ML18040A005

Monthly Operating Repts for Jul 1997 for San Onofre Nuclear Generating Station

ML18040A005
Person / Time
Site:	San Onofre
Issue date:	07/31/1997
From:	Gibson G, Williams C SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9708210407
Download: ML18040A005 (36)

Text

ENCLOSURE 1

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 2 AND 3 TEMPORARY EXTENSION OF EMERGENCY DIESEL GENERATOR (EDG)

ALLOWED OUTAGE TIME

RESPONSE

TO REQUEST FOR ADDITIONAL INFORMA.TION (RAI)

DATED JULY 17, 1997 Below are responses to the three NRC questions provided in the subject (RAI) on Technical Specification (TS) change request TS-391T.

NRC Question 1

Provide a description of work to be performed during the planned 12-year diesel generator preventive maintenance outage.

Include schedules for this work, assuming:

a. All activities are completed within a single outage.

b. Activities are split between two or more outages.

TVA Res onse As discussed in the TS-391T submittal, overall EDG unavailability may be reduced by combining the pending 2-year and 12-year vendor recommended preventive maintenance (PM) outages.

Estimated schedules for separate 2-year and 12-year

PMs, and a combined outage are provided below.

Attachment 1 provides a summary schedule for the 2-year inspection for EDG 3A which is the most recent inspection performed.

The various work activities for this particular outage are shown on the schedule.

The predicted duration for this outage was 4 days 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and is representative of the 2-year inspections.

The 2-year inspections occur relatively frequently and the best-estimate schedule durations have a good experience base.

The schedule duration is predicated on an assumption that no major unexpected problems are encountered in the work scope or in work performance.

Attachment 2 is a draft 12-year inspection schedule for EDG 1A.

t A listing of major activities associated with the 12-year PM is shown on the schedule.

Details of the schedule are still in

development.

Estimated duration of the PM is 5 days 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The work schedule does not include diesel-specific corrective maintenance work awaiting an outage, and assumes no major problems or work delays are encountered.

As discussed in the TS-391T submittal, the predicted schedule duration does not have a solid experience base due to the infrequency of performance.

Attachment 3 is the combined 12-year/2-year draft schedule Major activities include the combination of the 12-year and 2-year PM activities from the two schedules listed above.

Duration is estimated to be 6 days 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.

The work schedule does not include diesel-specific corrective maintenance work awaiting an outage, and assumes no major problems or work delays are encountered.

Also, as discussed in the TS-391T submittal, the predicted schedule duration does not have a solid experience base due to the infrequency of performance of the 12-year PM activity.

NRC Question 2

Describe how these activities were accommodated during previous 12-year preventive maintenance outages.

TVA Res onse The 12-year PMs have been conducted once previously in late 1985/early 1986.

From the maintenance

records, the shortest reported completion time for the work and testing was 16 days.

At the time, all three BFN units were in an extended outage

and, therefore, there would have not been a high TS driven priority for completing the PMs.

Also, some EDG modifications were performed during these particular outages.

Hence, it is not appropriate for TVA to reference these PMs performances as a

meaningful measure of expected duration of the upcoming 12-year EDG PMs.

The basic work control processes have also evolved considerably since 1986 and for this reason, it is likewise difficult to compare past performance with current work scheduling and work control practices.

NRC Question 3

Current technical specification (TS) 3.9.D.l reads as follows:

Whenever standby gas treatment is required to be OPERABLE in accordance with Specification 3.7.B and/or control room emergency ventilation is required to be OPERABLE in accordance with Specification 3.7.E, the associated diesel generator aligned to supply emergency power to that equipment shall be OPERABLE.

E1-2

a.

Standby gas treatment train A and/or control room emergency ventilation train A Diesel generator 1/2A or 1/2B.

b. Standby gas treatment train B Diesel generator 1/2D or l/2B.

c. Standby gas treatment train C

Diesel generator 3D.

d. Control room emergency ventilation train B Diesel generator 3C or 3B.

This specification apparently requires that certain diesel generators be operable in order to 'consider standby gas treatment and control room emergency ventilation trains to be operable.

In cases (a),(b),and(d),

either of two diesel generators can fulfill this function.

In case (c), only diesel generator 3D can be used in order to consider standby gas treatment train C to be operable.

TS 3.7.B.3 allows reactor power operation and fuel handling to continue only for the succeeding 7 days with one train of standby gas treatment inoperable.

Therefore, even if the allowed outage time for diesel generator 3D is extended to 14 days, it appears that TS 3.7.B.3 would not permit reactor power operation for more than 7 days.

Page El-2 of TVA's June 19, 1997, submittal states that TS l.C.2 provides that, when the units are operating, the diesel generator limiting condition for operation governs the operability related to temporary unavailability of on-site power sources, provided that all redundant systems and subsystems are available.

However, the staff believes that TS 3.9.D.l.c governs the case if diesel generator 3D is inoperable, because it provides specific requirements for that case.

Therefore, the staff requests that TVA either provide additional information which demonstrates that TS 3.9.D.l.c will not result in invocation of TS 3.7.B.3 if diesel generator 3D is inoperable for more than 7 days, or provide additional TS changes eliminating this problem, including appropriate justification for those changes.

TVA Res onse In the TS-391T submittal, TVA had indicated that in regard to TS 3.9.D.l, for the circumstances when an EDG was temporarily inoperable on an operating unit, TS 1.C.2 was applicable for the purposes of operability considerations for the shared equipment.

Therefore, the base allowed outage time (AOT) for inoperable EDGs as specified in TS 3.9.B would be governing in accordance with TS 1.C.2, and the requested 14-day AOT in the proposed

revision to TS 3.9.B would then be directly applied to the shared systems listed in TS 3.9.D.1.

Accordingly, TVA indicated no changes to TS 3.9.D provisions were needed to apply the requested AOT extension.

To address the RAI concern over a possible misapplication of TS 3.9.D.1 for an extended EDG AOT, TVA agreed to provide a

supplemental TS change to TS-391T to clarify TS 3.9.D.1 to explicitly reference 1.C.2 for units that are in operation.

This change is consistent with the standard application of TS 1.C.2 which provides that supported systems are not required to be declared inoperable solely due to the temporary unavailability of emergency onsite power sources (provided that redundant power sources and system components are operable).

For this situation, the base AOT for the inoperable EDG is invoked rather than the AOTs of the individual systems supported by the EDG.

The enclosed supplemental change to TS-391T will ensure a clear and common understanding of the appropriate application of TS 3.9.D.1 for an extended EDG AOT.

Since the same concern in the RAI is pertinent to TS-376, it is being revised herein in a like manner.

El-4

ENCLOSURE I ATTACHMENT1 WORK SCHEDULE FOR LAST 2-YEAR EDG 3A INSPECTION

3A DIESEL GENERATOR OUTAGE - 2 YR INSPECTION ENTER 7 DAY LCO 3A DSL.

GEN.

OPERABLE 0300 SFT1 FRI FRI 12/13 12/13 1530 WED 12/11 0700 MON 12/9 0100 MON 12/9 FRIDAY12/6 T39684 - PREP.

CABINETS FOR WELDING MODS -8 HR 0300 1200 1730 MON TUE WED 12/9 12/10 12/11 12/12 TAG OUT BEGIN 0700 MpDIFY

'EE PAGE I

I 3A DG ~

DRAIN I

HOLD

~IX.9%1a(3A)

BY0300 ~ DOWNOF~

~ RETURN Tp MON OIL/WATER 1

ORDER SERVICE OPERABILITY OPS Sl DG INSTRUMENTATION SEQUENCE I

I CALS laC I

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NOTE: OPS NbTIFY SEE DETAILS SEE NOTE I

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MMAS SOON'AS ON PAGE 3 3 (BELOW)

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TAGGING COI4PLETE I

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I PRELMNARY Sp MMCAN BEGIN I

g I

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WATER DRAI(4 I

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I DOWN WDSL.GEN.2YEARINSPECTION PM / MM SEE DETAILS ON PAGE 2 I

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I WORK PACKAGES /

~CORRECTIVE MAINT.ANDASSOCIATED I

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PMS/SEE DETAILSPAGE 2,3,4, 5

~

7 W34697A TESTING TAGGING SSI<9A.1 e(3A)

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W34697A I

I 0300 RTOCLOSURE'LT. ACCEPT MON ISSUE 83 S. E.-4 HRS MAINT.~ T.S., OPS 12/9 g

1200 MODS-2 HR I

MpN MODS 4IHR I

T39684-i I

ANCHORQ RTp CLpSURE i ~~

PLT.ACCEPT PANELS -

g MODS HR S, E, 4 HRS ggJ~

~NT

~ T.S,

~ OPS MODS 9 HRS MODS-2HR SI-4.9A.1.d - DSL. GEN. ELECTRICAL INSPECTION Sl / EM SEE DETAILSON PAGE 5 7/27/97 3AB11296.WFL PAGE 1PF5

0

3A DIESEL GENERATO UTAGE - MM DETAILS 960858200 REMOVE COOLER HEADS/

CLEAN COOLERS 960858200 COOLER REPAIR/

TUBE PLUGGING AS RECD 0700 MON 12/9 SFT3 MON 12/9 SFT3 TUE 12/10 0300 MON TAG 12/9 OUT 3A DG BY0300 MON 12/9 OPS I

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I II III I

IIII II 961234400 DRAIN DOWN WATER AS REQ'D MM SFT1 SFT2 WED WED 12/11 9608582OO 12/11 REPL COOLER 960858200 EDDY CURRENT ANALYSIS OF DG COOLERS EDDYCURRENT 3

SFT 2 12/10 9607332-26,27,28,36 INSPECT EECW CHECK VALVES MM-16HRS 961234400 C354515-LOW OIL LEVEL

&ooo'urn~

REQUIRED 961234400-2 YEARMECH. MAINT.PM-ITEMS MAYBE PERFORMED OUT OF SEQUENCE TO FACIUTATEFLOW OF WORK.

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1 961234400- 2 YEARMECH. MAINT.PM-ITEMS MAYBE PERFORMED OUT OF SEQUENCE TO FACIUTATEFLOW OF WORK. PERFORM ITEMS THATWILLALLOWOIL ANDCOOLANTTO BE ADDEDBACKTO DSL. GEN.

REL'O ON LUBE OIL CIRC PMP MVI TO PAGE 5

1530 1730 WED WED A

12/11 12/11 MODIFY HOLD ORDERS OPS I

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TEST I8C SEE PAGE 3 NOTE: OPS TO HAVEDG TAGGED BY0300. THIS IS TO ALLOWMM TO START DRAININGDOWN WATER.

964)1235440(hCOMPRESSOR PM4I HRS (hM)

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C323106-INSPECT FOR WELDCRACKS I

ON FUEL UNE LINKAGESUPPORTS I

- MVI-4 HR (M!NOR MAINT)

I 96414937400- WOODWARDGOV. OILLEVELHIGH - MM4 HR I

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II 96012346400-COMPRESSOR PIVWAVI8 HRS I

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964139654)00-DG LUBE OIL SAMPLE-(MVI)4 HRS I

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951372600- CLEANMOISTURE SEPERATOR/

I INSPECT CHECKVALVES-MM-8HRS I

I 960706300- INSPECT / REPLACE DSL GEN AIRHOSES - MM20HR 3

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I NOTE:

SEE PAGE 3 (CHEMISTRY DETAILS.)FOR REQUIRED MM SUPPORT.

PMT LEGEND PMT~

1. 3SIP.9A.1+,(3A) DG OPER. Sl, ANDNO EXTERNALLEAKAGE

2. MPI4482-INS002-INSPECTIONS/CHECKS PRESTART ANDWITHDG RUNNINGJ~h4 o/A.1a(3A)4A DG OPER Sl

3. VERIFYNO EXTERNALLEAKAGEATSYSTEM PRESSURE/MM

4. 'NOT DETERMNEDATTHIS FRAGNET REVISION.

5. NONE REQ'D PAGE 2OF5 7/27/97 3AB21296.WFL

3A DIESEL GENERAT OUTAGE - 18C DETAILS 1200 REQUIRES DG TUE EECW SYS.

12/10 RESSURIZED THU 12/12 I

SI-3.2.4 DG 3A EECW CHECK VALVE I

FLOW TEST 0300 MON 12/9

~~N NOTE COMPLETION OF INSTRUMENTGALS ANDRELEASE OF HOLD ORDER BY IdC IS PREDECESSOR TO BEGINNINGOF TIME DELAYRELAYS BY EM (SEE PAGE 5). COMPLETE GALS BY 1200 TUESDAY TAG OUT AIR/

BLEED CAUBRATEPRESSURE SWITCHES ANDINDICATORS DOWN ON DSL. GEN. STARTINGAIRSYSTEM PI46401 PI46402 PI46-727 PI46-762 PS46401 PS46401 PI46-728 PI46-763 I

PS46402 PS86402 PI4864729, PI4864764 I

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DRAINDOWN AND WATER CAUBRATEPRESSURE SWITCHES ANDINDICATORS LUBE OIL SYSTEM ON DSL. GEN. FUEL OILANDLUBE OILSYSTEMS SYS.

I MM I

OPS g

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-1 68-.

1

-1 6-1 l42-1 S42-12 P -1848 I

I PS-18-69 PS42-13 I

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D TAG OUT DSL. GEN~"

A)PS DRAINDOWN COOLING SYSTEM MM REMOVE PS42-15 INSTALLPS42-15 (CRANKCASE PS) ~

CAUBRATEPS42-15 (CRANKCASE PS)

QA REQ'D I

I CAUBRATEPRESSURE SWITCHES ANDINDICATOR.

ON DSL. GEN. COOLING ANDLUBE OILSYSTEMS.

TAG OUT WATER AND LUBE OIL SYSTEMS OPS PS424 PS-824 PS42-10 I

INSTALL TEMP. SWS QA REQ'D.

REMOVE CAUBRATE TEMP. SWS.

TEMP. SWS.

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I TS42-2 TS42-7 TS42-9 I

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REMOVE CALIBRATE INSTALL TEMP.

TEMP. INDICATORS.

INDICATORS 9607332-26, -27

-28,36 SEE MMDETAIL PAGE FOR PREDECESSOR TO PERFORM OF THIS SI. WHICHSERVES AS PMT DSL

. GEN. INST. CAL.WO'S 951962700 961219500 961219700 961219800 961219900 961220000 961220100 961220200 961220300 961220400 DSL. GEN. CORRECTIVE MAINT 951048300- 3-PI424004A 1

PMT LEGEND PMT~

1. -VERIFYCAL TI42-1 TI424 TI42-18 TI42-16 3A DIESEL GENERATOR OUTAGE-CHEMISTRY DETAILS 10 YEARCLEANINGOF DSL GEN. 7-DAYFUEL OILTANKS (REQUIED BY REG. GUIDE 1.137) 96413896400 BY0700 PUMP FUEL OILOUT OF 7-DAY TANKTO STG TANKJ TAG OUT FUEL OILVALVES OPSY HR 96413896400 REMOVE FLR COVER

~ UNBOLT 12 OF 16 TANKCOVER BOLTS (DO NOT BREAKTANKSEAI.)

MM 1200 MON 96413896400 12/9 96413896400 INSPECT TANK FOR CLEANINESS PUMP/VENT/CLEAN7-DAYTANK-20 HR PER TI-94, PLUS FTM OTHER INSPECTIONS CHEM-4 HRS NOTE: MMREMOVE/ REPlACE HATCHES - WO - 96013896400 1.

(1) 4QUEGEE TANK,.REMOVE SEDIMENT/SLUDGE. NaOCL WIPEDOWN.

2.

CONRNED ENTRYPERMIT-CHEMISTRYTOINITIATE 3.

FIRE PROTECTION REVIEW (OBTAINPERMITS AS REQUIRED) - CHEMISTRY 4.

FME ISSUES (CHEMISTRYTO EVAlUATE/ASSURETHIS ISS(/E ADDRESSED)

SFT1 WED 96413896400 12/11 r UMP 044 FUEL OIL BACKINTO PAGE 5 SYSTEM OPS-6 HRS TANKRERLL PREDECESSOR TO DAYTANK LEVELSW CAL BY EM PAGE 3OF5 3AB31296.WFL 7/27/97

3A DIESEL GENERATOR OU E - BATTERYDISCHARGE

. DSL. GEN. 3A TO BE TAGGED OUT BY0300 3A DSL. GEN. OUT OF SERVICE A

FT2 SFT 2 THU THU 12/5 12/5 3$14.9A2.CN VERIFYIPLACE FLOAT CHARGE FT1 MON 12/9 SFT 2 SFT 1 MON MON 12/9 12/9 3$IP.9A2.b3 s

0l00 3$&c/A2.Cg)

QUARTER Sl PERFORM PERFORMELECTRICAL ON BATTERY LINEUP PERSI EM-4 HR I

OPS-1HR SFT 3 MON 12/9 3$I4.9A2.Cg)-DG BATTERY DISCHARGE Sl B

EM/OPS-SHR BATTERYMUST BE ON FLOAT CHARGE AT LEAST 3 DAYS PRIOR TO DG BATTERY DISCHARGE MUST BE PERFORMED WITHIN24 HRS OF BATTERY DISCHARGE DG BATT.

INOP 96413626400 CAL. BATTERYCHARGER METERS TPS-8HR PRECAUTIONS IUMITATIONSIPREREQS.

PER: 3$ l<9A2.Cg). DSL. GEN.

BATTERYDISCHARGE Sl-SECTION 3.0 8 4.0, EM/OPS B

SFT 3 MON 12/9 3$ 14.9A2.GIB PERFORM 24 HOUR EQUAUZING CHARGE OF BATTERY EM-24HR 3A DG OUT OF SERVICE SFT 3 TUE 12/10 3$IP.9A2.b$

PERFORM QUARTERLYSl ON BATTERY EM-4 HR 3$ I-4cIA2.Cg)

COMPLETE 3$I49A2.C/0 RETURN BATTERY TO SERVICE / LOADS TO NORMAL CONFIGURATION EMIOPS -1 HR NOTE: ELECTRICAL UNEUP PER 3$I4.9A2.Cg) WILL NOT BE COMPLETE UNTILDSL. GEN.

HOLDORDER RELEASED (e.g., CLOSE LOGIC BKR.)

3$ IA.9A2.C/lj VERIFYBATTERY CAPACITYEQUALTO OR MORE THAN 80% OF RATED CAPACITY EM SFT 2 MON 12/9 961362500 CALGROUND METERS TPS-8HR SUCCESSFUL COMPLETION OF 3$IRBA2.b$ (QUARTERLYSl)

ANDVERIFICATIONOF BATTERY CAPACITY > 80%

REQUIRED TO DEClARE BATTERY OPERABLE.

NOTE: PLACE DG BATTERYON 24 HR EQUALIZINGCHARGE. COMPLETION OF 24 HR CHARGE IS N577KGOIRED TO SIGN OFF Sl. OR TO PLACE DSL.

GEN IN SERVICE NOTE: THIS IS ONLYA

SUMMARY

OFDG BATT.DISCHARGE Sl.

- ALLSTEPS OF Sl ARE NOT SHOWN.

7/27/97 PAGE 4 OF 5 3AB41296.WFL

0700 MON 12/9 A DIE EL ENER R

UTA E EM C

1530 WED 12/11 TAG OUT 3A DSL. GEN.

BY 0300 MON 12/9 OPS I

SIR.9A1.D-TIMEDELAYRELAYCHECKS. DG ELECT. INSPECTIONS, FUEL OIL PUMP MOTOR INSP., LOADBKR. CLOSING SPRING CHARGING TIMETEST. MEGGER LUBE OILCIRC. PUMP MTR.

I-SI49A1.d - CALDG TACH.ANDINSPECT PROTECTIVE RELAYS - TPS -8 HR.

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96-05716400 18 MO CALOF 3A D/G EXH I

FANS A 8 B TDDO RELAYS-EM(8 HRS)

I 96414995400-REPAIR VOLTMETER I

TPS4 HRS 5

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I SFT 1 g ~

96419063400-PM ON D/G OUTPUT BKR WED r-~

9&014994@00 REPAIR BKR COhhP 12/11 I

EM4 HRS I

961141905-REPL OVERSPEED LIMITSWITCH - EM 8 HR I

I Ir----

96415096400 -RELAYREPLACEMENT-EM - 16 HR 4

I 960722704,

-INSPECT GOV. EG-A CONTROL 1

BOXES-EM 4HR 960571500 CALTRANSFER PUMP LEVELSWITCHES EM 12 HR RETURN TO SERVICE / TESTING SE UENCE SFT 2 WED 12/11 A

SI4.9A.1.d 961243100 12/12 GOV. VOLT CONTROl. 8 OVERSPEED TRIP TEST EM/OPS MM UALLYROLL 44 HR ALLCRAFTS TO BE OFF DG HOLD ORDERS AT THIS POINT, EXCEPT FOR EM.

C3231 064%I WILLNOT HAVETO CLOSE WORK PMT LEGEND PMT

1. PMT NOT REQUIR

2. VEFIFYFAN OPERATION

3. SUCCESSFUL CAL 4.

REDUDANTSTART/34I498.1x(3A)

5. OVERSPEED TRIP TEST ANDALARMPER (3414.9A.1.d(3A) (3A DG 2 YR ELEC INSP) 3AB5129 6.WFL 7/29/97 PAGE 5OF5 96412202400-IM 96412204-000-IM 96414995400-TPS 95419063400-EM 96411419405-EM 1730 WED SI-4.9%.1.d SIN.9A.1.d SIR.9A,1.d 12/11 SPEED PROTECTIVE IMMERSION SW RElAY HEATER CAL CHECK CHECK EM/

EM/

EM TPS TPS 1HR 1 1/2 HR 11/2HR rr I

SI<.9A.1.d r

ALARMCHECKS MAN

-EM/OPS - 10 HR 3A DSL GEN IN PREP FOR RUN PERFORM OPS-1 HR INST. CHECK UST AT OPS REQUEST IM-1 HR IMMEDIATEATTENTIONI EMERGEN SFT1 FRI 12/13 96413625400-TPS 964123544004tlM 96413625400-TPS 9641396540041M 96413896400CE 96412203400-IM 964073324264Th T

9640733242Wm T

964073324284M T

9640733243um T

3A DG OPER W34697A-NM T

T3968 4-NM T

95419627000-IM T

96412197400-IM T

96415096400-EM T

954137264004th T

96412199400-IM T

96412198400 IM 96405715400-EM T

96407227404-EM T

I 3$IA.9A.1.d(3A) 3A DG 2 YR T

964123464004M INSP. - EM 954104834004/I 96412195400-IM 96405716400-EM 34'.9A2.C(l)

BATT. DISCH.

96408582400MM T

964123 444004IM T

O '6412198400-9/I

'6412201400-IM 96412200400-IM 961234400 SFT3 THU 12/12 961509600 34IA.94.1.a(3A)

HOT 'TART RACK ~~

TEST ~~ DG OPER Sl ~

SSS/OPS ERIC ~~ OPS/CHEM.~ CLOSURE OPS 4HR SIGNOFFS 3HR 6HR

ENCLOSURE 1 ATTACHMENT2 DRAFT SCHEDULE FOR 12-YEAR EDG INSPECTION

1 IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE N

ENTER 7 DAY LCO 1A DSL.

GEN.

PERABLE EVENING SHIFT SUN 11/2 04IC.9A.1.a(A) 1B DSL GEN OPER. SI OPS/CHEM 6HR PRELIMINARY (SEE NOTES BELOW) 0500 MON 11/3 0700 MON 11/3 1700 FRI 11/7 TAG OUT 970726800 - 12 YEARMECHANICAL1A DG O

MEC~ICALPREVENTA~~NTE~C SEE PAGE 2 I

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CORRECTIVE MAINT.ANDASSOCIATED PMS MODIFY HOLD ORDER OPS 0500

-C c6 SEE PAGE 3 NOTE:

PMTFOR STARTER CHANGEOUT 04IA9A1a(A) 1A DG OPERABIUTY Sl DOCUMENTATION REVIEW OPS 1300 SAT 11/8 8/15/97 1A121197.WFL PAGE 1 OF 3

IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE ON TAG OUT lADO ~~REMOVEDUCTq~)

COOLING)

DRAIN ENGINE OIL FOR CHANGE I

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ENGINE I

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INSPECT ENGINE INTERNALS CLEANTHE LUBE OILSTRAINER BOX, STAINER, AND FLEXIBLESEALS REPLACEMENT MAIN OILFILTER ELEMENTREPLACEMENT OIL AUX.TURBO OIL FLT. ELEMENTREPLACEMENT TURBO CHARGER OL FILTER ELEMENTREPlACEMENT LUBE OILCIRC. SYSTEM INSPECTION CLEAN LUBE OILSEPERATOR AND EJECTOR OIL BATHAIRFILTER INSPECTION LUBE OILCIRC PUMP ANDFLEXIBLESEALS REPL LUBE OIL FILTER BYPASS VALVEREPLACEMENT POWER ASSEMBLYREMOVAUREISNTALlATION:GASKET, SEALS, LOWER LINER SEALS REPLACEMENT, SEAT RING INSPECTION, FUEL INJECTOR QUAUFICATION.

~)Q DUCTWORK-~

MMIEM TO PAGE 3 p

REPlACE~

0,"': 0 AIRSTART CHECKVALVEREPLACEMENT AIRSTART RELAYVALVEREPlACEMENT AIRSTART VALVEREPlACEMENT AIRSTART MOTOR SERVICING AIRSTART MOTOR REPLACEMENT AIRBOX DRAINLINECHECK SET FUEL INJECTOR RACKS FUEL TRANSFER STRAINERS INSPECTION FUEL TRANSFER FILTER ELEMENTS REPLACEMENT FUEL PUMP SUCTIION STRAINER INSPECTION ENGINE FUEL FILTER REPlACEMENT ENGINE DRIVEN FUEL PUMP REPlACEMENT MOTOR DRIVENFUEL PUMP REPLACEMENT WATER PUMP ANDCOOUNG SYS.

FLEXIBLESEALS REPL ENGINE VIBRATIONDAMPER INSPECTION SERVICE ENGINE GOVERNOR PERIODIC TIGHTNESS CHECK TOP DECK COVER SEAL REPLACEMENT E

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PAGE 2 OF 3

1 IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE N

1700 FRI 11/7 MODIFY ENGINE HOLD 0

PRELUBRICATION OQ BAR ENGINE AS REQUIRED ORDER FROM E

OPS PAGE 2 E

E Q

CLEAN CYLINDERTEST VALVESEATS Q

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ADJUST INJECTOR TIMING E

E E

E E

Q EXHAVSTVALVETMNGCHECK~

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PISTON TO HEAD CLEARANCE AND PIPE AUGNMENTCHECK I

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E 0

ADJUST HYDRAUUCLASHADJUSTORS~

1900 FRI 11f7 REDUNDANT START TEST 1A DG OPSIEM ENGINE POST MAINT.

0 TESTING

~WARMENGINE INSPECTIONS I

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E I0- EXHAUSTSYSTEM INSPECTION I

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I 0-OVERSPEED TRIP SETTING ADJUSTMENT I

TO PAGE 1 OPERABIUTY E

Sl PAGE 3 OF 3

0

ENCLOSURE 1 ATTACHMENT3 DRAFT SCHEDULE - COMBINED2-YEAR/12-YEAREDG INSPECTION

0

IESEL GENERATOR OUTAG 12 YR MECH INSP Wl 2 YR CT ENTER 7 DAY LCO 1A DSL.

GEN.

PERABLE EVENING SHIFT SUN 11/2 0

0 0100 SAT 11/8 g

TAG PUT g

970726800 - 12 YEAR MECHANICAL1A DG 1A DG

~ MECHANICALPREVENTATIVEMAINTENANCE~

OPER SI ~

BY0700 ~

AND2 YEAR ELECTRICALINSPECTIONS MON MM OPS/CHEM 11/3 I

SEE PAGE 2 6HR I

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I CORRECTIVE MAINT.AND I

ASSOCIATED PMS THATREQUIRE D/G OOS PREUMINARY (SEE NOTES BELOW)

MODIFY HOLD ORDER OPS Qom PERFORM C

TESTING PER SIP.9A1.d(A)

SEE PAGES 384 0

REDUNDANT OPS/EM SEE PAGE 4 NOTE:

PMTFOR STARTER CHANGEOUT 1900 SUN 11/9 04'.9A.1.a(A)

I 1A DG OPERABILITY Sl DOCUMENTATION REVIEW OPS 0100 MON 11/10 PAGE 1 OF 4 8/15/97 1APAGE1.WFL

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ENCLOSURE 2

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 2 AND 3 PROPOSED TECHNICAL SPECIFICATION (TS)

CHANGE TS-376 AND TS-391T DESCRIPTION AND EVALUATION OF THE PROPOSED SUPPLEMENTAL CHANGES DESCRIPTION OF THE PROPOSED CHANGE TVA has previously submitted two TS amendment requests to extend the current 7-day Emergency Diesel Generator (EDG)

Allowed Outage Time (AOT) specified in TS 3.9.B to 14 days.

TS-376 was submitted on March 12,

1997, and requested a

TS change to permanently extend the EDG AOT to accommodate vendor recommended preventive maintenance (PM) outages and for unexpected major corrective maintenance outages.

Since, however, NRC indicated that the review of TS-376 would not be completed prior to the start of the pending 12-year mechanical PM outages for the eight,

EDGs, TVA later submitted a request for a one-'time temporary change (TS-

391T, June 19, 1997) of the 7-day AOT in TS 3.9.B to 14 days for the express purpose of completing the 12-year inspection outages for each EDG.

To address an NRC concern regarding the applicability of the proposed extended EDG AOT to TS 3.9.D.1, the following supplemental changes are proposed.

1.

TS-376, Current TS pages 3.9/4.9-15a (Unit 2) and 3.9/4.9-14a (Unit 3).

2.

In paragraph 3.9.D.1, the following text is inserted as shown on the mark-up pages in Enclosure 3.

The word processed revision pages are in Enclosure 4.

When the aligned diesel generator is inoperable on a

unit that is not in cold shutdown, refueling, or

defueled, then TS 1.C.2 applies for the purposes of operability determinations for the above affected equipment.

TS-391T, Current TS pages 3.9/4.9-15a (Unit 2) and 3.9/4.9-14a (Unit 3).

In paragraph 3.9.D.1, the following text is inserted as shown on the mark-up pages in Enclosure 5.

The word processed revision pages are in Enclosure 6.

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[Temporary Change:

When the aligned diesel generator is inoperable on a unit that is not in cold shutdown, refueling, or defueled, then TS 1.C.2 applies for the purposes of operability determinations for the above affected equipment.

This change is valid during the time period from January 1,

1998, to February 1,

1999].

REASONS FOR THE PROPOSED SUPPLEMENTAL CHANGE In TS-391T, TVA stated that, in regard to TS 3.9.D.1 (Diesel Generators Required For Units 1, 2,

and 3 Shared Systems),

for the circumstances when an EDG was temporarily inoperable on an operating unit, TS 1.C.2 was applicable for the purposes of operability considerations for the shared equipment in accordance with routine TS application.

Therefore, the base AOT for inoperable EDGs as specified in TS 3.9.B was governing in direct accordance with TS 1.C.2.

Thus, the requested 14-day AOT in the proposed revision to TS 3.9.B could be directly applied to the shared systems listed in TS 3.9.D.l.

Hence, TVA concluded no additional TS changes beyond those requested in TS-391T were necessary to apply the requested extended 14-day AOT for the shared systems listed in TS 3.9.D.1.

During the NRC review of TS-391T and in follow-up discussions with NRC staff on TS-391T, NRC indicated that the existing wording in TS 3.9.D.1 was not entirely clear in supporting TVA's application of 1.C.2 with regard to proposed extended EDG AOT for the shared system EDGs.

The NRC concern was formally transmitted in a Request For Additional Information (RAI) dated July 17, 1997.

To address the issue, TVA agreed to clarify TS 3.9.D.1 to explicitly reference TS 1.C.2 for temporarily inoperable shared system EDGs on operating units.

Therefore, we have enclosed a supplemental change to TS-391T to ensure a

clear and common understanding of the appropriate application of TS 3.9.D.l for an extended EDG AOT.

Since the same concern would apply to TS-376, the same supplemental change is being proposed.

SAFETY ANALYSIS In 1990, during preparations for the restart of Unit 2 from a long recovery outage, BFN Units 2 and Unit 3 TS were evaluated with regard to Unit 3 systems needed to support the operation of Unit 2.

At the time, Unit 3 was also in a recovery outage and not scheduled to restart for 3-4 years.

The evaluation included the Unit 3 EDGs since EDGs 3B, 3C, and 3D are the normal or alternate emergency onsite power sources for redundant trains of the shared ventilation systems (Standby Gas Treatment System (SBGT) and Control Room Ventilation System (CREVs)).

For the situation when the units were operating, existing TS 1.C.2 provided an allowance that, if a device was determined to be inoperable solely because its onsite emergency power (EDG) source was inoperable, then the affected systems could be considered operable for the purposes of satisfying respective system Limiting Conditions of Operation (LCOs) provided that normal power sources and redundant system components were available.'S 1.C.2 further states that for this circumstance, the EDG AOT limit would apply, not the individual requirements associated with the LCOs for the individual systems.

In practice, this means that if a particular EDG is temporarily inoperable, the supported equipment (for example, supported components of Residual Heat Removal

System, Core Spray System, Standby Liquid Control, etc.)

are not required to be immediately considered inoperable as would otherwise be required by the TS operability clause, 1.E.

By definition, TS 1.C.2 is self-excluded from use for units in cold shutdown, and at the time, Unit 3 was scheduled to remain shutdown for a protracted period.

The existing individual units'S were determined to be not entirely clear in specifying what LCOs were appropriate for an operating unit for an inoperable EDG on a unit that was shutdown.

Hence, it was determined there was a need for a specific TS for the Unit 3 EDGs supporting the shared ventilation systems.

Accordingly, TS-283 was prepared and submitted on July 13,

1990, and subsequently approved by NRC on January 9,

1991.

TS-283 added Section 3.9.D and provided 30-day LCOs for the aligned Unit 3 EDGs that supplied emergency power for the shared components provided that redundant components were in service.

If an inoperable Unit 3 EDG was not returned to service within 30

days, then the new TS 3.9.D.3 required the affected SBGT or CREV subsystem be declared inoperable and the.system specific LCO entered.

A copy of the original version of 3.9.D is attached for reference in Enclosure 7.

Note that the original version of 3.9.D specifically was written for Unit 2 operating and Unit 3 shutdown.

Prior to the return of Unit 3 to service, it was necessary to modify TS 3.9.D since it had been written for Unit 3 in a shutdown condition.

This was accomplished by TS-304 which was submitted on January 10,

1992, and approved by NRC on March 9, 1994.

In TS-304, 3.9.D was expanded to incorporate the above 30-day provision for shared systems E2-3

inoperable EDGs on any units that were shutdown.

For units that were operating, 1;C.2 was still considered applicable as discussed above and in TS-304.

The primary objective of TS-283 and TS-304 was to provide provisions for specifying operability requirements for shared system EDGs-on units in a shutdown status since this configuration was not specifically addressed in the individual units'S.

There was no intent or objective associated with either TS change to alter the standard application of TS 1.C.2 for inoperable EDGs on units that were operating with regard to determining system level operability, or to invoke a direct entry into system level LCOs for the shared systems.

Direct entry into a system level LCOs soley because of an inoperable EDGs would be atypical with the general application of BFN TS for units in operation.

No hardware

changes, system technical requirement

changes, or other analyses changes were involved in either TS change as is clearly delineated in the TS-283 and TS-304 submittals.

In summary, when the units are operating, the application of TS 1.C.2 is appropriate for operability considerations for inoperable EDGs for the shared system components in the same manner as applied to other devices powered by the EDGs.

Specifically, the AOT for the EDG is governing and supported systems are not considered immediately inoperable solely due to the temporary unavailability of an EDG power supply.

This application is consistent with the docketed objectives and bases for TS-283 and TS-304.

Therefore, it is not necessary to modify TS 3.9.D.1 to specifically reference the proposed 14 day EDG AOT since the revised 3.9.B AOT will be applied.

For inoperable EDGs on units in

shutdown, the current 30-day LCO continues to be applicable in accordance with existing TS 3.9.D.2.

To address NRC's RAI concern and to eliminate any possible confusion in the wording or applicability of the TS, TVA previously verbally agreed to directly reference TS 1.C.2 in TS 3.9.D.1.

This change is considered administrative since it is TVA's objective to more clearly delineate the customary application of 1.C.2 for inoperable EDGs on operating units, and does not involve technical changes or other changes in system operational modes or limitations.

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The no significant hazards determination provided in TS-376 and TS-391T are not affected by the supplemental changes and do not require revision.

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V.

ENVIRONMENTAL IMPACT CONSIDERATION

~ The proposed supplemental changes do not involve a significant hazards consideration, a significant change in the types of.or significant increase in the amounts of any effluents that may be released off-site, or a significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of the proposed changes is not required.

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