View source for 3F0795-02, Forwards Answers to NRC Questions on Previous Responses Re GL 92-08, Thermo-Lag 330-1 Fire Barriers, Including Proprietary Addl Info on Derivation & Use of EPRI TC Tools. Proprietary Info Withheld Per 10CFR2.790

{{Adams
| number = ML20086E593
| issue date = 07/06/1995
| title = Forwards Answers to NRC Questions on Previous Responses Re GL 92-08, Thermo-Lag 330-1 Fire Barriers, Including Proprietary Addl Info on Derivation & Use of EPRI TC Tools. Proprietary Info Withheld Per 10CFR2.790
| author name = Beard P
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0795-02, 3F795-2, GL-92-08, GL-92-8, NUDOCS 9507120118
| package number = ML19325F566
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 24
}}

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{{#Wiki_filter:I Florida Power CORPORATION
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July 6, 1995 3F0795-02 U. S. Nuclear Regulatory Commission Attention:    Document Control Desk Washington, DC      20555

==Subject:==
Answers to NRC Staff Questions on Previous Responses Regarding Generic Letter 92-08

==Reference:==
A. FPC to NRC letter, 3F0195-03, dated January 6, 1995 B. FPC to NRC letter, 3F0395-25, dated March 28, 1995 C. NRC to FPC letter, 3N0495-10, dated April 7, 1995 D. FPC to NRC letter, 3F0595-08, dated May 17, 1995 E. NRC to FPC letter, 3N0595-06, dated May 12, 1995 l
Dear Sir.                                                                                                       ]
Florida Power Corporation (FPC) is providing the information included in Attachments 1, 2, and 3 in answer to the NRC Staff questions contained in Reference E. Attachment I contains answers to the specific questions.
Attachment 2 contains additional information on the EPRI TC Tools in response to questions raised in our public meeting of April 25, 1995 on the subject. Attachment 3 contains supplementary information on the NRC Staff questions      in Reference C regarding FPC's tests of Thermo-Lag /Mecatiss fire barriers in France. We anticipate that the information                                       ;
contained in Attachment 3 will be sufficient for the NRC Staff to approve those test results as demonstrating rated I hour and 3 hour barrier systems. The bounded configurations for which we are seeking approval are described in Reference D.
FPC is continuing with a multi-phase approach to the resolution of Thermo-                                      ;
Lag fire barrier issues at CR-3.           We expect that the final resolution                        q(        '
actions will include abandoning some of the existing Thermo-Lag barriers, circuit re-routing, upgrading with Mecatiss overlay, removal of Thermo-Lag followed by reinstallation of Mecatiss barriers, and exemption requests.                                  I Q. Q}          \
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l U. S. Nuclear Regulatory Commission                                          i 3F0794-02 Page 2 The choice of a particular alternative will be based on considerations such as immediate and long term costs, safety benefit, and impact on other plant activities. Those choices cannot be made until the feasibility and cost of each option is determined and a comparison is made. Until a final solution is determined for each fire area, it is impossible to be certain which of the existing Thermo-Lag fire barriers will remain in place; thus, some of the information requested by Reference E is not available at this time. Where this is the case, we have so noted and have committed to provide the additional information when it is available.
FPC is submitting an affidavit requesting the technical essays contained in Attachment 2 be withheld from public disclosure on the grounds that the attachment contains information proprietary to FPC. The affidavit is provided in accordance with 10 CFR 2.790 (b)(1). The Public Meeting held between FPC and the NRC on April 25, 1995 summarized the technical conclusions contained therein in such a manner as to facilitate public understanding and involvement.
Please contact W. L. Rossfeld at (904) 563-4374 if you have any questions concerning this letter or the attachment.
Sincerely,
      .M Beard, Jr.
Senior Vice President Nuclear Operations PMB/SCP:ff xc:   Regional Administrator, Region II NRR Project Manager Senior Resident Inspector l

U. S. Nuclear Regulatory Commission 3F0795-02 AFFIDAVIT OF P. M. BEARD. JR.
A. My name is P. M. Beard, Jr.         I am the Senior Vice President - Nuclear Or erations for the Florida Power Corporation (FPC), and as such I am authorized to execute this affidavit.
B.          ~
                  'amiliar with the criteria set forth in Title 10 of the Code of a    al Regulations, Part 2.790 (10 CFR 2.790), to determine whether
: s. e .ain information of FPC is proprietary.
C. The following information is provided to demonstrate that the provisions of 10 CFR 2.790 have been considered:
(i)     The information contained in Attachment 2 has been held in confidence by FPC. Copies of the document are clearly identified as proprietary by FPC.         In addition, should FPC transmit the information in Attachment 2 to an external agency, the recipient will be requested to hold the information as proprietary, as FPC has requested the Nuclear Regulatory Commission to so do.
(ii)    FPC applied the following criteria in determining whether the information in Attachment 2 should be classified as proprietary.
Information may be classified as proprietary if one or more of these criteria are met:
: a. The information reveals data or material concerning FPC research or development plans or programs of present or potential competitive advantage to FPC.
: b. The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.
: c. The information consists of test data or other similar data concerning a process, method, or component, the application of which results in a competitive advantage to FPC.
: d. The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to FPC.
FPC has determined that the document listed in Attachment 2, contains information which falls within one or more of the criteria enumerated above.                                                         l 1
i l

U. S. Nuclear Regulatory Commission                                                                                                          l 3F0795-02                                                                                                                                  ]
        - AFFIDAVIT OF P. M. BEARD.'JR. (Cont'd.)
(iii) The document listed as Attachment 2, which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document and the information contained therein be withheld from public' disclosure.
(iv) The information contained in Attachment 2 is not available in the open literature and to the best of our knowledge is not known by current or potential domestic or foreign competitors of FPC.
(v)                The information contained in Attachment                             2,  if not held in confidence, could cause harm to FPC in that a competitor could use the information for their gain without having expended the financial and technical resources expended by FPC.                               FPC has expended significant time, money, and manpower to compile this information in the form contained therein.                                                                                     "
D. I have personally reviewed the document listed as Attachment 2 and have found that i t is considered proprietary by FPC because it contains information which falls within one or more of the criteria enumerated in Paragraph C. Attachement 2 contains information which affords FPC an opportunity to obtain a competitive advantage over those who may wish to.
know or use the information contained in the document.
ry) k P. 4. Beard, Jr.
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U. S. Nuclear Regulatory Commission 3F0795-02 STATE OF FLORIDA COUNTY OF CITRUS P. M. Beard, Jr. states that he is the Senior Vice President, Nuclear Operations for Florida Power Corporation; that he is authorized on the part of said company                         i to sign and file with the Nuclear Regulatory Commission the information attached                          '
hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
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Senior Vice President Nuclear Operations P. M. Beard, Jr., personally known to me. Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this ~7% day of July, 1995.
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Notary Public, State of Florida at large Notary Public, State of FForida at Large My Commission Expires [l,conm],syynypyn oy y,8,w, s9g.
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ATTACHMENT 1 i
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U. S. Nuclear Regulatory Commission                                  Attachment 1 3F0795-02 Page 1 cf 7 Crystal River Unit 3 Docket No. 50-302                                ,
Followup Request for Additional Information Regarding               l Generic Letter 92-08 "Thermo-Lag 330-1 Fire Barriers" 1.0 Schedules Our September 23, 1994, RAI requested information regarding important barrier parameters, Thermo-Lag barriers outside the scope of the Nuclear Energy Institute (NEI) program, ampacity derating, and schedules. Your January 6,1995 submittal did not provide a schedule for the completion of corrective actions necessary to resolve the Thermo-Lag issues. Please submit a schedule for completion of all corrective actions.
FPC Response In Reference A, FPC provided a schedule of activities for the evaluation of various options currently being pursued for the resolution of Thermo-Lag Fire barrier issues at CR-3. We provided a date by which those evaluation activities will be complete, and by which time we will formulate a final action plan. We committed to provide the schedule for implementation of the final action plan by December 31, 1995. Since we have not yet completed our evaluation of options or created a final action plan, a more definitive schedule of subsequent completion dates is not available. However considering the range and mix of corrective actions that are likely to be included in our final action plan, we believe that all actions will be complete by December 31, 2000. This schedule will encompass two refueling outages during which we can install plant modifications which will eliminate numerous Thermo-Lag barriers at CR-3. Furthermore this will allow sufficient time for submittal of exemption requests and their consideration by the NRC Staff.
2.0 EPRI TC Project Your March 28, 1995 submittal stated that you are participating in the Electric Power Research Institute (EPRI) Cable Wrap Fire Barrier Tailored Collaboration (TC) project to address Thermo-Lag barriers outside the scope of the NEI fire endurance test program.        This project is intended to develop tools to quantitatively determine the protection provided by plant-unique barriers that are not bounded by the NEI tests.        The tools employ enhanced fire modeling techniques that are based on the EPRI Fire ',duced Vulnerability Evaluation (FIVE) methodology. On the basis of the resul ' of this effort, you stated that you may (1) request exemptions to accept exis,ing Thermo-Lag configurations, or (2) implement corrective actions to return Thermo-Lag barriers to compliance with NRC fire protection requirements.
In a public meeting with us on April 25, 1995, you presented the EPRI TC methodology.      You have not submitted the EPRI TC methodology for our review.
Therefore, we cannot make a determination regarding the acceptability of this approach. Supplement I to Generic Letter 86-10 provided the staff guidance regarding the use of fire test programs to qualify the various configurations of fire barrier assemblies installed in the plant and the information to be l

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U. S. Nuclear Regulatory Commission                                      Attachment 1-3F0795-02 Page 2 of 7 submitted to support requests for exemptions from NRC fire protection requirements. Please submit additional information, as discussed at the April 25, 1995, meeting regarding the EPRI TC fire modeling effort and its application to Thermo-Lag fire barriers at Crystal River Unit 3 (CR3).
FPC Response It is not FPC's plan to submit the EPRI TC Tools Methodology for review and approval by the NRC as a ' topical report.' Instead, FPC will utilize the tools in support of specific exemption requests as appropriate for a particular fire                 ;
area under consideration. The EPRI TC Tools methodology will be provided with our specific exemptions to the extent the tools support the exemption.                      We i
anticipate that specific questions will arise during the NRC staff's review of our exemption requests, and we will be prepared to respond to~those questions at that time. FPC feels that this approach constitutes a more effective use of all the technical resources involved including FPC's, EPRI's, and the NRC's.
However, based on the discussion during our public meeting of April 25,1995, and questions that arose, additional information on the derivation and use of the EPRI TC Tools is provided in Attachment 2. FPC will be prepared to meet with the NRC Staff to resolve any remaining questions following submittal of our first exemption request.
3.0 Mecatiss Upgrades In a letter of October 31, 1994, you informed us of your intention to perform tests of Thermo-Lag fire barriers that are upgraded with an overlay of the Mecatiss fire barrier product. By {{letter dated|date=March 6, 1995|text=letter dated March 6,1995}}, you submitted the results of your scoping tests of the Mecatiss upgraded barriers for our review and indicated that you plan to perform additional fire endurance tests of the Mecatiss upgraded configurations. By {{letter dated|date=April 7, 1995|text=letter dated April 7,1995}}, we provided our comments on the test report and requested additional information regarding the fire test program for the qualification of Mecatiss upgraded Thermo-Lag fire barriers for use at CR3. Please provide the requested information.
FPC Response FPC provided answers to the NRC staff's questions on our Mecatiss fire barrier tests in Reference D . Additional information is provided in Attachment 3.
4.0 Chemical Analysis Your March 28, 1995, submittal stated that you will perform chemical tests of eight Thermo-Lag samples (pyrolysis gas chromatography in accordance with ASTM D3452) as part of the NEI generic chemical test program. You also stated that NEI will submit to us a written report that documents the results of the test program. You do not plan to submit a report.
Pyrolysis gas chromatography only provides data on the organic components of a sample. Inorganic components, which may be important to the material performance as a fire barrier, are not evaluated. In a public meeting with NEI on March 29, 1995, which was attended by your representatives, NEI indicated that it was considering several options for additional testing and analysis of both organic and inorganic Thermo-Lag 330-1 constituents and will inform us about the revised
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U. S. Nuclear Regulatory Commission                                                   Attachment 1 3F0795-02 Page 3 of 7 program.         Subject to our review and acceptance of the revised NEI program, and the testing of a sufficient number of samples, we find your participation in the NEI program acceptable for obtaining the data and information needed to evaluate the chemical consistency of Thermo-Lag 330-1 materials on a plant specific basis.
In our December 28, 1994 RAI, we requested you to submit a written report that provides the results of the analyses and any changes to previously submitted plans or schedules that result from the test program. Accordingly, please submit a report independent of the NEI report that is specific to the Thermo-Lag materials installed at CR3. You should also submit your basis for determining that eight samples of Thermo-Lag are sufficient to ensure that the data obtained from the industry chemical test program is applicable to the total population of Thermo-Lag installed at CR3.
FPC Response At this time FPC cannot provide final answers to this question, but offers the following current information. Initial results of chemical composition testing of five CR-3 material samples for organic constituents, show that they are similar to each other in chemical composition, and are similar to samples from other utilities. The test results for the remaining three CR-3 samples are not yet available. FPC is now awaiting the results of our remaining three samples, and an analysis comparing test results for all participants in the NEI program.
Regarding inorganic materials, NEI plans to draw samples from those already submitted to test for inorganic composition. When that information is available we will be able to determine if our materials are equivalent to materials which have been previously tested for fire endurance and reported in the NEI Application Guide. It is anticipated that FPC will have the required information from NEI by July 31, 1995.
As noted in the cover letter, FPC is continuing with a multi-phase approach to the resolution of Thermo-Lag fire barrier issues which will determine the Thermo-                    ,
Lag fire barriers which will remain. It is anticipated that we will make a final                     {
determination by December 31, 1995.                      Accordingly, until full test results are    l available as noted above, and a final list of required Thermo-Lag protected raceways is developed, FPC cannot absolutely determine a necessary and sufficient sample size for chemical composition testing. If there is not a significant variation in the composite test results, we believe that our sample size of eight samples for organic composition will be sufficient. FPC will report test results of our samples, our basis for determining the sufficiency of our sample size, and our position on testing for inorganic composition to the NRC Staff by September 30, 1995.
5.0 Material Weight and Density In the RAI of December 28, 1994, we requested information on the weight and density of Thermo-Lag materials installed at CR3. You responded that chemical test results are not expected to show significant variations in material composition and that variations in material weight and density can be attributed to the presence of voids or porosity in Thermo-Lag materials. Material density has been determined in testing conducted by industry to be significant in the                        !
performance of Thermo-Lag as a fire barrier material. Your response did not provide information regarding verification of the weight and density of Thermo-

U. S. Nuclear Regulatory Commission                                  Attachment 1 3F0795-02 Page 4 of 7 Lag materials installed at CR3. Please submit the information requested in our December 28, 1994 RAI.                                                            l I
FPC Response The procurement and receipt practices for the Thermo-Lag materials used in the    .
NEI fire endurance test program required that materials were weighed and that they met an acceptance criteria. This assured a degree of consistency in the materials tested, however it did not establish density, per se, as an important barrier parameter in assessing barrier performance.
FPC is aware of NEI plans to perform some additional limited density testing of Thermo-Lag materials. We will monitor the results of those tests and determine the importance of performing density testing of CR-3 materials to support our use of the Application Guide. FPC will report our conclusions and future actions on density testing to the NRC Staff by December 31, 1995.
6.0 Voids, Cracks, and Delaminations Our December 28, 1994, RAI requested information on the presence of voids, cracks, and delaminations in the Thermo-Lag fire barriers installed at CR3. You responded that your quality control (QC) inspection plans included a requirement for verification that there were no holes, cracks or depressions that would violate material thickness, that the existence of defects had already been accounted for in the industry test program, and any additional effort to quantify the existence of these defects would not be beneficial. In the test programs conducted by industry, the Thermo-Lag materials were carefully inspected prior to construction of the test specimens, and any defects were repaired or the material was not used. We stated in the RAI that you must have valid information on the Thermo-Lag materials installed at your plant and that reliance on generic information on Thermo-Lag is not sufficient.       Please submit the information requested in the RAI of December 28, 1994, regarding the presence of voids, cracks and delaminations in the Thermo-Lag materials installed at CR3.
FPC Response FPC believes that our previous response to this issue in Reference B provides an accurate assessment of the relative effects of voids and delaminations on the barriers at CR-3, and offers the following additional information.       The only reasonable means to assess the existence of voids and delaminations is observation of them as they are exposed by cutting Thermo-Lag panels or pre-shapes to fit specific installation sites.      The NRC Staff notes that during industry test programs, when they were observed, defects were repaired. At FPC the installation of Thermo-Lag fire barriers included pre- and post-buttering of joints between Thermo-Lag barrier pieces. The result of this practice was to fill any exposed voids and delaminations with trowel grade Thermo-Lag, in effect, repairing the defects. As reported previously, QC inspection of CR-3 Thermo-Lag barriers ensured that any external voids, cracks or depressions that violated material thickness requirements were identified and corrected. We believe that the specific installation techniques used at CR-3 resulted in finished barrier installations that were equivalent to barrier configurations in industry tests with regard to the existence and treatment of observable defects in the Thermo-Lag materials.

1 U. S. Nuclear Regulatory Commission                                        Attachment 1 3F0795-02 Page 5 of 7 7.0 Fire Endurance, Combustibility and Flame Spread In the RAI of December 28, 1994, we requested information on fire endurance, combustibility and flame spread of Thermo-Lag installed at CR3. Your response stated that these parameters are related to material composition and that the combustibility of Thermo-Lag will be addressed as part of the EPRI TC project, where Thermo-Lag is treated as combustible if it is subjected to sufficiently severe heat and flame conditions. The EPRI TC methodology has not been submitted for our review. However, we have previously stated our conclusion regarding the classification of Thermo-Lag as a combustible and the acceptable test methods for determining the combustibility of materials used in licensees' facilities. This information has been provided to industry in Information Notice 92-82, Results of Thermo-Lag 330-1 Combustibility Testing," Generic Letter 86-10, Supplement 1, and in a letter to NEI of March 13, 1995 (copy previously provided to the licensee). We also discussed the combustibility issue during public meetings on March 14, 1995, and March 29, 1995.          In the RAI, we stated that you must have valid information on the specific Thermo-Lag materials installed at your plant.
Please submit additional information regarding the fire endurance, combustibility and flame spread of Thermc-Lag materials installed at CR3.
FPC Response Fire Endurance Equivalent E-119 fire endurance for FPC fire barriers will be established by use of the NEI Application Guide, with consideration being given for site specific construction techniques that resulted in ' upgraded' barriers. Use may be made of the EPRI Barrier Rating Tool in specific cases to rate ' upgraded' barriers, and justification for its use will be documented. The basis for use of the NEI Application Guide will be established once it is demonstrated that CR-3 barrier materials are equivalent to materials used in tests compiled in the Application Guide.          Equivalence of materials will be based on chemical composition test results. Equivalence of complete barriers will be established through segment-by-segment evaluation of CR-3 Thermo-Lag barriers as prescribed in the Application Guide. Engineering evaluations of unique configurations not bounded by existing tests will be performed as necessary.                  The information and evaluations performed to establish barrier ratings will be retained for future site inspections.
FPC plans to use information in the Attachment to Enclosure 1 of Generic Letter 86-10, Supplement 1, " Acceptable Methods for Demonstrating Functionality of Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure," to evaluate cable functionality. FPC will apply the methods outlined to cables within barriers which do not achieve required fire ratings.
We will use this approach to demonstrate that the combined protection provided by our existing barriers and the thermal damage resistance of CR-3 IEEE 383 rated cable, will assure circuit integrity and functionality following fire exposure.
Combustibility and Flame Spread in the March 14, 1995 public meeting the NRC Staff made comments to the effect                       ,
that chemical composition was the key property of Thermo-Lag material required                       i to establish equivalence between the material used in industry tests and plant l
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U. S. Nuclear Reguletory Commission                                   Attachment 1 I 3F0795-02 Page 6 of 7 spe .fic materials.         It was further stated that once chemical composition equnalence was established, that establishing equivalence of the remaining material properties would be easier. Specifically related to combustibility and    !
flame spread, it was stated that generic industry test data could be used where it could be shown that chemical composition test data was consistent.
As noted in question 4.0 above, initial results from chemical composition tests of FPC materials indicates the chemical composition of our materials is equivalent to that of industry test program specimens. FPC is now awaiting the final test results of our samples and a comparison to thd results of chemical composition tests of other utilities' materials submitted under the NEI program.
Based on preliminary results, it appears that there is substantial consistency in the chemical composition test results across the industry. FPC will address the specific values we will use for flame spread and combustibility when we report the final results of FPC's and industry's chemical composition tests.
8.0   Important Barrier Parameters In the RAI of December 28, 1994, we requested information regarding the verification of the important installation parameters for Thermo-Lag fire barriers. You responded that the report on the inspections of fire barrier installations at CR3 was provided to us in your letter of January 6,1995, and that no additional      inspections of barriers are planned at this time and additional information may be obtained incident to the removal of abandoned barriers in the future. The information included in your {{letter dated|date=January 6, 1995|text=January 6,1995, letter}} was based on plant documentation of original barrier construction and verified by walkdowns.      Some destructive examinations were also performed.       'n the December 28, 1994, RAl, we stated that some important parameters m 9t be verified through walkdowns or by reviewing original installation recu ;s and procedures. We request additional information regarding your methodology for the destructive examinations to demonstrate that the sample size was adequate to assess the total population of Thermo-Lag barriers at CR3.        If the previous destructive examinations are not adequate to assess the total population of Thermo-Lag barriers, you should submit a description of its methodology for the additional examinations and a schedule for completion.
FPC Response In Reference A FPC listed the 24 barrier parameters that have been determined to be important in evaluating plant barriers relative to tested configurations. We listed the condition of each of these parameters as they exist for CR-3 barriers.
We are confident that sufficient valid information exists on CR-3 barrier parameters necessary to rate barrier segments bounded by existing tests.
Ongoing walkdowns of CR-3 Thermo-Lag barriers to establish ratings and evaluate the usefulness of the NEl Application Guide, have shown that we have many unique barrier segments that are not bounded by currently available tests. Therefore, numerous specific engineering evaluations of barrier segments will be required to establish barrier ratings.
As noted previously, FPC is continuing with a multi-phase approach to the resolution of Thermo-Lag fire barrier issues which will determine the Thermo-Lag only fire barriers which will remain. When those Thermo-Lag fire barriers are l

1 U. S. Nuclear Regulatory Commission                                    Attachment 1 I 3F0795-02                                                                           )
Page 7 of 7 identified, we will evaluate them to determine a justifiable fire endurance rating for each, based on the NEI Application Guide and other information that may be available, such as the EPRI Barrier Rating Tool. To perform these evaluations, FPC will demonstrate the applicability of the tested configuration to our configurations, and provide evaluations for segments that are not specifically bounded. If there are irnportant barrier construction details which must be determined to support engineering evaluations, we will perform additional destructive examinations.
At this time it would not contribute to the overall resolution of Thermo-Lag fire barrier issues at CR-3 to either plan or execute a sampling program to document barrier parameters. FPC will retain the information used to establish Thermo-Lag equivalent E-119 fire barrier ratings, including the results of destructive examinations, on file for review during future inspections.
9.0 Ampnity Derating In the RAI of September 23, 1994, we requested information regarding ampacity derating of cables enclosed within Thermo-Lag barriers. You stated that you considered it premature to use test results until technical issues relating to IEEE P848 are resolved. You plan to respond to these issues when technical issues with respect to ampacity derating factors have becn resolved. During the public meeting held on March 14, 1995, with you as one of the four lead plant licensees.for resolution of Thermo-Lag issues, we respr- i to the question 'Will the resolution of the ampacity derating concern be c' c      ed until agreement is reached on the appropriate testing protocol (i.e., IEtm <848)?". We reiterated the position, which was previously stated in the September 1994, RAI, that the ampacity derating concern could be resolved independently of the fire endurance concerns. At this time we are not aware of any NEI initiative to address the ampacity derating issue. After a review of tests which were performed under the draft IEEE standard P848, we transmitted comments which were designed to ensure the repeatability of the test results to the IEEE Working Group responsible for the test procedure. Please submit your ampacity derating evaluations, including any applicable test reports, in order to provide an adequate response to GL 92-08 reporting requirement 2.(c).
FPC Response FPC will have ampacity derating tests performed by Underwriters Laboratory in accordance with Draf t 16 of IEEE Standard P848. Tests will be performed on various fire barrier configurations, including baseline tests with no barriers, Thermo-Lag only, Thermo-Lag overlaid with Mecatiss, and Mecatiss only barriers.
Both 1-hr and 3-hr barrier configurations will be tested.       Thermo-Lag barrier installation will be in accordance with typical FPC construction techniques as established by FPC design and installation instructions.          Mecatiss barrier construction will be performed by Mecatiss personnel and will be the same as will be used in the future at CR-3. The test results will therefore be applicable to CR-3 plant fire barriers.
FPC will provide a report of our ampacity derating test results and a preliminary derating evaluation applicable to CR-3 to the NRC by November 1,1995. A final evaluation will not be available until final barrier designs are complete.

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ATTACHMENT 2 FPC PROPRIETARY
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U. S. Nuclear Regulatory Commission                                                                                   Attachment 3 3F0795-02 Page 1 of 9 Additional Information on December 6, 1994 Fire Endurance Tests of Thermo-Lag / Mecatiss Fire Barriers FPC offers the following additional information in answer to the NRC Staff
(      questions contained in Reference C. This information is provided to supplement the information previously provided in Reference D.
Fire Exposure r
NRC Question
: 1.    ' Both the l'-hour and 3-hour exposures appear to be outside the acceptable limits specified in ASTM E-119/NFPA 251. The furnace temperature readings for both the 1-hour and 3-hour tests, as measured by the "NFPA 251" thermocouples provided by Underwriters Laboratories, are below the standard time-temperature curve for the entire duration of both tests.
For the 1-hour exposure, the area under the curve as measured by the "NFPA 251" thermocouples should be within 10% of the corresponding area under the standard time-temperature curve. However, furnace temperatures, as measured by the "NFPA 251" thermocouples, during the first 10 minutes of the exposure are 72% less than the standard time-temperature curve. The difference is within 10% midway through the exposure period and within 5%
at the end of the 1-hour test. For the 3-hour exposure, the area under the curve should be within 5% of the corresponding area under the standard time-temperature curve. However, furnace temperatures during the first 10 minutes of exposure are 39% less than the standard curve. The difference is 4% midway through the exposure and 5% at the end of the 3-hour test.                                                    I The staff considers these deviations to be significant in evaluating the relative performance of fire barrier assemblies.
FPC Response (Supplement)
The ASTM E-Il9 Standard includes Table XI. " Standard Time-Temperature Curve for Control of Fire Tests," which delineates the required temperature at each five minute time step of a fire test. This table also                                                   l includes the inte in the units of, grated F-min.                                 areaFPC under hasthe  time-temperature plotted the measured curve       above 68 F time-temperature J
curves for the 1 hour and 3 hour fire endurance tests of Thermo-Lag /Mecatiss fire barriers conducted in florestel, France, and has calculated the area under these curves above the starting ambient temperature. Plots of time-temperature, area under the curve and area computations are provided for both the averaged 150 thermocouples and the averaged NFPA 251 thermocouples.                                                  As a quality check on our area computation, we computed the area under the E-119 curve and are within
              +0.0008% agreement with the standard. The curves and tabulated area computation are included in Figures 1 through 4 and Tables 1 and 2.
During the conduct of the tests the observers noted problems with the time lag between the ISO and NFPA thermocouples, and with furnace control following the required E-Il9 time-temperature curve.                                                       It was decided therefore to run the test for an additional ten minutes to compensate.
Following the extended test period the test articles were removed from the furnace and the hose stream test was completed.

U. S. Nuclear Regulatory Commission                                    Attachment 3 3F0795-02 Page 2 of 9 Tables 1 and 2 include columns which compute the difference between the area under the E-119 versus the area under the respective time-temperature curves for the ISO and NFPA 251 thermocouples. These computations show, at either the 1 or 3 hour test duration, that the areas under the measured time-temperature curves are not within the acceptance criteria of the E-119 Standard. However, at the 1:10 or 3:10 test duration, the measured curve areas are greater than the E-Il9 area. The area under these curves is a measure of total energy input to the furnace and therefore to the test articles. FPC is confident that by extending the duration of the fire endurance tests, the test articles were exposed to a fire that was equivalent to an ASTM E-Il9 exposure. Further technical information on the application of this concept is included in Attachment 2 under the topic heading of the " Total Heat Load Concept."
This information is provided as an alternative analysis of the measured time-temperature data which was previously questioned by the NRC Staff in Reference C. This information does not conflict with the analysis provided previously in Reference D, but demonstrates the same conclusion reached previously. FPC therefore requests that the NRC Staff approve the fire exposure test conditions documented in these tests as equivalent to an E-119 exposure.
I 1

U. S. Nuclear Regulatory Commission                                                                                                                             Attachment 3 3F0795-02 Page 3 of 9                                                                                                                                                                       {
Tm1 Comparison of E-119 vs. ISO and NFPA 251 Total Heat Flux i
1 Hour Test E-119                            ISO TC's                                                                                          NFPA 251 TC's TIME (h:mm) Temp,'F lIntg'd Area Temp,'F lIntg'd Areal                                                               delta                     Temp,'F lIntg'd Areal delta 0:00       68              0            48.1                                                                  0                              43.1             0 0.05      1000          2330          622.3                                 1435,5 (38.39%)                                                   244       502.25 (78.44%)
0:10      1300          7740         1107.3                                            5519 (28.70%)                                          809         2919 (62.29%)
0:15      1399       14147.5         1342.7                                     11404 (19.39%)                                               1183         7684 (45.69%)
0:20      1462         20960         1421.6                                     18074 (13.77%)                                               1303        13684 (34.71%)
0:25      1510         28050         1478.4                                   25084 (10.57%)                                                 1364        20136 (28.21%)      !
0:30      1550         35360           1527                                    32357                            (8.49%)                      1419        26878 (23.99%)
0:35      1584         42855           1561                                   39837                             (7.04%)                      1468        33880 (20.94%)
* 0.40      1613       50507.5           1588                                  47469                              (6.02%)                      1497        41077 (18.67%)
0.45      1638         58295           1622                                   55254                             (5.22%)                      1527        48422 (16.94%)
0.50      1661       66202.5           1667                                  63236                              (4.48%)                      1569        55947 (15.49%)
0.55      1681       74217.5           1692                                   71393                             (3.81%)                      1595       63642 (14.25%)       I 1:00      1700         82330           1706                                  79648_                             (3.26%)                      1623      (71472' (13.19%)      l 1:05                                   1727                                   87990                               6.87 %                     1642        79419    (3.54%)    I 1:10                                   1747  P.                         '964353 (17.13 %                                                     1654   /M474WFi$2}%
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i                                                                                                                                                                                                                                                                     .      - ..
t         S. wucteer Kegulatory Comission                                                                                                                                                                                 Attachment 3
:irn/95-02                                                                                                                                                                               -
Pa 3 4 of 9                                                                                                                   Figure 1 E-119 to ISO and NFPA 251 TC's Comparison Time-Temperature 1800
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U. S. Nuclear Regulatory Commission                                                 Attachment 3                (
3F0795-02 Page 6 of 9                                                                                                     ;
Results                                                                                                         :
NRC Question                                                                                                    ;
: 1.      The 3-hour test of the 3/4-inch conduit with a Thermo-Lag and Mecatiss fire barrier system exceeded the maximum allowable average temperature                               't criteria specified in Supplement I to Generic Letter 86-10. Licensees that intend to use fire endurance test results that deviate from the acceptance criteria as the bases for qualifying and installing fire barrier configurations, should request 'a deviation from the acceptance criteria based on an engineering evaluation acceptable to the staff, such
                     -as demonstration of cable functionality.
                                                                                                                              ~
FPC Response'(Supplement)                                                                                       l A similar analysis of time-temperature and total energy input can be                                    ,
applied to justify this apparent minor deviation from the acceptance criteria for the 3 hour test of the 3/4" conduit.                   Review of the data shows that 'at 3:05:30 (h:mm:ss) into the test, the average of thermocouples on the exterior of the conduit had not exceeded the acceptance criteria. At that point, the energy input as represented by                                  -
integration of the area under the NFPA 251 thermocouple time-temperature curve was within -2.16% of the energy represented by the E-Il9 curve.
This creates a fire exposure which meets the acceptance criteria of ASTM E-Il9 for a test of greater than 2 hours duration, namely an exposure within i 5% of the E-119 time-temperature curve.                                                        t As noted in Reference D FPC uses IEEE 383 qualified cable for all safety related and non-safety related applications. (Limited minor exceptions may exist for specialty. applications.)                   FPC cables are insulated and jacketed with thermoset insulation that typically remains free of damage a                     from short term heat exposures to temperatures of approximately 700*F.
This would provide a margin of several hundred degrees between the cable damage threshold and the temperatures that would be reached due to an E-119 exposure inside a 3/4" . conduit protected with this barrier configuration.               FPC    believes this test demonstrates a barrier'                          r configuration capable of providing protection for CR-3 cables for a 3 hour ASTM E-Il9 exposure and represents compliance with the requirements of Generic letter 8610 Supplement 1.
a f
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U. S. Nuclear Regulatory Consnission                                                        Attachment 3 3f0795 02 Pag 3 7 of 9 Table 2 Comparison of E 119 vs. ISO and NFPA 251 Total Heat Flux 3 hour Test E-119                              ISO TC's                   NFPA 251 TC's TIME (h:mm) Temp,'F l Unit Area lIntg'd Area Temp,'F lIntg'd Area l delta % Temp,'F lIntg'd Area l delta %
0.00                68         0           0    48.3                0           0 44.8            0          0 0.05             1000       2330        2330    701           1631.75 (29.97%)     242         493 (78.84%)
0:10            1300        5410        7740   1126              5958 (23.02%)     804        2884 (62.74%)
0:15            1399      6407.5     14147.5   1294             11767 (16.83%) 1092           7400 (47.69%)
0:20            1462      6812.5       20960    1406            18276 (12.81%) 1297          13149 (37.27%)
0:25            1510        7090       28050   1449             25172 (10.26%) 1386          19633 (30.01%)
0:30            1550        7310       35360   1533             32386   (8.41%)   1451      26502 (25.05%)
0:35            1584        7495       42855   1612             40007   (6.65%)   1517      33698 (21 37 %)
0.40            1613      7652.5     50507.5   1656             47936   (5.09%)   1571      41194 (18.44%)
0.45            1638      7787.5       58295   1677             56027   (3.89%)   1504      48883 (16.15%)
0:50            1661      7907.5     66202.5   1697             64221   (2.99%)   1626      56709 (14.34%)
0:55            1681        8015     74217.5   1702             72477   (2.35%)   1624      64610 (12.95%)
1:00            1700      8112.5       82330   1724             80801   (1.86%)   1640      72546 (11.88%)
1:05            1718        8205       90535   1742             89225   (1.45%)   1663      80580 (11.00%)
1:10            1735      8292.5     98827.5   1749             97711   (1.13%)   1687      88731 (10.22%)
1:15            1750      8372.5      107200   1768            106262   (0.88%)   1700      90975      (9.54%)
1:20            1765      8447.5    115647.5   1787            114908   (0.64%)   1719     105299      (8.95%)
1:25            1779        8520    124167.5   1789            123607   (0.45%)   1728     113693      (8.44%)
1:30            1792      8587.5      132755   1789            132311   (0.33%)   1735     122127      (8.01%)
1:35            1804        8650      141405   1799            141040   (0.26%)   1747     130608      (7.64%)
1:40            1815      8707.5    150112.5   1810            149821   (0.19%)   1754     139137      (7.31%)
1:45            1826     8762.5       158875   1821            158657   (0.14%)   1763     147706      (7.03%)
1:50            1836        8815      167690   1832            167548   (0.08%)   1769     156312      (6.79%)
1:55            1843     8857.5     176547.5   1827            176454   (0.05%)   1774     164946      (6.57%)
2:00            1850     8892.5       185440   1825            185343   (0.05%)   1769     173580      (6.40%)
2:05            1856        8925      194365   1850            194289   (0.04%)   1783     182236      (6.24%)
2:10            1862        8955      203320   1869           203345      0.01 %  1807     190987      (6.07%)
2:15            1869     8087.5 212307.5 1886                 212491      0.09 %  1820     199831      (5.88%)
2:20           1875         9020 221327.5 1887                221682      0.16 %  1818     208702     (5.70%)
2:25            1882     9052.5       230380   1906           230923      0.24 %  1819     217571     (5.56%)
2:30           1888         9085      239465   1895           240184      0.30 %  1819     226442     (5.44%)
2:35           1894         9115      248580   1854           249315      0.30%   1784     235226      (5.37%)
2:40            1900        9145      257725   1864           258369      0.25%   1790     243937     (5.35%)
2:45           1906         9175      266900   1874           267473      0.21 %  1797     252681     (5.33%)     !
2:50           1912         9205      276105   1887           276634      0.19 %  1807     261467     (5.30%)     t 2:55           1919      9237.5 285342.5 1906                 285875      0.19 %  1821     270313     (5.27%)
3:00           1925         9270 J [294612.5   1918 M295194_              0.20%   1838 d279237j (5.22%)
3:05                                           1940           304598      3.39 %  1854     288243     (2.16%)
3:10                                           1956 M 3f4097.2 ' 6.61% 1871 8297832MFO.92%                        ;
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Figure 3 E-119 to ISO and NFPA 251 TC's Comparison Time -Temperstmo                                                                                                                                                                                                                                                    ,,c 2000                                                                                                                                                                                                                                                                                                                                                                                                                               . , .
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