ML19207A869

Submits Request for Addl Info Re Power Sys & Conduct of Operations

ML19207A869
Person / Time
Site:	Waterford
Issue date:	08/02/1979
From:	Baer R Office of Nuclear Reactor Regulation
To:	Aswell D LOUISIANA POWER & LIGHT CO.
References
NUDOCS 7908220532
Download: ML19207A869 (18)

Text

I' If /j(' ((p'

/'v.. u 4, UNITED STATES

[%v

'h NUCLEAR REGULATORY COMMISSION

• -\\ M C

WASHINGTON, D. C. 20555

'k.,g m o rm Docket No. 50-382 Mr. D. L. Aswell Vice President, Power Production Louisiana Power and Light Company 142 Delaronde Street New Orleans, Louisiana 70174

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (Waterford Steam Electric Station, Unit 3)

Enclosed are requests for additional information.

These requests include Questions 040.45 through 040.71, concerning power systems, and 422.3 through 422.11, concerning conduct of operations.

Additional requests in the 040 series will ba sent to you when our resources permit the continuation of the Waterford Urit 3 review in that area.

Please advise us of the date you expect to provide responses to the enclosed requests.

Sincerely, k'l c

Robert L. Baer, Chief Light Water Reactors Branch No. 2 Division of Project Management

Enclosure:

Requests for !jditional In formation ecs w/ enclosure:

See next page

'/81194 2908220S$R-

Mr. D. L. Aswell AUG 0 2 ER9 Vice President, Power Production Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70 174 cc:

W. Malcolm Stevenson, Esq.

Monroe & Lemann 1424 Whitney Building New Orleans, Louisiana 70130 Mr. E. Bl ake Shaw, Pittr.an, Potts and Trowbridge IPC: n Street, N. W.

Washington, D. C.

20036 Mr. D. B. Lester Production Engineer Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Lyman L. Jones,. Jr., Esq.

Gillespie & Jones 910 Security Homestead Building 4900 Veterans Memorial Boulevard Metairie, Louisiana 70002 Luke Fontana, Esq.

Gillespie & Jones 824 Esplanade Avenue New Orleans, Louisiana 70116 Stephen M. Irving, Esq.

One American Place, Suite 1601 Eaton Route, Louisiana 70825

'81135

ENCLOSURE gg1979

~

040.00 POWER SYSTEMS BRANCH

.40.45 Section 1.7, Appendix A contains a list of FSAR acronyms.

Include information (1.7) for both electrical and mechanical drawings of the symbols used and their meaning to assist in the drawing review.

340.46 In order to improve the efficiency and effectiveness of our review, please 1.8) crovide a new section 1.8 in the FSAR.

In this section, include a table indicating the extent to which the design complies with all applicable NRC regulatory guides and the revision number of those guides.

For each appli-cable regulatory guide, the table should identify those sections of the SAR to which the guide applies and should indicate any proposed exceptions to the regulatory position.

40.47 in section 1.0, address Regulatory Guide ).70 and the applicable revision that

.:1.0) applies to the format and content c, your FSAR.

40.48 Your response to our original question 040,03 is not complete.

Address the (8.3) following comments:

1.

Your design provides a three-out-of-three logic to generate the loss of voltage signals (LOVS) and employs a common UY device for both levels of protection per phase.

Explain the failure mode anJ testability of your design considering single failures, Compare the reliability of your design with a two-out-of-three, logic system, 78113G 2

The Technical Specifications should be revised to include limiting conditions for operation, surveillance requirements, trip setpoints and associated time delay values (as outlined in 040.03),

nun 0 2155

. ~

3.

Specify the time delays and provide the ba, sis for selection of the trip points and time delays chosen relative to (a) the voltage transients encountered during diesel generator load sequencing and (b) equipment proter *.fon during the low voltage condition, 4

Explain the function of relays 27-1, 2H and 27-3 shoe on figure 8,3,5, AB AB AB 040.49 As described in FSAR section 8, 3,1,1, 2. 8, your design does not provide for (8.3) blocking of the load shed feature when operating on onsite power,

Further, an adequate basis for not blocking the load shed feature was not provided in response to our original question (040,04),

According?y, revise year FSAR to block the load shed feature when operating on onsite power, The major concern when load shedding is retained during operation on onsite power is inadvertent load shedding resulting from (a) voltage transients experienced during load sequencing, (b) failure of the loss of voltage signal (LOVS) actuating circuitry or (c) misadjustment of the LOVS components.

'id1187

AUG o 21579 ~

0.50 Pa ra graph 8, 3,1,1,2,8 indicates that load sequencing is performed both on

~

offsite and onsite power, Address whether or not you enploy independent or common sequencers when using the offsite or onsite power sources.

If common sequencers are used, provide a detailed analysis to demonstrate that there are no credible sneak circuits or common failure modes in the sequencer design that could render both offsite and onsite power sources unavailable, In addition, provide information concerning the reliability of your sequencers and reference design detailed drawings,

0.51 Your response to our question 040,05 is not acceptable, Your technical 3.3) specifications on testing onsite power sources should be revised to reflect the testing requirements of Regulatory Guide 1,108 The CE standard technical specifications are being revised to reflect the requirements of Regulatory Guide 1.108,

0.52 Your response to our question 040,09 is not complete.

Provide the details i.3) of your power lockout design and address the degree of conformance to branch technical position ICSB 18 (PSB) in Appendix 8A of the Standard Review Plan, 7a1138

. e, A1!G 0 2 d

-4

~

' larify the discussion is paragraph 8,3,1,1,2,13(f), Load Shedding Circuits C

40.53 in the following areas:

a)

Define " normal" source of power used in the discussion, b)

Expand the discussion related to shedding of non-essential loads when the diesel generator is the only source of power (paragraph 8.3,1,1.2,8 indicates that all loads are shed on loss of voltage), Provide the system description for information, c)

Define the non-essential loads (referred to also in paragraph 8,3,1,1,1,e, page 8.3-6, 4th paragraph),

Give exar.ples and possible combinations of these non-essentail loads, 040.54 Ofesel generator alar =s in the cont:rel reac:

A review of c:alfunction (8.3) reports of diesel generators' at operating nuclear plants has uncovered that in s =a cases ths infor:stfon available to the control reors operator to indicate the operatfocal status of the diesel generator my be igrecise and could lead to misinterpretation. This can be caused by the sharing of a single annunctater station to alam conditions that render a diesel generator unable to respond to an aut:xsatic emergency start signal and to also alam abnor=al, but not disabling, conditions.

Another cause can be the use of wording of an annunciator windcw that does not specifically say that a diesel generator is inoperable (i.e.,

unable at the tf=a to respond to an aut:x:atic ecargency start signal) tden in fact it is inoperable for that purpose.

300R BRNEL l

i31199 gua o e 9g79 Review and evaluate the alam and con, trol circuitry for the diesel generators at your facility to deterstne. hew each condition that renders

- a diesel generator unable to respond to an autratic energency start signal is alar:ned in the control roes. These conditions include not only the trips that lock out the diesel generator start and require ranual reset, but also control switch or ::cde switch positions that block aut: atic start,' loss of CCntrol Yoltage, insufficient starting air pressure or battery voltage, etc. This revien should consider all aspects of possible diesel generator operational conditions, for exa:nple One area test conditions and cperation frc:n local control stations.

of particular concarn is the unreset condition following a ranual stop at the local station which teminates a diesel generator test and pfter to receting the diesel generator centrols for enabling subsequent aut =atic cperation.

Provide the details of your evaluation, the results and conclusions, and a tabulation of the folleving infor:atton:

(a) all conditions that render the diesel generator incapable of responding to an aut==atic emargemey start signal for each crerating code as disc::ssed above; (b} the wording on the annunctatar wtndow in the control rocm that is alamed for each of th:2 c:ndtttons identified in (a);

(c) any othcr alam signals not included. in (a) abeve that also cause the sam an mc{

,r b

.om

AUG 0 21979

~

(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.

040.55 Recent experience with Nuclear Power Plant Class IE electrical system

8. 3.1 )

equipment protective relay applications has established that relay trip setpoint drifts with conventional type relays have resulted in premature trips of redundant safety related system pump motors when the safety system was required to be operative.

While the basic need for proper protection for

~

feeders / equipment against permanent faults is recognized, it is the staff's position that total non-availability of redundant safety systems due to spurious trips in protective relays is not acceptable.

Provide a description of your circuit protection criteria for safety systems / equipment to avoid the above referred protective relay trip setpoint drift problems.

043.56 Your response to request 040.21 is not complete.

In addition to the 9.5.4) infomation provided, describe how fuel oil will be delivered to the site under maximum postulated flood level of +30 ft. above mean sea level.

'td1.201

~

~

AUG 0 21973 043.57 Your response to request 040.23 is not acceptable.

You state that the (9.5.4)

RSP diesel oil storage tank vent and fill lines are not safety related, they are not protected from tornado missiles, and that the fill lines are provided with normally closed valves to prevent ingress of water into the diesel oil storage tank during postulated flooding.

Maximum postulated flooding at this site is +30 ft. above mean sea level.

At maximum flood level the fuel oil storage tank fill lines would be submerged ender 6 to 9 feet of water.

We require that all fill and vent line connected to the safety related fuel oil storage tank be designed to seismic Category I, Class 3 requirements, and that these lines are terminated above the site maximum flood level, and that they are protected from damage by tornados missiles.

Revise your design accordingly.

040.58 figure 9.5-3 shows two drain lines 7EGl 43 and 7EGle44 from the diesel (9.5.4)

RSP engine c.nnecting to the two fuel oil storage tank fill lines 7EG3-25 and 7EG3-26 respec_tively.

'76.120.?.

AUG 0 2 M Describe the normal function and operation of drain lines 7EGl-43 and 7EGl-44.

Should these lines be in normal use during diesel engine operation we require them to be designed to seismic Category I, Class 3 requi rements.

However, if they are not used during engine operation and are used only for house cleaning purposes, valves 3EG-V611 A, and 3EG-V630A, 3EG-V621B and 3EG-V629B should be shown in the normally closed position.

In addition we require the portion of these drain lines connecting to the fuel oil storage tank fill lines up to check valves 7EG-V624 and 7EG-625 and including a recom ended backup shut-off valve to be installed ahead of each check valve to be designed to seismic Category 1, Class 3 requirements.

Revise figure.9.5-3 accordingly.

040.59 In your response to Question 040.27, you state that periodic inspection and (9.5.4) testing of the diesel fuel oil will be done per Technical Specification 4.8.1.1.2 which will be revised upon your review of differences between ASTM D975-59 and D975-74 and other considerations.

You should compare AST!i D975-59 to ASTM D975-78, Federal Fuel Oil Specification VV-F-800b (April 12, 1975) or the requirements of the diesel generator manufacture, if they are more restrictive, and not ASTM D975-74.

The most stringent requirements should be met.

• i81203

AUG t 21979 040.60 Your answer to response 040.28 is not. complete.

You have addressed (9.5.4) only a portion of nur concern. What precautions have you taken in your

- design of the fuel oil piping located in the diesel generator room with regard to possible exposure to ignition cources such as open flames and hot surfaces.

(SRP 9.5.4, Part III, item 6),

040.61 Describe the sources of electri: nower for the fuel oil storage tank trans-(9.5.4) fer pumps and the standby jacket wcter circulating pumps, and give the motor characteristics, i.e., operating voltage, phase (s) and frequency.

Revise the FSAR Section 9.5.4 accordingly.

040.62 In your response.to request 040.32 you stata that the standby diesel engine design is'such that it can operate at no load'and full speed for seven days without degradation of the engine.

State the make and type of engine and the design features which enables the engine to operate at no load and full speed for seven days with^ut degradation of perfomance and reliability.

ProYide the manufacturer's test results which verify the above cited capability,

?

'.61204

. MG 0 21979

.40.63 You state in section 9,5,6.3 that each diesel engine is provided with 9.5.6) 15 P redundant air sta % systems each containing a compressor, air dryer, air

' receiver, and associated piping and valves.

You also state that each air receiver is sized to store enough air to crank and start a cold engine three times without the use of the air compressor.

This is not acceptable.

We require, as a minimum, each of the redundant starting systems for each standby diesel generator should be capable of cranking a cold diesel engine five tirnes without the use of the air compressor.

Revise your design accordingly.

(SRP 9.5.6, Part II, item 9b.)

J40.64 Provide additional discussion of the diesel engine starting sequence and (9.5.6) procedure used for nontal and accident conditions, In your discussion include the number of air start valves nomally used to start the engine from a cold start, and if both starting air systems are used, Include t.ny supplementary drawings to figure 9.5-5 deemed necessary, Revise FSAR section 9.5.6 accordingly,

40.65 Figure 9,5-5 shows the delineation of the nonenuclear and nuclear

9.5.6) service Class 3 portions of the air start system, The desig~ tion SC3/NNS shown on the air receiver serving the diesel engine right bank air start valves should be reversed.

Correct figure 9.5-5, VO12Ci5

- II -

got@

10.56 Describe the source of power for the air compressor motor for the diesel

.5.6) engine air starting system, Revise section 9,5,6 of the FSAR accordingly, 10.67 You state in section 9,5,6,2 that starting air is supplied to the 9.5.6) turning gear motor during diesel generator standby, Is it your intention to maintain the diesel generators on turning gear during standby condition? Expand your discussion in the FSAR and provide your justifi-caticn for this action, 20.68 Desc. ribe the source of power for the standby motor driven diesel engine 5.5.7) lubrication pump, oil circulating and prelube pump and lube oil electric heater.

Revise section 9,5,7 of the fSAR accordingly, 30.69 Your responses to requests 040.40 and 040,44 are not acceptable, In 10.2) your responses to the above requests you state the turbine overspeed protection system is not safety related, While this is partially true, General Design Criterion 4 " Environmental and Missile Design Bases" of Appendix A " General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, " Licensing of Production and Utilization Facilities,"

requires that structures, systems and components of nuclear power plants important to safety be appropriately protected against the effects of missiles that might result from equipment failures,

'S1206

- 12

• AUG 0 21979 Demonstrate that a high or moderate energy piping failure at the turbine or failure of the connection from the low pressure turbine condenser will

, not damage the turbine overspeed protection system to a degree that could result in generation of destructive missiles and possibly affect safe plant shutdown.

Discuss what protection has been provided to the turbine overspeed protection system equipment, electric wiring and hydraulic lines from the affects of a high or moderate energy pipe failure so that the turbine overspeed protection system will not be damaged to a degree to prevent performance of its intended function.

(SRP 10.2, Part III, item 8 and SRP 1.0.4.4, Part III, item 4).

.40.'70 As explaincd in issue No.1 of NUREG 0138, credit is taken for all valves 10.3) downstream of the Main Steam Isolation Valve (MSIV) to limit blowdown of a second steam generator in the event of a steam line break upstream of the ilSly.

In order to confirm satisfactory performance of such valves following a steam line break, provide a tabulation and descriptive text (as appropriate) in the FSAR of all flow paths that branch off the main steam lines between the MSIV's and the turbine stop valves.

For each flow path originating at the main steam lines, provide the following information:

VS1207

-"~

(us 01 @

a) System identification b) liormal maximum steam flow in pounds per hour.

~

c) Type of shut-off valve (s) and normal position (open or closed) d) Size of valve (s) e) Quality of the valve (s) f) Designcodeofthevalve(s) g) Closure time of the valve (s) h) Source of actuating signal i) Actuation mechanism of the valve (s) (i.e., Solenoid operated, motor operated, air operated diagram valve, etc.)

j) 'totive or power source for the valve actuating mechanism In the event of the postulated accudent, termination of steam flow from all branch lines, except those that can be used for mitigation of the accident, is required to bring the reactor to a safe cold shutdown.

For these branch systems describe what design features have been incorporated to assure closure of the steam shut-cff valve (s).

Describe what operator actions (if any) are required.

If the systems that can be used for mitigation of the accident are not available or decision is made to use other means to shut down the reactor, describe how these systems are secured to assure positive steam shut-off.

Describe what operator actions (if any) are required, If any of the requested infomation is presently included in the FSAR text, provide only the references where the infomation may be found, 70_lEC8

. AUG 02 M

.40.71 In your response to request 040,42 you state a turbine bypass system

,10.4,4) diagram has been added in section 1,7 (E-9270.413-021), Provide this

~

drawing in the FSAR.

781209

AUG o 21979 Request for Additional Information

!.'aterford Steam Elec_tric Station, Unit No. 3 422.0

_ Conduct of 0j_erations 422.3 Identify the person assigned to the position of project engineer (13.1.1.3)

(reporting to the Nuclear Projects Manager).

422.4 It is not clear from your answer to question 422.1 and the resumes

( 13.1.1. 3 )

submitted in subsection 13.1.1.3.2 of vour FSAP how many engineers report to the prcject engineer.

Please identify the engineers who are reporting to the nuclear project engineer.

422.5 It appears frcm your discussion in subsection 13.1.1.3 of your (13.1.1.3)

FSAR and answer to question 422.1 that you do not plan or do not have any home office (offsite) backup support particularly in the areas of chemistry (and radiochemistry), health physics, and instrument and controls engineering.

Please clarify this point.

422.6 Describe the responsibilities, if any, the plant staff shown in (13.1.2.1)

Figure 13.1-2 has for the operation and/or maintenance of Waterford Units 1 & 2.

If any of_ the plant staff does have responsibility for Units 1 & 2, describe this responsibility and the percentage of time you would expect they would spend on Units 1 & 2.

422.7 In Figure 13.1-2, you show several positions for which you state an (13.1.2.1)

NRC operators or senior operators license is a desirable qualification (noted by an asterisk).

Delete all such references to license requirements that are not firm commitments.

422.8 (RSP)

Parts of your answer to question 422.2 are not satisfactory. Listed (13.1.3.1) below in the left hand column are those position titles from your answer to question 422.2 for which we find the minimum qualification requirements not satisfactory. The right hand column describes our position relative to the minimum qualification requirements for those positions:

Position Title Minimum Qualification Requirements Engineering Technician -

ANSI N18.1-1971, Section 4.5.2 Chemical and Environmental Engineering Technician ANSI N18.1-1971, Section 4.5.2 Engineering Technician -

ANSI N18.1-1971, Sect'on 4.5.2 Nuclear Engineering Technician -

ANSI N18.1-1971, Section 4.5.2 Support Acti::ities Engineering Technicion -

ANSI N18.1-1971, Section 4.5.2 Quality Control 78tuo

AUG 0 21979.

Associate Engineer -

ANSI N18.1-1971, Section 4.5.2 Engineering Technician -

Training Associate Engineer -

ANSI N18.1-1971, Section 4.5.2 Engineering Technician -

Mechanical Associate Engineer -

ANSI N18.1-1971, Section 4.5.2 Engineering Technician -

Electrical Associate Engineer -

ANSI N18.1-1971. Section 4.5.2 Engineering Technician -

Instrument and Control Engineering Technician -

ANSI N18.1-1971, Section 4.5.2 Ccmputer/ Electronics Operations-Associate Six years of power plant experience Utility Engineer of which a minimum of two years shall be nuclear power plant experience.

He should be a senior licensed opera tor.

Health Physics Engineer Revision 1 to Regulatory Guide 1.8 for the position of Radiation Protection Manager.

Revise your FSAR to conform to these positions.

422.9 (RSP) You state in section 13.1.2.2.2 that your minimum shift crew (13.1. 2. 2 )

composition for various modes of reactor operation is discussed in detail in section 16.1.

In section 16.1 you state that the ninimum shif t crew composition for plant operation will be one Senior Licensed Operator, one Licensed Operator, and two un-licensed Operators.

This is not satisfactory.

It is our position that your minimum shift crew composition for operation include one Senior Licensed Operator, two Licensed Operators, and two unlicensed Operators.

Revise your FSAR to conform to this position.

422.10 Provide resumes of the people filling the positions of Associate /

(13.1.3.2)

Utility Engineer-0perations, Health Physics Engineer, Nuclear Engineer, Quality Control Engineer, Instrument-Control Engineer, and the remaining Operations and Maintenance Supervisors.

422.11 (RSP) You state in Amendment 3 to your FSAR Section 9.5.2 on your fire (9.5.3) protection program, section 3.1.2, that each Emergency Fire Team will consist of four persons.

It is our position, as stated in SRP 13cl.2, Revision 1, that each Emergency Fire Team consist of five people.

Revise your FSAR to conform to this position.

781211