ML20006A909

Forwards Response to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Util Has Program to Perform Visual Insps & Cleanings of Plant Svc Water Intake Structure by Means of Scuba Divers

ML20006A909
Person / Time
Site:	Farley
Issue date:	01/23/1990
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-13, NUDOCS 9001300471
Download: ML20006A909 (13)

Text

.__- -__ - --

Alabama Power Comparty j

• (O

. lnverness Ctrct Parkw:y

. Fbst Offee Bm I?95 ,

Dwmingham. Alabunt 35N1 Telephone 205 BGB-5581 ,

W. Q. Hairston,111 i

Senior Vice Presloent Nuclear Operations January 23, 1990 Ob3@U D U i the Southern t%ctrC Sy Ettrm I

Docket Hos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Vashington, D. C. 20555  ;

Gentlemen:  ;

i Joseph M. Farley Nuclear Plant - Units 1 and 2 '

Service Water System Problems Affecting Safety Related Equipment (NRC Generic Letter 89-13)

Generic Letter 89-13 was issued to require licensees e.nd applicants to supply information about their respective service water systems to assure the NRC of their compliance with General Design Criteria (GDC) 44, 45 and >

46 of 10CTR Part 50, Appendix A, and Section XI, " Test Control", of -

10CFR50 Appendix B and-to confirm that the safety functions of their respective service water systems are being met. Generic Letter 89-13 also requested that licensees and applicants perform five recommended actions listed in the generic letter, or equally effective actions, to ensure that their service water systems are and vill be maintained in compliance with the above stated regulatory requirements. Furthermore, Generic Letter 89-13 states that if a course of action is chosen different from the recommended actions, justification that the heat i removal requirements of the service water system are satisfied by use of the alternative program should be documented and retained in appropriate l

plant records.  ;

I Alabama Power Company has reviewed the requirements of the generic letter and determined that programs have been developed or vill be developed for the safety related portions of the service water system prior to startup from the Unit 2 Fall 1990 Refueling Outage to meet the intent of the five recommended actions contained within the generic letter. The Alabama Power Company response to each of the five recommended actions is provided in the Enclosure to this letter. Alabama Power Company intends .

to implement this program; however, should other means become available i for implementing these actions in the future, the program may be revised accordingly. Additionally, confirmation that these initial tests and activities have been completed and that continuing programs have been l established will be submitted within 30 days after completion of all initial tests and activities identified in this program.

i-

' 9001300471 900123 ADOCK 0500 48

{DR g[//

9 U. S. Nuclear Regulatory Commission Page 2 The information provided herein is true to the best of my knowledge and belief. If you have any questions, please advise.

Respectfully submitted, ALABAMA POVER COMPANY t.d.b. $ W V. G. Hairston, III VGH.III/LCTimV.1340 Enclosure SVORN TO AND SUBSCRIBED BEFORE ME cet Mr. S. D. Ebneter Mr. E. A. Reeves THIS d . AY OF Ojunau , 1990 Mr. G. F. Maxwell A>lo u . A c] /r M , / / ~

No @ry Public My Commission Expires: lu 00Co;Sil0N LW.ES Ltc.15.!D?2 l

1 1

e

, , ,  ; ~4 [ ]

, r

's.  :!

.{

.i Enclosure 'I Alabama Power Company (APCo). *

[ Response to Actions Recommended in NRC Generic Letter 89-13 m:

~!

I. NRC Recommended Actions 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 bioforling. The following program, or an equally -

effective program, is acceptable: .

t A. The intake structure should be visually inspected, once ver c refueling cycle, for macroscopic biological fouling organisms-- ,

(i.e., Asiatic clams), sediment and corrosion.- Inspec tions- '

should be performed either by scuba' divers or-'by devatering'the  !

intake structure or by-other' comparable methods. Any fouling accumulations should be removed.

B. The service water system should be continuously (for: example,.

during spawning)' chlorinated (or equally effectively treated _vith

• another biocide) whenever the potential for a macroscopic- j-biological luuling species exists (for example's Asiatic ~ clams-et freshwater plants). Precautions should be'taken to_ obey Federal, 4 State and local environmental regulations regarding'the-use of biccides. 3 C. Redundant and infrequently used cooling loops should be flushed and flow tested periodically at the'waximum. design flow to ensure that they are not fouled or clogged. Other components in the-F service water system should be tested on a regular' schedule to ensure that they are not fouled-or clogged. Service water cooling loops should be filled with chlorinated or equivalently-treated water before lay-up. Systems.that use raw service'vrter L

as a source, such as some fire > protection systemsi should also be chlorinated or equally effectively treated beforeElay-up'to help L prevent microbiologically influenced corrosion (HIC)'.

L Precautions should be taken to obey Federal, State'and local.

• L environmental regulations regarding the_use of biocides.

D. Samples of vater and substrate should be collected annually to-determine if Asiatic clams have populated the water source.

Water and substrate sampling is only necessary at freshwater -

plants that have not previously detected the presence of i _

! freshwater clams in their source water bodies. If Asiatic clams

! are detected, this sampling activity may be' discontinued'1f desired and the chlorination treatment program should be modifiedi .l to be in agreement with paragraph B, above.  ;

)

- a

^ .

, APC) R3:p:nsi to j

<s , G:n:ric Let tar 89-13 Pago 2

• APCo' Response:

A. APCo has a program:to' perform visual-inspections and cleanings of '

the Farley Nuclear Plant (PNP) service water intake structure for ,

both-Units 1 and 2 by means of scuba' divers to remove any_  :

accumulations of macroscopic biological-fouling organisms and j sedimentation.: Since the intake structure is constructed of i concrete, corrosion is'not a problem in the FNP' intake structure. '

The next inspection is currently planned for<the summer of 1990. t Based on the previous inspections, future inspections v111f initially be established on a two year frequency. . Should the

.results of these inspections indicate that the frequency;for, -

inspecting or c1 caning the_ intake structure need'be modified, the appropriate changes vill be made. Additionally, since:the ,

previous inspections and cleanings were; performed by, scuba-j divers, devatering of the intake structure was not necessary. .

B. APCo currently treats the service water system'during spawning  !

seasons for Asiatic clams. The current program or an equally I effective program vill continue for treating the service water system whenever the potential for Asiatic clams' exists.- This chlorination process is in-accordance with.our existing-plant ,

effluent discharge permit which is based on Federal, State _and local environmental requirements. +

C. The service water _ system at FNP is basically a once-through-system with most: safety related loads-continuously supplied service water in a-parallel flow arrangement. Thus, the safety' related portions of the FNP service water system'do'not contain-I redundant and infrequently used cooling. loops as referred to in ,,

the above recommended' action.

The FNP service water system does, _ however, contain :various lines in the safety related-portions-of-the system which are infrequently used. APCo vill develop a program prior to startup from the Unit 2 Fall 1990 Refueling Outage to periodically, place -

these lines in normal operation, flush these lines at normal operating conditions or at conditionsiconsistent with normal -

plant operations, or inspect the lines for fouling. The schedule for operating, flushing or inspecting these lines v111' be defined l

i by the program, The FNP program for testing safety related heat exchangers is '

addressed in the response to Action II below. Other service water system components (i.e., vents, drains and instrument-lines) are not included in this program. Additionally.-cooling loops of the FNP service vater system are not placed in lay-up.

i e

y e._

.5 ' . ~APCi R =p nsa to ]

.G:n2ric Lettsr 89-13 i

,Pega 3- .;

.l 0

The fire protection water suppression system,Jexcluding the ,

standpipes inside containment, does not use service vater as a' normal vater source. Therefore, chlorinating or equivalently  ;

treating the. fire protection _ vater. suppression system is not required. A connection from the service water system.to the-fire protection' vater suppression system exists but it is there only - -

as'a' backup water source and the. fire protection design does not-rely upon.this connection as an available water source. . This.

connection vill be included in the program discussed above for

! periodically _ operating, flushing-or inspecting infrequently used ,

lines. The normal water source for the standpipes inside l containment'is the service vater system. These lines will also^ .!

, be' included in the-program discussed above for periodically i i

operating, flushing or inspecting infrequently used lines.

Accordingly, chlorinating or equivalently treating these-lines is .;

not necessary, 1 D. The presence of Asiatic clams has been previously detected in the  !

service water pond at FNP. Thus, the annual sampling to determine if Asiatic clams have populated the-vater source is not-required for FNP. Accordingly, the chlorination' treatment program discussed in response to paragraph B addresses the chemical treatment for clams.

II. NRC Recommended Actions Conduct a test program 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,.and should include. heat'exchangers connected to or cooled by one or more open-cycle systems.' The initial frequency for the periodic _ retesting should be at'least once per' fuel cycle, but after three tests,-licensees and applicants should determine the best frequency'for testing to provide assurance that the equipment vill perform the intended safety functions during.

the intervals between tests and meet the requirements of GDC 44, 45 and 46. The minimum final testing frequency should be nnce every five years. A summary of the program should be documented, including the schedule for tests, and all relevant documentation should be retained in appropriate plant records. .

3 The need for testing of closed-cycle _ 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 4

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 systems.

7

. *~

. APCo'R0cp:nsa to- '

si*

G:ntric Letter 89-13

~ ,Pega 4 .;

1 < ,

Testing should be'done with necessary and sufficient- . .

instrumentation,-though the-instrumentation need not be permanently installed. The relevant temperatures should be verified to be within design limits.- If similar or equivalent; tests have not been ,

performed during the past year, the initial tests should be completed before plant.startup following the first refueling. outage  ;

beginning nine months or more after the date'of this letter. ,

I-As a part of the initial test program,.it may be decided to take.

corrective action before testing. Tests should be performed for;the *  ;

heat exchangers after the' corrective actions are taken to establishi baseline data for future monitoring of heat exchanger performance.

In the_ periodic retest program, the best frequency for testing toL provide assurance that the equipment' vill perform the intended-safety: functions during the intervals between tests should be determined after the completion 1of three tests. Therefore, in'the , i periodic retest program, testing.should be' performed for the' heat ,

exchangers before any corrective actions'are taken. LAs in.the i initial test program, tests should be repeated after any corrective actions are taken to establish baseline data'for future monitoring of heat exchanger performance.

An example of an alternative action that.vould be acceptable to the NRC is frequent regular maintenance of a heat eithanger in lieu of testing for degraded performance of the heat exchanger. This alternative might apply to small heat exchangers, such as lube oil coolers, pump bearing coolers or readily serviceable heat exchangers located in low radiation areas of the facility. >

The following program, or an equally' effective program to ensure ~ l satisfaction of the heat removal requirements of the service water i

~

system, is acceptable:

\

A. All Heat Exchangers l

~

Monitor and record cooling water flow and inlet and outlet temperatures for all affected heat exchangers during the modes of operation in which cooling water is flowing through the heat exchanger. . For each measurement, verify that the cooling water temperatures and flows are within design limits for the

, _ conditions of the measurement. The test results from. periodic I testing should be trended to ensure that flow blockage or

!- excessive fouling accumulation does not exist.

(

B. Water-to-Vater Heat Exchangers (In addition to Item A above) i l-

1. Perform functional testing with the heat exchanger operating, if practical, at its design heat removal' rate to verify its-capabilities. Temperature and flov' compensation should-be made to adjust the results to the design conditions.- Trend L

I the results, as explained above, to monitor degradation.

2. If it is not practical to test the heat exchanger at the i design heat removal rate, then trend test results for the heat exchanger efficiency or overall heat transfer coefficient. Verify that heat. removal vould be adequate for +

the system' operating with the most limiting combination of i flow and temperature.

g

.i i .- APC) R3sp:nsa to. -

G:nzric Letter 89-13

, Pega 5 C. Air-to-Vater Heat Exchangers (In' addition te' Item'A~above)

1. Perform etficiency testing (for example, in conjunction'vith.  !

surveillance testing) with the heat exchanger _ operating .;

under the maximum heat load'that,can be obtained practically .:

F and' correct the results for off-design conditions.L Verify.

design heat removal capacity-and trend results to_ identify any degraded equipment..-

2. If it-is not possible to test the heat exchanger.'to' provide

~

j statistically significant results (for: example, if error in

~

the' measurement exceeds the~value of the parameter being:

measured), then trend test results for.both the air andz vater flow rates in the heat exchangers and perform visual

~ inspections, where possible, of both the air and water sides of the heat exchanger to ensure cleanliness'of the heat exchanger. >

D. Heat Exchangers Other than Vater-to-Vater and Air-to-Vater '

(In Addition to Item A above)

1. If plant conditions allow testing at design heat removal conditions, verify.that'the heat exchanger performs its intended functions and trend the test:results to monitor-degradation.

7 2 .- If testing at design conditions is not possible', then._ _

provide for extrapolation of test' data to design. conditions., ,

The heat exchanger ef ficiency or the' overall--heat transfer a coefficient of the heat exchanger,should be determined ~ )

whenever possible. Where possible, provide for visual inspection of the heat exchanger.

APCo Responset APCo vill develop a test program prior to startup:from the Unit 2 Fall ,

1990 Refueling Outage to verify the-performance capability of safety it related heat exchangers cooled by service water to: ensure they can perform their safety related function. The test program vill require the performance testing of each heat exchanger.once during'ench refueling cycle for'three cycles. The results will.be'used to  !

determine the appropriate frequency for future testing to provide. .

assurance that the equipment vill perform the intended safety.

functions during the intervals between tests. Tests will:also'be-performed after any corrective maintenance that could: affect.the heat-exchanger performance. .All relevant documentation vill be retained in appropriate plant records.

APCo has reviewed the chemistry control program for the component cooling water (CCV) system and verified-that chemistry control for.the- ,

CCW system has been implemented over the operating history for-both-Units-1 and 2. If the performance of the CCW heat. exchanger trends-downward vithout logical explanation and-the' downward trend cannot be- '

remedied by corrective action on the service _ vater side of the CCW heat. exchanger, APCo will investigate the reasons for'the downward v trend in the heat exchanger performance and determine the appropriate- 7 corrective action fcr the CCV system.

C h_; -

?.- . APCD Risp:ns3-to" q 4

G:nsric Lattor 89-13 t .

P2g3 6. ] 3 e g -

l L Testing of the safety related heat exchangers cooled by service' vater . ,

vill be performed with necessary and= sufficient' instrumentation,-

considering both permanently installed and temporary > instrumentation. )

The test program vill address the: evaluation of relevant temperatures-vith respect to. design limits.. )

Vith regard to frequent regular maintenance of a heat exchanger in j L lieu of testing for degraded performance, APCo currently has in place ,

regularly-scheduled preventive maintenance (PM) tasks for inspecting-and cleaning, as necessary, the following safety related heat exchangers:

i  ;

L t Diesel Generator Jacket Unter Coolers-

~

1. j

2. Diesel Generator Lube Oil Coolers

3. Diesel Generator Turbocharger /Aftercoolers ,

4. All~scfety related room coolers-

5. CCW Heat Exchanger Alabama Power Company plans to continue to perform these PM tasks'for ,

each of these heat exchangers; however, the PM tasks'for the diesel:

generator lube oil coolers'and turbocharger.aftercoolers vill be used in lieu of periodic testing to ensure acceptable performance of these heat exchangers.

FNP has a heat exchanger testing program in placeLfor safety related room coolers (air-to-vater heat exchangers) cooled by service water.

The purpose of this program is to monitor the heat-removal capability of the heat exchangers by determining the overall heat transfer coefficient for the heet exchanger based on the test conditions and '

comparing this information to the overall heat. transfer coefficient required to temove the design safety function heat removal. -The overall heat transfer coefficient determined from=the test has also been used to predict when corrective action (such as cleaning:of the heat exchanger) needs to be performed.- This testing methodology i provides a means for comparing the heat exchanger performance to the l design heat removal requirements and allows the performance-to be j trended. Accordingly, APCo plans to' adopt this same methodology to i I

the other heat exchangers required to be tested in response to this ~

) generic letter.

The following information addresses the aspects of the heat exchanger testing program described.in Enclosure 2 to the generic letter as they relate to the service water system safety related heat exchanger testing program being developed for FNP.

+

i I

V b

___.'. - - _ _ . _ _ _ . _ _ _ +_. . _ _ _ _ _ _

. APCo Rssp:nta to? . j

gin 2ric Lettsr 89-13' ';

. Paga:7:> -j 1

A. All Heat Exchangers ]

~

The' service water flow and the service' vater inlet and outlet temperatures vill be verified to be within design limits for the conditions of the measurement. LAs described above, the

-determination of the overall heat transfer coefficient for the i heat exchanger at the conditions of the measurement.and the

-comparison of this information-to the overall. heat transfer

. coefficient.at the design heat removal requirements provides an. ,

adequate means to ensure'that-flow blockage or excessive' fouling ,

accumulation does not-exist.- Additionally, since service water J flows will'be measured as a part of.this program, APCo' vill trend 1

the flow measurements' for indications :of potential: flow blockage - '.

or excessive fouling. accumulations.-

t B.. Water-to-Vater Heat Exchangers (In addition to Item A above)

The safety related. vater-to-vater heat exchangers cooled by service water are the CCW heat-exchangers and the diesel ,

generator jacket water coolers. 'As described above, PM tasks are performed on both of these heat exchangers. However, a heat exchanger testing program vill be developed for_both of these heat exchangers which determines the.overall heat transfer coefficient at the conditions of'the measurement and compares it-to the design heat removal rate.

I C.- Air-to-Vater Heat Exchangers (In addition to Item'A above) l As . discussed 'previouslyi = APCo has a heat exchanger: testing -

program in place for the safety related' room coolers cooled by.

service water. The other safety related air-to-vater, heat '

exchangers cooled by service water are the containment coolers-and the diesel generator turbocharger aftercoolers. ..A testing-program vill be developed for,the containment coolers / consistent with the room cooler testing program. The diesel generator turbocharger.aftercoolers vill-be periodically inspected and j cleaned as a PM task in-lieu'of testing.

Furthermore, if it is not possible to'obtain' statistically significant results (i.e., the error in the measurement exceeds the value of the parameter being measured), APCo vill ~either

~

verify _that the service water flow meets the design requirements and perform a visual inspection'of the air-side of the heat'

-exchangers or retest the heat exchanger at an. appropriate time to obtain statistically significant results.-

i

l l

I I

1

]

I

^*f. ~APCo R:sp:ns2'to.

. Generic LettOr 89-13  :

Paga,8L J

D. Elent Exchangers.0ther than Vater-to-Vater'and.

Air-to-Vater -(In ' addition to Item A above)

The safety related heat exchangers cooled by service' I t.

water in'this category are the_ control room air ~

L conditioning condenser (Freon), the diesel generator lube oil coolers (oil), and.the_ service water pump motor i lube oil coolers-(oil).; As previously mentioned, the. 1 diesel generator lube oil coolers are periodically _ '

cleaned through PM tasks and are therefore not' required

!- to.be addressed in the testing-program. APCo. vill

. develop'a testing program for.the control' room air conditioning condenser.and the service water pump motor lube oil coolers basedion.the previously described room  ;

cooler testing program.- l!

i:

III. NRC Recommended Action:

L Ensure by establishing a routine' inspection and maintenance L program for open-cycle service water system' piping and-l.

components that corrosion, erosion, protective coating _

failure, silting and biofouling cannot degrade the 1

i. performance of the safety related systems supplied by ~!

l' service water. The maintenance program should have at f least the following purposes: 1 p

-1. To remove excessive accumulations of biofouling agents,-

corrosion products, and silti-i p 2. To repair defective protective coatings and corroded service l vater system piping and components.that could adversely l

I_

affect performance of their intended safety functions.;

1

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 these maintenance. inspections. I should be documented. All relevant documentation should be retained in appropriate plant records, i APCo Response:

)

As discussed in the' response to Action II, APCo j periodically inspects the safety related room coolers, the '

CCV heat exchangers, and the diesel generator heat exchangers which are cooled by service water for fouling, j corrosion products and silting accumulations. APCo has  ;

also previously inspected portions of the service water  ;

system piping utilizing ultrasonic testing and radiographic testing to identify pipe thinning and pipe blockage.- Where appropriate, corrective actions have been instituted.

These corrective actions include sandjet cleaning of some  !

lines and replacement of safety related two inch and under carbon steel lines with stainless steel to reduce fouling i accumulations in the lines. Additionally, APCo plans to i start adding a chemical dispersant to the service water 1 system in 1990 to aid in removing solids from the service water system.

P E,. '. APCp R p;ns3 to  ;

G:nsric Lettor 89 . Paga 9

• Furthermore, the FNP administrative procedure;for contro11 '

of plant maintenance contains a-clam inspection report

- which must be completed any time a heat exchanger supplied by service water is opened. These inspection and r maintenance actions are a part of the overall program that ensures the' acceptable performance of'the service water system. APCo vill develop-an ongoing inspection and maintenance' program for the service water system safety  :

related heat exchangers and piping prior to plant startup from the Unit 2 seventh; refueling outage,. currently scheduled for the Fall of 1990.

l The room cooler performance testing has been used as a' -

means to indicate when corrective maintenance on the system.

is needed. The total heat exchanger performance testing l ._

. program vill be used in the future to indicate.vhen corrective maintenance on the system is needed. Since the heat exchanger testing, program vill form the baseline for ,

verifying the service water system meets its' design requirements, this testing program vill also form the basis  ;

for the APCo inspection and maintenance program. All relevant documentation will be retained in appropriate

. plant records.

IV. NRC Recommended Action:

Confirm that the service water system vill perform its intended function in accordance with the licensing basis for the plant. Reconstitution of the design basis of the system'is not intended. This confirmation should include a review of the ability to perform required safety functions in the event of failure 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.(vithinlthe past 2 years) system walkdown inspections. 'This confirmation should be completed before plant startup following the first refueling outage beginning 9 months or more after the date of this letter. Results should.be documented and retained in appropriate plant records.

APCo Response APCo conducted a Self-initiated Safety System Assessment (SSSA)-of the service water system in May and June of 1989 and the.CCV system in August and-September of'1989. These SSSAs were based upon the vertical-slice inspection sampling technique utilized in NRC Safety System Functional Inspections-(SSFIs)=and consisted of an integrated design' and operation review for consistency and adequacy. As a part.of the design-review performed in these SSSAs,

-potential single failures and common mode failures were postulated and evaluated for the adequacy of the system design. Selected plant operating and maintenance procedures and practices were then reviewed for consistency i

t

' L. ; . "APC3 R:sp:n23.to

^

'; G:n2ric Lettor 89-13

. P gs 10-vith the design and licensing basis to: ensure that the 'I

. system' vill. perform its intended function in accordance with the licensing basis for the plant.- For.the service- '

vater system SSSA,fselected system valkdowns were also conducted. ,

one of the corrective actions resulting from the: service. d

-vater system SSSA is-the development of a system flow-; ,

balance model.. Although not yet complete, this action involves'the review of piping physical and-isometric drawings to accurately model the system, reevaluation of l the failure' modes'and consequences for the: service water ,

system, and field = flow, measurements for validation of the model. As a~ result'of developing this model, the' system b configuration and system operation has been further . i reviewed for-potential single failures. Upon' completion of? +

the model and evaluation of the post-accident. response of

~

the service vater system, the appropriate changes vill be '

implemented, as necessary. Additionally, this new model vill supersede the old design 1 basis hydraulic calculations b .for the service water system.

l The field flow measurements for validation of the mo' del-consisted of measurements of flov to each diesel generator, total service water pump motor lube oil cooling flow, flow to'all other safety related heat exchangers cooled.by service water, flows to some.non-safety related' loads on  ;

the system, and other strategic locations (such as pump: '

discharge flows, total flows to separate buildings, and potential 1 bypass flows). The valkdowns performed in L

preparation for, and in conjunction with, these flov measurements did not identify any physical-discrepancies -

between the as-built system and.the licensing basis-documentation. Some minor differences in'-system operating -

practices and the previous design basis hydraulic calculations were observed and are being-factored-into the flow balance model development. -Although a complete-system =

valkdown has not been conducted, APCo believes sufficient valkdowns have been performed to ensure the safety'related portions of the service water system are in accordance with the appropriate licensing basis documentation.

Since the CCW SSSA did not contain system valkdowns, selected system valkdowns of the CCW system vill be i conducted for consistency with the appropriate licensing basis documentation prior to startup from the Unit 2 Fall j'

1990 Refueling.0utage and the' Unit l' Spring 1991' Refueling

• Outage.  ;

1 APCo considers the reviews performed by the SSSAs'and the corrective actions resulting from the SSSAs, including the j service water system flow balance model development,.  !

sufficient to ensure the service water system and the CCV system vill perform their intended function in accordance with the licensing basis of the plant. 1 4

l

\

• - . . . 'i- .APCa1Risp:nr3 to .  :

- 'G:nsric Letter 89-13' i Pega ll; ' l  ;

.,, s

.V., NRC Recommended Action Confirm that maintenance practices, operating and emergency procedures, and training that involves the-service vater system are adequate to ensure that safety related equipment J cooled by the service water. system vill function as

-intended and-that operators oftthis equipment vill perform effectively. This confirmation:should include recent _ l (within the past.2 years) reviews of practices, procedures- i and training modules.- The~ intent of this action is to  !

reduce human errors in~the operation, repair and.  ;

maintenance of the service vater system. This confirmation.  ;

should be completed before plant.startup following~the i first refueling outage beginning 9 months or more after the date of this>1etter. -Results should be. documented and'

. retained in appropriate plant records.

APCo Response

i As discussed above in the~ response to Action'IV, the 9 service water system and CCW system SSSAsl reviewed selected maintenance practices and operating procedures. -The emergency operating procedures as they relate to the service water system and CCV system were reviewed during the SSSAs. The service water system SSSA also reviewed the training program as it relates to the service water system. -

Corrective actions necessary to ensure proper system operation vere documented as a part of the SSSAs, Additionally, the effects.of-operating. practices upon the flow balance of the service water system are being incorporated into the flow balance modelidevelopment. Any changes in operating or' maintenance practices, emergency-procedures or the training program-necessary to ensure'the acceptable operation of the service vater system as a result of completing the SSSA corrective actions,: including the service water system flow balance model, vill-be addressed.

Furthermore, APCo plans-to develop a functional system

• description (FSD) of the service water system and CCW

, system in 1990. The purpose of the FSDs is to' consolidate current system and component functional ~ design requirements '

i. for all modes of operation of these systems,in an understandable and easy-to use format. The FSDs vill then be reviewed against current. operating and. maintenance practices and procedures, emergency procedures, the -

training program and other plant programs, as appropriate, to ensure consistency between the design 1 functional requirements and these procedures and programs. This reviev vill provide added assurance that the' service water 1 system and CCW system vill function as intended and that operators of this equipment will-perform effectively. 'APCo plans to complete this review prior to plant startup from the Unit 2 Fall 1990 Refueling Outage.

LCT/m.1432

_ ~_ __ a