ML20058H462

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Forwards Addl Info in Response to NUREG-0737,Item II.K.3.17 Re Description of ECCS & Emergency Diesel Generator Outage Time Due to Surveillance Testing or Preventive Maint,Per 820701 Request
ML20058H462
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 07/30/1982
From: Crouse R
TOLEDO EDISON CO.
To: Stolz J
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.17, TASK-TM 843, NUDOCS 8208030587
Download: ML20058H462 (3)


Text

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Docket No. 50-346 TOLEDO EDISON License No. NPF-3 RCHARO P. Cant Serial No. 843 WAY wisi assaai July 30, 1982 Director of Nuclear Reactor Regulation Attention:

Mr. John F. Stolz Operating Reactors Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D. C.

20555

Dear Mr. Stolz:

This is Toledo Edison's response to your request for additional information on TMI Action Plan Item II.k.3.17 Report on Outages of ECC Systems, dated July 1, 1982, (Log No. 1024).

The request for additional information from Franklin Research Center (FRC) states that utilizing only the Licensee Event Reports (LER's) from Davis-Besse Nuclear Power Station will not result in enough information to allow complete review.

FRC, there-fore, requested that Toledo Edison supply information concerning surveillance testing of ECC Systems. of this letter is a description of the total ECCS and Emergency Diesel Generator outage time due to surveillance testing or preventative maintenance.

This completes Toledo Edison's response to NUREG-0737, Item II.k.3.17.

Very truly yours RPC:RFP:nif I

[

encl.

cc: DB-1 NRC Resident Inspector O

8208030587 820730 PDR ADOCK 05000346 P

PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

Docket No. 50-346 License No. NPF-3 Page 1 of 2 Serial No. 843 July 30. 1982 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - NUREG-0737, Item II.k.3.17 Inoperabilities of Emergency Core Cooling Systems (ECCS) and Diesel Generators (D.G.)

are reported in detail in the Licensee Event Report System (LER's), including the date, duration, cause, system and/or component, and corrective action taken. Davis-Besse prepares LER's for an unplanned inoperability not only when the unit is in the mode requiring operability but for any unplanned inoperability in all plant modes to document component failures. Therefore, the only additional information required should be the outage hours caused by surveillance testing and of planned or preventa-tive maintenance.

Surveillance Testing Since the amount of surveillance testing performed on the ECC and D. G. systems is dependent on the plant mode, a history of testing performed alone will not allou a determination of' cumulative outage limitations.

The ECCS technical specifications require redundant strings in plant modes 1 through 3 and the diesel generators re-quire redundant generators in plant modes 1 through 4.

Therefore, only testing per-formed during these modes should be included in the evaluation. These tests are:

ST 5051.09 "High Pressure Injection Pump & Check Valve Test" ST 5051.10 " Decay Heat / Low Pressure Injection Pump & Check Valve Test" ST 5081.01 " Diesel Generator Monthly Test" (Although the Core Flood System is part of the ECCS, it is a passive system, which is not affected by testing).

The ECCS pump testing ST 5051.09 and ST 5051.10, affect the operability of the string by opening a manual test line to provide a recirculation path-back to the borated water storage tank. This does not make the pump being tested inoperabic but would require manual closure of the test line valve.if full injection is required. This requirement for restoration is specified in each procedure to ensure test personnel perform the restoration if emergency operation is required. These tests would be performed for approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per month for each of the four ECCS pumps, for a total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per month for the ECC Systems.

Each D. G. is tested monthly during normal operation per Surveillance Test ST 5081.01.

The monthly-test is divided into a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> lubrication run at reduced speed and a loading run which takes approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform. The D. G. is not inoperable during the test but operator action is required to return the diesel generator to an emergency operation condition, as is stated in the procedure. Therefore, the total time a diesel generator is under test conditions is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per month, for a total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for both diesel generators.

.s

-Docket No. 50-346 License No. NPF-3 Page 2 of 2 Serial No. 843 July 30, 1982 Planned or Preventative Maintenance Although planned or preventative maintenance also removes ECCS and D. G. components from service during normal operation, establishing absolute values for the lengths of time the components are affected to allow a determination of cumulative outage limitations is not possible.

It is the practice at Davis-Besse to schedule as often as possible the preventative maintenance when the unit is in the mode which does not require the operability of the equipment. The following is a summary of the planned or preventative maintenance irrespective of any reduction due to unit availability factor or scheduling bias.

On the High Pressure Injection and Low Pressure Injection pumps, an annual oil change-and coupling alignment check requires approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per pump. The passive Core Flood System is not affected by preventative maintenance. The diesel generators have preventative maintenance performed which requires 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> each month and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> each quarter per diesel generator.

This additional information should satisfy the request for additional information and allow you to continue your review of NUREG-0737, Item II.k.3.17.

b SNB:nif 7/30/82

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