IR 05000317/1989017
| ML20246G139 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/16/1989 |
| From: | Anderson C, Julio Lara NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20246G126 | List: |
| References | |
| 50-317-89-17, 50-318-89-18, NUDOCS 8908310232 | |
| Download: ML20246G139 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION ~
REGION I
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50-317/89-17-Report Nos. 50-318/89-18-50-317'
Docket'Noi 50-318'-
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'Li ensee: ' Baltimore Gas and Electric Company
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'P.O. Box 1475 B_al_timore, Maryland 21203 Facility.Name: 'Calvert Cliffs Units 1 & 2
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W Inspection'At:
Lusby, Maryland-
-Inspection' Conducted: July-17-21,-1989
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_ Inspectors-
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J. F! Lara, Reactor Engineer, PSS date
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Approved by:
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C.p. Anderson, Chief,PiantSystemsSection date Inspection Summary: -Routine' unannounced inspection on July 17-21, 1989 (__ Combined Inspection Report Nos. 50-317/89-17 and 50-318/89-18)
Areas-Inspected:
Inspection of the licensee's program to ensure the quality'
of,the. emergency diesel generator fuel oil.
Results: One deviation from NRC commitments as specified in the facility's
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FSAR was identified pertaining to the sampling and. testing of fuel oil, pgj!S3rds!E Ss88)ig Q:
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DETAILS 1 ~. 0 Persons ~ Contacted
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1.1 ' Baltimore Gas & Electric Co.
- A. B. Anuje, Quality Audits Units
- P.-T. Crinigan, Chemistry Gen. Supervisor
- P. Furio, Licensing Engineer
- M. J. Gahan, Principal Engineer
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- W. F..Lang, Senior Engineer C. H.'Quimby, Quality Audits Unit E. Roach, QA Auditor M. S. Rominger, Chemistry
- L. B. Russell, CC Manager G. F. Wall, QASSD R.. L. Wenderlich, Gen. Supervisor - Nuclear Operations J. A. York, Chemistry 1.?
U.S. Nuclear Regulatory Commission
- H. Eichenholz,-Senior Resident Inspector
- V. Pritchett, Resident Inspector
- Denotes those present at exit meeting on July 21, 1989.
2.0 Purpose of Inspection The purpose of this inspection was Lto determine the licensee's program for the procurement, receipt, storage,_ handling and control of emergency diesel generator (EDG) fuel oil to ensure adequate quality of the fuel oil. Since the EDGs,.their fuel systems, and procedures are identical for Calvert Cliffs Units 1 and 2, this inspection is applicable to both units. The inspection included review of licensee procedures, records, and interviews with personnel.
Procedures and documents reviewed are listed in Attachment A.
3.0 Background In response to recent industry problems, the NRC issued Information Notice 87-04 on January 16, 1987 to alert licensees of potentially significant problems pertaining to the long-term storage of EDG fuel oil. The information notice documents the June 27, 1986 circumstances at Arkansas Nuclear One Unit 2 (ANO-2) which led to the inability of an EDG to complete a 24-hour endurance test due to a high concentration of particulate in the fuel oil. The particulate were determined to be a result of oxidation and biological contamination.'
In addition, on May 5, 1988, an EDG'at Diablo Canyon experienced a high differential pressure across a primary fuel filter.
It was later determined that the filter was clogged with biological debris and, in addition, the fuel oil day tanks were discovered to be contaminated with biological growth.
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To ensure the' continued quality of EDG fuel oil, a comprehensive inspec-tion, sampling and testing fuel oil program is essential. 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 the EDG fuel oil.
4.0 Inspection Results 4.1 Procurement of Fuel Oil The initial step in assuring proper fuel oil quality requires purchasing the appropriate fuel oil and a receipt inspection to assure the quality of the fuel oil prior to addition into the storage tanks. The licensee's purchase requisition for EDG fuel oil requires that the fuel supplier provide No. 2 Fuel Oil conforming to various specifications in accordance with ASTM standards. These specifica-tions pertain to limits for API gravity, flash point, sulphur, ash, water and sediment, viscosity among others. The fuel supplier is not-required to furnish a certificate of compliance upon delivery.
Prior to unloading the fuel, the licensee takes a sample from the delivery truck and it is promptly analyzed by chemistry personnel for specific gravity, viscosity, water and sediment.
In accordance with procurement procedures, these properties must meet acceptance criteria limits for the analyzed parameters before the fuel is unloaded into the storage tanks. The inspector's review of sampling and test results indicated a discrepancy 11 tha parameters analyzed during March 1989 fuel oil deliveries. The inspector noted that between March 15-28, 1989, 29 samples of fuel oil were not
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l analyzed for viscosity as required by chemistry procedures. The I
licensee acknowledged the discrepancy and indicated that it had been
identified during their internal review of records. There was a high number of fuel oil deliveries during this interval and the chemistry personnel did not analyze these samples. The licensee reinstructed chemistry personnel as to the procedural requirements during a train-ing session. The inspector did note that even though the chemistry
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personnel are analyzing the new fuel oil for specific gravity, viscosity, water and sediment, in accordance with chemistry procedures, the fuel oil procurement procedure, " Procurement and Storage Manual Section 6.9," only requires that chemistry personnel analyze for specific gravity. The licensee indicated the procurement procedure would be revised to require additional analyses for viscosity, water ar.d sediment.
No other deficiencies were identified.
4.2 Technical Specification Requirements and Licensee Commitments The Technical Specifications (T.S.) provide surveillance requirements relating to the quality of EDG fuel oil in the main storage tanks.
T.S. 4.8.1.1.2.b requires that at least once per 92 days an oil l
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sample from the fuel oil storage tanks be analyzed for viscosity, water and sediment. These parameters must be within the limits specified in Table 1 of ASTM D975-81. The inspector reviewed pre-vious surveillance test results and found that these parameters were within the acceptable limits as specified in the ASTM standard.
However, the inspector did note that the surveillance test procedure, STP No. 0-34-0, " Fuel Oil Quarterly Test," listed the maximum viscosity acceptable limit as 4.3 cst whereas Table 1 of ASTM D975-81 listed 4.1 cst as the acceptance limit. The licensee agreed to review the discrepancy and revise the surveillance procedure as necessary.
Since fuel oil degrades with time and external sources contribute contamination, periodic inspection is desired to assure continued fuel oil quality. The Calvert Cliffs FSAR Section 8.4.1.2 states the licensee's commitment to perform periodic sampling and testing of new and stored fuel oil as follows:
" Quarterly samples will be composited from incoming fuel oil and analyzed for API gravity, specific gravity, flash point, sulfur, ash, BTU per gallon, and viscosity.
Sampies are obtained from the fuel oil storage tanks every 3 months and analyzed for oxidation / deterioration products."
During this inspection the licensee was unable to. provide any documented evidence to show that the above sampling and testing analysis were being performed. The only testing performed is during initial delivery of fuel oil for viscosity, specific gravity, water and sediment (see Section 4.1).
Therefore, the licensee has no method of verifying that the procured fuel oil meets all the specifi-catiens listed in the purchase requisition.
In addition, the licensee has no data pertaining to oxidation products in the storage tank.
This discrepancy was identified during a Quality Assurance Audit (87-36) performed from July 21, 1987 thru January 18, 1988. However, as of this inspection the QA finding still had not been resolved, and no sampling / testing had been performed in the interim.
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Failure to perform sampling and testing of new and stored EDG fuel oil is considered a deviation from the licensee's commitments as specified in the Calvert Cliffs FSAR (50-317/89-17-01 and 50-318/89-18-01).
l Though the licensee is not currently sampling / testing the fuel in the storage tanks, it is implementing several actions which minimize the probability of an EDG being affected due to poor quality fuel oil.
The licensee performs the following scheduled activities:
Weekly draining of water from #11 and #21 FOST
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Monthly recirculation of #11 and #21 FOST
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s Annual addition of biocide / anti-corrosion additive to #11
and #21 FOST.
Periodic scheduled inspection of the FOST cathotic protec-
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tion. system 10 year draining and inspection of FOSTs
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In addition, in response to IN 87-04, the licensee included EDG fuel
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oil. strainers / filters in its PM program. These components are monitored i"
and cleaned on an' annual basis.to preclude clogging due to bacterial growth.
No other deficiencies were identified.
4.3 ? EDG System Design and 0 m ation Since excessive particulate in the fuel could lead te fuel
. strainer / filter clogging at described in IN 87-04, the inspector reviewed the licensee's fuel system' design, operational
. characteristics,'and actions taken to minimize the possibility of EDf, shutdown due to fuel particulate contamination.
The fuel system design provides for suction pipe pickup of fuel approximately 9 inches above the bottom of the main fue1~ storage tank to minimize the pick-up of particulate and water from the tank bottom. -Each EDG has the capability to obtain fuel from either of the two redundant storage tanks through-redundant headers..The fuel
. supply system to the EDG engine consists of an engine driven fuel pump. On each EDG unit there is a dual strainer basket assembly ahead of thel fuel pumps. The assembly is of the duplex type which permits operation on one filter.
In the event one filter becomes fouled, the. operation may be switched to the other filter without interrupting EDG operation. The assembly is instrumented to provide differential pressure indication.
In addition, a low fuel oil pressure local alarm is provided which could indicate dirty or
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clogged fuel filters. A remote EDG combined trouble alarm is pro-vided in'the control room along with other alarms annunciated at the local EDG control panel. The main fuel storage tank and day tank for each EDG unit are also instrumented to provide for local level indications and alarms, respectively.
4.4 QA Review of EDG Fuel Oil Program The inspector determined that the Quality Assurance function in the licensee's fuel oil program is to provide audit surveillance of the
adequacy of the implementation of the program. The inspector
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. reviewed Quality Audits Unit (QAU) Finding No. 87-36-02 dated-
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March 21, 1988 and QAU Surveillance No. S-88-08 conducted in August
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- September 1988 to assess-the coverage and scope of findings.
The'se.QAU documents identified procedural non-compitances in addition to the previously discussed failure to test fuel oil-samples as described in the FSAR (see Section 4.2).
In response to the QA finding, the chemistry departn.ent proposed initiating a change to the FSAR to remove sampling and analysis
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requi rements. However, as of this inspection a 10 CFR 50.59 safety
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review had-yet to be initiated.
In the'1'ight of recent industry experience relating to EDG fuel oil quality,'the considered FSAR change appears to-be a step in the less conservative direction.
These audit:fii. dings are being tracked by the. audit group to ensure that they-are addressed and resolved prior to closure of the items.
5.0 Exit' Meeting i
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The findings of the inspection were discussed with the' licensee's representatives periodically daring the inspection. An exit meeting was-conducted on July 21, 1989 at which time the findings of the inspection l
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- At no time during this inspection was written material concerning the inspection findings provided to the licensee by the inspector..The licensee did not indicate that any proprietary information was involved within the scope of this ' inspection.
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ATTACHMENT A-
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EMERGENCY DIESEL GENERATOR FUEL OIL PROCEDURES
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AND DOCUMENTS REVIEWED.
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' Procurement and Storage Manual,~-Section'6.9, Rev. 4 " Obtaining Fuel Oil h
fcr Calvert Cliffs"
. CP-226, Rev. 1, " Oil. Specifications"
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01-21, Rev. 24, " Emergency. Diesel Generators"-
STP No. 0-34-0, " Fuel Oil Sampling Quarterly Test"
Quality Audits Unit' Finding Sheet; Finding No. 87-36-02
Quality Audits Unit Surveillance Report; Surveillance No. S-88-08
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CP-226 Attachment 2, "011 Service. Record", 9/28/88 - 6/30/89
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