ML20085K227
| ML20085K227 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/18/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-13, GL-90-04, GL-90-4, NYN-91169, NUDOCS 9110300221 | |
| Download: ML20085K227 (7) | |
Text
4 NerHampshire Yh h
Ted C. Feigenbaum Preddent and j
Chief Execu6ve Officer N YN-91169 October 18, 1991 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Document Control Desh
References:
(a)
Facility Operating License No. FPF-86, Docket No. 50-443 (b)
NHY Letter NYN-90037 dated February 9,1990, " Response to Generic Letter 89-13,"
T. C. Feigenbaum to USNRC (c)
NHY Letter NYN-90138 dated July 13,1990, " Response to Generic Letter 90 04,"
T. C. Feigenb um to USNRC (d)
NHY Letter NYN-90176 dated September 24, 1990, " Supplementary Response to Generic Letter 80-13
- IL L. Drawbridge to USNRC
Subject:
Supplemental Response to Generic Letters 89-13 and 90-04 Gentlemen:
The NRC requestes in recommended actions IV and V of Generic Letter 89-13, confirmation that service water-systems will perform their intended function in accordance with the licensing basis for the plant. The NRC also requested confirmation that maintenance practices, operating procedures, emergency procedures and training involving service water systems are adequate to ensure tLat safety-related equiprnent caoled by service water will function as intended and that operators of this equipment will perform effectively. New Hampshire _ Yankee (NHY) initially responded to Generic Letter 89-13 in NYN-90037 dated February 9,1990 [ Reference (b)]. This initial response provided the requested confirmation for the Service Water and Cooling Tower Systems (the open cycle service water systems) at Seabrook Station. Supplement I to Generic Letter 89-13 clarified that recommended actions IV and V applied not only to cpen-cycl:: but also to closed-cycle cooling water systems which function to ransfer heat from safety-related structu s, systems and components to the ultimate 1 et.. sink. For Seabrook Station, the clarification of Supplement I had the effect of adding the Primary Component Cooling Water (PCCW) System to the scope of recommended actions IV and V.
New Hampshire Yankee committed, [ Reference (d)], to perform additional studies for the PCCW System responsive to recommended actions IV and V of Generic Letter 89-13 prior to restart follov'ing the first refueling outage.
9110300221 911Q18 PDR ADOCK 05000443 P
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- New Hampshire Yonkee Division of Public Service Company of New Hampshire I
P.O. Box 300
- Seobrook, NH 03874
- Telephone (603) 474 9521 g gO
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- United states Nucicht Regulatory Cominission October 18, 1991 Allention:
Docuinent Control Desk Page two f
Since service water systern issues were the subject of Ocnerie Safety issue (GSI) No.
$1, the corntnitmrnt to complete the sequested confistnational studies for the PCCW System was also identitled in the N11Y tesponse to Generle 1,etter 90 04, (Reference (c)), as an oatslanding item affecting full innplementation of G(
at Seabrook Station.
This letter repe % completion of the adu.,mnal confirmational studies for the Seabrook Station PCCW Syr, tem. New llampshire Yankee I as confirmed that.the PCCW System will perform its intended function in accordance with the licensing batis for the plant.
New flampshlte Yankee has also confirmed that Seabrook Station maintenance practice.,
i operating and emergency procedures and training involving the PCCW System are adequate te ensure that safety related equipmen; cooled by the PCCW System will function as intended, and that operators of the cquipment will perform effectivcly. Additional details-
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are provided in tInclosure 1, New llampshire tankee has completed all one time commitments associated with Ocneric Letter 8913. Completiot. of these cornmitments together with the ongoing programs associated with service water systems described in References (b) and (d) :mi herein result in full implementation of OSI $1 at Scribrook Station, if you have any questions on this matter, please contact Mr, Geoffrey Kingston at (60,5) 474 9521, Extendon 3371, Very truly yours,
&.;. W y m b Ted C. Felg(nbaum Enclosure TCF:GK STATE Ofg!,iUW ll AMPSlillUi Rockingham, ss.
October 18, 1991 Then pes.mily appeared before me, the above named Ted C. Folgenbaum, being duly sworn, did stoic that -he is President & Chief Executive. Officer of the New ilampshire Yankee Division of Public Service Company of New llampshire, that he in duly authoriecd
- to execute and-file the foregoing information in the name and - on the behalf of New Itampr, hire Yankee Division of the Public Scryice Company and that the statements therein are true to the best of his knowledge and belief.
W I k & Y lfb M.]
t Tracy AGDeCredico, Notary Public My Commission Expires: October 3,1995 L
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United States Nuclear Regulatory Commission October 18, 1991 Attention:
Document Control Desk Page three ec:
hir. Thomas T. hiartin Regional Administrator United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, F A 19406 hir Gordon !!. Edison, St. Project hinnager Project Directorate 13 Division of Reactor Projects U.S. Nuclear Regulatory Cummission WaAhington, DC 20555 hit. Noel Dudley NRC Senior Resident inspector P.O. Ilox 1149 Seabrook, Nil 03874
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New llampshine Yankee October 18,1991 i
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t ENCL,OSURE -1 TO Ni H 91169 FUI'Pl t! MENTAL RESPOf!SE TO NI(C IIECOMMl!NDED ACTIONS IV AND V DJMUEjlBIC LETfER H913 REGARDING Tilli Sl!AllROOK' STATION.
PRIM AltY COW'QNENT COOLIFO WATl!R (PCCW) SYSTEM _
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SUPPLEME,NTAl. RESPONSE TO NRC RECOMMENDED ACTIONS IV AFD V OF GENERIC LETTER 89-13 REG ARDING Tile SEAURCOK STATION PRIM ARY COMPONENT CODI,1NO WATER (PCCW) SYSTEM NRC RECOMMUNDI!D ACTION IV:
Confirm that the service water system will perform its intended function in accordance with the licensing basis for the plant. Reconstitution of the design basis of the system is not intended. This confirmation should include a review of the ability to perform required safety functions in the event of failure of a single active component. To ensure that the an built system is in accordance with the appropriate licensing basis documentation, this confirmation
-should include recent (within the past two years) system walk down inspections.
This confirmation should be completed before plant startup following tha first refueling outage beginning nine months or more after the date of this letter. Results should be documented and retained in appropriate plant records.
[Supplernent 1 to Generic Letter 8913 clarified that this recommended action pertained to both closed cycle and open cycle cooling water systems which transfer heat from safety.
related structures, systems and components to the ultimate heat sink.]
NHY RESPONSE:
The licensing basis of the PCCW System is established in the Seabrook Station Updated Final Safety Analysis Report (FSAR), Section 9.2.2.
New llampshire Yankee has confirmed that the PCCW System will perforra la intended function in accordance with the licensing basis for the plant. This confirmation is based upon the results of preoperational testing, a failure analysis and an engineering review.
Pir. operational testing has demonstrated the ability of the PCCW System to supply flow rates exceeding those required to fulfill its safety functions.
A failure analysis of the PCCW System and its components is presented in FSAR Section
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9.2.2.3.d and Table 9.2-9.
This analysis demonstrates that single failure design criteria have been met.
An engineering review of the PCCW System was performed in 1991. The engineering review compared the as built system configuration as shown in the Seabrook Station Piping and Instrumentation Drawings (P&lDs) to the configuration described in the FSAR. The' as-built system configuration was also verified by a system walkdown inspection.
The-engineering review verified that the as built configuration of the PCCW System as shown on P&lDs was--.as described in the FSAR and as observed during the sy6 tem walkdown inspection.
Outstanding design modifications pertaining to the PCCW System were evaluated to determine
?' any of these modifications were required to enable the system to fulfill its safety functions, During the current refueling outage, NHY replaced the tubes and applied a protective coating to the tubesheet assembly and tube ends of *>oth PCCW heat exchangers.
Since the replacement tubes are essentially equivalent to the or_iginal t 'ics, this modification did not 1
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result in a change to PCCW heat exchanger design. Therefore, this rnodification did not affect the ability of the PCCW heat exchangers to perform their safety function.
Other outstanding design modifications were evaluated to be performance enhancements and thus not required to enable the PCCW system to perform its safety functions.
NRC RECOMMENDFD ACTION V:
Confirm that maintenance practices, operating and emergency procedures, and training that involves the service water system are adequate to ensure that safety related equipment cooled i-by the scivice water system will function as intended and that operators of _ this equipment will perform effectively.
This confirmation should include recent (within the past 2 years) reviews of practices, procedurer, and training rnodules. The intent of this action is to reduce human errors in the operation, repair, and maintenance of the service water system.
This confirmation should be completed before plant startup following the first refueling outage beginning 9 months or more after 11e date of this letter.
Results should be documented and retained in appropriate plant records, fSupplement I to Generic Letter 8913 clarified that this recommended action pertained to both closed cycle and open. cycle cooling water systems which transfer heat from safety-related-structures, systems and components to the ultimate heat sink.)
NHY RESPONSE 1 t.
New llampshire Yankee has performed an evaluation to confirm that Seabrook Station maintenance practices, operating procedures, emergency procedures, and training impacting the PCCW System are adequate to ensure that safety related equipment cooled by the PCCW System will _ function as intended and that operators of this equipment will perform effectively. -The evaluator ___ interviewed NHY personnel and reviewed pertinent-documents--
associated with PCCW System maintenance, operation and training. The evaluation was perfortred with an awareness of human performance errors which have been reported within the industry as detailed in NUREG 1275. Volume 3, ' Operating Experience Feedback Report Service Water System Failures and Degradations.' The reported industry errors include mispositioned and mislabeled valves, operation of the wrong component, inadvertent component isolation, mispositioned circuit breakers and switches, and inadequate installation of parts during or following maintenance activities. An objective of the evaluation was to determine whether or not these types of human performance errors were occurrin g to a significant degree at Seabrook Station.
The' evaluator reviewed Seabrook Station documents pertaining to the PCCW System including preventive and corrective.. maintenance records, system performance reports, operating-and surveillance procedures, training records and reports for the past two years of industry and in house operating experience applicable to the PCCW System. Discussions with appropriate NHY personnel were conducted to determine system status and current concerns.
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The evaluation determined that sound maintenance practices and procedures applicable to
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the PCCW System have been established, that the PCCW System is operated, maintained and tested in accordance with properly reviewed and approved procedures and that the amount of ' preventive maintenance, corrective maintenance and post maintenance testing being 2
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of inaintenance and it6 ting activitic6 allecting the PCCW Sy6 tem and advisc6 innin t e n a n t e pctsonnel as needed, PCCW Systrin water chttuistry contiol using hydsatine as a wtro6 ion inhibitor wa6 deterinined to effe(thelv control systern ph and dinohrd onyren concentration.
An appropriate level of PCCW System water sainple analysin wn6 vrailled.
Approved procedures wese vesilied to clicctively implement Technical Specification 6 seguirement6 applienble to the PCCW System. The level of per6onnel tinining on the PCCW System wa6 judged to be adeyunte, Iteview of in house operating experience eventh involving the l'CCW System determined that these events, were Icw in number, minor in significance, not indicative of progsainmatie of trainine deliticurie*. and were followed up with appropriate costettive action.
The review noted that a significant opriational problem anotinted with the PCCW Systern was tube deyradation resulting loom sevelat probable cronion/corronlon mechanisme, affecting the $ctvite water side of the heat euhnngers.
't hi6 problem has been thoroughly evalunted and documented. shost terrn corrective actions including tube plugging and sierving were implemented to niaintain PCCW heat exchanger integelty during the first operating c ycle.
A modification completed during the current refueling outage consisted of au cuentially "in-kind" replacennent of the tuben in both PCCW bent exchangers and the application of a protective conting to the tubrShret aucmbly and tube endt.. The integrity of tht repintement tubra will be monitored by periodic eddy current examination with a frequency determined by operating experience. 1(coononendition6 for long term corrective actions to reduce f uture degradation of PCCW beat cubanger tubes are under evnluntion.
A detuited report of the review suinmavired above in maintained in Senbiook Station record 6.
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