JAFP-88-0450, Forwards Response to NRC 880411 Request for Addl Info Re IE Bulletin 85-003.Values Inputed Into Calculation for Target Thrust Values & Treated No Differently than Any Other Thrust Requirement

Forwards Response to NRC 880411 Request for Addl Info Re IE Bulletin 85-003.Values Inputed Into Calculation for Target Thrust Values & Treated No Differently than Any Other Thrust Requirement

ML20154D382
Person / Time
Site:	FitzPatrick
Issue date:	05/12/1988
From:	Radford Converse POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
IEB-85-003, IEB-85-3, JAFP-88-0450, JAFP-88-450, NUDOCS 8805190167
Download: ML20154D382 (9)

Text

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Jim:s A. Fit Petrick Nucl; t Powsr Pl;nt Po %= 41 Lycceng. New York 13093 315 342.3840 Radford J. Converse

1. > NewYorkPower 4# Authority May 12, 1988 JAFP 88-0450 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

SUBJECT:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

ON IEB 85-03 ENCLOSURES: (1) Response to Request for Additional Information on IEB 85-03 (8 pages) ,

1

REFERENCE:

(a) NRC letter, Wenzinger to Converse, dated April 11, 1988 The enclosure contains the Authority's response to your Request for Additional Information contained in reference (a). The specific requests have been ir.cluded in the text of the enclosure to essist in evaluating the responses.

DF RD J. Cp V 1 [J RJC:JRL:mac (j ,

cc: DCC NRR Division of Operational Events Assessment United Statee Nuclear Regulatory Commission Region 1 Attn: Edward C. Wenzinger 475 Allendale Road King Of Prussia, PA 19406

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4 8905190167 800512 PDR ADOCK 05000333 4

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1 Pg. 1 of 8 l l

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON IEB 85-03 j NRC REQUEST I

1. "Revise Table 1 of the response dated 05-14-86 to include the following MOVs, or justify their exclusion. According to pages 1 55 and 60 of BWROG Report NEDC-31322 dated September 1986 (for l HPCI and RCIC respectively), these valves have no safety actions  :

however, utilities are expected to report differential pressures for testing, per Note "o" on Page 66 of that report.  !

(a) HPCI MOVs 21 and 24 are shown normally closed in the upper right quadrant of FSAR Figure OP-15-1 Revision 6, and as MOVs 5 and 6 on Page 68 of the BWROG Report.

(b) RCIC MOV 30 is shown normally closed in Zone I-3 of FSAR Figure OP-19-1 Revision 6, and as MOV 5 on Page 72 of the EWROG Report." l l

RESPONSE  !

Table 1 of the 5/14/86 response reflected the design differential pressure for those valves determined by Attachment A of the Authority's response to be within the scope of the Bulletin requirements. Section 3.3.1.2 (page 13) of the Owner's l Group report, NEDC-31322, dated September 1986, provides the  !

rationale for exclusion of the test valves from the Bulletin response.

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For the purpose of the note "o" on page 68, the test methodology for the full flow surveillance pre-opens the valves prior to  ;

turbine start and trips the respective turbine before the valves are given a close signal. The maximum recorded operating pump differential pressures from IST records are 1125 psig (RCIC) and 1140 psig (HPCI). Both test valves have restricting orifices upstream that reduce the differential pressure the test valves would experience during situations with significant flow to the Condensate Storage Tanks. Since these valves are not within the scope of IEB 85-03 as established in Section 3.3.1.2 of NEDC-31322, revision of Table 1 is not required.

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Page 2 of 8 NRC REQUEST l

2. "Revise Table 1 of the response dated 05-14-86 to include the following MOVs, or justify their exclusion. According to pages 58 and 62 of the BWROG Report (for HPCI and RCIC respectively),

each of these valves has a safety action for closing.

(a) HPCI MOV 59 is shown normally open in Zone B-6 of FSAR Figure OP-15-1 Revision 6, and as MOV VII on Page 71 of the BWROG Report.

(b) RCIC MOV 130 is shown normally open in Zone F-6 of FSAR Figure OP-19-1 Revision 6, and as MOV VII on Page 74 of the BWROG Report."

RESPONSE

The JAFNPP Technical Specifications and FSAR establish the containment isolation boundary with the respective upstream HPCI and RCIC turbine exhaust check valves. These positions were established during the initial modification installing the vacuum breaker capability and confirmed by the Technical Specifications and FSAR. The Authority recently created a computerited Master Equipment List which provides a single, concise and unambiguous source for the identification of safety-related components. Generation of the Master Equipment List included component classification and the valve operator on these valves was designated class II/III - non-safety-related.

Other than serving as a pressure and maintenance boundary, these valves arovide no active safetv-related function. For JAF these valves have no active safety f'nction u and no revision to Table 1 is required.

While investigating the status of these remote manual isolation valves, an inconsistency was discovered in the November 15, 1985 submittal for the ASME Section XI Second Interval Inservice Test Program per 10CFR50.55a(g). Although the discussions at that time reflected the position stated above, the two valves were i unintentionally left in the submitted program package. A change will be submitted so that the Second Interval Program accurately reflects the status of these valves as having no active safety function.

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Page 3 of 8-NRC REQUEST l

3. "Revise Table 1 of the response dated 05-14-86 to include a value of differential pressure for closing Steam Admission Valve-

MOV-132 (sic), or-justify exclusion of that pressure. 'According

to Page 61. of the BWROG Rep' ort , this valve.has safety actions. i for opening and closing. N/A" is the~present entry for. closing l this valve." a t

RESPONSE

The steam admission valve for RCIC is 13MOV-131. .

l RCIC is not a safety-related system at FitzPatrick'except for l the primary containment isolation valves and steam leak

.' detection components. The commitment in the 5/14/86 Authority response was to include "those RCIC valves which provide -

functions comparable to HPCI valves which are within the scope ,

of the Bulletin." Since neither the HPCI steam admission valve l nor the original designed RCIC steam admission valve had any i safety-related closure function, the closed direction was-not included in Table 1 in the original response.  ;

A design modification to the 13MOV-131 logic resulting from NUREG 0737 actions, produced a High Reactor Vessel Water level closure signal. This closure would occur against the BWROG's maximum pressure of 1090 psig. An identical upstream valve *

(13MOV-16) demonstrated successful closure against this line  :

pressure during plant hydrostatic testing.  :

1 A revised Table 1 has been included in this response to reflect [

this requested change and the 13MOV-131 data sheet from the  ;

i 1/15/88 response has been revised to take credit for the type '

testing performed with 13MOV-16,  ;

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NRC REQUEST l.

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4. "According to the response of 01-15-88, MOVATs has been included  ;

! in the MOV testing program. If MOVATS is planned for  ;

application to some MOVs which are not included in its data  ;

base, commit to and describe an alternate method for determining

i the extra thrust necessary to overcome pressure differentials ,

i for these valves." ,

d RESPONSE t

No credit was taken for the data from the MOVATs data base of [

required thrust as a function of differential pressure for  !

! various valve manufacturers and sizes. l i

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

Page 4 of 8 In each case where MOVATs testing was cited in lieu of a hydrostatic test, the signature analysis was used to verify that the actuator could produce a pre-calculated target thrust. In all cases the thrust calculations had been verified by a differential pressure test in the open direction on the same valve.

The method used involved maximum differential pressures calculated using the GE BWROG's report methodology for target chrust calculations verified by on-site hydrostatic tests. This combination resulted in valve-specific target thrusts. The MOVATs signature analysis equipment was used to demonstrate that torque switch trip on closure provided adequate thrust relative to the target thrust ranges.

NRC REQUEST

5. "The proposed program for action items b, c and d of the bulletin is incomplete. Provide the following details as a minimum:

(a) commitment to a training pro ram for setting switches and maintaining valve operators ,g'

RESPONSE

All electrical personnel that work on Limitorque actuators have had training in the setting of actuator switches and maintaining valve actuators. The FitzPatrick Training module for electricians, who perform all Limitorque switch settings and electrical valve operator maintenance, received INPO accreditation in December, 1987. The curriculum includes sixteen hours of theory and operations and sixteen hours of lab work including equipment disassembly / reassembly and training in plant procedures.

The qualification standards include additional practical factors that require the demonstration of these skills.

Additionally, electricians directly involved in the acquisition of MOVATs signature analysis traces have received u) to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of instruction that included actuator theory and setup in addition to vendor equipment instruction. Additional training has been scheduled before the 1988 Refueling Outage to familiarize electrical maintenance personnel with the new motor control center signature acquisition.

Page 5 of 8 (b) "commitment to justify continued operation of a valve determined to be inoperable,"

RESPONSE

The requirements of JAF Technical Specifications and the ASME Boiler and Pressure Vessel Code Section XI are the determining criteria for motor operator valve operability.

Accordingly, operability or continued operation decisions will be based on this criteria.

Many IEB 85-03 Bulletin programs, especially those prepared for utilities by the leading signature analysis equipment vendor, rely heavily on "motor load unit" measurements for long-term valve monitoring. All but two of the FitzPatrick valves within this bulletin scope are DC. No equipment has been available until recently to perform these measurements on DC actuators. The Authority has submitted one of the first orders for this newly offered equipment and have had personnel at the vendor this month participating in procedural development. An active aarticipation in this development process will continue, but the Authority can make no specific program commitments without site evaluation of the product. This evaluation is expected to occur during the 1988 Refueling Outage (fall).

Presently available signature analysis. equipment provides exceptional diagnostic capabilities during actuator set-up and trouble shooting but cannot provide, of itself, practical operability criteria. Signature analysis equipment will be used to supplement existing criteria '

during operability considerations but at present is unsuitable for determining operability. An existing Plant Standing Order contains a maintenance post-work testing matrix that requires various levels of MOVATs equipment as a function of the complexity of the maintenance task completed.

(c) "description of a method possibly needed to extrapolate valve stem thrust determined b less than maximum differential pressure,"y testing at

RESPONSE

In addition to the one-time operation with maximum i differential pressure for those valves which could be ,

tested in that mode, numerous signature tests capable of l measuring either required (pressure test) or available I (static tests) thrust were performed. Many tests against l differential or line pressure ware conducted with signature l analysis equipment attached. These tests provided required  !

thrust values for the imposed presures. Similarly l instrumented valvos in functionally identical applications provided available thrust measurements from signature analysis. In this manner, an inboard steam line isolation i valve could be type tested using the (isolable) outboard l valve's pressure test results as criteria, i l

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Page 6 of 8 (d) "justification of a possible alternative tc testins u; maximum differential pressure at the plant, and"

RESPONSE

The calculations performed to establish target thrust values for various differential pressures were proven conservative in all but one case. That one case apptars to be a valve stem lubrication problem requiring actuator disassembly which will be addressed before the end of the 1988 Refueling Outage. Since the calculations have proven valid through the maximum differential pressures, reduced differential pressure tests can be utilized to benchmark thrusts necessary for a given valve and the results extrapolated to obtain target thrusts for the higher pressure.

. (e) "consideration of pipe break conditions as required by the bulletin."

RESPONSE

The bulletin requires pipe break consideration only to the extent that such valve operation is relied upon in the design basis. The only valves in this category are the HPCI and RCIC steam supply containment isolation valves.

These five valves (for FitzPatrick) all had a line break assumption in the maximum differential pressure evaluation as provided by the NSSS supplier in the BWROG report. Once the maximum differential pressures were obtained. the values were inputed into the calculation for target thrust values and treated no differently than any other thrust requirement.

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Page 7 of g AITAONENT B UJIIE 1 DESIGN BASIS DIFFERENTIAL PRESSURES DESIGN tDRMAL DIFFERD7 RIAL PRESSURES JAF ID DESCRIPTION POSITION OPEN PSID SHUR PSID RCIC System 13 FDV-15 Containment Inboard Steam OPEN 1250(2) 1250(2)

Supply 13 FDV-16 Contaiment Outboard Steam OPEN 1250(2) 1250(2)

Supply 13 FDV-18 Pucp Suction Fran CST OPEN 50 50 13 FDV-20 Pump Discharge Outboard OPEN 1320(3) N/A Isolation 13 FDV-21 Pump Inboard Discharge to CIDSED 1320(3) 1320(3)

Reactor 13 FDV-27 Mininun Flow to Suppression C WSED 1500 1500 Pool 13 FDV-39 Pump Suction Fran Suppression CWSED 50 50 Pool l

13 FDV 41 Puap Suction Fran Suppression CWSED 50 50 Pool 13 FDV-131 Turbine Steam Inlet CWSED 1250(2) 1250(2)

, 13 FDV-132 Cooling Water Isolation CWSED 1320(3) N/A HPCI Systen 23 FDV-14 Turbine Steam Inlet CWSED 1250(2) N/A 23 FDV-15 Containment Inboard Steam OPEN 1250(2) 1250(2)

Supply 23 FDV-16 Contaiment outboard Steam CWSED 1250(1) 1250(2)

Supply 23 FDV-17 Pump Suction Fran CST OPEN 50 50 23 FDV-19 Pump Inboard Discharge . CLOSED 1320(3) 1320(3)

Reactor Page 2 of 3 Revision 1 - 5/88

Pags 8 of 8 COMPONENT I.D.: 13 MOV 131 FUNCTION: RCIC Turbine Steam Admission MANUFACTURER: VELAN SIZE - TYPE: 3" Gate MODEL: Pressure Seal B10-7054P-02TS RATING: 900 f Class LIMITORQUE SMB - 00-10 MOTOR RPM: 1900 OUTPUT RPM: 59.6 DIFFERENTIAL PRESSURES:

ORIGINAL DESIGN BASIS RECALCULATED DESIGN BASIS TEST-OPEN/CLOSE OPEN/CLOSE OPEN/CLOSE 1250/1250 1090/1090 1100/ -

ORIGINAL SWITCH SETTINGS POST BULLETIN SWITCH SETTINGS OPEN/CIOSE OPEN/CLOSE

) 2/2 1.5/1.5 AS FOUND VALVE OPERABILITY Operable in the "as found" condition. The valve was exhibiting higher than expected thrust levels which were more than adequate to ensure operation. The torque switch settings were reduced to provide margin to the actuator maximum continuous thrust ratings f while still providing sufficient thrust for reliable operation, j TEST METHOD DESCRIPTION / JUSTIFICATION j This valve was opened against an 1100 psid.

Type testing of 13MOV-16 demonstrated the closure ability of this valve / actuator combination.

Revision 1 - 5/88