ULNRC-05294, Day Response to NRC Generic Letter 2006-03, Potentially Nonconformance Hemyc and MT Fire Barrier Configurations.

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Day Response to NRC Generic Letter 2006-03, Potentially Nonconformance Hemyc and MT Fire Barrier Configurations.
ML061570382
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/01/2006
From: Keith Young
AmerenUE
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
+kBR1SISP20060621, GL-06-003, GL-86-010, ULNRC-05294
Download: ML061570382 (4)
v • d • e


Text

Union Electric PO Box 620 Callaway Plant Fulton, MO 65251 June 1, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Ladies and Gentlemen: ULNRC-05294 WAmeren DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 U1f UNION ELECTRIC CO.

60-DAY RESPONSE TO NRC GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" 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 theirNPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis, including whether Hemyc or MT is creditedin other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
b. A descriptionof the controls that were used to ensure that otherfire barriertypes relied on for separationof redundant trains located in a singlefire area are capable ofproviding the necessary level of protection.Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

a subsidiatyof Amermn Corporation

ULNRC-05294 June 1, 2006 Page 2

2. Within 60 days of the date of this GL, for those addresseesthat have installedHemyc or MTfire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areas installed, systems protected),
b. Whether the Hemyc and/orMT installed in theirplants is conforming with their licensing basis in light of recentfindings, and if these recent findings do not apply, why not,
c. The compensatory measures that have been implemented to provide protection and maintain the safe shutdownfunction of affected areas of the plant in light of the recentfindings associatedwith Hemyc and MT installations,includingevaluationsto support the addressees' conclusions,and
d. A descriptionof and implementation schedulesfor, correctiveactions, includinga description of any licensingactions 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 requestedto provide a descriptionof actions taken to resolve the nonconforming conditions describedin 2.d.

Callaway Plant does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant trains located in a single fire area.

Callaway Plant utilizes Darmatt-KM-1 as raceway fire barrier protection for redundant trains located in the same fire area that satisfies 10 CFR 50, Appendix R, III, G requirements.

Callaway Plant also has one location that utilizes Silicone RTV foam as fire stops for intervening non-safety related cable trays located within a 20 foot separation zone. Callaway committed to the installation of these fire stops during the construction phase. These fire stops were reviewed and found acceptable in NUREG 0830, Safety Evaluation Report related to the operation of Callaway Plant Unit No. 1, Supplement 3.

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 and provide reasonable assurance that the installed fire barrier systems would provide the necessary level of protection.

.1) 1 ULNRC-05294 June 1, 2006 Page 3 AmerenUE inspects fire barriers every 18 months to ensure ongoing integrity.

Test reports, previous correspondence, and additional information are available on site.

Requests for information 2 and 3 do not apply to Callaway Plant.

In accordance with the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(0, AmerenUE is submitting this letter under oath and affirmation, as clarified in Regulatory Issue Summary (RIS) 2001-18, "Requirements for Oath or Affirmation."

This letter does not contain any commitments. If you have questions regarding this response, please contact D. E. Shafer at 314-554-3104.

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

Sincerely, Executed on June 1, 2006 M eD.- Rgu Manager - Regulatory Affairs PMB/jdg

A a ULNRC-05294 June 1, 2006 Page 4 cc: Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

Text

Union Electric PO Box 620 Callaway Plant Fulton, MO 65251 June 1, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Ladies and Gentlemen: ULNRC-05294 WAmeren DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 U1f UNION ELECTRIC CO.

60-DAY RESPONSE TO NRC GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" 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 theirNPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis, including whether Hemyc or MT is creditedin other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
b. A descriptionof the controls that were used to ensure that otherfire barriertypes relied on for separationof redundant trains located in a singlefire area are capable ofproviding the necessary level of protection.Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

a subsidiatyof Amermn Corporation

ULNRC-05294 June 1, 2006 Page 2

2. Within 60 days of the date of this GL, for those addresseesthat have installedHemyc or MTfire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areas installed, systems protected),
b. Whether the Hemyc and/orMT installed in theirplants is conforming with their licensing basis in light of recentfindings, and if these recent findings do not apply, why not,
c. The compensatory measures that have been implemented to provide protection and maintain the safe shutdownfunction of affected areas of the plant in light of the recentfindings associatedwith Hemyc and MT installations,includingevaluationsto support the addressees' conclusions,and
d. A descriptionof and implementation schedulesfor, correctiveactions, includinga description of any licensingactions 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 requestedto provide a descriptionof actions taken to resolve the nonconforming conditions describedin 2.d.

Callaway Plant does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant trains located in a single fire area.

Callaway Plant utilizes Darmatt-KM-1 as raceway fire barrier protection for redundant trains located in the same fire area that satisfies 10 CFR 50, Appendix R, III, G requirements.

Callaway Plant also has one location that utilizes Silicone RTV foam as fire stops for intervening non-safety related cable trays located within a 20 foot separation zone. Callaway committed to the installation of these fire stops during the construction phase. These fire stops were reviewed and found acceptable in NUREG 0830, Safety Evaluation Report related to the operation of Callaway Plant Unit No. 1, Supplement 3.

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 and provide reasonable assurance that the installed fire barrier systems would provide the necessary level of protection.

.1) 1 ULNRC-05294 June 1, 2006 Page 3 AmerenUE inspects fire barriers every 18 months to ensure ongoing integrity.

Test reports, previous correspondence, and additional information are available on site.

Requests for information 2 and 3 do not apply to Callaway Plant.

In accordance with the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(0, AmerenUE is submitting this letter under oath and affirmation, as clarified in Regulatory Issue Summary (RIS) 2001-18, "Requirements for Oath or Affirmation."

This letter does not contain any commitments. If you have questions regarding this response, please contact D. E. Shafer at 314-554-3104.

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

Sincerely, Executed on June 1, 2006 M eD.- Rgu Manager - Regulatory Affairs PMB/jdg

A a ULNRC-05294 June 1, 2006 Page 4 cc: Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

Text

Union Electric PO Box 620 Callaway Plant Fulton, MO 65251 June 1, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Ladies and Gentlemen: ULNRC-05294 WAmeren DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 U1f UNION ELECTRIC CO.

60-DAY RESPONSE TO NRC GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" 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 theirNPPs and whether it is relied upon for separationand/orsafe shutdown purposes in accordancewith the licensing basis, including whether Hemyc or MT is creditedin other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).
b. A descriptionof the controls that were used to ensure that otherfire barriertypes relied on for separationof redundant trains located in a singlefire area are capable ofproviding the necessary level of protection.Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

a subsidiatyof Amermn Corporation

ULNRC-05294 June 1, 2006 Page 2

2. Within 60 days of the date of this GL, for those addresseesthat have installedHemyc or MTfire barriermaterials,discuss the following in detail:
a. The extent of the installation(e.g., linearfeet of wrap, areas installed, systems protected),
b. Whether the Hemyc and/orMT installed in theirplants is conforming with their licensing basis in light of recentfindings, and if these recent findings do not apply, why not,
c. The compensatory measures that have been implemented to provide protection and maintain the safe shutdownfunction of affected areas of the plant in light of the recentfindings associatedwith Hemyc and MT installations,includingevaluationsto support the addressees' conclusions,and
d. A descriptionof and implementation schedulesfor, correctiveactions, includinga description of any licensingactions 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 requestedto provide a descriptionof actions taken to resolve the nonconforming conditions describedin 2.d.

Callaway Plant does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant trains located in a single fire area.

Callaway Plant utilizes Darmatt-KM-1 as raceway fire barrier protection for redundant trains located in the same fire area that satisfies 10 CFR 50, Appendix R, III, G requirements.

Callaway Plant also has one location that utilizes Silicone RTV foam as fire stops for intervening non-safety related cable trays located within a 20 foot separation zone. Callaway committed to the installation of these fire stops during the construction phase. These fire stops were reviewed and found acceptable in NUREG 0830, Safety Evaluation Report related to the operation of Callaway Plant Unit No. 1, Supplement 3.

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 and provide reasonable assurance that the installed fire barrier systems would provide the necessary level of protection.

.1) 1 ULNRC-05294 June 1, 2006 Page 3 AmerenUE inspects fire barriers every 18 months to ensure ongoing integrity.

Test reports, previous correspondence, and additional information are available on site.

Requests for information 2 and 3 do not apply to Callaway Plant.

In accordance with the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(0, AmerenUE is submitting this letter under oath and affirmation, as clarified in Regulatory Issue Summary (RIS) 2001-18, "Requirements for Oath or Affirmation."

This letter does not contain any commitments. If you have questions regarding this response, please contact D. E. Shafer at 314-554-3104.

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

Sincerely, Executed on June 1, 2006 M eD.- Rgu Manager - Regulatory Affairs PMB/jdg

A a ULNRC-05294 June 1, 2006 Page 4 cc: Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

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