NOC-AE-06002022, 60-Day Response to NRC Generic Letter 2006-03: Potentially Nonconforming Hemyc and MT Fire Barrier Configurations.

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60-Day Response to NRC Generic Letter 2006-03: Potentially Nonconforming Hemyc and MT Fire Barrier Configurations.
ML061510352
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/25/2006
From: Crenshaw J
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
+kBR1SISP20060621, GL-06-003, NOC-AE-06002022, STI: 32009570
Download: ML061510352 (4)


Text

I I Nuclear Operating Company South TC pr0ed FJCtJkIcialmngSbto PO Bar289 X&m't Tct 77483 ,

May 25, 2006 NOC-AE-06002022 10 CFR 50.48 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 60-Day Response to NRC Generic Letter 2006-03:

"Potentially Nonconforming Hemyc and MT Fire Barrier Configurations"

Reference:

NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations", dated April 10, 2006.

NRC Generic Letter (GL) 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006, was issued to request information from licensees regarding Hemyc and MT fire barriers, or other fire barriers using the materials and configurations described in the generic letter.

GL 2006-03 requested that all addressees provide a response that contains the following information:

1. Within 60 days of the date of this GL, provide thefollowing:
a. A statement on whether Hemyc or MTfire barriermaterialis used at their NPPsand whether it is relied upon for separationand/orsafe shutdown purposes in accordance with the licensingbasis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
b. A description ofthe controls that were used to ensure that otherfire barriertypes reliedon for separationof redundant trainslocated in a singlefire area are capable ofprovidingthe necessary level ofprotection. Addressees may reference their responsesto GL 92-08 to the extent that the responses address this specific issue.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570 4Yts

Page 2 NOC-AE-06002022

2. Within 60 days of the date of this GL, for those addressees that have installedHemyc or MTfire barriermaterials, discuss thefollowing in detail:
a. The extent of the installation (e.g., linearfeetof wrap, areas installed, systems protected),
b. Whether the Hemyc and/or MT installed in theirplants is conforming with their licensing basis in light of recentfindings, and if these recentfindings do not apply, why not,
c. The compensatory measures that have been implemented to provideprotection and maintain the safe shutdown function of affected areas of the plant in light of the recentfindings associatedwith Hemyc and MT installations, including evaluations to support the addressees' conclusions, and
d. A descriptionof and implementation schedulesfor, corrective actions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensing basis.
3. No later than December 1, 2007, addressees that identified in l.a. Hemyc and/orMT configurationsare requested toprovide a description of actions taken to resolve the nonconforming conditions described in 2.d.

STP Nuclear Operating Company (STPNOC) does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant trains located in a single fire area.

South Texas Project (STP) utilizes Thermo-Lag in one fire area only (i.e., Fire Area 7) to ensure that one train of safe shutdown cables, circuits and equipment remain free of fire damage in the event of a fire to satisfy 10 CFR 50, Appendix R, III, G requirements. Installation and inspection procedures verified that the barrier products were installed in a manner consistent with the testing and analyses to ensure test configurations and criteria would be bounding to the installed configurations. Deviations from the tested configurations were evaluated in accordance with Generic Letter 86-10, Supplement 1, providing reasonable assurance that the installed fire barrier systems would provide the necessary level of protection.

STPNOC inspects fire rated enclosures outside containment every 18 months to ensure ongoing integrity. Information regarding the utilization of Thermo-Lag in Fire Area 7 was previously reviewed by the NRC. (

Reference:

Letter ST-AE-NOC-000273, dated October 15, 1998 (TAC Nos. M92177 and M92178)). Test reports, other previous correspondence, and additional information are available on site.

Requests for information 2 and 3 do not apply to STP.

There are no NRC commitments in this letter.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570

r I Page 3 NOC-AE-06002022 If there are any questions regarding this submittal, please contact Ken Taplett at (361) 972-8416 or me at (361) 972-7074.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on !5 Za ca jJ4 ,-

John W. Crenshaw General Manager, Oversight A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • South Texas Project s Wolf Creek STI: 32009570

Page 4 NOC-AE-06002022 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Richard A. Ratliff Steve Winn Bureau of Radiation Control Christine Jacobs Texas Department of State Health Services Eddy Daniels 1100 West 49th Street NRG South Texas LP Austin, TX 78756-3189 Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN116 E. Alarcon Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570

Text

I I Nuclear Operating Company South TC pr0ed FJCtJkIcialmngSbto PO Bar289 X&m't Tct 77483 ,

May 25, 2006 NOC-AE-06002022 10 CFR 50.48 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 60-Day Response to NRC Generic Letter 2006-03:

"Potentially Nonconforming Hemyc and MT Fire Barrier Configurations"

Reference:

NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations", dated April 10, 2006.

NRC Generic Letter (GL) 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006, was issued to request information from licensees regarding Hemyc and MT fire barriers, or other fire barriers using the materials and configurations described in the generic letter.

GL 2006-03 requested that all addressees provide a response that contains the following information:

1. Within 60 days of the date of this GL, provide thefollowing:
a. A statement on whether Hemyc or MTfire barriermaterialis used at their NPPsand whether it is relied upon for separationand/orsafe shutdown purposes in accordance with the licensingbasis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
b. A description ofthe controls that were used to ensure that otherfire barriertypes reliedon for separationof redundant trainslocated in a singlefire area are capable ofprovidingthe necessary level ofprotection. Addressees may reference their responsesto GL 92-08 to the extent that the responses address this specific issue.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570 4Yts

Page 2 NOC-AE-06002022

2. Within 60 days of the date of this GL, for those addressees that have installedHemyc or MTfire barriermaterials, discuss thefollowing in detail:
a. The extent of the installation (e.g., linearfeetof wrap, areas installed, systems protected),
b. Whether the Hemyc and/or MT installed in theirplants is conforming with their licensing basis in light of recentfindings, and if these recentfindings do not apply, why not,
c. The compensatory measures that have been implemented to provideprotection and maintain the safe shutdown function of affected areas of the plant in light of the recentfindings associatedwith Hemyc and MT installations, including evaluations to support the addressees' conclusions, and
d. A descriptionof and implementation schedulesfor, corrective actions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensing basis.
3. No later than December 1, 2007, addressees that identified in l.a. Hemyc and/orMT configurationsare requested toprovide a description of actions taken to resolve the nonconforming conditions described in 2.d.

STP Nuclear Operating Company (STPNOC) does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant trains located in a single fire area.

South Texas Project (STP) utilizes Thermo-Lag in one fire area only (i.e., Fire Area 7) to ensure that one train of safe shutdown cables, circuits and equipment remain free of fire damage in the event of a fire to satisfy 10 CFR 50, Appendix R, III, G requirements. Installation and inspection procedures verified that the barrier products were installed in a manner consistent with the testing and analyses to ensure test configurations and criteria would be bounding to the installed configurations. Deviations from the tested configurations were evaluated in accordance with Generic Letter 86-10, Supplement 1, providing reasonable assurance that the installed fire barrier systems would provide the necessary level of protection.

STPNOC inspects fire rated enclosures outside containment every 18 months to ensure ongoing integrity. Information regarding the utilization of Thermo-Lag in Fire Area 7 was previously reviewed by the NRC. (

Reference:

Letter ST-AE-NOC-000273, dated October 15, 1998 (TAC Nos. M92177 and M92178)). Test reports, other previous correspondence, and additional information are available on site.

Requests for information 2 and 3 do not apply to STP.

There are no NRC commitments in this letter.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570

r I Page 3 NOC-AE-06002022 If there are any questions regarding this submittal, please contact Ken Taplett at (361) 972-8416 or me at (361) 972-7074.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on !5 Za ca jJ4 ,-

John W. Crenshaw General Manager, Oversight A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • South Texas Project s Wolf Creek STI: 32009570

Page 4 NOC-AE-06002022 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Richard A. Ratliff Steve Winn Bureau of Radiation Control Christine Jacobs Texas Department of State Health Services Eddy Daniels 1100 West 49th Street NRG South Texas LP Austin, TX 78756-3189 Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN116 E. Alarcon Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek STI: 32009570