ML17320B005

Revised Application for Amend to License DPR-74,providing Addl Info on Frequency for Torque Testing Ice Condenser Inlet Doors & Capability to Isolate Containment Svc Air.Rept on Test Dates & Drawing of Isolation Valves Encl

ML17320B005
Person / Time
Site:	Cook
Issue date:	04/19/1984
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0860-G, AEP:NRC:860-G, NUDOCS 8404260049
Download: ML17320B005 (21)

Text

REGULATORY LNFORMATION DISTRIBUTION SYb I Eh1 (RIDS)

ACCESSION NBR 8404260049 DOC ~ DATE 84/04/19 NOTARIZED, NO DOCKET ¹ FACIL:50-316 Donald C. Cook Nuclear BYNAME Power Plant~ Unit 2~ Indiana L 05000316 AUTH AUTHOR AFFILIATION ALEXICH<M.PE Indiana L Michigan Electric Co.

RECIP,NAME RECIPIENT AFFILIATION DENTONgH ~ RE Office of Nuclear Reactor Regulationi Director

SUBJECT:

Revised application for amend to License DPR<<.,74iprovidjng addi info on frequency for torque testing ice condenser inlet doors 8 capability to isolate containment svc air,Rept on test dates L drawing of isolation valves encl.

DISTRIBUTIQN CODE: A001S COPIES RECEIVED:LTR g ENCL SIZE:

TITLE: OR Submi t t a 1: Gene r a 1 Di s t r i bu t i of1 NOTES'EC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR ORB1 BC 01 7 7 INTERNALS ELD/HDS3 1 0 NRR/DE/MTEB 1 1 NRR/DL D IR 1 1 NRR/DL/ORAB 1 0 N TB 1 1 NRR/DSI/RAB 1 1 HEG FILE 04 1 1 RGN3 1 1 EXTERNAL: ACRS 09 6 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 NTIS 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 23

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INDIANA 8 MICHIGAN FLECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 API i 1 19, 1984 AEP:NRC:0860G Donald C. Cook Nuclear Plant Unit 2 Docket No. 50-316 License No. DPR-74 AMENDMENT TO TECHNICAL SPECIFICATION CHANGE REQUEST Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

This letter provides further information regarding the Technical Specification change request contained in our letter No. AEP:NRC:0860 dated March 1, 1984, as per phone conversations held with members of your staff. Specifically, we were requested to provide additional details with regard to the second and fourth proposed changes in AEP:NRC:0860.

The second change involved the frequency for torque testing the ice condenser inlet doors. Attachment 1 to this letter is plant report No. STP.207 dated February 27, 1984. The plant report shows the lower inlet door test dates and the corresponding condition reports. The condition reports describe the causes for the conditions and the corrective actions taken to assure that the respective doors function properly.

The fourth change involved the capability to isolate containment service air in Modes 1, 2, 3, and 4. Specificallyf we requested Table 3.6-1 be changed to add valve PCR-40 to list A and valve PA-342 to list E and to delete valve PA-243 and a blind flange (Item 47) from list E. Attachment 2 to this letter contains a figure and drawing which show the location of the above valves. Figure 9.8.3 from the updated FSAR shows the physical location of the valves. Drawing 1-2-PO-01 shows the isometric location of the valve PCR-40, which would replace a manually operated valve at that location. Upon the initiation of the containment isolation signal, this valve is to close automatically, thus providing containment isolation.

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Mr. Harold R. Denton AEP: NRC: 0 86 OG This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours,

~l M. . A exichg)

Vice President th Attachment cc: John E. Dolan W. G. Smith, Jr. Bridgman G. Charnoff R. C. Callen E. R. Swanson, NRC Resident Inspector Bridgman

I INDIANA 8 MICHIGAN ELECTRIC COMPANY OlA/ER SY5TK DATE: February 27, 1984 sUBJEcT: STP . 207 Repo rt FROM: A. L. Tetzlaff Tot K. S. Chapman STP.207 I/C Lower Inlet Door Test Dates and the Dates Condition Reports llere Llritten UNIT 1 UNIT 2 2-77 None 3-78 N/A to STP.207 9-77 None 5-78 N/A to STP.207 11-77 Hone 7-78 2-7-78-404 6-78 N/A to STP.207 11-78 2-11-78-617 12-78 1-4-79-176 5-79 2-5-79-242 5-79 None 10-79 None 10-79 1-11-79-4 79 7-80 Hone 7-80 IIone 11-80 Hone 12-80 1-12-80-348 11-83 Hone 6-81 1-1-81-001 3-81 2-3-81-102 11-81 None 10-81 None 2-82 None 3-82 None 7-82 None 8-82 Hone 3<<83 None 1-83 None 7-03 Hone 6-83 2-06-83-527 11-83 None 8-83 2-07-83-614 N/A to STP.207 1-84 Hone 2-08-83-753 11-83 None Please see the following pages for an explanation of what was done to correct and prevent L.I.D. problems.

Condition Reports, Dates, Causes, and Corrective Action Condition Report 1-4-79-176 LER 028 Discription of Condition/Event Uete 4/10/79 Event Tine 1515 Unit Affected 1 The torque required to open lower inlet door 3-R beyond 6 inches of travel was measured to be 902 in.- lbs. The applicable Technical Specification limit is 675 in.- lbs. Upon inspecting the door, screws along the bottom of the door were rubbing it was found that sheet metal against the surface of the bottom edge of the door frame.

INTRA SYSTEM

. Page Two Corrective Action Taken Initiated JO No. 49689 Depressed lower inlet door 3-R frame bottom edge surface to allow door to be opened beyond 6 inches utilizing an opening torque of 328 in lbs.

As a result of the problem described in the subject Condition Report, two inspections were conducted on April 13, 1979. The fi rst inspection consisted of observations made in bay 3 only. The second inspection consisted of observations conducted throughout the remaining bays based on the r suits of the first inspection conducted in bay 3.

During the first inspection, the following observations were made (refer to Attachment ~l):

1) abrasion marks appeared on the door frame bottom ledge where two of the door's sheet metal screws were making contact as the door was opened,

2) large dents in plate B were observed directly below the abrasion points thereby suggesting that a mechanical force, imparted on plate B, may have resulted in forcing plate A upwards and also increasing the size of the gap between plates A 5 B,

3) the RTV sealant, previously installed in the gap between plates A E B, was found missing thereby allowing the possibility of condensation to run from atop plate A down into the insulation to freeze and push plate A upwards and

4) mineral residue, indicating condensation flow across plate A (from warm side to cold side) and down toward the gap between plates A 8 B, was observed .

During the second inspection, the following verification were made:

1) it was verified that none of the other door frame bottom ledges exhibited significant damage (dents); the type of which was found in bay 3 and

2) it was verified that only bay 14 (in addition to bay 3) was missing the RTV sealant in the gap between plates A and B.

As a result of these inspections, Dayco Sheet tietal Inc. was ordered to remove both plate A and plate B from bays 3 and 14 to allow inspections for ice buildup in the insulation. After the plates wer e removed, it was verified that the insulation in bay 3 was heavily loaded with ice. The insulation in. bay 14, however, revealed no evidence of water or ice buildup.

Based oh the that door observations made during these inspections, it is apparent 3-R plate A was forced upwards (and in contact with the door's sheet metal screws) as a result of a cwbination of mechanical impact transmitted from plate B and insulation expansion as a result of freezing condensation.

During the insulation, it became obvious that not only did the blows to plash B force plate A upwards but also resulted in widening the gap between plates A 8 B which resulted in a high probability of increasing condensation flow into the insulation.

Page Three

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Upon ccmpleting the inspections described in the attached investigation report, Dayco Sheet tietal Inc. replaced all of the frozen insulation along the bay 3 door frame bottcm ledge and plates A E B were reinstalled in both bay 3 and bay 14. In addition, RTV sealant was installed along the entire length of the gap between plates A 8 B in both bays. The RTV sealant is considered a permanent fix in prohibiting condensation flow down through the gap and into the insulation.

To verify that an adequate clearance between the sheet metal screws and plate A existed after the completion of the repairs to bays 3 and 14, the following initial opening torque measurements were made:

~Ba Il ~tl i F L 1 A ~T 3 8.5 LBS 41 IN 348 IN LBS 3 8.5 LBS 41 IN 348 IN LBS 14 9.5 LBS 41 IN 309 IN LBS 14 9.0 LBS 41 IN 369 IN LBS

• Technical Specification maximum acceptable torque is 675 IN LBS.

To completely eliminate the possibility of this problem in the future, a RFC has been written to replace the horizontal plate A with a plate that would slope down in the di rection as shown in Attachment ¹2. The sloping feature of the this plate would provide a significantly greater clearance between the plate and the door's sheet metal screws. The greater clearance will allow plate B to absorb impact without causing plant A to interfere wi th the door's opening travel. It is planned to install the RFC in each unit during each unit' upcoming refueling outage. (This has been canpleted)

In an attempt to detect any damage to the doors that would result in an increase in the door's .opening torque, the initial opening force will be re-measured just prior to power escalation at the end of every ice condenser basket weighing project.

This investigation was done by K. A. Toner thy 3, 1979 LER 79-028 Event Description And Probable Consequences:

While performing a routine surveillance test it was discovered that the torque required to open lower ice condenser inlet door 3-R exceeded the limit identified under T.S. 3.6.5.3.

Cause Description And Corrective Actions:

The sheet metal screws located along the bottom of the door were discovered to be rubbing against the surface at the edge of the door frame requiring excessive force to open the door. The door frame edge was depressed to allow proper clearance, and a retest was performed with satisfactory results.(see supplement)

SUPPLEt1ENT TO LER ¹79-028/03L-0 SUPPLEHENT TO CAUSE DESCRIPTION Following an inspection of the remaining ice condenser doors for similar problems, a design change was submitted to change the positioning of the lower inlet door frames to allow a greater clearance between the door and frame.

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Page Four C.R.¹ 1-11-79-479 LER ¹79-056 Investi ation Re ort C R 1-11-79-479 Evaluation of the test data taken during the performance of THP 4030 STP.207 revealed that the opening torque limit of 195 in-lbs was exceeded only on lower inlet doors 17L 5 21R.

Examination of past data taken on the Unit 1 lower inet doors shows that the doors in bays 17 and 21 have been a problem in the past. These doors have always tested near or slightly above the limit of 195 in-lbs.

It seens likely from this data that the springs used in these particular doors might be slightly stiffer than those in the doors in other bays.

The spring tension adjustment bolts on these doors ( bays 17 8 21) are now backed out to their limit and the door opening torques are below the limit but only slightly, so as a permanent solution either the springs should be replaced or the spring tension adjustment bolts should be replaced with longer bolts.

Preventative Action:

An RFC has been written to replace the spring >adjustment bolts in order to relieve the spring tension on those lower inlet doors which have high opening torque values (RFC 12-1762). (This has been completed)

L ER ¹79-056 SUPPLEl1ENT TO CAUSE DESCRIPTIOH A design change has been initiated to replace the spring adjustment bolts with longer bolts in order to relieve the spring tension on the lower doors, (RFC 12-1762). (This has been completed)

The doors were immediately readjusted when the problem was found and no action was r equir ed by Technical Specifications .

C.R. ¹1-12-80-340 LER 80-028 Insulation slipped down causing 2 doors to fail when testing 25K of doors per Technical Specification 4.6.5.3-1-b. Bay 1 8 Bay 3 hinge friction was found existing per Technical Specification 4.6.5.3.l-b5.

Corrective Action Taken: Initiated JO No. 59677 Emergency RFC 01-1819 was written to replace slipped insulation.

J.O. 59677 was written to make door repairs.

Dayco Sheet tletal Company was assigned job for raising the insulation and adding sheet metal screws to hold ittheinplace on the door jams.

All bays were repaired per RFC 01-1819, and retested per 12 THP 4030 STP.207 for opening and closing torque and hinge friction. All doors were then acceptable, meeting all Technical Specifications.

J.O. nmber 59684 has been written to check the Unit 2 lower inlet doors during the next outage in April of 1981. (This has been completed)

Page Five The exact failure nechnism was not deternined due to unit start time constraints.

Door removal would have been necessary to determine exact failure'mode. Two modes are thought to be possible; 1- Failure of the 3-M Scotch Grip 134 adhesive due to age fatiguing. No temperature range of the adhesive could be determined. Westinghouse Drawing 81139E97.

2- Shearing of the pourious insulation blocks causing failure of the metal to insulation bond.

Written by: Art Tetzlaff LER 80-28 Cause Description And Corrective Actions:

The insulation around the two doors was found to be slipping in the downward direction. The rubbing between the doors and the insulation at this interface was the cause of the excessive torque. By design, the insulation is bonded to the metal by an adhesive and it was this bond that failed . An Emergency design change was issued (RFC 01-1819) to add sheet metal scr ews to the insulation on all the lower doors. This was done and all doors were tested and found to meet Technical Specifications. A Job Order has been written to check the Unit 2 lower ice condenser door insulation during the next refueling outage.

Note: This was done on Unit 2 Written by: Art Tetzlaff C.R. 81-1-81-001 No LER Description of Condition:

Bays 2, 3, 4, 5, 14, 18, 20, 21, 22 had pin cotter keys missing. The subject pins attached the lower inlet door springs to the door.

Corrective Action Taken: Initiated JO No. 59776 Job Order written to install all cotter keys will be installed before Unit 1 startup.

Job Order 59776 was written to have Dayco Sheet Hetal Co. reinstall the missing cotter pins.

All missing pins were replaced and checked in place before the Unit 1 start-up.

RFC 1-2-1762 was canpleted on Unit 1 lower inlet doors during the 1900 Refueling Outage. This RFC changed the door spring adjusters to give more spring adjustment.

It is believed the cotter pins were left out at this time.

Because the door spring pins are held in by gravity, at no time were the lower doors inoperable due to the missing cotter pins.

It is recanmended that subject Condition Peport be reclassified 'E'.

Remarks: The original Condition Report was lost and this new report was caopleted on 3-30-81 Written by: Art Tetzlaff 3-30-84

Page Six C.R. 8 2-7-78-404 LER 78-057 Description of Condition:

While running STP.207 Ice Condenser Lower Inlet Doors Doors 1-R and 14-L exceed the acceptance criteria of 675 inch pounds force to open the door.

Corrective Action Taken:

Smoothed out rough spots on door frames. When retested, the doors had an opening force of 613.2 (1-R) and 567 inch pounds (14.L) which fall within the acceptance criteria as stated in STP.207.

Investigation Report:

All the doors were checked for other rough spots, but none were found as noted in STP.207. When rechecked, doors 1-R and 14-L were found to be in spec.

LER 78-057 During a surveillance test on the ice condenser lower inlet doors, doors 1-R and 14-L exceeded the initial opeing torque specified by T.S. 4.6.5.3.1.b.l Cause Description and Corrective Actions Investigation revealed that the door seals were catching on rough spots on the door frames. These rough spots were smoothed and the doors were retested with the initial opening force meeting the Technical Specification requirements. All other doors were check for similar rough areas, none were found.

CR 0 2-11-78-617 LER None Description of Condition:

Inlet door No . 9 .L stuck about,2" open and exceeded the 675 in-lbs torque to open.

Corrective Action Taken Initiated JO Ho. 04092 Job Order Written Investigation Report:

Bay door'9L would not op n more than 2 inches without excessive force. A Job Order was written to repair. The door was found to have a small ice build-up probably from the defrost completed several days prior. A satisfactory retest was canpleted. All other doors were found in spec.

Page Seven Preventive Action Taken Initial openning force for STP.207 is completed prior to any ice condenser defrost activi ty.

2-5-79-242 LER None Description of Condition THP 4030 STP.207 step 5.1.11 Ice Condenser door annunciator does not alarm in the control rocm . SV panel drop 94. Contrary to the requirements of TS 4.6.5.3.1.

Written by: Bill Gillett Corrective Action Taken Initiated JO No. 10800, Job Order to correct condition C.R. 8 2-5-79-242 Investigation into the cause of the alarm failure revealed that the annunciator card for the ice condenser door alarm had failed. The card was replaced and the annunicator tested for proper operation. Step 5.1.11 was performed again and proper indication in the control rocm was received.

Written By: B. Hullinger This failure was only the audible alam function, all indicating lights functioned properly per B. Gillett.

Written By: J. L. Rischling 2-3-81-102 C.R. LER O'one Item reported on Unit 2 lower ice condenser inlet door springs Description of Condition Bay 9 left top door springs have two cotter pins missing . The missing cotter pins did not affect door operation.

Written By: Art Tetzlaff J.O. 59684 was wr itten to check cotter keys on Unit 2 during t".arch 1981 refueling outage per Condition Report 1-2-81 0'1-1-81-001.

All,bay doors 1-24 were checked 3-20-81, bay 9 top left door spring cotter pins were found missing. This did not effect door operation in any way.

J.O. 07232 was written on 3-20-81 to replace the missing cotter pins.

Pins were replaced 3-21-81.

Written By: Art Tetzlaff

Page Eight It could not be determined what happened installed.

to the missing cotter keys or if any were ever Written By: J. L. Rischling C.R. 0 2-6-83-527 LER 883-056 Item Reported On Unit 2 Ice Condenser Lower Inlet Doors Description of Condition While performing lower inlet door test (**12 THP 4030 STP.207), door 3L of bay 3 did not meet the acceptance criteria of initial opening torques of < 675 in. lbs.

The door required 912 in lbs. to open.

Written By: fl. J. Stark Immediate Action Taken:

The door was inspected visually it was determined that the door seal was dirty which caused the door to stick initially. A Job Order was written to have the doors and seals cleaned .

Written By: ti. J. Stark Investi ation Re ort CR 8 2-06-83-527 The ice condenser lower inlet door surveillance test 12 THP 4030 STP.207 was performed on June 24, 1983 to satisfy Technical Specification 4.6.5.3.1.

The left door of Bay three failed the initial opening torque limit of < 675 in-lbs. The door required a torque of 912 in-lbs to open.

The door hinges, and frame seals were visually inspected to try to determine the problem. The problem was the result of the frame seals initially sticking to the door because of glycol on the seals. The door was lined to contact the seals as designed .

Preventive Action A Job Order was written to have the door seals repaired or replaced (Job Order 12967). Upon visual inspection, it was determined that cleaning of the seals would .eliminate the problem. The seals were'cleaned and the door retes'ted July 5, 1983. The door satisfied the Technical Specification limit of < 675 in-lbs. No further preventive action is planned at this tine.

Note: Seals are cleaned after evey ice condenser basket weighing .

Written By: ti. J. Stark

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Page Nine LER 83-056 During surveillance testing on the ice condenser lower inlet doors, it was found that door 3L of bay 3 3xceeded the maximum allowable torque limit of less than or equal to 675 inch pounds required to initially open the door .

This event is non-conservative with respect to Technical Specification 4.6.5.3.1;b.l.

The action, requirements were met. Public health and safety were not affected.

This is the first occurrence of this type.

Cause Description and Corrective Actions Investigation found the problem was the result of the frame seals initially sticking to the door because of glycol being on the seals. The frame seals were cleaned and the door was retested satisfactorily. No futher action is planned at this time since this is the first occurrence associated with glycol .

C.R. ¹ 2-08-83-753 LER 83-003 Iten Reported On STP.207 Lower Inlet Door Test Description of Condition The following conditions were found during the test:

Bay 1, Left door stuck at about 4" open Right door exceeded 675" pounds

• 'ay 3,

Bay 10, Left door stuck at about 4" open - 36" to open Bay 13, Right door closed RTD cable.

Bay 14, Right door would not open past 4" Bay 18, RTD string loose - Dropped about Written By: W. T. Gillett 10'mmediate Action Taken: Initiated JO No. 12977 5 13127 Job Order to f1aintenance to repair doors Job Order to Controls and Instrumentation to repair RTD string Written By: W. T. Gillett Investigation Report CR ¹ 2-08-83-753 I

llh'ile conducting STP-207 (" Lower Inlet Door Test" ), Unit 2, five doors were found that exceeded the 675 inch-pound opening torque required by Technical Specification 3.6.5.3.

In bay-13 the right door was closed on a loose RTD cable. The cable was removed fron the door and tie-wrapped up out of the way. The door was retested satisfactorily.

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Ten Bay-1 left door, bay-10 left door, and bay-14 right door, all exceeded the 675 inch-pound Technical Specification limit. Job Order 12977 was sent to Maintenance to repair the doors. Maintenance found the doors to be sticking at the top. They moved the door frame to provide the necessary gap. The doors were retested satisfactorily.

Bay-3's right door exceeded the opening force of 675 inch-pounds. The door was inspected and the seals were cleaned . The door was retested

. satisfactorily.

In bay-18 hn RTD string had dropped about ten feet. The RTD string was pulled up and attached to the ice condenser framework, as per C8 I Job Order nunber 13127.

Preventive Action C.R. 2-08-83-753 Change sheet was written to **12 THP 4030 STP.211, "Ice Basket Weighing ."

This TP will insure that all doors are free from obstruction following an ice basket weighing project. This TP also insures the door seals and sealing surfaces are free from debris that could cause binding. This T.P.

has been incorporated into the ice basket procedure in the recent revision.

Written By: K. S. Chapman/W. T. Gillett LER 8 03-083 During perfornance of the ice condenser lower inlet doors surveillance test, was found that five doors exceeded the maximum initial opening force specifications.

it This event was non-conservative with respect to Technical Specification 4.6.5.3.l.b.

The action requirements were met. Public Health and Safety were not affected.

Previous occurrences of a similar nature included: 050-315/75-069,76-001, 024, 030i 038, 70-028$ 052,83-002, 316/78-057,83-056.

Cause Description and Corrective Actions:

Investigation revealed that three (3) of the doors required adjustments to the door frame. One door was found to be closed on a loose RTD cable. The cable was removed and secured away from the door . The remaining door was inspected and the seals were cleaned . The doors were retested satisfactorily. (See Lower Supplement)

Attachment to LER ¹ Su lenent to Cause Descr i tion Investigation revealed that three (3) of the doors required adjustments to the door frame. One door was found to be closed on a loose RTD cable. The cable was removed and secured away from the door. The remaining door was inspected and the seals were cleaned . The doors were retested satisfactorily.

To prevent recurrence, the appropriate procedure has been modified to insure that all doors are free from obstructions and that the seals and sealing surfaces are free from debris that could cause binding following cmpletion of ice basket weighing/repair project.

A. L. Tetzlaff

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