ATTACHMENT 2 Letter from Mark L. Marchi (WPSC) To … · @ 1999 Westinghouse Electric Company, LLC...

37
ATTACHMENT 2 Letter from Mark L. Marchi (WPSC) To Document Control Desk (NRC) Dated October 1, 1999 Reactor Protection and Engineered Safety Features Upgrade "Environmental, Seismic And Electromagnetic Compatibility Qualification Test Plan for E3 Class 1E Electrical Equipment for the Kewaunee Nuclear Power Plant Reactor Protection System Replacement Project" - Non-Proprietary Class 3 \\GBNUCI\VOLI\GROUP\NUCLEAR\WPFILES\LIC\NRCRS ESF UPGRADE PROJECTDOC

Transcript of ATTACHMENT 2 Letter from Mark L. Marchi (WPSC) To … · @ 1999 Westinghouse Electric Company, LLC...

Page 1: ATTACHMENT 2 Letter from Mark L. Marchi (WPSC) To … · @ 1999 Westinghouse Electric Company, LLC Nuclear Projects Division P.O. Box 598 Pittsburgh, PA 15230-0598 ... 5-1 Environmental

ATTACHMENT 2

Letter from Mark L. Marchi (WPSC)

To

Document Control Desk (NRC)

Dated

October 1, 1999

Reactor Protection and Engineered Safety Features Upgrade

"Environmental, Seismic And Electromagnetic Compatibility Qualification Test Plan for E3 Class 1E Electrical Equipment for the Kewaunee Nuclear

Power Plant Reactor Protection System Replacement Project"

- Non-Proprietary Class 3

\\GBNUCI\VOLI\GROUP\NUCLEAR\WPFILES\LIC\NRCRS ESF UPGRADE PROJECTDOC

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Westinghouse Non-Proprietary Class 3

Environmental, Seismic and

Electromagnetic Compatibility Qualification Test Plan

for E3 Class IE Electrical Equipment

Kewaunee Nuclear Power Plant Reactor Protection System

Upgrade Project

September 1999

All Rights Reserved @ 1999 Westinghouse Electric Company, LLC

Nuclear Projects Division P.O. Box 598

Pittsburgh, PA 15230-0598

9910060081,991001 PDR ADOCK 05000305 P PD R

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Westinghouse Non-Proprietary Class 3

HISTORY OF REVISIONS

Revision Revision Made By Description and Impact of the Change Date

0 Suresh Channarasappa Original Issue September 1999

09/27/99 - Rev 0KNPP E3 Equipment Qualification Plan

i/ii

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TABLE OF CONTENTS

Title

History of Revisions Table of Contents List of Tables List of Figures References List of Acronyms

Introduction

Codes and Standards

Equipment Classification

Equipment Description

Qualification Requirements

Qualification Methodology

Maintenance, Surveillance and Replacement Program

Documentation

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Section

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

Page

ivi iii iv IV

vi ix

I

3

5

8

9

18

25

26

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LIST OF TABLES

Title

E3 Equipment Safety Classification

Environmental Qualification Requirements

EMC Qualification Requirements: Emissions

EMC Qualification Requirements: Susceptibility

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3-1

5-1

5-2

5-3

Page

7

10

12

13

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Westinghouse Non-Proprietary Class 3

LIST OF FIGURES

PageTitle

5-1 Environmental Qualification Test Profile

5-2 Operating Basis Earthquake Required Response Spectrum

(Horizontal Direction)

5-3 Operating Basis Earthquake Required Response Spectrum

(Vertical Direction)

5-4 Safe Shutdown Earthquake Required Response Spectrum

(Horizontal Direction)

5-5 Safe Shutdown Earthquake Required Response Spectrum

(Vertical Direction)

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11

14

15

16

17

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Westinghouse Non-Proprietary Class 3

REFERENCES

1. Regulatory Guide 1.89, "Qualification of Class 1 Equipment for Nuclear Power

Plants," U.S. Nuclear Regulatory Commission, Revision 1, June 1984.

2. Regulatory Guide 1.100, "Seismic Qualification of Electrical and Mechanical

Equipment for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, Revision 2, June 1988.

3. IEEE Standard 323-1983, "IEEE Standard for Qualifying Class 1 E Equipment for

Nuclear Power Generating Stations," Institute of Electrical and Electronics

Engineers, Inc., 1983.

4. IEEE Standard 344-1987, "IEEE Recommended Practice for Seismic

Qualification of Class 1 E Equipment for Nuclear Power Generating Stations,"

Institute of Electrical and Electronics Engineers, Inc., 1987.

5. Draft Regulatory Guide DG-1 029, "Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety Related Instrumentation and

Control Systems," U.S. Nuclear Regulatory Commission, February 1998.

6. EPRI TR-1 02323, Revision 1, "Guidelines for Electromagnetic Interference

Testing In Power Plants," Electric Power Research Institute, January, 1997.

7. IEC Standard 61000-4-2, 1998, "Electromagnetic compatibility (EMC) Part 4:

Testing and measurement techniques-Section 2: Electrostatic discharge

immunity test," Basic EMC Publication.

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Westinghouse Non-Proprietary Class 3

8. IEC Standard 61000-4-3, 1998, "Electromagnetic compatibility (EMC)-Part 4:

Testing and measurement techniques-Section 4: Radiated, radio frequency, electromagnetic field immunity test". Basic EMC Publication.

9. IEC Standard 61000-4-4, 1995, "Electromagnetic compatibility (EMC)-Part 4:

Testing and measurement techniques-Section 4: Electrical fast transient/burst

immunity test," Basic EMC Publication.

10. IEC Standard 61000-4-5, 1995, "Electromagnetic compatibility (EMC)-Part 4: Testing and measurement techniques-Section 5: Surge immunity test," Basic

EMC Publication.

11. lEC Standard 61000-4-6, 1996, "Electromagnetic compatibility (EMC)-Part 4:

Testing and measurement techniques-Section 6: Immunity to Conducted

Disturbances, Induced by Radio-Frequency Fields."

12. IEC Standard 61000-4-11, 1995-03, "Electromagnetic compatibility (EMC)-Part 4: Testing and measurement techniques-Section 11: Voltage Dips, Short Interruptions and Voltage Variations Immunity Tests".

13. MIL-STD-461 C, "Military Standard-Requirements for the Control of

Electromagnetic Interference Emissions and Susceptibility," August, 1986.

14. MIL-STD-461 D, "Military Standard-Requirements for the Control of Electromagnetic Interference Emissions and Susceptibility," January, 1993.

15. MIL-STD-462D, "Military Standard-Measurement of Electromagnetic Interference Characteristics," January, 1993.

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Westinghouse Non-Proprietary Class 3

16. IEC Standard 1226-1993,"Nuclear Power Plants-Instrumentation and control

systems important for safety-classification".

17. Westinghouse Electric Company, LLC, "Quality Management Systems," Revision

2.1.

18. WCAP 8587, "Methodology for Qualifying Westinghouse WRD Supplied NSSS

Safety Related Electrical Equipment," Revision 6-A, March 1983.

19. IEEE Standard 627-1980, "IEEE Standard for Design Qualification of Safety

Systems Equipment Used in Nuclear Power Generating Stations," Institute of

Electrical and Electronics Engineers, Inc., 1980.

20. IEEE Standard 603-1991, "IEEE Standard Criteria for Safety Systems for

Nuclear Power Generating Stations," Institute of Electrical and Electronics

Engineers, Inc., 1991.

21. IEEE Standard 7-4.3.2-1993, "IEEE Standard Criteria for Digital Computers in

Safety Systems of Nuclear Power Generating Stations," Institute of Electrical

and Electronics Engineers, Inc., 1993.

22. Report CSR240, "Electromagnetic Emissions Mapping of the Auxiliary Relay

Room at Kewaunee Nuclear Station," CHAR Services Inc., September, 1999.

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LIST OF ACRONYMS

p. Micro Q Ohms A Ampere AC Alternating Current oC Degrees Celsius CFR Code of Federal Regulations dB Decibel dBpA Decibels relative to one microampere DBA Design Basis Accident DBE Design Basis Event DC Direct Current EFT/B Electrical Fast Transient/Burst EPRI Electric Power Research Institute ESD ElectroStatic Discharge EMC ElectroMagnetic Compatibility EMI ElectroMagnetic Interference EQ Equipment Qualification EUT Equipment Under Test G Giga GND Ground Hz Hertz I&C Instrument and Control IEC International Electrotechnical Commission IEEE Institute of Electrical and Electronics Engineers I/O Input/Output lbs. Pounds LLC Limited Liability Company k kilo kV Kilovolt m meter mA milliampere MHz Megahertz MIL Military msec millisecond mV millivolt M Mega. N/A Not Applicable NIST National Institute of Standards and Technology NPP Nuclear Power Plant NRC Nuclear Regulatory Commission OBE Operating Basis Earthquake

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Westinghouse Non-Proprietary Class 3

LIST OF.ACRONYMS (continued)

Pennsylvania Post Office Revision Root Mean Square Require Response Spectrum Safe Shutdown Earthquake Standard Surge Withstand Capability United States Volt Volts per Meter Volts Alternating Current Westinghouse Commercial Atomic Power

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PA P.O. Rev. RMS RRS SSE STD SWC U.S. V V/m VAC WCAP

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Westinghouse Non-Proprietary Class 3

1.0 INTRODUCTION

1.1 Purpose

The purpose of this document is to define the qualification strategy and requirements

for qualifying E3 safety related Class 1 E equipment for Kewaunee Nuclear Power

Plant.

1.2 Qualification Objective

The objective of safety related Class 1 E equipment qualification is to demonstrate that

the equipment is capable of performing the designated safety related functions during

and following a design basis accident and common mode stressors. A design basis

accident is a subset of a design basis event (DBE). Design basis events are the

postulated events used in the design to establish the performance requirements of the

structures, systems, and components. DBA or post-DBA conditions are those plant

conditions resulting from postulated equipment and piping failures during which safety

related equipment must operate without degrading the safety related function in a harsh

environment.

A mild environment is an environment expected as a result of normal and abnormal

service conditions where seismic is the only Design Basis Accident (DBA). In a mild

environment plant location, the environmental conditions are not expected to change as

a result of the DBA.

1.3 E3 Equipment Qualification

The E3 equipment will be qualified for use in a mild environment. The equipment

qualification insures that the E3 equipment can perform the safety functions under the

specified electromagnetic compatibility environment, normal and abnormal environment

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and design basis event conditions.

The electromagnetic compatibility, normal and abnormal environmental, and seismic

qualification will be performed to satisfy the various U.S. NRC Regulatory Guides and

technical requirements of various EN, IEEE, IEC and MIL or equivalent standards.

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2.0 CODES AND STANDARDS

2.1 Regulatory Basis

US NRC regulations are stated in 10 CFR 50.49, "Environmental Qualification of

Electrical Equipment important to Safety for Nuclear Power Plants."

2.2 Environmental and Seismic Qualification

US NRC guidance is provided in Regulatory Guide 1.89 (Reference 1) and Regulatory

Guide 1.100 (Reference 2), which endorses IEEE Standard 323-1983 (Reference 3)

and IEEE Standard 344-1987 (Reference 4), for environmental and seismic

qualification of Class 1 E electrical equipment.

2.3 Electromagnetic Compatibility (EMC) Qualification

US NRC guidance is provided in Draft Regulatory Guide DG-1 029 (Reference 5) for

electromagnetic compatibility qualification. In addition, the NRC staff has stated in

Draft DG-1 029 that the Electric Power Research Institute (EPRI) topical report TR

102323, Revision 1 (Reference 6) is acceptable, and endorses the emissions and

susceptibility test criteria and test methods. Electromagnetic-Compatibility (EMC)

qualification will comply with the technical requirements of the following IEC and MIL

standards.

Emissions:

a) MIL-STD-461D, CE101 and CE102 Conducted Emissions

b) MIL-STD-461 D, RE101 Radiated Magnetic Field Emissions

c) MIL-STD-461D, RE102 Radiated Electric Field Emissions

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Susceptibility:

d) MIL-STD-461 D, CS1 01, Conducted Susceptibility

e) IEC 61000-4-2, ElectroStatic Discharge (ESD) Immunity

f) IEC 61000-4-3, Radiated ElectroMagnetic Interference (EMI) Immunity

g) IEC 61000-4-4, Electrical Fast Transient/Burst (EFT/B) Immunity

h) IEC 61000-4-5, Surge Immunity

i) IEC 61000-4-6, Conducted Immunity

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3.0 EQUIPMENT CLASSIFICATION

The classification of E3 equipment is safety Class 1 E/Category A equipment. The

equipment safety Class 1 E and safety Category A classifications are consistent with

IEEE Standard 323 (Reference 3) and IEC Standard 1226 (Reference 16). Table 3-1

contains the equipment safety classifications and associated environmental

classification, seismic category, and EMC qualification acceptance criteria. The

following sections contain specific definitions of seismic category, environmental

classification and EMC qualification acceptance criteria.

3.1 Seismic Category

The E3 equipment is classified as seismic Category 1 E (Class 1 E), consistent with the

following definitions:

Seismic and dynamic loading qualification demonstrates that the seismic

Category 1 E equipment is capable of performing the designated safety related

functions and maintain structural integrity under applicable plant loading

conditions, including the Safe Shutdown Earthquake (SSE) earthquake level.

Some permanent deformation of equipment structure is acceptable at SSE

levels, provided that the capability to perform the designated safety related

functions are not degraded. The SSE is defined as the earthquake which

produces the maximum vibratory ground motion.

The operating basis earthquake (OBE) is the earthquake that may be expected

to affect the location during the operating life of the plant. No degradation of the

designated safety related functions and deformation of equipment structure are

acceptable at OBE levels.

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3.2 Environmental Classification

The installation environment for E3 equipment is classified as mild environment. This

type of environment is typical in electrical rooms, outside containment.

3.3 EMC Classification

The E3 equipment shall be qualified for use in a nuclear power plant's electromagnetic

environment per EPRI TR-102323, Revision 1.

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Table 3-1

E3 Equipment Safety Classification

EMC Qualification Equipment Environmental Seismic EMuit

CategoryImmunity Classification Classification Category Acceptance

Criteria (2)

IEEE 323 & 344/ IEC 1292 Mild 1 Para. 6.3.2 Westinghouse (1)

Class 1 E/ Category A X X X

Safety Class-3 (SC-3)

Notes: 1. Westinghouse equipment safety classifications are defined in Quality Management

Systems. (Reference 17). 2. Electromagnetic Compatibility environment is detailed in Tables 5-2 and 5-3.

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4.0 EQUIPMENT DESCRIPTION

The E3 electrical equipment to be qualified consists of digital reactor protection equipment. This type of equipment is typically installed in either floor or wall mounted seismic cabinets.

The equipment configuration for testing shall consist of an E3 Safety System cabinet performing Process Protection System functions, and an E3 Safety System cabinet performing Reactor Trip and ESF System functions.

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5.0 QUALIFICATION REQUIREMENTS

5.1 Environmental Requirements

The environmental requirements are based on information provided in WCAP 8587

(Reference 18), IEEE Standard 323 (Reference 3), and Kewaunee Nuclear Power Plant

Equipment Qualification Plan specific environmental conditions. Environmental

requirements are listed in Table 5-1 and illustrated in Figure 5-1.

5.2 Seismic Requirements

The seismic qualification requirements specified are based on the Kewaunee Nuclear

Power Plant specific requirements. The horizontal and vertical required response spectra (RRS) for Operating Basis Earthquake (OBE) and Safe Shutdown Earthquake

(SSE) are shown in Figures 5-2 through 5-5.

5.3 EMC Requirements

The EMC qualification requirements are based on the Draft Regulatory Guide DG-1029

(Reference 5), EPRI-TR-102323-R1 (Reference 6), IEC and MIL standards. The EMC

test specifications, requirements, test levels and acceptance criteria are provided in

Table 5-2 for Emissions and Table 5-3 for Susceptibility.

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Table 5-1

Environmental Qualification Requirementsa,c

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a,c

Figure 5-1 Environmental Qualification Test Profile

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Table 5-2 EMC Qualification Requirements: Emissions

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ac

EMC Phenomena Emissions Test Emissions Test Frequency Acceptance Remarks Standard Range Criteria

I 4. t

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Table 5-3 EMC Qualification Requirements: Susceptibility

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EMC Phenomena Susceptibility Susceptibility Test Level and Remarks Test Standard Frequency Range

4- +

4 4. &

1 1- t

a,c

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OBE RRS -- E-WIN-S Direction -- 1% Damping Reactor, Auxiliary, Turbine Bldg. Basement and Battery Rooms and Screen House Envelope Spectra

10

FREQUENCY--HE

Figure 5-2 Operating Basis Earthquake Required Response Spectrum (Horizontal direction)

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10

Z'

0 P

-j LU

0.1

100

1

1

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OBE RRS -- Vertical Direction -- 1% DM PING Reactor, Auxiliary, Turbine Building Basement and Battery Rooms and Screen House

10

0 P

LU UJI

0.1

1 10

FREQUENCY--HZ

Figure 5-3 Operating Basis Earthquake Required Response Spectrum (Vertical direction)

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100

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SSERRS -- E-WIN-S Direction -- 1% Damping Reactor, Auxiliary, Turbine Bldg. Basement and Battery Rooms and Screen House Envelope Spectra

1 10

FREQUENCY--HZ

Figure 5-4 Safe Shutdown Earthquake Required Response Spectrum (Horizontal direction)

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2 0 L

-1

U.)

0.1

100

1609/30/99 - Rev 0

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Figure 5-5 Safe Shutdown Earthquake Required Response Spectrum (Vertical direction)

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SSE RRS -- Vertical Direction -- 1% DAMPING Reactor, Auxiliary, Turbine Building Basement and

10 __ - Battery Rooms and Screen House

0.1 1 10 100

FREQUENCY--HZ

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Westinghouse Non-Proprietary Class 3

6.0 QUALIFICATION METHODOLOGY

The Westinghouse approach to Class 1 E safety related equipment qualification, that

will be implemented for E3 equipment, is based upon the applicable industry codes,

industry standards, Kewaunee Nuclear Power Plant Equipment Qualification Plan and

WCAP 8587 (Reference 18), approved by USNRC.

The normal and abnormal environmental and seismic qualification of the safety related

Class 1 E Equipment will be performed by testing or a combination of testing and

analysis. The electromagnetic compatibility qualification will be demonstrated by type

testing. The intent of the electromagnetic compatibility qualification is to demonstrate

that the equipment will perform satisfactorily during externally generated

Electromagnetic Interference (EMI) and Radio Frequency Interference (RFI).

The electromagnetic compatibility type testing, environmental and seismic qualification

testing will be performed to satisfy the various U.S. NRC Regulatory Guides and

technical requirements of various IEEE, IEC and Military or equivalent standards. The

applicable codes and standards are identified in the following sections. The equipment

qualification process outlined in the following sections is in accordance with the

technical intent of IEEE Standard 627 (Reference 19), IEEE Standard 603 (Reference

20) and IEEE Standard 7-4.3.2 (Reference 21).

6.1 Environmental Qualification

The environmental qualification will be performed in accordance with the technical

requirements of WCAP 8587, and IEEE Standard 323-1983. Type testing, analysis or

a combination of analysis and testing may accomplish environmental qualification of

the equipment. These may be used individually or in any combination depending upon

the particular situation.

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For Class 1 E equipment full compliance of the requirements will be achieved by test.

In the development of the environmental qualification program the following principal

conditions will be used:

a. Normal operating environments are defined as those conditions existing during routine plant operations for which the equipment is designed to operate on a

continuous basis.

b. Abnormal operating environments are defined as those conditions for which the

safety related equipment is designed to operate for a period of time without

accelerating normal periodic tests, inspections, and maintenance schedules for

the equipment. The abnormal operating environmental conditions are the

anticipated maximum and minimum conditions based on loss of normal airconditioning or ventilation systems. These maximum and minimum conditions

reflect the equipment design limits.

c. For floor and wall-mounted equipment, the simulation of five OBE level seismic

tests before an SSE level seismic test is typically considered to include the

vibration aging effects on equipment. In addition, the equipment will be

subjected to sinusoidal vibration tests prior to seismic testing.

d. Dust resistance compliance will be demonstrated by design methods and smoke

stressor compliance [ a,c

6.1.1 Environmental Qualification Functional Monitoring

To demonstrate proper functional operability, the normal mode of operation will be monitored during and after the environmental testing.

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6.1.2 Environmental Qualification Performance Acceptance Criteria

Environmental qualification must demonstrate that equipment is capable of performing

the designated safety functions during and after environmental testing [

a,c

6.2 Seismic Qualification

The seismic qualification will be performed to satisfy the technical intent identified in

Kewaunee Nuclear Power Plant specific documents, WCAP 8587, IEEE Standard 344

1987 and RG 1.100. Type testing, or a combination of analysis and testing of the

equipment may accomplish seismic qualification. These may be used individually or in

any combination depending upon the particular situation.

6.2.1 Seismic Qualification Functional Monitoring

To demonstrate proper functional operability of Class 1 E equipment, the normal mode

of operation shall be monitored before, during and after the seismic simulation.

6.2.2 Seismic Qualification Performance Acceptance Criteria

Seismic qualification must demonstrate that Class 1 E equipment is capable of

performing its designated functions [ ac .1 The test response spectra shall

envelop the required response spectra. Some permanent deformation of supports and

structures is acceptable at the SSE earthquake level provided that the ability to perform

the designated functions is not impaired. Where generic seismic spectra are specified, an evaluation will be performed to ensure that the OBE and SSE spectra envelop the

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plant specific floor response spectra for the equipment installation location.

6.3 Electromagnetic Compatibility Qualification

The EMC qualification of the E3 equipment will be demonstrated by type testing. The

EMC qualification type test will be performed to satisfy the technical intent of US NRC

Draft Regulatory Guide DG-1029, EPRI TR-102323 Revision 1, IEC and MIL

standards. The equipment will be tested under typical point of installation conditions.

The electromagnetic and radio frequency interference are from sources external to the

equipment, through the connecting cabling by capacitive or inductive coupling from the

source, or through voltage/current surges between the grounding references of local

equipment and remotely connected equipment. Interference may also be generated by

electrostatic discharges from the operators to panels, enclosures or cabinets and by

radiated electromagnetic fields which may be generated by walkie-talkies, portable

phones, broadcasting and television stations, as well as radar stations. AC power

supplies may be susceptible to interference generated by lightning and various

switching transients.

6.3.1 EMC Qualification Functional Monitoring

To demonstrate proper functional operability, the normal mode of operation and

essential safety functions will be monitored before, during and after the EMC type

testing as required by the test acceptance criteria.

The EMC immunity acceptance criteria requires no degradation in ability to perform all

designated safety related functions during continuous and transient EMC events as

simulated by immunity tests. System output variations shall not exceed the operating

design accuracy or stability by more than a factor of 10. During such output variations,

the system shall be capable of performing all designated safety related functions and

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must not cause any unintended actuation of reactor trip or engineered safety features.

Output variations beyond design accuracy during immunity tests must return within

specifications at the completion of the test without operator intervention.

6.3.2 EMC Qualification Performance Acceptance Criteria

The EMC qualification immunity acceptance criteria for the E3 equipment is defined as

follows:

(1) [ a,c

.1(2) [

a,c .1

(3) [

a,c .1 .

EMC type testing must demonstrate that the E3 equipment is capable of performing its a,c

designated functions [ .] The procedure will identify the specific

acceptance criteria for each function monitored.

6.3.3 EMC Site Mapping

An electromagnetic site survey of the Kewaunee Nuclear Power Plant Relay Room has

been performed (Reference 22). The purpose of the survey was to determine if the

electromagnetic environment at the intended point of installation is similar to that

identified in EPRI TR-1 02323, Revision 1 (reference 6). The electromagnetic site

survey consisted of radiated and conducted emission measurements performed

according to MIL-STD-461D, CE101, CE102, RE101 and RE102 test methods.

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6.3.4 Equipment Operation under Existing EMI/RFI Fields

The E3 equipment will be type tested to demonstrate immunity to the EMI/RFI

interference identified in the Section 2 with the E3 equipment cabinet/enclosure doors

closed. During plant normal operation the doors may have to be opened to conduct

periodic testing of the equipment. [

a,c

] (Reference 22).

6.3.5 EMC Administrative Controls

The following precautions will be identified in the plant operating procedures to prevent

any adverse effects on the E3 equipment as a result of electromagnetic and radio

frequency interference.

a. Access to cabinets must be under strict administrative control.

b. Anti-static mats and wrist straps must be used when necessary as defined in the

equipment Operation and Maintenance manuals.

c. Plant personnel are to be trained in the effects of ESD on the equipment, potential

damage to the equipment and knowledge of the warning signs for the ESD

sensitive equipment.

d. Use of two-way communications must be administratively controlled in the vicinity

of the E3 equipment and an exclusion zone must be established, as appropriate.

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7.0 MAINTENANCE, SURVEILLANCE AND REPLACEMENT PROGRAM

A maintenance, surveillance and replacement program will be developed to identify

replacement intervals for all components with a design life less than 40 years. Periodic

testing and inspections shall be identified in the technical manual.

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8.0 DOCUMENTATION

Details of the qualification tests and evaluations methods including the results will be

documented in the equipment qualification reports. The qualification report will

document the adequacy of equipment to perform the required safety related function.

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NRC FORM 190 U.S. NUCLEAR REGULATORY COMMI (9-1998) NRCMD 3.12

PROPRIETARY INFORMATION

NOTICE

THE ATTACHED DOCUMENT CONTAINS OR IS CLAIMED TO CONTAIN PROPRIETARY INFORMATION AND SHOULD BE HANDLED AS NRC SENSITIVE UNCLASSIFIED INFORMATION. IT SHOULD NOT BE DISCUSSED OR MADE AVAILABLE TO ANY PERSON NOT REQUIRING SUCH INFORMATION IN THE CONDUCT OF OFFICIAL BUSINESS AND SHOULD BE STORED, TRANSFERRED, AND DISPOSED OF BY EACH RECIPIENT IN A MANNER WHICH WILL ASSURE THAT ITS CONTENTS ARE NOT MADE AVAILABLE TO UNAUTHORIZED PERSONS.

COPY NO.

DOCKET NO.

CONTROL NO.

REPORT NO.

REC'D W/LTR DTD.

PRRIETARY INFORMATION

~5IUN

Ll

SSION