ML20042E618

Updates 890406 Response to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Condition Rept Initiated to Address Issue to Drain Instrument Air Filter Regulators

ML20042E618
Person / Time
Site:	Clinton
Issue date:	04/13/1990
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, JSP-0271-90, JSP-271-90, U-601625, NUDOCS 9004260210
Download: ML20042E618 (5)

Text

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o U-601625 L30-90 (04 -13 )-LP  ;

SG.120 til/N0/8 POWER COMPANY ,

I

• cLmtoN rowta station, P.O. BOK 6M, OLWtDN. (LUNOIS $m?  ;

! JSP-0271-90 April 13, 1990  ;

I i

Docket No. 50-461 [

t Nuclear Regulatory Commission [

Document Control Desk ,

Washington, D.C. 20555  ;

Subject:

Clinton Power Station l i Supplemental Information for Response to Generic  ;

I Letter 88-14, " Instrument Air Supply System.  !

Problems Affectina Safetv-Related Eauinment" l

l

Dear Sir:

The purpose of this letter is to provido an update to [

an April 6, 1989, letter (U-601384), which submitted the j Illinois Power Company response to Generic Letter 88-14 i j regarding instrument air supply system problems. The ,

Illinois Power Corrective Action Task force, which was i established to verify root cause and. corrective action  !

adequacy of selected Clinton Power Station corrective action documents, identified that additional information should be l

provided on five commitments listed in the April 6, 1989 letter. These items and the additional information are, i listed in the attachment to this letter.  !

I hereby affirm that the information in this letter'is correct to the best of my. knowledge. I i

Sincerely yours,  ;

J S. Perry V ce Presi t '-

)

PGB/ cam ,

+

Attachment  :

cc NRC Region III, Regional Administrator i NRC Clinton Licensing Project Manager NRC Resident Office

/ f ,

k O' t Illinois Department of Nuclear Safety i V){_ ,

9004260210 900413 PDR ADOCK 05000461 p PDC >

Att hment t3  !

U 601625 Undated Canarie latter 88-14 Ca==itted Actions Committed Actions -

in Anril 6. 1989 Letter Reason for Undate l

1. ... Assigning instrument air This statement was true at dryer problems a higher

.the time the April 6, 1989, priority (page 1 of 4, Item letter was written.

I Response, paragraph 2). However, since that time, instrument ,

air (IA) MWRs concerning IA quality had not routinely been worked with a ,

high priority.

i Actions Emine Taken l During the week of March 5,1990, -

the need to work instrument air MWRs '

concerning IA quality with a high priority was re emphasized by

• station management to Operations and Maintenance personnel.

~

Reason for Update

2. ... adding procedure steps to The original review of the certain preventive maintenance PM activities for all the (PM) activities to specifically instrument air supplied ,

invoke the cleanliness control equipment did not identify procedure... (psge 1 of 4 all of the PM tasks needing ,

Item I Response, paragraph 2). cleanliness control procedure job ,

steps.

Actions Beine Taken  !

A condition report, which is the  ;

formal corrective action document '

for Clinton Power Station, was ,

, initiated to address the cleanliness .

control requirements for the PMs- l identified as needing such a requirement. The cleanliness control procedure jobsteps have been incorporated into the PMs that were ,

identified as needing cleanliness .

control requirements, j t

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k i

1 of 4

Attachment to U 601625 1ammon for Undate

3. . . . All three air dryers A Maintenance Work Request will be reworked shortly (NWR) was prepared and worked after the current refueling on all three air dryers during outage to improve their the May July 1989 period imme -

performance (page 1 of 4, diately following the refuel.

Item 1 Response, paragraph 3) ing outage. The work was successful in improving the system dew point, however, further improvement in dew point is needed.

It was also believed at that time that particulate sizes were not meeting specification based upon-meesurements at the discharge of the-dryers.

'6ctions Being Taken Several additional NWRs were written and are in the process of being worked to further improve the system dew point and address the problem of particulate size not meeting specification. This additional work includes sending some system piping off site to be chemically cleaned and repassified. This work on.the first air dryer is completed. The other two air dryers are expected to be similarly reworked by July 31, 1990, (depending on availability of parts). If the work on the air dryers does not result in the desired level of performance, an additional action plan will be developed to ensure that the instru-ment air system is brought into design specifications. During the process of investigating the. problem with particulate sizes, it was determined that the filter used to collect the particulate test-sample had loose particulate contamination (roughly 20 30 microns) before any instrument air was drawn through it.

A new sampling technique was used on-April 3, 1990, and showed the size of the instrument air particulate contamination was less than three.

microns. The initial results of this test shows that particulate contamination is not a problem as 2 of 4

Attachment t3 U.601625 was believed when the original response to Generic Letter 8814 was issued. An evaluation of the test.

ing technique is being performed.

tammon for Undata

4. ...A PM task has been All equipment requiring a initiated, approved and scheduled PN task was not identified for all equipment that required to have an assigned PM a PM task. (page 2 of 4, task. For example, the requirement Item II Respor.se, paragraph 1) to_ drain instrument air filter regulators whenever the' components they supply undergo maintenance was included in an administrative procedure but was not translated into a PM task.

Actiona Reine Takan A condition report has been ini.

tiated to address the issue to drain-the instrument air filter regulators. In addition, there are numerous vendor manual PNs that are, suggested, as opposed to . ,

recommended, but have not been implemented at CPS. These PNs were reviewed as part of GL 88 14 and a i decision was made to not implement them until additional operating and maintenance history was obtained.

After the work identified in ites three above is completed, these I

suggested PMs will be reviewed and implemented, if appropriate.

Reason for Update

5. N/A Item III of the Generic Letter required e.' Verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function...' Instances have been discovered that indicate instrument air design problems may still exist.

For example, Illinois Power recently-identified that the problem reported in Information Notice'88 24 is applicable to CPS.

• 3 of 4

, Att chsent t> i U 601625 l Action Reinn Taken l l

A Condition Report, 1 90 03 056. was  !

generated. Investigation has indiccted that some active safety. ,

related valves are operated by .;

solenoids which may not function as .!

designed in the event that the  ;

instrument air line pressure  ;

regulator failed to reduce -;

instrument air pressure. Corrective  ;

actions included replacing four such ,

solenoids during PO-3 and the  !

remaining solenoids after PO 3.' LER  ;

90 04 00 was issued on this topic. l

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