ML17275B029

Provides Recommendations Re Cable Separation Criteria Proposed by Util at 810401 Meeting.Associated Circuits Should Be Analyzed or Tested to Demonstrate That Class IE Circuits Are Not Degraded Below Acceptable Level

ML17275B029
Person / Time
Site:	Columbia
Issue date:	05/04/1981
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Ferguson R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 8105150438
Download: ML17275B029 (8)

Text

IlHLQ6R DRKT rlLE 60PY Docket No. 50-397 Washington Public Supply System ATTN:

Hr. R. L. Ferguson I1anaging Director 3000 George Washington Way Ny 4 )9g

Richland, Washington 99352

Dear Mr. Ferguson:

DISTRIBUTION:

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TERA NRC/PDR L/PDR NSIC TIC ACRS (16)

Subject:

Staff Response to the Presently Proposed Cable Separation Criteria for the WNP-2 Facility In response to our question regarding the separation criteria for electrical cables in the WNP-2 facility (Item 031.100),

you submitted proposed criteria in an amendment to the FSAR in July 1980.

This proposed cable separation criteria was discussed by the staff with your representatives in a meeting in Bethesda on April 1, 1981.

As a result of our review of your July 1980 submittal and following our discussion on April 1st, ~we accept your response to Item 031.100 with a few exceptions as noted below.

These exceptions are related to the definition of associated circuits and their criteria for in-stallation.

He also have exceptions to your criteria governing the installati of non-Class 1E circuits.

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clrcults, we accept your proposed three-part Q

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Associated circuits are those:

08 I Hon-Class 1E cables/wires which share raceways with Class lE cables/wire "N ~, 6 and which are not physically separated from Class 1E cables/wires.

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Hon-Class 1E cables/wires which share enclosures with Class 1E cables/wires and which are not physically separated from Class 1E cables/wires.

Non-Class lE cables/wires which carry non-class lE loads but which are supplied from a Class 1E power source.

We recommend that you adopt the following separation.

criteria for associated (as defined above) and non-Class lE circuits. These recommended criteria should replace the criteria for non-Class 1E circuits you proposed in your response to Item 031.100.

1.

Associated circuits shall be uniquely identified as such or as Class lE and shall remain with, or be physically separated the same as, those Class lE circuits with which they are associated.

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We also require you to propose a criterion which addresses the requirements for separation of redundant conduits. If you have already done so, we require you to explicitly identify this criterion.

The intent of. our recommendations regarding the cable separation criteria contained in this letter is to expedite the resolution of our concerns regarding the cables you have already installed in the WNP-2 facility, to alert you to the unacceptability of certain portions of your proposed separation criteria, and to facilitate the determination of compliance by our Region V inspectors.

On this basis, we are recommending as separation criteria only those portions of IEEE Std. 384

( 1977) which are required to resolve our concerns about the

~wiring presently installed.

If you have any questions on this matter, please contact H. D. Lynch at 301/492-8413 or R. Auluck at 301/492-7702.

Sincerely, Robert L. Tedesco, Assistant Director for Licensing Division of Licensing cc:

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~I 2.

Associated circuits shall comply with the requirements described in Criterion I above from the Class 1E equipment up to and including an isolation device.

Beyond the isolation device, these circuits are not subject to the re-quirements of these criteria, provided they do not again become associated with a Class lE system.

3.

Associated circuits shall be analyzed or tested to demonstrate that Class lE circuits are not degraded below an acceptable level.

4.

tlon-Class lE circuits shall be physically separated from Class lE circuits and associated circuits by the minimum separation requirements specified for redundant Class 1E divisions or they become associated circuits.

5.

Non-Class 1E circuits shall be electrically isolated from Class IE circuits and associated circuits by the use of isolation devices, shielding and wiring techniques, physical separation, or an appropriate combination or they become associated circuits.

6.

The effects of lesser separation or the absence of electrical isolation between the non-Class lE circuits and the Class 1E circuits or associated ci rcuits shall be analyzed to demonstrate that Class 1E circuits are not degraded below an acceptable level or they become associated circuits.

7.

Low energy non-Class lE instrumentation and control circuits are not required to be physically separated or electrically isolated from associated circuits provided:

(a) the non-Class lE circuits are not routed with associated cables of a redundant division; and (b) they are analyzed to demonstrate that Class lE circuits are not degraded below an acceptable level.

As part of the analysis consideration shall be given to potential energy and identification of the circuits involved.

If you adopt the staff's recommendations listed above, identify those circuits which will be analyzed in order to demonstrate acceptability in accordance with Item 3, 6 and 7 above.

Additionally, identify those circuits which will be modified to comply with either Items I, 2, 4 or 5 above.

Individual circuits need not be identified if an entire class of circuits (e.g., wiring within panels) is to be analyzed.

All future cable pulling should, to the extent

pratical, be in accordance with either Items I, 2, 4 or 5 above as appropriate.

The identification of the above circuits should be done on an expedited basis and the acutal analyses should be presented for our review no later than 3 months prior to the scheduled issuance of the WNP-2 SER.

In addition, revise both Table IY of your response to Item 031.100 and your tray/cable marking codes to be, consistent with your final cable separation criteria.

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NRC FORM 318 110/SOI NRCM 0240 OFFictAL RECORD COPY 0I USGFO'88~28 824

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Mr. R. L. Ferguson Managing Director Washington Public Power Supply P. 0.

Box 968 3000 George Washington Way..

Richland, Washington 99352 cc:

Richard g. guigley, Esq.

WPPSS P. 0.

Box 968

Richland, Washington 99352 Nicholas Lewis, Chairman 820 East Fifth Avenue Olympia, Washington 98504 Mr. 0.

K. Earle Licensing Engineer P. 0.

Box 968 Richland, Washington 99352 Mr. Albert D. Tooth Resident Inspector/WPPSS-2 c/o U.

S. Nuclear Regulatory Commission P. 0.

Box 69 Richland, Washington 99352 Nicholas Reynolds, Esq.

Debevoise 5 Liberman 1200 Seventeenth

Street, N.

W.

Washington, D.

C.

20036

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