05000344/LER-1992-010, Suppls 900706 Response to GL 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Failure Position of All safety-related Active Valves Tested for in IST Program.Design Defect Reported in LER 92-10

Suppls 900706 Response to GL 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Failure Position of All safety-related Active Valves Tested for in IST Program.Design Defect Reported in LER 92-10

ML20127P151
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/25/1993
From:	Cross J, Robinson W PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, NUDOCS 9302010196
Download: ML20127P151 (2)

LER-2092-010, Suppls 900706 Response to GL 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Failure Position of All safety-related Active Valves Tested for in IST Program.Design Defect Reported in LER 92-10

Event date:
Report date:
3442092010R00 - NRC Website

text

l n ,p; m e m M le Portland General Electric Company Il kJ -

James E. Cross Vice President and Chief Nuclear Officer January 25, 1993 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555

Dear Sir:

Nuclear Regulatory Commission (NRC)

Generic Letter 88-14, " Instrument Air Supply System Problems _Affac. ting _ Safety-Related Equipment" The purpose of this letter is to provide additional information on Portland General Electric Company's (PGE's) response to NRC Generic Letter 88-14. On July 6, 1990 PGE stated that the requirements of the Generic Letter had been implemented. A PGE Quality Assurance Audit was performed on the Instrument and Service Air System to verify PCE commitments made in response to Generic Letter 88-14. This audit did not reveal items of noncompliance with the Generic Letter; however, three items were determined to require clarification of PGE responses, item _1 Generic Letter 88-14 Item 1 required that actual air quality be consistent with the manufacturer's recommendation for individual components served.

The PGE response to NRC Generic Letter 88-14 dated August 31, 1989 states, in part, that maintenance test procedures for air quality shall ensure adherence to the requirement of American National Standards Institute (ANSI) S7.3-1975, " Quality Standards for Instrument Air". This ANSI requirement specifies that particulate size shall not be greater than 3 microns for the instrument air systems. The audit revealed that PGE's procedures specified an acceptance criteria of 5 microns which is consistent with present system design. The 5 microns acceptance criteria met the requirements of Generi. Letter 88-14. The acceptance criteria has been revised to 3 microns as committed.

Item _2 Generic Letter 88-14. Item 3 required a verification that the design of the entire instrument air system, including air or other pneumatic accumulators, is in accordance with its intended fun < tion. An analysis of the instrument air system was performed. The PGE response to NRC Generic Letter 88-14 dated August 31, 1989 states, in part, that a design review included a-y 290080 h g 96 CK930125 h' p O 05000344 121 SW Salmon Street, Portland, OR 97204 PDR 503/464-8897

Document Control Desk January 25, 1993 P o gt_2 __ .

case-by-case analysis of the incidents in NUREG-1275, Volume 2. The case-by-case study was performed for the instrument air system cases contained in the body of NUREG-1275, Volume 2, but not for the cases of foreign reactor experience or the additional cases provided in Attachment 2 of NUREG-1275, Voltune 2 as may have been indicated by PGE's response.

R em_3 PGE's response to Generic Letter 88-14, Item 3 stated, in part, that

" Confirmation of valve failure positions by testing was accomplished in two phases. The first phase concisted of reviewing the existing Inservice _

Testing (IST) Program and Maintenance Procedures to ensure that all safety-related valves are tested. The failure position of all safety-related active valves is tested for in the IST Program. All passive valves, as defined in the Quality-helated Classification Report, or valves that have a failure position which is the same as their normal position, are tested in Reference 4 (Reference 4 is MP 12-4]." Although the failure position of air-operated safety-related valves that have a required failure position had been tested, a few valves had been tested by means other than -

the IST Program or the specific Maintenance Procedure referenced.

In addition to the three items identified by the Quality Assurance Audit, PGE identified a design deficiency associated with the backup air accumulators for the power-operated relief valves. This design deficiency is only applicable during shutdown conditions. This deficiency, including compensatory measures and corrective actions, was previously provided to the NRC in Licensee Event Report 92-10, dated May 6, 1992.

If you have any questions concerning this matter, please contact me or Mr.11. K. Chernof f of my staf f.

Sincerely, AWhI ,0w.4}

W. R. Robinson for J. E. Cross c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. Kenneth Johnston NRC Senior Resident Inspector Trojan Nuclear Plant I