ML20247A407

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Forwards Verification & Program Discussion Per Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Procedure in Place in Control Room to Address Loss of Instrument Air Sys Event
ML20247A407
Person / Time
Site: Mcguire, Catawba, McGuire, 05000000
Issue date: 05/08/1989
From: Tucker H
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-14, NUDOCS 8905230134
Download: ML20247A407 (37)
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[j-q' 4 yo g .;g'i DUKE POWER GOMPANY P.O. Box 33189 CHARLOTC N C. 28242 HAL B. TUCKER rztzenown non passmewr (yo4) 3y3 4531

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May 8, 1989 U. S. Nuclear Regulatory Commission

-Attn: Document Control Desk Washington, D.C. 20555

Subject:

~McGuire Nuclear. Station Catawba Nuclear Station Docket Nos. 50-369, -370; 50-413, -414 NRC Generic Letter No. 88-14 Instrument Air Supply. System Problems Affecting Safety-Related Equipment Gentlemen:

Mr. F. J. Miraglia, Jr. 's (NRC/0NRR) August 8,1988 letter (Generic Letter 88-14) concerned-instrument e.ir supply system problems affecting' safety-related

. equipment. The purpora of this generic letter was to request review of NUREG-1275 Volume 2,' and performance of a design and operations verification of the instrument air system. This verification was to include:

1. Verification by test that actual instrument air quality is consistent a with the manufacturer's recommendations for individual components j served.
2. Verification that mair.tenance practices, emergency procedures, and training ~are adequate to ensure that safety-related equipment will function'as intended on loss of instrument' air.
3. Verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function,' including verification by test that air-operated safety-related compenents will perform as expected in accordance with {

all design-basis events, including a loss of the normal instrument air 1 system. This. design verification should include an analysis of current ,

I air operated component failure positions to verify that they are correct for assuring required safety functions.

i In addition to the above, a. discussion of the program for maintaining proper '

instrument air quality was to be provided.

Accordingly, attached is the requested verification and program discussion for the McGuire and Catawba Nuclear Stations. Attachment 1 for each station addresses Generic Letter Item 1 above, Attachment 2 addresses Item 2, Attachment

'3 addresses Item 3, and Attachment 4 is the requested program discussion. Also attached (Attachment 5) for your convenience is a compilation from the above mentioned attachments of action items that remain to be completed and their 8905230134 890508 7 l PDR ADOCK 05000369h J l

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, U. S. Nuclear Regulatory Commission

... Page Two May 8, 1989-respective due dates. Pursuant to the requirements of the Generic Letter, when all requirements of the Generic letter have been implemented, written notification will be provided stating that all actions are complete, and.the documentation assembled for this verification will be retained for a minimum of

. .two years from this submittal date for future audit by the NRC staff.

Pursuant to.the provisions of 10CFR 50.54(f), I declare under penalty of perjury that the statements set forth.herein are true and correct to the best of my ,

knowledge. Please note that this submittal was'previously delayed via my letter of February 10, 1989. Should there be any questions concerning this matter, or if. additional information is required, please advise.

Very truly yours, gk -__ .. -

Hal B. Tucker PBN165/lcs Attachments xc: Mr. S. D. Ebneter

' Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta St., NW, Suite.2900 Atlanta, Georgia 30323 Mr. Darl Hood, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station Dr. K. N. Jabbour, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 I

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,U. S. Nucle:r Regulatory Commission

,, Pigs Three May 8, 1989 a

bxc: (w/ attachments) l R. L. Gill, Jr. '

P. F. Guill R. O. Sharpe R. M. Glover P. G. LeRoy J. S. Warren R. C. Futrell R. F. Cole G. W. Hallman C. L. Harlin L. A. Hentz D.-L. Rehn D. W. Murdock P. T. Farrish L. A. Reed R. L. Sweigart E. M. Geddie J. D. Wylie S. E. LeRoy J. E. Snyder W. F. Beaver J. R. Hilley T. N. Hoag Section File: MC-815.07 (88-14)

CN-815.07 (88-14)

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DUKE POWER COMPANY MCGUIRE NUCLEAR STATION NRC GENERIC LETTER 88-14 RESPONSE I

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. hl l; Attachment 1 1.

McGuire Air Quality Test Results Sample Dewpoint particulate Oil Content p:. Point ~ ( F) (Microns) (ppm) l-i 1.

? Dryer outlet ~ 41.7 0' <0.016 Unit 1 Auxiliary Building 36.2 0 <0.016 Unit 2 Auxiliary Building 34.0 3 <0.016 Unit 1 Doghouse 27.9 0 <0.016 Unit 2 Turbine Building- 18.3 0 <0.016 Air quality testing is performed per a recently written performance test proce-dure. Per this procedure, dew point in the instrument air system is determined every. six months, while oil concentration and particulate contamination are l detcrmined once per. year. Scmnle locations include the Service Building (dryer o

outlet), Turbine Building,- Auxiliary Buildings, and the Unit 1 Doghouse.

Samples were not obtained on the Containment air systems due to an interlock

-problem between the compressor and the dryer. This problem is being corrected at the present time.

The test. acceptance criteria will be determined by Duke's Design Engineering Department. The' acceptance criteria will be based on air operated. valve v6ndor 4 recommendations and the Instrument Air Standard ISA-S7.3-1975. l

--The criteria likely will be.as follows:

1. Dewpoint temperature at system pressure <35 . .
2. Oil-concentration <1 PPM.
3. No particles.>5 microns detected.

The dewpoint temperature was measured using a chilled mirror dewpoint hygrometer. Oil concentration is measured by passing 500 liters of air through a filter. The. filter is then analyzed by Duke's Industrial Health Group to (

. determine the mass of oil contained in the filter. The particulate content is checked by using a Royco Model 218 Portable Particle Monitor.

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l L Attachment 2.

McGuire Maintenance practices Review

. All preventative maintenance (PM) activities were reviewed on supply equipment

-and 'all'will' meet or exceed manufacturer's requirements after some minor addi-tions. The equipment reviewed were the reciprocating' compressors, centrifugal

compressor, refrigerant dryers, partic'u late filters, desiccant dryer, and' each containments Instrument Air system supply components. The following is a description of each' preventative maintenance activity on each of these compo-nents'.

The three reciprocating compressors ~ receive a semi-annual overhaul due to their age and' operating history. These compressors will be replaced by two 'new centrifugal ' compressors by 6/1/89. The following' checks are made during the. i semi-annual PM:

1. An' oil' sample.is drawn for analysis.
2. The inlet air filter and oil filter are replaced.
3. The compressor oil is' replaced.

4.- The condition of the belts are checked.

5. The unloader solenoid valves are checked.

6.. All valves are removed, ground, and reassembled.

7. Piston clearances are checked.
8. A functional verification is performed.

The one operating centrifugal compressor receives monthly, sem',-annual, and

. annual preventative maintenance. The following checks are made during the monthly PM:

1. .The oil level is checked.
2. ' 0i1 ;and water systems integrity is verified.
3. Oil filter D/P is checked.
4. .The inlet _ air filter primary element is inspected.
5. 'A functional verification is performed.

During the semi-annual PM, the following u.ecks are made in addition to those done on the monthly PM-

1. ~An. oil sample is drawn for analysis.
2. The main driver coupling is lubricated and alignment checked.
3. 'The prelube pump coupling is lubricated.
4. The oil' mist arrester is visually inspected.
5. The discharge check valve is visually inspected.
6. The condensate traps are removed and cleaned.
7. The inlet throttle and bypass valve calibration are checked.
8. . A functional verification is performed.

s During the annual PM, the following checks are made in addition to those done on the semi-annual PM:

1. The main driver is inspected.
2. The bull gear teeth are inspected for wear.
3. The bull gear bearing is checked for roughness.
4. The oil sump filters are inspected and cleaned.
5. The oil cooler tubes are inspected for leaks. ,
6. The inlet throttle valve.and bypass valve are visually inspected.  !
7. A functional verification is performed.

1 The four refrigerant dryers receive quarterly preventative maintenance. The j following checks are made during the quarterly PM.

1. A visual inspection is performed.
2. The refrigerant system and charge are checked. Freon is added if neces-sary. "  !
3. The condenser coils are cleaned.
4. A functional verification is cerformed. l The two full flow particulate filters have their elements replaced once per year or on high differential pressure, which ever comes first. I The Integrated Leak Rate Test (ILRT) desiccant dryer is only operated every three years and its air quality is verified prior to use. If necessary, the desiccant, prefilter, and after filter elements are replaced under a PM work request. ,

Each containment has its own, small, instrument air system. Each compressor, dryer, and coalescing filter receive monthly, semi-annual, and annual preventa-tive maintenance. The following checks are made during the monthly PM: '

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1. The inlet air filter is inspected.
2. The compressor hour meter reading is recorded.
3. The oil sump is vented.
4. The compressor oil is replaced.
5. V-belt tension is checked.
6. The oil return line orifice is cleaned.
7. The air receiver is vented.
8. The after cooler is inspected.
9. The air / oil separator is inspected.
10. The coalescing filter is inspected.
11. The refrigerant dryer is inspected.  !
12. A system functional verification is performed under full load. l l

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During the' semi-annual PM, the following checks are made in addition to those done.on the'. monthly PM:

11. The after cooler is cleaned and inspected"

.. .2. ;The motor sheave to compressor sheave is aligned and-the V-belt is tight-ened.

'3. The compressor t' s' nt is replaced.

4. "The dryer is inspeer .
5. The refrigerant charge on the dryer is checked.
6. The dryer condenser coils are cleaned.
7. A functional verification is performed.

.During the annual PM, the following checks are made in addition to-those done on the semi-annusi PM:

F 1. The inlet air filter. element'is replaced.

2. 'The coalescing filter element is replaced.
3. A function verification is performed.

IAE Maintenance Practice Review A pre'ventative maintenance program is being established for critical instrument air-' demand equipment. A. list of approximately 56 critical to operation air operated valves . ( A0VS) have been identified to have associated air regulator L filters replaced. ' These~ filters were replaced during the last Unit 1 and 2 outages. PM work requests are being written to change out these filters'every 2 years. This~ work activity will be completed by August.1, 1989. Additional PM's may'be established'as. deemed necessary.

~McGuire Emergency Procedure Review The t.oss' of? Instrument Air abnormal procedures were reviewed for the McGuire, Catawba, and Oconee nuclear stations in November and December of 1988. Guidance for the procedure review was provided by NUREG-1275, recommendation 2.a and reports provided by other industry groups such as NSAC and INP0. The procedure review involved determMng the availability of a procedure for each station, t the procedural strategy enployed to cope with loss of instrument air events, and a review of the technical content of.the procedures. 4 McGuire has in place, in the control room, a procedure to address a loss of instrument air system event. The overall strategy employed is to stabilize the plant by restoring the instrument air system functions by recovering normal air

. supply sources to providing a backup source of air and isolating any air leaks.

The technical content of the procedure carries out this strategy by identifying components to be manipulated, the sequence, and failure mitions of components j on lors of air. ' Our plants have experienced significant loss of air events.

The plants- recovered from these events without serious incident using the strategy that is contained in all three of the plant's' loss of air procedures.

The lessons learned from these events were used to strengthen the technical content of the proceduras.

i-2 y-1.. 'In conclusion, the McGuire loss of instrument air procedure is deemed adequate Lto cope.with anticipated loss of instrument air: events. Also, because of our- i experience with losses of air, the procedure.in effect has been validated.

McGuire Training Review  ;

1 BASIC AND GENERAL TRAINING Mechanical Maintenance The Contrc1 Valve Maintenance and Repair Lesson Plan was revised to reflect j problems that may result if extreme care is not taken to ensure no contami- l nation exists in the air system components.

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Power Plant Fundamentals The. existing " Compressed Air Systems" lesson plan covers the importance' of ')

. the Instrument Air System with discussion of uses of air systems for valve i operation and instrument control. This Lesson Plan also covers major components, function, and adverse effects'of loss of air. References to INPO SOER 88-1 (which was based in part on NRC Case Study Report AE00/C701,

.i.e., essentially NUREG 1275) have already been included.

. Instrument and Electrical

-SOER 88-1 will be added to the Pressure Measurement Lesson Plan, which is the first exercise oriented lesson addressing the use of instrument air i

! components in the Basic Instrumentation and Electrical (I&E) Program. This will be complete.by 7/1/89. Subject information will also be added to the Fisher Control Valve Actuator Lesson Plan presently under development for use'a's an' advance topic. The Instrument Air System and the failure of instrument air is presently covered in the " Plant Air Systems" lesson plan.

STATION-McCuire Nuclear Station will cover this SOER in its 489 Operating ExperSuce Program (OEP) Training Programs stressing the importance of the Instrument Air Systein and sensitizing the technicians to is vulnerability. SOER 88-1 will be reviewed at least every 3 years to determine its continued applicability.

BASIC OPERATOR TRAINING The operation of the instrument air system and the consequences of the loss of l- -instrument air are covered in the Systems Specific Module of the Basic Operator Training Program. This training is provided to all learners prior to them 1

reporting to the stations.

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Classroom training on the instrument air system is provided to all opera-tors during the Introduction to Systems Specific (ISS) module of training after reporting to the stations.

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.t e Each Non-Licensed Operator (NLO) is required'to qualify on the operation of the instrument air system.using the appropriate Training and Qualification (T&Q) guide' prior to operating the system.

e' .Each NLO requals on the operation of the instrument air system, after

' initial qualification, at a frequency deemed appropr_iate by the NLO requal program at McGuire. This frequency is presently every two years.

e Each licensed operator receives' classroom and simulator training on the loss of. instrument air during the license preparatory module. This train-ing includes specific simulator scenarios developed that require the operators to respond and to recover from a loss of instrument air.

. Each licensed operator receives requal training on the loss of instrument air at a frequency deemed' appropriate by the requal program at McGuire.

This training includes simulator training utilizing scenarios that require the operators to respond and to recover .from a loss of instrument air. ,

This training' is presently conducted at a frequency of each year at McGuire.

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Attachment 3 McGuire Instrument Air System Design Verification Item no. 3 of the subject document calls for " verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function, including verification by test that air-operated . safety-related components will perform as expected in accordance with all design-basis events, including a loss of the normal instrument air system. This design verification should include an analyais of current air-operated component failure positions to verify they are correct for assuring required safety functions". In order to meet the requirements of this item, Design's review for McGuire took place in five parts:

1) Verify that dryers and filters are sized correctly for existing and antici-pated future compressor capacity
2) Evaluation of instrument air lines located in areas where temperatures are potentially lower than the dryer dew point
3) Review instrument details to ensure that air-operated active valves fail in their intended positions
4) Check for non-qualified / extraneous devices which could impede the vent paths for the air-operated active valve actuators
5) Verify that backup accumulators are properly designed to perform their intended function The results of our review are as follows:

1). Verify That Dryers and Filters are Sized Correctly for Existing and Antici-pated Future Compressor Capacity:

McGuire has a total of four instrument air compressors, one centrifugal unit (1500 scfm) and three reciprocating units (650 scfm each). All are designed to be oil-free. The centrifugal compressor serves as the base unit while the three reciprocating units operate in a stand-by mode, starting on decreasing system pressure. The maximum anticipated base load is 1400 to 1500 scfm.

Discharge air from the compressors passes through a series of aftercoolers, moisture separators, dryers, and filters. The refrigerant dryers are designed to have a dew point of 35 F. Combined dryer capacity is 2100 scfm (three at 700 scfm each) while the combined filter capacity is 2400 scfm (two at 1200 scfm each). The filters are rated at 5 microns which is slightly higher than the ISA-S7.3 standard of 3 microns. However, 5 microns has been shown acceptable per Duke's review of air quality require-ments from the manufacturers of the associated air-operated equipment.

Therefore, based upon the above information, the McGuire instrument air system filters and dryers are adequately sized and are designed to provide high quality air to the components served.

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.2) . Evaluation of Instrument Air Lines Located in Areas Where Temperatures are potentially Lower Than the Dryer Dew point:

A. review was also performed to determine if instrument air lines were routed to areas which' could see temperatures potentially lower than 35 F (the dryer dew point) and, therefore, be susceptible to condensate forma-tion and/or freezing. The potential areas identified were the interior and exterior doghouses '(there are no instrument air lines routed to the yard which serve safety-related equipment). These areas will be maintained at a 40 F' minimum ambient temperature through the use of existing electrical heaters and administrative control 'of louver. positions. A Station Problem Report (SPR) was initiated for the station to address this problem by 6/15/89.

3) Review of Instrument Details to Ensure that Air-Operated Active Valves Fail in Their Intended Positions:

The McGuire active valve list was reviewed to determine which valves were air-operated (active valves are defined as those which are required to move to accomplish their safety function --i.e., prevent or mitigate the conse-quences of a design basis accident). Valve drawings and flow diagrtms were reviewed.to . determine the failure positions of the active valves. These are given in Attachment. A. . A review of corresponding instrument details confirmed _ that all the air-operated active valves at McGuire are designed

to fail,in their correct position due to loss of instrument air. Also, all air-operated valves on Attachment A are verified by test to go to their fail-safe position on a periodic basis with the exception of
1 YC-54,

-76, -113, -135, -148, -162, -176, -190 -204, -218, -232, and -246. A Problem Investigation Report (PIR) has been written to determine if these valves should be added.to the periodic valve inservice testing program.

4) Check For Non-Qualified / Extraneous Devices Which could Impede the Vent Paths For the Air-Operated Active Valve Actuators:

The instrument details referenced in Item #3 above were reviewed for non-qualified / extraneous devices which could impede the active valve

' actuator vent paths. This is significant because it may affect the ability of these valves to achieve their failure positions on a loss of air.

Several potential concerns were discovered. Non-qualified positioners were found' between safety-related solenoid valves and the operators on sixteen (16) active valves. The PIR referenced in item #3 above also addresses this issue. Subsequent corrective action will be taken.

During the current Unit 1 outage, the pneumatic controls for an additional valve (1NV459) were found to be connected in error, even though the instru-ment details were drawn correctly. The valve controls will be connected correctly during the outage.

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5) Verify that Backup Accumulators are Properly Designed to Perform Their Intended Function:

The list of air-operated active valves was again reviewed to determine which of these valves had accumulators as a redundant source of air to ensure the valve achieves its proper failure position. The only air-operated active valves with vendor supplied accumulators are 1 & 2 RN-89,

-190 (Nuclear Service Water System). Duke ~then performed a design veri-fication. -The accumulators were found to be properly sized to perform their intended function; yet, the system lines were found to contain extraneous devices which could impede the vent paths. PIRs were written and resolved, and subsequent corrective action was taken to install qualified components.

Summary And Action Items:

1) The McGuire instrument air system filters and dryers are adequately sized and are designed to provide high quality air to the components served.
2) The interior and exterior doghouses will be maintained at a minimum ambient temperature of 40 F through the use of existing electrical heaters and administrative control of louver positions. A Station Problem Report (SPR) was initiated for the station to address this problem by 6/15/89.
3) All'of McGuire's air-operated active valves fail in their correct position on loss of air per instrument detail review. Also, all air-operated valves at McGuire are verified by test to go to their fail-safe position on a periodic basis with the exception of: 1 YC-54, -76, -113, -135, -148,

-162, -176, -190, -204, -218, -232, and -246. A Problem Investigation Report (PIR) has been written to determine if these valves should be added to the periodic inservice testing program. This PIR also addresses the non-qualified positioners between safety-related solenoid valves and the operators on sixteen (16) active valves. Subsequent action will been taken.

4) The accumulators for active valves 1 & 2 RN-89, -190 (Nuclear Service Water System) are properly sized to perform their intended function; yet, the system lines were found to contain extraneous devices which could impede the vent paths. PIRs were written and resolved, and subsequent corrective action was taken to install qualified components.

In summation, McGuire has recognized the need to provide quality instrument air and is taking proper action to ensure these needs are met. To the best of our knowledge, the instrument air system at McGuire is designed in accordance with its intended function. Any design deficiencies have been identified and proper corrective action has been/is being taken. Verification by test that air-operated safety-related components will perform as expected has been conducted.

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q N5 o ATTACHMENT A pg. 1 of.4 MCGUIRE AIR-OPERATED ACTIVE VALVES OPERATOR FAILURE POSITIONS Valve Tag Failure Position 1,.2 BB1 Closed 1, 2 BB2 Closed 1, 2 BB3 Closed 1, 2 BB4 Closed 1, 2 BB5 Closed-1, 2 BB6 Closed 1, 2 BB7 Closed

- 1, 2 BB8 Closed 1, 2 CA20 Closed 1, 2 CA27 Closed 1, 2.CA32 Closed 1, 2 CA36 Open 1, 2 CA40 Open -l 1, 2 CA44 Open  ;

1, 2 CA48 Open 1, 2 CA52 Open 1, 2 CA56 Open

- 1, 2 CA60 Open 1, 2 CA64 Open 1, 2 CF17 Closed 1, 2 CF20 Closed

'1, 2 CF23

. Closed 1, 2 CF32 Closed  !

1 2 CF104 Closed 1 1, 2 CF105 Closed 1, 2 CF106 Closed 1, 2 CF107 Closed 1, 2 KC57 Open 1, 2 KC82 Open 1, 2 KC320 Closed i 1, 2 KC332 Closed 1, 2 KC333 Closed 1, 2 NC32 Closed 1, 2 NC34 Closed 1,,2 NC36 Closed 2 NC56 Closed 1, 2 ND14 Open 1, 2 ND29 Open 1, 2 NF228 Closed 1, 2 NF233 Closed 1, 2 NF234 Closed 1, 2 NV457 Closed 1, 2 NV458 Closed I

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ATTACHMENT A. pg. 2 of 4 (cont.)

MCGUIRE AIR-OPERATED ACTIVE VALVES OPERATOR FAILURE POSITIONS Valve Tag Failure position 1, 2 NV459 Closed 1 RF821 Closed 1 RF832 Closed pg 1, 2 RN21 Closed 1, 2 RN22 Closed 1, 2 RN25 Closed E 1, 2 RN26- Closed 1, 2 RN68 Open 1, 2 RN89 Open 1,.2-RN103 Open 1, 2 RN112 Open 1, 2 RN114 Open 1, 2 RN117 Open 1, 2 RN126 Open 1, 2 RN130 Open 1, 2 RN140 Open 1,'2 RN161 Open 1, 2 RN166 Open 1, 2 RN170 Open 1,'2 RN190 Open i 1, 2 RN204 Open 1, 2 RN213 Open 1, 2 RN215 Open 1, 2 RN218 Open .

1,-2 RN227 Open 1, 2 RN231 Open 1, 2 RN240 Open 1, 2 RN252 Closed 1,'2 RN253 Closed 1, 2 RN276 Closed l 1, 2 RN277 Closed 1 RN442 Open 1 RN445 Open 1 RN457 Open i 1 RN460 Open i 1, 2 RV32 Closed l 1, 2 RV33 Closed I 1, 2 RV76 Closed i 1, 2 RV77 Closed 1, 2 RV79 Closed 1, 2 RV80 Closed 1, 2 RV101 Closed i

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ATTACHMENT A pg. 3 of 4 (cont.)

MCGUIRE AIR-OPERATED ACTIVE VALVES OPERATOR FAILURE POSITIONS Valve Tag Failure Position 1, 2 RV102 Closed 1, 2 SA48 Open 1, 2 SA49 Open 1, 2 SM1 Closed L 1, 2 SM3 Closed 1, 2 SMS Closed' 1, 2 SM7 Closed 1, 2 SM9 Closed 1, 2 SM10 Closed 1, 2 SM11 Closed 1, 2 SM12 Closed 1, 2 SV1 Closed 1, 2 SV7 Closed 1, 2 SV13 Closed 1, 2 SV19 Closed 1, 2 VP1 Closed 1, 2 VP2 Closed 1, 2 VP3- Closed 1, 2 VP4 Closed

( 1, 2 VP6 Closed i 1, 2 VP7 Closed 1, 2 VP8 Closed 1, 2 VP9- Closed 1, 2 VP10 Closed 1, 2 VP11 Closed 1, 2 VP12 Closed 1, 2 VP13 Closed 1, 2 VP15 Closed 1, 2 VP16 Closed 1, 2 VP17 Closed 1, 2 VP18 Closed 1, 2 VP19 Closed 1, 2 VP20 Closed 1, 2 VQ1 Closed 1, 2 VQ2 Closed 1, 2 VQ5 Closed 1, 2 VQ6 Closed 1, 2 VX31 Closed 1, 2 VX33 Closed 1 YC54 Note 1 1 YC76 Note 1 1 YC113 Note 1

e ATTACHMENT A pg. 4 of 4 (cont.)

MCGUIRE AIR-OPERATED ACTIVE' VALVES OPERATOR FAILURE POSITIONS Valve Tag Failure position 1 YC135 Note 1 1 YC148 Note 1 '

1 YC162 Note 1 1 YC176 Note 1 1 YC190 Note 1 1,YC204 Note 1 1 YC218 Note 1 1 YC232 Note 1 1 YC246 Note 1 1 YC347 Open 1 YC357 Open Note 1 - These 3-way valves fail to a position to allow chilled water to flow through the coil of their respective air handling units.

~ SYSTEM KEY BB - Steam Generator Blowdown System CA - Auxiliary Feedwater System a CF - Main Feedwater System KC - Component Cooling System ]

q NC - Reactor Coolant System  ;

ND - Residual Heat Removal System '

NF - Ice Condenser Refrigeration System '

NV - Chemical Volume and Control System RF - Fire Protection System RN - Nuclear Service Water System RV - Containment Ventilation Cooling Water System 1 SA - Main Steam Supply to Auxiliary Equipment i SM - Main Steam System SV - Main Steam Vent to Atmosphere VP - Containment Purge Ventilation System VQ - Containment Air Deluge and Addition System j VX - Containment Air Return Exchange & Hydrogen .-

Skimmer System YC - Chilled Water System

Attachment 4 McGuire Instrument Air Quality Program i

Instrument air is presently supplied by three reciprocating and one centrifugal compressor. In the near future, all instrument air will be supplied by three centrifugal comr assors. All existing and future compressors are oil free.

Each compressor cafes suction' from the service building basement through an inlet filter. This area is free of corrosive contaminants and hazardous gases.

Downstream of each reciprocating compressor, the hot compressed air flows through an aftercooler and water separator before discharging into a receiver.

The aftercooler cools the hot compressed air and the water separator removes any water condensed in the cooling process. Downstream of the receivers, the instrument air is dried to a dew point of 35oF to 39 F by four refrigerated air dryers. After the dryers, the air passes through one of two full flow particu-late filters which remove particulate larger than five microns. At each air operated valve or instrument the air is filtered again through a filter regula-tor. Each containment is provided with an independent source of instrument air by a rotary screw compressor. The compressor takes suction from containment through a filter. From the compressor, the air flowe into an air receiver, after cooler, water separator, refrigerated air dryer, and a coalescing filter.

The coalescing filter removes 99.9% of the oil.

The instrument air system is now fully tested for acceptable air quality on a regular basis. Air moisture content is tested semi-annually, oil content and foreign particulate are tested annually. Air dew point should not exceed 35 F, oil content should not exceed 1 ppm, and foreign particulate should not exceed 5 microns in size. If any of these limits are exceeded, appropriate corrective actions are taken. Initial sampling points are each containment header, service building (dryer outlets), auxiliary building, turbine buildings, and each dog house. . After which, sample points will be limited to each containment header, the dryer outlets, and any identified problems headers.

All instrument air supply components are maintained in accordance with their respective manufacturers recommendations and our own maintenance experience.

Also, the filter-regulators associated with critical to operation air-operated valves will be regularly maintained by August 1, 1989.

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Compilation of McGuire Action Items l'. 'The air. quality testing specification will be written by 6/1/89. <

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2. The air-operated valve filter change out periodic preventive maintenance -j procedures on 56 air-operated valves will be written by 8/1/89. 1
3. 'The interior and exterior doghouses 'will be maintained at or above 40 F.

through the use of existing space heaters and administrative control of ,

louver positions by 6/15/89. '

4.- A Problem Investigation Report (PIR) will determine whether 12 Unit 1 YC valves will be added to the periodic valve inservice testing program. This

-PIR is also d dressing the non-qualified positioners between safety-related solenoid valves and the operators on the same 12 YC valves including-4 RN-valves. '

5. SOER'88-1 will be added to the Pressure Measurement Lesson Plan by 7/1/89.

Information will also be added to the Fisher Control Valve Actuator Lesson i Plan, presently under development. I

5. Valve 1NV459 controls will be correctly connected by end of the current -

Unit 1 outage.

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'9 DUKE POWER COMPANY CATAWBA NUCLEAR STATION NRC GENERIC LETTER 88-14 RESPONSE t

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Attachment 1 Catawba Air Quality Test Results Sample Dewpoint Particulate Oil Content Point ( F) (Microns) (PPM)

Unit 1 Service Building 31.5 <5 0.02 Unit 1 Turbine Building 31.5 <5 0.33 Unit 1 Auxiliary Building 27.8 <5 0.02 Unit 2 Service Building 32.1 <5 0.017  ;

Unit 2 Turbine Building 29.9 <5 0.0 Unit 2 Auxiliary Building 27.8 <5 0.033 Air quality testing is performed per a performance test procedure. Per this procedure, dew point in the instrument air system is determined every six months, while oil concentration and particulate contamination are determined once per year. Sample locations include the Turbine Buildings, Service Build-ings, and the Auxiliary Buildings.

The test acceptance criteria was determined by Duke's Design Engineering Depart-ment. The acceptance criteria is based on air operated valve vendor recommenda-tions and the Instrument Air Standard ISA-S7.3-1975. The criteria is as fol-lows:

1. Dewpoint temperature at system pressure <35'F.
2. Oil concentration <1 PPM.
3. No particles >5 microns detected.

Dewpoint temperature is measured utilizing a General Eastern Condensation Dew point Hygrometer. Oil concentration is determined by passing a predetermined volume of air through a filter, then analyzing the filter for oil. This analy-sis is performed by Duke's Industrial Health Group. Particulate contamination is checked with a Royco Model 218 Portable Particle Monitor.

i. y Attachment 2 L Catawba-Maintenance practices Review All preventative maintenance (PM) activities were reviewed.on supply equipment and all will meet or exceed vendor requirements af ter some additions. The equipment reviewed were the reciprocating compressors, centrifugal compressor, 4 refrigerant dryers, desiccant dryers, and coalescing filters. The following is a description of each preventative maintenance activity on each of these compo-nents.

- The three reciprocating compressors receive quarterly, semi-annual, and annual c- preventative maintenance. The following checks are made during the quarterly PM:

1. A visual inspection of all compressor components is performed.
2. The air intake pre-filter and final filter are checked, cleaned, and replaced if necessary.
3. The compressor run time is recorded.
4. The carrier ring wear clearance is checked.
5. 'The compressor :s returned to service and a function verification is performed.
6. The oil. pressure, level, and water temperature is checked.
7. The condition of the V-belts are checked.
8. The after cooler moisture separator and receiver tanks are blown down.

During the semi-annual PM, the following checks are made in addition to those done on the quarterly PM:

1. The compressor oil and oil filter are replaced.
2. The crankcase oil screen is cleaned.
3. A crosshead and crankcase inspection is performed.
4. The air breather is cleaned, i
5. The motor is greased.
6. A functional verification is performed. ,

1 During the annual PM, the following checks will be made in addition to those I done on the semi-annual PM. This is a new PM and will be added by 9/1/89: l

1. All valves are inspected and cleaned.
2. The cylinder water jackets are inspected and cleaned.

3 .~ The intercooler is inspected and cleaned.

In addition to the above PM's, a complete compressor overhaul will be performed every 8000 hours0.0926 days <br />2.222 hours <br />0.0132 weeks <br />0.00304 months <br /> of run time. The following checks will be made in addition to those done on the regular PM's. This is a new PM and will be added by 9/1/89:

1. The pistons are removed and inspected.
2. The cylinder bore is checked for wear.

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3. The crosshead and crosshead wrist pin are inspected and clearances are checked.
4. The main bearings are inspected.
5. A functional verification is performed.

The one operating centrifugal compressor receives bi-monthly, semi-annual, and annual preventative maintenance. Several steps are being added to each PM.

This will be complete by 9/1/89. The following checks are made during the bi-monthly PM:

1. The air pre-filter and final filter are replaced if required.
2. The moisture traps are manually blown down.
3. The compressor oil level is checked. (ADD)
4. Oil and water systems integrity is verified. (ADD)
5. Oil filter D/P is checked and changed if required. (ADD)
6. A functional verification is performed.

During the semi-annual PM, the following checks are inade in addition to those done on the bi-monthly PM:

1. The mist arrester is replaced if necessary. .
2. The discharge check valve is inspected. ,
3. The condensate traps are removed and cleaned.
4. The main driver coupling is lubricated and its alignment is checked. (ADD)
5. The inlet and bypass valve calibration is checked. (ADD) I
6. An oil sample is drawn and analyzed. (ADD)
7. The oil filter housing is checked for corrosion and its sealing surfaces {j are checked. (ADD) {
8. A functional verification is performed.

During the annual PM, the following checks are made in addition to those done on the semi-annual PM:

1. The oil pump suction screens are inspected and cleaned.
2. The discharge check, inlet throttle, and bypass valves are all inspected. I
3. The shell and tube side of the oil cooler is inspected and cleaned. (ADD)
4. The bull gear teeth and bull gear bearings are inspected. (ADD)
5. A functional verification is performed.

s The four refrigerant air dryers receive quarterly and annual preventative )

maintenance. The annual PM is new and will be added by 9/1/89. The following ]

checks are made during the querterly PM: j

1. A general, external, visual inspection is performed looking for broken or missing parts.
2. The dryer is removed from operation.
3. The condensate system is drained, if required, the automatic traps are i cleaned. I
4. The service panel is removed and the refrigerant system is inspected and l cleaned. (
5. The fan motors are lubricated. 1 i

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6. The dryer is returned to service.
7. The refrigerant is checked through the liquid indicator.
8. All parameters are verified to be within the normal limits.
9. The unit is adjusted as necessary to achieve proper operation.

During the annual PM, maintenance is performed on the exchanger coil:

1. The dryer is removed from service.
2. The dryer is isolated from the Instrument Air system.
3. The interior of the exchanger coil is cleaned, soaked, and flushed.
4. The unit is returned to service.

The Integrated Leak Rate Test (ILRT) desiccant dryer is only operated every three years and its air quality is verified prior to use. If necessary, the desiccant end filters are replaced.

The two small desiccant dryers serving outdoor components receive semi-annual preventative maintenance. This PM is a general inspection and will verify that the moisture indicator gauge is reading below 90%. If it's above 90%, a new desiccant cartridge is installed.

The four coalescing filters have their elements replaced once per year or on high differential pressure, whichever comes first.

IAE Maintenance Practico Review A preventative maintenance program is being established for critical instrument air demand equipment. A list of approximately 42 critical to operation air operated valves (A0Vs) have been identified to have their associated air regulator filters replaced. These filters have been replaced for Unit 1, and Unit 2 filters should be replaced by May 31, 1989. PM work requests are being written to change out these filters every two (2) years. This work activity will also be conpleted by May 31, 1989. Additional PM's may be established as deemed necessary.

Catawba Emergency Procedure Review The Loss of Instrument Air abnormal procedures were reviewed for the McGuire, Catawba, and Oconee nuclear stations in November and December of 1988. Guidance for the procedure review was provided by NUREG-1275, recommendation 2.a and reports provided by other industry groups such as NSAC and INP0. The procedure review involved determining the availability of a procedure for each station, the procedural strategy employed to cope with loss of instrument air events, and a review of the technical content of the procedures.

Catawba has in place, in the control room, a procedure to address a loss of instrument air system event. The overall strategy employed is to stabilize the plant by restoring the instrument air system functions by recovering normal air supply sources to providing a backup source of air and isolating any air leaks.

The technical content of the procedure carries out this strategy by identifying components to be manipulated, the sequence, and failure positions of components l

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on loss of air. 0ur plants have experienced significant loss of air events.

The plants recovered from these events without serious incident using the strategy that is contained in all three of the plant's loss of air procedures.

The lessons learned from these events were used to strengthen the technical content of the procedures.

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In conclusion, the Catawba loss of instrument air procedure is deemed adequate to cope with anticipated loss of instrument air events. Also, because of our experience with losses of air, the procedure'in effect has been validated.

Catawba Training Review BASIC AND GENERAL TRAINING Mechanical Maintenance

-The Control Valve Maintenance and Repair Lesson Plan was revised to reflect problems that may result if extreme care is not taken to ensure no contami-nation exists in the air system components.

Power Plant Fundamentals The existing " Compressed Air Systems" lesson plan covers the importance of the Instrument Air System with discussion of uses of air systems for valve operation and instrument control. This Lesson Plan also covers major components, function, and adverse effects of loss of air. References to INPO SOER 88-1 (which was based in part on NRC Case Study Report AE0D/C701, i.e., essentially NUREG 1275) have already been included.

Instrument and Electrical SOER 88-1 will be added to the Pressure Measurement Lesson Plan, which is .

.the first exercise oriented lesson addressing the use of instrument air components in the Basic Instrumentation and Electrical (I&E) Program. This will be complete by 7/1/89. Subject information will also be added to the Fisher Control Valve Actuator Lesson Plan presently under development for use as an advance topic. The Instrument Air System and the failure of instrument air is presently covered in the " Plant Air Systems" lesson plan.

STATION Catawba Nuclear Station will cover this 50ER in its '89 Operating Experience Program (OEP) Training Programs stressing the importance of the Instrument Air System and sensitizing the technicians to is vulnerability. SOER 88-1 will be reviewed at least every 3 years to determine its continued applicability.

BASIC OPERATOR TRAINING

' The operation of the instrument air system and the consequences of the loss of

, instrument air are covered in the Systems Specific Module of the Basic Operator

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Training Program. This training is provided to all learners prior to them reporting to the stations.

  • Classroom training on the instrument air system is provided to all opera-ters during the Introduction to Systems Specific (ISS) module of training after reporting to the stations.
  • Each Non-Licensed Operator (NLO) is required to qualify on the operation of the instrument air system using the appropriate Training and Qualification (T&Q) guide prior to operating the system.
  • Each NLO requals on the operation of the instrument air system, after initial qualification, at a frequency deemed appropriate by the NLO requal program at Catawba. This frequency is presently every four years.
  • Each licensed operator receives classroom and simulator training on the loss of instrument air during the license preparatory module. This train-ing includes specific simulator scenarios developed that require the operators to respond and to recover from a loss of instrument air.

. Each licensed operator receives requal training on the loss of instrument air at a frequency deemed appropriate by the requal program at Catawba.

This training includes simulator training utilizing scenarios that require the operators to respond and to recover from a loss of instrument air.

This training is presently conducted at a frequency of every year at Catawba.

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t-i Attachment 3  !

Catawba Instrument Air System Design Verification Item no. 3 of the subject document. calls for " verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function, including verification by test that air-operated safety-related components will perform as expected in accordance with all design-basis events, including a loss of the normal instrument air system. .This desis, verification should include an analysis of current air-operated component 1?ilure positions to verify they are correct for assuring required safety functions". In order to meet the requirements of this item, Design's review for Catawba took place in five parts:

1) Verify that dryers and filters are sized correctly for existing and antici-pated future compressor capacity
2) Evaluation of instrument air lines located in areas where temperatures are potentially lower than the dryer dew point
3) Review instrument details to ensure that air-operated active valves fail in their-intended positions
4) Check for non-qualified / extraneous devices which could impede the vent paths for the air-operated active valve and safety-related damper actuators
5) Verify that backup accumulators are properly designed to perform their intended function The results of our review are as follows:

1)- Verify That Dryers and Filters are Sized Correctly for Existing and Antici-pated Future Compressor Capacity:

Catat a has a total of four instrument air compressors One of these is the isu-tly installed centrifugal compressor (1537 scim) and the other three are the original reciprocating compressors (650 scfm each). Nor-mally, the centrifugal compressor serves as the base compressor and two of the reciprocating units serve as standby compressors, ready to start as system load demands them. The maximum anticipated base load is 1400 scfm.

In terms of peak demand, only the centrifugal compressor and one of the reciprocating units are expected to be needed simultaneously. Their combined output would be 2187 scfm. Installed refrigerant air dryer capacity is 2800 scfm (four at 700 scfm each) and filter capacity is 3600 scfm (four at 900 scfm each). Cyclone air / water separators are installed in each reciprocating compressor's discharge line upstream of the dryers.

The design dew point of the refrigerant air dryers is 35 F at system pressure and rated flow. The filters have retention characteristics as follows: 4 Solid particle retention - 100% of particles 2 1.0 micron Oil aerosol particle retention - 95% of aerosols 2 0.04 micron

- 100% of aerosols 2 3.00 micron

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d-Additional _ filtration of supply instrument air to instrumentation and solenoid valves is done by each element's filter regulator. Duke has specified and supplied filters with the following ratings, except where l

vendor recommendations deviate:

Component Filter Rating l

pneumatic instruments 5 micron solenoid valves 50 micron

! Occasional problems with solenoids in refrigerant air dryer compressor L freon circuits have been observed. Some of the original solenoid valves intermittently fail to cycle as intended, or cycle excessively. A new type of solenoid has been installed on two of the dryers. To date, cycling problems have ceased. Station personnel continue to monitor the situation on a daily basis and will take corrective action as they deem appropriate.

Therefore, the Catawba instrument air system filters and dryers are ade-quately sized and are designed to. provide high quality air to the compo--

nents served. Any operational problems have been identified and proper corrective action has been taken.

2) Evaluation of Instrument Air Lines located in Areas Where Temperatures are potentially Lower Than the Dryer Dew Point.

A review was also performed to determine if instrument air lines were routed in areas which could see temperatures potentially lower than the dryer dew point and therefore be susceptible to condensate formation and/or freezing. Several potential areas weie identified. Desiccant air driars, which are designed to drop the dew point to -40 F, are installed in lines upstream of- those portions subjected to temperatures below 40 F.

Two problems surfaced as a result of this review. First, heaters in the inboard and outboard doghouses are presently set to maintain a 35 F ambient temperature rather than 40"F. Second, each instrument air line routed to the yard has a desiccant air dryer which can be " valved in" during cold weather when line temperatures could potentially drop below 40 F. Duke has determined these dryers, to date, have not been used when needed.

Duke is taking appropriate action to address these problems. A Problem Investigation Report (PIR) was written to reset the heaters to maintain a minimum temperature of 40'F. In addition, a change to the FSAR has been written regarding this setpoint. As for the desiccant dryers, Duke's Design Engineering Department will issue written guidelines to the site prior to October 1, 1989 for their alignment during the winter months.

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3) Review of Instrument Details to Ensure That Air-Operated Active Valves Fail in Their Intended Positions:

The Catawba Active Valve List was reviewed to determine which valves are air-operated (active valves are defined as those which are required to move to accomplish their safety function - i.e., prevent or mitigate the conse-quences of a design basis accident). Air-operated safety-related dampers were also identified. Valve drawings and the Catawba Active Valve List were reviewed to determine the failure positions of the active valves while manufacturer's drawi qs and Duke flow diagrams were reviewed to determine the failure posit' s of the safety-related dampers. Valve and damper numbers and thei- espective failure positions are given in Attachment A.

A review of the corresponding instrument details confirmed that all the air-operated active valves and safety-related dampers at Catawba are designed to fail in their correct position on loss of instrument air.

Also, all of the air-operated valves and dampers on Attachment A are verified by test to go to their fail-safe position on a periodic basis with the exception of: 1 & 2 NV-1A, -2A, -1228, and -1238. As a result of a previously initiated design study, 1 & 2 NV-1A and -2A will be added to the periodic valve inservice testing program. Valves 2 NV-1A, -2A will be tested during the present refueling outage while valves 1 NV-1A, -2A will be tested during the next cold shutdown. Valves 1 & 2 NV-122B and -123B do not receive a safety signal and, therefore, are not fail-safe tested.

4) Check For Non-Qualified / Extraneous Devices Which Could Impede the Vent Paths For the Air-0perated Active Valve And Safety-Related Damper Actua-tors:

a) Valves -

This task was segregated into two categories:

i) Non-qualified extraneous devices supplied with the valve and actuator -

Manufacturer's drawings for the air-operated active valves and their respective actuators were reviewed to determine if any non-safety vendor supplied devices existed between the actuators and the safety solenoid valves in the air supply line. From this review, no problems were identified, ii) Non-qualified extraneous devices supplied separately from the valve and actuator -

Catawba's instrumentation details for active valves were reviewed and yielded two problems:

First, the solenoid valves for the Main Feedwater System (CF)

Feedwater Bypass Control Valves (1 & 2 CF30, 39, 48, and 57) were found to be non-qualified. This status has been justifitJ since

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1 i ' O, e their failure will not preclude the process valves from ful-filling their safety function. A' Station Problem Report (SPR) has: been written to initiate replacement with IE _ qualified solenoids. The replacements are currently scheduled for the end of each unit's next refueling outage (U1 - 2/11/90; U2 -

L. 7/31/90).

Second, non-safety solenoid valves 1 & 2 SASV0052, which are -

installed in safety-related tubing runs, have been identified.

These solenoids are in the actuator vent paths for the Auxiliary

Feedwater Pump Turbine Steam Control Valves. The solenoids will not preclude the system from its fail-safe design. since the '

safety functions related to the control valves are performed by othcr solenoid. valves in. the instrument line which are safety-related. The current design does not present an operability problem, but they.are non-1E qualified. They will be moved to a point in the tubing outside the safety vent path. An SPR has been issued to initiate corrective action on this problem. The Unit 2 work was completed on 3/30/89 while the Unit I work is currently scheduled for 2/11/90 (end of its.next refueling outage).

- b) Dampers -

Manufacturer's control and instrument details were reviewed for non-qualified, extraneous devices associated with the safety-related dampers. It was determined that the pilot valves for damper- 1 & 2 FPX-2A,8 through -7A,B are non-safety. However, these damp.. s are required only for the movement of fuel and not to mitigate the conse-quences of a design basis accident (i.e., they perform a non-safety function). Therefore, we do not recommend replacing the existing pilot valves with safety grade valves. -

5) Verify That Backup Accumulators are Properly Designed to Perform Their Intended Function:

The-list of air-operated active valves was again reviewed to determine which of these valves had accumulators as a redundant source of air to ensure the valve' achieves its proper failure position. Per the review, no such valves exist.

' Summary ,d Action Items:

1)- The Catawba instrument air system filters and dryers are adequately sized i and are designed to provide high quality air to the components served. Any operational problems have been identified and proper corrective action has

'aen taken.

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2)- A Problem Investigation Report (PIR) was written to reset the heaters in l the inboard and outboard doghouses to maintain a minimum temperature of L .40 F. In addition, a change to the FSAR has been written regarding this setpoint.

3) Design Engineering will issue written guidelines to the site prior to L October 1,1989 for the alignment during the winter months of desiccant dryers in each instrument air line routed to the yard.
4) All of the air-operated valves and dampers on Attachment A are verified by test to go to their fail-safe position on a periodic basis with the excep-tion of: 1 & 2 NV-1A, -2A, -122B, and -123B. Valves 2 NV-1A, -2A will be tested during the present refueling outage while valves 1 NV-1A, -2A will-be tested during the next cold shutdown. Valves 1 & 2NV-1A and -2A will be added to the periodic valve inservice testing program. Valves 1 & 2 NV-122B and -123B-do not receive a safety signal and, therefore, are not fail-safe tested.
5) There are no non-safety vendor supplied devices between the air actuators

-and the safety solenoid valves for Catawba's air-operated active valves.

6) The solenoid valves for the Main Feedwater System (CF) Feedwater Bypass Control Valves (1 & 2 CF30, 39, 48, and 57) were found to be non-qualified.

A Station Problem Report (SPR) has been written to initiate replacement with IE qualified solenoids. The replacements are currently scheduled fer the end of each unit's next refueling outage (U1 - 2/11/90; U2 - 7/31/90).

7) Non-safety solenoid valves 1 & 2 SASV0052, which are installed in safety-related tubing runs, have been identified. These solenoids are in the actuator vent paths for the Auxiliary Feedwater Pump Turbine Steam Control Valves. They will be moved to a point-in the tubing outside the . safety vent path. An SPR has been issued to initiate corrective action on this problem. The Unit 2 work was completed on 3/30/89 while the Unit 1 work is currently scheduled for 2/11/90 (end of its next refueling outage).
8) The pilot valves for safety-related dampers 1 & 2 FPX-2A,B through -7A,B were determined to be non-safety. However, because these dampers are required only for the movement of fuel and not to mitigate the consequences of a design basis accident (i.e., they perform a non-safety function), we do not recommend replacing the existing pilot valves with safety grade valves.
9) Catawba's air-operated active valves do not have accumulators which provide a redundant source of air to ensure the valve achieves its failure position.

In summation, Catawba has recognized the need to provide quality instrument air and is taking proper action to ensure these needs are met. To the best of our knowledge, the instrument air system at Catawba is designed in accordance with its intended function. Any design deficiencies have been identified and proper

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corrective action has been/is being taken. Verification by test that air-operated safety-related components will perform as expected has been/will be conducted.

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i ATTACHMENi A pg. 1 of 3 CATAWBA AIR-OPERATED ACTIVE VALVES AND SAFETY-RELATED DAMPERS OPERATOR FAILURE POSITIONS r Valve Tag Failure position 1, 2 CA36 Open 1, 2 CA40 Open 1, 2 CA44 Open 1, 2 CA48 Open.

1, 2 CA52 Open 1, 2 CA56 Open 1, 2 CA60 Open 1, 2 CA64 Open 1, 2 CA149 Closed 1, 2 CA150 Closed 1, 2 CA151 Closed y 1,.2 CA152 Closed 1, 2 CA185 Closed 1, 2 CA186 Closed 1, 2 CA187 Closed 1, 2 CA188 Closed 1, 2 CF28 Closed 1, 2 CF30 Closed 1, 2 CF37 Closed 1, 2 CF39 Closed 1, 2 CF46 Closed ,

1, 2 CF48 Closed  !

1, 2 CF55 Closed 1, 2 CF57 Closed 1, 2 CF87 Closed 1, 2 CF88 Closed '

1, 2 CF89 Closed 1, 2 CF90 Closed 1, 2 KC57A Open 1, 2 KC82B Open 1, 2 NC32B Closed 1, 2 NC34A Closed 1, 2 NC36B Closed 1, 2 ND26 Open 1, 2 ND27 Closed i 1, 2 ND60 Open i 1, 2 ND61 Closed 1, 2 NF228A Closed j 1, 2 NF234A Closed '

1, 2 NVIA Closed 1, 2 NV2A Closed 1, 2 NV10A Closed 1, 2 NV11A Closed

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W' ATTACHMENT A pg. 2 of 3 (cont.)

CATAWBA AIR-OPERATED ACTIVE VALVES AND SAFETY-RELATED DAMPERS OPERATOR FAILURE POSITIONS Valve Tag- Failure Position 1,-2 NV13A' Closed 1, 2 NV122B Closed 1, 2 NV1238- Closed 1, 2 RN291 Open 1, 2 RN351 Open 1, 2 SA2 Open 1, 2 SAS Open

.1, 2 SM1 Closed 1, 2 SM3 Closed 1, 2 SMS Closed 1, 2 SM7 Closed 1, 2 SM9 Closed 1, 2 SM10 Closed 1, 2 SM11 Closed 1, 2 SM12 Closed 1, 2 SV1 Closed 1, 2 SV7 Closed 1, 2 SV13 Closed 1, 2 SV19 Closed 1, 2 VPIB Closed 1, 2 VP2A- Closed 1, 2 VP3B Closed

~1, 2 VP4A Closed 1, 2 VP68 Closed 1, 2 VP7A Closed 1, 2 VP88 Closed 1, 2 VP9A Closed 1, 2 VP10A Closed 1, 2 VP11B Closed 1, 2 VP12A Closed 1, 2 VP13B Closed i 1, 2 VP15A Closed 1, 2 VP16B Closed 1, 2 VP17A Closed 1, 2 VP18B Closed 1, 2 VP19A Closed 1, 2 VP20B Closed Damper Tag Failure Position 1, 2 ABF-D-3 Open 1, 2 ABF-D-5 Closed 1, 2 ABF-D-7 Open I

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l ATTACHMENTS pg. 3 of 3 (cont.)

CATAWBA AIR-OPERATED ACTIVE VALVES AND SAFETY-RELATED DAMPERS OPERATOR FAILURE POSITIONS Damper Tag Failure Position 1, 2 ABF-D-10 Open

.1, 2 ABF-D-12 Closed 1, 2 ABF-D-14 Open 1, 2 ABF-D-17 Open 1, 2 FPX-D-2A,B Open 1, 2 FPX-D-3A,B Open 1, 2 FPX-D-4A,B Closed 1 1, 2 FPX-D-5A,B Open '

1, 2 FPX-D-6A,B Open 1, 2 FPX-D-7A,B Closed SYSTEM KEY CA - Auxiliary Feedwater System CF - Main Feedwater System KC - Component Cooling System ND - Residual Heat Removal System NF - Ice Condenser Refrigeration System NV - Chemical volume and Control System RN - Nuclear Service Water System RV - Containment Ventilation Cooling Water System SA - Main Steam Supply to Auxiliary Equipment SM - Main Steam System -

SV - Main Steam Vent to Atmosphere VP - Containment Purge Ventilation System ABF - Auxiliary Building Ventilation System (VA)

Damper FPX - Fuel Handling Building Ventilation System (VF) Damper

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e Attachment 4 Catawba' Instrument-Air Quality Program

, Instrument air is supplied by three reciprocating and one centrifugal compres-sor. The compressors intakes are in the service building which is free of corrosive contaminants and hazardous gases. Each compressor takes suction i through an inlea filter. Downstrear of each reciprocating compressor, the hot compressed air flows through an aftercooler and water separator before discharg-L ing to a receiver. The aftercooler cools the hot compressed air and the water separator removes any water condensed in the cooling process. Downstream of the E receivers, the instrument air is dried to a dew point of 35 F to 39 F by four refrigerated air dryers. In addition, desiccant dryers are provided on the lines going outside the buildings to dry the air to a dew point of -40 F. After '

the refrigerated dryers, the air passes through coalescing filters which remove oil and particles larger than 3 microns. At each air operated valve or instru-ment, the air is filtered again through a filter-regulator, i

The Instrument Air system is tested for acceptable air quality. Air moisture '

content is tested semi-annually, oil content and foreign particulate are tested annually. Air dew point should not exceed 35 F, oil content should not exceed 1 ppm, and foreign particulate should not exceed 5 microns in size. If any of these limits are exceeded, appropriate corrective actions are taken. In addi-tion to sampling at the dryer outlets (service building), instrument air is also sampled in the turbine building and auxiliary building.

All Instrument Air supply components will be maintained in accordance with their respective manufacturers recommendations and our own maintenance experience by 9/1/89. Also, the filter-regulators associated with critical to operation air-operated valves will be regularly maintained by May 31, 1989.

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l Attachment 5 Compilation of Catawba Action Items

1. Add annual Preventative Maintenance (PM) to reciprocating compressor j maintenance activities by 9/1/89. j j
2. Add 8000 hour0.0926 days <br />2.222 hours <br />0.0132 weeks <br />0.00304 months <br /> overhaul to reciprocating compressor maintenance activities )

by 9/1/89. l i'

3. Aod 3 steps to centrifugal compressor's bi-monthly PM by 9/1/89.
4. Add 4 steps to centrifugal compressor's semi-annual PM by 9/1/89. I
5. Add 2 steps to centrifugal compressor's annual PM by 9/1/89.
6. Add annual PM to refrigerant dryer maintenance activities by 9/1/89.
7. The air-operated valve filter change out periodic PM's on 42 air-operated valves will be written by 5/31/89, and filter change out on Unit 2 complet- j ed by 5/31/89. i
8. Guidelines will be issued for aligning the small desiccant dryers serving outdoor components by 10/1/89.
9. Valves 2NV-1A and 2A will be fail safe tested by the end of the present refueling outage. These valves are also being added to the periodic valve inservice testing program.
10. Valves 1NV-1A and 2A will be fail safe tested during the next Unit 1 cold shutdown. This will be no later than 4/1/90. These valves are also being added to the periodic valve inservice testing program.
11. The non-qualified solenoid valves for 1, 2 CF-30, 39, 48, and 57 will be replaced with 1E qualified solenoids by the end of the each units next refueling outage. Unit 1 - 2/11/90, Unit 2 - 7/31/90.
12. Non-safety solenoid valve SASV0052 will be moved to a point in the tubing outside the safety vent path by the end of the next Unit i refueling outage (2/11/90).
13. SOER 88-1 will be added to the Pressure Measurement Lesson Plan by 7/1/89.

Information will also be added to the Fisher Control Valve Actuator Lesson Plan presently under development.

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