ML18232A390
| ML18232A390 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/2018 |
| From: | Raymond Furstenau NRC/RES/DRA/FRB |
| To: | Joseph E Pollock Nuclear Energy Institute |
| Taylor G | |
| References | |
| Download: ML18232A390 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 19, 2018 Joseph E. Pollock Vice President, Nuclear Operations Nuclear Energy Institute 1201 F Street, N.W., Suite 1100 Washington, DC 20004
SUBJECT:
RESPONSE TO LETTER REGARDING NEI COMMENTS ON ALUMINUM HIGH ENERGY ARC FAULT (HEAF) PARTICLE SIZE CHARACTERIZATION TEST PLAN - DRAFT TEST PLAN; 83 FR 9334; DOCKET ID NRC-2018-0040
Dear Mr. Pollock:
Thank you for your interest and review of the subject draft test plan. Your letter dated May 17, 2018, has been made available to the public in the NRC Agencywide Document Access and Management System (ADAMS) under Accession Number ML18163A424. The information you provided covers a wide variety of topics beyond the scope of the small-scale testing, including Information Notice 2017-004 High Energy Arcing Faults in Electrical Equipment Containing Aluminum Components, an international test report CSNI-R2017-7, and interpretation of operating experience. This letter documents the NRCs response to your concerns.
Regarding the small-scale testing, the purpose of this testing is to better characterize aluminum particle size distribution, rates of production and morphology (agglomeration) of high energy arc faults (HEAFs), near the arc. The results and measurements from this investigation will be used to develop a model to predict additional energy from aluminum involvement during HEAF events. The comments from your letter related to the small-scale test plan have been reviewed and changes to that test plan have been made. All small-scale test plan comment resolutions can be found in ADAMS under Accession No. ML18170A332.
Comments pertaining to the phase 2 full-scale testing program have been reviewed and dispositioned. This program focuses on performing realistic HEAF testing that will support 1) the assessment of PRE-GI-0018 regarding HEAFs involving aluminum, and 2) improvements to HEAF modeling in fire probabilistic risk assessment methods. The phase 2 full-scale test plan has been updated and the comment resolution document has been made available in NRC ADAMS under Accession No. ML18233A469. Specific comments in your letter related to the results from the Phase 1 full-scale testing, interpretation of the test results, and the NRC Information Notice 2017-004 are also addressed in the phase 2 full-scale test plan comment resolution document.
As you are aware, the potential issue of HEAFs involving aluminum is currently in the assessment phase of the NRCs Generic Issue (GI) Program. As part of the assessment plan, additional research and testing is needed and planned to assess the hazard.
Your comments and the NRC public workshop held in April will aid an informed and representative testing program to support the assessment of the proposed GI.
The NRC HEAF workshop held in April 2018, allowed for an open dialog between NRC and the public. From those discussions, both test plans have been revised, adding realism and ensuring representative testing, within the limitations of the experiments and testing facility. In addition, the NRC will be working with its international partners and the Electric Power Research Institute (EPRI) under a collaborative research memorandum of understanding to ensure realism and representative test results and other technical aspects related to the HEAF hazard.
As part of our collaboration with EPRI, subject matter experts were invited and witnessed recent HEAF tests at the KEMA Powertest facility. We will continue to be committed to openness and transparency for future testing. This comprehensive effort is designed to ensure an appropriate level of agency response.
The NRC values the time and resources you have expended reviewing and providing feedback on these programs. The NRC staff looks forward to working with all members of the public to ensure realism in its research and risk assessment methods that support the NRCs mission.
Please contact me, or Gabriel Taylor at (301) 415-0781 or via e-mail at gabriel.taylor@nrc.gov, if you require any additional information.
Sincerely,
/RA/
Raymond V. Furstenau Director of Nuclear Regulatory Research
ML18232A390 OFFICE RES/DRA/FXHAB RES/DRA/FXHAB RES/DRA RES/DE NRR/DRA RES NAME G. Taylor M. Salley M. Cheok B. Thomas M. Franovich R. Furstenau DATE 08/21/2018 08/21/2018 09/06/2018 9/10/2018 10/14/2018 10 /19 /2018