ML20052E573

Testimony of Br Mccaffrey Re Suffolk County Contention 31 & Shoreham Opponents Coalition Contention 19(g) on Electrical Separation.Electrical Cables & Raceways Between Equipment & Panels Adequately Separated

ML20052E573
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/04/1982
From:	Mccaffrey B LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20052E543	List: ML20052E541 ML20052E551 ML20052E557 ML20052E566 ML20052E573 ML20052E577 ML20052E581 ML20052E587
References
ISSUANCES-OL, NUDOCS 8205110239
Download: ML20052E573 (19)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j Before the Atomic Safety ano Licensing boaro l

(

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

TESTIMONY OF BRIAN R. McCAFFREY l FOR THE LONG ISLAND LIGHTING COMPANY ON SUFFOLK COUNTY CONTENTION 31 AND SHOREHAM OPPONENTS COALITION

~ CONTENTION 19(g) -- ELECTRICAL SEPARATION i

l l Purpose l

l This testimony establishes that electrical caoles and i

' raceways between equipment ano panels are adequately separateo at,Shoreham in compliance with the applicable portions of Regulatory Guide 1.75 Revision 2, by use of cable trays, enclosed raceways, and in some areas separate rooms with three-hour fire-rated walls. Automatic CO2 floooing systems, smoke

[' detectors, and a cable separa' tion study further assure safe shutdown capability at Shoreham.

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l 8205110239 820504 l PDR ADOCK 05000322 l T PDR t _ _-

A program for dealing with deviations f rom the stated sep-aration criteria contained in FSAR 3.12 has been developed.

Appenximately 85% of these deviations are for conduit-to-conduit su,6aration, and result because the Shoreham criteria exceeds the IEEE-384 standards for separation. Therefore, the conduit-to-conduit installation deviations will be resolved by 4

simply accepting those installations as-is, since the installed condition exceeds the IEEE requirements. For the few remaining deviations, compliance will be achieveo by implementing one of four options suggested by the NRC to resolve these items.

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UNITED STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION defore the Atomic Safety ano Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1) )

TESTIMONY OF BRIAN R. McCAFFREY FOR THE LONG ISLAND LIGHTING COMPANY ON SUFFOLK COUNTY CONTENTION 31 AND SHOREHAM OPPONENTS COALITION CONTENTION 19(g) -- ELECTRICAL SEPARATION

1. Q. Please state your name and business address.

A. My name is Brian R. McCatfrey; my business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York.

t 2. Q. What is your position with LILCO?

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A. I am Regulatory Supervisor for L1LCO, responsible for managing the Nuclear Regulation Civision of the Nuclear Operations Support Department. In addition, I am responsible for managing and cooroinating the' Company's efforts in the ASLB licensing proceedings.

3. Q. Please state your professional qualifications.

A. The attached resume summarizes my professional quall-fications. My tami11arity with the electrical separa-tion issue stems f rom my involvement in li .nsing ano engineering matters concerning Shoreham, both as a Regulatory Supervisor ano in my previous position as Manager of Project Engineering for the Shoreham Station. I have worked on Shoreham for nine years.

4. Q. Are you familiar with Suffolk County Contention al and Shoreham Opponents Coalition Contention 19(g)?

A. Yes. They are substantively the same.

5. Q. What issues are presentea in those contentions?

A. The intervenors contend that LILCO has not adequately separated electrical cables and raceways at Shoreham in ccapliance with Regulatory Guide 1.75 Revision 2 t and Section 3.12 of the FSAR.

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6. Q. How is separation ot cables achieved at Shoreham?

A. At Shoreham, cables between equipment ano panels are

. run in cable raceways, that is, in conduits, duct ano cable trays with short sections (less than 4 feet) not supported. Conouits are round galvanized rigid steel

enclosures, normally 10 feet long, with threaded ends ana couplings. A duct is a round PVC enclosure encased in concrete and usually run underground between buildings. Cable trays are a means of suppor-ting cables. The trays consist of channel sides with rungs between them similar to a ladaer and are called open laoder-type cable trays. Some of these cable trays have been specified with solid bottoms to enclose the bottoms ana the sides of the cables.

The major electrical aivisions at Shoreham are denoted by the colors red, blue,'and orange. These divisions are backea up by the respective red, blue, and orange diesel generators. Throughout the plant, the cable raceways are arrangea to provide the-greatest separa-tion possible, with special attention to cable trays since they afford less protection than conduits. In plant areas where separate rooms with three-hour fire-rateo walls have been provided for redundant equipment, safety-related raceways are separated ~to their corresponding rooms. When a redundant cable tray of necessity passes through these rooms, it is totally enclosed to provide greater protection.

In the Relay Room at elevation 44 '-0" or the Control Building, which is also used as the cable spreaaing area for cables entering the Control Room, separate rooms could not be providea. Within the relay room, the Class lE red cable trays ano the Class 16 blue cable trays are laid out between each other, similar to interlocking fingers, such that the rec and blue trays are never above one another and have a separa-tion of at least 3 feet horizontally instead of the 1 foot required by IEEE Standard 364-1974 (IEEE-384).

The Class lE orange cable trays within the relay room are totally enclosea by the use of solid tray covers, top and bottom.

In the Reactor Building , safety-related equipment including cable racewajs have been segregateo with approximately halt of the builuing containing Class lE red trays and the other half containing Class 1E blue trays. Cables for the Class lE orange equipment are installed within enclosed raceways throughout the Reactor Building. This af fords greater protection to

, these cables that are redundant to both the red and blue cables.

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7. Q. Does this cable-separation arrangement comply with Regulatory Guide 1.75 Revision 2?

A. Revised FSAR Table 223.12-3, appearing on page 12 of my testimony, provides a comparison of the Shoreham cable tray separation criter.ia with IEEE-384 ana Regulatory Guide 1.75 Revision 2. (Revision 1 or 1.75 is substantively the same as Revision 2, with tne exception of references to certain fire-protection measures.) As stated in Revision 2, "IEEE Standard 384-1974 . .

. provides an adequate basis for comply-ing with IEEE Standard 179-1971 and the Commission's General Design Criteria 3, 17 and 21 ot Appendix A to 10 CFR Part 50 with respect to the physical indepen-dence of the circuits." Although in my opinion Revision 1 and Revision 2 are not applicable to Shoreham, separation of electrical cables and raceways between equipment and panels at Shoreham meets the Revision 2 and 1EEE-384 criteria, as can be seen from the table on page 12 or my testimony. Adaltionally, while the IEEE-384 standard allows for reduction of spacing by use of enclosed trays and conduits, Shoreham conservatively appliea the same separation requirements to conduits as to trays, thereby exceeding the Regulatory Guide requirements.

8. Q. Has the NRC reviewea the separation criteria for Shoreham?

A. Yes. The NRC Staff in Section 7.6.6 or the Safety Evaluation Report documented the review of the separa-tion criteria to assure the physical indepencence of redundant instrumentation, control ana electrical equipment. The Statt concluded that the Shoreham design is satisfactory.

9. Q. Does L1LCO rely solely upon separation or electrical cables to assure safe shutdown capability at Shoreham?

A. No. Automatic CO 2 fl o ing systems, actuatea by either products of combustion or temperature, are installed to protect the cable spreading and relay room, all three emergency switchgear rooms, the three safety-related battery rooms ano the three emergency diesel generator rooms. To provide for early warning in the event of a fire, smoke detectors are located in these rooms in addition to temperature detectors.

Both the smoke and temperature detectors alarm in the control room to alert the operators. An automatically activated halon fire suppression system is also installed in the Remote Shutdown Panel Room, ano the entire Reactor Builaing is protected by a fire

detection system. All cable is fire retaroant ana will therefore not reaally support or propagate a fire.

Additionally, LILCO has completed a two year Cable Separation Study (Separation Study) and submitted it to the NRC on December 31, 1980 (SNRC-536).

10. C. Is such a Cable Separation Study required by Regulatory Guide 1.75 Revision 2?

A. No.

11. C. Please describe the Separation Study.

A. This conservative evaluation separated the Reactor Building primary containment into 60* sectors and the secondary containment into 45" sectors, as shown in Figures 4.1.1-1 and 4.1.2-1 on pages 13 and 14 of my testimony. (Tnese zones are significant when comparea to the general 5 ' vertical ano 3' horizontal separa-tion criteria of IEEE-334.) The conservative assump-tion in the analysis is that an " exposure fire" de-stroys all cable and instrumentation containea in or passing through the assumed zone, with the zones extending from floor to ceiling. The analysis demon-strated that, even assuming loss ot otfsite power,

loss of any zone will not prevent safe snutdown of Shoreham. As part of this analysis, the zones were rotated 30* for the primary containment and 22 1/2*

fdr the secondary containment, ano the evaluation repeated.

12. G. Did LILCO always comply with FSAR 3.12 in installing cables?

A. No. The Nuclear Regulatory Commission's Inspection and Enforcement Report 50-322/79-07, dateo August 21, 1979, noted instances where the stateo separation crl-teria contained in FSAR 3.12 were not achieved due to field conoitions. Where the separation nas not been achieved as required by the hork Specification, an Engineering and Design Coordination Report (E&DCR) is issued. The site practice for the Work Specification has been ano continues to be to achieve the committea-to separation wherever possible.

, 13. C. What does LILCO plan to do about the deviations from i

FSAR 3.12?

A. LILCO has discussed the possible solutions with the NRC. The Commission, in Mr. R. L. Teoesko's letter of August 31, 1981 to Mr. M. S. Pollock, suggested four options:

1. correct the deficiency oy meeting tne electrical equipment separation criteria set forth in Section 3.12 of the Shoreham Final Safety Analysis Report;

2. correct the deficiency by meeting Regulatory Guide 1.75, " Physical Independence of Electric Systems,"

Revision 2 dated September, 1978;

3. correct the deficiency by installing an acceptable barrier; or

4. justify the deficiency by performing a specific analysis for each cable or race-way where the minimum separation is not met to demonstrdte that a failure will not propagate because or the insufficient separation.

14. Q. How has L1LCO responded to these suggestions?

A. LlLCO replieo to the NRC letter in $NRC-670, dated February 18, 1982, advising the NRC that we have implemented a program applying one of the options to each deviation as documented on appropriate E&DCR's or Non-Conformance and Disposition Reports (N&D's). As noted in this letter, options 3 and 4 have been clar-ified in accordance with LILCO's understandings from previous technical meetings with the NRC staff on this matter. NRC respondeo on March 15, 1962 in a letter from Mr. A. Schwencer to M. S. Pollok. The Statf encourageo LILCO to strive to use either option 1, 2 or 3 since option 4 would require a substantial sys-tems review by the NRC.

15. C. What are the separation deviations present at Shoreham?

A. 85,% of the separation deviations are for conduit to conduit, 13% for conduit to tray, ano 2% miscella-neous.

16. Q. How will these deviations be resolveo?

A. Shoreham's criteria per the Work Specification for separation between conduits exceeds IEbb-384.

Therefore, the conduit-to-conduit installations will in general be accepted as-is, since the installed con-dition exceeds the IEEE requirements. For conduit to tray, compliance will be achieved by covering the exposed tray in the area where the required separation is not achievable. Approximately 2% of the deviations will be resolved by reworking raceways to conrorm to.

the IEEE-384 requirements.

17. Q. Mr. McCaftrey, please summarize your testimony on l

l electrical separation at Shoreham.

A. The electrical cables and raceways between equipment and panels are adequately separated at Shoreham in compliance with the applicable portions of Regulatory Guide 1.75 Revision 2. In adoition, automatic CO2 l

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! flooding systems, smoke detectors, and the Cable Separation Study further assure safe shutdown capabil-ity at Snoreham.

Deviations from the stated separation criteria con-tained in FSAR 3.12 and the associated Work i

! Specification are being resolved using one of tour options developed by the NRC.

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Table 223.12-3 (Revised)

Cable Tray Separation in Nonhazardous Areas .

IEE Std. 384-74 and Redundant Class IE Trays Reg. Guide 1.75 (Rev, 1) SNPS-1 -

Cable Spreading Area Vertical 3 ft (1) 3 ft (1)(3)

Horizontal 1 ft (1) I ft (1)(4)

Tray Covers none required (1) none required (1)

General Plant Areas Vertical 5 ft (1) 5 ft (1)(3)

Horizontal 3 ft (1) 3 ft (1)

Tray Covers Non required (1) None required (1)

Non-Class IE & Class IE Trays Cable Spreading Area Vertical 3 ft (1) 3 ft (1)(2)

Horizontal 1 ft (1) I ft (1)(4)

Tray Covers none required (1) none required (1)

General Plant Area y Vertical 5 ft (1) 5 ft (1)(2)

Horizontal 3 ft (2) 3 ft (1)

Tray Covero none required (1) none required (1)

Cable Specification no requirement except for associated circuits Same as Class IE Fire Protection none required Auto CO2 in Cable Spread. Area, Diesel Generator Rooms, Emergency and Normal Switch-gear Rooms.

Notes: 1) IEEE std. 384-1974 as imposed by Reg Guide 1.75 allows reduction of spacing requirement to 1 inch vertically pr. horizontal.ly where solid tray covers or solid treys tie utilized.

I's Vertical sepiretion for 3NPS-1 is measured frira the bottom of the top tray to the bctccm cf :he side ra.'.1 of the bottom traj instead of the bottom of the top t ray te the top of the t is'.e rail of cne bottom tray as stated in IEEE std. 384.

3) dedundant trays are never in tc.e sema vertical stack.

4) Mastly'three feet.

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PROFESSIONAL QUALIFICATIONS Brian R. McCaffrey Regulatory Supervisor Long Island Lighting Company My name is Brian R. McCaffrey. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York. I have been employed by Long Island Lighting Company (LILCO) since 1973, and have been' Regulatory Supervisor for LILCO since November 1981, responsible for managing the Nucrear Regulation Division of the Nuclear Operations Support Department. In addition, 1 am responsible for managing ano coordinating the Company's efforts in the ASLB Licensing Proceedings. The Nuclear Regulation Division will support the operation of the 6horeham Station in cooroination of all NRC licensing activities, the Nuclear Review Board and the manage-ment of the Indepenaent Safety Engineering Group.

I graduated from the University of Notre Dame in 1967 with a Bachelor of Science Degree in Aerospace Engineering. I re-ceiveo a Master of Science Degree in Aerospace Engineering in 1972 from the Pennsylvania State University ano a Master of Science Degree in Nuclear Engineering in 1976 from the Polytechnic Institute of New York. I completeo a General Electric BWR Design Orientation Course in 1978.

My professional experience began with my employment with Grumman Aerospace Corporation in 1966. My primary responsi-bilities were in the areas or aircraft aerodynamics and flight test stability and control.

I joined LILCO in 1973. I have held the positions or Associate Engineer and Engineer in the Power Engineering Department (1973-1975), where I was involved with plant engineerins for both rossil ano nuclear power stations. I then becante Senior Engineer in the Power Engineering Department (1975-19"i7), witn responsibilities as Project Coordinator for gas turbine installations and Lead Mechanical Engineer for nuclear pro-jects; Senior Licensing Engineer for Shoreham Nuclear Project (1977-197o), with responsibilit-y for the licensing activities leading to an Operating License; and Project Engineer for Snoreham (1979-1980), with responsibilities that includeo directing Project Engineering and the Arcnitect Engineer in engineering and procurement for Shoreham.

I was assigned in 1980 as Assistant Project Manager for Engineering and Licensing (in July 1981, retitled Manager--Project Engineering) for Shoreham. In that capacity I was responsible for the overall engineering ano licensing ot the Shoreham Station. My organization directed ano approvea the engineering efforts of the Architect Engineer ano Nuclear Steam Supplier, and was responsible for directing the activi-ties leading to an Operating License f rom the NRC. I became Regulatory Supervisor in November, 1961.

. - . . i I am a Registered Professional Engineer in the State or New York. In addition, I am a member of the American Society or i Mechanical Engineers and the Long Islsnd Section of the American Nuclear Society.

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