ML20217E441

Discusses Licensee 970228 Revised Response to SE Open Items on Plant,Unit 1 Re thermo-lag Cable Functionality Issues. Requests That Revs to CPSES Engineering Rept ER-ME-067 Be Provided within 30 Days of Receipt of Ltr

ML20217E441
Person / Time
Site:	Comanche Peak
Issue date:	10/01/1997
From:	Clifford J NRC (Affiliation Not Assigned)
To:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
TAC-M85536, NUDOCS 9710070032
Download: ML20217E441 (6)

Text

_

, g....g co-W5 k UNITE 3 STATES

, s* ,}j NUCLEAR RE^ULATCRY CZMMISS12N WASHINGTON. D.C. 2004H001 k *.4..*/ October 1,1997 Mr. C. Lance Terry TU Electric Group Vice President, Nuclear Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043

SUBJECT:

RESPONSE TO SAFETY EVALUATION OPEN ITEMS ON COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 REGARDING THERMO-LAG CABLE FUNCTIONAllTY ISSUES (TAC NO. M85536)

REFERENCES:

1. NRC letter from Mr. Timothy J. Polich to Mr. C. Lance Terry dated May 22, 1996

2. TU Electric letter from Mr. C. Lance Terry, to NRC dated October 24, 1996 (TXX-96414)

3. Transcript of meeting between the NRC and Texas

, Utilities Electric Company held on December 5, 1996 at the NRC Region IV Office in Arlington, Texas

4. TV Electric letter from Mr. C. Lance Terry, to NRC dated February 28, 1997 (TXX-97047)

Dear Mr. Terry:

j By letter dated February 28, 1997 TXX-97047 (Reference 4 , Texas Utilities  !

Electric Company (TV Electric) submitted revised response)s to the seven open items in the Nuclear Regulatory Commission (NRC) staff's safety evaluation on Thermo-Lig fire barriers installed at Comanche Peak Steam Electric Station (CPSES) Unit I dated May 22 1996 (Reference 1). TV Electric's previous responses to the seven open, items, dated October 24, 1996 TXX-96414 (Reference 2), were discussed in detail during a meeting at the Region IV office in Arlington Texas on December 5,1996 (Reference 3). During the course of discussions at that meeting, your response to item 7 was found to be adequate, but your responses to the remaining six items required additional information for completion of the review by the NRC staff. A path to resolution for the six remaining items appeared to have been defined and agreed upon during that meeting. The staff has completed the review of Reference 4 and finds that Open items 2, 5, 6, and 7 have been addressed adequately and are considered closed (as indicated in %e Enclosure). However, Items 1, 3, and 4 remain open.

During the December meeting, the staff discussed Open Item 1 (thermal mass) at length (pages 12 to 33 of Reference 3). The staff finds your response to this \y item in Reference 4 to be contrary to those discussions. Specifically, the staff stated that your revised response should: discuss the testing that you have done for Unit I and Unit 2 and how the tests are the same; describe your g I

understanding of prior agreements made with the staff that you were supposed -

to test fire barriers this way and no other way; and also provide the Wn bNkb,$lll!l G EE GENER C@V 9710070032 971007 PDR P ADOCK 05000445 pon

Mr. C. Lance Terry references where those agreements are documented. Yet Reference 4 states that TU Electric performed an evaluation that demonstrated that reductions in cable mass below the values tested will not adversely impact the functionality of the cables. During the December 5, 1996, meeting TU Electric did not indicate l that cable functionality evaluations were to be the basis for determining the acceptability of the Thermo-Lag installation at CPSES, Unit I when the cable fill is less than the tested configuration. The information requested by the staff during the meeting was not included in the February 28, 1997, submittal (Reference 4).

During a phone conversation on September 16, 1997, your staff indicated that TU Electric has chosen to pursue the cable functionality option to resolve Item 1 and that TV Electric would contact the NRC if that position changed.

The NRC staff stated that the cable functionality review would delay resolution of the issue. Further your staff stated that the information requested by the NRC staff at the December meeting could not be located in any docketed correspondence (i.e., that the testing was the same at Units I l and 2).

With regard to Open Items 3 and 4, the staff finds that the TV Electric explanation also appears to be contrary to discussions during the December  !

meeting (pages 47 and 54 c.f Reference 3). Specifically, in that meeting the i staff stated (pages 51 anct 52 of Reference 3) that the fire stop was an integral part of the barrier and should meet the acceptance criteria specified in the October 29, 1992, latter, and that the use of the criteria specified in IEEE-634 was not acceptabit. Yet Reference 4 states that in CPSES Engineering Report ER-ME-067, Rev. 4, Attachment 2 to Appendix F, Silicone Elastomer and.

Thermo-Lag fire stop material were considered acceptable based on tests conducted in accordance with the criteria specified in IEEE-634 which is contrary to the October 29, 1992, criteria. These test reports have not been provided by TV Electric for NRC staff review. However, in reference 4 you stated that Silicone foam material will be removed or augmented with acceptable fire stop material via Design Modification 97-014. This response does not address the acceptance criteria used for the evaluation of Silicone Elastr.er or Thermo-Lag material used in fire stops at CPSES, Unit 1. Page 11 of the original safety evaluation (Reference 1) discussed the same issue.

During the September 16, 1997, call your staff explained that it was not the intent of TU Electric to use all of the tests referenced in CPSES Engineering Report ER-ME-067, Rev.1. Attachment 2 to Appendix F as qualifying tests for Unit 1. Your staff agreed to eliminate any unnecessary tests from ER-ME-067, Rev. 4, and to supply the NRC any referenced test reports not previously reviewed.

The conversations on September 16, 1997, were helpful in clarifying TV Electric's positions on the three remaining open items. It is the staff's understanding that TV Electric will make changes to the information pretiously

,-,,,-..,-,_-_._------,,,,.,_-,-.-.m___.a

O Mr. C. Lance Terry submitted. Please provide within thirty days nece'ipt of this letter your revisions to CPSES Engineering Report ER-ME-06's, tnd any change in position regarding the optione to resolve any of the thre6. emaining items. If you have further questions regarding these-open items .antact Timothy J. Polich at 301-415-1038.

Sincerely, ORIGINAL SIGNED BY:

James W. Clifford, Acting Director Project Directorate IV-1 l Division of Reactor Projects III/IV i l Office of Nuclear Reactor Regulation Docket No. 50-445

Enclosure:

List of Opea items I

cc W/ encl: See next page DISTRIBUTION:

Docket File. 0GC PUBLIC GHill (4)

ACRS TPolich (2) TGwynn, RIV PDIV-1 r/f CHawes JClifford EAdensam (EGAl) LBMarsh KSWest Econnell JCalvo PGill RJenkins LTran Document Name: CP85536.LTR See previous concurrence

• OFC PM/PD4-1 LA/PD4-1 SPLB* EELB* (A)PD4-1 NAME TPolich/ 7 CHawes d/g LBMarsh JCulvo JClifford DATE 9 47t /97 9 /2 I 97 9/9/97 9/9/97 to/l /97 COPY YFS/N0 [ES)NO ES YES/NO YES/NO YES/NO

~ OFFICIAL RECORD COPY

Hr. C. Lance Terry submitted.

revisions to CPSES Engineering Report ER-ME-067, a regarding the options to resolve any of the three remaining on items have further questions regarding these open items 301-415-1038.

. If you contact Timothy J

. Polich at Sincerely.

J es W. Cliffo , Acting Director Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket No. 5)-345

Enclosure:

List if Open items ec w/ encl: 5se rixt page i

l

\

\

i

• Mr. C. Lance Terry TV Electric Company Comanche Peak, Units 1 and 2 cc: I' Senior Resident inspector U.S. Nuclear Regulatory Commission Honorable Dale McPherson P. O. Box 1029 County Judge Granbury, TX 76048 P. D. Box 851 Glen Rose, TX 76043 Regional Administrator, Region IV U.S. Nuclear Regulator Office of the Governor 611 Ryan Plaza Drive, y Commission ATTN: John Howard, Director Arlington, TX 76011 Suite 400 Environmental and Natural Resources Policy Mrs. Juanita Ellis, President P. O. Box 12428 Austin, TX 78711 Citizens Association for Sound Energy 1426 South Polk Dallas, TX 75224 Arthur C. Tate, Director Division of Compliance & Inspection Mr. Roger D. Walker Bureau of Radiation Control TV Electric .

Texas Department of Health Regulatory Affairs Manager 1100 West 49th Street P. O. Box 1002 Austin, TX 78756-3189 Glen Rose, TX 76043 I

Texas Utilities Electric Company

( c/o Bethesda Licensing

) 3 Metro Center, Suite 810 1 Bethesda, MD 20814

{ George L. Edgar Esq.

1 Morgan, Lewis & Bockius l 1800 M Street, N.W.

J Washington, DC 20036-5869 1

4

. pen Icom 1:

Raceway at CPSES Unit I where the total enclosed thermal mass is less than the total enclosed thermal mass of the tested configurations. This item remains open.

Open Item 2:

The hose stream performance of the Thermo-Lag

• Box Assembly" tested in Scheme 11-4. The licensee has reinforced the joints of this assembly similar to those utilized for Scheme 12-1, 14-1 and 15-1. This item is closed.

Open Item 3:

Thermo-Lag fire stops installed in cable trays at CPSES Unit 1. This item remains open.

Open Item 4:

Silicone foam fire stops installed in cable trays at CPSrS Unit 1, where the qualification is based on fire tests that used silicone elastomer. This item remains open.

Open Item 5:

The use of Test Scheme 9-3 (1 1/2-inch and 2-inch conduits) at CPSES Unit 1.

The licensee has upgraded the 11/2-inch conduits installations in accordar, e with the design qualified in Scheme 9-2. The 2-inch conduits were found acceptable based on the licensee's cable functionality evaluations. This item is closed.

Open Item 6:

The use of Test Scheme 11-2 (2-inch air drop) at CPSES Unit 1. The licensee has upgraded the 2-inch air drops in accordance with the design qualified in Scheme 9-2. This item is closed.

Open Item 7:

The use of Test Scheme 15-2 for cables smaller than 750 KcMil (MCM). The licensee does not use this scheme for cables smaller than 750 MCM. This itein is closed.

ENCLOSURE

+