ML17348B480

LER 92-004-00:on 920330,QA Auditor Determined That Vendor Lab Used Incorrect ASTM Test During 920130 Analyses of Fuel Oil.Procedure 0-NCSP-022.3, Receiving Fuel Oil Shipments revised.W/920427 Ltr

ML17348B480
Person / Time
Site:	Turkey Point
Issue date:	04/27/1992
From:	Plunkett T, Salamon G FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-92-128, LER-92-004, LER-92-4, NUDOCS 9205040186
Download: ML17348B480 (7)

Text

ACCELERATED DISTRIBUTION DEMONST/TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9205040186 DOC.DATE: 92/04/27 NOTARIZED: NO DOCKET 1T FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME . AUTHOR AFFILIATION SALAMON,G. Florida Power & Light Co.

PLUNKETT,T.F. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 92-004-00:on 920330,QA auditor determined that vendor lab used incorrect ASTM test during 920130 analyses of fuel oil.Procedure O-NCSP-022.3, "Receiving Fuel Oil Shipments" revised.W/920427 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Inciden Rpt, etc.

NOTES:NRR RAGHAVAN,L 05000250 A D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-2 LA 1 1 PD2-2 PD 1 1 AULUCK,R 1 1 INTERNAL ACNW 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB SD 1 1 NRR/DST/SICBSH3 1 1 NRR/DST/~SPL BD1 1 1 NRR/DST/SRXB SE 1 1 G FICHE 1 1 RES/DSIR/EIB 1 1 N2- =FILE 01 1 1 EXTERNAL: EG&G BRYCE,J.H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY,G.A 1 1 NSIC POOREgW 1 1 NUDOCS FULL TXT 1 1 NOTES: 1 1 D

A D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31

P.O. Box 029100, Miami, FL, 33102-9100 FPL 0>> 21%2 L-92-128 10 CFR 50-73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit 3 Docket No. 50-250 Reportable Event: 92-004 Date of Event: January 30, 1992 Diesel Fuel Oil Analysis Performed Usin Non-Technical S ecification ASTM Anal sis The attached Licensee Event Report is submitted pursuant to the requirements of 10 CFR 50.73 to provide information on the subject event.

Very truly yours, T. F. Plunkett Vice President Turkey Point Nuclear TFPQGS Attachment cc: 'Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9205040186 920427 PDR ADOCK 05000250 S PDR an Fpi. Group company

LICENSEE EVENT REPORT (LER)

FACILITY NAME (1)

DOCKET NUMBER (2) PAGE (3)

TURKEY POINT UNIT 3 05000250 1 oF 3 TITLE (e) Diesel Fuel Oil Analysis for Sulfur Performed in Accordance With ASTM Specification Other Than Required by Technical Specifications Due to Vendor Error EVENT DATE (5) LER NUMBER,(6) RPT DATE (7) OTHER FACILITIES INV. (8)

HON DAY YR YR SEQ 0 Rf HON DAY DOCKET 0 (S) 27 92 Turkey Point Unit Oe 01 30 92 92 004 4 . 0500-0251 OPERATING HODR (9) 10 CFR 50.73 a 2 i POllER LEVEL (10) 871 LICENSEE CONTACT FOR THIS LER (12)

G;- Salamon, Licensing Engineer TELEPHONE NUMBER 305-246-6560 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COHPONENT HANUFACTURER NPRDS CAUSE SYSTEH COHPO- MANUFACTURER NENT EXPECTED MONTH DAY SUPPLEMENTAL REPORT EXPECTED (le) SUBHIS-SION (If yes, complete EXPECTED SUBHISSION DATE) NO DATE (15)

X,,

ABSTRACT (16)

On January 23, 1992, two shipments of. diesel fuel oil were delivered to Turkey Point. On March 30, 1992, a Quality Assurance Auditor determined that an ASTM specification which was not identified within the Turkey Point Technical Specifications (TS) was used to determine the sulfur content of the fuel oil delivered on January 23. Turkey Point implements the applica-ble Technical Specification primarily by specifying on the purchase order that the vendor perform the oil analysis in accordance with the TS required ASTM analyses. The vendor believed that any specification permitted by the current edition of the ASTM codes may be used to perform the analysis.

Based on this belief, the vendor selected a sulfur analysis method other than the ones called for in the Technical Specifications. The vendor indicated that the selection of the ASTM D4294 method was based on the essential equivalency of the four test, methods permitted in the latest edition of the ASTM codes. On April 14, 1992, the sulfur analysis was performed using ASTM D129, and confirmed that the fuel oil met the require-ments of the Technical Specifications. Procedure O-NCSP-022.3 was revised to require that the use of the appropriate TS required ASTM analysis be verified upon receipt of the analysis test results. The Technical Specifi-cations will be reviewed 'to identify other TS required ASTM analyses which may have been performed to ASTM specifications not permitted by the Techni-cal Specifications. Any operation or condition. prohibited by the plant's Technical Specifications is reportable under 10CFR50.73(a)(2)(i).

LECENSEIQFBNT REPORT (IER) TEXT CO+NOATZON FACILITY NAME DOCKET NUMBER LER NUMBER PAGE NO.

TURKEY POINT UNIT 3 05000250 92-004-00 02 QF 03 EVENT DESCRIPTION On January 23, 1992, two shipments of diesel fuel oil were deliv-ered to Turkey Point for addition to the Unit 3 Main Tank (EK, EIIS: TK) and the East Light Oil Tank. A vendor laboratory com-pleted analyses of the oil on January 30, 1992. On March 30, 1992, during a scheduled vendor audit, a Quality Assurance Auditor determined that. an ASTM specification which was not identified within the Turkey Point Technical Specifications (TS) was being used to determine the sulfur content of the fuel oil delivered on January 23. Units 3 and 4 were operating at 874 and 100> power, respectively, at the time of discovery. On April 14, 1992, follow-ing confirmation of the fact that the actual ASTM test being used for testing was not the correct one, the analysis was reperformed

,using the correct ASTM test. The results indicated that the sulfur content of the fuel oil was within acceptable limits.

During the dual unit outage which was completed in October, 1991, two additional Emergency Diesel Generators (4A and 4B) (EK, EIIS:

were installed. New fuel oil tanks were also installed to be DG) used by the 4A and 4B diesels. The oil used for the initial fill of the Unit 4 tanks was analyzed in accordance with the appropriate ASTM specifications.

Any operation or condition prohibited by'he plant's Technical Specifications is reportable under 10CFR50.73(a)(2)(i) .

II. EVENT CAUSE Turkey Point implements the applicable Technical Specification (TS 4.8.1.1.2.e(1)) through the following process:

o, procedure O-NCSP-022.3 requires the testing of the fuel oil delivered within 30 days of sampling to determine that the sulfur content of the oil is less than .50%.

o by specifying on the purchase order that the vendor perform the diesel oil analysis 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.

o following receipt of the test results, verifying that the sulfur concentration is less than .50%.

The vendor laboratory which performed the sulfur analysis believed that any specification permitted by the current edition of the ASTM codes may be used to perform the analysis. Based on this belief, the vendor'selected sulfur analysis method D4294, Standard Test Method for Sulfur in Petroleum Products by Energy-Dispersive X-Ray Fluorescence Spectroscopy. Technical Specification 4.8.1.1.2.e(1) requires testing using D975-81, except for sulfur, which may also be analyzed in accordance with ASTM D1552-79 or ASTM D2622-82.

I ICBBSBBQBBT RBPORT (IBR) TBXT COlHUATIOB FACILITY NAME DOCKET NUMBER LER NUMBER PAGE NO.

'URK%7 POINT UNIT 3 05000250 92-004-00 03 oF 03

'ASTM D975-81 does not permit analysis in accordance with ASTM D4294, however ASTM D975-90, the most recent revision of the D975 specification, does permit the use of ASTM D4294. The vendor indicated that the selection of the ASTM D4294 method was based on the essential equivalency of the four test methods permitted in the latest edition of the ASTM codes. Based on this, the cause of the event. was determined to be personnel error by non-utility non-licensed personnel, in that the vendor did not follow the specifi-cations of the purchase order.

III'VENT SAFETY ANALYSIS On April 14, 1992,- the sulfur analysis was performed using ASTM D129. The analys'is confirmed that the fuel oil sulfur concentra-tion was below .50>, and therefore the oil met the requirements of the Technical Specifications. Based on the above, the Emergency Diesel Generators were not placed in an inoperable condition due to improper fuel oil, and the health and safety of the public were not affected.

IV% CORRECTIVE ACTIONS The Unit 3 Main Tank and the East Light Oil Tank were sampled and analyzed for sulfur on April 14, 1992. ASTM D129, as permitted by the Technical Specifications, was used for the analysis. The results indicated a sulfur concentration of

. 40>o.

2 ~ The vendor was requested to perform analyses on fuel oil samples using only the methods listed on the purchase order.

3 ~ Procedure O-NCSP-022.3, Receiving Fuel Oil Shipments, was revised to require that the use of the appropriate,.TS required ASTM analysis be verified upon receipt of the analysis test results.

4. The Technical Specifications will be reviewed to identify other TS required ASTM analyses which may have been performed to ASTM specifications not permitted by the Technical Specifi-cations. The review will be completed by May 15,. 1992.

V. ADDITIONAL INFORMATION A. Similar Events: None B. Additional Information: None

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