ML102600216

Engineering Transmittal, ET-CEP-10-0006, Revision 0, Evaluation of Aluminum Conduit Seal Penetration Fire Tests, Dated May 13, 2010, North Anna and Surry Power Stations Units 1 and 2 (Redacted Version), Enclosure 2

ML102600216
Person / Time
Site:	Surry, North Anna
Issue date:	05/13/2010
From:	Dominion, Virginia Electric & Power Co (VEPCO)
To:	Office of Nuclear Reactor Regulation
References
10-478 ET-CEP-10-0006, Rev 0
Download: ML102600216 (60)

Text

Serial No.10-478 Docket Nos. 50-280/281/338/339 NON-PROPRIETARY ENCLOSURE 2 Engineering Transmittal, ET-CEP-10-0006, Revision 0, "Evaluation of Aluminum Conduit Seal Penetration Fire Tests," dated May 13, 2010 North Anna and Surry Power Stations Units 1 and 2 (Redacted Version))

Virginia Electric and Power Company (Dominion)

NON-PROPRIETARY EngineeringTransmittal So ominiow ',- HSDGN04 pag IJOf 19 1.Transmittal Number: 2. Rivlslon: 3. Station(s) 4. Unit(s):

ET-CEP-10-0006 0 9 North Anna Surry 0 Unitl I Unit 2 0 ISFSI 5.Title: .6. Quality Clesaficatlon:

Evaluation of Aluminum Conduit Seal Penetration Fire Tests NSQ

7. ETType 8. Required Actions? 9. FSRC Approval Req.?

Implementing (D Nn:ln Plementing OYes 0 No. Yes 5a No Prepared By IAffiliation: (Print) ISgature:_ Date-Date:

Date:

Date:

72T Date:

Date:

Date,~

DMaIte: ,

i.I - Activty Checklist included as attachment 1!1i *[

12. [3 Safeaty Review included as attachment. {. *j*

is. F1 50.59/72.48 Screen included as attachment .:..*  ; i

14. PRC & PRCS included as

Attachment:

0.[ ,;/

15. []COS Included as.

Attachment:

-2

• t.!

l1  :.o.*.avM ndd Rev*won C(c,@ 6qiremeni.s O CDRR Is NOT required.

1 NAPS and SPS DCEs are requested to Initiate CDRR upon receipt of this ET.

0 CDRR will be required at a later date. The affected DCE(s) will be notified following to Initiate CDRR.

NON-PRO Page 2 of 19 17.AddtioalAttachments K~J Ž: > i No. Description 3 Intertek Report No. 3197899SAT-001 4 Intertek Report No. 3197899SAT-002 5 Intertek Report No. 3197899SAT-003 6 Emails on Self-Ignition Temperatures of Neoprene and Hypalon Jacket Material 7 Evaluation Matrix of Aluminum Conduit Penetration Test Results 8 Memo - Discussion with NRC on 02/25/2010 9 Penetration Qualification Background lo Programs Review Checklist

18. ,Distibution~ (Originaflistransmiitted't Records. Copies shall be sent.,to Primary Recq~ipieqt(~anidothers kientiried be'low.)~

Primary Recipient(s): /Manager SPS Nuclear Engr. Programs

/Manager NAPS Nuclear Engr. Programs Copy To? Other Recipient / Department or Location Copy To? Other Recipient / Department or Location X / INNS Nuclear Engineering X /Supv. SPS Nuclear Engineering Programs Programs X / NAPS Aux. System Management X /Supv. NAPS Nuclear Engineering Programs X / Supv. INNS Nuclear Engineering X / SPS Aux. System Management Programs X / NAPS Nuclear Engineering X / SPS Electrical Engineering Programs X / SPS Nuclear Engineering X Records Management (Copy)

Programs X / Manager INNS Nuclear X - NAPS DCE Engineering Programs X - SPS DCE Source Documents CR347022 and CR347057 (Surry)

CR347193 and CR342994 (Nofth Anna)

Record of Revision Revision 0 - Original Issue Purpose & Applicability This is an implementing Engineering Transmittal (ET) that documents an evaluation of test

ýesults on aluminum conduit penetration seal configurations. This ET is in accordance with section 2.1.15 of STD-GN-0041.

ET-CEP-10-0006, R'ev. 0 Page 3 of 19 References NON-PROPRIE [At-i.

1. Branch Technical Position APCSB 9.5-1

2. Appendix A to the Branch Technical Position, titled "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976,"

3. Reg. Guide (RG) 1.189, Fire Protection for Nuclear Power Plants

4. Fire Protection System Review for North Anna Power Station Units 1 and 2, dated April 1 1977

5. Fire Endurance Test on Cable Penetration Fire-Stop Seal Systems Utilizing Dow Corning Q3-6548 Silicone RTV Sealing Foam Final Report, dated February 15, 1977

6. IEEE P634/D2, "Standard for Cable Penetration Fire Stop Test Procedure," dated October 5, 1976.

.7. Safety Evaluation Report For North Anna Power Station, dated March 6, 1979

8. North Anna Power Station Appendix R Report

9. Surry Power Station Appendix R Report

10. ASTM E-1 19, Fire Tests of Building Construction and Materials

11. Technical Report EP-001 1, Fire Test Reports Surry Power Station Units 1 and 2, dated 1/11/2000

12. Technical Report EP-0016, Fire Test Reports North Anna Power Station Units 1 and 2, dated 1/11/2000

13. IEEE 634, "Standard Cable Penetration Fire Stop Qualification Test.", dated April 19, 1978

14. Calculation No. 1250-111-CO1, Penetration Seal Configuration Documentation Pkg. 10" DC3-6548 Silicone Foam/North Anna & Surry Power Station

15. Calculation No. 1250-111-C02, Penetration Seal Configuration Documentation Pkg. Dux Seal/Thickol/Flamemastic /Surry Power Station

16. Calculation No. 1250-111-C03, Penetration Seal Configuration Documentation Pkg. 10" DC3-6548 Silicone Foam Blockout/North Anna & Surry Power Station

17. Calculation No. 1250-111-C04, Penetration Seal Configuration Documentation Pkg. 12" DC3-6548 Silicone Foam Blockout/North Anna & Surry Power Station

18. Design Change SU-10-1024-000, "Fire Penetrations with Aluminum Conduit Repair"

19. Design Change NA-10-00116, "Aluminum Conduit Fire Barrier Penetration Modification"

20. Engineering Transmittal ET-N-10-0031, Evaluation of Aluminum Conduit Fire Penetrations not Requiring Modification"

21. 1989 Industry Study "Conduit Fire Protection Research" and NRC SER dated 10/23/1989

22. Engineering Transmittal ET-CEP-99-0031, Penetration Seal Configuration Evaluations Surry Power Station Unit 1 and 2

23. Safety Evaluation Report For Surry Power Station, dated September 19, 1979

ET-CEP-10-0006, Rev. 0 Page 4 of 19 Design Inputs NONE NONPROPRETARY Discussion Introduction History During the 2009 NRC Triennial Fire Protection Inspection at Surry Power Station (SPS), the NRC identified that sufficient documentation did not exist to qualify the use of aluminum conduits with silicone foam seals penetrating fire rated barriers (i.e. floor and wall assemblies.)

This issue was entered into the SPS corrective action program (see CR347022 and CR347057). This issue was determined to be applicable to North Anna Power Station (NAPS) and entered into NAPS corrective action program as CR347193 after a review and walk downs were performed on aluminum conduit penetrations which may not have internal silicone seals.

As a result of the lack of documentation on qualification testing of silicone foam penetration seals in fire rated barriers, Dominion contracted with Transco Products, Inc. to perform testing at the Intertek Laboratories in Elmendorf, Texas. The test reports from the test are included as attachments to this ET.

Originallicensing bases NAPS UFSAR section 9.5.1.2.4.2 states:

"Conduits passing through rated fire barriers are provided with internal conduit seals as follows: a) if the conduit terminates at a distance of up to 5 feet from the fire barrier, or b) if the conduit is penetrating the Control Room pressure envelope."

Surry UFSAR section 9.10.2.8 indicates:

"Electrical cable penetrations in fire barriers surrounding safety-related areas throughout the plant are sealed using materials and methods that have been tested by Vepco to verify their effectiveness as a fire barrier. The fire test for penetration seals, as described by Vepco in a fire hazards analysis, utilized a gas burner as a flame source. The test on each specimen was conducted for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or until flame or hot gases, hot enough to ignite cables, penetrated the top of the sealing material. The test verified that penetration seals meet NRC Branch Technical Position APCSB 9.5-1.,

New penetration seals are made using silicone foam or other Engineering approved fire stop material with a 3-hour fire rating. The fire stop material may be used in conjunction with an approved permanent damming material, or in conjunction with temporary damming materials which are removed."

The NRC's original licensing requirements/guidelines for penetration seal qualifications are stated in Section D.3.d of Appendix A to BTP APCSB 9.5-1";,

"Cable and cable tray penetrations of fire barriers (vertical and horizontal) should be sealed to give protection at least equivalent to that fire barrier. The design of fire barriers for horizontal and vertical cable trays should, as a minimum, meet the requirements of ASTM E-1 19, "Fire Tests of Building Construction and Materials," including the hose stream test. Where installed

ET-CEP-1o-0006, Rev. 0 Page 5 of 19 o ON-P O El El penetration seals are deficient with respect to fire resistance, these seals may be protected by covering both sides with an - approved fire retardant material. The adequacy of using such material should be demonstrated by suitable testing."

This guideline incorporated, by reference, the specific test procedures outlined. in ASTM E-1 19 (NFPA-251). The ASTM E-1 19 test was originally intended to determine the fire resisting capability of walls and floors assemblies. As such, it did not specifically address testing procedures for penetration seals. The NRC, however, determined that-an adequate test procedure for penetrations seals could be adopted from the ASTM E-1 19 test.

As stated above, Branch Technical Position APCSB 9 .5-1 requires cable penetration of fire barriers to be sealed to give protection at least equivalent to that in a 3-hr fire barrier. On April 1, 1977, NAPS submitted a "Fire Protection System Review" indicating compliance to this requirement and it included a report (ref. 4) on a fire endurance test conducted at NAPS on December 15;1976. Similarly, SPS submitted this fire endurance test. This test report demonstrated the acceptability of a 6 inch metal sleeve with cables and an aluminum cable tray with cables penetrating a three hour rated fire barrier filled with Dow Corning Q3-6548 Silicone RTV Sealing Foam. The test was conducted in accordance with preliminary draft of IEEE P634/D2, "Standard for Cable Penetration Fire Stop Test Procedure," dated October 5, 1976.

On March 6, 1979 and September 19, 1979 the NRC issued a Safety Evaluation Report on the Fire Protection Program for NAPS and SPS, respectively and concluded that the submittals identified the plant to be in compliance with Appendix A. This test along with one other test (ref.

11) performed at NAPS in November 1975 was the basis for the acceptability of the conduit penetrations in fire barriers at NAPS and SPS throughout the 1980's.

In the early 1990's, Virginia Power contracted with Impell Corporation to generate documentation for the penetration seal configurations (PSCs) existing at SPS. This led to the issuance of several calculations (ref. 14-17) used to justify the PSCs. The test reports referenced by the calculations utilized acceptance criteria/testing methods from standards IEEE P634/D2, IEEE 383-1974, ASTM E-1 19-1976, ASTM E-814 and NEL-PIA/MAERP. The test reports were incorporated into technical reports TR EP-001 1 and TR EP-0016. SPS and NAPS adopted the test reports by reference of their respective technical report into the SPS Appendix R Report and NAPS Appendix R Report. During the 2009 NRC Triennial Fire Protection Inspection at Surry Power Station (SPS), the NRC reviewed the test reports and determined that sufficient documentation did not exist to qualify the use of aluminum conduits with silicone foam seals penetrating fire rated barriers as 3-hr fire rated.

Of these test reports, two mentioned testing on aluminum conduit sleeves (ref. profile tests 6 &

7 in TR EP-001 1). The aluminum conduit sleeve configurations achieved an F-rating as opposed to a T-rating of 3 hrs for the aluminum conduit penetration seal configurations being evaluated by this ET. A discussion on F-rating and other tested penetration configurations are discussed in Attachment 9 (Penetration Qualification Background.)

Description of Evaluation The results of the testing performed on aluminum conduits with silicone foam seals penetrating fire rated barriers at the Intertek Laboratories are analyzed by this ET.

Testing Method The test of aluminum conduits with silicone foam seals penetrating fire rated barriers was in accordance with IEEE 634-1978 with the noted exceptions discussed in this ET. Although

NlO M.-P RO ETe o-ooo6, Rev.o0 Page 6 of 19 ASTM E-1 19 is the test standard applicable in the licensing basis for NAPS and SPS, this standard was not chosen for the test because ASTM E-1 19 was not specifically Written for testing of conduit penetrations in fire rated barriers. IEEE 634-1978 is appropriate for testing the existing aluminum conduit penetration seal configurations at NAPS and SPS since it is was written for this purpose. The NRC concurred with this assessment during discussions with Dominion Virginia Power (Attachment 8). Also, Reg. Guide 1.189 permits IEEE 634 to be used as an acceptable test standard. Previous testing to IEEE P634/D2 provided further justification for testing in accordance with IEEE 634-1978.

Compliance and Deviations Generally, the testing was in accordance with IEEE 634-1978 except as noted below. A comparison of the test performed against the requirements of IEEE 634-1978 is discussed:

Type of Cable The tested configurations used control cable with jacket material made of [ 2.390(a)(4)

]. This material is representative of majority of the jacket of most instrument, control and power cables used at NAPS/SPS. In addition, penetrations were filled representing the maximum fill as discussed in the next section. This resulted in the*

maximum heat conduction that would challenge the cable insulation. Therefore, testing with instrument and power cables was not 'warranted as required by IEEE 634-1978. [ 2.390(a)(4),

]. This temperature is used in the acceptance criteria as discussed below.

Raceway Fill The aluminum conduit penetrations were [ 2.390(a)(4)1 . This is representative of the maximum cable fill at NAPS/SPS. No minimum or zero % cable fill configurations were tested in accordance with IEEE 634-1978 since these are not representative of most field configurations. A minimum or zero % cable fill configuration would be bounded by a test on maximum cable fill which has more cable surface area to burn and greater heat conduction contribution through more cable conductors from the exposed side to the unexposed side of the fire barrier.

Conduit Size 2.390(a)(4)] aluminum conduit penetrations were tested. The various sizes tested were in accordance with IEEE 634-1978. IEEE 634-1978 allows the successful testing of the largest size conduit penetration to bound the smaller tested conduit penetrations.

Supports The cables were attached to steel support bars on the unexposed side of the fire barrier and allowed to drop freely into the furnace with no restraints. The aluminum conduits on the unexposed sides were attached to the steel support using clamps. The aluminum conduits were not supported on the exposed side. Conduit penetrations are restrained more rigorously on both sides of the fire barrier with steel bolts, nuts and washers at NAPS and SPS. Therefore, tested configurations are more conservative and would bound any field configurations. The steel supports are acceptable in accordance with IEEE 634-1978.

Cable Installation 2 39 The cables within the penetrations . 0(a)(4 )]on the unexposed side and the cable ends were sealed, not capped as required by IEEE 634-1978. Sealing achieved the same purpose since it would preclude the passage of smoke and hot gases through the cables.

NON-PROPRIEMR0 006, Rev. 0 Page 7 of 19 The NRC concurred with this assessment during discussion as documented in Attachment

8. On the exposed side, the cable protruded at least [ 2.390(a)(4)] into the furnace.

Raceway Installation Most conduits within the penetrations did not [ 2.390(a)(4)] on the unexposed side and I 2.390(a)(4)] on the exposed side as required by IEEE 634-1978. This was done intentionally to demonstrate assorted plant conduit configurations found at SPS and NAPS.

Orientation This test was performed with the aluminum conduit penetrations in a floor-ceiling slab.

Results of the test were bounding of penetrations in the wall orientation in accordance with IEEE 634-1978.

Time-Temperature Curve The aluminum conduit penetration configurations were subjected to the standard time-temperature curve in ANSI A2.1-1972 (same as ASTM E-1 19) in accordance with IEEE 634-1978.

Exposed Side Test Instrumentation, Reading Intervals and Flame Source Accuracy Seven thermocouples on the exposed side were disposed and distributed to show the average temperature for each aluminum conduit penetration configuration. These thermocouples were placed in accordance with IEEE 634-1978. During the test of 2 of the 3 test slabs, one of the thermocouples was eliminated due to erroneous readings.

Temperature readings were taken at a minimum of[ 2.390(a)(4)] intervals which is more frequent than required by IEEE 634-1978.

Negative pressures of up to [ 2.390(a)(4)] were maintained. IEEE 634-1978 does not contain any pressure requirements on the exposed (furnace) side of the fire barrier.

The accuracy of the flame source control was such that the area under the time-temperature curve, obtained by averaging the results from thermocouple reading was within 5% tolerance of the standard time-temperature curve. This was in accordance with IEEE 634-1978.

Unexposed Side Test Instrumentation, Reading Intervals Thermocouples were placed on the conduit sleeve surface, external seal surface, the conduit/external seal surface interface, the internal seal surface and the cable jacket 2.390(a)(4)--,

surface. In some instances Temperature readings were taken at a minimum of [ 2.39o(a)(4)] intervals which is more frequent than required by IEEE 634-1978.

Hose Stream Test A hose stream was delivered through a 1.5 inch nozzle set at a discharge angle of 15 degrees with a nozzle pressure of 75 psi and a minimum discharge of 75 gpm with the tip of

NON-PROPRIETAR.Y-Oooo 6 Page 8 of 19

,Rev.o, the nozzle at a maximum 10 ft from the exposed face. The hose stream was applied for a duration of 2.5 minutes per 100 ft 2 of the test slab surface. This was in accordance with Regulatory Guide 1.189 which is acceptable to the NRC. This hose stream test is different from IEEE 634-1978 which requires a 30 degree angle. IEEE 634 criteria is acceptable per Regulatory Guide 1.189.

Acceptance Criteria The fire endurance test of the aluminum cable conduit penetration configuration was considered acceptable provided the following was met:

a) There was no passage of flame or gases hot enough to ignite the cable or fire stop material on the unexposed side. This was compliant with IEEE 634-1978.

b) Transmission of heat through the conduit penetration configuration after three hours did not raise the temperature.on its unexposed surface above the self-ignition temperature of the outer cable covering, the cable conduit penetration fire stop material, or material in contact With the cable penetration fire stop. [ 2.390(a)(4)

] Reg. Guide 1.189 permits temperatures higher than 700 0 F when justified in terms of cable insulation ignitability.

c) The conduit penetration configuration withstood the hose stream test without the hose stream causing an opening through the test specimen. This was compliant with IEEE 634-1978.

NOTE: The acceptability criteria used ih the fire endurance test at NAPS on December 15,1976, established by IEEE P634/D2, required that there be no passage of flame or gases hot enough to ignite the cable on the unexposed side of the penetration, and that the temperature on the unexposed side has not been raised more than 2500 F above the initial temperature. This criteria was not included this test. In cases where temperatures exceeded 2500 F above the initial temperature the specimens were evaluated.

Evaluation This ET evaluates the fire endurance test performed by Intertek Laboratories on aluminum conduits with silicone foam seals penetrating fire rated barriers. The test reports are in attachments 3, 4 and 5. The results of the test are evaluated against the following fire endurance test criteria:

a) There was no passage of flame or gases hot enough to ignite the cable or fire stop material on the unexposed side.

9 b) Transmission of heat through the conduit penetration configuration after three hours did not raise the temperature on its unexposed surface above the self-ignition temperature of the outer cable covering, the cable conduit penetration fire stop material, or material 2.390(a)(4) in contact with the cable penetration fire stop.

d

NON-PROPRI ETARY.1 00006, Page 9 of 19 Rev. 0 c) The conduit penetration configuration withstood the hose stream test without the hose stream causing an opening through the test specimen.

The test involved test specimens grouped into twelve (12) categories placed into [ 2.390(a)(4)

] which were tested on three separate days. The test report identifies the twelve categories which can be described as follows:

2.390(a)(4) '

y )

The test specimens in groups 1, 2, 3, 4, 5, 6 and 12 represent aluminum conduit penetration baseline configurations that exist at NAPS and SPS. The test specimens in groups 7 through 11 represent potential modifications to existing aluminum conduit penetration configurations that are considered as possible fixes to existing configurations that may not be found acceptable.

Results The test reports in attachments 3 (test slab 1), 4 (test slab 2) and 5 (test slab 3) of this ET are formatted as~follows:

1) The main body describes the testing method, the slab and penetration construction, testing and evaluation methods, the testing and evaluation results.

2) Appendix A provides the Q/A receiving reports.

3) Appendix B provides the slab construction drawing.

4) Appendix C provides Test Procedure No. TR-242 which describes the test method.

5) Appendix D provides the thermocouple locations.

6) Appendix E provides the temperature data from the thermocouples.

7) Appendix F provides the pictures during the test.

8) Appendix G provides information on calibrated equipment.

NO N-PROPRI NON-PROPR ETA*RY.,~o, ET-CEP-10-0006, o~ Rev.0 Page 10 of 19 Summary Table To present the test data in Appendix E of each of the test reports in an easy to understand format, the maximum temperature reading and the duration time before failure (where applicable) for each thermocouple in Appendix D in each of the test reports was summarized as follows:

ET-CEP-10-0006, Rev. 0 Page 11 of 19 Table I - Summary of Thermocouple Readings from Slab 1 2.390(a)(4

-v

• rni

-K F

ET-CEP-10-0006, Rev. 0 Page 12 of 19 Table 2 - Summary of Thermocouple Readings from Sla 2.390(a)(4) 0 CD C:D

-H J

ET-CEP-10-0006, Rev. 0 Page 13 of 19 Table 3 - Summary of Thermocouple Readings from Slab 3 2.390(a)(4) 0 M0

-H (

NON-PROPRI STAR-YOU,,Rev.

0 Page 14 of 19 2,390(a)(

Group 1 2.390(a)(4..,

Group 2 Group 3 2.390(a)(4)

Group 4 2.390(a)(4,)

NON-PRO'P RIETAR-YP-.,o0o,,Rev. 0 Page 15 of 19 2.390(a)(4)

Group 5 2.390(a)(4)

Group 6 2.390(a)(4)

Group 7 2.390(a)(4)

Group 8 ")

NON-PROPRI ET .,o4ooo, Rev.o Page 16 of 19 2.390(a)(4)

Group 9 2.390(a)(4)

Group 10 2.390(a)(4))

Group 11 2.390(a)(4j

ET-CEP-10-0006, Rev. 0 Page 17 of 19 2.390(a)(4)

Group 12 7

2.390(a)(4)

Observations Appendix F of each test report in attachments 3, 4 and 5 contains pictures of the condition of the internal and external penetration seals and aluminum conduits after the hose stream test. /In

general, 2.390(a)(4) of this ET summarizes the test results, the modifications and combustible controls required for the existing configurations.

Smoke Seals 2.390(a)(4)

Equivalent smoke seals were evaluated in 1989 Industry Study "Conduit Fire Protection Research" and NRC SER dated 10/23/1989 (reference 21). The 101 conduits tested in this study included a mixture of galvanized pipe, IMC and EMT electrical conduits. [ 2.39o(a)(,

NON-PROPR IEr- ETAPV,18 of 19000ooo6, Rev.

L 2.390(a)(4j Conduits L ~2.390(a)(4j Special Considerations 2.390(a)(4)

Margin K2"390(a)(41 Administrative Measures L 2.390(a)(4 1 Conclusion The fire endurance test performed by Intertek Laboratories on aluminum conduits with silicone foam seals penetrating fire rated barriers provided useful results for the resolution of the issues identified in this ET. The results show the following:

2.390(a)(4) j

• _.4==CEP-10-0006, Rev. 0 N-WpRO P RIE-A'-AH e19 of 19 2.390(a)(4)

Precautions and Limitations NONE Recommendations NONE Required Actions None. Attachment 2, Controlled Document Summary, block 10 provides for CDRR control of documents requiring revision of CM-AA-FPA-101.

NIOIE-PROPMETARI Attachment I ET CEP 10-0006 Rev 0 Pg lof 1 PDaminion' Activity Checkli.st

ýVAP,30 -

Atahmn 2 Pae o

1. Identification of Governing Document 2. Appicable Station 3. Applicable Unit ET CEP 10-0006 REV 0 1xj North Anna Power Station ix] Surry Power Station [x] Unit 1 1X] Unit 2 1 3 FSFSI

4. Brief Description of the Entire Activity ET CEP 10-0006 REV 0 evaluates the test results on aluminum conduit penetration seal configurations..

5. Is the activity bounded by another change that has already been If YES, identify the source document: (Skip to Block 8) determined to require NRC approval? E I Yes 1x] No

6. Isthe activt based on a source docunmentthat has already been reviewed If YES, Identify the source document or attach a copy of the completed In accordance with VPAP-3001 or DNAP-3004? I ]Yes rx] No review.

(Sktp to Block 8)

A. Does this activity require a change to the Operating License, Technical Specifications (station or ISFSI), Technical r Yes Cx] No Specification Bases, ISFSI License, or the Technical Requirements Manual?

B. Does this activity alter (temporarily or permanently) the design of a Structure, system, or Component (SSC) described I Yes x] No in the UFSAR?

C. Does this activity alter (temporarily or permanently) the function, ability to function, or method of performing a. I Yes [x] No function of an SSC described In the UFSAR?

D. Does this activity alter a numeric value associated with design or performance requirements that has not been [ i Yes cx] No previously reviewed in accordance with VPAP-3001 or DNAP-3004?

E. Does this activity modify how SSCs are operated or controlled as described,outlined, or summarized In the UFSAR? E I Yes [x] No F... Does this activity perform a test or experiment that Is not described in the UFSAR? C I Yes [x] No G. Does this activity Involve a change In a calculational method that supports the function of an SSC described In the I I Yes Cx] No UFSAR?

H. Does this activity Involve a temporary modification, as defined in VPAP-1403? 1 3 Yes rx] No I. Does this activity Involve a change, test, or experiment that may affect the environment? .I Yes Ex] No 9a. (x] Based on the results of the completed Activity Checklist, the activity has no Impact on the design, function, ability to function, method of performing the function, or control or operation of a SSC described In the UFSAR (i.e., the change activity is safe) and the activity can be Implemented without prior regulatory approval.

List documents used to perform the General Screen.

North Anna Power Station Appendix R Report Rev 27 Surry Power Station Appendix K Report, Rev. 30 North Anna Power Station UFSAR Section 9.5.

Surry Power Station UFSAR Section 9.10 9b. Conclusion 0 Administrative change to void an outdate reference document that has been superseded by current Information,

10. Preparer Name (Print) 11. Title

• - Nuclear Engineer

12. Preparer Signature 13. Date

14. Reviewer Name (Only Required If Preparer Is not AC Qualified) or lAW Block 8 15. Title.

16. Reviewer Signature 17. Date NIA I Key: UFSAR-Updated Final Safety Analysis Report which Includes the plant specific UFSAR and the ISFSI FSAR; Fom No. 730914 (Feb 2008)

Dominion ONPROPRIETARYttah Controlled 2ETCEP 10-0006 Rev 0 Pg. 3) I of 4 Document Summary (CD.

VPA-031 -Atahet2Pg I of 4.

1. Station 2. Unit 3. Change Document Type and Number

[ x] Surry [ x] North Anna [x]1 [ x]2 ET CEP 10-0006 Rev. 0

4. Change Document Title Evaluation of Aluminum Conduit Seal Penetration Fire Tests

-eci-n

5. Item 6. Change

- -rcdue

9. Person Contacted Number Required? 7. Item 8. Priority? (If Applicable)

Al [ ] Yes [ x] No *Periodic Test Procedures A2 [ Yes [x] No *Station Operating Procedures A3 [ ] Yes [x] No *Annunciator Procedures A4 [ ] Yes [x] No *Emergency Procedures (EOPs)

A5 [ ]Yes [x] No *Abnormal Procedures A6 [ ] Yes [x] No *Maintenance Procedures A7 ]Yes [x] No *Chemistry Procedures A8 [ ]Yes [x] No *Health Physics Procedures A9 [ Yes [x] No Admin. Procedures (Except VPAP-2103N, VPAP-2103S, VPAP-2203, and VPAP-2401)

A10 [ ]Yes [x] No Loss Prevention Procedures All [ ] Yes [ x ] No #Security Procedures A12 Engineering Technical Procedures (e.g., DRP,

[ Yes [ x ] No NAT, PAP, GEP) (Other than those specified in Al, C18, C22, and C23)

Al3 [ Yes [x ] No *Emergency Planning Implementing Procedures (EPIPs)

A14 [] Yes [x] No North Anna Plant Logs

'A15 [ ]Yes [x ] No Surry Plant Logs A16 [ ] Yes [x] No SAMGs (Nuclear Safety Analysis)

[Commitment 3.2.27]

A17 [ ] Yes [x] No Nuclear Design Control Program (NDCM Series)

A18 [ ] Yes [x] No Engineering STD- Series A19 [ ] Yes [x] No Engineering Implementing Procedures (NASES, SSES, etc.)

[]Yes [x]No

[]Yes [x]No BI [ ] Yes [x] No Chesterton Valve Packing Database B2 [ Yes [x] No Plant Computer Software, piping configuration, or electrical one-line-displays B3 [ IYes [x] No #ERF Computer Software (Surry)

B4 [] Yes [x ] No #Simulator Hardware/Software B5 [] Yes [x ] No Software Master List B6 [ Yes [ x] No Post Maintenance Testing Database B7 [ ]Yes [x ] No Maintenance Check Valve Database Key: DRPs-Design Reference Procedures;SAMGs-Severe Accident Management Guidelines; ERF-Emergency Response Facility;

• -Normally treated as priority; #-Normally treated as non-priority Form No. 721319(Feb 2010)

NO.0N-PROPRI

~~Dniiion EETARY',al-06Rv~.2f ARY ttach 2 ETDocument Controlled Dominn A CEP 10-0006 Rev 0(CDS) 2 Summary Pg. 2 of 4 Pe 2 1 Station 2. Unit 3. Change Document Type and Number

[x] Surry [x ] North Anna [X] 1 [x]] 2 ETCEP 10-0006 Rev. 0

5. Item 6. Change 7. Item 8. Priority? 9. Person Contacted Required? (If Applicable) 1B8 [ ] Yes [x] No Maintenance Relief Valve Database B9 [ ] Yes [x] No Snubber Tracking Database BI0 [ Yes [x] No #Local Area Network Software 311 [ ] Yes [x ] No Motor Operated Valve (MOV) Database B12 [ Yes [x ] No Air Operated Valve (AOV) Database B13 [ Yes [x] No Bill of Materials B14 [ Yes [x] No Equipment Data System (EDS)/Q-List B15 [ Yes [x] No Secondary Piping and Component Inspection Database B16 [ ] Yes [x] No North Anna VPSLL Database B17 [] Yes [x ] No Accident Analysis Design Basis Document (AADBD)

B18 [] Yes [x ] No Single Point Vulnerability (SPV) Database B19 [] Yes [ x ] No Equipment Performance Information Exchange (EPIX)

Sectio ,] C O*her Contro Ot- Documents' Cl [] Yes [x ]No *Plant Drawings C2 [ ] Yes [x] No Procurement Specifications (e.g., NAP-0036, NAP-0079/SUP-0073, NAP-0078/SUP-0072, NAS-2094/N US-2206)

C3 [] Yes [x] No Installation Specifications C4 [ Yes [x] No System and Plant Design Basis Documents C5 [] Yes [ x ] No *Design Calculations C6 [] Yes [ x ] No Class 1 Stress Reports C7 [ ] Yes [x ] No Appendix R Report C8 [ ] Yes [x ] No Station Electrical Load List C9 [ Yes [x ] No Qualifications Document Review Packages CO [ ] Yes [x ] No Environmental Zone Descriptions CII [ ]Yes [x] No EQ Master List C12 [ Yes [x No EQ Maintenance Manual C13 [ ]Yes [x] No EQ Procurement Manual C14 [] Yes [x] No *Technical Specifications C15 [ ] Yes [ x] No *North Anna Technical Requirements Manual C16 [ ] Yes [ x No *Surry Technical Requirements Manual C17 [ ] Yes [ x No Updated Final Safety Analysis Report (UFSAR)

C18 [ ]Yes [x No *Curve Book (NAPS SC- Series and SPS DRP-3)

Key: Q-List-Quality List; VPSLL-Virginia Power Station Load List; EQ-Environmental Qualification;

• - Normally treated as priority; #-Normally treated as non-priority Form No. 721319(Feb 2010)

Attach 2 ET CEP 10-0006 Rev 2 Pg. 3 of 4 2_1 W PROPRIETARY Controlled Document Summary (CDS)

VPAP-030 -Atcmn 2. Pae3 f4

1. Station 2. Unit 3. Change Document Type and Number

[x ]Surry [x]North Anna [x]l [x]2 ETCEP10-0006Rev. 0

-eto

5. Item C Othe

- Cotrled Douet

6. Change

-onine

9. Person Contacted Number Required? 7. Item 8. Priority? (IfApplicable)

C19 [ ] Yes [x] No Training Programs (e.g. NCRODP)

C20 [ ] Yes [x ] No #North Anna Setpoint Document C21 [ ]Yes [x ] No North Anna PLS Document C22 [ ]Yes [x] No MOV Operating Bands (NAPS O-DRP-1 and SPS 1/2-DRP-7)

C23 [ ]Yes [x] No AOV Setpoints (NAPS O-DRP-2 and SPS O-DRP-10)

C24 [x] Yes [ ] No Fire Protection Program (CM-AA-FPA-101) Non- Dean Tolete Priority C25 [ ]Yes [x] No Security Plan C26 [ ]Yes [x] No Vendor Technical Manuals C27 [] Yes [x] No Inservice Testing (IST) Valve Program C28 [ ] Yes [x] No Inservice Testing (IST) Pump Program C29 [ ] Yes [ x ] No Inservice Inspection (ISI) Program C30 [ ] Yes [ x] No Augmented Inservice Inspection Program C31 [ ] Yes [x] No Spare Part Stocking Level Requirements and Procurement Spare Parts C32 [ ] Yes [x] No Emergency Plan C33 [ ] Yes [ x] No Preventive Maintenance (PM) Program C34 [ ] Yes [x] No Surry Operations Checklists C35 [ ] Yes [x] No Regulatory Guide 1.97 Technical Report C36 [ ] Yes [x] No Westinghouse Process Control Instrument Scaling Implementation Procedure Technical Report C37 [] Yes [x] No Environmental Protection Plan C38 [] Yes [x] No Virginia Power Oil Discharge Contingency Plan C39 ] Yes [x] No Oil SPCC Plan (VPAP-2203)

C40 [] Yes [x] No #Offsite Dose Calculation Manual (VPAP-2103N and VPAP-2103S)

C41 [ ]Yes [x] No Maintenance Rule Program C42 [ Yes [x] No,' Fire Fighting Strategies C43 [] Yes [x] No Lube Program C44 [] Yes [x] No In Containment Banned/Restricted Materials C45 [ ] Yes [x] No North Anna Cable and Raceway Program (STD-GN-0026)

C46 [ ]Yes [x] No **Technical Report EE-0101 Setpoint Bases Document for NAPS and SPS C47 [] Yes [x ] No License Renewal (Aging Management) Program Key: SPCC-Spill Prevention, Control, and Countermeasures; PLS-Precautions, Limitations, and Setpoints; NCRODP-Nuclear Control Room Operator Development Program;

• Normally treated as priority; #-Normally treated as non-priority

• • - Not a priority document and not applicable to the 90 day clock. Notify Corporate Electrical/i&C/Computers If marked "Yes" Form No. 721319(Feb 2010)

I~N'PRnPRIETARyAttach2

- ,-,oEI ET CEP 10-0006 Rev 0 Pg. 4 of 4 ControlledDocument Summary (CDS)

I VPAP-0301 - Attachment 2 Page 4 of 4 1

1. Station 2. Unit 3. Change Document.Type and Number

[ x ] Surry [x] North Anna [x ].1 [x ] 2 ET CEP 10-0006 Rev. 0

-1 Section C

,--Ot-e Conrolled ments 'Continued

5. Item 6. Change 9. Person Contacted Number Reauired? 7. Item 8. Priority? (If ADDlicable)

C48 [] Yes [ x] No System Monitoring Plans C49 [] Yes [ x ]No Condition Monitoring Program C50 [ ] Yes [ x] No **Technical Report NE-0994, Safety Analysis Limits for Technical Specification Instrumentation Companion to EE-0101 for North Anna, Surry, and Kewaunee Power Stations C51 [ ]Yes [ x ]No **Technical Report NE-1 200, Key Operator Actions Assumed in the Safety Analyses for Surry and North Anna Power Stations C52 [ ] Yes [ x ]No ASME Section VIII Pressure Vessel Program C53 [ ] Yes [x ] No Surry Time Critical Operator Actions (0-DRP-049)

[Commitment 3.2.31]

C54 [] Yes [x ] No North Anna Time Critical Action Validation and Verification (0-GOP-17.0)

C55 [] Yes [ x ] No Containment Recirculation Sump GSI-191 Program

[]Yes [x]No Key: SPCC-Spill Prevention, Control, and Countermeasures; PLS-Precautions, Limitations, and Setpoints; NCRODP-Nuclear Control Room Operator Development Program;

• Normally treated as priority; #-Normally'treated as non-priority

• • - Not a priority document and not applicable to the 90 day clock. Notify Nuclear Safety Analysis if marked "Yes".

10. Remarks (Attach additional pages if needed.)

Evaluate and revise CM-AA-FPA-101 for combustible controls to preclude contact of transient combustibles with penetration seal configurations.

Key: ASME-American Society of Mechanical Engineers;

• - Normally treated as priority; #-Normally treated as non-priority Form No. 721319(Feb 2010)

Attachment 3 ET-CEP-10-0006, Rev. 0 Page 1 of 1

,,NON-PROP rIETARY Intertek Test Report Report Number: 3197899SAT-001, Rev. 1 Original Issue Date: February 25, 2010 Revised Date: April 15, 2010 Product Evaluated: Penetration Firestops Evaluation Property: Fire Resistance

rteK REPORT NUMBER: 3197899SAT-001 Rev. 1 o

ORIGINAL ISSUE DATE: February 25, 2010 T lri

.~ y%y EVALUATION CENTER 0 16015 Shady Falls Road Elmendorf, TX 78112 (voice) 210-635-8100 (fax) 210-635-8101 www.intertek.com RENDERED TO TRANSCO PRODUCTS, INC.

LU 55 E. Jackson Blvd, Suite 2100 Chicago, IL 60604 CIO This report contains proprietary information and cannot be used without the written approval of Dominion Virginia Power.

w PRODUCT EVALUATED: Penetration Firestops HM EVALUATION PROPERTY: Fire Resistance Report of Testing of Penetration Firestops for compliance with the applicable requirements of the following criteria: Modified IEEE Std 634-1978, IEEE Standard Cable Penetration Fire Stop Qualification Test, April 19, 1978, Approved December 15, 1977.

This report is for the exclusive use of Intertek's Client and is 'providedpursuant to the agreement between Intertek and its Client.

Intertek's responsibility and liability are limited to the terms and conditions of the agreement. Intertek assumes no liability to any party, other than to the Client in accordance with the agreement, for any loss, expense or damage occasioned by the use of this report. Only the Client is authorized to copy or distribute this report and then only in its entirety. Any use of the Intertek name or one of its marks for the sale or advertisement of the tested material, product or service must first be approved in writing by Intertek. The observations and test results in this report are relevant only to the sample tested. This report by itself does not imply that the material, product, or service is or has ever been under an Intertek certification program.

Transco Products, Inc.

Project No. 3197899SAT-001 Rev. 1 NON-PROPRIETARY April .15, 2010 Page 2 of 181 1 Table of Contents 1 Table of Contents ............................... ............................................................... 2 2 Introduction .............................................................................................................. 3 3 Test Sam ples ................................................................................................... 3 3.1. SAM PLE SELECTIO N ................................................................................. 3 3.2. SAMPLE AND ASSEMBLY DESCRIPTION .......................... 3 3.2.1. Slab Construction ......................................... ..................................... 3 3.2.2. Penetration Construction ...................................................................... 3 4 Testing and Evaluation Methods ......................................................................... 4 4.1. INTRUM ENTATIO N............................................................... ..................... 4 4.2. TEST STANDARD ........................................................................................ 4 4.2.1. Deviation From Standard Method .......................................................... 4 5 Test Results and Observations ........................................................................... 4 6 C o n c lu s io n ............................................................................................................... 6 APPENDIX A ............................................................................................................... 7 APPENDIX B ............................................................................................................. 18 APPENDIX C ............................................................................................................. 21 APPENDIX D .......................................................................................... ...................64 APPENDIX E .............................................................................................................. 67 APPENDIX F ........................................................................................................... 149 APPENDIX G 0...................................................

....................................................... 179 REVISION SUM MARY ............................................................................................ 181 i '911 Intertek

Non-Proprietary Serial No.10-478 DockettNos. 50-280/281/338/339 Pages 3 through 181 of Intertek Test Report Number 3197899SAT-001, Rev. 1 are Proprietary and therefore being Withheld from Public Disclosure Pursuant to 2.390(a)(4)

Attachment 4 ET-CEP-1O-0006, Rev. 0 Page 1 of 1 NON-PROP RETARY Intertek Test Report Report Number: 3197899SAT-002, Rev. 1 Original Issue Date: February 25, 2010 Revised Date: April 15, 2010 Product Evaluated: Penetration Firestops Evaluation Property: Fire Resistance

Inter REPORT NUMBER: 3197899SAT-002 Rev. 1 ORIGINAL ISSUE DATE: February 25, 2010 EVALUATION CENTER 16015 Shady Falls Road Elmendorf, (voice) TX 78112 210-635-8100 (fax) 210-635-8101 www.intertek.com J RENDERED TO TRANSCO PRODUCTS, INC.

55 E. Jackson Blvd, Suite 2100 IM. Chicago, IL 60604 This report contains proprietary information and cannot be used 0 without the written approval of Dominion Virginia Power.

W PRODUCT EVALUATED: Penetration Firestops EVALUATION PROPERTY: Fire Resistance Report of Testing of Penetration Firestops for compliance with the applicable requirements of the following criteria: Modified IEEE Std 634-1978, IEEE Standard Cable Penetration Fire Stop Qualification Test, April 19, 1978, Approved December 15, 1977.

This report is for the exclusive use of Intertek's Client and is provided pursuant to the agreement between Intertek and its Client.

Intertek's responsibility and liability are limited to the terms and conditions of the agreement. Intertek assumes no liability to any party, other than to the Client in accordance with the agreement, for any loss, expense or damage occasioned by the use of this report. Only the Client is authorized to copy or distribute this report and then only in its entirety. Any use of the Intertek name or one of its marks for the sale or advertisement of the tested material, product or service must first be approved in writing by Intertek. The observations and test results in this report are relevant only to the sample tested. This report by itself does not imply that the material, product, or service is or has ever been under an Intertek certificationprogram.

N Transco Products, Inc.

Project No. 3197899SAT-002 Rev-....1I N

rJ ,R, OPA

'

April 15, 2010 Page 2 of 188 I Table of Contents' ...

1 Ta ble of C ontents ................................................................................................ 2 2 Introduction ........................................................................ 3 3 T est S am ples .................................................................................................. 3 3.1. SAMPLE SELECTION ..... 3..............3 3.2. SAMPLE AND ASSEMBLY DESCRIPTION ................................................. 3 3.2 .1. S lab C onstruction ................................................................................... 3 3.2.2. Penetration Construction ....................................................................... 3 4 Testing and Evaluation Methods ......... .................................. 5 4.1. INSTRUMENTATION .......................................... 5 4.2. TEST STANDA R D ....................................................................................... 5 4.2.1. Deviation From Standard Method .......................................................... 5 5 Test Results and O bservations ............................................................................ 5 6 C o n c lu s io n ............................................................................................................... 7 A P P E ND IX A ....................................................................................................... 8 A P P E ND IXB ............................. .. ..................................................................... . . . 19 A P P E ND IX C .............................. ....................................................................... . . . 2 2 A P P E ND IX D ............................................................................................................. 65 A P P E ND IX E ...................................................................................................... . . 68 A P P E ND IX F ........................................................................................................... 14 7 A P P E ND IXG ........................................................................................................... 18 6 REVISION

SUMMARY

............................. ............... 188 r-

-I Intertek

Non-Proprietary Serial No.10-478 Docket Nos. 50-280/281/338/339 Pages 3 through 188 of Intertek Test Report Number 3197899SAT-002, Rev. 1 are Proprietary and therefore being Withheld from Public Disclosure Pursuant to 2.390(a)(4)

Attachment 5 ET-CEP-1O-0006, Rev. 0 Page 1 of 1 NON-PROPRIETARY Intertek Test Report Report Number: 3197899SAT-003, Rev. 1 Original Issue Date: March 30, 2010 Revised Date: April 15, 2010 Product Evaluated: Penetration Firestops Evaluation Property: Fire Resistance

Ite.ýr- e, REPORT NUMBER: 3197899SAT-003 Rev. I ORIGINAL ISSUE DATE: March 30, 2010 REVISED DATE: A ri 15, 2010 HM NON-PROPRIETARY EVALUATION CENTER 0 16015 Shady Falls Road Elmendorf, TX 78112 (voice) 210-635-8100 (fax) 210-635-8101 www.intertek.com RENDERED TO TRANSCO PRODUCTS, INC.

55 E. Jackson Blvd, Suite 2100 Chicago, IL 60604 Clo LU This report contains proprietary information and cannot be used without the written approval of Dominion Virginia Power.

F. PRODUCT EVALUATED: Penetration Firestops EVALUATION PROPERTY: Fire Resistance Report of Testing of Penetration Firestops for compliance with the applicable requirements of the following criteria: Modified IEEE Std 634-1978, IEEE Standard Cable Penetration Fire Stop Qualification Test, April 19, 1978, Approved December 15, 1977.

This report is for the exclusive use of Intertek's Client and is provided pursuant to the agreement between Intertek and its Client.

Intertek's responsibility and liability are limited to the terms and conditions of the agreement. Intertek assumes no liability to any party, other than to the Client in accordance with the agreement, for any loss, expense or damage occasioned by the use of this report. Only the Client is authorized to copy or distribute this report and then only in its entirety. Any use of the Intertek name or one of its marks for the sale or advertisement of the tested material, product or service must first be approved in writing by Intertek. The observations and test results in this report are relevant only to the sample tested. This report by itself does not imply that the material, product, or service is or has ever been under an Intertek certificationprogram.

Transco Products, Inc. April 15, 2010 Project No. 3197899SAT-003 Rev 1 NONe 1 1 Table of Contents 1 Table of Contents ....................................................................... 2 2 Intro d u ctio n ................................................ ...... I:..................................................... 3 3 T est S am ples ................................................................................................... 3 3.1. SA MPLE SELECTIO N ................................................................................. 3 3.2. SAMPLE AND ASSEMBLY DESCRIPTION ....................................... 3 3.2 .1. S lab C onstruction .................................................................................... 3 3.2.2. Penetration Construction ...................................................................... 3 4 Testing and Evaluation Methods ..................................... 7 4.1. INTR UMENTATIO N ............. ........................................................................ 7 4.2. TEST STANDA R D ....................................................................................... 7 4.2.1. Deviation From Standard Method ........................................................... 7 5 Test Results and Observations.................. .................... 7 6 Conclusion ..................................................... 9 A P P E ND IXA ............................................................................................................. 10 APPENDIX B .................................................... 21 A P P E ND IX C .............................................................................................................. 24 APPENDIX D ................................................................................ 67 A P P E ND IXE ............................................. ..... .................................................... 7 0 APPENDIX F .................................................... 153 A P P E ND IX G ........................................................................................................... 18 6 R EV IS IO N S UMMA R Y ............................................................................................ 188

Non-Proprietary Serial No.10-478 Docket Nos. 50-280/281/338/339 Pages 3 through 188 of Intertek Test Report Number 3197899SAT-003, Rev. 1 are Proprietary and therefore being Withheld from Public Disclosure Pursuant to 2.390(a)(4)

I

Attachment 6 ET-CEP-10-0006, Rev. 0 NON-PROPRIETARY Page 1 of 2 2.390(a)(4)

Attachment 6 ET-CEP-10-0006, Page Rev.

2 of 20 NON-PROPRIETARY 2.390(a)(4)j

- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-10-0006 Rev. 0 Page 1 of 7 2.390(a)(4

-o C

-o Fii

-H J

- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-1O-0006 Rev. 0 Page 2 of 7 2.390(a)(4)

- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-10-0006 Rev. 0 Page 3 of 7 2.390(a)(4' 0ý.

0 DO J

Attachment 7 - Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-1O-0006 Rev. 0 Page 4 of 7 r 2.390(a)(4) 0 0

CD

-o

- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-1O-0006 Rev. 0 Page 5 of 7 2.390(a)(4) 0

-o

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- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-IO-O006 Rev. 0 Page 6 of 7 2.390(a)(4) 0

-o3 m

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- Evaluation Matrix of Aluminum Conduit Penetration Test Results ET-CEP-1O-O006 Rev. 0 Page 7 of .7 2.390(a)(4>

0 CD m:)

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--

J

NON-PROPRIETARY Attachment 8 ET-CEP-10-0006 Rev. 0 Page 1 of 2

Dominion Memorandum May 5, 2010 To: Phil Bradley Department: Nuclear Engineering Program Location: INNS 3SE From: Dean Tolete Department: Nuclear Engineering Program Location: INNS 3SE Telephone Call with NRC on 2/25/2010 Attendees:

Bill Miller (NAPS)

Dean Tolete (INNS)

Mark Salley (NRC)

Gabriel Taylor (NRC)

Brian Metzger (NRC)

On 2/25/2010, Dominion held a teleconference call with members of the NRC Fire Protection group to clarify their position on aspects of the fire testing being performed on aluminum conduit penetration seal configurations.

The following is the response by the NRC:

1. [I

,390(a)(4)]The same type of jacket is typically used for instrumentation cable.

Power cables used at the sites are of armored cable type and are not run in conduits but rather in cables trays and therefore were not tested..[

2.390(a)(4]

2. The cable fill tested is representative of maximum load fill for a conduit at the sites which the NRC previously indicated was acceptable in our last phone call. IEEE 634-1978 requires that a type test evaluate maximum and minimum load fill. Dominion believes that our testing is not a type test since we are not marketing our configurations which is what vendors typically do with their products and therefore are required by this standard to account for various possible cable fills. NRC agreed that maximum load fill representative of the field configurations need only be tested unless Dominion has many aluminum penetrations without cables.

Form No. 720003 A (July 2006) 0 2006 Dominion Resources Services, Inc.

Attachment 8 ET-CEP-10-0006 Rev. 0 NON-PROPRIETARY Page 2 of 2 0Dominion Memorandum

3. 2.390(a)(4)-

4.

5. 'The hose stream test is in accordance with RG 1.189 which uses 1.5" fog nozzle @ 15 o and 75 PSI. The NRC previously indicated that was acceptable in our last phone call. NRC agreed that the RG 1.189 requirement is more rigorous to test and therefore is acceptable.

6. 2.390(a)(4)1

7. The above issues were evaluated against IEEE 634-1978. The NRC previously indicated that Dominion needed to utilize a national standard and comply with it. This standard is not our commitment but is similar to ASTM E- 119 which is our requirement in BTP 9.5-1. However, ASTM E-1 19 was not written for penetration seals. NRC wanted a test standard written for penetration of fire barriers to be used and IEEE-634-1978 is acceptable even though it is not the requirement of BTP 9.5-1.

8. If IEEE 634 is acceptable as discussed in item 7 above, is the 1978 version acceptable over a more current version like 2004 version. NRC agrees that the code of record version can be used.

Form No. 720003 A (July 2006)

C 2006 Dominion Resources Services, Inc.

\liX R II/ETA fY Attachment 9 ET-CEP-10-0006, Rev. 0 Page 1 of 6 Penetration Qualification Background NRC requirements and guidelines for fire barrier penetration seals are contained in various documents. The extent to which these requirements or guidelines are applicable to a specific plant depends on plant age, commitments established by the licensee in developing the fire protection plan, the staff safety evaluation reports (SERs) and supplements, and the license conditions pertaining to fire protection. The goal is to provide a fire barrier penetration seal that will remain in place and retain its integrity when subjected to an exposure fire, and subsequently, a fire suppressing agent. This will provide reasonable assurance that the effects of a fire are limited to discrete fire areas and that one division of safe-shutdown-related systems will remain free of fire damage.

To validate reasonable assurance that a fire barrier penetration seal will have the required fire-resistance capability or fire rating (1, 2, or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />), a representative penetration seal test assembly is subjected to a qualification fire endurance test. The test methods involve the furnace-fire exposure of a full-scale fire barrier penetration seal test specimen. The test specimens are representative of the construction for which a fire-resistance rating is desired, as to materials, workmanship, and such details as the dimensions of parts. The heat input to the test furnace is controlled so that the average temperature in the furnace follows as closely as possible the time-temperature curve specified in the test standard.

The standards used to test and rate penetration seals specify the standard time-temperature curve defined in American Society for Testing and Materials (ASTM) E - 119, "Standard Test Methods for Fire Tests of Building Construction and Materials." This time-temperature curve, which is generally accepted for evaluating and rating the fire resistance of all types of building fire barriers, is considered to represent a severe fire exposure. However, the fire endurance tests are not intended to model any specific room fire or the conditions under which the seals will be exposed during a fire, but rather provide a specific standard fire exposure against which similar fire-rated assemblies can be evaluated. The test standards and the NRC regulations and guidance documents specify fire test acceptance criteria that involve the measured response of the test specimen at the time into the standard fire exposure that corresponds to the desired barrier rating.

In all cases, the test specimen is also exposed to a hose stream test after the fire exposure. For example, a fire barrier penetration seal design is said to have a fire-resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> if the tested specimen meets the specified acceptance criteria during at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the standard fire exposure and the hose stream test. In this example, the fire-resistance rating qualifies the seal design for use as a 3-hour fire-rated barrier.

Therefore, assessments of fire test results consider both the test standard that was used and the acceptance criteria that apply. In general, the acceptance criteria ensure that the penetration seal does not burn through during the fire exposure, remains in place during the fire and hose stream exposure, prevents the passage of flames or gases hot enough to ignite combustibles that may be on the non-fire side of the test specimen, and limits the transmittal of heat through

NON-PROPRIETARY Attachment 9 ET-CEP-1 0-0006, Rev. 0 Page 2 of 6 the seal and any penetrating items (as determined by measuring the temperature rise on the nonfire side of the seal and any penetrating items). An independent testing authority is to be used to qualify penetration fire barriers by tests conducted in accordance with the provisions of the aforementioned guidelines. Decades of experience with the test standards by the nuclear and general building industries have provided adequate assurance that they are appropriate for qualifying fire barrier penetration seals. Hundreds of qualification-type fire endurance tests of a wide variety of penetration seal designs and materials have been performed by material manufacturers, installation contractors, test laboratories, research organizations, licensees, and others. The NRC has observed fire endurance tests of fire barrier penetration seals and reviewed fire test reports during licensing reviews and inspections. On the basis of these eyewitness accounts and reviews, the NRC has concluded that fire endurance tests have established the fire-resistive capabilities of the penetration seal materials, designs, and configurations installed in nuclear power plants.

NUREG 1552 indicates that the NRC has accepted the following industry standards for qualifying penetration seals:

(1) ASTM E-119; (2) National Fire Protection Association (NFPA) 251, "Standard Methods of fire Tests of Building Construction and Materials-";

(3) ASTM E-814, "Standard Method of Fire Tests of Through-Penetration Fire Stops"; and (4) Institute of Electrical and Electronics Engineers (IEEE) 634, "Standard Cable Penetration Fire Stop Qualification Test."

In addition, UL tests and approves penetration seals in accordance with American National Standards Institute/UL 1479, "Fire Tests of Through-Penetration Firestops," and other organizations, such as American Nuclear Insurers (ANI) and Factory Mutual (FM), also have test methods and standards for conducting penetration seal fire endurance tests. The NRC has also accepted the installation of penetration seals that had been qualified in accordance with these test standards. There are variations between the test standards and the test acceptance criteria. Note that the IEEE-634 standard and American Nuclear Insurers Standard NEL/PIA-MAERP are referenced in the NUREG 1552 document.

ASTM E- 814 establishes two ratings, F and T for every penetration seal tested. An F rating is based upon flame occurrence on the unexposed surface, while the T rating is based on the temperature rise as well as flame occurrence on the unexposed side of the fire stop. The test used by Underwriters Laboratory (UL) for. listing penetration seals is based on ASTM E-814, so all UL listed seals have F and T ratings.

NONoPROPRIETARY Attachment 9 ET-CEP-10-0006, Rev. 0

-- Page 3 of 6 Penetration seal testing is also discussed in section 4.2.1.5.b of Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants". This section states "An independent testing authority should qualify penetration fire barriers by tests conducted in accordance with the provisions of NFPA-251 or ASTM-E119. In addition, ASTM-E814 or IEEE-634 could be used in the development of a standard fire test (note that IEEE-634 was withdrawn on April 9, 1990, hence the standard should not be used for any new testing after that date).

The acceptance criteria for the seal testing are as follows:

1. The fire barrier has withstood the fire endurance test without passage of flame or the ignition of cables on the unexposed side for a period of time equivalent to the fire resistance rating of the barrier.

2. The temperatures recorded on the unexposed side of the fire barrier are analyzed and demonstrate that the maximum temperature does not exceed 325°F, or 250'F above ambient temperature. Higher temperatures at through-penetrations may be permitted, when justified in terms of cable insulation ignitability.

3. The fire barrier remains intact and does not allow projection of water beyond the unexposed surface during the hose stream test.

The guidance in IEEE-634 is bounded by these acceptance criteria.

Additional guidance on penetration seals is provided in the NRC's Generic Letter 86-10, , Section 8.19.1, which states:

"8.19.1 Penetration Designs Not Laboratory Approved QUESTION: Where penetration designs have been reviewed and approved by the NRC but have not been classified by an approved laboratory, will it be necessary to submit an exemption request?

RESPONSE: No This guidance states that the following penetration seals are acceptable for Appendix A:

a. Those which have been reviewed and approved by the NRC, and

b. Those which have been classified by an approval laboratory (such as UL).

Five basic penetration seal configurations were used in the construction of Surry:

a. Foam and Cerafiber Seal This penetration seal configuration consists of 10 inches of Dow Corning Q3- 6548 Silicone RTV foam, with 1 inch of Cerafiber or Cerablanket as permanent damming materials on each end. The total depth of foam and permanent damming material is a minimum of 12 inches.

b. Cable Tray Seal This penetration seal configuration consists of the same combination of foam and cerafiber described in Configuration A with the addition of a

Attachment 9 ET-CEP-10-0006, Rev. 0 Page 4 of 6 piece of Marinite XL or I board permanently attached to both sides of the penetration.

The board has a cut out to allow for passage of the tray.

c. 12 - Inch Foam Seal This penetration seal configuration consists of 12 inches of Dow Corning 03- 6548 Silicone RTV foam. Nonpermanent damming materials are used to form the seal. These damming materials are removed upon completion of the penetration sealing process.

d. Grouted Penetrations Penetrants which are permanently grouted into the fire.

barrier with grout or concrete and no silicone foam are considered to be a homogeneous part of the barrier, and are not considered to be individual penetration seals. The grouted penetrations at Surry are generally filled to'the thickness of the barrier with grout or concrete material. The mortar has cured and is an integral part of the barrier's construction. In block walls, the grout is the thickness of the block and is equivalent to the mortar joint customarily used to tie the individual construction materials together, forming a monolithic barrier.

e. Dux Seal, Thickol, and Flamemastic Seal This, penetration seal consists of 1-1/2 inches of 'Thickol" bounded by two metal or Micarta plates and 2 inches of "Dux Seal." Two 1/8" coatings of Flamemastic are applied on each end of the penetration.

These materials are no longer used to repair damaged penetrations or seal new penetrations.

Documentation of Configurations A and B penetration seals' fire resistance testing is contained in a test report entitled, "Fire Endurance Test of Cable Penetration Fire-Stop Seal Systems Utilizing Dow Corning Q3-6548 Silicone RTV Sealing Foam," dated February 15, 1977, conducted in-house by Virginia Electric and Power Company.

The testing~was not performed to ASTM E-1 19, nor was it tested by an independent laboratory.

However, the testing was based on a similar test procedure, and the acceptance criteria for a 3-hour fire resistance rating was achieved. The test report was then submitted to the NRC as an appendix to Supplement 1 dated December 15, 1977 to the "Fire Protection Systems Review" Report for North Anna Power Station. The report was reviewed and approved for both Surry and North Anna as indicated by the following statement from the Surry Fire Protection Safety Evaluation Report dated September 19, 1979:

"Any seals which must be replaced will be sealed using silicone foam installed as approved by the NRC staff for use at North Anna Power Station, Units 1 and 2."

Therefore, based on Generic Letter 86-10, Enclosure 2, Section 8.19.1, these penetration seals are acceptable for Appendix R.

Configuration C was tested to ASTM E-814 at Construction Technology Laboratories and is documented in a report entitled, "Fire and Hose Stream Tests of Cable Tray Seals - Dow Test No. 4," dated October, 1984.

\ \N-P -OPM ETAR Attachment 9 ET-CEP-10-0006, Rev. 0 Page 5 of 6 The test report references three standards: ASTM E-1 19, ASTM E-814, and IEEE 634. The flame test is the same between all three standards, but there are slight differences between the three standards in regards to the hose stream test and the acceptance criteria. Two separate hose stream tests were performed, and the report expresses the results of the testing in relationship to the acceptance criteria of both ASTM E-814 and IEEE 634. The referenced report is equivalent to one conducted by Underwriters Laboratories (U.L.) since the test procedure used by U.L. for classifying penetration seals is identical to ASTIVM E-814.

The subject test report states that no passage of flame occurred through either of the two penetration seals which were tested during the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire test. The report also states that one of the penetration seals passed the ASTIVM E-814 hose stream test. Since these are the acceptance criteria for an F rating in accordance with ASTIVM E-814 (i.e., no passage of flame and no projection of water through the penetration seal), it is concluded that the penetration seal configuration has a 3-hour F rating. The reason that failure of the other cable tray penetration seal during the hose stream test is not a concern is that the seal had already been subjected to and passed an IEEE 634 hose stream test. This test probably weakened the seal, leading to its failure during the ASTM E-814 hose stream test.

The acceptance criteria for a T rating in accordance with ASTM E-814 include the two criteria for a F rating plus a "maximum allowable temperature rise" criteria of 250°F above initial temperature or maximum temperature of 325 0 F. The test report states that the temperature criteria for a T rating were exceeded at several measuring points on the cable; therefore, the penetration seal does not have a 3-hour T rating.

The acceptance criteria for IEEE 634 also includes a "maximum allowable temperature rise" criteria, although it is higher than the ASTM E-814 criteria. Since the temperature criteria defined by IEEE 634 was exceeded at one measuring point on one penetration seal, the penetration seal does not have a 3-hour rating per IEEE 634.

It is concluded that the penetration seal is satisfactory since it passes the criteria for a 3- hour F rating, and the temperature limits for a 'T' rating are not required for operating plants. The basis for this conclusion is that the NRC's criteria for penetration seals, according to GL 86-10, seems to be whether or not the seal has been classified by an approved laboratory. Seals which are classified by Underwriter's Laboratories are listed with both an F and T rating. It is not uncommon for penetration seals to have a 3-hour F rating and a much lower I rating. In a power plant, there is no storage or other combustible material adjacent to the cables where they go through penetration seals. Therefore, even if the cables get very hot during a fire on one side of the penetration seal, it will be of no consequence on the unexposed side. Based on these observations, the temperature criteria for a T rating is not critical, the F rating is the critical factor.

Configuration D, grouted penetrations, does notf require specific qualification testing and does not require periodic surveillance. Under a typical exposure fire, the grouted seal is expected to remain intact just as the barrier itself, and is not subject to the design parameters which impact the fire resistance rating of a silicone foam seal. Documentation of this configuration is contained in Engineering Transmittal, CEP 99- 0031.

NON -PROPRI ETARY Attachment 9 ET-CEP-10-0006, Rev. 0 Page 6 of 6 Documentation of Configuration E penetration seal fire resistance testing is contained in a test report entitled, "Cable Penetration Fire Stop Test", conducted in-house by Virginia Electric and Power Company in November, 1975. [See Profile Test No. 2] This seal configuration was reviewed and approved by the NRC in the Surry SER dated September 19, 1979 Section 4.9.1 which states:

"Electrical Cable and Conduit Penetrations" Electrical cable and conduit penetrations in fire barriers surrounding safety related areas throughout the plant are sealed using materials and methods which have been tested by the licensee to verify theireffectiveness as a fire barrier. We have reviewed the procedures used for these tests and conclude that the existing penetration seals are adequate for most areas of the plant. The licensee's commitments to upgrade penetrations in fire barriers surrounding areas of high combustible loadings are included in the separate discussions for each area in section 5.0 of this report. Any seals which must be replaced will be sealed using silicone foam installed as approved by the NRC staff for use at North Anna Power Station, Units 1 and 2. We find that, subject to the implementation of the modifications described in this report, the protection of electrical cables and conduit penetrations satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."

Virginia Power provided an additional submittal to the NRC, dated October 31, 1980, which included assurance that the fire barriers in question were sealed to have a fire rating at least equivalent to the test criteria described by the fire hazards analysis. The NRC accepted this verification in Supplement 1 to Fire Protection Safety Evaluation Report, Dated September 19, 1980.

ATTACMENT10 - ET CEP 10-0006 Rev. 0

ýPOMTR~g 1 of 3 Programs Review Checklist Page I of 3 ST - N I0S S0 Document Number: Station:

FT CEP 10-0006 Rev. 0 r71 North Anna I7 Surrv M-Other Mark "Yes" or "No" for each item, based on the associated instructions for that item.

DCPs - Items with "Yes" require ER&D Section 3.0 discussion.

Other than DCP - Items with "Yes" require Programs Review Checklist Supplement discussion.

No discussion is required for items checked "No". Discussion may be provided at preparer's discretion.

Subject YES No

1. Updated Final Safety Analysis Report (VPAP-2803) El z

2. Technical Specifications and Facility Licenses (LI-AA-101-1001) Li E

3. Fire Protection/Appendix R (VPAP-2401) (STD-GN-0021) z Li

4. Environmental Qualification (CM-NA-EQ-100 & CM-SU-EQ-100) El Z

5. Station Security (Safeguards DNAP-2503) El Z

6. Electrical Systems Analysis (STD-EEN-0026) Li z

7. Containment Recirculation Sump GSI-191 Program E] z

8. Seismic (VPAP-0312) (STD-GN-0038) EL 2

9. Human Factors (STD-GN-0005) EL Z

10. In Containment Banned/Restricted Materials (STD-MAT-0006) ELi Z

11. Station Computer Software/Hardware (DNAP-0306) Li z

12. Plant Computer Systems (STD-GN-0028) Li z

13. Plant Flooding Eli Z

14. Heavy Loads (VPAP-0809) Li [

15. Post-Accident Monitoring (Reg. Guide 1.97) (STD-GN-0035) Li [

16. Heating, Ventilation and Air Conditioning (HVAC) Li [

17. Simulator Li [

18. Setpoints, Station Curves, Instrument Scaling & Instrument'Uncertainty Calculations Li (VPAP-0303) (STD-GN-0030)

19. Flow-Accelerated Corrosion (FAC) Program (ER-AA-FAC7 10 & ER-AA-FAC-1002) EL Z

20. Electromagnetic Interference Review (STD-EEN-0225 & STD-EEN-0308) EL Z_

21. Equipment Data System (EDS) (VPAP-0310) EL Z

22. ALARA (VPAP-2102) (STD-GN-0019) Li Z

23. Cumulative Effects on Plant Systems EL 0

24. Operating Experience and Recent NRC and Industry Concerns Li z

25. Impact of/on Other Design Changes EL Z

26. Equipment Added, Removed, or Modified EL E

27. System and Plant Design Basis Documents (CM-AA-DBD-1001) Li [

28. Removable Blocks and Other Barriers Li Z

29. Environmental Impact (Non-Radiological) (VPAP-0109 & 2810) Li Z

30. Masonry Block Walls (STD-CEN-0040) EL Z

31. Training Li Z

32. Recommended Spare Parts EL IZ (July 08)

SNOuN-PROPRIETARY ATTACHMENT 10 - ET CEP 10-0006 Rev. 0 S-Dominion- Page 2 of 3 Programs Review Checklist Page 2 of 3 ST -N-0iI Yes No Subject

33. Labeling (OP-AA-1200) Lii [

34. Abandonment of Equipment or Spare of Electrical Equipment El Z

35. Vendor Technical Manuals (VTMs) (VPAP-0602) El [

36. Reactivity Management (OP-AP-300) EIl

37. Equipment/System Response Times Dl [

38. Technical Requirements Manual (LI-AA-101) El [

39. Maintenance Rule (ER-AA-MRL-100) El [

40. Containment Heat Sink Tracking and Evaluation (NF-AA-NSA-5008) El [

41. Motor Operated Valves (MOV) (VPAP-0805) El [

42. Air Operated Valves (AOV) (VPAP-0816) El [

43. Common Cause Failure El [

44. SSC (Structure, System or Component)- Operation and Control El [

45. Protection and Control Analysis El Z

46. Personnel and Equipment Safety El Z

47. Emergency Plan N

48. Nuclear Material Control (VPAP-1406) El N

49. License Renewal Rule Program and Aging Management Activities (ER-AA-AMP-101) El Z

50. Chemical Reactivity Z

51. Early Site Permitting Program (North Anna) El [

52. Protective Coatings - Inside/Outside Containment (DNES-VA-MAT-1004 and 1007) El Z

53. Single Point Vulnerability (SPV) (ER-AA-PRS-1005) Z

54. Boric Acid Corrosion Control Program (BACCP) (ER-AP-BAC-1Z0) E] Z

55. Generic Letter (GL) 89-13 Program (NASES-3.20 and ER-SU-5314) El

56. Inservice Inspection El Z

57. Inservice Testing El [

58. Appendix J Program (NASES-3.18 for NAPS and 0-NSP-CT-100 for SPS) El [

59. Time Critical Operator Actions (TCOAs) (0-OSP-TCA-001) El [

60. Heat Exchanger Program (ER-AA-HTX-10 & ER-AA-HTX-1003) El [

61. B.5.b Program (EP-AA-505 - when implemented) El [

62. Cyber Security (IT-AA-CYB-103) El [

63. Other Concerns El Z (July 08)

ATTACHMENT 10 - ET CEP 10-0006 Rev. 0 Page 3 of 3 S2Dominion ProgramsReview Checklist Supplement NON-PROPRIETARY PaDGeN30of1 A I~ 666 Document Number: Station:

ET-CEP-1O-0006. REV. 0 2 North Anna NSurry E] Other Appendix R The Appendix R/Fire Protection control procedure for fire barriers is affected by this ET.

Attachment 2, Controlled Document Summary, block 10 provides for CDRR control of documents requiring revision of CM-AA-FPA-101.

Serial No.10-478 Docket Nos. 50-280/281/338/339 ENCLOSURE 3 Application for Withholding from Public Disclosure and Affidavit of J. Alan Price Virginia Electric and Power Company (Dominion)

North Anna and Surry Power Stations Units I and 2

Serial No.10-478 Docket Nos. 50-280/281/338/339 Enclosure 3 Page 1 of 2 10 CFR § 2.390 APPLICATION FOR WITHHOLDING AND AFFIDAVIT OF J. ALAN PRICE I, J. Alan Price, Vice President - Nuclear Engineering, state that:

1. I am authorized to execute this affidavit on behalf of Virginia Electric and Power Company (Dominion).

2. Dominion is submitting for the NRC's information Dominion Engineering Transmittal (ET), ET-CEP-10-0006, Revision 0, "Evaluation of Aluminum Conduit Seal Penetration Fire Tests," dated May 13, 2010. ET-CEP-10-0006, Revision 0, contains the test reports for aluminum conduit penetration configuration fire tests performed for Surry and North Anna Power Stations Units 1 and 2. The Proprietary Version of the ET contains proprietary commercial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4) because:

a. This information is being held in confidence by Dominion.

b.',This information is of a type that is held in confidence by Dominion, and there is a rational basis for doing so because the information contains sensitive commercial information regarding fire barrier test protocol and the results of that testing.

c. This information is being transmitted to the NRC in confidence.

d. This information is not available in public sources and could not be gathered readily from other publicly available information.

e. Public disclosure of this information would create substantial harm to the competitive position of Dominion by disclosing test configurations and the associated test results for various aluminum conduit penetrations to other parties whose commercial interests may be adverse to those of Dominion. Furthermore, Dominion has expended significant engineering resources in the development of the information. Therefore, the use of this confidential information by competitors would permit them to use the information developed by Dominion without the expenditure of similar resources, thus giving them a competitive advantage.

3. Accordingly, Dominion requests that the designated document be withheld from public disclosure pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4).

Serial No.10-478 Docket Nos. 50-280/281/338/339 En16 eur--3 Page 2 of 2 Virginia Electric and Power Company J. AIao P)ice Vice -retident -Nuclear Engineering STATE OF Afw rui" COUNTY OF Pen i

) Co Subscribed and sworn to me, a Notary Public, in and for the County and State above named, this 3Žý rl day of 'ý , 2010.

L - - - - - - - - - - - - - A I

GINGER LYNN MELTON Notary Public Commonwealth of Virginia My Commission Expires: "I'1/\'\

310847 ,TV.,,as m"Igicc'o, o, My Commission Expires Apr 30, 2013

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