IR 05000333/1992024
| ML20034F571 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/23/1993 |
| From: | Paolino R, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034F570 | List: |
| References | |
| 50-333-92-24, NUDOCS 9303040010 | |
| Download: ML20034F571 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
REPORT NO/ DOCKET NO:
50-333/92-24 LICENSE NO:
DPR-59 LICENSEE:
New York Power Authority
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Post Office Box 41 Lycoming, New York 13093 FACILITY:
James A. FitzPatrick Nuclear Power Plant INSPECTION AT:
- Scriba, New ' York
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INSPECTION DATES:
December 7-9,1992 (at site),
In Office Document Review through December 23,1992
>-> P'I3 INSPECTOR:
' CO t-R. Jf Paolino, Sr. Reactor Engineer, Date Electrical Section, EB, DRS
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NM APPROVED:
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W. H. Ruland,' Chief, Electrical Section, D' ate Engineering Branch, DRS Inspection Summary: Inspection on December 7-9,1992 followed by in office review through December 23,1992, of documents and test results furnished by the licensee to support the installed cable configuration (Inspection Report No. 50-333/92-24).
Areas Insrected: Special, announced inspection to review licensee's Electrical Cable -
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Separation Program Plan, and determine applicability of using electrical separation summary.
test data to resolve differences between actual installed cable separation distances and those
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distance specified in the Final Safety Analysis Report (FSAR).
Results: Industry test reports, supporting licensee summary test documents, and licensee cable flame test assessments were reviewed by the inspector. The cables tested were
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equivalent to those used on-site and the reduction in separation distances, based on the review of the test data, indicated that the reduced separation distances would still result in adequate separation.
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1.0 BACKGROUND The electrical separation philosophy utilized in the design of the James A. FitzPatrick (JAF)
facility was provided by General Electric and Stone & Webster design criteria documents.
The intent of these documents (written during the development of the IEEE Std 384-1974,
Trial Use Standard Criteria for Separation of Class IE Equipment and Circuits") was to
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provide design criteria for physical separation of redundant cabling. The major difference
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between IEEE Std 384 and the practice implemented at plants under construction was the recognition of the potential impact of nonsafety-related circuits on the operation of safety-related equipment. Plants issued construction permits prior to 1975 (such as FitzPatrick)
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were not required to separate nonsafety-related and safety-related circuits as defm' ed in the
Standard. This distinction allowed these plants to run nonsafety circuits in safety-related raceways.
In 1977, IEEE Std 384-1977, " Standard Criteria for independence of Class IE Equipment and Circuits," was issued to improve the separation and isolation of all safety-related circuits.
The 1977 Standard continued to prescribe minimum separation distances based on analysis of the proposed cable installation. The IEEE Std 384-1992 incorporated lessons from separation testing on internally-generated faults. This latest revision reduced the separation criteria
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based on test results and addresses electrical configurations not addressed in the earlier -
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revision. The industry-approved IEEE Std 384-1992 has_not been reviewed or endorsed by the NRC.
I The JAF FSAR addresses electrical separation of safety-related circuits from the standpoint of voltage class segregation, physical separation, and circuit isolation. The criteria for _
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physical separation of cables for ' redundant safety-related functions, as stated in the FSAR,.
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requires that a minimum horizontal distance of 3 ft and/or minimum vertical distance of 7 ft.
be maintained between cable trays, conduit, and armored cables not in trays. The adequacy
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of the physical separation of cables was identified as a potential startup issue (50-333/92-82-04) at FitzPatrick during the October 20,- 1992, NRC inspection. Further
inspections by licensee engineering personnel revealed a number of other cable installations i
that appeared to differ from the electrical cable separation criterion specified in the FSAR.
2.0 SCOPE OF INSPECTION Determine the extent and significance of the cable separation discrepancies and review applicability of documentation used by licensee to support acceptance of the installed cable configuration.
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3.0 WALKDOWNS The licensee established an electrical separation assessment program on November 20,.1992.
The purpose was to provide guidance for identifying, resolving, and correcting deviations
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from existing electrical separation criteria for safety-related raceways, cables, and equipment.
l The program was to provide assurance that the minimum required safety-related redundant -
circuits were physically independent. A 100% walkdown of the Control Room, Relay Room, Cable Spreading Room, Cable Tunnels, Battery Room Corridor, Radwaste Control
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Room Panels, and the Screenwell Emergency Pump Room was performed by the licensee.
In addition, a sampling was performed of balance-of-plant raceways and equipment selected
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from previously completed modifications. Using applicable design documents and drawings, the licensee visually identified raceways and equipment for the walkdown. Instructions, acceptance criteria, and training was provided for personnel participating in the walkdown; The personnel involved in the walkdown were knowledgeable, experienced, and cognizant of the inspection requirements. The discrepancies noted during the walkdown were separated into four (4) categories for further review and analysis by an independent contractor.
Generic Minor Modifications (GMM) were prepared for the resolution of deviations.
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Engineering Change Notices (ECN) were issued to resolve individual deviations. Evaluations-were performed to determine the reportability to the NRC under 10 CFR 50.73 requirements.
4.0 REVIEW AND ANALYSIS Of the thousands of items examined during the walkdown, 532 apparent discrepancies were documented. The walkdown documentation was reviewed by the licensee to determine if the
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apparent discrepancies actually deviated from the separation criterion specified in the FSAR or if it was an acceptable installation. A separation distance screening process was established by the licensee to group deviations and to focus the evaluation on those deviations
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that are potentially safety significant. The deviations were placed into three (3) groups, as
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follows:
r Group 1 - Separation distances less than three (3) ft horizontal, seven (7) ft vertical,
but greater than one (1) ft horizontal, one (1) ft vertical between cables of redundant color-codes.
Group 2 - Separation distances less than one (1) ft horizontal, one (1) ft vertical
between cables of redundant color-codes.
Group 3 - Common supports for conduits of different color-codes.
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Group 3 anomalies associated with the common supports were reviewed by the licensee and found to be acceptable. No operability issues were identified. The results of the licensee review were documented in evaluation report no. JAF-NSE-92-221. Based on this evaluation, the licensee concluded that the passive failure of a Category 1 support (which is
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considered a non-active part of the system) need not be assumed to occur in the event of a design-basis accident. The use of a common support for redundant conduits and cable trays
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did not involve an unreviewed safety question since all Category 1 conduits and cable trays were designed to withstand seismic loads and therefore the requirement for independent
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supports did not apply.
Group 2 anomalies involved 81 apparent deviations representing potential "non-conforming conditions," as defined in Generic Letter 91-18, "Information to Licensees Regarding Two
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NRC Inspection Manuals on Resolution of Degraded and Nonconforming Conditions and On Operability." Evaluation report JAF-NSE-92-236 addresses potential operability issues associated with the 81 apparent deviations where field walkdowns indicated that less than one foot separation existed between cables, or cable trays of different color-codes.' However, the basis for acceptance of separation distances ofless than one foot was the IEEE Std 384-1992 e
standard which has not been reviewed or endorsed by the NRC.
i The licensee's basis for acceptance of Group 1 anomalies was documented in evaluation report No. JAF-NSE-92-238. No operability issues were identified. The inspector's review of JAF-NSE-92-238 indicated that the licensee acceptance was based on summary test data of various tests conducted by industry.
Supporting documentation was not available during the site inspection for the summary tests used as a basis for acceptance of the discrepancies identified for Group 1 & 2. On December 23,1992, the licensee submitted a copy of Wylie report 17769-1, dated August 23,1985, which had been accepted by the NRC at another nuclear installation. The test program was designed to demonstrate the acceptability of various proposed configurations in accordance with Regulatory Guide 1.75, Revision 2, " Physical Independence of Electrical Systems," and with Section 5.1.1.2 ofIEEE Std 384-1974, which allowed the use of testing and analysis to justify separation ofless than the spatial
requirements of Section 5.1.3 & 5.1.4 Based on the inspector's review of this report, the walkdown documentation, and the cable types, sizes, and configurations at JAF, the Wylie test report of cable separation distances bounded the FitzPatrick installation and, therefore, was appropriate for use at JAF as alternate criteria.
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5.0 CONCLUSION i
Based on an NRC in-plant inspection and review of licensee plant walkdown programs and supporting test results, the NRC concluded that the Wylie Test Report Results (No. 17769-1)
bounded the reduced separation distance acceptance criteria used by the licensee.. These test results had been approved by the NRC in a G&rj Evaluation Report issued on.
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February 15, 1986, to the Commonwealth Edison Company to justify the reduced separation
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distances of cable at the Braidwood Nuclear Facility.
The licensee's prograrr. to resolve the separation issue appeared reasonable and -
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comprehensive. Therefore, the unresolved item, 50-333/92-82-04, pertaining to reduced cable separation distance at the FitzPatrick facility is resolved. This item is closed.
The results of this inspection are also reflected in Enclosure 3 of the FitzPatrick restart letter, from T. Martin to R. Beedle, dated December 29, 1992.
i 6.0 EXIT MEETING The inspector met with licensee personnel on December 9,1992 to discuss the scope of the inspection and the findings. Additional telephone conversations were held through December 23,1992, with licensee personnel as additional test data became availnble. Final inspection results were conveyed to the licensee on December 24,1992.
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ATTACHMENT A Persons Contacted
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New York Power Authority
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B. Barrett, GM - Operations L.12bruzzo, Nuclear Licensing Engineer Assistant T. Daugherty, Director of Project Engineering
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J. Hoddy, Senior Licensing Engineer J. Gray, Director Nuclear Licensing (via telephone)
J. Greene, Senior Nuclear Licensing Engineer T. Klein, Manager Electrical Engineering M. Licitra, Supervisor Engineering Operations D. Lindsey, GM - Maintenance K. Mavrikis, Director Nuclear Engineering Design
H. Salmon, Resident Manager A. Zaremba, ORG - Licensing Manager J. Szabados, Assistant Electrical Engineer K. Vehstedt, Senior engineer-Operations
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U.S. Nuclear Regulatory Commission J. Durr, Chief, Engineering Branch /DRS (via telephone)
J. Beall, Chief (Acting), Electrical Section /DRS (via telephone)
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