Text

Proposed Tech Specs,Reflecting Addition of TS 3.10.8 Allowing Extension of Sdg AOT for Cumulative 21 Days on Each Sdg Once Per Fuel Cycle & Extension of AOT on Each Essential Cw Loop for Cumulative 7 Days Once Per Fuel Cycle
	ML20091R415
Person / Time
Site:	South Texas
Issue date:	08/28/1995
From:	; HOUSTON LIGHTING & POWER CO.
To:	;
Shared Package
ML20091R413	List: ML20091R415; ST-HL-AE-5141, Application for Amends to Licenses NPF-76 & NPF-80, Requesting Addition of TS 3.10.8 Which Would Allow Extension of Sdg AOT for Cumulative 21 Days on Each Sdg Once Per Fuel Cycle;
References
	NUDOCS 9509070002
	Download: ML20091R415 (44)
	v • d • e

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ST-HL-AE-5141 Attaclunent 2 Page 1 of 4 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.8 DIESEL OPERABILITY EXCEPTION - MODES 1,2. 3 & 4 LIMITING CONDITION FOR OPERATION (LCO) 3.10.8 The requirements of Specification 3/4.7.4 and LCOs supported by this Specification may be suspended for 7 days / train / cycle AND Specification 3/4.8.1.1 may be suspended for 21 days / train / cycle provided:

a. The requirements for two (2) of the onsite power sources specified in Specification 3.8.1.1.b AND the two (2) supporting ECW loops specified in Specification 3.7.4 are OPERABLE;

b. The circuits required by Specification 3.8.1.1.a are OPERABLE;

c. The equipment specified in ACTION 3.8.1.1.d is OPERABLE;

d. The circuit between the 138 kV offsite transmission network, via the Emergency Transformer, and the onsite Class IE Distribution System shall be functional and available;

e. The technical support center diesel generator and the positive displacement pump are functional and available;

f. . Planned maintenance on the equipment specified in ACTION 3.8.1.1.d is suspended;

g. Maintenance in the switchyard is controlled APPLICABILITY: MODES 1,2,3, and 4.

SOUTH TEXAS - UNITS 1 & 2 3/4 10-8 Unit 1 - Amendment No.

Unit 2 - Amendment No.

9509070002 950828 PDR ADOCK 05000499 P,_ _ _PDR

e' ST-HL-AE-5141 l Attachment 2 ;

Page 2 of 4 i DIESEL OPERAHILITY EXCEPTION - MODES 1,2. 3 & 4 LIMITING CONDITION FOR OPERATION (LCO)

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ACTION: :

a. With any specified condition (s) not met, then restore the specified condition (s) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or place the unit in the following MODE, as applicable,:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and l

3. At least COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

j OR ,

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b. With any specified condition (s) not met, then exit this Special Test Exception and ,

enter the appropriate Technical Specification Action Statement. !

SURVEILLANCE REQUIREMENTS 4.10.8.1 Perform Surveillance Requirements 4.8.1.1.1.a for the Standby and Auxiliary i Transformers at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

l 4.10.8.2 '

Verify Emergency Transformer breaker alignment correct and indicated power available at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

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SOUTH TEXAS - UNITS 1 & 2 3/4 10-9 Unit 1 - Amendment No. !

Unit 2 - Amendment No. (

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i ST-HL-AE-5141 i Attachment 2 - i Page 3 of 4 l

3/4.10 SPECIAL TEST EXCEPTIONS BASES

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3/4.10.8 DIESEL OPERABILITY EXCEPTION - MODES 1. 2. 3 & 4 !

'i This Special Test Exception (STE) permits an essential cooling water loop to be inoperable for a cumulative 7 days per train per fuel cycle and a standby diesel generator to be inoperable for a cumulative 21 days per train per fuel cycle. In both cases, it is intended that if the essential cooling water is inoperable, the associated standby diesel generator is also inoperable. This exception is to !

be used for planned maintenance and testing only if all of the necessary compensatory actions are in !

place. If any condition of the LCO is not met during the time a standby diesel generator and/or the !

essential cooling water is inoperable under this special test exception, a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months would >

be permitted to restore the condition before a plant shutdown or exiting the special test exception is required. In addition, a risk assessment must be performed in accordance with the South Texas Project Configuration Risk Management Program (CRMP). Based on the resuhs of the assessment, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time may be further restricted. The intention of this action is to allow a component in one of the other two trains to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if the risk assessment ;

determines 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is acceptable, during this special test exception. If unable to return the inoperable equipment to operable status within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time limit or if the time limit determined by the risk assessment is shorter, actions must be taken in accordance with the STE and the STE CRMP.

l The CRMP specifies the process for assessing and monitoring changes in core damage probability or large early release probability while in certain planned and unplanned maintenance !

configurations. Large Early Release Probability (LERP) is defined as a large (>3") and early !

containment failure or bypass that possess a significant potential for short term health impact. Early containment failure includes failures occurring before or within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of reactor vessel breach and before the effective implementation of the off-site emergency response and protective actions.

Generally, the CRMP process is initiated once a planned maintenance schedule has been approved for i a selected period of time (typically one work week). The planned maintenance schedule is evaluated '

to identify the plant configurations that result from the scheduled work activities. A risk profile for i the selected time period is then generated by quantifying the PSA for each identified plant configuration. Risk thresholds are used to determine when rmnaement/ supervisory oversight or compensatory actions are warranted.

SOUTil TEXAS - UNITS 1 & 2 B 3/410-2 Unit 1 - Amendment No.

Unit 2 - Amendment No.

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r ST-IIL-AE-5141 Attachment 2 Page 4 of 4 3/4.10 SPECIAL TEST EXCEPTIONS BASES 3/4.10.8 DIESEL OPERABILITY EXCEPTION - MODES 1. 2. 3 & 4 The purpose of this exception is to allow pre-planned testing and maintenance of the standby diesel generator and the essential cooling water and to allow credit for the performance of surveillances prescribed in SR 4.8.1.1.2 while in Modes 1,2,3 and 4. The STE is not intended to be used as a means to start planned outage maintenance prior to the start of the planned outage. As much as is practical, the plant should be maintained in a steady state condition for the duration of the STE. Time permitting, evolutions, including mode changes, should be evaluated in accordance with the CRMP.

l The emergency transformer will be administratively dedicated to the ESF bus with the inoperable standby diesel generator. This means that the breaker alignment will enable the emergency transformer to supply power to the affected bus if a loss of offsite power were to occur.

It is also intended to allow the use of the emergency transformer to supply any ESF bus during a loss ,

of offsite power if the Shift Supervisor determines this is necessary. No pre-planned maintenance [

will be performed on the technical support center diesel, the positive displacement pump or the l emergency transformer during the use of this STE. In addition the Shift Supervisor will control all work that is performed in the switchyard in accordance with established station procedures.

The analytical basis for the STE is a combination of deterministic and probabilistic methods.

From a deterministic, design basis perspective, STP maintains the capability to mitigate most design basis events with one of its three ESF trains. This is a condition that is conservatively postulated to result from an accident while the STE is in effect with a loss of off-site power and a subsequent failure of one of the remaining ESF diesel generators and assumed failure of the emergency transformer.

Since maintenance and testing activities are explicitly included in the PSA analysis, it is possible to determine the impact of equipment outages on the probability of core damage or radiological release events for those systems and components within the scope of the PSA.

Generally, the impact of unavailable equipment is seen as a reduction in the defense-in-depth which causes an increase in probability of core damage or radiological release. The time and duration of planned equipment outages can be assessed and incorporated into the PSA analysis. The incremental !

risk associated with the STE has been determined to be small, which is attributable to the redundancy and capability of the STP design as noted above. The CRMP provides the process for controlling

. plant configurations to keep the risk acceptably small.

SOUTII TEXAS - UNITS 1 & 2 B 3/410-3 Unit 1 - Amendment No.

Unit 2 - A.mendment No.

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I ATTACHMENT 3 ANSWERS TO NRC QUESTIONS ON THE 21 DAY DIESEL SUBMITTAL

7 Attachment 3 ST-HL-AE-5141 Page 1 of 17 Ql. In your submittal of May 1,1995, you proposed to extend the allowed outage time (AOT) from 3 days to 21 days once per fuel cycle for each standby diesel generator (SDG) to perform preventive maintenance. Explain why 21 days is required to perform maintenance on the SDGS. Current staff thinking is that an AOT for the SDGs of more than 14 days should only be considered on a one-time basis. This time period is . .ased on industry experience, that a maximum of 216 hours0.0025 days 0.06 hours 3.571429e-4 weeks 8.2188e-5 months (13.5 days, -

consisting of two shifts, each shift working 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) is sufficient for a major SDG overhaul. Justify your request for 21 days rather than 14 days.

A1. This submittal requests a Special Test Exception (STE) that can only be used once per cycle per train. The STE duration is supported by the STP speciGc Probabilistic Safety Assessment (PSA). The anticipated time duration for an 18 month or 5-year diesel surveillance is eight days; however, a ten year surveillance is expected to require at least 14 days. This 14 day duration will consume two-thirds of the AOT time of 21 days. While our estimated duration for a ten year surveillance is consistent with the industry average and appear to support a 14 day AOT, we do not believe a 14 day AOT provides suf6cient margin for the resolution of Gndings which may be identined during the inspection. By normal South Texas Project (STP) practice, actual LCO work (excluding return to service activities) is scheduled for no more than 50% of the Limiting Condition for Operation (LCO) allowed outage time, except for special circumstances to allow for correction of issues identined during the LCO. It is STP's intention to limit the duration of the STE to as few days as possible to perform the required surveillance work. Consequently, the use of the full 21 days adds to the conservatism of the PSA evaluation.

Q2. Section 2.3.3, "Model for Emergency Transformer", discusses changes to previous PSA models. Expand upon the discussion provided and include a quantitative discussion on how industry data on offsite power losses were reclassiGed to quantify two different types of offsite power events. Also provide additional information on the emergency transformer power source and explain how this source would be connected to the safety busses when one SDG is inoperable for 21 days.

A2. The 138kV emergency transformer is supplied from a radial line out of Central Power and Light Company's Blessing Substation. The 138kV supply is capable of furnishing the full load rating of the 138kV emergency transformer. The 138kV transmission line does not cross over or under any high-voltage lines connecting the 345kV switchyard to the plant and the emergency transformer is physically separated from both the No. I and No. 2 standby transformers by a minimum of 800 feet. This will ensure that a :

single accident in the 138kV emergency transformer will not jeopardize the standby j transformers. During the routing of the 138kV line from the Blessing Substation to the STP switchyard, the 138kV line does cross under two of the eight 345kV lines l

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Attachment 3 ST-HL-AE-5141 Page 2 of 17 approximately 2 miles from the switchyard. In the unlikely event of earthquakes, high winds, tornados, or other natural phenomena, both the 345kV and 138kV lines could fail.

The PSA models analyzed the risk significance from two different types ofinitiating events that interrupt power from the offsite grid.

Loss of 345kV Power (LOSPk This initiator accounts for events that disable the normal power supply from the 345kV switchyard. These events do not include failures that simultaneously disable the 138kV power supply to the Emergency Transformer. Therefore, LOSP initiating events disable power from the Unit Auxiliary Transformer and the Standby Transformer, but they do not directly disable power from the Emergency Transformer. The Emergency Transformer power supply may remain available, or it may fail independently after the LOSP initiating event occurs.

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Loss of 345kV and 138kV Power (LOSPXh This initiator accounts for events that simultaneously disable all offsite power supplies from the 345kV switchyard and the 138kV line. Therefore, LOSPX initiating events disable power from the Unit Auxiliary, Standby, and Emergency Transformers.

The PSA models did not analyze any initiating events that involve loss of only the 138kV power supply. The Emergency Transformer does not normally supply any plant loads: therefore, loss of 138kV power, by itself, will not cause a plant trip, and is not an initiating event for the PSA.

Event data from NSAC-203 was screened to develop the initiating event frequencies used in this study. The events in NSAC-203 include only those failures that are reported as a " loss of offsite power." In particular, NSAC-203 does not include complete documentation of all failures of transmission lines, switchyard equipment, transformers, etc. that do not cause a " loss of offsite power" event. However, a number of plants in the NSAC-203 database did include alternate non-GDC-17 power supplies similar to the 138kV line and Emergency Transformer at STP. Most of the event descriptions for these plants clearly indicate whether the alternate non-GDC-17 supply remained energized during the " loss of offsite power" event. Based on this information, it was concluded the NSAC-203 database can be used to derive valid conservative estimates for the frequency of events involving combined failures of the GDC-17 and non-GDC-17 power supplies. These events correspond directly to the two initiating events (i.e., LOSP and LOSPX) that were used in the PSA models.

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y Attachment 3 ST-IIL-AE-5141 Page 3 of 17 The unavailability of the Emergency Transformer supply was quantified using generic failure rate data for the transmission lines, buswork, circuit breakers, motor-operated disconnect switches, and large transformers.

The mean frequency ofinitiating event LOSPX in the PSA models is 1.4E-02 events per year. This means the expected frequency of an event simultaneously disabling the 345kV and 138kV power supplies is approximately one event in 70 years of plant operation.

The mean frequency ofinitiating event LOSP in the PSA models is 2.20E-02 events per year. This means the expected frequency of an event that will disable only the 345kV power supply is approximately one event in 45 years of plant operation.

The estimated mean unavailability of the Emergency Transformer power supply in the PSA models is 5.84E-03. This means the Emergency Transformer is not available approximately 0.6% of the time, or approximately 2 days per year during plant operation.

The estimated unavailability of the Emergency Transformer power supply in the PSA models was not based directly on the data from NSAC-203. The NSAC-203 data was used to estimate the frequency of common cause events that simultaneously disable the ;

345kV and 138kV offsite power supplies.

Plant Operating Procedure, OPOP05-EO-EC00, " Loss of All AC Power", provides the actions necessary to respond to a loss of all AC ESF power. In step 5, if the standby diesel generator does not start from the control room or locally and no manual energizing of the AC ESF bus is possible, then the emergency transformer is used to energize the AC ESF bus. The emergency transformer will carry any one ESF bus in each unit.

Q3. Footnote 10 to Surveillance Requirement 4.8.1.1.2 states, " Credit may be taken for events that satisfy any of these Surveillance Requirements", however no discussion is provided in your submittal for this change. Explain how this footnote would be used to satisfy surveillance requirements.

A3. This' footnote is intended to allow surveillance credit for events, either planned or unplanned, that satisfy the surveillance requirements of the Technical Specification.

These events may include the performance of the surveillance tests during the special test exception, performance of the surveillance testing during shutdown, or an i actuation of the system due to a valid signal that fulfills the surveillance testing requirements. This footnote is part of the current Technical Specification NUREG l 1

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Attachment 3 ST-HL-AE-5141 Page 4 of 17 1

1431, Rev. I standard wording. This footnote will not have any impact on the normal performance of surveillance requirement testing.

Q4. The staffis presently concerned that the extensions of SDG AOTs may increase the mean core damage frequency (CDF) from station blackout (SBO) events, and impact the resolution of unresolved safety is::ue A-44. Provide the calculated CDF for SBO sequences without the proposed special test exception, and the CDF for SBO sequences with the proposed special test exception. Also provide the overall unavailability of the

, SDGs used in the PSA to calculate the CDFs for the SBO sequences requested.

A4. The primary objective of this STE is to permit concurrent planned maintenve to be performed on each DG and ECW train once per fuel cycle. This will extend tne ECW and DG system AOTs for each train to 7 days and 21 days, respecti'.ely, once per fuel cycle. The current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT for both systems will be retained for other planned maintenance activities during the rolling maintenance cycle (voluntary LCO entry) and all unplanned and corrective maintenance (involuntary LCO entry).

The PSA does not model the station blackout event as a single initiating event.

Instead, several initiators can contribute to a station blackout scenario (SBO). These are: Loss of all Offsite Power (LOSPX), Loss of 345kV Offsite Power (LOSP), Loss of Power from the Main Transformer (LOMT), General Transient Induced Loss of 345kV Power (TLOSP), General Transient Induced Loss of 345kV & 138kV Power (TLOSPX). These initiating events make up the spectrum of SBO scenarios in the PSA sequence database.

The STP PSA is a "Living PSA" which is revised as necessary to reflect current plant .

design and practices. The current PSA calculation, includes the incorporation of recently approved risk-based allowed outage times for several Technical Specifications, an update of the PSA plant specific and generic failure rate database and the incorporation of the emergency transformer. The impact of these changes further refines the PSA model in order to more accurately reflect plant risk. The initiating event contributions for comparison in the PSA sequence database are:

SBO Frequency - 1992 Level 2 (IPE) PSA 1.79E-05 SBO Frequency - 1993 Risk Based Evaluation 1.28E-05 SBO Frequency without Special Test Exception 3.73E-06 SBO Frequency with Special Test Exception 5.28E-06 The diesel generator system unavailability modeled in the STP PSA is shown below and includes all planned and corrective maintenance. Also, included in this value is the unavailability due to maintenance (corrective and planned) on the essential cooling

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Attachment 3 ST-HL-AE-5141 Page 5 of 17 i I

water system. This information accounts for the dependency of the diesel generators on the essential cooling water system. All other diesel generator dependencies are accounted for in the PSA.

Unavailability with Special Test Exception 1618 hours0.0187 days 0.449 hours 0.00268 weeks 6.15649e-4 months Unavailability without Special Test Exception 700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months Q5. The staff is currently in the process of granting a 14-day AOT to a plant that has installed a weather-proof tic-line from a hydro station used as an AAC source which will substitute for the inoperable SDG. The staff believes that a 14-day AOT is adequate to perform any preventive SDG maintenance, including a major overhaul, provided the following conditions are met. Provide a discussion of how you would satisfy each condition listed below.

Q5a. The Technical Specifications (TSs) should include verification that the required systems, mbsystems, trains, components, and devices that depend on the remaining SDGs as a source of emergency power are operable before removing ;

an SDG for preventive maintenance (PM). In addition, positive measures :

should be provided to preclude subsequent testing or maintenance activities on ;

these systems, subsystems, trains, components, and devices while the SDG is ;

inoperable. t A5a. Prior to using the STE, all required systems and trains will be verified operable using the normal administrative controls. In addition, prior to entry into the LCO allowed outage time, a PSA analysis of the planned work will be :

performed. During the STE LCO, planned maintenance and testing on required redundant systems and trains will not be scheduled, while the SDG is inoperable, unless required to comply with Technical Specifications.

Q5b. The overall unavailability of the SDG should not exceed the value that was used in the PRA supporting the proposed AOT. Also, the SDG unavailability should be monitored and controlled in accordance with the maintenance rule performance criteria.

A5b. The primary objective of this STE is to permit planned maintenance to be performed on each DG and ECW train once per fuel cycle. This will extend the ECW and DG system AOTs for each train to 7 days and 21 days, respectively, once per fuel cycle. The current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT for both systems will be retained for other planned maintenance activities during the rolling maintenance cycle (voluntary LCO entry) and all unplanned and corrective maintenance (involuntary LCO entry).

". I Attachment 3 ST-HL-AE-5141 Page 6 of 17 The PSA model conservatively assumes utilization of all 21 days of the requested STE once per Diesel Generator per fuel cycle. In actuality, this will not be the case. For example, the current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO for planned maintenance on the Diesel Generator has a mean average, including return to service activities, of 42.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , which is approximately 59% of the total LCO period. By conservatively assuming in the PSA the whole 21 days is utilized, the overall DG unavailability due to planned maintenance activities should not be exceeded. -

STP is in the process of implementing 10CFR50.65, the Maintenance Rule, and has been utilizing the PSA during this process. The Diesel Generator System '

has been determined to be a risk significant system and will have performance criteria set in accordance with the program. Therefore, Diesel Generator unavailability and reliability will be monitored and controlled in accordance with the maintenance rule performance criteria. Prior to entry into the LCO allowed outage time, a PSA analysis of the planned work will be performed.

After the work is completed, a revised PSA analysis will be performed to reflect the actual work duration.

Q5c. The TSs should contain requirements to demonstrate, before taking an SDG out for an extended period, the emergency transformer source is functional by verifying the power source is capable of being connected to the safety bus associated with the inoperable SDG, and verifying capability of being !

connected to the safety bus every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

A5c. These actions are contained in the requested STE as Action d. of the LCO and surveillance requirement 4.10.8.2.

Q5d. Voluntary entry into a limiting condition for operation (LCO) action statement to perform preventive maintenance (PM) should be contingent upon a determination that the decrease in plant safety is small enough and the level of risk the plant would be at with the AAC power source (or, in this case, the emergency transformer) is acceptable for the period and is warranted by operational necessity, not by convenience.

A5d. The primary objective of this STE is to permit planned maintenance performance on each DG and ECW train once per fuel cycle. This will extend the ECW and DG System AOTs for each train to 7 days and 21 days, ;

respectively, once per fuel cycle. The current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT for both systems will be retained for other planned maintenance activities during the rolling

s Attachment 3 ST-HL-AE-5141 .

Page 7 of 17 maintenance cycle (voluntary LCO entry) and all unplanned and corrective maintenance (involuntary LCO entry). .

The primary motivation behind STP's request for this STE is the desire to achieve a more balanced allocation of component maintenance tasks between full power operation periods and refueling outages. In addition, accounting for unique plant features will relieve an undue burden on the resources required to test and maintain plant equipment caused by the application of standard :

Westinghouse (20 Technical Specifications on STP.

The current 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT for both the diesel generator (DG) and essential cooling water (ECW) systems is still applicable for correct!"e and preventative maintenance activities. As a result of the proposed change, some of the preventative maintenance for the ECW and DG Systems currently performed during refueling outages could be performed with the plant at power. l Considering the risk impact of the proposed change, the requested STE will not result in a significant increase in the risk of a severe core damage event. In fact, when considering the positive effects of removing a significant amount of diesel generator and essential cooling water maintenance from the refueling outages, the proposed change will improve plant safety during refueling l' outages. This is due to the increased likelihood the ECW and DG Systems having a higher availability during shutdown conditions and an enhanced station focus on equipment within the scope of the proposed STE relative to the scope of equipment within a refueling outage.

Q5e. Voluntary entry into an LCO action statement should not be abused by repeated entry into and exit from the LCO. .

A5e. As stated in the bases of this submittal, this special test exception permits an essential cooling water loop to be inoperable for a cumulative 7 days per train per fuel cycle. It also permits a standby diesel generator to be inoperable for a cumulative 21 days per train per fuel cycle. In both cases, if the essential cooling water is inoperable, the associated standby diesel generator is also 4 inoperable. This exception is to be used for the cumulative number of days l

specified per train per fuel cycle and for planned maintenance and testing. This !

exception is permitted only if all of the necessary compensatory actions are in i place. STP intends to only use this STE once per train per cycle. However, !

since there is a maximum cumulative number of days allowed per diesel per fuel cycle, repeated entry into and exit from this STE will not occur.

I Attachment 3 ST-HL-AE-5141 Page 8 of 17 Q5f. Removal from service of safety systems and important non-safety equipment, including offsite power sources, should be minimized during the SDG PM.

A5f. It is the intention of STP to eliminate planned maintenance on risk significant systems during the STE and to minimize all other work on important non- ,

safety equipment, including offsite power sources during the use of the STE.

Since this STE will be used approximately four times per 12 months, planning for the 21 day AOT will be performed well in advance. Transmission and Distribution will be involved in this planning process to ensure all work to be performed is preplanned and no risk significant work is scheduled in the switchyard during the use of the STE. If a situation requiring corrective maintenance should occur during the use of the STE, a risk analysis will be performed to determine the actions necessary to ensure plant safety.

Q5g. Voluntary entry into an LCO action statement should not be scheduled when adverse weather is expected.

A5g. Current plant procedures will prevent voluntary entry into this LCO during ,

expected adverse weather conditions.

Q5h. If an SDG is removed from service for preplanned maintenance, the TSs should include provisions for demonstrating the operability of the remaining SDGs by testing at least once within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the first 7 days of the 14 days AOT period unless the required monthly testing of the SDGs coincides with the first 7 day period. This demonstration of operability is necessary to provide assurance that the remaining SDGs are operable because of their increased importance due to the inoperability of one SDG over this extended period. This operability test does not require paralleling to the grid and loading the SDG.

A5h. STP will demonstrate the operability of the remaining standby diesel generators prior to entry into the STE as part of the prerequisites. However, the STP believes the operability testing of the standby diesel generators after the first 7 days of the STE is not necessary and is inconsistent with the latest guidance provided in NUREG 1431, Rev. I and recently approved amendments to the STP Technical Specifications. The NUREG 1431, Rev. I guidance and the recently approved STP Technical Specification amendments are intended to resolve the unnecessary starting and resultant wear on OPERABLE standby diesel generators caused by Technical Specification requirements.

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Attachment 3 ST-HL-AE-5141 Page 9 of 17 In addition to the previous responses, Houston Lighting & Power 's Configuration Risk Management Program will be used to assess the risk associated with any configuration change occurring during the duration of the STE. This program augments the required 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ACTION and may impose shorter duration /more restrictive actions if calculated risk exceeds program criteria.

The STP Probabilistic Safety Assessment (PSA) is a plant-specific integrated risk analysis model which estimates the frequency of a core damage or radiological release event resulting from various initiating events (e.g., turbine trip, reactor trip, steam generator tube rupture). The PSA incorporates plant-specific design features and equipment dependencies along with operator actions to identify equipment and events necessary to prevent or mitigate a core damage or radiological release event.

Since maintenance and testing activities are explicitly included in the PSA analysis, it is possible to determine the impact of equipment outages on the probability of core damage or radiological release events for those systems and components within the scope of the PSA. Generally, the impact of unavailable equipment is seen as a reduction in the defense-in-depth which causes an increase in probability of core damage or radiological release. The time and duration of planned equipment outages can be assessed and incorporated into the PSA analysis. The results can be used to represent the conditional core damage probability or conditional large early release probability for the given planned maintenance configuration (s).

The CRMP specifies the process for assessing and monitoring changes in core damage probability or large early release probability while in certain planned and unplanned maintenance configurations. Large Early Release Probability (LERP) is defined as a large (>3") and early containment failure or bypass that possess a significant potential for short term health impact. Early containment failure includes failures occurring before or within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of reactor vessel breach and before the effective implementation of the off-site emergency response and protective actions.

Generally, the CRMP process is initiated once a planned maintenance schedule has been approved for a selected period of time (typically one work week). The planned maintenance schedule is evaluated to identify the plant configurations that result from the scheduled work activities. A risk profile for the selected time period is then generated by quantifying the PSA for each identified plant configuration. Risk thresholds are used to determine when management / supervisory oversight or compensatory actions are warranted.

Adherence to the work schedule as planned and represented by the associated risk profile ensures that the cumulative effects of equipment out of service is maintained at appropriate levels. If an unplanned event renders additional systems or

7 Attachment 3 ST-HL-AE-5141 Page 10 of 17 equipment within the scope of the PSA inoperable, then a re-analysis of the condition may be required and a revised risk profile generated. If the revised risk profile indicates that a threshold has been or will be exceeded, then station management t would be notified and compensatory actions developed, as appropriate. After the unplanned event has been evaluated, additional information relative to returning equipment to service or revising the plant condition or configuration, if appropriate, may also be identified to operations personnel.

Q6. With regard to the three-train system at STP, please clarify if any one train is sufficient to mitigate the consequences of all design basis accidents (DBAs). If any one train is not sufficient for all DBAs, please identify the scenarios where one train would not be sufficient?

A6. Only one safety train being available to mitigate accident consequences has the potential to impact the following Design Basis Accidents:

A. Steam system piping failures (UFSAR Section 15.1.5)

B. Feedwater system pipe break (UFSAR Section 15.2.8)

C. Loss of Coolant accident (UFSAR Section 15.6.5)

Houston Lighting & Power has not performed analysis of these Design Basis Accident (DBA) events with only one safety train available. The following is discussion, based on engineering judgement, of these accidents assuming only one safety train is available. The discussion shows only a small population of LOCA events have an increase in consequences with only one safety train available.

STEAM SYSTEM PIPING FAILURES The Steam System Piping Failure (Steam Line Break) analysis assumes two safety trains actuate to demonstrate compliance with design and licensing limits. A reduction in the number of safety trains to one could potentially impact the following aspects of the analysis: Departure from Nucleate Boiling (DNB), containment structural integrity, and equipment qualification. The following is a discussion of each of these topics.

The analyses of record for the DNB evaluation assumes a double ended steam line break inside containment from zero power conditions. The safety injection system is used to mitigate the return to power and to prevent the fuel from experiencing DNB conditions for this scenario. With only one train of safety injection, the return to power would increase slightly above the level in the analysis of record, thereby decreasing the margin to DNB. However, the increase in power would also result in a slightly higher RCS pressure, increasing the margin to DNB. Based on these

.e Attachment 3 ST HL-AE-5141 Page 11 of 17 competing effects and available margin to DNB, HL&P believes that DNB would not occur with only one train of safety injection available.

The containment structural integrity analysis of record assumes a double ended steam line break inside containment from full power conditions. The containment spray system and Reactor Containment Fan Coolers (RCFCs) are used to maintain the containment pressure and temperature conditions within the design basis of the containment structure limits for this scenario. With only one train of containment spray and RCFCs, the ability to reduce containment pressure and temperature conditions is also reduced. A review of the analyses of record shows sufficient margin exists with only one safety train to ensure containment pressure and temperature stay .

below the containment structural integrity limits.

The equipment qualification analysis of record for the steam line break event assumes a spectrum of breaks from several power levels. Like the containment structural analysis, assuming only one safety train available will reduce the ability of the contaimnent spray and RCFCs to maintain pressure and temperature below the equipment qualification limits. However, a review of analysis of record shows suflicient margin exists to accommodate the increase in pressure and temperature.

Therefore, one safety train is sufficient to insure there is no increase in consequences of the steam line break accidents.

FEEDWATER SYSTEM PIPE BREAK STP has four Auxiliary Feedwater (AFW) trains feeding four steam generators. The !

actuation circuits for AFW Trains A and D are powered from Safety Train A. AFW Trains B and C are powered from Safety Train B and C respectively. The current analysis assumes Safety Train A fails, disabling the automatic actuation of AFW trains A and D. AFW Train D can still be actuated by operator action. Train B is assumed to fill steam generator B. Train C is assumed to feed the faulted steam generator and not provide any cooling of the Reactor Coolant System. The acceptance limit for this accident is the pressurizer does not go water solid within 30 minutes with no operator action.

i The results of the analyses would be impacted only if Safety Train C was the safety train being assumed available. Under this condition, the scenario would assume no AFW to the steam generators. This could decrease the time required for the pressurizer to go water solid to less than 30 minutes without operator action. ,

However, operators would have sufficient time to align AFW Train C to other steam i generators using the Emergency Operating Procedures. Therefore, operators actions would ensure no increase in consequences from this event.

~

Attachment 3 ST-HL-AE-5141 Page 12 of 17 LOSS OF COOLANT ACCIDENT The Loss of Coolant Accident addresses several aspects of plant design. Aspects which may be impacted by having only one safety train include: (1) compliance with 10CFR 50.46 requirements, (2) compliance with 10 CFR part 100 and General Design Criteria (GDC) 19 requirements, (3) containment structural requirements, and (4) equipment qualification. The following is a discussion of each of these topics.

The analysis of record demonstrating compliance with 10 CFR 50.46 requirements assumes a large break LOCA in a cold leg of the Reactor Coolant System. For this accident, one safety train fails to start, one train of safety iajection injects into the broken loop and into containment, and one train provides flow to the reactor core to mitigate the consequences of the event. One train of safety injection flow to the reactor core is sufficient to ensure 10 CFR 50.46 requirements are satisfied. For this scenario, the consequences of a LOCA would not be satisfied if the break was in the cold leg of the available safety train. A break in any other location would produce acceptable results. In addition, the reduction of SI flow associated with only one train of SI flow may also result in the 10 CFR 50.46 requirements being exceeded for a small spectrum of small break LOCAs.

The medium break LOCA, as defined in the PSA, requires two HHSI trains for successful mitigation of the accident. A medium break LOCA results from a pipe break in the range of 2 to 6 inches in diameter. For a very narrow range of breaks on the smaller range of the spectrum, it is assumed one HHSI pump may not be enough to keep up with the break flow and the RCS may not depressurize enough to reach the LHSI injection pressure. Therefore, the core could uncover without two trains of HilSI available and core damage could result. However, in that case, emergency operating procedures require the operator to depressurize the RCS to the LHSI injection pressure. This action will provide the makeup capability necessary to prevent core damage. For breaks on the larger end of the spectrum, the accident behaves much like a large break LOCA.

The analyses of record demonstrating compliance with 10 CFR part 100 and GDC 19 requirements assumes two trains of containment sprays for the removal of Iodine after a large break LOCA. Review of this design basis calculation shows these limits may be exceeded if only one train of containment spray was available. Houston Lighting &

Power has confidence that analyses performed with more realistic methods and assumptions would show a single train of containment spray is adequate.

The containment structural requirements analysis of record assumes two containment j sprays and three RCFCs actuate for this event. With only one safety train, the number !

.y. _ _ . _ _ _ _ _ _ _ - . _ . __ . .-__

Attachment 3 ST-HL-AE-5141 Page 13 of 17 of containment sprays and RCFCs is reduced to one. A review of the analysis of record shows sufficient margin exists to ensure the containment structure does not exceed its design parameters with only one safety train.

The equipment qualification analysis of record assumes two safety trains function to reduce containment pressure and temperature and equipment dose during a large break LOCA. A review of the analysis shows sufficient margin exists such that one safety train will ensure the equipment pressure and temperature qualification limits are not exceeded. A review of the equipment qualification dose limits shows these limits may be exceeded.

The ATWS event is modeled in the PSA as requiring two trains of AFW for secondary heat removal. Three of the trains (A, B, and C) are motor operated pump trains and one is a turbine driven pump train (D). The three motor driven pump trains receive an ESF signal to start from their respective safety trains, while AFW train D receives a start signal frorr. safety train A. STP has four trains of AFW, but loss of the A train ESF signal and either B or C train AFW pump could result in a failure to automatically start three trains of AFW. This loss of automatic start cap.ibility does not prevent the operator from starting the necessary AFW pumps.

Q7. Proposed LCO 3.10.8.a would extend the time constraint associated with not meeting the requirements of TS 3.8.1.1.d from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The bases section of TS 3.8.1.1 Action d states in part; "Provides assurance that a loss of offsite power, during the period that a diesel generator is inoperable, does not result in a complete loss of safety function of critical systems . . the completion time takes into account the capacity and capability of the remaining AC sources, and the low probability of a DBA occurring during the period."'

Provide an analysis of what safety functions could be lost during the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for in this proposed TS, and a justification showing why 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months should be permitted instead of the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowed for in TS 3.8.1.1.d if any safety functions could be lost.

Since this special test exception is only intended for planned maintenance, explain what types of actions, if any, would be preplanned for an anticipated loss of a safety function prior to entering this proposed LCO.

A7. Technical Specification 3.8.1.1.d allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of restoration time should a safety j component / function become inoperable in a safety train other than the one with a diesel inoperable. This action is to provide assurance that a loss of offsite power, during the period that a diesel is inoperable, does not result in a complete loss of ;

i I

i

Attachment 3 ST-HL-AE-5141 Page 14 of 17 safety function of critical systems. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration period takes into account the capacity and capability of the remaining AC sources, and the low probability of a DBA occurring during the period.

STP has a three train design for most safety functions, however, some safety components / functions have only a two train design and thos( that are important to prevent core damage are accounted for in the PSA. The following safety ,

components / functions, which the PSA considers important to prevent core damage, have a two train design and might not be available if a total LOSP occurred in .

combination with a failure of one of the remaining standby diesel generators and the '

emergency transformer during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period:

Charging Pumps -

There are two trains of charging pumps at STP powered by safety trains A and C. The charging pumps are high pressure pumps and are separate from the High Head Safety Injection (HHSI) pumps. The system is included in the PSA primarily because of its function to maintain the required water inventory in the RCS, RCP seal injection, and alternate pressurizer spray. However, the charging pumps are not an ECCS system.

The ability to maintain RCS inventory during an accident is primarily accomplished in the PSA through the isolation ofletdown line valves. Isolation of these valves is required when normal charging is lost to prevent an uncontrolled loss of RCS inventory. The letdown line has an air operated isolation valve which will fait closed on a loss of instrument air following a LOSP. The seal return line is discussed under containment isolation.

The charging system provides RCP seal injection to prevent an RCP seal LOCA. The seal injection function is backed up by seal cooling provided by CCW through the RCP thermal barrier and an alternate seal injection path using the PDP. This alternate method of seal injection is included in the EOPs and will be available during the STE. This is discussed further in the CCW section below.

The charging system also provides a backup function to normal pressurizer 1 spray. The PSA models this function for steam generator tube ruptures (SGTRs). A SGTR followed by a LOSP (or vice versa) is a low probability event as modeled in the PSA. l

. I P

a Attachment 3 ST-HL-AE-5141 Page 15 of 17 ,

Although the HHSI pumps have a lower shutoff head, the makeup function of the charging pumps is backed up by the liliSI pumps. '

Component Cooling Water -

The CCW system is a three train design; however, some CCW functions are provided by the common header while others are provide by the non-safety header. Both headers are fed by all three trains. The common header provides cooling flow to the spent fuel pool while the non-safety header provides cooling flow to the Boron Recycle Evaporator, the Letdown Heat Exchanger and other small non-essential loads. There are two isolation valves (MOVs) for each of these headers. One isolation valve on each header is powered by C train while the other is powered by A train on the non-safety header and by B l train on the common header. These valves are normally open and close on an !

ESF signal so adequate flow for accident conditions is assured to the required accident loads. Unless the operable train is C train, only one of these headers will isolate during a total LOSP without manual action. The Emergency Operating Procedures (EOPs) give guidance on when the header isolation valves must be restored to keep the spent fuel pool from boiling. Should only one train of CCW be available, the PSA conservatively assumes the failure of these valves to close when required could divert enough flow so other CCW accident loads may not receive the required flow. The PSA conservatively assumes this will effectively cause a loss of all three trains of CCW. However, an operator can be dispatched to manually close these valves. The systems dependent on CCW for cooling, as modeled in the PSA, are seal cooling for the Reactor Coolant Pump (RCP) using the thermal barriers, the Residual Heat Removal (RHR) system heat exchangers and pump motors, Reactor Containment Fan Coolers (RCFCs), and Charging (room and lube oil cooling).

The main short term effect oflosing CCW and mitigating an accident based on the dependencies mentioned above is the loss of seal cooling and normal injection to the RCPs which could result in an RCP seal LOCA. In the case of a loss of all RCP seal cooling and normal injection, STP has an alternate means of seal injection during a loss of offsite power with the Positive Displacement Pump (PDP) powered by the Technical Support Center (TSC) diesel generator.

The availability of this alternate method of seal injection is an LCO action in the STE.

l

I'l Attachment 3 ST-HL-AE-5141 Page 16 of 17 Containment Isolation -

Containment isolation of various systems is accomplished by two of the three safety trains. A loss of power to two trains will result in a loss of power to several systems as modeled in the PSA. Most of the systems modeled in the PSA for containment isolation including Supplemental Purge, the main potential air pathway, has an air operated valve associated with it which will be closed by ESF actuation or fail closed on a loss ofinstrument air. Two systems modeled in the PSA associated with containment radiation monitoring (safety trains A and B) and RCP seal return line (safety trains B and C) have MOVs for both the inboard and outboard isolation function. The lines associated with these pathways out of containment are small and manual isolation of these lines is provided in the EOPs.

Containment Spray -

The Containment Spray system is a three train design which does not impact core damage in the PSA; however, the current design bases analysis assumes two pumps are providing flow during a LOCA. While one pump will provide approximately 70% of design flow and approximately 75% of design pressure, the current model assumes 100% design flow for the dose analysis.

The following safety components / functions, which the PSA does not consider important to prevent core damage and which will not be required if core damage is prevented, have a two train design and might not be ~available if a total LOSP occurred during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period:

Ilydrogen Recombiners -

STP has two trains of hydrogen recombiners that are diesel backed (safety trains B and C) . Therefore, if one diesel was out of service and the other recombiner or its support systems became inoperable, a subsequent LOSP will cause a loss of this function. The recombiners are not modeled in the STP PSA and have no impact on core damage frequency. The PSA has also shown the Large Early Release Frequency for STP is small without taking credit for the hydrogen recombiners.

Fuel llandling Building Filtration System -

STP has two trains of fuel handling building filtration that are diesel backed (safety trains A and B) . Therefore, if one diesel was out of service and the other filter train or its support systems became inoperable, a subsequent LOSP

Attachment 3 ST-HL-AE-5141 Page 17 of 17 will cause a loss of this function. The fuel handling building filtration systems are not modeled in the STP PSA and have no impact on core damage frequency. Without core damage there will not be a significant source term requiring the operation of the filter trains. The PSA has also shown the Large Early Release Frequency for STP is small without taking credit for the fuel handling building filtration systems.

P Technical Specification 3.8.1.1.d is also based in part on the low probability of an accident during the allowed restoration time. The total LOSP event for STP has a probability of 2.lE-6 per hour based on the updated electric power analysis used for this proposed Technical Specification. Therefore, the probability of a total LOSP during a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period is 4.2E-6 while the probability of a total LOSP during a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is 5.0E-5. The increased probability to 5.0E-5 is low based on the small exposure period. Also, this value does not take into account the likelihood of recovering electric power or the additional subsequent failures on the remaining operable train that are necessary to have a core damage event.

Q8. The bases section of TS 3.10.8.a states in part that the purpose of this exception is to allow pre-planned testing and maintenance of the SDG and the essential cooling water, and to allow performance of surveillances prescribed in 4.8.1.1.2 in Modes 1,2,3 and

4. Ilowever, the staff does not allow certain SDG surveillances to be performed while in Modes 1,2,3 and 4. Please specify the surnillances you intend to perform during this special LCO. ,

A8. STP intends to take credit for the performance of the 18 month,5 year, and 10 year diesel maintenance inspections required by surveillance 4.8.1.1.2.e.1 and the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months diesel generator run required by surveillance 4.8.1.1.2.e.7. The justification for the 24 -

hour diesel generator run at power has already been submitted in letter :

ST-IIL-AE-5089 dated May 22,1995.

Q9. What is the accident mitigation capability if only one ECW train is operable?

A9. Please refer to Q6 for a bounding answer.

I L

ATTACHMENT 4 DIESEL GENERATOR MAINTENANCE SCOPE AND VENDOR REQUIREMENTS

.. . . - - - - ._ - - - - - . - .._ - . - - - = - . - .- - - - - - . .

ST-HIeAE-5141

. Attachment 4 Page 1 of 18 i

Table of contents for the 18 Month Surveillance procedure. j

1) Pre-outage checks include engine analysis (including compression checks), lube analysis and turbocharger l spin down time.

2) Perform engine upper and lower end boroscopic l inspection. ,

3) Inspect rocker arms and valve actuation train.

4) Visually inspect timing chains and sprockets and check chain tension. .

5) Visually inspect auxiliary chain and sprockets and ,

check chain tension. i

6) Check engine cam / valve timing. 3

7) Inspect camshaft lobes and crossheads.

8) Inspect vibration damper.

9) Inspect turbocharger, j

10) Inspect inlet butterfly valve. l f

11) Based on DP, replace main lube oil filters.

12) Based on DP replace Turbocharger lube oil filters.

13) Based on DP replace fuel oil filters. ;

14) Remove, inspect and clean fuel oil strainers. ,

15) Functionally test connecting rod bearing temperature i detectors.

16) Remove and inspect all fuel injector nozzles. Pop and spray test as necessary.

17) Test engine overspeed trip. ,

18) Internal and external visual inspection of the [

generator. :

19) Verify tightness of generator terminal connections.

20) Clean generator windings.

21) Verify generator air gaps. j

22) Inspect collector ring (slip ring) and brushes.

t i

5

-n -

a

'- ST-HL-AE-5141

" Attachment 4 Page 2 of 18 Table of Contents for the 18 Month surveillance procedure (continued).

23) Measure generator insulation resistance

24) Calibrate generator differential protective relay.

25) Inspect and test Jacket Water Pump Motor.

26) Inspect and test lube oil pump motor >

27) Test / calibrate lube oil pressure trip switches.

Typically, we also take this opportunity to inspect our coolers / heat exchangers, perform adjustments as identified by engine analysis and surveillance inspections (i.e. fuel racks, governor linkage, both fuel and valve timing, etc.)

and perform ASME Section XI tests and/or inspections.

=

- ST-HL-AE-5141

AttachTent 4 Page 3 of 18 SOUTil TEXAS PROJECT ELECTRIC GENERATING STATION D0527

m. 2 p,,,,,,,

._.s_.

~ n -. -

z '- OPSP04-DG-0002 General Standby Diesel Generator 5 Year Inspection Quality Safety-Related Usage: IN IIAND Effective Date: 02/27/95 Gary Ent Harvey Wright Maintenance tee orifria PREPARER TECHNICAL USER COGNIZANr ORGANIZATION Pace Tabie of Contents

.... . ............. .. . ....... ........ 3

1.0 Purpose and Scope

3 2.0 Definitions . . . . . . ...... ......... . ... .. . .. .. ... .. .

. ... ... 3 3.0 Responsibilities . . . . . . . . .. ..... .............. . . ...

.. 4 4.0 Prerequisites . . ... . . .. ... . . . .. .. .

... .. .. . 6 5.0 Precautions ... . .. .. .... .. . . .......

... .. .. . .. . 7 6.0 Procedure ....... .. .. . .. .. . ..

7 6.1 Air Intercoolers . . . . . . . . . . . . . . . ......... . ........ .... ..

Fuel lnjection Pumps . . . . . . . . . . . . . . .... ........... ...... ..... 7 6.2 7

6.3 Engine Driven Water Pump . . . . . . . . . . . . . . . . . .... . ........ ..

Engine Driven Lube Oil Pump . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 6.4 Engine Driven Fuel Oil Booster Pump . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 6.5 Lube Oil Cooler Inspection ................. ............ .... ... 8 6.6 Jacket Water Cooler Inspection . . . . . . . . . .. .................... ... 11 6.7 15 6.8 Standby Diesel Non-metallic Flexible Hose Replacement ...... .... ......

6.9 Engine Main and Outboard Bearing Temperature Detector Fuse Rod 16 Replace ment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6.10 Engine Connecting Rod Bearing Temperature Detector Fuse Rod Replacement ... 17 6.11 Lube Oil AMOT Valve Thermostatic Element Replacement . . . . . . . . . . . . . . . . . 21 6.12 Jacket Water AMOT Valve Thermostatic Element Replacement . . . . . . . . . . . . . . 23 6.13 Perform Engine Overspeed Governor Oil Change and Trip Test . . . . . . . . . . . . . . 24 6.14 Perform Stand by Diesel Generator 18 month inspecdon. . . . . . . . . . . . . . . . . . . . 24 24 7.0 Acceptance Criteri a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

24 8.0 References . . . . . ..................... ...... ...... ... .... ...

ST-lUeAE-5141 Attachment 4 Page 4 of 18 SOUTil TEXAS PROJECT ELECTRIC GENERATING STATION D0527

m. 2

__ ._ .w F "

0 PSP 04-DG-0003 General y,,,,,,,,,

Standby Diesel Generator 10 Year Inspection Quality Safety-Related Usage: IN IIAND Effective Date: 02/27/95 tec Griffin Gary Hunt Harvey Wright Maintenance PREPARER TECHNICAL USER COGN!ZANT oRG ANIZATioN Table of Contents -

Pane

1.0 Purpose and Scope

. . . . . . . . . . . . . . . . . . .. . . . ................ . ... 3 2.0 Definitions . . . . . . . . . . . . . . ...... .. ...... .............. ... 3 3.0 Responsibilities . . . . . . . .... ....... . ........ ........ .... .. . 3 4.0 Prerequisites .... ... . ... .. . ..... . . . . . . 4 5.0 Precautions and Notes ... ... . . . .. .. . . ....... 9 6.0 Procedure . .... ... ... ..... .... ... . .... .. 10 6.1 Remove Cylinder Head . . . ....... . ...... .... .......... . 10 6.2 Disassemble Cylinder Head . . . . . . .. ... ... . . ..... .. . . 13 6.3 Remove Articulated Rod Piston ..... ...... . ............ ...... 14 6.4 Remove Master Rod Piston ......................................16 6.5 Remove Piston Pins From Both Pistons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 6.6 Remove Connecting Rod Bearing Shells ....... .. . ........ ........ 19 6.7 Remove Main Bearings . . . . . . . . . . . . . . . . . . . . . . . ............ . . 24 6.8 Remove Generator Outboard Dearing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 6.9 Clean and Inspect Cylinder Heads . . . . . . . . . .. ................. .... 27 6.10 Clean and Inspect Pistons and Cylinder Liners . . . . . . . . . . . . . . . . . . . . . . . . . . 32 6.11 Clean and Inspect Articulated Rod, Bushing and Pin . . . . . . . . . . . . . . . . . . . . . . 37 6.12 Clean and Inspect Master Rod . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 6.13 Clean and Inspect Main and Connecting Rod Bearings ....... ............ 39 6.14 Clean and Inspect Generator Outboard Bearing . . . . . . . . . . . . . . . . . . . . . . . . . . 40 6.15 Install Generator Outboard Bearing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 6.16 Install Main B earings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 6.17 Install Connecting Rod Bearings . . . . . .............................. 46 6.18 Engine Checks After Main and Connecting Rod Bearing Replacement ......... 48 6.19 Install Articulated Rod with Piston . . . . . .. ... ....... ......... ... 56 6.20 Install Master Rod Piston . . ......... ...... .. ...... .. ... . 58 6.21 Assemble Cylinder Head . . . . . . 59 6.22 Install Cylinder Head . . . . . . 60 6.23 Restoration . . . . 64

4 ST-HL-AE-5141 o Attachment 4

COOPER-BESSEMER KSV TECliNICAL MANU AL W f 18 FOR NUCLEAR STANDBY APPLICATIONS SECTION 15 RELIABILITY CHECKING AND MAINTENANCE INSPECTION i

15-3 introduction . . . ........................... ...............

Pre-Periodic Tests or Engine Standby Checks . . ' . . . . . . . . . . . . . . . .

15-3 Periodic Test Runs - Once Per Month Minimum . . . . . . . . . . . . . . . . . . . 15 4 Post-Periodic Tests - All Test Runs ..... .... . ....... ...... 15-4 Lube Oil Sampling - Monthly / Quarterly . . . . . . . . . , . . . . . . . . . . . . . 15 4 Annual or Refueling Outage lnspections . . . . . . . . . . . . . . . . .. 15-5 Five Year or 3rd Refueling Outage inspections . . . . ... . . 15-7 Ten Year or 6th Refueling Outage Inspections . . . . 15-8 APPENDIX A - EMERGENCY DIESEL GENERATOR PERFORM ANCE MONITORING RECOMMENDATIONS APPENDIX B -RECOMMENDED RUNNING TIMES AND LOADING RATES - BREAKIN AND TESTING NOTE: This section contains recommendations for maintenance and inspection of KSV engines in Nuclear Standby applications when an adequate system for monitoring and trending the health of the engines has been implemented. Without such a system the recommendations in Section 15 of the originalissue of the Operating and Maintenance manual should be followed.

A AO JTENDIX C - REPAIR INSTRUCTIONS FOR IIEAT EXCIIANGERS ^ @ ]

D uJ MM . tst, z l

APPENDIX D - SPECIAL DATA N SDG # 12

- SDDc, Ofn Idn U b ??ENbTK E-S% cvacaven ccerme.ssroa nessure rasnaa

( sca / uv- /3/2 . 59 i isani-692 jac A

Y'.:. .

._ ~ .- . _ . .

ST-HL-AE-5141

' Attachment 4 t.UUrtK-liESSEMER KSV TECllNICAL MANUAL Page 6 of 18 FOR NUCLEAR STANDBY APPLICATIONS SECTION 15 RELIABILITY CHECKING AND MAINTENANCE INSPECTION

(

1. Check, Measure or Verify - read the parameter and Introduction compare the indicated value with an exisdng parame.

- 1. Ii*i'*

The purpose for Reliability Checking and Maintenance is to assure that the diesel generator will always start and 2. Inspect - observe the condidon and make an asses.

load upon demand, and in accordance with appropriate sment of the acceptability of that condidon.

specificadons. It is presumed that periodic test runs will

3. Analyze.-reviewdataaboutaparameterorcondition be made consistent with applicable

Regulatory Agency.

to determme the acceptability to a parameter limit or requirements.

condition.

Design of the diesel generator unit permits its operadon 1. Log - record and/or use an electronic recording de-regardless of the status of the nuclear power plant. It vice m obtairi operadng parameter informadon for should not be run with jumpers or any other form of by-later trending or evaluadon.

pass around any part of the control system.

5. Trend-reviewloggedoperadngparameters. normal. i Whenever an engine is running and loaded, a complete h ploued fa case ohniew.

log of operating parametas should be made at least once every two hours. and trended or checked by personnet re- 6. Evaluate - make an assessment of engine pert'omt.

sponsible for plantoperation and maintenance. Any devi- ance based on a review of one or more operadng pa.

adon from parameter limits listed in Secdon 2. General rameters or conditions.

Data should be immediately reconciled. Regardless of other evaluadons, a review of diesel generator logs or Pre-Periodic Tests or Engine Standby Checks trending data should be made in order to recognize deteri-orating trends.

To assure start up when the diesel generator is in standby A log taken with the diesel generator running partially mode, the following checks should be performed:

loaded and not up to operating temperatures can provide I. Verify pr per operadon of the tube o.li c.treulating a verymisleadingsetofdata.Inorder,therefore.forvalid pump. Lube oil circuladng pump operadon can re.

riata to be acquired, the unit should be running at rated duce engine wear during start up by ensuring engine load and stabilized at normal operadng temperatures be-bearings are welllubncated.

fore making a log of running conditions.

2. Verifyproperoperadonofthejacketwatercirculating Accurate records should be kept of all items that have re.

pumpJacket watu circuladon can help reduce en.

quired anention so that historical evidence may be used gine wear during start up by maintaining an evenly to consolidate future prevendve maintenance programs.

heated engine while in standby condidon.

For the sake of alternadng annual inspecdons of muldple

3. erifypr puoperad nofthg. ac ketwadeanaM unit installadons,it is suggested that the *first year" range the tube oil heater. These heaters maintain the engine from twelve to eighteen months. Thereafter, mspeedons at an etwated tempaawe e assist m case d stamng should be scheduled on an annual or refueling outage ba-the diesel engine in the event of an ernugency.

sis as required by the plant's Technical Specificadons.

When carrying out the " Annual Five Year and Ten Year '"'* '"" '"" *"I

Inspections,"it is rectemmended that the services of qual-ns obsened.

ilied C-B representatives be used under contract. Such an arrangement provides access to the manufacturer's 5. Check for signs of external water, fuel oil, tube oil, collective experience, ensures condnuity for the purpose and air leaks.This inspecdon can provide an early in-of updanng procedures in conjunction with design phi- dicadon of potential engine problems.

I y, and will generally expedite the various inspec- , gy, ing governor sight glass and the overspeed governor The commonly used action verbs in this section are de- to ensure it is at the required oil level. Check the oil fined as follows: level in the generator outboard bearing.

, 60 15RR f-&92 de. DCAl d W M

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Page 15 4 COOPER-BESSEMER KSV *mCHNICAL MANU AL Page 7 cif 18 FOR NUCLEAR STANDBY APPLICATIONS !

SECTION 15 RELIABILITY CHECKING AND MAINTENANCE INSPECTION i.

5. Check for signs of external water. (uel oil. lube od.

7. Repair and/or correct any significant leaks or other and air leaks.This inspeedon can provide an early in.

anomatics at the first opportunity.For exampic if a dicadon of potential engine problems.

Jacket water leak is noted between acylinder head and the block.that head should be ternoved and the source 6. As applicable. check the oillevel in the speed regulat-of the leak idendfied and repaired. Always tristall ing govemor sight glass and over speed govemor to ;

insum itis at the rgired level.

new gum and water seats when remsta!!ing the .

head. :

Lube Oil Sampling - Once Per Quarter !

Minimum Periodic Test Runs-Once Per Month Minimum !

Obtain a representadve engine tube oil sample from a

1. Startandloadthedieselgeneratorinaccordancewith **een the discharge of tube oil pump and

"E "

poortode tu oile oluandMu. AnalyzedeM the stadon procedures. (Note the recommended start and load rates for monthly survei!!ance runs are con. *"P *I I C l tainedin Appendix B.) f v S# *i'Y

2. 1.og engine operadng parameters in accordance with stadonoperatingprocedures. Appendix A.Emergen.

Dirt i

cy Diesel Generator Performance Monitoring Rec-ommendadons contains a list of engine performance Water parameters and the recommended periodicity for -

Wear metais rnonitoring.

Acidity

1. Check for signs of extemal water, fuel oil lube oil.

and air leaks during engine operation. This inspection A firm that analyzes oil will recommend when any of the l can provide an early mdicauon of potential engine above condidons are cause for draining and replacing the r problems. oil. General guidance for the above condidons are as fol-30

5: '

4. Check for excessive sparking of generator brushes. if Viscosity -Lube oit viscosity changes can result from ex-applicab!c. Follow generator manufacturer's mainte.

tended operation and from fueloil diludon (numerous nance guidance if brush sparking is excessive.

- - '**' I**ki" EI "I'#I #3' #'I' *

5. Unload and stop the diesel generator in accordance Dirt- Excessive dirt in the lobe oil may result from inade.

with station procedures. (Note the recommended en. quate fiher maintenance and must be climinated by sine shutdown instructions for monthly survei!!ance changing oil and filten (oil and air) more frequently. !

runs arecontainedin Appendix B.)

Water-Excessive water in the lubc oil normally indicates f a leak between the two systems in a cooler or in the e n. ;

Post-Periodic Tests- AllTest Runs gine. Another source of water may be condensation ;

of combustion products when the engine is not al- -

1. Verify proper operation of the tube oil circulating lowed to fully warm up,i.e. run for short periods of I f

pump following engine shutdown. Verify pressure is time' within normallimits, Wear metals - Changes in wear metal levels must be ,

checked to determine where in the engine they origi.

2. For KSV-2(Tr engines, verify that the turbo lube oil nated and that area must be inspected for wear.

pressure is normal.

Acidity - Changes in tube oil acid level develop from !

3. For KSV-16T engines, within 15 minutes after en. long and severe service and/or operating with high !

gine shutdown, verify turbo lube oil pressure is zero. sulphur oil. In addition, numerous engine starts and ,

stops without suf ficient warmup can introduce mois-

4. Check the jacket water stand pipe and tube oil sump ture and acids into the tube oil.

for proper levels.

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~ Page 8 of 18 FOR NUCLEAR STANDBY APPLICATIONS SECTION 15 RELIABILITY CHECKING AND MAINTT! NANCE INSPECTION Note that combusdon balance and timing can also be Poor lobe oil quajity can lead to serious problems with the influenced by many other factors which may require ene,ine performance and wear. Comparison with pre-vious analyses should indicate changes in engine condi- invesdgadon.

tions that would lead to deterioration of the oil. 6. Use a modem, high resoludon borescope inserted f

through the fuel injecdon nozzle opening to inspect th* I"t*'i ' I *!! P **' *Y "d*'5 li (i"*1"d* li"*'5- i Annual or Refuelin Outage Inspections heads, piston erowns, valves and seats.ctc.).With the

...),d o (See. 5e.cvic.c.hll 6 % H ~P%e. str pistons at BDC, inspect the liner for excessive wear (e.g. scuffing. scoring, cracking) or other signs of de-An annual or refueling outage inspecdon wit! likely fol. terioradon, he intake, cxhaust and start air valves low one of the"PeriodicTestRuns" noted above. There. should be checked for signs of cracking or wear. Ifin-fore, complete all the required checks or inspections dicadons of a problem are observed, remove the pow.

above, as wc!! as the following inspecdons:

Pc4% W p i u. *R'. 'Io .l.p A s4. A3. u .4 9, erthecylinder head and perform a detailed inspeedon of head, piston and liner. The fast starts and rapid f 1. Withenginerunninganduptooperaungtemperatures loading common with emergency diesel generators and the generator at rated load.use an engine analyzer may cause more rapid cylinder wear than occurs in (such as the Cooper-Bessemer EN-SPEC 3000) to engines in other applicadons.

measure and record parameters such as combusdon pressure / time diagrams, horsepower, peak pressure 7. If the borescope inspections and engine analyzer re-angle, etc. for each power cylinder. Engine analysis suits indicate the need, remove affected cylinder should not be performed until at least one hour of heads and check their condidon. lf required, rescat all rated load operadon has been completed and engine valves. Excessive seat wear can cause poor engine

operating parameters have stabilized. Analyze re- performance. Refer to Seedon 2 for acceptance crite-cords for possible unusual engine running condidons ria. Replace head gaskets and"O"-ring seals for the and take appropriate remedial action. Jacket water connecdons on any cylinder heads re-m ved for any reason.

I

2. Measure power cylinder compression pressures.

8. Inspect the following inside the engine crankcase:

3. Unloadtheengineforanormalcool-down. Measure a. Cylinder liners for scuffing, with the pistons near and record turbocharger spin down time following g compledonof the engine run. b. Expansion seal at bottom of liner for water leaks.

4. Insureallfoundadonboltsinengineandgeneratorare dents or cracks. '

correctly tightened. If bolts are found loose or abnor- c. Visible portions of the piston skirt for abnormal mal conditions identified, evaluate the need to per- wear of the nn surfaces, with the pistons near form a crankcase web deflection inspection. BDC. ,

d. Bolts and locking devices for tightness.

5. Remove all fuelinjection nozzles. If the engine ana.

tyzer results indicate out of balance cembustion pres. %e inspections should check for excessive wear sure or dming conditions (see Secdon 2, General Data (e.g scuftmg, scoring. cracking)orothersignsorde.

for combustion pressure Itmits), or the nozzle tips ap- terioration.

pear unusual in any way, check opening pressure and 9. Replace fuel oilfilter elementsif trending of filter dif-spray panern on a test stand. Proper injector nozzle ferential pressure at rated engine load indicates this is operation is essential to good engine performance. necessary.The fuel oil filter traps pardcles that could The nonle openmg pressure should be 3400 psig, cl E the fuel pumps and fuelinjectors.

minimum. The spray pauern should be fully atom.

ized into a uniform mist " plume" and all nine spray 10. Inspect tube oil strainers for dirt and metal pardcles, The lubc oil stainers prevent foreign pardcles.such as holes should be clear. The cone angle of all the pipe scale or a ruptured oil filter.from entering the en.

plumes should appear uniform and be approximately gine. Foreign particles should be removed from the 140 degrees. No secondary injections or nozzle pops strainer and analyzed to determine their source.

in the plume should be observed, ,

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. Attachment 4 Page 15-6 COOPER-BESSEMER KSV TECliNICAL MANU AL P 8 FOR NUCLEAR STANDDY APPLICATIONS SECTION 15 RELIABILITY CHECKING AND MAINTENANCE INSPECTION

a. Check blower bearing, w hich includes the thrust

11. Replace elements in tube oil filter. The tube oil filter bearing, for wear, prevents contaminants from being distributed throughout the engine and causing wear to vital pans.

12. Inspect crankcase breather air filters and cylinder c. Checka!!bearingclearances*

head breather filter (if used) and clean as newy d. Clean turbine rotor and diffuser, Inspect and clean individual breathers in each cylin.

der head cover (if used). 21. Inspect att mlet system (filters, duedng, etc.) for evs..

dence of dirt or debris and clean as necessary. Air fil.

13. Inspect rocker arm assemblies (without disassem. ten ensure adequare supply of clean combusdon air.

bly). Visually inspect for excessive wear or dusdng of metal around the shaftbushings. Check clearances ,,

~~ *

""**"*#Y .*'"

if wear is evident. Inspect tube oilcrossover lines for

a. Condition of gears, drive chains and roller bear.

signs of freuing or cracking and replace as necessary. ings for the jacket water pump and tube oil purnp.

14. Check operadon and/or calibraion of a!! control and inspect for wear and proper adjustrnent. Check safety shutdown devices. Refer to Secdon 9 and Sec. drive chain for proper tensioning. (Refer to C-B tion 16 for guidance. Inspect control air tubing for in' Engineering Standard SD-65-3 in Appendix 1.)

dications of cracks or leaks. Rep!xe gaskets and b. Condidon of vibradon damper (if applicable).

-O"-rings as necessary Check moundng bolts for adequate torque.

15. Change the tube oilin the speed regulating govemor "The forward end auxiliary drive provides power for and the over speed governor,if applicable. Ittsure that the jacket water and t ube oil pumps. Inspect for visual any air is b!cd from the govemors and that the oi!leve evidence of wear or darnage.

is corTect when the engine is first staned. Refer to Governor manual. 23 Inspect flywheel end main drive foc

16. Check valve timing and tappet clearance on at least a. Condition of drive gears, chains and sprockets.

one cylinder per bank to ensure proper engine com. Inspect for wear and proper adjustrncnt. Check bustion. Refer to Section 2, General Data for timing drive chain for proper tensioning. (Refer to C-B and cicarance requirements. It may be necessary to Engineering Standard SD-65-3 in Appendix 1.)

check timing on additional cylinders if the cornbus. b. Condidon ofidler gear bearing and end play. In-tion analysisiudicates problems. spect for wear and sufficient lubricant.

17. Inspect fuel pum p and val ve cam lobes for indicadons c. Condition of camshaft gears. Inspect for m. dica.

of wear grooving.orloosenesson the shaft. Inspect dons of excessive wear, backlash, slippage,etc.

the fuel pump cam rollers for wear or degradation.

d. Condition of turning gear. inspect for cleanliness,

18. Remove the combustion airintet pips from the turbo- tubricadon, proper tood engagemem &

charger. Inspect and record the turbocharger thrust chipped teeth.

bearingclearance (.005 to .022),

Visually examine the compressor Repair or replace any defective parts as necessary, wheel for damage or excessive deposits. Examine the DANGER! WIIENEVER %,ORKING ON turbine wheel for damage, using a boroscope.

TIIE GENERATOR MAKE SURE TIIAT

19. Check turbocharger rotor for freedom to turn. This IT IS STATIONARY AND ALL WIND-don r ttheturbociwgeris freetospin INGS ARE DEENERGIZED. FAILURE TO COMPLY MAY RESULT IN INJURY

20. Disassemble the turbocharger if the turbocimger spin OR DEATil.

down time test results or the inspections listed above indicate there is a defect that could affect engine per- 24. Check the tightness of the terminal connections on formance. (Refer to Turtwharger Manual). generator.

) - 63 15RRI-6/92

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ST-IIL-AE-5141

CUU1'hK-t3ESdtMEK AS V i tL11NICAL M ANU AL Attachmerit 4 P ge 10 of 18 FOR NUCLEAR STANDBY APPLICATIONS SECTION 15 RELIABILITY CllECFING AND MAINTENANCE INSPECTION t

25. Measure and trend generator winding insuladon re- tion to those recommended in"Annu.a! or Refueling Out.

sistance (IR) measurements to ground using a Meg age inspecdons" secdon above.

ohmmeter. Follow generator manufacturer's guid- 1. If logged data indicates excessively high pressure ance on sneasurement method and minimum accept- .

dropona.ir side or other perfomunce deficiencies.re.

able IR values. move air intercoolers and thoroughly clean.His en-sures an adcouate supply of combusdon air. SEE

26. Clean insulated generator windings by blowing out with dry air. brushing (soft brush), wiping, vacuum , PAGc. 2.S9 FOR REPAIR INSTRUCTIONS.

11 tne engine analyzer test results indicate the need.

cleaning or any method described .in the generator MiWM inW pg on a mM manufacturer's manual. Observe a!! relevant safety .

3. When engine operadon indicates a degradadon in precauuons.

pump performance or there is other evideree (if detc-

27. Measure and record generator rotor to sutor air gap riaration.disassembleenginedrivenwaterpumps in- l st four locadons,90 degrees apart.on both ends of the spect mechanical seals and replace if nemury. Re-rotor (see generator instructiori manual). Reahgn if place all*"O"- rings and gaskets.and inspectimpetter

""'Y rings for wear.

28. Inspect generator outboard beanng for signs of exter. J. When engine operation indicates a degrausdon in nal oilleaks. pert'ormance,or there is other evidence of deteriora-tion of the engine driven tube oil pump. disassemble,

29. Clean air intet casing to generator sutor.

clean inspect and repair as needed.

30. Inspect all electric motors in accordance with the ven. 5. Basedontheresultsof enginemon.itoring data trend- p dor recommendadons. Repair as necessary. d ing, inspect lubricating oil and jacket water coolers.

check for leaks and repair as necessarv. SEE Os 3LPrior to running engine and after its systems have PAGE 2.54 : FOR REPAIR INSTRUCTIONS Wg ,

been Elled with oil and water,open indicator cocks on 6. r(eptace non-metallic flexible hoses, especially the y all power cylinder heads. Ensure the engine tube oil circuladng purnp is operadng. Roll the engine internal tube oil hoses and the start air valve hoses. s.g through at least two complete turns. Check for mois. 7. Based on trending of fuel oil booster pump perform- -

arec results.or other indicadons of dcterioration. dis-nq!

ture atindacator cocks. If moisture is found. invesd.

g2te cause and remedy. assemble, clean, inspect, and repair as n-ry D'

8. Replace main and connecting rod bearing tempera- @> I2

32. E,nsure the lubc oil circuladng pump,thc lubc oil heat.

er,the jacket water circuladng pump and jxket water ture cutecuc devices. Clean the trip valves and re- gg 6

heater are in operadon, place the "O"- rings.4 41e-

9. Check vibradon readings, motor current, and per-

33. Start engine and apply toad gradually undl oit and wa.

ter temperatures stabilize at their normal operadng formance data on the motor driven pumps installed on the auxiliary skid, and analyze results to determine u} g values. Run in accordance with Appendix B follow.

ing inspection. (When major engine components the need for repairs. Recondidon the pumps or motors t.c){

R3S as necessary have been repla;cd, note the recommended break-in run instrucdons contained in Appendix B.) 10. Inspect the generator. De following is intended as a D

guide and to highlight various areas. Refer to the gen. .g ,

34.Use an engine analyzer to measure and record com.

bustion parameters for each power cylinder. as in ste p erator manufacturer's instruedons for specific de. Ht t Lail8-

1. Analyze records for possible unusual engine run.

ning condidons and take appropriate remedial action. a. Inspect collector ring and commutator surfaces and commutator. Brushes shall move freely in .

their brush boxes. Replace worn brushes. Clean Five Year or 3rd Refueling Outage Inspections i collector rings, commutator, brushes and brush rigging by wiping with a clean. dry lint-free cloth, Every five years or during every 3rd refuehng outage.the following mspect ons should be accomphshed in adds- b. Check rotor pole bolts (or keys) for oghtness.

c pcept- ,

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O ST-Iff.-AE-5141 1;ttach mnt 4 Page 15 COOPER-BESSEMER KSV TECHNICAL MANU AL Page 11 of 18 FOR NUCLEAR STANDBY APPLICATIONS SECTION 15 RELIABILITY CHECKING AND MAINTENANCE INSPECTION

1. Remove fourcylinder heads. inspect valves and seats.

c. Measure and uend insulation resistance of wind-and recondidon as necessary. Replace a!! gaskets and ings to ground using a Meg ohmmeter. Repair in acrordance with generator manufacturers specifi- "O"-rings. Anyheadwhichwasremovedandrecon-cadons, didoned during the two year period immediately be-fore this inspection should not be selected for removal

d. Inspect generator frame and all fasteners for un- unless there are indicadons of a problem with that usual signs of distress. cylinder. Eva!nate the need to remove addidonal heads based es mi.s examinadon.

e. Whenreassemblinganypartof thegenerator,en-sure that any insuladon provided to prevent stray 2. Remove four p'istons and inspect piston, piston rings, shaft currents is correctly installed- piston pin and bushing. aniculated pin and bushing, and liner c ndid n. Determine from such an inspec-

f. Inspectexciterinaccordancewithmanufacturer's tion the extent to which odier pistons should be re-

g moved and any necessary rework accomplished.

11. Check mechanical condidon of all switch gear and re- 3. Remove connecdng rod bearings from rods attached lays. Follow the respeedve manufacturer s mstruc- to pistons removed per paragraph 2 and irtspect. De-t for cleaning relay contacts and other mainte- termine from the inspecdon the extent to which other

rod bearings should be removed and any necessary re-work accomplished. Do not reinstall any bearing

12. Replace the thermostade elements in the jacket water Shells removed from the rods for this inspection. Re-and tube oil temperature conuel valves on the auxilia.

place them with new shells.

ry skid.

A Remove two main Wngs at mdom aM insm

13. Replace 2301 Govemor dropping resistor. Determine from the inspection the extent to which other main bearings should be removed and any nec-4 Ten Year or 6th Refueling Outage Inspections essary rework accomplished. Replace any bearing shells which are removed with new she!!s.

Every ten years or during every 6th refueling outage, the 5. Inspect generator outboard bearing and repair as nec-following inspections should be accomplished in addi- essary. Insure that the insuladon resistance between tion to those recommended in"Five Year or 3rd Refueling the bearing and its support is maintained after reas.

Outage Inspecdons" secdon above. sembly.

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Attach: Tent 4

Pace 12 of 18

~

EMERGENCY DIESEL GENERATOR PERFORMANCE MONITORING RECOMMENDATIONS e

'?PPEND1 k A "

PERIODICITY l PARAM5TSR TO BE MONITORED ENGINT:

MONTHLY Cylinder Exhaust Gas Temperatures (*E)

ANNUALLY / REFUELING Cylinder Peak Firing Pressures (psig) & Angles (*ATDC)

MONT11LY Stan Time (Seconds)

MONDILY Crankcase Pressure (~ Hf))

LUBE OIL SYSTEM:

Main Lube Oil Pressure (psig)

MONTHLY Turbo Lube OilPressure (psig) MONTHLY Main Full Row Oil Filter Delta-P (psig) MONTHLY Turto Oil Filter Delta-P (psig) MONTHLY MONTHLY Engine Oilinlet temperature (*E)

MONTHLY Engine Oil OutletTempe: autre (aE)

LubeOil Analysis QUARTERLY FUEL OIL SYSTEM:

FuelOil Pressure (psig) MONTHLY Fuel 011 Filter Delta-P (psig) MONTHLY FuelOilStrainer Delta-P (psig) MONTHLY Fuel oilTransfer Pump Flow (gpm) QUARTERLY FuelOil Analysis QUARTERLY JACKET WATER SYSTEM:

1xtet Water Pump Discharge Pressure (psig)

MONTHLY 3xtet Water Engine Inlet Temperature ('E)

MONTHLY MONTHLY 1xtetWater Engine OutletTemperature ('E) 1xtet Water Analysis QUARTERLY

)

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3 ST-HL-AE-5141 Attachm2nt 4 rage A-[ .s.u..w. '*

Page 13 of'18 EMERGLNCY DIESEL GENERATOR PERFORMANCE MONTTORING RECOMMENDATIONS PERIODICITY PARAMETER TO BE MONITORED

-(

AIR INTAKE & EXIIAUST SYSTEM:

MONT11LY TurW gerExhaustInletTemperature ('E)

MONTHLY Turbocharger Exhaust OutletTemperamre ( E)

MONTTILY Turbocharger Air Discharge Temperature ('E)

MONTHLY Intale ManifoldTemprature ('E)

MONTHLY Turbocharger Air Discharge Pressure (* Hg)

MONTHLY Intake Manifold Pressure (RAL) (* Hg)

REFUELING Turhrhrger Spin Down Time (seconds)

MONTHLY Outside AirTempmmre ('E)

SERVICE WATER SYS1 tim:

MONTHLY Intenooler Water inletTemprature (*E)

MONTl!LY Intercooler Water Outlet Temperature (cr.)

MONTHLY

" -rviceWaterInletTemperature ('E)

MONTHLY Service Water Outlet Tempermure(s) ( E)

ELECTRICAL (GENERATOR, EXCITER, VOLTAGE REGULATOR):

MONTHLY Kilowatts MONTHLY Kilovars MONTHLY Volts MONTHLY Generator Current (Amps)

MONT11LY Generator Stator Temperature ('E)

VIBRATION MONITORING:

P REFUELING Skid Mounted Pump / Motor Vibrations MISCELLANEOUS:

NOTEI Engine Run Hours ,

NOTE 1 Number of Engine Starts _

( ; Parameter not measured as such ; maintain as part of engine start /run records.

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ST-IDeAE-5141 Page 14 of 18 ,

START /STOP/ LOAD APPLICATION PROCEDURE FOR NUCLEAR POWER PLANT EMERGENCY POWER STAND-BY ^ es t

APPENDixB in order to insure optimum engine life and reliability, it is important to operate an engine, whenever possible,in a manner to allow for gradual temperature increase and stabilization. This is espe of concern in nuclear stand-by service where the ratio of engine starts to total operating hours is very ;

high.

The following recommendations are provided at guidlines for operating / loading KSV engines used in nuclear emergency power stand-by duty.

MONTHLY SURVETT LANCE RUNS It is assumed that the numerous surveillance tests that have been run at the various ul past years have demonstrated the capability of a diesel en gine ( in particular the KSV/ generator ;

tem to respond to an emergency. Herefore it should not be necessary to conduct fast start-fast load tests at each monthly surveillance. Whenever possible, a gradual load application as prescribed by the following schedule is recommended:

% LOAD DURATION RPM 0 15 MINUTES ,

600 25 30 MINUTES 600 30 MINUTES 600 50 75 30 MINUTES 600 100 120 MINUTES 600 .

15 MINUTES 600 unloaded In order to enhance the long termlife/ reliability of the engine, itis advisable to operate long enough to acheive thermal stability within the engine. For this reason, Cooper-Bessemer recommends that a loaded engine run should not be less than four hours in duration.

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START /STOP/ LOAD APPLICATION PROCEDURE FOR !

NUCLEAR POWER PLANT EMERGENCY POWER STAND-BY }

l l

g JREAK-IN RUNS :

Whenever major engine components (pistons, piston rings, liners, beadngs & bushings) are re-placed,it is recommended that a slightly different procedure be followed to verify that th is operating properly. ' Die following loading schedule should be udlized at these times:

- Start engine. ,

- Run 15 minutes at 600 RPM, no load.

- Stop engine, remove crankcase doors and visually inspect. Look for any signs of abnor ties. Bearing caps should be " felt" to identify any bearings that are significantly hotter than :

the rest.

- Restart engine and load according to the following schedule:

1

% LOAD DURATION "

RPM 0 1 HOUR * ,

f 600 2 HOURS 600 25 2 HOURS 600 50 i

75 2 HOURS 600 !

100 2 HOURS 600

During this pedod of operation, fuel injection pump temperatures should be checked perio dically by" feel".lf any pumps get too hot to comfortably hold your hand on, proceed to 25 load point for 15 minutes. The engine should then be returned to the no load setting to com- i plete the recommended one hour segment. If many new components are installed in the en gine, consideration should be given to a longer run at zero load.

f

" If piston pin bolts or articulating pin bolts are disturbed during maintenance, the torque on these bolts should be rechecked after 1 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operation.

ENGINE SHUTDOWN Just as it is important to bring the engine up to speed gradually,it is also beneficial to avoid therm shock during shutdown. For this reason. it is recommended to run at no load for 15 minutes pr

( ) to shutdown.

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cooota coOPERBESSEMER RECIPROCATING t

APPENDIX D i I

i February 27,1991 Hou'ston Ughting' & Power Via Fax (512) 972 8041 i South Texas Project Wadsworth,TX 77483 l s

Attention: Mr. Ted Fryar

Reference:

Inspection walver request :

Annual and five year inspection of SDG #12 !

t Gentlemen:

Per your memo of February 22,1991,it is now understood that contrary to :

initialinterpretations, you are requesting a waiver of only a few items from i the C-B recommendations and not a postponement of the entire five year inspection. As you explained, the annual and five year inspections of :

SDG #12 are to be completed with the following proposed exceptions.

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1. Removal of Fust Iniection Nozzfes/Borescoce: Contrary to the annual inspection requirements, only those cylinders identified by i

engine analyzer data (i.e. indicator cards) as being out of !

specification will have injection nozzles removed and cylinders i borescoped. The reason for this is to avoid additional high pressure ,

fuelline connection leaks by not tampering with the connection any more than is absolutely necessary until Cooper design improvements l are available.

In order to minimize any concems associated with the waiver of this '

inspection, it is recommended that additional " engine analysis" ,

checks be made after six (September,1991) and twelve (March, l

1992) months. Any abnormallties found at these times should of course, be immediately addressed.

2. Main Bearino Hose Replacement: The current hoses were Installed in August,1987. The recommended five year hose replacement will be deferred one month until the September.1992 schedulod l

refueling outage. A deviation of this magnitude is felt to be l

insignificant and as a;resutt is acceptabfe. !

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ST-HL-AE-5141 !

~h # Attachment 4 I C 412 458 9725 c. B. FielP. Page 17 of 18 5 02/27/91 13:15 i

'( Mr. Ted Fryar Page Two February 27,1991

3. Air intake Manifold: The intake air manifolds will be inspected on the l engine when the intercoolers are removed for cleaning (to be completed during the current outage) and will not be removed from ';

the engine. This is judged to be sufficie,nt to comply with Cooper-Bessemers five year requirement to inspect the air intake system. j

4. Maintenance Procedure inspection Interval Revision: A procedura! -l revision to go from inspections at 4-%/9 years to 5/10 years in the ,

future is in ageement with current Cooper Bessemer recommendations. ,

5. 25% Tolerance on Recommended Inspeciton intervals: The reasons \

for needing flexibility in maintenance interval requirements to aid in scheduling is certainly understood. As you are aware from previous walver approvals, we will attempt to provide this flexibility whenever ,

it can be justitied. However, we cannot agree to a standard 25% .

. time tolerance .for att inspection intervals. Any deviation from t published Cooper Bessemer inspection period recommendations should be reviewed with us.

In summary, concunence with the proposed waivers is granted, with the !

exception of the previously noted requirements. .;

Sincerely, . }

R. G. Billig, Sr. Design Enginaer l Nuclear & Analytical Engineering Department CC: J. M. Horne R. A. Miklos E. E. Roper f l

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ST-HL-AE-5141 h Attachment 4 Page 18 of 18 HC 6 DCN#MM-1382 APPENDIX E SBDG CYLINDER COMPRESSION PRESSURE TESITNG

1. Have Operations operate engine at fullload and speed to obtain normal operating parameters. >

2. Decrease load to approximately 2900 KW (app. 41" Hg. absolute air manifold pressure).

3. Install analytical equipment on cylinder to be tested. Remove fuel oil line shields .

if required (items 1,2 & 3 Drawing KSV-50 HL&P Drawings 40<t1-00242-CE and 8041-00253-CE).

4. Disconnect the fuel pump control rack on cylinder to be tested (items 35 & 37 Drawings KSV-32 HL&P Drawings 4041-00280-CE, 4041-00211-CE, 8041-00291-CE and 8041-00222-CE). Pull the fuel pump control rack to the "no fuel" location. 1 1 5. Record cylinder compression pressure using the analytical equipment.

6. Reconnect funi pump control rack which will allow cylinder to retum to its normal firing condition.

7. Repeat items 3 through 6 on all twenty cylinders.

8. Advise Operations when testing is complete.

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k.

l ATTACHMENT 5 LARGE EARLY RELEASE INFORMATION

= _ _ _ _

S 1

Attachment 5 ST-HL-AE-5141 Page 1 of 2 The risk significance of the special test exception has been evaluated for its impact to prevention and mitigation. The key figure of merit to evaluate the risk impact relative to prevention has been evaluated in terms of core damage frequency and the key figure of merit to evaluate the risk impact relative to mitigation has been evaluated in terms of large, early release probability (LERP). In combination, these figures of merit provide assurance that the impact of the special test exception appropriately consider both early and long-term health effects.

Large, early release probability (LERP) is defined in the STP PSA as a radioactive release which is both large and early. Large is defined as greater than three inches with a rapid, unscrubbed release of airborne aerosol fission products from the containment. Included in the "large" category are bypasses such as multiple steam generator tube ruptures and interfacing systems LOCAs. A release is considered "small" if it is a controlled leak failure mode (i.e., a slow continuous release to the environment with considerable atmospheric dilution). Small leaks are only considered for pre-existing failures or certain bypass scenarios. All other containment failures are considered to be large. "Early" is associated with the timing of containment failure relative to the release of fission products which is usually associated with vessel breach. An early release is defined as containment failure which may be the result of a pre-existing failure (before vessel breach), a containment failure that occurs at the time of vessel breach, or one occurring within four hours after vessel breach. Late release categories are those that occur on the order of 4 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after vessel breach as well as those that result in long term overpressurization or basemat melt-through.

The risk profile shown in Figure A.5 estimates the impact of the proposed STE for the DG/EW on LERP. The risk significance threshold used is from the Nuclear Energy Institute PSA Application Guide. As seen the incremental risk is below the risk significance threshold value. Since the STE is associated with on-site electric power sources and other safety-related support systems, the risk impact relative to initiating events is an important consideration for both core damage assessment and containment performance. There is no indication of a direct correlation between initiating events and the above risk significance measures outside the scope of the PSA due to the implementation of the extended AOTs. STP design features and operational features included within the scope of the PSA include: fail-safe air operated valves which preclude guaranteed containment failure for loss of offsite power scenarios leading to station blackout, and emergency operating procedures which direct operators to verify containment closure or implement corrective actions if necessary.

1

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Estimated Risk Profile for Proposed 21 Day DG & 7 Day ECW AOT 10 ,

5 Normatized Annuot LERF =1 o '

g 8]

{

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$o. 6 Extended ECW AOT E$ 4 nt n ce 0 o - ~ ~ - a + - - + o = = = 2 e s = s e a ;; = = a n Days

! 2 00E -07 '-

180EC7

O !

O 160E471 0 l l

hC 1.40E47 f

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$* 1.00E-07 No@isk Significant Theshold G i

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w a 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 u u Days &

Figure A.5 Proposed STE impact on LERP and Risk Threshold

_

v t e Letter Sequence Request
TAC:M92169, (Open)
Initiation Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval... Other: ML20129D308, ST-HL-AE-5261, Provides Addl Info Re Proposed Special Test Exception 3.10.8, ST-HL-AE-5271, Provides Addl Info Re Proposed Special Test Exception 3.10.8, ST-HL-AE-5272, Provides Addl Info Re Proposed Special Test Exception 3.10.8, ST-HL-AE-5280, Forwards Revised Table to ,Deleting Item for Hydrogen Analyzers & Revised Table to ,Revising Column Heading.Stp PSA Info Re Containment Isolation Also Encl, ST-HL-AE-5414, Provides Addl Info Re Proposed Single ESF Train Mitigation Capabilities
MONTHYEAR1996-01-23 [Table View]

ML20091R415

Text

1.0 Purpose and Scope

1.0 Purpose and Scope

Reference:

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