ML20150C672

Special Rept:On 880205,nonvalid Failure of Train a Diesel Generator Occurred.Caused by Operator Error.Operator Counseled.Util Believes Occurrence Invalid Test Rather than Nonvalid Failure.W/Nrc Concurrence,Rept Will Be Withdrawn

ML20150C672
Person / Time
Site:	Vogtle
Issue date:	03/11/1988
From:	Gucwa L GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SL-4352, NUDOCS 8803210160
Download: ML20150C672 (5)

Text

.__ _ _ _ _ _ _ _ _ _ _ _ _ - -

r .

..- og g g c g nany ,

. Manta, Georgia 30308 Teitphone 404 526-6526 Maing Address Post OMee Box 4545 Manta Georg a 30302 Georgia Power L.T.Gucwa Ine southem ettrc system Manager Nuclear Safety and Lcensing -

SL-4352 0834m X7GJ17-V310 March 11, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 SPECIAL REPORT ON DIESEL GENERATOR NON-VALID FAILURE Gentlemen:

In accordance with Plant Vogtle Unit 1 Technical Specifications 4.8.1.1.3 and 6.8.2, Georgia Power Company (GPC) submits the enclosed special report ccncerning a "non-valid failure" of the Train "A" Diesel Generator which occurred on February 5,1988. A copy of this submittal is being provided to the NRC Region II office for review.

This "non-valid failure" of the Train "A" diesel generator is being reported consistent with NRC Region II's interpretation of NRC Regulatory Guide 1.108; however, it is GPC's belief that the occurrence of this event on February 5, 1988 is another example of an invalid test rather than a non-valid failure. GPC's interpretation of the reporting requirements of NRC Regulatory Guide 1.108 is discussed in our letter SL-4090 dated March 11, 1988 which responds to NRC Violation 50-424/87-57-02. Should the NRC ultimately concur with GPC's interpretation of NRC Regulatory Guide 1.108 after reviewing our discussion in our letter SL-4090, the enclosed special report will be withdrawn by GPC.

The delay in submittal of the special report was discussed with Mr. H. V. Sinkule of the NRC Region II office on March 7,1988.

Should there be any questions in this regard, please contact this office at any time.

Sincerely, Nh L. T. Gucwa pF..

JAE/PAH/1m I 8803210160 880311 PDR ADOCK 05000424 S DCD

c:

,n .

Georgia Power A U.:S. Nuclear Regulatory Commission March 11, 1988 Page Two

Enclosure:

.Special Report on Diesel Generator Non-Valid Failt.re c: Georaia Power Comoany Mr. P. D. Rice Mr. G. Bockhold, Jr.

GO-NORMS U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)

Mr. J. F. Pogge, Senior Resident Inspector-0perations, Vogtle 0834m 700775

GeorgiaPower d ENCLOSURE PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 SPECIAL REPORT ON DIESEL GENERATOR NON-VALID FAILURE The following information regarding a non-valid failure of the Vogtle Unit 1 Train "A" Diesel Generator (D/G) during monthly surveillance testing is hereby submitted to the NRC consistent with NRC Regulatory Guide 1.108, Section C.3.b.

On February 5,1988, the monthly surveillance test for the Train "A" D/G was being run (start attempt no. 1-88.-0073) when the operator manually stopped the engine (before loading to at least 501. continuous rating) because of the low lube oil pressure. The low lube oil pressure was caused by the pre-lube bypass valve not being closed expeditiously by the operator in the D/G room following diesel start. Failure to close the pre-lube bypass valve in an expeditious manner following diesel start resulted from an operator error in that the operator failed to follow procedures. The responsible operator was counseled about procedural compliance at the time the error occurred. The subject diesel was not declared inoperable because the diesel remained capable of automatically starting upon receipt of an emergency start signal. Additionally, start attempt 1-88-0074, which was performed approximately forty-five minutes later, demonstrated the operability of the diesel generator.

The Train "A" D/G start attempt no. 1-88-0073 is considered to be a non-valid failure in accordance with the NRC Region II's interpretation of Regulatory Guide C.2.e.2 and C.2.e.4 since an operator error occurred and since a successful start was intentionally terminated without loading, as defined in C.2.e.3. NRC Regulatory Guide 1.108, C.2.e states:

"e. Valid tests and failures (under Regulatory Positions C.2.a.(9) and C.2.d) should be based on the following criteria:

0834m E-1 03/11/88 SL-4352 700775 ._ _

Georgia Power A ENCLOSURE (Continued)

SPECIAL REPORT ON DIESEL GENERATOR HDN-VALID FAILURE (1) All start attempts (automatic, including those from bona fide signals, or manual) that result in a failure to start, except as noted in (2) below, should be considered valid tests and failures.

(2) Unsuccessful start and load attempts that can definitely be attributed to operating error, to spurious operation of a trip that is bypassed in the emergency operating mode, to malfunction of equipment that is not operative in the emergency operating mode (e.g., synchronizing circuitry) or is not part of the defined diesel generator unit design should not be considered valid tests or failures.

(3) Successful starts, including those initiated by bona fide signals, followed by successful loading (sequential or manual) to at least 50% of continuous rating and continued operation for at least one hour should be considered valid successful tests.

(4) Successful starts that are terminated intentionally without loading, as defined in (3) above, should not be considered valid tests or failures."

While the "non-valid failure" of the Train "A" Diesel Generator is being reported consistent with the NRC's interpretation of NRC Regulatory Guide 1.108, it is Georgia Power Company's (GPC) belief that the occurrence on February 5, 1988, is another example of an invalid test rather than a non-valid failure based on GPC's interpretation of the subject Regulatory Guide. GPC's interpretation of the reporting requirements of NRC Regulatory Guide 1.108 is discussed in our letter SL-4090 dated March 11, 1988 which responds to NRC Violation 50-424/87-57-02. Should the NRC ultimately concur with GPC's interpretation of NRC Regulatory Guide 1.108 after reviewing our discussion in our letter SL-4090, this special report will be withdrawn by GPC.

0834m E-2 05/11/88 SL-4352 mm

o. ..:

,w e~

GeorgiaPower A ENCLOSURE (Continued SPECIAL REPORT ON DIESEL GENERATOR NON-VALID FAILURE Table 4.8-1 in the Vogtle Unit 1 Technical Specifications reflects the Diesel Generator Test Schedule. The test schedule is as follows:

Number of Failures in Number of Failures Test Last 20 Valid Tests in Last 100 Valid Tests Frecuency 41 44 Once per 31 days 22 15 Once per 7 days This is a non-valid failure based on NRC Region II's current interpretation of NRC Regulatory Guide 1.108; therefore, the schedule is not affected. There have been 2 valid failures in the last 100 valid tests and 1 valid failure in the last 20 valid tests. The test frequency is once per 31 days as defined by the Technical Specifications.

r i

?

0834m E-3 03/11/88 i SL-4352 70077$