IR 05000286/1990004
| ML20034C028 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/05/1990 |
| From: | Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034C025 | List: |
| References | |
| 50-286-90-04, 50-286-90-4, NUDOCS 9005010329 | |
| Download: ML20034C028 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-286/90-04 Docket No.
50-286 License No.
DPR-64 Licensee: Power Authority of the State of New York.
Indian Point 3 Nuclear Power Plant P.O. Box 215 Buchanan, New York 19511 Facility Name:
Indian Point Unit 3 Inspection At: Buchanan, New York
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Inspection Conducted:
February 21 - March 2, 1990-Inspecto-
_C. H.FWoodard, Reactor Engineer date
Approved by:
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C. J.vAnderson, Chief, Plant Systems date-Section, Engineering Branch, DRS
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Inspection Summary:
Routine Announced Inspection on February 21 - March 2, 1990 (Inspection Report No. 50-286/90-04)
Areas Inspected: The inspection addressed the licensee's program to e'nsure adequate quality of the emergency diesel generators fuel oil.
Results: The licensee's program for diesel fuel. oil including proper specifications and fuel chemistry requirements were deemed adequate.. An unresolved item was identified as a consequence.of the failure to inplement procedures to control and ensure the availability of a seven day supply of
. diesel fuel oil. A non-cited violation was. identified as a consequence of-a portion of a vital system being located outside the vital area and being unsecured.
9005010329 900419 PDR ADOCK 05000286 g
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DETAILS 1.0 Persons Contacted 1.1 Power Authority of the State of New York
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J. Perretta, Superintendent of Power
J. Russell, Resident Manager
C. Mackay, Operations Superintendent
R. Lauricella, Licensing Coordinator
M. Peckham, Assistant Resident Mai.ager
~J. Vignola, Maintenance Superintendent
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J. Gillen, General Chemistry Supervisor
D. Quinn, Radiological Environmental Services Superintendent
C. Caputo, Technical. Services Superintendent
M. Albright, Instrumentation and Controls Superintendent
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R. Tansky, Training Superintendent
. T. Vitale, Maintenance Engineer
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D. Wilson, Chemistry Engineer
J. Kraft, Chemistry Supervisor
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1.2 Nuclear Regulatory Commission -
L. Rossbach,-Senior Resident Inspector-
G. Hunegs, Resident Inspector Denotes those present in the exit meeting
q 2.0 Licensee Action on Previous Inspection Findings b
2.1 (Closed) Violation Item 50-286/88-21-01 - Emergency Diesel Generators i
Maintenance Not In Accordance With Manufacturer's Recommendation The licensee's technical specifications require tha.t the EDG units shall be -inspected and maintained following the manufacturer's recommendations.
Inspection had revealed that.the manufacturer's
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recommendations in many cases were not followed in the licensee's maintenance procedures nor were there justifications for not following these recommendations.
i A review was made of the corrective actions taken by the licensee to.
resolve this issue including the following:
The licensee had obtained from the manufacturer (ALCO) a
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recommended maintenance schedule for diesel generators which typically operate 50-100 Sours per year. This schedule was used by the licensee in developing a matrix of 122 seperate maintenance activities with the recemmended ALC0 frequency, the licensee's frequency, the responsible department for the
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-3-maintenance activity, and appropriate comments. An attachment to the matrix is the detailed technical justifications and evaluations for nine activities for which the ALC0 recommended frequencies were not adopted. The inspector concluded that these activities were-addressed ' properly.-
The licensee had prepared new EDG maintenance procedures,
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where required, and revised-the others to. provide the'
required coverage.
The following procedures were reviewed.
in detail:
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GNR-004-ELC, Rev 0, 12/1S/89 - Diesel Generator Quarterly
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Inspection GNR-002-ELC, Rev 0, 6/10/89 - Diesel Generator. Annual J
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Inspection-l IC-PM-T-1283, Rev 3, 6/8/89 - Diesel Generator Jacket
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t Cooler Water Discharge. Temperature Preventive Maintenance The procedures reviewed were well prepared with. adequate
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coverage of the maintenance activities.
The licensee had implemented.a maintenance-trending program l
with the various EDG parameters included in the system on-
a monthly basis.
The trend information is utilized.for predictive maintenance purposes and for useLin establishing /
l justifying maintenance frequencies.
The data trend ~.
graphs / charts covering the period from July 1988 -' February
. i 1990 were reviewed along with the current (February 13,1990).
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analysis of the data trends. The trend data, its presentation and the trend analyses were.found to be meaningful in the
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licensee's maintenance program.
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Based upon the licensee's implemented program and p'racedures to i
effectively address the previous concerns, this item is closed.
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2.2 (Closed) Violation Item 50-286/88-21-02-Safety Related 480 VAC Circuit Breakers preventive Maintenance Not Proper A review of the preventive maintenance records for safety related
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circuit breakers had revealed that there was no evidence'of three
480 VAC circuit breakers being maintained as required by the licensee's procedure 3PM-R-ES-6 during the 1987 refueling outage.
The inspector determined that the licensee had tested thest creakers-during the 1988 outage and has taken appro~priate actions to prevent recurrences by implementing maintenance program enhancements.
In order to accurately track preventive maintenance work performed on
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the circuit breakers, a computer tracking program has been' expanded t
to include the breakers, mctor control centers, motors and motor.
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operated-valves. 'This program includes the use of unique bar-coded
~ identification labels on each current breaker in addition to its -
metal identification-tag to provide for traceability and account-ability..The program identifies all circuit breakers due.for preventive maintenance on a monthly basis and generates exception reports which include any past due maintenance. Written justification with the approval of the maintenance superintendent is required for.each exception where.the maintenance is.not:performedL when scheduled.
Based ri the licensee's implemer,ted program and
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procedures to effective 1/ address the-previous concerns,.this item is closed.
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3.0 Emergency Diesel Generator (EDG) Fuel Oil ~(T12515/100)
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3.1 Background For the safe and reliable operation of the EDG units it is necessary to ensure the proper quality of the-fuel oil. Appendix B to.10 CFR 50 and Regulatory Guide (RG) 1.137 provide regulatory requirements s
and an acceptable basis for a program to ensure the quality of the EDG fuel oil.
Regulatory Guide 1.137 states that American National Standard ANSI N195-1976-should be used along with its supplement in establishing and implementing the fuel program.
The supplement specifies that oil to be used for filling or refilling the supply tanks should meet ASTM specification D975-77 " Standard. Specification for Diesel Fuel Oils" or the recommendations of the diesel generator manufacturer if manufacturers standards are more restrictive.
The licensee is not committed to the RG 1.337-recommendations.for their diesel fuel oil program; however, assurance of proper fuel oil requires purchasing the correct fuel oil and receipt inspection to verify that the fuel oil is proper prior tc addition to the. fuel storage tanks.
Since oil degrades with time and biological growth and external sour:es contribute contamination, periodic inspection is important to assure the continued fuel oil quality.
NRC Information Notice.87-14 alerted. licensees to this potential problem of fuel oil degradation. This inspection was performed to determine the licensee's program to ensure adequate quality of the EDG fuel oil.
3.2 EDG Fuel Oil System Description The EDG fuel oil system is comprised of three 7700 gallon
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underground storage tanks which supply' oil to each of the three 175 gallon elevated day tanks by three transfer pumps each powered from a differen; safety related bus to provide fuel for occh of the three EDG units.
These tanks are maintained to provide for a minimum storage cepacity of 5616 gallons of fuel in each of the three
tanks.
P ocedures are provided for pumping of fuel from one
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diesel supply tank to feed another diesel generator in-the event of the failure of a fuel supply to a diesel. An' additional 26,300 gallons of fuel procured to the-EDG fuel oil specification is available from Indian Point Unit 2 fuel storage tanks by means of'
s a Unit 3 dedicated transfer tanker. Memorandum of Understanding No.
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7, Revision 0, dated January 19, 1978 between Indian Point-Units 2.
.l and 3 covering-this fuel availability (but not the tanker) was j
reviewed.
This combined fuel storage provides sufficent diesel
generator fuel to meet' technical specification requirements. EDG.
fuel is gravity fed from the elevated day tanks to the engine. fuel pumps which provide _fue~l pressure through the; duplex fuel filter.t'o
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-the engine fuel header and to the injectors. The duplex filter
permits change over during operation.
Fuel-in the day tanks is controlled by level switches which provide for-pumped make-up' fuel
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from the fuel storage tanks.
In addition to local indication and alarm in the EDG areas of fuel tank level and fuel pressure, these.
alarms actuate the EDG common alarm in-the control room.
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THIS PISHdP3 CET! iib SMEEJM 12?E,TEIl f20 IS EM F0il PUBL10
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i-6-EIS PARI 3MP!! CCMTES MECi!ARDS IMATEii IJD 1310T 10R PlFM DIS 0t0SEE, IT IS INT 9(TMALLY LEff BUl%.
The. inspectors findings on March 1, 1990 of the failure to control-access to a portion of a vital' system' constitutes a licensee violation-of. the NRC regulatory requirements.of 10. CFR 73.55(c).
However,-this
- violation is not cited in this report on the basis that the. licensee 1 identified the potential; violation, it normally w wldlbe classified at a Severity Level IV, it was corrected within a reasonable. time, and it was not a willful violation or a violation that could reason-~
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' ably be expected to have been' prevented by.the licensee's. corrective actions for a previous violation.
The violation was not reported; however the time frame'between its identification and this inspection-was only a matter of days.
(Non Cited Violation Item 50-286/90-04-01)
3.3 EDG Fuel Oil Procurement
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The EDG manufacturer (ALCO) in their fuel oil specification j
MI-13001F provided specifications for the fuel oil. ;These
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specifications closely match the characteristic standards for 2-D-
ry diesel fuels as specified in ASTM Specification D9754except that; the manufacturer specifies a wider acceptance range for: fuel oil-viscosity.
The licensee's procurement requirements asicontained-l in their blanket purchase order' number 90-IP-6050:to their fuel a
supplier specifies that the fuel shall be No. 2-D diesel fuel in accordance ytth the more restrictive requirements of ASTM D975.
Evaluation of the licensee's fuel procurement' program-included a l
review of the following:
i EDG Fuel Oil Dedication Package OP-0125,: including Quality
Assurance Requirements for Category 1
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i EDG Fuel Oil Purchase Order 90-IP-6050 including Vendor
Qualification Memorandum of Understanding No. 7 - Rules Governing the
Maintenance.and Use of~ Dedicated'(By Consolidated Ediso.n for the Power Authority) Diesel Fuel Oil (No. 2) Supply,i Revision 0, January 19, 1978 f(
Operations Procedure SOP-EL-9, Revision 4 - Filling Diesel Fuel
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-7-This review showed that the licensee has develope'd a program which extensively addresses the steps necessary to procure and receive the proper fuel oil from their cunmercial supplier.
Implementation of q
this program was confirmed by a review of the documentation-covering i
several fuel deliveries including the sampling.and analysis to
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verify the fuel.
Fuel procurement commitments with the supplier I
and commitments from the off-site analytical. laboratory are such
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that the fuel is sampled by the licensee at the supplices fuel yard and a completed ASTM 0975 analysis is received (within two days)
i prior to delivering the fuel. Additional samples are taken prior to off-loading the fuel into the EDG storage tanks for the ASTM D975~
specific gravity,fviscosity, water and sediment analysis in' order to ensure that no contamination or degradation of the fuel has occurred, Since the EDG fuel oil storage tanks combined minimum on site volume is insufficient to meet the technical specification operatiol.al requirements, the Power Authority has a memorandum of agreement with Consolidated Edison (Indian Point Unit 2) to procure and maintain an q
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additional dedicated 26,300 gallons fuel supply in their EDG fuel storage facil.ities. The agreement was reviewed and discussed with licensee operations personnel who verify the availability of this
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fuel source by procedure on a weekly basis.
Indian Point Unit 2
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personnel verify the fuel quantity routinely by.means of daily tank level / capacity readings.
(A minimum of-102,500 gallor.s of diesel f
fuel on hand at all times in the Unit 2 storage tanks is required to
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satisfy the technical specification requirements for both ilnits 2 and
3). The inspector confirmed that Consolidated Edison procures this
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fuel to the ASTM D975 requirements with appropriate sampling:and analysis of both new and stored fuel to ensure its quality. -Upon delivery this fuel would be sampled and analyzed the same as incoming.
l new fuel from the supplier to ensure quality prior to offloading into the EDG fuel storage tanks.
To move this additional fuel oil on-site from the IP Unit 2 storage tanks to the Unit 3 EDG fuel storage tanks require me use of a fuel oil transfer tanker. Technical Specificatica, iaragraph 3.7
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Basis states, in part, that "a truck with hosing connections compat-ible with the underground diesel fuel oil storage tanks is available for transferal of diesel oil from the storage areas either on site or at the Buchanan Substation.". Paragraph 2.2 of' licensee operating i
procedure S0p-EL-9, Revision 4, dated October 8, 1988 states in part that "The fuel oil transfer truck must' be available for transporting diesel oil whenever the reactor is above the cold shutdown condition."
Inspection of this dedicated truck tanker revealed the following:
The truck tanker is located just inside the main gate onsite at
IP Unit 2 and is owned by Consolidated Edison.
Offloading and filling of the tanker with fuel oil may require
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the use of the integral tanker pump.
Paragraph 4.2b3 of licensee operating procedure 50P-EL-9 states in part " Fill the-l
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truck using its-own pump." This pump is driven by a five horse-power 230/460 volt electric motor.
The motor is equipped with an installed power cable-(approximately 25 feet long).
Inspec-tion revealed that the power cable connector had been cut off and there was no provision made. for powering the rr.otor'.
Further inspections showed that there was no indication on the motor-as i
to whether it is connected for 230 or 460 volts.
q The truck tanker is ewipped with fuel hose holders but no H
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hose. 'It could require approximately 150 feet of hose of the-proper size with compatible end, fittings to. transfer. fuel to-the tanker and then to the EDG storage tanks.
The tanker is equipped with a nitrogea blanketing system;
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however, the two nitrogen cylinders we e-empty.
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11113 PARABRAPil CollTAINS SAFECUARDS IEUTGX IS IS NBT FOR Pil8t!C DISCLD5EE, IT IS lHTEXT10NAlli LEli ELCL
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The tanker is equipped with two fire extinguishers; however,-
they were last inspected-in 1987.
The tanker license plate expired in 1987.
Obtaining fuel from
the Unit 2 Buchanan Substation may require the use of.a
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public highway.
Inspection of the building areas adjacent to.the:EDG fuel tanks did-not readily reveal a location from which 230/460 VAC power could be obtained to run the tanker fuel pump. Questioning both operations and maintenance personnel revealed that_there are no established
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agreeW s or-procedures for the use of the Indian Point Unit 2
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ch might include such things as tanker avai_ lability; te.
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ents and responsibility for inspecting, cleaning, and main-tain.. the tanker; locating a tractor to pull the tanker,_ locating hose, to transfer fuel and locatfrg the proper p~ower connection i
for the pump motor.
In consideration of the above, the: inspector concluded that the availability of the truck tanker and thus the
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seven day fuel supply were not established.
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With regards to the above items, during subsequent telephone conversation between the licensee and NRC management on March 29 and 30, 1990 the licensee provided the following additional information:
The tanker has been moved to a different location within the
Consolidation Edison protected area to assure better physical access control.
The tanker was cleaned, inspected and all of its openings were closed and wire-sealed.
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-g-With regards to the tanker electric motor drit n. pump, the licensee
stated that_the pun.p is not required nor wouid it be_used for either filling the tanker or off-loading the tanker ento 'the EDG fuel storage. tanks.
The licensee stated that the proper lengths of hoses with
compatible fittings were located and are now available for use with.
the-tanker.
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The licensee' stated that although'a trailer licensee plate would not
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be req.' red for moving the fuel, they were planning to.obtain a i
current license plate.
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The licensee stated that they were working with Consolidated Edison
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to establish!a joint usage program to inciuoe ' agreements. for such'
things as tanker access, maintenance, and surveillance.
The licensee stated that they.have tractors on site which could be
used to pull the tanker.
In addition they state that'there are:an-
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abundance of readily-a4ailable tractors off-site both company-owned
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and commercial that could be used if.reqt Td.
.i The licensee stated that in addition to the dedicated,on-site fusi-
o oil tanker, there are tankers and tractors available un short notice locally that-could be used to deliver and transfer the diesal fuel oil as required to provide for the seven day on-site fuel supply.
According to the IP3 FSAR all of the emergency: diesel ~ generators' fuel
.g oil supply system is designed to seismic class I criteria. The inspector determined that the diesel fuel system was designed and built to meet seismic class 1 criteria except for the diesel fuel oil supply system fuel fill line. The. inspector.was unable to
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determine, during this. inspection, the reason why this' portion of.
i the system did not meet the seismic class 1 criteria. The; inspector i
determined that within the seismic portion of the fuel system, there is an alternate fill connection which could be used in the event of failure of the non-seismic fuel line. However, it would require 100 to 200 feet of fuel hose (depending upon the route chosen) to deliver fuel to the tanks '+om the supplying tank truck.
This overall-fuel
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system item involving the availability.of the' tanker, hoses,.
established procedures, and seismic classification of the fuel line is unresolved nending NRC review and evaluation and/or licensee-evaluation and corrective actions.
(Unresolved Item 50-286/90-04-02).
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3 '. 4 Fuel Oil Maintenance
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Information: Notice 87-04 alerted licensee's to-potentially
.significant problems pertaining to the long term storage of
. diesel fuel oil caused by its oxidation breakdown / deterioration and biological growth. These problems have caused EDG units to fail to operate because of.these fuel containments blocking the fuel-filters thus starving the engines _ of fuel.
Because of these factors, periodic inspection, testing and maintenance are desirable to ensure' continuing fuel quality.
The inspector determined'from a. review of licensee Procedure-
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RE-CS-001/0 Diesel Fuel Oil Bulk Storage Tank Sampling and Diesel
Fuel Oil Specifications that the EDG-fuel oil storage tanks are ampled on a quarterly basis by alternately sampling one tank _each j
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month.
Immediate analysis is made on site for water and sediment, I
specific gravity, and viscosity.
The remainder of :he ASTM D975 and-j tFc ASTM D2274 oxidation stability and biological s.awth
contaminacion parameters are determined by off-site analysis within
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two weeks.
The EDG day tanks are sampled twice'a month and analysis is made on site for water and sediment, specific gravity and vi sco sity. The day tanks are sampled from a bottom drain connection j
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which assures the removal of any water or sludge build-up.
Inspection of the s4mpling location _for the EDG fuel storage tanks
revealed that the samples are collected from a three-inch tank i
sounding tube which extends almost to the tank bottom. ' Samples
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taken from this tube near the bottom would be representative of tank:
bottoms'but not necessarily representa?ive of the bulk of the fuel.
Samples taken at other elevations would oet representative of the captive fuel in the sounding tube-and not represer.tative of the fuel i
in the tank. The tanks have a three-inch capped nozzle which
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q extends only into the top of the tanks. The licensee now plans to-
use this nozzle, to collect samples for determining.the fuel characteristics at elevations other than the tank bottom.
Recent fuel analysis (February 14,1990) have indicated fuel oil contamination levels in excess of the 10 mg/L and oxidation.
stability in excess of 1.5 mg/L which are the upper limits permitted by the licensee's fuel chemistry acceptance criteria. As a consequence, the licensee plans to recirculate / filter the fuel oil in all of the EDG storage tanks during the March 1990 outage to remove these fuel contaminants.
In addition, the licensee has initiated a program for the chemical treatment of the fuel oil stored in these tanks to retard axidation breakdown and to control biological growth. No outstanc eg deficiencies were noted in the licensee's fuel maintenance progrem.
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3.5 Additional R.G. 1.137 EDG Fuel Program Issues Although the licensee-is not committed to R.G. 1.137 in their-. fuel
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program, most of the recommendations have been addressed including; f
the following:
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The Regulatory Guide recommends pressure testing of the EDG fuel'
- systems to a pressure m.10 times the system design pressure
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at ten year intervals.
The inspector confirmed that the
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licensee performs this test every five years.
The Regulatory Guide recommends that the fuel oil stored in
the supply tank-should be removed, the accumulated sediment
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removed, and the tanks cleaned at 10 year 1 intervals. The=
licansee does not perform these maintenance items.
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the fuel will be recirculaf.ed periodically through an external r
filter to remove particulates, biological growth, and some t
sediment..In addition, the licensee has. implemented'the
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periodic use of a portable tank bottoms pump whsse pick-up suction nozzle will traverse the length of the bottom of a tank-to pick-up trek containments such as sludge,-water and sediment.
The Regulatory Guide recommends that the method of
replenishment of fuel oil without the interruption of the operation of EDG units should be such as to minimize the creation of turbulence of the accumulated residual sediment in-the bottom of the tanks during fueliaddition since'it has:the potential for causing the overall quality of the' fuel oil uin the storage tank to become-unacceptable.
Licensee review of this.
area established that the fuel fill flow rate'is limited by the.
two-inch fuel fill connection.
This fuel flows into a four-inch nozzle which terminates in the top of the tank. As-such, there should be little tank bottom turbulence during ' tank filling, particularly since the tank replenishment is normally begun while the fuel tanks are more than half-full.
Further, the licensee expects that the use of the tank bottoms pump will minimize these tank bottom fuel ccataminants.
The Regulatory Guide recommends that accumulated condensate
should be removed from storage tanks on a quarterly basis.
The inspector determined that the EDG fuel storage tanks are underground (subject to little temperature change) and are'kept fell most of the time.
As a consequence, condensate water has never been a problem.
The tanks are not equipped with drains.
According to the licensee, if water were detected during the periodic sampling, they would either,";mp-out the tanks and replace the fuel oil or utlize the tank bottoms pump-to remove it.
No deficiencies were identified with the above activities.
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-12-3.6 Conclusion One non-cited violation'was identified-in the licensee
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control'to a vital system. This violation:had been idtra 'ied by the licensee earlier and-corrective actions have been implemented.
One unresolved item was identified.n tne licensee's lack of control and =
procedures needed to assure.the availability of sufficient diesel, fuel oil to mest the technical specification on-site fuel requirements.
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Except for these items, the 11censee's fuel system and fJe1 programs were considered adequate to. ensure a supply of known quality-fuel oil to the. diesel generators.
4.0 Unresolved Itect.
i An unresolved item is a matter about which more information is required j
in order to ascertain whether it is an acceptable item or a violation.
Unresolved items identified during this inspection are discussed in paragraph 3.3 of this report.
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5.0 -Management Meeting Licensee management was informed of the scope and purpose of the
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inspection at the entrance meeting on February 21, 1990. The findings were discussed with the licensee representatives at the March 2, 1990 exit interview.
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j At no time during the inspection was written material provided to'the-
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licensee by the inspector.
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