ML20082A372
| ML20082A372 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/08/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, W3F1-91-0434, W3F1-91-434, NUDOCS 9107100299 | |
| Download: ML20082A372 (4) | |
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Entergy Operations,Inc.
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ft F. Durski W3F 1-91-0434 A4.05 QA July 8, 1991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 4
Generic Letter 88-14 Instrument Air Supply System Problems Affecting Safety-Related Equipment Centlemen:
The purpose of this letter is to provide information on the status of Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment," at Waterford 3. In addition to confirming that all required testing is complete as requhed by the generic letter, a change in the scope of the test program from that described in the original response will be described.
The NRC issued Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment," on August 8,1988. The purpose of this generic letter was to request that licensees review NUREG-1275, Volume 2, and perform a design and operations verification of their instrument air system. This verification was to include:
1.
Verification by test that actual instrument air quality is consistent with the manufacturer's recommendations for individual components served; 2.
Verification that maintenance practices, emergency procedures, and training are adequate to ensure that safety-related equipment will function as intended on a loss of instrument air; and a
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Verification that the design of the entire instrument air system including air or other pneumatic av umulators is in accordance with its intended function, including verification by test that air-operated safety-related components will perform as expected in accordance with all design-basis events, including a loss of the normalinstrument 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.
Louisiana Power and Light letter W3P89-0028, dated February 21, 1989, provided an overall evaluation of these requirements and described plans for future actions to confirm the adequacy of the Waterford 3 instrument air system.
With regard to item (1) of the generic letter, Louisiana Power and Light letter W3P89-3016, dated April 28, 1989, provided a report of a satisfactory test of Waterford 3 instrument air quality. In addition, an instrument air sampling procedure, CE-002-032, " Maintaining Instrument Air System," was instituted to provide for periodic monitoring of instrument air system quality. These actions, along with the evaluation provided in W3P89-0028, satisfy the requirements of item (1) of the generic letter.
The evaluation required by item (2) of the generic letter was documented in section 11 of Louisiana Power and Light letter W3P89-0028. Several enhancements were planned pending satisfactory evaluations. All of the necessary enhancements and changes described in section 11 of the original response are now complete.
Section III of W3P89-0028 documented the Waterford 3 response to item (3) of the generic letter. With regard to valves with air accumulators, the Waterford 3 response indicated that concerns existed regarding the design of safety injection recirculation sump outlet valves SI-602A and SI-602B but, pending further evaluation of those two accumulators, no additional accumulator testing was planned.
Calculations eventually confirmed the suspicion that the accumulators for SI-602A&B were undersized. The two accumulators were ultimately replaced with motor operators during Refueling Outage (RFO) 4. This particular condition is described in detailin Waterford 3 Licensee Event Report 89-007-01.
The resolution of the concern about SI-602A&B highlighted a shortcoming in the Waterford response to the generic letter: Namely, that the analysis described in the response was hampered by a lack of available design basis information This information was needed to completely evaluate accumulator sizing calculations.
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W3F1-91-0434 Generic Letter 88-14 Instrument Air Supply System Problems Affecting Safety-Related Equipment
- Page 3 July 8, 1991 In order to address this lack of information, formulation of a Design Basis Document (DBD) was initiated. W3-DBD-014, " Safety-Related, Air Operated Valves," was issued March 21, 1990. This document specifically describes the design basis of the air _ and nitrogen accumulators and provides information necessary to establish leak rate requirements.
The DBD differed from the generic letter response in that it clearly indicated that somi air accumulator testing was needed to assure the proper function of the asscciated valves. Nine instrument air accumulators were identified that may be needed to supply motive air to enable their associated valves to perform a safety function. As a consequence, the accumulators were incorporated in the test program to satisfy the requirements of item (3) of the generic letter and tested satisfactorily during RFO4.
Another outgrowth of the DBD effort was a revision to Off-Normal Procedure OP-
. 901-038, " Instrument Air Malfunction." The proceduro was revised to ensure that operator action is taken as necessary to preserve the various design bases described in the DBD. Minimum pressures are provided for each accumulator with the required action to be taken to address degraded system capabilities.
Furthermore, in recognition of its importance to continued safe, reliable plant operation, the instrument air system has been added to the Waterford 3 Long -
Term Reliability Program (LTRP)'.
The LTRP is intended to track and prioritize significant recurring problems affecting nuclear safety, availability, reliability, and performance of the plant and its systems. Schedules describing plans for improvements in tracked systems
- are periodically reviewed by management and are included in the quarterly plant trending reports. As such, items tracked by the LTRP receive high level management attention. Including the instrument air system in this program is a significant indicator of the importance that Waterford 3 attaches to the system's reliability. it further reflects the intention-that improvements to the instrument air system will continue to receive high priority in the allocation of resources.
In _ addition to the accumulator testing completed during RF04, all of the changes and evaluations that were committed to in Section III of the original response are now complete.
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W3F1-01-0434 Generic Letten 88-14 Instrument Air Supply System Problems Affecting Safety-Related Equipment Page 4 July 8,=1991 If you have any questions concerning this response, please contact T.W. Gates at (504) 739-6697.
.Very truly yours, pw RFB/TWG/ssf cc:
R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR E.L. Blake R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office l'
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