ML20004D881
| ML20004D881 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/03/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TASK-08-02, TASK-8-2, TASK-RR LSO5-81-06-010, LSO5-81-6-10, NUDOCS 8106100261 | |
| Download: ML20004D881 (15) | |
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June 3, 1981 s Fi'i$
Docket No. 50-245 LS05-81-06-010
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Nuclear Engineering and Operations p@
Northeast Nuclear Energy Company Post Office Box 270 i4 Hartford, Connecticut 06101
Dear Mr. Counsil:
SUBJECT:
SEP TOPIC VIII-2, EMERGENCY GENERATORS (MILLSTONE NUCLEAR POWER STATION, UNIT 1)
Enclosed is a revised copy of our contractor's evaluation of Systematic Evaluation Program Topic VIII-2, Emergency Generators.. This report has been revised to reflect the additional comments provided by your letter of April 13, 1981.
Please note that the conclusions of the enclosed evaluation (0111J) are different from those in our February 13, 1981 letter (enclosing Report lil1F).
The number and kinds of gas turbine trips that are not bypassed or are not redundant concern both the staff and our support contractor. We are unable to state that the probability of successful gas turbine operation under emergency conditions is equivalent to that of the diesel because of these concerns. Conversely, we cannot adequately estimate the consequences of a failure of these trips to function when required, as compared with our experiences with diesel engines. Accordingly, we suggest that we discuss this issue in a telephone conference to be l
arranged at our mutual convenience.
This evaluation will be a basic input to tne staff's SER on this topic for your facility. This topic assessment may be revised in the future if your facility design is changed or if NRC criteria relating to this topic are modified before the integrated assessment is completed.
Sincerely.
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Dennis M. Crutchfield, Chief Operating Reactors 3 ranch !5 Division of Licensing, 8.106100/6/
3 Mr. W.G. Counsil 4
Enclosure:
SEP Topic VIII-2 cc w/ enclosure:
William H. Cuddy, Esquire John F. Opeka Day, Berry & Howard Systems Superintendent Conselors at Law Northeast Utilities Service Company One Constitution Plaza Post Office Box 270 Hartford, Connecticut 06103 Hartford, Connecticut 06101
. Natural Resources Defense Council Connecticut Energy Agency 917 15th Street, NW ATTN: Assistant Director Washington, DC 20005 Research & Policy Development Department of Planning and Energy Northeast Nuclear Energy Company Policy ATTN: Superintendent 20 Grand Street Millstone Plant Hartford, Connecticut 06106 P. O. Box 128 Waterford, Connecticut 06385 Director, Criteria and Standards Division Office of Radiation Programs (ANR-460)
Mr. James R. Hirmelwright U.S. Environmental Protection Agency Northeast Utilities Service Company Washington, DC 20460 Post Office Box 270 Hartford, Connecticut 06101 U.S. Environmental Protection Agency Region I Office Resident Inspector ATTN: EIS COORDINATOR c/o USNRC JFK Federal Building P. O. Box Drawer KK Boston, Massachusetts 02203 Niantic, Connecticut 06357 Waterford Public Library Rope Ferry Road, Route 156 Waterford, Connecticut 06385 First Selectman of the Town of Waterford Hall of Records 200 Bostcc Post Road Waterfo' % Connecticut 06385
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.,g June 3, 1981 Docket No. 50-245 LS05-81 06-010 Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations flortheast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
SUBJECT:
SEP TOPIC VIII-2, EMERGENCY GENERATORS (MILLSTONE NUCLEAR POWER STATION, UNIT 1)
Enclosed is a revised copy of our contractor's evaluation of Systematic Evaluation Program Topic VIII-2, Cmergency Generators. This report has been revired to reflect the additional comments provided by your letter of April 13, 1981.
Please note that the conclusions of the enclosed evaluation (0111Ji are different from those in our February 13, 1981 letter (enclosingReport lillF).
The number and kinds of gas turbine trips that are not bypasrld or are not redundant concern both the staff and our support contractor. We are unable to state that the probability of successful gas turbine operation under emergency conditions is equivalent to that of the diesel because of these concerns. Conversely, we cannot adequately estimate the consequences of a failure of these trips to function when required, as compared with our experiences with diesel engines. Accordingly, we suggest that we discuss this issue in a telephone conference to be arranged at our mutual convenience.
This evaluation will be a basic input to the staff's SER on this topic for your facility. This topic assessment may be rezised in the future if your facility design is changed or if NRC criteria relating to this topic are modified before the integrated assessment is completed.
Si
- erely, W.
. Crutchrie d Ch ef Operating Reactors Branch #5 Division of Licensing b
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Mr. W.G. Counsil
Enclosure:
SEP Topic VI'f-?
cc w/ enclosure:
William H. Cuddy, Esquire John F. Opeka Day, Berry & Howard Systems Superintendent Conselors at Law Northeast Utilities Service Company One Ce titution Plaza Post Office Box 270 Hartfora, Connecticut 06103 Hartford, Connecticut 06101 Natural Resources Defense Council Connecticut Energy Agency 917 15th Street, NW ATTN: Assistant Director Washington, DC 20005 Research & Policy Development Department of Planning and Energy Northeast Nuclear Energy Company Policy ATTN: Superintendent 20 Grand Street Millstone Plant Hartford, Connecticut 06106 P. O. Box 128 Waterford, Connecticut 06385 Director, Criteria and Standards Division Office of Radiation Prograns (ANR-460)
Mr. James R. Himmelwright U.S. Environmer. cal Protection Agency Northeast ciilities Service Company Washington, DC 20460 Post Office Box 270 Hartford, Connecticut 06101 U.S. Environmental Protection Agency Region I Office Resident Inspector ATTN: EIS COORDINATOR c/o USNRC JFK Federal Building P. O. Box Drawer KK Boston, Massachusetts 02203 Niantic, Connecticut 06357 Waterford Dublic Library Rope Ferry Road, Route 156
.Waterford, Connecticut 06385 First Selectman of the Town of Waterford Hall of Records 200 Boston Post Road Waterford, Connecticut 063SS l
0111J SEP TECHNICAL EVALUATION TCPIC VIII-2 EMERGEfCY GENERATORS FINAL DRAFT '
MILLSTONE 1 00cket No. 50-245 Ny 1981 F. G. Famer e
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CONTE.4TS 1.0 I N TR O D UC T IO N............................ I 2.0 CRITERIA.............................. 2 2.1 Emergency Genera tor Loading.................. 2 2
2.2 Bypass of Protective Trips 2.3 Energency Generator Testing...........
3 3.0 DISCUSSION AND EVALUATION 5
...............s.
3.1 Emergency Generator Loading.................. 5 3.2 Bypass of Protective Trips 6
3.3 Emergency Generator Testing.................. 8 4.0
SUMMARY
.............................10 5.0 RE F ERE NC ES............................
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SEP TECHNICAL EVALUATION TOPIC VIII-2 EMERGENCY GENERATORS MILLSTONE I
1.0 INTRODUCTION
The objective of the review is to determine if the onsite AC generator i
for the Millstone 1 Nuclear Station has sufficient capacity and capability to supply the required automatic safety loads during anticipated occurrences and/oc in the event of postulated accidents after loss of offsite pmver.
The requirement that the onsite electric power supplies have capacity and capability to complete the required safety functions is obtained in' General Design Criterion 17.
Criterion III, " Design Control," of Appendix B, " Quality Assurance p
Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR j
Part 50 includes a requirement that measures be provided f,or verifying or checking the adequacy of design by design reviews, by the use of 7.1 ternate i
or simplified calculational methods, or by the performance of a suitable testing program.
Regulatory Guides, IEEE Standards, and Branch Tecnnical Positions which provide a basis acceptable to the NRC staff for compliance with GDC17 h
and Criterion III include: Regulatory Guide 1.9, " Selection of Of esel Generator Set Capacity for Standby Power Supplies;" Regulatory Guide 1.108,
" Periodic Testing of Diesel Generators Used as Onsite Power Systems at
' Nuclear Power Plants"; IEEE Standard 387-1977, " Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Stations;" BTP ICSB2, " Diesel-Generator Reliability Qualification Testing";
and BTP ICSB17, " Diesel Generator Protective Trip Circuit Bypasses."
Specifically, this review evaluates the loading of the emergency i
generator bypasses of protective trips _during accident conditions and 1
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periodic testing. The SEP reviews for Topics III-1 and III-12 will evalu-ate the emergency generator qualification.
2.0 CRITERIA 2.1 Emeraency Generator Loading. Regulatory Guide 1.9, " Selection of Diesel-Generator Set Capacity for Standby Pcwer Supplies," provides the basis acceptable to the NRC staff for loading emergency generator units.
The following criterion is used in this report to determine compliance with current i fcensing requirements:
1.
The automatically-connected loadt on each diesel-generator unit should not exceed the 2000-hour rating.
(Loads must be conservatively estimated utilizing the nameplate ratir' 4 of motors and transformers with motor efficiencies or 90% or less. When 3vailable, actual measured loads can be used.).
2.2 Bypass of Protective Trips. Branch Technical Position (BTP)
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ICSB 17, " Diesel-Generator Protective Trip Circuit Bypasses," specifies tha t:
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1.
.The design of standby diesel generator systems should retain only the engine overspeed and the generator differential trips.and bypass all other trips under an accident condition 2.
If other trips, in addition to the engine overspeed and generator differential, are retained for accident con-ditions, an acceptable design should provide two or more independent measurements of each of these trip parameters. Trip logic should be such that diesel-generator trip would require specific coincident logic.
2.3 Emergency Generator Testing. Regulatory Guide 1.108, " Periodic Testing Of Diesel Generator Units Used as Onsite Electrical Power Systems at ?bclear Power Plants", states that:
1 Testing of diesel-generator units, at least once every 18 months, should:
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Demonstrate proper startup operation by simulating loss of all ac voltage -snd demonstrate that the diesel generator unit can start automatically and attain the required voltage and frequency within acceptable limits and time.
b.
Demonstrata proper operation for design-accident-loading sequence to design-load requirements and verify that voltage and frequency are maint;trd within required limits.
c.
Demonstrate full-load-carrying capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> should be at a load equivalent to the continuous rating of the diesel generator and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a load equivalent to the 2-hour rating of the diesel generator. Verify that voltage and frequency requirements are maintained. The test should also verify that the cooling system func-tions within design limits.
d.
Demonstrate proper operation during diesel-generator load shedding, including a test of the loss of the largest single load and of complete loss of load, and verify that the voltage require-ments are met and that the overspeed limits are not exceaded.
e.
Demonstrate functional capability at full-load temperature conditions by rerunning the test phase outlined in a and b, immediately following c,
.3 Dove.
f.
Demonstrate the ability to synchronize the diesel generator unit with offsite power while the unit is connected to the emergency load, transfer this load to the offsite power, isolate the diesel-generator unit, and restore it to standby status.
g.
Demonstrate that the ergine will perfom properly if switching from one fuel-cil supply system to another is a part of the nomal operating proced-ure to satisfy the 7-day storage requirement.
h.
Demonstrate that the capability of the diesel-generator unit to supply emergency power within the required time is not impaired during periodic testing under 3, below.
2.
Testing of redundant diesel-generator units during normal plant operation should be perfomed indepen-dently (nonconcurrently) to minimize common failure modes resulting from undetected interdependences among 3
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diesel-generator units. Ebwever, during reliability demonstration of diesel-generator units during plant preoperational testing and testing subsequent to any plant modification where diesel-generator unit inter-dependence may have been affected or every.10 years (during a plant shutdown), whichever is the shorter, a test should be conducted in which redundant units are started simultaneously to help identify certain coccon failure modes undetected in single diesel-generator uni t tests.
3.
Periodic testing of diesel-generator units during nor-mal plant operation should:
a.
Demonstrate proper startup and veri fy that the required voltage and frequency are automatically attained within acceptable limits and time. This test should also verify that the components of the diesel-generator unit required for automatic startup are operable.
b.
Demonstrate full-load-carrying capability (contin-uous rating) for an interval of not less than one hour. The test should also verify that the cooling system functions within design limits.
This test could be accomplished by synchronizing the generator with the offsite power and assuming a load at the maximum practical rate.
4.
The interval for periodic testing under 3, above (on a per. diesel-generator unit bnsis) shou?d be no more than 31 days and should depend on demonstrated performance.
If more than one failure has occurred in the last 100 tests (on a per nuclear unit basis), the test interval should be shortened in accordance with the following schedule:
a.
If the number of failures in the last 100 valid tests is one or zero, the test interval should be not more than 31 days.
b.
If the number of failures in the last 100 valf d tests is two, the test interval should be not more than 14 days.
c.
If the number of failures in the last 100 valid tests is three, the test interval should be not more than 7 days.
.d.
If the number of failures in the last 100 -valid tests is four or more, the test interval should be not more than 3 days.
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3.0 OISCUSSION AND EVALUATION Millstone 1 uses one diesel generator and one gas turbine generator for emergency on-site power.
In the event that the diesel generator fails to start, the gas turbine generator can manually assume the loads nomally powered by the DG, as well as its own loads.
3.1 Emergency Ger.erator. Loading Discussion. Millstone Final Safety Analysis Report, Anend-l ment 15, provided a list of diesel and gas turbine generator loads; this list was subsequently modified by NNECo,13, 2
The diesel generator has a continuous rat'ng of 3330 kVA at 0.8 PF; no 30,winute rating is specified. The worst-case generator load is 3045 HP using nameplate data. With a 90". motor efficiency, as specified in j
R.G.1.9, the worst +:ase load is 3155 kVA at 0.8 PF. The maximum step load change is 829 kVA or 25t of the continuous' generator rating.
The gas turbine generator is rated at 12 MW, and derated to 11.1 MW at an andient temperature of 100 F; no 30-minute rating is specified.
The worst-case generator load is 13,240 HP (nameplate). Again using 90*.
motor efficiency, the worst-case load i* 10.975 MW. The maximum step load change for the gas turbine generator is 5.8 MW or 52". of the continuous generator rating.
Millstone 1 Technical Specifications do not require that the diesel and gas turbine generators be sequenced to full emergency loading during each refueling outage.3 Eval uation. The total worst-case automatically connected diesel generator load is 3155 kVA or 95t of the generator continuous rating. This is within the criteria of R.G.1.9.
The total woist-case automatically connected gas turbine generator load is 10.975 MW or 99". of the generator 0
continuous rating at 100 F.
This meets the criteria of R.G.1.9.
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3.2 Bypass of protective Trips Discussion. On December 9,1980 and April 13, 1981, NNECo pro-vided lists of protective trips which render the emergency generators incap-able of responding to an automatic emergency start signal.I3'l4
' Diesel-generator trips which are not bypassed under accident conditions are generator differential, voltage restrained overcurrent, and low engine lube oil pressure. The low oil-pressure trip requires signals from two of three sensors before a trip occurs.
There are four shutdown signals associated with critical events occur-ring during startup to accelerate the gas turbine to full speed and complete loading. Tnese annunciated trips are time-delay drops which will shut down the machine if the monitored event has not occurred within the allotted time. These signals and the times involved are as follows:
1.
If light-off speed (930 nm) is not reached in 20 sec-onds (light-soeed off speed is expected in 13 to 16 seconds).
2.
If light-off temperature (4000F) is not reached 15 seconds after light-off (light-off temperature is expected 5 to 8 seconds after reaching 930 nm).
3.
If starting air-f gnition cut-off speed (3400 rpm) has not been reached 60 seconds after start (expected 15 seconds after light-off).
4.
If generator excitation speed (540 rpm electric-generator-speed) is not reached in 60 seconds (expected l
35 seconds after, start).
The expected times denoted above for the anticipated event are based on the startup analysis under emergency conditions.
Tne actual operating time-delay settings allow for variations in perfomance of the applicable components and are set high enough to ensure a complete starting attempt and to preclude unnecessary shutdown of the system.
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There are threo out-of-limits type signals which could cause gas tur-bine shutdown. These are not associated directly with component malfunc-tions or miscalibration. Tnese events would occur after machine loading at full speed as the result of an electrical load and/or ambient air temper-ature in excess of the system rating. However, as discussed below, the probability of such conditions occurring during the emergency mode of oper-ation is greatly minimized.
1.
High Exhaust Gas Temperature--The trip for emergeny operation is set at 1300*F whereas, for peaking power 0
operation, it is set at 1200 F.
It is anticipated that for peaking operation on a maximum ambient day d
(105 F) the exhaust gas temperature will not be in 0
excess of 1050 F.
For machine operation in the emer-gency made on a maximum ambient day, the anticipated exhaust gas temperature is in the range of 11500F to ll750F. Tnis gives a margin of 1250F to 1500F between this temperature range and the trip setting of 13000 F.
2.
High Lube Oil Temeerature--The lube oil systems for the gas turoine generator unit are in two parts, each independent of the other.
Hign Gas anerator Speed--This trip is set at 7685 rpm, c
3.
wnica represents a K overspeed condition for the emer-gency mode of operation.
In the emergency mode of oper-ation, because the breakers are closed and loading of the electrical generator starts at approximately 987, of synchronous speed, chances of a spurious gas generator overspeed excursion is very low. Any indications of overspeed would be indicative of an overload condition existing in the gas generator. itwever, proper setting of the scheduled fuel flow to the gas generator pre-cludes occurrences of such a condition.
4.
Hign Turbine Oversoeed--6050 rpm.
5.
High Vibration Jet 6.
Low Lube Oil pressure--141bs There are seven, automatic trips associatec with the gas turbine generator output breaker. These trips are not disabled under accident conditions. The trips are as follows:
a.
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Opening of the exciter breaker c.
Generator differential d.
Megative sequence e.
Reverse power f.
Generator underspeed 9
Voltage restrained overcurrent.
These trips do not use redundant sensors or coincident logic.
Evaluation. The diesel-generator protective trips are in compli-ance with current licensing criteria. There are no specific criteria for protective trips on gas turbine generators, but the gas turbine trips do not appear to meet the intent of the diesel-generator criteria.
3.3 Emergency Generator lesting Discussion. Millstone 1 Technical Specifications, para-graph 4.9.A, require emergency generator testing as follows:
1.
Diesel Generator
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a.
Tne diesel generator shall be started and loaded once a month to demonstrate operational readines s.
The test shall continue until the diesel engine and the generator are at equil-ibrium temperature at full load output.
l During this test, the diesel starting air compressor will be checked for operation and its ability to recharge air receivers, b.
During each refueling outage, the conditions under which the diesel generator is required l
I will be simulated and test conducted to demon-strate that it will start and be ready to accept load within 13 seconds.
l c.
During the monthly generator test, the diesel fuel oil transfer pumps shall be operated.
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, Gas Turbine Generator a.
The gas turbine generator shall be fast started and the output breakers closed within 48 seconds once a month to demonstrate oper-ational readiness. The test shall continue until the gas turbine and generator are at equilibrium temperature at full load output.
Use of this unit to supply power to the system electrical network shall constitute an accept-able demonstration of operability.
b.
During each refueling outage, the conditions under which the gas turbine generator is required will be simulated and a test conduc-ced to verify that it will start and be able to accept energency loads wi thin 48 seconds.
Evaluation. Emergency generator testing defined in-the plant-Technical Specifications address the criteria listed in paragraph 2.3 to the following extent (evaluation is for both diesel and gas turbine generators except as noted):
1.
a.
Voltage and frequency limits are not speci fied.
5.
Load sequencing is not required.
c.
No limits are specified for voltage.
frequency or duration.
d.
Not addressed, e.
Not ad 'ressed.
f.
Diesei--not addressed; Gas Turbine--
acceptable, is normally used for plant load peaking.
g.
Diesel--covered on monthly test; Gas Turbine--
not applicable.
h.
Not addressed.
2.
Not addressed.
3.
a.
No limits specified for voltage or frequency; no time limit specified for diesel; automatic-start components are not addressed.
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Mot addressed.
The Technical Spacifications do not meet current licensing criteria for diesel-generator tastir3 Diesel-generator failure data will be extrac-ted by NRC from Licensee ~; vent Reports and will be considered in the final evaluation of testing at.equacy.
4.0 _
SUMMARY
The automatic diesel generator loading is in compliance with current licensing criteria. The automatic gas turbine generator loadir.g meets current licensing criteria.
Diesel generator protective trips are in agreement with current NRC staff guidelines as listed in BTP ICSB 17. Gas turbine generator protective trips do not appear to comply with the intent of current ifcensing criteria.
Energency generator testing, as specified by plant i'echnical Specifi-cations, does not meet licensing criteria.
The review of qual;fication of the c gency generators will be com-pleted with SEP Topics III-1, Seismic Qu-
. f cation, and III-12, Environ-mental Qualification.
5.0 REFERENCES
1.
Final Safety Analysis Reoort, Amendment 15, dated June 15, 1969, pp. V III-3.12, VIII-3.13.
l 2.
FSAR revision (apparently) received by NRC approximately August 20, 197 9, Table s 8.3.9-3 and 8.3.9-4.
3.
Millstone Nuclear Power Station Unit No.1 Technical Scecifications, Decemoer 197 7, pp. 3/4 9-1 and 3/4 9-2.
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4.
Letter NNRCo (Svitzer) to NRC (Lear) dated May 31,1977, " Evaluation' of Diesel Generator Alann and Control Circuitry."
5.
General Design Criterion 17, " Electric Power System," of Appendix A,
" General Design Criteria of Nuclear Power Plants," to 10 CFR Part 50,
" Domestic Licensing of Production and Utilization Facilities."
10
6.
General Design Cri:erion III, " Design Control," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Pl ants," to 10 CRF Part 50, " Domestic Licensing of Production and
' Utilization Facilities."
7.
" Standard Criteria for Class IE Power Systems and Nuclear Power Gener-ating Stations", IEEE Std. 308, 1974, paragraph 5.2.4.
8.
" Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Stations," IEEE Std. 387, 1977, 9.
" Selection of Diesel Generator Set Capacity for Standby Power Sup-plies", Regulatory Guide 1.9.
!bclear Plants,"g of Diesel Genera ~ tors Used as Onsite Power Systems at
" Periodic Testin 10.
11.
" Diesel-Generator Reliability Qualification Testing," BTP ICS82 (PSB).
- 12. '" Diesel-Generator Protective Trip Circuit Bypasses," BTP ICSB17 (PSB).
- 13. Letter, Northeast Utilities (Counsil) to NRR (Crutchfield), dated 12-9-80.
- 14. Letter, Northeast Utilities (Counsil) to NRR (Crutchfield), dated 4-1 3 -81.
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