ML17229A738

LER 98-006-00:on 980421,missed EDG Fuel Oil Sample Surveillance Was Noted.Caused by Personnel Error.Revised Fuel Oil Sampling Service Purchase Order & Revised Site procedure.W/980521 Ltr

ML17229A738
Person / Time
Site:	Saint Lucie
Issue date:	05/21/1998
From:	Frehafer K, Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-98-131, LER-98-006, LER-98-6, NUDOCS 9805290081
Download: ML17229A738 (7)

Text

CATEGORY ling REGULATORY INFORMATION DISTRIBUTIONSYSTEM (RIDS)

ACCESSION NBR:9805290081 DOC.DATE: 98/05/21 NOTARIZED: NO DOCKET ¹ FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 AUTH.NAME AUTHOR AFFILIATION FKEHAFER,K.W. Florida Power &, Light Co.

STALL,J.A. Florida Power & Light Co.

RESHIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 98-006-00:on 980421,missed EDG fuel oil sample surveillance was noted. Caused by personnel error. Revised fuel oil sampling service purchase order & revised site procedure.W/980521 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ZD CODE/NAME LTTR ENCL PD2-3 PD 1 1 'LEAVES,W 1 1 INTERNAL: ACRS 1 1 ~nf.Sn~eB 2 2 AEOD/SPD/RRAB 1 1 LE C 1 1 NRR/DE/ECGB 1 1 NRR/DE/EELB l. 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DET/EIB 1 1 RGN2 FILE 01 1 1 D EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE, J H 1 1 0 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 .1' NRC PDR 1 1 NUDOCS FULL TXT 1 U

E N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Fiorida Power & Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 May 21, 1998 L-98-131 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie.Units 1 and 2-Docket Nos. 50-335, 50-389 Reportable Event: 98-006 Date of Event: April 21, 1998 Missed EDG Fuel Oil Sample Surveillance Due to Personnel Error The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73.

Very truly yours, A. Stall Vice President St. Lucie Plant JAS/EJW/KWF Attachment cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant A

'rr8052'rr008i 98052i PDR ADOCK 05000335 8 ~v 8 PDR V'n FPL Group company

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3160%104 (4-96) EXRRES 04l30/SS ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATO INFORMATION COLLECTION REQUEST: 60.0 HRS. REPORTED LESSON LEARNED ARE INCORPORATED INTO THE UCENSINQ PROCESS AND BACK TO INDUSIRY. FORWARD COMMENTS REQARDINQ BURDEN ESTIMA LICENSEE ERTZÃT REPORT (LER) To THE INFORMATION AND RECORDS MANAQEMENT BRANCH IT% F33)

U.S. NUCLEAR REGULATORY COMMISSION, WASHINQTON, OC 206664XX)1 ANO TO THE PAPERWORK REDUCTION PROJECT 131600)04), OFRCE 0 (See reverse for required number of MANAGEMENTANO BUDQET, WASHINGTON, OC 20603.

digits/characters for each b)ock)

FAcluTY NAME l1) DOCKEf NLIVIBER 62) PAQEI3)

ST LUCIE UNIT 1 05000335 1 OF4 TITLE l4)

Missed EDG Fuel Oil Sample Surveillance Due to Personnel Error FACIulYNAME DOCKET NUMBER MONTH DAY YEAR SEQUENTIAL REVISION NUMBER NUMBER MONTH DAY YEAR St. Lucia Unit 2 05000389 FACIUTY NAME DOCKET NUMBER 21 98 98 006 0 21 98 n/a OPERATING MoDE (9) 20.2201 (b) 20.2203(a)(2) (v) 50.73(a) (2)(i) 50.73(a)(2)(viii)

POWER LEVEL (10) 100 20.2203(a)(2)(i) 20.2203(a) (3)(ii) 50.73(a)(2)(iii) 73.71 OTHER 20.2203(a) (2) (iii) 50.36(c) (1) 50.73(a)(2)(v) Specify in Abetrect below or in NRC Form 3BBA 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2) (vii)

TELEPHONE NUMBER Brcludo Aroo Code)

K. W. Frehafer, Licensing Engineer (561) 467-7748

';5gpE4.,'&t CAUSE SYSTEM COMPONENT REPORTABLE REPORTABLE To NPRDS CAUSE SYSTEM COMPONENT MANUFACTURER To NPRDS n/a n/a n/a n/a n/a MONTH DAY YEAR EXPECTED YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X No DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On April 21, 1998, St. Lucia Units 1 and 2 were in Mode 1 at 100 percent reactor power. The Nuclear Plant Supervisor invoked Technical Specification 4.0.3, for a missed surveillance on new emergency diesel generator fuel oil delivered on February 17, 1998. The fuel oil sulfur analysis was not performed to the test method specified in the Technical Specifications. A subsequent re-analysis of the February 17, 1998, fuel oil sample was performed to the correct test method and demonstrated that the sulfur content was within the required specification, and Technical Specification 4.0.3 was exited the same day.

This event was caused by a combination of cognitive personnel error on the part of the vendor contracted to perform the sample analysis and procedural inadequacies for site verification of the fuel oil sample results.

Corrective actions included revision of the fuel oil sampling service purchase order and revision of the site procedure used for verification of emergency diesel generator fuel oil properties.

NRC FORM 3BB (4.96)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISS(o I4-96)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 2 OF 4 98 006 0 TEXT (ffmore spaceis required, use additional copies of itVRC Form 3MA/ I17]

On April 21, 1998, St. Lucie Units 1 and 2 were in Mode 1 at 100 percent reactor power. At approximately 1130 on April 21, 1998, the Nuclear Plant Supervisor (NPS) received a facsimile copy of a Condition Report (CR) that was generated by the FPL corporate Quality Assurance Department. It described a condition related to the emergency diesel generator (EDG) fuel oil

[EIIS:DC] sample analyses performed by Herguth Laboratories, Inc. of Vallejo, CA. The issue dealt with a new fuel oil shipment that was sampled on Febru'ary 17, 1998. The St. Lucia Unit 1 and 2 Technical Specification Surveillance 4.8.1.1.2.c.2 requires verification of specified EDG fuel oil properties "when tested in accordance with ASTM D975-81 except that the analysis for sulfur may be performed in accordance with ASTM D1552-79 or ASTM D2622-82." This verification is required within 31 days of obtaining the new EDG fuel oil sample. Contrary to these requirements, the fuel oil laboratory results received on February 27, 1998, analyzed the sulfur content using an ASTM D4294-90 analysis, a test method not recognized by the Technical Specifications.

The Nuclear Plant Supervisor (NPS) invoked Technical Specification 4.0.3, which specifies actions to be taken upon discovery of a missed surveillance. In this instance, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay in applying action requirements for EDG inoperability was allowed, in order to provide time to complete the surveillance.

Herguth Laboratories was notified of the requirement to re-analyze the February 17, 1998, EDG fuel oil sample sulfur content per ASTM D2622-82. At 1315 on April 21, 1998, Technical Specification 4.0.3 was exited when Herguth notified the NPS that the sample sulfur result, 0.0373% by weight, was within the requirements of table 1 of ASTM D975-81.

This event was caused by a combination of cognitive personnel error on the part of the vendor and procedural inadequacies for site ver'ification of the fuel oil sample results.

The purchase order for the St. Lucie fuel oil sampling contract specified the correct Technical Specification ASTM standard to be used for analyzing sulfur content. The vendor erroneously applied the sulfur analysis methodology specified in the price list used by the vendor when developing their quote for services. The price list is contained in the commercial portion (i.e., the portion of the purchase order not subject to 10 CFR, Appendix B, quality assurance requirements) of the purchase order. A joint Nuclear Utilities Procurement issues Committee (NUPIC) audit finding has been accepted by the vendor, Herguth Laboratories, Inc. of Vallejo, CA., and documents the misapplication of purchase order requirements by the vendor.

NRC FORM 3BBA I4.96)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO I4-96I LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 3 OF 4 98 006 0 TEXT (ifmore space is rerluired, use addidonal copies of NRC Form 386Ai I17)

The procedure used to verify the emergency diesel fuel oil sample analysis, C-05, "Diesel Fuel Oil Inventory, Receiving Shipments and Periodic Sampling," was inadequate to assure proper verification of sample results. The procedure did not provide adequate instructions to check each analysis result for the proper test method and did not provide complete references to individual test methods allowed by ASTM D975-81.

Generic implications of this event'were investigated by the FPL corporate Quality Assurance Department by examining other vendors that perform Technical Specification required testing.

Duke Engineering and Services Environmental Labs, the vendoi that provides testing on quarterly gaseous and effluent composite samples, was reviewed and no Technical'pecification discrepancies in test methods were noted.

This event is reportable urlder 10 CFR 50.73(a)(2)(i)(B) as "any operation or condition prohibited by the plant's Technical Specifications," due to the missed surveillance of the EDG fuel oil sample.

The improper EDG fuel oil sulfur analysis had no adverse impact to the health and safety of the public. The subsequent fuel oil analysis demonstrated that the sulfur content was within the required specification, and EDG operability was not compromised by the missed surveillance.

The fuel purchased for the EDGs is low sulfur fuel oil, which typically has a sulfur content of 10 times less than the limit, and the EDG diesel oil storage tanks are tested every 6 months for sulfur content. The effects of an addition of postulated high sulfur content fuel oil would be minimized by the mixing effect with the existing large volume and low sulfur concentration of oil in the EDG diesel oil storage tank and resultant dilution. Additionally, the sulfur analysis was performed with an updated ASTM method for sulfur which would have indicated an adverse sulfur concentration.

The existing purchase order, PO 00026828, was revised to correct the erroneous fuel oil sulfur ASTM analysis method referenced in the vendor's quoted price list.

NRC FORM 388A I4.96I

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSIO

<4-seI LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION YEAR SEQUENTIAL REVISION ST LUCIE UNIT 1 05000335 4 OF 4 98 006 0 TEXT flfmore space is required, use additional copies of NRC Form 366AJ <17)

Procedure C-05, "Diesel Fuel Oil Inventory, Receiving Shipments and Periodic Sampling,"

will be revised to ensure that:

1. each analysis is performed per the correct ASTM test method,

2. each analysis result is within ASTM D975-81 specifications,

3. instructions are included for notification and CR initiation upon discovery of any Technical Specification parameter found out of specification, and

4. tracking is included to ensure results are promptly verified to allow any potential corrective action to be performed within the time frame allowed by the Technical Specifications.

None None NRO F0RM 388A <4-88I