ML19340E413
| ML19340E413 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1980 |
| From: | Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19340E412 | List: |
| References | |
| REF-SSINS-9310, RTR-REGGD-01.068.03, RTR-REGGD-1.068.03, TASK-OS, TASK-RS-709-4 NUDOCS 8101140409 | |
| Download: ML19340E413 (5) | |
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!s ' ^Q g NUCLEAR REGULATORY COrdMISSION REGION 11 Nr.t o ~ -.!
101 MARIETTA ST., N.W., SUITE 3100 kko ATLANTA, GEORGIA 30303 DEC 0 51980 SSINS 9310 MEMO.RANDUM FOR:
N. C. Moseley, Director Division of Program Development and Appraisal FROM:
C. E. Murphy, Chief, RC&ES Branch, RII
SUBJECT:
DRAFT iEG. GUIDE 1.68.3, PRE 0PERATIONAL TESTING 0F INSTRUMNT AND CONTROL AIR SYSTEMS This refers to the proposed revision to Regulatory Guide 1.80 (To be issued as Regulatory Guide 1.68.3).
General Coments Proposed Reg. Guide 1.68.3 appears to be adequate for preoperational testing of instrument and control air systems to demonstrate that the systems will initially perform as designed.
Soecific Coninents In that proposed Reg. Guide 1.68.3, only verifies that the air systems meet design operational performance specification, not regulatory requirements, it is imperative that the companion document, Standard Review Plan, Section 9.3.1 Proposed Revision 1, Compressed Air Systems, be approved and implemented for all applications for an operating license. All current operating plants should be reviewed against both proposed R. G. 1.68.3 and Standard Review Plan Section 9.3.1, Rev. I to determine where backfitting is required.
Standard Technical Specifications do not include limiting conditions for operations (LCO) or surveillance requirements to insure that air systems remain operable and capable of meeting design intent. Enclosure I lists severa" failures that have occurred involving air systems. These failures involving systems important to plant safety dictate imediate action to develop and impose Technical Specification LCO, and surveillance requirements as recomended in Memorandum Victor Stello, Jr., to Roger J. Mattson, dated May 15, 1978, (
Subject:
Technical Assistance Request - Air Supplied for Safety Related Systems).
Value/ Impact Statement Item No. 3, mistakenly refers to Regulatory Position 10.
The correct reference is Regulatory Position 9.
Contact:
F. S. Cantroll (242 4182) 8101140 4 07
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. DEO O 51920 Value/ Impact Statement Item ?!o. 4, mistakenly refers to Regulatory Position 11 i
instead of Regulatory Position 10.
We request these coments be submitted to the Secretary of the Commission,;
U. S. lluclear Regulatory Comission by January 12, 1981, so that these comments may be evaluated.
I C. E. Murphy, if Reactor Ccnstruction and Engineering Support Branch
Enclosure:
Events Involving Air Systems f
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EVENTS INVOLVING AIR SYSTEMS
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Indian Point 1:
Failure of containment isolation valves to close on a test signal due to " crud" in the air supply, Compliance Inspection Report 50-03/71-01 and several subsequent reports.
Oyster Creek:
Complete loss of plant air and instrument air systems due to rupture of expansion joint between the compressor and the receiver tank about 1972.
(Compliance Inspection Report during that period).
Brunswick 2:
As a result of corrosion of check valves designed to prevent back flow, low air pressure.was experienced while testing Unit 1 air systems.
(Information report on sir sy: tem, letter H. R. Banks, CP&L to N.C.
Moseley, dated September 26,1976).
St. Lucie 1:
Loss of reactor coolant pump seals due to loss of instrument air compressor - check valve stuck open in discharge line that prevented the backup air compressor from pressurizing the air system.
(LER 335-77-23).
St. Lucie 1:
Loss RCP seal coolant due to ground in solenoid on containment isolation valve in seal coolant re urn line (Solenoid controlled air operated valve), reactor scrammed and RCP tripped.
Steam bubble forme'd in reactor (LER 335-80-29).
Browns Ferry Fire:
Air supply to containment ar.d the safety relief March 1975 valves was lost thus prevented depressurizing Unit 1.
Until the air supply was restored; Unit I was unable to Edd make up water to the reactor for cooling (Report on Browns Ferry Fire).
Sequoyah 2:
A containment isolation signal isolates the air supply to the Power Operated Relief Valves, which are set to limit reactor pressure to 2350 psia.
As a result, reactor pressure could increase to 2500 psia (SRV set point). At this pressure, the
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4 centrifugal charging pumps (ECCS) could self distruct due to insufficient flow if operator action is not initiated to stop the pumps (The isolation signal also closes the minimum flow line on the charging pumps.)
(10 CFR 50.55(e) report dated June 18, 1980.)
Watts Bar 1, 2:
"A study by the University of Dayton has shown that accumulation of water in the starting air system has been one of the most frequent causes of diesel engine failure to start on demand". (Letter R. L.
Tedesco to H. G. Parris, Request For Additional Information - Watts Bar 1 & 2, Paragraph 040.100 (9.5.6) RSP.)
Rancho Seco 1:
Air hose leak between air relay valve a'nd starting motor. The loss of redundant emergency diesel generator starting air system may not be detected until both systems fail unless AC and DC air start systems are tested separately.
(LER 50-312/80-013).
Browns Ferry 3:
Failure of control rods to insert during a scram at a BWR due partial loss of control air.
(IE Information Notice 80-30 and IE Bulletin 80-17 Supplement 3.)
Sequoyah 2:
Corrosion caused by water or moisture in air supply inhibited operation of containment vaccuum relief isolation valves. A failure of these valves to operate could lead to a negative pressure that could damage containment.
(10 CFR 50.55(e) report dated October 23, 1980.)
Three Mile Island 1:
The replacement ASCO solenoid valves for eleven containment isolation valves had a maximum safe working pressure of 75 psi. The normal air supply is 85-95 psi. Over pressurization could have prevented operation of the isolation valves (LER 50-289/80-18).
Millstone 2:
A reactor trip occurred after the loss of control air to the feedwater regulating system due to the failure of an instrument air line in the secondar, plant system. (Daily Report 7/11/80)
Calvert Clifts 1:
Air from an air compressor after cooler leaked into the service water (SW) system causing all SW pumps to become air bound and a total loss of service water for several hours.
The SW system l
provides coolant to safety-related components such as containment cooling units, spent fuel pool heat exchangers, and the emergency diesel generator heat exchangers.
(LER 50-317/80-02 dated May 21, 1980, and proposed IE Circular:
Common Cause Failure of Service Water System.-)
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