ML19346A109
| ML19346A109 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway |
| Issue date: | 05/27/1981 |
| From: | Dromerick A, Edison G Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8106050093 | |
| Download: ML19346A109 (73) | |
Text
I TERA
'o UNITED STATES
! E,,q 'g NUCLEAR REGULATORY COMMISSION
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1 jun02 M " s Docket Nos.:
STN 50-482 and STN 50-483 e,,,ge "
4 APPLICANTS: Union Electric Company Vp-p Kansas Gas and Electric Company
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FACILITIES: Callaway Plant Unit 1 Wolf Creek Generating Station, Unit 1
SUBJECT:
SUMMARY
0F MEETING HELD ON MAY 14, 1981 WITH THE CALLAWAY AND WOLF CREEK APPLICANTS CONCERNING AUXILIARY SYSTEMS l
A meeting was held on May 14, 1981 at the Bechtel Offices in Gaithersburg, Maryland with representitives of the Union Electric Company, Kansas Gas and Electric Company, SNUPPS 'rganization and Bechtel Power Corporation. The meeting was held to discusi matters related to the (1) diesel generator and auxiliaries (2) turbine geneistor (3) diesel fuel oil storage (4) turbine by-pass systems (5) main condenser (6) comunications and lighting and (7) portions of the main steam system of the Callaway and Wolf Creek Plants.
The agenda for the meeting consisted of draft questions which were prepared by the Power Systems Branch and were transmitted to the applicants previously. lists the draft questions and the applicant's respor.ses to these questions.
The applicants will submit these responses as an amendment to the FSAR. The list of attendees at this meeting is attached as Enclosure 2.
Significant points discussed are summarized as follows:
1.
We advised the applicants that the draft responses to agenda items 430.1, 430 A, 430.7, 430.8, 430.10, 430.12, 430.13, 430.16 through
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430.29, 430.31, 430.33, 430.36, 430.37, 430.30, 430.40, 430.44 through 430.50, 430.52, 430.53 and 430.55 were conside"ed to be satisfactory responses to our concerns.
2.
With respect to operator training related to diesel generators (agenda item 430.22) the applicants stated that they will provided additional information regarding their training program which will be the man-ufacturer's recommended training program or the equivalent.
l 3.
With regard to diesel generator testing, Agenda items 430.3 and 430.22 the applicants stated that they will clarify what is ment by "short periods" t
l and " stipulated time intervals". The applicants will provide responses for each plant to requested items 3 4 4 of agenda item 430.3.
l 4
With respect to Agenda Item 430.5 the applicants will change Table 9.5.2-1 to include cold shutdown and will discuss the capability to l
adjust and control volume. The applicants will also clarify that comunication equipment is available to the auxiliary remote shutdown j
panel.
l 81060500S
Enclosuro 1 Applicants Responses to Power Systens Branch's Draf t Questions Regarding Callaway and Wolf Creek Plants 430.1 Operating experience at certain nuclear power plants (8.3) which have two cycle turbocharged diesel engines manufactured by the Electromotive Division (EMD) of RSP General Motors driving emergency generators have experienced a significant number of turbocharger mechanical gear drive failures.
The failures have occurred as the result of running the emergency diesel generators at no load or light load con-ditions for extended periods.
No load or light load operation cojld occur during periodic equip-ment 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 turbecharger.
As a result the turbocharger is driven mechanically from a gear drive in order to supply enough combusion air to the engine to main-tain rated speed.
The turbocharger and mechanical drive gear normally supplied with these engines are not designed for standby service encountered in nuclear power plant application where the equip-ment may be called upon to operate at no load or light load condition and full rated speed for a prolonged period.
The EMD equipTent was original-ly designed for locomotive service where no load l
sleeds for the engine and generator are much lower than full load speeds.
The locomotive turbocharged j
diesel hardly ever runs at full speed except at full load.
The EMD has strongly recommended to users of this diesel engine design against opera-e full tion at no load or light load conditions s rated speed for extended periods'because ei the short life expectancy of the turbocharger mechan-ical gear drive unit normally furnished.
No load or light load operation also causes general deteri-oration in any diesel engine.
To cope with the severe service the equipment is normally subjected to and in the interest of re-ducing failures and increasing the availability of their equipment EMD has developed a heavy duty turbocharger drive gear unit that can replace existing equipment.
This is available as a re-placement kit, or engines can be ordered with the heavy duty turbocharger drive gear assembly.
To assure optimum availability of emergency diesel generators on demand.
Applicant's who have in or order or intend to order emergency gener-
- place, ators driven by two cycle diesel engines manufac-tured by EMD should be provided with the heavy duty turbocharger mechanical drive gear assembly as re-commended by EMD for the class of service encoun-tered in nuclear power plants.
Confirm your com-pliance with this requirement.
430.'l-1
Mr. J. K. Bryan Mr. Glenn L. Koester Vice President - Nuclear Vice President - Nuclear Union Electric Company Kansas Gas and Electric Company P. O. Box 149 201 North Market Street St. Louis, Missouri 63166 P. O. Box 208 Wichita, Kansas 67201 cc: Gerald Charnoff, Esq.
Shaw, Pittman, Potts, Dr. Vern Starks Trowbridge & Madden Route 1, Box 863 1800 M Street, N. W.
Ketchikan, Alaska 99901 Washington, D. C.
20036 Mr. William Hansen Kansas City Power & Light Company U. S. Nuclear Regulatory Commission Resident Inspectors Office ATTN:
Mr. D. T. McPhee Vice President - Production RR #1 1330 Baltimore Avenue Steedman, Missouri 65077 Kansas City, Missouri 64101 Ms. Treva Hearn, Assistant General Counsel Mr. Nicholas A. Petrick Missouri Public Service Commission Executive Directo., SNUPPS P. O. Box 360 5 Choke Cherry Road Jefferson City, Missouri 65102 Rockville, Maryland 20850 Jay Silberg, Esquire Mr. J. E. Birk Shaw, Pittman, Potts & Trowbridge Assistant to the General Counsel 1800 M Street, N. W.
Union Electric Company Washington, D. C.
20036 St. Louis, Missouri 63166 Mr. D. F. Schnell Kansans for Sensible Energy Manager - Nuclear Engineering P. O. Box 3192 Union Electr*: Company Wichita, Kansas 67201 P. O. Box 141 St. Louis, ~ Missouri 63166 Francis Blaufuse Westphalia, Kansas 66093 Ms. Mary Ellen Salava Route 1, Box 56 Mr. Tom Vandel Burlington, Kansas 66839 Resident Inspector / Wolf Creek NPS Mr. L. F. Drbl c/o USNRC P. O. Box 1407 Missouri - Kansas Section Emporia, Kansas 66801 American Nuclear Society 15114 Navaho Mr. Michael C. Keener Olathe,' Kansas 66062 Wolf Creek Project Director State Corporation Commission Ms. Wanda Christy State of Kansas 515 N. 1st Street Fourth Floor, State Office Building Burlington, Kansas 66839 Topeka, Kansas 66612 Floyd Mathews, Esq.
Birch,.Horton, Bittner & Monroe 1140 Connecticut Fanue, N. W.
Washington, D. C.
20036 n
SNUPPS
RESPONSE
SNUPP" diesel generators are not manufactured by EMD; they are Fairbanks Morse diesel engines.
As discussed in response to FSAR Question 430.2 rpecific guidance has been provided by the diesel manufaci
'7.r on procedures for operating the engines at light or no load.
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430.1-2
SNUPPS 430.2 Provide a detail discussion (or pla';) of the level (8.3) 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 perr nnel that will be dedicated to the operations and r.ntenance of the emergency diesel generators and the number and type that will be assigned from your general plant ooperations 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 emer-gency generators.
Also discuss the level of education and minimum experience requirements for the various categories of operations and maintenance personnel associated with the emergency diesel generaters.
RESPONSE
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430.2-1
SNUPPS 430.3 Periodic testing and test leading of an emergency (8.3) diesel generator in a nuclear power plant is a RSP necessary function to demonstrate the operability, capability and availability of the unit on demand.
Periodic testing coupled with good preventive main-tenance practices will assure optimum equipment readiness and availability on demand.
This is the desired goal.
To achieve this optimum equipment readiness status the following requireme,nts should be met:
1 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 !crmation of gum and varnish deposits on the cylinder walls, intake and exhaust valves, pistons and piston rings, etc., and accumulation of un-burned fuel in the turbocharger and exhaust system.
The consequences of no load or light load operation are potential equipment failure due to t' gum and varnish deposits and firm in the engine exhaust system.
2.
Periodic surveillance testing should be per-formed in accordance with the applicable NRC guidelines (R. g. 1.108), and with the recom-mendations of the engine manufacturer.
Con-flicts between any such recommendations and the NRC guidelines, particularly with respect to test frequency, loading and duration, sould 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 inves-tigative testing of components which have a history 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 cemonstrated reliability, rather than repetitive repair and maintenance of the existing components.
Testing of the unit after adjustments of repairs have been made only et,httrm that the equipment is oper-able and does not necessarily maan that the root cause of the problem has been eliminated or alleviated.
4 3 0..'
SNUPPS Upon completion of repairs or maintenance and 4.
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, and test loads have been removed, and all valves are in the proper position to per-mit a manual start of the equipment.
After the unit has been satisfactorily started and load tested, return the unit to ready automatic standby service an'd under the control of the
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co9 trol room operator.
Provide a discussion of how the above requirements have been implemented in the emergency diesel gener-ator system design and how they will be considered i.e.,
by when the plant is in commercial operation, what means will be above requirements be enforced.
RESPONSE
FSAR Section 9.5.8.2.3 System Operation (Emergency Diesel 1.
addresses Engine Combustion Air Intake and Exhaust System) this as follows:
The diesel generator can be operated at no load to low loads (less than 20 percent) and rated speed for extended To reduce the possibility of periods (up to 30 days).
accumulation of combustion and lube oil products in the exhaust system at the lower loads, the engine will be operated at 50 percent or higher loads for short periods at stipulated time intervals, as recommended by the engine manufacturer.
l The diesel generator manufacturer recommends that in the event it is necessary to operate the engine for extended (over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) at from no load up to periods of time 20 percent of the engine rating, the engine should be l
run at about 50 percent load for one (or preferably more) 1-hour period during each subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - starting with the first hour of each 14-hour period in order to l
minimize the accumulation of products of combustion and Above lubricating products in the exhaust systems.
20 percent load rating, the engine may be run continu-ously as required with the recommendation that the engine parameters be monitored WEEEEEE and logged at least daily l
so as to be able to discover any problems early.
(Changes I
in exhaust temperatures are of particular interest. )
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430.3-2 l
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SNUPPS SNUPPS is in compliance with the requirements of Regula-i 2.
tory Guide 1.108.
Refer to FSAR Section 8.1.4.3 for details.
3.
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- 5.
With regard to emergency lighting, agenda item 430.6, the applicants will discuss emergency lighting in the diesel room and will clarify what areas are necessary for cold shutdown.
l 6.
With regard to agenda item 430.9, the applicants will clarify the draft response to indicate that buried piping is seismically designed.
7.
With regard to agenda item 430.11,.the applicants will. clarify that piping on the diesel is in accordance with ASME Code or discuss what piping does not meet code requirements and the standards to which they are designed.
8.
The applicants stated that they will provide additional information regarding the fuel oil storage tank filling procedures and expand on the discussion of the design of the system including the cross connect (agenda item 430.14).
9.
The applicants stated that they will provide the possible sources of fuel oil and distances from the plant (agenda item 430.15).
10.
With regard to agenda items 430.30 and 430.32, the applicants stated that they will provide additional information regarding the rocker arm lubrication system and a discussion of whether cooling of the lobe oil is required.
11.
With regard to agenda items 430.34 and 430.35, the applicants will provide further description related to blockage of the diesel intakes. They will also clarify that the starting circuits are not connected to the HVAC valves.
12.
The applicants stated that, they will provide additional information regarding the tornado missile protection of the diesel exhaust system (agenda item 430.38).
13.
The applicants stated that they will provide the valve closure time for the control, intercept and extraction valves (agenda item 430.41).
14.
With regard to agenda item 430.42 the applicants will address the effect of failures of the turbine overspeed protection system in the event of high energy line breaks.
15.
The applicant will provide additional information regarding hydrogen storage (agenda item 430.43).
16.
The applicants will clarify whether the reactor trips on loss of the condenser vacuum (agenda item 430.51).
17.
With respect to agenda item 430.54, the applicants will clarify that the bypass valves are stroked and will provide additional information regarding the testing frequency.
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' 18.
We expressed a concern that section 8.3.1.3 of the FSAR is too generally written regarding color coding. The 6erminology, " appropriate color",
on page 8.3-23 should be defined and explained so that it is explicitly clear what rules are to be followed in color coding wiring within a cabinet or panel. Such an explanation will serve as an aid to NRC reviewers and field inspectors.
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jc s c Lc7V (wgv Gordon E. Edison, Project Manager Licensing Branch No.1 1
i Division of Licensing s
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A'exander W. Dromerick, Project Manager Licensing Branch No.1 Division of Licensing
Enclosure:
As stated cc: See next page i
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SNUPPS
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430.4 The availability on demand of an emergency desel (8.3) generator in dependent upon, among other things, RSP the proper functioning of its controls and moni-toring instru. mentation.
This equipment is general-ly 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 vibration induced wear on skid mounted control and monitoring instrumenta-tion.
This sensitive instrumentation is not made to withstand and function accurately for prolonged periods under continuous vibrational stresses nor-mally encountered with internal combustion engines.
Operation of sensitive instrumentation under this environment rapidly deteriorates calibration, accuracy and control signal output.
Therefore, except for sensors and other equipment that must be directly mounted on the engine or associated piping, the controls and monitoring in-strumentation should be installed on a free stand-ing floor mounted panel separate from the engine skids, and located on a vibration free floor area.
If the floor is not vibration free, the panel shall be equipped with vibration mounts.
Confirm your compliance with the above requirement or provide justification for noncompliance.
RESPONSE
Controls and monitoring instruments for the SNUPPS emergency floor-diesel generators are installed in free standing, mounted control panels, separate from the engine skid.
Only those sensors and other electrical controls (solenoid valves and governor actuator) which send or receive signals to and from the control panels are mounted on the diesel generator unit.
Although the SNUPPS panels are mounted on the same floor as the engine skid they do not employ vibration mounts because the floor is of sufficient mass to dampen the engine vibra-tions.
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430.4-1 l
SNUPPS The information regarding the onsite communications 430.5 system (Section 9.5.2) does not adequately cover the system capabilities during transients and ac-cidents.
Provide the following information:
(a)
Identify all working stations on the plant sita where it may be necessary for plant per-sonal to communicate with the control room or the emergency shutdown panel during and/or following transients and/or accidents (in-cluding firms) in, order to mitigat.e the con-sequences of the. event and to attain a safe cold plant shutdown.
(b)
Indicate the maximum sound levels that could exist at each of the above identified working stations for all transients and accident con-ditions.
i (c)
Indicate the types of communication systems available at each of the above identified working stations.
(d)
Indicate the maximum background noise level that could exist at each working station and 3
yet reliably expect effective communication with the control room using:
1.
the page party communications systems, and 2.
any other additional communication system provided that working station.
Describe the performance requirements and (e) tests that the above onsite working stations communication systems will be required to pass in order to be assured that effective communi-cation with the control room or emergency shutdown panel is possible under all condi-tions.
l (f)
Identify and describe the power source (s) provided for each of the communications systems.
(g)
Discuss the protective measures taken to assure a functionally operable onsite com-l The discussion should munication system.
include the considerations given to component failures, less of power, and the severing of a communication line or trunk as a result of an accident or firm.
430.5-1
SNUPPS
RESPONSE
(a)
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(f)
The telephone, public address, and maintenance jack (g) systems each have their own dedicated conduit systems.
To the extent practicable these conduits are embedded to minimize the systems exposure to hazards.
A malfunction of a given system component will disable that particular component and hence, communications would have to be resumed using one of the remaining systems from that station.
An accident, such as a fire, that disables a PA system loop would disable that par-I ticular communications loop. and thus communications would have to revert to one of the remaining systems for that entire loop.
The maintenance jack system, if I
disabled by fire, would require repair before it could l
be restored to service.
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430.5-2 7-.,,.
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SNUPPS 430.6 Identify the vital areas and hazardous areas where emergency lighting is needed for safe shutdown of the reactor and the evacuation of personnel i'n the event cC an accident.
Tabulate the lighting system provided in your design to accommodate those areas so identified.
Include the degree of compliance to Standard Review Plan 9.5.1 regarding emergency lighting requirements in the event of a firm.
RESPONSE
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The areas that may be needed to be manned for safe shutdown in addition to the control room are listed in FSAR Section 9.5.2.
The available lighting in these areas is as follows:
1.
Reactor Trip Switchgear Rooms:
Battery packs, standby lighting, and normal lighting.
2.
Class 1E switchgear rooms:
Same as (1) 3.
Penetration rooms:
Same as (1) 4.
Auxiliary building HVAC rooms:
Same as (1) 5.
Diesel generator rooms:
Battery packs and normal lighting 6.
Auxiliary building basement corridor:
Same as (1) amm6 q k % =jg )) U, B tt y
ac Auxiliary shutdowa panel rooms:,f 7.
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e The normal lighting fixtures are powered from the non-Class 1E power system and provide the normal station lighting.
The standby lighting fixtures are similar to the normal lighting fixture, except that they are powered from the Class lE power system and are shed upon an SIS signal.
The battery packs are realed beam, self contained battery units rated 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that are normally connected to the normal lighting system to maintain battery charge.
They automatically transfer to internal batteries upon loss of ac.
For a discussion of lighting requirements to fight fires, refer to h 1.f./.
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430.6-1
SNUPPS 430.7 rescribe the instruments, controls, sensors and alarms prc 'ided for monitoring the diesel engine (9.5.4) feel oil storage and transfer system and describe their fuction.
Discuss the testing necessary to maintain and assure a highly reliable instrumenta-tion, controls, sensors and alarm system and where the alarm are annunciated.
Identify the tempera-ture, pressure and level sensors which alert the operator when these parameters are exceed the ranges recommended by the engine manufacturer and describe what operator actions arm required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss the system interlocks provided.
(SRP 9.5.4, Part III, item 1).
RESPONSE
All applicable instruments, controls, sensors, and alarms for the diesel fuel oil storage cnd transfer system are shown on FSAR Figures 9.5.4-1 and 9.5.6-1, Sheets 1 and 2.
Those levels and pressures which are alarmed directly in the control room are fuel oil storage tank low level and low-low fuel oil syctem strainer high pressure differential,
- level, and day tank low level, high level, and low stand pipe level.
The level of fuel oil in the day tank is indicated in the control room.
l The diesel engine basket strainer high pressure differential l
fuel filter high differential pressure alarm, and low l
- alarm, fuel oil pressure alarm all result in a control room " diesel l
trouble" light anu alarm.
An operator would go to the alarm panel in the diesel generator room to determine the specific alarm.
None of the above malfunctions will result in harmful effects to the diesel engine apd none w' 1 result in the trip ing of the diesel engine. A O wp~,s,&
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430.7-1
SNUPPS 430.0 The diesel generator structures are designed to (9.5.4) seismic and torrado criteria and ar 2 isolated from one another by a reinforced concrete wall barrier.
Describe the barrier (including openings) in more detail and its capabilityto withstand the effects of internally generated missiles resulting from a crankcase explosion, failure of one or all of the starting air receivers, or failure of any high or moderate energy line and initial flooding from the cooling system so that the assumed effects will not result in loss of an additiona? generator.
(SRP DSWS G 9.5.4, Part III, Item 2).
"'The barrier separating the two diesel generators is a 2-foot-thick reinforced concrete wall.
The wall reinforcement is such that the wall is capable of withstanding the impact of all the externally generated missiles identified in Table 3.5-1 of the Standard Plant FSAR.
There are four openings in the wall, but they are located within 3 feet of the north end of the building.
This location and the small size of the openings (1 foot square or smaller) will effec-
{tivelypreventanyinternallygeneratedmissiles from passing through the opening and d ing
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wu NUPPS diesel ngine is a low speed (514 rpm) engine which has a vented crank case.
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manufacturer has never experienced nor knows of M,
any crank case explosions or engine failures which resulted in missiles.
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tornado missile impact.
In the highly unlikely l
event that the engine did generate an external missile, the energy of that missile would be sig-nificantly less than that of the tornado missile.
The air tanks are ceismically mounted on their skids, which are in turn seismically anchored to l
the floor.
Rupture of a tank would not generate r
missiles whose energy exceeds that of a tornado missile.
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There are no igh energy lines in the diesel gener-I ator buildi The only moderate energy lines are thoca dire tly associated with each diesel engine.
Therefore failure of a moderate energy line would be the diesel single failure.
There are no open pe etrations between rooms, and therefore, flooding of one room will not degrade the opposite diesel I
e gine.
430.8-1
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SNUPPS 430.9 Figure 9.5.4-1 and the FSAR text state that the fuel (9.5.4) oil storage tank fill and vent lines are non-seismic.
We require these lines to be designed seismic Cate-gory I and Quality Group C.
Conform your compliance with this position.
Also describe the design provi-sions made to protect the fuel oil storage tank fill and vent lines from damage by tornado missiles.
(SRP 9.5.4, Part II).
RESPONSE
The fuel oil storage tank vent and all lines are'nonseismic above grade only (refer to FSAR Figure 9.5.4-1).
The lines rise above grade within the diesel generator building and then penetrate the building wall to the outside.
The portion of these lines within the building is seismically restrained.
Failure of these lines does not jeopardize operation of the diesel.
If the fill line is unus*able, the tank manhole can be used as toth the fill and vent connection if the tanks have to be replenished.
In addition to the transfer line, the storage tank and the day tank are also interconnected via the overflow and recirc line.
Snould the storage tank vent be totally restricted, venting can occur through the day tank.
(It should be noted that the vent sizes are based on filling operations and not engine operations.
The operating vent requirements are In the significantly less than those required for filling.).
unlikely event that both tank vents are completely restricted, either tank manhole could be loosened to provide venting.
Since failure the nonseismic storage tank vent and fill lines will not prevent system operation, no tornado protection is provided.
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SNUPPS 430.11 The FSAR text and Table 3.2-l' states that the com-(3.2) ponents and piping systems for the diesel generator (9.5.4) auxiliaries (fuel oil system, cooling water, lubri-(9.5.5) cation, air starting, and intake and combustion system) that are mounted on the auxiliary skids are (9.5.7)
(.5.8) designed seismic Category I and are ASME Section III Class 3 quality.
The engine mounted components and piping are designed and manufactured to DEMA stan-dards, and are seismic Category I.
This is not in accordance with Regulatory Guide 1.26 which requires the entire diesel generator auxiliary systems be designed to ASME Section III Class 3 or Quality Group C.
Provide the industry standards that were used in the design, manufacture, and inspection of Also show the engine mounted piping and components.
on the appropriate P&ID's where the Quality Group Classification changes from Quality Group C.
RESPONSE
Only those components and piping supplied with the standard diesel engine and which markeup an integral part of the engine are not Quality Group C.
These include such items as the injector nozzles and pumps, the engine-driven pumps, piping fabricated as a part of the engine block, and flex connec-tions.
The FSAR figures for the diesel engine auxiliary systems differentiate between seismic and nonseismic portions of the systems and identify those portions of the systems provided by the diesel engine manufacturer.
The standards used in the design, manufacture, and inspection of the nonQuality Group C components are the manufacturer's standards, developed, from his manufacturing and testing experience.
430.11-1
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SNUPPS Discuss the means for detecting or preventing growth 430.10 (9.5.4) of algae in the diesel fuel storage tank.
If it were detected, describe the methods to be provided for cleaning the affected storage tank.
(SRP 9.5.4, Part III, Item 4).
RESPONSE
If any growth of algae should occur detection would be accom-plished by either periodic sampling of the fuel oil or visual inspection of the tank interior.. Should any algae be found a decision would be made at that time as to what methods of treatment would be employed to prevent future occurrences.
Cleanup would be a manunl operation.
Should any algae occur system, the system strainers and and get into the fuel oli filters would remove it before it kisteiad the diesel engine.
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430.10-1
SNUPPS 430.12 Discuss what precautions have been taken in the (9.5.4) design of the fuel oil system in locating the fuel oil day tank and connecting fuel oil piping in the diesel generator room with regard to possible expo-sure.to ignition sources such as open flames and hot surfaces.
(SRP 9.5.4, Part III, Item 6).
RESPONSE
The fuel oil day tank is located more than 20 feet horizontal-ly from the diesel engine and well below the insulated diesel exhaust piping and, therefore, wfll not be exposed to any high temperature surfaces.
There is no elevated fuel oil piping adjacent to the engine.
The fuel oil piping between the engine and the day tank drops down from the tank and runs along the floor until it reaches the engine.
The diesel engine itself sets on a 6-inch skid and therefore elevated above the floor.
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430.12-1 1
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o SNUPPS 430.13 Identify all high and moderate energy lines and (9.5.4) systems that will be installed in the diesel gener-Discuss the measures that will be taken (9.5.5) ator room.
(9.5.6) in the design of the diesel generator facility to (9.5.7) protect the safety related systems, piping and com-ponents from the affects of high and moderate energy (9.5.8) line failure to assure availability of the diesel generators when needed.
(SRP 9.5.4, Part III, Item 0 SRP 9.5.5, Part III, item 4, SRP 9.5.6, Part III, item 8; SRP 9.5.7, Part III, item 3; SRP 9.5.8, Part III, item 6c).
RESPONSE
There are no high energy lines in the diesel generator the and the only moderne energy lines in the diesel
- building, generator building are those directly associated with the operation of the diesel generator.
Suitable barriers and separation exists between the two diesel generator rooms so that the failure of a moderate energy system 'in one room would not affect the availability of the other diesel generator.
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SNUPPS 430.14 In section 9.5.4 of the FSAR you state that accu-(9.5.4) mulated sediment and moisture may be withdrawn, prior to adding a new fuel oil, through the sample nozzle to minimize the possibility of degrading the overall quality of the new fuel in the unlikely event that would require replenishment of fuel oil without interrupting operation of the diesel gener-ator.
This is unacceptable since the sample nozzle would only permit removal of accumulated moisture but not the sediment.
Discuss that provisions that will be made in the design of the fuel. oil storage fill system to minimize the creation of turbulance 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 qual-ity of the fuel to become unacceptable and could potentially lead to the degradation of failure of the diesel generator.
Two methods of minimizing this problem are suggested.
- 1) Design a fuel oil storage tank fill system that will minimize turbu-lence in the tank.
- 2) Cross connect the fuel oil storage tank of each diesel in a manner that will permit supply of fuel oil to either engine from either tank.
In this manner one tank could be filled while the other tank supplies fuel to the operating D/G.
After filling the tank fuel would not be drawn from the tank for a period of time to permit settling of sediment.
RESPONSE
As shown on FSAR Figure 9.5.4-1, the two fuel oil storage tanks are cross connected, such that one engine can be sup-plied from either tank.
However, this cross connection is nonseismic and therefore cannot be assured to retain its in-tegrity following a seismic event.
The isolation capability is seismically qualified.
Tank capacity is sufficient to supply the diesel with fuel l
l for 7 days under the worst fuel consumption possible and have a margin of fuel oil remaining in the tank.
The fill connection is located at one end of the tank and terminates at the top of the tank.
The pump suction is approximately 40 feet from the end of the tank where the fill line connects and takes suction several inches above the bottom of the tank.
Because of the relative location of the fill and suction lines some settlin'g of sediment will occur before reaching the pump suction.
Because the fill line discharges at the top of tank as the tank fills, distur-bance of the bottom sediment is reduced and maximum distur-bance will occur only during the initial filling process.
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430.14-1 1
SNUPPS The fuel oil system incorporates a wye strainer, basket strainer, and filter between the storage tank and the diesel engine (refer to FSAR Figures 9.5.4-1 and 9.5.6-1, Sheets 1 and 2.).
Any sediment disturbed during the filling of the tank will be removed before reaching the engine.
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430.14-2 i
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SNUPPS You state in section 9.5.4.3 that diesel oil is 430.15 (9.5.4) normally delivered to the site by tanker truck and if road transportation is unavailable, it can be delivered onsite by railroad tanker.
Discuss per sources where diesel quality fuel oil will be avail-able and the distances required to be travelled from the source to the plant.
Also discuss how fuel oil will be delivered onsite under extremely unfavorable environmental conditions including maximum probable flood conditions.
RESPONSE
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I SNUPPS 430.16 You state in section 9.5.4.2 that the diesel gener-(9.5.4) ator fuel oil storage tank is provided with an indi-vidual fill and vent line.
Indicate where these
' lines are located (indoor or outdoor) and the height these lines are terminated above finished ground grade.
If these lines are located outdoors discuss the provisions made in your design to prevent en-trance of water into the storage tank during adverse environmental condition including maximum probrble flood conditions.
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RESPONSE
The fuel oil storage tank fill and vent lines terminate out-side of the diesel generator building; however, they are routed underground from the tank to the building and from the building to the outside.
The vent line has a flame arrestor, which is goosenecked downward.
The bottom of the flame arrestor is approximately 15 feet above crade.
The fill connection in capped and penetrates the building wall at approximately 3 feet above grade.
The maximum probable flood level does not exceed grade and, therefore, the vent and fill connections are not subject to flood conditions.
As noted, the fill connection is capped and the vent goose-necked down and, therefore, neither will allow the entrance of water into the system during adverse environmental condi-tions.
430.16-1
SNUPPS 430.17 Discuss the design margin (excess heat removal (9.5.5) capability) included in the design of major com-ponents and subsystems of the D/G cooling water system (SRP 9.5.5, Part III, Item I).
RESPONSE
Heat exchanger design by the engine manufacturer is based on maximum heat rejection requirements and a specified.002 Because fouling factor and 95 F entering water temperature.
these design conditions are inherently conservative, the diesel engine cooling system contains a suitable margin for operation under all design conditions.
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SNUPPS 430.18 Provide the results of the failure mode and effects (9.5.5) analysis to show that failure of a piping connec-tion between subsystems (engine water jacket, lube oil cooler, governor lube oil cooler, and engine air inter-cooler) does not cause total degradation of the diesel generater cooling water system.
(SRP 9.5.5, Part III, Item la).
RESPONSE
The diesels are totally redundant and do not share systems, nor are there any interconnections between the two engine Therefore, no failure of or between any of cooling systems.
the engine cooling subsystems would result in any degradation of the other diesel engine.
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430.18-1
SNUPPS 430.19 Indicate the measures to preclude long-term corro-(9.5.5) sion and organic fouling in the diesel engine cool-ing water system that would degrade system cooling performance, and the compatability of any corrosion inhibitors or antifreeze compounds used with the materials of the system.
Indicate if the water chemistry is in conformance wit the engine manufac-turers recommendations.
(SRP 9.5.5, Part III, Item 3.)
RESPONSE
The SNUPPS engine cooling water characteristics have been reviewed and accepted by the diesel manufacturer.
The use of additives is not expected.
The manufacturer includes in his instruction manual cooling water treatment guidelines.
Treatment of the :::rgency service water system that serves the cooling water heat exchanger is described in Section 9.2 of each Site Addende. h,
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SNUPPS 430.20 You stated in section 9.5.5.2.3 the diesel engine (9.5.5) cooling water is treated as appropriate to minimize corrosion.
Provide additional details of your pro-posed diesel engine cooling water system chemical treatment, and discuss how your proposed treatment complies with the engine manufacturers recommenda-tions.
(SRP 9.5.5, Part III, Item ic).
RESPONSE
See Response to 430.19 d
2 430.20-1
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SNUPPS Describe the instrumentation, controls, sensors and 430.21 alarms provided for monitoring of the diesel engine (9.5.5) cooling water system and describe their function.
Discuss the testing necessary to maintain and assure a highly reliable instrumentation, controls, sensors,.
and where the alarms are annunciated.
and alarm system, Identify the temperature, pressure, level, and flow (where applicable) sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe what operator actiors are required during alarm conditions to prevent harmful e=affec'ts to the diesel engine.
Discuss the systems interlocks provided.
(SRP 9.5.6, Part III, item lc).
RESPONSE
sensors, and alarms for All applicable instruments, controls, the diesel cooling water system are shown on FSAR Figure 9.5.5-1, Sheets 1 and 2.
Those temperatures and pressures which are alarmed in the diesel generator room but result only in the general control room " diesel trouble" alarm are high jacket water temperature from the engine, low jacket water temperature from the engine, low jacket water pump discharge pressure, low jacket water expansion tank level, high intercooler water temperature from the engine, low intercooler water temperature from the engine, and low intercooler pump discharge pressure.
An operator would go to the alarm panel in the diesel generator room to determine the specific alarm.
There are no cooling water system alarms which alarm directly in the control room.
Local indication in the diesel generator room is provided for intercooler jacket water temperature to and from the engine, water temperature to and from the engine, water temperature from the generator outboard bearing, jacket, water pump dis-and intercooler pump discharge pressure.
charge pressure, None of the above malfunctions which alarm in the control room will result in harmful effects to the diesel or shutdown, except fpr the high jacket water temperature from the engine.
High jacket water temperature is sensed by four separately mounted temperature switches, each at an increasing tempera-l ture setpoint.
Operation of any one switch will found an alarm, and operation of any two will result in engine shut-down.
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SNUPPS 430.22 In section 9.5.8.2 of the FSAR, you state that "To (9.5.5) reduce the possibility of accumulation of combustion RSP and lube oil products in the exhaust system at the lower loads, the engine will be operated at 50 per-cent or higher loads for short periods at stipulated time intervals as recommended by the engine manu-facturer.
Provide the time duration of the "short periods" and the manufacture's recommended " time intervals", d
RESPONSE
Refer to our Response to J.30.03.
fWerequirethatthis" light load or no load operation" pro-cedure be made part of plant operating procedures.
Confirm /
Q ur compliance with this position.
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430.22-1
SNUPPS 430.23 Provide a discussion of the measures that have been (9.5.6) taken in the design of the standby diesel generator air starting system to preclude the feeling of the air start valve or filter with moisture and conta-y minants such as oil carryover and rust.
(SRP 9.5.6, Part III, item 1).
RESPONSE
The SNUPPS emergency diesel generator is started by using air admitted directly to the cylinder through an air start dis-tributor.
The air is stored in two separate reservoirs, whicn are charged from two separate compressors.
Dryness of the air is assured by use of a dessicant-type air dryer on each compressor.
The air dryers are of the automatic recharging type, using purge flow to effect re-charge of the dessicant.
They are designed to provide air dried to a dew point of -40 degrees F at the design flow rate of 31ACFM, which is well below the lowest design room temperature of 60 degrees F.
Air tempera-ture entering the dryers is regulated by coolers mounted of the compressors.
Oil carryover from the compressor is controlled by use of a prefilter upstream of the dryer; and dessicant carryover into the air system is prevented by pulsacion dampers upstream and after-filters downstream of the dryers.
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SNUPPS 430.24 Describe the instrumentation, controls, sensors and the diesel engine air (9.5.6) alarms provided for monitoring'their function.
starting system, and describe Describe the testing necessary to maintain a highly reliable instrumentation, control, sensors and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe any operator actions required during alarm conditions to prevent harmful affects to the diesel engine.
Discuss system interlocks provided.
Revise your FSAR accordingly.
(SRP 9.5.6, Part III, item 1).
RESPONSE
All applicable instruments, controls, sensors, and alarms for the diesel, starting air system are shown on FSAR Figure 9.5.6-1, Sheets 1 and 2.
The only system function which is alarmed in the diesel gener-ator room is low air system pressure.
This alarm also gener-This ates a general control room " diesel trouble" alarm.
malfuction will not result in any harmful effects to the diesel engine.
Local indication is provided for each starting air tank pres-sure and each starting air system pressure.
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SNUPPS 430.25 Expand your description of the diesel engine start-(9.5.6) ing system.
The FSAR text should provide a detail system description of what is shown on Figure 9.5.6-1.
The FSAR text should al:.o describe:
- 1) components and their function,
- 2) :nstrumentation, controls, sensors and alarms. and 3) a diesel engine starting In describing the diesel engine starting sequence.
sequence include the number of air start valves used and whether one or both air start systems are used.
RESPONSE
Refer to response to 430.24 for information relating to above art 2).
The diesel engine air start system components and their func-tions are described in FSAR Section 9.5.6.22.
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System operation is discussed in FSAR Section 9.5.6.2.3.
430.25-1
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SNUPPS 430.26 Provide the source of power for the diesel engine air starting system compressors and motor character-
- istics, i.e., motor hp, operating voltage, phase (s),
and frequer r.
Revise your FSAR accordingly.
RESPONSE
Refer to Table 9.5.6-1 for the response to this question.
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430.26-1 j
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SNUPPS For the diesel enginer lubiration system in Section 43L.27 (9.S.7) 9.5.7 provide the following information:
- 1) define the temperature differentials, flow rate, and heat removal rate of the interface cooling systen external to the engine and verify that these are in accordance with recommendations of the engine manufacturer;
- 2) discuss the measures that will be taken to maintain the required quality of the oil, including the inspection and replacement when oil quality is degraded; 3) describe the capability for detection and control of system leakage.
(SRP 9.5.7, Part II, Item 8a, 8b, 8c, Part II7, Item I.)
RESPONSE
1)
Requested information for lube oil cooler is given in FSAR Table 9.5.7-1.
Design information given in Table 9.5.7-1 is manufacturer's data.
2)
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. u-u e# oil level in the engine lube oil sump is Low 3) alarmed locally and generates a control room " diesel trouble" alarm.
The auxiliary lube oil tank and tne engine control sufficient lube oil to operate for 7 days, under the worst expected operating conditions, before lube oil would have to be added.
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SNUPPS 430.28 What measures have been taken to prevent entry of (9.5.7) deliterious materials into the engine lubication oil system due to operator error during rechargin of lubicating oil or normal operation.
(SRP 9.5.7, Part III, Item ic).
RESPONSE
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SNUPPS 430.29 Describe the instrumentation, controls, sensors and (9.5.7) alarms provided for monitoring the diesel engine lubication oil system ar.d describe their function.
Describe the testing necessary to maintain a highly reliable instrumentation, control, sensors and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufac-turer and describe any operator action required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss systems interlocks provided.
Devise your FSAR accordingly.
(SRP 9.5.7, Part III, item 1c).
RESPONSE
All appropriate instruments, controls, sensors, and alarms for the diesel engine lube oil system are shown on FSAR Figure 9.5.7-1, Sheets 1 and 2.
Those lube oil temperatures, pressures, and levels which alarm locally and result in a control room " diesel trouble" light and alarm are high lube oil temperature from engine, high lube oil strainer differential pressure, low lube oil pressure to engine, low lube oil sump temperature, high lube oil filter differential pressure, lube oil level control tank high level and low level, low lube oil pressure to rocker arms, rocker lube oil filter high differential pressure, and rocker lube oil reservoir high level.
In addition to the local and control room alarm for low lube oil pressure to the enginer, operation of any two of the three low lube pressure switches will initiate automatic shutdown of the engine.
None of the other malfunctions will requirg f'~ g I
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differential pressure, lube oil filter differential pressure, lube oil level control tank level, rocker lube oil filter differential pressure, and lube oil pressure to rocker armr.
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I SNUPPS Expand your description of the diesel engine lube 430.30 The FSAR test should include a detail oil system.
(9.5.7) system description of what is shown on figure The FSAR test should also describe:
9.5.7-1.
- 1) components and their function, and 2) a diesel generator starting sequence for a normal start and a emergency start.
Revise your FSAR accordingly.
RESPONSE
Refer to FSAR Sections 9.5.7.2.2 and 9.5.7.2.3 for component description and operation.
430.32 1 r additional details concerning Refer to response to prelube and rocker lube operations.
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SNUPPS 430.31 Provide the soure of power for the diesel engine (9.5.7) prelube oil pump, lube oil transfer pump, clean lube oil transfer pump and used lube oil tank transfer pump, and motor characteristics, i.e.,
motor hp, operating voltage, phase (s) and fre-quency.
Also provide the pump capacity and dis-charge head.
Revise your FSAR accordingly.
RESPONSE
The SNUPPS diesel eigine is equipped with a main lube oil pump, an auxiliary lube oil (keep warm) pump, a rocker lube oil pump, and a rocker prelube pump.
Refer to FSAR Table 9.5.7-1 for the requested information.
430.31-1
SNUPPS 430.32 In section 9.5.7.2 of the FSAR you state that pre-lubrication o the rocker arm assembly during standby conditions is done periodically in accor-dance with the enoine manufacturer's recommendations.
Provide the follawing:
We require that the electric prelube pump a.
(RSP) automatically prelube the rocker. arm assembly and that alarms be provided which alert the operator of pump failure to start on automntic prelubrication.
b.
Provide the manufacturer's periodic prelubri-cation recommendations.
Discuss how the lubricating oil in the rocker c.
arm assembly lubrication system is cooler during engine operation and kept warm to enhance engine _ starting during standby opera-tion.
RESPONSE
The SNUPPS emergency diesel generator includes an electric motor-driven prelube/keepwarm pump as an integral part of the lube oil system.
This pump circulates lube oil from the engine crankcase through a keepwarm heater and a filter, then into the main lube oil system, through a strainer, and into the enginer header.
During engine standby, this system provides continuous prelubrication and filtering of the oil
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During engine operation, charge at keepwarm temperature.
this system is used for continuous filtration of the' oil charge.
Additionally, the engine includes a separate rocker arm lubricatien system.
This system includes an electric motor-driven prelubrication pump, which is manually operated and is intended to be used prior to test starts.
It is not considered detrimental by the engine manufacturer for the rocker arms to operate with reduced oil pressure for the short period of time during which the engine is coming up to speed in an emergency start situation.
The components discussed above are shown in FSAR Figure 9.5.7-1, Sheets 1 and 2.
430.32-1
SNUPPS 430.33 Describe the instrumentation, controls, sensors and (9.5.8) alarms provided in the region of the diesel engine combustion air intake and exhaust system which alert the operator when parameters exceed ranges recommended by the engine manufacturer and describe any operator action required during alarm condi-tions to prevent harmful effects to the diesel et-line.
Discuss systems interlocks provided.
Revise your FSAR accordingly.
(SRP 9.5.8, Part III, item 1 & 4).
RESPONSE
All appropriate instruments, controls, sensors, and alarms for the diesel engine intake air and exhaust systems are shown on FSAR Figure 9.5.6-1, Sheets 1 and 2.
The only malfunction which results in an individual local alarm and a general control room " diesel trouble" alarm is low intake filter suction pressure.
Local indication is provided for combustion air temperature, manifold air pressure, intake filter suction pressure, and exhaust air temperature from each cylinder, for the left side before and after the turbo charger and for the right side before and after the turbocharger.
There are no instruments, controls, or sensors in the intake and exhaust air systems which will shu down the engine or when alarmed require immediate operato action.
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SNUPPS 430.34 Provide the results of an analysis that demon-(9.5.8) strates that the function of your diesel engine air intake and exhaust system design will not be de-graded to an extent which prevents developing full engine rated power or cause engine shutdown as a consequence of any meteorological or accident condition.
Include in your discussion the poten-tial and effect of other gases that may intention-ally or accidentally be released on site, on the performance of the diesel generator.
(SRP 9.5.8, Part III, Item 3).
RESPONSE
Refer to FSAR Section 9.5.8.2.3 for a discussion of the potential for contamination or restriction of the diesel intake air and restriction of the diesel exhaust flow.
RefertoeachSiteIddendur ection 2.2 for a discussion of the location oT any# gases.
.ed on site.
There are no such gases stored sufficiently close to the diesel building, that a release would impair operation of the diesel engine through ingestion of the gases into the engine.
430.34-1
SNUPPS 430.35 Discuss the provisions made in your design of the (9.5.8) diesel engine combustion air intake, D/G supply ventilation system, and exhaust system to prevent p Lssible clogging, during standby and in operation, from abnormal climatic conditions (heavy rain, freezing rain, dust storms, ice and snow) that could prevent operation of the diesel generator on demand.
(SRP 9.5.8, Part III, item 5).
RESPONSE
See response to 430.34.
430.35-l
SNUPPS fY 430.36 Figure 1.2-1 of the Callaway/FSAR shows the ESF (9.5.8) transformers located near the control / diesel gen-erator building complex.
An ESF transformer fire with the right meteorological conditions could degrade engine operation by the products of combus-tion being drawn into the D/G ventilation system which supplies D/G combustion air.
Discuss thr; provisions of your design (site characteristics, ventilation system and building design, etc) which preclude this event from occurring.
RESPONSE
As shown on Figure 1.2-27, the diesel ventilation intake is located in the diesel building penthouse, which is approxi-mately 20 feet below the top of the control building.
As shown on Figure 1.2-11, the ESF transformers are located to the north of the diesel intakes.
The control building intervenes between the subject ESF transformers (which are at approximately grade elevation) and the diesel intake.
The building wake effect of the control building and the buoyancy of the smoke and gases would tend to prevent smoke In from a potential ESpifire from entering the intakes.
addition, the intake louvers are located on the downstream side of the penthousej(from the fire) make smoke injection even less likely.
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SNUPPS 430.37 Experience at some operating plants has shown that (9.5.8) diesel engines have, failed to. start due to accumu-lation of dust and other delecerious material on electrical equipment associated with starting of the diesel generators (e.g., auxiliary relay con-tacts, control switches - etc.).
Described the provisions that have been made in your diesel generator building design, electrical starting system, and combustion air and ventilation air intake design (s) to preclude this condition to assure availability of the diesel generator on demand.
Also describe under normal plant operation what procedures (s) will be used to minimize accumulation of dust in the diesel generator room; specifically address concrete dust control.
In your response also consider the condition when Unit 1 is in operation and Unit 2 is under construction (abnormal generation of dust).
RESPONSE
The diesel generator manufacturer has the following provi-sions designed into their equipment:
All electrical equipment mounted outside of the control panels for the diesel generator unit are provided with either NEMA 4 or NEMA 12 enclosures.
The control panels themselves are of NEMA 12 construction with filtered venti-lation openings.
The D/G building ventilation system employs no filters and thus supplies outside air directly to the building.
- However, the system will operate primarily only when the D/G is operating and, therefore, minimizes the time during which it will operate.
The ventilation system intake is located on tcp of the D/G building and, therefore, will intake only those particulates which are airborne (no ground dust).
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SNUPPS 430.38 Section 9.5.8.2.2 and 3.2.2 of the FSAR state that (9.5.8) the portions of the EDEAIES outside the D/G build-(RSP) ing are non-seismic and Quality Group D.
This is unacceptable.
We require that these portions of the system also be designed seismic Category I and Quality Group C.
In addition we required also that the exhaust stacks located outside the D/G building be tornado missile protected.
Separation by distance does not constitute adequate protection.
Confirm your compliance with these positions.
RESPONSE
The portions of the EDEAIES outside of the building which are not Quality Group C are the diesel exhaust stacks.
The stacks are seismically supported ANSI B31.1 piping.
The stacks were not designed to Quality Group C requirements because the pressure boundary integrity of the stacks is not required for proper operation of the diesel engines.
They are, however, designed to seismic Category I criteria to prevent them from falling on any seismic Category I structure or equipment or preclude blockage of the exhaust flow follow-ing a seismic event.
The design of the stacks, stack re-straints, and their separation make it highly improbable that a tornado missile could damage both stacks such that both diesel engines would be inoperable.
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SNUPPS 430.39 Provide a general discussion of the criteria and (10.1) bases of the various steam and condensate instru-mentation systems in section 10.1 of the FSAR.
The FSAR should differentiate between normal operation instrumentation and required safety instrumentations.
RESPONSE
The criteria and bases of the various steam and condensate instrumentation are to monitor system variables tc provide maximum plant availability, automatic control of equipment, and identification of abnormal cdnditions.
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SNUPPS 430.40 The FSAR discusses tha main steam stop and control, (10.2) and reheat stop and intercept valves.
Show that a single failure of any of the above valves cannot disable the turbine overspeed trip functions.
(SRP 10.2, Part III, Item 3).
RESPONSE
Section 10.2.2.3.2 describes the component redundancy which precludes single failure of any main stop, control, inter-mediate stop, and intercept valve from resulting in rotor speed exceeding design overspeed.' All the above valves have independent operating controls and mechanisms.
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430.40-1
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SNUPPS i
430.41 In the turbine generator sectaan discuss: 1) the (10.2) valve closure times and the ctrangement for the main steam stop and control and the reheat stop and intercept valves in relation to the effect of a failure of a single valve on the overspeed control functions; 2) the valve closure items and extrac-tion steam valve arranoements in relation to stable turbine operation after a turbine generator system trip; 3) effects of missiles from a possible turbine generator failure on safety related systems or components.
(SRP 10.2, Part III, Items 3, 4.)
RESPONSE
Main stop and control valves, reheat stop and intercept valves, and extraction nonreturn valves' closure times, arrangements and single failure effects plus table turbine operation after a trip are described in Sections 10.2.2.2 and 10.2.2.3.2, Table 10.2-1 and Figure 10.4-6.
Turbine missiles are discussed in Section 3.5.1.3.
430.41-1
SNUPPS 430.42 Discuss the effects of a high and moderata energy (10.2) piping failure or failure of the connection from the low pressure turbine to condenser on nearby Discuss what safety related equipment or systems.
protection will be provided the turbine overspeed control system equipment, electrical wiring and hydraulic lines from the effects of a high or moderate energy pipe failure so that the turbine overspeed protection system will not be damaged to preclude its safety function.
(SRP 10.2, Part III, Item 3).
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sn w p No JERdERF hig / moderate energy pipe break or hazards analysis is performed for nonsafety-related turbine building piping or components.
However, Section 10.2.2.3.2 describes the following component redundancies which rotect the turbine overspeed control system's function fro the effects of high or moderate energy piping failures, Main stop valves / control valves Q
a.
b.
Intermediate stop valves / intercept valves Primary speed control / backup speed control c.
d.
Fast acting solenoid valves / emergency trip fluid system (ETS)
Speed control /overspeed trip / backup overspeed trip e.
Figures 1.2-32 and 1.2-33 show the physical separation between redundant stop/ control valves and intermediate stop/ intercept valves.
Failure of the low pressure tu.-bine/
condenser connection will draw air into the condenser and i
increase turbine backpressure until trip occurs as stated in Section 10.2.2.3.4.
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430.42-1 T
SNUPPS Describe with the aid of drawings, the bulk hydro-430.43 (10.2) gen storage facility including its location and distribution system.
Include the protective nea-sures considered in the design to prevent fires and explosions during operations such as filling and purging the generator, as well as during normal operations.
RESPONSE
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430.43-1
SNUPPS Provide a tabulation in your ?SAR showing the 430.44 (10.4.1) physical characteristics and performance require-ments of the main condensers.
In your tabulation include such items as; 1) the number of condenser tubes, material and total heat transfer surface,
- 2) overall dimensions of the condenser, 3) number of pauses, 4) hot well capacity, 5) special design features, 6) minimum heat transfer, 7) normal and maximum steam flows, 8) normal and maximum cooling water temperature, 9) normal and maximum exhaust steam temperature with no turbine by-pass flow and i
i with maximum turbine by*-pass flow, 10) limiting oxygen content in the condensate in cc per liter,
(
and 11) other pertinent data.
(SRP 10.4.1, Part III, item 1).
RESPONSE
Table 10.4-1 has been revised to include the requested i
~
information.
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I TABLE 10.4-1 w
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CONDt3tsEN DESIGN DATA r.
Wol' Creek Snte Callaway Site l '.
Item Multipsessuse, 3-shell Mattspressure. 3
- ell
[*
Type 7.8696 m 10' 7.8696 a 10' y
Design duty, Btu /hr-total 3 j
shells
- t. -f J
2.06/2.56/1.22 2.34/2.89/3.64
)
Shell pressuae w/s0 F circ.
(
water. inches flga L
{
500,000 530,000 1
Waterbon circulating flou, gpa l
i 31.5 Tubeside temperature rise. F 30.0 Full vacuum to 15 psig Full vacuum to 15 peig l
Design pressure-shell 1
159.000
,7 i
159.000 Hotwell storage capacity -
)
total 3 shells, gallon 70 and full vacuum
,?
10 and full vacuum Design pressure-channel, psig k
59,796 59,796 Number of tubes Tube material (l
(
90:10 CuNi 30455 Main bundle 30455 30455 Air cooler 30455 30455 Impangement area Surface ares, eg. ft.
900,000 900,000 Overal dimensions 100' g
800*
Length 90' 90*
Wadth 72' r
72' Iteight 1
f, I
Nu4er of tube pases I.
i Steam flow. Ib/br 7,940,886 NoesaI 7,940,886 Maximum 8,270,75 8,270,151 i
[
. Circulating Water Temp, F 80
(
80 Design 90 Maximum 95 l-Steam temperature, F 114
!!O l
Normal (avg.)
134 Manamum (without tutbine bypass) 134 141
[
141 Maatmum (with tusbine bypass
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TABI.E 10.4-1 (Cont.)
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Wolf Creek S ue Callaway Site item ASME Sect. VIII Div.
- 3. ANSI ASME Sect. VIII, Div. 1 ANSI l.'.
l Standards, llEl Star.dasds for Standasds, itE t Standands for 5
Applicable codes and standards:
N
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Si a. Su.f.m. Cona nue.s Ste.m Surf.<e Co.. dens s
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7 7
Effluent oxygen content, ppb y
3 (1) Only Callawey Unit I has 90-10 Cu-Hi with stainless steel in t..e air cooler g
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section and periphery area.
Callaway Unit 2 tutie mates mal is the name as Wolf Creek I
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SNUPPS Discuss the measures taken; 1) to prevent loss of 430.45 and 2) to prevnet corrosion /errosion of (10.4.1)
- vacuum, condenser tubes and components.
(SRP 10.4.1, Part III, Item 1).
RESPONSE
Measures taken to prevent loss of vacuum and the Section describing them include:
Hydrostatic test of condenser shell (10.4.1.4).
a.
Water seal for the LP turbine / condenser connection b.
expansion joint with level indication (10.4.1.2).
Provision of condenser vacuum pumps (two operational c.
and one standby) (10.4.2.2),
d.
Control room indication of circulating water pump status (Site Addendum Section 10.4.5).
Measures taken to prevent corrosion / erosion of condenser tubes and components:
Provision of 304 stainless steel tubes in the a.
impingement areas of all tub-bundles (Table 10.4-1).
b.
Feedwater/ circulating water chemistry control (Standard Plant Section 10.3.5) and Site Addendum Section 10.4.5).
1 l
l 430.45-1
SNUPPS 10.4.1.2
System Description
10.4.1.2.1 General Description The main condenser is a multipressure, three-shell, deaerating unit.
Each shell is located beneath its rerpective low-pres-sure turbine.
The tubes in each shell are oriented transverse i
to the turbine-generator longitudinal axis.
The three condenser shells are designated as the low-pressure l
shell, the intermediate-pressure shell, and the high-pressure shell.
Each shell has six tube bundles.
At the'two SNUPPS sites with a closed-loop circulating water system (Callaway and Wolf creek), circulating water flows in series through the three single-pass shells, as shown in Figure 10.4-1.
At Sterling (open-loop circulating water system), two-thirds of the circulating water flows in series through the single pass low-pressure and high-pressure s5e12s, and one-third of the circulating water flows through the two-pass interme-diate pressure shell, as shown in Figure 10.4-1.
Exhaust steam from the steam generator feedwater pump tur-bine is used to reheat the condensate in the condenser.
I Each hotwell is divided longitudinally by a vertical parti-l tion plate.
The condensate pumps take suction from these hotwells, as shown in Figure 10.4-2.
l The condenser shells are located in pits below the turbine building operating floor and are supported above the turbine l
building foundation.
Failure of or leakage from a condenser shell will only result in a minimum water level in the condenser pit.
Expansion joints are provided between each turbine exhaust opening and the steam inlet connections of the condenser shell.
Water seals are provided around the entire outside periphery of these expansion joints.
Level indication provides detection of leakage through the expan-sion joint.
The hotwells of the three shells are inter-connected by steam-equalizing lines.
Four low-pressure feedwater heaters are located in the steam dome of each l.
shell.
Piping is installed for hotwell level control and condensate sampling.
10.4.1.2.2 Component Description Table 10.4-1 provides the design data for each condenser shell for both the closed loop and open loop circulating water systems.
10.4.1.2.3 System Operation During normal operation, exhaust steam from the low-pressure turbines is directed into the main condenser shells.
The condenser also receives auxiliary system flows, such as feedwater heater vents and drains and feedwater pump turbine exhaust.
10.4-2 l
SNUPPS 430.46 Indicate and describe the means of detecting and (10.4.1) controlling radioactive leakage into and out of the condenser and the meana for processing exces-sive amounts.
(SRP 10.4.1, Part III, Item 2).
RESPONSE
The means of detecting, controlling, and processing radio-active leakage into and out of the condenser resulting from a steam generator tube leak are discussed in Chapter 11.0.
The means for detecting and controlling radioactive leakage I
into and out of the condenser are. described in Sections l
11.5.2.2.2.2, 11.5.2.2.2.3, 11.5.2.2.3.4, and 11.5.2.3.2.1.
Processing of excessive radioactive leakage is discussed in l
Sections 11.2.2 and 11.3.2.
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430.46-1
SNUPPS Discuss the measures taken for detecting and 430.47 (10.4.1) controlling and correcting condenser cooling water leakage into the condensate' stream.
(SRP 10.4.1, Part III, Item 2).
RESPONSE
The measures taken for detecting, controlling, and correct-ing condenser cooling water leakage into the condensate stream are discussed in Section 10.4.1,as follows.
Circulating water leakage occurring within the condenser is detected and alarmed in the control room by monitoring the J
condensate leaving each hotwell (six monitoring points altogether).
This information permits determination of l
which tube bundle has sustained the leakage.
Steps may then,
be taken to isolate and dewater that bundle and it water kboxesand, sWDsequently, repair or plug the leaking tubes.
Conductivity and sodium content of the condensate from each condenser shell is monitored to provide an indication of l
condenser tube leakage.
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l 430.47-1
SNUPPS 430.48 Provide the permissible cooling water inleakage (10.4.1) and time of operation with inleakage to assure that condensate /feedwater quality can be main-tained within safe limits.
(SRP 10.4.1, Part III, item 2).
RESPONSE
The following information is provided in Section 10.4.6, Condensate Cleanup System.
Allowable condenser inleakage is " limited to levels that will not require continuous regeneration of a demineralizer bed more than once every 2 days.
This limitation is based on the capacity of the secondary liquid waste evaporator which The service run for each processes regenerative wastes.
demineralizer is terminated by either high differential pressure or high cation conductivity or sodium content is the demineralizer effluent water.
Alarms for each of these monitoring points are provided to ensure that condensate /
i
! feedwater quality is maintained.
430.48-1
SNUPPS 430.49 In section 10.4.1.4 you have discussed tests and (10.4.1) initial field inspection but not the frequency and extent of inservice inspection of the main con-denser.
Provide this information in the FSAR.
(SRP 10.4.1, Part II).
RESPONSE
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SNUPPS 430.50 Indicate what design provisions have been made to (10.4.1) preclude failures of condenser tubes or components from turbine by-pass blowdown or other high tempera-ture drains into the condenser shell.
(SRP 10.4.1, Part III, item 3).
RESPONSE
'See revised Section 10.4.1.2.3.
'"~
Sparger piping is provided for distribution of turbine Orifices bypass discharge and other high tTemperature drains.
are provided internal to the spargers where necessary for pressure reduction prior to distribution within the condenser.
Where sparger piping cannot be utilizied due to space limita-l tions, baffles are provided to direct the discharge away from the tubes and other condenser components.
Pressure reducing orifices are provided in the drains piping outside the condenser, where required.
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S 430.50-1
SNUPPS Hotwell level controls provide automatic makeup or rejection of condensate to maintain a normal level in the condenser hotwells.
On low water level in a hotwell, the makeup con-trol valves open and admit condensate to the hotwell from the condensate storage tank.
When the hotwell is brought to within normal-operating range, the valves close.
On high i
water level in the hotwell, the condensate reject control valve opens to divert condensate from the condensate pump discharge (downstream of the demineralizers) to the con-densato storage tank; rejection is stopped when the hotwell level falls to within normal openating range.
Sparger piping is provided for distribution of turbineOrifices bypass discharge and other high temperature drains.
are provided internal to the spargers where necessary for pressure reduction prior to distribution within the condenser.
Where sparger piping cannot be utilizied due to space limita-l l
tions, baffles are provided to direct the discharge away from the tubes and other condenser components.
Pressure reducing orifices are provided in the drains piping outside
{
the condenser, where required.
The main condenser, with the assistance of auxiliary steam at low loads, deaerates the condensate so that dissolved oxygen does not exceed 7 ppb over the entire load range.
l l
Both the air inleakage and the noncondensable gases con-l tained in the turbine exhaust are collected in the condenser l
and removed by the condenser air removal system.
During the initial cooling period after plant shutdown, the main condenser removes residual heat from the reactor coolant system via the turbine bypass system.
The main condenser receives up to 40 percent of VWo main steam flow through the turbine bypass valves.
If the condenser is not available to receive s'.eam via the turbine bypass system, the reactor coolant system can be safely cooled down by discharging steam through the atmospheric relief valves or the main steam safety valves, as described in Section 10.3.
Circulating water leakage occurring within'the condenser is detected and alarmed in the control room by monitoring the condensate leaving each hotwell (six monitoring points altogether).
This information permits determination of which tube bundle has sustained the leakage.
Steps may then be taken to isolate and dewater that bundle and its water boxes and, subsequently, repair or plug the leaking tubes.
During normal operation and shutdown, the main condenser has a negligible inventory of radioactive contaminants.
Radio-active contaminants may enter through a steam generator tube leak.
A discussion of the radiological aspects of primary-to-secondary leakage, including anticipated operating concentra-l tions of radioactive contaminants, is included in Chapter 11.0.
No hydrogen buildup in the main condenser is anticipated.
10.4-3
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SNUPPS 1
The failure of the main condenser and the resulting flooding will not preclude operation of any essential system because no safety-related equipment is located in the turbine build-ing, and the water cannot reach the equipment located in the auxiliary building.
Refer to Section 10.4.5.
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SNUPPS 430.51 Discuss the effect of loss of main condenser (10.4.1) vacuum on the operation of the main steam iso-lation valves (SRP 10.4.1, Part III, item 3).
RESPONSE
Loss of main condenser vacuum does not trip the main steam isolation valves.
Loss of main condenser vacuum trips the turbine and blocks turbine bypass.
The effects of potential failure modes on the NSSS and turbine system are adaressed in Sections 15.1.4, 15.2.3, and 15.2.5.
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SNUPPS 430.52 Provide additional description (with the aid of (10.4.4) drawings) of the turbine by-pass system (condenser dump valves and atmosphere dump valves) and asso-ciated instruments and controls.
In your discus-sion include:
- 1) the size, principle of operation, construction and set points of the valves, 2) the malfunctions and/or modes of failure considered in the design of the system.
RESPONSE
Condenser Dump Valves Section 10.4.4.2.1 and Figure 10
'-1, Sheet 3 provide a description of the turbine bypass system and the condenser dump valves.
The condenser dump valves are air actuated, carbon steel, 8 inch, 1,500 pound globe valves.
The valves are pilot-operated, spring-opposed, and fail closed upon loss of air or loss of power to the control system, as stated in Section 10.4.4.2.2.
Section 7.7.1.8 and Figures 7.2-1, Sheet 10 and 10.3-1, Sheet 3 described the associated instruments and controls.
The malfunctions and failure modes considered in system design and their effect on the NSSS and turbine system are addressed in Sections 15.1.4 and 15.2.3.
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Section 10.3.2.2, Table 10.3-2.andi gure 10.3-1 Sh t1 provide a description of the'Itmcepheric d=p voldes.ee The W A.
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atmospheric & mp va d are air actuated, carbon steel, 8 inch, 1,500 pound glove valves.
The valves are opened by pneumatic pressure and closed by spring action as stated in Section 10.3.2.2.
Section 7.4.1.2 and Figures 7.2-1, Sheet 10 and 10.3-1, sheet 1 describe the associated instru-The malfunctions and failure modes ments and controls.
considered in the system design are addressed in Section I
7.4.1.2 and Section 15.1.4.
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430.52-1
SNUPPS POWER-OPERATED ATMOSPHERIC RELIEF VALVE - A power-operated, atmospheric, relief valve is installed on the outlet piping The four valves are installed to from each steam generator.
provide for controlled removal of reactor decay heat during normal reactor cooldown when the main steam isolation valvesThe are closed or the turbine bypass system is not available.
valves will pass sufficient flow at all pressures to achieve a 50 F per hour plant cooldown rate.
The total capacity of the four valves is 15 percent of rated main steam flow at steam The maximum actual capacity of generator no-load pressure.
the relief valve at design pressure is limited to. reduce the magnitude of a reactor transient if one valve would inad-vertently open and remain open.
The atmospheric relief ",'"es are air operated carbon steel, l
8 inch 1,500 pound globs
.1ves, supplied by a safety-related and controlled air supply (as described in Section 9.3.1),
A nonsafety-related air supply is from Class IE sources.
available during normal operating conditions.
The capability for remote manual valve operation is provided in the main The valves control room and at the auxiliary shutdown panel.
are opened by pneumatic pressure and closed by spring action.
SAFETY VALVES
'Jhe spring-loaded main steam safety valves provide overpressure protection in accordance with the ASME Section III code requirement for the secondary side of the There are five steam generators and the main steam piping.Table 10.3-2 valves installed in each main steam line.
identifies the valves, their sct pressure, and capacities.
The valves discharge directly to the atmosphere via vent c
The maximum actual capacity of the safety valves at I
stacks.
the design pressure is limited to reduce the magnitude of a reactor transient if one of the valves would open and remain open.
MAIN STEAM ISOLATION VALVES AND BYPASS ISOLATION VALVES - One MSIV and associated bypass isolation valve (BIV) is installed I
in each of the four main steam lines outside the containment l
and downstream of the safety valves.
The MSIVs are installed to prevent uncontrolled blowdown from more than one steam The valves isolate the nonsafety-related portions generator.
The valves from the safety-related portions of the system.
are bidirectional. double disc, parallel slide gate valves.
Stored energy for closing is supplied by accumulators which contain a fixed mass of high pressure nitrogen and a variable For emergency closure, l
mass of high pressure hydraulic fluid.
a solenoid is energized which causes the high pressure hydrau-lic fluid to be admitted to the top of the valve steam driving piston and also causes the fluid stored below the piston to be Two separate pneumatic / hydraulic dumped to the fluid reservoir. Electrical solenoids for the power trains are provided.
separate pneumatic / hydraulic power trains are energized from The valves are designed to close separate Class IE sources.
10.3-4 n
SNUPPS operation of the main steam, power-operated, relief valves and spring-loaded safety valves prevents overpressurization of the main steam system.
There are 12 turbine bypass valves.
Seven valves discharge into the low pressure condenser, four valves discharge into the intermediate condenser, and a single valve discharges into the high pressure condenser.
The system is arranged in this manner to allow for the differences in the heat sink capacities of the three condenser shells.
The heat sink capacity of any one condenser she,ll is limited by. the admin-istrative limit of 5 inches Hga condenser pressure imposed on turbine operation by the turbine-generator manufacturer.
The low pressur3 condenser is the largest heat sink, since it normally operates at the lowest pressure.
The steam bypassed to the main condenser is not normally radioactive.
In the event offprimary-to-secondary leakage, it is possible for the bypassed steam to become radioactively contaminated.
A full discussion of the radiological aspects of primary-to-secondary leakage is contained in Chapter 11.0.
10.4.4.2.2 Component Description The TBS contains 12 air-actuated carbon steel, 8 inch, 1,500 pound globe valves.
The valves are pilot-operated, spring-opposed, and fail closed upon loss of air or loss of power to the control systea.
Sparger piping distributes the steam within the condenser.
Isolation valves permit maintenance of the bypass valve while the plant is in operation.
10.4.4.2.3 System Operation The TBS, during normal operating transients for which the plant is designed, is automatically regulated by the reactor coolant temperature control system to maintain the programmed coolant temperature.
The programmed coolant temperature is derived from the high pressure turbine first stage pressure, which is a load reference signal.
The difference between programmed reactor coolant average temperature and measured l
reactor coolant average temperature is used to activate the I
steam dump system under automatic control. The system operates l
l in two fundamental modes.
In one mode, two groups of six valves each trip oper; sequentially in approximately 3 seconds.
This operational mode is activated during a large reactor-to-turbine power mismatch.
In the second mode, four groups of three valves each modulate open sequentially in approximately 10 seconds.
A logic diagram is shown in Figure 7.2-1 (Sheet 10).
When the plant is at no load and there is no turbine load reference, the system is cperated in a pressure control mode.
The measured main steam system pressure is compared i
i 10.4-12
O SNUPPS 430.53 Section 10.4.4 of the FSAR describes the turbine (10.4.4) bypass system and states that the TBS dumps steam to the condenser through condenser spargers.
Figure 10.3.1, sheet 3 in the FSAR shows the It turbine bypass as described in Section 10.4.4.
also shows six 3 inch lines branching off the TBS lines upstream of the TBS valves.
These lines are labelled "To condenser Sparger" and seem to have normally open valves.
Explain the purpose of these lines and the status of these valves.
RESPONSE
The purpose of these lines in steam supply to the condenser hotwell spargers used for deaeration of the condensate, as described in Sections 10.3.5 and 10.4.3.2.3.
The valves in phantom on Figure 10.3.1, Sheet 3 are shown on P&ID M-02AD01 (Figure 10.4.2, Sheet 1) as normally closed.
430.53-1
. ~.
SNUPPS 430.54 In section 10.4.4.4 you have discussed tests and (10.4.4) initial field inspection but not the frequency and extent of ire. service testing and inspection of the turt,ine by-pass system.
Provide this information in the FSAR.
(SRP 10.4.4, Part II).
RESPONSE
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I 430.54-1
SNUPPS 1
430.55 Provide the results of an analysis indicating that failure of the turbine by-pass system high energy line will not have an adverse effect or preclude operation of the turbine speed control system or any safety related components or system located close to the turbine by-pass system.
(SRP 10.4.4, Part III, item 4).
RESPONSE
See response to Que.ation 430.42.. There is no safety-related equipment in the vicinity of the turbine bypass system, as stated in Section 10.4.4.3.
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430.55-1
7-
.1
,. o Meeting May 14, 1981 Union Electric Co.
Callaway Plant and Wolf Creek' Station Attendance List NRC A. W. Dromerick R. J. Giardina A. R. Ungaro
-G. Edison M0 PSC R. M. Fluegge SNUPPS R. L. Stright Bechtel L. L. Harvey P. A. Ward J. Prebula KG&E E. Tarver
'G. Rathbar.
D. Walsh N. Hoadley Union Electric K. R. Bryant A. C. Passwater r
r
e eI ao MEETING
SUMMARY
DISTC'S i,. Lea r Docket File MM 2 7 N f4RC PDR WJonns C. PC.
Ski
- t LocakR0ha TIC /t4 SIC /T
- r.
't. Canarcya
- 2. T.o.ztoczy fl. Hughes W. Haass LD#1 Reading O. Muller H. Denton R. Rillard E. Case D. Eisenhut W. Regen
- 0. Ross
/
R. Purple B. J. Youngblood P. Check A. Schwencer Chic'. Power Systems Branch F. Miraglia
- 0. Par-J. Miller F. Rosa ~
G. Lainas W. 2.'.l e r R. Vollmer W. Kreger R. nouston i
J. P. Knight Chief, Raciological Assessment Branch R. Bosnak F. Schauer L. Ruoenstein R. E. Jackson T. Speis Dromerick/ Edison Project Manager MSrinivasan Attorney, OELD J. Stel:
M. Rushbrook S. Hanever 0IE (3)
W. Gammill ACRS (16)
T. Murley R. Tedesco
.F. Schroeder D. Skovholt M. Ernst f1RC
Participants:
R. Baer C. Berlinger "I*I ADromerick, RJGiardina, ARUrgaro, GEdison G. Knignton l
A. Thadani l
D. Tondi J, Kramer D, Vassallo P. Collins D. Ziemann l
l bec: Applicant & Service List l
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r e
-