Text

FAQ 14-0071 - Acceptable Uses for Non IEEE 383 Cables
	ML16118A085
Person / Time
Site:	Brunswick
Issue date:	04/26/2016
From:	Anderson V, Holder A; Nuclear Energy Institute
To:	Daniel Frumkin; NRC/NRR/DRA/AFPB
	Frumkin DM
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	Download: ML16118A085 (5)
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To: Frumkin, Daniel

Subject:

[External_Sender] FAQ 14-0071 (cables)

Date: Tuesday, April 26, 2016 9:10:11 AM Attachments: FAQ 14-0071 R0b.doc See attached.

Victoria K. Anderson Senior Project Manager, Risk Assessment Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org P: 202-739-8101 F: 202-533-0173 E: vka@nei.org Take The NEI Future of Energy Quiz, www.NEI.org/futureofenergy FOLLOW US ON This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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FAQ Number 14-0071 FAQ Revision 0b FAQ Title Acceptable Uses for Non IEEE 383 cables Plant: Brunswick Nuclear Plant Date: April 7, 2016

Contact:

Alan Holder Phone: (919) 546-3372 Email: Alan.Holder@duke-energy.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

FAQ provides clarification for the acceptable use of Non-IEEE 383 or equivalent cables to Fundamental Fire Protection Program and Design Elements Transition Review (NFPA 805, Chapter 3)

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

NEI 04-02, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, and Appendix K, NFPA 805 Chapter 3 Clarifications.

3.3.5.3 Electrical Cable Flame Propagation Limits. Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ.

Circumstances requiring guidance interpretation or new guidance:

Clarification of the NFPA 805 Chapter 3 requirement of Section 3.3.5.3, which requires that Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ. The industry requires clarification as to what types of applications may not be required to have cables that meet the IEEE Std. 383 flame spread requirements, or equivalent tests endorsed by NFPA 805 FAQ 06-0022.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

None

FAQ Number 14-0071 FAQ Revision 0b FAQ Title Acceptable Uses for Non IEEE 383 cables Potentially relevant existing FAQ numbers: FAQ 06-0022, Acceptable Electrical Cable Construction Tests.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

3.3.5.3 Electrical Cable Flame Propagation Limits. Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ.

In order to provide clarity for the language above regarding Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ, this statement should be expanded upon for those casescrane cables which typically do not meet when non-IEEE Std. 383 or equivalent flame test requirements. cables are necessary for certain plant applications.

One example is:

Cables that require special properties (e.g., high flexibility) are specifically designed and constructed for crane applications and are not always qualified to IEEE Std 383 or equivalent. Where the use of these cables is required for crane applications and an IEEE Std 383 or equivalent cable cannot be used, the use of these cables is permissible, provided that the cable has been identified as having fire retardant properties by meeting a low intensity flame test such as the ones discussed in FAQ 06-0022 or similar, and is still classified as fire retardant and that their use does notdoes not have an adverse impact on the Approved Fire Protection Program, Safe Shutdown, and the Fire PRA.

FAQ Number 14-0071 FAQ Revision 0b FAQ Title Acceptable Uses for Non IEEE 383 cables If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Modify Appendix K to add the following clarification:

======================================================

K.X NFPA 805 Section 3.3.5.3 (FAQ 14-0071)

Specific clarification for NFPA 805 section 3.3.5.3, from FAQ 14-0071; To comply with the requirement Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ where used in section 3.3.5.3, one acceptable method application is as follows:

This clarification is applicable to CcCables that require special properties (e.g., high flexibility) are specifically designed and constructed for crane applications (e.g., high flexibility) and are not always qualified to IEEE Std 383 or equivalent. Where the use of these cables is required for crane applications and an IEEE Std 383 or equivalent cable cannot be used, the use of these cables is permissible, provided that the cable has been identified as having fire retardant properties by meeting a low intensity flame test such as the ones discussed in FAQ 06-0022 or similar, and their use does not have an adverse impact on the Approved Fire Protection Program, Safe Shutdown, and the Fire PRA.the cable is still classified as fire retardant and that their use does not have an adverse impact on the Approved Fire Protection Program, Safe Shutdown, and the Fire PRA. This clarification applies only to crane cable applications.

Long, exposed lengths of highly flexible cable may not be capable of meeting a currently acceptable fire propagation test because of its application. Cranes that use festoon cables and/or moving cable trays are typically located in the Turbine Building, Spent Fuel Pool, and Reactor Building. Highly flexible cables commonly meet the low intensity test methods identified in FAQ 06-0022. These tests are the VW-1 Vertical Wire Flame Test (UL 1581 and CSA C22.2 No. 0.3, and referenced in UL 83 and UL 44), the FT-1 Vertical Flame Test (UL 1581 and CSA 22.2 No. 0.3 and referenced in UL 83 and UL 44), Flame Test (ICEA S-61-402), and the FT-2 Horizontal Flame Test (UL 1581, CSA 22.2 No. 0.3, and referenced in UL 83 and UL 44). Cables that meet these

FAQ Number 14-0071 FAQ Revision 0b FAQ Title Acceptable Uses for Non IEEE 383 cables tests are classified as fire retardant cables; however, due to the vast differences between the IEEE 383-1974 and low intensity test methods the low intensity test cannot be directly compared to IEEE 383-1974.