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Forwards Revs to FSAR Sections 1.8,7.1,7.2,8.1,8.3 & Responses to Questions 430.119 & 430.131.Revs Made to Clarify Statements in FSAR Re Electrical Separation & Flexible Conduit.Changes Will Be Incorporated in Amend 34
	ML20125E546
Person / Time
Site:	Clinton
Issue date:	06/11/1985
From:	Spangenberg F; ILLINOIS POWER CO.
To:	Butler W; Office of Nuclear Reactor Regulation
References
	NUDOCS 8506130155
	Download: ML20125E546 (27)
	v • d • e

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U-600157 L34-85 (06-11 )-L 4

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1A.120 ILLIN0/8 POWER COMPANY CLINTON POWER STATION. P.o. BOX 678. CUNTON. tLUNoIS 61727 Docket No. 50-461 Director of Nuclear Regulation Attn:

Mr. W. R. Butler, Chief Licensing Branch, No.2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Clinton Power Station Unit #1 Electrical Separation and Flexible Conduit

Dear Mr. Butler:

Enclosed for your review is an advance co'py of revisions to Final Safety Analysis Report (FSAR) sections 1.8, 7.1, 7.2, 8.1, 8.3 and Responses to Questions 430.119 and 430.131. These revisions have been made primarily to clarify statements in the FSAR regarding electrical separation and flexible conduit.

In addition, Illinois Power (IP) has made two changes to its initial licensing position on electrical separation.

First, IP has chosen to utilize the analysis option offered in Regulatory Guide 1.75, Revision 2, Section C, Paragraph 6.

As stated in the revised FSAR page 8.1-13. IP deviates from the Regulatory Guide in that the analysis completed will be on permanent file, available for NRC review, but will not be an integral part of the FSAR.

Second, the revisions made to FSAR Page 8.3-24 and 8.3-26, concern-ing raceway clearances, deviate from IEEE-384, 1974, Paragraph 4.6.1.

f These changes have been through IP's formal review and will be F

' incorporated into the PSAR in Amendment #34, scheduled for issuance in July 1985. If you have any questions regarding this material, please contact me.

Sincerely ours, l

9'.

AfL[b 4 i

F. A. Sp gen rg Director - Nuclear L censing and Configuration Nuclear Station Engineering KAB/em Attachment cc:

B. L. Siegel NRC Clinton Licensing Project Manager NRC P.esident Office f

Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety l

1 8506130155 850611 PDR ADOCK 05000461

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ATTACIDfENT

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CPS-FSAR AMENDMENT 34 f

JULY 1985 Regulatory Guide 1.75, Rev. 2 (September, 1978)

Physical Independence of Electric Systems Project Position - The project complies with NRC Regulatory Guide 1.75 with the clarifications and exceptions noted in Subsections i

7.1.2.6.19 and 8.1.6.1.14.

FSAR Subsections 4" 7.1.2.6.19,.8.1.6.1.14.

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CPS-FSAR

AMENDMENT 34 JULY 198 5 least one of an inboard / outboard pair of shutoff valves.

7 (3)

Isolation valve circuits recuire scecial attention

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because of their function in limiting the

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' consequences of a pipe break cutside the primary containment.

Isolation valve control and cover circuits shall be protected from the pipelines that they are responsible for isolating as follows:

a.

Essential isolation valve wiring in the vicinity of the outboard valve (or downstream of the valve) is run in conduit and routed to

-take advantage of the mechanical protec icn afforded by the valve operator or other available structural barriers not suscectible to disabling damage from the pipe line ' creak.

Additional mechanical protection (barriers) is interposed as necessary between wiring and potential sources of disabling mechanica'.

damage consequential to a break downstrear. of the outboard valve.

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Motor-operated valves which have mechanical b.

check valve backup for their isolation I'

function are included in the division which embraces the system in which the valves are located rather than adherino strie:1y to the inboard / outboard divisional classificacien.

The testable check valve cable is run in the same division with the cables for the motor-operated valve in the same line.

7.1.2.2.5.2.3 Emercency Core Coolino Svstems (ECCS).

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The systems comprising the ECCS have their various sensors, logics, a~ctuating devices, and power supplies assigned to divisions in accordance with Table 7.1-10..

The wiring to the ADS, solenoid valves within the drywell shall run in one or more t

conduits.

ADS conduit (s) for solenoid "A"

shall be divisionally separated from solenoid "B" conduit (s).

Short pieces of flexible l

conduit may be used in the vicinity of the valve solenoids.

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CPS-FSAR

. AMENDMENT 34 I JULY 1985 7.1.2.2.5.2.4 Other Seoaration Considerations (1)

Steam Leakage Zone.

Class 1E Electrical equipment and raceways avoid location in a steam leakage 4

zone insofar as practical or are designed for z

short term exposure to the high temperature and humidity associated with a steam leak.

(2)

Suppression Pool Level Swell Zone.

Any electrical equipment and/or raceways for RPS and ESF equipment located in this zone are designed to satisfactorily complete their function before being rendered inoperable due to exposure to the l ;....

.. environment created by the swell.

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-(3)

Non-Class lE Instrumentation on Class lE Motors.

Where non-Class lE instruments such as thermoccuples or RTD's are used on lE motors, the non-lE instrument cables shall not occupy the same ij termination compartment as the lE power or control wiring.

In the event that separation C) cannot be maintained, analyses may be used

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to justify lesser separation.

(4)

Main Control Room panel separation is achieved as follows:

E a.

Two adjacent panels containing circuits of 7

different separation divisions are separated by at least 1 foot 'or there is a s' teel barrier 3

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between the two panels.

Panel ends closed. by steel end plates are considered to be a

acceptable barriers provided that terminal boards and wireways are spaced a minimum'of j

one inch from the end plate.

A b.

Panel-to-floor fireproof barriers are provided between adjacent panels of different divisions, and divisional equipment on the i

same panel.

i c.

Penetration of separation barriers within a k

subdivided panel is permitted, provided that i

such penetrations are sealed or otherwise 3

treated so that a fire generated by i

electrical fault could not reasonably 2[

propagate from one section to the other and j

disable a protective function, ya S=

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AMENDMENT 34 s

~ CPS-PSAR-r JULY - 198 5

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Where, for operational reasons, locating manual control switches on separate panels is

. considered to-be prohibitively (or' unduly) restrictive-to manual operation of equipment, the switches may be located on the same panel.

provided no' credible single event in the panel can disable both sets of redundant manual or automatic controls.

Wherever wiring of two different divisions exists in a-single panel section, spacing.cf terminal boards and wiring'is such as to preclude the possibility of fire propagat. ion from one division of wiring to another.

One of a redundant pair of-devices in close proximity (less than 6 inches) within a single panel will be considered adequately separated from the other if the wiring to one of the devices has flame-retardant insulation and is totally enclosed in fire resistant material and wiring routed in conduit at least te a point where 6 inch separation is again attained.

However, consideration shall be given to locating redundant switches on opposite sides of th.e barrier formed by the end closures of

- adjacent panels wherever operationally i

acceptable.

For the use.of flexible conduit in PGCC panels, see Subsectien 8.3.1.4.5.5.

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(4)

NSSS Isolation Devices.

Where electrical interfaces between Class 1E (or I

associated Class lE) and non-Class lE circuits, or between Class lE (or associated Class lE) circuits of different divisions cannot be avoided, isolation devices are used, except where justified by analysis.

Non-Class 1E power circuits are separated and e

isolated from all Class lE associated circuits and from al.1 Class lE circuits.

In addition, non-f Class 1E instrument and control circuits are not energized from a Class IE power supply unless 1

potential for degradation of the Class lE power-source can be demonstrated to be negligible by effective current or voltage limiting (ie.,

functional isolation) under all design basis conditions. ' Class lE power supplies which a

interface non-Class lE circuits are required to be

~ decoupled from the non-Class lE circuits when' conditions of the non-Class lE portion of the system can jeopardize the Class lE portions.

Finally' Class lE circuits which interf' ace non-s Class 1E power supplies are decoupled frca the

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non-Class lE power supplies when conditiens of the U

non-Class lE portion of the system can jeopardize J

the Class lE portion.

This decoupling device i

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CPS FSAR

-AMENDMENT 34 JULY 1985 L2-

-(11) Manual Scram

' Push buttons are-located ~in the control room to enable the operator to shut down the. reactor by

~ il initiating-a scram.

- (12) Mode Switch in SHUTDOWN

.When the mode switch is in SHUTDOWN, the. reactor.

is to'be shut down with all control-rods inserted.

This scram is not considered a protective t

function, because it is; not recuired to protect a

the fuel or reactor vessel process barrier and it bears no relationship to minimizing the release of radioactive material from any barrier.. The scram signal is removed after aishort delay, permitting a scram logic reset that restores the normal' valve

. lineup in the control rod drive hydraulic system.

7.2.1.1.7 Containment Electrical Penetration Assionment 4

. Electrical containment penetrations are assigned to the protection systems on a 4-division basis as described in

' Subsections 7.2.1.1.4.1 and 7.2.1.1.4.7.

Each. penetration is provided with a NEMA-4 enclosure box on each end providing continuation of the metal wireways described in t

' Subsection 7.2.1.1.4.7.

1 7.2.1.1.8-Cable Screadino Area Descriotion l

.A general description of the separation criteria used in cable spreading areas is described in GE Topical Report NEDO-10466-A l

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,, " Power Generation-Control Complex" and is further described in Subsection 8.3.1.4.

7.2.1.1.9 Main Control Room Area The main control room area is on one floor.

Divisions 2 and 3,

. Nuclear System Protection System (NSPS) cabinets, and Divisions 1 and~4, NSPS Cabinets are located on opposite sides of the main

' control room.

s, Detailed design basis, description, and safety evaluati'an aspects for a PGCC System are comprehensively documented and presented in GE Topical Report NEDO-10466-A " Power Generation Control Complex;" and its amendments.

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CPS-FSAR AMENDMENT 34 JULY 1985 Position C.6 No discussion required.

The position is merely a correction of a printing error in IEEE 117.

Position C.7 No discussion required.

This position indicates that specific applicability or acceptability of codes, standards, and guides referenced in Section 3 of IEEE 317 will be covered separately in other regulatory guides where appropriate.

8.1.6.1.13 Reaulatorv Guide 1.73 "Oualification Tests of Electric Valve Ooerators Installed Inside rne Containment of Nuclear Power Plants" Conformance with this Regulatory Guide is described as follows for the regulatory guides:

j Position C.1 To the extent practicable, auxiliary equipment has been tested in accordance with IEEE 382.

Position C.2 The valve operators have been tested according to their anticipated actual service operating sequence.

Position C.3 The magnitude of the environmental conditions that simulate actual expected conditions are based on conservative figures and use IEEE 323 as a basis.

i Position C.4 The radiological source term used is that used for t

qualifying all Class 1E equipment per Regulatory Guide 1.3.

Position C.5 Not applicable.

Position deals with qualification j

testing for gas-cooled reactor.

Position C.6 No discussion required.

Position states that other IEEE standards will be addressed with other regulatory guides as appropriate.

8.1.6.1.14 Reculatory Guide 1.75 " Physical Indeoendence of Electric Svstems" Conformance with this regulatory guide is described as follows for the regulatory positions:

Position C.1 Single circuit breakers in power circuits are used as isolation devices only if they trip on receipt of an accident (LOCA) signal, as shown in Figure 8.3-6.

Two fuses or circuit breakers actuated only by fault current are used in series as isolation devices as shown in Figure 8.3-6.

The accident (LOCA) signal which trips the Post Accident Sample System (non-safety-related) can be bypassed to allow operability as described in Subsec tion 9.3.7.3 and as required by NUREG-0737, Item II.B.3, and NRC letter from R. L. Tedesco (NRC) to G. E. Wu,ller (IPC) dated 7.ugust 3, 1981.

i 8.1-12

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CPS-FSAR-AMENDMENT 34 JULY 1985 1'l c l' Isolation of control and information circuits may be accomplished lj -

by the use of a single isolation dev. ice as shown in the "Infor-ip mation Circuits" portion of Figure 8.3-6.

If the single isolation id device is actuated by f ault current only (i.e., " unacceptable"),

the circuit beyond the isolation device must be' treated as an

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associated circuit.

If the single isolation device is an t

acceptable isolation device (e.g.,

relay), the circuit can be considered non-Class lE.

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Position C.2 Interlocked armor enclosing cable is not' construed as l

a raceway.

Position C.3 In general, redundant equipment, and therefore circuits, are located in separate safety class structures.

. Position C.4 Agree with position.

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Position C.5 Clinton Power Station complies with the require-i h,

ments of General Design Criterion 17.

4 Position C.6 The analyses performed in accordance with Section i

, 4.5(3), 4.6.2 and 5.1.1.2 of IEEE 384-1974 shall be prepared

-on a case-by-case basis and shall be on permanent file available q

for NRC review but will not be an integral part of the Safety b

. Analysis ' Repor t. -

Position C.7 Non-Class lE instrumentation and control circuits 1

are separated from associated circuits in-the same manner that l'

Class lE, circuits are-separated from non-Class lE circuits.

ab Position C.8 Redundant cables are not run within a confined space such as a cable tunnel that is effectively unventilated.

j.

Position C.9 Cable splicing is not permitted in raceways, except I

when terminating to equipment pigtails or if specifically shown

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on installation drawings and analyzed.

I Position'C.10 Class 15 and associated cables have color-ccded f

jackets or have black jackets marked with divisional color of 1

the cable ends and either at a maximum of 5-foot intervals in open' raceways (including trays with covers) or at every exposed man-hole,-junction box and pull box when a cable is pulled into 4

enclosed raceways.

Associated cables are further identified Q.

with their divisional markings.

li-l Position C.ll Class lE raceways are equipped with. color-coded markers.

Class lE and associated cables have color-coded jackets

. or.have black jackets marked with divisional color at the ends

.and either at a maximum of 5-foot intervals in open raceways

~ including trays with covers) or at every exposed man-hole, junction i

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box and pull box when a cable is pulled into enclosed raceways.

Reference materials are not required to distinguish between Class

'lE and non-Class lE circuits, between non-Class lE circuits associated.

with different redundant class lE systems, and between redundant Class lE systems.

Position C.12 Although redundant cable spreading areas are not utilized at CPS, sufficient separation to meet the requirements of IEEE 384-74 has been maintained between redundant' circuits and between Class lE to non-Class lE raceways.

For example, Division 1 and 2 cables are routed in separate rooms within the cable spreading area and enter the control room from overhead on opposite sides of the control room.

Power cables, when routed in the cable spreading rooms and control room, are necessary to feed, equipment associated with the area, and are installed h

in conduit only.

8.1-13

CPS-FSAR AMENDMENT 34 JULY 1985 i

Position C.13 In compliance with the regulatory position, no significance has been attached to the different tray widths illustrated in Figure 2 of IEEE 384.

' Position C.14 The diesel generators all have independent air supplies.

Position C.15 The four safety-related batteries are in separate The Division 1 battery room is served by a Division 1 rooms.

exhaust fan.

The Division 2 battery room is served by a Division 2 exhaust fan.

The Division 4 and balance of plant battery rooms are served by Division 1 and 2 powered exhaust fans.

The Division 3 battery room is served by a Division 3 exhaust fan which is connected via duct to the Division 1 and 2 powered exhaust fans which serve the Division 4 and BOP battery rooms.

Position C.16 The same separation requirements are placed on instrumentation. cabinets as are placed-on control switchboards.

RESPONSE

The fuel building HVAC control panel and the remote shutdown

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panel meet the IEEE 384 separation requirements both for redundant Class lE circuits and for Class lE circuits separated from non-Class lE circuits.

For panels with one division, separation between Class lE and non-Class lE circuits meet IEEE 384 requirements.

9 See also revised Subsections 8.3.1.4.2.3.1.2, 8.3.1.4.2.3.3 and 8.1.6.1.14, position C.6.

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CPS-FSAR AMENDMENT 34 JULY 1985 o-,o 430.131 It is not clear from the description of compliance (8.1.6) with Position C.12 of R.G. 1.75 contained in Section 8.1.6.1.14 whether the separation required by IEEE 384-1974 between redundant divisions and between Class lE and non IE circuits has been maintained in the cable spreading area.

Verify that this separation has been maintained and also that compliance with R.G.

1.75, Position C.12 which does not allow power cables to be routed through the cable spreading area or control room has been met.

Also, in the response to compliance with-Position C.10 of R.G.

1.75, ciprify that the cables are color coded at a minimum of 5-foot intervals prior to being pulled.

RESPONSE

All raceways meet the requirements of separation distance per.IEEE 384-1974 both between redundant divisions and Class lE to non-Class lE raceways.

Power cables, when routed in the cable spreading rooms and control room, are necessary to feed equipment associated with the area, and are installed in conduit only.

Cables are color coded as identified in

Subsection 8.1.6.1.14, Position C.10.

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i A!:E!!D G :T 34 JULY 19S5

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POWER CIRCUITS DIVISION 1 BUS (IE) 9 lE p,

r IE r IE UNACCEPTABLE ACCEPTABLE s ISOLATION

"' ISOLATION DEVICE DEVICE lE DIVISION I UNASSOCI TED

(NON IE)

<r ASSOCl TED

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(NON IE)

NON NON NON

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CIRCUIT BREAKER NOT TRIPPED ON LOCA OR FUSE

" LOCA TRIPPED CIRCUlT BREAKER

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INFORMATION CIRCUlTS s

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UNACCEPTABLE ACCEPTABLE ISOLATION ISOLATION DEVICE DEVICE

DIVISION UNASSOCIATED (r

ASSOCIATED (NON IE)

RELAY (EXAMPLE)

CLINTON POWER STATION FIN AL S A FETY AN ALYSIS T)CPOftT FIGUP.E 8,3-6 ELECTP,1 cal. ISOLAilC'l 1

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