05000305/LER-1989-005, :on 890310,insp of Diesel Generator Start Up Air Sys Finds Deficiencies That Could Render Both Diesel Generators Inoperable Due to Inadequate Design.Cause Unknown.Generic Implications Will Be Examined
| ML20244C548 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 04/10/1989 |
| From: | Steinhardt C, Webb T WISCONSIN PUBLIC SERVICE CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-041, CON-NRC-89-41 LER-89-005, LER-89-5, NUDOCS 8904200267 | |
| Download: ML20244C548 (11) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3051989005R00 - NRC Website | |
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i On March 10, 1989, with the plant in refueling shutdown, a management review of the instrument air system inspection findings concluded that deficiencies in the design of the emergency diesel generator air start system could render both l
diesel generators inoperable. These deficiencies include:
- 1) A lack of seismic documentation 2) components in the system exposed to pressures greater than their design pressures. One item of potential generic interest was also iden-tified.
It concerns long term post accident operability of the diesel generator ventilation dampers.
These deficiencies were the result of inadequate design and inadequate second level reviews of modifications and engineering evolutions.
The modifications relevant to this report occurred in 1973 during original plant construction and i
as a result of a subsequent modification in 1981. A contributing factor was an inappropriate change made to the quality assurance type of a portion of the system as part of a modification.
The deficiencies identified in this report will be corrected prior to the end of the current refueling outage. The procedures for providing second level reviews of proposed design changes have been revised since the end of plant construc-tion, the most recent revision occurred in November of 1988. The revisions were implemented to provide additional assurance that the reviews are conducted by qualified personnel and to the proper depth. The quality assurance procedures will be reviewed and revised as necessary to ensure that adequate evaluations are conducted of proposed QA typing changes.
These changes will help prevent 4
recurrence of similar u ents.
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Description of Event
On March 10, 1989, with the plant in refueling shutdown, a management review of the instrument air system inspection findings concluded that deficiericies in'the-design of the emergency diesel generator air. start system [LC] could render both diesel generators [DG] inoperable. There are two diesel generator air start trairs at the Kewaunee plant, one for each diesel generator. Each diesel generator air start train supplies QA-1 (safety-related) compressed air at a nominal pressure of 250 psig to the following components (refer to Figures 1 and 2):
.1.
four diesel generator air start motors [M0],
2.
diesel generator ventilation dampers [DMP], (the outside air supply and recirculation dampers modulate to maintain room air ten;perature at
.approximately 85'F),
3.
the service 9ater [BI] control valve [FCV] that supplies water to the diesel generator oil coolers [HX].
This system was inspected by Wisconsin Public Service Corporation's (WPSC's) 3afety System Engineering Group as part of their functional. inspection of the instrument air system.
The Safety System Functional Inspection (SSFI) program is a self initiated endeavor that assesses the operational readiness of safety systems at the Kewaunee Nuclear Power Plant. The SSFI of the diesel generator air start system identified two deficiencies and one item of potential generic interest. The two deficiencies identified by the SSFI are as follows.
1.
The documentation of the seismic adequacy for the mounting of the small diameter copper tubing [TBG] that supplies positioning air to the diesel generator ventilation dampers could not be located.
Furthermore the seismic documentation for components on the tubing (Johnson controller, damper air accumulator, etc.) could not be located.
2.
The design pressure of several components connected to the system is less than the system's maximum operating pressure.
As an item of potential generic interest, the SSF1 calculated that there was sufficient capacity stored in the primary air receivers to modulate the diesel generacor combustion dampers for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> post accident.
The two deficiencies were traced to original plant construction during the years 1968 through 1974. The item of generic interest occurred as a result of the implementation of design change request (DCR) 975 in 1981. The deficiencies and the item of generic interest are described in greater deteil in the following text. The text is divided into a section describing the deficiencies thit occurred during original plant construction and into a section describing the i
implementation of DCR 975.
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, nn Original. Plant Construction A search of historical records indicates that prior to September of 1973, the combustion air supply dampers were to be supplied with positioning air from the
'1 instrument air system [LD]. The instrument air system is a QA-2 system (not safety related) that supplies compressed air at a nominal pressure of 125 psig to air operated components in the plant.
In the original desi0n, the outside air supply dampers and the room exhaust dampers failed to the closed position to prevent a fire in a diesel generator room from spreading.
Since instrument air is not safety related and could not be assumed to function postaccident, accumu-lators [TK] were added to provide for damper control postaccident.
Kewaunee's architect engineer (A/E) Fluor Daniel (formerly Pioneer Services and Engineering) designed the'systen. The A/E changed the design of the system in September of 1973 apparently when the need to modulate the dampers was iden-tified. The revised design supplied the diesel generator recirculation and out-side air supply dampers with positioning air from the diesel generator air start system. Since the entire diesel generator air start system was QA-1 at that
. time, the dampers _could be absumed to operate indefinitely postaccident once they were connected to the system.
Although the design change resulted in a safety related supply of positioning air to these dampers, documentation of the following could not be located:
1.
An evaluation of the installed instrument air components for the increase in system pressure from 125 psig to 250 psig. As a result, a number of components on the compressed air supply line to the diesel generator ven-tilation dampers were exposed to prassures greater than their design-pressures.
Upon discovery of underrated components, steps were immediately taken to remove underrated isolable components from service.
2.
Analysis of the seismic adequacy for the positioning air supply (tube mounting, component mounting, etc.) to the diesel generator ventilation dam-pers. Since documentation of the seismic adequacy could not be located, the lines were visually inspected. The inspection determined that the lines would probably nct meet current seismic requirements.
Currently, it is not possible to determine if these findings were actual deft-ciencies or a result of poor documentation. To be conservative and to assure compliance with the reporting requirements in 10 CFR 50.73, the assumption was made that the these two findings were deficiencies. Therefore both diesel generators were declared inoperable. Although both diesels were declared ino-perable, at least one of the diesel generators was functionally available at all times during the current refueling outage.
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DCR 975 was implemented to install an aftercooler [CLR], a moisture separator-
[SEP], and an air dryer [ DRY] at the discharge of the diesel generator air start i
compressors [ CMP]. This DCR was implemented to improve the quality of air in the diesel generator air start system and thereby improve diesel generator reliability. At the time this DCR was implemented, the design engineer (DE), a contract employee, could not locate a vendor who could supply the equipment to meet the quality assurance requirements specified for safety related equipment.
Therefore, the DE reviewed relevant documents to determine the diesel generator air start system's safety related functions. His investigation determined that the system's safety related function was to crank the diesel generator for twenty seconds. Since this could be accomplished by each pair of air receivers, without being recharged by the compressor, the DE proposed moving the QA-1 boun-dary from the compressor to the check valves at the inlet of the receivers [SA-2001AP(BP) and SA-2001AR(BR)]. Based on this analysis, the Quality Assurance (QA) Typing Committee approved the DE's proposed QA typing change.
Therefore the equipment upstream of the air receiver inlet check valves was reclassified as non-safety related and was subsequently maintained and modified as non-safety related equicaent. Therefore, they could no longer be assumed to function post accident.
It appears that either the diesel generator air dampers were not identified as safety related loads on the air start system or the review of these loads was not properly documented. The SSFI determined that there would be sufficient capacity in the primary rect. vers to modulate the ventilation dampers for i
approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> after a diesel generator start. This assumes that the l
compressors would not be available to recharge the receivers.
Some tima after i
the diesel generators started, the operators would receive a low pressure alarm (200 psig) on receiver pressure. The operrtors would be directed to either valve in the reserve receivers (approximaf.ely 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of additional operation) or to start the air compressor.
1 Although, there are no explicit Technical Specifications (TS) on postaccident damper operability, WPSC has determined that it would be desirable to have these dam-pers operate for seven days postaccident without taking credit for operator action. This is consistent with the TS requirement on diesel fuel oil.
In addition to the SSFI findings described in this report, the SSFI also iden-tified potential deficiencies in the design of the diesel generator exhaust ducting, in the recirculation air ducting, and in the mounting of the pressure f
gauges on the air receivers. This equipment was identified as having potential deficiencies because the original documentation of its seismic adequacy could not be located. An analysis of the diesel generator exhaust ducting and recir-culation ducting has been completed and confirms that they did meet Kewaunee's seismic design basis. The analysis of the mounting for the air receiver pressure gauges has not been completed. However, the QA-1 isolation valves mounted on the air receivers have been closed to ensure the operability of the air receivers. They will remain closed until an analysis shows that the existing design is adequate or until the existing supports are modified to meet Kewaunee's seismic design basis.
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Cause of Event
Due to the lag between the time that these deficiencies occurred and the time they were discovered, the cause of these deficiencies cannot be unequivocally determined. Furthermore, some of the key personnel involved in these projects are no longer available to supply clarification concerning these findings.
Based on our investigation, it appears that the deficiencies that occurred during plant construction are the result of inadequate design and design review.
In addition, the QA typing comittee's approval to change the diesel generators air start system's QA-1 boundary was based on an incomplete eva-luation.
Analysis of Event
This event is being reported in accordance with 10 CFR 50.73(a)(2)(v) as an event that alone could have prevented a safety system from mitigating the con-sequences of an accident and as an item of potential generic interest. This event was also reported in accordance with 10 CFR 50.72(b)(2)(iii) at 1715 on March 10, 1989.
The deficiencies identified in this report could have resulted in the following scenarios.
1.
Positioning air to the diesel generator ventilation dampers is lost as a result of a seismic event.
2.
As a result of exceeding their design pressure rating, one or more of the overpressurized components ruptures.
The item of potential generic interest could have resulted in the diesel genera-tor ventilation dampers depleting the air receivers 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> after a diesel start.
A separate discussion of each scenario follows.
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gaping 8 8/3146 f actLeiv maast sti pocati Nunset a (21 Lin NuneDER les past tas Kewaunee Nuclear Power Plant o is to jo jo l 3l0l5 8l 9 0 l0 ; 5 0;O 0l 6 1 l0 or TtXT IR naere anene e omouneet uer enemanent NMC Sanm Ms)11n Positioning Air To The Diesel Generator Room Dampers Is Lost As A Result Of A Scismic Event The design of the ventilation system for the-two diesel generator rooms, refer to figure 2, is the same except for the design of the room air. exhaust dampers.
Diesel generator 1A room air is exhausted to the screenhouse, and the room exhaust damper (TAV-62A) is positioned by compressed air supplied from.the instrument air system with an accumulator back-up.
Tne air in diesel generator room 1B is exhausted to the outside and the damper (TAV-628) is positioned by
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compre: sed air supplied from the 18 diesel generater air start system.
In order to prevent a fire in one diesel generator room from spreading, the outside air supply dampers and the room exhaust dampers receive a signal to close on high temperature (160*F). They also fail closed on a loss of positioning air or on a loss of electrical power to their associated solenoid valves. The recirculation dampers are not a fire boundary and therefore do not receive a signal to close on high temperature. The recirculation dampers fail open on a loss of posi-tioning air and on a loss of electrical power to their associated solenoid valves.
If the positioning air supply lines to the dampers rupture during a design basis seismic event, the dampers would fail as previously described. Although there would be sufficient combustion air available in the diesel generator room for the associated diesel generator to start, continued operation of the diesel generator could be prevented by an insufficient-supply of combustion air or by I
t.n insufficient supply of cooling air. Prior to the diesels tripping, it is likely that a diesel generator high stator temperature alarm would actuate, due to a lack of cooling air. During a previous refueling outage, equipment i
problems caused the outside air supply damper to close and the high stator tem-i perature alarm actuated. The operators responded to this alarm by opening the doors to the diesel generator room and posting a fire watch in the area. This provided sufficient ventilation for short term (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) diesel generator opera-tion. Long term operation of the diesel generators with this ventilation con-figuration was not attempted. However, it can be assumed that the operators would initiate actions to open the dampers or to provide alternate ventilation with portable equipment within the two hours.
It is unlikely that the positioning air supply line to the diesel generator ven-l tilation dampers would have ruptured during a seismic event before the event generated a diesel generator start signal.
If this scenario did occur, the pri-mary air receivers would deplete in approximately 100 seconds to a pressure that would be insufficient to start the diesel generators. However, it is unlikely that a seismic event could render the diesel generator air start system ino-perable and not generate a aiesel generator start signal. A diesel generator start signal would have been initiated by a turbine trip, a safety injection l
signal, or a blackout signal.
Furthermore, the reserve air receivers would be available to supply additional capacity to start the diesel generators.
Based on this analysis there is reasonable assurance that operator actions could have 1
been taken to provide for continued diesel generator operation following a seismic event.
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service whenever the diesel generator is required to be operable. Therefore the components, including those components with design pressures less than operating pressure of the system, have been exposed to the system's operating pressure since they were installed. This overpressure condition has not resulted in a failure. Therefore experience and design margin provide reasonable assurance that these components would function as required during a design basis event.
The Diesel Generator Ventilation Dampers Deplete The Air Receivers If the positioning air supply line did not rupture during a design basis event, but the air compressors become inoperable, the air receivers would be the only source of safety related air to the loads on the diesel generator air start system. There would be sufficient air capacity stored in the receivers to start l
the diesel generators. Conservative calculations indicate that there would only be enough capacity air remaining in the primary receivers to modulate the com-bustion air supply dampers for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />.
Explicit guidance con-cerning the length of time that the dampers are required to operate postaccident could not be found in Kewaunee's Technical Specifications (TS) or in the Updated Safety Analysis Report. However to be consistent with the TS on diesel genera-tor fuel oil, WPSC has taken the conservative interpretation that these dampers are required to be operable for seven days postaccident.
Although the diesel generator air start compressors were downgraded from QA-1, they are supplied by opposite trains of emergency AC power. Therefore they could be considered reliable and likely to be available postaccident. With the I
compressors operable, the dampers would continue to operate indefinitely.
If the air compressors fail, the operators will receive a low pressure alarm (200 psig) on low diesel generator startup receiver pressure. Upon receiving this alarm, the operators would be directed to either valve in the other pair of air receivers (approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of additional operation) or to start the diesel generator air start compressor.
If the compressors were inoperable for i
some reason, the additional 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> would supply sufficient time to make the necessary repairs to one of the compressors and provide for continued diesel generator operability. Additionally, it is reasonable to assume that manual corrective actions could be taken, as described earlier, to provide adequate combustion air and ventilation to the diesel generators.
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Corrective Actions
Insnediate actions were taken to remove underrated isolable components from service..
Prior to the end of the refueling outage currently in progress, the deficiencies identified in this report will be corrected. The air lines and the components supplying positioning air to the diesel generator ventilation dampers will be replaced and installed to meet Kewaunee's seismic design basis requirements. To ensure that the diesel generator air start compressors are operable post acci-dent, the diesel generator start system's QA-1 boundary will be moved back to include the air compressor. This will also be completed prior to the end of the current outage..
Since the.end of plant construction, the. procedures providing design guidance and second level reviews of DCRs have been revised, including a recent revision in November of 1988. These revisions have been made to provide assurance that second level reviews. cover all aspects of a DCR; 1.e., mechanical, electrical, material, etc., and that the engineers conducting the review are skilled in their area of the review.
1 As a' result of these findings, the procedures for submitting QA typing changes to the QA typing committee are presently under review. The procedures will be revised as necessary to provide more indepth and proceduralized evaluations of proposed QA typing changes. Specific attention will be given to proposals for changing the typing of QA-1 components or systems.
The generic implications of these findings, as they apply to other safety systems at the Kewaunee plant, will be examined by WPSC's continuing SSFI Program.
Additional Information
Equipment Failures:
None
Similar Events
LER 89-001-00 SSFI Inspection Results of the Internal Containment Spray System.
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TELECOPIER (414) 433-1297 EASYLINK 62891993 WISCONSIN PUBLIC SERVICE CORPORATION 600 North Adams
- P.O. Box 19002
- Green Bay, WI 54307-9002 f:
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April 10,.1989 10 CFR 50.73
- - U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Reportable Occurrence 89-005-00 The attached Licensee Event Report for reportable occurrence 89-005-00 is being submitted in accordance with the requirements of 10 CFR 50.73, " Licensee-i Event Report System."
Sincerely,
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.C. R. Steinhardt Manager - Nuclear Power SLB/jms Attach.
cc - INPO Records Center Mr. Robert Nelson US NRC, Region III
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