IR 05000302/1987041

Insp Rept 50-302/87-41 on 871130-1204.Violation Noted.Major Areas Inspected:Diesel Generator Loading

ML20195H542
Person / Time
Site:	Crystal River
Issue date:	12/30/1987
From:	Conlon T, Fillion P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20195H540	List: IR 05000302/1987041 ML20195H536
References
50-302-87-41, NUDOCS 8801200205
Download: ML20195H542 (6)

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s UNITED STATES

_ - [A fog}'o NUCLEAR REGULATORY COMMISSION

. ,0 .n REGION ll 3 j 101 MARIETTA STREET. * 's ATLANT A. GEORGI A 30323

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Report No.: 50-302/87-41 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Con ucted: ovember 30 - December 4, 1987 Inspector: . /J[Jo[f'/

P. J. Filli'n (Ta te '51gned Approved //p// / /#Da'te

&Siijned

/C7 T. E.~ Conlon,lection Chief Division of Reactor Safety SUMMARY Scope: This special announced inspection was conducted on site and at the corporate offices in the area of diesel generator loadin Results: One violation was identified involving inadequate design contro g@g $2

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REPORT DETAILS

1. - Persons Contacted Licensee Employees

• R. Clauson, Nuclear Instrumentation and Control Engineer

• B. Hickle, Manager, Nuclear Plant Operations

• J. Lander, Manager, Maintenance and Outages

• Rahman, Nuclear Electrical Engineer

• D. Shook, Manager, Nuclear Electrical / Instrumentation and Control Engineering

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• K. Wilson, Manager, Nuclear Licensing D. Green, Licensing Specialist at Site Other licensee employees contacted included engineers, technicians, operators, security force members, and office personne Gilbert / Commonwealth, Inc. Employee:

• P. Shipper, Project Engineering Manager NRC Resident Inspectors

• T. Stetka

• Tedrow Exit Interview The inspection scope and findings were summarized on December 4,1987, with those persons indicated in paragraph I above. The inspector described 4 the areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The following new item was identified during this inspection:

302/87-41-01 Violation - Diesel Generator Overload Due to Inadequate

Design Control (Paragraphs 5 and 6).

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The licensee did not identify as proprietary any of the material provided i to or reviewed by the inspector during this inspection.

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l Licensee Action on Previous Enforcement Matters i

i (Closed) Unresolved Item 302/87-28-03, Determine the Effect That Increased

Emergency D/G Loading has on D/G Operatio This item is now considered

, to be an example of Violation, 302/87-41-01. Refer to Paragraph 6 for l discussion of this matter.

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4. Unresolved items Unresolved Items were not discussed during this inspectio . Diesel Generator Loading Compared With Capacity 10 CF 50, Appendix A, Criterion 17 requires that the onsite electric power system shall provide sufficient capacity and capability to assure that the core is cooled and containment integrity and other vital func-tions are maintained in the event of postulated accidents. At the Crystal River Plant, in order to ensure that the oncite electric power source has sufficient capacity, the load on the d!esel generators for any postulated accident shall not exceed the following load ratings:

a) 2750 KW, continuous b) 3000 KW, 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> (cumulative)

c) 3300 KW, 30 minutes (cumulative)

The scope of the inspection was to review the recently completed diesel generator loading calculations for methodology; completeness, and accurac Worst case load profiles were then compared to diesel generator load ratings and generator lead ampacit The present load on diesel generator A was calculated to be 3263 KW for a worst case scenario. The licensee is planning on performing special test to empirically confirm this value. These tests were scheduled to be conducted between December 5 and 20,198 An NRC inspection conducted daring the period of Pecember 7-10, 1987, reviewed the methodology, c procedures, and potential interpretation of the special test. Findings of the inspection are documented in Report No. 50-302/87-43. The calculated load of 3263 KW is within the 30 minute rating range. Abnormal procedures and audible alarms would guide the operator to reduce the load to the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> range before the 30 minute rating was exceede Hadifications impicmented during the present refueling outage (which began about September 19) removed 282 KW of load from diesel generator Therefore, before the refueling outage, the load on diesel generator A was 3545 K The 3545 KW load existed since the aux 114ary feedwater pump was made an automatically sequenced load in 1980 per Plant Modification 79-04-71, and is beyond any published rating for the diesel generato Since the load on the diesel generator, during the 1980 to 1987 time period, exceeded the load ratings, NRC requirements were apparently viola ted. It appears the licensee perfonned an inadequate analysis of diesei generator loading at the time the auxiliary feedwater pump (EFP-1)

was adde The licensee did not realize the diesel generator was overloaded until mid-October 1987, when he discovered a fundamental error in his calcula-tions. The methodology for the original diesel generator load calculation

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consisted of summing the corrected KVA 'and applying an assumed power factor of 0.8 to determine load KW. The actual' load power factor for a

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werst case scenario is approximately 0.9. Supplemental calculations in January 1980 and June 1987 repeated the same error with respect to the power facto i At 3300 KW, diesel generator current is about 510 Amperes which is within - ,

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the ampacity of the generator leads (approximately 700 amperes). ,

t Calculated load on diesel generator 8 is approximately 2950 KW which is within the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating rang Statements made in this section are based on one or more of the following sources of information in addition to interviews: , Letter from Fairbanks Morse Engine Division to Florida Power

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Corporation on Emergency Standby Diesel Generator load Ratings,

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dated September 10, 198 Letter from Gilbert / Commonwealth, Inc., to the NRC on Reportable

Event Emergency Diesel Generator Loading, dated November 16, 198 ;

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_ Abnormal Procedure AP-770 "Emergency Diesel Generator Actuation" Rev. 6, dated October 21, 1987, and draft Rev. 7.

! Letter from Florida Power Corporation to the NRC on Technical  ;

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Specification Change Request No. 157, Rev. 1, Diesel Generator  !

Loading, dated November 16, 1987, with attachments.

, Gilbert / Commonwealth, Inc., Calculation DC-5510-048-EE Rev. 2, dated November 12, 1987.

As a consequence of the above stated findings, this matter is identified

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as Violation 302/87-41-01, Diesel Generator Overload Due to Inadequate ,

Design Contro ; Diesel Generator Maintenance and Surveillance

! I i As described in Licensee Event Report 87-19, the 30 minute design rating of the diesel generators had been exceeded during previous one hour ,

operability tes The 30 minute design rating means that af ter engine ,

i, operation in the 3001 to 3300 KW range for 30 minutes total accumulated time, the engines must be disassembled and special inspections made, i Howevar, the licensee, in attempting to demonstrate operability of the

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diesel generators during refueling outages and other events, operated I

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the diesets at about 3100 KW for longer than 30 minutes, but the special j

! inspections were not made. Diesel generator A accumulated seven hours  !

and, diesel generator B three hour [

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Technical Specification 4.8.1.1.2 states that each diesel generator shall be demonstrated OPERABLE at least once per 18 months by verifying the diesel generator operates for equal to or greater than 3000 KW for 60 minutes. This Technical Specification appears to allow testing the diese generator at 3100 KW for 60 minutes continuous. It could not be determined at the time of the inspection (or later) how this Technical Specification ,

could have been submitted by the licensee and subsequently approved by the !

NRC when it allows the diesel to be overloaded during the surveillance ;

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During an NRC Operational Safety Team Inspection conducted during the

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period of August 24 - September 4, 1987 (Report No. 87-22), the licensee stated that he had prepared honconformance Operations Report (NCOR)87-131 dated August 31, 1987, tc resolve the above mentioned problem with Tech-nical Specification 4.8.1.1.2. LER 87-19, transmitted October 8,1987, states that the apparent cause for having exceeded the 30-minute rating during surveillance test was ".,.misinterpretat!on of the diesel generator LER 87-19 goes on to say that "Apparently rating early]in plant life."were misinterpreted as minimum values which bracketed or the [ ratings bounded the stated ' operating time / maintenance limit For example:

.. 3300 KW or greater for not more than 30 minutes". Despite claims in LER 87-19 that the licensee was not fully aware of the load rating structure of his diesel generator until he received a letter from Fairbanks Morse Engine Division on September 14, 1987, evidence indicates that the licensee knew since 1980 the correct ratings. For example, the enclosure to an FPC letter dated May 1,1980, on "Automatic Initiation of Emergency Feedwater Flow" states, "Alarms will be seen in the control room when the 2000-hour rating of 3000 KW is exceeded, and again when 25 of the 30 minutes have been expended." The watt transducer was set to alann at 3000 KW. An FPC letter on the same subject dated May 14, 1980, states, "The diesel generator vendor could not support continued operation at or near 3000 KW for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> after the initial 30-minute ir,ad of greater than 3000 KW." In addition, Abnormal Procedure AP-770, Rev. 6, states on page 6. "If the "A" EDG output remains greater than 3000 KW for 30 minutes, EFP-1 will trip...".

From the above statements made in the May 1980 letters and Abnormal Procedure AP-770, one can conclude that the lit.ensee understood the diesel generator has a 30 minute rating range of 3001 to 3300 K Subsequent to August 31, 1987 (the NCOR Jite), the licensee has taken the following actions: Successfully completed a special inspection on both emergency diesel generators during the refueling outage. The inspections did not reveel any damage to the upper piston wrist pins and bushings which

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. Request'ed a change to Technical Specification 4.8.1.1.2. .If the change is approved, the one-hour operability test would be run at l 3248 XW for five minutes, and in the 2000-hour rating range for 55 minute To not conform to manufacturer recommendations with respect to accumulated operation time in the 30 minute rating range represents a violation of NRC requirements in the area of maintenance / surveillance procedures. Further- .

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more, Technical Specification 3.8.1.1 was violated because knowingly

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exceeding the 30-minute rating during surveillance test and not performing the special inspection rendered the diesel generators technically inoperabl However, they were not declared inoperable while the plant continued to

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operate in mode 1, 2, 3, or 4. Technical Specification 4.8.1.1.2.d 4 was poorly written in that it allowed the 30 minute rating to be exceede Nevertheless, it is the licensee's responsibility to submit proper Tech-nical Specifications and to ensure _that all safety-related equipment is operable while at power.

! In consideration of the circumstances described in this paragraph, the

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cause of the violation was determined to be in the area of design contro The circumstances are considered to be a second example of Violation 302/87-41 01 described in paragraph 5.

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