05000293/LER-1998-001, :on 980127,single Failure Vulnerability of EDG Fuel Oil Supply Sys Was Noted.Caused by Failure to Clearly Translate Design Basis Assumptions Into Licensing Basis. Reviewed Affected Calculations & Determined Operability

:on 980127,single Failure Vulnerability of EDG Fuel Oil Supply Sys Was Noted.Caused by Failure to Clearly Translate Design Basis Assumptions Into Licensing Basis. Reviewed Affected Calculations & Determined Operability

ML20203L926
Person / Time
Site:	Pilgrim
Issue date:	03/03/1998
From:	Dicroce K BOSTON EDISON CO.
To:
Shared Package
ML20203L918	List: 05000293/LER-1998-001, :on 980127,single Failure Vulnerability of EDG Fuel Oil Supply Sys Was Noted.Caused by Failure to Clearly Translate Design Basis Assumptions Into Licensing Basis. Reviewed Affected Calculations & Determined Operability
References
LER-98-001, LER-98-1, NUDOCS 9803060310
Download: ML20203L926 (4)

LER-1998-001, on 980127,single Failure Vulnerability of EDG Fuel Oil Supply Sys Was Noted.Caused by Failure to Clearly Translate Design Basis Assumptions Into Licensing Basis. Reviewed Affected Calculations & Determined Operability

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ii)
2931998001R00 - NRC Website

text

___-_____ - ------ -

N..C Form 366

- (4-95)

U.S. NUCLEAR R !GULATORY COMMISSION APPROVED BY OMB NO. 31 A104 EXPlRES 04/3048

, LICENSEE EVENT REPORT (LER)

ESTurtED BURDEN PER RtSPoNSE To CouPt1 wits THis INFoRMAttoN COLLECTION REoVEST: 50 0 HRS REPORTED j

(See reverse for number of LES$oNS LEARNED ARE f.RPoRATED INTo THE UCENSNG PROCESS AND FLD BACK TO INDUSTRf.

digits /charactets for each block)

FORWARD COMMENTS REGARDING BURDEN ESTfAATE To THE lNFcRMATioN AND RECORDS h%NAGEMENT BRANCH (T-6 F3A U S.

NUCLEAR REGULATORY CCAeAIS$loN, WASHINGTON. DC 20$$S0001, AND To THE PAPERWORK REDUCTION PROJECT (31504104). OFFICE OF MANAGEM ANO BUDGET, WASHINGTON, DC 20503.

FACILITY NAME l1)

DOCKET NUMBER (2)

PAGE (?)

PILGRIM NUCLEAR POWER STATION TITLE (4) 05000 293 I I4 Singb Failure Vulnerabioty of the Emergency Diesel Generator Fuel Oil Supply System EVENT DATE (6)

LER NUMBER 18 REPORT DATE (7)

OTHER F ACILITIES INVOLVED (B)

BEQUENTIAL NUMBER REVISION McmN oAv vtia viin F AC4 ffy NAME NUMwa Mcuts oAv vE '"

DOCKET NUMBER WA MMO 01 27 98 98 001 00 03 03 98 N/A 05000 F ACILffy NAME DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED PUR$L' ANT TO THE REQUIREMENTS OF 1 11)

MODE ($)

N 20 2201 (b)

?) 2203(a)(2)(v) 22 2203(a)(1) 50 73(a)(2)(l)(B)

POWER 50 73(a)(2)Wlu) 20 2203(a)(3)(l)

X 50 73(a)(2)(ll)(B)

LEVEL (10) 100 20 2203(a)(2)(a) 20 2203(a)(3)(a) 50 73(a)(2)(x) 20 2203(a)(2)(u)

So 73(a)(2)(in) 73 71 20 2203(a)(4) 20 2203(a)(2)(in) 50 73(a)(2)(lv) 50 36(c)(1)

! OTHER 20 2203(a)(2)(tv) 50 73(a)(2)(v) 50 36(c)(2) spectry in Abstract below l

50 73(a)(2)fvn)

LICENSEE CONTAC i FOR THIS LER (12) or in NRC Forrn 366A Kristin R. DiCroce - Senior Regulatory Affairs Engineer TELEPHONE NUMBER (include Area Code)

(508)830-7667 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN 1 REPORTABLE To

CAUSE

SYSTEM COMPONENT MANUFACTURER HPROS

CAUSE

SYSTEM COMPONENT MANUFACTURER NPRDS REPORTABLE To I

l SUPPLEMENTAL REPORT EXPECTED (14)

X YES EXPECTED

_ MUNI H DAY M5t (Il ves, convicts EXPECTED SUDMISSloN DA'E)

NO SUBMISSION 05 08 98 ABSTRACT (Limit to 1400 spaces, i.e.,

DATE(16) approximately 15 single spaced typewritten lines) f l

On January 27, 1998, (16) potsntial single failure vulnerability in the diesel fuel oil supply systema review of t d2cign and licensing documentation identified conflicting bases for the EDG f A review of j

cystcm.

Efforts are ongoing to define and document uel supply l

cystem.

the design basis for the EDG fuel supply The rpparent cause was failure to clearly translate design basis assumpti liccnoing basis.

ons into the An engineering evaluation was performed to address fuel consumptionCo rmine operability.

fcilure.

The engineering evaluation provided the basis for concluding the EDGsassuming a single optrcble using EOPs.

baoic for the EDG fuel oil supply system. Corrective actions planned include clearly establishing the desi were l

Further corrective actions will be discussed in a cupplcmental report to this LER.

l Thio condition was identified while at colector switch in the RUN position.

100 percent reactor power with the reactor mode poig with the reactor water temperature at the saturation temperature for the rThe reactor ve pressure.

The condition posed no threat to public health and safety.

eactor 9803060310 900303 PDR ADOCK 05000293

NAC Form 300 U.S. NUCLEAR REGULATORY COMMitSiON APPROVED BY OMB NO. 31J0104

. (4M)

EXPIRES $4/30/98 L, ICENSEE EVENT REPORT (LER)

ESmATED BURDEN PER RESPONSE To CounmH THis INFoRMATioN COLLECTION REoVEST: 60 0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED INTo THE (See fever 50 for nurnber of LICENSING PROCESS AND FED BACK To INDUSTRY.

diOits/ characters for each block)

FORWARD Co64AENTS REGARDING BURDEN ESTfAATE To THE INFoRMATioN AND RECORDS MANAGEMENT BRANCH (T 6 F33). U 8.

NUCLEAR REGULATORY Cof4AISSloN.

WASHINGTON. DC 20$55 0001 AND To THE PAPERWORK REDUCTION PROJECT (3160 0104). of FICE oF MANAGEMENT AND BUDGET. WASHINGTON. DC 20503_

F ACILITY NAME (1)

DOCKET NUMBER (2)

PAGE (3) 1 OI 4 PILGRIM NUCLEAR POWER STATION 05000 293 TITLE (4)

Single Failure Vulnerability of the Emergency Diesel Generator Fuel Oil Supply Systern EVENT DATE (6)

LER NUMBER (6:

REPORT DATE (7)

OTHER FACILITIES INVOLVED (B) stouomAL NUMBE R Rt VI560N F ACIUff NAME DOCKt1 NUMBE R uo.m4 DAv

<t An vtAu Nuusta woNis n4v vcAn g

gg F Acstrty NAME DocKti NUMBE R 01 27 98 98 001 00 03 03 98 N/A 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR:(Check one or mve) 11)

MODE (#1 N

20 2201 (b) 20 2203(ax2)(v) 50 73(a)(2)(1)(B) 50 73(a)(2)(vai)

POWER 22 2203(a)(1) 20 2203(a)(3)(1)

X 50 73(aX2)(k)(B) 50 73(a)(2)(x)

LEVEL (10) 100 20 2203(a)(2)(1) 20 2203(a)(3)(c) 50 73ra)(2)(iii) 73.71 20 2203(a)(2)(61) 20 2203(a)(4) 50 73fa)(2)(W)

OTHER 20 2203(a)(2)(m) 50 36(c)(1) 50 73(a)(2)(v)

Spec #fy in Abstract below 20 2203(a)(2)(N) 50 36(c)(2) 50 73(a)(2)(vn) or in NRC Form 366A LICENSEE CONT ACT FOR THIS LER (12)

TELEPHONE NUMBER (include Area Code)

Kristin R. DiCroce - Senior Regulatory Affairs Engineer (508) 830 7667 COMPLETE ONE LINE FOR EACH COMPONENT F AILURE DESCRIBED IN THis REPGAT (135 REPORTABLE To REPORT ABLE To

CAUSE

SYSTEM COMPONENT MANUFACTURER NPROS

CAUSE

SYSTEM COMPONENT MANUFACTURER NPRDS SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED l M*1 H D^v I YLAN X

YES NO SUBMISSION 05 08 98 (If yes cornpiete EXPECTE0 SUBMISSloN DATE)

DATE(15)

ABSTRACT (Limit to 1400 spaces, i.e.,

approximately 15 single spaced typewritten lines) (16)

On January 27, 1998, a review of the EDG fuel oil storage calculations identified a potential single failure vulnerability in the diesel fuel oil supply system. A review of dscign and licensing documentation identified conflicting bases for the EDG fuel supply system.

Efforts are ongoing to define and document the design basis for the EDG fuel supply syctem.

The apparent cause was failure to clearly translate design basis assumptions into the licanaing basis.

Corrective actions were taken to review affected calculations and to determine operability.

An engineering evaluation was performed to address fuel consumption assuming a single failure.

The engineering evaluation provided the basis for concluding the EDGs were oparable using EOPs.

Corrective actions planned include clearly establishing the design basis for the EDO fuel oil supply system.

Further corrective actions will be discussed in a supplemental report to this LER.

Thio condition was identified while at 100 percent reactor power with the reactor mode aslector switch in the RUN position. The reactor vessel pressure was approximately 1035 poig with the reactor water temperature at the saturation temperature for the reactor pressure. The condition posed no threat to public health and safety.

9803060310 900303 ~

l PDR ADOCK 05000293 8

PDR

'NAC Form 366A U.S. NUCLEAR RECULATORY COMMISSION (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DocMET NUMBER (2)

LER NUMWER (0)

PAGE (3)

GEQUENTIAL REVISION YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION O N 93 98 001 00 2 of 4 TEXT (if more space to requwed, use addmonaNw i. of NRC Form 306A)(IT)

BACr4ROUND The safety objective of the standby AC power source is to provide a single failure proof cource of onsite AC power adequate.for the safe shutdown of the reactor following abnormal oparctional transients and postulated accidents assuming a complete loss of offsite power.

Two amergency diesel generators (EDGs) and their associated fuel supply systems were f eta 11ed to provide this source of standby AC power.

Ecch fuel oil supply system consists of a separate main fuel storage tank (T 126A/B) with a l

capscity of approximetely 25,000 gallons, a transfer pump (P 141A/B), and a day tank (T*

124A/B) with a capacity of approximately 600 gallons.

Provisions exist for cross connecting the normally independent fuel oil systems. Adequate fuel must be available on site to support EDG operations for seven days due to a loss of offsite porer (LOOP) in order to achieve and maintain safe shutdown of the reactor under accident conditions.

A minimum capacity of 19,000 gallons per tank is required by Technical Specification 3.9.A.3.

During a review to verify the minimum of 19,800 gallons per main storage tank was appropriate, several inconsistencies in calculation assumptions were identified. The conclusion was reached that the cross connection nti been assumed to be available in design cniculations in order to meet the design basis fuel requirements.

EVENT DESCRIPTION

During an engineering review of calculation St.SA 55 (rev. 5),

• Minimum On-Site Diesel Fuel Requirement," several inconsistencies in design assumptions and FSAR statements were idsntified.

An engineet tug evaluation (EE 98 011) was prepared to document the minimum fuel oil capacity requirements were adequate. During this review, it was recognized that without the use of approved EOPs, inst;ficient fuel capacity was available unless the croes-connection was utilized.

A problem report (PR 98.9052) was written to document the inconsistencies between the design masumptions and the FSAR. During a review of the problem report, a potential single failure vulnsrability in the EDO fuel oil supply system was identified.-

Specifically, it was diecovered that failure of either main storage tank suction check valve (38 CK-101A/B) would eliminate the ability to cross connect the tanks.

Engineering evaluation (EE 98-011) provided the original basis for concluding the EDGs were also operable for this single failure because the technical specification required minimum of 19,600 gallons of fuel per diesel generator is sufficient to ensure that either diesel can run at specified loads using EOPs for seven days without delivery of fuel from offsite scurces.

The licensing basis for the EDGs was reviewed and conflicting statements for the use of the cross connect were identified. The original design calculation for fuel storage tank technical specification capacity appears to have credited the manual cross connect and availability of both main storage tanks for fuel consumption by either EDO.

The inconsistet4ci69 in the licensing and design basis information resulted in inadequate documentation to recognita that the cromconnect needed to be integrated into system operation. Based on capa ry roquiremen e (sum of both tanks being available for either diesel) for single train operation, operator action is required to ensure an adequate fuel supply.

With the failure of a single EDG to start in response to a LOCA with LOOP, the remaining EDG will consume rme than the technical specification minimum of 19,000 gallons of fuel per discel during Lue first seven days without operator use of EOPs. A supplement to the engineering evaluation (EE 98 011) was issued to address EDG loading per FSAR Table 8.5-1.1

N7C Form 366A l

- (4 M)

U.S. NUCLEAR REWLATORY COMMISSION i

I LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION F ACILITY NAME (?)

DocMET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEQUEN TIAL RE VISION YEAR NUMBE R NUMBER PILGRIM NUCLEAR POWER STATION N 283 98 001 00 3 of 4 1Ex T (itEspue es reqwred, use addrhonal copes of NRC Form 3*6A)(IT)

Op2rator action is required in order to use the cross connect capability provided by original design.

" Locked Component Lineup Surveillance," for the norina11y locked closed valv 8.C.13, 103), and the Inservice Tenting (IST)

(38-HO-Valve Testing Program," for the foot check valves (38 CK 101A/B). program per procedure 8.I.1.1,

" Inservice Pump and Th3 colector switch in the RUN position. condition was identified while at 100 percent reactor power with the rea pcig with the reactor water temperature at the saturation temperature for the reactorThe reactor v proc 2ure.

CAUSE

The cpparent causes were failure to clearly translate design basis assumptions into the licensing basis and failure to establish proper configuration control.

CORRECTIVE ACTION

Ths NRC Operations Center was notified in accordance with 10 CFR 50.72 (b) (1) (ii) (B)

)

houro on January 27, 1998, at 1850 potentially outside the design basis.due to the belief that a condition was identified to be i

Calculation S&SA 119 (rev. 0).

with LOOP Using EOPs," was prepared to conservatively determine the quantity of fuel t would be consumed.

consumed over seven days following a design basis accidentIt was determined that less than 19,800 g (DBA)

EDG (single failure) using approved emergency operating proceduresLOCA w/ LOOP and loss of one (EOPs).

An engineering evaluation (EE 98-011) was prepared to document the minimum fuel oil capacity requirements were adequate.

During this review, it was recognized that without the use of tpproved EOPs, insufficient utilized.

Engineering evaluation (EE 98-011) fuel capacity was available unless the cross-connection was provided the original basis for concluding the minimum of 19,800 gallons of fuel per diesel generator is sufficient to ensu diosal can run at offsite sources.

specified loads using EOPs for seven days without delivery of fuel from A supplement to the engineering evaluation (EE 98 011)

FSAR Table 8.5 1 and identify operator action needed to cross connect the other tankwas issued to address ED Further corrective actions will be discussed in a supplemental report by May 8 1998.

SAFETY CONSEQUENCES

This condition did not result public health and safety.

in any component or system failure and posed no threat to Engineering evaluation (EE 98-011) oporcble based on conrideration of EOP response capabilities,provided the basis for determining that the ED and tenk capacity.

assuming the loss of one EDG This report is submitted in accordance with 10 CFR 50.73 (a) (2) (ii) (B) tha diesel fuel oil transfer system which represented operation outside des because a review of n

N4C FORM 366A (4-M)

NRC Form 306A U.S. NUCLEAR REGULATORY COMMISSloid (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION F ACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION N33 98 001 00 4 of 4 SIMILARITY TO PREVIOUS EVENTS A review of Pilgrim Station LERs submitted since 1984 was conducted based on the plant being outside its design basis. The review of LERs focused on those submitted in accordance with 10 CFR 50.73 (a) (2) (ii) involving the EDGs or EDO fuel supply system.

The review identified LER 97-021 00, " Emergency Diesel Generator Ambient Air Temperature," and LER 97 027-00,

" Emergency Diesel Generator Winter Ambient Temperature."

ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) CODES The EIIS codes for this report are as follows:

COMPONENTS CODES Generator, diesel DG Pump P

Tank TK SYSTEMS Emergency on-site power supply system EK Fuel receiving storage, and transfer system DE NRC f ORM 3f6A (4 95)

Licensina Correspondence Control Shee_j Outgoing NRC Letter 2.98.024 Date: 2/27/98 Distribution:

• Except for those personnel annotated with an *, the report was electronically distributed l

Licensing File *#1 l

J.F. Alexander B. Gaedtke (NSRAC)

T. McEthinney T.A. Sullivan l

G. Anderson (NWE)

J.P. Gerety H.V. Oheim T.S. Swan N.L. Desmond C.S. Goddara J. Ohrenberger D.F. Tarantino W.J. DiCroce K. Gracia (NWE)

J. Plummer (FERC)

T.E. Trepanier K.R. DiCroce R. Haistett (NWE)

M. Potkin B. VanVleet (NWE)

D.W. Ellis*

M. Jacobs (NWE)

M. Probasco (NWE)

T.A. Venkataraman V. Fallacara (NWE)

J.W. Keene W.J. Riggs L.E. Wetherell G. Fiedler (NWE)

J.D. Keyes M.B. Santiago N.F. Wetherell Jeff Fox (NWE)

V. Magnatta (NWE)

J. Scaccia T. White J.M. Fulton P. Mastrangelo (NWE) J.A. Seery Donald Williams (NWE)

DCC' W.B. Stone S.S. Wollman Off site Distribution:

Gautam Sen J. J. Keane

• Bruce Hayden Vermont Yankee VP Energy Supply Senior Engineer 185 Old River Road Comm Electric Eastern Utilities Assoc.

Brattleboro, VT 05301 2421 Cranberry Highway P.O. Box 543 Wareham, MA 02571 W, Bridgewater, MA 02379 Mr. Roger Bacon

• Manager, Power Brokering MMWEC P.O. Box 426 Ludlow, MA 01056 TAlg: LER 98-00100 "O slo Failure Vulnerability of the Emergency Diesel Generator Fuel Oil Supply System' Date: March 2,1998 Distribution Reviewed Bv:

Kristin R. DiCroce Action:

Provide supplement to LER 98 00100 by May 8,1998 (RC 98.2024).

KRD id: ter9800100