ML13330B226

Comments on Sections 2 & 3 of SER on Operability/Reliability of Facility Standby Diesel Generators,Per GE Lear

ML13330B226
Person / Time
Site:	San Onofre
Issue date:	07/09/1987
From:	Medford M Southern California Edison Co
To:	NRC Office of Administration & Resources Management (ARM)
References
NUDOCS 8707150624
Download: ML13330B226 (29)

Text

.gg Southem California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 M. 0. MEDFORD TELEPHONE MANAGER OF NUCLEAR ENGINEERING (818) 302-1749 AND LICENSING July 9, 1987 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.

20555 Gentlemen:

Subject:

Docket No. 50-206 Standby Diesel Generators San Onofre Nuclear Generating Station Unit 1

References:

(A) Letter dated January 28, 1987, from G. E. Lear (NRC) to K. P. Baskin (SCE), Safety Evaluation Report on the Operability/Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc. (TDI)

(B) Letter dated March 20, 1987, from M. 0. Medford (SCE) to the NRC, Safety Evaluation Report on Operability/Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc. (TDI)

(C) Letter dated September 3, 1985, from M. 0. Medford (SCE) to

3. A. Zwolinski (NRC), Transamerica Delaval Inc. (TDI)

Diesel Engines Design Review and Quality Revalidation Report (D) Letter dated April 17, 1986, from M. 0. Medford (SCE) to G. E. Lear (NRC), Comments on Draft Safety Evaluation Report on Transamerica Delaval Inc. (TDI) Diesel Generators Reference A transmitted a preliminary safety evaluation report (SER) on the operability/reliability of the San Onofre Unit 1 standby diesel generators. The letter requested that Southern California Edison (SCE) consider the recommendations and license conditions contained in the SER and within 60 days inform the NRC staff of SCE's plans to implement these recommendations and license conditions.

By Reference B we informed you that the requested information would be submitted at a later date.

We have the following general comments on Sections 2 and 3 of the SER. Enclosed Tables A and B provide our specific comments on these Sections.

Section 2 This Section contains the evaluations for Phase I and Phase II components. It states that subject to the SER clarifications, the NRC staff concurs with the conclusions and recommendations of

-67O7150624 870709 PDR ADOCK 05000206 PDR

Document Control Desk July 9, 1987 Pacific Northwest Laboratory, as presented in PNL-5600, PNL-5336, PNL-5444 and PNL-5718. The recommendations contained in these PNL reports relate to both Design Review and Quality Revalidation (DR/QR) and Maintenance and Surveillance (M/S), even though such a distinction is not made in the PNL reports. Of the four reports, PNL-5600 deals with Phase I components and is substantially applicable to San Onofre Unit 1. PNL-5336 and PNL-5444 deal specifically with the Phase II components of Shoreham Nuclear Power Station Unit 1 and Comanche Peak Steam Electric Station Unit 1 respectively. PNL-5718 endorses certain key M/S recommendations found in PNL-5600 for Phase I components that warrant special emphasis and it also endorses a selected number of Phase II M/S items found in PNL-5336 and PNL-5444 for implementation at sites other than Shoreham and Comanche Peak. SCE's position concerning the recommendations of each PNL report is explained in the paragraphs below.

Section 2.1 This Section addresses the PNL/Owners Group recommendations pertaining to modifications and/or replacement, quality revalidation inspections and all M/S items for the sixteen Phase I components.

It states that the findings and recommendations of PNL-5600 should be implemented in addition to the findings and recommendations of the Owners Group, subject to clarifications and exceptions as discussed in Section 2.1.3 of the SER.

Regarding the M/S items discussed in Section 2.1.3, Section 2.3 of the SER contains the further clarification that an acceptable M/S program will consist of (i) TDI Instruction Manual, TOI Service Information Memos and TDI correspondence on specific M/S issues (i) the M/S recommendations in Revision 2 of Appendix II of the DR/QR reports and (iii) additional items required by the NRC staff, as identified in Section 2.1.3 of the SER. Based on this clarification, we conclude that those M/S recommendations in PNL-5600 which are not specifically identified and endorsed in Section 2.1.3 of the SER or are left to the utility's discretion are not SER recommendations.

Regarding the remainder of Section 2.1.3, (component modifications and/or replacement and quality revalidation inspections), SCE has implemented the Owners Group DR/QR recommendations for both Phase I and Phase II components during the 1985-1986 plant outage, subject to the exceptions identified in Enclosure III of Reference C. We are currently performing a detailed review of the maintenance records to verify that our implementation of these recommendations was complete. SCE does not plan to implement any additional inspections, modifications or replacements as the result of PNL's review of the Owners Group program.

Document Control Desk July 9, 1987 Section 2.2 This section addresses the PNL/Owners Group recommendations pertaining to upgrades and modifications and quality revalidation inspections as well as all M/S items for the Phase II components.

It concludes that for these components, all of the Owners Group recommendations stemming from the plant specific Phase II evaluations should be implemented but that the additional recommendations of PNL-5336 and PNL-5444 for component improvement (endorsed by PNL-5718) should be discretionary.

The status of SCE's implementation of the Owners Group Phase II DR/QR recommendations is provided above under Section 2.1.

SCE will implement the recommendations of PNL-5336 and PNL-5444 at its discretion.

Section 2.3 This Section addresses the importance of a comprehensive M/S program for both Phase I and Phase II components and describes the three elements of an acceptable M/S program. In light of this clarification, we have concluded, as previously stated, that (a) for the Phase I components, only those PNL M/S items specifically identified and endorsed in Section 2.1.3 of the SER are SER recommendations and (b) for the Phase II components, the PNL M/S recommendations made in PNL-5336, PNL-5444 and PNL-5718 are discretionary to SCE.

Table A reflects our understanding of all the individual recommended actions encompassed by Section 2 of the SER as applicable to San Onofre Unit 1. It is our intent to implement these recommended actions, subject to the comments and clarifications provided in Table A. Subsequent to issuance of the final SER for San Onofre Unit 1, changes to these recommended actions will be accomplished using 10 CFR 50.59 review. However, items characterized as optional in Table A will be adopted, changed or deleted from the M/S program at SCE's discretion.

Section 3 This Section of the SER states that the most critical periodic M/S actions for Phase I components will be incorporated as license conditions. Appendix A and Enclosure 2 to the SER provide these "sample license conditions".

Table B provides our comments on the "sample license conditions".

As indicated in Reference D, it is our position that these periodic M/S items should not be license conditions, nor should any of them

Document Control Desk July 9, 1987 be incorporated into the Technical Specifications. We feel it is sufficient that changes to the M/S program be subject to a safety evaluation in accordance with the provisions of 10 CFR 50.59.

If you have any questions regarding this submittal, please call me.

Very truly yours, Enclosures cc: R. F. Dudley, NRR Project Manager, San Onofre Unit 1 J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 D. E. Broeils, Duke Power Co. (Delaval Diesel Generator Owners' Group)

TABLE A COMMENTS ON SAFETY EVALUATION REPORT SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 2

Evaluation Subject to a few clarifications as identified in this SER In light of Section 2.3 of the NRC staff concurs with the conclusions and recommendations SER, only those PNL M/S of PNL-5600, PNL-5336, PNL-5444 and PNL-5718, which are recommendations specifically incorporated into this SER by reference.

identified and endorsed by the SER are considered SER recommendations. The remaining PNL M/S recommenda tions are optional to SCE.

In the area of component modification, replacement or upgrading and quality revalidation inspections, SCE's commitment is to implement the Owners Group DR/QR program, as modified by Enclosure III of SCE to NRC letter dated September 3, 1985. These DR/QR items were implemented by SCE in 1985-86. SCE does not plan to implement any new DR/QR related inspections, modifications, etc., as the result of PNL's review of the Owners Group program.

-2 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 2.1 Technical Resolution of Phase I 2.1.1 In addition to OG findings and recommendations, implement the In light of Section 2.3 of the findings and recommendations in the following sections of PNL-5600 SER, only those PNL M/S subject to SER Section 2.1.3 clarifications and exceptions.

recommendations specifically identified and endorsed by the SER are considered SER recommendations.

The remaining PNL M/S recommenda tions are optional to SCE.

In the area of component modification, replacement or upgrading and quality revalidatlon inspections, SCE's commitment Is to implement the Owners Group DR/QR program, as modified by Enclosure III of SCE to NRC letter dated September 3, 1985.

These DR/QR items were implemented by SCE in 1985-86.

SCE does not plan to implement any new DR/QR related inspections, modifications, etc., as the result of PNL's review of the Owners Group programr Section Component 4.1.4.2 Air start valve capscrews 4.2.4.3 Auxiliary module wiring and terminations 4.4.4.4 DSRV-4 connecting rods 4.5.4.2 Connecting rod bearing shells 4.8.5.6 DSRV-20-4 cylinder crankshafts 4.9.5.2 Cylinder block 4.10.4.3 Cylinder heads 4.11.4.3 Cylinder head studs 4.13.4.2 DSRV engine base and bearing caps 4.14.4.2 Fuel oil injection tubing

-3 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 4.15.4.3 Jacket water pump 4.16.3.3 Piston skirts (type AE) 4.16.4.3 Piston skirts (modified type AF) 4.17.4.3 Push rods 4.18.4.3 Rocker arm capscrews 4.19.4.3 Turbochargers 2.1.2 This section is explanatory.

2.1.3 This section is explanatory.

2.1.3.1 Engine Overhaul Frequency Perform major engine overhauls at 10 year intervals per current OG recommendation instead of 5 year intervals, which was originally proposed by OG and endorsed by PNL.

Perform sample inspection of major engine components on a one time basis following 5 years of service.

2.1.3.2 Air Start Capscrews Verify on sampling basis, air start capscrews on each engine are of length 2 3/4 inches.

Following initial installation of capscrews with torque of 150 ft-lb, retorque capscrews every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> until no further change in torque is noted.

Section 4.1.4.2 of PNL-5600 recommends that periodic checks include retorquing following first period of engine operation after replacement of copper gasket that seals air start valve housing in cylinder head. This is to ensure that no additional gasket creep occurs as a result of the additional thermal and mechanical stresses.

2.1.3.3 Auxiliary Module Wiring and Terminations PNL recommendations are same as OG recommendations.

-4 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 2.1.3.4 Connecting Rod Bearing Shells DR/OR Appendix II matrix does not satisfactorily address need for Oil contamination analyses periodic oil contamination analyses. NRC will require that this are performed monthly, in matter be addressed satisfactorily in plant specific M/S programs.

accordance with Owners Group (Section 4.5.4.2 of PNL-5600 recommends oil contamination analysis M/S recommendations (see be performed on a regularly scheduled basis as recommended by the Component No. 02-540A) oil supplier to provide early warning of deterioration of bearing shells or warn of other developing engine or lubrication problems.)

2.1.3.5 No such subsection in SER.

2.10.3.6 DSR-48 Connecting Rods Not applicable 2.1.3.7 DSRV Connecting Rods Preservice Inspections The pre-service inspections for connecting rods recommended in Section 4.4.4.4.1 of PNL-5600 should be fully implemented as follows:

Rod eyes and rod-eye bushings should be subject to the same inspections recommended for the in-line connecting rods in Section 4.3 of PNL-5600, which are:

o During any disassembly that exposes the inside diameter of a rod-eye bushing, the surface of the bushing should be examined with liquid penetrant to verify the continued absence of linear indications in the heavily-loaded zone within

+15 degrees of the bottom dead center position.

o Any rod eye not previously examined in accordance with the acceptance criteria recommended by FaAA should be examined using an appropriate nondestructive technique at the first major (5-year) engine disassembly. No indications deeper than 0.04 inch should be allowed.

-5 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS Rod bow should be within FaAA recommended limits.

Inspections of lower connecting rod assemblies of all rods should include:

o Bolt holes in link rod box All threaded holes for connecting rod bolts should be inspected using appropriate non-destructive technique to verify the absence of pre-existing flaws.

PNL infers from FaAA-84-3-14 that any indication over 1/8 inch in depth in the pair of bolt holes immediately above the crankpin is rejectable. All indications should be recorded for engineering evaluation.

o Connecting rod bolts All connecting rod bolts should be examined. The DR/QR reports call for a magnetic particle test (MT), but do not specify the technique. In future examinations, PNL recommends that these bolts be examined using the wet fluorescent MT technique (in conjunction with a yoke) rather than the dry particle technique (and direct-current prods).

The wet fluorescent technique would provide the enhanced sensitivity normally specified for bolt examinations. The washers used with the bolts should be examined visually for signs of galling, as specified in the Comanche Peak and Grand Gulf DR/QR reports.

o Connecting rod bolt torque All connecting rod bolts should be lubricated in accordance with the engine manufacturer's instructions and torqued to the specifications of the manufacturer. As discussed in FaAA-84-3-14, the current torque specifications for the 1-1/2-inch bolts and the 1-7/8-inch bolts are, respectively, 1700 ft-lb and 2600 ft-lb.

-6 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS PNL suggests that the lengths of the two pairs of connecting rod bolts above the crankpin be measured ultrasonically pre and post-tensioning. These measurements would provide an accurate check on whether or not the desired bolt stretch has been achieved through application of the specified torque. In addition, these measurements would provide a useful reference for later ultrasonic checks of bolt preload. FaAA-84-3-14 and the DR/QR report for Grand Gulf recommend that breakaway torque be measured at any time the link rod box is disassembled, and that the bolts, bolt holes, and contact surface areas be carefully examined if the breakaway torque is less than 1600 ft-lb for 1-1/2-inch bolts or less than 2400 ft-lb for 1-7/8-inch bolts.

PNL notes that breakaway torque may not be an accurate measure of bolt preload, particularly after a connecting rod has been in service. Inaccuracies may be introduced by such factors as thread galling. Ultrasonic measurements of bolt length would provide a more reliable check because they would not be affected by the condition of the threads.

o Contact at serrated joint The contact between mating surfaces of the link rod box should be no less than the minimum specified by the engine manufacturer. The percentage of contact should be verified for each joint using an appropriate method (e.g., "blueing").

o Link rod clearance Clearance between the link pin and the link rod should be examined.

PNL concurs with FaAA's recommendation that this dimension must be zero when the link rod bolts are torqued to 1050 ft-lb as specified by the manufacturer.

Periodic Inspections NRC staff finds PNL recommended periodic inspections have generally been incorporated in Revision 2 of M/S program. NRC has the following comments.

-7 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS Perform baseline ultrasonic elongation measurements on all connecting rods at first availability, i.e., on 25% of the connecting rods at the next 25% sample inspection and on 100% of the connecting rods at the next 10 year overhaul inspection.

Revision 2 of M/S program recommends ultrasonic measurement of connecting rod bolt stretch prior to each bolt disassembly.

However, as part of the plant specific program, baseline ultrasonic measurements should also be required following each bolt assembly.

NRC staff concurs with PNL's recommendation that if connecting rod bolt tension is found to be reduced to less than 93% of its initial value as measured during installation, then the cause should be determined, appropriate corrective action should be taken and the interval between checks of bolt tension should be reevaluated.

(Note:

NRC staff considers only ultrasonic measurements and not torque measurements to be sufficiently reliable to compare with the 93% criterion.)

M/S matrix calls for a one time check rather than the periodic checks recommended by PNL regarding degree of surface contact at the serrated joint (of the connecting rod assembly) and the zero clearance condition between the link pin and link rod.

Licensees should consider future checks of surface contact in the event that periodic inspections should reveal excessive detensioning of the connecting rod bolts, fretting of the serrated surfaces or other evidence of connecting rod distress.

PNL recommends that an "appropriate non-destructive method" be employed for preservice and periodic inservice inspection of bolt holes in link rod bore. NRC staff concludes this inspection method shall include either (1) the eddy current inspection method developed by FaAA for threaded carbon steel bolt holes (i.e., FaAA Procedure NDE 11.9, Revision 1 or (2) an alternative method shown to be equivalent to FaAA eddy current procedure for purposes of discriminating small cracks in the threads.

-8 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS NRC staff will incorporate key M/S actions as license conditions for TDI facilities with DSRV connecting rods (see Appendix A of SER for sample license conditions).

2.1.3.8 Crankshafts Appropriate precautions should be taken for all engine models to Plant procedures will be prevent sustained engine operation in an unbalanced condition.

changed to incorporate these Plant procedures should clarify that the hourly cylinder exhaust recommendations.

(Action will temperatures that are taken per Table 1 of the M/S matrix should be completed by April 1, also be monitored for engine imbalance.

1988.)

Pending completion of efforts related to alleviation of transient See Table B torsional stresses, San Onofre Unit 1 crankshafts should be inspected at each refueling per Revision 2 of M/S program. Key periodic inspection items will be incorporated as license conditions (see Appendix A of SER).

Per Section 4.8.5.6.2 of PNL-5600, "If cracks reinitiate in the oil holes where they were previously discovered and removed, or if cracks initiate in other crankshaft surfaces, they should be removed and the adequacy of the repaired crankshaft(s) should be reanalyzed as a prerequisite to additional service. This analysis should address whether or not the new cracks and the operating history under which they developed are consistent with the predictions of the analysis documented in FaAA-84-12-14 (April 1985).

The analysis and the conclusions drawn from it should be subject to NRC review."

Depending on the outcome of this evaluation, NRC staff may require See Table B that cracking 'problem be.corrected prior to plant restart.

San Onofre Unit 1 Technical Specifications (TS's) should be revised Plant TS's and operating to limit surveillance test load to 4500 kW + 5%. Engine operating procedures have been revised procedures and training should be revised as necessary to guide to limit load.

and instruct operators against overloading beyond 4500 kW + 5%.

A lesson plan addressing the diesel generators will be revised to ihstruct operators regarding the basis for the 4500 kW + 5% load limit.

This revised lesson plan will be scheduled and taught in

-9 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS the 1987-1988 requalification training program to licensed and non-licensed operations personnel.

(Action will be completed by April 1, 1988)

If crankshaft is loaded beyond 4500 kW + 5% for some unspecified See Table B reason, contingency inspection will be required as a license condition. (See Appendix A of SER)

SCE should submit clarification to the NRC that the monthly slow See SCE to NRC letter dated starts will be at least 24 seconds in duration.

Plant TSs should March 25, 1987, for the be revised accordingly as soon as practicable.

status on this'subject.

Per Section 4.815.6.3 of PNL-5600:

A. To avoid cylinder imbatlance, (1) cylinder exhaust gas temperatures should be monitored during engine operation to verify that differences between individual cylinder temperatures andpthe average temperature for all cylinders remain within the range recommended by TDI; (2) cylinder firing pressures should be measured no less frequently than the interval recommended by TDI; and (3) SCE should analyze the trends of cylinder pressure and temperature measurements to detect changes that might indicate a need for maintenance Sfuel injection equipment.

Any abnormalities should be corrected expeditiously.

B. Continuous engine operation at speeds more than a few rpm Plant procedures will be above 450rpm should be avoided, particularly during engine changed to caution operators startup (imbalance in cylinder firing more likely).

Operators against continuous engine should be made aware of this situation.

operation at speeds more than a few rpm above 450 rpm.

However, during engine startup, speed transients are unavoidable.

(Action will be completed by April 1, 1988.)

A and B above should be incorporated into plant operating and surveillance testing procedures.

-10 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS PNL-5600 also recommends:

"All accessible gears in the gear train As a clarification, this should be inspected at the next refueling outage to verify their PNL recommendation is continued satisfactory condition. The remaining gears should be incorporated on PII-D-S01 inspected during the next major engine disassembly, unless an of Rev. 2 of our site earlier inspection is indicated by the condition of the gears specific Maintenance inspected during the next refueling outage."

Matrix.

However, no component number is provided in the matrix.

2.1.3.13 Engine Block See Appendix A of SER for license conditions.

Stud-to-Stud Cracks (The blocks of engines that have been operated without block top inspection or that have been operated for a time in excess of the allowable fatigue damage index described in the FaAA report should conservatively be assumed to have ligament cracks (see p. 4.142 of PNL-5600))

FaAA recommends that blocks with known or assumed ligament cracks All four block top halves should be inspected following each operation in excess of 50% of were inspected with NDE nameplate load to verify the continued absence of stud-to-stud and during 1985-86.

No cracks stud-to-end cracks.

PNL recommends that eddy-current testing or a were found.

Visual similarly sensitive nondestructive testing technique should be used inspections will provide to perform these inspections.

SER concurs with Owners Group adequate assurance of clarification that these inspections may be performed using a continued absence of cracks.

borescope with heads in place and should be performed within If the engine is operated in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after engine shutdown.

excess of 50% of nameplate load, then either a visual inspection of the block top half with Widmanstaetten graphite will be performed under intense light within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of engine shutdown or FaAAos cumulative damage

-11 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS index method will be used to justify continued engine operation.

The visual inspection will be performed directly or with borescope.

FaAA recommends that, if a stud-to-stud crack or stud-to-end crack See Table B is discovered, a detailed inspection be performed to ensure that the crack extends no more than 1.5 inches in depth from the block top.

PNL recommends further that the engine not be returned to nuclear service pending further analysis of the crack and its implications for engine reliability. The analysis and the conclusions drawn from it should be subject to NRC review before the engine is returned to service. (SER has incorporated these inspections as license conditions.)

Circumferential Cracks in Liner Bore PNL concurs with FaAA that circumferential cracks do not represent a hazard to engine reliability. However, PNL recommends that any time a cylinder liner is removed, the liner landing should be inspected for circumferential cracks.

If a crack is found, its length and depth should be characterized through appropriate nondestructive tests.

The characteristics of the crack should be evaluated relative to FaAA's predictions for circumferential crack behavior.

PNL does not recommend removal of cylinder liners for the sole purpose of this inspection.

Camshaft Gallery Cracks (These inspections are for inline engines only and are not applicable to San Onofre Unit 1.)

Inspections of Cylinder Liners Per PNL Section 4.9.5.2, referring to PNL Section 4.9.3.1.2, Accessible areas of the visual inspection of cylinder liners is recommended at each cylinder liners will be refueling to monitor wear. Boroscopic inspection is acceptable visually inspected at each if the cylinder heads are not to be removed.

Per PNL Section refueling to monitor wear.

-12 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 4.9.5.2, if cumulative results of these inspections over several power plant fuel cycles show that one or more of the inspections reveal nothing of significance, the scope and/or frequency of the inspections could be reconsidered.

PNL recommends that any changes be subject to NRC review before they are implemented.

Liquid Penetrant Inspections of Block Top P.4.148 of PNL-5600 states, "Blocks with known or assumed ligament This item has been completed cracks should be inspected at each refueling outage, to determine in accordance with the whether or not cracks have initiated on the top surface exposed by Owners Group M/S program.

the removal of two or more cylinder heads.

This process should be repeated over several refueling outages until the entire block top has been inspected. Liquid-penetrant testing or a similarly sensitive nondestructive testing technique should be used to detect cracking, and eddy current should be used as appropriate to determine the depth of any cracks discovered."

For liquid penetrant inspections of engine block top at future refueling outages, Section 4.9.5.2 of PNL-5600 recommends the inspection procedures found in Section V of the ASME Code and the acceptance criteria found in ASME SA-613, Sections 19 and 20, in lieu of ASTM E125 which is the standard referenced in the DR/QR reports.

Even though NRC staff has not evaluated the merits of this recommendation, licensees should consider including this recommendation in their M/S program. If a "stud-to-stud" or "stud-to-end" crack is discovered, see license condition in Appendix A of SER. (Optional) 2.1.3.14 Cylinder Heads For Group III heads, NRC staff finds 25% sample inspection to Installation of Group III be acceptable, as expressed in plant-specific DR/QR reports.

cylinder heads on both engines PNL Section 4.10.4.3 suggests engine owner may choose to bar-over has been completed. These the engine before it is air-rolled, to reduce the possibility of heads were purchased from Imo engine damage in the event water is present in the cylinder.

Delaval to the Owners Group (See license condition regarding air roll in Appendix A of SER.)

specified criteria. The heads will be re-inspected on a sampling basis at the next 5 year interval, per Owners Group M/S program.

-13 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS Per Section 4.10.4.3 of PNL-5600, cylinder heads with any through-wall weld repair of fire deck should not be placed in nuclear standby service if repair was performed from one side only

("plug weld").

Since coolant side of fire deck is not readily accessible for welding, a repair from the combustion side might leave defects on the coolant side that would compromise the head integrity.

NRC staff recommends that the following PNL-5600 recommendations regarding future cylinder head inspections should be considered for inclusion in M/S program:

"Currently, ASTM E125 is referenced as the standard for determining whether or not linear indications, shrinkage, inclusions, or porosity are reportable. PNL notes that this standard applies only to magnetic particle (MT) inspections.

Further, PNL notes that ASTM E125 uses references photographs that were assembled by, and for, the foundry industry, and specifies acceptance standards by defect type rather than by the measured dimensions of MT indications.

Thus, field inspection personnel must identify the type of defect represented by the indication to determine whether or not the defect is reportable. In PNL's opinion, it is preferable for field-useable criteria to be based on measured dimensions specified in acceptance standards that are readily available at nuclear power plant sites.

(Optional)

PNL recommends that alternative procedures and acceptance criteria be used in future cylinder head inspections. A well-established methodology for MT examinations may be found in Section V, Article 7 of the ASME Code (1983), and acceptance criteria for MT examinations may be found in ASME SA-613, Section 19.

Methodology for liquid penetrant examinations may be found in ASME Section V, Article 6, and acceptance criteria in ASME SA-613, Section 20.

The ASME standards just referenced are widely used throughout the nuclear industry."

(Optional)

-14 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS 2.1.3.15 Cylinder Head Studs M/S program should incorporate procedures for installing cylinder The Owners Group letter refers head studs, as identified in Owners Group letter to utilities dated to a TDI Service Information September 24, 1984.

Memo (SIM) which has not been issued yet.

After the SIM has been issued, it will be used as appropriate.

2.1.3.16 Engine Base-All Models For engine bases which have been shown to be crack free, base inspection intervals should be consistent with OG recommendations.

For bases in which cracks were found to exist, per Section 4.17.4.2 of PNL-5600, monitor for crack growth by magnetic particle or liquid penetrant inspection at alternate refueling outages.

Note:

PNL concurs that it is not necessary to remove the coating to perform the visual inspection.

Check each engine base for degenerate Widmanstaetten graphite and Both engine bases will be report to NRC if found, with detailed assessment as to adequacy of checked for Widmanstaetten engine base.

graphite prior to end of next refueling. Samples will be taken and analyzed. Any adverse findings will be reported to the NRC.

2.1.3.17 Fuel Oil Injection Tubing Per Section 4.14.4.2 of PNL-5600, (1) Replacement fuel oil injection tubing should be SAE-1010 rather than SAE-1008 steel.

-15 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS (2) Fuel lines should be shrouded (if not shrouded, should be shrouded at the first refueling outage).

(3) Newly installed tubing and fittings should be inspected for wetness or other signs of leakage during engine shutdown after operation.

(4) Plant M/S program should include manufacturer's instructions concerning installation and inspection of fuel line fittings.

(5) Replacement tubing should be examined over its full length prior to bending and any tubing with flaws deeper than 0.003 inch should be rejected. This full length inspection is recommended because of intermittent indications having been found in injection tubing already examined.

PNL suggests an eddy-current probe capable of traversing the entire tube bore be used for this examination (i.e., examination would be from inside the tube rather than outside).

NRC considers items (1), (2) and (3) to be optional.

2.1.3.18 Jacket Water Pump Per Section 4.15.3.3.3 of PNL-5600, confirm that the following Implementation of these SWEC recommendations regarding the DSRV-20 engine jacket water items will be completed pump assembly have been fully implemented or incorporated into by the end of the next plant M/S program:

refueling outage.

o The impeller end of one shaft should be inspected for overtorquing damage at the first available maintenance outage, and the nut should be torqued to 150 ft-lb. The second pump should be similarly inspected at the next refueling outage.

0 The gear end of the shafts should also be inspected at the next refueling outage, and the gear nut should be torqued to a value not to exceed 290 ft-lb.

-16 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS o

The SWEC recommended torque limits (between 100 and 150 ft-lb for impeller nut and between 200 and 290 ft-lb for gear nut) should be added to the assembly procedure for the pumps.

o Keys should be properly fitted in both ends of the pump shaft.

o A second hole should be added in the gear end of the pump shaft to facilitate adequate insertion of the locking cotter pin.

2.1.3.19 Piston Skirts (Type AE)

Require AE piston skirts to be inspected at first 10 year overhaul.

See Table B Per PNL-5600, the inspections should be with liquid penetrant and, as appropriate, with eddy current. Inspected areas should include stud boss area, rib area near wrist pin boss and intersection of rib with wrist pin boss. The acceptance criteria used for these inspections are summarized in PNL-5600, Section 4.16.3.3.

2.1.3.20 Piston Skirts (Modified Type AF)

Load limitations will remain in place for Type AF piston skirts See Table B even after crankshafts have been modified.

See Appendix A of SER for license conditions. Acceptance criteria for the inspections required by the license conditions are stated in PNL-5600, Section 4.16.3.3.

2.1.3.21 Piston Skirts (Type AH and AN)

(Not applicable to San Onofre Unit 1.)

2.1.3.22 Push Rods Friction-welded design push rods should be liquid penetrant inspected before service. Subsequent radiograph inspection and destructive examination recommended by PNL-5600 are optional to utility.

PNL also suggests that new friction welded push rods may be examined simultaneously and inexpensively by radiography, to ensure the presence of "lips" inside the tube, as evidence of a sound friction weld.

(Optional)

-17 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS Ball-end design for push rods is not acceptable.

Rocker Arm Capscrews 2.1.3.23 Revision 2 of OG M/S program is satisfactory.

2.1.3.24 Turbochargers:

Limit the maximum cylinder exhaust temperature to 1050OF to ensure turbine inlet temperature does not exceed manufacturer's recommendations.

Implement full flow lubrication during engine coast down (optional).

Incorporate in M/S program quarterly spectrochemical and ferrographic oil analyses recommended by FaAA to provide early evidence of bearing degradation.

Plant M/S program shall specify that any turbocharger in which nozzle ring anomalies are found as the result of OG recommended inspections should be reinspected at the next refueling outage.

Plant M/S program should clarify that the provision to No Elliot redesign for nozzle discontinue nozzle ring inspections after nozzle rings of rings is available at present.

an appropriate redesign have been installed does not apply If a redesign is available in to the turbocharger inspections which are performed at the future, the M/S program 5 year intervals (but applies to inspection of one will be clarified. If nozzle turbocharger per refueling outage).

ring inspections are discontinued, NRC will be notified.

See Appendix A of SER for license conditions.

2.2 Technical Resolution of Phase II Nuclear Unit 1 DR/QR program for Phase II should be fully Not applicable to San implemented for the Nuclear Unit 2 engines.

Onofre.

-18 SER SECTION RECOMMENDATION/LICENSE CONDITION COMMENTS Per Section 4.0 of PNL-5336 and PNL-5444, incorporate into plant M/S program the additional PNL recommendations relating to improvements for seven components (optional).

Each individual owner should implement all Owners Group recommendations stemming from plant specific Phase II evaluations.

2.3 M/S Program Prior to issuing final plant specific SER, NRC will require SCE's commitment to an acceptable M/S program that incorporates the following elements.

(1) The recommendations concerning operation, testing, inspection, Only those PNL M/S recommenda@

maintenance, adjustment, overhaul and repair of the engine as tions specifically identified incorporated in the TDI Instruction Manual, Service Information and endorsed in Section 2.1.3 Memos (SIMS), and TDI correspondence on specific M/S issues.

of the SER are SER recommenda tions. The remaining PNL M/S (2) The M/S recommendations developed by the Owners Group in items will be implemented at Appendix II, Revision 2, of the DR/QR reports.

SCE's discretion.

10 CFR 50.59 review is not needed (3) Additional Phase I items required per Section 2.1.3 of SER.

for these remaining M/S items.

Revisions to M/S program subsequent to issuance of final plant No M/S recommendation should specific SER should be subject to 10 CFR 50.59 review. Changes be a license condition.

to license conditions will be subject to NRC approval.

3.

Conclusions As stated in SER.

As stated above.

NOTES:

DR/QR tDesign Review and Quality Revalidation M/S =aMaintenance and Surveillance SaSfeCtE' Evaluation Report IAA:8272F

TABLE B COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (SER)

The items listed in Appendix A should not be license conditions, nor should they be otherwise mandatory. In addition, specific items should be changed as follows, for the reasons indicated. Any additional changes to these items after issuance of the final San Onofre Unit 1 SER should be subject to 10 CFR 50.59 review.

Requested Change Basis for Change Item No. 2 (Connecting Rods)

The fourth condition should be changed to read as This allows for alternative NDE methods.

follows:

o All connecting-rod bolts will be visually inspected for thread damage (e.g., galling),

and the two pairs of connecting rod bolts above the crankpin will be inspected by an appropriate NDE to verify the continued absence of cracking. All washers used with the bolts will be examined visually for signs of galling or cracking, and replaced if damaged.

The sixth condition should be changed to read as This allows for alternative NDE methods.

follows:

o All of the bolt holes in the link rod box will be inspected for thread damage (e.g., galling) or other signs of abnormalities.

In addition, the bolt holes subject to the highest stresses (i.e., the pair immediately above the crankpin) will be examined with an appropriate NDE to verify the continued absence of cracking. Any indications will be recorded for engineering evaluation and appropriate corrective action(s).

-2 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change Item No. 4 and Enclosure 2 (DSRV-20-4 Crankshafts and Modified Type AF Piston Skirts)

The first two conditions of Item No. 4 should be changed to read as follows:

o At each refueling outage, oil hole locations Inspection experience and FaAA analyses show that in the two most heavily loaded main journals cracks will first initiate and propagate most (i.e., journals 9 and 10) for each crankshaft rapidly in the #9 journal oil hole followed by will be inspected and any indications found the #10 oil hole.

Inspection of the #9 and #10 will be evaluated with an appropriate NDE.

oil holes will reveal.if cracking has reinitiated.

Alternative NDE methods should be permitted.

W o

During each major engine overhaul, the fillets This clarifies that dowel pin holes will also be of the most highly loaded main journals inspected and allows for alternative NDE methods (nos. 4 through 12) together with the and reliance on engineering evaluation to corresponding oil and dowel pin holes will be determine appropriate corrective action(s).

inspected.with an appropriate NDE. Any indications found will be recorded for engineering evaluation and appropriate corrective action(s).

In addition, these inspections will be performed for the oil holes and fillets in at least three of the crankpin journals at each major engine overhaul.

The third condition of Item No. 4 should be deleted.

The third.condition is addressed in detail in of Appendix A.

-3 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change The fourth condition of Item No. 4 should be changed Corrective action(s) for the engine need to be to read as follows:

initiated by SCE to expedite its return to service.

"Promptly" is defined as "within 0

If cracks are found during the above 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to make the reporting requirement inspections of the crankshafts, this condition better understood and implemented.

will be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC staff. Appropriate corrective action(s) will be taken and a report on these corrective action(s) will be submitted to the NRC prior to restoring the engine to service. should be changed in its entirety to read as follows:

The following actions will be taken for the As the piston skirts are qualified up to 4500 kW crankshaft and for the modified Type AF piston skirts

+ 5% (4725 kW), no additional inspections are if the engine is operated in excess of 4725 kW.( 1 )

necessary up to this limit.

(a) For indicated engine loads in the range of The brief 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period of operation to 6000 kW 4725 kW to 6000 kW for a period of less than would not significantly propagate an existing 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />( 2), inspections pursuant to Items crack, but would allow reasonable time for c.l and c.ii below will be performed for the correcting inadvertent engine operation to affected engine at the next refueling outage.

6000 W.

(b) For indicated engine loads in the range of Operation in the range of 4725 kW to 6000 kW for 4725 kW to 6000 kW for a period equal to or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or more or at loads greater than 6000 kW exceeding 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />( 2 or for loads greater for less than 15 minutes is not a significant than 6000 kW for less than 15 minutes( 2), a contributor to crack initiation or propagation written safety evaluation pursuant to 10 CFR in the crankshaft or in the piston skirts and 50.59 will be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

therefore should not cause the engine to be removed from service, declared inoperable and subjected to crankshaft and piston skirt inspections. A safety evaluation may very well conclude that it is safe to delay these inspections to a planned outage period.

-4 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change (c) For indicated engine loads reater than 6000 kW for 15 minutes or more,( ) 1) the engine will be removed from service as soon as safely possible, and 2) inspections pursuant to Items (i) and (11) below will be performed:

(1) A crankshaft inspection will be performed Inspection experience and FaAA analyses show which will include the main journal oil that cracks will first initiate and propogate hole numbers 9 and 10 using an most rapidly in the #9 journal oil hole followed appropriate NDE. If cracks are found by the #10 oil hole.

Inspection of the #9 and during these inspections of the

1. 10 oil holes will reveal if cracking has crankshaft, this condition will be reinitiated.

Alternative NDE methods should be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC permitted. Corrective action(s) for the engine staff. Appropriate corrective action(s) need to be initiated by SCE to expedite its will be taken and a report on these return to service.

"Promptly" is defined as corrective action(s) will be submitted to "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

the NRC prior to restoring the engine to service.

(ii) The stud boss attachments of the modified Alternative NDE methods should be permitted.

type AF piston skirts will be inspected Corrective action for the engine needs to be with appropriate NtE.

If cracks are initiated by SCE to expedite its return to found during these inspections of the service.

"Promptly" is defined as "within 24 piston skirts, this condition will be hours."

FaAA Report No. FaAA-84-2-14 need not reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC be referenced in the "license condition" even staff.

Appropriate corrective action(s) though it will be considered in establishing the will be taken and a report on these appropriate corrective action(s).

corrective action(s) will be submitted to the NRC prior to restoring the engine to service.

-5 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change Item No. 5 (Cylinder Blocks)

The first condition should be changed to read as During 1985-1986, NDE was performed on the follows:

entire right block top of DG No. 1 with some cylinder liners removed and on the areas between o

Whenever 50% of engine nameplate load has been adjacent stud holes and the stud to liner areas exceeded, the accessible areas of the cylinder on the left block top of DG No. 1 and both block block tops will be visually inspected under tops of DG No. 2. No indications were found.

intense light to verify the absence of At the time of its inspection, the right block cracking. Alternatively, the cumulative top of DG No. 1, which alone has the degraded damage index method developed by Failure Widmanstaetten graphite microstructure, had Analysis Associates (FaAA) may be used to accumulated approximately 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of operation justify continued engine operation.

at loads up to 6600 kW.

Visual Inspections will provide adequate assurance of continued absence of cracks.

FaAA's cumulative damage index method may be retained as an alternative.

The second condition should be deleted.

The entire block tops have been inspected and no cracks found.

This section is no longer applicable to San Onofre Unit 1.

The third condition should be changed to read as Corrective action(s) for the engine need to be follows:

initiated by SCE to expedite its return to service.

"Promptly" is defined as "within o

If inspection reveals cracks in the cylinder 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

blocks between stud holes of adjacent cylinders ("stud-to-stud" cracks) or "stud-to-end" cracks, this condition will beas reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC staff.

Appropriate corrective action(s) will be taken and a report on these corrective action(s) will be submitted to the NRC staff prior to mrestoring the engine to service.

-6 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change Item No. 6 (Cylinder Heads)

The subheading and the first two sentences of the condition should be changed to read as follows:

The following air roll test will be performed as The San Onofre Unit 1 Technical Specifications specified below, except when the plant is in one are written and numbered differently than the of the Action Statements of Technical standard Technical Specifications.

An engine Specification 3.7.I.B, in which case the operable should not intentionally be put into a condition diesel generator(s) need not be air rolled.

where it cannot receive a start signal if the other diesel(s) or other AC sources are already inoperable.

The engines will be rolled over with the airstart One air roll need not be followed by another air system and with the cylinder stopcocks open prior roll within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

to each planned start, unless that start occurs within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a preceding engine shutdown or air roll.

The engines will also be rolled over with the Multiple engine shutdowns within the same airstart system and with the cylinder stopcocks 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period should not result in multiple air open after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, but no more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after rolls.

each engine shutdown and then rolled over once again approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the shutdown.

However, if the engine is operated such that it is shut down more than once in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, then this recommendation will apply only to the last shutdown.

Item No. 7 (Modified Type AF Piston Skirts)

The first condition should be changed to read as follows:

-7 COMMENTS ON APPENDIX A OF SAFETY EVALUATION REPORT (Continued)

Requested Change Basis for Change o

The stud boss attachments of the modified type Alternative NDE methods should be permitted.

AF piston skirts will be inspected at each major engine overhaul with an appropriate NDE.

(This recommendation may be deleted for individual piston skirts after they have completed 750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br /> of service at engine loads equaling 4500 kW +5%).

The second condition should be completed to read as follows:

o The piston skirt inspections described in This section is left incomplete in the SER. will be performed as applicable if the engines are operated in excess of 4500 kW + 5%.

Item No. 8 (Elliot Model 65G and 90G turbochargers)

The last condition should be changed to read as follows:

o The nozzle ring components and inlet guide These changes are consistent with the vanes will be visually inspected on a one clarification presented in the body of the SER, turbocharger per refueling outage basis for which states that the nozzle ring components of missing parts or parts showing distress. If only one turbocharger per refueling will be such are noted, the entire ring assembly will visually inspected, with all the turbochargers be replaced.

being inspected at the engine overhaul.

(1)

Load transients not exceeding 10 seconds for Load transients of 10 seconds or less duration any cause need not be considered as an for any cause would not result in significant overload.

overloads.

Changing 5 seconds to 10 seconds would assist in better operator recognition of a (2)

If there are multiple overload events within a valid load transient.

given load range since the previous crankshaft inspection, then the time period criterion applies to the total accumulated time in that load range.

IAA:8370F