ML20011F419
| ML20011F419 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/26/1990 |
| From: | Eddy J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, TAC-71628, NUDOCS 9003060006 | |
| Download: ML20011F419 (5) | |
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Consumers Power t
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lf oeneral offices: 1946 Weet Parnell Road, Jackson, MI 49201 * (617) 78s 0660 February 26, 1990 j
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f Nuclear Regulatory Commission Document Control' Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
RESPONSE TO A REQUEST FOR ADDITTONAL INFORMATION ON GENERIC LETTER 88-14 (TAC NO. 71628) a-Consumers Power Company letter dated February 20, 1989 provided Big Rock Point's response to Generic Letter 88-14. " Instrument Air Supply Problems Affecting Safety-Related Equipment". NRC letter dated November 21, 1989, acknowledged receipt of Consumers Power Company's letter and requested additional information concerning Ceneric Letter 88-14. This letter provides additional information concerning Big Rock Point's initial response to i
~ Consumers Power Company's February 20, 1989 response utilized information readily available at that time. Responses to the-questions were formulated with the intent that final verification of compliance would be upon completion of the necessary analyses / evaluations and in accordance with the
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Big Rock Point Living Schedule. The following response to the request for' l
additional information is still based on the above premise.
J Daniel Eddy Plant Licensing Engineer CC Administrator, Region III USNRC NRC Resident Inspector.- Big Rock Point I
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ATTACHMENT Consumers Power Company l
Big Rock Point Plant Docket 50-155 ADDITIONAL INFORMATION FOR GENERIC LETTER 88-14 ITEMS 2 AND 3 Febniary 26, 1990 i
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Generic Letter 88-14 Item #2 Request l
" Verification that maintenance practices, emergency procedures, and training are adequate to ensure that safety-related equipment will function as intended on loss of instrument air."
Consumers Power Company's February 20, 1989 Generic Letter 88-14. Item 2
Response
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" Post-maintenance testing and periodic surveillance testing of safety-related equipment assures that the equipment can perform its intended safety function under the design conditions, including, when applicable, loss of instrument air. Testing is governed by individual work orders and maintenance or surveillance procedures that provide the necessary verification and documentation of equipment operability prior to return to service. Big Rock Point Off Normal Procedure ONP 2.2, " Loss of Instrument Air System", covers symptoms and actions for dealing with loss or decaying pressure in the instrument air system.
ONP-2.2 requires operators to scram the reactor when instrument air pressure cannot be maintained, and to verify that safety-related equipment j
functions as intended. Various other Operating Procedures, Alarm Procedures, and Emergency Procedures address symptoms and appropriate actions for dealing with loss of, or decaying instrument air system pressure on an individual component basis.
Operators are trained in the use of these procedures."
t NRC November 21, 1989 Request for Additional Information to Consumers Power Company's February 20, 1989 Response to Generic Letter 88-14 Item #2":
"Your response indicates the status to be the post-maintenance testing and periodic surveillance testing assures that the equipment performs its intended safety function. Also, several procedures are referenced dealing with loss of, or decaying instrument air system pressure and that the operators are trained in the use of these procedures. Does j
this status verify that maintenance practices, emergency procedures, and training are adequate to ensure that safety-related equipment will function as intended on loss of instrument air?"
Consumers Power Company's Response to the NRC Request for Additional Information on Response to Generic Letter 88-14 Item #2.
g Yes. Consumers Pcwer Company's response to Item #2 was intended to identify the in-place administrative controls and procedures which we believe satisfy the intent of Item #2.
Emergency procedures and training in themselves cannot ensure that equipment will perform as j
intended on loss of instrument air. The procedures and training provide guidance to the operators on, "how equipment will react to loss y
of air, symptoms of this condition, and what actions are required to mitigate the event." Maintenance practices, including testing and the administrative controls associated with these activities, do influence i
equipment conformance to design requirements.
Reviews conducted thus OC0290-0264-NLO4
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'far have concluded these activities are adeounte to ensure that
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equipment will function as intended.
Should the ongoing evaluations f
associated with the Generic Letter identify any concerns in this area, the appropriate procedures or practices will be revised.
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Generic Letter 88-14 Item #3 Request:
" 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 is safety-related components will perform as expected in accordance with i
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."
Consumers Power Company's F(bruary 20, 1989 Generic Letter 88-14 ltem #3
Response
"In 1984 an operational review of th instrument air system upon loss of air was conducted in preparation for the Refueling Outage during which the systetn was going to be removed from service for maintenance and modifications. This review was essential to ensure that all systems function as intended during this mode.
The results of this review were added as an attachment to the System Operating Procedure, SOP-27,
" Service and instrument Air System". The results were verified during the Refueling Outage activities and corrections / improvements were made.
A copy of this information is provided as Attachment 2 to this response."
"As a result of this Generic Letter, an additional review of the instrument air system design, including connected air pneumatic accumulators, has been completed. This review has concluded, by analysis, that the design is in accordance with the system's intended function."
"During the 1989 Refueling Outage, the instrument air system will again be removed from service for maintenance and air dryer replacement.
Should this evolution identify any discrepancies, appropriate changes to the system operating procedures will be made."
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"The plant's design basis for the instrument air system has always been considered non-safety related, and safety-related components supplies from instrument air are designed so that loss of air would place it in the position needed for assuring required safety functions. This was true for the original design, as well as for subsequent modifications."
NRC November 21, 1989 Request for Additional Information to Consumers Power Company's February 20, 1989 Response to Generic Letter 88-14 Item #3:
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"Your response did not address whether an analysis of current air operated component f ailure positions were perf ormed. Please verify that this analysis has been performed and that the failure positions are correct."
Consumers Power Company's Response to the November 20, 1989 Request for Additional Information to Consumers Power Company's February 20, 1989 Response to Genaric Letter 88-14 Item $3:
No formal analysis of safety-related air operated component failure positions were performed.
The intent of the operational review of the instrument air system conducted in 1984 was to establish that associated systems and components function as intended on loss of air to ensure that no safety functions needed during this mode of operation were jeopardized by removing the air system from service. Although no formal documentation of this effort was compiled, the results of this review vero added to the Service and instrument Air System Operating Procedure (S0p-27). A copy of this was provided with our February 20, 1989 letter. This review did in fact verifv air operated component failure positions in support of safety function performance.
During surveillance testing, components are manipulated to verify proper operation or actual position following manipulation.
Satisfactory completion of these manipulations are documented on the associated surveillance procedures which provides continuous feedback of system performance.
l In addition to the above and to the discussions provided in our February 20, 1989 response, engineering personnel are performing a review of the safety-related components / systems tied to the plant air system, their failure modes, and verification activities which will further ensure functional performance. At the completion of this effort a document file vill have been compiled which identifies the equipment analyzed, their failure positions, and the documentation supporting the verifica-tion of these positions.
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