ML20059B057

Forwards Rev to RAI Re GL-92-08, Thermo-Lag 330-1 Fire Barriers,Per 10CFR50.54(f) for Plant

ML20059B057
Person / Time
Site:	Perry
Issue date:	12/23/1993
From:	Callan L Office of Nuclear Reactor Regulation
To:	Stratman R CLEVELAND ELECTRIC ILLUMINATING CO.
References
GL-92-08, GL-92-8, NUDOCS 9401030277
Download: ML20059B057 (9)

Text

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y. December- 23, 1993 $

'Dockht No. 50-440-t Mr. Robert A. Stratman

'.Vice President Nuclear - Perry l

.Centerior Service Company i P.O. Box 97, S270 Perry, Ohio 44081 l

SUBJECT:

REVISED REQUEST FOR ADDITIONAL'INFORMATION REGARDING GENERIC LETTER 92-08, "THERMO-LAG 330-1 FIRE BARRIERS," PURSUANT TO 10 CFR 50.54(F), PERRY NUCLEAR POWER PLANT, UNIT N0. 1  ;

The enclosure contains a revised request for information pursuant to 10-CFR, ,

Part 50.54(f) that was previously issued to you on December 20, 1993. The principal changes are located .in item I.B.2. of the request for additional ,

information. We apologize if this has caused y my nconvienience. Should you have any questions, please contact yot:r Project Manager, Robert Stransky at (301).504-1346. ,

Sincerely, Brian Grimes /for ,

L. J. Callan Acting Associate Director-for_ Projects Office of Nuclear Reactor Regulation  :'

Enclosure:

Request for Additional Information cc w/ enclosure: t See next page DISTRIBUTION i Docket File CMcCracken MGamberoni RStransky .

NRC PDR PMadden RIngram, PMSB MRushbrook  !

Local PDR CBerlinger JMartin, RIII GMulley (0IG)

JHannon RJenkins OGC EPawlik (RIII/01): 1 JRoe GMulley (0IG) ACRS (10) JZwolinski  :

LCallano c[/ t 0FFICE LA:PD33h/n PM:PD33 PD:PD33 . AD/[// 1 NAME MRushbrook RStran'blik7 JHannobb J. ((LA[

DAT'E 12/ U /93 ll2M/93 12/0/93 12/7f/93 COPY- /fe/No /I$s)No [es/No Yes/No 0FFICIAL REGORD COPY -FILENAME: G:tPERRY\lHERMO.LT2 9401030277 931223 PDR ADOCK 05000440 ygn3 I h hf

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055541001

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          .....                                      December 23, 1993 Docket No. 50-440                                                                        ,

Mr. Robert A. Stratman Vice President Nuclear - Perry Centerior Service Company P.O. Box 97, S270 Perry, Ohio 44081

Dear Mr. Stratman:

SUBAu f: REVISED REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER , 92-08, " THERM 0-LAG 330-1 FIRE BARRIERS," PURSUANT 10 10 CFR 50.54(F), PERRY NUCLEAR POWER PLANT, UNIT NO. 1 The enclosure contains a revised request for information pursuant to 10 CFR, Part 50.54(f) that was previously issued to you on December 20, 1993. The principal changes are located in item I.B.2. of the request for additional information. We apologize if this has caused you any inconvienience. Should , you have any questions, please contact your Project Manager, Robert Stransky at (301) 504-1346. 7 S i,n.cprely, g ,, i I A

                                               /
                                               #     L. J. Callan                              '
                                           ,        Acting Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure: See next page t

Mr. Robert A. Stratman Perry Nuclear Power Plant Centerior Service Company Unit Nos. I and 2 cc: Jay E. Silberg, Esq. Mr. James W. Harris, Director Shaw, Pittman, Potts & Trowbridge Division of Power Generation i 2300 N Street, N.W. Ohio Department of Industrial Relations ! Washington, D.C. 20037 P. O. Box S25 Columbus, Ohio 43216 Mary E. O'Reilly Centerior Energy Corporation The Honorable Lawrence Logan 300 Madison Avenue Mayor, Village of Perry Toledo, Ohio 43652 4203 Harper Street Perry, Ohio 44081 Resident Inspector's Office The Honorable Robert V. Orosz U.S. Nuclear Regulatory Commission Mayor, Village of Ncrth Perry Parmly at Center Road North Perry Village Hall Perry, Ohio 44081 4778 Lockwood Road North Perry Village, Ohio 44081 Regional Administrator, Region III r U.S. Nuclear Regulatory Commission Attorney General ' 801 Warrenville Road Department of Attorney General ' Lisle, Illinois 60532-4351 30 East Broad Street Columbus, Ohio 43216 Lake County Prosecutor Lake County Administration Bldg. Radiological Health Program 105 Main Street Chio Department of Health Painesville, Ohio 44077 Post Office Box 118 Columbus, Ohio 43266-0118 Ms. Sue Hiatt OCRE Interim Representative Ohio Environmental Protection Agency 8275 Munson DERR--Compliance Unit Memtor, Ohio 44060 ATIN: Zack A. Clayton P. O. Box 1049 Terry J. Lodge, Esq. Columbus, Ohio 43266-0149 618 N. Michigan Street, Suite 105 Toledo, Ohio 43624 Mr. Thomas Haas, Chairman Perry Township Board of Trustees Ashtabula County Prosecutor 3750 Center Rd., Box 65 25 West Jefferson Street Perry, Ohio 44081 Jefferson, Ohio 44047 State of Ohio Mr. Kevin P. Donovan Public Utilities Commission Cleveland Electric Illuminating Company East Broad Street Perry Nuclear Power Plant Columbus, Ohio 43266-0573 P. O. Box 97, E-210 Perry, Ohio 44081 David P. Igyarto, General Manager Cleveland Electric Illuminating Company 6 James R. Williams, Chief of Staff Perry Nuclear Power Plant Ohio Emergency Management Agency P. O. Box 97, SB306 2825 West Granville Road Perry, Ohio 44081 Worthington, Ohio 43085

t ENCLOSURE REQUEST FOR ADDITIONAL'INFORMATION REGARDING GENERIC LETTER 92-08

                        " THERM 0-LAG 330-1 FIRE BARRIERS" PURSUANT TO 10 CFR 50.54(f)                             .;

I. Thermo-Lag Fire Barrier Configurations and Amounts A. Discussion Generic Letter (GL) 92-08,"Thermo-Lag 330-1 Fire Barriers," applied  : to all I-hour and all 3-hour Thermo-Lag 330-1 materials and barrier  ! systems constructed by any assembly method, such as by joining preformed panels and conduit preshapes, and trowel, spray, and  : brush-on applications. This includes all fire barriers, all i barriers to achieve physical independence of electrical systems, radiant energy heat shields, and barriers installed to enclose intervening combustibles. B. Required Information

1. Describe the Thermo-Lag 330-1 barriers installed in the plant to

a. meet 10 CFR 50.48 or Appendix R to 10 CFR Part 50,

b. support an exemption from Appendix R,

c. achieve physical independence of electrical systems, <

d. meet a condition of the plant operating license, ,

e. satisfy licensing commitments.

The descriptions should include the following information: , the intended purpose and fire rating of the barrier (for - example, 3-hour fire barrier,1-hour fire barrier, radiant energy heat shield), and the type and dimension of the , barrier (for example, 8-ft by 10-ft wall, 4-ft by 3-ft by i 2-ft equipment enclosure, 36-inch-wide cable tray, or 3-inch-diameter conduit).  ;

2. For the total population of Thermo-Lag fire barriers described under Item I.B.1, submit an approximation of:  ;

a. For cable tray barriers: the total linear feet and square feet of 1-hour barriers and the total linear feet and square feet of '-hour barriers.

b. For conduit barriers: the total linear feet of 1-hour <

barriers and the total linear feet of 3-hour barriers.

c. For all other fire barriers: the total square feet of 1-hour barriers and the . total square feet of 3-hour  ;

barriers.

d. For all other barriers and radiant energy heat I shields: the total linear or square feet of 1-hour barriers and the total linear or square feet of 3-hour barriers, as appropriate for the barrier configuration. '

or type.

• l II. Important Barrier Parameters A. Discussion In a letter of July 29, 1993, from A. Marion, NUMARC, to C. McCracken, NRC, NUMARC stated: " Relative to bounded configurations, ... (i]t will be the utilities' responsibility to verify their baseline installations are bounded." Furthermore, i NUMARC stated that the parameters of importance fcr utility use of data from the industry Thermo-Lag fire barrier test program are:

1. Raceway orientation (horizontal, vertical, radial bends)

2. Conduit

3. Junction boxes and lateral bends

4. Ladder-back cable tray with single layer cable fill

5. Cable tray with T-Section

6. Raceway material (aluminum, steel)

7. Support protection, thermal shorts (penetrating elements)

8. Air drops Baseline fire barrier panel thickness 9.

10. Preformed conduit panels

11. Panel rib orientation (parallel or perpendicular to the raceway)

12. Unsupported spans l'

13. Stress skin orientation (inside or outside)

14. Stress skin over joints or no stress skin over joints

15. Stress skin ties or no stress skin ties

16. Dry-fit, post-buttered joints or prebuttered joints  !

17. Joint gap width -!

18. Butt joints or grooved and scored joints

19. Steel bands or tie wires

20. Band / wire spacing

21. Band / wire distance to joints

22. No internal bands in trays -

23. No additional trowel material over sections and joints or  :

additional trowel material applied '

24. No edge guards or edge guards Each NUMARC cable tray fire test specimen includes 15 percent cable i fills (i.e., a single layer of cables uniformly distributed across i the bottom of the cable tray). This approach requires consideration  ;

of plant-specific cable information during the assessments of tested i configurations and test results in relation to plant-specific  ; Thermo-Lag configurations; for example, cable trays with less ' thermal mass (cable fill) than the NUMARC test specimens, different , cable types, and the proximity of the cables to the Thermo-Lag (e.g., cables may be installed in contact with the unexposed surface of the Thermo-Leg or may come into contact during a fire if the . Thermo-Lag material sags). In its letter of July 29, 1993, NUMARC i stated: " Utilities using the results of the NUMARC testing will , need to evaluate their installed cable fill and ensure that it is bounded by the tested cable fill." NUMARC is not conducting any , cable functionality tests or evaluations and stated that cable  ! functionality evaluations will be performed by utilities using data l from the generic program.

                                                                                ]

i

-. j l The' parameters of importance concerning cables protected by fire barriers are:

1. Cable size and type (power, control, or instrumentation). l

2. Cable jacket type (thermoplastic, thermoset) and materials.

3. Cable conductor insulation type (thermoplastic, thermoset plastic) and materials. .

4. Cable fill and distribution of cables within the protected f conduit or cable tray. ,

5. Proximity of cables to the unexposed (inside) surfaces of I the fire barrier.

6. Presence of materials between the cables and the unexposed  !

side of the fire barrier material (for example, Sealtemp cloth, which is used in the NUMARC test specimens).

7. Cable operating temperature.  !

Temperatures at which the cables can no longer perform their 8. intended function when energized at rated voltage and . current. Other parameters that are unique to particular barriers, such as interfaces between Thermo-Lag materials and other fire barrier materials or building features (walls, etc.) and internal supports,  ; are also important. In addition, because of questions about the  ; uniformity of the Thermo-Lag fire barrier materials produced over time, NUMARC stated in its letter of July 29, 1993, that "[c]hemical analysis of Thermo-lag materials provided for the program, as well as samples from utility stock, will be performed, and a test report prepared comparing the chemical composition of the respective samples." The results of the chemical analyses may indicate that , variations in the' chemical properties of Thermo-Lag are significant ' and may require additional plant-specific information in the future. B. Required Information  ! i

1. State whether or not you have obtained and verified each of  !

the aforementioned parameters for each Thermo-Lag barrier installed in the plant. If not, discuss the parameters you have not obtained or verified. Retain detailed information on site for NRC audit where the aforementioned parameters . are known.

2. For any parameur that is not known or has not been verified, describe how you will evaluate the in-plant barrier for acceptability. .

3. To evaluate NUMARC's application guidance, an understanding of the types and extent of the unknown parameters is needed.

Describe.the type and extent of the unknown parameters at 1 your plant in this context. F L 4

I:

    ,                                                   III. Thermo-Lag Fire Barriers Outside the Scope of the NUMARC Program A. Discussion In your response to GL 92-08, you indicated that actions necessary to restore the operability of these barriers would be based on the results of the NUMARC test program. During recent meetings with the NRC staff, the Executive Director for Operations and the Conaission, NUMARC descriv' ed the scope of its Thermo-l.ag fire barrier program, the results of the Phase I fire tests, ar.d planned Phase 2 tests, The program is limited to certain 1-hour and 3-hour conduit and cable tray fire barrier configurations and the development of guidance for applying the test results to plant-specific fire barrier configurations. However, NUMARC's program is not intended to bound all in-plant Thermo-Lag fire barrier configurations. In view of the scope of the NUMARC program and the limited success of the Phase 1 tests, it is clear that the NUMARC program will not be sufficient to resolve all Thermo-Lag fire barrier issues identified in GL 92-08. Thcrefore, licensees may need to take additional actions to address fire endurance and ampacity derating concerns with in-plant Thermo-Lag barriers.

B. Required information

1. Describe the barriers discussed under Item I.B.1 that you have determined will not be bounded by the NUMARC test program.

2. Describe the plant-specific corrective action program or plan you expect to use to evaluate the fire barrier configurations particular to the plant. This description should include a discussion of the evaluations and tests being considered to resolve the fire barrier issues identified in GL 92-08 and to demonstrate the adequacy of existing in-plant barriers.

3. If a plant-specific fire endurance test program is anticipated, describe the following:

a. Anticipated test specimens.

b. Test methodology and acceptance criteria including cable functionality.

IV. Ampacity Derating A. Discussion NUMARC has informed the staff that it intends to use the Texas Utilities (TV) Electric Company and Tennessee Valley Authority (TVA) ampacity derating test results to develop an electrical raceway component model for the industry. Additional information is needed to determine whether or not your Thermo-Lag barrier configurations (to protect the safe-shutdown capability from fire or to achieve physical independence of electrical systems) are within the scope of

i k

.                                                                               i the NUMARC program and, if not, how the in-plant barriers will be         i evaluated for the ampacity derating concerns identified in GL 92-08.      !

B. Required Information

1. For the barriers described under Item I.B.1, describe those '

that you have determined will fall within the scope of the NUMARC program for ampacity derating, those that will not be  ; bounded by the NUMARC program, and those for which ampacity derating does not apply. *

2. For the barriers you have determined fall within the scope }

of the NUMARC program, describe what additional testing or , evaluation you will need to perform to derive valid ampacity ' derating factors. >

3. For the barrier configurations that you have determined will not be bounded by the NUMARC test program, describe your plan for evaluating whether or not the ampacity derating tests relied upon for the ampacity derating factors used for ,

those electrical components protected by Thermo-Lag 330-1 ' (for protecting the safe-shutdown capability from fire or to achieve physical independence of electrical systems) are  ; correct and applicable to the plant design. Describe all corrective actions needed and submit the schedule for . completing such actions. 1

4. In the event that the NUMARC fire barrier tests indicate the need to upgrade existing in-plant barriers or-to replace existing Thermo-Lag barriers with another fire barrier l system, describe the alternative actions you will take (and '

the schedule for performing those actions) to confirm that the ampacity derating factors were derived by valid tests ' and are applicable to the modified plant design. Your response to Section IV.B may depend on unknown specifics of the NUMARC ampacity derating test program (for example, the final barrier upgrades). However, your response should be as complete as , possible. In addition, your response should be updated as i additional information becomes available on the NUMARC program. i V. Alternatives . A. Discussion On the basis of testing of Thermo-Lag fire barriers to date, it is ' not clear that generic upgrades (using additional Thermo-Lag materials) can be developed for many 3-hour barrier configurations ' or for some 1-hour barriers (for example,1-hour barriers on wide , cable trays, with post-buttered joints and no internal supports). , Moreover, some upgrades that rely on additional thicknesses of . Thermo-Lag material (or other fire barrier materials) may not be practical due to the effects of ampacity derating or clearance problems.  !

I l  ! B. Required Information Describe the specific alternatives available to you for achie'ving compliance with NRC fire protection requirements in plant areas that contain Thermo-Lag fire barriers. Examples' of possible alternatives to Thermo-Lag-based upgrades include the following: 4

1. Upgrade existing in-plant barriers using other materials.

2. Replace Thermo-Lag barriers with other fire barrier materials or systems.

3. Reroute cables or relocate other protected components.  !

4. Qualify 3-hour barriers as 1-hour barriers and install detection and suppression systems to satisfy NRC fire protection requirements.

VI. Schedules A. Discussion The staff expects the licensees to resolve the Thermo-Lag fire barrier issues identified in GL 92-08 or to propose alternative fire  : protection measures to be implemented to bring plants into , compliance with NRC fire protection requirements. Specifically, as i test data becomes available, licensees should begin upgrades for , Thermo-Lag barrier configurations bounded by the test results. - B. Required Information Submit an integrated schedule that addresses the overall corrective action schedule for the plant. At a minimum, the schedule should address the following aspects for the plant:

1. implementation and completion of corrective actions and fire barrier upgrades for fire barrier configurations within the  ;

scope of the NUMARC program,

2. implementation and completion of plant-specific analyses,-

testing, or alternative actions for fire barriers outside the scope of the NUMARC program. VII.- Sources and Correctness of Information Describe the sources of the information provided in response to this request for information (for example, from plant drawings, quality assurance documentation, walk downs or inspections) and how the accuracy and validity of the information was verified.}}