ML20128Q364

Clarifies 850114 Response to Insp Rept 50-482/84-51 Re Raceway & Cable Separation & 850114 marked-up Revised Pages to FSAR

ML20128Q364
Person / Time
Site:	Wolf Creek
Issue date:	05/30/1985
From:	Koester F KANSAS GAS & ELECTRIC CO.
To:	Denise R, Harold Denton NRC - WOLF CREEK TASK FORCE, Office of Nuclear Reactor Regulation
References
KMLNRC-85-140, NUDOCS 8506040169
Download: ML20128Q364 (12)

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THE ELECTFMC COMPANY xansas cas ano siecraic couraar GLENN L MOESTER wett Pars'OENT NUCLE AR May 30, 1985 Mr. R.P. Denise, Director Wolf Creek Task Force U.S. melear Regulatory Comission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Barold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conmission mshington, D.C. 20555 KMLNRC 85-140 Re: Docket No. SIN 50-482 Ref: 1) KMLNRC 85-031 dated 1/14/85 from GIKoester, KG&E, to RPDenise, NRC

2) KMLNRC 85-030 dated 1/14/85 from GIKoester, KG&E, to HRDenton, NRC Subj: Clarification Regarding Raceway and Cable Separation

Dear Gentlemen:

References 1 and 2 provided a response to Inspection Report 50-482/84-51 on cable separation and the marked up Wolf Creek Final Safety Analysis Report (FSAR) changed pages required by the response. In the process of incorporating the FSAR revisions included in Reference 2, KG&E has identified a need for further clarification.

The references did not point out that a limited amount of non-safety-related lighting, connunication, fire protection and speciality cable are not qualified to IEEE 383, but mcet its intent in one or more of the following ways: 1) exposed cables covered with flame retardant coatings; 2) installation in a i totally enclosed metal conduit system; 3) installation consisting of short lengths of exposed cable between the ends of a totally enclosed metal conduit system routed to a conponent and the connection to the cocponent (e.g. at light fixtures, piblic address devices and conpiter peripherals); 4) installation in non-safety-related areas separated from safety-related areas by fire boundaries; or 5) evaluation on a case-by-case basis for 00, adverse inpact on the fire protection program. ,

l 8506040169 850530 k PDR ADOCK 05000402 O PDR 201 N. Market - WicNta, Kansas - Mail Address: Ro. Box 208 i Wichta, Kansas 67201 - Telephone: Area Code (316) 2616451

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10DBC 85-140 May 30, 1985

! It has been verified that the power block and site-specific cable routing have no safety inpact resulting from the non-IEEE-383 qualified cables; therefore, there is no reduction in the level of protection provided' by the fire protection program as described in the FSAR.

Attactunent 1 provides a reivsed response to Inspection Report 482/84-51. Attachment 2 provides a revised PSAR markup which will be formally incorporated into the first update of the Nblf  :

Creek FSAR. The information in Attachments 1 and 2 supercede the information provided by References 1 and 2.

If you have any questions, please contact Mr. Otto Maynard of my staff.

Yours very truly, Glenn L. Koester Vice President - NLx: lear GU:: dab xc: P0'Connor (2)

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STATE OF KANSAS )

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Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said Company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

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Glenn L. Koester Vice President - Nuclear SUBSCRIBED and sworn to before me this day of M , 198 k

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Attachment 1 VIOLATION 482/84-51: VIOLATION OF 10CFR50, APP. B, CRITERION III Finding:

10 CFR Part 50, Appendix B, Criterion III, requires that applicable regulatory requirements aM the design basis, as defined in 10 CFR 50.2 and as specified in the license application, are correctly translated into specifications, drawings, procedures, and instructions.

10 CFR 50.2 defines " design bases" as that information which identifies the specific functions to be performed by a structure, system, or component of a facility, aM the specific values or ranges of values chosen for controlling parameters as reference bounds for design.

Section ,8.3.1.4.1.1 of the license application specifies that cables from different separation groups will, in accordance with IEEE Standard 384-177 (SIC) practice, be in steel conduit or enclosed raceway or separated by a fire barrier when the normal 5-foot and 3-foot horizontal separation cannot be maintained.

Section 8.1.4.3 of the license application specifies that deviations from the IEEE Standard 384-1977 practice which reduce the minimum spatial separation between circuits be supported by analysis and, in accordance with the specified Regulatory Guide 1.75-1974, be considered part of the licensee's application.

Contrary to the above, a number of nonsafety conduits to safety cable trays and cables exiting the trays did not meet the spatial requirments for ,

cables frm different separation groups in accordance with your conmitment ,

to Regulatory Guide 1.75 and IEEE-384 nor was such deviation supported by an J analysis, as specified in the license application.

Revised Response:

a) Corrective steps which have been taken and results achieved:

Item 1. An analysis has been performed and the results are as follows:

'Ihe safety design basis is to protect the safety-related cables from failure of the non-safety-related circuits, and not vice-versa. In consideration of this limit, enclosing the non-safety circuits in conduit and maintaining at least 1 inch separation provides an acceptable level of protection. The conduit can contain only a limited quantity of combustible material (cable insulation & jacket) . Furthermore, there is insufficient oxygen inside the l conduit to support combustion of more than a fraction of the available material.

Cables are qualified to IEEE-383, except as noted below, and meet the flame retardant requirements specified within and, therefore, the cables will not support combustion. Certain non-safety-related communication, lighting, 1

n fire protection and other specialty cables (e.g. cords, couputer:-ribbon cable) are not qualified to IEEE-383, but are considered by MG&E to meet its intent-in one of.the following ways:

1) exposed cables covered with flame retardant coatings; 2)~ installation in a totally enclosed metal' conduit system; ..

3). installation consisting of short lengths of exposed cable between_the ends of a totally enclosed metal conduit systen routed to a component and-the connection to the couponent; 4)' installation in non-safety-related areas separated from safety-related areas by fire boundaries;

5) evaluation on a case-by-case basis for adverse impact on the fire protection program.

I Based on these considerations,-it is established that 1-inch separation .

l' 'between 'a conduit containing non-safety-related circuits and an open tray,

! containing safety-related circuits is sufficient to assure that any- failure within the ncn-safety-related circuits .will not propogate into and compromise the integrity of the safety-related circuits.

Itan 2. In accordance with Regulatory Gaide 1.75 this analysis will be-incorporated.into the Final Safety Analysis Report Section 8.1.4.3 L as described in Attachnent 2.

I It should also be noted that in Section 8.1.4.3 in the Final Safety Analysis Report that IEEE 384-1974 is consmitted to and not, according to Inspection Report 50-482/84-51, IEFE 384-1977.

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} b) Corrective steps which will be taken to avoid further violation:

'Because of the corrective steps that have been taken in part a), KGEE

, will-- be in full conpliacce with licensing conunitments; therefore, no

! further corrective steps are necessary.

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! c) Date when full conpliance will be achieved:

'Ihe FSAR change to Section 8.1.4.3 is shown'in Attachment 2 and will be incorporated into the first update of the FSAR.

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. SNUPPS

b. For cable trays of different separation groups, there is a minimum vertical separation of 5 feet:

between open-top trays stacked vertically. In the limited number of areas where trays of different separation groups are stacked with less than 5 feet of vertical separation, a fire barrier is placed between the two neparation groups. The barrier extends 1 foot to each side of the tray system (or to the wall).

c. In the case where a tray of one separation group crosses over a tray of a different separation _ group and the vertical separation is less than 5 feet, a fire barrier is installed extending 1 foot from each side of each tray and 5 feet along each tray from the crossover.

d. Where it is necessary that cables of different separation groups approach the same or adjacent control panels with less than 3-foot horizontal or 5-foot vertical spacing, isolation is maintained by installing both separation groups in steel conduit or enclosed wireway or by installing fire barriers betseen the separation groups. In the case of horizontal separation, the barrier extends 1 foot below the bottom of the tray (or to the floor) to I foot above the top of the tray (or to the ceiling).

In the case of vertical spacing, the barrier extends 1 foot on each side of the tray system (or to.the wall ) .'

e. Isolation between separation groups is. considered to be adequate where physical separation is less than that indicated in Items a, b, and c above, provided the circuits of different separation groups are run in enclosed raceways that qualify as i

barriers or other barriers are installed.between

the different separation groups. The minimum i

distance between these enclosed raceways and be -

, tween barriers and raceways is 1 inch. The bar-riers are instal ed as ase ' bed in a through d above.

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CABLE SPREADING AREAS - The cabic spreading a.rea does not contain high energy equipment such as switchgear, trans-

formers, rotating equipment, or potential sources of missiles or pipe whip and is not used for storing flammable materials.

I (circuits in the cable spreading area are limited to control t

and instrument functions and also those power supply circuits l

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e Attachment 2 INSERT A In cases of open trays containing-related cables and totally enclosed cor.duits containing non-safety related cables, the safety design basis is to protect the safety related cables from failure of the non-safety related circuits, and not vice-versa.

In consideration of this limit, enclosing the non-safety circuits in raceway and maintaining at least one inch separation provides an acceptable level of protection. The conduit can contain only a limited quantity of combustible material (cable insulation and jacket) . Furthermore, there is insuffient l

oxygen inside the conduit to support conbustion of more than a fraction of the available material.

Based on these considerations, it is established that one-inch separation between a conduit containing non-safety related circuits and an open tray containing safety related circuits is sufficient to assure that any failure within the non-safety related circuits will not propagate into and compromise the integrity of the safety related circuits.

SNUPPS APCSB 9.5-1 Appendix A SNUPPS

• When safety-related cables do not satisfy the safety-related cables satisfy the provisions of Regu-provisions of Regulatory Guide 1.75, all exposed latory Guide 1.75.

cables should be covered with an approved fire retardant coating and a fixed automatic water fire

• suppression system should be provided.

(d) Cable and cable tray penetration of fire barriers (d) Cable and cable tray penetration of fire barriers (vertical and horizontal) should be sealed to (vertical and horizontal) are sealed to give protection give protecticn at least equivalent to that fire at least equivalent to the barrier which they pene-barriers for horizontal and vertical cable trays trate. Typical horizontal and vertical cable tray should, as a minimum, meet the requirements of penetrations are tested to prevent the spread of fire and retain structural soundness when exposed to a ASTM E 119, " Fire Test of Building construction 3-hour fire as discussed in 9.5.1.2.2.

and Materials," including the hose stream test.

Where installed penetration seals are deficient with respect to fire resistance, these seals may be protected by covering both sides with an approved fire retardant material. The adequacy of using such material should be demonstrated by suitable testing.

(e) Fire breaks should be provided as deemed (e) Fire breaks are provided as decaed necessary by the necessary by the fire nazards analysis. Flame fire hazards analysis. The cable rating is compatible or fire retardant coatings may be used as a with the construction of the fire break. Refer to fire break for grouped electrical cables to Appendix 9.58 and Section 9.5.1.2.2.

limit spread of fire in cable ventings.

(Possible cable derating owing to use of such coating materials must be considered during design.)

(f) Elt ;trical cable constructions should as a (f) Electrical cable passes the IEEE 383-1974 flame test d"'

ei .2us pass the current IEEE No. 383 flame h /cef~ oC th-t. (This does not imply that cables passing cr m e e,-f y f4e_ v*c.q u e

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• test will not require additional fire protection.)

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For cable installation in operating plants and plants under construction that do not meet the IEEE No. 383 flame test requirements, all cables must be covered with an approved flame retardant coating and properly derated.

(g) To the extent practical cable construction that (g) See response to D.2(c) above, does not give off corrosive gases while burning should be used. (Applicable to new cable instal-lations.)

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SNUPPS APPENDIX 9.5B FIRE HAZARDS ANALYSIS SECTION TITLE / DESCRIPTION PAGE(S) 9.5B.1 Introduction 9.5B-1 through 9.5B-2 9.5B.2 Assumptions on Plant 9.5B-2 through'9.5B-3 Conditions 9.5B.3 Fire Effects on Electrical 9.5B-3 Equipment and Safe Shutdown Information 9.5B.4 General Information on 9.5B-3 through 9.5B-4 Design Features 9.5B.5 Combustible Loadings dra! 9.5B-4 through 9.5B-5 fir m s. :foreed 9.5B.6 Fire Hazards Review 9.5B-5 through 9.5B-7 Methodology Fire Area A-1 Auxiliary Building - El. 9.5B-8 through 9.5B-13 1974 to 1988, General

. Area, Rooms 1101-1106, 1115, 1120-1125, 1128-1130, 1201-1207, 1329 '

2 Auxiliary Building Safety- 9.5B-15 through 9.5B-18 Related Pump Area Rooms 1111-1114 3 Boric Acid Tank Rooms, 9.5B-19 through 9.5B-22 Rooms 1116, 1117, 1407 4 Auxiliary Building Safety- 9.5B-23 through 9.5B-26 Related Pump Area, Rooms 1107-1110 5 Auxiliary Building Stair- 9.5B-27 through 9.5B-28 way an.d Elevator (South),

Room 1119 6 Auxiliary Building Stair- 9.5B-29 through 9.5B-30 way (North), Room 1127 7 Boron Injection Tank and 9.3B-32 through 9.5B-33 Pump Room, Room 1126 Rena==44 9.5B-1 W

. AWehra x SNUPPS In most fire areas, the boundaries are defined by walls, floors, and ceilings. In the reactor building, however, such natural bound, aries do not completely enclose localized. fire hazards. For the fire areas inside of the containment, the provisions of Appendix R, Paragraphs III.G.2.d, e, and f were addressed. '

Where a fire barrier is indicated, penetration seals in the barrier are fire rated for the same or greater time period, unless otherwise indicated.

All areas of the plant protected with water suppression systems have sufficient drainage capacity to prevent the run-off of water into other fire areas. All drains through-out the plant drain to their respective building sumps. From there, sump pumps transfer the water to the radwaste system.

Smoke and heat are assumed to be removed from areas affected by a postulated fire by the plant HVAC systems until such time that the fire dampers are actuated. Flexible duct and portable fans would be used to remove the remaining smoke to allow access to the area, as required, for manual fire fighting. The smoke would be removed via the flexible duct to an operable plant exhaust.

Equipment need times used in the fire hazards analysis are not absolute requirements and are listed to demonstrate that adequate time is available for operator action.

Emergency lighting is provided for areas which must be manned for safe shutdown and for access and egress to fire areas.

It consists of scaled beam units with individual 8-hour minimum battery power supplies.

9.5B.5 COMBUSTIBLE LOADINCS AND FL AME Sf#r4 9 Combustible loadings were determined for each room in the fire area through a review of design drawings. For each fire area, only those rooms which contain fixed or transient combustible materials and/or safe shutdown equipment are listed in the analysis. Other rooms are located and identi-fied on the figures. The term " negligible" is used where no measurable quantity of fixed combustible material has been identified.

Although fire hazard effects on exposed conduits have been evaluated for safe shutdown, electric cable inside metal conduit has not been considered as contributing to the fire loading in the hazard areas.

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Mha .,,t1 e; . SNUPPS' Noncombustible materials are defined to meet one of the following criteria:

. a. Material. of which no part will burn.

.' b' . -

Surface materials not over 1/16-inch thick.with a flame spread rating of 50 or .less aus measured by -

ASTM E 84-1976.

c. Interior finishes which meet a. or are listed by an.

approved organization for surface flame spread of 25 or less per ASTM E 84-1976 and potential heat release of 3,500 Btu /lb or less per ASTM D 3286-1973.

The fixed combustible loading is based on the total floor area of. each room. Unless indicated otherwise, the. specific location of combustible material within a room is not a significant factor in the analysis.

A _significant amount of the fixed combustibles in the plant is electric cable insulation. The specific calorific value-for each type and size of cable was used in calculating the maximum heat loading for each fire area. The following are

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//4 / *a+ cable insulation types used in the plant and their heat of combustion: l Insulation Range of Heat Type of Combustion Supplier FR(HC711) 8,700 - 13,100 Btu /ft Kerite NS(H170) 8,450 - 23,600 Btu /ft Kerite XLPE 90 Btu /ft Rockbestos .

Neoprene 630 - 4,390 Btu /ft Rockbestos' Hypalon. 645 - 8,070 Btu /ft Anaconda Hypalon 490 - 5,080 Btu /ft BIW -

Hypalon 950 Btu /ft Brand Rex Hypalon 370 - 2,385 Btu /ft Samuel Moore & Co.

All' safety-related cable in the general plant area is qualified to'IEEE 383-1974. All single conductors inside control a

els meet the flame resistance requirements of I,CEA S-19-81 A bN P Transient combustibles are estimated based on maintenance ande,. g. 4 -yo A

• o operations requirements. Their heat loading contribution to an area is not quantified, but they are considered as a means by which an exposure fire could occur.

9.5B.6 FIRE HAZARDS REVIEW MET!!ODOLOGY The SNUPPS fire hazards analysis, originally conducted in 1977, has been updated periodically as the design of the plant has been finalized. The most recent update reflects

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9.5B-5 Sy4 4-

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.- Attachment 2 INSERT B Lighting, fire. protection, communication and specialty cables which are flame retardant but not qualified to IEEE-383-1974; and other communication and specialty cable (e.g cords and computer ribbon cable), are limited in use in the following manner: -

A. Covered with a flame retardant coating per the requirements of (BTP) APCSB 9.5-1, Appendix A;

.B. installed in a totally enclosed metal conduit system; C. consist of short lengths of exposed cable between the end of a totally enclosed metal conduit system routed to a component and the connection to the component (e.g.

at light fixtures 3end public address devices);^

sna es.,pr e p seipho sis D. located in non-safety related areas which are separated from safety related areas by fire rated boundaries; or E. evaluated on a case-by-case basis for adverse impact on the fire' protection program.