L-92-008, Supplemental Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations.

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Supplemental Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations.
ML070850193
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 08/02/2006
From: Faulhaber H
Omaha Public Power District
To:
Document Control Desk, NRC/NRR/ADRO
References
GL-06-003, GL-92-008, LIC-06-0076
Download: ML070850193 (2)


Text

-:D(--' -))Cý(ýCLkd Dcirý',;-)O OPPD Omaha Public PowerDistinct 444 South 16th Street Mall Omaha NE 68102-2247 August 2, 2006 LIC-06-0076 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Reference:

1. Docket No. 50-285
2. NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" dated April 10, 2006 (NRC-06-0044) (ML053620142)
3. Letter from Gary Gates (OPPD) to Document Control Desk (NRC) dated April 15, 1993, Thermo-Lag 330-1 Fire Barriers - Generic Letter 92-08 Response (LIC-93-0103)
4. Letter from Harry J. Faulhaber (OPPD) to Document Control Desk (NRC) dated June 2, 2006, Fort Calhoun Station Unit No. 1, Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" (LIC-06-0061)

SUBJECT:

Fort Calhoun Station Unit No. 1, Supplemental Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" In response to Reference 2, the Omaha Public Power District (OPPD) provided Reference 4 which constituted the 60-day response for information requested in Reference 2 for Fort Calhoun Station Unit No. I (FCS). In an email dated June 20, 2006, the NRC requested additional information regarding Reference 4, specifically a list of fire protection materials and how they were tested or evaluated.

This information was not specifically requested in Reference 2; however OPPD is voluntarily providing the requested information.

FCS does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant post-fire safe shutdown circuits or for any other applications at the plant site.

IK FCS uses 3M Interam E50A, Pyrocrete, and Pabco materials as fire barrier protection for redundant trains of safe shutdown equipment located in the same fire area to satisfy 10 CFR 50, Appendix R III.G requirements. Installation and inspection procedures have verified that these fire barrier materials were installed in a manner consistent with tested configurations.

Deviations from tested and analyzed configurations were evaluated in accordance with Generic Letter 86-10, Supplement 1. These evaluations provide the necessary assurance that the installed fire barrier systems would possess the commensurate level of fire protection.

OPPD inspects fire barrier configurations outside of containment on an 18 month frequency and inside containment on a refueling outage frequency.

Employment with Equal Opportunity 4171 A (a CC-Q-1A LY) 3 12-ýPý0?

U. S. Nuclear Regulatory Commission LIC-06-0076 Page 2 OPPD responded to -3eneric Letter 92-08 in Reference 3. Reference 3 confirmed that FCS does not credit or rely upon the use of Thermo-Lag 330-1 barriers to meet physical separation, to meet a condition of the plant operating license or to satisfy a licensing commitment. Thermo-Lag 330-1 barriers are not used at FCS to protect safety-related systems or components.

FCS Design Engineering Procedure PED-GEI-4, Fire Protection System Interaction, is in place to ensure any plant configuration change that occurs will consider, in part, impacts to existing fire barrier systems or required evaluations of any new fire barrier systems intended to be installed at the station. This interaction procedure and checklist ensures adequate review of all engineering configuration change processes to properly evaluate any new or proposed fire barrier systems, to ensure adequacy and maintenance of licensing and design basis requirements.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on August 2, 2006.)

If you have additional questions, or require further information, please contact Thomas R. Byrne at (402) 533-7368.

Sincer ly, Zany J tberL Division Manager Nuclear Engineering HJF/TRB/trb

Text

-:D(--' -))Cý(ýCLkd Dcirý',;-)O OPPD Omaha Public PowerDistinct 444 South 16th Street Mall Omaha NE 68102-2247 August 2, 2006 LIC-06-0076 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Reference:

1. Docket No. 50-285
2. NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" dated April 10, 2006 (NRC-06-0044) (ML053620142)
3. Letter from Gary Gates (OPPD) to Document Control Desk (NRC) dated April 15, 1993, Thermo-Lag 330-1 Fire Barriers - Generic Letter 92-08 Response (LIC-93-0103)
4. Letter from Harry J. Faulhaber (OPPD) to Document Control Desk (NRC) dated June 2, 2006, Fort Calhoun Station Unit No. 1, Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" (LIC-06-0061)

SUBJECT:

Fort Calhoun Station Unit No. 1, Supplemental Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" In response to Reference 2, the Omaha Public Power District (OPPD) provided Reference 4 which constituted the 60-day response for information requested in Reference 2 for Fort Calhoun Station Unit No. I (FCS). In an email dated June 20, 2006, the NRC requested additional information regarding Reference 4, specifically a list of fire protection materials and how they were tested or evaluated.

This information was not specifically requested in Reference 2; however OPPD is voluntarily providing the requested information.

FCS does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant post-fire safe shutdown circuits or for any other applications at the plant site.

IK FCS uses 3M Interam E50A, Pyrocrete, and Pabco materials as fire barrier protection for redundant trains of safe shutdown equipment located in the same fire area to satisfy 10 CFR 50, Appendix R III.G requirements. Installation and inspection procedures have verified that these fire barrier materials were installed in a manner consistent with tested configurations.

Deviations from tested and analyzed configurations were evaluated in accordance with Generic Letter 86-10, Supplement 1. These evaluations provide the necessary assurance that the installed fire barrier systems would possess the commensurate level of fire protection.

OPPD inspects fire barrier configurations outside of containment on an 18 month frequency and inside containment on a refueling outage frequency.

Employment with Equal Opportunity 4171 A (a CC-Q-1A LY) 3 12-ýPý0?

U. S. Nuclear Regulatory Commission LIC-06-0076 Page 2 OPPD responded to -3eneric Letter 92-08 in Reference 3. Reference 3 confirmed that FCS does not credit or rely upon the use of Thermo-Lag 330-1 barriers to meet physical separation, to meet a condition of the plant operating license or to satisfy a licensing commitment. Thermo-Lag 330-1 barriers are not used at FCS to protect safety-related systems or components.

FCS Design Engineering Procedure PED-GEI-4, Fire Protection System Interaction, is in place to ensure any plant configuration change that occurs will consider, in part, impacts to existing fire barrier systems or required evaluations of any new fire barrier systems intended to be installed at the station. This interaction procedure and checklist ensures adequate review of all engineering configuration change processes to properly evaluate any new or proposed fire barrier systems, to ensure adequacy and maintenance of licensing and design basis requirements.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on August 2, 2006.)

If you have additional questions, or require further information, please contact Thomas R. Byrne at (402) 533-7368.

Sincer ly, Zany J tberL Division Manager Nuclear Engineering HJF/TRB/trb