, NEW YORK POWER AUTHORITY Indian Point 3 Nuclear Power Plant. FIRE SEAL. EVALUATION Self Ignition Temperatures of Cable Insulation as it Relates to'the Design of Fire Seals Evaluation Number: IP3-ANAL-FP-O1 392 /-> Revision 1 --- 9701030037 981223 PDR ADOCK 05000286 P PDR z k6 OW NewvYork Power 40 Authority FIRE SEAL EVALUATION Self Ignition Temperatures of Cable Insulation as it Relates to the Design of Fire Seals Evaluation Number: IP3-ANAL-EP-Ol 392 Revision 1 QIN T z C, f ?010J001w NEW YORK.POWER AUTHORITY Indian Point 3 Nuclear Power Plant FIRE SEAL EVALUATION Self Ignition Temperatures of Cable Insulation as it Relates-to the Design of Fire.S~als Evaluation Number: 1P3-ANAL-FP-01392, Revision 1 IITE CN'A N 0 UT LOC:_ ____ Prepared by: S. Reviewed by:t Dr. 'A. Tewarson -Technical Review F.cVrjMu( 1 Rsearch Corporation Reviewed by: P. Koklakis '~.censingReview Approved by: ___ Approved by IP3-ANAL-FP-01392, Fire Seal Evaluation Revision 1 Record of Revisions Bayjai=Q Initial Issue to respond to NRC Unresolved Item (URI) 286/93-24-03 a.,;documented in NRC Inspection Report 50 286/93-24 (Ref(xrence 2.15). Incorporate thel review of EPRI report test data anomaly. IP3-ANAL-FP-0139 2 , Fire Seal Evaluation Revision 1 Table of Contents Setin flatt 1.0 PURPOSE 2.0 REFERENCES 3.0 BACKGROUND 3.1 Initial Fire Seal Qualification 3.2 NRC Inspection 93-24 3.3 Initial Response to URI 93-24-03 3.4 EPRI studies 3.5 NRC Review of Revision 0 3.6 Disposition of NRC Concern 4.0 EVALUATION 4.1 IP3 Fire Seal 4.2 IP3 Fire Seal Design Basis 4.3 IP3 Cables 4.4 Justification for Acceptance 5.0 CONCLUSION 6.0 ATTACHMENTS- IP3-ANAL-FP-01392, Fire Seal Evaluation RevisionRvso 1 1.0 12URPOS~E This evaluation Iwill review the self-ignition temperatures of Indian Point No. 3 cables, that penetrate fire barrier penetration seals. The evaluation will demonstrate that the self ignition teI'peratures of these cables are sufficiently above 700'F where the fire seal qualification test resul~s indicated-an unexposed side temperature of greater than 250'F plus ambient (-325'F), but below 700 0F. Seven hundred degrees Fahrenheit (700 0 F) represents the maximum allowed unexposed side interface and penetrating items temperature identified in the fire test review methodology (ENG-527, Evaluation No. 5., Attachment 6.3). The fire test review methodology was used for reviewing fire seal qualification tests against actual IP3 fire seal designs. 2.0 REFRENCE.S 2.1 ASTM D470-1959T, Tests for Rubber and Thermal Plastic Insulated Wire and Cable. 2.2 ASTM E119-1976, Fire Test of Building Construction and Materials. 2.3 ASTM E814-1981, Fire Tests of Through-Penetration Fire St ops. 2.4 Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for Fire. Protection for Nuclear Power Plants, dated may 1, 1976. 2.5 CASP V; IP3 Conduit &Cable Schedule, report dated November 11, 1994. 2.6 EPRI Report NP-1200; Categorization of Cable Flanmmability Part 1: Laboratory Evaluation of Cable Flammiability Parameters, dated October 1979. 2.7 EPRI Report NP-1630; Categorization of Cable 'Flammability, Detection of Smoldering and Flaming Cable Fires, dated November 1980. 2.8 EPRI Report NP-1767; A Study of Damageability of Electrical Cables in Simulated Fire Environments, dated May 1981. 2.9 EPRI Report NP-1881; Ca tegorization of Cable Flammability, Intermediate- Scale Fire Tests of Cable Tray Installations, dated August 1982. 2.10 EPRI Report NP-7332; Design Guide for Fire Protection of Grouped Electrical Cables, dated May 1991. 2.11 FMRC Report J.I.OM2El.RC; Electrical Cables -Evaluation of Fire Propagation Behavior and Development of Small-Scale Test Protocol, dated January 1989. 2.12 IEEE Std. 383-1978, IEEE Standard for Type Test of Class IE Electrical Cables, Field Splices, Connections for Nuclear Power Page 1 of 25 IP3-ANAL-FP-01392, Fire Seal Evaluation RvsoRevision 1 Generating Stations. 2.13 IEEE Std. 634-1978, Cable Penetration Firestop Qualification Test. 2.14 NRC Letter dated June 1, 1978 regarding Staff Position P4, Cable Penetration Firestops. 2.15 NRC letter dated December 14,, 1993 transmitting NRC Region I Inspection 50-286/93.-24. 2.16 Nuclear Regulation (NuReg) 0800; Branch Technical Position (BTP) CMEB 9.5-1, Revision 2, Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981. 2.17 National Fire Protection Handbook (NFPA) Fire -Protection Handbook, 17th edition. 2.18 Society of Fire Protection Engineers (SFPE) Handbook of Fire Protection Engineering, 2nd edition. N4ote: The 2nd edition has not been distributed for public use as of this writing; a copy of the galley proof has been attached to this evaluation. 2.19 US Department of Transportation Report No. UMTA-MA-06-0025-83-6; .Combustibility of Electrical Wire and Cable for Rail Rapid Transit Systems, Volume 1: Flammability, dated May 1983. 2.20 FMRC Report J.I.0G3R9.RC; Small Scale Testing of Flame-Retardant Coated Cables,'dated June 1982.. 2.21 NRC letter dated February 2, 1984 transmitting*Appendix R SER. 2.22 Fundamentals of Heat !and Mass Transfer, John Wiley & Sons, 3rd edition. 2.23 Marks Standard Handbook for Mechanical Engineers, 9th edition. 2.24 Symposium Series 599, Fire and Polymers II, Materials and Tests for Hazard Prevention, 1995, American Chemical Society, Washington, D.C. Note ': This publication has not been distributed for public use as of this writing. A copy of the chapter submitted for publication is attached to this evaluation. 3.0 BAKRON 3.1 Initial Fire Seal Qualification Fire barrier penetration seals are installed with the intent that they remain in place and retain their integrity when subjected to an exposure fire and subsequently, a fire suppression agent. Silicone foam and silicone elastomer comprise the. two principal types of penetration fire seals used at IP3. Results of eight separate fire Page 2 of 25 IP3-ANAL-FP-01392,.Fire Seal Evaluation RevisionRvso 1 tests have been used to evaluate the silicone foam and silicone elastomer designs for both-electrical and mechanical penetration fire seals. The results of. each of these tests are summarized in Attachment 6.5. The review methodology utilized for comparing 1P3.fire seal designs against generic fire seal qualification tests allowed an unexposed' side penetrant interface temperature greater than 250OF plus ambient (z3250F) but less than 7000F. If the generic fire seal designs had an unexposed side temperature less than 7000OF, the temperatures were assumed to be sufficiently below the self-ignition temperatures of the cables used at 1P3. This was based on the qualification fire testing which typically evaluated worst case cable construction in its tested fire seal configurations. 3.2 NRC Inspection 93-24 During NRC Inspection 93-24 (Reference 2.15), an inspector noted that the fire test review methodology (ENG-527, Evaluation No. 5) which was used for reviewing qualification tests for fire seal designs, allowed a maximum unexposed surface temperature of 700 0F. The inspector additionally noted that 700'F was considerably higher than the 250OF plus ambient (=325'F) unexposed surface temperature identified by the staff and recognized by fire test standard-ASTM E119 (Reference 2.2). The inspector was informed that the allowance for 700OF was acceptable based on Staff Position P4 (Reference 2.14) and industry standards IEEE 634 (Reference 2.13) and ASTM E814 (Reference 2.3). The inspector stated that the allowance for 700'F in Staff Position P4 was based on self-ignition temperatures. The inspector questioned the 1P3 fire test review methodology because it did not consider whether the self-ignition temperatures of 1P3 cables are sufficiently above 700 0F. ENG-527, Evaluation No. 5 was revised to document a review of the maximum allowable unexposed side temperature and provide reasonable assurance that the minimum self-ignition temperatures of cables used at IP3 were above 700'F.. This assurance was based. on the cable testing and the quality assurance re .quirements that had been imposed at the time of cable purchasing. These requirements included a fire and heat resistance test commonly referred to as the Con Ed Bon-Fire Test (Attachment 6.1). This qualitative review was performed and made available for the inspector during Inspection 93-24. However, the inspector requested that NYPA obtain the cable insulation ignition temperatures for each of the cable types that penetrate a fire barrier penetration fire seal, where qualification test results indicated an unexposed side temperature greater than 250'F plus ambient. This request was formally issued by the NRC as Unresolved Item (URI) 93-24-03. 3.3 Initial Resvonse to URI 93-24-03 Page-3 of *25 IP3-ANAL-FP-01392, Fire Seal Evaluation RevisionRvso 1 Revision 0 of this evaluation reviewed the self-ignition temperatures of cables used at 1P3 by using generic cable flammability test data published in EPRI Reports NP-1200 -(Reference 2.6) and NP-7332 (Reference 2.10). The review was performed by comparing cables of similar construction and. jacketing to the piloted ignition temperatures of those tested. The reports were based on flammability studies performed by the Factory Mutual Research Corporation (FMRC) of Norwood, MA in the late 1970's and early 1980's. 3.4 EPRI Studies In 1979, EPRI initiated a study program (EPRI Project 1165-1) to categorize cable flammability in terms of: 1) flammability. of cable; 2) detection of combustion in cable tray installations; and 3) fire protection (sprinklers) for cable tray install-ations. EPRI Report NP-1200 documented the results of the first part of the research.