JPN-96-041, Revises Commitment Made in Response to GL 88-14 Re Maximum Particle Size Specified in ISA-7.3-1975 for Instrument Air Sys
| ML20128N065 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/10/1996 |
| From: | William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, JPN-96-041, JPN-96-41, NUDOCS 9610160281 | |
| Download: ML20128N065 (4) | |
Text
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October 10,1996 JPN-96-041 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Change to Commitment Made in Resnonse to Generic Letter 88-14
REFERENCES:
1.
JPN-89-061, " Response to NRC Generic Letter 88-14, Instrument Air Supply Problems Affecting Safety-Related Equipment," dated September 21,1989.
2.
Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment," dated August 8,1988.
3.
ISA-S7.3-1975 (R 1981), " Quality Standard for Instrument Air,"
approved November 16,1981.
4.
ISA-S7.0.01-1996," Quality Standard for Instrument Air," approved June 5,1996.
5.
NUREG-1275," Operating Experience Feedback Report - Air Systems Problems," Volume 2, Published December 1987.
Dear Sir:
The Authority is revising the following commitment made in response (Reference 1) to Generic Letter (GL) 88-14 (Reference 2) regarding the maximum particle size specified in ISA-7.3-1975 (Reference 3) for the Instrument Air System (IAS) at FitzPatrick:
I; "The FitzPatrick plant willcomply with the 3 micron limit as specified in ANSI /lAS Standard 7.3."
h 9610160281 961010 PDR ADOCK 05000333-P PDR 180054
with the following two commitments:
1.
"The FitzPatrick plant will comply with the 40 micron limit as specified in ISA-S7.0.01-1996. Pneumatic devices that require instrument air with less than 40 micron particle sizes shall have additional filtration to meet the particle size limit for the device."
2.
"If the air system quality does not meet the pneumatic equipment manufacturer's requirements during testing, corrective action will be taken to restore air quality to assure that those requirements are met."
Commitment 1 meets the particle size limit of ISA-S7.0.01-1996 (Reference 4). Commitment 2 utilizes the guidance contained in NUREG 1275 (Reference 5).
Recommendation 1 of Reference 5 states, in parts, that:
" Licensees should verify (and periodically monitor) that their plants' air system quality is within the specifications of the manufacturers of allpneumatic equipment that is either safety-related or relied upon to perform a safety function..."
"If the air system quality does not meet the pneumatic equipment manufacturer's requirements, either the air system should be modified to assure that those requirements are met, or the pneumatic equipment should be replaced with equipment that can perform the required function with the existing air system."
FitzPatrick periodically tests the plant's air quality. Recent test results show particle sizes of approximately five microns, which is in excess of the three micron limit. However, these test results verify that the manufacturer's recommendations for IAS particle size for all safety-related or important to safety pneumatic devices are being met. These test results also show lAS particle sizes less than the 40 micron limit specified in ISA-S7.0.01-1996. Therefore, there is no need to modify the air system or replace equipment. The revised commitments conform to current industry standards, and satisfy the particle size requirements for safety-related pneumatic equipment. contains the commitments made by the Authority in this letter. If you have any questions, please contact Mr. A. Zaremba.
William J. Cahill, Jr.
l Chief Nuclear Officer
Attachment:
As stated l
cc: next page
cc:
Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093 Ms. K. Cotton, Acting Project Manager Project Directorate I-1 Division of Reactor Projects 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 i
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l to JPN-96-041 Summary of Commitments Number Commitment Due Date JPN-96-041-01 The FitzPatrick plant will comply with the 40 micron Effective as of the l
limit as specified in ISA-S7.0.01-1996. Pneumatic date of this l
devices that require instrument air with less than 40 submittal.
I micron particle sizes shall have additional filtration to meet the particle size limit for the device.
JPN-96-041-02 If the air system quality does not meet the pneumatic Effective as of the equipment manufacturer's requirements during testing, date of this corrective action will be taken to restore air quality to submittai.
l assure that those requirements are met.
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