ML20116F866

Responds to 830323 Question Re Qualification of Personnel Performing Nde.Requirements of SNT-TC-1A 1980 Mandatory Rather than Guidance in NB-5521 Re Qualification Procedures

ML20116F866
Person / Time
Site:	Vogtle
Issue date:	06/13/1983
From:	Ennis K AMERICAN SOCIETY OF MECHANICAL ENGINEERS
To:	Baker E NRC
Shared Package
ML20116F832	List: ML20116F866
References
NUDOCS 8505010267
Download: ML20116F866 (37)

Text

_.

31 The American Society of Mechanical Engineers

'E ' S g

unnee Enginwing cemer. :ks t. erin St. New Yors. N.Y 10017 212 644 7722. TWX.7ta$31.!,2g7 June 13,1983 United States 5

Nuclear Regulatory Cousaission Washington, DC 20555 Act:

E. T. Baker

Subject:

MB-5521 Qualification Procedures 1980 Edition - Sunsner 1982

Reference:

Your letter of March 23, 1983 ASME File f NI 83-033 Gentlemen:

Our understanding of the question in your inquiry, and our reply are as follows:

Question: Does the 1980 Edition,' Sumaner 1982 Addenda,Section III, Sub-section NB requirement that personnel performing MDE be qualified with a written practice prepared in accordance with SNT-TC-1A,datory rather tha except as modified by N3-5521, make the requirements of SNI-TC-1A 1980 man guidance, i.e., "shall" is inserted in place of the per:nissive "should"?

Esply, Yes.

Yours truly,

~.

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/

Kevin Ennis Assistant Secretary (212) 705-7643

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RVHVS isolation valves are non-pressure balanced solenoid-operated valves. By design, these valves are susceptible to opening upon the imposition of a small reverse delta-p. The amount of delta-p necessary to open the valve depends on certain characteristics of the valve and solenoid operator. In the plant Vogtle systems designs, the reactor, vessel head vent letdown path isolation valves are valves which are of the non-balanced solenoid type, and thus are susceptible to this phenomenon. However, these valves are all inside

' containment, and are used to isolate the paths from the reactor vessel head to the pressurizer relief tank. None of the valves are used for containment isolation, and further, the only time the valves could be opened by the reverse delta-p is when the RCS pressure is lower than the pressure in the PRT. This would occur during shutdown of the RCS, as the pressure is lowered to below approximately 150 psig. During this time, the valves could be used to allow an inert gas blanket to be put over the coolant (i.e., during shutdown, SG maintenance, etc.) so an opening of the valves is not only possible, but is expected for these amintenance procedures to be performed.

In summary, the non-pressure balanced solenoid-operated valves found in plant Vogtle systems designs are correctly specified, and are not susceptible to a loss of containment isolation nor a loss of coolant.

The isolation and modulating valves have similar mechanical design features.

Both are pilot operated solenoid valves. The operability of these valves has been verified for post accident seismic and environmental conditions (![EE qualifications) successfully. These valves are adequately qualified to perf orm their intended f unctions. Since these valves are seismically and environmentally qualified, cosmon mode failure should be precluded.

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8.3.1.1.11 Motor-operated Valves with Power Lockout The motor-operated valves that require power lockout to meet BTP ICSB 18 and that have the means to accomplish power lockout are listed and outlined as follows:

g A.

The following motor-operated valven power lockout and restoration capability is accomplished at the main control board:

HV-8806 Safety injection pump suction g

from refueling water storage tank HV-8835 Safety injection pump cold leg injection HV-8802A, B Safety injection pump hot leg injection HV-8B40 Residual heat removal pump hot leg injection HV-8809A, B Besidual heat removal pump cold 1eg injection HV-8813 Safety injection pump miniflow isolation

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B.

The following motor-operated valve power lockout is accompliched by padlocking the circuit breaker at the motor control center during startup and maintained in the 7

locked open position durinq reactor power operation:

@\\ri6 yt c heag.n p&n)

HV-8908A, B,

C, D

Accurula+gr isolation vplves H N/ -6 8 C 3 A, 8the emergency core cooling $, of boren s n d u % <g.

In addition, system motor-operated valvos (item A) are provided with valve position-indicating l

light boxes to provide a continuous indication of valve gg position.

The Technical Specifications list these valves and their required positions.

8.3.1.1.12 Containment Building Electrical Penetrations The electrical penetrations are protected from damage resulting from overcurrent conditions through the use of redundant overcurrent protective devices as indicated in paragraph 1.9.63.2.

The use of series Class IE fuses for backup protection on the 480-V switchgear power circuits is justified Amend. 3 1/84 Amend. 7 5/04 0.3.1-28 Amend. 13 1/85 i

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VEGP-FSAR-Q Question 430.64 FSAR paragraph 8.3.1.1.2.K.5 states that molded; case circuit breakers for motor circuits are equipped with instantaneous trip only and motor overload protection is provided by thermal trip units in the motor controller.

It also states that during startup and periodic testing all starters for motor-operated valves (MOVs) are equipped with thermal overloads (TOLs) but prier to core loading and during plant operation the TOL contacts for all Class IE valves are permanently bypassed with jumpers.

In this regard the staff would like to point out that it is not the intent of Regulatory Guide 1.106 to totally eliminate the use of TOLs or MOVs.

It is intended to assure that under accident conditions the valve will not be hindered from performing its safety function by a spurious overload trip condition.

For the majority of valve operations such as during valve test or cperation during nonaccident conditions, the use of TOLs in MOV circuits is a prudent operational practice to minimize motor damage due to overload conditions.

Though the proposed approach resolves concern relating to inadvertent operations of TOL under accident conditions, the staff does not recommend the virtual elimination of TOLs from MOV circuits by permanent bypass.

Address the followin; comments relative to the above:

A.

For the Class lE MOV circuits that have the overloads jumpered out describe how your design protects the cables to the valve motors against sustained locked rotor currents or high impedance faults such that the cable will not fail and affect other Class lE loads.

B.

Describe how the settings of the circuit breaker instantaneous trips for the Class 1E MOVs satisfy the above concern as well as providing coordination while avoiding spurious operation during normal motor Starting translents.

C.

Continuous bypassing of Class lE MOV overloads (except during periodic or maintenance testing) is not the only option of fered by Regulatory Guide 1.106.

However, if it is used, it must comply with the sections of IEEE 279 which are designated as requirements in Regulatory Gu2de 1.106.

Tne use of jumpers to bypass the thermal overloads to Class 1E MOVs does not comply with section 4.13 of IEEE 279.

The requirement is that the bypass (or in this case lack of a bypass) be continuously indicated in the control room.

Please address this issue.

0430.64-1 Amend. 7 5/84 t

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VEGF-TSAR-Q Reaperse The following responses correspond to the above questions:

A.

The smallest confe ctor size used for any power circuit is No. 12 AWO.

Cables are protected by the magnetic only trip circuit breakers as indicated in figure t

6.3.1-7, sheet 1.

FSAR figure 8.3.1-7 is only completely applicable to circuits inside containment.

Outside containment, the magnetic-only circuit breaker is relied upon for circuit protection without a thermal magnetic circuit breaker backup.

'td5ELT The area cf overlap between the highest magnetic-only g

circuit breaker setting of 50A and the thermal capability of the associated No. 12 field conductor 15 does net begin until 500 s as shown on the revised sheet 1 of TSAR figure 8.3.1-7.

It is not judged l

credible that such a high impedance,25-50A f ault, cculd exist continuously for nore than 500 s without the fault increasing to the level which would actuate the nagnetic-only circuit breaker.

If such a high 1epedance f ault could exist beyond the three cenductor cable would most likely f ail 500 s, 2

internally affecting only that cable p r one train.

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-, Magnetic only trip circuit breakers are set to cperate 2

B.

at two times the locked-rotor current of the MOV but net to exceed 13 times the motor full load current.

The lowest setting on the next larger siae breaker is used where this criterion cannot be met.

Section 4.13 of IEEE 279 and Regulatory Ouide 1.47 C.

require continuous monitoring of a cor,ponent of a pretortion system being bypassed or deliberately rendered inoperative.

The VEGP design is such that, when an MOV is moved away fro:t the safe position, it is Bypassing monitored at the systen bypass status panel.

the TOL is bypassing an overeurrent protective device, not bypassing a protective system component as defined by IEEE 279.

It should be noted that the overload heater itself in the power circuit is not bypassed, During only the trip contact in the control circuit.

plant operation an MOV motor overload condition isan alarm using a second independent contact in the j e-overload relay.

Amend. 7 5/84 Amend. 13 1/85 Q430.66-2 Amend. 15 3/05

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VECP-FSAR-Q Redundant indication is provided at indicator light boxes ZLB6 and ZLB7 which are mounted on the main control board.

The power supplies for these light boxes are from termination cabinets which are supplied power from 120-V distribution panels located in Class 1E motor control centers (one per train).

The termination cabinet is not powered from a motor control center providing main power to any valve listed aoove.

The second position indication is powered from the motor-operated valve control circuit.

Valves HV-8803A and B are two new valves identified in paragraph 8.3.1.1.11 which will tlso have power lockout using locked open breakers.

The circuit breakers for these valves will be padlocked in the open position during reactor power operation, after the valves have

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beer. aligned to the required position.

g Light box ZLB6 is powered from distribution panel 1AYC131 (MCCIABC), with the valve position indicating gg lights for valves HV-8802A, HV-8809A, and HV-8835.

None of these valves are powered from MCC 1ABC.

Light box ZLB7 is powered from distribution panel 13YA131 (MCC 1BBA), with the valve position indicating lights for valves HV-8802B, HV-88093, HV-8806, HV-8813, and HV-8840.

Nor.

of these valves are powered from MCC 13 1BBA.

The ccrrect pcsition of the lockout switch contacts is ronitored by a white light on the main control board.

When the lockout switch is on the " lockout" position, two contacts from the switch w,pgjable the control circuitry. One of the switch --- -^ F'will disable the hot leg of the circuitry and at the same time will deenergize the white light. The other switch contact w;11 disable the neutral leg of the circuitry. A deenergized white light when the lockout switch is on lg g "g" the " lockout" position means the control circuitry is y inoperable.}}.: t:

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t' o O VEOP-FSAR-Q &.Jt. The defec.tive bulb re-be d;;;ct a uh:n & I b :k;ut ru;. h is pl :cd vu u.m "0N" pen *i^" "ith tha kg y*i'e light ctill deer.c;gi;;d, ,/ p. The accumulator isolation valves circuit breakers will 13 I be padlocked in the open position during reactor power operation. Paragraph 8.3.1.1.11 has been revised and notes have been added to the individual schematic diagrams for each of the accumulator isolation valves to indicate the padlock requirement. C[ The accumulator isolation valve circuits conform with Branch Technical Position ICSB-4 (PSB) by virtue of: 1. K621 and K603 relays for automatic valve opening. 2. Handswitch indicator lights for visual valve indication. 3. Critical function alarm with periodic reflash for independent audible and visual alarm. 4. Relay K603 automatic preventien of valve cicsure. Motor control schematic drawinos and drawings for the critical function alarm have been provided in figures D* 430.73-9 through 430.73-12. ~. ( For the valves using locked open circuit breakers, the '7o 'C)(,F position indicating lights on the handswitch will be l y 774 /Ep h 'deegey4*ig d. This position, 4 however, is monit The power supply to the,RT,.2Mrl2 13 the c 21 light box. B r /#6 - err light box is independent of the power provided to the p g (valves. Redundant indication and power supply provided to the position indicators of valves are: 1. Motor-operated valve co'ntrol handswitch indication light, feed from control circuit. 2. Monitor light (on main lighting board), fed from termination. cabinet. 3. Critical function alarm (periodic reflash), fed from annunciator panel (de and diesel generator-backed ac lowered). Amend. 7 5/04 Q430.73-3 Amend. 13 1/85 l13 I

D 0 h0e C~ l INSERT [ The position indicating lights on the handswitch for each accumulator isolation valve indicate the open or closed status of the valve when it is stroked open for operation at power or stroked closed for shutdown. When the isolation valves are padlocked in the open position during reactor power operation by locking open the circuit breakers, these position indicating lights on the handswitch will be de-energized. At this time, this position is monitored by McB annJnciators or in the monitor light box. The position signal is f rom a contact on the valve cam operator switch. Another contact on the va'ive cam operator switch signals the critical function valve alarm that the valve is not opened. There is also a critical valve reflashing alarm that indicates when the valve is not fully open which is signaled from a stem mounted limit switch. These diverse indications warn the operator if the valve is not open when it is required to be open for correct ECCS alignment. The power supplies to the McB annunciators on the monitor light box are independent of the power provided to the valves, cn ,c .......J,k,,..... /,5.y, uJ i., v n. z, i. h..... 'J. r:7 II./. u h U 4.7 I'h fnA>l wt,. 5., ,g,,, y M. - L 0258n/RJM/3-85

O 8 b /lClC$ufe I C VEGP-FSAR-Q Two other operators are available as needed. Additional operators could be reassigned from other shifts if required. In addition to the two crews with system responsibilities,'the other personnel in the maintenance department could be assigned 13 to maintenance efforts if required. 1 All personnel vill have a high school diploma or equivalent. The minimum educational and experience requirements for the aforementioned personnel are as specified in subsection 13. l'. 3. The following is a sample trainina course outline for' operators. I. Course Outline (Operations Personnel) --l.3% A. Pitrpose B. eneral Overview 1. Diesel Engine 2. Ge erator 3. Supp -t Systems C. -Component D cription 1. Diesel Eng ne 2. Generator 13 3. Support Systems Majo Components D. I & 'C or QEAS C E. Local Centrols F. Start Signals i G. Breaker Permiss /es H. Trips I. Sequencing J. Parallel'.g Operations j Simulatof used or topic emphasis and additional t sining on diesel gen rators". Course leng_n is'one day g / Amend. 7 5/94 Q430.1-2 Amend. 13 1/85

VEGP-FSAR-Q ..-*ructors hold SRO Certification. Iwief y b _.cined us ..tassroom course anc k) Replacement pe._- na l s (90* simulator av ...ses s._ 'a-that used for the original .s C ra' ' Refreek.. raining is done per VEGP-FSAR su -inn 13.2.1.3.2. k II. Training (Maintenance Personnel) g7 I A. Five foremen and 30 mechanics have complete.y rebuilt the diesel engines. or.he site for A seggor representative will be B. all ex nsive modification and .1 ma]cr preventis maintenance. 13 C. Vendor courses ' 11 be cheduled if necessary or an instructor wili '. qualified by attending the \\ vendor course. D. Presently r need for any sining beyond that received y on-the-job train:.. Maintenance inst.ctions will be aware of the the ies of operation of e. rgency diesel generators. "How and, ere" lube oil will be added is to be covered in the on-the-job trm ' ning program. JEGP currently is conducting a job and task anal,,is for o. rations and maintenance personnel. Based upon the ana'ysis results, the curriculum for initial / refresher training I.ay be modified. Amend. 7 5/84 Q430.1-3 Amend. 13 1/85 113

e ][eser b I. Course Description a n'! O'n li ne for Operations Personnel A. Purpose - discuss design basis and purpose of the emergency diesel generators. G en e ral B. 41 - jal Overview - provide a general overview of the energency diesel 7enerator with enphasis on interrelationships of major systems. C. Component Description - for the major components of the energency diesel generator, discuss the function and any requiremer.ts related to technical specifications. D. Instrument and Control - discuss main control board instrumentation associated with energency diesel generator operation, E. Local Controls - discuss local controls required for fP starting, operating, or shutting down the emergency diesel generator. F. Automatic Features - discuss start signals, automatic and manual trips, and breaker permissives. G. Sequencing and Paralleling Operations - participate in sequencing and paralleling operations as a part of simulator training. Course length is one day (including simulator). Instructors hold SRO certification or are technically proficient in emergency diesel generator operation. Replacement personnel will be trained using classroom courses and simulator exercises similar to that used for the original crew. Refresher training is discussed in section 13.2.1.3.2. j ggy ($ II. Tra ir.ing (Maintenance Personnel) A. Five foremen and thirty mechanics, Georgia Power personnel, have conpletely disassembled and reassembled the VEGP diesel engines under the direction of a TDI representative. This on-the-job training qualifies these individuals as diesel generator technicians. f i B. A vendor representative will be on the site for extensive modification and all major preventive maintenance, b= C. Vendor courses will be scheduled, if necessary, or an instructor will be qualified by attending' the vendor course to develop an equivalent training program for VEGP personnel. i e 9

a TwseY G Maintenanco persor.nel are taught the system purpose, major (f4N,E components and system objectives for the emergency diene generators and auxiliary systems in the Pressuriced Water React >: Systems orientation. "How and where* lube oil will be added covered in the on-the-job training program. Further, VEGP is conducting a detailed job and task analysis for maintenance personnel. This task analysis will include all tasks to be performed in the maintenance of the emergency diesel generators. Based upon the analysis results and its comparison to the TDI program the curriculum for initial / refresher training will be developed. The maintenance training program for emergency diesel generators will provide training an outlinei below. COURSE OUTLINE I. Introduction A brief description of the training will be given, followed by a review of theory of diesel engine operations. II. The Model DSE/DSRV-4 Engine A. Basic engine construction - discussions will concentrate on $lo the configuration of the engine and function of various conponents, the flow of fluids (i.e., air, oil, water, fuel and exhaust) will then be presented. B. Turbocharger - theory of operaton of turbochargers will be covered followed by a description turbocharger, and required maintenance. C. Fuel injection equipment - this session will describe fundamentals of direct injection in diesel engines. Governor Operation Basic thaory of governor operation will be reviewed followed by deceription of the Woodward Governor system. I '.. Vital Flows / Auxiliary Skid Schematics of the flows of lubricating oil, fuel oil, intake and exhaust gas, jacket water and starting air will be reviewed. Elements of each flow system including pumps, filters, and strainers will then be identified in the auxiliary skid and adjustment at.d maintenance reviewed. V. Engine Operation With completion of the description of all system components, integration and operation of the complete system will be discussed. Normal operating parameters will then be reviewed.

.i e .l 1 1 b sse rk 3 e] .g VI. Preventive Maintenance and Maintenance Schedule j Preventive maintenance techniques will bo rot w e -! -a n d thon 1

• ypical maintenance intervals discussed.

1 VII. Maintenance Procedures t IL The presentation will cover too'.s and procedures for m.intaining major components of the engine. J VIII. Troubleshooting i Troubleshooting techniques will be reviewed. t i i IX. Review and discussion. t .i i 0084m l l l .4

C D VEGP-FSAR-Q Question 430.2 shown that Operating experience of two nuclear power plants hasstandby diesel during periodic surveillance testing of a initiation of an emergency start signal (loss-of-generator, or loss of ofisite power) resulted in the coolant accident diesel failing to start and perform its function due tostarting air supply fro depletion of the This event occurred as the result of the starting relay. starting and inadequate procedures and from a hangup in enginelogic failing to add control circuit complete stop before relay to assure the engine comes to aDuring the period that the relay was attempting a restart. fuel to the engine was blocked, while the starting timing out, air was uninhibited. This condition, with repeated start attempts, depleted starting air and rendered the diesel generator unavailable until the air system could be repressuriced. this event Review procedures and control system logic to assureProvide a detailed discussion of will not occur at your plant. how your system design, supplemented by procedures, precludes-Should the diesel generator the occurrence of this event. logic and procedures require starting and control circuit provide a description of the proposed modifications.

changes, Rescense There will be a 90-s time delay initiated when the engine is down during periodic surveillance testing or intentionally shut If during the 90-s time delay shut down for any other reason.

period a loss-of-offsite power signal is received or a manual start attempt is initiated, the engine will not start because If the operator depresses fuel to the engine will be blocked. start pushbutton during the 90-s time delay period, the manual starting air valves will open for 5 s and automatically This built-in 5-s time limit the close after the 5 s have elapsed. on the opening of the starting air valves is to prevent the 13 depletion of the starting air. This 5-s limit also applies to loss-of-offsite power start signals received at the engine control panel. However, if an emergency start signal (loss-of-coolant accident) is received at the control panel the engine control system during the 90-s time delay period, will automatically bypass the 90-s time delay and will allow fuel oil and starting air to be admitted to the engine.

Also, will be automatically bypassed, i.e.

the the 5-s time linit starting air valves remain open until the engine starts (starting air pressure above 150 psig), or until the starting Amend. 7 5/S4 Amend. 13 1/85 Q430.2-1 em -,, m__

VEGP-FSAR-Q s 1 air pressure drops to 150 psig. At this pressure, the au toma t:. c start attempt will stop because at 150 psig the starting air valves automatically close. At this point, the engine can only Pushing be started manually by pushing the manual start button. the manual start button will cause the starting air valves to I open again. There is no built-in time delay between the conclusion of the automatic start sequence and the manual start attempt in a situation as described above. In other worcs, if the engine fails to start automatically, a manual start can be initiated immediately. The starting air sequence is designed in this manner so that the manual start attempt capability is available if an automatic start attempt fails. The engine can be manually started in this manner until the starting air pressure drops to 90 psig. Generally, starting air pressure below 90 psig will not start the engine when an attempt is initiated. 13 Insummary)hanytimetheenginecontrolpanelreceivesan emergency (loss-of-coolant accident) start signa 19'the fuel stop interlock will be retracted automatically. It does not have to wait for the engine to stop, or to get through the 90-s time delay period. This assumes that the mode switch is in the " Operational" position, and the point of control switch is in the " Remote" position. For any other starting signals loss of offsite power) received by the control panel, (including fuel stop interlock will not be retracted automatically the until the 90-s time delay period has elapsed. Also, the 5-s time limit on the opening of the starting air valves will be active in the control logic for all normal start signals even if the 90-s time delay is not initiated. In order to maintain the emergency start capability of the diesel generator, operating procedures will specify that periodic surveillance testing is te be initiated only from the control room, i.e., control switch is in the " Remote" position. Also, the operator will be made aware of the built-in 90-s time delay and will be instructed not to initiate manual starting of the engine during this period. See figure 430.33-1. l YM 4t$ bcb <l 5 ce h bsY && -<t f qfL m ul ls. a - n q" A W Y A"" al j } $' n*Mwf ~~4 e a + g., ng )n s w. G A at f.___ _ 4 -- a g Amend. 7 5/64 Q430.2-2 Amend. 13 1/85 l13 E

O E VECP-FSAR-Q Ouestion 430.4 The availability on demand of an emergency diesel generator is dependent upon, among other things, the proper functioning of its controls and monitoring instrumentation. This equipment is generally panel mounted and in some instances the panels are mounted directly on the diesel generator skid. Major diesel engine damage has occurred at some operating plants from vibration-induced wear on skid-mounted control and monitoring instrumentation. This sensitive instrumentation is not made to withstand and function accurately for prolonged periods unde: i continuous vibrational stresses normally encountered with internal combustion engines. Operation of sensitive instrumentation under this environment rapidly deteriorates calibration, accuracy, and control signal output. Therefore, except for sensors and other equipment that must be directly mounted on the engine or associated piping, the controls and monitoring instrumentation should be installed on a free-standing floor-mounted panel separate from the engine sk:d and located on a vibration-free floor area. If the floor is not vibration free, the panel shall be equipped with vibration mounts. Confirm your compliance with the above requirement or provide justification for noncompliance. I

Response

The diesel generator buildings for Units 1 and 2 are similar in design. The concrete foundation for each building is 114 ft x 94 ft x9 ft thick. The diesel generator, centrol cabinets, and associated equipment are mounted on the building foundation. The diesel engine is a four-stroke cycle, V-type engine with an operating speed of 450 rpm. Because of the type of engine and the large mass of the foundation, the magnitude of vibration anticipated during engine operation will be within the limits cf IEEE 323-1974 qualifications. Except for sensors and local 13 gauges that are required to be mounted on the engine, there are no controls or monitoring instruments mounted on the engine. The mounting requirements for the diesel generator control cabinets specified by the vendor are that the cabinets are to be floor-mounted with anchor bolts without using vibration isolators. Also, the seismic qualification testing performed on the control cabinets by the vendor was conducted by bolting the cabinets to the shake table to simulate actual field mounting condition. The cabinets are qualified in accordance with IEEE 323-3974 which addresses vibration aging. 6"". j Q k <raf n dds.4.eW ca!S/$ * yL d .d, n," 4" ij,* ; M ",./ MG /" @ {e$ Amend-7 s/84 u a y " 7: 43o 4- ^mene. 13 1/es 9 A,,6% w.c.A N & 74 "7, &n. l

VEGP-FSAR-Q Ouestion 430.12 tanks are that the fuel oil storage f vented to the " valve house" located between the storage tanks. In the ESAR, you state additional information on the design Expand your FSAR to provide" valve house" which ensure adequate ventilation features of this of the structure so as to preclude a buildup of combustible the ventilation capability gases and the provisions to preventa consequence of any weather condition. being blocked as 4 J l

Response

which by v'irtue is a heavy distillate gas oil, of its specification and chemical composition does not contain Diesel fuel oil butane, and light petroleum distillate products such as propane,and can transform into readily gasoline, which are volatile conbustible gases. Therefore, at room temperature it is highly since the means for unlikely for a combustible gas to build up, present. producing the combustible gases is not roof of the valve U-bend vents are provided on the house to provide redundancy in ventilation under the most Two 4-in., Similarly, two 4-in., U-bend vents adverse weather conditions. fuel oil storage tank are provided on the roof of each diesel punpheuse. separate locations. One is The storage tank is vented in two 430.12-1 located outside of the valve house as shown in figure truck fill from the 4-in. ,M-an-the second is through a branch line line to the diesel fuel oil day tank ven,t line as shown in figure O.C.'.-1--J thc ES /* W /2 @ NM mms? is located outside of the valve house The storage tank vent line lines downstream of branched out into two separate 4-in. vent the flame arrester inside the valve house. One branch is roof with a 180 bend, and the i terminated above the valve house the valve house wall with a 13 t other branch is te:minated outside are lines outside the valve house 90 bend. Neither of the vent missile protected. the second venting for the storage tank is connected tojust upstream of the i The line diesel fuel oil day tank vent the diesel generator flame arrester located outsidearrester and connected piping outside the vent The flame E building.fnerator building are missile protected. f diese In the unlikely event that both of the diesel fuel oil storagedamaged or block } pg :a.theestorage2_ tank gide the v,alve house are point. tank vent lines ou still M vented by.the.second._ vent p M ffs O il p &./ & & W W W b h d / ~ . 7 g7 e o m.s... -,- . y; +%[h gtsw("" Mbhxdhg6.L %&ddoh4 i

VECP-FSAR-Q ) the diesel generator building. Also, the storage (l located at arrester housing side plates can be unbolted and tank flame removed for emergency venting of the storage tank. In addition, tank manway cover can be partially opened to provide 13 the storage ) emergency venting. are being developed for emergency venting Operating procedures of the storage tank. 4 i ) I f. l l i ) Amend. 7 5/84 Amend. 13 1/85 l 13 Q430.12-2 MM I m ~-. -.. - -...- - ~ ~ ~ ~ ~ ~ - ~ ~ - - - - -,. - _ _ _ _, _, _ _, __ _

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Q V!NT O R A^Y MK3 W st, 23sLg~ Q EL.71/'-3ff 8 s S new~ ) ll. y Q bor rm < ) % t SfCCuG YEW 7 //his W Mi f 8.7A/ED L/d! f 04ffft 6fALWTBA., nwr d u/LD/NS fpaWART/AV Al/AJfD A OZ57fN LJ 's, ' = n 7A'U ;K / M L E4.2PZl4" ) STORAGS* 'TrWK ) THE SECOND VENT LINE OUTSIDE THE DIESEL GENERATOR NOTE: BUILDING AND THE FUEL OIL STORAGE TANK BUILDING IS BURIED. THE LOWEST PORTION OF THIS VENT LINE IS AT EL 210*-1%" } Dm smrm t'ss voo7" ,c c a a m a r n-georgia Power pyj;',agg";;7 ;r'*do a'a~r a l FIGUF2 430.12-1 433-9 1 i

~ VECP-FSAR-Q Question 430.21 In FSAR table 9.5.4-1, you include a heading of "nonsafety-related portion" under the title of Standby Diesel Generator Fuel Oil Storage and Transfer System. Describe what portions of this system are nonsafety-related, show these portions on the piping and instrumentation diagram, and describe their :sciation from safety-related portions. Resconse The truck fill lines (from truck fill connection to the first valve connection) and the flame arresters for both the fuel oil storage and fuel oil day tanks are the nonsafety-related portions of the fuel oil storage and transfer system. The nonsafety-related portions of the system are designated as project class 626 and are shown in figure 9.5.4-1. See revised table 9.5.4-1. T' : flam arrcatcr con icts of a h::vy cast aluminur houci.-~ whi. contains a removable multiplate flame arresting ba ' Plates. the flame-arresting bank are made of alumi-which is noncorrosis in hydrocarbon gases. Net-free are .nrough the flame-arrestin ank is approximately three t .our times the corresponding pipe ize. Et-i n designed- -pe rmi t-g re a te r net-free-area-through ch passageway wreatly reducing surface friction and increasing.. w capaci .-- The aluminum 1.ank--can be easily removed for. quick ins .on and.. cleaning by unbolting e the aluminum housing side p es. Since there are no m.ing parts inside e flame arrestor, blockage of the ..t line or its ven. ting c - bility due to structural f .ure of its internal components unlikely In the event ..a t the housing is damaged, the ventins apability will _rease instead of decrease. Therefore, failur of the fl ..e arrester will not impair the safety function of th en: .:nt. '1 5 f, Amend. 7 5/84 Q430.21-1 Amend. 13 1/85

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VICP-FSAR-Q Question 430.33 low lube cil In F3AR paragraph 9.5.7.5 you oriefly discuss the pressure trip. Expand your FSAR to provide additional information on this trip function, including mere details on the pressure switches (manufacturer, model, etc.), the location of and identification of switches on the diesel generator, these ( f : Tu n. switches on the piping and instrumentation diagram these 9.5.4-1). O

Response

lube oil trip function is provided for the The low pressureshutdown of the engine during both normal and automatic safe emergency operations. It is a two out of three logic (see This means that there'are three oil paragraph 9.5.7.2.2). The lube installed on the engine lube oil inlet header. sensors set to trip open at 30 psig decaying oil pressure sensors are Their operation is similar to mechanical valves which pressure. are closed when pressure is above 30 psig and trip open on These sensors are monitored by a series of ~ decreasing pressure. pneumatic logic circuits mounted inside the engine control In the event that any two of the sensors are tripped panel. 60 psi pressure from an alarm / shutdown circuit open, they vent When venting occurs, a control in the pneumatic safety system. fuel rack shutdown cylinder at the air pressure extends the fuel racks to the no fuel engine. The cylinder moves the At the position, and the engine stops due to fuel starvation. switch in the engine control panel same time, a pressure indicates to the electrical system that a malfunction has occurred in the lube oil system. are manufactured by California Controls The oil pressure sensors switch is manufactured and the pressure Company (model B-4400), Inc. by Barksdale Controls Division, Transamerica Delaval, (medel E15.M90). The oil pressure sensors and switches are furnished by the integral parts of the engine and control engine manufacturer asshown on engine pneumatic schematic and engine panel. They are control panel schemati; drawings furnished by the vendor. shown on the piping and instrumentation Aherefore, they are not 33 g diagram. lubricating l The high temperature jacket water and. low pressure oil sensors remain active for tripping during the energency operation. As shown on figure 430.33-1, three sensors are used At least two of these to monitor each of these parameters. a shutdown occurs. For example, if sensors must trip before Amend. 7 5/84 Q430.33-1 Amend. 13 1/85 i i

s e VEOP-FSAR-Q ) only the low pressure lubricating oil sensor on line 10A trips, port 1 of the UPPER lA-6943 is a loss of pressure at there This causes element MEM-5 to stop transmitting which, assembly. The NOT-9 causes element NOT-9 to have an output. in turn, output is applied to port "A" of element AND-13, and is also applied to port 8 of the assembly through elements OR-17 and switch PS-48N OR-18. Pressure at port 8 activates pressure which indicate to the electrical system that one of the luce oil sensors has malfunctioned. If a second lube oil sensor were to indicate a malfunction condition, the engine vould shut down. For example, if the sensor en line E;10B vents, ir. addition to the sensor on line E-10A, then the loss of pre.ssure at port 3 of ) from element the upper IA-6943 board would result in an output AND-13. The AND-13 output pressurizes port 6 of the assembly, and is also applied to both port "B" of element NOT-12, and to 11 through orifice / check 16. Port 6 an accumulator pair at port the trip pressure causes pressure switch PS-42N to transmit indication to the alard system. NOT-12 has an output for until terminated by the accumulator approximately two minutes, 12 of the upper timer. The NOT-12 output pressurizes port assembly, and is transmitted through the lower assembly to Note that the port 4 pressurice port 4 of logic board 1A-7055. stop signal bypasses the NOT-17 and NOT-18 elements which 13 The port 4 signal produces a-inhibit a normal safety shutdown. frcm element AND-24 which extends the fuel rack memorited output This shutdown shutdown cylinder through port 7 of 1A-7055. signal is AND-24 which extends the fuel rack shutdown cylinder through port 7 of 1A-7055. This shutdown signal is terminated after approximately two minutes to allow the engine to be restarted if the problem is corrected. includes the engine control panel schematic, Figure 430.33-1 engine pneumatic schematic, lube oil piping schematic, and control logic diagram. sensors are mounted on the engine, but all The lube oil pressure other related pneumatic safety components are mounted in the Seismic testing of a panel to simulate engine control panels. installation at VEGP has been performed and has its permanent One engine control panel has passed the seismic shake test. The other three panels are seismically been seismically tested. identical to the one t,tsted. qualified since they areengine control panels meet the faismic Category 1 Therefore, the inside the panel, which requirements. Safety-related components required to perform safety control functions of the diesel l are environmentally qualified per IEEE 323-1974. are safety-related components are powered by Class 1E generator, Also, these and the peumatic air supply to the electrical power supply, engine control panel is from safety-related starting air receiver. s Amend. 7 5/84 jZlgt,( f{ ) Amend, 13 1/95 ,/ Q430.33-2 N

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VEGP-ESAR-Q g Question 430.9 In ESAR section 1.9, you state that the design of the fuel oil storage and transfer system conforms to the requirements of

However, Regulatory Guide 1.137, which endorses ANSI N-195.

's there is no reference to testing of fuel oil as discussed in Appendix B of ANSI N-195 and position C2 of Regulatory Guide 1.137. Revise your ESAR tc include a discussion of your conformance to these requirements. 3 Resconse VEGP conformance to Regulatory Guide 1.137 is addressed in subsection 1.9.137. VEGP does not conform to the requirements nf _sMst m os,o7c an.~s < v a A,1Th 2 t;; tin ~ r ; qu i;;;c n- ; ; f 'S' ~ "'QC-lo'6 enderrer '.ST? 022"? 3 : us of p :: carr:lation h^t"een thir tert 2nd fuel c'_it2bility ir rtrr2;e, "Er? h2r 12 requirc=:nt: Of ACTM O227 f o r th s :c. ;f ACIM rubctituted the The testing requirements for the diesel generator fuel 'C22~1. oil will be specified in the Technical Specifications, which are scheduled to be submitted to the Nuclear Regulatory Commission by June 1985. follow //c3 The VEGP fuel oil surveillance program will, however, ! bP m' program cuch ac th; enc-that was approved for the McGuire Nuclear Station. ) e j %d i ?(_' Amend. 7 5/94 Amend. 8 7/84 Amend. 9 8/84 Q430.9-1 Amend. 13 1/85

WUYG f f 2-20-85 VOdTLE The following items are the TER input for the Vogtle Initial Plant Test Program through FSAR Amendment 14 (2-85) and draft FSAR Anendment 15 (3-85). Item Description 640.03 The Service Air System Preoperational Test (FSAR Subsection 14.2.8.1.56), the Instrument Air System Preoperational Test (FSAR Subsection 14.2.8.1.57), or other test abstracts should be modified to demonstrate that the valves identified in FSAR Table 9.3.1-2 (Safety-Related Pneumatically Operated Valves) fail to the safe position on loss of air in accordance with position C.8 of Regulatory Guide 1.68.3, Preoperational Testing of Instrument and Control Air Systems. 640.04 B. The response to this item should reference the Pressurizer Heater and Spray Capability and Ccatinuous Spray Flow Verification Test (FSAR Subsection 14.2.8.2.2) since part of the tests referenced in the response are accomplished in this test abstract. 440.07 The Power Coefficient Determination Test (FSAR Subsection f 14.2.8.2.26) should be modified to provide appropriate test prerequisites (satisfactorily addressed by draft Amendment 15). .640.08 A. Appropriate acceptance criteria should be provided for the following: 1. Preoperational test abstract numbers (FSAR Subsection 14.2.8.1): 7, 8, 11, 14-26, 28, 31, 32, 34, 41, 47-50, 53, 59, 63, 64, 71, 74, 76, 84-86,f9-91, 93, 95-100, 102-105, and 107-110 (all items except L5! {6, 4], 84, 9 9_, 100,.10 3, - 104, and 107-110 satisfactorily addressed by draft Amendment '~~ TE). 2. Startup test abstract numbers (FSAR Subsection 14.2.8.2): 2-5, 7, 9, 10, 14, 15, 24, 25, 27, 35, 36, 43-48, 52 and 53 (all items except,5, 24, 27, 4_7, 48, and 53 satisfactorily addressed by draft AmendmeHt 15). C. The acceptance criteria for FSAR Subsection 14.2.8.1.83 should be modified in accordance with the response to this item. 640.09 B. The Turbine-Driven Auxiliary Feedwater System Preoperational Test (FSAR Subsection 14.2.8.1.6) should be modified to secure power to the auxiliary feedwater pumphouse HVAC air supply fans to address the concerns of this item. C. The Turbine-Driven Auxiliary Fr edwater System Pr'eoperational Test (FSAR Subsection 14.2.8.1.6) should be modified to ensure that i the automatic, cold, quick start follows an idle period of / sufficient duration to demonstrate that the unit is not subject to startup overspeed trip due to drain-down of oil fromthespeef control mechanism. Alternately, show that this concern is not applicable to your facility. / l

6.40.12 The Ventilat ion capabilit y Test (FFAR Subsection 14.2.8.2.58), or other test abstracts, should be modified in accordance with the response t o this item (satisfactorily addressed by 2 raft Amendment 15). 640.20 B. The 125-V de preoperational test abstracts (FSAR Subsections 14.2.8.1.69 and 14.2.8.1.74) or other appropriate test abstracts should be modified to demonstrate that testing of de loads necessary for safe shutdown is conducted at minimum de system voltage or that the voltage drop at load to these components is measured to verify that the de loads are supplied with appropriate voltage under minimum battery voltage conditions. 640.30 ,Af A'. Operability of main steam bypass valves will be described in the Main Steam System Preoperational Test (FSAR Subsection 14.2.8.1.1) in a future amendment (satisfactorily addressed by draft Amendment 15). ,27 The Reactor Coolant System (RCS) Preoperational Test (FSAR Subsection 14.2.8.1.7) should provide a test method and acceptance criteria regarding testing of pressurizer safety valves (satisfactorily addressed by draft Amendment 15). C. Testing should verify that the capacity of pressurizer and steam generator power-operated relief valves are in accordance with the accident analysis assumptions for maximum valve capacity (FSAR Subsections 15.6.1 and 15.1.4, respectively). 640.32 FSAR Subsection 14.2.8 (Individual Test Descriptions) should be expanded to address the following systems listed in Regulatory Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plants, Revision 2, Appendix A: J aw4r The Fuel Building Hoists and Elevator Preoperational Test (FSAR Subsection 14.2.8.1.60) and the Fuel Transfer System Preoperational Test (FSAR Subsection 14.2.8.1.61) should be modified to include verification of the performance of the dynamic (100%) and static (125%) load tests of cranes and hoists associated with fuel handling and storage in accordance with the response to this item (ratisfactorily addressed by draft Amendment 15). Isswdr The Fuel Handling and Vessel Servicing Preoperational Test I (FSAR Subsection 14.2.8.1.59) should be modified to include l verification of the performance of the dynamic (100%) load j tests of the polar crane (satisfactorily addressed by draft i Amendment 15). 5.q Operability of the gross failed fuel detector should be demonstrated at 25% and 100% power. 5.c.c Operability of the gaseous and liquid radwaste systems should be demonstrated during the power ascension tesA phase. l I L

5.f.f vent ilation and air condit ioning syst em operability should be - de.nonstrated at 50% and 300% power. The Ventilation capability test (PSAR Subsection 14. 2. 8. 2. 5B) should be re ferenced a s. it addresses the concerns of this item. 5.k.k FSAR Subsection 1.9.68.2 should be modified to provide justification for exception to the loss of or bypass of feedwater heaters test. Jgpf The RCS Leak Rate Preoperational Test (FSAR Subsection 14.2.8.1.10). .was modified to delete the test objectives relating to testing of the containment cooler condensate measuring system. The test objectives are now part of the Containment, Auxiliary, Control, and Fuel Handling' Building Drains System Preoperational Test (FSAR Subsection s 14.2.8.1.54). The test objectives, test method, and acceptance criteria for the containment cooler condensate system should be included as a whole in either test abstract, rather than arbitrarily separated (satisfactorily addressed by draft Amendment 15). 7 Y s { t l

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