GO2-07-025, Response to Request for Additional Information Regarding the Proposed Amendment of Facility Operating License to Remove Operating Mode Restrictions for Performing Emergency Diesel Generator Surveillance Testing

Response to Request for Additional Information Regarding the Proposed Amendment of Facility Operating License to Remove Operating Mode Restrictions for Performing Emergency Diesel Generator Surveillance Testing

ML070440139
Person / Time
Site:	Columbia
Issue date:	02/05/2007
From:	Oxenford W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-07-025
Download: ML070440139 (13)

Text

ENERGY SNORTHWEST Peope - Vision. So-utions P.O. Box 968

• Richland, WA

• 99352-0968 February 5, 2007 G02-07-025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING

Reference:

Letter dated, May 22, 2006, G02-06-080, WS Oxenford (Energy Northwest) to NRC, "Proposed Amendment of Facility Operating License to Remove Operating Mode Restrictions for Performing Emergency Diesel Generator Surveillance Testing"

Dear Sir or Madam:

The NRC staff is reviewing Energy Northwest's application dated May 22, 2006 regarding removal of operating mode restrictions for performing emergency diesel generator surveillance testing. The NRC staff has determined that to complete the review, they require additional information. Attachment 1 to this letter contains a restatement of the requested information and Energy Northwest's responses.

If you have any questions or require additional information, please contact Mr. GV Cullen at (509) 377-6105.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, W$-Oienfopd ("i~j Drop PEO4)

Presicýe lechnical Services Attachments: 1. Response to R equest for Additional Information

2. List of Commitrnents cc: BS Malleft - NRC RIV RN Sherman - BPA/1 399 CF Lyon - NRC NRR WA Horin - Winston & Strawn NRC Senior Resident Inspector/988C

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 1 of 11 Response to Request for Additional Information NRC Question I Since performance of Surveillance Requirements (SRs) 3.8.1.11, 3.8.1.12 and 3.8.1.19 require de-energization of emergency buses, justify how performing these SRs during power operation would not cause any significant perturbation to the electrical distribution system. In addition, describe how the Loss Of Offsite Power (LOOP) and Emergency Core Cooling System (ECCS) initiation signals are generated without disturbing power operation.

Energy Northwest Response The Class 1E AC distribution system supplies electrical power to three divisional load groups, Divisions 1, 2, and 3, with each division powered by an independent Class 1E 4.16 kV ESF bus. The Division 1 and 2 4.16 kV ESF buses have two separate and independent offsite sources of power. The Division 3 4.16 kV ESF bus has one offsite source of power. Each 4.16 kV ESF bus has a dedicated onsite Diesel Generator (DG).

One of the three independent distribution subsystems (Division 3) is dedicated to supplying the HPCS system electrical loads and testing this subsystem whether online or shutdown affects the HPCS system only. Testing of the HPCS system, to meet SRs 3.8.1.11, 3.8.1.12, 3.8.1.16, and 3.8.1.19 as described in this license amendment request will be performed with the HPCS bus (E-SM-4) aligned to the 230 kV offsite power source via the startup transformer (E-TR-S). During HPCS testing, the Division 1 and Division 2 electrical buses will be powered from the main generator through the normal transformer (E-TR-N1). Since the Division 1 and Division 2 safety buses are powered from a different (electrically isolated) source, there will be no perturbation of these systems during testing of the HPCS system. When the Class 1E buses SM-7 and SM-8 are being fed from the main generator, the possibility of sustained undervoltage is not considered credible due to response characteristics of the voltage regulator and protection equipment for the unit.

The Loss of Offsite Power (LOOP) portion of the test involves de-energizing the safety bus (E-SM-4) and monitoring the DG-3 response in picking up the bus and re-powering HPCS system loads. The first portion of the Loss Of Coolant Accident (LOCA) test provides an ECCS initiation signal which results in a HPCS motor start with E-SM-4 aligned to E-TR-S. Starting the HPCS motor in this manner is bounded by the AC distribution system analysis that models all three divisional load groups (and associated balance of plant buses) aligned to E-TR-S when the HPCS motor starts. Therefore performance of the LOCA test with E-SM-4 aligned to E-TR-S is within the capacity of the onsite AC distribution system and offsite power circuit design and no system perturbation would result. The second portion of the LOCA test is a LOCA with LOOP.

During this portion of the test the HPCS motor will start while being powered by DG-3

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 2 of 11 which is its emergency standby power supply. Since all loads on E-SM-4 support the HPCS system and are isolated from other plant loads by virtue of being aligned to E-TR-S or DG-3, there is no perturbation to the other two divisional load groups and associated station electrical subsystems which would be powered from E-TR-N1.

Additionally, when the E-SM-4 bus is energized by DG-3, frequency and voltage are controlled by the DG-3 governor and voltage regulator.

The LOOP is simulated by opening the offsite power supply breaker causing an actual dead bus condition and isolation of the HPCS electrical subsystem from the other two station electrical subsystems. The ECCS signal is generated per system design with an ECCS test switch connected to a main control room panel (H13/P625). This test switch has been used many times during periodic surveillance testing with no impact on any electrical subsystem. Installation and removal of the test switch from the control room panel is procedurally controlled.

NRC Question 2 Section 4.4 of the submittal states that in comparison with Diesel Generator (DG)-I or DG-2, DG-3 has smaller loads associated with it (i.e., high pressure core system (HPCS)). There is less potential for testing of DG-3 to create a perturbation on the grid than there is with DG-1 or DG-2. Provide a list of loads that are normally powered by the DG-1, DG-2, and DG-3 buses.

Section 4.4 also states that DG-3 test results show that important bus voltage parameters stay within prescribed limits. However, the staff notes that these tests were conducted during shutdown. Justify that the bus voltage would remain within limits when performing these SRs at power operation.

Energy Northwest Response The principal ESF subsystem device loads requiring electric power to perform safety functions are described in Tables 8.3-1, 8.3-2, and 8.3-3 of the updated final safety analysis report for Columbia Generating Station and are included below. These tables indicate the redundant (Divisions 1 and 2) loads associated with safe shutdown systems and loads associated with the HPCS power system (Division 3).

During plant shutdown all station power is provided by the E-TR-S. While online all station power is supplied by the main generator through E-TR-N1. Testing of DG-3 while online will require transferring the HPCS bus (E-SM-4) to E-TR-S (offsite 230 KV source) while the other two safety buses for Division 1 (E-SM-7) and Division 2 (E-SM-

8) remain on E-TR-N1 (powered by the main generator).

During the Division 3 Loss of Offsite Power surveillance, the safety bus E-SM-4 is de-energized by opening the supply breaker from E-SM-2 to E-SM-4 which results in a start of DG-3 due to a loss of voltage sensed at E-SM-4. While performing this

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 3 of 11 evolution online with the Class 1E buses SM-7 and SM-8 being fed from the main generator, the possibility of sustained undervoltage is minimal due to response characteristics of the voltage regulator and protection equipment for the unit. The Division 3 LOCA testing will require starting the HPCS pump while aligned to E-TR-S.

Under normal operation with the HPCS system being supplied from the main generator through E-TR-N1, the system is designed and modeled to fast transfer to E-TR-S to provide power to the HPCS motor. The Division 3 LOCA with LOOP testing combines a LOCA signal with a LOOP signal resulting in DG-3 starting and providing power to its safety bus E-SM-4. The DG-3 was sized and designed to provide power to the loads associated with its safety bus E-SM-4.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 4 of 11 Table 8.3-1 Division 1 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus Shutdown With Loss of Offsite Power LOCA With Loss of Offsite Power No. Total hp/kW No. Req'd Time Time No. Req'd Time Time on Connected Part of to to Part of to to Item Description Bus to Bus Set P/O Starta Stop kW Set P/O Starte Stop kW

1) Motor operated valvesb Set 200.0 kW Set C sec (c) Set 0 sec (c)

2) Emergency lighting and power panelsd Set 98 kW Set C sec (e) 98 Set 0 sec (e) 98 Set 45.7 kW Set 03sec (e) 45.7 Set 0 sec (e) 45.7

3) Power panels (1E)

Set 146.2 kW Set 0 sec ej (ef) 146.2 Set 0 sece'f (ef) 146.2-

4) Diesel auxiliaries and HVAC 1 15/5.6 kW 1 0)sece (e) 5.6 1 0 sece (e) 5.6

5) Low pressure core spray water leg pump

6) Standby liquid control pump 1 40/28 kW 1 15/5.4 kW 0 secf (f) 5.4 0 secf (f) 5.4

7) Reactor core isolation cooling water leg pump 1 1

(

8) Fuel pool recirculation pump Set 55/37.2 kW Set 0 secf (e) 37.2 Set 0 secf (e) 37.2 Ad

9) Plant service water pump 1500/1176.7 kW 1 10 sec (e) 1176.7

10) Low-pressure core spray pump 1 1 1500/1117.0 kW 1 0 sec (e) 1117.0

11) Residual heat removal pump A 1 800/624.4 kW 1 10 mine (e) (624.4) 1 5 sec (e) 624.4 1

1750/1279.3 kW 1 (e) 1279.3 1 (g) (e) 1279.3

12) Standby service water pump (g)

13) Cooling tower makeup water pumpd 2 1600/1280.3 kW 1 (e,h) (e) (640.2)

14) Control rod drive pumpd 1 250/204 kW 1 (e) (e) (204)

15) Reactor closed cooling pumpd 1 200/161.3 kW 1 0 sec (e) 161.3

16) Load center transformer losses TR-7/71 and - 2 42.0 kW 2 0 sec Cont 42.0 2 0 sec Cont 42.0 7/73

17) 250-V battery charger 1 123.1 kW 1 0 sec (e) 123.1 1 0 sec (e) 123.1

18) 125-V battery charger 1 29.3 kW 1 0 sec (e) 29.3 1 0 sec (e) 29.3

19) Uninterruptible power supplyd E-IN-1 1 19.6 kW 1 0 sec (e) 19.6 1 0 sec (e) 19.6

20) Standby gas treatment fans and heater coils 2 50/47.6 kW 1 30 sec (e) 47.6 2 45.5 kW 2 20 sec (f) 45.5

21) Reactor protection system motor-generator 1 25/20.2 kW 0 sec (e) 20.2 1 (e) (e) 20.2 setd

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 5 of 11 Table 8.3-1 Division 1 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus (Continued)

Shutdown With Loss of Offsite Poweri LOCA With Loss of Offsite Power No. Total hp/kW No. Req'd Time Time No. Req'd Time Time on Connected Part of to to Part of to to Item Description bus to Bus Set Pi-' Start- Stop KVV Set i-'i Staru Stop KVV

22) Hydrogen recombiner (DEACTIVATED) 4z~t 1 Rl 1 1 OAN -- ---- -- DI(' cýc, tA0 mne (mý r, 1

23) Drywell cooling and fans Set 292.5/241.4 kW P/O Set 0 sec (e) 32.6 P/O Set 0 sec (e) 32.6

24) Control air compressor' 1 103/81.8 kW 1 0 sec (e) 81.8 1 0 sec (e) 81.8

25) Reactor building electrical equipment HVAC Set 338.5 kW Set 0 secf (e) 13.4 Set 0 secf (e) 20.9

26) Control building electrical equipment HVAC Set 253.7 kW Set 0 secef (e) 113.7 Set 0 secf (e) 112.7

27) Makeup water pump house electrical Set 80 kW Set (eh) (e) (80) equipment HVACd

28) Standby service water pump house electrical Set 38.4 kW Set 0 sec (e) 38.4 Set 0 sec (e) 38.4 equipment HVAC

29) Control room emergency chiller' Set 134.8 kW Set 0 sec (f) 134.8 Set 0 sec (f) 134.8

30) Security system power panelsd Set 71.1 kW Set 0 sec (e) 71.1 Set 0 sec (e) 71.1

31) TSC building electric equipment and heaters Set 92.2 kW Set 0 sec (e) 92.2 Set 0 sec (f) 82.2

32) Miscellaneous auxiliaries 9.8 kW --- 0 sec (e) 9.8 Set 0 sec (e) 9.8 Total automatically applied 3777.4 Total automatically applied 4321.7

( ) kW figures in parenthesis are for manually applied loads not added to total automatically applied loads.

a Time to start after bus voltage frequency have been established. Maximum time after signal to start generator for voltage to be established is 15 sec.

b Intermittent loads not included as long-term loading.

c Motors stop automatically when valve action is completed.

d Items are non-Class 1 E.

e Start and/or stop manually.

fStart and/or stop automatically with associated pump or diesel, pressure, temperature switch, or flow.

gSW start time (after bus energization) is the sum of SW start timer (20 sec) and SW return valve open time to actuate the limit switch permissive.

hLoad can be manually applied after the operator determines there is sufficient generator capacity.

'Operates automatically on chilled water demand.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 6 of 11 Table 8.3-2 Division 2 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus Shutdown With Loss of Offsite Power LOCA With Loss of Offsite Power No. Total hp/kW No. Req'd Time Time No. Req'd Time Time on Connected Part of to to Part of to to Item Description Bus to Bus Set P/O Starta Stop kW Set P/O Starta Stop kW

1) Motor operated valves' Set 200.0 kW Set 0 sec (c) Set 0 sec (c)

2) Emergency lighting and power panelsd Set 113.3 kW Set 0 sec (e) 113.3 Set 0 sec (e) 113.3

3) Power panels (1 E) Set 27.5 kW Set 0 sec (e) 27.5 Set 0 sec (e) 27.5 0 sec"2 (f) 179.6 Set 0 sece (ef) 179.6

4) Diesel auxiliaries and HVAC Set 179.6 kW Set 1 15/5.7 kW 1 0 sec (e) 5.7 1 0 sec (e) 5.7

5) Residual heat removal water leg pump

6) Standby liquid control pump 1 40/33 kW 2 50 kW 1 0 secf (f) 10.0 1 0 secf (f) 10.0

7) Standby liquid control tank heaters

8) Fuel pool cooling and cleanup system Set 37.2 kW P/O set 0 sec' (e) 37.2 P/O set 0 secf (e) 37.2 pump Bd 1 10 sec (e) 1176.7

9) Plant service water 1 1500/1176.7 kW 5 sec/0 2 1600/1287.6 kW 1 (e,f) (e) (643.8) 2 (e) 1287.6

10) Residual heat removal pumps B and C sec 1 1750/1260.7 kW 1 (e) 1260.7 1 (g) (e) 1260.7

11) Standby service water pump (g) pumpd 1 (e)

12) Cooling tower makeup water 2 1600/1280.3 kW (e,h) (640.2) 1

13) Control rod drive pumpd 1 250/204 kW (e) (e) (204) 1

14) Reactor closed cooling pumpd 2 400/322.6 kW 0 sec (e) 161.3 2 45/39.0 kW 2 0 sec Cont 38.0 2 0 sec Cont 39.0 and

-8/83dCenter Transformer Losses TR-8/81

15) Load

16) 125-V battery charger 1 27.3 kW 1 0 sec (e) 27.3 1 0 sec (e) 27.3 2 50/47.6 kW --- 1 30 sec (e) 47.6

17) Standby gas treatment fans and heater coils 2 45.5 kW 2 20 sec (f) 45.5 1 25/20.2 kW 1 0 sec (e) 20.2 1 (e) (e) 20.2

18) Reactor protection system motor-generator set

19) Hydrogen recombiner (DEACTIVATED) Set 25/52.8 kW --- P/O set 60 mine (e) 52.8 Set 347.5/41.3 kW P/O set 0 sec (e) 41.3 P/O set 0 sec (e) 41.3

20) Drywell cooling and fans

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 7 of 11 Table 8.3-2 Division 2 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus (Continued)

Shutdown With Loss of Offsite Power LOCA With Loss of Offsite Power No. Total hp/kW No. Req'd No. Req'd on Connected Part of Time to Time to Part of Time to Time Item Description Bus to Bus Set P/O Starta Stop kW Set PlO Starta to kW Stop

21) Control air compressor and dryersd 1 100/81.8 kW 1 0 sec (e) 81.8 1 0 sec (e) 81.8

22) Reactor building electrical equipment, HVAC Set 371 kW Set 0 sec' (e) 11.3 Set 0 secf (e) 17

23) Control building electrical equipment, HVAC Set 193 kW Set 0 secf (e) 99.0 Set 0 sece (e) 99.0

24) Makeup water pump house electrical Set 93.1 kW Set (e,h) (e) (93.1) ......... ...

equipment HVACd

25) Standby service water pump house Set 40.9 kW Set 0 sec (e) 40.9 Set 0 sec (e) 40.9

26) Control room emergency chiller' Set 134.8 kW Set 0 sec (f) 134.8 Set 0 sec (f) 134.8

27) Rectifier cabinetd E-IN-5B 1 59.6 kW 1 0 sec (e) 59.6 1 0 sec (e) 59.6

28) Security system power panelsd Set 150.6 kW Set 0 sec (e) 150.6 Set 0 sec (e) 150.6

29) Miscellaneous auxiliaries --- 10.5 kW --- 0 sec (e) 10.5 --- 0 sec (e) 10.5 Total automatically applied 3687.3 Total automatically applied 3789.5 S) kW Figures in parenthesis are for manual applied loads not added to the total automatically applied loads.

after bus voltage frequency have been established. Maximum time after signal to start generator for voltage to be established is 15 sec.

Time to startloads b Intermittent not included as long-term loading.

cMotors stop automatically when valve action is completed.

dtems are non-Class 1 E.

eStart and/or stop manually.

f Start and/or stop automatically with associated pump or diesel, pressure, temperature switch, or flow.

9 SW start time (after bus energization) is the sum of SW start timer (20 sec) and SW return valve open time to actuate the limit switch permissive.

h Load can be manually applied after the operator determines there is sufficient generator capacity.

'Operates automatically on chilled water demand.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 8 of 11 Table 8.3-3 Division 3 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus Shutdown With Loss of Offsite Power I LOCA With Loss of Offsite Power No. Total hp/kW No. Req'd Time Time No. Req'd Time Time on Connected Part of to to Part of to to Item Description Bus to Bus Set P/O Starta Stop kW Set P/O Starta Stop kW

1) High-pressure core spray pump (HPCS-P-1) 1 3000/2377.5 kW --- --- --- --- 1 0 sec (b) 2377.5

2) Motor operated valvesc Set 77/62 kW --- --- --- --- Set 0 sec (b) ---

3) High-pressure core spray water leg pump 1 15/12.8 kW 1 --- (b) 12.8 1 (b) (b) 12.8 (HPCS-P-3)

4) High-pressure core spray service water pump 1 60/49.6 kW 1 0 sec (b) 49.6 1 0 sec (b) 49.6 (HPCS-P-2)

5) Auxiliary panel (E-CP-DG/CP3) 1 3.5 kW 1 0 sec (d) 3.5 1 0 sec (d) 3.5

6) Diesel generator room exhaust fan (DEA-FN- 1 50/40.8 kW 1 (d) (d) 40.8 1 (d) (d) 40.8 31)

7) Supply fans (DMA-FN-31) 2 32/22.7 kW 1 (d) (d) 22.7 2 (d) (d) 22.7

8) Fan coil unit (RRA-FN-4) 1 10/8.4 kW --- --- --- --- 1 0 sec (d) 8.4

9) Instrument and control power (E-PP-4A) Pni 2.3 kW Pnl 0 sec (b) 2.3 Pnl 0 sec (b) 2.3

10) Lighting panel (E-ELP-4A)t Pnl 9.3 kW Pnl 0 sec (b) 9.3 Pnl 0 sec (b) 9.3

11) Miscellaneous auxiliary (DO-P-2, DLO-P-12, Set 4 kW Set 0 sec (b) 2.2 Set 0 sec (b) 4 POA-FN-2A)

12) Load center, transformer losses (E-TR-4/41) 1 7.0 kW 1 0 sec --- 5.4 1 0 sec --- 7.0

13) High-pressure core spray diesel room heater 1 35 kW 1 0 sec (d) 35.0 1 0 sec (d) 35.0e (DMA-EHC-32)

14) DMA supply fan (DMA-FN-32) 1 11.8 kW 1 0 sec (b) 11.8 1 0 sec (b) 11.8

15) Day tank room exhaust fan (DEA-FN-32) 1 0.5 kW 1 (b) (b) 0.5 1 (b) (b) 0.5

16) High-pressure core spray oil pump room 1 7.5 kW 1 0 sec (d) 7.5 1 0 sec (d) 7.5e heater (DRA-EUH-31)

Total 203.4 kW Total 2592.7 kW

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 9 of 11 Table 8.3-3 Division 3 Diesel Generator Loading Automatic Loading of Engineered Safety Systems Bus (Continued) a Time to start after bus voltage frequency have been established. Maximum time after signal to start generator for voltage to be established is 15 sec.

bStart and/or stop manually.

c Intermittent loads not included as long-term loading.

d Start and/or stop automatically with associated pump or diesel, pressure, temperature switch, or flow.

e Due to heat dissipation from the diesel, the room temperature exceeds 70°F (thermostat settings for DMA-EHC-32 and DRA-EUH-31 are 70°F and 500F, respectively) within a few minutes. Hence, DMA-EHC-32 and DRA-EUH-31 are switched off within a few minutes. Therefore, these heaters are short-term load. However, for a conservative approach, these heater loads are included in the diesel loading.

' Non-Class 1E.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 10 of 11 NRC Question 3 The staff notes that during the performance of SR 3.8.1.11, the HPCS pump is not started. Describe how this surveillance satisfies the requirement of GDC-18 which requires that the testing should be performed under conditions as close to design as practical. Also, provide justification for not starting the HPCS pump as required by this SR.

Energy Northwest Response The Technical Specification Bases for SR 3.8.1.11 found in NUREG-1434 states in part: "The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.

For instance, ECCS injection valves are not desired to be stroked open, systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified."

As such, it is not necessary to start the HPCS pump during performance of the procedure credited for meeting SR 3.8.1.11 (i.e., procedure TSP-DG3/LOP-B501) because it would be redundant to performance of procedure TSP-DG3/LOCA-B501 in which the HPCS pump is started. Test procedure TSP-DG3/LOCA-B501 is performed in part, to meet SRs 3.8.1.12, 3.8.1.16, and 3.8.1.19 and is described in section 4.5 of the referenced submittal. Procedures TSP-DG3/LOP-B501 and TSP-DG3/LOCA-B501 are performed sequentially within the required surveillance interval. In this way, the system is tested under conditions as close to design as practical and the full operation sequence that brings the systems into operation is tested as described NUREG-1434.

NRC Question 4 Section 4.5 of the submittal states that the control logic associated with DG-3 will be temporarily modified to prevent an actual injection into the reactor pressure vessel during the performance of SR 3.8.19.

Describe in detail how the control circuitry is modified and what precautions are taken to ensure that the HPCS system is reverted back to its original configuration.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Page 11 of 11 Energy Northwest Response The existing design of the control logic for the HPCS injection valve features a key-locked override switch which prevents the injection valve (HPCS-V-4) from automatically stroking in response to an injection signal. This feature will be used to prevent injection during on-line testing. The test configuration and restoration of the override switch to the normal standby position will also be controlled by the procedure.

. I . I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED AMENDMENT OF FACILITY OPERATING LICENSE TO REMOVE OPERATING MODE RESTRICTIONS FOR PERFORMING EMERGENCY DIESEL GENERATOR SURVEILLANCE TESTING Attachment 2 Page 1 of 1 List of Commitments

1. The design of the control logic for the HPCS injection valve features a key-locked override switch which prevents the valve from automatic stroking in response to an injection signal. This feature will be used to prevent injection during on-line testing.

The test configuration and restoration of the override switch to the normal standby position will also be controlled by the procedure.

2. Testing of the HPCS system, to meet SRs 3.8.1.11, 3.8.1.12, 3.8.1.16, and 3.8.1.19 as described in this license amendment request will be performed with the HPCS bus (E-SM-4) aligned to the 230 kV offsite power source via the startup transformer (E-TR-S).

3. Testing of the HPCS system, to meet SRs 3.8.1.11, 3.8.1.12, 3.8.1.16, and 3.8.1.19 as described in this license amendment request will be performed with the HPCS bus (E-SM-4) aligned to the 230 kV offsite power source via the startup transformer (E-TR-S) and the Division 1 and Division 2 electrical buses will be powered from the main generator through the normal transformer (E-TR-N1).