ML20128F710
| ML20128F710 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/1993 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Grimes B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9302120004 | |
| Download: ML20128F710 (6) | |
Text
.
'J AN 191993 i
HEMORANDUM FOR:
Brian K. Griines, Director Division of Operating Reactor Support, Office of Nuclear Reactor Regulation FROM:
Ellis W. Merschoff, Director Division of Reactor Projects
SUBJECT:
Pk0 POSED Mif0RMAT10N NOTICE: POTENTIAL PROBLEMS Wi1H THE USE OF COMMERCIAL GRADE LUBRICATING OILS AND GREASES IN SAFE 1Y RELATED APPLICATIONS i
A recent event occurred at a Region 11 facility involving potential problems with the use of commercial grade lubricating oils and greases in safety related applications. We believe an Information Notice is warranted on the subject. Accordingly, enclosed for your consideration is a proposed draft.
We understand that requirements in the subject area are under review by Vendor Inspection Branch, Division of Reactor Inspection and Licensee Performance, NRR.
I expect this draft information notice may be useful as_part of this review.
j If we can be of further assistance in this matter, please contact Todd Cooper at (704) 875-1681.
1 hb
&<, u,J.Aty )1n )$ww Ellis W. Herschoff l
Enclosure:
Proposed Information Notice cc w/ enc 1:
S. Ebneter i
L. Reyes E. Herschoff l
A. Gibson.
l J. Johnson A. Herdt C. Julian M. Shymlock l
A. Belisle l
S. Ninh W. Miller bec w/ enc 1:
Document Control Desk
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i HEMORANDUM FOR:
Brian K. Grimes, Director
/
Division of Operating Reactor Support, Offico of Nuclear Reactor Regulation TROM:
Ellis W. Herschoff, Director Division of Reactor Projects
SUBJECT:
PROPOSED INFORMATION N011CE: F9 ENTIAL PROBLEMS Wlill THE USE Of COMMERCIAL GRADE LUBRICA if4G OILS AND GREASES IN SAFE 1Y RELATED APPLICATIONS A recent event occurred at a Region 4 facility involving potential problems with the use of commercial grade i ricating oils and greases in safety related applications-We bolicy an Information Notice is warranted on the AccordkJ f, W osed for your consideration is a proposed draft.
1 subject.
We understand that. % t y nts in the subject area are under review by Vendor Inspection Branch, unpA of Reactor inspection and Licensee Performance, NRR.
/,-
If we can be nf further assistance in this matter, please centact lodd Cooper at (704) 875-1681.
Ellis W. Merschoff Enclosure; Proposed Information Notice bcc w/ encl:
S. Ebneter L. Reyes E. Merschoff A. Gibson J. Johnson
- t. Herdt C. Julian M. Shymlock A. Belisle S. Ninh W. Miller Decument Control Desk 11 R1 Rll 7
SN nb OlBelisle AHerdt 12/7/92 12/~\\/92 12/A/92
EtiCLOSURE UNITED STATES liUCLEAR REGULATORY COMMISS10fl OfflCE Of fiUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555
, 1992 fiRC INFORMATION 140TICE 92-XX:
THE USE OF COMMERCIAL GRADE LUBRICAllflG OILS AND GREASES If4 SATETY RELATED APPLICAT10f45.
Addressees All holdr.rs of operating licenses or construction permits for nuclear power reactors.
Purposq The U.S. tiuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees to the potential for introducing inappropriate lubricating oils and greases into safety related components.
it is expected that recipients will review the information for applicability to ' heir facilities and consider actions, as appropriate, to avoid similar 1roblems.
However,suggestionscontainedinthisinformationnoticearenotiRC requirementst therefore, no specific action or written response is required.
Description of Circumstances On June 24, 1992, operations personnel at the Farley Nuclear Plant, noted that the oil in the 1A Component Cooling Water motor outboard and inboard bearings had become discolored.
The oil was changed and samples were taken, as aart of the corrective actions.
Results of the sample analysis revealed that tie oil in the inboard bearing was not of the viscosity specified in that application (Texaco Regal R & 0 68 instead of Regal R & 0 32).
On June 28, 1992, the oil in the motor bearings was again noted to be discolored.
The oil was again changed and samples were obtained.
The oil in both the inboard and the outboard bearings was found to be Regal R & 0 68 instead of Regal R & 0 32.
On July 24, 1992, the oil in the 2B Component Cooling Water pump inboard bearing was reported to be discolored.
The oil was changed and a sample taken. The pump was run for fifty hours and sampled again.
This sample indicated that the wrong type of oil was in the bearing.
As a result of the incidents involving the use of the wrong oil, the licensee decided to sample the oil in all safety related equipment. Of the 33 samples taken, 18 revealed the presence of
IN 92 XX
, 1992 Page 2 of 4 the wrong lubricating oil, in some cases, the wrong oil was clearly present, in others, the sample indicated that a mixture of the correct oil and the incorrect oil was present. Wherever these situations were detected, the oil was changed.
Texaco Regal R & 0 68 oil was used in applications where R & O 32 oil was specified because of a mislabeled drum being supplied to the licensee from the vendor.
No sampling was performed to verify that the oil received was what was ordered.
The licensee contacted a consultant to evaluate the use of the R & 0 68 oil instead of the R & 0 32 oil. The cunsultant stated that no serious problem-was likely to occur, since the only differences in the two oils was in the viscosity. All of the additives were identical.
However, the consultant also stated that the more viscous oil would generate more heat from higher friction.
This might result in increased oxidation of the oil, resulting in shorter oil lifetime.
The higher viscosity might also cause bearing distress, which could cause increased wear on the bearing.
Djj_gussion The use of commercial grade items in a safety related application is allowable, provided certain regulatory requirements are satisfied.
10 CFR 21.3(a)(1) defines a basic component as a plant structure, system, component, or part necessary to assure (i) the_ integrity of the reactor coolant pressure boundary, (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to 10 CFR 100 referenced values.
10 CFR 21.3(a)(3) states that in all cases, basic component" includes-design, inspection, testing, or consulting services important to safety that:are associated with the component hardware, whether these services are performed by the component suppliers or others.
L 10 CFR 21.3(a)(4) discusses the use of commercial grade ' items.
A' commercial l
grade item means an item that is -(l) not subject to design or. specification -
L requirements that are unique to facilities or licensed activities, (2) used in L
applications other than activities or facilities licansed by parts of 10 CFR, and (3) to be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer!s published product description-(for example, a catalog),
o il
IN 92 XX
, 1992 Page 3 of 4 10 CfR 21.3(a)(4) also states that a commercial grade item is not part of a basic component until af ter dedication.
Dedication of a commercial grade item occurs after receipt when that item is designated for use as a basic component.
10 CfR 50, Appendix B, Criteria 111 states, in part, that measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety related functions of the structures, systems, and components.
For safety related procured items, 10 CFR 50. Appendix B, Criterion IV, Procurement Document Control, requires that measures be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors.
10 CFR 50, Appendix B, Criterion Vll, Control of Purchased Material, Equipment, and Services, states that measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.
These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor ur subcontractor source, and examination of produr.ts upon delivery.
Documentary evidence that material and equipment conform to the procurement requirements shall be available at the plant site prior to installation or use of such material and equipment.
This documentary evidence shall be retained at the nuclear power plant and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased material and equipment.
For use of a commercial grade item in a safety related function, the above references require that the item be assured to fulfill all of the safety related requirements that an item procured as safety related must meet. The tests to assurt-this level of quality can be performed either by the manufacturer /:.upplier, the purchaser, or other qualified personnel. This is part of the dedication program discussed in 10 CFR 21.
Many utilities are using EPRI document', NP-5652, Guideline for the Utilization of Commercial Grade items in Nuclear Safety Related Applications, as the basis for the dedication process.
According to this source, the utilization of commercial grade items intended for safety related applications involves two distinct processes:
(1)
A technical evaluation to assure that requirements for an acceptable item are specified in the procurement document.
(2)
Acceptance methods to reasonably assure the item received is the item which was specified.
I IN 92 XX
, 1992 Page 4 of 4 Further clarification is offered in the document, To utilize a commercial grade item in a safety related application, reasonable actions must be taken to assure the item is appropriate for its intended function.
The technical evaluation in combination with an appropriate acceptance process provides the assurance that the specified item is adequate to meet 10 CFR 50, Appendix B requirements.
Lubricating oils and greases are commonly procured as commercial grade material.
To be used in an essential application, such as bearing lubrication, in a safety related piece of equipment, the oils and greases should La considered a basic component, since without it, the equipment could not perform its intended function.
Therefore, a dedication program for oils and greases procured commercial grade is appropriate.
Brian K. Grimes, Director Division of Operating Reactor Support, Office of Nuclear Reactor Regulation Technical contacts:
George Maxwell, Ril (205) 899-3386 Michael Morgan, Ril (205) B99-3387 Todd A. Cooper, Ril (704) 875-1681
Attachment:
List of Recently Issued Information Notices
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