ML20246M518

Forwards Update on Action Plan Developed in Response to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment

ML20246M518
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/31/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, NUDOCS 8909070185
Download: ML20246M518 (9)

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MUIVR8V David W. Cockfield Vice President, Nuclear August 31, 1989 Trojan Nuclear Plant-Docket 50-344-License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington.DC 20555

Dear Sir:

Nuclear Regulatory Commission (NRC)

Generic Letter 88 Instrument Air Supply System Problems Affecting Safety-Related Equipment The purpose of this letter is to provide an update on the action plan developed to respond to NRC Generic Letter 88-14. " Instrument Air Supply System Problems Affecting Safety-Related Equipment". As stated in PCE's letter dated February 3,1989, our review of the- generic letter identi-fled six specific actions. required of licensees. Each NRC request, and Portland General Electric Company's (PGE's) action taken to comply with the request is provided in the attachment to this letter.

A file has been prepared storing the documentation generated for the action plan. This file will be maintained at the Technical Support Center located at the Trojan Nuclear Plant for a minimum of two years from the date of this letter.

Pursuant to your request under Title 10, Code of Federal Regulations, Part 50. Section 54(f) [10 CFR SD.54(f)], except as noted in the attach-ment, all the actions requested in Generic Letter 88-14 have been i

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' completed. When all requiree nts of the generic letter have been implemented, a written notification will be provided stating that all actions are complete. The notification will be submitted in November 1989.

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Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant Subscribed and sworn to before me this 31st day of August 1989. ,

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$ Troj an ; Nuclaer' Pitnt -  : Document Crntrol'De:k

' Docket.50-344 August 31. 1989' License"NPF-1 Attachment Page 1 of 7 PORTLANDGENERALELECTRICCOMPANY'S(PUE's)

ACTIONS.IN RESPONSE'TO NUCLEAR REGULATORY COMMISSION (NRC)

. GENERIC LETTER.NO. 88-14.. INSTRUMENT AIR SUPPLY SYSTEN PROBLEMS f.FFECTING SAFETY-RELATED EQUIPMENT l

NRC RF; QUEST i

,1. " Review Nuclear Regulation (NUREG) 1275, Volume.2".

l l PCE Respoqse 4 detailed review wts conducted of NUREO-1275, " Operating Experience Feedback Report - Air Systems Problems" (Reference 1). The

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operating experiences described in this report were examined for applicability to the. Trojan Nuclear Plant. Specifically, the defi-ciencies and recommendations outlined in the report's executive summary were evaluated. The responses provided below to the generic letter requests delineate the actions taken to address these concerns.

NRC REQUEST

2. "Verif.ication by test that actual instrument air quality is consis-tent with the manufacturer's recommen6ation for individual components sorved".

PCE Response A review was performed to identify air quality requirements for all safety-related components requiring instrument air. The review.

entailed inspecting vendor end-user drawings and technical manuals for identification of. supplier recommendations on moisture content,

' hydrocarbon content and particulate size. The results of the review are tabulated in Reference 1.

N. A test procedure was generated (Reference 2) to verify by test that actual instrument cir quality is consistent'with the manufac-turer's recommendations. The procedure checked for the hydrocarbon content, particulate content and dewpoint of the instrument air system downstream of the instrument air dryer after-filter. The measured and sampled air quality met or exceeded all vendor recommendations. The air quality test will be performed on a quarterly basis.

NRC REOUEST

3. " 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".

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Trajan NuclO r Pltnt Docum:nt Control De:k Docket 50-344 August 31, 1989 License NPF-1 Attachment Page 2 of 7 i: PCE Response l

Plant maintenance procedures and practices were reviewed to verify adequate maintenance is provided to ensure safety-related equipment will function as designed. As a result of the review, the system blowdown procedure (Reference 3) was rewritten to guarantee the entire system is blown down on a periodic schedule. Performance of this procedure and the air quality test procedure (Reference 2) i ensure adherence to the quality requirement of American National l Standards Institute-Instrument Society of America (ANSI-ISA)

Standard S7.3-1975, " Quality Standards for Instrument Air".

In addition, Reference 4 will be revised to include periodic mainte-nance inspections for in-line filter / regulators and lubricators.

The revision is scheduled to be completed in September 1989.

The air system soldered joints incide containment were checked for '

leakage. A partial check of the system outside containment has been completed. Some leaking joints were identified and repaired. The need to check the remaining portion of the system outside containment over the next four years is currently under evaluation (Reference 5).

Emergency procedures were reviewed to confirm the following infor-mation is provided: proper indication of loss of instrument air, identification of critical components operated by instrument air, expected system and Plant responses to a loss of instrument air and the consequences, manual actions the operator should be expected to take in responding to a loss of instrument air, actions if critical components do not fail in the intended position and restoration actions to be taken af ter instrum ant air is regained. The Off-Normal Instructions currently in use (Reference 6) provide the mentioned information. In addition, various Emergency Operating Procedures address actions to be taken if critical components are not in the proper configuration. The results of the review are documented in Reference 7.

Plant training was reviewed to verify that loss of instrument air is specifically addressed. The training materials currently in use adequately address the operation of the instrument air system. A single-use License Retraining lesson plan (Reference 8) has been generated to educate all current operc tors on the issues identified in NUREG-1275 and Generic Letter 88-14 As a minimum, the lesson plan covers common-mode failures and emphasizes the importance of the air system. Operator retraining has been initiated and is scheduled to be completed by October 1989. License training materials (Reference 9) for new operators will be revised to specifically cover the types of common-mode failures described in NUREG-1275 and to emphasize the importance of the air system. The update of the training materials is scheduled to be completed in October 1989.

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Trsjcn Cucitar Pitnt Docum:nt Control D2:k Docket 50-344 August 31, 1989 q License NPF-1 Attachment Page 3 of I  ;

l The Simulator Training Program currently includes three exercise ,

guides for loss of instrument air. The three guides are: an j initial one-hour demonstration of a complete loss of air event, a partial loss of air caused by a leak inside Containment during power reduction, and a complete loss of air at 100 percent power. 1 f

FRC REQUEST

4. " Verification that the design of the entire instrument air system including air or other pneumatic accumulators 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 l normal instrucent air system. This design verification should l include an analysis of current air-operated component failure posi- i tions to verify that they are correct for assuring required safety functions".

PGE Response The design verification of the entire instrument air system was performed in conjunction with the generation of a Design Basis l Document (DBD) on instrument air. The document, titled, " Instrument and Service Air System DBD-18", confirms the system provides the required pressure and has adequate capacity for supplying compo-nents. The design basis of the system is described in DBD-18. The following highlights the design verification effort.

A walkdown of the system was performed to identify and tag all valves and air users. The instrument air piping and instrument diagrams (P& ids) have been updated to reflect the walkdown. The expanded P& ids will help operators more readily locate problems.

A list of all safety-related air-operated components was assembled.

Each safety-related valve was analyzed for proper valve failure position. All the valves were found to fail properly for their intended function. The documents reviewed and the results of the review are tabulated in DBD-18.

A review of all safety-related air accumulators was also performed to verify proper sizing. The pressurizer power-operated relief valves (PORV) and the auxiliary feedwater (AFW) steam supply valves accumu-lators are adequately sized to perform their intended function (Reference 10). The main steam isolation valve (MSIV) accumulators are not safety-related, and thus are not included in the design verification (Reference 10).

l l Confirmation of valve failure positions by testing was accomplished l in two phases. The first phase consisted of reviewing the existing L Inservice Testing (IST) Program and Maintenance Procedures to ensure 1

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'I "h' Trojtn Nuclear.P1Ent . Documen$ Control Desk Docket 50-344 August 31, 1989

' License NPF-1 Attachment Page 4 of;7 that all safety-related valves are tested. The failure position of.

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al1~ safety-related active. valves is tested for in the IST Program.

All passive valves, as defined in the Quality-Related Classification Criteria Report, or valves that have a failure porition Which'is the same as their normal position, are tested in Reference.4. The review. tabulated in Reference 11 demonstrated that the actual failure position tested for is consistent with the intended failure position.

The second phase consisted of performing loss of air tests on safety-related accumulators. New procedures were generated (References 12-and 13), to perform a gradual and rap *d loss of air test on the' pressurizer PORV and AFW accumulators, the final test results verified the accumulators can maintain the required pressure to allow the valves to perform their intended safety function.

The air receiver tanks and attached piping were checked by ultrasonic testing for internal corrosion. The results verified that adequate wall thickness exists for the tanks and piping (References 14 and 15).

A review was conducted of all the instrument setpoints in the instrument air system (References 16 and 17).. The Instrument Index, J-900, the P& ids and the instrument calibration cards used by the Trojan Maintenance Department were reviewed f9r consistency.

Corrected setpoints have been issued on setpoint data sheets for the system.

The solenoid valve maximum operating pressure differential (HOPD) was checked. A list of all safety-related solenoid valves was developed from DBD-18. For each solenoid valve, the MOPD was deter-mined from valve drawings, vendor catalogs, or by contacting the vendor. Twenty valves were identified Which had an MOPD below the expected MDPD. For these valves, it was determined that adequate procedures, alarms or indications exist so that immediate action is not required to replace these valves. The remaining valves have a l-sufficiently high design MOPD to operate at the expected system MOPD.

l The design review included a case-by-case analysis of the incidents q in NUREG-1275. Reference I describes the applicability to the -

Trojan system design for each case. It was determined that it is unlikely that any one of the event could occur at Trojan with existing maintenance procedures in place.

Previous NRC Inspection Enforcement (IE) Notices, Institute of Nuclear Power Operations (INPO) Significant Operating Event Reports (GOERS), and instrument air event reports were reviewed to determine if any additional action was required beyond the requirements of the generic letter. It was determined (Reference 18) that the gener3 0 '

letter action plan addressed the commitments and recommendations made in the IE Notices, INPO SOERs and Event Reports, 1

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Trojen Nuclear Plent. ' Document Control Desk-9 Docket 344 - August 31,'1989

' Attachment License'NPF-1 '

Page 5 of 7-NRC CONCERN ,

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l_ -5. " Provide a discussion of the program for maintaining proper instru-

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-ment air quality".

PCE Response l'

l JThe Maintenance Program at the Trojan Nuclear Plant'has been up(sted I ~ to specifically address the issues identified:in the generic letier.

A new' procedure. (Reference 2) var written ' to sample the air ' system

.for hydrocarbon content . particulate content and dewpoint. . The air

_ quality test will be performed on a quarterly basis.

i DThe air system blowdown precedure (Reference 3) was revised to ensure the entire air system is blown down on a yearly basis.

. . l Maintenance inspections will be incorporated into Reference 4 for.

.inline/ regulators and lubricators in September 1989.

In addition, a preventive maintenance program is utilized. The air' .l compressors are serviced on a monthly, semiannual and annual basis (Reference 19). As a minimum, the service includes checking the. oil level,' inspecting for leaks, alignment of sheaves, inspecting pre-  !

filters and filters, testing compre:sor relief valves and cleaning :l

condensate traps.  !

I d Filters and moisture traps are al'.o serviced on a semiannual and annual basis (Reference 19). The service includes cleaning, inspecting and replacing filter elements as needed.

The desiccants in the air dryers are sampled annually and replaced j every three years (Reference 19). 'l Instrumentation is calibrated on a three-year cycle (Reference 20).

NRC REOUEST

6. " Identify any components that cannot accomplish their intended safety function and state the corrective cetion taken or to be taken".

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PCE Response The Trojan air system has been verified to respond properly to loss of air pressure. All safety-related components have been verified to. accomplish their intended safety function (Reference 1). j Two modifications were made to improve system operation. The first modification consisted of replacing the existing dryor after-filter

Trojcn Nuclear Pitnt Documint Control De~ak Docket 50-344 August 31, 1989 License NPF-1 Attachment Page 6 of 7 elements with filters of higher filtering capability to prevent desiccant from entering the system and to bring the instrument air system in line with the requirements of ISA 37.3.

The second modification was to rework and retest the check valves and solenoid valves associated with the pressur3xor PORY accumu-lator. Excessive leakage was discovered during the rapid loss of air testing.

APC/mr 3380W.0789

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August 31,-1989 -6 Y- License NPF-1 Attachment-Page 7 of 1 it as

• REFERENCES-

11. Letter BP-13866, Dated January 13, 1989, Bechtel to PGE.

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2. Periodic Engineering Test (PET) 16-4, " Quality Instrument Air System 4- .

~ Air Quality Test".

3. Periodic Operating Test (POT) 29-2, "InstrumentLAir System Blowdown".

$. Maintenance Procedure (MP) 12-4, " Valve Air Actuators".

5. Memoranduta, PAM-019-89, Dated February 14, 1989 P. A. Morton to S. Artus.

6. .Off-Normal Instruction (ONI)-51, " Loss of Instrument Air"

1. Memorandum PGE-10-89, Dated February 16,.1989, K. Erickson to R..H. Sherman, r

8. License'd Retraining Lesson ' Plan,04-209, " Instrument and Service Air Issues",

n 9. Training Materials,- 02-I-02, " Instrument Service Air System".

10.- Letter BP-13886', Dated January 30, 1989, Bechtel to PGE.

11'.- Memorandum DSS-027-89, Dated August 21, 1989 D. Seely to' File.

12.. Periodic Engineering Test (PET) 16-2, " Seismic I Check, Valve Leakage 1 Test".

13. Periodic Engineering Test (PET) 16-3, " Slow Loss of Instrument Air".

14. Maintenance Request, (MR) 89-5578.

15. Maintenance Request, (MR) 89-5579.

15. Letter BP-13967, Dated March 21, 1989, Bechtel to PGE.

17. Letter BP-14015 Dated April 18, 1989, Bechtel to PGE.

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18. Letter BP-13849 Dateo January 6, 1989. Bechtel to PGE.

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19. Maintenance Procedure (MP) 3-8, " Trojan Preventive Maintenance and Scheduling Program".

20. Maintenance Procedure (MP) 2-0, " Installed Plant Instryment Maintenance and Calibration".

APC/mr/3380W.0789

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