ML20207L029
| ML20207L029 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/05/1988 |
| From: | Tomlinson E Office of Nuclear Reactor Regulation |
| To: | Calvo J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8810170146 | |
| Download: ML20207L029 (5) | |
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October 5,1988 PEM0RANDUM FOR:
Jose A. Calvo. Director Project Directorate - IV Division of Reactor Projects - III, IV, Y and Special Projects FROM:
E. B. Tomlinson, Project Engineer Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects
SUBJECT:
TRIP REPORT - TRAVEL TO COOPER-BLSSEMER PLANT TO ATTEND DIESEL GENERATOR USERS GROUP MEETING From September 71 to Septenber 23, 1988 I attended a meeting of representa-tives of licensees which have emergenc Cooper-Bessemer Reciprocating (Cooper)y diesel generator (E00) sets supplied by and which utilire the KSV diesel engine.
The meeting was held at the Cooper facility in Grove City, PA.
The meeting, while structured, was nonetheless infortral because a "users group" has not yet been formally established. The primary purpose of this meeting was to develop a framework for establishing a formal organization which would represent the collective interests of licensees that have Cooper ESV diesel engines. To demonstrate the need for, and the advantages of a users group, there was an exchange of technical inforration and discussions of connon problems associated with KSV engines. The following is a discussion of the salient issues covered during the meeting. As applicable, a recomended staff action follows each discussion.
QualifiedReplacementParts The issue of qualified replacement parts is a tratter of concern to all the licensees represented at the treeting as well as to Cooper.
Simply stated, there is a growing problem with obtaining qualified replacement parts for EDGs. This is due to the fact that many vendors that supply parts to Cooper have eliminated their nuclear programs and will no longer provide parts in accordance with 10 CFR Part 50, Appendix B.
This, in turn, affects specific criteria such as environtrental qualification'(IEEE 323) and seismic qualifi-
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cation (IEEE344). Without a nuclear program, the equiptrent vendors cannot provide proper documentation to establish proper equiptrent qualification.
Based on discussions held during the meeting on this subject, it appears that each utility is taking a different aoproach to resolving this issue.
CONTACT:
E. Tomlinscn, PDIV/DRSP x?3024 0
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Jose A. Calvo
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These approaches vary from 1) the licensee establishing the qualification fcr a part, to ?) obtaining commercial parts and dedicating them for EDGs in accordance with 10 CFR Part P1, to 3) obtaining comnercial parts and disregarding qualification requirements.
In surrrary, there is a great deal of confusion among licensees as to what requirements are applicable to replacement parts and how to conform to these requirements.
The net effect of this confusion is a definite potential for serious enforcement actions as a consequence for licensees using improperly qualified replacement parts.
Cooper has proposed and will sponsor additional metings to establish what EDG components can be classified as concercial items, and what documentation, if any, would be required in support of this classification, with a view towards establishing a uniform approach to a solution. The staff should be an active participant in these meetings.
ASMESection1,1,1 The staff position on nacha.11 cal components in fluid systems on ECGS is that they be in complitnce with ASME Section III, Class 3 requirements.
As dis-cussed above, many venders that supply componer.ts to Cooper have not retained their "N" starp and can no longer provide components with the proper certifi-cation. Consequently, when such components are required, licensees are faced with the prospect of having to utilize components lacking proper certification with the attended potential for enforcement action.
The demand for mechanical replacement conponents is substantially less than the demand for electrical conponents. However, th basic problems are the safe, and action Eust be taken in orcer to reach a solution.
The subject of ASME Section III classification will also be discussed in the neeting proposed by Cooper on qualification. The staff should be an active participant in all meetings wherein tne subjects of component qualification /
classification are discussed, i
EDG Maintenance and Inspectign e
Representatives of Cooper and Louisiana Power and Light Co. (LP&L) (Waterford 3) gave presentations on predictive maintenance for EDGs as opposed to preventive maintenance. The major difference between the two is that preventive maintenance involves component overhaul / replacement at a
- predetermined frequency, while a predictive maintenance program only requires component overhaul / replacement based on EDG operating parameters that have been monitored and trended over tire.
Both the Cooper and LP&L presentations emphasized the use of an engine analyzer in order to obtain EDG perfortrance data for intrediate evaluation and for trending purposes. The engine analyzer; discussed has the capability of nonitoring and recor ding such critical e'.gine operating parameters as peak pressures, ignition timing, cylinder horsepower, valve timing, and vibration.
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Jose A. Calvo The Cooper preentation enphasi:ed the use of an analyzer as a treans of ensuring EDG reliability and for early detection of indications that could lead to catastrophic failures. The LP&L presentation included essentially the sarre points as the Cooper presentation, but went on to include the function an analyzer could play in tredifying periodic inspection requirements. To illustrate this, the LPAL representative referred to the recent five (5) year EDG inspection at Waterford for which the vendor recommended engine disasserrbly was deleted.
This deviation from vendor reconcendations was found acceptable by the staff because the LPal predictive traintenance program (which uses an engine analyzer) provided more information on engine condition than could be obtained through disassenbly and visual inspection, all without the very real potential for improper reassembly of the engine. The LP&L program also includes vibration monitoring, lube oil analysis, a trending of all operating paraneters.
The staff should encourage the implenentation of predictive maintenance prcgrans as discussed above. When properly irrplemented, such a program will provide the licensees with accurate and more extensive data regarding EDG condition, and should result in irrproved EDG reliability. To accortplish this, the staff should adopt the position that vendor reconmended inspection requirenents for disassembly (which are part of the licensing basis for nost plants) can be waived provided an acceptable predictive maintenance program has been irrplerrented. The progran,in place at Waterford 3 has been reviewed and found acceptable by the staff, and could serve as a model.
EngineSpgat,ing_ Ting There is a consensus that EDGs do not see enough operating tirre at load.
Cooper is of the opinion that their KSV engines do not reach stable operating conditions ur til they have operated in excess of one (1) bour and possibly as truch as two (2) hours. Operation at load for greater periods of time (Cooper Station routinely operates its EDGs for four hours at a tirre) would be beneficial because it vould reduce the potential for engine fouling and attendant deterioration, and would provide mere and better data en engine operating pararreters for trending and subsequent evaluation of engine condition. The not result of increased operating tirre would be an improvement in overall EDG reliability. On the negative side, however, there is the staff concern regarding exposing EDGs to potential grid instability for prolongad periods of tine.
Increasing the arrount of run tirre of EDGs on 'a rronthly basis from the commonly accepted one hour to as truch as four hours would not impact the long term life of these machires.
In the forty year design life of a plant, this would arrount less than 4,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation. This is not a significant arrount of time when viewed in light of the 75,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> design life for the Cooper KSV engines. Moreover, the additional data that would be available for trending and evaluation would provide for a better detertnination of overall engine condition and reliability, and would more than offset any increase in wear.
Jose A. Calvo.
Therefore, the staff should review its position on EDG operating time with a view towards increasing the recomended operating time at load. This will involve evaluating the added risk of operating for longer periods of time in parallel with the grid against the benefits that can be obtained through longer EDG operation.
AgastasRelaysandBendiMuelInjectors There have been problems with Agastat relays and Bendix fuel injector nozzles at Palo Verde and South Texas, respectively. These problems have been documented and are well known to the staff.
Recomendations for follow-up on these issues have been made in various inspection reports. To date, however, no follow-up Ms occurred.
The staff should conduct an at.dit of the Bendix Corporation to ensure that
- 1) the root cause of cracked fuel injection nonles has been accurately identified, 2) that all nozzles affected by the root cause have beer. traced, and 3) that all affected licensees have been notified of the potential problem and the solution to same.
The staff should review the ANPP solution to the problems of Agastas relays in the E00 governor centrol circuits for acceptability and potential appli-cability to other Cooper supplied EDGs at other plants.
Overall, the meeting was both interesting and informative.
It is my opinion that the licensees and the staff would both benefit from establishing a formal users group, and the staff should encourage its formation.
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/j,_g pret E. B. Tomlinson, Project Engineer Project Directorate - IV Division of Reactor Reactors - III, IV, V and Special Projects cc:
D. Crutchfield C. Holahan B. Grimes L. Rubenstein W. Brach i
Jose A. Calvo 4-Therefore, the staff should review its position cn EDG opereting time with a view towards increasing the recorrended operating tirre at load. This will involve evaluating the added risk of operating for longer reriods of tirre in parallel with the grid against the benefits that can be obtained through longer EDG operation.
Agastas Relays _and_Bendix Fugl_ Injectors There have been prablems with Agastat relays and Bendix fuel injector nozzles at Palo Verde and South Texas, respectively.
These problems have been docwented and are well known to the staff.
Reconnendations for follow-up on these issues have been trade in various inspection reports.
To date, however, no follow-up has occurred.
The staff should conduct an audit of the Bendix Corporation to ensure that
- 1) the root cause of cracked fuel injection no771es has been accurately identified, ?) that all nozzles affected by the root cause have been traced, and 3) that all affected licensees have been notified of the potential problem and the solution to sarre The staff should review the ANPP solution to the problems of Agastas relays in the EDG governor control circuits for acceptability and potential appli-cability to other Cooper supplied EDGs at other plants.
Overall, the neeting was toth interesting and inforn'ative.
It is rny opinion that the licensees and the staff would both benefit frcni establishing a fonval users group, and the stuff should encourage its formation.
/s/
E. B. Tcmlinson, Project Engineer Project Directorate - IV Divisien of Reactor Reactors - 111 IV, V and Special Projects cc:
D. Crutchfield C. Holahan P. Grines L. Pubenstein W. Brach DISTRIBil110N Docket F W NPC PDR local PDR PD4 Reading E. Tc.mlinson CGC-Rockville E. Jordan B. Grirr(s ACRS (10)
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