ML20245F690

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Ack Receipt of 890317 Response to Concerns Identified from Insp Repts 50-277/89-07 & 50-278/89-07.Note That Attachment 1 to Ltr Consists of One Page & Appears to Be Incomplete
ML20245F690
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 04/20/1989
From: Strosnider J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Corbin McNeil
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8905020465
Download: ML20245F690 (2)


See also: IR 05000277/1989007

Text

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APR 2 01989

Docket Nos. 50-277

50-278

Philadelphia Electric Company

ATTN: Mr. C. A. McNeill

Executive Vice President-Nuclear

Correspondence Control Desk

P. O. Box 7520

Philadelphia, Pennsylvania 19101

Gentlemen:

Subject: Inspection Nos. 50-277/89-07 and 50-278/89-07

This letter refers to your letter dated March 17, 1989, in response to concerns

identified during the NRC special electrical team inspection as presented at

the exit meeting on February 10, 1989 and transmitted in a subsequent letter

dated March 24, 1989

Thank you for informing us of the corrective and preventive actions documented

in your letter. We note that Attachment I to your letter consists of one page

and appears to be incomplete. We would appreciate it if you could forward a

complete copy of the subject attachment. Your corrective actions with regard

to the subject concerns will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Original Signed:By:

Jack R. Strosni. der

Jack Strosnider, Chief

Engineering Branch

Division of Reactor Safety

8905020465 890420

PDR

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G ADOCK 05000277

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0FFICIAL RECORD COPY RL PB 89-07 - 0001.0.0

04/19/89 gg

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. APR 2 01989 1

Philadelphia Electric' Company 2

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John S. Kemper, Sr , Senior Vice President-Nuclear )

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J. W. Gallagher, Vice President, Nuclear Services

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E. C. Kistner, Chairman, Nuclear Review Board j

Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station 1

Jack drban, General Manager, Fuels Department, Delmarva' Power & Light Co. i

John F. Franz, Plant Manager, Peach Bottom Atomic Power Station )

Troy B. Conner, Jr., Esquire

W. H. Hirst, Director, Joint Generation Projects Department,

Atlantic Electric

Bryan W. Gorman,: Manager, External Af fairs

Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)

Raymond L. Hovis, Esquire

Thomas Magette', Power Plant Siting, Nuclear Evaluations

W. M. Alden, Director, Licensing Section

Doris Poulsen, Secretary of. Harford County Council

Public Document Room (PDR)

local Public Decument Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth.of Pen 1sylvania

bec w/ enc 1:

Region.I Docket Room (with concurrences)

";n;;;= nt ^.;;i ct:n t , DR"^ ' (;'/c en:1)

Section Chief, DRP

PAC (23) SfiP :nd (2) E:pectier Reports

Robert'J.' Bores,.DRSS

- R. Martin,-NRR

M. Johnson, EDO

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Koshy/pmb Mathew Anderson

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OFFICIAL RECORD COPY RL PB 89-07 - 0002.0.0

04/12/89

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PHILADELPHIA ELECTRIC COMPANY

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, 2301 MARKET STREET

P.O. BOX 8699

PHILADELPHIA A PA.19101

(21s) e414502

S. J. KOWALSKI

vlCE-PRE 5tOENT

muc6s an s neeno e mene

March 2 7,1989

Docket Nos. 50-277

50-278

U. S. Nuclear Regu3atory Commission

ATTN: Document Control Desk

Washington, DC 20555

SUBJECT: Peach Bottom Atomic Power Station, Units 2 and 3

Special Electrical Team Inspection

50-277/89-07 and 50-278/89-07

REFERENCE: Letter from S. J. Kowalski (PEco) to D. S. Nuclear Regulatory

Commission dated March 3, 1989

Dear Sir:

This 3etter provides an advance response to the potential restart issues

identified by the NRC during the Specia] Electrica) Team Inspection which was

conducted January 30 through Febrenry 10, 1989. At the exit meeting for the

inspection, seven potential restart issues were identified. One of the seven

issues, " underrated fuse and wrong type of fuse", was a two part issue. In

subsequent telephone discussions with Mr. T. Koshy, Inspect $,n Team Leader, he

indicated that each part would be a separate restart issue.

In the 3etter referenced above, Ph13ade3phia Electric committed to

provide a response for each of these issues by March 17, 1989, assuming the

Inspection Report was issued in sufficient time prior to this date. Although

the Inspection Report has not been received by Philadelphia Electric, we are

providing our responses for each of the potential restart issues based on our

current understanding of them. These responses are provided as Attachments 3

through 8 to this 3etter. Calculations and supporting documentation for these

responses are available for your inspection at our corporate office. The

purpose of our submitting these advanced responses is to provide the NRC with

sufficient time to support efforts necessary for restart of Unit 2 in ear 3y

April , 1989.

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Please do not hesitate to contact us if you have any questions concerning

our interpretation or response to the restart issues.

Sincerely

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Attachment 1: Voltage Adequacy at DC MOV's

Attachment 2: Questionable Margin f 2B and 2D Battery

Attachment 3: Underrated Fuse

Attachment 4: Wrong Type of Fuses

Attachment 5: Lack of Surved33ance

Attachment 6: Questionable 13.8kv Switchgear Interrupting Capacity

Attachment 7: Adequacy of MCC Feeder Cable Ampacity Versus Breaker Settings

Attachment 8: Diesel Generator Load Analysis

cc: N.3 T..' Russell, Administrator, Region I, USNRC

C. J. Anderson, Section Chief, Region I, USNRC

T. P. Johnson, USNRC Senior Resident Inspector

T. Koshy, Lead Reactor Engineer, Region I, USNRC

R. E. Martin, Project Manager, NRR, USNRC

T. E. Magette, State of Maryland

J. Urban, De3marva Power

J. T. Boettger, Public Service Electric & Cas

H. C. Schwemm, Atlantic Electric

T. M. Cerusky, Commonwealth of Pennsy3vania

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Attachment 1

' TITLE: VOLTAGE ADEQUACY AT DC MOV's

PECO INTERPRETATION OF CONCERN

Several potential operability problems resulting from design deficiencies in power

supplies for safety related DC motor operated valves have recently been identified.

The NRC Information Notice No. 88-72 entitled, " inadequacies in the Design of DC

Motor Operated Valves", was issued to inform utilities of the potential problems in

the design of dc motor operated valves. It was expected that recipients would

review the NRC Information Notice for applicability to their facilities and consider

actions as appropriate. At the time of the NRC Special Electrical Team Inspection,

PECo had not completed its review of NRC Information Notice No. 88-72.

More recently the NRC issued NRC Information Notice No. 89-11 entitled, " Failure of

DC Motor Operated Valves to Develop Rated Torque Because of Improper Cable

Sizing."

Subsequent to the NRC Special Electrical Team Inspection, NRC Information Notice

No. 89-16 entitled " Excessive Voltage Drop in DC Systems" was issued. This notice

extends the concern of adequate voltage beyond DC motor operated valves.

PECO RESPONSE

INPO SER 25-88 is related to NRC Information Notice No. 88-72. Both of these

documents and NRC Information Notice No. 89-16 were received and are being

tracked in the Operating Experience Assessment Program.

The PECo position on issues of INPO SER 25-88 and NRC Information Notice 88-72

have been defined. It has been determined that a design review of dc motor

operated valves is required and includes the following activities:

A. Confirmation of the electrical design of MOV's in PBAPS Unit 2.

B. Confirmation of the electrical design of MOV's in PBAPS Unit 3.

To support the Unit 2 restart activities, item A has been evaluated as described

below, item B will be completed prior to restart of the Unit 3.

To evaluate the electrical design of dc motor operated valves in the PBAPS Unit 2,

calculations were performed to addrets the capability of each valve to accomplish

the required safety function under the minimum anticipated dc power distribution

system voltage combined with elevated temperatures resulting from postulated

design basis accidents.

This evaluation, which incorporated the concerns presented in NRC Information

Notice 89-16, indicated acceptable operability of dc MOV's with the exception of

the following valves:

MO-2-23-014 MO-2-23-019 MO-2-23-020

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For these valves the results of the calculations indicate that the motors, which utilize

step starting resistors, may not actuate their associated valves immediately under

the applicable limiting case system and environmental conditions. It was concluded j

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Attachment 2

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TITLE: QUESTIONABLE MARGIN OF 28 AND 2D BATTERY

PECO INTERPRETATION OF CONCERN

Site Question for Engineering SOE P-50080, which is the most recent evaluation of

the capacity of batteries 2BD001 and 2DD001, concludes that these batteries have a

design margin and aging factor of 1.0 and 1.15, respectively. IEEE Standard 485

recommends a design margin of 1.15 and an aging factor of 1.25 when sizing a new

battery. Therefore,it is not obvious that batteries 2BD001 and 2DD001 have

sufficient capacity.

PECO RESPONSE

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A new calculation has been prepared to evaluate the margin between the rated

capacity of the battories and the design load profile.This calculation uses the

existing calculations as a basis for the design load' profile and includes an allowance

of 5% for uncertainty in the magnitude of individualloads presently not confirmed

by field walkdown. The calculation evaluates the margin for both a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 4

hour duty cycle. The results are as follows:

Percent Margin Percent Margin

for 2 Hour for 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

Battery Duty Cycle Duty Cycle

2 AD001 104 97

280001 52 8

2CD001 104 97

2DD001 52 8

This new calculation also evaluates the consequences of removing the starting

resistors for various dc motor operated valve motors to resolve concerns related to

NRC Information Notice 88 72. The increased inrush current has an impact on the

battery load profile, reducing the available margin. _

PEco has decided to adopt a design load profile of less than four hours, consistent

with typical utility practice. Since the diesels start in approximately 10 seconds and

restore power to the 480V auxiliaries including the battery chargers within' 16

seconds after loss of offsite power, the batteries are only required to provide power

for approximately 16 seconds. Thus, the typical utility practice of using a design

load profile with a duration of two hours provides a significant degree of margin,

The results of the margin calculations, with the increased inrush current due to

removing starting resistors in response to NRC Information Notice 88-72, are as

follows:

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Percent Margin

for 2 Hour

. Battery Duty Cycle

2AD001 104

2BD001 21

2CD001 104

2DD001 21

IEEE Standard 485-1983, which is applicable for sizing a new battery, recommends a .

design factor of 1.15 and an aging factor of 1.25, for a total margin of 44E

However,IEEE Standard 450-1980, which is applicable for the ongoing assessment

of available margin, implies in Section 6.6, " Service Test," that a battery is

acceptable if it passes a service test which duplicates the design battery duty cycle,

as this demonstrates that the battery meets the design requirements of the system.

A battery is acceptable for continued use when the design load profile changes,

provided that a margin exists between the capacity of existing battery and that

required to meet the revised load profile.

The battery discharge tests performed in 1987 demor.strated that the tested

capacity of both batteries exceeded their rated capacity. Since battery capacity

normally decreases only a few percent during the first 10 years of battery life, PECo

concludes that the present battery capacity is still in excess of rated capacity.

Therefore; PECo concludes that the existing Unit 2 batteries are adequate for the

restart of Peach Bottom Unit 2 without further analysis or testing. Due to the

similarity of system design between Unit 2 and 3, confirmation of the adequacy of

the Unit 3 battery is expected. Nonetheless, a similar evaluation of the Unit 3

batteries will be comp 8eted prior to the restart of Unit 3.

PECo is proceeding to prepare new base line calculations to define the loading i

profile for each Class 1E battery in Units 2 and 3. These calculations will be based on I

field walkdown data to establish the load from individual components and will be j

used for load manr ement control to demonstrate that each battery is suitable for  !

continued use in accordance with IEEE Standard 450. These calculations will be i

updated and formally revised on a regular basis to account for load changes as the

result of plant modifications and plant operating procedure changes. Walkdown

data is presently being collected, and preparation of these design basis calculations

for Unit 2 will be completed in 1989, and the calculations for Unit 3 will be

completed in 1990.

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TITLE: UNDERRATED FUSES

PECO INTERPRETATION OF CONCERN

NRC Information Notice 84-65 " Underrated fuses which may adversely affect

operation of essential electrical equipment" was issued on August 6,1984. This

notice identified the Gould-Shawmut TR-R100 fuses as having a dc voltage rating of

less than 250 volts.

During the recent NRC Special Electncal Team Inspection at the Peach Bottom

Atomic Power Station Units 2 & 3, the following Gould - Shawmut TR-R100 fuses

were identified in 250Vdc safety related applications:

Bus: 20D11

Circuit 29-1100

RHR Pump Suction

Cooling Valve MO-2-10-017

Bus: 30D011  :

Circuit 29-1100

RHR Pump Suction

Cooling Valve MO-3-10-017

PECO RESPONSE

in response to the concern of TR-R100 fuses installed in safety related 250VDC

applications, Non Conformance Reports (NCR's) P89050-216 and P89111-216 were

generated to resolve this issue at PBAPS Units 2 & 3. These NCR's have been

dispositioned a replace the TR-R100 Gould - Shawmut fuses with

TR-5100 Gould - Shawmut fuses. The installation of the safety related TR-5100 fuse

in MCC 20D11 (30D11) to replace the existing TR-R100 fuses will be completed prior

to restart of each unit.

The specifications for Gould - Shawmut TR-R and TR-5 fuses are described below:

Model TR-R TR-5

Ampere rating 100a 100a

Class RK5 RK5

Sym. Short Circuit Rating 200 KAIC 200 KAIC

UL Listed No Yes

l DC Voltage Rating (Per UL 198L) 200VDC 600VDC

The application of the TR-5100 fuse will provide a 600VDC rating while maintaining

coordination with the upstream protective device. Calculation EE-7 Section E6 has

been revised to document circuit coordination with the new TR-5100 fuse.

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Attachment 3

A design review of the 125/250VDC power system was performed that concluded

the ratings of the remaining fuses are appropriate for the design application. A

walkdown of the subject fuses has confirmed that the installed fuses match the

design drawings.

An engineering memorandum will be issued to electrical engineering and design

personnel to clarify the significance of AC and DC voltage ratings of DC

components. Special consideration for voltage the rating of fuses will be

highlighted. This memo will be issued prior to restart of Unit 2.

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TITLE: WRONG TYPE OF FUSEC

PECO INTERPRETATION OF CONCEfiN

A. The dc control fuses installed in 250 Vdc MCC 20D11 compartment 29-1112 _)

= and 29-1121 are 10A while other MCC compartments have 6A fuses in their

control circuits. The adequacy of this situation needs to be evaluated.-

B.1 Drawings E-26 and E 27 identify the fuses in fuse box 20D19 and 30D19 as

Bussman Class RK5 type FRN,250 Vac. The installed fuses are Gould i

Shawmut Class RK5, type TR-R 250 Vac. The adequacy of the Gould  !

Shawmut fuses needs to be evaluated, i

8.2 Circuits 29-BD30604 and 29-BD30605 have 30A type "NON" and "KON" '

fuses installed while drawing E-26 indicates a type "FRN" fuse should be

used. This discrepancy needs to be evaluated.

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PECO RESPONSE

A. Inconsistency of Control Fuse Sizes in 250 Vdc MCC:

The primary purpose of a control fuse is to provide short circuit protection.

Control fuses are sized such that the interrupting rating is not less than the

maximum short circuit current of the control circuit. Although different

from the other control circuit fuses in the MCC 20D11, the existing 10A fuses

for compartments 29-1112 and 29-1121 provide adequate short circuit

protection.

To provide consistency of control circuit protection inside the Unit 2 MCC's,

the 10A fuses will be changed to 6A fast acting Bussman Limitron type fuses.

This work will be accomplished prior to restart of Unit 2. Any corresponding -

changes required in the Unit 3 MCC will be accomplished prior to restart of i

that unit.

B. Installed fuse type inconsistent with design documents:

1. An engineering evaluation indicated the time-current characteristics of

the Gould&.awmut TR-R fuse was similar to the Bussman FRN and .

resulted in no change to the electrical coordination,

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Non Conformance Report (NCR) P899025 312 wasinitiated and

dispositioned to reflect the installed Gould-Shawmut TR-R fuses on

single line drawings, E-26, sheet 1, and E-27, sheet 1. Calculation EE-7,

Section E6 was also updated to reflect the time-c'urrent characteristics

for the type TR-R fuses. This discrepancy was identified and

documented by PECo prior to the NRC Special Electrical Team

inspection. The related documentation has been revised and issued.

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2. An engineering evaluation was performed and showed that the 'l

installed 30A "NON" and "KON" fuses provide electrical system .

coordination with the 20H type FRN supply fuse in 125 Vdc panel

2BD306. However, to p ide consistency with the design documents,

the "NON" and "KON fu>es are being replaced with "FRN" type fuses  ;

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as shown on drawing E 26, Sheet 1. This replacement will be completed

prior to restart of PB APS Unit 2.

A walkdown of the Unit 2125/250 Vdc system has confirmed that no

additional discrepancies exist between the single line drawings and the

installed fuses. A similar walkdown for Unit 3 will be done prior to restart of l

Unit 3. Any identified Unit 3 fuse discrepancies will be resolved prior to l

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Unit 3 restart.

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TITLE: LACK OF SURVEILLANCE

PECO' INTERPRETATION OF CONCERN

The PBAPS 125V battery charger maintenance procedure M-57.4 does not include

maintenance for the AC and DC breakers internal to the battery charger. Is this

exclusion of breakers from Preventative Maintenance (PM) consistent with the

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PBAPS commitment and program for Preventative Maintenance for equipment and J

components or,is it an oversight where a vendor recommended maintenance has

not been included in the plant PM procedure? ,

if the exclusion of the breakers from the plant PM is an oversight,is this an isolated

deviation from the program or a result of programmatic weakness that would cause

recurrence of a similar nature if not corrected?

Relay 27FF in the Diesel Generator System was not included in the yearly PM or

Surveillance Testing. Is this calibration required to ensure operabilay or per vendor

recommendation and thus not included in PM or ST by an oversight? If it is an

oversight,is it an isolated case, or the result of a weakness in the PM program that

may cause a recurrence of a similar nature?

PECO RESPONSE I

The surveillance activity of safety related components such as the breakers and

relays is based on vendor recommendations given in Technical Manuals and EQ

documentation.

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To assure adequate surveillance is being maintained a detailed review of the

present PECo position on Equipment Surveillance, Generic Letter 83-28 actions, and 1

other identified concerns was performed. The results of the review are summarized

below:

1) Aspects of Generic Letter 83 28 addressing utility actions on vendor.

information for safety-related components have been fully responded to by

PECo.

2) PECo commitments of Preventative Maintenance and Surveillance in areas

identified in NRC Inspection Report 86-25 have been fulfilled. The Diesel

Generator Room Supply Fans and Battery Room Exhaust Fans have been

included in the Preventative Maintenance Program.

3) The Vendor Manual Update Program was completed in 1988, including the

revision of affected procedures.

4) PB APS has a committment to the Commonwealth of Pa. to have a program

defined for review, approval, and control of vendor manuals prior to restart of ,

Unit 2.

5) Vendor manuals reviewed during the preparation of this response were found

! controlled and up-to-date.

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Attachment 5

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'6)- Breaker and relay maintenance was included in the Plant Program where l

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require'd by the vendor. i

The 'AC and DC breakers identified during the inspection are installed in each -

battery charger. The basic function of the circuit breakers is to serve as a disconnect l

switch to isolate the battery charger from the AC and DC systems. 'Ine imakers are J

not used as protective devices either for thermal overload or short circuit current. )

The circuit breakers as designed are adequate to achieve their functions in the l

battery charger without routine calibration. Exercising the breakers during )

maintenance of the battery charger is sufficient to provide assurance of their i

intended function. The confirmation of equipment isolation will be included in the

PM program for each the battery charger prior to Unit 2 restart.

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Relay 27FF is a loss of field flashing voltage alarm relay, provided for each diesel

generator. Relay 27FF has been provided to detect a loss of the 125Vdc supply _

voltage to the exciter and to annunciate the loss of voltage after a 20 second time -

delay. Improper relay operation will not prevent the diesel generators from -  !

starting or performing their safety function. The 27FF relays will be added to the

PM program associated with each diesel generator and will be functionally tested

prior to Unit 2 restart.

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Attachment 6

TITLE: QUES'TIONABLE 13.8 KV SWITCHGEglNTERRUPTING CAPACITY

PECO INTERPRETATION OF CONCERN

The NRC reviewed the PBAPS Calculation EE-7, Subsection E2 " AC System Fault

Calculation" and raised a concern regarding the low margin in the 13.8kv circuit

breaker interrupting duty. The margin was 1.3% as shown in the calculation.

The NRC also questioned the limiting case electrical' distribution bus configuration j

assumed in the subject calculation. This case assumed "the recirc pump M-G set 1

tripped, the auxiliary buses fast transferred to one offsite power source, and cooling i

towers D & E tripped". The NRC requested comparison of this case with the plant i

startup configuration of two recirculation pump M-G sets running on two offsite 1

power sources before transferring to the one auxiliary system. It was pointed out to

the NRC that the subject calculation is conservative as it did not include f actors such

as cable impedance. The NRC requested an evaluation of the conservatism in the

calculation.

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PECO RESPONSE

"AC System Fault Calculation" was prepared for the Appendix R Breaker / Relay _-

Coordination Study in 1986. The 1.3% margin of 13.8kv breaker interrupting

upacity is based on ANSI standard C37.010-1979.

The calculation has been revised to include the operating configuration case of two

recirculation pump M G sets running on offsite sources. The margin obtained is

11.2% as compared with 1.3%. This confirms that the existing selection of the worst

case operating condition was correct.

The calculation has also been up' d ated to quantify the conservatism resulting from

exclusion of the 13.8kv cable impedance. Accounting for cable impedance, the

marginincreases from 1.3% to 13.4%

Therefore,it is concluded that the PB APS Units 2 & 3 electrical system has adequate 'l

short circuit withstanding capability, as proven by the updated calculations. )

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Attachment 7

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l TITLE: ADEQUACY OF MCC FEEDER CABLE AMPACITY VERSUS BREAKER SETTINGS

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PECO INTERPRETATION OF CONCERN l

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Calculation EE-7, Subsection E-3, Page 5, notes that the long time delay settings of I

certain breakers feeding the MCC's exceed the ampacity of the feeder cables. As a

result, the possibility exists that without protective action, these cables may become 1

overloaded, and therefore overheated.

Calculation EE-7, Subsection E-3, documents breaker coordination. However,it does I

not document the MCC feeder cable ampacities exactly, nor does it document the l

design load on the MCC feeders. The determination of the adequacy of the breaker 1

settings for equipment and cable protection requires additional documentation. l

PECO RESPONSE

PECo has maintained the design philosophy that breakers feeding MCC's should be

set to avoid the possibilty of inadvertent tripping. PECo considers the continued ,

operation of Class 1E systems is more critical than preventing minor short duration

cable overloading.

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Feeder cables to individual loads require overcurrent protection, in addition to fault j

protection, since a compoaent 'ailure or individual fault could result in overloading '

of these dedicated feeder cables. However, cables to MCC's are not subject to the

same type of overloads as the feeders to individualloads. The MCC feeder cables l

require short circuit protection, but the overload protection is controlled by the 1

design process which limits the amount of load applied, rather than from breaker l

overcurrent protection settings. Therefore, the long time element of the MCC  !

feeder breakers is not essential for cable overload protection. However, the l

continued operation of the MCC is essential for plant safety in the event of a design j

basis accident. Therefore,it is more prudent to set the long time delay element at a i

relatively high level to avoid the possibility of inadvertent tripping. l

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The cables feeding each MC . are sized on the basis of the anticipated running load

for the MCC. In response to the NRC Special Electrical Team inspection concern, a

reevaluation has been performed which confirms that the feeder cable ampacity l

exceeds 125% of the anticipated worst case running load on the MCC. Therefore,

there is no need to increase the size of any of the feeder cables. '

PECo therefore concludes that the design, as it stands, is adequate and imposes no

constraint on the restart of either Unit 2 or Unit 3.

PEco will revise calculation EE-7, Subsection E-3, to document the design philosophy

for MCC feeder long time cable protection and to confirm the adequacy of the cable

ampacity for the anticipated coincidentalloading.

PECo will review the feasibility and cost benefit of providing an improved design for

MCC feeder cable overcurrent protection. The review will be completed during the

next refuel cycle following restart of Unit 2 and 3.

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Attachment 8

TITLE: DIESM. GENERATOR LOAD ANALYSIS

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PECO INTERPRETATION OF CONCERN  !

The NRC 5pecial Electrical Inspection Team identified inconsistencies between the j

emergency diesel generator loading calculation and the mformation presented in

the FSAR Table 8.5.2.  !

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Based on these inconsistencies the adequacy of the diesel generator to supply )

power during a plant DB A and shutdown conditions was questioned. Specifically {

the following concerns were identified: l

1, Appropriate conversion of horsepower to KW loading of major  !

indiviaual loads.

.

2. Determination of the worst case dieselloading based on the l

conditions, described in the FSAR Table 8.5.2. )

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3. Confirmation that the diesel generators are capable of supplying the _

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identified worst case load for the required period of operation.

PECO RESPONSE

A review of the Diesel Generator and Emergency Bus Loading tables of the UFSAR '

show that the highest load occurs on DG El during the 10-60 minute time interval of

the DG loading cycle.

The totalload on DG El during this time interval consists c,f two 4 kV loads (one RHR

pump and one Core Spray pump) and two 480V load groups each of which is

supplied by a 500 KVA load center transformer.

The RH_R pump motor load has been conservatively calculated to be 1604 KW based

on the motor rating of 2000 hp and a fullload efficiency of 93%. This is the value. I

used for the RHR pump motor in the load tabulation of the Voltage Regulation

Study, dated January 1989. This value is considered conservative, as demonstrated

by the pump test curves. These curves indicate a pump runout condition of about

12,000 GPM rec uiring 1900 BHP, while the design rated flow of 10,000 GPM requires

1,800 BHP whic, equates to a 1,444 KW load at 93% efficiency.

The second 4 kV load on DG El is the core spray pump. The nameplate values of 600 '

horsepower and 93% efficiency result in a 481 KW design load.

Loads at 480V and below have been reviewed against the loads used in the Voltage

Regulation Study, the single line diagrams, and schematics to determine

conservative load values.

Since the major loads have been calculated on the basis of rated horsepower and i

nameplate efficiency, the potential for inadvertent overloading has been aveided

as described in Section 2 of Generic Letter 8815, power. factor misapplication.

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- _ _ _ _ . _ - - . _ _ _ _ _ .

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. Attachment 8

, The diesel generator is not operated for base load generation, and is only required  ;

for sustained operation following a LOOP /LOCA and prior to restoration of offsite

power. Therefore the 200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> rating is applicable.

The total KW load, assuming conservative loadings as described above is 3,006 KW l

for DG E1. This load is within the 3,100 KW,200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> rating of the unit. It is

therefore concluded that the diesel generators are adequately rated to support

DBA loading for Unit 2 and emergency shutdown of Unit 3.

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