ML20086T187
| ML20086T187 | |
| Person / Time | |
|---|---|
| Site: | 05000605 |
| Issue date: | 09/27/1991 |
| From: | Strong R GENERAL ELECTRIC CO. |
| To: | Poslusny C NRC |
| Shared Package | |
| ML20086S777 | List: |
| References | |
| NUDOCS 9201060166 | |
| Download: ML20086T187 (100) | |
Text
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- t ADVANCED BOILING WATER REACTOR PROGRAM ELECTRICAL SYSTEMS & EQUIPMENT DESIGN September. 27, 1991 cc (w/o att.): M.A. Ross J.N. Fox J.E. Maxwell
- TO: Mr. C. Posiusny NRC FROM:-R.W. Strong - GE
SUBJECT:
ABWR SSAR Chapter 8 Status / Clonure Plan for Items Discussed at the
' NRC/GE Meetings Held in San Jose 9/16 through 9/18, 1991;
Dear Chet,
As a promised follow up' to'our meetings held in San Jose on September 1618, 7
1991; attached is a copy of our status report and closure action plan for the
-issues we-discussed.
We believe we have accurately reflected the resolutions and/or actions required to resolve each issue.
However, we need NRC review for concurrence or comments to assure we are on a commca understanding with the staff as to what is
-required.
The " STATUS / CLOSURE PLAN" column on the right is new,-and.is our requested focus for your' attention.
The other columns are basically the sams as discussed:at the meeting, except that a few tf the "GE RESPONSE" items have
- already been updated as.part of our ongoing work on the resolutions.
- However,
.such changes;are clearly identified in the status column.
-Note particularly-Item 3 of Number 4.000, which concerns the revisions of the.
IEEE standards. We have identified the disconnects between those revisions
-specified in the Licensing Review Basis (and referenced in Chapter 8 of the SSAR),:and those endorsed by Regulatory Guides. We have-~also.estimat,ed the manpower needed-to make a comparison study.
Your response by' Friday, October 4, would be greatly appreciated.
Bcs egards Ro t
. Stron
/C 765 CE.NE ABWR Program San Jose, CA-95125 9201060166 911k'23 PDR ADOCK 05000605 A
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Page No.
1 09/2F/91
.00 CH81SSUE
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. REPORT FORM CLOSPtNS TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER CE RESPONSE STATUS / CLOSURE PLAN NUMBER DSER SECTION NRC CONCERN 1.000 8.2 8.2 CFFSITE POWER SYSTEM Items 1-3: (See the response to Question 1-3. As of the 9/16-18/91 435.63.)
meetings, the NRC had not yet reviewed the response to 435.63 Based on information presented on figure 8.3-1 of the ABWR (stinitted February 20, 1991).
S$AR, it appears that the offsite power system consists of the fottowing three sources:
Items 4-7: A new section 8.1.2.1.1, and This is an ARC action ites.
assouated figures 8.1-1 and 8.1-2, have been l
1.
A back feed from the transmission network through the added which address separation in accordance 4-7. GE to clarify separation of main transformer, bus duct, and two unit Auxiliary with these items (see attached mark-tps).
transformers ' & 9 in Figure 8.1-1, ard to show floor transformers to the Class 1E distribution system input separation of turbine building.
terminals. To initiate this back feed, the main generator eust be disconnected from this source by a generator Item 8: The second paragraphs of sections 8.1.3.1.1.1 and 8.3.1.1.1 have been revised in
- 8. Resolved.
breaker; accordance with section 8.3.4.9.
In addition, 2.
An offsite line from the transmission network through sections (1), (3) and (4) of 8.3.1.1.7 have
- 9. Resolved.
the reserve Auxiliary transformer to the Class 1E been clarified to attow feed from either distribution system input terminals; and offsite source during normat plant operation.
- 10. Resolved based on tu= ping this with Sdquestion 7 of item 31 (8.3.7) in the DSER.
3.
A contustion turbine generator to the Class 1E distribution system irput terminals.
Item 9: GE questions the validity of this criteria. GDC 17 requires two of fsite sources.
- 11. Resolved.
Section 8.2.3 indicates that these circuits, for the most tet, any plants (including the ABWR) with more part, are within the ABWR design scope; however, sections than two divisions could not meet such
- 12. GE needs to provide the 3.1.2.2.8.2.2, 8.2.1 and C 2.2 indicate that these circuits criteria, because tt'e toss of one of the current toad analysis, coupled are, in total, out of th.. WR Standard Plant scope; thus, offsite sources must affect more than one with an interface requirement f or description and analysis demonstrating coeptience of the division. Yet less reliable plant designs the final design, to show the offsite circuits to regulatory requirements has not been having only two divisions would seet the ru.rcers referenced in the provided in the ABWR SSAR. To initiate our review of the criteria. We suggest this item be deleted response (i.e., on the drawing =)
of fsite system, adfitional information is regaired for the since it is redundant to SER Issue 8.2.1.
are adequate. (See PS8-1 and $2P Page SA-14 for reference following items ard/or positions.
materiet.)
1.
The inconsistency between sections 3.1.2.2.3.2.2, 8.2.1, Item 10: There are no restrictions placed on 8.2.2, and 8.2.3 of the AsWR SSAR as to what part of the testing of the offsite systems during normal
- 13. WRC action ites t- *eview offsite system is within ABWR scope, plant operation. Interf ace 8.3.4.9 provides 435.63 (same as Items 1-3,
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Page No.
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" 10RM CLOSPLN8 TO PRINT
'-DSER ConCERNSi.
+-,3fATUS FOR CMAFTER 8 ELECTRIC POWER
-i 01MBER - DSER SECTION NRC CONCERN,
GE RESPONSE
' STATUS / CLOSURE PLAN Y
for continuous feed from both the preferred and. above).
- 2. lThe description and analysis of thefoffsite power.
afternate power sources. Therefore, the need system's preferred offsite power' supplies from the,
for testing should be minimmt. However,
. utility-ABWR ' interfaces to the Class 1E distributim system. testing procedares and frequency of testing for input terminals idiich' is within the ASWR Standard plant the offsite circuits is determined by the scope.
utiiity/appticant.
- 3. : Interface requirements for the effatte circuits from the utility-AgWR Interfaces out u the utility grid system which Litem 11: The emplicit definition was added to l'
is outside tne AgWR Standard plant scope.=
$dmection 8.3.1.1.1, as requested (see l
attached mark-up).
~f 4.
Description and analysis of criteria'retating to-physical and electrical seperation between the normat and i
alternate preferred offsite circuits and between the '
Item 12: The vot?=ge and power requirements I
preferred offsite and the onsite circuits including are given on Figure 8.3-1, with the utility instrumentation end control circuits. Onsite circuits
, rid interface defined in section 8.2.3, as l
include Class 1E power sely circuits and the Class 1E modified per the response to 435.5. What else U
distribution system circuits to the loads, is rent b/ the term " capacity and capability"?
I 4
5.
Interface criteria relating to physical and electrical i
1 separation between the normat and atternate preferred Item 13: (see Section 8.2.2 added in response offsite circuits and betwem offsite and onsite circuits.
to Question 435.63.)
{
inctuding instrumentation and centroL c1rcuits.
+
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- 6. ' Physical lay cut drawings which shows the physical '
separation of the offsite circuits and separation between
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onsite and nffsite circuits. This shall include the i
instrumentation and control circuits associated with each offsite circuit.
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- 7. ;The physical and electrical separation between the circuits associated with the cad u tion turbine generstor and other offsite circuits including instrumentation er.d controt circuits.~-
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9 Pege No.
3 09/27/91
.DO CM8 ISSUE
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.tEPGtT FORM CLCSPLt8 to Pttui DSER CDNCERsS/PESPONSES/ STATUS FOR CMAPTER S ELECT *it Poutt GE FESPONSE STATUS / CLOSUPE PLAs l
NL.MBER DSE2 SECTION WEC CONCERN I
8.
Inconsistencies between resporvae to cp.sestion 435.48 (or section 8.3.6.9) ord section 8.3.1.1.1 as to the nonnet offsite powee feeds to Class 1E division I, II, ard III.
Simiterty, sectiens 8.1.2.1 and 8.1.3.1.1.1 are l
inconsistent.
9.
No s'r p tfailure ground feutt or other aoerration in preferred circuit trtween the plent suitchyard one off.
and the C6.ss 1E distribution system iryut terininets shall cause toss of of ftite pon to or challenge in any way more then one Ctess 1E distribution system.
- 10. Identification, anstysis, and justification for each circuit er component part of the offsite system d ich will not be tested d.aring normal plant operation.
- 11. Explicit definition of normal plant operation which states that it seens att modes #f plant operation intudiN shutdown, refueling, ord stort ss).
- 12. Capecity and capability of each of fsite circuit to sagety comeetc<' toads.
- 13. Definition of criterie egoticable to of fsite systems similar to Table 8.1-1.
2.000 8.2.1 8.2.1 Indeperdence between of fsite and 01 site Systems.
The statem quoteo from sectier 8.3.2.2.1 1-3. sesolv=d per P statemmt refers to the individ.aol Ctess 15 125 VDC clarificaticr* in 8.3.2.2..
Tha following criteria, specified in section 8.3.2.2.1 for betteries neich control the Class tE switchgeer the Askt design, iepties that a single f atture of one 125 feeding each Class 1E 6.WV w/C tus. Each VDC system may jeoperdire end thus cause loss of of fsite ord divisionet bus is feed by its ews divisional onsite power to one safety civision but wilt not jeerdize breekers which are contratted by tte 125 vCC or cause loss of of f site preferred AC power to any other bettery of that same division. Therefore, it
l 1-e C W no.
L
- 09/2F/91 l
.D0 CMSIS3uE
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j
. REPORT FORM CLOSPLWS TO Pefut.
I DSik ConCERWS/WESPOBSES/ STATUS FOR CMAPtER 8 ELECTRIC POWER l
' anseER DSER SECTION NRC CONCERN GE RESPunSE Status / CLOSURE PLAs safety divisions.
- is correct in that no divisionet bettery j
felture can effect the feeders of the other "The intikely toes of one 15 VDC systes does not jeoperdire divisions.
. the stopty of prefeered and steney AC power to the Ctess 1E
{
buses of the other toad groies."
The statement gaoted in 8.3.2.2.1 has been clarified as foltous:
This criterie, with respect to the DC systems, meets the staf f position that no singte f ailure, groind fault, or
- The idikely loss of one 15 VDC system does other aberretion in one offsite preferred circuit between not jeopordize the Ctess 1E feed simply to the 3
l the plant switchyerd and the Ctess 1E distribution systee Ctess 1E buses of the other toed groies."
irput terminets shett cause toss of of fsite power to or chattense in any may more then one Ctess 1E distributter, j
system, division, or toad group om is, therefore, j
ecceptable. Bouever,'the offsite system being proposed for j
the ASWR does not meet this criterie. For example:
1 s.
Feiture d the single arqn transformer staplying two of i
tu safety et dsions will cause toss of offsite power to more than t=w.efety division.
j b Feiture of any one of. the four teilt musiliary
[
transforimers mitt couss toes of offsite power to more there 1'
one safety division.
4
) -
1 To initiate caer review in this eree, additional informathn is required for the following items.
j
- 1. ' The entent Ctess 1E DC power is used for control and
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. protection of the offsite circuits from the switchyard to j
the terminet cornection on the Ctssa 1E system.
2.
Descriptive information or anetysis demonstrating
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compliance of the ASWR design to the above stated criterie.
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09/N/91
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.90 cm8 ISSUE'
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.NEPORT FORN CLOSPLn8 TO PRItT f
t DSER ConCEttBS/ RESPONSES /STATLIS FOR CHAPTER 8 ELECTRIC "0ER J
j j
. InsteER ' DSER SECTION MRC CDuCEen '
E REspowSE STAftrs / CLOSumE Puus p
I 3.
specific identifiestion and documentation ef the above f
and other eeceptiers to this criterie in the Asut tsar with 4
justification.
1 2.100 8.2.2 (new) 8.2.2 Protective systeem for the Reactor' Internet pumps sem issue per sept to.ts 4
(euestion 435.4) seetings. The mRC pointed out
[
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incorsistencies between the
[
f section 15.3.1.1.1 of Amendment to to the ssAR states that retlebility readners in sessannee f
since four buses of a tased to se.gssdy power to the ten reactor 435.4 and section 15.3.1.1.1
{
internal pumps (Rips), the esorst single feiture con only which need to be corrected.
cause three RIPS to trip.' Further doun in this samme section e statesment is ende that the probability of any additionet
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RIP trips is low (tess than 10**(-6) per yeer). Therefore, I
this event (i.e., the sisestteneous trip of eere then three
)
RIPS) is etessified as a tietting feutt.
h t
In oroer to establish that the proembility of any additionet i
RIP trips is less then 10**(-6), additionet information or
]
enetysis is required free E in a SSAR emuerr$aent to address I
each of the following izens.
- I (a) Probability onetysis dich demonstrates that a fault en l
the offsite ci r sit that occurs anyiAere between and f
l including the of fsite switchyerd and the reactor intermt f
j pumps will not cause loss of more'then three reactor i
i internet pumps (RIPS).
I
' (b) Identify each couponent port of the power simply to the I
reactor internet pumpe and/or protective systees that is l
espected to fation to esaure the assumptions used in the j
probability onetysis of ites (e) above.
(
)
(c) Probability anetysis eAlch desuenstrates that the j
casubined probability of att events (including those
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b
Page Wo.
6 09/27/91
.00 Cm8 Issue
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. REPORT. FORM CLOSPLIES 70 PRINT DSER C0hCER45/ RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER IRMBER DSER SECTION WRC CoaCERE GE RESPOWsE Status / CLO$URE PLAN described in itas (e) above) is less than 10**(-6) for trip of more then three SIPS.
3.000 8.3.1 8.3 omSITE POWER SYSTEMS Response 435.26 has been modifled as fotIous:
- 1. Resetwed.
8.3.1 Compliance with Generet Design Criteria Itee (1)(b) of
- 2. Resolved.
section 8.3.1.2.2 iruficates that the Class 1E Constant
' Att conformance statements in the analysis voltage Constant Frequency (CVCF) power simply is in sections of Ch wter 8 have been modified to
- 3. Resotwed.
cogliance with Generet Design Criterie (GDC) 2, 4,17, erui state futt etsotience without the applicability 18 in port or in *ote, as applicable. Response to geestion cav=at (see attacheet).
- 4. Resotwed.
435.26 provides eterification that there are no noncomp8. lances, but some portions of the CDC's are not There are no rewaww with the CDCs.
- 5. Resotwed.
aplicable at this tevet (for esemple, the statement in CDC The 'as applicabte' statements mere interused 17 about two physicatty 1414 circuits from the ordy so dif ferentiate between those portions of
- 6. Resolved.
transmission networft). It is wteer as to det parts of the GDr.s we interpreted to be applicable to the these CDC's ycu consider not applicable to the CVCF power plant se a whcte, rather then to individJet
- 7. Resotwed.
sagsplies. Also it is uncteer es to ey two g*ysicatty systems or
- as. neuever, it is better independent circuits from the transmission networt are not to delete such statements if they are.onstrued applicable to the CVCF power semplies. In order to clarify en mean any deyv. of non-conformance.*
these and other related items, additional inforention is regsired for the fottowing issues.
With regard to the CVCF power essedles, they 1.
Identification of each port of GDC 2, 4,
'.7, and 18 ore ultimately fed from their respective 6.9tv which is ret considered applicable to the CVCF power divisional buses (see Figures 8.3-1, 8.3-3 and stopties and justification for each port that is considered 8.3-6).
Eoch 6.9KV divisionai bus is not applicable.
connectobte to two offsite sources (prefered and alternate prefered) and two onsite sources 2.
Clarification es to iAy the CDC 17 requirement for two (EDG and CTG).
- i. 4.-. A.t power sources is not a pticabte to the CVCF power steptles.
The above modification closes att iteams exept 3.
Clarification for each non applicabt e iterie shown in 86 and #7 which are addressed es foitows:
tabte 8.1-1.
Pege no.
T 09/ F/91
.00 CN81SSUE
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. REPORT f0RM CLOSPLh8 TO PRIuT DSER CONCERWS/REGONSES/ STATUS FOR CMAPTER 8 ELECTRIC PO(R NUMBER DSER SECTION mRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN
.p 4.
Inconsistencies within Tabte 8.1-1 and between Table item 4: $4section 8.1.3.1.2 arvi Tabte 8.1-1 8.1-1 and section 8.1.3.1.2 as to amticable criteria.
veve been audified for consistency. (See i+tached aurit-sp) 5.
Identification with justification for each part of the i
criteria listed in section 5.1.3.1.2 that is cor siderev' not a plicable to some part of the electrical system.
Item 7: the secorid sentence in $4section 1.2.1.1.2(11) has been clarified as tottows:
F 6.
Identification with justification for each part of the design of.he Instrtsmentation arts Control system that is "For Class TE systems er components (i.e. IEEE considered to meet the s4 stance and intent of (versus
?79 amties), singte f at tures of either active l
coactience with) IEEE 279,10 CFR 50 Amendia A, Generet or passive electrical components...*
Design Criteria 3, 17, 21, 22, and wRC Regulatory Guides 1.75 (IEEE 384) and 1.53 (IEEE 379). (
Reference:
section 8.3.1.4.2.1) 7.
Clarification of the systems or components to iMeh IEEE-279 apply (reference: item (11) of section 1.2.1.1.2).
3.100 8.3.1.1 8.3.1.1 Co mtience with criteria 2 and &
Tha second sentence of tne third paragraph in sesolved perusing est review of SSAR sr.ction 8.1.3.1.1.1 tissue gJoted tat changes at end of 13.2.9 and Chapter 8 of t5e ABWt SSAR contains the following statements paragraph (211 tas been undified per the the rme insert at the end of in relation to the compilance of electrical system design to fottowing:
5.4.7.3.3 (mark-w provided at the requirements of criterion 2, Design Bases for Protection 9/16-18/91 s e tings).
Against Naturat Phenomena, and criterion 4, Envirarsmentet "Redmdant ports of the system are strysicatty and Missites Design seses, of Appendia A to " CFR Part 50.
seperated arti independent to the eatent that in It amears that each statement can be incorrectly any design basis event with any resulti.no toss interpreted to snean that protection need only be provided cf equipment and single failure, suf ficient for two of the three (or four) independent safety related remaining safety systems will be evaltable to j
electrical divisions.
ef fect a safe plant shutdown for att attowable modes of plant operation."
(1?
- ?n some instances spatial separation is provided st.as i ut no single event may disable more than one of the Also, many of the paragraphs gJoted have been redJnuant divisions or prevent safe shuttbun of the plant.
modified or deleted because spatial separatier*
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Electrical equipment and wiring for the Clasr 1E systems by distance stone (i.e., without barriers), is M
Page No..
8 09/2F/91-
.D0 CNSISSUE
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. REPORT FORM CLOSPLn8 TO Palmi DSER ComCEReS/ RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC ConCEtt GE RESPORSE STATUS / CLOSUSE PUel ndlich ere segregated 'nto separate divisions are wporated not attowed without justification. Att erees so that no desiyt beels event is capable of disatting any within the plant containing safety-related ES* totet fimetion." (ref: section 8.3.1.1.5.13-egangment or cables are seperated ty three-hour fire rated barriers teless anetyred and (2)
"Re&ndent parts of the system are g*ysicatty justified in 94.5.
separated to the estent titet e single credible event...cannot cause loss of power to redJndent load groups." (ref: section 8.1.3.1.1.1)
(3)
"Where spetial separation carmot be maintained in hazardous erees (e.g., potentist missile arees), physical isonation between electricst ecpsipment of dif ferent div sions is achieved ty use of a 6-inch miniman thickness 8
. reinforced concrete berrier." (ref: section 8.3.1.4.1)
(4)
" Class TE electric equipmeit and wiring is segregated into seperate divisions so that no single credible event is capat le of disabling eriough esysipment to hinder reactor shutdonc, removat of decay heet from the core, or isolation of the contairment in the event of an accident." fref:
section 8.3.1.4.1.1)
(5)
- Equignment arrangement and/or protective barriers are provided such t%et no locatty generated force or missile can destroy any redJndant RPS, NS$$, ECCS, cc ESF fimettons. In eddition, arrangement and/or seperation berriers are provided to ensure that such disturbances do not af fect both MPCF and RCIC systems." (ref: section 8.3.1.4.1.13 (6)
- Conteirament penetretions will ti so erranged 'that no design basis eventcan disable catding in more than one division." (ref: section 8.3.1.4.2.3.2.(T)
(7)
"The protection system and ESF controt logic, end
Page No.
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. REPORT FCetM CLOSPLK8 TO PRINT j
DSER CDNERNS/ RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POWER
- NtJtBER DSER SECTION NRC CONCERN CE RESPONSE STATUS / CLOSURE PUus i
instrument penets/ rocks shall be located in a safety ctess structure in which there are no potentist sources of missiles or pipe bree6s that could jeopardize redtndent
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cabinets and raceways.* (ref: section 8.3.1.6.2.2.3)
(8)
"In any compartment containing en operating crane..there sust be o minious horizwitet separation of 20 feet or e 6 inch thick reindorced concrete wett between trays containing cables from different divisions." (ref:
section 8.3.1.4.2.2.2(3))
(9)
"In rooms or coupertments having heavy rotating unchinery...or in rooms contelning high-pressure feed water piping or high pressure steen lines...minlaun seperation of 20 feet or a 6-inch thick reinforced concrete watt is required between trays containing cables of dif ferent divisions.= (ref: section 8.3.1.4.2.2.2(1))
Based on a review of the above statements. It espears that berriers between redtndent safety divisions (versus barriers from the ef fects of a credible event such as a tecetty generated missile) is th? design basis for electricot systers meeting the protection requirements of criterie 2 and 4 of Amendia A to 10 CFR Port $0. The design basis for protection of safety systems is not clear. It is not eteer that following any design basis event with any resulting loss of equipment and single failure, Mtf ficient remaining safety systems will be eveitable to evfect a safe plant I
shutdcnnn for ett attowebte modes of plant operation.
4.000 8.3.2.1 8.3.2 PMTSICAL INDEPENDERM ttees 1 & 2: The tent of sections
- 1. aesolved.
a 8.3.1.4.2.3.1(6)&<T) and the response to 8.3.2.1 Conduits To open Treys osestion 435.35 (section 20.3) have been
- 2. nesotv d.
modified in accordance with the ettsched.
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-Page ro.
10 09/ N/91
.DO CMSISSUE
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. REPORT FORM CLOSPLN8 TO FRINT DSER CONCERNS /RESPCWSES/ STATUS FOR CMAPTER 8 ELECTRIC POWER NUMBER DSER SECTION WRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN Section 8.3.1.4.2.3.1 and response to a.sestion 435.35
- 3. This item has twen expanded to i
indicate that gfrysical separation, for concisits containing include att IEEE standart!s used j
scram solenoid grotp circuit wiring, will be by a miniansa Item 3: The SRP regsires that Regulatory Guide in Chapter 8.
Thic major issue separation disterce of one inch from either met::t enctosed 1.75 be acMressed, yet that guide specificatty is that the AswR is designed to receways or non-enclosed receways. The one inch of erdorses IEEE 384-1974. We assumed the acet later standards than those seperation between a conduit and enctosed raceways comties augentations of the guide woutJ appty equelty which are endorsed tg the reg with Regulatory Guide 1.75 separation guidelines and is to IEEE 384-1981 as mett, though some section guices. GE's action is to rewsew therefore acceptable. The one inch of separation between a rubers mittin the IEEE doctanent were changed Tables 8.1-1 (page 8.1-6) and l
conduit and non-enclosed raceways, however, does not cosipty in the newer version. To clarify the amarent 1.8-21 (page 1.8-62), identify
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with separatiot) guidelines of Regulatory Guide 1.75.
The contradiction, we have acMed this asseption att of the discomects, and staff is therefore concerned that the proposed one inch of statement to response 435.32 (see attached).
estiaaste the ball parit work separation sury ret provide suf ficient indegr -lence between IEEE 384-1931 is identified as the correct effor* involved in assessing retiJndant systeam and/or protection to safet, _ystans in version for the ABWR certification, as earlier vs. tater standeros. The accordance with the requirements of criterion 17 of Amendes indicated in response 435.33 ard Tabte 1.5 mRC needs to discuss this with A to 10 CTR Part 50. To resotwe this concern, additionat (see SSAR page 1.8-62 (Amerdamt 12)].
their m ~ 4 and detemine an infonnation is required for the following items, action plan for detemining that Tables 1.8-21 and 8.1-1 have been reviewad to later stardards are esset or acre 1.
Identification with justification for the erw inch of determine the disconnects between the versions stringent to ese tier standards.
separation.
of IEEE standards referenced in the SSAR (as required by the Licensing Review Basis (GE PORTION CLOSURE: The above 2.
The contradiction between response to questicri 435.35 Doctsnent), verses those versions endorsed by information has tw.n accered to 1
(or item 6 of section 8.3.1.4.2.3.1) and response to regulatory guides. The results are as fottows:
the response.)
question 435.33 (or section 5.3.1.2.1) with regard to allowable separation lyxen core 14t.and non enclosed CN.8 NRC R.C.
- 4. Resolved (ttsoed into item 3).
raceways. Response 435.33 cm wibits Ey reference to IEEE 384 IEEE R.G.
CATE DA!E white response 435.35 specif %#th sitows one inch of
--- ---- -.-- ~~
- 5. Resotwed pending the addition separation. (Separettori by one inch between enctosed and non 308* 1.32 1974 19SO
- et a reference to 9.5.1.0 placed enclosed raceways is a known area of non-compliance with the 31T 1.63 1953 1983 at the end of the first paragraph guidellrv.s of Regulatory Guide 1.75 which is allowed ty the 33C 1.118 1977 te'7 in $ 4 ;ection 8.3.1.1.5.1 tpege ABWR design. This non compliance should be justified within 354* 1.75 1974 1951 8.3-3).
This ties SECY-89-013 the ABWR SSAR. It should not be considered as an interface 387* 1.9 1977 1984 with the 3-hour fire barrier recuirement to be resolved bw others 4. indicated in section 450* 1.129 1975 1987 requireneet.
8.3.4.5).
484* 1.128 1975 1987
I
'Page N.
11
),
,09/27/91.
.D0 Cn81SSUE
+
i 1
l
. REPORT FO W M OSPLN6 TO Pflui
{
t DSER CONCEnuS/RESpouSES/ STATUS F(R CMAPTER 8 ELECTRIC POE4 i
l NLMBER. DSER SECTion NRC CouGM GE RESPONSE STATUS / CLOSURE PLAN 3.
The contradiction betiseen response to gaestiori 435.33
- Denotes date disconnect l
and 435.32 in the tr9 eof IEEE Standard 384-1981 versus
'384-1974.
GE had streedy perforund a congserison study for l -.
2EEE 384-1974 verses IEEE.384-1961. seced on I.
4 Estent of une cf IEEE Standerd 384-1981 in the desiyt of that task, it is estiented 12 to 16 man-hours I
j.
Asia.
per document pair are needed to aske similar j'
studies. A conservative estimate for ett five
. 5.
sessirements relating to seperation conteined in tetter disconnect pairs is three man-iseeks.
{.
Itee 4: As empteined in Iteur 3 abowe, arid in j.
response 435.33, IEEE 384-1961 is the j
{.-
certification staruterd, but is assismed to be augmented by Reguietory Guide 1.75. There are no limitations on the entent of use of this sterusard in the Aghst Standard Plant Desiys. In y
f act, the 3-hour berriers separating designated i
fire arees/ divisions emceeds the criteele of #G 1
Iteur 5: SECT-d9-013 requires that i
... designers ef standard plants...must demonstrate that safe shutdoun of their designs can be achieved, assisming that ett egrismurnt in g
any one fire aree hos been rendered inoperable i
by fire and that reentry to the fire aree for q
repeirs and for operator actiers is not possible."
i This regsirement necessitated 3-hour fire berrier protectices be prended to the asetts separating redundant divisionet erees. Such berriers thus defined the fire aree boinder6es.
4 i
.. _ ~
_ - ~., _ _... - -. _ -... - _ - - - _ - --. - - - _ _ _ _ _ _ _.
Page No.
12 09/27/91
.00 CM81SSUE
+
. REPORT FORM CLOSPLkS TO PR!NT DSER CONCERNS / RESPONSES / STATUS FOR CAAFTER 8 ELECTRIC PCWER ktMBER DSER SECTION WRC COerCERu GE RESPONSE STATUS / CLOSURE PLAN A reference to 9.5.1.0 has been pieced et the end of the first paragrar+t in $sbsection 8.3.1.1.5.1 (pege 8.3-3).
This ties SECY-89-013 with the 3-hour fire berrier reg 4irement.
5.000 3.3.2.2 8.3.2.2 contain:nent Penetrations The re ponse to 435.3t(s) and section
- 1. sesolved.
8.3.1.4.1.2(7) have been sodifled te sere item (7) cf section 8.3.1.4.1.2 indicates that electric specificalty state the seperation criteria for
- 2. sesolved.
penetration essemblies of dif ferent Ctess 1E divisions are the penetrations. Such seperation criterie j
separated by distance, separate rooms or barriers, and/or exceeds that of IEEE 384-1981, as explained in l
location m seperate floor levels. Separate rooms or the modified response (see attached).
l l
berriers and/or location on seperate floor levels exceeds separation guidelines for penetrations and is acceptable.
Separation by distance may also meet seperation guidelines; however, information es to iAst constitutes the minioun ettowable distance between penetrations has not been eteerty defined. To clarify what constitutes min -ase seperation distance, additional information is reg;i ed for the foll wing items.
1.
C1erification of the response to atnstion 435.31(a> es to:
- e. Mininam ottowable distance between redurutant penetrations.
- b. Minisus seperation distance between penetrations containing non-Class 1E circuits and penetrations containing Ctess 1E or associated Ctess 1E circuits.
2.
Minisame attowable separation distance between penetrations (containing Class 1E circuits) and other divisionet or non divisional cables.
- Page No.
13 09/27/91
.00 CM8 ISSUE
+
. REPORT FDatt CLOSPLN8 TO PRINT i
DSER CONCERNS / RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC P0hG j
NUMBER DSER SECTION htC ConCERu GE RESFONSE STATUS / CLOSueE PLAN G.000 8.3.2.3 8.3.2.3 Ctess 1E Equipment Stbsection 8.3.1.4.2.3.1(9) stated that was and
- 1. Resotwed tused on Luuping the j
i RC&ls " cables will not be placed in any '
mestion of toter verses certier i
Se-:fon 8.3.1.1.5.1, Physicet Seperation and Independence, enclosure iAlch will unchly restrict empshitity IEEE standerds with iteam 3 of states that tiivisionet seperation for Ctess 1E egsipment of removing probe connectors for maintenance issue 4.0 (8.3.2.1).
(iAlch includes RPS and other ESF systems) is achieved purposes.* Piecemer't of cables within fien L
6 through the use of barriers, spotiet separation, and totetty conduit, es stated in 94.5.5.5, is consistent
- 2. sesotwed.
y enclosed receways. This combinetton of methods for achieving with this regsirement. However, to avoid r
separation meets the guide-tines of section 4.3 of IEEE misinterpretation,'the statement in
- 3. Resotwed.
Standard 384-1974 and is acceptable.
8.3.1.E.2.3.1(9) has been modified to state "cabtes will be enclosed and seperated as section 8.3.1.4 indicates that barriers (used to maintain defined in 94.5.5.5."
divisionet separation) are fire rated where feasible. Also section 8.3.1.1.5.1 indicates that racemeys embe:Med in Item 1: IEEE 384 and aegulatory Guide 1.75 f
l concrete wetts, ceiling, or floors witt be used as berriers have streedy beer '<1entified as the desiipi to maintain divisforot seperation. The use of fire ret?d basis criteria ft seperation, as indicated in I
barriers and embedded conduit meets the intent cf IEEE the resolutions to previous issues, and standerd 364-1974 for seperation of divisionet cables and is throughout Chapter 8.
This is etso reiterated acceptable. Section 8.3.1.4.2.2.2, however indicates an within the same ssbsection referenced in this i
exception to the conbination of berriers, spatiet issue 18.3.1.4.2.2.2(4)&(511. In addition to separation, and totetty enetosed a eweys es the c+1terie the separation criteria, the plant is designed for maintaining divisional seperation. In plant erees with such that complete burnout within a fire zone potentist hazards (such es high-prewsure feed emeter piping can be essamed per SECY-89-013.
i or high pressure steem tines) retkndent receweys seperated l
by 20 feet without be tiers or being totetty enclosed is
[
l attewed to be used to maintain divisionet separation. Also Items 2&3: We have stready identified and item (9) of section 8.3.1.4.2.3.1 indicates that cabtes justified ar:y exceptions to seperation criteria
[
f associated with the four redwident divisions of the start to in Appendix 94.5.5, and/or within the I
range monitoring system and the two divisions of the rod aspropriate sections where they are discussed.
control and information system located smider the vessel will For enaapte, +he NRC acknowledged the exception f
]
root use barriers, spotiet separation, or totetty enclosed identified for the teekage detection racemeys. However section 94.5.5.5 indicates that ' lible instrumentation in the usin steam tumet, f
I metattic conduit is attowed to be used on these cables. sider 8.3.1.4.2.2.2(1).
(See etso 94.5.5.73 It mes the vesset. To clarify c4 resotwe tPese inconsistencies and noted these cables are pieced in conduit, I
Page No.
14 09/27/91
.00 CMSISSUE
+
. REPORT FORM CLOSF1h8 TO PRINT DSER CDNCERaS/ RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POLER MLMSER DSER SECTION WRC CONCERN GE RESPONSE STATUS / CLCSusE PLAN to establish consistent seperation criterie, additional though they carriot be physiestly seperated to infonnstion is required fcc the foltowing itens.
the same extent es other cables mentioned in (1), yet they do meet seperation reo==irements 1.
Clarification of the criteria to be used as the of IEEE 384 Furthermore, sinuttaneou-f ailure Licensing and/or design basis for seperation between (e) of att cables in the group was anatyred and redmdant divisional raceweys (or cables) and (b) divisionet found to be acceptable. nowever, the meC did or associated divisionet and non-divisional receways (or not state aAether this is acceptable. The cables).
examples referenced in the geestion are not inconsistencies, but are part of the enceptions
- 2. toentification of each exception to the ticensing end/or and justifications raomested by these item.
design besis criteria for separation.
The resptnse to 435.35 was modified, es 3.
Detailed design description and enelysis justifying each empteined in the response to SER issue 8.3.2.1.
exception identiffed.
If design basis criterte for separation is IEEE Standard 384, separation for emanple between epen tray and totetty enclosed receways with less than 3 feet of horizontal seperation or 5 feet of vertical separation sust be ed$ressed es part of. tens 2 and 3 above. Response to question 435.35 states that each scram condait will be i
physicat ty separated by at least one (1) inr_h f rom non-enctosed raceways. For any separation of 5 feet to one inch between a conduit and non-enclosed receway the design does not meet seperation guidelines of IEEE Standard 384-1974 and must be justified by analysis.
7.000 8.3.2.4 8.3.2.4 Cables in ebinets/Panets item 1: There is no inconsistency between the
- 1. Resolved per mark w at referenced sections, because the statea m in erwtings, dich repleted the Section 8.3.1.1.5.1 states tha. divisionet cabtes to and 8.3.1.1.5.1 refered to routing in raceweys, sixth pe egraph of 8.3.1.1.5.1 from the contairement ard to end frau the dedicated d ich is enternet to the contrt,t room area.
with *Seperation within the sein divisionet egsipment in the reactor building are routed in
(*...terstinet cabinets
- has been changed to control room is designed in seperate cable raceways fcr each division. Section
... cabinets".) However, separation is also accordance with IEEE 334, and is 8.3.1.1.5.1 further states that divisionet cabte routing is meintainea within the contra' room penets in discussed in 8.3.1.4.2.2.3.*
i
I 1
4 Page me.-
15 09/87/91'
.D0 Cn81SSUE
+
. REPORT FOR94 CLOSPLh8 TO PRINT Dtta CONCERNS / RESP 0uSES/ STATUS FOR CMAPTER 8 ELECTRIC POWER i
WJMBER DSER SECTION NRC CDeCERN GE RESPONSE STATUT / CLOSURE PLAs i
maintained up to the terminal cabinets in the mein control accordance with Reg Guide 1.75 and (EEE 384 4
l room. This statement lapties that separate wie receweys
- 2. Resotwed.
j for each division may not be maintoimd within cabinets and The operator interface for toe main contret implies that non safety cables may be rot-ted in the same comptes does respire circuits of suttiple
- 3. GE needs to clarify l
recewey with divisional cables within cabinets or that divisions, or Class 1E verses non-Class TE 8.3.1.3.2.1(3), specifically the l
redundant divisionet cables may be routed in the same circuits, in close premioity. Seperation new insert section, such that raceway within cabinets.'This statement contradicts other criterie for these arees are addressed in trutividust conductors will be sections of the A8ut SSAR eAlch require separate racewers 8.3.1.1.5.1.
Fire-rated berriers cannot be colored both within and without from terminst to terminet including irmide of cabinets or provided in the contret room itself, tatt the the cabinets. This should etso other types of enclosures. To resolve this inconsistency and remote shutdown system (the redkedmt system allow eption for manuet merkings.
other concerns, additionet information is re wired for the for the contret room), provides acceptable risk (ACTION CoulPLETED PER mil!FIED following items.
for complete burnout of the control room.
RESP 0eSE) a 1.
Irv:ensistency tietween section 8.3.1.1.5.t and A reference to 8.3.1.4.2.2.3, which discusses
- 4. Resolve.t.
8.3.1.4.2.2.3 as to required seperation between redurmsant seperation within the contret room penets, was l
circuits within a cabinet.
added to 8.3.1.1.5.1 (see etteched mark-up).
I 2.
Criterie for sepeestion between safety tor associated) and non safety cables and between divisionet cables within stem 2: The rewested separation criteria for l
cabinets or any other type of enetosure tocated inside and att types of enclosures is detineated in the outside the mein contret room.
ediote of section 8.3.1.4, and particularly 8.3.1.4.2 and its subsections.
3.
sterking of cables inside of cabinets and/or penets (ref t l
section 8.3.1.3.2.1(3)).
j
^
I Item 3: The following reptoces Sdmeetion i
4.
In addition, section 8.3.1.4.2.2.3 includes the 8.3.1.3.2.1(3):
statement that the purpose of criterie for physical seperation of cables in penets is to preclude. the Cables shall be marked in a momer of possit:llity of fire propogeting between retindent circuits sufficient durability to be legible throughout and preventing safe shutdown of the plant. The staff feels the life of the plant, and at intervals not to that this statement of purpose may be misleading ir that it exceed 5 feet, to facilitate initist does not futty delineote the requirements of GDC 2, 4, and verification that the instattation is in
- 17. The purpose for physical seperation is to prectode conformarre with the seperation criteria.
fatture of non-safety cirtuits from causing feiture of any
f Cage no.
16 09/2?/91
.Do CMSI$5UE
+
. REPORT Folgt CLO#Le8 TO PRINT I
D5ER ConCEterS/ RESPONSES / STATUS FOR CleAPTER 8 ELECTRIC POWER i
NLgIBER. DSSR sECitois IIRC CosetERSI GE RESPouSE
$TATUS / CLOSutE PLAs safety circuit and to proctude feiture of one safety circuit such merkings shell be colored, as dettneeted from causing feiture of any other re&mdere safety circuit _
in 8.3.1.3.1, to migsely identify the division (i.e. to proctude courson cause f atture ot; safety circuits).
(or non-division) of the calde. Generetty, The purpose for heving physicet separation in penais should indivieset conectors esposed by stripping the be clarified in the Attat $$AR.
jacket are also color ceded or color tegoed (et intervets not to es.eed 1 foot) sudi thet their division is atiti d=scernebte. Emcept3ans are a
permitted for individael conmactors within cabinets or penets eAere ett wiring is unique to e single division (or is non-divisionet).
i
(
Itemi 4: The purpose for physical seperation has been rewritten as suggested (see etteched Berk W ).
i 8.000 8.3.2.5 8.3.2.5 Associated circuits As of septeneer, 1991, there are no known Resot eed.
- essociated circuits * (es defined in IEEE 384) section 8.3.1.1.5.1, Physical seperation and Independence, in the AeWR ssAR stenderd Ptent desi n j
- states, in port, that associated cetnes are treeted as Ctess References to such circuits have therefore been j
1E circuits. The staff interprets this statement to seen deleted in ett erees of Chapter 8 eecept I
that associated cables or circuits witt meet ett 8.3.1.3.2, and a cew interf ace regnrement l
. reesirements ptoced on Ctess 1E circuits. Att ea-panents in pieced in 8.3.4.13.
These have been' retained i-the associated circuit's current loop (toods, cables, to define criterie for associeted circuits, f;
connectors, switches, reteys, protective devices, etc.) will-should they be added prior to the finet design.
j meet Class 1E requit===ets. Each enception to this
- note 1" has also been added in 8. 3.1.3.2 to j
interpretation should be identified and justified in the eterify criterie (3) enc (4) of IEEE 384-1981, AeWR SSAR.
Section 5.5.1.
I At this stage of the design,' et t --as j
iAlch interface with Ctess 1E circuits are etso
]
q:.setified es Ctess TE, udess they are specificetty isotsted wie aggirowed isoletion j
l
~
devices. Such isolated circuits are* couponents l
I t
I
.,.. ~,,,
.~.
f
~
Page No.
17 09/cT7/91
.00 CH8155UE
.CEPORf FatM C10S:"LES TO P;14T
-?SER COiCSEsSIRrJ'OkSC/STAfd5 FCR CMAPTER 3 ELFCT4IT FJWE4 GE RESP 0itSE STATUS / CLOSURE PW NUMBER DSER SECTIOd NRC CONCERN t' m tw nm-Ctese 1E. The teet two
]
- ceregraphs e8 section 3.3,1.4.1.3 hawa tx 'yt
<! ele'.ed (see Osc%.
I 9.000 8.3.2.6 8.3.2.6 Cmbtet*aceway 'deetification steo *: The cater soding methods for cables
- 1. Raceway and power cable gr.J recewevs are datineated in 8.3.1.3.1 ard mattings sutd be consistent in regard to merking of c-btes a.d receways, esponse to 3.3.1.3.2 U xtuer+ng 8.3.'.3.2.1).
(A+
wit-the comunitments for cotor question 435.29 irdicates that the idemification."itevis Amenument 10, paoe S.?-11-=13.1 S Wi:ionet sesing of irc:viii t cornictors i
l specified in section E.3.1.3.1 and J.3.2.?.2.1 fut'y eterification has baen saied to noth sectf ans in t w 3 ef CSER T.O.
.actica l
COMPLETLD eER mtIF!10 RESPCust.'
f couplies with the require:nents of Reg atory $;uide 1.7*
es fottows:
1 (revision 2) and IEEE 386-1974. Tne staff revi oed this
" Cable. shall be nrked in a marrier of criterie with respect to t.e guidelines cf positta 10 a suff*cie*.t dwability to be teg;.,te tW 2.. Rmt.sd per meeting merk-ws
)
11 of Regulatory GuiJe 1.75 (revision 21 and saction 5.1.2 the tife af the ster:, and to facilit-te of 5.3.1.3.2. i.e, associetea of IEEE 384-1974 and es e result identified a rwiber of initiat verification that the iratattatiert is erbtes are i.nigwly identified c=
To resolve these concern., additional in ormation in ecnt.a mnce with the separetion criteria.
e leitudinal sMipe or ::ther d
1 concerns.
color cods method, erus t*e date is required ft' the tottowing itama.
"Such martings shall be colored to w iPety on t%e tabet.*
l
- 1. The method for color coding power, instr.eentatim and identify tha divisiori (or re-dkision) ef the control cables and receways.
cable. Generetty, irdivitmat cenCIJctors
- 3. aesotD#3.
expeced by strigeng the jacket are el,c. ceter
- 2. The method for distiftTJishing *Mt*aeen #36-Class 1E coded or coto. taggeJ (et 6ntervatt net to
- 4. Resotwed.
circuita associated with dif ferent redsdant divisions.
exceed 1 foot) such trst t hir division is stilt Jiscernable. Exces'tvors are permitted for iMiriduai cordators withirt saoirets or
- 3. The.narability of markings.
panels iAere at t wir*.,s is ur.ioue to a single
- 4. The merking of cables th-cughout the entire es6te tength divisfort (or is nor*-divisional).*
fr.za terminal connection to terminal correctica inchartog inside cabinets and/or pe els.
Also, in 8.3.1.3.1, *Ali c:bte treys are morted with their proger...* hea beee. changad to *Att C1 ass 1E ce%ie trays are aarted with the divisie. color, aid with their prorw...*
Ites 2: The r?thod for distirwraisMeg bete
.- \\
=
Page No.
18 09/2F/91
.D0 CMSISSUE
+
. REPORT Forse CLO M BS TO PRINT DSER CONCERus/EESPomSES/ STAT!FS FOR CMAPTER 3 ELECTRIC POWER neJsBER DSER SECTION MRC CONCE25 GE RESPONSE STATUS / CLO5URE PLAN t
non-Class 1E circuita essociated wi*h different red r6snt divisions is detinentec tr. 8.3.1.3.2, and has been clarified as follows: " Associated c.htes are smimely idntifici by a 1angitudiret st*t:e or other ceter coded method, and the data on the t 0 1.
The coter of the cab 8e starter for associated cables shatt be TM same es the related Class 1E cable."
Item J: A dJrability staicesc* k '. den ached to sections 8.3.1.3.1 and 8.3.1.3.2.1(3) consistent with IEEE 384 (see ansched).
Itee 4: Thase coream are ob1Nr$ pat
- Assed in issue 8.3.2.4, ard in Itees 1 & 2 aoove.
10.000 8.3.2.7 8.3.2.7 Cables Agroaching and/or Emiting Cabinets /Panets the n#C's stated implication in C carcistent
- 1. sesolved.
with the WeC's concems stated in SER wtion Response to pestion 435.30 states that cable spreading 8.3.2.4, nor SSAR section 8.3.1.1.5.1.
That
- 2. Res*tM with the acMition of areas a e not applicable to the ABWR and are not in the section specifies that IEE? 384, Reg Guide 1.75 e reference to Figures 94.4-1 plant layout because the majority of the signets will be and GDC 17 criteria is spoticable to att through 94.4-16 in 8.3.1.4.t.1.
auttiptened to the control rocia. Thus, it has been implied divisional couipment, includirs intercomecting that the 1 foot-3 foot separation guidelines at tewed by cabling. In addition, 3-hour fire rated
- 3. aesetwed.
section 5.1.3 of IEEE Staruksd 384-1974 witt not be barriers separate divisions in att areas of the applicable to A8WR nor will the guidelines of position C12 plant escept as noted in item & below.
- 4. sesolved.
of Regulatory Guide 1.75. Criteria for the separation and p otection of cables approaching and/or emiting
.abinets/penets has not been addressed in the Aikat SSAR. To tten 1: The re wirements detineated in initiate our review in this area, acMitional information is e.3.1.1.5.1 do not distinguish betw-en metattic required for the fet towing items.
er fit:er-cptic cables, and thus are amticable l
to both. The fottowing sentence was acMed at
- 1. Routing criteria ard protection to be provided electrical the end of the first parearaoh of 8.3.1.1.5.1:
t I
I
j u.
L
.Page 40.
.9 I'
. O/2?/91 _
F
.D0 CMBISSUE-
+
Ii
.mEPORT FORM CLOSPlm6 TO Falgt i
a DSER CGICER4S/RESPouSES/ STATUS FOR CanPTER 8 E!"C?ttC 80ER 1
l l uts1BEst DSEst SECMJW sNtC CDuCERE q RESPouSE STATUS / CLGEURE. A and/or optical catdes used to carry andtiplemed or other
- " Class 1E to non-Class 1E separation is
[
type of signets to the car. trol room.
cesigned in accordance witet the reesiremmts of -
IEEE 384.* Cable racemeys are seperate,.
- 2. Criteria for routing of safety or non-safety pouer catges according to voltage tevets, es described in tr: any room witle instrumentation and control catnes. '
8.3.1.4.1.1(4).
The "vt* tevet tperegraph (d)I has been cdified to irctude fiber-optic caldes 3.~ Inconsistency between iten (5) of section 8.3.1.4.2.2.2 (see attached).
l aJ respnse to Mtion 450.30.
t 4.. Cable separation in cable tunnets.
Item 2: The physicat errangemmt of racemeys 4
j keeps power catdes separate frtum ISC signet j
catnes, as described in 8.3.1.
1.1(4). The 2
following sentence hos been added to 8.3.1.4.1.1(3):
- Class it and non-Ctess 1E catdes are separated in accordence with IEEE l
3". and #G 1.75 (see Figures 94.4-1 through
%. ~ - 15).
}'
I i
Item 3: Secti o 6 1.3.1 of IEEE 364-1951 changes the term cable e reeding rac:= t.
a "nordisterd gree". Peregrees (51 of l
L.1.4.2.2.2 hos twe:2 adit.4 to *^ att specific.npirements that~ att safety enripment j
er cat e.
- 9 shel' et or e N the reesiremamts cf IF M (see attacheo
.or= w ).
s t
Ite *: The tas;tdin6 strtr*ures fr tsia A
,dnant.,e:o. -. _
j.
tte cable tsanets ce not repaired for i
d visiones cat 4es, W4e h
- ich ese decipam$ in Xs %ae with IEE V, do eress 4
I
~
~
l l
Fage No.
20 1
09/27/91
.CO CM8 ISSUE
+
.tEFORT FORM CLOSPLES TO PituT DSEE CONCEauS/ RESPONSES /$fATUS FOR CRAPTER 8 ELECTRIC POWER WlMBER DSER SECTION i;RC CDWCEAN GE RESPomSE STAT 7JS / CLOSURE PLMI within the buildings. Except for the instrument sensor cables for the turbine stop vetwe closure and turbine controt valve fest closure (see 7.2.2.2.4(4)l, Ctess TE cable res occur only between the reector oc<f controt tmsildings; ett others are non-Ctess 1E.
Each divisionet cable & ct between and throughout these buildinr,s is entirely seperate ord isolated from redundant divisier's by three-hour rated fire barriers. Enceptions occur only within the control room compten itset t, and within the primary contatrone=vt, and for teak detection chermocm ptw*.
Yet these exceptfore still meet the requirements of Reg Guide 1.75 and IEEE 384 by provi6ap metal berriers and/or spetist seperation between divisions. Special cases within the reactor buitding ere ano4yred as acceptabte (in accordance with SECY.89-013) in 94.5.
The contret room conotes fire anstysis is prtvidmf in VA.4.2.4.1.
Ctess 1E cables are seperated from non-Cless 1E cables in accordance with the regsiresurnts of IEEE 384 ard RS 1.75 in ett erees of the plant, incitding cable choses.
19.000 8.3.3.1 8.3.3 PRCTECTION The met stated ess m ion that *...the proposed 1: sesolved.
design mitt include redtrdant interrteting 8.3.3.1 Electric Penetrations devices on ett inst <usenteden and contret
- 2. See svu. Items e & b ok, tmet circuits as wii es pewer circuits that pass remed word engineering on c & d.
j Ites 7 of Section 8 3.1.4.1.2 indicates that power circuits tnrough contaien=ita is not correct. Some going through electric penetratiert essestaties are protected circuits do not beve high fault current
- 3. Resotwed.
egainst over current by redtav$ent interrupting devices. In avoitable, such as therauxtnote circuits.
edfition, response to geestions 435.31(b) indicates that it
- 4. seed to include criterie for
Fage No.
21 09/N /91
.D0 Cn8 ISSUE
+
. RETORT FORM CLOSPluS TO FR!aT DSER CDMCERwS/RES*0KSES/ STATUS FOR CMAPTER 8 ELECTRIC FUER IRMBER DSER SECTION mRC CONCERW CE RESP 3rSE STATUS / Ct m PtAs is an ASWR design regJiremer t that redadant interrwting credit taken for internet devices te provided for electrical circuits going through Itee 1: the requested information was adsed to im adence devices es e w of the conteirvient penetrations, if the seminun sveitabte fault 8.3.1.4.1.2tr'), but with the high eweitatde two in series (i.e., air current (inettsfing feiture of wstreen devices) is greater f ault current stipitation.
circuits).
than the continuous current rating of the penetration.
Based on the above design re wirements, it a m eers that the proposed design will include redtadant interrupting devices Item 2:
8.3.4.4 hos be.n modified to specify on ett instrumentation ard centrol circuits as wett as power the requirements for proper coordinati e of circuits that pass through conteiruent. In addition, when thermal capability curves and protection ef the calculating anzinue eweitable feutt current at the penetration conictors (see attached). It penetration, current limiting devices will not be used in should be reted that these penetaations are not the calculation (i.e. worst case feiture or shorting cf the GE scope.
upstreme or current limiting devices will be assumed es a given in the calculation). Eesed on the above l
interpretation, the staf f concitzies that the preposed design Item 3: Section 5.4 of IEEE /&1-1986 specifies meets Regulatory Guide 1.63 (revision 3) and is acceptatde.
that 1) %>ere a penetration esse.edy can d
To confirm the above interpretation and to resolve other indefinitely withstand the staintse current reteted concerns, acilitionet information is re w ired for the available dse to a f ault it' side contairunent, no a
following items.
speciet consideration is required.15.4.21* and
- 2) " Electrical penatraticns ressiring spaciet
- 1. Descriptive information which explicitly states that consideration shall be prowiced with dJet electrical circuits includes ett instrumentation and control p insey protection operating seperate circuits as well es power circuits.
inter *teting devices, or primary and backte j
protection operating seperate interrupting
- 2. Clerification of interf ace reesirenerets presented in devices.t5.4.2.13* ard 3) *The time-current section 8.3.4.4 to cteerty state the criterie er
- sign curves of the dJat primary prctection or the regtsirements that anJst be demonstrated by (a) f ault current primary and beck e prctection shall coordinate cteering-time curves for protective devices, (b) therent with the time-currect capability curve of the capability curves of the per:etration, (c) location of electrical penetretion to te protective oevices, and (d) power stwties for protective protected.t$.4.2.21* This has streedy ten devices.
provided per items 1 and 2 above.
- 3. Descriptive information aAlch clearly indicates how panetration protective devices will conform to each Item 4: The description "re&ndant overturrent a
i I
Page so.
22 09/27/g1
.00 Cn81SSUE
+
.E'EPORT FORM CLOSPLkS TO PR!nf DSER CONCERNS / RESPONSES / STATUS FOR CMAPTER $ ELECTRif POWER WUMBER DSER SECTION WRC CosCERW E JESP0 HSE STATUS / Closure PLAs require =mts of section 5.4 of IEEE Str Jed 741-1956, IEEE interrwting devices
- irserently attews either Standard Criteria for Protection of Class 1E Power Systems fuses or circuit breakers.
and Ecysipment in nuclear Power Generating Systems, that is
' ' by position 1 of tregulatory Guide 1.63 (revision 3).
- 4. Criteria ediich would permit use ef one cumrit limiting device and one protective device as the retiedant protective devices rieeded to meet the guidelines of position 1 of aegulatory Guide 1.63.
12.000 8.3.3.2 8.3.3.2 Safety Buses stee 1: A description of the grounding devices
- 1. sesotwed.
and their associated intertecking logic bes on every bus shoin in figures 8.3-1, 8.'-2, and G.3-3, there tm acued to subsectica 8.3.1.1.1 (see
- 2. sesotwed.
is one circuit shows connected to groisid throuch a circuit attacu d).
break er.
The circuit breaker or bus groisiding device is
- 3. sesotwed.
l used to provide a safety grotrid on buses during mainte iance o,xrations. Intertecks for the bus stus1 ding device as item 2: The addition of army graisiding device i
stated in response to question 435.47(e) include:
wi t t, top its esistence, corstritiute to some 1
measure of degradation in reliability.
l
- 1. Under voltage retsys must be actuste:::
newever, the intertock constraints (including those ass w isted with the racking
]
- 2. Related breakers sust be in the disconnect positiert; and ot.t/disecrvect position of the breaker itself) place the breakers in a state of sem-emistance
- 3. vottage for bus instrumentation avaiiat-te.
(i.e., *rccked out*) metiie the bus is energized, such that the bus reliability is not The staf f feels that the proposed groisding device any be en unacceptably degradr3.
important enhancement for pef ferming mainterience on safety buses and should be included in the design; however, the staf f is concervied that the above proposed interlocks may iteur3: An interf ace requirement has treen net be sufficient in and of thesaselves to prevent acMed to assure ac>rinistrative controts are in inadvertent closing cf the device during reintenance place to keep these circuit breakers racked out operation. To resotwe this conct-i, additional inf ormation (i.e., in the discorviect position) eAile the is recraired for the following items.
buses are erergized. Furt%ernere, an
Dage me.
23 09/27/91
.D0 CN8:53UE
. REPORT FORM CLOSPLW8 TO PR!sT DSER CONCEttS/ RESP 0KSES/ STATUS FOR CMAPTER 8 ELECTRIC PO4R WUI'BER DSER SECTION WRC CONCERW GE RESPONSE STATUS / CLOSURE PLAs L
arrweister will somd ebenever these treekers
- 1. Description and analysis for the proposed design.
are rocked in for service. Tnis precaution, in adfition to the other interlocks provided.
- 2. Justification that the tevet of retiebility of the safety should prectude any probabitity the treeters bus has not been degraded ty the addition of the device.
could be inedwertently closed daring non-smintenance geration of the power system.
- 3. Interf ace regeirements, aterius, or other controls eAlch See new section 8.3.4.14 attached.
will be implemented to assure the device will not tn
[
inadvertentty ctosed.
l 13.000 8.3.3.3 8.3.3.3 Quelificatiin item 1: The first peregraph en 8.3.1.2.4 has
- 1. sesotved.
ocen revised to say "...att Class 1E egdgn=ent section 8.1.3.1.2.2 indicates, by reference te co mtience is desig wd to operate shring ord ef ter any
- 2. sesolved trised on itseing t%
with Regutetory Guide 1.32, that each type of Ctess 1E design basis event, in the accideat envircrweent omestian of toter verses eartier I
ensipsent will be quotified by anetysis, successful use espected in the area in amich it is located.
IEEE standards in wits It = 3 of under simiter conditions, or tv octuel test to desmonstrate att Ctess 1E electric comissment is oastified to issue 4.0 18.3.2.1).
its ability to perform its fmction taider fearmet and design IEEE 323 (see section 3.11).*
basis events. Section 8.3.1.2.4 and 8.3.3.1 include the
- 3. a.setvad.
fattowirg items (it aweers) in stwort of comptWe with this Regulatory Guide 1.32 regsirement.
Itee 2: Compliance with IEEE 308 for the
- 4. sesotwed.
physical ledependence ef electric power systeams
- 1. Class 1E essignment essential to timiting the consecpences is conseitted in the test paragrash cf
- 5. sesotwed.
of a LOCA ere designed to operate in norset service ord post 8.3.1.4.1, es accropriate to this section.
eccident ecviraraments; Futt cowtience to Seguietary Guide T.32
- 6. Resotwed.
(hence, to IEEE 308) is stated in St.bsection
- 2. Electric egsipment is seismicatty gustified; 8.1.3.1.2.2(3) ard Table 8.1-1.
However, the certification standard is IEEE 308-1960, not
- 3. Att class TE cables are moisture and radiation resistant IEEE308-1974, es shouse in Table 1.5-21.
and highty flame resistant; Corresponding sections referenred for the 1980 version are 5.3, 5.4 and 5.9, respactively.
I
- 4. Sepore' ' certification proof tests are perforised to deaanstrw.r 60 yeer life, radiation resistance, Section 4.7 of 308-1974 sisoty states that L
eruriroreental capability, flame resistance, and gas egsigznent should be gaettfied ty type testing.
evolution of cables; operating emperience, or anstysis. Section 5.9 r
I 1,
- Pege no.
24 09/27/91
.D0 CNSISSUE
+
. REPORT FORM CLOSPLW8 TO PRIRT DSER CDsCERES/ RESPONSES / STATUS FOR CHAPTER S ELEL..C POWER erJesER DSER *ECTION WRC CONCERM GE RESPouSE STATUS / CLOSURE PLAs of 338-1980 rewires that eg.sipumt be
- 5. Each power cable has e radiation resistant covering; mastified in acecrdance with IEEE 323-1974, unich delinestes ett of these methods incitating
- 6. Corwhetors are specified to continue to operate at 1007.
their contrinetiJns (see IEEE 323-1974, Section relative humidity with a tife espectancy of 60 yeers; and 5).
Therefore, Section 5.9 of 308-1980 is more strirment than Section 4.7 ef 338-1974.
- 7. Ctess 1E cables are designed to survive the LOCA ancient condities at tte end of a 60 year life span.
Item 3: Seperatim c-itsie for the cauipamt Each of the above itees meets in port the guidelines of in the drywelt is discussed in 9a.3.
segulatory Guide 1.32; however, based on the information Envirorinentet quotification for att ewipment presented, it is not clear that att cables, for example, are in at t locations, including the drywett, is designed ard wetified to survive the comeinad effects of discussed in sectim 3.11 and A@endia 3I. A tengerature, humidity, radiation, etc. essociated with a refererre to 3.11 (which in turn referecces LOCA envircrement or other design besis event enviroruments et Amendia 31) is streedy irrita$ed in 8.3.1.2.4.
the end of their quotified and/or design life.
Clarification of the cesie end mastification requirements for cables es wett es other Ctess 1E equipumt to survive item 4: the test sentence of 8.3.1.4.1.2(2) normet and accident envirarssents (inctissing identification t.Aich mentioned the drywett was not considered with justi 'icetion of exceptions tc the design end a herti1e eree] has been changed to: "Cabte qualification requirements) should be provided in the A8WR rmsting in the
- ywett is discussed in SSAR.
essociation with the easipment it serves, in the 'speciel caeas' section 94.5.*
In addition, section 3.3.1.2.4 indicates that ett Ctess 1E ewipment edtich is essentist to limiting the consegsmces of a LOCA is desired for geration in normat service item 5: The tens " hostile eres* was interused envirorinent and to operate in the post accident environment to seen those erees entich could be potentietty i
expected in the area in which it is located. Also, this exposed to the energy of a postulated reactor section indicates that electric cosipment is osatified to coolant (steam or water) pressure boundary p-ipe IEEE 344 (i.e. electric ensipamt will be demonstrated to rtsture. This criteria is defined in Ascendia meet its performance requirements dari-us and fottowing the 31 ard tables 31.3-1 through 31.3-21.
design basis seismic event by test and/or enetysis).
Based on information presented, the design and quetification Item 6: Plant Design specifications for
i Oege No.
25 09/2P/91
.00 CM8tSSUE
+
i
. REPORT F0mut CLOSPLWS TO PRINT I
f j-DSER CONCERWS/ RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POIER i
. Mt#WER DSER SECTION WRC CDeCEau CE DESPONSE STATUS / CLOSE.WE PLAW i
comunitment for electric ewipment in the proposed Astat electrical ewiN require such equipserit be design is not cteer with respect to the capability of '
capable of continuous operation 4r wottage-i equipment to survive the conbined ef fects of e LOCA fluctuations of +/- SOK. In oEstion, Ctess TE environment. To clarify and resolve this and other issues, actors sust be eine to withstand voltese orgs additionet information is rewired for the following items.
to TC1 rated during iterting transients.
t (These two sentences h+ve been added to $344
- 1. Emplicit design commitment that ett Ctes-1E electric
$dmeetion 8.3.1.1.5.2(1H.
l equipment will be desipwd and quotified for.peration in l
Its corset service emirorument eruf to operate in the accident and post accident envirorument expected in the aree l-in edisch it is located for any design basis event.
I 4
j
- 2. Compliance of the ASWR design with sections 4.2, 4.3, and 4.7 of IEEE Stenderts 306-1974 a
i
- 3. Expected normet and accident emirorument, seperation criteris, protection of forded Ctess 1E ewipment and cables, and spatification of ewipment for any emirorument in the dryweli.
1 i
- 4. For the espected worst case accident ewirorument in the drywett, eterification of why the drywelt is not considered a potentietly hostile aree.
- 5. Criterie for estatdishing hostite arees.
i
- 6. Design arid gaellfication of ewipment to operate for 5 j
minutes seen subject to wottage' et 90 percent of rated i
voltage erus to operate for a predetermined time et 70 percent.
'14.000 8.3.3.4 8.3.3.4 9 ^
@ ee there is no contradiction tetiseen the response
- 1. Resofwed.
to 435.36 and 8.3.1.2.1.
Quite the opposite is i
Item (6) of section 8.'t.1.4.2.3.2 states that any electricot true, in that the seated terurinetions preclude
- 2. #esolved.
1 4
I
2-Doge so.'
26 4-09/27/91
.D0 CN8 ISSUE
+
, REPORT FORut CLOSPLm8 TO PRINT DSER CONCER6tRESPONSES/ STATUS FOR CMAPTER 8 ELECTRIC PCMER mumsER DSER SECTION mRC ConCERm GE RESPONSE STATUS / CLOSURE PLAN 1
i equipment erw1/or receasey for RPS or ESF Iocated in the flooding ef fecte on eperation of the devices, stspression pool levet swett zone will be designed to which in this case are thersoco etes. Wowever.
- 3. Resotmed.
satisfactority couplete their ftmetion before being rendered 8.3.1.4.2.3.2(62 was v, m a and hos been inoperable due to ewee te the envircrament created by the corrected per the attached morh e.
I t evet p+ -.. In response to staf f question 435.36, the licensee identified electrical equipment that mey twa Section 4.7 of IEEE 308-1974 is swerceded by submerged es a result of stspression poet levet swett section 5.9 of IEEE 308-1980 which rewires j
phenemmens or es a result of a LOCA. The Licensee T.rther Ctess 1E e suipment be qualified to IEEE indicated that the design specifications associated with 323-1974.- This eroticit ccummitment has been d
this electric e wipment would require terminations be sealed added to response 435.36 in w ordance with the such that equipment operation would not be impeired by met request (see attached nurtt-sap).
sshmersion. The quellfication of this equipmeent in accordance with the guidelines of section 4.7 of IEEE It should be restired that, es indicated in Standard 308-1974 wes, however, not specificetty addressed.
response 435.36, the only electriest devices Based on information presentad, it appeers that electrical (tm
.s plant lighting equipment) in the equissannt steject to stAmmergeve is not quotified and only wtwell area are thermocouples and instrument i
I portietty designed for schmergence. This conclusion Diping for-tevet monitors (the instruments contradicts section 8.3.1.2.1 of the Aena SSAR ediich states th-metwes are outside the wetwett). vuost of f
that ett Ctess 1E equipment is gustified.
these thermoccuotes are stimerged ett the time.
The remaining ones are desipwd specificetty
{
- It is the staf f concern that equipment falture die to to be s. merged es the pool levet swells.
submergence may adversely effect the safe operation of the Thus, concerns about *erpsipment falture* or plant and may odwersely ef fect Ctess 1E power sources
" adverse effects on Ctess 1E power sources."
7 serving this ewipment. To resolve this concern, additional due to poet swett are not weerented.
f information is rewired for the following items.
- 1. The apparent contradiction between section 8.3.1.2.1 and response to question 435.36 in regard to oestification of equipment.
- 2. Analysis demonstrating that failure of u m tified equipment due to sutzergence will not adversely af fect safety or Ctess 1E power sources.
Page No.
27 09/27/91
+
.D0 CMEISSUE
. REPORT FOR14 CLOSPtt3 TO PitmT DSEE COMERNS/RESPCESES/ STATUS FOR CHAPTER f. ELECTRIC POWER STATUS / CLCSURE PLAN CE # ESP 0 HSE NUMBER DSE* SECTION NRC CONCERN i
- 3. Explicit ccessitzents to gastification in conformance to Section 4.7 of IEEE Std 308-1974 I
1 The plant is designed with three-hour rated Resolved.
15.000 8.3.3.5 8.3.3.5 tapingement of fire Stgeressant fire barriers seperating redtndant divisions.
Section 8.3.3.1 states that the cable installation is such Therefore, a complete less of fts,ction can be that direct (spiw of fire sigpressant will not prevent assumed within any one fire aree, with safe reactor shutdown. Gesed on this state *ient it is not acceptable c w es (i.e., safe shutdown).
cteer thether ispingement of fire stspressant witt ce will no safety ftsiction is required of any cable not cause f ailure of cable systems. Clarification of the once it is exposed to fire. Urder such design and qualification of cables to perform their safety cirewstances, the redsdent divisirms would ftsiction while being sihjected to the direct ispiegement of asstane the safe shutdoin fis,ction. In fire stooressant should be provided.
edfition, the fire berriec system confines smoke, hot gases, and fire sassiressant to the division of the fire; es stated in the fourth reqJirement/comotience peregraphs of S h ection 9.5.1.0.
(Also, see Saksection 9.3.1.0.10.)
This is the intent of the statement, which has been muodified for clerification (see attached eerk-te).
Ctess 1E cables are quotification tested to withstard severe envirorwiental stress, es irdicated in 8.3.3.1, and consistent with IEEE 323. They are etso hose-streme tested, and mitt be tied doen in sietet trop. Even though redundar:t divisions are available, the cables should perform their fisictions while being subj=cted to direct ispiW of fire stgeressant. Wowever, because of the redtsidency avaitet:te in separate fire zones, specific testing in this regard is not required, nor considered necessary.
Pege No.
28 09/2'7/91
.00 CMBISStJE
+
l
. REPORT FORM CLOSPtk3 TO PRiuT CSER CouCERNS/ RESPONSES / STATUS FOR CaAPTER 8 ELECTRIC POWER i
NLMBER DSER SECTION NRC CDwCERN E RESPONSE STATUS / CLOSURE PLAN O.000 8.3.3.6 8.3.3.6 Isolation Between Safety Buses and Non-Safety Loads The design has been modified as emptained in
- 1. GE shall review the design response 43547. The modification is such that which now uses 3 divisions of Section 3.3.1.1.2.1 indicates that Isolation treakers are toeds mer transfer only between civision I zone selective intertecking (251)
]
provided between the Class 1E and non-Class 1E buses. In (i.e., the non-Ctess 1E stub bus fed frce:
treekers ord their cw. i Jing addition to normat over current tripping of the isolation Division I es shown on Figure 8.2-3), ard the non-divisionet "ste tases. GE breaker, rtne selective interlocking is provided between rmn-divisionet buses. Class TE power sources will probably persue one of the each isolation breaker and its testream Ctess 1E bus feeder red.rdant to Divirion I are no tanger used as following options: a) Defend the breaker. Ecction 8.3.1.2.1 indicates that even though the atternates for these toads. The individust existing design, b) Use the 251 isolation breaker is feutt-current actuated in items acMressed below reflect this change.
and AC stub taas on one division con-compliance with the guidelines of position 1 of onty, or c) remove ett 251s and Regulatory ruide 1.75, the intent of this Guide is met AC power st 6 buses.
through the ' tone selective interlocktrg technime-thus, the item 1: The staf f screed the Etne selective j
design meets the recosamendations of this and other guides.
intertocking meets the intent of position 1 of 2-8. Resolved based on E
)
RG 1.75, ard meets the protection requirements redesign per Ite= 1.
With respect to protecting Ctess 1E systees from fatture of ef CDC's 2 and 4.
~he staff's concern about i
non-Ctess 1E s-stems and components; the staf f agrees with suf ficient independence of redundant power
- 9. Resolved.
the licensee that coordinated breekers with zone selective sources has been resolved per the acdifications intertecking meets the intent of position 1 of Regutatoey addressed in response 435.67.
- 10. Resolved.
Guide 1.75 end awts the protection regJirements of criterie 2 and 4; however, with respect to meeting the Euf ficient Per the 7/2/91 telephone conference, the staf f 11-12. Resetved based on GE independence requirement of criterion 17, the staf f reauested GE provide e r % _ J.4 initiet reopsign per Ite= 1.
disagrees with the licensees essessment. Non safety frequency for testing the isolation breaker computers and transient recorder toeds shown on figure 8.3-5 coordinetton and rene selective intertecking.
- 13. Resolved.
have provisions included in their power supply design for GE therefore rwd such testing be automatically treMferring these toads freum Ctess 1E performed initially (i.e., antit coeroting division 1 to 3 and from Ctess 1E diviwien 2 to 3.
In emperience is gained) et each fuel cutege.
addition, it apoeers that the power steply any also incita$e This is consistent with surveillance intervels provision for automatic transfer of these toads betwean for testing LOCA trip signets for other types division 1 ard 2.
The design does not meet the guidelines of isolation circuit breakers.
of Regulatory Guide 1.6 nor the intent of position 1 of Regulatory Guide 1.75.
The proposed design thus may not The etternete power source for the non-safety meet the indepe dence requirements of criterion 17 cf related instrument power system shoen in Figure Appendia A to 10 CTR Part 50. To resotwe this and other 3.3-4 has been changed from "C/5 MCC Eut0* to j
I 1
Page No.
29 l
09/27/91
.D0 CnBISSUE
-+
. REPORT FORM CLOSPLNS TO PRINT 4
i DSEt CONCERWS/9ESPONSES/ STATUS FOR CRMTER 8 ELECTRIC POWER t
1 l
NUMgER DSER SECTION NRC ConCERW E DESPouSE Status / CLOSURE PLAs I
issues, additionet inforisation is required for the following "C/t MCC A14" (see attached). This change is i
items and/or steff positions.
consistent with those described et the i
beginnirt of this response..
i
- 1. Rell eitity, testability, test frequency, functionst
{
test, and calibration of the isolation breaker coordination I
and zone selective interlocking.
Itese 2:
4 Itese 8: The isolation devices used et the.
l
- 2. Att non safety circuits connected to the Ctess 1E system interface between Ctess 1E circuits and through the isolation breeker with zone selective twwCless 1E egalpment circuits for interlocking shalt be treated es associated circuits.
annimiciators or dets toegees (reference section
)
8.3.1.4.2.2.4), are fiber-cotic devices. The
[
- 3. Intercorviectim between re&ndant divisions (whether use of such devices for this specific purpose I-through safety or non safety buses) shall be mainteined with is a:Wress M in response 420.128, Item Tb.
i l
two norimmily open and interlocked devices that are seperate
}
l and independent such that single fatture or single operator i
j ection can not cause the interconnection of or challenge to item 9: The T/s MCC's have been deleted from f
l redtsident divisions.
Figure 8.3-3 and added to tie non-Class 1E
[
buses on Figure 8.3.2 (see at W hed).
[
- 4. A&inistrative interface criter5a and/or eterius for maintaining and assuring intercomections open.
i l
Item 10: Response 435.15e hos been corrected, i
- 5. Identification of att safety and non safety toeds thet per attached, and now egrees with response
+
can be powered from more than one Class 1E divisier power 435.14 suppty. Appendia 20s shoutd be modifled to eieerty indicate f
loads that can be powered from more than ene safety f
division.
Item 11: Tables 8.3-1 and 8.3-2 show att DIG toads (including both Ctess 1E and non-Ctess tE f
i
- 6. A description and anstysis of the use of fault actuated toeds) for LOCA+LOPP and LOPP (w/o LOCA),
[
isolation devices in the Ctess 1E constant voltage constant respectively. kone modifications are shoun per i
k frequency power system.
attached mart-up.
,r i
i
- 7. The use of uninterruptible power stggdies es isolation The C/G's are rated at 6.25 avA with 0.8 pf devices (Reference response to questiwi 435.34c).
($000 kW), es shonen in Figure 8.3-1.
As of Aprit,1991, ehe esaisuas tond is shown te occur i
\\
l 4
1 i
f
Page No.'
30 09/27/91
.00 CM81SSUE
+
i
. REPORT FORM CLOSPLh8 TO F1t!NT DSER ConCERhS/ RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER NUMBER DSER SECTIDW NRC CONCERN GE RESPOKSE STATUS / CLOSURE PLAN
- 8. Isolation devices used at the interface between Class 1E on the 1 * (electrical division II) D/G for circuits and non-Class 1E egaipment circuits (i.e.,
the LOPP (w/o LOCA) condition (see marke tebte
[
ammciators or date loggers) (reference section 8.3-2 attached). This toed requires a dieset 8.3.1.4.2.2.4).
engine output deuend of 4960.9 LW. Assuming the generators are 95% efficient, this equates
- 9. The contradiction between Figure 8.3-3 and response to to about 4712.9 kw at the gmerator output i
westion 435.49c. Response to question 435.49c states that terminets. Therefore, m der menisam toed T/s seCC is non Class 1E and is powered fras non Class 1E conditions (idiich includes both Ctess 1E and power sources. Figure 8.3-3 in contradiction shows T/3 MCC non-Class 1E equipment), the worst-case to be powered from Class TE power sources.
(heaviest toeded) D/G would carry approximately 94% of its rated load.
I
- 10. The contradiction between response to question 435.18e, westion 435.14, and other A8WR SSAR sections (e.g.
8.3.1.1.2.1) as to tripping of non-safety toads on a LOCA Item 12: The dieset generators have sufficient I
signet.
capacity for att Class 1E ard non-Ctess TE toads, as emptained in Item 11. The capacity
- 11. Identification of att non-safety leads and their KW mergin and sizing teiteria for DC power systems j
ratings that can be powered from safety related dieset includes both Class 1E ard non-Class 1E toads, generators and identification of the extra tv capacity and is discussed in section 8.3.2.1.
available to st4 ply non-safety toeds during the various modes of ptont operation.
Item 13: Response 435.18(d) has been
- 12. The capacity, capacity margin, and other grovisions that clarified, as shown in the attached merk w.
l will be included in the sizing criteria for electric systems LOPP toads regsired for LOCA remain on the bus, I
and components (i.e. diesel generators, betteries, but others are tri ped off.
i distribution systems, etc.) neiich will attow thee to perform their safety fmetion reliably white suppt;ing non-safety loads.
t
- 13. Ineensistency between response e and d to w estion 435.18 as to loads that are discomected for a LOCA L
occurring after loads have been se v enced following a toss of offsite power. Response c indicates loads not required for LOCA are triped iAlte rwe d lapties that LOPP i
g i
W i
i l
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.REPC*T FORM CLOSPLW8 TO PRINT l
DSER CONCEANS/ RESPONSES / STATUS FOR CF. APTER 8 ELECTRIC POWER i
GE RESPCNSE STATUS / CLCSURE PLAN NU4BER CSER SECTION NRC CDNCERN toss ceasin connected.
17.000 8.3.3.1 8.3.3.7 Dieset Generator Protective Relaying item 1: There are two arguments why the bus
- 1. GE will rewrite the response differential relays shoutd not be bypassed to clarify that the bus Section 8.3.1.1.6.4, Protection Requirements, indicat i
- aat under LOCA conditions:
differential relays trip the bresher, but do not shut down the the foitowing protective relaying wilt trip the die o' generator and will be retained under accident condu m w:
- 1) A bus differencial indicates a serious fault dieset itself.
C=nerator dif ferential, bus dif ferential, engine over speed.
condition, in a similar class with the low dieset cooling water pressure (two out of two seraors),
generator differentist. unconditional trips
- 2. GE needs to make att bypnsed and low dif ferential presst?-* of seconrAry cooling water should apply to bus differential signals for alarms show on control roaa list (two out of two sensors). Other protective tG ps will be the same reasons they apply to ganerator and make consistent with Chapter bypassed during LOCA conditions. This protective relaying differential signals. The generator aruf bus
- 18. Also, add statement that (except f or bus dif ferentist) appears to meet position 7 of sust be protected f m
- such faults because th y they are alarmed in the control RegM atory Guide 1.9 (revision 2) and is acceptable. To are capable of inflicting major Or=ge to the room.
resolve the exception (i.e. bus differential retM. tripping generator or bus if lef t trichecked. Sus the dieset generator) and other related concerns, additional dif ferential protection is rw_a4 by IEEE
- 3. GL h $a to revise the information is required for the following items.
242-1986 (IEEE suff Book, Section 12.4) for response in tisnt ' N itfan 7 busses fed by local generators.
- 1. Bases and justification for t7 i <tif terent!al relays
- 2) There are three separate diesel generators,
- 4. Resolved.
tripping the diesel generator.
each supplying its own ira a nt safety r
I
- 2. Design description for alarming all trips including those division. Since a minlaus of only one division
- 5. Resolved.
(i.e., one dieset generator) is required to that are bypassed during LOCA.
achieve saf e plant shutdown (see response
- 3. Design description of bypass circuitry and its conpliance - 435.24), each generator can be better protected without conpromising plant safety. It is not with IEEE 279 rewirements.
necessary to risit Jamage or distruction of one
- 4. Separation between the two trip sensors and logic for low generater, even trider LOCA conditions, when diesel cooling water pressure and low differential pressure there are two remaining generator divisiens available.
of secondary cooling water.
- 5. Inconsistencies tntween section 8.3.1.1.6.4 und 8.3.1.1.8.5 as to bus differentia 1 retnying.
Item 2: Stbsection 8.3.1.1.8.5 tiets att stores associated with the dieset ganerator.
s
- o j.-
d
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. REPORT EORM CLOSPLN8 TO PRINT 4
DSER CONCERNS / RESPONSES / STATUS EOR CHAPTER 8 ELECTRIC POWER r
NUMBER DSER SECTION NRC CONCERN GE RESP 0mSE STATUS / CLOSURE PLAN The stare list has been expanded to include the tax diiferential trip, the generator grotmd i
overcurrent trip, and the generator loss of
[
field trip. However, es indicated in response t
435.22, the x tunt alarms required may var.,
I depending on the specific D/G selected t a the final design stage.
4 Item 3: The types of bypasses discussed in IEEE 279 (sections 4.11 through 4.% ) are tho e which remove systems or chamets from operation, and thus tend to reduce essa, a s ct protective actions. Conversely, the D/.
-5 l
bypasses uti1ited trider LOCA conditions e provided to assure the protective action of the i
diesel generators. These t p ases do not
{
operate on the protective f m etton Itself (i.e., the diesel generato.
but ratha, on r
n t
4 the circuits 6Alch trip the protective i
funct 4*in.
Therefore, the IEEE 279 criterie relating to automatic renowet of b messes, i
5 etc., are not a @ licabte to the trip bypasses y
discussed here. Otherwise, such criteria would j
have a negative ispect on safety.
L h
Item 4:.The three diesel styport systems are l
safety related, independent, and redundant; and
[
each is on the same division as its associated I
'dieset. Therefore, additionet seperation i
regJiremente are tvst imposed within each t
division itself.
Sot.' naturet s waration of these sensors would exist, based on the 4
I
}
4
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. REPORT FORM CLOSPLh8 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE.
STATUS / CLOSURE PLAN manufacturer's design, but it is not rewired that they be seperated because of the three redundant diesel systems.
Item 5: The bus differential relay trip has been added to 8.3.1.1.8.5 (see attached mark-w).
18.000 8.3.3.8 8.3.3.8 Thermal Overloads As indicated in response 435.60, circuit GE needs to consult with design details at the elementary levet are beyond the and field personnet to assure the In response to question 435.60, the licensee indicated that LR8. However,.an interface requirement has thernet overtoed circuits are thermal overload protection for Class 1E Mov's is in effect been added as section 8.3.4.15 to assure the testable as presently designed.
only when the Mov's are in test and are bypessed at all MOW overtoed bypasses are testable (see An alternative sey be to redesign other times by means of closed contacts in peraltet with the attached).
the overload protection auch that thernet overload contacts. A visuet indication is provided it is bypassed only on LOCA in the main control room when the MOV is in test. -The signet.
proposed design for bypass can assure that the thernet overtoed protection wilt not be in ef fect daring accident conditions to prevent opration of valves. The design thus em.- 1 the intent of Regulatory Graide 1.106 and is acceptable with the possible exception of testability. Sufficient information relating to the capability fer p*riodically testing the contacts that are in parattet with the thernet overtoed contacts to assure they are closed during normal operation has not been presented.' To resolve this concern, additional information is required concerning testing c the thernet overtoed bypess' device.
19.000 8.3.3.9 8.3.3.9 Breaker Coordinetton The senterLe has been clarified as follows:
Resolved per additionet sentence:
" Tripping of the Class 1E feed breaker is
" Coordination is provided between In section 3.3.1.1.2.1, the licensee states that tripping of normat for faults which occur or the Ctess 1E the bus main feed breakers and the Class 1E bus feeder breaker is normat for feutts which bus it feeds. Coordination is provided t'etween the toed breakers." which was occur on its Class 1E toads. The staff disagrees with this the bus main feed breakers and the toed added per merkw at the meetings.
a
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. REPORT f0 Ret CLOSPLMS TO PRINT
.i DSER CONCERNS / RESPONSES / STATUS FOR CHAPTEit 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN y
statement. Class 1E toed breakers should be coordinated-breakers." See attached mark-up.
with the Class 1E tus feeder breaker so that foutts which
'f a
occur on its Class 1E toads witt, to the entent possible, not cause trip of the bus feeder breaker. ' Clerification of '
7' the ASWR design with respect to breeker coordinetion is 4
recaired for resolution.
20.000 8.3.3.10 8.3.3.10 Protective Relaying The details for setpoint methodology specific As of the 9/13-16/91 meetings, for the ASWR may be found in the " Instrument the NRC had not yet reviewed the Experience with protective relay applications has' Setpoints Design Regstrements" document Instrument Setpoints Design established that relay trip set point will drift with identified in the reference in Section 1.1.3 of Requirements document..The NRC I
I conventionet types of retsys. Set point drift et Nucteer the Athat SSAR. A reference to this document hos the document, and has the..
power plants has resulted in premature trip of. redundant has been added to response 435.58 (see action item to review it in light..
safety related pump motors den they were regJired to be attachment).
of this issue.
operative. White the besic need for proper fault erotection j
for feeders / equipment is recognized (and may be a.
~
l recp'Irement for. the design basis event fire), it is the r
staff position that total non-eveitability of red e dent.
safety systems due to spurious trips of protective releys is-
.[
not acceptable. The primary safety function of the electrical distribution system is to provide power, reliably, to safety related egsipment. The Licensee in
'l response to this position (gaestion 435.58) indicated that f
loads, such as motors, will be purchased with sufficient -
current carrying capability or overtoed margins so that set.
{
points of protective devices can be set sufficiently above l
the operating current point of loeds to ottow for. set point j
drift. Purchase of motors with sufficient overtoed margins v
meets the intent of the deve staf f position and is acceptable if one assuers the following:
'1. The overtoed mergin will acce te the toed's starting
., t current as welt es the normat operating cur.ents of toads.-
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. REPORT FORM CLOSPLN8 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE Pt.AN Q MBER DSEX SECTION NRC CONCE'tM
- 2. Specific design parameters and/or Interface requirements clearly define (in the ABWR SSAR) the overload margin requirements with respect to protective device trip set point, the margin between the trip set point and operating i
current point of toads, set point drift, and the margin j
between the trip het point and overload rating of loads.
- 3. The load breaker protective device trip set point is I
established witt. suf ficient margin (a) between trip point and operating current, (b) between trip point and overload ating of the load, and (c) between trip point and trip point of the main bus feeder breaker.
- 4. The protective device trip set point is periodicatty verified and calibrated.
- 5. The protective device is subjected periodicatty to a functional test to demonstrate (a) its capability to not trip at its design setting i.e. the normat operating csrrent of toad plus margin and (b) its capability to trip when subjected to a fault current.
The staf f is concerned that the ASJt design may not meet the above assumtions.
21.000 8.3.3.11 8.3.3.11 Fault Interrtpting capacity item 1:
8.3.1.1.5.2(4) has been modified to
- 1. Resolved par ad$ed "...mder say: "Interrtpting capacity of switchgear, load att modes of operation." (See Design criteria (4) in section 8.3.1.1.5.2 states that centers, motor controt centers, and Page e.3-4.)
interrteting capacity of switchgear, load centers, motor distribution pa,ets is equal to or greater than control centers, and distribution penets is corpatible with the manisua available f ault current to which it
- 2. Add interface reqJirement for the short circuit current available at the Class 1E buses.
is exposed." (See attached.)
Listing of " common" truisstry standa4Js (designer oriented).
Based on this statement, it is not clear that the See, for ema gte, the C.F. Braun interrtpting capacity of this egJipnent will be equal to or greater than the maxisue available fault current to which it Item 2: Comtience of this equipnent io purchase specifications.
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. REPORT FORM CLOSPLN8 TO PRINT I
DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER CE RESPONSE STATUS / CLOSURE PLAN NUMBER DSER SECTION NRC CONCERN would be exposed. To clarify the criteria for the ind;stry standards required by the SRP is interrupting capacity of equipnent and to resolve other stready provided in section 8.3.1.2.
The NRC related concerne, additional information is recpired for the should give guidance on what additional standards, if any, are being i m osed.
following items.
). Clarification of the criteria for interrupting capacity, and
- 2. Cornpliance of both Class 1E and ry: Ct%s 1E switchgear, load center saotor control centers, and distribution penets to applicable industry standards.
22.000 8.3.3.12 8.3.3.12 Control of Design Parameters item 1: Normat settings of the thermal
- 1. Resolved based on luming overload trips, in accordance with the testability question with DSER Valve problems such as excess friction, packing too tight, manufacturer's requirements, will prctect the issue rurt>er 18 (8.3.3.8).
etc., can result in an operational condition where the valve operating motors of att non-Class 1E MOVs Mowever, this response statement will need to be changed if the current dram will exceed the design rating or capability of at att times.
overload bypasses are redesigned.
the insulation system used in the valve motor winding.
Operating experience has shown that excessive current, if Class 1E MOV's have similar protection during manual testing or maintenance trider
- 2. Pesolved.
undetected during operation, can cause premature or actninistrative control (see response 435.60).
unexpected failure d en the valve is next operated.
Methods, design provisions, alarms, or proced;res for However, Class 1E MOV thermet overload trips l
assuring the valve motor will not be operated with exce*tsive are bypassed at att other times in accordance I
currents (or will always be cperated within their design with Regulatory Guide 1.106.
timits) has not been presented in the ABWR S$AR. To resolve the issue discussed above and related concerns, additional information is required for the following items:
Item 2: Att Class 1E cogonents are designed, parchased, tested, and inspected in accordance
- 1. Methods used to assure design parameters for motor with IEEE 279, specifically paragraphs 4.3 ard operated valves will not be exceeded during valve operation.
4.4.
- 2. Method used to assure design parameters for att Class 1E cog onents will not be exceeded during att modes of plant
l f
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37 f
09/2F/91
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I
. REPORT TORM CLOSPtk8 TO PRINT f
DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE PLAN NUMBER DSER SECTION NRC CONCERN operation, i
23.00 8.3.3.13 8.3.3.13 fire Protection of Cable Systems Spatial separation, where necessary, is Resolved.
justified within the primary contairrent Section 8.3.3.2 indicates that spatial separation is used as because it is inerted with nitrogen during a method of preventing the spresd of fire between adjacent reactor operation. An exposure fire cannot be cable trays of different divisions (e.g. Inside primary sustained in the nitrogen environment. (See containment). The objective is always to separate cable response to SER section 8.3.2.2.)
j trays of different divisions with structural fire barriers such as floors, ceilings, and watts. Where a floor, 10 CFR 50, Appendix R applies to nuctear power l
ceiling, or walt is not possible, divisional trays are facilities op; rating prior to January 1, 1979, i
separated spatially by 3 ft. horitentatty and 5 ft.
therefore, conpliance with A;pendia R is not verticatty. Where this 3 ft.-5 ft. spatial separation is acMressed in the ASWR Standard Plant.
not possible, fire rated barriers are used to separate divisional cable trays. For a fire initiated by a cable in accordance with the SRP, the ABWR has f ault within one division, the above defined separatf or*
cczunitted to meet STP CMEB 9.5.1, which meets the guidelines of Regulatory Guide 1.75, will provide incorporates the requirewe s coveted by reasonable assurance that a fire in one division will not Appendix R.
Corptiance with BTP CMEs 9.5.1 is propagate to a redt:1dar.t division, and is acceptable. For discussed in SSAR section 9.5.1 and Appendia the design basis event fire, spatial separation and fire 9A.
f rated barrierr may est be sufficient to prevent the spread of fire between adjacent cable trays or wire bundles.
l Clarification of the design's compliance with 10 CFR Part 50 AppendiA R requirements is required to resolve staff concerns.
24.000
- 8. 3.3.1 '.
8.3.3.14 Electrical Protection Assenblies (EPAs)
The need for redundant EPAs was based on the The NRC stated that resolution of fact that RPS power stgplies in operation this issue will be based on what Two independent electrical protection assenblies (EPAs) were during 1980 were non-Class 1E; theref ore, a was implemented at the Clinton regaired (by a Septenber 24, 1980 letter to att operating single random failure had to be taken in site with regard to EPAs for the BWRs) on the output of RPS power supplies in order to acMition to the postulated power spty RPS. CE has action to consult satisfy the single f atture criterion for non-f ail-safe type failure. Question 435.7 acknowledged that with site personnel and reflect failures which may be caused by under voltage, over voltage, because a Class 1E RPS power st4 ply is used on the Clinton design resolution in and taider frequency conditions.
the A8WR, redialdant LPAs are not required since this response.
Page No.
38 09/2'/91
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. REPORT FORM CLOSPLES TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN failure of the Class 1E sw ply is the first Response to question 435.7 indicates that EPAs witi not be random failure taken. The focus of the used in the ASWR design because of special design features.
qtestion, then, was whether a single These specist features include monitoring of voltage and independent EPA is required.
frequency, automatic transfer of power s @ ply ircut sources when vottage and/or frequency exceed preestablished limits, GE's position is that even a single independent control room alarm for abnormat conditions, operator action EPA is not necessary, because (unlike previous in response to storm of wbnotinetity, and design and plants) the type of protection provided by an qualification of equipanr.t to not fait after operation for e EPA is already included within *he power period of time under the extremes of voltage and f recpaency.
stopties themselves. The Class 1E power sources sa g tying power to the solenoids of the scram pilot valves are ecp;irped with Class 1E Based en a review cf these special features, it appenes that voltage and f requency regulation, and stso with they may provide reasonable assurance that any abnormality Class 1E nonitcring and protection devices in voltage and frequency (which can ceuse f ailure of which monitor for taidervoltage, overvoltage, fait-safe-type egJipment) will be promptly disconnected by treerfrequency and overfrequency *ditions and alarma and operator action. The specist features, however which will automaticatty trip the power source do not meet the single falture criterion. Failure of the (i.e., disconnect the loads from the degraded spectat features to alarm or of the cperator to take prompt power source) whenever an out-of-specification appropriate action are single failures which may cause a condition pe'sists.
non-fall-safe type falture. The capability to scram the reactor may thus be compromised.
Twn f altures are necessary to cause a condition of degraded power to the scree pilot valve An explicit statement of conpliance with the staf f position solenoids. The first failure would be the that two EPAs be provided on the output of the RPS power degraded power condition of the Class 1E power stpplies with justification for areas of non compliance source; the second would be the failure to should be inctoded in the ABWR S$Mk.
transfer power, to alarm, or to trip. The power distribution system is thus desi ned such J
that a single failure cannot result in degraded power being stopiled to the "A" or "B" solenoids.
Both the technical and redundancy functions performed by an EPA are therefore preserved
Page No.
39
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. REPORT FORM CLOSPLN8 TO PRINT DSER CONCERN >/ RESPONSES / STATUS FOR CHAPTEe 8 ELECTRIC POWER NLWlER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN within tha design of the power st9 ply itsetf, and an externet EPA is not necessary or requireu.
25.000 8.3.4.1 8.3.4 ELECTRICAL IhDEPENDENCE This issue is addressed in response 435.67.
Resolved based on respor.se Figure 8.3 8 was modified as explained.in that 435.67.
8.3.4.1 Interconnections response.
Figure 8.3-8 shows two interconr.ections between redundant divisions:
- 1. Division Ill 480 vott bus designated P/C EN1 is connected to Division 1 480 voit bus designated P/C CN1 through circuit breakers and mechanicat' interlock. Section 8.3.2.1 indicates that this interconnection is used to transfer the 250 VDC Worsal bettery charger between Division I and III toed centers.
- 2. Division III 480 volt buw designated MCC EN10 is comected to Division 1480 volt bus designated P/C CN1 through bettery chargers; breakers. and key interlocked breakers. Section 8.3.2.1 Indicates that this interconnection is used for selection of the normat or the stancby battery charger.
Criterion 17 of AppeMix A to a0 CFR Part 50 requires independence between redteident divisions such that f atture of one will not chattenge or cause failure of the remaining redundant divisions. Sufficient information describing-these and other ir.terconnections as to their compliance with the independence requirement of criterion 17 has not been provided in the ASWR SSAR. It is the staff position that two independent open discomect links, racked open breakers, or other equivalent open devices be maintained between.
e
- age No.
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REPORT FORat CLO'iPLNS TO PRIN)
DSER CostCERNS/ RESPONSES / STATUS TOR CHAPTER 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE *LAN C1MBER DSER SECTION NRC CONCERN redundant divisions if redundant divisions are to be electrically interconnected. Additional information as to extent of compliance with the above staff position with justification of area of Non Compliance is required in the ABIAt SSAR for resolution of this issue.
26.000 8.3.4.2 8.3.4.2 constant Voltage constant Frequency Power Supplies There are four independent and redsidant
- 1. Resolved.
batteries which s@ ply DC power to the CVCF's.
Section 8.3.1.1.4.2 indicates that each of the four The only link between divisions is through the
- 2. sesolved.
irdependent trip systems of the reactor protection logic and division IV battery charger, which receives its control systent are powered by four constant voltage constant power f rom the division I AC supply. There is frequency control power buses (Divisions I, II, III, and comp 8"e independence of the four divisions IV). This section also states that each of these buses is f rom ti e batteries, through the CVCFs, and on sw ptied independently from an inverter which, in turn, is to the cads. The statement in 6.3.1.1.4.2.1 has been clarified to esplicitly identify the supplied from one of four independent and redandant AC at DC power sigpties. Subsequent sections and figure 8.3-6, f our DC st4 plies and three AC selfes (see however, indicate that the AC supply for divisions I and IV attached mark w ).
originates from a single 480 volt motor control center l
{
(C14). A single 480 voit motor control center is not The purpose of division IV is to provide futt independent and remndant as stated in section 8.3.1.1.4.2.
two-out-of-four togic for the SSLC, which To resolve this inconsistency and other concerns, additional governs the ECCS and RPS channels. It also information is required for the following issues and/or f acilitates reversion te two-out-of-three logic at the loss of any one of the four channels. A l
rositions.
cceptete justification of this arrangement la
- 1. Description, justification, and analysis to demonstrate assured by the f act that safe shutdown that suf ficient red;ndancy and independence has been criteria, including singte failure c'esigned into the protectim system and their associated comiderations, are atrendy acconcodated with powr supplies in accordance with the requirements of divisions I, II and !!! alone. Also, this fina caiterion 21 of Appendix A to 10 CFR Part 50.
between the division IV battery charger and the division I power source is explicitly defined
- 2. AC power swpty for Division IV should be powered f rom a in the PRA study. For additional details, see 6.9 KV division bus that is independent, to the extent response 430.315 and subsection 9.5.1.2.11.
practical, f rom Division I, !!, and III 6.9 KV and 480 voit distribution systerns.
Page No.
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. REPORT FORM CLUSPLWS TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN 27.000 8.3.4.3 8.3.4.3 Power Stpply Circuits foe Safety / Relief Valve (SRVs) ltem 1: Section 19E.2.1.2.2.2 has been
- 1. Resolved.
modified as snown in the attached mark-up.
Section 19E.2.1.2.2.2 indicates that portions of each There are ein safety retlef valves on each of
- 2. Resolved.
safety /retief valve (SRV) control circuit utitira non-safety divisions I, II and III. ADS Velves are grade pover and that this non-safety grade power is taken controlled by divisions I and II.
f rom the Class 1E DC system through DC/DC converters or -
Non-divist m l power is not 'tilized in either isolation devices conrected to each of the four redundant the SRV or..DS ftrictions. C rision *V is used and independent Class 1E DC system buses. Section c-ty for the two-out-of-four initiation logic 19E.2.1.2.2.2 imp?ies that controt power for each SRV comes for the AD. The electrical power divisions from a.ainisan of two dif ferent Class 1E power source assigned t each valve are shown on Tabte divisions. Ehe source directly from the Class 1E DC bus 19C.3-3.
with the other from a different Class 1E DC bus through the DC/DC converter. The staff is concerned that the proposed design for powering the SRV's may not provide sufficielt Item h The physical and electrical separation independence between the redtrident DC power sources in for ADS control circuits is preserved. The accordance with the requirementa cf GDC 17. To resolve this close proximity of the divisions I and II C S concern, additional information is required for the solenoids reqJires barriers to maintain following itees.
separation. These solenoids are isolated by metet junction boxes, rigid conduit, snd/or
- 1. Design information and/or criteria for the physical and short sections of ftextbte conduit, as electrical u paration of safety and non-safety control power described in 8.3.1.4.2.3.2(4).
circuits for each SRV from the power source to and including the SRV control circuit.
- 2. Physical ard electrical separation of the ADS control circuits and their sources of power. (Section 19E.2.1.2.2.2 i
indicates that four of the eight SRV's used two divisions and the remaining four can be stpplied by any of three divisions).
28.000 8.3.5 8.3.5 LIGHTING SYSTEMS Item 1: The lighting tevels are based on the
- 1. Add cross reference relating IES recomunended intensities, as indicated in Table 9.5-1 item to appropriate Section 9.5.3.1.2 indicates that adequate lighting for any 9.5.3.1.1(1).
1ES standard items. The kRC
Fwge No.
42 00/27/91
.00 CH8 ISSUE
+
. REPORT FORM CLOSPLNB TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER CWBER DSER SECTION NRC CCWCERW GE RESPONSE STATUS / CLOSURE PLAN safety related area, such as areas used daring emergencies stated that a correlation problem or shutdowns, incitsfing those along the appropriate access exists between these two or exit routes, are provided from 3 different tighting Item 2: Ittisination tevets for att areas are doctments.
circuits. (a) koreal, (b) Stan@y, and (c) Emergency DC given in Tabte 9.5-1.
These are considered and/or self-conta'ref bettery fixtures.
1001 levels; therefore, the 50% tevels are half
- 2. Resolved.
those given on the table.
In order ta complete our review of tighting systems,
- 3. Resolved.
additional ieformation is required for the following items.
Item 3: Att areas meet criteria for adequate
- 4. Resolved.
- . Criteria for what constitutes an adequate tevel of Lighting.
LightDig for vcrious areas of the plant and for the various
- 5. Resolved.
nndes of plant operation.
Item 4: Section 9.5.3.2(1) identifies normat
- 6. Resolved.
- 2. Clarificatien of the level of lighting provided by 100 lighting as non-essential. Therefore, the and 30 percent of normai tighting.
source of power for normat lighting is the
of a reference to 8.3.1.3 which
- 3. Identification with jtast881 cation for specific plant needs to be put in 9.5.3.1.1(T) areas and modes of plant operation ttut do not meet criteria Ipage 9.5-3.2).
f or what constitutes ad quste lighting.
Item 5: Section 9.5.3.3 indicates no periodic testing is regaired for normat lighting.
- 8. Resolved pending clarification
- 4. Source of power for normat tighting.
In 9.5.3.2.2 that " essential" meane "Ctess 1E".
- 5. Frequency of insoection 80e normal lighting.
Item 6: Section 9.5.3.1.1(4)(r) indicates two gewer buses shall supply lighting to staircases
- 9. Section 9.5.3.1.1(4)(r) (see
- 6. Plant areas where 50% tighting shall be secured with one and passages in main buildings. The additional item 6) indicates two power buses stan @ y 1ighting power suppty.
bus atiows these ereas to be tesporerty ptsced s4gipty 1ighting to stsireases and on 50% tighting (i.e., one power supply) white passages in main buildings. GE
- 7. Method of distinguishing between normat, stan @y, and the other is asider inspection or maintenance, needs to determine if this means Emergency DC circuits to assure that they wilt be routed there are two redundant divisions separately, within these areas. If so, this Item 7: Wiring / cables are separated and color use of multiple divisions within
- 8. Source of power for stan @y llE*tting.
coded in accoedance with criteria dettneated in a coranon area should be included subsections 9.5.3.1.1(7) wxt (8), respectively; in the exceptional cases for the P Separation between the two stan@y power source circuits.
and in 8.3.1.3.
3-hour fire barrier separation
Page No.
43 09/27/91
.DO CHSISSUE
+
. REPORT FORM CLOSPLN8 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN CE RESPONSE STATUS / CLOSUaE PLAN anatyred in 94.5.
In either
- 10. Levet of lighting with 100 percent and 50 percent of case, 9.5.3.1.1(4)(r) should be stan&y tighting for varicus areas.
Iten 8: The second paragraph of section clarified.
9.5.3.2.2 indicates that starrty (essentiet)
- 11. Seismic design 5f stan&y tighting.
Lighting is provided by essential power buses.
- 10. Resolved
- 12. Comptience of st- *y lighting with Class 1E ci. cult
- 11. Assure bulbs / fixtures are requirements.
Item 9: Table 9.5-3 shows areas unich re<pire seiwicetty qmtifiable. If not, acre than one division of stan&y tighting.
the circuits must be justified by
- 13. The redtridaricy of the emeriterry DC lighting circuits.
These divisions are separated in accordarme catting them associsted, or by with same criteria for Class 1E divisions in providing a faltere analysis for
- 14. The levet et i'lumcation of emergency levnting.
general (Section 8.3.1.4.2).
the effect of the ren-seismic components on the Class 1E power
- 15. Periodic inspection end testire of lighting.
system.
Item 10: It tusination levels for att are== are
- 16. Justification for not havine self contained battery given in Tabte 9.5-1.
These are conaidered
- 12. Resolved based on tuiping fixtures seismicatty qualified.
1007. levets; therefore, 50% tevels are htf this with Iten 11.
tSose given in the table. Areas specificatty 1?. The ittumination teve.s with justification of the self clesignated for stan*y lighting are identified
- 13. Resolved.
2 contained battery fixtures.
In Table 9.5-3.
- 14. Resolved.
- 18. Justification for having self contained battery fixture lighting turn off with restoration of power versus itee 11: The third paragraph of section
- 15. Add interface in 9.5.13 restoration of adequate tiott.
9.5.3.2.2 ird'este f that stan @y tighting was (i.e., 9.5.13.13 If available) to "in empliance wit 1 the stardards"; however, reference 9.5.3.3 and assure
- 19. Justification for not ha.ing any seismically cpatified this has been modi'ied to clearly state testing freque cy is in place for tighting.
conptience with
- ess 1E standards. Class 1r emergency tighting.
qualification ucit&s Seismic Catet.ory I.
- 16. Resolved.
Iten 12: (See item it)
- 17. Add justif fration for tight levels given in Tabte 9.5-4 The justification will be besed on item 13: The DC energency lighting is assurart; that the battery packs
r e
P'ge No.
44 I
09/27/91
.D0 CH81SSUE'-
+
. REPORT FORM CLOSI.ad TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER t
C2JMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS'/ CLOSURE PLAN
~are in' ended for emit / egress.
redundset to the AC stan@y lighting,' eAlch is' t
red mdent to the norset AC Lighting. DC only, not for teelt perforsunce.
emergen'cy lighting is not multi-divisional This justification will be ached '-
within a given area, but is of the same to the SSAR.
division as the area (i.e., designated fire -
- [
txx.ndary) it serves, as indicated in Table
- 18. Resotwed based on the
' i 9.5-4.
asstaption that battery packs are charged and/or switched by the
.[
same source (s) as the room e
I+en 14: The minisun itttmination tewels for lighting. This must be confirmed D emergency tighthe are given in Table 9.5-4.
and clarified in the SSAR.
I f
- 19. Resotwd.
Iteen 15: ; inspection arvi testing requirements are identified in Section 9.5.3.3.
The l
frequency of testing is dependent on the
-l
}
operating and.maintes ance procedJres of the utility applicant.
i Item 16: The question is erroneous.
Self-contained battery fints es are seismic
..y qualified as stated in the test paragraph of section 9.5.3.2.4.
I Item 17: The self-contained txsttery fixtures era required to meet the ittreifetion. Levels
-l given in Table 9.5-4.
I i
5 Item 18: As indicated in'stesections 9.5.3.1.1(4)(f)&(e), AC essentiat tighting has-no on/off switches; therefore, restoration of e
Poge No.
45 09/27/91
.00 CH81SSLT
+
. REPORT FO9M CLOSPLES TO PRINT
'I i
DSER CONCERNS / RESPONSES / STATUS FOR CHAPTE:4 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE PLAN WUMBER DSER SECTION NRC CONCERN AC essential power to an area would assure lighting circuits are energized. The voltage l
necessary to activate to switching relay of the battery fixture would also be sufficiert to 4
previde oriequate light to the area.
Iter 19: The question is erroneous. The staW 8.ighting, the DC emergency tighting, and the self-contained battery fixtures are att seissicatty qualified as indicated in sections 9.5.3.2.2 (see Item 11), 9.5.3.2.3, and 9.5.3.2.A, respectively.
The design control for the ASWR is based on Reso;wed.
29.000 8.3.6.1 S.3.6 ')ESIGN CONTROL MEDO-11209-04a, the " Green sooka, Rev. 7.
This doctment has been aproved by the WRC, and is 8.3.6.1 Control of the Design Process referenced in SSAR Section 17.1.3.
Recently, there have been a rumbe* of problems identified with the electrical system design at rmJctear po cr plants.
Although Ohe majority of these problems arose as a result of modifications performed af ter plant licensing some were (ard att could have been) the result of poor originat design.
Generic letter 88-15 addresses a rumber of these problees that have occurred primarity as a result of inadequate control over the design process. These problems have occurred in areas of electrical system design which have historically weit established and comprehensivs design criteria and guidelines available for the design engineer such as circuit b,eaker coordination and fault current interrtption capability. The staff does not normatty tridertake a detailed review of these areas. The staff instead relies on the designers proper exercise of the well established design criteria and guidelines. To ensure that
1 I
Page No.
46 09/27/91
.DC CM81$9JE
+
AEPORT faitM CLOSPLk8 TO PRINT DSER 00NCf phS/RESPONSESISTATL4 F0p. CitAPTER 8 ELECTRIC POWtt t
l S1*.TUS / CLOSURE PLAN CE RESPr % E OMBER 05Eit SECTIOW NRC CONCERN l
the criteria and ge~delines.re followed controt is required. The control being isplemented for thw ABWR electrical design ard the recpired control for any subsequent endifications thereto should be described in the ASWE $$AR.
Ei(.t of the fif teen issues identifying This shall remain open pending
~0.000 8.3.6.2 3.3.6.2 control of the 0* sign sases t
kronsistencies in this ctraf t SER were the ERM review in SER stage. Some the bases for the design d6 scribed and presented in the ABWR result cf design changes in %ich areas inconsistencies may en*.t until SSAR is, for the most part, used as the basis by which the diming the same topic were not sti upasted the fuit ERM review.
KRC issues a plant opersting licerse. Based on, review of at the same time. (See responses for draft SER l
the bases presented in Chapter 8 and other relatcd chapters, sections 8.3.1, C.L2.1, 8 3.2.3, 8.3.2.4, runerou6 inconsistencias haie been identified. These 8.3.3.6, 8.3.6.2, 0.3..,
and 8.3.8.1)
These in other sectiers of this have been couected in association with these inconsistencies are identiflor d
safety evaluation rerort. Given these inconsistencies, it responses, as indicated t roughout this subci tt et. However, a format engineering appears that the process fJr controllinP the design bases r;eing pres-nted in the ASWR *.SAR me, be deficient. The review end ugxie*- will occur following receipt process f or controtting the desion bases should be clarified of the SER for Chapte 8.
The formal review has baen awaiting that time, so that resolution in the ASWR SSAR.
to SER issues can be incorporated along with
' Jeneral update of the chapter. This is
,lstent with our schedsting program for the LWR /SSAR doctrent control.
- ne remaining seven issues were, in fact, erroneous interpreta.,ons of the information reviewed. We have also identified these areas within this submittat. (See responses foe draft SER sections 8.2, 8.3.2.7, 8.3.3.4, 8.3.3.7, 8.3.4.2, 8.3.8.3, and 8.3.8.5.)
The met is requested to reconsider this question in the tight of the respan es and text g dates associated with this sutzni*tst
Page No.
47 09/27/91
.00 CH8 ISSUE
. REPORT FORM CLOSPLkS Tu PRINT r
~
DSER CONCERNS / RESP 0kSES/ STATUS FOR CKiteiR 8 ELECCIC POUE2 NtMBER DSER SECTION NRC CONCERN C RESPONSE STATUS / CLOSURE s'LAN 31.000 8.3.7 8.3.7 TESTING stec 1: $ection F.3.1.1.5.3 has tAen endified
- 1. Resolvad wi+ the additim to specificatsy state confort. ante with
"...any c6
- of iAlch can ety Section 8.3.1.1.5.3, Testing, indicates that t*>e desian of Regutstory Guid,1.118 md IEEE 333 (see shut ocuri the ptar t d Class 1E equipment provides for periodically testing the attac3wd). The spesif3 provietor for testing chain of system elements f rom sensing devices through drivet with an ackf alonet a* tosance for single talture
- 2. There is a need L %ce 6.t ru equipnent to assure that Ctess 1E equipment is functionir=w is addressed in '>*ction St4) of IEEE 338.
- p. je red me ntena~e +eiit tw in accordance with design requirements. This section also addres",ed. Tr.ts shCJLC be a Tech inplies that the requirements of the single failure Spec issue.
criterion described in IEEE Standard 379 are met with items 2-4: This information is coctained 'n respect to testing of Class 1E equipment. The steff the Technical pec9 catice.s, Chapter 16.
3 Resotwed.
interprets this section to mean that one complete electrical system division may be deenergized and taken out of service
- 4. A etwed.
for maintenance erus/or repair during any mode of plant item 5: There.re no div mional cross operation and still have the remaining electrical systens in connections recpaired for testiN paposes in
- 5. Resolvea.
conpliance with the single failure criterion. The staff the ABWR Stamford Plant Des!yn.
concludes that this design provision for testability of
- 6. Reso*Ved.
electrical systems es interpreted meets the sufficient testability seqJireJent af Criterion 17 ano is acceptable.
Item 6: The apropriate version s for att 2EEE
- 7. Electricat eyJipper t such es in order to confirm and clarify this interpretation in the standards are gi<en in Table 1.8 21.
main geneator breaker. stone et AeVR $$AR and address other related issues, additional battery syste=ms, etc., weee not information is re4Jired for the follcwing items.
Included in the non-tes:able list item 7: Certsin components cannot be futty in the resprese to 420.120. GE
- 1. Explicit statement for testCbility during normal plant tested during reactor operation without needs to review the one-t"ne operation while meeting single failure requirements with degrading plant operability or safety. These diagram on the basis of GDC 15, remaining systems for any design basis event.
were specificatty identified in response and determire if additio-st 420.120.
etectricaI ctoponents shoutd be
- 2. Proposed attowed outsge tines for one division to be out added to the 1ist of equipment of service to perform preptanned and tsiptamed maintenance.
not testable daring reactor Item 8: We cannot determine any operation.
- 3. Frequency for periodicatty testing each system etenent to inconsistencies between these two sections. If as*ure its availability to mitleate design basis events.
the st4 posed inconsistencies are related to the
- 8. Resolved.
statements involving applicability, these have
- 4. Basis for establishment of test frequency for each system been regnoved in association with Item 3 of DSER
- 9. Resolved.
Page No.
48
. 09/27/91
.D0 CMSISSUE
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. REPORT FORM CLOSPLNS TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CNAPTER 8 ELECTRIC POWER dJMBER DSER SECTION hRC CONCERN CE RESPONSE STATUS / CLOSuaE PLAN element.
issue 8.0.
Otherwise, the NRC needs to specifically identify the sumosed
- 10. Resol ad based on removel of
- 5. Identification (with justification for their use) of any inconsistency.
the *30 s esnd" capability divisicnal cross comection which must be > sed to acet the statement in 8.3.1.1.8.2(4) [Page above design provision for testability.
8.3-61.
The paragraph now reads:
Items 9, 10 and 12: This information is "Esch diesel generator is capable
- 6. Clarification of the version of IEEE Standard 379 being contained in the Technical Specifications, of reachirg; futt speed and referenced in section 8.3.1.1.5.3.
Chapter 16.
voltcge within 20 seconds after rece?ving a signal to start, and
- 7. Identification with justification for ar'y areas of capable of being fuity loaded non-compliance with the above design provision for Item 11: The testing and calibration of the within the next 65 seconds, as testability.
diesel generator overcurrent eetay is based shown in Table 8.3-4."
primarity on the retay enrvn.:turer's
- 8. Inconsistency between section 8.3.1.1.5.3 and 3.3.1.2.2 recommendations; and also on the
- 11. Resolved.
with respect to aceting the single f ailure criterion while utility / applicant's surveittance test testing one division of the CVCF power stpply system.
procedJres. This level of detait is beyond the
- 12. Resolved.
Licensing basis for the ABWR Standard Plant.
- 9. Periodic testing provisions to assure the capability of
- 13. Resolved.
the dieset generator to accept loads in any toading order (reference: 435.18).
Item 13: The cessaiteents to meet the i4. new iten added at 9/13-16/91 requirements of Regulatory Guide 1.47 are given meetings.
- 10. Periodic testing to demonstrate the dieset generator's in $sAR sections 8.3.1.2.1(2)(d)*(3)(e), and a capability of being started in 13 seconds and futty toaded listing of arvar.::lations associated with this
- 15. new item added at 9/13-16/91 within 30 seconds.
requirement is given in section 8.3.1.1.8.5.
meetings.
- 11. Testing and calibration of the dieset generator over current relay.
- 12. Testing and/or analysis to be perforwd periodicatty to demonstrate the capability of the dieset generator to supply the actual futt design basis toad current for each sequenced Ioed atep.
- 13. Interf ace requirements for conpliance with Regulatory
Page No.
49 09/27/91
.00 CN81SSUE :
+
. REPORT FORM CLOSPLN8 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POWER L
NUMBER OSER SECTION WRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN i
]
Guide 1.47, Sypassed and inoperable Status Indication for Nuclear Power Plant Safety Systems and 81P PS8-2, Criteria for Alarms rnd Indications Associated with Dieset-Generator
'l Unit gypassed and Inoperable Status.
E e
- 14. (Added to DSLR per 9/16-18/91 meetlags) Confirmation -
that the testa'iitity inherent in the design of protection systems is not so turdensome operationally that required
{
testing at intervels of 1, 2, or 3 months cannot be inclu$ed j
in the Technical Specifications if deemed necessary. The systems addressed should.inc'..sse but not be timited to the reactor protection system and the engineered safety features actuation system. Identify exceptions.
- 15. (Added to DSER per f/16-18/91 meetings) Testing to demonstrate the capability of the diesel generCtor to automaticatty revert to the emergency response mode idiite in the test mode if a design basis accident or loss of offsite power event were to occur.
33.000 8.3.5.1 8.3.8 CAPACITY AND CAPASIllIY Section 1.2.1.2.5.2 has been nodified to agree Resolved.
with section 8.3.1.2.1, which is correct (see 8.3.8.1 Shutdown capabitity of Each Load Groie attached mark-up).
Section 8.3.1.2.1 states that the stan@y power system
-i rededency i. cased on the capability of any one of the four '
i divisf orc (one of three load groups) to provide the miniensi safety f m ettons necessary to shut down the unit from the
[
control room in case of an accident and maintain it in the safe shutdows condition. However, in apparent contrediction section 1.2.1.2.5.2 states that the Class 1E power systema j
are designed with three (3) divisions with any two divisions a
being adequate to safety place the unit in the hot shut dews condition.' This agparent contradiction should be clarified l
i
Page No.
50.
- t 09/27/91 i
.D0 CM8 ISSUE.-
+.
l
. REPORT FORM CLOSPLM8 TO PRINT DSER CouCERWS/ RESPONSES / STATUS FOR CMAPTER 8 ELECTRIC POE R l
l i'
<NLMBER ~DSER SECTION NRC CONCERN.
. GE RESPouSE
. STATUS / Closure PLAN
- t
..-(
..f in the ASWR $$AR.
f l
33.000 8.3.8.2 '
8.3.8.2 man-Safety DC Power Systems Section 1.2.2.5.1.6 has been amended as sho m the mRC stated DC-to-DC l
l In the attacf ed mark-up. The 125 VDC non-Ctess ' converters were not acceptable 'es.
I Section 1.2.2.5.1.6 Indicates that the AeWR desig-,ctudes 1E system is briefly discussed neer the end of isolation devices on the basis of.
}
[
a unit atmitiary de power system that stepties p -- to de section 8.1.2.1; however, a new section capacity & independence concerns 1
{
toads that are non-safety reteted. However, sectum 8.3.2, 8.3.2.1.4 has been added which further per GDC 17 The/ mere concerned which is stepose to address de power systems incladed in the describes this system.
thst' grounds, sneek circuits,.
f
}
A8WR, omits description and analysis of the unit munitiary etc., from the r.an-1E side could '
5f i
de power system. This system and the extent it will be used proposete to the IE in,es.' Also,'
,{
to steply de control power to systems that are important to they questioned the additi> net '
f safety (such as of fsite power circuits) should be defined in toeds placed on the Class 1E
[
the AeWR SSAR.
betteries to seeply the non-1E.
l toeds..GE shalt review the
{
desisn and offer defense or
{
atternetIves..
i f
34.000 8.3.8.3 8.3.8.3 Class 1E 125 volt DC Battery Capacity Section 5.4.6.1 has been modified, per attached GE to clarify erut justify either f
{
merk-w, to be consistent with the eight-hour 8-he r or 2-hour coping capacity
[
Section 8.3.2.1.3.2 indicates that each of the four Ctess 1E coping capacity stated in secticn for station blackout. (Either is f
123 volt betteries have sufficient stored energy to operate 19E.2.1.2.2.2.
ok, so tog as it is justified.)
j connected essentiat tceds continuousty for at ieost two Aiso, a iood profite 4 needed I
hours without recharging. Durig loss of ac power, section The two-hour avaitsbility time stated in (see IEEE 485).
)
5.4.6.1 indicates that the bettery capacity shoutd attou section 8.3.2.1.3.2 is not reatty irtonsistent,
~
l over four hours of operation of the RCIC system. (tem 3 of in that this assimes continuously futty toeded l
section'19E.2.1.2.2.2 indicates that the de betteries mitt conditions. The eight-hour time for station
[
]
be sized to be capable of operating the RCIC system for e -
blackout conditions is eveitable because RCIC minisum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> assuming toed shedding and use of att toeds are intermittents and other toads can be
- 1 4
four Ctess 1E betteries. Item 2a of section 19E.2.1.2.2.2 shed or shifted to other divisions (i.e., SRV
- t i
)
indicates that Division 1 bettery by itself has suf 85cient functions). This is emplained in responses
[
}
capacity to operate the RCIC system for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. These 435.38(c) and 435.2 (SSAR section 20.3, tab
}
inconsistencies should be clarified and the design basis RAI-8); and in section 19E.2.1.2.2.2.
This i
toed profita for eerh bettery should be explicitly stated in clarification hos been added to 8.3.2.1.3.2 per
- the Asun SSAR.
the attached merk-w.
k s
m.
Page No.
51 09/27/91
.00 CH8 ISSUE
+
. REPORT FORM CLOSPLNS f0 PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER WUMBER DSER SECTION NRC CONCERN CE RESPONSE STATUS / CLOSURE PLAN An estimated load demand profile for the 125 VDC batteries was provided in response 435.38 (SSAR page 20.3-253.21). As emptained in that response, this information could change as the design is specified for unique application.
35.000 8.3.8.4 8.3.8.4 Use of Silicon Diode in the DC System Item 1: The effects on reliability of the DC The following NRC concerns system due to the SID heve been accotsited for (expressed during a telephone Figure 8.3-7 and response to question 435.51 indicates that in the PRA.
The contribution to probabilistic conference) are based on the use a silicon diode (SID) which has a voltage drop of 10 votts f ailure caused by diode SID being open is of the SID in the Japanese has been installed in series with the output of the battery specificatty included in the 125 Vdc electric designed power stopty. If and battery charger. During wnsel operation (i.e. battery power fault tree (Figure 190.6-1Da). The adequate reliability information charger output voltage is setJ d: 140 volts for equatire results of the PRA study confirm the is not available from Japan on charge) the switch in paratlet W.th the silicon diode witt reliability of the DC system is adequate.
the use of the SID, the circuits be open so that the voltage from the battery charger to the and egaipment are designed for DC bus will remain at 130 volts (140 volts minus the 10 volt higher voltage tevets such that drop across the silicone diode) dile 140 volts is stwtied item 2: This information was provided in the SID can be removed. This to the battery for equatire charge. The staff feels that response 435.38 (SSAR page 20.3-253.21).
would resolve att items below, the proposed design has merit; however, suf ficient but woutJ regJire a DAL.
descriptive information and analysis to reach a conclusion on acceptability for att modes of plant operatiers has not item 3: The system is designed such that the
- 1. The NRC stated "The overall been presented in the ABWR SSAR. To resolve staf f concerns, equalizing charge mode ($1D conducting) reliability of the DC system with additional information is required for the fottowing iteam.
automaticatty transfers to the float charge and without the SID needs to be mode (SID bypassed) whenever either of the quantified; and if there is a
- 1. Reliability of the proposed DC system. The addition of following conditions exist: 1) A fauts occurs decrease in the rettability, the the silicon diode in the DC system circuit adds an in the SID, or 2) Irput AC power is lost daring basis and justification for its additional level of ulreliability to the system dite at the equalizing. In aMition, the SID is designed acceptability needs to be same time may improve overett DC system reliability.
to continuously carry the maxisua current the ad eessed. The diode SID being chargers can supply to the 125 Vdc bus.
open is only one f ailure mode.
- 2. Capacity and capability of the DC system to supply design other failures or co e instions of basis loads during loss of offsite power events.
fattures need to be a Mressed."
item 4: The duration of egaatizing chargina is
- 3. Design provisions to assure the battery will never have short, and the f requency of amtication sejr
- 2. The NRC stated "The capacity
Page No.
52 09/27/91
.DO CH81SSUE
+
. REPORT FORM CLOSPLN5 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER OMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLM to surpty its design basis loads with the silicon diode vary from weekly to several months depending on and capability of the battery and connected in series with the battery and DC bus.
the battery manuf acturer's recciamendations ard the charger to stopty design the specific utility's maintenance procedures.
basis loads with the diode in the
- 4. Monitoring for the switch instatted in parallel with the In any case, the chargers will be in the float circuit needs to be addressed."
diade.
charge code (parat tet contact closed) the great majority of the tise. During those short
- 3. The aaC wants "The description periods when the contact is open (equalizing and details of the proposed charge mode), the automatic transfer circuitry for performing the capabilities provide protection (as explained automatic transfer. Also, the in item 3). C mfirmation of the switch's rettability of the transfer needs position and proper fmetion may be made at any to be included in item 1 above.*
time, by ccuparing voltage readings (pstream if the SID is to remain in the and downstream of the SID utilizing the circuit, GE needs to get this voltmeter provided with the power stopty Information from Japan.
(Figure 8.3-7).
- 4. Resolved.
36.000 8.3.8.5 8.3.8.5 Class 1E AC Stancby Power System item 1: The dieset generator (D/G) capebility
- 1. Resolved.
of reaching futt s Med and voltage has changed As a result of our review of the standby power system f rom 13 seconds to 20 seconds in order to be
- 2. Resolved.
proposed in the A8WR SSAR, the following areas of concern consistent with EPRI/ALWR recpJirements. The
- 3. GE needs to clarify 8.3.4.2 to have been identified.
changes are shom in attached markups for state D/G design details which sections 8.3.1.1.8.2(4), 8.3.4.2, and Table are to be setied by others.
- 1. Inconsistency between section 8.3.1.1 8.2 and 8.3.1.1 8.3 8.3-4
[
as to the de icn capability of the diesel generator to start
- 4. Apparently, the prtunised and attain rated voltage and frequency.
modification to 8.3.1.1.5.2(5)
Item 2: As indicated in section was inadvertently left orJt.
- 2. The capability of the dieset generator to supply toads 8.3.1.1.8.2(2), the D/G is designed such that needs to ads the missing asstraing loss of of f site, toads being either stoptied by or its voltage drop will rwt esceed 25% (75% bus infortsation.
being sequenced on the diesel generator, and bus vottage voltage), even tnder sequence loading drops below 70 percent.
conditions. Therefore, white the D/G is typtying power to the bus, the bus voltage
- 3. Clarification of the dieset generator design details will not drop below 70% for a sustained period which are to be s e tied by others (reference question tsitess the D/G itself fails or there is a fault
Page No.
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REPORT FORM CLOSPLN8 TO PRINT DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE PLAN CMBER DSER SECTION NRC CONCERN 435.21(b)) and the criter8e the design must meet (i.e.
condition. Under such conditions, the of fending division toads are tripped (assuming interf ace requiressa-%).
to LOCA), and the safety isnctions will be
- 4. Clarification of the contirasous ard overload ratings of assuned by the redtsidant divisions. The three the diesel generator defined in section 8.3.1.1.8.2.
Independent D/Gs, and their associated divisions, provide more than adeqJate redundancy to mitigate the suggested single-falture scenario.
Item 3: The interface ti pairement in stmort of response 435.21(b) was added as a N tion 8.3.4.2 the same time as the response.
However, the reference to that stksection was inadvertently mitted in response 435.21(bs.
Therefore, the ref erence has been acMed per the attache <f markte of page 20.3-253.13.
Item 4: This infors:stion was provided in response 435.21(a), but in adfition, has em been added as stbsection 8.3.1.1.8.2(5) tree attached markup).
Item 1: Any one of the sis AC power sources
- 1. The NRC stated "The 6/4/91 37.000 8.3.9 8.3.9 STATION SLACKOUT (i.e., the two off-site lines, three diesel draft did not pr9 vide a response The ABWR coping analysis for Station Stackout is presented generators, and one coreustion turbine to this concern."
in stction 19E.2.1.2.2.
Also, table 19E.2-2 presents design generator) has suf ficient capacity to bring the basis values for various plant parameters that will not be plant tr - ife shutdown. As stated in
- 2. Resolved.
exceeded at the end of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping duration for a 8.3.1.2.1, any one of the three AC electrical Station Stackout event. Based on a review of this coping divisions car
- provide the etnisua safety
- 3. Resolved.
analysis and design information presented in other sections functions necessary to shut down the unit froar of the ASWR $$AR, the staff has identified the following the control room ard maintain it in the safe
- 4. The WRC stated: " Accident environments anatyred in Section shutdown condition.
areas of concern.
Page No.
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. REPORT FORet CLOSPLN8 TO PRINT DSER CONCERNS /RESPOKSES/ STATUS FOR CHAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / 405URE PLAN 3.11 don't correlate to
- 1. Analysis results demonstrating safe plant shutdown can be The diesel generators (DGs) are designed with environments during station accomplished starting with reestablishment of AC power to bypass valves for.the DC solenoids such that blackout. Additional any one of the three AC divisions from either offsite, they can be started manually without DC power clarification is needed." Also, diesel generators, or cad = tion turbine generator at the (i.e., asstaring the DC batteries are discharged "Where is the analysis which end of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of coping.
following 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of coping). Also, the demonstrates that the control combustinn turt>ine generator is started by a room temperatures and RCIC room
- 2. Justification for the proposed design thich provides an saatter self-contained dieset with its own temperatures will not exceed alternate AC surpty (combustion turbine generator) but battery.
egJipment design temperatures for-dictates that its first priority use be to stgpty AC power at least eight hours.*
to Non-Class 1E plant investment protection toads versus Ctess 1E toads needed to assure safe plant shutdown.
Item 2: The ccabustion turbine generator (CTG)
- 5. Resolved.
is inchded in the ABWR Starderd Plant as a
- 3. The capacity and capabitity of the combustion turbine result of EPRl/ALWR regJirements (ALWR tJtility
- 6. Resolved, generator to stypty minimum safe shutdown toads and minlaun Requirements Document, Revision 1, Vol II, required plant investment prctection toads at the same time.
Chapter 11, Section 5.2.4).
Its fwn tion is
- 7. The mRC stated: -Section consistent with those requirements, namely: 1) 9.5.11 does not sadress position
- 4. Design and qualification of egJipment for the The unit is non-Class 1E, and is provided to 1.
It is clear from 9.5.11 that environments espected daring and following the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping feed perminant non-safety toads dJring LOPP the CTG is not normatty connected time anatyred for station blackout events.
events, 2) It is avaltable to back sp twe to the onsite power system but Class 1E DGs, should they fait or not be the entent the CTG is connected
- 5. Clarification of how Division 2, 3, and 4 are shutdown avaltable, and 3) It is capable of coping with to the offsite system is not dJring a station blackout situation.
a station blackout.
addressed. Positions 2, 3, 4, and 5 are also not addressed in
- 6. Clarification of the source of instrument power from DC The CTG assumes non-safety investment Section 9.9.11.*
or constant vo1tage constant f requency sources daring protecticn tcads outomat!caLty, but the station btackout situations.
connection to each Ctass-1E bus is manual.
- 8. Apterentty, this test item was This is justified because: 1) N site either eissed in the original
- 7. Estent to 6 ditch the combustion turbine generator complies emergency power is provided by three Class-1E DSER, or was added as a result of with position 3.3.5 of Regulatory Guide 1.155, Station DGs and no credit is taken for safe shutdown the teleshone conference. At any Blackout.
utilizing the CTG. 2) Although the CTG can rate, GE needs to investigate and cope with the station blackout, the AIMt can provide the response.
- 8. The inconsistency between response to question 435.2 and cope with station blackout without the need for the 6/4/91 draft section o4 19E.2.1.2.2 of the $$AR with the CTG, as described in 19E.2.1.2.2.
- 3) The
I l
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. REPORT FORM CLOSPLN8 TO PRINT DSER CONCERNS /REr/0NSES/ STATUS FOR CHAPTER 8 ELECTRIC POWER GE RESPONSE STATUS / CLOSURE PLAM WLNBER DSER SECTION NRO CONCERN 1
respect to the rumber of SRVs powered from division 1.
CTG interface configuration provides independent stan @ y power for non-safety 1oads ed thus maintains better separation between safety and non-safety systews. This also prevents the Irwestment protection toads from having to be assuned by the DGs.
I In sumery, the ABWR meets att regulatory requirements without the CTG. It was added in l
accordance with the EPRf/ALWE requirements document; therefore, its function is also consistent with that document.
Item 3: The CTG is rated to prodxe approximately 20% more power than a DG (i.e., 6 MW for the CTG, compared to 6.25 MvA a 0.8 pf =
5 W for a DG). However, the CTG is not designed, nor recpired, to assume att investment protection toads in addition to a DG toad. If the need arose for the CTG to assune the Class 1E toads on a DG bus, the investment protection toads would be shed. This is atso done as a precaution to assure non-Class TE toads do not astersty affect the CTG's ability to stopty power to the Class 1E toads.
Item 4: The erwirornental ef fects on electrical equipment daring a station blackout event are expected to be tess severe than the accident environments anatyred in section 3.11.
t This is because such equipment would be in its deenergized state, ard thus would produce no
[
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56 -
09/27/91
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. REPORT FORM CLOSPLN8 TO PRINT DStL CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER NUMBER DSER SECTION NRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN internet heet rise coopered with the envirorument. Likewise, there would be no other significant heet radiators in any vicinity of the plant save the eres lusmediately surro m ding the reactor itself. Therefore, no additional analysis has been done for the station blackout envirorument,' nor is it considered necessary.
Item 5: In a station blackout event, if division I instrumentation is fmetioning property, the operator should manuesty shut down rededent divisions !!, III and IV in order to 1) reuuce heat dissipation within the control room wh N e Nv4C is lost, and.2) conserve battery energy for additional SRV capacity, or other specific purposes as needed, or indicated in 19E.2.1.2.2. Only division I is essentist to the RCIC operation and should remain fmetional at att times during this event. This is e y the division 1 bettery has significantly more capacity than the other batteries.
An interface section 5.3.4.16 has been ad$ed to assure this operator action is included in the aplicant's Emergency Operating Procedures.
(See attached mark-se.)
3 Item 6t As a generet rule, att Class 1E instrument power comes directly f a the divisional DC buses. The only exceptions are some E/O converters in the process radiation
..~.;
_.y Page No.
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M'"
. REPORT FORM CLOSPLN8 TO PRINT
. DSER CONCERNS / RESPONSES / STATUS FOR CHAPTER 8 ELECTRIC POWER '
CSIBER 'DSER SECTION HRC CONCERN GE RESPONSE STATUS / CLOSURE PLAN sanitoring systest. These rewire AC power
. provided by the DC via the CVCF power stypty,
units. m divisional CVCTs also s w ty power.
to the non-Class 1E aree radiation detectors.
item 7: Att of the five criteria of Regulatory Guide 1.155, section 3.3.5, are met or exceeded by the CYG (see $$AR section 9.5.11).
1 e
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Page No.
1 06/04/91
.00 CP8 ISSUE
. REPORT FORM QUESANS8 TO PRINT NEC DRAFT SER ISSUES & CE RESPONSES FOR ABl.T $$AR CHAPTER 8 ISSUES GE CONSIDERS RESOLVED PER THESE RESPONSES NUMBER NRC ISSUE GE RESPONSE 3.000 8.3 ONSITE POWER SYSTEMS Response 435.26 has been modified as fot tows:
8.3.1 Ca gliance with Generat Design Criteria Item (1)(b) of = action 8.3.1.2.2 irdicates that the Class 1E Constant Voltage Cons' s Frequency
- All conformance statements in the analysis sections of Chapter 8 have been j
(CVCF) power supply is in cogliance with Generat Design Criteria ('DC) 2, 4, modified to state futt compliance without the applicability caveat (see i
17, and *8 in part or in whole, as applicable. Response to question 435.26 attached).
provides clarification that there are no nonco gliances, but some portions of the GDC's are not applicable at this tevet (for exagte, the statement in GDC There are no non-conformances with the GDCs. The 'as applicable' statements 17 about two physicat ty independent circuits frcun the trans-mission were intenled only to differentiate between those portions of the GDCs we network). It is unciewr as to what parts of these CDC's you consider not interpre* M to be applicable to the plant as a whole, rather than to applicable to the CYCF power stpplies. Also it is unclear as to why two irdividual systems or conponents. However, it :s better to delete such
- iysicatty independent circuits frces the transmission network are not statements if they a e onstrued to mean any degree of non-conformance."
applicable to tie CYCF power stpplies. In order to clarify these and other related items, additional information is required foe the following issues.
With rega-d to the CVCF power stopties, they are ultimately fed from their 1.
Identification of each part of GDC 2, 4,17, and 18 which is not respective 6.9tv divisional buses (see Figures 8.3-1, 8.3-3 and 8.3-6).
Each considerett arcticable to the CYCF power sigpties and justification for each 6.9tv divisional bus is ce nectable to two offsite sources grefered and part that is considered not applicable.
alternate pet fered) and two ensite sources (EDG and CTG).
2.
Clarification as to why the CDC 17 requirement for two independent power sources is not applicable to the CVCF power su;pties.
3.
Clarification for each non applicable criteria s d in tabte 8.1-1.4.
4 { Inconsistencies within Tabte 8.1-1 and between Table 8.1-1 and section 8.1.3.1.2 as t-> applicable criter na.
5.
Identification with justification for each part of the criteria listed in section 8.1.3.1.2 that is considered not applicable to some part of the electrical system.
6.
Identificaticn with justification for each part of the design of the Instrumentation dnd ContFOt system that is considered to meet the substance and intent of (versus conotience with) IEEE 279 10 CfR 50 Appendia A,
g c.
b
=
7
.. ~
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. REPORT FORie DIKSA453 'O Pfl4T ttC DRAFT SER IS%ES & GE FESPONSES FOR A9WR SUR CMAPTEC 8 TSSUES GE EDNSth45 RESCLVED PER TMESE REsporSES GE RESPouSE OUMBER NRC ISSUE r.meret Design Criterie 3, 17, 21, 22, and WRC 4 4tatory Guides 1.75 (IEEE 384) and 1.53 (IEEE 379). (refererce: section 8.3.1.4.2.1) 7.
Clorificatio* of the systens or ces to which IEEE-279 espty (reference: item (til of sation 1.2.1.1.2).
l the second sentmce of the third persgraph in SEAR section 2.1.3.1.1.1 het 3.100 8.3.1.1 Compt f a ice arith Criteria 2 and 4 beest modified te incerperste the erC's recomev*d design besis stateaumt par the fottoering:
Chapter 8 et the ASWR SSAR contains the intlowirw statements in relation to the compliance of ~tectricot system deeig : to the reg.siressents of criterien 2,teesign Beses tw Protecticrt Agai:ist Weturet Phenomer.a, and criterion 4,
- RedJndant ports of the system are physiestly seperated and le a a to the r
ertent that in any desigri besis event wirk any resulting loss of emaipment. and Envirormiental ord Missiles Design Bases, of Aperdia A to 10 Cf t Port 50. It single feiture, sufficient receitving safety systemis will be evellebte ta speers that each statement can be iricorrectly interpreted to mean that ef f ect a safe pient shut ^w ter et t ot toasebte modes of plant eperation."
protection rieed only be provided for two of the three (or four) 1.hM safety retered elects icet divisiais.
Also, eeny of the pt *egraphs omted have been sedified or deleted because is not et tensad "In some instances spetiet seperation is prended such that no sirgte spottet seperatien ty ^ stance alone (i.e., neithout berriers).
arees within the plant con *sining safety-related event may disable more than ene of the redJn& int divisions or prevent safe without justificatier shutdown of tha plant. Electricot -gsinent and wiring for the Ctess 1E erssipnent or cables are. - ersted by three-hour fire rated.serriers eless systeia eMch ere segreested into taporate divisions are seperated se that rio onetyred eno justified in ga.$.
design basis event 's capable of disabting any ESF totst fwction." (ref:
sectie 4 3.1.1.5.1) trwiant parts of the system are physicetty separated to the entent that a pngie credible event...cennot cause loss cf power to red.rdant toed groups." fref: sect io i 8.'. 3.1.1.1)
- Jhere spatist separation carviot be maintained in haterdous erees (e.g ptentist missite eress), physical isoletion tetween electricot A
l aquig mt of dif f erent divisions is achieved by use of e 6-irch minimm thide us reinforced concrete k n ier * (ref: sect ier. 8.3.1.4.1)
"Claso 1E electric cat es=mt and wiring is segregated irto seperate mvisions so that rue single credible event is capable o* disabling enmrft
e
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.06/04/91
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. REPORT fOnet GUESmeS8 TO PRIET NRC DRAFT SER ISSUES & JE REspoeSES FOR Agut SSAR CNAPTER 8 ISSUES GE ConstDERS RESOLVED PER TMSE RESPONSES l-FrGER NRC !$5UE GE RESPC-T2 i
ewipment to hinder reactor shutdows, removst of decoy heat from the core, or
~
isolation of the contalrument in the event of an accident." (ref: section 8.3.1.4.1.1)
- E w ipment errengement and/or protecti e berriers are provided such that no tocetty generated force or missite crn de-troy any redundant RPS, I-
{.
berriers are pro =%d to ensuee thet such disturbances do not effect tsoth i'
NPCF and RCIC systems." (ref:'section 8.3.1.4.1.1) i i.
j
- Contelrument penetrations will be so erranged thet no desiyt basis fI eventcon disable cabling in mo** then one division." (ref: section 8.3.1.4.2.3.2.(F)
- The proe tien system and ESF control tosic, and j
instrument penets/ rocks sW be laceted in a safety ctess structis e in eAich there are no poter,tiet er 4es of missites or pipe breeks thet could j
jeopardize redJndent cdr wts. and recemeys.* (reh section 8.3.1.4.2.2.3 )
i "In any comporte nt containfng an operatirw crane...there vuust be a minisue horizontet sep etion of 20 feet or e 6 inch thick eeinforced concrete wett between rays 'containing cables from dif f ert:.4 ?_vist ns.*
(ref: section 8.3.1.4.
2.2(3))
airt rooms or cowteents beving heevy rotating ameninery...or '3 rooms containing high-pressure feed water piping or high pressure ster >>
Lines...winiana seperation of 20 feet or a 6-inch thick *einforced concrete well is required between t.roys containing cables of different divisions."
(ref: section 8.3.1.4.2.2.2(1))
8esed on a review of the above statements, it appears that barriers between redundant safety divisiens (versus berriers from the ef fects af a credible event such as e locatty generated missile) is the design 4:wst: W electrical systems meeting the protection requirements of.criterie 2 are s of Amendia A to to CTR Part 50. The design basis for protection of safety eystems is not clear. It is et clear that fottowing any design basis event veth any resulting loss of equipment and single f atture, sufficient reunining safety
+
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Page so.
4 06/04/91 l
.D0 CM8tSSUE
. REPORT FORet QtKSaeS8 TO PR 1T j
mRC DRAST SER ISSUES & GE RESP 0 ESES f0R AF*t SSAR Cha*TER 8 f
ISSUES GE Caes!DERS RESOLVED PER TMESE RESP 0 ESES
?
NLMBElt " NRC ISSUE GE BESP0mSE L
systeis sitt be eweitable to effect e oefe plant shutdonai for att attomable nodes of plant operation.
h 4.000 8.3.2 PHYSICAL INDEPEteteCE Iteen 1 & 2: The test of sections 8.3.1.4.2.3.1(6)4(7) and the response to
[
question 435.35 (section 20.3) have teen modified in - he with the
?
?
8.3.2.1 Ca duits To open Treys etteched.
[
i section 8.3.1.4.2.3.1 eru:1 rescanse to geestion 435.35 indicate thet physicat i
seperation, for conthsits centsiains scree soleno*d gree circuit wiring, will Item 3: The SRP requires that Reguletory Guide 1.75 te eddressed, yet thet be by a minisase seperation distence of one inch from either metet enclosed guide specifically endorses IEEE 386-1974 We assumed the ouemmtettone of receweys or non-en.tosed receweys. The one inch of seperation between e the guide ucutd em4y essetty to IEEE 384-1981 es mett, though some section corduit and enclosed receweys complies with Regulatory Guide 1.75 separation rmsubers witMn tee IEEE document were changed in the weer version. To guidelines and 's therefore acceptable. The one inch of seperation between a clarify the e g erent contradiction, we beve added this assumption statement to conduit and non-enclosed racemeys, however, does not comply with seg stion response 435.32 (see et'eched). IEEE 384-1961 is i&mtified es the ce rect guidelines of Regulatory Gutte 1.5.
The staff is therefore concerned that version for the Acut certification, as indicated in response 435.33 and Table the proposed one inch of seperation any not provide sufficient 4. A Ae 1.8-21 Esce SSAR pose 1.8-62 ~%=endment 12)t.
between rededent systems and/or protection to safety syst sur in accordance j
with the requirements of Criterion 17 of Appendia A to 10 Cta Part 50. To
[
resotwe this concern, additionet inforention is required for the foitowing Itee 4: As empteined in item 3 above, ed in response 435.33, IEEE 386-1961
(
items.
is the certification starderd, but is essmed to be suymer ted by Reputetary l
f Guide: 1.75. There ere no limitettons en the entent of use of this stenderd in 1.
Identification with justification for the one inch of seperatien.
the asut Stenderd Ptent Design. In f act, the 3-hour-berriers segereting i
designated fire arees/ divisions emceeds the criter.e of RG 1.75 eM IEtt 386 2.
The contradiction between response to question 435.35 (or itse 6 of se tion 8.3.1.4.2.3.1) and response to question 435.33 (or section 8.3.1.2.1) with regard to ottowebte seperation between conduit and non enctesed Itee 5: SECT-89-013 requires that.... designers of storderd plants...must reeweys. Respense 435.33 prohibits by reference to IEEE 384 iAile re=oonse dmonstrate that safe shutdown of their designs can be achieved, esstseing that 435.35 specifiestly ettows one inch of sepere* -m. (Seperetten by one inch ett equipemt in er=y one fie 3 aree has teen rendered inapproble by fire and between enclosed and non encto*ed receweys is a known eres of non-conc *tience that reentry to t%e fire eree for repairs and fer eperator actions is not l
with the guidelines of Reguletory Guide 1.75 imich is ettowed by the Asuri possible.*
l design. This soon comptience should be justifice within tfe A8WR SSAR. It l
should no. be considered as en inter *ece require =mt to be resotwed by others This reasirement nacessitated 3-hour fire barrier protectim tw prow 4 sad to es indicated in section 8.3.4.5).
the watts seperating reArmiant devisionet erees. Such terriers thus defiwd
[
the fire aree tumdories.
i Page No.
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- 06/04/91
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i
.D0 CM8tSSUE
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i I'
. REPORT FORM GUESAwS8 TO PR!ff f
WRC DsAFT SER ISSUES & CE PESPowSES 70R A8WR SSMt CnAPTER 8 ISSUES GE CONSIDERS #ESOLVED PER TMESE RESP 9mSES i
3RD9ER WRC ISSUE CE RESP 0mSE i
- 3..The contradiction between response to gaestion 435.33 and 435.32 in the i
useof IEEE Standerd 384-1969 versus 384-1974 4 Estent of use of IEEE Standerd 384-1981 in the design of ASWR.
f 5.
Requirements retsiing to seperation contained in letter SECY-89-013.
2-!'
f 5.000 S.3.2.2 conteirwent Penetrations The resporse to 435.31:a) and section 4.3.1.4.1.2(T) heve twen modified to 3'
oore specifically state the seperation criterie for the penetrations. Such Item (7) of section 8.3.1.4.1.2 indicates that electric penetration seperation criterie enceeds that of IEEE 384-1961, es empleired in the essemblies of different Ctess 1E divisions are seperated by distance, modified resoonee (see etteched).
1 seperate rooms or berriers, and/or tocation on seperate floor levels.
i Separate rooms or barriers end/or location on separete floor tevets exceeds I
e seperotion gutdetines for penetratiens and is acceptatde. Seperation by distance soy etso wet separation guldetines; however, information es to iAst constitutes the mini. w attowetde distance between penetrations has not bee-j cteerty defined. To s.. rify what constitutes minianan seperation distance,
[
{
additionet infonnetton is required for t:ee following items.
}
t i
1.
Clerification of the response te question 435.31(a) es to:
i I
1 I
^
- e. Minimum ettowebte distance between red edent penetrations.
[
- b. Mininum seperation distance between penetraticris containing non-Ctess tE l
circuits ord penetrations containing Ctess 1E or essociated Ctess 1E j
circuits.
j 2.
Miniaun ettoweble seperation distance between penetrations (containing i
j Ctess tE circuits) and other divisionet or non divisionet cables.
i l
1 6.000 8.3.2.3 Ctess 1E Ecysipment subsection 8.3.1.4.2.3.1 6) stated that ens and PC&Is Nabtes wilt not be ptoced in any encic+ure which will wwidy restrict. capability of renewing
[
j Section 8.3.1.1.5.1, N sical Seperation and independmce, states that probe comectors fe maintenance smargeses.* Placenme of cabtes within fien j
3 -
divisionat separation for Ctess 1E equipment (iAich includes ePS and o-her condsit, as stated in 9a.5.5.5, is consistent with this regstrewnt. anuever,
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. REPORT FORM QUESANS8 TO Ph?st stC DRAFT SER ISSUES & CE FESP0 ESES FOR ASWE SSAR CNAPTER 8 ISSUES GE CouS1DERS mESOLVED PER inESE RESPGsSES i
NUMBER NRC ISSUE GE RESP 0kSE ESF systems) is achieved through the use of barriers, spetist seperation, ard to swold 8sinterpretation, the stateaumt in 8.3.1.4.2.3.1t9) has been totetty enclosed receweys. This co@ination of tethods for schieving modified to state " cables will be enclosed and seperated es defifwd in seperation meets the guide-tines of section 4.3 of IEEE Starderd 384-1974 04.5.5.5.*
ard is acceptable.
Item 1: IEEE 32 % ard Regulatory Guide 1.75 have streedy been identified es Section 8.3.1.4 Indicates that berriers (used to maintain divisionet the desi p beste criterie for seperation, es indicated in the resolutions to seperation) are fire ested meere fessible. Also section 8.3.1.1.5.1 indicates previous issue., and througneut Chapter 8.
this is etso reitereted within the that receweys cepoded in concrete wells, ceiling, or floors will be used as same s*section referenced in this issue (8.3.1.4.2.2.2(4)&t533. In addition barriers to meintain divisionet seperation. The use of fire reted berriers to the sepeest 7 criterie, the plant is designed such that complete burmout and embed >d conduit meets the intent of IEEE standard 384-1974 for within a fire zone can be assumed per SECT-89-Ct3.
I separation of divisionet cables and is oecep*ebte. Section 8.3.1.4.2.2.2, however indicates en enception to the co@inetton of berriers, spetist seperation, 3rd totetty enclosed receways es the criteria for maintaining Itens 213* We have atreedy identified end justified ery emceptions to di=ieioneI seperation. In ptont erees =ith poteatiet be2ords (such as seperetion criterie in Amedie S4.5.5, end/or mithin the accroprlete sections i
high-prerture feed wete" piping or high pressure stese lines) redJndent eAere they are discussed. For esemple, the DRC ackruntedgad the esception receweys seperated ty 20 feet without berriers or being totetty enctosed is identified for the testege detection instrwe=tetion in the mein stese tuviet, ettewed to be uwed to maintain divisionet seperation. Also ites (9) of 8.3.1.4.2.2.2(1).
(See also 94.5.5.7)
It was noted these cables are ptoced I
section 8.3.1.4.2.3.1 indicates thet cables associated with the four in condsit, though they cannot be physicotty sepereted to the seame entent es r-$sident divisiens of the start to range monitoring system and the two other cables mentioned in (1), yet they do meet sepsration requireurnts of diwtmns of the red control ord infonnotion system tocatawl isider the vesset IEEE 384. Furthermore, sinuttaneous fatture of ett cab 4es in the greie was will not use berriers, spatiet seperation, or totetty enclosed receweys.
enstynd and found to be acceptable. sowever, the met did not state whether powever section 94.5.5.5 indicates that fienible metallic conduit is ettowed this is acceptabte. The enesetes referenced in the question ere not I
to be used on these cables wider the vesset. To clorify or resolve these 1 consistencies, out are port of the e,ceptions and justifications requested 8
inconsistencies and to estabitsh consistent seperation criteria, additionet by these items.
inforsetion is required for the following items.
f response to 435.35 was sedified, es emplained in the rescanse to SEs issue l
1.
Clarification of the criterie to ba used es the licensing ord/or design 2.1.
besis fe,c seperstitet between (e) redsdent divisionet receweys (or cabtes) and (b) divisionet or associated divistor st and ren-divisionet rereweys (or cables).
i 1
- 2. Identification of each esception to the licensing and/or design basis criterie foe separatiert.
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. REPORT 70R*4 QUEsass8 TO PRINT htC DRAFT SER ISSUES & GE RESPon5ES FOR A8WR $$AR CMAPTER S ISSUES GE CONSIDERS PESOLVED PER TMESE RESPONSES NUMBER NRC ISSUE GE RESPouSE t
3.
Detailed J2 sign description and enetysis justifying each exception identified.
If design besis criterie for seperation is IEEE Stande*d 384, seperation for enspple betwean open trey and totetty enclosed receweys with less then 3 feet of horizontet seperation er 5 feet of verticet reperstlen sust be addressed es pe*t of items 2 and 3 above. Response to mestion 435.35 states that each scram conduit w ll be ohysicetty seperated by et teest ene (1) inch from i
non-enclosed receweys. 'or any seperation of 5 f<
2 to one iness between o conduit and non-enclosed recewey the design does not meet sepersticei guidelines of IEEE Stenderd 334-1974 and sust be justified ty onetysis.
8.000 8.3.2.5 Associated circuits as of merch,1991, there ere no bw-s *essociated circuits
- sign. nowever, criterie for Section 8.3.1.1.5.1, Physicet Seperation and Indapendem e, states, in port, essociated circuits is in piece throughout Chapter 8 of the ssAR, should such that essociated cabtes are treated es Ctes* 1E circuits. the staff circuits be edt$ed prior to the firwl design.
interprets this statement to mean that associated cables or circuits will meet ett requirtamts pieced on Ctess 1E circuits. Att components in the At this stege of the design, ett etweenents =Aich interf ace with C;ess 1E associated circuit's current loop (toede, cables, comectors, switches, circuits are etso @stified as Ctess 1E, miess they are specificet ty isoleted reteys, protective devices, etc.) wi81 meet Ctess 1E requirements. Each wie approved isoletion devices. Sas% isolated circuits and ctswonents then encept on to this interpretation should be identified and justified in the became non-Ctess 1E. The test two peregraphs of section 8.3.1.4.1.3 have been i
A8WR SSAR.
deleted (see sitsched).
An interf ace requirement has been added to assure aceticents referencing the ASWR stentserd Ptent identify and justify any essociated circui's in the finet design. (See ettached seetion 8.3.4.13) 10.000 8.3.2.7 Cables Approaching and/or Emiting Cabinets /Penets The sec's stated isotication is ret consistent with the oat's concerns stated in sER section 8.3.2.4, nor ssAR section 8.3.1.1.5.1.
That section specifies Response to question.35.30 states that cable preading erees are not that IEEE 384, Reg Guioe 1.75 and GDC 17 criterie es eget scobte to att orpticable to the A8WR and are not in the plant toyaut tneuse the mielerity divisieret e visnee:t, intudies intercomecting cabling. In addition, 3-hour of the signets witt be multiptened to the control room. Ttus, it has been fire reted berriers separate divisions in ett erees of the plant encept es inntied that the 1 foot-3 foot seperation guidet tnes attowed ty section 5.1.3 noted in item & below.
of IEEE Standard 384-1974 will not be appli'able to ABWR nor wilt the
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. REPORT FORM QUESANS8 TO PRINT 4
NRC ORAFT SER ISSUES & CE RESPONSES FOR A8=4 SSAR CN4PTER 8 ISSUES GE CDNSIDERS RESOLVED PER TMESE RESe0 ESES 4
i NUMmER htC ISSUE GE RESPONSE l
guidelines of position C12 of Regulatory Guide 1.75. Criteria for the f
- seperation' end protection of cables aproechirg and/or emiting item 1: The reesireernts delineated in 8.3.1.1.5.1 do not distinguish between
[
I cabinets /penets has not been addressed in the Aandt SSAR. ' To initiate our metettic or fiber-eptic cables, are thus are amticetde ta both. C*te f
review in this eree, 'additionet information is remaired for the followins raceweys are seperate, according to vettege levels, es described in f
items.
8.3.1.4.1.1(4).
The *v1= tewet tperegraph (dji hos been codified to incluse
}
fiber-optic cables (see ettsched).
- 1. Routing criteria and prr**ct
. be provided electricet and/or optical cables used to carry easttik.;r or 6ther type of signets to the controt 1
room.
Ite= 2: The physicet errengsent of receveys keeps power cebtes seperate from i
IEC signet cables, es described fr= 8.3.1.4.1.1(4).
)
- 2. Criterie ior routing of safety or non-safety power cables in any room with I
instrumentation and control cables.
j Item 3: Section 6.1.3.1 of IEEE 384-1961 changes the ters
- cable spreading
[
l
- 3. Inconsistency between item (5) of se.: tion 8.3.1.4.2.2.2 and response to room" to "normerord erve*. Peregraph (5) of 8.3.1.6.2.2.2 hos been modified
. I" question 450.30.
to state specific reesirements thet ett safety egsipment or ceMe erees shalt meet or exceed the regsirements of IEEE 384 (see etteched eerk-up).
j:
4 Cable separation in cobte turinets.
y j
\\
Item 4: The tusilding structures for the AgWR Starderd Plant ere told out in such e emnner that cetde twwwts are not regJired for divisionet cables.
[
Cable choses, which are designed fri e,Me with IEEE 384, do esist within l
the tusildings. Encept for the instrument sensor catdes for the turbine stop l
wolve closure and turbine contret wolve fest closure (see 7.2.2.2.4(6)], Ctess 1E cab'e runs cccur only between the ee ctor ord control tmsitdings; ett others
[
).
are nort-Ctest 1E. Each divisionet cable dact between and tveroughout these
}
l buildings is entirety seperate end isolated from rh division = by f
three-hour rated fire berriers. Enceptiens occur only within the contret room l
comptes itsetf, and within the primary conteirment and mein steus turviet. tet i
j ihese exceptienst orees stilt meet the recesirements of Reg Guide 1.75 eru* IEEE 384 ty prwiding metet barriers ard/or spetist seperation betwaen divisions.
j Speclet cases within the reactor building ere enetyred es acceptable (in i
accordance with SECY-89-013) in 9a.5.
The control rena caseten fire anetysis i
is provided in 94.4.2.4.1.
I i
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. REPORT FORM clESANSS TO PRINT NRC D# AFT SER ISSUES & CE RESPowSES FOR ASWR SSAR CMAPTER 8 753UES GE Cows 1CERS RESOLVED PER THESE RESPONSES if MBER NRC ISSUE CE RESPouSE 12.000 8.3.3.2 Safety auses item 1: A deceeletion of the grounding devices eruf their essociated interlocking logic Fes bean ocksed to sesection 8.3.1.1.1 (see ettsched).
On every txes shown in figures 8.3-1, 8.3-2, and 8.3-3, there is one circuit shown etmected to ground through a circuit breeker. The circuit breaker or bus grounding dev;ce is uscJ to provide a safety gramd on buses daring item 2: The addition of any gramding device vitt, by its esistence, maintenance operations. Interlocks for the bus gromding device as stated in contribute to some measure of degradet,on in retiebility, powever, the response to questico 435.47(e) inctiz3e:
interteck constraints tirw:tuding those essociated with the rocking out/ disconnect position of the breeker itself) piece the breekers in a stete
- 1. t# der voltege ratsys aust be actuated; of semi-emistence (i.e.,
- recked out*) white the bus is energized, such that the bus retisbiIity is not mecceptobty degraded.
- 2. Reteted breekers sust be in the disconnect position; and
- 3. voltage for bus instrtsmentwtion evettebte.
Item 3: an interface requirement has been d$ed to assure arministrative controls are in piece to keep these circuit breeters rocked out (i.e., in the The staf f feels that the proposed gromding device may be en important disconnect position) dite the buses are eeergized. Furthersere, en enhance:nent for gerf orming enintenance on safety buses and should be included ervmciator will sound whenever these treakers are rocked in for service.
In the design; however, the staf f is concerned that the above prtposed This precaution, in addition to the otnar interlocks providad, should prectuse interlocks may not be sufficient in and of themselves to prevent inadvertent any pecbability the breakers coi/1f be inadvertently ettsed daring closing of the device during non-emintenance weration. To resolve this non-emintenance operatien of the power system. See ne6 section 8.3.4.14 concern, additionet information is remaired for the following iteens.
etteched.
11 Description and enetysis for the prtposed design.
- 2. Justification that the levet of retiebility of the safety bus has not been j
degraded by the addition of the device.
- 1. Interface requirements, eterms, or other centrois which will be j
2 taptewnted to assure the desice will not be inadvertently closed.
)
13.000 8.3.3.3 oustification Itam 1: The first peregrar* en 8.3.1.2.4 has been ewwmed to soy *...eit Ctess 1E ensipment, =Alch is essentist to tioiting the consemences of a LOCA.
Section 8.1.3.1.2.2 indicates, by reference to compliance with segutatory is oesigned to coerete in the post-occident emireev-at espected in th e-ee Guide 1.32, thet each type of Ct ess 1E equipment will be qualified by in *Aich it is tocated for any design basis event. Electric equiprwnt is
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, REPORT FORM GUESAeS8 TO PRINT mRC DRAFT SER 1SSUES & GE RESPONSES FOR ASWR SSAR CHAPTER 8 ISSUES GE CDeSIDEeS RESOLVED PER TutSE RESPONSES NtJMBER tiRC ISSUE GE RESPORSE enetysis, successfut use seuir sleiter corditions, or by actunt test to qualified to IEEE 323 (see section 3.11).*
demonstrate its ability to perfone its fteiction under nornet and design besis events. Section 8.3.1.2.4 and 8.3.3.1 incitsse the. f attouing iteam (it appears) in styport of compliance with this Reguletory Guide 1.32 ttee 2: Futt compliance with IEEE 308 is comunitted in the test peregrach of requirement.:
8.3.1.4.1.
powever, the certifiestion standerd is IEEE 308-1980, not IEEE308-1974, as shoun in Tabte 1.8-21.
C vie M ing sectione referenced for
- 1. Ctess 1E equipment essentist to tielting the consegsences of e,toCA are the 1980 versim are 5.3, 5.4 and 5.9, respectively.
designed to operate in norest service end post accident erwiroruments;
- 2. Electric equipment is setenricatty gastified;-
Item 3: Seperation criteeie for the essipment in the dryuelt is discussed in 94.5.
Erwirorumental cpetification for ett egaipment in att locations,
- 3. Att etess 1E cables are moisture and radiation resistant aruf highty flame including the drywet1, is discussed in section 3.11 and Ascendia 31. A resistent; reference to 3.11 (which in turn references Asycadia 31) is streedy inctuckd in 8.3.1.2.4.
- 4. Seperate certification proof tests are perforund to demonstrate 60 yeer Life, radiation resistence, erwirorumental capability, flame resistance, and gas evolutitui of cables; tree 4: The test sentence of 8.3.1.4.1.2(2) tuhich mentioned the drywett was not considered a hostile oreel hos been changed to: "Caote routing in the
- 5. Each power cable hos a radiatien resistent covering; drywett is discussed in associetion with the ogsipment it serves, in the
'specist cases' section 9A.5.*
- 6. Conthsetors are specified to contiruse to operate et 1001 relative htsmidity with a life expectancy of 60 years; and sten 5: The term " hostile eree* wes intentsed to mean those erees which could
- 2. C*ess 1E cables are designed to survive the LOCA atient cornfitions et the be potentietty exposed to the energy of a postuteted reactor coolant (steem e*
end of e 60 yeer life span.
water) pressure boundery pipe rseture. This criterie is defifwd in Appendia 38 and tables 31.3-1 through 31.3-21.
r Each of the above itees meets in part the guidelines of Reguletory Guide 1.32; however, based on the inforsmation presented, it is not cteer that att cables, for enanote, ere designed and gastified to survive the codifwd item 6: Plant Desipi specli scatiens for electricet eMr ; reasire such ef fects of tewature, hasnidity, radiatier., etc. essociated with a LOCA essipment be capable of continuous meestion for voltage fluctuotions of +/-
envirorunent or other design basis event environments et the end of t%ir 101 In addition Ctess TE setors sust be obte to withstand wottage drops to quotified end/or design life. Clarificatiers of the design and quotit..etion 701 rated dJring starting transients.
requireemts for cables as. welt es other Ctess 1E eqisipment to survive norwet and occident ern.rorummts (including identification with justification of j
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. REPORT f0est GUESAeSS TO Petut kNic DRfET SER ISSUES & E RENS FOR ASWR $$AR CMAPTER 8 I
ISSUES GE CtWSIDER% RESOLVED PER TutSE RESPomSES MunsER NRC ISSUE GE RESP 3eSE emceptions to the design and quotification requirements) should be provided in the ASWR SSAR.
In addition, section 8.3.1.2.4 indicates thet eli Ctes-- 1E equipment which is essentist to tiesting the consegsences of a LOCA is designed for operation in normal service erwiro usent and to aperate in the post occident enverorument expected in the aree in eAlch it. Is located. Also, this section indicates that electric essipment is <psetified to IEEE 344 (i.e. electric evipment will be demonstrated to meet its perforumnce reautrements daririg and fottowing the design basis seismic event.by test and/or snetysis).
Sesed on infarretion preser.:ed, the desip and gastificetion cameituent for electric equipment in the proposed ASWR design is not cles* with respect to the capability Of essipment to survive the combined effects of a LOCA envirvument. To clarify and resotwe this and other issues, additionet infonmotion is reesired 8er the following items.
- 1. Emplicit design comunitment that ett Ctess 1E electric egaipment will be designed and esetified for operation in its normet service erwironment eruf te operate in the scrident and post accident envirorument espected in the eree in which it is located for erw design basis ew.
- 2. Compliance of the ASWR design with sections 4.2, 4.3, and 4.7 of IEEE Stenderd 308-1974.
- 3. Empected norumet and accident enviroriment, seperettori criteria, protection of forded Ctess 1E equignment eM.abtes, and quetification of equipernt for any envirorument in the drywett
- 4. For the empected worst case occident erwirorument in tte drywell, eterification of mAy the drywell is not considered a potentietty hostile area.
- 5. Criterte for estebtishing hostite areas.
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. REPORT FORM N SAuS8 To Pelef.
f meC DRAFT SER Is"AIES & GE LIMS FOR Asut SSAR CMAPTER 8 l
IS'ilES GF 'ONSIDERS RESOLVED PER THESE RESPONSES
'f
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uungER ieEC ISSUE.
GE R W omSE
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. 6. Design and w elification of e wipment to operate for 5 meinut s when s* ject to voltage et 90 percent of reted voltage and to operate for a j~
predetermined time et 70 percent.
i 14.000 8.3.3.4 $4dsmergence there is no contradiction between the response to 435.36 and 8.3.1.2.1.
Guite i
the opposite is true, in thet the seated terminations preclude flooding i
Stee (6) c' section 8.3.1.4.2.3.2 states thet any electricet cauisement'end/or effects en operation of the devices, which in this case are tL-Jes.
[
racemey for RPS or ESF tocated in the saqupression pool tevet suelt zone wilt be deslysed to satisf actority complete their ftenction before being rendered Section 4.7 of IEEE 306-1974 is n - w M by section $.9 of IEEE 308-1980 j
j inoperable due *a esposure to the envirorument creeted by the level A __. eAlch rewires Ctess 1E epipment be wellfied to IEEE 323-1974. This I
f In response to stoff w estion 435.36, the licensee identified electricot-empticit comunitment has been added to response 435.36 in accordance with the f
i equipment that ory be sadamerged es s result of suppression poet levet suett NRC re w est (see ettsched mark-up h phenomene or es G result of a LOCA. The licensee further indicated that the desiert specifications associated with this electric ewipment would rewire it should be reetired that, es indicated in response 435.36, the only terminations be seated such'that epipment operation would not be jeweired by electrical devices (tes; des plant tighting ewipment) in the metuelt eree ere submersion. The w ellfication of this e pipment in accordance with the thermocoetes and instrument piping for tewet menitors (the instruments
-f j
guidellres of section 4.7 of IEEE Standard 308-1974 mes, however not themmetwes are outside the metuett). Isost of these thermocopies are c
specifically addressed. Sesed on infonmotion presented, it appeers that stAmerged ett the time. The remaining enes are desipwd specificetty to be
}
electricot equipment s*)ect to sidsmergence is not wellfied eruf only s4 merged es the poet'tevet suetts. Thus, concerves about "cauipmeat feiture*
h f
portietty designed for stammergence.. This conclusion contradicts section or *edverse ef fects en Ctess 1E power sources.* ese to pool sett are not f
8.3.1.2.1 of the Aswa SSAs mAich states sw att Ctess TE equipment is verrented.
I j-quetifled.
1 i
!t is the staf f concern thet epipuent f aiture Gee to sthmerger"e may
{
f adversely ef fect the safe operation of the plant eruf may adversely ef fect
[
j Ctess 1E power sources servir*3 this equipment. To resolve this concern, f
l edditionet information is required for the folteming items.
[
[
]
- 1. The spoorent centradiction between section 8.3.1.2.1 and response to j
. questim 435.36 in regard to quotification of equignment.
f I
I i
1
- 2. Arntysis danonstrating that feiture of.tsiquellfied ewipment due te, j
sdmergence vitt vet adversely ef fect safety or Ctess it power sources.
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.FEPORT Fopee Q W SatSS TO PR!af DRC DRAFT SER ISSUES & CE RESPouSES FOR ABWR SSAR CMAPTER 8 I
ISSUES GE CDNSIDEd5 #ESOLVED PER 7pESE RESPONSES NUMBER NRC ISSUE CE RESPORSE t
- 3. Explicit convoltments to quellfication in conformente to Section 4.7 of IEEE Std 308-1974.
j 15.000 8.3.3.5 tvingement of fire Sa4pressant The plant is designed with three-hour rated fire berricts u aerating redtevisrt
.)
divisione. Therefore, e conotete toss of fss,cticri can % essassed within any Section 8.3.3.1 states that the catde instattation is such that direct one fire eree, with acceptable conserpsences (i.e., safe shutdeun). se sefety imingement of fire st41pressant Fitt not preverft safe reactor shutdown.
function is reSlired of any Cable once it is eRDosed to fire. Unde-such Besed on this statement it is not clear wh*ther ispingement of fire circumstantes, the redurudent divisions would assume the safe shutdown stepressant will or will not cause feiture of cable systene. Clarification fsrction. This is the intent of the stateme-et, which has twen modified for of the design and quotif fration of catdes to perform their safety ftsvtion clarification (see attached serit-up).
white being stL}ected to the direct ispingement of fire suppressant should be i
provided.
Ctess TE cables are quellficatices tested to withsterd severe envirar nentei p
stress, as indicated in 8.3.3.1, and consistent with IEEE 323. They are etso hose-streew tested, and will be tied donas in metal troys. Even though
- edmdent divisions are available, the cables should perform their ftartions white being stejected to direct ispingeaumt of fire stepressant. nouever.
l because of the rerkadency oweitable in sepecote fire zones, specific testing In this regard is not regsired, nor considered necessary.
]
16.000 8.3.3.6 Isolation Between Safety Suses and non-Safety Lcads the design hes been modified es explained in response 435.67 The inforwelion
~
in response 435.67 precludes the need to ad$ress Items 1 through T.
The Section 8.3.1.1.2.1 irvficates that Isolation breakers a e provided between reasining itens es e ediressed below.
i the Class TE and non-Class 1E buses. In e&fition to normet over current tripping sf the isolation breaker, rene setactive interlocking is provided between each isolation breaker and its testream Ctess 1E bus feeder breaker.
It*= 8: The isolation devices used at the interface betw=en Ctess 1E circuits Section 8.3.1.2.1 indicates that even though the isolation breeker is and non-Ctess 1E cosipment circuits for erwn.ncistors or date toggers fautt-current actuated in non-compliance with the guidelines of pesition 1 of treference sectier: 8.3.1.4.2.2.4), are fit,er-optic devices. The use of cuch
[
Regulatory Guida 1.75, the intent of this Guide is weet through the zone devices *cr this specific purpose is addressed in eesponse 420.128, Item 1b.
selective intertorking technio.se; thus, the design meets the recorseendations of this and cther guides.
Itevu 9: The T/8 KC's have beere deleted from Figure 8.3-3 and ed>d to the 4
With respect to protecting Ctess 1E systems from feiture of enn-Class 1E non-Ctess TE buses on Figure 8.3.2 (see attached).
systems and components, the staf f agrees w th Oae licensee that coordinated i
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. REPORT FORM QUESANSS TO PR!ui mac DeAFT SER ISSUES E GE RESPouSES FOR A3WR SSAa CHAPTER 8 ISSUES GE COwSIDERS RESOLVED PER THESE RESP 0hSES NUMBER NRC 7SSUE GE RESPONSE breakers with zone selective interlocking meets the intent of position 1 of Reguletory Guide 1.75 and ouuts the protection regstrements of criterie 2 and Itee 10: Resoonse 435.18e has been corrected, per ettsched, and now ogrees 4; however, with respect to eeeting the saffic!ent independence requirement with response 435.14.
of criterion 17, the staf f disegrees with the licensees essessment. Non safety computers and transient recorder toeds shown en figure 5.3-5 have provieions inetuded in their power stsyty design for outoneticeity Item 11: Tabtes 8.3-1 and 8.3 2 show e11 D/G toeds (inctuding both C1ess 1E I
transferring these toeds fross Ctess 1E division 1 to 3 and from Ctess 1E and non-r'ess 1E loeds) for LOCA+LOPP and LOPP (w/o LorA), rewettively. Some l.
division 2 to 3.
In addition, it appears that the power stspty may etso modif *.-s m are shows per attac* *d mort-te.
1 incit.de provision for automatic transfer of these foods between division 1 and 2.
The design does not meet the guidelines of Regutetery Guide 1.6 nor The 0/S s are rated at 6.25 MWA with 0.8 pf (5000 kW), as shown in Figure the intent of position 1 of Regulatory Guide 1.75.
The proposed design thus 8.3-1.
As of Ap-it,1991, the mooieum toed is shown to occur on the e*
may not meet the independence requircoents of criterion 17 of Appendia A to (etectricot division it) D/G for toe LOPP (w/o (OC.a) condition (see -arki.e 10 CTR Part 50. To resolve this and other issues, odtfitionet informatim is tebte 8.3-2 ettsched:. This toed re3Jires a dieset engine output demand o*
required for the fc. towing items ord/or staf f positions.
4940.9 kW.
Asstseing the generators are 95% ef ficient, this ecuates to about 4712.9 kW et the gerwrotor output terminets. Therefore, weer mesteus toed
- 1. Retiebility, testability, test frequency, functionet test, and cet tbretion conditions teAich includes both Ctess 1E and non-Class 1E egsipsent), the of the isolation breaker coordination ord zone setective intertecking.
worst-case (heeviest loaded) D/G would carry approoimotely 96% of its rated i ed.
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- 2. Att non safety circuits connected to the Cisss 1E system through the l
isolation breaker with ame selective interlocking shett be treeted as I
associated circuits.
Item 12: The dieset generators have sufficiert capacity for ett Ctess TE and t
non-Ctess 1E toads, es captainM in Itew 11.
The cepecity muergin and sizing
- 3. Interconnection betw=en redtsident divisions (whether through safety or non criteria fo. DC power systems includes Leth Ctess TE erd non-Ctess TE toads, safety buses) shall be omintained with two normatty open and intertocked and is discussed in section 8.3.2.1.
devices that are separate and independent such that singic feiture or single operator action con not cause the interconnectim of or chattenge to reduridant divi = ions.
Ite== 13: sesoonse 435.18(d) hos been eterified, es stown in the ettsched merkte. LOPP toads regaired for LOCA remetn on the bus, toJt others are
- 4. Administrative interf ace criterie and/or eterms for maintaining ord trigped off.
assuring intercorriections open.
- 5. Identification of ett safety and non safety toads that con be powered from more than one Ctess 1E division powe supply. Accendia 208 should te modified to cteerty indicate loads that een be powered f rees mere than c ie I
.A
=
e I,'
eege No.
15
'06/04/91
.00 CnB1SSUE
+
. REPORT 70mm GUESANS8 TO Fttui NRC DRAFT SER ISSIES & E RESPouSES FOR 40WR SSAR CHAPTER 8 j
- ISSUES E CouS!DERS RESOLVED PER TtutSE SEsponSES NUM8ER NRC ISSUE E RESPomSE safety division.
l
- 6. A' description and onetysis of the use of fault actuated isolation devices I
in the Ctess 1E constant voltage constant frogsency power system.
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' 7. The use of unintemptible power septies es leotation devices (Reference j
response to esestion 435.34c).
1 I
- 8. Isolation devices used et the interface between Ctess 1E circuits and l~
non-Ctess 1E e wipment circuits (i.e., ennunciators or date toegers)
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(reference section 8.3.1.4.2.2.4).'
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- 9. The contradiction between Figure 8.3-3 and response to question 435.4*r I-Response to question 435.49c states thet T/s nCC is non Ctess 1E and is l
powered from non Ctess 1E power sources. Figure P 3-3 in contradiction shows T/B MCC to be powered from Ctess 1E power sourcec.
- 10. The contradiction between response to auestion 435,18e, question 435.14, and other_ ngua SSAR sections (e.g. 8.3.1.1.2.1) es to tripping of non-sofety toeds on a LOCA signet.
- 11. Identification of att non-safety loads and their W ratings thet con be powered from safety related diesel generators and identification of the entre W cepecity available to steply non-sofety toads during the verious modes of pien* operation.
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- 12. The cepecity, cepecity mergin, and other provisions thet will be included I-in the siring criteria for electric systems and components (i.e. dieset generators, betteries, distribution systems, etc.) whicts will ettow them to
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perf orm their safety function reliably shite s@ptying non-safety toads.
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- 13. Inconsistency between response c and d to westion 435.18 es ts loads that ere disconnected for. t0CA occurr ng.fter i.eds he.e been se,,e,ced following a toss of offsite power. Response e indicates loads not re wired I
e.
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. REPORT FORSt QUESAnd TO Pttui met CRAFT SER ISSUES & GE RESP 0mSES FOR A8W SSAR CnAPTER S 1
ISSUES GE CouSIDERS RE4JLVED PER TMESE RESPONSES NUMBER WRC ISSUE CE RESPO4SE for LOCA ere trioped iAlle response d ing. lies that LOPP toads receio d
connected.
17.000 8.3.3.7 Dieset Generator Protective Retsying item 1: There ore two argum vts iAy the tus differentist reteys should not be typassed asider LOCA conditions:
Section 8.3.1.1.6.4 Protection neg8rements, indicetes that the fottowing protectiwe re.sying will trip the dieset generator and will be retained seider II A bus esf ferencial indicates a serious feutt condition, in e simitee ctess accident cevufitions: Generator differentist, bus differe tiel, engin-over with the generator differentist. tavorutitionet trips should scipty to bus speed, low diesel cocting water pressure (two cut of tww sensors), and low dif.erettlet signets for the same reem they espty re generefor dif ferentist dif ferentiet pressure of seco e$ery cooling water (two cut of two sensors).
signets. The panerator ord tems must be protected from such feutts because Other protective trips will be bypassed durfee LOCA cceditions. This they are capable of inflicting mejor damage to the geneetter or bus if left protective relaying (e.-ept for bus dif ferentiet) ace art to meet position 7 is, check ed. Sus differentist protection is e n - M by.Eif 242-1986 (IEEE of Regulatory Guide 1.9 (revision 2) and is acceptable. To resolve the Buf f Sook, Section 12.4) for busses fed by tocol generators.
esception (i.e. bus dif f rientist retsys tri;pirg th: dieset generator) and other related concerns, odditionet information is regsired for the following
- 2) There are three seperate diesel generators, each stcptsing its c=sn items.
enue.w-u$ent safety divs94cn. Since e einisue of enty one division (i.e., arme diess. generator) is re-xsired to achieve safe plant shutdown i.ee response
- 1. seses and justification for bus differentist relays tripping the dieset 43).24), each generator esa be better protected without cw4i,e plant generator.
safety. I? 's not necmary to risa dnooga or distruction of one g=neester, even isider LotA condittons, iAen there are two remainirg generater divisions
- 2. Design description for eterning et t trips incitsfing those that are oveitobte.
bypassed during LOCA.
- 3. Design descriptia-* of bypess circuitry and its comptience with IEEE 279 Item 2: Subsection 8.3.1.1.8.5 tists ett eteres wssociated with tne dieset raquirewents.
generetor. The etone tist has baen empended to itvIude the bus diHe entieL trip, the generator grouruf overcurrent trip, erut the geo stor loss of field
- 4. Separatiori tetween the two trip sensors and logic for low diesel cooling trip. Nowever, es iewsicoted in tww 435.22, the octml elores recauired water pressure end tew differentist pressure of secondary cooling water.
esy very depanding on the specific D/G selected in the fir:e* design stege.
- 5. Inconsistencies tetween section 8.3.1.1.6.4 and 8.3.1.1.8.5 as to bus differentist reteying.
Ite== 3: The types of bypesses en?ew. sed in IEEE 279 tSections 4.'t throuch 4.14) are those iAsch remove systems or channets frase opee** ion, and th ss did to redxe e,surance of evetective actions. Conversely, the C/G trip te utilized tseer LotA conditions are providad to assure tha,:rotective action ei
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. REPORT Font ouESAuS8 TO PRisi het DRAFT SER ISSUES & GE RESPONSE.S FOR A8WR $$AR CHAPTER 8 ISSUES GE CONSIDERS RESCLVED PER TMESE RESPONSES 4
NUMCF n=a ISSUE GE RESPONSE the dietet genereters. These bypesses do not coerste on the pr.tectiw*
fmetion itself (i.e., the dieset generators), but rather, on the <!rc~4ts which trip the prote.Jve fmetion. Therefore, the IEEE 277 criter:e *eisters to automatic remove! Of bypesses, etc., ere not e@ticebte to th* trist bypesses discussed here. Otherwise, such criterie would have e negative ispect on safety.
J Item 4: The three diesel support systeuis are safety related, indepe@st, anG redsdent; and each is on the some division es its essecteted diesel.
Therefore, additionet s paration regtsirements are not imposed w' thin each division itself. Some naturet separation of these sensors would esist, tesed on the sortf acturer's design, but it is not regtaired that they tse saporated because of the three redtsident dieset systems.
Item 3: Tne bus dif ferentist relay trip hos tm addm$ to 8.11.1.8.5 (sae attached merk-up).
18.000 8.3.3.8 Thernet overtoeds As inc*'ceted in response 435.60, circuit deteils et the ele =antary tewel ere beyond the LRS. mowever, en interf ace rewirement hos tm ed3ed es section In response to question 435.60, the Iicensee indicated that thernet overtoed 8.3.4.15 to assure the Mov overtoed bypesses are testable (see ettsched).
protection for Ctess 1E MOV's is in ef fect only when the Mov's are in test and are bypassed at ett other times by means of closed contacts in perettet with the thernet overtoed contacts. A visuet indication is provided in the 4
main control room when the MOV is in test. The proposed design for bypess can assure that the therent overtood protection will not be in effect during accident conditions to prevent operation of valves. The design thus meets the intent of Regulatory Guide 1.106 and is acceptet>te with the possible y
esception of testability. Swficient information relating to the capability 1
for perio'icetty testing the contacts that are in paret tet with the thernet overtoed contacts to assure they are closed during normat operation has not been presented. To resotwe this concern, ecMitionet information is reaJired concerning testing nf the therwist overtoed bypess device.
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. REPORT FORM clESAeS8 TO PR!af wat D44FT SER ISSUES & GE RESPONSES FOR ABWR SSAR CMAPTER 8 i
ISSUES GE CDWSIDERS RESOLVED PER TeESE RESP 0 ESES a
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j WLMSER NRC ISSUE GE RESPONSE l
19.000 8.3.3.9 Breeker coordinetton The sentence Fes tm eterified es fottows: *Tripp g of the Ctess TE feed 4
areeker is normet for f outts which occur on the Ctess 1E tps it feeds.* See j
in section 8.3.1.1.2.1, the lice usee states that trisping of the Ctess 1E tse ettsched merk-w.
l feeder breaker is normet for feutts which occur en its Ctess ti toods. The l
stef? disagrees with this stetement. Ctess 1E tood theekers should be
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coordinated with the Ctess' 1E bus feeder breaker so that feutts iAlch occur f
on its Ctess 1E toads wilt, to the extent possible, not cause trip of the bus feeder breeker. Clecification of the ASWR design with respect to breeter coordination is regsired for resolution.
20.000 8.3.3.10 Protective Reteying The detetts fer setpoint methodology specific foe the AsWR mey be fomd in the
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" Instrument Setpoints Design Remair==ents* docuernt identified in the Emperience with protective retey applications has established that relev trip referewe in Section 1.1.3 of the ABWR $$AR. A re'ifence to this doctement hos set point wilt drift with conventionet types of reteys. Set point drift et been added to response 435.58 (see ettschment).
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l hucteer power plants has resulted in preesture trip of rechJndent safety related pump motors uhen they were reasired to be cperative. While the basic l
need for proper f ault protection for feeders /eqtsipment is recognized (and emy be e regsirement for the design best. event fire), it is tha staff position that total non-eveitauility of redtsident safety systems due to spurious trips of protective retsys is not acceptable. The primary safety fmction of the electricot distribution system is to provide power, reliably, tc, safety related equipment. The licensee in response to this position j
(question 435.58) indicated that loads, such es setors, wilt be purchased i
with suf ficient current carrying capability or overtoed mergins so that set pois ts of protective devices con be set suf ficiently above the cperating current point of fcads to e14ou for set point drif t.
Purchese of notors with sufficient overtoed mergins meets the intent of the above staff position and i
l is acceptabte if cne esstsies the following:
- 1. The overtoed mergin will accomodate the toed's starting current es wet t j
es the norest operating cerents of toads.
- 2. Specific design peraru ters and/or interf ace requirewnts cteerty oefine
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.EEPowT FORM 1RKSAeS8 TO PWIWT NEC DeaFT SEE ISSUES S E RESPONSES FOR ASW SSAR CMAPitt 8 ISSUES GE CONSIDERS EESOLVED PER THESE RESPowSES i
I WUMBER NRC ISSUE E RESPONSE i
(in the A8WR SSAR) the overtoed margin requireamts with respect to i
protective device trip set point, the mergin between the trip set point erut j
operating curf ent point of toads, set point drift, and the mergin between the trip set point and overtoed retirg of loads.
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- 3. The toed breaker protective device trip set p int is established with t
5 suf ficient mergin (e) between trip point erut operating current, (b) between I
i trip point and overtoed rating of the tood, and (c) between trip point and e
I' trip point of the sein oue feeder bree6.er.
- 4. The protective device trip set point is p=riodicotty verified and ceIibrated.
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- 5. The protective device is subjected periodicetty to e functior.st test to f
demonstrate (a) its towebility to not trip at its design setting i.e. the
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nornet operating current of toed plus mergin and (b) its capability to trip z
l when subjected to e feutt current.
l The stof f is ww M that the A8WE design may not meet the abow 3
1 essi. supt ions.
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22.000 8.3.3.12 contret of Desip Perameters Item 1: mormat settirgs of the thernet overtoed trips, in accordance with the manufacturer's reo.sirements, will protect the wolve operating meters of ett
)
I Vetwe prthlems such es emeess friction, pecting too tight, etc., can result non-Ctess TE uGWs et ett times.
j in en operationet condition h the current drames will esceed the design rating or capability of the insutstion system used in the wolve motor Ctess 1E mov's have sioiter protection daring manuel test 6ng or maintenance
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winding. Operating esperience has shown t~nst excessive current, l'f tsw$er seeinistrative contret tsee response 435.60).
Mo==wer, Ctess 1E Mot I
I undetected during operation, con cause premature or unespected feiture asien thermal overtoed trips are bvpessed at ett other times in accordence with i
the watwe is nest operated. Methods, design provisions, stores, or Regutetery cuide 1.106.
procedures for assuring the wolve motor will not be operated with excessive I
currents ter will etways be operated within the!r design timits) hos not baen f
presented in the Asut 55Aa. ' To resotwe the issue discussed above end related Itee 2: At t Ctess 1E tc-panents are designed, purchased, tested, and j
concerns, eMitionet inforestion is required for the fottoweng stems:
6nspected in accordanca with IEEE 2M. sps:ificotty peregraphs 4.3 sews 4.4.
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Pege wo.
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06/04/91
.to CsBISSUE
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aEPORT F04st irJESAmS8 TO PetNT Net DEATT SER ISSLES & GE RESPoeSES FOR ASWR S$AR CMAPTER 8 i.
ISSUES GE CONSIDERS RESOLVED PER TNESE RESPONSES i
WUMgER WRC ISSUE GE RESPGrSE
- 1. seethods used to assure design parameters for-motor operated vetves will not be exceeded daring votwe operation.
- 2. se thod used to assure design parameters for ett Ctess 1E components witt e
not be exceeded daring att medes of plant eperation.
23.000 8.3.3.13 Fire Protection of Cable Systems Spatiet seperetion. #ere necessery, is p.mtified within the primary contairement because it is inerted with nitrogen during reactor eperation. An Section 8.3.3.2 fridicates that spotlet seperation is used es e method of esposure fire esrriot tue sustoiced in the nitrogen enviruremmt. (See response preventing the spread of fire between adjacent ceMe trsys of different to SER section 8.3.2.2.)
divisions (e.g. inside priamey conteirament). The objective is etweys to seperate cobte troys of dif ferent divistons with structical fire berriers 10 CFR 50, Appendia a appties to nutteer power fecitetles we eting g;rior to such es floors, ceit legs, and watts. Where e floor, celting, or wett is not January 1,19'9; therefore, comotience with Appendia t is ret addressed in the possible, divisionet treys are seperated opstietty by 3 ft. horizontelly and ASWR Standard Plant.'
5 ft. verticetty. Where this 3 f t.-5 f t. spetiet seperation is ret possible, fire rated barriers are nasM to seperate divisionet cable trays. For a fire In he with the SRP, the ASWR hos comeritted to meet STP OuES 9.5.%
7 initiated by a cabte fault within one division, the above defined seperation ehich incorporates the requirements cowered by Appmdie E.
Camptionce with smeets the guidelines of aegutatory Guide 1.75, will provide reesomebte STP des 9.5.1 is discussed in SSAR section 9.5.1 and Assumdia 9A.
essurance that a fire in one division will not proposete to e reesident division, and is acceptabte. For n Jesign basis event fire, spottet
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]'
seperation and fire reted berriers may ret be suf ficient to prevent the 4
I spread of fire between adjacent catde trays or wire bundles. Clarification of the design's compliance with 10 CFR Port 50 Appendia a requfrements is l
required to resolve staff concerns.
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i 24.000 8.3.3.14 Electricot Protection Assemblies (EPAs)
The need for redundant EPAs wes.besed on the fact thet RPS power samplies in eperation daririg 1990 wer= non-Ctess TE: t*=refore, e single rendas feiture Two 6 4C electricot protection essemblies (EPAs) were reepsired (by a had to be token in addition to the postuteted power simply feiture. Question Septee er 24, 1960 tetter to att wereting WW'ts) en the output of RPS power 435.7 ocknowledged that because e Ctess tE aPS power sssely is used en the l
supplies in order to satisfy the single feitiere criterion for non-f ail-sofe.
Aews, redsudent EPAs are not reepsired since feiture of tow? Ctess 1E sumpty is
)
type feitures which may be caused by inder voltage, ever vettege, eruf under the first rendom feiture taken. The factes 2f the 4pJestien, then, was whether frequercy conditions.
e single i.-
.. EPA is reanstred.
f e
Wesponse te, question 435.7 itujicates that EPAs will not be tr,ed in the ABWe GE's position is that even a single indag=vwSent EPA is not tweessery, tweeuse
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Page so..
21
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06/04/91
.00 CneISSUE I
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.WEPORT FORM eUES8eS8 TO Perot
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1stC DRAFT SER tssuES & GE RESP 0nfSES FOR Asum 55aa CemePTit 8 l
ISSUES GE CONSIDERS RESOLVED PER TWESE SESPCBSES
[
_j design because of speclet desiyt feetures. These special feetures include (isstike previous plants) the type of protection proeridn! by an EPA is etreedr j
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eenitoring of wottage erwt freesency, automatic transfer of posser sies:4y irgsut
(*tcluded within the pomer oWies theumelwes. The Ctess 1E poner sources sources when iPottege eruVor fregaancy enceed preesteldished limits, contret sapplying peuer to tb eotenoids of the scrase pilot wetves are equipped with J
room atorm fee abnoruust corditions, operator actlen in response to eters of Ctess TE wettese and fressency rewtotion, and e4e with Ctess TE annitoring abnornetity, and design and wtification of egripment to ret felt ef ter erui protection devices which monitor for tsutervottage, overvottoge, 1
j operation for a period of tise eder the estremes of voltage e9d free *Jency.
tsu$erfreesency and overfre9sency conditioras aruf eAich will outamaticetty trip
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the power sourre (i.e., disconnect the toads from the degraded pomer eeurce) l 5esed on a review of these special feetures, it aggerrs thet they any provide whenever an out-ef-epecification conditiere persists.
f 4
reasonable essurance thet any abnormatity in vettage and frege=ncy (seich can t
cause feiture of fait-sefe-type essipment) wilt tse presuptly discereiected tur Two feltures are hary to cause e corufition of des aded pouer to the scran i
i l.
eterms and operator action. The speclet features, however do not meet the pitot wetw= solenoids. The first feiturs <eidd be the degrad=d posser i
c single feiture criterion. ' Feiture of the special features to eterm or of the cornfition of the C1ess 1E pouer ource; the second would tue the feiture to i
s operator to tehe prompt appropriate action ere single f aitsres 3Alch any transfer power, to eters, or to trip. The penser distributlers systess is thus cause e non-felt-sefe type felttrv. the capebility to scram the reector may designed such thet a single feiture cemet result in *grothed peuer turirg thus be compromised.
siss> tied to the *A* or *t* eetenoids.
s An emplicit statement of ctgtlance with the staff position thet tuo EPAs tse Seth the techn4cet aruf 711 fections perfonmed by art EPA are themfore y w.
4 within the desiyt of the power sisspiy itself, and are entercel (PA is g
provided on the output of the RFS penser stepites with justification for erees a
i of non compilance should be included in the Agut SSAR.
not necessory or regaired.
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25.000 8.3.4 ELECTRICAL tuDEPENDENCE.
This issue is ocktressed les response 435.67. ' Figure 8.3-8 mes modified es empteined in that response.
8.3.4.1 Intercomections Figu e 8.3-8 shows two intercomections between resswinnt divisions-
- 1. Division ist 480 wott tne designated P/C EMI is comected to Division I
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480 wett bus designated P/C Cut through circuit breekers and mechanicet i
interlock. Section 8.3.2.1 fruficates that this intercomection is used to j
i transfer the 250 WDC morimot bettery cperger t:-tween Division I aruf IIt toed
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centers.
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- 2. Division its 480 wott bus designated 8eCC EW10 is connected to Division I f
480 wott tm oesignated P/C Cut through bettery chargers, breehers, and key -
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_ REPORT FORse OtKSANS8 TO PR!si NRC - RAFT SER ISSUES & GE RESPotSES FOR ASWR SSAR CNAFTER 8 ISSUES GE ComSIDERS RESOLvrD FTR IMESE RESPONSES I
GE RESPONSE WUMBER NRC ISSUE interlocked breakers. Section 8.3.2.1 Indicates that this intercomection is used for selection of the nofset or the ste % y bettery charger.
Criterion IT of Appendia A to 10 CTR Port 50 requires f.hac. e betwaen rededent divisions such tSet feiture of one will not chattence or cause f ailure of the remaining redsident divisions. Sufficient information describing these ent" other intercomactions os to their compliance with the l
independence requirement of criterion IT has not been provided in tne ABWR It is the staf f position that two indepmdent open disconnect tires, SSAR.
rocked open breekers, or other egeivalent open devices be meintained between redurdant divisions if redtsident divisions are to be electrically interconnected. Adfitional information as to entent of compliance with the above staf f position with justificetton of eree of mon Compliance is rentsired in the ABWR SSAR for resolution of this issue.
There are four irha a seus redundant betterits uhich sup4y CC power to 26.000 8.3.4.2 Constant Vettege Constant Frequency Power S e tles the CYCF's. The enty lif* between divisions is through the division IV bettery cherger, dich receives its power f rone the division AC sWy.
Section 8.3.1.1.4.2 indicates that each of the four f.e aa trip systeams There is corptete ii h a s of the four divisions frtue the betteries, ofthe reactor protection logic and control systee ere powered by four constant voltage constant fre w contret power buses (Divisions I, !!,
throug% the CVCFs, and on to the toeds. The stete=wat in 8.3.1.1.4.2.1 has been clorified to eepticitly identify the four DC stsvlles and three AC III, and IV). This section etso states that each of these buses is sssetied sureties (see attacfwd eert-to).
independently f rom en inverter ediich, in turn, is swelled from one of four i.44,a ord redtsdant AC and DC power stsplies. SubsegJent sectiers and The purpose of division IV is to provide fuit two-eut-of-four (cgic for the figure 8.3-6, however, indicate that the AC stopty for divisions I and IV originates from a single 480 wott motor control center (C14). A single 480 SSLC, mAich goveress the ECCS and RPS chamets. It etso facilitates reversion to two-out-of-three logic et the less of any one of tM four chamets.
A volt motor contret center is not i,@aa and redtsdent es stated in com> tete justification of this eerengement ts assured by the f act that safe section 8.3.1.1.4.2.
To resolve this inconsistency and other concerns, shutdowri criterie, ircluding single f ailure considerations, ere streedy additionet information is ragaired for the fattowing issues and/or positions.
wccomunodeted with divisions t, !! and til alone. Also, this t ir* between the division IV bettery charger and the division I power source is e=plicitly defined in the PSA stufy. For eefitionet detests, see response 430.375 and
- 1. Descript on, justification, and enetysis ;o desenstrate that sufficient i
stesection 9.5.1.2.11.
redtridancy and indepmdmce has been designed into the protection system and their associated power sagiplies in accordante with the rewirearnts of criterion 21 of Appefdia A to 10 CFR Pert 50.
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. REPORT FOME QUEseWS8 TO FRINT mRC DRAFT SER ISSUES & GE RESP 0 ESES FOR ASWR SSAR CHAPTER 8 l
ISSUES CE CONSIDERS RESOLVED PER THESE RESPomSES l
4 NUMBER NRC ISSUE CE RESPouSE j
l
- 2. AC power s g ply for Division tv should be powered from e 6.9 KV division f
j bus thet is independent, to the entent practical, fron Division I, II, and l
. lit 6.9 KV and 480 volt distritntion systems.
f I
i.
l 27.000 8.3.4.3 Power Seply Circuits for Safety /Retief Velve (SRVs) tree 1: Section 19E.2.1.2.2.2 has been modified es shows in the ettsched
[
mark-te. There are sin safety relief ve1wes on each of divisions I, it and
[
]
til.. ADS Vetwee ere controtted by divisions t and it. man-divisionet power
[
Section 19E.2.1.2.2.2 indicates that portions of each safety /retief vetwe (SRVkontrot circuit utilire non-sefety grade power end th:.t tfits non-safety is ret utitired in either the SRs e ADS fisictions. Division IV is used only
[
f grade power is taken from the Class 1E DC system through DC/DC -onverters or for the two-aut-of-four initiation toeic for the aos. The electrical power f
isolation devices corriected to each of the four reesident eruf 14.a..;
divisione esslysed to eel wetve are shown on Table 19C.3-3.
i Ctess 1E DC system tw. Section 19E.2.1.2.2.2 lapties thet controt power
[
l for each SRV comes from e minimum of two dif ferent Class 1E power source
[
divisions. One source directly from the Clees 1E DC bus with the other from Item 2: The physicet and electricot seoerotion for ADS centrot circuits is f
a different Ctess 1E DC bus through the DC/DC converter. The staff is preserved. The close prwinity of the divisions I eruf It ADS solenoids
[
I concerned that the proposed design for pomering the "Rv's may not provide regdres berriers to maintoin seperation. These solenoids are isolated by
(
sufficient i,4,~ a. e between the reesident DC power sources in accordance metet itsiction benes,' rigid con & sit, and/or short sections of fleeible
[
j with the regsirements of GDC 17. To resolve this concern, edfitionet conduit, es described in 8.3.1.4.2.3.2(4).
e enformation is regsired for the fottoming items.
1
]
- 1. Design information and/or. criteria for the physicet and electricot l
a seperation of safety and non-safety controt power circuits for each SRV from the power source to and including the SRV control circuit.
l I
- 2. Physicet and electricot seperation of the ADS control circuits and their sources of power. (Section 19E.2.1.2.2.2 indicates that four of the eight SRV's used tuo divisions and the reamining foue con be steptied by any of j
three divisions).
1 29.000 8.3.6 DESIGN CONTROL The design controt for the ABWR is based on WE00-11209-Ose, the " Green Book =,
l Rev. 7.
This document has been approved by the NRC, and is referenced in SSAR
)
j 8.3.6.1 Control of the Design Process Sectiert 17.1.3.
f j-Recently, there have been a nure;*r of problens identified utth the electricet s
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Pege No.
24 06/04/91
.DO CESISSUE
.REPCri FORM QUESAeS8 TO PRIRT
' kRC DRAFT SER ISSUES & CE RESPONSES FOR ASWR SSAR CMAPtER 8 IS91ES GE CONSIDERS RESOLVED PER fnESE RESPouSES WLMBER
- RC ISSUE GE RESPORSE system desig,e at nutieer power ptonts. AIthough the mejority of these problems arose es a result of modifications performed af ter plant licensing some were (and ett could have been) the resett of smor originnt design.
Generic letter 88-15 edsresses a ruuber of these problems that have occurred primarity as a result of inadequate controt over tt'e design process. These problems have occurred fe,ereen of electricot system design which have historicelty. =tt estebtished and comprehensive design criterie and guidelines available for the design engineer such as circuit breeker coordination and f ault current interrtg> tion capability. The staff does not normatty sedertake e detailed review of these arees. The staff instead relies on the designers procer esercise of the wett established design criterie and guidelines. To ensure that the criterie and guidelines are followed control is rewired. The control being implemented for the ASWR electricot design and the required control for any subse m ent modifications thereto should te described in the ASWR SSAR.
30.000 8.3.6.2 Control of the Design Beses Eis'it of the fif teen issues identifying incmsistencies in this draf t SER were the resuit of design changes in s ich erees discussing the same topic were not The beses for the design described and presented in the ABLat SSAR is, for the ett @ ted et the same time. (See responses for draft SER sect ons 8.3.1, i
most part, used es the basis by iditch the mRC issues a plant operating 8.3.2.1, 8.3.2.3, 8.3.2.4, 8.3.3.6, 8.3.6.2, 8.3.7, and 8.3.8.1) these have license. Sesed on a review of the bases presented in Chapter 8 and other been corrected in essociation with these responses, es indicated throughout related chapters, rumerous irtonsistencies have been identified. These ttiis -dsmittet. However, a formet engineering review red tedete will occur inconsistencies are identified in other sections of this safety evetustion following receipt of the SER for Chapter 8.
The formet review hos been report. Given these inconsistencies, it appears that the process for eweiting that time, so that resolution to SER issues con be incorporated along controtting the design bases being presented in the ABWR SSAR mey be with the generet tgdete of the.:hopter. This is consistent with c w deficient. The process for controtting the design bases should be clarified schedet ing peogram for the A8WR/SSAR doctrumt control.
In the A8WR SSAR The remaining seven issues escre, in f act, erronecus interpretations of the information review =d.
We beve else identified these arees within this sutzeiat at.
(See responses for draft SER sectiens 8.2, 8.3.2.7, 8.3.3.4, 8.3.3.7, 8.3.4.2, 8.3.8.3, and 8.3.8.5.)
the est is reo;ested to reconsidar this question in the tight of the resomses ord test sgdetes associated with this sutunittet.
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.REPORY FORet SUESeNS8 iO PRIwT i
esec eRAFT SER ISSUES & GE RESPONSES FOR ASWR SSAR CHAPTER 8
-ISSUES GE CDeSIDERS RESOLVED PER fnESE RESPomSES NUMBER elec 1SSUE GE RESPGsSE 1
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5 32.000- 8.3.8 CAPAClif A G CAPASILITY Section 1.2.1.2.5.2 hos twen modified to egree with section 8.3.1.2.1, which is correct (see etteched mort-up).
ij.
' 8.3.8.1 Shutdoun Copsbility of Each Lead Group
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Section 8.3.1.2.1 states that the stoney power system red.J y is based on the capability of any one of the four divisions (one of three toed grotes) to provide the ednieman safety fisictions necessory to shut down the mit from the cor, trol room in case of an occident erwl enintain it in the safe shutdown candition. nouewer, in epoorent contradiction section 1.2.1.2.5.2 states that the Ctess 1E power syst m are destried with three (3) divisions with any two divisions being odegate ta eefety piece the taitt in the hot shut '
i down condi ion. This esperent contradiction should be clarified in the ARN t
SSAR.
i 33.000 8.3.8.2 men-Safety DC Power Systems Sectiivi 1.2.2.5.1.6 bes been seended es shows in the ettsched mort-se. The 4
i 125 vDC non-Ctess 1E system is briefly discussed neer the end of section i
Section 1.2.2.5.1.6 indicates that the AeWR destyi includes e insit eunitiery 8.1.2.1; however, e new section 8.3.2.1.4 hos been e Med inich further de power system ttnt supplies power to de toads that are non-sofety ref ered.
describes this systes:.
j Movever, section 8.3.2, eAlch is stepose to address de power systees included in the ASWR, omits description and onetysis of the urait eumiliary de power system. This systeen and tfes estent it will be used to simply de contret power to systems that ere importent to safety (such es offsite pouer circuits) should be defined in the ASWR SSet.
4 34.000' 8.3.8.3 Ctess 1E 125 vott DC settery Cepecity Saction 5.4.6.1 has been edified. per ettsched mork-se, to be consistent with the eight-hour capire capacity stated in section 19E.2.1.2.2.2.
Section 8.3.2.1.3.2 indicates that each of the four Ctess 1E 125 volt I
betteries have suf fi 'ent stored energy to operate corriected essentist toeds The two-hour availability time stated in section 8.3.2.1.3.2 is not reetty continuously for at teest two hours without recharging. During loss of oc inconsistent, in that this essasmes continuously fatty toedad cortfitions. The j
power, section 5.4.6.1 indicates that the bettery carecity should attou ever eight-hour tism for station blocteut conditions is eveitable because RCIC
]
four hours of operatica of the ECIC system.
Ita= 3 of section 19E.2.1.2.2.2 toads are intemettent, and other toads een be shed or shif ted to other indicates that the de loetteries will be sired to be capable ef operaterig the divisions (i.e., SRV fisttions). This is esp 4eined m resperuses 435.38(c) and RCIC system for a minosuse of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> essuming toad shedding and u:e of ett 435.2 (SSee section 20.3, tab SAI-83 and in section 19E.2.tl.2.2.
this 1
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. REPORT FORM QUE$eeS8 TO PatuT mRC DRAFT SER ISSUES & CE RESPONSES FOR AgWR SSAR CRAFTER 8 sSSUES GE CowSIDERS RESOLVED PER TRESE RESPONSES i
NUMBER WRC ISSUE GE RESPONSE four Ctess 1E betteries. Item 2e of sectices 19E.2.1.2.2.2 indicates that clarification hos turen added to 8.3.2.1.3.2 per the etteched merit-se.
)
Division 1 bettery by itself has suf ficient capacity to operate the RCIC i
system for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. These inconsistencies should be clarified and the design An estimeted toed damend profile for the 125 WC betteries was provided in
^
I bests load profite for each bettery should be esplicitly stated in the ASWR resporwe 435.38 (SSAR page 20.3-253.21). As empteined in that response, this b
SSAR.
Information could change es the desiyt is specified for esque agetication.
t 35.000 8.3.8.4 Use of Silicon Diede in the DC Systein Item 1: The ef fects en retlebility et the DC system &e to the SID have been acce pted for in the PRA. The contribution to probabilistic feiture caused by Figure 8.3-7 and response to gaestien 435.51 Indicates that a silicon diode diode SID being coen is specificetty included in the 125 vde electric power (SID) d ich has e voltoge drop of 10 wotts hos bee
- instetted in series with fault tree (Figure 190.6-10e). The results of the PWA study confire the j
the output of the bettery and bettery charger. During normet operation (i.e.
rettability of the DC systee is odeguate.
bettery chorger output voltoge is set et 140 volts for equellac charge) the l'
switch in porettet with the silicon diede will be ccen so that the voltage
- j f rom the bettery charger to the DC bus evitt remain at 130 volts (14e wotts Itese 2: This information was providad in response 435.38 (SSAR page minus the 10 voit drop ecross the silicone diede) iAlte 140 volts is stoptied 20.3-253.21).
to the bettery for eqJetire charge. The staff feels that the preposed design has merit; however, suffici e t descriptive leformation and onetysis to reach a conclusion en ecceptability for ett andes of plant operation has not been Itee 3: The systee is oesigned such that the atuettring charge mode ($10 presented in the ASWR SSAR. To resotwe staf f concerns. edditionet cordacting) outoesticetty transfers to the fleet charge ende ($1D bypassed) information is required for the following items.
whenever either of the following conditions esist: 1) A fault occurs in the SID, or 2) Input AC powar is lost & ring egantiring. In addstion. the S!D is
- 1. Retiebility of the proposed DC system. The e&fitien of the silicon diede designed to continuously carry the semisue current the chargers con stgoty to h
in the DC system circuit odds en additienst tevet of eretiability to the the 125 Vdc bus.
syste=e white et the some time may improve overalt DC system retlebility.
e
- 2. Cepecity and capability of the DC system to supply design basis toads Itee 4: The duration of egaeliting charging is short, and the fregency of i
daring toss of offsite power events.
opplication may very fran weekly to several months depperfirws on the bettery annuf acturer's recessiandations.and the specific utitity's maintenerce
- 3. Design provisions to assure the better, will never have to sagoty its procedures. In any case, the chargers will be in the float charge mode design basis toads with the silicen diode comected in series with the (perettet contact closed) the greet mejority of the time. During those short f
bettery and DC bus.
periods when the contact is corn (egaettring charge mode), the automatic transfer capabilities provide protection (as eepleined in item.*).
f
- 4. Monitoring for the sw4tch instelled in paratlet with the diode.
Confirmation of the switch's position and grceer function sesy be eter" et any time, by cepcoring voltage readings sgstreme eru2 downstreon of the SID
v
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Pege no.
27 06/04/91
.D0 CMISSUE
.REPORI FOPM QUESARSS TO PeteT utC DEAFT SER ISSUES & GE RESPowSES FOR Asut $$At CMA7TER 8 ISSE S GE CouSIDERS RESOLVED PER THESE RESPONSES afUwSEE WRC ISSUE GE RESPONSE utilizing the voltaeter provided with the power stsply (Figure 8.3-7).
36.000 8.3.8.5 Ctess 1E AC Stency Power System item 1: The diesel generator (D/G) capability of reoching futt speed and voltage has changed frtz 13 secords to 20 secords in order to be consistent As e result of our review cf the sten @y power systee proposed in the ABWR with EFat/stnat reorirements. The changes are shown in attached morbes for SSAR, the fottowing erees of concern have been identified.
sections 8.3.1.1.8.2(4), 8.3.4.2, and Table w.3-4.
- 1. Inconsistency betweee section 8.3.1.1 8.2 and 2.3.1.1 8.3 es to the design capability or the diesel gereretor to start ord ettein rated wettege and tree 2: As indictted in section 8.3.1.1.8.2(2), the C/G is designed such that frequency.
Its voltage drop w:lt ret exceed 25% (757 bus voltages, eve =n sader sessence toedi-ng conditions. Therefore, white the 0/G is stsytying power to the bus.
- 2. The capability of the diesel ganarstor to stscty toads assuming loss of the toss voltage will not drop below 70% for a sustained period se*tess the 0/G of fsite, toads tueing either sssplied by or being sequanced on the diese8 itself faits er there is e feutt condition. tWer such conditions, the gereretor, and bus voltage drops below 70 perettet.
offending division is trigved and the safety functions will be assuurd by the redundant divisions. The three indepmdent 0/Gs, ord their essociated
- 3. Clarification of the diesel generator design details which ere to be divisions, provide sore thcet adagaste redseancy to sitigste the suggested sssplied by others (reference tpsestion 433.21(b)) and the criterie the design single-feiture scenario.
sust meet (i.e. Interf ace requiremants).
- 4. Clarification of the contirsJous and overtoed retings of the dieset item 3: The interf ace reasireamt in stsvert of rescense 435.21Cb) wos oddad generator definad in section 8.3.1.1.8.2.
es subsection 8.3.4.2 the some time es the response. sowever, the reference to that subsection was inadverte vity omitted in response 433.21(b).
Therefore, the reference hos been added per the ettsched moriup of page 20.3-253.13.
Itm 4: This information was provided in response 435.21(a), but in addition, has now been addad es subsection 8.3.1.t.8.2t$) [see attached aerkiel.
37.000 8.3.9 STAT 10m st*CrouT ttee 1: Any ona 4 the sie at power sources (i.e., the two ef f-site lines, three diesci genee stors, and one combustion turtrine geneester) has sufficient The ABWR coping onetysis for $tetton Stockout is presented in section copecity to brtng the plant to $sfe shutdonat. As stated in 8.3.1.2.1, ery one 19E.2.1.2.2.
Also, table 19E.2-2 presents design basis vetues for various of the three AC electricot divisiens con provide the emi=se safety functions plant persmaters that witi not be esteeded et the erd of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coptrig necess.ory to shut down the notit fross the Wrot foem ord movfyrem it in the
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. REPORT $0Rf4 CMKSARS8 TO PR!uf hRC DRAFT SER 153UES & CE RESPONSES FOR A8W SSAR DAPTER 8 ISSUES CE CONSIDERS RESa VED PER TMESE RESPONSES a
NtesBER NRC ISSUE GE RESPONSE duration for a Station Stockout event. Essed on a review of this coping safe shutdoun cordition.
enstysis and design informe<fon presented in other sections of the ABWR SSAR, the staff has identified the following stees of concern.
The dieset gamerators (m) are designad with bypess vetves for the DC solenoids such that they can be started manuelty without De power (i.e.,
i
- 1. Anotysis results damonstrating safe plant shutdoun een be accomplished essuming the DC betteries are discherged following 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of cwing). Also, I
starting with reestablishment of AC power to ery one of the three AC the cereustion turbine generator is started ty e smetter self-contained dieset j
divisions from either of fsite, dieset generators, or combustion turbine with its own bettery.
generator et the end of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of coping.
i
- 2. Justification for the proposed design =Alch provides en etternate AC Item 2: The cratmastion tutine generator (CTE) is inctuckd in the AsWR st.cpty (combustion turbine generator) but dictetes that its first priority Stenderd Ptent es e result m EPRI/ALW reazirements (ALW t;tility use be to supply AC power to non-Ctess 1E plant investment protection toeds Reoaireeents Document, sevision 1, Vol II, Chapty it. Section 5.2.4).
Its versus Ctess 1E toads needed to assure safe plant shutd3=n.
fuic*lon is consistent with those rewirements, nemety: 1) The wiit is non-Ctess 1E, and is provided to feed perminent non-sofety toads during LOPP
{
- 3. The cspecity and copebitity of the combustion turbine generetor to suopay events, 2) It is eveitobte to back up the Ctoss tE DGs, shoutd they feit or minina.se safe shutdown toeds and minimum required plant investment protection net be avaitable, and 3) It is capable of coping with a station blackout.
toeds et the same time.
The CTG essumes non-safety investment protection toads automaticetty. but the
- 4. Design and wastification of equipment for the environments expected durirva connection to each Ctess-tE bus is moruset. This is juselfied because: 1) 4 and fottowing the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> coping time enetyred for station blockout events.
On-site emergency power is provided tv three Ctess-1E DGs and no credit is taken for safe shutdown utilizing the CTE. 2) Although the CTG car, cope with
- 5. Clarification of how Division 2, 3, and 4 ore shutdown during a station the station blacteut, the AswR can cepe with station bieckout without the need blackout situation.
for the CTG, es described in 19E.2.1.2.2.
- 3) The CTG interface configuration provides indeperdent stanc2'y power for non-safety toeds and thus maintains
- 6. Clarification of the source of instrtsment power from DC or constant better seperation between safety ord non-safety systems. This etso prevents voltage constant freqJency sources during station blackout situotions.
the investment protection toads from having to be assuned ty the DGs.
- 7. Exteet to which the coebustion turbine generator complies with position In suumery, the ASWR meets et t regutetory reasirements without the CTG. It 3.3.5 of Regulatory Guide 1.155, Station slechout.
was arised in accordance with the EPR1/ALWR reatersments desent; therefore, its function is also consistent with that document.
Item 3: The CTG is rated to produce agpron metely 20% more poww then e DG (i.e., 6 89 f or the CTG, concered to 6.25 Pv4 3 0.8 pf = 5 mu f or a DG).
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9EPORT F0m elESMS8 TO Pt1#T I
mRC DRAJ1 SER issues & GE DESPomSES FOR Asut SSAR CareEP 8 ISSUEO E ConstDERS RESOLVED PER THESE aESPouSES j
NUMBER NRC !! SUE T Response 3-Neuever, the CTG is net designed, nor roupaired, to sosisme et1 investment protection loads in additlen to e DG teed. If the need ernse for the CTG to -
-[
essume the Ctess TE tweds en a DG tess, the investernt protection toads would I
be shed. This is eleo done os e precaution to oesure Moss TE tends de not adversly of fect flee CTG's ability to segurly power to the Ctess 1E loads. -
f 1
I
> ; The environmentet effects en electricot empsipment during a ststian 2
1 a-i txecLet event are espected to be tess severe then the accident envirereents
+
enetyred in tJction 3.11. This is because such espsiement would tue in its deenergired state, and thus would prochsce no intemet heet rise compared with I
l the erwirenennt. Likeelse, there enould be to other siytificant heet radiators f
f in any tricinity of the plant sewe the eroe immediately surreeding the reactor l
Itself. The*efore, ne additlenet anotysis has been done for the stettom i
blackout envirorument, nor is it considered necessery.
l t
tree 5: In a station blockout event, if division I instrtmentation is fectioning property, the operster should moresetty shut doun redundant i.
divisiers II,181 eruf IV in order to 1) reesce heet dissipetion within the contret rooms dite NweC is lost, and 23 conserve bettery energy for additionet
$4V capacity, or other specific purposes as W, os ivuficated in 19E.2.1.2.2. Ordy division 1 is essentiet to the stic eperation and should reamin functionet et ett times di:-ing thit event. This is why the divisien 8
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bettery hos significantly more cepecity then the other betteries.
I i
j An interface section 8.3.4.16 hos been added to assure this operator sction is
)
included in the applicant's Emeripency Opersting Precechares. (See ettsched 8
merk-se.)
t Itee 6: As e generet rete, ett Ctess 1E instrument power cones directly free f
the divisional DC buses. The enty exceptices are some E/O converters in the process radiation monitoring system. these require AC pow =e prowit>d by the
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. REPORT F M OUIESANS8 TO PRINT NRC DRAFT SER ISSUES & CE RECPONSES Fue AB'Jt $$AR CHAPitt 8 ITSUES CE C0KSl%RS RESOLVED PER THESC rE'. PONS *,
GE RESPONSE CUMBER hRC ISSUE Le vis the CYCE power sigply units. Non-divisional CYCFs also stwty power to i
tte run-Class 1E ares radietion detectors.
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i Itew 7: Att of the five criter es of neguter-se 135, sectius 3.3.5, are r *
- exceeded by the CTC <see SSAR sectir ; J.11).
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06/04/91-
'.00 CH8tSSUE
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-. REPORT FOM QUESANS8 TO PRINT.
NRC DRAFT SER ISSUES & GE RESPONSES FOR ASWR $$AR CMAP!ER 8 r
GE REQUESTS ADDITIONAL mRC GUIDANCE ON THESE ISSUES '
- ?
huMBER ~ NRC NSUE GE RESPONSE i
b 1.000 8.2 OFFSITE POWER SYSTEM '
Items 1-3: (See the response to Question 435.63.).
Based on inforention presented on figure 8.3-1 of the AsWR SSAR, it appears that the offsite power system constats of the following three sources:
Items 4-7: A new section 8.1.2.1.1, and associated figures 8.1-1 and 8.1-2,
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have been added which address seperation in accordance with these items (see
}
- 1. " A back feed from the transmission networir through the main transformer, attached mark-ws).
busduct, and two unit Auxiliary transformers to the Ctess 1E distribu tion
-.y systan imut tenmis. To initiate this back feed, the main generator aust be disconnected from this source by a generator breaker;-
ttem 8: The second peregraphs of sections 8.1.3.1.1.1 and 8.3.1.1.1 have been revised in accordance with section 8.3.4.9.
In addition, sections (1), (3)-
f
~
2.
An offsite line from the transmission network through the reserve and (4) of 8.3.1.1.7 have been eterified to attow feed from either of fsite
-Auxiliarytransformer to the Ctess 1E distribution system i m ut terminats; and source daring normat plant operation.
s 3.
A conbustion turbine generator to the Class 1E distribution system imut terminals.
' Item 9: CE questions the validity of this criteria. GDC 17 requires two
[
offsite sources. Yet, viy plants (including the A9WR) with more than two Section 8.2.3 indicates that these circuits, for the most part, are within divisions could not meet such criteria, because the toss of one of the offsite the ASWR design scope; however, ractions 3.1.2.2.8.2.2, 8.2.1 and 3.2.2 sources unsst effect more than ene divi.lon. Yet less reliable plant designs indicate that these circuits are, in tocat, out of the ASWR Standard Plant having only two divisions would meet the criterie. We suggest this item be I
i scope; thus, description and analysis demonstrating unpliance of the of f site deleted since it is redundant to SER Issue 8.2.1.
.j
. circuits to regulatory requirerents has not been provided in the ASWR $$AR.
'{
To initiste our review of 'the of fsite system, adhtionat information is There are no restrictions placed on testing of the offsite systems j
r v ireo for the foitowing items and/or positions.
Item 10:
- during normal plant operation.. Interf ace 8.3.4.9 provides for continuous feed -
1.
The inconsistency between sections 3.1.2.2.8.2.2, 8.2.1, 8.2.2, and 8.2.3 from both the preferred and etternate power sources.. Therefore, the need for
'f of'the A8WR $$AR es to what part of the offsite system is within ASWR scope.
' testing should be minimet, However, testing procedures ard frequency of '.
f testirag for the of fsite circuits is determined by the utility / applicant.
Y I
2.
The descrintion and analysis of.the of f site power system's preferred offsite power supplies fr m the utility-A9Wt interfaces to the Class 1E i
distribution system input terminals which i: wit?'n the A8WR Standard ptant item 11t The expiteit definition was added to Sdsection 8.3.1.1.1, as
- scope, requested (see attached anark-w ).
v i
3.
Inter 9 ace requirenents f or the of f site circuits f rom the utility-AaWR -
m e-
~
~
-w'v hwr
M[@
Ptge No.
2 06/04/91
.00 CM8 ISSUE
.REPORY FORM QUESANS8 TO PRINT NRC DRAFT SER ISSUES & CE RESPONSES FOR ASW SSAR CHAPTIR 8 CE RIJUES15 ADDITIONAL WRC CU10ANCE ON THESE ISSUES CE RESPONSE ktMBER WRC IWA item 12: The voltage and power requirements are given on Figure 8.3-1, F.ith interf aces out to the utility grid system eAlch 1.s outside the A8WR Stardard the utitity gry interf ace defined in Section 8.2.3, as modifled per the response to 435.5. What else is ment by the term " capacity and capability *?
ptant scope.
Des ription and analysis of criteria relating to physical and electrical 4.
seperstim between the normat and alternate preferred of f site ciecuits and (See sectim 8.2.2 added in response to ouestion 435.63.)
Itee 13:
beNen.ne preferred offsite and the onsite circuits inctu:fing in4tnsamtation and control circuits. Onsite circuits include Class 1E power s @ ty circuits and the Class 1E distribution system circuits to the loads.
5.
Interf ace criteria relating to physical and electrical separation between the normat and atternate preferred offsite circuits and between offsite and onsite circuits including instrismentation and control circuits, Physical lay out drawings which shows the physicat separation of the i
ts.
offsite cirw its and separation between onsite and offsite circuits. This shalt incit* 'he instrumentation and control circuits ass,ciated with each c:fsite circuit.
The physical arti electrical separation betweei the circuits associated 7.
withthe combustion turbine generator and other offsite circuits incitafing instrumentation and controt circuits.
Inconsistencies between retponse to questim 435.45 (or stction 8.3.4.9) 8.
and section 8.3.1.1.1 as to the normat of f site power feeds to Class 1E division I, II, and 111. Similarly, sections 8.1.2.1 and 8.1.3.1.1.1 are inconsistent.
9.
No single failure ground fault or other eberration in one offsite preferredeircuit between the plant switchr e end the Class if distribution system irput terminals shalt cause toss of offsite power to or chattenge in any way more than one Class 1E distribution system.
10.
Identification, analysis, and justification for each circuit or co p t part of the offsite system which will not be tested during normat
-w
+
Pese no.
3 06/04/91
.D0 CM8 ISSUE'
+
.REPtAT FORM QUESA458 TO PRINT NRC DRAFT SER ISSUES & GE RT*PONSES FOR Agut $$AR CMAPTER 8 GE REQUESTS ADolTIONAL *AC GUIDAaCE ON THESE ISSUES l'JMBER NRC iSiiUE z E RESPONSE plant operatfor<.
- 11. Explicit definition of nonant plant operation which states that it means att modes of plant operation including shutdown,~ refueling, and start up.
- 12. Capacity and capability of each of f, lte circuit to supply connected '
toads.
i
- 13. Definition of criteria applicable to offsite systems similar to Tabte '
'I 8.1-1.
1 2.000 8.2.1 Independence between offsite and onsite Systems.
The issue states that it is "the staff position that no sinate fatture, gree d i
fault, or other aberration in one offsite preferrvd circuit between the plant The fottowing criteria, specified in section 8.3.2.2.1 for the A8WR design, switchyard and the Class 1E distelbution system input terminals shall cause i glies that a single fatture of one 125 wDC system may jeopardire and thus toss of offsite power to or chattense in any way more than one Class TE cause loss of offsite eruf onsite power to one safety o. vision but wilt not distribution systee, division, or toed greg.*
jeopardize or cause loss of of fsite preferred AC power to any other safety j.
divistores.
GE questions the validity of this criteria; in particular, with the staff's l
interpretation to include the main and auxiliary transformers. CCC 17 "The unlikely less of one 125 VDC systmo does not jeopardize the s4 p ly cf regJires two offsite sources. Wowever, any plants (ir:cLuding the AguC) having preferred ard stan&y AC power to the Class 1E buses of the other toad '
two of fsite sources and more than two divisions could not meet such criteria, -
.j g roups.
because the loss of one of the of fsite sources must af fect more than one J
division. tet less reliable plant designs having only two divisions would j
This criteria, with respect to the DC system, meets the staff position that meet the crite*ia.
no single f ailure, gromd f ault, or other aberration in one of fsite preferred circuit between the plant switchyard and the Class 1E distritmation system
- The stateaumt quoted from section 8.3.2.2.1 refers to the individust Class 1E input terminals shalt cauce toss of offsite power to or chattenge in any way 125 VDC batteries which control the Class 1E switchgear feeding each Ctnss 1E more than one Class 1E distribution system, division,.or load gro w and is,-
6.9KV M/C bus. Each divisional bus is feed by its own divisional breaken tnerefore, acceptable. However, the effsite system being proposed for the idhicts are controtted by the 125 VDC battery of that same division. Theittore, ABWR ooes not meet this criteria. For exempte:
it is correct in that rio divisional battery f ailure can effect the feeders of
'the other divisions.
a Failure of the sirigte main transformer supplying two of the safety divisions will cause loss of offsite power to more than one safety division.
Page No.
4 06/04/91
.DO CH81SSUE
+ '
l
. REPORT FORet GUESANS8 TO PRINT '
[
WRC DRAFT SER IESlXS & CE RESPONSES FOR ASWR SSAR CMAPTER 8
~
j b.
Failure of any one of the four imit auxiliary transformers will cause j
loss of offsite power to more than one safety division.-
To initiate our review in this area, additional information is rwired for the following items.
?
1.
The extent Class 1E DC oower is used for control and protection of the a
offsite circuits from the switchyard to the terminal connection on the Class i
3 1E system.
f 1
-L 2.
Descriptive information or analysis demonstrating compliance of the ASWR j
design to the above stated criteria.
i l
I
- 3. ' Specific i:$entification and documentation of the above and other
(
exceptions to this criteria in the ALWR SSAR with justification.
I L
F 7.000 8.3.2.4 Cables in Cabivts/Panets-Item 1: There is no inconsistency between the referenced sections, because f
the statement in 8.3.1.1.5.1 refered to routing in raceways, which is externet
[
Section 8.3.1.1.5.1 states that divisional cables to and from the contairveent. to the control room area.
(*...terminst cabinets" has been changed to i
I and to and f rom the dedicated divisional egalpment in the reactor building
"... cabinets".) Mowever, separation is also maintained within the controt are routed in separate cable raceways for each division. Section 8.3.1.1.5.1 room penets in accordance with Reg Guide 1.75 and IEEE 384 further states that divisional cable routing is maintained up to the terminst cabinets in the main control room. This statement implies that separate cable the operator interface for the main control comptes does requirs circuits of i
t raceways for each division may not be maintained within cabinets and isp;es multiple divisions, or Class 1E verses non-Class 1E circuits, in close that non safety cables any be routed in the same raceway with divisional proximity. Separation criteria for these areas are addressed in 8.3.1.1.5.1.
~
Fire-e ated barriers comot be provided in the controt room itset', but the j
cables within cabinets or that re&ndant divisional cables may be routed in the swe raceway within cabinets. This statement contradicts other sectirvis remote shutdoem system (the redtsident system for the control room), provides of the ABWR SSAR neich require separate raceways from terminal to terminal acceptable risk for complete burnout of the controt reos.
including insioe of cabinets or other types of enclosures. To resolve this f
inconsistency and other concerns, additional information is required for the A reference to 8.3.1.4.2.2.3, Aich discusses separation within the controt following items.
room penets, was added to 8.3.1.1.5.1 (see attached mark-up).
l 1.
Inconsistency between section 8.3.1.1.5.1 and 8.3.1.4.2.2.3 as to I
required separation between redJndant circuits within a cabinet.
Item 2: The requested separation criteria for att types of enctosures is 4
a
Page No.
5 06/04/91
+
.DO CH81SSUE
. REPORT FORM QUESANS8 TO PRINT NRC DRAFT SER ISSUES & CE RESPONSES FOR AB nt S$AR CHAPTER 8 CE REQUESTS ADDITIONAL NRC GUIDANCE ON fnESE ISSUES CE RESPONSE C'JMBER NRC I5$UE delineated in the whole of section 8.3.1.4, and particuterly 8.3.1.4.2 and its s4 sections. In light of this detailed information, we do not understand the 2.
Criteria for seperation between safety (nr associated) and non safety cables and between divisional cables within cabinets or any other type of request. The NaC needs to specificatty identify where they feet information is tacking.
enctosure located inside and outside t*)e main control room.
3.
Marking of cables inside of cabinets and/or penets ;ref: section Item 3: Penets are marked eccording to section 8.3.1.3.
Cabtes inside of f
8.3.1.3.2.1(3)).
cabinets and/or penets are tagged et each end with the acpropriate divisional l
(or non-divisional) surkings consistent with the plant standards, and with the 4.
In addition, section 8.3.1.4.2.2.3 includes the statement that the design drawings or cable schedAe.
purpose of criteria for physical separation of cables in penets ic to preclude the possibility of fire propagating between redundant circuits and there multiple divisionet cables (or division & non-division cables) exist preventing safe shutdown of the plant. The staf f f eels that this statement of within a penet enclosure (i.e., the main contret console), merkings shalt be parpose sey be misteading in that it does not futty delineate the provided in accordance with the requirements in 8.3.1.3 by one or both of the requirements of CDC 2, 4, and 17. The purpose for physical separatico is to
)
following methods: 1) Each divisionet section, idisch is separated by metat prec!ude f ailure of non-safety circuits from causing felture of any safety circuit and to preclude f aiture of one safety circuit frosa causing f ailure of berriers, shalt be tabeled, or 2) each cable shati be tabeled. These any other redundant safety circuit (i.e. to preclude copion cause faite cf stipulations have been ackled to sesection (3) of 8.3.1.3.2.1.
safety cir uits). The purpose for having physical seperation in penets should be clarified in the AANt $$AR.
Ites 4: The purpose for physical separation has been rewritten as suggested (see attached serk-ts)).
"tes 1: The color coding methods for cables and receways are delineated in 9.000 8.3.2.6 Cable /Receway identification 5.3.1.3.1 and 8.3.1.3.2 (incitding 8.3.1.3.2.11.
(See Amenchnent 10. page 8.3-11->13.1 NRC guidance is needed on what more is required.
in regard to marking of cabl.es and raceways, response to question 435.29 indicates that the identification criteria spe *fied in section 8.3.1.3.1 and 8.3.2.3.2.1 futty conplies with the requirements of Regulatory Guide 1.75 (revision 2) and IEEE 384-1974. The stsff reviewed this criteria with respect Item 2: The method for distinguishing between non-Class TE circuits associated with dif ferent re&ndant divisions is detineated in 8.3.1.3.2, to the guidelines of position 10 and 11 of Regulatory Culpe 1.75 (revision 2) and section 5.1.2 of 1EEE 384-1974 and as a result identified a ruber of 4.e., " Associated cables are u1iquety identified by a longitudinal stripe To resolve these concerns, additionat inf ormation is recnired for and/or the date on the tabet. The color of the cable marker for associated concerns.
cables shalt be the same as the related Class 1E cable " tRC guidance is the following items.
needed en what more is s equirc<f.
- 1. The method f or color coding poiser, instrunentation and control cables and
Page No.
6 06/04/91
.00 CM81SSUE
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. REPORT FORM QUESANS8 TO PRIKT NRC DRAFT SER ISSUES & cE RESPONSES FOR A8 bit SSAA CMAPTER 8 E REQUESTS ADDITIONAL NRC GUIDAaCE OW TMESE ISSUES CE RESPONSE NUMBER NRC ISSUE 1
raceways.
Item L L Wrabitity statement has been ack$ed to section 8.3.1.3.2.1(3) 1 I
- 2. The method for distinguishing between Non-Class 1E circuits associated cona's'r.* with IEEE 384 (see attached).
l with dif ferent redtsident divisions.
Item 4: These concerns are already addressed in issue 8.3.2.4, ard in ite'es 1
- 3. The Arability of markings.
& 2 above. NRC guidarce is needed on set more is regJired.
f The marking of cables throughout the entire esble tength f ro terminst 5
)
I conne-lon to tetrainal comection including inside cabinets and/or penets.
The NRC stated asstrption that "...the proposed design will include redsident 11.000 8.3.3 PROTcCTIOW interrupting devices on att instrtsmentation ard controt cirev'ts as weit as Some circuits power circuits that pass through conteirment" is not correct.
8 1.3.1 Electric Penetrations do not have high fault current available, such as thermocouple circuits.
l Itco 7 of Sectici *..'.4.1.2 indicates that power circuits going through electric penetratfor c.enblies are protected against over current by redt;ridant interrw ting devices. In addition, response to questions 435.31(b)
Item h The requested informatfon was ad3ed to 8.3.1.4.1.2(7), but with the i
indicates that it is an ABWR desigr. requirement that redundant interrtpting hig5 availeM fault current stipulation.
devices be provided for electrical circuits goN thMxagh contairment penetrations, if the moniaue available fault current (l'icluding failure of upstream devices) is greater than the continuous current retirug of the item 2:
8-.4.4 has been modified to specify the reesirements for proper ccordination of thermal capability curves and protection of the penetr;;. tion penetration. Based on the above design requirements, it appears that the conductors (see attachef). Considering these penetrations are not CE scooe, proposed design will include redundant interrupting devices on att instrts:ientation and control circuits as weit as powe< circuits that pass WRC guidarce is needed on dat additional information 's ree&d from GE.
through containment. In addition, when calculating manious available f ault current at the penetration, current timiting devices wilt not be used in the Item 3: Section 5.4 of IEEE 741-1986 specifies that 1) "Where a pence c +un calculation (i.e. worst case f ailure or shorting of the *mtream or current limiting devices will be asstaned as a given in the calculation). Based on asseebly can indefinitely withstard the siamimum current available due to a f ault inside conteirvient, no special consideration is required.f$.4.21* and 2) the above interpretation, the staff concludes that the proposed d= sign meets Regulatory Guide 1.63 (revision 3) and is acceptable. To confir1a the above "Etectrical penetrations requiring special consideration shall be provided interpretetion and to resolve other retsted concerns, additional information with dtast primary protection coerating separate interrs.cting devices, or primary ard backup protectiori eperating separate interrupting k required for the following items.
devices.t5.4.2.11" and 3) "The tise-current curves of the dual primary
- 1. Descriptive information which explicitly states that electrical circuits protection or the primary and backtp protection shalt coos dinate with the
+
Page No.
T 06/04/91
.00 CH8155UE
+
. REPORT FORM QUESANS3 TO PRINT kRC DEAFT SER ISSUES 1 LE RESPONSES FOR ASWR $$AR CMAPTER 8 CE REQUESTS ADDITIONAL, NRC GUIDANCE 04 TMESE ISSUES -
Nt NBER WRC ISSUE GE RESPONSE includes att 'instrunentation and contret circuits as well as power circuits.
time-current capability curve of the electrical penetration to be protected.t5.4.2.21" This has already been provided per items 1 and 2 above.
- 2. Clarification of interf ace requirements presented in section 8.3.4.4 to htC guidarce is needed on what more is required of GE.
clearly state the criteria or design regJirements that must be demonstrated by (a) f ault current clearing-time curves for protective devices, (b) thermat capability curves of the penetration (c) location of protective devices, and item 4: The &scription "redmdant overcurrent interrupting devices" (d) power sgpliet for protective devices.
irberently attows either fuses or circuit breekers. anc guidance is nee:$ed on what more is required.
- 3. Descriptive icformation ediich clearly indicates how penetration protective devices will conform to each requirements of section 5.4 of IEEE Stardard M1-1936, IEEE Standard Criteria for Protection of Class 12 Power Sys'. ems and Ecydpaent in Nuclear Power Generating Systems, that is recopusended by position 1 of Regulatory Guide 1.63 (revision 3).
- 4. Criteria which would permit use of one current limiting device and one protective device as the redundant protectiv9 devices needed to meet the guidelines of position 1 of Regulatory Guide 1.63.
21.000 8.3.3.11 Fault Interrupting Capacity item 1:
8.3.1.1.5.2(4) has been modified to say: " Interrupting capacity of switchgear, load centers, motor controt centers, and distribution penets is Design criteria (4) in section 8.3.1.1.5.2 states that interrteting capacity eqJet to or greater than the maalaus available f ault current to which it is of switchgear, load centers, motor control centers, and distribution penets exposed." (See attached.)
is compatible with the short circuit current avaltable.at the Class 1E buses.
Based on this statement, it is not clear that the interrupting capacity of this equipment will be equal to or greater than the maxinua available f ault stem 2: Compliance of this eqJipment to industry standards regsired try the current to which it would be exposed. To clarify the criteria for the sap is already provided in section 8.3.1.2.
The ARC should give cuidance on interrupting capacity of equipnent ard to resolve other related conceres, what additional standards, if any, are being imposed.
additional information is required for the following items.
- 1. Clarification of the criteria for interrupting capscity, and e
- 2. Comtience of both Class 1E and son Class 1E switchgear, load center motor control centers, and distribution penets to arpticable industry standsrds.
. + -,
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Page No.
8'
'06/04/91'
.00 CN81SSUE'.
+
. REPORT FORM OUESANS8 TO PRINT f
mRC DRAFT SER ISSUES & GE RESP 0aSES FOR ASWR SSAR CMAPTER 8 GE REQUEST $ ADOITIceAL NRC EUIDANCE 08 iNESE ISSUES '
- )
NUMBER 'NRC ISSUE CE RESPONSE i
28.000 9.3.5 LIGHTING SYSTEMS Item 1:.The lighting levels are based on the IES recomumended inttnsities, es indicated in 9.5.3.1.1(1).
l Section 9.5.3.1.2 indicates that adequate tighting for any safety retered eres, such as ems used during emergencies or shutdouns, including those
. elong the appr@ nte access or exit routes, are provided free 3 dif ferent Item-2: Ittumination levels for ett erees are given in febte 9.5-1.
These.
tighting circuits. (e) Norma' (b) Stan&y, and (c) Emergency DC and/or
. are considered 100% tevels; therefore, the 50% tevets are half those given en.
self-contained bettery ffatures.
the table.
in order to comtete cor review cf lighting systems, ed6stionet information
'is re wired for the following items.
Item 3: We do not inderstand why there should be any such erees implied try f
[
- this w estion. NRC guidance is needed.
'f
- 1. Criterie for d et constitutes en edew ete level of tighting for various areas of the plant and for the various modes of plant operation.
l Item 4: Section 9.5.3.2(1) identifies norest tighting es non-essentiet.
- 2. Clarification of'the'tevet of lighting provided by 100 and 50 percent of Therefore, the source of power for nonent tighting is the non-Ctess TE AC f
normat lighting.
power distritvtion system.
- 3. Identification with justification for specific plant erees ord modes of
~l plant operation that do not meet criterie for d et constitutes adequate item 5: Section 9.5.3.3 indicates no periodic testing is reesired for normat tighting.
lighting. NRC guidance is neaded es to ey this is e licensing issue.
}
i
- 4. Source of power for normet tighting.
Item 6: Section 9.5.3.1.1(4)(r) indicates two power buses shotI steply
- 5. Frequency of inspection for norset tighting, lighting to staircases and posseges in mein buildings. The additionet bus ettous these areas to be temporetty pieced on 501 tighting (i.e., one power
- 6. Plant erees dere 50% tighting shall be secured with one stan&y lighting segply) while the other is wder inspection or maintenance, power sumty.
i
- 7. Method of distinguishing between normati sten &y, and Emergency DC ttem 7: Wiring / cables are seperated and color coded in accoethnce w!th circuits to assure that they will be routed separately, criterie detineated in subsections 9.5.3.1.1r7) and (6). respectivety; and in..
.{
8.3.1.3.
- 8. Source of power for sten &y lighting.
[
5f l
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4 #
ww-..
.-y.,-w,
..c-w
Page'4o.
9 06f04/91
.00 Ch81SSUE'
+
. REPORT FORet OUESANSS TO PRINT anC DRAFT SER ISSUES & CE RESPONSES FOR AgWR SSAR CMAPTER 8
' CE IEQUESTS ADDITIONAL N#C GulDANCE Du TWESE ISSUES
- p NUMBER NRC ISSUE CE RESPONSE
- 9. Separation between Je w stan*y power source circuits.
Item 8: The second paragraph of section 9 5.3.2.2 indicates that stan ey (essentist) tighting is provided by essentist power buses.
- 10. Level of lighting with 100 percent and 50'perient of stan @ y tighting for 3
various areas.
Item 9: Tabte 9'.5-3 shows areas which require more than one division of
- 11. Seismic design of stan cy tighting.
stoney tipting. These divisions are separated in accordance with same criteria for Class 1E divisions in generet (Section 8.3.1.4.2).
- 12. Compliance of stan & y tighting with Class 1E circuit requirements.
- 13. The re&ndancy of che emergevy DC tighting circuits.
Item 10: ttiaaninetton levels for all areas are given in Table 9.5-1.
These are considered 100% tevets; therefore, 50% tevels are half those given in the
- 14. The levet of ittismination of emergency tighting.
t able.. Areas specificatty designated for stanty lighting are identified in Tabte 9.5-3.
- 15. Periodic inspection and testing of lighting.
- 16. Justification for not having self contained battery fixtures seismically item 11: The third paragraph of section 9.5.3.2.2 indicated that stan c y qualified.
lighting was "in coactience with the starufards"; however, this has been modified to clearly state compliance with Class 1E standards. : Class 1E
- 17. The illumination levels with justification of the self contained qualification includes Scismic Category I.
betteryfixtures.
- 15. Justification for he.ing self contained battery fisture tighting turn o8f Item 12: (See Item 19) with restoration of power versus restoration of adequate light.
- 19. Justification for not having any seismically spatified tighting.
Item 13: The DC emergency tighting is redundant to the AC stanty tighting, which is red e dent to the normal AC tighting. DC ivwr lighting is Nt autti-civisional within a given area, tut is of the same division as the ares (i.e., de-ignated fire bomdary) it serves, as indicated in Tabte 9.5-4.
Item 14: The minintss ititseinstion levels for DC
. gmy tighting are given.
In Table 9.5-4.
i
.J
Page No.
10 06/04/91 9
.00 CM51SSUE
+
. REPORT FORM QUESANS8 TO PRINT NRC DRAFT SER !$5UES & GE RESPONSES FOR A8WR sat CMAPTER S CE REQUESTS ADolTIONAL NRC GUIDA2CE ON THESE ISSUES WUMBER NRC ISSUE CE RESPONSE Itee 15: lespection and testing requirements are identified in Section 9.5.3.3.
The fremency of testing is dependent m the operating and enintenance procedures of the utility aplicant.
Item 16: The auestion is erroneous. Self-contained battery fixtures are seismicattp @ atified as stated in the test paragraph of secti-6 9.5.3.2.4.
Item 17: The self-contained battery fixtures are re w ired to meet the illtr.inat'en levels given in Tabte 9.5-4.
item 18: As indicated in subsections 9.5.3.*.1(4)(f)1(g), AC essentist lighting has no en/off switches; therefore, r?storation of AC essentist power to an area would assure lighting circuits are energirad. The voltage necessary to activate the switchirs relay of the battery fixture would also be suffic:ect to provide adequate light to the area.
Item 19: The question is erroneous. The stan&y lighting, the DC emergency tighting, and the self-contained battery fixtures are att seismically qualified as indicated in sections 9.5.3.2.2 (see item 11), 9.5.3.2.3, and -
9.5.3.2.5, respectively.
31.000 8.3.7 TESTING stee 1: Section 8.3.1.1.5.3 his been sodified to specificatty state conformance with Regulatory Guide 1.118 and IEEE 338 (see attached). The Section 8.3.1.1.5.3, Testing, indicates that the design of Class 1E ewipnent specific provision for testing with an edditional attowance for single failure provides for periodically testing the chain of systee elements from sensing is addressed in Section 5(4) of IEEE 338.
devices through driven equipment to assure that Clas,s 1E equipment is functioning in accordance with design requirements. This section also inplies that the requirements of the single failure criterion described in items 2-4: This information is contained in the Technical Spxifications, IEEE Standard 379 are met with respect to testing of Ctass 1E equipment. The Chapter 16.
staff interprets this section to mean that one complete electrical system k
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.00 CH81SSUE
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. REPORT f0RM CtJESANSS TO f*RINT NRC DRAFT SER ISSUES & CE RESPONSES FOR ABWR SSAR CMAPtER 8 CE REQUESTS ADDITIONAt. NRC GUIDANCE ON THESE ISSUES NUMBER NRC ISSUE CE RESPONSE division may be deenergized and taken out of service for maintenance and/or repair during any mode of plant operation and still have the remaining item 5: There are no divisionst cross connections required for testing electrical systems in compliance with the single failure criterion. The purposes in the ABWR Standard Plant 9esign.
stsff concludes that this design provision for testability of electrical systems as interpreted meets the suf ficient testability requirement of 1
Criterion 1T and is acceptable. In order to confirm and clarily this Item 6: The approprir'te versions for att 1EEE standards sre given in Table interpretation in the ASWR SSAR and ackfress other related issues, additional 1.8-21.
.information is required for the feltcwing items.
- 1. Caplicit statement for testability charing normat ptar,t operation white item 7: Certain conponents camot be futty tested during reector geration meeting single falture requirements with remaining systems for eny design without degrading plant operability w safety. These were specificatty basis event.
Identified in response 420.120.
- 2. Proposed allowed outaga times for one division to be out of service to perform preptemed and triplanned maintenance.
Item 8: We cannot determine any inconsistencies between these two sections.
If the stsposed inconsistencies are related to the e tatements involving
- 3. Frequency for periodically testing each systes element to assure its applicability, these have been removed in association with SER issue 8.'t.
availability to mitigate design basis events.
Otherwise, the NRC needs to specificatty identify the supposed inconsistency.
t
- 4. Basis for establishment of test freq'aency for each system element.
Items 9, 10 and 11: This informtion is contaired in the Technicet
- 5. Identification (with justification for their use) of any divisional cross Specifications Chapter 16.
connection which must be used to meet the above design provision for l
testability.
(
Item 11: The testing and calibration of the diesel generator overcurrent
- 6. Clarification of the version of IEEE Standard 379 being referenced in relay is based primarity on the ratay manuf acturer's reconsnardations; and aiso section 8.3.1.1.5.3.
on the utility /amticant's surveittanct test procedures. This tevet * 'etait
- 7. Identification with justification for any areas of nor;-conotiance with the above design provision for testabitity.
i The conn rments to meet the requirements of Regulatory Guide 1.47 Item 13:
e
- 8. Inconsistex y between section 8.3.1.1.5.3 and 8.3.1.2.2 with respect to are given in $$AR sections 8.3.1.2.1 C)(d)S(3)(e), and a tisting of meeting the single failure criterion while testing one division of the CYCF annunciations associated with this requirement is given in section power supply system.
C.3.1.1.8.5.
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. REPORT FORM OUESANS8 TO PRINT M C DRAFT SER ISSUES & GE RESPONSES '.JR ASWR SSAR CHAPTER 6 GE REQUESTS ADDITIONAL WC GUIDA#CE ON THE'A ISSUES -
NUMBER htC ISSUE GE RESPONSE
- 9. Periodic testing provisions to assure the capability of the diesel generator to accept toeds in any toeding order (re,ference: 435.18).
- 10. Periodic testing to demonstrate the dieset generator's aspebility of
-being started in 13 seconds and futty toeded within 30 seconds.
- 11. Testing and calibration of the dieset pecerator over current retey.
- 12. Testing and/or enetysis to be perfonced perloolcotty to demonstrate the capability of the dieset generator to stgiply the octuel futi design basis
- toed current for each sequenced toed rtep.
' 13.' Interf ace requireewnts for cooptience with Regulatory Guide 1.47, Sypassed and Inoperable Status Indication for Nui;teer Power Plant Safety Systems and BTP PS8-2. Criterie for Atenes and 1:1dications Associated with
'Dieset-Generator Unit Sypassed and Inoperable Status.
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