05000298/FIN-2015004-01
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Finding | |
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| Title | Diesel Fuel Oil Cloud Point Acceptance Criteria not in accordance with ASTM D975, Revision 1989a |
| Description | The inspectors identified a non-cited violation of Technical Specification 5.5.9, Diesel Fuel Oil Testing Program, for the licensees failure to establish an emergency diesel generator fuel oil cloud point acceptance criterion in accordance with ASTM D975, Standard Specification for Diesel Fuel Oils. Specifically, the diesel fuel oil cloud point acceptance criterion of = 32F specified in the licensees diesel fuel oil testing program procedures was not in accordance with the ASTM limit of = 3.2F and was not technically justified as described by the standard. Corrective actions included development of an evaluation which concluded that the appropriate acceptance criterion was = 15F based on the most limiting day tank room temperatures during accident conditions; verification that the cloud point of the fuel onsite at the time was 8.6F, which met this criterion; and establishment of compensatory measures to monitor and administratively control the cloud point until fuel oil program procedures could be revised. The licensee entered this deficiency into the corrective action program as Condition Reports CR-CNS-2015-06745, CR-CNS-2015-06717, CR-CNS-2015-06718, and CR-CNS-2015-7150. The licensees failure to establish a diesel fuel cloud point acceptance criterion in accordance with ASTM D975, in violation of Technical Specification 5.5.9, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to establish a diesel fuel cloud point acceptance criterion in accordance with ASTM D975 could result in formation of wax crystals affecting the capability to transfer the fuel oil from the storage tanks to the emergency diesel generator engine cylinders. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Finding At-Power, dated June 19, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. The finding had a cross-cutting aspect in the area of human performance associated with documentation because the licensee failed to create and maintain complete, accurate, and up-to-date documentation for the worst case temperature at which the emergency diesel generator fuel oil would be stored [H.7]. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2015004 Section 1R01 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | B Larson C Henderson E Simpson G Warnick J Kirkland J Robbins M Hayes P Elkmann P Voss S Garchow |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Cooper - IR 05000298/2015004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2015Q4
Self-Identified List (Cooper)
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