ML19276F543
| ML19276F543 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1979 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19276F539 | List: |
| References | |
| REGGD-01.131, REGGD-1.131, NUDOCS 7903300597 | |
| Download: ML19276F543 (28) | |
Text
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VALUE/ IMPACT ASSESSMENT OF PROPOSED REVISION 1 TO REGULATORY GUIDE 1.131, "GUALIFICATICN TESTS.0F ELECTRIC CABLES AND FIELD SPLICES FOR LIGHT-WATER-CCOLED NUCLEAR PCWER PLANTS" Backcround Regulatory Guide 1.131, " Qualification Tests of Electric Cables and Field Splices for Light-Water-Ccoled Nuclear Pcwer Plants," is being revised to respond to ccanents received on the guide and to include more specific definition of fire testing parameters based on the results of research con-ducted at Underwriters' Laboratories. Also, the word " connections" is being deleted frcm the guide title in order to coincide with the content of IEEE Std 383-1974 which is endorsed by the guide. Although IEEE Std 383-1974 has the word " connections" in its title, its contant does not address re-quirements peculiar to the qualification of connections.
IEEE/NPEC is currently developing a separate standard that will address qualification of connections.
a Substantive Chances and Their Value/Imoact 1.
Regulatory Position C.4 was added to modify a provision of a referenced industry standard (in IEEE Std 383-1974) to the effect that all cables used in nuclear pewer plants should meet the accelerated water absorption criterion without regard to separators, insulation thickness and protective cover re-movability. The referenced industrial standard (IPCEA) would exempt cables which have a nonconductive separator between the conductor and insulation, insulation less than 45 mils thick, and insulation having a covering which cannot be removed without damage to the insulation.
Value - The eliminaticn of any exenptions of cable from meeting the water absorption criterien will help assure that no cable intended for use in safety-related circuits will fail to perform its function due to short 730330 osy circuits caused by water absorption. This requirement is particularly significant since deluge systems are proposed as a means of preventing fire propagation.
Impact - There should be no imoact since several cable vendors contacted currently do not take the exemption but certify, by other test data, that
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cables which physically cannot be tested as described, will meet or ex-ceed the water absorption criterion of IPCEA S-19-81.
2.
Regulatory Position C.5 was modified to provide that synergistic effects en aging due to simultaneous application of environmental conditions be given censideration in the accelerated aging program.
Value - Research studies of an NRC sponsored program at Sandia Laboratories has established that, while all materials may not, some materials do exhibit synergistic effects under simultaneous applicatien of accelerated aging environmental ccnditions. Therefore, in order to assure that during qualification testing a cable sample is put in true end-of-life condi-tions, synergistic effects must be given censideration. This is essential as part of the demonstration that equipment (cables) important to safety will functicn under all conditions in which they will be required *w function.
Impact - This provision could have a significant impact en cable qualifica-tion.
If synergistic effects are known to exist in a given cable material, the cost would be as high as $30,000 per test for simultaneous temcerature and radiation aging, provided that a facility can be found to apoly a sufficiently high temperature and radiation dose rate to accomplish die
- desired age conditioning in a reasonably short period of time (3 days).
If a facility cannot be found that can provide the environmental ' con-ditions for a short accelerated age-conditioning time, the costs will increase in direct proportien to the length of time required for lower temperature and radiation dose rate values.
3 Regulatory Position C.5 was modified to provide that locations other than in-plant could be suitable for on-going qualification test programs providing ecuivalent service and environmental conditions are met.
Value - A wider range of facilities will be available for conducting on-going qualification testing, thus providing an alternative to removing cable from an operating plant for use in on-going qualification.
Impact - There is no impact. The provision merely broadens the places where on-going qualification tests can be accomplished.
4.
Regulatory Position C.7 was modified to provide for testing other than full-scale vertical tray flame testing to demonstrate that the fire retarding properties of cable are not adversely affected by aging.
Value - The provision broadens the acceptable evidence that aging of cable does not adversely affect the fire retarding preparties, thus providing alternate ways for achieving the desired results without expensive full-scale tests.
Impact - There is no impact. The provision merely establishes other acceptable methods of meeting an existing requirement.
5 Regulatory Position 9 was added to specify size, ventilation requirements and ambient temcerature of the test cell used in fire qualification tests.
Value - It has been demonstrated that test results for a given type of cable vary fran facility to facility decending uoan test cell configuration and other test parameters. This provision standardizes cell size and other significant test parameters to help assure that consistent results can be obtained in various test facilities.
Impact - The impact should be minimal. Any test rocm or bay, no matter hcw large, can be used by constructing an inexpensive test cell inside using incrganic board material clamped together to form the standard test cell. Other parameters including ambient temperature and ventilation re-quirements can be easily regulated with existing equipment to meet the requirements with little, if any, additional cost.
6 Regulatory Position 10 was added to specify the cable tray construction to be used in the fire qualification test.
Value - Cable tray construction can have a pronounced effect on the way cables burn. Trays of different masses or rung spacing could alter heat absorption and burning pattern, thus affecting test results. Spec-ifying a standard tray will contribute to obtaining consistent results.
Impact - There is no impact. The use of a cable tray is an existing re-quirement. The provision merely provides standardization.
7 Regulatorf Position C.11 wa, added to clarify that the intent of the three fire tests is to demonst" ate reproducability and that all three tests must meet the fire retarding requirements in order for the cable to be considered as having passed the fire retardancy test. Also, a provision was added that, during the fire test, the cable should be tied on everf other rung using metal ties.
Value - The provision is to prevent a misunderstanding that a particular cable type, having passed one or two of the three fire tests, would be
. considered as being acceptable. Addi:1cnally, metal ties do not burn and hence will keep the cable in a relative fixed position during the test, thus helping assure reproducability.
!=cact - There is no impact.
It was the original intent of the standard that all three tests meet the requirements in order to consicer the cable as having passed the test. Also, tying the cable is not a new requirement.
The provision merely standardizes the use of non-burnable ties.
8 Regulatory Positions 15 and 17 were added to supplement the record of test results by recording flame height at regular intervals during the test and by specifying that data recorded during qualification testing should be of suffi-cient detail to substantiata compliance with test requirements.
Value - Dccumentation requirements of IEEE Std 383-1974 fail to specify the necessity for recording the rate of cable burning during the fire test. Inclusion of the rate of burning will add another cable character-istic useful for the designer in cable application.
Impact - There should be very little inpact since a record of the cable burning rate is a small addition to the documentatien already required.
Enciosure 2 DISCUSSION OF PUBLIC C0Z'4ENTS Public comments on proposed Regulatory Guide 1-131, " Qualification Tests of Electric Cables, Field Splices, and Connections for Light-Water-Cooled Nuclear Power Plants," dated August 1977, were received frem those listed below, and a discussion of the comment follows:
Russell M. Bimber, Chemist Kenneth W. Dungan, Professional Loss Control, Inc.
R. L. Mitti, Public Service Electric and Gas Ccmpany D. S. Duncan, General Atemic Company P. B. Haga, Offshore Power Systems John B. Gardner, The Kerite Company A. J. Simmons, IEEE/NPEC A. Garshick, IEEE/ICC Glenn G. Sherwood, General Electric Ccmpany W. H. Owen, Duke Power Ccmpany Comment #1 - The 5 to 1 air to gas ratio would not produce anywhere near the desired amount of heat. The air to propane ratio of about 25 to 1 or an oxygen to propane ratio of 5 to 1 would be required.
Rescanse - The comment is correct. Mcwever, the remaining required air (oxygen) comes from the atmosphere. No change in the guide is proposed as a result of this comment.
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-2 Comment #2 - The term "self-extinguishing" has created great controversy in both the plastic industry and the fire protection engineering comunity.
It is suggested that the term " fire retarding tendency" be used.
Resolution - The coment has been incorporated into the guide.
Comment #3 - The Arrhenius method of component aging is overly conservative and the data cannot be used for absolute detennination of insulation life.
Resconse - The Arrhenius technique for component aging is given in IEEE Std 383-1974 as an acceptable method which may be used.
It is not a requirement. Other methods of aging, which can be justified, will also be acceptable.
Ccment #4 - NRC has suggested two methods of ongoing qualification. Other methods may be just as effective and not involve removal of cables from the plant.
Resconse - The guide delineates methods which are acceptable to the staff.
An applicant has the option of proposing alternative methcds. Mcwever, the guide has been changed to provide that locations, other than in-plant, which create equivalent conditions for in-service aging, may be used.
Comment 45 - The guide states that the IEEE Std 383-1974 fire test is not acceptable as a method for qualifying installed cable. The guide does not, however, establish guidelines for test methods used to qualify installed
_ configurations, nor does it give any indication of special provisions" to be used in the case of splices.
Resconse - The purpose of the guide is to provide an acceptable method for qualifying electric cable as a component. The adequacy of installed cable systems is addressed by other guides such as Regulatory Guide 1.75,
" Physical Independence of Electric Systems," and Regulatory Guide 1.120,
" Fire Protection Guidelines for Nuclear Power Plants."
The " pecial provisions" for field splices is that they should meet the fire test provisions af the standard. The guide has been modified to make this clear.
Comment #6 - The guide does not provide guidance on the fire qualification of non-Class lE cables that could affect the performance of Class 1E cables.
Resconse - Non-Class lE circuits that are in close proximity to Class lE circuits are (per Regulatory Guide 1.75) classified as associated circuits and must meet all of the environmental qualification and fl =e retardance, etc., requirements of Class lE.
Comment 17 - The statement that " test of the cable or connection assembly, as applicable, shall then supplement the cable tests in order to qualify connections" could be interpreted as requiring that each cable-connector configuration be tested.
- Response - IEEE Std 383-1974 is supplementary to the parent document IEEE Std 323-1974 and pertains specifically to type testing of cables and field splices as the preferred method of qualification. Qualifi:stien by analysis and by operating experience are also acceptable methocs under cer-tain conditions. Section 1.3 of IEEE Std 383-1974 states that qualification of one cable may permit extrapolation to other cables of the same type. Con-nections are not adequately covered in IEEE Std 383 and IEEE/NPEC is in the process of developing a separate standard for connections. Regulatory Guide 1.131 has been changed accordingly.
Cor: ment #8 - The citing in the standard of 136*C as a specifically required data point for aging is wrong. The intent is that the data point should be 136*C or lower making sure that the data point is at least this low.
Resolu' tion - The guide has been changed accordingly.
Comment 19 - The apparent requirement for vertical tray testing of aged as well as unaged cables is an extension well beyond the intent of IEEE Std 383 and will greatly complicate and crc. ate resistance to the usage of IEEE STd 383 fire test. This new requirement may rapidly push all testing into
,a few (if any) labs that have fire testing, large aging ovens and radiation aging facilities.
Rescanse - The requirement to test aged as well as non-aged cable is not an extension beyond the intent of IEEE Std 383. The standard specifically states (Section.1.3.5.2 "Ag1ng") that " type testing for design basis event
5-conditions (fire being a design basis event. Section 1.3.4.2.2) shall involve both aged and unaged samples." To alleviate the concern regarding pushing all testing to a few labs with large-scale facilities, a statement has been added in Section C.7 of the guide giving an alternative to full scale vertical tray flame testing of aged cable.
Coment 410 - The description of source flame is unworkable.
It should be restated so that the burner's fuel input is 70,000 BTU. There is no feasible way in most laboratories for measuring heat release.
Resolution - The description of the flame source (Section C.10) has been changed to incorporate this cement.
Cement fil - Neither Regulatory Guide 1.131 nor IEEE Std 383 ackn:wledge the fact that many cables in the nuclear pcwer plant are not subject to significant radiation levels (e g., cables in the control recm). These cables shculd not require irradiation as part of the qualification, and the regulatory guide pos-ition should reflect this consideration.
Resoonse - The standard adequately addresses the concern of this coment. Sec-tion 1.3.4.1, " Meeting Service Conditions," of IEEE Std 383-1974, states that, "The total station may be subdivided into zones with substancially different ambient conditions, and if segregation of cable in certain areas is assured, a cable need only be suitable for meeting service conditicn-in those zones in which it is located". No cht.1ge in the guide is proposed as esult of this comment.
5 C
ent d12 - The IEEE Std 383 test sequence is not the only acceptable test sequence for achieving thennal and radiation exposure.
It is recc= ended that Section 2.3.3 be modified to add the phrase, "or a valid alternative
- after the phrase, "the folicwing test sequence".
Rescense - The purpose of a regulatory guide is to outline provisions which are kncwn to be acceptable to the NRC staff. Valid alternatives to any staff position will always b given consideration as stated in the " boiler plate" at the bottom of Page 1 of the guide and in Section D, " Implementation" of the guide. No change in the guide is proposed as a result of this ccement.
Cement #13 - The word, " burn" should be changed to the phrase, " burn or gicw until cooled belc4 the ignition temperature". This change will pernit evalua-tion of the extent of propagation or absence of propagation in the glowing mode above the ignition temperature.
Rescanse - The dictionary definition of burning includes gicwing. Therefore, the total damage to the cable is accounted for if the cable is allcwed to burn until the c able seTf-extinguishes or burns to the end of the tray. No change in the guide is proposed as a result of this cc=ent.
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Subject:
NRC Pegulatory Guide 1.131 Co.ments for Early Pevision Duke Flie: A-12.16.2 Gen tlemen:
Ve feel that the last sentence of paragraph C.6 of the subject guide should be deleted, that is, aged cable should not be required to be fire tested.
Current practice of the industry is to accelerate aging of the Individual cenductors cnly.
If the Individual conductors meet the required aging parameters then varicus systems of binders, tapes, fillers, Jackets, etc.
can be added to the qualified singles to make up cables for particular application requirements. As a matter of practice, binder, tapes, fillers, armor, Jackets, etc. are not included in the accelerated aging precess.
To require fire testing of a cable censtructicn before and after accelerated aging wculd necessitate a cerrplete restructuring of the industry-wide accelerated aging methods. We believe that the perceived gain is not worth the added expense to the Industry, particularly since IEEE 383-1974 Is a screening test and is not representative of a fully leaded tray. Moreover, since the NRC does not presently give credit to cable fire retardancy as part of the plant fire protection system, this added testing requirerrant is further unwar ranted.
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Very truly ycurs,
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November 2,1977 Ltr. No. 780-309-77
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Secretary of the Ccr.nission
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Attention:
Chief Cocketing and Servicing Section 0
y Gentlemen:
SUBJECT:
GENERAL ELECTRIC COMMENTS ON REGULATORY GUIDE 1.131
" QUALIFICATION TESTS OF ELECTRIC CABLES, FIELD SPLICES, AND CCNNECTICNS FOR LIGHT WATER-COOLED NUCLEAR PCWER PLANTS," AUGUST 1977 The General Electric Ccmpany has reviewed the subject guide and has develcped the ce=ents provided herewith in Attachment A.
The changes recc= ended in Atcach=ent A are intended to improve the meaningfulness and cachnical accuracy of the Guide.
Please revise the Guide to incorporate these ce=ents.
If you have questions regarding this letter, please centact R. J. Murillo (4C8) 925-3406.
Very truly yours, b
Glenn G. Sherwcod, Manager Safety & Licensing Operation GGS:fg/15 Attachment g'
cc:
M. Kehnecuyi (NRC)
Y L. S. Gifford (GE)
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PCWER PLANTS," AUGUST lg77.
CR LIGT MTER-COOLED NUCLEAR 1.
Conrent:
Neither Regulatory Guide 1.131 nor IEEE-383, "IEEE Standard for Type Tests of Class lE Electric Cables, Field Splices, and Ccnnections for Nuclear Power Generating Stations," ackncwledge the fact that many cables in the nuclear power plant are not subject to significant radiation levels.
Control Cc= plex, are not subject to significant radiation leve cables should not require irradiaticn as part of the qualification, and These the Regulatory Guide position should reflect this consideration.
2.
Cement:
The IEEE-383 test sequence is not the onl achieving ther::a1 and radiation exposure.y acceptable test sequence for GE recc= ends that paragra::h 2.3.3 of IEEE-383 be modified to add the phrase, "or a valid alternative" after the phrase, "the folicwing test sequence."
3.
_ Cement:
In the last line of paragraph C.13, (s), the word, " burn" should be changed to the phrase, " burn or glcw until ccoled belcw the ignition temperature...".
This change will permit evaluation of the extent of propagation or absence of propagation in the gicwing made above the ignition temperature.
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5 5 5 AY STR E ET 3 CSTC N M A S S AC M U S ETT5 C 212 5 E171 2 G S-2t C2 < *s$sa 34-C E Cd Oc+wber 24, 1977 Directorate of Regulatory Standards U.S. Nuclear Regulatory Comission Washington D.C.
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Attention:
A. S. Hintze
Reference:
Regulatory Guide 1.131 Dear Mr. Hintze Coninents to Reg Guide 1.131 have been solicited from the working group that prepared IEEE-383-1974. Two were received endorsing the Regulator /
Guide.
Ore conrnent received from J. Bauer, chairren of SC-2 of NPEC, offered coninents on the addition of other nethods for on going qualification.
Mr. J. B. Gardner, chairmen of SC-12 of the Insulated Conduc+4rs Comittee of IEEE, has several comments to the guide, one of which deals with on going qualification as well.
I have asked him to forward these comments directly to you since they are the only substantive ones that have been presented.
Yours truly br L
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A. Garshick
' Chair:en CC-WG 12-3 2 IEEE 383-1974 cc:
J. Bauer J. Gardner
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Subject:
Regulatory Gulde 1.131 G. M. WH,h, Jr.
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References:
1)
A. Si=cus letter to.NRC
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by J. T. Bauer) dated 10/24/77
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~1. Carshick letter to NRC AI5CN WITH -
dated 10/24/77
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J. Gardner letter to NRC dated
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10/25/77 with attached co=enen 7, ;, g,,,,,,
N5 50 dated 10/24/77 F.W.Chnd!w N51.NSMS
Dear Sirs:
T. J. M.,i.
N51. Fir. Pre.cu.n This is to follow up Reference 1 and submit the I" g3,h3 Nuclear Power Engineering C =1:ces co=nents on the above subject D. C. Plesh.,
Regulatory Guide.
cl.NIS R. G. B..h..
Mr. Carshick via Reference 2 has reported on the revicy of 41 N42 RG 1.131 by the Working Group that prepared T m -383-74, A. J. Sewgi.
5",E.Cc Mr. John 3. Cardner, our MPEC liaison with the Insulated A
,go Conductor Cc=1::ee of 17.. has sub=itted ccm=ents (Reference 3)
SME. a t6 A. J. 5; Which We hereby endorse.
Additional co=ents are as follows:
1.
Next to las paragraph of 3 (page 2) - The reference to RG 1.120 should be deleted until the disposition of RG 1.120 is cicar.
lYSl7
U. S. Nuclear Regulatory Co=21ssion Page 2 2.
Paragraph C4 "Cngoing Qualification Procedure" (page 3)
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This paragraph should as a =ini=u:2 add:
"(c) other methods where justified =ay be used to extend the qualified life of installed cables." Additional laboratory testing of cabling for exa=ple =ay indicate the original assess =ent of qualified life was extre=ely conser-vative.
Additionally, the paragraph gives no specific direction on hev to acco=plish the ongoing qualification. For exa=ple: What constitutes an acceptable number of cables?
How many cables should be re=oved? How do we deter =ine what are " representative" cables?
The paragraph on "Cngoing Qualification Precedure" there-fore needs rework. We suggest this section
- a deleted fro:2 the Regulatory Guide at this ti=e and held for a future; revision.
3.
Paragraph CS (page 3) -
The definition of the source ter= is i=poftant to cable qualification and as we understand is being revised in the rework of RG 1.89.
It therefore appears =icleading to refer to the source te::2 in RG 1.89 at this time. Alternately, this RG could be held until RG 1.89 is reissued.
s JT3/st Attach =ents (2) and (3)
Prepared by:,
Approved by:
M jjJ.T.Bauer, Chair =an A. J. /S,1==ons, Chair =an
- f ySC-2 Equipment Nuclear Power Engineering Qualification Coc=1ttee cc:
R. Allen I. G. Eacton J. Cardner W. R. Kr:esi A. Carshick W. S. Morgan J. L. Keepringer C. L. Waccer
[
- , say Street Seymour Connecticut 06483 (203) 388 2591
- WSh, the kerite company October 25, 1977 Air. A. S. Hintze U. S. Nuclear Regulatory Commission Office of Standards Development Washington, D.C. 20555
Dear A1:
The enclosed comments on Reg. Guide 1.131 are sent direct in that I requested of Al Garshick the opportunity to modify for clarity several comments originally transmitted to him.
These comments are primarily my own. However, the No. 3 comment coincides with that formerly passed on to LIr. Garshick by John Bauer, Chairman of SC-2. Comments No. 2 and No. 5 represent the opinions of several members of SC-2 of NPEC and the Insulated Conductors Committee with whom I have exchanged views.
I trust that the less than formal submission of these comments, as far as IEEE committees are concerned, does not interfere with their proper consideration of each, since each one should certainly stand on its own merits. I only hope I have made the comments sufficiently clear so that the points will not be missed, but if you or other staff members have any questions I should be very happy to explain further, either by phone or in writing.
Very truly yours,
,m
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JBG:me ohn B./Gardner Attachment cc: Mr. A. C-arshick ) With Mr. J. Bauer
) Attachment MusB2LL a suosiciary of HARVEY HUBBELL INCORPCRATED
ay Street Seymour, Conrecucut C6483 (203) 888-2531
- dS7, the kerite company October 24, 1977 CONDIEh"I'S ON RG 1.131 DRAFT I believe that most of the issues raised could be a serious disservice to the Industry if not acted upon.
1.
P. 2, left column, line 5 should be changed to:---of the cable when subject to moderately severe but limited conditions of source fire, grouping of cables for mutual heat exchange and vertical orientation.
However---.
There has been very substantial misunderstanding as to the intent and function of the 383 fire test. The several explanations in 383 have fed the controversy. Therefore, it seems appropriate that a better orientation in this respect may be a real contribution to understanding the place that the fire test really has in the whole qualification process. The above words will, I believe, help to do just this. In addition, the following slight change may also help:
In the following paragraph, insert "some aspects of" after "simniqHg,"
Ghange last word in next-to-last line from "the" to "any."
2.
Section C4. The citing of 136' C is wrong, just as in 383. It is a minor but obvious error in 383 and should not be promulgated in a RG. It should be changed to: " Aging data----data points including one of 136" C or lower and two or more --." There was never any intent to force all qunlifiers to use 136', but only to be sure thtt data collected went at least this low.
3.
P. 3, Ongoing Qunlification Procedure. I find the first eight lines incomprehensible as a criterion for requiring ongoing qualification.
This issue of what is proper limit for judging qunhfication life is important, not well defined in IEEE documents to date, but 8 lines seem to caly compound the confusion. Methods a and b are not the only valid methods for ongoing qualification. In fact, they are probably not the most rigorous or practical methods available, and one of them has been subject to serious question of validity. Therefore, an added sentence is needed, such as used in IEEE 323, to not only permit, but encourage, development and use of other methods.
MU BB E1.1.
a si,0sidiary of HARVEY Nt;S8 ELL INCORPCRATED
COMMENTS ON RG 1 1 DRAFT 2.
October 24, 1977 4.
P. 3, Section CG. The apparent requirement for vertical tray testing of aged and unaged cables (presumably 6 tests for one cable type) is an extension well beyond the intent of 383 and will greatly complicate and create resistance to the usage of the 383 fire test.
This new element, combined with common extension of 383 to lenger trays, fuller trays, and the application of the fire test as a production test to all items of an order, may rapidly push all testing into the few (if any) labs that have the fire testing, large oven aging, (and radiation aging ?) facilities required.
The intent of the original working group (as I knew it) was that fire resistance of aged and unaged cable materials be directly compared in a rigorous way (not vertical tray test) to demonstrate that aging did not have an adverse effect. A variety of small scale lab tests are available to do this. It is absurd to repeat large scale tests to reprove the same thing again and again.
The second sentence should be changed to: " Additional testing shall be done to demonstrate that the burning-self-extinguishing related properties of materials or cables are not adversely affected by ag:ng, or the vertical tray flame testing shall be carried out on both aged and unaged cables." Incidentally, a rather devious use of their present langutge might induce me to include one aged cable in a single test of otherwise unaged cables as full compliance.
5.
P. 3, Section C9. I believe this section is in error and probably not what was intended by the NRC staff. In any case, it is unworkable. It should be restated so that the burner's fuel input is 70,000 BTU. There is no feasible way in most laboratories for measuring heat release.
Additionally, there certainly cannot be compliance with the BTU release figure and other aspects of the flame description given in the RG and Standard.
ohn B., Gardner JBG:me
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t U.S. Nuclear Regulatery Ccmmissicn 7
Occketing and Servica Branch
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Dear Sir:
Offshore Pcwer Systems has reviewed Regulatcry Guide 1.131, issued for ccmment in August 1977. As a result of our re-view we wish to offer the following ccmment for your censid-eration..
Section C.3. states in part that..." test of the cable ce connection assembly, as applicable, shall then supplement the cable tests in order to qualify the connections and other aspects unique to planned usage. Tnis statement could be interpreted as requiring that each cable-cennector configuration be tested..Since the connectors are most often located in connection ccmpart=ents which in turn are a part of the teminai equipment, this would mean that all manner of electrical equipment (motors, etc.) would have to be tested as a supplement to cable tests. We believe this recuirement (if intended) to be excessive.
There is very little difference between generic types of cables and connections, and extrapolation of tests shcuid be valid for similar applications withcut perfoming still more tests. The ner:.al recuired margin in tasting will al-low for this logical extrapolation.
We therefore recc=end that this section of the guide be re-worded to permit judgement in the definition of required tar-minal testing.
Vem truly ye rs, W
o p.3.Haga,[hiefEngineer Mechanical Nuclear Engineering
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Secretary of the Ccmission Ny i U. S. Nuclear Regulatcry Comission pp Washington, D.C. 20555 pp Attention: Oceketing and Service Section U
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% s -J Gentlemen:
General Atcmic Cc=pany has reviewed Regulatory Guide 1.131, " Qualification Tests of Electric Cables, Field Splices, and Ccnnecticns for Light-Water-Ccoled Nuclear Power Plants," and offers the folicwing cc=ents for your consideration:
1.
It is recc= mended that the wording in Position C.4 be changed to
" Aging data shall be develeced..." since in the context of IEEE-383 it is not clear to whcm tne cata should be " submitted".
s 2.
The addition in Position C.4 of the statement "If there is not sufficient evidence..." raises the question as to what would constitute sufficient evidence and how this decision wculd be reached.
If there are criteria acceptable to the NRC for evaluating aging data, scme reference shculd be made to them.
3.
In Position C.4, " Ongoing Qualification Pro:edure," the NRC has suggested two metheds of ongoing qualification tests. Other methods may be just as effective and not involve removal of cables from the plant.
It is recommended that a statement be included that other ongoing qualifica-tion methods are acceptable if they adequately demonstrate projected life.
4.
Position C.7 states that the IEEE-383 fire test is not acceptable as a method for qualifying installed cable.. The regulatory guide does not, hcwever, establish guidelines for test methods used to qualify installed configurations, nor does it give any indication of the "special provisions" to be used in the case of splices.
While we agree that the IEEE-383 flame test cannot be applicable to all installed ccnfigurations, the implicaticn in Positicn C.7 of "qualifi cation of any installed cable system configuration" is far-reaching in view of the probable large number of configurations. Further, it is not apparent what criteria would be applied to establish qualificaticn.
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Secretary of the Cc==ission Oct:bar 18, 1977 The regulatcry guide should clarify this ;csiticn wi-h regard to cable tray arrangements that would er would not need to be quali-fied by test, what wculd ccnstitute an acceptable test, and what the acceptance criteria would be.
It is recc== ended that initiating fire be specified as the IEEE-383 burner unless the particular configuration is subject to more severe fire scurces such as over-current or nearby fla::mable materials.
5.
The regulatory guide does not provide guidance on the fire qualification of non-Class IE cables that could affect the perfor=ance of Class IE cables (due to insufficient separation or isolation). The NRC should address this questian either as part of R.G.1.131 or in a separate guide.
Sincera
,V h ce-D. S. Cuncan, Acting Director Plant Licensing Division CSD:JHL:=ef O
O PSEG Public Service E!ec:nc and Gas Com;:any 80 Park P! ace Newark, N.J. 07101 Phone 201/62r-TCCO October 6,1977 N
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.#1 i#[%7 U.S. Nuclear Regulatory Commission Washington, D.C.
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Attention:
Docketing and Service Branch h
Gentlemen:
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REGULATORY GUIDE 1.131 - QUALIFICATION TESTS OF ELECTRIC CABLES, FIELD SPLICES, AND CCNNECTIONS
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FOR LIGHT WATER CCOLED NUCLEAR PCWER PLANTS In accordance with the Federal Recister notice of August 22, 1977 (42PR42262), we herewith sucmit comments on the above-referenced Regulatory Guide, specifically with respect to long-term physical aging properties and flame testing on aged cables.
Wq appreciate this opportunity to comment on this version and hope that our comments will be of value to the Commission in the preparation of the final Guide.
Very truly yours, A./ l,
, h;t,hVj' R. L. Mittl General Manager -
Licensing and Environment Engineering and Construction Attachment
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PUBLIC SERVICE ELECTRIC AND GAS COMPANY COMMENTS CN REGULATORY GUIDE 1.131 - CUALIFICATION TESTS CN ELECTRIC CA3LES, FIELD SPLICES, AND CONNECTIONS FOR LIGHT WATER CCCLED NUCLEAR PCWER PLANTS We are in general agreement with Regulatory Guide 1.131, which endorses IESE Standard 383-1974 with several qualifications.
For example, we agree with the endorse =ent of the gas burnce flame source.
However, there are two areas of the Guide that warrant additional consideration.
These two areas are Section 2.3.2, "Long-Term Physical Aging Properties" and Section 2.5.1.
which requires a fla=e test on aged cables.
Section 2.3.2 suggests two ways of establishing long-term performance of the insulation, the Arrhenius method or an ongoing qualification method.
We believe the Arrhenius method is inaccurate for absolute measurement of insulation life because it produces an overly conservative life, but is useful in comparing newer compositions to well-known materials.
Arrhenius aging is based on a single chemical reaction.
Today's flame retardant insulations have many components, and at least four different chemical reactions relating to aging are occurring simultaneously.
At low temperatures, similar to those seen in service, a much slower reaction rate is dominant.
At higher temperatures, near those selected for obtaining Arrhenius data, a faster reaction rate occurs, thereby inaccur-ately predicting an apparent short life at service temperatures.
For instance, Arrhenius data on neoprene indicates a life of 14.7 years at 130C.
A sample of this insulation has been installed outdoors in New Jersey for many years, in an average annual temperature of 130C.
Periodic testing on this cable showed a life of 35 years.
Similar ce=parisons between the life predicted by high temperature Arrhenius data and the actual measured perfor=ance of other rubber materials yield similar results.
Therefore, Arrhenius data cannot be used for absolute determination of insulation life.
However, on newer materials where sufficient time to determine low temperature, long time points on an Arrhenius plot does not exist, the Arrhenius data for these modern insulations can be compared to well-known insulations that have operated successfully for many years.
For instance, in comparing EPR insulation to butyl rubber insulation, the EPR takes six to ten times as long to reach a stated end point at elevated Arrhenius ta=peratures.
Since butyl has performed successfully for many years, by analogy, we can conclude that the EPR will also.
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PUBLIC SERVICE ELECTRIC AND GAS CCMPANY COMMENTS CN REGULATORY GUIDE 1.131 - CUALIFICATION TESTS CN ELECTRIC CABLES, FIELD SPLICES, AND CCNNECTIONS FOR LIGHT WATER CCOLED MUCLIAR PCWER PLANTS Section 2.5.1 of the Regulatory Guide requires a fla=e test on aged cables.
Elevated temperatures, which are necessary to simulate aging by the Arrhenius methed, may be high enough to alter the flame retarding characteristics of the insulation.
At service temperatures, however, the flame retardant charac-teristic is quite stable.
Therefore, aging an insulation according to a highly elevated Arrhenius temperature may produce totally inaccurate flame test data.
A more realistic assessment of flame retardant stability at in-service temperature should be applied to demonstrate aging versus flame resistance characteris-tics.
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Secretary of the Ccemission d g. *.. p U.S. Nuclear Regulatory Ccrmnission
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Re: Regulatary Guide 1.131
Dear Sir:
I would like to make the folicwing cormr.ents on Regulatory Guide 1.131:
- 1. Paragraph 6, which references Section 2.5.1 of IEEE 383, contains misleading termino 1cgy concerning cable insulations having "self-extinguishing tendencies." The tern self-extinguishing has created great controversy in both the plastics industry and the fire protection engineering cor= unity. Because of the misleading nature of the term, the Federal Trade Commission has criticized its use in advertising information.
I recoment the wording of this section be changed to either fire retarding tendencies or flame propagation characteristics.
These terms better express the intent of the test and will be more meaningful to the fire protection comunity.
- 2. Paragraph 7, which references Section 2.5.2.2 of IEEE 383 also uses "self-extinguishing." For the same reasons as stated a.bove, this wording should be changed frem"that are inadequately self-extinguishing" to "that display undesirable flame propagation haracteristics (or fire retarding characteristics)."
I appreciate the opportunity to cement on t.is guide.
I trust that you will consider these recomendatens for future issuance of Regulatory Guide 1.131.
If you have any questicas concerning these comments, please feel free to contact me.
Atat.'adt,)ad.g(r\\&r-j Very truly yours,
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There appears to be a significant error in Re6ulatory Guide 1.131:
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Page 1.131-3, w;hs 9 a:d 11 deal with releasing 70,CCO 3tu/ hour by burni::s 27.8 sta.-dard cubic feet of propane por hcur with an air to gas ratio cf 5 to 1 This veuld net p:cduce a:rjuhere near the desired a=ount of heat.
Ccaplete ecs'custion of the propano uculd prcduce the desired a cunt cf l
heat, but would require an air to prepa e ratio cf about 25'to 1, or an or/sen to propane :stio of 5 to 1 2.e stoichic etry cf the ec bustica may be represented as follcws:
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2 Cr/ gen shculd give a hotter bazo than.five ti=es its volu=e of air, since the nitregen ec=# sing about 8C74 of the air would abscrb sc:e of the heat' produced. 2.e erfgen flame ight also be s aller.
I cocme::1 your effed to standardize burner gec ctry by sugges'drg; a specific burner. Still, it =ay be desirable to speify sc e ec:bination of te=;erature to be reached at a specified point on the ca.ble t:sy specimens and one contin-uous ti.e for which that temperature shall te maintained.
Sincerely, w-...'. i--J : e-*'. Q:. M,f.l.. $,.
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(Chemist: E:i '.Icstern Eccerve Univ. ' th. )
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