ML20140F356

Summary of 970414 Meeting W/Util in Rockville,Md to Discuss Issues Associated W/Use of Thermo-Lag Fire Barrier Matl at Plants.Meeting Attendees & Handouts Encl

ML20140F356
Person / Time
Site:	Peach Bottom, Limerick
Issue date:	04/30/1997
From:	James Shea NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
TAC-M85565, TAC-M85566, TAC-M85586, TAC-M85587, NUDOCS 9705020263
Download: ML20140F356 (30)

Text

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i g s UNITED STATES

, g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 0001 i o o # April 30, 1997

! LICENSEE: PECO Energy Company (PECO) f

! FACILITY: Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Limerick Generating Station (LGS), Units 1 and 2 l

SUMMARY

OF APRIL 14, 1995 MEETING BETWEEN NRC AND PECO, RESOLUTION i 0F THERM 0-LAG CONCERNS, PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 l

AND 3, AND LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS, M85586, M85587, M85565 AND M85566) l L On April 14, 1997, the NRC staff met with representatives of PECO Energy  !

! Company (PECO, the licensee) at the NRC offices in Rockville, Maryland, to )

! discuss issues associated with the use of Thermo-Lag fire barrier material at  !

PBAPS and LGS. A list of meeting participants is enclosed (Enclosure 1).

Also enclosed is a copy of PEC0's meeting handout (Enclosure 2).

In introductory remarks, the NRC staff stated that it was interested in ,

! expeditiously resolving concerns with the effectiveness of Thermo-Lag 330 as a i fire barrier in nuclear power plants. Concerns with the effectiveness of i Thermo-Lag are described in NRC Generic Letter-(GL) 92-08, "Thermo-Lag 330-1 Fire Barriers," and other NRC generic communications. The staff expressed

! interest in understanding PEC0's plans and schedules for the resolution of these concerns at PBAPS and LGS. The licensee stated that it was prepared to provide that information as well as information on its accomplishments to date l in this area.

PEC0 began its presentation by describing the scope of Thermo-Lag use at PBAPS and LGS. Approximately 4800 linear feet and 4400 linear feet of Thermo-Lag is installed at LGS and PBAPS respectively, in both 1-hour and 3-hour fire barrier applications, encompassing cable trays, conduits, junction boxes and

( gutter ways. Since 1992, PECO has implemented compensatory measures, primarily roving fire watches, while the Thermo-Lag corrective action program is completed.

t PEC0 stated that its overall approach since 1992 has been to resolve Thermo- '

Lag issues in a cost effective manner while ensuring plant safety. PEC0 described a number of integrated activities it has conducted, or is conducting as part of its overall resolution plan. These activities include a complete safe shutdown re-analysis for both PBAPS and LGS, completion of fire risk analyses associated with the Generic Letter 88-20, Individual Plant Examination for External Events (IPEEE), evaluation of existing Thermo-Lag configurations and evaluation of alternative fire barrier materials. PEC0 stated that one additional goal of the project is to significantly upgrade the fire protection program documentation for each plant.

l With regard to the overall schedule, PEC0 stated that its schedule for full i j regulatory compliance was driven by the potential to perform major gjj(

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( modifications at either PBAPS or LGS, and that the major modification schedule was driven by the need to perform such modifications during bi-annual refueling outages. PEC0's current schedule is to be in full compliance with associated regulatory requirements by April 1999 for LGS (Unit 2) and October 1999 for PBAPS (Unit 3).

To date, PECO indicated that it has completed and submitted the IPEEE fire risk analysis for both PBAPS and LGS. PECO also stated that it has identified the revised safe shutdown configuration in terms of necessary equipment, necessary manual operator action and the reliance on fire barrier electrical raceway protection for protection of the necessary equipment. PECO indicated that the revised analysis will provide for a potential 70% reduction in the amount of Thermo-Lag relied upon to achieve and maintain safe shutdown in accordance with NRC fire protection requirements. In addition, PEC0 has identified and approved for conceptual design the necessary major modifications needed to support the revised analysis.

PECO described the evaluations it has performed on the existing Thermo-Lag l configurations including identification of which PECO fire barrier assemblies

! were bounded by industry tests, and which PECO configurations required the

, development of PECO-specific tests. PEC0 described the Thermo-Lag composition

! verification program it had completed and the revisions to combustible loading

, analyses that had been required based on the known combustible nature of l Thermo-Lag. PEC0 described briefly its participation in industry Thermo-Lag testing programs.

l PECO explained the scope of remaining analytical and modification work  !

required to meet the schedule commitments. In the handout, PEC0 described the  !

process and general schedule on which all modifications are developed with respect to the outage in which they are to be installed. PECO also described the general modification review criteria for modifications related to Thermo-Lag reduction including consideration of the type of plant operations window required for completing installation and testing while meeting radiological dose minimization objectives. For one modification each for PBAPS and LGS, PEC0 described how the review criteria established the commitment schedule of April 1999 for LGS and October 1999 for PBAPS.

I PECO concluded by stating that it was committed to and on track for meeting l the stated completion target dates. PEC0 did state that it planned to submit one exemption request for PBAPS and a deviation for iGS with regard to the requirement to have fire suppression equipment in addition to one-hour rated l fire barriers in certain areas of the plant and would submit its requests by 1 May 1997.

Throughout the meeting, the NRC stated that it is concerned that PEC0's resolution schedule is excessive and challenged the licensee on considering methods to improve on the implementation schedule for as much of the project as possible. The staff commented for instance, that PEC0 should examine the possibility of performing pre-modification design plant walkdowns during l

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o forced outages rather than waiting for the next Unit 3 refueling outage. In this instance, PEC0 estimated that the associated walkdowns for the PBAPS fire area wall modification would take approximately 80 man hours and would require extensive scaffolding. PECO indicated that it would consider performing the walkdowns during forced outages but that the frequency of and duration of forced outages at PBAPS and LGS in recent years did not make it likely that the walkdowns could be done prior to the refueling outage.

The staff did not obtain a clear understanding of the reasons for the licensee's schedule. The staff closed by stating that it was interested in understanding in more detail the scope of the remaining work and indicated that it would seek additional dialogue or another meeting to review the scope of the remaining work. .

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/S/

Joseph W. Shea, Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation )

Docket Nos. 50-277/278 and 50-352/353

Enclosures:

1. Meeting Attendees 1

2. Licensee's Meeting Handout cc w/encls: See next page DISTRIBUTION (Hard Copy w/ Enc 1 1 and 2): E-MAIL (w/ enc 1 1):

Docket File Sco111ns/FMiraglia JStolz PUBLIC RZimmerman M0'Brien PDI-2 Reading SVarga WDean MModes, RI CPoslusny CHehl, RI 1 JShea AThadani FRinaldi l OGC LMarsh Econnell, SPLB {

ACRS MHart RJenkins, EELB l Dross MModes, RI LTran D0udinot

• Previous Concurrence P 0FFICE PDId/LA<M Pb/PH SPLB/C PD M s NAME M0'NM J5 k h LMarsh

• JStN [

DATE N/l/97 h k97 4/28/97 $ / 20/97 0FFICIAL RECORD COPY

• DOCUMENT NAME: G:\SHEA\ PEACH \PECOTLAG.MTG

l l

l forced outages rather than waiting for the next Unit 3 refueling outage. In this instance, PEC0 estimated that the associated walkdowns for the PBAPS fire area wall modification would take approximately 80 man hours and would require extensive scaffolding. PECO indicated that it would consider performing the '

walkdowns during forced outages but that the frequency of and duration of

! forced outages at PBAPS and LGS in recent years did not make it likely that the walkdowns could be done prior to the refueling outage.

The staff did not obtain a clear understanding of the reasons for the l licensee's schedule. The staff closed by stating that it was interested in '

understanding in more detail the scope of the remaining work and indicated that it would seek additional dialogue or another meeting to review the scope of the remaining work.

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Jope h W. Shea, Project Manager Prbject Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-277/278 and 50-352/353

Enclosures:

1. Meeting Attendees

2. Licensee's Meeting Handout cc w/encls: See next page i

e i

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, PECO Energy Company Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 cc:

J. W. Durham, Sr., Esquire Chief-Division of Nuclear Safety Sr. ~ V.P. & General Counsel PA Dept. of PECO Energy Company Environmental Resources 2301 Market Street, S26-1 P.O. Box 8469 Philadelphia, PA 19101 Harrisburg, PA 17105-8469 PECO Energy Company ATTN: Mr. T. N. Mitchell, Vice President Board of Supervisors Peach Bottom Atomic Power Station Peach Bottom Township 1848 Lay Road R. D. #1 Delta, PA 17314 Delta, PA 17314 PECO Energy Company Public Service Commission of Maryland ATTN: Regulatory Engineer, A4-5S Engineering Division Peach Bottom Atomic Power Station Chief Engineer

, 1848 Lay Road 6 St. Paul Centre l Delta, PA 17314 Baltimore, MD 21202-6806

, Resident Inspector Mr. Richard McLean U.S. Nuclear Regulatory Commission Power Plant and Environmental

( Peach Bottom Atomic Power Station Review Division P.O. Box 399 Department of Natural Resources Delta, PA 17314 B-3, Tawes State Office Building Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Manager - Limerick Licensing, 62A-1 475 Allendale Road PECO Energy Company King of Prussia, PA 19406 965 Chesterbrook Boulevard Wayne, PA 19087-5691 Mr. Roland Fletcher Department of Environment Mr. Walter G. MacFarland, Vice President 201 West Preston Street Limerick Generating Station Baltimore, MD 21201 P.O. Box A Sanatoga, PA 19464 A. F. Kirby, III External Operations - Nuclear Plant Manager Delmarva Power & Light Company Limerick Generating Station l

P.O. Box 231 P.O. Box A Wilmington, DE 19899 Sanatoga, PA 19464

, Chairman l Board of Supervisors j of Limerick Township i

646 West Ridge Pike Linfield, PA 19468

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!. PECO Energy Company Peach Bottom Atomic Power Station, i Units 2 and 3 Limerick Generating Station,  !

Units 1 and 2  !

!~ Director - Site Support Services Senior Resident Inspector i Limerick Generating Station U.S. Nuclear Regulatory Commission P.O. Box A Limerick Generating Station Sanatoga, PA 19464 P.O. Box 596 Pottstown, PA 19464 Manager - Experience Assessment Library Limerick Generating Station U.S. Nuclear Regulatory Commission i P.O. Box A Region I Sanatoga, PA 19464 475 Allendale Road King of Prussia, PA 19406 l

l Senior Manager - Operations Dr. Judith Johnsrud l Limerick Generating Station National Energy Committee P.O. Box A l Sierra Club i l Sanatoga, PA 19464 433 Orlando Avenue State College, PA 16803 )

I Director - Site Engineering Manager-Peach Bottom Licensing l Limerick Generating Station PECO Energy Company P.O. Box A Nuclear Group Headquarters Sanatoga, PA 19464 Correspondence Control Desk P.O. Box No. 195 Manager-Business & Co-owner Affairs Wayne, PA 19087-0195 Public Service Electric and Gas i

Company Mr. George A. Hunger, Jr.

P.O. Box 236 Director-Licensing, MC 62A-1 Hancocks Bridge, NJ 08038-0236 PECO Energy Company Nuclear Group Headquarters PECO Energy Company Correspondence Control Desk Plant Manager P.O. Box No. 195 L

Peach Bottom Atomic Power Station Wayne, PA 19087-0195 1848 Lay Road

Delta, PA 17314 l Manager-Peach Bottom Licensing PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box 195 i Wayne, PA 19087-0195 i

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l Meeting Attendance List NRC/PECO Energy Company

. April 14, 1997 l ILAtiE ORGANIZATION

1. D. Fetters PECO Nuclear

2. J. Cotton PECO Nuclear

3. G. Hunger PECO Nuclear

4. G. Spinka PEC0 Nuclear )

5. C. Bruce PEC0 Nuclear l

6. A. Marie PEC0 Nuclear

7. A. Cross-Dial PECO Nuclear

8. C. Pragman PEC0 Nuclear

9. J. Hufnagel PEC0 Nuclear

10. D. Salek PEC0 Nuclear

11. J. Davenport PECO Nuclear j

12. A. Thadani NRR/ADT j

13. L. Marsh NRR/SPLB l

14. E. Connell NRR/SPLB l

15. D. Oudinot NRR/SPLB

16. R. Jenkins NRR/EELB

17. J. Shea NRR/PDI-2

18. F. Rinaldi NRR/PDI-2

19. M. Hart NRR/PDI-2

20. C. Poslusny NRR/PDI-2

21. L. Tran NRR

22. S. Maingi Pennsylvania Bureau of Radiation Protection

23. F. Emerson Nuclear Energy Institute

24. H. Abendroth Atlantic Electric

25. B. Knieriem Delmarva Power

26. E. Wenzinger NUS-LIS

27. T. Sutter Bechtel

28. E. Holub EPH Solutions Enclosure 1

l Fire Protection Comph.ance:

Thermo-Lag 330-1 Operability Resolution Schedule Review '

Presented To: The U. S. Nuclear Regulatory Commission ,

April 14,1997  !

Presented By: PECO Energy Company t

Limerick Generating Station Peach Bottom Atomic Power Station I I t

r Enclosure 2  :

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PECO Energy Participants m Presenters D.B. Fetters, Vice President, Station Support A.J. Marie, PSA Branch Manager C.D. Bruce, Fire Protection Program Manager G.L. Spinka, Thermo-Lag Project Manager a Attendees  ;

J.B. Cotton, Director, Nuclear Engineering G. .A. Hunger, Jr, Director, Licensing ,

A.E. Cross-Dial, Thermo-Lag Licensing Engineer D.A. Salek, LGS Modification Project Manager J.K. Davenport, PBAPS Modification Project Manager  ;

C.J. Pragman, Safe Shutdown Program Manager 2 af 23  !

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Purpose l

a Review PECO Energy's Thermo-Lag Resolution Schedule Limerick Generating Station (LGS) l Peach Bottom Atomic Power Station (PBAPS) a Present the Resolution Strategy i Accomplishments Remaining Issues a Provide Bases for the Resolution Schedule  :

3 of 23

Presentation Overview ,

m Resolution Approach u Project Configuration  ;

m Accomplishments ,

a Remaining Analysis Work

.l m Thermo-Lag Reduction Modifications  ;

a Open Resolution Issues  !

a Conclusion

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Resolution Approach Magnitude of the Issue m GL 92-08 Thermo-Lag 330-1 Fire Barriers Are Indeterminate; Compensatory Measures are in Place Scope of Encapsulated Raceways at LGS

> Approximately 4,800 Linear Feet

> 1 & 3-Hour Barriers

> Tray, Conduit, Boxes and Gutter Scope of Encapsulated Raceways at PBAPS

> Approximately 4,400 Linear Feet

> 3-Hour Barriers

• Conduit and Boxes sor23

Resolution Approach Ensure Safety; Cost Effectively Resolve The Issue m Integrate These Elements to Achieve the Goal of Ensuring Plant Safety, While Cost Effectively Resolving The Thermo-Lag Operability Issue Thermo-Lag Reduction Project

> Safe Shutdown Re-analysis IPEEE Fire Risk Analyses (GL 88-20, Sup. 4)

> Solutions Will Not Create Vulnerabilities Fire Barrier Assembly Configuration Evaluations

> Thermo-Lag Assembly Qualification for 1-Hour Assemblies

> Alternate Fire Barrier Material Evaluations for 3-Hour Barriers Participation In Industry Programs

> Support and Stay Current With the Industry Enhance Fire Protection Program Documentation 6 of 23

b Resolution Approach Ensure Safety; Cost Effectively Resolve The Issue

_ s i a Resolution Approach Underlying Schedule Assumption

> Unit Outages for Some Required Modifications

- Installation & Testing a Schedule Submitted via GL 92-08 RAI Responses a LGS Barriers in Full Regulatory Compliance April 1999 Coincides with Unit 2 Outage a PBAPS Barriers in Full Regulatory Compliance October 1999

> Coincides with Unit 3 Outage 7 of 23

Project Configuration ,

Common Resolution Approach for LGS and PBAPS m Integrated Project Using a Common Approach for Resolution at LGS and PBAPS  :

m VP Station Support, VP LGS, VP PBAPS a Sponsors Analyses - Director of Nuclear Engineering

> Engineering Branch (Discipline) Managers Licensing - Director of Licensing LGS Interface - Director Site Support Services

> Operations, System Managers PBAPS Interface - Director Site Support Services i

> Operations, System Managers Sof23

Project Configuration Common Resolution Approach for LGS and PBAPS m Thermo-Lag Project Manager Contractors with Specific Technical Expertise PECO Energy FP & SSD Program Managers PECO Licensing Outsourced & Inhouse Technical Tasks Outsourced & Inhouse Technical Reviews a Modifications LGS MOD Project Manager

> Lead Responsible Engineer PBAPS MOD Project Manager

> Lead Responsible Engineer l

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Accomplishments Safe Shutdown Re-Analysis m GL 88-20 Sup. 4, Fire Risk Analyses LGS Submitted June 1995 PBAPS Submitted May 1996 a Revised Safe Shutdown Configuration Identified Peer Reviews on Revised Configurations Potential 70% Reduction in Raceway Protection Manual Actions Deemed Reasonable by Operations

Major Modifications to Support Revised SSD Methodology Approved for Conceptual Design l

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Accomplishments Safe Shutdown Re-Analysis t

m Redocumenting Fire Protection & Safe Shutdown Analyses Improving Documentation

> For Existing and Revised Supporting Analyses Short Term: Maintain the Existing & Planned SSD Analysis Configurations Long Term: Facilitate Configuration Control I a Revised Safe Shutdown Configuration Documentation Method and System Logics Flow Path Analyses Component and Cable Selection 11 of 23

Accomplishments Thermo-Lag Barrier Qualification m Thermo-Lag 330-1 Fire Barrier Evaluations Evaluated Existing Assemblies at LGS & PBAPS

> Identified Bounded Assemblies Using NEI Application Guide

> Identified Unbounded Assemblies

- Derived PECO Energy Specific Test Requirements Performed PECO Energy Specific Test Verified LGS Barrier Construction - Internal Examination 1-Hour Barrier Upgrade Design Requirements Established m Ampacity Derating Factors Derived Derived for AllInstalled Assemblies

> Bounded By Industry Testing or,

> Heat Transfer Analyses Methodology 12 of 23

Accomplishments Thermo-Lag Issues  ;

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_ l a Composition Verified Using NEI Composition Testing Program  !

a Thermo-Lag Combustibility Improved Combustible Loading Analyses  ;

Structural Steel Survivability Analyses

> LGS: Complete t

> PBAPS: Initiated Elimination of Thermo-Lag from Combustible Free Zones

> Alternate Compliance Methodology Analysis  ;

a Fire Barriers Using Other Materials i Gutter Type Wireway 1-Hour Mecatiss Test Test Managed By Florida Power Corp.

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Accomplishments Participation in Industry Programs

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m NEI Thermo-Lag 330-1 Test Program '

Provided Input for Configurations Tested  ;

a NEI Application Guide Pilot Program Derived a Methodology to Use the Application Guide Presented to NRC December 1995 i a NEI Thermo-Lag Composition Testing Tested Material Samples From All Units m NEI Fire Protection Working Group  !

Director of Licensing i a Florida Power Corp. - Mecatiss Testing Tested Gutter Wireway in a Shared Test m Witness Installation of Other Fire Barrier Materials Darmat KM-1 & Mecatiss

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Remaining Analysis Work Issues With The Potential to Require Modifications m Application of Ampacity Derating Factors to Encapsulated Cables Cable Replacement or Reroute a Time Line Analyses Emergency Lighting Installation a Electrical Coordination MHIF* and Breaker / Fuse Coordination Reviews

> Breaker / Fuse Replacements a Structural Steel Survivability Analysis (PBAPS)

Fire Retardant Connic 0:1 Structural Steel Removal of Thenno-Lag

_ *MHIF - Multiple High Impe&. we Fault

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Thermo-Lag R' eduction Modifications Unit Outage Modification Process Schedule m Modifications Requiring Outage Work are Planned Per the Following Schedule To Ensure Quality Design & Configuration Control t Support Outage Planning MOD Status Schedule SMMG* 1 Initiate Conceptual Design SMMG* 2 Outage Start - 18 months Rev 0 Outage Start - 9 months PIMS Planned Outage Start - 6 months Ready to Work Outage Start - 3 months Unit Outage Start

• SMMG - Station Modification Management Group

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i Thermo-Lag Reduction Modifications Outage Modification Review Process Review Team m Coordinated by Thermo-Lag Project Manager m Site Modification Project Managers (Lead) m Appropriate System Engineers a Modification Engineers

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a Operations m Health Physics m Management Approval ofEvaluation

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Thermo-Lag Reduction Modifications Outage Modification Review Process Modification Review Criteria  !

a Installation Rcquirements '

t Non-Outage / System-Outage / Unit-Outage m Functional Testing Requirements Non-Outage / System-Outage / Unit-Outage m ALARA Concerns for Design, Installation, & Testing i

Non-Outage / System-Outage / Unit-Outage i

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Thermo-Lag Reduction Modifications LGS Modifications l

l l u Safety Related System Circuit Modifications i Requires Disabling Safety Systems to Install & Test Modifications l Requires Completion and Acceptance of Work During LCOs Risk: Assurance That the Modification & Testing can be Completed Within the LCO Unit Outage is Required for Higher Risk Modifications -

i a Enhance or Install Local Control Capability Provide Transfer and Control Capability for RHR Valves at MCC i

> Control Circuits can be modified during System Outages;

, Two (2) Valves are Pressure Isolation Valves i

- IST Requirement: Unit Outage Required for Functional Testing

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Unit 1 Outage, April 1998 Unit 2 Outage, April 1999.

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Thermo-Lag R' eduction Modifications LGS Modifications m Modifications Which Do Not Require Unit Outages Other Local Control and Instrumentation Enhancements Installation of Circuit Isolation Devices Re-Routing Safe Shutdown Cables

> Route Cables to Eliminate the Requirement for Cable Protection Raceway Fire Barrier Encapsulation Modifications Emergency Lighting for New Operator Manual Actions o -

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Thermo-Lag R' eduction Modifications PBAPS Modifications a Modification to Re-Define Fire Areas Fire Rate Structural Walls i

> Insights From IPEEE Fire Risk Analyses Unit Outage Required for Personnel ALARA Concerns

> Walkdowns - Unit 3 Outage,10/97

> Installation - Unit 3 Outage,10/99 m Modifications Which Do Not Require Unit Outages Modification to Increase Off-Site Power Availability Raceway Fire Barrier Encapsulation Modifications Emergency Lighting for New Operator Manual Actions

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Open Resolution Issues LGS and PBAPS m Issues With the Potential to Change the Resolution Strategy PBAPS: Exemption Request

> Install Suppression or 3-Hour Rated Fire Barriers LGS: Deviations

> Install Suppression or 3-Hour Rated Fire Barriers a Issues With the Potential to Impact the Resolution Schedule ,

Identification & Resolution of Safe Shutdown Analyses Anomalies Changes in Regulatory Safe Shutdown Implementation Guidance Identification of Additional Thermo-Lag 330-1 Issues NRC Acceptance of Ampacity Derating Methodology '

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Conclusion a Provided PECO Energy's Resolution Strategy a Provided Accomplishments and Statused the Remaining Work u Identified Risks Associated With Meeting the Existing Schedule ,

a PECO Energy Remains Committed to 1999 Resolution

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