JPN-91-047, Forwards Status Rept on 18 Tasks Committed to by Util to Complete Response to Generic Ltr 88-14, Instrument Air Supply Problems Affecting Safety-Related Equipment. Only 4 of 18 Tasks Remain to Be Completed

Forwards Status Rept on 18 Tasks Committed to by Util to Complete Response to Generic Ltr 88-14, Instrument Air Supply Problems Affecting Safety-Related Equipment. Only 4 of 18 Tasks Remain to Be Completed

ML20082Q875
Person / Time
Site:	FitzPatrick
Issue date:	09/10/1991
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, JPN-91-047, JPN-91-47, NUDOCS 9109130107
Download: ML20082Q875 (10)

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4# Authority ty;;;;2r-September 10,1991 JPN 91-047 U. S. Nuclear Rogulatory Commission Mall Station P1 137 Wash!ngton, D.C. 20555 Attention: Document Control Desk

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Status of Action items identified in Response to NRC Generic Letter 8814 Instrument Air Supply Problems Affecting Safety-Related Equipment

Reference:

1. NYPA lotter, J. C. Brons to NRC, dated September 21,1989 (JPN 89-061) *Rosponso to NRS Gonoric Lottor 8814 Instrument Air Supply Problems Affecting Safoty-Rolated Equipmqqt."

Doat Sir:

Attachod is a report on the status of eightoon tasks the Authority committod to completo in its responso to NRC Gonoric Lottor 8814 (aoforenco 1). The report also includos the lost results the Authority committed te provido in its responso.

In Section X of the first report on the FitzPatrick plant's instrument air system (Roforonco 1),

the Authority summarized eightoon tasks that had not boon completed when the report was submittr>d. Those tasks includod rnodifications, revisions to oporating proceduros, tests, maintonanco, engincoring reviews and tralning.

Only four of thoso eightoon tasks romain to be completod: 1) Two air operated valves must be replaced with spool plocos (Itom C.3); 2) A Reactor Analyst proceduro for the scram intol/ outlet valvos rilust be revised to refloct ASME Soction XI test requirements (Itom B.3);

l 3) Anomalous test results must be assessed and, if required, correctivo action scheduled (Itom C.6.c); and 4) The instructor's lesson plan for the scenario when instrumont air has boon lost requires review and approval (Item F), Complotion datos for those tasks are discussed in the attachment.

As roquestod by the Genotic Lottor, the Authority will provido a written notification whoo all requirements of the Gonoric Lotter have boon completod.

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. If you have any questiott.. please contact Mr. J. A. Gray, Jr.

Very truly,y s, e alph Boodlo

$.M w(g Exocutivo Vice Prosidont Nuclear Generation cc: Offico of the Rosident inspector U. S. Nuclear Regulatory Commission P. O. Box 136 Lycoming, NY 13093 Rogional Administrator U.S. Nuclear Rogulatory Commission 475 Allendalo Road King of Prussia, PA 19400 Mr. Brian C. McCabo Project Dirockrato 11 Division of Roactor Projects 1/11 U.S. Nuclear Rogulatory Commission Mall Stop 14 B2 Wash!ngton, DC 20555 i

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1 Now York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91-047 PaDo 1 of 8 REPORT ON THE STATUS RESPONSE TO NRC GENERIC LETTER 8814

• lNSTRUMENT AIR SUPPLY PROBLEMS AFFECTING SAFETY RELATED EQUIPMENT" NRC Goncric Lottot 88-14," Instrument Air Supply Problems Affecting Safety Rolated Equipmont," requ; rod each licensoo to review NUREG 1275, Volume 2 and perform a design and oporations verification of its instrument air system. The rosu!ts of the FitzPatrick plant instrument Air System (iAS) ovaluation woro transmitted as Attachment I to Robronco 1. Tho FitzPatrick evaluation identified eightoon items for further action and summarlzod thom in Section X. The current status of those items, including test results, is presented below:

A. Modifications

1. Air Dryor Drain Valvos No modification to add manual drain valvos was found to bo necessary; the drain traps on air dryor profitters 39F 5A and B have manuel drain yhlves.

2. Dosiat.n. . ,yer Afterfilters A modification (D1-90-236) was performed to increase the rotontion rating of tho instrument air dryer afterfilter clomonts. The afterfiltor elomonts have boon rool aced by filters which moet tho 3 micron particulato rotention requirements of ANSI /ISA standard S7.3.

B. O J orating %cedure Revisions

1. System Operat;ons Operations Department Standing Order ODSO 17, " Auxiliary Operator Plant Tour and

- Operating Logs

• has boon revised to ensure that operating parameters specified by Operating Proceduro OP-39, "Broathing, instrument, and Servico Air System," are monitored and recorded during normal plant operation.

2. System Operations Abnormal Operating Procedure AOP 12, " Loss of Instrument Air," has boon revised to include: component ID, description, and fait safo posit!nn. The proceduto also includos guidelinos for recovery frorc loss of instrument air. Survoillanco Test procedure ST 39N,

• Outboard MSIV Simulated Loss of Instrument Air Drift Test,'

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e New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91047 Pago 2 of a specifies an acceptanco valuo of grohter than 30 minutos for tho Main Steam Isolation Valvos (MSIV) to drit' from 100% open to 90% open when the air supply is removod from tho accumulator.

3. Control Pod Scram Timo Evaluation The insorvico Testing Program for Pumps and Va!vos complies with ASME Section XI, 1980 Edition through Wintor 1981 Addenda. Roactor Analyst Proceduto 7.3.10,

" Control Rod Scram Timo Evaluation " is currently being revised to referenco ASME Sect!on XI,1980 Edition through Winter 1981 Addenda. The revision will be completed by September 30,1991.

4 RCIC and HPCI Dicahargo Testable Check Vaivos A review of the logic diagrarr s shows that on loss of air or cloctrical power the RCIC and HPCI dischargo testablo chock valvos (13SOV 22 and 23SOV-18) fail "as is." The air actuators aro not designed to closo the valvo on flow or hold it open against reverso flow. Therefore, no degradation of the check valve function would occur as a result of the failure of the actuator.

5. Classification of Various Vawcs 23AOV 39 (HPCI condonsato pump dischargo to clean radwasto isolation vaivo):

Based on a review of appucable piant procedures, drawings, Mastor . iipment Ust (MEL) componont data and design specifications, this air operated vJve is normally open, closing upon HPCI initiation signal or loss of instrument air. The operator is classified as OA category I and solsmic category I. Surveillanco Test Proceduro ST-4N "HPCI Flow Rato and inservico Tost" includes testing of valvo 23AO\ -3G to ensure its operability.

10AOV 71 A and B (RHR' heat exc' origor level control); 10PCV 69 A and B (RHR heat exchanger pressuro reducing valvo); 10FCV-43 (RHR head spray flow control va!vo):

The pressure boundary of the abovo valvos is classified as OA Category I. Becauso iho actuators for thoso valvos are category ll/Ill, no testing is performed. The valvos for RHR heat exchangor lovel control and pressuro reducing (10AOV-71 A and B and 10PCV-69A and B, respectively) are operated when the steam condensing modo of the RHR is actuated, and the RHR head spray control va;vo (10FCV-43) could bo (but usually is not) operated during the RHR shutdown cooiing modo. However, those i RHR operating modos are no; required for safo piani shutdown, and, thus, no testing program is required. Operation in the steam condensing modo of tno RHR is very

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_ James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN-91-047 Page 3 of a rarely used but will cause the RHR heat exchanger level control and pressure reducing valves to be operated. Failure of the valve operators will not affect the safety function of the other RHR operating modes or containment integrity.

C. . Tests

1. Containment Sump Isolation Valve Air Accumutators Surveillance Test Procedure ST.1U "Radwaste Containment Isolation AOV Fail Safe '

Test" includes testing of the two drywell equipment draln containment sump isolation valves (20AOV-83 and 20AOV 95) for their fall-safe (closed) position, and checks the integrity of the accumulator and the check valve condition. The test is performed once each 92 days. The initial test conducted during the 1990 refueling outage

' demonstrated their acceptability.

U 2. - Air Dryer Testing As a d?monstration of system capability, a special test was performed to collect one .

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- additional water vapor sample after one air' dryer was secured and isolated from the

!' ' two dryer system. Isolating one dryer without operating the backup dryer (AD-3) is

- done during normal dryer maintenance. Water vapor results ranged from 30 mil'igrams per cubic meter to 100 milligrams per cubic meter corresponding to a dew poir' rango of -60*F to .35'F. This meets the requirements of ANSI /ISA-S7.3 and, theiL operatien of the backup dryer (AD-3) during scheduled maintenance of a ,

p - normt i >perating dryer is not required.

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-3. Incorrect Valve Position Failures Electrical unit' bay area unit cooler 16A and 168 temperature control valves (67TCV.

119 and 120f respectively) currently f ait closed instead of open as required for system functionability on loss of air. As an interim corrective measure, tne service water -

bypass valves (46SWS-64A and B) around the temperature control valves (C7TCV-119 and 120) are tagged open to ensure service water flow to unit coolers 67UC-16A and B on loss of instrument air during normal or emergency conditions.

An engineering review has determined that removal of the temperature control valves

' instead of a modification to their operating characteristics is the preferred option to resolve this item. The function of these valves, control of area temperature, was transferred to the air side of the area cooling system to resolve a silt buildup concem.-

L This was the subject of Technical Specification Amendment 156. S!nce these valves

'. are no longer required to control area temperature, they can be removed.

{ Accordingly, a modification package has been prepared and is under review for the l

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New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91-047 Page 4 of 8 romoval of the temperature control valvos and their replacement with spool plocos.

This modification is schnduled to be performed during the 1992 refuel outage.

4. Fall Safe Positions Surveillance Test Procedure ST-41 F "HVAC Control Valve Fail Position Test" includos testing of servico water system pressure control valves (66PCV 101 and 67PCV 101) for their fail-safo position with a test froquency of once overy 92 days.

5. Valvo Operability in Unit Coolor Performance Testing Crescent area unit coolor temperaturo control valvos (66TCV 107A,66TCV-107B, 66TCV 107C,66TCV 107D,66TCV-107G,66TCV 107H,66TCV-107J and 66TCV-107K), have boon replaced by stain! css steel spool pieces as part of the crescent area unit coolor improvement modification (F1-89-049). Since those valves havo boon removed, no further action is necessary.

Crescent arua unit cooler temperaturo control valves (66TCV 107E and 66TCV 107F) continuo to operato as designed. Thoso valvos fail in the open position on loss of instrument air to provido a continuous service water supply to tha crescent area unit coolers during norma: or emergency operation.

Surveillanco Test Procoduro ST-19A ' Crescent Area Unit Cooler Operability Test' and ST-41 F 'HVAC Control Valve Fail Position Test" includo performance testing to ensure operability and detect valvo degradation for crescent area unit cooler temperature control valves (66TCV-107E and 66TCV-107F).

6. Instrument Air Testing

a. Hydrocarbor.s The highest measured value obtained at the FitzPatrick plant was within the limits of 1 ppm (volumo/ volume or weight / weight) as specified in ANSI /ISA-G7.3.

b. De'n Point Dew point measuromonts ranged from -35 F to -60"F during plant operating conditions. Tho measurements are well within the specification requiromonts of ANSI /ISA S7.3.

New York Power Authority James A. FitzPatrick Nuclear Power Plant

) ATTACHMENT 1 TO JPN-91-047 Page 5 of 8

c. Particulate Testing Cassette samples were examined using computer-controlled scanning electron microscopy Very little material was deposited on the sample media, confirming the performance of the recently installed afterfilters. For the initial test, the filters met the requirements of ANSI /ISA-S7.3 in filtering out particulates of 3 microns or larger. Subsequent tests have given inconclusive results. Because those tests were recently performed, the nececsity for corrective action or modifications has not been determined.

d. Long Term Test Program Process Surveillt. ace Procedure PSP-29 " Instrument Air Sampling and Analysis" has been implemented and provides instructions for the sampling and analysis of the instrument air system. The instrument air is checked quarterly for dew point, oil content, and particle size. However, based on the test results described in

, paragraph 6.a and the compressors oil free piston lubrication and teflon piston rings, testing for hydrocarbons during the quarterly test may not be warranted.

4 7. Header Isolation Valve Testing Gurveillance Test Procedure ST-41G " Breathing and Service Air Headers Simulated Automatic Isolation Test" includes testing of header isolation valves (39FCV-110 and 39AOV 111). This test is performed once overy operating cyc'c.

D. Maintenance The wear rate for the piston rings in the air compressors has been determined to be e approximately 0.005 in, for the low pressure side and 0.010 in. for the high pressure side per 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> of normal operation. Maintenance replaces the piston ring when the ring wear reaches 0.010 to 0.005 in. for the low pressure side and 0.015 to 0.010 in, for the high pressure side.

The Preventative Maintenance (PM) checklist was developed by maintenance using vendor training and the Technical Manual.

u After reviewing the PM checklist and compressor log data, the Authority concluded that the established wear rate fur the niston rider ring and the 1500 hour0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> PM schedule is adequate for determining when 60 schedule parts replacement.

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. New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91-047 Page 6 of 8 ,

E. Review f

1. Adequacy of Accumulators on Containment Isoh: ion Valves A modification (F1-89-129) was performed in 1989, which consisted of installing a ,

safety-related (OA Category 1, Seismic Class 1) pneumatic supply line from the i L

nitrogen Containment Atmosphere Dilution (CAD) supply system to the Reactor ,

Building Closed Loop Cooling Water (RBCLCW) system containment isolation valve accumulators. This modification provides a safety-related pneumatic supply to the i valve actuators to ensure containment isolation.  ;

2. Instrument Air Quality Testing Relative to Hydrocarbons  !

See Sections C.6.a and C.6.d above. f F. Tralning Instructor Lesson Plan SDLP-39 " Instrument, Brea .iing and Service Air" has been revised }

to address the consequences of air operated valves failure on loss of air,  ;

instructor Lesson Plan LPAOP 12 " Loss of instrument Air" for Abnormal Operating Procedure AOP 12 " Loss of Instrument Ali' (see section B.2 above) has been developed to train personnel on the problems and consequences associated with common mode failure. LPAOP 12 is currently in a draft form with approval schedcled for December 31, 1991.

i References Documents referrw to in the ' ext above are identified in this list of references.

1. NYPA letter, J. C. Bronc to NRC, dated Septem!: ..; 21,1989 (JPN 89-061) " Response to NRC Generic Letter 80-14 instrument Air Supply Problems Affecting Safety-Related Equipment." ,

2. NRC Generic Letter 88-14,"Irmtrument Air Supply Problems Affecting Safety-Related Equipment", dated August 8,1988.

3. NRC NUREG-1275, Volume 2, " Operating Experience Feedback Report-Air Systems l Problems," dated December 1,1987. ,

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New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91-047 Page 7 of 8

4. NUS Corporation, NUS-5192, " Instrument Air Systom Evaluation in Rosponsa to NRC Generic Letter 8814 James A. FitzPatrick," prepared for NYPA, Revision 0, dated July 1989.

5. NYPA James A. FitzPatrick Nuclear Power Plant Modification D190-236, " Increase tho l Rotontion Rating of the Instrument Air Drycr Filter Elomonts," Rovision 0, dated

) December 16,1990.

6. American National Standard Institute / Instrument Society of America (ANSI /ISA)

Standard S7.3, " Quality Staadard for Instrument Air," dated November 18,1981.

7. NYPA James A. FitzPatrick Nuclear Power Plant Operations Department Standing Order ODSO-17, "Auxilian, Operator Plant Tour and Operating Logs," Revision 9, dated February 14,1990.

8. NYPA James A. FitzPatrick Nuclear Power Plant Operating Proceduto OP 39,

" Breathing, Instrument, and Servico Air System," Revision 19, dated May 8,1991.

9. NYPA James A. FitzPatrick Nuclear Power Plant Abnormal Operating Proceduro AOP-12,

" Loss of Instrument Air," Revision 10, dated May 8; 1991.

10. NYPA James A. FitzPatrick Nuclear Power Plant Surveillance Test Proceduro ST-39N,

" Outboard MSIV Simulated Loss of instrument Air Drift Test," Revision 3, dated June 2, 1990, 11.

NYPA James A. FitzPatrick Nuclear Power Plant "Inservico Testing Program for Pumps and Valves," Revision 4, dated May 1,1991,

12. NYPA James A. FitzPatrick Nuclear Power Plant Reactor Analyst Procedure 7.3.10,

" Control Rod Scram Timo Evaluation," DRAFT, scheduled September 30,1991,

13. NYPA James A. FitzPatrick Nuclear Power Plant Surveillance Test Proceduro ST-4N, "HPCI Flow Rato and Inservico Test," Revision 14, dated July 24,1991.

14. NYPA James A. FitzPatrick Nuclear Power Plant Surveillanco Test Proceduro ST-1U, "Radwaste Containment Isolation AOV Fail-Safe Test," Revision 1, dated October 17, 1990.

15. NYPA Jcmos A. FitzPatrick Nuclear Power Plant Technical Specification Amendment 156, dated April 11,1990.

16. NYPA James A. FitzPatrick Nuclear Power Plant Surveillance Test Proceduto ST-41F, "HVAC Va've Fail Position Test," Revision 4, dated July 11,1991.

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New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN 91047 Page 8 of 8

17. NYPA James A. FitzPatrick Nuclear Power Plant Modification F189-049, *Croscont Area Unit Cooler imprcvemonts

• Revision 0, dated July 25,1990.

18. NYPA James A. FitzPatrick Nuclear Power Plant Survoillanco Test Procedure ST 19A,

• Crescent Area Unit Cooler Operability Test," Revision 10, dated September 13,1990.

19. NYPA James A. FitzPatrick Nuclear Power Plant Process Survoillanco Proceduro PSP.

29, " Instrument Air Sampling and Analysis," Revision 1, dated March 11,1991.

20. NYPA James A. FitzPatrick Nuclear Ponor Plant Surveillarsco Test Proceduro ST-41G, "Broathing and Servico Air Headers Simulated Automatic Isolation Tost," Revision 1, dated April 18,1990.

21. NYPA James A. FitzPatrick Nuclear Power Plant Modifictalun F1-89129, " Nitrogen Supply to the RBCLCW Containment Isolation Valvos,* Revision 1, dated May 25,1990.

22. NYPA James A. FitzPatrick Nuclear Power Plant Instructor Lesson Plan SDLP-39,

" instrument, Breathing and Servico Alt," Revi 'n 3, dated May 10,1990.

23. NYPA James A. FitzPatrick Nuclear Power Plant Instructor Lesson Plan LPAOP-12, " Loss of Instrument Air," DRAFT, schedulod December 31,1991.

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