ML19347F532

Testimony of Jf Montalbano & FP Barbieri Re Tx Pirg Contention 12,cable Fires.Prof Qualifications Encl.Related Correspondence

ML19347F532
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	05/11/1981
From:	Barbieri F, Montalbano J EBASCO SERVICES, INC.
To:
Shared Package
ML19347F516	List: ML19347F515 ML19347F520 ML19347F522 ML19347F524 ML19347F527 ML19347F529 ML19347F530 ML19347F531 ML19347F532 ML19347F534 ML19347F535 ML19347F536 ML19347F537 ML19347F539
References
NUDOCS 8105190547
Download: ML19347F532 (17)

Text

I WTED ff)RRESPONDENCB 93 Qg 5-11-81

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3 MC UNITED STATES OF AMERCIA 1

NUCLEAR REGULATORY COMMISSION MAY 13195)j,, 7 2'

BEFORF THE ATOMIC SAFETY AND LICENSING BOARD C d

g ofnce of the sm 3

T2Ve7/ a s.r.

\\

In the Matter of

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4

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W HOUSTON LIGHTING & POWER COMPANY

)

Docket No. 50-466 S i

)

(Allens Creek Nuclear Generating

)

6 Station, Unit No. 1)

)

)

7 O

DIRECT TESTIMONY OF J.

F. MONTALBANO AND F.

P.

BARBIERI ON BEHALF OF HOUSTON LIGHTING & POb",R COMPANY 9

ON TEXPIRG CONTENTION 12/ CABLE FIRES 10' O.

Mr. Montalbano, please state your name and job position.

11 A.

My name is Joseph Montalbano and I am a Supervising 12 Electrical Engineer for Ebasco Services, Inc.

13 0.

Please state your educational backginund, work experience 14 and professional qualifications.

15 A.

The statement of my background and qualifications is 16 attached as Exhibit JFM-1 to this testimony.

l 17 o.

Mr. Barbieri, please state your name and job position.

18 A.

My name is Fred Barbieri and I am the Lead Fire Pro-19 tectiun Engineer-ACNGS for Ebasco Services, Inc.

20 o.

Please state your educational background, work experience 21 and professional qualifications.

22 A.

The statement of my background and qualifications is 23 attached as Exhibit FPB-1 to this testimony.

24 9

Mr. Montalbano, what is the purpose of this testimony?

25 A.

The purpose of this testimony is to address TexPirg 26 Contention 12 which alleges that:

27 Electrical wiring for the ACNGS is susceptible to fast flaming, and potential resulting common mode E

failures, in the event of an intense flash fire.

8105190 % 7

1.

2 A fire protection research test conducted by the Underwritete Laboratory for the Commission, which 3

the Staff forwarded on October 30, 1978 to the Board and to those on the service list, indicated that 4

modifications to certain of the Staff's fire pro-tection criteria may be necessary.

6 0

What is your interpretation of this contention?

7, A.

Intervenor contends that the electrical wiring for 8

ACNGS is susceptible to fast flaming and therefore has the 9

potential to result in the failures of redundant safety-10 related (Class lE) cables in the event of an intense flash 11 fire.

In general, Intervenor appears to allege that the 12 present fire protection criteria for cable and electrical 13 wiring to be used at ACNGS is inadequate.

14 Q.

What is the fire protection criteria under NRC regula-15 tions used for the safety-related electrical cable at 16 ACNGS?

17 A.

Criterion 3 of Appendix A to 10 CFR Part 50 requires, 18 in pertinent part, that:

19 Structures, systems and components ir.portant to safety shall be designed and located to minimize, 20 consistent with other safety requirements, the probability and effect of fires and explosions.

21 Noncombustible and heat resistant material shall be used wherever practical throughout the unit, 22 particularly in locations such as the containnent and control room.

Fire detection and fighting 23 systems of appropriate capacity and capability shall be provided and designed to minimize the 24 adverse affects of fires on structures, systems, and components important to safety.

2,0 26 ACNGS structures, systems and components important to 27 safety are identified in PSAR (Section 3.2) and include 28 electrical cable designated as Class lE, as defined in

1.

2' IEEE Standards 380-1975, " Definition of Terms Used in IEEE 3

Standards on Nuclear Power Generating Staticus."

4 Q.

Does the ACNGS design satisfy the criteria set forth in 5

Criterion 3?

A.

In order to satisfy Criterion 3, ACNGS design utilizes 6l 7~

the " defense-i n-depth" approach recommended by Regulatory 8

Guide 1.120 " Fire Protection Guidelines for Nuclear Fower 9'

Plants."

Defense-in-depth attempts to minimize both the 10 prcbability and the consequence of postulated fires by 11 utilizing all of tha following three elements:

12 1.

prevent fi res from starting; 13 2.

detect fires quickly, suppress those fires which 14 occur, extinguish fires quickly thereby limiting 15 their damage; and 16 3.

design plant safety systems so that should a 17 fire stsrt in spite of the fire protection 18 program and burn for a considerable time in 19 spite of fire protection activities, the fire 20 will not prevent essential plant safety functions 21 from being performed.

22 None of the above three elements is complete or adequate 23 in and of itself.

The secret of defense-in-depth is to 14 achieve an adequate balance of the three basic elements.

25 Q.

How does the ACNGS design with respect to electrical 26 caoles address the first clement of Regulatory Guide 1.120, 27 that is, preventing a fire from starting?

28 A.

ACNGS his selected cables which have proven fire

i s

l 1

1

_4_

2 retardant properties.

3-O.

How are you assured that these procerties are flame 4

retardant?

5 A,

Flan.e retardant properties of Class lE cables can be 6

adequataly demonstrated by type testing in accordance with 7l] IEEE Standard 383-1974, "IEEE Standard for Type Test of 1

81 Class lE Electric Cables, Field Splices, and Connections for N

9 Nuclear Pcwer Generating Stations."

Cables which pass this 104 test have been accepted as meeting NRC Branch Technical 11 Position APCSB 9.5-1, Appendix A dated May 1976 and Regulatory 12 Guide 1.120.

All ACNGS Class lE cables will satisfy the 13 criteria of IEEE 383-1974.

14 IEEE 383-1974 includes procedures for a flame test of 15 representative samples of both aged and unaged samples of 16 the cable category being qualified including the cable 17 insulation.

This test was developed to demonstrate that 18 qualified cables installed in the vertical tray configura-19 tion specified in the test will not cause fire propagation 20 after the flame source has been removed.

(This arrangement 21 represents the worst case condition from a flame propagation 22 point of view).

A successful IEEE 383-1974 type test 23 provides adequate assurance that the insulation and jacketing 24 material of cables installed in a tray will not support the 25 spread of flame within that tray.

26 o.

would you describe how the fire protection properties 27 of electrical cables are vecifie??

28 A.

The Office of Nuclear Regulatory Research has initiated f

1.

2 a series of generic tests to determine the effectiveness 3

of fire protection features used in nuclear power plant 4

designs.

The test program in part examined:

5 (a) the c'fects of fires on various cable insulations, 6

(b) the effects of physical separation.

7 since fire protection features vary considerably from 8

plant to plant, the fire protection research program was 9

designed to provide msic data to assist the staff in 10 the review of the proposed fire protection features for 11 each plant design.

12 several of these tests have provided data for evaluation 13 of the IEEE 383-1974 flame test and its adequacy as a 14 benchmark for the design objective of minimizing the spread 15 of a fire within a cable tray.

For example, in an experiment 16 conducted at sandia Laboratories, cable of a construction 17 that had passed the IEEE 383-1974 flame test was installed 18 in a horizontal run of cable tray, and ignited using the 19 IEEE 383-lC74 flame-test burners.

From the reported test 20 results, it was apparent tnat the flame did not spread 21 significantly beyond the area of burner flame impingement.

22 Q.

Have tests been conducted on cables using different 23 insulation and jacket materiels?

24 A.

Yes.

In a series of 20 experiments conducted by 25 Underwriters Laboratories (NUREG/CR-0346), cables with three 26 dist[nct insulation and jacket materials were installed in a 27 vertical cable tray and subjected to a burner flame similar 28 to that of IEEE 383-1974.

The three cable types tested were

1.

2 A.

PVC insulation with a nylon jacket 3

B.

EPR insulation with a hypalon jacket d

C.

XLPE insulation with a neoprene jacket i

I 5

The tests results clearly established that Type B and Type 6, C cables demonstrated superior performance and in general I

7 support the adequacy of the cables to meet the requirements 8 of the IEEE 383 standard.

9 Q.

What cable materials will be used at ACNGS?

10 A.

The low voltage and power cables will use EPR insulation 11 with a hypalon jacket while the control cables will use XLPE 12 insulation with a hypalon jacket.

Both of these compounds 13 are thermosetting materials.

The flame resistant XLPE 14 insulation and the Hypalon jacket have an oxygen index (OI) 15 of about 3.

(To be self extinguisti.ng, materials should 16 have an OI of about 25 or higher.

PVC has an OI of 21 to 17 22.)

The Type I EPR used on Allens Creek has an OI of 27 18 and the cable constructicn utilizes Hypalon jacket over the l

19 individual conductors and a Hypalon jacket over all.

1 20 Therefo.e, both cable types have self extinguishing character-21 istics and as demonstrated in the above test, pass the 22 vertical tray flame test of IEEE 383-1974.

These results 23 establish that the cables to be used at ACNGS are not sub-N ject to fast flaming.

25 Q.

In his contention, Mr. Doherty refers to a fire pro-20 tection research test conducted by Underwriters Laboratory U

which was transmitted to the Licensing Board on October 30, 1978.

What is the relevance of this test to ACNGS?

1

_7_

2 A.

In a test conducted by UL (Interim Report UL-USNC83OL-1 3

dated October 6, 1978), the effects of fire on a vertical 4

tray arrangement with cables protected by a mineral wool 5

fire barrier and fixed automatic fire detection and sup-6' pression system was conducted.

The use of mineral wool 7

blankets is not being proposed for use on ACNGS and therefore 8 the test has no relevance to the ACNGS design.

9 Q.

Mr. Barbieri, turning to the second element in Regula-10" tory Guide 1.120, please describe the fire protection systems 11 for the safety related electrical cable at ACNGS.

12!;A.

The fire protection systems for ACNGS are described in 13 A'ppendix 9.5-1A "Conformance to Regulatory Fire Protection 14 Guidelines" of the Preliminary Safety Analysis Report.

A 15 fixed automatic PREACTION sprinkler system will. be installed 16 with manual hose backup in accordance with the guxdelines of 17 Mgulatory Guide 1.120 and BTP 9.5-1 Appendix A, Sections 18 Dc 3 (c) and F.3.

The Preaction Sprinkler System is an 19 automatic sprinkler system containing air under supervisory 20 pressure downstream from the preaction valve.

This system 21 is automatically actuated by a thermal fire detection system 22 ins:alled in the same area as the sprinklers which responds 23 before fusing of the sprinkler fusible link.

Actuation of 24 the fire detection system opens the preaction valve charging 25 the piping with water which will make water available to a 26 sprinkler head which is fused by the heat of the fire.

27 In addition to the thermal fire detection system used M

for actuation cf the automatic PREACTION system, an early I

1

-B-o 2

warning fire detection system is provided in each fire area 3

or fire zone.

This system consists of smoke detectors 4

located in all cable tray areas.

Upon detection of smoke, 5-which usually precedes intense heat and flame, an larm 6

signal is sent to a Local Early Warning Fire Detection 7

Panel.

This panel provides local audible and visual alarms 8'

while simultaneously transmitting an audible and visual h

9" alarm to the Plant Communications Room and the Control Room.

10 In the balance of the plant, the cable tray separation 11 distances of Class lE cabling will, as a minimum, be the 12 same as those prescribed in IEEE 384 Section 5.1.4.

Where i

13 cable tray configurations in a single fire area are such 14 that a single division of safety related cable exceeds 6 15 trays either stacked vertically or located side-by-side, l

16 automatic PREACTION systems and early warning zoned fire i

17 detection systems are provided.

Moreover, manual hose i

18 stations and portable fire extinguishers are provided in all 19 cable areas.

Besides the normal fire protection water 20 supply system, standby water from the essential services 21 water system is provided for hose stations located within 22 reach of any safety-related cable required fo safe shutdown l

23 of the plant. All divisions of safety-related cable trays l

l 24 are installed either in separate fire areas or if installed l

25 in the same fire area, they are separated spatially such 26 that the effects of fire on 2 safety divisions simultaneously 27 are minimized.

A fire area is that portion of a building

(

28 that is separated from other areas by boundary fire barriers d

1,

2 (walls, floors or roofs) with any openings or penetrations 8

protected with seals (fire stops) or closures having a fire 4

resistance rating equal to

.at of the barrier.

Where 5

redundant safety divisions of cable tray in the same fire 6

area are less than 20 feet apart, an automatic PREACTION 7

sprinkler system is provided.

8 In addition to the above, fire breaks are provided in 9-vertical and horizontLi cable trays carrying Class lE cable 10 to limit the spread of a fire.

The barriers are located at 11 15 foot intervals on all vertical cable tray runs and at 20 12 foot int,rvals on all horizontal cable tray rune.

A fire 13 barrier prevents fire propagation along the length of cables 14 or prevents spreading of fire to nearby combustibles within 15 a given fire area or fire zone.

Cable and cable tray 16 penetrations of fire barriers, both vertical and horizontal, 17 are sealed to give protection equivalent to that of the 18 penetrated barrier.

For example, a cable tray passing 19 through a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier is sealed at the barrier 20 with a fire stop assembly which has been tested as providing 21 a resistance to burnthrough for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

22 Q.

Mr. Montablano, will you discuss how the ACNGS design 23 will meet the third element of Regulatory Guide 1.120?

24 A.

The third element of Regulatory Guide 1.120 relates 25 primarily to separation of redundant safety-related cable.

26 Several experiments in the NRC's test program have 27 provided data for evaluation of the tray separation distance 28 criteria of IEEE 384-1974 as a method of minimizing the

1 -

2 effects of an electrically initiated fire in one cable tray 3

on adjacent cable trays.

These experiments were conducted 4

on cable tray installations that met the requirements of 5

IEEE Standard 384-1974 for cable and cable tray construction, 6

cable installation, and hazard limits.

The cable tray 7

separation distances used in these experiments were less 8

than the IEEE Standard 384-1974 design criteria for minimum 9

separation distances between cable trays in the cable vault.

10 Seven separate full-scale experiments were conducted, and 11 the experiments are described in detail in Sandia Laboratories 12 reports.

In all of these experiments, electrical ignition 13 of a cable fire was accomplished in an " ignition" tray, and 14 data was gatherec

.,n the effect of such a fire on cable in 15 trays below, above, and to the side of the ignition trays.

16 As stated on page 32 of the Summary and Conclusions of 17

" Cable Tray Fire Tests."

Sand 77-ll25C, July 1977:

18 At no time did the cables in trays displaced from the ignition tray begin to burn.

All circuits in 19 these trays remained functional and elongation measurements taken of the insulation closest to the 20 fire showed no major (10%) change.

21 These expermients provide assurance that cable vault cable 22 tray installations designed in accordance with IEEE Standard 23 384-1974 will not suffer fire effe"ts from electrically 24 initiated fires in excess of that allowed by criterion 3.

25 An additional related experiment was conducted at 26 Sandia Laboratories in July 1977 (Sand 77-1424) and provided 27 further data useful in anclyzing cable tray installations 28 that use an exposure fire as a design basis.

This test used l

I 1 -

2 the stacked cable trays and cable tray separation criteria 3

of IEEE 383-1974, with an exposure fire initiating source 4

(two burners) rather than electrical heating source.

5 An important re<: ult of this fire test is that the 6

lowest 3 cable trays separated horizontally from the exposed 7

cable tray by 8 inches were not affected by the fire and the 8; cable in those trays remained functional.

In addition, the 9 l cable tray simulating the redundant division, and located 3 10 !

feet horizontally from the top of the 14 trays simulating 11 the other division, was not damaged and the cable in that 12 tray remained functional.

This result provides convincing 13 evidence that the horizontal separation distance of IEEE 14 384-1974 is adequate for the cable vault even if an exposure 15 fire is used as a design basis and therefore the potential 16 of common mode failure has been averted.

17 Q.

Please describe the cable tray separation and fire 18 protection system design criteria used at ACNGS.

19 A.

Criteria for the design of seismic category I cable 20 tray installations used at ACNGS are given in IEEE Standard 21 384-1974, "IEEE Trial-Use Standard Criteria for Separation 22 of Class IE Equipment and Circuits" and are endorsed by the 28 NRC in Regulatory Guide 1.75, " Physical Independence of 24 Electric Systems."

Section 5.1.3 of IEEE Standard 384 25 states criteria for the separation of the cable trays in the 26 cable vault.

That Section provides in part that:

27 The minimum separation distance between redundant Cless lE cable trays shall be.

. 1 foot between 28 trays separated horizontally and 3 feet between trays separated vertically.

1.

2 Section 5.1.1.3 of IEEE Standard 384-1974 also stipulates 3

specific requirements as to cable and cable tray construction, 4

cable installation, and hazard limits justifying the 1 foot 5

horizontal and 3 foot vertical separation distances as 6

conservative criteria for the design of the cable tray 7

installations in the cable vault.

The ACNGS cable vault 8

will meet or exceed this separation criteria.

9 The cable vault at ACNGS is located at Elevation 10' 164', 0" in the Control Building.

The ACNGS cable vault 11 contains class lE cable and seismic category I cable trays 12 for all four safety divisions.

Within this area, cables 13 associated with Safety Divisions 1 & 4 are separated from 14 cables associated with redundant Safety Divisions 2 & 3 by a 15 three hour fire barrier wall consisting of reinforced 16 concrete.

Since this design of the cable tray installation 17 is significantly more conservative than that required by 18 IEEE 384, the requirements of Criterion 3 are thereby 19 satisfied when considering the physical anc apatf.el separation 20 between redundant cable divisiens.

21 Q.

What are your conclusions concerning this contention?

22 A.

The present fire protection criteria for electric cable 23 wiring to be used at ACNGS is adequate, and NRC requirements 24 concerning electrical cable wiring design have been incorporated 25 into the design at ACNGS.

The fire protection plans for 26 ACNGS provide additional assurance that the design of the 27 electrical cable wiring systems will not create a safety 28 hazard.

1 Exhibit FPB-1 2

EDUCATION AND PF0FESSIONAL QUAI.IFICATIONS 3

Fred P.

Barbieri 4

SUMMARY

OF 3XPERIENCE 5

Professional Affiliations -

Member - Society of Fire b'

Protection Engineers 7

Member - National Fire Pro-O tection Association 0

Education -

Manhattan College, Bachelor of 10 Engineering (Chemical)-1973 11 EBASCO EXPERIENCE (Since 1973) 12 Ebasco Services Incorporated, Lyndhurst Office:

Senior

10. Mechanical Nuclear Engineer assigned to the Allens Creek 14 Nuclear Project.

Responsible for the preparation an:1 maintenance of the Plant Fire Hazards Analysis Report to I

be submitted as part of the FSAR to the NRC.

Responsible for generating Fire Protection Design Criteria for ACN:!S Unit 18 1 and preparation of the Fire Protection System Description.

No.

I0 Respont,1ble for all fire protection baseline engineering 20 (flow diagrams, specifications, calculations, piping layouts).

I Responsible for review of all other baseline engineering 22 associated with fire protection measures to insure consistency 23 with fire protection criteria.

Also responsible for the 24 design and layout of the Early W$ ring Fire Detection Systems.

PRIOR EXPERIENCE 26 Burns and Roe, Inc., Paramus, New Jersey, Building 27 Services Department for three (3) years:

Cognizant Engineer 28 on Forked River Nuclear Station, Lacey Township, New Jersey

1,

2 for Jersey Central Power & Light Company.

Responsible for the 3 design of the fire protection systems including yard system 4

and internal fire suppression systems.

This included pre-

5. paration of system calculations, system flow diagrams, system 6l design descriptions, valve lists, piping line lists, equipment 7 lists, equipment and construction specifications and bid 8' evaluations of said specifications.

Responsible for coordinating 9 project effort to produce plant fire hazards analysis, and 10 preparation of final fire hazards analysis report to be sub-11 mitted to NRC.

Responsible for design and layout of early 12 warning fire detection systems.

Responsible for layout

• ' 3 (General Arrangement Drawing) of Fire Protection Pumphouse as 14 well as coordinating design effort to produce fire protection 15 system piping layouts.

Responsible for submitting all fire 16 protection related baseline documents, specifications and 17 physical layouts to NELPIA for approvsl.

18 Also responsible for the baseline engineering design of 19 heating and ventilating systems for the Fire Protection Pump 20 House, Circulating Water Pump House and Turbine Buildings.

21 This included system calculations, system flow diagrams and 22 system design descriptions.

23 Cognizant Engineer on Three Mile 131and Nuclear Station, N

Unit II, RoyMton Township, Pennsyl rnia for Jersey Central 25 Power & Light Company.

Responsible for the design of the 26 fire protection and detection systems.

This included pre-27 paration of system flow diagrams, system design descriptions, 28 valve instrument list and specifications.

Responsible for

I 1 2 coordinating contractor construction effort for installation 3 of fire protection and detection systems, review and approval 4

of vendor drawings and calculations.

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 l

l 21 l

N 23 24 25 26 27 28 l

l

1 EXHIBIT JFM-1 EDUCATION AND PROFESSIONAL QUALIFICATIONS 2'

8li JOSEPH F. MONTALBANO 4I EXPERIENCE

SUMMARY

5 Registered Professional Engineer with nine years of 6

in electrical design engineering of fossil and 7l experience nuclear-fueled electric generating stations.

Responsibilities 8

included developing the electricsl system and basic design 9

criteria for each project, application of computer analyses 10 for an optimum electrical auxiliary system, development of 11 electrical main and auxiliary one-line diagrams, input 12 criteria for physical design drawings for the station, 13 economic analysis of equipment options, preparation of 14 equipment specifications, purchase requisitions, bid evaluations 15 and recommendations for purchase, surveillance of equipment 16 orders for compliance with specification and required-at-site 17 dates, and engineering support to field forces.

18 Ad:ainistrative responsibilities have included project 19 implementation of QA Programs, development of CPM logic and 20 manpower forecasts and resources and exercising job control 21 by monitoring schedule and workday and Earned Value reports.

22 Responsibic for distribution system des;gn for 5 kV 23 and 13 kV underground networks including conductor selection, 24 cable and transfcrmer selection and location and impedance 25 calculations.

26 EMPLOYMENT HISTORY 27 Ebasco Se2 vices Incorporated, New York, New York; 28 1972 - Present

I I

1- '

Supervising Engineer, 1981-Present 2l Principal Engineer, 1980-1981 3

Senior Engineer, 1977-1980 4,

5l, Engineer, 1975-1977 6l Associate Engineer, 1974-1975 l

Assistant Engineer, 1972-1974 7

8 i EDUCATION 9

Polytechnic Institute of Brooklyn-BSEE-1972 I

10' Polytechnic Institute of New York-MSEE-1977 11 New York Institute of Technology-MBA-1981 12 13 REGISTRATIONS 14 Professional Engineer in the States of New York 15 and New Jersey.

16 PROFESSIONAL AFFILIATIONS 17 IEEE-Member 18 19 20 21 l

22 23 24 25 26 27 28