ML18031A318

Forwards Request for Addl Info for Completion of OL Application.Includes Question Originated by ORNL

ML18031A318
Person / Time
Site:	Susquehanna
Issue date:	11/23/1979
From:	Parr O Office of Nuclear Reactor Regulation
To:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
References
NUDOCS 7912050520
Download: ML18031A318 (51)

Text

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Docket Nos.:

60-387 388 Hr. Norman M. Curtis Vice President Engineering and Construction Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

Dear Hr. Curtis:

DISTRIBUTION:

NRC PDR bcc:

Local PDR NS IC Docket Files LMR 83 Fi1 e ACRS (16)

DVassallo DRoss FWilliams OParr SHiner HRushbrook (w/extra copies)

RHattson SHanauer JKnight RTedesco RDeYoung VHoore HErnst

'Denise ELD IE (3)

SUBJECT:

SUS(UEHANNA STEM ELECTRIC STATION, UNIT aiOS.

1 AND 2-RE(UEST FOR ADDITIOINAL INFORHATION As a result of our review of your application for operating licenses for the Susquehanna Steam Electric Plant, we find that we need additional information in the area of Power Systems.

The specific information required is listed in the Enclosure.

Some of this review has been performed by the Oak Ridge t'lational Laboratory (ORNL).

guestions originated by ORNL are identified by an X10 to the question number.

Please contact us if you desire any discussion or clarification of the information requested.

Sincerely, Pgpaan)

Ct 4Q Q'jj Oti>g P~p Olan D. Parr, Chief Light Mater Reactors, Branch No.

3 Division of Project Hanagement

Enclosure:

As Stated cc:

See Next Page 7g/go5 o

OtatatCSW Sl ItItAla C W IDAT'C+

QPPlg!MR 43 SHi ne Pmec 11/ ~p /79 DPlt Ilf4g3 ODPa t

11/ >S /79

~ PORTE 510 (5476) i~ 0240

• M a oovc1aaaaEIIT

~ttlaahta4 otaat44a It'll la ~

3 ~ a

l

Mr. Norman 'i. Curtis cc:

Mr. Earle M. i"ead Project Engineering Manager Pennsylvania Fo~~~

& Light Company 2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Jay Silberg, Esq.

Shaw, Pittman, Potts Trowbridge 1800 M Street, N.

M.

l,'ashington, D. C.

20036 Mr. 4'i lliam E. Harberich, t'uclear Licensiru Group Supervisor Pennsylvania Paver

& Light Company 2 North Ninth Street Al 1 ento',

Pennsy'i vania 18101 Edward M. Nagel, Esquire General Counsel and Secretary Pennsylvania Power

& Light Company 2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Bryan Snapp, Esa.

Pennsylvania Pov. r & Light Company 901 Hamilton Street Al 1 entown, Pennsyl vania 18101 Robert M. Gallo Resident Inspector P. 0.

Box 52 Shickshinny, Pennsylvania 18655 Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.

500 South River Street I!ilkes-Barre, PA 18702 John L. Anderson Oak Ridge National Laboratory Un on Carbide ".nrrcrati~

Bica..3500, P. L. Bux 'X Oak Ridae, Ter lessee 37830

!i;. Rooe't J.

Shovl;n Project

.".anager Penns"'ania Power and Lip'r,-'. Co.

2 "or~th Ninth Street Allentor, Pennsyl vanIa 1810>

Matias F. Travieso-Diaz, Esq.

Shaw, Pi-.;man, Potts Tl owbr: dae 1800 M S-rect, M.

h'ashincton, D. C.

20036 Dr. Judith H. Johnsrud Cc-Director Env ronmental Coalition on Nuclear Power 433 Orlando Avenue St a t e C = 1 1 ege, PA 16801 Mr. Thor...as M. Gerusky, Direct::;

Bureau of Radiation Protection Depart..ent of Environmental Resou! ces Commor::eal:h of Pennsyl vania P. 0.

Box 2063 Harrisburg, PA 17120

!is. Colleen Marsh Fox 5 ~ i-RD=4 t:.auntain

Top, PA 18707 M~s. Irene Lemanowicz Chairperson The Citizens Against Nuclear Dangers P. 0.

Box 377 RDgl

Ferwick, PA 18503

SECOND ROUND REQUESTS SUSQUEHANNA STEAN. ELECTRIC STATION V

DOCKET NO. 50-387 POMER SYSTEMS BRANCH

040. 64-X10 by 125" of four hour demand but seems to be actually only 100'~

of 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> demand by Table 8.3-8 and report your findings.

in the event of failure of preferred power, then the alternate power; please discuss the operational sequence

=or restoration of the Class EE power channels.

a) from standby power to alternate

power, b) from standby power ta preferred power.

040,65 X10 Branch TechnicaT Position ICSB (PSB) 2 Diesel Generator Reliability gualificgtion Testing (SRP Appendix 8A) requires a

prototype qualification program to dwenstrate the capability af new and/or unique designs for use in nuclear service.

Provide the results of the prototype qualification for the SSES units.

l-I Cooper Bessemer has made recent changes in its design of cylinder heads and induction systems.

State in light of these changes whether the SSKS diesel generators have

.hese new design features and if so whether they have been qualified in accordance with BTP ECSB (PSB) 2, ot offer an alternative on some other defined bass s.

040, 66 X10 In FSAR Section 7.4,1,2.2, i is stat d that both divisions of the SLCS are powered rom Division I, Yet in Table 3.12-1

.he SLCS k

is listed in

~i separate divisions, t and II..

Provide a discussion erich resolves these apparent. inconsistencies.

040. 6>Xl0 A "480v Swine< Bus" is lis.ed in Division I and another in Division II (Table 3,12-1) and describe" in Section 8.3.1.3.5 Although these swings are no be~

n redundant divisions they are between redundant sepal tion channels as

.hre channels out of four are requir d in your plant to suc'essfully me -'he on-si.

1 J

power r quirmen s of a LOCA in one uni and safe shu down o

.he other unit.

Th"is configuration r cu;:res incependenc and separa on

040. 62-X10 04Q. 63-X1Q 4

Tne RBCCN and, i

CCM are sequenc d on the ".

"=. buses af,er a

loss of oif-site power (LOOSP)

(Table 8.3-1).

'.n Sec ion 9.2.2 in the FSAR these are both listed as non-=SF loads but in Tables 8.3-1 and la the RBCCN is lis.ed as an

="SF load, sequenced aC 60 sec onto Unit 2 for sa e shutdown.

Explain the power supply rationale for these two sys ms, siate E

whether they both can be isolated from their power supplies by a derivative of an accident signal ir. or.e.

a meet isolation requirements in accordanc wi=h Rag.

Guide 1.75, and correct any inconsistences in the FSAR text.

Provide a faildre mode and effects analysis of the dc system of the plant.

Descr'ibe i<<e operation of th unit 1 dc system and the "uninterruptable ac power supply" of Unii 1 during the period that Unii 1 is operating a,nd Uni s s-.ill under construction.

During this phase of operation ther is, pparer, ly. some switching of loads (lighting ancL communication}

=rom a Unit 1 vital ac bus to a Unit 2 vital ac bus under some conditions (Sec. 9.5}.

Provide fur.her details of

".is aspect of your design.

The indicated load on the 125v dc system Table 8.3-o) is 106A or great r over a four hour period, whil b

ery charger is raied. at lQOA. Discuss the iime span and conci ions or actions thai wi11 be necessary to establish cha.r e ~'"ii;brium in the batteries.

ln addiiion, with regard to the dc syst=;s, oroviide note 5 =or Figure 8.3-6 and -,or the 24v dc sy~.an s.==wn in -'.h>s figur.

Review he ba ry capacl y wh.c.". s.,ou::,

by y"". "wn c. i

. 1 a,

3 w

between Class IE channels as w'eel as ESP divisions in each of the two units oj your plant, In order to,acil jtate our review of this aspect o~'our design, provide a common mode-ccamon cause failure analysis for the Russell Electric Company transfer switches that you use to transfer from one power supply channel to the other in each division.

Also describe the testing program for the entire isolation arrangement(motor-generator set) protective switchgear, and transfer'scheme o

the sNng bus arrangemen o sa s>y the iequirements of GDC 18, 040.'68 Xl0

. Yarious metallic vapor lamps have "delaved" reianition time characteristics, Postulate a condition such as a temporary loss of power, which would produce a delayed reignition condition.

Are there any SSFS plant areas jn which this postulated condition could interfere with plant operations7 If so, provide modified design to correc this situation.

040..69-X10 I'n Section 7,4 the statement "heat tracing of pump suction piping receiVes power from a bus that is connectable to the standby A-C power supply."

Identify this "connectable bus" and describe the loads (by name and rating), method of connection, and isolation (if non-IE),

040. 70-X10 J

Reg, Guide 1.70 recommends "in particular, the circuits that supply power for.he safety loads from the transmission network should be identi, fed and shown w meet GOC 17 and 18," and describe and provide layout drawings of the circuits that connect the onsite distribution system tc the pr ferred power supply including transmission lines, switchyard arrangement, right of way, etc."

GOC 18 states "electric power systems important to safety shall

~ l be designed to permit apprqprjz:e periodic inspection and testing of important areas and featur~s--."

Too state thai for pre-Unit 2 operation the preferred power sources for the SEES are the contour-Mountain and the Nescosville-Susquehanna tie lines.

Discuss these tre tie line systems and their associated switchyards wi.h regard to the'bove stated references and reaffirm that PCB protective P

relay testing, maintenance and calibration apply to these switchyards and can be performed during uni i operation.

In the event that the control room must be vacated, what means and, methods of comnunjcatjon are available from the remote shutdown panel of'nit 2 to the various out-buildings, such as diesel generator building, emergency service water pump hi"~se, make-up water pump hose, circulating water pump house, and radwaste

building, C~neral Design Criterion 18 requires the abtl sty to perjodtcally inspect'and test important safety features'of electric power

systems, State whether pe. todic tnspectton o, the penetration assemblies'is possible and whether the requiremeni of GDC-18 have been satisfied in this regard.

Figure 3,13-4, Es.her a program for testj'ng and tnspec jng the 120v ac control ctrcutt 6A fuses?'lso, provide the type (e.g, molded case}

and source'of actuatton power'for the 20A Cutler am Hammer Type (HB br ake.s, the HFi-~i. ~0A breakers at the 480v NCC, and ihe 22:-A supply bre.k r at each tnstru-oent ac panel,

Periodic testing of containment cti cuit protectton schemes ta a requiremen Provide the details. of your pertodtc testtng pra gralil.

040.73-XI 0 State whether 'the essenttal,1ig&ing system ts sequenced an.a the Class IE 480 buses or remains connecti.d'to.the bus through-out transfer'to..he dtesels tn the'event of a

LOOSP, Is the total'f essential 1 tghttng=l69kw as in Table 8,3-3, or 188kw-as tn 8,3-2 or 222k's tn 8,3-4, or 258kw tn 8,3-8?

'Ahy

.hese dtfferences?

040.74 -X10 On the topic of non-C'lass IE instrument ctrcutts; In paragraph 8.1.6.1.n-7 you state as an "analysis" that "non-Class IE

.tnstrument ctrcutts are considered low energy and the. probabiltty of'hese non-C'lass IE circutts providtng a mechanism of ail ure to the Class IE ctrcutt ts extremely low."

This is nat accentable as ar. aralysis o

your desigr,.

Provide the. necessary justification and supporting bases to demonstrate your conclusions.

040. 75-X10 In this same context review your use of Class IE devices as information sources for digital/analog information, as described in paragraph 9 of Section 3.12.3.4.1 of the FSAR (Page 3.12-9 of FSARJ and report your indings.

Verify that acceptable, isolation is provided in accordance with I==" Standard 279-1971 Sec tons 4.1 and 4.7.

Qn the same toaic as Item 040.82, above, but in i.s app'lic ticn to containment electrical pene.'ra ions, (your paragraoh B.i.o.l.n-13) you state

.hat cable pane ra ions into the 'suppress;on pool contain Class

= and non-Class

"= circuits.

These non-Class IE circuits include instr.mentaticn.

annunc;ation,

circuits, and computer circuiA.

Provide fur"her jus ification for the classif..cation of these as non-Class

.'=" cir=uits in containment penetrations, or describe a testing program to d ons.;ate the accep>hility of your-design approach.

040. 76-X10

- Your placement ai'lect.ical separation descriptions tn section 3.12.3.4 has made tt difficult to follow.he conttnuity of subject matter tn the FSAR.

In 3,12,3.4,1-fourth subsection, "Raceway sharing of Class'IE and non-Class IE Ctrcutts" i is stated that, "480v ac and 125/250V dc non>>Class IE load groups connec ed to Class IE buses are supplied through two circuit br eakers physically separated from each other and connected in series.

The cables from the Class IE bus up to the second breaker remain Nth and follow the same rules as the Class IE circuits oi'he respeci3ve separation divisions and are uniquely identified.

ine second breaker and i.s'.trcuits are not subject-',"

State whether'he second breaker of such an arrangement is Class IE, and list the circuits that use this double breaker isolation scheme,'Further',

provide the bases for acceptance for the use of this fault-actuated isolation

scheme, 040.77-X1Q Section 8,1.6.1.n, "Compliance with Regulatory Gutde 1.75 (1/75}."

1)

The statement at the end of the first paragraph of this section, referring to Sec ion 7.1, is not understandable, nor is the next paragraph coirect in its description of r dundancy'and independence',

It $ s s ill not clear. what,orms o, electric 1 isolatton ar used tn the design o,

SSES, Therefore, proVide a ltstlng of all the assoctated and non-IE ctrcutts tha" requtre tsolatton from the Class IE systems and the'method of Isolation (method 1, 2, 3, or 4 as described fn your paragraph 8,1.6,1.n-5}

used for each circutt.

2)

Your description of "isolatton systems" tn paragraph 8.1.6.l,n-5 defines"something thai ts not tn accordanc with Regulatory Gutde 1,75 for assuring independence of Class IE power"sources from an intermedta e non-Class IE bus (method 3 of the paragraph).

Therefore, stat whether there are indeed some non<<Class'E.loads tn the SSES design that are supplied'from a Class IE source through an tnter-mediate

bus, and describe the <solatfon system

.'or ihai bus, 040.78-xl 0 Paragraph 8.3.'1;3.14 of the FSAR indicates'that some electrical equipment associated with Class IE loads ident$ fted tn Chapt r 16.0" ts not testable during reac or operation, List or reference this equipmen Demons rate that all of.he above equipment so identified'$s tn confopnanc 'with Regulatory Guide 1,22 Section 0.4, O4O.79 -XlO Figure 8<3-5, "125v*dc and 250v'dc Systems" tndjcates that loads 10666, lD165, 10656, and 1D155 and 10615, 10635, 106Z5 and 10645, are "Non-g-Ltsted" Panels, Yet on drawings Ell, She ts 3 and 4,

". here are no es'hat all loads are "g-lis ed,"

On drawing :.ll Sheets 1

5. Z the. no e also says ha all equipment ts "g 1)s ed."

Provide further detatls to facilitate our unders-anding of this aspect of your design, Me do not have drawtng E26-Sh,3, and therefore, can not tell gust what loads are on the 1257'c distribution panels tn question.

Provtde this drawing,

'In the 250V dc case (Owg. E-ll., Sh.

3 '5 Sh. 4) the loads seem to be en.irely emergency'ube'ot1 pumps that are not Class IE by,unction.

State how such load centers are handled and whe.her an accident signal derivative trtps off the entire bus or tndtvtdual loads.

Me note that tn Table 3,'IOC-13 panels

10155, 10165, as well as 29155 and 20165 (for Unft 2) are lis ed as sefsmicaliy qualf

<ed while all the others are not.

Explatn the rationale for these Ckfferences.

Also, in Ftg. 8.3-5 the 250v'c Class IE battery suppltes a

1600A dtstrfbutfon panel through a 2000A,use, Stat the design bases for this aspect of your destgn, 040.80 -X10 Provtde a lfstfng of all switchgear that is not self-

'ctivated (both safety and non-safety) and spectftcally identi,y the source of contr'ol power to each one, This is ne ded tn order to assist our independent revfew o-,

how your emergency power systen'desi gn meets the singi e failur criter ion, G40. 81 (8.3)

RSP The availability on demand o,

an emet gency diesel generator is dependent

upon, among other things,'the proper func toning o= t.s con.rois and monitoring instrumentation.

This equipment ts generally I

anel mount& and in som tns ances the panels ar mount d dtr c.ly on the "tesei gene.ator sktd.

i%~or dtesei engine damage has oc"urred

a.

some operating plants from vibration induced wear

'n skid mounted control and monitoring lns rumentation.

7nis sensitive ins.rumenta.ion is not mad to wi.hstand and function accurately for prolonged periods under continuous vibrational stresses normally encoun ared with internal combustion engines.

Operation of sens tve instrumentation under this environment rapidly deteriorates calibration, accuracy and control si gnal output oner for, except, or sensors and othe.

equipmen that mus be direc ly mounted on the engine or associated piping, the controls and monitoring ins.rumentation should be ins.alled on a free s.anding

,loor mounted panel seoarate from the engine skids, and located on a vibration fre floor area or equipped with vibration mounts.

Confirm your compI<anc with the above requirement or provioe justification for noncompliance.

O4O.82 (8.3)

RSP P riodic testing and test loading of an emergency die'sel generator in a nuclear power plant is a necessary func ion to demons rate the operability", capability and avaT'labjltty of the unit on demend.

Periodic

'ta ing coupled. with good preen"ive main.enance prac ices will assure ootimum equipmen readiness and availability on demand.

inis is the desired coal, o

lo achieve his Qp imuii ecuip ent readiness s

us

.ie he 01 lowing reouir...ents should be met:

I, Tne equipment should be tes:ed with a mfnimum loading o" 25 per ent o, rated load.

No load or light load opera ion will cause incomplete combus fon of fuel.resulting in the formation o

'gum and varnish deposits on the cylinder walls, intake and exhaust

valves, pistons and piston rings,. etc.,

and accumulation of unburned fuel in the turbocharger and exhaus system.

The consequences o,

no load or light load operation are potential equipment failur due to the gum and varnish deposits and ffre in the engine exhaust sys.em.

2.

Periodic surveillance tes ing should be performed in accordance with the applicable NRC guidelines (R.g. 1.108),

and with the recommendations of the engine manufacturer.

Conflicts between any such recorrmendatfons and he HRC guidelines, partfculd. Iy wf.h.respec.

.o. st frequency, loading and duration, should be identified and jus.ified.

J 3.

Preventfve mafntenance should go beyond the normal routine adjust-ments, servfcing and repair of components when a malfunc ion occurs.

Preventive maintenance should encompass fnvesttgative tes.fng o, components which'ave a his.ory of repeated malfunc.foning and r quire constant'..entfon and repatr In sue/

cases consideration should be given to replacement o, those components with other produc s which have a record oi dmonstl ated relfabfTtty, rathe, than epe i Ye repair and matn-.enance o

the exis-.",ng compon n:s, 72s ing ft of :he unf i af.er adjus ments or repairs have been made only confirms

."'.at the equipmen-is operable and does ao-necessarily mean that the G

cause o,

he probI em has been el fmfnated or al I evia-.ed.

4.

Upon completion of repairs or mafntananca and prior to an actual s.art, run, and load test a final equipment check should be made

.o assure hat all elec rfcal circuits are functional, i.e,,

uses are in

place, switches and cfrcuf" breakers are fn thefr proper position, no loose wires all test leads have been r omved, and all valves are fn the proper'osi ion= to permit a manual start of the equipment

~

Aiter the unit has bean satfs actorfly s artad and load

". stad, return the uni

.o ready automatic s.andby service and under the control of the contml room operator.

Provide

a. d'ncussion of how the above requirements have been implemented in he emergency diesel generator sys.am design and how tf ay will be 7

considered when :he plant is in commercial opera ion,, i.e.,

by what means will the above requirements be enforced.

Provide a datafT discussion (or plan) of he level of training proposed Rr your operators, maint nance crier, quali y assurance, and supervisory personnel r sponsible for tha operation and mafnt nance of he emergency diesel generators.

Idantffy the number and type of personnel hat w111 be dedicated to the operations and mafn enanca oi the emergency d1esal gene. a-.ors and the number and type that will be assigned

,rom your general plant operations and. maintenance groups to ass1st wnan needed.

n your 'iscussfon iden j-,g -.he amoun-and k nd of training tha-. will be received by each o= the above ca agcrias and

=."e ype o= oncoing

=r ~ inin-

"r.cram ;lannad

.o assuro oc

.mum avai'Iab",,i.y of :he amer"ency canarators

Also discuss the level of education and minimum experience r qu remen s

or the various categories of opera.ions and maintenance pe.sonnel associated with the emergency dieseT generators.

040.84 (9.S.41 Your response to reques" 040.36 is no complete.

You state'n section 9.5.4.2 the available net positive suction head (NPSH),

With the impeller flooded, is much greater than the I ft. 6 inch required NPSH for the pump.

Therefore the entire volume above the pump centerline, 10 3/4 inch from the bottom, is available for the diesel gnerators.

Tne fuel oil storage tank transfer pump selected requires a

minimum NPSH of I ft. 6 inch to deliver its rated capacity of 25 gpm at 30 psi differential head.

Operation of this pump xith less than the required NPSH will affec.

pump performance and reliability.

At some point, if the pump is permit.ed to operate with diminishing NPSH, the pump will cease to deliver fuel and sever cavitation &11 occur.

Your above statements need further clarification, 040. 85 (9.5.4)

Your answer to request 040.37 is not complete.

The neo Figures 9.5-28, 9.5-29 and 9,5-30 do not provido <<he needed

- information to evaluate the adequacy o, the diesel genera. or I

fuel oi1 scrag@

and ransfer system.

Provide, additional information and draÃng (plans and sections}

1, The piping tn the truck fill pit.

2.

The locatton of the fuel oil storage tanks..with respect to the diesel generator butlding tncludtng all fue1 piping from the storage tank to t s associated day tank and from the day tank to the stoppage tank.

The ruat-;cn cf ",he fuel oil storage tanfw.o Buried yard piping that may Be,in the vacini-'y or cross under the fuel storage tank concrete support mat.

(see Fig. 9. 5-28).

Identify the line size, carrying capacity in gpm, pressure and fluid.

Provide assuranc that a pipe line break under the fuel oil storage tanks suppor struc ure will not prevent the diesel generator fuel oil storage and ransfer system from performing its safety function.

Plans of diesel generator butldtng at elevattons 660'-0",

710'-0" and 723'-0" 040.86 (g.s.c)

Rsp Your answer to request 040,38 ts. not complete, Ftgure 5.5-19 and figures 9,5-28, 9,5-24 and R,5-30 show the tank fill connec ton and branch fill ltnes to each

,uel otl storage tank as non-seismic,'lass D constructton.

Also the above figures do not identify the ptptng classtftcatton of the. fuel oil storage tank vent line and other connections,

~". ts our position that the-fuel otl storage

.ank fill line Him he ank tnter,ace up o and tncludtng the truck fill tnterface and all other tank cannecttons should be seismic Category.,

Class C construction.

Revtse your design accordingly.

You state in section 9.5.4.2 (Revision 9) the

<uel oil storage tank vents are goose necked and provided with screens

-to keep out potential above grade fuel contamination.

This is not acceptable.

Et is our position that fuel tank vents, should be provided with fiame arestors.

Revise your design accordingly.

Section S on figur 9,5-Z9 shows the four diesel genera. or fuel oil storage tanks, concrete support ma and. structures are loca ed between and abutting exis ing c~ane founda tons, Provide the r esuIt of an analysts wnich demonstrates that in the event of a design basis earthquake seismic tnteraction between the existing crane foundations and diesel generator fuel oil system support. structures will not prevent the hiesel generator

,uel oil stoppage and trans,er system from per,orming its safety function.

You state in section 9.5.4.3 (Rev. 7) excessive splashing and sediment turbulance is preven ed by the fuel fill line discharging near the bottom of the storage

tank, I< minor sediment turbulence

occur,

<ueI filters will keep the overall quali.y of the fuel oil acceptable during replenishment.

Location of the fill line near the bottom of the s orage tank does not necessarily mean that turbulenc is minimized.

To.he contrary, the magni.ude of turbulence generated wi h a vertical uel fill line is dependent urn ex'ipe veloci.y and the distance the end of the

,uel fill pipe is h.om the bottom o, the s.orage

.ank.

The tur bulence generated wi.hin the storage tank with your desicn is dependent upon the ill Itne location and =w',t veloc',ty.

Provide a draQng showtng the stz and arrangement of the fuel,ill line tn the s.orage tank, exjecked maximum r fueling rate (gpm},

and maximum fiII ltne exit veloct y, Also provide assurance that the turbulence generated at the maximum exis velocity will not degrade -the i'uel

.and prevent availabtlity of the diesel generator on demand.

A method of aleviating or mtntmiztng excessive turbulenc in the storage tank would be by a perforated'fuel fill distribution

header, The perforati'ons or or iftces should be designed for low exit veloct ies, 040. gO (g..-'.e)

Rsp Operating experience has shown that accumulation of water in the s.arting air system has been one of the mos frequen causes of diesel engine ailure to start on demand.

Condensation of entrained mois ur in com-pressed air lines leading to control and star ting air valves, air start

motors, and condensation of mois.ure on the working sur,aces of these components has caused rust, scale and water itself to build up and score and jam.he internal working par.s of these-vi.al components ther by preventing s arting of the diesel generators.

In the event of loss of offsite power the diesel generators must function wince they are vital to the safe shutdown o, the reac.or(s).

Failure of the diesel. engines to star.

from.he ef,e =s of mois ur condensation in air s art ing sys

~as and.

,, om other causes have lowered their operational reliabili.y.o subs an. ally less

.han the desired reliability of O.gg as s"eci,ied in Branch Technical Pcs i 'on ICSB (PSB

)

2 "Diesel Ceneracor Re1iability Testing" and Regulatory

"=u'de 1.108 "Periodic Tes=ing of Diesel Cene'tor Units "sed as Cnsi.a

.=lee=. ic

.-"owe.

Sys-ems a: Nuclear Power Plants."

s In an effort award T'mproving diesel engine starting r liabili.y we r quir that compressed air starting syst m designs tnclude air dryers for the removal of entrained moisture.

Tne two air dryers most correnly used are the dessicant and refr igerant types, Of these two types, the refrigerant type is he one most suited for this 'application and her mr is pr-ferred.

Starting air should be dried to a dew point of not more than 50 F

when ins alled in a normally controlled 70oF environment, other ~ise the starting air dew point should be controlled to at leas 10 F less than the lowest expected ambient temperature.

Revise your design of the diesel engine air s.arting system accordingly, describe this feature of your design.

O40.91 (9.o.7)

You s.a.e response to our request 040.49 ts coveref tn section 9.5.7.2 revision T.

Re have reviewed revtsion 7 and'o not find that you have addressed our request, provide your response to request 040.49.

040. 92 (9,i.7)

RSP Several fir s have occurred at some operating plants in the area o

the diesel en ine e

'xnaus mani, old and inside the turbocharcer housinag which have r suited in equipment unavatlabtlity.

~ne,ir s wer s.artad fr.m iube oil leaking and. accumulating on.he ngine exhaus mani old and accumulating and fgnf fng-tnsfde the turbocharger housing.

Accumulation of lube ofl fn these

areas, on some engines, fs'pparently caused irom an excessively long prelube perfod, generally longer than five minutes, prior to manual s.arting of a diesel genera. or.

This condition does not occur on an emergency s art since the pr lube period 4

is minimal.

Rhen manually starting the diesel generators d'or any reason, to minimize the potential fire hazard and to improve equipmen availability, the prelube period should be limited to a maximum of three o five minutes unless otherwise recommended by the diesel engine manu,ac.urer.

Conffrm yout compliance with this requirement or provide your ju~.i.fcatfon for requiring a longer prelube time interval perior.o manual s arting o=

the dfesel generators.

Provide the prelube time interval your diesel engine will be exposed to prior to manual swrt.

040.93 (9.o.7)

Rsp An eaer gency diesel generator unit fn a nuclear power plant fs normally fn the ready s andby mode unless there fs a loss o

o-,,site po'wer, an accident or the diesel generator fs under tes..

Long periods on standby have a tendency to drain or nearly empty the engine lube ofl piping 14 or more sys m

On an emergency start oi the engine as much as:

o 1. or sys iKA.

seconds may elapse,.om the s art of cranking un"fl,ul ~ lube oil r ssur

~

~

V fs at.afned ven though. -,ull engine sp ed fs c ne. ally re ched fn about five seconds.

Mfth an essentfally dry engine, the momentary lack of lubrication at the various moving parts may damage bearing surfaces pro-ducfng incipient or actual component faflur with resultant equipment unavailability.

The emergency condi fon of readiness requfr s this equipment to a.afn full rated spe d and enable automa fc secuencing oi electric load wi hin ten seconds.

For this reason, and to improve upon the avaflabtlt y of this equfpment on demand, ft fs necessary to establfsh as quickly as possible an oil film in the wearing parts o, the diesel engine.

Lubricating oil is normally delfvered to the engine wearing parts by one or more engine driven pump(s).

Ouring 'the starting cycle the pump(s) accelera'.s slowly wt.h'he engine and may not supply the required quantity oi lubricating oil whe, e needed fast enough.

To remedy this condition, as a minimum, an electrically driven lubricating oil pump, power d from a r liable OC power supply, should I

be installed fn the lube oil system to operat in parallel wi h he engine driven main lube pump, The elec rfc drtven pre1ube pump should operate onlyduring the engine cranking cycle or untf1 satfs7actory lube oil pressur fs established fn the engine main lube dfstrfbution header.

The fnswllatfon of thfs prelube pump should be coordinated wf h the

v

~

r spec.ive engine manufacturer, mneme diese1 engines tncl "de a, lube oil circulating pump as an tntregal part o, the lube otl pr heating system which is in use while the diesel engine is in the standby

mode, In this case an additional preluoe oil pump may not be needed, Confirm your comp1iance wi h the above requirement or provide your Justification for not tnstalling an electt ic prelube oil pump.

Experience at some operating plants has shown that diesel engines have failed to start due to accumulation o

dust and other deleterious 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 gene. ator building design, electrical s.arting system, and combustion air and ventilation ai intake design(s) to preclude this condition to assure availability of the diesel generator on demand.

Also describe under norma'i plant operation wha procedur (s) wtll be used to minimize accumulation o< dus" in the diesel generator room.

In your response also consider the condi.ion when Unit 1 is tn operation and Unit 2 ts under construction (abnormal generation of dust),

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos.:

50-387/388 Mr. Norman W. Curtis Vice President Engineering and Construction Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNIT NOS.

1 AND 2-REQUEST FOR ADDITIONAL INFORMATION As a result of our review of your application for operating licenses for the Susquehanna Steam Electric Plant, we find that we need additional information in the area of Power Systems.

The specific information required is listed in the Enclosures Some of this review has been performed by the Oak Ridge National Laboratory (ORNL).

Questions originated, by ORNL are identified by an X10 to the question number.

Please contact us if you desire any discussion or clarification of the information requested.

Sincerely,

Enclosure:

As Stated Light Water Reactors, Branch No.'

Division of Project Management cc:

See Next Page

>912050 ~~4,

f'.r. tforman '>>. Curtis Edward N. Nagel, Esquire General Counsel and Secretary Pennsylvania Power 8 Light Company 2 North 1'iinth Street Al 1 entown, Pennsyl vani a 18101 Bryan Snapp, Eso.

Pennsylvania Pov, r 8 Light Company 901 Hamilton Street Al 1 entown, Pennsyl vania 18101 Robert H. Gallo Resident Inspector P. 0.

Box 52 Shickshinny, Pennsylvania 18655 Susquehanna Environmental Advocates c/o, Gerald Schul tz, Esq.

500 South River Street Wilkes-Barre, PA 18702 John L. Anderson Oak Ridge National Laboratory Union Carbide

".orf;. rat I Bldg., 35QC, P.

U.

Box K

Oak Ridge, Tenne s=e 37830 cc:

t!r." Ea rl e N.

f 'e ad Project Engineering f!anager Pennsylvania Poi~~

6 Light Company 2 North Ninth Street Al 1entown, Pennsyl vania 18101 Jay Silberg, Esq.

Shaw, Pittman, Potts 6

Trowbridge 1800 N Street, "f.

W.

I,'ashing ton, D. C.

20036 f~r. William E. Harberich, t<uclear Licensing Group Supervisor Pennsylvania Power 6 Light Company 2 North Ninth Street Al 1 ento',

Pennsyli vani a 18101 f'ir. Robert J. Snovlin Project f:,anager Pennsylvania Power and Lieth'.

Co.

2 "orth Ninth Street Al 1entown, Pernsyl vania 1810>

flatias F. Travieso-Diaz, Esq.

Shaw, Pittman, Potts E

Trowbridge 1800 i'1 Street, N.

W.

Washington, D. C.

20036 Dr. Judith H. Johnsrud Co-Director Env.ronmental Coalition on Nuclear Power 433 Orlando Avenue State College, PA 16801 f!r. Thomas Yi. Gerusky, Director Bureau of Radiation Protection Department O'nvironmental Resources Commorwealth of ?ennsylvania P. 0.

Box 2063 f'.arrisburg, PA 17120 fis. Colleen Harsh F.ov 538A, RD;-4 f!ountain Top, PA 18707 f'~s. Irene Lemanowicz, Chairperson The Citizens Aga inst fluclea r Dangers P. 0.

Box 377 RDrl

Ferwick, PA 18503

SECOND ROUND RE(gESTS SUQUEiQNNA.STEAN ELECTRIC STATION DOCKET NO. 50-387 POMER SYSTBlS BRANCH

040. 64-X10 by 125~ of four hour demand but seems to be ac.ually only 100>>

of 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> demand by Table 8.3-8 and repor your findings.

in the event of failure of preferred power, then the alternate power; please discuss the operational seouence for restoration of the Class IE power channels, a) from standby power to alternate

power, b) from standby power to preferred power.

040,65 X10 Branch TechnfcaT Position ICSB (PSB) 2 Oiesel Generator Reliability gualfficptfon Testing (SRP Appendix 8A) requires a

prototype qualification program to demonstrate the capability af new and/or unique designs for use fn nuclear service.

Provide the results of'he prototype qualification for the SSES units.

'I Cooper Bessemer has made recent changes in its design of cylinder heads and induction sys ems.,

State in light of these changes whether the SSES diesel generators have these new design features and if so whether they have been qualified in accordance with BTP ICSB (PSB) 2, or offer an alternative on some other defined basis.

040, 66 X10 In FSAR Section T,4,1,2.2, ft fs suted that both divisions of the SLCS ar powered firn Division I, Yet in Table 3.12-1 the SLCS fs listed fn

~~

separate divisions, I and II.

Provide a discussion which resolves these apparent inconsistencies.

040. 6~xi 0 A "480v Swfng Bus" is listed in Ofyfsfon I and another fn Oivfsfon II (Table 3,12

1) and described fn Section 8,3.1,3.5 Although these swings ar not betm n redundant divisions they are betmen r dundant separaLion channels as three channels out of four are requir d in your plan. to successfully me t the on-si.

power r qufmnents of a LOCA fn one uni: and safe shutdown of the othe". unit.

This configuration

. quir es indepenaence and separat on

between Class IK channels as wll as KS'"--:sions in each of the two units of your plant, In order

.o acili~te our review of this aspec of your design, provide a c~on mode-ccmnon cause failure analysis for the Russe11

."-lec.ric Company transfer switches that you use to transfer from one power supoly channel to the other in each division, Also describe the testing program for the entire isolation arrangement (motor-genera or set) protective swttchgear, and transfer scheme Of.he swtng bus h

q1

• ;':xts.

040. 68.X10

'/arious metallic vapor lamps have "delaved" reicnition time cfaracteristics, Postulate a condition such as a temporary loss of power, which would produc a delayed r ign"'.t:".". condition.

Are there any SSFS plant areas fn which this postulated condition could interfere with plant operations'7 if so, provide modified design to correct this situation.

040. 69-X10 in Section 7.4 the, statement "heat tracing of pu~ suc ion piping receives power from a bus that is connectable to the standby A-C power supply."

Identify this "connectable bus" and describe the loads (by name and rating), method of connection, and iso'lation (jf non-IE),

040. 70 X10 G.Z Reg.

Guide 1.70 reccmends "in particular, he circuits that supply power for the safety loads from ".,",e

-.". nsmission network should be identified and shown to meet GDC 17 and 18," and describe and provide layout drawings of the circuits :na-c nnec" the onsite dist) ibutjon system to the pr ferred pcwe.

sup=.-y,ncluding transmission lines, switchyard arrangemen:,

right of way, etc."

GDC 18 states elect jc power systems jmpor-. n: to saf ty shall be designed to pepqjt apprqprja~e periodic inspection and testing of jmportant areas and featurrs---,"

You state that i'or pre-Unit 2 operation the preferred power sources for the SSFS are the contour-Fountain and the Mescosvjlle-Susquehanna tje lines, Oiscuss

.hese tn tie line systems and their assocjated switchyar"s with r gard to the'bove stated referenc s and reaffirm that PCS protective relay testing, maintenance and calibration apply to these switchyards and can be performed during unit operation.

040, 71-Xl 0 In'he event that the control room mus. be vacated, what means and methods of communication are available from he remote shutdown panel of Unit 2 to the various ou -buildings such as diesel generator building, emergency service wate.

pump house, make-up water pump hose, circulating water pump house, and radwaste

building, 040. 72-X10 Cwnera1 Oesign Crtterjon 18 requires the abjlj y ta perjodtcally inspect and test'important safety features of electric power

systems, State whether pertodjc inspe tion of the penetration assemblies's possib1e and whether'the requjrenent of 'GOC-18 have been satisfied'in this regard, Figure 3.13-4, Is there a program for

. s:-',ng anc tnspec jng the 120v ac contro1 cjrcutt 6A fuses'lso, provide the'type (e.g; molded case}

and source'o actuation wwer for -he 20A Cutler an Hamner Type CH8 breaker s,:he

.'-'..=:-;8 "-0'reakers ai the 480v ]AC", and

.he 225A supply bre.k

." a.

each

~<stru-ment ac panel,

Periodic tes ing of containment circuit prot tion sc.".emes ta a requirement.

Provide the details. of your pe.todtc testtng pro gr am.

040.73-X$ 0 State whether

.he essen illligh"ingsystem ts sequenc d onto the Class IE 480 buses or reaa$ ns connec ed'to the bus through-ou< transfer'to-he diesels in the'event of a

LOGSP, Is the total of essential lighti'ng 169kw as in Table 8,3-3, or 188kw as in 8,3-2 or 222kw as in 8,3<, or 258kw in c,3-5?

Mhy these dif,erences?

040.74 -X10 On the topic of non-Class IE instrument circui.s; In pa.agraph

'8.1.6.1,n-7 you state as an "analysis" tha. "non-Class IE

.instrument circuits are considered low energy and the probabil tty of these non-Class IE circutts providing a mechanism o, faiiur e to the Class IE circutt is extremely low."

This fs na. acceptable as ar. aralysfs of your de." gr..

Provide the. necessary justification and suppor ing bases to demonstrate your conclusions.

040. 75-X10 In this same context review your use of Class IE devices as informa ion sources for digital/analog information, as described in paragraoh 9 of Section 3.12.3.4.1 of the FSA'R (Page 3.12-9 of ~~AR} and report your findings.

Verify that acceptable isolation is provided in accordance with IE:-= Standard.279-1971 Sections'4.l and 4.7.

On the same topic as stem 040.82, above, bu" in i s a pl',cation z containment elec.rical penetrations, (your paracr oh 8.1.5.1.n-13) you state that cable penetrations into the supprzsion

=col con". in Class'E and non-Class

."= circuits.

These non-Class IE circuits include instrumenta"ion.

annunc-.ation, 0

circuits, and computer circuit.

Provide further jus ification for the classif.cation of these as non-Class Ii circuits in containment penetrations, or describe a testing program to demonst;a.e the acceptability of your design approach.

040. 76-X10

'-Your placement of electiicaI separation descriptions tn section 3.12.3.4 has made tt difficuIt to follow he conttnuity o subject matter tn the FSAR.

In 3,12,3.4.l-fourth subsection, "Raceway sharing of Class IE and non-Class IE Ctl cutts" tt 3s s.ated that, "480v ac and 125/250y dc non<<Class IE load groups connected to Class.

IE buses are supplied through two circuit breakers physically separated from each other and connected jn series'The cables from the Class IE bus up to the second breaker remain wt h and follow the same rules as the Class Ii circuits of the i espective separation divisions and are uniqueIy tdenttfied, The second breaker and its ctrcuits are not subject-'

State whether'the second breaker of such an arrangement is Class IE, and ltst'the circuits that use this double breaker isolation scheme,'urther, provide the bases for acceptanc for the use of this fault-actuated isolation

scheme, 040.77-XIO Section 8,1.6.1,n, "Compliance with Regulatory Gutde 1,7S (1/7S}."

I)

The statement at the end of the firs paragraph of this section, referring to Sec ion T.I, is no unders.andable, nor is.he next paragraph correct in its description of redundancy'and independence',

It is stiT1 not clear. what Wry o, ele.ric 1 isolation are used tn the design'>

SSH, Therefore, provide a ltsting of all the assoctated and non-IE circui'ts that requtre tsolation from the Class IE systems and the'ethod of isolation (method 1, 2, 3, or

4. as described in your paragraph 8,1.6,1.n-5I used for each circuit.

2)

Your description of "isolatton systems" in paragraph.

8.1.6,l,n-5 de,ines'something that is noi in accordance with Regula.ory Gutde 1.75 for assuring independenc o,

Class IE power'sources from an intermedtat non-Class IE bus (method 3 o the paragraph).

Therefore, state wheiher there are inde d some non-Class IE.loads in the SSES design that are supplied'from a, Class IE source through an inter-mediate

bus, and describe the isolation system for thai bus, 040.78 -Xl 0 Paragraph 8,3,1,3,14 of, the FSAR indicates'tha some

"-electrical equipment associated with Class IE loads identified tn Chapter 16.0" ts not testable during reac or operatton, List or reference this equipment, Demonstrate that all of the above quipmen" so identified is tn conformance'with Regulatory Guide 1,22 Section D,4, 040 7g -XTO Figure 8 3-5, "125v'dc and 250v'dc Systems" indicates that loads 1D666, 10165,

1D656, and 10155 and 10615,

10635, 10625 and 10645, are "Non-q-Lts ed" Panels, Y'et on drawings c,iT, Sheets 3 and 4, there are notes that all loads are "g-Tfs ed,"

On drawing =l1 Sheets

'T

& 2 the. note also says thai all equipment is "g lisied."

Provide further deiatls to acilitat our understandtng of this aspect of your design, Me do not have drawtng BG&h,3, and there-,ore, can no teil gust wnat loads are on.he 125Y'dc distribution panels fn question.

Provf'de this drawing, In the 250Y dc case (Owg..E-ll., Sh.

3 5 Sh, 4) the loads seem to be entfrely emergency'lube'oil pumps that are not C'>ass I"- by function.

State how such load centers are handled and whe her an acciden.

signal derfvatfve trips of, the entfr bus or fndfv'duai loads.

Me note that fn Table 3,1OC-13 panels

10155, 10155, as well as 20155 and 20165 (i'ot Unit 2} are lfsted as seismjcaiiy quaitffed while all the o.hers are not, Bplafn the

. a icnal

. or these Cffferences.

Also, tn Ftg. 8.3-5 the 250v'c Class I="ba-ter y supplies a

16OOA dtstributfon panel through a

2OOQA fuse, Stat the design bases for this aspect of your desfan, P",.ovfde a listing oi'll switchgear that is no". seif-activated (both safety and non-sa,ety) and spe f-,fcaily identi,y

.he source o

control power to each one.

This is needed tn order

.o assist our independent r view o, how your emergency power systen'design meets the single faf1 ur cri erion, 040.81 (8.3}

Rsp The availability on demand of an emergency diesel generator fs dependent

upon, among o her things, the proper

-,unc ioning o= tts controls and monitoring ins rumenta fon.

Thfs equfpmen-fs generally oanei mounts and fn some fns ances:he panels are noun:ed direc iy on the diesel generator skid.

i%'or dfesei ang'.ne damage has occur red

a some opera ing plants from vibratton induced we r on skid maun ed control and monitoring instrumen attar.

Tnts sensitIve tns:rumentatiart

.is not made to wtths and and functton accurately =.r pr longed periods under continuous vibrational stresses norma'eely encaun ared wi h internal cambus ton engines.

Operation of sensttve ins rumen a.'.on under this environment rapidly deteriorates calibratton,-

accuracy and control signal output.

oner rore, except

,or sensors and other equipmen that must be dire ly mounted on the engine or associated ptptng, the controls and manitorinc ins.rumentation should be installed on a fre standinc,laor mounted panel separate rom the engine skids, and located on a vibra=ion,re

,loor area or equipped with vibration mounts.

Canftrm your campitance wtth the above requtrement or "ravide gus t,ic tjon ar noncompliance.

040.82 (s.i}

Rsp Periodic testing and es loading of an emergency diesel cenera ar in a nuclear power plant is a necessary func ion ta denanstrate

.he operability, capabiltty and avatlabjltty of the unit on demend.

Periodic esting coupled. wi.h eood preventtve main.enance prac tees wili assure optimum equipmen r adiness an8 avatiabtii y an demnd, inis is the desired coal.

~ ~

Tc acnieve this op imum equipment readtness s: tus:.'-.e:.'".e ra>.awing recuire...en s should be met:

0

- IQ-1.

one equipmen should be.es.ed wi h a minimum Toad'.nc of S oerc nt of rat d load.

No load or light load operation will cause incomplete combus ion of fuel resulting in the formation o,'gwa and varnish deposi s on the cylinder walls, intake and exhaust valves, pistons and piston rings,. etc.,

and accumulation of unburned fuel in the turbocharger ahd exhaus.

sys em.

Tne consecuences of no load or light load operation are potential equipment failure due to the gum and varnish deposi s and,ire in the engine exhaus. system.

2.

Periodic surveillance tes.ing should be pe.,ormed in accordance wi.h the applicable NRC guidelines (R.g, 1.108),

and wi h the recommenda ions of the engine manufacturer.

Conflic s between any such recommendations and the HRC guidelines, particui>riy with.respe. to est frequency,

'I loading and duration, should be identified and jus ified.

3.

Preventive main enance should go beyond the normal routine adjust-ments, servicing and repair oi'omponents when a mal f nc ion occurs.

Preventive maintenance should encompass inves t oative t sting of components which have a his.ory of repeated mal func.toning and require cons:an. at. ention and r pair, In such cases consider tion should. be given to r placemen of.hose components wi h other produc s which have a record of'emnstrat~ reliabil;.y rather than r peti ive repair and maintenance c t le exis

'lg components, Testing o, the uni after adjustments or repairs have been

.-,.ade only confirms tha. the equipment is operable and 'oes not necessar-.'.y

.,ean

-.hat -he roo cause o,

.he problem has

'"een ei'.mina-ed or a;,ev a-ad.

4.

Upon completion of repairs or mfntananca and prior.o an actual start, run, and load test a ffnal equipment check should be made to assure that all electrfcal cfrcui.s are functional, i.e,, fuses are fn

place, switches and circuit breake. s are in their proper position, no loose wiresall tas. leads have been rmaved, and all valves are in the proper posi ion to permit a manual start of the equipment, After the unit has be n satis,actorfly started and load tas.ed, return the unit to r ady automatic s.andby service and under the control of the control room operator.

Provide a; d'mcussion of how the above requir ments have been implemented in he emergency diesel generator sys.em design and how.hey will be 7

considered when the plant is fn comnercfal operation,. f.e.,

by what means will the above requiremen s

be anfor ed.

\\ ~

Provide a detafT discussion (or plan) of he level of trafning proposed for your operators, maintenance crier, qual f.y assurance, and supervisory phrsonne1 r sponsible for the operation and mafnt nance of the emergency diesel generators.

Ldentffy the number and type of personnel that will be dedicated to the opera fons and mafntananc o, -he emerg ncy diesel generators and the. number and type that wfll be asstgned from your caneral plant operations and maintenance croups to assis.

when ne ded.

n your discussion identffy he amoun:

and kind o. =r.'nin", :ha-will be rec ived by each of tha above cat gor as and :he :ype cf cncoing "ra'ning program planned o assure op-fmum availabf;i= r of :."'.e amer"ercy gener'tors.

Also discuss the level of education and minimum ex."er

~"."a.-ecuir~".en s

or the various categories of operations and maint=-".a.".ca ;ewcnnel associated wi h the emergency dieseT genera ors.

040.84 (9.S.4}

Your response to r quest 040,36 iz not complete.

You. state in section 9.5.4.2 the available net positive suc:ion heac

(.')PSH),

with the impeller flooded, is much greater than

.he 1 ;..

6 inch required NPSH for the pump.

Therefore the entir o vo'.u-.'bove the pump centerline, 10 3/4 inch from the bot.om, s available

=or the diesel gnerators.

The fuel oil storage tank transfer pump selected roq"i.

s a

minimum HPSH of 1 ft. 6 inch to deliver dts ra.ed capaci y of 25 gpm at 30 psi differential head.

Oper ation of :h s

pump with less than the required NPSH &11 af,ect pump."er-,cr. ance and reliability.

At some point, if the pump is permit=ad ~

opera.e with diminishing NPSH, the pump will cease." c liv r

,uel and severe cavitation &11 occur.

Your above statements need further clarification.

040.85 (9..-.4}

Your answer to request 040.37 is not complete, The nex Figures 9.5-28, 9.5-29 and 9,5-30 do not provid

e neede

'nformation to evaluate the adequacy of the d',ese.

c nera-cr uel oil storage and ransfe.

sys.em.

13 Provide. addftfonal informatfon and drawing (plans and sections}

1.

The piping

$ n the truck fi11 pit.

h 2.

The location of the fuel oil storage inks with respec-to the diesel generator building including all fuel piping from the storage tank to its associa ed day tank and from the day tank w the stoppage tank.

3.

The re..at crt cf the, fuel oil storage tan~

.o Buried yard piping that may Be in the vacinity or cross under the fuel storage tank concrete support mat.

(see Fig. 9.5-28).

identify the line size, carrying capacity in gpm, pressur and fluid.

Provide assurance that a pipe line break under the fuel oil Istorage tanks support structure will not prevent the diesel generator fuel oil storage and ransfer sys em rom performing its safety function.

4.

Plans of diesel generator butldtng at elevations 660'-0",

?10'-0" and ?23'-0" 040.86 (c 5d)

Rsp Your answer to request Q40,38 ts not complete.

Figure 9.5-19 and figures 9,5-28, 9.5-29 and 9,5-30'how the tank fill connection and branch fill lings to each,uel oil storage, ank as non-seismic, Class D constructton, Also the above figures do not identify the ptptng classification of the fuel oil storage tank vent line and other connections.

04G.87 g9.5.4}

Et ts our positiorr that the fuel oil storage tank fill line mm the tank tnter face up to and tnciudtng the ruck fill interface and a11 other tank conne talons should be seismic Ca egory i, Class C construe.ion.

Revise your design accor dingly.

You state in sec ion 9.5.4.2 (Revision

9) the fuel oil s orage.

tank vents are goose necked and provided with screens to ke p cut potential above grade fuel contamina ion.

This is not acceptable.

it, is our posi ion that fuel tank vents should be provided with fIame arestors.

Revise your design accordingly.

Section 8 on figure 9.5-Z9 shows the four diesel generator fuel oil storage

tanks, concrete support mat and struc ures ar loc.ed between and abut.$ ng existing crane foundations, Provide the result of an analysts which demonstrates that in the event of a design basis earthquake seismic tn eraction between the existing crane foundations and diesel generator i'uel oil system support structures will not prevent the diesel generator

,uel oil storage and transfer system from performing its safety function.

You s.ate in section 9.S.4.3 (Rev. 7) excessive splashing and sediment turbulance is prevented by the,uel fill line discharging near the bottom of the s orage tank.

i-, minor sediment turbulence occur, fuel filters will keep the over aII quali.y of the fuel oil acceptable during replenishment.

Location of the fill line near the bottom of the s orage tank does not necessarily mean hat turbulence is minimized.

To the contrary, the magnitude. of turbulence generated wi h a ver".ical fuel fill line is dependen" upon exit pipe velocity and the distance the end of the fuel fill pipe is from he bo om o -,

he s.orage tank.

The urbulence generated within the storage

.ank with your desi",",

is dependent upon the ill Itne Iocat',on and =w t veloci.y.

- 15 Provide a draQng showtng the stze and arrangemen of the fuel fill line tn the s orage tank, ex"ected maximum r fueling rate (gpm),

and maxtmum ftII line exit veioct.y, Also provide assurance that the turbulence generated at the maximum extst veioctty will not degrade -the fuel.and preven avatiabtltty of.he diesel generator on demand.

A method of aleviat]ng or-mtntmtztng excessfv turbulence tn the

/

storage tank would be by a perforated fuel ftll distribution header.

The per forattons or oriftces should be designed for Iow exit vel octttes, 040. 90 (g.3.6)

Rsp Operating experienc has shown that accumulation of water in the s ar.ing air system has been one of the mos frequent causes of diesel engine failure to start on demand.

Condensation of entrained mois ure in com-pressed air lines leading to control and s ar.ing air valves, air start

motors, and condensation of moistur on the working surfaces of these components has caused rus

, scale and wat r itsel, to build up and score and jam he internal working parts of these. vital componen.s thereby preventing s.arting of the diesel genera ors.

in the event of loss of of, site power the diesel generators mus: function since they are vital to the safe snutdown o, the r ac.or(s).

Failure of the diesel engines to s ar. from he ef,e""s of mois.r c"ndensa ion in air s arting sys ems and. from othe>>.

causes nave lower d their operational reiiabili y tc subs.antially less than

-.he desi rod reiiabili y "= 0.99 as specified in Branch Technical Posi.ion.

SB (PSB) 2 "".i sei Generator Reitabii sty Testing" and Regulatory Guide I,IOS "Per':odic Testing of Diesel Cinerator Units Used as'Cnsita

=iec=r c P"wer Svs->>s a-..'nuclear

/

Power Plants."

?n an effort toward tmproving diesel engine s ar-ing r liability we recu're that compressed air starting system designs tnclude air dryers for the removal of entrained mois ure.

one t'm air drye. s most comenly used are he dessicant and refrigeran types.

0 hese two.ypes, the r frigerant

.ype is.he one mos suited for this application an" herefore is pr-fewed.

Star ing air should be dried to a dew point of no more than S0 F

when ins all ed in a normally controlled 70oF environment, otherwise the s arting air dew point should be controlled to a. le s

10oF less than the lowest expe

.ed ambient temperature.

Revise your design of the diesel engine air starting sys.em accordingly, I

describe this feature o

your design..

040.91 (9.S,7) 4 You s ate response to our reques.

040,49 ts cove. ed tn section 9.~.7.2 revision T.'e have reviewed revtsion 7 and'o not find

.hat you have addressed our request.

provide your response to request 040.49.

040. 92 (9.o.7)

RSP Sev ral fires have occurred at some operating plan s in he area o=

e area oi

.he diesel engine exhaus manihld and inside the "or~<charge.

housina wnich have r suited. in equipment unavailability.

Tne fir s wer star.ed

-,rom lube oil leaking ance acct mulating on the engine exhaus

- 17'-

manffoId and accumulating and fgnf ing inside he turbocharger housing.

Accumulation of lube ofl in these

areas, on some

ngfnes, ls apparently caused from an excessively long prelube period, generally longer han five minutes, prior.o manual s

ar fng of a dfiesel genera or.

This condition does not occur on an emergency start siince the prelube period fs minimal.

When manually starting the dfesel gene,ators

-,or any r ason, to minimize the potential ffre hazard and to improve equipment availability, the pr lube period should be limited to a

max',mum o-, :hr to ;fve minutes unless otherwise recommended by the diesel engine manu-,actur r.

Confirm your compliance with this requirement or provide your >us:i ication for requiring a longer prelube time interval perior to manual s ar=ing o-,

the diesel generators.

Provide the prelube time interval your diesel engine will be exposed to prior to manual swrt.

040,93 (g.~.7)

RSP An emergency diesel generator. unit fn a nuclear power plan-fs normally fn the r ady standby mode unless ther fs a loss o-, o-..si:

power, an accident, or the diesel generator fs under tes Long periods on standby have a tendency to drain or nearly empty the engfre I be cfl piping system.

On an emergency s ar'. o, the engine as much as

=.o I-. or more seconds may elapse Mm the s.ar" og crankfng until

. I i lube oil pressure

is attained even though iuII engine s eed is generally reached

',n about

,fve seconds.

'>lith an essentfaIly dry engire, the momentary lack of lubrication at the various moving parts may da:-,age bearing surfaces pro-ducing incipient or actual component failure with resultant equipment unavailabflfty.

The emergency condi ion of readiness requft s this equipmen to a.ain full rated speed and enable automa ic sequencing o-. electric load within ten seconds.

For this reason, and to improve upon the avaflabili y o, this equipment on demand, ft fs necessary to establish as quickly as possible an oil -,flm in the wearing parts o-, the diesel

engine, L bricating oil is normally delivered to the engine wearing parts by one or more engine driven pump(s).

Ouring the s artfng cycle the pump(s) ac"elerates slowly wt h the engine and may not supply the required quantity o= lubric ting oil wher needed

,ast enough.

To remedy this condition, as a minimum, an elec-rically driven lubricating oil pump, power d irom a reliable OC power supply, should be ins alled in the lube ofl system to operat in parallel with the engine driven main lube pump, The elec ric. driven pr eiube pump should ooerate onlyduring the engine cranking cycle or unttI satfs-,ac.ory lube oil pressure fs es ablished in the engine main lube dfs.rfbutfon header.

one fnsmllatfon of this prelube pump should be ccordfnatad with the

r spactiva engine manu,actur r, 5'ome dtesal engines tnclude a lube ofl S

ctrculating pump as an tntregal part of.he lu"a otl pr heattng system whfch is in usa while the diesel angina is in -he standby mode.

In this case an additional prelube otl pump may not be na dad.

Canffrm your compl fanca with the above r qufr ~ant or provide your

<us ffication for not fns ailing an elec rfc prelube otl pump.

Experience at some operating planta has shown tha diesel engines have fatled to start due to accumulation o, dust and other delttarfous material on al c.rfcal equip associated with starting of the diesel generators (e.g.,

auxfltary relay contacts, control switches - atc),

Describe the provisions that have been made in your d ese'.

generator building design, electrical starting system, and combustion air and ventilation air intake design(s) o preclude this condition to assure availability of the diesel oenerator on demand.

Also describe under normal plant operation wha procadur (s) wtll be used to mfnfmfza accumulatton o", dus" tn the dfesel generator room.

In your response also consider the condition when Unf 1 fs tn operatton and Ont 2 ts under cons:ruc ion (abnormal generatton oi* dust),

0