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SUBJECT: COMMENTS ON NRC PROPOSED RULE ...

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standby mode. For example, the bus for ISSS train A would be<br />

energized from thc A bus of the class IE 4KV pouer distribution<br />

'. syst.em. Thc ISSS 480 V bus su~pl'ies power to the ISSS battery<br />

charger, maintaining the ISSS batteries fully charged, and also<br />

to thc condcneate drain pumps and floor d:ain sump pumps. The<br />

power supplies to the ISSS 400 V busscs are tripped when the ISS<br />

is actuated. Lighting loads and valvc solenoids are supplied<br />

from thc ISSS battery.<br />

Actuation of thc ISSS system is manual from either the main control<br />

room or at a Ioc~l station in the ISSS bunkers. Manual actuation<br />

has been selcctcd since it 1s intended that the ISSS only operate<br />

in response to a sabotagc or other gross emergency. It is believed<br />

that plant opcratorc can best make the judgement that such an<br />

emerqcncy docs or does not exist. Relyinq on the sensing of<br />

plant parameters such as voltage or flow to actuate the system<br />

automatically is bol icved to bc undesirable since conditions<br />

: othcr th~n snbotagc could cause actuation. The actuation logic<br />

i ,<br />

could bccome quite complex if it had to determine, from sevcral<br />

paramctcrs, that a sabotage evcnt was in progrcso. Elimination<br />

of plant paramctc!r sensing for aut.omatic actuation also reduccs<br />

the numhcr of intcrlacc!s hctwcen :b,c ISSS arid the rcmaindcr of<br />

the? plant an(i tb,cir .2:;:;aci~t1?d ::~bot;lqc vu1ncr;lCil icier,. Sufficient<br />

i time (on the ord~?r oS one hour) is avail;lt?!e to 3s:iez.s thc need<br />

, .<br />

. for thr LSSS and to actuatc it manually.

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