ML20202G689
| ML20202G689 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/09/1998 |
| From: | SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | |
| Shared Package | |
| ML20202G639 | List: |
| References | |
| NUDOCS 9802200197 | |
| Download: ML20202G689 (15) | |
Text
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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.8.1.1.2 Each EDG shallbe demonsdated OPERABLE:
- a. I: NEE $$$$ L(:$Y := r-STAGGERED TEST BASTS by! "::'&d :- T:M: iS 1 on a.
- 1. Verifying the fuel level in the day tank and fuel sierage tank.
- 2. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.
- 3. Verifying the diesel generator can start
- and accelerate to synchronous speed (504 rpm) with ;enerator voltage and frequency at 7200 i 720 volts and 60 i 1.2 F2.
- 4. Verifying the generator is synchronized, gradually loaded
- te an indicated 4150-4250 kW" and operates for at levt 60 minutes,
- b. At least once per 31 days and after each operation of the diesel where the penod of operation was greater than or e by removing accumulated water from the day tank. qual to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />
- c. At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks; I
- d. By sampling new fuel oilin accordance with the applicable ASTM .
l standard pnor to addition to storage tanks and: ;
- 1. By verifying in cecordance with the tests specified in the ,
applicable ASTM standard prior to addition to the storage t tanks that the sample has: t I
- a. An API Gravity of within 0.3 degrees at 60'F or a specific gravity of within 0.0016 at 60/60'F, when compared to the su lier's certificate, or an absolute specific gravity at /60'F ofgreater than or equal to
' 0.83 but less than or equal to 0.89, or an API gravity of greater than or equal to 2~ degrees but less than or equal to 39 degrees;
- b. A kinematic viscosity ot 40'C of greater than or equal to 1.9 centistokes, but less than or equal to 41 centistokes (alternatively, Saybolt viscosity, SUS at 100'F of greater than or equal to 32.6, but not less than or equal, to 40.1), if gravity was not determined by companson with the supplier's certification; This test shall be conducted in accordance with the manufacturer's recommendations re,garding engine prelube and warmup procedures, and as applicable regardmgloadm, g recommendation.
- This band is meant as guidance to avoid routine overloading of the engine.
Loads in excess of this band shall not invalidate the test.
SUMMER UNIT 1 3/48-3 Amendment No. 'RM.
9002200197 900209 NM <
ELECTRICAL POWER SYSTEMS SURVEILLANCE RE0UIREMENTS (Continued)
/
within 10 seconds, energizes the auto-connected shutdown loads through /
the load sequencer, and operates for greater than or equal to 5 min-utes while its generator is loaded with the shutdown loads. After p//
energization of these loads, the steady state voltage and frequency "
shall be maintained at 7200 1 720 volts and 6011.2 Hz. I
)
- h. At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 504 rpm in less than or equal to 10 seconds,
- i. At least once per 10 years by:
- 1. Draining each fuel oil storage tank. removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or its equivalent, and
- 2. Performing a pressure test of those portions of the diesel fuel oil system designed to Section III subsection ND of the ASME a
Code at a test pressure equal to 110 percent of the system design pressure.
'43r1A3 Reports - All diesel generator failures, valid or non-vali,dA,V be reported 104he Comission in a Special Report pursuant to S 4ftration 6.9.2 within 30 days. Re of diesel generator fa s all include the CftdP information recomended in Re si .. of Regulatory Guide 1.108, Revision 1. August 1977. If t ettu es in the last 100 valid tests (on a per diesel gener is greater than or 1 4 7, the report shall be sup nts include the additional information rectme d in Regula osition C 3.b of Regulatory Guide 1.108, Revision 1, August SUMER - UNIT 1 3/4 8-6a AMENDMENT NO. 92, 99
lN
] Number of 411ures in Last 20 Valid Tests
- 11 TABLE 4 6 DIESEL GENERATOR TEST SCHECULE Number of Failures in Last 100 Valid Tests
- 14 Test Frequency Once pe. 31 days Once er 7 days 12** 15
/
- Criteria for determining numbeNof failures and umber of valid tests shall be in accordance with RegulatoryNPosition C.2.s of Regulatory Guide 1.108, but determined on a per diesel generator ba f.
For the purposes of determining the rgquif d test frequency, the previous test failure count may be reduced to zetro if, in conjunction with the manu-
- facturer a complete diesel overhaul toA(ke-new conditions is completed, and if acceptable reliability has bee:s demonstrated. The reliability crite-ri5n shall be the successful comple% ion of'14 consecutive tests in a single series. Ten of these tests shal_ij6e in acco'rdance with Surveillance Require-ment a.8.1.1.2.a.3 and 4.8.1.1.2/a.4; foe
- tests, in accordance with Surveillance Requirement 4.8.1/1.2.f. If this hqitation is not satisfied during the first series of teits, any alternate criterion to be used to l s
transvalue the failure count'to zero requires NRC a proval.
- The associated testency frequ/ shall be maintained unt seven CJnsecutiVe failure free demands have been performed and the~numbe{rsof failures in the ,
last 20 valid demanjs as been reduced toTrie.
\
\
/ \
SUtHER - UNIT 1 3/4 8-7 AMENDMENTNO.f},h
!l ELECTRICt.L POWER SYSTEMS A.C. SOURCES SHUTOOWN LIMI' TING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
- a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
- b. One desel generator
- with:
- 1. A day fuel tank containing a minimum volume of 300 gallons of fuel,
- 2. A fuel storage system containing a minimum volume of 33,200 gallons of fuel, and " t. h
. .. :, ; .v .o .. s
- 3. A fuel transfer passp:-
APPLICABILITY: MODES 5 and 6. - ' , ' - -
+n- m 2 ACTION: v- 4. - '- . .m -.
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving C8tE ALTERATIONS positive reactivity changes, movement of irradiated fuel, or crane operation with. loads over the fuel storage pool. In addition, when in N0E 5 wittr the Reactor- Coolant loops not filled, 'or in MODE 6 with the water level .less than 23 feet above the reactor vessel flange, immediate'y initiate corrective action to restore the recuired. sources to OPERABLE status as soon as possible.
. 2 :s .n. .
.... .- - i.... .
SURVEILLANCE REQUIRE"ENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1,
- 4. 8.1.1. 2 (with the exception of 4. 8.1.1. 2. a.4), :-4 ' . S. I.1. 3. f
- ESF load sequencer may be deenergized in Modes 5 and 6 provided that the loss of voltage and degraded voltage are disabled.
SUM'iER - UNIT 1 d-8 AMENDHENT NO. //, K a
.- l 3'/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4. 8.1, 3/4. 8. 2 AND 3/4. 8.3 A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS
-The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident cordi-tions within the facility. The minimum specified independent and redundant A.C. &nd D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10 CFR 50.
The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C.
power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power ar.d single failure of the other onsite A.C. source. The A.C. and D.C. source allowable out-of-service times are based bn Regulatory Guide 1.93, " Availability of Electrical Power Sources," December 1974. When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERABLE diesel generator as a source af emergency power, are also OPERABLE, and that the stess-driven auxiliary feedwater pump is OPERABLE. This require-ment is intendec to provide assurance that a loss of offsite power event will not result in a complete loss of safety function of critical systems-during.
the period one of the diesel generators is inoperable. The ters verify as used in this context means to administrative 1y check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons. It doas not mean to perform the surveillance requirements needed to demonstrate the OPERABILITY of the companent.
The OPERABILITY of the minimum specified A.C. ano D.C. power sources and associated distribution systems during shutdown and refueling enstres that-
- 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.
The Surveillance Requirements for demonstrating the 3PERASILITY of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9, " Selection of Diesel Generator Set Cap 3 city for Standby Power Supplies," March 10,1971,1.100, " Peri;di: T::tir; f O!:::1 C:r:rster Unit:
U::d :: Cr:it: Eintri; P;nr 4;te ; t L; int P;nr Pier.t;," Pa.i;ier,1,
-Agnt 1077, and 1.137, " Fuel-Oil Systems- for Standby Diesel Generators,"
Revision 1, October 1979, as modified by the NRC's review and approval of South Carolina Electric & Gas Company's June 10, 1985 and December 6, 1985 amendment requests.
The fuel storage system minimum volume of fuel to demonstrate operability #
of the diesel generators was based on fuel consumption determined from time 6 dependent loads following a design basis accident and a loss of off-site power o as listed in FSAR Table 8.3-3 for seven days plus a 10% fuel margin as Z recommended in Regulatory Guide 1.137, Revision 2, " Fuel-Dil Systems for %
Standby Diesel Gene ators." position C.1.C(2).
SUMMER - UNIT 1 B 3/4 8-1 AMENDMENT NO. /))7g
s ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
'4.8.1.1.2 Each EDG shall be demonstrated OPERABLE:
- a. At least once per 31 days on a STAGGERED TES. BASIS by:
- 1. Verifying the fuellevelin the day tank and fuel storage tank.
- 2. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.
- 3. Verifying the desel generator can start' and accelerate to synchronous speed (504 rpm ) with generator voltage and frequency at 72JO 720 veits and 60 1.2 Hr.
- 4. Verifying the generator is synchronized, gradualty loaded
- to an indcatec 4150-4250 kW" and operates for at least 60 minutes.
- b. At least once per 31 aays and after each operation of the desel where the pered of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by removing accumulatec na*e5 from the day tank.
- c. At least once per 31 aays by checking for and removing accumulated uase trem the fuel oil storage tanks:
- d. By sampling new fuel oilin accordance with the apolicacie ASTM stardarc pri:r to addition to storage ta.vs and:
- 1. By veritying in ac=:rmnce with the tests specfied in the applicade ASTtt standard pnor e asinon to the storage tanks that the sample has:
- a. An API Grairry of within 0.3 degrees at 60'F or a specific grant ct within 0.CC15 a2 6060*F, when compared to the suppliers cenicrs, or an absatne soe=iic gravity at 60/60*F c4 greater than er exsj t 0.83 but Wss tian or ecual to 0.89, or an API gravity of gresar ran or equal n 27 seg ees out less than or equaj to 39 degrm,
- b. A kinemzic vs csky of 40*C of greater than or equal to 15 centistoksi. b.t less than or equal to 4.1 cv:ts:ckes (ahrrd.e6<
Saybott vs asty, SUS at 100*F of grea:er ran er equal t 321 b.t not less t am :r saaal to 40.1), if gravity was nct determirec by companso . win tne sucoler's cerd5ca:on:
- This test shall be conducted in acuce with tne manufacttre(s rec:mmerda*.ccr; regarding engine prelube and wa- n c :rotecures. and as apoicabe reep.rdirq Icedrq recommendations.
This band is meant as guican:a e roc routine evericadrq ci 7.e ergine Lucr. n excess of this band shall not ivaloEne ne test.
SUMMER UNIT 1 F4 6-3 Anercrnent ik, r,W-M%
ELECTRICAL POWER SYSTEMS SURV5ILI. ANCE REQUIREMENTS (Continued) within 10 seconds, energize 3 the auto connected shutdown loads through the ! cad sequencer, and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization of these loads, the steady-state voltage and frequency shall be maintained at 72001720 volts and 60 1.2 Hz.
- h. At least once per 10 years or after any modifications which could affect diesel generator interdependence by starting the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to at least 504 rpm in less than or equal to 10 seconds,
- i. At least once per 10 years by:
- 1. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite solution or its equivalent, and
- 2. Performing a pressure test of those portions )f toe diesel fuel oil system designed to Section 111 subsection ND of the ASME Code at a test pressure equal to 110 percent of the system design pressure.
SUMMER - UNIT 1 3/4 8-6a Amendment No. 9W
e THIS PAGE l'lTENTIONALLY LEFT BLANK (Table 4.8-1 was deleted) i SUMMER - UNIT 1 3/4 8-7 Amendment No. 50, '?, 99,
=
ELECTRICAL POWER SYSTEMS d.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:
- a. One circuit between the offsite transmission network and .he onsite Class 1 E distribuf n system, and
- b. One diesel generator
- with:
- 1. A day fuel tank containing a minimum volume of 300 gallons of fuel,
- 2. A fuel storage system containing a minimum volume of 33,200 gallons of fuel, and
- 3. A fuel transfer pump, APPLICABILtTY: MODES 5 and 6.
ACTION:
With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool.
in addition, when in MODE 5 with the Reactor Coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor versel flange, immediately initiate, corrective act.on to restore the required sources to OPERABLE status as soon as possible.
SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 (with the exception of 4.8.1.1.2.a.4). l
- ESF load sequencer may be deenergized in Modes 5 and 6 provided that the loss of voltage and degraded voltage relays are disabled.
SUMMER - UNIT 1 3/4 8-8 Atrendment No. W84r
3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1, 3/4.8.2. AND 3/4.8.3 A.C. SOURCES D.C. SOURCES. AND ONo!TE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation er.sures that sufficient power will be available to supply tha safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10 CFR 50.
The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source. The A.C. and D.C. source allowable out-of-service times are based on Regulatory Guide 1.93, " Availability of Eiectrical Power Sources," December 1974.
'Nhen one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems. trains, components and devices, that depend en the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE. This requirement is intended to provide assurance that a loss of offsite power event will not result in a complete loss of sclety function of critical systems during the period one of the diesc; generators in inopere 'e. TL,e term verify as used in this context means to administratively check by examining lo ss or other information to determine if certain components are out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILIT( of the component.
The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that 1) the facility can be maintained in the shutdown or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.
The Surveillance Requirements for demonstrating the OPERABILIT( of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9, " Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10,1971, and 1.137, l
" Fuel-Oil Gystems for Standby Diesel Generators," Revision 1, October 1979, as modified by the NRC's review and approval of South Carolina Electric & Gas Company's June 10,1985 and December 6,1985 amendment requests.
The fuel storage system minimum volume of fuel to demonstrate operabiliy of the diesel generators was based on fuel consumption determined from time dependent loads following a design basis accident and a loss of off-site power as listed in FSAR Table 8.3-3 for seven days plus a 10% fuel margin as recommended in Regulatory Guide 1.137 Revision 2, " Fuel-Oil Systems for Standby Diesel Generators," position C.1.C(2).
SUMMER - UNIT 1 B 3/4 8-1 Amendment No. 77, C1, e
Att: chm nt ll to Docum:nt Control D:sk RC 98 0016 TSP 980002 Page 1 of 2 SAFETY EVALUATION FOR REMOVAL OF TABLE 4.8-1 DIEREL GENERATOR TEST SCHEDULE FROM THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS
_ Description of Amendment Request SCE&G proposes to change the current VCSNS Technical Specifications (TS) so that the requirements for accelerated testing and special reporting are removed. This follows implementation of the required maintenance program for monitoring and maintaining diesel generator performance consistent with the provisions of 10CFR50.65 and the guidance as applicable to diesel generators of RG 1.160.
Specifically, these changes to the applicable diesel generator Technical Specifications are proposed:
- 1) SR 4.8.1.1.2.a specified frequency is changed to 31 days; 2) SR 4.8.1.1.3 Reports section is deleted; 3) Table 4.8-1 " Diesel Generator Test Schedule" is deleted; 4) SR 4.8.1.2 reference to 4.8.1.1.3 is removed; and; 5) Bases Page 3/4 8.1 deleting reference to RG 1.108.. This is consistent with the guidance provided by NRC GL 94-01.
Safety Evaluation Generic Letter (GL) 94-01 advises licensees that they may request a license amendment to remove accelerated testing and special reporting requirements for the Emergency Diescl Generators (EDGs) from their Technical Specifications. The basis for the change is that the licensee must implement a maintenance program for manitoring and maintaining diesel generator performance consistent with the provisions of Ser: tion 50.65 of the Code of Federal Regulations (10CFR50.65) and the guidance as applicable to diesel generators of NRC Regulatory Guide (RG) 1.160.
The maintenance rule provides an acceptable method for monitoring the effectiveness of Diesel Generator maintenance. The elements of this program include the performance of detailed root cause analysis of individual EDG failures, effective corrective actions taken in response to individual EDG failures, and implementation of EDG preventive main'9 nance consistent with the maintenance rule.
SCE&G will continue to comply with the provisions of 10CFR50.72 and 50.73 to notify the NRC and report significant EDG failures consistent with failures of other plant systems, structures, and components. Since SCE&G is required to have a performance monitoring program under 10CFR50.65 and provide for operability and
' Att: chm:nt 11 to Docum:nt Control Desk RC 98 0016 TSP 980002 Page 2 of 2 reportability determinations under 10CFR50.72 and 50.73, there is no need to have additional requirements in the Technical Specifications.
The changes proposed in this amendment request are consistent with the guidance provided by NRC GL 94 01.
. Att: chm:nt lll to Docum:nt Co.itrol Desk RC 98-0016 TSP 980002 Page 1 of 3 NO SIGNIFICANT HAZARDS EVALUATION FOR REMOVAL OF TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE FROM THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS Description of Amendment Request SCE&G proposes to change the current VCSNS Technical Specifications (TS) so that the requirements for accelerated testing and special reporting are removed. This follows implementation of the required maintenance program for monitoring and maintaining diesel generator performance consistent with the provisions of 10CFR50.65 and the guidance as applicable to diesel generators of RG 1.160.
Specifically, these changes to th 'oplicable diasel merator 3 Technical Specifications are proposed: 1) SR 4.8.1.1.2.a .pecified frequene/ .t changed to 31 days; 2) SR 4.8.1.1.3 Reports section is deleted; 3) Table 4.8-1 " Diesel Generator Test Schedule" is deleted; 4) SR 4.8.1.2 reference to 4.8.1.1.3 is removed; and; 5) Bases Page 3/4 8.1 deleting reference to RG 1.108.. This is consistent with the guidance provided by NRC GL 94-01.
Basis for No Slanificant Hazards Consideration Determination .
In accordance with 10CFR50.92, a proposed change to the operating license involves no "significant hazards" if operation of the facility, in accordance with the proposed change, would not: 1) involve a significant increase in the probability or consequences of any accident previously evaluated; 2) create the possibility of a new or different kinu of accident from previously evaluated, or; 3) involve a significant reduction in a margin to safety.
This request is evaluated against each of these criteria as follows:
- 1. This request does not involve a significant increase in the probability or consequences of an accident previously evaluated.
This change will provide flexibility to structure the emergency diesel generator maintenance program based on the risk significance of the structures, systems, and components that are within the scope of the maintenance rule. The removal of the diesel generator accelerated testing is acceptable as the maintenance rule applies system and train
~ , ' Attachm:nt lli to Docum:nt Centrol Desk RC 98 0016 TSP 980002 Page 2 of,3 specific performance criteria to monitor diessi generator performance.
These criteria include a running availability and reliability meacure. The performance criteria for the diesel generator reliability and unavailability established by the maintenance rule, and the causal determinations and corrective actions required for functional failures and/or exceeding performance criteria, is considered to be an acceptable method fo,-
monitoring diesel generator performance.
As the diesel generator performance will continued to be assured by ths maintenance rule, the proposed changes do not affect any of the initiators for an accident previously evaluated. The changes do not impact the diesel's design sources, operating characteristics, system functions, or system interrelationships. The failure mechanisms for the accidents previously analyzed are not affected, and no additional failure modes are created that could cause an accident previously evaluated. Since the changes are administrative in nature, and the diesel generator performance and reliability will continue to be- assured by the ,
maintenance rule, the proposed changes cannot involve a significant 8 increase in the probability or consequences of an accident previously
. evaluated.
- 2. This request does not create the possibility of a new or different kind of accident from any accident previcusly evaluated.
This proposed change does not involve a change to the plant design or operation. As a result, the proposed change does not affect any cf the parameters or conditions that could contribute to the initiation of any accidents. The proposed changes only affect the methods used to monitor and assure diesel- generator performance. The performance criteria for both- the diesel generator reliability and unavailability established by the maintenance rule, and the causal determinations and corrective actions required for functional failures and/or exceeding performance criteria, is considered by GL 94 01 to be an acceptable method for monitoring diesel generator performance.
i No SSC, method of operating, or system interface is altered by this change. The changes do not impact the diesel's design sources, operating characteristics, system functions, or system interrelationships.
The failure mechanisms for the accidents are not affected, and no additional failure modes are created. Because the proposed changes are administrative in nature, and the diessi generator performance and
i
, J ' Attachn. eat lll to Docum:nt Control Desk i
RC 98 0016 TSP 980002 Page 3 tjf 3 reliability will continue to be assured by the maintenance rule, the proposed changes cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. This request does not involve a significant reduction in a margin to saliety ,
l The proposed changes only affect the methods used to monitor and assure diesel generator oorformance. The performance criteria for both the diesel generatorieliability and unavailability established by the maintenance rule, and the causal deteminations and corrective actions l required for functional failures and/or exceeding performance criteria, is
' considered by GL 94 01 to be an acceptable method for monitoring diesel generator performance. No margin to safety as defined in the basis for any technical specification is impacted by these changes. This change does not impact any uncertainty in the design, construction, or operation-3 oi any SSC. Diesel generator response to accident initiators is unchanged. No SSC, method of operating, or system interface is altered by this change. The changes do not impact the diesel's design sources, operating characteristics, system functions, or system interrelationships.
Because the proposed changes are administrative in nature,.and the diesel generator performance and reliability will continue to be assured by the maintenance rula, the proposed changes cannot involve a significant
, reduction in the margin to safety.
Environmental impact Consideration
- SCE&G haa reviewed this request against the criteria of 10CFR51.22 for environmental considerations. Since this request involves (!) no significarit hazard consideration, (ii) no significant change in the types or significant increase in the amounts of any effluents j that may be re
- eased offsite, and (iii) no significant increase in individual or cumulative occupational radiation exposure, SCE&G has concluded that the proposed change j meets the criteria givsn in 10CFR51.22 (c)(9) for a categorical exclusion from-the 4
reouirement for an environmental impact statement.
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