ML17345A629
| ML17345A629 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/06/1989 |
| From: | Edison G Office of Nuclear Reactor Regulation |
| To: | Conway W FLORIDA POWER & LIGHT CO. |
| References | |
| TAC-69023, TAC-69024, NUDOCS 8901130161 | |
| Download: ML17345A629 (26) | |
Text
e ap,s RE0y
~
i.
~Ci+
q Wp y
~
0 W**gk
'0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 January 6,
1989 Docket Nos.
50-250 and 50-251 Mr. W. F.
Conway Senior Vice President-Nuclear Nuclear Energy Department.
Florida Power and Light Company Post Office Box 14000 Juno Beach, Florida 33408-0420
Dear Mr. Conway:
SUBJECT:
TURKEY POINT UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION ON EMERGENCY POWER SYSTEM ENHANCEMENT PROJECT (TAC NOS.
69023 AND 69024)
The purpose of this letter is to request additional information regarding the Emergency Power System (EPS)
Enhancement Project so that we can complete our review in a timely manner.
In your submittal dated June 23, 1988, you provided the EPS Enhancement Report to the NRC staff.
Your subsequent letter dated December 14, 1988 detailed the FPL licensing approach for this project and made clear that NRC review of the June 23, 1988 submittal was desired.
In order to complete our review, we require the additional information described in Enclosure 1.
In a separate submittal dated October 19, 1988, you also requested NRC review of a portion of the test program, specifically the qualification testing of the new diesel generators.
We discussed our concerns in a telephone call with your staff (T. Grozan, M. Koby et al.) on November 22, 1988.
These verbal comments are formalized as questions in Enclosure 2.
It is requested that you provide your responses to the comments in Enclosures 1
and 2 within 30 days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.
85'Oii3016i 890i06
~
PDR ADOCK 05000250 P
PDC L)F0f
I
~
4 wd I,
Mr. M. F.
Conway January 6,
1989 J
Any questions co'ncerning the enclosed commentsshould be directed to the NRC Project Manager for Turkey Point, Gordon Edison'.
Sincerely,
\\
r
, 'RIGINAL SIGNED BY J
J Gordon E. Edison', Sr. Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/enclosures:
See next page DISTRIBUTION C~J NRC 3 Local PDRs PD22 Rdg
- SVarga, 14/E/4
- GLainas, 14/H/3 DMi 1 le r GEdison LOlshan, 13/D/1 OGC
- EJordan, 3302 NMBB BGrimes, 9/A/2 HBerkow FRosa JKnight AToalston Bwilson, RII ACRS (10)
LA:PD22 DMi 1 1 er 01/$ /89 PM:PD22 GEdison 01/
/89 88~J'1/6 /89
1
/
'I t
Mr. W. F.
Conway Florida Power and Light Company Turkey Point Plant CC:
Harold F. Reis, Esquire Newman and Holtzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036 Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 John T. Butler, Esquire
- Steel, Hector and Davis 4000 Southeast Financial Center
- Miami, F 1ori da 33131-2398 Mr. J.
Odom, Vice President Turkey Point Nuclear Plant Florida Power and Light Company P.O.
Box 029100 Miami, Florida 33102 County Manager of Metropolitan Dade County Miami, Florida 33130 Resident Inspector U.S. Nuclear Regulatory Commission Turkey Point Nuclear Generating Station Post Office Box 57-1185 Miami, Florida 33257-1185 Jacob Daniel Nash
, Office of Radiation Control Department of Health and Rehabi 1 itati ve Serv ices 1317 Winewood Blvd.
Ta1 1 ahassee, Florida 32399-0700 Intergovernmental Coordination and Review Office of Planning
& Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Ta 1 1 ahassee, Florida 32301 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street Atlanta, Georgia 30323 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nuclear Plant F 1ori da Power and Light Company P.0.
Box 029100 Miami, Florida 33102
ENCLOSURE 1
RE UEST FOR ADDITIONAL INFORMATION K
p The following applies to the new structures, systems and components (SSC) that are to be added for the proposed Emergency Power System Enhancement
- Project, to the interfaces of the SSC with existing plant, and to the interfaces with existing plant of those SSC that are to be relocated or reconnected.
l.
Identify the applicable
- Codes, Standards, Regulatory Guides,
- NUREGs, General Design Criteria, Generic Letters, and other documentation (hereafter "Standards" ) that are to be applied to the system enhance-ment.
For each Standard identified, indicate to which part or parts of the system enhancement that the Standard will apply.
2.
Identify and provide justification or the reasons for deviations that are known at this time from these Standards.
As work progresses, periodically update any further deviations from the Standards and the reasons for such deviations.
Also, identify any additional Standards that become applicable as work progresses.
3.
Make a positive statement that all electrical systems and equipment associated with the System Enhancement and important to safety are classified as lE.
4.
Hake a positive statement that the Class 1E electrical equipment and systems associated with the System Enhancement are qualified consistent with Regulatory Guide 1.89.
- If there are exceptions, specifically note the exceptions and provide the reasons.
5.
Make a positive statement that SSC important to safety meet the require-ments of GDC 2, 4 and 5.
~
~
E
6.
It is understood that 125VDC Bus 3A is to be connected to 125YDC Bus 4B (and Bus 3B to 4A) for battery testing.
What limits are placed on the conditions under which or the length of time that the buses are to be connected?
Describe the operation of the 4160 volt ties between buses 4B and 4C, 4A, and 4C, 3B and 3C, 3A and 3C, 3A and 4A (Aux. Transformer connection),
and 4A and 3A (Aux. Transformer connection).
What interlocks, keylocks, or administrative procedures insure electrical separation between unit divisions (A and B), between units (3 and 4), and between safety and non-safety buses.
8.
After the system enhancement, what major systems/equipment important to safety will be shared by the two units?
What are the alternative power supply sources (buses) for these systems/equipment?
9.
For the "Loss of Normal Power Supply Followed by Actuation of SIS" scenario, it is stated that those loads that have already been connected to the 4. 16kV bus by the sequencer action, in response to the LOOP, will remain connected if they are required in response to an SIS.
Are those loads not required by the SIS stripped from the buses?
If so, how is this accomplished?
If not, what prevents a possible overload on the diesel generators?
10.
For the "Actuation of SIS With Normal Power Supply Available" scenario, are the non-safety related loads stripped from the safety related buses'?
11.
We understand that the enhancement project will involve the following locations:
2.
3.
New diesel generator building Existing diesel generator building Unit 4 auxiliary building, hot machine shop
>>3<<
4.
Unit 4 auxiliary building, mezzanine floor 5.
Control room Identify any other general areas that will be impacted by the enhancement project due to equipment installation, relocation or other changes, in-cluding cable routing.
Identify those safety related circuits (power, control, indication, alarm, etc.) that will pass between or through these general areas.
Identify these circuits as to function, end points and intermediate points.
Identify those circuits and areas for which divisional separation or isolation consistent with applicable Standards is required, and indicate how such separation or isolation will be accomplished.
12.
Consistent with Regulatory Guide 1.6, staff believes that an interlock should be provided on the breakers between 480 volt load center buses 4A and 4B, 4C and 4D, 3A and 3B, and 3C and 3D to prevent an operator error that would parallel these power sources.
Provide these interlocks or justify non-conformance.
13.
Include an analysis to illustrate that the 125 volt D.C. batteries are adequate for the worst single failure and accident loading condition.
14.
Describe the changes to be made in the control room (control, indication, alarms, etc.) for the enhancement project.
Discuss how these changes will be scheduled and controlled to limit possible installation induced operational transients.
15.
Review and evaluate the alarm and control circuitry for the diesel generators for any condition that renders a diesel generator unable to respond to an automatic emergency start signal.
These conditions include not only the trips that lock out the diesel generator start and require manual reset, but also control switch or mode switch positions that block
automatic start, loss of control voltage, insufficient starting air pres-sure or battery voltage, etc.
This review should consider all aspects of possible diesel generator operational conditions, for example test condi-tions and operation from local control stations.
One area of particular concern is the unreset condition following a manual stop at the local station which terminates a diesel generator test and prior to resetting the diesel generator controls for enabling subsequent automatic operation.
Provide the details of your review including the following information:
(a) all conditions that render the diesel generator incapable of responding to an automatic emergency start signal for each operating mode as discussed above; (b) the wording on the annunciator window in the control room that is alarmed for each of the conditions identified in (a);
(c) any other alarm signals not included in (a) above that also cause the, same annunciator to alarm; (d) any condition that renders the diesel generator incapable of responding to an automatic emergency start signal which is not alarmed in the control room; and (e) any proposed modifications resulting from this evaluation.
16.
Concerning the Class 1E Direct Current Power System, address the following:
As a result of recent reviews on the adequacy of safety-related direct current power systems of operating plants the following recommendations applicable to those plants undergoing operating license and construction permit reviews have been proposed.
In this regard, state if your design conforms to these recommenda-tions and explicitly identify any exception.
a.
The position of circuit breakers or fused disconnect switches associated with the battery charger, battery and direct current bus supply should be monitored to conform to the recommendations of Regulatory Guide 1.47, "Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems,"
(May 1973).
b.
The technical specifications should include periodic testing of battery chargers to verify that the current limiting characteristics have not been compromised or lost.
c.
The technical specifications should require that cell-to-cell and terminal connection resistance measurements be made as recommended in IEEE Standard 450-1972, "Recom-mended Practice for Maintenance,
- Testing, and Replacement, of Large Stationary Type Power Plant and Substation Lead Storage Batteries."
d.
The direct current power system design should include the following monitors and alarms (1)
An ammeter (directional and dual range) in-the battery output to monitor the battery input current while the battery is on floating and equalizing charge and to monitor the battery output current when it is supplying power.
(2)
An annunciator to alarm whenever the charger goes into a current limiting condition.
(3)
A temperature indicator to measure the battery room ambient temperature.
17.
State if the battery c'er has sufficient capacity to meet the requirements of position c.l.b of Regulatory Guide 1.32.
- Also, state if the stability of the battery charger output is load dependent and if so describe.
18.
Provide a description of the capability of the emergency power system battery chargers to properly function and remain stable upon the dis-connection of the battery.
Include in the description any foreseen modes of operation that would require battery disconnection such as when applying an equalizing char ge.
19.
Provide the details of your design of the DC power system that assures equipment will be protected from damaging overvoltages from the battery chargers that may occur due to normal equalize charging, faulty regulation or operator error.
20.
For the diesel engine fuel oil storage and transfer system, discuss the testing necessary to maintain and assure a highly reliable in-strumentation, control, sensor, and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors which alert the operator when these parameters exceed the ranges recom-mended by the engine manufacturer and describe what operator actions are required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss the system inter locks provided.
21.
Describe your design provisions made to protect the fuel oil storage tank fill and vent lines from damage by tornado missiles.
22.
Discuss the means for detecting or preventing growth of algae in the diesel fuel storage tank.
If it were detected, describe the methods to be provided for cleaning the affected storage tank.
23.
For the diesel fuel oil system, include a more explicit description of proposed protection of underground piping.
Where corrosion pro-tective coatings are being considered (piping and tanks) include the industry standards which will be used in their application.
Also discuss what provisions will be made in the design of the fuel oil storage and transfer system in the use of a impressed current type cathodic protection system, in addition to waterproof protective
- coatings, to minimize corrosion of buried piping or equipment.
If cathodic protection is not being considered, provide your justification.
24.
Discuss what precautions have been taken in the design of the fuel oil system in locating the fuel oil day tank and connecting fuel oil piping in the diesel generator room with regard to possible exposure to ignition sources such as open flames and hot surfaces.
25.
Identify all high and moderate energy lines and systems that will be installed in the diesel generator room.
Discuss the measures that will be taken in the design of the diesel generator facility to protect the safety related
- systems, piping and components from the effects of high and moderate energy line failure to assure availability of the diesel generators when needed.
26.
The discussion of your diesel engine fuel oil storage and transfer system (EDEFSS) does not specifically reference ANSI Standard N195 "Fuel Oil Systems for Standby Diesel Generators."
Indicate if you intend to comply with this standard in your design of the EDEFSS; otherwise provide justification for non-compliance.
27.
Assume an unlikely event has occurred requiring operation of a diesel generator for a prolonged period that would require replenishment of fuel oil without interrupting operation of the diesel generator.
What provision will be made in the design of the fuel oil storage fill system to minimize the creation of turbulence of the sediment in the bottom of the storage tank.
Stirring of this sediment during addition of new fuel has the potential of causing the overall quality of the fuel to become unacceptable and could potentially lead to the degradation or failure of the diesel generator.
28.
Discuss the precautionary measures that will be taken to assure the quality and reliability of the fuel oil supply for emergency diesel generator operation.
Include the type of fuel oil, impurity and quality limitations as well as diesel index number or its equivalent, cloud point, entrained moisture, sulfur, particulates and other deliterious insoluble substances; procedure for testing newly delivered fuel, per-iodic sampling and testing of on-site fuel oil (including interval between tests),
interval of time between periodic removal of condensate from fuel tanks and periodic system inspection.
In your discussion in-clude reference to industry (or other) standard which will be followed to assure a reliable fuel oil supply to the emergency generators.
29.
Discuss the design considerations that will/have determine(d) the phy-sical location of the diesel engine fuel oil day tank(s) at your facility.
Assure that the proposed/selected physical location of the fuel oil day tank(s) meet(s) the requirements of the diesel engine manufactures.
30.
Will the diesel generator fuel oil storage tank be provided with an individual fill and vent line.
Indicate where these lines are located (indoor or outdoor) and the height these lines are terminated above finished ground grade.
If these lines are located outdoors, discuss the
- Tl'
provisions made in your design to prevent entrance of water into the storage tank during adverse environmental conditions.
31.
We require -the vent line from each diesel day tank be designed to seismic Category 1, Class C requirements.
Also the portion of the vent line and flame arrestor exposed above the diesel generator building roof should be protected from damage by tornado missiles.
Your design should meet these requirements.
32.
Provide a tabulation showing the individual and total heat removal rates for each major component and subsystem of the diesel generator cooling water system.
Discuss the design margin (excess heat removal capability) included in the design of major components and subsystems.
33.
Provide the results of a failure mode and effects analysis to show that failure of a piping connection between subsystems (engine water
- jacket, lube oil cooler, governor lube oil cooler, and engine air inter-cooler) does not cause total degradation of the diesel genera-tor cooling water system.
34.
Indicate the measures to preclude long-term corrosion and organic fouling in the diesel engine cooling water system that would degrade system cool-ing performance, and the compatability of any corrosion inhibitors or antifreeze compounds used with the materials of the system.
Indicate if the water chemistry is in conformance with the engine manufacturer's recom-mendations.
35.
Provide details. of your proposed diesel engine cooling water system chemical treatment, and discuss how your proposed treatment complies with the engine manufacturer's recommendations.
36.
For the diesel engine cooling water system discuss the testing necessary to maintain and assure a highly reliable instrumentation,
- control, sensor, and alarm system.
Identify the temperature,
- pressure, level, and flow (where applicable) sensors which alert the operator when these para-meters exceed the ranges recommended by the engine manufacturer and des-cribe what operator actions are required during alarm conditions to pre-vent harmful effects to the diesel engine.
Discuss the systems interlocks provided.
37.
Describe the provisions made in the design of the diesel engine cooling water system to assure that all components and piping are filled with water.
38.
The diesel generators are required to start automatically on loss of all offsite power and in the event of a LOCA.
The diesel generator sets should be capable of operation at less than full load for extended periods without degradation of performance or reliability.
Should a
LOCA occur with availability of offsite power, discuss the design provisions and other parameters that have been considered in the selection of the diesel generators to enable them to run unloaded (on standby) for extended periods without degradation of engine per-formance or reliability. Explicitly define the capability of your design with regard to this requirement.
39.
You state in section 5.2.7 of the June 23, 1988 submittal that each diesel engine cooling water system is provided with an expansion tank to provide for system expansion and water makeup.
The expansion tank should provide for minor system leaks at pump shafts seals, valve stems and other components, and to maintain required NPSH on the system circulating pump.
Provide the size of the expansion tank and location.
Demonstrate by analysis that the expansion tank size will be adequate to maintain required pump NPSH and make up water for seven days contin-Uous operation of the diesel engine at full rated load without makeup, or provide a seismic Category I, safety class 3 make up water supply to the expansion tank.
40.
Provide the source of power for the standby immersion heater in the diesel engine cooling water systems.
41.
What is the source of power for the electric motor driven (AC and DC) external lube oil pumps.
42.
Provide a discussion of the measures that have been taken in the design of the standby diesel generator air starting system to preclude the fouling of the air start valve or filter with moisture and contaminants such as oil carryover and rust.
43.
For the diesel engine air starting system, describe the testing necessary to maintain a highly reliable instrumentation, control, sensor and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe any operator actions required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss system interlocks provided.
44.
Expand your description of the diesel engine starting system.
Describe the diesel engine starting sequence including the number of air start valves used and whether one or both air motors are used.
45.
A study by the University of Dayton has. shown that accumulation of water in the starting air system has been one of the most frequent causes of diesel engine failure to start on demand.
Condensation of entrained moisture in compressed air lines leading to control and starting air valves, air start motors, and condensation of moisture on the working surfaces of these components has caused rust, scale and water itself to build up and score and jam the internal working parts of these vital components thereby preventing starting of the diesel generators.
In the event of loss of offsite power the diesel generators must function since they are vital to the safe shutdown of the reactor(s).
Failure of the diesel engines to start from the effects of moisture condensation in air starting systems and from other causes have lowered their operational reliability substantially.
In an effort toward improving diesel engine starting reliability we require that compressed air starting system designs include air dryers for the removal of entrained moisture.
The two air dryers most commonly used are the dessicant and refrigerant types.
Of these two
- types, the refrigerant type is the one most suited for this application and therefore is preferred.
Starting air should be dried to a dew point of not more than 50'F when installed in a normally controlled 70'F environ-ment, otherwise the starting air dew point should be controlled to at least 10'F less than the lowest expected ambient temperature.
Describe the design of the diesel engine air starting system with respect to this concern.
46.
Provide the source of power for the motor driven air starting system compressor and the motor characteristics, i.e., motor hp, operating voltage.
47.
For the diesel engine lubrication system, provide the following information:
- 1) discuss the measures that will be taken to maintain the required quality of the oil, including the inspection and replace-ment when oil quality is degraded;
- 2) describe the protective features t
(such as blowout panels) provided to prevent an unacceptable crankcase explosion and to mitigate the consequences of such an event; and
- 3) describe the capability for detection and control of system leakage.
48.
For the diesel engine lubrication oil system, describe the testing necessary to maintain a highly reliable instrumentation,
- control, sensor, and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe any operator action required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss systems interlocks provided.
49.
Describe the instrumentation,
- controls, sensors and alarms provided in the design of the diesel engine combustion air intake and exhaust system which alert the operator when parameters exceed ranges recommended by the engine manufacturer and describe any operator action required during alarm conditions to prevent harmful effects to the diesel engine.
Dis-cuss systems interlocks provided.
50.
Show by analysis that a potential fire in the diesel generator building together with a single failure of the fire protection system will not degrade the quality of the diesel combustion air so that the remaining diesel will be able to provide full rated power.
51.
Experience at some operating plants has shown that diesel engines have failed to start due to accumulation of dust and other deliterious material on electrical equipment associated with starting of the diesel generators (e.g., auxiliary relay contacts, control switches - etc.).
Describe the provisions that have been made in your diesel generator building design, electrical starting system, and combustion air and ventilation air intake design(s) to preclude this condition to assure availability of the diesel generator on demand.
Also describe under normal plant operation what procedure(s) will be used to minimize accumulation of dust in the diesel generator room; specifically address concrete dust control.
ENCLOSURE 2
RE UEST FOR ADDITIONAL INFORMATION TU N
By letter dated October 19, 1988, the licensee for the Turkey Point Nuclear Plant, Units 3 and 4, submitted information regarding their proposed Diesel Generators to be added as a part of their planned Emergency Power System Enhancement Project.
In lieu of a 300 Start and Load Acceptance Test as speci-fied in IEEE 387-1984, the licensee proposes to accept a 30 Start and Load Acceptance Test as recommended by the EDG supplier Morrison-Knudsen
- Company, Power Systems Division.
The supplier's position is that previous qualification testing on similar EDGs is applicable to the proposed Turkey Point EDG's.
The proposed Turkey Point EDG's are EMD Model 20-645F4B which replaces EMD Model 20-645E4.
The F48 differs in several minor respects from the E4, however staff's main concern is that the F4B has a higher compression rate and a higher brake mean effective pressure (BMEP).
Also, the proposed Turkey Point EDGs are 20
- cylinder, 900 rpm, with a single prime mover.
The EDGs that have been qualified by the 300 start and load test had dual prime movers (tandem arrangement) and were 20 cylinder, 750 rpm or 16 cylinder, 900 rpm.
The licensee states that several nuclear plants have 20 cylinder, 900 rpm, single prime movers of the E4 type.
Presumably this particular configuration was not qualified by the 300 start and load test.
INFORMATION NEEDED:
The licensee has presented substantial information to illustrate that the 900 rpm starting requirements are not substantially different from the 750 rpm requirements, and also that the starting requirements for the single prime mover are not substantially different from the individual prime movers of the tandem arrangement.
However, sufficient information has not been presented to show that the forces exerted at a single end of a shaft does not result in more critical stresses than equal forces at both ends of a shaft.
Also, the informa-tion presented to substantiate that the previous qualification tests are applicable to the higher compression ratio and higher brake mean effective pressure of the F4B model is not sufficient.
In particular, the licensee has stated that the total stresses in the crankshaft have been calculated and are within the stress limits specified by the Diesel Equipment Manufacturers Association.
No informa-tion has been presented to illustrate how the stress margins of the 20 cylinder, single prime mover, F4B model compare to the 20 cylinder, E4 model that has undergone the 300 start and run tests.
This type of information is needed.
With the increase in BMEP and BHP of the F4B series, staff is concerned that the EDG may be approaching a situation comparable to that resulting in the crankshaft failure at Shoreham on the TDI EDG.
What tests or other measures are proposed to assure that the F4B series can withstand the additional forces without experiencing fatigue failures over its life?
More information is desired as to the similarities and dissimilarities between the proposed Turkey Point EDGs and the "F" engines used for railroad service in order to determine the relevancy of the railroad experience.
Also, the following should be analyzed and discussed:
1.
Comparative properties of the 4140 Blade Con Rod material of the F4B versus the 1050 material of the E4.
2.
Comparative properties of the 1080 Camshaft material of the F48 versus the 5046 material of the E4.
3.
Comparison of the FA Turbocharger of the F4B versus the E Turbo-charger of-the E4.
4.
Discussion of how the F4B obtains a higher compression ratio than the E4 considering that the piston to head clearance or the stroke has not changed.
5.
Significance of the I-l/4 Top Piston Ring Location of the E4 versus the 0.75" Fire Ring for the F4B.
6.
Justification for the fact that the standard EMO components are not built in accordance with ASME Section III Class 3.
3