ML19317F565
| ML19317F565 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse |
| Issue date: | 05/25/1977 |
| From: | Roe L TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8001150886 | |
| Download: ML19317F565 (2) | |
Text
,= w 195 v.s. NUCLEAa r.EcutATxy CouuissioN ooCxET Nuu eE n I
~
50- 3Wo s
""""E'"
' NRC DISTRIBUTION ren PART 50 DOCKET MATERIAL TJ:.Mr. John St'olz FROM: Toledo Edison DATE or DOCUMENT
_ 77 05 Toledo Ohio 43652 Lowell E. Roe DATE AECElVED 05-27-77
$ ETTER CNOTORIZED PROP INPUT FORM NUMBER OF COPIES RECEtVED bRIGINAL
% Ng(AgggplED OCO9Y h &lQ){h ENCLO3URE OESCT.lPTION Furnishing requested revisions to.the
~ noise testing program. of NRC 04-08-77 ltr.
request. And changes to Unit 1.FSAR which 1 page will be made in Rev. 27 and supersede al1 i
FSAR changes whick were transmitted by NRC, 03-23-77 ltr....
15 pages
'D0 NOT REiIOVE ADKNOETEDGEp PLANT NAME' DAVIS BESSE UNIT # 1 jC3 SAFETY FOR ACTION /INFORMATION m Tnn I
/ ASSIGNED,5D:
I VQ 5 se llo (Gd AssTm:vn An.
I d,3BA!!CH._CitTEF r Stol ?
nnAwnt entre.
8
/
PRCUECT PANAGER:
W m A n e_s PROJECT MANACER:
I
/ LIC. ASST. :
E / hoi (thd LIC. ASST. :
i t
p w%,
INTERN AL DISTRIBUTION f Q REG FILE T T SYSTEMS SAFETY PLANT SYSTEMS I
SITE SAFETY &
/
M HEINEMAN
/
TERSCO AM ENVIRO ANALYSIS
/ I & E (2.)
SCHROEDER 7
BENAROYA DI'NTON & vt'T T ??
/ OELDL6.-
A TATNAs GCSSICK & STAFF ENGINEERING
/
IPPOLITO ENVIPA_IECH.
MIPC MACARRY l
KIR3NOOD ERNST CASE
/
B032AK BALLARD HANAUER
/ - SIINEIL OPERATING REACTORS SPANGLER HARLESS__
/
PAWLICKI STELLO SITE TECH.
PROJECT MANAGEMENT REACTOR SAFETY OPERATING TECH.
/
CAMMILL C.I)
BOYD
/
ROSS Lfh-
/
- E 521TP STEPP P COLLINS
/
NOVAK 35$
HULMAN HOUSTON
/
ROSZTOC2Y BAER PETERSON
/
CHECK BITTLER SITE ANALYSIS MELT 2 CRIMES
/
VOLLgR th -
hELTEMES AT & I
/
BUNC_H SKOVHOLT SALEMAN
/
J. COLLINS RUTBERC
/ KRECER EXTERNAL DISTRIBUTION CONTROL NUMBER ZId.DR : PC Glan he. h M NATm LAB i
3R00KI E i_NAT YAR-Z, TIC:
ULR_H. SON (ORNL)
M p '.
2 NSIC:
LA PDR ASLB:
CONSULTANTS:
~
/.ACRS lL CYS Thn.ui.M / 3EBT sk 5 CM $4 l
800115087C
(
NRCFLAM 196(2 76)
TDLEDO h EDISON LOWELL E. RCE Ygulatory Docket Fifi
=:= -.-
Docket No. 50-346 mei ass-san N
May 25, 1977 t I rg Scrial No.
282 g
ej A
n, MAY271977> 9.5 Director of Nuclear Reactor Regulation ( j, C"l'O [/p A,. 3,,t.....~ mien 1(D Attn:
Mr. John F. Stolz, Chief g
Light Water Reactor Branch No.
D; Division of Project Management U. S. Nuclear Regulatory Commission
/ co ' \\
Washington, D. C.
20555
Dear' Mr. Stolz:
As request?d in your letter dated April 8, 1977, concerning noise tests on the Davis-Besse Unit 1 Reactor Protection System (Rl'S) we are enclosing as Attachment I revisions to the noise testing program which had been submitted to you in a letter dated March 23, 1977. These revisions provide for noise tests in accordance with MIL. Standard 19900, Section 4.6.11, to be conducted on non-class IE circuits that interface with the RPS. Attachment 2 consists of the changes to the Davis-Besse Nuclear Power Station Unit 1 FSAR which will be made in Revision 27 and supersede all the FSAR changes which were transmitted by our March 23, 1977 letter.
These procedures meet the procedure requirement of License Condition 2C(3)(k) which was included in the transmittal of License No. NPF-3 dated April 22, 1977 for the Davis-Besse Nuclear Power Station, Unit No. 1.
Yours very truly,
' - Revisions to Noise Testing Program - Davis-Besse Nuclear Power Station Unit 1 FSAR rages 8-21a(1) thru 8-21a(10) cp e/2 mh.<.,_a u__
THE TCLECO ECISCN COMPANY EDISCN PLAZA 300 MACISCN AVENtd TCLECO. OHlO 43652
.~
s REVISIONS TO NOISE TESTING PROGRAM
,~
7.0 MIL-199005 NOISE TESTS (for RPS only) - REFERENCE FICURE 4 & 4A i
The MIL-199003 noise tests assume that signal lines which couple isolated signals from Class IE equipment to non-IE equipment can be l
subjected to EMI induced noise signals outside the Class IE cabinets.
The purpose of the MIL-19900B noise tests is to demonstrate that the RPS is capable of performing its protective function following the test.
The MIL-19900B noise test (s) will be conducted as follows:
7.1 One complete RPS channel will be tested.
7.2 An unshielded cable loop per figure 4 will be bundled with all j
non-IE shielded signal cables external to the RPS cabinets.
7.3 MIL-19900B noise source No. I will be connected to the loop -
see figure 4A.
7.4 Prior to the test, the RPS channel will be powered and checked for i
normal operation and its setpoints will be adjusted to maximize sensitivity to transient conditions.
7.5 The switch SI-see figure 4A - will be opened and closed as directed by MIL-19900B. During this time the RPS channel will be observed for any of f normal operation of its Class IE functions.
7.6 The RPS channel will be tested for normal operation following the test.
7.7 Test steps 7.3 through 7.6 will be repeated for MIL-19900B noise source No. 2.
l l
1
- 4a -
'f v
MIL /99003 M0/SE 7~ESTS CLASS IE DIW3/OAl R Fs d4AMMG'
& MIL I99003 RAbuAroR RUN wanIin 17" ai=
ENTRAMCE YO CLASS 12 CABINET b MIL 19900 8 RADIATOlt GUNDLEb wsTH NON IG C O N b uC7~O)f S NelSE SOURCE IrtouciIve-
_^
PE R LonD PER
~
IAIL - 19900B IAlt ~ 19900B
^
sv.ut. rs r=O l
Non te S16ust._
toAos 7 sam,ujgt pgg4 A$
/
l::
~
< c
)
n,;.
i n
i v
20 FEET tAsts
+
1 RGURE
// _
.. l
e 4
tti b4 Q~
2 no k
E Na m
i w
$21 3 s
k m
k "Db
B890 h
Btusa
~e Haags n
e s
m sa 3
O gg n
4 N
D f9 g
s s4 ne.a
~
N C
Sh seu
- r. g he R
%=
~
W 1
=
%yw ty W
D g(S w%kQ M
h 9
w D
NN
+1 Q
k Q
N N S S $w $a s
i 4
W h
w w
w s n D
k k
$, 8 E
n 4
a a
i w$J k
h O
k s
i k
S E
4
%s hs
DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 FSAR Pages 8-21a(1) thru 8-21a(10)
0 D-B Analog signal isolation devices, with individual power supplies, are provided between the sensing channel and the logic channel.
Digital signal isolation 23 devices are provided between the logic channel trip bistables and the output modules of the actuation channel.
Electrical noise transient testing was performed on the SFAS equipment during system functional testing at the vendor facility. Noise transients were generated in close proximity to all interconnecting wiring including essential and nonessential wiring. All equipment was operational with inputs and out-22 puEs simulated.
It was verified that the equipment operation was not af fected by the transients. The noise test report has been submitted as part of the 2-i docket under separate cover.
As a further precaution against electrical noise, particulary radio interference, no portable radio tran:=itters (with attached transmitting antenna) er any other radio trancmitting antennae vill be allowed in the centrol/ cabinet roem or cable spreading rocm.
In addition to the isolation and noise testing described for the SFAS, a test program is planned to further demonstrate the adequacy of the SFAS. The test program will demonstrate the adequacy of the noise rejection isolation devices and internal cable routing of the SFAS for credible electrical faults introduced from non-IE systems and equipment. The test program will envelop the electrical i
noise and electrical faults that can be postulated from interfacing non-IE cabinets.
The postulated electrical. faults have been determined as follows:
3 a
1.
Each non-IE system and equipment that receives signals 27 from the SFAS has been exa=ined to determine if a single credible event in the non-IE systems or equipment can cause an electric.a1 fault (voltage and/or current, steady state faults or transient faults) on non-IE signals, which are all isolated from the IE system, from more than one channel of SFAS. For example, the non-IE plant computer system has been examined to determine if a single credible event within the computer system can impose an electrical fault on non-IE signals originating from more than one channel of SFAS. Non-IE circuits which interface with only one channel of SFAS or are totally channelized from other IE and non-IE circuits will not be tested. These circuits can only affect one channel of SFAS and the remaining channels of SFAS will perform their intended functions in a 2 out of 3 mode if the affected channel fails Not-tripped, or a 1 out of 3 mode if the affected channel fails Tripped.
Documentation will be provided with the test results that will identify the destinationc of all non-IE cables leaving the SFAS cabinets, and vill substantiate the implementa-t;en of the above criteria.
8-21a(1)
Rev:.sion 27
-~
u.. --..
D-R In examining the non-IE systems and equipment, credit has been taken for features in the design of the systems and equipment that preclude failures in the non-II equipment from imposing faults on more than one channel of SFAS. Such features include: shielding of the IE and non-IE cables external to the SFAS cabinets, channel separation of IE and non-IE cables exiting the SFAS, separation in the non-IE
.k systems and equipment that process the signals originated in the SFAS cabinets, and the physical location of cables
. between the non-II cabinets and the SFAS (which are all in the cable spreading room where no power cables are located).
Nonessential cables *.hich exit from the SFAS cabinets do not contain nor come in contact with cables carrying voltages in excess of the isolation device circuit rating. The only non-IE cabinets which interface with more than one channel of the SFAS are the station annunciator and the station computer.
The maximum voltage that can be applied by a credible fault to these circuits in the non-IE cabinets is as follows:
Maximum Voltage Non-IE System /Ecuipment Magnitude 27 Plant Computer - Analog 24 V.D.C.
Plant Computer - Digital 125 V.D.C.
Annunciator 172 V.D.C.
These values are significantly below the rated values of the SFAS isolation devices and the internal and external inter-connecting cabling. The control power cables for the non-IE cabinets are routed separately from the nonessential cables which interface with the SFAS. All cables and wiring to conven-ience outlets (120 V.A.C) are separate from other cables and viring and are installed in exclusively dedicated conduits.
2.
The non-II systems and equipment identified in step I have been coalytod to identify the typec of 21ectrical faults that can occur as a result of credible events in these systems and equip -
ment. From this, the postulated electrical faults have been selected using the following basis:
The non-IE systems and equipment signal processing card or nodule that processes the SFASs signal is assumed to fail such that the electrical energy i.
8-21a(2)
Revision 27
_c -
e.
D-B available to the signal processing card or module from its power supply is applied to the non-IE cable to the SFAS. The available voltage and/or current value (steady state and/or transient) that results from the assumed failure will define the credible electrical' faults to be used in the test program. The consequential effects of the assumed failure will be analyzed to assure that the volt-
,(
age and/or current values used in the test program reflect the complete effect of the assumed failure.
The steady state condition will be determined by the power supply characteristics and circuit imped-ence and the duration of the transient will be determined by the circuit protection device.
The test program will subject the non-IE signal cable or separate wiring loops (Noise loops) installed during the test in the SFXS cabinet to simulate the non-IE signal cable, to the postulated electrical faults. These non-IE signal cables areconnected to one SFAS channel. The single SFAS channel used in the test will either envelop the physical' and electrical con-figuration of the equipment at the plant site or be an actual SFAS channel installed at the plant site. The postulated electrical faults will be generated by utilizing equipment that duplicates the actual power supply distribution used in the non-IE systems / equipment, or by enveloping, 27 vich conservative margins, the non-IE power supply distribution equipment with test equipment. The postulated electrical faults will be applied to representative non-TE nignal or cha Noita 1.eep csbles te de=rnstr:::
coise rejection and isolation capability of the SFAS. '4here applicable, the effects of postulated electrical faults on more than one circuit to the SFAS in a non-IE cabinet will be tested.
Specific test program acceptance criteria developed to assure the SFAS function as designed are:
A.
For postulated steady state electrical faults, i) assurance of trip function during and af ter fault application
- 11) assurance that no spurious trip occurs dur-ing or after fault application B.
For transient electrical faults, i) assurance of trip function af ter electrical fault transient ii) assurance that no spurious trip occurs dur-ing or af ter electrical fault transient
- n addition, no da= age will be allowed en Class !E equipment except fsr *.he non-IE side of the isolation devi:e in the SFAS equipment.
If r3:n.sl under test fails the test, uill be censidered th.'t cl.
inncis would have failed. !! che v-e7 being to.ed rcs co l
t-
,s
y WB the test, it will be considered that all four channels have passed the test.
27 If the acceptance criteria is met as a result of the test program, the noise rejection and isolation capability of the SFAS as installed by the Applicant is considered verified by the test progran.
I:4 l
l C-21a(O j'.
1 D-B 1
As discussed in section 7.2.2.1, physical separation between redundant channels of the RPS is accomplished by locating each redundant channel in a separate cabinet assembly. The cabinet assembly provides physical protection of the cabinet internal equipment from external hazards such as missiles and fire. All openings between the cable spreading room and RPS cabinet s through which RPS cables pass, are sealec to prevent the passage of fire, smoke, and fumes. These seals are silicone foam base.
Internal to the RPS cabinets, the separation of redundant channels is maintained by. isolation device circuits. The isolation device circuits have been tested anh analyzed to protect against short circuits, open circuits, grounds, and 20 the application of ac or de potential as listed below:
1.
Analog signal isolation device circuits are capable of withstanding a minimum of 400 V de or ac peak across their output without af fecting the input.
2.
Digital signal isolation device circuits have a minimum dielectric strength rating of 480 V ac RMS between the input and output signals.
The isolation device circuits include the isolation device, internal wiring, and field wiring connection terminal strips.
The isolation device is an isolation amplifier for analog signals and a relay for digital signals.
The isolation device circuit internal wiring and field connection terminal strips have the same characteristics (flame retardancy, maximum operating tempera-ture, dielectric strength) as the wiring and terminal strips used internally within the cabinets for IE service.
The isolation device circuits have been tested and analyzed by type tests and type analysis to establish the isolation device characteristics. The RPS isolation device circuits for Toledo Edison-Davis Besse i Nuclear Power Generation Station are production units of the circuits tested and analyzed 22 by type. The isolation test report has been submitted as part of the docket under separate cover.
The RPS exhibits a high degree of immunity to the effects of electromagnetic and electrostatic-induced noise on non-IE signal output leads and Class IE input leads.
The immunity to noise has been established by operating exper-ience, tests, and noise-rejection circuits. The Noise Test Report has been 23 T
submitted as part of the docket under separate cover.
In addition to the isolation and noise testing described for the RPS, a test program is planned to further demonstrate the adequacy of the RPS. The test program will demonstrate the adequacy of the noise rejection isolation devices 27 and internal cable routing of the RPS for credible electrical faults introduced from non-IE systems and equipment. The test pro cam will envelop the electrical s
noise and electrical faults that can be postulated from interfacing non-IE
- cabinets, t-2]t(5}
Kevi~sion 27 IT i
I 4
L
r
-~
_. n -. -
D-B-The postulated electrical faults have been determined as follows:
1.
Each non-IE system and. equipment that receives signals from the RPS has been exa=ined to deter =ine if a si: gle credible event in the non-IE systems or equipment caw cause an electrical fault (voltage and/or current, steady
.g s
state faults or transient faults) on non-IE sigt:als,
which are all isolated from the IE system, from more than one channel of RPS.
For example, the non-IE plant :omputer system has been examined to determine if a single credible event within the computer system can impose an electrical fault on non-IE signals originating from more than one channel of RPS.
Non-IE circuits which interface with only one channel of RPS or are totally channelized from other IE and non-IE circuits will not be tested. These circuits can only affect one channel o f RPS and the remaining channels of RPS will perform their intended functions in a 2 out of 3 mode if the affected channel fails Not-tripped, or a 1 out of 3 mode if the affected channel fails Tripped.
Documentation will be provided with the test results that will identify the destinations of all non-IE cables leaving 27 the RPS cabinets, and it will substantiate the implementa-tion of the above criteria.
In examining the non-II systems and equipment, credit has been taken for features in the design of the systems and equipment that preclude failures in the non-II equipment from imposing faults on = ore than one channel o f RPS.
Such features include: shielding of the II and non-IE cables external to the PPS cabinets, channel separation of IE and non-IE cables exitYng the RPS, separation in the non-IE systems and equipment that process the signals originated in the RPS cabinets, and the physical location of cables between the non-IE cabinets and the RPS (which are all in the cable spreading room where no power cables are 1ccated).
Nonessential cables which exit from the RPS cabinets do not contain nor come in contact with cables carrying voltages in excess of the isolation device circuit rating. The only non-IE cabinets which interface with more than one channel of the RPS are the station annunciator, the station computer, the NNI and the Loose Parts Monitoring System cabinets.
8-21n(6)
D-B 4
The maximum voltage that can be applied by a credible fault to these circuits in the non-IE cabinets is as follows:
Maximum Voltage Non-IE System / Equipment Magnitude pg Plant Computer - Analog 24 7.D.C.
s l
Plant Computer - Digital 125 V.D.C.
Annunciator 172 7.D.C.
Non Nuclear Instrumentation 24 7.D.C.
Loose Parts Monitoring System 20 V.D.C.
These values are significantly below the rated values o f the RPS isolation devices and the internal and external inter-connecting cabling. The control power cables for the non-IE cabinets are routed separately from the nonessential cables which interface with the RPS. All cables and wiring to conven-iance outlets (120 V. A.C) are separate from other cablas and viring and are installed in exclusively dedicated conduits.
2.
The non-IE systems and equipment identified in step I have been 27 analyzed to identify the types of electrical faults that can occur as a result of credible events in these systems and equip-ment. From this, the postulated electrical faults have been selected using the following basis:
The non-IE systems and equipment signal processing card or module that processes the RPS signal is assumad to fail such that the electrical energy available to the signal processing card or nodule from its power supply is applied to the non-IE cable to the RPS.
The available voltage and/or current value (steady state and/or transient) that results from the assumed f ailure will define the credible electrical faults to be used in the test program. The consequential effects o f the assumed failure will be analy:ed ra assure that the vol t-age and/or current values used in the test program reficct the complete effect of the a rsened failure.
The steady state condition will be determined by the power supply charactecistics and circuit imped-ence and the duration of the trcr.sient will be deter =ined by the circuit procec?ien device.
l I
8-21a(7)
Revisien 27 l 2~
O466
+w-e w-sb6
i
^
The test program vill subject the non-IE signal cable or separate viring loops (Noise loops) installed during the test in the RFS cabinet to simulate the non-IE signal cable, to the postulated electrical faults. These non-IE signal cables are connected to one RTS channel. The single RPS channel used in the test will either envelcp the physical and electrical configuration of the equipment at the plant site or be an actual RPS channel installed at the pla*.t site. The postulated electrical faults vill be generated by utilir'.ng equipment that duplicates the actual power supply distribution used in the non-IE systems / equipment, or by enveloping, with conservative margins, the non-IE power supply distribution equipment with test equipment. The poskulated electrical faults vill be applied to representative ncn-IE signal cables to demonstrate noise rejection and isolation capability of the RPS.
~
Where applicatie, the effects of postulated electrical faults on more than one circuit to the RPS in a non-IE cabinet will be tested.
Specific test progra= acceptance criteria developed to assure the RPS function as designed are:
A.
For postulated steady state electrical faults, assurance of trip function during and after fault application.
B.
For transient electrical faults, assurance of trip function after electrical fault transient.
In addition, no damage vill be allowed on Class IE equipment except for the non-IE side of the isolation device in the RPS equipment.
If the channel under tect fails the test, it will be considered that all 27 channels vould have failed. If the channel being teated passes the test, it vill be considered that all four channels have passed the test.
3 1
i If the acceptance criteria is met as a result of the test program for postu-lat:ed electrical faults, the noise rejection and isolation capability of the RFS as installed by the Applicant is considered verified by the test program.
In addition to the isolation.and noise testing described, the planned postu-lated electrical fault test, a noise test progran is planned to further de=enstrate the adequacy of the RPS. The noise test vill demonstrate the noise rejection of the RPS for noise induced on non-IE cables exiting the RPS cabinets by conducting generic noise susceptibility tests.
The generic noise susceptibility tests will be in accordance with Mil-199CC3, section 4.6.11 (or equivalent).
~
- The noise test program vill subject the non-IE signal cables external to the Nhl cabinet to the noise sources described in Mil-199003 (or equivalent).
The non-IE signal cables from one RPS channel vill be bundled together.
The noint source cable vill be bundled with the non-IE signal cable for twenty fect-The eingle RPS channel and non-IE cicnal cables used in the test vill eithe enyc1cp the physical and electrical eerfiguration of the equipment at t'>
Art r ue or be an actual RFS channc'
.ed er '
innt citc. The t c :~
n o vill be energized per Mi?-Ic~
1 P
e 9
h'we em e
e o
Wg
-s ow -
e
m p_3 The specific noise test acceptance criteria developed is assurance of trip 4
l function after the electrical noise tests.
j If the channel being tssted fails the test, it will be considered that all four channels vould have failed. If the channel being tested passes the test, it vill be considered that all four channel have passe'. the test.
If the acceptance criteria is net as a result of the noise test program, the 9
~
noise rejection capability of the RFS as installed by the applicant is considered verified by the test program.
lt As'a further precaution against electrical noise, particularly radio inter-ference, no portable radio transmitter (with attached transmitting antenna) or any other radio transmitting antenna vill te allowed in the control /
cabinet rece or cable spreading room.
ASP In-Cabinet Isolatien As discussed in subsection 7.h.2.5.1, physical separatien bet 9een redundant channels of the auxiliary shutdevn panel (ASP) is accccplished by locating each redundant equipment system and its terminations in separate and inde-pendent, fully enclosed subsections of the panel.
Internal to the ASP, the separation of IE and non-IE analog circuits is main-tained by an isolaticn device circuit. The circuit configuration for the analog isolation in the ASP differs frcm the configuration used in the NI/RPS only in that the operational a=plifier in the ASP is used in the noninverted mode while the amplifiers in the NI/RPS are used in the inverted mode. The velt g 1:01stien ::pabilitie: Of the f.SP cen'iguration 1:.crf cinilar t:
that of the NI/RPS. Analysis perfor=ed en the ASP circuits has shcun the sa=e isolation canabilities as the NI/RPS.
Clarificatien to Essential Channels of the SFAS The logic of the safety actuation channel No.1 requires that both the 1
terminatin6 relays of sensing and 1cgic channels No.1 and No. 3 be de-energized to initiate the actuation of channel No.1.
Similarly it is i
required that sensing and logic channels No. 2 and No, h be de-energized to initiate actuation channel No. 2.
See Chapter 7, Secticn 7.3.1.1.2.
1 Approximately fifty percent of the field cable terminations of actuation channel No.1 are =ade in the channel No.1 SEAS cabinets while the remaining field cables of actuation channel No.1 are ter=inated in the channel No. 3 SEAS calinets. Si=ilarly for actuation channel No. 2, the terminating field cables are in channel No. 2 and channel No. 4 SEAS cabinets.
15 TL: field cables are coded by the color of the actuation channel that it serves.
Revision *.
r i
a
~
.O DB Nonestential Channels Nonessential, i.e., ncn-Class IE, functions are divided into channelized cate-gories for i= proving station reliability. Classifications are alphabetized as contrasted to the nt=erical essential channels and are designated as Channels 17 A, B, and C.
Nonessential cables may have any mix of black, white, or yellow jackets when routed in raceways designed to carry nonessential cables. Nonessential 17 22 cables that are routed in raceways designated to carry Class IE cables are 16 color-coded, as a ninimum:
I i
1 l
?
I P
a I
l b;
V--E.." ' - i -
....