ML18153D282
| ML18153D282 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/25/1993 |
| From: | Buckley B Office of Nuclear Reactor Regulation |
| To: | Stewart W Virginia Power (Virginia Electric & Power Co) |
| References | |
| GL-88-014, TAC-M71726, TAC-M71727 NUDOCS 9303310278 | |
| Download: ML18153D282 (4) | |
Text
e UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. W. L. Stewart Senior Vice President Virginia Electric and 5000 Dominion Blvd.
Glen Allen, Virginia Dear Mr. Stewart WASHINGTON, D.C. 20555-0001 Nuclear Power Company 23060 March 25, 1993
SUBJECT:
SURRY POWER STATION, UNITS 1 AND 2 - GE~ERIC LETTER 88-14 "INSTRUMENT AIR SUPPLY SYSTEM PROBLEMS AFFECTING SAFETY-RELATED SYSTEMS" (TAC NOS. M71726 AND M71727)
By letter dated February 21, 1989, as supplemented February 15, 1991, December 2, 1991, April 20, 1992, and February 2, 1993 you responded to Generic Letter 88-14.
In your February 21, 1989 letter you stated your intent to upgrade the Surry Turbine Building and Containment Instrument Air Systems to safety-related air-operated components with air meeting the Instrument Society" of America (ISA) Standard 7.3, Quality Standards for Instrument Air, 1981 revision. Subsequently, by letter dated February 15, 1991, you stated that you had experienced difficultly in meeting certain requirements of ISA 7.3; specifically, reducing the particulate size to 3 microns tn both air systems and maintaining dew point at 35°F for the Containment Instrument Air System.
With regard to the Turbine Building Air System, you stated that you upgraded this system by replacing the refrigerant dryers with desiccant-type dryers which resulted in improved air quality; however, while the ISA 7.3 three micron particulate criterion was not achieved, you believed that this criterion could be met during the next several operating cycles by periodic blowdown of this system.
You also stated that while your long-term goal is to meet the 3 micron criterion, you have modified your commitment from 3 microns to 5 microns. Thus, except for this one exception you meet all other criteria specified i.n!ISA 7.3.
The other sy~tem where you state that you do not fully meet the ISA 7.3 criteria wi"tJ( respect to particulate size and dew point is the Containment Instrument Air System which operates independently of the Turbine Building Instrument Air System.
However, the testing you conducted in accordance with Generic Letter 88-14 verified the system components' operability.
In addition, you stated that numerous maintenance and performance verification activities were completed in this area.
These activities included system blowdowns, stroke testing of air-operated valves, reconditioning of one of the air compressors, and preventative maintenance on both Containment Instrument Air Dryers. Subsequently, based on special tests using a laser particulate counter, the maximum particle size measured in the Containment Instrument Air System was less than 20 microns.
Thirteen operability tests were conducted in 300016
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e March 25, 1993 accordance with GL 88-14 to determine particulate size. It was shown that the majority of the particulate were less than or equal to 10 microns.
Although a few were greater than this value, those in excess had particulate sizes of less than 20 microns.
Measurable accumulation on the filter disk was not seen in tests with air flow periods of one hour and two hours. There have been no safety-related solenoid operated valve failures atributable to the containment instrument air system since 1984.
In order to ensure proper system operation, containment instrument air is being reviewed as part of the reliability-centered maintenance program, and testing in accordance with the technical specifications and the in-service testing program will ensure performance testing and preventive maintenance activities are accomplished.
As a result, the deviation from ISA 7.3 regarding particulate size is acceptable, provided that if the particulate size increases above 20 microns, you must notify the staff.
With respect to the dew point, you state that the Containment Instrument Air System uses refrigerant dryers that cannot meet the ISA Standard for dew point of 35°F.
Because the minimum temperature in the containment during operation is approximately 100°F, the current refrigerant dryers can only reduce the dew point to 50°F.
However, as stated in your December 2, 1991 submittal, due to the elevated containment temperatures during operation, the instrument air dew point temperature is l8°F below the containment ambient temperature, as required by the ISA Standard, and does not pose a component operability issue.
During cold shutdowns the safety-related air-operated components in the containment will be supplied by the existing Turbine Building cross-connect, which meets the ISA Standard for a 35°F dew point.
Based on the testing for component operability as required by the Technical Specifications and the ASME Section XI In-Service Test Program, the continued implementation of preventative maintenance activities established in response to Generic Letter 88-14, the operating and maintenance history of air-operated safety-related components in both Instrument Air Systems, and the inclusion of the containment air system in the reliability-centered maintenance program, we find the_proposed exceptions to the ISA Standard acceptable.
This completes our efforts on this issue, and we are, therefore, closing out TAC Nos.. M71726 and M71727.
cc:
See next page Distribution:
See next page OFC LA: PDII-2 NAME l
DATE 03/"6;93 OFFICIAL RECORD COPY DOCUMENT NAME - SU.ISA (Original Signed By H. Berkow For)
Bart C. Buckley, Senior Project Manager Project Directorate tl-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation C:SPL CMcCracken 03/2 /93
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Mr. W. L. Stewart Virginia Electric and Power Company cc:
Michael W. Maupin, Esq.
Hunton and Williams Post Office Box 1535 Richmond, Virginia 23212 Mr. Michael R. Kansler, Manager Surry Power Station Post Office Box 315 Surry, Virginia 23883 Senior Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse, Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23209 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Robert B. Strobe, M.D., M.P.H.
State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 24~8 Richmond, Virginia 23218 Surry Power Station Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219 Mr. M. L. Bowling, Manager Nuclear Licensing & Programs Innsbrook Technical Center Virginia Electric and Power Company 5000 Dominion Blvd.
Glen Allen, Virginia 23060
e Memorandum Dated March 25, 1993 Distribution
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NRC & Local PDRs PDII-2 RF S. Varga G. Lainas H. Berkow E. Tana B. Buckley OGC ACRS (10)
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