IR 05000245/1990011
| ML20059C829 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/09/1990 |
| From: | Anderson C, Bhatia R, Paolino R, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059C828 | List: |
| References | |
| 50-245-90-11, 50-336-90-12, 50-423-90-09, 50-423-90-9, NUDOCS 9009050382 | |
| Download: ML20059C829 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
-Report Nos.
50-245/90-11 50-336/90-12 50-423/90-09 Docket Nos.
50-245-50-336 50-423 License Nos.
DPR-21 DPR-65 NPF-49 Licensee:
Northeast Nuclear Energy Company P. O. Box 270
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Hartford, Connecticut 06101-0270 Facility Name: Millstone Nuclear Power Station, Units 1, 2 & 3-Inspection At:
East Berlin, Connecticut Inspection Conducted: June 11-15, 1990, June 25-29, 1990
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Inspectors:
, no, Senior React'or Engineer date R.PaopEB,DRS PSS,
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R. Bha i, Reactor Engineer, PSS, EB, DRS date k
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C. W46dard, Re c ( Engineer, PSS, EB, DRS date Approved by:
0 C. J. A#derson, Chief, Plant System Section date EB, DRS Inspection Summary:
Routine Announced Inspection on June 11-15, 1990 &
June 26-29, 1990; Combined Inspection Nos. 50-245/90-11, 50-336/90-12 and 50-423/90-09 Areas Inspected: The inspection covered:
1) er.gineering support activities for-the Millstone 1, 2 and 3 operating plants, 2) close out of previously identified open EQ issues, and 3) a review of the licensee's emergency diesel
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generator fuel oil program.
The inspection of engineering support activities included an assessment of corporate engineering, plant engineering, field engineering and related quality assurance activities.
Results: No deficiencies were identified.
9009050382 900828 ADOCK0500gj$
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1.0 Persons Contacted 1.1. Northeast Utilities Service Company
M. F. Ahern, Senior Engineer - Steam Generator Replacement Program R. W. Bates, Engineering Supervisor - Unit 2
E. Bennett, Operations Engineer M. Bigiarelli, Acting Engineering Manager K. Burton, Staff Assistant to Director
M. A. Ciccone, Senior Engineer C. H. Clement, Director - Unit 3
G. E. Cornelius, Superintendent Reactor Plant Systems F. Geluso, PIR Coordinator i
J. S. Harris, Engineering Supervisor - Unit 3
M. Hess, Mechanical HVAC Supervisor S. T. Hodge, Supervisor General Nuclear Training
W. E. Hutchins, Senior Engineer i
G. E. Johnson, Director - Generation Engineering & Design
V. Joseph, Associate Engineer R. M. Joshi, Senior Engineer - Unit 3
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R. M. Kacich, Manager Generation Facility Licensing J. S. Keenan, Director - Unit 2
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E. J. Lindsay, Acting Supervisor - Unit
T. W. Lyons, Engineering Supervisor M. F. Marino, Senior Scientist D. T. McDaniels, Reactor Engineering Supervisor P. J. Miner, Scientist (Units 1 & 2)
R. C. McGuiness, Supervisor Nuclear Training K. Murphy, Engineer R. A. Place, Supervisor, Nuclear Engineering Safety R. J. Palmieri, Operations Manager
W. V. Richter, Electrical I & C Supervisor A. Stave, Human Factors Scientist (via phone)
T. B. Silko, Associate Engineer J. P. Stetz, Director - Unit 1 G. P. Van Noordennen, Superv',or Nuclear Licensing G. J. Van Voorhis, Senior General Training 1.2 U.S. Nuclear Regulatory Commission K. S. Kolaczyk, Resident Inspector
Personnel present at exit meeting of June 15, 1990
- Personnel present at exit meeting of June 29, 1990 l
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2.0 Objectives The objective of the inspection was to assess the adequacy of the licensee's program for engineering support to plant operations including modification design and configuration control, interfaces with_ other internal and external organizations, management support, staffing levels and experience, training and licensee response to NRC requirements and commitments and to review tb licensee's pro; am for controlling the
quality of fuel oil for the emergency diesel generators.
3.0 Licensee Commitments
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. Licensee commitments including those to specific codes, standards and Regulatory guides are contained in the FSAR and Technical Specifications.
Procedures and instructions reviewed during this inspection were noted to reference applicable codes and standards.
4.0 Organization The management and technical support organization consists of personnel b
from Northeast Utility Service Company (NUSCO) and Northeast Nuclear Energy Company (NNECo).
NUSCO is responsible for the Northeast Utility (NU) headquarters support activities and NNECo is responsible for the onsite operational activities.
These activities are coordinated between the organizations with each providing review and concurrence as appropriate to the organization having the lead responsibility for the activity, The Nuclear Engineering and Operations (NE&O) group is responsible for all NU electric generation facility projects; for nuclear, mechanical, civil, electrical and environmental engineering support; and for nuclear operations at all generating facilities.
The Generation Engineering and Design (GE&D) department through its Generation Mechanical Engineering, Generation Electrical Engineering and Generation Engineering Design
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groups provides engineering support to the operating plants for Reactor Plant Systems, Balance of Plant Systems, Component Engineering, I&C/
Electrical, Special and Program Studies and Qualification Engineering.
l Within GE&D decision-making authority is governed by established procedures, principally the NE&O Procedures.
These procedures specify the lines of authority for review and ultimate approval of all safety-related as well as non-safety-related engineering documentation.
.All engineering and design documentation requires the approval of the responsible supervisor, as a minimum and, according to the specific document, further approvals in the management chain may be required.
The inspector interviewed supervisors and engineers involved with both onsite and offsite engineering activities.
Plant modification packages were sampled to establish completeness and conformance to engineering procedures.
Packages reviewed include:
PDCR No. MP3-90-009 revision 00,
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I PDCR No. 2-30-88 revision 0, PDCR No. 2-008-89 revision'0, PDCR No.
I 1-28-89 Revision 0, PDCR No. 1-1-88 revision 0, PDCR No. 1-52-87 revision 0 and MP-3-89-21 revision 0.
The packages were observed to be complete and in conformance with the controlling procedures. Good interaction between the various responsible engineering groups was observed.
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The inspector concluded that the engineering organization is sufficient in structure and depth to provide engineering resolution to plant problems, 5.' 0 Staffing The organizational structure and the number of employees within tbs engineering organization is established jointly by functional management i
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and a staff organization, Corporate Performance Services and
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- Organizational Control. Manpower levels within the established limits are maintained by the functional organization.
Manpower levels are
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scheduled to remain constant through 1990, To date, new hires have been
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y limited to one reactor engineer.
However, there have been transfers and J
L adjustment within various departments.
Records indicate a low turnover rate.
The professional staff within GE&D is an experienced staff with an-average of 15.5 years of experience with 7-10 years of experience within Northeast Utility. All engineers within GE&D possess-the appropriate engineering degree for their discipline.
Staffing level is adequate.
Potential contract personnel are required to submit a resume of their qualifications and experience. Contract personnel are selected based upon their resumes and interviews with the intended supervisor.
Contractor activities are controlled by licensee supervisors and where appropriate, supported by assigned full time staff.
Contractor activity is considered a part of the overall engineering activity and is subject to the same audits and acceptance criteria that govern all GE&D personnel.
Staffing levels appear to have remai.. ' the'same as those of the previous i
SALP period.
Site procurement has been upgraded by assigning specific engineering assistance.
6.0 Communications The procedures which cover communications of the corporate office with the plants are contained in the NE&O Procedures Manual.
Site procedures are basically the same as the corporate NE&O procedures. The procedures which cover communications include the following:
the Project Assignment Procedure, Project Description Procedure, Design and Interface Reviews and Plant Design Change Record Procedures.
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Various formal meetings are held between engineering and the plant staff.
Once a month there is an engineering meeting which includes a discussion of current engineering and design topics; a monthly project status meeting between plant and torporate personnel to discuss project status and level of effort status; and for an individual project, there is a project-
" kick-off" meeting attended by project participants,
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Also, Quality Assurance and Quality Control personnel attend the daily.
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station morning and jaily unit meetings.
These personnel meet frequently with plant and engineering _ personnel.
Formal communication is established via quality-related project assignments and project descriptior s.
7.0 Workload The project work load is controlled in accordance with NE&O Procedure
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No. 3.04.
Project Assignments come from a variety of sources, by plant personnel, the engineering organization or the user. Work that does not meet the criteria in NE0-3.04 is typically considered level-of-effort and is subject to the approval of the responsible engineering supervisor prior to-acceptance.
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Workload priorities are initially established through Generation Engineering and Construction (GE&C) staff interaction with plant management.
The process of outlining and prioritizing the project work load for future -
years involves year-round discussions.
Overall, plant management has the responsibility for priorities affecting the plants.
Engineering and design supervision have the responsibility for accomplishing the work within these priorities considering available resources and priority changes as they may occur.
Currently, there are approximately 60 engineering / design / construction projects, 45 engineering studies and 100 level-of-effort assignments
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planned for the 1990 budget year.
Projects are tracked by distributed reports, routed documentation, and regularly scheduled status meetings through the project engineer, cost engineer and planning engineer in each project.
Distributed reports include detailed Critical Path Method (CPM)
project schedules showing individual department activities and their interrelationships, engineering matrices summarizing the critical mile-stones of individual projects, budget status reports, and construction program reports.
9.0 Quality Assurance QA/QC interfaces with engineering are accomplished through audits and surveillances of engineering activities and design modifications. On large project assignments, OA/QC assigns dedicated personnel to cover designated projects. QA/QC does not perform an in-line review of engineer-ing output except for QA procurement specifications and purchase orders to ensure proper QA requirements are specified.
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Quality Assurance / Quality Control (QA/QC) is performed through audits, surveillances, inspections and in process verifications. Audits are performed based on a schedule that is issued at the beginning of the year and periodically revised.
QA is directly involved in the review of work orders and nonconformances in accordance with procedures ACP-QA-2.02C and
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NE0-3.5/ACP-QA-5.01.
Surveillances are performed on a random basis in accordance with ACP-QA-9.07C.
Normally, audit: are addressed in a timely manner with dispositions being thorough and corrective actions being implemented within an acceptable time frame.
Trending-is performed on all Quality Service Department (QSD) findings whether they are audits or surveillances.
Results are published to the director of QSD with an executive summary issued to VP's and station anG unit superintendents.
9.0 Training The Technical-Staff and Manager (TSM) training program consists of three groups divided into indoctrination, initial and continuing training
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courses.
Its purpose is to provide the target population with knowledge of plant design and operations.
The target population includes permanent engin" ring ano technical administration staff positions who will be enga in the day-to-day operations of the plant.
Contract personnel-on
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sater than one year must participate in the program the same as l
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.ent employees.
Indoctrination training courses are completed by new personnel within the first twelve months of entering the TSM program which consists of Introduction to BWR/PWR Systems, Codes and Standards and Nuclear Industry Requirements I and II.. Initial training courses provide more detailed information and are completed within two years of entering the program.
The continuing training courses contain specific training presented quarterly for plant personnel.
This training includes presentations on current plant and industry events, significant procedure changes, plant modifications and periodic reviews of selected tapes. Administrative training is provided in the use
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of Work Procedures, Purchasing, Non-conformance Reports and Root Cause l
analysis.
Academic training includes Reactor Theory, Thermodynamics, Basic Process l-Control, Plant Chemistry and Electric Fundamentals.
Certified instructors are used to present the training program courses.
Records are maintained in accordance with established procedures (NTM-1.16).
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10.0 Status of Previously Identified Open EQ Issues (Closed) Unresolved Item No. 336/88-07-03 regarding current licensee valve testing procedures which require valves to be tested at full system pressure (2385 psig) but not at the low LTOP pressure (450 psig). The ASME Section XI periodic valve testing criteria establishes valve operability and valve seat tightness. The LTOP valve qualification pro-gram demonstrates that if the valves operate at 2385 psig they will also
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t operate,at 450 psig and therefore is sufficient to establish valve operabi-lity at both set points (2385 psig/450 psig). A licensee evaluation / analysis (PSE-CE-88-459) issued in July 21, 1988 of the valve qualification program confirms the PORV's acceptable relieving capability at 450 psig for the bounding RCS low temperature pressure - transient corresponding to an RCP actuation with a water solid RCS.
This item is closed.
(Closed) Violation No. 423/88-04-07 regarding the unqualified configuration for twenty-one Litton Veam Connectors.-
Licensee analysis / evaluation determined that, of the 21 connectors identified without the heat shrink tubing, only two of the connectors are required to remain functional to mitigate a LOCA/HELB event.
The two connectors are used in circuits for valve position indication on two containment valves (3GSN * CTV105 and 3PGS * CV8046).. These two con-nectors have been replaced with qualified connectors during the second refueling outage under,PA 88-018/PDCR Mp3-88-014.
The remaining
connectors were reviewed under pIR No. 60-88.
The licensee determined that failt.re of these devices would not result in incorrect operator l
actions or aggravate the consequence of an accident.
These devices'(19)
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were removed from the EQ Master List. An operability determination in i
conjunction with a justification for continued operation (JCO) was performed for each device, and a review for reportability under applicable requirements.of 10 CFR 50.49, 50.72, 50.73, Part 21 and the Technical Specifications was performed.
This item is closed.
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11.0 Emergency Diesel Generator (EDG) Fuel Oil (TI 2515/100)
Background
For proper operation of the emergency diesel generators, it is necesscry to ensure the proper quality of the fuel oli.
Assurance of the proper fuel oil requires purchasing the correct fuel oil and a receipt inspection to verify that the fuel oil is proper prior to addition to the it; rage tanks.
Since fuel oil degrades with time and external sources centribute contamination, periodic inspection and actions are required to assure
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continued fuel oil quality. Appendix B to 10 CFR 50, as supplemented by Regulatory Guide (RG) 1.137, serves as an acceptable basis for licensees-to maintain a program to ensure the quality of EDG fuel oil, t
In response to industry problems, the NRC issued Information Notice (IN) 87-94 " Diesel Generator Fails Test Because of Degraded Fuel" to alert licensee to potentially significant problems, pertaining to the long-term storage of fuel oil.
This Information Notice documents the June 27, 1986 Arkansas Nuclear One Unit 2 (ANO-2) inoperability of an emergency diesel generator due to a high concer.tration of particulates in the fuel oi _
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Also, at Millstone Unit 3 on Novemoer 20, 1987 (PIR 223-87), an-EDG was declared inoperable due to particulate matter in the EDG fuel-exceeding the Technical Specification (TS) 4.8.1.1.2e limit of 10 mg/ liter. At that time, the plant was in a refueling outage, the EDG was not ir. aperation, and core alterations were suspended until an acceptable supply of fuel oil was obtained.
This inspection was p'erformed to determine the licensee's program for the procurement, receipt, storage, handling and control of EDG fuel oil to ensure adequate quality of the fut1 oil.
11.1 System Design and Operation The EDG Fuel Oil Supply system consists of parallel redundant supply headers running from the Fuel Oil Day Tank to the suction of the engine mounted fuel pump. Two independent and redunaant fuel oil transfer pumps draw off of a buried 25,000 gallon bulk storage tank i
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The transfer pumps are powered from different safety-related buses and they automatically respond to day tank level switch commands to maintain
day tank contents between 1390 and 1610 gallons.
A fuel oil strainer is included in the fuel supply line from the storage tank to the day tank and in each of the parallel fuel lines
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from the day tank to the EDG fuel pump.
A duplex filter unit is
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mounted on the EDG unit in the fuel line from the EDG fuel pump to
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the engine fuel headers. These strainer / filter elements ensure that i
the fuel oil does not contain particulates of sufficient size.and l
quantity to adversely affect injector operation.
In accordance with
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the preventive maintenance schedule, the strainers are cleaned and the filters are replaced each outage.
Further, the duplex filter is l
instrumented to provide indication of the differential pressure
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across the filter.
The differential pressure is routinely monitored
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and trended during EDG operation.
If the filter differential pressure l
indicates that the filter is becoming less effective, the duplex
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filter can be switched to the clean filter during EDG operation.
The EDG fuel oil system is instrumented to provide fuel day tank and
'l storage tank level indications and alarms.
The fuel system pressure
and level instrumentation indications and alarms are locally mounted I
above the fuel storage tank and on the local panels in the EDG room.
The day tank low level alarm also provides an alarm to the " Diesel Generator Trouble" alarm in the control room.
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The inspector conducted a walkdown inspection of the EDG fuel system and made observations of the system and its components in the vicinity of the fuel oil supply tank, the fuel oil day tank, the EDG room, and a
in the main control room. The system and its components were compared
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to the system description and drawings.
No discrepancies were noted, d
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11.2 Fuel Oil Procurement, Sampling and Analysis The. inspector reviewed.the licensee's fuel procurement requirements, receipt sampling and analysis, and the periodic sampling and analysis of the stored fuel to ensure its cuality.
Documents reviewed include
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Northeast Utilities purchase order to.Amerada Hess Corporation
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including Exhibit B - No. 2 Fuel Specification SP 668.11 - Unit 1 Diesel Fuel Sampling Analysis
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ASTMD975-81 - Specification for Diesel Fuel Oils
ASTMD2276-89 - Standard Test Method.for Particulate Contaminants
in Aviation Fuel NRC Regulatory Guide 1.137 - Fuel Oil Systems for Standby Diesel
Generators Northeast Utilities Significant Operating Experience Report
(NVSOER) 90-01 - High Particulate in Diesel Fuel
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Colt (Fairbanks Morse) Opposed Piston Engine Manual Pages B7
and B8.
Regulatory Guide 1.137 states in part that "The oil stored in the fuel oil supply tank and the oil to be used for filling or refilling the supply tank shcald meet the requirements of ASTM D975 or the requirements of the diesel generator manufacturer if they are more restrictive".
The inspector reviewed the manufacturer (Colt) fuel requirements as stated in the vendor manual and compared them to the licensee's purchase order fuel specifica-tion and to the ASTM D975 requirements.
From this comparison, the inspector determined that the licensee is specifying and procuring fuel oil which meets the manufacturer's requirements and complies with ASTM D975.
The inspector confirmed that the licensee performs sampling and analysis upon receipt of new fuel oil to confirr at it meets the ASTM specifica-tion requirements for API gravity, mont y flash point, clear and bright
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prior to addition to the storage tank. A monthly sample from the storage tank is analyzed to ensure compliance with the ASTM D975 and ASTM D2276 fuel specification requirements. The day tank and fuel storage tank are-also checked for water each month.
Fuel not meeting specification require-ments must be replaced within one week.
Additional improvements in the sampling analysis methods and procedures including "all levels" type of sampling from trailer tanks have been included in the program in accordance with NUSOER 90-01 January 11, 1990 recommendations.
Based upon this review, it was determined that the licensee's sampling and analysis program is adequate to assure the proper quality for the fuel oil.
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11.3 IN 87-04 Degraded Fuel Oil The inspector reviewed the licensee's evaluations, internal responses
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the following:
Northeast Utilities Significant Operating Experience Report
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i (NUSOER) 90-01, High Particulate in Diesel Fuel Emptying, cleaning, inspecting and refilling the fuel storage
and day tanks during the 1987 outage.
With the assistance of the Pfizer. Chemical Company and the EDG
manufacturer (Colt), evaluating the use of fuel additives to control particulate build up and implementing the use of a proper fuel' additive.
Revising the Diesel Fuel Oil Sampling Analysis Procedure SP
668.11 to perform additional fuel oil receipt inspections and to
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perform monthly sampling and analysis of fuel in both the day tank and storage tank to assure that it continues to meet the specification requirements of ASTM-0975 and ASTM-D1276.
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From this review, the inspector concluded that the licensee has adequately addressed the IN 87-04 fuel oil clogging issues and.has taken appropriate actions.
11.4 Conclusions The licensee's fuel oil procurement, sampling and analysis programs address the issues to ensure the receipt of the proper fuel oil and to maintain the quality of the stored fuel oil.
The inspector observed no outstanding deficiencies in the licensee's program to ensure the quality of the emergency diesel generator fuel oil, 11.5 Licensee Response to NRC Information Notice 89-50 Information Notice (IN) 89-50 alerts licensees to the potential for an inadequate supply of diesel generator fuel.
It addresses a review of the design basis for tae Emergency Diesel Generators (EDG) units at Palisades in which it was discovered that tne EDG fuel oil consump-tion calculations perfermad in 1968 had not been updated to reflect increases in equipment loading and operating times in post-accident conditions.
As a consequence, the Technical Specification minimum amount of EDG fuel oil stored on-site was insufficient to provide for operating the EDG units for the time required.
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- Th.e inspector. determined.that the licensee had conducted an; evaluation
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-to determine the= amount of fuel oil ~ required on site =to operate <the.
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EDG unit at: full rated load:for. the five day time periodurequired by'
i the-Technical Specification.
This evaluation was conducted with'the-I assistance of.the'EDG manufacturer (Colt).
Based'upon the evaluation; findings, the licensee determined that the minimum quantity ~of on-site
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stored diesel generator fuel' oil was-inadequate and it should be?.
Lincreased from 20,000'to 23,400 gallons. Accordingly, the licensee
'l has administratively: implemented this: change and is'currentlyi I
processing'a Technical _ Specification revision:to include this
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change.. The inspector concluded that the licensee had adequately.
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addressed this Information Notice.
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12.0 Exit Meeting l I
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The inspectors met with licensee management representatives (details, l
paragraph 1.0) at.the site and the corporate office on June 15, 1990 and
June 29, 1990. The inspectors summarized the scope and findings ofLthe
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inspection at.that time,
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During this inspection, no written material.was provided to the
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