ML20038C657
| ML20038C657 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/04/1981 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | Parker W DUKE POWER CO. |
| References | |
| NUDOCS 8112110373 | |
| Download: ML20038C657 (61) | |
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L/PDR LB#4 r/f NRC/PDR NOV 4 1981 DEisenhut NSIC/ TIC EAdensam TERA KJabbour ACRS (16)
Du a"
Docket nos.:
50-413/414 ur RTedesco gM s RVollmer i.r.
,.illia.a o. Parker, J r.
rtf eld Vice President - Stedi.i Procuction 97 '
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4 buke Po..er Lo.:.pany 0IE (3) 6-UOV '2 P.o. dux 3alub 1
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charlotte, horth Carolina zaz42 uear hr. Parr,er:
r,e uest for acaitional Inforuation dacacct:
s In the pertoruance of the Cataaba station licensing review, the staf f has identified tne need for additional inforuation in the followir.3 areas:
1.
ueosciences - deisuolojy (Lnclosure 1) 2.
Geosciences - Geology (t.nclosure 2) 3.
Power sjstens (Enclosure 3)
Our review in other areas will be completed in the near f utare; and we will send you separate requests for donitional intor.aation related to those areas.
We request that you provide the inforuation herein requested no later tnan Decenber 11, 1981.
If you require anj clarification of this re.;uest, please contac t tne project icanaiser, hantan Jaobour, at (M;l) 492-7821.
Lincerely, S
i.linor b. noensa:a, eranch Lhief Licensin, orancn #4 Division of Licensing Lnclosures: As stated r
cc: See next page 8112110373 811104 PDR ADOCK 05000413 A
PDR N,
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OFFICIAL RECOFsD COPY
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C AT Au.4 A Mr. Williaa 0. Parker Vice President - Steam Production Duke Power Conpany P.O. Box 33199 i
Charlotte, North Carolina 28242 cc: William L. Porter, Esq.
i;crth Carolina Electric Membership Duke Power Company Ccrp.
P.O. Box 33189 3333 North Boulevard Charlotte, North Carolina 28242 P.O. Box 27306 Raleigh, North Carolina 27611 J. Michael McGarry, III, Esq.
Debevoise & Liberman Saluda River Electric Cooperative, 1200 Seventeenth Street, N.W.
Inc.
-e Washington, D. C.
20036 207 Sherwood Drive
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Laurens, South Carolina 29360 North Carolina MPA-1 P.O. Box 95162 Ja es W. Burch, Director Raleigh, North Carolina 2762S Nuclear Advisory Counsel 2600 Bull Street Mr. R. S. Howard Columbia, South Carolina 29201 Power Systems Division Westinghouse Electric Corp.
Mr. Peter K. YanDoorn P.O. Box 355 Route 2, Box 179N Pittsburgh, Pennsylvania 15230 York, South Carolina 29745 Mr. J. C. Plunkett, J r.
NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 Mr. Jesse L. Riley, President Carolina Environmental Study Group 854 denley Place Charlotte, North Carolina 28208 Richard P. Wilson, Esq.
Assistant Attorney General S.C. Attorney General's Office P.O. Box 11549 Columbia, South Carolina 29211 Walton J. McLeod, J r., Esq.
General Counsel South Carolina State Board of Health J. Marion Sims Building 2000 Bull Street Columbia, South Carolina 29201 e
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l ENCLOSURE 1 1
REQUEST FOR' ADDITIONAL.SEISMOLOGICALnINF0kMATION 230.2 Section 2.5.2.3.3 How was the boundary of the Charleston Epicentral Area (163 miles from the site) determined.
203.3 Section 2.5.2.6 Identify the historic earthquake which is assumed to be the largest earthquake to occur at the site. What is the intensity and/or i
magnitude and associated peak acceleration of this earthquake.
(The Staff's position-has been to use the " Trend of the Mean" relationship of l
Trifunac and Brady (on the correlation of seismic intensity scales and the peaks of recorded strong ground motion, BSSA, vol. 65, 1975) coupled q
with the Reg. Guide 1.60 spectrum curve to define the ground motion).
4 230.4 P16t spectra developed by method discussed in question 230.3 and compare
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to Catawba design spectra, reference section 2.5, figure 2.5.2-7.
Discuss significant differences if any.
5 230.5 Update Table 2.5.2-1 to include all earthquakes having MM intensity greater j
than IV or magnitude greater than 3 which have been reported to date in an area within 200 miles radius from the site.
Include the scismic data provided by the Southeastern U.S. Seismic Network.
230.6 Update Table 2.5.2-2 to include all recorded and/or felt earthquakes to i
date within a 50 mile radius of the site.
Include applicable data l
provided by the Southeastern U.S. Seismic Network.
l 230.7 Discuss the influence of the Hendersonville earthquakes of April 9 and May 5,1981 on the assessment of seismic hazard of the site.
(Reference Tennessee Earthquake Information Center, Special Report ?4).
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ENCLOSURE 2 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 REQUEST FOR ADDITIONAL GEOLOGICAL INFORMATION 231.01 Update the FSAR to consider all pertinent geologic and seismologic (2.5.1.1) information that has been developed in the region since publication of the FSAR. The most recent published earth science reference in the FSAR bibliography is 1977. Consi-derable geological and seismological research has been done in southeastern U.S. since that time. Evaluate this information and determine whether or not it is significant to the geological and seismological analysis of the site. Recent research work in the site regicn includes but is not limited to the following:
a.
geological and seismological investigations by the USGS and others concerning the origin of seismicity in the vicinity of Charleston, S.C., including the 1886 Intensity X Charleston Earthquake (Rankin, 1977 and more recent papers presented at the 1980 GSA Eastern Section meeting in Atlanta, Georgia).
b.
the Southern Appalachian C0 CORP line (Cook et al,1979).
231.02 Based on these studies several hypotheses about the causative mechanism
( 2. 5.1.1 ).
of the 1886 Charleston Earthquake have been developed such'as, stress amplification at the boundary of mafic plutons (McKeown,1978 and Kane, 1977); reactivation of a master decollement (Seeber and Armbruster,1981, Behrendt et al,1981); high angle reverse faults (Wentworth and tergner-Keefer,1981) (Behrendt et al,1931); reactivated P41eozoic aulocogen (Rankin,1976 and 1978); etc. Several of these hypotheses would require
a s.
consideration of a recurrence of.the Charleston Earthquake much ' closer to the site than was assumed in the FSAR.
Discuss the significance of these theories to the Catawba site.
231.03 Update the FSAR to consider all pertinent geologic and seismic work that (2.5.1.2.1) has been done.in the subregicn around the site and in the site area.
Evaluate the relevance of this data to the geologic and seismic safety of the site.
Some of this work with respect to the Kings Mountain Belt was presented at the 42nd annual meeting of the Carolina Geological Society during October 23-25, 1981 at Gaffney, S..C..
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REFERENCES
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1.
Behrendt, J. C., Hamilton, R. M., Ackerman, H. D., and Henry, V. J.,
1981, Cenezoic faulting in the vicinity of Charleston, South Carolina, earthquake zone: Geology, v. 9, no. 3.
2.
Cook, F.
A., and others,1979, thin-skinned tectonics in the crystalline southern Appalachians; C0 CORP seismic-reflection profiling' in the Blue Ridge and Piedmont: Geology, v. 7, p. -563-567.
3.
Kane, M. F.,1977, Correlation of major eastern earthquake centers with mafic / ultra-mafic basement masses, in Rankin, D. W. (editor). Studies related to the Charleston, South Carolina, earthquake of 1886. a preliminary report: USGS Prof. Paper 1028, p.199-204.
4 McKeown, F. A.,1978, Hypothesis : many eart'.qukes in the central and southeastern United States are casualty rela ted to mafic intrusive bodies: USGS Journal of Research, v.
6', p. 41-50..
5.
Rankin, D. W.,1976, Appalachian salients and recesses: Late Precambrian continental breakup and the opening of. the Iapetus,0cean. JGR, Vol. 81, no. 32, p. 5606-5619.
6.
Rankin, D. W.,1978, The Charleston South Carolina Earthquake of 1886' and the Blake Spur fracture zoni. GSA, vol.10, no. a, 27th, annual meeting Southeastern.Section, Abs of Programs.
7.
Rankin, D. W. (editor),1977, Studies related to the Charleston, South Carolina Earthquake of 1886 Introduction USGS Prof. Paper 1028-A.
8.
Seeber, L. and Armbruster, J. G.,1931, The 1886 Charleston, South Carolina.
Earthquake and the Appalachian Detachment; UGR, vol. 86, no. 89, p. 7874-7894.
9.
Wentworth, C. M., and Mergner-Keefer, M.,1981, regenerate faul ts of small Cenozoic offset as probable earthquake scurces in the southeastern United States; USGS,0 pen File Report 81-356.
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ENCLOSURE 3 POWER SYSTEMS. BRANCH
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430.3 In section 8.2.1.6 of the FSAR you state that the reliability criteria
. ( 8.2.1. 6).
of the Southeastern Electric Reliability Council (SERC) assures that each of the SERC member systems is designed to avoid system cascading upon the occurrence of sudden loss of entire generating capability in' any one plant and sudden loss of large load or major load center. As required by-Standard Review Plan, Section 8.2, paragraph III.2.f provide the results j
of the grid stability analysis (swing curves) for the cases of loss of the largest generating station on the grid and sudden loss of the largest load or major load center on the grid.
430.4 In section 8.2.1.5 of the FSAR you state that the generator circuit breakers (8.2.1.5) utilized at Catawba are identical to those at the McGuire Nuclear Station which were reviewed and found acceptable by the i4RC staff during the licensing of McGuire.
Indicate whether any of the system-dependent variables such as maximum available fault current and maximum rate of rise of recovery voltage have increased beyond the specification ratings for the circuit breakers shown on page E-22 of the McGuire' Safety l
Evaluation Report (HUREG-0422) since the date of the report. Will the system-dependent values increase beyond the circuit breaker ratings with the addition of the future lines and the future generating capacity l
indicated in figures 8.2.1-2 and 8.2.1-5 of the Catawba FSAR7 i
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t 430.5 Are the incoming circuit breakers on the double fed 600 VAC motor control (8.3.1.1) centers (described in sections S.3.1.1.1.5 and 8.3.1.1.1.6 of the FSAR) interlocked to prevent paralleling of the two incoming sources.
430.6 Provide a listing of all motor operated valves within your design that (8.3) require pcwer lockout in order to meet the single failure criterion and provide the details of your design that accomplish this requirement.
[ Reference NRC Standard Review Plan NUREG-0800, formerly NUREG-75/087, Branch Technical Position ICSB-4 (PSB) and ICSB 18 (PSB)]
420.7 In section 8.3.1.1.1.3 of the FSAR you address an automatic transfer (8.3.1.1) scheme at the 6.9 kv level.
Indicate whether the transfer is an automatic fast transfer or slow transfer and provide the transfer times involved.
For slow source transfer also indicate the sequence of events involved in the transfer.
430.8 Provide a guide to symbols and nomenclature for the electrical (1.7, l
7.0 instrumentation and control drawings that are listed in Table 1.7.1-1.
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430.9 The undervoltage tripping scheme described in section 8.3.1.1.2.1 of
( 8. 3.1.1 )
the FSAR is presently desig'ned is not acceptable:
l 1.
The setpoint of 83.2% is below the normally specified minimum continuous operating equipment voltage of 90% according to ANSI C84.1.
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2.
Starting the diesel-instantaneously when the voltage drops below 83.2% creates the possibility of unnecessarily challenging the diesel start systems as a result of nortnal motor starting or distribution system short duration voltage transients.
3.
The time delay of 8.5 seconds for any voltage between 0% and 83.2%
will likely allow equipment to be damaged since it is possible they could be operated at voltages much lower than their rated values for 8.5 seconds before being separated from offsite power.
A more acceptable undervoltage protection scheme is provided by two levels of undervoltage protection as described in the following revised staff position. The first level will separate the loads rapidly (1 sec) for very low voltage conditions or total loss of voltage, and the second level will allow longer time delays at voltages just below equipment ratings. The revised criteria, for design of the 2nd le' vel of voltage protection, allows a period of time for the operator to take action to-improve the low voltage condition. This is a preferred method over the previous NRC criteria but in no way detracts from the acceptability of designs in accordance with the previous criteria.
In lieu of justifying the deficiencies in your existing design itemized above you may opt for the revised design criteria contained in part i following; however the requirements for biccking the load shedding feature, for optimizing voltage levels at safety-related buses, and for a verification test which are contained in parts 2, 3 and 4 following should be adhered to:
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4-1.
In addition to the undervoltage scheme provided to detect loss of offsite power at the Class lE buses, a second level of undervoltage protection with time delay should also be provided to protect the Class 1E equipment; this second level of undervoltage protection shall satisfy the following criteria:
a) The selection of undervoltage and time delay setpoints shall be determined from an analysis of the. voltage requirements of the Class 1E loads at all onsite sysf-m distribution levels; b) Two separate time delays shall be selected for the second level of undervoltage protection based on the following conditions:
- 1) The first time delay should be of a duration that establishes the existence of a sustained degraded voltage condition (i.e.,
something longer than a motor starting transient). Following this delay, an alarm in the control room should alert the operator to the degraded condition. The subsequent occurrence of a safety injection actuation signal (SIAS) should immediately separate the Class 1E distribution system from the offsite power i
systen.
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- 2) The second time delay should be of a limited duration such that l
the permanently connected Class 1E loads will not be damaged.
i Following this delay, if the operator has failed to restore adequate voltages, the Class 1E distribution system should be i
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e 5-automatically separated from the offsite power system. Bases and justification must be provided in support of the actual delay chosen.
c) The voltage sensors shall be designed to satisfy the following
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applicable requirements derived from IEEE Std. 279-1971,
" Criteria for Protection Systems for Nuclear Power Generating Stations":
- 1) Class 1E equipment shall be utilized and shall be physically located at and electrically connected to the Class 1E switchgear.
- 2) An independent scheme shall be provided for each division of the Class 1E power system.
- 3) The undervoltage protection shall include coincidence logic on a per bus basis to preclude spurious trips of the offsite power source;
- 4) The voltage sensors shall automatically initiate the disconnection of offsite power sources whenever the voltace set point and time -
delay limits, (cited in item 1.b.2 above) have been exceeded;
- 5) Capability for test and calibration during power operation shall be provided.
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- 6) Annunciation must be provided in the control roorn for any bypasses incorporated in the design.
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. d) The Technical Specifications shall include limiting conditions for operations, surveillance requirements, trip setpoints with minimum and maximum limits, and allowable values for the second-level voltage protection sensors and associated time delay devices.
2.
The Class 1E bus load shedding scheme should automatically prevent shedding during sequencing of the emergency loads to the bus. The load shedding feature should, however, be rainstated upon completion of the load sequencing action. The technical specifications must include a test requirement to demonstrate the operability of the automatic bypass and reinstatement features at least once per 18 months during shutdown.
In the event an adequate basis can be provided for retaining the load shed feature during the above transient conditions, the setpoint value in the Technical Specifications for the first level of undervoltage l
protection (loss of offsite power) must specify a value tsving maximum and minimum limits. The basis for the setpoints and limits selected must be documented.
3.
The voltage levels at the safety-related buses should be optimized for the maximum and minimum load conditions that are expected throughout j
the anticipated range of voltage variations of the offsite power sources by appropriate adjustment of the voltage tap settin,ns of the intervening tra ns formers. The tap settings selected should be based on an analysis l
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. of the voltage at the terminals of the Class 1E loads. The analyses perfomed to determine minimum operating voltages should typically consider maximum unit steady state and transtant loads for events such as a unit trip, loss of coolant accident, startup or shutdown; with the cffsite power supply (grid) at einfaum anticipated voltage and only the offsite source being considered available. Maximum voltages should be analyzed with the offsite power supply (grid) at maximum expected voltage concurrent with minimum unit loads (e.g. cold shutdown, refueling). A separate set of the above analyses should be perfonned for each available connection to the offsite power supply and the results forwarded to the NRC.
4.
The analytical techniques and assumptions used in the voltage analyses cited in item 3 above must be veriff ed by actual measurement. ' The verification and test should be performed prior to initial full power reactor operation on all sources of offsite power by:
a) loading the station distribution buses, including all Class 1E l
buses down to the 120/208 y level, to at least 30%;
b) recording the existing grid and Class 1E bus voltages and bus loading down to the 120/208 volt level at steady state conditions and during the starting of both a large Class 1E and non-Class 1E motor (not concurrently);
Note: To minimize the number of instrumented locations.
(recorders) during the motor starting transient tests, the bus voltages and loading need only be recorded on that string of buses which previously showed the lowest analyzed voltages from item 3 above.
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c) using the analytical techniques and assumptions of the previous voltage aneljses cited in ites 3 above, and the measured existing grid voltage and bus loading conditions recorded during conduct of the test, calculate a new set of voltages for ali the Class 1E buses down to the 120/108 volt levelg i
d) compare the analytically derived voltage values against the test results.
With good correlation between the analytical results and the test results, the test verification requirement will be met. That is, the validity of the mathematical model used in performance of the analyses of item 3 will have been established; therefore, the validity of the results of the analyses is also established.
In general the test results should not be more than 3% lower than the analytical results; however, the difference between the two when subtra:ted from the voltage levels determined in the original analyses should never be less than the Class lE t luipment rated voltages.
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, _g-430.10 mcent expertence wf th Nuclear Pouer Fiant Class 1E electr'ical (8.3.1) sys can equipnent protective relay appitcatiort has established that relay trip setpoint drifts with conventionai type relays have resultad in premature trip: sf ' redundant safety related system pump noton when the safety systan was required tc be operative. While the basic need for proper protection for feeders / equipment against permanent faults is recognized, it is the staff's psition that total non-avellability of redundant safety systams due to sourious trips in protective relays is not acceptable.
Provide a descriptfon of your cfreutt protection erf terta for safety systems /equfpment to avoid incorrect inttfal setpotnt telection and the above ef ted protectlye relay trip setpoint drtft problems.
430.11 Provida a listiitof the following for the containment electri-(8.3.1) 2 cal penetrations by voltage Class: I t ratings, maxinu: predicted fault currents, identification of maximi:ing faults, protective equipment setacints, and expected clearing times.
l Pr vide a descHption of the Mical arrangement utilitized in your design to connect the field cables ins'ida contatment to the contafreent penetrations, e.g. c:nnectors, spitees, w tarsinal blocks. Provida supportive doc:statation' that these physical in*Macas are qualified to vithstand a m or staas line break earfmnment.
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Ig w been noted during past reviews that pressure switches or other 430.12 (8.3) devices were incorporated into the final actuation control circuitry for large horsepower safety-related motors which are used to drive pumps..These switches or deviges preclude automatic (safety signal) and manual operation of the actor / pug coccination unless permissive conditions such as lube oil pressure are satisfied.
Accordingly, identify any safety-related :notor/ pump corbinations wnich are used in the Catawba design that operate as noted above. Also, describe the redundancy and diversity which is pro-vided for the pressure switches or permissive devices that are used in 'his manner.
430.13 Identify all electrical equipment, both safety and non-safety, that (6.3,
- 8. 3) may beccee submerged as a result of a LOCA. For all such equipment that is not qualified for service in such an environment provide an analysis to determine the following:
1.
The safety significance of the failure of this electrical etuip-ment (e.g. spuricus actuation or loss of actuation function) as a result of flooding.
2.
The effects on Class 1E, electrical pcwer sources serving this equipment as a result of such submergence, and 3.
Any proposed design changes resulting from this analysis.
430.14 Mde the resuits of = Mas of ymr coertting, maintananca, and
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tasting ;tecadurts to detarzine the extant of usage of jumpars er other weary forms af byns. sing fanc fons for operating, tast-ing, er saintaining of safety estatad systam. Identify and justify any cases whers the us: of the theve matheds cancet be avoided.
Provide the cMtaria for any se of jumpers for tasting.
430.15 Oferal generator alar =s in the contro'! room:
A review of malfunction (8.3) reports of diesel generators at operating nuclear plants has uncovered that in some cases the infccmatfon available to the control room operator to indicata the operational status of the diesel generator may be i= precise and could lead to misinterpretation. This can be caused by the sharing of a single annunciator statifen to alarm conditions that render a diesel generator unable to respond to an automatic ernergency start signal and to also alam abnennal, but not disabling, conditions.
Another cause can be the use of wording of an annunciator window that does not specifically say that a diesel generator is inoperable (i.e.,
unable at the time to respond to an autratic emergency start signal) when in fact it is inoperable for that purpose.
Review and evaluate the alam and control circuitry for the diesel generators at your facility to detamine hew each condition that renders a diesel generator unable to respond to an autmatic emergency start signal is alarmed in the control room. These conditions include not only the trips that lock out the diesel generator start and require l
l manual reset, but also control switch or mode switch positions tha,t t
block automa tic start, loss of control voltage, insufficient starting air pressure or battery voltage, etc. This review should consider all l
aspects of possible diesel generator operational conditions, for exa.:ple test conditions and operation from local control stations. One area of particular concern is the unreset condition following a manual stop l
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at the local station which terminates a diesel generator test Y
and prior to reseting the diesel generator controls for enabling subs,equent automatic operation.
Provide the detatis of your evaluation, the results and conclusions.
and a tabulation of the following infomation:
(a) all conditions that render the diesel generator incapable of responding to an automatic emergency start signal for each operating mode as discussed above; (b) the wording on the annunciator window in the control roem that is alarmed for each of the condittens identified in (a);
(c) any other alam signals not included in (a) above that also cause the same annunciator to alam; (d) any condition that renders the diesel generator incapable of responding to an automatic emergency start signal which is not alamed in the control room; and (e) any proposed modifications resu'ttng from this evaluation.
--13 430.16 Incidents have occurred at nuclear power stations that indicate a (7.0 0 8.0) deficiency in the electrical contnsi circuitry design. These inci-dents included the inadvertent disabling of a component by racking out the circuit breakers for a different component.
1 As a result of these ocetrrences, we request that you perform a review of the electrical control circuits of all safety related equipment at the plant, so as to assure that disabling of one component does not, through incorporation in other interlocking or sequencing con-trols, render other components inoperable. All modes of test, opera-tien and failure should be considered. Verify and state the results of your review.
Also your procedures should be reviewed to ensure they provide that, whenever a part of a redundant system is rerreved from service, the pertion remaining in service is functionally tested innediately af ter the disabling of the affected portion. Verify that your procedures include the above cited provisions.
430.17 Ccncerning the emergency load sequencers which are associated with (8.3)
I the offsite and onsite* power sources we requirt that you either provide a separate sequencer for offsite and onsite power (per electrical division) or a detailed analysis to demonstrate that there are no credible sneak circuits or connon failures rnodes in the sequencer design that could render botn onsite and offsite power sources unavailable. In addition provide information con-cerning the reliability of your sequencer and reference design detailed drawings.
430.18 (8.3)
Explicitly identify all non-Class lE electrical loads which are or may be powered from the Class IE a-c and d-c systems. Also, for each load identified, provide the horsepower or kilowatt rating for that load and' identify the corresponding bus number from which the load is powered.
430.19 In section 8.3.1.1.3.4 of the FSAR you state that the setpoint of the (8.3.1.1) diesel generator overspeed trip is above the maximum engine speed on a full-load rejection.
Provide the full load engine speed and maximum safe engine speed.
In accordance with position C.4 of Regulatory Guide 1.9 verify that, during recovery from transients caused by step load increases or resulting from the disconnection of the largest single load, the speed of the diesel generator unit does not exceed the nominal speed plus 75 percent of the difference between nominal speed and the overspeed trip setpoint or 115 percent of nominal, whichever is lower.
430.20 Section 8.3.1.1.3.5 of the FSAR states that the load shedd.ing feature (8.3.1.1) for the Class lE buses will remain blocked following load sequencing until the load sequencer is manually reset or diesel engine speed decreases below approximately 44%.
Branch Technical Position PSB-1 in the Standard Review Plan (NUREG 0-800) requires automatic reinstatement of the load shedding feature upon completion of load sequencing. Your present design is not acceptable since it will not autcmatically result in load shedding upon trip of the diesel generator circuit breaker when there is no loss of diesel generator frequency.
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430.21 Section 8.3.1.1.3.1 of the FSAR describes what happens when an (8.3.1.1) undervoltage safety injection actuation signal is received during test of the diesel generator, but it does not describe what occurs for a loss of offsite power (LOOP).
Nonnally, during periodic testing of diesel generator, the diesel generator is paralleled with the offsite power system. During such a test, should a LOOP occur, a LOOP signal would probably not be generated because the D/G would attempt to provide power to the bus and to the offsite system through the closed offsite power feedbreaker.
In this case, the D/G breaker will trip on overcu'rrent or underfrequency and in some designs the D/G breaker also locks out for this condition.
Toassurethecontinuedavailability of the D/G unit it is essential that the diesel generator breaker should not be locked out for such overload conditions. At the same time, the governor is shifted auto-
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matically from droop to isuchronous mode and the voltage regulator to automatic mode. With the above actions complete. the d,iesel generator unit will be ready to accept its required load for LOOP conditions.
Verify that your Catawba diesel generator control design complies with the above.
- 16 430.22 Section 8.3.1.1.3.9 of the FSAR addresses prototype qualification (8.3.1.1) testing of the Catawba diesel generator but it is not clear from the description that the testing was entirely in accordance with IEEE 387-1977 and Regulatory Guide 1.9.
If the diesel generator is a type not previously qualified as a standby power source for nuclear power generating stations,it must undergo a prototype qualification test.
Verify that the diesel generators for the Catawba plant have been prototype tested in accordance with'IEEE 387-1977 as modified by NRC Regulatory Guide 1.9 and that these test results are available for inspection.
430.23 (8.3.1.1)
Verify that the preoperational testing addressed in section 8.3.1.1.3.10 of the FSAR conforms with positions C.2.a and C.2.b of Regulatory Guide 1.108.
430.24 (8.3.1.1)
Section 8.3.1.1.4 of the FSAR states that the minimum accelerating voltage for Class 1E motors is 80% of motor rated voltage'except for the diesel generator auxiliary motors not required during a less of coolant accident, and Class lE motor operators for valves which are designed to start at 90% and 85% of motor rated voltage, respectively.
What is the function of the diesel generator auxiliary motors not required during a loss of coolant accident? Also justify the use of all these motors whcn oper, rom the diesel generator xhich has an allowed 75% voltage dip during load sequencing. Also justify use of the 90% and 85% motors when operating from offsite power with an essential bus undervoltage setpoint of 83.2%.
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430.25 In section 8.3.1.1.2.1 of the FSAR you state that if a blackout (8.3.1.1) condition (loss of offsite power) occurs, the diesel generator load sequencer will sequence only those loads required to mitigate the consequences of the blackout. Verify that, if subsequent to this a LOCA signal is received, the non-Class lE blackout loads will auto-matically be tripped and the LOCA loads sequenced on. Also justify how the required automatic sequence can take place if the load sequencer manual unit has not been reset following the blackout load sequencing.
430.26 The 125 VDC and 240/120 VAC Ncn Class lE Auxiliary Control Power System (8.3.1.1)
{
shown in figure 8.1.2-1 ties the two 4160 V Class 1E divisions together through the battery chargers and auctioneering diode assemblies or 125 VDC and 240/120 VAC bus ties, when the blackout switchgear are supplied from the diesel generators. Verify that a fault on the Non Class 1E Auxiliary Control Power System bus ties or a fault on the output of the auctioneering diode. assemblies will not affect either 4160 V Class 1E division.
430.27 Describe the cable spreading area and the separation of cables in this i
(8.3.1.4) area with regard to the requirements contained in section 5.1.3 of IEEE 384-1974 as modified by NRC Regulatory Guide 1.75.
Does the area contain high energy equipment such as switchgear, transformers and rotating i
equipment or piping (high and moderate energy) that could be a potential source of missiles or pipe whip? Are flammable materials stored in the area? Are power cables ructed through the area? Are redundant cable spreading areas utilized?
18 -,
I 430.28 Section 8.3.1.4.5.2 of the FSAR states that interlocked armor cable (8.3.1.4) is used in plant areas where the minimum separation distance cannot be maintained, and when it is used 12 inch separation is maintained between redundant Class 1E circuits or additional barriers are supplied, and six inch separation is maintained between Class lE and non Class lE cables or additional barriers are supplied. Because there is no criteria existing on which to evaluate the separation distances given for the use t.
armor cables, an analysis based on tests must be provided in accordance with section 5.1.1.2 of IEEE 384-1974. You i
. shculd also explain the different separation distances used for i
redundant Class lE circuits versus Class lE and ncn Class *lE circuits since no such distinction is made in IEEE 384-1974 or R.G.1.75.
430.29 In section 8.3.1.4.5.2 of the FSAR you state that as'sociated non Class lE (8.3.1.4) circuits will be treated as Class lE up to and. including the isolation device. As required by IEEE-384 also verify that the associated circuits will remain with, or be separated the same as, those Class lE circuits l
with which they are associated.
430.30 Identify the color coding used for the associated ncn Class lE circuits (8.3.1.3) and verify that it is in accordance with R.G. 1.75 and IEEE 384-1974.
Also identify the color coding used for non Class 1E circuits which allows them to be distinguished from Class lE and associated circuits.
Verify that cable color coding is applied prior to be pulled.
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- 430.31 Section 8.3.1.4.5.2 of the F.S&R states that the minimum separation (8.3.1.4) between penetrations carrying mutually redundant circuits is five feet in all directions. Provide the separation distances between penetration carrying Class lE circuits from penetrations carrying non Class lE circuits.
430.32 Indicate whether your cable design allows splices in raceways.
If (8.3.1.4) they are allowed, the resulting design should be justified by analysis.
430.33 In accordance with Regulatory Guide 1.70 section 8.3.1.1,. provide the (8.3.1) fault current at - and the interrupting capacity of - switchgear, load centers, control centers, and distribution panels.
430.34 Provide the separation distances maintained between Class 1E cables
_(8.3.1.4) in conduit and non Class 1E cables and redundant Class lE cables in open raceways.
630.35 The 120 VAC vital Instrumentation and Control Power System shown in
.(8.3.2.1) figure 8.3.2.3 has only one alternate power source available for the four divisions of 120 VAC instrument power fed from the static inverters, and the alternate source is taken from a non Class lE motor control center. Because this source is not Class lE,we do not view it as a i
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qualified source of power to the vital instrument buses; end, as a result, the plant must go into an LCO whenever the normal-source of poweto a r
vital instrument bus is lost. Also, irregardless of the source of power for the alternate source, is the reliability of. $h,e ' inverters such that only one alternate source is sufficient 'as a. backup to four static inverters?
j 430.36 Describe operation of the bus tie circuit breakers between. buses IEUA.
(8.3.2.1)
IEDB, IEDC and IE00 shown in Figure 8.3.2.3 of the FSAR. Arithey manually or electrically actuated and how is use of the circuit breakers controlled?
i 430.37 What is the operating voltage range of the Class lE de loads? How (8.3.2.1) i does this compare to the Class lE battery minimum discharge voltage- '
I,.
and maximum equalizing charge voltage?
430.38 The 250 VDC Auxiliary Power System, described in section 8.3.2.1.1.3
- (8.3.2.1) of the FSAR and shown in Figure 6.3.2.2, can tie the Unit 1 and Unit 2 i
division A Class lE systems together through the two normal 250 VDC battery chargers if the bus ties between the two 250 VDC distribution centers are closed during operation of the blackout loads frcm the ciesel s
generators.
Describe the intended use of this tius tie and verify that
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it will not jeopardize either division A diesel generator or the, S
Class lE system. Are the circuit breakers used in tha bus tie c'anually actuated or electrically actuated?
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430.39 -
Section 8.l.4 of the FSAR states thai each battery charger has (8.3.2.1)
Js adequate capacity to supply.its assigned steady-state loads while i
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simultaneously rechargiqg its associated battery.
Is the charger capacity. sufficient to supply the loads of two 125 VDC busses when they are inter-tied due to a loss of one battery? Provide the battery charger ratings and verify they'have sufficient capacity to supply worst-case steady state loads while simultaneously recharging the battery. Also provide the recharge time for this condition.
s 430.40 "
Section 8.3 2.1.2.1.2~of tne FSAR states that the 125 VDC Vital (8.3.2.1)P'
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.instruT.entation and Control Fower Batteries have the capacity to
) Mpply two lo'ad groups for a period of one hour, and the one hour
'. capacity is based on a conservative estimate of the. time required
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jorestorelpowertothebatterychargersunderthemostadverse v
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\\ conditions. NRC Auxiliary Systems Branch requires that' systems be
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'avaf'lable to support operation of the AFW pumps for at least two hours.
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, Provide 'the details of your analysis which supports one hour as a s
conserva{ive estimate of time to reestablish ac power to the battery s
chargers '
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T'able 8.3.2-1.and Figure 8.3.2-4 which provide the loading for these batt'eries do mot agree. Please clarify. Also, provide the ampere-hcur
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ratings for these batteries.
Do the batteries have the one-hour s
_c'apacity at the minimum anticipated battery room temperature at the
. end of[ battery service life?
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"h r 430.41 The Catawba FSAR indicates that the diesel generator batteries are (8.1.5.2)
. nickel cadium. Are these batteries Class 1E? Existing Technical Specifications only apply-to lead acid type batteries. What kind of maintenance and surveillance requirements do you propose to verify the battery are operational? Are these requirements based on accepted industry standards?
The diesel generator nickel cadium batteries are also auctioneered with the lead acid 125 VDC Vital Instrumentation and Control Power-System batteries to provide power to the Vital Instrumentation and Control Power Distributien System. Won't the dissimilar voltage 1
" discharge characteristics of the two types of batteries result in J
discharge of;the nickel cadium battery first, leaving the Diesel Essential Auxiliary Power System with no pcwer source?
Provide the diesel generator battery ampere-hour rating along with its loading and duti cycle.
Provide the time period these batteries can supply their loads when the charger is disabled.
s 430'.42 Section 8.1.5.2 of the FSAR takes exception to the IEEE 484-1975 i
(8.i.5.1) requirement t..,
the battery racks be solidly grounded. The l,
justification is that the batteries are part of an ungrounded system.
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-If the racks are metal they should be grounded in order that the ground detection scheme can detect a battery short to the rack, such as might be caused by battery electrolyte, before it becomes a double short to the rack which could disable the battery. How will the ungrounded battery racks satisfy this concern?
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430.43 The specific' requirements for DC power system monitoring derive from the (8.3.2.1) i generic requirements embodied in Section 5.3.2(4), 5.3.3(5) and 5.3.4(5) of IEEE Std 308-1974, and in Regulatory Guide I.47. In sumary, these general requirements simply state that the DC system (batteries, dis-tribution systems and chargers) shall be monitored to the extant that it,
is shewn to be ready to perform its intended function. Accordingly, the guidelines used in the ifeensing review of the DC pcwer system designs are as follcws:
The following indications and alarms of the Class 1E DC pcwer systes status should be provided in the control room:
- Battery current (arceter-charge / discharge)
- Battery charger output current (ameter)
- DC bus voltage (voltmeter)
- Battery charger output voltage (voltmetar)
- Battery discharge
- DC bus undarvoltage and overvoltage alars
. - DC bus ground alars (for ungrounded system)
- Battery breatar(s) or fuse (s) open alars
- Battery charger output breakar(s) or fuse (s) open alars
- Battery charger troch's alars (one alars for a number of abnormal conditions which art usually indicated locally)
It has been concluded that the above cited monitoring, avgr:ented by the periodic t[st and surveillanca redu'irements included in the Technical i
Specifications, provida reasonabla assurance that the C7 ass 1E DC power
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system is ready to perform its intanded safety function. Please indicate your compliance or justify any deviation.
6 430.44 Section 8.1.5.2 of the FSAR indicates that a hydrogen survey in the (8.1.5.2) battery rooms is not performed or recorded as required by Regulatory Guide 1.128 since the amount of hydrogen present during recharging is very small. R.G.1.128 establishes this requirement precisely to determine that the ventilation system limits hydrogen concentration to less than 2%. Since the staff has no information that this is no longer a needed requirement, the hydrogen survey must be performed.
430.45 The description of the diesel generator protection system contained (8.3.1.1) in FSAR section 8.3.1.1.3.4 is not complete. Describe the sequence of events which occur if the diesel generator fails to start following an automatic start signal.
Is the unit tripped after a specified period of time? Locked out? Is sufficient air left to attempt subsequent starts and how will these subsequent starts be performed?
430.46 Regarding protection of penetration assemblies, section. 8.l.5.2 of the (8.1.5.2)
FSAR states that those circuits which are incapable of supplying a fault current sufficient to cause a loss of mechanical integrity of the penetration do not require circuit overload protection (e.g., thermo-couple instrumentation circuits, annunciator and computer points).
Indicate the margin between the maximum available fault current of these circuits and the rated continuous operating current of the penetration device.
If the fault current is greater than the rated continuous operating current of the penetration it must be protected by at least two protective devices.
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430.47 Verify that a service test is performed on the Class lE batteries (8.3.2.1) during preoperational testing as required by position C.1 of Regulatory Guide 1.129 and as described in section 5.6 of IEEE 450-1975.
430.48 Section 8.3.1.l.3 of the FSAR states that each diesel generator is (8.3.1.1) designed to attain rated voltage and frequency and to accept load within 11 seconds after receipt of a start signal. Generally the starting time for diesel generators'used in nuclear plants is 10 seconds.
Is 11 seconds sufficient to mitigate the consequences of a design basis accident, and has this value been used in the accident analysis?
130.49 In the Response to TMI Concerr.s, Table 1.9-1, section II.G the 1.9)
Catawba FSAR states that the pressurizer power-operated relief valves are air-operated with de control solenoids.
Identify the electrical power source to the air system.
In accordance with NUREG-0737. Item II.6i.1, Clarification 4, the electrical power supply to the air system should have the capability to be manually connected to the emergency power sources.
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. 430.50 Operating expertence at certain nuclear power plants which have two (8.3)
RSp cycle turbocharged diesel engines manufactured by the Electromotive Division (EMD) of General Motors driving emergency generators have expertenced a'stgnificant number of turbocharger mechanical. gear drive' failures. The failures have occurred as the result of running the c
emergency diesel generators at no load or light load conditions for extended periods. No load or 1.tght load operatton could occur during periodic equipcsent 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 turtpcharger.
As a result the turbocharger is driven mechanically from a gear drive in order to supply enough combuston air to the engine to maintain rated speed. The turbocharger and mechanical drive gear normally supp1ted with these engines are not designed for standby service encountered in nuclear power plant application where the equipraent may be called upon to operate at no load or light load condition and full rated speed for a prolonged period. The DiD equipment was ortgtnally designed for locomotive service.
where no load speeds for the engine and generator are :uch lower than full load speeds. The locomotive turbocharged diesel hardly ever runs at full speed except at full load. :The EMD has strongly recomended to users of this diesel engine design.against' operation at no load or light load conditions at full rated speed for extended periods because of the short 11fe expectancy of the turbocharger mechanical gear drive unit normally 1
furnished. No ioad or light load operation also causes general deterioration in any diesel 'sngine.'
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To cope with the severe seriica'the equipment is nonna11y subjected'to and -
in the interest of reductng failures and increasing the availahtitty of their equipcent EMD has develop' d a heavy duty turbocharger drive gear e
unit that can replace existing equipment. This is available as a replacement kit, or engines can be ordered with the heavy duty turbo-charger drive gear assembly, I
To assure optimum availability of emergency diesel generators on demand,
(
Applicant's who have in place, on order or intend to order emergency generators driven by two cycle diesel engines manufactured by EMD, should be provided with the heavy duty turbocharger mechanical drive gear assembly as recorm: ended by EMD for the class of service encountered in nuclear power plants. Confirm your compliance with this requirement.
430.51 Provide a detail discussion (or plan) of the level of traini,ng proposed (8,3) for your operators, maintenance ~ crew, quality assurance, and superytsory personn.el responsible for the operation and maintenance of the emergency diesel, generators. Identify the number and type ofipersonnel that will be dedicated to the operations and maintenance of the emergency diesel generators and the number and type that will be assigned from your general plant operations and maintenance groups to assist when needed, In your discussion identify the amount and kind of training that will be received by each of the above categories and the type of ongoing training program planned to assure optimum availabtitty of the emergency 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 generators.
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l 430.52 Periodic testing and test loadtng of an emergency diesel, generator.
(8.3)
RSP in a nuclear power plant. is a necessary function to demonstrate the operability, capabtitty and availabtitty of the unit on demand. Periodic testing coupled with, good preventive maintenance practices will assure +
optimum equipment readiness and availability on demand. This is the desired goal, To achieve this optimum equipment readiness status, the follow 1.ng requirements should be meti
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The equipment should be tested with a atntmum loading of 25 percent-of rated load. No load or 1ight load operation will cause incomplete combustion of fuel resulting in the formation of. gum and varnish deposits on the cylinder walls, intake and exhaust valves, pistons and piston rings, etc.', and accumulation of unburned fuel in the turbocharger and exhaust system. The consequences of no ' load or light load operation are potential equipment failure due to the gum and vhrnish deposits and fire in the engine exhaust system.
2 Periodic surveillance testing should be performed in accordance with
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the applicable MRC guidelines (R.g.1.108), and with the recomendations of the engine manufacturer. Conflicts between any such recommendations and the NRC guidelines, particularly with. respect to test frequency,
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loading and duration', should be identified and justified, l
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Preventive maintenince should..go beyond the normal routine adjust-ments, servicing and repair of components when'a malfunction occurs.
Preventive maintenance'she'uld encompass investigative testi.ng of
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D components htch'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 demonstrated reliabtitty, rather than repetitive repair and maintenince'of the existing components. Testing of the unit after' adjustments or repairs have been made only confirms that the equipment is operable anddoes not necessarily meang hat the t
root cause of the problem has been eltainated or alleviated.
4 Upon' completion 'oflepairs or maintenance and prior to an actual start, run, and ' load test a final equipment check should be made to assure that all electrical circuits are functional, i.e., fuses are in place, switches and circuit breakers are in their proper position, no loose wires, all test leads have been removed, and all valves are in the proper position to permit a manual start of the equipment, After the unit has been satisfactorily started and load tested, return the unit to ready automatic standby service and under the centrol of the control room operator.
Provide e discussion of how the above requirements have been implemented in the emergency diesel generator sys't'em' design and how they will be considered when the plant is in corrercial operation, i.e., by what means will the above requirements be enforced.
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450.53 The availability on demand of,an' emergency'dtesel generator is (8.3)
RSP dependent upon, among other things, the proper functioni,ng of its,
controls and monitoring instrumentation. This equipment is. generally panel mounted and in some instances'the panels are pounted directly on the diesel, generator sktd.. Major diesel engine damage has occurred at some operating plants from ytbratton induced wear on skfd mounted contml and monitoring instrumentation. This sensitive instrumentation is not made to withstand and function accurately for prolonged periods under continuous vibratio1al stresses'normally encountered with internal combustion engines. Operation of sensttye instrumentation under this environment rapidly dkteriorates 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 unitoring instrumentation should be installed on a free standing 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.
l Confirm your compliance with the above requirement or provide justification for nonccmpliance.
1
. 430.54 The information regarding the onsite comunications system (Section (9.5.2) 9.5.2) does not adequately cover the system capabilities during transients and accidents.
Provide the following information:
i (a) Table 9.5.2.1 lists certain locations and the comunication systems in those areas that are available for transient and accident conditions. The list seems incomplete in that it does not include all areas needed to bring the plant to a safe cold shutdown.
Identify a
any additional working stations on the plant site where it may be necessary for plant personnel to comunicate with the control room or the emergency shutdown panel during and/or following transients and/or accidents (including fires) in order to mitigate the conse-quences of the event and to attain a safe cold plant shutdown.
In addition identify the systems associated with the valves listed in Table 9.5.2.1.
(b)
Indicate the maximum sound levels that could exist at each of the above identified working stations for all transients and accident condttions.
(c)
Indicate the types of comunication 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 yet reliably expect effective comunication with the control room using:
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- 33i-a 1.
the page party communication systems, and 2.
any other additional canmunication system provided that working station.
(e) Discuss the protective measures taken to assure a functionally operable onsite communication system. The discussion should include the considerations given to component failures, loss of power, and the severing of a communication line or trunk as a result of an accident or fire.
430.55 The Description of the Emergency Offsite Communication Systems is (9.5.2) incomplete.
Provide a detailed description of each plant to offsite communication system including any radio systems used.
In the description, provide the locations served (both on and offsite) by the communication systems as well as their power sources.
430.56 Table 9.5.2-1 identifies certain areas and their communicaticn systems (9.5.3) during accident and transient conditions. Section 9.5.3.2 identifies those areas of the plant served by the emergency lighting systems; not all the areas listed in Table 9.5.2-1 are listed in section 9.5.3.2.
The reverse is also true. Therefore, identify all vital areas and hazardous areas where emergency lighting is needed for safe (cold) shutdown of the reactor and the evacuation of personnel in the event of an accident.
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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 fire.
430.57-Section 9.5.3.2 of the FSAR describes the emergency lighting system (9.5.3)
RSP which is composed of three subsystems. They are the 2E0 VDC, 208Y/120 VAC,
and eight hour battery lighting systems. A number of areas in the plant are served by these systems, each area being served by one of the DC systems and/or the AC system. All systems are classified non-Class lE.
The AC system takes its power from the diesel generators, but must be mcnually connected in the event of a LOCA or manually reconnected on any accident following a loss of offsite power. Assuming a failure or non-availability of the 250 VDC lighting system, it is possible that portions of the plant particularly the control room may be without sufficient lighting for extended periods of time during an accident.
This is unacceptable.
It is our position that adequate lighting be provided to all vital and hazardous areas needed for the safe shutdown of the reactor and the evacuation of personnel in the event of an accident.
Provide the necessary lighting.
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. 430.58 Section 9.5.4.2.3 of the FSAR lists the instruments, controls, sensors (9.5.4) and alarms provided for monitoring the diesel engine fuel oil storage and transfer system. The description for these items is incomplete.
Provide the following:
Discuss the testing necessary to maintain and assure a highly reliable instrumentation, controls, 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 what operator actions are required during alarm conditions to prevent harmful effects to the diesel engine. Discuss the system interlocks provided.
(SRP9.5.4,PartIII, item 1).
430.59 The diesel generater strue'tures are designed to seismic and (9.5.4) tornado criteria and are isolated from one another by a reinforced concrete wall barrier. Describe the barrier (including openings) in more detail and it: capability to 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 additional generator.. (SRP 9.5.4, Part III, Item 2).
430.60 Describe your design provisions made to protect the fuel oil (9.5.4) storage tank fill and vent lines and the day tank vent line and flame arrestor that are ex' posed above the roof from damage by tornado missiles.
(SRP 9.5.4, Part II)
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430.61 In section 9.5.4.3 you state that tanks and other underground components (9.5.4) are protected from corrosion by a coal-tar enamel coating similar to that described by AWWA C203-1973. This statement is too general.
Expand the FSAR to include a more explicit description of proposed protection of underground piping. Where corrosion protective coatings are being considered (piping and tanks) include the industry standards which will be used in their application. Also discuss what provisions will be made in the design of the fuel oil storage and transfer system for internal corrosion protection for the fuel oil storage tanks and in the use of an impressed current type cathodic protection system, in addition to water proof protective coatings, to minimize corrosion of buried piping or equipnent.
If cathodic protection is not being considered, provide your justification.
In addition discuss the need for internal corrosion protection of the day tanks (SRP 9.5.4, part II, and Part III, item 4).
430.62 The FSAR text and Table 3.2.2-2 states that the components and piping (3.2)
(9.5.4) systems for the diesel generator auxiliaries (fuel oil system, cooling (9.5.5)
(9.5.6 water, lubrication, air starting, and intake and ccmoustion system) that (9.5.7 (9.5.8 are mounted on the auxiliary skids are designed seismic Category I and have a quality classification of Duke Class C, non-nuclear safety or not applicable. Tables 3.2.2-3 and 3.2.2-4 define Duke Class C as equivalent to ASME Section III Class 3 quality. The engine mounted components and piping are seismic Category I but the s':tdards to which they are designed has not been defined.
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.
I
37 -
Provide the following:
(a)
The industry standards that were used in the design, manufacture,, '
V and inspection of the engine mounted piping and components.
Also i show on the appropriate P&ID's where the Quality Group Classification changes from Quality Group C.
(b)
Table 3.2.2-2 defines certain pumps, filter, strainers, silencers, and valves in the diesel generator' auxiliary systems as non-nuclear safety or not applicable with regards to Quality Group Classification.
It is our position that all components and piping in the diesel generator auxiliary systems be designed to ASME Secti'n III Class 3 o
requirements. Comply with this position.
330.63 39.5.4)
Section 9.5.4.3 of the FSAR states that the emergency diesel engine fuel oil storage and transfer system (EDEFSS) conforms to ANSI Standard N195
" Fuel Oil Systems for Standby Diesel Generators" except for the overflow line from the day tank, fill line strainers, and flame arrestors on the storage tanks.
Provide justification for the noncompliance with the i
standard for the fill line strainers and the flame arrestors.
For the overflow line from the day tank shew that it is designed seismic Category I and to ASME Section III Class 3 requirements.
Also show that it is tornado missile protected For the entire length of the vent (see question 430.60).
In addition, -'. ate your compliance to Regulatory Guide 1.137 " Fuel Oil Systems fo Standby Diesel Generators" position C.2a through C.2.h.
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430.64 Figures 9.5.4-10 and 9.5.4-11 indicate an underground crossing of the (9.5.4) safety-related fuel oil lines to the seven-day fuel oil storage tanks with the non-safety condenser circulating water (CCW) lines, which are huge and subject to seismic or other failures. State the consequences of a failure of a CCW line as it relates to the fuel oil lines and tanks--at their underground crossing points in the yard.
430.65 Discuss the design considerations that have determined the physical (9.5.4) location of the diesel engine fuel oil day tank at your facility.
Assure that the selected physical location of the fuel oil day tanks meet the requirements of the diesel engine manufacturer and for the NPSH of the fuel oil and fuel oil booster pumps.
(SRP 9.5.4, Part III, item 5(c).)
430.66 Assune an unlikely event has oc:urred requiring operation of a (9.5.4) diesel generator for a prolonged period that would require replenish-ment of fuel oil without interrupting operation of the diesel gen-erator. lihat provision en be made in the design of the fuel oil storage fill system to minimize the creation of turbulence of the rediment in the bottom of the storage tank. Stirring of this sediment during addition of new fuel has the potential of causing
. the eve all quality of the fuel to become unacceptable and could potentially lead to the degradation or failure of the diesel genera-tor.
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430.67 You state in the FSAR section 9.5.4.2.1 that to prevent settling, (9.5.4) stratification and deterioration of the fuel oil during extended 4
storage periods, a recirculation pump is provided. This pump can be 1
used to recirculate oil within a single storage tank or transfer oil from one storage tank to another. This statement is too general.
Provide a description of the system, location or equipment, locations of the suction and discharge piping in the tanks, and duration of operation (continuous or intermittent). Also, provide a discussion on provisions in the system design to minimize.the creation of turbulence of the sediment in the bottom of the storage tanks during recirculation and fuel oil transfer. The stirring of this sediment during these operations has the potential of causing the overall quality of the fuel to become unacceptable and could potentially lead to degradation or failure of the diesel generator.
430.68 You state in section 9.5.4.2 that the diesel generator fuel oil (9.5.4) storage tank is provided with an individual fill and vent line.
Indicate where these lines are located (indoor or outdoor) and the heightthese lines are terminated above finished ground grade.
If these lines are loccted outdoors discuss the provisions made in your design to prevent entrance of water into the storage tank dur-ing adverse environmental conditions.
430.69 Recent licensee event reports have shown that tube leaks are being (9.5.5) experienced in the heat exchangers of the jacket ' cooling water system.
s Provide a discussion on the means used to detect tube leakage and the 1
corrective measures that will be taken.
Provide the permissible inleakage or outleakage for each subsystem cooled by the cooling water system and the time of operation with leakage to assure coolant or cooled ~
liquid quality can be maintained within safe limits. Also provide the results of a failure mode and effects analysis to show that failure of a piping connection between subsysters (engine water jacket, lube oil cooler, governor lube oil cooler, and engine air inter-cooler) does not cause total degration of the diesel generator cooling water system (SRP 9.5.5, Part III, Item la).
430.70 FSAR section 9.5.5.2 refers apparently to two kinds of " standby operation."
(9.5.5)
The first paragraph states that the engine-driven cooling water circulation pump operates during engine standby and assures 'that the system is completely filled with water. The third paragraph states that a keep-warm circulating pump keeps "the engine warm during standby." Describe the j
meaning of standby operation for both of these cases. Modify the FSAR l
accordingly.
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. l the FSAR lists the instrumentation, controls, 430.71 Section 9.5.5.2.3 o (9.5.5) sensors and alarms provided for monitoring of the diesel engine cooling water system. Discuss the testing necessary to maintain and assure a highly reliable instrumentation, controls, sensors, and alarm system, and where the alarms are annunciated.
Identify the temperature, pressure, level, and flow (where applicable) sensors which alert the operator when these parameters exceed the ranges recocnended by the
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engine manufacturer and describe what operator actions are required during alam conditions to prevent hamful effects to the diesel en-gine. Discuss the systems interlocks provided. (SRP 9.5.6, Part III,itemIc).
430.72 Describe the provisions made in the design of the diesel engine (9.5.5) cooling water system to assure that all components and piping are f
filled with water.
(SRP 9.5.5, Part III, Item 2).
430.73 You state in section 9.5.5.2.1 that the s%ndby diesel engine design is (9.5.5) such that it can operate at no load and full speed for seven days without degradation of the engine.
Provide the make and type of engine and the design features which enabies the engine to operate. at no load and full speed for seven days without l
degradation of perfomance and reliability.
Provide the manufacturer's test results which verify the above cited capability and no load and l
light load operation reconnendations.
. 430.74 You state in section 9.5.5.2 each diesel engine cooling water system (9.5.5)
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is provided with an expansion tank to provide for system expansion and for venting air from the system.
In addition to the items mentioned, the expansion tank is to provide for minor system leaks at pump shafts seals, valve stems and other components, and to maintain required NPSH on the system circulating ptsnp. Provide the size of the expansion tank and location.
Demonstrate by analysis
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that the expansion tank size will be adequate to maintain required pump NPSH and make up water for seven days continuous operation of the diesel engine at full rated load without makeup, or provide a seismic Category I, safety class 3 make up water supply to the ex-panston tank.
430.75 Provide a discussion of the measures that have been" taken in the design (9.5.6) of the standby diesel generator air starting system to preclude the fouling of the air start valve or filter with moisture and contaminants such as oil carryover and rust.- (SRP S.5.6, Part III, item 1).
430.76 Section 9.5.6.2.3 of the FSAR lists.ae instrumentation, controls, (9.5.6) sensors and alarms provided for monitoring the diesel engine air starting system. 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 recomended by the engine manufacturer and describe any operator actions required during alarm conditions to prevent harmful effects to the diesel engine. Discuss system interlocks provided.
Revise your FSAR accordingly.
(SRP 9.5.6, Part II, item 1).
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430.77 You state in section 9.5.6.2.1 that each diesel engine is provided (9.5.6)
RSP with two independent air starting systems each with its own air receiver tank. You also state that the air start system has sufficient capacity for a minimum of 5 successful engine starts without the use of the air compressor.
Section 8.3.1.1.3.2 states that the air start system has sufficient capacity for a minimum of two successful starts.
This is inconsistent, and not acceptable. We require, as a minimum, the air starting system for each standby diesel generator should be capable of cranking a cold diesel engine five times without the use of the air compressor.
Revise your design and FSAR accordingly.
(SRP 9.5.6, Part III, item 9b).
430.78 Table 9.5.6-1 " Diesel Generator Engine Starting Air System Single Failure (9.5.6)
Analysis" is incomplete.
It does not consider a failure of the starting air distributors, or govg(nor oil pressure boost cylinder.
It also only considers a pipe break upstream of checkvalves 1.VG28, lVG29, lVG30, and LVG31.
Revise the table accordingly.
430.79 Section 9.5.6.2.1 states that the starting air is supplied to the (9.5.6) ends "of the two cylinder banks on the engine.
From there, the starting air is directed to the individual cylinders by the starting air distributors..."
Figures 9.5.6-1 and 9.5.6-2 do' not seem to l
confonn to this description. The figures seem to show the No. 2 system feeding air to the starting cir distributors upstream of the cylinder banks, and the No. 1 system feeds air into the cylinder banks, then into the No. 2 system and frem there into the starting air distributors. The sameistrueforthegoveforoilpressureboostcylinderonlythe I
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o supplying systems are reversed. System 1 is the primary system and System 2 seems to be secondary.
Provide a detailed description of how the air starting system functions.
Include in the description:the-starting air systems that serve the sterting air distributors and governor oil pressure boost cylind;r.
430.80 The air starting system has multi-stage drying and filtering unit (9.5.6) installed to minimize the accumulation of moisture. This portion of the air starting system is non-seismic and classified as non-nuclear safety. Accumulation of water in the starting air system has been
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The air dryers installed in the system will provide the dry quality air needed to enhance starting reliability. Our concern is that unless the air dryers are properly maintained, the air quality may be degraded and moisture may be introduced into the system. Discuss the plant controls and I
procedures that will be used to assure that the air starting system has dry, quality air.
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' 430.81 For the diesel engine lubrication system in section 9.5.7 provide the (9.5.7) following information:
- 1) 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; and 2) describe the capability for detection and control of system leakage.
(Both into and out of the system - see Question 430.69)
(SRP 9.5.7, Part II, Items 8a, 8b, Sc, Part III, Item 1) l l
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430.82 Section 9.5.7.2.3 describes the instrumentation, controls, sensors and (9.5.7) alarms provided for monitoring the diesel engine lubrication oil system.
"uscribe 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 action required during alarm conditions to prevent harmful effects to the diesel engine. Discuss systems interlocks provided. Revise your FSAR accordingly.
(SRP9.5.7, PartIII,itemle).
430.83 Section 9.5.7.2.1 of the FSAR states that "Before the engine is started, (9.5.7) the lube oil system must be pressurized by the pre-lube oil pump...
The pre-lube oil pump is connected in parallel with the engine driven pump. Oil circulation.is through the same internal system with the exception of the turbochargers, but the pump is of sufficient :ize to assure complete filling of the system with oil before starting."
Section 9.5.7.2.2 states that "The prelube oil pump delivers warmed oil to the engine during standby..." Figures 9.5.7-1 and 9.5.7-3 do not appear to agree with the FSAR text. Clarify the above and also provide a detail description of the prelube system operation.
Include in the description whether the system is centinuously or intennittently operated on standby or operated just on manual start, and the parts of the engine the system lubricates.
If the prelube system is manually started only when the engine is manually started, answer Questions 430.84 and 430.85 that follow.
If the system operates continuously but only lubricates some of the wearing parts of the engine, answer Question 430.85 only.
430.84 Several fires have occurred at somelperating plants in the area of (9.5.7)
RSP the diesel engine exhaust manifhld.and inside the turbocharger housing which have resulted in equipment unavatlability. The fires were started fmm lube oil leaktng and accumulating on the engine exhaust manifold and accumulating and, igniting inside the turbocharger housi.ng.
Accumulation of lube oil in these areas, on some engines, is apparently caused from an excessively long prelube period, generally longer than
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five minutes, prior to manual starting of a diesel generator. This l
condition does not occur on an emergency' start since the prelube pariod is minimal.
l When manually starting the diesel generators for any reason, to minimize t
the potential fire hazard and to improve equipment availabiltty, the prelube period should be'11mited to a maximum of three to five minutes unless otherwise recomended by the diesel engine manufacturer. Confirm your compliance with this requirement or provide your justification for requiring a longer prelube time interval prior to manual starting of the diesel generators. Provide the prelube time l interval your diesel engine will be exposed to prior to manual start.
430.85 An emergency diesel. generator unit in a nuclear power plant is nontally (9.5.7)
RSP in the ready standby mode unless there is a loss of offstte power, an accident, or the diesel, generator is under test. Long periods on standby have a tendency to drain or nearly empty the engine lube oil pf ptng I
system. On an emergency start of the engine as much as 5 to 14 or more l
seconds may elapse fmm the start of cranking until full lube oil pressure is attatned even though full engine speed is. generally reached in about i
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five seconds. With an essentially dry engine, the momentary lack of lubrication at the various movtng parts may damage bearing surfaces pro-ducing incipient or actual component failure with resultant equipment s unavailability.
The emergency condition of readiness requires this equipmat to attain full rated speed and enable automatte sequencing of electric load within ten seconds.
For this reason, and to improve upon the availabiltty of this equipment on demand, it is necessary to estabitsh as quickly as possible an oil film in the wearing parts of the diesel engine. Lubricating oil is normally delivered to the engine wearing parts by one or more engine driven pump (s). During the starting cycle the pump (s) accelerates slowly with the e.ngine and may not supply the required quantity of lubricating oil where
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needed fast enough. To remedy this condition, as a etntmum, an electrically driven lubricating oil pump, powered from a reltable DC power supply, should
......be installed in the lube oil system to operate in parallel with the engine driven main lube pump.
The electric dr1 Yen prelube pump should operate-. -
onlyduring the engine cranking cycle or ontti satisfactory lube oil pressure is established in the engine matn lube distributton header.
The insta11atica of this prelube pump should be coordinated with the respective engine manufacturer. Some diesel engines include a lube oil circulating pump as an intregal part of the lube oil preheating system which is in use while the diesel engine is in the standby mode.
In this case an additional prelube oil pump may not be needed.
Confirm your compliance with the above requirement or provide your justification for not insta111ng an electric prelube oil pump.
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You state in section 9.5.7.2.1 of the FSAR and shown in {igure 9.5.7.2, 'n.
430.86 (9.5.7)
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that lube oil is added to the diesel generator lubricating oil sys, tec%
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from an 8000 gallon underground lube oil storage tank. ProvideaY
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discussion on the measures that have been taken to prevent entry #of;
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accumulation of water, sediment or other deleterious maerial in the '
underground clean lube oil storage tank. Also discuss what measures i
s have been taken to prevent entry of. deleterious materials into the Y,,,
underground clean lube oil storage tank due to operator error during
,y filling operations.
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(a) Discuss themeans for detecting or preventing growth of algae in J
the clean lube oil storage tank.
If it were detected, describe C[
the methods to be provided for cleaning the affected storage
['ss tank.
l (b) Provide an explicit description of proposed corrosion protection for the underground piping and lube oil storage tank. Where corrosion protective coatings are being considered for the piping and tanks (both external and internal) include the industry standards which will be used in their application. Also discuss what provisions will be made in the design of the lube oil storage
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and transfer system in the use of a impressed current type cathodic protection system, in addition to water proof protective coatings, to minimize corrosion of buried piping or equipment.
If cathodic l
protection is not being considered, provide your justification.
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(c) Figure 9.5.7.2 of theJ SAR shows that the diesel generator clean N Q " s..,%
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lobe oil storage tank is provided with an individual fill and vent.
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Indic' ate,where these lines are located (indoor or outdoor) c,;
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[fsthesel. ines are located outdoors discuss the provisions 1
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-430.8f Figure 19.5.4-3, 9.5.4-6'and 9.5.4;7 show an open ended diesel generator (9.5.8)
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exhaust pipe extending out of the D/G building vall, with no protection s,
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430.88 Describe the instrumentation., controls, sensors and alarms pmvided in (9.5.8) the design of the diese'l 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 conditions to prevent harmful effects to the diesel engine.
Discuss systems interlock.s provided. Revise your TSAR accordingly.
(SRP 9.5.8, Part III, item 1 & 4).#
430.89 Experience at some operating plants has shown that diesel engines have (9.5.8) failed to start dLt to accumulation of dust and other deldertous material on electrical equiprent associated with starting of the diesel generators (e.g., auxiliary relay contacts, control switches - etc.).
Describe the pmvisions 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 riant operation what precedures(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 constructicn (acnormal generation of dust).
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430.90 Section 9.5.8.2.1 of the FSAR describes the combustion air intake (9.5.8)
RSP structure for the diesel generator building. Figures 9.5.4-3_through 9.5.4-9 show the layout of the diesel generator building. The figures are not clear. and it is difficult to determine the arrangement and location of the outer air intake structure. The description in the-FSAR imp 1ks that both diesel generators share the same outer air intake structure. a) The description of the system is insufficient and is unacceptable. We require that each. diesel generator has its own intake structure which is separate and independent of the other diesel generator's air intake structure.
Provide a detailed description of the system and show that you comply with the above position. b) The FSAR states that for the air intake structure, dust, rain, ice, and snow are removed by floor drains ir the outer combustion air intake compartment. Floor drains will only remove water accumulation, not dust, snow, ice, or freezing rain. Discuss the provisions made in your design of the d;esel engine combustion air intake and exhaust system to prevent possible clogging, during standby and in operation, from abnormal climatic conditions (heavy rain, freezing rain, dust storms, ice and snow) that could present operation of the diesel generator on demand.
(SRP 9.5.8, Part III, item 5).
430.91 You state in section 9.5.8.3 of the FSAR that "A fire within one diesel (9.5.8) room, along with a single failure of the fire protection system, will be completely contained within that room. The combustion products will be exhausted from the room by the ventilation system at the end of the 9
. building opposite from the end which contains the intake structure for the redundant diesel.
If the fire protection system operates as designed and extinguishes the fire, the gaseous carbon dioxide (extingu.shing medium) will be contained in the same matter." We disagree with this statement. A fire within one diesel room along with the failure of the supply ventilation fire damper would allow the products of combustion and/or the carbon dioxide to go out the ventilation inlet which shares the same plenum as the ' combustion air intake.
If the design is as is stated above in Question 430.90 or if the outer air intake structures are separate, the gaseous products could be drawn into the other diesel generator's air intake. Show by analysis that a potential fire in the diesel generator building together with a single failure of the fire protection system will not degrade the quality of the diesel combustion air so that the remaining diesel will be able to provide full rated power.
430.92 In the turbine generator section discuss: 1) the valve closu' e times and (10.2) the arrangement 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 times and extraction steam valve arrangements in relation to stable turbine operation after a turbine generator system trip.
(SRP 10.2, Part III, Items 3, 4.)
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430.93 The FSAR discusses the main steam stop and control, and reheat (10.2) stop and intercept valves. Show that a single failure of any of the above valves cannot disable the turbine overspeed trip func-tions. (SRP 10.2. Part III. Item 3).
430.94 Discuss the effects of a high and moderate energy piping failure (10.2) or failure of the connection from the low pressure turbine to condenser on nearby safety related equipnent or systems. Discuss what protection will be,prbvided 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. (SRP10.2.PartIII.Ites8).
430.95 In section 10.2.3.6 you discuss inservice inspection and exercising (10.2) of the main steam turbine stop and control and reheater stop and intercept valves. You also discuss the inservice inspection, testing and exercising of the extraction steam valves. You do not provide the time interval between periodic valve exercising to assure the extraction steam valves will close on turbine trip.
Provide this time interval.
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430.96 Describe in more detail and with the aid of drawings, the bulk hydrogen
'(10.2) storage facility including its location and distribution system.
Include the protective measures considered in the design to prevent
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fires and explosions during operations such as filling and' purging the generator, as well as during normal operations.
430.97 Discuss the measures taken for detecting, controlling and correcting.
(10.4.1) condenser cooling water leakage into the condensate stream.
(SRP 10.4.1,PartIII, item 2).
430.98 Provide tb6 pemissible cooling water inlaakage and time of opera-(10.4.1)
. tion with inleakage to assure that condensate /feedwater quality can be maintained within safe limits.
(SRP10.4.1,PartIII, item 2).
In section 10.4.1.4
'u have discussed tests and initial field in-430.99 (10.4.1) spection but not the frequency and extent of inservice inspection of the main condenser. Provide this information in the FSAR.
(SRP 10.4.1, Part II).
l430.100 Indicate what design provisions have been made to preclude failures (10.4.1) of condenser tubes or components frcm blowdown or high temperature drains into the condenser shell.
(SRP 10.4.1, Part III, item 3) l l
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. 430.101 Discuss the effect of loss of main condenser vacuum on the operation (10.4.1) of the main steam isolation valves (SRP 10.4.1, Part III, item 3).
430.102 Discuss the measures taken; 1) to prevent loss of vacuum, and 2) to (10.4.1) prevent corrosion /errosion of condenser tubes and components.
(SRP 10.4.1, Part III, item 1).
430.103 Indicate and describe the means of detecting and controlling radioactive (10.4.1 )
leakage into and out of the condsaser and themeans for processing excessive amounts.
(SRP 10.4.1, Part III, item 2).
430.104 In section 10.4.4.4 yo; have discussed tests and initial field inspection (10.4.1) but not the frequency and extent of inservice testing and inspection of the turbine bypass system.
Provide this information in the FSAR.
(SRP10.4.4,PartII).
430.105 Provide the results of a failure mode and effects analysis to (10.4.)
detemine the effect of malfunction of the turbine by-pass sys-tem on the operationof the reactor and main turbine generator unit.
(SRP 10.4.4, Part 'III, itect
).
430.106 (10.4.4)
Assure that a high energy line failure of the turbine by-pass sys-tem will not haYe an adverse effect or preclude operation of turbine speed controls or any safety-related components or systems located close to the turbine hypass system.
(SRP 10.4.4 Part III, item
).
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