ML20094H522

Testimony of Ma Serbanescu on Eddleman Contention 116 Re Fire Protection.Prof Qualifications Encl.Related Correspondence

ML20094H522
Person / Time
Site:	Harris
Issue date:	08/09/1984
From:	Serbanescu M CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), EBASCO SERVICES, INC.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094H487	List: ML20094H483 ML20094H493 ML20094H503 ML20094H509 ML20094H522 ML20094H547
References
OL, NUDOCS 8408140031
Download: ML20094H522 (42)

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August 9, 19 -

AGO 13 pyg;j4 UNITED STATES OF AMERICA' Ger

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ;

In the Matter of ')

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CAR LINA-POWER & LIGHT COMPANY ) . Docket No. 50-400 OL

-and NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

, Plant) )

APPLICANTS' TESTIMONY OF MARGARETA A. SERBANESCU IN RESPONSE TO EDDLEMAN CONTENTION 116 (FIRE PROTECTION)

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1 Q.l' Please state your name, address, present occupation 2 and employer.

3 A.1 My name is Margareta A. Serbanescu. My business 4 address is Ebasco Services Incorporated, Two World Trade Cen-5 ter, New York, NY 10048. I am employed by Ebasco Services In-6 corporated as a Principal Mechanical Engineer responsible for 7 the supervision of the Ebasco Fire Protection Engineering 8 Group. My responsibilities include development of the fire 9 protection program for the Shearon Harris Nuclear Power Plant 10 (SHNPP) project. A copy of my professional experience and 11 qualifications is affixed hereto as Attachment A.

12 Q.2 State your educational background and professional 13 work experience.

14 A.2 I am a Principal Engineer with 18 years of mechanical 15 engineering experience, including 11 years of fire protection 16 engineering for both nuclear and fossil power generating sta-17 tions. My work experience includes engineering and design of 18 various fire protection systems, using diversified suppression 19 agents such as water, carbon dioxide, halon, dry chemical, and 20 foam. My responsibilities have included conceptual design; 21 preparation of system design criteria, flow diagrams, procure-22 ment specifications, bid evaluation, and purchase recommenda-23 tions; vendor and Ebasco-generated drawing input, review and 24 drawing approval; supervision of installation; field verifica-tion and support; and turnover of the systems to clients.

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26 have also been involved in negotiations with authorities having 27 jurisdiction over fire protection, such as governmental

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1. authorities,. local authorities, insurance underwriters and own-2 ers. Some of my responsibilities.have included preparation of 3 Safety Analysis Reports, Fire Hazards Analyses, and Safe Shut-4 down Analyses in Case of Fire -- all performed in accordance 5 with various criteria issued by the Nuclear Regulatory Commis-6 sion (NRC), industry standards, National Fire Protection Asso-7 ciation (NFPA) standards and recommended practices. I have 8 provided technical assistance to a client during an NRC " walk-9 down" of a nuclear power plant's fire protection systems.

10 Q.3 Describe the professional services that you have pro-11 vided to Applicants for the operating license for the SHNPP and 12 the degree of involvement that you and your associates at 13 Ebasco have had in the development of the Harris fire protec-14 tion program.

15 A.3 Ebasco was retained by Applicants, in conjunction 16 with providing architect-engineering services, to develop the 17 fire protection program for the SENPP in accordance with NRC 18 regulatory requirements, insurance carrier's guidelines, indus-19 try standards and local authorities' requirements. I was as-20 signed as the Fire Protection Engineer for the SENPP in 21 September 1978. I was involved in the preparation of the Plant 22 Final Safety Analysis Report (ESAR) which included a detailed 23 Fire Hazards Analysis developed from the Preliminary Safety 24 Analysis Report. One year later I was assigned to be Fire Pro-25 tection Lead Engineer for the SENPP and was placed in charge of 26 1 the Pl' ant fire protection program within Ebasco's scope of

. 2 wor.k.. In January .1981.I.was promoted.to Supervisor of the 3 Ebasco Fire Protection Engineering Group, retaining responsi-4 bility for the SHNPP fire ~ protection activities. In this ca-5 pacity I was involved in the supervision of the fire protection 6 effort within Ebasco's designated scope of work, which included 7 prepara; ion of the Safe Shutdown Analysis in Case of Fire for 8 the SENPP (SSA), coordination of the interdisciplinary reviews 9 and comment resolution (including Applicant comments), provi-10 sion of fire protection features or justifiestions of devia-11 tions from separation criteria prescribed by the NRC, and the 12 complete final report preparation. FSAR Section 9.5.1 and Ap-13 pendix 9.5A, which describe the SHNPP fire protection program, 14 are Applicants' Exhibit  ; a summary of the SSA is Appli-15 cants' Exhibit .

16 Q.4 What is the purpose of your testimony?

17 A.4 The purpose of my testimony is to address the fiist 18 five allegations of Eddleman ContentLan 116, which can be stat-19 ed as follows:

20 (1) "The fire hazard analysis of section 9.5A (Appendix) in the FSAR does not 21 address the availability of control and power to the safety equipment."

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(2) "In establishing fire resistance rat-23 ings f fire barriers with respect to fires in cable trays, Applicants have not estab-24 lished that qualification tests represent actual plant conditions or comparable con-25 ditions."

26 1 (3)'"Another vague statement is that barri-ers are used 'where practical' without 2 .. defining. practical or. stating.the criteria to decide where a fire barrier is or is not 3 practical (and what type of fire barrier is or is not practical). 9.5.1.1.1."

4 (4) "The ' analysis' of Appendix 9.5A does 5 not demonstrate, as 9.5.1.1.1 claims it will, the adequacy of other fire protection 6 measures in all cases. Rather, it esti-mates the BTU of combustible material, 7 smoke generation and removal rate from the area, gives usually a qualitative descrip-8 tion of some measures to mitigate or reduce fire effects, and assumes that the fire 9 will be promptly detected (usually, no analysis of location of detection instru-10 ments, etc.) and the fire brigade will re-spond rapidly and put out the fire, or the 11 automatic equipment will work. These as-sertions are made despite the time it takes 12 to get people into the containment and to the fire (not well analyzed). Further, the 13 ' analysis;' of what happens if the fire spreads is generally a rationalization that 14 it can't spread much, not an analysis.

See, e.c. ' Analysis of Effects of postu-15 lated fires'."

16 (5) "The effect of a fire in a Fire Area or Fire Zone with a combustible loading 17 greater than 240,000 BTU /sq. ft. doesn't get dealt with in realistic terms."

18 My testimony demonstrates that these five aspects of the fire 19 protection program for the SHNPP, which have been questioned by 20 Eddleman Contention 116, meet NRC regulations and are consis-21 tent with NRC regulatory guidance and NFPA and industry stan-22 dards, and, therefore, that there is no merit to any of these 23 allegations.

24 Q.5 What NRC regulations and regulatory guidance are ap-25 plicable to the fire protection program at the SNHPP?

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1 A.5 The applicable NRC regulations and regulatory guid-J2 ance.,for_the SHNPP: fire protection. program are: 10.C.F.R. Part 3 50 Appendix A, General Design Criteria 3 " Fire Protection"; 10 4 C.F'.R. 5 50.48 " Fire Protection"; 10 C.F.R. Part 50 Appendix R, 5 " Fire Protection Program For Nuclear Power Facilities Operating 6 Prior to January 1, 1979"; Regulatory Guide 1.70, " Standard 7 Format and Content of Safety Analysis Reports for Nuclear Power 8 Plants," Revision 3; NUREG-0800 " Standard Review Plan," Section 9 9.5 Fire Protection; and Branch Technical Position (BTP) -

10 Chemical Engineering Branch (CMEB) 9.5-1, " Guidelines for Fire 11 Protection for Nuclear Power Plants," dated July 1981.

12 Q.6 Were all of these regulations and guidance in effect 13 at the time the Harris FSAR was filed with the NRC Staff?

14 A.6 No. On June 26, 1980 Applicants filed the SENPP FSAR 15 with the NRC. 10 C.F.R. 5 50.48 and Appendix R to Part 50 16 became effective in February 1981 and NUREG-0800, which includ-17 ed BTP CMEB 9.5-1, was issued in July 1981.

18 Q.7 What major changes have been made to the SENPP fire 19 protection program since the FSAR was first drafted?

20 A.7 Applicants performed an SSA which was submitted to 21 the NRC on July 22, 1983 and was subsequently revised 22 October 11, 1983, February 24, 1984, and June 12, 1984. Appli-23 cants have reviewed the SHNPP fire protection program against 24 the requirements of Appendix R to 10 C.F.R. Part 50. As a re-25 sult of the SSA and Applicants' review of their program against 1

26 1 1

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l' Appendix R, additional changes were made to the SENPP design,

.2. including the .. addition -of suppression systems, fire barrier 3 wrap of cable tray and conduit and cable rerouting.

4 Q.8 Eddleman Contention 116 first alleges that the Fire 5 Hazard Analysis in FSAR Appendix 9.5A "does not address avail-6 ability of control and power to safety equipment." How do you 7 respond to that allegation?

8 A.8 The Fire Hazards Analysis in FSAR Appendix 9.5A does 9 not directly address availability of control and power cables 10 to safety related equipment. This is done in FSAR Subsection 11 9.5.1.2.2, " Fire Protection of Cables and Circuitry," FSAR Sec-12 tion 8.3, "Onsite Power Systems" and in Applicants' SSA.

13 Q.9 How do the above-referenced sections of the FSAR and 14 the SSA demonstrate the availability of control and power to 15 safety equipment necessary to shutdown the reactor in the event 16 of a fire?

17 A.9 As stated in ESAR Subsection 9.5.1.2.2, safety relat-18 ed cable trays and circuits are isolated or protected from the 19 effects of fire through the use of physical isolation, spatial 20 separation, non-combustible covering, fire prevention through 21 provision of automatic sprinkler systems, or any combination of 22 these methods to ensure. the integrity of essential electric 23 circuitry needed during the fire for safe shutdown of the plant 24 and for fire control. In this regard Applicants are complying 25 with the guidelines found in Appendix A to BTP APCSB 9.5-1 and 26

) . .

f 10 C.F.R. Part 50, Appendix R (unless the NRC permits a devia-1 2 tion from the requirements of Appendix R for a particular situ-3 ation). Also, as discussed in FSAR Section 8.3, Regulatory 4 Guide 1.75, " Physical Independence of Electrical Systems," was 5 used in the plant design. This regulatory guide addresses 6 methods acceptable to the NRC to ensure physical independence 7 of circuits and electrical equipment which comprise or are as-8 sociated with certain safety related power and protection sys-9 tems.

10 Furthermore, in accordance with Section C.5.6 of BTP CMEB 11 9.5-1, Applicants performed an SSA, which verifies that fire 12 protection features for structures, systems and components im-13 portant to safe shutdown, including control and power cables, 14 are protected so that one train of systems necessary to achieve 15 and maintain hot standby conditions from either the Control 16 Room or Emergency Control Station (s) is free of fire damage, 17 and that one train of systems necessary to achieve and maintain 18 cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from either the Control Room or 19 Emergency Control Station (s) is free of fire damage or can be 20 repaired.

21 Thus the information that Mr. Eddleman could not find in 22 FSAR Appendix 9.5A is described in other sections of the FSAR 23 and the SSA. It is my understanding that Mr. Eddleman has not 24 to this date identified any specific deficiency in the FSAR and 25 SSA analysis regarding the availability of control and power to 26 safety equipment.

r 1 Q.10 The second issue raised by Eddleman Contention 116 i.2 is an allegation that_"in establishing _ fire resistance ratings 3 of fire barriers with respect to fires in cable trays, Appli-4 cants have not established that qualification tests represent 5 actual plant conditions or comparable conditions." What fire 6 barriers are associated with a fire in a cable tray?

7 A.10 A fire barrier is a component of construction rated 8 by testing laboratories in hours of resistance to fire which is 9 used to prevent the spread of fire. Each Fire Area in the i 10 SENPP is enclosed with three-hour fire resistance rated barri-t 11 ers. In addition, certain cable trays within a Fire Area are

12 Protected by three-hour or one-hour fire resistance rated en-13 closures (envelopes), as identified in the SSA at Table 9.5B-3. i 14 Where a cable tray penetrates a fire barrier, penetration fire 15 seals, having a minimum fire resistance rating at least equiva-16 lent to the rating of the fire barrier, are installed as de- i 17 scribed in FSAR Subsection 9.5.1.2.2. l 18 Q.11 What are the industry standards established for de-19 termining the fire resistance rating of a fire barrier?

l 20 A.11 The test methods established for determining the 21 fire resistance rating of fire barriers are based on standard 22 fire tests performed in accordance with ASTM E-119, " Standard 23 Test Method for Fire Test of Building Construction and Materi-24 als"; NFPA-251, " Standard Methods of Fire Tests of Building 25 Construction and Materials"; Nuclear Mutual Limited (NML),

26 1 " Property Loss Prevention Standards'for Nuclear Generating Sta-2 tions,". Appendix A-14;. Underwriters Laboratories (UL) 263 " Fire 3 Tests of Building Construction and Materials"; and American Nu-4 clear In'surers Bulletin No. 5 " Standard Fire Endurance Test 5 Method to Qualify a Protective Envelope for Class IE Electrical 6 Circuits." ASTM E-119 describes methods of measuring and 7 specifying fire resistive properties of materials and 8 assemblies with the exception of ceiling construction and pro-9 tective combustible framing. Both NFPA-251 and UL 263 are sim-10 ilar to ASTM E-119, but include testing and acceptance criteria 11 for ceiling construction and protective combustible framing.

12 NML Appendix A-14 is a medified IEEE-634 " Standard Cable Pene-13 tration Fire Stop Qualification Test." This standard covers 14 tests of penetration fire seals when mounted in rated fire bar-15 riers. ANI Bulletin No. 5 describes methods of measuring and 16 specifying fire resistive properties of materials and 17 assemblies used to establish a protective envelope for safety 18 circuits, including redundant safety circuits in the same Fire 19 Area exposed to a fire originating either outside of the cable 20 system or inside the protective envelope and subjected to me-21 chanical impact damage (such as a fire hose stream). ,

22 Q.12 Describe the qualification tests associated with the 23 fire barriers with respect to fires in cable trays.

24 A.12 Tests for cable tray enclosures are described in ANI 25 Bulletin No. 5, excerpts of which are attacheti to this 26 Y . .

1 testimony as Attachment B. Penetration fire seals are tested 2 against the detailed testing requirements and acceptance 3 criteria set forth in NFPA-251, UL 263 and ASTM E-119, de-4 scribed above.

5 Q.13 How has it been established that the test methods 6 for determining the fire resistance rating represent actual 7 conditions likely to be encountered in the maximum credible 8 fire in any given Fire Area or Fire Zone?

9 A.13 Test methods for determining the fire resistance 10 rating of a fire barrier are based on an exposure fire repre-11 sented by the " standard time-temperature curve." The points on 12 the curve that determine its character are:

13 1000 F ( 538 C) at 5 min.

14 1300*F ( 704*C) at 10 min.

15 1550*F ( 843 C) at 30 min.

16 1700 F ( 927*C) at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 17 1850 F (1010*C) at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 18 1925 F (1053 C) at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 19 2000 F (1093 C) at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 20 2300*F (1260 C) at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or over 21 It is not the intent of the tests to simulate actual plant con-22 ditions likely to be encountered in the maximum credible fire 23 in any given Fire Area or Fire Zone, but rather, by the use of 24 the standard time-temperature curve, to exceed actual plant 25 conditions by use of the standard common " worst case" exposure 26 fire.

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1 Th'e standard time-tempe'rature curve'has been determined empirically. to.. represent a common '1 worst case" . exposure fire.

- - 2 3 Actual fire tests, conducted by the National Bureau of Stan-4 dards by burning to destruction a five-story and a two-story 5 brick, wood-joisted building loaded with waste lumber, produced 6 overall results in approximation to the standard time-7 temperature curve. Additional data were obtained by burning 8 various amounts of" materials in two fire resistive buildings.

9 By analysis of the data, a relationship of fuel loading that 10 will produce an exposure equivalent to the standard time-11 temperature curve for a specific duration has been approximated 12 and reported in Table 6-8A of the National Fire Protection As-13 soc'iation's Fire Protection Handbook (14th Edition-1976). For 14 a three-hour period, a combustible load of 240,000 BTU /sq. ft.

15- yields a fire severity approximately equal to that indicative 16 of the standard time-temperature curve over a corresponding pe-17 riod.

18 The Fire Hazards Analysis presents the combustible load 19 for each plant Fire Area. The combustible loading in all Fire 20 Areas in the SHNPP power block is less than 240,000 BTU /sq. ft.

21 Thus, a fire barrier tested to withstand a fire based on the 22 standard time-temperature curve will resist a fire from the 23 maximum calculated combustible loading in any Fire Area in the 24 SHNPP power block.

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1 1 "Q.14 What independest tests'are conducte'd to-ensure-that

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-2s themfirez. resistance. rating.of. fire-barriers..for cable trays for .

3 the SENPP meets the established standards?

14 A.14 Test methods and acceptance criteria are standard-

~5 ized and are detailed in documents such as ASTM E-119, NFPA-6 251,'UL 263, NML Appendix A-14, and ANI Bulletin No. 5 (all 7 mentioned earlier). For each fi re barrier for cable -trays that 8 will be used in the SENPP, a qualification test -- in accor-9 de.nce with the test methods and acceptance criteria referenced 10 above -- will be performed on a " generic assembly" of that fire 11 barrier by an independent laboratory. Tests are conducted by 12 independent laboratories such as Underwriters Laboratories,- In-13 dustrial Testing Laboratories, Southwest Research Institute, 14 and Portland Cement Association on various generic assemblies 15 in accordance with the applicable standards to establish fire 16 ratings. Installation of fire barriers at SENPF will be in 17 accordance with the testing laboratory recommendations to en-18 sure that the actual installed fire barrier conforms to the 19 configuration of the tested assembly.

20 Q.15 The third issue raised by Eddleman Contention 116 is 21 that FSAR Section 9.5.1.1.1 contains the " vague statement" that 22 "[ fire] barriers are used 'where practical' without dqfining 23 ' practical' or stating the criteria to decide where a fire bar-

.24 rier is or is not practical (and what type of fire barrier 25 should be used)." How are fire barriers used in the Harris 26 fire protection program?

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1 A.15 Fire barriers are used to separate Fire Areas to re-2 duce the possibility-of fire-related damage to redundant 3 safety-related trains of equipment and to isolate safety-4 related systems from hazards in nonsafety-related areas.

5 Q.16 How is the determination made as to what the fire 6 resistance rating of each fire barrier should be?

7 A.16 Fire Areas are bounded by barriers with construction 8 that provide a minimum three-hour fire rating or equivalent, 9 regardless of the combustible loading. In 95% of the Plant 10 Fire Areas, the combustible loading is less than 240,000 11 BTU /sq. ft. Fire Zones within Fire Areas may be bounded en-12 tirely or partially with barriers having a three-hour fire rat-13 ing or less. As a generally accepted fire protection practice, 14 each combustible fire loading increment of 80,000 BTU's/sq.ft.

15 indicates the need for an additional one hour of fire rating 16 for the barrier. The use of fire barriers in the SHNPP is de-17 scribed in detail in FSAR Section 9.5.1.2.2 and Appendix 9.5A.

18 Q.17 Are there any circumstances where it has been deter-19 mined that defined Fire Areas could not " practically" be sepa-20 rated by properly rated fire barriers at SHNPP?

21 A.17 In one instance a Fire Area is not bounded by a fire 22 barrier on all cides -- the emergency diesel generator rooms 23 have large intake openings required for diesel operation. With 24 that one exception all defined Fire Areas are separated by a 25 properly rated fire barrier.

26 1 Q.18 The fourth issue raised by Eddleman Contention 116 2 is a generalized criticism-of-Appendix 9.5A of the FSAR, 3 claiming that Applicants have not demonstrated "the adequacy of 4 fire protection measures in all cases." Contention 116 finds 5 fault with the " estimates" of the BTU content of combustible 6 material, smoke generation and removal rates, measures to re-7 duce or mitigate fire effects, detection capability and fire 8 brigade response and effectiveness. In this regard, please de-9 scribe in general the Fire Hazards Analysis.

10 A.18 The SENPP fire protection program has been designed 11 to allow the plant equipment to maintain the ability to perform 12 safe shutdown functions and to minimize radioactive releases to 13 the environment in the event of a fire. The effectiveness of 14 the fire protection program is verified through the Fire Haz-15 ards Analysis by evaluation of fire hazards, postulation of re-

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16 alistic potential fires, and assessment of effects of these 17 fires in Fire Areas throughout the plant. The Fire Hazards 18 Analysis is found at FSAR Appendix 9.5A.

19 The purpose of the Fire Hazards Analysis is to demonstrate 20 that fire protection measures, suitable for control of the area 21 hazards, have been provided. In performing the analysis, the 22 f 11 wing considerations were addressed: spread of fire; 23 potential extent of damage to essential equipment, loss of 24 s fety function, and/or radiological release to the environ-25 ment; containment of the fire and its consequences within the 26

l 1 considered Fire Area, and/or effect on other Fire Areas; provi-2 sion of detectors to sense area fire or smoke conditions for 3 prompt fire control response; effective use of manual fire con-4 trol equipment and backup systems; smoke removal to permit per-5 sonnel to enter the Fire Area, assess the fire condition, and 6 use manual equipment; effects of smoke and heat damage from the 7 postulated fire on required operation of essential equipment in 8 the area; protection of redundant systems, equipment or trains, 9 if located in the same Fire Area, to maintain operability; and 10 separation or isolation of redundant equipment.

11 The Fire Hazards Analysis for the SENPP demonstrates that 12 adequate fire protection measures are available in each Fire 13 Area or Fire Zone analyzed. I disagree with the fourth issue 14 raised by Eddleman Contention 116 because the combustible load-15 ing for each Fire' Area is estimated conservatively; the smoke 16 removal rates are based on NRC recommendations; the measures to 17 reduce or mitigate fire effects are described in considerable 18 detail and are of demonstrated effectiveness; and fire detec-19 tors to be utilized are proven decigns. As discussed in Appli-20 cants' Testimony of David B. Waters, the fire brigade will be 21 well-trained, adequate in numbers and well-equipped to fight 22 fires.

23 Q.19 You have referred to Fire Areas a number of times in 24 y ur testimony. How are Fire Areas defined?

25 26 1 A.19 The Fire Areas were established based-on the nature

. , l2_ ofcoccupancy of the plant space, the amount and distribution of l

3; combustible materials within the area, and the-location of-

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4 safety-related systems and equipment. Areas important to the 5 Plant's capability for safe shutdown, such as electrical pene-6 tration areas, cable. spreading rooms, diesel generator areas, 7 switchgear and battery rooms, were designated as Fire Areas.

8 other Plant areas were designated as Fire Zones within the Fire 9 Areas to facilitate the Fire Hazards Analysis and to ensure 10 adequate fire protection features are distributed within a Fire 11 Area as required by-potential hazards present in each Fire 12 Zone.

13 Each Fire Area is bounded by barriers with construction 14 that provide a minimum three-hour fire rating (with the one ex-15 ception of the emergency diesel generator rooms, described pre-16 viously).

17 For each designated Fire Area, the Fire Hazards Analysis.

18 evaluates separately the occupancy, boundaries, combustible 19 1 ading, control of hazards, fire detection, access and initial 20 response, fire suppression systems, Fire Area fire fighting 21 equipment, and the effects of postulated fires.

22 Q.20 How is the combustible loading of a Fire Area deter-23 "i"*d?

24 A.20 The severity of fire that may develop and the damage 25 that may result in the most extreme case in a Fire Area is a 26 l

e r 1 function of the amount of combustibles present and the total 2 heat of combustion generated. As combustibles in an area are

_ _ _ _ 3 not point-source concentrated, a more realistic measure of the 4 relative fire hazard or exposure to fire damage of an area is 5 determined by spreading this combustible loading over the floor 6 area of the space or, in the case of a localized concentration 7 of combustibles, over the floor area within the sphere of in-8 fluence of the postulated fire.

9 The configuration of fire loading varies from area to 10 area. Some areas are devoid, or essentially so, of combustible 11 materials; other areas contain one or more localized fuel con-12 centrations, spatially separated from each other. A localized 13 concentration of combustible material is delineated by finite 14 parameters beyond which the fire loading is sharply reduced.

15 Examples of local fuel concentrations considered include cable 16 insulation in Motor Control Center units or electrical cabi-17 nets, charcoal beds in filter housings, oil in equipment reser-18 voirs, waste materials in containers or on skids, and similar 19 items. Linear concentrations of combustibles are usually asso-20 ciated with cable trays either solely within the Fire Area or 21 extending through several Fire Areas by penetration of inter-22 vening fire barrier walls.

23 To simplify the calculation of area combustible loadings, 24 conservative calorific values, based on the Fire Protection 25 Handbook, were adopted for classes of combustible materials 26 9

1 which were representative of heat values of specific materials 2 grouped within the. class. These include:

3 ordinary Combustibles 8,000 BTU /lb.

4 Combustible or Flammable 20,000 BTU /lb. (108,000 Liquids BTU / gal.)

5 Charcoal 10,000 BTU /lb.

6 (Combustible loading for minor amounts of grease, integral with 7

equipment, not exceeding one pound each, was not inventoried 8

since it does not create a significant fire hazard.) Using man-9 ufacturer's data on cable construction of typical cables used 10 in SENPP and the BTU content of the insulation materials, BTU 11 values were derived for each running foot (RF) of 24 in, wide y 12.

cable trays, as follows:

13 Power 180,000 BTU /RF 14 Control 157,000 BTU /RF 15 Instrumentation 95,000 BTU /RF 16 These values were adjusted proportionally for trays of differ-17 ent widths. All cable trays were considered to be 40% loaded, 18 the maximum design loading of a cable tray.

19 The combustible loading for all cables routed in conduit, 20 cast concrete trenches, or contained within metallic cabinets 21 or consoles was not inventoried since they do not create a fire 22 hazard, as recognized by good fire protection engineering prac-23 tice.

24 In addition to the combustibles normally present in an 25 area, an inventory of " transient" combustibles which might 26 1 realistically be introduced into areas as a part of planned 2 operation.was incorporated in.the Fire Hazards Analysis for 3 each Fire Area and Fire Zone. In most cases, the introduction 4 of transient combustible materials into areas where such mate-5 rial may expose safety-related equipment will coincide with 6 scheduled station maintenance. Combustible materials that may 7 be introduced in quantities sufficient to require special at-8 tention include: construction materials, such as scaffolding, 9 shoring, forms, etc (although in the power block such materials 10 will be limited to fire retardant wood); resins in bulk quan-11 tities and associated packaging materials; charcoal; combusti-12 ble liquids, such as lubricating oils and paints; grease (oil 13 in solid state); plastic bags and protective sheeting; 14 packaging materials and containers, such as plastics, wood, 15 paper, etc; flammable liquids and gases, such as solvents and 16 volatile fuels; rags; and anti-contamination clothing.

17 The quantity, movement, use and handling of all such mate-18 rials as well as the provision of supplemental fire protection 19 measures are administratively controlled in the plant through 20 written procedures. For this reason, the fire loss exposure 21 resulting from the addition of transient combustibles in an 22 area during these periods of increased plant surveillance, 23 strict procedural control and augmented area manning has been 24 considered as being no greater than that from the inventories 25 f n ntransient combustibles normally present in each area, 26 except for the periods of major plant outages.

.l 1 After the conservative inventory _of all combustible mate-2 . . .: ,

.2. . rials;Jn;a, Fire Area, total,.B,TU and BTU.,per sq. ft. values were-3 calculated and then summed to indicate the total combustible

.4^ fire loading for the Fire Area. The calculated combustible.

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5 fire loading of a Fire Area was then used to compare the area 6 fire hazard relative to those of other Fire Areas, to judge the 7 adequacy of the area boundary fire barriers, and to verify the 8 proper selection of adequate fire control and suppression sys-9 tems and equipment.

10 Q.21 What conservatisms are built into this analytical 11 process?

12- A.21 In determining the hourly rating of fire barriers in 13 the SENPP power block, complete combustion of all. combustibles 14 is assumed and no credit is taken for the lack of continuity of 15 combustibles. Nor is it assumed that automatic or manual fire 16 suppression systems will limit the extent of a fire. A fire 17 barrier hourly rating is selected for a combustible loading in 18 excess of that determined in the_ conservative calculation.

19 Q.22 Are smoke generation and removal rates " estimated" 20 in the Fire Hazards Analysis as alledged in Contention.ll6?

21 A.22 No. Smoke generation rate is not estimated; the.e 22 are too many variables to determine what an average or even 23 w rse case smoke generation rate should be. Nor is smoke *e-24 m val rate " estimated." It is assumed to be 1.5 cfm/sq.ft. of 25 fl r area for the most severe combustible loaded area in the 26

1 power block (cable spreading area) based on the capability of 2 the HVAC system.- .This is consistent with BTP APCSB 9.5-1, Ap-3 pendix A. Where less than the most severe combustible loading 4 is present, a minimum assumed smoke removal rate is obtained by 5 dividing the combustible load of the analyzed Fire Area by that 6 maximum loading and multiplying by 1.5 cfm/sq.ft. to obtain the 7 proportional cfm/sq.ft. required. This may be considerably 8 less than the actual capability of the HVAC system.

9 Q.23 What measures are incorporated into the fire protec-10 tion program "to reduce or mitigate fire effects?"

11 A.23 A number of defense-in-depth passive and active fire 12 protection features / measures have been provided to reduce the 13 fire effects on the Plant safe shutdown in case of fire and 14 fire damage to all Plant areas. These measures include limita-15 tion of the amount of transient combustible materials, '

16 utilization of fire-resistive construction, provision of fire-17 breaks and fire penetration seals in cable trays, utilization 18 of IEEE 383 cable (which has a low fire propogation rate), and 19 installation of fire detection systems and automatic fire ex-20 tinguishing systems. These measures follow the fire protection 21 guidelines issued by NRC and are described in the Fire Hazards 22 Analysis and in the SSA in detail -- not just in a "qualita-23 tive" manner as alleged in Contention 116. The Fire Hazard 24 Analysis constitutes a realistic and thorough assessment of the 25 nature of fires, the effects of fires and the ability to 26 c ntrol fire in the various Fire Areas of the SHNPP.

. o 1 Q.24 What fire detection systems are provided for each

2. Fire _ Area? . .

3 A.24 Three different types of fire detectors will be used 4 in the SHNPP: ionization detectors, thermal detectors and ul-5 traviolet flame detectors.

6 Ionization detectors utilize a small amount of radioactive 7 material which ionizes the air in a sensing chamber, thus ren-8 dering it conductive and permitting a current flow through the 9 air between two charged electrodes. This gives the sensing 10 chamber an effective electrical conductance. When smoke parti-11 cles enter the ionization area, the conductance of the air is 12 decreased because the smoke particles attach themselves to ions 13 causing a reduction in mobility. When the conductance is less 14 than a predetermined level, the detector responds.

15 Thermal detectors operate on the rate of rise / fixed tem-16 perature principle. Thermal detectors respond when the temper- -

17 ature rises at a rate exceeding a predetermined amount or 18 reaches a temperature set-point. Thermal detectors are an in-19 tegral part of the fire suppression system and actuate sprin-20 kler systems when a fire is detected.

21 Ultraviolet flame detectors use a Geiger-Mueller gas type 22 cathode tube designed to detect flame radiated rays at the ex-23 treme low end of the radiation spectrum.

24 The Fire Hazards Analysis of each Fire Area discusses the 25 types of fire detectors in each area.

26 s

'1 ?

Q.25 How were'these detection ~ systems' selected? ,

/c , ., , sJ 2' a, c A'25,. The S.HNPP detection, systems wer.e selecte'd to ,

3 optimize early. warning of a fire condition in its incipient 74 stage.and thus to ensure ~ timely fire brigade response. For 5 this reason ionization' type smoke detectors were selected as 6 the principal detection system. These' detectors respond to the 7 first traces of fire in the form of visible smoke or invisible 8 products of combustion. Heat or flame is not required to acti-9 vate the detector.

10 In locations additionally protected with automatic wa.ter-11 type suppression systems utilizing temperature actuated fusible 12 link sprinklers and dry piping (preaction and multi-cycle) 13 sprinkler systems, thermal detectors are used to initiate 14 actuation of the suppression system. These detectors have a 15 temperature set-point approximately 30*F above environmental 16 conditions to preclude inadvertent operation, but below the 17 temperature required to open the fusible link sprinklers.

18 Thus, the detectors will alarm and initiate suppression system 19 actuation, allowing water'into the system piping before any 20 sprinklers open to discharge water on the fire.

21 For several specific applications such as the diesel gen-22 erator building and the fuel oil pump area, ultraviolet flame 23 detectors are utilized. These detectors are used primarily 24 where anticipated fires will develop quickly with little or no 25 incipient or smoldering stage and where ignition is almost 26 instantaneous.

_ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ . _ _ _ . ______._______m_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _

l 1 .Q.26 Wha't provisions are made for the SHNPP response to a 2 fire?, ,

3 A.26 A trained fire brigade will be available on each I

4 shift to respond to any fire event. A fire brigade response 5 time of approximately 5-15 minutes is expected for most fire 6 events within the power block.. The SENPP fire brigade, its'ca-7 pabilities and its training are described in Applicants' Testi-8 many of David B. Waters.

9 Q.27 What automatic fire suppression systems have been 10 provided in SENPP?

11 A.27 Wet pipe sprinkler systems are the basic industrial 12 automatic water suppression systems. This type of system uti-13 lizes water-filled piping with closed sprinkler nozzles which 14 open one at a time when subjected to a predetermined tempera-15 ture through the use of fusible links. Where the area 16 protected by an automatic suppression system contains equipment 17 that could be damaged by inadvertent activation of sprinklers, 18 variations in the wet pipe sprinkler system have been developed 19 with applications in nuclear plants. The automatic suppression 20 systems that will be installed in the SHNPP include the follow-21 1"9:

22 1. Pre-Action Sprinkler Systems 23 The pre-action sprinkler system consists of the same pipe 24 and sprinkler arrangement as the wet pipe system, except that 25 n rmally the sprinkler pipes contain no water and an 26 i

l 1 electro-mechanical valve is inserted in the. water supply pipe

_ 2 to..the.. system. ,A two-step release mechanism is employed to 3 Prc:lude inadvertent operation or water discharge due to me-4 chanical damage to the piping system. Thus, under non-fire 5 conditions, mechanical damage to the piping system would not 6 result in water discharge since the electro-mechanical valve 7 would not have opened.

• Under fire conditions, thermal fire de-8 tectors sense the condition and electrically signal the 9 electro-mechanical valve to open. This permits water to pass 10 into the sprinkler piping before a temperature sufficient to 11 open the fusible link sprinklere is reached. The system, in 12 this mode, is now the basic wet pipe sprinkler system awaiting 13 a temperature increase from the developing fire to initiate 14 sprinkler water discharge.

15 This system will be installed in the areas shown in FSAR 16 Table 9.5.1-3, which are primarily cable loaded areas and ordi-17 nary combustible loaded areas where general sprinkler coverage 18 on an area-wide basis is provided.

19 2. Multi-cycle Sprinkler Systems 20 The multi-cycle sprinkler system acts in the same fashion 21 as the pre-action system up to the point water is discharged 22 from sprinklers. After activation, when the thermal fire de-23 tector senses a sufficient reduction in ambient temperature 24 indicating that the fire has been suppressed, a signal is 25 transmitted to shut the electro-mechanical valve and stop the 26

.25-

{

1 flow of water. The system continues to function in an on/off

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2 cyclical. mode,as dictated.by high or reduced temperature sensed 3 by the detectors. This added feature results in a much reduced 4 overall discharge in volume of water as compared to the wet or 5 pre-action systems and is used primarily in areas where consid-6 erations other than fire protection indicate an advantage to 7 reducing the overall quantity of water which must be disposed 8 of after fire suppression has occurred. Multi-cycle sprinkler 9 systems are installed in the areas shown in FSAR Table 9.5.1-4, 10 including containment, diesel generator day tank enclosures and 11 diesel oil pump rooms.

12 3. Water Spray Systems 13 The water spray system is designed and acts in a fashion 14 similar to the pre-action system, except that open spray noz-15 zles or sprinklers are utilized in lieu of closed, fusible link 16 activated sprinklers. This provides for immediate water dis-17 charge on the entire protected area when the system is acti-18 vated by thermal detectors. This immediate deluge is 19 advantageous in quickly suppressing fires with a potential for 20 rapid spread or rapid development of high heat release. Water 21 spray systems are used to protect areas in the vicinity of cer-22 tain equipment and transformers as detailed in ESAR Table 23 9.5.1-5.

24 Q.28 What design considerations went into the establish-25 ment of the fire suppression systems?

26 1 'A.28 The type, coverage, actuation and supervision of 2 fire suppression systems provided in each Fire Are: is de-3 scribed in the Fire Hazards Analysis. The role of automatic 4 suppression is to ensure suppression and to extinguish a fire 5 condition, regardless of the fire brigade response, where con-6 siderable combustible loading is present. The selection of the 7 particular fire suppression system, mode of operation and per-8 formance criteria is based on the fire hazards found in the 9 area, the realistic fire expected and the overall fire control 10 approach utilized for containment of the fire.

11 Q.29 What additional fire fighting capability has been 12 provided for use by the fire brigade?

13 A.29 Each area of the SENPP can be reached by at least 14 two fire hose streams. In addition, there will be a fire en-15 gine on site ready to respond immediately to a fire event. The 16 capability of the fire brigade is discussed in more detail in

17. Applicants' Testimony of David B. Waters.

18 Q.30 In summary what does the Fire Hazards Analysis dem-19 onstrate regarding the potential effects of a fire at the 20 SHNPP? i 21 A.30 The Fire Hazards Analysis verifies the effectiveness 22 of the fire protection program by evaluation of fire hazards, 23 postulation of realistic potential fires, assessment of Plant 24 response to a fire and the effects of fires in Fire Areas 25 throughout the Plant. The Fire Hazards Analysis provides 26 l

i. ,;o ,_

i 1- assurance that fire protection facilities, suitable for control 2 of the area. hazards, have been provided.' In summary, the-Fire 3 Hazards Analysis demonstrates that the SHNPP can safely shut-4' down the reactor, maintain it in a safe shutdown mode and mini-5 mize radioactive releases to the environment even in the event l 6 of a fire.

7 Q.31 The fifth issue raised by Eddleman Contention 116 is 8 an allegation that "the effect of a fire in a Fire Area or Fire 9 Zone with a combustible loading greater than 240,000 BTU /sq.

10 ft. doesn't get dealt with in realistic terms." Is there any 11 Fire Area or Fire Zone in the Harris Plant with a combustible 12 leading greater than 240,000 BTU /sq. ft?

13 A.31 Yes. ,

Two Diesel Generator Fuel Oil Day Tank Enclo-14 sures (Fire Areas 1-D-DTA and 1-D-DTB), each have a combustible 15 loading of 2,920,000 BTU /sq. ft. (assuming total combustion of 16 3,000 gallons of diesel oil); Diesel Fuel Oil Storage Tanks A 17 and B (Fire Areas 12-D-TA and 12-D-TB) each have a combustible 18 loading of 17,500,000 BTU /sq. ft. (assuming total combustion of 19 175,000 gallons of diesel oil). For this calculation No. 2 20 diesel fuel oil with a BTU / gal. value of 140,000 is assumed.

21 Q.32 What provisions are made to deal with a postulated 22 fire in the diesel fuel oil day tank enclosures?

23 A.32 The diesel fuel oil day tank enclosures are each 24 isolated from other Fire Areas by three hour rated concrete 25 fire walls. Although the calculated combustible loading of the 26

1 enclosures are greater than 240,000 BTU /sq. ft., this calculat-

~

2 ed-loading.is' extremely conservative.since it.is based on the 3 total volume of oil in the enclosure. The only realistic way 4 to postulate combustion of the volume of oil ~in the fuel oil 5 day tank is-attendant to a rupture of the tank. The diesel 6 fuel oil day tank is a safety class 3, Seismic Category I com-7 ponent which is designed to remain functional after a Safe 8 Shutdown Earthquake. NRC regulatory guidance in the Standard 9 Review Plan (NUREG-0800, Section 9.5.1 BTP CMEB 9.5-1 1 C.l.b) 10 provides that " worst case" fires need not be postulated to be 11 simultaneous with nonfire-related failures in safety systems, 12 plant accidents, or the most severe natural phenomena. Even in 13 the highly unlikely event of a rupture of the diesel fuel oil 14 day tank followed by combustion, only a thin layer of oil would 15 actually be ignited in a fire. Furthermore in the event of 16 fire, an automatic multi-cycle sprinkler system would be actu-17 ated by thermal detectors to cool the oil below the ignition 18 point. If the thermal detectors or the valve automatic release 19 failed to operate, the sprinkler system could be actuated manu-20 ally. Finally, automatic fusible link fire dampers are pro-21 vided to the diesel fuel oil day tank enclosures to limit the 22 amount of air available to support continued combustion. All 23 of these design features in combination provide assurance that 24 in the highly unlikely event of a postulated fire in the diesel 25 fuel il day tank enclosures, the fire will be quickly 26 contained.

s- .,

I 1 .Q.33 What provisions are made to deal with a postulated

~

2 fire in the diesel fuel oil storage tanks?

3 A.33 Diesel fuel oil storage tanks A and B are installed

.4 underground in the yard area of the SHNPP, over 175 feet from 5 principal plant structures. The tanks are constructed of rein-6 forced concrete designed to seismic Category I requirements and 7 are lined with steel. The only access to the tanks is by a re-8 inforced concrete hatch. Each tank vent is supplied with a 9 flame arrestor to prevent flash-back of a flame into the tank.

10 Yard hydrants are located adjacent to the area to fight a fire.

11 For the reasons discussed above with respect to the diesel fuel 12 oil day tanks, a fire in the diesel fuel oil storage tanks is 13 extremely remote. However, in the unlikely event of a fire, 14 the physical location of the tanks away from plant structures 15 preclude any potential impact to safety related systems. The 16 emergency diesel operation would not be impacted by a fire in 17 the diesel fuel oil storage tanks since the day tanks contain 18 enough diesel oil to operate the emergency diesels.

19 Q.34 In your professional opinion are these measures ade-20 quate to protect the SHNPP in the event of a fire in the diesel 21 fuel oil day tank enclosure or diesel fuel oil storage tanks?

22 A.34 Yes.

23 Q.35 In conclusion, is the SENPP fire protection program 24 adequate to protect the public health and safety?

25 26 u _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ __----

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[1 (A.35;'Yes..

" ~

.2 ~ Q.36 Please summarize the principal reasons for'your con-

-jr fidence'in-the efficacy of the Harris fire protection program.-

10 ~ .A.36 I have confidence in the efficacy of the SHNPP fire 5 protection ~ program because of the " defense in. depth" concept 6: that has.been used in.the development of the program to ensure:

7 a) prevention of fire initiation through the' control, separation and guarding of sources of ignition; 8

b) prompt detection of fires or incipient fire condi-9' tions in areas containing safety related equipment or in i areas of high combustible loading which may expose safety 10 related equipment; 11 c) effective suppression of fires-to limit consequent damage and to reduce exposure to safety related equipment;.

12 d) confinement of-fires to their areas of initiation by 13 provision of fire barriers, spatial separation and segre-

.gation of combustibles; and s 14 l

1 e) separation of redundant safety related equipment to 15 maintain operational capability under postulated fire con-ditions.

l A rigorous Fire Hazards Analysis was conducted to verify the 17 efficacy of the fire protection program. A SSA was subse-l quently performed using even more stringent criteria than the l 19 l Fire Hazards Analysis. The results of the Fire Hazards Analy-20 sis and the SSA demonstrate that safe shutdown of the Plant is 21 assured.even in the event of a fire. Applicants have adopted

! 22 l

administrative controls, fire fighting procedures, fire brigade 23 training and measures for fire protection that supplement the i

24 l fire protection design features and provide added confidence in 25 the.SHNPP fire protection program.

26 h

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y , .: s , . . .

MARGARETA A. SERBAPESCU a

Principal Engineer EXPERIENCE SLM4ARY Principal Mechanical Engineer ~ with 19 years diversified e merience in engineering. and -design of fire protection, , plunbing , HVAC and waste treatment / water - pollution control systems of- fossil and nuclear . fueled electric generating stations and industrial projects including aoninistrative

- and/or technimi supervision of fire protection engineers, mechanical and/or -

buildings engineering designers. Responsibilities included developing- fire protection, plumbing and other .- mechanical water system designs and basic design criteria. Prepared system flow diagrams, calculations, input criteria for physical design drawings , economic . analysis of. equipment options, procurement specifications, purchase requisitions, bid evaluations, equipment selection studies and purchase recorvnendations. Supervised equipment installation, engineering coordination with other engineering disciplines, clients and authorities having jurisdiction. As senior enoineer, was assigned

' as Lead Fire Protection Engineer and was responsible for the design of an entin nuclear omer plant fire protection system / program including licensing support, manomer planning and coordination with other project arvas.

Prepared preliminary,' final and special safety analysis reports for nuclear fueled electric generation stations.

As Principal' Engineer continued as Lead Fire Pzbtection Engineer responsible for nuclear plant fire protection systems and programs, and prepared company fire protection standards. In January of 1981 was assigned to supervise the Fire Protection Engineering group and was responsible for ' technical and adninistrative fire protection engineering operations. Suoervised engineering, design and other activities on fire protection -systems for all nuclear and fossil projects in Ebasco's corporate offices, responsible for the development of comoany fire protection technical standa rds and standa rd specifications. Ensured these activities were perfomed in an efficient and timely manner, in accordance with company procedures / guides to provide a high quality product.

REPRESENTATIVE EXPERIENCE Client Project Size Fuel Carolina Power & Shearon Harris 900 MW Nuclear Light Company Nuclear Power Plant Westinghouse Pressurized Water j Reactor Unit Louisiana Power & Waterford SES 1165 MW Nuclear i Light Company Unit No. 3 l Combustion

! Engineering

! Pressurized Water

! Reactor Unit O

k-

c S

g 'g =,

MARGARETA A. SERBANESCO ,

REPRESENTATD'E EXPERIENCE (Cont'd)

Client- Project Size Fuel h shington Public #PSS Unit No. 3 1300 MW Nuclear

• Power Sucoly Combustion System Engineering Pressurized

- hter Reactor Taiwan Power Chimshan Unit 600 MW ea Nuclear Company Nos. 1 & 2 GE Boiling Water . -

Reactor Units Carolina Power Shearon Harris 900 MW ea Nuclear

& Light Company Nuclear Power Plant Units 1 & 2 -

Westinghouse Pressurized hter Reactor Units Iowa Public G Neal Unit No. 4 576 MW Coal Service Comoany Houston Lighting & Allens Creek Nuclear 1200 MW Nuclear Power Company GeneI1tting No. 1 General Electric Boiling hter Re-actor Unit Limestone Electric 750 MW ea Lignite Generating Station Unit Nos.1 & 2 Orange and Lovett Station 200 MW ea Coal Rockland Coal Conversion Utilities Inc. Unit Nos. 4 & 5 -

Florida Power & St Lucie Power 890 MW Nuclea r

& Light Co. Plant Unit No.1 and St Lucie Power 690 MW Nuclear Plant Unit No. 2 Combustion Engi-neering Pressurized hter Reactors

4/7 MARGARETA A SERBANESCU REPRESENTATlVE EXPERIENCE (Cont'd)

. Client Project Size Fuel Comision Federal Laguna Verde 675 MW ea Nuclea r de Electricidad Power Plant Unit de Mexico Nos.1 & 2 General Electric Boiling hter Reactor Reactor Consolidated Arthur Kill Unit 200 MW/ 011 to Edison Company Nos. 2 & 3 300 MW Coal Re-of New York Respectively conversion Knolls Atomic Knolls Facilities -

Nuclear Power Laboratory Modification i Program Clark 011 and Feasibility Study ,

Synthetic Refining Corp. of Producing Gasoline f rom Coal Arkansas Pmer & Coal to Medium - Synthetic Light Co. Stu Gas HNO Synfuels The River Plant -

Synthetic Company, Texas Coal to Methanol Inc.

Virginia Electric Surry Unit Nos. 3 & 4 950 MW ea Nuclear and P>er Co. Babcock & Wilcox Pressurized Water l Reactor Units l l

Power Authority Astoria Unit No. 6 830 MW Oil of the State of New York Greene County 1300 MW Nuclear Nuclear Pmer Plant Babcock &

Wilcox Pressurized hter Reactor Unit Electra de Santillan Nuclear 1100 MW Nuclear Viesgo, SA Spain P>er Plant

'a w l, j r

4 MARGARETA A. SERBANESCU REPRESENTATIVE E'XPERIENCE (Cont'd) t '-

Client Project Size Fuel People's Repuolic Shibeng Pm er 300 MW Coal of China Plant Huai-Nan Power 600 MW Coal Plant.

Ebasco Nuclear Standard- 1200 MW Nuclear ization Programs GE Boiling Water Reactor Unit , Com-bustion Engineering Pressurized Water Reactor Unit,' West-inghouse Pressurized Water Reactor Unit Ebasco Coal-Fired Reference 400 MW Coal Plants 600 MW Coal.

800 MW Coal E WLOYE NT HISTORY Ebasco Services Incorporated, New York, NY; 1978-Present o Principal Engineer - Supervisory Function,1/81-Present

- Lead Engineer 7/80-1/81 o Senior Engineer - Lead Engineer 1/79-7/80

- Support Engineer 7/78-12/78 Stone and Webster Engineering Corporation, New York, NY; 1973-1978 o Engineer in Pmer  !

Hydrotechnic Corporation, New York, NY; 1969-1973 o Mechanical Design Engineer Spotnails, Incorporated, New York, NY; 1966-1969  ;

o Mechanical Draf tsman - Designer i

Interzoo, Caserts , Italy; 1965-1966 l

e r

, -"s' o ,;

. 1 MARGARETA A. SER8ANESCU.

EDUCATION Polytechnic Institute of Bucharest, Master of Mechanical Engineering - 1965 Trene Eoucational Division, Trane Air Conditioning Clinic - Completed Course PROFESSIONAL AFFILIATIONS National Fire Protection Association - Member e

5 e

0 59 L

j APPDOIX B a * *

(Excorpto from ANI Bitlletin No. 5) 3.1 SCOPt & PURP0tt '

2.1 The purpose of this test is to qualify for insurance purposes a preteettve tavelone for Redundant Class If Cables in Nuclear Power F1 ants when locates In the same rtre area.

as.that portion of a building that is encompa(A fire area is eeffnedssed by r c6111ns: and fleers.) The maintenance of circuit integrity in these Class !! safety circuits during a postulated fire is of prime importance.

2.2 The intent of this Test Method is to establish a protective' envelope that maintains circuit integrity for safety circuits when:

---Redundant safety circuits, located in the same fire arm, are aposed to a fire outside of the cable syste, or

---Redundant safety circuits, located in the same fire area, are aposed cable by a fire syste, or originating in an adjacent " protected-in-place"

---Redundant safety circuits, located in the same fire arm, are subjected to mechanical impact damage as simulated by a hose stream, or other impact test.

3.0 ggPTANCE CRITERIA AN!/M4tRP Acceptance will be based on the completion and review of 1_1, of the following: 1 3.1 Successful passage of fire tests, as outlined in section 3.4 of this test method, and suba'ttal of necessary test documentation as prepared by a recognized testing laboratory;or consultant.

3.2 A Quality Control / Quality Assurance Program for the systa/ design should be submitted for review. Complete details covering installation procedures, physical characteristics, identification methods, sample foms for third party sign-off, etc. shpid be included.

The QC/QA Program is considered an integral part of the acceptance process and variations between the QC/QA Program fop.the, test and the program developed.fo,e the actual installation wt11'not be acceptable, j i

3.3 tion All ofmaterials andbecomponents the cable shall in the completed rated as non-combustible with the acep-syste,i e Puel Contributed,,and Smoke Developed ratings of 25 or less.. ., Flame Spread Materials or components that are combustible or hazardous during the installation phase, should have a material hazard analysis performed with procedures developed for quantities on hand, storage practices, and precautions to be taken during installation.

4 i

. .. 4 3.4 The Cable Protective Envelope shall be exposed to the followfnp ffre endurance and hose stream tests. Test configuration and dotat s should he submitted for review and comment prior to test.

3.4.1 Test ! - Eanesi re Fire - The Protective Envelope shall be exposed go the standart temperature-time curve found in ASTM E-11g-76 (ANSI A2.1) for a minimum of one hour. Sketch i 1 outlines a sueseste4 test conffguration.

3.4.1 Mose Stream Test - !anedtately followine Test !. accessible sur-races of the Protective Envelope shall be subjected to one of the following hose stream tests. The hose stream shall be app 11ed for a sinfmum of 21/2 minutes, without de-energizing the circuits.

PROPER SAFETY PRECAUTIONS SHALL BE EXERCISED. One of the follow-ing tests shall be used:

1. The stream shall be delivered through a 21/2 inch national standard playptpe equipped with 11/8 inch tip, nozzle pressure of 30 psi located 20 feet from the syste. .

er

1. The stream shall be delivered through a 11/2 inch nor:1e set at a dfscharge angle of 30' with a nozzle pressure of 75 p:1 and a sintmum discharge of 75 gpa with the tip of the nozzle a maximum of 5 ft. from the system.

er

3. The stream shall be delivered through a 11/2 inch nozzle set at'a discharge antle of :,5' with a nozzle pressure of 75 psi and a min'aum discharge of 75 gem with the tip of the nozzle a maximum of 10 ft. from the system. -

N0ft #1 is the preferred test.

3.4.3 "est "" - Internal Fire - For systems / designs that require heat us actvate the Protective Invelope, the system shall also be subjected to Test !! - Internal Fire. Sketch it outlines a 3g311g( test conffguratfen.

3.4.4 Cable Construction & Test Details -

3.4.4.1 Cables shall be energfred for circuit monitoring durine Test Method !. For the purpose of thfa test method, 'onergfzed' means sufffcf ent current to nonf ter fa11ure.

8

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3.4.4.2 Cable constructions shall be representative of cable used at the site. Cable tray loadings shall be in ace-ordance with suggested test layouts.

3.4.4.3 In both test methods, cable tray construction shall be representative of actual site conditions, where applicable.

3.4.4.4 Cable systen supports shall be those currently found in nuclur power plants and follow accepted installation procedures. Care should be exercised in using only supports that are necessary for the test. Supports that are used for the Protective Envelope shall be part of the final installed design.

3.4 4.5 Thermocouples shall be located strategically on the surface and at one foot intervals in the cable system and temperatures recorded throughout the test.

3.4.4.8 shall be acceptable to Fire stops American or breaks Nuclear if used,ilure Insurers. Fa of the fire stop or break shall not necessarily constitute a failure of the the Protective Envelope.

3.5 The tests shall be constituted a failure if any of the following occur:

1. Circuits fail or fault during the fire test as required in Test I or fail during the hose stream test.

2. Cotton wate in Test !! ignites during the test period.

3.8 The minimum fire endurance ratinc acceptable for Test ! shall be one hour. If longer ratings are des' red, they shall be in one hour increents, such as 2 hr. and 3 hr. ratings. ,

4.0 FINAL ACCEPTANCE , .

Prior to any installation at plants insured by American Nuclur Insurers, or Mutual Atomic Energy Reinsurance pool, complete plans outlining system

, to be installed location, etc. shall be submitted for review and acceptance.

JtA,Y.1979 .

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2 7/79 '!

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SUGGESTED TEST LAYOUT - TEST ETH00 2 INTERNAL FIRE TEST yx&:_ MM" ML : = ^

CABLE PROTECTIVE ENVELOP' COTTON (OPEN AT BOTH ENDS)

WASTE t

6" g -~ _ , + %ww.e_ m : n ~

• s W 4 i

4 6m 7 NOTE 1: COTTON WASTE SHALL BE PLACED OVER THE ENTIRE TOP SURFACE OF THE TEST. SYSTEM AND A SAMPLE SYSTEM 6 INCHES BELOW THE TEST SYSTEM.

NOTE 2: THE CABLES USED IN THE TEST SHALL BE REPRESENTATIVE OF

- THE CABLE USED AT THE SITE. LOADINGS SHOULD BE 205 FILL WITH RAND 0M LAY.

THE CABLES IN THE TRAY SHALL BE IGNITED USING THE "0IL SOAKED BURLAP" METH00 AS OUTLINED IN IEEE/ICC/WG 12-32. '

DATED 6/27/73, OR OTHER ACCEPTABLE " FLAME SOURCE",

DEPENDING ON DESIGN AND OPERATING CONDITIONS OF THE C0ATING. THE FLAME SOURCE SHALL BE LOCATED AT THE MID- l POINT OF THE CABLE SYSTEM. THE INTENT BEING TO PROVIDE i AN IGNITION / FLAME SOURCE THAT IS DESIGNED TO LAST APPR0XI- l MATELY 20 MINUTES AND ACTIVATE THE PROTECTIVE ENVELOPE.

CBSERVATIONS AND THERM 0 COUPLE READINGS SHALL BE MAINTAINED

. FOR ONE HOUR FROM THE POINT OF IGNITION OF THE " FLAME SOURCE". .

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, J. e , 7/79 l

. SUGGESTED TEST LK/0UT - TEST METHOD 1- l EXPOSURE FIRE TEST CABLE PROTECTIVE ENVELOPE (Note 1.l j/ f \yFIRE STOP o , ,

• I I I l l

A FIRE ~STOP g , , ,

E

= TEST j OVEN l l l l d I i i I i l iI I HORf70NTAL RUN l l l

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<re gu err gw FRONT VIEW END VIEW (N0 SCALE)

NOTE 1: TWO PROTECTIVE ENVELOPES TO BE TESTED. ONE LOADED TO MAXIMUM {40%)

DESIGNANDONELIGHTLYLOADED.(ONELAYER)'. .

SUFFICIENT CIRCUITS TO BE MONITORED TO DETECT FAILURE; CIRCUIT TO l CIRCUIT, CIRCUIT TO SYSTEM, OR CIRCUIT TO GROUND.

VARIOUS TYPES OF CABLE; SUCH AS POWER, CONTROL AND INSTRUMENTATION.

CABLE SHOULD NOT EXTEND MORE THAN THREE FEET OUTSIDE THE TEST OVEN.

NOTE 2: DUE TO FURNACE DESIGN, IT MAY BE NECESSARY TO ENTER AND EXIT THE FURNACE ON THE TOP OR THE SIDE.

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