ML20132D218
| ML20132D218 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/09/1985 |
| From: | Barry Miller BROOKHAVEN NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20132D087 | List: |
| References | |
| NUDOCS 8507160128 | |
| Download: ML20132D218 (19) | |
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MILLSTONE NUCLEAR POWER STATION, UNIT 3 DOCKET NUMBER 50-24S' /23 PUMP AND VALVE OPERABILITY ASSURANCE AUDIT TECHNICAL EVALUATION REPORT PREPARED BY BRUCE MILLER AND RUDY H0 DOR BROOKHAVEN NATIONAL LABORATORY APRIL 9, 1985 e
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Summary The pump and valve operability review team (PVORT) from Brookhaven National Laboratory (BNL) and representatives of the Equipment Qualification Branch (EQB)of the NRC conducted an on-site audit of the pump and valve oper-ability assurance program at the Millstone Nuclear Power Station. Unit 3 dur-ing the week of March 4, 1985. Ten components, three in the Nuclear Steam Supply System (NSSS) (one supplied by the NSSS vendor, two by the Architect Engineer); seven in the balance of plant systems (BOP); and the central files were audited.
On the basis of the observation of the field installation, review of the qualification documentation responses provided by the applicant to PV0RT, inquirjes and the Safety Evaluation Report (SER) open items it is concluded that the applicant has developed and implemented a program addressing pump and valve operability.
Upon satisfactory resolution of the specific and generic concerns out-lined in this report, it is concluded that the pump and valve operability as-I surance program for the. Millstone Nuclear Power Station, Unit 3 will meet the applicable portion of GDC 1, 2, 4, 14, and 30 of Appendix A to 10 CFR 50, Appendix B to 10 CFR Part 50 and Appendix to 10 CFR Part 100 f
1.
Introduction To assure that an applicant has developed and implemented a program re-garding the operability qualification of safety-related pumps and valves, the EQB performs a two-step audit. The first step is a review of Section 3.9.3.2 of the Final Safety Evaluation Report (FSAR) for the description of the appli-cant's pump and valve operability assurance program.
The information provided in the FSAR, however, is general in nature and not sufficient by itself, to e
provide confidence in the adequacy of the licensee's overall program for pump I
and valve operability qualification. To provide this confidence, the PVORT, consisting of staff from BNL and the NRC, conducts an on-site audit of a small
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representative sample of safety-related pumps and valves and their supporting qualification documentation.
The criteria by which the audit is performed is described in Section 3.10 entitled, " Seismic and Dynamir. Qualification of Mechanical and Electrical Equipment" of the Standa' d Review Plan. Conformance with SRP 3.10 is required r
in order to satisfy the applicable portions of General Design Criteria (GDC) 1, 2, 4, 14, and 30 of Appendix A to 10 CFR 50 as well as Appendix B to 10 CFR 50 and Appendix A of 10 CFR 100.
2.
Discussion 1
The EQB staff in performing the first step of the audit, reviewed the methodology and procedures of the pump and ' valve operability assurance program contained in Section 3.9.3.2 of the FSAR. As a result of this review, six specific areas were identified as needing further clarification and were docu-mented in the SER dated February 14, 1984 The SER concluded that the appli-cant had in general, defined a pump and valve operability assurance program but it was not possible to determine the adequacy of the overall program with-4 i
out a site audit.
The on-site audit, second step, was performed by the PVORT during the week of March 4, 1985. The purpose of this step was (1) review the adequacy of the overall program, and (2) determine the extent that Northeast Utilities (NU) meets the criteria of Section 3.10 of the Standard Review Plan (SRP).
A sample of three components in the nuclear steam systems and seven components in the BOP systems were selected to be audited; this included two surprise items.
(Note: two of the three nuclear steam system components are supplied by the Architect Engineering Firm and one by the reactor supplier.)
The site audit also reviewed Northeast Utilities response to the six areas of concern identified in the February 14, 1984 SER. Table 1 identifies the equipment i
audited and the audit findings. Table 2 lists the six areas identified as j
needing further clarification in the February 14, 1984 SER and their present
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status.
The on-site audit includes a plant walkdown inspection of the as-built configuration and installation of the equipment, a review of the normal, acci-dent, and post-accident conditions under which the equipment and systems must operate, the associated fluid dynamic loads, and a review of the qualification documentation (status reports, test reports, analysis, specifications, sur-veillance programs, and long-term operability program (s) etc.).
3.
Specific Concerns As a result of the audit, three generic concerns were identified re-quiring verification by the applicant prior to fuel load, they are:
1.
All pumps and valves important to safety have had their required pre-operational tests completed.
2.
All pumps and valves important to safety are qualified and opera-tional for normal, accident, and post-accident operating conditions.
3.
Confirmation that new loads resulting from a postulated Loss of Coolant Accident (LOCA) or analysis of as-built conditions applic-able to pump (s) and valve (s) important to safety do not exceed those loads originally used to qualify the equipment.
Additionally, the PVORT conducted a brief review of the applicant's documentation system by requesting, at short notice, test reports and related qualification documentation for a particular component.
NU response to this request resulted in a walk-through of their documentation retrieval capabil-ity. The findings of this effort were favorable in that the documents re-quested were eventually found. However, it became very apparent that the NU system is cumbersome and has possibly overwhelmed them.
Section 3.1 will highlight the evaluation / audit process for the indi-vidual components.
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3 MSS *CTV27A - inch Single Seated Globe Valve (B0P) Surprise Item This valve is a Main Steam Isolation Valve located in the main steam valve building at approximately the 68 foot 6 inch elevation.
The function of this valve is to close immediately in the event of a rupture in the main steam piping either upstream or downstream of the valve.
This valve is manufactured by Sulzer Brothers Limited of Winterthur, Switzerland.
The actuation of the valve is achieved by solenoid values t$at control the flow of the operating medium to a piston chamber on tire valve.
By regulating the flow path through the redundant control lines and solenoid valves the working fluid. operates the valve.
Extensive testing and analysis have been performed on this model valve.
Flow interruption capability has been demonstrated by means of tests on -
a smaller valve with a seat area equal to 80% of this valve.
Additional analysis was then performed utilizing results of the tests, similarity of the valves, and Millstone piping geometry to further demonstrate the capability of the valve to close against flow in either direction.
In addition, the valve assembly was manufactured and qualifed in accordance with ASME, ANSI, ASTM, IEEE (323, 344, 382), and NUREG-0588.
The qualification documentation addressed PVORT concerns regarding internal / external leakage, the various analyses and tests performed, and the establishment of acceptance criteria.
The applicant has demonstrated operability qualification for this component.
3.2 3 MSS *RV22A - 6" x 8" x 8" Dual Outlet Safety Valve (80P)
This main steam safety valve is located in the Main Steam Valve Build-ing at approximately the 68-foo,t elevation.
Its function is to prevent overpressurization of the main steam line.
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C In reviewing the qualification documentation, a discrepancy was initially revealed between a Stone and Webster (AE) calculation and Dresser (valve manufacturer) regarding the natural frequency (f ) of the valve.
The n
specification called for a fn > 35 Hz, Dresser qualification reports indi-cate 36.9 Hz in Revision 0 and 37.3 Hz in Revision 1, while Stone and Webster calculations determined fn to be 27.5 Hz.
In gesponse to the question re-garding the discrepancy, a calculation was performed by Stone and Webster that concluded that the natural frequency is indeed greater than 35 Hz confirming the results of Dresser.
This satisfied the staff's concerns.
In response to the inquiry regarding valve testing and verification of the set point of the valve, a discussion took place regarding Millstone's overall preventive' maintenance program and commitment to Section 11 of ASME.
The r,esult of this discussion addressed the concerns in this area and the overall program being established by NU.
The qualification documentation and resulting discussions also ad-i ~
dressed inquiries regarding leakage criteria, analysis, testing performed, and boundary condition utilized in qualification and acceptance.
As a result of the plant walkdown, it was observed that an identical 4
. valve (RV-25A) was tagged for a change in bolting.
In response to why this was being undertaken and did it apply to RV-22A, the applicant produced a change order to replace the bolts and indicated that the change order had been implemented for RV-22A.
The applicant has demonstrated operability qualification for this component.
3.3
~ 3 MSS *MOV-18A inch Motor Operated Gate Valve (80P)
This valve's function in the Main Steam system is to isolate the pres-l sure relieving and pressure relieving bypass valve located in the main steam e
system.
The valve is located;in the Main Steam Building, at approximately the 69-foot elevation. J
c Reviewing the stress analysis revealed that the maximum AP utilized in toe analysis was 1,106 psi.
However, the long form and data sheet summarizing input used in the stress analysis indicates that the maximum AP is 1,185 psi.
In response to this discrepancy, NU reports that the design specification gave a design pressure of 1,185 psi and a maximum differential pressure of 1,106 psi, and that it would have been more appropriate to use the 1,185 psi num-ber. However, the vendor calculations were reviewed using design pressure and it was found to have a negligible effort.
Stress increases in critical sec-tions were: yoke stress, increased by 283 psi and bolt stress, increased'by 666 psi. NU also pointed out that:
(1) significant margins existed between the code allowables and the resultant stress and (2) the operating pressure of.
the system is 1,092 psig.
In response to inquiries, it was then discovered that the downstream
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valves in this cystem had also used 1,106 psi in their analysis.
The staff in reviewing the stress analysis of MOV18A, and the boundary conditions utilized 4
in the qualification documentation, along with a commitment by NU to evaluate this valve and the downstream valves to ensure that they are capable of with-standing a AP of 1,185 psi find.that they have addressed the staff concerns on this area.
In response to an inquiry concerning the capability of the actuator under degraded voltage conditions (questions also asked from a generic stand-point for all motors), NU made a brief presentation.
The response indicated that all motors, pump and valve, that are classified as' class IE have been procured specifying operability with a 70% (degraded voltage) of rated voltage starting requirements. All pump / motor sets (class IE) have or will be tested at both 100% and 701 rated voltage starting requirements.
This response
' addresses the concerns in this area.
Also addressed were questions regarding torque / force requirements of actuator, closure time, safety function, temperature transients, operability, qualification testing, and analysis.
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d The applicant has demonstrated operability qualification for this component.
3.4 3FWA* PIA - Auxiliary Feedwater Pwng This motor driven / horizontal centrifugal-auxiliary feedwater pump is located in the Engineering Safety, Feature Building at approximately the 21-foot elevation.
As a result of the plant walkdown, it was observed that rework had been or was being performed on the pump.
This rework included changing bearings due to material problems identified by the manufacture and replacement of RTD probes. The explanation for these changes and additional Inspection Report Finding and Non-conformance and Disposition reports related to the pump satis fied the concerns related to this rework.
NU indicated that the manufacturer's pump curves, system pump curves, and bearing temperature history are incorporated into the initial site quali-fication criteria for this assembly. A brief discussion also revealed a 12%
margin was incorporated into sizing calculation (12179-210P) and that the specification requires that during pump performance testing, that the head shall be within +13% of the guaranteed head, f
l The applicant reports that qualification will be farther ensured during l
pump performance. testing. This address satisfied concerns in this area.
l In response to questions regarding the introduction of service water into the pump, the applicant stated that there is potentially an infinite l
source of safety grade water supply available (meets Reg. Guide 1.139) to the i
system, prior to introducing service water to the system.
The subsequent dis-cussion presented by NU in this area satisfied all concerns.
A discussion was also provided by NU on the development of pump performance procedures for this component.
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c The applicant has demonstrated operability qualification of this component.
3.5 3SWP*P1AC - Service Water Pump Service water pump PIA was originally se.lected for this audit.
How-ever, due to performance problems it was removed for maintenance and pump IC was audited.
Both deep draft pumps are located in the circulating and Service Water Pump House at the 14 foot 5 inch elevation.
The applicant was presented with an NRC letter dated April 11, 1983 from J. P. Knight to T. M. Novak regarding the long-term operability of deep draft pumps. This NRC letter contained a suggested procedure, generated by the EQB, for detecting problems with deep draft pumps.
The applicant was asked to indicate how closely they were following the suggested procedure.
The resulting presentation and discussion indicated that for the service water pumps and containment recirculation' pumps the NU startup program meets the in-tent of the EQB guidelines.
In reviewing the results of the staroup testing on the service water pumps, it was observed that the acceptance criteria were not met for three separate issues. NU had already initiated an investigation into these con-cerns but.was not able to present the results at this time.
Therefore, as a result, three open items exist on this component that require an explanation of their resolution by the applicant.
They are:
1.
The pump curves generated during startup testing do not meet the criteria generated by the vendor shop curves or the system design Curves.
2.
In comparing the rundown time for each pump with the time for the other pumps, the resulting values were not within the 20% specified i
in the procedure.
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For pumps B, C, and D, the calculated motor horse power was not within 10% of the pump horse power determined from the performance 4
Curves.
As a result, it is concluded that the applicant has not demonstrated operability qualification of the service water. pumps.
3.6 3RSS*P1A - Containment Recirculation Pump (BOP) l This deep draft pump is located in the Engineering Safety Features Building at the 49-foot elevation.
Its safety function is to start in re-sponse to a CDA signal, plus a 220 second time delay.
Initial activity is containment spray followed by long-term core cooling.
The pump is qualified by a combination of analysis and testing.
Deep draft pumps have been identified in the July 1979, IE issued Bulletin 79-15 as 4
j having the potential for problems with long-term operability.
Consistent with f,,
this, NU was asked to respond to the question of how closely they follow NRC's suggested guidelines for deep draft pumps issued in April of 1983.
Stone and Webster personnel responded stating that having reviewed the guidelines, their conclusion was that the NU startup program meets the intent of the guidelines i
for the Containment Recirculation Spray Pump (RSS) as described below.
)I The reviewer's concur with NU's conclusion that the startup program meets the intent of the NRC guidelines, however, the results of the tests will determine the pumps capability for long-term operation.
The startup program provides for the pumps to be started in a con-trolled environment with various pump and motor paramaters being constantly monitored.
The pumps are operated over the entire range of their performance curves to verify that pump performance is in accordance with specified para-meters. Specific data recorded includes flow, suction pressure discharge pressure, pump 1 motor vibrating, and bearing tempr.ratures.
The acceptance 2
criteria for pump / motor vibrati,on is in accordance with industry standards and i -
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vendor recommendations. During the startup program, baseline vibration signa-tures are obtained for future reference in accordance with the Millstone 3 ISI program.
While reviewing the PVORT long form, it was determined that the infor-mation listed for pump height and motor dimensions was incorrect and that clarification regarding motor qualification and maintenance ' interval was re-quired.
Stone and Webster personnel provided a satisfactory revised long form.
The question regarding the capability of the driver to handle the load torque at 5,000 gpm and reduced voltage (70%) was addressed by Stone and Web-ster personnel who produced curve number 66-3889 demonstrating this capability.
Another concern identified was the proximity of the calculated critical speed to the operating speed (operating 1,170 rpm, critical 1,185 rpm).
Stone and Webster seismic dynamic personnel later determined that the 1,185 rpm critical speed was incorrect and revised it to 468 rpm.
During the walkdown inspection, the PV0RT team observed a tag affixed to the junction box bearing the number IR #X5A00011. After some difficulty in locating the inspection report, a copy of the report was produced by NU.
The discrepancy, which had been corrected, was a missing junction box cover.
A trip report by NU and Stone and Webster concerning factory acceptance i
testing of the pump at Bingham Willamette was reviewed and contained findings upon disassembly of the pump, of damage to the bowl and column bearings.
Stone and Webs.ter personnel included a pump consultant who was present during the tests indicated that the problems were due to misalignment caused by a failure to follow the detailed assembly / disassembly procedure.
Pump perfor-mance exceeded specification requirements and was considered acceptable.
Stone and Webster personnel stated that the pump had been reassembled satis-o factorily and a Certificate of,Conformance to the contracted assembly pro-cedure was provided, i
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a Responding to a question concerning startup program instrumentation to verify acceptable vibration levels, Stone and Webster stated that horizontal vibration packages would be mounted on the top and bottom of the pump motor i
and would be monitored during the startup testing to assure that the accep-f tance criteria of 0.2 inches per second was not exceeded, and also to obtain baseline signatures for future reference in accordance with the Millstone 3 ISI program.
I The applicant has demonstrated operability qualification for this component.
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t 3.7 3RSS*M0V208 inch Butterfly Valve (B0P)
. This valves is a containment recirculation spray pump discharge valve l
located in the Engineering Safety Features Building at the 15 foot 5 inch f
elevation.
Its function is to open in response to a CDA signal followed by
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closure during manual switchover to long-term recirculation.
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The valve is manufactured by Henry Pratt Company and is provided with a motor operated Limitorque actuator.
The valve assembly was qualified by a i
combination of testing and analysis.
r A review of the PV0RT long form disclosed missing serial numbers for the valve and actuator, a listed value of 651 Hz for the fundamental frequency of the assembly which appeared to be far too high, and other discrepancies.
I The natural frequency analysis was provided and when it was examined, it was found that 651 Hz was the natural frequency of a component part not of the r
assembly.
The valve assembly natural frequency had apparently not been calcu-lated.
Stone and Webster personnel independently Liculated the natural fre-que'ncy of the valve assembly and determined that it behaved as a rigid body f
with a fundamental frequency above the specified valve of 38 Hz.
i A corrected long form was provided containing serial numbers and with
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other discrepancies corrected; i
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s Other qualification documentation reviewed and found to be satisfactory concluded motor operator test data, hydro test, seat and stem leakage, and valve operating test reports.
The applicant has demonstrated operability qualification for this component.
3.8 3SIL*MV88128 inch Gate Valve (B0P)
This valve remains normally open.
The SIL system is always aligned for cold leg injection mode.
Its safety. function is to be closed by operator action as part of switch-over to long-term recirculation mode.
The valve is manufactured by Pacific Valves, provided with a motor operated Limitorque actuator and is located in the Engineered Safety Features Building at an elevation of 12 feet.
The valve assembly has been qualified by a combination of test and analysis with ASME II 1977 Ed. and Addenda through Summary 1979, IEEE-323 (1974), IEEE-112 (1978), IEEE-344 (1975), IEEE-382 (1972), and MSS-SP-61 L
(1977) used as guides for qualification.
Review of the PVORT long form disclosed missing serial numbers, a lower valve for delivered torque than for required torque, an operator model number discrepancy with the master list,'and an inadequate statement for packing re-placement interval.
Stone and Webster personnel later produced a revised satisfactory long form.
During the review of qualification test documentation, the hydrostatic test report was found to be for another valve. The applicable hydrostatic test report was produced at a later date.
The purchase specification for the valve was reviewed and found to agree with data on the long form, and name plate data from the walk down.
t The applicant has demonstrated operability qualifications for this component.
3.9 3SIL*MV8808A inch Gate Valve (80P)
This 10-inch motor operated gate valve is located in the containment building at the 22 foot 10 inch elevation.
The valve nornally remains open with the power removed during power operation.
During plant startup and nor-mal shutdown, the valve is closed via administrative procedures.
Its safety function is to remain open; however, when the valve is closed during' shutdown or startup, it will open in response to an SIS signal.
During the walkdown inspection, a bent hinge was observed on the opera-tor li,mit switch cover compartment.
The question as to corrective action and why there was no reject or Non-conformance and Disposition (N&D) tag affixed was asked. A copy of N&D Number 11175 was produced later showing that Limitorque was aware of and had redesigned the hinge. Limitorque also ap-proved Stone and Webster's proposed hinge design.
Also noted during the walk down was IR (Inspection Report) tag number E4A05091. A copy of the report was requested and reviewed with the applicable N&D Number 7833.
The reports indicated that the valve actuator arms had no adjustment and would not make up with the limit switch arms. The corrective rework proposed by Stone and Webster and shown on the N&D report was checked with limitorque and received their concurrence.
The PVORT long forms were reviewed and found to contain several omis-sions (actuator and valve serial numbers) and discrepancies. A revised long form received later was received and found to be satisfactory.
Qualification documentation reviewed included the certificate of com-pliance, purchase specifications and actuator sizing calculations.
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O The applicant has demonstrated operability qualification for this j
component.
3.10 3RCS*SV8095A inch Solenoid Operated Gate Valve (NSSS)
This valve which is located as part of the Reactor Coolant System in the containment building at the 55 foot 10 inch elevation is normally kept closed except for venting during startup.
Its safety function is to open and provide a safety grade letdown patch for the RCS for inventory control during boration, and again to open to provide a vent for the RCS.
During the walkdown by the PVORT team, an apparent discrepancy in serial numbers was flagged. The valve was installed, hooked up and had been stroked.
The serial number discrepancy was later attributed to the fact that the serial number from the Nuclear Stamp had been written down during the walkdown rather than the manufacturer's serial number.
Qualification of the valve was by a combination of testing and analy-sis. The valve was designed in accordance with ASME Code Section III, Class I.
Documentation reviewed included facto.ry acceptance test reports and the equipment specification.
i The applicant has demonstrated operability qualification for this component.
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Table i Audited Equipment and Finding Page I of 3 NS$$ or Plant BOP De-Safety Compo-Manufac-Finding /
l.D. Number Suppli ed scription Functi on nont turer Edel Resoluti on Statu s 3 MSS *CTV27A BOP 44" single min steam Valve Sulzer DAS 630-0 Satisfactory Closed seated globe Isolation Brothers valve Actuator
( Actuated by operat-Ing medium) 3 MSS *Rv22A BOP 6"xPx8" dual Prevent over Valve Dresser 3707R Sati sf actory Closed outlet safety pressuriza-Indust.
Speci al valve tion of sein i
steam Ilpe.
3 MSS *MOVl8A BOP 8"-900d motor Isolation of valve Walmorth N5247PSB Satisfactory closed operated gate pressure re-valve lieving &
Actuator Limitorque SMS-O-25 pressure re-b Ileving bypass ut valve.
- 3SW8PIC BOP Vertical Provides cool-Pump Hayward-24 VSN Open i tems con-mixed flow Ing for emer-Tyler corning mechant-centri f ugal gency diesel Driver GE SK6338x cal performance pump gen., contal n-Cil9A testa ment recirc.
-Generated pump Open coolers, and re-curves do not actor plant meet vendor or eux. systems.
system design curves.
-Rundown time Chen comparison of pumps was not within the 205 specified in procedure.
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Table I Audited Equipment and Finding Page 2 of 3 NSSS or Plant BOP De-Safety Compo-Manufac-Fi ndi ng/
I.D. Number Supplied scription functi on nont turer
% del Resolution Statu s 35W'P IC
-Calculated Open IContinued) horse power was not withi n 10% of pump horse power de-termined from performance curves.
, ' 3FWA*PI A BOP Horizontal Prowldes emer-Pump BInghan 3x6x9 CMSD Satisfactory Closed contrliugal gency source WIIIamotto pump of water for Drive GE SK821051C40 steam genera-b fors.
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3RSS*PI A BOP Deep draff Pump starts in Pump 01ngham VCR-10x12x Seil sf actory Closed centrifugal response to Willamette 10B pianp G A signal.
Driver Westing-5888P36 Delivers sump house water f or con-talement spray thea switches to long-term cooling.
3SIL*Mv8808A BOP 10a motor Valve to remain Valve Westing-10GM88E EH Satisfactory Closed operated open to miti-house gate valve gate DBA Actuator Limitorque SED-4-200 t
3S IL*MV88128 BOP 12" motor Valve to close Valve Pacific G-55509 Satisfactory Closed operated by operator gate valve action as part Actuator Limi torque SB-1 of long-term
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recirculation mod e.
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Table i Audited Eeulpment and Finding Page 3 of 3 NS$$ or Plant BOP De-Safety Compo-Nanufac-Fi nding/
1.D. Number Supplied scription function nont turer Mxlel flasolution Status 3RSS*M0v20B BOP 10" motor Opens in re-Valve Pratt N>t(-il Satisfactory Closed operated sponse to CDA butterfly signal. Dur-Actuator Li mi torque HOBC/SNB valve Ing manual switch over to long-term
.3 recirculation, valve must be closed by re-b mote operator 7
octi on.
3RCS'Sv8095A NSSS l' solenold Opens to pro-Valve Target 7948 @ l Satisfactory Closed operated vide a safety Assembly Rock globe valve grade letdown i
path f or reac-for coolant system for in-ventory control during boration.
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Table 2 SER Open Items Finding /
SER ltems Resolution Status
- 1. The applicant did not provide the design criteria Satisfactory Closed for pump and valve internal parts, such as valve discs and pump shafts. A review of qualification documents is necessary to determine whether the pump and valve internals are adequately qualified.
- 2. SRP 3.10, Paragraph II.la(2) indicates that equip-Satisfactory Closed ment should be tested in the operational condition, that is, normal plant loadings should be super-imposed on seismic and dynamic loads, including thermal, flow induced loads and degraded flow conditions. The FSAR should clearly indicate how this requirement is met.
- 3. For those components where qualification and/or Satisfactory Closed operability assurance was provided by analysis alone, some question remains as to the confidence level ensured by this methodology.
The necessity for additional component testing is being con-sidered and cannot be established without an in-spection at the plant site.
- 4. There should be a list of types of equipment.that Satisfactory.
Closed clearly shows the methods used for qualification.
This list should also address which standards are met, in particular those sited in SRP Section 3.10.
- 5. Clarification of how aging was incorporated in the '
Satisfactory Closed qualification process should be contained in the FSAR.
In addition, the applicant should commit to establish a maintenance and surveillance pro-gram to maintain equipment in a qualified status throughout the life of the plant.
- 6. Further justification of the independent qualifica-Satisfactory Closed tion of pumps, valves, prime, movers, and actuators vs. their assembly qualification is also required.
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