS OR ADDITIONALTROWEL MATERIAL APPLIED 24 NO EDGE GUARDS OR EDGE GUARDS YES REFER TO ITEM NO_16 A110VE.
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. to TXX-95004 Page 6 Of 8 ATTRIBUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 2 ITEM IMPORTANT BARRIER VERIFIED REMARKS NO.
PARAMETERS HY TUE 25 CABLE SIZE AND TYPE (POWER, CONTROL, OR YES VERIFIED DURING RECEIPT INSPECTION AND DURING INSTALLATION INSPECTION.
INSTRUMENTATION)
RJ ELECTR!C'S INDEPENDENT FIRE ENDURANCE TEST PROGRAM IIAS QUALIFIED SEE FOOTNOTE I TIIERMO-LAG BARRIERS INSTALLED ON THE FULL RANGE OF RACEWAY A 2.
COMMODITY SIZES INSTALLED AT CPSES. AS PART OF TIIESE QUALIFICATION TESTS, ELECTRICAL CABLES EXTRACTED FROM CPSES STOCK INVENTORY WERE INCLUDED WITillN EACal FIRE BARRIER CONFIGURATION TESTED. Tile CABLE TYPES SELECTED CONSISTED OF Tile SAME TYPE, SIZE AND CONSTRUCTION AS TiiOSE PROTECTED BY TilERMO-LAO BARRIERS AT CPSES.' IN PERFORMANCE OF FIRE ENDURANCE TESTS, CABLE TEMPERATURES WERE MONITORED BY TilERMOCOUPLES INSTALLED AT 6 INCillNTERVAIX IMMEDIATELY FOLLOWING CONDUCT OF llOSE STREAM TESTS, ENCLOSED CABLES WERE SUBJECTED TO INSULATION RESISTANCE TESTS TO VERIFY TilEIR FUNCTIONALITY..
ADDITIONALLY, FOLLOWING REMOVAL OF THE BARRIER MATERIALS, DETAILED VISUAL INSPECTION OF Tile CABLES WAS PERFORMED BY QUALIFIED OMEGA POINT LABORATORY PERSONNEL TO CHECK FOR EVIDENCE OF CABLE DEGRADATM)N. IN Tile EVENT TilAT CABLE TEMPERATURES IN EXCESS OF TilOSE ALLOWED BY Tile TEST PROCEDURE WERE RECORDED, OR EVIDENCE OF POTENTIAL CABLE DEGRADATION WAS DETECTED UPON VISUAL INSPECTION, TU ELECTRIC PERFORMED FURTifER EVALUATION OF UNDERLYING CAUSES FOR SUCH DAMAGE AND/OR SUPPLEMENTAL CABLE FUNCTIONALITY EVALUATIONS. AS SUCll, ATTRIBUTES ASSOCIATED WITil ELECTRICAL CABLES SUCH AS SIZE, TYPE, JACKET AND CONDUCTOR MATERIAL COMPOSITION, CABLE FILL AND DISTRIBUTION, PROXIMITY TO INTERIOR BARRIER SURFACES, PRESENCE OF OTHER MATERIALS BETWEEN CABLES AND BARRIER SURFACES, CABLE OPERATING TEMPERATURE AND MAXIMUM TEMPERATURES FOR CABLE liAVE BEEN ADDRESSED.
26 CABLE JACKET TYPE (TilERMOPLASTIC, THERMOSET YES.
REFER TO ITEM NO. 25 ABOVE.
PLASTIC) AND MATERIALS
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. tO TXX-95004 Page 7 Of 8 A'ITRIIlUTES VERIFIED BY TU ELECTRIC (TUE)
TABLE 2 ITEM IMPORTANT BARRIER VERIFIED REMARKS NO.
PARAMETERS BY TUE 27 CADLE CONDUCTOR INSULATION TYPE YES REFER TO ITEM NO,25 ABOVE.
(TilERMOPLASTIC.TilERMOSET PLASTIC) AND MATERIALS 28 CABLE FILL AND DISTRIBUTION OF CABLES WITilIN YES REFER TO ITEM NO. 25 ABOVE.
TIIE PROTECTED CONDUIT OR CABLE TRAY 29 PROXIMITY OF CAllLES TO Tile UNEXPOSED (INSIDE)
YES REFER TO ITEM NO. 25 AliOVE.
SURFACES OF Tile FIRE BARRIER 30 PRESENCE OF M ATERIALS BETWEEN TIIE CADLES YES REFER TO ITEM NO. 25 A!!OVE.
AND TIIE UNEXPOSED SIDE OF Tile FIRE BARRIER MATERIAL (FOR EXAMPLE, SEALTEMP CLOTil, WillCllis USED IN Tile NUMARC TEST SPECIMENS) 31 CADLE OPERATINO TEMPERATURE SEE REM ARKS REFER TO ITEM NO. 25 AllOVE.
32 TEMPERATURES AT WillCII Tile CABLES CAN NO SEE REMARKS R EFER TO ITEM NO. 25 AllOVE.
I ONGER PERFORM TilElR INTENDED FUNCTION WiiEN ENERGlZED AT RATE VOLTAGE AND CURRENT
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TABLE 2 FOOTNOTES 1.
Refer to TU Electric Fire Endurance Test Reports previously provided to NRC via-TXX-93023 and-TXX-93353 dated January 19, 1993 and October 20, 1993 respectively. Also refer to TU Electric's " Evaluation of Thermo-lag Fire Barrier Systems" (ER-ME-067, Rev. 3), logged TXX-94092 dated March 24. 1994.
2.
Refer to TU Electric letters logged TXX-93060 and TXX-94267 dated January 25. 1993 and November 9..1994 respectively. These letters. describe TU Electric's position regarding cable Jacket material, cable' Jacket..
damage and cable functionality evaluations.
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