ML20058F704
| ML20058F704 | |
| Person / Time | |
|---|---|
| Issue date: | 11/24/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9312080235 | |
| Download: ML20058F704 (106) | |
Text
-
.W M4%%%%%%nWnn%%WfM44%%%%%%884UNANNNUNU N NNNkNfM $
s(i i
l 3
- At:5MinAL TO:
Y' Occument Control Oest, 016 Phillies g
\\
A 6"
s 10VANCEO COPY TO:
The Public Occument Docm G
//!/h 3
3
- ATE:
c
=
2 3
- CM:
SECY Correspondence & Recorcs Brancn g
2 2
5 Attact:ec are copies of a Cormssten meeting transcript and relatec meeting
&5 O
cetument(s).
They are ceing forwarced for entry on tne Daily Accession 1.ist and 3
placement in tne Public Document Pecm.
No other cistribution is recuested or 9
.f 3
C recuirec.
L s-E R
"eeting
Title:
/be4 Ac1
/Im%u-L, 5;v v'/4 tme o - h-+-
d W
h p
c 5
C 3,.
- eetinc Cate:
// A @ /Ci.3 Open I Closec G
O g
P c
E 3
3
', 8
' tem Cescriptien*-
Ccoies 3
Advanced DCS s'
to POR Cg E
i::'
W.
E 5
h
- 1. TRANSCRIPT 1
1 1
I:
fi l Yc<>e e, l 4 ]
j a s
}l-d o'
B h
7 aba C
3:-
C a-
~
'Nb 4
c C
l l
W g
E Ol 00 's
~
9312080235 931124
[
o PDR REVGP ERGNUMRC g$
lj g
\\
m two of each SECY pacer.
?
C1R Branen files the or1ginal transcript, with attacnments, withf.;; SECY
)
j
- DDR is advanced one copy of eacn document,
?
f.
{ i, g f
=a
- acers.
sin 1
" iFM%%%%%1%%%%%%%%%%%%%%%%%%%gggggrQgygggggyj
q UN-f TED STATES OF AMERICA NUCLEAR REGUL-ATORY'COMMIS SION j
-l:
l
$k(16*
BRIEFING BY NUMARC ON THERMO-LAG i
LOCatiOIl ROCKVILLE, MARYLAND
)
bObO*
NOVEMBER 24, 1993 q
PageS 86 PAGES 5
ll i
NEAL R. GROSS AND C0., INC.
j COURT REPORTERS AND TRANSCRIBERS l
1323 Rhode Island Avenue, Northwest Washington, D.C.
20005 (202) 234-4433 B
1
1 l
DISCLAIMER i
This is an unofficial transcript of a meeting of the United States Nuclear Regulatory commission held on
+
November 24, 1993, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaceutacies.
i The transcript is intended solely for general i
informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding 'as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
G e
NEAL R. GROS $
coutt Rftotitt$ AMO TRANSCRftfit$
1313 kHopt ISLAMO AYtMut. M.W.
(202) 234 4433 WASHINGTON. 01 2000$
' (202) 232-6600
1 UNITED STATES OF ANERICA NUCLEAR REGULATORY COMMISSION BRIEFING BY NUMARC ON THERMO-LAG PUBLIC MEETING i
Nuclear Regulatory Commission One White Flint North Rockville, Maryland Wednesday, November 24, 1993 The Commission met in open
- session, pursuant to
- notice, at 9:00 a.m.,
Ivan
- Selin, Chairman, presiding.
COMMISSIONERS PRESENT:
IVAN SELIN, Chairman of the Commission KENNETH C.
ROGERS, Commissioner I
E. GAIL de PLANQUE, Commissioner l
1 l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234-4433 WASHINGTON. O C. 20005 (202) 234-4433 I
I 2
' STAFF AND PRESENTERS SEATED AT'THE COMMISSION TABLE:
SAMUEL J.
CHILK, Secretary KAREN CYR, Office of the General Counsel JOE COLVIN, President and CEO, NUMARC BILL RASIN, Vice President and Director, Technical Division, NUMARC F
f I
i t
t r
NEAL R. CROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W (202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
3 j
1 P-R-O-C-E-E-D-I-N-G-S-2 9:00 a.m.
3 CHAIRMAN SELIN:
Good morning, ladies and
-j 4
gentlemen.
5 This morning the Commission will be q
6 briefed by representatives of NUMARC on the Thermo-Lag 7
fire barrier test program.
The meeting this morning
~
8 is a follow-on to the briefing that the commission 9
received from the staff on October 29th when they-i i
10 discussed the status of actions to resolve the various 11 Thermo-Lag issues.
12 I cannot emphasize enough the importance 13 of fire protection as it relates to operating reactor-14 safety, although of course the barriers are only one l
15 element of fire protection.
'}
16 The Browns Ferry fire in 1975 sensitized 17 the Commission properly to the importance of fire 18 protection.
That fire demonstrated design 19 deficiencies in instances where electrical cables have l
20 insufficient separation.
This is really a very l
21 important issue.
In nuclear power plants we have the 22 principle of redundant independent system e
23 s such that if something affects one of the emergency 24 systems the other emergency system should continue to 25 operate. however, it turned out that the cabling from I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234-4433 WASHINGTON. D C. 2000S (202) 2344433
t 4
1 these systems in many cases was commingled in such a 2-way that a fire would knock out both systems or all l
3 the trains simultaneously.
4 As a result of the Browns Ferry fire, the 5
NRC regulatory work culminated in promulgation of 6
Appendix R in the early 1980s.. This appendix.made 7
clear that the preferred solution was one in which 8
there would be physical separation between the cables -
9 of the supposedly independent systems such that a fire 10 or another event would not be expected to knock out j
l 11 both systems.
In the absence of separation, we would
{
12 accept barriers that would withstand a fire for one 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> if that was also coupled with fire suppression 14 techniques such as automatic systems to put out the 15 fire.
In the absence of separation and in the absence l
16 of fire separation, we required a three h'our barrier 17 such that a fire would not simultaneously attack both 18 sets of cables and would give the plant personnel 19 enough time to detect and fight the fire.
20 The Thermo-Lag fire barriers, which we 21 discuss here today, are an important element in the 22 fire protection system.
These barriers are widely j
23 used in operating reactors.
For instance, 23 of the I
i 24 currently operating reactors utilize a one hour fire 25 protection barrier.
Fifteen reactors possess only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I
1323 RHODE ISLAND AVENUE, N.W.
(202) 2344433 WASHINGTON. D C. 2000S (202) 2344433
r S
1 three hour protection barriers and 40 more reactors i
i 2
have a combination of both one hour and three hour 3
fire protection barriers.
So, _ this is a problem or an 4
issue that is very broadly affecting the industry.
5 The NUMARC group has been pursing a 6
testing program for Thermo-Lag fire barrier issues on l
7 behalf of the utilities for some time.
These tests 8
involve experiments on the effectiveness of the i
9 insulation under a variety of conditions.
The 10 Commission's previous meeting exposed certain l
11 differences of opinion between the positions of the 12 NRC staff and NUMARC.
These are fairly technical t
13 differences but very important, including the 14 placement of heat sensors which will be referred today 15 cryptically as thermocouples, but they're just devices l
t 16 to measure temperature, and also test criteria for i
17 associated conditions.
18 So, we're particularly pleased to have 19 NUMARC provide information on the nature of the test t
20 program.
- However, I wish to stress that the 21 Commission's concerns go beyond the test program and 22 we're concerned whether there is any test program that 23 could lead to timely resolution of the fire barrier 24 issue on a generic basis or whether we will have to 25 resort to plant by plant solutions to this problem.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON. D C 20005 (202) 2344433
6 l
1 We're interested in exploring the basis for ~ your i
2 technical position today.
and especially we're i
3 interested in your plans for future actions intended l
4 to resolve the urgent matter.
5 We are particularly concerned about the 6
lack of an obvious clear path to satisfactory 7
resolution of the fire barrier issues.
We need to be 8
looking for an approach which would achieve 9
effectiveness coruparable to that which would' be 10 achieved through separation of the cables.
Now, we 11 know that this is hard to do in existing plants, but 12 there are other possibilities such as spray systems, 13 fire retardant materials or more complicated fire l
14 barriers.
In fact, the NRC staff is now initiating i
15 efforts to prepare letters to obtain each nuclear 16 utility's plans either to restore the required fire r
17 resistant capabilities of barriers or to identify t
18 alternative actions.
19 In fact, this morning, Mr. Colvin, if you 20 care to comment on any of these broader issues, the 21 Commission is prepared to hear your comments.
22 I
understand that copies of your 23 viewgraphs.are available at the entrance to the hall 24 to the public.
l 25 Commissioner Rogers?
f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON, D C. 20005 (202) 2344433 1
.7 j
1 Commissioner de Planque?
l 2
Mr. Colvin, the floor is yours.
3 MR.'
COLVIN:
Thank you, Mr.
Chairman.
4 Good morning.
5 We are pleased to be here with you today.
6 and try to brief you on the industry's fire protection j
7 program and in particular on the aspects of the.
6 Thermo-Lag testing program and the various parameters 9
as you articulated.
We also appreciate the 10 Commission's rapid recponse to our request to meet 11 with us and do so on the eve of Thanksgiving at such 12 an early hour.
So, thank you very much.
13 CHAIRMAN SELIN:
Let's hope you don't 14 offer us a turkey, Mr. Colvin.
15 MR. COLVIN:
Yes,-sir.
We did take that 16 into consideration in preparing the briefing.
17 (Slide)
Can I have the first slide, 18 please?
19 In opening the discussion, I'd like to 20 just mention.-- to start out on a little broader scale i
21 and talk about the industry fire protection program j
22 and then move directly into Thermo-Lag.
But I wanted 23 to make sure the Commission recognized that the l
l 24 industry is looking at the fire protection issues in i
25 a much broader context, to look at not only the j
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBF 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C. 20005 (202) 234 4433
q 8
l 1
testing and the qualification of Thermo-Lag barriers, 2
but also the other fire barrier materials and the r
3 elements of those because we and the staff have some 4
potentially similar concerns vis-a-vis other non-r 5
Thermo-Lag materials, and also to try to respond to 6
the staff's proposed changes or potential proposed 7
changes on Appendix R and moving that into the 8
performance-based area.
9 So, in response to that, one of the things l
10 we decided to do is establish an executive level 11 working group, much in the same context that-we have-12 in the maintenance area and license' renewal and so i
13 forth to try to bring the policy level discussions and 14 involve the senior executive leadership of the i
15 industry to do so.
We're taking those steps.
As you f
l 16 indicated, the staff on Friday -- we briefed the staff l
17 and had discussions at a senior management level of l
18 the staff and agreed with Jim Taylor, who was the EDO I
19 at that time, to establish a high level policy working 20 group and have senior management meetings on a regular i
21 priority.
We would use that process of this working-
.[
22 group along with the NUMARC staff to have those senior 23 management meetings.
1 24.
(Slide)
Second slide, please.
1
'25 Moving into the Thermo-Lag test program,
'l I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON D.C. 20305 (202) 2344433
9 1 -.
I think it's important to realize that in looking at 2
Thermo-Lag we're really not just going off to do some 3
experiments and tests in Thermo-Lag.
Really what we 4
have to do, what we've come to believe we have to do 5
is, in fact, complete reestablish the technical and 6
licensing basis necessary to. qualify these fire 7
barrier materials. That causes the program to be very L
f 8
broad in scope and also a very complex issue and 9
that's what we'd like to, through the presentation 10 today, provide a little bit of insights on that, i
11 (Slide)
Next slide, please.
12 Some of the conclusions that we reached, 13 and as a result of why we felt we needed to take this 14 broad program, really are indicated on this slide.
15 First, all the Thermo-Lag tests, except for those l
l 16 recently conducted by the Texas Utilities Company, l
i 17 really have been concluded to be indeterminate because 18 neither the staff nor the industry has the information 19 necessary to qualify those fire barriers in either a 20 one hour or three hour rating as required by Appendix 21 R of 10 CFR 50.
22 Secondly, the existing fire barriers were 23 installed to differing and changing installation 24 requirements.
So, when we try to look at those and 25 apply the test results from the past, we have an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
@ 2) 234 4433 WASHINGTON, D C. 20005 (202) 234 4433 I
10
.l l
1 element of concern for both how it was installed as 2
much as whether that application can be then taken and 3
applied in other specific applications.
i 4
Third is that the tests have shown that we l
5 have really two elements.
That is the thermal-
~
6 performance issues related to the fire barrier i
7 material and secondly the structural issues - that 8
relate to how that fire barrier material is applied 9
and whether it can sustain itself throughout. the 10 duration of these tests or even, more importantly, 11 throughout a fire if we had a real fire at the plant.
12 There are other structural issues which we
[
13 will discuss.
There are other issues relating to 14 safety and the f act that the Thermo-Lag and the-weight 15 applications also give us some problems with respect l
l 16 to seismic analysis and other safety requirements of 17 the Commission, we will address-that very briefly i
18 throughout the presentation.
l 19 The other thing that has come up is that I
20 there is an ampacity question on what is the derating 21 that we would have to take into effect on the ampacity l
r 22 of the cables, the current carrying capability of 23 those cables, by the addition of either more fire 24 barrier material and having that be acceptable and f
25 tested properly throughout ' a fire.
So, the second NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENtK N W.
(202) 2344433 WASHINGTort D C. 20005 s J2) 2344433 i
11 1
point of that is how do you apply those-derating and 2
those ampacity derating values in a
specific-3 application.
So, that's part of the program.
4 The fifth issue is really that the Thermo-5 Lag has been questioned to whether it is combustible 6
or not.
In fact, we did a testing program --
Bill 7
will talk about that very briefly today.
We'd be 8
happy to respond to questions but through the 9
Underwriter's Laboratory to test the combustibility of 10 the Thermo-Lag material itself and then try to take 11 steps on how one would take that into account 12 throughout to meet the Appendix R requirements.
13
. Lastly, the generic test program'.that we 14 are trying to design really - has to encompass as 15 broadly as possible the specific applications that we-16 have within the industry to reasonably envelope those 17 and take full advantage of the generic elements.
18 (Slide) So, today, what we'd like to do --
19 next slide, please -- is kind of outline for you the 20 Thermo-Lag test program, how we would see applying the 21 results of that program in specific licensee 22 applications.
I'd like to talk to you briefly about 23 the test results that we've seen through phase.1.
24 There have been a lot of successes in this program.
25 There's still a lot of work to do in this, but we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433
~f f
-12 1
made some progress in the testing and it's given~us 2
some real insights into - this material and its I
3 applications.
f 4
We would like to talk to you about a 5
couple of the test acceptance criteria issues and in l
i 6
that regard they do get very technical and our intent
?
?
7 is not to ask the Commission to come to some decision 8
on these.
We recognize that you have asked the 9
Advisory Committee on Reactor' Safeguards to get t
i 10 involved and we are supporting that with the staff to i
l r
11 kind of bring these issues to resolution.
But we'd i
5 12 like to try to give you some insights as to why we.
[
t 13 have been stubborn in this area and why those issues 14 are so important to the success of this program.
15
- Lastly, I'd like to provide a
few i
16 conclusions.
17 So, with your permission, I'd like to turn 18 the discussion over to Mr. Rasin and I'll come back i
19 for the conclusions.
20 MR. RASIN:
Thank you, Joe.
21 (Slide)
May I have slide number 5,
22 please?
23 Fire protection, as you've noticed, Mr.
i 24 Chairman, we're trying to keep in perspective the f act i
25 that the fire barriers are one element of fire NEAL R. GROSS COURT FIEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
5 (202) 2344433 WASH!NGTON. D C 20005 (202) 2344433
13 p
1 protection in a regulation that, in fact, is a defense i
2 in depth
- approach, first concentrating on the 3
prevention of fires and then going on with detection 4
and prompt suppression and then finally followed up 5
with the protection of equipment if the fires are not 6
extinguished and that's where we get.into the fire 7
barrier question.
8 The regulation again, as you pointed out, 9
requires one or three hour fire barriers, depending on 10 whether they are combined with fire suppression 11 systems.
However, we have to keep in mind also that l
12 these fire barriers are unralated to any actual plant I
13 fire loadings and, in fact, are based on a rating from 14 a combination of industry standards and NRC staff 15 acceptance criteria.
16 Typically for these fire areas in the i
17 plant we have a low fuel load, typically less than 20 6
18 minutes in most applications, which is far below the 19 typical testing criteria.
I will add, however, there 4
20 are a few areas in the plant that, in fact, approach 21 that testing criteria and there are some areas that do.
l 22 require special attention with these barriers.
)
23 There has been no actual fire in a plant i
24 that has ever come close to challenging these barriers l
25 or the criteria by which they are tested.
The NRC NEAL R. GROSS COURT REPORTERS AND TAANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
QD2) 2344433 WASHINGTON. D C 20005 (202) 234-4433
I 14 j
i i
staff has recognized the actual fire hazards in many i
2 cases on a plant-specific basis by granting exemptions 3
by specifically considering the load.
)
i 4
CHAIRMAN SELIN:
Before you go on, this f
f 5
last point, I thi is really important.
We do not 6
require one and three hour separation.
We say if you f
i 7
are to use a generic solution based on the material, 8
that's what is required.
I think we all understand 9
those are surrogates for plant by plant safety 10 analyses, so that if all else fails we are quite 1
11 content to look at the plants on a specific basis i
12 based on the loads in that plant and any threats in i
13 that plant.
r 14 One of the main questions facing-us is
[
15 whether there is, in fact, a generic solution or r
^
16 whether there will be, in most
- cases, little 17 alternative to a plant by plant --
18 MR.
RASIN:
- Yes, sir.
That is an t
19 important element, Mr. Chairman.
While we realize t
20 that, one of the reasons that we have been pursing the 5
21 generic program is simply looking at the most 22 expeditious path to resolution.
The resources i
23 required by the NRC staff to do this plant by plant i
24 review, barrier by barrier review for thousands of 25 barriers, in fact, I believe will lead to a very long-3
'i f
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS ura RsODE ISt.AND AVENUE. N W.
l (202) 2344433 WASHINGTON. D C. P9005 (202) 2344433 f
15 1
term solution to the problem which none of us want.
2 So, that's why we continue to believe that a generic 1
3 approach can_get us most of the way there if properly.
i 4
applied.
5 (Slide)
May I have slide number 6,
I 6
please?
I 7
With respect to the - Thermo-Lag material 8
itself, Thermo-Lag is the predominant cable raceway 9
fire barrier raterial used in the industry for i
10 compliance with Appendix R.
We have a very large i
11 scope of installation within the industry. I've shown 12 a breakdown here between conduits and cable trays in l
13 one and three hour applications in terms of linear 14 feet across the industry just to show the very, very 15 large usage of this material.
16 As Joe noted, all previous tests have been 17 declared indeterminate by the NRC staff, meaning that 18 the details of the testing are not sufficient for us 19 all to conclude that those tests serve-as an 20 acceptable regulatory basis for Appendix R compliance.
{
21 That is why a successful test program has to aim for 22 establishing a basis for the requalification for 23 compliance with this material.
If this program were 1
24 simply to show in various applications that Thermo-Lag 25 will work to serve its function, it would be a rather NEAL R. GROSS COURT REPORTERS AND TRANSCHIBERS i
1323 RHODE ISLAND AVENUE. h W.
j go m.m
-S,~a10~.oc. -
em m-33
)
a
16 l
1 easy test program.
But, in-fatt, we are trying to 2
16ck' for the most expeditious way to return a complete 3
regulatory confidence in the application of this 4
material within the plants.
i 5
(Slide)
Slice number 7.
6 With respect to the fire barrier test 7
program, our purpose is to assess the Thern.o-Lag 8
performance for representative plant cable. raceway I
i 9
installations and we have identified a combination of 10 baseline applications, meaning applications exactly as j
11 installed in the plants, a set of proposed upgrades j
12 using T;.ermo-Lag itself, and a set of upgrades that 13 uses the Thermo-Lag in combination with other fire 14 barrier materials.
I 15 The scope of the program to cate is 17 i
16 test configurations which we have undertaken in two
.I l
17 phases and it may be that further tests may need to be i
i 18 undertaken based on the success of the tests in the t
19 first two phases and an opportunity through what we 20 learn here to show that a few more tests may, in fact, I
I 21 expand the boundaries of what can be generically i
22 tested and applied.
1 23 Let me explain a little bit Phy We took 24 the two phased testing approach.
Early on in this
'i e
25 definition of a test program the supplier of Thermo-t i
NEAL R. GROSS
' COURT REPORTERS AND TRANSCR!BERS 1323 FtHODE ISLAND AVENUE N W.
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433.
}
l 17 1
Lag came forward to several utilities with some 2
proposed fixes for Thermo-Lag, some upgrades, that he
{
3 thought would be responsive to this problem.
We felt I
4 that individual testing of those configurations would 5
not lead to the industry-wide confidence and 6
credibility necessary and yet we saw two advantages to
[
+
7 those tests.
One, quite honestly, the vendor was l
8 willing to completely foot the bill for-them, which we 9
thought was much to our advantage.
- Secondly, it i
10 provided an opportunity for some testing and some data
{
11 on three hour fire barriers which none of the previous i
12 testing has spoken to.
{;
13 So, for that reason we agreed to undertake I
14 a phase 1 testing that centered on vendor recommended l
15 upgrades to the barriers.
16 The phase 2 tests is more appropriately l
I 17 the industry program where, in fact, that phase will i
18 test a combination of baseline barriers or currently 19 installed barriers and also some industry proposed 20 upgrades to those barriers.
i 21 (Slide)
Next slide, please.
j I
i 22 There are many attributes of the installed.
f i
l 23 configurations that affect Thermo-Lag performance. As t
1 s
l 24 Joe pointed out, there are really two issues with i
~
e i
25 Thermo-Lag. One is simply the thermal performance, is l
i i
NEAL R. GROSS COURT AEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
l (202) 234-4433 V.ASHINSTON, D.C 20005 (202) 234 4433 l.
- )
l 18 i
i there enough Thermo-Lag,'enough thickness of it, to 1
2 adequately perform its function.
But two, is it j
3 installed in such a way that it maintains its physical 4
integrity throughout the fire test so that, in fact, j
.t 5
the Thermo-Lag is held in place in the proper l
6 perspective to perform that function.
The original I
7 Texas test that indicated some of these problems did 8
have problems like joints opening up where the Thermo-9 Lag was joined and that is a further complication of
(
10 the problem.
I 11 Some of these attributes such as material 12 thickness speak directly to the thermal performance.
13 Many of the others, such as pre-grouting of joints,.
14 direction of structural ribs, internal panel supports, 15 et cetera, really speak to the structural question.of-16 the fire barrier performance.
17 CHAIRMAN SELIN:
Before you get off this I
18 page, Mr. Rasin, I'd like your views on two related.
19-questions.
The first is are you trying to build a l
l 20 model that talks about the effectiveness of Thermo-Lag f*
k 21 as a function of these parameters or are you-trying to f
t 22 find some dominant solution that says that over the 23 whole range of pre-grouting of joints and a couple of 24 these other points that one could be confident in the 25 Thermo-Lag?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
[
(202) 2344433 WASHINGTON. D C, 20005 (202) 2344433
19 3
1 MR. RASIN:
I think I'll explain that a 2
.little better when I get into how one would apply the
[
3 test results.
But, in fact, to reference.it for 4
regulatory qualification, we think you have'to deal j
5 with what you have and match that up to an appropriate 6-test.
We have not found a set of tests-we could do 7
that we thought answered all those questions on a 8
generic basis without plant-specific justification of 9
that installation.
10 CHAIRMAN SELIN:
That gets to my second t
11 point.
Some of these would be obvious, like what 12 raceway dimensions will be and the unsupported span
[
13 distance, but questions like pre-grouting of joints or i
14 particularly the grouting that is hidden, are these 15 determinable in a particular installation in a non-16 destructive fashion?
I 17 MR. RASIN:
They're determinable by the l
18 instruction or the installation instructions that a f
19 utility used which, as Joe pointed out, did-change 5
20 over time.
But each utility knew what instructions.
i 21 they installed the material to.
So, they --
f a
22 CHAIRMAN SELIN:
But you couldn't l
23 l physically go out and inspect the' talk about i
24 grouting.
That's the one I'm most concerned about.
i 25 Do you physically go out and inspect an installation l
r i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS f
1323 RHODE ISLAND AVENUE. N W.
{
(202) 234-4433 WASHINGTON, D C 20005
. (202) 234-4433
h 20 I
to say the spaces have been filled in under the 2
su'rface or not?-
You would have to go back to some 3
logs to see what the installers said they did?
4 MR. RASIN:
You would have to go back to 5
your original installation instructions.
Inspecting 6
- them, once they are installed, becomes a
very
[
7 difficult task.
In fact, would likely require in 8
damaging the barrier to the point you'd have to 9
replace it anyway.
r 10 CHAIRMAN SELIN:
Okay.
11 MR. COLVIN:
Just one other comment on 12 that, Mr. Chairman.
I think that the point that --
13 Bill is going to address a number of the questions you 14 might have on this, but I might say that we know a lot
[
t 15 about the variability of these specific issues as they 16 are independent variables in the equation.
The real 17 thing that we don't know is how they all work together l
18 and that's why we need to do these integrated tests.
i I
19 When you go into and you'll see the test 20 application as we go in there, you can see the various l
I 21 combinations of these elements that we've put together a
22 to try to get some range of application and data on
{
s 23 this.
So, I think you'll see how that comes together-24 in a few minutes.
25 (Slide)
May I have slide 9, please?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(P02) 234-4433 WASHINGTON, O C. 20005 (202) 234 4433 5
-l
,-4I
31 I
1 At the start of this program we conducted 2
an extensive survey of the industry where we actually 3
gathered the design information on the Thermo-Lag 4
configurations in the industry and analyzed that to a 5
significant degree to determine what variation in the-6 parameters that we had and also to define a test 7
program that we felt would, in fact, be referenceable 8
by the largest number of configurations.
9 We analyzed these survey results for the 10 broad parameters that we have listed on the previous 11 page and the real challenge in this program is to l
12 properly bound these factors with a reasonable number 13 of tests, but not to get so overly conservative that, 1
e 14 in fact, the test fails, in which case you haven't I
15 bound anything with that test.
16 (Slide)
Next page, please.
17 The next slide shows a cartoon of a 18 typical test configuration and I wanted to explain 19 this to you to show that while we have what-would 20 appear to be a relatively small number of tests, in 21 fact each test does look at a very large number of 22 these parameters. The test configuration that's shown 23 here is used for either 36 or 24 inch cable trays and 24 in this configuration we are, in fact, testing a lot 25 of things.
For instance, just from a geometrical NEAL R. GROSS COURT REPORTERS AND TRANSCRrBERS 1323 RHODE ISLAND AVENUE. N W.
j (202) 2344433 WASHINGTON, D C 20305 (202) 2344433
32 1
point of view, we have vertical runs of the cable 2
trays, we have U bends of the cable trans and we have 3
horizontal runs of the cable trays.
t i
4 Moreover the fabrication techniques used 5
on the right-hand U bend and vertical rise are i
6 different than the fabrication techniques used on the 7
left-hand U bend and vertical rise.
With respect to 8
the upgrade, you can see that we have tested the use
{
9 of stainless steel tie wire for the structural l
10 integrity on the right-hand portion.
We've used
[
11 stainless steel banding on the left-hand portion.
In 12 all cases, we have used post-buttered rather than pre-13 buttered joints because, in fact, that has shown to be 14 the most problematic structural problem from the
{
i 15 previous testing.
16 So, from this one article --
i 17 CHAIRMAN SELIN:
Translate that to 18 English.
19 MR. RASIN:
Yes.
Buttering is actually 20 preparing the joints of the Thermo-Lag by application i
21 of what's called a trowel-grMe material.
It can be 22 done before joining those joints together to form a 23 nice smooth seal and then press them together and hold 1
24 them together or, in fact, the material can be put t
25 together and then the joints ladled with this trowel-j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
f 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON, O C. 20005
(?OP) 2344433 L
ia
~23 l
l 6
1 grade material after they have been put in place and 2
j o'ined.
The latter case is what we refer to as post--
.i 3
buttering.
I 4
CHAIRMAN SELIN: That's a greater problem?
5 MR. RASIN: ~ Yes, sir, s
6 CHAIRMAN SELIN:
And.therefore if that is 7
found to be satisfactory, then the pre-buttered joints l
8 would be included?
-s 9
MR. RASIN:
Yes, sir.
[
t 10 So, in conclusion, what I'd like you to i
11 draw from this slide is, in fact, while there are only.
I l
12 17 tests, you can see that we're gaining a tremendous 13 amount of information from each actual test that's
-l 14
- run, it's not just a simple matter of testing one 15 configuration.
16 (Slide)
Now, on the nest slide I'd like
'I 17 to talk a little bit then about how one would go about j
i 18 using this on a plant-specific basis and why such a
+
19 generic program can, in fact, address many of the 20 configurations and we think the great majority of the t
21 configurations within the industry.
- 'l 22.
This chart speaks in terms of commodity, l
23 which I have to tell you is a term our contractor came l
l 24 up with for this.
I don't know if I like it or not.
25 But basically what it refers to is a specific
)
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j
1323 RHODE ISLAND AVENUE. N W.
{
ac23 234=33 wAss NatDN. o c. 2000s cro23 2344433 i
24 1
geometric configuration of Thermo-Lag and a rather 2
discreet configuration.
For instance, commodity 1 1
3 represents a straight run of conduit.
Commodity 2 is l
4 a junction box.
Commodity 3 is a large cable tray 5
with a horizontal run and commodity 4 is what's called 6
an air drop or a cable drops from one element, which R
7 in this case is a conduit, and joins an existing 8
cable tray somewhere in mid-span.
9 Now, obviously, this is not an uncommon 10 configuration in an actual plant, but you will not see 11 us conduct any test that you can identify as looking 12 exactly like this.
On the other hand, we have run 13 tests of straight run of horizontal and vertical t
14 conduit.
We have run tests of junction boxes in 15 various physical configurations ~and we have run, as 7
16 you can see, many configurations of cable tray and air 3
17 drops.
So, what one does to apply this in a plant-f i
18 specific basis would be, in fact, to break down che i
19 existing plant configurations into these commodity 20 groups, reference these commodity groups based on a 21 comparison of the existing plant parameters to the 22 test parameters and then correlate this to a specific 23 test to show that, in fact, for that piece of this 24 fire barrier this material can be referenced to a 25 specific test and qualified and with confidence show I
NEAL R. GROSS CC"JRT REPORTERS AND TRANSCRIBERS f
1323 RHODE ISLAND AVEFUE. N W.
(202) 2304433 WASHINGTON. D C. 20005 -
(202) 234-4433 i
s 25 1
that all regulatory requirements are met.
2 So, that's how we see a specific test i
3 program actually being applied and this is a very,
'l 4
very important of understanding the whole program.
s 5
The test program by itself is not going to solve the 6
problem.
You've got to look at the application of i
7 that program.
8 (Slide)
Next page, please.
9 COMMISSIONER ROGERS:
You're saying that 10 in every plant the applications -- or in any plant, 11 let's put it that way, in any plant the applications i
12 of Thermo-Lag would fall into these four commodity
.i 13 groups.
Is that right? There are none outside that.
i 14 Is that what --
15 MR. RASIN:
Oh, no, I wouldn't say there i
~
16 are none outside that.
In fact, that's a good lead-17 in, Commissioner, to page 10 of the slides.
We 18 believe that this program will bound a significant 19 percentage of the plant cable raceway installations.
20 There has been some consternation that we've been able l
21 to put an exact number on that and I'll explain to you l
22-a little on the next slide actually why that is 23 difficult to do at this period of time.
But our i
24 feeling is that we are talking somewhere in the 70 25 percent range.
It may be a little less, it may be a NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON. D.C. 20005 (202) 234 4433 e
y
36 1.
little more, depending on a few factors.
2 This program will not address large 3
unusual shaped enclosures. For instance, we know that 4
there are some applications of Thermo-Lag where there i
5 are things like small cabinets or perhaps even a pump l
6 enclosure that's made of Thermo-Lag.
They are very 7
specific.
We made no attempt to address those.
~
8 We are aware that there are some places 9
where Thermo-Lag is actually used in'the form of a 10 wall between two rooms or between two areas of a room.
11 Those again are very specific applications.
We have i
12 made no attempt to address those in this testing 13 program.
14 Finally, we have to say we have seen some 15 very strange configurations even for raceways, that at 16 this time it's not clear whether this program would or 17 would not address and whether one could break them i
18 into commodities that would easily match up with the 19 tests.
It's likely that you would be able to qualify 20 maybe 80 percent of the run of a particular cable i
21
- tray, but in one area you had a
very weird 22 configuration that you just could not justify to these 23 tests.
In that case then a specific test would have 24 to be done or some other approach.taken.
25 We are developing an application guideline NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I
1323 RHODE (SLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433 f
i
37 1
which will be a very thorough explanation of who one 2
goes about. applying these test configurations within 3
the plant and returning the barriers to a state of 4
regulatory compliance.
We have previously told the 5
staff that it's every bit as important that we'have 6
dialogue in their review of this application guideline 7
as it is the testing program because, in fact,. the.
8 amount of installations that will actually be bounded 9
by this program will depend very heavily on the 10 staff's agreement with this application guideline and '
j 11 its approach.
f 12 (Slide)
That is one of the reasons, I
13 continuing to page 11, that at this time, even though l
14 we have all the physical information and could sit 15 back in our offices and count up in our own minds the 16 configurations that will be covered, we are reluctant 17 to do so and give a number until we've had significant 18 dialogue with the staff on this application guideline.
l 19 CHAIRMAN SELIN:
I 'm sorry. Let me see if f
i 20 I understood.
Even if you did have or even though you i
21 do have?
i 22 MR. RASIN:
We do have.
.l 23 CHAIRMAN SELIN:
You have details?
i 24 MR. RASIN:
We have the design material 25 that we collected, in fact, to design the test program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j
1323 RHODE ISLAND AVENUE, N W.
f (202) 234-4433 WASHINGTON. D C. 20005 (202) 234-4433
28 1-to make the test matrix that we thought enveloped a
?
I 2
majority of the industry configurations. But until we l
3 have agreement that the approach we're on for the 4
application and for this commodity approach to 5
qualification is acceptable to the staff.
Such a
{
i 6
comparison will be only our opinion and would require 7
a lot of work that wouldn't be productive right now.
~
(
8 CHAIRMAN SELIN:
Does that include a 9
reactor by reactor survey of how much of each of these 10 four building blocks there is and how much the special 11 figurations there is?
12 MR.
RASIN:
We have all of that 13 information.
We have concentrated on the cable 14 raceways.
I do not believe that we have at hand in l
15 our office all of the special configurations.
Let me 16 turn around and get a nod or a shake to see if that's 17 correct.
That's correct.
We do not have in-hand
?
18 design details on all of these special configurations.
19 CHAIRMAN SELIN:
But that seems to imply 20 that the information the staff is thinking of asking l
i 21 for in these 50.54 letters is available at the plants.
i 22 They've done most of that at_least to answer _your j
23 surveys.
24 MR. RASIN:
That is correct, most of it, i
25 yes.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
l
'f (202) 2344433 WASHINGTON, D C. 20005 (202) 234-4433
l 1
29 1
CHAIRMAN SELIN:
Okay.
j 2
MR. RASIN:
We believe that at the end of I
3 our program, once having completed the tests and 4
reviewed those test reports with the. staff, having 5
come to a conclusion and agreement on the application 6
guideline, that at that point in time we will have the 7
material available for each utility to use to select i
8 the best alternative to achieve full compliance 1
9 through one of the following methods.
I will say 10 missing on here, because we've concentrated on the
}
11 problems, is using the test to show that installed 12 configurations are adequate.
We believe for a large
{
13 number of one hour barriers we may be able to do that 14 as they exist.
15
- However, the alternative will be for l
16 problem areas to upgrade the barriers, to install I
17 other types of barrier material, to seek an exemption i
18 request based on the fire loading coupled with the 19 qualified performance of. the existing barrier as 20 referenced in some of our tests, to reroute the' cables l
?
21 or, in fact, to install suppression systems to turn a
(
22
_three hour barrier into a one hour barrier.
23 I will caution though.
I think there has l
24 been an impression after the test of the three hour 25 barriers to jump to the conclusion that, okay, we-NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON D C 20005 (202) 234-4433
33 1
ought to make them all one hour.
But I'll again 2
return to the fact that all Thermo-Lag tests have been i
3 declared indeterminate and therefore while we may 4
technically be very confident that a three hour 5
barrier will perform a one hour function, in fact it i
6 is no better qualified in a regulatory compliance 7
sense than any other barrier at this point in time.
~
8 Therefore, the testing program must continue, whether-9 that approach is selected or not.
10 COMMISSIONER de PLANQUE:
Do you consider 11 this list of alternatives an exhaustive list or just 12 the best possible options?
13 MR. RASIN:
Oh, I would be reluctant to 14 consider it exhaustive.
I think they are the more 15 obvious options with just a reading of the regulation.
16 COMMISSIONER de PLANQUE:
Okay.
17 CHAIRMAN SELIN:
Really there isn'_t -- I 18 mean there isn't much more you can do logically.
You 19 can fix the barrier, you put in a new barrier, you get-l 20 an exemption, you go from a three hour to a one hour 21 by putting suppression or you just separate the cable.
i 22 I mean it's logically hard to imagine that'that isn't 23 pretty exhaustive.
24 MR. RASIN:
Yes, I would agree with that, 25 but there are engineers in the utilities much more 1
NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ISLAfC AVEriUE, N W.
(202) 2344433 WASHINGTON. D C. h (202) 2344433
31-1 clever than I and I wouldn't want to rule out any 2
really clever technical solutions at this time.
3 CHAIRMAN SELIN:
I'm as nervous about 4
clever engineers as I am about clever accountants.
5 But we'll let you go on.
6 MR. RASIN:
Actually more worried about E
7 clever licensing managers than engineers.
8 (Slide)
If we could go to page 12, 9
please.
10 I'd like now to talk briefly about the 11 phase 1 test results.
Of the configurations we 12 tested, I have listed here those configurations which 13 we felt exhibited satisfactory performance in all 14
- respects, including meeting the NRC's proposed 15 criteria with the exception of the differences we 16 have, which we will discuss later.
17.
CHAIRMAN SELIN:
So, this page is to be 18 read that if the NRC accepted your views as to what 19 the cable loading ought to be and where the censor 20 should be placed, that you believe that the statements 4
21 on this page are true.
)
i 22 MR. RASIN:
Well, they exhibited -- from 23 a technical point of view they exhibited complete 24 satisfactory performances.
The barrier remained l
25 intact.
There was no breach.
The cable temperature
-i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(M2) 2344433 WASHINGTON. D C, 20005 (202) 2344433
32 1
I remained within the specs as we I.easured it and the f
2 vi'sual inspection of the cable afterwards showed 3
absolutely no damage to the cable whatsoever.
4 So, satisfactory in a technical sense. In 5
a regulatory sense, yes, if the staff accepted the i
6 acceptance criteria that we have used for this i
7 program, there should be absolutely no question of the 8
regulatory compliance of these configurations, f
9 COMMISSIONER de PLANQUE:
But these were j
10 all done according to your acceptance criteria?
11 MR. RASIN:
Yes.
Yes.
That's correct.
i 12 (Slide)
On page 13 we have a second set 13 of the phase 1 upgraded configurations which, in fact, d'
14 exceeded the te:aperature limits in the final one to 13 15 minutes of a three hour test, with the exception of 16 the last one which was within a few minutes of a one 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> test.
Again, these configurations had complete 1
i 18 integrity of the barrier and visual inspection showed 19 absolutely no damage to the cable.
However, even with 20 our
- criteria, the temperature values actually 21 specified by the staff, with which we don't have a' 22 disagreement, were exceeded at a
few discreet' 23 locations within the test and therefore have to be 24 called from a
regulatory standpoint a
- failure, 25 although from a technical standpoint the barriers' i
NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS h
1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C 20005 (202) 2344433 I
33 i
1 obviously performed very well.
2 The final two configurations at the bottom j
3 of these. phase 1
upgrades did not demonstrate i
4 satisfactory performance either in a technical or i
i
-t 5
regulatory sense.
t i
6 CHAIRMAN SELIN:
Mr. Rasin, would you go 7
back to this middle class?
8 MR. RASIN:
Yes, sir.
9 CHAIRMAN SELIN:
You didn't say this and j
-l 10 I'm not trying to put words in your mouth, but t
-l 11 listening to what you're saying it would suggest that
?
12 even these tests, although they didn't meet the 13 temperature, the test could be useful in helping a.
q 14 specific utility demonstrate that their particular 15 configuration and their fire loading would, in fact, i
i 16 be appropriate for an exemption request.
Is that a 17 fair conclusion?
18 MR. RASIN:
I don't think I'd make that 19 general conclusion with all three of these.
I believe 20 two of the three we could probably make an argument 21 for detailed review and discussion by the staff and a j
22 determination as to whether they were acceptable or 23 not.
Also, they could form the basis for an exemption 24 request showing that they far exceeded the existing i
25 fire load.
There's at least one of these tests which l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I
1323 RHODE ISLAND AVENUE, N W, i
(202) 2344433 WASHINGTON, D C 20005 (202) 234 4433
)
34 1
we are not prepared even to make that argument at this i
2 time.
3 CHAIRMAN SELIN:
Which is the third one?
4 The one for which you're not prepared to make that 5
argument.
6 MR. RASIN:
The first one, the three hour i
7 aluminum cable tray with "T" section.
In that case,
[
8 we actually had some water intrusion when we did the l
9 hose stream test.
So, even though the barrier f
10 performed all right throughout the test, after it was 11 over and we did the hose stream, there was some 12 leakage of water which led to some other problems.
13 Whether that is a function just of the arrangement we
[
P 14 had with the test location or whether, in fact, it is 15 a problem for an actual installation, we haven't 16 determined yet.
s 17 I just wanted to point out that ever since 18 we've completed these tests we've been reviewing them.
i 19 It is not a small task to do this.
The typical 20 configuration I showed you before has approximately 21 300 thermocouples when constructed and instrumented to
[
22 meet the standards and the criteria that the staff has f
r 23 on the barriers.
So, the basic criteria that we've i
24
- used, if there's any one of those - thermocouples 25 anywhere that exceeds this temperature criteria, then NEA'L R. GROSS COURT REPORTERS AND TRANSCRIDERS f
1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON, D.C. 20305 (202n 234 4433
.~
35 1
the test is not a clean pass and is put on hold.
2 Going back and deciding now what the real physical 3
situation was with that barrier then becomes quite an-4 intensive task.
What we have done to date is not to 5
press that point, not to engage the staff in arguments 6
over this is good even though we-had this exceedence 7
because what we really want is a nice set of tests to 8
where we do not have to use all the resources to do 9
that, they're just clearly referenced.
Whether we 10 return to some discussions on particular tests at some 11 point in the future, I will leave open, but that's not 12 our intent at this point.
13 COMMISSIONER de PLANQUE:
'But the 14 temperatures were okay up until between one and 13 15 minutes short of the time?
16 MR. RASIN: That is correct, they were all 17 below the specified temperature criteria up until that 18 time, at which typically there was one thermocouple 19 that exceeded somewhere in the test configuration that 20 temperature.
21 COMMISSIONER de PLANQUE:
What's the 22 accuracy of the thermocouples?
23 MR. RASIN:
That's a good question.
24 COMMISSIONER ROGERS:
Oh, they're pretty b
25 good.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W h02) 2344433 WASHINGTON. D C. 20005 (202) 2344433
36 I
1 COMMISSIONER de PLANQUE:
They should be 2
pretty good, j
3 COMMISSIONER ROGERS:
They're very good.
i 4
It's the best way there is.
I 5
MR. RASIN:
They're very accurate within 6
one degree..
However, that's wi. thin the temperature 7
range of the pass / fail.
What we have found is that 8
when you do get into an exceedence where you get the 9
higher temperatures, even though the temperature right 10 with the cables may be okay, we're unwilling to rely 11 on those thermocouples once we get up into the 500 or 12 600 degree range.
13 (Slide)
Page 14, please.
14 For some of these test results, we have 15 taken the approach in the design of these for some 16 fairly conservative baseline installations and we 17 believe that they have contributed to the failure.
18 For instance, we've used minimum material thicknesses 19 based on our survey of the industry for these i
20 applications and we've used the most limiting 21 construction attributes.
This was carefully 22 considered based on a desire to bound the maximum 23 number of installed applications. Basically what this
[
t 24 says in this test we may have pushed too far trying to 25 envelope things and by backing of f a little bit on the l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENIM, N W.
f (232) 2344 433 WASHINGTON, O C. 20005 (202) 2344433
i 37 I
criteria we may leave out a few percent of the_
l 2
ex'isting barriers, but in fact be able to show that i
3 the rest of them are qualified.
t 4
That's one of the tradeoffs that we have 5
to make in this text
- matrix, is a
careful
+
6 consideration of how far do you go to bound a certain i
7 number in a given configuration without pushing so far f
8 that you fail the test and, in fact, have bound l
t 9
nothing.
I think in phase 2 we'll probably learn, get i
10 a little smarter, but we may also find there that we 11 pushed a little too far to envelope.
12 COMMISSIONER de PLANQUE:
Is there a 13 question of density in addition to thickness? Has the 14 material always been.made in a uniform way?
15 MR.
RASIN:
There have been questions 16 raised with respect to Thermo-Lag both on chemical i
17 composition and the density or consistency of. the 18 Thermo-Lag.
In the test program we are receiving the r
19 Thermo-Lag direct from the manuf acturer.
However, we l
20 have independent chemical analysis of all the Thermo-21 Lag received for each test.
So, we will have' a
'i 22 consistent set of parameters. When we get to applying l
23 that to plant-specific configurations, I think the 24 chemical questions will be easily answered.
We still 25 have to ask ourselves whether we have concerns we have l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C. 20005 (202) 2344433
4 1
38 j
i 1
to do something special about with respect to the l
2 density.
l
[
3 Finally, with the phase 1 test program, my f
i 4
people and the consultants assure us that the failure 5
mechanisms we have observed are well understood and 6
that therefore we can't take those into account in the 7
phase 2 program and hopefully not make the same 8
mistakes twice.
We will have to see how, in fact, 9
that comes out.
10 We have done significant redesign of the I
11 phase 2 test program as a result of what we've learned I
12 in phase 1.
In fact, just during this month those i
i 13 designs are proceeding and we plan in December to 14 construct the test articles for phase 2,
apply the f
15 Thermo-Lag which needs a 30 day cure time before 16 testing and then in January we will proceed with the 17 phase 2 tests.
l i
f 18 COMMISSIONER ROGERS:
Excuse me.
Just on 19 that failure mechanism is well understood.
That's a i
i 20 very important statement.
I'm trying to make sure I j
21 understand what it says.
Does it suggest that tnere
[
22 were deficiencies in some way that in the ideal
[
23 installation application of Thermo-Lag might not have.
t t
24 led to a failure?
In other words, what are these 25 mechanisms that you're considering?
One of the I
i NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
I (202) 234-4433 WASHINGTON, D C. 20005 (202) 234-4433 i
39 1
questions is Thermo-Lag itself, whether it can do the 2
job even if it's properly installed and'so on and so 3
forth. Are these mechanisms that you're talking about 4
here deficiencies from the idealized application of-
-l
-I 5
this material or what?
j 6
MR.
RASIN:
Commissioner, the failure f
7 mechanisms
- here, I
- think, relate to the direct 8
application of the Thermo-Lag as done in the industry i
9 for specific configurations.
I don't believe at this 10 point there is a question on whether Thermo-Lag can in l
t 11 fact perform the function that it's supposed to 12 perform.
Whether, in fact, it is applied correctly 13 and in adequate thickness to perform that function in 14 every situation is a question.
i 15 For instance, on our tests of conduit, we i
i 16 found that the thickness of Thermo-Lag specified for 17 various sizes of conduit, particularly the smaller
[
f 18 sizes, is in fact just not adequate.
Therefore the j
f 19 installed configurations for certain sizes of small i
20 conduit would need to be upgraded in the industry.
21 In other cases, we have found difficulties i
22 with the construction details for very large cable 23 trays.
For instance, for a 36 inch span without any 24-internal support, the Thermo-Lag on top tends to sag.
\\
25 So, while it performs this function --
l l
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
1323 RHODE ISLAND AVENUE. N W l
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433 I
l t
=
~
40 1
COMMISSIONER ROGERS:
Let me come back to I
i I
2 that first example.
i 3
MR. RASIN:
All right.
l f
4 COMMISSIONER ROGERS:
You say it was not 5
thick enough.
)
6 MR. RASIN:
Yes.
7 COMMISSIONER ROGERS:
To me that's saying 8
that if it were thicker you think it would have t
9 worked.
{
t 10 MR. RASIN:
Clearly.
l 11 COMMISSIONER ROGERS:
Well, what's the 4
12 evidence for that?
How do you know that?z 13 MR. RASIN:
Well, I think some of the --
14 let me ask my consultants back here.
l 15 COMMISSIONER ROGERS:
It seems to me
{
i 16 that's very much related to the question of whether t
17 the material itself will do the job.
f i
18 MR. RASIN: Well, for one instance, on the l
l 19 test articles that we have done with these upgrades,
'l I
20 I can tell you that the biggest factor of the upgrades
'l t
21 in phase 1 is the addition of greater thickness of.
22 Thermo-Lag material.
So, for particularly the three i
i 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> configurations that we have shown here, it was l
24 felt even before the testing that the existing i
i 25 thickness of the Thermo-Lag would result in an j
i NEAL R. GROSS l
COURT REPORTER $ AND1RANSCRIF5ERS 1323 RHODE $ LAND AVENUE, N W.
.l (202) 234 4433 WASHINGTON, D C. 2000$
(202) 2344433
)
^
i 41 1
unsuccessful test.
So, the upgrade was, in fact, to t
2 put a greater layer of Thermo-Lag atop what already l
3 existed.
So, we put the article exactly as it would t
t 4
have existed in a plant, bounded by our conservative i
f 5
parameters, and then we applied an additional layer cf 6
Thermo-Lag as an upgrade that would be done in a field t
7 situation and ran the test.
Many of these tests, as
'~
{
I 8-you saw, were successful under that situation.
So,
[
9 obviously the Thermo-Lag must have been working.
10 There were also sole previous tests and 11 I'm reluctant to say much about the details because I l
12 don't recall them.
But I believe even in some of the 13 Texas testing done in conduit, that the thickness on I
14 various sizes of conduit was explored.
But I would i
15 have to check the details on that.
We will also have 1
16 that in the phase 2 testing where, in fact, the l
17 approach we're taking there with the industry proposed l
18 upgrades is to test an existing baseline configuration 19 and then immediately afterwards test the proposed 20 upgrade to that configuration.
So, we will have a
- j 21 direct comparison with how does it perform as 22 installed and how will it perform with the designed i
23 upgrade.
So, we should have some very definitive 24 information on those questions.
}
25 COMMISSIONER ROGERS:
Okay.
I i
NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVDvUE. N W (202) 2344433 WASHINGTON D C. 20005 (202)234 4433 l
_~
1 l
43 i
1 MR. RASIN:
(Slide)
Slide 15.
l
\\
2 I'd like to speak to some of the 3
conclusions that we have drawn based on what we've 4
learned so far in assessing the phase 1 testing.
5 Obviously these could be subject to learning a little l
6 bit more in the future.
But at this point in time,
\\
7 we believe that one hour upgrades can be successfully 8
demonstrated through such a testing program as ours.
9 By one hour upgrades I mean those that could be i
10 practically considered for installation in the plant.
11 Not on here, but let me comment.
We have 12 not had any information until we entered the phase 2 I
J 13 testing, but we believe that a significant number of t
14 the existing one hour barriers will probably prove
)
15 satisfactory for their situation.
l 16 With respect to three hour barriers, it's i
17 clear that upgrades are likely to involve more-
!A 18 extensive retrofits for most existing installations 19 and, in fact, will be difficult to install in the 20 field.
At the same time, we feel it's premature to' 21 conclude that three hour upgrades cannot be 22 successfully developed mainly because we do have some 23 industry proposed upgrades in the phase 2 part of the -
24 program.
I remind you the phase 1 was only vendor 25 recommended fixes. Also we're gaining more experience l
NEAL R. GROSS i
COURT HEPORTERS AND TRANSCRIBERS i
1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON, D C. 20005 (202) 234-4433
i 43 1
1 with this' testing program where really we're testing 2
to a new more stringent set of criteria than has ever i
3 been applied to these fire barriers before.
Our real 4
challenge is to identify those upgrades that are real 5
practical solutions for installing in the plant to 6
6 return to compliance.
7 CHAIRMAN SELIN:
You're going to go 8
through some of these test results that you have?
9 MR.'RASIN:
Sir?
l 10 CHAIRMAN SELIN:
You're going to continue 11 into some of these other charts that you have in the t
12 back, aren't you?
4 13 MR. RASIN:
Yes, I was planning to.
14 CHAIRMAN SELIN: The question I had on the 15 three hour barrier and maybe it's too early, not in 16 the presentation but in the test, to answer that, is 17 do you see any reasonable hope that you can get three 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> results on a generic basis as opposed to getting i
19 the building blocks so that a specific plant for a 20 specific configuration could claim that they have j
r 21 three hour separation?
j l
22 MR. RASIN:
Yes.
We still see some hope j
23 for that in different configurations.
For instance, 24 on conduit where it may be a matter of just adding an l
25 additional layer of Thermo-Lag, which doesn't have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON. D.C. 20005 (202) 2344433
)
I 44 i
1 be all that thick, it may well be very practical.
For 2
something like a large 36 inch cable tray where in 3
fact the additional material being added is fairly l
4 heavy and affects the ampacity and your seismic I
5
. calculations, then that may be a difficulty. However, 6
we're also -- in phase 2 we. have some proposed 7
upgrades that involve using a combination of other l
t 8
material along with the Thermo-Lag that may provide 9
yet a practical solution.
10 It's also important that you look on a 11 plant-specific configuration.
We may come up with an 4
12 upgrade that's very easily installable at one plant 13 and one configuration, but where in another place 14 there just is not the room to apply that upgrade.
So,
-l 15 while we acknowledge three hour barriers are a real
[
t I
16 challenge, we do think it's premature to conclude that 17 all three hour barriers are out of the question to i
18 qualify.
l 19 (Slide)
Turning to page 16, I'd like to 20 just briefly show you a
chronology of the key 21 act2.vities.
I hope to show you that we really have L
22 been working hard on this for a long time.
While I 23 won't go through the list, I will point out a few of 24 the key factors.
25 In June of 1992, the test results from i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433
i I
45
.j 1
some of the early testing at Texas Utilities came out,
{
2 which I
think was the first time -it clearly 1
3 demonstrated that we had more than a regulatory t
4 paperwork problem. It clearly demonstrated that there 5
were structural problems with the barriers and 6
therefore that the exact.
installation and I
7 configurations were very important.
~
8 In August of 1992, we held a workshop for 9
the industry, specifically to impress upon everyone 10 that this, in fact, was a real problem that needed 11 real attention and was going to be a very difficult 12 one to resolve and that we really needed the support 13 of the industry to proceed forward with resolution.
14 By September of
'92, we had submitted a 15 white paper to begin a discussion with the staff on 16 the testing and acceptance criteria under which we 17 would proceed to look at the fire barriers.
We had 18 those interactions over the rest of 1992.
19 In February of 1993, we received our 20 survey results from the industry with all of the 21 design and installation details on the existing cable 22 raceway applications which allowed us then to begin to 23 formulate the details of a test matrix.
24 (Slide)
Continuing onto page 17, we had 25 an interesting happening in February of 1993 which, in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
46
...t 1
- fact, did lead to a several month delay in our i
I 2
actually starting the test program.
I want to explain 3
that to you because it has nothing to.'do with the j
4 technical details.
We had designed a test program 5
which we thought to be most effective should take
{
6 advantage of equipment and ' personnel.
from the i
7 utilities so that we would not have to hire i
8 contractors to build and install and actually conduct 9
and monitor the test program.
10 So, we had several utilities lined up that i
11 were going to supply us materials such as cable trays l
v 12 and conduits for the phase 1 testing.
They were going 13 to supply the manpower to actually construct the 14 material, apply the Tnermo-Lag and they were going to
[
t 15 supply the quality assurance people to, in fact, -
16 monitor the test.
17 Unfortunately in February of-
- 1993, t
18 subpoenas appeared at all or most utilities with I
19 respect to a grand jury investigation underway in j
20 Baltimore and upon finding out that that was a i
')
21 criminal investigation, the legal advice to those-22 utilities was to have no direct participation in the-23 test program.
So, at that time we had to step back 24 and, in fact, take a different approach whereby NUMARC 25 contracted separately and distinctly with contractors NEAL R. GROSS l'
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
i (202) 2344433 WASHINGTON. D C. 20005 (202) 234 4433
- Y
.~
47 F
1 to build the test articles, to install the Thermo-Lag 2
and to do the quality assurance checks necessary for f
i 3
the testing.
For us to regroup in that situation did, 4
in fact, result in a delay in the test program.
5 However, it was only the delay due to the contractual 6
necessities, not any technical difficulties.
7 In March of
'93, we made the decision, we 8
think at some risk, to proceed forward even though we 9
had not finalized test and acceptance. criteria with
.L 10 the NRC because we realized that there would have to 11 be public cominent on those proposed criteria and that 12 that would result in a significant delay.
We felt at 13 that time, however, that we could not wait until those 14 criteria were completely finalized because it would i
15 result in too long of a delay in resolving these' 16 issues.
So, we have pressed ahead with determination, 17 realizing that there is some degree of risk that the 18 NRC will not accept results that we think are 19 satisfactory because they differ with the criteria.
20 On the other hand, we think we have a technically 21 sound program that will withstand the scrutiny and 22 result in approval, even though we may have a few 23 deviations.
t 24 (Slide) On page 18 we show the activities 25 immediately ahead of us.
We have another industry-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W.
(202) 2344433 WASHINGTON, D C. 20005 (202) 2344433 t
t
48
)
i 1
wide workshop scheduled for December 1st and 2nd where 2
we intend to present to the industry in excruciating 3
detail the results of the phase 1 testing and what we 4
have learned and to go over with them our thoughts on 5
phase 2.
We will also at that time give the industry 6
the first presentation on the intention for the i
7 application guideline and get them to begin to 8
understand how they will go about using these test i
9 results on a plant-specific basis.
10 By the end of this year we expect to have 11 the phase 1 test reports officially published and i
12 distributed to the industry.
As I said before, the 13 phase 2 testing will proceed in January and early in
-l 14 1994, upon completion of the phase 2 testing and upon 15 discussion of the staff with the industry application i
16 guideline, we hope to have all of this material in the 17 hands of the industry within the first quarter of 18 1994.
19 COMMISSIONER ROGERS:
That application 20
- guide, that doesn't depend upon phase 2 testing 21 results, I take it?
.[
22 MR. RASIN:
Well, it does, Commissioner,.
i 23 in that there is certainly a synergism between the i
24 testing and the application guideline and the various 25 combination of parameters that one is trying to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
(202) 234 4433 WASHINGTON, D C. 20005 (202) 2344433
=
49 1
envelope.
So, from the-tests we learn the 2
significance of different combinations of parameters.
t 3
That in turn affects the application guideline as to 4
what we think can be technically justified in terms of 5
reterencing plant-specific configuration to a test..
6 (Slide)
Moving onto.page 19, I'd like to i
7 talk very briefly to you about the test and acceptance 8
criteria issues.
9 Generic Letter 86-10 specified measurement 10 of temperature at the unexposed side of the barrier i
11 and the basis for that were existing industry 12 standards at that time.
In fact, we don't quarrel f
13 with that because what was used was all that existed 14 at the time.
But, in fact, the main determinant was 15 a standard that was based on use of non-load bearing 16 Walls, as fire protection between two adjacent rooms
{
17 with the intent being to protect combustible material 18 on the cold side of the wall.
There were no cable 19 raceway standards in existence at that time.
So, it's l
20 certainly understandable why such criteria were P
21 chosen.
In fact, I hope to show you as we proceed 22 forward that it's quite a different situation and f
23 that, in fact, certain portions of these criteria do 24 make a considerable difference particularly in how one l
25 goes about testing.
NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
(202) 234 4433 WASHINGTON, D.C. 20005 (202) 2344433 I
t
i
.i 50-i
-1 Furthermore, the actual tests that we hava 2
seen for typical fire barrier materials in the 3
industry have not rigorously applied this standard 4
but, in fact, have been accepted upon further review 5
of-cable temperature and circuit integrity.
l i
6 (Slide)
Next slide, please.
f 7
The NRC staff has proposed a supplement to 8
Generic Letter 86-10 with the express intent of 9
clarifying test and acceptance criteria.
As. we 10 discussed earlier, those criteria are still under 11 final consideration of public comments and have yet to i
12 be issued.
However, again, as I said, in the spring 13 of '93 we determined we had to move forward even in 14 the absence of those final criteria.
15 (Slide)
Page 21, please.
16 We believe that the clarification of the 3
17 86-10 requirements in fact involves quite a number of 7
i 18 increased conservatisms and we have those listed here.
I i
19 I will say that we had very thorough discussionu with f
20 the staff on these ' issues and with just a couple 21 exceptions we, in fact, agree that these new criteria 22 and these conservatisms are appropriate for this 23 situation.
24 (Slide)
Page 22, please.
25 However, we do have technical differences h
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 2344433 WASHINGTON, D C. 20005 (202) 2344433 l
51 1-on the significance of two issues.
One is' the 2
placement of thermocouples for cable trays and one is 3
the use of representative cable-fill in cable tray 4
tests.
I would point out that these are not 5
completely unrelated issues. They're not separate and 6
distinct independent variables. and we'll try to 7
explain that later.
8 Let me say with respect to conduits and 9
the criteria put
- forth, we have absolutely no 10 disagreement with what the staff has proposed and, in 11 fact, our test program is entirely consistent with 12 that.
13 (Slide)
Page 23, please.
14 The basis for the temperature measurement 15 approach that we have used in our testing program is 16 given here.
It is consistent with what we believe is i
17 an applicable industry standard, consensus standard,
(
-t 18 ASTM E5.11, which admitted is, in f act, in draf t form.
19 However, it is so much closer to appropriate for what 20 we're actually testing here that we think there's a i
21 reason for giving it serious consideration as opposed i
22 to relying on an old standard which clearly is nowhere 23 close bo the actual situation we're testing.
i 24 We believe temperatures should w measured
)
25 in the areas containing or in contact with cables NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON. O C. 20005 (202) 234-4433 i
r -
}
52.
I since, in fact, it is the cables themselves that we
[
2 are trying to protect and the temperature of those-i 3
cables is what directly relates to the performance of l
4 a safety function.
[
5 Barrier temperature location outside the 6
cables we believe is unnecessarily conservative with i
7 respect to cable functionality.
We have found only 8
one valid mechanism for cable barrier contact that we
-l t
9 think is a reasonable consideration and while we will 10 talk about that, but briefly it is the sagging of the l
11 upper section in a very wide cable tray, bringing that 12 section into direct contact with cables.
- I 13 Finally, we believe that while the staff 14 has maintained that they have always held to a cold 15 side barrier temperature, in fact previous tests have 16 not been approved to that criteria.
Previous tests 17 have been considered on a case by case basis and 18 approved in spite of that criteria.
We see no sense 19 holding to a criteria that in fact is a screening 20 value that's always broken.
21 COMMISSIONER ROGERS:
Before you leave 22 that, just could you explain that comment on the next-23 to the bottom bullet, upper copper conductor in place 24 to address this effect?
I don't quite understand 25 that.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON, D.C. 20005 (202) 234-4433
i 53-i 1-MR. RASIN:
I believe I can answer that a
-l 2
little better when we.get to a picture of an actual
-3 cable tray installation.
4 COMMISSIONER ROGERS:
Fine.
5 MR. RASIN: That will be just a few slides 6
later.
7 COMMISSIONER ROGERS:
Okay.
f 8
COMMISSIONER de PLANQUE:
Before you go i
9 on, can you tell me where the ASTM standard is in the 10 consensus process?
I see they're up to draft 14.
i 11 Where is it?
12 MR. RASIN: It is in the balloting process i
13 for that and whether that will result in final 14 issuance or whether it will result in draft 15 or.16 15 or 17, we can't say.
As you-well know, one can never 16 predict the consensus standard process.
On the other 17
- hand, from the standpoint of the thermocouple f
18 locations, it is -- to our knowledge it has never been j
19 a technical issue throughout the many drafts of the j
20 standards as to the location.
In recent drafts there 21 have been questions raised about the location of-the 22 thermocouple with respect to whether you do or do not i
23 have cable in the cable tray.
We think they're not i
I 24 completely unrelated issues and I will try to' explain 25 that to you.
But the location itself has not been.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j
1323 RHODE ISLAND AVENUE. N.W.
(202) 2344433 WASHINGTON. O C. 20005 (2C2) 2344433
i 54.
1 In fact, the recent controversy appears to have arisen 2
after we designed our test program and proceeded as we 3
have and we think the standard committee is responding 4
to questions brought up by the NRC staff and that that 5
is part of the concern as opposed to just a pure 6
technical concern.
7 (Slide)
Page 24.
~'
t 8
With respect to the testing with the 9
representative cable fill, our test program uses a i
10 single layer of cable fill for the cable trays. We'll 11 point out that with respect to conduit there is no
(
12 issue.
There is no cable included in conduit for l
13 testing and we agree with that approach.
-[
14 This single layer in our testing i
15 represents about a 15 percent cable fill.
From our j
r 16 survey results we've concluded that this would i
17 envelope 90 percent of the existing cable tray 18 installations in the industry, meaning that any cable
[
19 tray with a greater than 15 percent loading could 20 reference one of our reports successfully. Those with 21 less than 15 percent, of which there are less'than ten I
22 percent of the installed configurations, would not be 23 able to directly reference these test reports with no 24 other work or considerations.
l 25 CHAIRMAN SELIN:
Is there a significant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.f 1323 RHODE ISLAND AVE.NUE, N W.
(202) 234 4433 WASHINGTON. D.C. 20005 (202) 2 % 4433 l
~.
t 55 i
1-variation from one lot of cable to another in its heat j
2 sink characteristics or from-one manufacturer to 3
another of cable ostensively meeting the same l
4 specification? Or if you have a 15 percent fill, does 5
that really take care of all the 15 percent fill or l
5 6
greater in the industry?
7 MR. PASIN:
It does.
However, in the 8
application guideline the major point is the amount of 9
thermal mass that that represents.
That will be known 10 and that is based on the type and size of the cable 11 that is used.
In fact, what we'll look for in 12 matching up these tests is a thermal mass.
i 13 With respect to the cables themselves, 14 there are different properties with respect to the i
15 insulation, but the heat absorption and heat transfer -
16 characteristics of the cable is pretty well fixed 17 based on the fact that they're copper.
So, it's only 18 the diameter of the gauge used that has any variation.
19 With respect to the cable fill, we believe 20 that this will provide a test condition that is much 21 more representative of actual plant installations.
22 Again, as we hope to show, the barrier performance 23 itself, particularly because of the test and the way 24 we're testing it, even more so than the existing in-25 plant installations, is significantly affected by the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C. 20005 (202) 234-4433
~
56 t
1 fact of whether there is a thermal mass inside the 2
barrier or not.
[
I 3
(Slide)
Moving to the next page, what we l
4 have shown here is a plain view of a
typical l
5 ladderback cable tray.
Running up and down the page 6
horizontally are what are called side rails,-running 7
across the -- I'm sorry, vertically.
Running across 8
the page horizontally are the rungs of the so-called 9
ladder of the ladderback cable tray.
You can see that 10 they are actually rather thin structural membranes on 11 which the cables are laid.
12 (Slide)
Going on to the next page, one i
I 13 can see a cross sectional view of such a cable tray 14 with the side pieces noted on the left and the right-f 15 hand side and across the bottom is one of those 16 membranes on which the cables rest.
It's important to 17 keep in mind that that is not a solid floor of the 18 cable tray.
Also shown on here are the thermocouple 19 locations that we have used in the test.
You can see 20 that there's one right in the center, in amongst the i
21 cables, resting on that membrane.
There.is a -- and
.i 22 these are bare copper conductors to which the 23 thermocouples are attached, so that we do have a 24 uniform measurement throughout.
-[
25 On the left and right you will see l
NEAL R. GROSS f
COURT REPORTE.RS AND TRANSCRIBERS 1323 AHODE ISLAND AVENUE, N W.
(20?) 234-4433 WASHINGTON. D C. 20005 (202) 234 4433
I 57
'1 thermocouples attached to the outside of the rails and l
2 in the center on the very top, Commissioner Rogers, is 3
another bare copper conductor with thermocouples 1
4 attached.
5 What we were talking about before is the i
6 structural integrity of the top.of this barrier.
If 7
you look at the barrier going across the
- top, 8
especially for 36 inch trays, that's quite a wide 9
span.
If there is no internal banding providing i
i 10 structural support, as the Thermo-Lag reaches high 11 temperatures, we'd see a tendency of that top piece to 12 in fact sag downward.
I might also add we see' a-13 tendency of the bottom piece to sag downward.
That's i
14 really of no consequence with the cable itself.
But 15 the top piece, in fact, can sag far enough to come in 16 contact with the cables and, in fact, it would touch i
17 that top conductor.
So, with the test, we could see, l
l 18 in fact, that that had happened.
19 CHAIRMAN SELIN:
Before you leave this 20 chart, Mr. Rasin, would you be so gracious and open-21 minded to put where you think the staff would have 22 you -- show us where you think the staff would have
[
[
23 the thermocouples placed?
24 MR.
RASIN:
- Well, according to the 25 proposed criteria, the staff would like us to place NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS r
1323 RHODE ISLAND AVENUE. N W.
(202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
58 I
the thermocouple below the cable _ rung, actually in 2
contact with the lower cold side of the barrier.
So, 3
it would be between the horizontal rung on the bottom 4
and the fire barrier down below that.
5 COMMISSIONER ROGERS:
Or right on it?
~
6 Right on the fire barrier?
r 7
MR. RASIN:
It says cold side of the fire
~
8 barrier.
So, ideally, you would like it in contact 1
9 with --
10 CHAIRMAN SELIN:
Would there be any 11 difference on the sides?
12 MR. RASIN:
No.
Well, I don't think so.
13 The location is in the side. The standard requires it 14 to be in contact with what can contact the cable.
I 15 guess a rigorous application would be cold side.
16 However, that's not been raised as an issue in our 17 discussions, i
18 CHAIRMAN SELIN:
Okay.
You've got four t
19 thermocouples on this sketch.
You talked about the 20 one in the middle towards the bottom.
In other words, i
21 middle from left to right towards the bottom.
22 MR. RASIN:
Yes.
23 CHAIRMAN SELIN:
There's also one in the 24 middle from left to right towards the top.
I assume 25 that would be in contact with the whatchamacallit or f
NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASHINGTON. D C. 20006 (202) 234 4433 i
r
59 1
with the thingamajig.
f 2
MR. RASIN:
No.
No.
3 CHAIRMAN SELIN:
With the barrier.
l 4
COMMISSIONER de PLANQUE:
The Thermo-Lag 5
on the top?
f 6
MR. RASIN:
The whatchamacallit with the 7
thingamajig is supposed to stay up where it is.
But 8
as I was explaining to Commissioner Rogers, if in fact 9
that sagged, it would come in contact --
10 CHAIRMAN SELIN:
But wouldn't that 11 thermocouple be actually attached to the cold side of i
12 the top barrier as opposed to the insulation?
13 MR. RASIN:
No.
No.
It is not, nor am I 14 aware that that's a particular issue.
15 CHAIRMAN SELIN:
So --
16 MR. RASIN:
The main issue we've had is 17 with the lower one.
18 CHAIRMr.N SELIN:
So, the configuration 19 we're talking about would be one thermocouple, right?
f 20 MR. RASIN:
Yes.
i 21 CHAIRMAN SELIN:, Can I ask you another --
22
' MR. RASIN: Now, one set. That's actually t
23 a common --
24 COMMISSIONER ROGERS:
Thirty-six inches.
25 CHAIRMAN SELIN:
I understand.
NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS
[
1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D C. 2000'.,
(202) 234 4433 i
f
60 i
1 MR. RASIN:
A bare copper conductor with
[
2
.ma'ny thermocouples.
~
3 CHAIRMAN SELIN:
But in this section it's 4
one of them.
5 MR. COLVIN:
Yes, sir.
6 CHAIRMAN SELIN:
Okay.
I have a loaded 7
question for you, so please beware.
What would it i
8 cost you, not in terms-of the ability to argue your.
9
- case, but in terms of dollars and sense or' 10 inconvenience, what have you, to add a thermocouple so 11 that you had one where you show it and one where the 12 staff would show it?
13 MR. RASIN:
It's not a major cost issue 14 with the test.
There's some additional cost, but i
15 clearly that is not the issue.
In fact, we have i
16 agreed in phase 2 that in a set of the test, meaning i
17 one of the baseline configurations and one of the 18 related upgrade to that baseline, we vould in fact 3
19 include an additional bare copper conductor with.
l 20 thermocouples in that location requested by the staff 21 and provide that information to them for their 1
22 consideration.
We will discuss the' effects of that 23 later and what I hope to do is to set, as you say, an 24 open mindedness for what those results say.
25 I think in the previous briefing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433
i 61 3
1 message was left that, well, we don't think it'will l
2 make much difference.
In fact, that's not quite true.
)
i 3
I think the not makes much difference people have in s
4 mind, well, if it's only ten degrees or so it-doesn't 5
matter.
In fact, it may be greater than that and the l
6 fact that it's greater than that leads to why it 7
matters and I'll try to explain that to you a little
- i k
8 more.
9 COMMISSIONER de PLANQUE:
Do you have any 10 sense of how much greater than that it might be?
I i
i 11 know it's a guess.
12 MR. RASIN: Yes. Actually, the best guess 13 I have at this point in time is some feedback from i
i 14 some of the staff contractors where I believe they 15 think for our configuration that it may be in the 16 range of 80 degrees.
I think that might be a little 17 bit high, but they may be right.
18 (Slide)
To go on to the next page, we 19 have created a little model to try to demonstrate 20 conceptually the importance of this issue and why with 4
21 respect to just these two points on measurement 22 location and cable inclusion, why we think that we 23 just go too conservative.
As I stated, many of the 24 other criteria had conservatisms, but we think they 25 are justified to the situation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
?
(202) 2344433 WASHINGTON. D C. 20005 (202) 2344433
~
62 1
I want to add great caution as we go 2
through and talk about this that this model does not 3
represent Thermo-Lag, it does not represent any fire 4
barrier material on the market right now.
It is, in 5
fact, in analysis using a representative insulation 6
material to demonstrate a point.
However, we have F
7 crafted this so that we think the principles shown in 8
fact are representative of a typical fire barrier 9
material.
10 One of the problems is that a fire barrier L
11 material typically in use today is not a simple 12 insulating material.
It is a
chemically and 13 physically active material that seeks to take the heat F
14 away as opposed to simply insulate the enclosure.
I 15 That makes it an extremely difficult analytical 16 problem because both the specific heat and thermal 17 conductivity are functions of temperature and, in many 18
- cases, time at temperature.
- However, one can 19 represent these by an effective specific _ heat and 20 thermal conductivity, and that is what we have tried 21 to do here.
~
22 The first picture shows what I think a i
23 pure fire protection engineer would like to see and 24 that's quite understandable.
He would like to see a t
25 fire barrier represented with absolutely nothing NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS
'i 1323 RHODE ISLAND # VENUE, N W.
(202) 234 4433 WASHINGTON. D C. 20005 (202) 2344 433
}
63 1
inside it so that if the temperature on the inside 2
surface in fact met the criteria, there would be 3
absolutely no question to where it was used or how it 4
was used or what was inside it.
A notable goal, but 5
it's quite a price.
6 (Slide)
If we go to.the next page, we see 7
a more representative situation where, in fact, inside 8
this barrier is some thermal mass.
What we have 9
depicted here is simply a copper bar, a thin copper 10 bar located in the center.
What I hope to show you 11 is
- that, in
- fact, particularly given the test 12 configuration, the presence of thermal mass is very 13 important.
14 (Slide)
If we go to the next page, we 15 have a chart of some analytical results running a 16 simple one dimensional heat transfer model for this 17 situation.
The dashed line on this curve represents 18 the temperature at the inside surface of the barrier l
19 with nothing but air inside the barrier.
Now, it's 20 important to understand t he physical situation.with a 21 testing program because, in fact, a-test model, 22 whether small scale or large scale,'is a completely 23 sealed unit with no ability to transfer heat outside.
24 Therefore, it is only a thermal mass which simply-25 absorbs heat.
In the case where there's nothing 1
NEAL R. GROSS COUR1 REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433
.<ASHINGTON, D C. 20005 (202) 2344433
64 1
inside the barrier, in fact the barrier itself' absorbs 2
heat and therefore the inner surface temperature is 3
reflective of the amount of heat absorbed.
There can 4
be no heat transfer out of that inner surface and i
I 5
therefore one could expect the temperature to be l
6 higher.
In this case it's shown it is very
[
7 significantly higher. That's why we alluded before to
'[
8 the fact that the thermal mass within the barrier 9
actually has a significant effect on the successful 10 performance of that barrier.
To have a barrier that t
11 would meet the successful criteria with nothing inside 12 it will require substantially greater thickness than i
13 one in a more realistic situation.
14 CHAIRMAN SELIN:
And, in fact, we really 15 wouldn't care what would happen to a raceway that had 16 no cable in it.
17 MR. RASIN:
No, I really wouldn't care
[
J 18 very much.
I don't think we'll see a major safety 19 issue.
+
20 MR. COLVIN:
From a safety standpoint, 21 yes, sir.
22 MR. RASIN:
The next one line down the 23 little dots and Xs in fact represents the inner 24 surface temperature of this model with the existence t
25 of the copper --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
l (202) 2344433 WASHINGTON. D.C. 20005 (202) 2344433
65 1
CHAIRMAN SELIN:
I'm sorry.
Just a 2
second.
The dashed line is the temperature at the 3
inside of the barrier?
4 MR.
RASIN:
The inner surface of the 5
- barrier, the first barrier with nothing but air 6
inside.
7 CHAIRMAN SELIN:
So, there are two 8
differences between the first and the second line, 9
both what's in the cavity and also where you're 10 measuring temperature.
11 MR.
RASIN:
Yes.
Where you measure 12 temperature is the point of the second chart and the 13 lower --
-l 14 MR.
COLVIN:
In fact, I think you've 15 misunderstood.
The temperature measurement for the 16 crossed line is at the same point in both test models.
3 17 Is that correct?
18 MR.
RASIN:
That is correct.
The t
19 temperature -- the dashed line and the line with the 20 dots and Xs, in fact, represents the same temperature l
21 monitoring location.
22 CHAIRMAN SELIN:
Oh, it does?
r 23 MR. RASIN:
The difference being -- and 24 that is the inner surface of the insulator.
The 25 difference being whether there is or is not an NEAL R. G90SS COURT REPORTERS AND *RANSCRIBERS 1323 RHODE ISLAND AVENui, N W.
(202) 234 4433 WASHINGTON. D C. 20005 (202) 234-4433
66 1
additional thermal mass within the barrier itself.
2 So, the dashed line is the picture with nothing j
3 inside.
4 CHAIRMAN SELIN: Where did you measure the --
l 5
first temperature?
j i
6 MR. COLVIN:.Okay.
I.f you go to the first 7
slide, Mr. Chairman, that has no top or mass.
8 MR. RASIN: See where it says "T surface?
9 MR. COLVIN:
You see T surface?
10 CHAIRMAN SELIN:
Right.
11 MR. COLVIN:
And then you go -- for that 12 model that's the dashed line.
13 CHAIRMAN SELIN:
Okay.
And so that's 4
14 where you're measuring the temperature?
l 15 MR. COLVIN: That's where you're measuring
[
i 16 the temperature.
When you go to the second model, 17 which has the copper in it, the measurement T surface, f
18 which is the crossed line, is the same.
The bottom 19
- line, which Bill hasn't gotten to yet with the
[
20 rectangular lines is, in fact, measuring at the copper
[
i 21 bar-itself.
22 CHAIRMAN SELIN: Okay. Right. Thank you.
23 MR. RASIN:
(Slide)
Now, to move to the 24 second diagram, we have the question of do you measure 25 at the surface or do you measure at the cable?
As we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(2(4 2344433 WASHINGTON, D C. 20005 (202) 2344433 f
67 1
just concluded, the center line with the Xs and dots 2
is~ the inner surface, including the thermal mass of 3
the copper within the barrier.
The square dots and 4
.the lower curve represent the actual copper 5
temperature in this situation, and I'll try to explain 6
to you in this model kind of what happens.
7 We have explored the three different types 8
of heat transfer, which is cendtetion, convection and 9
radiation in this model. We find that because this is 10 a completely enclosed structure that convection plays 11 very little part, and so at the lower temperature and 12 time limits we have a predominant conduction heat 13 transfer.
That heat has to conduct through a layer of 14 air which if fact is itself a very good insulator, 15 particularly in an enclosed stagnant state.
As we 16 proceed to higher temperatures, the radiative heat 17 transfer in fact becomes the dominant mode that is 18 proportional to the absolute temperature difference to 19 the fourth power and so one can see a very rapidly 20 escalating heat transfer as the temperatures increase, 21 which is what one would expect in theory.
22 Now, the difference between the center 23 curve and the lower curve is the question of the 24 conservatism as to whether you measure the cold side 25 of the barrier or whether in fact you measure the NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON, O C. 2D005 (202) 2344433
i I
4 68 i
1 temperature in closer proximity to the cables.
Again 2
I'll stress this is an analysis to demonstrate the
(
l 3
point.
We do not believe that the temperature i
4 difference will be as large as shown here in the 5
natural situation.
~
f 6
CHAIRMAN SELIN:
Because there's real 7
convection in the--
i 8
MR.
RASIN:
No, I
don't think the 9
convection.
I think the geometry is a
little 10 different.
For one thing, we don't have a thin copper
{
i 11 bar right through the center of this thing.
We have t
[
12 a more distributed mass.
The distance involved is I
13 less. And in fact, at the sides there's actually some i
14 contact between the sides of the barriers and the f
15 cable tray itself.
So it's a more complicated 16 geometry, however the same principles apply.
And as t
17 I've stated, some thoughts we've had from some t
18 contractors actually involved in this testing think f
19 that the temperature difference we may experience may 20 be as large as 80 degrees, certainly much less than i
21 shown here.
i 22 Now there is another factor, though, that I
23 speaks.to the conservatism of this situation.
When
(
24 you are in the test mode, as I said, you have a sealed 25 element which simply is a heat absorption machine. In i
e I
NEAL R. GROSS i
COURT REPORTERS AND TRANSCRIBERS l
1323 RHODE ISLAND AVENUE, N W.
l (202) 2344433 WASHINGTON, D C 20005 (202) 2344433
69
[
i 1
an-actual in-plant configuration you have large runs l
i 2
of cable on either side of any particular fire zone i
3
- and, as was brought up before, copper is a very i
I 4
conductor of heat and so in fact in an actual in-plant f
f 5
setting you would have a very rapid transfer of heat
[
6 down the length of the cable as the: temperature 7
increased resulting in overall significantly lower
~
i 8
cable temperatures than one would expect-in a test.
t i
9 situation, fr 10 CHAIRMAN SELIN: What this all shows me is i
11 what I thought coming in, namely that there seems to 12 be an awful lot of argument over really very small 13 points, and I'd like to explain.
14 First of all, I'd like'to' repeat what I t
15 said at the beginning, which is, even if there were no l
16 differences on the testing questions, there are still i
17 major concerns about what will come out.
And I think i
i 18 in a different way your remarks support that, that the
{
19 efficacy of particularly the three hour barrier, the i
20 different configurations, et cetera, says we're likely 21 to have a serious problem in some of the locations in 22 a lot of these plants regardless of the test results.
i r
23 I'd just like to restate that so that my comments are
[
24 in a more limited context.
l 25 Where you measure the temperature, it just NEAL R. GROSS l
COURT REPORTERS AND TRANSCRfBERS
)
1323 RHODE ISLAND AVENUE. N W 4
f (202) 2344433 WASHINGTON. D.C. 20005 (202) 2344433
70 i
1 seems to me you ought to measure the temperature in
[
t 2
both places.- You still will have an argument with the i
3 staff about what temperature at what location equates 4
with a certain safe cable operation.
In other words, 5
we're looking for a surrogate, a screening factor, and 6
the question comes, well, at what temperature rise do 7
we not even have to take a look at the irapact on the j
i 8
cable or what-have-you, we just know there's no 9
problem.
i 10 And this argument is mixing up two points.
11 One is, from a testing point of view, what should we 12 know? And I think it's very clear that everybody, the 13 industry, NUMARC, the staff, the ACRS, would like to 14 know what the temperature gradients are so that for a I
15 better model and for use'in a particular configuration we really do know for aikely configuratior$s how fast 16 i
17 the temperature drops with distance from the i
1 18 insulation.
l 19 So what you're arguing is not where the 20 temperature should be measured. To me it's clear that 21 it should be measured in both places.
What you're 22 arguing is what use should be made of that 23 temperature.
For a given temperature, should the 24 screening criterion be set for 275 degrees at the 25 cable or at the wall?
And if you have the data, l
)
l NEAL R. GROSS COURT RFPORTERS AND TRANSCRfBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C,20005 (202) 2344433
71 1
you're'in a better position to' argue that with the l
2 staff.
3 As far as the fill goes, I mean, in a t
4 sense that's the industry's call.
If it's clear that 5
the temperature criterion can't be met in most cases 6
with an empty raceway, then I would think you'd be in I
7 a position to say "we'll take the measurement with 15 8
percent fill, maybe even with multiple fills," and
-I 9
come argue with the staff that says that "these aren't 10 as general as we'd like them to be, but we think they 11 cover 90 percent or 80 percent of the configurations."
j r
12 And, you know, it's almost irrelevant -- sorry, it's
[
t 13 not irrelevant, but it's almost an industry call as to I
i 14 how much fill to put in.
What the ACRS subcommittee
~l 15 feels, what the staff feel and what I feel is that 16 obviously the less you're relying on the cable the l
17 more unchallengeable your results would be.
But if 18 they're unachievable, you could come in with 19 temperatures to be determined at what point for l
20 different amounts of fill and say, "at least for these 21 configurations, we tnink we 've met the standard. " And t
22 the standard is clearly written in terms of j
23 temperatures at specific points as a surrogate for i
24 damage done to cable and the staff is really trying to 25 make your life easier, namely come up with a situation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(20?) 234 4433 WASHINGTON. D.C. 20005 (202) 2344433 l
i
72 1
that covers 100 percent of the situations, but there 2
doesn't seem to -- that may be an empty case.
i 3
And so it seems to me the argument between i
t 4
NUMARC and the staff on the. fill is sort of 5
irrelevant, that you run the fill that you want and P
6 the more fill you have the mcre limited the case, and l
1 7
that our desire is not so much for a more conservativt l
8 figure but for a figure that would just be more widely 9
applicable.
But it just seems sort of obvious you
.i 10 ought to run as little fill as you think you can get 11 reasonable results in the range of temperatures and
[
12 then argue about whether we're being too conservative 13 as to where the temperature is mexsured.
- [
I 14 MR. RASIN:
Let me respond'to that just 4
15 briefly, because clearly from a reasonable technical r
16 point of view one could proceed that way.
~
r 17 What we have been concerned about'is two i
18 things.
One -- and I'll just give you a for-instance.-
l l
19 If, in fact, the 80 degree temperature difference i
1 20 th::ught by different' contractors is correct, then all 21 of the tests that I previously pointsid out to you as-22 being successful in fact now are not successful, and l
23 so then--
i 24 CHAIRMAN SELIN: I was trying to avoid the i
25 question of what's successful and what's not-i 1
NEAL R. GROSS i
COUHT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) 234-4433 WASHINGTON. D C. 20005 (202) 2344433 1
73 1
successful to the point --
2 MR. RASIN:
But how could we do that when i
3 we are trying to show compliance with the regulation?
4 That is the difficulty, and so you get into a very j
5 resource intensive interaction with the staff which 6
takes a lot of time and I am convinced that in the end 7
we would come up with a successful resolution-that i
8 shaded on the over-conservative side leading to i
9 upgrading of a lot of barriers which in fact would
=!
10 perform their function very well and in fact it will 11 only take longer to reach final resolution.
And i
12 that's been our concern in this issue, looking for a
'I 13 practical resolution in a timely fashion that did'not 14 indiscriminate 1y just require unnecessary upgrading of l
15 all the existing barriers.
In all of the discussions 16 we had quite good technical agreement in all areas 17 except for these simply for that reason.
l
-i 18 CHAIRMAN SELIN:
Let me just fol?cw-on.
19 Number one, the real question is how much I
i 20 damage would be done to the barriers. We need to know.
21 the temperature both at the -- I'm sorry, not to the-l l
22 barriers but to the cable.
We need to know the
-l 23 temperature at the cable and we need to know ' the -
-+
24 temperature at the barrier. We need to know something 25 about the gradient as you move in, and we need to know j
NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS
{
1323 RHODE ISLAND AVENUE. N W.
l wo2> 2awas wASmNa,0N. o c. 2aws wo2> 2awas j
I I
'74 i
1 more than we seem to know about the characteristics of '
[
2 the cable.
3 My understanding of the history of this
[
4 regulation was that the reason that the measurement I
5 was intended to be made at the insulation was not i
6 because we did5't know there.was a gradient but t
7 because we felt that that temperature at the cable i
8 might in fact be too low.
In other words, there's'an e
9 argument about what temperature.the cable is supposed
[
10 to operate at.
11 But you'd be much better off having the 12 data. Even taking the measurement as we're asking you 13 to do docen't mean that you agree with or surrender to 14 the concept that that's where the measurement should 15 be taken for regulatory compliance.
You still can
{
i 16 argue that that's too conservative as a standard, but
~
17 knowing what the temperature is and what the gradients l
18 are would facilitate your arguments with the staff, 19 would make it much easier for-the industry to then l
20 look at specific configurations and figure if they f
i 21 have the problem.
I i
22
-I just want to add one more point to that.
!l l
23 It's clear to me,. even though you're not ready to
~24 agree to that, that there is inevitably going to be a.
25 fair amount of configuration-specific, site-specific i
i NEAL R. GROSS I
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE.lSLAND AVENUE, N W.
i
. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 234 4433
75 i
1 discussion.
You'd be much better off if the data on i
2 temperature gradients were available so that those 3
could be referenced when a specific utility came in to I
4 say, "We may not meet your regulatory standard, but we 5
don't have a problem.
Let us explain why."
6 What you're trying to do is subvert the 7
science to solve a regulatory argument.
If you won't 8
measure it here, then we can insist that the standard 9
be set at this point instead of that point, and I just 10 think that's foolish, actually.
11 MR. COLVIN:
I think the question that's 12 been on the table for the industry and has been 13 addressed from a policy standpoint is not whether we 14 ought to do the tests, whether there's an expense or 15 cost with respect to putting these thermocouples, but 16 really questioning when you get that result what does 17 that result mean.
18 CHAIRMAN SELIN:
Right.
19 MR. COLVIN:
You know, I think if you look i
20 at the ASTM standard and the technical issues, there 1
21 is no technical agreement by any of the parties except 22 for the NRC staff, to my knowledge, that there ought i
i 23 to be a measurement at the cold side of the barrier 1
24 for raceways.
I mean, the technical experts in this 25 issue say that you ought to measure it where in fact NEAL R. GROSS COURT REPORTERS AND TRANSCRIDER$
1323 RHODE ISLAND AVENUE N W.
(202) 234-44*3 WASHINGTON, D C. 20005 (202) 234-4433
76 i
. i 1
it is being measured.
2 The second point is that when you have 300 i
3 thermocouples instrumented down that line and any one 4
4 of those thermocouples requires the cessation of the e
5 test -- I mean, the test is a go/no-go.
The. test is 6
set up to be a pass / fail test and the whole criteria 7
is such that then when you fail then the next step to 8
do that is then to do the engineering analysis that's 9
required to analyze each thermocouple and what the 10 temperature rise over time and so forth.
11 So what we're talking about, although it 8
i 12 may seem like a -- I mean, it's a simple point to put 13 the thermocouples there.
When you try to then take I
14 that to the application in the engineering effort, you 15 really raise a number of questions as to whether we l
16 can effectively and in a
timely manner get-to
- I i
17 resolution on those issues.
That's the real meat of j
i 18 the issue from the industry standpoint.
19 COMMISSIONER de PLANQUE:
Yc u're saying 20 that in the majority of cases.then you would have to j
21 go through that exercise?
22 MR. COLVIN:
For every test that you have
{
23-these measurements, and again we have agreed to set up 24 a test with a baseline and an upgrade to do that.from f
25 a research standpoint.
I mean, that's really what I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1
1323 RHODE ISLAND AVENUE N.W.
(202) 234-4433 WASHINGTON. D.C. 20005 (202) 234-4433 o
=
77 1
that is, is a research standpoint, not an issue of
[
2 whether the cable integrity is at risk, which is the i
3 safety issue.
I don't think there's been any A
4 disagreement from the technical people on that point.
i 5
The question is, what is the real 6'
temperature there, and there is some concern about 7
what do you do if a cable was sagging down on that and 8
that happened to. touch, which is a question that we 9
need to look at.
But when you really get down to it, 10 what that would require is a considerable amount of 11 effort, time and engineering and analytical work to a
t 12 try to answer those questions about what each one of 13 those temperature differences mean without any real 14 result affecting safety.
I mean, that's the real 15 issue.
i i
16 CHAIRMAN SELIN:
So what I would do if I i
17 were in your shoes would be argue a little bit about l
18 the protocol as opposed to the measurements and come t
19 back to the basic idea.
The idea is not to get a 20 regulatory agreement or disagreement.
The idea _-is to 21 get an answer to a real and immediate - fire safety
[
22 problem that, even if all these tests are entirely 23 successful by your standards, we still have a lot of 24 problems in a lot of locations that have to be solved.
25 And this testing question will not be so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
1323 RHODE ISLAND AVENUC. N W.
j (202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
78 l'
generic that it's going to solve cll your problems, so 1
2 maybe you might consider recasting the argument a l
3 little bit about, if you take the two measurements and i
I 4
one passes and one doesn't, do you have to do as full i
e 5
analyses or where do you go.
6 MR.
RASIN:
Well,.that's probably the 7
reality of where we find ourselves, but it's still --
8 I understand your physical, technical and, in a very L
i 9
few cases, perhaps, safety concern, and I think that 10 can be quickly dispensed with.
But if.we go back to 11 the fact that the end result of this for final i
12 resolution of this issue to return to regulatory i
i 13 compliance, in fact I think we have a very real 14 regulatory question and it just does not seem to me to i
i 15 be the expeditious way through it to set a criteria 16 that's unnecessarily conservative to the point where i
i 17 every test result is unsatisfactory until thoroughly 18 discussed and point by point and test by. test and I
i 19 application by application approved by the staff 20 through some internal process.
Then ' why bother 21 setting a screening criteria?
22 CHAIRMAN SELIN:
I've given you a fair j
23 amount to think about.
I'm not going to repeat-the 24 point, but put a little more emphasis on discussing i
25 what the protocol is and a little less on where you I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS I
1323 RHODE ISLAND AVENUE, N W.
{
(2023 234 4433 wAsswoToN. O c 20005 (2023 234 4433 j
i
l 79 1
take -the measurements.
You might have a more j
2 productive dialogue.
l 3
Commissioner Rogers?
4 COMMISSIONER ROGERS:
Well, I have to say 5
that what I've heard ' the Chairman say ' strikes a 6
resonant chord with me.
Maybe I'm not looking at this 7
thing the way you folks are looking at it, but it does
~
8 seem to me that it looks to me as if you're saying 9
" don't take the measurement at the wall because the 10 results might give you a regulatory problem."
11 You want to make the argument that it's i
1 12 the integrity of the cables and the cable temperature 13 which is really the important thing in an actual 14 situation.
That's clearly true.
On the other hand, 15 if there is a regulatory issue about what the-wall 16 temperature is and whether you're satisfying that, not 17 taking that temperature isn't going to make that issue 18 go away.
19 I mean, you're trying to change the basis 20 of your argument, it seems to me, from satisfying.a 21 regulatory requirement which is stated in terms of 22 wall temperature to what is the actual temperature at 23 the cables, because that's the important thing. Well, 24 you know, I have to agree with you.
That's the 25 important thing.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(?O2) 234-4433 WASHINGTON. D.C. 20005 (202) 234-4433
80 1
But if there is a regulatory issue that 2
revolves around what the wall temperature is, not 3
taking the wall temperature isn't going to get you out l
4 of that pickle, so, I mean, I don't understand why you i
5 don't take the wall temperature measurement and then 6
nake your arguments however you.Want to make them.
7 But not taking a piece of data and then saying, "well, 8
because we don't have the data, that's really not the 9
important point, the important point is what the I
10 temperature is at the cables," I think just tries to l
11 sidestep the regulatory issue that maybe you just have 12 to head into, maybe we all have to head into.
13 But I'm very uncomfortable about what I'm l
14 hearing here on this, because it doesn't seem to me as 15 if the. issue which you seem to be very concerned 16 about, whether there's a regulatory sticking point I
17 attached to what the wall temperature is versus what 18 the cable temperature is, I don't think that problem 19 is going to go away by not taking that data.
20 Now something you said about how you do 21
.the experiments, it's a go/no-go experiment, don't you 22 just run the thing out?
I mean, if any thermocouple 23 exceeds this 275 degrees, do you suddenly cease the 24 experiment?
I mean, that would be crazy.
You run it 25 all the way out and then you take the data and look' at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
(202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433
4-
- ~
81 i
1 whae.ver you've got.
So, I don't understand.
There
{
2 are several things here I don't understand.
t 3
CHAIRMAN SELIN:
To put it simply, the 80-l 4
degree differential demonstrated -would certainly l
1 5
buttress your argument about the regulatory piace.
6 MR. COLVIN: Mr. Chairman, we ara going to 7
do that.
There's no question.
We've_already agreed
-f 8
that we will take those measurements.
'l t
9 I think I'd-like to go back and address 10 Commissioner Rogers' point, though.
We need to go
+
11 back to what is the basis. The regulatory requirement I
12 that existed in 1986 was a regulatory basis designed i
13 to test a wall, not designed to test a cable _ tray.
l 14 That's where the barrier requirement came from.
t 15 COMMISSIONER ROGERS:
I understand.
l 16 MR. COLVIN: Today that requirement is not 17 within the ASTM standard.-
That requirement for 18 raceway testing is in fact only a requirement from the
.i 19 staff to go back and relate the '86 requirement, which 1
20 we all agree was not the right requirement.
So, we 21 are going to do-that.
We're not trying to skirt the 22 issue.
i 23 The question is, what is an acceptable, l
l 24 technical, credible test for the application to l
y 25 protect the safety? That's what we're trying to come NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C. 20005 (202) 2344433
'}
83 1
to and I think the ASTM standard gives us that.
2 That's at least the --
3 COMMISSIONER ROGERS: The draft standard?
4 MR. COLVIN:
The draft standard gives us 5
that.
6 COMMISSIONER ROGERS:
It's a
draft 7
standard.
8 MR. COLVIN:
So there's no question of I
9 trying to circumvent the test or any question that 10 we're trying to not do that.
I think we're coming 11 back to the real basic issue of what is the right test 12 to qualify this material and ensure the safety of the 13 cables.
14 We would be willing -- and in the Texas l
15 Utilities test they did not measure the barrier on the 16 inside.
Okay?
They measured and instrumented the 17 cable.
We'd be happy to instrument the cable, but 18 that's not an acceptable solution.
So I think what 19 we're trying to do is get into the issues in a way 20 that gives us the right technical solution that.
21 provides the confidence that we can solve the 22 regulatory aspect.
23 I don't want to leave the impression with 24 you and the impression that you gave in the comments 25 that we are trying to get away with something by not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(20?) 234 4433 WASHINGTON. D C 20005 (202) 2344433
.~.
~
83 l'
measuring.
That clearly'is not the case.
2 COMMISSIONER ROGERS:
No, I think you're 3
not trying to get away with something.
You're trying 4
to change the basis of a judgment, and from the 5
earlier standard, which we all agree was accepted at 6
the time because that's all there was, that was based 7
on -- that related to wall temperature to a standard 8
that doesn't relate to the wall temperature.
That's, 9
it seems to me, what you're arguing for and --
10 MR.
COLVIN:
If I
could interrupt, 11 Commissioner Rogers, not to argue the point, but, the 12 point is that the standard in 1986 was not applied.
13 The application was, in fact, for every application 14 and every test we looked at, that standard and 15 measurement technique was not utilized.
I mean, 16 that's really part of the issue that we're dealing 17 with is whether or not that was an accurate 18 application then and whether it is today.
19 COMMISSIONER de PLANQUE: We can all argue -
20 over what is the best test for what you're trying to 21 achieve, but right now you may be stuck with a certain 22 test.
23 MR. COLVIN:
Absolutely.
24 COMMISSIONER de PLANQUE:
Okay.
I think 25 you have to face that reality.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
. (202) 234 4433 WASHINGTON. D C. 20005 (202) 234-4433
84 1
Now, down the road, if there's any chance F
2 of having a more reasonable approach to that, the more 3
data you have to support your argument the better, in I
4 my estimation.
5 MR. COLVIN:
Absolutely.
And, you know, 6
I want to make it clear.
We' asked -- we came to the 7
Commission to give you our insights and our. views and 8
not to ask you to make a decision.
In essentially
'i 9
every discussion we've had, whether it's with senior 10 management of the staf f or whether it's with industry, l
11 we all get immediately down into the technical details i
12 of which I am certainly not competent to discuss.
13 So I think that we have, Mr. Chairman and 14 Commissioners, we have the understanding of the
[
15 Commission, your views from that standpoint.
We will 16 clearly take those into account and we are trying to.
17 move ahead with this test program and do so in an
+
18 expeditious manner.
i 19 CHAIRMAN SELIN:
Well, you know, in the 20 constructive tone that you've put in, Mr. Colvin, a 21 lot of what you've said today has been very reassuring 22 about the thoroughness, not only the tests but the 23 limited conclusions - that are drawn from them, the 24 necessity of looking at specific configurations.
25 I'm sorry we even used the word NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE SSLAND AVENUE, N.W.
l (202) 7344433 WASHINGTON, D C. 20005 (202) 2344433 i
85 1
" exemption."
They're not exemptions that we grant.
2 What we're saying is,
- well, you didn't pass the i
i 3
screening test, but let's look at the actual safety 4
analysis, that the safety standard that we're setting i
5 is no lower in those specific cases than in the 6
general cases.
It's just that. the surrogate, the
{
i 7
screening tests, are a way'to save time and effort
~
t 8
when it's possible.
9 So a lot of what you've said today is very 10 positive.
You didn't ask for and you really didn't 11 get a Commission conclusion, but you did get the 12 reaction of three of the Commissioners who are -- we 13 have diplomas that say we used to be scientists and 14 engineers, so I think they should be taken seriously
)
15 and there will be further conversation.
j 16 Commissioner Rogers?
17 COMMISSIONER ROGERS:
Just that I do 18 appreciate hearing more of the details here of what i
19 you're presented today, because I think that it does 20 indicate that there is progress and it puts the whole i
i 21 question or many questions in a perspective that,
[
22 quite frankly, I didn't have until today.
t l
23 So, I
appreciate very much the l
24 presentation and the detail with which you've 25 expressed it, and with that I guess I've said all I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 7344433 WASHINGTON. D C. 20005 (202) 2344433
i 86 j
1 can say.
2 CHAIRMAN SELIN:
Commissioner de Planque?
i 3
COMMISSIONER de PLANQUE:
I have nothing 4
further.
i l
5 CHAIRMAN SELIN:
I believe the first.
I 6
turkey of the week will not.in fact come until 7
tomorrow, Mr. Colvin.
~
i 8
Thank you.
Thank you very much.
9 (Whereupon, at 10:48 a.m.,
the above-'
10 entitled matter was adjourned.)
l 11 12 13 14
.4 i
15
-j P
16 1,
I 17 18 I
19 i
20
[
21 22 i
23
-t 24 9
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13?3 RHODE ISLAND AVENUE, N W.
f (202) 234-4433 WASHINGTON. D.C. 20005 (202) 2344 433 i
(
I i'l CERTIFICATE OF TRANSCRIBER j
This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
l TITLE OF MEETING:
BRIEFING BY NUMARC ON THERMO-LAG PLACE OF MEETING:
ROCKVILLE, MARYLAND I
DATE DI MEETING:
NOVEMBER 24, 1993 were transcribed by me. I further certify that said transcription..
is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
7 N,
N
- v L
i Reporter's name:
Peter Lynch E
l f
h t
.{
NEAL R. GROSS count nepoersas me inAnscamats 1313 AM00s MLA8e AVD8UE M.W.
5 per) zu-uss wAmeneTou.or sooos emi m-eem.
j i
l i
Industry Fire Protection Program q
i
- Testing Thermo-Lag fire barriers Concerns relative to other fire barrier materials Proposed revision to fire protection.
regulations - 10 CFR 50.48 and Appendix R i
a l
l il i
NUMARC l
1
~
.l l
l h
Industry Thermo-Lag Program j
.i 1
OBJECTIVE:
1 To re-establish the tecanical anc licensing basis to qualify Thermo-Lag materials for use in one anc j
three hour fire ratings as required j
by Appenc'ix R I
i i
4 i
f NUMARC 2
Thermo-Lag Concerns Conclusion by NRC staff that fire endurance tests are " indeterminate" Differences in installation due to i
variec installation instructions Thermal performance and structural issues j
Inconsistencies in ampacity cerating values Combustibility L
- Generic applicability of test program 1
to actual p. ant installations NUMARC i
e
-5
.l Discussion Topics Test Program
~
Aaplicability o' Program Results Test Results Test / Acceptance Criteria Issues l
Conclusions i
t l
NUMARC 4
l
Fire Protection Defense in cepth
- prevent fires
- detect and promptly suppress fires
- protect equipment if fire cannot be extinguished (fire barriers)
Rec uirement for 1 or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers unrelated to alant fire loacings
- Low fuel loads are typical (less than 20 minutes)
- No actual fire has challenged installed barriers
- NRC has recognized the actual fire hazards in granting numerous plant specific exemptions NuMARC 5
4 i
Thermo-Lag 330
-l
~
Predominant cable racewayfire barrier material used for Appendix R i
Large scope of installation:
i
- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> conduit:
69,000 linear feet
- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> cable trays:
16,000 linearfeet j
- 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> conduit:
22,000 linear feet j
- 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> cable trays:
13,000 linear feet l
All previous tests declared indeterminate by NRC staff 1
1 Successful test program must re-1 establish qualification basis
[
NUMARc l
l
i Generic Fire Barrier Test Program l
j j
Purpose:
I
- Assess Thermo-Lag performance for j
representative plant cable raceway
~
installations Baseline Upgrades using Thermo-Lag Upgrades using other materials j
i Scope:
-l
- 17 test configurations
- Phase 1 - seven tests i
- Phase 2 - ten tests
- Further tests may be undertaken j
i i
t 7
l
f i
i Program Applicability t
l Many attributes of irstalled configurations are known to affect i
Thermo-Lag performance 1
+
- material thickness
- pre grouting of joints
- direction of structural ribs l
- internal panel supports
- band or tie wire spacing l
- type of joints
- unsupported span distance j
- support protection
- cable fill j
- raceway mass
- raceway dimensions
- raceway material l
- others l
i 4
i NUMARC 8
i i
Program Applicability (Cont)
~
h UMARC conc.uctec. surveys requesting extensive in"ormation on installec configurations Analysis of survey results revealec 3 road distribution of c ata relative to imaortant performance aarameters Challenge is to aounc t1ese factors wit 7out ceve.oaing u agraces that are over y conservative for tyalcal installations NuMARC l
9
4 1 and 3 Hour Baseline Thermo-Lag Installation 36M and 24'( Gable Trays: Tests 1 - 5
\\h 1
I 2'r' '
Stainless Steel Tie Wire Stainless Steel Bending 11 sed On Right Left D'sied On'Lef t Leg q
12'8 pex Structural Supporte hn 2..
s w
l
~
~ '
I v
"b one or three Three llour Allj6 edi b Et.f tSIMM
- ~
I"
^#
l Two (2) tie ae ed o
~~"7 wires are tened fasten eacht.
7 to fasten each scored section nittered sect!nt I
of radios.
/
~~
of radlies.
'l ll
- l One flour
%45guelg,PA.lgt.,$s h s($
Test'Atttele ihr.O.se#f0fts"-O" One (1) band is deed to f asten each scored siection 3Ir..l.080*f 0.15cf -O' r
of radius.
4 e--
.-.. m
Commodity #1 Commodity #4 Commadity #3 i
7 Commodity #2 Fire Resistive Barrier System NUMARC
-- -------.---. -.----------u
.--,.--u
..--.c,,--,.---r-
-c..
~s
~. -, - -
6 Program Applicability (Cont)
Program will bound significant
~
percentage of plant cable raceway installations Program will not address t
- Large, unusual shaped enclosures 4
)
- Large wall type installations i
- Raceway installations having unique j
i installation attributes l,
l l
NUMARC Application Guide will address comparison of tested to installed configurations i
i NUMARC i
10 l
l i
l i
Program Applicability (Cont) j
)
Generic applicability cannot be precisely quantifiec until Phase 2 1
tests results are known Utility alternatives to achieve full compliance following program completion:
- Upgrade barriers j
- Install other barrier types
- Exemption request - demonstrate installed i
barrier adequate to address actual hazard
- Reroute cables E
- Install suppression systems NUMARC 11
Phase 1 Test Results 1
u Phase 1 upgracec configurations exhiaiting satisfactory performance
' hour rated conduits (3 sizes, steel and aluminum) and junction box hour rated straight run steel cable tray i hour rated junction box hour rated small conduit NUMARC 12
Phase 1 Test Results (Continued ll Plase 1 upgraced configurations wit 1 tem aerature exceec ances in
'ina' 1 to 3 minutes o test, no cable c amage o aservec hour rated aluminum cable tray with "T" section hour rated wide span (36") steel cable tray hour rated wide span (36") steel cable tray 3 1ase ' upgradec configurations not cemonstrating satisfactory aer ormance: hour rated medium and large conduits
. hour rated air drop assembly NUMARC 13 i
I Phase 1 Test Results (Cont)
.l i
i 3
Conservative caseline installations contributed to test failures t
i
- Minimum material thickness
- Minimum construction attributes
?
Failure mechanisms we'l uncerstooc i
l i
t t
i NUMARC i
f 14 f
Phase 1 Conclusions
' lour upgrades can be
~
cemonstratec througa tests 3 lour aarrier u agraces are likely to involve more extensive retrofits o" existing installations Premature to conclude that 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> upgraces cannot be successfully c evelo 3ec 1
- Phase 2 may demonstrate more practical upgrades
- Gaining experience with testing to new criteria C.lallenge is to develop u 3 grades that can 3e 3ractically installed NUMARC 15
fi I
Chronology of Key Industry Activities
~
3/92 NUMARC forms AHAC q
6/92 TUEC test results - Bulletin 92-01 i
8/92 NUMARC holds initial industry workshop 9/92 NUMARC submitted test and acceptance criteria white paper to NRC 10/92 Test program funding approved 10/92 Industry installation survey developed, forwarded-11/92 NUMARC provides written comments on NRC proposed test / acceptance j
criteria 2/93 NUMARC received industry survey results 1
i NUMARC i
16
o s
Chronology (Cont)
~
2/93 Receipt of subpoenas results in i
withdrawal of direct utility involvement in test program f
3/93 Decision made to proceed with test i
program prior to NRC criteria finalization 4/93 Industry survey results compiled i
5/93 Test program contractors and lab selected l
6/93 Combustibility tests completed at UL f
7/93 Second industry workshop held 8/93 Responded to FRN on draft NRC test / acceptance criteria 9/93 Phase 1 testing Combustibility evaluation guideline distributed to industry
)
NUMARC 17 i
Scheduled Activities l
Inc ustry Meeting - December 1 - 2 Phase 1 test reports to industry by end of year l
Phase 2 testing January 1994 inc ustry Application Guide early 1994 e
NUMARC 18
Test / Acceptance Criteria Issues GL 86-10 specifiec "unexaosed sice of Jarrier" as temperature measurement location i
- Basis: NFPA 251, ASTM E-119 (wall standards)
- Cable raceway standards did not exist at that time Actual tests "or all barrier types were ty3ically conductec anc acceatec' on basis of cable temperature, circuit integrity (ANI) l j
NUMARC 19
Test / Acceptance Criteria issues (Cont) l NRC proposed Supplement to GL
~
86-10 would " clarify" test and i
acceptance criteria I
Revised criteria have not yet been finalizec.
Spring 1993: NUMARC decision to l
test with criteria based.on best i
technical judgment j
i I
l l
+
t
[
NUMARc 20 i
(
t
Test / Acceptance Criteria issues.
l (Cont)
Clarification of 86-10 requirements j
involves increased conservatism:
- Retain original wall standard as basis
- Specify instrumentation requirements for
" unexposed side of barrier" temperature measurement thermocouple placement, spacing use of bare copper conductors
- Provide more rigorous and explicit process for comparison of tested to installed configurations
- Provide increased requirements for cable 4
functionality determination NUMARC-21
1 1
i Test / Acceptance Criteria Issues j
l' Cont) j Agreement has been reached on l
most aspects of test criteria i
i Technical differences exist on:
i
?
- Placement of thermocouples (lower copper conductor) for cable trays
- Use of representative cable fills in cable tray 4
tests t
l F
t NUMARC 22 l
,.~
~
n
t Test / Acceptance Criteria Issues (Cont?
Bases for temperature measurement approach:
~
- Consistent with applicable industry consensus standard (ASTM E5.11 Draft 14)
- Temperatures should be measured in areas containing, or in contact with cables, since cable temperatures relate directly to performance of safety function
- Barrier temperature at location outside cable tray is unnecessarily conservative with respect to cable functionality protection
- Only valid mechanism for cable / barrier contact is sagging top panel. Upper copper conductor in place to address this effect
~
- NRC proposed temperature measurement method has not been applied to any previous cable tray test NUMARC 23
1 Test / Acceptance Criteria Issues (Cont)
Basis for position on testing with
~
representative cable fill o
- NUMARC program uses single layer (15%)
cable fill for cable tray tests NUMARC survey data show 90% of industry cable tray installations bounded by NUMARC cable fill-i percentage
- Basis: Provide test conditions i
representative of actual plant installations
-t
- Barrier performance affected (improved) by additional mass of cables l
9 NUMARC 24
F 4
6 i
M V
i l
e e
M d'
4-
.J s
U eg
=
aus k
ed 4
+
W
(
14w
- b te 3
> U 2>
M L 3 h 3=
=
-d,,
m M
W 2
.J 5
e mk s,
2 o a s
+
5*
~
~Q lC U
.E.
.1 On m
+
,i ; sn n
~
-.=
34 4
M b
7 1
I
_OC A-~ O s O-3ARE CO33ER CO N DUC-~O RS l \\
CA 3LE
~~ RAY
~~ ES~~
A R~~ C _ ES BARE 14 AWG COPPER CONDUCTOR ON TOP OF CABLE LAYER
//gu ni nig/un un/gnuungn/n
/
'I
/
T/Cs
=
==
l T/Cs
!?///}u/u n N /u n uuNunnu%u]
BARE 14 AWG COPPER CONDUCTOR ON TOP OF TRAY RUNGS T/Cs LOCATED EVERY 6" ALONG CONDUCTOR AND SIDE RAILS
4
^
7 EJ J
~~ - E R v' A V O J E 0 7 S
v, 3 RACEWAY RE 3ARR ER ENC _0S RE 0.5" INSULATION MATERIAL Cp=0.55
////f
/
f/
[
AIR
/
/
/
/
/
[ldi?se f//////////
1800 '
F SURFACE TEMPERATURE
..-+e 4-
+ -....
.--,+~-#
Sv3 r EJ J
~~
E R V A v0]E_ 07 RACEWAY r RE 3ARR ER ENC _OS RE i
0.5" INSULATION MATERIAL Cp=0.55 ff/ff f///
AIR
/
T
/
COPPER 1
/
/
"\\
/
AIR [SUh CE RAD A IVE
//////////?
"^"8vc" 1800 '
F SURFACE TEMPERATURE e
y
Simplified Model Time - Temperature Characteristics 1000
,/, -
N5 900=
/
800-y s
e*
700-
/
8 600-
}
a u
soo
/
m 400-g-;,, ;, a s.#x x
y gmp --
7 g
300-I
(
N' 200-
_ w-. ImWHHBf WHEEEE l Z C
100,.,me 0 0 0.5 1
1.5 2
2.5 3
3.5 4
Time thr)
-t-- Copper Surface
-M6-insul inner Surface
-B-Copper Center Line (with copper)
- - - 7 Estimated Terpperature for Empty Enclosure
m i..>
Effects of increased Conservatisms Barrier upgrades solely to address new conservatisms Increasec difficulties in addressing conflicting safety requirements for ampacity derate and seismicity Contrary to program objective of re-I establishing the technical and licensing basis to qualify Thermo-l Lag materials for Appendix R compliance NUMARC.
i
]
i
...s Conclusion NUMARC program is:
- Technically sound and consistent with draft consensus standards developed for cable j
raceway testing
- Takes into account actual installation j
parameters
-i i
- Provides practical generic resolution a
i i
i