[Federal Register Volume 70, Number 141 (Monday, July 25, 2005)]
[Notices]
[Pages 42596-42602]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E5-3941]
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NUCLEAR REGULATORY COMMISSION
Proposed Generic Communication; Impact of Potentially Degraded
Hemyc and Mt Fire Barriers on Compliance With Approved Fire Protection
Programs
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of opportunity for public comment.
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SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is proposing to
issue a generic letter (GL) to:
(1) Request that addressees evaluate their facilities to confirm
compliance with the existing applicable regulatory requirements in
light of the information provided in this generic letter and, if
appropriate, take additional actions. Specifically, although Hemyc and
MT fire barriers in nuclear power plants (NPPs) may be relied on to
protect electrical and instrumentation cables and equipment that
provide safe shutdown capability during a fire, recent NRC testing has
revealed that both materials failed to provide the protective function
intended for compliance with existing regulations, for the
configurations tested using the acceptance criteria in Generic Letter
(GL) 86-10, Supplement 1, ``Fire Endurance Test Acceptance Criteria for
Fire Barrier Systems Used To Separate Redundant Safe Shutdown Trains
Within the Same Fire Area.''
(2) Require that addressees submit a written response to the NRC in
accordance with NRC regulations in Title 10 of the Code of Federal
Regulations, Section 50.54(f) (10 CFR 50.54(f)).
This Federal Register notice is available through the NRC's
Agencywide Documents Access and Management System (ADAMS) under
accession number ML051540292.
DATES: Comment period expires September 23, 2005. Comments submitted
after this date will be considered if it is practical to do so, but
assurance of consideration cannot be given except for comments received
on or before this date.
ADDRESSES: Submit written comments to the Chief, Rules and Directives
Branch, Division of Administrative Services, Office of Administration,
U.S. Nuclear Regulatory Commission, Mail Stop T6-D59, Washington, DC
20555-0001, and cite the publication date and page number of this
Federal Register notice. Written comments may also be delivered to NRC
Headquarters, 11545 Rockville Pike (Room T-6D59), Rockville, Maryland,
between 7:30 a.m. and 4:15 p.m. on Federal workdays.
FOR FURTHER INFORMATION, CONTACT: Angie Lavretta at (301) 415-3285 or
by e-mail [email protected], Daniel Frumkin at (301) 415-2280 or e-mail
[email protected], or Chandu Patel at (301) 415-3025 or by e-mail at
[email protected]v.
SUPPLEMENTARY INFORMATION:
NRC Generic Letter 2005-XX
Impact of Potentially Degraded Hemyc and Mt Fire Barriers on Compliance
With Approved Fire Protection Programs
Addressees
All holders of operating licenses for light-water nuclear power
reactors, except those who have ceased operations and have certified
that fuel has been permanently removed from the reactor vessel.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this
generic letter to:
(3) Request that addressees evaluate their facilities to confirm
compliance with the existing applicable regulatory requirements in
light of the information provided in this generic letter and, if
[[Page 42597]]
appropriate, take additional actions. Specifically, although Hemyc and
MT fire barriers in nuclear power plants (NPPs) may be relied on to
protect electrical and instrumentation cables and equipment that
provide safe shutdown capability during a fire, recent NRC testing has
revealed that both materials failed to provide the protective function
intended for compliance with existing regulations, for the
configurations tested using the acceptance criteria in Generic Letter
(GL) 86-10, Supplement 1, ``Fire Endurance Test Acceptance Criteria for
Fire Barrier Systems Used To Separate Redundant Safe Shutdown Trains
Within the Same Fire Area.''
(4) Require that addressees submit a written response to the NRC in
accordance with NRC regulations in Title 10 of the Code of Federal
Regulations, Section 50.54(f) (10 CFR 50.54(f)).
Background
NRC's concern with the performance of fire barriers at nuclear
power plants began with the failure of Thermo-Lag to pass performance
tests in October 1989 at Southwest Research Institute. The tests were
done for the Gulf States Utilities Company after visually observing
degradation of Thermo-Lag at River Bend Station. In June and August
1992, two sets of full-scale fire endurance tests on Thermo-Lag were
conducted at Omega Point Laboratories in San Antonio, Texas, by Texas
Utilities Electric Company for Comanche Peak Steam Electric Station,
with similar results. In July 1992, the NRC sponsored a series of
small-scale fire endurance tests at the National Institute of Standards
and Technology. The results again indicated that 1-hour-and 3-hour-
rated Thermo-Lag barrier material failed to consistently provide its
intended protective function.
On August 6, 1991, the NRC issued Information Notice (IN) 91-47,
``Failure of Thermo-Lag Fire Barrier Material To Pass Fire Endurance
Test,'' the first in a series of INs issued between 1991 and 1995 on
performance test failures and installation deficiencies related to
Thermo-Lag 330 fire barrier systems.
Because of questions about the ability of 1-hour- and 3-hour-rated
Thermo-Lag fire barrier material to perform its specified function and
because of the widespread use of Thermo-Lag in the nuclear industry,
the NRC issued the following generic communications to inform licensees
of the Thermo-Lag test results and to request that licensees implement
appropriate compensatory measures and develop plans to resolve any
noncompliances with 10 CFR 50.48:
Bulletin 92-01, ``Failure of Thermo-Lag 330 Fire Barrier
System To Maintain Cabling in Wide Cable Trays and Small Conduits Free
From Fire Damage,'' June 24, 1992.
Bulletin 92-01, Supplement 1, ``Failure of Thermo-Lag 330
Fire Barrier System To Perform its Specified Fire Endurance Function,''
August 28, 1992.
GL 92-08, ``Thermo-Lag 330-1 Fire Barriers,'' December 17,
1992.
Supplement 1 to GL 86-10, ``Fire Endurance Test Acceptance
Criteria for Fire Barrier Systems Used To Separate Redundant Safe
Shutdown Trains Within the Same Fire Area,'' March 25, 1994. GL 92-08
specifically asked licensees to review any existing fire barrier
configurations credited for 10 CFR 50.48 compliance in light of the
concerns with Thermo-Lag 330-1 fire barriers.
In response, the licensees reviewed their fire protection safe
shutdown plans to determine if corrective actions were needed. Some
licensees had made conservative commitments and installed Thermo-Lag in
locations where it was not needed to satisfy NRC requirements,
therefore no corrective actions were required. Where fire barrier
materials were required, licensees took one or a combination of the
following corrective actions:
Rerouted cables through other fire areas so that redundant
safe shutdown trains were not located in the same fire area.
Replaced Thermo-Lag, or the affected material, with an
alternative rated fire barrier material.
Upgraded the installed fire barriers to a rated
configuration.
Concluded that certain Thermo-Lag barriers were no longer
required.
Subsequently, deficiencies were also identified in other fire
barrier materials. In 1993, for example, Kaowool installed as a 1-hour-
rated fire barrier was found to be unable to pass circuit integrity
tests. In response, the NRC reassessed previous staff reviews of
Kaowool fire barriers and informed the industry and the Commission of
the potential failure of Kaowool to perform as intended and suggested
additional testing of Kaowool (SECY-99-204; ADAMS Accession No.
ML992810028). To resolve the issue, the industry took voluntary
corrective actions. In August 1993, the Nuclear Energy Institute (NEI)
formed a Fire Barrier Review Ad Hoc Advisory Committee to address the
adequacy of fire barrier materials other than Thermo-Lag. The Committee
performed reviews of the original testing of the fire barrier, Hemyc
(performed in the early 1980s in Spain), and concluded that Hemyc was
differently constructed than Thermo-Lag 330-1, and therefore was not
subject to the same failure modes as Thermo-Lag 330-1. In May 1994,
this review was documented in the NEI report, ``Documentation of the
Adequacy of Fire Barrier Materials in Raceway Applications Vis-
[agrave]-vis Failure Characteristics Inherent to the Thermo-Lag 330-
1.''
However, beginning in late 1999, three plant-specific findings by
the staff raised concerns about the performance of Hemyc and MT fire
barriers.
In November 1999, during an inspection at Shearon Harris
Nuclear Power Plant (IR 50-400/99-13; ADAMS Accession No. ML003685341),
the inspection team noted that the acceptance of the Hemyc and MT fire
barrier materials used was based on American Nuclear Insurers (ANI)
Bulletin No. 5 test acceptance criteria, even though the ANI test
methodology clearly stated that the tests were done for insurance
purposes only and were not intended to be considered the equivalent of
fire barrier endurance tests for fire barrier ratings.
In October and November 2000, during an inspection at
McGuire 1 and 2 (IR 50-369/00-09, 50-370/00-09; ADAMS Accession No.
ML003778709), the inspection team noted that the licensee was unable to
provide documentation demonstrating protection by Hemyc fire barrier
material used to separate safe shutdown functions for two trains within
a single fire area.
In September 2000, during an inspection at Waterford 3 (IR
50-382/00-07; ADAMS Accession No. ML003773900), the inspectors noted
that the Hemyc materials were installed in configurations which
typically would not be bounded by the existing tests.
In June 2001, the NRC initiated confirmatory fire tests in response
to Task Interface Agreement 99-028 (ADAMS Accession No. ML003736721),
after concluding that existing testing was likely insufficient to
qualify Hemyc or MT as rated fire barriers. The NRC tests were based on
ASTM E119 Standard time-temperature conditions and the current NRC
guidance in GL 86-10, Supplement 1, for typical Hemyc and MT
installations used in U.S. NPPs. The test results indicated that Hemyc
and MT fire barriers did not pass the GL 86-10, Supplement 1, criteria
to achieve a 1-hour fire rating for Hemyc or a 3-hour fire rating for
MT, for the configuration tested. On April 1, 2005, the NRC issued IN
2005-07, ``Results of Hemyc Electrical Raceway Fire Barrier System Full
Scale Fire Testing.'' This IN describes the results of the NRC-
sponsored confirmatory testing of
[[Page 42598]]
Hemyc. However, the staff recognized that additional evaluations would
be needed to determine whether regulatory compliance exists in light of
the concerns identified in IN 05-07.
On April 29, 2005, the staff held a public meeting with licensees
and interested members of the public to discuss the Hemyc and MT test
results and the staff's intentions to take prompt additional regulatory
action to ensure that appropriate measures are under way for compliance
with 10 CFR 50.48 requirements at affected plants. This generic letter
is the follow-on to IN 05-07.
The NRC has established a Web page to keep the public informed of
the status of the Hemyc/MT fire barrier issue at http://www.nrc.gov/reactors/operating/ops-experience/fire-protection/technical-issues.html#fire.
This page provides links to information on related fire protection
issues, along with documentation of NRC interactions with industry
(including generic communications, industry submittals, meeting
notices, presentation materials, and meeting summaries). The NRC will
continue to update this Web page as new information becomes available.
Hemyc Construction--Hemyc fire barrier material consists of mats of
2-inch Kaowool ceramic fiber insulation inside an outer covering of
Refrasil \1\ high-temperature fabric. The mats are custom-sized for the
electrical raceway and machine-stitched to produce the factory mats.
Hemyc mats, which are installed over a metal frame to provide the 2-
inch air gap design, are identical except that 1\1/2\-inch Kaowool is
used instead of the 2-inch material.
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\1\ Refrasil was used during NRC tests. Siltemp and Refrasil
were tested by the NRC and determined to be essentially equivalent
(ADAMS Accession No. ML051190055).
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MT Construction--MT used with conduits has four layers. The first
layer, closest to the conduit, is 1 inch of Kaowool ceramic fiber
blanket wrapped in a fiberglass fabric. The second layer is a 2-mil
sheet of stainless steel. The third layer is a hydrate packet. This
packet is made by stitching together packets of aluminum trihydrate in
a fiberglass-coated fabric. The fourth and outermost layer is a 1\1/2\-
inch Kaowool blanket wrapped in Refrasil. The configuration is slightly
different for air drops and structural supports. Air drops use a 3-inch
blanket of Kaowool as the inner layer. Structural supports do not have
the hydrating packet layer or the stainless steel sheet.
Discussion
Hemyc and MT, manufactured by Promatec, Inc, were installed at NPPs
to protect circuits and instrumentation cables in order to meet
regulatory requirements and in accordance with plant-specific
commitments. The NRC conducted confirmatory testing of both materials
at the Omega Point Laboratories in San Antonio, Texas. The test results
indicated that when tested to GL 86-10, Supplement 1, criteria, neither
the Hemyc nor the MT fire barrier system would provide its rated fire
barrier protection.
The staff noted at least three failure modes in the limited test
program. Two failure modes resulted from shrinkage of outer material
(Refrasil), causing the barrier to open and exposing the interior
surfaces or layers to the fire. The third failure mode resulted from
failure to adequately protect steel members intruding into the barrier.
The standard used by some utilities required protection of 3 inches of
intruding steel for the Hemyc 1-hour fire barrier and 18 inches of
intruding steel for the MT 3-hour fire barrier. The test results
indicated that additional protection of intruding steel was required to
achieve a 1-hour or 3-hour fire rating. Based on these test results,
the NRC is concerned that the Hemyc and MT fire barriers may not
provide the level of fire endurance intended by licensees and that
licensees that use Hemyc or MT may not be complying with NRC
regulations. Section 50.48 of 10 CFR part 50 requires that each
operating NPP have a fire protection plan that satisfies General Design
Criterion (GDC) 3, ``Fire Protection,'' of 10 CFR part 50, Appendix A,
``General Design Criteria for Nuclear Power Plants.'' The NRC
Regulation in 10 CFR 50.48 states that each operating nuclear power
plant (licensed before or after issuance of GDC 3) must have a fire
protection plan that satisfies Criterion 3 of Appendix A. GDC 3
requires that structures, systems, and components important to safety
be designed and located to minimize, in a manner consistent with other
requirements, the probability and effect of fires and explosions. Fire
protection features required to satisfy 10 CFR 50.48 include features
to limit fire damage to structures, systems or components important to
safety so that the capability to shut down the plant safely is ensured.
One means of complying with this requirement is to separate one safe
shutdown train from its redundant train with rated fire barriers. The
duration of fire resistance required of the barriers, usually 1 hour or
3 hours, depends on the other fire protection features provided in the
fire area. The NRC issued guidance on acceptable methods of satisfying
the regulatory requirements of GDC 3 in the branch technical positions
(BTPs) and generic letters identified below in the Applicable
Regulatory Guidance section of this generic letter. GL 92-08
specifically included the staff's expectation that licensees would
review existing fire barrier configurations credited for 10 CFR part
50, appendix R, compliance, based on earlier concerns with Thermo-Lag.
Licensees of plants licensed to operate before January 1, 1979, must
comply with their fire protection requirements as specified in 10 CFR
50, appendix R, and licensees of plants licensed to operate after
January 1, 1979, must comply with the approved fire protection program
incorporated into their operating license. The staff expects licensees
to reevaluate their fire protection programs in light of information
provided in IN 05-07 and this generic letter and to implement
appropriate compensatory measures and develop plans to resolve any
noncompliances within a reasonable timeframe.
For guidance in addressing any degraded or nonconforming Hemyc and
MT fire barrier configurations, licensees should consult the guidance
in Revision 1 to GL 91-18, ``Information to Licensees Regarding NRC
Inspection Manual Section on Resolution of Degraded and Nonconforming
Conditions,'' dated October 8, 1997. Licensees are encouraged to review
Regulatory Issue Summary 2005-07, ``Compensatory Measures To Satisfy
the Fire Protection Program Requirements,'' in determining the
appropriate compensatory measures to meet fire protection program
requirements for the degraded or nonconforming fire barrier
installations. All licensees should consider the impact of fire barrier
degradation on the operability of affected equipment and assess the
impact on plant safety.
NRC regulations do not require fire detectors and automatic fire
suppression systems when 3-hour fire barriers are used. NRC regulations
do require fire detectors and automatic fire suppression systems when
1-hour-rated fire barriers are used; however, the staff has approved
plant-specific requests for exceptions (i.e., exemptions or amendments)
for specific areas of the plant based on detailed evaluations of the
area configuration and combustible loading. Hemyc and MT fire ratings
are expected to provide time to extinguish fires before safe shutdown
systems are damaged.
[[Page 42599]]
If a nonconforming condition is identified, then licensees can use
at least two methods, individually or in combination, to restore
compliance. One way is to make plant modifications such as replacing
the Hemyc or MT fire barriers with an appropriately rated fire barrier
material, upgrading the Hemyc or MT to a rated barrier, or rerouting
cables or instrumentation lines through another fire area. Another way
to address the issue is to perform a technical evaluation that
considers defense-in-depth and safety margins as follows:
Plants licensed to operate before January 1, 1979, that do
not plan to perform a plant modification must request an exemption from
10 CFR part 50, appendix R, that demonstrates that the configuration as
installed meets the requirements of 10 CFR 50.12, ``Specific
Exemptions.'' If the plant proposes to use a risk-informed approach to
justify an exception in accordance with 10 CFR 50.12, then this
approach should follow the guidance of Regulatory Guide (RG) 1.174,
``An Approach for Using Probabilistic Risk Assessment in Risk-Informed
Decisions on Plant-Specific Changes to the Licensing Basis.''
Plants licensed to operate after January 1, 1979, that do
not plan to perform a plant modification must meet the fire protection
requirements in the operating license condition. The standard license
condition allows a licensee to make changes to the approved fire
protection program without prior staff approval ``if those changes
would not adversely affect the ability to achieve and maintain safe
shutdown in the event of a fire.'' GL 86-10, ``Implementation of Fire
Protection Requirements,'' provides guidance on performing and
documenting these changes.
Plants licensed after January 1, 1979, that adopt a risk-informed
approach, must submit a license amendment in accordance with 10 CFR
50.90. The exception to 10 CFR 50.90, provided in the standard license
condition and in 10 CFR 50.48(f)(3), does not apply because the risk
assessment approaches used by plants deviate from the approved
deterministic approaches used in their licensing bases. Furthermore,
the licensees' risk assessment tools have not been reviewed or
inspected against quality standards found acceptable to the NRC staff.
Consequently, the staff is not confident that a risk-informed approach
``would not adversely affect the ability to achieve and maintain safe
shutdown in the event of a fire,'' at this time. Because this approach
fails to meet the exception criteria for an exception to 10 CFR 50.90,
a license amendment is required for the change to the license
condition, in accordance with 10 CFR 50.90.
Applicable Regulatory Requirements
NRC regulations in 10 CFR 50.48 and 10 CFR part 50, appendix A, GDC
3, require each operating nuclear power plant (licensed before or after
issuance of GDC 3) to have a fire protection plan providing post-fire
safe shutdown. That is, a means must be provided to limit fire damage
to structures, systems or components important to safety so that the
capability to shut down the plant safely is ensured. The regulation in
10 CFR 50.90 requires a licensee who desires to amend their license, to
submit an amendment request to the NRC. All NPPs licensed to operate
before January 1, 1979, are required to comply with 10 CFR part 50,
appendix R, paragraph III.G, ``Fire Protection of Safe Shutdown
Capability.'' All NPPs licensed to operate after January 1, 1979, are
required to comply with 10 CFR 50.48(a), which requires that each
operating nuclear power plant have a fire protection plan that
satisfies GDC 3. The fire protection plan is incorporated into the
operating license for each post-1979 plant as a license condition. This
license condition specifically cites the staff SER on the licensee's
fire protection plan, to demonstrate that the license condition has
been met (although licensees may modify their fire protection plan as
long as there is no adverse effect on safe shutdown).
Applicable Regulatory Guidance
The NRC issued guidance on acceptable methods of satisfying the
regulatory requirements of GDC 3 in Auxiliary and Power Conversion
Systems Branch (APCSB) BTP 9.5-1, ``Guidelines for Fire Protection for
Nuclear Power Plants,'' May 1, 1976; Appendix A to APCSB BTP 9.5-1,
February 24, 1977; and Chemical Engineering Branch (CMEB) BTP 9.5-1,
``Fire Protection for Nuclear Power Plants,'' July 1981. In response to
licensees' questions, the staff provided additional guidance on fire
barriers in GL 86-10. The staff issued additional guidance as
Supplement 1 to GL 86-10.
In the BTPs and in GL 86-10, the staff states that the fire
resistance ratings of fire barriers should be established in accordance
with National Fire Protection Association (NFPA) Standard 251,
``Standard Methods of Fire Tests of Building Construction and
Materials,'' \2\ by subjecting a test specimen that represents the
materials, workmanship, method of assembly, dimensions, and
configuration for which a fire rating is desired to a ``standard fire
exposure.'' Supplement 1 to GL 86-10 provides guidance for fire barrier
endurance testing and for evaluating deviations from tested
configurations. This guidance is repeated in RG 1.189, ``Fire
Protection for Operating Nuclear Power Plants.''
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\2\ American Society for Testing and Materials (ASTM) E-119,
``Fire Test of Building Construction Materials,'' and NFPA 251 are
essentially equivalent.
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Requested Actions
Within 60 days of the date of this letter, all addressees are
requested to determine whether or not Hemyc or MT fire barrier material
is installed and relied on for separation and/or safe shutdown purposes
to satisfy applicable regulatory requirements.
Addressees who credit Hemyc or MT for compliance should provide
information regarding the extent of the installation; whether the
material is degraded or nonconforming; and any compensatory actions in
place to provide equivalent protection and maintain the safe shutdown
function of affected areas of the plant in light of the recent findings
of potential degradation of Hemyc and MT. Licensees should provide
evaluations to support conclusions that they are in compliance with
regulatory requirements for the Hemyc and MT applications. Licensees
that can not justify their continued reliance on Hemyc or MT shall
provide a description of corrective actions taken or planned and a
schedule for milestones including when full compliance will be
achieved. In addition, licensees should identify and discuss all
applications that are considered degraded but operable, including a
basis for this conclusion.
Compensatory and corrective actions shall be implemented in
accordance with existing regulations commensurate with the safety
significance of the degraded or nonconforming condition. The NRC
expects that all licensees shall fully restore compliance with 10 CFR
50.48, and submit the required documentation to the NRC, by December 1,
2007.
Requested Information
All addressees are requested to provide the following information:
1. Within 60 days of the date of this generic letter, provide a
statement on whether Hemyc or MT fire barrier material is used at their
NPPs and whether it is relied on 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.,
[[Page 42600]]
exemptions, license amendments, GL 86-10 analyses).
2. Within 60 days of the date of this generic letter, addressees
who have installed Hemyc or MT fire barrier materials should discuss
the following in detail:
a. The extent of the installation (e.g., linear feet of wrap, areas
installed, systems protected),
b. Whether the Hemyc and/or MT installed in their plants continues
to comply with 10 CFR 50.48, in light of recent findings,
c. The compensatory measures that have been implemented to provide
equivalent protection and maintain the safe shutdown function of
affected areas of the plant in light of the recent findings of
potential degradation Hemyc and MT, including evaluations to support
the addresses' conclusions and a discussion of the impact on plant
risk,
d. A general description of, and implementation schedule for, all
corrective actions to restore the fire protection program to compliance
with the licensing basis, including a description of any licensing
actions or exemption requests needed to support changes to the plant
licensing basis.
3. No later than December 1, 2007, addressees that have degraded or
nonconforming Hemyc and/or MT and rely on it for separation and/or safe
shutdown purposes should provide the following information upon
implementing corrective actions:
a. Confirmation that the fire protection program is in compliance
with the regulatory requirements listed in the Applicable Regulatory
Requirements section of this generic letter once all corrective actions
for regulatory compliance have been completed and the licensing basis
has been updated to reflect the actions taken.
b. A summary of the evaluation used to determine the susceptibility
of the fire protection program to the adverse effects of potentially
degraded Hemyc or MT fire barriers. (The submittal may reference a
guidance document, e.g., GL 86-10, or another approach previously
submitted to the NRC. The documents submitted or referenced should
include the results of any supporting Hemyc or MT tests or evaluations
performed to obtain pertinent information used in the determination.)
c. A description of the existing programmatic controls that will
ensure that other fire barrier types will be assessed for potential
degradation and resultant adverse effects. Addressees may reference
their responses to GL 92-08 to the extent that the responses address
this specific issue.
Required Response
In accordance with 10 CFR 50.54(f), in order to determine whether a
facility license should be modified, suspended, or revoked, or whether
other action should be taken, an addressee is required to respond as
described below.
Within 30 days of the date of this generic letter, an addressee is
required to submit a written response if it is unable to provide the
information or it cannot meet the requested completion date. The
addressee must address in its response any alternative course of action
that it proposes to take, including the basis for the acceptability of
the proposed alternative course of action.
The required written response should be addressed to the U.S.
Nuclear Regulatory Commission, Attn: Document Control Desk, 11555
Rockville Pike, Rockville, Maryland 20852, under oath or affirmation
under the provisions of Section 182a of the Atomic Energy Act of 1954,
as amended, and 10 CFR 50.54(f). In addition, a copy of the response
should be submitted to the appropriate regional administrator.
Reason for Information Request
The recent confirmatory testing of the Hemyc and MT fire barriers
revealed that similar barriers installed at NPPs may not perform their
intended protective function during a fire.
The NRC staff will review the responses to this generic letter and
will notify affected addressees if concerns are identified regarding
compliance with NRC regulations. The staff may also conduct inspections
to determine addressees' effectiveness in addressing the generic
letter.
Related Generic Communications
1. Regulatory Issue Summary 05-07, ``Compensatory Measures To
Satisfy the Fire Protection Program Requirements,'' April 19, 2005.
2. Information Notice 05-07, ``Results of Hemyc Electrical Raceway
Fire Barrier System Full Scale Fire Testing,'' April 1, 2005.
3. Information Notice 99-17, ``Problems Associated with Post-Fire
Safe-Shutdown Circuit Analysis,'' June 3, 1999.
4. Information Notice 95-52, Supplement 1, ``Fire Endurance Test
Results for Electrical Raceway Fire Barrier Systems Constructed from 3M
Company Interam Fire Barrier Materials,'' March 17, 1998.
5. Information Notice 95-49, Supplement 1, ``Seismic Adequacy of
Thermo-Lag Panels,'' December 10, 1997.
6. Generic Letter 91-18, ``Information to Licensees Regarding NRC
Inspection Manual Section on Resolution of Degraded and Nonconforming
Conditions,'' Revision 1, October 8, 1997.
7. Information Notice 97-70, ``Potential Problems With Fire Barrier
Penetration Seals,'' September 19, 1997.
8. Information Notice 97-59, ``Fire Endurance Test Results of
Versawrap Fire Barriers,'' August 1, 1997.
9. Information Notice 94-86, Supplement 1, ``Legal Actions Against
Thermal Science, Inc., Manufacturer of Thermo-Lag,'' November 15, 1995.
10. Information Notice 95-52, ``Fire Endurance Test Results for
Electrical Raceway Fire Barrier Systems Constructed from 3M Company
Interam Fire Barrier Materials,'' November 14, 1995.
11. Information Notice 95-49, ``Seismic Adequacy of Thermo-Lag
Panels,'' October 27, 1995.
12. Information Notice 95-32, ``Thermo-Lag 330-1 Flame Spread Test
Results,'' August 10, 1995.
13. Information Notice 95-27, ``NRC Review of Nuclear Energy
Institute, Thermo-Lag 330-1 Combustibility Evaluation Methodology Plant
Screening Guide,'' May 31, 1995.
14. Information Notice 94-86, ``Legal Actions Against Thermal
Science, Inc., Manufacturer of Thermo-Lag,'' December 22, 1994.
15. Information Notice 94-34, ``Thermo-Lag 330-660 Flexi-Blanket
Ampacity Derating Concerns,'' May 13, 1994.
16. Information Notice 94-28, ``Potential Problems With Fire
Barrier Penetration Seals,'' April 5, 1994.
17. Generic Letter 86-10, Supplement 1, ``Fire Endurance Test
Acceptance Criteria for Fire Barrier Systems Used To Separate Redundant
Safe Shutdown Trains within the Same Fire Area,'' March 25, 1994.
18. Information Notice 94-22, ``Fire Endurance and Ampacity
Derating Test Results for 3-Hour Fire-Rated Thermo-Lag 330-1 Fire
Barriers,'' March 16, 1994.
19. Information Notice 93-41, ``One Hour Fire Endurance Test
Results for Thermal Ceramics Kaowool, 3M Company FS-195 and 3M Company
Interam E-50 Fire Barrier Systems,'' May 28, 1993.
20. Information Notice 93-40, ``Fire Endurance Test Results for
Thermal Ceramics FP-60 Fire Barrier Material,'' May 26, 1993.
21. Generic Letter 92-08, ``Thermo-Lag 330-1 Fire Barriers,''
December 17, 1992.
22. Information Notice 92-82, ``Results of Thermo-Lag 330-1
Combustibility Testing,'' December 15, 1992.
[[Page 42601]]
23. Bulletin 92-01, Supplement 1, ``Failure of Thermo-Lag 330 Fire
Barrier System To Perform its Specified Fired Endurance Function,''
August 28, 1992.
24. Information Notice 92-55, ``Current Fire Endurance Test Results
for Thermo-Lag Fire Barrier Material,'' July 27, 1992.
25. Bulletin 92-01, ``Failure of Thermo-Lag 330 Fire Barrier System
To Maintain Cabling in Wide Cable Trays and Small Conduits Free from
Fire Damage,'' June 24, 1992.
26. Information Notice 92-46, ``Thermo-Lag Fire Barrier Material
Special Review Team Final Report Findings, Current Fire Endurance
Tests, and Ampacity Calculation Error,'' June 23, 1992.
27. Information Notice 91-79, ``Deficiencies in the Procedures for
Installing Thermo-Lag Fire Barrier Materials,'' December 6, 1991.
28. Information Notice 91-47, ``Failure of Thermo-Lag Fire Barrier
Material To Pass Fire Endurance Test,'' August 6, 1991.
29. Information Notice 88-56, ``Potential Problems With Silicone
Foam Fire Barrier Penetration Seals,'' August 4, 1988.
30. Generic Letter 88-12, ``Removal of Fire Protection Requirements
from Technical Specifications,'' August 2, 1988.
31. Generic Letter 86-10, ``Implementation of Fire Protection
Requirements,'' April 26, 1986.
32. Generic Letter 83-33, ``NRC Position on Certain Requirements of
Appendix R to 10 CFR Part 50,'' October 19, 1983.
33. Generic Letter 81-12, ``Fire Protection Rule (45 FR 76602,
November 19, 1980),'' February 20, 1981.
Backfit Discussion
Under the provisions of Section 182a of the Atomic Energy Act of
1954, as amended, 10 CFR 50.109(a)(4)(I) and 10 CFR 50.54(f), this
generic letter asks addressees to evaluate their facilities to confirm
compliance with the existing applicable regulatory requirements as
discussed in this generic letter. Specifically, although Hemyc and MT
fire barriers in NPPs may be relied on to protect electrical and
instrumentation cables and equipment that provide safe shutdown
capability during a fire, recent NRC testing has revealed that both
materials failed to provide the protective function intended for
compliance with existing regulations.
For plants licensed to operate before January 1, 1979, licensees
are required to comply with 10 CFR part 50, appendix R, which requires
protection of safe shutdown capabilities. One means of complying with
this requirement is to separate one safe shutdown train from its
redundant train using rated fire barriers, as cited in Appendix R,
paragraph III.G.2(a). Recent test results indicated that Hemyc and MT
fire barriers did not pass the GL 86-10, Supplement 1, criteria to
achieve a 1-hour fire rating for Hemyc or a 3-hour fire rating for MT.
Therefore, for any such plant that relies on Hemyc and/or MT for
compliance, compliance with Appendix R is in question and the
information requested by this generic letter is a compliance exception
to the rule in accordance with 10 CFR 50.109(a)(4)(I).
For plants licensed to operate after January 1, 1979, licensees are
required to comply with 10 CFR 50.48(a), which requires that each
operating nuclear power plant have a fire protection plan that
satisfies GDC 3. The fire protection plan is incorporated into the
operating license for each post-1979 plant as a license condition and
may rely on fire barriers such as Hemyc and MT to provide the required
protection. The license condition specifically cites the staff SER on
the licensee's fire protection plan, to demonstrate that the license
condition has been met (although licensees may modify their fire
protection plan as long as there is no adverse effect). However, recent
test results indicated that Hemyc and MT fire barriers did not pass the
GL 86-10, Supplement 1, criteria to achieve a 1-hour fire rating for
Hemyc or a 3-hour fire rating for MT. Therefore, for any such plant
where the staff-approved fire protection plan relies on Hemyc and/or MT
for compliance with their license condition, compliance with the
license condition is in question and the information requested by this
generic letter is a compliance exception to the rule in accordance with
10 CFR 50.109(a)(4)(I).
Federal Register Notification
A notice of opportunity for public comment on this generic letter
was published in the Federal Register (XX FR XXXXX) on July XX, 2005.
Small Business Regulatory Enforcement Fairness Act
In accordance with the Small Business Regulatory Enforcement
Fairness Act of 1996, the NRC has determined that this generic letter
is not a major rule and has verified this determination with the Office
of Information and Regulatory Affairs of the Office of Management and
Budget (OMB).
Paperwork Reduction Act Statement
This generic letter contains information collection requirements
that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501
et seq.). These information collections were approved by the Office of
Management and Budget, clearance number 3150-0011, which expires
February 28, 2007.
The burden to the public for these mandatory information
collections is estimated to average 300 hours per response, including
the time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing
the information collection. The U.S. Nuclear Regulatory Commission is
seeking public comment on the potential impact of the information
collections contained in the generic letter and on the following
issues:
1. Is the proposed information collection necessary for the proper
performance of the functions of the NRC, including whether the
information will have practical utility?
2. Is the estimate of burden accurate?
3. Is there a way to enhance the quality, utility, and clarity of
the information collected?
4. How can the burden of the information collection be minimized,
including the use of automated collection techniques?
Send comments on any aspect of these information collections,
including suggestions for reducing the burden, to the Records and FOIA/
Privacy Services Branch (T-F52), U.S. Nuclear Regulatory Commission,
Washington, DC 20555-0001, or by Internet electronic mail to
[email protected]; and to the Desk Officer, Office of Information
and Regulatory Affairs, NEOB-10202 (3150-0011), Office of Management
and Budget, Washington, DC 20503.
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to
respond to, an information collection unless the requesting document
displays a currently valid OMB control number.
Contact
Please direct any questions about this matter to the Technical
Contacts or the Lead Project Manager listed below, or to the
appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Bruce A. Boger, Director, Division of Inspection Program
Management, Office of Nuclear Reactor Regulation.
[[Page 42602]]
Technical Contacts:
Daniel Frumkin, NRR, (301) 415-2280, e-mail: [email protected].
Angie Lavretta, NRR, (301) 415-3285, e-mail: [email protected].
Lead Project Manager:
Chandu Patel, NRR, (301) 415-3025, e-mail: [email protected]v.
Note: NRC generic communications may be found on the NRC public
Web site, http://www.nrc.gov, under Electronic Reading Room/Document
Collections.
End of Draft Generic Letter
Documents may be examined, and/or copied for a fee, at the NRC's
Public Document Room at One White Flint North, 11555 Rockville Pike
(first floor), Rockville, Maryland. Publicly available records will be
accessible electronically from the Agencywide Documents Access and
Management System (ADAMS) Public Electronic Reading Room on the
Internet at the NRC Web site, http://www.nrc.gov/NRC/ADAMS/index.html.
If you do not have access to ADAMS or if you have problems in accessing
the documents in ADAMS, contact the NRC Public Document Room (PDR)
reference staff at 1-800-397-4209 or (301) 415-4737 or by e-mail to
[email protected].
Dated at Rockville, Maryland, this 18th day of July, 2005.
For the Nuclear Regulatory Commission.
Patrick L. Hiland,
Chief, Reactor Operations Branch, Division of Inspection Program
Management, Office of Nuclear Reactor Regulation.
[FR Doc. E5-3941 Filed 7-22-05; 8:45 am]
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