ML20245L435
| ML20245L435 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/29/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-14, NLR-N89119, NUDOCS 8907050493 | |
| Download: ML20245L435 (10) | |
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i Public Service i
Dectric and Gas Company Shven E. Mittenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Veto Pfumdent and Cheel Nuclear Ofhcor JUN 2 91989 i
NLR-N89119 United States Nuclear Regulatory Commission i
Document Control Desk l
Washington, DC 20555 Gentlemen:
RESPONSE TO GENERIC LETTER 88-14, INSTRUMENT AIR SYSTEM PROBLEMS i
AFFECTING SAFETY-RELATED EQUIPMENT llOPE CREEK GENERATING STATION DOCKET NO. 50-354 l
Public Service Electric and Gas Company (PSE&G) hereby submits,
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in Attachment 1 of this transmittal, our response to the subject l
Generic Letter.
As documented in our transmittal, NLR-N88188, l
dated December 6, 1988, an extension, to June 30, 1989, of the original February 8, 1989 due date was granted to permit the integration of a scheduled Safety System Functional Review into this response.
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Should you have any questions regarding this response, we will be pleased to discuss them with you.
8907050493 890629 Sincerely,
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DR ADOCK 05000354 7
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PNU f.s. e. u w ;l n i'
Affidavit Attachment C
Mr. C. Y.
Shiraki Licensing Project Manager Mr. G.
W.
Meyer Senior Resident Inspector Mr.
W. T.
Russell, Administrator Region I Mr. K. Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering j
REF: NLR-N89119 i
STATE OF NEW JERSEY
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COUNTY OF SALEM
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1 Thomas M. Crimmins, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set j
forth in our letter dated JUN 2 9 M concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
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Subscribed and Sworn to before me this J T day of
, 1989 i
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Notary kublic o bNew Jersey ELIZABETH J. KIDD Notary Public of New Jersey l
My Dommission Expires April 25,1940 j
My Commission expires on Y!Af!/ffd I
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ATTACHMENT 1 Response to NRC Generic Letter 88-14 Hope Creek Generating Station l
NRC Generic Letter (GL) 88-14 requests.that licensees: perform.
a design and operations verification of instrument air systems at.their respective nuclear facilities. This' request resulted from an NRC review of' operating plant events attributable to air system. failures.
!'l At Hope Creek, plant systems applicable to the requirements of GL 88-14 include the Instrument? Air System, (including the
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Service Air Compressors) and the Primary Containment, j
Instrument; Gas System.
In support of'PSE&Gs response to GL L
88-14, a detailed Safety System Functional Review (SSFR) of the Hope Creek Generating Station Pneumatic systems'was I
recently completed.
The SSFR was. structured to encompass.
many of the aspects included in.the NRC's own Safety. System Functional Inspection process and'to address those specific-requirements delineated in GL 88-14.
The detailed results of' 1
the review form the basis for PSE&Gs response-to GL 88-14 for those applicable systems.
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Generic Letter (GL) 88-14 identifies fou' (4) areas to be evaluated and requires that a plant specific response be submitted in each area. Each of the areas to be addressed are j
described below along with the PSE&G response. An
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identification of outstanding tests and the schedule for
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their completion are also included.
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Item __1 i
Verification by test that actual instrument air quality is consistent with the manufacturer's recommendations-for i
. individual components served.
k PSE&G_ Response l
Air quality is defined in the Instrument Society of America l
Standard S7.3 to consist of four (4) elements including Dew Point (at line' pressure), Particle Size, Oil Content, and Contaminants. The Standard specifies limits for each of:the l
above elements. At Hope Creek, commitments and exceptions to i
this Standard are outlined in UFSAR Section 9.3.1.2 for the
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Instrument Air System and UFSAR Section 9.3.6.4 for the Primary Containment Instrument Gas System (PCIGS).
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c-Rasponee'to Gantric Letter 88-14 The current air quality program consists of the following:
1)
Dew-Point __ Testing Dew Point Testing is performed on the Instrument Air' System using~ Hope. Creek preventative maintenance procedures on a quarterly basis.. Dew Point Testing has been performed on the PCIGS using Hope Creek preventative maintenance procedures _on an annual-basis. The frequency of this activity has beenl changed to quarterly to conform with UFSAR commitments. Review of the. latest results of the preventative: maintenance procedures indicate that ISA S7.3 for Dew' Point is being met.
2)
Particle Size Testin.gf PSE&G requirements for Particle Size Testing vary from ISA S7.3. These requirements are based upon equipment manufacturer cleanliness recommendations'for safety-related components supplied by Instrument Air and the PCIGS. These recommendations, whien were' solicited and received _by PSE&G during startup in 1986, and which-state that a particle size of 50 microns or smaller is acceptable for the operation of the equipment, are currently contained in.the UFSAR for Instrument Air and will be incorporated in that document for PCIGS.
Satisfactory Particle Size Testing was performed on PCIGS previously during plant startup'in 1986.
Satisfactory Particle Size Testing for'the Instrument Air System was performed in June 1989. The next scheduled testing _for the PCIGS is scheduled for the Refuel Outage in September.
The frequency for this testing is every 18 months.
3)
Oil _ Cont _e_n_t ___ (Hydrocarbon) __ Tes ting Oil Content (Hydrocarbon) Testing was satisfactorily performed on PCIGS during plant startup in 1986.
Testing for the Instrument Air System was performed satisfactorily in June 1989.
The results of those tests satisfy the minimum requirements of ISA S7.3.
It should be noted that the small amount of oil found in the Instrument Air System is a natural result-of oil leakage from the two centrifugal type air compressors used to supply Instrument Air. Since the UFSAR currently specifies oil-free compressors for the Instrument Air System, a change will be implemented to indicate that the compressors used will. minimize the introduction of oil into the system.
Additionally, the UFSAR will be changed to reflect that the oil testing will be done every 18 months, concurrently with the particle testing, instead of every 3 months.
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f' Roeponoc-to G:ncric Letter'88-14 Jl The next testing for the PCIGS is scheduled for the Refuel Outage in September.
The frequency for this testing is every 18 months.
4)
Con.taminant_ Testing Contaminant Testina was satisfactorily performed on PCIGS during plant startup in 1986. Testing for the Instrument Air System was performed satisfactorily in June 1989. The results of these tests satisfy the
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mLnimum requirements of ISA S7.3.
Testing for the PCIGS is scheduled for the. Refuel Outace in September.
The frequency for this testing is every 18 months.
The determination made by PSE&G in regard to satisfying the requirements of NRC Generic Letter 88-14, Item 1, for the above mentioned elements of air quality testing is as follows:
1)
Current Dew Point Testing on the Instrument Air System.
1 and PCIGS satisfies the requirements for Dew Point
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Testing in accordance with the UFSAR and ISA S7.3.
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Current Particle Size Testing on the Instrument Air i
System and PCIGS satisfies equipment manufacturer recommendations. This testing is included as'part of a
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comprehensive air quality program. As such, this part j
of Item 1 will be included in our response and commitment to Item 4 to maintain a comprehensive program to monitor and maintain air quality.
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3)
Current Oil Content Testing on the Instrument Air i
System and PCIGS satisfies the requirements for Oil j
Content Testing in accordance with ISA S7.3. This i
testing is included as part of a comprehensive air j
quality program. As such, this part of Item 1 will be included in our response and commitment to Item 4 to j
maintain a comprehensive program to monitor and maintain air quality.
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4)
Current Contaminant Testing on the Instrument Air System and PCIGS satisfies the requirements for i
l Contaminant Testing in accordance with ISA S7.3. This testing is included as part of a comprehensive air quality program. As such, this part of Item 1 will be included in our response and commitment to Item 4 to maintain a comprehensive program to monitor and maintain air quality.
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Response to Generic Letter 88-14 Item 2 Verification that maintenance practices, emergency procedures and training are adequate to ensure that safety-related equipment will function as intended on loss of Instrument Air.
PSE&G__ Resp _onse At Hope Creek, maintenance programs are in place to ensure that safety-related components in the Instrument Air System and PCIGS function properly in response to a loss of Instrument Air.
In addition, emergency operating procedures and operator training programs are in place to further ensure appropriate response to a loss of Instrumant Air.
A description of the programs, procedures ano training is as follows:
1)
Maintenance activities performed on the Instrument Air System and PCIGS are based on manufacturer recommended tasks and frequencies, as well as equipment history and commitments. A review of vendor maintenance requirements against existing maintenance practices was performed as part of the Safety System Functional Review (SSFR). It was found that existing maintenance procedures are in.accordance with vendor requirements and that no significant differences that would affect safety related equipment exist.
2)
Maintenance training for station personnel who perform maintenance activities on the Instrument Air System and PCIGS is provided to ensure that these personnel are adequately trained to perform proper maintenance.
A review of the maintenance training program for pneumatic system equipment was performed as part of the ESFR.
It was found that the existino maintenance training program for pneumatic system equipment is adequate.
3)
Emergency Operating Procedures and System Operating Procedures have been developed and are in place for use by Control Room operators in response to and recovery from a loss of Instrument Air. A review of the Emergency Operating Procedures and System Operating Procedures used in response to a loss of Instrument Air was performed as part of the SSFR. It was found that both the Emergency Operating Procedures and the System Operating Procedures are adequate for proper response to a loss of Instrument Air.
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Rooponse to Gan2ric' Letter 88-14 4)
Operator' Training.for the, Instrument; Air System and.
PCIGS is provided to all licensed operators'so that they understand plant operation both with and without the Instrument Air System. The licensed operators receive simulator training on the lossLof the Instrument Air System., Equipment Operators are trained to respond in'the field by' performing the required manual equipment operations (i.e. positioning a valve using the manual operator). A review of the Operator Training Program for the Instrument Air System was performed as part of the SSFR..It was found that the. Operator Training Program for the Instrument
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Air System was adequate. The lesson plans / scenarios reviewed were. concise, accurate and updated prior to use. A Loss of Instrument Air scenario is a. scheduled activity for both the initial licensed operator i
simulator program and the licensed operator requalification training program. Interviews with operations personnel indicated.they'were knowledgeable; l
of the consequences of a loss of Instrument Air and l-were cor.'
ent in their ability to respond adequately.
T The-determination.made by.PSE&G in regard to satisfying the requirements of NRC Generic Letter 88-14,: ' Item 2, for the above mentioned programs, procedures and training is as follows:
1)
Current maintenance procedures are adequate to ensure L
that safety-related equipment will function as intended on a loss of Instrument Air.
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Current maintenance training program is adequate to ensure that safety-related equipment will function as i
intended on a loss of Instrument Air.
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Current Emergency Operating procedures and System j
Operating procedures are adequate to ensure that i
safety-related equipment will function as intended on I
a loss of Instrument Air.
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Current operator training program is adequate to ensure that safety-related equipment will function as intended on a loss of Instrument Air.
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Response to Generic Letter 88-14 Item 3 Verification that 1) the design of the entire Instrument Air System including air or other pneumatic accumulators is in accordance with its intended function, including 2) 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 normal Instrument Air System. 3) 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.
PSE&G Respopse l
l UFSAR Section 15.9.6.3.3.2, Event 8, addresses a loss of the l
plant Instrument / Service Air System. The section states that a loss of Instrument or Service Air causes a reactor shutdown and closure of isolation valves. Although these actions occur, they are not a requirement to prevent unacceptable consequences in themselves. Multiple equipment failures would be ;>acessary to cause the deterioration of the subject system to t he point that the components supplied with Instrument or Service Air would cease to operate normally and/or fail safe.
The design adequacy of the Instrument Air System and PCIGS at Hope Creek has been previously evaluated during system operation.
A Configuration Baseline Documentation (CBD) review is scheduled to be completed by the end of this year.
The verification of design adequacy as described in Item 3, was included as part of the SSFR.
The SSFR results for each of the three areas contained in Item 3 are as follows:
1)
Verification that the design of the Instrument Air System and PCIGS is in accordance with the intended function included a review of the system sizing calculations.
The results of this review indicated that the system sizing was adequate. Due to the small margin available in the 500 SCFM @ 100 PSIG compressor capacity in the original design, Instrument Air Compressor sizing was increased to 700 SCFM @ 100 PSIG.
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Response to Generic Letter 88-14 l
Walkdowns of the Instrument Air System were also performed to thoroughly evaluate system performance, as part of the SSFR. It was found that at that time, no significant air leaks existed on the system.
Subsequently, an air leak was detected on a Reactor Building Instrument Air Branch Header at a 3" Tee joint. A-temporary repair was completed and plans were developed for permanent repair. To determine if this leak was an isolated case, an inspection program, including Radiography Testing to determine joint insertion depth and soap bubble testing to determine leakage, was initiated for 74 similar joints on Instrument Air Headers in the Reactor Building, Turbine Building and Auxiliary Building.
Results of the inspection program revealed 2 small leaks out of i
the 74 joints inspected. The repair of these two joints will be included with the repair of the initial leaking joint.
2)
In order to perform a verification by test that air-operated safety-related components will perform as expected in accordance with all design-basis events, l
including a loss of the normal Instrument Air System, l
controlled Loss of Instrument Air tests are scheduled l
for parts of the system during the upcomina 2nd l
Refueling outage.
The test will provide information in regard to plant response upon loss of Instrument l
Air, with specific emphasis placed upon the response of safety-related components.
3)
Verification of current air operated component failure positions to verify that they are correct for assuring required safety functions was performed using the plant data retrieval system. The design of failure positions for air operated safety-related valves was found to be adequate. However, the failure positions of the Reactor Building Truck Bay Air Lock Isolation l
Dampers and the RACS Minimum Flow Valve are being i
evaluated and will be revised after completion of the Controlled Loss of Instrument Air Test, if necessary.
l The determination made by PSE&G in regard to satisfying the requirements of NRC Generic Letter 88-14, Item 3, for the above mentioned design verification is as follows:
1)
The current system design is adequate.
2)
Loss of Instrument Air tests will be performed during the upcoming 2nd Refueling Outace.
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cRosponso to Ganaric..Latter'88-14 s
13)-.The current'. failure, position'of. air operated safety--
=related.valvesfwas. adequate.
However,fthe' failure'
. positions of componentsLidentified_aboveLare.being.
evaluated andLwillfbe-revised.after completionfof?the:
Controlled Loss of' Instrument-AirLTest, if-necessary.
Item"4' Leach licensee / applicant should provideLa discussion of'thdir
. program for maintaining. proper. instrument air quality
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PS_E&G_ Response At: Hope Creek, based onLimprovements recommended by the SSFR,.
'the program to, ensure. proper,. Instrument. Air and'PCIGSfair quality. includes comprehensive. periodic? testing of dew' point, S
- particle size, Roil content and' contaminants in'accordance:
=with'ISA S7.3, Hope Creek'UFSARLand/or1 vendor cleanliness recommendations..: Preventative maintenance. procedures are used
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toimaintain thel Service Air Compressors,' Emergency Air.
Compressor, Instrument Air Dryers,'the dryer desiccant-and the dryer ~prefilter'and afterfilter-in accordance with? vendor 7
specifications and requirements. In addition,.the-station.has developed'.a design-change to install a third-Instrument Air' Dryer toLincrease system' reliability.
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