ML20003G669
| ML20003G669 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/22/1981 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20003G668 | List: |
| References | |
| NUDOCS 8104300463 | |
| Download: ML20003G669 (9) | |
Text
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OG St UNITED STATES OF AMERICA 4)
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY l
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit 1)
)
AFFIDAVIT OF ROBERT D.
POLLARD _
Robert D.
Pollard, being duly sworn, does depose and state as follows:
O 1.
I have reviewed the following documents:
a.
UCS' Motion for Board Order on PORV Block. Valve Test Results, dated March 3, 1981, and the EPRI letter dated January 14, 1981 attached to UCS' Motion; i
b.
Licensee's Answer, dated March 13, 1981, to UCS' motion and the attached affidavits of Messers. Correa and Urquhart; c.
The NRC Staff's Answer, dated March 23, 1981,
' t-o UCS' Motion and the attached affidavit of Mr. Hemminger; i ~
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d.
' Lice'nsee s Amended Answer, dated April 9, 1981, to UCS' Motion and the attached supplemental affidavit of
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. Mr. Correa; and e.
Slides presented during an NRC Staff meeting held on March 20, 1981, concerning the EPRI testing program of PWR safety, relief, dnd block valves.
2.
Block valves tested by EPRI and the failures observed are as follows:
a.
July 1980 - Westinghouse block valve model 3GM88 equipped with a ROTORK operator set at 110 ft-lbs l
and tested in-line with a Control Components PORV would not close against full steam flow; b.
August 1980 -- Anchor Darling block valve equipped with an unspecified operator and tested in-line with a Fisher PORV would not fully close against full steam flow and significant wear patterns were observed at the disc / seat interface; c.
Prior to October 27, 1980 - Rockwell block valve 1
l had a body to bonnet seal problem; l
l d.
January 12, 1981
- Westinghouse block valve i
model 3GM99 equipped with a Limitorque operator model SMB-000-10 would not close fully against full steam flow (The model of in-line PORV, if any, has not been specifiedl;
.e.
Janua_ry 13,,1981 - Velan block valve model C2345 S/N-24302 equipped with a Limitorque actuator model
SMB-00-15 experienced galling on one of the disc guides Lthe model of in-line PORV, if any, has not been specified).
3.
All failures of block valves to close fully during the EPRI tests involved a mismatch between the valve closing force needed and the size of the motor operator or an incorrect torque switch setting.
No valve failures, per se, were involved in these failures to close.
4.
The TMI-1 block valve Dr Velan valve of unspecified model number) uses a Limitorque operator iduntical or similar to the Limitorque operator used on one of the Westinghouse block valves which would not close fully against full steam flow.
5.
The block valve / motor operator combination used at TMI-l has not been tested.
6.
No information concerning the design differences and design similarities between the TMI-l block valve and any of the block valves tested by EPRI has been supplied to this Board by the Staff or Licensee.
7.
Limitorque uses the same methodology to match the size of the motor operator to the service requirements of the block valve in each case (Correa Supplemental Affidavit, paragraph 4.)
8.
The EPRI tests involved cycling block valves open i
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and closed under full steam flow conditions.
9.
Other tests involving water flow, mechanical fixture testing (using a hydraulic cylinder to duplicate flow loads so force transfer can be studied in depth) and seat friction factor tests (to determine stellite on stellite friction factors under water and steam conditions) are underway or complete for Westinghouse valves.
The results have not yet been reported.
- 10. There is not sufficient information available upon which to base a conclusion that the TMI-1 block valve / motor operator combination "can be operated, closed, and opened for all fluid conditions expected under operating and accident conditions." (NUREG-0737, page 3-73)
- 11. If the TMI-1 PORV sticks. open and the TMI-l block valve cannot be closed, the result is a necessarv challenge to the ECCS.
Such challenges together with other challenges may exceed the design basis of the TMI-1 ECCS.
- 12. 'taff counsel argues that "[t]he block valve test results reported in the EPRI letter are not relevant to TMI-1." (Staff answer at 31 This argument misrepresents the affidavit of Mr. Hemminger who states only that the tests of Westinghouse block valves are, to an unspecified degree, less relevant than tests on Velan valves. (Hemminger affidavit, paragraph 6)
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. 13. Licensee argues that "the EPRL tests to date are valid confirmations of the TMI-l block valve's capability.
(Licensee Amended Answer at 2 and Correa supplemental affidavit, paragraph 61 However,thisargumentislnotsupportedby 5
Hamminger who states only that "[t]est yata from Velan block i
valves could be applicable to TMI-1."
f(Hemminger affidavit, paragraph 7, emphasis addedl Furthermore, EPRI is still developing a block valve test program responsive to the requirements of NUREG-0737 for submittal to the PWR utilities by June 1, 1981.
Thus, the testing to.date must be inadequate l
to demonstrate the capability of the bl'ock valves to function under the full range of fluid conditions expected under operating C
and accident conditions.
Moreover, it should be noted that l
while the staff and Met Ed are willing to extrapolate from l
l successful tests of valves similar to that at TMI-l (but C
l with at least a different motor operator), they are unwilling to accept the applicabil?.ty of unsuccessful tests of a similar or identical motor operator but'different valves.
l l
This is inconsistent and unjustifiable.
- 14. The following information should be provided to the Board:
a.
The basis for the Staff's belief that block i
valve testing would provide verification of block valve 4
u-
. functionability.
(See NUREG 0737, page 3-73) The explanation should discuss the failure of block valves to'cicse in EPRI tests conducted in July and August 1980, months before the publication of NUREG 0737 in November 1980.
b.
A comparison of the design of the valve / operator combinations tested by EPRI with the design of the actual valve / operator combination used at TMI-1.
c.
A comparison of the methodologies used to deter-mine the motor size, operatcr gear ratio, and closing loads for the TMI-1 block valve / operator combinations'and the block valve / operator combinations which were unable to close fully in the EPRI tests.
d.
A comparison of the range of fluid conditions which the TMI-l block valve can be expected to experience under oper-ating and accident conditions with the range of conditions experienced in tests or operation of other block valves whose capabilities are being relied upon to demonstrate TMI-l block valve capability.
e.
The effect, if any, on block valve function-ability during tests conducted with a PORV in-line with the block valve, but different from the TMI-l PORV.
f.
Ident,,ification of any instances where the Staff reported to any Board any of the block valve failures experiences in the EPRI tests, prior to UCS' Motion in this proceeding.
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Robert D. Pollard I, Robert D. Pollard, do hereby attest that the above is true and accurate to the best of my knowledge and belief.
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Subscribed and sworn to before me this Jf^"Uday of April, 1981.
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'0 UNITED STATES
-1 NUCLEAR REGULATORY COMMISSION e
FFICE OF INSPECTION AND ENFORCEMENT
- /
WASHINGTON, D.C.
20555 A>
p April 9, 1981 IE Bulletin No. 81-02:
FAILURE OF GATE TYPE VALVES TO CLOSE AGAINST DIFFERENTIA l
PRESSURE Descriotion of Circumstances:
l As a part of its pressurized water reactor (PWR) Safety and Relief Valve Testing Program, the Electric Power Research Institute (EPRI) conducted limited testing of a number of valves used on PWRs as power-operated relief valve (PORV) isolation or block valves.
These tests indicate a number of cases in which i
l cartain of tnese valves failed to fully close under conditions that approximated those of their intended se.cvice (i.e., saturated sterm at approximately 2,400 psi).
The valves that failed to fully close are gate type motor-o;.erated valves that tr.ay be used in various safety-related applications in addition to PORV block i
I valves.
Backaround on EPRI Testino:
The proposed full-scale qualification testing of PORV block valves, with a completion date of July 1,1982, was first provided to the utilities in a September 5, 1980, draft of NUREG-0737.
The item was formally issued, with Commission approval, in NUREG-0737 on October 31, 1980.
The block valve qualification testing was proposed in NUREG-0737 primarily as an additional means of reducing the number of challenges to the emergency core cooling system and the. safety valves during plant opc r. tion.-
In anticipating a request for PWR block valve testing, EPRI decided to make provisions for the installation of block valves betwean the test steam source and the test PORV in July 1980 at the Marshall test facility.
The Marshall test facility is a full-flow steam test facility owned by Duke Power Company.
Test PORVs had been carefully selected, with close coordination between EPRI, its consultants and PWR utilities, to assure that PORVs representative of those in service or intended for service would be tested.
Howeve., for the block valves that have been tested concurrently, this selection process was not followed beca'ase an NRC block valve test program had not been formulated.
Therefore, seven readily available valves were obtained and tested by EPRI, primarily to obtain some general baseline information on block valve closure capability.
For the bldek valves tfiat were tested, EPRI had not established, at least at the time of testing, the population of plants, either operating or under construction, that might have a valve of the type needed for testing.
In addition, it should be noted that the test conditions used at Marshall to date were only those that were determined to be applicable for steam testing of PORVs.
700R MME
IED 81-02 April 9,1981
'. ~
Page 2 of 4 t
These test conditions were selected after review by EPRI, utilities, and PWR NSSS vendors.
NRC staff also reviewed and concurred with the test conditions.
To date, there has been no similar specific determination by EPRI or the NRC staff as to the relevance of the Marshall block valve test conditions to the conditions in any specific PWR plant under which a block valve should be able to close to isolate a stuck-open PORV.
i To date, EPRI has tested a total of seven PORY block valves, all at the Marshall facility.
During these tests, the following valves failed to fully close during the EPRI PORV block valve testing:
1 1.
Westinohouse Electro-Mechanical Division (V-EMD) 3-inch Valves - These valves, whicn are manufactured by W-EMD, can be identified by the yoke-mounted nameplates that are stamped " WESTINGHOUSE" and include " VALVE IDENT." and " VALVE I.D." numbers given in Table 1.
Supplemental analyses and water testing, performed by W-EMD, determined.that a 4-inch valve also would not close fully and therefore is included in this bulletin. The.
nameplate data on this valve are given in Table 1.
These analyses and tests also determined the threshold differential pressure across the valves above which closure cannot be assured.
These values are given in Table 1.
A list of power reactor facilities believed to have the affected valves is given in Table 2.
It is our understanding that W-EMD has notified these facilities of the failure of these valves to fully close.
2.
Bore-Warner Nuclear Valve Division (BW-NVD) 3-inch 1500-pound Motor-Operated Gate Valves - These valves can be identified by BW-NVD part numoers 75460, 77910, and 79190.
Supplemental testing to determine threshold differential pressures for less severe service has yet to be completed.
A list of power reactor facilities believed to have the affected valves is given in Table 3.
BW-HVD has' submitted a 10 CFR Part 21 report in which they indicated that they have notified.these fe.cilities of the failure of these valves to fully close.
(Note:
Similar valves with BW-NVD part numbers 74380 and 74380-1 have been modified,_ retested, and demonstrated to close under test conditions.
As a result, they are not i
included in this bulletin.)
3.
Anchor Darlino 3-inch 1540 pound Double-Disc Valve - This valve, the first of a series of specially designed valves, has been modified, retested, and demonstrated to close under test conditions.
The remaining valves will be similarily modified during* manufacture.
As a result, they are not included in this bulletin.
(
It must be cautioned that Tables 2 and 3 may not be complete.
For example, the staff is aware of one power reactor facility that obtained affected valves from another inventory. -For thi,s. reason, this bulletin is applicable to all power reactor ficilities with an operating license or construction permit.
The tests and analyses performed to date raise doubts as to the ability of the affected valves to close under less severe service conditions.
These valves have also been supplied for utilization in a number of safety-related
-April 9, 1981 Paga 3 of 4 applications.
In the case of the W-EMD valves, they are also provided as spares or replacements through direct sales from the manufacturer.
For this reason, this bulletin is applicable to the affected valves that are required to close with a differential pressure across them in safety-related systems or as PORV block valves.
The responsibility for notification and corrective actions based on adverse test results continues to lie with the utilities and vendors in the industry.
NRC will continue to monitor the progress of the qualification program. All adverse test data will continue to be evaluated on a case-by-case basis.
NRC staff will take appropriate action, if necessary, to assure that the necessary corrective actions are made in a timely, manner.
Actions to be Taken bv Licensees:
1.
Within 30 days of the issuance date of this bulletin; ascertain whether any of the affected valves have been installed, or are maintained as spares for installation, where they are required to close with a differential pressure across them in safety-related systems or as PORV block valves.
The differ-ential pressures of concern include the following:
a.
For the W-EMD manufactured valves, values in excess of the threshold values iii Table 1.
b.
For the BW-HVD valves, any value.
2.
If no affected valves are identified, report this to be the case and ignore the items below.
3.
If any affected valves are identified as being installed, take corrective action and evaluate the effect that failure to close under any condition requiring closure wouid have on system (s) operability pursuant to the facility technical specifications for continued operation'.
l 4.
If any affected valves are identified as spares, either modify the valves so that they are qualified for the intended service or obtain qualified replacements prior to installation.
5.
Within 45 days of the issuance date of this bulletin, submit a report to l
NRC listing the affected valves identified, their service or planned j
service, the maximum differential pressure at which they would be required l
to close, the safety consequences of the valve's failure to close, the corrective action taken or planned, and the schedule for completing the l
corrective action.
Actions to be Taken by Construction Permit Holders:
1.
Ascertain whether any of the affected valves are or will be installed or maintained as spares for installation where they are required to close
IES 81-02 April 9, 1981 Paga 4 of 4 with a differential pressure across them in safety-related systems or as PO?N block valves.
The differential pressures of concern include the following:
For the W-EMD' manufactured valves, values in excess of the threshold-a.
values tii Table 1.
b.
For the BW-NVD valves, any value.
2.
If no affected valves are identified, report this to be the case and. ignore the items below.
3.
If any affected valves are identified, either modify the valves so that they are qualified for the intended service or obtain qualified replacements prior to startup.
4.
Within 90 days of the issuance date of this bulletin, submit a report to NRC listing the affected valves identified, their planned service, the maximum differential pressure at which they would be requirtd to close, the safety consequences of the valve's ' failure to close, the corrective action taken or planned, and the schedule for completing the corrective action.
For those cases in which reports ~have already been submitted in accordance with the Technical Specification,10 CFR Parts 21 and/or 50.55(e), this information need not be resubmitted.
Rather, licensees or construction permit holders should reference this earlier report and submit only the additional information requested above.
l Reports, signed under oath or affirmation under the provisions of Section 182a of the Ato. ic Energy Act of 1954, shall be submitted to the: Director of the m
appropriate NRC Regional Office and a copy shall be forwardeo to the Director or the NRC Office of Inspection and Enforcement, Washingten, D.C.
20555.
If you need additional information regarding this matter, please contact the apprcpriate NRC Regional Office.
This request for information was approved by GAO under blanket clearance number R0072 that expires November 30, 1983.
Comments on burden and duplication should be directed to Office of Managefnent and Budget, Room 3201, New Executive Office Building, Washington, D.C.
20503.
Attachments:
1.
Table 1 - Identification of W-EMD Manufactured Valves and Differential Pressure Limits for'0peration 2.
Table 2 - Partial List of Plants With Affected Valves Manufactured by )f-EMD 3.
Table 3 - Partial List of Plants With Affected Valves Manufactured by BW-NVD 4.
Recently issued IE Bulletins
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IDENTIFICATION OF W-EMD MANUFACTURED VALVES AND
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DIFFERENTIAL PRESSURE LINITS FOR VALVE OPERATION Nominal W-EMD Valve Model
" VALVE A***
Size (in.)
Reference IDENT."*
" VALVE I.O."**
(osid) 3 3GM88 03000GM88 3GM58 or 3GM78 or 3GM88 1500 3GM88 03002GM88 3GM58 or 3GM78 or 3GM88 1500 3GM99 03001GM99 3GM58 or 3GM78 or 3GM88 750 4
4GM88 04000GM88 4GM78 or 4GM88 750 4GM88 04002GM88 4GM78 or 4GM88 750 4
4GM87 04000GM87 4Gh77 '
750 4GM87 04002GM87 4GM77 750 This number is found on the yoke-mounted nameplate and occupies the first nine positions of a 24 position number.
It is used in evaluating the functional AP requirements.
This number is found on the yoke-mounted nameplate and occupies the l
first three positions of a six position number.
Valves sold as spares J
or replacements may not contain this number.
Pressure below which valve will close (as shipped).
Notes:
A " position" may contain mors than one character. ;The three-oosition i
" VALVE I.D." nurber consists of five digits in the three positions; j
for example 3 'iM 78.
All nameplates have " VALVE IDENT." numbers, but those sold as spares or replacements may not have " VALVE I.D." numbers.
The " VALVE IDENT."
number includes the manufacturer's model reference, and the " VALVE I.D." number is a reference to the valve system application. The
" VALVE I.D." number also appears on Westinghouse valve indexes and system flow diagrams.
There is no reference to tne " VALVE IDENT."
number on these indexes or flow diagrams.
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1-b2 TABLE 2.
PARTIAL LIST OF PLANTS WITH AFFECTED VALVES MANUFACTURED BY W-EMD
" VALVE IDENT." Number 04000GM88 04002GM88 04000GMS7 03000GMB8 03002GM88 03001GM99 04002GM87 Plant Operating plants (supplie.d as spares or replacements except as noted):
Beaver Valley 1 X
Connecticut Yankee X
Farley 1, 2 X*
Indian Point 2 X
Kewaunee X
North Anna 1, 2 X
Cconee 1, 2, 3 X
X San Onofre 1 X
Sur:/ 1, 2 X
X X
X Zion 1, 2 Nonoperating plants (supplied as original scope of supply except as noted):
Beaver Valley 2 X
~~
X Braidwood 1, 2 X
X Byron 1, 4 x
X Callaway 1, 2 X
X Comanche Peak 1, 2 X
X l
Harris 1, 2, 3, 4 X
X Jamesport 1, 2 X
X Marble Hill 1, 2 X
X l
San Onofre 2, 3 X**
l Seabrook 1, 2-X X
X i
South Texas 1, 2 Sum =ar X
X l
Vogtle 1, 2 X
X l
Watts Bar 1, 2 X
X "olf Creek X
X l
A
- Trar.sferred from inventory at another plant.
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- Spares or replacements.
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PARTIAL LIST OF PLANTS WITH AFFECTED VALVES MANUFACTURED BY BW-HVD Plant NVD-P/N Arkansas Nuclear One, Unit 2 75460 Bellefonte 79190 Palo Verde 77910 O
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DZ Courspon UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND L7 CENSING BOARD
)
In the Matter of
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METROPOLITAN EDISON
)
Docket No. 50-289
^*
COMPANY, et al.,
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(Three Mile Island
)
usna:
Nuclear Station, t'..it
)
APR 2 41981 > :'s No. 1)
)
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Officeof the t
Dochtsg Branch CERTIFICATE OF SERVICE s
7 I hereby certify that copies of the " Union of Concerned Scientists's Reply to Met Ed and Staff Submissions on Valve Testing," and " Affidavit of Robert D.
Pollard" have been mailed postage pre-paid this 22nd day of April, 1981 to the following parties:
i i
Mr. Steven C.
Sholly l
Secretary of the Commission l
U.S. Nuclear Regulatory Commission Union of Concerned Scientists.
l Washington, D.C.
20555 1725 I St., NW, Suite 601 l
Attn:
Chief, Docketing & Service Washington, DC 20006 Section James A. Tourtellotte, Esq.
Jordan D.
Cunningham, Esq.
Office of the Exec. Legal Director Fox, Farr & Cunningham U.S. Nuclear Regulatory Commission 2320 North Second Street Washington, D.C.
20555.
Harrisburg, PA 17110 Frieda Berryhill' Karin W. Carter, Esquire Coalition for Nucle'ar Power
- Assistant Attorney General
~
Postponement
-505 Executive House
~
2610 Grendon Drive;e:; -'
P.O. Box 2357
.w. 7 Harrisburg, PA 17120
.Wilmington, Delaware 19808-Walter W. Cohen, Consumer Adv.
Daniel 21. Fell Department of Justice
.. 32 South Beaver Street York, Pennsylvania 17401 Strawberry Square, 14th Floor Harrisburg, PA 17127
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Cert. of Service Docket No. 50-289 I
Robert L. Knupp, Esquire Chaunce'y Kepford Assistant Solicitor Judith H. Johnsrud County of Dauphin Environmental Coalition on P.O. Box P Nuclear Power i -
I 407 North Front. Street 433 Orlando Avenue Harrisburg, PA 17108 State College, PA 16801 John A.
Levin, Esquire.
Robdrt Q. Pollard Assistant Counsel chesapeake Energy Alliance Pennsylvania Public Utility 609 Montpelier Street Commission Baltimore, Maryland 21218 Harrisburg, PA 17120 Marvin I. Lewis 6504 Bradford Terrace f
Ms. Louise Bradford TMI ALERT Philadelphia, PA 19149 315 Peffer Street -
Harrisburg, Pennsylvania 17102 I
Ms. Marjorie Aamodt Ivan W.
Smith, Chairman Atomic Safety & Licensing; Board RD #5 Coatesville, PA 19320 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Walter H. Jordan Dr. Linda W. - Little f
881 W. Outer Drive 5000 Hermitage Drive _
l Oak Ridge, Tennessee 37830 Raleigh, North Carolina-27612 l
George F. Trowbridge, Esquire Ms. Jane Lee Shaw, Pittman, Potts &
R.D.
- 3, Box 3521 Etters, Pennsylvania 17319 Trowbridge i
1800 M Street, N.W.
Washington, D.C.
20036 I
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