3F0289-02, Responds to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Task Force Created to Evaluate Full Range of Actions & Plan Instituted Consisting of Listed Elements

Responds to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Task Force Created to Evaluate Full Range of Actions & Plan Instituted Consisting of Listed Elements

ML20235M151
Person / Time
Site:	Crystal River
Issue date:	02/09/1989
From:	Widell R FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0289-02, 3F289-2, GL-88-14, NUDOCS 8902280138
Download: ML20235M151 (5)

Text

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g Power COR PO R ATION February 9, 1989 3F0289-02 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 subject: Crystal River Unit 3 I Docket No. 50-302 i Operating License No. DPR-72 )

Instrument Air System Verification {

Generic Letter 88-14 l

Dear Sir:

Generic Letter 88-14, Instrument Air Supply System Problems Affecting Safety-Related Equipment, requested a response describing actions taken or planned to assure the system performance does not have an adverso impact on plant safety. This letter is in response to that request.

Because of the number of related issues, Florida Power Corporation (FPC) organized a task force to evaluate the full range of actions which may be needed to assess properly any problems associated with the Instrument Air System. The task force was made up of members from ,

plant operations, maintenance, training, nuclear safety, engineering, and licensing. The task force evaluated several recommendations which have been made as a result of the Safety Performance Improvement Program (SPIP) , plus INPO Significant Operating Experience ' Report (SOER) 88-1, NUREG-1275, Volume 2, as well as Generic Letter 88-14.

Combining these various recommendations into a single review has allowed FPC to take an integrated approach to the resolution of the Instrument Air System concerns.

The task force produced a plan to resolve this issue. The plan includes the following key elements: i

1. A walkdown of the Instrument Air System will be performed. The walkdown will identify all components served by each root valve in the instrument air header. Component information will be collected including manufacturer, model number, location etc. The information will be gathered in such a way to assure effective integration into the configuration management efforts. An

, 8902280138 890209 PDR ADOCK 05000302 600l fl i P PDC I \

POST OFFICE BOX 219 + CRYSTAL RIVER, FLORIDA 32629-0219 + (904) 563-2943 A Florida Progress Company

February 9, 1989

, 3F0289-02 l Page 2 inspection will be performed to identify any cracks, leaks or other types of system degradation which may have occurred. Sketches of individual components will be prepared as appropriate and an assessment will be made of component accessibility for emergency operation.

2. Plant drawings will be revised based upon the information collected during the walkdown. Flow diagrams will be expanded as appropriate to indicate components served and relative location of instrument air system valves.

3. Components served by the Instrument Air System will be categorized as critical or non-critical. Critical components are defined as those which are required for safe shutdown or which could initiate or complicate a plant transient. This information will be used to prepare the failure analysis described in item 4.

4. A failure analysis will be performed for all critical components.

The analysis will determine whether or not the component failure mode is consistent with its required safety function and will include a complete loss of instrument air.

5. Functional specifications will be developed for all critical components. These specifications will include air quality requirements, air pressure and volume requirements, maintenance requirements, and post-trip / accident requirements. This information will be compared to the test data obtained by item 11 below.

6. Test procedures will be developed for critical component testing to determine response to a loss of instrument air. Any modifications necessary to enable performance of such tests will be identified.

The tests will evaluate component response to a loss of instrument air.

7. Instrument Air System procedures for corrective maintenance, preventive maintenance and surveillance of the compressors, filters, dryers and end devices will be reviewed and updated as necessary.

8. Emergency operating procedures for loss of instrument air transients will be developed. The procedures will follow the philosophy of the existing symptom based abnormal procedures.

9. Lesson plans will be developed for operator and maintenance personnel training on instrument air related events. The training will include system function and interfaces, normal operations, transient events and recovery from a system failure.

,. February 9,'1989

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-10. The General Employee Training (GET) or other training programs lesson plans will be updated as appropriate to include a section on the importance of the Instrument Air System.

11. Baseline air quality tests will be conducted at several locations within the system. The results of these tests will be compared to the functional specifications for the critical components to assure adequate air quality.

12.-A program will be developed to monitor periodically air quality at selected locations. Corrective action will be initiated if air quality declines below a predetermined level.

13. A study will be performed to determine any improvements needed regarding the Instrument Air System dryer.

14. FPC is evaluating the feasibility of providing control for all compressors from the control room. Presently only four of the six compressors can be started and stopped from the control room.

15. A stidy will be performed to evaluate the need to install auto:aatic operating Instrument Air System header isolation valves.

Implementation of this plan has begun. Preparations for air quality testing and system walkdown are under way. The evaluations, walkdowns, and baseline air quality testing will be completed by the end of 1989.

Loss of air testing on individual components will be done on-line, where possible,-by the end of 1989. Where on-line testing is not

.possible, this testing will be completed prior to restart from the next refueling outage currently scheduled to begin the first quarter of 1990. Any necessary modifications will be scheduled based on the relative priority of the needed change (s).

Walkdowns associated with the solenoid valve application issue identified in IE Information Notice 88-24 and confirmed to exist at CR-3 (LER 89-01) are being scheduled. The schedule will be provided via LER Supplement by March 6, 1989.

The Instrument Air System at Crystal River 3 (CR-3) is designated as non-safety related, although some safety related components are served i by the system. Those valves required for safe shutdown fail or lock in a safe position upon failure of the air system. Instrument air is not used inside containment during plant operation.

As.part of FPC's efforts to achieve compliance with 10 CFR 50.63, Loss of.All Alternating Current Power, a review of the design failure position of all air operated containment isolation valves has been performed. This review concluded that all such valves are designed to

g. Fcbruary 9, 1989

, 3F0289-02 Page 4 fail to;a' safe position and appropriate containment integrity will-be maintained. .No operator action is necessary during a station blackout

-event in order to assure' continued containment' isolation to compensate

for the resulting loss of instrument air.

Should there be any questions, please contact this office.

Sincerely, 7 I Rolf C..Widel , Director

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-Nuclear Site Support AEF:

xc:. Regional Administrator, Region II Senior Resident Inspector

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4 STATE.OF; FLORIDA COUNTY OF CITRUS l

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.Rolf C. Widell states that he is the Director, Nuclear Site Support for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

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Rolf C. Widell, Director Nuclear Site Support Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 9th day of February 1989.

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Notary Public Notary Public, State of Florida at Large, My Commission Expires: pNa'mmts e nIxo : MIr2 1Y91 Bonded by Western Surety Company l

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