ML20083D014

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Intervenor Exhibit I-MOSBA-13,consisting of 890217 Sworn & Subscribed Memo to NRC Re GL 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Equipment
ML20083D014
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/19/1995
From: Hairston W
GEORGIA POWER CO.
To:
References
CON-#295-16686 GL-88-14, OLA-3-I-MOS-013, OLA-3-I-MOS-13, NUDOCS 9505230262
Download: ML20083D014 (29)


Text

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U. S. Nuclear Regulatory Comission 'Y Re ion II, Suite 2900

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10 Marietta Street N. W. 5 MCDVED W f6 W '

Atlanta, GA 30323 AM { {

V0GTLE ELECTRIC GENE NITS I and 2 'of

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GENERIC LETT N0., 88-14 INS UMENT AIR SUPPLY SYSTEM PROBLEMS AFFECTING 5AFXIY RELATED EQUIPMENT Gentlemen:

Generic Letter 88-14 requested that each licensee / applicant review NUREG -

1275, Volume 2 and perform a design and operational verification of the instrument air system. A response to this generic letter was to be submitted to the NRC within 180 days.

Attached is a response to the identified concerns of NUREG - 1275, Volume 2.

The reviews and/or investigations indicate that the design, installation, testing, operation and maintenance of the instrument air systems at Plant ,

Vogtle are adequate to ensure the proper and reliable operation of pneumatically-operated, safety-related equipment.

If you have any questions, please advise.

Mr. W. G. Hairston, III states that he is a Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

GEORGIA POWER COMPANY By: Id . k W W W. G. Ha'rston, III i Sworn to and subscribed before me this /75 day of February, 1989. I 1

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J NUCLEAR rf GULATORY COMMISSION so <<x s-cu,3 Docket No_ S'- v a r-eta.3 Cif;c:al Exit. No' In the m0: Int z.(

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ELV-00197. -

Page 2

Enclosure:

cc: Georgia Power Company Mr. P. D. Rice Mr. C. K. McCoy Mr. G. Bockhold, Jr.

GON0RMS U.S. Nuclear Regulatory Consission Mr. M. L. Ernst Acting Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)

Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle O .

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. j cx hibit IA,page 3 of l

\ V0GTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 RESPONSE TO GENERI: LETTER 88-14 G.L. Item 1: Verification by test that actual instrument air quality is con-sistent with the manufacturers' recossnendations for individual components served.

A. Action Plan:

1. Verify the Instrument Air Quality from performance of pre-operational test procedures.
2. Periodic verification during performance of preventive I maintenance (PM) tasks associated with the Instrunent Air System.
3. Select sample points and conduct additional in-plant testing i to measure actual instrument air quality.
4. Verify diesel generator air start system air quality from I preoperational test procedures.

B. Response:

O Testing of instrument air system air quality has been accomplished as follows at VEGP: J

1. Testing activities during the performance of preoperational l test procedures consisted of verifying the air quality (moisture and oil content) innediately downstream of the afterfilter for each set of dryers and at the end of selected feeder lines. This testing was accomplished in accordance with the VEGP stated position of conformance to Regulatory Guide 1.68.3 which is provided in FSAR Section 1.9.68.4.2. This statement of conformance coimaitted VEGP to meeting the quality requirements of ANSI /ISA S7.3-1975 l for verifying moisture and oil content and noted that veri- I fication of particulate size at the end of each feeder line l 1s not considered necessary at VEGP since "the VEGP instru-ment air system design is such that instrument air is filtered at the dehumidifier and at each instrument (by a local filter / regulator) in accordance with individual instrument manuf acturer's requirements." To meet the requirements of ANSI /ISA 57.3-1975, the acceptance criteria for maximum allowable oil content was established as 1 1 ppe (w/w) and the maximum allowable moisture content was j established at -150F dewpoint at line pressure (see FSAR Section 9.3.1.2.2). The results of the preoperational test-ing of instrument air quality are tabulated in Tables 1 and
2. These results show that preoperational testing verified that the instrument air systems for both units meet the O moisture and oil content requirements of ANSI /ISA S7.3-1975. )

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1 Mibit.L-.,page ? 012j{

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RESPONSE TO GENERIC LETTER 88-14 .--

Page 2

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2. For Unit'1, periodic verification during performance of PM: .i tasks consisted primarily of verifying the air-quality (moisture and oil content) ismediately downstream of the' .

afterfilter for each set of dryers.: . Verification of moi ture '

content (dewpoint) at the end of a representative-feeder line  !

has also been performed on eight separate occassions. The PM acceptance criteria for maximum allowable oil content is established as .1 ppe (w/w) and maximum allowable moisture - ,

content is established as.-600F dowpoint at line pressure. l The results of the PM verifications of instrument air system I air quality are tabulated in Table 3. These results show that l oil content has consistently been verified to be O ppm-(a i few measurements were recorded as less than 1 ppe); however, i dewpoint, on occasion, has been found to exceed the PM accep- i tance criteria of -600F. In these cases, corrective -

maintenance was typically required to restore the dewpoint I to less than -600F. While the dowpoint has been found to i exceed the PM acceptance criteria in several instances 1 (typically due to a malfunctioning' solenoid valve associated with the dryers), the dewpoint has still consistently, been verified to be less than the ANSI /ISA $7.3-1975 requirement of -150F at line pressure.' This demonstrates that the VEGP O instrument air system design is such that high quality instrument air can typically be supplied even with a sul-functioning system component. 1 i

i Verification of particulate size has not been performed as a part of the PM verifications of instrument air quality; such verification has not been considered necessary for the same reason as stated previously for not performing such verification during the preoperational tests for the instru-ment air system. However, as a part of the inspections '

performed per PM checklist SCL00285, ' Valve / Damper Stroke",

the local air filters / regulators for approximately 39 safety related air-operated valves were inspected during the Unit I first refueling outage (Fall. 1988). These inspections veri-fled that no cleaning or replacement of the air filters was required. Vogtle Electric Generating Plant considers that periodic inspection and cleaning or replacement as necessary of these local air filters for each safety related air +

operated component is an appropriate method of ensurin that instrument air quality is maintained consistent with t ,

manufacturers' recosumendations for size of particulates con-tained in the air stream. The VEGP program for performing such periodic inspections is discussed later in this response.  :

3. Additional inplant testing of the operating Instrument Air System consisted of verifying the oil content and dowpoint O for five (5) instrument air feeder lines. The results of this testing are tabulated in Table 4. These results show ,

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. 1 RESPONSE TO GENERIC LETTER 88-14 Page 3 that the oil content and dewpoint was again verified to meet the. requirement of ANSI /ISA 57.3-1975. This testing, com -

bined with the periodic PM measurements of air quality, is considered as sufficient for reverifying the air quality testing results of preoperational test 1-3KB-01 for VEGP Unit 1. The air quality. testing results of preoperational test 2-3K8-01 for VEGP Unit 2 are still considered current 2 and therfore reverification of those results is not con-sidered necessary at this time. ,

Vogtle Electric Generating Plant concludes that the above testing has been sufficient to verify that actual instrument air system air quality is consistent with the manufacturers' recommendations for individual components served. This conclusion is made based on a review that was conducted of the manufacturers' literature associated with individual air operated components. This review indicated that while certain reconsnendations, such as "ffitered,' ' dry,' or " oil free,' have been made for the supply air, quantitative air quality requirements have not been specified. The above described testing verified moisture and oil content to be consistent with the quan-titative requirements of ANSI /ISA 57.3 - 1975 and the inspection of O local air filters (Unit 1) verified particulate size to be acceptable for 4 fore Jment air as supplied to the individual components. There-instrument air system air quality is considered as having l'

beer, " .fied as consistent with the manufacturers' reconmendations.

Testing of air quality for the diesel generator air start system has l also been accomplished for VEGP Units 1 and 2. The VEGP diesel j generator air start system was supplied by Transamerica Delaval.

(Note: YEGP diesel generators are also Transamerica Delaval) and consists of two separate cospressed air systems or trains per diesel, ,

with each individual train consisting of one suction filter, com-pressor, aftercooler, air dryer, and air receiver. Downstream of each air receiver is a y-strainer / filter for removing particulates and oil. Further downstream, filters exist for the starting air distributor and for the engine control panel. The maximum dowpoint ,

acceptance established ascriteria 500F'atfor the VEGP system pressure diesel air start Table.9.5.5.

1(see.FSAR. system has..l.been Q This dewpoint criteria was established based on the design capability  ;

of the air start system, the fact that the air is compressed..to f which raises the dowpoint, and the minimum -

between 225 and diesel generator 250des room psig,ign temperature of 500F. Preoperational f test procedures 1-3XJ-01 " Diesel Generator Train A Starting Air i System" (Unit 1), 1-3KJ-02 "Otesel Generator Train B Starting Air j System" (Unit 1), 2-3KJ-01 Diesel Generator Train A Starting Air .

System" (Unit 2), and 2-3KJ-02 " Diesel Generator Train 8 Starting l Air System" (Unit 2) included a verification of dewpoint for starting air contained in each receiver. The results of this preoperational O verification of dewpoint are tabulated in Table 5. These results r

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  • 'i Exhibit O,page Of N RESPONSE TO GENERIC LETTER 88-14 Page 4 show that the dewpoint acceptance criteria was met for all but the No. 2 air start train for the Unit 1 "B" diesel. After replacement of a bad condenser fan motor and recharging the dryer with refrigerant, this air start train was also verified to meet the iewpoint acceptance criteria.

Testing of the diesel generator air start system for particulate and  ;

oil content is not considered necessary due to the system design which includes the previously mentioned y-strainer / filter and downstream filters. Transamerica Delaval (now IM0 Delaval) has  !

specified the exact filters to be used in these applications. These filters are periodically inspected and cleaned or replaced in accordance with the generic maintenance recomendations developed by the Transamerica Delaval owner's Group (see Appendix II of the TDI Diesel Generator Design Review and Quality Revalidation Report -

VEGP: Note: This report was previously submitted to the NRC). The VEGP program for performing these periodic inspections is discussed in more detail later in this response.

A review was conducted of Transamerica Delaval recomendations and of the recommendations developed by the Transamerica Delaval Owner's Group. This review indicated that quantitative air quality q requirements have not been specified for the diesel generator air Q start system. Therefore, VEGP considers that the air quality testing I

performed during preoperational tests 1-3KJ-01,1-3KJ-02, 2-3KJ-01 '

and 2-3KJ-02 was sufficient to verify the air quality of the diesel air start systems for Units 1 and 2 consistent with the manufacturers' reconvendations.

G.L. Item 2: Verification that maintenance practices, emergency procedures and training are adequate to ensure that safety-related equip-ment will function as intended on loss of instrument air, j

A. Action Plan:

1. Evaluate current maintenance programs and practices to deter-mine overall adequacy for components within the scope of the generic letter.
2. Review plant procedures designed to mitigate the effects of a loss of instrument air.
3. Review the content and scope of training programs for  !

adequacy in the area of required response to a loss of 1 instrument air.

I O

i, Shibit O ,page 1 of o RESPONSE TO GENERI: LETTER 88-14 Page 5

8. Response:
1. Maintenance Practices

' Maintenance on saf ety-related air-operated components is ,

controlled by Maintenance Work Orders (MWO's) issued per the instructions of Procedure 00350-C 'Maintenarce Program," l and by various task specific procedures which are identified as appropriate when preparing the detailed work isntructions for the MW0. Examples of a few of the different procedures that might be identified on tne MWO as required for main-tenance on air-operated components are: ,

25036-C " General Valve Packing" l 26060-C 'ASCO Solenoid Valve Maintenance" l 26081-C ' Copes Vulcan D-100-60, 100, 150, 400 Valve Maintenance" 26844-C 'A0V Diaphram Replacement" 26850-C ' Fisher Type 67AF and 67AFR Regulator Maintenance" On cospletion of the maintenance task, the Work Planning 4

Group assigns a functional test to the Nd0 using Procedure 29401-C ' Maintenance Work Order Functional Tests" as a O guideline. Included in Attachment A of Procedure 29401-C.

Rev. 3, are specific guidelines for functional tests to be performed on air-operated valves (A0V's). An A0V failure mode check (fall open, fail close) is specified as one of the checks required following replacement of the actuator, the valve portion, or the entire A0V. Procedure 29007-C

' Air Operated Valve Post Maintenance Verification," Rev. O, includes specific guidance for checking that a safety-related A0V will properly assume its " failsafe" position both on slowly bleeding-off supplied air pressure and on suddenly venting supplied air pressure.

The above described maintenance practices are considered adequate for ensuring that safety-related air-operated l components will function as intended on loss of instrument l air.

2. Emergency Procedures 1

Procedures are provided to assist operators in the identi-  !

fication, control, and recovery from a partial or total loss

, of instrument air event. Alarms on the main control board include " Service Air Header lo Press' which alarms at 95 psig in the service air header and " Inst Air Equip to Press 150' which alarms at 70 psig in the Turbine Building air header. (Note: The service air header isolates at j 80 psig and the Turbine Building air header isolates at j l

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xhibit O ,page I of n '

RESPONSE TO GENERIC LETTER 88-14

.Page 6 70 psig). Annunciator Response Procedure (ARP) 17001-1, L Rev. 10, describes actions to take on receipt of these  ;

i: alarms. For the service air header low pressure alarm. ARP-17001-1 directs the operator to go to abnormal operating procedure (A0P) 18028-C " Loss of Instrument Air," if pres-sure continues to fall and cannot be restored. For.the instrument air equipment low pressure isolation alarm. ARP 17001-1 directs the operator to go ismediately to AOP 18028-C. A0P 18028-C, Rev. 4, lists other symptoms of a loss of instrument air to ensure identification of such an event. ADP 18028-C identifies critical components operated by instrument air and describes failure modes of ,

which the operator needs to be aware. The note. preceding '

Step A2 identifies that a loss of service air will result in failure of the fuel transfer canal and/or cask loading pit gate seal assemblies. The note preceding Step A4 identifies that a loss of Turbine 8uilding instrument air will close all extraction steam non-return valves and will fail all feedwater heater high level dump valves fully open. While the " failsafe' position assumed by safety-related air-operated components on a loss of instrument air is essential to ensure O mitigation of accidents and events described in the safety analysis AOP 18028-C recognizes that the " failsafe" positions for some components may not be favorable or appropriate for actual existing plant conditions and therefore directs the operator to either take manual control or bypass certain l specific components when appropriate to maintain control of '

the plant. The note preceding Step 86 identifies that a loss of instrument air will cause the positive displacement charging pump to fail to maximum speed and the note pre-ceding Step 87 identifies that the reactor coolant pump seal injection flow control valve will fail open. Under non-accident conditions, these " failsafe' positions would result ,

in an increasing pressurizer level. AOP 18028-C therefore '

directs the operator to close the charging header isolation valves if pressurizer level is rising and to bypass the seal injection flow control valve and to throttle the bypass valve to maintain RCP seal injection flow within the proper range.

Other examples exist in A0P 18028-C where the operator is directed to take manual control or bypass certain " failsafe" )

components dependent on actual plant conditions. On recovery t from a loss of instrument air, if in Mode 1 or 2, A0P 18028-C directs the operator to initiate system operating procedures 13710-C " Service Air System' and 13711-C " Instrument Air System" to ensure systems are restored to normal; for Modes 3, 4, 5, and 6. AOP 18028-C contains the appropriate steps to restore potentially impacted systems to normal, e Emergency Operating Procedures (E0P's) also contain guidance when appropriate for operator actions to be taken when

Exhibit O,page 9 of M RESPONSE TO GENERIC LETTER 88-1,4, Page 1

nstrument air is not available. E0P 19002-C " Natural Circu- ,

lation Cooldown," Rev. 6, includes a note prior to Step 4 '

indicating that makeup to the volume control tank is not possible without instrument air available. Attachment.A >

of E0P.19030-C, " Steam Generator Tube Rupture," Rev. 7, pro-  !

.vides instructions for establishing charging flow without instrument air available and applies to Step 22 of that  :

procedure. ,

The types of procedural controls as discussed above are con-sidered adequate for ensuring that safety-related air-operated components will function as intended on loss of instrument air. ,

4

3. Training Current training for licensed operators includes lesson plans, instructional units, and simulator exercises as follows:

LO-LP-02110 . " Service and Instrument Air Systems" l O LO-IV-02110-001 ' Start Air Compressors" LO-IU-02110-002 " Respond to Instrument Air System Alarms" LO-IU-02110-003 ' Respond to. Service Air System Alarms" LO-IU-02110-004 ' Respond to a Loss of Instrument Air to Containment" LO-SE-60019 'RHR Operations With Malfunctions" LO-SE-60023 ' Coolant & Feedwater & Air Systems Malfunctions" LO-LP-60321 ' Loss of Instrument Air" LO-IU-60321-001 ' Respond to Loss of Instrument Air"-

Lesson Plan LO-LP-60321 is based on abnormal operating procedure (A0P) 18028-C and includes training on how to detect a loss of instrument air, response of critical components to a loss of instrument air, how to compensate for certain critical components assuming failure positions which are not necessarily favorable for actual plant conditions, and how to recover from a loss of instrument air. Simulator exercise LO-SE-60019 introduces a loss of instrument air during operations associated with plant shutdown (Mode 5) and simulator exercise LO-SE-60023 introduces a loss of instrument air during power operation (Mode 1). The operator is expected to utilize the guidance of A0P 18028-C for responding to both simulator exercise scenarios.

Current training for non-licensed operators includes lesson plans and instructional units as follows:

NL-LP-02201 " Service and Instrument Air Systems -

Outside Area Operator"

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.xhibit I

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RESPONSE TO GENERIC LETTER 88-14  :

Page 5 l

i NL-LP-02301 " Service and Instrument Air Systems -

Turbine Building Operator" l NL-!U-02301-00-001 " Perform Service / Instrument Air Start-Up ' l Inspections" NL-!U-02301-01-002 " Operate Air Dryers" r NL-IU-02301-01-003 " Blowdown Moisture Separator Drain Traps and Air Receivers" NL-!U-02301-01-004 " Cross-Connect Unit Compre ned Air Systems" l NL-!U-02301-01-005 " Restore Instrument Air to Turbine Building Following Isolation"

.NL-IU-02301-00-006 " Restore Service Air Following Isolation" NL-IU-02301-01-007 " Check Proper Operation of Rotary Air t Compressor" NL-!U-02301-00-008 " Check Proper Operation of Reciprocating Air i

Compressors" NL-!U-02301-01-009 " Check Operation of Master Energy -

Conservator" NL-LP-02401 " Service and Instrument Air Systems -

Auxiliary Building operator" NL-LP-53112 " Introduction to Valve Actuators" NL-!U-53112-00-001 " Verify Power-Operated Yalve Operation" O NL-LP-53170 " Introduction to Basic Air Compressors" NL-LP-02201, NL-LP-02301, and NL-LP-02401 provide training on the purposes of the instrument air system,.flowpath, identification of major air-users, expected response of major components to a loss of instrument air, and pertinent

. industry events. The discussion of industry events is based on events described by NRC Information Notice 87-28 NUREG-1275, Vol. 2, and 50ER 88-01 and is intended to sen-sitize the plant equipment operator to the importance of the instrument air system and to problems which could occur if instrument air quality is allowed to degrade.

Current training for maintenance personnel includes Lesson Plan ME-LP-10003 " Air Operator Maintenance " which is pro-vided to mechanical maintenance personnel and GE-LP-12516,

" Service and Instrument Air," which is provided to I & C personnel.

HE-LP-10003 provides training on the basic purpose and principle of operation of air operators, various types of '.

air operators, general maintenance practices for trouble-shooting comenon mechanical and operational causes of air operator failures, and includes a review of NRC Information Notice 87-28 NUREG-1275, Vol. 2, and 50ER 88-01 to empha-size the need to prevent degradation of the instrument air i

O system by allowing foreign material such as oil, water, dirt, or debris to enter the system while performing main-tenance. GE-LP-12516 provides training on the purpose of i

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  • . Exhibit b ,page d ofM

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RESPONSE TO GENERIC LETTER 88-14

, Page 9 the instrument air system, major components, functions'and flowpath, emphasizes that significant. problems have occurred at various nuclear plants due to the contamination e of instrument air'and instructs the student to observe for .,

contamination while performing maintenance on the instrument l air system or components serviced by instrument air.

The above described training for licensed operators, non- i licensed operators, and maintenance personnel has been  !

reviewed against the recommendations of NUREG-1275, Vol. 2 j and revised where appropriate to' incorporate those recommen-dations. This training is considered adequate.for ensuring that safety-related equipment will function as intended on loss of instrument air.

G.L. Item 3: Verification that the design of the entire instrument air system l including air or other pneumatic accumulators is.in accordance l with its intended function, including verification by test that ;I air-operated, safety-related components will perform as expected l in accordance with all design-bases events, including a loss of the normal instrument air system. 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.

A. Action Plan: '

i

l. Identify, by reviewing plant design documentation, the system ar.d component level safety design bases.
2. Create a list of all safety-related components within the scope of the generic letter.
3. Review the testing that was performed for each safety- '

related component within the scope of the generic letter.

4. Schedule any additional safety-related component testing required.

B. Response:

Safety-related active instrument air users for YEGP Units 1 -

and 2 are tabulated in Tables 6 and 7. The current failure position for each of these components, as indicated on Piping and Instrumentation Diagrams (P & ID's), was checked against

the FSAR-FMEA Tables and/or design calculations as appropriate.

The current failure positions for these components were verified to be correct for assuring the required safety functions.

O 4

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i Exhibit O,page J2ing 9 i

RESPONSE TO GENERIC LETTER '88-14 - -

Page 10  ;

With exceptions as noted below, loss of instrument air pressure -

tests were performed for the components listed in Tables 6 and 7 .!

during construction acceptance testing for each unit. The air-

-operated valves listed in Table 6 were individually tested in accordance with construction acceptance. test CAT-M-04 " Air Operated Valves." The air-operated dampers listed in Table 7 were individually tested in accordance with. CAT-M-07 "HVAC Pneumatic Operated Dampers." This testing was performed to meet ,

the VEGP stated position of conformance to Regulatory Guide 1.68.3 which is provided in FSAR Section 1.9.68.4.2.

Loss of instrument air pressure testing performed per CAT-M-04 i consisted of placing the valve opposite to its fail-safe position and then verifying the valve properly moved to its fail-safe position on slowly bleeding off the air from the actuator and, as applicable, on suddenly venting the positioner or con-troller air supply port to atmosphere. Loss of instrument air pressure testing performed per CAT-M-07 consisted of placing the damper opposite to its fail-safe position and then verifying l the damper properly moved to its fail-safe position on slowly  !

reducing the air pressure to the actuator.

> O The main feedwater isolation valves (i.e., valves 1HV5227.-

INV5228, lHV5229, lHV5230, 2HV5227, 2HV5228, 2HV5229, and 2HV5230) were not CAT-M-04 tested. These valves are hydraulic actuated valves but require a source of air to' perform their

' safety function in that air-operated pilot valves have to repo-sition on a feedwater isolation signal to allow the flow of hydraulic fluid to the appropriate side of the hydraulic piston.

The source of air is ensured by air reservoirs and instrument air check valves which seat when supplied instrument air pressure is decreased. The VEGP MFIV's are the same valves as those des-cribed in NRC Information Notice 85-35 and which are used as main steam isolation valves at Byron Unit 1. Following issuance ,

of Notice 85-35, the VEGP MFIV's were modified by replacing the j air check valves with those of a slightly different design. 'The 1 ability of these air check valves to seat on a gradual loss of supplied instrument air pressure and to therefore not impact the ability of the W IV's to perform their safety function is a c periodically verified in accordance with testing performed per Procedure 14850-1 (14850-2) " Cold Shutdown Valve Inservice Test."

This testing is considered adequate verification for the MFIV's <

as required by the Generic Letter. I Dampers AHV12479, ANY12480, AHV12481, AHV12482, lHV12604,

' lHV12605, lHV12606, lHV12607, 2HV12604, 2HV12605, 2HV12606, and 2HV12607 are air-operated dampers, but are also equipped with an inflatable bubble tight seal. A source of air is ensured by a reserve air storage tank and an instrument air check valve for O each damper. A CAT-M-07 test was performed for each of these dampers which verified that each properly assumed a closure position on loss of instrument air.

f,' - Exhibit' O ,page 02 of M

< 1 D ~~' RESPONSE TO GENERIC LETTER 88-14 ,

Page H l CAT-M-07 does not include confirsation of' proper operation of ,

inflatable bubble tight seals. Therefore MW0's will be issued (

to perform testing that confirms the proper operation of these )

. seals on loss of instrument air. These MWO's will also include the testing of the inflatable bubble tight seals for non-pneumatic dampers 1HV12562 and IHV12563. This testing will be completed by 1 September 1989.

It could not be verified that Valve 1CV9446 or Dampers AHV2534, 2HY12146,'2HV12147, 2HV12148, and 2HV12149 had been tested 4 according to CAT-M-04 or CAT-M-07. However, these items have been tested to confirm that they move to their proper position 'i when required (i.e., on receipt of a Control Room Isolation, ,

Safety Injection, or Fuel Handlig Building Isolation signal, as i applicable). MWO's will be issued to perform additiona. testing L which is expected to be completed by 1 September 1989. l l

The adequacy of the diesel generator air start system air receivers to perform their intended function was verified dur-ing preoperational tests 1-XJ-05 " Diesel Generator Train A. 1 Synchronization, Load Rejection, 5 Air Starts, and 35 Consecu- l tive Starts" (Unit 1. Train A), 1- R J-06 (Unit 1, Train B), )

O 2-3KJ-05 (Unit 2. Train A), and 2-3KJ-06 (Unit 2. Train B).

The five air starts test consisted of verifying that each air '

receiver contained sufficient air to perform five air starts of the diesel with the associated air compressor deenergized and with the redundant air receiver isolated from the diesel.

This testing is considered adequate verification as required by the Generic Letter.

Use of safety-related pneumatic accur.ulators at VEGP is limited to air accumulators for the MFIV's, air accumulators for safety-related bubble tight dampers equipped with inflatable seals, and the diesel generator air start system air receivers. The adequacy of these accumulators to perform their intended func- i tion on a loss of noresl supplied air. pressure was verified as discussed above.

G.L. Item 4: Provide a discussion of the VEGP program for maintaining proper instrument air quality.

A. Action Plan:

Review the instrument air quality program and make any improve-ments deemed necessary.

8. Response:

Procedure 11880-1 (11880-2) " Turbine Building Rounds Sheets" requires the Turbine Building operator to check prefilter and

Exhibit I ,page of d

f ,+a -

S 4 ~ ' -'

RESPONSE TO GENERIC LETTER 88-14 Page 12 l afterfilter differentia'l pressure for each set of air dryers, to check the moisture (itessicant-type) indicator located on each dryer can, to blowdown the profilter and afterfilter drains for each set of air dryers, to blow 6nen the instrument air receivers, to blowdown the moisture sepsretor drains, and to perform various checks and blowdowns for the rotary and receprocating air com-pressors. These inspections'and blowdowns are performed shiftly. '

'~ Maintenance Work Orders and/or Deficiency Cards are initiated as l appropriate to resolve potential problems identified during these l inspections.

Preventive Maintenance (PM) standardized checklist SCL00402 has been originated to provide for periodically verifying the dew -

point and oil content inmediately downstream of. the af terfilter  !

for each set of instrument air dryers on both Units. Previously, 1 PM verifications of instrument air dewpoint and oil content were I performed for Unit 1 per PM repetitive task 12420005-00lW-N. .

Table 3 reflects results obtained by performance of this pre- '

vious PM task.

Standardized PM checklist SCLOO332 has been originated to pro-vide for a periodic inspection of the air filters for the.

O safety-related air-operated valves listed in Table 6. The air-set / regulator and associated air filter per this checklist will .i l

be inspected for contaisinants such as oil, water, dirt, or i debris and the filter will be replaced if it exhibits signs of clogging or is physically damaged. If a filter is found which needs replacing, then Maintenance Engineering will determine what other instrument air users in the vincinity of the subject component should be similary inspected. The frequency for the inspections described by SCLOO332 has been established.to cor :

respond to the intervals of other required inspections for the subject valves and will occur at either 24,- 36, or 48 month intervals dependent on the particular valve.

YEGP considers the above described inspections and blowdowns )

to be a sufficient method to ensure proper air quality is main- )

tained for the instrument air system.

Procedure 11882-1 (11882-2) "Outside Areas Rounds Sheets" re- .,

quires a shiftly " general" inspection of the diesel generator  !

air start system air compressors. Maintenance Work Orders and/or i Deficiency Cards are initiated as appropriate to resolve poten- i tial problems identified during these inspections. j PM standardized checklist SCL00166 has been originated to pro-vide for periodically performing a dewpoint measurement of the starting air contained in the diesel air start system air

]O receivers for both units.

)

l 1

~

Exhibit 13 ,page 6 ofN

~- RESPONSE TO GENERIC t.ETTER 88-14 '-

Page 13 Inspection of the y-strainer / filter, starting air distributor filter, engine control cabinet filter, and the barring device air filter for the diesel generator air start system is performed on an "End-of-Cycle" basis which corresponds to the generic maintenance recommendations developed by the Trans-america Delaval Owner's Group. These inspections are _

performed per the instructions of Procedure 28714-C "E0C Diesel Generator Checkout" and were completed for the Unit I diesels I during the recent Unit I refueling outage (reference MWO's 18806319,18806320,18806321, and 18806322).

VEGP considers the above described inspections to be a suf-ficient method to ensure proper air quality is maintained for the diesel generator air start system.

i 4

O

. . _ . - ~ , , . . , . - . , - _ .

i Exhibit _b.,page D of M TABLE 1 PREOPERATIONAL TEST 1-3K8-01 (UNIT 1)

INSTRUENT AIR QUALITY DATE LOCATION DEWOINT OIL CONTENT 10/30/86 Af terfilter ."A" Discharge -600F 0 ppm 10/30/86 Afterfilter "B" Discharge -720F 0 ppm 10/30/86 Turbine Bldg. El. 195' & 220' -500F 0 ppm 10/30/86 Turbine Bldg. E1. 245' & 270' -600F 0 ppm 10/30/86 Auxiliary Bldg. Line -480F 0 ppm 11/17/86 Auxiliary Boiler & Cooling Tower -360F 0 ppm TABLE 2 PRE 0PERATIONAL TEST 2-3KB-01 (UNIT 2)

A V INSTRUMENT AIR QUALITY DATE LOCATION DEWOINT OIL CONTENT 06/04/88 Af ter filter "A" Discharge -800F 0 ppm 06/04/88 Af terfilter "B" Discharge -800F 0 ppm 05/15/88 Turbine Bldg. El. 195' & 220' -800F 0 ppm 05/15/88 Turbine Bldg. E1. 245' & 270' -800F 0 ppm  ;

05/15/88 Auxiliary Bldg. Line -800F 0 ppm O

Fxhibit b,page O of TABLE 3 M PM CHECKS (tmIT 1)

INSTRUENT AIR QUALITT DATE (ptfod) LOCATION DEWPOINT OIL CONTENT

  • 11/18/86 (18619762) Af terfilter "A" Discharge -800F 03/15/87 (18703110) Af terfilter "B" Discharge -350F 06/29/87 (18705688) Af terfilter "B" Discharge -400F 11/05/87 (18708997) Afterfilter "8" Discharge +6.80F 11/19/87(18708995) Af terfilter "A" Discharge -800F 1 12/03/87 (18711877) Af terfilter "A" Discharge -800F 07/19/88(10804297) Af terfilter "A" Discharge -800F 0 ppm Af terfilter "B" Discharge -800F 0 ppm 07/26/88 (18804461) Af terfilter "A" Discharge -800F <1 ppm Afterfilter "B" Discharge -800F <1 ppm 08/02/88 (18804615) Afterfilter "A" Discharge -630F <1 ppm Afterfilter "8" Discharge -740F <1 ppe 08/09/88 (18804802) Afterfilter "A" Discharge -680F 0 ppe Af terfilter "B" Discharge -720F 0 ppm v 08/16/88 (18805141) Afterfilter "A" Discharge -710F 0 ppm Af terfilter "B" Discharge -730F 0 ppm I & C Shop Line -800F ,

08/23/88(18805400) Af terfilter "A" Discharge -700F 0 ppm Afterfilter "B" Discharge -780F 0 ppm I & C Shop Line -800F 08/30/88 (18805507) Af terfilter "A" Discharge -800 0 ppm Afterfilter "B" Discharge -780 0 ppm I & C Shop Lirie -800F 09/06/88 (18805661) Afterfilter "A" Discharge -800F 0 ppm Af terfilter "8" Discharge -800F 0 ppe Control 81dg. Level 8 -800F 09/13/88 (18805833) Af terfilter "A" Discharge -800F 0 ppm Af terfilter "8" Discharge -800F 0 ppm 09/21/88 (18806086) Afterfilter "A" Discharge -800F 0 ppm Af terfilter "B" Discharge ~800F 0 ppm I & C Shop Line O

ExhibitO,page N of M TA8LE 3 (Continued)

PMCHECKS(UNIT 1)

V -

INSTRUMENT AIR QUALITY DATE (ftf0f) LOCATION DEWPOINT OIL CONTENT 09/27/88 (18806202) Afterfilter "A" Discharge -670F 0 ppm Afterfilter "B" Discharge -700F 0 ppm Control Bldg. Level B -770F 10/04/88 (18806273) Af terfilter "A" Discharge -710F 0 ppm Af terfilter "B" Discharge -710F 0 ppm 10/05/88 (18806475) Afterfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -800F 0 ppm Control Bldg. Level B -800F 10/22/88(18806727) Af terfilter "A" Discharge -680F 0 ppm Afterfilter "B" Discharge -680F 0 ppm 10/29/88 (18806998) Afterfilter "A" Discharge -680F '0 ppm Afterfilter "B" Discharge -680F 0 ppm 11/15/88(18807138) Afterfilter "A" Discharge -200F 0 ppm Afterfilter "B" Discharge -200F 0 ppm

/ 11/21/88(18807315) Afterfilter "A" Discharge -200F 0 ppm  :

Afterfilter "B" Discharge -200F 0 ppm  !

11/29/88 (18808384) Af terfitler "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -560F 0 ppm l

12/06/88 (18808385) Af terfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -590F 0 ppm i 12/16/88 (18808653) Af terfilter "A" Discharge -760F 0 ppm Afterfilter "B" Discharge -610F 0 ppm 12/20/88(18808654) Afterfilter "A" Discharge -690F 0 ppm Af terfilter "B" Discharge -GOOF 0 ppm l

12/27/88 (18808655) Af terfilter "A" Discharge -610F 0 ppe Af terfilter "B" Discharge -430F 0 ppe 01/03/89(18808854) Af terfilter "A" Discharge' -460F 0 ppe Af terfilter "B" Discharge -220F 0 ppe 01/10/89(18808966) Afterfilter "A" Discharge -800F 0 ppm Af terfilter "B" Discharge -800F 0 ppm

  • PM measurement of oil content was implemented in 1988 1

l l

1 l

- . ExhibitM,page I6 of 2_) i I

. i

[l-C l

l TABLE 4 SPECIAL TESTING (Unit 1)  :

INSTRUENT AIR QUALITY (MWO #18900303)

DATE LOCATION DOfPOINT OIL COME N 02/03/89 Turbine Bldg. Level 1 -800F 0 ppm ,

02/03/89 Control Bldg. Level B -800F 0 ppm 02/03/89 Auxiliary Bldg. Level 0 -800F 0 ppm 02/03/89 Diesel Generator Bldg. lA -800F 0 ppm 02/03/89 Diesel Generator Bldg.18 -800F 0 ppm TABLE 5 DIESEL GENERATOR AIR START SYSTEM AIR QUALITY PREOP TESTING DATE PREOP AIR START TRAIN ROOM TEM DEWPOINT l 11/03/86 1-3KJ-01 1-2403-G4-001-K01 770F 48.30F 11/03/86 1-3KJ-01 1-2403-G4-001-K02 770F 48.20F 11/04/86 1-3KJ-02 1-2403-G4-002-K01 790F 49.10F 11/04/86 1-3KJ-02 1-2403-G4-002-K02 790F 61.90F 10/06/87 2-3KJ-01 2-2403-G4-001-K01 770F 41.40F 10/06/87 2-3KJ-01 2-2403-G4-001-K02 770F 42.40F 10/13/87 2-3KJ-02 2-2403-G4-002-K01 630F 36.39F 12/11/87 2-3KJ-02 2-2403-G4-002-K02 710F 400F O i

Exhibit O ,page d C of M

. l TABLE 6 Iml U SAFCTT~ R D TED INSTRUENT AIR USERS


ACTIVE VALVES----

AIR FILTER VALVE VENDOR MODEL SIZE (M) FE A-FSAR REF. POSITION 1HV13005A FISHER P595 50 FMEA-FSAR CLOSED 2HV13005A TABLE 10.3.3-1 1HV13005B FISHER P595 50 FMEA-FSAR CLOSED 2HV13005B TABLE 10.3.3-1 1HV13006A FISHER P595 50 FMEA-FSAR CLOSED 2HV13006A TABLE 10.3.3-1 1HV13006B FISHER P595 50 FMEA-FSAR CLOSED 2HV13006B TABLE 10.3.3-1 1HV13007A FISHER P595 50 FMEA-FSAR CLOSED 2HV13007A TABLE 10.3.3-1 1HV13007B FISHER P595 50 FMEA-FSAR CLOSED 2HV13007B TABLE 10.3.3-1 1HV13008A FISHER P595 50 FMEA-FSAR CLOSED 2HV13008A TABLE 10.3.3-1 1HV130088 FISHER P595 50 FMEA-FSAR CLOSED 2HV130088 TABLE 10.3.3-1 1HV7603A CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED 2HV7603A TABLE 10.3.3-1 l

l 1HV76038 CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED 2HV7603B TABLE 10.3.3-1 1HV7603C CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED 2HV7603C TABLE 10.3.3-1 '

(Continued) 1

Exhibit. 02 ,pageM. of 25

- TABLE 6 (Continued)

SAtuT-RELAiw INSTR 1sENT AIR USERS J -----ACTIVE VALVES---- .

AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION 1HV7603D CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED 2HV7603D TABLE 10.3.3-1 1HV5280 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HYS280 TABLE 10.3.3-1 1HV5281 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HV5281 TABLE 10.3.3-1 1HV3502 FISHER 67AFR 40 NONE CLOSED 2HV3502 1HV8823 FISHER P-594-1 40 NONE CLOSED 2HV8823 1HV8824 FISHER P-594-1 40 NONE CLOSED 2HV8824 1HV8843 CON 0 FLOW FH-20 35 NONE CLOSED 2HV8843 1HV8881 CON 0 FLOW FH-20 35 NONE CLOSED 2HV8881 1HV27901 CON 0 FLOW GFH20XT1782 35 NONE CLJSED 2HV27901 1HV8871 FISHER P594-1 40 NONE CLOSED 2HV8871 1HV8964 FISHER P594-1 40 NONE CLOSED 2HV8964 1HV8888 FISHER P594-1 40 NOME CLOSED 2HV8888 1HV8880 FISHER P-594-1 40 NONE C1OSED 2HV8880 1HV8160 CON 0 FLOW FH-20 35 NONE CLOSED 2HV8160 1HV8152 FISHER P594-1 40 NONE CLOSED (Continued) 2

Exhibit N ,page32 of 525 l f

TABLE 6 (Continued) p, SAFUT-REW u Q INSTR 1M NT AIR USERS


ACTIVE VALVES----

)

AIR FILTER

  • J VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. _ POSITION j 1HV8825 FISHER P-594-1 40 NONE CLOSED 2HV8825 ,

1HV8890A FISHER P-594-1 40 NONE CLOSED 2HV8890A 1HY88908 FISHER P-594-1 40 NONE CLOSED 2HY88908 1HV8033 CON 0 FLOW FH20XTKXG81 35 NONE CLOSED 2HV8033 1HV8047 CON 0 FLOW FH20XTKXG81 35 NONE CLOSED 2HY8047 1HV8028 CON 0 FLOW FH20XTKXG81 35 NONE CLOSED 2HY8028 1

1HY3513 FISHER P595 50 NONE CLOSED 2HY3513 1HV3514 FISHER 67AFR 40 NONE CLOSED i 2HY3514 1HV3507 F! SHER P595 50 NONE CLOSED l 2HV3507 1HV3508 FISHER 67AFR 40 NONE CLOSED 2HV3508 1HV5278 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HV5278 TABLE 10.3.3-1 1HY5279 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HV5279 TABLE 10.3.3-1 1HV7699 CON 0 FLOW FH20XTKXG81 35 NONE CLOSED 2HV7699 1HV7136 CON 0 FLOW FH20XTKXG81 35 NONE CLOSED 2HV7136 l

l (Continued) i

Exhibit 1"l> page 5223 of 2f TABLE 6 (Continued) f- SAFLIT-RELA I LD INSTRUMENT AIR USERS


ACTIVE VALVES----

AIR FILTER VALVE VENDOR M00EL SIZE (M) FEA-FSAR REF. POSITION 1HV780 CON 0 FLOW GFH20XT1782 35 NONE CLOSED 2HV780 1HV781 CON 0 FLOW GFH20XT1782 35 NONE CLOSED 2HV781 1HV7126 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HV7126 1HV7150 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HV7150 1HV9385 CON 0 FLOW GFH20XT1782 35 NONE CLOSED 2HV9385 1HV9378 FISHER 67AFR 40 NONE CLOSED l 2HV9378 l GFH20XT1782 35 FMEA-FSAR CLOSED l 1HV15198 CON 0 FLOW O 2HV15198 TABLE 10.4.9-4 l 1HV15197 CON 0 FLOW GFH20XT1782 35 FMEA-FSAR CLOSED 2HY15197 TABLE 10.4.9-4 1HV15199 CON 0 FLOW GFH20XT1782 35 FHEA-FSAR CLOSED 2HV15199 TABLE 10.4.9-4 1HV15196 CON 0 FLOW GFH20XT1782 35 FMEA-FSAR CLOSED 2HV15196 TABLE 10.4.9-4 1CV9446 FISHER 67AFR/67FR 40 NONE CLOSED 2CV9446 1CV9447 FISHER 67AFR/67FR 40 NONE CLOSED 2CV9447 (Continued) 4 O

Exhibit O ,page2 of M TABLE 6 (Continued)

SArut-RELMw

(~l

'd INSTR 12ENT AIR USERS I


ACTIVE VALVES----

l AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION 1HV8145 FISHER P-594-1 40 FIG. 3.6.1-1 CLOSED 2HV8145 (SHEET 25) 1HV15214 FISHER P595 50 NONE CLOSED 2HV15214 1HV10957 CON 0 FLOW GFH20XT1782 35 NONE CLOSED  !

2HV10957 1HY10958 CON 0 FLOW GFH20XT1782 35 NONE CLOSED 2HV10958 1HV15212A FISHER P595 50 FMEA-FSAR CLOSED 2HV15212A TABLE 10.3.3-1 1HY152128 FISHER P595 50 FMEA-FSAR CLOSED 2HY152128 TABLE 10.3.3-1 1HV15212C FISHER P595 50 FMEA-FSAR CLOSED 0 2HV15212C 1HV152120 FISHER' P595 50 TABLE 10.3.3-1 FMEA-FSAR CLOSED 2HY152120 TABLE 10.3.3-1 1HV15216A FISHER P595 50 FMEA-FSAR CLOSED 2HV15216A TABLE 10.3.3-1 1HV152168 FISHER P595 50 FMEA-FSAR CLOSED 2HV15216B TABLE 10.3.3-1 1HV15216C FISHER P595 50 FMEA-FSAR CLOSED 2HY15216C TABLE 10.3.3-1 1HV15216D FISHER P595 50 FMEA-FSAR CLOSED 2HV152160 TABLE 10.3.3-1 (Continued) 1 5 l l

Exhibit 11,page M ofb m TABLE 6 (Continued)

( ^~

5Aru Y-RELA lt.u INSTRLSENT AIR USERS ,


ACTIVE VALVES----

AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION ILV0459 FISHER P594-1 40 NONE CLOSED 2LV0459 1LV0460 FISHER P594-1 40 NONE CLOSED 2LV0460 1HV8153 FISHER P594-1 40 NONE CLOSED 2HV8153 1HV8154 CON 0 FLOW FH-20 35 NONE CLOSED 2HV8154 1HV5227 WATTS F-602-4EJ 40 NONE CLOSE0*

2HV5227 e

1HV5228 WATTS F-602-4EJ 40 NONE CLOSED

  • 2HV5228 1HV5229 WATTS F-602-4EJ 40 NONE CLOSED
  • 2HV5229 1HV5230 WATTS F-602-4EJ 40 NONE CLOSED
  • 2HV5230 AHV19722 CON 0 FLOW GFH20XT1782 35 NONE CLOSED AHV19723 CON 0 FLOW GFH20XT1782 35 NONE CLOSED
  • Assumes failure position on feedwater isolation signal 6

O

s.. .

TABLE 7 exhibit 'page M OIM SAFf W-R QTED IRSTRUENT AIR USERS


ACTIVE DAfrERS-----

O. AIR FILTER FAILURE DAfrER VEISOR DODEL $1ZE(M) FEA-FSAR REF. POSITION AHV2534 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED >

AHV2535 'NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED-AHV2528 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED AHV2529 NORGREN F12-400A3M 50 TABLE 9.4.2-2 ' CLOSED AHV12482 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED ANY12481 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED AHV12479 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED AHV12480 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED AHV12152 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED AHV12153 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED AHV12162 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED i AHV12163 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED 1HV12605 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED 2HV12605 1HV12607 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED 2HV12607 1HY12604 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED 2HY12604 1HV12606 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED 2HV12606 F12-400A3M 50 TABLE 6.4.4r1 CLOSED  ;

1HV12146 NORGREN l

2HV12146 1HV12147 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED 2HV12147 1HY12148 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED 2HV12148 1

O 1

l l

! - ,, TABLE 7(CONTINUED) Exhibitd ,page[ of 7#

L SAFETY-RELATED .

INSTRt#ENT AIR USERS

..... ACTIVE DAfrERS-----

AIR FILTER' FAILURE.

DAMPER VELO 0R IWDEL SIZE (M) FM.A-F5AR REF POSITION 1HV12149 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED 2HV12149 1HV26268 FISHER 262C 40 NONE CLOSED 2HV26268 1HV2627B FISHER 262C 40 NONE CLOSED 2HV26278 1HV26288 FISHER 262C 40 NONE CLOSED 2HV26288 ,

1HV26298 FISHER 262C 40 NONE CLOSED '

2HV26298 1HV2636A NORGREN F12-400A3M 50 TABLE 9.4.5-3 CLOSED 1HV26368 NORGREN F12-400A3M 50 TABLE 9.4.5-3 CLOSED 1HV2638A NORGREN F12-400A3M 50 TABLE 9.4.5-3 CLOSED-1HV26388 NORGREN F12-400A3M 50 TABLE 9.4.5 CLOSED 1HV12562 8ALSTON TABLE 9.4.5-3 CLOSE0' q 1HV12563 8ALSTON TABLE 9.4.5-3 CLOSE0'  ;

1HV12596 FISHER 67AFR 40 .NONE CLOSED 2HV12596 l;

1HV12597 FISHER 67AFR 40 NONE CLOSED 2HV12597 1TV12086/12086A NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12086/12086A ITV12098/12098A NORGREN F12-400A3M 50. TABLE 9.4.7-2 OPEN 2TV12098/12098A 1TV12085/12085A (USES FILTER ON 1TV12098) TABLE 9.4.7-2 OPEN 2TV12085/12085A (USES FILTER ON 2TV12098) 1HV12010 NORGREN F12-400A3M 50 TABLE 9.4.8-2 OPEN 2HV12010

  • These are electric operated dampers with air operated bubble tight seals; does not assume failure position on loss of instrument air.

O

.. ivhibit I3,page of '

TA8LE 7 (CE TINUED) f3 5 art.U-RELAIw Q INSTRLK MT AIR USES


ACTIVE DAW ERS----- '

l l

AIR FILTER FAILURE DAMERS VDIDOR MODEL SIZE (M) FN.A-FSAR REF. POSTION 1HV12010A NORGREN F12-400A3M 50 NONE OPEN 2HV12010A ITV12095A/12095C NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12095A/12095C 1TV120958/120950 NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV120958/120950 1TV12094A/12094C NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12094A/12094C ,

ITV12094B/120940 NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV120948/12094D ITV12096/12096A NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12096/12096A ITV12097/12097A (USES FILTER ON 1TV12096) TABLE 9.4.7-2 OPEN 2TV12097/12097A (USES FILTER ON 2TV12096)

.TV12099/12099A NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12099/12099A ITV12100/12100A NORGREN F12-400A3M 50 TABLE 9.4.7-2 CLOSE:

2TV12100/12100A

)

1TV12101/12101A NORGREN F12-400A3M 50 TABLE 9.4.7-2 CLOSE:

2TV12101/12101A i

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