ML20151E317

Forwards Response to Suppl 1 to IE Bulletin 85-003 & NRC Request for Addl Info Re IE Bulletin 85-003.Differential Pressures Have Been Provided Based on Preliminary Calculations for Inadvertent Valve Mispositioning

ML20151E317
Person / Time
Site:	Browns Ferry
Issue date:	07/15/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
IEB-85-003, IEB-85-3, NUDOCS 8807260014
Download: ML20151E317 (14)

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TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 374o1 SN 157B Lookout Placo JUL 151988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Cen: ' emen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260

) 50-296 BROWNS FERRY'dUCLEAR PLANT (BFN) - RESPONSE TO NRC INSPECTION AND ENFORCEMENT BULLETIN (IEB) 85-03 SUPPLEMENT 1 AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CONCERNINC RESPONSES TO IEB 85-03 In responso to supplement 1, NRC Bulletin No. 85-03 dated April 27, 1988, TVA is providing the information requested in enclosure 1 to this letter. This information is provided under oath and affirmation as requested.

Enclosure 2 contains the information requested by letter from K. P. Bare to S. A. White dated April 1, 1988, regarding IEB 85-03 for BFN. The Apell 1, 1988 letter requested additional information to responses submitted in TVA letters dated May 13, 1986, Eaptember 13, 1986, and May 1, 1987.

Enclosure 3 includes revised table 1, originally presented.in the May 13, 1986 letter to J. N. Grace from R. Gridley with additional information provided in the September 30, 1986 letter to J. N. Grace from R. Gridley, for both high pressure coolant injection (HPCI) and reactor coro isolation cooling (RCIC) including maximum differential pressur6s and ad<titional valves to address inadvertent valve mispositioning. Differential pressuras have been provided based on preliminary calculations for inadvertent valve mispositioning. TVA will part,1cipate in the Bolling Water Reactor Owners Group (BWROC) and utilize worst caso differential pressures for each safety related valvo function as deturmined by BWROG generic methodology for inadvertent valve mispositioning.

These preliminary calculattors may be revised based on the BWROG methodology.

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8807260014 000715 PDR ADOCK 05000259 PNV ~

jj d G f An Equal Opportunity Empioyer .

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U.S. Nuclear Regulatory Comission { { g' Sumary statements of comitments contained in this submittal are provided in enclosuro 4.

If there are any questions, please telephono J. L. Turner at (205) 729-2853.

Very truly yours, TE ESSEE V LEY AUTHORITY R. Geldley, D1'ector Nuclear Licon.Ing and Regulatory Affairs Subscribedanjsworn bo(ore no on t is ./JNay of / 988.

0N Notary Public h

My Comission Expires Enclocures cc (Enclosuro):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Com lssion one White Flint, North 11555 Rockvillo Piko Rockville, Maryland 20852 Mr. F. McCoy, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Comission Region 11 101 Mariotta Street, NW, Suite 2900 Atlanta, coorgia 30323 Browns Ferry Resident inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611

ENCLOSURE 1 RESPONSE TO NRC BULLETIN NO. 85-03, SUPPLEMENT 1 DATED APRIL 27, 1988 Item a Review and document the design basis for the operation of each valve. This documentation should include the maximum dif ferential pressure expected during both opening and closing of the valve for both normal and abnormal events to the extent that the events are included in the existing, approved design basis (i.e. , the design basis documented in pertinent licensco submittals such as Final Safety Analysis Report analysos and fully approved operating and emergency procedures, etc.). In addition, when dotormining the maximum differential pressure for valves that can be inadvertently mispositioned, the fact that the valvo must be able to recover from such mispositioning should be included.

TVA Response Table 1 of TVA's response to NRC Bulletin 85-03 for BFN, which was originally presented in the May 13, 1986 letter to J. N. Craco from R. Celdley with additional information provided in the September 30, 1986 lottor to J. N. Crace from R. Cridley, has been revised to includo all motor oporated valves (MOVs) in the HPCI and RCIC systems. Enclosure 3 is the revised tablo 1 and includes applicable changes. ,

Table 1 has also boon revised to include inadvertent equipment operation to verify that required valves are able to recover t' rom an inadvertent mispositioning. Maximum differential pressures for recovering from inadvertent mispositioning have been included in the revision to tablo 1.

The HPCI portion of table 1 has been revised to ohow the normal position of MOV 73-81 as closed verses open. This reflects the changing of this valvo  ;

position on DFN drawings and procedures.

Item b Perform action item b of the original bulletin for any additional valvos identified above.

1 The intent is to provido assurance that a pragram exists for rotecting and I setting valve operator Switenos to ensure a high rollability of safety system l valves. If changing the switch cottings is not sufficient to ensuro the capability for repositioning a particular mispositioned valvo, a justification for continued operation should be provided in the bulletin responso if tho l licensco does not elect to implement additional actions, cuch au  !

administrativo or procedural controls or equipment modifications, to minimize the likelihood of valve malfunction.

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, 1 TVA Response l Establishment of correct switch sottings, which was previously completed as reported in the May 1, 1987 letter from R. Gridley, is being reperformed.

This is due to revision of TVA's General Construction Specification G-50 (Torque and Limit Switch Settings for Motor Operated Valves) approved December 18, 1987. '

This new revisten chanson the technique for setting torque switches. The old cathod for uetting torque switches used at least the minimum torque switch setting provided by the vendor. The new method sets torque switches using actual thrust values determined during valve testing.

The new settings are based upon calculations being supplied to TVA from the original valve sanufacturers. Theso calculationc includo required thrusts for both opening and closing valves under differential pressure. 'ho maximum thrust values and the limiting structural components for both opening and closing these valvec are also provided by the manufacturers I Reestablishme'.t of cor.ect switch settings (item b of NRC bulletin 85-03) will be completed by each respective unit's startup.

Items e and_d_

Pecrotm action item e and d of the ort t inal bulletin for any additional valves identified above.

Tyt Response The schedule for implamenting items e and d to addrens inadvertent va.1vo mispositioning will remain the same se previously committed to fa the May 1,1987 supplemental respo.tso to IE Bulletin 85-03.

1 Item e I Within 30 days of receipt of this supplement, sabmit a written report to the NRC that, for any additienal valsos: (1) provides the revised results of item a above and (2) contains a schedule for completion cf L'.e'ms b through d above, i

TVA Responso Enclosure 1 of this letter supplicA the infocmation to the request in item e.

Item f l

Envise the report requestod by the original bullot!n to include any addltlonal valves. This revised report shsLL bo submitted to the NdC within 60 days of e mplet ion of the program (or the tod'.tional valvos, j l

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. . -1 TVA Response The schedulo for issuing the final report addressing inadvertent valve mispositioning will remain as previously committed in the May 1, 1987 ,

response, 60 days af ter completion of the program for each respective unit.. .

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• ENCLOSURE 2 RESPONSE TO HRC REQUEST FOR ADDITIONAL INFORMATION DATED APRIL 1, 1989 IRB 85-03 Item 1 Revise table 1 of enclosure 1 of the responso dated September 30, 1986, to include the following MOVs, or justify their exclusion. As required by Action Item a of the bulletin, assume inadvertent equipment oporations. How would HPCI or RCIC injection bo ensured if these injcetion valve test valvos were to be (a) actuated inadvertently to the closed position upon intended initiation of the system or (b) left closed inadvartently?

(a) HPCI MOV 73-34 is shown normally open in Zonc E-3 of Drawing 47W610-73-1, revision D, and ac MOV 8 on page 68 of BWROG Report NEDC-31322 dated September 1986.

(b) RCIC HOV 11-37 is shown normally open in Zone E-4 of Drawing 47W610-71-1, revision B, and as MOV 8 on page 72 of the BWROG Report.

P TVA Response (a) High-pressure coolant injection (HPCI) motor operated valvo (MOV) 73-34 (Injection Valve Test Valve)

(b) Reactor core isolation cooling (hCIC) MOV 71-37 (Injection Valvo Tdst Valve)

The valves are included in the revision to table 1 to address inadvertent valve mispositioning.

Itom 2 Revise table 1 of enclosure 1 of the response dated September 30, 1986, to include the following MOVs, or justify their exclusion. According to pages 58 and 62 of the BWROG Report (for HPCI and RCIC respectively), cach of those vacuum breaker line isolation valves has a safety action for closing.

(a) HPCI MOV 73-64 is shown normally open in Zonc F-2 of Drawing 47W610-73-1, revision D, and as MOV III on Pago 71 of the BWROG Report.

(b) RCIC MOV 71-59 is shown normally open in Zone G-2 of Drawing 47W610-71-1, revision B, and as MOV VII on Pago 74 of the BWROG Report. ,

l TVA Responso (a) HPCI HOV 73-64 (Vacuum Dreaker Line Isolation Valvo)

(b) RCIC MOV 71-59 (Vacuum Breaker Lino Isolation Valvo) 1 These valves are included in the revision to tablo 1 for completeness but they l have no activo safety function. These valves are normally open and  !

deenergized to inhibit inadvertent closuro, l l

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The Owner's Group Report (NEDC-31322) Lists these valves with an active safety function to close to provido the requlred isolation. These valves are not primary containment isolation valves at UFN. Any leakage following a loss of coolant accident (LOCA) will be controlled by two primary containment check valves (73-24,73-609 and 71-14,71-580) for HPCI and RCIC respectively.

These valves are included in operating instruction to be closed following a LOCA after HPCI and RCIC have been utilized and steam pressure has been reduced such that these systems are no longer required to function. The remote manual closure of these valves would serve to minimize leakage from primary containment but is not mandatory.

Item 3 Revise table 1 of enclotcre 1 of the response dated September 30, 1986, to includo HPCI MOV 73-36, or justify its exclusion. This CST Test Return Valve is shovn normally closed in Zot.e C-3 of Drawing 4 7W610-73-1, .evision D, and as MOV 6 on Page 68 of the BWROG Report. According to Page 55 of that report, this valve has no safety action; however, utilities are expected to report differential pressures for testing, per Note "c" on Page 66.

TVA Responso HPCI HOV 73-36 (Redundant Shutof f Test Valve to C'iT) . I Tnis valve has been added to table 1 for completeness but has no active"safety function. This valve is normally closed and is opened for testing HPC1/RCIC.  ;

The dif ferential pressure, based on actual operating experience, has been Provided as requested. HPCI and RCIC will perform thelr-intended safety ,

function with MOV 73-35 and MOV 71-38 closed regardless of the poeition (open or closed) of MOV 13-36. )

Item 4 Revise table 1 of enclosure 1 of the responso dated September 30, 1986, to include values of differential pressure for opening the following valves, or ,

justify exclusion of these pressures. How would suction from the CST {

[ items 4(a) and 4(b)] or steam supply to the RCIC Turbine [1tems 4(c)) be '

ensured if these valves were to be (a) actuated inadvertently to the closed i position upon intended initiation of the system or (b) left closed '

inadvertently? I (a) HPCI MOV 73-40 (CST Suntion Valvo) is shown normally open in Zono B-S of l Drawing 47W610-73-1, revision D, and as MOV 3 on Page 68 of the BWROG Report.

(b) RCIC MOV 71-19 (C0T Suction Valvo) is shown normally open in Zono C-6 of Drawing 4 7W610-71-1, rettsion B, and Page 72 of the BWROG Report.

(c) RCIC MOV 71-9 (Trip and Throttle Valve) is shown normally open in Zono C-8 of Drawing 47W610-71-1, revision B, and as MOV X on Page 74 of the BWROG Report.

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TVA Response (a) HPCI MOV 73-40 (CST Suction Valvo)

(b) RCIC MOV 71-19 (CST Suction Valve)

(c) RCIC MOV 71-9 (Telp and Throttle Valvo)

Maximum opening differential pressures have been included in the revision to table 1 for the above valves to address inadvertent valve mispositioning.

Item 5 Reviso table 1 of enclosure 1 of the responso detod September 30, 1986, to include values of differential pressure for opening supprossion pool suction isolation MOVs 71-17 and 71-18, or justify exclusion of these pressures.

According to Pago 59 of the BWROG Report, these valves have safety actions for opening and closing. These valves are shown as MOVs 4 and 4a on Pago 72 of the BWROC Report.

TVA Response (a) RCIC MOV 71-17 (Suppression Pool Suction Valvo)

(b) RCIC MOV 71-18 (Suppression Pool Suction Valvo)

The maximum opening differential pressures are supplied in the revision to table 1. These valvos are remote manually opened by the operator on low CST level or high suppression pool level.

. Item 6 The proposed program for action b, c, and d of the bulletin is incomplete.

Provide the following details as a minimum:

(a) commitment to a training program for settlns switches and maintaining valva operators, (b) cammitment to justify continued operation of a valvo determined to bo inoperable, (c) description of a method possibly needed to extrapolato valvo stem thrust determined by testing at loss than maximum differential' pressure, (d) justification of a possible alternative to testing at maximum differential pressure at the plant, (e) consideration of pipe break conditions as required by the bulletin, (f) stroke testing when necessary to meet nulletin requirements, and (g) consideration of applicable industry recommendations in the preparation of proceduros to ensure maintenance of correct switch settings.

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TVA Response The following section provides additional information requested on our proposed program for action items b, c, and d of IE Bulletin 85-03,

s. Training Program - All electrical and mechanical craft personnel are required to successfully complete training prior to independent maintenance of valvo actuators. This training includes Limitorquo salvo actuators, Rotock valve actuators, and MOVATS (Motor Operated Valve Analysis and Teeting System).

b. Any valve that is determined to be inoperaato will bo justified for continued operation as applicable por plant technical specifications.

c. Differential pressure testing has not been performed at less than tho

- calculated values of maximum differential pressure specified on table 1 of the TVA response to IE Bullotin 85-03 to date. Any test results at less than the maximum differential pressure specified in table 1 will-includo a justification in the final report. Justifications different from stem thrust extrapolation may be utilized.

3. Justification for testing at less than the maximum differential pressure, if applicable, will be supplied in the final report. Valvos will be justified on an individual basis due to the number of variables involved with each valve operator,

e. Pipo break conditions were included in calculation of maximum differential pressure and establishment of correct switch settings as required by the bulletin. The methodology agrees with the approach defined in the BWROG report section 1.4.

f. Stroke testing is currently being performed as part of valvo maintenanco procedures on each motor operated valvo to verify propor implemer.tation of switch sottings. Before a valvo operator is returned to servico, applicable valvo surveillance instructions are performed to verify operability.

g. Industry recommendations for procedures to ensuro maintenanco of correct switch settings are considered by poroonnel involved in IE Bulletin 85-03. Browns Ferry utilizes the Nuclear Network and Operation Experience Reports to keep abreast of current industry practicos involving all phases of MOV work. Additionally, TVA has a MOV Users Group which meets periodically to address issues and problems associated I with MOVs.

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ENCLOSURE 3 TABLE 1 Valve Valve Max. Differential Normal Safety Function Pressure (lbjin'd)

Unique No. Description Position Description Opening Closing 73-2 HPCI steam Open Valve must close to 11051 1105 i solation isolate containment valve in case of a HPCI steam line break.

73-3 HPCI steam Open Valve must close to 11051 1105 isolation isolate containment valve in case of a HPCI steam ' ~

line break.

73-16 HPCI steam Closed Valve must open on HPCI 1105 supply valve initiation to supply __ ,

reactor steam to the turbine 73-26 HPCI suction Closed Must open to allow the 50.3 valve to the 40.6 HPCI pump to take suppression suction from the torus pool and must close if isolation of primary containment is required 73-27 HPCI suction C1csed Must open to allow the 50.3 41.5 valve to the HPCI pump to take suppression suction from the torus pool and must close if isolation of p-iman containment is required 73-30 HPCI minimum Closed Must both open and close 1361.8 1439.1 recirculation to provide adequate flow valve pump recirculation flow and adequate cooling flow to the reactor vessel respectively 73-341 HPCI Open Valve must remain open injection 1363.3 __

to inject water to the valve test reactor vessel.

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ENCLOSUdE 3

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TABLE I (Continued)

Max. Differential '

Valve valve Normal Safety function Pressure (1blin'd)

Unique No. Description Position Description Opening Closing 73-35 HPCI test Closed Must close on HPCI __ 1250

return to initiation to ensure condensate adequate flow to the reactor vessel.

73-36' Redundant Closed Valve has no safety __ 1250**

shutoff to function; redundant condensate shutoff to CST for MOVs ,

storage tank 73-35 and 71-38.

73-40 HPCI suction Open Valve must close when 43.6I 95.2 valve to the HPCI is aligned to condensate take suction from the storage tank. suppression pool.

73 -44 HPCI discharge Closed Must open on HPCI 1230.3 __

injection initiation to inject valve. water to the reactor vessel through the feedwater system,73-642 Vacuum breaker Open Valve must remain open 2 line isolation to prevent water from valve being drawn up into turbine exhaust line. .

73-81 HPCI steam Closed Must close to isolate __ 1105 supply bypass primary containment valve on a HPCI steam .,

line break.

f Valve is included for completeness; it has no motar-operated safety function.

utsed on actual operating experience in test return mode.

NOTE 1 - These valves and maximum differential pressures have been included to address inadvertent valve mispositioning.

NOTE 2 - This valve is blocked from inadvertent operation at the motor

, control center. .

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4 ENCLOSURE 3 TA8LE 1 (Continued)

Max. Dif terential Valve Valve Normal Safety Function Pressure (1blin'd)

Unique No. Description Position Description Opening Closing 71-2 RCIC steam Open Valve must close and 1105I 1105 isolation isolate containment valve on RCIC steam line break.

71-3 RCIC steam Open Valve must close and 11051 1105 i s olation isolate containment r-valve on RCIC steam line break.

71-8 RCIC steam Closed ' Valve must be open on 1105 __ .

supply valve RCIC initiation to supply reactor steam to the turbine.

71-9 RCIC Open Valve must spring close 11051 01 turbine on RCIC isolation signal stop valve to stop the turbine.

71-17 RCIC suction Closed Valve must close if 147.7 39.4 valve to the opened and containment suppression isolation is required.

pool 71-18 RCIC suction Closed Valve must close if 147.7 39.4 valve to the opened and containment

• suppression isolation is required.

pool 71-19 RCIC suction Open Valve must close when 140.91 37.5 valve to the RCIC is aligned to take s condensate

p. suction f rom the storage tank suppression pool.

71-25 RCIC cooling Closed Valve must be open on 1342.9 water supply RCIC initiation to valve ensure an adequate cooling supply.

71-34 RCIC minimum Closed Must both open and close 1335.8 1469.7 recirculation to provide adequate pump

• flow valve recirculation firw and . ,

adequate system ..ow to the vessel, respectively.

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ENCLOSURE 3 TABLE 1 (Continued)

Max. Olfferenti 1 Valve Valve Normal Safety Function Pressure (1blin'4 d )

Unique No. Description Position Description Opening Closing 71-37I .RCIC injection Open Valve must remain open 13401 ~~

valve test to inject water to the valve reactor vessel.

71-38 RCIC test Closed Valve must close on an __ 1200**

return to initiation signal while condensate in the test return mode to enssee adequate flow to the reactor vessel. <

71-39 RCIC discharge Closed Valve must open on RCIC 1254.3 __

injection initiation to inject valve. water to the reactor vessel through the feedwater system.71-592 Vacuum breaker Open Valve must remain open 2 line isolation to prey t water f ronu-valve being di..m up in>c' turbine exhaust j 4ine, j e

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• • Valve is included for completeness, it has no motor-operated safety function.

Based on actual operating experience in test return mode.

4 NOTE 1 - These valves and maximum differential pressures have been included to address inadvertent valve mispositioning.

NOTE 2 - This valve is blocked from inadvertent operation at the moter, control center.

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ENCLOSURE 4 COMMITHENTS MADE IN TilIS SUBMITTAL

1. Re-est ablistunent of switch sett.'.ngq wLil be completed by each respectLvo unit's startup.

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