ML20127K868
| ML20127K868 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/19/1993 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-92-08, GL-92-8, TXX-93038, NUDOCS 9301260253 | |
| Download: ML20127K868 (5) | |
Text
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- TXX-93038 Fi1e # 10119
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- Generic Letter 92-08 NRC Bulletin 92-01 7t/ELECTR/C January 19, 1993 Wmiam J. Cahill, Jr.
Group Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 2 00CKET NO. 50-446 RESPONSE TO GENERIC LETTER 92-08 THERMO-LAG 330-1 FIRE BARRIERS REF:
1)
TU Electric letter logged TXX-92331 from W. J. Cahill, Jr., to NRC dated July 9, 1992; Response to NRC Bulletin 92-01 2)
TU Electric letter logged TXX-92446 from W. J. Cahill, Jr., to NRC dated September 18, 1992; Response to NRC Bulletin 92-01, Supplement 1 3)
TU Electric letter logged TXX-92626 from W. J. Cahill, Jr., to NRC dated December 23, 1992; Evaluation of Thermo-Lag Fire Barrier System 4)
TU Electric letter logged TXX-93023 from W. J. Cahill, Jr., to NRC dated January 19, 1993; Thermo-Lag Laboratory Test Result Reports for CPSES Unit 2 5)
NRC letter from Thomas A. Bergman to William J. Cahill, Jr.,
dated September 22, 1992 6)
HRC letter from Thomas A. Bergman to William J. Cahill, Jr.,
dated October 2, 1992 Gentlemen:
Generic Letter 92-08, dated December 17, 1992, stated that all addresses are required, pursuant to section 182(a) of the Atomic Energy Act of 1954, as amended, and 10CFR50.54(f), to submit a written report within 120 days from the date of this generic letter. TU Electric has reviewed the Actions l
Requested and Reporting Requirements.
l The Actions Requested and Reporting Requirements specified in the generic letter and the corresponding responses for CPSES Unit 2 are provided below.
The responses for CPSES Unit 1 and the voluntary submittal of impact data are being evaluated and will be submitted at a later date.
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TXX-93038 Page 2 of 4 I.
ACTIONS REOUESTED Action 1)
Confirm that the Thermo-Lag 330-1 barrier systems have been qualified by representative fire endurance tests.
Response 1)
TV Electric has confirmed that the Thermo-Lag barrier systems have been qualified by representative fire endurance tests.
The results of the TU Electric tests have been submitted-to your staff via reference 3 and reference 4.
Additionally reference 4 provides details regarding Engineering Evaluatior:s of untested configuration.
TV Electric is in full compliance with this requested action'.
Action 2)
Confirm that the ampacity derating factors have been derived by valid tests.
Response 2)
Engineering Report ER-ME-067, was docksted via TV Electric's letter TXX-92626 dated December 23,1992(reference 3).
Section 6.0 of this engineering report documents TV Electric's evaluation on ampacity derating factors. This evaluation is based upon the conservative application of the results from several ampacity tests (as referenced in the report) to the specific configurations used at CPSES. Additionally the report states that TV Electric will complete additional plant 4
specific ampacity derating testing and will identify corrective actions if required, by the completion of the first refueling outage. TU Electric is in compliance with the requested action.
Action 3)
Confirm that these qualified barriers have been installed with appropriate procedures and quality controls to ensure that they comply with the NRC's requirements.
Response 3)
TU Electric confirms that qualified barriers have been installed with appropriate procedures and quality controls to ensure that they comply with the NRC's requirements. This matter is also discussed in reference 3 and reference 4.
e TU Electric is in compliance with the requested action.
II. REPORTING REOUIREMENT_S Requirement 1)
Stcte whether Thermo-Lag 330-1 barriers are relied upon (a) to meet'10CFR50.48, to achieve physical independence of electrical systems, (b) to meet a condition of a plant's operating license, or (c) to satisfy a licensing commitment.
If applicable, state that Therno-Lag 330-1 is-not used at the facility. This generic letter applies to all 1-hour and all 3-hour Thermo-Lag 330-1 materials and barrier systems assembled by any_ assembly method such as by
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F j-t TXX-93038 l
Page 3'of 4 1
assembling preformed panels;and conduit shapes, as well as..
spray, trowel and brush-on applications.
l Response 1)
As stated in response to NRC Bulletin _92-01 and Supplement I to Bulletin 92-01 (reference l'and reference 2), Thermo-L.
Lag'330-1 barriers are relied upon to satisfy NRC.
requirements._ Additionally,-reference 3 describes in detail TU Electric's licensing commitments (refer to Section 3.0 of the Engineering Report ER-ME-067).
l Requirement 2)
If'Thermo-Lag 330-1 barriers are used at the facility, i
(a)
' State whether or not the licensee has qualified the i
Thermo-Lag 330-1 fire barriers by conducting fire
. endurance. tests.in accordance with;the NRC's i
requirements and guidance or= licensing commitments.
b
.(b)
State;(1) whether or not the fire barrier configurations installed in the. plant: represent the materials, workmanship, methods of assembly, dimensions, and configurations of the qualification test assembly configurations; and (2) whether or not j
the licensee has evaluated any deviations from the
-tested configurations.
(c)
State'(1) whether or not the as-built Thermo-Lag l
330-1. barrier configurations are consistent with the barrier configurations'used during the ampacity derating tests relied upon by the licensee for the ampacity derating factors used for all raceways protectedbyThermo-Lag-330-1(for.fireprotectionof c
safe shutdown capability or to achieve physical F
~independenceof-electricalsystems)and(2)whether or not the.ampacity-derating test results relied upon 4
F by_the licensee ~are correct and applicable to the
_ lent design.
p t
Response 2a)
Reference 3 and'. reference 4 describe in detai_1 that; TU Electric has qualified the Thermo-Lag 330-1_ fire.
barriers by conducting fire endurance tests-in-accordance-i ~
with the:NRC's: requirements'and guidance and licensing
{
commitments.
Response 2b)
The fire barrier configuration installei--in the plant; j
represent-the_ materials,. workmanship, methods of-assembly, dimensions,'and configurations =of the qualification-test' assemblies and configuration. Additionally, TU Electric l-has-evaluated the configurations which did not represent j
the tested configurations, these. evaluations have been-
'provided to your_ staff via_ reference 4.
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TXX-93038 Page 4 of 4 Response 2c)
Refer to Section I, response to Action 2, above.
Requirement 3)
With respect to any answer to items 2(a), 2(b), or 2(c) above in the negative (a) describe all corrective actions needed and include a schedule by which such actions shall be completed and (b) describe all cornpensatory measures taken in accordance with the technical specifications or administrative controls.
When corrective actions have been completed, confirm in writing their completion.
Response 3a)
Although additional plant specific ampacity testing is planned no additional corrective actions are presently required.
Response 3b)
Reference 1 and reference 2, which are respoases to NRC Bulletin 92-01 and Supplement 1 to Bulletin 92-01, describe the appropriate compensatory measures. At the date of this letter, the installation of the Thermo-Lag barrier system is not complete for Unit 2.
If the Unit 2 low power operating license is issued prior to the completion of this Thermo-Lag installation, such compensatory measures shall be established as needed.
Requirement 4)
List all Thermo-Lag 330-1 barriers for which answers to item 2 cannot be provided in the response due within 120 days from the date of this generic letter, and include a schedule by which such answers shall be provided.
Response
Not applicable for Unit 2.
Responses for Unit 1 will be provided within the allotted time, Reference 5 and 6 accepted TU Electric's response to NRCB 92-01 and its supplement and requested that TU Electric inform the NRC when corrective actions are complete. As noted above, corrective actions are complete and all that remains is the completion of Thermo-Lag installation for Unit 2.
i Should you have any questions or need additional information please contact Obaid Bhatty at (817) 897-5839.
Sincer,el,
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William J.
ahill, Jr.
OB/tg Attachment 4
c-Mr. J. L. Milhoan, Region IV Resident Inspectors, CPSES (2)
B. E. Holian, NRR T. A. Bergman, NRR
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Attachment to TXX-93038 Page 1 of 1 2
l UNITED STATFS OF AMERICA NUCLEAR REGULATORY COMMISSION In.the Matter of i
l Texas Utilities Electric Company Docket Nos. 50-446 (Comanche Peak Steam Electric
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i Station, Unit 2)-
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j, William J. Cahill, Jr. being duly sworn, hereby deposes'and says that he is i
Group Vice-President, Nuclear of.TV Electric, the lead Applicant herein;-
i that he is auly-authorized-to sign and file'with.the Nuclear. Regulatory.
Commission this response to' Generic Letter 92-08 for the captioned facility; that he-is familiar with the content thereof; and that the matters set =forth therein are true and correct to the best of his knowledge, information and belief.
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_ illiam J..Cahill, Jr../
W Group:Vice President, Nuclear
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i STATE OF TEXAS
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COUNTY OF Somervell Subscribed and sworn.to before me, on this 19th ~ day of' Januarv i--
1993.
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. Notary Public
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