ML20244A584
| ML20244A584 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/05/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89359, NUDOCS 8906120083 | |
| Download: ML20244A584 (2) | |
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FM Log # TXX-89359 File # 10130
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IR 87-37 J
IR 87-28 1UELECTRIC
.gog 3 Ref. # 10CFR2.201 William J. Cahill, Jr.
Executive \\'ke President U. S. Nuclear Regulatory Commission I
Attn: Document Control Desk Washington, D. C. '20555
SUBJECT:
COMANr.HE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NOS. 50-445 AND 50-446
'1 REVISED RESPONSE TO NRC INSPECTION REPORT N05. 50-445/87-37 AND 50-446/87-28
-REF: -TU Electric letter to NRC logged TXX-88332 and dated April 11, 1988.
I Gentlemen:
In' the referenced letter at page 53 of 121, TV Electric provided a response to Open Item.E-28. That TU Electric response was intended to address certain specific-questions raised by the NRC during ongoing inspection and review activities. The design criteria for separation of power circuits are provided in the FSAR (See Section 8.3.1.4 Item 5), and it is not the intent of TU Electric to supercede those criteria.
j A revised response to Open Item E-28 is attached. This revised response addresses the open item broadly and clarifies the commitment.
This revised response impacts the NRC's safety evaluation for this item as l
documented in SSER No. 17 Appendix A, pages 74 and 75.
Sincerely, i
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Mu~
William J. Ca ill, Jr.
WJH/vid Attachment i
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c - Mr. R. D. Hartin, Region IV j
Resident Inspectors, CPSES (3) g 8906120083 890605 g D FDR ADOCK 05000445 Q
' 400 North Olive Street LB B1 Dallas, Texas 75201
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w Attachment to TXX-89359 June 5,.1989 4
Page 1 of 1 Open Item E-28 Document Number:
DBD-EE-057. Revision 0. Separation Criteria Position C6 in Regulatory Guide 1.75 indicates that all circuits which utilize lesser separation distances and are accepted on the basis of analyses and testing-should be identified.
Because of their significant damage potential, all power circuits which utilire analysis / testing for justification of lesser -
separation should be identified. This has not been accomplished.
RESPONSE
As identified in FSAR Section 8.3.1.4 (Item 5), CPSES utilizes lesser separation distances for power circuits, based on analysis, when conduit is located either above open tray, adjacent to open tray but not above the side rails,- or below a ladder type tray.
As a clarification of the FSAR, these separation criteria are also applied to power cables which are not located in raceway and not inside equipment as if the cables were in an open ladder type tray.
Since there are no siderails, horizontal separation between such cable and safety-related conduit meets the separation distances referenced by Regulatory Guide 1.75.
Power cables with a wrap of woven silicon dioxide are treated the same as conduit for the purpose of separation.
These criteria are applied generally throughout CPSES and could affect essentially all power circuits.
SIGNIFICANCE / EXTENT There is no safety concern because the Comanche Peak criteria for lesser separation distances have been analyzed to show no adverse impact on Class 1E circuits.
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