TXX-4377, Submits Evaluation of Revised Tdi Diesel Generator Owners Group Rept Re Adequacy of Diesel Generators.Final Rept Anticipated by 850101

Submits Evaluation of Revised Tdi Diesel Generator Owners Group Rept Re Adequacy of Diesel Generators.Final Rept Anticipated by 850101

ML20101E725
Person / Time
Site:	Comanche Peak
Issue date:	12/17/1984
From:	George J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TXX-4377, NUDOCS 8412260367
Download: ML20101E725 (13)

Text

f ,

TXX-43775 -

(A 'CPPA-42175 (,s . .

~'

-!rEXAS UTILITIES GENERATING COMi%NY P. o. Box 1002 + C1.EN nose. TEXAS 76043 e

b December- 17, 1984

'Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Subject:

Comanche Peak Steam Electric Stacion Unit No.1 Docket No. 50-445 Texas Utilities Evaluation of the Design / Review Quality Revalidation (DR/QR) Report on the TDI L

Diesel Generators at CPSES Unit 1

References:

1. . Letter OGTP-246-0-132 to J. B. George from C.L. Ray, Jr., dated September 7, 1984;

2. Letter OGTP-582-0-360 to J.B. George from C.L. Ray, Jr., dated November 21, 1984;

3. Letter TXX-4326 (CPPA-41258) to H.R. Denton from J.B. George dated October 5, 1984;

4. Letter TXX-4329 (CPPA-41272) to Dr. David

_ Dingee from J.B. George dated October 8, 1984;

5. Letter to M.D. Spence from B.J Youngblood dated October 1, 1984;

6. Letter 0GTP-176-0-92 to J.B. George frem C.L.

Ray, Jr., dated August 9, 1984.

7. Letter OGTP-591-N-48 to H.R. Denton from C.L. Ray, Jr., dated November 27, 1984.

8. Letter OGTP-627-N-51 to H.R. Denton from C.L. Ray, Jr. dated December- 11, 1984.

Dear Mr. Denton:

Texas Utilities has recently completed a detailed evaluation of the DR/QR report (Reference 1) prepared by the TDI Diesel Generator Owners' Group for the CPSES Unit i diesel generators, including the revisions proposed in Reference 2. For all practical purposes, the CPSES DR/QR report represents the final results of Phases I and II of the

, 8412260367 841217

) PDR ADOCK 05000445 9 PDR e

g A 838V8NisDN 03Y TEXAN l'TELETit:N Ei.9:4'1 Rit' t' TIM PA N Y

TXX-4377' CPPA-42175, .

Owners' Group. program to assess the adequacy of the CPSES Unit 1

' diesel generators to perform their intended safety function. Advance copies of the report were forwarded-to NRC Staff at.d to consultants

'from Pacific Northwest Laboratories (PNL) via References 3 and 4, prior to review by Texas Utilities. Revisions proposed in Reference 2 have been reviewed by Texas Utilities'and comments provided to the

-Owners' Group. Publication of the final DR/Q Owners'Groupiserpectedby_ January 1,1985,peportrevisionbythe and Texas Utilities presumes that.there will be no substantial technical differences from the. proposed revisions. Copies.of the final revision will be forwarded to NRC upon receipt.

The purpose of this letter, therefore, is to provide for NRC and PNL review the results of Texas Utilities' evaluation of the revised,DR/QR

, report, particularly the recommendations made therein to assure reliable diesel generator performance over the life of CPSES Unit 1.

As established in Reference 5, actions taken and commitments made to date.by-Texas Utilities have been sufficient for NRC Staff reviewers of-TDI diesel generator issues to conclude that the Unit i engines are adequate for first cycle operation. A report on Texas Utilities' progress in meeting the. commitments identified in Reference 5 is currently under preparation and will be issued by December 20, 1984.

The DR/QR report recommendations are categorized and discussed as follows:

Recommended modifications to equipment. These are discusaed in Enclosure 1 to this letter;

- Recommended maintenance and surveillance activities. These are discussed in Enclosure 2 to this letter;

, -Recommended baseline vibration testing for the engine, piping, tubing and components (one engine only). Baseline vibration testing has recently been performed per.0wners' Group procedures (Reference 6) as recommended, subject to a restriction to load the engines no higher than 5740 KW (approximately 82 percent of rated capacity) as directed in Reference 5. Baseline data are to be used to identify engine components with unusually high vibration levels and to determine initial vibration characteristics of the engine, thus providing a basis for subsequent trend analysis and comparison with similar engines.

Baseline data will be reduced and evaluated against acceptance criteria established by TD1 and Owners' Group personnel. The Owners' Group will issue a formal report in mid-January, 1985, on engine vibration testing.

/L*

- TII .4377:

CPPA-42175 ,

Should:there_be any questions or concerns on this matter, please feel free to contact us at any time.

./ "'

Si c f y,

. . - G ,or .

Vice President / Project General Manager JBG/SMW/1jh Enclosure.

CC: ARMS M.D. Spence-J.T. Merritt J.W. Beck D.H. Wade R.A. Jones

.R.E.-Camp-C.K. Moehlman.

N.S._Reynolds V. Noonan - NRC C~. Berlinger - NRC S. Burwell - NRC D. Persinko - NRC

.C.L.'~ Ray;- Duke /TDI Owners' Group A.P. Cobb.- Duke /TDI Owners' Group B.R. Clements L.F. Fikar-J. ' Stefano ' - NRC K..Trickett - Doe i W. Laity - PNL B.J. Youngblood - NRC

. Files f

s ,

a m ~ ,

%*~3

~

d ,

g i$ [TXX-437'7 . ,

W h  :

CCPA-42175-.

s

~

5 Enclosure 1;

~

.  :;y8

" , .L Results of Texas Utilities- Evaluation of'the CPSES DR/QR Report

'RecommendationsforDgcalGeneratorEquipmentModifications 4

. Texas Utilities concurs with all Owners' Group ~ recommended

^

~

modifications to piping and tubing supports,: couplings and electrical

.controlscas" stated.in the revised CPSES DR/QR; report with the'

~

following clarifications: .

, j k'[ .  %%

3 -1)l Component CP-102, Generator Controls

' ~

m >

, ..Several options were identifieti in-the report for this

component.- Texas Utilities (. currently intends to implement.

~

. I 'g the y' maintenance: and modification" recommendations

~ .

identified in-Attachment'l to the referenced. component report.: -:However, the -ir.terval for monitoring of the pertinent'sub-components-.has been modified by Texas

(, , .-ytilities as stated in Enclosure 2 to this letter.-

s m .. ,

?? b b' .

~ 2) D diimponent-02-455B,' Fuel Oil Strainers-A recommendation was.made for this component to change the size of the fuel. oil. strainers to a coarser design should i

the currently installed strainers require excessive

~ h cleaning.' Based on a-l'ack of problem experience with the installed . strainers during engine operation, Texas Utilities.

74-

/d idoes not intend to replace the strainers, however..this .

. position may be reevaluated if the need arises in the' future.

'ThA.DR/QR equipmEn,t modification recommendations as clarified above will be implmented,: as . applicable, for both CPSES Unit I diesel

. generators. /Except for~ generator ~ control panel modifications, the recommended modifications-will be implemented prior to the restart

'from the.first refueling. outage at CPSES Unit 1. -Generator control ipanels will'be modified prior to exceeding 5% power to enable

' subsequent monitoring of specif,ied sub-components.

Lj^

i -

.~

v m

J 1' / I

~! \

J

& 2

'?4-

$ kh ._ I, I'

,i

7 e' a

~TXX-4377' CPPA-42175, .

Enclosure 2 Results of Texas Utilities' Evaluation of the CPSES DR/QR

- Recommendations Regarding Maintenance and Surveillance Activities Texas Utilities concurs with all Owners' Group recommended maintenance Kand surveillance activities:as stated in the revised CPSES DR/QR component reports and revised maintenance' matrix, with the following proposed modifications and/or clarifications:

'1) Component F-068,-Intercoolers Item-2 in the revised maintenance matrix recommends-cleaning 1 and inspection of.intercooler shell and tube sides after every refueling outage. Texas Utilities concurs with the

, inspection interval for the tube side, however, it is proposed that the shell side-be comparably inspected at a five (5) year interval, based on a lack of identified problem experience for the shell side.

-2)  : Component MP-022/23 Turbochargers Item 2 in the revised maintenance matrix recommends cleaning of the' turbocharger impeller and diffuser'at every refueling outage.- Texas Utilities proposes as a more practical maintenance approach that the impellers and diffusers be inspected every refueling outage and cleaned if necessary.

A supplementary Phase I report on turbocharger nozzle ring assemblies has also been issued by the Owners' Group (Reference 7) which contains the following additional

-Utility recommendations:

a.. At any turbocharger disassembly there should be a visual inspection of nozzle ring components for any apparent damage, failure or apparent mispositioning of vanes. Replace all affected nozzle ring components. During reassembly ensure that capscrews are properly installed with recommended pretorque.

b. Monitor engine operation to ensure exhaust gas temperatures do not exceed those specified.

Texas Utilities will comply with the utility recommendation a) above during all turbocharger disassemblies and'will perform pre-turbine exhaust temperature monitoring on a monthly basis.

pc,

?

gmy y

' J_ iTXX-4377i_.

, . '. CPPA-42175. .

t r_ . -

3)1 : Component 00-420, Lube Oil Pres'sure Regulating Valve-

~~

Itemil ih the. revised maintenance matrix ~ recommends. valve

, l disassembly and cleaning at every-outage.; Texas Utilities-concurs;-but proposes that the interval be changed to lalternate refueling outages' based-on satisfactoryEindustry experience with this valve.

34) Component 02-307B, Lube 011 Fittings,' Internal-

. Texas Utilities' concurs with the recommendation in Item 1 to

, 1 check tubing for dents or crimps at every refueling outage, however.fthis_will-be performed on accessible tubing only.

1. 5) ' Component 02-310A,~ Crankshaft

~

' Item 2 in the~ revised' maintenance matrix. recommends that all crank journal! diameters be measured at alternate outages.

. Texas Utilities proposes _that a sample'of. main journals be

. measured at, alternates refueling outages in order to be compatible with the established sampling' frequency for the-main bearing shells (see component 02-310B).

-).

6 ' Component 02-310B, Main Bearing Shells

~ ~

. Item 1 in the. revised maintenance matrix recommends visual-and' dimensional inspection of all main _ bearing shells for:

~

evidence-of. wear or misalignment-at the first refueling outage and at-alternate outages thereafter. Texas Utilities-believes .that the minimal problems encountered with the

CPSES Unit 1 DG main bearing shells do not warrant

,y ,

Jinspection to.the degree recommended by the Owners' Group.

n . This position'is in agreement with the assessment by NRC and

'PNL of CPSES main bearingushell experience,was stated on

, pages 5.12 and 5.13 of'PNL-5234 (enclosure to Reference 5).

3Y 's , As recommended by NRC andsPNL, Texas Utilities will perform a , a sample inspection of two (2) highly loaded bearings per v engine (bearings 5 and 6) at alternate refueling outages.

Associated caps and saddles will also be checked. The need

, for additional' inspection will be determined by the results of the initial sample inspection. Due to accessibility

, restrictions, inspection of bearings 1, 9, and 10 are to be

_ performed only during an engine teardown (every 5 years).

u -

a h

?'

..v

TXX-4377 CPPA-42175 ,

m-

.-7) Component 02-310C, Thrust Bearing Ring

~ Item 2'in the revised. maintenance matrix recommends a visual inspection of the thrust bearing for signs of wear-or-degradation concurrently with visual and dimensional main

-bearing shell inspections'as recommended above. However,

the-main bearing shell inspection frequency has been modified as stated.-above. Texas Utilities proposes that the recommended. visual inspection would be adequate if performed at a five (5) year interval (i.e. at overhauls) since a

" bump check"' for thrust bearing clearance will be performed atrevery refueling outage.

' 8). Component 02-315A, Cylinder Blocks

. Item 1 in the revised maintenance matrix recommends a visual inspection of the cylinder block and eddy-current inspection for stud-to-stud cracks between cylinder heads and for cracks between the block edge and studs at the block ends.

The recommended frequency for the inspection is prior to

-returning the engine to standby service after any period of operation above 50% load.

Texas Utilities agrees that surveillance of the block top g

surfaces to ensure the absence of stud-to-stud cracks and stud-to-edge cracks is appropriate for the first cycle of operation at CPSES Unit 1, until such time as the indications found on Train A, cylinders 4R and SR and on Train B, Cylinder 1R and 4R are reinspected at the first refueling outage. Future inspection requirements should be based on the results of the above inspections and on any additional information provided by the Owners' Group. This position is in agreement with PNL's position in PNL-5234.

Texas Utilities proposes at this time, however, that a visual and boroscopic examination be substituted for the eddy-current technique at the same frequency of performance.

Texas Utilities believes that the use of visual /boroscopic examination will result in greater engine availability and is -justifiable based on the stated conservatism in the Owners' Group assessment of the CPSES block indications as

" ligament cracks" and on the absence of Widmanstaetten graphite in the CPSES cylinder blocks.

The indications in the Train A right bank cylinder block are the largest found at CPSES, but the Owners' Group has concluded that they were casting induced not service induced. The smaller indications in the Train B right bank cylinder block were also determined to be casting defects (by TUGCO) and are-less than 0.050 inches in depth. All of these indications are in lower stress regions of the block top than ligament cracks and are all smaller than ligament cracks.

' ~~

ly 3l f% 3 >

~

.J7 5TIX-4377f g . __CPPA-42175 _

.1 --

v:- +

y,

-,a Y. "t S

Widmanstaetten graphite is a degenerate microstructure.that'

reduces the' strength andl fatigue' resistance of: grey cast; -

iron.-:The Owners' Group has~ determined that there is no-

$Widmanstaetten graphite present in-the CPSES Unit I cylinder

? _

O, Jblocks.'

, lThe Ownersf Group'has.' stated in the latest._ Phase I report-

(reference-8) that blocks which have or are assumed to have

. , ligament! cracks and wnich~.have no Widmanstaetten graphite

- ~

fare capable of. withstanding.a LOOP /LOCA event.with,

sufficient margin, provided no: stud-to-stud _ or stud-to-edge :

(cracks exist.- Furthermore, engines with.such cracks 'an' c

• + -

'still be returned'to standby service provided these cracks are less'than;l -inchesLin depth'from the block top. .

~

Because.initiationLof stud-to-stud or' stud-to-end cracks m -

- -occurs at_.the' block top: surface and because they propagate

' - downward,' visual surface- inspection of the block top prior

~

sto; returning an engine to service will be adequate to assure

,f :the absence of -such cracks.

LAs required in Reference 5, Texas Utilities will also A  ; perform routine: daily visual anspections of the block and-external. surfaces ~during operating' periods, with a more f thorough monthly-inspection under strong lighting (also with

~

the engine. operating). As stated above, block indications-are to.be reinspected for propagation at the first refueling

, outage. The cylinder block camshaft; gallery will also be visually inspected at-each' refueling outage.

'9) Component 02-340A, Connecting Rods m

Item 2-in the revised'maintenece matrix recommends inspection and' measurement of connecting rods at 5 year intervals. NRC. requirements in Refersuca 5, however,

~

y."'

specify a visual inspection of._all rod box etternal surfaces and a bolt preload check at each 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of ope ation or

'_at 9 months, whichever comes first.

+

Texas Utilities will comply with the requirements specified by NRC in ReferenceL5*for the connecting rods. It is hereby

'N 'N s

.. requested,'however, that the inspection interval be changed N T, .to each 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of operation or each refueling outage,

~

whichever; comes first. Texas Utilities believes that hours

- of operation would have more of an affect on the= likelihood

-of bolt pre-load relaxation than would the passage of time, and'should be the parameter of concern.

E

_s h'^

g= -

.g , - -

h[' TXX-43775 ~ ' ' -

?~ -

.\ c (CPPA-42175) .

- 9 L10)~ Component-02-34'0B, Connecting Rod Bearing Shells

' ~

g i

(Iten 1:in the= revised maintenance matrix recommends'that I"

-visual endidimensional; inspection of all bearingEshells be

performed. at the' outage which: precedes 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of--

c 1* "  ; operation by:st 1 east,the sum of. hours of operation in a

~

,- LOOP /LOCA plus the expected hours of operation between

outages.1 f" , _

I'nplaceofltheabove. scheme,TexasUtilitieswillperforma

! visual:and. radiographic-examination of-connecting rod bearing shells;for 2 sets of pistonstper engine, as

~'

fspecified:byiNRC in

Reference:

5,'at;the first. refueling-outaget Lube ~o111 analysis for' contamination will be' fe  ; performed'on-a monthly basis, and bearing clearance will be measured .byl" bump ~ check" at every refueling outage. -

11)' Component 02-341A, Pistons- =

. Items.I and'2.in the original maintenance matrix recommended visual'and liquid penetrant inspections respectively, for apistons at 5 year intervals. .NRC has specified in Reference

,5 that these inspections also lue performed on 2 sets of epistons at-the first' refueling. outage.

-Texas Utilities has learned-informally through the Owners' Group that substantial positive' operating and inspection data have been gained on Type AE. pistons as a result of a 750 hour0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />'run on.an AE-equipped engine at Shoreham Nuclear Power Station. The Owners' Group has also proposed deleting

~

.the' liquid penetrant-inspection in a revision to the maintenance matrix.: Based on this information, it is

_ ,possible that concerns with regard to AE pistons may be eliminated in theLnear future. Therefore, Texas' Utilities s -hereby; defers commitment to an inspection of AE pistons and

' ~

' requests that NRC reevaluate the-need for such inspections-

, in lightaof this information.

12)- Component 02-350A, Cam Shaft Assembly D

J Item 1 in the original maintenance matrix recommended visual

-inspection of all cam lobe surfaces at 5 year intervals. -

-while the component report specifies inspection at each p?t' ~ _ outage. The Owners' Group has revised the frequency in the

.% maintenance matrix to agree with the component report

frequency.. This is in conformance with NRC requirements 1" '

specified'in Reference 5 and the inspection will be performed by Texas Utilities at each refueling outage.

ss i

e at + - , s,,-,, ,, ,-e,,-,,,,, .-, . - .

g - -

E , (TXX-4'377

~CPPA-42175j ..

9-13). Component 02-380A, Exhaust Manifold Item 1_in the revised' maintenance matrix recommends magnetic particle examination of_a sample'of circumferential pipe -

welds and' corresponding heat affected zones at the first-refueling outage and at. alternate refueling outages thereafter.

Texas Utilities proposes to visually examine all accessible

welds at'the frequency given above,-instead of a sample of magnetic particle tests. It is felt that this procedure would provide a more practical approach with broader weld inspection coverage.

14)' Component 02-387A, Crankcase Vacuum Fan Item 1 in the revised maintenance matrix recommends cleaning and inspection of the fan at alternate outages. Texas Utilities proposes, as a more practical-approach, that the

, fan be inspected at alternate refueling outages with cleaning as necessary.

15) Component 02-390E, Rocker Arm Bushings Item 1 in the revised maintenance matrix recommends visual and dimensional inspection of intake rocker arm bushings at the outage which precedes 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> of operation by at least the sum of expected hours of operation in a LOOP /LOCA plus the expected hours of operation between outages.-

However, NRC has concurred in Reference 5 with Texas Utilities earlier proposal to visually inspect rocker arms at each refueling outage.

Based on the above, Texas Utilities will perform a visual inspection of the intake rocker arms at every refueling outage, and will measure them every 5 years during overhauls.

16) Component 02-410A, Overspeed Trip Covernor Recommended settings will be reviewed to ensure compatibility with the Texas Utilities' grid system requirements and may be adjusted accordingly.

17) Component 02-410C, Overspeed Trip Drive Couplings

. Item 3 in the maintenance matrix recommends that the present L-110 Lovejoy couplings be replaced with new units at the next outage, per TDI Service Information Memo (SIM) 363.

~

Texas Utilities does not intend to replace these couplings at the first refueling outage because they were already replaced per SIM 363 instructions.

m . gym ~ -

- , l n - ,w <

'nDL 1-TXX-4377,

l. CPPA-42175, , '

q. _

. . ~ .-

' : [

(18)- Chaponent 02 1413A,1 Governor Linkage-

x '

+

Itemil in_the original maintenance matrix recommends that-

. bolt; heads and; roll pins be -lockwired. - , The10wners ' ' Group -

~

Jhas revised this-item-to read: " Install positive locking-

- hardware to the lever arm? clamp-bolt heads and shaft rolli pins."'

~

(Texa's' Utilities will-install;1ockwire on all fasteners

designedifor use with lockwire.. Other_ locking hardware will be installed'where specified.

" - 19) ' Component 02-415A, Woodward Governor i

.1 . Recommended settings will be revi+wed to ensure

~

. compatibility with the Texas Utilities grid system

, requirements : and may be adjusted accordingly.

20)j : Component 02-5000, Breakers & Contact Blocks Item 3-in=the revised maintenance matrix recommends that

~

circuit breakers be- trip'-checked at each outage. Texas Utilities: believes that breakers'of the molded' case type 7 -<7 lshould-not.be-tested =at frequent intervals and proposes to'

perform this test every 5 years for-this type.of breaker.

Other.. types of breakers would be tested at each refueling outage as recommended.

~221)_ Components 02-525B, C, Barring Device Controls & Filter R Because~the barring device is not required during engine.

_ operation, the Owners' Group recommendations for the

^*

. associated components may.not'necessarily be incorporated by.

Texas Utilities,1but will.be taken into consideration.

22) . Component 02-717C, Jacket Water Piping, Couplings, Fittings, Orifices & Y-Strainers-The DR/QR component report recommends that flanges be torqued per the general' torque tables in the TDI Instruction Manual. Texas Utilities flange torquing procedure provides for greater torque than the general torque tables and will provide adequate load transfer to

. attaching-supports.

(

s .,

y '

.x .

g- - ~, .

..~>

y '

TXX-4377[ -

a', ~ YCPPA142175 '  ;

.m , ,

$fc 1::

g!< _ --

n _ _

23).LComponent 02-717G,'K, Lube 011' Valves and Fuel 011 Valves

-~:

( g; Item 2"in the original maintenance matrix: recommended O- idisassembly,' cleaning and checking of lift' pressure for lube oil and. fuel' oil relief valves at every outage,;while the

~

~

"~.,

~

, :1ubeloi1 valve: component report" specifies a 5; year interval fforfchecking lift pressure and the: fuel: oil valve component freport does not address:liftipressure at all...lk revision.to the; maintenance. matrix has been proposed by the.0wners'

, 7 roup, G however,'.which sets ~the interval for. checking-lift Jpressure on lube oil?and fuel' oil relief valves at 5 year

? intervals.7 Texas; Utilities will comply with theLrevised

-recommendation.

'24) L Component 02-810E,' Jacket Water' Heaters

~

'The Owner' Group recommends in the revised ~ maintenance

matrix that'the:following.be performed at each outage: 1)

. measure heater: insulation, resistance, 2) inspect and clean e v _ heater elements, and'3); check calibration and inspect 1

' thermostat. However, this recommendation appears to be earbitrary in thatuit is not based on either~a design review orfon adverse component experience according to the

. component report. Texas Utilities believes that the

' activities recommended above would be adequate if performed Lat' alternate refueling outages and intends to implement that interval.

l 25) . . component 02-820A, Lube Oil Sump Tank Heaters -

The Owners' Group recommends that heater insulation resistance be measured and that thermostats be checked and-calibratediat ev'ery outage. Based on satisfactory

" experience with these heaters, however, Texas Utilities proposes that these activities be performed at alternate

. refueling outages. The heater elements will be inspected at

. every refueling outage in conjunction with the tank inspection, as recommended.

j . ,26) Component CP-102, Generator Controls

, Items 6, 7 and 8 in the revised maintenance matrix recommend monthly inspection of temperature sensitive tape and Glyptol lacquer that are to be applied to several control panel

components. The tape is also'specified to be' examined before and after each running of the engine.

n a

4 0

r P

t-

.3

y  ; ,

-.s 4

, . LTXX-4377

- , iCPPA-42175J *~

p.

J.

r,

Texas Utilities believes-that. operating experience with the ,

subject components at CPSES Unit 1-has been extremely-

~ '

nc positive and does not warrant inspection at.the recommended, frequency.- No overheating or vibration problems, which the recommended measures are, designed to' detect -have-been Jencountered-with'these components even during extended full.

. f load runs of. the . ' engines. : On this basis, Texas Utilities

, proposes:that'the inspection be; performed at each refueling outage.

The DR/QR' maintenance an'd surveillance activities recommended by

~

-the'0wners' Group are to be incorporated into the CPSES Unit 1

. diesel generator. preventive maintenance and surveillance program,

'as: modified and/or' clarified above,as follows:

Monthly and; daily surveillance and maintenance items are to be' incorporated into the surveillance or~ maintenance programs prior to. exceeding 5% power at CPSES Unit 1. Items based on number'of' engine starts or hours of operation, as w211 as 18 month surveillance items, are included in this

' category.

-Surveillance-and maintenance items which are to be l accomplished on a refueling outage or longer ~ basis will be incorporated into the appropriate programs prior to the first. refueling outage.

.It should be noted, however, that evolution of the maintenance and: surveillance program can be expected to occur based on c cimplementation feedback. inspection results and on additional

~

input from NRC, the'0wners' Group,'TDI or othe applicable

~

sources.- Also,' variations in the methods of achieving the intent-of the recommendations may be necessary'upon implementation in L

order to provide a practical approach to maintenance. NRC is

'hereby requested to provide guidance on the' subject of possible future changes (both major and minor) to the programs for the reasons stated above, particularly regarding NRC notification of prospective changes.

Finally, the TDI inspection and maintenance forms referenced in the " Comments" section-of the maintenance matrix may or may not be used in the performance of the recommended activities.

-Maintenance instructions and procedures will specify which forms are to be used, if any, for a specified activity.

-.