IR 05000309/1990007
| ML20043E481 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 05/07/1990 |
| From: | Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20043E479 | List: |
| References | |
| 50-309-90-07, 50-309-90-7, IEIN-87-004, IEIN-87-4, NUDOCS 9006130039 | |
| Download: ML20043E481 (6) | |
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U. S. NUCLEAR REGULATORY COMMISSION-
REGION I
Report No.
50-309/90-07 Docket No.
50-309
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' License No.
DPR-36 Licensee: -Maine Yankee Atomic Power Company
83 Edison Drive P
' Augusta,-Maine 04336 Facility Name: Maine Yank;e l-Inspection At: Wiscasset, Maine d
' Inspection Conducted: April 18-20, 1990 W
' Inspectors: db/
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op!7/9o
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C. H.'Woodard, Reactor Engineer, Plant
~dat.e System Section, RS Approved by:
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C. J.8/Anders#n, Chief, Plant Systems date Section, EB,'DRS (Inspection Summary:. Routine, announced inspectior. on April 18-20, 1990 of'the Emergency Diesel Generators Fuel Oil Area Inspected:
The inspection addressed the licensee's program to ensure adequate fuel oil for the Emergency Diesel Generators (EDG).
~Results: The inspector identified several deficiencies (unresolved items) in-
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the licensee's EDG fuel oil program / system as follows:
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Both the incoming new fuel oil and stored fuel. oil sampling and
analysts programs do not provide assurance of the fuel oil quality.
Operation of the two fuel oil storage tanks as one common tank
by means of open interconnecting piping / valves creates the
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potential for the common mode failure of both EDG units.
The Technical Specification minimum quantity of stored EDG fuel
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may be too low to meet operational requirements.
The licensee's EDG fuel oil procurement specifications and Quality Assurance safety-related classification of the fuel oil were considered acceptable.
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DETAILS
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-1.0 Persons Contacted Maine Yankee Atomic Power Company B. Blackmore, Plant Manager
R. Prouty, Assistant Plant Manager
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S..Nichols, Licensing Manager t
B. Nelson;. Technical Support Manager
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P. Radski, Chemistry Manager
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S. Leclerc, Quality Assurance: Manager-
- W. Drake, Licensing Engineer.
- J. Stevens,. Senior Chemist A. Proctor, Stores Manager S. Baily, Quality Assurance Supervisor
- ' Denotes'those present at the exit meeting
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2.0 Emergenqv Diesel Generator (EDG) Fuel Oil (TI 2515/100)
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2.1 Background-Appendix B to 10 CFR1510 and Regulatory Guide (RG) 1.137 provide -the regulatory requirements 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 Institute ANSI N195-1976 should b6 used along with its supplement in establishing and implementing the fuel oil program. The supplement specifies that fuel oil to be used for filling or refilling the supply tanks should meet ASTM specifica-tion D975-77 " Standard Specification for Diesel Fuel Oils" or the recommendations of the diesel generator manufacturer, if the manu-facturers standards are more restrictive.
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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-(IN) 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 stored fuel oil degradation.
This. inspection was performed to determine the licensee's program to ensure adequate quality of the i
EDG fuel oil,
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2.2 EDG Fuel-011 System Descriptio_n-The EDG fuel oil system is-comprised of two 20,800 gallon undergroand bur.ker storage tanks which supply fuel to two_ EDG elevated day tanks -
by means of two fuel transfer pumps (these tanks also serve to pro-vide the fuel supply to the auxiliary boilers).
Each of the two
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transfer pumps is powered from a different safety-related bus to.
provide fuel for each of the two EDG units.
Piping and valving are
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provided to permit pumping fuel from either. of the storage tanks to feed the other EDG day tanks in the event of failure of the fuel-supply to one of the EDG units.
Fuel storage tank equalizing piping and valving are provided between the tank bottoms to permit fuel oil to flow-freely from one tank to the other, i
Make-up fuel oil to the day tanks is'automically-controlled by level
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switches which actuate to pump fuel from the storage tanks.
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oil.is gravity fed,from the day tanks to integral EDG' fuel tanks.
The fuel oil is numped from the integral fuel tanks by both an
electric motor C.iven and an engine gear driven fuel pump.
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pump. supplies fuel through a separate set of duplex filters to the engine fuel headers and injectors.
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In addition to local indications and alarms of fuel oil pressures at
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the duplex filters, these alarms actuate the EDG common trouble alarm in the control room, s
2.3 EDG Fuel System Walkdown Inspection
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Inspection of the EDG fuel system revoaled that the fuel tanks and pumps are located in an underground concrete bunker with access-to j
the tank top mounted pumps and valves controlled by an operational-ly-locked door. Operations personnel inspect this area eac! shift and take readings of the fuel level in each tank. New fuel into
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these two tanks is supplied from a common. locked and capped nozzle.
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Immediately following the nozzle is a separate four-inch valved fill line to each of the two tanks. The inspector determined that each of i
the EDG fuel storage tzAs is equipped with in-tank equalizing = valves l
(FO-5 and F0-10) that are. operated from the top of the tanks by means i"
of an installed reach rod operator. The equalizing valves (when both are open) provide direct fuel flow piping tatween the bottoms-of.both tanks. This inspection determined that both,f the equalizing valves
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were open.
The EDG fuel system is provided wi A cross-over piping
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and valving downstream of the fuel transfer pumps to permit the opera-tion of an EDG unit utilizing the other EDG unit's Tuel ac age tank fuel and fuel pump. This inspection determined that the cross-over piping valve FO-11 was open.
The inspector determined that Licensee Procedure 1-25-1, " Fuel Oil System Attachment A, Fuel Oil System Valve Lineup" requires that EDG fuel tank equalizing valves FO-5 and F0-10 and fuel cross-over-valve FO-11 be open.
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The inspector questioned the deliberate tying of the otherwise separate:
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and independent EDG fuel systems together by means of the normal valve alignment i_n-Procedure 1-25-1.
With both_the equalizing and cross-over valves open, the two fuel storage tanks become in effect
-one tank.
As a consequence, any single. failure in the fuel tanks or piping or i
an improper: lot of fuel oil can become a source for the common mode failure of both of the EDG units. The licensee initiated an evalua-tion (completion expected by June 1,1990).to review the acceptability-
of these practices.- This item is unresolved pending completion of the licensee's evaluation and NRC review of the resolution
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(Unresolved Item 90-07-01).
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2.4' Adequacy of Quantity Of Stored EDG Fuel Oil l
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The inspector discussed with the licensee the Technical Specification
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Section 3.12 which specifies the minimum amount of EDG fuel oil
required in the diesel fuel. oil storage tanks in order to provide for
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the maximum expected engineered safeguard loads for a period of seven i
days'.. The inspector noted that the amount of fuel appeared to be low for this make and model of engine to operate loaded for a seven day l'
time period. The licensee stated that the EDG loading and fuel
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consumption are currently being evaluated in response to 'Information Notice 89-50 in order tu assess their adequacy.
Based upon the
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licensee's preliminary review, it appears-that the Technical Specifi-
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l cation minimum amount of fuel is Inadequate to support operation of p
the EDGs for the required seven days.
In a telephone discussion'with 1-the licensee on May 22, 1990, licensee personnel stated that an
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L-administrative-limit of a minimum of 29,600 gallons would be imposed L
instead of the lower 19,600 gallons minimum limit of the technical-p specifications pending final resolution of this issue.
The, increased minimum limit of 29,600 gallons reflects the current conservative
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calculations. The licensee plans a final resolution of this issue in
July 1990.
This-is an unresolved item. pending final resolution of the minimum fuel oil required for the storage tanks.
(Unresolved Item 50-309/90-07-02).
2.5 EDG Fuel Oil Sampling and Analysis Program i
The licensee procures EDG fuel oil under Blanket Purchase Order 57077-00 in which the fuel oil is required to comply with the requirement; of ASTM _ Specification 0975 for Grade 20.
The purchase order requires that the fuel supplier indicate-that the fuel oil meets all specification requirements. A review of the. purchase
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order and a recent (4/15/90) fuel oil delivery determined that the only indication of compliance was a statement handwritten across the top portion of the fuel oil delivery ticket " meets ASTM D-975-20."
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Upon-delivery, the fuel oil is sampled by Plant Chemistry for analysis and the delivery ticket is signed by operations personnel accepting the fuel oil.
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In order to verify that purchased fuel oil complies with o
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specification requirements, it is important that fuel oil receipts l
undergo appropriate verification analyses.
Since fuel oil degrades
- with time and because of other contaminants, it is'important that
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L stored fuel oil undergo periodic analysis to ensure continuing fuel-
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quality.
Inspection of the licensee's fuel sampling / analysis program revealed deficiencies which could lead to potential problems-including common
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mode failure of the EDG units.
The deficiencies with'.the licensee's.
diesel fuel oil sampling / analysis program have been recognized by-the l
licensee and most previously have been identified by both Plant E
Chemistry and QA personnel in various documents including " Receipt'of QAR F,1 011 QA/QC Surveillance Report No. 90S-021". This report
covers an audit period from December 15, 1989 through March 24, 1990.
Problems identified by the licensee and the inspector include the
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following:
_ Fuel oil ' samples taken_by the Chemistry Department'are not
being processed in.a timely manner.
New fuel is off-loaded from the tanker trucks into the EDG storage tanks prior to
.l completion of the minimal ASTM D-975 analyses for water, f
sediment, and viscosity. The only analyses performed are for specific gravity and that it "looks like" and " smells like" diesel fuel oil, j
The incoming new EDG fuel oil is never analyzed by the licensee i
to determine compliance with the other ASTM D-975 specification
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-requirements. including those for flash point, cetane number,
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i distillation temperature, sulphur _ content, ash, and cloud point.
Fuel oil' stored in-the EDG fuel storage tanks is never analyzed
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by Plant Chemistry to ensure its continuing' quality.
The inspector determined that the licensee's QA program to ensure
'l the quality of EDG fuel oil includes an annual audit of fuel
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quality in the EDG fuel storage tanks. A sample of the fuel from each tank is analyzed by an outside' laboratory to verify all of the ASTM D-975 specification requirements. However, the inspector questioned the value of this annual analysis.
During-an outage when the auxiliary boilers are operating, the fuel storage tanks may receive one to two tanker loads of new fuel a day. A sample / analysis made under these circumstances would be of limited value in assuring the quality of the fuel oil in the storage tanks later during power operation when the auxiliary j
boilers are not operating.
The value of this type of analysis
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is directly related to its timing and frequency.
Because of the fact that these potential EDG fuel oil sampling /-
analysis deficiencies could lead to the common mode failure of the EDG units, the licensee currently is addressing means to assure the l
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quality of incoming' deliveries of new fuel oil 'and the periodic.
sampling / analysis of the. fuel stored in the tanks to assure the
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~ continuing quality of the fuel oil. This' item is unresolved pending j
L the completion of licensee corrective actions and NRC review of this L,
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issue (50-309/90-07-03).
2.6 Licensee's' Response to IN 87-04-
The inspector reviewed the licensee's responses to IN 87-04 from the
, initial 0perational Assessment (OAS) Contro1~ Number 4-14-4, July 22,
.1987: evaluation through the other ten assessments to 0AS Control Number ~4-14-14 dated December 14, 1987.
The operational evaluation assessments properly addressed the issues, were technically adequate and' led to the implementation of changes in EDG fuel oil specifi-
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cations, fuel oil sampling / analysis / testing, preventive maintenance
- and operational procedures, and EDG fuel system alarm setpoints,
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The inspector considered that the licensee had addressed IN 87-04 e
h adequately, with the exception of the unresolved issues discussed.in
'the prior paragraphs pertaining to:
the minimum required amountiof
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- fuel in the fuel storage tanks; the sampling of the fuel in the storage tanks; and cross connections of the fuel storage tanks.
'3.0 Unresolved Items Unresolved. items are matters about which more information is required in y
- order to ascertain whether they are acceptable items, violations or
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deviations. Unresolved items are discussed in paragraphs 2.3, 2,4 and.
2.5 of this report.
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4.0 Exit Meeting'
l Licensee management was informed of the purpose and scope of tne
- inspection at the entrance interview. The findings of the inspection
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were; periodically discussed and were summarized at the exit meeting
- on April 20, 1990.
At'tendees at the exit meeting are listed in Section 1.0 of this report. At no time during the inspection was written material l
provided to the licensee by the inspector.
The licensee did'not-
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indicate that the inspection involved any proprietary information.
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