ML20115E686
| ML20115E686 | |
| 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 8504190255 | |
| Download: ML20115E686 (12) | |
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THIS LETTER, 2NRC-5-045. DATED MARCH 13, 1985, IS BEING REISSUED
[TO INCLUDE ATTACHMENTS E SH g RE INADVERTENTLY OMMITTED.
(412 87 5 Nuclear construction Division Thy 6
Roomoon Plaza, svilding 2. Suite 210 E
Pittsburgh, PA 1520s March 13, 1985
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United States Nuclear Tegulator / Commission Washington, DC 20555
.1 ATTENTION: C_Mr.; George W.1Knighton, 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 b
REFERENCES:
- 1) 2NRC-4-150, dated September 20, 1984
- 2) 2NRC-4-162, dated October 10, 19 84 Gentlemen:
This letter forwards rssponses to the issues listed below which were provided by PSB.
Responses were provided in References 1 and 2, and subse-e quantly discussed in a meeting on December 14, 1984, for which no minutes have yet been provided.
FSAR changes described in these revised responses are intended to be incorporated upon acceptance by PSB.
The following iemas are attached: :
Revised response to Outstanding Issue 196 of the Beaver Valley Power Station Unit No.
2 Draft Spfety Evaluation Repo rt,
Section 8.3.3.1.1 (originally provide.d in Reference 2).
L I : ' Res ponse to Outstanding Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Section 8.3.3.3.1.
7 1
A t t achment 3: Response to Outstanding Issue of the Beaver Valley Power Sta-
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tion Unit No. 2 Safety Evaluation Report, Sect ions 8.3.3.3.6 r
and 8.3.3.3.15.
" : Response to Outstanding Issue of the Beaver Valley Power Sta-tion Unit No. 2 Safety Evaluation Report, Section 8.3.3.3.14
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A ttachment 5 : 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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8504190255 850313 PDR ADOCK 05000412 E
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U2itt:d Sectes Nuclocr R:gulctory Commissicn f
Mr. G33rg3 W. Knighten,. Chief PSB Electrical 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).
7 DUQUESNE LIGHT COMPANY By e.
E.VJ. Woolever Vice President I
4 GLB/wjs At tachment Mr. A. Ungaro, Section Leader (w/a) cc:
Mr. B. K. Singh, Project Manager (w/a)
Mr. G. Walton, NRC Resident Inspector (w/a)
Mr. L. Rubenstein, Assistant Director (w/a)
COMMONWEALTR OF PENW8YLVANIA )
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$s:
l COUNTY OF ALLECNENT
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On this L8 N day of Neh
//f8, before me, a Notary Public in and for said Commonwer.' s and County, personally appeared E. J. Woolever, who being duly sworn, d6 god and said that (1) he is Vice President of Duquesne Light, (2) he is du authorised to execute and file j
the foregoing Submittal on behalf of said Ca sny, and (3) the statements set I
forth in the Submittal are true end correct to the bes t of his knowledge.
l W/
Notary Public ANITA ELAINE REITER, NOTARY PUBUC RUBIN 3CN TOWNSHIP, ALLEGHENY COUNTY MY COMMISS:CN EXPIRES OCTOBER 20,1986 l
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United Stetos Nuciocr R guictory Cosuniesion Mr. C3cego W.,Knighpon, Chief PSB Electrical Outstanding Issues Page 3 1
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NR/NRC/PSB/0I Attachment w/actachment bec:
J. J. Carey w/ attachment W. T. Wardsinski w/ attachment E. J. Woolever w/act."*hment R. E. Dougher w/att achment l
C. E. Ewing w/ attachment T. D. Jones w/ attachment E. F. Kurts, Jr.
w/ attachment J. R. Latshee w/ attachment.
T. P. Noonan w/ attachment J. A. Bocco w/ attachment R. M..Siegel w/ attachment R. J. Swiderski w/ettachment l
C. L. Beatty w/ attachment l
E. T. Eihaman w/ attachment-R. W.. Pedia.
w/ attachment i
K. M.-Holcumb w/ attachment l
J. Lee', Esq..
w/ attachment.
R. E. Martin w/ attachment J. D. O'Neil w/ attachment l
S. L. Fernick, Jr.
w/ attachment K. A. Tromler w/ attachment T. J. Zogleann w/ attachment A. A. Dasenbrock w/ attachment G. R. Oliver w/attachmen't D. E. Burke (CEI) w/ attachment R. G. Schuerger (CEI)
B. M. Miller (2) (OEC) - w/actachment i
w/ attachment J. Silberg (3 PPT) w/ attachment D. Chamberlain (S&W) w/att achment J. 5. Chin (S&W) w/ attachment (3)~
F. Raysirear (S&W)(5)
T. J. Lex (W)
- w/ attachment-i B. Lorens (W)
- w/ attachment
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- w/ attachment NCD File
- w/ attachment l
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ATTACHMENT 1 Response to Outstanding Issue 196 of the Beaver Valley Power Station Unit No. 2 l
Draft Safety Evaluation Report Draf t SER Section 8.3.3.1.1:
Submerged Electrical Equipment as a Result of a Loss-of-Coolant Accident It is the staf f's concern that following a loss-of-coolant accident, fluid (from the reactor coolant system and from operation of the energency core cooling systems) may collect in the primary containment and reach a level that may cause certain electrical equ_ipment located inside the containment to become submerged and thereby rendered inoperable.
Both safety and nonsafety-related electrical equipment is of concern because their failure may cause electrical faults that would compromise the operability of redundant emergency powe r sources or the integrity of the contaitument elect rical penetrat ions.
In addition, the safety-related electrical that may be submerged is also of concern if this equipment is equipment for both the short-required to mitigate the consequences of the accident l
term and long-term emergency core cooling system functions and for containment isolation.
j 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 l
be qualified for submerged operation, or the lack of qualification must be j
justified.
l By Amendment 3 to the FSAR, the applicant provided a listing of safety i
l ches equipment that may become submerged as a result of a LOCA and are not designed and qualified for submergence.
In justification of the lack of qualification, the applicant stated that the design of the Class IE the distribution system satisfies the isolation criteria by ensuring that f ailure of the submerged equipment will not degrade the Class IE power l
Clarification of the isolation criteria and how it ensures that source.
Class 1E syst'eus will not be degraded will be pursued with the applicant and the results of the staf f review will be reported in. a supplement to this report.
Response
1E electrical equipment 4ich may become submerged as a result All Class of a LOCA, as listed in the response ~ provided for 430.18, Amendment 3, is l
electrically tripped by a Class 15 systen, disconnecting its Class 1E l
power source upon a high flood level indication. The Class 18 level trans-mitters providing the sensing and instrumentation for this high flood level indication will be qualifled for submergence.
Two Claes IE sensors (orange and purple train-related) will be located below the Class IE 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 r
accordance with pihat procedures, calibrations will be performed at a refueling frequency.
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9 ATTACHMENT 2 Response to Outstanding Issue of the
, Beaver Valley Power Station. Unit No. 2
.f Safety Evaluation Report SER Section 8.3.3.3.5:
Adequacy of Cable Separation Inside Balance-of-Plant
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i Cabinets (Text unavailable to DLC.)
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Response
cabinets are located lin a 1
The subject control switchboards and instrument protected area and are not subject to external energetic eve,nts such as flood, high-energy pipe rupture, and missiles.
Electrically generated fires caused by fault current are not considered to be a hasard because of i
the use of fire-retardant material and low-energy cables.
The 1-inch separation is justified because it will prevent interaction between wire bundles resulting from electrical potentials or heated wire caused by electrical faults.
This separation provides sufficient independence between redundant circuits and an acceptable level of protection to Class 1E. circuits in accordance with the independence and single-f ailure requirements of GDC 17.
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Response to Outstanding,Isses of the Beaver Valley Power Statio? Unic No. 2 Safety' Evaluation Esport 4
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StR'[Section 11. 3. 3. 3. 6 end 8.3.3.3.15 :
Additional Tests and Analyses for i
Specified Cad e 'G9nfigurations (Text unavailable to DLC.)
R3sponse:
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',As agre4f, at the September 26, 1984, meeting, DLC has provided a detailed l
description and justification for configudations that were found accept-cble on other dockets without testing.
This inforam fon 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 recent SERs, testing or additional justification, s,-d analyses are unnecessary for NRR to find these configurations acceptable
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ATTACHMENT 4 i
Response to Outstanding Issue of the l
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 Area, Control Room, and Computer Room (Text unavailable to DLC.)
Response
In letter 2NRC-4-270, dated October 16, 19 84, Dic provided the text of a proposed revision to the BVPS-2 FSAR. The attached change to that revision addresses the reviewer's concern.
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1 raceway or cable and a
barrier is 1 in.
as shown on Figures 8.3-22 (Detail E), 3 4, 3 5, 38, and 39.
i Testing performed for the NRC by Sandia I. abs (SAND 7F-IF10C) 1 demonstrated the effectiveness of tray covers and enclosed bot-toes for parallel trays, one over the other, when a fire was induc ed.
This test was done with non-IEEE 383 cualified cable, and it shows the effectivenesa of the ' covers.
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Position C.9 j
i Cable ' trays for e c.ol and instrumentation cables may be filled above the side rails where the overfill has been limited to a maximum of i 1/2 in. above the top of the side rail and where solid high-hat covers with a 2 in, raised flat center section are used to enclose the top of the cable tray as shown on Figure 8.3-48.
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Position c.10 Class 1E cable and raceway. shall be marked at intervals not exceeding 15 'f t and shall be plainly visible.
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Position C.12
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Power cables that supply power to control room distribution panels, limited to 120V ac and/or,125V de, are:
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Enclosed in rigid conduit in the cable spreading room.
2.
Enclosed in rigid conduit, with flexible conduit at entrsace to the panels.
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' Power cables to f acilities serving the control room, limited b) to -120V ac and/or 12 5" de. are enclos ed in rigid conduit except at entrance / exit to floor sleeves in the cable spreading room and control room, and at entrance to equip-ment in the centrol room.
c)
Othar. power cables (480V and 120V ac service) that traverse the cable spreading room to provide services (ventilation.
etc.) to this area are enciesed in rigid conduit.
d)
The loss of the above cables..or the control room or cable spreading room due to the design basis event fire, will not compromise the capability to achieve cold shutdown as out-lined in Section 9.5.1 and in the Fire Protection Evaluation Report.
e)
The Beaver Valley Fower Station - Unit 2 design utilizes a single cable spreading room.
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Position C.16 (Sa ction 5.6.2 of IEEE-384) 17 The minimum 6 in. separation (or a barrier) applies to spacing betwec.t exposed terminals, contacts, and equipment of redundant i
Class IE circuits or Class IE' and non-Class IE circuits for j
testing and maintenance purposes.
A minimum of.1 in separation (or. a barrier) is required be tween redundant wire bundles or
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Class IE and non-Class LE wire bundles.
The min ~1n'um of 1 in.
separation is suf ficient because the control toerds are protected from and/or are not subj ect to hazards such as external fire, flooding, high energy piping, and missiles.
Internal electrical fires are not considered a hazard due to fire retardant meterials and low energy application.
Separation requiriments fo r Westinghouse MSSS ecuipment are specifically addressed in Section 7.1.2.2.
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ATTACHMENT 5 Response to Outstanding Issue of the Feaver Valley Power Station Unit No. 2
_ l Safety Evaluation Report
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SER Section 8.3.3.3.16:. Frequency of Cable Identification Markings (Text unarailable to DLC.)
Response
A 15-foot maximus' marking distance is sufficient to facilitate visual verification that the cabin installation is 'in conformance with separation criteria.
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r, ATTACHMENT 6 Response to outstanding Issue 199 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report Draft SER Section 8.3.3.7.2:
Compliance with RG 1.63 Ssetion 8.3.1.2.1 of the FSAR indicates that primary and backup con--
t aimment electrical penetration protection is provided only where the fault-current exceeds the cur rent-carrying capabilities of cvailable psnetration conductors. This design for containment electrical penetration does not meet the guidelines of position 1 of Regulatory Guide 1.63.
Position 1 requires primary and backup protection where ariximum available fault-current exceeds. the current-carrying capability of the penetration varsus capability of the conductors.
By Amendment 3 to the FSAR, the applicant indicated that the Bester Valley design provides primary and backup protection as required by BG 1.63 and i
the following additional information would be provided by March 1984:
that
- n. fault-current versus time curve 1 for each representative type cable l
conductor which penetrates primary contaimment G.
- b. test report which verify the capability of penetration to withstand the '
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l total range of tinse versus fault current for worst case environmental l
conditions.
Revision to the FSAR to indicate compliance to RG 1.63 without exception l
sad review of the above additional information-will be pursued with the-
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applicant. The results of the staf f review will be reported in a sapple-ment to this report.
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Response
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i The following additional information was provided in letter 2NRC-4-150, i
dated September 20, 1984.~
- a. fault current versus time curves for each representative type cable conductor"which penetrates primary containment
- b. tese repo rt axcerpts which verify the capability of' penetratis.s to i
withstand the total range of time versus fault current for worst case environmental conditions CDC 51 is met by providing penetration assemblies which are designed to withstand, without loss of mechanical integrity, the maximum short-circuit cuerant versus time conditions. that could occur given single random failures of circuit overload protection devices.
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