ML20127G592

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Forwards Point by Point Response to Five Recommendations Identified in IE Circular 80-05.Based on Response IE Circular Can Be Closed
ML20127G592
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/27/1984
From: Wynne J
LONG ISLAND LIGHTING CO.
To: Eselgroth P
NRC
Shared Package
ML20127B461 List:
References
FOIA-85-190 IEC-80-05, IEC-80-5, NUDOCS 8506250490
Download: ML20127G592 (1)


Text

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o November 27, 1984 TO:

P. Eselgroth Senior Resident Inspector

SUBJECT:

IE Circular 80-05 Attached, please find a point by point response to the five recommendations identified in IE Circular 80-05.

Based on the response to the five recommendations, Operational Compliance feels that IE Circular 80-05 can be closed.

Please contact W. Burnett (Ext. 3416) or myself regarding questions concerning the response to the Circular.

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Operational %'ompliance Engineer Shoreham Nucicar Power Station JGW/mm SR2-NF F

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fir. Andrew W. Wofford Vice President

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The enclosed IE Circular tio. 80-05, "Energency Diesel-Generator Lucricating 011 Addition and Onsite Supply," is forwarded to you for information.

No written response is required.

If you desire additional informatior. regarding this catter, please contact this offico.

Sincerely, hdff__1 LL2 ban Boyce H. Grier

' Director Enc 1csures:

1.

IE Circular lio. 80 SHOREHAM' 2.

List of Recently Issued Circulars DOCUMENT C0tlTACT:

D. L. Canhton (215-337'5254)

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J. P. Ilovarro, Project Iianager Edward it. Barrett, Esquire Edward J. Walsh, Esquire T. F. Gerecke, Ilanager, Engineering QA Department 1p.

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.s ENCLOSURE 1 SSINS No.: 6830 Accession No.:

UNITED STATES 7912190691 NUCLEAR REGULATORY CC"J4ISSION OFFICE OF INSPECTION AND ENFORCEl4ENT WASilINGTON, D.C.

20555 IE circular No. 80-05 Date:

April 1, 1980 Page 1 of 3 EMERGENCY DIESEL-GENERATOR LUBRICATING OIL ADDITION AND ONSITE SUPPLY Description of Circumstances:

On January 17, 1980, the Kewaunee Nuclear Power Plant experienced a partial loss of offsite power which resulted in a turbine trip, reactor trip, and one emergency diesel engine driven generator (diesel-generator or D/G) supplying power.to one engineered safeguards bus.

Offsite power continued to supply the other engineered safeguards bus.

During the day before, on 1-16-80, this diesel generator had successfully completed a 24-hour loaded test run but had a low lube oil alarra. condition with oil level 1/2-inch low.

The D/G was fully operational in this condition.

Before oil could be added on 1/17/80, the D/G was required for emergency power following the failure of the reserve auxiliary transformer.

~The normal oil fill location could not be used while the D/G was cperating.

The D/G Technical 11anual (Til) indicated that oil could be added with the engine running, but did nnt describe the method to be used.

Lube oil was added by pumping into the' crigine through a pipe that was assumed to be a lube oil line; this line was color coded in the T!4 and painted with the lube oil system color code.

Three barrels of oil were added via this line while the D/G was operating.

After transferring the emergency bus to off-site power through the tertiary auxiliary transformer the D/G was shut down.

With the D/G shut down two more barrels of oil were added through this line without increasing the sump level.

Then two more barrels of oil were added through a different addition point and the level was restored to normal.

The following day a factory representative determined that the first five barrels of oil had been added to the engine air box through a mismarked (should have been color coded as an air line) drain connection.

Four and a half barrels of oil were drained out af ter which the diesel-generator was satis-factorily test operated.

It is believed that the diesel engine could have been damaged had an en0ine start been attempted while the five barrels of oil were in the air box.

Further, it is noted that procedures for adding oil to the operating dicsci engine were not available and that the personnel perform-ing the addition were not familiar with, nor trained on, how to add oil to a running engine or how to verify that oil had been properly added.

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i s IE Circular No. 80-05 Date:

April 1, 1980 Page 3 of 3 4.

Verify that appropriate procedures or instructions exist, and personnel are trained, on the proper addition of lube oil and the performance of maintenance during operation of other similar vital equipment.

i 5.

Determine the lube oil usage rate for each diesel engine under full load conditions including the rates considered to be excessive.

Provide adequate inventory of lubricating oil of the proper grade consistent with the highest usage emergency diesel generator (s) operating for the time period specified in the plant Technical Specifications for fuel cil supply.

When lube oil consumption rates become excessive, provisions should be included for overhaul of the diesel engine.

All holders of construction permits for nuclear power reactor facilities should be aware of the. potential problems identified above and initiate appro-priate procedures prior to initial fuel loading.

No written response to this Circular is required.

If you require additional information regarding these matters, contact the Director of the appropriate NRC Regional Office.

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7 IE Circular tio. 80-05 l

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April 1,1980 i

Page 2 of 3 This event brought to light an additional problem which may be generic.

During the previous day's test run of the diesel generator lube oil consump-tion was approximately 3 gal /hr.

During the loss of power event, the licensee had three barrels (165 gallons) of lube oil availabic ensite.

The licensee's

  • Technical Specifications require a seven day supply of fuel oil for one diesel gen-erator be availabic onsite.

To meet the intent of the Technical Specifications, a seven day supply of lube oil should also be availabic onsite.

The diesel engines are model 999-20 manufactured by the Electro-Motive Division of General llotors Corporation.

These diesel engines use a 2-stroke cycle and lube oil consumption is normally higher than for the 4-stroke cycle diesel engines.

Vendor representatives and liRC consultants indicate that lube oil consumption rate varies with' engine condition and load.

Further, the 3 Cal /hr consumption rate is considered to b'e in the normal range.

Recommended Action for Licensee's Consideration:

All holders of operating licenses for nuclear power reactor facilities should be aware of the potential problems described above.

Because of the generic nature of these matters, it is recommended that the considerations identified above be reviewed at your facility in the following respects:

'1.

Verify the existence and adequacy of procedures or instructions for adding lubricating oil to safety related equip..cnt.

This should include the following:

a)

Whether or not, how and where lube oil can be added while the equipment !

l 1s in operation, b)

Particular assurance that the wrong kind of oil is not inadvertently added to the lubricating oil system, and c)

That the expected rise in level occurs for each unit of lube oil added.

l These operating procedures or instructions should be available locally in the area of the affected equipment.

t 2.

Verify that personnel are trained in such approved procedures and demon-strate an ability for using these procedures to add oil while the D/G is operating and that they understand how to verify that the proper amount l

of oil has been added, j

3.

Verify that the color coded, or otherwise marked, lines associated with the diesel generator are correct and that the line or point for adding lobe oil has been cicarly identified.

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' 'k RECOMMENDATION #1:

Verify the existence and adequacy of procedures or instructions for adding lubricating oil {6.garety1relEed7quig?'] This should include the,following.

a) Whether or not, how and H3,twhile the equipment is in operation, j

b)

Particular assurance that the wrong gipargr";D]L1} s not inadvertently added to the lubricating oil system, and c) That the TJGJC.t*h jy,E.60 Ad4TO(ireach'nitoflubeoil (/

u added.

These operating Airoceduresgor instructions should be Na3,f '.thiE sffpctgaie,quw-jntj

RESPONSE

SP 31.019.01 (Lubrication Control) establis,hes the requirements for storage, control, and issue / usage of all greases and oils used at SNPS.

The Preventive Maintenance Program (SP12.015.01) scheduled activity worksheets (SAWS) specifically identify the type of lubrication required for equipment in the plant. The two programs jointly satisfy all concerns raised in Recommendation 81.

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RECOMMENDnTIOA #h Verify that pet onnel are train <.:d in such approved procedures at deconstratt.

an ability for using these procedures to add cil while the D/G is operating to ve:ify that the proper amount of cil has been and that they understand ti added.

RESPONSE

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/1 Equipment Operator Qual. Guide #19 (EQG-19) has been issued to insure that persmrel (E0's) additcg lubricants to PJant equipment are properly trained.

Equipme).t Operators have completed Cectibn I (knowledge requirements) of EQG-19 and training on Section II (practical requiremente) will continue during the normal.craining rotat. ion.

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RECOff4ENDATION #3:

Verify that the color coded, herwise marked,)1ines associated with the diesel-generator are correct and that the line or point for adding lube oil has been clearly identified.

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RESPONSE

011/ lubrication lines at SNPS are not color coded; howeser, all oil addition points are clearly marked. Specifically, the TDI oil addition point is, clearly marked on the machines and identified in ARP 6009 (lube oil low level).

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RECO!NENDATION #4 Verify that appropriate procedures or instructions exist,and personnel are trained, on the proper addition of lube oil and the performance of m'aintenance during operation of other similar vital equipment.

RESPONSE

Tne response to Recousnendations #1 and #2 adequately address the concerns of the above Recommendation.

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Recommendation #5:

Determine the lube oil usage rate for each diesel engine under full load conditions including the rates considered to be excessive.' Provide adequate inventory of lubricating oil of the proper grade consistent with the highest usage emergency diesel-generator (s) operating for the time period specified in the plant Technical Specificat_ ions for fuel oil supply. When lube 611 consumption rates become excessive, provisions should be included for overhaul of the diesel engine [

RESPONSE

  • p The following preoperational test results establish the lube oil consumption rates for the TDI diesels:

EDG 101 - PT307.005A - 328 Gal /7 days PT307.003-2A - 210 Gal /7 days EDG 102 - PT307.005B - 392 Gal /7 days PT307.003-2B - 420 Gal /7 days EDG 103 - PT307.005C - 168 Gal /7 days PT307.003-2C - Not Performed Based on the PT307.003-2B results (highest EDG L.O. consumption) lube oil consumption was determined to be 420 gal /7 days. Assuming that the oil sump level is maintained at the low level alarm point as a minimum, the oil sump provides a consumable reservoir of 108 Gal (difference between low level and minimum level per Delaval = 6" x 18 gal /in= 108 gal).

Subtracting the 108 gal, from the required 420 gal. indicates that 312 gal of oil must be available to support a 7 day run. Thus, a minimum of 936 gal. of oil (312 gal / engine) must be maintained on site for the three TDI Diesels. To insure 936 gal of oil are available, 20 drums (20 drums x 55 gal / drum = 1100 gal) of oil have been set aside in the lube oil storage area per the attached SAWS.

The !!aintenance Department will monitor EDG lube oil consumption rates and in consultation with NED and Transamerica Delaval, implement corrective actions as required.

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