ML061600213

Donald C. Cook, Units 1 & 2 - 60 Day Response to NRC Generic Letter 2006-03: Potentially Nonconforming Hemyc and MT Fire Barrier Configurations

ML061600213
Person / Time
Site:	Cook
Issue date:	06/01/2006
From:	Peifer M A Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
+kBR1SISP20060621, AEP:NRC:6054-03, GL-06-003
Download: ML061600213 (6)

Text

Indiana Michigan Power INDIANA Cook Nuclear Plant MICHIGAN One Cook Place,ERBridgman, MI 49106&WERO AEPcom A unit of American Electric Pc wer June 1, 2006 AEP:NRC:6054-03 Docket Nos.: 50-315 50-316 U. S. Nuclear Regu Latory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Donald C. Cook Nuclear Plant Units 1 and 2 60 DAY RESPONSE TO NUCLEAR REGULATORY COMMISSION GENERIC LETI'ER 2006-03: POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS Generic Letter 2006-03 notified licensees of deficiencies identified in Hemyc and MT fire barriers during Nuclear Regulatory Commission (NRC) testing that was conducted in 2005. The testing revealed that both materials failed to provide the protective function intended for compliance with existing regulations for the configurations tested. The NRC requested that, within 60 days, licensees provide a statement on whether Hemyc or MT fire barrier material is used in their plants, and a description of the controls that were used to ensure that other fire barrier types relied on for the separation of redundant trains located in a single fire area are capable of providing the necessary level of protection.

Additionally, plants that have installed Hemyc or MT fire barrier material were requested to provide additional information regarding the application of Hemyc or MT fire barrier material.Indiana Michigan Power Company's response to the request is provided in the attachment to this letter.This letter contains no new commitments.

Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Supervisor, at (269) 466-2649.Sincerly, Site Vice President RGV/rdw U. S. Nuclear Regulatory Commission AEP:NRC:6054-03 Page 2

Attachment:

60 Day Response to Nuclear Regulatory Commission Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations c: J. L. Caldwell -NRC Region III K. D. Curry -AEP Ft. Wayne J. T. King- MPSC MDEQ -WHMD/RPMWS NRC Resident Inspector P.S. Tam- NRC Washington, DC U. S. Nuclear Regulatory Commission Page 3 AEP:NRC:6054-03 AFFIRMATION I, Mark A. Peifer, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this response with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M zre true and correct to the best of my knowledge, information, and belief.Indiana Michigan Power Company Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS \ DAY OF .,2006-- -My Commission Expires &a g;J. \DANIELE .BLURGOYNE Notary Public, State od Michigan County d Berrien-MY CommisslOn I.iOres Apr. 4,2008 AC Ie9 County 3f.a Attachment to AEP:NRC:6054-03 60 DAY RESPONSE TO NUCLEAR REGULATORY COMMISSION GENERIC LETTER 2006-03: POTENTIALLY NONCONFORMING HEMYC AND MT FIRE BARRIER CONFIGURATIONS Generic Letter (GL) 2006-03 notified licensees of deficiencies identified in Hemyc and MT fire barriers during Nuclear Regulatory Commission (NRC) testing that was conducted in 2005. The testing revealed that both materials failed to provide the protective function intended for compliance with existing regulations for the configurations tested. The NRC requested that, within 60 days, licensees provide a statement on whether Hemyc or MT fire barrier material is used in their plaints, and a description of the controls that were used to ensure that other fire barrier types relied on for separation of redundant trains located in a single fire area are capable of providing the necessary level of protection.

Additionally, plants that have installed Hemyc or MT fire barrier material were requested to provide additional information regarding the application of Hemyc or MT fire barrier material.Indiana Michigan Power Company's (I&M's) response to the request is provided below.NRC Request la Provide a statement on whether Hemyc or MT fire barrier material is used at the Donald C. Cook Nuclear Plant (CNP) and whether it is relied upon for separation and/or safe shutdown purposes in accordance with the licensing basis, including whether Hemyc or MT is credited in other analyses (e.g., exemptions, license amendments, GL 86-10 analyses).

I&M Response to la Neither He myc nor MT fire barrier material is installed at CNP.NRC Request lb Provide a description of the controls that were used to ensure that other fire barrier types relied on jfr separation of redundant trains located in a single fire area are capable of providing the necessary level of protection.

Licensees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.I&M Response to lb As a result of the deficiencies identified for Thermo-Lag material in GL 92-08, Darmatt was installed at CNP to replace most of the Thermo-Lag material.

With support provided by Transco Pioducts, Incorporated, Darmatt was installed with an approved plant procedure that was based on the vendor recommended procedure for the installation of Darmatt KM1 Attachment to AEP:NRC:6054-03 Page 2 Fire Protection System The vendor procedure was tailored to address the Darmatt applications at CNP. Fire test reports supporting the CNP Darmatt applications are identified in the procedure.

The replacement of Thermo-Lag material with Darmatt was documentel in I&M's response to GL 92-08 (References 1 and 2).Mecatiss has been used as a cable tray 1-hour fire wrap in one fire zone to achieve compliance with 10 CFR 50, Appendix R, Section III.G.2(b).

With support provided by Brand Fire Protection Services, Mecatiss was installed in accordance with a Brand Fire Protection Services manual. Fire test reports supporting the CNP application are identified in the manual.Thermo-Lzg material is used as a fire-rated barrier to provide separation between fire areas in the Unit 1 and Unit 2 hot shutdown panel enclosures.

This use of Thermo-Lag material was qualified with an application specific evaluation that was supported by field testing.This use of Thermo-Lag material is documented in References 1 and 2. Additionally, Thermo-Lag material in the Unit 1 CD Diesel Generator Room and the Unit 2 AB Diesel Generator Room, in conjunction with the existing fire detection and fire suppression system, has been evaluated to credit the current barrier configuration for compliance with 10 CFR 50, Appendix R, Section III.G.2(c).

The Darmntt, Mecatiss, and Thermo-Lag applications are inspected every 24 months to ensure coninued compliance.

CNP is transitioning to 10 CFR 50.48(c), NFPA 805 Standard.

During this transition, CNP intends to re-establish the compliance of the Thermo-Lag, Darnatt, and Mecatiss fire wraps through the application of technical evaluations that consider potential adverse effects, risk, defense-in-depth, and safety margins.NRC Request 2 For those licensees that have installed Hemyc of MT fire barrier materials, discuss the following ipt detail:[Items n 9t repeated as this request is not applicable to CNP.]I&M Response to 2 This item is not applicable because neither Hemyc nor MT fire barrier materials are installed at CNP.

Attachment to fAEP:NRC:6054-03 Page 3 NRC Request 3 No later than December 1, 2007, addresses that identified in L.a Hemyc and/or MT configurations are requested to provide a description of actions taken to resolve the nonconforming conditions described in 2.d2 I&M Response to 3 This item is not applicable because neither Hemyc nor MT fire barrier materials are installed at CNP.References

1. Letter from E. E. Fitzpatrick, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Response to Generic Letter (GL) 92-08, 'Thermo-Lag 330-1 Fire Barriers," AEP:NRC:0692DB, dated December 27, 1996.2. Letter from John F. Stang, Jr., NRC, to Robert P. Powers, I&M, "Completion of Licensing Action for Generic Letter 92-08, 'Thermo-Lag 330-1 Fire Barriers,'

Dated December 17, 1992 for Donald C. Cook Nuclear Power Plant, Unit Nos. 1 and 2, TAC Nos.M85538 and M85539," dated August 27, 1998.