ML20086H715

Submits Status Update for Outstanding Items Resulting from Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Periodic Programs for Monitoring Instrument Air Quality Established

ML20086H715
Person / Time
Site:	McGuire, Mcguire
Issue date:	12/02/1991
From:	Mcmeekin T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, NUDOCS 9112090315
Download: ML20086H715 (7)

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DUKE POWER December 2, 1991 U.S. Nuclear Regulatory Commission ATTN Documen. Control Desk washington, D.C. 20555 Subjects McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369, -370 Status Update for Outstanding Items Resulting from Generic Letter 86-14 (Instrument Air Supply System Problems Affecting Safety-Related Equipment)

References Letter from M.S. Tuckman to NRC, Revised Response to Generic Letter 88-14 for Oconee, McGuire, and Catawba Naclear Stations, dated August 12, 1991 Gentlemen:

The purpose of this letter is to provide the NRC information regarding commitments that were made as a result of the subject generic letter. In the reference letter, it was indicated that we would submit additional information by December 1, 1991, which would address additional actions taken and provide schedular information for items remaining to be completed.

Following is a summary of our response relative to the requirements of Generic Letter 88-14:

1. Verify by test that actual instrument air quality is consistent with manufacturers' reen==ndations for individual components served by instrument air.

Response-McGuire's original response to the NRC dated May 8, 1989 provided the instrument air quality testing results and indicated that these results would be evaluated againat future acceptance criteria to be developed.

A review of manufacturer air quality requirements for components served by the instrument air system has been performed. Based upon this review, test emceptance criteria were issued which defines the minimum instrument air quality requirements at McGuire. If met, these minimum requirements would ensure that the instrument air quality is consistent with manufacturer recommendations. Periodic testing of instrument air quality indicates that dewpoint and particulate of the system are frequently greater than the maximum allowed by the test acceptance criteria.

McGuire's response to this generic letter requirement is incomplete.

The following actions are being pursued to correct the dewpoint and particulate problems:

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Document Control Desk December 2, 1991 Page 2 a) In the long term, the dowpoinN deficiency could be corrected by the installation of new dryers. Recent testing of the existing dryers indicates that attempts to lower the exit dewpoint from the dryere tc values below the test acceptance criteria maximum were unsucceseful.

In order to corract the dewpoint problems experienced, McGuire la implementing steps to replace the existing dryers by the end of 1993.

b) The particulate problem could be corrected by the installation of 5 micron filters it. each filter regulator associated with pneumatically operated components. Filter changeout is being accomplished as regularly scheduled preventive maintenance is performed. If a particular component does not have regularly scheduled PM performed, a work request is to be written to change the filter regulator to 5 microns. This changeout should be completed by the end of 1993.

2. Verify that maintenance practices, emergency procedurea, and training are adequate to enuure that safety-related equipment will function as intended upon lona of instrument air.

Responeo A thorough review of instrument air related maintenance practicos, emergency procedurea, and training has been completed. Adequate preventive maintenance (PM) is in place for all supply side equipment.

However, on the demand side, filter regulator PMa still need to be developed for the instrumeat air portion og both safety and non-eafety-related valves, dampers, and instrumentation. Station emergency proceduren and training were deemed to be adequate to ensure proper operation of plant equipment and eyetems upon a loss of instrument air. The emergency procedures and training related portions of this requirement are closed. However, further malatenance Inlated actions need to be completed. McGuire's response to this generic lotter requirement la incomplete. To complete thin item, the following action is being pursued a)-Develop.and implement a filter regulator PM program for both safety and non-nafety-related valves, dampers, and instrumentation. A program is being evaluated that would assign numbers to all filtet regulatore, track them, and change them out at a spectfied frequency.

Priority will be given to development of the safety-relatud or critical component PM program. This program should be implemented by the end of 1993. Note that while a PM program will be developed for both safety and non-safety-related componente, 5 micron filters will be installed only on safety-related or critical components.

-3. . Verify that the design of the entire instrument air system, including air or other pneumatic accumulatore, is in accordance with its intended function. This analysie should include an analysis of current air operated component failure positions to verify that they are correct for assuring required cafety functions. Also, verify by test that air operated safety-related components will perform as expected during all design basia evento, including a lose of the normal instrument air system.

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t Documert Control Desk Decembet-2, 1991 Page 3 Responoo A revicw of the supply side instrument air equipment has revealed that its design should be adequate to allow this equipment to perform its intended functicn. A similar design review of demand side equipment reveal.d that &ctive and passive air operated valves and other comronents should perform their intended functions. All required testing to verify that thcee components perform as expected during all deuign baulo evente has not yet been completed. This testing is expected to be completed by the end of the current refueling outage on Unit 1 (December 1991) and by the end of the upcoming refueling outage on Unit 2 (Marc'h 1992).

4. Provido a discunnion of our program for maintaining proper inotrument air quality. Proper instrument air quality is defined by ISA-S7.3-1975, Utandardo for Air Quality. These standards are:

- No particulate > 3 microne

- Dowpoint. at line preneure should be at least 38 degreen P below the lowest expected ambient temperature and in no case should it be > 35 degroes F

- < 1 ppa hyciroc.arimna

Response

The periodic programa for monitoring instrument air quality have been set up. Initial monitoring has been completed. The two remaining action items in this area which have been identified above are to install new dryers and 5 micron regulator filters. Note that McGuire has set the particulate standard at 5 micron instead of 3 micron as stated in the ISA standard. This is based upon our review of manufacturer requirments which indicated that the 5 micron standard is adequate for components served by McGuire's instrument air systems.

In addition to the items discussed above, we have researched all previous correspondence pertaining to Generic Letter 88-14 for McGuire Nuclear Station in an effort to summarize all commitments that were made and to determine the status of those commitments. These commitments, as well as their disposition or current status, are listed in Table 1 (attached). Also shown are the daten of the original lettero to the NRC in which the commitments were made.

If you have any questions on this material, please call P.F. Guill at (704) 373-2844.

Very truly _/1 yours, sY , f,

/ , h T.C. McMeekin, Vice President McGuire Nuclear Generation Department Attachment

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W.M. Sample R.L. Gill,-Jr.

P.F. Guill R.E.. Hall R.W. Revels T.L.~McConnell (MNS)-

R.O. Sharpe-(MNS)

J.W.-Bryant (MNS) .

-Files- - MC-B15.07 (GL 88-14)

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f Table 1 McGuire Commitments for Generic Letter 88-14 Scheduled Commitment Ref Ltr Complete / Incomplete Comp Datr

1. Write air quality test 5/8/89 Complete NA specification.

2. Write periodic PM 5/8/89 Incomplete 1/1/94 procedures for filter changeout on 56 AOVs.

3. Maintain doghouses > 40F 5/8/89 COMPLETE NA via space heaters and control of louvers.

4. Determine whether 12 U-1 5/8/89 COMPLETE NA YC valves will be added to IST program. Also address non qualified positionere between safety-related solenoid valves and operators on same valves and 4 other RN valves.

5. Add SOER 88-1 to Pressure 5/8/89 Complete NA Measurement Lesson Plan.

Alno add information to Fisher control Valve Actuator Lasson Plan.

6. Correctly connect INV459 5/8/89 Complete NA controls,

7. Review AOVs to criteria 9/20/90 Complete NA of GL and supp'iement Ret 8/12/91 ltr.

responses.

8. Identify other componente 9/20/90 Complete NA that meet GL criteria. Ref 8/12/91 ltr.

9. Revise verification test 9/20/90 Complete NA procram to be consistent with scope of GL for all components.

10. Develop schedule for 9/20/90 Complete NA completion of verification Current RFO for Ul.

triting of components. Upcoming RFO for U2.

11. Define how VI system is 9/20/90 Complete NA to be tested and what are acceptance criteria.

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• Table 1 (continued)

Commitment Ref Ltr Complete /Incompleto Comp Date

12. Review response to GL 9/20/90 COMPLETE NA verification action item 2 to verify completeness and accuracy for newly identified components.

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