ML17199Z360
| ML17199Z360 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, LaSalle, 05000000 |
| Issue date: | 06/03/1988 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 4752K-2, IEB-85-003, IEB-85-3, NUDOCS 8806100137 | |
| Download: ML17199Z360 (15) | |
Text
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Commonwealth Edison One First National Plaza. Chicago, Illinois Address Reply to: Post Ott1ce Box 767.
. Chicago, Illinois 60690
- 0767 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk,
- Washington, D.C.
20555 June 3, 1988
~ubject: Dresden Station Units 2 and 3 Quad Cities station Units 1 a.nd 2 LaSall~ County Statiort Units 1 and 2 Response to NRC Bulletin No. 85-03, Supplement 1 Docket Nos. 50-237/249; 50-254/265, 50-373/374
Dear Sir:
Reference:
(a) NRG Bulletin 85-03 supplement l, Dated April 21; 1988 The above. referenced NRC Bulletin requested that holders of 6perating licenses or.constructio~ permits for boiling ~ater reactors with safety-related motor-operated valves in selected high pressure systems not included in the actions plann~d or completed in response to the original Bulletin, develop and implement* a program to ensure that valve operator
.switches are selected, set, and maintained properly; commonweal th Edison has completed its review pursuant to the..
request outlined in NRC Bulletin 85-03 supplement 1 for Dr_esden, *Quad Cities and LaSalle County 5tations~ *This informatiori is ~ttached in Enclosures 1~3.
To the best of my knowledge and belief, the statements contained above are-true and correct.
In some respect these statements are not based on my personal knowledge, b~t obtained informati6n furnished by other CorrunonwealthEdison. employees, contractor employees, and consultants.. Such information has been reviewed in. accordance with company practice, and I believe it to be r~liable.
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USNRC June 3, 1988 Please address any questions that you or yo~r staff may have concerriing thi~ response to this office.
rf AttacM.ents
.cc: A.B. Davis Resident Inspectors - D/QC/LSC subsc : bed and swa:;n to
- beforie mE-this 3 -
day of
, 1988 4752K Respectfully, L~o.,v-w [
k~~v_,.,
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W. E. l.horgan Nuclear Licensing Administrator
. ATTACHMENT l Dresden Station Response to NRCBulletin 85=-03, Sup?lement 1 Supplement 1 to !EB 85~03 ~equires that the scope of t~e original bulletin be ~xtended to ~11 safety relat~d valves in the selected systems
.and that inadvertent mispositionings be included in determining the maximum de~ign basis differentiai pressures for each valve.
Dresden Station has alre~dy addressed the requirements of supplement 1 in the above referenced letter.
During the current Unit 3 refueling outage, four additional Unit 3 HPCI valves and five Isolation Condenser.valves will 'be tested using MOVATS.
The corresponding Unit 2 valves will be si~ilarly tested during ihe upcoming Unit 2 refu~ling outage
.scheduled to begin in September, 1988.
Inadvertent mispositioning was
- considered in.determining the maximum differential pressures provided in the referenced letter.
Completio~ of Bulleiin items b through d for these additional valves is schedul~d for the end of the Unit 2 refueling outage scheduled to begin in September, 1988...
4752K-2
ATTACHMENT 2 Quad Cities Station Response to NRC Bulletin 85-03 supplement 1 **
The following four safety related High Pressure Coolant Injection... ystem and two safety related Reactor Core Isolation Cooling System valves were added to the original s~~pe of the Bulletin based on the Supplement:
1-1301-25
~1-2301-48 1-2301-49 2-1301-25 2-i3ol-48 2-2301-49 These additional val_ves are scheduled to be diagriostically tested during
- the next Unit 1 and Unit 2 refuel outages scheduled to begin in June and OCtober, 1989 respectively.
The differential pressures that the 1(2)-2301-8, 1(2)-2301~9, 1(2)-2301-10, and 1(2)-2301-14 ~alves must operate against due to inadvertent valve misposltioning are now 1225 psig instead of the corresponding pressures listed in the IE 85-03 Bulletin response dated January 15, 1988.
With.the exception of the 1-2301-9 motor. operated valve, all valves diagnostically tested within the original scope of the Bulletin have thrusts great enough to overcome.*
differential pressure~ in the open and closed dire~tion. The 1~2301-9 valve did not meet the conservative minimum desired target thrusts using.the original differential pressure criteria of 1150 psi.
Two stems were bent attempting to provide a conservativ' operability margin.
In on-site review 87-49, the function of the valve was reviewed.. The valve is normally open and remains open during HPCI initiation.
The valve doesfunction normally at 0
~si thr~~t requirements as specified by Sargent & Lundy Project No.
8189~00.
Station and BWR Engineering agreed to set torque switch settings to original as-found values.
The 1-2301-9 valve will *be diagnostically *tested during the next Unit 1 refuel outage scheduled to begin in June 1989.
This valve will meet the OEM Is minimum. target thrusts required for misalignment consideration prior to the Unit 1 star~up.scheduled for September, 1989.
SUPPLEMENT I ACTION ITEM A Review and document the design basis for the operation of each valve.
This documentation should include the maximum differential pressure expected during both opening and closing of the valve for both normal and abnormal events to the extent that the events are.included in the existing, approved.
design basis (Le., the design basis documented in pertinent licensee submit ta ls such as FSAR analyses and fully approved operating and emergency*.
procedures, etc.}.
In addition, when determining the maximum differential pressure for valves that can be inadvertently mispositioned, the fa.ct that the valve must be able to r*ecover from such mispositioning should. be included.
RESPONSE
- The maximum differential pressure values for Quad Cities MOVs that are
- within the original Bulletin scope and the fiist supplement of the Bulletin are shown in attachment A.
Inadvertent equipment operations within the plant design basis conditions were considered in development of the design basis conditions for each valve.
There were six valves added to the origi~al Bulletin scope due to the Bulletin supplement.
The.*1(2)-2301-48 and 1(2)-2301-49 motor operated valves are classified safety related in the*
HPCI (High Pressure Coolant Injection) system arid the 1(2)-1301-25 motor operated valves are classified safety related in.the ~CIC (Reactor.core*
Isolation Cooling) system, therefore, added to the scope of the Bulletin.
Inadvertent misposltioning considetations of the Bulletin.valves have changed the differential pressure requirements of the 1(2)-2301-8, 1(2)-2301-9, 1(2)-2301~10, and 1(2)-2301-14 motor operated valves~ The differential.pressure requirement for the eight valves is 1225 PSI in the open and closed direction.
The 1(2)-2301-8, 2-2301-9, 1(2)-2301-10 and the.
1(2)-2301-14 valves currently have thrusts that exceed their differential pressure requirements in the open and closed direction.
The 1-2301-9 valve did not meet the conservative minimum desired target thrusts using the original differential pressure criteria of ll50 psi.. Two stems were ben_t attempting to provide a conservative operability margin.
In on-site review 87-49, the function of the valve was reviewed.
The valve is normally open and remains open during ~er initiation.
The valve does function normally*
at 0 psi thrust.requirements as specified by Sargent & Lundy Project No.
8189..:.oo.
Station and. BWR Engineering agreed to set torque switch settings to original as-fourid values.
An AIR (14-88-003) has been lssued to BwR.
En~ineering. to track fin~l valve disposition.
The valve was considered operable because its normal position is its safety position and the valve
-could be stroked under static conditions.
However, the valve has a high level of operability confidence even if the valve is inadvertently closed.
because the open torque switch is bypassed approximately 26\\ full stroke in the open direction.
- By bypassing the open torque switch 26\\, there will be a large decrease in differential* pressure that the torque switch would actually operate against because of the initial flow through the pipe before the torque switch is in the control circuit~ The 1-2301-9 valve will be diagnostically tested during the next Unit 1 *refuel outage scheduled to begin in June 1989.
This valve will meet the OEM's minimum target thrusts prior to the Unit 1 startup scheduled for September, 1989.
With the ex~eption of the l-~301-9, 1(2)-1361~25, 1(2)~2301~48 a~d the
. 1(2)-i301-49 valves, all other IE 85-03 Bulletin valves have tested thrust values greater than.that needed to overcome inadvertent misaligrunents.
SUPPLEMENT I ACTION ITEM B Perform action item B of the original bulletin for any additional valves identified above.
The intent is to provide assurance that a program exists for selecting and setting valve operator switches to ensure a high reliability of safety system valves.
If changing the switch settings is not sufficient to ensure the capability for repositioning a particular mispositioned valve, a justification for continued operation should be provided in the bulletin "response if the licensee does not elect to implement additional actions, such as administrative or procedural controls or equipment modifications, to minimize the likelihood of valve malfunction.
RESPONSE
This phase of the program establishes torque and limit switch setpoints.
The.technical basis for many of these setpoints have been obtained from.
MOVATS Incorporated.
Diagnostic testing has utilized test results from many plants to establish and justify several alternate policies for torque,
~orque bypass, and limit switch setpoint adjustments.
Using MOVATS and 'other recommendations, a s~tpoint p'alicy for the 85-03
- Bulletin valves was established..Diagnostic testing techn~ques will be
~sed on the ~ix additional valve~ added t6 the s~ope of th~ Bulletin to determine the "as-found" condition of the motor operated yalves and the existing switch setpoints.
The Bas-found" and "as-left" conditions of the 1(2)-2301-8,.1(2)-2301-9, 1C2r-2301-10, and the 1(2)-2301-14 valves, the eight valves that the differential pressure requirements changed due to the supplement, are.listed in Table l.
SUPPLEMENT*! ACTION ITEM C Perform action item C of the original bulletin for any additional valves.
identified above.
RESPONSE
This phase of the program began with the actual adjustment of the switches for the original scope of the Bulletin using the established policies.
To
- .facilitate measurement of parameters such as percent vaive travel, thrust values at torque switch.trip (needed in setting the switches), and. to facilitate testing to prove operability, the MOVATS Signature. Analysis Process was utilized.
Information regarding the operation and principles
- of MOVATS may be found in the American Society of _Mechanical Engineers paper 84-NE-16 "Early diagnosis of Motor operated Valve*Mechanical and Electrical Degradations", 12th Inter-Ram Conference for. the Electric Power Industry report entitled "Update on Field Signature Testing of Motor Operated Valve Mechantcal and Electrical Degrad~tions".
Utilizin~ the control switch signature discussed above for the valves in the original scope of the~ulletin~ the limit switch setpoints previou~ly deter~ined were set and verified to be withih the correct percent of valve travel by indication of act~al switch trip ~etpoint in milliseconds of valve travel.
{The addiiion t6 the Bulletin ot the 1(2}*1301-25,.
1(2)-2301-48 and 1(2)-2301~49 valves by the supplement will require initial testing which will be performed during* the next Unit l and Unit 2 refuel outage scheduled to begin June and October, 1989 respectively.
The final aspect considered is a demonstration that the valves will function properly U!'1der the maximum differential pressures expected on the
. valves during both normal and abnormal events within the design basis.
To date, Quad Cities has utilized a.test method {developed by MOVATS) that verifies the valves will function against differential pressure.
This method divides the total thrust encountered during valve operation into two_
parts:* thrust resulting from differential pressure,.and th.rust resulting from the valve itself (Le.; packing loads, friction, gear efficiency, etc.}.* *.The thrust resulting from the valve itself is easily observed during MOVATS testing~ The thrust resulting from differential pressure alo~e is then caiculated and added to the measured valve running thrust to determine the total required thrust.. Finally the thrust value at torque switcb trip is adjusted to a value 9reater.than the total required thrust -
ensuring that each valve will operate under maximum differential pressure conditions.
The thrust values calculated for MOV operation at maximum expected differential pressures are based 6n the. itandard vendor formula for wedge gate and globe valves.
{a) Thrust. = {Diff. pressure x seat a~ea x valve factor) + {stem area x line piessure) + stuffing box load.
- With the exception of the 1-2301-9.motor operated valve, all valves diagnostically tested within the original scope of the Bulletin have
- thrusts large enough to overcome differential pressures in the open and clos.ed direction.
The 1-2301-9 valve did not meet the conservative* minimum desired target thrusts using the original differential pressure criteria of ll50 psi.
Two stems were bent attempting to provide a conservative operability margin.
In on-site review 87-49, the function of the valve was reviewed.
The valve is normally open and remains open during HPCI initiation. The.valve does function normally at 0 psi thrust requirements as specified by Sargent & Lundy Project No. 8189"."'.0Q.
Station and.BWR
- . Engineering agreed to set torque switch settings to original as-found values.
An AIR {14-88-003) has been issued to BWR Engineering to track final valve disposition. *The 1-2301-9 valve will *be diagnostically tested during the next Unit l refuel outage scheduled to begin in June 1989.
This valve will meet the OEM's l!linimum target thrusts required for misalignment consideration prior to the Unit l startup scheduled for September, 1989.
(See Table l for as-found and as-left valves~)
The total requir-ed thrust for the Bullet in valves have been. computed and verified to be less than the maximum allowable loading condition specified by-the actuator* and valve supplier.
During the next Unit 1 and Unit 2 refuel outages scheduled to begin June and October, 1988, the 1(2)-1301-25, 1(2)-2301-48, 1(2)-2301-49 and the 1-2361-9 valves will be diagnostically tes~ed and verified to have ~hrusts greater than required to overcome the differential pressures that the valves must operate against in the opening and the closing direction.
SUPPLEMENT I ACTION ITEM D Perform action item D of the original bulletin for any additional valves identified ab6ve~
RESPONSE
The Station intends to develop preventive maintenance procedures by Decemb~r, 1988, to periodically perform testing to ensure the switch settings are being maintained.
This testing will verify that the valves are still capable of overcoming accident differential*pressures to perform their functions.* Periodic testing will consist of the following:
a)
Limit and torque switch settings are. to be ver:ified set correctly after any maintenance which could affect limit and/or torque switch settings*
and on a periodic basis not to exceed two refuel cycles.
b)
Signature traces are.to be obtained.
The signature verifies valve motor current as well as proper coordination between limit.and.torque switches.
ATTACHMENT Ji. (UNIT 1)
MI~:ALIGNMENT LIMITORQUE CON:HOEHATlON VALVE EPN SYSTEM
- FUNCTION DESCRIPTION TYPE SIZE OPERATOR*
DP~ esi2 1-1301-16 RCIC Turbine Steam Supply.
Gate 3"
SMB-000-*5 1135 Inboard Isolation 1-1301-17 RCIC Turbine s.team supply Gate 3"
SMB-00--7.5 1135 Outboard Isolation 1...:1301-25 RCIC suppression Pool Gate.
6" SMB-000-5 44 suction 1-2301-3 HPCI Turbine Steam supply
.Gate 10" SMB-3-100 1135 Isolation 1-2301-4 HPCI Turbine Steam supply Gate 10" SMB-* l-60 1135 Inboard Isolat.ion 1-2301.,..5
. HPCI Turbine Steam Supply Gate 10" SMB-1-:-40 1135 outboard *1solat ion 1-2301-6 HPCI Pump suction Isolation Gate 16" SMB-0-25 30 from Condensate Storage Tank.
1-2301-8 HPCI Vessel Injection Gate 14" SMB-4T-200.
1.225' Isolation 1-2301-9 HPCi Pump Discharge* Injec-Gate 14..
SMB-4T-200 1225 ti on Line* Isolation 1-2301-10 HPCI Pump Discharge to Globe 6"
SMB:...2-40 1225 Condensate Stge Tank (Test Line) 13~8H
1-2301-14 HPCI Pump Minimum Flow Globe 4"
SMB-0-40..
1225 1-2301-35 HPCI Pump suction.Isolation
- Gate*
16" SMB-0-25 44 from Suppres~ion Pool 1-2301-36 HPCI Pump suction Isolation Gate 16" SMB-0-25 *
'.l..
44 f r6m Suppression Pool 1-2301-48 HPCI Gland Seal and Lube Oil Gate*
4" SMB-000.-5 80 cooling Water Return Valve 1-2301-49 HPCI Gland Seal and Lube Oil Gate 4"
SMB-00-15 80 Cooling Water Return Valve to CCST
ATTACHMENT A (UNIT 2).
MISALIGNMENT LIMITORQUE CONSIDERATION VALVE EPN SYSTEM FUNCTION DESCRIPTION.
TYPE SIZE..
OPERATOR DP(psi).
2-1301-16
.RCIC Turbine.steam Supply Gate 3"
SMB-000-5 1135 Inboard Isolation 2-:1301-11 RCIC Turbine steam Supply Gate
. 3"'
SHB-00-1.5 1135 outboard Isolation 2-1301-25 RCIC Suppression Pool Gate 6i*
SHB-000-5 44 suction 2-2301-3 HPCI Turbine steam Supply Gate 10" SMB-3-100 1135..
Isolation 2-2301-4 HPCI Turbine* Steam supply Gate 10u SMB~l-60
. 1135 Inboard ~solation 2-2301-5
'HPCI Turbine Steam.Supply Gate.
- 10"
.SHB:-1-40 1135*
outboard Isolation 2-2301-6 HPCI Pump suction Isolation Gate 16" SMB;...0-25 30..
from Condensate Storage *Tank.
. 2-2301-8.
HPCI Vessel Injection Gate
.14" SHB-4T-200 1225.
Isolation 2-2301-9 HPCI Pump Discharge Injec-Gat,e
. 14."
SMB-4T-200 1225 ti on Line Isolation 2...:2301-10 HPCI
- pump Discharge to Globe..
6" SHB-2-40 1225.
Co~densate Stge Tank (Test Line)
I l358H
,:t
2-2301-14 HPCI Pump Minimum Flow Globe 4"*'
SMB-0-40 1225 2-2301-35 HPCI Pump Suction Isolation Gate 16" SMB-0-25 44 from suppression Po0l 2-2301-36
SMB-000-5 80' Cooling,Water Return Valve 2-2301-49 HPCI Gland Seal and Lube Oil Gate 4*11 SMB-00-15 80 Cooling Water Return Valve to CCST 135~H
TABLE I.
I OEM DESIGN I
I THRUST FOR As*
F 0 UN 0 I
A S L E F T A S F 0 U N D I MISALIGNMENT.
THRUST OPEN/ I TORQUE SWITCH OPEN/
I THRUST OPEN/ I TORQUE SWl,TCH OPEN/
VALVE I CONS IDERA Tl ON THRUST CLOSE I TORQUE SWITCH CLOSED I THRUST CLOSE I TORQUE SWITCH.CLOSED AS PER BULLETIN REQUIREMENTS 1-2301-8 46735
- N/A/49235 2.0/1.0 N/A/74600 2.25/1.25 OPERABLE l-2IDl-9 46735 N/A/19868.
2.0/1.0 N/A/N/A2 2.0/1.0 OPERABLE I 1-2IDl-IO 35155 80400/59800 2.0/1.25 54800/65600 1.0/1.4 QPERABLE 1-2IDl-14 17158 25400/24180 2.25/2.5 20960/21000 2.0/2.0 OPERABLE 2-'"2IDl-8 46735 N/A/36815 2.0/1.5
.N/A/78953 4.0/3.0 INOPERABLE}
2-=2301-9 46735 N/A/105465 1.0/1.0 NiA/106391.
2.0/1.0 OPERABLE 2-2IDl-10 35155 98794/56440 2.5/1.0 62265/64898
- 1.25/1.25 OPERABLE 2-2IDl-14 17158 6}049/25856
- 2.25/2.25
. 19040/20640 1.2/1.0 OPERABLE The "as-fQund" condition of the valve can be considered operable If inadvertent valve mlsallgrvnent ls not taken Into consideration. The safety function of the valve Is In the open direction which is Its normal position._ If the valve were inadvertently closed the va*lve would have operated with a high degree of con~ldence due to the open torque switch being bypassed past valve unseating.
2 The 1,..2301-9 valve did not meet the cottservatlve minimum desired target thrusts using the differential pressure criteria of 1150 psi.
Two stems were bent atteq>t.ing to provide th'fs* conservative operabl I lty margin.
In on-site review 87-49, the function of the valve was reviewed.
The valve is nonnaliy q,en and remains op,n during HPCI Initiation. The valve does function normally at 0 psi thrust requirements as specified by Sargent & Lundy Project No~ 8189-00: *.. $:tatlon and BWR Engineering agreed to set torque switch settings to ~rlglnal as-found values.
An AIR (14-88-003) has been Issued to BWR Engineering to track final valve disposition *. The 1-2IDl-9 valve w,111 be dlagnostlcal ly tested during the next Unit I refuel outage scheduled to begin In iune. 1989.
This valve wl 11 meet the OEM's minimum target thrusts in the open and closed
- direction* prior to the Unit I startup scheduled for September, 1989.
The safety function of the valve Is In the.open position which Is Its normal position.
If fhe valve Is Inadvertently closed.the va.lve would open.with a high degree of.confidence due to the fact that the open torque switch is bypassed approximately 26S of full stroke.
3 The 2-2301-8 valve Is normally CLOSED as per nonna.I I ine-up.
1358H/0389Z 1358H
~
).(.*
~),'
ATTACHMENT 3 LaSalle County Station Response to NRC Bulletin 85-03 Supplement 1 Lasaile county Station has reviewed ~he application of safety related valves in the HPCS and RCIC systems.
It,has been determined that all safety related valves in these systems have been subject to the requirements of IEB 85-03 with the exception of the following test valves:
E22-F010 HPCS Full FLOW Test Upstream Stop to Cyc1ed condensate Storage
- Tank E22-F011 HPCS Full FLOW Test Downstream Stop to-Cycled Condensate Storage Tank E22-F023 HPCS Full flow Test Stop.to suppression Chamber E51-F022 RCIC Full FLOW Test to Condensate Storage Tank Upst*ream Stop E51-F059 RC!C Full Flow Test to Condensate Storage Tank I>Ownstream Stop LaSalle county ~tation has performed a review of the design basis for operation of thesevalves.
The maximum differential pressure for the test valves are listed in the table below.
Also LaSalle County Station has reviewed similar valves from the BWR OWners Group.
The design pressures listed are more conservative than the pressures calculated froin the BWR Clwners
- Group.
- Valve E22-F010 E22-F011 E22-F023 E51-F022
- E51-F059 Design Pressure 1500 psi-1500 psi 1500 psi 1500 psi 1600 psi A review has been performed on the* operation of each valve and the impact on the valve's ability to perform its *safety function.
A swrunary is provided in the following paragraphs:
E22-F010 and E22-F011..,. These valves provide the isolations*of the HPCS Pump discharge piping from the condensate Storage Tank (CST)."
LaSalle Station does not presently use the CST as a source of water for the HPCS system due to the inoperability of the suction line from the CST to HPCS.
The unavailability of the HPCS Suction line from the CST has been addressed in applicable operating procedure~ and the E22-F010 and FOll valves have been taken out of service electrically to prevent inadvertent operation.
Therefore, no potential for inadvertent operations exists.
E22-F023 - This valve provides the_ isolat~on of the HPCS pump discharge piping from the suppression Chamber.
The valve is closed at all times during unit operation except when HPCS is being run in the Full Fl~ Test Mode.* The valve*
is verified as being closed as part of LOS-HP-Ml, HIGH CORE CORE SPRAY SYSTEM OPERABILITY TEST, and has an interlock.which returns the valve to the closed*
position upon a HPCS *initiation of low reactor level or high drywell pressure.
The ability of the valve to close under flow is verified during LOS-HP-Ql; HPCS SYSTEM INSERVICE TEST WHEN CY LINES ARE ISOLATED~
E51-F022 and E51-F059 - These valves provide the isolations of the RCIC system from the CST.
The valve_s are closed at all times during unit operation except when RCIC is being run in the Full Flow test Mode.
The valves are verified*
closed as part of LOS-RI-Ml REACTOR CORE ISOLATION COOLING SYSTEM INSERVICE TEST IN CONDITIONS.!, 2, & 3_and have an interlock which closes the valves.
, upon a signal that the E51-F031, RCIC. suction From Suppression Chamber Stop, is open.
Additionally, the E51-F059 has an interlock* which closes the valve on receipt of a low reactor water level signal.
Therefore, the potential for*
inadvertent positioning is eliminated both by procedural controls and electrical interlocks. controls are ~lso in place to assure the valves ci6se tightly and provide sufficient iso.lation of the RCIC system from the CY tank.
Inadvertent operation of one valv~ will not prevent system operation since the other valve would remain closed.
Therefore, controls are in place to prevent inadvertent operation and mispositioning of all valv~s which are cla~sified as safety telated in the RCIC and HPCS systems~ These valves are maintained in their safety position
- during _nbrmal plant operations and have been proven c~pable of performing th.eir safety function.when the safety system is required to actuate..
The following paragraph provides *the Stati~ns position for item b, c and d of the original IEB 85-03 as it applies ~o the valves lisied in this supplemental response.
Control of switch settings and thermal overload sizing for these valves is performed in the same manner as the valves covered in the original IEB 85-03.
Torque switch.settings are issued and controlled as a design document with station procedures requiring engineering approval for any chan~es. Open and closed limit switches are set in accordance with*
approved procedures which assure proper bypass times and verification that the valve is not electrically backseating.
Current signature traces are performed periodically and after any maintenance wh_ich could affect.
operating current and/or switch coordination.
Valve stroke times are meas.ured and trended after any maintenance which could affect the operating time of the valve.
Thermal overload devices are bypassed during system actuation in accordance with Regulatory Guide* 1.106.
Control of switch settings, overload devices, and post maintenance testing for the valves covered in this response is identical to that performed_ on valves.
in the original IEB 85-03.
Adequate controls exist to prevent *1nadvertent
- operations. Procedural controls exist to ensure the valves will.return to their safety position upon receipt of a s~stem initiation signal. Therefore, LaSalle Station believes the operation and maintenance of safety related valves in the HPCS and RCIC systems is in accordance with the intent of IEB 85-03.