ML20127L932
| ML20127L932 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/26/1993 |
| From: | Architzel R Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20127L916 | List: |
| References | |
| OL, NUDOCS 9301280059 | |
| Download: ML20127L932 (9) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IlEFORE THE COMMISSION In the Matter of
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Docket No.
50-446-OL TEXAS UTILITIES ELECTRIC
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COMPANY
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I (Comanche Peak Steam Electric
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Station, Unit 2)
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AFFIDAVIT OF RALPH E. ARCHITZEL REGARDING THERMO-LAG INSTALLATION AT TESTING FOR CPSES UNIT 2 1, Ralph E. Architzel, first being duly sworn, depose and state
- 1. My name is Ralph E. Architzel. I am employed by the U.S. Nuclear Regulatory Commission as a Section Chief, Nuclear Reactor Regulation, Plant Systems Branch.
My resume is attached hereto as Attachment 1.
- 2. The purpose of this affidavit is to respond to the technical questions regarding Thermo-Lag testing and installation at CPSES Unit 2, raised by the January 13,1993 letter from Ciitizens for Fair Utility ReFulation (CFUR) to the Commission; specifically, to describe actions the staff is taking in the various areas cited and to describe why the alleged deficiencies do not pose a threat to public health and safety.
- 3. In June 1991, the NRC established a Special Review Team to investigate the safety significance and generic applicability of technical issues regarding allegations and operating experience concerning Thermo-Lag fire barriers at River Bend Station. The 9301200059 930126 PDR ADOCK 05000446 9
results of fire test failures and installation problems were discu: sed in Ir: formation s
Notices 91-47 and 91-79. Information Notice 92-46 documented the team's findings regarding the indeterminate nature of the fire barrier system. Additionally, NRC Bulletin 92-01 described failures of Thermo bg fire barrier test con 6gurations that TU Electric conducted in June,1992. This testing was conducted in response to the concerns identified in ins 91-47 and 91-79. The NRC staff provided additional information regarding Thermo Lag in IN 92-55 and Bulletin 92-01, Supplement 1, IN 92-82, and Generic 1.etter 92-08,
- 4. The NRC staff, through its acknowledgement letter dated August 19,1992 (to a 2.206 petition which raised many of these same concerns), stated that it was not necessary to issue an order to stop the continued installation of Thermo-bg at CPSES Unit 2 because the licensee was proceeding with construction at its own risk, and the NRC would ensure at the operating l! cense stage that " issues related to Thermo-Lag at Comanche Peak Unit 2 are sufficiently resolved to ensure adequate protection of the public health and safety." Prior to license issuance, the NRC will determine the acceptability of the Thermo-bg fire barrier system.
- 5. The allegation that " tests mnducted to date have not shown that Thermo-bg can meet the NRC criteria for fire protection" is incorrect. Specific criteria for TU Electric's testing was forwarded to them by letter dated October 29,1992. Test reports submitted by TU Electric demonstrate that Thermo-Lag fire barrier systems
3 that are properly designed and installed do meet NRC criteria for fire protection. Final staff review of the Unit 2 tests will be completed prior to low power license issuance.
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Appropriate compensatory actions in accordance with the utility's fire protection program will be required if technical issues regarding operability remain unresolved.
- 6. Regarding the allegation that Thermo-Lag was shipped to the CPSES site with voids and found filled with staples:
The NRC staff requested additional information (letter of November 25,1992) from TU Electric following notification of these deficiencies. TU Electric responded by letter dated December 15,1992, providing additional details regarding their quality control and quality assurance programs relating to Thermo Lag procurement, testing, and installation in its letter, the applicant described the a:tions it had taken to ensure that the fire barrier materials used in its fire test program were representative of the materials installed in CPSES, described its quality controls and receipt inspection process, and described how it had addressed the delamination and void concerns. TU Electric Engineering Report ER-ME-067, revision 2, also provided information on the applicant's receipt acceptance criteria for Thermo-l.ag materials.
The staff evaluated the information provided by the applicant, observed the construction of several fire test specimens, and audited the applicant's fire barrier material procurement specifications, procedures, and documents during the CPSES,
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Snit 2 site visit of January 11 through 13,1993. The staff concluded that the 5;
=: ant's source inspections, including verification of the vendor's thickness and
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weight measurements, coupled with the applicant's receipt inspections provided reasonable assurance that the prefabricated and preshaped Thermo-Lag fire barrier materials used at CPSES, Unit 2 are acceptable. The staff also concluded that the Thermo Lag materials used to construct the fire test specimens were representative of the materials installed at CPSES, Unit 2, that the fire test program demonstrated that the nominal thickness variations and volds inherent in the prefabricated Thermo-lag 3301 fire barrier materials do not cause premature failure of the tested fire barrier configurations, and that the applicant had adequately addressed the delamination and void concerns that the vendor identified to the staff.
These actions, coupled with the satisfactory fire test results provide assurance that the Thermo Lag material procurred and used at CPSES Unit 2 will perform at acceptable levels. Additionally, TU Electric's receipt inspection practice of weighing prefabricated Thermo-Lag sections ensures that the material is bracketed between acceptable minimum and maximum weight limits. The minimum weight acceptance criteria, coupled with testing using materials representative of material to be installed, provides assurance that the barrier system is acceptable, notwithstanding the presence of voids. The maximum weight limit ensures that the total weight does not exceed support loading limits.
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- 7. Regarding the issue of the independence of the vendors own testing of the material, TU Electric independently tested the material in order to qualify the fire barrier system. A majority of the testing program has been observed by NRR, Region IV, and NRC contract personnel.
- 8. Regarding the concern over the combustibility of Thermo-lag, this issue was identified by the NRC staff and documented in IN 92-82. TU Electric responded to the concerns identified in this IN by letters dated January 19, and January 25,1993. In the fire areas where Thermo-Lag is used, TU Electric has analyzed the potential in situ combustible loading, and based on their Fire Hazards Analysis, has concluded that adequate fire protection features exist to address the combustible properties of Thermo-Lag. The utility has committed to participate in the NUMARC effort at addressing Thermo-Lag combustibility. This is acceptable due to the fire retardant nature of the Thermo-Lag material and TU Electric's analysis ofin-situ combustible loading and fire protection features discussed above.
Additionally, there is no evidence that Thermo-Lag could be an initiator of a fire.
- 9. Regarding the concern regarding " confusing and wrong" ampacity ratings, this
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6-allegation is not new, and has been addressed by NRC generic correspondence (IN 92-82 and GL 92-08). The NRC staff has determined that, in practice, the ampacity derating factor resulting from Thermo-lag insulating properties represents only one of many variables used in determining the design capacity for cable systems, and that sufficient margin likely exists (e.g., cables normally have a higher current carrying capacity, cable sizing is based on a full load current plus a 25 percent margin, in-plant cable sizes are often larger than required by design which provides additional current carrying capacity, most cables are normally deenergized and are used during surveillance testing for short time periods), in this area to preclude any immediate safety concerns. The NRC staff's generic assessment of this concern has concluded that based on the conservatisms present in design and operation, the ampacity derating issue is not an immediate safety issue, but rather is an aging issue to be resolved over the long term.
TU Electric has documented their ampacity deratings in a letter dated December 23, 1992. They are utilizing the cable derating factor of 31 percent, consistent with the --
results of testing performed at Underwriter's Laboratory facility. TU Electric has also i
i committed to the NRC staff to complete ampacity derating' testing and identify-corrective action (as required), by the completion of the first refueling outage. ' This is
- acceptable based on the generic assessment discussed above, and TU Electric's commitment to test for ampacity derating prior to the completion of the first refueling -
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ATTACHMENT 1 Ralph E. Archittel Statement of Professional Qualifications I am employed as Chief of the Special Projects Section, Plant Systems Branch, Office of Nucaar Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C.
I attended the U.S. Naval Academy, Annapolis, MD and received a BS degree with a major in Physics / Applied Science in 1971. I later attended George Washington University and received a Masters in Engineering Administration in 1983.
In my present position I direct and supervise personnel responsible for the regulatory oversight and licensing reviews for issues relating to fire protection (10 CFR Part 50.48), control room habitability, plant ventilation systems, diesel generators, radioactive waste systems, and special projects assigned to the Plant Systems Branch.
These responsibilities include review and approval of safety evaluations of applicant and licensee submittals involving licensing and plant modifications and related changes to the technical specifications issued with each operating license. These responsibilities also include supervision of the implementation of the NRC's action plan to address technical issues associated with the Thermo-Lag fire barrier systems.
Prior to assuming my present assignment in 1988, I led teams of engineers 8
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,n, performing inspections of the engineering and design of nuclear power plants. These inspections were multi-discipline in nature and used senior experienced engineers to critically examine detailed aspects of the design / design process at nuclear plants in order to draw conclusions regarding their adequacy.
Prior to 1983 I was assigned as the Senior Resident Inspector at the Calvert Cliffs Nuclear Power Plant. I was responsible for supervising and conducting inspections of operations at this two-unit pressurized water reactor. My previous duty within the NRC prior to 1980 included assignment as a reactor principal inspector for two operating boiling water reactors and several research reactors in the Region 1 Office.
4 This position was the primary inspection focal point for nuclear power plants before the start of the NRC Resident inspector program. I also served as a procedures, training, maintenance, and quality assurance inspector while at the Region I Office.
Between 1971 and 1976 I served onboard submarines in the U.S. Navy. This service included the supervision of operations, maintenance, and testing of nuclear power plants.
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outage of Unit 2.
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The matters stated above are true and correct to the best of my _ knowledge, information and belief.
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Ralph E. Architzel Subscribjd and sworn to before me thit'af6dday of January,1993.
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Notary Public My commission expires: /4d/f.5:
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