ML18051B081
| ML18051B081 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/01/1984 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-84-15, NUDOCS 8410110054 | |
| Download: ML18051B081 (14) | |
Text
consume11 Power company General Offices: 1945 West*Parnall Road, 'Jackson, Ml 49201 *:1517) 7138-0550 October 1, 1984
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR-20 PALISADES PLANT - RESPONSE TO GENERIC LETTER 84-15 "PROPOSED STAFF ACTIONS TO IMPROVE AND MAINTAIN DIESEL GENERATOR RELIABILITY" Generic Letter 84-15 "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability" dated July 2, 1984 requests that licensees furnish certain information concerning: 1) their intended actions or current programs to avoid "cold fast start" surveillance testing of the emergency diesel generators (EDG); 2) the reliability of their emergency diesel generators; and, 3) their current programs, if any, to attain and maintain diesel generator reliability goals. Additionally, licensees were requested to comment on, and compare their existing or proposed program to an example diesel generator performance technical specification. These items are presented in detail in Attachment 1 to this letter, but major points have been summarized below.
Response to Item 1 Consumers Power Company does not subject the EDGs at the Palisades Plant to "cold fast starts". Supporting discussion is contained in the Attachment to this letter.
Response to Item 2 Surveillance test data for the last 20 and 100 tests is detailed in Attachment 1 to this letter.
Response to Item 3 The Palisades Plant maintains a proceduralized system for ensuring the reliabil-ity of the EDGs. A full discussion of the system is contained in the Attach-ment to this letter.
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. *PD.R* ADOCK 05000255 *.,-* !
OC0984-0009AA-NL02 p* ' . ..: * . **PDR *.__...
Director, NRR 2 Palisades Plant RESPONSE TO GEN LTR 84-15 October 1, 1984 Consumers Power Company does not _believe a demonstrated. need exists 'for an EDG performance technical specification such as that proposed by the NRC.' With the demonstrated high reliability of the Palisades EbGs and the current programs to .ensure maintenance of same' a requirement such as a proposed performance technical specification is not appropriate.
In response to the request in the subject Generic Letter; Consumers Power Company has compiled extensive comments on the proposed example technical specification. These are presented in* detail in the attachment to this letter, but major points are presented below.
Comment *l Consumers Power Company*strohgly opposes the treatment of emergency diesel generator (EDG) reliability as a generic issue. As noted in the subject Generic Letter, 75% of the EDGs currently in service have a reliability of
.95/demana or greater, with the median value of reliability at.operating plants being .98/demand. We do not support attempts to establish*generic reliability goal~, since acceptable reli~bili~y levels (and the ~orresponding probability of events leading to a co_re melt accident) are'. highly dependent on plant design. .The creation of a generic. 'requirement for new technical specifi..:.
cations that cover additional reliability actions, reporting requirements, and an.EDG requalification program imposes an excessive administrative burden on all licensees. This is particularly true for those licensees* with EDGs that have demonstrated high reliability and proven programs to assure maintenance of same.
The proposed technical spec'ifications appears to be an attempt to prescribe analysis, .evaluation and corrective actions than are already in the *1icensee's own best economic interest. We question the appropriateness of the promulga-tion of any requirements that are not clearly.related to safety.
- Comment 2 We have followed NRC concerns regarding EDG reliability and the associated issues of Station Blackout for some time. We concur with the Staff goal to increase EDG reliability (which should reduce the probability of.events leading to a core melt accident). We do not agree, however, with the philosophy that increased surveillance testing would motivate licensees to maintain highly reliable* EDGs. And, we cannot now concur with a r'equirement for a reliability program that l) causes unwarranted additional wear on EDGs; and, 2) statistically precludes the requalification of most EDGs.
We are committed to maintaining highly reliable EDGs. We believe that existing technical specifications limiting conditions of operation (LCO) are reason enough for licensees to maintain high reliability by strictly limiting the maximum allowable times for EDG inoperability. EDGs that fail required surveillance testing must undergo investigation, evaluation and corrective OG0984-0009AA-NL02
Director, NRR Palisades Plant RESPONSE TO GEN LTR 84-15
- 3 October 1, 1984 actions (requiring time), and then successful retesting, before being declared operable.. Therefore, licensees with unreliable EDGs may affect plant availa-bility (via LCO) by the time constraints imposed by the cor.rective action process and the additional retesting required prior to declaring the EDG operable.
Comment 3
_As now written, the requalificatio:n process that requires completing 14 consecutive tests without a failure is extremely restrictive with a very low probability of success. Usiµg a binomial di~tribution, the probability of a
.95 reliable EDG (minimum desired ret!ability) having 14 consecutive failure free demands is only 0.49 (P ~ (.95) ) .. Similarly, a .90 reliable (minimum acceptable reliability) generator would only have a 0.23 probability of 14 consecutive failure free demands. Following .the recommendations of the proposed NRC program, the total probability of successfully completing the requalifica~ion program is 0. 74 for a .95 reliable. EDG 0 and 0;41 for a .90 reliable* EDG~ Supporting detail is contained in the attachment to this letter.*
Comment 4 The introduction of new terminology in the proposed technical specification and guidelines (qualified, not qualified, not qualified for nuclear service) will only confuse the issue of equipment operability~ As now written, an EDG can be both operable .and disqualified.
Comment 5 We are concerned about the combination of reliability and operability programs in the NRG* proposal. Each provides separate and distinct determinations of safety and its impact to continued *operation. Contrary to the proposed NRC program, a reliability program should address preventative maintenance
- activities, inspections, long term correct;ive actions, and should remain separate from operability determinations.
Comment 6 We note the NRC proposal will not allow EDG testing more frequently than once
. every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during requalification. In discussion with your staff, we understand the intent of this proposed requirement is to allow the EDG time to returp to ambient conditions. This conflicts :with Item 1 of subject generic
. 11atter which is aimed at reducing the number of. "cold fast starts." Additional-ly, this requirement poses the burden of additional down time, and will force licensees to propose.significant increases in the technical specification maximum allowable. "times for inoperability.
OC0984-0009AA-NL02
Director, NRR 4 Palisades Plant RESPONSE TO GEN LTR 84-15 October 1, 1984 Consumers Power Company appreciates the opportunity to comment on the proposed requirements in Generic Letter 84-15. As can be seen, we have given this matter careful consideration and have tired to evaluate the benefits resulting from implementation of the proposed requirements objectively. We have concluded, as discussed in detail in the comments above and in the attachment to this letter, that the current technical specifications regarding EDG operability (other than fast cold start requirements) are sufficiently effective to ensure adequate EDG reliability. Any further reliability programs or guidelines should be the licensees' decision. .
Brian D Johnson Staff Licensing Engineer CC Administrator, Region HI, USNRC NRC Resident Inspector - Palisades Attachment OC0984-0009AA-NL02
CONSUMERS POWER COMPANY Palisades Plant Docket 50.;...255 - License DPR-20 REPONSE TO GENERIC LETTER 84-15 .
At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's
_Rule and Regulations thereunder, Consumers Power Company submits our response to Generic Letter 84-15 dated July 2, 1984, entitled, "Proposed Staff Actions to Improve apd Maintain Diesel Generator Reliability." Consumers Power Company's
,* .response is dated October 1-, 1984.
CONSUMERS POWER COMPANY BJ:
RB DeWitt; Vice President
~ :. Nuclear Operations Sworn and subscribed to before me this 1st day of October 1984.
- ifey, Notary u 1 c County, Michigan My commission expires November 5, 1986.
SHERRY LYNN DURFEY Notary Public, Jackson County, 'Jlic't My Commission Expire~ Nov. 5. 1985 OC0984-0009BB-~02
ATTACHMENT 1 Consumers Power Company Palisades .Plant - Docket 50-255 RESPONSE TO GENERIC LETTER 84-15 PROPOSED STAFF ACTIONS TO IMPROVE AND MAINTAIN DIESEL GENERATOR RELIABILITY October 1, t984 8 Pages OC0984-0009E~NL02
Item 1: Reduction in Number of Cold Fast Star~ Surveillance Tests for Diesel Generators Item 1 of Generic Letter 84-15 requests that licensees describe their current programs to avoid cold fast start surveillance testing or their intended actions to reduce cold fast start surveillance testing for their diesel generators.
Response
The emergency diesel generators at Palisades are not subjected to cold fast starts. Both diesel generators are equipped with lubrication oil and jacket water heaters that maintain the lubrication oil and jacket water at elevated standby temperatures. In addition, a pre-lubrication pump is employed to keep the lubrication oil circulating when the diesel is in standby. These standby conditions, which are manufacturer's recommendat*ions, prevent the cold fast starts which may cause premature engine failure. (It should be noted that the Palisades technical specifications do not require fast starts from ambient conditions. Nonµally, fast starts are made from the standby condition only.)
Item 2: Diesel Generator Reliability Data Item 2 of Generic Letter 84-15 requests that licensees furnish reliability data (based on surveillance tests) for each diesel generator at their plant for its last 20 and 100 demands, indic_ate whether they maintain a record of diesel generato~ demands and failures in accordance with Reg Guide 1.108 position C.3.a, and whether a yearly data report is maintained for each diesel generator's reliability. Our re$ponse to this request is given below.
Recognizing that operation of the Palisades Plant precedes Regulatory Guide 1.108 and its criteria, our definitions of successful .star.ts, valid tests and failures differs from that of.Regulatory Guide 1.108. At the Palisades Plant, a failure of the EDG to perform within surveillance test limits results in the test being declared a failure, investigation, corrective actions, repairs, and*
finally retesting. A piece of equipment must successfully demonstrate its capability to function prior to being declared operable.
Testing done as part of the trouble shooting a r~pair process is not consider-ed as either a failure or success. This is in alignment with the intent of section C.2.e(7) of Reg Guide 1.108. At .the completion of maintenance or repair activities, the shift supervisor determines those portions of the Technical Specification EDG surveillance procedure that must be performed to determine equipment operability and documents it on process control sheet.
The process control sheet controls *the testing to verify operability and return the equipment to operable status. These tests are not considered valid tests, regardless of success or failure. These tests do, however, result in
- an declaration of operability.
Response
A review of*the surveillance test results for the last 20 and 100 demands (through June 1984) yields the following results.
OC0984-0009-NL02
2 EDG 1-1 20 demands *(through Jun~ 17, 1984)
During the time period from November 3, 1982 to June 17, 1984, twenty (20) surveillance tests were completedwith zero (0) failures.
100 demands (through June 17, 1984)
During the time period from April 3, 1977 to June 17, 1984, one hundred (100) surveillance tests were completed with five (5) failures to start.
The five failures occured on February 2, 1982, June 2, 1981, November 2, 1979,'0ctober 3, 1979, and January 3, 1979. Calculated reliability is
.95.
EDG 1-2 20 demands (through June 17, i984)
During the time period from September 2, 1982 to June 17, 1984, twenty (20)" surveillance tests were*completed with one (1) failure. This failure occured August 31, 1984.
100.demands (through June 17, 1984)
During the time period from May 11, 1976 to Jurie 17, 1984, one hundred (100) surveillance tests were performed with two. (2) failures. These
- failures occured cin August 31, 1983 and ~eptember 2, 1981. Calculated reliability is .98.
In addition, Enclosure 2 of Generi~ Letter 84-15 requested licensees to indicate if they .maintain a record of demands and failures per dies*!
generator according.to Regulatory Guide 1.108 position C.3.a. At this time no*
such consolidated record exists*. which provides this information.
No annual data re.port of *each diesel generator reliability is maint;ained.
Item 3 Diesel Generator Reliability Item 3 of Generic .L~tter 84-15 requests that licensees describe their diesel generator reliability improvement program for attaining and maintaining a reliability goal. Licensees are also requested to comment on and compare their .existing or any proposed program with the proposed performance specifi-cation *ittached to Enclosure 3 of the generic. letter.
Response
Consumers Power Company.recognizes the need for highly reliable EDGs and has a proven program in place to ensure continued high reliability. The following section provides a description of .the current program to ensure diesel" generator reliability at the Palisades Plant.
OC0984-0009-NL02
3 Palisades Plant Diesel Generator Reliability Program The Palisades. Plant maintains a proceduralized system for ensuring the reliabil-ity and availability of the emergency diesel generators. This system consists of:
- 1. Performance of surveillance and periodic maintenance tests and procedures to collect data.
- 2. An evaluation and review of the data gathered in those tests and procedures.
- 3. The required actions to be initiated based on the results of the
'evaluations and reviews.
- 4. A system e*ngineer from the Plant technical department who is assigned the. responsibility for mo.nitoring and evaluating the systems' perform-ance.*
Plant procedures require that all monthly surveillance tests results be reviewed by the Shift Supervisor and the shift engineer on whose shift the test is completed (both of who maintain SRO licenses), and the plant technical superintendent. The surveillance procedures contain ready reference to 1) acceptable 0 perating limits for all parameters; 2) an alert range; and, 3) a required ac~ion range.
The alert range*category was developed as an early indicator of possible diesel generator degradation. For any operating parameter that falls within the alert range, the supervisor responsible for the,perforance of the test (normally the Shift Supervisor) is responsible for generating a deviation report and consequent corrective action (maintenance orders, etc). An investi-gation into the root causes of the parameters falling within the arert range is conducted, and, based on this. ~nvestigation and evaluation, additional corrective actions are prescribed. Parameters falling in the alert range are still within acceptable operating limits and do not result in a surveillance test failure. The alert range was developed only as an indicator of possible diesel generator problems.
The* required action range indicates that the diesel generator performance is*
not acceptable. For any operating parameter falling in the r.equired action range, the equipment is declared inoperable, an event report is initiated, and the surveillance test declared a failure. The event. report requires a thorough investigation, evaluation, review by Palisades Corrective Action Review Board and subsequent corrective.actions. Operational testing following maintenance procedures on the diesel generators is performed to insure all parameters are within normal limits prior to declaring the diesel generator operable.
The periodic preventive maintenance program has been **established to insure manufa9turer's recommended tests and maintenance are performed. These recom-mended manufacturer'.s tests monitor equipment performance and insure trends and/or pot~ntial problems are identified prior to becoming a.problem. The recolnniended' oil changes and inspections are performed to prevent or identify developing problems prior to adverse operation.
OC0984-0009-NL02
4 Consumers Power Company has compiled the following comments on the "Example of Diesel Generator Performance Techt?-ical Specification" presented as "Attachment to Enclosure *3 11 of Generic .*Letter '84~15. Consumers Power Company *has reviewed and evaluated this example technical specification from two perspectives - the first being from the viewpoint of integration into the Palisades existing technical specifications which do not follow the format nor include all the level of detail in the standard technical specifications. These comments are presented in Section 1 below. Secondly, Consumers Power Company has evaluated this example technical specification from an editorial and administrative perspective as it interfac~s,with the standard technical specifications.
These comments are presented in Section 2 below. Where applicable, comments
- have been structured in the same format and order as that of the Generic Letter.
Section 1 Comments on Integration or Applicability of Attachment to Enclosure 3 "Example of Diesel Generator Performance Technical Specification" for the Palisades Nuclear Plant As stated in our general comments above, Consumers Power Company does not concur with staff actiqns to establish generic EDG reliability goals and requirements. The Palisades plant has highly reliable EDGs and programs to maintain their high reliabil-ity. Adequate incentives to maintain EDG. performance are contained in existing*LCOs.
Section 2 - Editorial and Administrative Review Comments of Attachme.nt to Enclosure 3 "Example of Diesel Generator Performance.*
Technical* Specification"
Background
- We note that NUREG-0933 states LER review demonstrates . 94/demand average reliability whereas it. iS stated here the LER review indicates the median value to be .98/demand. This would seem to indicate the need for diesel generator reliability programs is not a generic issue ~f the importance once thought.
- Reliability Program
- 1. Reliability Goals The implication in this section as well as the introductory paragraph of the cover letter to Generic Letter 84-15 is that there is significant risk
. from station blackout events at all facilities and that implementation. of reliability goals and actions with respect to diesel generators will have a substantial safety benefit. It is clear that these statements have been made generically without regard to.unique plant specific design features which have an. effect on the importance of the emergency power system. It would seem that the potential for loss of off site power sources and the impact of the loss of the facility on the local grid also play a role on the importance of the emergency power system at a given facility. The goals as presel).ted in this letter do*not accomodate unique plant and electrical distribution design featureq.
OC0984-0009-NL02
5 In addition, it is not clear what the basis is for the selection of .95 as "the minimum desired level" of reliability (or the reliability action .
levels of .95 and .90). Consumers Power Company-considers.it undesirable to establish reliability goals on isolated pieces of equipment out-of-context with the integrated plant design. This option is particularly tru.e when such goals are considered as' limiting conditions for _operation as su~gested by Table 4.8-2.
- 2. Reliability Level Remedial Actions The example states."the reliability of each diesel generator is based on the number of faiiures in the last 100 valid demands." We note that Table 4.8.1 "Diesel Generator Test Schedule" of Appendix A and Table 4.8-2 "Additional Reliability Actions" both reference the number of failures in the* last 20 valid demands, and require subsequent action based on these figures.
The Reliability Improvement Program Report that would be required if there are three (3) failures in the last 20 valid tests or s.ix (6). failures in the -last 100 tests is an intrusion of regulatory requirements into a licensee's discretionary a~eB;S. The*consequences of an .EDG having high failure rates (increas~d surveillance testing, wear, repairs, etc) are penalty enough. We question the appropriatene~s of requirements (reports) that are not.clearly related to a direct increase in safety margin.
Table. 4. 8-2* "Additional .Reliability Actl.ons" utilizes the termin~logy "Declare the diesel generator inoperable" -for failure rates of 5/20 and 11/100. We understand (in discussions w{th your staff) this to mean that.
the EDG is disqualified (and therefore subject to the.requalification program requirements of Attachment 2 to.Table 4.8-2). However, after one subsequent succ.~ssful surveillance test is performed, . the. diesel generator is considered operable for the purpose .of technical specifications LCOs.
We encourage the NRC*to more*explicitly.define the *term "disqualified" and its use. t The EDG requalificatfon. program, then, a,ppears to have no commonality with the term "operable" and' the limiting conditions for operability that are of concern to licensees.
- Indeed, we gather that the requalification program is *a "stand alone" effort to bring about improvements in the
.reliability of EDG's*without impacting the LCO's.
The* sentence. "The diesel gen_erator would remain. inoperable from the time of the last failure through the period re~uired for corrective aition and until the first subsequent valid succ.essful test is completed" should be clarified so that "the period for corrective acti?n" is not construed or interpreted as meaning the requalification program. '
- 3. Surveillance Test Frequency We are concerned about the requirement to maintain the seven-day test frequency until seven' consecutive failure free demands have been performed and the number of failures in the last 20 demands reduced to one or less, as described in the footnote to proposed Table 4.8.1 "Diesel Generator Test Schedule". From a probability standpoint, even a .95 reliable EDG OC0984-0009-NL02 ,
6 would only have a 0.70 p7obability of having seven consecutive failure free demands (P = (.95) = 0.70). Additionally, two adjacent test failures that are a resu-lt of a*common cause failure result in the need.
for 19 consecutive successful tests (to reduce the number of failures in the last 20 valid demands to one.or less) before the.surveillance test frequency would revert to a monthly basis. If analysis and/or repairs are made that eradicate the common cause failure, it seems inappropriate that 19 additional tests that further degrade the EDG be performed. The probability of a .95 reliabli EDG successfully passing these 19 consecu-tive tests is only P = (.95) 9 = 0.38 *
- 4. Remedial Action Criteria We note the use of the terminology "should" in* ...the licensee should within
.. 14 days *** " whereas the term "shal.l" is used in Attachment 1 to Table 4.8-2 "Reporting Requirements". We also note the disparity between this
- section and Attachment. 1 to Table *4. 8-2 in regard to NUREG/CR.;.0660 recom-mendations. This section describes a report which includes "~ .. the implementation of NUREG/CR-0660 recommendations'" whereas Table 4. 8-2 requires the evaluation of the recouimendations of the NUREG wi'th. respect to their applicability to the plant.
- 5. Requalificat~on Criteria Using a binominal distribution, even a .95 reliable diesel generator would
- have less than a**. 50 probability of having 14 consecutive failures free demands. Following the recommendations of Attachment 2 to Table 4.8-2:
Probability of Successfully Completing Requalification Program Diesel Reliability Diesel t~sting history .95 .90 following repair 14 consecutive success .49 .. 23 14 consecutive success .15 .12 following qne failure.
in 1st seven tests 14 consecutive success .10 .06 following one failure in 2nd seven tests Total probability .74 .41 of sucess The likelihood of having to shut the plant down following the suggested requalification progra~ is nearly 60% given a marginally reliable diesel generator (.QO) and over 25% if the diesel meets the proposed goal (.95).
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- ' ~* ;
7 As stated above, we understand the term "disqualified" does not affect the "operability" of the EDGs if one successful surveillance test has been performed. Ho.wever, we understand that if the second attempt to achieve the acceptable requalification test series fails, the EDG would then be declared inoperable for nuclear service. In this instance, what actions would be required for a licensee to bring the EDG back to operable s~atus?
The requirements to return the EDG to operable status after the second failure during the requalification program are not clear.
It is stated, "The diesel generator unit would not 'be tested more frequently than once in* any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval." We understand the intent of this requirement is to allow the EDG time to return to ambient conditions. This requirement would seem to be in. conflict with Item 1 of this Generic Letter which is aimed at reducing t:he number of "colq fast starts", and also poses the additional *burden of- excessive down time.
This will require that licensees propose significant increases in the maximum allowabl~ times in the technical specifications for inoperability.
For example, a failure occurs during surveillance testing of the diesel.
If, repairs are affected within two hours, twenty-two hours must pass before the diesel can be retested. This time (22 *hours) will have to be taken into account when determining the maximum allowable time the EDG may be inoper~ble (LCO 3.8.1.1).
6 * . Failure to Requalify a Diesel Generator As stated in 2 and 5 above, we understand this to mean that after two (2) unsuccessful requalification attempts, the EDG would be declared inoperable for technical specification limiting condit;i.ons of operation (LCO) purposes. *.How would* a licensee take action .to bring the EDG back to operable status after the second failure during the. requalification program?
7 .. Diesel Generator Inoperability As mentioned in 5 above, the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> between surveillance tests require-ments will necessitate a significant increase in the allowable out-of-service period from that which would be proposed if the requirement for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> between tests is deleted.
- 8. Valid Demands and Failures There are several concerns regarding the criteria of R.G. 1.108. In general, the criteria indicate that only surveillance tests could be counted as successes. However, .failures occurring at other times would be counted against the surveillance test data base. This would appear to be an invalid use of the data (i.e., it loads the surveillance test data base with failures which did not occur as a.result of that specific testing).
- 9. Reliability Records A clarification is needed between Attachment 1 to Table 4.8.2 of Appendix A and the recommended record keeping of Reg Guide 1.108.
- We believe it is OC0984-0009-NL02
8 intended that Reliability Improvement Program reports as required in Table 4. 8. 2 be included in Reg Guide 1. 108 recommended log.
Comments on Appendix A Typical Technical Specifications LCO 3. 8.1.1 Action b - We believe an incorrect citation exists and that the asterisked (*) statement attending this LCO should read "satisfies the .requirements of Surveillance Requirement
- . 4.8 *. l.l.2(a)4 Electric Power Systems".
L.CO 3
- 8
- 1. 1 Action e - The last sentence of the action statement says "With one diesel generator unit.restored, follow Action Statement b and d .. " TJ:ie requirement to follow action state-ment 'd' is not understood.
- Table 4.8.1 Diesel Generator Tesi Schedule See 3 above for comrilents.
Table 4.8~2 Additional Reliability Actions See 2 above for need to clarify use of terms inoperable and disqualified.
Attachment 1 to Table' 4.8-2 Reporting Requirement See 2 above for discussion pertain:i,ng to this proposed requirement ..
Additionally~ this section st.ates " .*. submit a yearly data report on the
. diesel generator reliability". It is not c*lear as to whom or in what detail this is to be submitted~
Attachment 2 to Table 4.8-2 Diesel Generator Requalification Program Item 4 states that "Following the second*failure during the requalifi-cation test program* be in at least HOT *STANDBY during the next.* .. " This is in disagreement with item 6 above "Failure to Requalify a Diesel Genera.tor" that states " ... the action statement in the plant technical specifications for one diesel generator inoperable shouid be followed immediately." The action statement .in the Standard Technical Specifica-tions allows for additional repair time prior to proceeding to* Hot Standby and Cold Shutdown.
Item 5 discusses.24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> intervals between test frequencies *.. See 7 above for comments.
Item (c) addr~sses the"placement of failures" within the last 20 or 100 demand series and allows that further requalification testing will not be required provided the number of failures is not increasing. We believe this same appro.ach should be used in the "Diesel Generator Test Schedule Table 4.8.1." As now stated, two or more failures that occur in the latter part of 20 valid demands, will necessitate weekly.surveillance testing for perhaps as long as 19 weeks. (See 3 above for example.) This increased test frequency will result in increased wear on the EDGs - and could not be justified when corrective actions are taken that eliminate the cause of the problem.
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