ML19260E046
| ML19260E046 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/22/1980 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | Stampley N MISSISSIPPI POWER & LIGHT CO. |
| References | |
| 800133, NUDOCS 8002130193 | |
| Download: ML19260E046 (36) | |
Text
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Distribution NRC PCR TMurphy Jin 21980 E8EI?t gle nst i
P LWR #2 File RDenise DFRoss DBVassallo IE(3)
NSIC coctet Nos. 50-416 SAvarga ud 50-417 FJWilliams RLBaer S(16)
TCHoughton JLee Mr N. L. Stapley, Vice President RMattson Production and Engineerin9 SHanauer Nississippi Powr and Light Company JKnight
. O. Box 164C-RTedesco Jacksong Mississippi 39205 RDeYoung VMoore Cear Mr. Stapley:
WKreger
SUBJECT:
RECUESTS FOR ADDITIONAL INFORMATICN (Grand Gulf Nuclear Station, Units 1 and 2)
As a result of our review of the information contained in the Final Safety Analysis Report for the Grand Gulf Nuclear Station, Units 1 and 2, we have developed the enclosed requests for additional inforttetion. Incluoed are questions on the Fire Protecticn Program from the Quality Assurance Branch and the Auxiliary Systems Branch, a staff position concerning full lead testing of 4160-480 volt transformers from tne cuality Assurance Branch, and electrical and mechanical questions from the Power Systems, Branch.
We request that you amend your Final Safety Analysis Report to reflect your responses to the enclosed recuests by April 30, 1980.
If you cannot meet this data, please advise us of the date ycu can ccet as soon as possible so that we may consider the need to revise our review schedule.
Please contact us if you desire any discussion or clarification of the enclosed requests.
Si ncerely, original sig:ied17 Tich.:."'. V T*
Robert L. Baer, Chief Light Water Reactors Branch No. 2 Division of Project Management
Enclosure:
ns0 Requests for Additional 9
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4G OFFICEi 1979 289 369 NRC FORM 318 (9 76) NRCM 0240
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8002130
Mr. N. L. Stsapley JAN 2 21980 Mr. N. L. Stampley Vice President - Production Mississippi Power and Light Company P. O. B ox 1640 Jackson, Mississippi 39205 ces: Mr. Robert B. McGehee, Attorney Wise, ^Jrter, Child, Steen and Caraway P. O. Box 651 Jackson, Mississippi 39205 Troy B. Conner, Jr., Esq.
Conner, Moore and Corber 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Mr. Adrian Zaccaria, Project Engineer Grand Gulf Nuclear Station Bechtel Power Corporation Gaithersburg, Maryland 20760
013.1 GENERAL You state in your Fire Hazards Analysis how various safety-related cable trays, conduit and equipment are separated by distance from its redun-dant counterpart, and the criteria that were used to establish barriers between these redundant trains.- However, it is essential that your fire hazards analysis also include the effects of postulated exposure fires involving permanent and/or transient combustibles (exposure fires) on systems, circuit cable trays or equipment required for safe plant cold shutdown which are separated only by distance (no fire barriers and with redundant trains 20 ft. or less from each other, as you listed in page 9 A-21 o f the FHA).
Redundant trains within 20 ft. of each other, as a minimum, will be required to be protected by a hai f hour fire rated barrier as well as area automatic sprinklers.
This does not mean that in some instances, redundant trains separated by more than 20 ft. will not require additional protection.
In the fire hazards analysis your need to demonstrate assuming, failure of the primary suppression system, a fire on installed or transient combustibles will not result in the loss of capability to achieve safe cold failure of the primary suppression system, a fire on installed or transient combustibles will not result in the loss of capability to achieve safe cold shutdos.n. Where this cannot be demonstrated, an alternate means of assuaing safe plant shutdown (cold shutdown) should be provided. Alternate shutdown will most likely be required for areas such as the upper and lower cable spreading rooms, and rooms 0C 205 and OC 208.
9 m.
' Demonstrate:
(1) Safe shutdown from the main control room where a fire disables any re ote shutdown panels, or any safe shutdown equipmen-inciucia.;
conduit / cable trays controlled frcm remote locations.
(2)
Safe shutdown frcm remote locations when the main control room is uninhabitable due to a fire or when fire disables safe shutdown equipment or cables in the cable spreading areas or rooms listed on your FHA page 9A-21.
Alternate stutdown capability need only be provided for the essential ins rumentation, controls and equipment necessary to bring the plant to a hot standby condition.
Fire damage to systems necessary to achieve and maintain cold shutdown should be limited so that repairs can be made an: cold snu ::an c nditien achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Attached (Enclosure l', are our guidelines for alternate shutdown systems.
01 3.2 Page 3A-il, 3.0 Scope You state that only areas in seismic Category I structures were reviewed.
Sh:w -hat any fire (transformer fire, hydrogen fire, storage fire, :::,;
ou side of these seismic Category I structures will not prevent the plant frem achieving safe cold shutdown.
013.3.
Page 9A-59, Item 7.2.2.10 It is our position as stated in Section C.6.g of BTP APCSB 2.5-1 tha- -he loss of the ventilation system to any safety-related battery room should
- e alarmed and annunciated in the control room.
3 013.4 Page 9A-60, Item 7.2.2.11 You state in your FHA that, "the complete operative loss of the emergency remote shutdown panels due to a possible fire could impair safe-shutdown capability."
It is our position that safety-related circuits in the control room and remo e snutdown panels be isolated from each other such that the complete loss of one set of panels will not prevent from achieving safe shutdown.
Show how you will comply with this position in all affected areas of the plant.
013.5 Page 9A-73, Item 7.2.2.43 (a)
Provide details on the type and number of. portable Class A and Class C fire extinguishers in the control room complex.
(b)
It is our position that you comply with Section F.2 of BTP APCSB 9.51, Appendix A, in that the concealed ceiling space should have fixed automatic total flooding Halon protection.
(c)
Verify that the outside air intake (s) for the control room ventila-tion system are provided with smoke detection capability to alarm in the control room to enable manual isolation of the control room ventilation system and thus prevent smoke from entering the control room.
013.5 Page 9A-74 Power Generation Control Complex (PGCC)
Verify that you comply with the interface requirements of NECO 10466,
" Power Generation Control Complex Cesign Criteria and Safety Evaluation."
01 3.7 Page 9A-82, Item 7.2.3.2 Provide an automatic sprinkler system and a fire detection system to pro-tect each reactor coolant pump. Verify that an adequate drainage system will be provided for all the runoff water.
013.8 Table 9A-1, Sheet 5, Item D.1 (a)
It is our position that you compTy with Section C.5.a.1 of BTP APCSB 9.5-1 in that area fire detection systems should be provided for all areas that contain safety related equipment.
Show how you will comply with this position.
(b)
It is our position that you corply with Section E.1.a of STP APCS 3 9.5-1, Appendix A, in that each fire detection system should be equipped with an audible and visual alarm and annunciate in the control
- room, t.ocal audible alarms shot 1d also be provided.
Show how you will comply with this position.
013.9-Table 9A-1, Sheet 6, Item D.l(j)
~
Substantiate the fire resistance capability of the following items as they pertain to safety-related areas er nigh hazard areas by verifying that their construction is in accordance with a particular design that has been fire tested.
Identify the design, the test method used and the acceptance criteria:
(1 ) P.ated fire barriers, including floor and ceiling construction and their supports; (2)
Fire dampers and fire doors, as well as how they are installed in the ventilation ducts that penetrate rated fire barriers of safety-related areas; and (3)
Fire barrier penetration seals around ducts, pipes, cables, cable trays and in other openings (e.g. concrete joints sealers and fillers).
Verify that all seals are of the thickness specified in the tests, and that cables and cable trays are supported in a manner similar to supporting arrangements used in any tests.
013.10
-Table 9A-1, Sheet 7, Item D.3(c)
You state that water spraying onto cable trays would cause electrical faults at the cible termination points.
It is our position that you comply with Section D.3.c of BTP APCSS 9.5-1, Appendix A, in that cable trays should be designed to allow wetting down with deluge water without electrical faulting (i.e. use weatherproof terminal boxes or cabinets, if necessary).
013.11 Table 9A.1, Sheet 13, Item D.5 It is our position that you comply with Section 0.5la) of BTP APCSB 9.5-1, Appendix A, in that a fixed emergency lignting system con 31 sting of sealed beam units with individual (8-hour minimum) battery power supplies be installed in all areas required for safe shutdown operations, including access and egress routes.
- /erify that you will comply with our position.
013'.12 Table 9A.1, Sheet 14 Item E.l(d)
Demonstrate that primary and secondary power for the alarm system can be maintained by:
a.
Using normal offsite power as the primary suoply, with a 4-hour battery supply as the secondary source, b.
Having tne capability for manual connection to the Class lE emergency power bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of ~ loss of offsite power 013.13 Table 9A.1, Sheet 14, Item E.2(e)
Verify that the fire pumps can provide, in accordance with 3 0 9.5-1 Section 5.b.5, the largest firewater flow and pressure (based on 500 gpm for manual hose streams plus the largest design demand of any sprinkler or deluge system as determined in accordance with NFPA 13 or NFpA 15) with the largest fire pump out of service.
013.14 Table 9A.1, Sheet 16, Items E.4 and E.5 For all Halon and CO suppression systems provide the concentration and 2
soak time.
013.15 Table 9A.1, Sheet.19, Item F.14 Verify that the radwaste building is separated from other areas of the plant by fire barriers having at least three-hour fire ratings.
i 013.16 Fire Protection program procedures - General Verify that the plant fire brigade:
(1) Consists of five members during all shifts.
(2)
Con fi n: that the fire bri;ade provides for local fire department participation in drills at least annually.
013.17 Page 93-24, Item 2.9.4,b.1 Two spare air bottles for each breathing unit are insufficient.
It is our position that you comply with Section D.4.h of STP APCSB 9.5-1, Appendix A, in that, in addition to the two spare air bottles, an onsite six hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned.
If compressors are used as a source of breathing air, only units approved for breathing air should he used, compressor s;. auld be operable assuming a loss of offsite power.
Special care must be taken to locate the compressor in areas free of dust end containments.
Indicate how ycu will comply with this position.
/
& c l..r s e 1
STAFF POSITION SAFE SiiUTCCWN CAPABILITY O
Staf' C:ncern Curing the staff's evaluation of fire prctection crograms a:
c:erating clants, one or more specific clant areas may be identified in anicn :ne staff cces not have adequate assannce tnat a postula:ed fire will not damage both redundant divisiens of snutdown systems.
~his lack of assurance in safe snutdcwn cacability nas resulted fecm one or both of de follcwing situatiens:
Case A: The licensee.has not acequately identifiec the systems arid ccmcenents recuired for safe shutccwn and their loca icn in scecific fire areas.
Case B: The licensee has not demonstrated that the fire protecticn for specific olant areas will prevent damage :: both redundant divisions ci' safe shutdenn c:mponents identified in these areas.
For Case A, the staff has required that an adecuate safe shutdcwn analysis be cer#crmec.
3is evaluation includes the icenti#ication of me systems required #ce safe snutdown and tne locatien of One sys;em c:ecenents in =e clara. Where it is determined by dis evaluation tna; safe snu::cwn ccmcenents of be:n redundant divisiens are located in =e same # ire area, the licensee :s recuired to cemenstrate ma: a cstulated fire will not damage born divisions or :revice altamate snu: cwn cacacility as in Case 3.
.f..b For Case 3, 2e staf' ma have required dat an altemate snutdcwn cacability be provided "- is inde endent of *ne area of concern or -he licensee may have peccesed such a cacacility in lieu of certain additi:nal fire :rctaction modifications in the area.
De s:ecific modifications asscciated with tne area of c:ncern alcng witn
- =er systems and ecui: ment alreacy indecendent of me area form te alternate snut:cwn ca:acility.
Fcr eacn plant, ce mocificati:ns neecee and
=e ::mcinaticns of systams wnich provide 2e snu:dewn func:icns may :e unicue for eacn critical area; hcwever, the snu:dcwn functions crevidec sncula maintain slan: = ara:ne:ers within he bcunes of de limiting safety c:nsecuences deemed ac:ectable for de design basis event.
Staf' positien e
Safe snutdown caoacility should be demonstrated (Case A) or alternate shutdcwn cacability provided (Case 3) in ac:crdance with
- ne guidelines croviced :elcw:
- 1. :esien Basis Even:
Be design basis event for c:nsidering the need for altemate snu::cwn is a cs ulated fire in a scecific fire ama c:ntaining g
recuncant safe snu:ccwn cables /ecuipment in ciese proximity wnere it nas been determined =at fire protection means cannot assure
^
na sa'e shut:cwn capability will be preserved. T.to cases should be considered: (1) offsite pcwer is available; and (2) offsite pcwer is not availaole.
. 2. Limitinc Safety Ccnsecuences and Recuime Shutdcwn Functions 2.1.1o fission product boundarf integrity snall be affected:
a.
No fuel clad damage; b.
No rupture of any primarf c::lan: bcundarf; c.
No rupture of the c:ntainmen-boundary.
2.2 The reactor coolant systam pr0 cess variables shall be within these predicted for a loss of ner al ac pcwer.
2.3 The alternate shutdewn capability snall be aola to achieve and maintain succritical conditions in :ne reactor, maintain reactor coolant inventor /, achieve and maintain not standby
- conditions (liot shutdcwn" for a SWR) for an extended period of time, achieve cold shutdewn* conditiens within 72 hcurs and maintain cold shutdcwn conditiens thereafter.
As defined in the Stancard Tecnnical Scecifications.
- 3. :erfor ance Goals 3.1 The reactivity c:n:rch function snali be :acaole of achieving and maintaining cold shutdewn reactivity c:nditions.
3.2 The Nac: r c:clant makeuc function snall be cacable of maintaining :ne reactor c:olant lecel accie -he top of the core for SWR's and in.he pressuri:er for pWR's.
3.3 The reactor heat removal functicn snall be cacamle of acnieving and maintaining decay heat removal.
3.4 3e arecess monitoring function snall be cacable of providing direct readings of the : recess variaoles necessary to :erfor n and centrol One a:ove functions.
3.5 The succorting function-shall be ca:acle of provicing -he Or cess :coling, lubrication, e :. necessary :: ;ermi t ne operaticn of the equi: ment used for safe snut:cwn by One systems icentified in 3.1 - 3.2
.3.6 The scuipment and systems used. acnieve and maintain hot stancby conditions (hot snat0cwn for a SWR) sneuid be (1) free of fire damage; (2) ca:able of maintaining such conditions f:r an extended tine :eriod longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the equipment recuired to ac.ieve and maintain cold shutccwn is not available due t: fire camage; and (3) pcwered by an ensite emeagency : wer system.
3.7 The equi: ment and systers used o achieve and maintain cold snutdcwn c:nditicns shculd be ei:n-te free of fire damage or 7
- ne fire damage o such systems snculd be limited such
.h that repairs can be made and c:ld shutdown c:nditions acnievec within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
E ui=ent and systems used crior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire should te ocwered oy an ensite eergency power system; :ncse used after 72 neurs gay be pcwered by a
s
offsite pcwer.
3.3 These systems need not be designed to ( ) seismic category I criteria; (2) sin,gle failure criteria; or (3) cope, witn c ner plant accidents sucn as pipe breaks or stuck valves
( Accendix A STP 9.5-1), except those scrtiens of these systens wnich interface with or impac: existing safety systems.
- 4. :'AR Ecui ment :-enerally Necessary For Hot Standby (1)
Reactivity Centro 1 Reactor trip capabili.ty (scram). Scration ca: ability e.g.,
enarging ; ump, makeup. pump or hign pressure injection pumo taking sucticn from concentrated borated water suoplies, and letdown system if. required.
(2)
Reactor C:clant Makeue Reactor coolant makeuo cacacility, e.g., cnarging :um:s Or the hign pressure injection Oumes.
Power coerated relief valves may be required 50 reduce pressurt to allcw use of the hign :ressure injection pum:s.
- 3)
React:r C clant System Pressure Control Reactor :ressure control cacacility, e.g., charging :umos v
or pressuri:er heaters and use of the letdcwn systems if required.
(a)
Decav Weat Removal
- ecay heat removal capability, e.g., Ocwer c:erated relief valves (steam generator) or safety relief valves for neat removal with a water sucoly and emergency or auxiliary feecwater cumos for makeuo to the steam ;enerator. Service water Or Otner umes may be required to :rovide water for auxiliary
'eed :uro suction if the condensate st: rage tank cacacity is
".ot acecuate for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
anitorine Instrumentation
-(5) 2-ecess v cass monitoring cacacility e.g., pressuri:er cressure and i _.el, steam generator level.
(6)
Succort.
The ecuipment required to succort c eration of the above described snutdewn ecui: ment e.g., comoonent cooling 4ater service water, etc. and ensite pewer sources ( AC, DC) with
- ncir associated electrical distributien system.
-4
- 5. FWR Ecuicment Generally Necessary ce Cold Shutdewn*
/
(1)
Seactor Coolant Svstem Pressu e Reducticn :: Residual West Removal System ( RHR) Cacao:11:y Reactor coolant system cressure reducticn by coolecwn using steun generatnr pcwer coerated miief /alves or atmospneric dump valves (2)
Cecay Heat Removal removal Cecay heat remc/al capability e.g., resicual nea:
system, ccmcenant cooling water system and service water system to removal heat and maintain cold snu:cewn.
~
(3) Succor Supcort capability e.g., ensite power scurces ' AC 10C) or offsite after 72 hcurs and the associated electrical distribution system to sucoly One acove equipment.
E uicment necessary in addition to t. a alreadv crovided :: *aintain 9
not standby.
- 5. iWR Icuicment Generally Necessarv For Hot Shuttewn
'. I ',
Reactivity Contrcl Reactor trip capability (scram).
(2) Reactor Coolant Makeuo Reac cr coolant inventory makeuc cacability e.g., reac:ce core isolatien cooling system (RCIC) or :ne hign pressure :colant injectica system (HPCI).
(2)
- eac:ce Pressure Control and Decav Heat Removal
- ecressuri:atien system valves or safety relief valves for dumo to the suceression ;ool. The residual heat removal system in steam condensing mode, and service water system may also be used for heat removal to the ultimate heat sink.
(a)
Suceression Occi Ccolina Residual heat removal system (in suopression cool ccoling mcde) service water system to maintain hot shutdown.
(5) ?rccess Monitorina Process menitoring cacacility e.g., reactor vessel level and cressure and sucoression cool temcerature.
L-o
. 7 s.
(G Suecor:
Su: port capability e.g., ensite ;cwer source (AC 1 DC) and neir associated distributicn systems :: Orovide for the shutdown equipment.
- 7. SWR Ecui ment Generally Necessarv For Cold Shutdown
- At this point the ecui: ment necessary for hot snutdown has reduced de primary system cressure and temperature to where the RHR system may be placed in service in RHR c: cling moce.
(1)
Cecav Heat Removal Residual heat removal' system in the MiR cooling mode, service water system.
(2) Succort Onsite scur:es (AC & CC) or offsite after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and their associated distributien systems :: ;rovide for shutccwn equipment.
E:ui: ment provided in aediticn Oc that for acr.ieving het shut cwn.
- 3. Infor atien Recuired cr Staff :eview
,w.r (a)
Cescription of the systems or ;ortiens Onereof used.o Or0 vide the shutdcwn capability and modifica icns recuired to acnieve One alternate shutdcwn cacacility if recuired.
~
(b)
System design by drawings which shcw nomal and alternate snu:cewn centrol and pcwer circuits, locatien of ccmpenents, and nat wiring whicn is in the area anc the wiring wnich is cut of the area :nat recuired the alternate system.
s :l
'ierification that enanges to safety systems will not
- egrace safety systems.
(e.g., new iscla:f cn switenes anc centrol swit:hes snculd meet design criteria and standar s in FSAR for electrical ecuicment in the system that *.he switen is to be installed; caoinets :nat tne swit:nes are :: be mcunted in snould also meet the same criteria (F5AR) as other safety Slated cacinets and
- anels; to avoid inadvertent isolation from tne control recm, the isolation switenes shculd be keylocked, or alarmed in the control recm if in the " local" or " isolated" :csition ;
- eriodic checks snculd be made to verify switch is in the orcoer position for nomal oceration; and a single transfer switch cr otner new devi:e snculd not be a scur:e for a single failure to cause ! css of mduncant safety systems).
'c) 'lerificatien :na: wiring, inclucing Ocwer sources for tne
- ntrol circuit and ecui: ment oceration for :ne alternate
~
shutdcwn method, is incecencent of ecuiement wiring in
- ne area Oc be avoided.
i e
i
- . h (a) Verification that alternate shutdcwn ;cwer sources, including al' treakers, have isolation devices cn : ntrol cir:uits
- nt: are routed througn the area to be avciced, even if :ne areaker is to be cperated manually.
( *)
Verifica:icn that licensee procedure (s) have been develcced whica describe one tasks to :e :erformed to effect the snutdcwn e: hod. A sumn.ary of these precacures shculd te reviewed by tne staff.
(g) Verification that spare fuses are !vailable for control circuits wnere nese fuses may be recuired in suoplying pcwer to control circuits usec for the shutdcwn method and may be blown by the effects of a caole spreading r:0m fire. The scare fuses should be located convenient
- :ne existing fuses. The shutdown peccedure snculd inform the caerator :o check tnese fuses.
(h) Verification :nat the man:cwer -ecuired to :erform the shutdown func:icns using :ne pr:cecures of (f' as well as to r0 vide fire brigade Tem:ers :: 'i gn: :na ' ire is availacie as required by :ne fire origade tecnni:al s:aci'ica:icns.
7eri#ica:icn that acecuate accectance tests are :erformed.
ess snculd verify tha:: ecui:. men: c: era:es fr:m the lccal ::ntrol staticn wnen the :ransfer or iscla:icn switen is 31 :ed in the " local * :ositien and :nat tne ecuipment cannc. be acerated frem tne con:rol reem; and inat acuic-men t :erates trem the c:ntrol recm but cannot be ocerated a: the iccal control staticn wnen the transfer or isolation switen is in the " remote" posi; ion.
(j)
Te:nnical Specifications Of the surveillance recuirements ard limiting ::ndi:icns 'Or Ocera:icn for tha; ecuitment 90: 1 reacy OcVered by existing Teca. Scecs.
ce examole, i' new isola:icn and c:n:rol swit:nes are adced Oc a service wa er system, the existing Tech. Scec. surveillance requi re-ments n :ne service wa:er sys:em snculd add a statement similar to One felicwing:
"Ever/ :nird Oura test shculd also veri #y Ona the umo starts ' rem :ne alternate shu:::wn s:stion after moving all servic: water system isolation switenes :: ne local c:ntrol positicn."
(k) Verifica:icn that the systems availa' te are adecuate to :erf:rm tne necessary shutdown ' unctions.
'.ne functices recuired
~
sneuld be cased en prev cus analyses, if Ocssible (e.g.,
in :ne 5AR), suen as a icss cf normal a.c. pcwer or shut:cwn
- n a Grouc I isolation '5WR).
The ecui ment recuired 'Or :ne
.?q alterna e ca:acil'ty snculd be :ne lame er ecuivalent to
~ S,).l
- na: relied on in :ne accve analyti:.
%9 9
4
r i
- ~
(1) Verifica icn that repair precedures 'Or cold sr.
- syste s are caveicoed and material for maain is main:a
- n si:a.
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9 6
5
421.0 Cuality Assurance 421.1 The Quality Assurance (QA) pr:gran for fire protection should (App. 9A) be under the management control of the QA organization.
This control consists of (1) formu ating or verifying that a fire protection QA program incorporates suitable requirements and is acceptable to management responsible for fire protection; and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, and audit.
Revise Section C of Table 9A-1 in Appendix 9A to clarify that the QA program for fire protection is under the management control of QA, or provide an alternative position for the staff's evaluation.
421.2 Mr. Vassallo's letter of August 29, 1977 on fire protection (App. 9A) provides supplemental guidance on QA. Modify Section C of Table 9A-1 in Appendix 9A to be responsive to the latest supplemental guidance on QA for fire protection or provide an alternative for the staff's evaluation.
'de note that if the fire protection QA prograc criteria are met as part of the QA program described in topical recort MPL-TCp-1A, " Operational QA Manual," which meets Appencix B to 10 CFR 50, i' is not necessary to submit a detailed description for t1RC review.
422.0 Conduct of Ooerations 422.16 Identify the upper level offsite management position (s) which (App.9A) has overall responsibility for the formulation, implementation, and assessment of the effectiveness of the station fire protection program.
422.17 While the plant Manager is generally responsible for all activities (App. 9A) at the facility, describe any further delegation of these responsi-bilities for the fire protection program such as training, maintenance of fire protection systems, testing of fire protection equipment, fire safety inspections, fire fighting reocedures, and fire drills.
422.18 Describe the authority of your Shift Fire Chief relative to that (App. 9A) of your Shift Supervisors.
422.19 Describe the composition of your shift fire brigade in terms of (App. 9A) numbers and job titles.
O
423.38 It has come to our attention that although some applicants had committed to Regulatory Guide 1.68, they did not intend to conduct full-load tests of some 4160-480 volt transformers supplying potar to vital buses. Your test description in FSAR Chapter 14 does not contain suf ficie: t detail for us to determir.e if you intend to conduct such a test.
It is our position that full-load tests of vital buses must be conducted including all sources of power supplies to the buses.
Modify your test description to indicate that this testing will be conducted in accordance iv ith Regulatory Guide 1.68.
040.80 Section 8.1.4.1.b of the FSAR says that there are three (3) physically (8.1) independent circuits from the 500KV switchyard to the onsite electrical distribution system. Figure 8.2-3 indicates that there are only two (2) circuits from the 500XV switchyard.
Cla ri fy.
040.81 In the first paragraph of FSAR Section 8.1.4.3 a " spare set of B0P trans-(8.1) formers" are mentioned.
Are these in addition to those shown in Figure 8.1-1 or do you mean that these are included in the four B0P transformers shown (such as BOP XFMRS #12A and 128)?
N0.32 In FSAR Section 8.1.4.2.3.f it is stated that " provision is made for con-f3.1) trol (of the HPCS power syscem) frcm the control room and another locatio t external to the contr:1 rcom".
Identify the other location.
0 0.83 SRP Section 8.1, III, 5, Revision 1, requires that criteria applicable to (8.1) the design should be identified and the degree of conformance defined.
SRP Table 8-1 lists applicability of criteria to each FSAR section.
Each section of your FSAR Chapter 3 should mention conformance (or exception) to all of the criteria of SRP Table 8-1.
%is may be done by a single comprehensive table in.:SAR Section 8.1 which would be referenced by the subsequent sections. Where exceptions, relative to tne electrical power systems, are taken, these should be specifically noted and referenced to a detailed explanation.
. 040.34 In the table of contents of Appendix 3A, RG 1.93 is noted as "not (8.1)
App. 3A addressed in FSAR...." and RG 1.32 is no ed as N/A (page 3A-4).
- However, in FSAR Section 8.1.4.4.1 and 3A/1.32-1, compliance with Regulatory Guides 1.93 and 1.32 is stated. Correct Appendix 3A accordingly.
040.85 GDC-17 states that the safety function for each of the offsite systems (8.1)
(assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that: (a) specified accep-table fuel design limits and design conditions for the reactor coolant pres-sure boundary are not exceeded as a result of anticipated operational occurrences and (b) the core is cooled and containment integrity and other vital functions are maintained in the event of the postulated accidents.
We require that the adecuacy of the transformers (service and ESC) be verified by the voltage analysis at transient and steady sta 9 This is in order to assure that the transformers are capable of starting and operat-ing the loads with the worst combined condition (the minimum expected grid voltage and the maximum combined loads).
040.36 SRP Section 8.1, III, 1 states that FSAR grid
... descriptions shoul:
u.2) state whetner facilities are existing or planned, if planned, the respec-tive completion dates should be provided." Provide the completion status of the 500KV and ll5KV overhead lines.
040.87 Regulatory Guide 1.70, Revision 3, Section 8.2.2 specifies that the appli-(3.2) cant should " provide infomation and a discussion of grid availability, including the frequency, duratica and cause of outages".
For the outage statistics given in FSAR Table 8.2-1, furnish the following information:
a) cause of each outage b) duration of each outage c) update the table to the present time
040.88 In FSAR Section 8.2.1.2 and Section 8.2.1.4 tne acronym "NAPSIC" is used.
(8.2)
Explain the meaning and the function of NAPSIC.
Explain how you comply with Regulatory Guide 1.9, revision 1, paragraph 040.89 (0.3)
C.9 with respect to first out alam indication.
C40.90 The chosen voltage sepoint and time delay associated with the undervoltage (8.3) protection must assure that the safety related equipment is not subjected to a voltage below that recomended by the manufacturer and ANSI C84.1-1973 for a period of time long enough to cause malfunction and/or thermal Y
damage. We require infomation regarding startingand operating characteristics, and themal capability of the safety related equipment in terms of the voltage current and time.
C40.91 In the FSAR paragrapn E.3.1.1.4.2.10 it indicates that generator dif-(8.3) ferential current and engine overspeed are the only emergency ?rotective devices for the HPCS diesel. Figure 8.3-8 of the FSA.4 shows that lube oil pressure low (2 of 3 logic) and case pressure high (2 of 3 logic) also operate protective interlocks during an emergency for division I and II.
If this logic diagram also applies to the HPCS diesel explain the discrepancy or provice the icgic diagram for the HPCS diesel.
0 0.92 FSAR Section 8.3.1.1.5.1 in describing the RPS power supply states that (3.3)
...the power feeds to independent divisions are physically separated and feed four redundant buses." FSAR Figure 8.3-11 shows only two buses, "A" and "B".
Correct the contraciction.
-4 040.93 In FSAR Table 8.2-3 " Load Flow Studies and Table 8.2-4 " Stability (8.2)
Studies", the results of analysis of contingencies and faults are statet as "no problem" and " stable". Define these terms more explicitly so as to provide greater assurance of the results of the analysis. Provide mini-mum or maximum voltage, transient durations, and other quantitative values to substantiate the conclusions drawn in Table 8.2-3 and 8.2-4.
040.94 Clarify the description in FSAR Section 8.2.1.2, regarding alarms for the (8.2) various problems that could occur involving the switchyard ' auxiliary sys-tems.
Identify the alarm indication and its location.
- 40. 95 In Section 3.2.1.1 on page 8.2-2, it is stated that "The ll5KV line does l3.2) not cross over or under any of the 500KV offsite power supply lines...".
However, from Figure 5.2-2, it appears that the 500KV line from Franklin to Grand Gulf does cross over the ll5KV line between Natche: " E.S.
and Fort Gibson. Confirm that it does or does not cross. Provide further information on grid stability at Grand Gulf if the above mentioned 500KV line fell on top of the ll5KV line.
240.96 FSAR Secticn 8.3.1.1.a.1 : age 8.3-11 provides information on controls for
'3.3) diesel generators. Clarify the statement concerning the number and loca-tion of the local control stations for each diesel generator.
030.97 Describe the actions and operations you take to assure that a diesel generator (3.3) will respond to an automatic start,ignal after completion of and during a periodic test. Address the following:
Governor control settings Monitoring of Diesel Generator Sync-Speed setting
040.102
- n FSAR Section 8.3.1.1.4.1.1.a.2 page 8.3-12, it a;; pears that the resistive (8.3) load was omitted from the tabulated data in test 2; clarify. Also, provide the analytical method for obtaining the cumulative loads.
040.103 he load shedding and sequencing reset operation is mentioned in Section (8.3)
- 2. 3.1.1.3 page 8.3-5.
Regarding restoring of motors and valve operations following loss of offsite power, clarify and expand the description regard-ing reset operaticn since you state that, " reset is not a function of the presence or absence of bus voltage".
040.104 In Table 8.3-5 of FSAR, it is stated that the diesel generator start (8.3) signal is given at time 3 seconds following LOCA.
In Table 6.3-1 the diesel generator start signal is given a tir.e o seconds.
Correct this discrepancy.
0a0.105 Operating experience at ce.tain nuclear power plants which have two (S.3 RSP cycle turbocharged diesel engines manufactured by the Electromotive Division (EMO) of General Motors driving emergency generators have ex:erienced a significant number of turbocharger mechanical gear drive fail ures. The failures have occurred as the result of running the emergency diesel generators at no load or light load conditions for extended periods. No load or light load operation could occur during periodic ecuipment testing or during accident conditions with availability of offsite power. When this equipment is operated under no load conditions insufficient exhaust gas volume is generated to operate the turbocharger.
As a result the turbocharger is driven mechanically from a gear drive in order to supply enough combusion air to the engine to maintain rated
0d0.102 In FSAR Section 8.3.1.1.4.1.1.a.2 page 8.3-12, it a::ea : taat :..e resistive (8.3) load was omitted from the tabulated data in :est 2; clarify.
Aisc, prcvide the analytical method for obtaining the :umulative loads.
040.103 The load shedding and sequencing reset coeration is mentioned in Section (3.3) 8.3.1.1.3 page 8.3-5.
Regarding restoring of motors and valve operations following loss of offsite power, clarify and expand the description regard-ing resat operation since you state that, " reset is not a function of the presence or absence of bus voltage".
040.104 In Table 8.3-5 of FSAR, it is stated that the diesel generator start (3.3) signal is given at time 3 seconds following LOCA.
In Table 6.3-1 the diesel generator start signal is given at time 0 seconds.
Correct this discrepancy.
040. 105 Operating experience at certain nuclear power plants wnich have two (3.3; RSP cycle turbocharged diesel engines manufactured by the Electromotive Division (EMO) of General Motors driving emergency generators have experienced a significant number of turbocharger mechanical gear drive fail ures. The failures have occurred as the result of running the emergency diesel generators at no load or light load conditions for extended periods. No load or light load operation could occur curing periodic equipment testing or during accident conditions with availability of offsite power. When this equipment is operated under no load conditions insufficient exhaust gas volume is generated to operate the turbocharger.
As a result the turbocharger is driven mechanically from a gear drive in order to supply enough combusion air to the engine to maintain rated
. speed. The turbocharger and mechanical drive gear normally supolied with these engines are not designed for standby service encountered in nuclear Mwer plant application where the equipment may be called upon to operate at no load or light load condition and full rated speed for a prolonged period. The 80 equipment was originally designed for locorctive service where no load speeds for the engine and generator are much lower than full load speeds. The locomotive.turbocharged diesel hardly ever runs at full speed except at full load. The ED has strongly recommended to users of this diesel engine design against operation at no load or light load conditions at full rated speed for extended periods because of the short life excectancy of the turbocharger mechanical gear drive unit normally durnished. No load or ltgnt load operation also causes general deterioration in any diesel e gine.
To cope with the se' are service the equipment is normally subjected to and in the interest of reducing failures and increasing the availability of their equipment BD has developed a heavy duty turbocharger drive gear unit that can replace existtn; equipment. This is available as a replacement kit, or engines can be ordered with the heavy duty turbo-charger drive gear assembly.
To assure optimum availability of emergency diesel generators on demand, Acplicant's wno have on order or intend to order emergency generators driven by two cycle diesel engines marufactured by 80 should be provided with the heavy duty turbocharger mecht.nical drive gear assembly as recorrended by 80 for the class of service encountered in nuclear power plants. Confirm your comoliance with this re:utrement.
. 040.106 Provide a detail discussion (or plan) of the level of training proposed (S.3) for your operators, maintenance crew, quality assurance, and supervisory personnel responsible fer the operation and maintenance of the emergency diesel generators. Identify the number and type of personnel that will be dedicated to the operations and maintenance of the emergency diesel generators and the number and type that will be assigned from your general plant operations and maintenance groups to assist when needed.
In your discussion identify the amount and kind of training that will be received by each of the above categories and the type of ongoing training program planned to assure optimum availability of the emergency generators.
Also discuss the level of education and minimum experience requirements for the various categories of operations and maintenance personr..:1 associated with the emergency diesel generators.
NO.107 periodic testing and test loading of an emergency diesel generator
'3.3) 05p in a nuclear power plant is a necessary function to demonstrate the operability, capability and availability of the unit on demand. Periodic testing coupled with good preventive maintenance practices will assure optimum equipment readiness and availability on demand. This is the desired goal.
To achieve this optimum equipment readiness status the the 1311owing requirements should be met:
.g.
1.
The equipment should be tested with a minimum loading of 25 percent of rated lead. No lead or light load operation will ceuse incomplete combustion of fuel resulting in the formation of gum and varnish deposits on the cylinder walls, intake and exhaust valves, pistons and piston rings, etc., and accumulation of unburned fuel in the turbocharter and exhaust system. The consequences of no load or light load operation are potential equipment failure due to the gum and varnish deposits and fire in the engine exhaust system.
2 Periodic surveillance testing should be performed in accordance with the applicable NRC guidelines (R.g.1.103), and with the reconnendations of the engine manufacturer.
Conflicts between any such recommendations and the NRC guidelines, particularly with respect to test frecuency, loading and duration, should be identified and justified.
3.
Preventive maintenance should go beyond the normal routine adji st-ments, servicing and repair of ccmponents when a malfunction occurs.
Preventive maintenance should encompass investigative testing of components which have a history of repeated malfunctioning and require constant attention and repair. :n such cases consideration should be given to replacement of those components with other products which have a record of de::enstrated reliability, rather than repetitive repair and maintenance of the existing components. Testing of the unit after adjustments or repairs have been made only confirms that the equipment is operable and does not necessarily mean that the root cause of the problem has beer eliminated or alleviated.
4 Upon completion of repairs or maintenance and prior to an actual start, run, and load test a f*nal equipment check should be made to
assure that all electrical circuits are functional, i.e., fuses art place, switches and circuit breakers are in their ;-oper pcsiti:n, no loose wires, all test leads have been re. ved, and an valves are in the proper position to permit a manual scart of the equi;..ent.
After the unit has been satisfactorily started and load testad, retur the unit to ready ~ automatic standby service ard under ne control of the control room operator.
Provide a discussion of how the above reccirements have been i=olemented in' the emergency diesel generator systen design and how they will be considered when the plant is in commerciai operation, i.e., by what means will the above requirements be enforced, o
Ot0.108 Tne availability on demand of an emer,ency diesel generator is (8.3)
RSP dependent upon, among other things, the paper functioning of its controls and monitoring instrumentation. This equipment is generally panel mounted and in some instances the panels are runted directly en the diesel generator skid. Major diesei engine damage has cecurred at some operating plants from vibration induced wear en skid cunted control and monitoring instrumentation. This sensitive instrumentation is not made to withstand and function accurately for prolonged periods under continuous vibrational stresses nor. ally encountered with internal c:mbustion engines. Operation of senstive instrumentation under this environment rapidly deteriorates calibratics,. accuracy and control signal output.
11 Therefore, except for sensors and other equipment that must be directly mounted on the engine or associated piping, the controls and monitoring instrumentation should be installed on a free standing door mounted panel separate from the engine skids, and located on a vibration free floor area or equipped with vibration mounts.
Confirm your compliance with th'e above requirement or provide justification for noncomoliance.
Ja0.109 Expand your discussion in paragraph 9.5.4 to include the following (9.5.4) information for each tyce of engine:
1.
Useable capacity of the fuel oil storage tank 2.
Minimum car 2 city of the fuel oil storage tanks for post LOCA load demands.
040.110 Tne diesel generators are required to start automatically on loss of (9.5.5) 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 perfomance 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 performance or reliability.
Ex:and your PSAR/FSAR to include and explicitly define the capability of ycur design with regard to this requirement for the HPCS diesel generator.
(SRP 9.5.5, Part III, Item 7).
Previous question 040.55, part 3, asked for your provision for removing
- SP moisture in the HPCS diesel generator air starting system. Since this question was asked, a study by the University of Dayton has shown that a::=ulation of water in the starting air system has been one of the most 3-e:uent causes of diesel engine failure to start on demand. Condensation o# sntrained moisture in compressed air lines leading to control and r* 'rting air valves, air start motors, and condensation or moisture on the working surfaces of these compenents has caused rust, scale and water itself to build up and score and jam the internal working parts of these vital com-p:nents 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 Jafe 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 to substantially less than the desired reliability of 0.99 as specified in Branch Technical Position IC53 (PSB) 2 " Diesel Generator Reliability Testing" and Regulat.ory Guide 1.108 " Periodic Testing of Diesel Generator Units Used at Onsite Electric Power Systems at Nuclear Power Plants."
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 cor=cnly 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 pre-ferrad. Starting air should be dried to a dew point of not more than 500F when installed in a nor ally controlled 70cF environment, otherwise the starting air dew point should be controlled to at least 100F less than the lowest expected ambient temperature.
Revise your design of the diesel engfne air starting system accordingly, describe this feature of your design.
040.112 Several fires have occurred at some operating plants in the area of (9.5.7) the diesel engine exhaust manifold and inside the turbocharger housing RSP which have resulted in equipment unavailability. The fires were started from lube oil leaking and accumulating on the engine exhaust manifold and accumulating and igniting inside the turbocharger housing.
Accumulation of lube oil in these areas, on some engines, is apparently caused from an excessively long prelube period, generally longer than five minutes, prior to manual starting of a diesel generator. This condition does not occur on an emergency start since the prelube period is minimal.
When manually starting the diesel generators for any reason, to minimize the potential fire hazard and to improve equipment availability, the prelube period should be limited to a maximum of three to five minutes unless otherwise reconmended by the diesel engine manufacturer.
Confirm your compliance with this requirement or provide your justification for recuiring a longer prelube time interval perior to manual starting of the diesel generators.
Provice the prelube time interval your diesel engine will be exposed to prior to manual start.
e
, 040.113 An emergency diesel generato unit in a nuclear power plant is normally (9.5.7)
RSP in the ready standby made unless there is a loss of offsite power, an accident, or the diesel generator is under test. Long periods on standby have a tendency to drain or nearly empty the engine lube oil piping system. On an emergency start of the engine as much as 5 to 14 or more seconds may elapse from the start of cranking until full lube oil pressure is attained even though full engine speed is generally reached in about five secends. With an essentially dry engine, the momentary lack of lubrication at the various moving parts may damage bearing surfaces pro-ducing incipient or actual component failure with resultant equipment unavailability.
The emergency condition of readiness requires this ecuipment to attain full rated speed and enable automatic sequencing of electric load within ten seconds. For this reason, and to improve upon the availability of this equipment on demand, it is necessary to establish as quickly as cossible an oil film in the wearing car.s of the diesel engine.
Lubricating oil is nor ally delivered to the engine nearing : arts by one or more engine driven
- um:(s). During the scarting cycle the pump (s) accelerates slowly with the engine and may not supply the required quantity of lubricating oil where needed fast enough. To recedy this condition, as a minimum, ar. electrically driven lubricating oil pum:, powered from a reliable DC power supply, should be installed in the lube oil system to operate in parallel with the engine
. driven main lube pump. The electric driven prelube pump should operate only during the engine cranking cycle or untti satisfactory lube oil pressure is estabitshed in the engine main lube distributien header.
The installation of this prelube pump should be coordinated with the respective engine manufacturer. Some diesel engines include a lube oil circulating pump as an intregal part of the lube oil preheating system which is in use while the diesel engine is in the standby mode.
In this case an additional prelube oil pump may not be needed.
Confirm your compliance with the above requirement or provide your justification for not installing an electric prelube oil pump.
.