ML20052D124

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Forwards Revised Responses to Concerns Identified in Power Sys Branch Draft Ser.Responses Will Be Incorporated in Subsequent Amend to FSAR
ML20052D124
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 04/29/1982
From: Davidson D
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 8205060296
Download: ML20052D124 (6)


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THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P O Box 5000 m CLEVELAND. oHlo 44101 e TZLEPHONE (216) 622-9800 e ILLUMINATING BLDG e 55 PUBLIC SoVARE Serving The Best Location in the Nation Daiwyn R. Davidson OCE PRESIDENT SY STEM E NGINEERING AP7 CONSTRUCTION April 29, 1982 Mr. A. Schwencer Chief, Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Perry Nuclear Power Plant Docket Nos. 50-W O; 50-W1 Response to Draft SER Power Systems Branch

Dear Mr. Schwencer:

This letter and its attachment is submitted to provide revised responses to the concerns identified in the Draft SER for Power Systems.

It is our intention to incorporate these responses in a subsequent amendment to our Final Safety Analysis Report.

Very Truly Yours, I

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-430.17 The FSAR text and Table 3.2-1 states that the components and piping (3. 2) systems for the diesel generator auxiliaries (fuel oil system, (9.5.4) cooling watur, lubrication, air starting, and intake and combustion (9.5.5) system) that are mounted on the auxiliary skids are designed Seismic (9.5.6)

Category I and are ASME Sec' tion III Class 3 quality.

The engine (9.5.7) mounted components and piping are designed and manufactured to (9.5.8)

DEMA standards, and are Seismic Category I.

This is not in accordance with Regulatdry Guide 1.26 which requires the entire diesel generator auxiliary systems be designed to ASME Section III Class 3 or Quality Group C.

Provide the industry standards that were used in the design, manufacture, and inspection of the engine mounted piping and components.

Also show on the appropriate P61D's where the Quality Group Classification changes from Quality Group C.

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Response

Compliance with current regulations is reflected in revised Sections 9.5.4.3, 9.5.5.3, 9.5.6.3, 9.5.7.3, 9.5.8.1, and 9.5.9.'.

The' industry standards applicable to the design, manufacture and inspection of the HPCS diesel generator are given in -

of NEDO 10905.

The P6ID's indicate the safety classification changes from Safety Class 3 (Quality-Group C) to non-safety class.

Refer to Figures 9.5-8, 9.5-9, 9.5-10, 9.5-11, and 9.5-12.

The design of the standby diesel generator engine mounted auxiliary system piping components and the HPCS diesel generator auxiliary systems piping and components, both engine mounted and auxiliary skid-mounted can be demonstrated equivalent to systems designed to ASME Section III Class 3 requirements with regard to system functional operability and inservice reliability.

l This piping and components as part of the diesel engine package are seis-mically qualified to Category I requirements which provides assurance of operability for a design basis seismic event.

The diesel engines are manuf ac tured,

and tested, and inspected in accordance with the quality

assurance program requirecents of ANSI. 45.2 " Quality Assurance Program Requirements for Nuclear Facilities". Qualification and periodic testing in accordance with the guidelines of Regulatory Guides 1.9, " Selection, Design, and Qualification of Diesel-Generator. Units used 'as Standby (Onsite)

Electric Power Systems at Nuclear Power Plants", and 1.108, " Periodic

, Testing of Diesel Generator Units used as Onsite Electric Power Systems at

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Nuclear Power Plants" provides further assurance of inservice reliability.

Additionally, an analysis of system stresses has been performed to show that the piping and associated components are designed with sufficient margin for the system application and working stresses are within the limits of ANSI Standard B31.a. " Code for Pressure Piping." The analysis considered the worst case combination of pipe material, largest diameter, minimum wall thickness, maximum system pressures and temperatures and piping support spacing for'all the auxiliary systems.

The analysis showed that under normal operating conditions stresses due to pressure, dead weight, and therma.1 loads are less than ten percent of the allowable stresses per ANSI Standard B31.1.

Thus, the piping is intentionally overdesigned for these low working stresses and results in a high degree of assurance of system functional operability.

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1 430.34 Figure 9-5-16 shows an immersion heater in the diesel engine (9.5.5) cooling water system attached directly to the lube oil cooler, and to the engine-driven pumps' suction and discharge lines.

The FSAR in Section 9.5.9 does not provide a detailed des-

-cription of how the diesel engine cooling water system operates during standby conditions nor does the design of this system seem to provide for preheating of the jacket water to enhance engine start capability.

Provide a detailed description of how the diesel engine cooling water system operates on standby conditions.

Response

i A detailed description of the diesel engine cooling water system operation on standby conditions is provided in revised Section 9.5.9.2.2.

t The HPCS diesel engine specificiation requires the engine to operate at room temperatures ranging from 40 to 120 F.

The diesel generator building HVAC systems are designed to maintain the required environmental conditions between the minimum and maximum ambient conditions specified.

The design basis thus provides an ambient room temperature ranging from 40 to 120 F for outside temperature ranging from -5 dry bulb to 95 F.

Engine low temperature condition will be annunciated in the control room e

through a low temperature alarm (85 F) in the lube oil return line to the strainer pump.

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To address the NRC concern with HPCS diesel generator operation in room temperature below 65 F, CEI will demonstrate, during preoperational testing, l

the engine's capability to start and accept load within 10 seconds at an ambient room temperature of approximately 40 F.

In addition, required monthly surveillance testing will demonstrate engine start tests over a range of room temperatures. Additional parameters that will be monitored prior to the

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monthly test include: room and engine block temperatures on the day before and day of the test-, and temperatures of the' lube oil and cooling water systems. An

. assessment of the impact of ambient temperatures on the diesel generator starting r

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430.34 (Con't)

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performance will be made by identifying and trending the frequency of test failures at reom temperatures below 65 F.

Visual inspection for wear will be included in maintenance procedures when the unit is dismantled for overhaul.

(NOTE: A failure of a D/G start test results in increased test frequency per R. G.

1.108 and will provide additional data points).

After 24 months, an evaluation of the D/G performance during monthly testing will be submitted to the NRC along with justification for continued operation or proposed desiga modifications to either the HPCS D/G room HVAC system or the engine cooling water system to assure the engine is suitably pre-heated and improve starting reliability.

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April 29, 1982 i

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4 430.40 (3)

Describe the protective features provided to prevent unacceptable P arti al -

crankcase explosion and to mitigate the consequences of such an event.

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Response

A crankcase pressure detector is previded for the HPCS diesel engine to detect change in the normally negative crankcase pressure to a positive prassure.

If the crankcase pressure should become positive, the high crankcase pressure alarm annunciates. The oil relief valve is released and lube oil pressure to the oil pressure switch is relieved. Low 1.uSe oil pressure at the switch will initiate engine shutdown during the teix mode of operation. During other modes of operation, the low lube oil pressure trip signal is bypaased as required 'by Regulatory Guide 1.9.

A L c.: L high crankcase pressure alarm and a diesel generator trouble alarm in the control room are provided.

In addition, relief ports 4

will be provided prior to fuel load to relieve crankcase overpressure on the HPCS diesel engine.

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