ML18094A313
| ML18094A313 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/31/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, NLR-N89062, NUDOCS 8904120308 | |
| Download: ML18094A313 (7) | |
Text
,J Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer March 31, 1989 NLR-N89062 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen; RESPONSE TO NRC GENERIC LETTER 88-14, INSTRUMENT AIR SYSTEM PROBLEMS AFFECTING SAFETY-RELATED EQUIPMENT SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas (PSE&G} hereby forwards to this transmittal in response to the subject NRC Generic Letter.
An extension to the original due date was granted as discussed in our transmittal NLR-N88188 dated December 6, 1988.
If there are any questions regarding the attached, please feel free to contact me directly.
Sincerely, Attachment
' '1 I
Document Control Desk C
Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector 2
Mr. w. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 03-31-89
REF: NLR-N89062 STATE OF NEW JERSEY
)
SS.
COUNTY OF SALEM Steven E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President and Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated March 31, 1989
, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me "this,j/ sf_
day of YWJcJi
, 1989
'~-m-Ock
.* ~otary _ I>yblic of New Jersey My Commission expires on EILEEN M. OCHS NOTARY PUBLIC OF HEW JERSEY My Commission Explm July 16, 1892
ATTACHMENT 1 Response to NRC Generic Letter 88-14 Salem Generating Station Units 1 and 2 NRC Generic Letter (GL) 88-14 requests that licensees perform a design and operations verification of instrument air systems at their respective nuclear facilities.
This request resulted from an NRC review of operating plant events attributable to air system failures and the perception of a possible threat to the long term operability of safety-related systems and components which depend on these systems.
The results of the NRC review are summarized in NUREG-1275.
Public Service Electric and Gas (PSE&G) recently completed a detailed System Functional Review {SFR) of the Salem Unit 1 and 2 Control and Station Air Systems.
The SFR was structured to encompass many of the aspects included in the NRC's own Safety System Functional Inspection process and to address those specific requirements delineated in GL 88-14.
The detailed results of this review* form the basis for PSE&Gs response to GL 88-14.
Generic Letter (GL) 88-14 identifies 4 areas to be evaluated and requires that a plant specific response be submitted in each area.
Each of the areas to be addressed are described below along with the PSE&G response.
An identification of outstanding tests and the schedule for completion are also included.
Item 1 Verification by test that actual instrument air quality is consistent with the manufacturers recommendations for individual components served.
PSE&G Response A vendor manual review was conducted in order to identify applicable manufacturer recommendations regarding air quality.
The majority of vendor manuals reviewed did not provide air quality requirements.
In order to establish a limiting air quality design condition, PSE&G reviewed the air quality table provided in NUREG 1275, Volume 2.
It was determined that particulate filtration was the limiting design condition with the most limiting particle size being 5 microns (max).
The Salem control air dryer after filters contain 3 micron filters thereby satisfying this quality requirement.
Instrument Air Society of America (IASA) Standard ISI-S7.3 was also utilized to identify quality recommendations for the control air system.
This standard identifies the following factors for NLR-N89062 1
evaluation; 1) Dewpoint (at line pressure), 2) Particle Size,
- 3) Oil Content, and 4) Contaminants.
Each of these factors was reviewed qualitatively as part of the SFR and, where applicable, appropriate recommendations for improvement have been made.
It is PSE&Gs position that additional air quality testing to address this item is not warranted based on our commitment to institute a comprehensive program to monitor and maintain air quality.
This commitment is discussed in detail under Item 4.
Item 2 Verification that maintenance practices, emergency procedures and training are adequate to ensure that safety related equipment will function as intended on the loss of instrument air.
PSE&G Response Maintenance activities applicable to the control air system are based on manufacturer recommended tasks and frequencies and on equipment history.
Maintenance procedures covering these activities currently exist and are judged to be adequate to address the concerns of GL 88-14.
However, based on the results of the SFR, the Salem Technical and Maintenance departments will be upgrading certain tasks and procedures.
These upgrades are generally administrative in nature with no impact on the safety of plant operation.
As such, these procedures will be revised as part of the normal 2 year update cycle.
Additionally, PSE&G is in the process of developing a Reliability Centered Maintenance program.
Program development activities will continue over the next several years.
The Salem Station control air system is presently included in the scope of this program.
As such, maintenance and surveillance activities will again be reviewed with an emphasis on improving overall system reliability.
Emergency procedures covering operator response to complete loss and partial loss of control air are presently in place.
These procedures address both response to and recovery from the event and provide necessary guidance on equipment fail-safe positions (e.g.. valve fails open or closed).
These procedures were reviewed as part of the SFR and found to be satisfactory.
The Salem operators are trained to understand the operation of the plant both with and without the control air system.
Licensed operators receive simulator training on the loss of the control air system.
Other plant personnel (equipment operators/I&C Techs) are trained to respond in the field by performing the required manual equipment operations (e.g. positioning an essential valve using manual operator).
The SFR concludes that the training program is adequate to address the concerns of GL 88-14.
NLR-N89062 2
Item 3 Verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function, including verification by test that air operated safety-related components will perform as expected in accordance with all design-basis events, including a loss of the normal instrument air system.
This design verification should include an analysis of current air operated component failure positions to verify that they are correct for assuring required safety functions.
PSE&G Response The overall design adequacy *of the control air system was reviewed by the Salem Technical department as part of the SFR.
The only safety-related accumulators in the system are installed on the Unit 1 and Unit 2 pressurizer housing and operate the Power Operated Relief Valves (PORV) when control air is isolated to the containment building.
These accumulators are designed to stroke each PORV a minimum of 50 times with the normal supply isolated.
The capability of the Unit 2 accumulators was verified by the test in October 1988.
The unit 1 PORV's will be tested during the upcoming 8th refueling which is scheduled to begin April 1989.
Air operated equipment failure positions were analyzed as part of the SFR and found to be acceptable.
The Salem Station Maintenance Retest program requires a fail-safe position verification after maintenance on safety related air operated valves.
Additionally, periodic surveillance is performed on safety-related air operated equipment to verify its ability to perform its required safety function under loss-of-air or loss-of-control power conditions.
As such no additional design basis testing of air operated equipment is required to satisfy this item.
During the Unit 1 8th refueling outage which is presently underway, a test of the Unit 1 emergency control air compressor (EAC) will be conducted.
The test will determine the actual capacity of the Unit 1 EAC~
A similar test will be conducted on Unit 2 during its 5th refueling outage which is scheduled to begin in April 1990.
Because of the shared nature of these systems, it is impractical to conduct a design which fully verifies the EAC design basis.
Such a test would require 1) that both Salem Units be in Mode 5 at the same time, and 2) that all safety-related loads for both units be in operation during the test.
Requirement 1 is not practical from an economic standpoint and requirement 2 represents an unacceptable risk to public health and safety.
NLR-N89062 3
Therefore, to fully assess the ability of the Salem Station EAC to meet its design basis, the results of the EAC capacity tests described above will be evaluated against a load study of the control air system.
The load study will identify all essential air operated components and their respective demand and expected leakage rates.
The load study and subsequent determination of system design basis compliance will be completed prior to start-up following the Salem unit 2, 5th refueling outage.
Item 4 Each licensee/applicant should provide a discussion of their program for maintaining proper instrument air quality.
PSE&G Response Beginning in March 1989, both Salem Units will use ANSI/ISA Standard S7.3 as the quality standard for instrument air.
Previously, air sampling at the Salem Station was limited to monthly dew point readings taken at the outlet of the control air dryers.
These dryers are scheduled for replacement during 1989.
The new dryers will provide air quality consistent with ANSI/ISA Standard S7.3 and also provide for improved system reliability.
Additionally, new recurring tasks have been initiated to require sampling instrument air at the outlet of the normal control air dryers and the emergency control air dryers.
This sampling will include particle size, oil content, hydrocarbon content, and dew point (at line pressure).
Samples will be taken on a monthly basis and the results forwarded to System Engineering for evaluation and trending.
The acceptance criteria will be as contained in ANSI/ISA Standard S7.3.
NLR-N89062 4