ML20042D442
| ML20042D442 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/02/1990 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, IEB-85-003, IEB-85-3, NYN-90003, NUDOCS 9001090145 | |
| Download: ML20042D442 (15) | |
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Ted C Feigenboom,
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Senior Vice President and -
Chiel Operating Officer :
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'NYN 90003
' January 2 -1990,
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. United States Nuclear Regulatory Conunission-
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References:
' a)j ~ Facility Operating License NPF-67, Docket No. 50-443 ep n
b)..USNRC Generic Letter No. 89-10 dated June 28, 1989,
' Safety-Related Motor-Operated Valve Testing and Surveillance' 4
a.
c)-
PSNH Letter SBN-1052 dated May 15,'1986, ' Response to IE
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Bulletin 85-03", G. S. Thomas:to Dr; T. E. Murley, Jr.
d);
PSNH Letter.NYN-87137 dated November 30,-1987 " Response
,5 Eto.IE Bulletin 85-03','G. S. Thomas'to Mr.'W. T. Russell-e)
PSNH Letter NYN-88097 dated July 18.-1988,-_' Request for
' Additional Information to IE~ Bulletin 85-03' if)
PSNH~ Letter NYN-89154 dated November 29, 1989,
' Informational Update on.IE Bulletin 85-03"-
1
Subject:
Response.t'o Generic Letter'89-10 0 Gentlemen:
.New Hampshire _ Yankee has described, in the letters referenced above,
'_ theJProgram developed in. response to IE Bulletin 85-03, to ensure that the switches of' motor-operated _ valves (MOVs) are properly selected, set and maintained.
.The Program currently implemented at Seabrook Station Unit 1
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emergency;feedwater (EFW) systems. As previously described in letters, NHY p/
. hasjcompleted baseline diagnostic testing of the thirty (30) MOVs within tiNeAn the scope:of the Progrant. New Hampshire Yankee has also performed Q
Ediagnostic' testing of over thirty (30) additional MOVs in safety-related N.
"{ew systems 1which are currently beyond the scope of the Program.
90s0 mi In Generic Letter 89-10, NRC requested that licensees make the j*g conunitment.to extend the.ecope of the Program, developed in response to joQ LIE: Bulletin 85-03, to include MOVs in all safety-related systems except M.
those MOVs blocked from inadvertent operation.
This letter submits information pursuant to 10CFR50.54(f), describing the actions planned by NHY
- in' response to the recommendations of Generic Letter 89-10.
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,4 New Hampshire Yankee Division of Public Service Company of New Hampshire j
P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474 9521 i
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- United States Nuclear Regulatory Commission '
January 2, 1990' s
Attention:- Document Control Desk-Page 2 I
The Program described in previous letters (SBN-1052, NYN-87137 and'
-NYN-89154).will be extended'in scope to include applicable MOVs in safety-related systems.
In determining'the specific MOVs to be included within the
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scope of the extendedLProgram, the criteria described in' Generic. Letter 7
89-10 will be. considered. 'The. basis for not including a MOV in a safety-
- related: system within.the scope of'the extended Program will be documented
'm and that documentation will be retained onsite.
.The'NHY response to each recommended action,of Generic Letter 89-10 cand a schedule.for completion of' planned actions is provided-in Enclosure 1 to this. letter. LA description of.a MOV diagnostic testing methodology lwhich is basedLupon the use of strain gauges and is currently under.
C development at Seabrook Station is provided in Enclosure 2 to this letter.
. Current'conunitments regarding MOV differential pressure or flow testing.at Seabrook Station are described in FSAR Section'3.9(B).3.2 and PSNH letters SBN-1052~(Reference (c)] and'NYN-88097,[ Reference (f)). This response.to' Generic Letter-89-10 contains no additional commitments
.regarding MOV differential pressure or. flow testing.- New Hampshire Yankee
. intends-to' monitor industry developments' pertaining to MOV differential I
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pressure or flow testing and alternatives to such testing.
. If you have any questions on this matter, please contact Mr. Geoffrey
-Kingston at-'(603) 474-9521, extension 3371.-
Very truly yours,
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Ted C. Feigenbaum Enclosures-i i
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- United States' Nuclear Regulatory Commission January 2,-1990 Attentions, Document Control Desk.
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Mr.-William T. Russell Regional Administrator United-States Nuclear Regulatory Commission Region I>
475 Allendale Road King of Prussia, PA 19406-Mr. Victor Nerses. Projec't Manager Project Directorate I-3 United States Nuclear Regulatory Commission.
Division of Reactor Projects Washington - DC : 20555 Mr. Antone C. Corne NRC Senior Resident Inspector P.O., Box:1149 Seabrook, NH 03874
. STATE OF NEW HAMPSHIRE Rockingham, es.
January 2, 1990 2
.Then personally appeared before me, the above-named Ted C. Feigenbaum, being duly sworn-did state that he is Executive Director-Nuclear Production of
- the.New Hampshire Yankee Division of Public Service Company of New Hampshire, that he is duly authorized to execute and file the foregoing information in the name and on'the behalf of New Hampshire Yankee Division of the Public Service Company and that the statements therein are true to the best of his knowledge
- and belief.
O M b 3 N % et u
- Beverly Silldpay, Notary Puhtic
-My Commission Expires: March 6, 1990 p
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New~ Hampshire Yankee
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January 2, 1989
. ENCLOSURE 1.TO NYN-90003 RESPONSE TO THE NRC-RECOMENDED ACTIONS OF GENERIC LETTER 89-10
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New Hampshire Yankee January 2, 1989 MAC-Racessended Actions f a) and (e):
4 a - Review and document.the design basis for.the operation of each MOV.
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This documentation should include the maximum differential pressure expected during both the opening and closing of the MOV for both normal operations and abnormal events, to the extent that these MOV operations and events are included in the existing approved design.
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Regarding item a.,
no change to the existing plant design basis is intended and none should be inferred. The design-basis review should not: be restricted to a determination of estimated maximum design-basis differential pressure, but should include an examination of the pertinent design and installation criteria that were used in choosing the'particular HOV. For example, the review should include the effects on HOV performance of design-baeis l -
degraded' voltage, including the capability of the MOV's power s
supply'and cables to provide the high initial current needed for the operation of the MOV.
j NBY Response:
I New' Hampshire Yankee will conduct a design-basis review for each HOV
' determined to be within the scope of the extended Program. uThis review will identify the design-basis line pressure, fluid flow, fluid temperature,
--differentialLpressure and minimum operating voltage for each MOV, as applicableito its' type and function within the system.
P Applicable. design-basis information will be used as input to a L
calculation performed to define the maximum and udnimum thrust for each MOV q,
during both opening and closing of the MOV. The interval'between the l
maximum and minimum calculated thrust will provide a range of thrust values
(' calculated range").
The actual thrust, as meast red during MOV diagnostic L
- testing, should be within the calculated range at the time of torque switch operation.
The excended Program description will include a description and
' schedule for completion of the design-basis review.
NRC-Recossiended Action (b):
l Using the results from item a., establish the correct switch settings.
H This should include establishing a program to review and revise, as L
necessary, the methods for select 3ng and setting all switches (i.e., torque, torque bypass, position limit, overload) for each valve operation (opening and closing). One purpose of this letter is to ensure that a program exists for selecting and setting valve operator switches to n
ensure high reliability of safety-related HOVa.
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- is New Hampshire Yankee January 2, 1989 i
NEY Response:
-New Hampshire Yankee has developed methodology to establish conservative MOV switch settings based upon the use of multiple sources of information. For the thirty (30) MOVs currently within the scope of the Program, the results of the design-basis review, the results of MOV diagnostic testing, manufacturer's recommendations and other pertinent data form the, basis for the determination of MOV switch settings. The s
methodology for establishing switch settings for HOVs utilizing this input data is described in approved Seabrook Station procedures. Documents under the programmatic control of the Design Control Program specify limiting values or a dange of acceptable values for the torque and limit switch setpoints of'each MOV. The flexibility afforded to field personnel to change MOV switch settings is~ constrained by the limits specified in these documents. This same methodology will apply to the additional MOVs l
determined to be within the scope of the extended Program.
The extended L
Program description will include a description of the methodology to establish conservative MOV switch settings.
MRC-Recommended Action (c):
l-Individual MOV switch settings should be changed, as appropriate, to those L
established in response to item b.
Whether the switch settings are changed or not, the MOV should be demonstrated to be operable by testing it at the design-basis differential pressure and/or flow determined in response to e
item a.
Testing MOVs at design-basis conditions is not recommended where
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such testing is precluded by the existing plant configuration. An l
explanation should be documented for any cases where testing with the
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' design-basis-differential pressure or flow cannot practicably be performed.
This explanation should include a description of the alternatives to design-l l
basis differential pressure testing or flow testing that will be used to verify the correct settings.
E91E This letter is not-intended to establish a recommendation for valve testing for the condition simulating a break in the line containing the MOV.
However, a break in the line should be considered in the analyses described in items a.,
b., and c., if MOV operation is relied upon in the design basis.
Each MOV should be stroke tested, to verify that the H0V is L
operable at no-pressure or no-flow conditions even if testing with differential pressure or flow cannot be performed.
NHY Response As part of the extended Program, conservative MOV switch settings established as described in the response to Recommended Action (b). above, 2
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New Hampshire Yankee
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Deviations between actual
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- will be_ compared to actual MOV switch settings.
settings and conservative settings will be reviewed and appropriately l
resolved..The extended Program description will describe in more detail the process of resolving any deviations between actual and conservative MOV switch. settings.
J Pre-operational or startup testing performed to date has included, to the extent practical, differential pressure or flow testing of selected y
._ The extent'of.the differential pressure or flow applied during MOV's.
testing is based upon consideration of system design and configuration' limitations as well as an assessment of the MOV safety function and sound operating principles. Differential pressure or flow testing performed to
.date has verified'that motor operator switch settings established as described above have been conservatively set.
L NHY will review the differential pressure or flow testing that has been performed to date on each MOV within the scope of the extended Program.
Provided that existing cosunitments regarding differential or flow testing
-have been met, differential pressure or flow testing will not be repeated unless deemed appropriate based upon the circumstances of the particular MOV.
Stroke' testing of MOVs under static conditions is performed in
.accordance with the requirements t.f the ASME Code,Section XI, as described in FSAR Section 3.9(B).3.2.
No additional commitment regarding differential pressure or flow testing is contained in this letter. New Hampshire Yankee will continue to
. monitor industry activities pertaining to MOV differential pressure or flow testing and.the alternatives to such testing as the extended Program is developed and implemented.
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NRC-Recoassended Action (d):
L Prepare or revise procedures to ensure that correct switch settings are l'
determined and maintained throughout the life of the plant.
These procedures should include provisions to monitor MOV performance to ensure the switch settings are correct.
This is particularly important if the torque or torque bypass switch setting has been significantly raised above that required.
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It may become necessary to adjust MOV switch settings because of the effects of wear or aging. Therefore, it is insufficient to merely verify that the switch settings are unchanged from previously established values.
The switch settings should be verified in accordance with the program schedule, (see item j.).
The ASME Code L.
Section XI stroke-timing test required by 10CFR Part 50 is not oriented toward verification of switch settings. Therefore, additional measures should be taken to adequately verify that the switch settings ensure 3
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New Hampshire Yankee January 2, 1989 HOV operability.
The switch settings need not be verified each time y
the ASME Code stroke-timing test is performed.
p MHY Resnonse:
In response to IE Bulletin 85-03, NHY reviewed procedures governing preventive maintenance, corrective maintenance, surveillance and diagnostic p
testing of.the thirty,(30) MOVs within the scope of the Program to ensure J
that the requirements of these. procedures implemented the Program.
Specifically, this review verified that the procedures require MOV switch 6,
' settings to be established, set and verified in accordance with the asethods f
described in the NHY responses to IE Bulletin 85-03.
In implementing the j
extended Program, applicable procedures will again be reviewed to verify that the specific requirements of the extended Program are implemented.
Where required, procedures will be revised and new procedures will be developed.
1 Surveillance and diagnostic testing will be periodically performed te monitor MOV performance to ensure that switch settings remain conservatively set to provide sufficient torque and/or thrust to overcome design-basis conditions for the'. operating life of each MOV.
q NRC-Recommended Action ff):
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Documentation of explanations and the description of actual test j
methods used for accomplishin3 item c.,
should be retained as part of the required records for the MOV.
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-It is also recognized *that it may be impractical to perform insitu MOV L
testing at design-basis degraded voltage conditions. However, the
-switch settings established in response to item b.,
should at least be established to account for the situation where the valves may be called on to operate at design-basis differential pressure, or flow, and under degraded voltage conditions. If the licensee failed to consider degraded voltage, power supply, or cable adequacy for MOVs in systems covered by Bulleting 85-03, the design review and established switch settings for those MOVs should be reevaluated.
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Alternatives to testing a particular MOV insitu at design-basis pressure or flow, where such testing cannot practicably be performed, could include a comparison with appropriate design-basis test results on other MOVs, either insitu or prototype.
If such test information is not available, analytical methods and extrapolations to design-basis conditions, based on the best data available, may be used until test data at design-basis conditions become available to varify operability of the MOV.
If this two-stage approach is followed, it should be accomplished within the schedule outlined in item 1.,
and would allow for MOV testing and surveillance to proceed without excessive delay.
Testing of MOVs at design-basis conditions need not be repeated unless 4
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New Hampshire Yankee January 2, 1989 the MOV is replaced, modified, or overhauled to the extent that the licensee considers that the existing test results are not i
-representative.of the HOV in its modified configuration.
MHY Resoonse:
Yhe extended Program description will define the documentation pertaining to MOV testing to be maintained as part of required records for i
'the MOV.
The' design-basis review, to be performed in response to NRC-Recommended Action (a) will'take into account design-basis degraded voltage conditions.
New Hampshire Yankee does not plan to rely upon either prototype
- testing or the-MOVATS data ~ base to verify conservative motor operator switch settings. New Hampshire Yankee will establish conservative motor operator switch settings as described in the. response to NRC-Recommended Actions (a),
(b), (c) and (e).- New Hampshire Yankee believes that this programmatic approach obviates.the need to rely upon prototype testing or a data base to r
verify conservatively ~ set MOV switch settings.
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New Hampshire Yankee will monitor MOV performance at Seabrook Station in order to ensure that switch settings remain conservative.
The monitoring program will-utilize available information such as post maintenance test results,= surveillance. testing and diagnostic testing.
The extended Program description will= describe in more detail the sources of information to be used and methodology for monitoring long-term MOV performance.
1 New Hampshire Yankee currently employs the Motor-Operated valve Analysis and Test System (MOVATS) to diagnostically test the thirty (30)
-MOVs within the scope of the Program developed in response to IE Bulletin 85-03'at Seabrook Station. Additional equipment and methodology as described-in PSNH letter NYN-89154 (Reference (f)) is used in conjunction
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with MOVATS equipment and methodology to successfully test eight MOVs in the L
Emergency Feedwater (EFW) System which are equipped with actuators manufactured by Rotork, Inc.
_ In'1etter NYN-89154, NHY stated that it has been developing alternative
-MOV diagnostic test equipment based upon the use of strain gauges in order to further. improve the effectiveness of the Program. When site-approved, NHY: plans to employ the strain gauge method in conjunction with other traditional MOV parameter sensors to diagnostically test the thirty (30) l HOVs currently within the scope of the Program.
The application of the strain gauge or other approved equipment and methodology to MOV diagnostic testing is a change to the commitment made in PSNH letter SBN-1052 5
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L New Hampshire Yankee 1
January 2, 1989 L
[ Reference (c)) to employ only H0 VATS in HOV diagnostic testing. A summary of the strain gauge MOV testing methodology is provided in Enclosure 2 to this letter.
In the extended Program, NHY intends to utiliae any MOV diagnostic test i
l method and equipment which has been evaluated and approved by NNY.
j MRC-Racammmaded Actica fm):
A number of deficiencies, misadjnstments, and degraded conditions were discovered by licensees, either as a result of their efforts to comply j
with Bulletin 85 03 or from other experiences. A list of these conditions (including improper switch settings) is included in Attachment A to this letter for licensee review and information.
l B Y Resnonse:
No response is required to this item.
NRC-Escommanded Action th):
Each MOV failure and corrective action taken, including repair, alteration, analysis, test and surveillance, should be analyzed or i
justified and documented. The documentation should include the results and history of each as-found deteriorated condition, malfunction, test, inspection, analysis, repair or alteration. All documentation should be retained and reported in accordance with plant requirements.
It is suggested that these MOV data be periodically examined (at least every two years or after each refueling outage after program implementation), as part of a monitoring and feedback effort to establish trends of MOV operability. These trends could provide the p
basis for a licensee revision of the testing frequency established to periodically verify the adequacy of MOV switch settings (see items d.
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and j.).
For this monitoring and feedback effort, a well-structured and component-oriented system (e.
g., the Nuclear Plant Reliability
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Data System (NPRDS)) is needed to capture, track, and share the i
equipment history data. The NRC tacourages the use of the industry-l wide NPRDS, appropriately modified, for this purpose in view of the L
multiple for these data.
hBY ResDonse:
currently approved Seabrook Station programs and procedures define the requirements for evaluation and determination of corrective action for HOV failures, should they occur. These programs and procedures address repair, alterction, failure analysis, test and surveillance with respect to MOV
< failures. HOV's determined to be within the scope of the extended Program are subject to the requirements of these existing programs and procedures.
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.i' New Hampshire Yankee January 2, 1989 j
New Hampshire Yankee prepared ' Summary Report Data She9ts' for the thirty (30) MOV'e within the scope of the Program develop 9d in response to IE Bulletin 85-03.
The Summary Report Data Sheets doevuonted HOV data resulting from the design review, calculations, test results and follow-up work associated with IE Bulletin 85 03 actions. The Summary Report Data j
i Sheets for the thirty (30) MOV's within the scope of the IN Bulletin 85 03 Program were originally included with PSNH letter NYN-87137
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[ Reference (d)), have now been revised and aro being maintained onsite.
1 Summary Report Data Sheets will be prepared for the additional MOV's determined to be within the scope of the extended Program.
These Summary Report Data Sheete will be maintained onsite.
Schedule New Hampshire Yankee will, by June 30, 1990, prepare a written
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description and schedule for completion of the extended Program.
The
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extended Program description will:
l a) Identify the specific HOV's to be included within the scope of the extended Program.-
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b) Describe and provide a schedule for completion of each aspect of the extended Program. The extended Program description and rehedule will address:
- 1) The design-basis review process.
- 2) The method of determining, setting and maintaining MOV switch settings.
- 3) The program for testing HOVs to ensure their operability for the life of the plant.
- 4) Programmatic support for and documentation to be maintained in association with the extended Program.
New Hampshire Yankee will complete the following actions by June 30, 1994 for the HOVs determined to be within the scope of the extended Programs a) Perform the design-basis review.
b) Establish conservative MOV switch settings.
I c) Compare actual to conservative switch settings and resolve any deviations.
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New Hampshire Yankee January 2, 1989 d) Establish programmatic support including requirements i
for documentation for the extendsd Program.
I New Hampshire Yankee is currently evaluating the request of Generic l
Letter 89-10 that-licensees commit to:
. a).
Complete the first cycle of MOV testing by June 28, 1994.
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i b)
Establish a five year surveillance testing interval for j
MOV's within the program.
New Hampshire Yankee is. studying possibic siternatives to the above requests of Generic Letter 89-10.-
The study includes probabilistic safety assessment considerations to determine the relative nuclear-safety consequences of postulated failures of MOV's within the extended Program.
The study also evaluates the economic impact of completing the increased amount of MOV testing within the five year cycle and the alternative cycles under consideration.
In order to complete these ongoing studies, NNY plans to defer any commitment it might make regarding the schedule for completion of actual MOV l
testing under the extended Program until at least June 30, 1990.
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New Hampshire Yankee January 2, 1989 1
RNCLOSURE 2 TO NYN-90003 A StBR4ARY DESCRIPTION OF THE l
STRAIN GAUGE METHODOLOGY OF MOV DIAGNOSTIC TESTING
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New Hampshire Yankee January 2, 1989 HOV DIAGNOSTIC TESTING STRAIN GAUGE METHODOLOGY SIDMARY DESCRIPTION PROGRAM OBJECTIVES:
- 1) To develop a program which implements the use of strain gauges to accurately measure forces applied to valve shafts by valve actuators.
- 2) To ut111:e strain gauge measurements in a program which verifies that valve actuator switch settings are selected, set, e.nd maintained at setpoints which ent.ure valve operability under design-basis conditions for the' life of the plant.
RACKGROUND:
The actual measurement of torque or thrust delivered to a valve shaft by its actuator has been the focus of the industry's motor operated valve programs.
In February of 1989, New Hampshire Yankee embarked on a research effort which applied strain gauge measurement technology to measure the torsional forces' developed in valve shafts on power actuate butterfly valves. The l
effort was undertaken in order to find an improved method of testing these valves. Previous efforts, using H0 VATS equipment, required actuator removal in order to perform calibration testing, i
The results of the development project encouraged NHY to impleTent a program uhich sets position limit switches on motor operated butterfly
' valves in the Service Water System based on valve shaft torque values l
developed'during seating and unseating these valves. Expansion of this program is anticipated to include all motor operated butterfly valves.
Further research, conducted by NHY, has concluded that this methodology can l
also be applied to rising stem valves. Strain gauge measurements performed on rising stom valves provide accurate measurements of thrust quantities developed during valve seating and unseating. A program is being developed by NHY to implement strain gauge measurements as the basis for switch setpoint verification for rising stem motor operated valves.
NHY has also developed a MOV Diagnostic Signature Test System to integrate the strain gauge measurement technique with existing MOV monitoring devices i
in order to more effectively test MOV's at Seabrook Station. A brief system description is included in this report.
STRAIN GAUGE METHODOLOGY Strain gauge measurement technology has been employed in stress analysis since the early 1940s.
Strain gauges are highly sensitive devices 1
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'so New Hampshire Yankee January 2, 1989 which can give true measurements of strain developed in components being analysed.
The physical size and compact features of today's strain gauges permit their application to most valve stems or valve shafts.
Dependent upon the forces being measured, strain gauges can be selected and
-wired, in a Wheatstone Bridge configuration, to accurately measure normal strain.
The strain gauges are bonded to the valve stem or shaft (dependent upon application) when the valve is in an unstrained position. An excitation voltage is supplied and the strain gauge bridge is null balanced.
As the valve is actuated, the strain in the valve shaft changes. Due to the strain gauge being an integral part of the stem, the electrical resistance in the Wheatstone Bridge changes. This change in electrical resistance in the strain gauge bridge is directly proportional to the change in strain in the valve stem. The strain gauge measurements have been demonstrated to be repeatable and are more sensitive than LVDT measurements.
NHY has developed a test system to diagnostically assess the perfonnance of HOVs using the strain gauge methods to determine stem / shaft force along with L
other traditional actuator diagnostic sensors.
The system is personal computer-based and is capable of monitoring eight parameters during a single valve stroke.
The following is a list of those valve and actuator functions which can be monitored during a given test:
TORQUE SWITCH ACTUATIONS I
LIMIT SWITCH ACTUATIONS-TORQUE SWITCH BYPASS LIMITSWITCH ACTUATIONS VALVE STEM FORCE (tension & compression or torsional application)
ACTUATOR OUTPUT at open switch trip (LOAD CELL HONITORING)
SPRING PACK HOVEMENT HOTOR CURRENT MOTOR LOAD All parameters can be analyzed with respect to the same point in time and displays are configured to present data in engineering units for analysis j
ease.
New Hampshire Yankee intends to use this new test equipment wherever possible.
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