AECM-86-0249, Forwards Summary of 860806 Meeting W/Nrc Re 860707 Proposal to Limit Deferral of Certain Insps of Div II Emergency Diesel Generator.Requests Prompt Approval in Order to Support Final Preparations for 860905 Refueling Outage

Forwards Summary of 860806 Meeting W/Nrc Re 860707 Proposal to Limit Deferral of Certain Insps of Div II Emergency Diesel Generator.Requests Prompt Approval in Order to Support Final Preparations for 860905 Refueling Outage

ML20205F370
Person / Time
Site:	Grand Gulf
Issue date:	08/13/1986
From:	Kingsley O MISSISSIPPI POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AECM-86-0249, AECM-86-249, TAC-61781, NUDOCS 8608190169
Download: ML20205F370 (17)

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B O X 164 0, J AC K S O N, MIS SIS SIP PI 39215-1640 August 13, 1986 j O. D. KINGSLEY, J R.

VICE PREllDENT NUCLE AR OPERATIONS U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 Attention: Mr. Harold R. Denton, Director

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Limited Deferral of Inspections on Division II EDG, Supplemental Information AECH-86/0249 Mississippi Power & Light Company (MP&L) proposed a limited deferral of certain inspections of the Division II emergency diesel generator (EDG) in its letter to the NRC, AECM-86/0070, dated June 7, 1986. To support the NRC review of this proposal and to respond to NRC concerns on the matter, a meeting was held with the NRC staff on August 6,1986. This letter provides documentation of supplemental information provided by MP&L at that meeting.

Attachment 1 includes a summary discussion of the principal elements provided by MP&L to support the NRC review. Attachment 2 encloses the MP&L presentation " handout" as provided to the NRC during the meeting.

l Based on discussions with your staff, we understand this information to I

be sufficient to complete your review. We request your prompt approval of this limited deferral in order to support final preparations for the upcoming refueling outage scheduled to start September 5, 1986.

Yours ly, l

ODK:mre I

Attachments l cc: (See Next Page) 8608190169 860G13 PDR ADOCK 05000416 G PDR 00 J11AECM86080901 - 1 Member Middle South Utilities System

AECM-86/0249 Page 2 cc: Mr. T. H. Cloninger (w/a)

'Mr. R. B. McGehee (w/a)

Mr. N. S. Reynolds (w/a)

Mr. H. L. Thomas (w/o)

Mr. R. C.' Butcher (w/a)

Mr. Jaees M. Taylor, Director. (w/a)

Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. J. Nelson Grace, Regional Administrator (w/a)

U. S. Nuclear Regulatory Commissicn Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 l

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Attachment 1 AECM-86/0249 Documentation of MP&L Meeting August 6, 1986, Bethesda, MD l i

PROPOSED LIMITED DEFERRAL Of CERTAIN DRQR INSPECTIONS ON THE DIVISION II EMERGENCY DIESEL GENERATOR I. FOREWORD Mississippi Power & Light Company (MP&L) met with the NRC Staff on August 6,1986, to address certain concerns raised by the NRC in its review of MP&L's letter dated June 7, 1986. In that letter (Reference 1), MP&L proposed a limited deferral II emergency for one diesel operating) generator (EDGcycle

. Thisofattachment certain inspections is intendedoftothe Division provide a summary of the supplemental information and commitments provided by MP&L to support the NRC Staff's review and approval. Attachment 2 provides a copy of the meeting handout material provided to the NRC on August 6.

II. INTRODUCTORY REMARKS As a matter of introduction to this issue, MP&L discussed an overview of its outage planning philosophy and discussed the significance of the proposed deferral with regard to the upcoming refueling outage. As indicated in MP&L's initial submittal (Reference 1), the proposed deferral represents a critical path savings of approximately nine days and significant indirect savings in terms of the utilization of plant resources on other required outage work.

This discussion was followed by an overview of the TDI EDG Owners Group Design Review / Quality Revalidation program, its overall structure, and accomplishments. MP&L indicated its commitment to the program's implementation including the maintenance and surveillance program. MP&L's position on this subject and overall response to the NRC Generic Safety Evaluation Report on the TDI Owners Group program (Reference 2) was submitted to the NRC by letter dated July 18, 1986 (Reference 3).

As a final point of introduction, MP&L presented a summary of key elements of the MP&L June 7 letter that provided the basis for justifying a deferral of certain inspections on the Division II EDG for one operating cycle (to Refueling Outage 2). MP&L presented its overall conclusion that the proposed deferral was fully justified and did not adversely impact the safety of plant operations during the period of deferral (Cycle 2).

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Attachment 1 AECM-86/0249 III. ENGINE CONNECTING R0D INSPECTIONS A. As proposed by MP&L in its June 7 letter (Reference 1), the scope of RF01 Division II EDG inspections included the full disassembly and inspection (in accordance with DRQR recommendations) on connecting rods associated with eight engine cylinders #5 through f8, left and right bank.

B. To address NRC concerns regarding those connecting rods which would. remain assembled during RF01, an inspection plan was developed, supplemental to that provided in the June 7 MP&L letter, and was presented to the NRC Staff in the August 6 meeting. The key elements of the plan include an essentially complete implementation of those DRQR inspection items which are considered by MP&L to be the most important regarding connecting rod performance and reliability.

C. The inspections proposed for the four ASSEMBLED rods are as follows:

1. Assemble and review existing documentation.

2. Performance of eddy current test on all rod box female threads.

3. Performance of magnetic particle testing on all key connecting rods bolts. (Top four bolts on box - RF01; Bottom two bolts -

RF02).

4. Performance of visual inspection on all connecting rod bolt washers and contact surfaces for signs of galling. (Top four bolts on Box - RF01; Bottom two bolts - RF02).

5. Verification that the torque loads on all the connecting rod bolts are in accordance with the latest TDI recommended values.

D. Per the proposed inspection plan for the four (4) ASSEMBLED rods, DRQR inspections not deemed as critical for these connecting rods would not be performed during RF01 but deferred to RF02. Failure Analyses Associates, Inc. (FaAA), a TDI Owners Group contractor, concurs with MP&L in its assessment of the relative significance of these four inspections. A representative of FaAA, Dr. L. A. Swanger, presented information to the NRC in the August 6 meeting, regarding these inspections supporting their deferral for one operating cycle at GGNS. The subject inspections and Dr. Swanger's remarks are summarized below:

1. Performance of liquid penetrant testing on the surface of the internal diameter of all wrist pin bushings.

BASIS FOR DEFERRAL TO RF02 As a matter of background, this DRQR recommended inspection resulted from examinations performed on new bushings associated with TDI engines at another nuclear facility. The subject cast bushings revealed manufacturing imperfections that were believed J11AECM86080901 - 5

Attachment 1 AECM-86/0249 to be detrimental to the bearings if the imperfections were located in the high oil film pressure area of the bushing. A 30 degree arc at the bottom location of the bushing was determined to be subject to the highest film pres'sures. It was originally postulated that oil may enter the imperfections and drive the imperfections into cracks. However, subsequent analysis (by FaAA) has shown that oil film pressures are not sufficiently high to overcome the compressive forces that exist from pressing the bushing into the rod eye. Therefore, if linear type defects did exist, compressive forces would prevent their propagation.

Additional detail on the FaAA crack propagation analysis is provided in References 5 and 6 and Pacific Northwest Laboratory Technical Evaluation provided in Reference 4.

2. Performance of visual inspection of the rack teeth connection for signs of wear.

BASIS FOR DEFERRAL TO RF02 Fretting of the rack teeth is considered to be a by-product of inadequate preload on the connecting rod bolts. GGNS has maintained controls on bolt preload using mechanical torquing methods and more recently, periodic bolt elongation ultrasonic measurements. The rods were also disassembled in 1983 with maintenance inspections performed at that time. The bolt preload elongation will be measured again at RF01. Any evidence of relaxation _will be evaluated.

3. Performance of clearance check of the link rods and link pins for proper alignment.

BASIS FOR DEFERRAL TO RF02 With the implementation of TDI SIM 349 at GGNS in 1980, measurements were taken using the vendor prescribed 1.5 mil clearance criteria between link pin and link rod. The measure-ments were recommended to ensure that the securing dowel pin hole counterbores were of sufficient depth and that dowel pin compression due to firing forces did not occur to the extent of causing an excessive relaxation of the link pin-to link rod bolts. This potential problem was first identified on commercial service engines, and SIM 349 was issued for 4

resolution. SIM 349 was implemented on Division I with less than 331 hours0.00383 days <br />0.0919 hours <br />5.472884e-4 weeks <br />1.259455e-4 months <br /> and on Division II with less than 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> of operation. Since implementation of-SIM 349, Division I has been disassembled'four times ~with no evidence of degradation of components that could be attributed to link bolt relaxation. In view of the number of operating hours at GGNS on the Division II EDG, the dowel pin bolt relaxation would have occurred early in life. The rods have been disassembled and reassembled twice since SIM 349 was implemented thus reestablishing the required torque on all link rod bolts. Further dowel pin hole measurements can be deferred to RF02.

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Attachment 1 AECM-86/0249

4. Measurement of centerline bow.

BASIS FOR DEFERRAL TO .'tF02 Centerline f.ow af the rods is a manufacturing imperfection created by inade w ate support of the rod during cooling.

Analysis has showr. that if the bow exceeds 0.47 inches then uneven wear of the pistcn pin bushing and the connecting rod bearing could result. This would occur by shifting the axis of the piston pin bore and the connecting rod bore to an angle other than parallel with the piston pin and crankshaft. The net effect is reducticn of betring itfe. For example, a bearing with a conservatively estinated 10,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> lifetime may be reduced by approximately 50%. Therefore, since Division II engine hours are low and expected hcurs from RF01 to RF02 should not exceed 100, centerline bov neasurements can be deferred to RF02 for these four rods.

E. In summary, a complete DROR disassembly and inspection will be fully accomplished on four of the Division II engine's connecting rods. Further, because of the supplemental inspection plan, the most important inspection items will be accomplished on the four rods to remain assembled during the RF01 work. 0.n whole, this represents essentially a 100% inspection on the highest priority items for all eight rods of the Division II engine during RF01. Since four rods will be fully disassembled and subjected to appropriate DRQR inspections, including those labeled above as less important, this represents a proposed implementation during RF01 of 50% of all " lower priority inspections." Based on discussions in Section III.D above, the deferral of these " lower priority" inspections on the Division II EDG connecting rods is technically justified.

F. Out-of-specification materials were recently discovered in connecting rod assemblies at another nuclear facility. To address NRC concerns on this subject with respect to GGNS, MP&L further commits to perform hardness and material comparator tests for Division II EDG connecting rods. These tests will be performed consistent with similar DRQR material tests already recommended for other engine components.

IV. FEASIBILITY OF USING HPCS EDG AS ALTERNATE POWER SUPPLY FOR DIVISION II LOADS The NRC Staff requested MP&L to present information regarding the feasibility of disassembling both TDI EDGs simultaneously and utilizing the

, Division III HPCS EDG to supply power, if necessary, to the Division II loads while the Division II EDG was not available. The purpose in considering this approach was to develop a plan whereby no deferral of DRQR inspections would be necessary while at the same time maintaining the MP&L outage duration goal.

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Attachment 1 AECM-86/0249 1

l As presented to the NRC, the key factor that renders this approach unfavorable is the reliance of the HPCS EDG on cooling water from Standby Service Water (SSW) Basin "A". This basin will be drained for a large portion of the time when the HPCS EDG would be required operable to support the approach under consideration here. Because of this dependence, this approach using the Division III EDG represents only a minimal savings in critical path ,

time after hookup and testing.

MP&L has evaluated the technical aspects of this use of the Division III EDG at length and has concluded that while technically feasible it should be used only as a last resort under situations where the onsite and offsite power supply is seriously degraded.

Several disadvantages and complexities associated with this approach were presented to the NRC on August 6. These points are outlined in Section V of Attachment 2 to this letter.

V. CONCLUSION MP&L's letter of June 7 provided the basis for justifying the proposed limited deferral. The TDI Owners Group has reviewed and concurred with the proposed deferral. MP&L's conclusions at the August 6 meeting with the NRC Staff are outlined in Section VI of Attachment 2. A supplemental inspection plan for those engine connecting rods which would remain assembled during RF01 provides for inspection activities of those DRQR items which are considered to be of the highest priority for these components. Further, MP&L commits to perform appropriate material comparator tests on the Division II EDG connecting rods to address material concerns regarding these components recently identified at another nuclear facility.

This limited deferral, as discussed in MP&L's June 7 letter, is proposed for one operating cycle. This cycle is expected to span approximately 12 months based on current fuel cycle plans and supporting analyses.

As discussed in the June 7 letter, MP&L recognizes that the inspection scope may require expansiori if the currently ' proposed inspection identifies components that exhibit an abnormal condition. Any such findings will be evaluated considering service function, expected wear rate, sdrvice hours, importance of function, and nonnal operational wear. Corrective actions and inspection scope expansions, as appropriate, will be based on such an evaluation with support as required from appropriate external engineering and technical organizations.

Overall, MP&L considers the proposed limited deferral to have no adverse impact on the reliable operation of the Division II EDG or overall plant safety.

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Attachment 1 AECM-86/0249 VI. REFERENCES

1. .MP&L letter to the NRC, Proposed Limited Deferral of Certain Inspections on Division II EDG, AECM-86/0077, dated June 7, 1986.

2. NRC letter to MP&L, Generic SER on TDI Owners Group DRQR Program, dated June 26, 1986.

3. MP&L Letter to NRC, Response to NRC Generic SER on TDI OG DRQR and Operating License Condition 2.c(25), AECM-86/0172, dated July 18, 1986.

4. Review of Resolution of Known Problems in Engine Centonents for Transamerica Delaval Inc. Emergency Diesel Generators dated December 1985, PNL-5600.

5. Failure Analysis Associates (FaAA) June 1984, Design Review of Connecting Rods of Transamerica Delaval Inline DSR-48 Emergency.

Diesel Generators, FaAA-84-3-13, Palo Alto, California.

6. Failure Analysis Associates (FaAA), August 1984 Design Review of Connecting Rods of Trans4merica Dalaval DSRV-4 Series Diesel Generators, FaAA-84-3-14, Pal' o Alto, California.

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ATTACHMENT 2-NRC/MP8L MEETING AUGUST 6, 1986 GGNS DIVISION II EDG PROPOSED PARTIAL DEFERRAL OF DR/0R INSPECTIONS P I. OVERVIEW, OUTAGE PLANNING 0. D, KINGSLty, JR, PHILOSOPHY AND ROLE OF PROPOSED DEFERRAL-II, OVERVIEW 0F DR/0R REPORT C. W.. ANGLE III. BASIS FOR DEFERRAL C. W. ANGLE IV, CONNECTING R0D INSPECTIONS C. W. ANGLE /

L. A. SWANGER (FAAA)

V. FEASIBILITY FOR USE OF HPCS EDG AS J. E. CROSS-ALTERNATE POWER SUPPLY FOR DIVISION II LOADS VI, CONCLUSION 0. D. KINGSLEY, JR, e

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I, 0VERVIEW, OUTAGE PLANNING PHILOSOPHY AND ODK RULE OF PRUPUSED DEFERRAL 0 MP8L OUTAGE PLANNING PHILOSOPHY REFUELING OPS CRITICAL PATH O RF01 CONTROLLED BY SEQUENTIAL DIVISION I AND II EDG WORK MAJOR WORK ALSO REQUIRED FOR DIVISION III HPCS EDG 0 RF01 OUTAGE STRATEGY / IMPROVEMENT EFFORTS CONSTANT EFFORT OVER LAST 12 MONTHS TO AFFECT MORE EFFICIENT SCHEDULING /

EFFICIENT LOGIC FALL 1985 OUTAGE O ROLE OF DIVISION II EDG PARTIAL DEFERRAL l

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l - - . , . . . , . ._-. , . - . . . . . - . . . . . . _ _ - . - _ . - - _ . .

II. DVERVIEW 0F DR/0R EFFORT AND REPORT CWA 0 GENERIC PROBLEM RESOLUTION OF 16 MAJOR COMPONENTS (PHASE I OUALITY REVALIDATION) 0 DESIGN REVIEW OF 150-170 SUBCOMPONENTS (PHASE II)

O MAINTENANCE / SURVEILLANCE PROGRAM, APPENDIX II O OVERALL ACc0MPLISHMENTS OF PROGRAM DR/0R PROGRAM HAS RESULTED IN EXTENSIVE AND COMPREHENSIVE DESIGN AND QUALITY REVIEW OF ALL TDI NUCLEAR SERVICE ENGINES.

INSPECTIONS HAVE CONFIRMED THE ADEQUACY OF V-16 ENGINES.

ADDRESSED GENERIC AND PLANT SPECIFIC ITEMS, INCLUDING DESIGN, MATERIAL, QUALITY, MAINTENANCE SCHEDULES AND INSPECTION FREQUENCIES.

0- PROGRAM REPRESENTS SUBSTANTIAL COORDINATION OF EFFORT AND TECHNICAL RESOURCES BETWEEN UTILITIES, CONSULTANTS AND NRC 0 MAJOR PROGRAM EFFORT CULMINATED IN THE ISSUANCE OF THE RESULTS OF MANY TECHNICAL ANALYSES, DESIGN AND MATERIAL EVALUATIONS 0 CONTAINED IN THE DROR, PNL, FAAA AND SER REPORTS 0 MP8L IS COMMITTED TO THE IMPLEMENTATION OF THE PROGRAM INCLUDING THE MAINTENANCE /

SURVEILLANCE PROGRAM i

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III, BASIS FOR PROPOSED DEFERRAL ON DIVISION II EDG CWA A. CONSIDERATIONS 0 SAFETY AND RELIABILITY FOREMOST IN

.CONSIDERING DEFERRAL REQUEST r

0 OG PROGRAM HAS SHOWN FAVORABLE INDUSTRY INSPECTION HISTORY ON NUCLEAR SERVICE TDI ENGINES (INCLUDING V-16S) 0 IMPRESSIVE DATA BASE FROM INSPECTIONS AND RECENT EXPERIENCES FORMED BASIS FOR ESTABLISHING CONFIDENCE IN THE V-16 ENGINE OPERABILITY AND TEMPORARY DEFERRAL REQUEST FOR COMPLETE DISASSEMBLY OF ENGINE AT RF01 0 APPROXIMATELY 6,000 COMPONENTS EVALUATED OR INSPECTED ON ABOUT 35 B)GS 0 220 CONNECTING RODS IN NUCLEAR SERVICE INSPECTED FOR EXAWLE, Wim ONLY 2 DEVIATING CONDITIONS VERIFIED.

4 0 IN GGNS RF01, A LARGE PORTION OF-DIVISION II B)G MAJOR COMPONENTS ARE TO BE INSPECTED AS WELL AS DRQR ITEMS WHICH ALSO WILL BE IMPLEENTED i-0 SELECTED ON BASIS OF HIGH STRESS OR TORSIONAL LOADS

0 INSPECTiONSCOPEMAYBEEXPANDEDBASED -

ON RESULTS 0 OVER 1500 NDE INSPECTIONS EXPECTED TO BE l

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III. (CONT'D).

B. TDI OWNERS GROUP REVIEW / CONCURRENCE O FAVORABLE NUCLEAR INDUSTRY INSPECTION HISTORY PLAYED KEY ROLE O TECHNICAL REVIEW CONDUCTED BY OWNERS GROUP TECHNICAL STAFF 0 OWNERS GROUP EXECUTIVE Co mITTEE CONCURRED BASED ON TECHNICAL REVIEW C. FAWRABLE INSPECTION /0PERATING HISTORY ON GGNS DIVISION I AND DIVISION 11 EDGS 0 SEVERAL DISASSEMBLIES, INSPECTION, REFURBISWENT ACTIVITIES PERFORMED WITH THE ACCUMJLATION OF SIGNIFICANT BASELINE DATA O LATEST - DECEMBER 83 FOR DIVISION II

- JULY 198l4 FOR DIVISION I O FAVORABLE RESULTS ON COMPARATIVE -

EVALUATION OF BOTH EDG'S REGARDING AS-MANUFACTURED QUALITY D. DIVISION II EDG TOTAL RUN TIE AT RF02 LESS THAN DIVISION I EDG AT 6/84 TEARDOlfl/

IN5FtCIION 0 DIVISION II DG RUN TIME AT ELEVATED LOADS SIGNIFICANTLY LESS THAN DIVISION I O MP8L RESTRICTS ENGINE LOAD TO 185 BN P (82% OF FULL LOAD) 0 ANTICIPATE LOW NUMBER OF ADDITIONAL l HOURS TO RF02 DOC 6

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IV. CONNECTING ROD INSPECTIONS . CWA l

0 FOUR DISASSEMBLED RODS TO BE INSPECTED IN ENTIRETY AT RF01 IN ACCORDANCE WITH DRUR REC 0lHENDATIONS.

O FOUR ASSEMBLED RODS TO BE INSPECTED AS GIVEN BELOW.

0 QUALITY REVALIDATION CRITERIA FOR PARTIAL INSPECTION (FOUR (4) ASSEMBLED RODS)

RF01 RF02 ASSEMBLE AND REVIEW EXISTING DOCUMENTATION. X PERFORM AN EDDY CURRENT TEST ON ALL ROD BOX X FEMALE THREADS.

PERFORM A MAGNETIC PARTICLE TEST ON ALL X X O

CONNECTING ROD BOLTS.

PERFORM A VISUAL INSPECTION ON ALL CONNECTING X W X(2)

ROD BOLT WASHERS AND CONTACT SURFACES FOR SIGNS OF GALLING.

VERIFY THAT THE TORQUE LOADS ON ALL THE X CONNECTING ROD BOLTS ARE IN ACCORDANCE WITH THE LATEST TDI REC 0 MENDED VALUES.

PERFORM A LIQUID PENETRANT TEST ON THE SURFACE X OF THE INTERNAL DIAN TER OF ALL WRIST PIN BUSHINGS.

PERFORM A VISUAL INSPECTION OF THE RACK TEETH X CONNECTION FOR SIGNS OF FRETTING.

PERFORM A CLEARANCE CHECK OF THE LINK RODS AND X LINK PINS FOR PROPER ALIGNMENT.

MEASURE CENTERLINE BOW X 0 DR. LEE SWANGER WILL DISCUSS TECHNICAL JUSTIFICATION FOR DEFERRALS.

NOTES:

1. TOP FOUR (4) BOLTS

2. BOTTOM TWO (2) BOLTS DOC 5

I -IV (C0ffPD) C0ffl R0D INSRCTIONS BOLT HOLES i

-FOUR (4) DISASSEMBLED RODS TO BE INSPECTED BY EDDY CURRENT (E.C;)

FOUR (4) ASSEMBLED RODS TO BE INSPECTED BY E.C. WITH SPECIALLY

-FABRICATED HARDWARE.

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fiETHOD AND ADAPTERS SATISFACTORILY. DEMONSTRATED'AT FAAA FACILITY.

MATERIALS CONN RCD MASTER AND LINK BOXES MATERIAL RECORDS WERE VERIFIED AND VERIFIED TO BE OF PROPER PHYSICAL AND CHEMICAL PROPERTIES. ,

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MATERIAL' CERTIFICATIONS HAVE BEEN REVIEWED BY BECHTEL, THE OWNERS t

GROUP, AND MORE RECENTLYIP8L AND FOUND TO BE ACCEPTABLE.

DOCLNENTED IN DRQR AND VENDOR DOCLMENTS RECENTLY. ADDED VERIFICATION PROMPTED BY SAN ON0FRE INCIDENT.

I DESIGN DRAWINGS, PROCESSES, MANUFACTURING RECORDS REVIEWED AND l CONCLUDED BOTH DIVISION I AND DIVISION II HAD SIMILAR AS-MANUFACTURED QUALITY.

I MATERIALS JUDGED TO BE SATISFACTORY BASED ON THE REVIEWS.

t CONCLUSION HIGHEST PRIORITY ITEMS WILL THEREFORE BE INSPECTED AND VERIFIED TO BE SATISFACTORY FOR ALL CONN RODS.'

i 100% INSPECTION OF FIVE (5) HIGHEST PRIORITY ITEMS FOR ALL EIGHT-(8) CONN RODS.

50% INSPECTION OF LOWER PRIORITY ITEMS DURING RF01.

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V. FEASIBI_ITY OF USING HPCS EDG AS ALTERNATE JEC PUWER SJPPLY FOR DIV. 11 LOADS 0 WOULD REQUIRE MAJOR REVISION TO'0VTAGE PLANNING LOGIC

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ESTIMATED MAXIMUM!THE0R$TICAL' ADVANTAGE OF TWO. DAYS AVAILABILITY OF HPCS EDG SUPPORT SYSTEMS IS CONSTRAINING O IMPLEMENTATION NUMEROUS TEMPORARY DESIGN ALTERATIONS DISCONNECTION OF PREFERRED OFFSITE POWER FEED i

DISABLING OF NUMEROUS INTERLOCK FEATURES IMPLEMENT ONLY UPON LOSS OF 0FFSITE-POWER (EFFECTIVELY STATION BLACK 0UT)

MAY INVOLVE UNREVIEWED SAFETY ISSUE i 0 SPECIAL TESTING MAY BE REQUIRED TO DEMONSTRATE

- ADEQUACY OF POWER SUPPLY TO CARRY SELECTED LOADS

0 TRAINING / PROCEDURES / STAFFING TO SUPPORT IMMEDIATE IMPLEMENTATION 0 RESTORATION OF PREFERRED POWER (UPON REGAINING OFFSITE POWER) MORE COMPLEX l AND TIME-CONSUMING PARALLEL INSPECTION OF DIVISION I AND O

DIVISION II EDGS ESSENTIALLY DOUBLE MP&L AND CONTRACTOR MANPOWER REQUIREMENTS -

MECHANICS, INSPECTORS, AND QUALITY

PERSONNEL (AND TOOLS) i DOC - 7 i

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VI, 0VERALL CONCLUSION ODK o TECHNICALLY JUSTIFIED REPRESENTATIVE, HIGHLY. STRESSED' COMPONENTS TO BE INSPECTED DURING RF01 DIv. II EDG ENGINE LOAD LIMITS AND ENGINE RUN TIME SUPPORT DEFERRAL DROR INSPECTION EXPERIENCE HAS PROVIDED CONFIDENCE REGARDING MATERIAL QUALITY, NOT PREVIOUSLY AVAILABLE TO DRQR 100% INSPECTION ON FIVE (5) MOST IMPORTANT ITEMS OF CONNECTING RODS o TDI OG TECHNICAL REVIEW AND CONCURRENCE o REASON FOR REQUEST PREVIOUSLY DISCUSSED o REQUEST PROMPT NRC REVIEW AND APPROVAL DOC - 8

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