ML071090024

Request for Additional Information Generic Letter 2006-03 Potentially Nonconforming Hemyc and MT Fire Barrier Configuration (TAC MD1586 and MD1587)

ML071090024
Person / Time
Site:	Hatch
Issue date:	05/08/2007
From:	Martin R NRC/NRR/ADRO/DORL/LPLII-1
To:	Madison D Southern Nuclear Operating Co
Martin R, NRR/DORL, 415-1493
References
GL-06-003, TAC MD1586, TAC MD1587
Download: ML071090024 (5)

Text

May 8, 2007Mr. Dennis R. MadisonVice President - Hatch Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP) - REQUESTFOR ADDITIONAL INFORMATION (RAI) REGARDING GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" (TAC NOS. MD1586 AND MD1587)

Dear Mr. Madison:

The Nuclear Regulatory Commission (NRC) staff is reviewing your responses, dated June 9,and November 28, 2006, to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," as they may apply to the HNP and find that additional information is needed as stated in the enclosure.If you have any questions regarding this response, please contact me at 301-415-1493.Sincerely,/RA/Robert E. Martin, Sr. Project ManagerPlant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-321 and 50-366

Enclosure:

RAI cc w/encl: See next page May 8, 2007Mr. Dennis R. MadisonVice President - Hatch Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 (HNP) - REQUESTFOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2006-03, "POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS" (TAC NOS. MD1586, MD1587)

Dear Mr. Madison:

The Nuclear Regulatory Commission (NRC) staff is reviewing your responses, dated June 9,and November 28, 2006, to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," as they may apply to the HNP and find that additional information is needed as stated in the enclosure.If you have any questions regarding this response, please contact me at 301-415-1493.Sincerely,/RA/Robert E. Martin, Sr. Project ManagerPlant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-321 and 50-366

Enclosure:

RAI cc w/encl: See next pageDISTRIBUTION:

PublicRidsAcrsAcnwMailCenter LPL2-1 R/FRidsNrrDraAfpb (DFrumpkin)

RidsNrrDorlL2-1 (EMarinos)RidsRgn2MailCenter(SShaeffer)

RidsNrrDorlDprRidsNrrPMRMartin (hard copy)

RidsNrrLAMO'Brien (hard copy)RidsOgcRp RidsNrrAfpb (SWeerakkody)

ADAMS No: ML071090024 OFFICENRR/LPL2-1/PMNRR/LPL2-1/LAAFPB/BCNRR/LPL2-1/BCNAMERMartin:ncMO'BrienSWeerakkodyEMarinosDATE04/23/07 04/23/0704/19/0705/8/07 OFFICIAL RECORD COPY EnclosureREQUEST FOR ADDITIONAL INFORMATIONCONCERNING FIRE BARRIER CONFIGURATIONSFOR EDWIN I. HATCH PLANT, UNIT NOS. 1 AND 2Please provide clarifying information regarding whether the following information, based on theletter from Southern Nuclear Operating Company, Inc., dated November 28, 2006, for the Farley Nuclear Plant, also applies to the Edwin I. Hatch Plant, Unit Nos. 1 and 2 (HNP). Item 1 - How was the Promat tested? Is the Promat testing, as described in the November 28, 2006, letter also applicable to HNP? That letter stated: The Promat was tested and qualified to American Society of Testing Materials(ASTM) E119-88 by Performance Contracting Inc. under Omega Point Project No. 8806-90254 (Promat Report SR90-005). This testing included ASTM E119 time-temperature, full scale fire testing for the wall assembly and a small scale fire testing of the ceiling assembly. The test details are documented in Promat Report SR90-005.If this information is not applicable to HNP, please provide the information in the Questionsbelow.Item 2 - What acceptance criteria were used? Were the same acceptance criteria as describedin the November 28, 2006, letter, used? That letter stated:The test acceptance criteria were that of ASTM El 19-88 Section 16 "Conditionsof Acceptance," which meets the acceptance criteria of GL 86-10, Supplement 1.

The 325 degrees Fahrenheit temperature criterion was used, which assumes a maximum temperature rise of 250 degrees Fahrenheit above an ambient temperature of 75 degrees Fahrenheit.If this information is not applicable to HNP, please provide the information in the Questionsbelow.Item 3 - How were installed configurations that were different from tested configurationsevaluated? Were the field installations deviations evaluated similarly as described in the November 28, 2006, letter? That letter stated:An analysis and acceptance for plant specific deviations from the testedconfigurations is included in Performance Contracting Inc. Fire Protection Technical Evaluation (FPTE) FPTE 2006-001, Revision 0. This evaluation received a documented review and approval by a qualified fire protection engineer within Southern Nuclear and found to be consistent with the GL 86-10, Section 3.2.2 criteria.If this information is not applicable to HNP, please provide the information in the Questionsbelow.QUESTIONS, if November 28, 2006, responses do not apply to HNP 1) For HNP, the Promat H board is described as a fire barrier that separates redundanttrains within the same fire area (for example, cable tray enclosures). The response states that Promat H board is tested in accordance with Underwriters Laboratory Standard 263, ASTM Standard E119, and National Fire Protection Association Standard 251. Use of these tests and standards identifies fire testing for building members and assemblies, but does not specifically address 1- and 3-hour fire barrier systems protecting electrical raceways.If the Promat H boards were used in accordance with a listed fire rated assembly (suchas a UL listed assembly), please provide that information.The NRC staff's current guidance for raceway protection is contained in Generic Letter86-10, Supplement 1, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations." The NRC staff is interested in whether the Promat H fire barriers (as installed in the plant) were tested and evaluated (for deviations from the testing) in accordance with the GL 86-10, Supplement 1, guidance. If not, the NRC staff is interested in the following:a)Is the support protection and penetrating item protection for the Promat Hbarriers in the plant representative of the protection provided during the testing?b)Does the testing encompass or bound the installed configurations?

c)Is the plant cable loading (the thermal mass) of the installed configurationsbounded by the tested configurations?

Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:

Laurence BergenOglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349Mr. R. D. BakerManager - Licensing Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295Resident InspectorPlant Hatch 11030 Hatch Parkway N.

Baxley, GA 31531Harold Reheis, DirectorDepartment of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334Steven M. JacksonSenior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684Mr. Reece McAlisterExecutive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334Arthur H. Domby, Esq.Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216ChairmanAppling County Commissioners County Courthouse Baxley, GA 31513Mr. Jeffrey T. GasserExecutive Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295General ManagerEdwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.

U.S. Highway 1 North P.O. Box 2010 Baxley, GA 31515Mr. K. RosanskiResident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515