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,'1L l lNuclear Memorandum PREVENTATIVE MAINTENANCE DURING OPERATION Date February 5, 1991 iubject T. G. Broughton - Director, TMI-1 Locat.:n TMI - OSF File: NRC - General 3000-91-017 F. I. Young - Senior Resident Inspector, TMI During 7. T. Martin's visit of December 1990, the subject of entering timeclocks to perform preventative maintenance was discussed.
In 1986 GPU looked into this gaestion, as it applies to emergency diesel generator maintenan:e at TMI-1.
I offered to provide Mr. Martin with a copy of the i
results of this study. The study includes gaantitative assessments of risks and also considers the subjective belief that the quality of the maintenance is enhar.ced by performing it in a non-outage period with the most qualified technicians and supervisors.
I have also included other relevant supporting information.
please provide the attached material to Mr. Martin. We welcome the opportunity to discuss this further with the NRC.
T. G. Br ghton Oirector, TMI-1 pje Attachments I
9408250229 940629 PDR COMMS NRCC CORRESPONDENCE PDR
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l Nuclear Memorandum i
Date January 7 1986 se,c, Preventive mintenance While Plant 6350-86966 Is Operating Consulting Engineer Locat cn CIG-Il p,c, W. F. Schnauss 2180K Director, Eclear Assurance g
A. L. Long The purpose of this memorandan is to outline a plan to evaluate the nuclear safety significance of planned removal of plant safety equipment from service for preventive maintenance during nuclear plant operations.
t The attached Plan shows the proposed program, schedule, logic paths and end product.
The interaction with and assistance need from other divisions is also identified in the Plan.
in accition to these proposed activities and courses of action, the following interactions have already taken place:
- Conversatforu with Technical functions Risk Analysis personnel regarding Probabilistic Risk Assessment (PRA) studies.
The scheduled availability of their resources and their need for budget support is incorporated in the Plan.
A conversation with the 0.C. Deputy Director to present GPUN question (s) on this subject to the EE1 Nuclear Operations Committer during their next meetings (February 3, 4, 5, 1986).
Conversations on this subject with Mr. Joe Carroll, Jr. (JCP4L) and the O.C. Plant Operations Director.
A conversation on this subject with the GPUNC Chairman of the GORBs.
A conversation with the TMI 10&M Director.
1his conversation covered both the proposed study areas at TMI-1 and the planned interaction with him when PRA results are available but prior to submittal of any conclusions or recommendations to the D/P.
Formal initiation of the PRA study of the 1MI-1 emergency diesels.
08 W. F. Schnauss Consulting Engineer - NSAD
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l ENuclear Memorandum i
subiect Preventive Maintenance While Plant Date January 20, 1986 6350-46-908 Is Operating "
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5'om-Consulting Engineer Loestion CHB-!!
W. F. Schnauss 2210K 4
To-Director, Nuclear Assurance R. L. Long i
i This memorandum outlines a plan to evaluate the nuclear safety significance of planned removal of plant safety equipment from service for preventive maintenance during nuclear plant operations.
The objective of this plan is to s
produce a docweented conclusion ard recommendation with regard to this issue.
The initial thrust of this plan is to use FRA methods to evaluate IH of the i
THI-1 emergency diesels while operating.
In parallel with this study, a @ery of the EEI Nuclear Operations Committee on this issue is planned.
If these two activities produce a useful result, a reccamerriation will be available i
March 10,1986.
(A preliminary discussion with Tech Functions Risk Analysis cast doubt that PRA results w>uld be conclusive.)
t If the first step does not produce a useful result, then we should consider a similar analysis of the THI-1 energency feedwater system. This PRA work would rewire estimated budget support of $35.K for Risk Analysis.
If the second step does not produce a useful result, we could consider conducting a more elaborste industry survey.
In addition to the preparation of this Plan, the following actions have been taken:
A discussion with Ron Toole regarding this plan and the PRA i
studies of THI-1 safety owipent.
Fomal initiation of the PRA study of the 1MI-1 emergency diesels.
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Nuclear Memorandum Svoieet CpWC Questions for the EEI Nuclear Date January 21, 1986 Operations Committee, Feb. 3 - 5, 1986 6350-86-910 From Consulting Engineer Location. CHB-!!
W. F. Schr.auss 2228K To Deputy Director, Onter Creek J. J. Barton The attached (uestions are forvarded per our telephone conversation on Decee.be r 31, 1985.
Your support in presenting thee to the EEI Co.=eittee is appreciated.
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W. F. Schmauss Consulting Engineer, NSAD h75:ves Attachs.
cc: CARIRS - H.Q.
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i GPtNC QUESTIONS FOR 1NE EEI WC1.E#t OPDATIONS CGNITTEE s
i February 3, 4, 4 5, 1986 i
The following questions are presented to obtain broad-based industry opinions regarding scheduled preventive maintenance on safety equipment during nuclear plant operations:
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I 1.
Do your Technical Specifications permit deliberate removal fres service of one train of a redundant safety system for preventive j
maintenance?
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2.
For those plats that the Technical Specifications persit such removal from service, what is your practice in this regard?
j 3.
Do you schedule major preventive maintenance, i.e.,12 or 18 i
month emergency diesel generator inspections, during operations j
or refueling outages?
4 What is your practice on less complex equipment such as an j
eeemency feedwater pop?
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In the event that your plants schieve higher Availability and 1
Capacity factors, which greatly reduce available time for j
scheduled preventive maintenance, would you re-evaluate your
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tA s/~,J 2 f471 Nuclear /
Ats 25ses Memorandum
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Subsect cana I: Dei POR INVEarrIGA:rIGI, ACTICN, cwt Date: August 21, 1986 CDMDC from Director. "JC H. D. Rukill t.oe s tion S c - TrailerIf U2
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Fi2m: G3tB 3000-46-200 he follaring itsus were raised at tfie CDIB meeting on August 19-20.
IndiviAmin appearing by each item are requested to provide sur with a status of seu.
t 1.
Inert tunnel - Should we install s@marsible pumps in case the tunnel fi mr*, again and nakes the presently instaued pomys incperab1m?
(Colitz) 2.
rnr the pit manhola cover in the FS-P-3 pep house, should it be grated and rot be watartight? If we de this, is there danger of trash getting into the pit?
(Colitz) 3.
Are diastragru in valves for the fizu deluge system a significant raintenanos pecbim @
(CoMt.2) 4 should a apoeial tig be designed for adaf ng oil to resetor coolant purps Aring operation, Weh sculd assure the proper arount of oil was =WA fram a rumann incation without creating a fire hazard?
(Aces) 5.
he G3tB reted that dring a roosnt reactor trip mt>oceling margin decreased wry elmee to the limit of 250 F.
A discussion ensued on how sus shlirst margin normany decreases during a trip. My ends with one 9 tift Supervisor indicated ed> cooling margin l
decreased to about 300 on the ons trip he cbearved.
It is ruguested that personnal the have aboarved our othar trips he questioned to estamine an appresdanta valus of ad><noling margin shortly after reactor trip.
(Rosa - Please provide se best infomation.)
6.
The ocstB raised several questions regarding irput from the Plant Staff to the PRA. The PflA is a very important project aid we need to ensure those conducting it reenive the best informatim available.
caaparation with amabars of the FRA taan by knewisageable eunbars of the Plant staff is a met to acezziplish this.
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.DISTRIMCN 2
AtaNet 21, 1996 2000-86 200 j
the alam. Durig the post trip rwiew, the button was depressed ard the alarm was % ted. Se MR &ms ret a:mment further on this mattar.
In view of the proper actiers and fleetionisq of the manual reactor trip button durire an A2WS, *.at fo12 car up is heirs taken on this netter?
It is suggested that all possible alternatives be estplarei If the reason canret be pinned & men, then it would appear that sczne action should be taken to lessen the probEbility of recurrence from and potantial Is any asneideration balig given to changf rq frusn a push button cause.
to a t>c position evitch? (Glaviare - Please have revie.ed ard prwide se infonnation.)
8.
Attached is the outline of a presentation by Bill Seseuss on Darymncf Diesel Generator Preventive Mailhee. Durirg Plant Oparation. The last page of this presentation contairs reocrenandations whie I agree with.
Plaaaa have then formally inplanantmi.
(Toola - shovlin - Please rotify no when 1.plemented or if you have disagreements.)
9.
Se CGtB strergly h.
d-that we procedur 11se rapirenants that work on or that could affect redundant systems not be permitted 4.an safety systsu are taken out of service for maintenance. I understand that this is our practice, but agree that we should formally proce&ralize it.
(Toola - kus - P1mana infom me h this has been procedar:11:ed, or let me kncw if ycu disagree or have altervative suggestions.)
I appreciats your help in arwwering these issues raised by the 00RS.
Di.roctor, M-1 HDH/pjl Attactrant ces chaizzan, Genaral Office Review Boards - I. R. Finfrock, Jr.
METPJECH Plant Ergineering Dirwn., M J. J. Colitz Plant Analysis Matager, M R. T. claviare Plant operations Dirw's, M M. J. Ross Managst, Plant Maintenanen, M D. M. Shculin operstiers a Maintenance Diz
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RECOMMENDATIONS I.
IMPLEMENT tnt FOLLOWING To RAIIRIZE tnt AVAIL ABILITY Or orFSITE ELECTRICAL P0wtn cuaINs THI-I EDG P.M.lINSPECTION:
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Scutoult THI-I EDG MAINTENANCE To co!NCInt WITw senze.
wtATHtm Stas 0NS.
AVOID tnt NISHER PROBA8!LITY SNoWIICE AND THUNDERSTORM / TORNADO SEASONS.
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CooRDINATt/ScHroult TMI-I EDG MAINTENANCE WITH MET Es STtTtM DISPATCHIN8 To ENSURE MAYIMUM AVAILA8!LITY OF oFF-s!TE POWER To TMI.
2.
IMPLEMteT GPUN ConPonATE Paocteunt. Peeernuer reo covroot er PLANT N0DIrfcAff0NS AND Marot MAIMTENANff kbtr WWTt E ?WF PLANT in In opre Arren. No.1504-ADM-3040.01 To aroufar
- PtcIFIc DIvtsfoN O!ntCToR APPROVAL Fon tnt EDG P.M./ INSPECTION TASK AND PERFotMANCE oF SUPPLEMENTAL SUPtaVIsont at PONSIsILITIts esmINs THIs vote.
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G.P.U.y O/P i
orricE or THE PRES!oENT pp %. g.., ' T ACTION ITEM 4(JG gg i
DATE. 08/08/86 i.
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j TO: Director, Nuclear Assurance, R. L. Long SUBJECT-PREVENTIVE MAINTENANCE WHILE PLANT IS OPERATING l
OUE DATE:
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j The attached correspondence assigns an ACT!oN to you t
from President - P. R. Clark.
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When responding, please reference this document and ATTACM THIS NOTE TO YouR RESPONSE.
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At t actwnent
RESPONSE
This action item is complete.
See attached transmittal letter 6300-86-995 and
},g J,- Mr* report of the CPUN Study on this subject.
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k Sub,ect Preventive Maintenance Whfie Date September 22, 1986 plant is Operating NA/1387 i
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Director Nuclear Assurance MCC-E3 j
R. L. Long 3047K in President, p. R. Clark r
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The folinwing is in response to the questions you had noted on the action item sheet (Attachment 1).
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The $tudy recommendations were agreed with and implementation j
initiated by H. D. Hukill memo 3000-86-200, paragrapn 8 1
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(Attacnment 2).
1 Current experience of EDG reliability at TMI-1 and Oyster Creek are identical as presently reported in terwn of failures experienced in the preceding 100 starts.
A change in the Oyster Creek Tech Specs is not recommended for the 4
following reasons:
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Tne of fsite power sources for Oyster Creek are not as reliable as those at TMI-1 2.
The Dyster Creek staff has expressed a strong belief that EDG p.M./ Inspection should be seneduled when the plant is shutdown.
i R. L. Lon
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Direc tor welear Assurance RLL/WPS:ves l
Attacns.
cc: Executive Vice President - E. E. Kintner Cnairman GORBS - I. R. Finfrock, Jr.
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Director, Oyster Creek P. B. Fiedler i
Director, Tecnnical Functions - R. F. Wilson Director, TMI H. D. Nukill Director, Maintenance, Construction, Facilities - F. F. Manganaro Nuclear Safety Assessment Director - R. W. Whitesel u......
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