ML20056E238
| ML20056E238 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/16/1993 |
| From: | Piet P COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9308230042 | |
| Download: ML20056E238 (10) | |
Text
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E i) 1400 Opus Place Ccmmonwssith Edison m
Downers Grove, lilinois 60515
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August 16,1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn: Document Control Desk
Subject:
LaSalle County Nuclear Power Station Units 1 and 2 l
Supplemental Information to the Application for Amendment Request to Facility Operating Licenses NPF-11 and NPF-18, Appendix A, Technical Specifications NRC Docket Nos. 50-373 and 50-374
Reference:
(a) M. Depuydt letter to T. Murley, dated February 22,1993.
Dear Dr. Murley:
Reference (a) transmitted Commonwealth Edison Company's (CECO's)-
l proposed amendment request regarding the change in the allowed-outage-time (AOT) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to seven (7) days for the _'O' Emergency Diesel Generator (EDG) at LaSalle County Station. In response to questions posed by members of your Staff regarding the subject amendment request, CECO is providing supplemental information. This information is provided as an attachment to this letter.
To the best of my knowledge and belief, the statements contained above are
- i true and correct. In some respect these statements are not based on my personal j
know! edge, but obtained information furnished by other Commonwealth Edison l
i employees, contractor employees, and consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
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9308230042 930816 P
l PDR ADOCK 05000373 fhr I
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1 br. Murley August 16,1993 r
If there any questions concerning this supplement, please contact this office.
t Respectfully, eter L. Pie Nuclear Licensing Administrator l
Attachment:
Response to NRC Ouestions cc:
J. B. Martin, Regional Administrator - Rill J. L. Kennedy, Project Manager - NRR D. Hills, Senior Resident !nspector - LaSalle Office of Nuclear Facility Safety - IDNS i
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RESPONSE TO NRC QUESTIONS 1
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(Page 1 of 5) 1 1.
BEQUESI; Elaborate on preventive maintenance versus corrective maintenance and include types of preventive maintenance with approximate completion times.
RESPONSE
The current footnote describes under what conditions the normal 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time (AOT) can be extended. The footnote starts with the urpose, followed by modification of action statement b, and then a list of 5 conditions that must be met in order to allow exception. The purpose, as shown in both Unit 1 and 2 Technical Specifications, is as follows:
- For the purposes of completing technical specification surveillance requirements 4.8.1.1.2.d.1 and 4.8.1.1.2.f.1, as part of a pre-planned preventative maintenance I
program, on the O diesel generator the requirements of action statements b are modified to-l The specified surveillance requirements are:
4.8.1.1.2.d.1 (at least once per 18 months by):
Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service.
4.8.1.1.2.f.1 (at least once per 10 years by):
Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite or equivalent solution, and (4.8.1.1.2.f.2 follows).
The specified surveillances are very precise as to their scope, vith d.1 specifying
" diesel" manufacturer, which is Electromotive Division of General Motors (EMD); and f.1, storage tank cleaning.
The electrical control panel, generator, ventilation, diesel fuel storage and transfer system, fire protection and detection, diesel cooling water system (part of the core standby cooling system), air start system, and generator electrical protective relays are ktla\\!asatie\\dg0raiv4 3 f
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s BESPONSE TO NRC QUESTlQNS (Page 2 of 5) all either by different manufacturers and/or separate support systems. Therefore, although extensive preventive maintenance work may be required on support systems, i
the action statement footnote currently limits work to only the diesel itself and a 10-year fuel storage tank deaning.
Examples of support system work not currently allowed by footnote :
NOTE The following examples are DQt intended to be a comprehensive list. The times listed do not indude the time required to remove the equipment from service, restore the equipment and perform required testing to dedare the diesel generator or support equipment operable (1 to 2 shifts).
1 a.
Diesel generator heat exchanger inspections and deaning based on Generic Letter 89-13. Cleaning should be done without other work in progress in the area due to the nature of the work. Estimated duration 2 days; an additional 2.5 days if the heat exchanger needs to have the protective coating reapplied (48-hour curing time prior to re-assembly).
b.
Intemal inspection of the generator due to an adverse parameter trend, such as increasing stator temperatures or vibration. These trends would not make the generator inoperable, but would be showing by predictive means the need to schedule preventive maintenance. Estimated duration 3 days.
c.
Diesel Cooling Water Pump or Fuel Transfer Pump / motor rework due to increasing vibration. Normally performed by replacement with rebuilt pump / motor. Estimated duration 1 day for pump replacement,3 days for motor replacement.
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d.
Fuel storage tank deaning due to dedining fuel' quality (found by ongoing sample analysis). Estimated duration 3 days.
e.
Diesel cooling water system piping repair or replacement due to pipe wall thinning determined from Non-destructive Examination. Estimated duration 4 days.
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BESPONSE TO NRC QUESTIONS 5
(Page 3 of 5) f.
Diesel Generator output breaker preventive maintenance sunteillan.
Estimated duration 2 shifts.
g.
Predictive and planned maintenance per the following definition of Preventive Maintenance on the diesel or any of the support systems.
Commonwealth Edison Co. defines Preventive Maintenance as follows:
Preventive Maintenance - actions taken to maintain plant equipment within design operating conditions and extend plant equipment life. Preventive Maintenance is classified into three (3) types:
1)
Predictive Maintenance (PR) - continuous or periodic monitoring and diagnosis of equipment and components in order to forecast equiprmnt failures. Predictive Maintenance results are used to trend and monitor eauipment perfomunce so that planned maintenance can be performed prior to equipment failure. Examples include the following:
-vibration monitoring and analysis
-lube oil analysis
-heat exchanger performance monitoring
-nondestructive exanination 1
-pump and valve performance monitoring j
-insulation resistance (Meggaring)
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BESPONSE TO NRC QUESTIONS (Page 4 of 5) 2)
Periodic Maintenance (PE) - maintenance tasks performed on a routine basis (typically based on operating hours or calendar time) and may include any combination of extemal inspections, alignrnents, calibrations, intemal inspections, lubrication and filter changes. Examples include:
Check valve inspections.
Limitorque MOV inspection.
Filter Changes Lubrication 3)
Banned Maintenance (PL) - task performed prior to equipment failure, can be initiated by predictive or periodic maintenance results. Examples are as follows:
Scheduled Valve repacking.
Replacement of bearings as suggested by vibration analysis.
Major or minor overhauls based on experience or vendor recommendations.
i EQ Program.
Pump overhauls based on performance monitoring.
Thus, preventative maintenance includes predictive, periodic and planned maintenance actions performed befom equiprnent malfunctions / failures. Corrective maintenance is defined as:
Corrective maintenance performed to repair and restore equipment that is malfunctioning, degraded or has failed in service.
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BESEQNSE TO NRC QUESTIONS (Page 5 of 5)
The term degraded in the above definition would be evaluated on a case by case basis to determine if the equipment /cornponent is OPERABLE. If the equipment / component is OPERABLE, then the maintenan would be preventive if determined by predictive maintenan. Otherwise, the work would be corrective maintenance. Likewise, if predictive maintenance determines that a parameter required by ASME Section 11 is in the Required Action range, then the maintenance is corrective instead of preventive.
Based on the above definition of preventive maintenance and the number of support systems that are not included in the current definition of " diesel preventative maintenance", the footnote
- purpose is desired to be changed as submitted.
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RESP _QNSElO_NBC QUESTIONS (Page 1 of 2) 2.
RE_QUESI; i
Explain why using this extended Alloed Outage Time for modifications is acceptable.
BESPONSE:
Modifications are defined as follows:
Modification - Modifications are defined in ANSI N45.2.10 as:
A planned change in plant design or operation and accomplished in accordance with the requirernents and limitations of applicable codes, i
standards, specifications, licenses and predetermined safety j
requirements.
Modifications are defined in ASME Section Ill NCA 9000 as:
A change to an item made necessary by or resulting in, a change in design requirements.
Commonwealth Edison uses both of the above definitions for the description of a nudification. This procedure is the process used for controlling plant modifications, however, the same items considered rnooifications by the above sections of ANSI and ASME are procedurally controlled by the station outside the scope of this procedure; e.g., temporary procedure changes, setpoint changes, electrical trip settings, parts evaluations, component replacements, and computer software changes.
Modifications could result from equipment malfunctions or failures, which would normally be performed as corrective maintenance instead of a rnodification. In this case, the extended Alloed Outage Tme would not time be used. This limitation on the use of the extended Allowed Outage for modifications would be administratively controlled.
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BEEPONSE TO NRC QUESTIONS (Page 2 of 2)
The following are considered modifications at LaSalle:
a.
Modification.
b.
Minor modification.
c.
Setpoint Change.
d.
Component Replacement.
e.
Temporary System Change.
f.
Exempt Change.
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BESPONSE TO NRC QUESTIONS (Page 1 of 1) 3.
REQUEST:
Evaluate relocation of the reference to footnote
- that currently is located in Technical l
Specification 3.8.1.1 Urniting Condition for Operation.
BE_SEORSE; The location of the Footnote
- reference was discussed with the Operations Department. Based on the fact that licensed personnel are used to the current location and that the note clearly applies to diesel operability, LaSalle desires that the footnote reference remain unchanged.
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