ML20043F251

Advises That Util 900129 Response to Generic Ltr 89-13, Svc Water Problems Affecting Safety-Related Equipment Acceptable.Expresses Concern Re Extent & Rate of Corrosion Found in Plant Svc Water Sys

ML20043F251
Person / Time
Site:	Limerick
Issue date:	06/06/1990
From:	Clark R Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-89-13, TAC-74020, TAC-74021, NUDOCS 9006140292
Download: ML20043F251 (5)

Text

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June 6, 1990

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Docket Nos. 50-352 and 50-353-Mr. George A. Hunger, Jr.

Director-Licensiag, MC 5-2A-5 Philadelphia Electric Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No. 195 Wayne Pennsylyania 19087-0195

SUBJECT:

GENERIC LETTER 89-13 " SERVICE WATER PROBLEMS AFFECTING

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SAFETY-RELATEDEQUIPMENT"(MPAL9-13,TACNOS. 74020,74021) 1 Generic Letter (GL) 89-13. " Service Water Problems Affecting Safety-Related Equipment" dated July 18, 1989 requested licensees and applicants to advise the NRC whether they had established programs to implement the recomendations L

of the letter er that they were pursuing an equally effective alternative course of action including schedules of plans for implementing the various actions. AsupplementtoGL89-13wasissuedApril4,1990containingthe questions and answers read into the transcripts during the workshops held in late November and early December 1989, including-responses to several questions L

I raised by Philadelphia Electric Company staff. You responded to GL 89-13 by letter dated January 29,1990.

(NUDOCSAccessionNo. 9002080367).

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With respect to recommended Action I, you stated that you will implement programs consistent with GL 89-13 for the Spray Pond and cooling tower basin

=and an alternative program for the intake structure inspections. We find these acceptable to address the issue of potential flow blockage as a result of biofouling.

To address recomended Action 11 you stated that you will conduct a test l

programto.erifythehsattransfercapabilitiesofsafety-relatedheatexchangers l-cooled by the Emergancy Service Water (ESW) and Residual Heat Removal Service Water (RHRSW) systems. You also stated that the total test programs will consist of an initial test program and a periodic retest program, with periodic L

test frequencies based upon previous test results to assure the equipment will L

-perform the intended safety functions during the interval between tests. You

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proposed an alternative method of testing the heat transfer capability for certain room unit coolers. Your proposed schedules for testing and test programs are acceptable.

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5 M'r. George A. Hunger, Jr. As you discussed in your responses, you have established a preventative maintenance program for the cooling tower basin, ESW and RHRSW system components including the ESW side of the diesel generator heat exchangers and the RHR pump and motor oil coolers. This arogram basically addresses recommended Action 111. You stated that tie existing PM programs will be l

reviewed and upgraded to include additional PM tasks, as necessary, for inspection and maintenance of system components and piping to ensure that corrosion, erosion, silting, and biofouling do not degrade the required performance of safety-related systems supplied by the ESW and RHRSW systems.

Considering the extent of corrosion in the ESW system, including evidence of mirobiologically induced corrosion (MIC), we will evaluate the acceptability of the augmented program in future site visits and inspections. Your present program and proposed actions does satisfy the intent of GL 89-13.

In response to recommended Action IV, you noted that system walkdowns and performance testing were recently completed for the ESW and RHRSW systems during the preoperational test programs conducted in 1984 for Unit I and 1988 for Unit 2.

The programs included review of system design and as-built configuration and testing to verify the systems' capability to perform in accordance with their licensing basis. Additional walkdowns will be performed to resolve discrepancies identified during the design baseline document review.

You also stated that an independent activity to confirm that the ESW and RHRSW systems will perform their intended functions in accordance with the licensing basis for LGS, including a review of single active component failures, will be completed as part of a Configuration Management design baseline document review of these systems which is scheduled to be completed in late 1990.

You also stated that you plan to conduct a Safety System l

Functional Inspection (SSFI) of the ESW system in 1990. Your proposed program represents a proactive approach to addressing this issue and is acceptable.

With respect to recommended Action V, you discussed your plans and schedule to confirm that the maintenance oractices, operating and emergency operating procedures, and training whic1 involve the ESW and RHRSW systems are adequate to ensure that safety-related equipment cooled by these systems will function as intended and that the opportunity for human error is minimized.

Your proposed action satisfactorily addresses this issue.

Our review has determined that you have satisfactorily responded to GL 89-13 and as a licensing issue, this is closed out. Since a number of proposed actions are not completed, you are requested to formally notify us when the proposed actions in your letter of January 29, 1990 are implemented.

I Mr. George A. Hunger, Jr..

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Aswehavediscussedinvariousmeetingsandinspectionreports(e.g.,

50-352/90-13 and 50-353/90-13 datedMay7,1990),weareconcernedaboutthe extent and rate of corrosion that has been found in the Limerick service water systems. The effectiveness of the proposed revised treatment programs, rodifications (e.g., Nod 5225) and other actions you plan to take to reduce the corrosion degradation in the service water systems will be the subject of future discussions with your staff.

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P char ark, Pr M Manager ect Di ectorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc: See next page S

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'Mr. George A. Hunger, Jr.

Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:

Troy B. Conner, Jr., Esquire Mr. Thomas Gerusky, Director Conner and Wetterhahn Bureau of Radiation Protection 1747 Pennsylvenia Ave., N.W.

PA Dept. of Environmental Resources Washington, D. C.

20006 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Mr. Rod Krich 52A-5 Philadelphia Electric Company Single Point of Contact 955 Chtsterbrook Boulevard P. O. Box 11880 Wayne, Pennsylvania 19087-5691 Harrisburg, Pennsylvania 17108-1880 Mr. Graham M. Leitch, Vice President Mr. Philip J. Duca Limerick Generating Station Support Manager Post Office Box A Limerick Generating Station Sanatoga, Pennsylvania 19464 P. O. Box A Mr. Marty J. McCormick, Jr.

Plan Manager Mr. Garrett Edwards Limerick Generating Station Superintendent-Technical P.O. Box A Limerick Generating Station Sanatoga, Pennsylvania 19464 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Larry Doerflein U.S. Nuclear Regulatory Commission Mr. Gil J. Madsen Region I Regulatory Engineer 475 Allendale Road Limerick Generating Station King of Prussia, PA 19406 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Thomas Kenny Senior Resident inspector US Nuclear Regulatory Commission P. O. Box 596 Pottstown, Pennsylvania 19464 Mr. John Doering ProjectManager Limerick Generating Station P. O. Box A Sanatoga, Pennsylvania 19464 Mr. Larry Hopkins Superintendent-0perations Limerick Generating Station P. O. Box A Sanatoga, Pennsylvania 19464

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Hr. George A. Hunger, Jr. As we have discussed in various meetings and inspection reports (e.g.,

50-352/90-13 and 50-353/90-13 dated May 7, 1990), we are concerned about the extent and rate of corrosion that has been found in the Limerick service water systems. The effectiveness of the proposed revised treatment programs, modifications (e.g., Mod 5225) and other actions you plan to take to reduce the corrosion degradation in the service water systems will be the subject of future discussions with your staff.

Sincerely, Original signed by R! chard J. Clark Richard J. Clark.. Project Manager Project Directorate 1-2 l

Division of Reactor Projects - 1/11 J

Office of Nuclear Reactor Regulation ec: See next page DISTRIBUTION w/ enclosures:

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