ML20052C714
| ML20052C714 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/04/1982 |
| From: | Eberly R, Knox J, Mauck J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20052C678 | List: |
| References | |
| NUDOCS 8205050425 | |
| Download: ML20052C714 (27) | |
Text
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t Uff!TED STATES OF AMERICA NUCLEAR REGULATORY C0f1 MISSION BEFORE THE AT0f11C SAFETY AND LICENSING BOARD In the Matter of
)
LONG ISLAND LIGHTING COMPANY Docket No. 50-322
)
(Shoreham Nuclear Power Station)
)
NRC STAFF TESTIMONY OF JOHN L. KN0X, RANDALL EBERLY AND JERRY L. MAUCK ON ELECTRICAL SEPARATION SC CONTENTION 31 AND S0C CONTENTION 19(g) 8205050425 820504 PDR ADOCK 0D000322 T
o 4
0UTLINE OF TESTIMONY The Staff's testimony in response to SC Contention 31 and SOC Contention 19(g) shows that, at present, the majority of the Shoreham design regarding physical independence of electrical cables and raceways meets Regulatory Guide 1.75 (Rev.1).
Thus, the " independence" requirement of GDC 17 and 21 and 10 C.F.R. Q 50.55a have been met. The limited number of exceptions have been evaluated by the Staff and the Staff has either imposed the requirements of Reg. Guide 1.75 (Rev.1),
required additional documentation from Applicant or has determined there is an insufficient basis to require additional design modifications.
With respect to GDC 3, the plant has been reviewed and found acceptable in accordance with the requirements of Appendix R to Part 10 C.F.R., Part 50.
Accordingly, the contentions in question are without merit.
l' V
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322
)
(Shoreham Nuclear Power Station)
)
NRC STAFF TESTIMONY OF JOHN L. KN0X, RANDALL EBERLY AND JERRY L. MAUCK ON SC CONTENTION 31 AND S0C CONTENTION 19(g)
Q.
Please state your respective names and positions with the NRC.
A.
My name is John L. Knox.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Electrical Engineer in the Power Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached hereto as Attachment 1.
My name is Jerry L. Mauck.
I am a Reactor Engineer (Electrical) with the Instrumentation and Control Systems Branch, Division of Systems Inteoration, Office of Nuclear Reactor Regulation. A copy of my professional qualification is attached hereto as Attachment 2.
My name is Randall Eberly.
I am a Staff Fire Protection Engineer with the Chemical Engineering Branch, Division of Engineering, i
Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
I have been in this position since February,1982.
Prior to that time, I was employed as a Fire Protection Engineer by the United States Coast Guard, Office of Merchant Marine Safety for approximately seven years. A copy of my professional qualification has been previously filed in this proceeding in connection with NRC Staff Testimony on SC Contention 17.
o s Q.
What is the purpose of your testimony?
A.
The purpose of this testimony is to respond to Suffolk County Contention 31 and Shoreham Opponents Coalition Contention 19(g). These contentions are identical except for their preambles which are:
SC 31-Suffolk County contends that 10 C.F.R.
Q 50.57 and 6 50.109 requirements have not been met because:
50C 19(g) - A major contributing factor in the TMI-2 accident was that operating plants were not required by the NRC Staff (Staff) to be in compliance with current regulatory practices (i.e.,
Regulatory Guides, Branch Technical Positions, and Standard Review Plans). The TMI-2 accident also demonstrated that the current regulatory practices, practices similar to those b:!ag applied by the Staff in their safety evalLation of Shoreham, were in a number of cases not suitably conservative to properly protect the health and safety of the public (i.e., hydrogen generation, radiation sheilding, source terms, and single failure criterion).
50C contends that the NRC Staff has not required LILC0 to incorporate measures to assure that Shoreham conforms with the standards or goals of safety criteria contained in recent regulatory l
guides. As a result, the Staff has not required that Shoreham structures, systems, and components be backfit as required by 10 C.F.R. 5 50.55a.
Q 50.57, and b 50.109 with regard to:
Regulatory Guide 1.75 - The design of the l
Shoreham electrical system fails to provide adequate physical independence of electrical cables and raceways as set forth in Revision 2 to Regulatory Guide 1.75 and therefore does not comply with 10 C.F.R. 550.55a and Part 50, Appendix A, Criteria 3, 17 and 21.
In addition, the minimum separation criteria for Shoreham stated in Section 3.12 of the FSAR have not been followed as noted in Inspection Report 50-322/79-07 dated August 21, 1979 and subsequent reports from the Office of
Inspection and Enforcement. Accordingly, each deficiency in separation for Shoreham electrical cables and raceways must be adequately demonstrated using one of the following options:
(i) Correct the deficiency by meeting the electrical equipment separation criteria set forth in Section 3.12 of the Shoreham Final Safety Analysis Report; (ii) Correct the deficiency by meeting Regulatory Guide 1.75, " Physical Independence of Electrical Systems," Revision 2 dated September 1978; (iii) Correct the deficiency by installing an acceptable barrier; or (iv) Justify the deficiency by performing a specific analysis for each cable or raceway where the minimum separation is not met to demonstrate that a failure will not propagate because of the insufficient separation.
Q.
In regard to the guidelines set forth in Revision 2 of Regulatory Guide 1.75, will the Commission require backfitting f." Shoreham?
A.
(Knox) Under 10 C.F.R. 9 50.109, the Commission may require the backfitting of a facility after a construction parmit has been issued, if it finds that such action will provide substantial, additional protection which is required for the public health and safety.
The Commission has found that backfitting to comply with Regulatory Guide 1.75, Revision 2, does not provide for substantial additional protection. This finding is inherently stated in the imple-mentation section of Regulatory Guide 1.75 which provides:
... this guide will be used by the NRC staff in evaluating all co'nstruction permit applications for which the issue date of the Safety Evaluation Report is February 1,1974 or after." The Shoreham CP-SER was issued February 20, 1970.
I L*
_4 Q.
What was the basis used by the Staff for evaluating the adequacy of physical independence of electrical cables and raceways at Shoreham and compliance with Criterion 17 of Appendix A to 10 C.F.R. 507 A.
(Knox) Criterion 17 of 10 C.F.R. Part 50 requires, in part, that the onsite electric power supplies and distribution systems shall have sufficient independence to perform their safety function assuming a single failure. The Staff had determined (as indicated in the Commission's Standard Review Plan, NUREG-0800) that conformance to the sp':cific guidelines of IEEE Standard 384-1974, as augmented by Regulatory Guide 1.75, Rev. 1 or 2 (which provide identical positions) provides a sufficient basis for acceptance of the above stated independence requirement of Criterion 17.
Section 3.12 of the Shoreham Final Safety Analysis Report presents the Applicant's separation criteria that has been followed to assure that sufficient independence of redundant instrumentation, control, and electrical equipment will be maintained. The basis used by the Staff for judging the acceptability of the Applicant's separation criteria was conformance to the specific guidelines of IEEE Standard 384-1974 as augmented by Regulatory Guide 1.75 (Revision 1). The Staff had determined (as indicated in the Commission's Standard Review Plan, NUREG-0800) that conformance to the specific guidelines of IEEE Standard 384-1974, as augmented by Regulatory Guide 1.75, provides a sufficient basis for acceptance of the above stated independence requirements of Criterion 17.
Q.
What was the basis used by the Staff for evaluating the adequacy c' physical indenpendence of electrical cables and raceways for
the Protection System at Shoreham and compliance with 10 C.F.R. 50.55 and Criterion 21 of Appendix A to 10 C.F.R. 50?
A.
(Mauck) Criterion 21 of 10 C.F.R. Part 50 require; in part that independence designed into the protection system shall be sufficient to assure that no single failure results in loss of the protective function and Section 50.55a, " Codes and Standards", of 10 C.F.R. Part 50,
" Licensing of Production adn Utilization Facilities", requires in paragraph (h) that protection systems meet the requirements set forth in the Institute of Electrical and Electronics Engineers " Criteria for Nuclear Power Plant Protection Systems", (IEEE 279).
Section 4.6 of IEEE Std. 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations", (also designated ANSE N42.7-1972) requires, in part, that channels that provide signals for the same protective function be independent and physically separated. The staff had determined (as indicated in the Commission's Standard Review Plan, NUREG-0800) that conformance to the specific guidelines of IEEE Standard 384-1974, as augmented by Regulatory Guide 1.75, Rev. 1, provides c. sufficient basis for acceptance of the above stated independence requirements of Criterion 21 and 10 C.F.R. 50.55a.
Q.
Has the Shoreham physical separation design for cables and raceways been implemented in a manner that meets the requirements of GDC 17, 21 and 10 C.F.R. 5 50.55a?
A.
(Knox and Mauck) Yes, with the possible exception of wiring in the NSSS cabinets as noted below.
During the review of the Shoreham physical separation design, the Staff requested from the Applicant a comparison of Shoreham design requirements to those in IEEE Standard l
384-1974 as augmented by Regulatory Guide 1.75 (Revision 1).
In addition, where less stringent criteria are proposed, the Staff requested, from the Applicant, a discussion of the reasons for concluding that the less stringent criteria met the independence requirement of GDC 17, 21 and 10 C.F.R. 5 50.55a.
The requested comparison and discussions have been documented in the Shoreham FSAR (Applicant responses to questions 223.12 Part 1 and 223.67) (Attachment 3).
Exceptions, to the guidelines of IEEE Standard 384-1974 as augmented by Regulatory Guide 1.72 (Revision 1), have been evaluated as follows:
a.
(Knox) Connection of non-Class 1E loads to Class 1E busses and separation between Class 1E and non-Class 1E cables located in control panels have been evaluated in sections 8.4.4 and 8.4.10 of the Shoreham Safety Evaluation Report (NUREG-0420).
I have reviewed the evaluations and concur that that the design meets Staff requirements and is acceptable.
b.
(Knox) Minimum separation between redundant Class 1E c.ibles at Shoreham has been specified to be 1 foot horizontal and 3 feet vertical in the cable spreading area (relav room) and 3 feet horizontal and 5 feet vertical in general plant areas. Where the minimum separation cannot be maintained, both redundant cables are run in enclosed raceways separated by one inch or a barrier is installed
between redundant cables. This separation is the same as the guidelines of IEEE Standard 384-1974 as augmented by Regulatory Guide 1.75, Rev.1, except that vertical separation is measured in a different manner.
The separation at Shoreham is measured from cable tray top to top versus from the top of the lower tray to the bottom of the higher tray as recommended by IEEE Standard 384-1974.
Thus, the cables as a minimum could be separated by 2 feet 8 inches vertically versus 3 feet in the cable spreading area and 4 feet 8 inches versus 5 feet in general plant areas. The difference of 4 inches in vertical separation will not appreciably affect the independence of redundant Class 1E cables since separation guidelines of IEEE 384-1974 are based on open top trays. Trays at Shoreham are covered (solid tops) and redundant trays are never in the same vertical stack. The separation at Shoreham, thus, a
exceeds the guidelines of IEEE Standard 384 and is acceptable.
c.
(Knox) Minimum separation between non-Class 1E and Class 1E cables at Shoreham has been specified to be 1 inch horizontal and 1 foot vertical with barriers or cable tray covers between cables.
Even though the
-8 minimum separation guidelines of IEEE Standard 384-1974 (5 feet vertical and 3 feet horizontal for general plant areas and 3 feet vertical and 1 foot horizontal for the cable spreading area) have not been specified for the Shoreham design, the tray covers or barriers specified in addition to separation of 1 inch horizontal and 1 foot vertical meets the guidelines of IEEE Standard 384-1974 and is acceptah 4.
For cables with a separation greater than 1 inch horizontal and 1 foot vertical but less than 3 feet horizontal and 5 feet vertical recommended by IEEE Standard 384-1974, the Shoreham separation criteria has been interpreted to mean that the barrier or tray covers specified by Shoreham separation criteria will be installed between cables. This interpretation meets the guidelines of IEEE Standard 384 and will be imposed as a condition to the Shoreham operating license.
l d.
(Mauck) Physical separation has not been i
provided between non-Class IE and Class 1E cables at Shoreham inside the NSSS cabinets.
The Staff will l
l require that the Applicant provide information to l
justify that physical separation inside the NSSS I
l cabinets is not required to prevent failures in the I
_g.
non-Class IE cables from adversely affecting the safety equipment and circuits.
(Knox-Mauck)
It was previously concluded in the Shoreham SER and now we reaffirm that the physical independence of electrical cables at Shoreham have been evaluated in accordance with the guidelines of IEEE Standard 384-1974 as augmented by Regulatory Guide 1.75 (revision 1),
meets the independence requirement of General Design Criterion 17 and 21 Appendix A to 10 C.F.R. Part 50, and 10 C.F.R. 50.55a and is acceptable, with the possible exception of the cables in the NSSS cabinets.
As previously indicated the Applicant is to provide additional information on the cables inside the NSSS cabinets.
Q.
10 C.F.R. 50.57 requires, in part, that each operating license will include appropriate prnvisions with respect to any uncompleted items of construction and such limitations or conditions as are required to assure that operation during the period of the completion of such items will not endanger public health and safety.
In regard to deficiencies identified in the separation of electrical cables at Shoreham, will they be corrected before fuel is loaded at the Shoreham plant?
A.
(Knox) Yes. The Staff has required each deficiency to be corrected using one of four options presented in the contentions. The options either meet or exceed the separation criteria specified in the FSAR or the guidelines of Regulatory Guide 1.75.
If option 4 is used, the specific analysis will have to be evaluated by the Staff and the results will be reported in a supplement to the Shoreham Safety Evaluation Report.
Q.
Does the design and location of the Shoreham electrical system components meet GDC 3 requiremonts?
A.
(Eberly) Ye s, on May 23, 1980, the Commission issued a Memorandum and Order (CLI-80 71) which indicated that a proposed fire protection rule was to be published and stated that:
"The combination of the guidance contained in Appendix A to Branch Technical Position, ASB 9.5-1 and the requiremetns set forth in this proposed rule define the essential elements for an acceptable fire protection program at nuclear power plants docketed for construction permit review prior to July 1,1976, for demonstration of compliance with General Design Criteria 3 of Appendix A to 10 C.F.R. 50."
On October 27, 1980, the Commission approved a rule concerning fire protection. The rule and its Appendix R were developed to establish the minimum acceptable fire protection requirements necessary to resolve certain areas of concern in contest between the Staff and licensees of plants operating prior to January 1,1979. The physical independence requirements for the purpose of conforming to GDC 3 are contained in Section III.G of Appendix R.
The Shoreham station was reviewed to the guidelines of Appendix A to Branch Technical Position ASB 9.5-1, the requirements of Appendix R to 10 C.F.R. 50, and GDC 3 of Appendix A to 10 C.F.R., Part 50. Our evaluation concerning electrical components and cables and safe shutdown capability is set forth in Sections 9.5.5.2, 9.5.5.3, 9.5.5.5 and 9.5.6 of Stipplement 1 to the SER (NUREG-0420).
In sum, the Staff determined that the Applicant's programs were acceptable.
O ATTACHMENT 1 G
John L. Knox Professional Qualifications Power Systems Branch Division of, Systems Integration.
Office of Nuclear Reactor Regulation I am a Senior Electrical Engineer (Reactor Systems) in the Power Systems Branch in the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission.
In this position I perform technical reviews, analyses, and evaluations of reactor plant features pursuant to the construction and operatfon of reactors.
Education In 1962. I received an Associates of Arts degree in Electrical Power System Technology from Montgomery College.
In 1971. I received a Bachelor of Science degree in Electronic Systems Engineering from the University of Maryland. Since 1974 I have taken a number of courses on PWR and BWR system operatien, equipment qualification, and reactor safety.
Experiente, From 1971-1974, I worked for Potomac Electric Power Company in Washington, D. C.
I was assigned to the underground power Transmission Engineering Group and my duties included relocation and restoration of underground power and transmission cables due to the subway construction project.
(Priorto this, I spent four years in the Air Force working on the F4 aircraft electronic weapons control systems.)
From 1974 to the present. I have worked for the Nuclear Regulatory Comission involved in the technical review of electrical systems (onsite and offsite power, instrumentation and control). Through 1976, I was a member of the g
Electrical Instrumentation and Control Systems Branch. This branch was split in January 1977 into an I&C branch and a power branch. Since this split, I have bten a member of the Power Systems Branch. My present responsibilities include review and evaluation of onsite and offsite electric power.systsas.
l
ATTACHMENT 2 s
JERRY L. MAUCK DIVISION OF SYSTEMS INTEGRATION, U.S. NUCLEAR REGULATORY COMMISSION PROFESSIONAL QUALIFICATIONS I have been with the U.S. Nuclear Regulatory Commission since September 1980.
I am a Reactor Engineer (Instrumentation) in the Instrumentation and Control Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
i I serve as a reviewer in the area of nuclear power plant instrumentation and control systems in performing and coordinating reviews and evaluations of those portions of the applications for Contruction Permits and Operating Licenses and submittals regarding proposed modifications in licensed nuclear power plants for 1
which the branch has responsibility to assure public health and safety and pro-tection of the environment.
I serve as project leader and coordinator of other i
reviewers for the resolution of highly complex technical issues and licensing problems and pmvide technical assistance and authoritative advice in the areas relating to the safety aspects of reactor plant instrumentation and control sys-tems and components.
t I received a Bachelor of Science degree in Electrical Engineering from Virginia Tech University in 1967. Additional graduate studies were subsequently performed l
at George Washington University where I received a Masters of Science degree in Engineering Administration. Other educational background includes: CFC Instru-mentation School,1968; Interdata Computer School,1972; Hewlett Packard Computer School,1978; Boiling Water Reactor Technology - NRC spon:;ored - 1980; Boiling Water Reactor Simulator School - NRC sponsored - 1981; Pressurized Water Reactor l
Simulator Technology - NRC sponsored - 1982.
n From }967 to 1980 I was employed by the Naval Ship Research and Developme$t Cen-ter (David W. Taylor Model Basin) as an Electronic Engineer with such duties as specifying, processing, and operating highly sophisticated instrumentation sys-tems for use during naval ship trials (conventional and nuclear powered).
'M e
4 f
O O
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1 ATTACHMENT 3 SNPS-1 FSAR Request 223.12 (3.12.3)
(8.~4.1.) :
Section 3.12.3 of the FSAR sets forth separation criteria for electrical systems and equipment which in various cases seems to satisfy equivalent requirements and recommendations as those in the IEEE Std 384-1974 and Regulatory Guide 1.75, Revision 1.
In this regard provide the following:
1.
Compare your separation design requirements to those in the IEEE Std 384-1974 as augmented by Regulatory Guide 1.75, Revision 1 and identify those requirements hnd aspects of your design which are not in accordance with either the standard or the Regulatory Guide.
Where less stringent criteria are proposed, discuss the reasons for concluding that the less strirgent criteria are adequate.
s i
223-12 Revisicn 3 - Noverber 1976
SNPS-1 FSAR
Response
1.
As stated in Appendix 3B-1.75, the electrical systems do not fully comply with Regulatory Guide 1.75, Revision 1, and IEEE Std 384-1974 due to the advanced sta.ge of design of the plant at the. time of issuance of this guide and the IEEE Standard.
- However, within the limitations imposed by' the systems equipment and plant design, all effort was
- made, to the maximum extent practicable, to comply with the intent of Regulatory Guide 1.75 and IEEE 384-1.974.
The comparison of the SNPS-1 separation design to the requirements of IEEE Std 384-1974 and Regulatory Guide 1.75 is as follows:
a.
Associated Circuits and Isolation Devices Although not specifically addressed in the FSAR, the SNPS-1 design utilizes the concept of isolation devices and associated circuits. '
l l
The degree of compliance with IEEE Std 384-19.74, Sections 4.5 and 4.6 and Regulatory Guide 1.75 Positions C.1 and C.7 is discussed below:
(i)
Power Circuits 4,160 V System i
The 4,160 V
system circuits comply with both the IEE_E Standard and the Regulatory Guide noted above.
p The non-class IE feeders to the control rod drive water pump motors connected to Class IE buses remain with and follow the same rules as the class IE circuits of the respective separation division and are uniquely marked.
Moreover, these motors are tripped on a loss of coolant accident.
223-12a Revision 3 - Novenicer 1976 T
O SNPS-1 FSAR 480 V a-c and 125 V. d-c Systems Non-Class IE 480 V a-c and 125 V d-c loads connect-ed to the Class IE power supplies are grouped to reduce the number of points at which non-Class IE loads are connected'to Class IE buses.
These non-Class IE load groups are supplied through two circuit breakers physically separated from each other and connected in series.
Tables 223.12-1 and 223.12-2 show the groupings of the 480 V a-c and i
125 V d-c loads respectively.
The two breakers in series (also RPS motor generator set and inverters for the uninterruptible t
power supply bu,ses) although not fully complying with Regulatory Guide 1.75, Position C.1,* are.
j considered acceptable isolation devices.
The -
l cables up to the second breaker (also RPS motor 1
generator starter and input breaker of the inverter j
for the uninterruptible power supply) are treated i
in the same way as safety-related cables.
The trip setting of feeder breakers to the buses to which non-Class IE load groups are connected are coordinated with the Class IE feeder.
Two breakers'
- i in series ensure that for any fault on the l'
secondary side of the second. breaker, the feeder will be tripped should one of the breakers fail to 0T' open.
i (ii) Control and Instrument Circuits l
Wherever.
practicable, non-Class IE circuits'which cannot be separated from, Class IE circuits have f
been assigned the same color code as the Class IE circuits and wired accordingly.
One example is the control rod drive pump' motor.
The 4,160 V breaker for this motor is part of a
safety related bus.
Therefore, both the main power feed and the control:
circuitry are color coded.
Current transformer and potential ' transformer circuits on 4,160 V Class IE switchgear which have to be wired to devices on Class IE portions of the main control board, have been assigned the Class IE color code and wired accordingly.
The exception to the above occurs,for the 4,160 V supply breaker e
' circuits' which are connected to the NSS a,nd RSS y
y transformer differential relays.
The differential I
relay-is non-Class IE, although the design does not l
, permit separation due to the nature of the circuit I
(itself..
t t
/[223-12b kvision 3 - Noverber 1976 I
~.
- T.
y SNPS-1 FSAR A
Where the above is not practicable, every effort has been made to separate the Class IE and non-Class IE wiring.
Examples of these follow.
For normal and reserve station service transformer feeders to 4,160 V emergency buses, an additional trip coil has been added with a separate non-,
Class IE control power supply for such trip signals.
This trip coil, its auxiliary switches, and its wiring, are physically separated to the maximum degree possible within the limitations of the breaker design.
" Block close" signals are multiplied through a multiplier
- relay, and the contacts of the multiplier relay are in the breaker closing
- circuits, so that contact to coil separation can be achieved.
In general where interface occurs,nonhiassIE circuits are separated from Class IE circuits by the _use of imaltiplier relays and/or contact to contact separation.
All possible motor feeder ansneters have 0-1 milliamp de acvements.
A transducer is provided at the switchgear to provide electrical separation.
Whereva.r possible Class IE motor-operated valves,
-ce air-operated valves, motor-operated
- dampers, and air-operated dampers whose limit switches or position switches interface with both Class,IE and non-Class IE
- circuits, have metal barriers or separate metal boxes between the Class IE and' non-Class IE contacts for separation purposes.
The isolation devices which separate the Shoreham Startrec system from the reactor safety syctems are manutactured by Validyne.
These isolators provide electrical - to electrical isolation and are identical to those
'that have been Class IE qualified for. use at the '4immer and LaSalle power stations.
~
b.
BOP Pattels Internal Wiring Separation Redundant Class IE circuits are separated by barriers or b in. physical separation.
Electrical separation ot e
Division _ I or Division II output logic, signals interfacing with Division III equipment actuation centrol circuits is achieved by butfer. relays mounted in such a manner that the relay coil wiring is separated from the relay contacts by means of a metal barrier.
' ^
223-12c Revision 24 - December 1971
=
SNPS-1 FSAR e
Wherever possible non-class IE circuits are not run in y
the same wire bundles or wireways used by any group. of the redundant Class IE cables.
To maintain separation between Class IE and non-Class IE wiring on the same control board, devices are enclosed in can type boxes where necessary and their wiring is run in metal conduits to separate terminal blocks.
c.
NSSS Panels Internal Wiring Separation i
Separation of a pair of redundant control devices that must be located in close proximity is achieved by totally enclosing the wiring to one of the devices within 'a fire-resistant material.
In a
few specific cases the criterion for separation within the metallic enclosure, (cabinet or panel) is relaxed.
This relaxation of the criterion is allowable since an analysis for the.particular system shows that the complete failure of the equipment with2.n the enclosure will not compromise the system's-redundant counterpart or the redundant power supply (refer to the single f ailure analysis in GE Report NEDO-10139, " Compliance of Protection Systems to Industry Criteria-General Electric BWR Nuclear Steam Supply System").
The requirements for physical separation are documented on each system elementary diagram (for
- example, 791E420TF hote 13 which is used to denote those switch-contacts and lights that shall be enclosed in a metal container).
All applicable elementaries may be found in Section-5.1 of " Safety Related Schematics and Drawings" submitted rebruary 10, 1976.-
d.
Cables and Raceways The comparison of cable tray separa' tion in nonhazardous areas between SNPS-1 design and that of IEEE Std 384 and Regulatory Guide 1.75 is given in Table 223.12-3.
The cable trays are generally arranged either by voltage ~
class level with non-Class IE and Class IE cable trays interlacted or arranged in groups of non-Class IE cable trays at the top and Class IE cable trays at the bottom.
Cable trays are 9.enerally run with the highest voltage cable at the top.
523-12d Revision 24 - December 1981
G SNPS-1 FSAR l
l TABLE 223.12-1 480 V a-c NON-CIASS IE LOAD GROUPS SUPPLIED FROM CLASS IE BUSES 3 Hon-Class IE Connected to Isolation Imad Group Class it Bus Device' Remarks 1.
Division I Power Source Turbine Building MCC Emergency Switchgear Two breakers Tripped on Loch with 1R24-MCC111B Room MCC 1R24*MCC1115 in series loss of offsite power Reactog Building MCC Reactor Building MCC
'No breakers Tripped on LOCA 1R24-MCC111A 1R24*MCC1113 in series Emergency Lighting 480 V Emergency Swgr.
Two breakers Tripped on LOCA with Distribution Panel Bus 111 in series loss of offsite power 1140-PNL-AC2 UPS Inverter (for Emergency Switchgear Two breakers Second breakers in vital nonsafety bus)
Room MCC 1R24*MCC1115 in series and*UPS rectifier and regulator i
1R36-1NV-01 section of UPS 24 V Battery A Chargers Emergency Switchgear Two breakers Tripped on LOCA 1R41-BC-A2-182 Room MCC 1R24*MCC1115 in series and charger i
RPS Motor / Generator Set Emergency Switchgear One breaker and Room M'X: 1R24 *Mcc1115 M/G set with motor starter and generator output breaker 2.
Division II Power S'urce o
d' Turbine Building MCC !
Emergency switchgear Two breakers in Tripped on LOCA with 1R24-MCC112B Room MCC 1R24*MCC1125 series loss of offsite power Reactor Building MCC Reactor Building MCC Two breakers in Tripped on LOCA 1R24-MCC112A 1R24*MCC1123
- rcries, 24 V Battery B Chargers Emergency Switchgear
'Two breakers in Tripped on IACA 1R24-BC-B2-182 Room MCC 1R24*McC1125 series & charger RPS Motor / Generator Set Emergency Switchgear One breaker and Room MCC 1R24*MCC1125 M/G set with motor
- starter and genera-tor output breaker e
t
(
1 of 2 Revision 17.- September 1979
SNPS-1 FSAR TABLE 223.12-1 (COfff *D)
Non-Class IE Connected to Isolation Load Group Class IE Bus Device Remarks 3.
Division III Power Source Turbine Building MCC 480 V Dnergency Swgr.
'two breakers in Tripped on LOCA with 1R24-MCC113A Bus 113 series loss of offaite power Essergency Lighting Dis-480 V Emerge'ncy Swgr.
Two breakers in' Tripped on LOCA with tr tion Panels Bus 113 series loss of offsite power 1K40 PNL-AC1 and 1TSI-PNL-AC2 8
UPS Inverter (for computer)
Emergency Switchgear
'two breakers in Second breakers in 1R36-1NV-02 Roosa MCC 1R24*MCC1133 series and UPS rectifier and regulator section of UPS l
i i
d3
- T
,2.
{,,f,
t t
)
1 2 of 2 Revision 17 - September 1979
)
SNPS-1 FSAR Table 223.12-2 125 V D-C NON-CLASS IE LOAD GROUPS SUPPLIED FROM CLASS IE BUSES Non-Class IE Connected to Isolation
_I_oad Group Class IE Bus Device Remarks
- 1. Division I Power Source Turbine Build-125 v d-c Switch-Two breakers one common ing and Relay gear in series feed for Room Distri-1R42*SWG-A1 both panels bution Panels 1R24-PNL-A3 6 1R24-PNL-A4 UPS Inverter 125 v d-c Switch-Two breakers Second break-(for vital gear in series er in inver-nonsafety 1R42*SWG-A1, ter section bus) of UPS 1R36-INV-01
- 2. Division II Power Source Turbine Build-125 v d-c Switch-Two breakers One common ing and Re-gear in series feed for lay Room Dis-1R42*SWG-B1
~,
both panels tribution Panels 1R42-PNL-B3 6 1R42-PNL-B4
- 3. Division III Power Source Emergency 125 v d-c Switch-Two breakers Switchgear gecr.
in series Room Distri-1R42*SWG-C1 bution Panel 1R42-PNL-C2 Turbine Build-125 v d-c Switch-Two breakers ing Distribu-gear in series tion Panel 1R42*SWG-C1 1R42-PNL-C3-
~
UPS Inverter 125 v d-c Switch-Two brdakers Second break-(for Comput-gear in series er in invert-er) 1R42*SWG-C1 er section 1R36-INV-02 of UPS 1 of ~1 Revision 3 - November 1976 1
M
Y SNPS-1 FSAR l
TABLE 223.12-3 CABLE TRAY SE?ARATION IN. NONHAZARDOUS AREAS IEEE Std. 384 and Redundant Class IE Trays Reg. Guide. 1.75 SNPS-1 Cable Spreading Area Redundant trays never in same vertical 3 ftt83 vertical stack Horizontal 1 ft 1 1t I
Tray Covers none required solid (a>
General Plant Areas Vertical 5 fttan Same as above Borizontal 3 ft 3 ft Tray Covers none regaired solidcas Don-Class 1E S Class 1E Trays Cable Spreading Area Vertical 3 fttaa 1 f tt * *.
Borizontal 1 ft 1 in.
Tray Cowbra none require.1 solidE83 General Plant Area vertical 5 ftta3 1 fttaata3 Horizontal 3' f t 1 in.
Tray Covers None solidta3*
Chble Specification no requirement except for associated circuits same as Class 1R Fire Protection none required Auto CO, in Cable Spread. Area, Diesel 4
Generator Roomas, Emergency and Normal Switchgear Roomas MS ta3 Vertical, separation for SNPS-1 is measured from the bottosa of the top tray to the
'bottous of the side rail of the bottosa tray instead of the bottoms of the top tray to the top of the side rail of the bottom tray as stated in IEEE Std. 384.
ta3In certain isolated cases, 9 in. separation is used in the reactor building due to
.. limitation of available space.
883 Tray covers for H and L trays are solid side ventilated 3 covers of K C, and X trays are
-- q solid nonventilated.
i k
a 1 of 1 Revision 16 - April 1979
SNPS-1 FSAR 1
Request 223.67 (3.12.3) -
O Provide the following information pertaining to the response to request item 223.12:
1.
Identify those non'-Class IE control and instrument circuits which are not practicable or possible to separate from Class IE circuits.
Describe the analyses and tests that have been performed to demonstrate that Class IE circuits will not be degraded below an accep. table level.
2.
With regard to BOP panels internal wiring separation, identify those non-Class IE circuit wirings which are not possible to segregate from Class IE wire bundles or wireways.
Describe the analyses and tests that have been performed to demonstrate that Class IE circuits will not be degraded below an acceptable level.
3.
Confirm that the 'non-Class IE cables running in the same underground duct banks as the. Class IE cables follow the same rules as Class IE circuits or respective separation division.
Response
1.
A further review of the BOP instrument and control circuits confirms the following:
a.
All non-Class IE control circuits are separated from Class IE circuits by the use of coil-to-contact and/or contact-to-contact separation.
b.
All Class IE motor-operated valves, air mperated valves, motor-operated dampers,.and air-operated' dampers whose limit switches or position switches interface with both Class IE and non-Class IE circuits have metal barriers or separate metal boxes between the Class IE and non-Class IE contacts for separation purposes.
c.
Any non-Class IE load (instrument or control) which is not separated from a Class IE source has bOen u signed the same color code as the Class IE -source and wired accordingly.
The non-Class IE loads are seismically analyzed and/or tested so as to demonstrate that the Class IE source is not degraded.
Similarly, the non-e-
Class IE device is mounted in or on a Seismic Category I panel, instrument rack, or process
- line, and scinde analysis and/or tests are being ' performed to ensure structural integrity.
j d.
Radiat. ion monitoring instrument circuits utilize optical Se isolation for separation between Class IE monitors and the non-Class IE computer.
)
223-67 Revision 9 - December 1977 M
SNPS-1 FSAR
' O;N-e.
In reference to Item 1a, some wire bundles internal to equipment are not separated due to physical limitations and/or equipment design.
These bundles are:
(i) 4,160 volt Emergency Switchgear, (ii) 480 Volt Emergency Switchgear, (iii) Diesel Generator Control Panels, (iv)
AC and DC Motor Control Centers (MCCs),
(v)
HVAC Filter Train 1T46*FLT-0/A, B and j
1X61*FLT-02A, B, and (vi)
Hydrogen Recombiner Control Cabinets A and B. -
i Non-Class IE wiring outside 'of the equipment above is run in separate raceways from Class IE.
The majority of circuits here wire bundles are not separated between Class IE and non-Class IE wiring involves inputs to th'e station annunciator and computer 1
systems.
Both these systems involve low level circuits, failure (open, short) of which will not damage that cable or adjacent Class IE cables (maximum current of 10 ma for the annunciator or computer).
Fire propagation along the non-Class IE cable is not a
- hazard, since all wire used within Class IE equipment,
,l whether used for Class IE or non-Class IE functions, is the same and is qualified in accordance with Class IE requirements.
The balance of circuits involved other than those listed in the response to Reque.st 223.12 are:
(1)
Space Heater Wiring in 4,160 V Switchgear breaker cubicles to the Service Water Pumps (2)
Space Heater Wiring in 4,160 V Switchgear breaker cubicles to the RHR Pumps (3)
Space Heater Wiring in 4,160 V Switchgear breaker I
cubicles to the Core Spray Pumps p
(4)
Space Heater Wiring in 4,16 0 V Switchg, ear breaker
)
cubicles to the CRD Pumps (5)
Space Heater Wiring in DC MCCS for RCIC and HPCI
)
Pumps (6)
' Fire Protection Detector Circuit for Filter Trains 1
1 223-67a Revision 9 - December 1977 1-
SNPS-1 FSAR (7)
Contacts to Reactor Water Cleanup System isolation s
logic (Class IE) from a non-Class IE MCC Most non-Class IE control and instrumentation circuits in i
NSSS control panels are associated with annunciators and computer inputs.
There are no sources of energy within NSSS control room panels of sufficient magnitude to cause failures to both redundant safety system divisions from a non-Class IE circuit analys,i and/or fault.
Therefore, a
circuit by-circuit-assure safe,sty system testing is not deemed necessary to operation.
The Shoreham NSSS control room panels have been designed to be in full conformance with IEEE 279-1971 thus assuring the separation of redundant Class IE safety system circuits.-
Whenever new design changes are incorporated, the requirements of Regulatory Guide 1.75 (including separation of Class IE and non-Class IE circuits) are considered and incorporated to the maximum extent possible.,
2.
Reference Item 1e above.
3.
Non-Class IE cables installed in underground duct banks are
.;)
designed,' installed, and tested to the-same criteria as the safety related cables with the following exceptions:
a.
Class IE cables are sized more consezkratively than non-l Class IE cables.
- However, cable derating and cable protection criteria are the same for both classes of cable.
I b.
Non-Class IE cable pulling tansion is monitored on a sample basis.
Pulling tension is monitored for all Class IE cables installed by machine in underground ducts.
The maximum allowable pulling tension is the i
I same for both Class IE and non Class IE cables.
W i
22 ~, -67 b Revision 9.- December 1977 l
..m.
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