ML19329F603
| ML19329F603 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/19/1977 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Boyd R Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.008, RTR-REGGD-01.009, RTR-REGGD-01.011, RTR-REGGD-01.022, RTR-REGGD-01.032, RTR-REGGD-01.040, RTR-REGGD-01.041, RTR-REGGD-01.045, RTR-REGGD-01.047, RTR-REGGD-01.053, RTR-REGGD-01.062, RTR-REGGD-01.063, RTR-REGGD-01.073, RTR-REGGD-01.075, RTR-REGGD-01.081, RTR-REGGD-1.008 3987, NUDOCS 8007020762 | |
| Download: ML19329F603 (12) | |
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Stephen H. Howell Vice Pressdent General Of fices: 1945 West Parned Road, Jackson, Michigan 49201
- Area Code 517 788-0453 July 19, 1977 p
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Director of ;iuclear Reactor Regulation
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Attn: :;r Roser toyd, Director 3 @,; o 0 g!..$ M,9
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EDLXiD PROJECT DOCC T ;iOS 50-329, 50-330
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ELCCTRICAL, I!i3TRU:E;TATIC'i XID C0;iTROL EVALUATIO:I 0F RZGULATORY GUIDE POSITIO:IS FILE: 0505 SERIAL: 3957
?ir S A Varga's 3epte=ber 29, 1976 letter trans=itted the 'IRC staff evaluation of the Censumers Power Cc=pany position en Regulator / Guides 1.6, 1.9, 1.11, 1.22, 1.32, 1.40, 1.41, 1.45, l.h7, 1.53, 1.62, 1.63, 1.73, 1 75, and 1.81 relative to the !!idland Plant. Subsequent to your review some of our positions have changed, or require additional clarification due to reinterpretatica of Regulatory Guide contents. Also, we wish to advise you of our intended action in r, hose areas where the Staff's pcsition is interpreted to be different from the Consumer's position.
Attachnent 1 is a Senry Status of each Regulator / Guide reviewed in the Struc-tural Zngineering category. Attachr.ents 2 thru 6 provide additional discussion on individual Regulatory Guides.
The attached caterial is for information only since !!RC evaluaticn on the final LIidland Plant Regulatory Guide positions vill be performed during review of the Final Safety Analysis Report which is scheduled for cubmittal on September 1, 1977
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Summary Status of Electrical, Instrumentation and Control System Regulatory Guides Regulatory Guide Comment 1.6 The Midland project is complying fully 1.9 See Attachment 2 1.11 The M3dland project is complying fully 1.22 The Midland project is complying fully 1.32 The Midland project is complying fully 1.40 The Midland project is complying fully 1.41 The Midland project is complying fully 1.45 The Midland project is complying fully 1.47 The Midland project is complyfag fully 1.53 The Midland project is complying fully 1.62 The Midland project is complying fully 1.63 See Attachment 3 1.73 NRC agrees with the Midland position 1.75 See Attachment 4 1.81 The Midland project is complying fully l
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" Selection of Diesel Generator Set Capacity for Standby Power Supoly" - (March 10, 1971)
Subsequent review of our position has shown that an additional clarification to the implementation of this regulatory guide is required to address the specific diesel generator set which has now been purchased. This clarification is to address the recognized rating of the diesel generator sets and is as indicated below:
As an alternate to the 2,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> and 30 minute ratings referenced in rasition C.2 of the regulatory guide, the ratings of the Midland diesel generator sets are established in accordance with IEEE Standard 387-1972.
The ratings of IEEE Standard 387 provide for a continuous rating of 8,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> and a short-time rating of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
Our vendor's understanding is that Regulatory Guide 1.9 is being revised to reflect the rating of IEEE-387.
Also, in order to correlate load with rating, the following alternative to Position C.2 applies for the Midland diesel generator sets.
The loads for each diesel generator do not exceed 90% of the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> short-time rating of the set.
~*ttrchment 3 Regulatory Guide 1.63
" Electric Penetration Assemblies in Containment Structure for Water-Cooled Nuclear Power Plants" - (October 1973)
The NRC is not in agreement with the position presented by Midland response to NRC question 2.2.1.2.
A meeting was held with NRC on October 14, 1976 and the following position was subsequently developed to address the NRC concerns.
The requirements of Regulatory Guide 1.63, Positions C.2, C.3 and C.4 are fully implemented. The following is being implemented to comply with Position C.1 of the regulatory guide.
In accordance with Position C.1 of the Regulatory Guide, the electrical penetration assemblies are designed to withstand, without loss of mechanical integrity, the maximum fault current vs time conditions which would' occur as a result of single random failures of circuit overload devices, as an alternate to providing adequate self-fusing characteristics within the penetration conductors themselves. Compliance is achieved by implementing the system design methods described below:
General The overload protection system for circuits penetrating the containment meet the intent of applicable portions of IEEE Standard 279-1971, except that circtilt independence and, in some instances, physical separation, are limited in that both protective equipment (primary and backup) may share the same enclosure.
The quality and reliability of overload protection system components for non-Class II circuits is demonstrated through compliance with applicable industrial standards (i.e., ANSI, NEMA, etc).
Overload protection systems are periodically tested to establish a degree of availability and functional performance coceensurate with the protection being provided.
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Design Details:
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1.0 Medium Voltage Power (6.9kV)
1.1 Circuits
The only applicable circuits are the RCP motor power supply.
1.2 Overload Protection System 1.2.1 RCP motor circuit breaker serves as the primary overload protection for all ranges of fault current.
1.2.2 The'6.9 kV main bus feeder breaker serves as the backup overload prctection for all ranges of fault current.
1.2.3 Separate non-Class IE battery sources are provided for the primary and backup protection systems.
1.3 Penetration Assembly Design Penetration conductors are of a sufficien't size that the penetration
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assembly will withstand the available range of fault current for the time duration required for the backup protective device to interrupt the circuit under a single failure condition.
2.0 Low Voltage Power 2.1 480V Load Centers
2.1.1 Circuits
There are no-low voltage power circuits fed directly from a 480V load' center penetrating the containment.
2.2 480V Motor Control Centers (MCC) 2.2.1 Loads not requiring a breaker-starter combination.
2.2.1.1 All loads that fall into this category are de-energized during plant operation, see Section 5.0.
2.2.2 Loads requiring a brea*.ter-starter combination.
2.2.2.1 Circuits:
Includes all Class IE and non-Class IE motor loads and all non-Class IE MOV's.
Does not i
l include safety-related MOV's, see Section 2.2.3.
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2.2.2.2 Overload Protection System: Thermal-magnetic breaker, starter overload and high fault circuit protector (HFCP) fuses in series provide primary and backup overload pro-teccion. Magnetic breaker and starter overload provide HTCP's primary protection for all ranges of fault current.
and breaker thermal element provide backup overload protection for all ranges of current.
2.2.2.3 Penetration Assembly Design: Penetration conductors are of a sufficient size such that the penetration assembly will withstand the available range of fault current for the time duration required for the backup protective device to interrupt the circuit under a single failure condition.
Loads requiring a breaker-starter combination with starter overload 2.2.3 bypassed.
2.2.3.1 Circuits: Includes all containment safety-related MOV's, 3 horsepower, or less. Starter overloads for these cir-
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cuits are bypassed under accident conditions; Reference Branch Technical Position, EICSB-27.
2.2.3.1.1 Overload Protection System: Magnetic breaker provides primary overload protection for fault current in excess of motor locked rotor current. HFCP's provide backup overload protection for fault current in excess of l
l motor locked rotor current.
l 2.2.3.1.2 Penetration Assembly Design: Since starter f
overloads are bypassed under accident conditions, I
oversized penetration conductors are utilized j
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to maintain containment integrity for I
fault currents in ranges less than the trip setting of the magnetic breaker and HFCP's.
The penetration assemblies will also withstand the continuous current capability of motor locked rotor, as well as the available range of fault current for the time duration required for the backup protection device to interrupt the circuit under a single failure condition.
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2.2.3.2 Circuits: Includes all containment safety-rela;ed MOV's larger than 3 horsepower. Starter overloads are also bypassed under accident conditions, however, in order to provide for practical penetration conductor sizing, two thermal-magnetic breakers in series are provided for overload protection. The breaker thermal trip setpoint is established in accordnace with the requirements of Branch Technical Position, EICSB-27.
2.2.3.2.1 Overload protection System: Thermal-magnetic breakers in series provide primary and backup overload protection.
The thermal-magnetic breakers provide primary and backup protection for all
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ranges of fault current.
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2.2.3.2.2 Penetration Assembly Design: Pene-tration conductors are of a suffic-ient size such that the penetration assembly will withstand the avail-able range of fault current for the time duration required for the back-up protective device to interrupt the circuit under a single failure con-dition.
2.2.4 480V MCC Loads - Special l
2.2.4.1 Circuits: The only loads included in this category are the pressurizer heaters.
2.2.4.2 Overload Protection System: MCC thermal-magnetic breaker serves as primary overload protection for all ranges of fault current. The 480V leati center feeder breaker to the pressurizer heater 480V MCC serves as.the backup overload. protection for all ranges of fault current.
2.2.4.3 Penetration Assembly Design: Penetration conductors are of a sufficient size such that the penetration assembly will withstand the available fault current for the time duration required for the backup 1
protective device to interrupt the circuit under a single failure condition.
3.0 Low Voltage Control l
3.1 Control Circuits by Source 1
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3.1.1 Circuits
Includes all non-Class IE and Class IE ac control fed from hCC 480/120V control transformer.
3.1.2 overload Protection: Two fuses in series in the secondary of the control transformer provides primary and backup protection.
3.1.3 Penetration Assembly Design: Penscration conductors are of a sufficient size suct that the penetration assembly will with-stand the available range of fault current for the time duration required for the backup protective device to interrupt the circuit under a single failure condition.
3.2 Control Circuits fed from Power Panels
3.2.1 Circuits
Includes all non-Class IE and Class IE 120V ac and 125V de control circuits, i.e.,
auxiliary controls, solenoids, etc.
These circuits are individually fused frem a fuse panel located in the control board. The fuse panel is fed from a power panel breaker or fuse.
3.2.2 Overload Protection System: Two circuit fuses in series, or a circuit fuse in series with a power panel breaker (fuse) provide primary and backup overload protection.
3.2.3 Penetration Assembly Design: Penetration conductors are of a sufficient size such that the penetration assunbly will with-stand the available range of fault current for the time duration required for the backup protection device to interrupt the circuit under a single failure condition.
f 4.0 Instrument Systems
4.1 Circuits
Includes all non-Class IE and Class IE instrument circuits.
l 4.2 Oterload Protection System: Each instrument loop is individually fused which provides primary overload protection. Backup protection is not
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provided due to the inherent low energy level associated with instrument systems.
4.3 Penetration Assembly Design: Penetration conductors are s' zed to carry the maximum available fault current that could occur under a failure of the individual instrument loop protective device.
5.0 Non-class IE power circuits penetrating the containment that are not required for plant operation will not be subject to the requirements of Position C.1 of Regulatory Guide 1.63.
Such loads are only used during startup or refueling, and their feeder breakers can be locked open or racked out at other times. Typical loads include containment lighting, welding circuits, polar crane, etc.
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6.0 Control Rod Drivers: Since the CRDM Power circuits are tripped (de-energized) under accident conditions through the reactor trip switchgear via the RPS, credit is taken here for one protective action. The normal protection provided for each CRD starter is considered to be the second, or backup action.
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" Physical Independence of Electrical Systems" -
(Revision 1. January 1975)_
The NRC considered the formal Hidland position unacceptable. A meeting was held with the NRC on October 14, 1976 and, in addition to the submittal of PSAR Amendment 32, the below position was subsequently developed. The amendment to Appendix 8A of the PSAR which details the methods for implementation of Regulatory Guide 1.75 was submitted for NRC staff review on March 25, 1977. The applicant is currently awaiting formal acceptance of Amendment 32.
The Regulatory Guide position developed i
subsequent to the October 14, 1976 meeting is as follows for equipment which is part of the balance of plant scope.
The requirements of Regulatory Guide 1.75 are met.
The following cable marking criteria is implemented as an alternative in complying with Position C.10 of the Regulat'ory Guide:
To facilitate initial verification that the installation is in conformance with the separation criteria, cables installed in Class IE raceways, except for those routed in conduit and duct banks, are marked at intervals not to exceed 15 feet throughout the cable length and at points of entry to and from enclosed areas (i.e., fire barriers, floors, walls, etc). Cables routed exclusively 1
in conduit or duct banks are marked at points of entry and exit l
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only.
For equipment in the NSS scope of supply, the NRC's request for additional information will be resolved upon the resolution of the CPCo and Toledo Edison joint _ proposal for testing of the reactor protection system.
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NRC DISTR'IBUTION ren N..T 50 DCCKET MATERIAL FROW cATscrocc w :NT Tor Mr. R. Boyd Consumers Power Co.
7-19-77 Jackson, Mich.
49201 C^Ta asceiveo S. H. Howeti 7-25-77 Jr.sT--s m CNoTemizso once iNeutacau Nuussa or copies asesivso Fea rciN AL EuscLAssipiao CC "
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