ML20073P797

Affidavit of Ja Rigert Re Util Compliance W/Ie Bulletin 83-03, Check Valve Failures in Raw Water Cooling Sys of Diesel Generators. Certificate of Svc Encl

ML20073P797
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/21/1983
From:	Rigert J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20073P793	List: ML20073P791 ML20073P794 ML20073P797
References
IEB-83-03, IEB-83-3, ISSUANCES-OL, NUDOCS 8304270255
Download: ML20073P797 (6)

Text

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

(Shoreham Nuclear Power Station- )

Unit 1) )

Affidavit of John A. Rigert.

1. My name is John A. Rigert. I am employed by Long Island Lighting Company as the Section Head of the Systems Engineering Section of the Nuclear Engineering Department. In this capacity, I supervise the development of Shoreham's inservice testing program for valves.

2. I am familiar with I&E Bulletin 83-03, " Check Valve Failures in Raw Water Cooling Systems of Diesel Generators," March 10, 1983. I&E Bulletin 83-03 8304270255 830422 PDRADOCKOSOOOg C

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establishes requirements for operating plants for inservice testing of check valves in the flow path of cooling water for diesel generators from intake to the discharge.

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3. .In a letter of April 1, 1983 from Richard W. Starostecki, Director of the Division of Project and Resident Programs, to M. S. Pollock, the NRC requested that LILCO, because its testing plan had already undergone licensing review, respond to Bulletin 83-03. (Attachment 1). Accordingly, LILCO will provide to the NRC a written response to the six requirements that- Bulletin 83-03 imposes upon operating plants.

4. As a result of the licensing review of Shoreham's draft valve inservice testing plan in November-December 19 82, all six Service Water system diesel generator cooling water check valves at Shoreham are included in l^

Shoreham's inservice testing program. Thus, Shoreham l

l already complies with the first requirement of Bulletin 83-03,

5. Currently, the inservice valve testing program at Shoreham specifies quarterly verification of both forward and reverse flow operability. This testing complies with the second requirement of Bulletin 83-03, which allows flow tests to confirm integrity of valve internals.

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6. LILCO will perform the third requirement of Bulletin j 1

83-03 -- initial valve integrity verification -- prior to fuel load. The written report to the NRC describing the inservice testing program and the valve integrity l verification procedure methods will be performed within 90 days of April-1, 1983, pursuant to the fourth requirement of the Bulletin. LILCO will also submit, in a timely fashion, the written report necessary to comply with requirements 5 and 6.

C/

John A Rigert STATE OF NEW YORK )

COUNTY OF SUFFOLK )

Subscribed to and sworn before me this 21st day of April, 1983.

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DocketNo.50-32d 1 Long Island Lighting Company ATTN: Mr. M. S. Pollock Vice President - Nuclear 175 East Old Country Road Hicksville, New York 11801 Gentlemen:

Subject:

IE Bulletin No. 83-03: Check Valve Failures in Raw Water Cooling Systems of Diesel Generators This refers to the subject Bulletin issued March 10, 1983. Construction Permit Holders were not required to respond to the Bulletin. However, since the licensing review of the Shoreham In-Service Test Program has already been performed and since Shoreham is approaching a decision on an operating license, you are requested to provide a written response to the subject Bulletin, addressing Items 1 through 6.

With regard to Item 3, you are requested to perform the initial verification be-fore fuel load. With regard to Item 4, your written response may be submitted within 90 days of the date of this letter vice the date of the Bulletin.

Your cooperation with us in these matters is appreciated.

Sincerely,

& fhn.- l Richard W. Starostecki, Director Division of Project and Resident Programs cc:

J. Rivello, Plant Manager J. L. Smith, Manager of Special Projects Edward M. Barrett, Esquire Jeffrey L. Futter, Esquire T. F. Gerecke, Manager, QA Department Public Document Room (PDR)

Local NuclearPublic Document Safety Information Room (LPDR) (NSIC)

Center NRC Resident Inspector State of New York Shoreham Hearing Service List L.Brenner(ASLB)

J. Carpenter (ASLB)

P. Morris (ASLB)

4 55 INS: No. 6835

..[ 005 N2.: 3150-0097 .

Expirstien Det9: 11/85 l IEB 83-03 l UNITE 0' STATES NUCLEAR REGULATORY COPWISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C. 20555

- March 10, 1983 l

r IE BULLETIN NO. 83-03: CHECK VALVE FAILURES IN RAW WATER COOLING SYSTEMS OF DIESEL GENERATORS Addressees:

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All nuclear power reactor facilities holding an operating license (OL) for

!- action and all those holding construction permits for information.

Purpose:

! The purpose of this bulletin is to (1) notify licensees'and construction permit holders about numerous incidents of failed check valves in systems important to safety; (2) inform licensees of a sigrificant generic matter for which addi-tional NRC action is anticipated; (3) to require appropriate surveillance and testing of check valves in raw water cooling systems for diesel generators. A response to this bulletin is required from all nuclear power reactors holding an OL as discussed below.

Description of Circumstances A review of available operating experience, data and licensee event reports (LERs) shows that numerous check valve failures have occurred in systems important to safety in nuclear power plants. A series of IE generic communi-cations (listed in Table 1) has been issued which describes a broad range of check valve failures involving various designs, causes, and applications.

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The NRC has evaluated check valve failures in consideration of the need tq i

request generic action by licensees. The focus of this bulletin is directed primarily at the failure mode of disassembly or partial disassembly of check valve internals. For example, the check valve disc becomes separated from the hinge.

Title 10 of the Code of Federal Regulation, Section 50.55a(g) requires testing of valves whose function is required for safety. This is implemented by appli-cation of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.

However, our analysis of operating experience with check valves has shown that disassembly and partial disassembly of check valve internals is not effectively found by Section XI testing as it is implemented at this time. Tests performed for Section XI or Technical Specifications usually require only forward flow through check valves. These tests may not detect internal check valve failures unless the disassembled parts move to block flow during the test.

This bulletin is expected to be part of a generic response to check valve failures which will result in improved testing to ensure operability and to improve reliability of check valves. In addition to the generic

MoovJin

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(. IEB 83-03 March 10, 1983

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communications issued by IE, the NRC Dffice of Nuclear Reactor Regulation requires that licensees consider all check valves in systems important to safety for inclusion in the ASME Section XI Pump and Valve Inservice Testing Programs. Although most check valves in systems important to safety are included in current IST program reviews, most are not required to be reverse flow tested or disassembled to detect gross internal failure because licensees have, identified each of these valves as having a single safety function: the

• cpen position. However, forward flow tests to verify the open position are inadequate for detecting internal disassembly. Effective check valve testing techniques are necessary to the development of a more meanigful and productive  ;

IST program. Operating experience provides a basis for determination of what areas of IST check valve surveillance need to be improved.

The specific requirements of this bulletin stem from analysis of check valve failures in the raw cooling water supply to the diesel generators at the Dresden and Quad-Cities nuclear power stations and other events which are described in Table 1. At Dresden and Quad-Cities, it was found that six of six check valves in the raw cooling water systems for the diesel generators had failed with the disc becoming detached from the pivot arm. Many of the failures described in the generic communications listed in Thble 1 also involved detached discs. The Dresden event is described in detail in IE Information Notice No. 82-08. In summary, the event involved failure of the check valves in the raw water cooling systems for the diesel generators which resulted in interruption of cooling water flow to the diesel generator heat cxchangers and subsequent inoperability of the diesel generators. The Dresden check valve failures rendered two diesels inoperable at the same time when the valve discs moved to the valve outlets and blocked flow. However, the true cause of flow blockage was not determined until almost one month later. All three Diesel Generator Cooling Water Pump (DGCWP) systems at Dresden Units 2 and 3 involved check valve failures which were discovered during a short period of time. These failures were not identified by operator observations and instrument readings during diesel generator surveillance tests, but were discovered by direct inspection of the internals of the valves. It is not known how long these check valves were broken before their condition was detected.

The broken valve discs were found to be free to move within the valve Ipodies cnd may have been that way for some time before coming to rest in a polition which restricted flow enough to cause the diesels to trip on high engine temperature. The subject check valves are horizontally mounted Crane 8-inch, cast iron swing check valves, Type 373, and have a pressure rating of 125 psi.

Because of the similarity between the Dresden Units and Quad-Cities Units, .

NRC Region III requested that Commonwealth Edison inspect the DGCWP discharge

• check valves on the Quad-Cities Units on a schedule consistent with the avail-ability of valve parts and the availability of the DG units. The DGCWP systems at Quad-Cities were inspected and all three DGCWP discharge check valves were

• found with the discs separated from the pivot arms.

At Quad-Cities, the failures remained latent; although the discs were lying free in the valve body, they did not move to the outlet and block flow. The DGCWP discharge check valves at Quad-Cities were also Crane, 8-inch, swing check valves, Type 373. However, the Quad-Cities valves and the Dresden valves were not identical. The Quad-Cities valves had larger, more bulbous valve bodies and slightly different internals.

IEB 83-03 4*- March 10, 1983 -

Page 3 of 5 4

Forallva]ves,themostdominantfailuremodewasduetoacombinationof abrasive and corrosive wear of valve internals. In particular, the valve disc was held to the pivot are by a stud with washer and nut. Apparently, flow conditions at the valves were such that the discs' vibrated (fluttered) causing local abrasive wear:st the are bore of the hinge where it joins the disc. This

. . same ac tion also resulted in severe degradation of the washer used to retain the disc on the hinge, and once the degree of degradation at the hinge bore and washer was sufficient, the two components separated. The stud and nut wore such that the stud and nut assembly pulled through the enlarged hole in the pivot arm and became detached.

In the case of the Dresden Unit 2 valve, the valve disc remained barely. attached to the pivot arm and the arm had broken at its hinge to the valve hinge pin.

In this case, abrasive / corrosive wear was found to have occurred at the hinge pin bore. All of the failed valves showed wear at this location. The degree of degradation varied from very slight in the Quad-Cities 1/2 hinge As to extreme plants in the Dresden Unit 2 hinge which had fractured at this location.

age, failure modes of these types may be expected to become more prevalent.

The bulletin focuses on check valve failures in the raw water cooling system of diesel generators for the following reasons:

(1) Six of six check valves in these systems at Dresden and Quad-Cities failed with the potential for interrupting flow of cooling water to the diesel generators.

(2) Both diesels on'Dresden Unit 3 tripped on overtemperature due to lack of cooling water f. low and the unit was without emergency power.

(3) The cause of the lack of raw cooling w)ater flow to the Dresden U dedicated diesel (failed check valves was not discovered for almost one month following the event despite numerous test and surveillance procedures and was attributed to other causes. The condition of the swing diesel and the unit 2 dedicated diesel check valves at Dresden was not discovered until more than one month after the initial event.

(4) None of these check valves was included in the plant IST program at the time of the event. Since the event, the NRC Office of Nuclear Reactor Regulation has added these valves to IST requirements for plants currently being reviewed.

(5) Even if the valves had been in the IST program, it is doubtful if the normal forward flow test would have discovered these latent

. fa6 lures except by chance, as occurred at Dresden. The failures were finally discovered by direct inspection of valve internals.

It should be noted that the popular use of swing check valves in safety related Pl ant fluid systems considerably expands the scope of concern Licensee for event check reports valve maintenance and testing beyond diesel cooling systems.

indicate that other systems important to safety have experienced failures of check valves which are not included in the IST program and have not been

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• Page 4 of 5 .

discovered during testing. Other licensee event reports indicate that for those valves which are not leak tested, both the type and. frequency of testing may not be adequate to detect valve failure. Maintenance and IST programs should be reconsidered in light of detecting and preventing gross and multiple check valve failures that can defeat functions of systems important to safety.

This includes conceras both for check valve opening and closure.

Required Actions For Holders Of Operating Licenses:

Licensees are requested to review the plant Pump and Valve In-Service g 1.-

Test (IST) program required by Section XI of the ASME Boiler and Pressure Vessel Code and modify it if necessary to include check valves in the flow path of cooling water for the diesel generators from the intake to the i discharge. Those portions.of the cooling water system which do not  !

directly supply the diesel may be excluded from this review. For example, l f if the cooling water to the diesel is supplied by the normally operating 1 service water system, the loop of piping to the diesel from the service water piping and back must be considered, but not the complete service  !

water system. For those cooling water systems which come into operation )

l only upon demand for diesel cooling, all portions of the system which are '

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- required to change state must be reviewed.

2. For the valves described in (1)'above, licensees are requested to examine the IST program and modify it if necessary to include verification proce-dures that confirm the integrity of the valve internals. This may be accomplished by using both a fontard flow and a back flow test or by valve --

disassembly and inspection. Other equally effective means of assuring integrity of the valves may be used. A reasonable schedule for the test ,

of these valves shall also be included in the IST program. ,

3. Licensees are requested to perform initial valve integrity verification procedures for the valves identified in (1) above using the methods described in (2) above, to be completed by the end of the next refueling outage commencing after April 1, 1983.. _

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4. Licensees are requested ubmitareporttotheNRdwithin90daysof the date of this Mhtgo, which lists the valves identified in (1) above and describes the valve integrity verification procedure methods and schedule identified in (2) above. This report should include the history of any known previous failures of these valves at your plant.

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! 5. Licensees are requested to submit a report to the NRC within 90 days of

• I completion of the results of the initial valve integrity verification -

I procedure performed in accordance with (3) above. For those valves which

-are found to have undergone either partial or complete disassembly of

• valve internals, a description of the failure mode should be included.

6. The written reports required shall be submitted to the appropriate Regional Administrator under oath or affirmation under provisions of Section 182a, Atomic Energy Act of 1954, as amended. The original copy of the cover i

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.IE8 83-03

-t March 10, 1983

• Pag 5 of'S ,

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let,ters and a copy of the reports shall be transmitted to the U. S.

Nuclear Regulatory Commission, Document Control Desk, Washington, D. C.

20555 for reproduction and distribution.

Required Actions for Holders of Construction Permits: l None. This information is provided to holders of Construction Permits to These programs will provide guidance in preparing their proposed IST programs.

be reviewed during the ifcensing process.

Although no specific request or requirement is intended, the following information would help the NRC evaluate the cost of implementing this bulletin:

• Staff time to perform requested valve integrity verification procedures Staff time to prepare written responses This rquest for information was approved by the Office of Management and Budget under clearance number 3150-0097 which expires on November 1985.

Comments on burden and duplication should be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D.C. 20503.

If you have any questions regarding this matter, please contact the Regional Administrator of the NRC Regional Office or the technical contact listed below.

J =^ *

/ ,

Richard C. D/tYoung, rector OfficeofIn#ectionandEnforcement I.

Technical

Contact:

George F. Lanik, IE (301) 492-9636 l

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Attachment:

. 1. Table 1 - IE Generic Communications

2. List of Recently Issued IE Bulletins

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_ _ _ ._-_ _ - ~ . - _ _ _ _ _ _ . . - _ -_ _ _.

f it? LILCO, April 22, 1983 o- >

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V CERTIFICATE OF SERVICE 4

In the Matter of-LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322 (OL)

I hereby certify th'at copies of LILCO's Response.to SC's Motion to Reopen Record on Suffolk County Contention'll and Report on Discussions Regarding the Substantive and Procedural Aspects of the Motion and on the Settlement Status of SC Contention 11 were served this date upon the following by first-class mail, postage prepaid.

Lawrence Brenner, Esq. Secretary of the Commission 1

Administrative Judge U.S. Nuclear Regulatory ,

Atomic Safety and Licensing Commission

Board Panel Washington, D.C. 20555 U.S. Nuclear-Regulatory Commission- Atomic Safety and Licensing Washir;gton, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory '

Dr. Peter A'. Morris Commission Administrative Judge Washington, D.C. ~20555 g Atomic Safety and-Licensing ,.

Board Panel .

Atomic Safety and Licensing '

U.S. Nuclear Regulatory Board Panel ~

Commission U.S. Nuclear Regulatory l Washington, D.C. 20555 Commission l .

Washington. D.C. 20555 l Dr. James H. Carpenter L Administrative Judge Daniel F. Brown, Esq.

! Atomic Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel l Commission U.S. Nuclear Regulatory

[ Washington, D.C. 20555 Commission Washington, D.C. 20555

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,. Bernard M. Bordenick, Esq. David J. Gilmartin, Esq.

David A. Repka, Esq. Attn: Patricia A. Dempsey, Esq.

U.S. Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C. 20555 Veterans' Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq. Gtephen B. Latham, Esq.

Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq. 33 West Second Street Kirkpatrick, Lockhart, 11111, P. O. Box 398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W. Ralph Shapiro, Esq.

Washington, D.C. 20036 Cammer and Shapiro, P.C.

9 East 40th Street Mr. Marc W. Goldsmith New York, New York 10016 Energy Research Group 4001 Totten Pond Road James Dougherty, Esq.

Waltham, Massachusetts 02154 3045 Porter Street Washington, D.C. 20008 MHB Technical Associates 1723 Hamilton Avenue Howard L. Blau Suite K 217 Newbridge Road San Jose, California 95125 Hicksville, New York 11801 Mr. Jay Dunkleberger Matthew J. Kelly, Esq.

New York State Energy Office State of New York Agency Building 2 Department of Public Service Empire State Flaza Three Empire State Plaza Albany, How York 12223 Albany, New York 12223 l

b Mhh '

Daniel O. Flanagan (

l

. Hunton & Williams l

707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 I

l DATED: April 22, 1983 l