ML20198E860
| ML20198E860 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/01/1997 |
| From: | Eric Simpson Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-13, LR-N97411, NUDOCS 9708110038 | |
| Download: ML20198E860 (4) | |
Text
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Electne and Gas Compa'y E. C. Simpson Public Service E tric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 00038 009 439-1700 so u. n.-,u..
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AUG 1 1997 LR-N97411 i
United States Nuclear Regulatory Commission Document Control Desk Washington,' DC 20555 UPDATE ON-THE IMPLEMENTATION OF COMMITMENTS MADE IN RESPONSE TO GENERIC LETTER 89-13 HOPE CREEK-GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:
On July 18, 1989, the NRC issued Generic 89-13, " Service Water System Problems Affecting Safety-Related Equipment," which required licensees to submit information concerning:
- 1) how their service water system satisfies regulatory requirements; and
- 2) how the safety functions of their service water systems are being met.
On January 26, 1990, Public Service Electric & Gas Company- (PSE&G). provided Hope Creek's response to Generic Letter 89-13 via letter NLR-N90021.
In PSE&G's letter, Hope Creek had committed, in part, to:
- 1) performing periodic SACS heat exchanger performance testing to verify heat exchanger capability; and 2) conduct a review of the service water system's ability _to perform as required in the event of a single active component failure by March, 1991.
As a result of a Service Water Operational Performance Inspection (SWSOPI) recently conducted at Hope Creek, PSE&G identified that these Generic Letter 89-13 commitments need to be revised.
This letter provides an update on the status of these commitment revisions as described separately in the paragraphs below.
Heat Exchanger Performance Testing The commitment in Generic Letter 89-13 response required periodic SACS heat exchanger perfarmance testing to verify heat exchanger capability and was to follow the guidelines.in EPRI's, " Heat Exchanger Performance Monitoring Guidelines" (as modified in 1
PSE&G's letter LR-N970218,- dated April 22, 1997).
Recent assessments of Generic Letter 89-13 activities (including SWSOPI) determined-that the heat. exchanger test procedure did not follow
\\O, the EPRI guidance and that certain test assumptions could not be i
supported by engineering calculations.
As a result, Hope Creek
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b-[0 9708110038 970001 PDR ADOCK 05000354 8
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i AUG 1 1997 D'ocument Control Desk LR*N97411 concluded that the EPRI heat exchanger performance flow monitoring requirements could not be met without completing major system piping changes to accommodate fluid flow measurement.
Options for corrective actions were reviewed by Hope Creek and a revision to the Generic Letter 89-13 heat exchanger program was developed.
Specifically, the heat exchanger program was revised to consist of inspection and cleaning rather than performance testing (similar to programs at Browns Ferry and Susquehanna).
The SACS Heat exchangers have been inspected and eddy current tested every 36 months since 1988.
The only heat exchanger that was not inspected in 1996 was the B1 heat exchanger, which was inspected in April of 1994.
Inspections in 1996 showed that the tubes in all the heat exchangers were clean and free of tube fouling.
These inspection results, along with the heat exchanger performance between inspection cycles (i.e.,
typical delta T's for flow and load conditions), indicate that fouling has not been an issue at Hope Creek.
The primary reason for this good condition is the chlorinating program that has successfully kept biological growth in check.
The most recent inspection of a SACS heat exchanger occurred in October, 1996 after 8 months of service since its last cleaning.
This inspection was performed to evaluate the consequences of a service water strainer failure.
The inspection showed minor debris, but the tubes were clean when the tube sheet was cleared of debris.
The as found condition was consistent with our expectations and past inspections.
The new commitment for heat exchanger performance monitoring is as follows:
"The heat exchanger testing program at Hope Crcek follows the alternate action for frequent regular maintenance provided in Generic Letter 89-13, Enclosure 2.
During the next two refueling outages (RFO7 and RF08) all four Safety Auxillaries Cooling System (SACS) heat exchangers will be inspected, cleaned and a baseline tube-side pressure drop recorded.
Between refueling outages, service water pressure drop across the heat exchanger will be routinely monitored to detect the onset of macrofouling.
Based on the results from these inspections, an appropriate frequency for future SACS heat exchanger inspections will be established."
Single Failure Analysis This commitment in the Generic Letter 89-13 response concerned the review and confirmation of the service water system's ability to perform its required safety functions in the event of a single 95 4933
AUG 1 1997 Document Control Desk LR-N97411 active failure.
In that letter, PSE&G stated that the Hope Creek service water system met the design criteria in effect at the time the plant was designed and that subsequent modifications were reviewed for their impact on the design, including single active failures.
A commitment to perform a confirmational review of the Hope Creek service water system by March, 1991 was also documented in that Generic Letter 83-13 response.
- However, during a self assessment of Hope Creek's Generic Letter 89-13 implementation, formal documentation of this confirmational review was not found and verification that this commitment was satisfied could not be made.
On July 31, 1997, PSE&G completed a service water system failure modes and effects analysis, which satisfies the commitment made in Hope Creek's response to Generic Letter 89-13.
Should you have any questions regarding this transmittal, we will be pleased to discuss them with you.
Sincere y,
/
[d'yn1 95 4933
)
AUG 1 1997
.Document Control Desk LR-N97411 C
Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
D. Jaffe, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 l
Trenton, NJ 08625
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