ML20086M843
| ML20086M843 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/15/1984 |
| From: | Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8402170117 | |
| Download: ML20086M843 (7) | |
Text
e PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101
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EDW ARD G. B AU ER. J R.
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g oanns at counssk EUGENF J. BR ADLEY assoceave same AAh CouNsEb DON ALD SLANMEN RUDOLPH A. CHILLEMS E. C. K: R K H A LL T. H. M AMER CO RNELL
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February 15, 1984 EDW ARD J. CULLEN J R.
THOM AS H. MILLER.J R.
IR ENE A. McKEN N A assesvant couwssk Mr. A.
Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Limerick Generating Station, Units 1 & 2 Instrument Air Cleanliness
REFERENCES:
Telecon between J.
Ridgely (NRC),
J.
T. Robb (PECO) and D.
R.
Helwig (PECO) on 1/16/84
Dear Mr. Schwencer:
The attached FSAR page changes modify Section 14.2 and the responses to NRC RAI 410.73 and 410.74 as discussed in the reference telecon concerning instrument air cleanliness.
The information contained on these draft FSAR page changes will be incorporated into the FSAR, exactly as it appears on the attachments, in the revision scheduled for February 1984.
Sincerely, Eug.ne
. Irradley JHA/gra/020184145 Attachment Copy to:
See Attached Service List
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D 8402170117 840215 O
PDR ADOCK 05000352 i
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cc: Judga Lawrence Brenner (w/o enclonuro)
Judge Peter A. Morris (w/o enclosure)
Judge Richard F. Cole (w/o enclosure)
Troy B. Conner, Jr., Esq.
(w/o enclosure)
Ann P. Hodgdon, Esq.
(w/o enclosure)
Mr. Frank R. Romano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Mr. Marvin I. Lewis (w/o enclosure)
Charles W. Elliot, Esq.
(w/o enclosure)
Zori G. Forkin, Esq.
(w/o enclosure)
Mr. Thomas Gerusky (w/o enclosure)
Director, Penna. Emergency (w/o enclosure)
Management Agency Mr. Steven P. Ilcrshey (w/o encionure)
Angus Love, Esq.
(w/o enclosure)
Mr. Joseph H. White, III (w/o enclosure)
David Wersen, Esq.
(w/o enclosure) l<obert J.
Sugarman, Est g.
(w/o enelaenurv)
Spence W.
Perry, Esq.
(w/o enclosure)
Jay M. Gutierrez, Esq.
(w/o enclosure)
Atomic Safety & Licensing (w/o enclosure)
Appeal Board Atomic Safety & Licensing (w/o enclosure)
Board Panel Docket & Service Section (w/o enclosure)
Martha W.
Bush, 129
'(w/o encionuie)
James Wiggins (w/ enclosure)
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- 1. 5tl.1 Preoperational and Initial Startup Testino g Feedwater and Condensate Systems for Boilino Water Reactor Power Plants (Revision 1, January 1977).
1.68.2 Initial Startup Test Procram to Demonstrate Remote Shutdown Capability for Water 2 ooled Nuclear Power Plants (January 1977).
1.68.3 Preoperational Testino of Instrument d Control Air Systems (April 1982).
CCMPLIN CE-L5 DeMot45TRKTE o. 6y bcesf-AT mat T66T' 9QCE.odRES P4 8 1, F-83. I, M o P-t004 1.70 Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (NoWr.ber 1978).
1.80 Preoperational Testino g Instrument Air Systems (June 1974).
1.104 Overhead Crane Handlino Systems for Nuclear Power Plants (February, 1976).
Overhead crane testing exceptions are as outlined in Section 9.1.5.
1.108 Periodic Testino of Diesel Generators Used as Onsite Electric Power Systems & Nuclear Power Plants (Rev.
1, August 1977).
Testing of the diesel generators is discussed in Section 8.1.6.1.20.
1.140 Desion Testino and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Licht-Water-Cooled Nuclear Power Plants (Rev. E October 1979) i 14.2-19
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QUESTION 410.73 (Section 9.3.1)
(a) Verify that every instrument air system meets the requirements of ANSI MC11.1-1976. For each requirement not currently met, justify the deviation or provide a discussion of design changes which will bring each system into f ull compliance with ANSI MC11.1-1976 req uirements.
(b) Verify that all instrument air compressors are non-oil lubricated (dry).
(c) Verify conformance with the guidelines of Regulatory Guide 1.68.3 3Preoperational Testing of Instrument Air Systems" f or each instrument air system.
I
RESPONSE
(a) The instrument. air system and primary containment instrument gas system meet the requirements of ANSI MC11.1-1976 with the exception that allowable particulate size has been determined based on equipment supplier recommendations and engineering analysis.
Most safety related instrument air or gas users have been verified to be provided with an appropriately sized local, in-line, filter connected to the user with copper or stainless steel tubing.
Particulate limits for safety related components not provided with individual filters (M SIV 's, ADS SRV 's, CRD HCU 's) have been investigated.
After consultation with the equipment suppliers and review of applicable operatine experiences, it has been determined that a limit of no I
f visible particulate will assure long term, reliable operation of each component.
Documentation confirming this assessment has been obtained from the equipment i
suppliers.
Although visible particulate is greater than 20 micron, a measured value of less than 20 microns will be verified to exist at the following locations during an air blow of at least one hour duration:
each MSIV operator manifold (8 total) each ADS SRV-operator (5 total) each CRD HCU air supply header (4 total)
(b) The instrument air system and primary containment instrument gas system use non-oil lubricated air compressors.
(c) The safety-rela'ted portions of the instrument air system and primary containment instrument ges system are tested
in accordance with Segulatory Guide 1.68.3, as stated in-Section 14. 2.,
Conpliance to Reg. Guide Position C.11.
is demonstrated by the following program:
1)
Verification that the specific. type or model of safety related solenoid valves and pneumatic valve actuators (PSAR Table 9.3-4) have been tested by the equipment suppliers for the maximum supply system pressure resultino from credible system failures.
i 2)
For safety-related equipment that has not-been tested by the equipment supplier, the equipment will be tested on-site at the maximum supply system p essure resulting from credible system failures in order.to ensure there will be no loss'of operability.
3)
Safety-related equipment that has been: tested by the equipment supplier, but a) is rated below the maximum credible supply system pressure and/or b) fails the test in (2) above will be replaced by equipment with a higher service pressure rating or 4
will be provided with appropriate overpressure protection devices.
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CUESTION 410.74 (Section 9.3.1)
.ts' u Provide a discussion of the maintenance and periodic testing program for each instrument air system to assure compliance with the requirements of ANSI MC11.1-1976.
Specify the maximum time between testing of the compressed air system in the discussion.
t
RESPONSE
4 Limerick is in compliance with the requirements of ANSI MC11.1-1976 as discussed in the response to Question 410.73.
4 1
The primary containment instrument gas (PCIG) system is
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shown in Figure 9.3-2.
The refrigeration and desiccant I
dryers employed in this system lower the dew point to -400F at 100 psig.
The need for desiccant replacement is indicated when the local visual moisture indicating gel turns from blue to pink.
The quality of air at individual safety-related PClG users will be periodically verified to l
meet the dew point and oil content quality specified in ANSI MC11.1-1976.
A random sample of points of use will bo tested once each refueling cycle.
The filters provided at the outlet of the PCIG desiccant dryers are designed to 3
j remove particles 3 microns and larger.
These filter elements will be inspected and replaced at least on an j
annual basis.
Safety-related PCIG users not provided with individual in-line filters, like inboard MSIV's and ADS SRV's, will be periodically verified to meet the particulate i
limits discussed in response to Question 410.73.
A randon i
sample of points of use will be tested once each refueling cycle.
The instrument air system is shown in Figure 9.3-1.
In addition to supplying instrument air to various plant equipment, this system also serves as a backup to the primary, containment instrument gas system.
Filters capable of providing filtration of particulate greater than 3.0 microns will be provided at the interconnection of the PCIG system with the instrument air system.
The instrument air system is provided with desiccant dryers that dry the gas to I
a -40'F dew point at 105 psig and filters that remove 100%
of all' particles larger than 0.9 micron in diameter.
The
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filters will be switched to the parallel set'of filters every six months and the elements will be replaced yearly.
The need for desiccant replacement is indicated when the.
local visual moisture indicating gel turns from blue to pink.
In addition, excessive dryer outlet moisture is i
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The l
. quality of air at individual safety-related instrument air
' users will be periodically verified to meet the dew point
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and oil content quality specified in ANSI MC11.1-1976.
Periodically, particulate levels will be veritied to be less than the limits discussed in response to Question 410.73.
A l
random sample of points of use will be tested once each ref ueling cycle.
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