ML20112A669
| ML20112A669 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/13/1985 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-5-045, 2NRC-5-45, NUDOCS 8503180414 | |
| Download: ML20112A669 (8) | |
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(412 787 5i (412)923-1960 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plaza. Building 2. Suite 210 Pittsburgh, PA 15205 March 13, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chief Licensing Branch 3 Office of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 PSB Electrical Outstanding Issues
REFERENCES:
- 1) 2NRC-4-150, dated September 20, 1984
- 2) 2NRC-4-162, dated October 10, 19 84 Centlemen:
This letter forwards responses to the issues lis ted below which were provided by PSB.
Responses were provided in References 1 and 2, and subse-quently discussed in a meeting on December 14, 1984, for which no minutes have yet been provided.
FSAR changes described in these revised res ponses are intended to be incorporated upon acceptance by PSB.
The following items are attached:
A t tachme nt 1:
Revised response to outstanding Issue 196 of the Beaver Valley Power Station Unit No.
2 Draft Safety Evaluation Repo rt,
Section 8.3.3.1.1 (originally provided in Reference 2). :
Response to Outstanding Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Section 8.3.3.3.5.
A t t achment 3:
Res ponse to Outstanding Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Sect ions 8.3.3.3.6 and 8.3.3.3.15. : Response to Outstandiag Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Section 8.3.3.3.14. :
Response to Outstanding Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Section 8.3.3.3.16.
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8503180414 850313 PDR ADOCK 05000412 E
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Unitcd Stctuo Nuciscr RIgulctcry Commiosion Mr. George W. Knighton, Chief PSB Elcetrical Outstanding Issues Page 2
- : Response to Outstanding Issue 199 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report, Sect ion 8.3.3.7.2 (originally provided in Reference 1).
DUQUESNE LIGHT COMPANY By e.
E.VJ. Woolever Vice President GLB/wjs Attachment cc:
Mr. A. Ungaro, Section Leader (w/a)
Mr. B. K. Singh, Project Manager (w/a)
Mr. G. Walton,'NRC Resident-Inspector (w/a)
Mr. L. Rubenstein, Assistant Director (w/a)
COMMONWEALTH OF PENNSYLVANIA )
)
SS:
COUNTY OF ALLEGHENY
)
On this
/J day of N
/ /8 8, before me, a
' Notary ' Pub lic in and for said Commonwealth and County, personally appeared lE. J. Woolever, who being duly sworn, deposed and said that (1) he is Vice
. President ' of -Duquesne Light, (2) he is duly authorized to execute and file
- the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the bes t of his knowled e.
O Notary Public ANITA ELAINE REITER, NOTARY PUBLIC ROBIN 3Cfl TOWNSHIP, ALLEGHENY COUNTY MY COMMISS: Oft EXPIRES OCTOSER 20,1986 b
j ATTACHMENT 1 Response to Outstanding Issue 196 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report Draft SER Section 8.3.3.1.1:
Submerged Electrical Equipment as a Result of a Loss-of-Coolant Accident accide nt, fluid It is the - staf f's concern that following a loss-of-cc.
- r.
(from the reactor coolant system and from operation ot rae energency core cooling systems) may collect in the primary contairusent and reach a level that may cause certain electrical equipment located. ins ide. the contaimeent to become submerged _ and thereby rendered inoperable.
Both safety and nonsafety-related electrical equipment is of concern because their failure
- may cau se
- .. elect rical fault s that would - compromise the operability of redundant - emergency powe r sources or the integrity of the containment elect rical penetrat ions.
In ad di t ion, the safety-related electrical equipment that may be subme rged is ' also. of concern if this equipment is required to mitigate the consequences of the accident for both the short-term and long-term' emergency core cooling system functions. and for containment isolation.
The staf f's position, in regard to submerged equipment, is that all elec-trical equipment must be located above the maximum possible flood level or be qualified for submerged operation, or the lack of qualification 'eust be
-justified.
By Amendment 3 to the FSAR, the applicant provided a listing of safety class, equipment that may become submerged as a result 'of a LOCA and are not designed and qualified for submergence. L in justification of the lack
- of - qualification, the applicant stated that ' the design of the Cla,s IE distribution system satisfies the isolation criteria by ensuring that the failure of ' the subme rged ~ equipment will not degrade 'the Class 1E power source.
Clarification of the isolation criteria and how it ensures that Class 1E systems will not be' degraded will be pursued with the applicant and the result s of the staf f review will be reported in a supplement to this report.
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Response
All Class 1E electrical equipment which may become submerged as a result of a LOCA, as. listed in the response provided for 430.18, Amendment 3, is electrically tripped by a Class IE system, disconnecting its Class 1E power source upon. a high flood level indication. The Class 1E level trans-mitters providing ' the sensing and ~ ins trumentation for this ~ high flood
-level Indication.will be qualified for submergence.
Two Class 1E sensors
' (orange ' and ' purple train-related) will be located below the Class 1E electrical equipment, which may become submerged ' as a result of a LOCA.
Figure 7.4-27 shows a typical system logic for this tripping function. In
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accordance with. plant procedures, calibrations will be perfo rmed at a refueling frequency.
ATTACHMENT 2 Response to Outstanding' Issue of the Beaver Valley Power Station Unit No. 2 Safety Evaluation Report SER Sect ion 8.3.3.3.5:
Adequacy of cable Separation Inside Balance-of-Plant Cabinets (Text unavailable to DLC.)
Response
The subject control switchboards and instrument cabinets are located in a protected area and are not subject to external energetic events such as flood, high-energy pipe rupture, and missiles.
Electrically ge nerated fires caused by fault current are not considered to be a hazard because of the.tse of fire-retardant material and' low-energy cables.
The 1-inch separation is justified because it will prevent interaction' between wire bundle s res ult ing from electrical potentials or heated wire caused by e le ct rical-faults.
This separation provides sufficient independence between redundant circuits and an acceptable level of protection to Class IE circuits in accordance with the independence and single-failure requirements of CDC 17.
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ATTACHMmiT 3-
' Response to Outstanding Issue of the
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Beaver Valley Power Station Unit No. 2 Safety Evaluation Report SER Sect ion' 8.3.3.3.6 and ' 8.3.3.3.15 :
Additional Tests and Analyses for Specified Cable Configurations
-(Text unavailable to DLC.)
- Response:
As agreed at the September 26,1984, meeting, DLC has provided a detailed description and justification for configurations that were found accept-able on other dockets without testing.
This information was provided _ in letter 2NRC-4-270, dated October 16,.1984.
Since that submittal provided justifications and analyses which are consistent with those described as acceptable in other tecent SERs, testing or additional justification and analyses are unnecessary for NRR to find these configurations acceptable.
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' ATTACHMENT 4 Response ' to Outstanding Issue of the Beaver Valley Power Station Unit No. 2 Safety Evaluation Report
_SER Section 8.3.3.3.14 :
Routing of Power Circuits in the Cable Spreading
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Area,-Control Room,.and Computer Room (Text unavailable to DLC.)
Response
In letter 2NRC-4-270, dated October 16, 1984, DLC provided the text of a proposed revision to the BVPS-2 FSAR. The attached change to that revision -
' addresses the reviewer's concern.
[I ATTACHMENT 5 Response to Outstanding Issue of the Beaver Valley Power Station Unit No. 2 Safety Evaluation Report c
-SER Section 8.3.3.3.16:
Frequency of Cable Identification Markings (Text unavailable to DLC.)
Response
A 15-foot maximum marking distance is sufficient to facilitate visual verification that the cable installation'is in conformance with separation criteria.
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t ATTACHMENT 6 Response to Outstanding Issue 199 of the Beaver Valley Power Station ~ Unit No. 2 Draft Safety Evaluation Report Draf t-SER Section 8.3.3.7.2:
Compliance with RG 1.63 Sect ion 8.3.1.2.1 of the FSAR indicates that primary and backup con-t ainment electrical penetration protection is provided only where the available ~ fault-current exceeds the current-carrying -capabilities of penetration conductors. This design for contairusent electrical penetration
- does ' not meet the guidelines of position 1 of Regulatory Guide' 1.63.
Position 1 requires primary and backup protection where maximum available fault-current exceed s the current-carrying capability of the penetrat ion versus capability of the conductors.
By Amendment -3 to the FSAR, the applicant indicated that the Beaver Valley design provides primary and backup protection as required by RG 1.63 and that the following additional information would be provided by March 1984:
- a. fault-current ve rsus time curve for each representat ive type cable conductor.which penetrates primary containment
- b. test report which verify the capability of penetration to withstand the total range of time versus fault. current fo r wo rs t case environmental conditions.
Revision to the FSAR to indicate compliance to RG - 1.63 without exception and review of the above additional information will be pursued. with the applicant.
The results of the staf f review will be reported in a supple-ment to this report.
Response
The following additional information was provided in letter 2NRC-4-150, dated September 20, 1984.
a.
fault - current ve rs us time curves for each representative type cable conductor which penetrates primary containment
.b. test repo rt exce rp t s wh '.ch ve rify the capability of penetrations to withstand the total range of time versus fault current for wors t case environmental conditions GDC 51 is met by providing penetration assemblies which are designed to withstand, without loss of mechanical integrity, the maximum short-circuit current.ve rs u s ' time conditions that could occur given single random failures of circuit overload protection devices.