ML18018A014

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Updated Response to Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment
ML18018A014
Person / Time
Site: River Bend Entergy icon.png
Issue date: 10/21/1998
From: King R
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-89-013, RBF1-98-0251, RBG-44655 NUDOCS 9810270335
Download: ML18018A014 (5)
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. ~Entergy October 21, 1998 U.S. Nuclear Regulatory Commission Document Control Desk, OPl-37 Washington, DC 20555

Subject:

River Bend Station - Unit I Docket No. 50-458 License No. NPF-47

. Eolergy Operations, Inc.

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Updated Response to Generic Letter 89-13, "Service Water. System

  • Problems Affecting Safety-Related Equipment"

Reference:

RBG-34558, Update to Generic Letter 89-13 Response, dated 3/1/91 File Nos.:

01.49.5, 09.5, 09.33.4 RBFl-98-0251 RBG-44655 Ladies and Gentlemen:

The purpose of this letter is to update the River Bend Station (RBS) response to Generic Letter (GL) 89-13. On March 1, 1991, RBS provided a response update to GL 89-13, per RBG-34558. The updat~ contained the following commitment:

"Temperatures in the auxiliary building will be monitored as part of the Heat Exchanger Perfonnance Monitoring Program to ensure there is no unacceptable degradation in u:nit cooler performance."

Though we made procedural changes providing for the implementation of.this commitment, a review of GL 89* J 3 actions found no evidence of actual implemeiltatfon. After further review and due to service water system chari'ges since 1991; we no longer intend to implement the commitment and have initiated action to address the commitment deviation within our corrective action program. The following discussion identifies RBS service water system changes and progress since 1991 and provides an update to our GL 89-13 response..

In 1992, RBS modified the service water system to a closed loop system, chemically cleaned the system, replaced se~ected pipes and components, and cleaned, several safety-related heat pAoaull.

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Updated Response to Generic Letter 89-13 Octobe'r 21, '1998 PFl-98-0251 RBG-446SS Page 2 of 5 exchangers. Additionally, we initiat.ed chemical treatment of the Standby Cooling Tower*.

P1:oactive water chemistry controls are now in place. As a result, the significant sources of system biological contamination have been mitigated and nonnal system heat loads are no longer directly rejected to a raw water source. Therefore, Recommended Action II 2 of GL 89-13 no longer applies.to the RBS service water system.

The perfonnance testing scope of the RBS Heat Exchanger Monitoring Program has included the following heat exchangers:

Diesel Generator Jacket Water Coolers Control Building Chiller Condensers Residual Heat Removal (RHR) Heat Exchangers We completed initial testing on the above heat exchangers during Cycles 5, 6 and 7 (1994 through 1997) and hav~ perfonned periodic retesting nominally each fuel cycle up to the present time.

Control Building Chiller Condensers continue to be tested per Technical Specification surveillance requirements. RHR Heat Exchangers continue to be tested in accordance with GL 89-13 Supplement l, Section 110 and IIIF, due to shell side concerns (untreated Suppression Pool subject to the service water problems discussed in GL 89-13). Test frequency wiUbe reevaluated after the conduct of three tests. Due to the modification of the service water system to a closed loop system, performance testing of the Diesel Generator Jacket Water Coolers is no longer required. Past performance testing of the Diesel Generator Jacket Water Coolers has been satisfactory.

RBS initially listed the Auxiliary Building Unit Coolers. the RHR Heat Exchanger Radiation Monitor Coolers, and the Penetration Valve Leakage Coritrol System (PVLCS) Compressor

' All safety-related heat exchangers cooled by service water are on Nonna! Service Water during nonnal operations. As $1lCh,.the source of any fouling would be Nonnal Service Water and not Standby Service Water. These heat exchangers are. only exposed to Standby Service Water during plann~d surveillance 1esting and outages or accident scenarios. The Standby Cooling Tower does not represent a significant contaminatfon source because it is treated, mo.nitored and periodically ¢leaned.

2 Conduct.an initial and periodic t.est program to verify the heat transfe~ capability of all safety related heat exchangers cooled by open-cycle service water ~ystems. (The possibility of selectively extending the test

... program to closed-cycle systeins is also discussed.)

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U~ted Response. to Generic Letter 89-13 October 2.1, 1998 fWFl,-98-0251 RBG-44655 Page 3 of 5 Aftercoolers within the testing scope of GL 89-13. However, as provided in Enclosure 2 1 of GL 89-13, we implemented alternative actions:

replaced all Auxiliary Building Unit Cooler coils by the end of Cycle 4;

  • *completed initial air side inspections on Auxiliary Building Unit Coolers during Cycle 5,
  • with subsequent periodic inspections/cleanings; chemically cleaned the tube side of Auxiliary Building Unit Cooler (HVR-UC) 6 during Cycle 6, followed by inspection; perfonned initial tube side inspection on HVR-UCI 18 during Cycle 7; initially cleaned the RHR Heat Exchanger Radiation Monitor Coolers during Cycle 5; and replaced the PVLCS Compressor Aftercoolers during Cycle 4, followed by initial cleaning during Cycle 5.

1~ *..hough not required to meet Recommended Action II of GL 89-13, we will continue the following periodic maintenance actions, in assuring continued complicµ1ce with General Design Criteria (GDC) 45 of 1 OCFR50, Appendix A:

inspection/maintenance on the Auxiliary Building Unit Coolers; routine maintenance ( cleaning) on the RHR Heat Exchanger Radiation Monitor Coolers; and

  • routine maintenance ( cleaning) on the PVLCS Compressor Aftercoolers.

The modifications, replacements and testing identified in this letter have resulted in substantial reliability.increases in the RBS service water system and confidence that the system will perfonn its*intended function. The commitments contained in this document are identified on the Commitment Identification Form. If you have any questions or require additional infonnation, please contact Bill Fountain at (225*) 381-4625.

Sincerely, PNL for RJK\\WW 1 Enclosun: 2 is entith:d.. Program For Testing Heat Transfer Capability." It address~s initial and periodic testing pro~ams for safety~related beat exchangers on open~cycle service water systems. Corrective actions

. _are ~lle>We4 ~fqreJe~dng ~d ~plible alternative~ to testing are di~ussed.,

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Upiat~ Response.to Generic Letter 89-13..

C>ctbber it, 1998 RBFt-98-0251 RBG-44655 Page 4 of 5

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Mr. Robert J. Fretz NRR Project Manager U.S. Nuclear Regulatory Commission MIS OWFN 13-H-3 Washington, DC 20555 NRC Resident Inspector P. 0. Box.1050 St. Francisville; LA 70775 U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 7061 I Department of Environmental Quality Radiation Protection Division P. 0. Box 82135 Baton Rouge, LA 70884-2135 Attn: Administrator

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  • The RBS telephone area code is in the process of being changed from 504 to 225.

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Commitment Identification Fonn Updated Response to.Generic Letter 89-13 October 21, J 998

- RBF 1-98~025 l RBG-44655 COMMITMENT The RHR Heat Exchangers will continue to be tested in accordance with GL 89-13 Supplement 1, Section IID and UIF, due to shell side concerns (untreated Suppression Pool subject to the service water problems discussed in GL 89-I 3 ).

Test frequency [on the RHR Heat Exchangers] will be reevaluated after the conduct of three tests.

Continue the periodic action of inspection/maintenance on the Auxiliary Building Unit Coolers.

Continue the periodic action of routine maintenance (cleaning) on the Residual Heat Removal Heat Exchanger Radiation Monitor Coolers.

Continue the periodic action of routine maintenance (cleaning) on the PVLCS Compressor Aftercoolers.

  • Check one only page 5 of 5 ONE-TIME CONTINUING ACTION*

COMPLIANCE*

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