ML20245K917

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Provides Advance Changes to Be Included in Future FSAR Amend Re Electrical Isolation & Separation of Safety Sys Inoperable Indication Panels
ML20245K917
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/15/1989
From: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-89576, NUDOCS 8908210203
Download: ML20245K917 (25)
v • d • e


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Log # TXX-89576 File # 10010, 901.8 27 II 907.1, 908.3

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Ref. # 10CFR50.34(b) nlELECTRIC August 15, 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk

. ashington, D. C.

20555 W

SUBJECT:

COMANCHE PEAK: STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 ADVANCE FSAR SUBMITTAL

. SAFETY SYSTEM INOPERABLE INDICATION PANEL ELECTRICAL' ISOLATION AND SEPARATION Gentlemen:

This letter provides an advance copy of changes to be included in a future FSAR amendment dealing' with the electrical isolation and separation of the Safety System Inoperable Indication (SSII) Panels.

In accordance with Regulatory, Guide 1.75, Revision 1, and the corrective actions for SDAR CP-87-85 (see TXX-89568 dated August 4,1989), an analysis is provided in -

the FSAR supporting that the low energy circuits in the SSII logic panels and the attendant' associated cables do not impact the function of the Class-1E field devices or adjacent Class IE cables.

In order to facilitate NRC staff review of these changes, the enclosure is organized as follows:

1.

Draft revised FSAR pages, with changed portions indicated by a bar in the margin, as they are to appear in a future amendment (additional pages immediately preceeding and/or following the revised pages are provided if needed to understand the change).

2.

A line-by-line description / justification of each item revised.

3.

A copy of related SER/SSER sections.

4.

An index page containing the title of " bullets" which consolidates and categorizes similar individual changes by subject and related SER section.

OOD 2

I 8908210203 890815 400 N. Olive Dallas, Texa. 75201 l

PDR ADOCK 05000445 A

PDC

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TXX-89576:

- August 15, 1989 Page'2 of 2 5.

The bold / overstrike version of the revised FSAR pages referenced by the description / justification for each item identified above.

-The bold / overstrike version facilitates review of the revisions by highlighting each addition of new text in bold type font and overstriking with a slash (/) the portion of the text that is deleted.

If you h' ave any questions regarding this submittal please contact Joe Harnden at (214) 812-8226.

Sincerely,-

e William J. Ca ill, Jr.

WJH/smp

_ Enclosure 1

c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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1 Enclosure to TXX-89576 i

August 15. 1989_

l

. Advance FSAR Change Regarding the Safety System Inoperable Indication Panel Electrical Isolation and Separation Item 1 Draft Revised FSAR Pages pg. 2 thru 7 Item 2 Description / Justification pg. 8 thru 10 LItem 3 Related SER/SSER Pages pg. 11 thru 16 Item 4 Index Page Containing the pg. 17 Title of " Bullets" i

Item 5 Markup of Existing FSAR Pages pg. 18 thru 23 Pg. 1 of 23

4-Enclosure to TXX-89576 CPSES/FSAR ust 5 1989 Regulatory Position C.4 - The multiconductor cable between the Safety DRAFT System Inoperable Indication (SSII) logic panel located in the control room and the termination cabinet in the cable spreading room meet the requirements of this position except for Class IE environmental qualification. The cable materials meet IEEE Standard 383-1974 for the attributes of flame and radiation resistance. The cable is installed in a mild environment. Based on analysis, a fault at the SSII logic panel will not impact the availability of adjacent Class IE cables.with which these associated cables are routed. This analysis l.

is provided in Section 8.3.

Regulatory Position C.6 - Lesser separations are being used in several 64 locations between Class 1E wiring and non-Class IE Area Radiation Monitoring detector wiring and Public Address System speaker wiring based on analysis. This analysis is provided in Section 8.3.

Separation between associated circuits and non-Class 1E circuits in 76 fire panels CPX-EIPRLV-29, CPX-EIPRLV-29A, and CPX-EIPRLV-30 is not required based on analysis. This analysis is provided in Section 8.3.

Separation between associated cables and non-Class IE cables at the DRAFT Safety System Inoperable Indication panels is not required based on analysis. This analysis is provieed in Section 8.3.

Regulatory Position C.9 - Splice type connections have been used to 75 terminate field routed cables in raceways. Such splices are utilized in CPSES design at:

68 a.

Electric penetration assemblies (EPAs) and Thermocouple Reference 68 Junction Boxes l

l l

1A(B)-49 Draft Version

Enclosura to TXX-89576 Pg.'3 of 23 CPSES/FSAR

. -August 15,-1989

0032.69 51 The system functions like an annunciator system in that 3

activation of a field contact or momentary actuation of a backlighted pushbutton causes the light in that pushbutton to l

flash and the horn to come on.

Pressing the acknowledge button, l

silences the horn and the light becomes steady. Upon return to normal the light stays on until " reset" button is pressed.

0032.69 DRAFT For electrical schematic drawings, see drawings 2323-El-0071.

Nor PRRTOF

. r#,s umGr sheets 46 through 65, 67 and 68.

0032.69 11 2.

The SSII does not perform functions essential to mitigate the consequences of an accident, nor do administrative procedures require operator manual actions based solely on SSII displays.

SSII is implemented as a non-safety grade system consistent with 11 R.G. 1.47.

0032.69 DRAFT 3.

Electrical separation is based on analysis provided in Section 8.3.

The interface with safety systems and components is such that no degradation of safety systems will occur because of an SSI! failure.

0032.69 11 4.

The SSII display is automatically initiated for those inoperable conditions reasonable expected to occur more frequently than once per year when the affected system is normally required to be operable.

0032.69 51 5.

A means for manually initiating the SSII light exists for those l

maintenance or bypass activities.not automatically initiated.

The manual initiation consists of pressing the backlighted pushbutton used for display. This can only be cleared by again actuating the pushbutton.

0032.94 66 6.

An audible alarm is sounded when any bypass is automatically initiated.

C032.69 Draft Version 7.1-42

I Enclccura to TXX-89S76 Eg. 4 f 23 CPSES/FSAR August 15, 1989' i

66 The lighting circuits routed in ccnduit c:et the scparation criteria of Section 8.3.1.4.

l e.

Diesel Generator Neutral Ground System 66 i

66 The non-Class IE diesel generator neutral grounding transformer

{

I is connected to the neutral of the Class IE diesel generator.

An analysis has been performed which demonstrates that a fault on j

the non-Class IE portion of the circuit will not cause an unacceptable influence on the Class IE system.

In addition, the interconnecting cable is routed within the diesel generator room.

The cable is routed in dedicated raceway and is inspected to Class 1E requirements.

DRAFT f.

Safety System Inoperable Indication (SS!!) Panel Isolation and Separation DRAFT The Safety System Inoperable Indication (SSII) panels have input signal circuits originating from dry contacts in Class IE field devices. The SSII panel indication performs no safety-related function nor is operator acnual action required based solely on SSII displays. The equipment is nots-Class IE and is fe3 from a non-Class IE power source. The logic between the non-Class IE power circuits and the input circuits from the Class IE sources is not electrically isolated based on the following analysis.

DRAFT The output of the SSII power pack is at 115-VDC which is protected by a 0.5 amp fuse. The circuit to the individual field contact is current limited at the logic card to a value of 0.767 amp by means of a series resistor.

In addition, logic l

panel input power is protected by two 3 amp fuses in series.

l l

Field contacts at Class IE devices are rated for 250-VDC and 5 amp, which is more than adequate to handle the current and, as such, a fault at the SSII logic panel will not affect the Class l

l IE field contacts or devices.

B.3-55 Draft Version

Encio ura to TXX-89576'

'I k I

- 8 1

'Pge-5.of 23 l

Augurt 15,'1989 CPSES/FSAR 3

The multiconductor cable between the SSI! logic panel located in DRAFT the control room and the'terminatico cabinet in'the cable spreading room meet the requirements of Regulatory Guide 1.75 Revision 1. Regulatory Position C.4 except for Class IE environmental qualification. The cable materials meet IEEE Standard 383-1974 for the attributes of flame and radiation l

resistance. The cable is installed in a mild environment.

One cable is used per ESF train. The insulation is rated at 600V.

Any individual conductor is sized at a minimum #18 AWG while

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carrying a maximum 0.767 amps (current is limited at the 5511 l

logic card as noted above). The system is protected by a 0.5 amp fuse at the 115-VDC SSI! power supply. Based on the above

-i analysis, a fault at the SS!! logic panel will not impact the avaliability of adjacent Class IE cables with which these associated cables are routed.

8.

Compliance With NRC F4:gulatory Guide 1.81 [16]

i The CPSES design is in compliance with the provisions of Regulatory Guide 1.81.

Onsite Class IE AC and DC power sources are not shared between the two units nor are their respective electric distribution systems shared.

l l

Safety-related loads shared between both units are powered from 40 j

common MCCs. 120-VAC panels, and 125-VDC panels as described in Subsections 8.3.1.1.9 and 8.3.2.1.

Indication of source of l

power associated with the common electrical equipment mentioned above is provided on a common panel located in the Control Room j

l and accessible to both unit operators.

l 9.

Compliance With NRC Regulatory Guide 1.93 [18) l l

1 CPSES power operation procedure is in compliance with NRC 12 l

Regulatory Guide 1.93 as described in technical specifications.

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Draft Version 8.3-56 l

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.En91osura to Txx-89576 CPSES FSAR AMENDMENT l

Pg.'8 of 23 DETAILED DESCRIPTION August 15, 1989 FSAR Page (as amended)

Atmut Description i

1A(B)-49 2 _. Separation of associated multiconductor cable between SSII logic panel and termination cabinet is based on I

analysis.

Addition:

The multiconductor cable between the Safety System Inoperable Indication (SSII) logic panel located in the.

control room and the termination cabinet in the cable spreading room meet the requirements of Reg. Guide 1.75 Revision 1 Regulatory Position C.4 except for Class IE environmental qualification. The cable materials meet IEEE Standard 383-1974 for the attributes of flame and radiation resistance. The cable is installed in a mild environment. Based on analysis provided in Section 8.3 a fault at the SSII logic panel will not impact the availability of adjacent Class IE cables with which these associated cables are routed.

This change is consistent with the corrective actions for SDAR CP-87-085 (TXX-89568 dated August 4, 1989).

FSAR Change Request Number: 89-532.1

{

Related SER Section: 8.4.4:

SSER17 4.2.1.3 SER/SSER Impact: Yes SSER 17 Section 4.2.1.3 discussion does not reflect updated corrective action of analysis versus replace-ment.

1A(B.)-49 2

Separation and isolation between associated cables and non-Class 1E cables at the SSII panels is based on analysis.

Addition:

Separation and isolation between associated cables and non-Class IE cables at the Safety System Inoperable Indication (SSII) panels is based on analysis provided in Section 8.3.

The logic panel input power is protected by two 3 amp fuses and the output of the 115 VDC SS!! power pack is protected by a 0.5 amp fuse.

l The circuit to the individual field contact is current limited at the logic card to a value of 0.767 amp.

The field contacts are rated at 250 VDC end 5 amp.

Therefore, a fault at the SSI! logic penel will not

)

affect the Class IE field contacts or devices.

This change is consistent with the corrective actions for SDAR CP-87-085 (TXX-89568 dated August 4, 1989).

FSAR Change Request Number: 89-532.2 Related SER Section: 8.4.4:

SSER17 App.A&B SER/SSER Impact: Yes SSER 17 Appendix A Open Item E-29 and Appendix B DIR No. D-1527 discussions do not reflect updated j

corrective action of analysis. Two series fuses are installed on logic panel input power, but the panels l

L

Enclorura to TXX-89576

.Pg.1 9 of 23 -

CPSES FSAR AMENDMENT August 15, 1989-DETAILED DESCRIPTION FSAR Page (as amended)

Greun Descristinn are non-Class IE.

7.1-42 2

Electrical separatics of the SSII panels is based on analysis provided in Section 8.3.

Revision:

Electrical separation of the Safety System Inoperable Indication (SSII) panels is described in and associated analysis provided in Section 8.3.

The interface with safety systems and components is such that no degrada-tion of safety systems will occur because of an SSII failure.

FSAR Change Request Number: 8g-532.3 Related SER Section: 8.4.4; SSER17 App.A&B SER/SSER Impact: Yes SSER 17 Section 4.2.1.3. Appendix A Open Item E-29 and Appendix B DIR No. D-1527 discussions do not reflect updated corrective action of analysis.

8.3-55, 56 2

Electrical separation of the SSI! panels is based on analysis.

Addition:

Electrical separation of the Safety System Inoperable Indication (SSII) panels is described in and associated analysis provided in Section 8.3.

The interface with safety systems and components is such that no degrada-tion of safety systems will occur because of an SSII failure.

Separation and isolation between associated cables and non-Class 1E cables at the SSII panels is based on analysis. The logic panel input power is protected by two 3 sep fuses and the output of the 115 VDC SS!!

power _ pack is protected by a 0.5 amp fuse. The circuit to the indivudval field contact is current limited at the logic card to a value of 0.767 amp. The field contacts are rated at 250 VDC and 5 amp. Therefore, a fault at the SSII logic panel will not affect the l

Class 1E field contacts or devices.

The multiconductor cable between the SS!! logic panel located in the control room and the termination cabinet in the cable spreading room meet the requirements of l

Reg. Guide 1.75 Revision 1 Regulatory Position C.4 l

except for Class 1E environmental qualification. The l

cable is installed in a mild environment.

Based on the l

cable attributes and limited current (as described above and in the analysis), a fault at the SSII logic panel will not impact the availability of adjacent Class IE cables with which these associated cables are routed.

This change is consistent with the corrective actions I

I:ncictura to Txx-89576' Pg. 10'of 23 CPSES FSAR ANENDNENT Augu;t 15, 1989 DETAILED DESCRIPTION

+

FSAR Page (as amended)

Group Description for SDAR CP-87-085 (TXX 89568 dated August 4. 1989).

FSAR Change Request Number: _89-532.4 Related SER Section: 8.4.4:

SSER17 App.A&B SER/SSER Impact: Yes SSER 17 Section 4.2.1.3, Appendix A Open Item E-29 and Appendix B DIR No. 0-1527 discussions do not reflect updated corrective action of analysis. Two series fuses are installed on logic panel input power, but the panels are non-Class 1E.

Table 8.3-10 2

See Sheet No(s):5, 6 Separation between the associated circuits and non-Class 1E circuits in the SS!! panels is not required based on analysis.

Addition:

Electrical separation of the Safety System Inoperable Indication (SS!!) panels is described in and associated analysis provided in Section 8.3.

The interface with safety systems and components is such that no degrada-tion of safety systems will occur because of an SSII failure. The SSII panels are added to the table along with an appropriate note.

FSAR Change Request Number: 89-532.5 Related SER Section: 8.4.4:

SSER17 App.A&B SER/SSER Impact: Yes SSER 17 Appendix B DIR No. D-1527 discussion does not reflect updated corrective action of analysis. Two series fuses are installed on logic panel input power.

but the panels are non-Class 1E.

i l

1 i

I 1

l

Encloruri to TXX-89576

'Pg. 11 of 23

' August 15,-1989

,s b

result in needless hindrance to successful ccepletion of safety functions.

Regulatory Guide 1.106 recommends (in-Position C.1) bypassing thermal overload M

devices during accident conditions or (in Position C.2) selecting the setpoints for the thermal overloads in a manner that precludes spurious trips.

In the Comanche Peak design, Class IE MOV motor starters are provided.with thermal' overloacs, connected to alarm only.

Thermal magnetic breakars are used to trip the starter ~for sustained lockad-rotor conditions.

This dasign is in conformance with Regulatory Guide 1.105 and is acceptable.

8.4.3 Power Lockout to Motor-Operated Valves The applicant has provided a list of valves that require power lockout in order to meet the single-failure criterion in the fluid systems.

Branch Technical Position ICSB 18 (PSB) requires that all such valves and their required position be listed in the Technical Specifications and that the position indications for these valves meet the single-f ailure critericn.

The applicant has not submitted the Technical Specifications for review, but a start toward compliance with BTP-ICSB 18 (PSB) is accomplished by providing-position indication and out-of position alarms at the control board and a control powar cutoff switch for each valve.

The applicant states that spurious movement of an MOV as a result of an electrical fault in the motor actuation circuitry, coincident with a LOCA, has been analyzed and found to be a very low probability event.

However, to comply with.the present NRC position on this issue, the applicant has made the commitment to comply with BTP-ICSB-18.

Compliance is accomplished by providing C

a control board control power cutoff switch for each valve.

In order to meet the staff requirements that redundant valve status indication be provided to the control room operator, the applicant'has provided redundant and separate valve position switches.

One position switch is gear-driven and mounted on the valve operator.

The pecond position switch is mounted on the valve stem.

In the event that one position switch is inoperable, the second will be available to provide position indication.

Each position switch actuates a separate indicating light in the main control room. Thase indicating lights are powered from separate powar supplies.

The applicant has not yet submitted t: a draft Technical Specifications.

The staff will ensure that the valves and their required positions are included in the Technical Specifications when performing this aspect of our review.

--p-8.4.4 Physical Identification and Independence of Redundant Safety-Related Electrical Systems The applicant has provided the criteria for physical identification and separa-tion of electrical equipment to preserve the independence of redundant equipment.

Physical identification of safety-related electrical systems is accomplished as follows.

Each cable and raceway is given a unique alphanumeric identifica-tion and is color coded to indicate its separation group.

This identification provides a means of distinguishing a cable or raceway associated with a particular separation group.

n 4

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8-15

}

Enclosura to'Txx-89576

?-

pg. 12 of 23 A

August 15,.1989

-Exposed raceways containing Class IE cables are marked by color codes in a distinct permanent manner at intervals not to excaed 15 ft and at points of A

y entry to and exit frcm enclosed areas.

In general, all Class IE cables and f' associated cables are jacket color-coded throughout their entire length, g il.

Cables that~ require field color coding will be so worked at intervals not to exceed 5 ft.

Non-Class 1E equipment, raceways, and cables in raceways are not marked by color code and have a black outer jacket.

In plant ar?as which are free from potantial hazards such as missiles, external fires, and pipe whip, the minimum separation between redundant caole trays is 3 ft between trays separated horizontally and 5 ft between trays seoarated vertically.

In the cable spreading areas and the control rcom, the minimum separation between redundant cable trays is 1 ft between trays separated horizontally and 3 ft between trays separated vertically.

Where plant arrangements preclude maintaining the minimum separation distance, the redundant circuits are run in solidly enclosed raceways or other barriers provided between redundant circuits in accordance with Regulatory Guide 1.75.

In addition, each reactor protection system or ESF system at the channel level has its own distinct color.

Protaction of equipment against simultaneous failures is achieved by physical arrangement and separation between redundant Class 1E systems Each diesel generator, including its associated auxiliaries, is located in a separate room.

The electrical switchgear of train A is separated from that of trai'n B by locating them on different elevations.

Each Class 1E 125-V dc battery is located in a se'parate and independently ventilated room.

are separated from those of other trains by locating them in separate The Class lE MCCs and distr #bution panels of one train are separated from those of the other train by a distance of at least 20 ft.

Where it is not possible to maintain a 20-ft distance,* barriers are provided to maintain proper separation.

The control room and cable spreading area do not contain

~

high energy equipment such as switchgear, transformers, rotating equipment, high-energy piping, or other potential sources of missiles.

Based on its review of the applicant's design criteria regarding physical identification, separation, and independence of redundant safety-related electrical systems, the staff finds these criteria to be in accordance with Regulatory Guide 1.75 and, therefore, acceptable.

However, the staff will verify the implementation of applicant's design criteria for these areas during a site visit.

8. 4. 5 Nonsafety Loads on Emergency Sources Present regulatory practice for Operating License applications allows the connection of nonsafety loads--in addition to the required safety loads--to Class 1E (emergency) power sources if it can be shown that the connection of nonsafety loads will not result in degradation of the Class 1E system.

The Comanche Peak design provides for the connection of both safety and selected nonsafety loads to the Class 1E emergency buses of the ac and de onsite emergency power systems.

8-15

___________m__

l Enclotura to TXX-89576 p

Pg.: 13 of 23

.. LAugust 15, 1989 l'

(

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l of design and vendor documents.

Typical load data include motor horsepower, equipment operating modes, and bus assignment.

The information is identified within a computerized database and is controlled in accordance with SWEC design control Project Procedure PP-077 (Reference'83).

These data were used as input to various design' validation processes such as validation of calculations and drawings.

The load list is a source of electrical load data at CPSES Unit 1 and common areas.

It provides a controlled means of using electrical load information among interfacing disciplines.

Additional or modified load data are entered into the database, and the load list is periodically revised and reissued.

In summary, the scope of the CAP addresses the CPSES safety-related electrical design on an integrated, comprehensive basis rather than thi gh a separate program directed at specific issues.

This approach is inte ded to ensure that any generic implications of known electrical design issues and any undetected electrical design issues are identified and resolved and that undetected elec-trical design-related deficiencies that are safety significant will not. exist in the CPSES validated design.

4.2.1.3 Results As a result of the electrical design validation process, SWEC developed the following hardware modifications, which are being implemented:

The preferred power system has been augmented by dedicating the existing

/

startup transformers to the safety-related buses.

In addition, two new startuptransformershavebeenaddedtopowerthenon-safety-relatedbuses.('

The structural embedments and concrete floor were reworked to provide a level foundation for the 6.9-kV switchgear.

The capability of the 6.9-kV nonsegregated phase bus was adjusted by improving the bus ventilation so the bus rating (ampacity) complies with the design criteria.

Control circuits were modified to ensure that supply voltages are within operating ranges required by the control device.

Cable sizes for certain power circuits were increased to ensure that circuit ampacity or supply voltage meets load requirements.

Power and control circuits and protective devices were modified to ensure adequate penetration and electrical protection, ampacity, and short circuit capability.

Circuits are being modified to add isolation devices between Class 1E and non-Class 1E equipment used in the circuits (solid-state protection system power supply, reactor coolant pump underfrequency trip signal), or non-Class 1E equipment was disconnected from Class 1E sources (motor control l

center space heaters).

\\

Comanche Peak SSER 17 4-34

  • ~

Enclo ura to TXX-89576

Pg. 14.of 23 August 15, 1989

' Damaged equipment (bus insulators, electric conductor seal assemblies, and

(

enclosure door gaskets) or incorrect devices (de relays and-fuses) were replaced.

The essential ac and emergency de lighting systems are being modified to bring.tha systems into compliance with the design criteria.

Control circuits were redesigned to ensure adequate terminal voltages.

Panel circuits were reassigned to provide compatibility between load and panel types.

Separation barrier material used to separate cables and raceways was removed because of its high derating effect on ampacity.

Where required, it is being replaced with a material requiring less derating.

Design changes were implemented to provide electrical separation between Class IE and non-Class 1E radiation monitoring circuits and fire protec-tion circuits.

The 6.9-kV control circuits for the reactor coolant pumps and for the Class IE 480-V ac load center bus tie breakers were modified to ensure adequate protection of containment penetrations.

Cables for which Thermolag was used as a fire barrier were rerouted or replaced with larger cables or a combination of both if required to comply with ampacity design criteria.

Battery chargers were modified to ensure adequate cooling.

- Weidmuller terminal blocks that were identified as not being environmen-tally qualified are being removed and replaced by butt splices with environmentally qualified insulating material.

Cables that were designated as Class 1E cables but that do not perform a safety-related function are being properly redesignated as non-Class 1E and are being rerouted in non-Class 1E raceways.

Cables that did not meet Class 1E requirements (those associated with the safety system inoperable indication) are being replaced with qualified cable with, proper isolation.

Cable arrangements for certain power circuits are being modified to agree with the revised installation specification requirements to ensure balanced currents in each cable of circuits with "multiconductor per phase" design.

4.2.2 Staff Actions 4.2.2.1 Design Insp*ections l

The electrical design inspections included the review of design documents l

relating to the Class IE de power system, motor control center starter coil pickup analyses, protective relay settings, the Class 1E 6.9-kV power system, gComanche Peak SSER 17 4-35 L _ _ _.__

Enclorure to TXX-89576 K

Pg.*15 of 23-August 15, 1989 NRC EVALUATION Based on the above commitment that power cables always maintain one' inch minimum separation in conjunction with two enclosures, we find the response acceptable.

This item is c?nsed.

OPEN ITEM E-29 (CLOSED)

Document Number:

DBD-EE-057, Revision 0, Separation Criteria section 4.1.3 in DBD-EE-057 states, " Lack of isolation device shall be justified by analysis." We found that analyses and justifications were prepared for the power level circuits.

Similar analyses for the control and instrumentation circuits were not available.

We also reviewed the disposition of various field identified problems (Refer to documents listed under 1.f through 1.s.) These have been adequately dis-positioned is accordance DBD-EE-057.

RESPONSE

Refer to Amendment 68 FSAR Section 8.3.1.2.1, paragraph 7.B and C for isolation of control and instrumentation circuits.

The DBD-EE-057, Section 4.1.3 provision for " Lack of isolation device shall be justified by analysis" has not been utilized.

In all cases an isolation device C

has been provided. All Class 1E elementary diagrams have been reviewed to assure that all circuit devices are either specified as Class 1E or an isolation device is provided.

SIGNIFICANCE / EXTENT There is no safety concern because the FSAR change documents analyses of iso-lation devices for the control and instrumentation circuits.

NRC EVALUATION The project has stated that all_ elementary diagrams have been reviewed to assure that isolation devices are provided in each control and instrumentation circuit when needed. We reviewed some examples of the results of this review, e.g., DCA 68600/0, Inter-Office Memo dated 3/12/87 from Steve Kim to E. Heneberry, Inter-Office Memo dated 11/16/87 from R. L. Poltrino to E. Heneberry.

These examples in conjunction with the staff's review of FSAR Section 8.3.1.2.1 resolve the concern.

Therefore, this item is closed.

OPEN ITEM E-30 (CLOSED)

Document Number:

Calculation 16345-EE(B)-048, Revision 0, Protection and Ampacity of Electrical Containment Penetration.

This calculation addresses protection for twenty-three classes of electrical penetration circuits.

Of these twenty-three, the calculation shows that nine-teen do not meet one or more of the three established criteria.

Based on Comanche Peak SSER 17 75 Appendix A

Enclosurs'to TXX-89576

'. Pg.7 16 of 23 L k

August 15,;1989 DIR NO:

0-0896, Rev. 0

' PROBLEM STATEMENT Loading Calculation V-7, Revision 5, does not provide analysis method, accept-

'ance criteria or adequate justification for inverter load determination.

DISPOSITION Load determination analysis method, acceptance criteria, and justification is not a function of Calculation V-7, but rather that of Calculation VII-13.

This calculation has been superseded by SWEC calculation 16345-EE(B)-005 which defines the analysis method and the relationship of actual inverter loads to inverter ratings.

NRC EVALUATION SWEC Calculation 16345-EE(B)-005, Rev. 2, dated 3/24/88, " Static Uninterrupt-ibic Power Supply System Determination of Class 1E UPS Loading," provides the analysis method and the relationship of actual inverter loads to inverter rat-ings. We agree that this resolves the concern.

DIR NO:

0-1527, Rev. 2 PROBLEM STATEMENT Cannot determine if supporting analysis was performed to demonstrate that AFW

(

Class 1E circuits are not degraded below an acceptable level by the SSII logic circuit.

Ref. IEEE-384, paragraph 5.6.(4).

DISPOSITION It was determined that SSII Logic Panel is not environmentally qualified.

Given this fact it could be assumed that' multiple faults could occur that could flow through field contacts and degrade Class 1E side of the input circuit.

Isola-tion of non-Class 1E circuit from Class IE circuits will be provided by two Class IE fuses to comply with IEEE-384.

DCA-60060 has been written to provide qualified isolation between Class IE and non-Class IE circuits.

NRC EVALUATION Two Class 1E fuses connected in series are considered adequate for the purpose of electrically isolating the logic panel from the Class IE circuits.

This arrangement is considered adequate to preclude Class 1E circuit degradation (due to faults or failures associated with the Non-Class 1E logic panel) below l

an acceptable level. We agree with project actions to resolve the DIR concern.

1 i

Comanche Peak SSER 17 29 Appendix B

_ _ _ = _ - _ _ _

Enclo:ura to TXX-89576 E

.Pg.'1,7.of 23 August 15, 1939 8.4.4 Physical Identification and Independence of Redundant and Safety Related Electrical Systems

26. Adds Reg. Guide 1.75 analysis for electrical isolation and separation of Safety System Inoperable Indication (SSII) logic panels and associated cables.

_.. ~. - _ - -. -. -.... _. - - _.

= _ - - - - _ _ _ - - _ _ - - - - _ _ _ - - - - -

LII Enclosure to TXX-89576 9

Pg. 18 of'23 August 15, 1989 CPSES/FSAR Regulatory Position C.4 - The multiconductor cable between the Safety System Inoperable Indication (SSII) logic panel located in the control l,

room and the termination cabinet-in the cable spreading room meet the

- requirements of this position except for Class IE environmental qualification. The cable materials meet IEEE Standard 383-1974 for the attributes of flame and radiation resistance. The cable is installed in a mild environment. Based on analysis, a fault at the SSII logic panel will not impact the availability of adjacent Class IE cables with which these associated cables are routed. This analysis is provided in Section 8.3.

64 Regulatory Position C.6 - Lesser separations are being used in several locations between Class 1E wiring and non-Class IE Area Radiation Monitoring detector wiring and Public Address System speaker wiring based on analysis. This analysis is provided in Section 8.3.

76 Separation between associated circuits and non-Class IE circuits in fire panels CPX-EIPRLV-29 CPX-EIPRLV-29A. and CPX-EIPRLV-30 is not required based on analysis. This analysis is provided in Section 8.3.

Separation between associated cables and non-Class IE cables at the Safety System Inoperable Indication panels is not required based on analysis. This analysis is provided in Section 8.3.

i 75 Regulatory Position C.9 - Splice type connections have been used to terminate field routed cables in raceways.

Such splices are utilized 68 in CPSES design at:

I 68 a.

Electric penetration assemblies (EPAs) and Thermocouple Reference Junction Boxes 1

1A(B)-49 Bold /0verstrike Version

Enclosura to TXX-89576 Pg. 19,of.23 CPSES/FSAR e

August 15,-1989 0032.69 51-The system functions like an annunciator system in that activation of a field contact, or momentary actuation of a backlighted pushbutton causes the light in that pushbutton to flash and the horn to come on.

Pressing the acknowledge button, silences the horn and the light becomes steady. Upon return to normal, the light stays on until " reset" button is pressed.

0032.69 1,1 For electrical schematic drawings, see EEM drawings 2323-El-0071, p

g,.

oFy5 sheets 46 through 65, 67 and 68.

g 0032.69 11 2.

The SSII does ntt berform functions essential to mitigate the consequences of an accident, nor do administrative procedures require operator manual actions based solely on SSII displays.

SSII is implemented as a non-safety grade system consistent with 11 R,G. 1.47.

0032.69 3.

App /dp/fifd Electrical separation is based on analysis provided 11 in Section 8.3.

t/ffdtid A/d dppIfdd fd The interface with safety systems and components is such that no degradation of safety systems will occur is pdiff 87d because of an SSII failure.

0032.69 11 4.

The SSII display is automatically initiated for those inoperable conditions reasonable expected to occur more frequently than once per year when the affected system is normally required to be operable.

0032.69 l

51 5.

A means for manually initiating the SS!! light exists for those maintenance or bypass activities not automatically initiated.

The manual initiation consists of pressing the backlighted pushbutton used for display. This can only be cleared by again actuating the pushbutton.

1 0032.94 66 6.

An audible alarm is sounded when any bypass is automatically j

initiated.

l 0032.69 Bold /0verstrike 7.1-42 Version

'8'~ Enclosure to TXX-89576 l

l 'e' Pg.'20 of 23 CPSES/FSAR i

b August 15, 1989 l

l'*

66 Tha lighting circuits rcuted in conduit cast tho scparation

)

1 triteria of Section 8.3.1.4.

l l

e.

Diesel Generator Neutral Ground System 66 l

66 The non-Class 1E diesel generator neutral grounding transformer is connected to the neutral of the Class 1E diesel generator.

An analysis has been performed which demonstrates that a fault on the non-Class IE portion of the circuit will not cause an unacceptable influence on the Class IE system.

In addition, the interconnecting cable is routed within the diesel generator room.

The cable is routed in dedicated raceway and is inspected to Class IE requirements.

f.

Safety System Inoperable Indication (SSII) Panel Isolation and Separation The Safety System Inoperable Indication (SSII) panels have input signal circuits originating from dry contacts in Class IE field devices. The 55I1 panel indication performs no safety-related function nor is operator manual action required based solely on SSII displays. The equipment is non-Class IE and is fed from a non-Class 1E power source. The logic between the non-Class IE power circuits and the input circuits from the Class IE sources is not electrically isolated based on the following analysis.

The output of the SSII power pack is at 115-VDC which is protected by a 0.5 amp fuse. The circuit to the individual field contact is current limited at the logic card to a value of 0.767 amp by mee.ns of a series resistor.

In addition, logic panel input power is protected by two 3 esp fuses in series.

Field contacts at Class IE devices are rated for 250-VDC and 5 sep, which is more than adequate to handle the current and, as such, a fault at the SSII logic panel will not affect the Class IE field contacts or devices.

8.3-55 Bold /0verstrike Version

a~

. Enclosure to TXX-89576 Pg.'21 of 23 August 15, 1989 CPSES/FSAR l-The multiconductor cable between the SSII logic panel located in the control room and the termination cabinet in the cable spreading room meet the requirements of Regulatory Guide 1.75, Revision 1. Regulatory Position C.4 except for Class IE environmental qualification. The cable materials meet IEEE Standard 383-1974 for the attributes of flame and radiation resistance. The cable is installed in a mild environment. One cable is used per ESF train. The insulation is rated at 600V.

Any individual conductor is sized at a minimum #18 AWG while carrying a maximum 0.767 amps (current is limited at the SSII logic card as noted above). The system is protected by a 0.5 amp fuse at the 115-VDC SSII power supply. Based on the above analysis, a fault at the SSII logic pane? will not impact the availability of adjacent Class IE cabies with which these associated cables are routed.

8.

Compliance With NRC Regulatory Guide 1.81 [16)

The CPSES design is in compliance with the provisions of Regulatory Guide 1.81.

Onsite Class IE AC and DC power sources are not shared between the two units nor are their respective electric distribution systems shared.

Safety-related loads shared between both units are powered from 40 common MCCs, 120-VAC panels, and 125-VDC panels as described in Subsections 8.3.1.1.9 and 8.3.2.1.

Indication of source of power associated with the common electrical equipment mentioned 9

above is provided on a common panel located in the Control Room and accessible to both unit operators.

9.

Compliance With NRC Regulatory Guide 1.93 [18]

CPSES power operation procedure is in compliance with NRC 12 Regulatory Guide 1.93 as described in technical specifications.

Bold /0verstrike 8.3-56 Version

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