ML18094A758

Responds to NRC 890824 Ltr Re Deviations Noted in Insp Repts 50-272/89-18 & 50-311/89-16.Corrective Actions:Updated Final Safety Analysis Rept Change Will Be Initiated to Correct Rept & Specify That Oil Supplied to Diesel Generator

ML18094A758
Person / Time
Site:	Salem
Issue date:	10/02/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89198, NUDOCS 8910160208
Download: ML18094A758 (8)

Text

• Steven E. Miltenberger Vice President and Chief Nuclear Officer Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-4199 OCT 0 2 1989 NLR-N89198 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF DEVIATION NRC INSPECTION REPORT NO. 50-272/89-18 AND 50-311/89-16 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated August 24, 1989, which included a Notice of Deviation concerning the use of heating fuel for the diesel generators. PSE&G's response to this Notice of Deviation is provided in the attachment to this letter.

Should you have any questions in regards to this transmittal, do not hesitate to call.

Attachment 8910160208 891002 1fol PDR ADOCK 05000272 Q PNU

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• Document Control Desk NLR...,.N89153 c Mr. J. c. $tone 2

OCT O 2 1989 Licensing Project Manager Ms. K. Halvey_Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

• I I

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• • ATTACHMENT The NRC in it's letter dated August 24, 1989, identified a deviation froin FSAR section 9.5.4 -pertaining to the diesel fuel oil system. The deviation and PSE&G's response are provided below.

FSAR Section 9-. 5. 4. states in part, that the diesel fuel oil system stores and supplies the diesel generators with No. 2 diesel fuel oil.

Contrary to_the above, as of June 20, 1989, the diesel fuel oil system stored and supplied the diesel generators with building heating fuel instead of No. 2 diesel fuel oil.

RESPONSE

PSE&G DOES NOT DISPUTE THE DEVIATION PSE&G believes that-the reference to No. 2 diesel fuel oil.

in question was an error in an effort to describe that No. 2 fuel oil is supplied to the diesel generators from the diesel fuel oil system. This is supported in the FSAR as all other mention of fuel oil in the FSAR is either " fuel "

or "fuel oil", including numerous mention in Section 9.5.4.

The Technical Specifications further support that fuel oil is correct as they also specify "fuel oil", "fuel", and "diesel fuel".

CORRECTIVE ACTION TO PREVENT RECURRENCE An UFSAR change will be initiated that will correct the FSAR to specify that fuel oil is supplied to the diesel generators. This change will be incorporated into the next FSAR update, scheduled*

for July 1990.

ADDITIONAL INFORMATION In the cover letter of the subject inspection report, it was requested that PSE&G address the unresolved item regarding dedication of consumable materials as safety grade and any changes in procedures or hardware that would be made to improve EDG reliability based on PSE&G's follow-up of the observations identified in this report.

In regards to the dedication of consumable materials as safety grade, the fuel oil for the diesel generator is procured in the following manner. Fuel oil for Salem is currently purchased through our standard process as non-safety related. This includes PSE&G specifications that the fuel meet a

• • modified ASTM 0396 criteria. All fuel oil received at Salem is sampled upon receipt in accordance with Operating Procedure V-13.3.2, "Accepting Fuel Oil Truck Delivery". This sample is then analyzed by Maplewood Lab for BTU content, sulfur content, water, sediment and specific gravity. Every tenth sample is also analyzed for flash point. This testing ensures that the fuel o.:j.l received meets the specified requirements. PSE&G's Quality Assurance department performs periodic au.di ts and surveillances on the Maplewood Lab to insure that they meet Salem QA requirements. After initial analysis the fuel oil is sampled in accordance with Tec_hnical Specification requirements as stated in the inspection report.

Currently the Salem UFSAR specifies that the fuel oil is safety related.. Although the fuel is not purchased as safety related, PSE&G uses the quality process to dedicate consumables as safety related. The QA Department performs audits of the testing laboratory to ensure that testing is- properly performed to ensure that the critical parameters of the fuel oil are acceptable. The FSAR will be modified to clarify this.

The dedication of commercial grade materials is governed under Nuclear Depar;tment Procedures: DE.AP-ZZ-0024, "Commercial Grade Dedication Program"; DE.TS-ZZ-5414, "Commercial Grade Evaluation", and DE.AP-ZZ-0034, "Commercial Upgrade Program".

The.procurement.process for ordering fuel oil will be changed, in that fuel oil will be designated as a non-safety related with QA provisions, folio item; thus, providing the QA department with means of tracking and auditing the process under the governing procedures. EOG lube oil is presently purchased in this manner.

Additional changes to procurement specifications and sampling are discussed in response to Concern 1 below.

NRC CONCERNS The subject inspection report identified various c0ncerns and requested that PSE&G identify any changes to procedures or hardware that it planned on making to improve the EDG reliability as a result of reviewing these concerns. The following provides a summary of the NRC concerns and PSE&G's response to each concern.

Concern 1 Inadequate EOG stored fuel sampling that would not adequately detect water/sludge build-up prior to pickup in the EDG fuel line.

Response

• Due to design restrictions, some of which are mentioned in the inspection report, sampling restrictions and engineering judgement, PSE&G committed to meeting only Position C.2.b of Regulatory Guide 1.137, with regard to fuel oil sampling. The sampling requirements of this Position are currently reflected in the testing specified in the Technical Specifications. PSE&G is

• • in the process of establishing additional requirements for the purchasing and receipt sampling of diesel fuel. These requirements will specify that the fuel will be ordered and tested. upon receipt to the critical parameters of ASTM D396 and D975 as modified by PSE&G requirements. (Any deviations to the ASTM requirements will be justified and documented in ah engineering evaluation. Table 1 provides a list of the expected criteria. Testing of stored fuel will also be performed to the criteria specified in Table 1. It is expected that these changes will result either in making Maplewood Lab Procedure CDP-7, Chemical/Environmental Division Procedure For Testing Diesel Fuel Hope Creek Generating Station, into a common Salem/Hope Creek procedure or that a Salem procedure will be developed closely resembling the Hope Creek procedure. These procurement and sampling changes will be incorporated into the program by January,.

1, 1990.

In addition to the above plans., the following actions have been or will be taken. Since the inspection period, PSE&G has taken samples from the sediment traps, which is representative of the bottom of each of the four 30,000 gallon Diesel Fuel Oil Storage Tanks. These samples, revealed no evidence of water or sludge in the oil. These samples have been submitted for bacterial analysis and the results are expected by October 2, 1989. The September samples will also include a sample analysis verification against the new criteria. PSE&G plans to sample the tank bottom yearly, via grab sampling in accordance with ASTM D270 requirements, to assure that the 92 day samples (off the present sample point) are representative of the actual tank contents.

Concern 2

'Inadequate or lack of use of biocides and antioxidants in the fuel oil storage tanks.

Response

As,mentioned above, bacterial samples have been taken and analysis results are expected soon. If ho bacterial problem is identified, bacterial sampling and testing will be performed on a semi-annual basis until a data base is e*stablished. The frequency of future samples will be re-evaluated based on the results obtained. The use of biocides and antioxidants will also be evaluated based on the results of the testing. The diesel manufacturer does not recommend the routine use of biocides or -

antioxidants and PSE&G concurs with this position.

• • Concern 3 Abnormal Operating Procedures provide inadequate guidance to the operators for local manual starting and operation of the EDG in the event of the loss of the remote/automatic features.

Response

The development of procedures for local manual starting and operation of the diesel generators is being reviewed. This review will assess the benefits to be gained in providing local, manual starting and operation of the diesels. This evaluation should be completed during the first quarter of 1990, and will provide the basis for future action in this area.

Concern 4 Lack of local indication of engine speed and procedures for use during manual operation of the engine governor speed control knob.

Response

PSE&G does plan to instail local engine speed indication at the EDG governor. However, this change has not been integrated into the living engineering plan. Procedures for manual operation are discussed in the response to Concern 3.

Concern 5 Lack of adequate protection and procedures to detect and protect wiring from mechanical damage.

Response

The identification of physical damage and improper material condition of equipment is the responsibility of the plant personnel. Recent efforts have been taken by plant and senior management to increase attention to detail efforts in the station. Recent meetings emphasizing attention to detail and increased standards have been held with the Salem employees.

Furthermore, a "Work Standards" handbook has been issued.to increase personnel awareness of these types of deficiencies.

For the specific case of the EDG, immediate repairs were initiated and the wiring connections corrected. The System Engineer performed a detailed walkdown of the EDGs with no other discrepancies identified.

Concern 6 Potential for loss of fluid for EDG fuel, jacket water, and lube oil due to line breakage.

Response

PSE&G does not plan to change the instrument tubing lines for fuel oil, lube oil or jacket water instrumentation. These lines are seismically qualified and have not demonstrated a susceptibility to breakage. The risk of line breakage is assessed under the single failure assumptions of the accident analysis, which considers the complete loss of a diesel generator.

Concern 7 Lack of adequate EDG alarm response procedures.

Response

PSE&G is currently undertaking a major review of the Procedures at Salem. This Procedure Upgrade Project (PUP) will include a complete review of the EDG alarm procedures from both a technical and human engineering standpoint. The review of these procedures will be conducted on a priority basis. The priority schedule is not yet finalized; however, it is expected that the review of the EDG alarm procedure will be completed during the first quarter of 1990.

TABLE 1 Specifidation for No. 2 Fuel Oil Characteristics Salem Generating Station Critical Parameter Criteria Test Flash Point, °F 130 min. ASTM D93 Pour Point, °F O' winter ASTM 02500

+10 summer Carbon Residue % wt .20 max. ASTM 0189 (10% Res.) or ASTM D524 Ash Weight, °F .01 max. ASTM 0482 Distillation Temp., °F 540 min. ASTM D86 (90% pt.) 640 max.

Sulfur, % wt .2 max. ASTM D1552 Gravity (API) 30 min. ASTM D88 Copper Strip Corro~ion No.

• 3 max. ASTM D130 Cetane No. (calculated)* 40 min. ASTM D976 Stability max. 2 mg./ioo ml. ASTM D2274 Heating Value min. 18190 Btu/lbm ASTM D240 max. 20000 Btu/lbm ASTM D2890 Water and Sediment .05% vol. max. ASTM Dl796 Viscosity (Kinematic) 1.9 CTS min. ASTM D445 4.1 CTS max.

OR (Saybolt @ 100°F) 33 SUS min.

40.4 SUS max.

NOTE 1: Exception is taken to cloud point testing due to indoor location of storage tanks and lack of temperature extremes because of indoor location. Testing for pour point is substituted as the refill lines and bulk storage are outdoor.

NOTE 2: Critical Parameters and Criteria per Technical Department Engineering Memo No.89-112.