ML20091H969

Intervenor Exhibit I-MOSBA-13,consisting of Re GL 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment

ML20091H969
Person / Time
Site:	Vogtle
Issue date:	05/17/1995
From:	Hairston W GEORGIA POWER CO.
To:
References
GL-88-14, OLA-3-I-MOSBA13, NUDOCS 9508150388
Download: ML20091H969 (28)

Text

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3 95 JLL 27 A9:48 bfANkb5 i g !g, }C&%0F SECRETARY

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V0GTLE ELECTRIC GENE ITS 1 and 2  %#h o ,. , t "

OPERATING LI NSES MP - A NPF-79 '

GENERIC LETT NO., 88-14 INS UMENT AIR 1

SUPPLY SYSTEM PROBLEMS AFFECTING 5AFETY 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.

1 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.

NUCLEAR REGULATORY COMMISSION GEORGIA POWER CQ4PANY Docket No. 50-424/425-OLA-3 EXHIBIT NO. MThi 3 in the matter of Georain Power Co. et al, Vootle Units 1 & 2 O staff O Applicant Q[Intervenor D Other [

S Idtntified O Received O Rejected Reporter C4 W. G. Hairston, III Date 07- 0

• 9T Witness 3 Mf

• I"M Sworn to and subscribed before me this /7 $ day of February, 1989.

t n a W 4. l bib Y NoytryPublic ,

WM/ijb .- E3DEC15,1ggr 9508150388 950517 PDR ADOCK 05000424 Q PM y ._ )

b i it' Exhibit 1.3.,page.2 of2$

. Georgia Power A.

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Enclosure:

l cc: Georgia Power Company

Er. P. D. Rice l Mr. C. K. McCoy i Mr..G. Bockhold, Jr. 1

, .GONORMS l l

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

, Mr. J. F. Rogge, Senior Resident Inspector-Operations, Yogtle l 1

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. $xhibit I ,page of YOGTLE ELECTRIC GEMERATING PLANY -

UNITS 1 MD 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' reconnendations 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 maintenance (PM) tasks associated with the Instrument Air System.

1

3. Select sample points and conduct additional in-plant testing to measure actual instrument air quality.  ;

4. Verify diesel generator air start system air quality from preoperational test procedures.

B. Response:

Testing of instrument air systes air quality has been accomplished as follows at VEGP:

4

1. Testing activities during the performance of preoperational l

test procedures consisted of verifying the air quality

(moisture and oil content) imediately 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 connitted VEGP to meeting the quality requirements of ANSI /ISA 57.3-1975 for verifying moisture and oil content and noted that veri-

fication of particulate size at the end of each feeder line

! is 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 accordence with individual instrument manuf acturer's requirements." To meet the requirements of ANSI /ISA S7.3-1975, the acceptance criteria I

for maximum allowable oil content was established as l 1 ppm (w/w) and the maximum allowable moisture content was l

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 I and

2. These results show that preoperational testing verified i

that the instrument air systems for both units meet the

moisture and all content requirements of ANSI /ISA S7.3-1975.

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MDIL.l , d ofgj RESPONSE TO GENERIC LETTER 88-14 - -

Page 2-

2. For Unit 1, periodic verification during performance of PM tasks consisted (moisture primarily)of and oil content verifying immediately the air quality downstream of the afterfilter for each set of dryers. Verification of moisture content (dewpoint) at the end of a representative feeder line has also been performed on eight separate occassions. The PM i acceptance criteria for maximum allowable oil content is l established as 1 ppe.(w/w) and maximum allowable moisture l content is established as -600F dewpoint at line pressure. 1 The results of the PM verifications of instrument air system )

air quality are tabulated in Table 3. These results show that l oil content has consistently been verified to be O ppm (a ,

few measurements were recorded as less than 1 ppm); however, j dewpoint, on occasion, has been found to exceed the PM accep-  ;

tance criteria of -600F. In these cases, corrective  ;

maintenance was typically required to restore the dewpoint i to less than -600F. While the dewpoint has been found to exceed the PM acceptance criteria in several instances i (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 desmonstrates that the VEGP  ;

instrument air system design is such that high quality  ;

instrument air can typically be supplied even with a mal-j functioning system component.

! Verification of particulate size has not been performed as i 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 l i

performed per PM checklist SCLOO285, " Valve / Damper Stroke",

the local air filters / regulators for approximately 39 safety I i related air-operated valves were inspected during the Unit 1 i first refueling outage (Fall, 1988). These inspections veri-fied that no cleaning or replacement of the air filters was

! required. Vogtle Electric Generating Plant considers that i periodic inspection and cleaning or replacement as necessary i of these local air filters for each safety related air-

! operated component is an appropriate method of ensuring that  ;

j instrument air quality is maintained consistent with the '

t manufacturers' recomunendations 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 dewpoint for five (5) instrument air feeder lines. The results of l

I this testing are tabulated in Table 4. These results show l

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hnibit I b ,page G Of 2l-

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RESPONSE TO GENERIC LETTER 88-14 Page 3 i

i 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 j

considered as sufficient for reverifying the air quality testing results of preoperational test 1-3KB-01 for VEGP 7

Unit 1. The air quality testing results of preoperational test 2-3KB-01 for VEGP Unit 2 are still considered current j' and therfore reve'.ification of those results is not con-sidered necessary at this time.

, Yogtle 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' reccsmendations 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 recommendations, such as " filtered," " 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

! local air filters (Unit 1) verified particulate size to be acceptable i for instrument air as supolied to the individual components. There-fore, the instrument air ystem air quality is considered as having l been verified as consistent with the manufacturers' reconsnendations.

l Testing of air quality for the diesel oenerator air start system has also been accomplished for VEGP Units 1 and 2. The VEGP diesel

! generator air start system was supplied by Transamerica Delaval.

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

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 4

and oil. Further downstream, filters exist for the starting air distributor and for the engine control panel. The maximum dewpoint acceptance criteria for. the VEGP diesel air start system har, been establishedas500F'atsyrtespressure.(see.FSAR. Table.9.5.4-lO This dewpoint criteria was established based on the design capability of the air start system, the fact that the air is compressed._tof between 225 and 250 psig, which raises the dewpoint, and the minimum diesel generator room design temperature of 500F. Preoperational test procedures 1-3KJ-01 " Diesel Generator Train A Starting Air System".(Unit 1), 1-3KJ-02 " Diesel Generator Train 8 Starting Air System" (Unit 1), 2-3KJ-01 Diesel Generator Train A Starting Air System" (Unit 2), and 2-3KJ-02 " Diesel Generator Train 8 Starting Air System" (Unit 2) included a verification of dewpoint for starting I air contained in each receiver. The results of this preoperational l verification of dewpoint are tabulated in Table 5. These results l

Exhibit I) ,page b' Of 5II

_ _ . _ , __ 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 dcwpoint 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 /1(Iter and- ,

downstream filters. Transamerica Delaval (now IMO 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 recommendations developed by the Transamerica Delaval Owner's Group (see Appendix II of the TDI Diesel Generator Design Review and Quality Revalidation Report -

YEGP: Note: This report was previously submitted to the NRC). The j

YEGP program for performing these periodic inspections is discussed in more detail later in this response, j A review was conducted of Transamerica Delaval recommendations and of 1 the recominendations developed by the Transamerica Delaval Owner's Group. This review indicated that quantitative air quality j l requirements have not been specified for the diesel generator air 1 l -

start system. Therefore, VEGP considers thct the air quality' testing 1 performed during preoperational tests 1-3KJ-01,1-3KJ-02, 2-3XJ-01,  ;

t and 2-3KJ-02 was sufficient to verify the air quality of the {

l diesel air start systems for Units 1 and 2 consistent with the  ;

manuf acturers' reconmendations. '

G.L. Item 2: Verification that reintenance practices, emergency procedures i

and training are adequate to ensure that safety-related equip-ment will function as intended on loss of instrument air.

A. Action Plan:

1. Evaluate current maintenance programs and practices to deter-1 mine overall adequacy for components within the scope of the i generic letter.

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! 2. Review plant procedures designed to mitigate the effects of l- a loss of instrument air.

3. Review the content and scope of training programm for adequacy in the area of required response to a loss of instrument air.

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. j Shibit O , page._l_. ofM q

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Page 5 i

B. Response:

1. Maintenance Practices Maintenance on safety-related air-operated components is controlled by Maintenance Work Orders (MWO's) issued per the instructions of Procedure 00350-C ' Maintenance Program,"

and by various task specific procedures which are identified ,

as appropriate when preparing the detailed work isntructions for the MWO. Exagles of.a few of the different procedures that isight be identified on tne MWO as required for main-tenance on air-operated components are:

25036-C ' General Valve Packing" 26060-C "ASL0' Solenoid Valve Maintenance" '

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 completion of the maintenance task, the Work Planning Group assigns a functional test to the MWO using Procedure i 29401-C ' Maintenance Work Order Functional Tests" as a guideline. Included in Attachment A of Procedure 29401-C, ,

Rev. 3, are specific guidelines for functional tests to be I performed on air-operated valves ( A0V's). An A0V failure L mode check (fail 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 i

" Air Operated Valve Post Maintenance Yerification,' Rev. O,

includes specific guidance for checking that a safety- j l related A0V will properly assume its " failsafe" position 1

both on slowly bleeding-off supplied air pressure and on j suddenly venting supplied air pressure.

The above described maintenance practices are considered i adequate for ensuring that safety-related air-operated

! components will function as intended on loss of instrument

, air.

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2. Emergency Procedures l 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 i- 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 i 80 psig and the Turbine Building air header isolates at i

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Shibit O ,page ofd-j I

RESPONSE TO GENERIC LETTER 88-14 Page 6.

70 psig). Annunciator Response Procedure (ARP) 17001-1, Rev.10, describes actions to take on receipt of these alarms. For the service air header low pressure alarm, ARP 17001-1 directs the operator to go to abnormal operating procedure (AOP) 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 imediately to A0P 18028-C. AOP 18028-C, Rev. 4, lists other symptoms of  ;

a loss of instrument air to ensure identification of such  ;

an event. AOP 18028-C identifies critical components operated by instrument air and describes failure modes of )

which the operator needs to be aware. The note preceding l 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 Building instrument air will close i 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-relate.1 air-operated components on a loss of instrument air is essential to ensure ,

I mitigation of accidents and events described in the safety l l

analysis A0P 18028-C recognizes that the " failsafe" positions i

< for some components may not be favorable or appropriate for 1 actual existing plant conditions and therefore directs the i operator to either take manual control or bypass certain l l

' specific components when appropriate to maintain control of the plant. The note preceding Step B6 identifies that a loss of instrument air will cause the positive displacement i 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-i accident conditions, these " failsafe" positions would result l in an increasing pressurizer level. AOP 18028-C therefore ,

i directs the operator to close the charging header isolation *

! valves if pressurizer level is rising and to bypass the seal L injection flow control valve and to throttle the bypass valve

to maintain RCP seal injection flow within the proper range.

t .Other examples exist in AOP 18028-C where the operator is l

directed to take manual control or bypass certain " failsafe * '

components dependent on actual plant conditions. On recovery from a loss of instrument air, if in Mode 1 or 2, A0P 18028-C i - directs .the operator to initiate system operating procedures 13710-C " Service Air System' and 13711-C ' Instrument Air i System" to ensure systems are restored to normal; for Modes 3 L

4, 5, an;f 6. A0P 18028-C contains the appropriate steps to L

restore potentially impacted systems to normal.

p l Emergency Operating Procedures (E0P's) also contain guidance

when appropriate for operator actions to be taken when i

i

!- c

• l Exhibit 1 3 ,page 9 of d l

. aw . . . .

RESPONSE TO GENERIC LETTER 88-14

Page 7 instrument 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-cperated components will function as intended on loss of

. instrument air.

3. Training

! Current training for licensed operators includes lesson plans, instructional units, and simulator exercises as y

follows:

LO-LP-02110 " Service and Instrument Air Systems" LO-IV-02110-001 " Start Air Compressors'  ;

LO-!U-02110-002 " Respond to Instrument Air System Alarms" l

LO-IV-02110-003 " Respond to Service Air System Alarms" i-LO-IV-02110-004 ' Respond to a loss of Instrument Air to l Containment" i l

LO-SE-60019 'RHR Operations With Malfunctions" l LO-SE-60023 " Coolant & Feedwater & Air Systems Malfunctions" l LO-LP-60321 " Loss of Instrument Air" LO-IV-60321-001 ' Respond to Loss of Instrument Air" Lesson Plan LO-LP-60321 is based on abnormal operating i procedure (A0P) 18028-C and includes training on how to detect a loss of instrument air, response of critical components i 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 ,

i 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 AOP 18028-C for responding to both simulator exercise scenarios.

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

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

Outside Area Operator"

I Abit ,page 0 of2 RESPONSE TO GENERIC LETTER 88-14 2

Page 5 e

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

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

Following Isolation" NL-IU-02301-00-006 " Restore Service Air Following Isolation" NL-IV-02301-01-007 " Check Proper Operation of Rotary Air Compressor" l NL-IV-02301-00-008 " Check Proper Operation of Reciprocating Air Compressors" I i NL-IV-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" O NL-!U-53112-00-001 " Verify Power-Operated Valve Operation" 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.

.ME-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 common mechanical and operational causes of air operator failures, and includes a review of NRC Information Notice 87-28, NUREG-1275, Vol. 2, and SOER 88-01 to empha-size the need to prevent degradation of the instrument air system by allowing foreign material such as oil, water, 4 dirt, or debris to enter the system while performing main- l tenance. GE-LP-12516 provides training on the purpose of

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- Exhibit O ,page_ll of 2_

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RESPONSE TO GENERIC LETTER 88-14 Page 9 l

i the instrument air system, major components, functions and flowpath, eschasizes that significant problems have i

occurred at various nuclear plants due to the. contamination  !

! , of instrument air and instructs the student to observe for

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

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

, reviewed against the reconsnendations of NUREG-1275, Vol. 2,

and revised where appropriate to incorporate those recomunen- '

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 ,

including air or other pneumatic accumulators is in accordance 1

' with its intended function, including verification by test that t i air-operated, safety-related components will perform as expected 4 in accurdance with all design-bases events, including a loss of 1

the normal instrument air system. This design verification should include an analysis of current air operated component i failure positions to verify that they are correct for assuring

required safety functions.

A.. Action Plan.

I

1. Identify, by reviewing plant design documentation, the system and comoonent 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.

8. 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.

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• Exhibit N,page l2 og2 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 Yalves." 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 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 t pressure testing performed per CAT-M-07 consisted of placing

! the damper opposite to its fail-safe position and then verifying i the damper properly moved to its fail-safe position on slowly

reducing the air pressure to the actuator.

The main feedwater isolation valves (i.e., valves lHV5227,

t. lHV5228, lHV5229, 1HV5230, 2HYS227, 2HV5228, 2HV5229, and 2HV5230) were not CAT-M-04 tested. These valves are hydraulic l actuated valves but require a source of air to pe-form their safety function in that air-operated pilot valves have to repo-l sition on a feedwater isolation signal to allow the flow of i 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 I decreased. The VEGP MFIV's are the same valves as those des-

! cribed in NRC Information Notice 85-35 and which are usad as

main steam isolation valves at Byron Unit 1. Following issuance

of Notice 85-35, the VEGP MFIV's were modified by replacing the i

air check valves with those of a slightly different design. The l 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

., 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 l

as required by the Generic Letter.

! Dampers ANV12479, AHY12480, AHV12481, AHV12482,1HV12604, lHV12605, lHY12606, lHY12607, 2HV12604, 2HY12605, 2HV12606, and 2HY12607 are air-operated dampers, but are also equipped with i an inflatable bubble tight seal. A source of air is ensured by i a reserve air storage tank and an instrument air check. valve for i each damper. A CAT-M-07' test was performed for each of these j dampers which verified that each properly assumed a closurs position on loss of instrument air.

- Exhibit O.,pageJ.3 of M

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RESPONSE TO GENERIC LETTER 88-14 Page 11 CAT-M-07 does not include confirmation 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 inc.ade the testing of the inflatable bubble tight seals for non-pneumatic dampers lHV12562 and 1HV12563. This testing will be completed by 1 September 1989.

It could not be verified that Yalve 1CV9446 or Dampers AHV2534, 2HV12146, 2HV12147, 2HV12148, and 2HV12149 had been tested according to CAT-M-04 or CAT-M-07. However, these items have been tested to confirm that they move co their proper position' when required (i.e., on receipt of a Control Room Isclation.

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

The adequacy of the diesel generator air start system air receivers to perform their intended function was verified dur-ing preoperational tests 1-3KJ-05 " Diesel Generator Train A Synchronization, Load Rejection, 5 Air Starts, and 35 Consecu-tive Starts" (Unit 1 Train A), 1-3KJ-06 (Unit 1. Train B),

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 accumulators at VEGP is limited l

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-l tion on a loss of normal supplied air pressure was verified as

discussed above.

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

i A. Action Plan:

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

B. Response:-

[ Procedure 11880-1 (11880-2) " Turbine Building Rounds Sheets"

requires the Turbine Building operator to check prefilter and I---_______________---__ _. __ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ -____ _ . - _ _

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Exhibit b ,page N of1

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! RESP 0 HSE TO GENERIC LETTER 88-14 j Page 12 i

afterfilter differential pressure for each set of air dryers,

to check the moisture (dessicant-type) indicator located on each

! dryer can, to blowdown the prefilter and afterfilter drains for 3 each set of air dryers, to blowdown the instrument air receivers, j to blowdown the moisture separator drains, and to perform various checks and blowdowns for the rotary and receprocating air com-i pressors. These inspections and blowdowns are performed shiftly.

Maintenance Work Orders and/or Deficiency Cards are initiated as i appropriate to resolve potential problems identified during these

inspections.

3 L Preventive Maintenance (PM) standardized checklist SCLOO402 has been originated to provide for periodically verifying the dew -

1 point and oil content immediately downstream of the af terfilter i for each set of instrument air dryers on both Units. Previously,

! PM verifications of instrument air dewpoint and oil content were

! performed for Unit 1 per PM repetitive task 12420005-001W-N.

j 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 safety-related air-operated valves listed in Table 6. The air-set / regulator and associated air filter per this checklist will I be inspected for contaiminants such as oil, water, dirt, or debris and the filter will be replaced if it exhibits signs of 1 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 shoula 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.

VEGP 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 Deficiency Cards are initiated as appropriate to resolve poten- f tial-problems identified during these inspections.

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 receivers for both units.

i

' Exhibit 1 1 ,page 6 of d

- - - - - . . - - - - - . . .- . RESPONSE TO GENERIC LETTER 88-14 ^ ~ ' '~ ~ ~ ' ~ ~

Page 13 a

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 "EOC Diesel Generator Checkout" and were completed for the Unit 1 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.

4 j

i l

l

\

g

_ m -

Exhibit _b.,page b of 2 TABLE 1 PREOPERATIONAL TEST 1-3KB-01 (UNIT 1)

INSTRUMENT AIR QUALITY DATE LOCATION DEWPOINT 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. El. 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 PREOPERATIONALTEST2-3KB-01(UNIT 2)

INSTRUMENT AIR QUALITY l

DATE LOCATION DEWPOINT OIL CONTENT 1

06/04/88 Af ter filter "A" Discharge -800F 0 ppm I

. 06/04/88 Af terfilter "B" Discharge -800F 0 ppm 05/15/88 Turbine Bldg. El. 195' & 220' -800F 0 ppm 4

05/15/88 Turbine Bldg. El. 245' & 270' -800F 0 ppm 05/15/88 Auxiliary Bldg. Line -800F 0 ppm i

1 I

, l l

1

Exhibit b ,page b of 2 3

. . TABLE 3 PM CHECKS (talIT 1) __ _ - . _ .

INSTRLD OIT AIR QUALITY' DATE (WOd) LOCATION DEWPOINT OIL CONTENT

• 11/18/86 (18619762) Afterfilter "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) Af terfilter "B" Discharge +6.80F 11/19/87 (18708995) Af terfilter "A" Discharge - -800F 12/03/87 (18711877) Af terfilter "A" Discharge . -800F 07/19/88 (18804297) Af terfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -800F 0 ppm 07/26/88 (16804461) Af terfilter "A" Discharge -800F <1 ppe Afterfilter "B" Discharge -800F <1 ppm 08/02/88 (18804615) Af terfilter "A" Discharge -630F <1 ppe Af terfilter "B" Discharge -740F <1 ppe 08/09/88 (18804802) Afterfilter "A" Discharge -680F 0 ppe Af terfilter "8" Discharge -720F 0 ppm 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) Afterfilter "A" Discharge -800 0 ppm l

! Afterfilter "B" Discharge -780 0 ppm l I & C Shop Line -800F

, 09/06/88 (18805661) Afterfilter "A" Discha m -800F 0 ppm I

Af terfilter "B" Discharp -800F 0 ppm I Control Bldg. Level 8 -800F 09/13/88 (18805833) Af terfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -800F 0 ppm ,

09/21/88 (18806086) Afterfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -800F 0 ppm

I & C Shop Line I

l!

Exhibit O ,page N of 2_

TABLE 3 (Continued)

PM CHECKS (UNIT 1)

'~' ~~ ' ' ~ " ~ ' ~ ~ ~ ~ ~ ~ ~ ~ ~ '

INSTRUMENT AIR QUALITY DATE (WOf) LOCATION DEWPOINT OIL CONTENT 09/27/88 (18806202) Afterfilter "A" Discharge -670F 0 ppm 4

Afterfilter "B" Discharge -700F 0 ppm Control Bldg. Level 8 -770F Af terfilter "A" Discharge 10/04/88 (18806273) -710F 0 ppm j Afterfilter "B" Discharge -710F 0 ppm 10/05/88 (18806475) Af terfilter "A" Discharge -800F 0 ppm .

Af terfilter "B" Discharge -800F 0 ppm Control Bldg. Level 8 -800F 10/22/88 (18806727) Af terfilter "A" Discharge -680F 0 ppm Afterfilter "B" Discharge -680F 0 ppm 10/29/88 (18806998) Af terfilter "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) Afterfitler "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -560F 0 ppm 12/06/88 (18808385) Afterfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -590F 0 ppm 12/16/88 (18808653) Afterfilter "A" Discharge -760F 0 ppm Afterfilter "B" Discharge -610F 0 ppm 12/20/88 (18808654) Afterfilter "A" Discharge -690F 0 ppm Afterfilter "B" Discharge -600F 0 ppm 12/27/88 (18808655) Af terfilter "A" Discharge -610F 0 ppm Afterfilter "B" Discharge -430F 0 ppm 01/03/89(18808854) Af terfilter "A" Discharge' -460F 0 ppm Af terfilter "B" Discharge -220F 0 ppm 01/10/89(18808966) Afterfilter "A" Discharge -800F 0 ppm Afterfilter "B" Discharge -800F 0 ppm PM measurement of oil content was implemented in 1988

i t

Exhibits, pag @ d of 2.

TABLE 4 SPECIAL TESTING (Unit 1)

INSTRUDENT AIR QUALITY (Md0 #18900303)

DATE LOCATION DEWPOINT OIL C0KTENT 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 D -800F 0 ppm 02/03/89 Diesel Generator Bldg. lA -800F 0 ppm

, 02/03/69- Diesel Generator Bldg.18 -800F 0 ppm J

TABLE 5 1

DIESEL GENERATOR AIR START SYSTEM i7 AIR' QUALITY PREOP TESTING DATE PRE 0P AIR START TRAIN ROOM TEM DEWPOINT 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 36.30F 12/11/87 2-3KJ-02 2-2403-G4-002-K02 710F 400F l

l 1

I l

i Exhibit O ,page2 of 2 ,

TAK E 6 SAFETT-MGTED

_.. ____ ._.-INSTRUENT AIR USERS . - - - - - - - - - - - --

---

ACTIVE VALVES----

AIR FILTER VALVE VENDOR MODEL SIZE (M) ,

FEA-FSAR REF. POSITION 1HV13005A FISHER P595 50 FMEA-FSAR CLOSED 2HV13005A TABLE 10.3.3-1 1HV130058 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 1HV1300GB 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 IHV13007B FISHER P595 50 FMEA-FSAR CLOSED i 2HY13007B TABLE 10.3.3-1 1 1HV1300BA FISHER P595 50 FMEA-FSAR CLOSED 2HV13008A TABLE 10.3.3-1 1HV13008B FISHER P595 50 FMEA-FSAR CLOSED 2HV13008B TABLE 10.3.3-1 1HV7603A CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED 2HV7603A TABLE 10.3.3-1 1HV76036 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 A ,pageA of E l

)

. TABLE 6 (Continued) 5Atu Y-REl.Alts INSTRUENT AIR USERS

..... ACTIVE VALVES-----; - - - - -- --

AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION 1HV7603D CON 0 FLOW FH-20 35 FMEA-FSAR CLOSED' 2HV76030 TABLE 10.3.3-1 FISHER 67AFR 40 FMEA-FSAR CLOSED 1HV5280 2HV5280 TABLE 10.3.3-1 FISHER 67AFR 40 FMEA-FSAR CLOSED 1HV5281 2HV5281 TABLE 10.3.3-1 FISHER 67AFR 40 NONE CLOSED 1HV3502 2HV3502 s

FISHER P-594-1 40 NONE CLOSED 1HV8823

, 2HV8823 FISHER P-594-1 40 NONE CLOSED 1HV8824 2HV8824 FH-20 35 NONE CLOSED 1HV8843 CON 0 FLOW

.i 2HV8843 FH-20 35 NONE CLOSED 1HV8881 CON 0 FLOW 2HV8881 '

g GFH20XT1782 35 NONE CLOSED 1HV27901 CON 0 FLOW ,

2HV27901 FISHER P594-1 40 NONE CLOSED 1HV8871 2HV8871 FISHER P594-1 40 NONE CLOSED 1HV8964

• 2HV8964 FISHER P594-1 40 NONE CLOSED 1HV8888 2HV8888 1HV8380 FISHER P-594-1 40 NONE CLOSED 2HV8880 1HV8160 CON 0 FLOW FH-20 35 NONE CLOSED 2HV8160 1HV8152 FISHER P594-1 40 NONE CLOSED  ;

2HV8152 4

(Continued) 2 4

Exhibit 6 ,page32 of N TABLE 6 (Continued)

SAF t.IT-RELA Itm  ;

. . _ . . . INSTRimENT AIR USERS _ _ . . _ . _ _. _ _ . .

---

ACTIVE VALVES----

AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION 1HV8825 FISHER P-594-1 40 NONE CLOSED 2HY8825 ,

l- 1HV8890A FISHER P-594-1 40 NONE CLOSED 2HV8890A 1HY88908 FISHER P-594-1 40 NONE CLOSED 2HV88908 1HV8033 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HV8033 IHY8047 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HV8047 1HV8028 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HY8028 1HV3513 FISHER P595 50 NONE CLOSED 2HV3513 1HV3514 FISHER 67AFR 40 NONE CLOSED 2HV3514 1HV3507 FISHER P595 50 NONE CLOSED '

2HV3507 i 1HV3508 FISHER 67AFR 40 NONE CLOSED 2HV3508 ,

1HV5278 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HV5278 TABLE 10.3.3-1 l l

1HV5279 FISHER 67AFR 40 FMEA-FSAR CLOSED 2HV5279 TABLE 10.3.3-1 1HV7699 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED 2HV7699 i 1

1HV7136 CON 0 FLOW FH20XTKXGB1 35 NONE CLOSED l 2HV7136 i l

l l

(Continued) l 3 l

5 '

Exhibit 1 3 ,page. D of M-i TABLE 6 (Continued) 5AFETY-RELAIt.u INSTRLSENT AIR USERS '

. _ . . . . _ . . . _ _ _ _ .----ACTIVE VALVES-----

AIR FILTER VALVE VENDOR BRIDEL SIZE (M) FE A-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 l 1HV9385 CON 0 FLOW GFH20XT1782 35 NONE CLOSED 2HV9385 1HV9378 FI. SHER 67AFR 40 NONE CLOSED 2HV9378 1HV15198 CON 0 FLOW GFH20XT1782 35 FMEA-FSAR CLOSED 2HV15198 TABLE 10.4.9-4 1HV15197 CON 0 FLOW GFH20XT1782 35 FMEA-FSAR CLOSED j 2HV15197 TABLE 10.4.9-4 e ,

1HV15199 CON 0 FLOW GFH20XT1782 35 FMEA-FSAR CLOSED i i 2HV15199 TABLE 10.4.9-4 I 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 W

l

phibit_O ,page N of TABLE 6 (Continued)

SAFETY-RELAlts INSTRUMENT AIR USERS

. -ACTIVE VALVES----

~ ~

' AIR FILTER VALVE VENDOR MBEL 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 s

GFH20XT1782 35 NONE CLOSED 1HV10957 CON 0 FLOW 2HV10957 GFH20XT1782 35 NONE CLOSED 1 1HV10958 CON 0 FLOW 2HV10958 FISHER P595 50 FMEA-FSAR CLOSED 1HY15212A 2HV15212A TABLE 10.3.3-1 i

P595 50 FMEA-FSAR CLOSED 1HV152128 FISHER 2HV152128 TABLE 10.3.3-1  ;

FISHER P595 50 FMEA-FSAR CLOSED 1HV15212C 2HV15212C TABLE 10.3.3-1 FISHER P595 50 FMEA-FSAR CLOSED 1HV152120 2HV15212D TABLE 10.3.3-1 FISHER P595 50 FMEA-FSAR CLOSED 1HV15216A I

2HV15216A TABLE 10.3.3-1 FISHER P595 50 FMEA-FSAR CLOSED 1

1HY15216B 2HV15216B TABLE 10.3.3-1 FISHER P595 50 FMEA-FSAR CLOSED 1HV15216C 2HV15216C TABLE 10.3.3-1 i

FISHER P595 50 FMEA-FSAR CLOSED 1HV15216D 2HV152160 TABLE 10.3.3-1 (Continued)

- 5 1

t Exhibit _l.22. , page M of 2I

~

TABLE 6 (Continued) 5APtiT-RELAItu ~ ~ - ^ ~

INSTR 12E3tT ' AIR USERS . ~~

---

ACTIVE VALVES----

AIR FILTER VALVE VENDOR MODEL SIZE (M) FEA-FSAR REF. POSITION ILV0459 FISHER P594-1 40 NONE CLOSED 2LV0459 ILV0460 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 CLOSED

• 2HV522?

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

• i 2HV5228 1HY5229 WATTS F-602-4EJ 40 NONE CLOSE0*

2HV5229 1HV5230 WATTS F-602-4EJ 40 NONE CLOSED

• 2HV5230 AHV19722 CON 0 FLOW GFH20XT1782 35 NONE CLOSED  !

l AHY19723 CON 0 FLOW GFH20XT1782 35 NONE CLOSED i

• Assumes fa'lere ;c:,uton on feedwater isolation signal l

1 I

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• ?

, 3 TABLE 7 cx Ndt O ,page M Ol b

< SAFETY-RELATED INSTRUENT AIR USERS

---

ACTIVE DAIFERS-----

AIR FILTER FAILURE DAMPER VENDOR MM)EL SIZE (M) FEA-FSAR REF. POSITION AHV2534 NORGREN F12-400A3M 50 TABLE 9.4.2-2 CLOSED 4 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 r AHV12481 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 ANV12153 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 i

2HV12605 1HY12607 NORGREN F12-400A3M 50 TABLE 9.4. 3-5 CLOSED e 2HV12607 l 1HV12604 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED i 2HV12604 i 1HV12606 NORGREN F12-400A3M 50 TABLE 9.4.3-5 CLOSED 2HV12606 1HV12146 NORGREN F12-400A3M 50 TABLE 6.4.4r1 CLOSED 2HV12146 1HV12147 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED 2HY12147 1HV12148 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSEC

2HV12148 .

i

$ TABLE 7 (COMIIIRJED) ExhibitO_ ,page2b of N i

SAFETY-RELATED INSTRUIENT AIR USERS

..... ACTIVE DAprERS-----

i . . _ __ _ __ ._- .-

AIR FILTER FAILURE DAMPER VEle0R ICOEL SIZE (pl) FEA-FSid REF POSITION 1HV12149 NORGREN F12-400A3M 50 TABLE 6.4.4-1 CLOSED

2HV12149 1HV2626B FISHER 262C 40 NONE CLOSED 2HV26268 1HV26278 FISHER 262C 40 NONE CLOSED 2HV26278 1HV2628B FISHER 262C 40 NONE CLOSED 2HV2628B 1HY26298 FISHER 262C 40 NONE CLOSED 2HV2629B 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 9.4.5-3 CLOSED l

1HV12562 BALSTON TABLE 9.4.5-3 CLOSED' .

4 1HV12563 BALSTON TABLE 9.4.5-3 CLOSED' 1HV12596 FISHER 67AFR 40 NONE CLOSED 2HV12596 i 1HV12597 FISHER 67AFR 40 NONE CLOSED 2HV12597 1TV12086/12086A NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 4

2TV12086/12086A 1TV12090/12098A 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.

A

• Exhibit 12t , page ;22 og ,? Y TABLE 7 (CONTINUED) 5AFLTT-RELAltu INSTRUMENT AIR USES

,'~

' ~ ~ ~ ~~~

'~

---

ACTIVE DAM ERS----- -

AIR FILTER FAILURE e O A r tii! VENDOR MODEL $1ZE(M) FE A-FSAR REF. POSTION 1HV12010A NORGREN F12-400A3M 50 NONE OPEN 2HV12010A 1TV12095A/12095C NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12095A/12095C ITV12095B/12095D NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12095B/120950 l ITV12094A/12094C NORGREN F12-400 V( 50 TABLE 9.4.7-2 OPEN

2TV12094A/12094C ITV12094B/12094D NORGREN F12-400A3M 50 TABLE 9.4.7-2 OPEN 2TV12094B/120940 I F12-400A3M 50 TABLE 9.4.7-2 OPEN 1TV12096/IE096A NORGREN

! 2TV12096/11096A 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 l

i ITV12101/12101A NORGREN F12-400A3M 50 TABLE 9.4.7-2 CLOSE:

2TV12101/12101A t

1 e

j