HNP-06-004, Response to Request for Additional Information (RAI) Regarding the Request for a License Amendment to Use Fire-Resistive Electrical Cable

Response to Request for Additional Information (RAI) Regarding the Request for a License Amendment to Use Fire-Resistive Electrical Cable

ML060540397
Person / Time
Site:	Harris
Issue date:	02/15/2006
From:	Kamilaris C Progress Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-06-004
Download: ML060540397 (36)

Text

Cj Progress Energy FEB 1 5 2006 Serial: HNP-06-004 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE ELECTRICAL CABLE AT THE HARRIS NUCLEAR PLANT Ladies and Gentlemen:

On November 7, 2005 and December 6, 2005, the NRC requested additional information to facilitate the review of the proposed request (HNP-05-063 dated August 18, 2005) for a license amendment to use fire-resistive electrical cable at the Hanis Nuclear Plant (HNP). provides the requested additional information from the first RAI (November 7, 2005).

-' provides the requested additional information from the second RAI (December 6, 2005). provides the specifications of the fire-resistive cable as additional information to facilitate the review of the proposed request. provides the applicable electrical evaluation portion and design drawings of the HNP modification for the Volume Control Tank (VCT) outlet valves.

The additional information provided by this submittal does not change the intent of or the justification for the requested license amendment. HNP has determined that this submittal did not result in any change to the No Significant Hazards Consideration contained in the original letter. Therefore, the 10 CFR 50.92 Evaluation provided in the August 18, 2005 submittal and published in the Federal Register (i.e., 70 FR 677.46 dated November 8, 2005) remains valid.

HNP requests that the proposed license amendment be issued by May 13, 2006 to support startup from HNP Refueling Outage (RFO)-13.

This document contains no new Regulatory Commitment.

Progress Energy Carolinas, Inc.

Harris Nuclear Plant P.O. Box 165 New Hill, NC 27562

-p HNP-06-004 Page 2 Please refer any question regarding this submittal to Mr. Dave Corlett at (91i9) 362-3137'.

I declare, under penalty of perjury, that the attached information is true and correct (Executed on FEB 1 5 2006 )

Sincerely, C. S. Kamilaris Manager, Support Services Harris Nuclear Plant CSKJjpy Attachments:

1. Response to the First Request for Additional Information (RAI) Regarding the Request for a License Amendment to Use Fire-Resistive Cable at Harris Nuclear Plant (HNP) 2;. Response to the Second Request for Additional Information (RAI) Regarding the Request for a License Amendment to Use Fire-Resistive Cable at Harris Nuclear Plant (HNP)

3. Specifications for Meggitt Fire-Resistive Cable

4. Applicable Electrical Evaluation portion and Design Drawings of the Harris Nuclear Plant (HNP) modification for the Volume Control Tank (VCT) outlet valves, Engineering Change (EC) 52769 titled, "1 CS-1 65 and 1 CS-166 Cable Protection for 1-A-EPA, 1 -A-E13B, 1 -A-BAL-B" c:

Mr. R. A. Musser, NRC Senior Resident Inspector Ms. B. 0. Hall, N.C. DENR Section Chief Mr. C. P. Patel, NRC Project Manager Dr. W. D. Travers, NRC Regional Administrator to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO THE FIRST REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the First Request for Additional Information (RAI) dated November 7, 2005:

Request 1:

Meggitt Safety Systems, Inc., Fire Test Report, Project No. 14980-121039, dated February 23, 2005 (Attachment 4 to SERIAL: HNP-05-063, dated August 18, 2005): on page 217 in the Conclusions Section, it is stated that "Omega Point Laboratories, Inc.,

has not been requested to analyze the lMegger, Conductor Resistance nor Current Leakage data. These data have, therefore, been presented as collected for review and analysis by authorized, qualified persons." Please provide the document where this review and analysis has been performed. Also, provide the acceptance criteria for the megger, conductor resistance, and current leakage testing of the cables, and the justification for meeting (or not meeting) the acceptance criteria.

Response 1:

The megger, conductor resistance and current leakage data, which was collected during fire testing performed under Fire Test Report Project No. 14980-121039, provides baseline cable performance data during a three-hour fire. To take credit for the fire rated capability of the cable, an application specific analysis (controlled under the plant modification process) is required. This analysis must demonstrate that the cable selected is acceptable for the specific application.

The electrical evaluation portion of the Harris Nuclear Plant (HNP) modification for the Volume Control Tank (VCT) outlet valves, Engineering Change (EC) 52769 titled, "1 CS-165 and 1 CS-1 66 Cable Protection for l-A-EPA, 1 -A-EPB, 1 -A-BAL-B," provides the requested information. Attachment 4 provides this section of the EC package.

Request 2:

Meggift Safety Systems, Inc. Fire Test Report, Project No. 14980-117047, dated July 7, 2004 (Attachment 5 to SERIAL; HNP-05-063 dated August 18, 2005): on page 24 in the Conclusions Section, it is stated that "C'mega Point Laboratories, Inc., has not been requested to analyze the Megger, Conductor Resistance nor Current Leakage data.

These data have, therefore, been presented as collected, for review and analysis by authorized, qualified persons. " Please provide the document where this review and analysis has been performed. Also provide the acceptance criteria for the megger, conductor resistance and current leakage testing of the cables, and the justification for meeting (or not meeting) the acceptance criteria.

Page Al-1 of 6 to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO THE FIRST REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the First Request for Additional Information (RA/) dated November 7, 2005:

Response 2:

The cable performance data collected under Fire Test Report Project No. 14980-117047 provides additional assurance of and demonstrates the acceptability of the cable supports and consistency in cable performance at high temperature, but it was not evaluated in any design or plant modification document. Therefore, no specific review or ana ysis is provided for this test.

Request 3:

Please explain why the acceptance criteria in the CP&L Meggiff Cable Test Plan -Test 3 (Document Number 51-5060368-01, page 31 of Attachment 4) is only for cable supports and does not include cable functionality.

Response 3:

The acceptance criteria for the cable supports is not application dependant. Electrical performance characteristic acceptance criteria is dependant on application specific design constraints. HNP EC 52769 contains the analysis based on the baseline cable performance data collected under Fire Test Report Project No. 14980-121039. The evaluation contained in EC 52769 demonstrates that Meggift Safety System fire-resistive cable is acceptable for use in the Volume Control Tank outlet valve application as set forth within the EC.

Request 4:

Please explain why the acceptance criteria in the CP&L Meggitt Cable Test Plan (Document Number 51-5038146-02, page 29 of Attachment 5) is only for cable supports and does not include cable functionality.

Response 4:

The acceptance criteria for the cable supports is not application dependant. Electrical performance characteristic acceptance criteria is dependant on application specific design constraints as stated in Response 3 of this RAI.

Page Al-2 of 6 to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO THE FIRST REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the First Request for Additional Information (RAI) dated November 7, 2005:

Request 5:

On Drawing No. 02-5050103A-01, there appears to be four cables in the area of the section cut C-C. On Drawing No. 02-5050106A-00, Section C-C, five cables are shown.

Please explain this apparent discrepancy.

Response 5:

As indicated on drawing 02-50501 03A-01, there are four cables in the area of Section C-C. On drawing 02-50501 06A-00, Section C-C indicates four cables and one dead weight. This dead weight was included to demonstrate the acceptability of an alternate type of cable clamp. This alternate clamp type was included in the fire test in both the horizontal and vertical positions.

Request 6:

Meggift Safety Systems, Inc., Fire Test Report, Project No. 14980-121039,dated February 23, 2005 (Attachment 4 to SERIAL: HNP-05-063 dated August 18, 2005):

page 60 - Please confirm that the Megger test was performed on the 4/C #8 cable at 1000 volts direct current (VDC).

Response 6:

In Fire Test Report Project No. 14980-121039, the Megger readings for the 4/C #8 cable shown on page 60 were taken at 1000 volts direct current (VDC) as directed by the test plan (page 39 of the test report).

Request 7:

Meggilt Safety Systems, Inc., Fire Test Report, Project No. 14980-121039, dated February 23, 2005 (Attachment 4 to SERIAL: HNP-05-063 dated August 18, 2005):

page 63 - At the top of the spreadsheet the test voltage is written as 500 VDC. At the right of the first three rows, the voltage is written at 1000 VDC. Below the table there is a note that reads "Resistance measurement @ 500 VDC is the first reading in Megohms for Cond. #1 Red to Black and Red to blue. All other readings @ 1000 VDC. " Please confirm what voltage was used for this test.

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REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the First Request for Additional Information (RAI) dated November 7, 2005:

Response 7:

In Fire Test Report 14980-121039, the Megger readings for the 4/C #8 cable shown on page 63 were taken as follows: The technician attempted to take Megger readings at 1500 VDC during the fire test. With the cable at an elevated temperature, the test equipment was not capable of taking Megger readings at 1500 VDC. The technician reduced the voltage and took the Megger readings at 500 VDC. After taking the first two Megger readings at 500 VDC, the technician was directed to start over and take the Megger readings at 1000 VDC as directed by the test plan (page 39 of the test report).

The report shows that the first two Megger readings were taken at 500 VDC (values on the left). Also shown for the first two Megger readings are the values taken at 1000 VDC (values on the right). The remaining readings on page 63 of the test report were all taken at 1000 VDC as directed by the test plan.

Request 8:

Meggitt Safety Systems, Inc., Fire Test Report, Project No. 14980-121039, dated February 23, 2005 (Affachment 4 to SERIAL: HNP-05-063 dated August 18, 2005):

pages 68 and 69-Please confirm that the Megger testing performed on 8/C #12 - Cable

1. 2 was at 500 VDC.

Response 8:

In Fire Test Report 14980-121039, the Megger readings for the 8/C #12 - Cable #2 shown on pages 68 and 69 were taken at 500 VDC as directed by the test plan (page 39 of the test report).

Request 9:

Meggitt Safety Systems, Inc., Fire Test Report, Project No. 14980-121039, dated February 23, 2005 (Attachment 4 to SERIAL: HNP-05-063 dated August 18, 2005):

page 78 - Please confirm that the Megger testing performed on 7/C #14 - Cable #3 was at 500 VDC.

Response 9:

In Fire Test Report 14980-121039, the Megger readings for the 7/C #14 - Cable #3 shown on page 78 were taken at 500 VDC as directed by the test plan (page 39 of the test report).

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REGARDING THE REQUEST F:OR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the First Request for Additional Information (RAI) dated November 7, 2005:

Request 13:

Meggilt Safety Systems, Inc., Fire Test Report, Project No. 14980-121039, dated February 23, 2005 (Attachment 4 to SERIAL: HNP-05-063 dated August 18, 2005):

page 92 - This page is titled "Certificate of Calibration for Carolina Power & Light." At the bottom of the page it is written "Page 1 of 2." There is no page 2 of 2 provided.

Please provide page 2 of 2.

Response 13:

Page 93 of Fire Test Report Project No. 14980-121039 is the second page (page 2 of 2) of the 'Certificate of Calibration for Carolina Power & Light" (the first page is shown on Page 92 of the test report).

Request 14:

"Propcosed [final safety analysis report (FSAR)J Changes" - Attachment 3 to SERIAL:

HNP-05-063: Please explain why the proposed FSAR changes are written in general terms and not specifically for the circuits associated with volume control tank outlet valves 1CS-165 and ICS-166.

Response 14:

The proposed FSAR change is worded in such a manner as to be consistent with the level of detail currently contained within the Harris Nuclear Power Plant final safety analysis report (FSAR) for electrical cables. The proposed use of fire-resistive cable is discussed in the second paragraph of the Description for the proposed License Amendment (page 1 of Attachment 1), which states:

"HNP proposes to use fire-resistive electrical cable to address the specific circuits associated with the volume control tank (VCT) outlet valves to the charging/safety injection pumps (CSIPs) and may use fire-resistive electrical cable in other applications conditioned upon an evaluation to demonstrate that the cable is acceptable for the specific application."

Per discussions with the NRC on January 12, 2006, approval of this proposed License Amendment may be conditioned upon specific approval to address the circuits associated with the VCT outlet valves rather than generic approval for use of fire-resistive electrical cable. If conditionally approved, then use of fire-resistive electrical cable in other applications would require prior NRC approval.

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REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005:

Request 1:

In the license amendment request (LAR), the licensee stated that two independent, three-hour fire qualification tests specific to the Harris Nuclear Plant (HNP) applications were performed, and both of these tests will be used to bound the HNP applications of stainless steeljacketed fire resistive cables by Meggitt Safety Systems Inc. (Meggitt cables). The licensee further stated that the installation requirements for the cable and supports will be bounded by the tested configurations. These installation requirements will include such details as: minimum bond radius, clamp torque force, maximum support span, minimum seismic clearance, minimum electrical separation, routing to protect against mechanical damage from other equipment, restrictions on contact with galvanized material, grounding of cable, and application-specific evaluations to demonstrate that the cable is acceptable for its tested insulation resistance values.

Please provide the specifics of the above mentioned installation requirements which will be bounded by the fire test configurations providing references to the pertinent pages from the Meggitt cable test reports.

Response 1:

Fire test Project Report No. 14980-117047 referred to in the HNP proposed License Amendment is applicable since it provides additional assurance of and demonstrates the acceptability of the cable supports and consistency in cable performance at high temperature, but its cable performance data was not evaluated in any design or plant modification document. Therefore, the test report referred to in this response (Response 1 of this RAI) is Fire Test Report Project No. 14980-121039.

Minimum bend radius: The minimum bend radius is six (6) inches as specified by Meggilft Safety Systems Inc., Appendix R Cable Specifications, dated April 12, 2004 (Attachment 3 of this response). General Notes 1.b) on Page 55 of the fire test report states,, "Minimum bend radius is 6 inches. At least one bend shall be installed with a minimum bend radius as indicated on Drawing No. 02-5050103A." This specific installation requirement will be incorporated into HNP drawings 6-B-060 Sheet 0007J and 6-B-060 Sheet 0028E by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 1, on 6-B-060 Sheet 0007J, and line items 7-10 on 6-B-060 Sheet 0028E. The mark-ups for these drawings are included in.

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REGARDING THE REQUEST F:OR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005:

Response 1 (continued):

Clamp torque force: The fire test included two different types of B-Line cable clamps, B2000 SS4 and B2088 SS4. The clamping force to be applied to the tested configuration is discussed in General Note 5.d) on Page 56 of the test report for B-Line B2000 SS4 model clamps and General Note 6.c) on Page 56 of the test report for B-Line B12088 SS4 model clamps. HNP modification EC 52769 evaluated the use of the B2000 SS4 clamp, and the specific installation requirement will be incorporated into HNP drawing 6-B-060 Sheet 0007J, specifically the Fire Rated Cable Installation Notes and Details, Note 2. The mark-up for this drawing is included in Attachment 4.

Maximum support span: The maximum support span included in the fire test is 81 inches. Page 49 of the fire test report represents fire test specimen construction drawing 02-5050103A. The drawing includes detail which shows that the distance between supports A-A and B-B is 81 inches. Eighty-one inches is the maximum distance between any two supports within the fire test. This specific installation requirement will be incorporated into H1NP drawing 6-B-060 Sheet 0007J by plant modification EC 52769, specifically the Fire Rated Cable Installation Notes and Details, Note 3. The mark-up for this drawing is included in Attachment 4.

Minimum seismic clearance: This design requirement was not derived from the fire test. Seismic cable separation was selected to be 12" between the outside of cable jacket to the outside of the neighboring cable jacket. Seismic functionality of the cable was demonstrated through seismic testing. A representative sample of cable types, were seismically tested by Trentec, Inc., under the SQURTS Program and is documented under Trentec Inc., Test Report No. 4S002.0. During the seismic testing, the sample cables were installed with %.4" of cable jacket to cable jacket separation at the support locations. During the seismic testing, cable electrical functionality was successfully demonstrated. This specific installation requirement will be incorporated into HNP drawings 6-B-060 Sheet 0007J and CPL-2168-S-9459 by piant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 9, on 6-B-060 Sheet 0007J, and the Seismic Clearance Dimensions, Table 1, Note 7, on CPL-2168-S-9459. The mark-ups for these drawings are included in Attachment 4.

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REGARDING THE REQUEST F:OR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005:

Response 1 (continued):

Minimum electrical separation: During the fire test, the cable samples were installed with two (2) inches of separation between cables centerline to centerline (slightly less than 1%2" between cable jackets). This separation is shown on Pages 49-52 of the fire test report, which represents fire test specimen construction drawings. The results of the fire test demonstrate that the cables; flex and move during exposure to the fire and during the hose stream portion of the fire test. HNP Engineering evaluated the cable separation and movement with respect to cable functionality and concluded that there is no adverse correlation between cable separation and cable functionality during a fire. In other words, the cables can be in contact with one another or with support members during a fire, and it does not adversely impact the functionality of the cable. The only restriction identified is that the cables cannot come in physical contact with galvanized materials. To simplify installation inspections, the electrical separation criteria has been specified to the same value as the seismic inspection criteria, which is 12". The specific installation requirement for 12" of electrical separation will be incorporated into HNP drawings 6-B-060 Sheet 0007J and 6-8-060 Sheet 0007D by plant modification EC 52769, specifically the Fire Rated Cable Installation Notes and Details, Note 10 on 6-B-060 Sheet 0007J, and the Preferred/Acceptable Spatial Separation W/O Barriers Note 7 on 6-B-060 Sheet 0007D. The mark-ups for these drawings are included in.

Routing to protect against mechanical damage from other equipment: The potential exists for non-fire rated features within the plant to fail during a fire. To prevent the failure of these features from physically damaging (falling on) the fire-resistive cable, the design approach for installing fire-resistive cable calls for the cable to be routed as high as possible (along the ceiling) in the subject fire area. The fire test configuration was constructed to represent a ceiling application. The photographs of the test specimen on Pages 282-289 of the fire test report depict a concrete slab, representing a ceiling, with the test assembly mounted on the underside of the slab. For the cable to be routed beneath existing equipment, the equipment must be supported in such a manner that the equipment will not degrade the fire-resistive cable during a fire. This specific installation requirement will be incorporated into HNP drawing 6-B-060 Sheet 0007J by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 11 on 6-B-060 Sheet 0007J. The mark-up for this drawing is included in Attachment 4.

Page A2-3 of 7 to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO THE SECOND REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additionasl Information (RAI) dated December 6, 2005:

Response 1 (continued):

Restriction on contact with galvanized materials: During the fire test documented under Fire Test Report Project No. 149130-117047, the Meggitt cable samples were attached to galvanized coated support members. Pages 47-53 of the test report depict the tested support configurations and materials. The B-Line strut materials shown B1 1, B22 and B52 are hot dipped galvanized materials. During the test, zinc was released from the galvanized coating. The zinc reacted with the stainless steel jacket of the Meggiltt cable and resulted in liquid metal embrittlement (holes) of the jacket. The cable samples subsequently failed to function electrically when subjected to water during the hose stream portion of the fire test.

During the fire test documented under Fire Test Report Project No. 14980-121039, the Meggitt cable samples were attached to both galvanized and stainless steel support members. During this test, the Meggitt cable samples were physically isolated from the galvanized support materials by the use of a stainless steel shield plate. Pages 49-54 of the test report depict the tested support configurations, materials and shield plate details. The Meggitt cable samples demonstrated continued electrical functionality during this fire test. As a result of the testing conducted under Fire Test Report Project No. 14980-121039, the installed Meggitt cable configuration HNP is required to be installed in such a manner that it does not come in direct contact with any galvanized materials. The specific installation requirement that Meggitt cable jacket not be allowed to come in contact with galvanized materials will be incorporated into HNP drawing 6-B-060 Sheet 0007J by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 13 on 6-B-060 Sheet 0007J. The mark-up for this drawing is included in Attachment 4.

Grounding of Cable: During the fire test, Meggitt cable sample jackets were connected to ground at one point along the length of the cable. This connection to ground is shown on the Electrical Wiring Diagrams included in the fire test plan as Figures 7.1-7.4 (pages 43-46). In each of the four figures, the cable jacket is shown as "S metal shield." The specific installation requirement for cable jacket grounding will be incorporated into HNP drawings 6-B-060 Sheet 0007J and 2166-B-051 Sheet 0015 by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 14 on 6-B-060 Sheet 0007J, and Note 31 on 2166-B-051 Sheet 0015.

The mark-ups for these drawings are included in Attachment 4.

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REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005:

Response I (continued):

Application specific evaluations to demonstrate that the cable is acceptable for its tested insulation resistance value: During the fire testing, insulation resistance data was collected. This data will be used in application specific analysis to determine if the Meggitt cable is acceptable for specific fire applications. The requirement to perform application specific electrical cable analysis will be incorporated into HNP drawing 6-B-060 Sheet 0007J by plant modification EC 52769, specifically, the Fire Rated Cable Installation Notes and Details, Note 16 on 6-B-060 Sheet 0007J. The mark-up for this drawing is included in Attachment 4. Attachment 4 also includes the applicable electrical evaluation portion and design drawings of HNP modification EC 52769.

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REGARDING THE REQUEST F:OR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005:

Request 2:

The fire tests have been carried out on the following Meggitt cables:

Cable #1:

4/C #8 A WG, power cable with one of the conductor energized from 480 VA C electrical source with a load current of approximately 0.8 ampere Cable #2:

8/C #12 A WG, control cable with one of the conductor energized from 120 VAC electrical source with a load current of approximately 0.8 ampere Cable #3:

7/C #14 AWG, control cable with one of the conductor energized from 120 VAC electrical source with a load current of approximately 0.8 ampere Cable #4:

7/C #10 A WG, control cable with one of the conductor energized from 120 VA C electrical source with a load current of approximately 0.8 ampere Please confirm whether the Meggitt cattle application will be limited to above nominal conductor size, number of conductors, voltage, and current values. If not, provide an explanation how the deviations will be bounded by the test configurations.

Response 2:

HNP does not intend to limit the Meggitt cable application to the conductor sizes, number of conductors, voltage and current values as listed in Request 2 of this RAI.

HNP will ensure that the specific Meggitt applications are bounded by the testing which has been performed. Meggitt cable is available in a variety of conductor sizes as well as in a number of conductors. Meggitt cable configurations available and considered for inclusion in the fire test included 4/C #8, 4/C #10, 7/C #10, 8/C #12, 7/C #14 and 9/C #14. Generic Letter 86-10 Supplement 1 does not provide guidance with respect to cable selection for inclusion in a fire test. HNP selected several different Meggitt cable types lo be included in the fire test to bound the variety of cable configurations available. UL Standard 2196, Section 4.4, which provides selection criteria for cables to include in a fire test, was used for guidance in cable selection. The criteria suggests the following considerations:

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REGARDING THE REQUEST FOR A LICENSE AMENDMENT TO USE FIRE-RESISTIVE CABLE AT HARRIS NUCLEAR PLANT (HNP)

From the Second Request for Additional Information (RAI) dated December 6, 2005.

Response 2 (continued):

Test UL 2196 Selection Criteria Specimen Selected Smallest conductor size 7/C #14 Minimum number of conductors 4/C #8 Minimum thickness of conductor insulation 7/C #10 Minimum thickness of insulation between conductors 7/C #10 Minimum thickness of insulation between conductors and the outer jacket 7/C #10 Because Meggift cable is also available in #12 wire size, HNP chose to include a sample of an 8/C #12 cable in the test.

Based on the cable configurations selected for testing, and the megger testing, conductor resistance testing and high pot testing performed, all variations of the Meggitt cable configurations are bounded by the fire testing performed. With respect to voltage levels, the #8 power cable was tested to application < 1000 VAC. The control cables were tested for applications of < 250 V[)C and < 120 VAC. The cable performance data collected during the tests was collected following the guidance of Generic Letter 86-10 Supplement 1.

Additional insulation resistance cable performance data was also collected following the method described in NUREG/CR-6776, Cable Insulation Resistance Measurements Made During Cable Fire Tests, published June 2002. This cable performance evaluation method energized a single conductor and monitored the adjacent conductors for indication of changes in insulation resistance. However, the currents utilized in this additional data collection method were not intended to be bounding with respect to field applications of the Meggitt cable. The bounding current for a particular cable is based on an application specific analysis (e.g., Attachment 4 of this RAI response for the VCT outlet valves).

As additional information to facilitate the review of the proposed request, Attachment 3 provides the specifications of the fire-resistive cable.

Page A2-7 of 7 to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 SPECIFICATIONS FOR MEGGITT FIRE-RESISTIVE CABLE Specifications for Meggitt Fire-Resistive Cable Page A3-1 of 3

CZIEGGITT MEGOCIT SAFETY SYSTEMS INC APPENDIX R FIRE CABLE PHYSICAL CHARACTERISTICS CHARACTERISTIC SPECIFICATION Dimensions Outside diameter 0.360" to 0.592" Conductor Sizes

1. 6 AWG to # 16 AWG Sheath Thickness 0.0155 inches, Nominal Cable Weight 0.5'92" diameter, 0.4 lbs/foot (nominal) 0360" diameter, 0.13 lbs/foot Materials Outer Jacket 321 Stainless Steel Conductors Nickel Clad (27%) Copper Dielectric Insulator Silicon Dioxide (SiO2)

ELECTRICAL CHARACTERISTICS PARAMETER SPECIFICATION Voltage Rating 600 VAC Insulation Resistance l.5x10' ohms-feet @ 702F Conductor Resistance, Ni/Cu

• Ni/Cu*

calculated ohms/100 feet

@ RT

@ 1995 0F 16 AWG 0.54 2.89 14 AWG 0.34 1.82 12AWG 0.22 1.14 10 AWG 0.14 0.717 8 AWG 0.09 0.451 Coax cable Impedance 50 ohm nominal;

. 75 ohm, special request Coax Cable Capacitance 25 pf/ft nominal A,.3j 1

1 fi

• r Z

• Ate.~

iNore: ivickel claa Copper conauctors are sizea to me equivalenr copper conductor AWG size.

Appendix R Cable Specifications 4/12/2004 I

mm a:

i i MEOGITF SAFETY SYSTEMS INC GENERAL C RARACTERISTICS CHARACTERISTIC SPECIFICATION

.ri.a.nCanadian Standards Association (CSA),

CertificationClass I & II, Hazardous Locations ASTM El 19-95 (3-hr. exposure)

Verifications Generic Letter 86-10, Supplement I Test VUL 1709 & Norwegian Petroleum Directorate High Rise Fire Exposure Applications Power, Control, Instrumentation, TC Maximum Operating Temperature 1950 OF NaCl, Jet Fuel, Hydraulic Fluid; Chemical Resistance 1H2SO4, HF; and H2S Fumes Mechanical Properties Minimum Bend Radius 6 inches Maximum Tensile Load 5,000 pounds Appendix R Cable Specifications 4/12/2004 2

to SERIAL: HNP-06-004 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 APPLICABLE ELECTRICAL EVALUATION PORTION AND DESIGN DRAWINGS OF THE HARRIS NUCLEAR PLANT (HNP) MODIFICATION FOR THE VOLUME CONTROL TANK (VCT) OUTLET VALVES, ENGINEERING CHANGE (EC) 52769 TITLED, "1 CS-1 65 AND 1CS-166 CABLE PROTECTION FOR 1-A-EPA, 1-A-EPB,

.-A-BAL-B" Applicable Portions of EC 52769 Description Electrical Evaluation, Section BOO, Pages 51-62 of 100 Drawings, Section C02, Pages 16, 20, 22 & 32 of 36 Drawings, Section G02, Page 3 of 50 Drawings, Section C02, Page 32 of 36 (24" x 36" format)

Page A4-1 of 19

PCHG',-DESG Engineering Change 0000052769RII Electrical Evaluation:

Procedure EGR-NGGC-0100 requires changes to the plant auxiliary electrical distribution system to be evaluated for potential adverse impact and for identification of required changes to associated electrical calculations. EC 52769 replaces some control cables associated with Motor Operated Valves 1CS-165 (1-LCV-1 15C or 2CS-L520SA-1) and 1CS-166 (1-LCV-1 15E or 2CS-L521SB-1) with Meggitt Safety Systems, Incorporated Type Si2400 "fire rated" cable.

See Table 1 for a summary of the proposed cable changes and Table 2 for a comparison of electrical characteristics between the existing and proposed cable types.

Cable Sizing:

Control Cables 10243C-SA, 10243F-SA, 10245C-SB, 10245F-SB, 10245K-SB & 10245L-SB Several of the cables identified for replacement have more conductors than what is available in the selected wire gauge replacement cable. The six existing cables identified will be replaced with ten fire rated cables. The following table identifies the replacement configuration. Note that there are changes in wire gauge size. This change is necessary to address voltage drop concerns at high temperatures (this is discussed in greater detail further in the evaluation).

Existing Cable Existing Cable Size 1 Replacement Cable Replacement Cable l

Number l

l Numbers J

Sizes 1 0243C-SA 10/C #12 10243C-SA 7/C #10 10243K-SA 4/C #10 10243F-SA 17/C #16 10243F-SA 9/C #14 l

10243L-SA 7/C #14 10245C0-SB 10/C #12 10245C-SB 7/C #10 10245M-SB (Part) 7/C #10 10245K-SB 10/C #12 10245K-SB 7/C #10 10245P-SB 4/C #10 10245F-SB 17/C #16 10245F-SB 9/C #14 10245N-SB 7/C #14 10245l-SB 4/C #12 10245M-SB (Part) 7/C #10 Control cable selection criteria are specified in Procedure EGR-NGGC-0105. For control cables, there are no specific requirements regarding ampacity or fault current withstand; however, voltage drop must be evaluated. Cables 10243C-SA, 10243F-SA, 10245C-SB, 10245F-SB, 10245K-SB and 10245L-SB are control cables associated with MOVs 1CS-165 and ICS-166 and are evaluated in Calculalions E-5518.049 and E-5518.214.

In order to not reduce margin in the aforementioned control loop voltage drop calculations, the proposed Si2400 cables will be larger than the existing cables (existing # 12 awg will be replaced with #10 awg Si2400 cable and #16 will be replaced with #14). Only cable resistance is used in the control loop voltage drop calculations as allowed by Procedure EGR-NGGC-0105. The resistance of existing #12 awg (;able is 1.886 ohms per 1000' at 500C; whereas, the resistance of the replacement Si2400 #10 awg cable is approximately 1.589 ohms/1 000' at 500C. The resistance of existing #16 awg cable is 4.868 ohms/1000' at 500C; whereas, the resistance of the replacement Si2400 #14 awg cable is approximately 4.022 ohms/1 000' at 500C.

BOO Page 51 of 100

1PCHG-DESG Engineering Change 0000052769RII For MOV 1 CS-1 65, existing #12 awg Cable1 0243C-SA is being replaced with two #10 Si2400 cables (10243C-SA and 10243K-SA) and existing #16 awg cable 10243F-SA is being replaced with two #14 Si2400 cables (10243F-SA and 10243L-SA).

For MOV ICS-166, existing #12 Cables 10245C-SB and 10245K-SB are being replaced with four Si.2400 #10 cables (10245C-SB, part of 10245M-SB, 10245K-SB and 10245P-SB). The existing #16 Cable 10245F-SB is being replaced by two Si2400 #14 cables (1 0245F-SB and 1 02451N1-SB). The existing #12 Cable 1 0245L-SB is being replaced by part of one Si2400 #10 cable (10245M-SB).

Unlike the existing plant cables, the replacement cables are designed to function during a fire scenario. During a fire, the section of cable within the fire area of concern will be subjected to elevated temperatures having an adverse affect on conductor resistance. Based on the replacement cable routes the following lengths of cable will be within fire areas (in other words, these lengths will see the elevated cable temperature due to fire):

Cable Length Total Fire Fire Cable Within a Fire Area*

Cable Length Area Area Rating 102430-SA 150' 297' 1-A-SWGRB 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 102431K-SA 150' 297' 1-A-SWGRB 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 10243IF-SA 65' 115' CSRA 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10243IL-SA 65' 115' CSRA 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 102451C-SB 175' 344' CSRA 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10245M-SB 175' 344' CSRA 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10245'K-SB 50' 114' CSRB 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10245P-SB 50' 114' CSRB 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10245F-SB 30' 9,1' CSRB 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 10245N-SB 30' 911' CSRB 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

• The cable lengths listed were derived from initial field walkdowns. These lengths have been used in the electrical analysis performed to support the design for this EC. Final designed cable routes resulted in shorter cable lengths, within particular fire areas. These shorter routes are used elsewhere in the design evaluation. Because the longer lengths are conservative the electrical analysis is acceptable as is.

The conductor resistance per 1000' for the proposed replacement cables is similar to that of the existing cables for normal and LOCA plant conditions where the conductor temperature is assumed to be 500C. The overall control loop voltage drop during contactor pickup is negligibly higher under"normal" plant conditions, which is acceptable. The voltage drop under LOCA conditions will improve slightly. The NETWORK computer runs for these two calculations have been updated and are included in Section COO as "markups". Note, however, that conductor resistance will increase for the "new fire scenario" where postulated cable temperature is 1093.34°C (2000'F). The "new fire scenario" is addressed in a later section of this evaluation.

Impact on Electrical Distribution Systern Parameters:

The changes in control cable types used for Motor Operated Valves 1CS-165 and 1CS-166 will not result in changes to calculated ac power system voltages, loading or available fault current.

In addition, there will be no impact on calculated EDG loading. Since there are no changes in calculated fault current and since there are no changes to overcurrent protective devices, there is no impact on overcurrent protective device coordination (selective tripping) including Appendix R Coordination.

BOO Page 52 of 100

PCHGi-DESG Engineering Change 0000052769RII Impacted Electrical Calculations:

All electrical calculations are either Priority 3 or Priority 4. No electrical calculations are required to be updated prior to turnover or closure of the EC. The following electrical calculations are impacted by EC 52769 and should be listed on the EC PassPort ADL and in Section C.2 of the EC. Any "markups" should be included in Section COO.

E-6003 See "markups" in Section COO. Tables J4 and J12 in Attachment J will be revised to change the minimum pickup and/or hold-in voltage for MCC-1A31-SA compartment. 4D and 1 B35-SB compartment. 6B. Note that this change does not affect the worst case pickup / hold-in voltage for these two MCCs.

E-551 8.049 See "markups" in Section COO. As a minimum, revise the resistance modeled for each conductor of Cables 10243C & 10243F (replaced with new cables 10243C, K, F and L) and re-run existing NETWORK runs. Note that each cable must be modeled as two cables with a splice to allow modeling the section within the "fire" at a higher resistance. Following is a summary of the required voltage for the present condition, post-modification condition with no fire and post-modification condition with a fire in the fire area with the longest length of Si2400 cable:

PATH DESCRIPTION*

PRESENT MOD (NO FIRE)

MOD (FIRE)

Opening Valve 296.34 296.47 308.12 2

Closing Valve 296.34 296.47 308.12 3

Opening Valve 247.55 247.55 247.55 4

Closing Valve (SI) 306.58 303.33 n/a for fire scenario

• Paths 1 & 2 involve "picking up" the open (or close) contactor using the Control Switch. Path 3 assumes the Open contactor is energized while the valve is in "mid-travel" and determines the required voltage to avoid contactor "dropout".

Path 4 involves "picking up" the close contactor via an SI signal (does not apply to the fire scenario). Path 4 also includes auto swap over (VCT to RWST) on low level. This auto function is not credited for Safe Shutdown.

As can be seen above, the proposed cable changes have basically no impact on required voltages for normal plant conditions. For the LOCA scenario, there is actually a slight improvement in required voltage. Slightly higher voltages are required for the new "fire scenario" due to the higher resistance of that portion of cable affected by the postulated fire.

However, there is considerable margin with respect to the MCC-1A31-SA criteria voltage established in calculation E-6003.

E-551 8.214 See "markups" in Section COO. As a minimum, revise the resistance modeled for each conductor of Cables 10245C, 10245F, 10245K & 10245L (replaced with new cables 10245C, M, K, P, F and N) and re-run existing NETWORK runs. Note that cables 10245C, 10245F and 102451K must be modeled as two cables with a splice to allow modeling the section within the "fire" at a higher resistance. Cable 10245L. is modeled as part of new cable 10245M with a splice. Following is a summary of the required voltage for the present condition, post-BOO Page 53 of 100

PCHG-DESG Engineering Change 0000052769RII modification condition with no fire and post-modification condition with a fire in the fire area with the longest length of Si2400 cable:

PATH 1

2 3

4 DESCRIPTION*

Opening Valve Closing Valve Opening Valve Closing Valve (SI)

PRESENT 302.72 302.72 249.70 333.28 MOD (NO FIRE) 303.78 303.78 249.85 334.42 MOD (FIRE) 324.56 324.56 251.12 n/a for fire scenario

• Paths 1 & 2 involve "picking up" the open (or close) contactor using the Control Switch. Path 3 assumes the Open contactor is energized while the valve is in "mid-travel" and determines the required voltage to avoid contactor "dropout".

Path 4 involves "picking up" the close contactor via an Si signal (does not apply to the fire scenario). Path 4 also includes auto swap over (VCT to RWST) on low level. This auto function is not credited for Safe Shutdown.

As can be seen above, the proposed cable changes have basically no impact on required voltages for normal plant conditions. For the LOCA scenario, there is actually a slight improvement in required voltage. Slightly higher voltages are required for the new "fire scenario" due to the higher resistance of that portion of cable affected by the postulated fire.

However, there is considerable margin with respect to the MCC-1 B35-SB criteria voltage established in calculation E-6003.

References:

EGR-NGGC-0100 EGR-NGGC-0105 EDC-0008 E-6000 E-6003 E-551 8.049 E-5518.214 6-B-4011 0243 6-B-4C1 0245 6-B-041 175S01 6-B-041 179S02 R6 R3 R10 R8 R5 RO RO R20 R21 R21 R18 Electrical Distribution System Change Control Control Cable Sizing Power Cable Sizing Auxiliary System Load Study Emergency FPower System Voltage Criteria Volume Conlrol Tank Outlet Isolation Valve 1 -LCV-1 15C Volume Conlrol Tank Outlet Isolation Valve 1-LCV-1 15E Volume Control Tank Outlet Isolation Valve 1-LCV-1 15C Volume Control Tank Outlet Isolation Valve 1-LCV-1 15E 480V MCC 1A31-SA 480V MCC 1 B35-SB BOO Page 54 of 100

PCHG;-DESG Engineering Change 0000052769RII Evaluation of New Fire Scenario:

The above evaluations determined that cable changes being made under EC 52769 will not adversely impact the electrical distribution system and/or supporting calculations under existinig analyzed scenarios such as normal full power, shutdown, and LOCA. However, a new scenario has been developed which assumes a fire in the area through which the Si2400 "fire-rated" cables pass. It is assumed that the conductor temperature of the Si2400 cables affected by the postulated fire is approximately 20000F (1093.340C) under this scenario. Note that only the control cables for the affected MOVs are being replaced.

Control cable changes will not impact the MOV motor output torque, but they can impact the operation of MCC control circuit components. Therefore, it must be assured that MCC control circuit components (e.g. contactors) for the affected MOV motors are capable of operating during the new fire scenario. New NETWORK computer runs have been performed for the "fire scenario" for Calculations E-5518.049 & E-5518.214 where the temperature of the new Si2400 control cables is 1093.34°C. Worst case MCC voltage required for pickup is 325 volts and the worst case for dropout is 252 volts. These values are well within the calculated voltages shown in Calculation E-6000.

BOO Page 55 of 100

PCHGi-DESG Engineering Change 0000052769RII TABLE I Summary of Cable Changes EXISTING NEW CABLE #

FROM TO CABLE CABLE TYPE LGTH Cable #

TYPE LGTH FIRE*

10243C-SA IA31-SA-4D MTC-IA(SA) 10/C - 12 297 10243C-SA FR # 10 297 150 10243K-SA FR# 10 297 150 10243F-SA MTC-1A(SA)

MCB-1A2 17/C-16 115 10243F-SA FR # 14 115 65 10243L-SA FR # 14 115 65 10245C-S;B 1 B35-SB-6B ATP-SB 10/C - 12 344 10245C-SB FR # 10 344 175 10245M-SB FR # 10 344 175 10245K-'SB ATP-SB MT0CIB(SB) 10/C - 12 114 10245K-SB FR# 10 114 50 10245P-SB FR# 10 114 50 10245F-'B MTII1B(SB)

MCB-1A2 17/C-16 91 10245F-SB FR# 14 91 30 10245N-SB FR # 14 91 30 10245L-UB 1EB35-SB-6B ATP-SB 4/C-12 344 10245M-SB FR# 10 344 175

• Portion of new Si2400 cable affected by a fire in the worst-case fire area (resulting in longest portion of cable eKposed to fire conditions).

TABLE 2 Cable Characteristics CABLE R/1000' R/1000' R11000' R/1000' TYPE (21.1 °C)

_ (25°C)

(50°C)

(1090°C)

Exist 12 awg ctrl n/a 1.720 1.886 n/a Exist 16 awg ctrl n/a 4.440 4.868 n/a FR 10 awg ctrl 1.434 n/a 1.589 7.170 FR 14 awg ctrl 3.630 n/a 4.022 18.200

1. R/1000' at 250C for existing control cable obtained from E-5521.000, R1, Page A7. R/1000' at 21.11 0°C for proposed Meggitt fire-rated" cable obtained from Meggitt data. Twist factor has not been included for comparison purposes. Temperature correction factor for existing copper conductors is (234.5 + T2) / (234.5 + T1) per Okonite Bulletin EHB-90. Resistance Temperature Coefficients for the proposed nickel-clad copper conductors have been calculated from Meggitt data for # 10 and # 14 awg as 246.95 and 246.03 respectively, which are applied in the aforementioned formula. Resistance at 500C has been calculated for control cable conductors using these resistance temperature coefficients.

Resistance of 'fire rated" cable at 2000 F (1093W0.34 C) obtained directly from Meggitt data. Inductive reactance is not used for control cable voltage drop calculations as allowed by procedure EGR-NGGC-0105.

Ampacity is not required for control cables (existing as well as proposed Meggitt "fire rated" cables).

BOO Page 56 of 100

PCHG-DESG Engineering Change 00000527691111 Cable Separation:

Separation of safety related circuits are required to be maintained in accordance with Regulatory Guide 1.75. Separation is provided to maintain independence of electrical circuits and equipment so that the protective functions required during any design basis event can be accomplished. The degree and method of separation varies with the potential hazards in a particular area.

Because routing redundant cables in separate safety class structures affords a greater degree of assurance that a single event will not affect redundant systems, this EC routes redundant cables in separate safety class structures whenever practicable. In those instances in which it was not practicable, a combination of barriers, distances and consideration for the potential hazards were incorporated into the cable routing. Following is a detailed description of the cable routes:

Barrier - The cable itself contains an integrated three hour fire barrier. Factory splices carry the same three hour fire rating as the cable itself.

Distance - Within three hour fire areas it is possible that during a design basis fire some structural components may fatigue or even fail. This could result in falling support material, raceways and equipment. Because the Meggitt Safety System fire rated cable is considerably smaller in size (0.592") than most other installed equipment and raceways, consideration in the routing of this cable included keeping the fire rated cable as high as possible, thus avoiding potential damage from falling objects. The goal when routing the cable in a three hour fire area, was to have the cable above anything which has the potential to fall and damage the cable. The cable is credited in 2 one-hour fire area locations. In both 1-A-CSRA, and 1-A-CSRB the primary combustible hazard is IEEE 383 qualified cable and the areas are provided with suppression. While the tabulated combustible load for the two areas is high, the actual fire hazard is postulated to be a slow growth fire initiated by a cable failure or minor amounts of transient combustibles. Both areas are "no storage" locations where transient material may not be left beyond a work shift.

This type of fire is not postulated to develop a hot gas layer sufficient to cause any structural support fatigue or failures. As a result, the structural supports, equipment and raceways do not present the same damage potential as in a three hour fire area. In a one hour fire area the cable route has been designed using the seismic two over one philosophy. The cable is not routed beneath anything which is not seismically supported which has a size and weight capable of damaging the cable. The cable routes on the RAB 305' and 286' elevations do not contain any pipe whip or missile potentials. The cable route on the RAB 261' elevation in the hallway to Motor Control Center 1 B35-SB does contain mechanical equipment.

Again, this cable is routed as high as possible in order to avoid potential sources of damage.

Seismic Clearance Seismic modeling has been used to demonstrate acceptable interaction distance exist based on separation distances provided on the installation sketches contained within this EC. Typical installation separation distance provided on the sketches is I Y2" cable centerline to cable centerline (0.908" outside of cable jacket to outside of cable jacket) at the supports. This modeling demonstrates that no adverse seismic interaction exists between new fire rated cables and existing equipment/components.

Cable functionality has also been demonstrated through seismic testing. A representative sample of cable types being installed by this EC were seismically tested by Trentec, Inc., under the SQURTS Program. Reference Test Report No. 4S002.0. During the seismic testing performed, the cables were installed with %A" of cable jacket to cable jacket separation at the supports. During the test the cables deflected to the point at which they came in contact with one another (0.0" separation). Even with the cable physical interaction, cable electrical functionality was successfully demonstrated.

Therefore, the minimum seismic separation distance between cable jacket faces established by this BOO Pg 7o 0

BOO Page 57 of 100

PCHG-DESG Engineering Change 0000052769RII EC is 'W. The /2" seismic separation distance will be incorporated onto plant drawing 2168-S-9459

'Safety and Non-Safety Installation Considerations" for fire rated cable installation inspection.

Electricall Separation Cable fire testing was performed. A representative sample of cable types being installed by this EC were fire tested at Omega Point Laboratory under the direction of Framatome/Areva. Reference Test Report 14980-121039. The fire rated portion of the cables (this does not include the terminations) are constructed entirely out or non flammable materials. The cables do not burn or propagate fire. During the fire testing approximately 11/2 " of cable jacket to cable jacket separation distance was maintained between the four cable samples tested. During the fire test, the entire content of the test furnace reached a temperature in excess of 19000F. When the test assembly was removed from the test furnace alt the end of the three hour test, all metal portions (including the cables) of the test assembly were red in color. There was no adverse interaction between cable samples or between cables and the support structure. Before, during and after the fire test electrical functionality was successfully demonstrated. It has been concluded that cable separation with respect to fire having an adverse interaction on cable electrical functionality is not a concern and separation in order to mitigate the propagation of fire with respect to the fire rated cable is also not a concern. For inspection purposes 2166-B-060 Sheet 7D will be updated by this EC to indicate that %2" of electrical separation is acceptable for metal sheathed Fire Rated Cable.

In conclusion, the seismic clearance distance between fire rated cables and other structures shall be in accordance with 2168-S-9459 as revised by this EC. Electrical separation distance between fire rated cables and other cables/raceways shall be in accordance with 2166-B-060 Sheet 7D as revised by this EC.

The Minimum Seismic Clearance Requirement for 3 and 1 Hour Fire Rated Cable is W'A.

Minimum Separation Between Open or Enclosed Raceway and Fire Rated Cable is t/2".

Cable Identification:

The Fire Rated Cable exhibits a combination of raceway characteristics and cable characteristics.

Neither the raceway or cable marking/identification details provide in CAR 2166-B-060 provides direct applicability to Fire Rated Cable. For example the "Typical Ml Cable Marker" instruction on sheet 7AB only identify the cable by number at the ends. If damage occurs to a fire rated cable somewhere in the middle of the route it could be very difficult to quickly determine the plant/system impact by not being able to easily identify what cable has been impacted. Based on this, new color code marking requirements and cable identification requirements will be added to CAR 2166-B-060 specifically for Fire Rated Cable. The following statement will be added to CAR 2166-B-060 Sheet 7A:

'Fire Rated Cable shall be color coded in accordance with 3.2.1A. The color coding shall be applied using tape extending around the outside of the cable jacket. The bands will have a minimum width of 2 inches and be spaced a maximum of 15 feet apart along the length of the cable. Cables shall have cable identification markers installed at each end of the cable as well as each color code location along the length of the cable. Reference Typical Ml Cable Marker shown on sheet 7AB. Cable Markers shall be secured to the cable at both ends using stainless steel tie wire or bands."

For this EC the "Typical Ml Cable Marker" will be extended from 7/8" long to 1" long to allow for a second fastening hole. Addition labels will be installed along the length of each Fire Rated Cable.

These labels will identify the cables by cable number, safety train and that the cable is a three hour fire rated cable. These labels are in addition to the requirements of CAR 2166-B-060 and are being installed as an aid to accurately identify the cables as fire rated equipment.

BOO Page 58 of 100

PCHG-DESG Engineering Change 00000527691111 Evaluation of Insulation Resistance Degradation During a Fire:

When Meggitt cable is exposed to fire, its insulation resistance degrades. The degraded insulation resistance! will result in increased leakage cunent. The purpose of this evaluation is to determine if the reduction in insulation resistance and subsequent increase in leakage current is acceptable.

Increase in leakage current can have adverse affects on control circuits as follows:

a) spurious opening of the control power transformer secondary-side fuse(s) b)

spurious "pick up" of a de-energized contactor c) inability to "drop out" an energized contactor upon demand This EC will evaluate a postulated (conservative) worst case scenario for the 1CS-165 and ICS-166 control circuits in order to determine if the control circuits will still function properly considering the decrease in insulation resistance caused by the fire.

Control Circuit Contactor Data Per EDB and Calculation E-5518.000, NEMA Size 2 contactors are used in safety-related Size 1 and Size 2 starter compartments. Per Calculation E-5521.000, Page A3, NEMA Size 2 contactors have the following electrical characteristics:

Pick Up Voltage 61.6 VAC Drop Out Voltage 47.3 VAC Inrush Resistance 17.4 0 Inrush Reactance 28.5 Q Hold In Resistance 72 fl Hold In Reactance 318 Q Based on pick up voltage and inrush resistance & reactance, the minimum current needed to pick up the contactor would be:

61.6 vac / 417.42 + 28.52

= 1.845 amps Likewise, using drop out voltage and hold-in resistance & reactance, the minimum current needed to prevent an energized contactor from dropping out would be:

47.3 vac 1 4722 + 3182

= 0.145 amps Meggitt Cable Leakage Current Data During Meggitt Safety System fire cable testing, leakage current data was collected using two methods :Reference Omega Point Laboratories Test Report 14980-121039). The first method involved rneggering each control cable sample at 500 VDC and recording the readings. The second method involved energizing one conductor in each sample cable and electronically monitoring each of the other conductors within the cable for leakage current. The test samples exposed to the fire test included a 40 foot length of 7/C #10 cable of which 22.1 feet of the cable was subjected to the elevated temperatures of the test furnace. The cable sample was meggered repeatedly throughout the duration of the fire test and the lowest megger reading obtained was 0.19 Meg-ohm. Neglecting the insulation resistance of that portion of cable sample which was outside the furnace during the fire test, this equates to 4.199 Meg-ohms per foot of cable exposed to the fire test. Assuming that the control circuit voltage is 132 vac for conservatism, this would result in leakage current of 0.03144 ma /

foot of conductor exposed to the fire.

BOO Page 59 of 100

PCHG-DESG Engineering Change 0000052769RII 1CS-165 Control Circuit Evaluation:

The mark-up of CWD 6-B-401 0243, shows existing plant cable 10243F-SA being replaced with two new fire rated cables 10243F-SA and 10243L-SA. The two replacement cables are routed together from inside the Main Control Board, out the bottom of the control board, through the floor and into the "A" Cable Spreading Room. The cables then run through the "A" Cable Spreading Room and exit by going up through the ceiling and into the bottom of Main Termination Cabinet 1A-SA. The total cable route is approximately 115 feet. The ends of Ithe cables which will be located inside the Main Control Board and Main Termination Cabinet 1A-SA account for approximately 10 feet of the overall length.

The remaining 105 feet of each of the cable runs are located within the 'A" Cable Spreading Room in Fire Area CSRA. For conservatism and simplicity, it will be assumed that all utilized conductors of these two cables leak current which could pass through the contactor coil. From the CWD markup, there are 10 conductors being used which would equate to a total of 1050 feet of Meggitt cable in Fire Area CSRA resulting in 33 ma of leakage current. Existing cable 10243C-SA is also being replaced with two new fire rated cables 10243C-SA and 10243K-SA. The two replacement cables run parallel with each other following the same route. These two cables are routed from MCC-1A31-SA to Main Termination Cabinet IA-SA. The cable route involves going through several fire areas. MCC-1A31-SA is located in the 286' RAB South Penetration Area. From there, the cables run through the 'A" and 'B" Switchgear Rooms into the 'A" Cable Spreading Room then up through the ceiling and enter the bottom of Main Termination Cabinet 1A-SA. The longest section of these cables routed through a single three hour fire area is the section which is routed through the 'B" Switchgear Room (Fire Area 1-A-SWGRB). The length of the cable within this room is approximately 120' taken from SK-52769-E-3000 and SK-52769-E-3003. New fire rated cable 10243C-SA is a 7/C #10 and 10243K-SA is a 4/C

1. 10. Of these two cables, 9 conductors are used for a total of 1080 feet resulting in 34 ma of leakage current.

Per the extremely conservative calculations above, the worst case leakage current for 1CS-165 is 34 ma. This is not enough current to spuriously pick up a contactor (which requires 1,845 ma) or to keep an energized contactor fronn dropping out (which requires 145 ma).

Per EDB, control power fuse FUl/243 is a Gould-Shawmut ATM-3 fuse. Field walk down determined the fuse to be a Ferraz Shawmut A6Y3-2B 3 amp fuse. This is documented in AR 157873157873 The markup to Calculation E5518.049 presents three control circuit analysis cases during a postulated fire.

Path 1 F (picking up the open contactor) and Path 2F (picking up the close contactor) indicate 2.6377 amps through the fuse with an MCC voltage of 419vac. Adjusting for maximum allowed MCC voltage of 506 vac and adding the 34 ma of leakage current yields approximately 3.22 amps maximum. Per the markup to Calculation E-5518.049, an A6'Y3-2B fuse can withstand 4.2 amperes for 60 seconds!

Since this current will only last for a few milliseconds until the contactor picks up, this amount of current will not cause the fuse to blow. (Note that the fuse current even without the conservatively calculated leakage current of 34 ma is still 3.19 amperes, i.e. the leakage current causes an insignificant increase in current through the fuse). With regards to the DGVR fuse evaluation for pick-up with degraded voltage, the fuse current considering 34 ma of leakage current is 2.003 amperes which is much less than the fuse rating and therefore acceptable. Path 3F represents steady-state conditions during a fire with the MCC at it highest allowed voltage of 506 vac. In this case the 74 alarm relay is energized and the open contactor is energized. The control power transformer secondary-side fuse current is 0.6179 amps. This current plus the additional leakage current of 34 milliamps would result in control power fuse current of 0.652 amps which will not challenge the 3 ampere fuse.

The control power fuse rated at 3 amps can withstand the additional 34 milliamps of potential leakage current without adverse impact.

BOO Page 60 of 100

PCHG-DESG Engineering Change 0000052769RII ICS-166 Control Circuit Evaluation:

The mark.-up of CWD 6-B-401 0245 shows existing plant cable 10245F-SB being replaced with two new fire rated cables 10245F-SB and 10245N-SB. The two replacement cables are routed together from inside the Main Control Board, out the bottom of the control board, through the floor and into the "B" Cable Spreading Room, through the West wall into the stairwell leading to the 305' elevation. The cables exit the stairwell and enter the room located behind the Main Control Room which contains Main Termination Cabinet 1 B-SB. The cables enter Main Termination Cabinet 1 B-SB through the top and are terminated within the cabinet. Existing plant cable 10245K-SB is being replaced with two new fire rated cables 10245K-SB and 10245P-SB. The two replacement cables are routed together out the top of Main Termination Cabinet I B-SB. The cables then enter the stairwell leading down to the 286' elevation of the Switchgear Room. The cables exist the East wall of the stairwell and into the "B" Cable Spreading Room. The cables are routed through the "B" Cable Spreading Room to Auxiliary Transfer Panel SB where they are terminated. Existing plant cables 10245C-SB and 10245L-SB are being replaced with new fire rated cables 10245C-SB and 10245M-SB. The two replacement cables are routed together out the top of Auxiliary Transfer Panel SB through the "B" and "A" Cable Spreading Rooms down to the 261' elevation of the RAB. The cables are routed in the hallway near MCC-1 B35-SB. The cables are routed into the top of MCC I B35-SB and terminated within the MCC.

The fire areas identified previously, in which the new fire cables are routed, are primarily one-hour fire rated areas (MCC 1 B35-SB areas, "B" Cable Spreading Room, "A" Cable Spreading Room). The longest cable route within a single fire area would be cables 10245C-SB and 10245M-SB routed through the "A" Cable Spreading Room. This length of cable route is approximately 55 feet.

Reference SK-52769-E-3001. Since there are 12 utilized conductors, maximum leakage current would only be 12

• 55 ft

• 0.03144 ma = 21 ma. (In addition to the other conservatisms previously mentioned with regards to 0.03144 ma / ft leakage and assuming all conductors contribute leakage current, the impact of a fire in a one-hour fire area on the insulation resistance is not as significant as in a three hour fire area due to the slightly lower temperatures).

Per the extremely conservative calculations above, the worst case leakage current for 1CS-166 is 21 ma. This is not enough current to spuriously pick up a contactor (which requires 1,845 ma) or to keep an energized contactor from dropping out (which requires 145 ma).

Per EDB, control power fuses FU1/245 & FU1245 are Gould-Shawmut ATM-2 fuses. the markup to Calculation E5518.214 presents three control circuit analysis cases during a fire. Path IF (picking up the open contactor) and Path 2F (picking up the close contactor) indicate 2.5218 amps through the fuse with an MCC voltage of 419vac. Adjusting for maximum allowed MCC voltage of 506 vac and adding the 21 ma of leakage current yields approximately 3.066 amps. Since this current only lasts for milliseconds until the contactor picks up, this amount of current will not cause the fuse to blow.

(Note that the fuse current even without the conservatively calculated leakage current of 21 ma is still 3.045 amperes, i.e. an insignificant change). With regards to the DGVR fuse evaluation for pick-up with degraded voltage, the fuse current considering 21 ma of leakage current is 2.000 amperes which the 2 ampere fuse can readily handle for the required 60 seconds. Path 3F represents steady-state conditions during a fire with the MCC at it highest allowed voltage of 506 VAC. In this case the 74 alarm relay and the open contactor are energized. The control power fuse current is 0.6541 amps.

This current plus the additional leakage current of 21 milliamps would result in secondary control power transformer current of 0.6751 amps which will not challenge the 2 ampere fuse.

The control power fuse rated at 2 amps can withstand the additional 21 milliamps of potential leakage current without adverse impact to the fuses.

BOO Page 61 of 100

PCHG-DESG Engineering Change 0000052769R1 1 Grounding:

Fire Rated Cables being installed by this EC are constructed with an outer metallic sheath. This sheath is required to be connected to the site grounding system. The cables being installed by this EC are not being physically tied to the equipment/cabinets to which they terminate using a grounding bushing. Therefore the cable sheath will be connected to the site grounding system by using a compression type grounding fitting over the outside of the cable sheath. Connection from the compression fitting to the site grounding system shall be made in accordance with 2166-B-051 for 120 VAC control cables.

Connection of the ground compression fitting to the Fire Rated Cable is not a fire rated (tested) configuration and as such, it shall be made in a section of the cable route in which the cable is not required tD be fire rated. The areas of each cable route in which the cables are not required to be fire rated are the equipment terminations. The ground connection should be made as close to the cable termination point (at either end) as possible. As a minimum, the ground connection point on the Fire Rated Cable shall be made within the same Fire Area as the equipment termination (at either end of the cable).

BOO Page 62 of 100

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SCALE, NONE MISCELLANEOUS ELECTRICAL DETAILS AND NOTES I REV IATE CAMI CRIIam lOl DWN ICHK I APP'D rNT-. rCA4 21RR-280S0 tfa2RO C02 Page 22 of 36

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DWG NO. CPL-2168-S-9459 D-Oss