ML20215B713

Rev 4 to Issue Specific Action Plan Isap I.b.3, Conduit to Cable Tray Separation

ML20215B713
Person / Time
Site:	Comanche Peak
Issue date:	01/24/1986
From:	Beck J, Mallanda J, Mallanda J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20197E251	List: IA-86-272, Discusses 851113-14 Audit of Comanche Peak Response Team Const Evaluation Program in Area Re Piping & Pipe Supports. Three Unresolved Items Listed IA-86-454, Submits Update of 860408 Schedule for Remaining Work Needed on Sser 13 for Comanche Peak Program Plan.Related Info Encl ML20197E245 ML20197E254 ML20197E289 ML20198A376 ML20198G456 ML20210A924 ML20210K577 ML20215B696 ML20215B713 ML20215B725 ML20215B728 ML20215B734 ML20215B736 ML20215B741 ML20215B742 ML20215B745 ML20215B749 ML20215B798 ML20215B805 ML20215B816 ML20215B827 ML20215B835 ML20215B876 ML20266H095 ML20266H108 ML20266H113 ML20266H148 ML20266H159 ML20266H170 ML20266H176 ML20266H183 ML20266H193
References
FOIA-86-272, FOIA-86-454 ISAP-I.B.3, PROC-860124-01, NUDOCS 8610080400
Download: ML20215B713 (7)

Text

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1 L COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP I,b.3 i

Title:

Conduit to Cable Tray Separation I

l Revision No. 4 l Reflects Comments Description On Plan j Prepared and Recommended by:. ,

Review Team ,

Leader Date EY

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l Approved by:

Senior Review Team [h t.1 b ,f __

Date /f1-4lf

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hokOO O 861003 GARDE 86-272 PDR I I

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ISAP I.b.3 Conduit to Cable Tray Separation

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC (NUREG-0797, Supplement No.

7, Page J-42)

"The TRT found no evidence that the existing G&H analysis for establishing the criteria for a 1-inch separation between rigid conduits and cable trays, as stated in G&H Electrical Erection Specification 2323-ES-100, had been evaluated by the NRC staff for Comanche Peak. This analysis should have been referenced in the FSAR."

2.0 ACTION IDENTIFIED BY NRC (NUREG 0797, Supplement No. 7, Item 6(e),

Page J-44)

"TUEC shall accomplish the following actions prior to fuel load:

Submit to the NRC the analysis substantiating the acceptability of the criteria stated in G6H electrical erection specification governing the separation between separate conduits and cable trays.

This analysis shall be supported with the necessary documentation in sufficient detail to perform an independent evaluation of how these criteria were established based on the analysis."

3.0 BACKGROUND

Raceway separation criteria utilized in Gibbs & Hill electrical drawings and specifications were based upon the requirements of IEEE 384-1974 and Regulatory Guide 1.75 (Revision 1, 1/75). Although very specific criteria are provided in the standard and regulatory guide for separation between cable trays, the interpretation and application of that criteria for separation between conduits and cable trays is not specified.

Documents internal to Gibbs & Hill were prepared to establish-the engineering interpretation of required separation between conduits and cable tray in accordance with established criteria in the standard and regulatory guide. These documents were not-submitted to the NRC staff for review because the interpretation was not considered a deviation to the standard or regulatory guide, but was considered documentation supporting the implementation of these requirements. It is industry practice to not submit"such implementing documents to the NRC.

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ISAP I.b.3 (Cont'd) l l

4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this actica plan is to substantiate the acceptability of the criteria governing the separation between conduits and cable trays, and submit the evaluation and supporting documentation to the NRC.

To achieve this objective, the following tasks' will be implemented:

- Prepare Gibbs & Hill report compiling criteria

- Review report to substantiate separation criteria

- Submit report to NRC 4.1.1 Report Preparation Gibbs & Hill will prepare a report for TUGC0 presenting the methodology and criteria used in applying IEEE-384(1974) and Regulatory Guide 1.75 (Revision 1, January 1975) to conduits requiring separation from  ;

redundant cable trays. Included will be a copy of a l Sandia Report (" Cable Tray Fire Tests" SAND 77-1125C) which is the primary reference used in establishing the l separation criteria. l l

.4.1.2 Report Review The above report will be submitted to the Review Team Leader and his third-party adviser for review.

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ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 Report Submittal to NRC After the report has been reviewed and approved, it and any supporting documents will be submitted by TUGC0 to the NRC for review. An FSAR Change Request will be initiated to provide a description of the cable tray-to-conduit separation criteria in the FSAR.

4.2 Participants Roles'and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective work scope.

4.2.1 TUGC0 Comanche Peak Project

4. 2.1.1' Assist the Review Team Leader in reviewing the report compiling the Gibbs & Hill criteria.

4.2.1.2 Submit, upon approval, the report to the NRC.

4.2.1.3 Personnel Mr. W. I. Vogelsang, TUGC0 Coordinator 4.2.2 Electrical Review Team 4.2.2.1 Review the report compiling the Gibbs & Hill criteria.

4.2.2.2 Review NCRs and inspection reports, if any.

I-4.2.2.3 Personnel (prior to October 18, 1985)

1. Mr. M. B. Jones, Jr., Review Team Leader Mr. E. P. Stroupe Issue Coordinator 4.2.2.4 Personnel (starting October 18, 1985)

Mr. J. J. Mallanda, Review Team Leader Mr. R. J. Bizzak, Issue Coordinator Mr. M. B. Jones, Jr., Third-Party Adviser l Mr. E. P. Stroupe, Third-Party Adviser e

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ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.3 Gibbs & Hill 4.2.3.1 Prepara a report compiling the criteria used in confirming the adequacy of conduit-to-cable tray separation.

4.2.3.2 Personnel Mr. S. P. Martinovich, Senior Electrical Engineer l

4.2.4 Third-Party Adviser 4.2.4.1 Review the report compiling the Gibbs & Hill criteria r 4.2.4.2 Personnel Mr. L. D. Bates, Third-Party Adviser l 4.3 Qualification of Personnel Where tests or inspections require the use of certified inspectors, qualifications at the appropriate level will be to the requirements of ANSI N45.2.6, " Qualification of Inspection, Examination, and Testing Personnel at Nuclear Power Plants." CPRT third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program, and specifically trained to the CPRT Program Plan.

Third-party participants in the implementation of this action plan will meet the personnel qualification and objectivity requirements of the CPRT Program Plan and its implementing procedures. 1 Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. Activities performed by other than third-party personnel will be governed by the applicable principles of Section III.K, " Assurance of CPRT Program Quality", of the CPRT Program Plan.

4.4 Procedures Not applicable.

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Paga 5 of 5 ISAP I.b.3 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) .

4.5 Acceptance Criteria The acceptance criterion for the report is that it demonstrate that the cable tray-to-conduit separation criteria meet the intent of IEEE-384 (1974) and Regulatory Guide 1.75, Revision l 1, January 1975.

4.6 Decision Criteria If compliance with IEEE-384 (1974) and Regulatory Guide 1.75, Revision 1, January, 1975 cannot be adequately demonstrated, the conduits and cable trays will be modified, as appropriate, to achieve compliance.

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