ML19323H917

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Forwards Responses to NRC 790327 & 800303 Info Requests. Info Provided to Be Included in Future FSAR Amend
ML19323H917
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 06/09/1980
From: Novarro J
LONG ISLAND LIGHTING CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
SNRC-480, NUDOCS 8006170261
Download: ML19323H917 (30)
v • d • e


Text

{{#Wiki_filter:' f ,~ < ~__m LONG ISLAND LIGHTING COM PANY SWI SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RO AD

  • WADING RIVER, N.Y.11792 w,-

June 9, 1980 SNRC-480 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commissi.on Washington, D. C. 20555 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322

Dear Mr. Denton:

Forwarded herein are fifteen (15) copies of LILCO's responses to the information requests, contained in the following letters: 1. NRC letter of March 27, 1979, S. A. Varga to A. W. Woffold. 2. NRC letter of March 3, 1980, L. S. Rubenstein to A. W. Wofford. A complete list of the questions addressed in this submittal is included in the enclosed Table of Contents. As a reminder, it is'our intention to include the information provided herein in a future amendment to the FSAR. We trust that the enclosed responses will provide adequate resolution to your concerns. Should you request further information, please do not hesitate to contact this office. Very ruly yours, r( McM y J..P.

Novarro, Project Manager N \\

Shoreham Nuclear Power Station j LG/cc Enclosures cc: J. Higgins i h, sooeno 16(

_4.....~.-___.. t i i i l 1 i i 'LdNG ISLAND LIGHTING COMPANY l l SHOREHAM NUCLEAR POWER STATION UNIT-1 l i l l ' RESPONSES TO NRC QUESTIONS JUNE 9, 1980 I 1 h 1 i i s, 1 ,x l h;' . ~.-

TABLE OF-CONTENTS REQUEST NO. PAGE TABLES FIGURES 212.106 212.106-1&2 212.106-1 (3 pages) f 223.74 223.74-1&2 223.75 223.75-1&2 223.76 223.76-1 223.77 223.77-1 223.77-1 223.78 223.78-1 223.80 223.80-1 223.81 223.81-1&2 223.82 223.82-1&2 O 223.83 223.83-1 '223.84 223.84-1 9.5.7-1 223.85 223.85-1 223.86 223.86-1&2 223.87 223.87-1&2 4 l

M ^'b.. REQUEST 212.106: Isolation 1between the reactor coolant system and connecting systems should be provided by at least two normally closed isolation valves. Identify by specific valve number these isolation valves for the RHR,.CS, HPCI, RCIC, SBLC, and CRD. Your previous discussions .have indicated that the Type C Test (Appendix-J 10CFR50) is proposed to fulfill periodic leak testing for these valves. However,- insufficient information has been submitted to justify that these allowable leakage limits satisfy concerns on high/ low -pressure' interface. We-re, quire that these isolation valves be leak ' tested p"criodic' ally'in accordance with the provisions of Section.XI of the.American Society of Mechanical Engineers Boiler and Pressure Vessel Code. Submit your proposal for allowable leakage limits for each valve and justify those limits. Also . provide a discussion to-assure'that adequate high/ low pressure isolation valves are stroked as required by Technical Specifications.

RESPONSE

The reactor coolant pressure boundary (RCPB) containment isolation l valves for the RHR, CS, HPCI, RCIC and SBLC systems are listed i. in Table 212.106-1. The cable also includes the penetration, and the maximum allowable t.dME XI leakage. The CRD system is not - () considered part of the RCPB as defined in FSAR Section 6.2.4.3.2 and isinot included in the table. The RCPB containment isolation valves can be placed into three groups as outlined below: i Group I - Containment isolation valves which also serve as a high/ low pressure boundary and for which reactor 4 pressure tends to increase leak tightness (e.g., globe valve with pressure over the seat). Group II - Containment isolation valves per above where reactor pressure would not increase leak tightness (e.g., globe valve with pressure under the seat). Group III.- Containment isolation valves which serve a containment isolation function only, and do not separate 4 . high/ low pressure boundary (e.g., HPCI steam supply). l- 'Allelow pressure piping systems isolated.by a Group I or II RCPB. containment isolation valve are protected from overpressure .via-relief' valves. The capacities of these relief valves, at the' limiting low pressure piping conditions, are listed in Table 212.106-1. This leakage represents the mraimum allowable . isolation valve ASME XI seat leakage (at the corresponding RCPB f~) _ condition), while still ensuring protection of the' low pressure

piping.

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4 l1 In all cases, the maximum relief valve capacities exceed the typical Type C test criteria. At RCPB conditions, this relief valve capacity is on-the order of 13 to 170 GPM, as compared to typical Type C test criteria of 0.2 to 15 scfh, including cor-rection to the higher RCPB pressures. 'Since the pressure correction.is conservative for Group I valves, an exemption from ASME XI requirements is requested on the basis of'the more stringent Type C test as compared to the ASME XI leakage test. Reduced pressure-testing is permitted for Group I valves as defined in ASME XI, par. IWV-3423. For. Group II valves, however, the reduced Type C limits can-not be shown conservative at higher RCPB pressure and, therefore, they will be tested in accordance with ASME XI requirements, with maximum leakages as determined by the relief valve ca-pacities. Group III valves do not perform a pressure boundary interface function and only a Type C test is performed. An exemption-is requested from ASME XI leak rate test requirements since the. Type C leak rate test requirements are adequate to satisfy containment leakage test requirements. Adequate high or low pressure isolation is provided during power operation when containment isolation valves are stroked s_ as required by Technical Specifications, since at least two valves-with high pressure ratings are always located in series. In the case of stroking valves which rely on an air operated check valve'to act alone as a high to low pressure boundary, positive seating of that valve may be verified by the operation of position indicator lights or by opening the proper test' con-nection prior to stroking the valve. u 212.106 2

j . Pago 1 cf ' H TABLE 212.106-1 REACTOR COOLANT PRESSURE BOUNDARY CONTAINMENT ISOLATION VALVES MAXIMUM ALLOWABLE ASME XI LEAKAGE ' SYSTEM PENETRATION VALVE DESCRIPTION (R.V. CAPACITIES) REMARKS Grcup I Valves. RHR X-ll Inboard Isolation Valve 33.9 gpm (1) (IEll) RPV Head Spray lEll* MOV-054 (F022) X-6A Outboard Isolation Valve 67.8 gpm (2) LPCI Injection IE11* MOV-37A (F015A) X-6B Outboard Isolation Valve 33.9 gpm (1) LPCI Injection IEll* hCV-37B (F015B) X-5 Inboard Isolation Valve 45.2 gpm (3) Shutdown Cool-IEll* MOV-047 (F009) ing from RPV Outboard Isolation Valve 45.2 gpm (3) lEll* MOV-048 (F008) CS X-20 A/B Outboard Isolation Valve 161 gpm (4) (IE21) Injection to 1E21* MOV-033A/B (F008A/B) RPV Group II Valves RHR X-11 RPV Outboard Isolation Valve 33.9 gpm (1) (IEll) Head Spray lEll* MOV-053 (F023) X-6A Inboard Isolation Valve 33.9 gpm (2) This is a Group I valve;;however, LPCI Injection lEll* A0V-081A (F050A) it must be tested in conjunction with a Group II MOV, due to piping Inboard Isolation Valve 33.9 gpm (2) configuration. lEll* MOV-081A X-6B Inboard Isolation Valve 16.9 gpm (1) This is a Group I valye; however,. LPut Injection IEll* A0V-081B (F0508) it must be tested in conjunction with a Group 11 MOV, due to piping Outboard Isolation Valve 16.9 gpm (1) configuration. IEll* MOV-081B l

or () (. s TABI.E 21_2,.l106-1 Continued r

{d
1 MAXIMUM ALLOWABLE ASME XI LEAKAGE g

SYSTEM PENETRATION VALVE DESCRIPTION (R.V. CAPACITIES) REMARKS T Group II Valves (Cont'd.) - 1 X-20 A/B-Inboard Isolation Valve 80.5 gpm (4) This is a Group I valve; however,- ' f it must be tested :Ln conjunction CS~ Injection to' IE21* A0V-081A/B (F006A/B) with a Group II MOV, due to piping' 1 (1E21) RVP configuration. i. Outboard Isolation Valve 80.5 gpm (4) IE21* MOV-081A/B Group III Valves HPCI X-12 Inboard Isolation Valve-(IE41) Turbine Steam 1E41* MOV-041 (F002) l Supply Inboard Isolation Valve IE41* MOV-047 (F097) Outboard Isolation Valve IE41* MOV-042 (F003) Outboard Isolation Valve lE41* MOV-048 (F080) RCIC X-16 Inboard Isolation Valve (1E51). Turbine Steam 1E51* MOV-041 (F007) Supply Inhoard Isolation Valve lE51* MOV-047 (F085) Outboard Isolation Valve IE51* MOV-042 (F008) Outboard Isolation Valve IE51* MOV-048 (F075) Page 2 of 3

.l (~) ' .,0 . r ") \\/ TABI.E 21 h.-tf!/i-1 Cont Itunei! l I*AXIlmM ALLOWABLE ASME XI LEAKAGE SYSTEM PENETRATION

VALVE DESCRIPTION (R.V. CAPACITIES)

REMARKS Cruup III Valves'(Cont'd.) 2 SBLC-X-36 Inboard Isolation Valve -(IC41)._ RPV Injection to .1C41* VCS-150D-1 Outboard Isolation Valve IC41* VCS-150D-1 Outboard Isolation Valves .(EXPLOSIVE) IC41* EV ^50A/B (F004A/B) (1) Leakage limit based on 67.8 gpm capacity of IE11*RV-153B. (2) Leakage limit based on 67.8 gpm capacity of IE11*RV-153A. (3) Leakage limit based on 45.2 gpm capacity of 1 Ell *RV-154. (4) Leakage limit based on 161 gpm capacity of IE21*RV-093A/B. Page 3 of 3

i t O REQUEST 223.74 (8.3): Provide a detailed discussion or plan of the level of training proposed for your operators, maintenance crew, quality assurance, and supervisory personnel responsible for 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 gen-eral 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 re-quirements for the various categories of operations and main-tenance personnel associated with the emergency diesel genera-tors.

RESPONSE

r bs The Shoreham operating personnel participate in a formal training program which includes documented completion of the training re-quirements for safety related equipment. Training for the opera-tion of the diesel generators will be part of this formal train-ing program and will include sufficient instruction to insure that the operators and licensed supervisors have the ability to operate the diesels properly. Periodic training of operators and licensed supervisors on dies _el generator operation will take place as part of the license requalification program. Since SNPS operators'and licensed supervisors are required to partici- .pate in the formal training program, there will be no specific group of operators or supervisors dedicated to the operation of the diesel generators. For a detailed discussion of the Shoreham training program, refer to Section 13.2 of the FSAR. .The training and qualification requirements for the permanent maintenance crew at Shoreham are as specified in plant admini-strative procedures. This program satisfies the requirements of ANSI 18.1-1971, " Selection and Training of Personnel for Nuclear Power Plants", and Regulatory Guide 1.8-1971, " Person-nel Selection and Training". The training program consists of.a basic training phase and an advanced training phase. The basic training phase instructs the maintenance crew in the areas i of plant procedures, plant systems (including EDGs) and general f, 223.74-1 r, - ~ - -

l' ^ ( >, RESPONSE (Cont'd.): maintenance' skills. During the advanced training phase, the t.aining may be conducted by the equipment vendors. A main-tenance course, conducted by the diesel supplier DeLaval, is -part of this advanced training phase. Permanent maintenance personnel are required to.successfully complete the appropriate training program requirements. Shoreham does not plan'to have personnel solely dedicated to the maintenance of the EDGs. As such,-several maintenance person-nel shall be qualified to perform and/or cupervise both pre-ventive~and corrective maintenance on the EDGs. The maintenance performed on the EDGs. will be within the capabilities and skills of the personnel performing the work. Maintenance performed by the general maintenance group _or contracted personnel will be directly supervised by permanent plant personnel qualified to the requirements of the 3horeham maintenance training program or as necessary by vendor representatives. Operational Quality Assurance (OQA) inspection personnel are quali-fied, in accordance with Regulatory Guide 1.58-1973 " Qualification of Nuclear Power Plant Inspection, Examination and Testing Person-nel". As such inspection personnel' training programs include re-g- view of procedures, witness of testing, and review of test re-(s) sults during the preoperational, startup, and power operations. Additionally, OQA Inspection-persannel will attend applicable Shoreham training programs. The education and experience requirements for the Shoreham opera-tors, maintenance crew and licensed supervisors will, as a mini-mum,.be in compliance with ANSI N18.1-1971. t 9 v 223.74-2 .gft -v "y'e t-m. wew M

.+ REQUEST. 223.75'(8.3) -(m .(,) Periodic testing and test loading of an emergency diesel generator lin.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 following requirements should be met: 'l. The equipment should be tested with a minimum loading of 25 _ percent _of rated load. No load or light load operation will cause-incomplete combustion of fuel resulting in the formation o.f 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 exhaust system. The consequences of no load or' light load operation are potential equipment failure due to the gum j 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. 1.108), and with the recommendations of the engine manufacturer. Conflicts between any such recommendations and the NRC guidelines, particularly with respect to test' frequency, loading and duration, should (v) be identified and justified. 3. Preventive maintenance should go beyond the normal routine adjustments, servicing and repair of components when a malfunction occurs. Preventive maintenance should encompass investigative testing of components which have a history 4 of repeated malfunctioning and require constant attention and repair. In such cases consideration should be given to replacement of those components with other products which have_a record of' demonstrated 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 been eliminated or alleviated. 4. Upon completion of repairs or maintenance and prior to an actual start, run, and load test a final equipment check .should.be made to assure that all electrical circuits are . functional, i.e., fuses are in place, switches and circuit breakers are in their proper position, no loose wires, all test loads have been re' moved, and all valves are in the proper position to permit a manual start of the equipment. After the unit has been satisfactorily started and load tested, return.the unit to ready automatic standby service and under {} the-control of the control room operator. Discuss how the above requirements have been implemented in your emergency diesel generator system design, and how their Limplementation will be assured when the plant is in commercial operation. 223.75-1

RESPONSE TO 223.75: In order to assure the operability and availability upon demand of~ equipment such as the cmergency diesel generators (EDGs) a periodic testing and an agressive maintenance program will be . implemented at the-Shoreham facility. To accomplish maximum EDG readiness, the applicable procedures will include the following requirements: 1. The EDGs will be periodically tested in accordance with Technical Specifications. These surveillance tests will include monthly loading each EDG to a minimum of 25% of rated load, for a period of one hour. 2. Periodic surveillance testing of EDGs, during normal plant operations, will be in accordance with Regulatory Guide 1.108-Revision 1, August 1977, with the following clarification: The components of the diesel generator unit, required for automatic startup (Section C.2.c.1 of Reg. Guide 1.108) include such components as the starting air system, fuel oil system, ventilation system and governor control system, but not the low voltage and LOCA signal relaying. Testing (J the low voltage and LOCA signal relaying, along with the ~S EDG, would initiate bus shedding and transfer schemes which'would preclude the testing'.of the EDG during normal operation. 3. When a malfunction has occurred on equipment, a maintenance work request (FBut) is initiated and will serve as the administrative control for the identification, performance and' documentation of work performed on the equipment. Additionally, a maintenance record system with appropriate history forms will document the details of work performed on the equipment. Maintenance personnel job knowledge and periodic. review of the above mentioned history files will serve to detect recented malfunctioning of equipment. To assist maintenance'oersonnel in the detection of repeated ' malfunctions, computer printouts are available and ' sorted ^ by component-I.D. number listing all corrective or preventive maintenance performed on the equipment or components. Appropriate administrative controls are provided to initiate the required design changes for the replacement or modification of the components which have a history of repeated malfunctions, -if: required. 4. Maintenance on the EDGs will be preplanned and performed in accordance with the administrative controls outlined r-on the FRut. The FRH1 will require the use of a detailed (_SJ written procedure'unless the maintenance can be performed Jusing skills normally possessed by qualified maintenance personnel.. In any case, provisions are provided on the MWR', maintenance procedure, and/or system operating procedure to return the EDGs to an operable inservice condition-including any necessary post maintenance testing. 223.75-2

w ~ g NJ -REQUEST 223.'76: The availability on demand of an emergency diesel generator is -dependent upon, among other things, the proper functioning of its controls and monitoring instrumentation. The equipment is -generally. panel mounted and in some instances the panels are mounted directly on the diesel generator skid. Major diesel engine damage has occurred at some operating plants from vi-bration induced wear an1 skid mounted control and monitoring instrumentation. This sensitive instrumentation is not made -to withstand-and function accurately for prolonged periods under. continuous vibrational stresses normally encountered with internal combustion engines. Operation of sensitive in-strumentation under this environment rapidly deteriorates cali-- bration, accuracy and control signal output. Therefore, except for sensors and other equipment that must be directly mounted on the engine or associated piping, the con-trols and monitoring instrumentation should be installed on a free' standing floor mounted panel separate from the engine skids, and located on a vibration free floor area or equipped with vi-bration mounts. Confirm your compliance with the above requirement, or provide r3 justification for noncompliance in view of these expressed con-(_) - cerns and experiences.

RESPONSE

The controls and monitoring instrumentation, with the exception of sensors and other equipment that must be directly mounted on the engine'or associated piping, are mounted in the diesel gen-erator control panels. These panels are free standing, floor mounted and are located in the diesel generator rooms. Since the foundations for the diesel generator skids are separated from the rest of the floor, vibrations will not be transmitted to the panels. f'b - v_/ 223.76-1

O RzouESr.223.77 (9.4.10'3):

Provide a' plan and elevation view of the diesel generator build-ing with.a section. view that clearly shows the details of the

- arrangement'for. admission of air' intake and the elevation and . shielding of the exhaust stack.

RESPONSE

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F I G. 223. 77 - 1 ~ l",'Q Q DIESEL GENERATOR ROOMS EL 22'-6" ort.s ti=rras sieo4.sieou SHOREHAM NUCLE AR POWER STATION - UNITI M fie m,'i- E'dd'Ei.Il"ioY Ecssty FINAL SAFETY ANALYSIS REPORT a 1 w w u ra e -')*'

V(m REQUEST 223.78 (9.4.10.3): J Provide a discussion to explain how the-diesel engine combustion intake and exhaust system is protected from: 1) possible clogging.during operation, including standby, from atmospheric conditions (ice, snow); 2) tornado missiles that could block the intake or exhaust openings. (SRP 9.5.8, Part III, Item 4 t and 65).

RESPONSE

The combustion air for the diesel generators is drawn through a reinforced concrete missile protected intake hood (one for each diesel) located on the west side of the control building. The missile protected hood has a configuration such that it provides protection for the intake louvers from snow, ice and rain. The hood openings are oriented vertically downward to preclude the possibility of a tornado missile entering the protective hood. The diesel generator combustion air exhaust lines exit through the east wall of the control building. Refer to the response to (') request 223.77. The exhaust air is discharged above the roof of the control building at a velocity of approximately 5000 fpm. The_ location of the exhaust lines is inherently protected by the major plant structures, including the control building, the turbine building, the reactor building, and the main steam pipe tunnel. Accordingly, it is-highly unlikely that one of the exhaust lines would be hit by a tornado missile, since the avenues of approach are almost non-existent. Moreover, the possibility of more than one line being damaged so as to impair flow is not considered' credible. The Shoreham plant can be brought to a safe shutdown with any two out of three diesel generators. Nevertheless, if a tornado missile were to impair flow, the affected diesel can be returned to operation within a short time by cutting away the damaged portion of the exhaust line. 4 /'N A 223.78-1 \\

v REQUEST 223.80- (9.4.10.3):

Experience at some operating plants has shown that diesel engines have-failed to start due to accumulation of dust and other deliterious material cn1 electrical equipment associated with starting of the diesel generators (e.g., auxiliary relay contacts,

. control switches - etc.). ~ Describe the provisions that have been made :Ln your _ diesel generator building design, electrical starting system, and combustion air and ventilation air intake design (s) to preclude this condition.to assure availability of the diesel generator upon demand. Also describe what procedure will be used under normal plant ~ operation to minimize accumulation of dust in the diesel generator room, specifically address concrete dust control. Your response should.also identify and address any special conditions, construc-tion or maintenance activities during operation which may result in abnormal generation of dust.

RESPONSE

() Upon completion of construction, the diesel generator rooms will be thoroughly cleaned, and any debris, surplus material, dirt, and packing materials properly disposed. The diesel engine generator set will be wiped clean and all spilled lubricants removed, and minor paint damage will be touched up. All equipment access and construction temporary openings will be closed ~and terminal box and other-protective covers installed. The generator, exciter, and control panel shall be cleaned to . remove accumulated dust and dirt. The combustion air for the diesel generator is filtered. In addition, the ventilation system is only operated when the diesel generator is running otherwise the associ'ated air dampers are.normally closed. All diesel _ generator room concrete floors and walls, to a height of 8 feet'above-the floor, will be cleaned and sealed, with appropriate paint or sealant, to control the generation and accumulation of dust. Accessuto the' diesel generator rooms will be controlled for security purposes during plant operation. This control will minimize traffic within the rooms, thereby reducing the potential for subsequent generation of dust. In addition, the Shoreham Station will comply with Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Power Plants", dated March,_1973 during plant operation. ~N (U 223.80-1 ~~

q l m REQUEST 223.81 (9.5.4): Section 9.5.4.1 emergency diesel engine fuel oil storage and transfer system (EDEFSS) does not specifically reference ANSI Standard N195 " Fuel Oil Systems for Standby Diesel Generators". Indicate if you intend to comply with this standard in your design of the EDEFSS; otherwise provide justification for non-compliance. (SRP 9. 5. 4, Rev. 1, Part II, Item 12.)

RESPONSE

Engineering and design of the fuel oil system for emergency diesel generators were developed prior to the existence of ANSI N195-1976 " Fuel Oil Systems for Standby Diesel Gener-ators". However, the present system does comply with the re-quirements of ANSI N195 standard with the following exceptions: 1. High Level Alarm for Fuel Oil Storage Tank (Section 8) Fuel oil storage tank level is continuously monitored by the computer in the main control room. Since the tank filling operations are performed locally and are manually ('~3 controlled, no high level alarm has been provided. v 2. Fill Line and Associated Components for Fuel Oil Storage Tanks (Subsections 7.1 and 7.5) The design of the fill line and associated components com-plies with Subsection 7.5. A common fill line is used for the three fuel oil storage tanks. The fill line is pro-vided with a bag type filter (100 micron filtration), which is constructed to OSHA Flammable Liquid Standards and ASME Section VIII - Pressure Vessel Code with code stamp. A shutoff valve is provided for the downstream fill line lead-ing to each underground storage tank located approximately 38 ft. from the shutoff valve. The associated pumping equip-ment for the storage tanks is located in an above ground struc-ture protected from tornados and floods with dividing wall between adjacent fuel oil systems. The portion of fill line adjacent to each storage tank com-plies with the design of Safety Class 3 Piping. The design of upstream portion of piping components conforms to ANSI B31.1 and, therefore, deviates from Subsection 7.1, which, as a general statement, requires Safety Class 3 design for fuel oil system piping and components. A portion of this fill line piping and all components are located above ground, remote from the storage equipment and are accessible for main- ,xL' tenance. Thus, this design does not affect the availability of the emergency diesel generator and will not result in sys-tem hazards. 223.81-1

.(d RESPONSE (Cont'd.): 3. Flame Arrestor. Located on the Vent Line of Fuel Oil Storage Tank.(Subsection-7.5) .The1 fuel oil storage tank is provided with a vent which has a screen to minimize ingress'of foreign material. This vent design complies with-National Fire Protection Association Standard No. 30, 1977, " Flammable & Combustible Liquids Code",'Section 2-3.5, regarding vents for underground storage tank for Class II liquids. A flame arrestor is not required by this code.or the nuclear fire insurance 4 underwirters and has not been installed. 4 s. 4 i o s l i 1 8

1. -

7 [.. , '. (- l 223.81-2 k

,) 'u REQUEST 223.82 (9.5.4): Assume an unlikely event has occurred requiring operation of a diesel generator for a prolonged period that would require replenishment of fuel oil without interrupting operation of the -diesel generator. What provision will be made in the design of the fuel oil storage fill-system to minimize the creation of turbulence of the sediment in the bottom of the storage tank? Stirring of this sediment during addition of new fuel has the potential of causing the overall quality of the fuel to become unacceptable and could potentially lead to the degradation or failure of the diesel generator.

RESPONSE

The diesel generator fuel oil storage and transfer system is designed to minimize the degradation of the overall quality of the fuel oil while filling during diesel operation. The diesel fuel oil storage tanks have been equipped with a very fine, 100 micron filter which passes up to 100 gpm of No. 2 diesel fuel oil. This filter is located upstream of the three buried tanks in the common fill line and greatly reduces the possibility of sedimentation buildup in the main ( ') storage tanks. In addition, these tanks are sloped a minimum of 1/26 in. per ft., or 2 in, total to accumulate any moisture and sediment at the. low end of the tank away from the fuel oil pumps. The diesel fuel oil storage tanks are inspected and sampled periodically, and if excessive amounts of moisture are accumulating in the tanks, the moisture is removed by means of a portable pump via the sounding tube. Refer to the response to request 223.83 for further details with regard to the measures provided to assure the quality of the diesel fuel oil. Each fuel oil storage tank is provided with a low level alarm which is set to alarm at a level corresponding to two days of remaining supply (approximately 11,700 gal, or 4 ft. above the bottom of the tank). The distance between the fuel oil fill connection and the suction of the first fuel oil pump is approximately 40 feet. At the initiation of the low level alarm, the operators can select either of the following options available: (i) order a new delivery of oil which can be supplied in a very short time; or (ii) pump oil from auxiliary boiler fuel oil storage tanks using an interconnect provided between the auxiliary boiler fuel storage and diesel generator fuel oil tanks for this purpose. This crossconnect ties into (~~) the common fill line upstream of the filter to minimize sediment carry over from the auxiliary boiler fuel oil tanks. Type No. 2-D fuel oil will be used for the auxiliary boilers. 223.82-1 L

~ (O> RESPONSE (Cont' d. ) : ~With the-level in the diesel fuel oil storage tank approximately 4.ft. above bottom of the tank and with oil fill connections approximately 40 ft. from.the suction of the first fuel oil transfer pump, the possibility of creation of turbulence and entraining sedimentation in the pump suction is essentially eliminated. The diesel fuel oil is further strained and filtered downstream of the fuel oil day tank-before it is injected into the diesel generator. The fuel oil duplex strainer consists of a stainless steel basket with a filteration of 46 micron absolute, 22 micron nominal with no bypass or relief valve. High differential pressure alarm across these Y strainers is provided on the diesel generator panel and annunciated as a diesel trouble alarm in the main control room. The engine mounted fuel oil filter consists of a laminated disc. mesh of 491 squares per inch. A low pressure switch is provided downstream of these filters to annuciate' low pressure alarm.(in case of filter clogging) on the diesel generator and a trouble alarm in the main control (~s) room. u -The possibility of sedimentation entering the diesel generator during a filling operation becomes negligible due to the extent of filteration, straining automatic monitoring, periodic sampling, and tank design. Additionally, the day tank has the capacity for at least one hour of diesel operation without any make up. This should further help to settle the oil in the main storage tank and greatly minimize the possibility of carry-over of sedimenta-tion to the diesel generator. vs 223.82-2

nU . REQUEST 1223.83 (9.5.4): Discuss the precautionary measures that will be taken to assure the-quality and. reliability of the fuel oil supply for emergency diesel generator operation. Include the type of fuel oil, impurity and quality limitations as well as diesel index number or its equivalent, cloud point, entrained moisture, sulfur, particulates and other deliterious insoluble substances; procedure for testing newly delivered fuel, periodic sampling and testing of on-site fuel oil (including interval between tests), interval of time between ocriodic removal of condensate from fuel tanks and periodic.sys' tem inspection. In your discussion include reference to industry (or other)-standards which will be followed to assure a reliable fuel oil supply)to the emergency generators (SRP, 9.5.4, Part III, items 3 and 4.

RESPONSE

The fuel oil for the Shoreham emergency diesel generators will be of type No.-2-D. In order to assure quality and reliability, the fuel oil will be specified to the applicable limits of ASTM-D975-74, Table 1 for viscosity, water and sediment, sulfur, cloud point and flash point. A lot assay will be provided at the ~ time of delivery showing that viscosity, water and sediment are within the specified limits. In addition, a sample obtained at -( g the time of delivery will be tested for further verification / that the fuel oil meets the specification requirements. This sample will also be analyzed for API gravity and aniline point to determine the diesel index number. If the fuel oil does not meet the applicable specifications, further analyses will be performed. If the fuel. oil does not meet the limits as specified.in the above mentioned standard, as determined by these analyses, it will be replaced. Each emergency diesel fuel oil storage tank will be sampled at least'once every 92~ day period in accordance with the procedure of ASTM-D270-65. These samples will be analyzed for viscosity, entrained moisture and sediments to verify that the fuel oil .is within the limits specified in ASTM-D975-74, Table 1. The diesel generator. fuel oil day tank will be inspected for condensate accumulation after each operation of the diesel for one' hour or longer (minimum once per 31 days in accordance with Regulatory Guide 1.108, Revision 1, dated August, 1977). If any water is found, it will be removed at that time. The storage j tanks will be. checked for accumulated water once every 92 day period. If any water is found, it will be removed as soon as practical, p U ~ 223.83-1 1

O) REQUEST 223.84 (9.5.6): Provide a discussion of the measures that have been taken in the designJof the standby' diesel generator air starting system to preclude the fouling of-the air start valve or filter with moisture and contaminants such as oil carryover and rust. ~(SRP 9.5.6, Part III, Item 1.)

RESPONSE

~Each diesel generator is provided with two independent redundant' air starting systems. In order to-preclude the fouling of the air start valve or filter with moisture and contaminants, such as oil carryover and rust, each diesel generator startup air system includes a prefilter and oil mist separators; a refrigerant air drior; a moisture separator and a strainer. In addition, the air storage tanks are provided with drain valves to remove any contaminants including rust. Refer to FSAR Section 9.5.6 for further details. O 'w/ O) 223.84-1 \\/

/~N V REQUEST 223.85: Several fires have occurred at some operating plants in the area of the diesel engine exhaust manifold and inside the turbocharger housing 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 avail-ability, the prelube period should be limited to a maximum of three to five minutes unless otherwise recommended by the diesel engine manufacturer. Confirm your compliance with this require-ment or provide your justification for requiring a longer prelube time interval period to manual starting of the diesel generators. Provide the prelube time interval your diesel engine will be exposed to prior to manual start. O

RESPONSE

Each diesel-engine includes an ac motor-driven lubricating oil circulating pump to ensure that the lubricating oil is continuously circulated at the desired temperature through the engine while the diesels are on standby. However, as shown in revised FSAR Figure 9.5.7-1, attached, a check valve prevents lubricating oil from being circulated through the turbocharger during this mode of operation. Once the diesel engine is started, either manually or automatic, the ac motor-driven pump is shut down and the engine driven lube oil pump takes over. Lubrication to the turbocharger is not required within a minimum time lapse of 12 to 15 seconds after the start of rotation (greater than the ten second ~ period required to attain diesel engine rated speed during accident conditions). Therefore, a prelube period for the turbocharger is not necessary and lube oil is not circulated through it while the engine is not running. This would preclude the leakage and buildup of oil in the turbocharger and exhaust manifold. G.l 223,85-1 + w y

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REQUEST 223.86: An emergency diesel generator unit in a nuclear power plant is normally in the ready standby mode unless there is a loss of offsite power, an accident, or the diesel generator is under test. Long periods of 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 seconds to 14 or more seconds may clapse from the start of cranking until full lube oil pressure is attained even though full engine speed is generally reached in about five seconds after start of cranking. With an escentially dry engine, the momentary lack of lubrication at the various moving parts may damage bearing surfaces, producing incipient or actual component failure with resultant equipment unavailability. The emergency condition of readiness require.s this equipment to attain full rated speed and enabic 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 possible an oil film in the wearing parts of the diesel engine. Lubricating oil is normally delivered to the engine wearing parts by one or more engine-driven pumps. During the starting cycle the pumps (~) accelerate slowly with the engine and may not supply the required quantity of lubricating oil where needed fast enough. To remedy this condition, we require that, as a minimum, an electrically driven lubricating oil pump, powered from a reliable DC power supply, be installed in the lube oil system to ope-ate in parallel with the engine-driven main lube pump. Tl electric-driven prelube pump should operate only during the engine cranking cycle or until satisfactory lube oil pressure is established in the engine main lube distribution header. The installation of this prelube pump should be coordinated wit h the respective engine manufacturer. Some diesel engines ir.clude a lube oil circulating pump as an integral part of the lube oil preheating system which is in use while the dicsci 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.

RESPONSE

As discussed in the response to request 223.85, an ac motor-driven lube oil pump is provided in addition to the engine driven lube oil to circulate the lube oil at tha desired temperature when the (~1 engine is not running and to provide lube oil to the engine during (_/ startup before the engine' driven pump takes over. The control power to the ac motor driven lube oil pump, the pump switch "off" 223,86-1 i i L

4

V 4-RESPONSE (Cont ' d. ) :

position and lube oil low pressure are monitored and alarmed .in-the main control room. Since loss'of offsite power and, 1 therefore, loss of the ac motor-driven lube oil pumps, will o result in a simultaneous auto start of the emergency diesel generator, the engine will be sufficiently lubricated during the time period, ten seconds or less, required for the diesel- ' to'obtain full rated speed. At that time lubrication will be maintained by the engine-driven' lube oil pump. 4 0 ) i n rQ,] ' '223.86 1 h -+,m -4, ,...-,-.,.r y v.__ ,,y..%.

('/ REQUEST'223.87 (RSP): It has come to our attention that some applicants did not intend to conduct confirmatory tests of some distribution systems and transformers supplying power to vital buses as required by Pesi-tion.3 of Regulatory Guide 1.68, and more specifically by Part 4 of the staff position on degraded grid voltage (applied to all plants in licensing review by the Power Systems Branch since 1976). Part 4 of the degraded grid voltage position states as follows: "4. The voltage levels at the safety-related buses should be optimized for the full load and mini-mum load conditions that are expected through-out the anticipated range of voltage variations of the offsite power source by appropriate ad-justment of the voltage tap settings of the intervening transformers. We require that the adequacy of the design in this regard be veri-fied by actual measurement and by correlation of measured values with analysis results. Provide a description of the method for making this verification; before initial reactor power operation, arovide the documentation required /') to establisi that this verification has been accomplished." Your test description in FSAR Chapter 14 does not contain suf-ficient detail for us to determine if you intend to conduct such a test. It is our position that confirmatory tests of all vital buses must be conducted including all sources of power suoplies to the buses. Modify your test description to indicate t1at this testing will be conducted in accordance with Regulatory Guide 1.68 and the above cited position.

RESPONSE

The adequacy of the design of the 4160, 480, and 120 V safety dis-tribution systems, including power and control circuits, shall be verified in concept by actual measurement of selected voltages and loads. Also a correlation of measured values with analytical results will be used to confirm that the voltage levels at the safety-related buses have been optimized for the full load and minimum load conditions that are expected throughout the antici-pated range of voltage variations of the offsite power source with the selected taps on the intervening transformers. Documen-tation will be available when the tests are complete. These tests will be performed prior to fuel load, k/ _The test.will be run according to the following: 223.87-1

. 0 RESPONSE (Cont'd.): Electrical System Verification Specific Checkout and Initial Operation Test Obj ective To demonstrate the capability of the offsite sources to supply power to the safety-related buses at full load and minimum load throughout the anticipated range of voltage variations of the offsite power source by correlation of measured values with analytical results. 1 Prerequisites 1. The applicable general prerequisites, as listed in FSAR Section 14.1.3.4, will be met. 2. The appropriate sections of the 120 V AC power distri-bution system necessary to this test will be operational. () 3. Sufficient loads available for loading of system. Test Method i 1. The ability of the offsite sources to supply rated voltage to safety-celated components will be verified. 2. The test will be run at the minimum and maximum loads practical and measured values will be checked for correlation with the analysis to verify the design for operation at the minimum and maximum design conditions. Acceptance Criteria 1. The applicable general acceptance criteria, as listed in FSAR Section 14.1.3.6, will be met. t 2. The safety buses will supply rated voltage to safety-related equipment. 223.87-2 . -..}}

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