IR 05000220/1990018
| ML17056A891 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/20/1990 |
| From: | Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A890 | List: |
| References | |
| 50-220-90-18, 50-410-90-17, NUDOCS 9006180080 | |
| Download: ML17056A891 (12) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/90-18 50-410/90-17 Docket Nos.
50-220 50-410 License Nos.
DPR-63 NPF-69 Licensee:
Nia ara Mohawk Power Cor oration 301 Plainfield Road S racuse New York 13212 Facility Name:
Nine Mile Point Units 1 and
Inspection At:
Scriba New York 2 <<9:
~II
9 Inspector:
C.
H.
oodard, Reactor Engineer, Plant Systems Section, E
DRS date Approved by:
C:
. Anderson, Chief, Plant Systems Secticn, Engineering Branch, DRS date Ins ection Summar:
Ins ection on Ma 2-4 1990 Ins ection Re ort Nos. 50-220/90-18 and 50-410/90-17 Areas Ins ected:
The inspection included a review of the licensee's program to ensure adequate quality of fuel oil for the emergency diesel generators.
Results:
The licensee's program for diesel fuel oil including the fuel oil specifications, procurement, storage and chemistry requirements were deemed adequate.
A concern was identified regarding a potential means for fuel contamination.
The licensee took immediate action to address this concern.
ry00 gC) l=l P00618008, 0~~000240
~ R
+JOCK 'od rz
DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Cor oration
- J. Beratta, Security Manager
- D. Crager, Generation Engineer
"A. Curran, Regulatory Compliance Manager
"J. Ouell, Chemistry Supervisor
~P. Finnerty, Design Engineer
"D. Kaopuki, Technical Assessment Specialist
- D. Keeny, Nuclear Security Compliance Director
"G. Montgomery, Assistant Station Superintendent
"G. Schneberger, Generation Specialist U.
S. Nuclear Re ulator Commission R. Laura, Resident Inspector
"Present at exit meeting May 4, 1990.
2,0 Emer enc Diesel Generator EDG Fuel Oil Back round and Sco e of Ins ection Appendix 8 to
CFR 50 and Regulatory Guide (RG)
1. 137 provide the regulatory requirements and an acceptable basis for a program to ensure the quality of the FOG fuel oil.
Regulatory Guide 1. 137 states that American National Standard Institute, ANSI N195-1976 should be used along with its supplemert in establishing and implementing the fuel program.
The supplement specifies that fuel oil to be used for filling or refilling the supply tanks should meet ASTM specification 0975-77,
"Standard Specification for Diesel Fuel Oils," or the recommendations of the diesel generator manufacturer, if the manufacturers standards are more restrictive.
Assurance of proper fuel oil requires purchasing the correct fuel oil and receipt inspection to verify that the fuel oil is proper prior to addition of the fuel oil to the fuel storage tanks.
Since oil degrades with time and biological growth and external sources contribute contamination, periodic inspection is important to assure the continued fuel oil quality.
NRC Information Notice 87-04 "Diesel Generator Fails Test Because of Degraded Fuel" was issued to the licensee on January 16, 1987, to alert the licensee to the potential problem of fuel oil degradation.
The inspection was performed to determine the.licensee's program to ensure adequate quality of the EDG fuel oi.1 Unit
EDG Fuel Oil Pro ram Inspection of the Unit
EDG fuel oil program was made and reported in NRC Inspection Report 50-220/89-05.
This report concluded that additional information was required from the licensee to properly address several fuel oil issues in order to complete the scope of the inspections This report addresses these issues as follows:
~
Ten year inspection/cleaning of fuel storage tanks.
The licensee recently replaced the tanks with new double-walled tanks which are equipped with cathodic protection and leak detection instrumentation.
In addition, actions have been taken to implement periodic inspection/
cleaning procedures.
~
Periodic sampling/analysis of fuel oil in the storage tanks.
The licensee has implemented Procedure Nl-CSP-8M "Diesel Fuel Oil Analysis" to perform periodic analysis of fuel chemistry and to determine water, sediment, and particulate contamination.
In addition, this procedure identifies specific operator actions that are required (including declaring the EDG units inoperable)
when test results indicate that the fuel oil does not meet specification requirements.
~
A system for removing particulate matter and water from the fuel storage tanks.
The licensee does not have an installed system for the recirculation/filtration/dewatering of the fuel oil.
However, the feasibility of bringing in a portable unit, if necessary,,has been established.
~
The use of a fuel oil additive to limit fuel oxidation and to inhibit biological g"owth.
The licensee has taken action to implement the use of additives.
~
Sampling/analysis of fuel oil in the day tanks.
The licensee does not sample or analyze the fuel oil in the day tanks.
The tank bottom drain valve is opened and fuel is cycled through these tanks quarterly as a part of the Fuel Transfer/Pump Test Procedure N1ST(}16.
This will assure the transfer of fuel, accumulated water and sediment back to the fuel storage tanks which are routinely sampled.
~
The licensee conducted a review of Information Notice (IN) 87-04 relative to a reported EDG fuel starvation event.
This review/
evaluation was conducted and reported internally under Nine Mile Problem Report No.
1230.
The inspector found the evaluation to be thorough and technically adequate to address the IN issues.
A walkdown inspection of the Unit
EDG fuel system revealed that the fuel storage tanks are outside, underground and adjacent to the EDG building.
Access to the top of the tanks is provided through a manway cover and ladder.
Ground level access to the tank fill and instrumentation nozzles is through lift-offcover plates.
The tank vent line is piped to the side of the building and is approximately 15 feet above ground level such that it is
not easily accessible.
The inspector observed that the fuel fill nozzle was readily accessible, opened easily and could provide a path for fuel oil contamination.
The inspector observed that this was unlike the Unit 2 fuel oil storage tanks which had locked nozzles to restrict access.
Before leaving the site, the licensee responded to this observation by installing locks on the Unit 1 fuel tank nozzles and by establishing periodic verification of the locks on both Unit 1 and 2 fuel storage tanks during operational tours and routine security patrols.
The inspector had no.further questions regarding the adequacy of the licensee's Unit
EDG fuel oil program.
2.2 Unit 2 EOG Fuel Oil Pro ram 2.2.1 Fuel S stem Oescri tion A walkdown inspection of the Unit 2 EDG fuel oil 'system revealed that the system is completely independent for the two EOG units.
Each system includes a 55,000 gallon underground storage tank with its fill, sounding tube, and vent connections on the outside of the diesel building.
However, most of the tank is under the floor of the EDG building.
Inside the EDG building, above the fuel storage tank, are redundant fuel pumps which are powered from different safety related power supplies.
These pumps feed a
common header to pump fuel to an elevated 660 gallon day tank.
The day tank gravity feeds the redundant electric and gear driven fuel pumps on the EDG skid.
Each pump provides fuel through a separate set of duplex filters to the engine fuel oil header.
2.2.2 Fuel Oil Pro ram In response to NRC Information Notice ( IN) 87-04, the licensee conducted an evaluation of the Unit 2 EOG fuel oil system and fuel oil program to assure the supply of proper quality fuel oil to the emergency diesel generators.
This evaluation was reported through internal correspondence
"Subject NRC IE Information Notice 87-04, File Code NMP 37867," dated August ll, 1988.
The licensee concluded from this evaluation that the IN 87-04 EOG fuel program issues are appropriately addressed within the fuel program at NMP2 and additional actions are not required.
The inspector found the evaluation thorough and technically adequate to address the IN issues.
The inspectors review of the licensee's fuel oil program included the following items:
~
Fuel oil is purchased to meet the requirements of ASTM D975-81.
Incoming new fuel is sampled/tested under Chemistry Procedure N2-CSP-8V to meet the requirements of the purchase order and the technical specifications.
Verification is made for AP1 gravity, kinematic viscosity, flash point and appearance prior to addition of the fuel oil to the storage tanks.
Additional tests are performed on the sample within two weeks to verify the remainder of the ASTM 0975-81 fuel oil propertie ~
Fuel oil in the storage tanks is periodically tested on a monthly basis in accordance with Chemistry Procedure N2-CSP-8V and the requirements of the technical specifications to verify that the total particulates contamination is less than 10 mg/liter.
An annual analysis is made of the added fuel oil preservative.
A diesel fuel oil stabilizer is added to the fuel oil storage tanks at the time of new fuel addition and it is reinhibited at yearly intervals if required to maintain fuel quality.
Fuel storage tanks are checked for water accumulation at least each 31 days in accordance with Procedure N2-OSP-EGF-M001 to meet the technical specification requirements.
Day tanks are checked for water after each EOG operation and monthly by means of a water-indicating paste on a sounding rod.
Fuel oil storage tanks are periodically drained,'leaned and inspected on a ten year interval basis in accordance with Procedure N2-MSP-EGF-10Y001 to meet the requirements of the Technical Specification
~
The design of the fuel oil system incorporates differential pressure indicators/alarms across the fuel strainers/filters to alert operations personnel of potential problems.
Local indication/alarm is provided with alarm input feeder to a
common EOG trouble alarm in the control room.
The use of duplex filters on the EOG skid permits filter change-over without disrupting diesel generator operation.
The fuel oil filters/strainers are maintained/cleaned/replaced once each eighteen months in accordance with Procedure N2-MSP-EGS-R001.
~
The fuel oil system does rot include an installed recirculation/
filtration/dewatering system.
However, the licensee has determined the feasibility of using a portable system if required.
The inspector concluded that the licensee's program provides adequate assurance of the Unit 2 EOG fuel oil quality.
3.0 Emer enc Diesel Generators On-site Fuel Oil Su
Ade uac NRC Information Notice (IN) 89-50 alerted licensees to the potential existence of an inadequate Emergency Diesel Generator (EOG) fuel supply to meet the FSAR and Technical Specification (TS) requirements.
The IN also noted that in several plants, there were discrepancies between the FSAR and TS basis for the amount of fuel oil required to be available for specific operational requirements for the EDG units.
The inspector reviewed the licensee's evaluation which was made to address the concerns of IN 89-50.
This evaluation is included in the licensee's
"Internal Correspondence File Code NUP 54020" dated August 22, 1989.
The inspector determined from the licensee's evaluation that there are no discrepancies between the FSAR and Technical Specification require-ments.
Further, the licensee's evaluation (using both manufacturer's and
measured fuel consumption data) provides ample evidence that there is sufficient fuel oil stored independently on each site in the EDG fuel storage tanks to meet the FSAR and Technical Specification requirements for both the Unit 1 and Unit 2 reactor plants.
4.0 Mana ement Meetin
\\
Licensee management was informed of the scope and purpose of the inspection at the entrance meeting on May 2, 1990.
The findings were discussed with the licensee representatives as indicated in Paragraph l. 1 of this report at the May 4, 1990 exit interview.
At no time during the inspection was written material provided to the licensee by the inspecto I
~