ML20106B299
| ML20106B299 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/25/1992 |
| From: | Rosen S HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-92-001, IEB-92-1, NUDOCS 9210010107 | |
| Download: ML20106B299 (6) | |
Text
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The Light c o mp a ny "" "*'
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'd** oyth Tcmas 77483 llouston Lighting A l'owerI
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_ f September 25, 1992 ST-HL-AE-4216 File No.:
G3.03 U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 South Texas Project
'I, s -
3 Units 1 and 2
.,l Docket Nos. STN 50-498, STN 50-499 E9sooDse to NR2 Bu Hatin 92-01. Supplement 1
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Reference:
Letter ST-HL-AE-4156 dated July 21, 1992 from S.
L. Rosen (HL&P) to the USNRC Document Control Desk
- s HL&P submits the attached response to NRC bulletin 92-01, Supplement 1.
Mr.
A.
W.
Harrison is the point of contact for this issvc at STP and can be reacned at 512-972-7298.
S.
L.
Rosen Vice President, Nuclear Enginearing SDP/ag
Attachment:
Response to NRC Br. Iletin 92-6:.,
Supplement 1 200033 t
l CLP\\9? 262.001
\\ %hsidiary of Houston Industries incorporated 9210010107 920925 g
fur ADOCK C5000498 e
Iloaton Lighting & Power Company ST-HL AE-2416 South Texas Project Electric Generating Station File No.: G3.03 Page 2 cc:
1 Regional Administrator, Regic.) IV Ruf.
S.
Scott Nuclear Regulatory Coinmission Asst.
ste General ccd mol 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Coc.pany Arlington, TX 76011 P.
O.
Box 61867 Houston, TX 77208 George Dick, Project Manager U.S.
Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 Circle 75 Parkway J.
I. Tapia Atlanta, GA 30339-3064
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Senior Resident Inspector c/c U.
S.
Nuclear Regulatory Dr. Joseph M. Hendrio Commission 50 Bellport Lane P.
O.
Box 910 Bellport, NY 11713 Bay City, TX 77414 D.
K.
Lacker J.
R.
Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C.
Texas Department of Health 1615 L Street, N.9.
1100 West 49th Street Washington, DC 20036 Austin, TX 7L!L5-3189 D. F. Ward /T. M.
Puckett Central Power and L3jht Company P.
O.
Box 2121 Corpus Christi, TX 78403 J.
C. Lanier/M.
B.
Lee City of Austin Electric Utility Department P.O.
Box 1088 Austin, TX 78767 K. J. Fiedler/M. T. Hardt City Public Service Board P.
O.
Box 1771 San Antonio, TX 78296 Revised 10/11/91 L4/NRC/
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LNITED STATES OF AMERICA.
HUCLEAR REGULATOR'l COMMISSION.
In the Matter
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)
Houston Lighting & Power
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Docket mos. 50-498 Company, et al.,
)
50-499
)
South Texas Project-
)
Units 1 and 2 AFFIDAVIT S. L. Rosen being duly sworn, hereby deposes and says-that he is Vice President, Nuclear Engineering of Houston Lighting & Power-Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Response to NRC Bulletin 92-01, Supplement 1 is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.
Q CM S.
If Rosen Vice President, Nuclear Engineering STATE OF TEXAS
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Subsci and sworn to before mc a Notary Public in and b
1992.
forTheStateofTexasthisS6%Adayofc9/Or~t'4L l
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{p,,gyg gf_ y./g?,3[{~ n Atoy ruenc.see 9 km . gg) Notary Public in and for the W com=r.e Den Mc 94 l State of Texas l GLB)D2-262,001 r, k
Attachment ST-ilL-AE-4 216 - Page 1 of 3 R9spSoEge to_NRC Bulletin _92-01, Supplement 1-MEOUESTED ACTION: All holders of operating licenses for nuclear power reactor, immediately upon receiving this bulletin supplement, are requested to take the following actions. The actions are essentially the same as those listed jn Bulletin 92-01, but the scope has been expanded to include all sizes of cenduits and trays and to include walls, ceilings, and equipment enclosures. 1. For those plants that use either 1-or 3-hour pre-formed Thermo-Lag 330 panels and cr nduit shapes, identify the areas of the plant which have Thermo-Lag 330 fire barrier material and determine the plant areas which use this material for the protectior. and neparation of the safe shutdown capability. 2. In those plant areas in which Thermo-Lag fire barriers are used in raceways, walls, ceilings, equipment enclosures, or other areas to protect cable trays, conduits, or separate redundant safe shutdown functions, the licensee should implement, in accordance with-plant procedures, the appropriate compensatory measures, such as fire watches, consistent with thque that would be implemented by either the plant technical ^ -_ifications or the operating license for en inoperable fire barrier. These compensatory measures should remain in place until the licensee can declare the fire barriers operable on the basis of applicable tests which demonstrate successful 1-or 3-hour barrier performance. l Each licensee who har f.nstalled Thermo-Lag 330 fire barriers must inform the NRC in writing within 30 daya of receiving this bulletin i supplement, whether or not it has taken the above actions. Where fire barriers are declared inoperable, the.1/ censee -is required to describe the measures being taken to ensure ot restore fire barrier operability. These measures should be consistent with actions taken l in response to Bulletin 92-01. l GLB\\92-262.001 l l
_ _ _ _ _ _ _ ~ _ _... _. _ _ _ _. _ _. _ b Attachment ST-HL-AE-4216 Page 2 of 3 RhkP_RE019FE h ACTION 1 Thermo-Lag 330 fire barrier systems have been used fer the protection and separation of the safe shutdown capability-in STP units 1 and 2. All areas of the plants which have Thermo-Lag 330 fire barrier material installed have been identified. HL&P has located all Thermo-Lag installations being used to protect the primary safe shutdown circuits and those which separate HVAC ductwork needed to support safe shutdown. Thermo-Lag is not used icr walls, ceilings or other such enclosures at STP. ACTION 2: Ac reported in response to NRC Bulletin 92-01, hourly fire watches have been established for each of the affected fire areas outside the reactor containment building. These fire watches have been t.xpanded in response-to NRC Bulletin 92-01, Supplettent
- 1 to envelo;>e the expanded scope described in the Supplement. The not effect on fire watch activities was minimal due, in part, to conservatism used.
in establishing fire watches in response to the Bulletin. This action is consist.cnt with the requirements of the STP fire protection program as described in the STP UFSAR. HL&P also initially established hearly fire watches inside the reactor containment building (RCB) in response to NRC Bulletin 92-01. These vatches were discontinued subsequunt to a conference call with the NRC on June 25, 1992 in whien HL&P agreed to impose alternative compensatory actions.. There is no reason to impose compensatory actions in addition to the ongoing actions thus established since the expanded scopo described in the Bullet 4n Supplement #1 did not address any Thermo-Lag installations inside containment which had not been identified and evaluated previoucly. HL&P has staged fire suppression equiprent close to containment entry air
- locks, established pro-staged radiation work permits to ensure pr7pt RCB entry in case of fire, briefe.d the fire brigade on the Thermo-Lag degraded condition and has drilled the fire brigade specifically on RCB entry. As previously described in responne to Bulletin 92-01, HL&P considers the Thermo-Lag inside the RCD effective as - a radiant energy shie:d in accordance with Appendix R,
III.G.2.f. Consequently, the ongoing compensatory actions for the RCB described above are conservative. GLB)92-262.001 m . ~ -w ar w .,c ---y
Attachment ST-HL-AE-4216 Page 3 of 3 ACTION _lq_EE_8JAE_]QLD TO PJSTOR5 FIRE DARRIER OPERABILQX As a benefit of having three 2ndependunt safety trains, STP's safe shutdown design generally. includes two functionally redundant pathways, which exceeds regulatory requirements. As a result, the impact of the Thermo-Lag issues is mitigated by STP's unique design. Also, HL&P has conservatively estaolished fire watches for areas where the primary pathway is protected by Thermo-Lag, Appropriate actions to establish fire barrier operability r are being developed through an industry program being coordinated by NUMARC. This program includes the establishment of a test database, development of guidance for app'icability-of
- tests, development of generic instal Lt ion guidance and consideration and coordination of additional testing as appropriate. HL&P supports the NUMARC program and will apply the results of these efforts, when completed, to the affected STP Thermo-Lag installations.
As an additional indication of the safety of the STP design relative to fire, the STP Probabilistic Safety Analysis-(PSA) shows that fire contributes less that it of the total STP core damage frequency. Furthermore, the PSA did not include credit for applied fire barriers such as Thermt,-Lag. C CLB\\92-262.001 .}}