ML031110174

Telefax Transmittal to Ken Riemer/Ken Obrien with Attached Audit Finding Report - Nuclear Quality Assurance

ML031110174
Person / Time
Site:	Point Beach
Issue date:	11/21/2002
From:	Division of Nuclear Materials Safety III
To:	O'Brien K, Kenneth Riemer NRC/RGN-III
References
FOIA/PA-2003-0094
Download: ML031110174 (8)

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PNTED-OM RECYCtED PAPER W

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POWER COMPANY 23i W McNo O. &x WA201 AUDI T FINDING REPORT NUCLEAR QUALT ASSURANCE IAFR 0 A-P-90-12-075 2

IAudit Dates 9/5-10/22/Dc COP'J'LCED 8D1 i1 IIAD__

Scope of Audit Vertical Slice Audit - Aux. Faadwater System I

Reference I Requirenents Au d ignatrr4 Calculation P-87-001 MR 89-127 klSSM 87-13 Finding (Mandatory Response)

NEPB-88-90 Observation VPNPD-89z-O9Q Response Required;

_-YEE 14NO Description Priority 2

See Attached Sheet.

Recoiiiended Corrective Action Sae Attach.ad Sheet.

Responsible for Corrective Action Required Risponse Date Potentially Reportale a o

IJS January 4, 1991 I;

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COPLMI BY AUDITED M5JZAYIODM Corrective Action Perforfed and/or Planned Scheduled Corrective Action Cumpletion Date:

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Form QAt 18.1-4 Rev. I

300 red NUV ;1

'02 14:06 AFR #A-P-9g-12-075 Descrjption:

Electric auxiliary feed ;ump discharge pressure is controlled by air-operated valves AF-4012 (for P-38A) and AF-4019 (for P-38B). These valves are normally closed, and throttle open in response to increasing pump discharge pressure in order to maintain a discharge pressure of 1200 psi.

Two specific concerns were identified regarding the design and qualification of these valves and their controlling instrumentation:

1)

The pressure transmitters, pressure controllers, I/P transducers, and Upositions for these valves are non-seismic and non-QA. Although these valves are designed to fail open upon the loss of power of instrument air pressure, it cannot be concluded that all credible failures will result in opening the valves. Because of the non-qualified nature of the valve-controlling instrumentation, any postulated failure would be in addition to the single failure assumed during an accident analysis.

As determined during the engineering evaluation for MR 89-127 (Train-specific power supplies for PC-4012 and AF-4019 and their associated pressure controllers are both run in the same cable tray.

This exacerbates the Potential for a common mode failure which could incapacitate both electric auxiliary feed pumps.

2)

Various analyses have been done in the past (see references), which have determined that a failure of AF-4012 and AF-4019 in the open direction is acceptable and will not Jeopardize the ability of the auxiliary feed system to perform its safety function.

It is not clear, however, that all applicable factors have been taken into account in these analyses.

During MSSM 87-13, for example, it was noted that if the discharge valve failed open, the pump motor would trip on overload before runout flow occurs. This was dIetermined to be acceptable, as the pumps could be restarted after resetting the overload trip.

The effects of the resulting increase on diesel loading (approximately 80 kw at the maximum long delay overload trip setpolnt) from operating the motor in an overloaded condition were not addressed.

Recommended.Correct I vljti 0::

1)

Assess the acceptability of utilizing unqualified instrumentation to control the electric auxiliary feed pump discharge pressure control valves.

Upgrade this equipment if necessary.

2)

Reassess the acceptability of allowing these valves to fail open upon loss of instrument air pressure. Consider adding a backup to the instrument air supply or providing other compensatory measures, as appropriate.

Provide feedback ot. the results of all analyses as a design input for MR 89-127.

Page 2 of 3

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308 P05 NOU 21 '02 14:06 Correctiv'e action evaluation for APR #A-P-90-12-075

1)

Corrective Action Performed and/or Planned The first concern states that the pressure transmitters, pressure controllers, I/P transducers, and position indicators used to control valves AF-4012 and At-4019 are not currently considered to be seismic or QA qualified.

The concern also states that because of the non-qualified nature of the valve controlling instrumentation, any postulated failure would be in addition to the single failure assumed during an accident analysis.

Obviously, if the non-safoty grade controllers for AP-4012 and AF-4019 failed to the worst position, both valves would remain shut.

Some form for manual override would be necessary to open the valves (i.e. the air supply rust be isolated or stopped and the valves' operators must be vented).

No flow from the electric motor driven pumps would be available during the time that the valves are shut.

Additionally, the pumps could be without recirculation flow because the recsirculation flow control is non-safety grade.

The design of the AFW system for Point Beach should be such that the automa tic actuation of auxiliary feedwater to both units should provide a zinimum flow of 200 gpm to each unit, even after assuming the most restrictive failure of an active safety grade component.

For Point Beach this failure is one of the turbine driven auxiliary feedwater pumps, because they have the highest capacity.,

If the flow control valves from the electric motor driven auxiliary feedwater pumps remain shaut due to failure of their non-safety-grade controllers, then no flow would be available to the unit in which the turbine driven pump is assumed to fail.

.I X have.attempted to determine what would be the capability of the AFW system if this deficiency was corrected.

To mace this determination I performed calculation H-90-095, "Minimum AFW Flow for Actuation to Both Units."

If the controllers for valves AF-4012 and AF-4019 operated as designed, they would control flow from P38A and P38B to be about 200 gpm from each.

In calculation N-90-O95, I showed that if the ateum generator pressures in the unit with the operating turbi:ne driven pump were about 1000 psig and the steam generator pressures in the unit without an operating turbine driven pump were about 1100 psig, the unit without

,~eran operating turbine driven pump would not receive any LFW flow.

This situation could be rapidly corrected by the operators.if they isolated the flow paths from the electric motor driven pumps to the unit with the operating turbine driven pump.

Since operator action would be necessary to initiate flow if the valves function properly, it 2may be possible to argue

ZUd trlUb NUV 21 '02 14:06 thit'cperator action to initiate flow if the valves mialfunotion iz also acceptable.

The main difference being that if the AF-4012 and AF-4019 valves function, the operators could establish flow using valve control Owitches in the control room andif they d6 not function, manual manipulation of the AF-4012 and AF-4019 valves may be necessary.

The manual manipulation may take longer than the repositioning-of valves from the control room,, but in either case operator action is required.

Cause. of Deficien/;

Xnadequate design of the AFW system.

cthior :o Prevent Degurrenee I have generated an NCR due to the inability of the system

'to automatically provide flow as required to meet the assumptions of the FSAR accident analyses. The ultimate corrective action for thio concern will depend on t4a resolution of this NCR.

2)

Corrective Action Performed andid r 2lgnned The second concern essentially st^tea that the of ects of increnzed diesel loading from running the electric 3otor driven ArW puwopau at higher than design flow ?ates has not been addressed in evaluations of runout in the AFW system.

Runout of the electric motor driven auxiliary feedwater pumps was evaluated by A. R.

bones in calculation PtS47-001.

That calculation showed that the flow rate from ne :electric motor driven auxiliary feudwater pump, with the 4isgharge valve failed open, to one team generator variem wifh iiteam generator pressure.

Trcm the r.sults of calciulitiot P 001 it can be seen that tis flow rate. from one epactric motor driven aucillazy feedwater pump to one pta'a venerator varies from 265 gpm at 0S5O.psia to 500 gpm at 390 Ipsia.

Runout of P38A and P382 in at approximately 500 gpm#

The electric motor driven auxiliary feedwater pumps.us. morQ power au flow rate increases.

The results of calcu ation P-87-001 prove thtt flow rates above ZOO gpm are poss a19 from these pumps.

Therefore, I recommend that this issu be referred to S.

F. Mayer for evaluation in thin diesel generator loading calculation.

Cause of Deficiearpl;y This should be dotermined by the diesel loading svaluation.

Act o12 to Preveuit Recurtan This should be determined by the disel loadine ovaliuation.

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aCMION 2 by:S.F.Mayer 2/13/91 The P38A and P3BB auxiliary feedwater pumps have pressure control discharge valves which serve to maintain flow through the pumps at about 200 gpm. The pump motors are 250 BP and appear tp be sized based upon the pump supplying the 200 gpm flow value. The pump discharge valves are non-safety related And a calculation has been done which indicates that if the valves fail open, the pump flow rate will Be about 500 gpm. The pumnp curves indicate that at 200 gpm, the break horsepower will be about 240 HP and at 500 gpm, it will be about 330 HP. A question has been raised as to the effect this load increase has on the diesel loading calculation.

The diesel load calculation used the motor nameplate horsepower rating of 250 HP. Therefore this potential failure could increase loading by so HP over what was assumed in the calculation. This corresponds to 66.3 KW. Note that the original AFR description appears to be incorrect in that it states that the diesel loading would increase by 80 XW.

330 HP corresponds to 273.5 KW or 365.5 amps at 480V and a.9 PF.

The P38A&B supply breakers are 1B52-12C and 2B52-31C. The existing time-overcurrent curves for these breakers indicate that at 365A, the breakers will trip in about 200 seconds. For the most heavily loaded diesel, if the failure occurred at them worst time, the extra 66.3 KW would load the diesel to just over the 200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> rating. Sirce the breaker would trip out on overload in about 3 and 1/2 tinutes this would have very little effect on the static loading of the diesels. I therefore recommend that no change be made to the diesel loading calculation. Note that when a motor is overloaded, the power factor is typically much worse than.9

. This means that the current is probably greater and the breaker will trip faster than indicated above.

Another consideration is what effect this additional load would have on the transient loading of the diesels. On an SI with loss of off-site power, the major safety related loads are sequenced onto the diesels. The: auxiliary feedwater pump is one of these loads. From the information in the component instruction manual, it is my judgement that the diesels would be able' to handle this additional load. We will shortly be performing a transient diesel loading analysis to verify the adequacy of the original design of the load sequencing onto the diesel. We will add to the scope of this analysis the case where the auxiliary feedwater pump is at the heavier load valuae. This should be done by 9/30/91.

Because of the timing on the existing breaker overcurrents, the 66.3 KW load addition is not a significant concern on the static loading of the diesels. However modification MR# 87-034*Hl will replace the existing overcurrents. Care should be taken When establishing the new settingfs for the amtector overcurrents that at 365A the trip will not occur at much greater than 200 seconds.