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NUREG/CP-0311, Proceedings of the Information Sharing Workshop on High Energy Arcing Faults (Heafs)
ML19212A150
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Issue date: 07/31/2019
From: Kenneth Hamburger
Office of Nuclear Regulatory Research
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Meyd, Donald
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NUREG/CP-0311
Download: ML19212A150 (214)


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NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High Energy Arcing Faults (HEAFS)

Office of Nuclear Regulatory Research

AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as books, NRCs Library at www.nrc.gov/reading-rm.html. Publicly journal articles, transactions, Federal Register notices, released records include, to name a few, NUREG-series Federal and State legislation, and congressional reports.

publications; Federal Register notices; applicant, Such documents as theses, dissertations, foreign reports licensee, and vendor documents and correspondence; and translations, and non-NRC conference proceedings NRC correspondence and internal memoranda; bulletins may be purchased from their sponsoring organization.

and information notices; inspection and investigative reports; licensee event reports; and Commission papers Copies of industry codes and standards used in a and their attachments. substantive manner in the NRC regulatory process are maintained at NRC publications in the NUREG series, NRC regulations, The NRC Technical Library and Title 10, Energy, in the Code of Federal Regulations Two White Flint North may also be purchased from one of these two sources. 11545 Rockville Pike Rockville, MD 20852-2738

1. The Superintendent of Documents U.S. Government Publishing Office These standards are available in the library for reference Mail Stop IDCC use by the public. Codes and standards are usually Washington, DC 20402-0001 copyrighted and may be purchased from the originating Internet: bookstore.gpo.gov organization or, if they are American National Standards, Telephone: (202) 512-1800 from Fax: (202) 512-2104 American National Standards Institute 11 West 42nd Street
2. The National Technical Information Service New York, NY 10036-8002 5301 Shawnee Road www.ansi.org Alexandria, VA 22312-0002 (212) 642-4900 www.ntis.gov Legally binding regulatory requirements are stated only in laws; 1-800-553-6847 or, locally, (703) 605-6000 NRC regulations; licenses, including technical specifications; or A single copy of each NRC draft report for comment is orders, not in NUREG-series publications. The views expressed available free, to the extent of supply, upon written in contractor prepared publications in this series are not request as follows: necessarily those of the NRC.

The NUREG series comprises (1) technical and administrative Address: U.S. Nuclear Regulatory Commission reports and books prepared by the staff (NUREG-XXXX) or Office of Administration agency contractors (NUREG/CR-XXXX), (2) proceedings of conferences (NUREG/CP-XXXX), (3) reports resulting from Multimedia, Graphics, and Storage & international agreements (NUREG/IA-XXXX), (4) brochures Distribution Branch (NUREG/BR-XXXX), and (5) compilations of legal decisions and Washington, DC 20555-0001 orders of the Commission and Atomic and Safety Licensing E-mail: distribution.resource@nrc.gov Boards and of Directors decisions under Section 2.206 of NRCs regulations (NUREG-0750).

Facsimile: (301) 415-2289 DISCLAIMER: Where the papers in these proceedings have Some publications in the NUREG series that are posted been authored by contractors of the U.S. Government, neither at NRCs Web site address www.nrc.gov/reading-rm/ the U.S. Government nor any agency thereof, nor any U.S.

doc-collections/nuregs are updated periodically and may employee makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third partys differ from the last printed version. Although references to use or the results of such use, of any information, apparatus, material found on a Web site bear the date the material product, or process disclosed in these proceedings, or was accessed, the material available on the date cited represents that its use by such third party would not infringe may subsequently be removed from the site. privately owned rights. The views expressed in these proceedings are not necessarily those of the U.S. Regulatory Commission.

NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High Energy Arcing Faults (HEAFS)

Manuscript Completed: July 2018 Date Published: July 2019 Prepared by:

G. Taylor K. Hamburger N. Melly K. Miller S. Gardocki T. Boyce Mark Henry Salley, NRC Project Manager Office of Nuclear Regulatory Research

ABSTRACT The U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Regulatory Research, organized this Information-Sharing Workshop on High Energy Arcing Faults (HEAFs). The workshop took place April 18-19, 2018, at the NRC Headquarters Professional Development Center, Building Three, 11601 Lansdown Street, Rockville, MD. The workshop had the following four objectives:

(1) Inform interested stakeholders about the status of PRE-GI-018 and related research.

(2) Review and resolve public comments received on the phase II draft test plan.

(3) Solicit and review information from industry partners regarding common equipment types and configurations to inform future testing.

(4) Provide an opportunity for public feedback on future testing.

The workshop was a Category 3 public meeting and open to the public for participation. The NRC broadcasted the meeting via webinar to encourage participation among interested parties for whom travel was not possible. The agency coordinated the workshop with the Electric Power Research Institute (EPRI) and the National Fire Protection Association (NFPA). The organizers advertised the workshop at recent nuclear industry information forums and during NRC public meetings related to fire protection. The workshops technical topics focused on HEAF hazards and recently completed and ongoing research initiatives. The workshop also covered the NRCs Generic Issues (GI) program as it relates to the aluminum HEAF issue. This proceedings report documents the recommendations and insights from the session presentations and follow-on discussions.

iii

FOREWORD The U.S. Nuclear Regulatory Commission (NRC) values the technical views and inputs from all stakeholders in the development of agency research projects. The research on high energy arcing faults (HEAFs) is no different. The need for the research is driven by the analysis of the most recent U.S. and international nuclear power plant (NPP) fire event data and operating experience, which has identified HEAF events as a non-negligible fire hazard. This HEAF operational experience illustrates that significant damage may occur during the event.

Experimental results have identified that the involvement of aluminum components during a HEAF may increase the hazard potential. Safe nuclear operation depends on engineers, operators, and probabilistic risk assessment (PRA) practitioners understanding the risk potential of a HEAF and preventing the event or protecting important safety systems, structures, and components from its effects.

This report documents the presentations and discussions conducted during a 2-day public workshop held in the spring of 2018. The NRC plans to use the information gained during the workshop to help finalize its test plans and inform the agency decision-making process. The staff also believes the workshop equally benefitted the participating stakeholders by providing them with the most current information available from the NRC on this matter.

This report continues to build upon previous U.S. and international HEAF work. This research will advance the understanding of this complex phenomenon and its impact on safety. I hope this work will ultimately be used to make a positive contribution to nuclear power plant fire safety.

Mark Henry Salley, P.E.

Chief, Fire and External Hazards Analysis Branch Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission June 26, 2018 Rockville, MD v

TABLE OF CONTENTS ABSTRACT ............................................................................................................................. iii FOREWORD .............................................................................................................................. v LIST OF TABLES ........................................................................................................................ ix EXECUTIVE

SUMMARY

............................................................................................................. xi ACKNOWLEDGMENTS ............................................................................................................. xv ABBREVIATIONS AND ACRONYMS ..................................................................................... xvii 1 INTRODUCTION .............................................................................................................. 1-1 1.1 Background........................................................................................................... 1-1 1.2 About This Report ................................................................................................. 1-2 2 WELCOME AND OPENING ............................................................................................ 2-1 2.1 Workshop Opening ............................................................................................... 2-1 2.1.1 Discussion ............................................................................................ 2-1 2.1.2 Presentation Slides .............................................................................. 2-2 2.2 Workshop Introduction and Objectives ................................................................. 2-4 2.2.1 Discussion ............................................................................................ 2-4 2.2.2 Presentation Slides .............................................................................. 2-5 3 REVIEW OF PHASE I HEAF RESEARCH ...................................................................... 3-1 3.1 Review of Phase I HEAF Research ...................................................................... 3-1 3.1.1 Discussion ............................................................................................ 3-2 3.1.2 Presentation Slides .............................................................................. 3-3 4 THE GENEREIC ISSUE PROCESS AND PILOT PLANTS ............................................ 4-1 4.1 The Generic Issue Process .................................................................................. 4-1 4.1.1 Discussion ............................................................................................ 4-1 4.1.2 Presentation Slides .............................................................................. 4-2 4.2 Aluminum HEAF PRE-GI-018 ............................................................................... 4-8 4.2.1 Discussion ............................................................................................ 4-8 4.2.2 Presentation Slides ............................................................................ 4-10 4.3 Pilot Plants .......................................................................................................... 4-15 4.3.1 Discussion .......................................................................................... 4-15 4.3.2 Presentation Slides ............................................................................ 4-18 5 DEFINING THE HAZARD ................................................................................................ 5-1 5.1 Definitions of Energetic Electrical Faults .............................................................. 5-1 5.1.1 Discussion ............................................................................................ 5-1 5.1.2 Presentation Slides .............................................................................. 5-3 6 SMALL-SCALE TESTING AND PROBABILISTIC RISK ASSESSMENT MODELING IMPLICATIONS ........................................................................................... 6-1 6.1 Small-Scale Testing at Sandia National Laboratories .......................................... 6-1 6.1.1 Discussion ............................................................................................ 6-1 vii

6.1.2 Presentation Slides .............................................................................. 6-3 6.2 Probabilistic Risk Assessment Modeling Implications ........................................ 6-10 6.2.1 Discussion .......................................................................................... 6-10 6.2.2 Presentation Slides ............................................................................ 6-11 7 NATIONAL FIRE PROTECTION ASSOCIATION PERSPECTIVE ................................. 7-1 7.1 Perspective from the National Fire Protection Association ................................... 7-1 7.1.1 Discussion ............................................................................................ 7-1 7.1.2 Presentation Slides .............................................................................. 7-2 8 ELECTRIC POWER RESEARCH INSTITUTE PERSPECTIVE ...................................... 8-1 8.1 Perspective from the Electric Power Research Institute ....................................... 8-1 8.1.1 Discussion ............................................................................................ 8-1 8.1.2 Presentation Slides .............................................................................. 8-3 9 PHYSICAL TESTING AND FAILURE RATES ................................................................ 9-1 9.1 Physical Testing and Failure Rates ...................................................................... 9-1 9.1.1 Discussion ............................................................................................ 9-1 9.1.2 Presentation Slides .............................................................................. 9-2 10 TEST PARAMETER AND EQUIPMENT SELECTION .................................................. 10-1 10.1 Test Parameter and Equipment Selection .......................................................... 10-1 10.1.1 Discussion .......................................................................................... 10-1 10.1.2 Presentation Slides .......................................................................... 10-10 11 DRAFT TEST PLAN AND COMMENT RESOLUTION.................................................. 11-1 11.1 Review of Phase II Draft Test Plan and Comment Resolution ........................... 11-1 11.1.1 Discussion .......................................................................................... 11-1 11.1.2 Presentation Slides ............................................................................ 11-3 12 WORKSHOP WRAPUP,

SUMMARY

OF RECOMMENDATIONS, AND FOLLOW-UP .................................................................................................................. 12-1 12.1 Conclusion of Workshop ..................................................................................... 12-1 12.2 Summary of Recommendations ......................................................................... 12-1 12.3 Summary of Follow-Up Actions .......................................................................... 12-2 13 REFERENCES ............................................................................................................... 13-1 APPENDIX A DRAFT LARGE-SCALE TEST PLAN AND COMMENTS ................................ A-1 APPENDIX B REVISED LARGE-SCALE TEST PLAN ........................................................... B-1 APPENDIX C NEEDS AND OBJECTIVES .............................................................................. C-1 APPENDIX D DRAFT SCMALL-SCALE TEST PLAN AND COMMENTS .............................. D-1 viii

LIST OF TABLES Table 10-1 Summary of Parameter Ranking from Workshop Participants ............................. 10-7 Table 12-1 Summary of Workshop Recommendations .......................................................... 12-1 Table 12-2 Summary of Followup Actions .............................................................................. 12-2 ix

EXECUTIVE

SUMMARY

PRIMARY AUDIENCE:

Generation facility staff, fire protection engineers, electrical engineers, and probabilistic risk assessment (PRA) practitioners who are responsible for fire protection programs, electrical equipment operation and maintenance, and associated duties involving the hazard assessment of fire and explosions caused by energetic electrical faults.

SECONDARY AUDIENCE:

Engineers, reviewers, utility managers, and other stakeholders who conduct, review, or manage protection programs and need to understand the U.S. Nuclear Regulatory Commission (NRC) research and planned research related to energetic electrical faults.

KEY RESEARCH QUESTION:

How can the NRC ensure that future research programs on the aluminum high energy arcing faults (HEAF) hazard accurately reflect plant conditions and will produce usable results?

RESEARCH OVERVIEW:

Energetic electrical faults can result in explosions, electrical arcing, fire, ionized gases, and smoke, prompting collateral damage to adjacent equipment and causing latent failures. The characteristics of these failures differ from those of the traditional fire protection hazard assessment, including the bypass of the fire ignition and growth stages; rapid propagation of the fire to other equipment and across vertical fire barriers; power system designs that are vulnerable to station blackout; failed fire-suppression attempts with dry chemicals and the need to use water; longer restoration time to recover; and unexpected challenges to operator response from event byproducts (smoke and conductive gases). These highly energetic events that have the potential to impact plant safety are commonly referred to as High Energy Arcing Faults (HEAFs).

NRC regulations, regulatory guidance, and defense-in-depth design philosophy exist to provide reasonable assurance of adequate protection to public health and safety from the consequences of fires that may occur in a nuclear facility. In the early 2000s, the NRC investigated the insights gained from fire incidents and began an international collaborative effort to better understand operating experience as it relates to fire safety. This collaboration resulted in a series of tests conducted in the United States between 2014 and 2017 to support revisions and improvement to existing fire risk methods. The results demonstrated a unique failure mode for electrical equipment that contained aluminum components, which displayed more damage than revealed in tests conducted on equipment that did not contain aluminum.

These insights prompted the NRC and its international research partners to pursue additional testing.

The NRC issued Information Notice 2017-04, High Energy Arcing Faults in Electrical Equipment Containing Aluminum Components, dated August 21, 2017, to alert addressees of the test results and related operating experience. The NRC staff also proposed this potential safety issue as a generic issue (GI) (PRE-GI-018). In order to adequately assess PRE-GI-018, the NRC needed additional information and decided to hold a workshop to communicate this issue and obtain feedback and information from stakeholders.

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The motivation for holding this workshop was to communicate the NRCs past and planned actions related to the HEAF hazard involving aluminum components. Additionally, the NRC sought feedback from stakeholders to support realistic and representative test conditions to ensure the efficient and effective use of NRC resources as the agency assesses the impact of HEAFs involving aluminum components. The workshop objectives were to (1) inform interested stakeholders about the status of PRE-GI-018 and related research, (2) review and resolve public comments received on the phase II draft test plan, (3) solicit and review information from industry partners regarding common equipment types and configurations to inform future testing, and (4) provide an opportunity for public feedback on future testing. In particular, the technical issues focused on the test parameters that influence the HEAF phenomena, and many discussions during the workshop focused on realistic and representative parameter ranges and nuclear power plant electrical system configurations.

The NRC staff from the Office of Nuclear Regulatory Research organized the workshop in collaboration with the Electric Power Research Institute (EPRI) and the National Fire Protection Association (NFPA). Staff from DNV GL, the National Institute of Standards and Technology (NIST), and Factory Mutual (FM) also provided feedback and direction for organization of the workshop. The NRC welcomed the public to attend and observe this Category 3 public meeting and posting workshop information on the agencys Public Meeting website. About 30 workshop registrants attended the workshop in person. In addition, approximately 33 individuals participated in the workshop via a webinar advertised on the NRC Public Meeting website.

KEY FINDINGS:

In the opening session, the NRC presented the expected outcomes of the workshop. Next, an introduction session welcomed the participants and identified the workshop purpose, objectives, and agenda and emphasized the NRCs safety mission. This was followed by a presentation that reviewed past agency efforts and research related to the HEAF hazard. Following this presentation, the NRC discussed the GI program and gave a presentation on the status of PRE-GI-018 related to the aluminum HEAF issue. Before concluding the morning sessions, presenters spoke about the development of HEAF definitions, small-scale testing, and risk assessment modeling implications. The afternoon sessions focused on research undertaken outside the NRC. This included presentations from the NFPA, EPRI, and DNV GL. The second day of the workshop included extensive discussion among the participants related to the parameters and test configurations that would support realistic and representative configurations to characterize the HEAF hazard and develop data to support the assessment of the HEAF hazard as it relates to the influence of aluminum components. Part of this discussion allowed for voluntary participation in ranking various parameters for their importance in influencing the HEAF phenomena. The NRC and partners could use results from this ranking to support test plan revisions and experimental configurations during future testing. The final sessions of the workshop revolved around the draft full-scale testing being pursued as an international initiative under the Nuclear Energy Agency (NEA) / Organisation for Economic Co-Operation and Development (OECD). The final session focused on a presentation of the draft test plan and resolution of comments received during the public comment period.

As a result of the workshop, the NRC identified several recommendations and follow-up actions, including the following:

improvements to project tracking and task dependencies xii

NRC expectations and schedule related to the pilot plant initiative to support the assessment stage of the GI program suggestion to perform a literature search to allow for better communication and basis for specific aspects of the proposed testing proposed changes to testing configurations and parameters follow-on interactions with stakeholders to communicate findings in a timely manner definitions of the hazard and associated frequencies that would support test result applicability to ensure consistent treatment of the hazard in a risk assessment WHY IT MATTERS:

This report provides recommendations to assist the NRC staff and stakeholders in performing needed research and work to assess the impact of aluminum components on the HEAF hazard and the assessment of that hazard related to plant safety.

HOW TO APPLY RESULTS:

Engineers conducting research related to this topic should focus on Chapters 3-8 and 10.

Users of this report are also encouraged to consult the reference material identified in Section 1.3 and included in the companion DVD.

LEARNING AND ENGAGEMENT OPPORTUNITIES:

Users of this report may be interested in the annual fire PRA training, Module III, Fire Hazard Analysis, sponsored jointly between EPRI and the NRC Office of Nuclear Regulatory Research.

In addition, numerous commercial training opportunities are available related to the analysis of arc flash hazards for personnel safety.

xiii

ACKNOWLEDGMENTS The U.S. Nuclear Regulatory Commission acknowledges and appreciates the many people and organizations that supported the Information-Sharing Workshop on High Energy Arcing Faults (HEAFs). Those who attended that workshop in person and via the webinar provided exceptional feedback and included the following:

Ashley Lindeman (EPRI) Donna Gilmore Brenda Simril (TVA) Marvin Lewis Robert Rhodes (Duke Energy) Marc Janssens (SWRI)

Rob Cavedo (Exelon) Dane Lovelace (Jensen Hughes)

Francisco Joglar (Jensen Hughes) Chris Riedl (TVA)

Daniel Funk (Jensen Hughes) Victor Savulyak (DNV GL)

Jana Bergman (Curtiss Wright) Robert Taylor (BSI)

Francesco Pellizzari (EPM) Jeffrey Voskuil (Entergy)

Stephen Turner (Consultant) Sandy Naccarato (Southern Company)

Scott Bareham (NIST) JongSeuk Park (KINS)

Rodney Pletz (AEP) Joshua Ross (First Energy Corporation)

Mathew Merriman (Appendix R Solutions) Neal Simmons (Duke Energy)

Beth Wetzel (TVA) Keith Vincent (FPL)

Jens Alkempes (FM Global) Kiang Zee (Jensen Hughes)

Sujit Purushothaman (FM Global) Preston Cooper (TVA)

Thomas Shudak (NPPD) Mike Franovich (NRC)

Kenneth Fleisher (EPRI) Steven Alferink (NRC)

Anthony Putorti (NIST) Philipp Braaten (NRC)

Kazimierz Leja (Exelon) William Monk (NRC)

Victoria Anderson (NEI) Tomy Nazario (NRC)

Jack Campellone (Duke Energy) Sam Graves (NRC)

Alex Feldman (DNV GL) Gregory Werner (NRC)

Robert Egli (TVA) David Stroup (NRC)

Scott Groesbeck (DP Engineering) Robert Daley (NRC)

Mark Hulet (APS) Tomy Nazario (NRC)

Young Jo (Southern Company) Bas Verhoeven (DNV GL)

David Lochbaum (UCS) Frank Cielo (DNV GL)

Bob Meyer Alice Muna (SNL) xv

ABBREVIATIONS AND ACRONYMS AC alternating current ADAMS Agencywide Documents Access and Management System AL aluminum AT auxiliary transformer AWG American Wire Gauge BSI Brendan Stanton Inc.

CCDP conditional core damage probability CDF core damage frequency CFD computational fluid dynamics CFR Code of Federal Regulations CIGRE International Council on Large Electric Systems CSNI Committee on the Safety of Nuclear Installations DC direct current EELS electron energy loss spectroscopy ERFBS electric raceway fire barrier systems EPRI Electric Power Reseach Institute EDXA energy dispersive x-ray analysis FAQ frequently asked question GDC general design criterion/criteria GI generic issue GIRP Generic Issue Review Panel GSU generator step-up HEAF high energy arcing fault HGL hot gas layer HRR heat release rate IEC International Electrotechnical Commission IEEE Institute of Electrical and Electronics Engineers IN information notice ISO International Organization for Standardization KINS Korea Institute of Nuclear Safety LER licensee event report LV low voltage MOU memorandum of understanding MV medium voltage NEA Nuclear Energy Agency NEI Nuclear Energy Institute NFPA National Fire Protection Association NIST National Institute of Standards and Technology NPP nuclear power plant xvii

NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSP non-suppression probability OECD Orginisation for Economic Co-operation and Development OpE or OPEX operating experience OSHA Occupational Safety and Health Administration PIRT phenomena identification and ranking table PRA probabalistic risk assessment RES Office of Nucear Regulatory Research ROI Regulatory Office Implementation RTPC Research and Testing Planning Committee SEM scanning electron microscopy S/NRA/R Secretariat of Nuclear Regulation Authority (Japan)

SNL Sandia National Laboratories SPAR standardized plant analysis risk STL short-circuit testing liason SWRI Southwest Reasearch Institute T&D transmission and distribution TPP test procedure and protocol UCS Union of Concerned Scientists ZOI zone of influence xviii

1 INTRODUCTION

1.1 Background

The U.S. Nuclear Regulatory Commission (NRC) fire protection requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, (Ref. 1) and the supporting guidance address fire from energetic faults.

For example, 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion 3, Fire Protection, requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effects of fires and explosions. The requirements in 10 CFR 50.48, Fire Protection, state that each operating nuclear power plant must have a fire protection plan that satisfies General Design Criterion 3 of Appendix A to 10 CFR Part 50.

Section 4.1.3.6, Electrical Cabinets, of NRC Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, Revision 3, issued February 2018 (Ref. 2), states that electrical cabinets present an ignition source for fires and a potential for explosive electrical faults that can result in damage not only to the cabinet of origin, but also to equipment, cables, and other electrical cabinets in the vicinity of the cabinet of origin. Regulatory Guide 1.189 also states that fire protection systems and features provided for the general area containing the cabinet may not be adequate to prevent damage to adjacent equipment, cables, and cabinets following an energetic electrical fault; therefore, cabinets with voltages of 480 volts and above should have adequate spatial separation or substantial physical barriers to minimize the potential for an energetic electrical fault to damage adjacent equipment, cables, or cabinets important to safety.

Fire probabilistic risk assessments (PRAs) include methods to characterize the high energy arcing fault (HEAF) hazard, as documented in Electric Power Research Institute (EPRI)

Technical Report (TR) 1011989/NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, issued September 2000 (Ref. 3). Volume 2 of NUREG/CR-6850 contains the guidance for electrical enclosures (Appendix M), and Supplement 1 (Ref. 4) contains guidance for bus ducts (Chapter 7). Both methods provide a bounding approach to quantifying the HEAF hazard; that is, they assume physical damage zones based on available operating experience that demonstrated extensive damage to surrounding equipment. Although the details of each method are documented in the reference identified above, the methods generally assume all components and systems within the physical damage zone are ignited and are unable to perform their intended design function. Accordingly, these methods were considered conservative and bounding for future arcing fault events.

Starting in the mid-2000s, the NRC began international collaboration to better understand the HEAF phenomena and advance the existing state of knowledge and fire PRA methods. This collaboration was facilitated through the Nuclear Energy Agency (NEA)/Organisation for Economic Co-operation and Development (OECD), of which the NRC is a member. Under an OECD FIRE data exchange project, member countries share operating experience related to fires occurring at nuclear facilities in 12 countries. As part of the analysis of this data, a non-negligible number of reportable events with non-chemical explosions and rapid fires resulting from high energy arcing faults (HEAF) was observed (Ref. 5). As a result of this observation and in alignment with the major goals of the NEA/OECD task to develop a correlation for predicting damage, establishing input data, and establishing boundary conditions for more detailed modeling, the member countries recommended performance of a series of experiments.

1-1

From 2014 to 2016, the NRC led an international experimental program, as documented in NEA/CSNI/R(2017)7, Report on the Testing Phase of High Energy Arcing Fault Events (HEAF)

Project, issued May 2017 (Ref. 6). This report documents 26 HEAF tests that were performed on a variety of donated electrical equipment. One significant finding from this work was that HEAFs involving aluminum components may result in greater damage and different failure modes than HEAFs that do not contain aluminum. Based on these findings, the international group recommended additional testing.

In 2016, based on the results from testing indicating that the current fire PRA methodology may not be bounding, the NRC staff proposed a potential safety concern related to HEAFs involving aluminum as an issue for the NRCs Generic Issue (GI) program. Following an initial review and a formal screening review, a Generic Issue Review Panel (GIRP) determined that the proposed issue met all seven screening criteria of the GI program and recommended that the issue be moved into the assessment stage of the GI program. As part of that assessment stage, a number of actions were identified that will be performed to assess the potential risk impact associated with HEAFs involving aluminum. These actions include, in part, additional testing.

These findings also prompted the NRC staff to reevaluate operating experience and identify any HEAF events that involved aluminum components. The staff documented the results of this effort in Information Notice (IN) 2017-04, High Energy Arcing Faults in Electrical Equipment Containing Aluminum, issued August 2017 (Ref. 7). This IN summarizes the test results where damage states exceeded existing guidance and involved aluminum components. Additionally, the IN summarizes six HEAF events from operating experience that involved aluminum components and provides a qualitative description of those events.

Given the NRCs desire to understand the HEAF hazard involving aluminum and ensure adequate protection of public safety, external stakeholders have developed information to better understand and model the hazard. These initiatives include NRC Frequently Asked Question (FAQ)17--0013, High Energy Arcing Fault (HEAF) Non-Suppression Probability (NSP), dated March 21, 2017 (Ref. 8). EPRI has also developed two whitepapers (Refs. 9, 10) that provide an overview of nuclear power plant electrical distribution systems and characterize operating experience and testing.

In 2017, the NRC staff began formalizing an international agreement to perform a Phase II testing campaign to address knowledge gaps and further explore the impact aluminum plays in HEAF events. The NRC issued a draft test plan for public comment in the Federal Register on August 2, 2017. However, in order to ensure that U.S. interests are met and the program is performed in an efficient and effective manner, the NRC staff decided that additional stakeholder interactions and feedback were warranted. As such, it was suggested that an HEAF workshop be held as the forum for this interaction. The workshop took place April 18-19, 2018, at the NRC Headquarters offices in Rockville, MD. This report documents that workshop, the discussions held, and the feedback received.

1.2 About This Report This report is a collection of the materials presented at the 2-day workshop held April 18-19, 2018. The workshop transcripts (Refs. 11, 12) are available in the NRCs Agency-wide Documents Access and Management System (ADAMS) under Accession Nos.

ML18114A817 and ML18114A818. The companion DVD also includes these transcripts.

1-2

In addition to the workshop materials and transcripts, the companion DVD includes a variety of documents related to the HEAF research program, including the following:

test footage and data from Phase 1 testing FAQs, INs, and GI communications related to HEAF licensee event reports (LERs) from relevant HEAF events small- and large-scale draft test plans and comments This report documents the material sequentially as it was presented during the workshop. For each session, this report includes a brief summary of any formal presentation, followed by documentation of discussion points, recommendations from those discussions, and any follow-up action items. Each chapter ends with the slide deck as presented, reproduced as embedded images.

1-3

NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High Energy Arcing Faults (HEAFS)

Office of Nuclear Regulatory Research

AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as books, NRCs Library at www.nrc.gov/reading-rm.html. Publicly journal articles, transactions, Federal Register notices, released records include, to name a few, NUREG-series Federal and State legislation, and congressional reports.

publications; Federal Register notices; applicant, Such documents as theses, dissertations, foreign reports licensee, and vendor documents and correspondence; and translations, and non-NRC conference proceedings NRC correspondence and internal memoranda; bulletins may be purchased from their sponsoring organization.

and information notices; inspection and investigative reports; licensee event reports; and Commission papers Copies of industry codes and standards used in a and their attachments. substantive manner in the NRC regulatory process are maintained at NRC publications in the NUREG series, NRC regulations, The NRC Technical Library and Title 10, Energy, in the Code of Federal Regulations Two White Flint North may also be purchased from one of these two sources. 11545 Rockville Pike Rockville, MD 20852-2738

1. The Superintendent of Documents U.S. Government Publishing Office These standards are available in the library for reference Mail Stop IDCC use by the public. Codes and standards are usually Washington, DC 20402-0001 copyrighted and may be purchased from the originating Internet: bookstore.gpo.gov organization or, if they are American National Standards, Telephone: (202) 512-1800 from Fax: (202) 512-2104 American National Standards Institute 11 West 42nd Street
2. The National Technical Information Service New York, NY 10036-8002 5301 Shawnee Road www.ansi.org Alexandria, VA 22312-0002 (212) 642-4900 www.ntis.gov Legally binding regulatory requirements are stated only in laws; 1-800-553-6847 or, locally, (703) 605-6000 NRC regulations; licenses, including technical specifications; or A single copy of each NRC draft report for comment is orders, not in NUREG-series publications. The views expressed available free, to the extent of supply, upon written in contractor prepared publications in this series are not request as follows: necessarily those of the NRC.

The NUREG series comprises (1) technical and administrative Address: U.S. Nuclear Regulatory Commission reports and books prepared by the staff (NUREG-XXXX) or Office of Administration agency contractors (NUREG/CR-XXXX), (2) proceedings of conferences (NUREG/CP-XXXX), (3) reports resulting from Multimedia, Graphics, and Storage & international agreements (NUREG/IA-XXXX), (4) brochures Distribution Branch (NUREG/BR-XXXX), and (5) compilations of legal decisions and Washington, DC 20555-0001 orders of the Commission and Atomic and Safety Licensing E-mail: distribution.resource@nrc.gov Boards and of Directors decisions under Section 2.206 of NRCs regulations (NUREG-0750).

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NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High Energy Arcing Faults (HEAFS)

Manuscript Completed: July 2018 Date Published: July 2019 Prepared by:

G. Taylor K. Hamburger N. Melly K. Miller S. Gardocki T. Boyce Mark Henry Salley, NRC Project Manager Office of Nuclear Regulatory Research

ABSTRACT The U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Regulatory Research, organized this Information-Sharing Workshop on High Energy Arcing Faults (HEAFs). The workshop took place April 18-19, 2018, at the NRC Headquarters Professional Development Center, Building Three, 11601 Lansdown Street, Rockville, MD. The workshop had the following four objectives:

(1) Inform interested stakeholders about the status of PRE-GI-018 and related research.

(2) Review and resolve public comments received on the phase II draft test plan.

(3) Solicit and review information from industry partners regarding common equipment types and configurations to inform future testing.

(4) Provide an opportunity for public feedback on future testing.

The workshop was a Category 3 public meeting and open to the public for participation. The NRC broadcasted the meeting via webinar to encourage participation among interested parties for whom travel was not possible. The agency coordinated the workshop with the Electric Power Research Institute (EPRI) and the National Fire Protection Association (NFPA). The organizers advertised the workshop at recent nuclear industry information forums and during NRC public meetings related to fire protection. The workshops technical topics focused on HEAF hazards and recently completed and ongoing research initiatives. The workshop also covered the NRCs Generic Issues (GI) program as it relates to the aluminum HEAF issue. This proceedings report documents the recommendations and insights from the session presentations and follow-on discussions.

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FOREWORD The U.S. Nuclear Regulatory Commission (NRC) values the technical views and inputs from all stakeholders in the development of agency research projects. The research on high energy arcing faults (HEAFs) is no different. The need for the research is driven by the analysis of the most recent U.S. and international nuclear power plant (NPP) fire event data and operating experience, which has identified HEAF events as a non-negligible fire hazard. This HEAF operational experience illustrates that significant damage may occur during the event.

Experimental results have identified that the involvement of aluminum components during a HEAF may increase the hazard potential. Safe nuclear operation depends on engineers, operators, and probabilistic risk assessment (PRA) practitioners understanding the risk potential of a HEAF and preventing the event or protecting important safety systems, structures, and components from its effects.

This report documents the presentations and discussions conducted during a 2-day public workshop held in the spring of 2018. The NRC plans to use the information gained during the workshop to help finalize its test plans and inform the agency decision-making process. The staff also believes the workshop equally benefitted the participating stakeholders by providing them with the most current information available from the NRC on this matter.

This report continues to build upon previous U.S. and international HEAF work. This research will advance the understanding of this complex phenomenon and its impact on safety. I hope this work will ultimately be used to make a positive contribution to nuclear power plant fire safety.

Mark Henry Salley, P.E.

Chief, Fire and External Hazards Analysis Branch Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission June 26, 2018 Rockville, MD v

TABLE OF CONTENTS ABSTRACT ............................................................................................................................. iii FOREWORD .............................................................................................................................. v LIST OF TABLES ........................................................................................................................ ix EXECUTIVE

SUMMARY

............................................................................................................. xi ACKNOWLEDGMENTS ............................................................................................................. xv ABBREVIATIONS AND ACRONYMS ..................................................................................... xvii 1 INTRODUCTION .............................................................................................................. 1-1 1.1 Background........................................................................................................... 1-1 1.2 About This Report ................................................................................................. 1-2 2 WELCOME AND OPENING ............................................................................................ 2-1 2.1 Workshop Opening ............................................................................................... 2-1 2.1.1 Discussion ............................................................................................ 2-1 2.1.2 Presentation Slides .............................................................................. 2-2 2.2 Workshop Introduction and Objectives ................................................................. 2-4 2.2.1 Discussion ............................................................................................ 2-4 2.2.2 Presentation Slides .............................................................................. 2-5 3 REVIEW OF PHASE I HEAF RESEARCH ...................................................................... 3-1 3.1 Review of Phase I HEAF Research ...................................................................... 3-1 3.1.1 Discussion ............................................................................................ 3-2 3.1.2 Presentation Slides .............................................................................. 3-3 4 THE GENEREIC ISSUE PROCESS AND PILOT PLANTS ............................................ 4-1 4.1 The Generic Issue Process .................................................................................. 4-1 4.1.1 Discussion ............................................................................................ 4-1 4.1.2 Presentation Slides .............................................................................. 4-2 4.2 Aluminum HEAF PRE-GI-018 ............................................................................... 4-8 4.2.1 Discussion ............................................................................................ 4-8 4.2.2 Presentation Slides ............................................................................ 4-10 4.3 Pilot Plants .......................................................................................................... 4-15 4.3.1 Discussion .......................................................................................... 4-15 4.3.2 Presentation Slides ............................................................................ 4-18 5 DEFINING THE HAZARD ................................................................................................ 5-1 5.1 Definitions of Energetic Electrical Faults .............................................................. 5-1 5.1.1 Discussion ............................................................................................ 5-1 5.1.2 Presentation Slides .............................................................................. 5-3 6 SMALL-SCALE TESTING AND PROBABILISTIC RISK ASSESSMENT MODELING IMPLICATIONS ........................................................................................... 6-1 6.1 Small-Scale Testing at Sandia National Laboratories .......................................... 6-1 6.1.1 Discussion ............................................................................................ 6-1 vii

6.1.2 Presentation Slides .............................................................................. 6-3 6.2 Probabilistic Risk Assessment Modeling Implications ........................................ 6-10 6.2.1 Discussion .......................................................................................... 6-10 6.2.2 Presentation Slides ............................................................................ 6-11 7 NATIONAL FIRE PROTECTION ASSOCIATION PERSPECTIVE ................................. 7-1 7.1 Perspective from the National Fire Protection Association ................................... 7-1 7.1.1 Discussion ............................................................................................ 7-1 7.1.2 Presentation Slides .............................................................................. 7-2 8 ELECTRIC POWER RESEARCH INSTITUTE PERSPECTIVE ...................................... 8-1 8.1 Perspective from the Electric Power Research Institute ....................................... 8-1 8.1.1 Discussion ............................................................................................ 8-1 8.1.2 Presentation Slides .............................................................................. 8-3 9 PHYSICAL TESTING AND FAILURE RATES ................................................................ 9-1 9.1 Physical Testing and Failure Rates ...................................................................... 9-1 9.1.1 Discussion ............................................................................................ 9-1 9.1.2 Presentation Slides .............................................................................. 9-2 10 TEST PARAMETER AND EQUIPMENT SELECTION .................................................. 10-1 10.1 Test Parameter and Equipment Selection .......................................................... 10-1 10.1.1 Discussion .......................................................................................... 10-1 10.1.2 Presentation Slides .......................................................................... 10-10 11 DRAFT TEST PLAN AND COMMENT RESOLUTION.................................................. 11-1 11.1 Review of Phase II Draft Test Plan and Comment Resolution ........................... 11-1 11.1.1 Discussion .......................................................................................... 11-1 11.1.2 Presentation Slides ............................................................................ 11-3 12 WORKSHOP WRAPUP,

SUMMARY

OF RECOMMENDATIONS, AND FOLLOW-UP .................................................................................................................. 12-1 12.1 Conclusion of Workshop ..................................................................................... 12-1 12.2 Summary of Recommendations ......................................................................... 12-1 12.3 Summary of Follow-Up Actions .......................................................................... 12-2 13 REFERENCES ............................................................................................................... 13-1 APPENDIX A DRAFT LARGE-SCALE TEST PLAN AND COMMENTS ................................ A-1 APPENDIX B REVISED LARGE-SCALE TEST PLAN ........................................................... B-1 APPENDIX C NEEDS AND OBJECTIVES .............................................................................. C-1 APPENDIX D DRAFT SCMALL-SCALE TEST PLAN AND COMMENTS .............................. D-1 viii

LIST OF TABLES Table 10-1 Summary of Parameter Ranking from Workshop Participants ............................. 10-7 Table 12-1 Summary of Workshop Recommendations .......................................................... 12-1 Table 12-2 Summary of Followup Actions .............................................................................. 12-2 ix

EXECUTIVE

SUMMARY

PRIMARY AUDIENCE:

Generation facility staff, fire protection engineers, electrical engineers, and probabilistic risk assessment (PRA) practitioners who are responsible for fire protection programs, electrical equipment operation and maintenance, and associated duties involving the hazard assessment of fire and explosions caused by energetic electrical faults.

SECONDARY AUDIENCE:

Engineers, reviewers, utility managers, and other stakeholders who conduct, review, or manage protection programs and need to understand the U.S. Nuclear Regulatory Commission (NRC) research and planned research related to energetic electrical faults.

KEY RESEARCH QUESTION:

How can the NRC ensure that future research programs on the aluminum high energy arcing faults (HEAF) hazard accurately reflect plant conditions and will produce usable results?

RESEARCH OVERVIEW:

Energetic electrical faults can result in explosions, electrical arcing, fire, ionized gases, and smoke, prompting collateral damage to adjacent equipment and causing latent failures. The characteristics of these failures differ from those of the traditional fire protection hazard assessment, including the bypass of the fire ignition and growth stages; rapid propagation of the fire to other equipment and across vertical fire barriers; power system designs that are vulnerable to station blackout; failed fire-suppression attempts with dry chemicals and the need to use water; longer restoration time to recover; and unexpected challenges to operator response from event byproducts (smoke and conductive gases). These highly energetic events that have the potential to impact plant safety are commonly referred to as High Energy Arcing Faults (HEAFs).

NRC regulations, regulatory guidance, and defense-in-depth design philosophy exist to provide reasonable assurance of adequate protection to public health and safety from the consequences of fires that may occur in a nuclear facility. In the early 2000s, the NRC investigated the insights gained from fire incidents and began an international collaborative effort to better understand operating experience as it relates to fire safety. This collaboration resulted in a series of tests conducted in the United States between 2014 and 2017 to support revisions and improvement to existing fire risk methods. The results demonstrated a unique failure mode for electrical equipment that contained aluminum components, which displayed more damage than revealed in tests conducted on equipment that did not contain aluminum.

These insights prompted the NRC and its international research partners to pursue additional testing.

The NRC issued Information Notice 2017-04, High Energy Arcing Faults in Electrical Equipment Containing Aluminum Components, dated August 21, 2017, to alert addressees of the test results and related operating experience. The NRC staff also proposed this potential safety issue as a generic issue (GI) (PRE-GI-018). In order to adequately assess PRE-GI-018, the NRC needed additional information and decided to hold a workshop to communicate this issue and obtain feedback and information from stakeholders.

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The motivation for holding this workshop was to communicate the NRCs past and planned actions related to the HEAF hazard involving aluminum components. Additionally, the NRC sought feedback from stakeholders to support realistic and representative test conditions to ensure the efficient and effective use of NRC resources as the agency assesses the impact of HEAFs involving aluminum components. The workshop objectives were to (1) inform interested stakeholders about the status of PRE-GI-018 and related research, (2) review and resolve public comments received on the phase II draft test plan, (3) solicit and review information from industry partners regarding common equipment types and configurations to inform future testing, and (4) provide an opportunity for public feedback on future testing. In particular, the technical issues focused on the test parameters that influence the HEAF phenomena, and many discussions during the workshop focused on realistic and representative parameter ranges and nuclear power plant electrical system configurations.

The NRC staff from the Office of Nuclear Regulatory Research organized the workshop in collaboration with the Electric Power Research Institute (EPRI) and the National Fire Protection Association (NFPA). Staff from DNV GL, the National Institute of Standards and Technology (NIST), and Factory Mutual (FM) also provided feedback and direction for organization of the workshop. The NRC welcomed the public to attend and observe this Category 3 public meeting and posting workshop information on the agencys Public Meeting website. About 30 workshop registrants attended the workshop in person. In addition, approximately 33 individuals participated in the workshop via a webinar advertised on the NRC Public Meeting website.

KEY FINDINGS:

In the opening session, the NRC presented the expected outcomes of the workshop. Next, an introduction session welcomed the participants and identified the workshop purpose, objectives, and agenda and emphasized the NRCs safety mission. This was followed by a presentation that reviewed past agency efforts and research related to the HEAF hazard. Following this presentation, the NRC discussed the GI program and gave a presentation on the status of PRE-GI-018 related to the aluminum HEAF issue. Before concluding the morning sessions, presenters spoke about the development of HEAF definitions, small-scale testing, and risk assessment modeling implications. The afternoon sessions focused on research undertaken outside the NRC. This included presentations from the NFPA, EPRI, and DNV GL. The second day of the workshop included extensive discussion among the participants related to the parameters and test configurations that would support realistic and representative configurations to characterize the HEAF hazard and develop data to support the assessment of the HEAF hazard as it relates to the influence of aluminum components. Part of this discussion allowed for voluntary participation in ranking various parameters for their importance in influencing the HEAF phenomena. The NRC and partners could use results from this ranking to support test plan revisions and experimental configurations during future testing. The final sessions of the workshop revolved around the draft full-scale testing being pursued as an international initiative under the Nuclear Energy Agency (NEA) / Organisation for Economic Co-Operation and Development (OECD). The final session focused on a presentation of the draft test plan and resolution of comments received during the public comment period.

As a result of the workshop, the NRC identified several recommendations and follow-up actions, including the following:

improvements to project tracking and task dependencies xii

NRC expectations and schedule related to the pilot plant initiative to support the assessment stage of the GI program suggestion to perform a literature search to allow for better communication and basis for specific aspects of the proposed testing proposed changes to testing configurations and parameters follow-on interactions with stakeholders to communicate findings in a timely manner definitions of the hazard and associated frequencies that would support test result applicability to ensure consistent treatment of the hazard in a risk assessment WHY IT MATTERS:

This report provides recommendations to assist the NRC staff and stakeholders in performing needed research and work to assess the impact of aluminum components on the HEAF hazard and the assessment of that hazard related to plant safety.

HOW TO APPLY RESULTS:

Engineers conducting research related to this topic should focus on Chapters 3-8 and 10.

Users of this report are also encouraged to consult the reference material identified in Section 1.3 and included in the companion DVD.

LEARNING AND ENGAGEMENT OPPORTUNITIES:

Users of this report may be interested in the annual fire PRA training, Module III, Fire Hazard Analysis, sponsored jointly between EPRI and the NRC Office of Nuclear Regulatory Research.

In addition, numerous commercial training opportunities are available related to the analysis of arc flash hazards for personnel safety.

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ACKNOWLEDGMENTS The U.S. Nuclear Regulatory Commission acknowledges and appreciates the many people and organizations that supported the Information-Sharing Workshop on High Energy Arcing Faults (HEAFs). Those who attended that workshop in person and via the webinar provided exceptional feedback and included the following:

Ashley Lindeman (EPRI) Donna Gilmore Brenda Simril (TVA) Marvin Lewis Robert Rhodes (Duke Energy) Marc Janssens (SWRI)

Rob Cavedo (Exelon) Dane Lovelace (Jensen Hughes)

Francisco Joglar (Jensen Hughes) Chris Riedl (TVA)

Daniel Funk (Jensen Hughes) Victor Savulyak (DNV GL)

Jana Bergman (Curtiss Wright) Robert Taylor (BSI)

Francesco Pellizzari (EPM) Jeffrey Voskuil (Entergy)

Stephen Turner (Consultant) Sandy Naccarato (Southern Company)

Scott Bareham (NIST) JongSeuk Park (KINS)

Rodney Pletz (AEP) Joshua Ross (First Energy Corporation)

Mathew Merriman (Appendix R Solutions) Neal Simmons (Duke Energy)

Beth Wetzel (TVA) Keith Vincent (FPL)

Jens Alkempes (FM Global) Kiang Zee (Jensen Hughes)

Sujit Purushothaman (FM Global) Preston Cooper (TVA)

Thomas Shudak (NPPD) Mike Franovich (NRC)

Kenneth Fleisher (EPRI) Steven Alferink (NRC)

Anthony Putorti (NIST) Philipp Braaten (NRC)

Kazimierz Leja (Exelon) William Monk (NRC)

Victoria Anderson (NEI) Tomy Nazario (NRC)

Jack Campellone (Duke Energy) Sam Graves (NRC)

Alex Feldman (DNV GL) Gregory Werner (NRC)

Robert Egli (TVA) David Stroup (NRC)

Scott Groesbeck (DP Engineering) Robert Daley (NRC)

Mark Hulet (APS) Tomy Nazario (NRC)

Young Jo (Southern Company) Bas Verhoeven (DNV GL)

David Lochbaum (UCS) Frank Cielo (DNV GL)

Bob Meyer Alice Muna (SNL) xv

ABBREVIATIONS AND ACRONYMS AC alternating current ADAMS Agencywide Documents Access and Management System AL aluminum AT auxiliary transformer AWG American Wire Gauge BSI Brendan Stanton Inc.

CCDP conditional core damage probability CDF core damage frequency CFD computational fluid dynamics CFR Code of Federal Regulations CIGRE International Council on Large Electric Systems CSNI Committee on the Safety of Nuclear Installations DC direct current EELS electron energy loss spectroscopy ERFBS electric raceway fire barrier systems EPRI Electric Power Reseach Institute EDXA energy dispersive x-ray analysis FAQ frequently asked question GDC general design criterion/criteria GI generic issue GIRP Generic Issue Review Panel GSU generator step-up HEAF high energy arcing fault HGL hot gas layer HRR heat release rate IEC International Electrotechnical Commission IEEE Institute of Electrical and Electronics Engineers IN information notice ISO International Organization for Standardization KINS Korea Institute of Nuclear Safety LER licensee event report LV low voltage MOU memorandum of understanding MV medium voltage NEA Nuclear Energy Agency NEI Nuclear Energy Institute NFPA National Fire Protection Association NIST National Institute of Standards and Technology NPP nuclear power plant xvii

NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSP non-suppression probability OECD Orginisation for Economic Co-operation and Development OpE or OPEX operating experience OSHA Occupational Safety and Health Administration PIRT phenomena identification and ranking table PRA probabalistic risk assessment RES Office of Nucear Regulatory Research ROI Regulatory Office Implementation RTPC Research and Testing Planning Committee SEM scanning electron microscopy S/NRA/R Secretariat of Nuclear Regulation Authority (Japan)

SNL Sandia National Laboratories SPAR standardized plant analysis risk STL short-circuit testing liason SWRI Southwest Reasearch Institute T&D transmission and distribution TPP test procedure and protocol UCS Union of Concerned Scientists ZOI zone of influence xviii

1 INTRODUCTION

1.1 Background

The U.S. Nuclear Regulatory Commission (NRC) fire protection requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, (Ref. 1) and the supporting guidance address fire from energetic faults.

For example, 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion 3, Fire Protection, requires that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effects of fires and explosions. The requirements in 10 CFR 50.48, Fire Protection, state that each operating nuclear power plant must have a fire protection plan that satisfies General Design Criterion 3 of Appendix A to 10 CFR Part 50.

Section 4.1.3.6, Electrical Cabinets, of NRC Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, Revision 3, issued February 2018 (Ref. 2), states that electrical cabinets present an ignition source for fires and a potential for explosive electrical faults that can result in damage not only to the cabinet of origin, but also to equipment, cables, and other electrical cabinets in the vicinity of the cabinet of origin. Regulatory Guide 1.189 also states that fire protection systems and features provided for the general area containing the cabinet may not be adequate to prevent damage to adjacent equipment, cables, and cabinets following an energetic electrical fault; therefore, cabinets with voltages of 480 volts and above should have adequate spatial separation or substantial physical barriers to minimize the potential for an energetic electrical fault to damage adjacent equipment, cables, or cabinets important to safety.

Fire probabilistic risk assessments (PRAs) include methods to characterize the high energy arcing fault (HEAF) hazard, as documented in Electric Power Research Institute (EPRI)

Technical Report (TR) 1011989/NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, issued September 2000 (Ref. 3). Volume 2 of NUREG/CR-6850 contains the guidance for electrical enclosures (Appendix M), and Supplement 1 (Ref. 4) contains guidance for bus ducts (Chapter 7). Both methods provide a bounding approach to quantifying the HEAF hazard; that is, they assume physical damage zones based on available operating experience that demonstrated extensive damage to surrounding equipment. Although the details of each method are documented in the reference identified above, the methods generally assume all components and systems within the physical damage zone are ignited and are unable to perform their intended design function. Accordingly, these methods were considered conservative and bounding for future arcing fault events.

Starting in the mid-2000s, the NRC began international collaboration to better understand the HEAF phenomena and advance the existing state of knowledge and fire PRA methods. This collaboration was facilitated through the Nuclear Energy Agency (NEA)/Organisation for Economic Co-operation and Development (OECD), of which the NRC is a member. Under an OECD FIRE data exchange project, member countries share operating experience related to fires occurring at nuclear facilities in 12 countries. As part of the analysis of this data, a non-negligible number of reportable events with non-chemical explosions and rapid fires resulting from high energy arcing faults (HEAF) was observed (Ref. 5). As a result of this observation and in alignment with the major goals of the NEA/OECD task to develop a correlation for predicting damage, establishing input data, and establishing boundary conditions for more detailed modeling, the member countries recommended performance of a series of experiments.

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From 2014 to 2016, the NRC led an international experimental program, as documented in NEA/CSNI/R(2017)7, Report on the Testing Phase of High Energy Arcing Fault Events (HEAF)

Project, issued May 2017 (Ref. 6). This report documents 26 HEAF tests that were performed on a variety of donated electrical equipment. One significant finding from this work was that HEAFs involving aluminum components may result in greater damage and different failure modes than HEAFs that do not contain aluminum. Based on these findings, the international group recommended additional testing.

In 2016, based on the results from testing indicating that the current fire PRA methodology may not be bounding, the NRC staff proposed a potential safety concern related to HEAFs involving aluminum as an issue for the NRCs Generic Issue (GI) program. Following an initial review and a formal screening review, a Generic Issue Review Panel (GIRP) determined that the proposed issue met all seven screening criteria of the GI program and recommended that the issue be moved into the assessment stage of the GI program. As part of that assessment stage, a number of actions were identified that will be performed to assess the potential risk impact associated with HEAFs involving aluminum. These actions include, in part, additional testing.

These findings also prompted the NRC staff to reevaluate operating experience and identify any HEAF events that involved aluminum components. The staff documented the results of this effort in Information Notice (IN) 2017-04, High Energy Arcing Faults in Electrical Equipment Containing Aluminum, issued August 2017 (Ref. 7). This IN summarizes the test results where damage states exceeded existing guidance and involved aluminum components. Additionally, the IN summarizes six HEAF events from operating experience that involved aluminum components and provides a qualitative description of those events.

Given the NRCs desire to understand the HEAF hazard involving aluminum and ensure adequate protection of public safety, external stakeholders have developed information to better understand and model the hazard. These initiatives include NRC Frequently Asked Question (FAQ)17--0013, High Energy Arcing Fault (HEAF) Non-Suppression Probability (NSP), dated March 21, 2017 (Ref. 8). EPRI has also developed two whitepapers (Refs. 9, 10) that provide an overview of nuclear power plant electrical distribution systems and characterize operating experience and testing.

In 2017, the NRC staff began formalizing an international agreement to perform a Phase II testing campaign to address knowledge gaps and further explore the impact aluminum plays in HEAF events. The NRC issued a draft test plan for public comment in the Federal Register on August 2, 2017. However, in order to ensure that U.S. interests are met and the program is performed in an efficient and effective manner, the NRC staff decided that additional stakeholder interactions and feedback were warranted. As such, it was suggested that an HEAF workshop be held as the forum for this interaction. The workshop took place April 18-19, 2018, at the NRC Headquarters offices in Rockville, MD. This report documents that workshop, the discussions held, and the feedback received.

1.2 About This Report This report is a collection of the materials presented at the 2-day workshop held April 18-19, 2018. The workshop transcripts (Refs. 11, 12) are available in the NRCs Agency-wide Documents Access and Management System (ADAMS) under Accession Nos.

ML18114A817 and ML18114A818. The companion DVD also includes these transcripts.

1-2

In addition to the workshop materials and transcripts, the companion DVD includes a variety of documents related to the HEAF research program, including the following:

test footage and data from Phase 1 testing FAQs, INs, and GI communications related to HEAF licensee event reports (LERs) from relevant HEAF events small- and large-scale draft test plans and comments This report documents the material sequentially as it was presented during the workshop. For each session, this report includes a brief summary of any formal presentation, followed by documentation of discussion points, recommendations from those discussions, and any follow-up action items. Each chapter ends with the slide deck as presented, reproduced as embedded images.

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2 WELCOME AND OPENING 2.1 Workshop Opening Michael Cheok, Director of the Division of Risk Analysis in the NRC Office of Nuclear Regulatory Research, opened and welcomed everyone to the workshop. Mr. Cheoks key message was to encouraged participation to promote realistic and representative research that will support the NRC staff assessment of the proposed GI on aluminum HEAFs. Mr. Cheok thanked everyone for their time and dedication to this important effort and noted that the experience and expertise in the room are greatly valued as the NRC moves forward to ensure safety for NRC-licensed facilities, as well as the larger industrial community.

2.1.1 Discussion No discussions from the participants occurred during or immediately after the opening. The Workshop Opening presentation is documented on pages 5-8 of the Day 1 transcript. No recommendations or follow-up actions were identified from this session.

2-1

2.1.2 Presentation Slides 2-2

2-3 2.2 Workshop Introduction and Objectives Mark Henry Salley, Chief of the Fire and External Hazards Analysis Branch in the Office of Nuclear Regulatory Research, welcomed the attendees and presented the workshop purpose and objectives, an outline of the agenda, and proposed path forward. Mr. Salley emphasized the need to develop a long-term, risk-informed, defense-in-depth solution to serve the NRCs mission and ensure public health and safety. Mr. Salley also noted that the openness and collaboration sought through the workshop will serve a much larger engineering community to promote safety.

2.2.1 Discussion No discussions from the participants occurred during or immediately after the opening. The Workshop Introduction and Objectives presentation is documented on pages 13-18 of the Day 1 transcript. No recommendations or follow-up actions were identified from this session.

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2.2.2 Presentation Slides 2-5

2-6 2-7 2-8 3 REVIEW OF PHASE I HEAF RESEARCH 3.1 Review of Phase I HEAF Research Nicholas Melly, Fire Protection Engineer in the Office of Nuclear Regulatory Research, and Mark Henry Salley presented a high-level review of the Phase 1 testing performed under the international agreement with NEA/OECD. The presentation addressed the types of fire hazards and their contribution to plant risk, referencing an EPRI skyline charge that EPRI presented at the NRCs Regulatory Information Conference in March 2018. The data indicate that, in general, HEAFs are the third largest contributor to plant fire risk as estimated by fire PRAs.

Mr. Melly communicated the basics of how fire PRAs partition fire ignition sources into different bins and explained the differences between Bin 15 fires that are associated with thermal electrical enclosure fires and Bin 16 HEAFs that are much different and more energetic that the classical thermal fire postulated in Bin 15. A key point of this discussion was the lessons learned from Bin 15, electrical enclosure thermal fires and how they would apply to Bin 16, HEAFs. For Bin 15 fire ignition sources, the bin contains a broad range of fire ignition sources from low-voltage controls to medium-voltage switchgear. This broad range has resulted in difficulties quantifying the associated heat release rate (HRR) profile and detection and suppression assessments. Reviews of operating experience and test results have indicated that the HEAF hazard has varying levels of severity and, as such, Mr. Melly proposed that realistic divisions for Bin 16 be developed to improve fire PRA characterization of the HEAF hazard potential. To ensure continuity within the fire PRA definitions of the specific energetic fault, divisions are needed to ensure consistency in frequency estimation, hazard postulation, and hazard mitigation or fire suppression. Presentations on the draft set of definitions were discussed later in the day and can be found in Chapter Error! Reference source not found. of this report.

The presentation included several sets of slides containing photographs of energetic fault events or testing results. The photographs included events that would be classified as arc flashes, arc blasts, and HEAFs. Mr. Melly summarized the duration of several HEAF events, including both domestic and international operating experience. The duration of an energetic arcing event is a key parameter the influences its damage potential. The durations observed from operating experiences were much longer than would be expected for a typical electrical protection to clear a fault. This indicates that electrical protection does not always work as expected because of several failure mechanisms.

The presenters gave the background of the HEAF research program. Deliverables included several NEA/OECD technical reports related to operating experience exchange (NEA/OECD/R(2013)6) and a review of methods to estimate HEAF damage (NEA/OECD/R(2015)10) (Ref. 13).

Mr. Melly next presented an overview of the Phase I testing. This included information on the experimental configuration, videos of several HEAF tests with a comparison between testing involving aluminum and not, and a summary of the test report documented in NEA/OECD/R(2017)7.

The presenters briefly discussed mitigation measures, such as shields. Mitigation measures are intended to limit the extent of damage from HEAF events to plant targets that could impact the plants ability to achieve safe and stable conditions. Although the intent of these measures is 3-1

genuine, several questions were posed as to their design basis, acceptance/rating/qualification test method, and a general deviation from regulatory acceptance of classical fire-protective features such as fire barriers (walls and floors), fire doors and dampers, penetration seals, and electric raceway fire barrier systems. Additional photographs of testing results showed that existing assumptions on mitigation measure may not serve their intended purpose.

Mr. Melly briefly discussed PRE-GI-018, which was covered in more detail later in the day (see Chapter Error! Reference source not found. of this report), and IN 2017-04, which informed addressees of operating experience and test results pertaining to the magnitude of arc fault hazards in electrical equipment containing aluminum.

The final portion of Mr. Mellys presentation covered recently completed research. In January 2018, the NRC issued NUREG-2218, An International Phenomena Identification and Ranking Table (PIRT) Expert Elicitation Exercise for High Energy Arcing Faults (HEAFs), (Ref. 14) which documented a PIRT to better understand the parameters that influence the HEAF phenomena. Conclusions from this work included the need to focus HEAF research to support fire PRA applications, characterize target fragility, understand mitigation measures that support the defense-in-depth safety philosophy, understand the characteristics of the ensuing fire, and characterize the HEAF source term and pressure effects. Lastly, Mr. Melly summarized the International Agreement Report (Ref. 15), which documents a series of testing the Secretariat of the Nuclear Regulation Authority (S/NRA/R) performed.

3.1.1 Discussion Following a presentation on the Phase I HEAF testing, Stephen Turner asked if the conductivity of the HEAF-generated aerosol was evaluated. Mr. Melly and Mr. Cielo confirmed that there was no post-test evaluation of that byproduct. The Review of Phase I HEAF Research presentation is documented on pages 19-58 of the Day 1 transcript. No recommendations or follow-up actions were identified from this session.

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3.1.2 Presentation Slides 3-3

3-4 3-5 3-6 3-7 3-8 3-9 3-10 3-11 3-12 3-13 3-14 3-15 3-16 3-17 3-18 3-19

4 THE GENEREIC ISSUE PROCESS AND PILOT PLANTS 4.1 The Generic Issue Process Thomas Boyce, Chief of the Regulatory Guidance and Generic Issues Branch in the Office of Nuclear Regulatory Research, provided an overview of the GI program. The presentation included a discussion of the origins and purpose of the GI program, the programs three stages (screening, assessment, and implementation), and the roles and responsibilities of various NRC staff members. Mr. Boyce clarified that a proposed GI does not become a GI until both the screening and assessment stages have been completed and the issue is transitioned to the appropriate regulatory office for implementation. Mr. Boyce closed his presentation by identifying resources for additional information, including NUREG-0933, Resolution of Generic Safety Issues, (Ref. 16) and the GI dashboard on the NRCs public website.

4.1.1 Discussion During this presentation, the attendees asked several questions. Beth Wetzel asked whether the limited regulatory analysis would go out for public comment. Mr. Boyce answered that the process allows for the memorandum to be made publicly available but not for public comment.

The public would have an opportunity to comment during the development process for the regulatory action selected to address the GI. A second attendee asked where the backfit process fits into the GI process. Mr. Boyce indicated that if a pre-GI moves past the assessment stage and the transition team decides that action is warranted, the backfit process would occur at the appropriate point in the development process for the regulatory action selected to address the GI.

The Generic Issue Process presentation is documented on pages 58-80 of the Day 1 transcript.

No recommendations or follow-up actions were identified from this session.

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4.1.2 Presentation Slides 4-2

4-3 4-4 4-5 4-6 4-7 4.2 Aluminum HEAF PRE-GI-018 Stanley Gardocki, Senior Reactor Engineer in the Office of Nuclear Regulatory Research, presented on the topic of Generic Issue PRE-GI-018, High Energy Arc Faults Involving Aluminum. The presentation provided an overview of the GI stages, a summary of completed actions, a list of short- and long-term actions, and the status of progress associated with these actions. PRE-GI-018 is currently in the assessment stage of the process, having met all seven screening criteria of the screening process. The GIRP recommended a phased approach, whereby both short- and long-term actions were identified as possible requirements to perform the assessment. Mr. Gardocki reported that the NRC received an informal survey from the Nuclear Energy Institute (NEI) on the extent of aluminum components currently installed in nuclear power plants. The NRC will invite experts to support a joint industry/NRC expert elicitation process, possibly through the EPRI memorandum of understanding (MOU), to develop interim guidance to support performance of focused-scope risk assessments for a select number of pilot plants containing aluminum components susceptible to HEAFs. Lastly, Mr. Gardocki indicated that a complete assessment of aluminum-involved HEAF phenomena would require additional testing and refinements to the methods used to assess risk.

Presentations and discussion on future testing was the focus of Day 2 of the workshop.

4.2.1 Discussion During this presentation, the attendees asked several questions, summarized as follows with responses:

With regard to the international review of plant equipment, what was the level of rigor and detail of that assessment, whether they do or do not have aluminum?

o It varied from country to country. Finland did have some aluminum, while Germany indicated that only one of its plants had aluminum, and it was shut down.

o Other participants indicated that the use of aluminum in new installation is increasing globally. This is happening for a variety of components, including transformers, distribution equipment, and cables for a variety of facility and distribution types.

With regard to the probabilities and frequencies, what does it mean that the NRC will calculate potential risk increase?

o As part of the GIRP process, the assessment team will have to assess the increase in risk to the plant from the aluminum HEAF hazard. This assessment includes reevaluation of the frequency of occurrence (based on the definitions being revised to better characterize the HEAF hazard) and the probabilities of damage for a specific plant (based on revised HEAF hazard assessment).

Is PRE-GI-018 only being approached strictly from a fire PRA perspective or is the NRC questioning the Class 1E traditional separation criteria acceptability?

o The GI includes plants licensed with either deterministic or performance-based fire protection programs. The NRC is focusing the initial effort on the performance-based side because the information from that effort can directly 4-8

support resolution for deterministic plants. The separation criteria will be evaluated once more information and data are collected.

The Aluminum HEAF PRE-GI-018 presentation is documented on pages81-106 of the Day 1 transcript.

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4.2.2 Presentation Slides 4-10

4-11 4-12 4-13 4-14 4.3 Pilot Plants Nicholas Melly presented on the need for pilot plants to support PRE-GI-018 during the assessment stage. Mr. Melly presented EPRI data on the key contributions to fire risk by ignition source from 27 different plants. The data indicate that, according to current risk assessment techniques, HEAFs are the third highest contributor to plant risk. Next, Mr. Melly showed that in preliminary risk assessments using available information and assumptions, an expanded HEAF impact from aluminum would increase plant risk. The analysis contained both conservative and non-conservative assumptions because of the lack of detailed scenario information. However, without plant-specific information, there is a limit to the amount of realism that such an analysis could produce. Therefore, to provide improved estimates, the GIRP identified the need to perform focused-scope fire PRA assessments at a select number of pilot plants. Mr. Melly asked the attendees to identify volunteer plants that have aluminum to support the GIRP assessment. In addition, those plants selected should have unique HEAF scenarios modeled within their PRA. Plants that mapped HEAF scenarios to hot gas layer damage states are not ideal candidates for this evaluation.

4.3.1 Discussion During this presentation, the attendees asked several questions, summarized as follows with responses:

How many plants are needed for the pilot?

o An actual number has not yet been determined. The initial thoughts were three, but it would ultimately depend on the differences between scenarios among the plants.

Will the pilot effort be done with HEAF ignition frequencies corrected or just adjusting the zones of influence without adjusting the frequencies?

o If new HEAF frequencies are developed that have been vetted through a regulatory process, such as the NRC FAQ process or a joint research effort between EPRI and the NRC Office of Nuclear Regulatory Research with NRC acceptance, then they will be used. It makes sense to use all available information and methods at the time of the assessment. It is ultimately an issue of timing.

o Along these lines, it is also important to have continuity throughout the risk assessment process so that the frequencies match the hazard being assessed or modeled.

It would be important to understand any latent sources of conservatism in the pilot results before further decisions are made related to the GI treatment.

o Mr. Melly agreed with this statement.

What is the schedule for performing these pilot plant assessments?

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o Typically, the assessment stage should be completed within a 2-year period.

Given that the NRC is approximately 6 months into this stage, the assessment stage is expected to be completed in the next 18 months.

What is the benefit to a plant for volunteering to be a pilot?

o Without pilots, the program will have to resort to using the conservative analysis that was presented earlier, the results of which look very unappealing. This may cause the NRC to make decisions that are resource intensive for both the agency and the industry and that may not improve risk as much as expected.

The interim zone of influence (ZOI) and the other HEAF-related fire PRA modeling improvements, such as frequency, should dovetail together to support the pilot plant assessment. If the NRC agrees with that, some confusion remains as to the schedule and how these tasks outlined in the GI screening letter fit together.

o Mr. Melly agreed with this statement.

It is also important to show some logical linking between the GI milestones and how they are related and scheduled together.

o Mr. Melly agreed with this statement.

Current PRA results are constrained by methods acceptable to the authority with jurisdiction. Would methods the GI assessment team proposes impose the same constraints? For licensees to commit to the pilot plants, there needs to be some level of assurance that constraints on acceptable methods will not drive the results.

o The GI assessment will likely be performed much like a sensitivity study, rather than something that is going to inform plant changes. If any changes to existing acceptable methods were an outcome of the GI assessment stage, then the assessment team would make a recommendation for the Regulatory Office to consider when that office is resolving the GI.

There are several nuances to what and how current HEAFs vs. classical fires are modeled, and it will be important for industry to identify pilot plants that have the right modeling and insights to help provide the best information.

o Mr. Melly agreed with this statement.

Adding conservatism will show unrealistic results and will make finding pilot plants difficult. If the NRC proposes something that is at least in the ballpark, then the likelihood of licensees volunteering for a pilot plant and collecting meaningful data will increase.

o The NRC staff envisions the pilot plant focused-scope risk assessment to be a collaborative effort in order to better understand the risk and instill realism into the process with the expert elicitation.

The Pilot Plants presentation is documented on pages 106-133 of the Day 1 transcript.

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4.3.1.1 Recommendations It would be helpful for project tracking and status of the GI program to have a schedule of when specific actions are expected to be completed and any relationship between the individual action items (i.e., dependencies).

In order for EPRI or NEI to better support the pilot plant initiative, they would need to understand the NRCs expectations for a pilot plant. A timeline or schedule would also be useful.

In addition to better characterize the HEAF ZOI, associated HEAF frequency, binning, and suppression modeling improvements are needed to ensure a consistent risk assessment methodology.

4.3.1.2 Follow-up Actions Develop a tentative schedule for PRE-GI-018 action items.

Show dependencies between and among action items.

Develop a charter for the pilot plant focused-scope HEAF assessment.

Develop revised HEAF binning (definitions) and frequency estimates.

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4.3.2 Presentation Slides 4-18

4-19 4-20 4-21 4-22 5 DEFINING THE HAZARD 5.1 Definitions of Energetic Electrical Faults Kenn Miller, Team Leader in the Office of Nuclear Regulatory Research, gave a presentation on definitions of energetic electrical faults. The purpose of documenting clear definitions is to ensure a common understanding of the various types of energetic electrical faults and to ensure a consistent assessment of those energetic electrical faults that pose a substantial risk to plant safety. The proposed definitions evolved from established definitions from consensus standards. Mr. Miller proposed three severity classes for arc faults:

(1) Class 1: Arc Flash Damage is contained within the general confines of the component of origin.

(2) Class 2: Arc Flash/Blast/HEAF Damage is contained within the general confines of the component of origin. However, arc blast effects have the potential to damage surrounding equipment through pressure-rise effects (i.e., severe equipment deformation, thrown doors, degraded fire barriers).

(3) Class 3: Arc Blast/HEAF Damage includes the component of origin as well as the surrounding equipment within the fire zone. This damage includes pressure-rise effects (i.e., severe equipment deformation, thrown doors, degraded fire barriers), which potentially can affect equipment in other fire zone(s).

5.1.1 Discussion During this presentation, the attendees asked several questions, summarized as follows with responses:

The definitions do not make reference to the minimum voltage level or power level to be classified as a HEAF hazard. A voltage of 120 volts or lower will not have enough energy to cause the types of damage discussed.

o Mr. Miller agreed with this statement.

A tremendous amount of research was done on the threshold for a sustained arc. So instead of testing to the lower end, it may be worthwhile to perform a literature search to inform the agencys judgment.

o Mr. Miller agreed with this statement.

Typically, faults lasting for several seconds occur because there are several protection failures. This should be referred to as multiple circuit failure protection.

o Mr. Miller agreed with this statement.

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The Definitions of Energetic Electrical Faults presentation is documented on pages 139-163 of the Day 1 transcript.

5.1.1.1 Recommendations Perform literature search.

Tie EPRI into the discussion between the NRC and National Fire Protection Association (NFPA) members on the definitions.

5.1.1.2 Follow-up Actions Conduct a literature search.

Refine the definitions based on feedback from 2- and 3-second time durations of switchgear and breakers, respectively.

Include EPRI in future collaboration on refinements to the definitions.

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5.1.2 Presentation Slides 5-3

5-4 5-5 5-6 5-7 5-8 6 SMALL-SCALE TESTING AND PROBABILISTIC RISK ASSESSMENT MODELING IMPLICATIONS 6.1 Small-Scale Testing at Sandia National Laboratories Gabriel Taylor of the Office of Nuclear Regulatory Research delivered a presentation on the small-scale testing being performed at Sandia National Laboratories (SNL). Mr. Taylor explained the reason for pursuing small-scale testing, including to minimize experimental variation, take measurements close to the arc, and characterize the particulate size near the arc where the exothermic reaction occurs for aluminum. Mr. Taylor identified the expectations of this testing and the means for accomplishing them, both experimentally and post analytically.

Mr. Taylor gave an overview of the test matrix and the variety of parameters SNL was testing to understand their impact. He discussed the public comment period for the draft test plan (see Appendix D), which closed on April 4, 2018. Mr. Taylor indicated that he would add any comments received via e-mail (Gabriel.Taylor@nrc.gov) by May 4, 2018, to the agency document management system, and that the NRC/SNL team would review the comments for incorporation, as appropriate.

6.1.1 Discussion During this presentation, the attendees asked several questions, summarized as follows with responses:

Given the short duration of these experiments, they are more similar to direct current (DC) rather than alternating current (AC).

o Mr. Taylor agreed with this statement. The limitation of the arc duration does not allow for a true sinusoidal current profile.

How is the change of current being made?

o The laboratory is using a motor generator in conjunction with inductors and capacitors to achieve the desired current and duration.

The test matrix appears to be missing some information. Tests 8, 12, and 16 do not indicate whether they are AC or DC.

o Mr. Taylor agreed that this is an error.

The NRC questioned the need to perform the DC tests given the limitation on available current to 300 amperes.

o Feedback from the attendees indicated that it was worthwhile to explore DC arcing, given the lack of the zero crossing point and research that indicates that DC arcing events can be severe.

Will the testing be able evaluate isophase voltages (approximately 22kV )?

o The NRC staff is unsure of SNLs capabilities and will confer with the laboratory.

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Will the testing be phase to phase or phase to ground?

o The voltage across the bus bars will be the phase-to-phase voltage.

Will 480V testing bound the 600V testing?

o The 480V will not bound the 600V tests. The purpose of these tests is to evaluate particulate size, and testing at 480 volts will provide some data at the low-voltage level. A voltage of 480 is more common than a voltage of 600 in U.S. nuclear power plant facilities.

Can the test results be extrapolated or interpolated to gain information on configurations (voltage) not tested?

o The NRC staff is unsure of SNLs capabilities and will confer with the laboratory.

Arc voltage is more important than system voltage. Bus spacing has a first-order effect on arc voltage. The focus should be on the parameter variation on gap spacing rather than system voltage.

o The team will consider changing the three levels of medium voltage to a single medium voltage (system voltage) and vary the bus spacing.

The Small-Scale Testing at SNL presentation is documented on pages 164--191 of the Day 1 transcript.

6.1.1.1 Recommendations Consider changing system voltage to bus bar spacing as a parameter of importance for the medium-voltage tests.

6.1.1.2 Follow-up Actions Determine whether SNL can perform at isophase bus voltages and, if so, whether it is worth including in this effort.

Determine the possibilities for the extrapolation or interpolation of test results.

If needed, perform a public webinar to communicate the results of the small-scale testing.

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6.1.2 Presentation Slides 6-3

6-4 6-5 6-6 6-7 6-8 6-9 6.2 Probabilistic Risk Assessment Modeling Implications Gabriel Taylor of the Office of Nuclear Regulatory Research gave a presentation on PRA modeling implications. Mr. Taylor provided an overview of the current methods to quantify the HEAF hazard, documented in EPRI TR-1011989 and NUREG/CR-6850, Volume 2, and its Supplement 1. Mr. Taylor next provided an overview of three modeling approaches to improve realism and characterize the aluminum HEAF hazard. The first method is an update to the existing bounding model, whereby new data are used to update the existing method to ensure the model bounds all potential HEAF hazards. The second proposed approach would be an evolution of the bounding approach, whereby different categories could be devised by, for example, power, energy, voltage equipment type, or material, and then a specific method used to bound the individual categories. The third proposal would be to devise a dynamic model by using scenario-dependent source information (current, voltage, bus bar gaps) to characterize the source term, and then evaluating target damage on a scenario-dependent case. In this last case, the physical damage zone is dependent on the source and target characterization. Mr.

Taylor provided information on the advantages and disadvantages of the various approaches, along with qualitative cost differences. He indicated that the choice of an adequate approach must be a balance between realism and cost and time.

6.2.1 Discussion During this presentation, the attendees made several comments, summarized as follows:

There appears to be two schools of thought on the modeling of these arcing events: (1) those that use Institute of Electrical and Electronics Engineers (IEEE) 1584, IEEE Guide for Performing Arc-Flash Hazard Calculations, (Ref. 17) to protect people and (2) those that use computational fluid dynamics (CFD) models. Japan has been performing CFD studies, and those appear to be matching up with the data fairly well; however, the durations appear to be short. Fluent has been used without the plasma physics model and is coming up with some good results. Although the NRC is not advocating to require licensees to use CFD to support licensing, those tools are available to support this research and possibly confirm experiments and fill gaps.

Much of the discussion has focused on the modeling of the source term, but there are also models that look at the result with respect to the target. There is a need to tie them together.

The PRA Modeling Implications presentation is documented on pages 191-206 of the Day 1 transcript. No recommendations or follow-up actions were identified from this session.

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6.2.2 Presentation Slides 6-11

6-12 6-13 6-14 7 NATIONAL FIRE PROTECTION ASSOCIATION PERSPECTIVE 7.1 Perspective from the National Fire Protection Association Mark Earley, Chief Electrical Engineer at NFPA, gave a presentation on the IEEE/NFPA Arc Flash Collaborative Research Project. The presentation provided an overview of NFPA, Federal electrical safety requirements, and formulation of the joint IEEE/NFPA Arc Flash Collaborative Research Project. Mr. Earley identified the projects goals, membership, and sponsorship and gave an historical perspective of the project. The next phase of NFPA research will focus on a comprehensive DC arc flash model. This model will focus on parameters such as power source configuration, voltage and current ranges, bus gaps, and materials. Mr. Earley identified the research approach to developing hypotheses and models, followed by performing scouting tests to provide preliminary validation of the models.

7.1.1 Discussion During this presentation, attendees asked several questions, summarized as follows with responses:

Everyone is here today because it has been noted that aluminum is problematic for a HEAF event. Given the large number of arcing experiments that the IEEE/NFPA cooperative has performed, the IEEE standard does not make a distinction between copper and aluminum. Please provide some background on why this is. Were there any differences in the teams tests?

o Mr. Earley noted that most of the tests were actually conducted with copper, which does splatter as well. Those in the fuse and circuit breaker industry are well aware of the aluminum issue and its implications.

The NFPA Perspective presentation is documented on pages 206-226 of the Day 1 transcript.

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7.1.2 Presentation Slides 7-2

7-3 7-4 7-5 7-6 7-7 7-8 7-9 7-10 7-11 7-12 7-13 7-14 7-15 7-16 8 ELECTRIC POWER RESEARCH INSTITUTE PERSPECTIVE 8.1 Perspective from the Electric Power Research Institute Ashley Lindeman of EPRI provided a presentation on EPRIs perspective on HEAFs. Ms.

Lindeman started by referencing the following EPRI white papers that were issued in 2017:

EPRI 3002011922, Characterization of Testing and Event Experience for High-Energy Arcing Fault Events (Ref. 9)

EPRI 3002011923, Nuclear Station Electrical Distribution Systems and High-Energy Arcing Fault Events (Ref. 10)

The EPRI work characterized the electrical distribution system into seven categories and provided a qualitative assessment of the impact and consequences given a HEAF. The team identified one vulnerability, the unit-connected design, in which a generator-fed electrical fault could progress for an extended duration as the generator coasts down. Ms. Lindeman summarized the operating experience from U.S. HEAFs and suggested that HEAF-initiating frequencies and HEAF ZOIs should be refined as suggested by the operating experience. Ms.

Lindeman also presented the statistics of the operating experience. This included identifying that more than 90 percent of HEAFs occur in non-safety related equipment, and less than 15 percent of HEAFs occur in low-voltage equipment (less than 1,000 volts). Ms. Lindeman also provided EPRI perspectives on the testing. These views included variations between low-voltage and medium-voltage equipment, variation on the amount of energy from aluminum tests, and threshold for aluminum involvement. Ms. Lindemans final topic involved the treatment of HEAF in fire PRAs. EPRI suggested that HEAF ignition frequencies be refined and scenarios be defined. Ms. Lindeman summarized the importance of HEAF events to both safety and economic consideration, the importance of optimizing overcurrent protection, and the need for proper maintenance to help prevent these events.

8.1.1 Discussion During this presentation, the attendees had several questions, summarized as follows with responses:

Did the database discriminate between events that involved aluminum and those that did not?

o The team did not consider that at this time. However, it may be something to consider when EPRI works with the NRC to refine the HEAF frequencies.

The presentation indicated that HEAF events in the United States represent approximately 2 percent of fires. Is this 2 percent relative to all fires or challenging fires?

o The 2-percent figure is relative to all fires that contribute to fire frequency; that is, all fires classified as challenging or potentially challenging.

The slides identify a wide variety and severity of events, stating, Not all HEAFs result in post-event fire. Most HEAF events only damage the equipment suffering the failure.

Would the cable be thermoplastic or thermoset?

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o The results did not have that level of clarity.

With regard to Slide 15, Fire PRA Treatment, could the NRC work with EPRI to support the GI and meet the need of the pilot programs so that the GI can reach the assessment stage of the GI program?

o Yes, however, it is unclear whether it would be EPRI or NEI.

Was the plant status considered during the assessment of the operating experience?

o Yes, most of the events occurred at power.

With regard to the categorization by safety class (Class IE vs non-Class IE), could this distinction be from normal loading as opposed to safety classification?

o The team discussed this but believes it has more to do with care and maintenance and some operational practices.

Did you evaluate differences between insulated and non-insulated buses?

o No. The licensee event report data were not ideal, but a subsequent analysis should try to drill down into more detailed information from the events to clarify the driver of these events.

Did the review of the events reveal any new insights or information related to event duration that has not already been identified in NRC documents such as IN 2017-04 or the draft test plan?

o This study focused less on the event review of duration but rather on how the protection schemes differed and whether there were failures in the protection.

The EPRI Perspective presentation is documented on pages 226-251 of the Day 1 transcript.

8.1.1.1 Follow-up Actions EPRI or NEI will support the NRC GI pilot plant assessment.

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8.1.2 Presentation Slides 8-3

8-4 8-5 8-6 8-7 8-8 8-9 8-10 8-11

9 PHYSICAL TESTING AND FAILURE RATES 9.1 Physical Testing and Failure Rates Bas Verhoeven, Director of Global Business Development and Innovation at DNV GL, gave a presentation on physical testing and failure rates. Mr. Verhoeven provided a high-level overview of the testing laboratories, including the KEMA facility in Pennsylvania, where the Phase II testing is planned to occur. Mr. Verhoeven then discussed certification as a risk mitigation measure. This included discussion of certification groups, protocol, and relationship to computer modeling as a surrogate to testing. The next topic covered was related to power system reliability and failures. The discussion identified causes of equipment failure, trending of equipment outages, failure modes of equipment, and failure rates. The final topic Mr.

Verhoeven covered was related to statistics on the failure rate during type testing. Roughly 25 percent of test objects initially failed type tests. The presentation included statistics by equipment classification and type, along with theory of operation and failure. A key point is that although a significant amount of research and testing has been performed, the knowledge from these efforts has gone into improving the business line rather than ensuring adequate equipment operating margin.

9.1.1 Discussion During this presentation, attendees asked several questions, summarized as follows with responses:

Is the high failure rate because the standard requires testing at 100 percent of the components rating, whereas in reality, the component may only be running at, for example, 60 percent?

o IEEE, the International Electrotechnical Commission, and the American Society for Testing and Materials standards require testing transmission and distribution components at their maximum rating as assigned by the manufacturer. While in service, these components normally have a lower loading; however, the components can be loaded by the utility up to the maximum rating; thus, the test requirements in the standards are realistic.

How many different cables are within each years dataset?

o The total dataset is 900 samples, so there are always at least 10 to 50 samples per year.

The Physical Testing and Failure Rates presentation is documented on pages 253-300 of the Day 1 transcript. No recommendations or follow-up actions were identified from this session.

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9.1.2 Presentation Slides 9-2

9-3 9-4 9-5 9-6 9-7 9-8 9-9 9-10 9-11 9-12 9-13 9-14 9-15 9-16 9-17 9-18 9-19 9-20 9-21 9-22 9-23 9-24 9-25 9-26 10 TEST PARAMETER AND EQUIPMENT SELECTION 10.1 Test Parameter and Equipment Selection Gabriel Taylor, Senior Fire Protection Engineer, and Kenn Miller, Team Leader, both in the Office of Nuclear Regulatory Research, led a presentation on NRC test parameter and equipment selection. The objective of the session was to solicit discussion and feedback from the audience on the NRCs Phase II test program, understand the range of operating (fault) conditions, and identify equipment configurations and types for inclusion in the test program.

Mr. Taylor gave a high-level overview of High Energy Arcing Fault (HEAF) Research, Needs and Objectives, dated March 23, 2018 (ADAMS Accession No. ML18081B300). The presenters communicated the goals and objectives of the NRC project and identified the parameters that the NRC believes influence the HEAF phenomena. Following the overview, the presenters discussed each parameter, including the data used to support the choice of test parameter range. After this discussion, the audience gave feedback, including whether they agreed on the selection of test parameters, as summarized in Section 10.1.1 . The presentation concluded with a discussion of equipment selection and bus bar test configurations. Mr. Taylor presented the proposed equipment to be supplied through an international agreement. This includes medium-voltage Magneblast breakers and switchgear from Korea and low- and medium-voltage switchgear from Germany. After the discussion on the test parameters, Nicholas Melly summarized the international PIRT documented in NUREG-2218.

10.1.1 Discussion During this presentation, attendees asked questions and provided comments and feedback, summarized as follows with responses:

Normally, low-voltage fault currents are much higher than identified in the tables in the presentation.

o Presently, the selection of fault currents for medium- and low-voltage tests is based on infinite bus calculations. The team took this approach because the NRC does not have the information needed to perform detailed studies of the plant-specific bolted fault currents. It should be noted that although the infinite bus (zero source impedance) assumption adds conservatism, the analysis does not account for motor contributions, a non-conservative assumption. Therefore, while these data have limitations, they should be considered a reasonable estimate of expected fault currents. In addition, the proposed fault currents of the test program are arcing fault currents. The bolted fault currents from the study were converted to arcing fault currents using the approach presented in IEEE 1584.

o Several attendees suggested that the proposed fault currents are likely realistic.

Nuclear plants are somewhat unique, in that their step-down transformers between medium and low voltage are typically small, from 750kVA up to the maximum of 2.5MVA, most are in the 1MVA range.

o One utility identified that its low-voltage fault current was in the range of 16kA or 18kA and typically feed off of a 1MVA transformer.

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What is the population of aluminum components in the plants? Is it both in 480V and 4,160V, or is it primarily in one application as opposed to another? This may be important when considering risk and the influence of separation among components.

o Based on the NEI informal survey (ADAMS Accession No. ML17165A140), the team is not able to determine the population by voltage level.

The NEI survey is anonymous, and the individuals in the room do not represent all U.S.

plants. Is there another effort to gather that information from the industry to ensure the testing is done correctly with regard to that configuration?

o The NRC would like to leverage the experts at the workshop, as well as industry support groups such as EPRI and NEI, to assist the program by providing information representative of plant configurations.

o Mr. Salley communicated the opportunity for stakeholders to provide input or actual equipment to the testing program to ensure realism.

When will the international agreement be signed and the tests locked down from further input?

o The current schedule is to have the agreement signed by the end of the summer 2018.

The low-voltage tests identify testing to either 4 or 8 seconds. What is the derivation of the 8-second figure?

o International operating experience has a low-voltage HEAF event that lasted for 8.5 seconds. One U.S. low-voltage event that was discussed earlier also lasted longer than 8 seconds.

Extensive discussion identified that although time-delay protection could clear a fault in 1 to 15 seconds, the proposed currents for the test program would not correlate to the high end of that range. Rather, the more realistic durations for low voltage would be in the 2-to 4-second range. Testing at 2 seconds would be a good lower end because it has ties to equipment ratings, and an upper level of 4 seconds would be consistent with some of the coordination studies that the workshop participants mentioned.

o A change of fault current from 4 to 8 seconds to 2 to 4 seconds will be proposed.

The testing should occur in the 1- to 2-second range, as the equipment is rated for this range.

o Although such a test would provide some information, it is not the type of information that the program is trying to obtain because those shorter durations would not appear as a HEAF event. Those events would typically be characterized as a non-HEAF event (Bin 15 fire) if the event met certain screening requirements to be included in the PRA ignition frequency.

Compared to the HRR profiles of traditional fires, does the energy release of a HEAF vary over the duration or is it essentially constant?

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o For the most part, the energy is constant; however, test 23 in the Phase I program resulted in an observation of increased energy. The typical behavior observed during testing may be a result of the characteristics of the electrical power feed into the fault from the test facility. The team has used a constant energy source via super excitation, whereas this may not be the case, for example, in a generator-fed fault where the generator trips and the energy decreases with time. Another aspect is the energy received at a target. The time it takes the arc event to breach the electrical enclosure, whether a door or panel opening or the arc burning through the enclosure, has an impact on the temporal profile for the energy received.

Testing at medium voltage should represent the current decrement curves when the fault is being fed from a generator.

o The laboratory can produce steady currents or follow a current profile (with some limitations). To be realistic, the NRC would need information such as decrement curves from high-speed digital recorders (or similar) to evaluate whether testing could match those characteristics.

Is there any proposal to test the electrical equipment within a larger room enclosure to understand the pressure effects?

o The focus thus far has been to record the pressure within the electrical enclosure and try to extrapolate room pressure. It is uncertain at this time whether that will be possible. It may be possible to construct a test room at the test laboratory, but that decision will be weighed in terms of the costs and benefits.

Is it possible to demonstrate the switchgears compliance with IEEE C37.20.7, IEEE Guide for Testing Switchgear (Ref. 18) (i.e., that it does not damage anything beyond the enclosure) and thereby certify that the switchgear is healthy for testing?

o This may be possible for the low-voltage tests but expensive for the medium-voltage tests. It would also be cost prohibitive if the equipment tested is not all of the same design. In general, it is unclear as to what would be gained from performing these tests. The referenced IEEE document provides a qualification process for arc-resistant equipment, and it is unclear that this was a requirement or procurement specification of the plant when it was licensed.

Additionally, if the test used equipment representative of the plant equipment and it failed, what would that imply for the equipment in the field? In general, the comment appears to be off topic for the purpose of these tests.

IEEE has performed a number of tests with durations from 0.5 to 1 second. This information should be reviewed to understand the results and help communicate that the focus of this work is the large energy releases that are being observed in plants, but the data are not there to support a realistic modeling tool.

o Mr. Taylor agreed with this statement.

Is it possible to characterize the generation source, such as a black box model or impedance model?

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o Many configuration changes are available with the test laboratorys generators, reactors, and other supply equipment to meet a wide range of power system configurations. The team will document the configurations tested; however, it is more important to understand the generation facilities sources so that the test power supply can be configured to match.

If the NRC is seeking voluntary information from the industry, how will the NRC ensure that any information provided is representative of the overall industry and not a non-representative best case?

o NRC experts, such as the electrical engineers in Mr. Millers group or regional staff who have experience inspecting this equipment at various sites, would vet the information received. If EPRI and NEI participate in the information review, experts from those organizations would also review and check the information.

  • With regard to the discussion on wye or delta connected testing power sources, there are a variety of configurations in the field and it may make sense to test a combination of the two. However, the preference was not that strong, and it was felt that a more important aspect of the testing would be to test in the configuration that allowed the laboratory to meet the current, duration, and voltage specifications of the testing. The international PIRT ranked the system connection configuration as a low importance.
  • Regarding the discussion on the grounding configuration, the audience identified several grounding configurations from solid grounds on the low-voltage systems to high-resistance grounding and grounding transformers on the medium-voltage systems.

The discussion concluded with the point that grounding should not affect the testing. It will affect the duration of actual events and the associated protection scheme. For testing, the tests will be initiated phase to phase, and grounding has little to do with those types of failures.

o The biggest testing concern with grounding configuration is the thermal effects on the generators because those cannot be damaged and the laboratory will not allow testing in a configuration that will damage or potentially damage its infrastructure.

o The discussion concluded that variations of the grounding configuration are not warranted.

EPRI provided information on a sample of medium-voltage transformer winding configurations for the unit auxiliary transformer. Based on a sample of 28 units, the following population was noted:

o Delta primary to Wye secondary (-Y): 20 units o Delta primary to Delta secondary (-): 6 units o Wye primary to Wye secondary (Y-Y): 2 units Therefore, the predominant of the secondary side of the unit auxiliary transformer is a Wye-connected configuration.

Should the phase-to-ground fault that does not transition to a phase-to-phase fault be considered in frequency space? Although it may be a lower likelihood that the 10-4

phase-to-ground fault remains a phase-to-ground fault, the phase-to-ground fault would limit the current.

o That is something that should be kept in mind if the team performs a more thorough review of the operating experience. From the information that is currently available, the commenters distinction cannot be made.

  • With regard to the discussion on the placement of arcing wire, the most recent issuance of IEEE 1584 describes a definite distinction between the energy that was emitted from an arc created on a vertical versus horizontal section of bus. Should this be considered when deciding where to place the arcing wire?

o Mr. Earley of NFPA responded that it is true that the results from the vertical and horizontal test yielded different results. The horizontal configuration was more severe.

o Although testing guides such as IEEE C37.20.7 identify placing the arcing wire far from the incoming power source, OECD Phase I test results indicate that the arc can move to other locations within the enclosure.

o It was also recommended that the arc should not be placed in a location where it is unlikely to occur, such as documented in the IA report where some of the bus insulation was removed to support a sustained arc.

The original configuration of the equipment should be kept; where changes are required, those changes and the rational for the change should be documented.

The participants discussed the arcing wire characteristics.

o IEEE C37.20.7 identifies two types of acing wire. The purpose of the arcing wire is to provide sufficient material to initiate and sustain the arc plasma.

Low-voltage systems use a 10-American Wire Gauge (AWG) type K stranded conductor, while a medium-voltage system uses a 24-AWG. The NRC has requested clarification on the specification of the arcing wire from IEEE. The IEEE guide wire sizes will be used unless justification for other sizes is identified.

The participants discussed bus duct testing.

o One plant was identified as having non-segregated bus ducts with bus bar insulation made of Norrell. Other participants identified that there was a mix of insulated and non-insulated bus bars within bus ducts.

o The ventilation of bus ducts also differs from bottom ventilated to top-hat ventilated.

o The end treatment of the tested bus ducts will also be important.

The end treatment for the Phase 1 testing did not last long and, from industry testing the supporting insulators along with the insulated bus, seems to have stabilized the arc in one location. As testing progresses, 10-5

the team wants to make the testing as realistic as possible while still being able to predict arc location such that active measurements at those locations can be made. Whether connecting a bus duct to an electrical enclosure, using insulation, or making physical breaks in the conductor, the team is trying to balance realism with testing practicality.

o Is the intent to simulate a segmented bus duct failing at a joint or is it to be applied to both segmented and non-segmented bus duct failures? The current fire PRA modeling approach is different.

The focus was on segmented bus ducts failing at a bolted connection.

The team is trying to stay consistent with the current modeling technique in Supplement 1 to NUREG/CR-6850 and EPRI 1011989.

Do cameras provide information needed to assess the severity of the HEAF event or is their role to help market the badness of HEAF events?

o The cameras can help identify where shrapnel is ejected. There were some limitations with the initial cameras that were used, and the team is working with the national laboratories to obtain valuable information from these recordings.

The other aspect is thermal imaging. The camera that was previously used was limited by its dynamic range. For Phase II testing, the team is looking at other products that allow for a wider dynamic range to capture more information.

Will different alloys of aluminum be tested?

o Currently, the team does not know the population of aluminum alloy in the plants.

We have provided some information on this aspect in the small-scale test plan, but it appears that there is not much difference in the aluminum used for electrical applications.

Do atmospheric conditions influence the HEAF phenomena?

o The testing performed during Phase I has a significant variation of atmospheric conditions, but the team did not observe that as being a driving factor. It may be more important from a frequency (or arc initiation) standpoint, but once the arc is initiated, the atmospheric conditions likely do not influence the HEAF results.

Will the coupons located on the instrument racks have unique identifier such that they are identifiable after the test and if they were to come lose and fall off of the rack?

o Each coupon will have a unique identifier.

With regard to donated and procured equipment, it is vitally important to have the equipment vendor manuals, factory test reports, and everything that is related to the equipment.

o Mr. Taylor agreed with this statement.

Regarding the discussion on equipment selection, the participants identified the following as common types of equipment:

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o GE Magna-Blast o Westinghouse DB-50 o ITE k-line If equipment is donated to the testing program, will it be tested to rated voltage or to the voltages specified in the testing plan, which may be greater than the rating of the equipment?

o The equipment will NOT be tested at voltages in excess of its rating. For example, although the test plan specifies 6.9kV for medium voltage, if the team receives a set of equipment that is only rated for 5 kV, then that equipment would be tested at 4.16kV.

Will the testing include cable as targets?

o Yes, there will be cable coupons located on the instrument measuring racks.

Initially, the team planned to use cable trays for the testing, but after much thought that was dropped because of several limitations. The first difficulty of having full cable trays was defining a representative cable type and configuration, given the vast range of configurations found in the plant. Secondly, the cable trays block some of the HEAF effluent and incident energy to the active measurements devices. Because the team plans on developing a model to predict (validate) incident energies, having cables in the way did not serve this interest.

Will the program evaluate differences in equipment design between indoor and outdoor offerings?

o No, the focus of this effort is indoor equipment that poses a fire-related hazard to safe shutdown.

After the presentations and discussion from the morning session and a presentation on the results from NUREG-2218, the participants reviewed the parameters and ranked their importance to influencing the HEAF phenomena. The participants discussed each parameter to clarify the meaning of the parameter. Following that discussion, the parameter was ranked either high, medium, or low with respect to its importance to the HEAF phenomena, as presented in Table 10-1. Not everyone in attendance voted, and not everyone voted for each issue. The table also includes votes received through the webinar.

Table 10-1 Summary of Parameter Ranking from Workshop Participants Importance Ranking Parameter High/Medium/Low Comment Duration High (consensus)

Voltage High (consensus) Arc voltage not system Current High (consensus) 5 High Arc Location 2 Medium More examination of the IEEE testing configuration (orientation) 3 Low Grounding Low (consensus) Important to frequency Configuration 10-7

Importance Ranking Parameter High/Medium/Low Comment Experience that arc voltage has not shown a Delta vs. Wye Low (consensus) difference 5 High Current Decay 6 Medium Plant information necessary for decay behavior 3 Low 3 Medium Enclosure Thickness 9 Low Bus Insulation Low (consensus)

(enclosure)

Bus Insulation (non- 9 High segmented bus) 1 Medium Circuit 2 High Potentially included in earlier parameters, however Characteristics 7 Medium needed for modeling Linked to arc voltage; Low because of 11 High Bus Gap phase-to-phase interaction and other arc strike 1 Low locations within the enclosure 6 Medium DC Offset 3 Low Ventilation 9 High (enclosure) 1 Medium Ventilation (bus 3 Medium duct) 7 Low 1 High Aluminum Alloy State of knowledgeHigh rank outlier 8 Low Measurement High (consensus) Target locations and positions Separation Interval 1 Medium Important to frequency and initiation of event; Atm. Conditions 10 Low unknown to consequence Ventilation (oxygen 8 High availability; 3 Medium aluminum)

Ventilation (oxygen 2 Medium availability; copper) 10 Low The Test Parameter and Equipment Selection presentation is documented on pages 7-227 of the Day 2 transcript.

10.1.1.1 Recommendations Consider reducing the number of low-voltage tests, given the presentation by EPRI, which indicated that less than 15 percent of the events are in the low-voltage class, while the draft test plan has 50 percent of the tests at low voltage.

Change the range of the low-voltage durations to 2 to 4 seconds.

Review the IEEE literature on short-duration testing to support the basis of need for longer duration tests.

Split the bus duct tests into insulated / non-insulated.

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10.1.1.2 Follow-up Actions Prepare generator-fed fault decrement curves from high-speed digital recorders (EPRI).

Develop the station power source characteristics to support the testing of power supply configurations (EPRI).

Conduct follow-on interactions with stakeholders or EPRI, as needed.

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10.1.2 Presentation Slides 10-10

10-11 10-12 10-13 10-14 10-15 10-16 10-17 10-18 10-19 10-20 10-21 10-22 10-23 10-24 10-25 10-26 10-27 10-28 10-29 10-30 10-31

11 DRAFT TEST PLAN AND COMMENT RESOLUTION 11.1 Review of Phase II Draft Test Plan and Comment Resolution Nicholas Melly, Fire Protection Engineer in the Office of Nuclear Regulatory Research, presented a review of Phase II draft test plan HEAFs involving aluminum. Because the morning session covered a majority of the information, Mr. Melly focused his presentation on the information not already covered. Mr. Melly presented the experimental variables, measurements, OECD member countries, test structure, experimental approach, and timeline.

He also presented comments on the draft test plan.

11.1.1 Discussion During these presentations, attendees asked several questions, summarized as follows with responses:

The small-scale testing is not integrated into the schedule; the expectation was that it was going to be a predecessor.

o The small-scale testing is separate from the OECD program. It will be conducted before the full-scale OECD testing.

How will all of this work be documented?

o The current plan is to have seven or eight reports that document this work.

The NRC will document the workshop in a NUREG/CP.

A NUREG/CR report will document the small-scale testing at SNL.

An OECD report will document the OECD-sponsored tests, as was done in Phase I.

A NUREG will document the NRC tests and provide an analysis of all tests performed.

A NUREG or joint report with EPRI will document an improved HEAF methodology.

Researchers in Japan have performed a number of tests, and, through an MOU, the NRC plans on working with them to publish two more NUREG/IA reports to document this work.

A NUREG report will document the analysis of photographic and video information.

Will the documentation of the enclosure include any aluminum piece other than the conductors?

o The report will document aluminum pieces or parts that could become involved in the HEAF.

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When does the NRC expect to complete the small-scale report?

o The NRC will issue a draft final report no later than September 30, 2018. The report will go through a review and publication process. The report should be available to the public around the end of 2018. If stakeholders are interested, the NRC could hold a public webinar to announce the results once the reports have been approved internally.

Does the NRC expect the majority of the test equipment to be donated, or will the agency procure the test equipment? Ideally, it may be preferred to identify a specific line of equipment and then contact the manufacturer to understand whether the enclosure could contain either aluminum or copper bus and then make the design specifications available to support such a change.

o Currently, only two countries from the international program are expected to donate equipment. The NRC will accept donations that support the intent and objectives of the program from U.S. utilities or vendors. Donations are needed primarily in the area of bus duct testing. However, if, for example, six Vendor A switchgears were donated and they are representative of U.S. fleet equipment, then the NRC could procure more equipment like that and then use resources to perform additional testing or other activities, as needed.

EPRI provided a summary of the high-speed digital recorder event that would support generator test setup. In summary, for the first 26 cycles, the voltage drops from 22kV down to 17kV and then holds steady. This steady state may be because the exciter switchgear breaker is still closed and actually exciting the rotor. Afterward, there is another 20-percent drop to about 50 percent of the original system voltage. Then, it is assumed that the breaker opens and the voltage slowly decays from there as would be expected. This decay lasts to about the 6-second point, when the arc finally extinguishes. EPRI may be able to compile this information into a short whitepaper.

o That information would be beneficial.

The Review of Phase II Draft Test Plan and Comment Resolution presentations are documented on pages 227-288 of the Day 2 transcript.

11.1.1.1 Follow-up Actions Prepare a white paper on the generator decrement curve from high-speed digital event recorder. (EPRI) 11-2

11.1.2 Presentation Slides 11-3

11-4 11-5 11-6 11-7 11-8 11-9 11-10 11-11 11-12 11-13 11-14 11-15

12 WORKSHOP WRAPUP,

SUMMARY

OF RECOMMENDATIONS, AND FOLLOW-UP 12.1 Conclusion of Workshop The workshop concluded with remarks from Mark Henry Salley, Chief of the Fire and External Hazards Analysis Branch, and Michael Cheok, Director of the Division of Risk Analysis in the Office of Nuclear Regulatory Research.

Mr. Salley thanked everyone for attending and providing valuable feedback and recommendations that will undoubtable improve the quality and results of this work. He reminded the attendees of the importance of performing the pilot plant focused-scope aluminum HEAF risk analysis. That effort is needed to support the GI program during the assessment stage for PRE-GI-018, and the NRC requests support from utilities and EPRI, through its MOU on fire risk, to accomplish this task.

Mr. Cheok thanked everyone in attendance and those on the webinar for spending the 2 days supporting this important work for the NRC and public safety. Interactions like this workshop provide an opportunity for participants to learn more about NRC processes and allows the NRC to better understand the comments and questions that it receives. Mr. Cheok also reminded the attendees that the Office of Nuclear Reactor Regulation is prominent in the GI process. Mr.

Cheoks counterpart, Mike Franovich, Director of Division of Risk Assessment in the Office of Nuclear Reactor Regulation, followed the workshop via the webinar. Staff from both offices will work together to move this issue through the GI process.

12.2 Summary of Recommendations The discussions held during the workshop resulted in several recommendations that were viewed as adding value to the program. Table 12-1 summarizes those recommendations.

Table 12-1 Summary of Workshop Recommendations

  1. Description Chapter R1 It would be helpful for project tracking and status of the GI program to have a 4 schedule of when specific actions are expected to be completed and any relationship between the individual actions items (i.e., dependencies).

R2 In order for EPRI or NEI to better support the pilot plant initiative, they would need to 4 understand the NRCs expectations for a pilot plant. A timeline would also be useful.

R3 In addition to better characterization of the HEAF ZOI, associated HEAF frequency, 4 binning, and suppression modeling improvements are needed to ensure a consistent risk assessment methodology.

R4 Perform a literature search. 5 R5 Tie EPRI into the discussion between NRC and NFPA members on the definitions. 5 R6 Consider changing system voltage to bus bar spacing as a parameter of importance 6 for the medium-voltage tests.

R7 Consider reducing the number of low-voltage tests, given the presentation by EPRI 10 indicating that less than 15 percent of the events are in the low-voltage class, while the draft test plan has 50 percent of the tests at low voltage.

R8 Change low-voltage durations to be within the range of 2 to 4 seconds 10 R9 Review IEEE literature on short-duration testing to support the basis of need for 10 longer duration tests.

R10 Split the bus duct tests into insulated / non-insulated 10 12-1

12.3 Summary of Follow-Up Actions The discussions held during the workshop identified several follow-up actions that were viewed as adding value to the program. Table 12-2 summarizes those actions.

Table 12-2 Summary of Follow-up Actions Responding

  1. Description Organizations Chapter A1 Develop a tentative schedule for PRE-GI-018 action items. NRC 4 A2 Show dependencies between and among action items. NRC 4 A3 Develop a charter for the pilot plant focused-scope HEAF NRC 4 assessment.

A4 Develop revised HEAF binning (definitions) and frequency NRC / EPRI 4 estimates.

A5 Conduct a literature search. NRC 5 A6 Refine the definitions based on feedback from 2- and 3-second NRC 5 time durations of switchgear and breakers, respectively.

A7 Include EPRI in future collaboration on refinements to the NRC / EPRI / 5 definitions. NFPA A8 Can the laboratory perform at isophase bus voltages? If so, is it NRC / SNL 6 worth including in this effort?

A9 What abilities are there for extrapolation or interoperation of test NRC 6 results?

A10 If needed, perform a public webinar to communicate the results NRC 6 from the small-scale testing.

A11 EPRI or NEI to support the NRC GI pilot plant assessment. NRC / EPRI / 8 NEI A12 Prepare generator-fed fault decrement curves from high-speed EPRI 10 & 11 digital recorders.

A13 Develop the station power source characteristics to support the EPRI 10 testing of power supply configurations.

A14 Conduct follow-on interactions with stakeholders or EPRI, as NRC 10 needed.

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13 REFERENCES

[1] 10 C.F.R. Part 50, Domestic Licensing of Production and Utilization Facilities.

[2] Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Revision 3, U.S.

Nuclear Regulatory Commission (NRC), Washington, DC, February 2018.

[3] EPRI TR-1011989 and NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities: Volume 2, Detailed Methodology. Electric Power Research Institute (EPRI), Palo Alto, CA, and NRC Office of Nuclear Regulatory Research, Washington, DC, September 2005.

[4] Supplement 1 to NUREG/CR-6850 and EPRI 1011989, Fire Probabilistic Risk Assessment Methods Enhancements, EPRI, Palo Alto, CA, and NRC, Washington, DC, December 2009.

[5] NEA/CSNI/R(2013)6, OECD Fire ProjectTopical Report No. 1 Analysis of High Energy Arcing Fault (HEAF) Fire Events, Nuclear Energy Agency, Paris, France, June 2013.

[6] NEA/CSNI/R(2017)7, Report on the Testing Phase (2014-2016) of the High Energy Arcing Fault Events (HEAF) Project Experimental Results from the International Energy Arcing Fault Research Programme, Nuclear Energy Agency, Paris, France, May 2017.

[7] Information Notice 2017-04, High Energy Arcing Faults In Electrical Equipment Containing Aluminum Components, NRC, Washington, DC, August 2017.

[8] FAQ 17-0013, High Energy Arcing Fault (HEAF) Non-Suppression Probability (NSP),

NRC, Washington, DC, March 21, 2017.

[9] EPRI 3002011922, Characterization of Testing and Event Experience for High-Energy Arcing Fault Events, Electric Power Research Institute, December 2017.

[10] EPRI 3002011923, Nuclear Station Electrical Distribution Systems and High-Energy Arcing Fault Events, Electric Power Research Institute, December 2017.

[11] HEAF Information Sharing Workshop Transcript, Day 1, ADAMS Accession No, ML18114A817.

[12] HEAF Information Sharing Workshop Transcript, Day 2, ADAMS Accession No, ML18114A818.

[13] NEA/CSNI/R(2015)10, A Review of Current Calculation Methods Used to Predict Damage from High Energy Arcing Fault (HEAF) Events, Nuclear Energy Agency, Paris, France, June 2015.

[14] NUREG-2218, An International Phenomena Identification and Ranking Table (PIRT)

Expert Elicitation Exercise for High Energy Arcing Faults (HEAFs), NRC, Washington, DC, January 2018.

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[15] NUREG/IA-0470, Nuclear Regulatory Authority Experimental Program to Characterize and Understand High Energy Arcing Fault (HEAF) Phenomena, S/NRA/R, Tokyo, Japan, and NRC, Washington, DC, August 2016.

[16] NUREG-0933, Resolution of Generic Safety Issues, NRC, Washington, DC, December 2011.

[17] IEEE 1584, IEEE Guide for Performing Arc Flash Hazard Calculations, IEEE, September 2001.

[18] IEEE C37.20.7, IEEE Guide for Testing Switchgear Rated Up to 52 kV for Internal Arcing Faults, IEEE, January 2017.

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APPENDIX A DRAFT LARGE-SCALE TEST PLAN AND COMMENTS The citation information for the High Energy Arcing Faults in Electrical Equipment, Phase 2, Draft Test Plan as published in the Federal Register is as follows:

Date of Publication: August 2, 2017 Comment Period Close: September 1, 2017 Document Citation: 82 FR 36006 Page: 36006-36007 (2 pages)

Agency/Docket Number: NRC-2017-0168 Document Number: 2017-16233 The draft test plan is accessible on the companion DVD at the following file address:

/Reports & Documents/NRC Phase 2 Materials/Large Scale Testing/Draft Test Plan.pdf The draft test plan is also accessible in the Agencywide Documents Access and Management System (ADAMS) at ADAMS Accession No. ML17201Q551 (https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML17201Q551).

The comments and their dispositions are accessible on the companion DVD at the following file address:

/Reports & Documents/NRC Phase 2 Materials/Large Scale Testing/Comments and Dispositions.pdf The draft test plan is also accessible in the Agencywide Documents Access and Management System (ADAMS) at ADAMS Accession No. ML18233A469 (https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18233A469).

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APPENDIX B REVISED LARGE-SCALE TEST PLAN The revised large-scale test plan is detailed below. This final test plan incorporates public comments.

The final test plan is accessible on the companion DVD at the following file address:

/Reports & Documents/NRC Phase 2 Materials/Large Scale Testing/Revised Test Plan.pdf B-1

APPENDIX C NEEDS AND OBJECTIVES The workshop organizers disseminated High Energy Arcing Fault (HEAF) Research, Needs and Objectives, dated March 23, 2018, before the workshop for discussion at the event.

The document is accessible on the companion DVD at the following file address:

/April 2018 Workshop/Needs & Objectives.pdf The document is also accessible in the Agencywide Documents Access and Management System (ADAMS) at ADAMS Accession No. ML18081B300 (https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18081B300).

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APPENDIX D DRAFT SCMALL-SCALE TEST PLAN AND COMMENTS The citation information for the Aluminum High Energy Arc Fault (HEAF) Particle Size Characterization Test PlanDRAFT, dated February 5, 2018 (draft small-scale test plan) as published in the Federal Register is as follows:

Date of Publication: March 5, 2018 Comment Period Close: April 4, 2018 Document Citation: 83 FR 9344 Page: 9344-9345 (2 pages)

Agency/Docket Number: NRC-2018-0040 Document Number: 2018-04341 The draft small-scale test plan is accessible on the companion DVD at the following file address:

/Reports & Documents/NRC Phase 2 Materials/Small Scale Testing/Draft Test Plan.pdf The draft test plan is also accessible in the Agencywide Documents Access and Management System (ADAMS) at ADAMS Accession No. ML18036A448 (https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18036A448).

The comments received on this draft test plan and their resolution are available on the companion DVD in the following folder:

/Reports & Documents/NRC Phase 2 Materials/Small Scale Testing/

The draft small-scale test plan comments and their resolution are also accessible in ADAMS at ADAMS Accession No. ML18163A423 (https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML18163A423).

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NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High Energy Arcing Faults (HEAFs) July 2019 G. Taylor K. Hamburger N. Melly Technical K. Miller S. Gardocki T. Boyce Division of Risk Analysis & Division of Engineering Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Division of Risk Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 M. Salley, NRC Project Manager The U.S. Nuclear Regulatory Commission (NRC) organized the Information-Sharing Workshop on High Energy Arcing Faults (HEAFs). The workshop took place April 18-19, 2018, at the NRC Headquarters in Rockville, MD. The NRC coordinated the workshop with the Electric Power Research Institute (EPRI) and the National Fire Protection Association (NFPA) and advertised it at recent nuclear industry information forums and during recent NRC public meetings related to fire protection. The workshop technical topics focused on HEAF hazards and recently completed and ongoing research initiatives. The workshop also included discussion about the NRCs generic issues program as it relates the aluminum HEAF issue. The objectives of the workshop were to (1) inform interested stakeholders about the status of PRE-GI-018 and related research, (2) review and resolve public comments received on the Phase II draft test plan, (3) solicit and review information from industry partners on common equipment types and configurations to inform future testing, and (4) provide an opportunity for public feedback on future testing. This report documents the recommendations and insights given during session presentations and the discussions that followed.

electrical fault arc fault arc flash high energy arcing fault (HEAF) fire probabilistic risk assessment fire protection fire safety

NUREG/CP-0311 Proceedings of the Information-Sharing Workshop on High July 2019 Energy Arcing Faults (HEAFS)