IR 05000293/1986012
| ML20203Q168 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/21/1986 |
| From: | Anderson C, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203Q162 | List: |
| References | |
| 50-293-86-12, NUDOCS 8605090077 | |
| Download: ML20203Q168 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/86-12 Docket No.
50-293 License No. OPR-35 Pricrity Category C Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts Inspection Conducted: March 24-28, 1986 Inspectors:
_ _. thano 4-IS-86 S. V. Pul a Protection Engineer d te
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b Approved by:
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C. J. Anderson, Chief, Plant Systems
' date Section Inspection Summary:
Inspection conducted on March 24-28, 1986 (Report No. 50-293/86-12)
Areas Inspected: Routine announced inspection of the plant modification for the Analog Trip System (ATS) and work observations of the new cable installations associated-with various plant modifications.
Results: No violations, deviations or other unacceptable conditions were identified.
8605090077 860502 PDR ADOCK 05000293 O
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DETAILS 1.0' Persons Contacted
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1.1 Boston Edison Company (BECo)
J. Aiello, Electrical Engineer
- M. Akhtar, Modification Management Activity Group Leader
- L. Bechwith, Plant Engineer M. Brosee, Maintenance Section Manager
- R. Fairland, Nuclear Engineering Department
- *F. Famulari, 0QC Group Leader d'
- E. Graham, Compliance Group Leader C. Hulteen, Senior Construction Engineer G. Lafond, I&C.'oervisor
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O. Mills, Construction Group Leader J. Peters, Senior Lonstruction Engineer D. Richards, Senior I&C Engineer
- J. _ Seery, Acting Station Manager R. Velez, Project Manager-Fire Protection a
T. Venkataraman, Principal Licensing Engineer
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E. Ziemianski, Management Service Section Manager i
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1.2 Bechtel Power Corporation (Bechtel)
M. Chaudhry, Electrical Engineer J. Sarino, Electrical QC Engineer
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1.3 Nuclear Regulatory Commission (NRC)
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- H. Eichenholz, Senior Resident Inspector, Vermont Yankee J. Lyash, Resident Inspector, Hope Creek M. McBride, Senior Resident Inspector i
Denotes those present at the exit meeting.
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2.0 Purpose The purpose of this inspection was to ascertain that the plant modifica-tion for the Analog Trip System (ATS) are being implemented properly. The inspection also included work observation of the new cable installations associated with the ATS modification and other plant modifications such as those required by 10 CFR 50 Appendix R and the new process computer.
These modifications are currently in progress and are at various stages of completion.
3.0 ATS Modification 3.1 Description Certain engineered safeguard sensor trip inputs for the Reactor Protection System (RPS) and Emergency Core Cooling System (ECCS)
are being changed from contact switches to analog transmitters with electronic trip units and output relays.
These changes are being made to provide for continuous monitoring of the affected variables, to improve testing procedures and capabilities, and to improve operational characteristics such as fewer instrument testing related scrams and fewer instrument valving errors.
The sensors affected by this change are listed in Attachment 1.
The modification involves replacement of existing mechanically-actuated pressure, level and differential pressure switches which initiate the Reactor Protection and Emergency Core Cooling Systems with an Analog Trip System consisting of environmentally qualified electronic transmitters, master and slave trip units and output relays to perform the same initiating functions.
The modification requires the addition of two new ECCS Analog Trip Cabinets in the cable spreading room, replacement of field mounted (rack or local) switches with new transmitters and routing new instrumentation cable between the transmitters and trip cabinets, and between the trip cabinets and control room.
Each new transmitter will be part of an instrumentatior loop with electronic trip units mounted in cabinets in the Cable apreading Room. A functional block diagram of a typical instrument loop is shown in Attachment 2.
For RPS signals, the existing RPS analog trip cabinets C2228A1 & A2, and C222981 & B2 will house the trip system components.
For ECCS signals, two new Class 1E divisional trip unit cabinets C22233A & B are installed to house the trip system components.
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3.2 Inspection of the ATS Modification i
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This plant modification is being implemented through Plant Design l
Change Package PDC 84-70, Detailed Design for Analog Trip System, l
Revision 0, and several associated Field Change Requests (FCRs). The
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portion of the modification not requiring a plant outage was mostly complete at the time of this inspection. The remaining portion is scheduled to be completed during the next refueling outage beginring September, 1986.
l The inspector reviewed selected portions of the modification package and associated documentation and the completed portion of the modification to ascertain that it is being implemented properly.
The scope of inspection included the following areas:
Review of the modification package to verify that it complied l-
l with the related licensee commitments and requirements (see Attachment 3).
Implementation of the modifications, including work
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observations to ascertain that they were conducted in l
accordance with appropriate specifications, drawings, and other commitments.
l Post-modification testing was conducted in accordance.with
technically adequate and approved procedures.
Adequate quality assurance, including proper administrative
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controls, were in effect for the above activities.
The details of the above areas of inspection are discussed below.
l 3.2.1 Review of the Modification Package l
This modification is being implemented as a major plant design change in accordance with Nuclear Engineering Department Procedure NED 3.02, Preparation, Review, Verification and Revision of Design Documents for Plant Design Changes, Revision 14. The inspector reviewed the procedure and the modification package to verify that sufficient administrative controls existed for the activities associated with the modification and that these controls were in effect.
Specifically, the review i
was to ascertain that the following controls exists:
Procedures for control of the modifications, including
methods for initiating design changes; request for design changes; and methods to assure that the modification does not involve an unreviewed safety question.
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Procedures and responsibilities for design control,
including organizational responsibilities; review of design and modification program; methods for conducting safety evaluation, reviewing and approving design input requirements and performing independent verification;
-training of personnel performing modification activities; and auditing design activities Administrative control for design and document control, a
incluaing interdepartmental interface; record storage; implementation of approved design changes in accordance with approved procedures; post-modification acceptance testing; and post-modification acceptance criteria No unacceptable conditions were identified.
The inspector also reviewed selected portions of the modification package including associated engineering drawings and vendor manuals. The scope of review was to ascertain that the package was technically adequate and complied with the related licensee commitments and NRC requirements.
No unacceptable conditions were identified.
3.2.2 Implementation of the Modification As discussed in Section 3.2 of this report, the modification was only partially completed at the time of this inspection. The procurement requirements for the materia. and the installation instructions are specified in the modification package and are controlled by various BECo standards and specifications. The procurement of major items such as the ATS transmitters and the analog cabinets is the responsibility of BECo. Bechtel is responsible for procurement of miscellaneous items such as cable, conduits, terminal lugs, instrument tubing, supports, etc., and also major installation activities.
The inspector reviewed selected procurement and installation documents to verify that they complied with the appropriate standards, specifications and drawings.
The inspector also toured and visually inspected completed portions of the modification to ascertain that the installation is as specified in the drawings.
The inspector also ascertained that the non-outage related portion of the modification which was in progress during this inspection did not have any safety consequences on the operating plant.
No unacceptable conditions were identifie.
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3.2.3 Post-Modification Testing At the time of this inspection, only a small part of the testing was complete. Most of the testing is to be done after the modification is complete, i.e., end of September 5, 1986 refueling outage. However, the inspector verified that the licensee has a program to perform the required testing. The licensee plans to conduct approximately 10 tests (numbered TP-86-06, 09, 11, 12, 18, 19, 22, 23, 25 and 52) to cover the fifty six ATS transmitters and their associated instrument loops thereby testing the entire modified system. The procedures were mostly in draft form at the time of this inspection.
The inspector reviewed the followed randomly selected procedures:
TP-86-06, Preoperational Test of Modifications on RPS
Analog Trip Cabinets C-2228A1 & A2 and C-222981 & B2, Revision 3 TP-86-12, ATS Loop Test of Racks C1%"/. 2nd C1293
Transmitters, Revision 0 TP-86-18, ATS Loop Test of Rack C2205 Transmitters,
Revision 0 TP-86-22, ATS Loop Test of Racks C2251 ar" C2252
Transmitters, Revision 0 TP 86-25, ATS Loop Test of Locally Maintained
Transmitters, Revision 0.
The inspector also reviewed the test results for the part of Procedure TP 86-06 conducted on March 20, 1986, i.e.,
the test for Cabinet C2228A2.
In addition, the inspector reviewed Nuclear Operations Department Procedure N00 1.3.4, Procedures, Revisions 29, which is the administrative control procedure for preparation of all procedures.
The scope of the above review was to ascertain that:
Appropriate administrative controls were in effect for the
preparation and performance of the test procedures.
The test procedures were technically adequate to
functionally verify the operability of the modified systems.
The independent reviews were performed to determine the
adequacy of the procedure.
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The procedures were approved by the Operations Review
Committee (ORC).
The test was performed in accordance with the approved
procedures.
The test results met the specified acceptance criteria.
- No unacceptable conditions were identified.
3.2.4 Quality Assurance The scope of inspection included a verification that the modification is being implemented in accordance with the quality assurance requirements of the following documents:
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants.
Pilgrim Quality Assurance Manual
Nuclear Engineering Department Procedure"NED 3.02;
Preparation, Review, Verification and Revision of Design Documents for Plant Design Changes; Revision 14 Other requirements and licensee commitments (see
Attachment 3).
No unacceptable conditions were identified.
4.0 Work Observation of Electrical Cable Installation The work observation included inspection of completed cable installations for various plant modifications which are currently in progress and the installation work in process at the time of the inspection.
4.1 Completed Cable Installation l
Randomly selected sample of completed cable installations were inspected. Those installations were associated with plant modifi-cations such as those required for the ATS, 10 CFR 50 Appendix R, and the new process computer. The scope of inspection was:
Cable, wire, and termination materials (lugs, tapes, stress
cones, splice kits, connectors, terninal blocks, etc.) are as specified.
Cable routing is as specified on latest approved drawings.
- Cable identification is preserved and located where specified.
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Bending radius is as required.
- Required separation criteria for physical independence is
maintained.
Segregation is maintained (power, control, instrument).
- There is no evidence of damage to cable.
- Terminations are properly located and made (entry, tightness,
etc.) and a7e of the correct type.
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Cable supports are provided and are adequate.
- Cables are' protected from sharp edges, hostile environments,
and adjacent construction activities (welding, etc.).
Cable tray, conduit, etc., are adequately protected and not
being used as ladders, walkways, etc.
t Clearances between cable and adjacent components such as
piping, ducts, and supports are as specified.
Cabinets, panels, cable trays, junction boxes, etc., are
maintained free of debris (periodically cleaned).
Specified fire barriers, compartment boundary seals and
fire-retardant materials are inrtalled or applied, where required.
Specified inspections are made by qualified personnel.
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Documentation of completed installation and inspection
activities are properly and timely completed.
Nonconforming conditions are identified and handled in
accordance with approved procedures, including adequate justification for use-as-is disposition.
No unacceptable conditions were idenfied.
4.2 Observation of Work in Process
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The inspector witnessed several cable pulling operations associated with 10 CFR 50 Appendix R modifications which were in progress at the time of inspection. The scope of inspection was to ascertain that:
The latest approved revision of applicable construction
specifiations, drawings, pull cards and procedures'are available and used by the installers.
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Cables, associated materials, and pulling compounds are as
specified.
Pulling attachments and tensions used are acceptable.
- Raceway completion and condition are adequate before cable is
installed.
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Cables are protected from sharp edges, hostile environments, a
and adjacent construction activities (especially welding and cutting activities).
Cable routing is correct.
- Separation criteria for physical independence is maintained.
- Segregation is maintained (power, control, instrument).
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Cable identification is preserved.
- Proper bending radius is maintained (during and after
installation).
Cable and other conductor supports are provided.
- Unterminated cable ends are properly protected (i.e., moisture
protection), if required.
Electricians are adequately qualified by an effective
indoctrination and training program QC inspectors are properly qualified and are present and a
performing their assigned tasks, when required, during handling and installation activities.
Nonconformances are identified and handled in accordance with
procedures, including adequate justification for use-as-is disposition.
Installation and inspection activities are being documented
during the activity.
No. unacceptable conditions were identified.
4.3 Quality Assurance The scope of inspection of the new cable installation discussed in Sections 4.1 and 4.2 of this report included the quality assurance aspects of the associated activities.
The scope included a verification that the activities were conducted in accordance with
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i the quality assurance requirements of the following documents.
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear
Power Plants
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Pilgrims Quality Assurance Manual
Other requirements and licensee commitments (see Attachment 4)
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No unacceptable conditions were identified.
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5.0 Unresolved Items
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Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, violations or deviations.
6.0 Exit Interview The inspector met with licensee management representat,!ves (see Section 1.0 for attendees) at the conclusion of the inspection on March 28, 19@6.
the inspector summarized-the scope and findings of the
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inspection at that time.
The inspector and the licensee discussed the contents of this inspection
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report to ascertain that it did not contain any proprietary information.
- ' The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).
At no time during this inspection was written material provided to the licensee by the inspector.
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ATTACHMENT 1
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Analog Trip System Component List
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Sensor System Incation Measured Wriable Division
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PS-503A RPS L
Condenser Vacuan A1 PS-5038 RPS L
(bndenser Vacutan B1 PS-503C RPS L
Condenser Vacusa A2 PS-50 3D RPS L
Cbndenser Vacusan B2 PS-504A RPS L
Turb. 1st Stage Press.
A1 PS-504B RPS L
Wrb. 1st Stage Press.
B1 PS-504C RPS L
hrb. 1st Stage Press.
A2 PS-504D RPS L
hrb. 1st Stage Press.
B2 PS-261-30A PCIS L
MSL *A*
Press.
A1 PS-261-30B PCIS L
MSL * B" Press.
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PS-261-30C PCIS L
MSL *C" Press.
A2 PS-261 -3 G)
PCIS L
MSL *D*
Press.
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LITS-263-59A Nucl. Boiler C2205 Rx Water level
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LIS-263-57A RPS, PCIS C2205 Rx Water Invel A1 LIS-263-57B RFS, PCIS C2205 Rx Water Invel B1 LIS-263-72A ADS, CS, HPCI, C2205 Rx Water Invel A
RCIC, RHR LIS-263-72C ADS, CS, HPCI, C2205 Rx Mater Invel A
RCIC. RHR LIS-263-49A RRR C2205 Rx Press.
A PS-263-5 0A RHR C2205 Rx Press.
A PS-263-51A RPS C2205 Rx Press.
A1 PS-263-51B RPS C2205 RK Press.
PS-263-52A CS, RHR C2205 Rx Press.
A PS-263-5 3A CS, RHR C2205 Rx Press.
A PS-263-55A RPS C2205 Rx Press.
A1 PS-263-558 RPS C2205 Rx Press.
B1 LITS-263-59B Nucl. Boiler C2206 Rx Water level
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LIS-263-58A RPS, PCIS C2206 Rx Mater Invel A2 LIS-263-588 RPS, PCIS C2206 Rx Mater Iavel B2 LIS-263-72B ADS, CS, HPCI, C2206 RK Mater IAvel B
RCIC, RHR LIS-263-72D ADS, CS, HPCI, C2206 Rx Mater Iavel B
RCIC, RHR PS-263-498 RER C2206 Rx Press.
B PS-263-50B RNR C2206 Rx Press.
B PS-263-51 C RPS C2206 Rx Press.
A2 PS-263-51D RPS C2206 RK Press.
B2 PS-263-52B CS, RHR C2206 Rx Press.
B PS-263-538 CS, RHR C2206 RK Press.
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PS-263-55C RPS C2206 Rx Press.
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PS-263-55D RPS C2206 Rx Press.
B2 PS-512C RPS, PCIS C2206 Drywell Press.
A2 PS-512D RPS, PCIS C2206 Drywell Press.
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PS-1001-83B RHR C2206 Drywell Press.
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Sensor System Incation Nasured Variable Division PS-1001-83D RHR C2276 Drywell Press.
B PS-1001-89B ADS C2206 Drywell Press.
B PS-1001-890 ADS C2206 Drywell Press.
B PS-1001 -9 0B CS, HPCI, RHR C2206 Drywell Press.
B PS-1001-900 CS, HPCI, RHR C2206 Drywell Press.
B PS-512A RPS, PCIS C12 9A Drywell Press.
A1 PS-512B RPS, PCIS C129B Drywell Press.
B1 PS-1001 -8 3A RHR C12 9A Drywell Press.
A PS-1001 -83C RHR C129A Drywell Press.
A PS-1001 -89A ADS C129B Drywell Press.
A PS-1001-89C ADS C129A Drywell Press.
A PS-1001-9 04 CS, HPCI, RHR C129B Drywell Press.
A PS-1001-90C CS, HPCI, RHR C129A Drywell Press.
A PS-516 RPS ( Annune.)
C129A Drywell Press.
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LITS-263-73A RHR C2251 Rx Mater Iavel A
LITS-263-73B RHR C2252 Rx Water Invel B
DPIS-261-2A PCIS C2256 MSL "A" FIow A1 DPIS-261-2B PCIS C2256 MS L " A" now B1 DPIS-261-2C PCIS C2256 MSL "A" now A2 DPIS-261 -2D PCIS C2256 MS L " A" now B2 DPIS-261-2E PCIS C2256 MSL "B" Flow A1 DPIS-261-2F PCIS C2256 MS L * B" Flow B1 DPIS-261-2G PCIS C2256 MSL "B" Flow A2 DPIS-261-2H PCIS C2256 MS L " B" Flow B2 DPIS-261-2J PCIS C2256 MSL "C" Flow A1 DPIS-261-2K PCIS C2256 MS L " C" Flow B1 DPIS-261-2L PCIS C2256 MSL "C" Flow A2 DPIS-261-2M PCIS C2256 MS L " C" Flow B2 DPIS-261-2N PCIS C2256 MSL "D" now A1 DPIS-261-2P PCIS C2256 MSL "D" Flow B1 DPIS-261-2R PCIS C2256 MSL "D" Flow A2 DPIS-261 -2S PCIS C2256 MS L "D " Flow B2
ATTACHMENT 2
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Analog Trip System Transmitter and Mastor Trip Unit Functional Block Diagram
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ATTACHMENT 3
__ References for the Analog Trip System Modification 1.
Codes, Standards and Regulatory Requirements 10 CFR 50, App. B Quality Assurance Criteria for Nuclear Power Plants 10 CFR 50, App. R Fire Protection Program for Nuclear Program Facilities Operating Prior to January, 1979 10 CFR 50.49
~ nvironmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants.
10 CFR 50.59 Changes, Tests and Experiments 10 CFR 21 Reporting of Defect and Non-Compliances IEEE 279-1971 Criteria for Protection Systems for Nuclear Power Generating Stations IEEE 308-1980 Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Systems IEEE 323-1974 Qualifying Class 1E Equipment for Nuclear Power Generating Stations IEEE 344-1975 Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generat-ing Stations IEEE 379-1977 Standard Application of Single-Failure Criterion to Nuclear Power Generating Station Class IE Systems IEEE 383-1974 Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations IEEE 384-1981 Standard Criteria for Independence of Class 1E Equipment and Circuits 2.
BECo Specifications C-26, Rev. E3 Furnishing, Delivery and Erection of Structural Steel
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Attachment 3
C-86, Rev. El Design, Installation and Inspection of Hilti Kwik-Bolt Concrete Anchors C-87, Rev. El Procurement, Acceptance, Storage and Handling of Hilti Kwik-Bolts C-88, Rev. E0 Procurement and Placement of Nonshrink Grout C-90, Rev. E0 Conduit Support Specification, BECo #C-90-ER-0-E0 C-93, Rev. O Furnishing, Delivery, Storage, and Application Field Painting Outside the Primary Containment C-94, Rev. E0 Procurement, Receipt, Installation and Inspection of High Strength Bolts, Nuts and Washers C-98, Rev. 0 Furnishing, Delivery, Storage and Application of Special Coating Materials C-109, Rev. O Design, Installation and Inspection of Hilti Hol-Hugger Sleeve Anchors for Use in Masonry Block Walls E-211, Rev. 3 Cable Scheme Index E-258, Rev. 19 Grounding & Cathodic Protection - Notes Symbols
& Details E-345 Raceway Schedule E-346 Cable Schedule E-347, Rev. E2 Raceway Installation Criteria M-260-1, Rev. G Instrument Index Report M-300, Rev. E2 Piping Classification M-301, Rev. 9 Field Fabrication and Installation of Piping and Instrumentation M-543, Rev. O Procurement, Acceptance, Storage and Handling of Instrument Tubing 3/4" 0.D. and Under M-548, Rev. O Procurement, Acceptance, Storage and Handling of Swagelok Tube Fittings: One Inch and Under
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Pilgrim Plant Documentation PNPS Final Safety Evaluation Report Pilgrim Technical Specifications PNPS Operations Manual Pilgrim Instrument Data (VISI Sheets)
Equipment Qualification Master List (EQ List)
Pilgrim Seismic Spectra PNPS No. 600 Unit 1 Spec. for Seismic Qualifcation of Safety Essential Equipment & Equipment Supports Wyle Seismic Test Report No. 45353-1 & Flex Conduit Test Report No.
45592-3, Model 1153 Series B Pressure Transmitter Nutherm Report N-105-02RA, Revision 1 Equipment Environmental Qualification Report, Nutherm Analog Trip Calibration Cabinets, Pilgrim Nuclear Power Station, Unit 1 4.
General Electric Documents 22A3034, Rev. 0 Electrical Equipment, Separation for Safety Systems NEDO-21617-A,12/78 Licensing Topical Report - Analog Transmitter / Trip Unit System for Engineered Safeguard Sensor Trip Inputs.
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ATTACHMENT 4 References for Electrical Cable Installation 10 CFR 50, Appendix A, General Design Criteria for Noclear Power Plants, Criteria 1, 2, 3, 4, 5, 17, 18, 19, 20, 22, 24, 34, 35, 38, 39, 40 and 46.
10 CFR 50, Appendix 8, Quality Assurance Criteria for Nuclear Power Plants Facility SAR, Chapters 1, 3, 6, 7, 8, 9, and 17, including pertinent codes and standards referenced in these chapters National Electrical Code, NFPA 70-1978 (ANSI)
Regulatory Guide 1.6, Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems Regulatory Guide 1.32, Criteria for Safety-Related Electric Power Systems for Nuclear Power Generating Plants (IEEE 308)
Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants (ANSI N45.2.2)
Regulatory Guide 1.39, Housekeeping Requirements for Water-cooled Nuclear-Power Plants
. Regulatory Guide 1.53, Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems (IEEE 279 and IEEE 379)
Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel (ANSI N45.2.6)
Regulatory Guide 1.64, Quality Asssurance Requirements for the Design of Nuclear Power Plants Regulatory Guide 1.75, Physical Indpendence of Electric Systems (IEEE 384)
Regulatory Guide 1.88, Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records (ANSI N45.2.9)
Regulatory Guide 1.89, Qualifications of Class IE equipment for Nuclear Power Plants (IEEE 323)
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