ML20072A936
| ML20072A936 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/07/1983 |
| From: | Puttarini D TARGET ROCK CORP. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| REF-PT21-83-901-000 E-16612, PT21-83-901, PT21-83-901-000, NUDOCS 8306130150 | |
| Download: ML20072A936 (9) | |
Text
i Twx se ra en' Target flock Corporation, P.O. Box V,1966E Broadhollow Rd., East Farrningdale, N.Y.11735 / Phone:(516) 293-3800 sunra Am curmss mast conmnAT:co Refer to: E-16612 June 7, 1983 Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Subject:
10 CFR 21 Report by Combustion Engineering on Target Rock Solenoid Activated Valves, Models 77C-001 and 77C-003 dated November 8, 1982,
- LD-82-087
Enclosure:
Al Report of Combustion Engineering and Target Rock Review of Valves at Palo Verde Site B)
Service Bulletin S. B. 8302
Dear Mr. DeYoung:
This letter is being written to provide a response to the 10 CFR Part 21 disclosure by Combustion Engineering of problems found with Target Rock Corporation supplied valves.
The charges made are:
a) incorrect valve assembly, b) significant missing parts, c) limited switch valve position indicator failures, d) valve failed to open, el valve failed to close.
Items a and b were experienced on valves supplied for qualification i
test from the site.
Since the valves had been shipped to the plant site in the 1978-1979 period and records of disassembly and reassem-bly are nonexistent or vague, the charges are unsubstantiated.
The valves examined during a random inspection at the plant site exhib-ited conditions indicative of undocumented maintenance including assembly, disassembly and cannibalization of parts. The concern associated with potential coi! loosening has been addressed in a i
Target Rock service bulletin which has been transmitted to owners l
of valves where this problem may exist.
A copy of the plant site inspection report and the Target Rock ser-vice bulletin are enclosed for your information. Further details l
or information on the inspection or design of Target Rock valves will be supplied upon request.
l l
8306130150 830607 I
l P0ft ADOCK 05CN}0529 i
S PDR
E TARorr Rocx CoRPORAMON Page 2 of 2 Letter E-16612 June 7, 1983 Items c, d and e were anomalies experienced during a NUREG 0588 qualification test undertaken by Combustion Engineering and, as such, should not have been included in a Part 21 disclosure. This position is supported by an NRC response to a direct question re-ported in the " Environmental Qualification Newsletter", Volume One, Number 12, April 1982, regarding qualification test failures. The NRC stated that qualification test failures need not be reported unless conducted on operating installed equipment where such fall-ures could result in significant safety hazards. Since the Palo Verde plant is not in operation, the valves could have been modified without a Part 21 disclosure.
In addition, it should be noted that these valves had been previously qualified to their specific order requirements and the Combustion Engineering tests were an attempt to upgrade the qualification to later requirements.
We would be pleased to discuss this further with you at your con-venience.
very truly yours, TARGET ROCK CO ORATION D. M. Pattarini Vice President, Engineering DMP/jm Enclosures i
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ENCLOSURE A TO TARGET ROCK LETTER E-16612, 6/7/83 TAHurr Hoca CouroRATION January 21, 1983 Project 822-107 f
REPORT OF CC.*/80STION ENGINEER ING AND TARGE T ROCK REVIEW CF VALVES AT PALO VERDE SITE Backcround Engineering representatives of Comoustion EngineeringtC.E.1 ano Target Rock !TRC) visited the Palo Verce Nuclear Power Plant site to examine solenoid valves in the warenouse and in pipelines.
This visit was re-questec by C.E. to ascertain the validity of charges mace in a'10 CFR Part 21 disclosure of preolems found with TRC supplied valves.
The cnarges made are:
a - Incorrect valve assemoty b - Significant missing parts c - Limit suiten valve position indicator failures c - Valve failed to open e - Valve failed to close.
Items c, d anc e were anomalies experiencea during qualification test-ing to NUREG 05e8 and as suen snoula not nave been inciucec in a Part t
21 cisclosure.
This position has prececence by an NRC response to a direct question reported in the " Equipment Qualification Newsletter",
Volume I, NO. 12, April 1982, regarding qualification test failures.
The NRC stated that qualification test failures need not ce reported unless on operating installea equipment where such failures could re-sult in a significant safety hazard. Since the Palo Verde plant is not in operation, the valves could have been modi f ied wi thout a Part 21 disclosure.
P ltems a and b were experienced on valves supplied for qualification test from the site.
Since the valves had been shipped to the plant in the 1978-79 period and recercs of disassembly and reassemoly are non-existent or vague, the charges are, for the most part, unsuostantiat-ed.
The valves examined, therefore, were viewed specifically to as-certain if the assembly was correct (a) and if there were significant missing parts (bl.
Examination Five valve samples were examined.
These included two 77L-001 model valves tone in the as-snipped condition, and one in the pipelinel; one 77L-003 mocel valve (in pipeline); and two 76HH model valves (both valves were in the pipelinel. The 77L /alves were sold to C.E.
(77L-001 is a 1" and -CO3 is a 2") and the 76HH valves to Sechtel (76HH-002 is a 1" valvel.
The Secntel supplied valves.ere being reviewec because they are also safety related active valves.
Fur-thermore, fixes needed to nave 77L valves meet fiUREG 0589 could have application to tne Bechtel valves.
Page 1 of 4
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l TARurr HOcx CORPORATION January 21, 1983 Project 822-107 The examination of the valves was conducted by representatives of C.E.
and TRC and viewed by quali ty control representatives of Becntel ISPC) and Arizona Power. LAPS).
The examination followed a disassembly and inspection procedure prepared by TRC.
The two 77L-001 valves were in-spected to TR Procedure 3709, the 77L-003 valve to TR Procedure 3710 and the two 76HH-002 valves to TR Procedure 3711.
Each procedure con-tained a check list.
The results of tne examination are included in the appendix.
The significant areas of discrepancy are as follows:
1 1 - No rubber bushing in the solenoid coil housing of both 77L-001 valves lonly) 2 - Broken saiten bracket in the line-mounted 77L-001 valve 3 - Solenoid coil insulation wasner found offset in the line-mounted 77L-001 valve 4 - Two screws (power lead terminal screws) found loose in the coil housing of the line-mounted 77L-001 valve 5 - Loose Coil - Solenoid coil insulation washers below the step on the bonnet tuce, leaving t,he coil free to move in the 77L-001 valves and the 77L-0C2 valve 6 - No 'O' ring below the solenoid assembly of the 77L-002 valve (only).
4 Discussion of Observations 1 - Missing Bushino At the time of processing the 77L and 76HH valve programc, Target Rock sas pursuing the incorporation of a rueber bushing into the solenoid c il housing.
The busning, to be +ocated at the conduit connection, would reduce the care and handling necessary to prevent wire insula-tion damage on installation of the coil into the housing. An earlier l
. change had eliminated the pipe threads on the inside corner surface of the pipe boss, which had caused some wire damage on installation.
The cast housing incorporated a radius on the inside corner of the conduit connecting boss and was designed to eliminate threads in this area. The 77L valves inspected included the cast solenoid housing de-sign and had no threads on the inside corner of the boss.
These should not have caused a problem of wire damage on installation.
A review of the TRC drawings and drawing releases indicate that the i~
solenoid assembly specified on the 77L-001 valves did not require a rubber bushing.
The valve assemoly draaing, 1-S*.*S-5-4, depicts a bushing in the solenoid coil assembIy but the P/N 300151 assembly j
released on the Target Rock release sheet for this program specifies Revision G without a bushing wnere Revision H incorporated the bush-
.ing.
i Page 2 of 4 m,
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TANGEr ItOCK CORPORADON January 21, 1983 Project 822-107 2 - Broken Switch Bracket Line-mounted 77L-001 valve.
3 - Coil Insulation Washer Found Offset Line-mounted 77L-001 valve.
4 - Two Screws Found Loose in Coil Housing Line-mounted 77L-C01 valvo.
With all these conditions found in the one assembly, it is obvious that this valve's electrical works had been disassembled and not prop-erly reassembled. With two screws found loose in the coil housing and the switch bracket broxen, the valve could not be properly tested and, therefore, could not be accepted by C.E.
inspectors.
The valve would have to have been disassemoled after snipment from TRC.
5 - Loose Coil it has always been the intention of Target Rock engineering that the coil be clamped by the use of additional insulating washers as re-quired.
Since the Target Rock drawings indicate two wasners only are to be supplied, the assembly does not provide the clamping action de-sired.
Earlier model valve assemblies called for supplying washers as required (A/R) to insure clamping and the valves supplied to Bech-tel indicate the clamping action was present.
It is also concluded that the qualification test valve, used in the program conducted for Bechtel, incorporated a clamped coil since the two valves examined (76HH-002) exhibited a properly clamped coil.
It is Target Rock's intention, therefore, to circulate a service bulletin to advise owners of valves wner e this problem may exist.
s Note also that the jam nut, holding the coil assembly in place, was found to have loosened during C.E.'s testing to NUREG 0588.
There-fore, to insure retaining the clamping action afforded by the added insulating wasners, a lock nut, in place of the jam nut, will be offered.
6 - No
'O' Ring Below Solenoid Coil Assembly This valve had obviously been disassembled without paperwork (prob-ably for welding the valve into the line).
This does not constitute evidence that TRC shipped the valves in this manner.
All 77L-003 solenoid valves should be examined for the
'O' ring.
Page 3 of a
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TAHGET HOCK CORPORATION January 21, 1983 Project 82Z-107 Conclusions 1 - No validity to claim of incorrect assemoly bs compared to TRC drawings).
2 - TJo validity to significant missing parts (as compared to TRC crawings),
it has been shown, however, that 77L valves have a loose coil (permitted by TRC crawing anc not cesired by TRC engineering). Corrective action is required.
3 - TJo requirement to announce limi t swi tch cracket failures, valve failure to open or to close unless the power plant was opera-tional.
Action Recuirec 1 - TAC to issue a service bulletin to all customers of previously supplied valves to incorporate:
a)
Additional washers as recuired to insure coi! ciamping b)
Lock nut in place of jam nut to insure coil clamping.
2 - C.E. to withcraw or amend the 10 CFR Part 21 to reflect the con-Clusions and findings of this investigation, yy J
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TAHGE*r HOCK CORPOHATION APPENDIX TR Precedure 3709 - January 6, 1983 TR Precedure 3710 - January 6, 1983 TR Proceaure 3711 - January 7, 1983 TR Prececure 3709 Data Sheets (2) - 77L-001 (S/N 21) Valve -
As shipped TR Procedure 37C9 Data Sheets (2) - 77L-001 (S/N 9) Valve -
In pipeline TR Procedure 3710 Data Sheets (2) - 77L-OO3 (S/N 41 Valve -
In pipeline TR Procecure 3711 Data Sheets (2) -76HH-002 (S/N 7) Valve -
In pipeline TR Procedure 3711 Data Sheets (2) -76HH-002 (S/N 51 Valve -
In pipeline
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Target Rock Corporation.1966E E oadhollow Road. East Farm:w;oale f er.v iork 11735 /Fnone '5t612931800 February 2, 1983 82Z-107 s
q ADDENDUM NO. 1 TO REPORT OF COMBUSTIO:2 ENGINEERING & TARGET ROCK REVIEW 0F VALVES AT PALO VERDE SITE (CATED JA::CARY 21, 1983) 1.0 SCOPE This addendum adds the following information concerning relays to the report listed above.
2.0 ADDITIONAL INFORMATION 2.1 Add Item No. 7 to the "E:C 4I:iATION" Section:
7.
The 77L-003 valve had KR11DG 110 VDC relays instead of the KAllDG 110 VDC relays as called out on the valve assembly drawing.
The two 77L-001 valves had the KAllDG 110VDC relays as required and the 76HH-002 valves did not require relays.
2.2 Add Item No. 7 to the " DISCUSSION OF OBSERVATIONS" Section:
7.
The KRllDG 110VDC relay is equivalent to the KAllDG J 10VDC relay in form, fit and function. The only difference is that the l
KA11DG 110VDC relay uses molded phenolic as the insulating material (initial resistance to ground is 100 megaohms minimum),
while the KRllDG 110VDC relay uses laminated phenolic (initial resistance to ground is 1000 megaohms minimum).
2.3 Add Item No. 1 (c) to " ACTION REQUIRED" Section:
Ic. The KRllDG 110VDC relay shall be identified as being an acceptable alternate to EAllCG 110VDC relay. The two relays are equivalent in form, fit and function.
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ENCLOSURE B TO TARGET ROCK LETTER E-16612, 6/7/83 O b S. B. 8302 E
Date:
4-6-83 R
V PRODUCT IMPROVEMENT SOLENOID OPERATED VALVES s
C ALL MODELS WITH UNPOTTED SOLEMOIDS ADDING SOLENOID ASSEMBLY INSULATING WASHERS B
1.
GENERAL INFORMATION.
A. Description. This Service Bulletin provides a method for E
checking axial travel of the solenoid assembly and, if b
found, to obtain the parts necessary to eliminate it.
' {;
B. Effectivity. The work called for by this Service Bulletin is applicable to all Solenoid Operated Valves with unpetted solenoids.
C. Reason. To eliminate the possibility of axial travel of the T
solenoid coil inside the solenoid housing on unpotted solenoid asserblies.
I D. Compliance. It is recommended that the work outlined herein be accomplished while the Solenoid Operated Valve is in storage or when the system is off-line as between fuel loadings.
E. Material. A modification kit is needed to perform the requirements of this Service Bulletin. This kit will contain the pa'rts and instructions necessary to perform this procedure. Centact the Field Service Department, Target Rock, for kit information and detailed instructions.
l Written by:
Date':
-/'t-O
- d. H. Schulman/ echnical Writer Approved by: f h/
~
Date:
F - / l - d.3 D. M. Patdarini, Vice Pres., Engineering J
Tar get Rook
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Target Rock Corporation,1966E Broadhollow Road, East Farmingdale, New York 11735
PREPARED BY TARGET ROCK CORPORATION PAoE 0'
2 2
DATE EAST FARMINGD ALE LONG ISLAND, N. Y.
nsPony APPROVED ev S.B. 8302 rs CATE F. Special Tools. None required.
G. References. Engineering investigations and field service recommendations.
H. Publications Affected. This Service Bulletin shall become a part of and be filed with the applicable Technical Manual (s). Reference to this Service Bulletin shall be made when ordering spares.
2.
INSTRUCTIONS.
A. Inspect the Solenoid operated valve for axial travel as follows:
(1) Provide an axial lifting force of 50 to 100 counds to the solenoid housing. Check to see if the solen 6'id housing moves.
Movement of the solenoid housing indicates axial travel of the solenoid coil inside the housing.
(2) If axial travel is evident, obtain a modification kit and perform the procedure contained in the instructions included with the' kit.
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B.
It is recommended that a modification kit be kept on hand.
Additional modification kits can be obtained, as required, from the Target Rock Corporation, Field Service Department.
Field service assistance may be obtained from the Target Rock Corporation at current rates.
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