ML18163A429

Comment Disposition_Nei

ML18163A429
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/17/2018
From:	Joseph E Pollock Nuclear Energy Institute
To:	Office of Nuclear Regulatory Research
G. Taylor 415-0781
Shared Package
ML18163A423	List: ML18163A424 ML18163A429 NRC-2018-0040, Firstenergy - NRC-2018-0040
References
83FR9334, NRC-2018-0040 SAND2018-0706 O, Draft 0002
Download: ML18163A429 (4)

Text

REVIEW / COMMENT DOCUMENTATION Commenter: Joseph E. Pollock Phone: 202.739.8114 Document #, Rev: SAND2018-0706 O, DRAFT 0002 Aluminum High Energy Arc Fault (HEAF) Particle Size Discipline/Department: Nuclear Energy Institute Date: 5/17/2018 Title: Characterization Test Plan - DRAFT

• CLEARLY STATED AS A MATTER OF FACT (OR A SPECIFIC QUESTION)

• COMPLETE AND INCLUDE A REFERENCE TO THE AFFECTED DOCUMENT Comments shall be:

• LEGIBLE AND REPRODUCIBLE

• FOCUSED TO A SPECIFIC PROBLEM OR DEFIENCY The majority of the document submitted by NEI were not related to the small-scale test plan as noticed in the Federal Register. Only those comments under the Detailed Comments on Test Plan section are included as part of this comment resolution.

Document Comment Number Section / Review Comments (Print)/Basis for Comment Comment Disposition / Resolution Change to Document No.

Paragraph General Since bus bar spacing is dependent on the Small scale testing does not aim to No change gear that is available for testing, and can vary replicate the bus bar spacing of plant from what is installed at nuclear plants in the equipment. The small-scale testing US, when the test results and PRA frequencies program is a scaled experimental series 1 are documented the deviation in bus bar that aims at characterizing the arc particles.

spacing with respect to those in IEEE 1584 and As such, the bus bar size and spacing are in the industry should be documented and scaled to provide arc characteristics that evaluated. are more representative of large-scale electrical arcing.

General The bus bar to be used is 3mm x 1mm, which is This is scaled testing, the bus bars are No change undersized for any commercial power plant. much smaller than what you find in the 2 plant. The bus bar dimensions were scaled to scale the energy and to allow for more precise measurements mass loss.

General The plan states that the test setup will be in an The figure references is an illustration. In Figure replaced with photo for clarity.

enclosure. Several figures depict the actual testing the bus bars are in the middle dimensions. If these figures are accurate, the of the enclosure, so the blast back enclosure is snugged up to the bus bar and will concern is minimized due to the 3

reflect the blast back on the bus bar, effectively symmetrical nature of the setup. The doubling it. configuration of the small scale testing was described in detail at the public workshop on April 18-19, 2018.

General No artificial enclosures should be used on end of It is unclear how this comment relates to No change buses. If the bus does not terminate in a cabinet, the small-scale test program. No such 4 then do not cap the ends. The buses at the enclosures or bus terminations are plants are generally long runs with no blanked off proposed for use in the small scale testing.

ends.

REVIEW / COMMENT DOCUMENTATION Commenter: Joseph E. Pollock Phone: 202.739.8114 Document #, Rev: SAND2018-0706 O, DRAFT 0002 Aluminum High Energy Arc Fault (HEAF) Particle Size Discipline/Department: Nuclear Energy Institute Date: 5/17/2018 Title: Characterization Test Plan - DRAFT

• CLEARLY STATED AS A MATTER OF FACT (OR A SPECIFIC QUESTION)

• COMPLETE AND INCLUDE A REFERENCE TO THE AFFECTED DOCUMENT Comments shall be:

• LEGIBLE AND REPRODUCIBLE

• FOCUSED TO A SPECIFIC PROBLEM OR DEFIENCY Document Comment Number Section / Review Comments (Print)/Basis for Comment Comment Disposition / Resolution Change to Document No.

Paragraph General The ground intend to be placed in the cabinet is The comment is in reference to the shorting Test plan corrected to clearly document 2.6mm, roughly the same size as the bus bar. wire, not a grounding wire. However, the test procedure.

Again, this is not consistent with grounding used draft test plan incorrectly used a shorting in a commercial power plant installation wire sized per IEEE guidance. Because of the short duration, narrow gap scaled 5

nature of this testing that guidance is not appropriate to meet the purpose of the shorting wire. As such, the test plan has been updated to accurately document the size and configuration of the shorting wire.

General The fault current profile utilized for It is unclear how this comment relates to No change testing at MV should resemble a typical the small scale test program. The testing generator behavior (ie. decrement will be initiated with a shorting wire phase to phase in all cases. The intent of the curve). Typically MV gears have small scale program does not aim to grounding transformers or grounding evaluate probability of occurrence.

resistors on the neutral. This limits the phase to ground fault current to lower levels. Since NRC is performing phase to 6 phase testing and the ground resistors only limit the phase to ground current, the testing procedure is not impacted by the presence of the ground resistor.

However, presence of these phase-to-ground current limiting devices should be used to lower the probability of an arcing event at the MV voltage level

REVIEW / COMMENT DOCUMENTATION Commenter: Joseph E. Pollock Phone: 202.739.8114 Document #, Rev: SAND2018-0706 O, DRAFT 0002 Aluminum High Energy Arc Fault (HEAF) Particle Size Discipline/Department: Nuclear Energy Institute Date: 5/17/2018 Title: Characterization Test Plan - DRAFT

• CLEARLY STATED AS A MATTER OF FACT (OR A SPECIFIC QUESTION)

• COMPLETE AND INCLUDE A REFERENCE TO THE AFFECTED DOCUMENT Comments shall be:

• LEGIBLE AND REPRODUCIBLE

• FOCUSED TO A SPECIFIC PROBLEM OR DEFIENCY Document Comment Number Section / Review Comments (Print)/Basis for Comment Comment Disposition / Resolution Change to Document No.

Paragraph General Regarding widely used high voltage bus bars, Agree-change wording to medium voltage Change wording to medium voltage the bus widely used in NPPs is either low or medium voltage but not high. However, that depends on your definition. The high voltage terminology is not well defined even among industry standards. Many IEEE standards use high voltage to apply to anything greater than 7

1000V. NEMA C84.1 2016 defines high voltage as greater than 100kV. Reference NEMA C84.1 or some other standard for Voltage Class definitions. It is recommended that the voltage classes be defined in the test plan so that it is more clear what voltage ranges are being discussed General Consider matching the location of the It is unclear how this comment relates to No change instrument racks being used to monitor the the small scale test program. The small HEAF to match the existing ZOIs that were scale test program does not use instrument used in 6850 and FAQ 35. The material racks or material coupons. The small scale coupons on the instrument rack should include testing will use carbon tape and an aerogel both steel and aluminum. collection material to collect the products of 8 the small scale HEAF byproducts for further analysis. The small-scale testing focuses on near field particle characterization, where as this comment appears to be concerned with far field measurements, which are outside the objectives of this testing.

General Regarding the tests exceeding equipment It is unclear how this comment relates to No change 9 ratings, it seems the duration of fault currents the small scale test program. There is no would exceed the equipment ratings. Provide rated equipment specified in this test plan.

REVIEW / COMMENT DOCUMENTATION Commenter: Joseph E. Pollock Phone: 202.739.8114 Document #, Rev: SAND2018-0706 O, DRAFT 0002 Aluminum High Energy Arc Fault (HEAF) Particle Size Discipline/Department: Nuclear Energy Institute Date: 5/17/2018 Title: Characterization Test Plan - DRAFT

• CLEARLY STATED AS A MATTER OF FACT (OR A SPECIFIC QUESTION)

• COMPLETE AND INCLUDE A REFERENCE TO THE AFFECTED DOCUMENT Comments shall be:

• LEGIBLE AND REPRODUCIBLE

• FOCUSED TO A SPECIFIC PROBLEM OR DEFIENCY Document Comment Number Section / Review Comments (Print)/Basis for Comment Comment Disposition / Resolution Change to Document No.

Paragraph more specifics for this statement and the ratings discussed.

General For system voltages not specifically tested, there The data from this testing will be evaluated No change should be a method to extrapolate results to and analyzed to determine if extrapolation different voltages, e.g., 600V, 4.16kV for is possible. However, the lack of enclosure testing or 480V, 6.9kV for bus ducts. repeatability will increase the uncertainty 10 associated with any extrapolation. Any information related to the extrapolation will be documented and discussed after the data has been collected in a separate NUREG.

General Provide specifics on the type of cables that will It is unclear how this comment relates to No change be tested, i.e., thermoset, thermoplastic, IEEE the small scale test program. There are no 11 383 or not, etc. Alternatively, include in the test insulated electrical cables being used in plan the requirement to document the relevant testing.

properties of the cable(s) that were tested.

General Several sections reference IEEE standards The IEEE guide is only used as reference. Remove reference to IEEE guide.

12 meant for the testing of a first-off-the-line piece Direct use of the IEEE guide has been of switchgear, not a test rig. removed from the test plan.