NRC-90-0012, Forwards Response to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Monitoring & Treatment Programs to Reduce Incidents of Flow Blockage Due to Biofouling Will Be Implemented During Early 1991

Forwards Response to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Monitoring & Treatment Programs to Reduce Incidents of Flow Blockage Due to Biofouling Will Be Implemented During Early 1991

ML19354E889
Person / Time
Site:	Fermi
Issue date:	01/26/1990
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0012, CON-NRC-90-12 GL-89-13, NUDOCS 9002020289
Download: ML19354E889 (8)

Text

-

.g e

s. n iph srMa comor vae Psee.ornt 1

b430 North Danie Hephesy

,en we.cori wcao.n eiu I d %sr (313) M6-4150 mm 1

i l

L i

January 26, 1990 NE-90-0012 i

j

'i l

U. S. tbclear Regulatory Commission t

Attn: Document Control Desk-l I

Washington, D. C.

2055S 1

Referures:

1) Fermi 2 1

NE Docket No. 50-341 NE Licence No. !FF 2)

NE Generic Letter 89-13, " Service Water System Problems Affecting

{

l-Safety-Related Equipment", dated July 18, 1989

Subject:

Resnonne to NE Generic Letter 89-13 Detroit Edison has reviewed the Generic Letter 89-13 (Reference 2) d which was received on August 1,1989. _ This Gmeric Ietter requires 1

licensees to supply information about their Service Water Systunn to' assure the NE of their coupliance with the requirenants and to confirm that the safety functions'of the Service Water Systems are being net.

At Fermi 2, the Service Water Systems'as defined by this Generic '

Letter ore identified as Dnergency Equipnent Cooling Water System, Emergency Equipment Service Water System, Residual ~ Heat Benoval j

Service Water System, and the Diesel G. arator Service Water System.

Detroit Mison is currently inplementing programs and procedures to ensure that these Service Water Systems conply with the requirenents and adequately perform their interded design and safety functions.

l These programs and procedures are being further reviewed based on the Generic Letter requirements and, if needed, they will be modified to assure coupliance with the Generic Letter 89-13.

J i

Detroit Mison's' response to each specific NE recomnended action is -

I provided in the enclosure of this letter.

In addition to this response, as required by the Generic Letter 89-13, 1

Detroit Mison will confirm to the NE within 30 day:. of the inplementation that all the recommended actions or their justified alternatives have been inplenented.

1 e:

9002020289 900126 DR ADOCK 0500 1

p j

ve

c USNIC

-J muary 26, 1990 NIC-90-0012 Page 2 With that confirmation, as requested by Generic Letter 89-13,' Detroit Edison will also provide the NIC with-the ~information regarding the time required to perform the requested confirmation and'any needed

,1)-

fo11mm2p action; and the time required;to prepare the-requested -

-l documentation.

~

If you have any questions, please contact Mr. Girija Shukla at' (313)'

f-586-4270.

a

.- l Sincerely, -

1 ff I'

En::losure i

cc:

A. B.. Davis R. W. Defayette W. G. Rogers J. - F. Stary) -

USNIC Begion III i

t

-I q

i l

'l Li

-1 l

~

,t

.y t

'h_'

I,h i

L i:

m USNIC January 26,:1990-NIC-90-0012 :

Page;3 I, B.'IRLPH SYLVIA, do hereby affirm that the foregoing statements' are based on facts-and ciretmetances which are true and accurate to-

~

the best of my knowledge and belief.

-o

~

A h

f?

'B.RAIfH.SYLyIk Senior Vice President -

On'this 26th

-day of; January-1990, before.me personally appeared B. Ralph Sylvia, being first duly sworn and says that he executed the foregoing as his free act and deed.

p

'Notarygdblic '

SHiliEY L C M uiON Notary Putsc. Wayne Cow 4 MI

MyCommissionEssmashab1991 -

%:h.

r i

k I

Lj

..n

g.

Enclosura to

.NRC-90-0012 Page 1 1

RESPONSE '!O GENERIC LETER 89-13

-The Detroit Edison response to each specific NRC recommended action'of Generic Letter 89-13 is'given below:

o NRC Recommended Action I.

For open-cycle service water systems,

. implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling. A program-

. acceptable to the NRC is described in." Recommended Program to-

' Resolve Generic Issue 51" (Enclesure;1). It should be noted that Enclosure.1-is provided as guidance for an acceptable program.-

An equally effective program to preclude biofouling would:also be-acceptable. IniM al activities should be completed before plant startup following the first refueling' outage beginning 9 months or more after the date of this. letter. All activities should be documented and all. relevant documentation should be retained in appropriate plant records.

Detroit Edison Response:

L Detroit Edison is; implementing monitoring and treatment programs i

to significantly reduce the incidents'of flow blockage problems-at Fermi 2 due to biofouling. 'These. programs are based on the.

i NRC recommended program described in~the Enclosure 1 of this, Generic Letter. These programs include performance testing.of heat exchangers and other components,; trending of surveillance data for any degradation of systems and-components, periodic i

monittring of systems for.microfouling, chemical treatment of the servic,e water system, and periodic maintenance activities for systems not included in the performance testing program.

Implementation of these programs is scheduled to be completed by-the second refueling outage,.which is scheduled for early 1991.

l All activities will be documented and all relevant-documentation will'be retained in the plant records.

o NRC Recommended Action II. Conduct a test to verify the' heat' transfer capability of all safety-related heat exchangers cooled '

by service water. The total test program should consist of.an

'{

' initial test program and a periodic ~ retest program. Both the-

.i initial test program and the periodic retest program should-include heat exchangers connected to or. cooled by one or more ooen-cycle systems as detined above. Operating experience and studies indicate that c12 sed-cycle service water systems, such as.

l component cooling water systems, have the potential'for 1

significant fouling as a consequence'of aging-related in-leakage and erosion or corrosion. The need~for testing of. closed-cycle j

y

t.

Enclo2urs to NRC-90-0012 t

Page 2 system heat exchangers has not been considered necessary because of the assumed high quality of existing chemistry control programs.

If the adequacy of these chemistry control programs.

cannot be confirmed over the total operating history of the plant-or if during the conduct of the total testing program any unexplained. downward trend in heat exchanger performance is identified that cannot be remedied by maintenance of an open-cycle system,.it may be necessary to selectively extend the; test program and the-routine inspection and maintenance program addressed in Action III, below, to the attached _ closed-cycle

d systems.

A program acceptable;to the NRC for. heat exchanger testing is described in " Program for Testing Heat Transfer Capability"~

4 (Enclosure 2).

It should be noted that Enclosure 2 is,provided I

as guidance for an acceptable program..An equally effective l

program to ensure satisfaction of-the heat removal' requirements

--j of the service water system.would:also be acceptable.

j Testing should be done with necessary and sufficient instrumentation, though the-instrumentation need not be l

permanently installed. The relevant temperatures should be 1

verified to be within design limits._If.similar or equivalent-j tests have not been performed during the past year, the initial' j

tests should be completed before plant startup following the first refueling outage beginning 9 months or more after-the date j

of this le.;er.

R As a part of the initial test program, a licensee:or~ applicant may decide _to take corrective action before testing. Tests should be performed for the heat exchangers after the corrective actions are taken to' establish baseline data for future monitoring of heat exchanger performance.

In the periodic retest

[

prograa, a licensee or applicant should determine afterLthree

]

i tests the best frequency for' testing to provide assurance that

~

{

the equipment will perform the intended safety functions during, the intervals between tests. -Therefore, in the periodic retest l

program, to assist that determination, tests should be-performed for the heat exchangers before any corrective actions are taken.

As in the initial test program, tests should be repeated after an/

corrective actions are'taken to establish baseline data for

- i future monitoring of heat exchanger performance.

- I An example of an alternative action that would be acceptable to l

the NRC is frequent regular maintenance:of a heat; exchanger in lieu of testing for degraded performance of,the heat exchanger.

This alternative might apply to small-heat exchangers, such as lube oil _ coolers or pump bearing coolers or readily serviceable heat exchangers located in low radiation areas'of the facility.-

1 Enclosura to NRC-90-0012 Page 3 In implementing the continuing program for periodic retesting of i

safety-related heat exchangers cooled by service water in r

open-cycle systems, the initial frequency of testing should.be at least once each fuel cycle, but after three tests, licensees and j

applicants should determine the best frequency.for testing to:

provide assurance that the equipment will perform the intended safety functions' during the intervals between tests and meet the.

requirements of GDC 44, 45, and 46. The'ainimum final testing frequency should be once every 5 years. A summary of the program should be~ documented, including the schedule for. tests, and all-relevant documentation should be retained in appropriate plant.

~

a records.

~

Detroit Edison Response:.

Detroit _ Edison is currently in the process of implementing.a-test-

~

and monitoring program to_ verify the heat' transfer capabilities ~

{

of safety-related. heat exchangers and other heat exchanging-components of service water' systems. This program will be based:

on the NRC recommended program described in Enclosure _'2 of.the Generic-Letter 89-13 The initial testing will be-completed by.

the second refueling outage.

Periodic retesting and inspection schedules will be established through the existing survoillance-i program, preventive' maintenance program,;and' performance testing 7

i program. The frequency of testing would'be initially once~per' i

each fuel cycle until 3 tests have been conducted at)which time the frequency may be changed to once per 5 years based on-evaluation of test results. The testing' program will~be' documented and retained in the plant _ records..

L o

NRC Recommended Action III. Ensure by. establishing a routine inspection and maintenance program for.open-cycle service water system piping and components:that corrosion, erosion, protective l

coating failure, silting, and biofouling cannot degrado the performance of the safety-related' systems supplied by service i

water. The maintenance program should have at.least the following purposes:

.]

A.

'To remove excessive accumulations of biofouling agents,.

corrosion products, and silt:

'l B.

To repair defective protective coatings and corroded service water system piping and components that could adversely affect performance of.their intended safety.

?

functions.-

j i

This program should be established before. plant startup following' the first-refueling outage 'beginning 9 months after the date of this letter. A description of-the program and the_results of

.s, Enclo2ura to c

NRC-90-0012 Page 4 these maintenance inspections should be documented. All relevant documentation should be retained-in appropriate plant records.

Detroit Edison Response:

Detroit Edison is currently implementing inspection and maintenance programs for service water systems piping and components to ensure that corrosion, protective coating failure, silting and biofouling problems do not degrade the' performance of' the safety related systems supplied by' service water.. As the-operating temperature of the service water systems is below' 0

200 F (the lower temperature. limit for the existing erosion / corrosion program) and the flow rate is relatively low, inspection for erosion is not included in these programs..These

- t programs will include removal of excessive accumulations and

~ Implementation of-repair of degraded systems and components.

these programs-is scheduled to be completed by the second' refueling outage. These programs will be documented and retained 1 in the plant records.

i o

NBC Recommended Action IV. Confirm that the service water j

system will perform its intended function in accordance with the

{

licensing basis for the plant. Reconstitution'of-the design 1

basis of the system is not intended. This confirmation should i

include a review of the ability to perform required safety-functions in the event ofJfailure of a single active component.

To ensure that the as-built system is in'accordance with the' appropriate licensing basis documentation, this confirmation-should include recent-(within the past 2. years)-system walkdown.

inspections. This confirmation should be completed before plant j

startup following the first refueling outage beginning 9 months 1

or more after the date of this letter. Results should be I

documented and retained in appropriate plant records.

Detroit Edison Response:

1 Detroit Edison is currently undertaking a design basis document review which will include a review for the ability of the service water systems to perform required safety functions in the event of failure of a single active component. The design basis review will be supported by a recent system walkdown inspection to ensure that the as-built systems complies with the licensing _ _

basis documents. This review and confirmation will be completed by the second refueling outage. The results of the review will be documented and retained in the plant records.

)

o NRC Recommended Action V.

Confirm that maintenance practices, I

operating and emergency procedures, and training that involves the service water system are adequate to ensure that y

j

-a.-

Enclosura to NRC-90-0012 Page 5 safety-related equipment cooled by'the service 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, procedures, and training modules. 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 the date of this letter. 1Results should:be-documented and retained in appropriate plant records.

Detroit Edison Response:

At Fermi 2, current maintenance practices, operating and

]

l emergency procedures, and training programs related.to'the-service water sptens were established ~to ensure that the systems will perform their intended design and safety functions, and--the operators will also perform effectively in operating the systems. These programs and procedures will-be further reviewed to assure the requested confirmation. 'This confirmation willbe completed by the second refueling outage and documented in the plant records.

.]

i a

!a

'l t

!)

!q f

.j