ML20128Q141

Forwards Addl Info Re Reg Guide 1.75 Concerning Electrical Separation,To Clarify

ML20128Q141
Person / Time
Site:	Beaver Valley
Issue date:	07/22/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.075, RTR-REGGD-1.075 2NRC-5-106, NUDOCS 8507260595
Download: ML20128Q141 (2)

Text

_.

'A@

DuquesneLidit 2;;Rgg10e Nuclear Construction Division Telecopy 41 2 29 Robinson Plaza, Building 2. Suite 210 Pittsburgh, PA 15205 July 22, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. George W. Knighton, Chie f Licensing Branch 3 Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Electrical Separation Regulatory Guide 1.75 Information

REFERENCE:

2NRC-5-101, dated July 10, 1985 (attached)

Gentlemen:

This letter is to clarify the subject of our letter 2NRC-5-101, dated July 10, 1985.

That letter did not readily identify the subject, which was to provide additional information regarding Electrical Separation Regulatory Guide 1.75.

All other informat ion contained in that submit t al should be aufficiently clear.

DUQUESNE LIGHT COMPANY M

By J. # jfarey t

Vice Yresident GLB/wjs Attachment cc:

Mr. S. Ebnetter (w/a)

Mr. J. Knox (w/a)

Mr. J. M. Taylor, Director (3) (w/ a)

Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a)

INPO Records Center (w/a)

NRC Document Control Desk (w/a)

SUBSCRIBED AND SWORN TO BEFORE ME THIS

_J L [ DAY OF

'll,

, 1985.

,< (d u

,u)

/

bC Notary Public ANITA ELAINE REITER. NOTARY PUBLIC g72go g"ggO$12 ROBINSON TOWNSHIP, ALLEGHENY COUNTY yl 4

PDR MY COMMISSt0N E.mqE3 OCTro $ " 'ns l

Unitsd Stctos Nuclear Raguistory Conunission Mr. George W. Knighton, Chief Electrical Separation Regulatory Guide 1.75 Information Page 2 COMMONWEALTH OF PENNSYLVANIA )

)

SS:

. COUNTY OF ALLEGHENY

)

On this A h [ day of b((

///S

, before me, a

/

if Notary Public in and for said Commonwealth and County, personally appeared J.

J. Carey, 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 best of his knowledge.

llt u

ne>

Not ary' Pub lic ANITA ELAINE REITER, NOTARY PUEllC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMM!ss!ON U. FIFE 3 CCTOGER 20,1955 I

1, I

l e,-,

,,__---,,-en-n

F s

ATTACHMENT 2NRC-5-101 W@

:a;%:

Nuclear Construction D6 vision Telecopy (412) 787-2629 Robinson Plaza. Building 2 Suite 210 Pittsburgh, PA 15205 July 10, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. George W. Knighton, Chie f Licensing Branch 3 Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Gentlemen:

we are proceeding with the revision to the in-For your information, stallation speci fication 2BVS-931 and the appropriate engineering documents, field cons t ruc t ion procedures and inspection plans to incorporate the sep a ra-t ion criteria submit t ed to the NRC with our letter 2NRC-6-081, dated June 4, 1985.

This revision contains the revised criteria for internal panel wiring s eparat ion as well as that fo r cab le in raceway and in free air (drop outs) external to panels. The separation requirement for electrical color separation within equipment to be included in the revisions to the appropriate documents are detailed in Attachment 1.

We will be proceed ing with the implementation of this criteria based on the flow chart attachment I that was submit ted to the NRC with our letter 2NRC-4-151 dated September 24, 1984 (attachment 2).

In order to assist your rev iew of the results of the WYLE Test Report, we sugge s t that a meeting be held with your rev iewe rs at your earliest c o n-venience.

This would pe rmit complet ion of the case 3 c ons eque nt ial work effort as referenced in our (2NRC-4-151) September 24, 1984 letter.

DUQUESNE LIG COMPANY By _

J.{./Carey

,Vice President JFK/ caw Attachment SUBSCRIBED AND SWORN TO BEFORE ME THIS bs1

>1935-R0/JFK/NRC DAY OF hR Y lNte -

j,9 y[gqg Nocaty I'ublic ANITA ELAINE REITER, NOTARY PUBUC OgI y.m m m-ROBINSON TOWNSHIP, ALLEGHENY COUNTY 1

r e

i-United States Nuclese Reguletory Connaission Mr. George W. Knighton, Chief

. Mr. R. DeYoung, Director (3) (1-w/a; 2-w/o) cc:

Mr. B. K. Singh, Project Manager (w/a)

Mr. S. Ebnetter (w/a)

Mr. J. Knox (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a)

INPO Records Center (w/a)

NRC Document Control Desk (w/a)

COMMONWEALTH OF PENNSYLVANIA )

)

SS:

COUNTY OF ALLEGHENY

)

On this

/d day of

/9[(,beforeme, a

Notary Public in and fo r said Cdimonw[alth and County, personally appe ared J.

J.

Carey, who being duly sworn, deposed and said that (1) he is Vice Pres ident 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 best of his knowledge.

Notary Public ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISS!ON EXPlRES OCTOBER 20,1986

e t

Unitud Stcteo Nuclect Reguletory Commission Mr. George W. Knighton, Chief

. bec:

J. J. Carey

- w/ attachment E. J. Wooleve r

- w/ attachment R. S. Christner

- w/ attachment R. E. Dougher

- w/ at t achme nt l

C. E. Ewing

- w/ attachment T. D. Jones

- w/ at t achment J. A. Hultz

- w/ attachment 8' u F.~ Kurts, J r.; i

- w/ at t achme nt J. H. Latshaw

- w/ attachment R. E. Martin

- w/ a t t achme nt T. P. Noonan

- w/ attachment J. A. Rocco

- w/ at t achme nt R. J. Swiderski

- w/ attachment G. L. Beatty

- w/ at t achment E. T. Eilmann

- w/ attachment R. W. Fedin

- w/ at t achment K. M. Holcomb

- w/ attachment J. Lee, Esq.

- w/ at t achme nt J. D. O'Neil

- w/ attachment S. L. Pernick, J r.

- w/ attachment K. A. Troxler

- w/ attachment T. J. Zoglmann

- w/ at t achme nt A. A. Dasenbrock

- w/ attachment G. H. Oliver

- w/ attachment D. E. Burke (CEI)

- w/ attachment R. G. Schuerger,(CEI). - w/ a t t achment B. M. Miller (2) (OEC) - w/ attachment T. Gerusky (PADER)

- w/ attachment J. Silberg (SPPT)

- w/ attachment D. Chamberlain (S&W)

- w/ attachment C. Richardson (S&W)(5) - w/ attachment (3)

T. J. Lex (W)

- w/ att achment B. Lorenz (E)

- w/ attachment

~

DLC/ EPM

- w/ at t achme nt NCD File

- w/ attachment

..i.

g.

-1 ATTACHMENT 1 ELECTRICAL COLOR SEPARATION WITHIN EQUIPMENT

1. Low Voltage Equipment

{

la. The minimum separation distances between wire groups within Low

. Voltage equipment are:

1.a.1 1 in between wire groups or I

L.a.2 L in between wire groups and contacts or l.a.3 6 in between contacts ib. The following protection methods or combination of authods may be used to reduce the distance specified in Section la.

L.b.1 One wire group or contacts (A) protected as shown in (A) below when separated by distance (C) from wire group (B) as shown in (B) below.

Open wire groups are groups with no protection.

WIRE GROUP ( A)

DISTANCE (C)

WIRE GROUP (B)

Preferred Method-Open 1"

Open Co nduit*

1" Open Conduit

• 0" Conduit

• Conduit

• 0" Wrap Preferred Method-Wrap 0"

Wrap No future conduit installation is anticipated.,Any conduit presently installed and analyzed will be left as is.

[

L.b.2 One wire group or contacts separated from another wire group or contacts by a barrier may have the total distance between wire groups reduced to 1 inch plus the thickness of the

[

barrier.

If either group, separated by a barrier, is p

enclosed in a wrap or conduit, the distance. between the L

groups and the barrier can be reduced to 0 inches.

(The L

non-enclos ed group may touch the barrier and the enclosed group may also touch the barrier.)

NOTE:

Barriers shall extend a minimum of 1 inch beyond exposed terminals and shall be designed of with sufficient strength to withstand misuse of tes t ing equipment and maintenance tools.

Barriers less than 1 inch from terminals shall be nonco nd uc t ing,

seismically supported.

r Attachment t

2. Medium Voltage Equipment

24. The minimum separation distances between wire groups within medium voltage equipment are:

2.a.1 6 in between wire groups or 2.a.2 6 in between wire groups and contacts or 2.a.3 6 in between contacts.

2b. The following protection methods or combination of methods may be used to reduce the distance specified in Section 2.a.

2.b.L. One group or contacts (A) protected as shown in (A) below when separated by distance (D) from wire group (B) as shown in (B) below.

Open wire groups are groups with no protec-tion.

WIRE GROUP (A)

DLSTANCE (D)

WIRE GROUP (B)

Preferred Method-Open 6"

Open Conduit Method

• 1" Open Preferred Method-Wrap Conduit

• 1" Conduit

• No future conduit installation is anticipated.

Any conduit as is.

presently installed and analyzed will be left 2.b.2 One wire group or contacts separated from another wire group or contacts by a barrier may have the total distance between wire groups reduced to 1 inch plus the thickness of the barrier.

NOTE:

Barriers shall extend a minimum of L inch beyond exposed terminals.and shall be designed of with suf-ficient strength to withstand misuses of tes t ing equipment and maintenance tools terminals shall be nonconducting, seismically supported.

4. Where wire groups are not adequately separated and a solution as out-lined in i and 2 above is not possib le.

The Contractor shall request Engineering authorization prior to tennination.

5. The color group of internal wiring is determined by the external cable connecting with or as an extension to it.

Wiring diagrams should be used for making this de te rminat ion.

In case of difficulty in deter-mining the group color of the wire group for internal wiring the engin-eer should be requested to provide resolution.

r-e ATTACHMENT I FLOW CHART

" CASE f*

M

• CASE l* CONSEQUENTIAL WORa WALa00eN OF PANELS SCNEOULE START QuTSIDE CONSE0utNTIAL WORN FOR SEPARAfl0N SCOPE & SCNE0uLE*

MANNOLES IS PROSLEMS S SS 05084 S a lS - 4 4 1

E t

DISCUSS ' CASE 2' OISCUSS TEST PNGRAM CONSEQUENTI AL WORE

& EXPECTED RESULTS DETA4L S wlTN NRC wtTN seRC 9*26-8 5 S 24-84 h

INCORPORATE NRC INCDR80R ATE NRC COMMENTS IN ComptNTS IN TEST PROGR Au DE T AILS AMEND h

FSAR

'r PERFORM TESTiesG START II-t 84

" CASE 2 DEVELOR SQLufl0NS ENO 12 S0 44 CONSEQUOeflAL wCRK FOR SEPARATION SCOPE & SCNEDULE g

PR00 LENS Fouho IN v

10-44 PANELS FINAL TEST REPORT g

2 28 SS I

flut g

ISSUE REwoRE CONSE0uENTIAL gggg,g,gg gg C ETAILS

'OA" QRE ATER TNAN Y

DISCUSS REPOR' RESULTS 12-85 84 WDutE RE0uiREM G RE0uCTION OP CONSEQ FOR CASE 2 work WITN NRC iwPLEpostATION g.gg ROX S 8S INCORPOR ATE NRC N

C0tesENTSIN CETAILS 3-SS IMPLEWENT CASE 2 SCOPE OF

=

^

CONS EQUEN TI AL wCRM SASED ON TESTQ NRC 4

MEETINO CECl0E ON led PLEMENT ATION OF TEST RESULTS T

AMENO FSAR

'r

" CASES

• CONSEQUENTI AL WORs SCOPE G SC(OULE r

IWPLEMENT CASE S CONSE0utNTIAL woRR O

7_.

.f

'Af 4 2 is 41 Nuclear Construction oiviseon (412) 923-1960 RoDinson Plaza, Buil$ng 2. suite 21o Telecopy (412) TsT-2s29 Pittsburgh PA 1520$

September,24, 1984 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Electrical Separation R.G.1.75 Information Gentlemen:

The status of the BVPS-2 program to achieve compliance with its commitment to Regulatory Guide 1.75 Rev. 2 and IEEE-384-74 was presented to the NRC during a site meeting on August 30, 1984.

Copies of the conference notes and presentation slides were submitted to the NRC with our letter 2NRC-4-143 dated September 14, 1984.

During the August 30 meeting, NRC representatives reques ted a des-cription of the relationship between our implementation scope and plan for consequential work and future test program results, future licensing (FSAR) submittals and future walkdowns of electrical separation within panels.

The attached flow chart (Attachment 1) has been developed to identify the rela-tionships among these' four (4) efforts.

It should be noted, as shown on Attachment 1, that " Case 1" is the consequential work scope and schedule that was discussed at our August 30, 1984 meeting and was included in our September 14, 1984 submittal.

Case 1 is based upon the consequential work details 1983 meeting.

presented during our December 20,

" Case 2" consequential work scope and schedule, as shown on Attach-ment 1, will be based upon implementation of the additional types of conse-quential work details that have already been found acceptable to the NRC.

" Case 3" consequential work scope and schedule, as shown on Attach-ment 1, will be based on test results that substantiate the bases for NRC acceptance of further reductions in the quantity of conse,quential work.

u <

s app

r-A United States Nuclear Regulatory Conunission Mr. George W. Knighton, Chief Page 2 I

Since we have already established that Case 1 can be ac commoda ted within the existing plant schedule, and since Cases 2 and 3 will reduce the quantity of consequential work required to be performed, we believe that the attached flow cart de sc ribes a positive system for resolution of the elec-trical separation issue that is in our mutual best interest to complete.

DUQUESNE LIGHT COMPANY By E. J. Woolever Vice President HMS/nel Attachment cc:

Mr. C. Anderson, Region 1 (3) (w/ attachment)

Mr. J. Knox (w/ attachment)

Ms. M. Ley, Project Manager (w/ attachment)

Mr. G. Walton, Resident Inspector (w/ attachment)

COMMONWEALTH OF PENNSYLVANIA )

)

SS:

COUNTY OF ALLEGHENY

)

On this.2 day of f

/[

, before me, a

/

Notary Public in and for said Commonwealth and County, personally appeared E. J. Woolever, who being duly sworn, deposed and said that (1) he is Vice Pres ident 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 be st of his knowledge, d

M.

Notary Public ANITA ELAINE REiTER, NOTARY PUBLIC RODINSON TOWN 3 HIP. ALLEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 20,1986

e

.s United States Nuclear Regulatory Commission Mr. George W. 'Knighton, Chief f

Page 3 HMS/nul NR/NRC/ REG /175 Attachment bec:

W. T. Wardzinski (w/o/ attachment)

C. E. Ewing T. D. Jones R. E. Dougher E. F. Kurtz, Jr.

J. H. Latshaw T. P. Noonan J. A. Rocco H. M. Siegel R. J. Swiderski G. L. Beatty E. T. Eilmann K. M. Holcomb J. F. Konkus J. Lee, Esq.

R. E. Martin S. L. Pernick, Jr T. J. Zoglmann D. E. Burke (CEI)

R. G. Schuerger (CEI)

E. A. Licitra (NRC)

G. Waltoa (NRC)

W. T. Keller (NUTEC)

B. M. Miller (2) (OEC)

J. Silberg (SPPT)

D. Chamberlain (S&W)

T. J. Lex (W)

J. J. Carey~

(w/ attachment)

E. J. Woolever J. A. Hultz P. RaySircar (S&W)

C. R. Bishop (S&W)

NCD File

.