ML20235L734
| ML20235L734 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/02/1989 |
| From: | Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8902270651 | |
| Download: ML20235L734 (4) | |
Text
FEB 0 2-1939 V,frginia Electric and Power Company jATTN:
'Mr. W. R. Cartwright, Vice President, l
a Nuclear Operations l
5000 Dominion Boulevard Glen Allen, VA 23060 Gentlemen:
SUBJECT:
CONFlaMATION OF ENFORCEriENT CONFERENCE DOCKCT NOS. 50-338 AND 50-339 This confirms the telephone conversation between G. L. Pannell of your staff and F. S. Cantrell of my staff, on January 24, 1989, concerning an Enforcement Conference to be conducted at the NRC Region li office on February 7, 1989, at 10:30 a.m.
We requested this meeting to discuss instrument air problems which have been identified at North Anna as they relate to der.ign control and corrective action.
Enclor.ure 1 contcins a summary of the instrument air system problems.
Enclusure ? contains a proposed meeting agenda listing the issues which are to be addressed at the Enforcement Conference.
An upcoming inspection report will further discuss these problems and also summarize the Enforcement Conference.
Should you have any question regarding these arrangements, we will be pleased to discuss them.
Sincerely, Original signed by Malcolm 1.. Ernst Acting Regional Mainistrator Enclocuras:
1.
Summary of instrument Air System Problerns 2.
Proposed Meeting Agenas cc w/encis:
G. E. Kane, Station Manager R. F. Saunders, Managar - Nuclear Programs and Licensitig C:monwe61th of Virginia J
bcc w/encls:
JNRC Resident Inspector DRS Technical Assistant Occonent Control Desk p'
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ENCLOSURE 1
SUMMARY
OF INSTRUMENT AIR SYSTEM PROBLEMS During s routine Quality Assurance inspection condur.ted in ' January and February 1988, problems involving the North Anna be"vice inspection and testing programs were determined.
These problems involved repetitive valve fai%res and increased valve stroke times.
Mony of these failures involved component cooling vater valves, and although the licensee determined no definite root cause, the failures were contributed to service water intrusion into the instrument air system on 4;H 1 24, 1907.
In this event, service water entered the instrument air systeu during blowdown of the recirculation spray
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Root u use anal sis of the original vaive failures is still j
heat exchangers.
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under investigation, j
i The licensee tested several of the affected valves to verify reliability /
operability, and retected the Unit 2 component cooling water valves.
Five of 29 ydives failed the tests.
IG August 1988, Generie Letter 88-14, Instrument Air Supply System Problems Affecting Safety 9 elated Equipment, requested licensees to perform a design and operations verification of the instiument air system including s
testing of air quality and verification that the design of the instrument air ic in accordance with its interded function.
Response to this Generic letter
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is due February 1989.
l Because of the oil and water.ntrusion problems and iswance of Generic Letter 83-14, in September 1988, the licensee ccmpleted a Cafety Systern Functional l
Inspection (SSFE) of the instrument air system.
This inspection disclosed findings related to the air gnlity in the instrument air lines and the I
configuration control program.
With regard to air quality, the SSFI concluded that North Anna is net committed to standaros that set limits for dew point, particle size, and oil content, and that tests for these limits are not normally conducted.
In reference to the configuration control findings, the SSF1 revealed numerous differences between the installed instrument air system and the Updated Final Safety Analysis h port (UFSAR)
These differences have contributed to the oil and water contamination in tFe instrument air system by using compressors that have limited moisture and oil removal capability and air dryer filters with retention sizet greater than the maximum particle size recommended by standards.
The SSFI also disclosed questions of the seismic 3
qualification of the compressor in use, as well as the emergency power supply.
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On January 4,1989, during the performance of a periodic test, erratic resporJe j
was observed from au auxiliary feedwater valve.
On January 7, a maintenance request was written to inspect the valve and during the inspection, approximately one quart of water was found in the valve positioner above the diaphram.
Based
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on clamical atalysis, the source of this water appeared to be fro,a the l
aforementioned service water system intrusion which occurred in April 1987.
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EUCLOSURE 1 2
Additionally, the concentration of molybdate in the samples indicated that I
condensation might be occurring in remote portions of the instrumerst air f
systo.
An investigation of the extent of the water intrusion into the 1
instrument air system revealed that 7 of 14 valves inspected had water in l
the actuators.
4 Dew point samples taken in various locations indicated the possibility of condensation being an additional source of water in the instrument air-system.
11 eat lamps were placed in the unheated pipe tunnels to the Auxiliary
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Feedwatee Pump I;ouse in order to maintain the temperature above 50 F.
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Two justifications for continued cperation (JC0s) were written on January 13, I
1989 (JCOs 89a01 and 89-02).
The former JC0 was written to justify continued j
I operation following discovery that several control valves in the auxiliary feedwater system had water inside their actuators.
This aC0 concluded that l
the 1987 water intrusion event was an isolated event, and that all the water l
was apparently not removed during clean-up.
JC0 89-02 was written to address l
the UFSAR discrepancies.
This JC0 concluded that the existing instrument air i
I system is boundet by the most limiting conditions.
in reviewing this sequence of evcqts, the NRC is concerned about the licensee's corrective action program to address water / oil intrusion into tiie instrument air system as well as the design control of this system.
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ENCLOSURE 2
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I FEBRUARY 7, 1989
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ENFORCEMENT CONFERENCE AGENDA j
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Opening Remarks NRC/VEPC0 II. Chronology of Licensee Identification VEPC0
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of Problems and NRC Notification
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III. Discussion of Issues / Evaluations VEPC0 10 CFR 50.59 Reviews of Impact of Modification to Add Sullair Compressor Discrepancies Between UFSAR and Installed Compressed Air. System Oil / Water Impact on Valve Operability, including Seals Impact Regarding Use of Construction Air to Supplement Instrument Air Instrument Air Capability to Meet Safety-Related Needs IV. Corrective Actions Including Testing of Accumulators VEPC0 as Stated in 1/13/89 JCO, SSFI Recommendations, and ildequate Trending Analysis V.
Conclusions / Mitigating Circumstances VEPC0 VI. Closing Remarks NRC i
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