ML18040A005
| 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 t
the work scope or in work performance.
Attachment 2 is a draft 12-year inspection schedule for EDG 1A.
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. 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 diesel generator 3D is inoperable, because it provides specific if 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 3A DSL.
7 DAY GEN.
LCO OPERABLE 0300 0100 0700 1530 1730 SFT1 FRI 0300 1200 WED MON MON MON TUE WED FRI 12/13 12/9 12/9 12/11 12/11 12/13 12/9 12/10
~ ~ 'EE 12/12 I
TAG OUT 3A DG BY0300 MON
~
I BEGIN DRAIN DOWNOF OIL/WATER 0700 DG INSTRUMENTATION CALS laC I
1 MpDIFY HOLD ORDER OPS
~ PAGE RETURN Tp SERVICE SEQUENCE I
I I
~IX.9%1 a(3A)
OPERABILITY Sl I
I NOTE: OPS NbTIFY SEE DETAILS SEE NOTE I 1 I ON PAGE 3 3 (BELOW) I I MMAS SOON'AS TAGGING COI4PLETE I I I I Sp MM CAN BEGIN I g I I I PRELMNARY WATER DRAI(4 I I I I DOWN WDSL.GEN.2YEARINSPECTION PM / MM SEE DETAILS ON PAGE 2 I I I I I I I I WORK PACKAGES / ~CORRECTIVE MAINT.AND ASSOCIATED I I I PMS/SEE DETAILS PAGE 2,3,4, 5
~ W34697A TESTING 7 SSI<9A.1 e(3A)
TAGGING I I W34697A FRIDAY 12/6 0300 MON ISSUE 83 RTO CLOSURE'LT. T.S.,
S. E.-4 HRS I
MAINT.
ACCEPT
~ OPS I
12/9 1200 MODS-2 HR I
~~
g MODS 4IHR I T39684 - PREP. T39684- i MpN I CABINETS FOR WELDING MODS -8 HR ANCHOR Q PANELS - g MODS 9 HRS MODS-2HR MODS HR SI-4.9A.1.d - DSL. GEN. ELECTRICAL INSPECTION Sl / EM RTp CLpSURE i S, E, 4 HRS ggJ ~ ~NT PLT.ACCEPT
~ T.S, OPS
~
SEE DETAILS ON PAGE 5 PAGE 1PF5 7/27/97 3AB11296.WFL
0 3A DIESEL GENERATO UTAGE - MM DETAILS 960858200 960858200 0300 0700 REMOVE SFT3 960858200 SFT3 COOLER SFT1 SFT2 1530 1730 MON MON COOLER MON EDDY CURRENT TUE REPAIR/ WED WED WED WED A TAG 12/9 12/9 HEADS/ 12/9 ANALYSIS 12/10 TUBE 12/11 9608582OO 12/11 12/11 12/11 OUT CLEAN OF DG COOLERS PLUGGING REPL 3A DG COOLERS EDDY CURRENT AS RECD COOLER MODIFY BY 0300 HOLD TO MON 3 PAGE ORDERS 12/9 OPS 5 OPS SFT 2 I I I 12/10 I I I I I I I 9607332-26,27,28,36 I INSPECT EECW CHECK VALVES I Sh3.2.4 I MM-16 HRS I I DG CKV FLOW I I TEST I
I I8C I SEE PAGE 3 I
I 961234400 I
I I
I C354515- LOW I OIL LEVEL I
961234400 I REL'O I
DRAIN DOWN WATER AS REQ'D MM 1
961234400- 2 YEAR MECH. MAINT.PM-ITEMS MAYBE PERFORMED OUT OF SEQUENCE TO FACIUTATE FLOW OF WORK. PERFORM ITEMS THAT WILLALLOWOIL AND COOLANT TO BE ADDED BACK TO DSL. GEN. & ~ ooo'urn REQUIRED ON LUBE OIL CIRC PMP MVI 961234400-2 YEAR MECH. MAINT.PM-ITEMS MAYBE PERFORMED OUT OF SEQUENCE TO FACIUTATE FLOW OF WORK. I I I I I NOTE: OPS TO I C323106- INSPECT FOR WELD CRACKS I HAVE DG TAGGED I ON FUEL UNE LINKAGESUPPORTS 5 BY 0300. THIS IS I - MVI- 4 HR (M!NOR MAINT) I I
TO ALLOWMM I TO START I DRAINING DOWN I 96414937400- WOODWARD GOV. OIL LEVEL HIGH - MM 4 HR 3 I
WATER. I I
I I 96012346400-COMPRESSOR PIVWAVI8 HRS I
I I
I I
I 964)1235440(hCOMPRESSOR PM4I HRS (hM)
I I
I I
964139654)00-DG LUBE OIL SAMPLE-(MVI)4 HRS 3 I I
I I I I I I 951372600- CLEAN MOISTURE SEPERATOR/ I I INSPECT CHECK VALVES - MM-8 HRS I
I 960706300- INSPECT / REPLACE DSL GEN AIR HOSES - MM20HR PMT LEGEND PMT~
NOTE: SEE PAGE 3 (CHEMISTRY 1. 3SIP.9A.1+,(3A) DG OPER. Sl, AND NO EXTERNAL LEAKAGE DETAILS.) FOR REQUIRED MM 2. MPI4482-INS002-INSPECTIONS/CHECKS PRESTART AND WITH DG SUPPORT. RUNNINGJ~h4 o/A.1 a(3A)4A DG OPER Sl
- 3. VERIFY NO EXTERNAL LEAKAGEAT SYSTEM PRESSURE/MM
- 4. 'NOT DETERMNED AT THIS FRAGNET REVISION. PAGE
- 5. NONE REQ'D 2OF5 7/27/97 3AB21296.WFL
3A DIESEL GENERAT OUTAGE - 18C DETAILS 0300 1200 REQUIRES DG MON ~~N NOTE COMPLETION OF INSTRUMENT GALS AND RELEASE OF HOLD ORDER BY Id C IS PREDECESSOR TO BEGINNING OF TIME DELAYRELAYS BY EM (SEE PAGE 5). COMPLETE TUE EECW SYS.
12/9 12/10 THU 12/12 TAG OUT GALS BY 1200 TUESDAY RESSURIZED AIR/ I SI-3.2.4 BLEED CAUBRATE PRESSURE SWITCHES AND INDICATORS DG 3A EECW DOWN ON DSL. GEN. STARTING AIR SYSTEM CHECK VALVE PI46401 PI46402 PI46-727 PI46-762 PS46401 PS46401 I FLOW TEST PI46-728 PI46-763 I PS46402 PS86402 PI4864729, PI4864764 9607332-26, -27 I I I I SEE MM DETAIL I I I I PAGE FOR
-28,36 I I I I I I I PREDECESSOR TO I
I I PERFORM OF THIS TAG OUT SI. WHICH SERVES FUEL OII. DRAIN DOWN AS PMT AND WATER CAUBRATE PRESSURE SWITCHES AND INDICATORS LUBE OIL SYSTEM ON DSL. GEN. FUEL OIL AND LUBE OIL SYSTEMS SYS. I MM I OPS g I -1 68-. 1 -1 6-1 l42-1 S42-12 P -1848 DSL . GEN. INST. CAL. WO'S I I PS-18-69 PS42-13 I I I 951962700 I I D
I I I
~" ~
I I I INSTALLPS42-15 961219500 TAG OUT REMOVE PS42-15 DSL. GEN (CRANKCASE PS) CAUBRATE PS42-15 (CRANKCASE PS)
A)PS QA REQ'D 961219700 I
DRAIN DOWN I 961219800 COOLING CAUBRATE PRESSURE SWITCHES AND INDICATOR.
TAG OUT SYSTEM ON DSL. GEN. COOLING AND LUBE OIL SYSTEMS.
WATER AND MM 961219900 LUBE OIL PS424 PS-824 PS42-10 SYSTEMS I 961220000 OPS REMOVE INSTALL 961220100 CAUBRATE TEMP. SWS TEMP. SWS. TEMP. SWS.
QA REQ'D.
I 961220200 I
I I I TS42-2 TS42-7 TS42-9 I 961220300 I I I I I I 961220400 I I I I INSTALL REMOVE CALIBRATE DSL. GEN. CORRECTIVE MAINT TEMP. TEMP. INDICATORS.
INDICATORS 951048300- 3-PI424004A 1 PMT LEGEND PMT~ TI42-1 TI424 TI42-18 TI42-16
- 1. -VERIFY CAL 3A DIESEL GENERATOR OUTAGE- CHEMISTRY DETAILS 10 YEAR CLEANING OF DSL GEN. 7-DAY FUEL OIL TANKS (REQUIED BY REG. GUIDE 1.137)
SFT1 1200 WED MON 96413896400 12/11 96413896400 12/9 96413896400 96413896400 INSPECT TANK 044 TANKRERLL BY 0700 PUMP FUEL OIL OUT OF 7-DAY FOR CLEANINESS r UMP FUEL OIL PREDECESSOR TANKTO STG TANK J TAG OUT PUMP/VENT/CLEAN 7-DAY TANK- 20 HR PER TI-94, PLUS TO DAY TANK FUEL OIL VALVES FTM OTHER BACK INTO PAGE 5 SYSTEM LEVEL SW CAL OPSY HR INSPECTIONS BY EM CHEM- 4 HRS OPS- 6 HRS 96413896400 NOTE: MM REMOVE / REPlACE HATCHES - WO - 96013896400 PAGE 3OF5 REMOVE FLR COVER UNBOLT
~
12 OF 16 TANKCOVER BOLTS 1. (1) 4QUEGEE TANK,. REMOVE SEDIMENT/SLUDGE. NaOCL WIPEDOWN.
(DO NOT BREAK TANKSEAI.) 2. CONRNED ENTRY PERMIT- CHEMISTRYTO INITIATE MM 3. FIRE PROTECTION REVIEW (OBTAIN PERMITS AS REQUIRED) - CHEMISTRY 3AB31296.WFL
- 4. FME ISSUES (CHEMISTRYTO EVAlUATE/ASSURE THIS ISS(/E ADDRESSED) 7/27/97
3A DIESEL GENERATOR OU E - BATTERY DISCHARGE
. DSL. GEN. 3A TO BE TAGGED OUT 3A DSL. GEN. OUT OF SERVICE BY 0300 A SFT 2 FT2 SFT 2 FT1 SFT 1 MON SFT 3 THU THU MON MON 12/9 MON 12/5 12/5 12/9 12/9 12/9 3$ 14.9A2.CN 3$ IP.9A2.b3 0l00 VERIFYI PLACE PERFORM s
3$ &c/A2.Cg) 3$ I4.9A2.Cg)-DG BATTERY PERFORMELECTRICAL FLOAT QUARTER Sl LINEUP PERSI DISCHARGE Sl B CHARGE ON BATTERY I OPS-1HR EM/ OPS-SHR EM-4 HR BATTERYMUST BE ON FLOAT CHARGE AT LEAST 3 DAYS MUST BE PERFORMED WITHIN24 HRS OF BATTERY DG BATT.
PRIOR TO DG BATTERY INOP DISCHARGE DISCHARGE 96413626400 CAL. BATTERY CHARGER METERS TPS-8HR PRECAUTIONS I UMITATIONSI PREREQS.
PER: 3$ l<9A2.Cg) . DSL. GEN.
BATTERY DISCHARGE Sl- SECTION 3.0 8 4.0, EM/OPS 3A DG OUT OF SERVICE NOTE: ELECTRICAL UNEUP PER 3$ I-4cIA2.Cg) 3$ I4.9A2.Cg) WILL COMPLETE NOT BE COMPLETE UNTIL DSL. GEN.
SFT 3 SFT 3 HOLDORDER MON TUE RELEASED 12/9 12/10 (e.g., CLOSE LOGIC BKR.)
3$ 14.9A2.GIB 3$ IP.9A2.b$ 3$ I49A2.C/0 PERFORM 24 HOUR PERFORM RETURN BATTERY EQUAUZING QUARTERLY Sl TO SERVICE / LOADS B
CHARGE OF BATTERY ON BATTERY TO NORMAL EM-24HR EM-4 HR CONFIGURATION EMI OPS -1 HR 3$ IA.9A2.C/lj NOTE: PLACE DG BATTERY ON 24 HR VERIFY BATTERY EQUALIZINGCHARGE. COMPLETION CAPACITY EQUAL TO SUCCESSFUL COMPLETION OF OF 24 HR CHARGE IS N577KGOIRED OR MORE THAN 3$ IRBA2.b$ (QUARTERLYSl) 80% OF RATED AND VERIFICATIONOF TO SIGN OFF Sl. OR TO PLACE DSL.
CAPACITY BATTERY CAPACITY > 80% GEN IN SERVICE EM REQUIRED TO DEClARE BATTERY OPERABLE.
SFT 2 MON 12/9 961362500 CALGROUND METERS TPS-8HR PAGE NOTE: THIS IS ONLYA
SUMMARY
OFDG 4 OF 5 BATT. DISCHARGE Sl. - ALLSTEPS OF Sl ARE NOT SHOWN.
7/27/97 3AB41296.WFL
A DIE EL ENER R UTA E EM C 0700 MON 1530 12/9 WED 12/11 I SIR.9A1.D-TIME DELAYRELAYCHECKS. DG ELECT. INSPECTIONS, TAG OUT 3A DSL. GEN. FUEL OIL PUMP MOTOR INSP., LOAD BKR. CLOSING SPRING BY 0300 MON 12/9 CHARGING TIME TEST. MEGGER LUBE OIL CIRC. PUMP MTR. A OPS I- SI49A1.d - CAL DG TACH. AND INSPECT PROTECTIVE RELAYS - TPS -8 HR.
I I 96-05716400 18 MO CAL OF 3A D/G EXH I FANS A 8 B TDDO RELAYS-EM (8 HRS)
I I 96414995400-REPAIR VOLTMETER I TPS4 HRS 5 I
rI g ~
-~ 96419063400-PM ON D/G OUTPUT BKR 9&014994@00 REPAIR BKR COhhP EM4 HRS I SFT 1 WED 12/11 SFT 2 WED 12/11 960571500 I CAL TRANSFER PUMP 961141905- REPL OVERSPEED LEVELSWITCHES EM 12 HR LIMITSWITCH - EM 8 HR I
I I
r---- 96415096400 -RELAYREPLACEMENT- EM - 16 HR 4 I
960722704,
-INSPECT GOV. EG-A CONTROL 1 BOXES-EM 4HR RETURN TO SERVICE / TESTING SE UENCE S I4.9A.1.d 961234400 1730 961243100 SFT3 SI-4.9%.1.d SIN.9A.1.d THU SFT1 WED SIR.9A,1.d FRI 12/11 12/12 12/12 961509600 34IA.94.1.a(3A) 12/13
~~
GOV. VOLT SPEED PROTECTIVE
'TART I
IMMERSION HEATER CHECK EM 1HR SI<.9A.1.d 1
TPS 1/2 HR RElAY CHECK EM/
TPS 11/2HR r
rr CONTROl. 8 OVERSPEED TRIP TEST EM/OPS MM HOT RACK 3HR
~~ TEST ERIC OPS 6HR
~~ ~~ DG OPER Sl OPS/CHEM.
4HR SSS/OPS CLOSURE SIGNOFFS ALARMCHECKS MANUALLYROLL 44 HR 3A
-EM/OPS - 10 HR 3A DSL GEN IN DG PREP FOR RUN OPER OPS-1 HR W34697A-NM PERFORM 96413896400CE T INST. CHECK UST AT 96412203400-IM T3 968 4-NM T OPS REQUEST 96413625400-TPS IM-1 HR IMMEDIATEATTENTION I EMERGEN 964073324264Th T 95419627000-IM T ALL CRAFTS TO BE OFF DG HOLD ORDERS AT WORK THIS POINT, 9640733242Wm T 96412197400-IM T 964123544004tlM EXCEPT FOR EM.
C3231 064%I 964073324284M T 96415096400-EM T WILLNOT 96413625400-TPS HAVE TO CLOSE 9641396540041M 9640733243um T 954137264004th T PMT LEGEND PMT 96412202400-IM
- 1. PMT NOT REQUIR 96405715400-EM T 96412199400-IM T 96412198400 IM
- 2. VEFIFY FAN OPERATION 96412204-000-IM
- 3. SUCCESSFUL CAL T 96408582400MM T
- 4. REDUDANT START/34I498.1x(3A) I 96407227404-EM
- 5. OVERSPEED TRIP TEST AND ALARMPER 96414995400-TPS 3$ IA.9A.1.d(3A)
(3414.9A.1.d(3A) (3A DG 2 YR ELEC INSP) 3A DG 2 YR T 964123464004M 964123 444004IM T INSP. - EM 95419063400-EM 96411419405-EM 954104834004/I O '6412198400-9/I 34'.9A2.C(l) 96412195400-IM '6412201400-IM PAGE 3AB5129 6.WFL 7/29/97 5OF5 BATT. DISCH. 96405716400-EM 96412200400-IM
ENCLOSURE 1 ATTACHMENT2 DRAFT SCHEDULE FOR 12-YEAR EDG INSPECTION
1 IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE N ENTER 1A DSL.
7 DAY GEN.
LCO PERABLE EVENING 0500 0700 1700 1300 MON MON 0500 SAT SHIFT FRI SUN 11/2 11/3 11/3 11/8 11/7 04IA9A1a(A) 1A DG TAG OUT 970726800 - 12 YEAR MECHANICAL1A DG 04IC.9A.1.a(A) 1B DSL GEN OPER. SI OPS/CHEM O
I MEC~ICALPREVENTA~ ~NTE~C SEE PAGE 2 I
MODIFY HOLD ORDER OPS
-C .':.;
SEE PAGE 3 c6 OPERABIUTY Sl DOCUMENTATION REVIEW 6HR I OPS I I I I NOTE:
CORRECTIVE MAINT.AND ASSOCIATED PMTFOR PMS STARTER PRELIMINARY CHANGEOUT (SEE NOTES BELOW)
PAGE 1 OF 3 8/15/97 1A121197.WFL
IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE ON TAG OUT
~~REMOVEDUCT lADO q~) POWER ASSEMBLY REMOVAUREISNTALlATION:GASKET, SEALS, LOWER LINER SEALS REPLACEMENT, SEAT RING INSPECTION, FUEL INJECTOR QUAUFICATION. ~)Q DUCTWORK-~
MMIEM COOLING) TO I
E DRAIN ENGINE OIL FOR CHANGE INSPECT ENGINE I
I I
p REPlACE
~ PAGE 3 Q ENGINE INTERNALS CLEAN THE LUBE OIL STRAINER BOX, STAINER, AND FLEXIBLESEALS REPLACEMENT MAIN OIL FILTER ELEMENT REPLACEMENT 0 ,"': 0 OIL AUX.TURBO OIL FLT. ELEMENT REPLACEMENT TURBO CHARGER OL FILTER ELEMENT REPlACEMENT LUBE OIL CIRC. SYSTEM INSPECTION CLEAN LUBE OIL SEPERATOR AND EJECTOR OIL BATH AIR FILTER INSPECTION LUBE OIL CIRC PUMP AND FLEXIBLESEALS REPL LUBE OIL FILTER BYPASS VALVEREPLACEMENT AIR START CHECK VALVEREPLACEMENT AIR START RELAYVALVEREPlACEMENT AIR START VALVEREPlACEMENT AIR START MOTOR SERVICING AIR START MOTOR REPLACEMENT AIR BOX DRAIN LINE CHECK SET FUEL INJECTOR RACKS FUEL TRANSFER STRAINERS INSPECTION FUEL TRANSFER FILTER ELEMENTS REPLACEMENT E I
I FUEL PUMP SUCTIION STRAINER INSPECTION I I
I ENGINE FUEL FILTER REPlACEMENT E I
E ENGINE DRIVEN FUEL PUMP REPlACEMENT I I
MOTOR DRIVEN FUEL PUMP REPLACEMENT E I
WATER PUMP AND COOUNG SYS. I FLEXIBLESEALS REPL E I
ENGINE VIBRATIONDAMPER INSPECTION I E
E E
E I
SERVICE ENGINE GOVERNOR PERIODIC TIGHTNESS CHECK TOP DECK COVER SEAL REPLACEMENT PAGE 2 OF 3
1 IESEL GENERATOR OUTAG 12 YR MECHANICALINSPE N 1700 1900 FRI FRI 11/7 11f7 0 ENGINE PRELUBRICATION OQ BAR ENGINE AS REQUIRED E
MODIFY HOLD ORDER OPS REDUNDANT START TEST 1A DG OPSIEM FROM I TO PAGE 2 E E PAGE 1 Q CLEAN CYLINDER TEST VALVESEATS Q OPERABIUTY
~
E Sl I
E ADJUST INJECTOR TIMING I
E 0 ENGINE POST MAINT.
TESTING
~WARM I
ENGINE INSPECTIONS I
E E I
E E I
E I
Q EXHAVSTVALVETMNGCHECK E I
E E
PISTON TO HEAD CLEARANCE E
E 0-I EXHAUST SYSTEM INSPECTION I
AND PIPE AUGNMENTCHECK
~
I I I I I I I E E 0 ADJUST HYDRAUUC LASH ADJUSTORS 0- OVERSPEED TRIP SETTING ADJUSTMENT PAGE 3 OF 3
0 ENCLOSURE 1 ATTACHMENT3 DRAFT SCHEDULE - COMBINED 2-YEAR/12-YEAR EDG INSPECTION
0 IESEL GENERATOR OUTAG 12 YR MECH INSP Wl 2 YR CT ENTER 7 DAY 1A DSL.
LCO GEN.
PERABLE EVENING SHIFT SUN 11/2 0 g TAG PUT 0~
g 970726800 - 12 YEAR MECHANICAL1A DG 0100 SAT 11/8 MODIFY Qom PERFORM 0 REDUNDANT 1900 SUN 11/9 I
04'.9A.1.a(A) 1A DG 0100 MON 11/10
~
TESTING OPER SI OPS/CHEM 1A DG BY 0700 MON 11/3
~I MECHANICALPREVENTATIVE MAINTENANCE~
AND 2 YEAR ELECTRICAL INSPECTIONS MM SEE PAGE 2 HOLD ORDER OPS C PER SIP.9A1.d(A)
SEE PAGES 384 OPS/EM SEE PAGE 4 OPERABILITY Sl DOCUMENTATION REVIEW 6HR I OPS I I I I NOTE:
I CORRECTIVE MAINT.AND PMTFOR I ASSOCIATED PMS STARTER THAT REQUIRE D/G OOS CHANGEOUT PREUMINARY (SEE NOTES BELOW)
PAGE 1 OF 4 8/15/97 1APAGE1.WFL
0 ESEL GENERATOR OUTAG 2 YR MECH. INSP. Wl 2 YR CT Q
TAG OUT OPS
~~
~Q REMOVE DUCT WORK -
MM/EM ~~ ~POWER
~RING ASSEMBLY REMOVAUREINSTALlATION:GASKET, SEALS, LOWER LINER SEALS REPlACEMENT,SEAT INSPECTION, FUEL INJECTOR QUAUFICATION.
~t REPLACE DUCT WORK-MMIEM TO DRAIN PAGE 3 ENGINE REPLACE s, OIL FOR ENGINE OIL A
CHANGE INSPECT I ENGINE I I I
INTERNALS CLEAN THE LUBE OIL STRAINER BOX, STAINER, AND FLEXIBLESEALS REPlACEMENT MAIN OIL FILTER ELEMENT REPLACEMENT
-0 I g I I g I I AUX. TURBO OIL FLT. ELEMENT REPlACEMENT CAUBRATE PRESSURE SWITCHES TURBO CHARGER OL FILTER ELEMENT REPLACEMENT 0- II INDICATORS ON AIR START SYSTEM (1 2 TOTAL)
OIL LUBE OIL CIRC. SYSTEM INSPECTION CALIBRATEPRESSURE SWITCHES 4 INDICATORS ON FUEL OIL
'AGE 3 CLEAN LUBE OIL SEPERATOR AND EJECTOR 8 LUBE OIL SYSTEMS OIL BATH AIR FILTER INSPECTION (9 TOTAl)
Q=REPIACE CRANKCASE4 LUBE OIL CIRC PUMP AND FLEXIBLE SEALS REPL REMOVE CAUBRATE 0 LUBE OIL FILTER BYPASS VALVEREPlACEMENT I
PRESSURE SWITCH 0- CAUBRATE PRESSURE SWITCHES Q
Q AIR START CHECK VALVEREPLACEMENT AIR START RELAYVALVEREPlACEMENT 0
4 INDICATOR ON COOLING SYSTEM CAUBRATE TEMPERATURE SWITCHES AND INDICATORS (7 TOTAL)
Q=AIRSTART VALVEREPlACEMENT AIR START MOTOR SERVICING AIR START MOTOR REPlACEMENT AIR BOX DRA!N UNE CHECK SET FUEL INJECTOR RACKS FUEL TRANSFER STRAINERS INSPECTION Q FUEL TRANSFER FILTER ELEMENTS REPlACEMENT FUEL PUMP SUCTIION STRAINER INSPECTION Q
ENGINE FUEL FILTER REPlACEMENT Q
ENGINE DRIVEN FUEL PUMP REPlACEMENT MOTOR DRIVEN FUEL PUMP REPLACEMENT WATER PUMP AND COOUNG SYS. PAGE FLEXIBLE SEALS REP'L 2 OF 4 Q ENGINE VIBRATIONDAMPER INSPECTION SERVICE ENGINE GOVERNOR PERIODIC TIGHTNESS CHECK TOP DECK COVER SEAL REPlACEMENT
ESE1 GENERATOR OUTAG 2 YR MECH. INSP. Wl 2 YR CT 0100 SAT
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11/8
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~ BAR ENGINE MODIFY HOI.D
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PRELUBRICATION AS REQUIRED ORDER I I OPS I FROM PAGE 2 I PAGE 4 CLEAN CYUNDER TEST I I
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ADJUST INJECTOR TIMNG I I I I I I 0
I I I I I I EXHAUST VALVE I TIMING CHECK I I
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PISTON TO HEAD CLEARANCE AND PIPE AUGNMENTCHECK ~ I I
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I I I I I I I I ADJUST HYDRAUUC LASH ADJUSTORS I I I I I I I I I I I I 1/2 SIP.9A.1.d(A)-TIME DElAYREu(Y CHECKS, DG ELECT. INSPECTIONS, FUEL OIL PUMP MOTOR INSP. LOAD BKR. CLOSING SPRING
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CHARGING TIME TEST. ME/GER LUBE OIL CIRC. PUMP MTR.
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I I I B I 1/2 SIR.9A.1.d(A) - CAL DG TACH. AND INSPECT PROTECTIVE RElAYS - TPS I
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1 IESEL GENERATOR OUTAG 2 YR MECH. INSP. Wl 2 YR- CT T/0 RACK SET GOV. VOLT IMMERSION HEATER CHECK SPEED SW CAL
~ PROTECTIVE RELAY CHECK CONTROL IL OVERSPEED TRIP HOT RACK REDUNDANT START TEST 1A DG EM EM/ EM/ TEST TPS I OPS/EM TPS EM/OPS I TO I MM PAGE 1 I OPERABIUTY I
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INSPECTIONS
-EM/OPS- 1A DSL GEN IN I I PREP FOR RUN I PAGE 3 I OPS I I I I A I I
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I I I I I I I I I OVERSPEED TRIP SETTING ADJUSTMENT PAGE 4OF4
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).
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.
- 2. 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.
0
[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, solely because if a device was determined to be inoperable 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 to modify TS 3.9.D since it 3 to service, had been it was necessary 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
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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 eligibility criteria 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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