ET 06-0022, Response to NRC Generic Letter 2006-03

Response to NRC Generic Letter 2006-03

ML061570375
Person / Time
Site:	Wolf Creek
Issue date:	05/31/2006
From:	Garrett T Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
+kBR1SISP20060621, ET 06-0022, GL-06-003
Download: ML061570375 (4)

Text

SOF CROEEI NUCLEAR OPERATNCOPRIN Terry J Garrett Vice President, Engineering May 31, 2006 ET 06-0022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

1) NRC Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" Docket No. 50-482: Response to NRC Generic Letter 2006-03 Gentlemen:

This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to NRC Generic Letter (GL) 2006-03 (Reference 1), "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations," dated April 10, 2006, which was issued to request information from licensees regarding Hemyc and MT fire barriers, or other fire barriers using the materials and configurations described in the generic letter.

GL 2006-03 requested that all addressees provide a response that contains the following information:

1.

Within 60 days of the date of this GL, provide the following:

a.

A statement on whether Hemyc or MT fire barrier material is used at their NPPs 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).

b.

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. Addressees may reference their responses to GL 92-08 to the extent that the responses address this specific issue.

P.O. Box 411 Burlington, KS 668391 Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

F I I

ET 06-0022 Page 2 of 3

2.

Within 60 days of the date of this GL, for those addressees that have installed Hemyc or MT fire barrier materials, 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 is conforming with their licensing basis in light of recent findings, and if these recent findings do not apply, why not,

c.

The compensatory measures that have been implemented to provide protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings associated with Hemyc and MT installations, including evaluations to support the addressees' conclusions, and

d. A description of, and implementation schedules for, corrective actions, 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 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.d.

Wolf Creek Generating Station (WCGS) does not use Hemyc or MT fire barrier materials for fire barrier separation of redundant post fire safe shutdown (PFSSD) circuits.

WCGS utilizes Darmatt KM-I and Thermo-Lag 330-1 as raceway fire barrier protection for redundant post fire safe shutdown (PFSSD) circuits located in the same fire area. This fire barrier protection is provided in order to satisfy WCGS Updated Safety Analysis Report comparison response to 10 CFR 50, Appendix R, III.G requirements. Darmatt KM-i is the predominate fire barrier material utilized, while Thermo-Lag 330-1 is utilized in limited applications.

For both material types, installation and inspection documentation, and fire protection engineering evaluations confirm that the barrier products are installed in a manner consistent with industry fire testing. Unique configurations that are not directly bounded to tested configurations are evaluated in accordance with 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" providing reasonable assurance that the installed fire barrier systems provide the required level of protection. WCNOC inspects fire rated enclosures every 18months to ensure ongoing integrity.

Raceway fire barrier design, installation documentation, and engineering evaluations are available on site.

Requests for information 2 and 3 do not apply to WCNOC.

In accordance with the provisions of Section 182a of the Atomic Energy Act of 1954, as amended and 10 CFR 50.54(f), WCNOC is submitting this letter under oath and affirmation.

ET 06-0022 Page 3 of 3 This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Kevin Moles at (620) 364-4126.

Very truly yours, Terry J. Garrett TJG/rlt cc:

J. N. Donohew (NRC)

W. B. Jones (NRC)

B. S. Mallett (NRC)

Senior Resident Inspector (NRC)

Jl" STATE OF KANSAS COUNTY OF COFFEY

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Terry J. Garrett, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Vice Engineering SUBSCRIBED and sworn to before me this 31 Wday of Ifrlq, 2006.

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MY COMMISSION EXPIRES Notary Public I.....

January 1 2010 NaryPublic Expiration Date a9(2ifh k//I A/