Text

Forwards Response to Series 430 Requests for Addl Info Dtd 820212
	ML20049J363
Person / Time
Site:	Seabrook
Issue date:	03/12/1982
From:	Devincentis J; PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:	Miraglia F; Office of Nuclear Reactor Regulation
References
	SBN-236, NUDOCS 8203170583
	Download: ML20049J363 (250)
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SEABROM STATION Engineering Office:

O I Companyof PUBLIC SEAVICE NewHampshw e 1671 Worcester Road D Framinoham, Massachusetts 01701 (617) - 872 8100 N/

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r. Y',';) ' ' /;S Ma rc h 12, 9g2. /N f)'r ...,fW SBN-236 ei f I2 T.F. B 7.1.2 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Frank J. Miraglia, Chief Licensing Branch #3 Division of Licensing O Re fe re nc es : (a ) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated February 12, 1982, " Request for Mditional Information," F. J. Miraglia to W. C. Tallman Su bj ec t : Responses to 430 Series RAIs; (Power Systems Branch)

Dear Sir:

We have enclosed responses to the subject RAIs, which you forwarded in Re f e re nc e (b).

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY wL/LA John DeVincentis Project Rinager JDV: ALL: dad l

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430.2 Section 8.1.5.1 of the FSAR indicates that the design of the

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(,,_s on-site power system conforms only to CDC 17 and 18 of Appendix A to 10CFR Part 50. It is the staff requirement that the Seabrook of f-site power system conform to CDC 5,17 and 18 and the on-site power system conf orm to CDC 2, 4, 5, 17, 18 and 50. Revise the FSAR to indicate compliance with these GDC's or justify non-compliance.

RESPONSE: The on-site power system design conforms to GDC 2, 4, 5, 17, 18 and 50. FSAR Section 8.1.5.1 addresses GDC 17 and 18 and will be revised to include GDC 2, 4, 5 and 50. Section 3.1 discusses conformance of the plant design to General Design Criteria.

Section 8.3 discusses, in detail, the conformance of the on-site power system to GDC 5, 17 and 18.

The off-site power system conforms to GDC 5. The following section will be added to the FSAR as Section 8.2.1.7: 8.2.1.7 Compliance With General Design Criterion 5.

The off-site power systems of Uait 1 and Unit 2 share a common 345 kV power grid, common connecting transmission lines and a common 345 kV switching station. Such sharing does not impair the ability of the of f-site power system to supply the required safety loads in the event of an accident in one unit while simultaneously supplying suf ficient power to the other unit to permit an orderly shutdown and cooldown. With both Unit I and Unit 2 generators p of f-line, any one of the connecting 345 kV transmission lines has

( ,) the capability to supply the total station service load of both units. In addition, as noted in Section 8.2.2.1, the operation of the 345 kV circuit breakers to clear faults on transmission lines or within the switching station will not interrupt more than one of the of f-site power circuits to either unit. Normal tripping of a unit will have no ef fect on the availability of of f-site power to either unit since the generator is disconnected by means of the generator circuit breaker associated with that unit.

Indication and control of the of f-site power circuits for Units 1 and 2 are such that events in one unit will not interfer, with the ,

ability of operators in the other unit to control and monitor the status and availability of the off-site power system.

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start-up and shutdown, auxiliary power may be taken from the 345 kV system in one of two ways:

a. Back-fed through the generator step-up transformers and unit auxiliary trans formers when the generator circuit breaker is open.

b. From the reserve auxiliary trancformers.

The one-line diagram of the onsite ac power system for each unit is shown in Figure 8.3-1. The principal feature of this system is the two redundant diesel generators which are connected to two groups of redundant emergency buses and loads when a loss of all of fsite power sources occurs. Each redundant emergency bus ar.J associated load group has sufficient redundancy, :

independence and testability to assure that the safety functions are pe r fo rmed .

The onsite ac vital instrumentation and control power system one-line diagram is shown in Figure 8.3-3. This system, consisting of inverters and distribution panels, provides power to safety related control and instrumen-tation systems. Sufficient redundancy, independence, and testability are incorporated to assure that the safety functions are performed.

O V The onsite de system one-line diagram is also shown in Figure 8.3-3. This system consists of batteries, battery chargers, and distribution. panels. (

The oc system provides power for the normal and standby de requirements. A.

Sufficient redundancy, independence and testability are incorporated to

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assure that the safety functions are performed.

8.1.3 System Safety Loads All electrical equipment required for the engineered safety features systems is supplied from the ac emergency buses, the'ac vital instrumentation and control power supplies, or from the de buses.

The safety loads are listed in Table 8.1-1 as to load type, function performed, and type of electrical power required (ac or de).

8.1.4 Design Bases of Safety Related Electrical Systems The safety-related electrical systems shall meet their functional requirements under the conditions produced by the design basis event.

8.1.5- Design criteria 8.1.5.1 Cencral Design Criteria of Appendix A to 10CFR part 50 m The design of the onsite power system conforms to the NRC Ceneral Design

( l Criteria of Appendix A ' listed below. See Section 3.1 for a discussion on design criteria.

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A SB 1 & 2 FSAR CDC-17 Electric Power Systems CDC-18 Inspection and Testing of Electric Power Systems GDC-Co 6,s 4rp.enined Away de 1 8.1.5.2 Institute of Electrical and Electronic Engineers (IEEE) Standards The electric power systems are in conformance with the following standards:

IEEE Std. 1 - 1969 " General Principals for Temperature Limits in the Rating of Electrical Equipment" IEEE Std. 96 - 1969 "Ceneral Principals for Rating Electrical Apparatus .

for Short-Time, Intermittent, or Varying Duty"

IEEE Std. 142 - 1972 " Recommended Practice for Grounding of Industrial and Commercial Power System" (IEEE Creen Book)

IEEE Std. 279 - 1971 " Criteria for Protection Systems for Nuclear Power Generating Stations"

'() IEEE Std. 288 - 1969 " Guide for Induction Motor Protection" IEEE Std. 308 - 1971 " Standard Criteria for Class IE Electric Systems for j '

Nuclear Power Generating Stations" iM%

IEEE Std. 317 - 1972 " Electric Penetration Assemblies in Containment Structures for Nuclear Power Cencrating Stations" IEEE Std. 323 - 1974 " Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations" -- Refer to Subsection 3.11.2 for discussion of this standard.

IEEE Std. 334 - 1971 " Trial-Use Guide for Type Tes ts of Continuous-Duty Class 1 Motors Installed Inside the Containment of Nuclear Power Generating Stations" i IEEE Std. 336 - 1971 " Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations" ,

IEEE Std. 338 - 1975 " Criteria for the Periodic Testing of Nuclear Power 1 l l l

Cenerat.ing Station Protection Systems" -- Refer to Subsection 7.1.2.11 for discussion of this standard.

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IEEE Std. 344 - 1975 " Guide for Seismic Qualification of Class I Electric

(,) Equipment for Nuclear Power Generating Stations" e

-- Refer to Section 3.10 for discussion of this standard.

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3.1.5 Reactor Containment 3.1.5.1 Criterion 50 - Containment Design Basis The reactor containment structure, including access openings, penetrations, c.nd the containment heat removal system shall be designed so that the containment structure and its internal compartments can accommodate, without exceeding the design leakage rate and, with sufficicat margin, '

the calculated pressure and temperature conditions resulting from any loss-of-coolant accident. This margin shall reflect consideration of (1) the effects of potential energy sources which have not been included in the determination of the peak conditions, such as energy in steam generators and energy from metal-water and other chemical reactions that may result from degraded emergency core cooling functioning, (2) the limited experience and experimental data available for defining accident phenomena and containment responses, and (3) the conservatism of the calculational model and input pa rame te rs .

i RESP 0NSE The design of the containment is based on two containment design basis tecidents. One assumes a double-ended rupture of the largest reactor coolant n pipe OOCA); the other the rupture of a main steam line inside containment.

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~ ) The maximum calculated atmospheric pressure and temperature reached within the containment during the LOCA are 46.1 psig and 2710F; the maximum o atmospheric pressure and temperature attained during a main steam line \

rupture is 34.5 psig and 3700F. A containment design pressure of 52.0 psig has been selected to provide ample margin to allow for increased energy rources. The peak liner design temperature was selected equal to the maximum calculated LOCA ataaspheric temperature, 271 F. Although the con-tainment atmospheric temperature following a MSLB is higher than that following a LOCA, the containment liner temperature will not exceed 271 F, cince a lower heat transfer coefficient will result under the superheated F.tmospheric condition during the MSLB.

Su Subsection 3.8.1 for containment loading combinations and 6.2.1 for design evaluation.

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f-' 430.3 Section 8.1.5.2 of the FSAR indicates that the Seabrook design is

( (8.1) in conformance with IEEE Standard 387-1972. Section 8.1.5.3 of the FSAR, on the other hand, implies that the Seabrook design is also in conformance with 387-1977 by reference to Regulatory Guide 1.9 (Revision 1). Similar inconsistencies exist between Sections 8.1.5.2 and 8.1.5.3 of the FSAR f or IEEE Standard 308-1971 and Regulatory Guide 1.32 (Revision 2), IEEE Standard 317-1972 and Regulatory Guide 1.63 (Revision 2), IEEE Standard 384-1974 and Regulatory Guide 1.75 (Revision 2), IEEE Standard 338-1975 and Regulatory Guide 1.118 (Revision 2), IEEE Standard 484-1975 and Regulatory Guide 1.128 (Revision 1), and IEEE Standard 450-1972 and Regulatory Guide 1.129 (Revision 1).

Correct the inconsistencies and describe and justify each exception taken to IEEE Standards 308-1974, 387-1977, 317-1976, 384-1974, 338-1977, 484-1975 and 450-1975.

RESPONSE: The basic commitments to various industry standards pertinent to the electrical design of the Seabrook project have been established at the PSAR stage. We have and plan to adhere to these commitments as shown in Section 8.1.5.2. It is pointed out that IEEE Standard 338-1975 and IEEE 379-1972 are additions to the PSAR listed standards as is the upgrading of IEEE Standard 344-1971 to 344-1975.

Over and above these commitments, it was decided at the FSAR

("') stage, to evaluate the extent of compliance to the most recent,

\m / Regulatory Guides and Branch Technical Positions at the date of issuance of the FSAR. This evaluation is reflected in Section 8.1.5.3 and 8.1.5.4 and in no way should be construed to reflect a commitment to the Regulatory Guide. We are aware that the listed Regulatory Guides often reference a later issue of an industry standard, however, Regulatory Guides such as 1.30, 1.40, 1.41, 1.53, etc., continue to reference superseded issues of industry standards in spite of the publication of revised s t a nda rd s. This unfortunate lack of coordination will always exist unless simultaneous revisions are made by industry and the NRC. It is obvious that the problem is not easily resolvable and for this reason we have established the ground rules reflected in the discussion above. The evaluation of the Seabrook design against the most recent Regulatory Guides provides an indication of how Seabrook design complies with recent NRC requirements.

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430.4 The three off-site power circuits are routed in close proximity between the transmission line terminating structures and the switchyard as indicated on Figures 8.2-7 and 8.2-8 of the FSAR.

In addition, the two of f-site circuits from the switchyard to the generator step-up transformers and the reserve auxiliary transformers are also routed in close proximity. Describe, as required by CDC 17, how the subject routings are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions.

RESPONSE: The SF6 insulated circuits connecting the 345 kV transmission lines to the 345 kV switching station, and those connecting the switching station to the generator step-up and reserve auxiliary transformers, have complete electrical isolation from each other.

Each phase conductor is located within a cylindrical aluminum enclosure which is at ground potential. The completely sealed, 1/4-inch thick, aluminum bus enclosures provide physcial and electrical protection from environmental conditions such as wind, ice, snow, and lightning which are of concern when locating a standard design (air-insulated) transmission line. Because no phase-to phase electrical faults are possible, and because the circuits are protected from environmental hazards, close physical

,-s proximity between circuits is possible.

b Structures in the vicinity of the SF6 insulated bus include a 34.5 kV, wood pole, distribution line which crosses over the bus runs connecting the line termination area to the switching station. The conductors of this line are fully insulated so that the possibility.of damage to the SF6 buses due to a fallen conductor is minimal. The distribution line, which is required for construction power, will be removed af ter completion of construction.

There are no other structures, such as lighting towers, located such that, if they fell, they could cause failure of more than one 345 kV circuit.

The low profile of the bus runs minimizes wind loadings on the support structures and conservative design of the common support structures and their foundation footings provides ascurance that the probability of a 345 kV bus support structure failing is extremely low.

Protection against vehicles on the controlled access bridges and on the roads adjacent to SF6 bus runs is provided by a guard rail along the plant access road and by guard rails on the bridges which pass over SF6 sulatad bus runs. The bridges themselves are conservatively otaigned for the largest loads required during jg construction or operation of the plant. The possibility of a

( ,j vehicle causing damage to the SF6 insulated bus runs is further minimized by the fact that roadways adjacent to the SF6 bus runs are on plant property, access is controlled, and vehicles are subject to strict plant regulated speed limits.

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O The above considerations demonstrate that GDC 17 has been met since the likelihood of simultaneous failure of the off-site power circuits has been minimized to the extent practical. Furthermore, we believe that our design, using SF6 insulated curcuits, is superior to a design using pole-mounted, air-insulated circuits.

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RAI 430.5 The voltage levels at the safety-related buses should be optimized for the full load and minimum load conditions that are expected throughout the anticipated range of voltage variations of the offsite power source by appropriate adjustment of the voltage tap settings of the intervening transformers. Submit the planned range of normal operating voltages for each safety-related bus.

RESPONSE
We are in the process of finalizing the voltage regulation study for the Seabrook Station. This study will promise the voltage analysis required by .
i BTPPSB-1 (See RAI 430.14), and will demonstrate that the voltage at the safety-related buses have been optimized for anticipated range of grid voltage variation.
The tap settings of the intervening transformers will be appropriately adjusted. This study will be submitted to the NRC by 5/1/82.
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430.6 Section 8.2.1.3 of the FSAR indicates that a common insulating gas
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s_- is used among the off-site power circuits from the transmission line interconnections through the switchyard to the generator step up and reserve auxiliary transformers. It is unclear how this common insulating gas meets the requirements of GDC 17. Provide clarification and a description as to how the irsulating gas system meets the physical separation requirements of GDC 17.
RESPONSE: The following will be added to FSAR Section 8.2.1.3.a.1, between the fourth and fifth paragraphs, to clarify compliance of gas insulated system to GDC 17. The referenced Figure 8.2-13 will be developed f rom ITE Drawing 422-851, enclosed, and will be included in the FSAR.
Each circuit breaker and each bus section of the 345 kV switching station forms a separate gas insulated system which is individually monitored as a 3-phase system. Each 3 phase circuit breaker is supplied with its own self-contained SF6 gas system.
There is no interconnection between the circuit breaker SF6 gas systems and the switching station gas systems. The bus section gas systems include the 3-phase bts connections between two circuit breakers, extending to the point of connection to a transf ormer or to an overhead line. Refer to Figure 8.2-13 fee a schematic of the switching station gas systems.
There is no ga in erconnection between the bus on one side of a
) circuit breaket a: the bus on the other side. Therefore, a gas s/ leak in any one F .as system only affects the insulation level of one bus secth The affected circuit can be electrically isolated withou affecting the availability of any other bus section.
Each of the switching station SF6 gas systems is subdivided by gas barrier insulators provided with normally open bypass valves.
These gas tight barriers (located at disconnect switches and other natural division points) permit optimum installation, maintenance, and leak detection procedures. In addition, valves and manifolds provide gas interconnections between the three phases of individual circuit sections to maximize the volume of each SF6 gas system and thus to minimize the sensitivity to small leaks.
The interconnecting valves can be closed to permit evacuation of a single phase section.
l The independence requirements of GDC 17 are satisfied by ensuring that a loss of insulating gas in one bus section or in one circuit breaker of the 345 kV switching station does not af fect the availability of other circuit paths through the switching station. Suf ficient independence exists to assure performance of the required safety function assuming a single failure.
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p FSAR RAI 430.7 CDC 17 requires in part 'that each of the offsite circuits be designed to be available in sufficient ti:n following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of
,the reactor coolant pressure boundary are not exceeded. The description in the FSAR as to compliance with this part of GDC 17 is not sufficient to reach a conclusion of acceptability. Describe design provisions for establishing an offsite circuit from the transmission system through the switchyard to the Class IE system assuming some event in the switchyard protective relaying that has tripped all 345 kV switchyard breakers.
RESPONSE
In order for all eight 345 kV breakers to be tripped, four separate faults or relay misoperations (or a combination of faults and relay or circuit breaker misoperations) would have to occur simultaneously. No single set of protective relays at Seabrook can trip all of the 345 kV circuit breakers.
If some event or series of events in the protective relaying systems for the 345 kV switching station and transmission lines resulted in all eight 345 kV breakers being tripped, re-establishment of off-site power connections to the Class lE power systems would be accomplished through the coordinated action of the station operators and the transmission system dispatchers at the Electrical System Control Center (ESCC).
Initially, a station operator would be sent to Relay Room No. I to determine which relays had operated. Step-by-step restoration of the off-site circuit connections would be performed as a coordinated effort of the station operators and the system dispatchers in accordance with a written procedure for responding to protective relay operations at Seabrook. Relays would be ,
reset in Relay Room No. I and Relay Room No. 2. Manual disconnect switch operation (if required) would be performed in the switching station. The 345 kV circuit breakers would be closed using control switches in the Unit I control room; in Relay Room No. 1, at the ESCC, or at the device in the switching station. Communications would be maintained between the station operators and the system dispatchers throughout this process.
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430.8 The control and monitoring of the off-site power ci cuits from the switchyard to the Class IE power system is shared bitween Units 1 and 2. Provide a description of compliance to GDC 5 RESPONSE: Independent status indication for 345 kV circuit breakers and motor-operated disconnect switches is provided in three locations: the Unit 1 Control Room; Relay Room No. 1; and the Unit 2 Control Room. This is accomplished by using separate power supplies for each of the three locations and by the use of separate contacts of the individual device auxiliary switches.
The degree of independence of control functions between Unit 1 and Unit 2 is described in FSAR Section 8.2.1.4.d. Though control of 345 kV circuit breakers is not provided in Unit 2, control can be transferred from the Unit No.1 Main Control Board to Relay Room No. 1 by use of transfer switches located in each control circuit in the Relay Room No. 1 panels. Thus an independent control location is provided.
The power source for 345 kV indication and control at the Unit 1 Main Control Board is Battery 1-ED-B-2A located in the Unit 1 turbine building.
-% The power sources for 345 kV indication and control circuits in g,j Relay Room No.1 are the two switching station control batteries located in Relay Room No. 1.
The power source for the 345 kV circuit breaker and motor-operated disconnect switch status on the Unit 2 Main Control Board is supplied from Battery 2-ED-B-2A located in the Unit 2 turbine building. The wiring to the device auxiliary switch contacts used to provic' status indication for Unit 2 is routed direct to the 345 kV swisching station and is not routed through Unit 1 or Relay Room No. 1. Control power for motor-operated disconnect switch T-1006 is alno supplied by Battery 2-ED-B-2A.
Voltage indic ation for 345 kV Bus 1 and Bus 2 is provided on the Unit 1 Main Cintrol Board and on the Unit 2 Main Control Board.
The voltage starces for these indications are derived from separate secondary windings of the bus capacitive coupled voltage trans f ormers. iue circuits to Unit 2 are routed directly from the 345 kV switching station and not via Unit 1 or Relay Roem No. 1.
Compliance with CDC 5 is demonstrated by the above described design which provides assurance that the degree of independence between the control and monitoring circuits of Unit 1 and Unit 2 is such that events in one unit will not interfere with the ability of operators in the other unit to control and monitor the 1 status and availability of the off-site power system.
l Furthe rmore , those functions that are shared will not
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! and cooldown of the other unit.

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SB 1 & 2 FSAR O
RAI 430.9 The capability to test the transfer of power from one immediate access !
offsite circuit to the other circuit from the reserve auxiliary transformer I has not been specifically addressed in the FSAR. Describe how this transfer can be tested during plant normal operation and its compliance with GDC 18.
RESPONSE
The various automatic and manual transfer schemes to each bus from one source to the other, are detailed in Subsection 8.3.1.1.b.3. The transfer schemes as described can be tested during plant normal operation.
The requirements of GDC 187 are met, because the electric power systems are l designed with the capability to test the transfer of power between the nuclear power unit; the offsite power system, and the ensite power system.
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RAI 430.10 Figures 8.2-6 and 8.3-36 show cables associated with both preferred offsite circuit and both onsite power sources being routed through the Rod Control Room of the Control Building. Describe design provision being implemented to preclude a design basis event such as a fire from causing loss of all onsite and offsite *. .its.
RESPONSE
Figure 8.2-6 has been revised to more accurately depict the routing of the onsite and offsite power source non-segregated phase bus ducts. As shown in Figure 8.2-6, the non-segregated phase bus ducts for the two onsite power sources are in two separate fire areas with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated firewall between them. In addition, the non-segregated phase bus duct for the offsite sources for only one train passes through the rod contial area.
Figure 8.3-36 shows the separation between Train A and Train B cable trays, and does not show routing of onsite and offsite power source non-segregated buses.
Specific concerns pertaining to 10 CFR 50 Appendix R are presently under study and will be submitted separately.
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430.11 Section 5.6 2.2(1) of IEEE Standard 387-77 (endorsed by Regulatory Cuide 1.9, Revision 2) requires that a start-diesel signal shall O- override all other operating modes and return the control of the diesel-generator unit to the automatic control system. Sec tion 8.3.1.1.e.6 of the FSAR indicates that during load testing the diesel-generator breaker automatically trips upon receipt of an SI signal and the diesel generator continues to run. Based on the FSAR, it appears that control of the diesel generator is not returned to the automatic control system as required by IEEE ;
Standard 387-1977. Justify the apparent non-compliance.
RESPONSE: The control of the diesel generator does return to the automatic control system under the conditions described above. Appropriate sections of 8.3.1.1.e.6 have been revised accordingly.
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upon whether an accident condition (SI) is also present, the EPS provides appropriate contact outputs to the various safety related loads to start them in a programmed time sequence.
Momentary signals are provided to circuit breakers and starters of loads which are required to start at a specific time (" definite start loads" see Tables 8.3-1 and 8.3-2, Sheet 1 of 2); maintained permissive contacts are provided for loads whose starting is also dependent upon the presence of a process signal ("indef-inite start loads," see Tables 8.3-1 and 8.3-2, Sheet 2 of 2).
Indicating lights for the sequencing steps are provided on the main control board to assist operation. Loading is started when the diesel generator reaches rated speed and voltage and the generator circuit breaker closes (approximately 10 seconds after the diesel start signal).
Table 8.3-1 shows the order and time at which the loads are automatically and sequentially applied to the diesel generator during a combined loss of offsite power and accident condition.
Table 8.3-2 shows the order and time at wn~ ich the loads are automatically and sequentially applied to the diesel generator
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During the diesel generator loading process, 4160 and 480 volt emergency bus undervoltage tripping circuits are disabled (
to prevent inadvertent tripping due to momentary voltage dips caused by application of large motor loads. If for any reason the diesel generator breaker trips open during or subsequent to the loading process, undervoltage tripping is restored and the bus is cleared, as in the original loss of of fsite power. Upon reclosing of the diesel generator breaker, the loading process is re-initiated and proceeds as before.
-D In the event of a safety injection signal, the diesel gener-ators are automatically started and operated at idle. Should the of fsite power supply subsequently fail, the diesel gener-l ntors are automatically connected to the emergency buses and l the loading sequence as described in Table 8.3-1 is initiated.
Upon receipt of a safety injection signal during load testing, the diesel generator breaker is automatically tripped, and the diesel generator continues to run. Should this be accom-panied by a loss of offsite power, relays sense the loss of voltage on the emergency bus and respond by initiating the loading sequence described in Table 8.3-1.
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430.12 Provide the Emergency Power Sequencer logic diagram in the FSAR
( and provide the results of an analysis to demonstrate:
(1) that there are no credible sneak circuits or common failure modes in the sequencer design that could render both the on-site and off-site power sources unavailable and I (2) that the reliability of on-site and of f-site power sources has not been compromised.
RESPONSE: The Emergency Power Sequencer (EPS) logic diagram is included in Ammendment 44 to the Seabrook FSAR.
Through the development of reliability requirements, the utilization of high reliability design concepts and an extensive test and qualification program, the EPS has achieved a high level of reliability. The high level of reliability minimizes effects of common mode failures.
EPS malfunction may be attributed to electric component failure and/or system logic malfunction. Electric component reliability has been addressed by the EPS manufacturer in his Reliability Program Report. The report contains the reliability analysis for the EPS system in both the Loss of Power (LOP) and LOP with Engineered Safety Feature (ESF) actuation modes, performed in accordance with IEEE Standard 352-1975. The estimated availability and Mean Time Between Failures (MTBF) is given for f-')s 4 the EPS operating as a single unit, and as a duplicate redundant system, as will be used in the Seabrook Station.
Since the EPS has been qualified to perform it's intended function in the specified environment over it's entire lifetime, an electric component f ailure is not considered a common mode failure. Therefore, a component failure causes a failure of one EPS unit, and the duplicate redundant unit completes the intended function.
EPS logic malfunctions may be caused by electric component failure and/or poor logic design. Component failure has already been discussed. Poor logic design results in L' desirable output when unexpected combinations of input signals are received. These inputs can be combinations of ESF actuation and LOP signals as reported in various LER's by other operating plants, or they can be caused by the malfunction of the input source devices such as voltage relays or breaker auxiliary contacts.
The EPS logic has been designed and tested to properly respond to any combination of input signals. Some of the cases are described in the FSAR. Input combinations along with the appropriate EPS response are listed and verified in the System Test Procedure prepared by the manufacturer and in addition, preoperational tests will further verify proper operation. Analysis of the logic
/% diagram has also been used to confirm the proper operat'on of the
(_) EPS for various input combinations.
i.
i-i l In conclusion, the effects of sneak circuits and common mode failures have been minimized by good design concepts and complete l
test and qualification programs and therefore, the reliability of i the on-site and off-site power sources is not compromised by the .l EPS. !
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RAI 430.13 Section 8.3.1.1.e.5 of the FSAR it dicates that a type qualification testing program meeting the requirements of IEEE 387-1977 was performed on one diesel generator unit. Provide,'the type qualification testing program test report with results.
RESPONSE
One diesel generator unit successfully completed a type qualification testing program, meeting the requirements of IEEE 387-1977. Also, see FSAR Subsection 8.3.1.1.e.5. Copies of the complete testing program with results-are available for inspection, if required. The test results are summarized below:
Load capability qualification was demonstrated by; performing the following tests:
1. No Load Test Acceptance Criteria: The diesel generator unit must be operated for 6 hvars at " ready to accept load" status, then operated for a
-s g period of I hour at 100% load with no abnormalities encounted.
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Conclusion:
Performance of the diesel generator unit met the acceptance criteria.
2. 100% Load Test
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Acceptance Criteri1: The unit must' operate at 100% load (8414 bhp
- 6083 kW) at agatlibrium temperatures without exceeding 1800F jacket water temperature out of the engina and 1450F lube oil to s
the engine.
Conclusion:
Seven hourly percent load readings were noted that were below the 100% load rating. The worst being 98.9% or 6066 kW which was 17 kW below rated load. Despite this discrepancy, it is felt that the performance of the diesel generator has met the intent of the acceptance criteria.
3. 110% Load Test Acceptance Criteria: Immediately following the 100% load test, the unit must operate at 110% load (9264 bhp - 6697 kW) for a
. period of two hvers without exceeding 1800F jacket water temperature out of the engine and 1450F lube oil to the engine.
Conclusion:
Performance of the diesel generator met the
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4. 100% Load Rejection Test Acceptance criteria: The unit, when operating at 100% load (8414 bhp - 6083 kW) must remove the load instantaneously in one step without exceeding 560 rpm.
Conclusion:
The diesel generator met the acceptance criteria.
Start and load acceptance qualification was demonstrated by performini the following test:
1. 300 Start and Load Acceptance Qualification Test Acceptance Criteria: A total of 300 valid start and loading tests shall be performed with no more than 3 failures allowed. If the 300. tests are spread over more than one unit, each unit shall be started and loaded at least 100 times. Failure of the unit or units to successfully complete this series of tests, as prescribed will require a review of the system design adequacy, the cause of the failures to be corrected, and the tests continued until 300 valid tests are achieved without exceeding the 3 failures allowed.
Conclusion:
The diesel generator unit successfully passed the 300 start and load acceptance qualification test.
Margin qualification was demonstrated in conjunction with the load acceptance tests.
Acceptance Criteria: Start the diesel generator and apply an initial load 10% greater than the initial design load and than when the diesel is at approximately 75% of its rated load apply an additional load 10% greater than the worst design step load.
While:
a. The voltage shall not drop to less than 80% of normal and ,
frequency not less than 95% of normal. !
b. The time to recover from 80% rated volts to 90% rated volts and from 95% frequency to 98% frequency after.each load step shall not be more than 3 seconds.
Conclusion:
The diesel generator successfully met the stated criteria during the load test.
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430.14 Describe how the Seabrook design meets Branch Technical Position PSB-1, Adequacy of Station Electric Distribution System Voltages.
l RESPONSE: The following discussion describes how the design of Seabrook Station meets the requirements of Branch Technical Position PSB-1. The item numbers correspond to the positions of the Branch Technical Position.
(1) A second level undervoltage protection system is provided.
This system is described in FSAR Section 8.3.1.1.b.4.b and in the response to RAI 430.15. i l
(2) The Seabrook Station design meets Position 2 of Branch ,
Technical Position PSB-1. The bypass of the load shedding l feature during sequencing, and its restoration in the event j of a subsequent diesel generator breaker trip is discussed in l
FS AR Section 8.3.1.1.e. 6. In addition, the load shed feature is reinstated after load sequencer action when the operator resets the sequencer override pushbutton. This action l permits the operator to re-assume control of diesel-generator loading.
The Technical Specifications will include a test requirement
! to demonstrate the operability of the automatic bypass and
("'s reinstatement features at least once per 18 months during
! (s-) shutdown.
The load shed circuitry will be modified to include the capability to monitor the status of che bypass circuitry.
(3) The design'of Seabrook Station meets the requirements of Position 3. The response to RAI 430.5 contains the complete analysis required by Position 3.
(4) The analytical techniques and assumptions used in the voltage analysis cited in Item 3 above will be verified by actual measurement as part of the pre-operational test program. The guidelines of Position 4 of Branch Technical Position PSB-1
. will be followed and good correlation between the analytical results and the test results will be demonstrated.
Seabrook Station's commitment to perform this testing is also described in FSAR Section 14.2.6. This section describes Seabrook Station's interpretation of Appendix A, Section 1.g of Regulatory Guide 1.68.
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- 430.15 Section 8.3.1.1.b.4.b of the FSAR indicates that activation of the i second level of undervoltage protection generates only an alarm l when there is no accident signal and generates an off-site power !
source trip signal when there is an accident signal. Based on !
this information, it appears that the design does not meet
, Position 1 of Branch Technical Position PSB-1. Justify ,
non-compliance. !
RESPONSE: We are providing an acceptable alternative to the applicable portions of PSB-1. This alternative design was reviewed and !
approved by PSB Branch Chief and is documented in our letter !
WYR-80-83 to the USNRC. A copy of the above letter is* attached as [
Attachment 430.15. L i
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,. Telep hone 617 366 90H twx s,o no ms YANKEE ATOMIC ELECTRIC COMPANY s.3.2.1
- - --,., WYR 80-83 h 20 Turnpoke Road Westborough. Mossochusetts 01581 YAuxts July 24, 1980 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Office of Nuclear Reactor Regulation Mr. T. A. Ippolito, Chie f Operating Reactors Branch f3 Division of Operating Aeactors !
Re ference s : 1. License No. DPR-3 (Docket No. 50-29)
2. License No DPR-28 (Docket No. 50-271)
License No. DPR-36 (Docket No. 50-309)
O 3.
4.
5.
Docket No. 50-443 and 50-444 USNRC Letter, dated 8/12/76 (typical)
6. USNRC Letter, dated 6/3/77 (typical)
7. USNRC Letter, dated 10/16/79
8. VYNPC Letter No. WY-76-114, dated 9/16/76 (typical)
9. VYNPC Letter No. WY-77-65, dated 7/18/77 (typical)
10. VYNPC Letter No. WY-79-139, dated 12/6/79
Subject:
Mitigating the Effects of Crid Degradation on Safety Related Electrical Equipment
Dear Sir:
This lecter is being written by Yankee Atomic Electric Company on behalf of the Yankee Rowe, Vermont Yankee, Maine Yankee, and Seabrook nuclear stations. These facilities have been identified as References (1, 2, 3 and 4).
BACKGROUND INFORMATION Yhe NRC position on degraded grid voltage (Reference 5, 6 and 7) requires automatic disconnection of the supply from the grid (offsite power supply) to the plant emergency buses sny time the voltage drops below a pre-determined limit. The NRC is concerned thr.t a sustained variation outside the safety related equipment's design ratad limit could result in a lors of capability if the equipment were simultaneously required to perform its safety function.
l Yankee Atomic has steadfastly opposed the NRC's position on degraded grid voltage because we believe that any changes made in equipment or circuitry I
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United States Nuclear Regulatory Commission July 24, 1980
, Attention: Mr. T. A. Ippolito Page 2 i
. i should increase rather than decrease the level of overall nuclear plant safety; it is our opinion that in attempting to resolve one safety concern additional safety concerns should nor be introduced in the process.
Yankee Atomic has proposed an* alternative position (References 8,;9 & 10) [
which relies on operator action in lieu of an automatic trip to resolve the l NRC's basic concerns on degraded grid voltage. On receipt of our letter dated
, 12/6/79 (Reference 10), the NRC requested a meeting to discuss Yankee Atomic's generic position on grid undervoltage. The meeting was held at the NRC offices on May 5,1980.
At the above meeting. Yankee Atomic engineers acknowledged that the NRC's concerns for continued operation of safety related equipment under degraded voltage conditions were valid, but, stated that they could not ignore the fact '
that additional safety concerns were being introduced by the NRC position.
These safety concerns were categorized into three areas:
a. Violations of CDC-17, ;
b. Disintegration of the entire grid,
c. Being lef t with a less reliable source of power or no source nf power. ,
l s It was pointed out that the Yankee Atomic position (References 8, 9 & 10) relied on the station operator to assess the situation relating to grid degradation and to take appropriate action to ensure that degradation was being corrected. Failing this he would take additional steps to protect safety-related equipment from the influence of degraded grid voltage. The operator action would ensure that a further deterioration of safety would not result from any action directed at correcting the degradation. ;
At the meeting, the NRC stated that they had an ongoing concern with operator action; they did not have confidence in operator action and for that reason were opposed to placing any reliance on it.
As one alternative (henceforth known as Alternative 1), the NRC suggested that we consider interlocking the automatic trip with an accident signal. An automatic trip of the of fsite power supply would then result only if a simultaneous grid degradation and an accident occurred.
Another alternative (henceforth known as Alternative 2), suggested by the NRC for our consideration subsequent to the meeting, was that we interlock the automatic trip with a signal indicating that the main generator was off-line.
An automatic trip of the of fsite power supply would then result only if grid degradation occurred when the generator was not synchronized to the grid.
Both the above alternatives assumed that manual operator action would be utilized in modes when the automatic trip was not applicable.
f-s DISCUSSION:
D We have considered the two NRC suggestions and have analyzed the merits of each scheme. These alternatives have then been compared with both the original NRC position (Reserence 5, 6 & 7) and the Yankee Atomic position (References 8, 9 & 10) on degraded grid voltage.
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l United States Nuclear Regulatory Commission July 24, 1980 l O Attention: Mr. T. A. Ippolito Page 3 Alternative 1 This alternative 6equires that the offsite power circuit breaker be l automatically tripped if a simultaneous grid degradation and accident occurred. ;
Tke circuit breaker connecting of fsite power to the emergency bus is shown in Figure 1. The first level undervoltage relay is shown as device 27A. The second level undervoltage relay is shown as device 27B. Both relays sense i voltage on the emergency bus.
When voltage is degraded below that required to ensure the continued operation of safety-related equipment, the second level voltage relay 27B will be activated. Contacts of relay 27B will close in the breaker trip circuit as well as in the alarm circuit. The breaker will trip automatically if an ,
accident signal is also received.
If bus voltage is severely degraded or lost altogether, the first level f voltage relay 27A will also be activated. Contacts of relay 27A in the i breaker trip circuit will cause an instantaneous trip of the circuit breaker. i With Alternative 1, a grid degradation experienced without an accident signal will only cause an alarm. Established plant procedures require the operator O to take specific steps to assess the magnitude and expected duration of the grid degradation. If he is not assured that the disturbance is transitory, and that recovery is imminent, he may choose to manually trip the offsite power circuit breakers af ter ensuring that a further deterioration of safety will not result from his proposed action.
Advantages
1. Violations of CDC 17 are precluded.
2. An accident signal would itself cause a trip of the main generator; therefore, any resulting collapse or disintegration of the grid could not be attributed to this circuit modification.
3. The reliance on operator action in the event of a simultaneous accident and degraded grid condition is avoided.
4. Operator action would be maintained for all non-accident conditions, '
thus precluding our concerns expressed in References (8, 9 and 10).
i Disadvantages i l
1. If the reactor is at power and all onsite ac power is determined to be unavailable, (i.e. all diesel generators lost) the reactor will be brought to a cold shutdown condition in accordance with technical specification requirements. If, during this mode, an accident
()
signal and a grid degradation were to occur, the offsite power l supply breaker would trip leaving the plant with a total loss of all onsite and of fsite ac power.
United States Nuclear Regulatory Conunission July 24, 1980 Page 4 Attention: Mr. T. A. Ippolito This scenario is being identified in spite of its extremely low probability because firstly, the basis for the NRC position on grid L degradation is to design for a simultaneous accident and grid degradation, and secondly, loss of all onsite ac power has occurred at a number of facilities. The combined probability, however,
. remaining extremely low. .
Alternative 2 This alterrative requires that the offsite power circuit breaker be tripped automatically if a grid degradation occurs when the generator is not connected to the grid.
The circuit breaker connecting offsite power to the emergency bus is shown in Figure 2. The first level undervoltage relay is shown as device 27A. The second level undervoltage relay is shown as device 278. Both relays sense voltage on the emergency bus.
When voltage is degraded below that required to ensure the continued operation of safety-related equipment, the second level voltage relay 27B will be activated. Contacts of relay 27B will close in the breaker trip circuit as l
well as in the alarm circuit. The circuit breaker will trip automatically if l it is determined by a logic circuit that the generator is not connected to the [
grid.
l If bus voltage is severely degraded or lost altogether, relay 27A will also be
. activated. Contacts of relay 27A in the breaker trip circuit will cause an instantaneous trip of the circuit breaker.
With Alternative 2, a grid degradation experienced with the generator connected to the grid will only cause an alarm. Established plant procedures '
require the operator to take specific steps to assess the magnitude and expected duration of the grid degradation. If he is not assured that the disturbance is transitory, and that recovery is imminent, he may choose to manually trip the offsite power circuit breakers after ensuring that a further ,
deterioration of safety will not result from his proposed action.
f Advantages
1. Violations of GDC-17 are precluded.
2. Disintegration of the entire grid is precluded.
l
3. This alternative prevents the second level undervoltage relay from automatically tripping the of fsite power circuit breaker during plant operation. Our concerns expressed in References (8, 9 and 10) relating to a plant trip are thereby removed.
Disadvantages A
' If the reactor is at power and all onsite ac power is determined to be
! unavailable (i.e. all diesel generators lost), the reactor will be brought to a cold shutdown condition in accordance with technical specification requirements. Once the generator is disconnected from the grid, this circuit l
United States Nuclear Regulatory Commission July 24, 1980 Page 5
. Attention: Mr. T. A. Ippolito will cause the circuit breaker to trip if a grid degradation also occurs; the plant will now face a total loss of all onsite and offsite ac power. This situation is extremely undesirable because of the unpredictable consequences of this transient.
1 CONCLUSI ON We, have carefully analyzed four possible methods of mitigating the effects of stid degradation on safety related equipment. These methods were:
(a) NRC Position (b) Yankee Atomic Position (c) Alternative 1 (d) Alternative 2 Of these four methods, we believe Alternative 1 is the most desirable scheme for our facilities. Additionally, the low probability disadvantages of Alternative 1 are outweighed by the advantages. We, therefore, propose to adopt Alternative 1 for mitigating the effects of a grid degradation. The sensors, and circuit to be utilized will be as detailed in Figure 1, and as described in the text above.
PROPOSED ACTION AND SCHEDULE We are assuming your continued endorsement of Alternative 1, and will
() therefore immediately commence engineering changes to incorporate this modification for our Yankee Rowe, Vermont Yankee, and Maine Yankee facilities. It is anticipated that engineering for these changes will be completed by November 1980. Installation will follow at the first opportune shutdown following completion of engineering and receipt of materials.
Similar changes will be made op our Seabrook facility and will be documented in the FSAR and installed prior to commencement of fuel loading.
Should you have any comments on this proposed course of action and schedule, please notify us by August 15, 1980.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY
% ~' '
D. E. Vandenburgh Senior Vice President 1
1 1
O FIGURE i TD OFFSITE MEE DNDERVOLTAGE SENSOES 27A OFFSITE POWER GEC0tT ) . n PT'S BREAKER
,, EMEEGENCY BUS , , . .
i ONE UNE. REPRESENTATION
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27A-l ; d ; d 27B-l 278-2
r TO ALARtA
.. ACCIDENT SIGNAL 7 l
l BREAKER TRIP COLL SCHEMATIC. REPRESENTATION OF OFFSITE.
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POWER. CIRCutT BREAKER TRIP CIRCulT
I FIGURE 2 TO OFF5ITE POWEE UNDERVOLTAGE.
SENSORS OFFSITE O27A27B NR GEIT ) >x , PT'S E>REMER
. . EMERGENCY Bus ,,
ONE LINE REPRESENTATON
+ , ,,
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27A-1 ;f ;;f 27B-l TO 27B-2;d ggg id 1.06lC INDICATING 3 GENERAToe IS DISCONNECTED FRON\ GRID TL BREAKER. TRIP COIL j l
O sc.nEm Tic. aErnese.sT& Tion or oessire.
POWER. ClitCUlT BRE AKER. TRIP CI RCU lT t
SB 1 & 2 ELECTRICAL POWER SYSTEMS SURWILLANCE REQUIREMENTS (Continued) a) Verifying de-energization of the emergency buses and load shedding from the emergency buses.
b) Verifying the diesel starts from ambient condition on the auto-start signal, energizes the emergency buses and the permanently connected loads, energizes the auto-connected emergency loads through the emergency power sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After loading, the voltage and frequency of the emergency buses shall be maintained at 4160 volts +2%
and 60 Hz +2% during the test, c) Verifying that all automatic diesel generator trips except engine overspeed, low lube oil pressure, 4160 volts bus fault and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection actuation signal.
d) Verifying that the permanently connected and auto-connected loads to each diesel generator do not exceed the short time rating of 6697 kW.
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2. Verifying that the diesel generator operates for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the test, tne diesel generator shall be loaded at 6697 kW, the short time rating, and during the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of this test, the diesel generator shall be loaded to greater than or equal to 6083 kW, the continuous rating. The test should also verify that the cooling system functions within design limits.
3. Verifying the capability to reject a load of greater than or equal to the largest single load, (later) kW, while maintaining voltage within 4160 volts + 10%, - 2% and without exceeding 75% of the difference between nominal speed and the overspeed trip setpoint.
4. Verifying the diesel generator capability to reject full load without reaching the overspeed trip setpoint.
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f-~s 430.16 Section 8.3.1.1.e.1 of the FSAR states that the capacity of the
(,,) diesel generator is adequate to support operation of engineered safety feature loads within the short-time rating and is determined on the basis that the sum of the conservatively estimated loads needed to be powered at any one time is equal to or less than the short-time rating. The above statement appears to be inconsistent with Positions 1 and 2 of Regulatory Guide 1.9 in that the conservatively estimated loads should not exceed the continuous rating. Provide clarification. Define each mode of plant operation when the diesel generator will be required to supply loads in excess of it's continuous rating, the length of time the load will be required, the degree of loading in excess of the continuous rating, and the methods or procedures to be used to assure disconnection of excess load prior to exceeding the two hour rating.
RESPONSE: Section 8.3.1.1.e.1 of the FSAR will be revised to state that "the capacity of the diesel generator is adequare to support operation of engineered safety feature loads within the short-time rating and is determined on the basis that the sum of the predicted loads needed to be powered at any one time does not exceed the short-time rating".
FSAR Tables 8.3-1 and 8.3-2 indicate that the diesel generator loading does not exceed the continuous rating under any mode of plant operation.
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i SB 1 & 2 FSAR ;
O RAI 430.17 i Section 8.3.1.1.i of the FSAR indicates that Class IE motors are sized for continuous running load at 90 percent of rated motor voltage, and are capable of starting and accelerating their rated load with 80 percent voltage at the motor terminals. ,
A. The output voltage of the diesel generator can drop to 75 percent as permitted by position 4 of regulatory guide 1.9 (Revision 2). ,
i Provide justification that demonstrates the capability of motors to perform their safety function at this 75 percent voltage level.
B. Provide the results of the station voltage study that demonstrates i that voltage levels at the equipment terminals will not drop below j 90 percent of the equipment's rated voltage for any mode of plant '
operation including operation when the offsite power grid system !
is at the minimum permissible voltage level.
RESPONSE: '
A. Although Regulatory Guide 1.9 permits the diesel generator output voltage to drop to 75 percent, the specification for the Seabrook diesel generators limits the output voltage to a minimum of 80 ,
s percent. This capability has been demonstrated by factory load tests of the machines, i
B. Refer to the response to RAI 430.5.
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f SB 1 & 2 FSAR RAI 430.18 (8.3-1) l Diesel generator alarms in the control room: A review of malfuction reports !
of diesel generators at operating nuclear plants has uncovered that in some i cases the information available to the control room operator to indicate the ;
operational status of the diesel generator may be imprecise and could lead ,
to misinterpretation. This can be caused by the sharing of a single annun-ciator station to alarm conditions that render a diesel generator unable to respond to an automatic emergency start signal and to also alarm abnormal, 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 automatic emergency start signal) when in fact, it is inoperable for that purpose.
Review and evaluate the alarm and control circuitry for the diesel generators I at your facility to datermine how each condition that renders a diesel generator ,
unable to tenoond to an automatic emergency start signal is alarmed in the control r oom, These conditions include not only the trips that lock out the diesel generator start and require manual reset, but also control switch or mode switch positions that block automatic start, loss of control voltage, insufficient starting air pressure or battery voltage, etc. This review should consider all aspects of possible diesel generator operational conditions, for example, test conditions and operation from local control stations. One Os area of particular concern is the unreset condition following a manual stop at the local station which terminates a diesel generator test and prior to resetting the diesel generator controls for enabling subsequent automatic operation.
Provide the results of your svaluation, and a tabulation of the following I information:
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 room that is
. alarmed for each of the conditions identified in (a);
c) any other alarm signals not included in (a) above that also cause the same annunciator to alarm; d) any condition that renders the diesel generator incapable of responding to an automatic emergency start signal which is not alarmed in the control room; and e) any proposed modification resulting from this evaluation.
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SB 1 & 2 FSAR
RESPONSE
Conditions that can render the diesel. generator unable to respond to an emergency start signal have been evaluated. These conditions and the resulting alarm messages presented to the control room operator have been sunusarized in Table 430.18-1. The indicated conditions and alarm messages apply to both diesel generators A and B. Note that the alarms given for Train A diesel are typical of Train B.
Other conditions that can make emergency power unavailable, but do not necessarily render the diesel generator unable to respond to an automatic start signal, are presented in Table 430.18-2.
The following proposed modification is recommended as a result of the evaluation:
Change engine overspeed alarm to "DG-A overspeed device - (NORMAL, TRIPPED)"
and interlock with " Diesel Operational" computer point and " Diesel Ready for auto start" monitoring light to indicate diesel is not ready to respond to auto start signal until mechanical overspeed switch is reset.
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TABLE 430.18-1 (Sheet I of 2)
ColWITIONS TRAT CAN RENDER DIESEL CENERATOR INCAPABLE OF BESPOEDIEC 'IO AN AITTOBnTIC ENERCENCY START SICNAL ernGIFIC-AtAiGi CG. M diAin CWDITION N CET ON CRT MNtITORIBC LIGHTS Barring device engaged DC-A barring device DC-A Operational - NO A-Diesel Ready for Auto engaged - YES TRE A Emerg Power, Start - 0FF
- INOP D-C differential protection DC-A Primary Prot - L/0 DC-A Operational - 30 A-Diesel Ready for Auto TEN A Emerg Power Start - 0FF
- INOP Mode selector switch in DC-A Cont. Select Switch DC-A Closa Ckt - INUF A-Diesel Eeady for Auto maintenance position in - MAINr. DC-A Operational - ND Start - 0FF S TEN A Emerg Power g.-
- INOP. A-Diesel Maintenance-ON >>
w D-C control panel power lost DC-A Control Power - LOSS DC-A Operational - 30 A-Diesel Ready for Auto Start - OFF Engine shutdown due to high DG-A lube oil temp. - HICH lube oil towperature (Note 1)
Engine shutdown due to high DC-A jacket 1seter temp.
Jacket coolant tempera- - NICH ture (Note 1)
No starting air pressure DC-A starting air pressure TEN-A Emerg power A-Diesel Ready for Auto
- LOW - IMOF Start - 0FF
O O O TABLE 430.18-1 (sheet 2 of 2) i SPECIFIC AI.Atti 0(30005 ALAst CONDITICH Gt CRT ON CET MonITottuc LIGHTS Engine shutdown due to low DG-A lube oli press - 105 -- -
lube oil pressure (2/3 (Note 2) logic)
Engine si:,tdown due to DG-A engine speed - MICR -
overspeed 1
Engine fail to start DG-A engine start - FAIL -- - l NOTES:
D D
(1) Diesel generator is operational under accident (safety injection) conditions; interlocks bypassed. 2 .-
Ee I (2) Alaria received prior to start of auxiliary oil pump and e.ngine shutdown. u l
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OTHER 00lEITIONS THAT MAKE EMEEGENCY POWER UNAVAILABLE 2
-o SPECIFIC ALARN 0000E05 AIJutM h COIGITIGE W CNPUTER Ott_OCDEPUTER DG breaker control power lost DG-A Close ekt - INOP .
j TFJI-A emerg. power - INOP I
i' Bus fault protection bus E5 - FAULT TRN-A emerg. power - IMOP TRN A einerg power - INOP DG breaker control switch -
DC-A close ekt - INOP in " Full to Lock" position EPS LOP / clock fault - TES TEN-A emerg. power - INOP EPS loss of power (Note 2)
DC-A close ekt - INOP M Mode selector switch in DC-A cont. select. switch local position in - LOCAL TEN A Emers. Power - IMOP h[ n DC back-up protection DG a backup prot. L/O DG-A close ekt. - INOP TEN A emerg. power - IMOP (Note 1) 4.16 kV BUS E5 - A-field DG-A Backsp prot. - L/0 DG loss of field (Note 1) DG-A close ekt. - IMOP
- LOST (Note 2)
TRN A emers, power - IMOP DG breaker in test position - DC-A close ekt. - INOP TRN A emerg, power IMOP .
MOTES:
(1) Diesel generator is operational under accident (safety injection) conditions, interlocks bypassed.
(2) Existing wording; under review for clarity
I SB 1 & 2 FSAR O
RAI 430.19 Section 8.1.5.3 of the FSAR indicates that the design of the electric power system is in accordance with regulatory guide 1.9, revision 1, except for position C5. The frequency will not recover to 60 -1.2 Hz within 60 percent of the load sequence interval in accordance with the regulatory position.
Revision 2 of the regulatory guide, however, permits a greater percentage of the load sequence interval for recovery, if it can be justified by analysis.
In addition, sufficient margin must be included in the allowable percentage of the load sequence interval for recovery to account for the accuracy and repeatability of the load sequence timer.
State the new recovery percentage, provide the results of the analysis that justifies the new recovery percentage and document the accuracy and repeatability of the load sequence timer by test results or by other methods to justify that there is sufficient margin.
RESPONSE
Section 8.1.5.3 will be modified to remove the clarification to position C.5 of Regulatory Guide 1.9. Theoretically, total frequency recovery cannot be accomplished until load acceleration is completed. The Seabrook design contains several centrifugal fans which have acceleration times which exceed 100 percent of the sequence time interval; therefore, frequency recovery to nominal frequency theoretically may not occur within the sequence time interval. These motors however, are relatively small compared to diesel-generator ratings; and therefore, do not create a significant frequency dip.
Load acceptance tests performed on the Seabrook diesel geaerators at the factory have demonstrated that the Seabrook; diesel gene'rators meet the requirements of Position C.5 of Regulatory Guide 1.9. During the factory
- load acceptance test the frequency recovered to less than two percent of nominal within sixty percent of the load sequence tide interval.
A computer analysis has also been performed to simulate the worst loading condition. Analysis results indicate that the diesel generator wil meet the recovery limit of Regulatory Guide 1.9.
The capabiliti to meet the requirements of Position C.5 will also be verified during the pre-operational test program, when load acceptance testing required by Regulatory Guide 1.108 is performed.
O
t SB 1 & 2 FSAR RAI 430.20 A number of indefinite start loads that are dependant upon the presence of a ;
process signal to start have been identified on Tables 8.3-1 and 8.3-2 of '
the FSAR.
Describe design provisions that assures that these indefinite loads will only start at 12, 17, 52 or 120 second time during the sequencing of loads as !
implied by Tables 8.3-1 and 8.3-2 of the FSAR or describe how capacity and capability of the diesel generator will be demonstrated if loads start at any time based upon process parameters.
RESPONSE
The indefinite start loads assigned to the first load step at the 12 second time sequence point are not interlocked with a sequence timer contact and may, therefore, be loaded on the diesel generator at any time. By assigning these loads to the first load step in Tables 8.3-1 and 8.3-2, they are '
assumed to start at that time or at anytime thereafter throughout the !
j loading sequence. This first step is the most heavily loaded step and, i therefore, is the limiting step. If these loads start randomly at any other time, other than at the first step, they will have less impact on the diesel generator loading capability. Indefinite start loads assigned to
() steps at the 17, 52 and 120 second intervals are interlocked with sequencer tratng contacts to prevent these loads from starting prior to their assigned s6quence point. As in the first step, these loads may start at any time after their assigned step.
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l 430.21 In FSAR Section 8.3.1.1.e.4 you state that an additional
/~N protective relay has been provided to trip the diesel generator
\m- circuit breaker on a 4.16 kV bus fault. Describe the relay and state whether its application conforms to the recommendation of Position C.7 of Regulatory Guide 1.9, Revision 2 (formerly part of Branch Technical Position ICSB 17), in respect to coincident trip I logic, since the trip is not bypassed during accident condition, j In case of nonconformance, provide justification.
RESPONSE: A Ceneral Electric type IAC induction disc time overcurrent relay is applied to detect the diesel generator's contribution to a 4.16 kV bus fault. The relay is set to coordinate with the 4.16 kV l
incoming line breaker and feeder breaker overcurrent relays such that the relay only responds to a fault on the 4.16 kV bus.
The application of the 4.16 kV bus fault relay is outside the scope of IEEE 387 and Regulatory Guide 1.9; thus, the requirement for coincident trip logic does not apply. Furthermore, the relay does not trip the diesel generator but only trips the diesel generator circuit breaker. The diesel generator continues to run and can be reconnected manually to the bus if no feult exists.
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SB 1 & 2 ,
FSAR i
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Identify the loads that are Non Class IE on Tables 8.3-1 and 8.3-2 of the l FSAR. l l
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RESPONSE
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Tables 8'.3-1 and 8.3-2 have been revised to identify the non-Class 1E loads J
with asterisks.
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SB 1 & 2 FSAR O V RAI 430.23 The single line diagrams for buses E5 and E6 indicate that there are two 600 i hp service water pumps and two 700 hp component cooling water pumps on each of the buses. Tables 8.3-1 and 8.3-2 indicate that only one of the two is in
'the diesel generator starting load sequence. Provide clarification and the electrical schematic diagrams for the service and component cooling water , ! Pumps.
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RESPONSE
l In both the service water and the component cooling water systems, the ! Seabrook design incorporates two 100% capacity pumps on each diesel-generator bus. In each case, a single pump provides full flow requirements for its associated loop. Upon loss of offsite power, the pump control circuitry permits only one 100 percent capacity service water pump, and one , 100 percent capacity component cooling water pump, to be connected to each diesel generator. Schematic diagrams for these systems (M-301107 and M-310895) have been furnished under Section 1.7. ' O s. h
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48.17 'es s385s sMT SttsI00K STATION = 9763 p,gg4 O ' 430.24. ODESTION It has been noted during past reviews that pressure switches or other devices were incorporated into the final actuation control circuitry for large horse-power safety-related notors which are used to drive pumps. These evitches or devices preclude automatic (safety signal) and manual operation of the motor / f pump combination unless permissive conditions such as lobe oil pressure are eatisfied. Accordingly, identify any safety-related motor / pump combinations i which are used in the Seabrook design that operate as noted above. Also, , describe the redundancy and diversity which are provided for the pressurs ! i switches or permissive devices that are used la this menner. l
\ l 00.24. ANETR '
Large horsepower safety related motors on Buses 5 and 6 have no pressure evitch or other process interlocks to interfere with the automatic or manual operation of thess pumps and fane. O ' r N O -
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l SB 1 & 2 FSAR
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RAI 430.25 Notes on tables 8.3-1 and 8.3-2 of the FSAR indicate that cooling tower or service water pumps (not both) will be loaded on the diesel generator. It is understood that the service water pumps will stop and cooling tower pump will start on a low service water discharge pressure. Describe the design provision that will permit starting of the pumps only at sequence interval 37 seconds or describe how capacity and capability of diesel generator will be demonstrated to drop the 600 hp load and start the 800 hp cooling tower pump at any time after 37 seconds of this sequencer timer. Also, provide electric schematic diagrams for the subject cooling tower and service water pumps.
RESPONSE
Whenever a tower actuation (TA) signal is received; the cooling tower pumps receive an automatic start signal and, the service water pumps are automatically tripped and locked out. Upon loss of offsite power, diesel generator loading is controlled by the Emergency Power Sequencer (EFS). All service water pumps and cooling tower pumps receive a trip signal on loss of offsite power. At sequence interval I')
\s 37 seconds (step 5), both the cool lng tower pump and the service water pump receive a signal to start.
If a IA signal is present, the cooling tower pump starts. If no TA signal is present, only the service water pump will actually start. After step 5, automatic starting of the cooling tower pump is again blocked by the EPS until step 8 (52 seconds), such that, if a TA signal is received between 37 to 52 seconds the cooling tower pump will start at 52 seconds. ' The cooling tower pump will start immediately if a TA signal is received any t*me after sequence interval time 52 seconds. The electrical schematic diagrams for the referenced pumps (M-301107, Sht. Nos. AQ3b and AU2b), are included in Section 1.7 of the FSAR. The diesel generator has been tested and/or analyzed to demonstrate its ability to:
1) accept loads in a combination which exceeds the requirements of,the actual loading sequence, and 2) to drop the largest single load.
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O ' 430.26 As shown on Figures 8.3-7 and 8.3-8 of the FSAR, the 1500 hp startup feed pump is normally connected to non-safety-related Bus 4 with an alternate (manually initiated) feed from safety-related Bus E5. An electrical interconnection exists between a Class 1E and non-Class lE bus. It is the staff position that no single failure in the interconnection, operator action or failure of the non-Class 1E load shall cause the paralleling of I the Class lE and non-Class lE buses or failure of the Class lE system. Provide a design that meets this staff position or justify non-compliance. RESPONSE: We believe our design of the alternate feed for the startup feed pump (SUFP) meets the staf f position. Paralleling of the Class lE and non-Class lE buses will be positively prevented by the interlocking system. Presently, there is a two position (" Bus ES"
- " Bus 4") key-locked switch which will have to be operated in order to be able to close the breaker on Bus E5 or Bus 4. We are upgrading this interlock such that when the switch is placed in ;
position " Bus E5" it will send a trip signal to the circuitry of the SUFP on Bus 4 and vice versa. Furthermore, as pointed out in Note 7 of Figure 8.3-8, no 4 kV breaker is provided for the switchgear position in Bus E5 dedicated to the alternate feed of the SUFP. The operator, following a procedure, will have to 7-~g remove the 4 kV breaker from the SUFP compartment on Bus 4, ' (_,) transport it to the Bus E5 switchgear room and insert it in the proper compartment cf Bus E5. From the above, it is evident that it will take two failures (one electrical and one human error) in order to parallel the two buses. In regards to the concern of failure of the non-Class lE load , affecting the Class lE system, we would like to point out that the connection of the startup feed pump to Bus E5 is not a normal operation; it will be done only under contingency conditions. Fu r the rmore , the connection of the non-Class lE load to the Class lE bus will be done with a Class lE breaker. b) s__-
SB 1 & 2 FSAR RAI 430.27 Section 9.5.5.5 of the FSAR states that "there are no interlocks between the t coolant systems and the diesel generator emergency start circuit, in L conformance with BTP ICSB-17". The meaning of this statement is unclear. Provide clarification.
RESPONSE
The statement in Subsection 9.5.5.5 will be clarified to read: "In conformance with ICSB-17, all diesel generator coolant system protective interlocks affecting diesel operation are bypassed on an accident signal by a lockout relay. The alarms are not inhibited, and the bypass circuitry is testable." Diesel generator protective devices and their compliance with Branch Technical Position ICSB-17 are discussed in FSAR Subsection 8.3.1.1.e.4. , o O i l-l ()
i l SB 1 & 2 FSAR RAI 430.28 The charge-equalizing of the de batteries is not discussed in the FSAR. Usually, the equalizing requires an increased level of voltage. Describe the method of equalizing and the maximum voltage used. In case the de loads remain connected to the battery during the equalizing, state whether these loads are designed and qualified to operate at the equalizing voltage level.
RESPONSE
The Seabrook batteries are composed of fifty-nine lead calcium cells. These cells are maintained on float-charge of 2.23 volts per cell. Manufacturer's data indicate that when this type cell is float-charged above 2.20 volts per cell it requires no, or infrequent, equalizing charge. If equalizing is required, the cell voltage will be raised to 2.33 volts per cell (137.5 volts total). Equalize charging of each battery can be provided by the dedicated battery charger with the' battery connected to the bus. All de equipment has been specified.and purchased with a maximum operating voltage of 140 volts de. O . O'E b e G
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SB 1 & 2 FSAR l O RAI 430.29 ' Provide a battery duty cycle diagram, as defined by IEEE Standard 485-1978, in the FSAR for each Class IE battery. The duty cycle must include both Class IE and Non-Class 1E loads, and the combined loads of two divisions if credit for the interconnection through the tie breaker is to be taken.
RESPONSE
The battery duty cycle diagrams are shown on the attached Figures, which will be added to the FSAR in the next revision. ' A revised Table 8.3-5 is also included. O O i e e
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$ i 775 l
E ,., 1 MIN,40 AMP
@E a2 275 r-- ,
l
. RANDOM LOAD 24 i u" i a
1 = l 15 TIME (MINUTES) 120 : COWNED LOADS OF BUSES 11A AND 11C
l r
AMPS h 575 i
>- i Ze O d ms U 75 f
15 I flME 041NUTES) tj0 j SUS 11C LO4D PROFILE r k AMPS 1 n , 3go ~ 1 MIN,40 AMPS g% g7 200 p.--, RANDOM LOAD
=
D< w U . 1 ; TIME (MINUTES) 120 BUS, ItA LCAD PROFILE : i FIGURE 8.3 41,o.te i
l l ! mn ' \ b O r n. 5^ 1 MIN,40 AMPS W ns g ....[ amoam uno y
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=
TIME (MINUTE $) 120 COMENED 'LMD5 0F SUSES'113 AND 11o
.ues a
e z Ol u II t TrME MNuras) 120 RJS l'D LQ40 PROFILE AMPS n
$^ 310 g *m r--[ 1 MIN,40 AMPS amooMtwo u
tlME (MINUTES) 120 BUS 118 LO4D PROFILE O : FIGURE 8.3 : Mo ti E l
- - is.njeg' t'fis'2 sht stnundpp tig_tiow FTny _ _ , _ m_m. .m. .1 2-- . - - - b.s2= - -M BB1&2 O FSAR . TABLE 4.3-5 s& -
gafety Belated -- -- - - -- - DC Imad . Sis Imad1s Daraties* DC Sus ; Vital Instrument Bus Inverter 1-1A-1 8 .A kW 2 houre- . 11A Vital Instrument Bus Inverter.I-13-1 g 4 kW 2 hours 113 Vital Instrasest Bus Inverter I-1C-1 y 4' kW 2 hours 11C Vital Instreest Ess Daverter I-1D-1 7 E kW 2 houra 11D vital Isaemmasse ase In - ter I=12-1 p g kr 2 homes 11A Vital Instrument Bus Inverter I-1F-1 F 4 kW 2 hours 113 Beactor Protection sad Safemuard Systei.s
. Trois A Diesel Generator Emetter 4.0 kW ,1 min. . ,
11A Train a Diesel Generator Essitar
4.0 kW 1 min. 115 Train A Vital Salesold Valves '
3.8Ov1 kW 2 hours 11A Train S Vital Solenoid Valves 3 0,,9A kW 2 hours 115 Trais A Class Is Power systen 5.0 kW l ain. 11A , Control Power - Train 3 Class II Power Systes 5.0 kW 1 min. 113 Centrol Power ( Triin A Reactor Trip 8vgr. Control Power 1.0 kW 'l sin. 11A l Train 3 Reactor Trip Segr. Control Power 2.0 kW 1 min. 113 - Train A Diesel Generator Sequencer 2.0 kW
2 houra 11A !
sad control Train 5 Diesel Generator Sequencer 2.0 kW 2 hours
115 and Control

Daration - Time used with these loads for the design basis 2 ho6r discharge used to sise the batteries. .
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SB 1 & 2 FSAR O
, RAI 430.30 Describe how the methods used for sizing each Class 1E battery meets the recommended practices described in IEEE Standard 485-1978.
RESPONSE
The Seabrook battery sizing follows the recommended practices described in i IEEE Standard 485-1978, as follows:
1. The system maximum voltage (140 volts) and maximum equalizing cell voltage (2.33 V per cell) were selected. This resulted in a selection of 59 cells which includes margin between the equalizing voltage (137.5V), and the system's maximum voltage.

2. A duty cycle diagram was developed, based upon the combined known and anticipated loads for both de buses of the same train. (See Response to RAI 430.29).

3. The battery capacity data were selected from the manufacturer's data, based upon the minimum cell voltage (1.78V per cell) permitted by the system minimum voltage of (105 V).

4. The calculated minimum required cell size was increased by 25% for
-' end-of-life compensation.
5. Temperature correction factors were applied to the calculated l
1 minimum required cell size, to allow for operation at the minimum design temperature (650F). ' L
6. Sizing calculations were performed using methods similar to
- Figure 3 of IEEE 485-1978 to determine the minimum required cell size.
7. I A minimum design margin of 15 percent was added to the calculated minimum cell size to allow capacity for future loads. l i l l O
I I l . 1 1 g 430,31 Describe how the Seabrook design meets the guidelines of IEEE W Standard 484-1975 and Regulatory Guide 1.128. ,
RESPONSE

The design of the Seabrook de system is in conformance with IEEE j Standard 484-1975 and Regulatory Guide 1.128 (Rev. 1). ,
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i 430.32 The specific requirements for de power system monitoring derive [h
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from the generic requirements embodied in IEEE Standard 308-1974 Sections 5.3.2(4), 5.3.3(5), and 5.3.4(5) and in Regulatory Guide 1.47. In summary, these general requirements simply state that the de syste, (batteries, distribution systems, and chargers) shall be mon.tored to the extent that it is shown to be ready to perform its intended function. Accordingly, the guidelines used in the licensing review of the direct current power system designs are as follows: These indications and alarms of the Class lE de power system status shall be provided in the control room: (1) battery current (ammeter-charge / discharge) (2) battery charger output current (ammeter) l (3) de bus voltage (voltmeter) (4) battery discharge alarm (5) de bus undervoltage and overvoltage alarms (6) de bus ground alarm (for ungrounded system)
; (7) battery breaker (s) or Fuse (s) open alarm
() (8) battery charger output breaker (s) or fuse (s) open alarm (9) battery charger trouble alarm (one alarm for a number of abnormal conditions which are usually indicated locally) The staff concludes that the monitoring cited above, augmented by the periodic test and suveillance requirements included in the Technical Specifications, provides reasonable assurance that the Class lE de power system is ready to perform its intended safety function. Table 8.3-6 of the FSAR describes de power system surveillance and monitoring provisions at Seabrook. Based on a review of Table 8.3-6, it has been noted that a number of indications and alarms specified by the above guidelines are not being provided in the control room. Either revise the Seabrook design to include all indications and alarms specified in the above guidelines or justify the non-compliance. RESPONSE: The following demonstrate our compliance with each indication and alarm as given in the listing above. (1) battery current (ammeter-charge / discharge) - An ammeter is located in the control room and at the de switchgear to indicate battery charge and discharge. O V l
(2) battery charger output current (ammeter) - An ammeter is () located at the charger. In addition, a loss-of-current relay (Device No. 37/62) is provided which senses loss-of-charger output current. This relay provices an alarm locally at the charger and a computer alarm. These, plus the loss-of-charger input ac voltage computer alarm, provide suf ficient indication to show that the battery charger is 1 capable of performing its intended function. (3) de bus voltage (voltmeter) - A voltmeter is located in the ; control room and at the de switchgear to indicate the bus i voltage. In addition, there is a voltmeter at the charger l showing the charger de output voltage. ! (4) battery discharge alarm - A control room alarm will be provided to indicate battery discharge. Table 8.3-6 will be revised to show addition of this alarm. (5) de bus undervoltage and overvoltage alarms - Two undervoltage computer alarms are provided for the de buses. One for . alarming low voltage as a result of battery discharge. A second for alarming on low voltage as a result of a bus fault; this also trips the charger feeder breaker to prevent the charger from feeding a fault. An overvoltage computer alarm is provided by an overvoltage relay at the charger (Device No. 59/62); the charger being the most probable cause of an overvoltage condition. O (6) de bus ground alarm (for ungrounded systems) - For ground detection, a computer alarm and meters are provided in the , control room with additional meters mounted locally near the de switchgear. l l (7) battery breaker (s) or fuse (s) open alarm - The battery supply . breaker to the bus has a computer alarm for the breaker open position.
There is no direct alarm to detect an open or blown fuse.
, Because the battery fuses are bolted in place, the probability of the fuses being unbolted and inadvertently , left out of the circuit is negligible; furthermore, a blown ! fuse of this size (1600A) will be detected soon enough for remedial action. Therefore, no alarm is needed. ; (8) battery charger output breaker (s) or fuse (s) open alarm - The battery charger supply breaker to the bus has a computer . I alarm for the open position. The charger output breaker (integral to the charger) does not have an open alarm; however, it is non-automatic and would therefore not open on i a fault, and if inadvertently lef t open, it would be alarmed i by the loss-of-charger output current since the charger could ! not feed the bus (see #2 above). O . f
1 j -, (9) battery charger trouble alarm (one alarm for a number of l abnormal conditions which are usually indicated locally) - The battery charger trouble alarms, high de output voltage, low de output voltage, loss-of-charger output current, and loss of ac input voltage, all have separate computer and local alarms. i 1 h 4 i . O i .i i 1 I i I O i
l l l SB 1 & 2 l FSAR O P RAI 430.33 1 Recent operating experience has shown that an incompatibility between the battery rack and the battery may cause cracking of the battery case. The cracking may be caused in part by the improper support at the battery stress points. Describe the battery stress points and their relationship with j battery rack supports. l
RESPONSE
The Seabrook batteries utilize cells that have a plate support bridge that is molded separately from the cell jar. This permits even distribut' ion of element weight across the entire bottom surface of the jar, thereby ' minimizing the stress areas in the jar. In the racks, the cells, which have a base of 14 9/16 X 14\ inches, sit on three 1.63" wide steel stringers located under the cell center line and + 5 inches from the center. This evenly distributes the cell weight to minimize ! stress on the cell. , The battery manufacturer has provided assurance that the Seabrook battery i installation has been designed to provide support to the cells. I 0 I O
i i i O 430.34 Section 8.3.2.2.b.1 of the FSAR indicates that to further enhance j safety and reliability, two de supply buses of the same train may ! be connected together manually. Provide the results of analysis, ! reliability studies or other methods that may have been used to ' conclude that safety and reliability of the de systems is enhanced { when one has an intertie available and when interconnected. ! RESPONSE: Please refer to the response to RAI No. 430.37. r i i I F O o O
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l 430.35 As part of the de system failure mode and effects analysis found () in Table 8.3-7, failure of de system A and C or failure of dc system B and D was not addressed. Because these de systems can be interconnected, Table 8.3-7 should be expanded to address the
subject failures. Provide the effect of the subject failures and its safety implication. '
RESPONSE: The failure of buses A and C or the failure of buses B and D with the bus interties closed will be added to failure mode and effects ! analysis in Table 8.3-7, as shown on the next page. I i ! l ! l i t P t I i i 1 i I l l
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TABLE 8.3-7 (Sheet 6 of 6) i EFFECT OF DE1ECTION SAFETY IMPLICATION FAILURE MODE FAILURE DESCRIPTION FUNCTION ITEM Loss of Bus low 1. None - Train B Bus Fault 1. control circuits Bus 11A and llc Distributes voltage
25. power to de all Train available.
(bus intertie A de con- ala rm closed) loads trol ekts.
2. None - Normal

2. Loss of de 480 V ac supply backup available, or Train B power to availabic.
inverters 1-1A, I-1C and I-lE Bus low 1. None - Train A Bus Fault 1. Loss of control circuits Distributes voltage
26. Bus llB and 11D all Train available.
power to alarm (bus intertie de loads B de con-closed) trol ekts.
2. None - Normal

2. Loss of de 480 V ac supply backup available, or Train A power to available.
inverters 1-1B, 1-1D and I-1F
I l l O 430.36 The description provided in Section 8.3.2.2.a.3 of the FSAR of de power system testing as it relates to other equipment associated with the de system is insufficient. IEEL Standard 450 and , Regulatory Guide 1.129 address only batteries. Testing of other i equipment associated has not been described in the FSAR. Provide the descriptiou. The description should include methods or procedures to be used to periodically verify the capability of the batteries to supply power to the de bus when the battery charger , is not available, as well as testing of other equipment such as breakers and fuses. RESPONSE: Procedures will be written for test and inspection of the batteries and battery chargers as outlined in the Surveillance Requirements of Section 4.8.2.3.2 of the Technical Specifications. These Surveillance Requirements verify the capability of the batteries to supp;y power to the bus when the battery charger is not available. Other equipment such as breakers, etc., associated with the de system will be tested and inspected according to the regular plant maintenance program which , will be developed to satisfy the requirements of ANSI-N18.7-1976, l Administrative Controls and Quality Assurance for the Operational - Phase of Nuclear Power Plants, which is committed to in Section , 17.2.2.4 of the FSAR. , O O l r
O V 430.37 As stated in Section 8.3.2.1 of the FSAR, the design of the de power system includes interconnections between redundant load centers through mechanically interlocked manual circuit breakers. It is the staff position that no single failure in the interconnections shall cause the paralleling of the de power supplies. An acceptable design will provide for two' tie breakers connected in series, physically separated from each other, administratively kept open during all modes of plant operation except shutdown and alarmed on closure. The proposed Seabrook design does not provide the needed two breakers in series to meet the staff position. Justify i non-compliance and describe the purpose, need, and Technical Specifications for the interconnection. The proposed design will also parallel redundant battery chargers or de power supplies. Justify the parallel operation of redundant de power supplies. RESPONSE: We believe that the above question has resulted from a misunderstanding of the design of the de system at Seabrook. For the purpose of clarifying any misconceptions and resolving the above questions, the following description of the de system is provided:
, ('/)
s. The safety-related portion of the station de power system for each unit consists of two redundant trains as shown in Figure 8.3-37. The minimum NSSS (RESAR 3S) control power requirements call for two independent batteries and battery chargers with each battery and charger combination connected to a single bus serving two inverters. The Seabrook design improves upon the minimum NSSS requirements by utilizing two batteries, two battery chargers, and two buses per redundant train instead of one battery, one battery j charger, and one bus. Each NSSS inverter is now served from a dedicated de bus rather than a shared bus. The design incorporates mechanically interlocked manual circuit
! breakers which will permit the connection of the two buses within the same train to a single battery. There are no provisions for either manually or automatically interconnecting the two redundant trains of power.
We believe that having the above mentioned interconnection capabilities within the same train enhances the reliability and ' flexibility of plant operations by allowing one of the train batteries to be removed for maintenance while maintaining power to all of the train loads. The Technical Specifications have been written to take credit for the interconnections (see Technical Specification Section 3.8.2.3). (7-~)
%.) As stated in Section 8.3.2.1.b of the FSAR, each safety-related battery is sized to have sufficient capacity to serve both load groups of the same train during the period when one battery is out of service.
430.38 Section 8.3.1.4.a of the FSAR states that " Train B associated () circuits are kept to a minimum, consisting essentially of support equipment for Train B safety-related equipment, such as the diesel generator". Support equipment such as the diesel generator are considered Class lE equipment and are not considered associated as defined by Section 3.9 of Appendix 8A of the FSAR. The above statement appears to be in non-compliance with separation criteria defined in Appendix 8A of the FSAR. Justify ) the non-compliance. RESPONSE: The diesel generator requires both Class lE and non-Class lE auxiliary equipment. Section 8.3.1.4.a may be misleading by implying that all diesel generator support equipment have associated circuits. The section will be clarified to read:
" Train B associated circuits are kept to a minimum, consisting essentially of non-Class lE auxiliary equipment for Train B safety-related equipment; for example, the diesel generator B starting air compressor.
O O
SB 1 & 2 FSAR
\
O RAI 430.39 Based on a review of the Seabrook separation criteria, it appears that isolation devices (circuit breakers) are used to separate Non-Class 1E circuits from Class 1E circuits. It also appears that Non-Class 1E circuits that have been isolated are again routed with Class 1E circuits in non-compliance of separation criteria (Section 4.5.b of Appendix 8A to the FSAR). Justify this apparent non-compliance. ,
RESPONSE
In the Seabrook design, non-safety-related circuits are associated with either Train A or Train B, in compliance with option 4 5a of Appendix 8A Non-safety-related circuits meet the requirements for associated circuits, such as cable derating, environmental qualification, flame retardance and raceway fill. All associated circuit cables meet the same specification requirements as Class 1E Cable. They are also uniquely identified. O . b Oe e i l i i n v l
SB 1 & 2 FSAR O 1 RAI 430.40 Section 8.3.1.4a of the FSAR states that " .. . all train B associated l (non-vital) power circuits are de-energized during an accident condition ! upon receipt of a safety injection (SI) signal. In this way, the signal failure criterion is met, in that only Train A is vulnerable to effects of a ; single incident which may effect non-safety related raceways of both ! separation groups A and B." Based on this statement, it appears that ! associated cables from train A and B are routed together in a common non-safety related raceway with non-class IE cables. This does not meet l section 4.6 of Appendix 8A of the FSAR. Justify the non-compliance.
RESPONSE
8 Seabrook design is in complete compliance with options 4.Sa and 4.6.2 of j Appendix 8A of the FSAR. All non-safety circuits are treated as associated circuits. Our design does not allow the associated cables from Train A and Train B to be routed together in a common raceway. FSAR Subsection 8.3.1.4a has been revised to correct an error in the earlier writeup. f O i I 6
- / t 4 s.
JP . /. ,, SB 1 & 2 ( l l Nuclear instrumentation cables are routed in steel conduits for their entire distance. The two redundant trains (Train A and B) and the four redundant channels (Channels I, II, III and IV) are routed through four ; physically separated raceway systems, called separation groups, as shown in Table 8.3-4. Physical separation of the four groups is maintained by means of one or more of the following:
1. Separate erposed rigid metal conduits, or

2. Separate concrete-encased plastic or metal ducts in the same duct bank, or

3. Cable trays separated by a wall, a floor, or an equivalent i barrier with a three-hour fire rating, or

4. Separate cable trays in the same room where a minimum of three feet horizontal or five feet vertical separation exists between trays of redundant systems.

5. Separate cable trays in the cable spreading room (as defined
(}
\s) in Appendix 8A, Section 5.1.3) where a minimum of one foot horizontal and three feet vertical separation exists between trays of redundant systems. [
All non-safety-related circuits are associated with either Train A or Train B, in accordance with Option 4.5a of Appendix 8A. Train B associated circuits are kept to a minimum, consisting essentially of support equipment for Train B safety-related equipment, such as the diesel generator. To further enhance the separation of groups A and B, all Train B associated (non-vital) power circuits are de-energized during an accident condition upon receipt of a safety injection (SI) signal. In this way, the single failure criterion is met in that only Train A is vulnerable to effects of a single incident which may affect non-safety-related circuits of either l f separation Group A or B. ;
b. Selection of Cable Insulation Insulation systems for cables comprise materials or combinations of materials for primary insulation, jackets, shielding, tapes, fillers and armoring. The factors considered in selecting a cable insulation system include stability and length of life, dielectric properties, resistance to ionization and corona, resis-tance to high temperatures, resistance to moisture, resistance to chemicals, resistance to radiation, mechanical strength, flexibil-ity, self-extinguishing and non propagating fire characteristics, g 's and general environmental considerations.
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i 8.3-30 i l
_ _ ______. _ _ _ ~ _ SB 1 & 2 i FSAR ! t O RAI 430.40A Identify each difference between the separation criteria of regulatory guide ! 1.75 (IEEE Standard 384 1974) and separation criteria identified in i Appendix 8A of the FSAR. i RESPONSE: I i In the Seabrook design, non-safety circuits are treated as associated ! circuits, meeting options 4.Sa and 4.6.2 of Appendix 8A of the FSAR. There ; is no difference between Regulatory Guide 1.75 and Appendix 8A regarding the . above options. To further enhance the systee, associated circuits are electrically isolated { from Class 1E circuits by qualified Class IE circuit breakers or fuses. ; t
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SB 1 & 2 FSAR O RAI 430.41 Section 8.3.1.4 of the FSAR indicates that separation of redundant cables with control and all other fietd mounted racks is discussed in Section 7.1 of the FSAR. The referenced separation discussion is not provided in Section 7.1 of the FSAR. Provide a description of separation between redundant Class 1E cables, betseen Class IE and Non-Class IE cables, and between Non-Class IE and associated cables. Describe and justify each exception to Section 5.6 of Appendix 8A of the FSAR.
RESPONSE
Independence of redundant safety-related systems is discussed in Subsection 7.1.2.2 of the FSAR. All cabling to control and field-mounted racks is identified as either Class 1E or associated cables. There are no non-class IE cables. There are no exceptions taken to Section 5.6 of Appendix 8A of the FSAR. . O 9 d l f s l l s
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SB 1 & 2 FSAR O RAI 430.42 Section 8.3.1.4.a of the FSAR states that "all non-safety related circuits are associated with either train A or train B. Based on this statement, it appears that non Class 1E cables and raceways do not exist at the Seabrook plant, and that all cables are color coded as defined in Section 8.3.1.3 of the FSAR. Provide clarification and define the separation provided between associated cables and non-class 1E cables.
RESPONSE
In the Seabrook design, non-safety-related circuits are treated as associated circuits. Also, refer to responses to RAIs 430.40 and 430.40A. O I 1 l
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FSAR RAI 430.43 ' l Busses E51, E52 and E53 and busses 161, E62 and E63 are interconnected throush i i normallyopenbustiebreaker. Provide a description of the interconnection ' that includes capacity and capability of the 4160/480 volt transformers to ! supply the conhected loads when using the interconnections. I
RESPONSE
Bus tie breakers provide manual interconnection capability between unit substations E5L E52 and E53, all of Train A. Similarly, interconnection j capability exi sts between unit substations E61, E62 and E63, all of Train 3. Bus ties may b i used when any unit substation transformer is outLof service N 1 for maintenancp or repair. Bus ties are provided only for operational l flexibility. peunitsubstationsarenotdesignedtosupplythetotalload When a bus tie breaker is used, loading on each - l when bus ties pre used. unit substation will be administratively controlled to be within the FA '- of the unit su3 station transformer. I O k O l I l
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C;' . 430.44 Redundant Buses E5 and'E6 are interconnected through Bus ES2, (8.3.1) MCC 523, Charger ED-13C-2B, 125V Bus 12B, UPS ED-I-2B and Bus E63. , (8.3.2) Either eliminate or justify this interconnection.
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Provide the results of an analyhis 'tliat' identifies and justifies
, all electrical interconnections betweeh redundant divisions. ~ ~. ,
RESPONSE: Although such interconn_ections as des'cribed above might be i f , theorized, we believe that from a prac'tical standpoint they are nonexistent. It is inconceivable for'apy failures to occur which would af fect both safety divisions. .,The safety divisions are , effectively isolated through the inherent blocking feature between . input' and output of the chargers, the current limiting feature of l the UPS and the charger and the various protective devices.
, - 2,3 ,
It remains r tion that there are no ele'ctrical l interconnec oetween re'd undant. divisions.
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j ... 'I i, l SB 1 & 2 FSAR i i RAI 430.45 I 1 Provide 460 volt motor control center (MCC) one line diagrams for MCC 531, l 523, 631 and 541. ' i j RESPONSE 4 3: Enclosed are one line diagrams for motor control centers 531, 523 and 631. . MCC 541 is non-existent. - 4 . t 4i I i i i 1 l 3 i r O l i I l-t I' i i r_ . . . _ . _ _ _ _ . , . . _ . , . _ . _ = . . _ _ _ _ _ _ _ . _ . . . _ _ _ , , _ _ _ - . . _ _,, _
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SB 1 & 2 ,i RAI 430.46 Non-Class IE space heeters are provided in Class IE motor control centers and are powered from Class 1E power sources as indicated on Figure 8.3-45 of the FSAR. It is the staff position that the Class IE circuits may be degraded below an acceptable level as a result of a failure in the Non-Class IE heater circuits. It is the staff position that the applicant either demonstrate that the space heater circuit arrangement will not degrade the Class IE circuits below an acceptable level or provide a design that satisfies IEEE Standard 384-1974 as supplemented by regulatory guide 1.75 (revision 2). Describe the degree of compliance with this position.
RESPONSE
Non-Class IE space heaters are isolated from Class 1E power sources by Class 1E fuses backed up by Class 1E breakers. These Class 1E protective devices will prevent any degradation of Class IE circuits below an acceptable level. A U 4 I l lO .
SB 1 & 2 FSAR O RAI 430.47 Compliance to the guidelines of Regulatory Guide 1.118 revision 1 and IEEE Standard 338-1975 is Section 8.1.5.3 of the FSAR indicates that the design of electric power systems is to be in conformance with Regulatory Guide 1.118 revision 2, Section 1.8 of the FSAR also indicates that the BOP electric power system testing will comply with Regulatory Guide 1.118, Revision 1, but, for NSSS supplied electric power systems, the recoussendations of regulatory guide 1.118 reivision 1 will only be followed at the NSSS suppliers discretion. In addition, Section 8.3.1.1.g of the FSAR implies or addresses only compliance with IEEE Standard 308 and GDC 18. Provide clarification and clearly state that the onsite ac and de Class 1E power systems meet the guidelines of regulatory guide 1.118 and IEEE Standard 338 in Sections 8.3.1 and 8.3.2 of the FSAR.
RESPONSE
The onsite ac and de electric power system design, as stated in 8.1.5.3, is in conformance with Regulatory Guide 1.118, Rev. 2, and IEEE Std. 338-1977. Sections 1.8, 8.3.1.1 and 8.3.2.1 of the FSAR have been revised to incorporate compliance of the design to these criteria. The NSSS supplier position regarding Regulatory Guide 1.118 as stated in Section 1.8 of the FSAR, does not apply to NSSS supplied " electric power system." These power systems are uninterruptable power supplies whose normal feed is from a plant as source. Automatic uninterrupted output on loss of ac source can be tested by opening P.he normal ac source circuit breaker. i O
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/
SB 1 & 2 (To b2 incor-1 FSAR porated in , Amendment 45) I greater than the required 10-3 For further discussion, refer to Subsection ; 3.5.1.3. . l l Regulatory Guide 1.116 Quality Assurance Requirement, for Installs- l (Rev. 0-R, 6/76, 5/ 7 7) tion, Inspection and Testing of Mechanical l Equipment and Systems f r Endorses ANSI N45.2.8-1975 l The guidance of this Regulatory Guide has been used in the installation, i inspection a For further discussion, refer qd testing of sechanical to Sections equipment 17.1.2 and 17.2. and systems. ! Reaulatory Gs ide 1.117 Teenado Design Classification - (Rev.1, 4/741) l The plant deoign complies with Regulatory cuide 1.117, Rev. 1. ! l Although the condensate storage tank is not designed for missite's or a pressure drog, the system will function if the tank fails because the shield ; wall is designed for missiles and is waterproofed to contain water from the ' O The ultimate heat sink cooling tower is not designed for tornado sissiles in
,the fill area . The primary source for water is the Atlantic Ocean through the undergrotad tunnels, which will function during a tornado event.
For further d iscussion on this subject, refer to Section 3.5. Regulatory Ct ide 1.12 Periodic Testing of Electric Power - (Rev. 2, 6/71,) and Protection Systems i The onsite ac and de Class 1E electric power system testing will comply with l l Rev. 2 of this regulatory guide IEEE-338-1977. ' For protectica system testing NSSS supplier will treat all "should" i. ! statements it IEEE-338-1975 as recossendations to be followed only at its l discretion. Detailed positions on the regulatory positions are presented belows
a. Regulatory Position C.1 j The N588 supplier will provide a means to facilitate response ties testing from the sensor input at the protection rack to and l influding the input to the actuation device. Examples of actuatioe devices are the protection system. relay or histable.
i 1.8-41 )
)
l
^/{ M TD.41 )
l SB 1 & 2 FSAR I
.forlmotorsisNEMAClassBasaminimum,withtheactualinsulation ,
class selected on the basis of environment and service conditions I in phich the motor is required to operate. The factors taken into consideration in selection of the insulation system are resistance to ' radiation, resistance to moisture, resistance to chemicals, amblient temperature and pressure. The motor enclosure is selected , to protect against adverse environmental conditions. Winding temperature detectors and bearing thermocouples are providad on large motors to alarm high temperature conditions. The, motor suppliers are required to verify that actual test data confirm that the torque margin is equal to of greater than tha't of the calculated data. A further check of motor capability is khe preoperational testing conducted at the site under plant light load conditions, to simulate the maximum voltage practically obtainable, and under plant heavy load conditions, to sinnsiste the minfaman voltage practically obtainable (reference Section 14.2.6, exceptions to Regulatory Guide 1.68). J. Prorisions for Periodic Testing and Maintenance j The onsite ac distribution system for engineered safety features loais is designed and installed to permit periodic inspection testing in accordance with General Design Criterion 18 IEEs and;dard Stan 308-1971, Regulatory Guide 1.118, Rev. 2 and IEEE 338-1977 l to ensure:
1. The operability and functional performance of the components of the system, and

2. The operability of the system as a whole under design conditions.
Swi tchgear and accessories for the auxiliary power system are ; eas ily accessible for inspection and testing. l The 13.8 kv, 4160' volt and 480 volt switchgear circuit breakers may be tested when the individual equipment is deenergised. The , beeskers can be placed in the test position and tested functionally.
~
! The first and second level undervoltage schemas (see Subsection 8.3.1.1.b.4) are designed to permit periodic testing during normal plast operation. Breskers for engineered safety features auxiliaries are exercised on a schedule siellar to that for the auxiliaries controlled by the b reakers. Transfer schemes can be exercised during normal l operation, or by simulation of the necessary condicione. Timing l che'cks can be performed on transfer schemes. Protective relays
are provided with test plugs or test switches to permit testing, l and calibrating the devices.
I 8.3-22 .
m...e v. 7 ...p.- -. 551&2 FSAR O DC Power System Testing e. The batteries and other equipment associated wich the de system are easily accessible for periodic testing and inspection. Sur- l vel}1ance and testing are performed in accordance with the plant Technical Specifications in compliance with the guidelines of IEEE 5tsudard 338, 450, negulatory cuide 1.118 tev. 2 and 1.129. l The preoperational testing of the safety related portion of the de pystem will be performed in accordance with Regulatory Guides 1.63 and 1.41.
f. Surveillance and Monitorina The operator is provided with indications and alarms for monitoring the state of the de system as listed in Table 8.3-6.
8.3.2.2 Analysis The DC Eystem Failure Mode and Ef fect Analysis is found in Table 8.3-7. I a. Compliance with General Design Criteria f 1. Criterion 2_- Design Basis for Protection Aasinst Natural Phenomena (a) The components of the onsite de power system are located in seismic Category I structures which provide protection x from the effects of tornadoes and e'ternal floods, and other natural phenomena. (b) These components ar* Class 13. (c) These components have been designed to be fully qualified for the seismic and natural environmental conditions appropriate to their location. See section 3.11.
2. Criterion 4 - Environmental and Missile Design Bases (a) The components of the onsite de power system are located .
in seismic Category I structures which provide protection ' from the effects of tornado missiles, turbine missiles and other events and conditions which may occur outside the nuclear power unit. (b) These components are class lE. (c) These components are designed to accommodate the* effects of and be compatible with or are protected against the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents including loss-of-coolant accidents. Criteria are presented in chapter 3. Environmental conditions :re presented in chapters 3 and 6. 8.3-40
430.48 Section 8.3.1.1.g of the FSAR indicates that thermal overload () (8.3.1) (8.3.2) relays will be tested or removed and replaced with precalibrated relays. It is not clear how removal and replacement negates or replaces testing. Provide clarification and describe the capability to test the subject relay as required by GDC 18. RESPONSE: Removal of thermal overload relay devices and replacement with precalibrated, pretested ones does not negate testing, it is considered an equivalent method of in place testing of the relays. A number of ambient compensated thermal overload relays are selected identical to the corresponding number of relays designated to be tested per Technical Specification 3.8.3.2. The selected relays undergo a testing program at the maintenance shop or other designated location prior to the 18-month test interval. The testing is done as described in Section 8.3.1.1.g of the FSAR by applying a preselected value of current and observing that the relay operates (it opens the circuit) in accordance with the criteria established and the relay curve. These pretested relays will now be installed in the selected circuits (see Technical Specification Section 3.8.3.2) whose thermal overload relays have been removed; the functional operation of the circuit will then be tested (i.e., valve closed or open). We believe that this procedure is equivalent to testing in place the operation of the thermal overload relays; in fact, it might be superior because the testing of the relays is not performed under the time constraints , so common during refueling outages. O o F 0 V 7
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_RAI 430.49-Section 8.3.1 7 13 of the FSAR states that ambient compensatederload thermal ov relaysalso F8AR aresta usad to protect both continuous and short-time rated motors. The current chara tes that the relays are responsive to current and their time-variations. :teristic are, for practical purposes, unaffected by temperature that demonstrTrovide a description of the test and/or analysis with results tions. ate that the sub. ject relays are unaffected by comparature varia - Eg8PONSE: A test procedu overload relays is provided below.re and test results for testing ambient-compensated the manufacturer af the Seabrook Motor Control Centers.This test procedure was developed by Correction Cu An Ambient Temperature 430.49-1. Th overload rela e figure demonstrates that the ambient-compensated therm y has a relatively flat temperature correction curve. For practical purposes the trip current is unaffected by variations in the
ambient RAI tempe rature of the thermal overload relay.
430.50. See also the response to _ Test No. 81WO71
SUBJECT:
U.L. Approval Test for Size 1 and 2, L11 Independently Mounted, Ambient Compensated, Overload Relays. PURPOSE: To obtain U.L. approval on subject OLE'5'with Header Tables 409541 and 409542 from Test No. 81WO14. PROCEDURE Three Sise 1 and three Size 2 Independently Mounted, Ambient Compensated overload Relays were supplied for this test. All overload relays were individually checked for calibration in the lab'sre408C ovens with T44A heaters.Calibration procedures 26.3 amperes, quired that the overloads trip with a current of in less than 4200 seconds. 2, 4 (Sise 1) and #5, 6, 7 (Size 2) were then combined onOverload relays #1, mounting plates for testing as three pole devices. Each set was placed in an overload test oven, and wired with four feet of wire attached to each field wiring terminal. Wire size Ssetion 23, Paragraph 23.7.was rated for 125% of heater element rating, == Three heater sises were selected for testing request with the three pole overload relays, per U.L. Sise 1, 3 pole I T6 (low) T34 (middle) T49A (high) l 5ise 2, 3 pole as T374 (low) T47A (middle) 736 (high)
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O 430.50 Position C2 of Regulator" Cuide 1.106 requires that the trip setpoint of the thermal ost.rload protection devices should be established with all uncertainties resolved in favor of completing r the safety function. Define each uncertainty considered with de cription and justification of how each is resolved in favor of completing the safety function. , RESPONSE: To assure completion of the safety function many concerns have been addressed; the significant concerns are listed below. We are also providing a copy of an IEEE paper entitled "The Dangers of , Bypassing Thermal Overload Relays in Nuclear Power Plant Motor Operated Valve Circuits" which elaborates on the solution of these ; concerns, and provides insight into our philosophy for selecting thermal overload relays. The paper is identified as Attachment ' 430.50.
1. Concern: Variations in motor ambient.
Resolution : This is not a condition that will affect the proper operation of the thermal overload relay. (Refer to , Attachment 430.50 for further details). "
2. Concern: Variations in overload relay ambient.
Resolution: The use of ambient compensated relays precludes O ~ this concern. I
3. Concern: Variations in ambient temperature between the installed location of the motor and the thermal overload device.
I Resolution: The thermal overload relay is unaf fected by this condition unless there is a corresponding change in the ambient at the relay. The use of ambient compensated thermal overload relays precludes this latter concern.
4. Concern: Inaccuracies due to misapplication of manufacturers overload relay selection tables.
Re solution: Manufacturer supplied tables for selection of thermal overload relays are not used. Each thermal overload , relay is selected by individual calculation, taking into account the individual motor parameters, the valve stroking time, and the time-current characteristic curves of the < overload relay. (Refer to Attachment 430.50 for further details.)
5. Conce rn: Inaccuracies due to setpoint drift.
Resolution: Limits of setpoint drif t are established by the manufacturer and are indicated on the time-current i
\' characteristic curves as the tolerance band of the relay; the !
tolerance band is considered in the calculations described in i Item 4 above. l f _ -.
t O 6. Concern: Premature operation of the thermal overload relay. Resolution: The overload relay selection criteria noted on FSAR page 8.3-20 stipulates that the relay not trip in a time less than twice the normal stroking time. This assures adequate margin to preclude premature tripping.
7. Concern: Longer stroking time due to binding, etc.
Resolution: See Item 6 above. O O 1
IEEE Transactions on Power Apparatus and Systerns. Vol. PAS-99. No. 6 Nov/Dec 1980 2287 ! l THE DANGERS OF BYPASSING THERMAL OVERICAD !' RELAYS IN NUC12AR POWER PLANT MCFTOR OPERATED VALVE CIRCUITS Farouk D. Baster, Senior Member, IEEE pgTT fN cuwE nT ($0 5D i l Yankee Atomic Electric Company Westboro, Massachusetts Abstract -A situation may exist where a control circuit modification designed to enhance safety and I ~ ~ ~ ~~~~~ ~~~""~~q ~~j relitbility may actually jeopardise the integrity of l l the very system it is trying to protect. One such Power g l , sit ua ttan involves ac and oc Motor Operated valve l Supply l f circuits in nucle a r power plants which have been l g designed with their thermal overload protection g g bypsued or altogether elimina ted. The purpose of this paper is to: g } } } Circuit Breaker g g l I ! (t) Point out the dang e r s of this design _ philo sophy. O nCotaclor __ g (b) Show that the thermal overloed relay can g} ~~ ' Clo[eCoStac[or8 l play an important part in improving overall nuclear plant safety. ! l l 1 '; (c) Provide recommendations on the selection of l Thermal Overidad thermal overload relays. I Relay SensinPl l Element l g t---_-- .._ _ _ _ _1 j b N.) Motor Operated Valves (MOV's) in Nuclear Power
.ents are usually powered from Motor Control Centers HOV (McC's) as illustrated in rigure 1.
Short circuit protection of the MOV circuit is typicc11y provided by a molded case circuit breakers ovsrlsad protection is accomplished with thermal Figure 1. Line Diagram Showing evstload relays installed in a reversing contsetor. Typical MCC Internals whsn the breaker ope r ate s, it opens up the power circuit directly: when the thermal overload heater recchts its trip point, it activates a relay which (b) Thermal overload relays are desigsed d2-snergises the control circuit, thus dropping out primarily to protect continuous duty motors the contactor and deenergising the power circuit. In and are not suited to intermittent duty stteEpting to increase the overall reliability of the motors. MOV when performing a sa f ety function, it has bee n common practice to either bypass the output contacts (c) It is difficult to accurately select thermal of the thermal overload relay, or use an over sised overload relays for motor operated valves. tharcal overload element such that it becune s unresponsive to circuit overloads. (d) Temperature variations at the Mov and the Both of these practices may result in a decrease MCC under different operating conditions in cvsrall nuclear plant sa f ety system reliabilitys make operation of an overload relay nonsthsle s s, arguments and justifications continue to unpredictable and erratic. be offered for this action. Some of these arguments ses listed below: (e) Accuracy and repeatability of the thermal overload relay is unknown. j (s) The safety function must be performed even l I at the risk of damag ing or destroying the motor. ANALYSTS l The preceeding arguments are unfortunately based ! I firstly, on misconceptions of the fundamentals involved, and secondly, on oversimplification of the l Mov and its appurtenances. It is hoped that the i succeeding paragraphs will help clarity these 4 misconceptions,
)
M 0 260 0 A paper recommended and approved by the
.s.EE Nuclear Power Engineering Committee of the IEEE Power III Intermittent Duty Motors - The thermal overload relays are de signed to be Enginscring Society for presentation at the IEEE PES Wintar Meeting, New York, NY, February 3-8, 1980. responsive to the heat produced by the flow ,
of currents whether this current is drawn by Manuscript submitted September 9,1979;made available * * "'I""*** d**Y "***' "" I"*"I"**"" far printing December 5,1979. duty motor is tomaterial as far g 0018-9510/80/I100 2287500.7501980 IEEE
l 220s i i l' l as the thermal overload relay is concerned. (4) Dangers - The reasons why bypassing of O By using the correct techniques and trip thermal overload relays results in a characteristic curves, the overload relay decrease i verall nuclear plant safety are can be sised and used ef fectively to protect illustrated by analysing MOV operation under intermittent duty sotor s with all various abnorra1 conditions such as frosen uncer taintie s r e solved . It should however bearing, tight packing, mid-travel be pointed out that manufacturer supplied obstruction, torque swita" fa!!ure, limit selection tables for thermal overload relays switch failure, and post-accident are intended to be used on continuous duty operation. First, a brief explanation of motors therefore, use of these tables for solded case circuit breakers is in order. intermittent duty motors constitutes a Molded circuit breakers are of two basic types misapplication which could result in errors. (This appears to be the most common Magnetic Only, and cause for thermal overload relay maloperations and also, th e est popular Thermal-Magnetic. reason for advocating their bypass.) Both types of breakers have a magnetic trip; (2) variations in Motor Ambient - The Mov should the magnetic trip is an instantaneous device be designed to oper a te in the maximum that trips without time delay once a predeter-environment which is expected: therefore, mined setting has been reached. The thermal-the mtor will have no problem operating in magnetic Circuit breaker differs from the temperatures lower than this ma xim a, magnetic in that it has an inverse-time (Admittedly, by this design the Mov vill thermal element to provide some degree of over-have unutill ed thermal capability at any load protection. The minimum trip point of te mpe r a tur e lower than its design maximum.) the thermal element is usually unadjustable Under a given operating condition, the MOV and factory set at approximately 300% of will essentially draw the samt current breaker continuous current. whether its ambient is 400 C or 150 C for example, if the full load current is 10 In selecting a circuit breaker one must ensure A at 40"C, it w!11 for all practical that it has a continuous current rating greater purposes, be 10 A at 150 0C. (Although than the full load current rating of the Mov, motor winding resistance will increase with and that it has a magnetic trip setting increasing temperature, this will have a greater than the locked rotor current. (Since minimal effect on the current drawn) . Now' the magnetic trip its instcntancouS, it must if the remotely located thermal overload be set above locked rotor current to allow the relay is set to trip at say 10 A, it will motor to start). ] j trip at this current regardless of the V temperature of the motor. Clearly, motor ambient temperature variations do not (a) Frozen Bearing - if a safety related influence the trip setting of the thermal valve has a frozen bearing, the motor overload relay because these variations do will not move and will drew locked not have any ef fect on the current passing rotor current. If the circuit breaker ,; through the overload relay. is of the thermal-magnetic type, then , the thermal element in the circuit ] Variations in MCC Ambient - Temperature breaker will sense the locked rotor } variations at the MCC are of concern because current and open the circuit - 3 these affect the operation of the overload therefore nothing has been gained by f relay. Most manufacturers as sume a 400C eliminating the thermal overload j ambient when providing relay time-current telay. In fact, there is a serious characteristics; however, as pointed out in concern that the motor might exaeed its paragraph (1) above, the overload relay thermal withstand limit before the , responds to heat which is normally oduced thermal element actuates. by the flow of current (hea t .c I ) , any other source of heat will also af fect the If the circuit breaker is magnetic $ relay, including significant changes in only, the locked rotor current it is ambie nt temperature at the MCC. If carrying is well above its continuous h temperature variations in MCC ambient are a rating and yet below the instantaneous concern, the solution is to use ambient trip setting. Failure of the circuit t compensated . overload relays. If it can be breater or motor is now imminent. If i determined that the MCC is located in a the circuit breaker or motor fails, a y controlled environment area, the ambient short circuit will result which will compensated relays may be unnecessary. now have to be cleared by the incoming i breaker to the MCC; this action will l Steady state temperatures above or below remove all power to other safety j 400 C can be compensated by recognising the decreased or increased thermal capability of equipment on the bus. The reliability of the safety system has been decreased [ the relay to accommda te 12 heating prior by eliminating the th,rmal overload -f to relay actuation. relay. (3) Accuracy - The accuracy of thermal overload (b) Tight Packinq = the valve may C relays is known and is available from the experience partial binding (that is, (' manufacturers' published data. Most binding due to tight packing), that l time-cur r e nt characteristic curves indicate permits restricted movement of the l the operating band of the heater and relays valve. The motor may draw a current i the most conservative value of the band anywhere from full load current to ' should be ut!11:ed. locked rotor current depending on the i
f
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I O degree of binding. I If the circuit breaker is of It should be clear from the above discussion thethermal-magnetic type, then the that the thermal overload relay is invaluable in , r thermal element may or may not see the providing circuit protection for all type s of . increased current. malfunctions and operating modes that may be l e xpe r ie nced it is also vital in .nhancing the ; i If the thermal-magnetic element senses continued safety of the nuclear power plant. i the current and opens the circuit, Elimina ting or oversiting the thermal overload relay ' 3 then nothing has bee n gained by appears to be a practict for which there is no eliminating the thermal overload relay. technical basis or justification. I, n f If, however, the thermal element does RECCMMENDATION [ not sense the increased current. the ' current will exceed the continuous In order to assist eng inee r s and designers in rating of the circuit breaker by a { C factor up to 3004. Failure of the correc*.ly sizing thermal overload relays, certain ; circuit breaker or sotor can be steps are suggested: an example of an actual l' ll - expected in time with results similar calculation is also provided. l *a that described in paragraph leal l above. The reliability of the safety The first step is to obtain the following informations J decreased by system has been h eliminating the thermal overload relay. Rated stor full load currer t E
" ' Rated motor locked rotor current t
(c) Mid-Travel Obstruction and Torque Motor service factor j Motor thermal time limit for carrying l l Switch ra11ure - if a safety related
/
1 valve encounters an obstruction during locked rotor current j travel and the torque produced exceeds Stroking time of MOV when performing its the setting of its torque switch, the design function switch will actuate to instantaneously Time-current trip curve of thermal de-energine the circuit. Since the overload relay thermal overload relay has Overload heater selection tables MCC ambient temperature O itive r se-time characteristics, it would not have responded as fast as the torque switch in this s itua tion, The selection of the thermal overload relay for a l therefore, nothing is gained by given application should be based on the following eliminating the thermal overload relay. criteria If, t1 wever, the torque switrh had 1. When carrying locked rotor current, the fallet to operate and the thermal thermal overload relay should actuate in a overload relay had been bypassed, the time within the motor's limiting time for IOV would have drawn locked rotor carrying locked rotor current. current. The consequences would be sin 11ar to the massive failure 2. When carrying a current equal to nameplate described in paragraph 4a. full load current times the service factor, the motor should not trip in a time period If a valve encounters an obstruction less than twice the MOV stroking time. and the torque produced does not e xceed the setting of its torque , Example switch, the situation and consequences would be similar to those described in 1. Given Data paragraph 4.b. Full load current 5.0 A 38.5 A (d) Limit Switch Pailure - if a valve locked rotor current 1.15 i reaches the end of stroke and its Service factor l limit switch fails to operate, the MOV Thermal time limit will draw locked rotor current. If for carrying locked l the ther mal eserload relay has been rotor current 15 seconds [ bypassed, the consequences would be Stroking time 35 seconds y Time-current trip u sluttar to the massive failure ' described in paragraph 4.a. curve Figure 2 Heater selection Operation by table Figure 3 (e) Post- Accident - eliminating the thermal overload MCC ambient temp. 30 C to 50 0C I relay, the MOV or its circuit may be damag ed or destroyed while trying to 2. Selection Procedure perform its sa f ety function. It is (g v
}
obvious that firstly, the MOV may not be in its de s ir ed pos ition when it
a. On Figure 2 draw a horizontal line at 15 seconds to indicate the thermal time limit for carrying locked rotor ,
falls: and secondly, the MOV say be I incapable of being moved subseque ntly current. if it is in a high radiation or other i This line intersects the relay curve inaccessible area. Inclusion of the b. at both 3.5 and 6 times the trip I thermal overload relay in the circuit could provide for r e pea ted stroking current rating. If we choose 3.5 , times, we observe that, due to attempts even if the relay actuated, l l l
22b [
. tolerance, the relay may also trip in j :
40 seconds. This is unacceptable as it violates criterion 1. Choosing 6 Mrater or u r at time s results in a ma x imum trip time p of 15 seconds and a minimum of 6 Cat. eso. Ma. Men. f.
" #'" ** 1 1.92 2.10
c. Now locked rotor current = 6 time s 2 2.11 2.31 i relay trip current, or relay telp 3 ,,33 g current = 38.5/6 = 6.4 A.
4 2.56 2.80 .
d. The note on Figure 3 states that the g relay trip current is 125% of the rated relay settings so relay minimum 6 3.08 3.38 current = 6.4/1.25 = 5.10 A. 3 3,3, 3, ,3

e. The nearest rated relay site from 8 3.8t 4.19 Figure 3 is Heater No. 11 with a 4.57 9 4.20 minimum current rating of 4.99 A.
10 4.5a 4.98
f. Using Reater No. 11 the trip current i 4*99 $ 43 is now 4.99 x 1.25 = 6.25 A.
1r 5.42 5.89 )
g. Locked rotor current is 38.5/6.25, or ,
13 5.90 6.44 6.2 times the trip current. , eccoo 14 6.45 7.03 N0ft:
- The current at which the heater will 8000 trip the everloat relay is 125% of j the above setting. J I
8000 i rigure 3 Overload Relay Selection Table g 2000 i I
h. Referring back to Figure 2, we note that 6.2 times trip current results in
{ a trip time of 14 seconds maximum and J 5.5 secx>nds minimum, both of which meet criterion 1 and are therefore i 5 soo acceptable. !
1. To determine if criterion 2 is met, we d 800 divide the full load current times the J f service factor by the relay trip !
800 current (step f), i.e. 5.0 x 1.15/6.25 [
= 0.92. This indicates that the full ,
load current is 0.92 times the trip , we 00 0 \ current. Re ferring to Figure times trip current 2, note that 0.92 ,d > I results in a minimum trip time of 1000 seconds and a maximum of infinity.
1 Since the stroking time of the MOV is j 35 seconds, criterion 2 is also d I
so satisfied. go j. The correct heater is established as No. 11. !
\ 3 l ( \ <
i. r g i CONCtOSTONS i
E \ \ The preceeding paragraphs have analyzed the he \ operation of MOV's under various abnormal conditions 3 y suct' as frozen bearing, tight packing, mid-travel 3 g obstruction, torque switch failure, limit switch 8 failure, and post-accident operation. Each condition s
g
- has been reviewed to show that an adverse situation "8 results if the thermal overload relays in the circuit p
g j are bypassed. In conclusion, there appears to be no - V technical basis for bypassing or overstaing the a thermal overload relay provided it is selected e a a e s e r om ao correctly. Correct selection becomes simple once the Multiples of Overload Relay Trip Current operating fundamentals and characteristics of circuit breakers, thermal overload relays, and Mov's are Figure 2. Overload Relay Tirc - Current understood. 1d aid in the proper selection of Characteristics Adjustable thernal overload relsys, certain recommendations have Arnblent Compensated Type
- ^*
2291 F~ ,ee n made. These recca.enaations should h.1, sarery related Mov circuits in nuclear generating racinties.
ettninete all uncer taintie s leading to unreliable overload relays are either bypaswd or oversized to prevent operation of the MOV, and additionally, should result overload relays to unnecessary trip MOVs due to small over-b in an increased margin of sa f ety at nuclear power load conditions. plants. Cables, in this case, will have to be taken into special considera-tions when being sized. Abnormal locked rotor current or short circuit condition is beyond the bearable condition and should be isolated as E_ mzFERENCES soon as possible. 6 Failure of fuses or breakers to open a fault will result in a com-picte isolation of the MCC,however redundant equipment are therefore [& l11 R. for C. Fitzpatrick, " Standard Control Circuitry Motor Operated valves." Yankee Atomic required and are fed from an independent source. M: Electric Company Report No. YAEC-1066, October 31, 1972. [ Manuscript received February 25,1980. h 3 (2) A. N. Richards, C. D. Formica, " Motor Overload 9- Protection for Ptator Actuated valves." IEEE ,7 Paper No. F 79 669-3 presented at IEEE PES
- Summer Meeting, vancouver, July 1979. Farouk D. Baxter: I would like to thank Mr. Duong for taking the time . to comment on my paper. I will discuss his comments in the order E [3] U.S. Nuclear segulatory Commission Regulatory listed in his analysis. - Guide 1.106
Thermal Overload Protection for 1. I agree that thermal-magnetic breakers are not recommended for Electric Dtatora on Motor Operated valves.* motor operated valve circuits, this is because it may be difficult to
[ '. a provide adequate protection against overload heater burn out with
^ --
Farouk D. Baxter (M'68-SM'77) thermal-magntic breakers. De use of magnetic only breakers are I 4 hh p .
.N was born in Poona, 1937. He received the B. Tech.
India in preferred because they can improve heater protection. However, the practice of using thermal-magnetic breakers is 7 . 'M Degree in Electrical Engineering quite prevalent in the industry, and for this reasonIhave addressed 's I %,q 4 from the Indian Institute of them. My point was to emphasize that with or without thermal-hchnology, Kharagpur, India in magnetic breaken, nothing is gained by bypassing the thermal I J 3g; 1962. overload relay, Of 17 years 2. The dangers addressed in the paper will exist whether circuit h $ i his professional e xperie nce, all breakers or fuses are used. If fuses are used, the fuse must be sized have been associated with power to be unresponsive to locked rotor current drawn during motor f7 starting; therefore, when carrying a sustained locked rotor current, generattonr 15 years of these with the engineering, licensing, it remains questionable if the fuse would blow before the motor f' failed. De use of fuses does not eliminate the dangers associated cnd operation of nuclear power plants. Since 1969, hj
1 he has been with Yankee Atomic Electric Company where with the bypassing of thermal overload relays.
Additionally, the use of fuses introduces yet another hazard; he currently holds the position of Manager of A. Electrical Engineering. als r espons ibilitie s cover that of single-phasing. After the 1968 San Onofre fire which was attributed to single phasing, many utilities have avoided using f the full spectrum of electrical engineering (power) fuses m 39hase circuits. ? - as they agply to and interface with nuclear power
plants. 3. Iflocked rotor current is allowed to p4tsist,one can expect burn-R F Mr. Baxter is a registered professional engineer out or failufts of the thermal overload heaters, the motor, the
" in the States of Massachusetts and New Hampshire. He contactor, or the circuit breaker because these equipments may is a member of the IEEE PES Nuclear Power Engineering not be capable of operating continuously while carrying locked rotor current. Unfortunately, the failure or burn-out may not be (f I 6 .-
- Ccunmittee (NPEC) as well as Vice-Chairman of the NPEC Auxiliary Power Subcommittee. in fail-safe mode, and if not, the consequences could result m E decreased safety by r'ow requiring the incoming supply breaker to Z the MCC to open.
E- Discussion 4&5.Taking credit for the MCC incoming supply breaker trip resultsin i Quang 11. Duong (De Detroit Edison Co., Detroit, M1): The following a totally unacceptable design for the following reasons: j a. A!! other safety related equipment on that MCC will now be c' are comments on the analysis of the dangers: de<nergized due to a localized event on a branch circuit. H I. Normal practice is to use either magnetic-only type circuit b. Since the redundant MOV, powered from an independent h breakers or fuses and thermal overload relays to protect source, is designed to the same criteria, it must also be B MOV actuators. Dermal-rnagnetic breakers are not recom- assumed to fail in the same mode, that is, by tripping the 1 '( . mended to be used in cordunction with thermal overload MCC incoming breaker. A ccmmon mode design failure has i relays, therefore the analysis is unnecessary. now been introduced in the redundant component which is 7, 2. In case overload relays are bypassed: If fuses are utilized, contrary to the single failure criterion (see IEEE-379). l[ I, locked-rotor current when persists long enough will be in conclusion,it is the objective of n y paper to try to point out cleare<! by fuses. In case magneticenly type breakers are the dangers of this socalled " normal practice"of bypassing or over-j;w utilized, locked rotor current will eventually damage the sizing thermal overload relays. Regulatory Guide 1.106 position C.1 motor. Utilitation of fuses therefore is preferable. clearly states that "frovided that the completion of the safety function I- 3. In case overtoad relays are oversited: I.ocked-rotor curstnt is not jeopardired or that other safety systems are not degraded (a) the when persists longes than allowed, will be cleared by over- thermal overload protection devices should be continuously by-l load relays. passed . . . It should be quite clear frorn this position that the NRC is
4. Breakers or fuses are utilized to interrupt ana isolate a fault concemed with indiscriminate, bypassing of thermal overload relays l- should a short circuit occur. If they fail to trip open in- which could result in a decrease of overall nuclear plant safety. With I coming breaker feeding the MCC is next to trip. Overload the help of my paper. licensees can now make a determination whether l? relays, as the name represents, are not designed to operate on or not they should bypass thermal overload relays. Furthermore, be-Ik a short circuit. Contactors are not rated or designed to inter- cause of the recognized dangers of bypassing thermal overload relays,
' J b rupt short circu;t currents. the NRC have provided in their Regulatory Guide 1.106, an alternative T 1 F De reliability of Oc safety system will not be decreased position C2 which advocates the use of thermal overload relays for both b- as written in 4a, by eliminating the thermal overload relay. normal and safety functions.
s 5. In conclusion, overload heaters ar normally selected to y operate at '25% FLA st its normal ambient temperature.In Manuscript received AprG 2,1980. r r i a i
i 430.51 Section 8.3.1.1.g of the FSAR indicates thermal overload relays
-/ (8.3.1) will also be installed in continuous duty motors. Describe the (8.3.2) periodic testing to be performed and the capability to test the overload relays in accordance with GDC 18.
RESPONSE: Because of the nature of application of the continuous duty motors such as pumps, fans, etc., misoperation or misapplication of thermal overload relays will be detected in time by either alarm or other process signals and corrective action will be taken. Redundant motors that might be on a standby mode will be periodically rotated so that any abnormal condition will be again detected. For the above reasons and with the exception of the regular maintenance program under ANS1 N18.7-1976, no specific surveillance program will be specified in the Technical Specifications for the thermal overload relays of the continuous duty motors.
?. special case though exists for the continuous duty motors inside containment. Because the thermal overload protection for continuous duty motors located inside containment is part of the design provided to satisfy the requirements of Regulatory Guide 1.63 for containment electrical penetrations, the thermal relays will be periodically tested as defined by the Technical Specification Section 3.8.3.1 (please refer to Appendix A of the FSAR for Technical Specifications).
O i i #S l G l
430.52 Proposed NRC Standard Technica? Specification Action and O- (8.3.1) Surveillance Requirements for thermal overload protection on (8.3.2) valves or continuous duty motors are as follows: ACTION: With the thermal overload protection for one or more of the above required valves inoperable, bypass the inoperable thermal overload within 8 hours; restore the inoperable thermal overload to OPERABLE status within 30 days or declare the affected valve (s) inoperable and apply the appropriate ACTION statement (s) for the affected system (s). SURVEILLANCE REQUIREMENTS 4.8.3.2 The thermal overload protection for the above required valves shall be demonstrated OPERABLE at least once per 18 months and following maintenance on the motor starter by the performance of a CHANNEL CALIBRATION of a representative sample of at least 25% of all thermal overloads for the above required valves. Provide comments or propose alternative Technical Specifications. RESPONSE: In regards to the surveillance requirements for thermal overload protection on valve motors, we are complying with Position C2 of Regulatory Guide 1.106, Revision 1. Our Technical Specifications O have been developed accordingly; see Technical Specification Section 3.8.3.2. Please refer also to the response of RAI #430.48 for further clarification. For surveillance requirements of thermal overload protection _used on continuous duty motors, see response to RAI #430.51. 3
I 1 l SB 1 & 2
! FSAR i RAI 430.53 Describe how the Seabrook design complies with the guidelines of NUREG-0737 f.
. iten II.E.3.1 and II.G.I. i j _ RESPONSE: The requested information has been provided in our letter SBN-212 to the NRC
, dated February 12, 1962, to the Attention of: Mr. F. Miraglia, Chief j Licensing Branch #3.
i s f j i l 1 i O i t O
I S3 1 & 2 1 FSAR RAI 430.54 Section 8.3.1.2.b.4 of the FSAR indicates. that instrumentation and low energy circuits are not provided with redundant overload protection devices. Define low energy circuits and justify non-compliance with the guidelines of regulatory guide 1.63. i
RESPONSE
Low energy circuits are those energized by devices that are inherently i energy self-limiting (e.g. control transformers or instrumentation current / voltage loop pover suppies etc). Regulatory Guide 1.63 is satisfied because short circuit would result in an energy level which is sufficiently low as to preclude damage to the electrical penetration seal. l I J O 4 t i e l i l O
i ! t i SB 1 & 2 : FSAR l Ga 6 I RAI 430.55 ; Provide coordinated fault-current versus time curves for each representative type cable that penetrates primary containment. For each cable, the curves must show the relationship of the fault carrying capability between the electric penetrations, the primary overcurrent protective device, and the ( backup overcurrent protective device. l t
RESPONSE
Refer to revised FSAR pages 8.3-3 and 8.3-9 and new Figures 8.3-46, 8.3-47, l 8.3-48 and 8.3-49. The coordination curves shown on these figures represent i typical electrical penetration protection for the Seabrook Station. ! i r l i O i co l i l
( i SB 1 & 2 FSAR pump motors. These fuses are located in a seismic Category I building and are part of the protection for the containment electrical penetrations as required by Regulatory Guide 1.53. In addition, a measure of backup protection is provided by the rea?. tor coolant pump circuit breaker and the 13.8 kV bus incomit.g line circuit breaker. DC control power from separate battery sources is provided for these breakers to preclude the loss of a single de source from preventing the tripping of both the RCP and the incoming line breaker. For the penetration protection coordination curve, see Figure 8.3-46.
b. 4160 Volt Distribution System

1. Arrangement The 4160 volt distribution system for each unit is shown in Figures 8.3-1, 8.3-7, 8.3-8, and 8.3-9. For each unit, the system consists of four buses, two of which are the redundant Class IE emergency buses supplying the redundant engineered safety features loads. These safety loads are divided into two separate and independent Trains A and B, as shown on
(~'T Figures 8.3-8 and 8.3-9. The preferred power supply to each
\- / 4160 volt bus is from a UAT. An alternate source is available to each bus through a RAT. A standby power supply, consisting of a diesel generator, is available to each emergency bus.
Buses E5 and E6 are the equipment designations of the redun-dant Class 1E buses. Redundant Class IE Buses E5 and E6 are located in completely separate, but . adjacent rooms in the seismic Category I control
. building, as snown on Figure 8.3-27. Buses E5 and E6 are connected to the auxiliary transformers via non-Class 1E non-segregated phase bus duct.
The bus duct is supported by seismically qualified supports in the control building. Taps in the bus duct provide the power to non-safety-related Buses 3 and 4 from the bus duct runs to Buses E5 and E6, respectively. The tie between the non-safety related bus ducts and the Class IE switchgear is through Class 1E air circuit breakers.
2. Switchgear All Class 1E switchgear has identical electrical ratings:
(a) Buses - 2000 ampere continuous rating, braced for 80,000 amperes momentary. (O
,/ (b) Incoming line breakers - 2000 ampere continuous rating, 350 MVA nominal interrupting capacity.
8.3-3_ _ _ _ _ _ _ _
m. _
SB 1 & 2 FSAR
7. Special 480 Volt Circuits l
(a) Protection of Containment Electrical Penetrations The Class IE and non-Class IE 480 volt unit substations, 460 volt motor control centers and the distribution panels which feed loads inside the containment are all qualified to meet Class IE requirements and are located ! in seismic Category I structures. 460 volt loads inside ! the containment are fed from distribution equipment with special provisions to satisfy the requirements of Regulatory Guide 1.63 for containment electrical penetration protection. These provisions are outlined , below. Motor control . center units feeding in-containment motors less than 5 hp are equipped with two combination motor starters in series. Larger motors are supplied from MCC units having a thermal magnetic breaker in series with a combination motor starter. Other feeders for containment loads fed from MCC units are equipped with two thermal magnetic breakers in series, plus a con-p tactor as required. See Figures 8.3-48 and 3.3-49 for Q typical curves. 460 volt distribution panels feeding in containment loads are equipped with two thermal magnetic molded case breakers in series to protect the containment electricEl penetration. 460 volt loads inside the containment, which are fed directly from the 480 volt unit substations, satisfy the requirements of Regulatory Guide 1.63 by utilizing the load breaker as pricary protection and the unit substation incoming feeder breaker as backup protection. See Figure 8.3-47 for an example. l 460 volt loads inside the containment which are normally used only during shutdown (e.g. , cranes, refueling machines, welding receptacles, etc.) are not provided with redundant protection because their circuits are de-energized and padlocked at the unit substation or motor control center during normal plant operation.
Note that some of these circuits cay be required for brief durations during plant operation such as prior to or after refueling outages. Lack of redundant protec-i tion is justified because of the very limited usage l in this mode, and the fact that such usage will be under l Q administrctive control.
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SB 1 & 2 FSAR O v RAI 430.56 Provide the test report with results that substantiates the capability of the electrical penetration to withstand the total range of time versus fault current without seal failure for worst case environmental conditions.
RESPONSE
The ability of the containment electrical penetration assemblies to meet specified 12 t values under worst case environmental conditions was demonstrated by test. The test results are swamarized below: A. Low Voltage Penetration Extractions from the Addendum to the penetration vendor's report, PEN-TR-77-59, dated November 11, 1977 -- Report on the rated maximum duration of rated short-circuit current test, is shown as Exhibit 430.56-1. B. Medium Voltage Penetration Extractions from the penetration vendor's report, PEN-TR-78-22, Revision 3, dated July 3, 1979 - The qualification of modular type O medium voltage electrical penetrations following the requirements of IEEE Standard 317-1976 and Standard 323-1974 for use in PWR and BWR, is shown as Exhibit 430.56-2. C. Electrical Penetration 1 t2 Curves The penetration vendor's test reports, PEN-TR-77-68, dated June 29,1981 - Electrical Penetration Pigtail I 2 t Curves and Addendum to PEN-TR-77-68, dated June 29, 1981 -- Additional I2 t Information for Seabrook Station, is shown as Exhibit 430.56-3 and 430.56-4. t O l
SB 1 & 2 FSAR O EXHIBIT 430.56-1 1.0 EQUIPMENT PERFORMANCE SPECIFICATION The test followed the requirements of IEEE Standard 317-1976, Part 6.4.14, and AEC Regulatory Guide 1.63, October 1973. 2.0 SPECIFIC FEATURES TO BE DEMONSTRATED BY THE TEST The ability of the herein described nuclear penetration prototype modules to withstand the rated maximum duration of rated short-circuit test without loss of containment integrity will be demonstrated. 3.0 TEST PLAN 3.1 Equipment Description The two modules tested are the same modules that were subjected to and passed all prior IEEE Standard 317-1976 prototype tests including DBE. It is important to note that "it is not the intent of Section 6.4.13 and 6.4.14 (of IEEE Standard 317) to require that an assembly be subjected to more than one qualification test O _ situation where it would be exposed to design basis maximum postulated accident event conditions." Because the modules performed so well during and after all other prototype tests including DBE, it was decided to see'if they would also survive the rated maximum duration of rated short-circuit current test. i 3.2 Service Conditions to be Simulated Rated maximum duration of rated short circuit current et 2900F (1430C) at 78 psig. This temperature simulates the penetrati4.s temperature during a LOCA which produces of 3400F ambient in the
, containment.
3.3 Performance Limits Gas leakage: Through leakage must be equal to or less than l 1 x 10-2 Std-cc/see (dry nitrogen) at rated pressure during and } after the test. Electrical integrity need not be maintained. l l i f%.-
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SB 1 & 2 FSAR 4.0 REPORT OF TEST RESULTS 4.1 Test Procedure 4.1.1 Rated Maximum Duration of Rated Short-Circuit Current Test This test was performed'in the high power lab at the Westinghouse Low Voltage Breaker Division, Beaver, Pa. The modules were installed and secured in a test mounting collar in the same manner as they would be sealed into a bulkhead. Three cables of the same size were connected together at the inboard side of the module and their extensions on the outboard side were secured to the three phase power source. The inboard side of the module and the inboard cables were wrapped with heating tape and heated to 2900F, the temperature they would attain during a 3400F DBd. The monitoring volume of the module was pressurized to ' 78 PSIG. After programming the power source to produce the required amount of c.urrent for the ptsper number of cycles (bolted fault), the unit was turned on, thereby delivering the faulted current to the (~' cables. At the conclusion of the test performed on the first triad of wires, the second group was connected and the test repeated. This procedure was continued until all the required cable size of both modules has been tested. 4.1.2 Gas Leak Rate and Pneumatic Pressure Test The modules' containment integrity was verified during the test by-observing any loss in monitoring volume pressure. The modules' containment integrity was verified dfter the rated maximum duration of rated short-circuit current. . 4.2 Test Results and Data 4.2.1 Rated Maximum Duration of Rated Short-Circuit Current Test Cable Symmetric Asymmetric Peak X/R Duration 2 1e Size (Amps) (Amps) (Amps) Ratio Cycles (Amp)2(see) 1 BFI 35,100 38,300 74,000 4 30 6.2E8 1 1 , 350 KCMIL2 33,100 34,600 68,200 2.7 23 4.3E8 i 1 -g 350 KCMIL 33,200 35,200 69,200 3.0 30 5.5E8 m) er i
4 SB 1 & 2 FSAR Cable nmaetric Asymmetric Peak X/R Duration 2 1e Size Sy(Amps) (Amps) (Amps) Ratio Cycles (Amp)2(gec) , BF 30,300 33,600 62,709 4.4 18 2.8E8 250 KCMIL3 29,600 32,300 58,400 3.8 17 2.5E8 250 KCMIL4 29,400 31,400 61,300 3.3 17 2.5E8 , 250 KCMIL 29,300 32,000 62,000 3.8 18 2.6E8 ; 1/0 29,200 32,200 60,700 4.1 4.32 6.1E7 BF 26,100 28,800 53,000 4.3 2.64 3.0E7 ,
#2 24,300 26,900 50,000 4.2 2.64 2.6E7 '
BF 16,000 17,900 33,200 4.6 2.58 1.1E7 ! #4 15,300 16,200 30,700 3.0 2.58 1.0E7 l BF 4,200 4,700 8,700 4.9 2.28 6.7E5
#10 4,200 4,500 8,400 3.3 2.28 6.7ES BF 2,500 2,700 5,100 4.0 2.4 2.5E5 #12 2,100 2,200 4,100 3.3 2.4 1.8E5 NOTE 1: The BF readings are the bolted fault current available to the wire sizes following in the table. ,
i NOTE 2: The first attempt at shooting the 350 KCMIL triad resulted in the fusing of the external terminals on two phases at the module power supply interface after 14.5 cycles. These terminals are rated for 250 KCMIL and 350 KCMIL use. The second 350 KCMIL shot was run 10 minutes after the first. The two shots coupled with the inboard DBE temperature was sufficient to cause a leak (20 x 10-2 j i Std-cc/sec) between the inboard side and the monitoring volume. ! , The leak, however, is not a through leak. j NOTE 3: One wire was blown out; of the external connection after 6.5 i and 4: cycles. The shot was' repeated. The same wire was again blown out ! at this same connection after 5 cycles. Sufficient time was i allowed between the three 250 KCMIL shots such that the excessive temperature that developed ia the case of the 350 KCMIL test was not repeated. J
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; SB 1 & 2 f
.; FSAR i ! 4.2.2 Gas Leak Rate and Pneumatic Pressure Test ! There was no through leakage detected during or followng the rated . maximum duration of rated short circuit current test. t
5.0 CONCLUSION
The results of this test in conjunction with the results of other ! i tests confirm that the prototype penetrations meet the ! requirements of IEEE Standard 317-1976 and IEEE Standard 323-1974. 1 This design can, therefore, be classified IE. ! i The ratings determined by ti is test can be used to match the circuit overload protection system as required by Reg. Guide 1.63 ! October 1973. I l i t l t l. f 4 O l
a SB 1 & 2 i FSAR O i i , EXHIBIT 430.56-2 1.0 EQUIPMENT PERFORMANCE SPECIFICATION !
The tests followed the requirements of IEEE Standard 317-1976 and i
323-1974. { i 2.0 SPECIFIC FEATURES TO BE DEMONSTRATED BY THE TESTS ! r The ability of the herein described medium voltage nuclear } penetration prototype modules to withstand the qualification tests ! specified in Section 6.4 of IEEE Standard 317-1976, and still ; function electrically and as a pressure barrier, will be t demonstrated. l 3.0 TEST PLAN 3.1 Equipment Description i A medium voltage electric penetration module assembly consists of a single conductor having a rated value above 1000 Volts, , terminated at one end by a primary seal and at the other end by a i secondary seal. The primary seal, when secured in its bulkhead aperture, allows for the passage of electric current and voltage , through the wall of a nuclear containment vessel without l compromising the integrity of the pressure boundary. The spiral ' path to the conductor seal allows for the continuous monitoring of the primary module's gas leakage rate. The secondary seal functions as a fire barrier and can be used to maintain a slight pressure differential when required as well as a means of connecting the penetration to the field cabling. { The medium voltage assembly can be composed of many different j module combinations in various size nozzles. The configuration l chosen in which to perform this qualification test was the three ( module 12" nozzle arrangement. It was selected because the , maximum mechanical forces are generated during short circuit j testing due to the inter-module spacing. l 1 Due to the length of the completed module assembly and the l necessity of performing some of the tests in an oven, the initial I part of the program was performed on the three primary modules each containing a 10" length of 1000 KCMIL cable attached to its bushing rather than the 7 feet of cable and secondary seal. This procedure does not detract from the intent of the program for the primary modules contain the containment seal. O
SB 1 & 2 FSAR O I The retaining ring of two of the primary modules were made of stainless steel while the third module's was made of epoxy. They were constructed of these dissimilar materials in order to test their ability to function as a retaining ring. 3.2 Number of Units to be Tested One penetration assembly comprised of three module assemblies has been tested. The module assemblies are identified as - Primary Module No. Secondary Module No. Identification 11 8 11-8 6 9 6-9 2* 4 2-4
Epoxy Retaining Ring 4.4.4 Rated Short-Time Overload Current Test O This test was performed in the high power lab. at the Westinghouse Low Voltage Breaker Division, Beaver, Pa.
The secondary modules (8 and 9) of module assemblies 11-8 and 6-9 were connected together with a copper bar. The primary modules (11 and 6) were connected to the proper source. The' overload current was introduced. The copper bar was then placed between secondary modules 4 and 9' connecting together module assemblies 2-4 and 6-9. Primary modules 2 and 6 were connected to the current source and the overload current applied. By this method, module assemblies 11-8 and 2-4 were subjected to one and 6-9 to two rated short-time overload current tests. The cable jacket temperature of 6-9 was measured by menas of thermocouple. Comment The Seabrook requirement is 1700 AMP for 32 seconds for an I2e value of 9.25E7. Starting at 900C, the condu*ctor temperature was found to reach 1180C for 4200 AMPS for 82 see, well below the 13000 specified. Thus the penetration can be rated for an 1 2t value of 1.45E9. 4.4.5 Short-Circuit Current and Duration Test N This test was performed in the high power lab. at' the Westinghouse {'s) s_ Low Voltage Breaker Division, Beaver, Pa.
l t SB 1 & 2 l FSAR The three phases of the current source were shorted together. The source was then programmied to deliver the required amount of current for the proper number of cycles. The unit was turned on, thereby producing a bolted fault. I The shorting bars were then removed from the current source output 1 and each of the three module assemblies was connected to a phase of the current source through a 5 foot length of 1000 KCMIL cable. l The three 5 foot lengths were tied together approximately 3 feet ' from the connection to the medium voltage penetration assembly to simulate the tie down of field cables at an installation. l h A 3 foot length of 1000 KCMIL was connected to each secondary j module at one end and to each other at the other end through a copper block to form the short. The copper block was then i grounded. The current source was turned on, subjecting the medium ! voltage assembly to the same programmed conditions at the bolted ' fault. 6 6 Conanent j The penetration is rated at 53.5 (sym) KA, 123.7 (peak) KA, 79 l l (rms asyn.) KA for 19 cycles. 12t = 9.06E8. The Seabrook requirements is 20 kA (sym) for 8 cycles with X/R ratio of 24 which-produces a first loop peak of 2.55'x 20 kA = j 51 kA. Since the first loop peak developed in the test was 123.7 kA, ample mechanical strength was demonstated.
The max duration requirement is an 12 t value of 1.2E9. The penetration was shown to be capable of an I2 t value of 1.45E9 so !
the Seabrook requirement is met. ' l The force developed in the short circuit test was sufficient to crack the epoxy retaining ring off the primary module of module , j assembly 2-4. The two module assemblies with metal retaining l rings were undisturbed. The bulkhead assembly containing the ( i three module assembly leaked. It is strongly felt that the ! l 1eakage was caused by the movement of module assembly 2-4, once it l was allowed to move with no retaining ring to keep it secured in : its aperture seal. ! Comment , l, ! The Seabrook penetrations have been supplied with a metal i retaining ring and not the expoxy type which failed during short !
, circuit test. !
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l l 1 SB 1 & 2
<) l 4.4.7 Design Basis Event-Rated Continuous Current Test The three module assemblies were removed from the seismic test i assembly and installed in the design basis event, 6 foot long '
bulkhead-nozzle assembly. This assembly contains a 19" diameter , flange on the secondary module end for the purpose of sealing the ' nozzle to the steam chamber. The assembly also contains cable support tubes. The bulkhead, containing the three primary modules, was pressurized with dry nitrogen to 67 psig and leak tested. dielectric strength, insulation resistance and contact resistance ' readings were taken. P Secondary modules 8 and 9 were connected together with a copper bar. An elastomer cap was placed over the third secondary module (4) to prevent the exposed connector from breaking down to the steam chamber wall. I The medium voltage bulkhead-nozzle assembly was wrapped with i insulation and sealed to the steam chamber. O The bulkhead, and therefore the monitoring volumes of the three primary modules, was pressurized with dry nitrogen to 15 psig.
' Module assembly 2-4 was placed at 15 kVac to ground and a continuous current of 600 AMP ac was run through module assemblies 11-8 and 6-9. ;
The medium voltage bulkhead-nozzle assembly was then subjected to l the following LOCA conditions. The medium voltage bulkhead-nozzle assembly was then subjected to the following LOCA conditions. Time Steam Temperature (OF) Steam Pressere (psig) 3 hours 343 Ill i l 3 hours 326 84 32 days 280 32 NOTE: The conductivity of the treated steam averaged 3600 umhos/cm throughout DBE. The conductivity of borated water (8.5 ph) is ' 900 mhos/cm. O
I SB 1 & 2 FSAR O At the conclusion of the design basis event-rated continuous current test, the modules, installed in the bulkhead, were , pressure leak tested with dry nitrogren at 59 psig. Dielectric l Strength and Contact Resistance readings were taken. ' Comment i Rated maximum duration of rated short current test is required to be performed at max postulated design basis event, temperature, pressure and relative humidity. The short time overload test found that an 12t value 20% greater than the Seabrook max duration requirement, produced an increase in insulation temperature of only 280C. As DBE test was performed at 1730C, 370C higher than the required 1360C it can be concluded that the penetration seal will readily survive an I t2 value which produces a 280C increment. 4.5 Test Results and Data 4.5.1 Gas Leak Rate and Pneumatic Pressure Test () There was no leakage detected prior t-i qualification testing (10-6 Std.-cc/sec. range) and at the conclusion of qualification testing (10-2 Std.-ec/sec.). i During DBE, due to the small monitoring volume, the assembly had to be repressurized several times. The leak rate, h6 wever, over the entire 744 hours was never greater than the 10-3 Std.-cc/sec. l range. The following total leak rates that includes gas absorption were ! J measured on the penetration assembly after the inicated tests. i Test After Pressure (PSIG) Leak Rate (Std.-cc/sec) , Aging 64 1.9 x 10-4 ; Radiation 59 1.0 x 10-4 Seismic 57.5 5.9 x 10-5 , DBE 59 3.0 x 10-4 ; 1
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SB 1 & 2 FSAR O , EXHIBIT 430.56-3 Westinghouse Electronic Components Westinghouse Circle Electric Corporation Divisions Horseheads New York 14845 PEN-TR-77-68 - l August 19, 1977 Revised December 20, 1977 ' Revised November 18, 1979 - Revised March 12,1980 Revised July 7,1980 Revised October 29, 1980 Revised January 26, 1981 () Revised June 29,1981 P ELECTRICAL PENETRATION PIGTAIL I2 CURVES i R. L. Korner Project Engineer i
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l l SB 1 & 2 FSAR i ELECTRICAL PENETRATION PIGTAIL I2t CURVES Normal Environment Conditions ) T'ae curves shown represent the short circuit rating of the penetration pigtails 4 at 900C experiencing a short circuit and reaching 2500C as a maximum 'during the short circuit. Only the portions of the curves below 10 seconds are valid for
this rating. (See explanation in Appendix).
{ Tests were conducted at the highest value of synenetrical current shown on each curve. First Loop Peak Current The table below gives the peak current that the circuit delivered to the penetration during the first half cycle of the short circuit current. Conductor Peak Current Size Amp
#12 5500 #10 8340 #4 55500 #2 46200 #1/0 46200 250 47800 350 60000 1000 127500 The conductors can withstand the mechanical force produced by the peak current given in the table and the thermal I t2values shown on the curves.
As the tests on conductor sizes #12 thru 350MCM were performed at an X/R ratio of 4, the symmetrical current rating can be adjusted for other X/R ratios. O 7.
SB 1 & 2 FSAR X/R Ratio Multiplier 4 1 6 0.92 8 0.88 10 0.85 The test on the 1000 MCM conductor was performed at an X/R ratio of 8.5. If a greater X/R ratio is required, the synenetrical current rating should be adjusted as follows: X/R Ratio Multiplier 8.5 1 16 .93 LOCA Conditions O During LOCA conditions the electrical penetration must be able to withstand a short circuit current for maximum duration without damage to the seal. The entire curve is applicable for this rating (maximum duration of rated short circuit current). For a given size conductor note that the same curve applies for both short circuit requirements i.e. at LOCA and at normal environment. l
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1 SB 1 & 2 FSAR APPENDIX PEN-TR-77-68 Explanation of the 10 Second Limitation in Report PEN-TR-77-68 The 10 second limitation for rated short circuit current applies only to the penetration pigtail. The seal conductor inside the penetration will maintain electrical and mechanical integrity for all time durations shown. The curves shown in the report should be interpreted so that if a short circuit occurs with a duration over 10 seconds, some degradation of the pigtail insulation would occur. The longer the short circuit duration, the more severe the damage. Under normal conditions, a short circuit current will exceed 10 second duration only if the primary breaker fails to open. If such an event occurs, the pigtails of the circuit should be examined for possible damage. I O . 99 l L r G
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i i SB 1 & 2 : FSAR O l EXHIBIT 430.56-4 Westinghouse Circle l Westinghouse Electronic Components Horseheads New York 14845 ; Electric Corporation Divisions (607) 796-3211 l ADDENDUM TO PEN-TR-77-68 ! t i' June 29,1981 i i. t I ADDITIONAL I 2t INFORMATION f FOL SEABROOK STATION f i t O ! W. Lankenau f Contract Engineer I i e v i f 1 < i s h I i J l I i 4
SB 1 & 2 FSAR
1. NORMAL AND LOCA ENVIRONMENTS DURING TEST COMPARED WITH SEABROOi' ENVIRONMENT 4
A. The short circuit tests were initiated with the cables at the j maximum allowable temperature of 900C for normal operation.
; The normal operating temperature of the cable for Seabrook is 900C j or less.
B. The short circuit test during the simulated LOCA was conducted with the penetration module at 2900F, the temperature the module would reach after 1 hour in a 3400F environment. The module was pressurized at 78 PSIG. 4 The Seabrook LOCA environment is 11 seconds at 2960F, 4.7 hours at 278 0F and one year at 1600F. The module would never reach 2900F with this profile.
! The maximum pressure is 52 psig, i
j II. The tests were conducted using a combination of Anaconda Durasheath EP and Okonite Okolon power and control cables. Both of these style p) cables are ethylene propylene rubber insulated with a chlorousulfonated i
\,, polyethylene jacket, the same composition as the cable being supplied on the Seabrook contract.
4 i
i I () 430.57 Section 8.1.5.3.b indicates that the Seabrook design does not comply with Position 15 of Regulatory Guide 1.75 (Revision 2). Four independent batteries are not served by four independent ; ventilation systems as recommended. Two ventilation systems are i I provided with a cross-tie so that one ventilation system can serve all four batteries. Justify non-compliance. f RESPONSE: The paragraph on Battery Room Ventilation in Section 8.1.5.3.b was not intended to imply non-compliance but was actually a clarification on the Seabrook system to show compliance. The t paragraph will be revised as follows:
2. Battery Room Ventilation Although the four Class lE batteries are housed >
in separate safety class structures, they represent only two redundant load groups (see Section 8.3.2). Each load group is served by a separate safety-related ventilation system. There is a cross-tie between the two ventilation systems to allow one system to serve both load groups in case the other system is inoperable. Fire dampers are provided to isolate each battery room. fg For additional information on the four batteries and two ( j redundant load groups, see the response to Question 430.37. h A l O v i
SB 1 & 2 O FSAR RAI 430.58 The battery room ventilation system is powered from an ac power source. Describe the capability of the battery and the de system to function for two hours without ventilation.
RESPONSE
As discussed in RAI 430.57, the battery rooms are served by two separate ventilation systems with a cross-tie between systems to ensure availability of ventilation. The separate ventilation systems are powered from separate redundant safety buses. In the unlikely event that ventilation is lost, the batteries are capable of perfo ming their function for two hours. Ventilation is not necessary during the two-hour time that the battery is providing its discharge current, because no hydrogen is generated during discharge. l O
85 1 & 2 FSAR O RAI 430.59 Section 8.1.5.3.b of the FSAR indicates that the Seabrook design does not , comply with Po'ition s 1 of Regulatory Guide 1.75 Revision 2. Justify the i non-compliance.I RESPONSEt Section 8.i.5. 3.b of the FSAR was erroneous and has been revised in response toRAI430.404 Seabrook complies with position 1 of Regulatory Guide 1.75, Revision 2. See response to RAI 430.40A for further details. O 9 l O 1
i SB 1 & 2 FSAR O4 RAI 430.60 Provide the results of an analysis that demonstrates that the requirements l of GDC 2 and 4 met with respect to structures, systems and components of the j onsite ac and de power systems being capable of withstanding the effects of natural phenomena (such as earthquake, tornadoes, hurricanes and floods) and missiles and environmental conditions associated with normal operation and postulated accidents. Provide a definitive statement in Section 8.3.1 and 8.3.2 of the FSAR that the onsite ac and oc power system and components (1) are located in seismic Category I structures which provide protection from the effect of tornadoes, tornado missiles, turbine missiles and external floods; (2) have been given a quality assurance aesignations Class IE, (3) have been designated to be seismically and environmentally qualified and (4) are to be designed to accommodate or are to be protected from the effects of missiles and environmental conditions associated with normal operation and postulated accidents.
RESPONSE
The design of the onsite ac and de power systems meet the requirements of General Design Criteria 2, Design Bases for Protection against Natural Phenomena, and GDC 4 Environmental and Missile Design Bases. Section 8.1.5.1 has been revised to incorporate reference to GDC 2 and 4. Sections 8.3.1.2a and 8.3.2.2a have been revised to incorporate references to and provide definitive statements regarding compliance with GDC 2 and 4. d l i { O
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GDC-17 Electric Power Systems p a sip GDC-18 Inspection and Testing of Electric Power Systems [ 8.1.5.2 Institute of E1 etrical and Electronic EnEineers (IEEE) standards j
'the electric Power systems are in conformance with the following standards: ;
IEEE sed. 1 - 1969 " General Principals for Temperature Limits in the Rating of Electrical Equipment" , IEEE 8td. % - 1969 " General Principals for Rating Electrical Apparatus f
,for short-Time, Intermittent, or Varying Duty" l IEEE Std. 142 - 1972 "Recoussended Practice for Grounding of Industrial and Coussercial Power System" (IEEE Green Book)
IEEE 8td. 279 - 1971 " Criteria for Protection Systems for Nuclear Power Generating Stations" l IEEE Std; 288 - 1969 " Guide for Induction Motor Protection" : IEEE std. 308 - 1971 " Standard criteria for Class 11 Electric Systans for Wuclear Power Generating 8tations" k ! IEEE Std. 317 - 1972 " Electric Penetration Assemblies in Containment l Structures for Nuclear Power Generating stations" ; IEEE 8td. 323 - 1974 " Standard for Qualifying Class IE Equipment for l' Nuclear Power Generating Stations" ~ Refer to Subsection 3.11.2 for discussion of this ! standard. l r IEEE Std. 334 - 1971 " Trial-Use Guide for Type Tests of Continuous-Duty I' class 1 Motors Installed Inside the containment of Nuclear Power Generating'8tations" j IEEE Std. 336 - 1971 " Installation, Inspection and Testing Requirements ! for Instrumentation and Electric Equipment During the j Construction of Nuclear Power Generating Stations" IEEE Std. 338 - 1975 " Criteria for the Periodic Testing of Nuclear Power GeneratinE 8tation Protection Systems" -- Refer to ' Subsection 7.1.2.11 for discussion of this standard. IEEE Std. 344 - 1975 " Guide for Seismic Qualification of Class 1 Electric Equipment for Nuclear Power Generating Statione"
- Refer to section 3.10 for discussion of this standard.
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P.es7 as.22 'es 21:02 eMT SEEsROOK STRTION - r763 X SB1&2 FSAR cooling water eystes can be accouplished, assuming a single failure. Ttro independent power trains at each distribution voltage level supply redundant load groups with power during normal, abnormal and post-accident conditions. These load - groups comprise engineered safety features and protection systems in such a way that loss of one group does not pre-vent the minimis safety function from being performed. I b. ,C,ompliance with Appifcable Eszulatory Guides
1. Regulatory Guide 1.6 - Independence Between Redundant ,
d Standby Power sources l h , Two diesel generators constitute the ac standby power sources f r as h unit. Each diesel generator serves as the standby (Niggy A, power supply for a redundant load group. In addition, each
, redundant load gecup is connected to the preferred (offsite) 4 $,, power supply through different t)ATs or RATS. The design of Ig gggy pach unit is based on the concept of independent, redundant groups of engineered safety feature loads and, as such, one redundant load group or power source is never automatically connected to the other redundant load group or power source.
O (See Figures 8.3-1 and 8.3-3)
2. Regulatory Guide 1.9 - Selection of Diesel-Cenerator see
Capacity for Standby Fosser Supplies Each diesel generator set has been selected on the basis that the total running load at any time will not exceed the short time rating of the diesel generator.
During preoperational testing, the maximum continuous load demand will be verified by tests. Each diesel generator is capable of starting and accelerating all Class 1E loads to rated speed, in the required sequence. The excitation and govenor controls furnished for the diesel generators are designed so that, during and af ter sequential loading of Class 1E loads, the voltage and frequency decrease to no less than 80% and 95% of nominal values, respectively. The voltage any dip to less than 8Q% of nominal value when the diesel generator breaker closes and energises the 1000/ 1333 kVA, 4160/480 V unit substation transformers. The diesel generators are designed to recover from this dip (due to transformer magnetisin5 inrush current) to at least 80% of nominal value in about 6 cycles, causing a negligible delay to the acceleration of the first load group. O 8.3-26 h ' SAntf- 3 4 7
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t i 5 Criterion 2 Desian Bases for Protection Anainst Waveral Phenomena i
1. m ' components of the onsite ac power system are located in seismic l Category I structures which provide ptotection from the affects of l tornadoes and external ficods, and other natural phenomena. l

2. h ee components are Class II ;

3. These components have been designed to be fully qualified for the !
saismic and natural enviromaantal conditions appropriate to their : i location. See Section 3.11. i I l O -
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IIVISICE TC 8.3.1.2a continued
6. , Criterion 4 _EnvirousentQ ajd Missile Design Bases

1. The components of the onsite ac power systen are located in seismic catagory I stmetures which provide protection from the effects of 3
tornedo missiles, turbina missiles and other events and conditions
, which may occur outside the nuciaar power unit. ,
2. These components are class II.

3. These components are, designed to accounodata the efffects of and be compatible with or are protected against the environeantal conditions associated with normal operation, maintenance, testing, and postulated accidents including loss of coolant accidents. Criteria are presented in Chapter 3. Environmental conditions are presented in Chapter 3 and 6.

4. These conponents are protected. as appropriate, against dynsmic effects, including the effects of missiles, pipe Whipping, and discharging fluids that may result from equipment failures (po'stulated accidents,).
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e. DC power Systes Testina I
The betteries and o.ther equipment associated with the de system are easily accessible for routine testing and inspection. Surveillance
and testing are performed in accordance with the plant Technical ,
i Specifications in compliance with the guidelines of IgEE Standard 450 and Esgulatory Guide 1.129. ; The preoperational testing of the safety related portion of the I de system will be performed in accordance with Regulatory Guides 1.68 and 1.41. , i
f. surveillance and Monitoring i j
The operator is provided with Indications and alarms for monitoring the state of the de system as listed in Table 8.3-6. j 8.3.2.2 Analysis ; The DC System Failure Mode and If fact Analynis is found in Table 6.3-7.
a. Compliance with General Desian Celteris _
Criterion 5 - sharina of _systeas and Components i No portion of the station dc system or its components important " a # to safety is shared between units. g(N , e 4 Criterion 17 - Electric power systems Compliance with the requirements of the "de portion of .the l flgf electric power supplies criterion and the associated independence, redundancy and testability are covered by subsections 8.3.2.1b ( l through 8.3.2.le. . The station safety related de power system provides separate and. independent de power supplies and channels for redundant - load groups during abnormal and accident conditions. Wese redundant load groups comprise engineered safety features , i and plant protection systems, grouped in such a way that
. loss of one group does not prevent the minissam safety functions of redundant groups from being performed. In the event of loss of de power from the chargers, the batterlea pick up the load l on the de buses.
Criterion 18 - Inspec_ tion and Testing of Electric power Systems , he Class 1E de electric equipment is desi'gned and located n v so as to permit appropriate periodic inspection and testing, in line with the provisions for testing listed in Subsection 8.3.2.le. , 11 ; 8.3-40 *T )Q*b0 '
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h. Criterion 2 Desian Esses for protection Assinst Neutral Phanonena .
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h components of the onsite as power system are located in seismic
1. ..
Category I structures which provido protection from the affects of tornadoes and enternal floods, and other natural phenomena.
2. h oe components are Class 1R

3. h oe components have been designed to be fully qualified for the seismic and natural environmental conditions appropriate to their location. See Section 3.11.
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g. Criterion 4 Environmenta_1 and Missile Desfan Bases de \

1. The ccuponents of the onsite a power system are located in saismic l catagory I structures which provida 3,mtection from the effects of l tornado missiles, turbina missiles and other events and conditions which may occur outside the nuclear power unit. {
i (
2. These components are class 1E. !

3. These components are designed to accommodate the afffects of and be compatible with or are protected against the environments 1 conditions associated with normal operation, maintenance, testing, and postulated ,
accidents including loss of coolant accidents. Criteria are presented l in Chapter 3. Environmental conditions are presented in Chapter 3 and 6.
4. These components are protected, as appropriata, against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids <
that may result from equipment failures (postulated accidents). ! O l 1 i i I !
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i i p30 40 l l - WT YV' - i e
l ("'s s_ ,/ 430.61 Recent experience with Nuclear Power Plant Class lE electrical , system equipment protective relay applications has established l that relay trip setpoint drifts with conventional type relays have l resulted in premature trips of redundant safety-related system pump motors when the safety system was required to be operative. i While the basic need for proper protection for feeders / equipment against permanent faults is recognized, it is the staff's position that total non-availability of redundant safety systems due to spurious trips in protective relays is not acceptable. Provide a description of your circuit protection criteria for safety systemc/equipr.ent to avoid the above cited protective relay trip setpoint drift problems. RESPONSE: FSAR Section 8.3.1.1.g describes the Seabrook circuit protection criteria. The relay types used have been applied successfully for decades to protect motors, feeders, transformers and transmission lines throughout the electric power industry. We have never experienced any significant setpoint drift problem in these types of relay at our other nuclear facilities. Selection of these relays for Seabrook was based on prior satisf actory performance. We believe that the criteria for relay and trip setpoint i selection, together with our satisfactory experience at our other s/ facilities, assures completion of the protective function so as to minimize to the extent practical the total non-availability of redundant safety systems due to spurious trips in protective relays. b F v
SB 1 & 2 FSAR RAI 430.62 Identify all electrical equipment, both safety and non-safety, that may become 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 equipment (e.g. spurious actuation or loss of actuation function) as a result of flooding.
2, The effects on Class 1E electrical power sources serving this equipment as a result of such submergence; and
3. Any proposed design changes resulting from this analysis.
RESPONSE
1. Safety Significance of Failure of Submerged Equipment Refer to Table 430.62-1 for the List of Submergered Equipment.

a. Valves, Safety-Related

1) SI Accumulator Valves, SI-V-03, -17, -32 and 47 These motor operated valves are driven open during plant operation.
Stem-mounted limit switches provide an alternate valve position indication. Failure of these switches could cause loss of these alternate valve position indication circuits, but would not affect valve operation.
2) RCP Seal Water Isolation Valve, CS-V-168 This motor-operated valve is driven closed upon a containment isolation signal, therefore, this valve would fail in its safe position.
These are motor-operated va1ves on individual circuits, so failure of this circuit would not affect the remaining loads on the motor control center. The valve position monitor light will be revised to add an interposing relay, so that failure of the limit O' switch internal to the operator will not effect the monitor light circuit of other valves.
4 SB 1 & 2 FSAR I
3) SI Pump Hot Leg Test Line Isolation Valve, SI-V-160 i This air-operated valve is closed upon a containment
) I isolation signal. 1 j Failure of this circuit will also cause loss of power to i two other safety-related valves, SI-V174 and SI-V70. { These valves are already closed on safety injection and ! containment isolation, respectively, therefore, loss of j power results only in loss of valve position indication at the control switches. The limit switch for valve ! SI-V160 is also used in the Train B monitor light circuit, and this circuit may also be lost. ] 1 This circuit will be modified by adding an interposing { relay to the SI-V160 circuit. The relay will be mounted j in the control building, and a contact from this relay I will be used in the monitor light circuit to preserve
} this circuit from failure upon flooding of the SI-V160 l limit switch.
I 1 4) SI Cold and Hot Leg Test Line Isolation Valves, j SI-V-131, -134 } These valves are normally closed' test valves that also i receive a containment isolation signal to ensure they are closed. Valve SI-V-131 is a Train B valve on the same circuit as SI-V-160 (item 3 above). Valve SI-V-134
, is a Train A valve, and failure of this circuit will l cause loss of power to four other safety-related valves, i SI-V-165 & 173 (already closed on safety injection) and l SI-V-62 & 157 (already closed on containment isolation).
Valve position indication at their respective control 5 switches will be lost. J Valve position monitor lights circuit from valves i SI-V-13 and SI-V-134 will be modified to add an i interposing relay to avoid loss of the monitor lights i for the remaining safety valves.
5) Charging Pump Test Line Isolation Valve, SI-V-158 This Train B valve is a normally-closed test valve that also receives a containment isolation signal. This valve is on the same circuit as SI-V-160 (item 3 above) and the same analysis applies.

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SB 1 & 2 FSAR
6) ,RHR Test Valves RM-V-27. -28 and -49 These valves are normally-closed test valves that also receive a containment isclation signal. Valves RH-V-27 and RH-V-49 are Train A valves. Failure of this circuit will cause loss of power to safety-related valve RH-V-16, and solenoids for FY-618-1 and HCV-606. Valve RH-V-16 is already closed on containment isolation. Loss of power to FY 618-1 and HCV-606 solencids will result in full flow of the RH system going through the RHR heat exchanger, E-9A, and the closing of the bypass line.
As with item 3 above, monitor lights will be added to RH-V-27 and -49 using interposing relays. Valve RH-V-28 is a normally-closed Train B test valve that also receives a containment isolation signal. This valve is similar to RH-V-28, and failure cf this circuit will result in loss of power to safety-related valve RH-V-16 and solenoids for FY-619-1 and HCV-607. This will result in full flow through RHR heat exchanger E-9B. Valve position monitor light will be added to this circuit O with an interposing relay.
b. Valves - Non Safety A number of non-safety-rtlated air-operated valves are located below the flood level r that their stem-mounted limit switches and/or pilot solenoids may become submerged following LOCA.
Failure of the limit switch or solenoid will cause the entire . circuit to lose power, with the results that all non-safety-related valves on that particular circuit will deenergize to their fail-safe position. Valve position indication will also be lost. Those valves not submerged, which may be affected by flooded solenoids or limit switches are indicated on the attached Table 430-62-2.
c. Instrumentation All safety-related instrumentation, with the exception of the ex-core neutron detectors, will be located above the flood level.
Non-safety-related instrumentation located below the flood level may fail and give misleading information. None of this () instrumentation is required following a LOCA.
SB 1 & 2 FSAR
d. Miscellaneous Non-Safety Related Equipment

1) Pumps Those pump motors that may become submerged and fail are protected with redundant Class 1E starters. Failure of the particular circuit will not affect other circuits.
These non-safety-related motors are not required following a LOCA.
2) Control Panels The sump control panels are not required following LOCA.

3) Lighting The lighting system inside containment is normally off. I Control of the system is at control stations located outside the personal air lock.

4) Pressurizer Heater Terminal Boxes
() Failure of heater backup groups, C and D, will not affect the backup groups A and B which are fed from emergency busses.
2) Effect of Class IE Electrical Power Sources

a. Safety-Related Valves Only the circuits powering those valves which may become
-aubmerged will be lost from the Class 1E power distribution .Aystem. Other Class IE motor control center loads will not be affected. . b. Non-Safety-Related Valves Failure of these circuits will not affect any Class IE power supply.
c. Instrumentation Safty-related and non-safety-related instruments are powered ,
through separate instrumentation panels. These panels are powered from separate distribution circuits. Internal low voltage power supplies further isolate the individual circuits from the distribution system. Therefore, the Class IE power ( ) sources will not be affected by. submergence of any instrumen-tation. 0
SB 1 & 2 i 0\
+
FSAR l l
d. Miscellaneous f!

1) Pumps The non-vital pumps that may be submerged are powered from the non-Class IE Power system. Failure of these j motor circuits will not affect the Class 1E sources. '
' i
2) Control Panels
. I The control panels for the containment sump pumps are .
powered from non-Class IE sources and their failure will I not affect the Class IE system. l
3) Lighting System l
The lighting system is normally deenergized during plant operation. In addition, the feed to lighting transformer ED-X-16A, which is connected to the B Train Class IE ' power system, is deenergized following a LOCA. Therefore, the Class 1E power sources will not be affected.
4) Pressurizer Heater Terminal Boxes Backup heater groups, C and D, are not powered from the Class lE power system, and their failure will not affect the Class 1E system.
l
3. Proposed Design Changes

a. Safety-Related Valvee The monitor light circuit will be removed from the valve limit ,
switch and replaced with an interposing relay powered from j ~ the valve circuit. This will prevent submergence of the limit switch from tripping off the entire valve position monitor light circuit. No additional changes are proposed. I - l b. Non-Safety-Related Valves , No design changes are proposed.
c. Instrumentation l Safety-related reactor coolant flow transmitters I
z } ..._ t- -v -- - -
.- will be l
raised above the flood level. l No additional design changes are proposed.
d. Miscellaneous Equipment No design changes are proposed, l
SB 1 & 2 FSAR O l TABLE 430.62-1 i (Sheet 1 of 4) EQUIPMENT LOCATED IN THE CONTAINMENT _BELOW THE FLOOD LEVEL OF (-) 20'-8" i V-VITAL ! TAG NV - NON-VITAL COMPONENT APPLICATION CS-V-59 NV Solenoid & Limit RCP LD Seal Water Return ! Switch CS-V-145 NV Solenoid & Limit Letdown HX-E-2 to HX-E-8 Switch i CS-V-170 NV Solenoid & Limit Letdown HX-E-3 to RCDT i Switch , CS-V-175 NV Solenoid & Limit Excess Letdown Line Switch , CS-V-176 NV Limit Switch Excess Letdown Line ; CS-V-177 NV Limit Switch HX-E2 to Cold Leg 4 ! CS-V-18 0 NV Solenoid & Limit HX-E2 to Cold Leg 1 (
. Switch CS-V-18 5 NV Solenoid & Limit HX-E2 to Pressurizer Switch i O %)
CS-V-168 V Motor Operator RCP Seal Water Isolation j NG-V-17 NV Solencid & Limit Accumulator 9A Ni Line , Switch ! NG-V-19 NV Limit Switch Accumulator 9B Ni Line NG-V-21 NV Solenoid & Limit Accumulator 9C Ni Line Switch NG-V-23 NV Limit Switch Accumulator 9D Ni Line RC-LCV-459 NV Solenoid & Limit Letdown Isolation Valve Switch RC-LCV-460 NV Solenoid & Limit Letdown Isolation Valve Switch ' RC-LCV-81 NV Solenoid & Limit RC Loop 3 Letdown to Switch HX-E2 - RMW V-28 NV Solenoid RMW-TK 12 to RC TK 11 RMW V-180 NV Solenoid RC-P-1B Seal Pressurizer Equalizing Valve RMW V-181 NV Solenoid RC-P-1A Seal Pressurizer Equalizing Valve ' RH-V-27 V Solenoid & Limit HE-E-9B Header Test Switch RH-V-28 V Solenoid & Limit HX-E-9A Header Test ' Switch ! 1 i
SB 1 & 2 TABLE 430.62-1 V-VITAL TAG NV - nod-VITAL RH-V-49 Switch RH-V-54 Switch SI-V-03 SI-V-04 SI-V-18 Switch ~ SI-V-23 Switch O SI-V-32 .; SI-V-38 SI-V-53 SI-V-131 SI-V-133 SI-V-134 Switch Valve 'i ( WLD-FV-1403 Switch i T i FSAR l O ! I (Sheet 2 of 4) ! [ COMTONENT APPLICATION ; V Solenoid & Limit HX-E-9A Injection Test ! ! NV Solenoid & Limit SI-P-6A Discharge Test ! I RH-V-55 NV Limit Switch SI-P-6B Discharge Test f V Stem Mounted Limit Accumulator Iso. Valve Switch Stem Limit Sw. ! NV Limit Switch Accum. Test Valve t SI-V-15 NV Solenoid & Limit Accum. Fill Valve f Switch i SI-V-17 V Stem Mounted Limit Accum. Iso. Valve Stem 5 Switch Limited Sw. NV Solenoid & Limit Accum. Test Valve , [ NV Solenoid & Limit Accum. Fil Valve ! V Stem Mounted Limit Switch Accum. Iso. Valve Stem Limit Switch l SI-V-33 NV Solenoid & Limit Accum. Test Valve i Switch [ NV Limit Switch Accum Fill Valve SI-V-47 V Stem Mounted Limit Accum Iso. Valve - Stem Switch Limit Switch SI-V-48 NV Solenoirl & Limit Accum Test Valve Switch ! NV Solenoid & Limit Accum Fill Valve j Switch ; V Limit Switch SI - Cold Leg Test i SI-V-132 NV Limit Switch SI - Hot Leg 3 Test ! NV Limit Switch SI - Hot Leg 2 Test ! V Solenoid & Limit SI - Hot Leg Test ! I SI-V-158 V Solenoid Charging Pump Test l; SI-V-160 V Limit Switch SI Pump - Test Line Iso. ! NV Solenoid & Limit RCDT Transfer Valve ; I i
SB 1 & 2 FSAR 1 TABLE 430.62-1 (Sheet 3 of 4) B. INSTFVMENTATION LIST
1. Safety-Related Instruments Which May Be Submerged Tag Description Action NI-NE-41 A/B Power Range Neutron Not required post LOCA Detectors l NI-NE-42 A/B Power Range Neutron Not required post LOCA l Detectors NI-NE-43 A/B Power Range Neutron Not required post LOCA Detectors NI-NE-44 A/B Power Range Neutron Not required post LOCA Detectors RC-FT- 414,415,416 RC System Loop 1 - Will be raised above q
(,f RC-FT- 424,425,426 Flow the flood level RC System Loop 2 - Will be raised above Flow the flood level RC-FT- 434,435,436 RC System Loop 3 - Will be raised above Flow the-flood level
2. Non-Vital Instrumentation Which May be Submerged CAH-TE-5640 - 5647 NI Detector Well Temp.
CAS-AE-8815 Hydrogen Analyzers in RC TK 55 Area CAS-AE-8816 Hydrogen Analyzers in RC CS-E-3 Area CAS-AE-8817 Hydrogen Analyzers in Cntmnt. Valve Rm. CAS-AE-8818 Hydrogen Analyzers in CS-E-2 Area COP-PT-178 7 CS-PT-124 Excess Letdown HX, CS-E-3 Outlet Pres. CS-TE-126 Regenitive HX, CS-E-2 Charging Line Temp. CS-FT- 154 - 157 RCP Low Range Leakage Flow CS FIS 191 - 194 RCP Seal Flow LD-LT-8 333 Sump B Level RC-LT-9405 Press. Relief Tank Level RM-RX-6578 - 6581 Radiation Monitor D U
SB 1 & 2 i FSAR TABLE 430.62-1 (Sheet 4 of 4) i SF-LT-2629 Refueling Canal Level ,. SF-PT-2614 Refueling Canal Level : SM-XS3 XT-6701 Seismic Monitor ' SM-XS, ST-6709 Seismic Monitor WLD-LT-1403 RCDT, TK 55 - Level WLD-TE-1403 RCDT, TK 55 - Temp. ! WLD-FT-1406 RCDT, TK 55 - Flow ! WLD-FT-1411 RCDT, EX E-43 Inlet Temp. ; WLD-TE-1413 RCDT, EX E-43 Outlet Temp. j WLD-PT-1412 RCDT, EX E-43 Pump P33A/B Discharge Pres. ! WLD-PT-1420 RCDT, EX E-43 Pump P33 A/B Section Pres. WLD-LSH-6266 Containment Drains Sump A Level f WLD-LSH-6267 Containment Drains Sump B Level i i
3. Misc. Non-Vital Equipment Which May be Submerged ;
I
a. Pumps RC-P-271 Pressurizer Relief Tank, TK 11, Recire. Pump.
() SF-P-272 WLD-P-5A, SB Refueling Canal Drain Pump Containment Sump A pumps [ WLD-P-SC, SD Containment Sump B pumps ! WLD-P-33A, 33B RCDT, TK 55, Pumps ' i
b. Instrument Racks l
Individual instruments located on these racks have been identified above. i
c. Control Panels WLD-CP-280 Containment Sump A - Control Panel WLD-CP-281 Containment Sump B - Control Panel ;
i
d. Lighting i l
ED-X-16F Transformer supply for Panel Ll? , ED-X-16A Transformer supply for Panels PP-8B and EL 13 ( ED-X-16J Transformer supply for Panel L41 ' Panel L41 Lighting Panel i
e. Terminal Boxes !
X45 Pressurizer Heater Backup Group C () X46 Pressurizer Heater Backup Croup D l
~
l t Question 430.63-Provide a detail discussion (or plan) of the level of training proposed for your operators, maintenance crew, j quality assurance, and supervisory personnel i responsible for the operation and maintenance of the [ emergency diesel generators. Identify the number and ! type of personnel that will be dedicated to the opera- ; tions and maintenance of the emergency diesel genera- j tors and the number and type that will be assigned from j your general plant operations and maintenance groups to t' assist when needed. l In your discussion identify the amount and kind of training that will be received by each of the above ( l categories and the type of ongoing training progrca i planned to assure optimum availability of the emergency l generators. t Also discuss the level of education and minimum { experience requirements for th, various categories of ( operations and maintenance personnel associated with - the emergency diesel generators. ! Respone to 430.63 i i The Seabrook Station Training Department conducts non-
)
i s licensed training for station personnel including the ! diesel generator training. This training module, which l will consist of information derived from the diesel l technical manual and from the expertise of the t installation engineers, will include classroom training, " hands-on" sessions , and on-the-job training. [ The material to be covered includes: Prestartup checks t a.) Breaker checks b.) Interlock checks ' c.) Air & lube systems checks ' Running conditions a.) Af ter start instrument checks i b.) Equilibrium instrument checks _S_hutdown a.) Shutdown procedure ' b.) Verification of diesels auto status j \_ / .
i
~
i i 430.63 (cont'd) O- The operator training course for the diesel and other safety related equipment will have been given prior to ; any unsupervised operation of that equipment. ; Seabrook Station plans to send 20 members of the h Maintenance Department staff to a formal training l program now being developed by Colt Industries on ! -' their new Pielstick PC diesel. These trainees will ! include engineers, supervisors, and mechanics. The [ Seabrook Station Maintenance Department has 50 addi- l tional people available for maintenance activities. ! A formal on-going training program is described in FSAR i Section 13.2.2. ! The minimum educational level for station operators and ; Maintenance Department personnel at Seabrook is a High I School graduate or equivalent. Minimum experience is described in FSAR Section 13.1.2.1. . The level of training for quality assurance personnel will be identical to the operations / maintenance crew t personnel. , 5 F p b t 9 i f i O _ . .__ s_ . -. - _ _ - _ _ , ,
1 l I Question 430.64 () Periodic testing and test loading of an emergency diesel generator in a nuclear power plant is a necessary function to demonstrate the operability, capability and availability of the unit on demand. Periodic testing coupled with good preventive main- - ttnance practices will assure optimum equipment readi-ness and availability on demand. This is the desired goal. To achieve this optimum equipment readiness status the following should be met:
1. The equipment should be tested with a minimum loading of 25. percent of rated load. No load -
or light load operation will cause incomplete combustion of fuel resulting in the 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 turbochartar and exhaust system. The consequences of no load or light load operation are potential equioment failure due to the gum and varnish deposits and fire in the engine exhaust system.
2. Periodic surveillance testing should be per-O, formed in accordance with the applicable NRC guidelines (R.G.1.108), and with the recommen-dations of the engine manufacturer. Conflicts between any such recommendations and the NRC guidelines, particularly with respect to test frequency, loading and duration, should be identified and justified.

3. Preventive maintenance should go beyond the normal routine adjustments, servicing and repair of components when a malfunction occurs.
Preventive maintenance should encompass investigative testing of components which have a history of repeated malfunctioning and require constant attracion and repair. In such cases consideration should be given to replace-ment of those components with other products which have a record of demonstrated reliability, rather than repetitive repair and maintenance of the existing components. Testing of the unit af ter adjustments or repairs have been made only confirms that the equipment is operable t 1 does not necessarily mean that the root cause of the problem has been eliminated or alleviated. O
I I l 430.64 (contd.)
4. Upon completion o' repairs or m2intenance and prior to an actual start, run, and load test a ,
final equipment check should 'se made te assure that all electrical circuits are functLonal, i.e. , fuses are in place, switches and circuit i breakers are in their nroper 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 control of the control room operator. t Provide a discussion of how the above requirements have ; been implemented in the emergency diesel generator ' system design and how they will be considered when the i plant is in commercial operation, i.e. , by what means will the above requirements be enforced. Response to 430.64 Part 1. The emergency diesel generators will be tested with loading from 25 to 100 percent of rated load. This () will preclude concern over incomplete combustion of fuel and its subsequent effects. f I Part 2. The surveillance test procedures will be written and ! performed in accordance with Reg. Guide 1.108, except I as defined in Section 1.8. [ Part 3. Seabrook Station's maintenance program is being deve- ! loped to include the review of failed components for i repeat malfunctions. Our work request program will ! include acceptance testing after maintenance or repairs have been completed. When repeated malfunctions of identical components occurs, replacement with a more ! reliable item will be considered. I L [ I r 1 i r b i -
430.64 (contd.) I O
Part 4. Maintenance and Operations personnel will follow the station procedures, particularly including those con-
, cerning equipment control and test control. This series of procedures, as described in revised FSAR Section 13.5.1.1.3, provides means of verifying that the diesel generators are placed in the appropriate configuration for testing and subsequently for automa-tic standby service. 2 1 6 O O 1- -- - , - - - _ -.___ _ _ _ _ _ , _ _ _
1 SB 1 & 2 ! l FSAn O : I l RAI 430.65 ; I l The availability on demand of an emergency diesel generator is dependent upon, among other th'ings, the proper functioning of its control and monitoring inotru- ! mentation. This equipment is generally panel mounted and in sone instances the ! panels are mou'nted directly on the diesel generator skid. Major diesel engine i damage has occ'rred u at some operating plants f;sm vibration induced wear on skid J mounted control and monitoring instrumentation. This sensitive instrumentation ; j isnotmadetolwithstandandfunctionaccuratelyforprolongedperiodsunder continuous vibrational stresses normally encountered with internal conbustion l j engines. Operlation of sensitive instrumentation under this environment rapidly ' deteriorates calibration, accuracy and control signal output. Therefore, except for sensors and other equipment that must be directly mounted on the engine br associated piping, the controls and monitoring instrumentation , should be inst'alled on a free-standing floor mounted panel separate from the i If the floor is not ! engineskids,hndlocatedonavibrationfreefloorarea. ' vibration free, the panel shall be equipped with vibration mounts. Confirm your campliance with the above requirement or provide justification for noncompliance.
RESPONSE
Instrumentatiop aad controls not specifically mounted on the engine or associated piping are loc,ted a in the " engine gauge panel", " relay and terminal box", and the diesel generator control panel. The " engine gagge panel" is mounted on the engine-end of the skid using vibration isolating mounts, and contains gauges and switches. Failure of any instrument located in thi's panel does not affect operation of the diesel generator. The " relay and terminal box" sounced on the generator-end of the skid, contains control relays and the solid state speed switch. These devices are not considered sensitive instrumentation subject to setpoint drift due to vibration. In addition, the devices located in this panel have been seismically qualified; similar devices have been utilised for approximately 15 years in identical applications with no record of vibration-induced failure. I The " diesel generator control panel" is a free-standing, floor-mounted panel f separated from the engine skid. This control panel contains the balance of i diesel generat ar controls and monitoring instrumentation. j 1 O
SB 1 & 2 FSAR l ( RAI 430.66 , f i Tables 8.3-1 and 8.3-2 of the FSAR show that upon an emergency diesel engine { start the following diesel generator components are left in the operating j mode for Train A, but automatically turned off for Train B: [ t
a. Prelube and filter pump

b. Crankcase exhauster (

c. Rocker arm prelube pump I i
! d. Main and recirculs. ting seal pump
(Turbine generator or diesel generator cannot tell from Tables)

e. Auxiliary lube oil pump - signal to initiate pump start, f 4

f. Auxiliary fuel oil pump - signal to initiate pump start. '
Items a and c should be turned off "pon engine start, items b, d (if it is ; referring to the diesel engine), e and f should be left on for both trains ! since they are needed for proper operation of the diesel or serve as back up i to the primary system pumps in the event of their failure. Revise your () design accordingly. ;
RESPONSE
Design is being revised to trip items a & c on engine start. These loads are now deleted from diesel loading tables. Item d pertains to the main turbine generator. Items b, e and f are non safety related loads and, in 1 accordance with Seabrook separator criteria, are tripped off on a safety injection signal from Train B. None of these are required for operation of the diesel. j i t i i r i l l (:) - 1
43.22 'ee attse stiT'su.snook STAT!oM - W 63 A'83d8I8I'W 44 851&2 ! ygAR February 1982 l l l i Taht 0.)-l theet 8 el 3) [ I 9135th DEastATOL laastet 8m0utect !
$4FE$ MAP 010ut. WIN le88 0F effilf1 Plan 3 6 l
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3 Soorgeevy Feeenster Pteep (S) 900 779 603 4444 403 003 M3 483 7 aste ; 8 emelles fosse Fee (a) 400 330 8754 See 37e 320 esat temene 3 Coeltas fewer Fees (4) 390 480 afat 400 600 400 Centlewees 3 DThrt Side Settery Sergers (A) FT% W SS $$ coe t teesee 3 Cel tids lettery thergere 37% tv 35 SS testinesee , 3Q8eorter(4) M kV4 M
30 concioesse 3 (Cal Bles Cable to Dey Pee (A) I4 8 65 . 8 coollsamme [
lay til 3148 Cable as het Fee (A) at 4 68 8 eset teneve i
.I Cal Bles tege area sepysy Fee 49 $3 419 333 . , 19 Cestievens ;
3 Cal tids tage aree setere Fee M 13 11 395 . Il contievows SQ Ceble fewest gebeest Fee (al ' le 4 63 8 OsetLevees 405 i Sofielte Start need Addittee his period = Tveis a test M4 SM 4M Fat ett S Sie $ th ' bef talte heet & sed addittee Ttta Period = freie S 643 See 3M ek 738 678 603 400 e SS (4) = Tveie 4 esty i (B) = Tvete 5 Saly lleg Teort 9mp or torvie, goter peop, not teth, will be leaded on the 30. cooltas Teost Pump leed de lesser med is thesolete 11esed. l
8. emette ews seen sets thee M days. ,

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I 1 P.015 22.22 '90 21859 SMT SEABROOK STAfl0M - 9763 BB1&2 AMund ent 44 FSAR February 1982 l
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I 430.67 The information regarding the on-site communications system (9.5.2) (Section 9.5.2) does not adequately cover the system capabilities (~') N/ o during transients and accidents. Provide the following inf ormation: l (a) Identify all working stations on the plant site where it may be t necessary for plan: personnel to communicate with the control room or the emergency shutdown panel during and/or. following transients and/or accidents (including fires) in order to mitigate the consequences of the event and to attain a safe cold plant shutdown. (b) Indicate the maximum sound levels that could exist at each of the above identified working stations for all transients and l accident conditions. 2_ (c) Indicate the types of communication systems available at each of the above identified worki ,3 stations. (d) Indicate the maximum background noise level that could exist at
; each working station and yet reliably expect effective .
I communications with the control room using-
! 1. the page party communications system, and
2. any other additional communication system provided that
, working station. ! (e) Describe the performance requirements and tests that the above on-site working stations conmunication systems will be required to pass in order to be assured that ef fective communication with the control room or emergency shutdown panel is possible under all conditions. 4 (f) Identify and describe the power source (s) provided for _each of the communications systems.
, (g) Discuss the protective measures taken to assure a functionally operable on-site 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.
j Response (a) For those events which require Control. Room evacuation, we have j identified the following areas as requiring mannio; to achieve and maintain cold shutdown. Switchgear Rooms A and B i RHR Vaults A and B 4 Diesel Generator Control Panels A and B i In addition, there are many other areas where one time actions (i.e., valve caeration) may be necessary.
, The statiot. > asign provides for bringing the plant to cold ' - (' ) shutdown f rom the Control Room.' -The ref ore , if the Control' Room is available, there is no need to man remote locations to mitigate the consequences of an event or to attain a safe cold 1 plant shutdown.
i e--- - y e ,.--------g<-we- e w - p.- --9 , py gi*. .er grmy ,--m--- -w-- y-p-.
(b) The maximum sound levels are as follows:
/~' Switchgear Room A - (Later), B - (Later) \w_)) RHR Vaults A - (Later), B - (Later)
Diesel Generator Control Panels A - (Later), B - (Later) (c) The remote shutdown locations ide atified in a) and b) share a dedicated sound powered telephone channel. Each location, with the exception of the RHR vaults, also have access to a dedicated paging station. Because of the close proximity to each other, the RHR vaults share a single paging station. There is also an extension from the station telephone system near each location. In addition to those communication systems identified above, the station radio system (FSAR Section 9.5.2.2.a.4) is designed to provide communications betweeen all areas of the station (except the Containment Building) via hand-held portable ra dios. The radio system would provide communication to those areas noted in a) as requiring one time actions. (d) The maximum background noise level that could exist at each manned location identified in a) is listed in b).
1. The page party system is designed to provide ef fective communications at maximum background noise level.
ys 2. Headphones will be provided as necessary to assure () _ effective communication via the dedicated sound powered system. Sound absorbent booths will be employed as necessary to assure audible communications via the plant telephone system. Individual volume control on the hand-held portable radios assures that this system will provide effective comnunication under the maximum expected noise levels. , i (e) Functional tests will be conducted under conditions that simulate the maximum plant noise levels being generated during the various operating conditions and accident conditions, to demonstrate system capabilities. (f) The telephone system PABX is located in the construction office building and is powered by an of f-site construction power source. Following completion of Unit 2 power will be supplied l from a Unit 2 non-safety power system. Back-up power to the telephone system PABX is provided by a dedicated engine generator unit. The Public Address (PA) system for Unit 1 is powered f rom a Unit 1, Train "A" UPS bus. The PA system for Unit 2 is powered from a Unit 2, Trsin "A" UPS bus. The repeater for the station radio system is powered from Unit 1 non-safety power system. Back-up power is provided by a [) dedicated battery rated for 8-hour use. Portable units are_ powered by rechargeable batteries.
l' The sound powered telephone system requires no external power supply to maintain its function. t
~I (g) The following protective measures have been taken to assure a functionally operable on-site communication system.
I - Power. supplies for the various communication systems are discussed in (f). i The telephone system has redundant Central Processing l Units'(CPU). Two multi-pair telephone cables following i diverse routes connect the station telephone system to off-site public telephone system. Upon loss of all power i -l to the telephone system, preselected phones are automatically connected to the off-site telephone system. P i The telephone PABX, and each unit's PA system control cabinets, are housed in different locations. Cables for the PA system are run in Train "A" race - 's that a re di f f e rent from those used for the telephs ..e system. l The remote shutdown locations have a dedicated sound powered telephone system. i J i i h i 1 1 1 l. t
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l J 430.68 The description provided in Sections 8.3 and 9.5.2 of the FSAR is
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(9.5.2) not sufficient to determine the f unctional capability of the communication systems during certain accident conditions. You state j that power for the telephone and PA systems is supplied from Train A.
; The sound powered telephone system is routed in the Train A raceways. The power source for the radio system and the repeater stations in the plant is not described. Assuming an accident condition such as a high energy line pipe break which damages the sound powered telephone systems, and the failure of the Train A
", Power Source, show that ef fective communication can be maintained in i' all the areas listed in Request 430.67 above and that the plant can
, be brought to a safe (cold) shutdown, using the remaining operable portions of the communications system. Also provide the power source to the radio system and operating stations in the plant.
Response We feel the diverse nature of the power supplies for the various
portions of the communication system provides reasonable assurance ,
that communications will be maintained for any credible event. The hand held portable radios are unaffected by the accident l scenarios and provide the ultimate assurance that at least one means l of communication will always be available. i ) 4 O i I
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SB 1 & 2 FSAR O RAI 430.69 Identify the vital and hazardous areas where essential and emergency lighting is needed for safe shutdown of the reactor and the evacuation of personnel in the event of an accident. Tabulate the lighting system provided in your design to accommodate those areas so identified. Include the degree of compliance to Standard Review Plan 9.5.1 regarding emergency lighting requirements in the event of a fire.
RESPONSE
The following tabulation identifies lighting systems available at each area required to be manned for safe shutdown of the reactor. NORMAL ESSENTIAL EMERGENCh AREA LIGHTING LIGHTING LIGHTING
1. Control Yes Train A & B Station Battery Room 8 hours

2. Emergency fes Train A & B Station Battery Switchgear 8 hours Rooms A & B
(-~) U
3. Diesel Gen. Yes Train A & B Station Battery Room A 8 hours

4. Diesel Gen. Yes Train A & B Station Battery Room B 8 hours

5. RHR Vault A Yes Train B Battery Pack 8 hours

6. RHR Vault B Yes Train B Battery Pack 8 hours In compliance with 10 CFR Part 50, Appendix R, Section III J, all the above areas are also provided with eight-hour-rated self-contained battery packs for access and agress lighting. All other plant areas are provided with Ib hour rated self-contained battery packs for egress lighting.
In addition, fire brigade and operation personnti req'uired to achieve safe plant shutdown will be provided with suitable sealed beam battery powered, portable hand lights.
SB 1 & 2 FSAR - RAI 430.70 The description in sections 8.3 and 9.5.3 of the FSAR is not adequate to 5 determine the ability of the lighting system to provide sufficient i illumination during accident conditions. Your state in section 9.5.3.3 that ; power for the essential lighting system is from Train A and Train B diesel l generators, and the emergency lighting system is powered from the non-vital station battery. Tables 8.3-1 and 8.3-2 show that for a loss of oftsite Power (LOP), power to the essential lighting a system is as stated above, , but for any other accident condition concurrent with LOP, power to the l essential lighting system is from Train A only. Since the emergency lighting system is powered from non-vital station battery, its functioning during ) certain accidents such as a seismic event, cannot be assured. A failure of Train A at this time would result in inadequate or no lighting in the plant. i This is unacceptable. We require that adequate lighting be provided to all vital areas necessary for the safe shutdown of the reactor. For those areas listed in Request 430.67 and 430.69, assure that adequate lighting is provided for all plant conditions. ! l RESPONSE: i The Standard Review Plan, 9.5.3 states that the normal lighting system is () acceptable if it is powered from offsite power sources. While the emergency lighting system is acceptable if it is powered from onsite power sources. The SRP does not require that the lighting system: l i a) be designated as a Class 1E System, b) be powered from a Class IE Source, i i c) be designed to accommodate single failures of its power sources, I d) be designed to operate under combined accident and seismic events, t The Seabrook lighting system has been designed to operate with a diversity j and multiplicity of ac and de offsite, onsite, emergency, and non-emergency, ! power sources which we believe exceeds by far the requirements stipulated by l
, SRP 9.5.3. The design does assure adequate lighting to all vital areas ,
necessary for safe shutdown of the reactor, and to the access routes to and ! from these areas. ' l l l 1 () I
8B 1 & 2 FSAR O RAI 430.71 Expand the lighting section of the F8AR to include a discussion of how lightir. will 430.69abovealbeprovidedforthoseareaslistedinRequests430.67and nd illuminated by the emergency lighting systca only, in the event of a sustained loss of offsite ac power (in excess of 8 hours and up to 7 days) or provide the rationale why lighting is not requ{ red in these areas. Incivde in your discussion what, if any, other areas would require lighting during a sustained loss of ac power, and how it would be provided.
RESPONSE
As shewn abovp in response to Request 430.69, all areas required to be manned for sala shutdown of the reector have been provided with essential lighting from diesel-generators. As such, sustained loss of offsite power (in excess of 8 hours and up to 7 days) will have no impact on the assential lighting. Tha assential lighting system provides reduced illumination in other selecte i plant areas also. O 9
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i .5 i O RAI 430.72 .: i f Describes the instruments, controls, sensors and storms provided for i monitoring the diesel engine fuel oil storage and transfer system and . , their function. No information has been provided on the testing l l necessary to maintain and assure a highly. reliable instrumentation, ; controls, sensors and alarm systema [ Provide this information. Also ! l identify the temperature, pressure and level sensors which alert the l j l operator when these parameters exceed the ranges recourended by the t ' 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. i RESPONSE .
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During plant operation', the diesel generator fuel oil system integrity and operability will be demonstrated during periodic tests of the diese* l 3.7 ..;...._,.
-yw generator. No further tests are provided. 1 Temperature is not monitored in the fuel oil systam. Pressure is monitored .
j at the fuel inlet headers by PS-FFIA. Low pressure is alarmed locally and in l
, the control rcom.'with it's control switch in the " auto" position and the j ~
diesel engine running nomally, the electrically driven auxiliary fuel oil ,
;- . pump will start on this low pressure signal. The auxiliary fuel oil pump ~
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.will continue"_to' run .until ' shutdown locallym.or when the engine stops. , .a;. a n ...~, . . . .
) . . .. . I The operator; may run the auxiliary fuel: oil' pump, by switching:the locally l I mounted"contro1' switch to the ,"run" position excess high pressure fuel' oil !
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u.. rom. is returned;to" ttie' fuel oil' day tank.*"" W ' W 'iN Y W ".' ".8- . I
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l .. . ... ~ ~ ' f Pressure is indicated at .the inlet (By F1'-9595) and outlet (By P1-9502)._of the fuel oil: transfer pianp,'the operation of which is controlled by leviel l l switch IS-FLC in the fuel oil day tank. Should it become necessary,'ths fuel' oil day tank may be filled,from the other train storage tank by operator action using locked closed valves and the other train fuel oil transfer
--.- pump. __-
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l Bigh differential pressure .across the strainer in the fuel oil transfer . i line is alarata locally, by PSID-9540, and- ~is an input to the common trouble alarm in the control room. - . . - . , High differential pressure across the strainer in the inlet to the fuel oil f pumps is alarmed locally, by FDIS-FSHD, and is en input to the common t' rouble j y alarm in the control roca.._ _ l
~ ~ ,' ; T . .m Righ' differential pressure across. thefuel, oil filters is, alarmed;1ocally, by M ..' M FDIS-FFED, and'is an input~ -to the? : commonotrouble alarm in the '
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i,;. The strainers and filters are duplex units, on alarm or normal. maintenance. l may be valved out.for' exchange or cleaning while the redundant' unit is in. ~ servica.: . ._ g ; - - . In " auto" the auxiliary fuel oil pump is interlocked with engine speed of ,
} over 375 rpm and .1acket coolant pressure that corresponds to engine speed -j l r 'of 375 rpm.
SB 1 & 2 FSAR O RAI 430.73 (9.5.4) The diesel generator structures are designed to seismic and tornado criteria and are isolated from one another by a reinforcea concrete wall barrier. Describe the barrier (including openings) in more detail and its capability to withstand the effects of internally generated missiles resulting from a crankcase explosion, dislodging of one or all of the starting air receivers, failure of any high or moderate energy line and initial flooding from failure of the cooling system so that the assumed effects will not result in loss of an additional generator.
RESPONSE
Each diesel generator (D-C) and its associated auxiliaries are independent and physically separated from the other. The fuel oil storage tank and transfer pump for each D-G are in a below grade room separated from the other by a solff reinforced concrete wall with no openings. The D-G skid and its auxiliary skids are in a room above grade which is also separated from the other by a reinforced concrete wall. There are two doorways in this division wall for personnel access. These openings are at the extreme east and west ends of the division wall, suf ficiently removed from D-G equipment so that internally generated missiles from one D-G cannot affect operation of the other. There are drainage trenches around each D-G skid to control flooding, wo that failure of the cooling system of one D-G cannot affect the other. Also, each D-G skid and the auxiliary skids are supported off the floor by the skid foundations (See FSAR Figures 1.2-34, 35 and 36). I O
1 I i i 4 I i 1 l
430.74 Discuss the means for detecting or preventing growth of algae in If it were detected, describe the l (9.5.4) the diesel fuel storage tank.
i methods to be provided for cleaning the af fected storage tank. i f RESPONSE: Fuel oil samples will be tested on a periodic basis. If algae is
detected, fuel oil will be treated to prevent further growth. The i tank is drained and cleaned internally through piping connections and the manway, i f required .
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l i SB 1 & 2 i FSAR t () ! RAI 430.75 (9.5.4) In Section 9.5.4 of the FSAR you do not discuss for the diesel fuel oil system corrosion protection to minimize fuel oil contamination. Expand the FSAR to include a more explicit description of proposed internal and external corrosion protection of diesel oil storage tanks and any 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 in the use of an impressed current type cathodic ; protection system in addition to waterproof protective coatings to minimize corrosion of buried piping. If cathodic protection is not being considered, provide your justification. ; RESPONSE: - The fuel oil storage tanks are protected internally by a shop-applied ' corrosion resistant primer, and externally by a shop applied primer. A ; portion of the storage tank fill piping is buried in the yard. This piping ; has been coated and wrapped with Tapecoat-20 prior to installation. All l protective coatings have been applied in accordance with manufacturer's recommendations and etandard industry practice. An impressed current system for cathodic protection has been provided for the diesel generator buried () P ii P ng.
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SB 1 & 2 FSAR O RAI 430.76 (3.2) The FSAR text and Table 3.2-1 states that the components and piping systems for the diesel generator auxiliaries (fuel oil system, cooling water, lubrication, air starting, and intake and combustion system) that are mounted on the auxiliary skids are designed seismic Category I and are ASME Section III Class 3 quality. The engine mounted components it'd piping are designed and manufactured to DEMA standards, and are seismic Category I. This is not in accordance with Regulatory Guide 1.26 which requires the i entire diesel generator auxiliary systems be designed to ASME Section III l , Class 3 or Quality Group C. Provide the industry standards that were used ! in the design, manufacture, and inspection of the engine mounted piping and components. Also, show on the appropriate P&ID's where the Quality Group classification changes from Quality Group C, and where the seismic classification changes. (See Request 430.111 for additional requirements on the air start system.)
RESPONSE
The diesel engine and its engine-mounted portions of auxiliary piping are designed to seismic Category I requirements and follow the guidelines of DEMA standards, which are endorsed by Regulatory Guide 1.9 and IEEE Standard 387. Regulatory Guide 1.26 states that "other systems not covered by this guide, such as ... diesel engine and its generators and auxiliary support systems, diesel fuel ... should be designed, fabricated, erected and tested to quality standards commensurate with the safety function to be performed." FSAR Figure 9.5-5, 6, 7, 8 and 9 indicate the on-skid and off-skid portions of piping systems and components; and their Qual'ity Group Classification. All piping and components are designed to seismic Category I requirements. O
SB 1 & 2 FSAR O I RAI 430.77 (9.5.4) t Discuss what precautions have been taken in the design of the fuel oil system in locating the fuel oil day tank and connecting fuel oil piping in the diesel generator room with regard to possible exposure to ignition sources such as op'n e flames and hot surfaces.
RESPONSE
The fuel oil day tanks are located in separate enclosures on the floor level above the diesel generator room. The connecting piping is not routed near and ignition sources such as open flames and hot surfaces. l i
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SB 1 & 2 ! FSAR l O l 1 RAI 430.78 (9.5.4) l l Identify all high and moderate energy lines and systems that will be ! installed in the diesel generator room. Discuss the measures that will be ! taken in the, design of the diesel generator facility to protect the safety i related systeens, piping and comporents from the effects of high and moderata energy line f' allure to assure availability of the diesel generators when l needed. (See request 430.111 for additional concerns in high energy line breakswithrlegardstotheairstartsystem.) l t RESPONSEt , gach diesel-smnerator and its associated equipment and piping is independent i andphysica11pseparatedfromtheother. The redundant air start headers t'o j each engine are high energy lines. Failure of one line would not affect t'is availability of the diesel generator, since the engine is capable of being l started with only one receiver and header. In the event of a line failure l l affecting saf fty related systems or components of a diesel generator, the i redundant diesel generator would be unaffected and available for service if { needed. l l There are no other high energy or non-diesel-related moderate energy lines l in the diesel generator rooms. Failure of a diesel-related moderate energy l l line (i.e. diesel Jacket cooling water) would constitute failure of the l diesel. For this type of occurrence, the other diesel generator would be unaffected and would provide the necessary emergency function. l l L h t O
430.79 In Section 1.8 of the FSAR, you state that you comply with (9.5.4) Regulatory Guide 1.137, " Fuel Oil Systems for Standby Diesel {~T Generators". Section 9.5.4, " Emergency Diesel Engine Fuel Oil Storage and Transfer System (2DEFSS)", does not provide adequate information to determine compliance. Indicate if you intend to comply with this Regulatory Guide and ANSI Standard N195, " Fuel Oil Systems for Standby Diesel Cencrators", in your design of the EDEFSS, otherwise provide justification for noncompliance. RESPONSE: The diesel generator engine fuel oil storage and transfer system design is in general compliance with requirements of ANSI Standard N195. Each tank is provided with a vent and flame arrestor designed to ANSI B31.10 requirements (see response to RAI 430.86). The storage tank fill lines do not include a stiainer, since the fuel oil is normally filtered by the duplex strainers in the suctions to the fuel oil transfer pumps and also by the duplex strainers in the outlets of the day tanks to the diesel engine. Additionally, prior to reaching the engine fuel racks, the fuel oil is filtered by duplex filters. See FSAR Figure 9.5-5. O f l v
SB 1 & 2 i FSAR RAI 430.80 (9.5.4) Discuss the design considerations that have determined the physical location of the diesel engine fuel oil day tank (s) at your facility. Assure that the selected physical location of the fuel oil day tank meet the requirements of the diesel engine manufacturer. .
RESPONSE
The day tanks are located in separate enclosures on the floor level above the diesel generator room. The engine requirements for fuel at atmospheric pressure and ambient temperature are satisfied by maintaining normal level in the day tanks. O l O
<~' Ouestion 430.81 Discuss the precautionary measures that will be taken to assure the quality and reliability of the fuel oil for emergency diesel generator oper- ion. Include the type of fuel oil, impurity and qual..y limitations as well as diesel index number or its equivalent, cloud point, entrained moisture, sulfur, particulates and other deleterious insoluble substances; procedure for testing newly delivere/. fuel, periodic sampling and testing of on-site fuel oil (incit. ding interval between tests), interval of time between periodic removal of condensate from fuel tanks and periodic system inspection. In your discussion include reference to industry (or other) standards which will be followed to assure a reliable fuel oil supply to the emergency generators. - Response to 430.81 Fuel oil will be purchased to Federal Fuel Oil Specification VV-F-8006 (April 2, 1975) as per Reg. Guide 1.137. Tankers arriving at the site will be sampled and analyzed, as a minimum, for' specific gravity, water, sediment, and viscosity prior to transfer to a storage tank. Within fourteen days of a Os transfer to a storage tank, the analysis required by ASTM D 975-78 will be completed. The diesel day tank will be sampled for water monthly and daily when engine operating period exceeds one hour. In accordance with Seabrook Technical Specification 4.8.1.1.2.c at least every 92 days the storage tanks will be checked for water, sediment and viscosity. All sampling will be in accordance with ASTM D270-1975. t Reliability of diesel oil supply is discussed in the response to Question 430.83 t
85 1 & 2 FSAR l l l() l ' I RAI 430.82 (9.5.4) l Assumeanunl{ikelyeventhasoccurredrequiringoperationofadiesel I generator for, a prolonged period that would require replenishment of fuel oil without Lnterrupting operation of the diesel generator. What provisien will be made I n the design of the fuel oil storage fill system to minimise i the creation f turbulence of the sediment in the bottom of the storage ! tank. Stirring of this sediment during addition of new fuel has the potentialofhausingtheoverallqualityofthefueltobecomeunacceptable , and could pobsntially lead to the degradation or failure of the diesel [ generator. t l RESPONSE l The fill and transfer pump suction connections on the storage tanks are offset by 84". The suction connection extends 1" into the tank. The suction line includes a duples strainer to remove any sediment drawn from the tank. , Additionally, prior to refilling of the storage tanks, the fuel oil day I tanks would be filled. These tanks provide a minimum of three hours operationatfullloadforeachdieselgenerator. This time frame would allow the majority of any sediment to settle out prior to refilling the day l tanks. ! l i l i l t l O
430.83 Provide additional justification to support your statement in (9.5.4) Section 9.5.4.3 that sufficient additional fuel can be delivered O to the plant site by truck. In your discussion, include sources where diesel quality fuel oil is available, and distances travelled f rom the source to the plant. Also, discuss how fuel oil will be delivered on-site under extremely unfavorable environmental conditions, including probable maximum flood conditions. RESPONSE: Diesel quality fuel can be delivered by motor transport from a [ number of distributors within a 40-mile radius of the station. These distributors include: a) Gulf 011 Fuel - Newington, NH b) Northeast Petroleum of NH - Portsmouth, NH c) Sprague Energy - Portsmouth, NH d) Ueather Watch Heating, Inc. - Portsmouth, NH e) Belcher Oil Company - Revere, MA Routing of deliveries will be via state and federal highways which ' are maintained year-round in a passable condition. Site access roads from Route 1 to the diesel generator building are maintained passable by PSNH. The finished grades of access roads are at or j () above 20.5 feet above MSL. This grade is above the Probable Maximum Flood level of 8.9 feet above MSL computed f rom the PMF hydrograph. For the extreme cases of flooding caused by
" northeasters" or hurricanes refer to FSAR Section 2.4.2.2.e, "Have Runnup and Overtopping".
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SB 1 & 2 FSAR l RAI 430.84 (9.5.4) You state in Section 9.5.4.2 that the diesel generator fuel oil storage tank is provided with an individual fill and vent line. Include where these lines are located (indoor or outdoor) and the height these linas are terminated above finished ground grade. If these lines are located outdoors discuss the provisions made in your design to prevent entrance of water into the storage tank during adverse environmental conditions.
RESPONSE
The fill line runs underground from a truck-connection at grade (E1. 20'-0") in the yard into the diesel generator building, with a branch line to each storage tank. The truck connection is normally capped, and the branch line to each tank includes a normally closed valve. The vent lines from each storage tank are piped through the outside wall of the diesel-generator building and include a flame arrestor. These lines terminate 13'-0" ft above grade, at elevation 33'-0" and are designed to prevent direct entry of rain, snow, and debris (see FSAR Figure 9.5-5). O
i i SB 1 & 2 FSAR RAI 430.8 5 (9.5.4) Provide the source of power for the fuel oil storage tank motor driven fuel I oil recirculation pump and diesel engine motor driven fuel oil booster pump , and the motor characteristics, i.e., motor hp., operating voltage, phase (s) ; and frequency. Also include pump capacity and discharge head. Revise the l FSAR accordingly. i RESPONSE l Data for the motor driven fuel oil transfer (and recirculation) pump, and { on-skid auxiliary fuel oil pump is tabulated below and will be added to FSAR l Table 9.5-5. Fuel Oil Storage Tank On-Skid l r Transfer Pump Aux F0 Pump ( Capacity, gpm 20 13.7 i-Discharge Head 50 35 l l Source of Power EDE -MCC-521 (A) EDE-MCC-511 (A) l O- EDE -MCC-621 (B) EDE-MCC-611 (B) [ Notor, hp 2 2 ( Voltage 460 460 Phase / Frequency 3/60 3/60 i-t f [ I i i I l I I f r : l t
i SB 1 & 2 FSAR O RAI 430.86 Figure 9.5.5 shows that the diesel engine day tank vent line and the fuel i oil storage tank fill and vent lines are of non-seismic Category I l construction. This is not acceptable. The lines are required to be ! designed to Category I ASME Section III Class 3 (Quality Group C) Requirements in accordance with Regulatory Guide 1.26. In the event of a design basis earthquake (DBE) it is postulated that these lines will fail and that all other nonseismically designed systems in the plant will also fail or will be damaged to a degree requiring prolonged operation of the standby diesel generators. After an interval of time, it will become necessary to refill the storage tanks, as required by ANSI N-195 and Regulatory Guide 1.137. Since these lines are damaged, refilling and venting of the tanks may not ba possible. We require that these lines be designed to seismic Category I, Class C requirements. Also the portion of these lines outside the diesel generator building should be protected from damage by tornado missiles. Revise your system design accordingly.
RESPONSE
The fuel oil storage tank fill lines are designed to Category I, ASME Section III, Class C, requirements. The vent lines are designed to ANSI , B31.10 requirements, with seismic Category I supports inside the diesel (' generator building. This design is considered adequate, since capability of refilling the tanks is assured, and alternate means of venting can be provided if necessary. Regulatory Guide 1.26 states that diesel fuel systems are not covered, and should be designed to quality standards commensurate with the safety function to be performed. (See response to RAI ; 430.76.) It does not address atmospheric vent lines. The portion of the i vent lines inside the diesel generator is designed to seismic Category I, Class 3, requirements. The portion of the vent lines outside the diesel generator building is not protected from damage by tornado missiles; damage i to this piping is unlikely to affect operation of the diesel generators. In j the unlikely event that the storage tank vent lines are damaged, temporary provisions for venting can be provided during refilling. [ l 1 l I
SB 1 & 2 ! FSAR i RAI 430.87 (9.5.4) You state in FSAR Section 9.5.4.2 and show in Figure 9.5.5 that a common fill line for both fuel oil storage tanks is provided. This is acceptable l as stated in Section 7.5 of ANSI N-195 provided that the requirements of i Section 7.3 of the standard are met. Section 7.3 requires that " Provisions i shall be made to allow refilling the supply tanks af ter a Design Basis l Accident." The common truck fill connection does not meet this requirement ' since a design basis accident such as a tornado missile could damage the connection, thus preventing refilling the tank (s). Also, a fire in one D-G storage tank room would result in the inability to refill the other storage j tank or result in flooding the damaged tank room with fuel oil during , refilling. This is unacceptable. We require the following: I I
a. An alternate means of refilling the diesel generator fuel oil storage 2
tanks following a design basis event. -
b. Redundant isolation valves on the common fill line to isolate the two i divisions.
Revise your design accordingly. ;
RESPONSE
r (~' a. In the unlikely event that the fill line is unavailable due to tornado missile or fire damage, either storage tank can be refilled directly > from the truck through a spare 4" connection on the top of the tank.
b. In view of the above, and the normally closed fill valves,at each !
storage tank, additional valves on the common fill line are considered unnecessary. ! J c O , i
I SB 1 & 2 FSAR , O
\s ,/ RAI 430.88 (9.5.4) l You state in FSAR Section 9.5.4.3 and show in Figure 9.5.5 that there are a number of interconnecting pipes with proper isolation between the storage tanks, transfer pumps and day tank piping to allow for transfer of fuel oil to the adjacent engines' components, and return of fuel oil to the storage tanks. Lines 4377-05-152-1 " and 4378-05-152-lb" are the interconnecting lines of the diesel generator fuel oil transfer pump discharge. They are -
isolated by redundant, locked closed valves (V120 and V126). This line is c'onnected to the common fuel oil storage tank fill line by line ' 4374-04-152-1 ". Provide the following:
a. Explain the purpose of this connecting line. ,

b. Assuming an event in which valves V120 and V126 are opened to provide for transfer of fuel oil from one system's atorage to the other system's L day tank. Show that this lineup will not divert fuel back to the i storage tanks and that the conditions stated in 430.87 above can be met.
Note: The isolation valves required in 430.87b may not be adequate to prevent flooding of a tank room if this system line-up is used.
RESPONSE
a. Line 4374-04 allows the direct transfer of fuel oil from one storage r~g tank to the other, without affecting either day tank or engine piping.
(_) It also allows the discharge of contaminated fuel oil from either storage tank through the truck connection.
b. During transfer of fuel oil from one storage tank to the other day tank, the normally closed storage tank fill valves (V102 and V103) will prevent diversion of fuel oil back to the storage tanks.
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l l SB 1 & 2 FSAR l RAI 430.89 (9.5.4) Figure 1.2-34, 1.2-35 and 1.2-36 show pipe and drain trenches in both the diesel oil storage tank rooms and both diesel generator rooms. The drawings are unclear, and it appears that the trenches are connected at the dividing wall either by a wall opening or by drainage piping. This is unacceptable. A fuel line or cooling water line break in any of these rooms could also flood the adjacent D-G room and render both digs unavailable. To maintain separation and redundance, we require these openings sealed or illuminated. Comply with this position. , l
RESPONSE
The drain trenches in the storage tank rooms and the diesel generator rooms are not connected. The dividing wall at C-Line separates each D-G unit and its associated equipment f. rom the other D-G unit. The storage tank drain line passes through this wall with normally closed valves on each side. A fuel line or cooling water line break in one room cannot flood the adjacent D-G room. l O 1 (
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SB1&2 FSAR RAI 430.90 (9.5.5) section 9.5.5 indicates that the function of the diesel generator cooling water system Le to dissipate the heat transferred through that 1) engine water jacket, 2) lube oil cooler, 3) engine air water coolers, and 4) governor lube oil cooler. Some design data has been provided for the D-G jacket water cooler and lube oil cooler. Provide information on the individual component heat removal rates, flow (1bs/hr) and temperature differencial C0F) and the total heat removal rate required for all coolers. Also provide the design margin (excess heat removal capacity) included in the design of major components and subsystems. ,
RESPONSE
Heat Removal Cooling Water Temp. Design Rate, Beu/hr Flow, apa Diff. Marsin Jacket Water Cooler 15,550,400 1800 170F 55% Lube Oil Coolor 1,991,800 1060 40F N/A l ! The engine air coolers and governor oil coolers are integral with the engine. Deelain parameters were established by the engine manufacturer to meet engine requirements, but are not available fer tabulation. O
l i ' SB1&2 FSAR j i O RAI 430.91 (9.'5.5) l Recent licensee event reports have shown that tube leaks are being experiencedidtheheatexchangersofdieselenginejacketcoolingwater systems with resultant engine failure to start on demand. Provide a discussion on the means used to detect tube leakage and the corrective measures that will be taken. Include jacket water leakage into the lube oil system (standby mode), lube oil leakage into the jacket water (operating mode), jacket water leakage into the engine air intake and governor systems j (operating ettndby mode). Provide the permissable inlaakage or outleakage in each of the above conditions which can be tolerated without degrading l engine perforsmace or causing engine failure. The discussion should also include the effects of jacket water / service water systems leakage. I RESPONSI: Condition Means of Detection corrective Measures Jacket water leakage 1. Low level alarm on As required into lube oli system JW expansion tank (Standby modeh 2. High level alarm on rocker arm lube oil l reservoir. ; Lube oil leakage 1. Low level alarm on As required O into jacket water (Operating mode) 2. engine crankcase Overflow of JW sapansion tank Jacket water leakage 1. Low level alarm on 'As required into air intake JW expansion tank
2. Smoke in ensina .
exhaust Jacket water Leekage 1. Oil level sight glass As required into governor oil Service water leakage 1. Overflow of JW As required into jacket water expansion tank ; Note: The ab>ve abnormal conditions would be detected before operating , limits are asceeded, or engine performance is affected. j I 1 l
SB 1 & 2 FSAR O RAI 430.92 (9.5.5) Provide the results of a failure mode and effects analysis covering piping connections between diesel engine subsystem (engine jacket water, lube oil cooler, governor oil cooler,,and engine air intercooler).
RESPONSE
Component Failure Mode Effect on Diesel Generator Jacket water cooler Tube leak Gradual dilution of cooling water by service water; relief valve protects cooling water system from overpressure. D-G can cont,inue operating. Lube oil cooler - Tube leak Gradual dilution of cooling water 1 by lube oil; relief valve protects cooling water from overpressure; alarms provided for low lube oil level and pressure. D-C can continue operating. () Engine air cooler Tube leak Gradual addition of cooling water combustion air, causing visible smoke in exhaust D-G will gradually lose lead capability. Redundant D-G will start and maintain load. Governor oil cooler Tube leak Gradual addition of cooling water into governor oil, visible in oil level sight glass. D-G can ' continue operating. l O I I
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Question 430.93 O
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You state in Section 9.5.5.1 that the diesel engine cooling water is treated as appropriate to minimize corrosion and organic fouling. Provide additional details of you.r proposed diesel engine cooling water system chemical treatment, and discuss how your proposed treatment complies with the engine manufac-turers recommendations. Response to 430.93 The diesel engine cooling water system will be chemi-cally treated to minimize corrosion and organic fouling. This treatment will meet the manufacturers requirements for chemistry parameters: (1) pH 8 5 - 9.5 (2) Hardness <50 ppa A compatible inhibitor will be used if antifreeze is used to preclude relying on the inhibitors in the anti-freeze. This is in accord with the manufacturer's recommendations. Analysis for chemical verification will be done at least biweekly. 4 l l O
RAI 430.94 (9.5.5) Section 9.5.5.5 of the FSAR briefly describes the instrumentation, controls, sensors and alarms provided for monitoring of the diesel engine cooling water system. No information has been provided on the testing necessary to maintain and assure a highly reliable instrumentation, controls, sensors, and alarm system. Provide this information. Also, identify the temperature, pressure, level, and flow (where applicable) sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe what operator actions are required during alarm conditions to prevent harmful effects to the diesel engine. Discuss the systems interlocks t provided.
RESPONSE
During plant operation, the diesel generator cooling water system operability will be demonstrated during periodic testing of the diesel generator. l Other than being able to test rur. the jacket coolant standby circulating pump and heater, and the auxiliary coolant pump, no other tests are provided. High temperature in the jacket coolant eff.uent l is alarmed in the control room , and at the local panel by temperature switch TS-CTHA in the jacket coolant effluent line. Jacket coolant effluent temperature is monitored by a temperature control loop (s g,,) consisting of temperature transmitter TT-7Al with a pneumatic signal to temperature controller TC-7Al controlling temperature control valve TCV-7Al which diverts the jacket coolant water through the diesel generator component cooling water heat exchanger E-42A or partially by passes the heat exchanger. Diesel generator intercooler (air cooler) water temperature is monitored by a temperature control loop consisting of temperature transmitter TT-7A2 and temperature controller TC-7A2 controlling temperature control valve TCV-7A2 which controls the amount of water that goes through the heat exchanger or is recirculated. Jacket coolant inlet and outlet pressure is measured by pressure transmitter PT-7Al and PT-7A2 and the pneumatic signals from these trensmitters are fed [ to pressure differential transmitter PDT-7A, then to pressere differential controller PDC-7A1. The signal from PDC-7Al then positions valve PV-7Al to control coolant flow through the jacket coolant system. t The effluent from the intercooler (engine air cooler) is divided, some water circulated through temperature control valve TCV-7A2 to the air cooler system and some bypassed through the lube oil heat exchanger E-41A. The air cooler outlet flows through the lube oil heat exchanger to the diesel generator component coolant heat exchanger E-42A. The lube oil heat exchanger E-41A inlet and outlet pressure is measured by pressure transmitters PT-7A3 and PT-7A4. The pneumatic signals of these 3 transmitters are fed to pressure differential transmitter PDT-7A2 and then x_,) to pressure differential controller PDC-7A2. The signal from PDC-7A2 then positions valve PV-7A2 to control the water flow through the intercooler and the lube oil heat exchanger.
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. r 4 i The outlet pressure of the jacket coolant system is monitored by pressure ( 1 switch PS-CPLA. Should the jacket coolant outlet pressure drop below 15 psi, [ with the alarm permit conditions satisfied, the auxiliary coolant valves VilA [ i and V12A are opened and the auxiliary coolant pump P-122A started to provide water to the jacket coolant system. These valves close and the auxiliary 4 coolant pump stops if the outlet pressure exceeds 19 psi. i Jacket coolant outlet pressure is also monitored by pressure switch PS-CPS ! l whose set point is adjusted to correspond to an engine speed of 375 rpm and - 1 whose cont [)ct forms a part of the " Alarm Permit" logic. [ h Low air cooler inlet water pressure is detected by pressure switch PS-1PLA i which provides a local alarm and an input to the DG system trouble alarm ! at the computer. This pressure switch also opens the auxiliary coolant valves , V9 and V13 and starts the auxiliary coolant pump if the pressure drops ! below 25 psi. The valves close and the pump stops if the pressure exceeds ! 30 psi, j The auxiliary coolant pump runs if either or both coolant systems require { additional water pressure. Low level in the expansion tank is alarmed locally by level switch LS-CLLA. l l This switch also is an input to the DG system trouble alarm at the computer. l Local indication is provided by a level gage. The expansion tank level may l be increased by the operator manually valving demineralized water into the ; O' tank. ; i f J ! 4 l i 4 h t i i f I i i f f 1 i e : t
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l SB 1 & 2 FSAR
RAI 430.95 (9.5.5)
The diesel generators are required to start automatically on loss of all offsite power and in the event of a LOCA. The diesel generator sets should l be capable of operation at less than full load for extended periods without degradation of performance or reliability. Should a LOCA occur with availability of offsite power, discuss the design provisions and other parameters that have been considered in the selection of the diesel generators to enable them to run unloaded (on standby) for extended periods without degradation of engine performance or reliability. Expand your FSAR to include and explicitly define the capability of your design with regard to this requirement.
RESPONSE
The diesel generators are capable of running up to 24 hours at no load without affecting engine performance or reliability. Operating the D-G at 50% or greater load for one hour after each 14 hours of running at no load will maintain the engine in the standby condition, ready to accept load as required. O O
SB 1 & 2 FSAR r
, O RAI 430.96 (9.5.5) i Operating experience indicates that diesel engines have failed to start on j demand due to water spraying on locally mounted electronic / electrical !
components in the diesel engine start'ing system. Describe what measures have been incorporated in the diesel engine electrical starting system to ', protect such electronic / electrical components from such potential environment. ; i
f RESPONSE: ,
j Electrical components of the starting system are enclosed and protected from potential water sprays. There are no high energy water lines in the D-G ! t rooms. I i
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r r 1 m b P 1 I i O
SB 1 & 2 FSAR
-s/ RAI 430.97 (9.5.5) f You state in Section 9.5.5.2 that each diesel engine cooling water system 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, l valve stems and other components, and to maintain required NPSH on the , system circulating pump. Provide the size of the expansion tank and I location. Demonstrate by analysis that the expansion tank size will be adequate to maintain required pump NPSH and make up water for seven days I continuous operation of the diesel engine at full rated load without makeup, l or provide a seismic Category I, Safety Class 3 makeup water supply to the ' expansion tank. l RESPONSE: I
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l The cooling water expansion tanks have a desiga capacity of 290 gal and are f locared 46 ft above the engine skids at elevation 67'-6". This location ; assuras that the pump NPSH requirements are maintained. Pump shaf t seals, valve atem packing and other components are checked for zero leakage during ) routing engine testing. The expansion tank capacity can allow a leak of 1.7 gph for seven days without loss of contents. Makeup to the exp.ansion tank is from the demineralized water system, which can draw from the , condensate storage tank. l l l I L I l l l O
f i i SB 1 & 2 FSAR O RAI 430.98 (9.5.5) ! Provide the source of power for the diesel engine motor-driven jacket water ( standby circulating pump auxiliary coolant pump, and electric jacket water i heater. Provide the motor and electric heater characteristics, i.e., motor i hp., operating voltage, phase (s), frequericy and kW output as applicable. ; Also include the pump capacity and discharge head. Reivse the FSAR ; accordingly. j
RESPONSE
l: Data for the jacket water heater, motor driven auxiliary coolant pump, and [' on-skid standby circulating pump is tabulated below and will be added to FSAR Table 9.5-7. i i Auxiliary Standby Jacket-Coolant Pump Cire. Pump Water Heater Capacity, gpm 1150 70 - 1 i Discharge Head, ft 110 20 - ! Source of Power EDE-MCC-511 (A) EDE-MCC-511 (A) EDE-MCC-511 (A) l EDE-MCC-611 (B) EDE-MCC-611 (B) EDE-MCC-611 (B) { Motor, hp 50 1 - I Power, kW - - 49 Voltage 460 460 460 Phase /Freq. 3/60 3/60 3/60 ( r r I i e l i l l l l
SB 1 & 2 i FSAR O : RAI 430.99 (9.5.5) l l In Section 9.5.5 of the FSAR you state that the diesel generator component ! coeling water heat exchanger is not located in the diesel generator building l but in the primary auxiliary building, Figure 9.5-6 confirms this ! arrangement and it also shows that the diesel generator cooling water lines l are routed from the diesel generator building through the plant yard before i entering the primary auxiliary building. No mention is made about the exact routing of the piping or tornado missile protection for these lines. Provide the following:
a. Indicate where these lines are located'(above or below ground) and the f tornado missile protection provided for these lines. If none is ,
provided, it is our position that tornado missile protection be provided. Comply with this position. 6
b. Provide a discussion of the external corrosion protection provided for this piping. Where corrosion protective coatings are being considered, include the industry standards which will be used in their application.
If this piping is buried, discuss what provisions will be made in the design of this piping in the use of an impressed current type cathodic protection system in addition to waterproof protective coatings to minimize corrosion of buried piping. If cathodic protection is not being considered, provide your justification supplements by adequate drawings.
c. It is our position that if the cooling water piping for diesel generator room 1A passes through diesel generator room IB' or if the piping for both diesel generators are in close proximity to each other '
such that a single accident, such as a tornado missile or high energy line pipe break, could damage both the trains, then this is , unacceptable and your design will have to be revised. Provide a description supplemented by adequate drawings of the routing of the cooling water piping for both trains. Include in the description i sufficient information to show that the piping is adequately separated or protected and that any single accident will not degrade both trains. I
RESPONSE
a. The D-G cooling water lines exit the D-G building below grade through the west wall and enter the PAB below grade. Both buildings are ,
seismic Category I and provide tornado missile protection for equipdent and piping inside the buildings. I
b. The buried piping has been coated and wrapped prior to installation with Tapecoat-20, applied in accordance with the manufacturer's recommendations and standard industry practice. An impressed current system for cathodic protection has been providea.
-O c. The cooling water piping for one D-G does not pass through any areas associated with the other D-G. The piping exits to the yard through the west wall of the storage tank rooms, which are separated by a division wall.
SB 1 & 2 FSAR RAI 430.100 (9.5.5) Figure 9.5.6 of the FSAR shows 3 three-way bypass type valves in the engine cooling water system for each engine. Two are thermostatically controlled valves (valve numbers TCV-7A-1 and TCV-71-2) and one valve (no. V145-A) has no visible means of control. For each of these valves, describe the function and purpose of the valve, the temperatures at which they operate, and their adjustable temperature range. Fer valve V145-A describe how the valve is controlled.
RESPONSE
The following data is applicable to similar valves on each diesel generator: Valve Function / Purpose Operating Temp. Range TCV-7A-1 Regulate Cooling Water .00-2000F Flow Through Jacket Cooler TCV-7A-2 Regulate Cooling Water 100-2000F Flow Through Air Cooler, V145-A Regulate Cooling Water O (self-contained) Flow Through Fuel Injectors 100-2000F 9 O
SB 1 & 2 FSAR o ' RAI 430.101 (9.5.5) You state in Section 9.5.5.2 that upon failure of the engine driven jacket coolant pump and/or the engine driven air coolant pump, the auxiliary coolant pump automatically starts. Figure 9.5-6 shows this pump piped in parallel with the other pumps. The valves connecting the auxiliary coolant pump to the two other circuits are interlocked - so that they open and close together. Valves V11 and V12 are for the jacket cooling portion and valves V9 and V13 are for the air coolant portion of the system. The valves appear to be air or hydraulic operated. No discussion has been provided as to whether the valves open automatically or must be manually opened when the auxiliary coolant pump starts. Provide this information. If the valves , operate automatically, describe the sensors, logic and/or controls used to determine which section of valves open.
RESPONSE
The valves connecting the auxiliary coolant pump to the ccolant piping for jacket coolers and air coolers are pneumatic cylinder operated. The supply air to the valve operators is controlled by solenoid valves which are activated by pressure switches. The valves open automatically on low coolant pressure. For the jacket coolers, valves V11 and V12 are opened at 15 psig coolant pressure. For the air coolers, valves V9 and V13 are opened at 25 psig coolant pressure, (reference Drawing 503486). IO .
SB 1 & 2 FSAR RAI 430.102 (9.5.5) You state in Section 9.5.5.2 that during standby operation the jacket coolant heater and jacket coolant standby circulating pump heats and circulates the engine coolant water into the engine jacket. Figure 9.5-6 shows the cooling water system. From the figure it does not appear that heated cooling water circulates throughout the entire cooling water system. The diesel engine cooling water system should be preheated during standby condition to enhance engine start capability. Provide a detailed description of how the diesel engine cooling water system operates in the standby condition. Include in your discussion a description of the heating provided to the cooling water in the piping that passes between the diesel generator building and the primary auxiliary building. (See request 430.99 concerning piping in question.)
RESPONSE
In the standby condition, the only portion of the cooling water system that operates is the circulating pump, heater, and associated piping to and from the engine jacket. This is done to keep the engine warm and thereby enhance-engine start capability. It is not necessary to heat other components, or maintain circulation throughout the entire system. Once the engine starts, the entire system functions to remove heat from the engine, so that heating the entire system during standby would serve no purpose. I O , V
SB 1 & 2 FSAR O RAI 430.103 (9.5,5) Figure 9.5.6 of the FSAR shows a number of lines labeled D-G cooling water system that interconnect the diesel generator component cooling water heat exchangers. These lines (ID Numbers: 4406-05-Al-3/4", 4406-06-Al-1", 4406-02-Al-1", 4418-05-Al-3/4", 4418-04-Al-1", and 4418-02-Al-1") eventually connect to the floor and equipment drains system. It appears that these lines are ,usnd as system drain lines, but no description is provided in the FSAR as to the purpose of these lines. Your discussion should include the following:
a. If the lines are, or will be, used for more than system drainage, show that the requirements of General Design Criteria 17, " Electric Power Systems" and 44, " Cooling Water System", which regards, in-dependence, separation, and single failure criteria are met.

b. Provide the results of a failure mode and effects analysis that shows that any failure in these lines such as failure to close the isolation valves, pipe break or failure of relief valves will not degrade the diesel generator cooling water system for the engines or compromise system separation, and independence.
RESPONSE
These lines are heat exchanger drain, vent, and relief valve discharge lines, downstream of normally closed valves. The lines are connected to the floor and equipment drain system as a convenience, to avoid puddles on the floor during system maintenance and startup operations. During normal plant operation, the valves in these lines are closed to maintain cooling water system integrity. A failure of these lines will not affect operation of either diesel generator. i l lnO
1 1 SB 1 & 2 FSAR O RAI 430.104 (9.5.6) Provide a discussion of the measures that have been taken in the design 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.
RESPONSE
As shown on FSAR Figure 9.5-7, the air starting system includes a compressor inlet filter, air dryer, dryer prefilter, dryer af terfilter, moisture traps,
,and receiver blowdown piping. The engine skid piping also includes redundant strainers and filters. All of the above will preclude fouling of
( the air start valves and distributors. O O
SB 1 & 2 FSAR O RAI 430.105 (9.5.6) Describe the instrumentation, controls, sensors and alarms provided for monitoring the diesel engine air starting system, and describe their func-tion. Describe the testing necessary to maintain a highly reliable instru-mentation, 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 operate actions required during alarm conditions to prevent harmful effects to the diesel engine. Discuss system interlocks provided. Revise your FSAR accordingly.
RESPONSE
During plant operation, the diesel generator starting air system operability will be demonstrated during periodic testing of the diesel generator. The air compressor may be test started locally at the motor control center. No further tests are provided. The starting air compressor C-2A (C-2B for DG-B) control switch is normally key locked in the " Auto" position. With the compressor running, compressor lube oil level is monitored by level switch LSL-9519A. Low level is an input to the DG system trouble alarm at the computer and is alarmed heally. Air temperature is monitored at the compressor outlet by temperature switch TSH-9529A. High temperature is alarmed locally and is an input to the DG system trouble alarm'at the computer. This alarm is actuated at 4900F increasing and drops out at 4600F decreasing. The compressed air passes through a timer controlled desiccant air dryer with prefilter and postfilter before being stored in dual accumulator tanks. Air pressure in the accumulator tanks is monitored by pressure switches PS-APCI and PS-APC2. These switches are adjusted to close at 560 psi decreasing, to start the compressor, and 600 psi increasing, to stop the compressor. The accumulatcr tanks are equipped with safety valves set at 630 psi. To enable diesel air start, the barring devices, BD1 and BD2, must be dis-engaged. Starting air should then be available for starting when air start solenoid valves AS1 and AS2 are energized. The shut down air accumulator tank is charged and will shut the engine down by terminating the fuel oil supply to the engine should the shut down solenoid, SDS, be energized. Starting air pressure is monitored at the engine by pressure switches PS-APL1 and PS-APL2. Low starting air pressure is an input to the DG system alarm at the computer. Low starting air pressure will extinguish the " Ready for Auto Start" monitor light at the MCB and provide an alarm at the local panel, l i
SB 1 & 2 FSAR O Low-low starting air pressure is alarmed locally and at the computer by pres-sure switches PS-APLL1 and PS-APLL2. Low-low starting air pressure is also an input to the " Train Emergency Power Inoperable" alarm at the computer. d !O . A e O 4
l f SB 1 & 2 I FSAR l O l RAI 430.107 (9.5.6) A study by r.he University of Dayton has shown that accumulation of water in l the startir.g air system has been one of the most frequent causes of diesel l engine failure to start on demand. Condensation of entrained moisture in L compressed air lines leading to control and starting air valves, air start [ motors, and condensation of moisture on the working surfaces of these ! components has caused rust, scale and water itself to build up and score and ! jam the internal working parts of these vital components thereby preventing - starting of the diesel generators. In the event of loss of offsite power, the diesel generators must function j since they are vital to the safe shutdown of the reactor (s). Failure of the ; diesel engines to start from the effects of moisture condensation in air ; starting systems and from other causes have lowered their operational ! reliability to substantially less than the desired reliablity of 0.99 as l specified in Branch Technical Position ICSB (PSB) 2 " Diesel Generator i Reliability Testing" and Regulatory Guide 1.108 " Periodic Testing of Diesel ! Generator Units Used as Onsite Electric Pcwer Systems at Nuclear Power [ Plants". l
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In an ef fort toward improving diesel engine starting reliability, we require : that compressed air starting system designs include air dryers for the 0 removal of entrained moisture. The two air dryers most commonly used are the dessicant and refrigerant types. Of these two types, the refrigerant i type is the one most suited for this application and therefore is preferred. ! Starting air should be dried to a dew point of net more than 500F when ! installed in a normally controlled 700F environment, otherwise the starting air dew point should be controlled to at least 100F less than the lowest l expected ambient temperature. - You state in Section 9.5.6.1 that, " Provisions are incorporated for periodic j blowdown of accumulated moisture and foreign material in the air receivers." t This is unacceptable for moisture removal in the air start eystem, however l Section 9.5.6.2 mentions a dryer in the system, but it is not shcan on ! Figure 9.5-7. Describe this feature in your design and revise Figure 9.5-7 I accordingly. If no air dryer is provided, we require that an air dryer be f installed. Revise your design of the diesel engine air start system ! accordingly. Also expand your FSAR to discuss the procedures that will be i followed to ensure the dryers are working properly and the frequency of [ checking / testing. ; RESPONSE: ! As discussed in response to RAI 430.104, the air starting system includes an I air dryer, moisture traps, and receiver blowdown piping. The dryers are i twin-tower, dessicant type, and are identified as D-6A and D-6B on FSAR I Figure 9.5-7.
SB 1 & 2 FSAR O RAI 430.108 (9.5.6) ! l Provide the source of power for the diesel-engine air starting system l compressors and motor characteristics, i.e. operating voltage, phase (s), and i frequency. Revise your FSAR accordingly. l i i RESPONSE: ; i Data for the air starting system compressor motor is as follows: l l EDE-MCC-511 (A) l Source of Power EDE-MCC-611 (B) l t Motor hp 15 I Voltage 460 l I Phase /Freq. 3/60 i i r h O ! i i t I i i i t I f f b l O . i I
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SB 1 & 2 FSAR RAI 430.109 (9.5.6) l Expand Section 9.5.6.5 of your FSAR to clarify the statement regarding the f capability of the air start system "of five consecutive start attempts (successful or not) without recharging the air receivers", when an emergency l start signal exists. State whether the diesel engine cranks until all compressed air is exhaused, or cranking stops after a preset time to conserve f the diesel starting air supply. Describe the electrical features of this ' system in Section 8.0 of the FSAR (in the appropriate subsection).
RESPONSE: '
i In the event that the engine fails to start within 9 seconds of receiving a ' start signal, the start will be aborted. Interlocks tre provided so that a
second automatic start will not occur. If necessary, the operator must t initiate a manual start, after clearing the fault which caused termination of the first start. It is assumed that the redundant D-G will have started and accepted the design load. For a description of the electrical features ;
of this system, oee FSAR Subsection 8.3.1.1.e.2. j t I t P l r l l l i l l
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SB 1 & 2 FSAR RAI 430.110 (9.5.6) It is stated in the FSAR that the air start system and engine (air over piston) is designed for a air start pressure of 630 psig. Most air starting systems provided by other manufacturers have an air starting system design pressa e of no more than 250 psig. Provide the following:
a. Provide discussion as to why such a high pressure is needed to start the engine. Include in the discussion the minimum pressure
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needed to start the engine.
b. Figure 9.5.7 shows the relief valves on the air receivers and air compressors set at 630 psig, but Subsection 9.5.6.2 states that the air compressor design capacity is 31 cfm at 700 psig. Correct this discrepancy.
RESPONSE
a. The design pressure of the air starting system was determined by the engine manufacturer, based on the physical size of the engine and inertia of rotating components. A minimum pressure of 300 psig is required to start the engine.
(~') b. The air compressor is rated at 700 psig discharge pressure. v Controls are provided to unload and stop the compressor on increasing pressure at 600 psig. The air receiver relief valves are set at 630 psig. The apparent discrepancy reflects design margin. l l l __
i g SB 1 & 2 FSAR i I O RAI 430.106 (9.5.6) t
'l i Expand your description of the diesel engine starting system. The FSAR text
! should provide a detail system description of what is shown on Figure 9.5-7. The FSAR text should also describe: 1) components and their function, i
2) instrumentation, controls, sensors ~and alarms, and 3) a diesel engine starting sequence. In describing the diesel engine starting sequence include the number of air start valves used 'and whether one or both air start systems are used, i
; RESPONSE:
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! 1) Components of the starting system are identified and described in FSAR ! Subsection 9.5.6.2.
I 1 2) Instrumentation for the starting system is described in FSAR Subsection ' 9.5.6.5, and shown on Drawings 506391, 506392, 506393 and 506394. 4
3) On initiation of a start signal, starting air is applied through j redundant components to both banks of cylinders simultaneously to

accelerate the engine to provide rated frequency and voltage in less
; than 10 seconds. Each redundant portion of the starting system has an l independent receiver, supply line, air start valve and distributor, and supplies starting air to half of the engine cylinders (one bank). If ,
j either portion of the starting system should fail, the other portion, already activated, will continue to apply starting air to the engine. 4 .1
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i , O 9
SB 1 & 2 FSAR O RAI 430.111 (9.5.6) The air starting system for your plant is defined as a high energy system. A high energy line pipe break in the air starting system of one diesel generator, plus any single active failure in any auxiliary system of the other diesel generator will result in loss of all onsite ac power. This is unacceptable. Provide the following information:
a. Assuming a pipe break at any location in the high' energy position of the air start system, demonstrate that no damage from resulting pipe whip, jet impingement, or missiles (air receivers, or engine mounted air tanks) will occur on either of the two diesel generators or their auxiliary systems.

b. Section 9.5.6.2 states that the air receivers, valves, and piping to the engine are designed in accordance with ASME Section III Class 3 (Quality Group C) requirements. This is partially acceptable. We require the entire air starting system from the compressor discharge up to and including all engine mounted air start piping, valves and components be designed to Category I, ASME Section III Class 3 (Quality Group C) requirements. Show that you comply with this position. ,
RESPONSE
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a. Each D-G has redundant air receivers and supply lines to the engine-mounted air start valves and distributers. All piping to i
the D-G is designed to seismic Category I requirements. A failure or pipe break affecting one line will not affect the other, so that the diesel generator is still capable of starting. Each diesel generator is physically separated from the other by a reinforced concrete division wall.
b. The compressors, air dryers, pre-filters, and after-filters are not c6mmercially available as ASME Section III, Class 3 design.
The on-engine air start piping is designed to DEMA Standards. (See response to EAI 430.76). Also, the air compressor is considered non-critical since capability for starting the D-G is based on having pressurized air receivers with inlet valves for isolation from the compressors.
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l SB 1 & 2 FSAR i RAI 430.112 In Section 9.5.6.3 of the FSAR you state that a small air tank, isolated by a check valve, assures stopping capability if air pressure is lost in both ; headers. This statement is too general. Provide a detailed discussion on } the tank. The discussion should include the purpose or function of the l tank, the tank size (capacity), design pressure, and the industry standards ; to which it was designed. RESPONSE: , An engine-mounted air cylinder is provided to drive the fuel rack to the off j position for engine shutdown. Air supply to this cylinder is controlled by ! a 3-way, normally closed, solenoid valve. The air tank upstream of this l valve provides a reserve air supply for this function. The air tank is j 6" diameter x 12" long, and is designed to 630 psig, in accordance with ASME l Secticn III, Class 3 requirements. ; i 3 1 P 4 l e O l { I l .
1 l SB 1 & 2
. FSAR 1
O RAI 430.113 (9.5.7)
For the diesel engin~e lubrication system in Section 9.5.7 provide the following information: 1) define the temperature differentials flow rate, and heat removal rate of the interface cooling system external to the engine and verify that these are in accordance with recoassendations of the engine
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I manufacturer; 2) discuss the measures that will be taken to maintain the required quality of the oil, including the inspection and replacement when oil quality is degraded; 3) describe the protective features (such as blowout i panels) proviced to prevent unacceptable crankcase explesion and to mitigate the consequences of such an event; and 4) describe the capability for detec-tion and control of system leakage.
RESPONSE
1) The lube oil system and cooling water system were designed and furnished by the diesel engine manufacturer, based on the fluid temperature, flow rate, and heat removal requirements of the engine.
Design data for the lube oil cooler is as follows (see also Table
9. 5-8 ) :
j Shellside Tubeside Fluid Lube Oil Cooling Water j Flow rate, gpm 475 1060 1 Inlet Temp., OF 160 120.9 1 i Outlet Temp., OF 141.6 124.9 Heat Load, Btu /hr - 1,991,800
2) Lube oil quality is checked as part of regular D-G testing, with addition or replacement as required. Contamination of crankcase oil by cooling water leaks at the cylinder heads is eliminated, by providing a separate lubrication system for the rocker assemblies (See FSAR Fig. 9.5-8 ).

3) The crankcase is provided with an exhauster to continuously remove fumes, and maintain the crankcase under vacuum. A pressure switch is provided to alarm a loss of vacuum. The crankcase inspection

covers are provided with spring safety valves for relief of internal pressure due to crankcase explosions.

4) Crankcase level is monitored by the plant operators during regular D-G testing. A crankcase level switch is provided to alarm on low level. The oil reservoir for the rocker assembly lubrication is
! also provided with a level switch, to alarm on high level,
resulting from cooling water leakage into the rocker lubrication system.
1
l 1 i i' 430.114 Ilhat measures have been taken to prevent entry of deleterious ,
! (9.4.7) materials into the engine lubrication oil system due to operator error during recharging of lubricating oil or normal operation.
RESPONSE: The crank case fill connection is capped during normal operaticn. ! i Addition or recharging of lube oil is administratively controlled. The checking of oil level and any addition of oil to the engine lube oil system is the subject of procedures and training that , fall within the scope of Section 5.27 of ANSI N18.7-1976. f I i , 1 I t . a I l O : 6 l t i i I i
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O- ; I I I A t
l l SB 1 & 2 ,
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FSAR I IAI 430.115 (9.5.7) Describe the instrumentation, controls, sensors and alarms provided for monitoring the l diesel engine lubrication oil system and describe their function. Desciribe the testing necessary to maintdin a highly reliable instruisentatiod, control, seners and alarm system and where the alarms are annunciated. 3dentifythetempeteture,pressureandlevelsensorswhich alert the operator when these parameters exceed the ranges recoussended by the engine manufactiurer and describe any operator action required during alarm conditions to prevent hansful effects to the diesel engine. Discuss systems interlocks provided. Revise your FSAR accordingly. l l RESPONSE: , During plant operation, the diesel generator lubrication oil system operability is demonstrated during periodic testing of the diesel generator. The auxiliary ube oil pump, P-117A, may be test run by switeling the l control switch mounted at the motor control center, to "Run". This switch l in normally ke locked in the " auto" position. The prelube and fitter pump, P-116A, may be test run by switching the control switch, mounted at the motor control center, to "Run". This switch O is normally key-locked in the " auto" position. No further tests are provided. i The actor-driven prelube and fitter pump is designed to run continuously. l When the pump is running, lube oil temperature is monit'ored by temperature l switch TS-ORT. If the lube oil temperature falls below 1200F, the lube oil heater will be energized. The heater is deenergized when the tube oil-temperature rises above 1258P. This assures prelubrication of the engine with warm lube oil. l When the diesez generator is running, lube oil is pumped through a water cooled heat exdhanger E-41A. . Temperature control valve, TCV-7A, determines the volume of water that la directed through the heat exchanger, the remainder is bypassed back to the engine header. Lube oil temperature is monitored at tte lube oil pump outlet header and high lube oil temperature is alarmed locolly and at the computer. High lube oil temperature is also an input to the engine trouble shutdown logic. Normally, when the diesel generator is in operation, lube oil is pumped by the engine-driven pump. Lube oil pressure is monitored by four pressure switches PS-OPL1, PS-OPL2, P8-0PL3, and PS-OPL4. PS-OPL1 will close at 65 PSI decreasing and reset at 70 pai increasing; PS-OPL2 will close at 65 PSI - decreasing and reset at 70 PSI increasing; PS-OPL3 will close at 60 PSI decreasing and reset at 70 PSI increasing; PS-OPL4 will close at 60 PSI decreasing and reset at 70 PSI increasing.
s m. . . . ...o... xn. oos . . . . . . . . . . . I - SS 1 & 2 2 FSA1 O i l With diesel generator running at greater than 375 rpm and the alarm permit logic satisfied, PS-O?L1 or PS-OPL2 will start the auxiliary lube oil pump.
" Auxiliary Lube Oil Pump Running" is alarmed at this local control panel and . at the computer. If the alarm permit logic is satisfied, the detection of
! low pressure bp any of these four switches will be alarmed locally and at the computer. Two out of three low pressure signals from PS-OPL2, PS-OPL3, } and PS-OPL4 will result in an engine trouble shutdown. l j Low level in the rocker arm lube oil reservoir is alarmed locally by LS-KLHA and is an input to the DG system trouble alarm at the computer. Level in the engine sump is monitored by level switch.LS-OLLA, and low level is alarmed locally and at the computer. Lube oil tempeyature in the engine sump is monitored by temperature switch TS-0TLA. Low temperature is alarmed locally and at the computer. Differential pyessure across the lube oil strainer is monitored by pressure ' differential switch PDS-OSED. High differential pressure is alarmed locally and is an input, to the DG system trouble alarm at the computer. O . O
SB 1 & 2 FSAR ( RAI 430.116 (9.5.7) Expand your description of the diesel engine lube oil system. The FSAR text i should include a detail system description of what is shown on Figure 9.5-8. The FSAR text should also describe,1) components and their function, 2) instrumentation, controls, sensors and alarms, and 3) a diesel generator starting sequence for a normal start and an emergency start. Revise your ! FSAR accordingly, t RESPONSE: ;
1) Components of the lube oil system are identified and described in FSAR Subsection 9.5.7.2.

2) Instrumentation for the lube oil system is described in FSAR l Subsection 9.5.7.5, and shown on Drawings 506401 and 506402.

3) During and after either a normal (test) start or an emergency start, the engine-driven lube oil pump and engine-driven rocker arm lube pump provide the required lubrication to the engine ;
components. During engine standby, the motor-driven prelube and filter pump operates to provide prelubrication of the engine with heated and filtered oil. Prior to engine test, the motor-driven fs rocker arm prelube pump is run to provide prelubrication of the ! (,,) cylinder heads. An emergency start does not require operation of : the rocker arm prelube pump. L r f s
SB 1 & 2 FSAR O RAI 430.117 (9.5.7) Provide the source of power for the diesel engine prelube and filter oil pump, auxiliary lube oil pump, and rocker are prelube oil pump, and motor characteristics, i.e, motor hp, operating voltage, phase (s) and frequency. Also provide the pump capacity and discharge head. Revise your FSAR accordingly.
RESPONSE
Data for the motor driven prelube putips and auxiliary lube oil pump is tabulated below and will be added to FSAR Table 9.5-8. , Engine Prelube Rocker Arm Aux. Lube
& Filter Pump Prelube Pump Oil Pump Capacity 75 gpa 2.4 gpm 475 gym Disch. Head 140 pri 20 psi 100 psi
{ Source of Power EDE-MCC-511 (A) EDE-MCC-511 (A) EDE-MCC-511 (A) EDE-MCC-611 (B) EDE-MCC-611 (B) EDE-MCC-611 (B) Motor HP 15 0.5 60 Voltage 460 460 460 I Phase /Freq. 3/60 3/60 3/60 0
Sn 1 & 2 FSAR RAI 430.118 (9.5.7) Several fires have occured at some operating plants in the area of the diesel engine exhaust manifold and inside the turbocharger housing which have resulted in equipment unavailability. The fires were started from lube oil leaking and accumulating on the engine exhaust manifold and accumulating and igniting lnside the turbo-charger housing. Accumulation of lube oil in these areas, pn some engines, is apparently caused from an excessively long prelube period, generally longer than five minutes, prior to manual starting of a diesel generator. This condition does not occur on an emergency start since the preIube period is minimal. Provide the following information: 1
a. Except for the rocker arm lubrication system, the diesel-engine preIube will be continuous while the diesel generators are in the standby mode. Therfore, expand your FSAR section on engine prelube to demonstrate that (1) diesel engine prelube is in accprdance with manufacturer's recommandations, and (2) that continuous prelube will not result in dangerous annuinulations of lube oil that could ignite.

b. When manually starting the diesel generators for cny reason, to minimise the potential fire hazard and to improve equipment aval.1 ability, the prelube period for the rocker arm lubricating sys tem should be limited to a maximum of three to five minutes unipse otherwise recommended by the diesel engine manufacturer.
Confira your compliance with this requirement or provide your jus cification for requiring a 1 cager prelube time interval prior to panual starting of the diesel generatora. Provide the prelube ti interval your diesel engine will be exposed to prior to man al start.
RESPONSE
a. The complete diesel generator lubrication system, including components used for engine prelube, were designed and furnished by the engine manufacturer in accordance with engine requirements.
Undesirable accumulations of lube oil due to continuous prelube are unlikely to occur while the engine is in standby mode because the lube oil is continuous drained by gravity back to the crankcase. In addition, the crankcase is maintained under vacuum by the crankcase exhauster to assist lube oil drainage.
b. Whep manually starting the diesel generators, the rocker arm prelube period is administrative 1y controlled by the operator in ace'rdance o with engine manufacturer's instructions. The normal preiube period prior to a test start is 5 minutes. The engine manufacturer recommends that the rocker arm prelube pump be operatedr once a week for 5 to 30 minutes.
O
i i SB 1 & 2 i FSAR i RAI 430.119 j An emergency diesel generator unit in a nuclear power plant is normally in l the ready standby mode unless there is a loss of offsite power, an accident, ; or the diesel generator is under test. Long periods on standby have a ! tendency to drain or nearly empty the engine lube oil piping system. On an [ .; emergency start of the engine as much as 5 to 14 or more seconds may elapse i 1 from the start of cranking until full lube oil pressure is attained even ! though' full engine speed is generally reached in about five seconds. With I an essentially dry engine, the momentary lack of lubrication at the various moving parts may damage bearing surfaces producing incipient or actual component failure with resultant equipment unavailability. I i The emergency condition of readiness requires this equipment to attain full l rated speed and enable automatic sequencing of electric load within ten ' seconds. For this reason, and to improve upon the availability of this equipment on demand, it is necessary to establish as quickly as possible an ; oil film in the wearing parts by one or nore engine driven pump (s). During j the starting cycle the pump (s) accelerates slowly with the engine and may j not supply the required quantity of lubricating oil where needed fast ' enough. To remedy this condition for the rocker arm assembly lubrication system, as a minimum, an electrically driven lubricating oil pump,' powered from a reliable de power supply, should be installed in the rocker arm lube oil system to operate only during the engine cranking cycle or until satisfactory lube oil pressure is established in the engine rocker arm lube ; j oil distribution header. The installation of this prelube pump should be l coordinated with the respective engine manufacturer. ; Confirm your compliance with the above requirement or provide your ! justification for not installing an electric prelube oil pump. RESPONSE: ! The diesel generators are each equipped with a motor-driven rocker arm ; prelube pump, and a motor-driven engine prelube and filter pump. Both pumps [ are mounted on the D-G skid and operate only when the diesel-generator is in ! the ready standby mode. These pumps are shown on FSAR Fig. 9.5-8. For i additional pump data, see response to RAI 430.117. i l l 1 i i O
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SB 1 & 2 FSAR i
iV O j RAI 430.120 Figure 9.5.8 of the FSAR shows the lube oil system. It appears from the figure that during engine operation a portion of the lube oil that passes i through the lube oil heat exchanger by passes the lube oil strainer and is j directed back to the sump. It also appears that the lube oil is directed
. through an indicating device - ID. Number TI-7B-2. In addition it is i nuclear whether the oil is distributed by a main lube oil header or by other means. Provide a clearer drawing as well as a Jetailed description of the i
1 oil flow paths, during operation and standby. j RESPONSE: ? 4 The line described above as a strainer bypass is 3/8" diameter tubing. The lube oil header to which it connects is a 5" diameter pipe. Flow through this tubing would be minimal compared to the flow through the strainer. 1 The line which is shown in Figure 9.5.8 as flowing through the dual element ) indicator TB-7B-2 is a temperature sensing line, which will not allow flow j i of the contained medium. ll } Figure 9.5.8 shows the complete lube oil system. During engine operation
the portion of system used follows the following flow path: from the engine crankcase through the engine driven pump (P-115) to the cooler. The three-O way temperature control valve mixes the appropriate quantities of warm and cool oil and sends the resulting mixture through the strainer and into the
] j main distribution header where it lubricates and cools the rain bearings j camshaft bearings, followers and drives gears, and returns by gravity to the
; crankcase.
i l The rocker lube system is separate from the engine lube system described above. Oil is taken from a separate reservoir by the pumps (P-227 or P-228) j through the duplex filter, and distributed to the rocker assemblies, and j then returns by gravity to the reservoir. i I During standby conditions, lube oil flows from the engine crankcase through the motor driven pump (P-166) through the heater and filter, and into the j main system downstream of the three-way temperature control valve. From
this point the oil follows the same path as the main engine lube oil system.
J J I T !O
SB 1 & 2 FSAR RAI 430.121 (9.5.7) In Section 9.5.7.2 you state that the auxiliary motor driven lube oil pump is used in the event of a main lube oil pump failure. You further state that it is non-class IE and powered from the associated emergency bus. The FSAR does not state "that the associated emergency bus is a class IE bus. We require that the auxiliary lube oil pump and its power source be class IE. Show that you comply with this position.
RESPONSE
The motor-driven lube oil pump backs up the engine-driven lube oil pump. Failure of an engine-driven pump is considered a failure of the diesel generator. Back up pumps (motor-driven) for engine-driven pumps are desirable, but not essential for safety, and are therefore classified as non-Class 1E. lO iO
i ! SB 1 & 2 FSAR RAI 430.123 (9.5.8) l Provide the results of an analysis that demonstrates that the function of l your diesel engine air intake and exhaust system design will not be degraded to an extent which prevents developing full engine rated power or cause , engine shutdown as a consequence of any meteorological or accident condition. Include in your discussion the potential and effect of fire extinguishing (gaseous) medium, recirculation of diesel combustion products, or other gases that may intentionally or accidently be released on site, on , the performance of the diesel generator. l
RESPONSE
I The engine is designed to operate under adverse meteorological conditions as noted in FSAR Section 9.5.8.2. The location and physical spearation of air [ intaker, exhaust discharges, and building vents precludes recirculation of ; gases which could prevent the diesel generators from performing their safety func tion. i I 4 0
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I SB 1 & 2
! FSAR
) i RAI 430.124 (9.5.8) l j Discuss the provisions made in your design of the diesel engine combustion ' air intake and exhaust system to prevent possible clogging, during standby and in operation, from abnormal climatic conditions (heavy rains, freezing
, rain, dust storms, ice and snow) that could prevent operation of the diesel generator on demand.
I
RESPONSE
The diesel engine combustion air is drawn through screened openings loca:ed } in the north and south walls of the diesel generator building. The openings are covered by a canopy for missile protection. This canopy guards against any precipitation entering this system. The air intake piping guards i against dust from entering this system. The diesel engine exhaust stack has a a drip leg, of 12" nominal diameter pipe approximately 2'-9" long, to l capture precipitation. This leg is located in the horizontal piping between ] the vertical exhaust stack and the exhaust silencer. 1 Cate valves located at the bottom of this leg and also in the bottom of the exhaust silencer could be cracked open, or periodically opened to drain the exhaust system. Also note that high exhaust temperatures of 9000F-10000F will quickly evaporate any captured precipitation when diesel engine is i; () running. Dust should not affect exhaust performance. 4 1 I 4
SB 1 & 2 FSAR O RAI 430.125 (9.5.8) 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 i diesel will be able to provide full rated power.
RESPONSE
Each diesel generator and its auxiliaries are physically separated by a division wall along C-line at each level of the D-G building. The air intakes and room vents for diesel generator A are along the north wall of
, the D-G building, over 80 feet from the air intakes and room vents for diesel generator B, which are along the south wall of the D-G Building (see FSAR Fig. 1.2-35). Therefore, a fire affecting one D-G will not degrade the quality of combustion air to the other D-Gs O
1, J 0 _ . , -,c---n- . - --- - ----- --, ,
_ - - _ _ _ _ _ . _ _ _ _ _ . _ - _ _ - _ - _ - - - . ~ . . . ___ - . . _ - _ - _ _ . _ _ _ _ . _ l S31&2 FSAR ! ,!O ! i I j RAI 430.126 (9.5.8 ) i i !
! Experience at some operating plants has shown that diesel engines have l l failed to start due to accumulation of dust and other deliterious materials ,
i on electrical equipment associated with starting of the diesel generators I (e.g., auxiliary relay contacts, control switches-etc.). Describe the
j provisions that have been made in your diesel generator building design, l electrical starting-systes, and combustion air and ventilation air intakes ,
j design (s) to preclude this condition ::o assure availability of the diesel - i generator on demand. ; i ' Also describe under normal plant operation what procedure (s) will be used to l minimize accumulation of dust in the diesel generator room; specifically , a address concrete dust control. In your response also consider the condition l when Unit 1 is in operation and Unit 2 is under construction (abnormal l generation of dust). I i l RESPONSE: f I Electrical components of the starting air system are enclosed and protected ! ! from dust and debris. Intake and discharge points for combustion air are [ j physically separated from the diesel generator rooms. Ventilation air for ! l the diesel generator rooms is filtered at the air intakes. During normal [ i plant operation, periodic testing, maintenance, and general housekeeping f operations will assure D-G operability. The D-G equipment for Unit 1 is in ! j a totally separate building from Unit 2 D-C equipment, and will not be ; affected by Unit 2 construction activities. ; 6 l i i
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SB 1 & 2 78A1 O . l 1AI 430.127 (9.5.8) You state in Section 9.5.8.1 of the r$At that the diesel-generator intake, f exhaust, and l crankcase vacuum systems are designed to ANSI 531.1 " Piping ! Code". The supports for the components and piping for this system are designed in accordance with seismic Category I requirements. You also state l t that the comp'onents of the system loested inside the dieselFigures generator 1.2-36 ! buildingare%rotectedfromtornadoandturbinemissiles. i and 9.5~9) show that the above systems are non-seismic, non-nuclear safety ' and the portilons of the diesel engine exhaust system and crankcase exhaust : system exter s i to the diesel-generator building are not being protected i This is not acceptable. We require that fromtornado%ndturbinemissiles.the entire diesel generator intake, exhaust, and cr ; designed to s'eismic Category I, ASME Section III Class 3 (Quality Group Comply C) requirementshadbeprotectedfromtornadoandturbinemissiles. j with this position.
RESPONSE
The D-G air intake filters and exhaust silencers are not consercially All piping and components in availableas%8MEBecticaIII, Class 3 design. the intake, exhaust and crankcase vacuum systema are designed to seismic f Category I re'quirements, and conform to Quality Group D requirements of Reg. ! Guide 1.26. $$aeresponsetoquestion430.76). The crankcase exhaust O system is des'irable, but not essential for operation of the diesel generators. i l e h O
SB 1 & 2 FSAR O RAI 430.128 Figure 1.2-2$ of the FSAR shows a number of air vents, smoke relief vents, and room relief vents located directly beneath the combustion air intake for the diesel generators. The FSAR and the figures do not provide adequate explanation of the purpose of the vents, the rooms they serve or their effect on diesel engir.e operation. Provide this information as well as the following information:
a. In the event these vents have to be used during an accident condition such as a fire in the room it serves show 'that the operation of only one diesel engine will be degraded or disabled.

b. In the event of a probable maximum flood, show that these vents are located above the probable maximum flood level. If they are not, show that diesel engine operation will not be degraded.
RESPONSE
a. Each D-G fuel oil storage tank room is provided with air vents, smoke relief vents, and room relief vents. The air and room relief vents provide air circulation for ventilation of these rooms. The smoke relief vents provide an escape for smoke in the
} event of a fire in the storage tank rooms. The smoke from a fire in one storage tank room may affect the operation of the corresponding D-G, but the other D-G will not be affected, since it has separate and independent air vents and air intakes. (See response to question 430.125).
b. The storage tank room vents are terminated 5 feet above grade, at '
elevation 25'-0. The vents for the storage tanks are terminated 13 feet abovo grade, at elevation 33'-0". The D-G skids are set on , the D-G room floor at elevation 21'-6". The probable eaximum . t flood level is at elevation 20.6 feet. O
i SB 1 & 2 FSAR O
I l RAI 430.129 (9.5.8) l Figures 1.2-3S and 1.2-36 of the FSAR shows the equipment for the control room and both diesel-generator room ventilation systems sharing the same room in the dl.esel generator building with the diesel generator room stems taking their supply air from this room. In addition the , ventilation figures also s{how 9 a number of receivers and accumulators located in this i roois (ID. Numbers CBA-TK-141A, CRA-TK-1415, CBA-TK-142A, and CSA-TK-1425) I which are parl: of one of the ventilation systems. The gas or liquid ! contained by 1;hese tanks is not specified. From the Figures it does not
; appear that adequate isolation, or separation has been provided between the two adjacent diesel-generator combustion air intake and exhaust rooms and l
this room. Fhreachofthefollowingaccidents: a fire in the ventilation l equipment roon or in one of the diesel generator rooms plus a single active , failure in the fire protection system, a rupture of one or more of the { receivers due to an internally generated missile, a failure in one of the ; diesel general:or exhaust systems, sher that the operation of only one diesel generator wil:, be effected. RESPONSI: I 1 The ventilation equipment room is physically separated by a division wall r along 6.4 lino. Also, the D-G intake and exhaust equipment rooms for each j i D-G are physically separated from each other by a division wall along C-line i and the day tank enclosures (see FSAR Fig. 1.2-35). Therefore, a fire in j
, one of these rooms will not affect equipment in the other rooms, nor affect !
operation of acre than one diesel generator, even with a failure in the fire ;
protection ayates. I There is no equipment in the D-G equipment rooms at elevation 51'-6" that could generato an internal missile which would affect operation of either diesel genera

or. Exhaust fans FN-26A and 3 are located in separate {
enclosures. A failure of one D-C exhaust system may affect operation of the : corresponding D-G. However, the other D-C is protected by the division ! well, between intake and exhaust equipment ?ooms. l i o i l O 9
7- SB 1 & 2 FSAR O RAI 430.130 In Section 9.h.8.2 of the FSAR you state that the diesel generatore are
" capable of o'perating at its maximum rated output for the following service conditions and for the durations indicated during the following weather disturbances:
a. Service conditions l

1. f Ambient Air Intakes - 10 to 950F

2. Humidity: 20 to 801

b. Weather Disturbances

1. A tornado pressure transient causing an atmospheric pressure reduction of 3 PSI in 3 seconds followed by a rise to nor, sal pressure in 3 seconds.

2. A hurricane pressure of 26 inches Hg for a duration of one (1) hour."
We find these service conditions unacceptable. The following environmental service hovu Lwea determined se be neeeo spywopriate for Seshrnn1r
a. service conditions:

1. Hustidity: 20 to 100%

b. Weather Disturbances:

1. A tornado pressure transient causing an atmospheric pressure reduction of 3 PSI in 1.5 seconds followed by a rise to normal pressure in 1.5 seconds.

2. A hurricane or northeastern store pressure of 26 inches Hg for a minimum duration of two (2) hours followed by a pressure of approximately 26 to 27 inches Eg for an extended period of time (approximately 12 hours)
Provide the followings
a. In light of recent weather conditions in the northeast (Subsero tepperatures) justifyIfthe lower limit of -loor for the ambient air the temperature has to be revised intake temperature.
wnward, discuss the effects this will have on engine operation doldoutput,andwillairpreheatingberequiredtomaintainengine an performance. l O ga , - - - _ _ _
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b. Using the revised conditions stated above, discuss the effects they will have on engine operation and output.
RESPONSE
a. A ' low ambient air intake temperature will havs- no affect on engine op'eration and output. Combustion air is prehested in the turbo-ch'arger and is supplied to the engine at a temperature of 1000 mibimum and 2000 maximum.

b. A l, tornado pressure transient of 1.5 seconds is less severe and will not affect engine operation and output. A storm pressure of 26," Hg for a period of 14 hours may result in a reduction in mass flow of combustion air to the engine. However, since the com-bulstion air system is designed for approximately 50% excess air flow, this transient will not effect engine operation and output.
I
c. FSAR Subsection 9.5.8.2 has been revised to reflect the environmental co'nditions stated in the RAI.
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(To be incor-531&2 porated in f FSAR Am:ndnent 45) s O ! The crankcase exhauster is not safetyFailure of the
ofthediesekgeneratorbuilding. i f the engine.
bility of the engine. related and i's not required fortingoperat on oexhauster' doe's n at its maximum rated output l Ecch diesel-generstor unit is capable of operaditions and for the duratio a under the following outdoor service conduring the following we
a. Outdoor Service Conditions:
-30 to 950F l
1. Ambient air intakes ;
l
2. Eumidity: 20 to 100% i

b. Weather disturbances: i pressure j A tornado pressure transient causing an atmospher cby a rise i 1
reduction of 3 pai in 3 seconds followedA shorter transient (1.5 se l pressure in 3 seconds. d output. l will not affect engine operation an 6 inches Hg 2. A hurricane or northeastern storm26"pressure of 2The engine is Hg with no affect l for a duration of onefor(1)uphour. 1 l continued operation to 14 hours at i air system is t O on operation and output, since the combust on designed for approximately 50% excess air. Safety Evaluation Each redundant 9.5.8.3 for each nuclear unit. system. intake and exhaust l There are two redundant diesel generators i dieselenginelhasanindependentcembustionarloss of function of more thanl This redundancy and independence prevents theine in the event e isolated from I one diesel e and exhaust systems of each diesel engine ard from any motor-driven The air inta ther diesel engine and are also isolateShould an incident occur thosa of the artition wells. 2 extinguisher, it would have no equipment byleak or an accidental discharge of a CO effect on che' redundant diesel engina. the possibility of the use However, 1 intakes rather remote. The physical , l ocation of the 2 extipguisher in the area of the air air intakes makesd inBased the ismediate of a CO gine operation. should such e tinguishers be dischargethere would be no signif intake, a diesel manufacturer, a CO ill dilute the air intake by on airtests intake fro for a period of over 30 seconds wall diesel engines run at 30 l lessthanonalm(1) percent.inimising any effect of such an incident. also helps in, A V 9.5-33 1
SB 1 & 2 FSAR O RAI 430.131 (10.2) Expand your discussion of the turbine speed control and overspeed protection system. Provide additional explanation of the turbine and generator electrical load following capability for the turbine speed control system ; with the aid of system schematics (including turbin~e .:ontrol'and extraction , steam valves to the heaters). Tabulate the individual speed control protection devices (normal emergency and backup), the design speed (or range l of speed) at which each device begins operation go perform its protective function (in terms of percent of normal turbine operating speed). In order to evaluate the adequacy of the control and overspeed protection system, provide schematics and include identifying numbers to valves and mechanisms (mechanical and electrical) on the schematics. Describe in detail, with ; references to the identifying numbers, the sequence of events in a turbine ; trip, including response times, and show that the turbine stabilizes. ; Provide the resui;2 of a failure mode and effects analysis for the overspeed + protection systems. Show that a single steam valve failure cannot disable the turbine overspeed trip from functioning. ;
RESPONSE
The above subject matter is discussed in FSAR Subsection 10.2.2.4, and supplemented by schematic control diagrams Figures 430.131-1, 430.131-2 (12 sheets) and 430.131-3. O : i I a { l l l l l
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SB 1 & 2 FSAR O RAI 430.132 (10.2) In the turbine generator section discuss: 1) the valve closure times and 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; 3) effects of missiles from a possible turbine generator failure on safety related systems or components.
RESPONSE
1) Turbine valve closure times are as follows:
a) Turbine main steam stop valve = .15 see b) Turbine main steam control valve = .19 see c) Reheat stop valve = .20 sec d) Reheat intercept valve = .17 see Because of the physical arrangement of the turbine stop and control valves (in series), the failure of one valve will not () affect turbine operation or protection. The same logic would also apply to the reheat stop and inte cept valves. '
2) Extraction steam valve closure times are less than 2 seconds when tripped under low flow conditions.

3) There are no safety-related cystems or components within the turbine building to be affected from a possible turbine generator failure.
O G I
Question 430.133 O In Section 10.2.3.6 you discuss the inservice inspec-tion program for throttle-stop, control, reheat stop and interceptor steam valves: you do not address the capability for testing essential components during tur-bine generator system operation. Provide this information. In addition you state the main steam and reheat valves will be exercised periodically, but you do not define " periodically". We find this unacceptable. We require weekly exercisng of the valves, and dismantling one valve of each type every 3-1/3 years. Comply with this position. Response to 430.133 The turbine generator system design provides the abi-lity to test each turbine stop, control, intermediate (reheat) stop and intercept valve individually during Station operation. Each valve will be stroked from its operating position to the closed position and back to the operating position on a weekly schedule. At least once every 40 months, one valve from each of the above turbine valve types will be disassembled and inspected. O i ( i O Gl
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I SB 1 & 2 l FSAR l i i RAI 430.134 (10.2) Discuss the effects of a high and moderate energy piping failure, or failure j of the connection from the low pressure turbine to condenser on nearby safety related equipment of systems. Discuss what protection will be l provided the turbine overspeed control system equipment, electrical wiring and hydraulic lines from the effects of a high or moderate energy pipe failure, so that the turbine overspeed protection system will not be damaged to preclude its safety function. I RESPONSE: 5 i There are no safety-related systems in the turbine building. The turbine overspeed control system equipment is located in the front standard on the l operating floor. The turbine is tripped.by low hydraulic fluid pressure, so i a hydraulic line break caused by high or moderate energy pipe failure would have the same result. A mechanical overspeed trip provides additional ' protection against turbine overspeed, and acts independent of electrical ; wiring and hydraulic lines. i L t i i I l () e
I 430.135 In Section 10.2.3.6, you discuss the inservice inspection and (10.2) exercising of the main steam turbine stop and control valves and i [ reheater stop and intercept valves. You do not discuss the
' inservice inspection testing and exercising of the extraction :
steam valves. Provide a detailed description of: 1) the l extraction steam valves, and 2) your inservice inspection and ! testing program for these valves. Also, provide the time interval between periodic valve exercising to assure the extraction steam [ valves will close on turbine trip. RESPONSE: The extraction steam valves are not in the ASME Section XI f Inservice Inspection Program. It is planned torperform periodic [ - tests on these valves, but frequency and extent of these tests has l not yet been determined. Such information will be provided when ; defined. ' ! FSAR Section 10.2.2.3 presents a description of these valves. i - j b { I i
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.. RAI 430.136 (10.2)
Describe with the aid of drawings, the bulk hydrogen storage facility including its location and distribution system. Include the protective measures considered in the design to prevent fires and explosions during operations such as filling and purging the generator, as well as during normal operations.
RESPONSE
The bulk storage facility is located adjacent to Unit No. 2 transformer area, in accordance with NFPA-50A requirements. The piping is routed underground from the storage area to the waste processing building and the Unit 1 and Unit 2 turbine buildings, respectively. Monitors are contained in building zones through which hydrogen supply piping is routed to detect leakage. When ' filling the generator casing, the casing is first purged of air using an inert gas (carbon dioxide) to avoid an explosive hydrogen air mixture. Carbon dioxide is also used during the purging of the casing of hydrogen. During these operations, an analyzer is used to maintain a safe mixture. During normal operation, a control panel monitors the generator's hydrogen system status with alarm points for hydrogen purity, high and low temperature. e i l I. r O
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i l' SB 1 & 2 FSAR O i RAI 430.137 (10.4.1) Provide a tabulation in your FSAR ahowing the physical characteristics and performance ec'quirements of the main condensers. In your tabulation include such items as': 1) the number of condeneer tubes, material and total heat . transfer surface, 2) overall dimensions of the condenser, 3) number of , passes, 4) he't well capacity, 5) special design features, 6) minimum heat transfer, 7) pormal and maximum steam flows, 8) normal and maximum cooling water temperature, 9) normal and maximum exhaust steam temperature with no turbine bypas's flow and with maximum turbine bypass' flow, 10) limiting oxygen conton't in the condensats in cc per liter, and 11) other pertinent data. !
RESPONSE
Total Number af Condenaar Tubes 52,380 Tube Material Titanium i l Surface Area, ft2, shell 251,370 l Overall:Dia. (each shell) 31'W x 70'L x 45'E Number of Passes Two , O l Meat Transfer Rate 436 Btu /hr/sq. ft/0F Steam Loading, Design 7,560 x 106 Btu /hr Maximum 7,900 x 106 stu/hr Cooling Water Temp, OF 55 Design, 65 Max. l l Free Oxygen in Condensate, cc/ liter 0.005 l Hot Well Capacity, gallons 66,000 Normal Temp. (No bypass flow), OF 101 Maximum Temp. (No bypass flow), OF 134 i O
... 1 BB1&2 i FEAR l RAI 430.138 010.4.1) !
I l Discuss the measures taken: 1) to prevent loss of vacuum and, 2) to prevent { corrosion /ero'aion of condenser tubes and components. i i' RESPONSE' i
1) ing normal plant operation, two of the three vacuum pumps are !
Dur,d use to maintain condenser' vacuum. The third pump is available , fodservice,andwillauto-startupondecreasingvacuum. l Additionally, condenser vacuum indication and low condenser vacuum ' ala'us r are provided in the main control room to alert the operator as ko vacuum status. [ l
2) Internal baffles on condenser shell connections are provided to ;
pro,tect the tube bundle. The waterboxes are rubber lined, and an [ impressed current cathodic protection system is provided to [ protect the tube ends and tube sheet. b l r p l l I l, l ! l () ! l : t l
m i SB 1 & 2 FSAR N- RAI 430.139 (10.4.1) i Indicate and describe the means of detecting and controlling radioactive leakage into and out of the condenser and the means for processing excessive amounts.
RESPONSE
The presence of radioactivity in the condensers is the result of leakage of , primary coolant into the secondary systems across the steam generators.
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There are two systems for monitoring such leaks, the condenser air evacuation ; monitors, and the steam generator blowdown sample monitors. These monitors are described in Section 11.5, and their use for leakage monitoring and ! control is described in Subsection 5.2.5. Cleanup of the fluids in the I secondary system is accomplished by the steam generator blowdown system ! described in Subsection 10.4.8. B Limits on the levels of radioactivity in the condensers, as well as the l entire secondary system are established in Plant Technical Specifications. O , P t e O
I i Question 430.140 Discuss the measures taken for detecting, controlling, , correcting condensor cooling water leakage into the ! condensate stream. Response to 430.140 The secondary system includes extensive chemisty pro- ' cess instrumentation which will allow rapid deter-mination of condenser seawater intrusion. Process instrumentation provides sodium analysis and catior conductivity for each condenser hotwell. Most leaks are expect to occur at the tube sheet. A special collection trough on the tube sheet with a conductivity cell will continually supply information regarding system inleakage. Grab samples will also be analyzed f by shif t chemistry technicians to supply backup information. Leaks will be further identified by using such state-of-the-art techniques as helium mass spectroscopy to provide expeditious means of iden-tifying tubes for plugging. See response to Question 282.2. O . O
l Question 430.141 Provide the permissible cooling water inleakage and time of operation with inleakage to assure that condensate /feedwater quality can be maintained within safe limits. Response to 430.141 The controlling parameter for condenser inleakage will be the Westinghouse criteria not to exceed 0.15 ppm ! chlorides in the steam generators. From the generic data presented at the EPRI Condenser Workshop given in i Florida, January 1979, an inleakage rate of 2 X ' 10-3 gpm of seawater will produce an equilibrium chloride of 150 ppb in the steam generator. The site-specific model for Seabrook is being developed by the - Chemistry Department. - l s
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Question 430.142 i In Section 10.4.1.4 you have discussed tests and ini-tial field inspection but not the frequency and extent ; of inservice inspection of the main condenser. Provide ; this information in the FSAR. ' i Response to 430.142 : I t The main condenser is not part of the ASME Section XI I Inservice Inspection Program. It is planned, however to l perform a visual inspection of the condenser internals ' during each refueling outage as part of the normal sta-tion preventive maintenance activities. 5 The FSAR will be revised to add this inspection commit- ! ment to Section 10.4.1.4. as shown on the attached copy j of FSAR page 10.4-4. j I t t i b i I b r I i I
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l l SB 1 & 2 FSAR ggg, y,%f- 6 gM 4 30. /C 1 h-r. Total Heat Load: h Design (guaranteed flow) 7.58 x 109 Btu /hr VWO 7.90 x 109 Btu /hr Steam dump 7.15 x 109 Btu /hr Tubes: Titanium
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Length 55'-3" Size 1" OD, 22 gage Circulating water flow (total) 399,000 gpm Temperature rise 380F - Water velocity 7 fps Head loss . 27 ft 10.4.1.3 Safety Evaluation ' The main condenser has no safety-related design basis. Due to the plant design (PWR) there is negligible influence of condenser control functions on reactor coolant system operation, and negligible potential for hydrogen . y@ buildup in the condenser due to continuous gas removal. g 'C "l w s= omu In the event of a steam generator tube leak, radioactivity can be present in t,a the secondary side. See Section 11.1 for expected activity due to steam 8,7 % generator tube leakage, ('_ ,8.3T a58 u e o y) ' ( '"'9 Due to the location of the condenser in the turbine building, any flooding u e y ,c , resulting from condenser failure will not af fect safety related equipment. Eu5.
E w. E 10.4.1.4 -nspection and Testing ogo; <

oI "T The main condenser shell, tubes, and waterboxes are hydrostatically tested y g, j to verify integrity prior to initial plant start-up. 44 ,,g For service inspection, access manholes are provided on the outlet and turn- 5*e
,, g g around waterboxes, on both ends of the hotwell, and in the steam dome. M oag t coe oou 10.4.1.5 Instrumentation ; ,,5 Condenser vacuum is indicated and recorded in the control room. Condenser E5s cg, vacuum pressure switches are utilized to 1) alarm pre-turbine trip vacuum, ,c 3 ,>
2) trip the turbine with two-out-of-three coincidence logic and 3) block - oy steam dump to the condenser, also with two-out-of-three coincidence. g,o Hotwell level indication and high and low level alarms are provided in the
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control room. Hotwell level will control the hotwell water inventory by admitting make-up or returning excess water to the condensate storage facility. Sea water inleakage to the condenser is monitored by conductivity cells and _(3h recorded and alarmed in the control room and at a local panel. Inteakage is (f,[. y\. )+ .- 10.4-4
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i SB 1 & 2 ; FSAR RAI 430.143 (10.4.1) , Indicate what design provisions have been made to preclude failures of condenser tubes or components from turbine bypass blowdown or other high temperature drains into the condenser shell.
RESPONSE
The turbine bypass system and other high energy drains into the condenser shell have internal piping and baffle arrangements within the condensers which direct the effluent away from conde.: er tubes or components. O lO l
I i SB 1 & 2 FSAR ) 4
] RAI 430.145 (10.4.4)
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i Provide additional descriotion (with the aid of drawings) of the turbine { bypass valves and associated controls. In your discussion, include the i
number, size, principle of operation, construction, set points, and capacity '
i l of each valve and the malfunctions and/or modes of failure considered in the design of the turbine bypass system. i I RESPONSE: 1 The FSAR addresses this subject in Subsection 10.4.4.2. Steam dump valves and associated piping are shown on Figure 10.3-1, Sheet 2. Schematic
control diagrams 506559 thru-561, which are listed in Section 1.7, were
] provided to the NRC in a separate submittal. i 1 4 i
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430.146 In Section 10.4.4.4, you have discuseed tests and initial field I (10.4.4) inspection but not the frequency and extent of inservice testing and inspection of the turbine bypass system. Provide this information in the FSAR. ! RESPONSE: The Turbine Bypass System is not in the ASME Section XI Inservice l Inspection Program. It is planned to perform periodic tests on this system, but the frequency and extent of these tests has not been determined. When defined, such information will be provided in a revision to the FSAR. O o o
SB1&2 FSAR O RAI 430.144 (LO.4.1) Discuss the e Efect of loss of main condenser vacuum on the operation of the main steam isolation valves.
RESPONSE
The loss of main condenser vacuum has no effect upon the operation or l operability o f the main steam isolation valves. Upon a loss of condenser vacuum the turbine stop valves close, the turbine is tripped and the turbine steam bypass 'ralves are prevented from opening. Reactor coolant system heat removal is ac':omplished by the steam generator atmospheric steam reliefs er the steen generator safety valves. In this event, the main steam isolation valves would remain open, which is an acceptable condition. _ l l l O 9 l t l 1 ,
l SB 1 & 2 FSAR I O ! RAI 430.147 (10.4.4) Provide the results of an analysis indicating that failure of the turbine bypass system high energy line will not have an adverse effect, or preclude operation of the turbine speed control system or any safety related components or systems located close to the turbine bypass system.
RESPONSE
A failure in the turbine bypass system high energy line will not have an adverse effect on the turbine speed control system (TSCS), as it is designed to fail safe. If hydraulic pressure is lost in the TSCS, all turbine valves will close, tripping the turbine generator. There are no safety-related components or systems located in the turbine building. fO l . -
SB 1 & 2 FSAR
-O RAI 430.148 (10.4.4)
I g Provide the results of a failure mode and effects analysis to determine the effect of malfunction of the turbine bypass system on the operation of the reactor and main turbine generator unit. i
RESPONSE
k This subject is covered in FSAR Subsection 10.4.4.3. I h O l 1 r I l l r I l t I t I l i c : t "O I L
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