05000244/LER-2014-001, Re Total Particulate Concentration in B Emergency Diesel Generator Fuel Oil Storage Tank Exceeded Acceptance Criteria - Cause Attributed to Contamination from Using a Temporary Fuel Oil Storage Tank
| ML14079A521 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/19/2014 |
| From: | Philippon M Constellation Energy Group, EDF Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 14-001-00 | |
| Download: ML14079A521 (8) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2442014001R00 - NRC Website | |
text
Michel Philippon Plant General Manager CENGS.
a joint venture of Constellation q'#-eDF
- SEnergy, 40eD Office: 585-771-5205 Fax: 585-771-3943 Email: Michel.Philippon@cengllc.com March 19, 2014 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
SUBJECT:
Document Control Desk R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 LER 2014-001, Total Particulate Concentration in B Emergency Diesel Generator Fuel Oil Storage Tank Exceeded Acceptance Criteria -
Cause
Attributed to Contamination from using a Temporary Fuel Oil Storage Tank The attached Licensee Event Report (LER) 2014-001 is submitted under the provisions of NUREG-1022, Event Reporting Guidelines. There are no new commitments contained in this submittal.
Should you have any questions regarding this submittal, please contact Thomas Harding at 585-771-5219.
Sincerely, Aý 1 l-MP/CS
Attachment:
(1)
LER 2014-001 cc:
NRC Regional Administrator, Region I NRC Project Manager, Ginna NRC Resident Inspector, Ginna R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road, Ontario, New York 14519-9364 y~99~
Attachment (1)
LER 2014-001
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/3112017 (02-2014)
Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
Reported lessons learned are incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the FOIA, Privacy and Information Collections "EE EENT Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by LICENSEE EVENTI REPORT (
internet e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and (See Page 2 for required number of Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC for each block) 20503. If a means used to impose an information collecton does not display a currently valid OMB digits/characters fcontrol number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE R.E. Ginna Nuclear Power Plant 05000 244 1 OF 6
- 4. TITLE Total Particulate Concentration in B Emergency Diesel Generator Fuel Oil Storage Tank Exceeded Acceptance Criteria - Cause Attributed to Contamination from using a Temporary Fuel Oil Storage Tank
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REVMi FAC,',YNAME DOCKET NUMBER YER NUMBER NO.
MOT A
ER05000 FACILITY NAME DOCKET NUMBER 01 20 2014 2014 -
001 0
03 18 2014 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
E] 20.2201(b)
E] 20.2203(a)(3)(i)
E] 50.73(a)(2)(i)(C)
E] 50.73(a)(2)(vii).
[]
20.2201(d)
E] 20.2203(a)(3)(ii)
[I 50.73(a)(2)(ii)(A)
F1 50.73(a)(2)(viii)(A)
D] 20.2203(a)(1)
E] 20.2203(a)(4)
[
50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A) 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL F] 20.2203(a)(2)(ii)
[
50.36(c)(1)(ii)(A)
EI 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x) 20.2203(a)(2)(iii)
D 50.36(c)(2)
[]
50.73(a)(2)(v)(A)
D 73.71(a)(4) 10 20.2203(a)(2)(iv)
F] 50.46(a)(3)(ii)
[j 50.73(a)(2)(v)(B)
E 73.71(a)(5) 100%
D 20.2203(a)(2)(v)
[
50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(C)
[
50.73(a)(2)(i)(B)
D 50.73(a)(2)(v)(D) specifyoin Abtract below or in
I. DESCRIPTION OF EVENT
A. PRE-EVENT PLANT CONDITIONS:
The reactor was in Operational Mode 1 at 100% power, 2235 psig and 574 degrees F.
B. EVENT:
On January 7, 2014, fuel oil samples were collected from the "A" and "B" Emergency Diesel Generator (EDG) fuel oil storage tanks (TDG01A and TDG01 B respectively) per Technical Specification (TS) Surveillance Requirement (SR) 3.8.3.2, for routine testing. The samples were shipped to an outside laboratory for analysis; the laboratory analytical results were received at Ginna on January 20, 2014. The laboratory report indicated that the total particulate concentration in the TDG01A was 1.0 mg/L and the total particulate concentration in the TDG01 B sample was 14.0 mg/L. The total particulate concentration in TDG01B exceeded the 10.0 mg/L acceptance criteria established by TS 5.5.12, "Diesel Fuel Oil Testing Program." Due to the 13 day lapse between sample collection and licensee receipt of analytical results, the Completion Time of seven (7) days for TS Limiting Condition for Operation (LCO) 3.8.3, "Diesel Fuel Oil,"
Condition B, "Restore fuel oil total particulates within limit," had been exceeded. A second sample, for confirmation, was collected from TDG01B on January 20, 2014. The total particulate concentration in the second sample was 24.3 mg/L. These results were communicated to Ginna on January 22, 2014.
Samples were collected from TDG01 B throughout the event. In the interest of timely receipt of results and as a cross-check, samples were sent to outside laboratory (Lab 1) in California and to an in-house laboratory (Lab 2) in Pennsylvania. Pertinent dates for sample shipping and receipt of results are presented in Section I.D.
The event was captured in the Corrective Action Program under CR-2014-000303.
C. INOPERABLE STRUCTURES, COMPONENTS OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:
No other inoperable structures, systems, or components contributed to the event.
D. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES
All TDG01 B samples referenced below were collected from the normal sample point off the fuel oil transfer pump, unless otherwise specified.
April 3 - 4, 2013 Maintenance performed that used a temporary storage tank to hold fuel oil from TDG01 B.
May 2013, through November 2013 January 7, 2014 January 20, 2014 January 21, 2014 January 22, 2014 Samples collected from TDG01B per SR 3.8.3.2. Total particulate concentration is slightly elevated, but within acceptance criteria.
Fuel oil sample collected from TDG01B.
Sample results indicating fuel oil particulate concentration is outside of acceptance criteria are received at Ginna.
Confirmatory sample collected and shipped to Lab 1.
Commenced filtration of TDG01 B.
Collected two TDG01B samples after commencing filtration, one shipped to Lab 1, one shipped to Lab 2.
Confirmatory results from 1/20 Lab 1 sample are received, particulate concentration is outside of acceptance criteria.
Sample results from 1/21 sample sent to Lab 2 are received, results are within acceptance criteria.
Collected two TDG01 B samples, one shipped to Lab 1, one shipped to Lab 2.
Total of four samples, two for each lab, collected and analyzed since commencing filtration have total particulate results within acceptance criteria.
Several supplemental samples are collected and analyzed. Inconsistent results are received from the two different labs. The average of the sample results remains elevated, but still within the acceptance criteria.
The filtration process is secured and plans are developed to drain, clean, inspect, and refill TDG01B with fuel oil from the "A" off-site storage tank, TMN03.
TDG01B is drained, cleaned and inspected. Tank is filled with fuel oil from TMN03. TDG01B is sampled and total particulate concentration is within acceptance criteria.
Three supplemental samples are collected at approximately weekly intervals. All results verify total particulate concentration has returned to baseline.
January 23, 2014 January 24, 2014, through January 28, 2014 February 3 - 4, 2014 February 2014
E. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED
None
F. METHOD OF DISCOVERY
Discovered during performance of scheduled Technical Specification Surveillance Requirement.
G. MAJOR OPERATOR ACTION:
Extent of condition review performed to verify TDG01A, "A" EDG fuel oil storage tank, was not impacted. Testing of "A" EDG fuel oil had returned acceptable results.
The TS 3.8.3 LCO Condition D "Required Action and associated Completion Time not met" was not entered during this event; the "B" EDG was not declared inoperable due to this event, and the "B" EDG fuel oil total particulate concentration was returned to an acceptable concentration within seven (7) days of the initial discovery that it was outside acceptance criteria.
H. SAFETY SYSTEM RESPONSES:
None If. CAUSE OF EVENT:
In April, 2013, the fuel oil in TDG01 B was pumped to a temporary storage tank in order to clean and inspect TDG01 B. The temporary storage tank was acquired from an outside vendor.
Following this work, the results of the Technical Specification SR 3.8.3.2 performed in May 2013 indicated a step change increase in total particulate concentration in TDG01B. The average total particulate concentration of samples available prior to performing the work was 2.1 mg/L.
Following the work performed, the average of the samples taken was 4.1 mg/L, which is within the acceptance criteria of 10.0 mg/L.
Review of the work order controlling the clean/inspect task determined there were no steps or actions placed in the work instructions to ensure cleanliness of the tank supplied by the outside vendor prior to placing fuel oil in it. Review of the quote from the outside vendor for the task also indicated no condition or requirement regarding tank cleanliness prior to use.
Therefore, the probable cause is that the temporary storage tank used to hold the fuel during the April 2013 maintenance contained contaminants that negatively impacted particulate concentrations.
This information explains the step change in TDG01 B fuel oil total particulate concentration following completion of the April 2013 maintenance. It is apparent there was a substance in the temporary storage tank used that contaminated the fuel. The contamination led to degradation of the fuel that resulted in particulate results outside the range of the acceptance criteria.
I1l. ANALYSIS OF THE EVENT:
The TDG01 B sample results indicated that the particulate concentration in the fuel oil storage tank had exceeded the allowable particulate specification since January 7, 2014. The previous
quarter sample, collected in November 2013, had been within acceptance criteria. There was a 13 day period between the first sample and receipt of the corresponding analytical results.
Technical Specification (TS) 3.8.3, "Diesel Fuel Oil," LCO 3.8.3, Condition B, "One or more required DGs with stored fuel oil total particulates not within limit," requires that the fuel oil total particulates be returned within limit within seven (7) days. Due to the delay in receipt of analytical results, the 7-day LCO completion time requirement was exceeded.
Therefore, the condition is reportable under 10CFR50.73(a)(2)(i)(B) criteria.
There were no safety consequences as all safety related systems remained operable during this event. Total particulate concentration exceeding the acceptance criteria for a short period of time is acceptable because the presence of particulate does not mean the fuel will fail to burn properly in the EDG. If not corrected, particulate can cause fouling of filters and fuel injection equipment which eventually may cause engine failure. However, the potential for this is minimized by the frequency of sampling the storage tanks (92 days) which allows ample time to correct any quality issues with the fuel oil before they have the potential to affect the operability of the EDG. Additionally, the surveillance requirement to verify each EDG starts from standby conditions and achieves rated voltage and frequency every 31 days provides reasonable expectation the EDG is fully operable. The operational tests and periodic surveillances ensure no long term failure will be caused by this short period of total particulate outside the acceptance criteria This event will have no effect on NRC Performance Indicators.
IV. CORRECTIVE ACTIONS
A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:
A work order was implemented to establish continuous filtration of TDG01 B commencing on 1/21/14. During the period of continuous filtration, samples were collected from the discharge of the filter on two separate occasions. These samples indicated that the filtration was not achieving a satisfactory reduction in total particulate concentration; therefore the filtration was secured on 1/26/14. After further evaluation, the decision was made to replace the fuel oil in the tank. This was completed on February 4, 2013. The most recent test results show total particulate concentration of 0.5 mg/L, within the acceptance criteria of 10.0 mg/L.
B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE Guidance will be added to the procedure controlling work utilizing temporary storage containers or tanks (tanker trucks, frac tanks, barrels, poly tanks, etc.) to ensure the temporary tanks meet the same cleanliness criteria as the systems they are being used to service.
Corrective actions for timeliness of test results are in progress to update the purchase order with the laboratory to ensure total particulate samples are analyzed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of receipt and that the Operations Shift Manager is on the distribution list for results.
V. ADDITIONAL INFORMATION
A.
FAILED COMPONENT No components failed.
B.
PREVIOUS LERS ON SIMILAR EVENTS A review of Ginna events over the past five years identified no similar events.