ML20115A575

Responds to RAI Re GL 92-08, Thermo-Lag Fire Barriers

ML20115A575
Person / Time
Site:	Grand Gulf
Issue date:	06/28/1996
From:	Hutchinson C ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115A581	List: ML20115A575 ML20115A583 ML20115A585
References
GL-92-08, GL-92-8, GNRO-96-00073, GNRO-96-73, NUDOCS 9607080196
Download: ML20115A575 (5)

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Enter y Oper;tions, loc.

'e ENTERGY

~- eo eo 7se Port Gitson, MS 39150 '

Tei 601437 2800 C. R. Hutchinson -

Vr.e Pesdent 1 June 28, 1996- cru wm,, sei U.S. . Nuolear Regulatory Comunission Document Control Desk Mail Stop P1-37 Nashington,'D.C. 20555

-Subjects Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Response to the Request for Additional Information Regarding Generic Letter (GL) 92-08 Itasa 2 (c) : Thorsso-Lag Fire Barriers, dated November 6, 1995 I

GNRO-96/00073 Gentlement Generic Letter '(GL) 92-00 was issued to obtain inforunation needed'to verify that the Thermo-Lag 330-1 fire barrier systesna comply with NRC fire protection requirements for protecting equipment required to achieve and maintain safe shutdown in the event of a fire. Reporting Requirosasnt Item 2 (c) of GL 92-00 requests information concerning the ampacity dorating of cables. enclosed in Thermo-Lag fire barriers and the evaluation and application of test results performed to determine the i

.ampacity dorating of Thermo-Lag barriers.

The Staff's- Request for Additional Information (RAI) dated November 6, ,

1995 (Reference 1). concluded that GGNS' previous responses to Item 2(c) of GL 92-00 were incosplete. In order to provide an adequate response, the Staff requested in'the November 6, 1995 RAI that GGNS submit aspacity l dorating evaluations, including any applicable test reports. The l

anticipated test procedure.or a description of the analytical methodology (including typical calculations) that will be used to determine the ampacity dorating parameters for Thermo-Lag fire barriers installed at GGNS were also requested. This information was to be subunitted within 45 days freen receipt of the November 6,1995 RAI.

An interim response to the November 6,1995 RAI delineating our comunitted schedule for providing the complete response to reporting requirement

2 (o) by June 30, 1996 was subenitted by letter dated December 20, 1995

[ Reference 2). This' submittal' dockets the GGNS response to GL 92-00 reporting requirement Item 2 (c) , as comunitted in our December 20, 1995 interim response.

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j June-28, 1996

.mIRO-96/00073 Page 2 of 4- l

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--We have completed engineering evaluations of GGNS.Thermo-Lag fire barriers >

to address ampacity dorating parameters ! References 3 and 4]. The ~l completed evaluations are provided as Attachments 1 and 2. Our evaluations )

include development of an ampacity dorating database which lists all cables and raceways evaluated with pertinent ampacity dorating data and incorporates input collected from Thermo-Lag barrier walkdowns.-No plant l

specific.ampacity dorating tests were performed, and consequently no test j reports or anticipated test procedures were developed.

Our engineering evaluations conclude that ampacity dorating factors for all GONS electrical cables enclosed in Thermo-Lag raceways are bound by j generic. industry testing previously performed. These conclusions are ]

based on comparisons of GGNS Thermo-Lag barriers with barriers tested for ]

ampacity dorating factors utilising the draft IEEE Standard P848 test j protocol which has previously been reviewed by the NRC, in lieu of l

. utilizing an analytical methodology to calculate ampacity dorating i factors. The comparisons demonstrate that the tested configurations bound l comparable GGNS' installations, and therefore relevant ampacity dorating .l

. factors can be utilized to analyse GGNS Thermo-Lag installations. Although ]

the Staff has'not formally endorsed this draft standard, a submittal to j address ampacity dorating of Thermo-Lag clad raceways based on this draft

- standard has been approved and distributed to licensees by the NRC for ,

. potential generic application. The application of these ampacity dorating factors to Thermo-Lag clad GGNS cable raceway installations determine that

. cables are adequately sized.

In addition to' fire endurance and aspacity dorating, the NRC also d

expressed concerns regarding the material representativeness of Thermo-Lag

. materials. By letter dated December 28, 1994 [ Reference 5) the Staff t- requested GGNS to provide information demonstrating that Thermo-Lag

, . materials installed at GGNS are representative of materials and

- configurations tested during the industry testing initiative coordinated

! by the Nuclear Energy Institute (NEI) . As part of the GGNS response I ~

[ Reference'6), we stated that samples of Thermo-Lag material removed from

' installed configurations and warehouse stock were to be examined to determine chemical consistency between installed and tested configurations. Wo.further stated that, with GGNS Thermo-Lag materials

. demonstrated to be representative of tested materials, we plan to use the L results of generic' testing and industry experience to address GGNS Thermo-l Lag issues..

Tho' industry testing. initiative is now complete. Results conclude that j

' GGNS installed and stock Thermo-Lag materials have chemical compositions I

, that are consistent with the Thermo-Lag materials tested during the .I

~ industry testing' program coordinated by NEI. We anticipato use of our

! lccamercial grade-dedication program-to ensure material parameters for new

. materials procured.from Thermal Science,'Inc..

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, i U iJune 28, 1996  :

, , GNRO-96/00073 _ i j Page.3 of 4 c .

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4 inne engineering evaluations are considered to fulfill the. reporting requiremant' cf GL 92-08 Item 2 (c) . regarding ampacity dorating of GGNS '

electrical raceways enclosed in.Thermo-Lag barriers. Positive.results from '!

l the industry chemical composition testing initiative provides a high

degree of confidence that GGNS installed and stock Thermo-Lag materials

are consistent with tested materials, and thus resolves the issue of r

' material: representativeness. As previously committed,: fire endurance corrective actions for GGNS Thermo-Lag barriers are anticipated to be.

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' . completed prior to startup from our eighth refueling outage, scheduled for

' November of this year. ,

This information is being submitted under affirmation in accordance with l' 10 CFR 50.54 (f) (Attachment 3) . In accordance with GL 92-08 reporting

' requirement 3, we will provide written confirmation upon completion of all corrective actions required by this generic letter.

Please contact. Charles E. Brooks at (601) 437-6555 should you have any  ;

l questions, or require additional information.

i l Your truly,

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4 CRM /mtc attachment: 1. GGNS Engineering Report GGNS-96-0006 ,

2. GGNS Rngineering Report GGNS-96-0032

3. Affirmation of the GGNS Response to 92-08 RAI (Item 2C),  ;

, dated November 6, 1995 cca Mr. R. B. McGehee (w/a)-

Mr. R. S. Reynolds (w/a)

Mr. J. E. Todrow (w/a)

[ Mr. M. L. Thomas (w/a)  ;

Mr. J. W. Yelvertson (w/a) t Mr. L. J. Callan (w/a)

Regional Administrator i U.S. Nuclear Regulatory Commission Region IV

. 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 l'

Mr. J. N..Donohew, Project Manager (w/2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

, Mail Stop 13H3 washington, D.C. 20555

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References:

1. Letter U.S. Nuclear Regulatory Commission to C. Randy Hutchinson, dated November 6, 1995 - Request for Additional Information Regarding Generic Letter 92-08, "Thermo-Lag 330-1 Fire Barriers".

2. Letter C. R. Hutchinson to the U.S. Nuclear Regulatory Commission, dated December 20, 1995 - Response to Request for Additional l Information, Generic Letter 92-08, dated November 6, 1995: "Thermo-Lag 330-1 Fire Barriers".

3. Engineering Report No. GGNS-96-0006 Revisira 0, " Grand Gulf Nuclear Station Engineering Report for Evaluation of Ampacity Deratings for Thermo-Lag Fire Barrier Enclosed Cables in Fire Areas /Eones OC202, OC402, OC702 and 1A316".

4. Engineering Report No. GGNS-96-0032 Revision 0, " Grand Gulf Nuclear Station Engineering Report for Evaluation of Ampacity Deratings for Thermo-Lag Fire Barrier Enclosed Cables in Fire Areas / Zones OC214, OC302, OC308 and 1A539".

5. Letter U.S. Nuclear Regulatory Commission to C. Randy Hutchinson, dated December 28, 1994 " Follow up to the Request for Additional Information Regarding Generic Letter 92-08".

6. Letter C. R. Hutchinson to the U.S. Nuclear Regulatory Commission, dated March 29, 1995 - Response to Follow-up to the Request for Additional Information (RAI) Regarding Generic Letter 92-08 Issued Pursuant to 10CFR50.54 (f) on December 28, 1994: "Thermo-Lag 330-1 Fire Barriers",

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l Attachment 1 to GNRO-96/00073

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