ML20154N831

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Summary of 860128-29 Meetings W/Util,Sargent & Lundy & BNL in Chicago,Il Re Test Vs Analysis Concern for Active Valve Qualification Identified During Sqrt & Pvort Audits
ML20154N831
Person / Time
Site: Clinton Constellation icon.png
Issue date: 03/11/1986
From: Siegel B
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 8603200049
Download: ML20154N831 (31)


Text

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+ IC, UNITED STATES

[. h NUCLEAR REGULATORY COMMISSION

' 7, WASHINGTON, D. C. 20555 j

.... MAR 111sd Docket No. 50-461 i

APPLICANT: Illinois Power Company FACILITY: Clinton Power Station

SUBJECT:

SUMMARY

OF MEETING TO RESOLVE TEST VS ANALYSIS CONCERN FOR ACTIVE VALVE QUALIFICATION IDENTIFIED DURING SQRT AND PVORT AUDITS AT CLINTON POWER STATION A meeting was held January 28 and 29, 1986 at the Sargent and Lundy offices

in Chicago, Illinois between Illinois Power Company (IP), Sargent and Lundy (S&L), the NRC staff, and the staff's consultants from the Brookhaven National Laboratory (BNL). A list of primary meeting attendees is contained in i Enclosure 1.

The purpose of the meeting was to resolve the test vs analysis issue for qualification of active valves identified during the SQRT and PVORT audits.

A description of IP's analytical approach to resolve this issue was presented by R. Tjernlund of S&L and is contained in Enclosure 2. Discussions between IP, S&L, the staff, and BNL followed and then the documentation provided by IP to verify the acceptability of its approach was reviewed by the staff and its consultants to determine if the information provided adequately addressed the staff's concerns.

Upon the completion of the review the staff and BNL provided IP with preliminary conclusions regarding its assessment of the infonnation provided to resolve the issue of test vs analysis to satisfy both the SQRT and PV0RT concerns. These preliminary conclusions are stated below.

For operability issue related to SQRT:

  • IP has used an analytical approach
  • IP has used data from 32 test data packages for verification

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  • The analysis conservatively predicts the test data in all cases
  • Comparison between the test results and system analysis results show a large degree of conservatism (Enclosure 2, Table B2)
  • IP has grouped all the active valves into 21 groups and identified the test valve data that are directly applicable to each valve group (Pages 4 and 5, Enclosure 2)

The staff and BNL have reviewed the valve groups and determined that the test data are adequate to demonstrate operability for all but Groups 1 and 15 (for Crosby valves only). For these two groups, additional test data or a probabilistic analysis approach could be used to demonstrate operability.

  • The sta'f and BNL will review further the acceptability of IP's analytical approach for the resolution of the operability issue for the remaining J two valve groups.

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i, I In addition, the staff provided IP with the current status of the SQRT issues

, identified during the August SQRT audit and the following additional open 1 issues resulting from the current review that either require or may require

! IP action.

i 1. Review test report #MR52600-570-1-1 needed for the similarity demonstration i of valve #V526-6310-4C (Ref. Group #2) and present the findings to the j staff.

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! 2. For all active valves, the similarity analysis should be corrected, as I needed, and included in the qualification package.

1 3. Adequate test data were not provided to demonstrate operability of the l following valves:

1 a) Anchor Darling Gate and Globe, Group 1 b) 8" Crosby Relief, Group 15

IP will be advised whether additional test data are required for the above

! valves, j For the operability issue related to PVORT:

l The purpose of this review was to give S&L the opportunity to provide the staff i the justification for qualification of valve components in lieu of providing l verification by test to demonstrate operability. S&L has categorized all the Clinton valves into 21 groups. For purposes of this documentation review five groups were audited. The documentation provided reflected a clearer understanding

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by the applicant and S&L of qualification requirements. However, test data to verify each components analysis does not exist within the S&L files. The basis for S&L's approach was to show valve qualification by tests that were performed on similar components in other groups. The staff believes that S&L has provided all the documentation that they have in their possession. Final resolution of the Clinton PVORT will be determined by the staff after discussion with upper management and the staff's consultant. In addition, the staff provided IP with the current status of PVORT issues identified during the August and November audits.

The staff agreed to try to provide IP with a position with regard to accepta-bility of IP's approach to active valve qualification for the two remaining valve groups (Groups 1 and 15) reviewed under the SQRT program and with regard to the acceptability of the approach for the PVORT program by Friday, January 31, 1986 l but no later than February 4,1986.

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3-i l Since the meeting the staff has identified the additional actions required of

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IP to achieve final resolution of both these issues. Enclosures 3 and 4 con-l tains these actions which have also been informally provided to and discussed with IP on January 20, 1986. IP has stated they understand the staff's position

) on these issues and will comply with the actions identified in Enclosures 3 and

4. These positions will be sent to IP once they are officially received from the technical review branch.

3 B'yron L. Siegel, Project Manager BWR Project Directorate No. 4 4

Division of BWR Licensing

Enclosure:

As stated i

cc: See next page i

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Mr. Frank A. Spangenberg Clinton Power Stettion 1 Illinois Power Cor.pany Unit 1 cc:

Mark Jason Jean Foy, Esquire Assistant Attorney General 511 W. hevada Public Utilities Division Urbana, Illinois 61801 Office of the Attorrey General State of Illir,ois Center Richard B. Hubbard 100 West Randolph Street - 12th Floor Vice President Chicago, Illinois 00601 Technical Associates 1723 Hamilton Avenue - Suite K Mr. D. P. Hall San Jose, California 95125 's Vice President Clinton Power Station P. O. Box 678 Clinton, Illinois, 61727 ffr. D. C. Shelton Manager-Nuclear Station Ergireering Dpt.

Clinton Pcwer Station F. O. Box 678 Clinten, Illinois 61727 Sheldon Zabel, Esquire Scniff, Harcir. L lleite 7200 Sears Tower 233 Wacker Drive Chicago, Illinois 60606 Resident Inspectcr U. S. fluclear Regulatory Comnission RR 3, Box 229 A Clinton, Illinois 61727 Mr. R. C. Heider Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 Mr. L. Larscr Project Manager General Electric Company 175 Curtner Avenue, N/C 395 San Jose, California 95125 Pegional Administrator, Pegion III 799 Roosevelt koad Glen Ellyn, Illinois 60137

Enclosure 1 Principal Attendee's to January 28 and 29,1986 Meeting to Resolve Test VS Analysis Concern for Qualification of Active Valves at Clinton Power Station Name Company D. W. Wilson Illinois Power R. C. Heider S&L M. J. Shewski S&L

1. T. Kisisel S&L R. M. Tjernlund S&L P. D. Raheja S&L P. Raysircar IP H. M. Sroka S&L K. Bandyopadhyay BNL B. Siegel NRC J. Lombardo NRC B. Miller BNL M. E. D'Paem IPC D. C. Shelton IP C. T. Gentile IP R. Kokesh S&L

. Enclosure 2 NRC CONCERNS OPERABILITY OF ACTIVE VALVE ASSEMRLIES DEPENDENT UPON DISPLACEMENT OF EXTENDED PARTS NRC SATISFIED WITH CLINTON APPROACH FOR DEMONSTRATING

  • VALVE STRUCTURAL INTEGRITY
  • OPERATOR SE!SMIC CAPABILITY 1.

l APPROACH

1) OPERABILITY DEMONSTRATED BY TESTING ALONE, OR COMBINATION OF TEST AND ANALYSIS
2) WHEN ANALYSIS USED:

-EACH VALVE ANALYZED

-REPRESENTATIVE SAMPLES OF SIMILAR VALVE ASSEMBLIES TESTED

3) PURPOSE OF TESTING:
  • SUBSTANTIATE ANALYTICAL METHODS
4) ONCE SUBSTANTIATED
  • SAME ANALYTICAL MODEL/ METHODS CAN BE USED TO QUALIFY SIMILAR VALVES
5) ANALYSIS PERFORMED BY VALVE MFG OR BY HIS SUBCONTRACTOR S&L REVIEWS 4

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i CLINTON ACTIVE VALVES CATAGORIZED INTO 21 GROUPS ACCORDING T0:

  • VALVE IYPE 1
  • VALVE MANUFACTURER
  • ACTUATOR IYPE
  • ACTUATOR MANUFACTURER i

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CATEGORIES OF CLINTON ACTIVE VALVES Page 1 Valve Valve Actuator Actuator Size Test Group Mfg. Type Type Mfg Range Population Valve 1 .inchor Gate / Globe Mo Limitorque 1" - 24" 152 16"-150# Mo Gate Darling 2 Valcor Gate / Globe So Valcor "

-2 57 " So Globe 1"-600# Gate 1"-2500# So Globe 2"-275# So Globe 3 Rockwell Globe Mo Limitorque 1"- 1 1/2" 5 15"-1500#Mu clobe 4 Sporlan Globe So Thermal Sporlan Expan.

5/E"-7/8" 21 7/8" So Globe 5 Alco Globe So Alco 5/8" 2

! 5/8" So Globe 6 Yarway Globe Mo Limitorque 1"-2" 22 '15"-3600"So Globe 7 Fisher Globe Ao Fisher 3/4"-8" 56 1"-6004 Ao Globe 1"-1500# Ao Globe l\"-600# Ao Globe 3"-600# Ao Globe 4"-600# Ao Globe 8 Atwood & Globe Ao Sheffer 24" 16 24"-1500# Globe

. brrill 9 Jamesbury Bfly, Ball llo ITT 1

-4" 5 NII-90 Series Actuator 10 Clow Bfly Ao Bettis 12" 4 12"-150# Ao Bfly 11 Posi-Seal Bfly Mo Limitorque 2"- 36" 58 IIBC/SMB Actuator Ao Matrix 8"-150# A0 Bfly 12"-150# Ao Bfly 24"-150# A0 Bfly 12 XoMOX  ? lug Ao X-ACT 2" 2 2"-150# AO Plug 13 XOMOX Plun Mo Limitoroue 2"-3" 3 11BC/SMB Actuator i

Page 2 CATEGORIES OF CLINTON ACTIVE VALVES Actuator Size Tested Valve valve Actuator Va1ves Type M f er . Panoe Ponulation Group Mfg. Ty,pe 8" 16 8 x 10 Safety Relief Ao Dikkers 14 Dikkers Relief None N/A 5"-8" 70 1"-1500# Relief 15 Target Rock Relief 2"-1500# Relief Dresser 4"-150G# Relief Crosby N/A 10" 32 10" Vaccum Anderson Vacuum None Breaker 16 Greenwood Relief Ao llammel Dahl 1"-2" 2 1"-1500# Ao Globe 17 llammel Dahl Globe 2"-1500# Ao Globe Conax 1 2 1 "-1400#

18 Conax explosive explosive Explosive 19 Robert Shaw IICU Valves Robert Shaw 3/4"-1" 290 Tested with IICU's ASCO Globe (126.127) Ao 145 So ASCO GE Globe (139) 3/4"-1" 580 Check (l14) None N/A (l15)

(137)

(138)

N/A 5"-30" 128 20 Anchor Darling Check None(a)

Dragon GPE 1 Tested with RClc Mo Limitorque 3" 21 Gimpel Globe "

Note: a) 8 of the check valves are testable possessing Ao Actuators Ul

SAMPLE VALVE ASSEMBLIES FROM EACH GROUP TESTED EXCEPTIONS:

1) CHECK VALVES NOT SEISMICALLY TESTED SEISMIC LOADS INCONSEQUENTIAL COMPARED TO IMPACT LOADS ASSOCIATED WITH RAPID CLOSING /0PENING
2) TESTuiG FOR 2 GROUPS OF 90 TURN VALVES, TESTED EXTENDED PARTS ONLY, NOT BODY TESTING OF EXTENDED PARTS SUFFICIENT TO DEMONSTRATE OPERABILITY
3) 1 GROUP OF A0 PLUG VALVES NOT TESTED FOR CLINTON WERE TESTED FOR ANOTHER STATION WITH OPERABILITY DEMONSTRATED

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1/29/86 TABLE 31

! OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ACTUAL & TEST ACCELERATIONS Group Valve Test Accelerations N Number Description Accelerations for which For Which Operability 0 Analysis Demonstrated Operability is Demonstrated T E

H1 H2 V Hi H2 V S 1 4"-Gate 300#-M0 4.5 4.5 3.0 9.4 9.1 6.2 (1,8)

(Powell) 1 16"-Gate 150#-M0 4.5 4.5 3.0 12.3 11.9 5.6 (1,8)

(Anchor / Darling) 2 1/ 2"-Glo be-S. O. 4.5 4.5 3.0 15.0 15.0 8.0 (1,8)

(Valcor)

! 2 1"-Gate 600#-S.O. 4.5 4.5 3.0 4.5 4.5 4.5 (1,8)

(Valcor) 2 1"-Globe 2500#-S.O. 4.5 4.5 3.0 4.5 4.5 4.5 (1,8) 4 (Valcor) 2 2"-Globe 2758-S.O. 4.5 4.5 3.0 4.5 4.5 4.5 (1,8)

(Valcor) 3 9/f-Globe-1500#-M.0. 4.5 4.5 3.0 4.5 4.5 3.0 (4,8)

(Rockwell) 4 7/8" Globe Valve 4.5 4.5 3.0 6.3 6.3 4.5 (1, 8) [

(Sporlan) 5 5/8" Globe Valve 4.5 4.5 3.0 6.3 6.3 4.5 (1, 8)

( Alco) 6 $/f-Globe 3600#-M.0. 4.5 4.5 3.0 6.0 5.0 --

(4,8)

(Yarway) 7 1"-Globe 600#-A.O. 4.5 4.5 3.0 9.4 9.4 --

(3,8)

(Fisher) 7 S/f-Globe 600#-A.O. 4.5 4.5 3.0 9.7 9.6 --

(3,8)

(Fisher) 7 3"-Globe 600#-A.0, 4.5 4.5 3.0 10.5 10.5 --

(3,8)

(Fisher) 7 4"-Globe 600#-A.O. 4.5 4.5 3.0 9.2 9.2 --

(3,8)

(Fisher) 7 1"-Globe 1500#-A.O. 4.5 4.5 3.0 9.4 9.4 --

(3,8)

(Fisher) 8 24"-Globe Valve 6.5 7.3 9.0 10.0 10.0 15.0 (1,7,8)

(Atwood & Morrill) i 7

-_- - =. _ - _ _ .- . . . - - - . _ _ .

u TABLE B1 OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ALTUAL & TEST ACCELERATIONS I Test Accelerations N Group Valve Number Description Accelerations for which For Which Operability 0 Analysis Demonstrated Operability is Demonstrated T E

H1 H2 V H1 H2 V S 10 12"-Butt erfly 150#-A.O. 4.5 4.5 3.0 11.0 11.0 11.0 (1,8)

(Clow) 11 12"-Butterfly 150#-A.O. 3.0 3.0 3.0 4.0 4.0 4.0 (1,8)

{

l (Posi-Seal) 11 12"-Butterfly 150#-A.O. 3.0 3.0 3.0 4.5 4.5 4.5 (1,8) 1 (Posi-Seal) 11 24"-Butterfly 150#-A.O. 3.0 3.0 3.0 4.5 4.5 4.5 (1,8)

(Posi-Seal) 11 8"-Butterfly 150#-A.O. 3.0 3.0 3.0 4.5 4.5 4.5 (1,8)

(Posi-Seal) 14 8"x10" Safety Relief Valve 5.8 5.8 3.6 6.4 6.4 6.0 (1,9)

(Dickers) 15 1"-Pressure Relief

-1500#-Spring 4.5 4.5 3.0 - -

6.0 (6,8)

(Dresser) 15 2"-Pressure Relief

-1500#-Spring 4.5 4.5 3.0 - -

6.0 (6,8)

(Dresser) 15 4"-Pressure Relief

-1500#-Spring 4.5 4.5 3.0 -- -

6.0 (6,8)

(Dresser) 15 3/4" Pressure Relief V alve (Crosby 4.5 4.5 3.0 5.0 5.0 5.0 (2,8) 16 10"-Vacuum Breaker 21.5 18.2 21.8 - - -

(5) i (Anderson Greenwood)

I 17 1"-Globe Valve 4.5 4.5 3.0 6.5 6.5 6.0 (1,8) '

(Hamhal Dahl) 17 2"-Globe Valve 4.5 4.5 3.0 6.5 6.5 6.0 (1,8)

(Hamhal Dahl) 18 1 1/2"-Conax Explosive 4.5 4.5 3.0 6.8 6.8 6.8 (2,9)

(Conax) 1 1

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TABLE B1 OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ACTUAL & TEST ACCELERATIONS Group Valve Test Accelerations N Number Description Accelerations for which For Which Operability 0 Analysis Demonstrated Operability is Demonstrated T E

H1 H2 V Hi H2 V S 19 3/4"-Check Valve - - - 9.0 9.0 24.0 (1 J [0 (General Electric) 19 3/4"-Globe '/alve - - - 9.0 9.0 24.0 (I J 0)

(Robert Shas) 19 1/2"-Globe Valve - - -

9.0 9.0 24.0 (lJ 00 (Ro be rt Shaw) 19 1"-Check Valve - - -

9.0 9.0 24.0 (l J0)

(General Elect ric) 19 1"-Clobe Valve - - -

9.0 9.0 24.0 (lJ0)

(General Electric) 21 4"-Globe Valve - - -

4.0 4.0 5.0 (lJ0)

(Terry Turbine) l 9

TABLE B2 OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ACTUAL & TEST ACCELERATIONS Group Valve Test Accelerations N Number Description Actual Accelerations For Which Operability 0 Per Piping Analysis is Demonstrated T E

HI H2 V HI H2 V S 1 4"-Gate 3008-M0 1.9 2.8 1.3 9.4 9.1 6.2 (1,8)

(Powell) 1 16"-Gate 150#-MO 2.0 1.7 2.2 12.3 11.9 5.6 (1,8)

(Anchor / Darling) 2 1/ 2 "-G lo be -S . O. 1.33 1.33 1.2 15.0 15.0 8.0 (1,8)

(Valcor) 2 1"-Globe 600#-S.O. 0.4 0.4 0.4 4.5 4.5 4.5 (1,8)

(Valcor) 2 1"-Globe 2500#-S.O. 0.3 0.3 0.9 4.5 4.5 4.5 (1,8)

(Valcor) 2 2 "-Glo be 275#-S.O. 0.2 0.2 0.3 4.5 4.5 4.5 (1,8)

(Valcor) 3 1 1/f-Globe-1500t!-M.0. 2.2 1.3 1.0 4.5 4.5 3.0 (4,8)

(Rockwell) 4 7/8" Globe Valve .3 .3 .9 6.3 6.3 4.5 (1, 8)

(Sporlan) 5 5/8" Globe Valve .3 .3 .9 6.3 6.3 4.5 (1, 8)

(Alco) l 1.1 1.4 6.0 5.0 6 l/f-Globe 3600#-M.O. 2.0 --

(4,8)

(Y arway) 7 1"-Globe 600#-A.O. 0.3 0.3 1.0 9.4 9.4 --

(3,8)

(Fisher) 7 9/f-Globe 600#-A.O. 0.8 0.6 1.0 9.7 9.6 --

(3,8)

(Fisher) 7 3"-Globe 600#-A.O. 1.1 1.1 1.1 10.5 10.5 --

(3,8)

(Fisher) 7 4"-Clobe 600#-A.O. 0.4 0.3 1.2 9.2 9.2 --

(3,8)

(Fisher) 7 1"-Globe 15004-A.O. 0.4 0.0 0.0 9.4 9.4 --

(3,8)

(Fisher) 8 24"-Globe Valve 6.5 7.3 9.0 10.0 10.0 15.0 (1,7,8)

(Atwood & Morrill)

/0

TABLE B2 OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ACTUAL 6 TEST ACCELERATIONS Group Valve Test Accelerations N Number Description Actual Accelerations For Which Operability 0 Per Piping Analysis is Demonstrated T E

HI H2 V H1 H2 V S 10 12"-Bu tt erf ly 150#- A.O. 0.8 0.9 1.3 11.0 11.0 11.0 (1,8)

(Clow) 11 12"-Butterfly 150il-A.O. 2.2 0.2 0.2 4.0 4.0 4.0 (1,8)

(Posi-Seal) 11 12"-Butterfly 150#-A.O. 0.7 0.7 0.9 4.5 4.5 4.5 (1,8)

(Posi-Seal) 11 24"-Butterfly 150J-A.O. 1.0 0.9 1.1 4.5 4.5 4.5 (1,8)

(Posi-Seal)

!! 8"-Butterfly 150#-A.O. 1.8 0.7 0.2 4.5 4.5 4.5 (1,8)

(Posi-Seal) 14 8"x10" Safety Relief Valve 2.8 2.8 1.6 6.4 6.4 6.0 (1,9)

(Dickers) 15 1"-Pressure Relief

-1500#-Spring 0.3 0.3 0.9 -- --

6.0 (6,8)

(Dresser) 15 2"-Pressure Relief

-1500#-Spring 1.2 1.0 1.3 -- --

6.0 (6,8)

(Dresser) 15 4"-Pressure Relief

-1500#-Spring 1.0 1.9 2.0 -- --

6.0 (6,8)

(Dresser) 15 3/4" Pressure Relief Valve (Crossby) 0.2 0.2 0.9 5.0 5.0 5.9 (2,8) 16 10"-Vacuum Breaker 10.4 15.9 14.5 -- -- --

(5)

(Anderson Greenwood) 17 1"-Globe Valve 2.3 2.3 1.2 6.5 6.5 6.0 (1,8)

(Hamhal Dahl) 17 2"-Globe Valve 2.3 2.3 1.2 6.5 6.5 6.0 (1,8)

(Hamhal Dahl) 18 1 1/2"-Conax Explosive 1.1 1.7 0.7 6.8 6.8 6.6 (2,9)

(Conax)

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TABLE B2 OPERABILITY VERIFICATION OF VALVE ASSEMBLIES COMPARISON OF ACTUAL & TEST ACCELERATIONS Group Valve Test Accelerations N Number Description Actual Accelerat. ions For Which Operability 0 Per Piping Analysis is Demonstrated T E

HI H2 V Hi H2 V S 19 3/4"-Check Valve 0.8 0.8 3.8 9.0 9.0 24.0 (1,10)

(General Electric) 19 3/4"-Globe Valve 0.8 0.8 3.8 9.0 9.0 24.0 (1,10)

(Robert Shaw) 19 1/2"-Globe Valve 0.8 0.8 3.8 9.0 9.0 24.0 (1,10)

(Robert Shaw) 19 1"-Check Valve 0.8 0.8 3.8 9.0 9.0 24.0 (1,10)

(General Electric) 19 1"-Globe Valve 0.8 0.8 3.8 9.0 9.0 24.0 (1,10)

(General Electric) 21 4"-Globe Valve 0.5 0.5 0.7 4.0 4.0 5.0 (1,10)

(Terry Turbine) 12

1 4

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i j TABLE B OPERABILITY VERIFICATION OF VALVE ASSEMBLIES 1

i j COMPARISON OF ANALYSIS & TEST RESULTS

NOTES

j 1) Valve Dynamically Tested: Biaxial or triaxial random i motion test.

2) Valve Dynamically Tested: Uniaxial sine dwell or sine beat test.
3) Valve Static-Pull Tested: Using resultant loads applied uniaxially in the most critical direction.

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4) Valve Static-Pull Tested: Using loads applied biaxilly.
5) Valve Impact Tested: Using maximum postulated closing /

opening disc velocities.

6) Valve Dynamically Tested: Uniaxial random motion test i with the load applied in the most severe direction.
7) Valve has been analyzed to the exact piping accelerations.
8) Valve was cycled (open-closed) during testing.
9) Special function valve. Operability verified after the test. Electrical continuity monitored during the test.
10) Valve was tested as part of an assembly to show operability as part of the entire system. System was operational 4 before, during, and after the seismic test.

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l ENCLOSURE 3 STAFF POSITION FOR ACCEPTANCE OF THE CLINTON STATION'S PDMP AND VALVE OPERABILITY PROGRAM -

Two PVORT audits were performed at the Clinton station and one documentation review was performed at the S&L headquarters in Chicago. Several outstanding concerns remain to be resolved. Qualification by analysis alone vs. analysis with test verification of the analysis has become the most significant issue.

The purpose of the S&L)HQ review was to give S&L the opportunity to demonstrate adequacy of their approach for qualification of valve components, in lieu of providing verification by test to demonstrate operability. S&L had catagorized all of the Clinton valves into 21 groups, from which the staff and its consultant selected 5 groups for audit. The documentation provided during that third audit reflected a clearer understanding by the applicant and S&L of the information needed to establish operability qualification. S&L's approach was to show valve qualification by test (s), performed for the most part on components in other groups, and similarity.

To supplement the information provided by the applicant to date, and based upon the experience gained from the three audits, the applicant should be required to (1) review all qualification documentation including test data to assure that all fluid dynamic concerns regarding operability qualification have been addressed, e.g. flow interruption capability, fatigue, cyclic, vibration, water hammer, thermal loads, corrosion, aging, and stress analysis, and (2) document the bases used to verify the adequacy of analysis including conservatisms in the analyses, and if similarity to another valve is used, the bases upon which the similarity has been established. Upon completion of this effort the applicant shall provide a statement confirming that the operability qualification of all valves within the scope of the program is complete, and that all documentation relied upon to demonstrate the qualifi-cation of each valve is in.an auditable format *. The attachment provides guidance regarding qualification documentation.

2_

For any valve assembly failure, i.e. inability to properly function, identified during preoperational testing conducted as of the end of February 1986 that is determined to be design, system, or fluid induced, the applicant shall, (1) perform an evaluation of the failure to determine the root cause, (2) reevaluate the qualification documentation to determine why the potential for this failure was not addressed previously, (3) verify that the qualification documentation still supports a conclusion that operability qualification is established, and (4) determine if the failure is an isolated case or has generic implications.

The applicant shall document the results of this effort in an auditable format and submit it to the NRC staff for review.

Completion of the above, as well as satisfactory responses to the open items from the three audits, should provide the staff with sufficient confidence to conclude that the Clinton Pump and Valve Operability Program is acceptable.

ATTACHMENT: Documentation-Excerpt from NUREG/CR-3914 Pump & Valve Qualification Review Guide

  • Auditable format-The documentation is organized in a readily understandable and traceable manner that permits independent auditing of that documentation and the conclusions drawn from it.

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ATTACHMENT

5. DOCUMENTATION The qualification documentation should verify that each component is qualified for its application and meets its specified perforcunce . require-ments. The basis of qualification.should be explained to show.the relation ship of all facets of proof needed to support adequacy of the complete equip-ment. Data used to demonstrate the qualification of the equipment should be pertinent to the application and organized in an auditable form. This section -

was taken from NUREG-0588 and IEEE 323 and modified to relate to pump and valve qualification.

5.1 FILES The applicant / licensee should maintain a qualification file that contains the following information, depending on the qualification method used.

5.1.1 Type Test Data The type test data should contain the following:

- Equipment performance specification.

- Identification of the specific feature (s) to be demonstrated by the test.

- Test plan.

- Report of test results:

- objectives,

- equiprent tested,

- description of test facility (test setup) and instrumentation used, in-cluding calibration and records reference,

- test procedures,

- test data and accuracy (results).

- acceptance criteria,

- sumnary, conclusions, and recommendations,

- supporting data,

- statement of similarity,

- approval signature and date.

5.1. 2 Operating Experience Data The operating experience data should contain the following:

- Equipnent performance speci fication.

- Interface or boundary conditions of the equipment.

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- Specifications of equipment for which operating experience is available. i

- Identification of the specific features to be demonstrated by operating experience. l

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- - Comparison of past application and specifications with the new equipment spe.ifications for each feature identified above.

- Summary and source of operating experience applicable to equipment qualifi-cation.

- The basis on which the data have been determined to be suitable and the -

equipment qualified.

- Approval signature and date.

5.1.3 Analysis The analysis data should contain the following:

- Equipment performance specification.

- Interface or boundary conditions of the equipment.

- Specific features, postulated failure modes, or the failure ef fects to be analyzed.

- Assumptions, empirically derived values, and rathematical models used, together with appropriate justification for their use.

- Description of analytical methods or computer programs used.

- Summary of analytically established performance characteristics and their i

acceptability.

.se :~ - Approval signature and date.

5.1.4 Extrapolation Where test data or operating experience data have been extrapolated, the basis and justification for the extrapolation should be included.

G

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ENCLOSURE 4 THE SQRT REVIEW STATUS OF THE CLINTON SEISMIC QUALIFICATION PROGRAM The following presents a summary of the status of the SQRT (seismic quali ,

fication review team) review of the applicant's program for the seismic qualification of safety-related equipment, in general, and of active valves in particular. It addresses the applicant's generic valve qualification program, their position and SQRT's concerns.

Activa Valve Qualfication Program a) The active valves for Clinton were procured by using a specification which allowed the vendor to use " analysis only" along with other choices to seismically qualify an active valve, including its operability. Most vendors opted to use an " analysis only" approach to qualify the active valves. IP/S&L reviewed and approved the qualification documents on this basis.

b) During the audit in August, 1985, the SQRT expressed concerns regarding the approach of qualifying active valves by " analysis only". Subsequently, IP/S&L collected test data for some valves (not necessarily Clinton valves) to demon-strate validity of their analysis models and techniques. Thus, IP/S&L attempted to justify the analysis approach generically.

c) In response to the SQRT's request to correlate the existing test data with the applicable valves, IP/S&L divided the entire active valve population into twenty-one (21) groups, during the SQRT's second audit conducted at S&L office in Chicago, Ill. , on Janaury 28 & 29, 1986, and provided reference to test data available, if any, for each group.

IP/S&L's Position IP/S&L maintains that " analysis only" is a valid method. They argue that once the analysis technique is validated by test results of a valve, other valves, which could be of different types (e.g., gate vs. globe) and sizes and/or from different manufacturers, can be qualified by analysis only, without a need for further test results.

I T'

SQRT Comment on IP/S&L's Position The SQRT believes that the key element in this review is similarity with the tested valves. Due to inherent complexities and nonlinear characteristics of valve assemblies, and the limitation of analytical models, the analysis technique may not be adequate to assess valve operability, which primarily depends on the deflection of the extended part of the valve. This is especially true due to the fact that the allowable and the actual deflections are of the order of 10 -2 inch or less. Moreover, it is the valve deflection rather than stresses that should be considered as the parameter for comparison of the analysis results with the test results so far as operability is concerned.

Instead valves groups, should be identified and similarity should be established by considering valve types, design, size, manufacturer, actuator types, etc.

SQRT Review ,

Since the SQRT did not agree with the qualification methodology adopted by IP/S&L to demonstrate operability of active valves, it was decided that the SQRT would study the valve groups with IP/S&L engineers to verify that similarity exists between the tested valves and other valves in the group, or whether judgement can be used (e.g. , short extended part, low as-built g-values, etc.) to accept the qualification. On this basis, SQRT studied various valve groups and reviewed some documents. IP/S&L engineers provided valve design drawings, available test results and some non-auditable similarity analyses.

Open Issues l

As a result of the study, it was found that a majority of the valves can be shown to be similar to the tested valves. Therefore, the SQRT study proved to be successful at least in reducing the number of valves in question.

'Of '

. -A-The following comments are offered by the SQRT regarding demonstration of operability of active valves, in addition to the other related comments for valves provided in the Clinton SSER No. 5.

1. Test report MR52600-570-1-1 was required for demonstration of similarity of valve No. V526-6310-4C (Ref. Group No. 2). This report was not available during the most recent audit, nor was it reviewed by IP/S&L. IP/S&L should review this document and present the findings to the SQRT for acceptance.
2) As stated above, there were documents presented during the most recent audit which are required for demonstration of valve similarity. All such similarity analyses should be corrected as needed and included in the qualification package in an auditable format. Note that the similarity analysis should address all individual valves, rather than just the generic valve group, to ensure that all valves in that group have been examined.
3. Adequate test data were not available to demonstrate operability of the following valves:

a) Anchor Darling Gate and Globe Valves, Group No.1, valves sizes 1" -24", various actuator sizes, population 152 (i.e., about 29%

of all active valves other than check valves and valves bought with HCU's).

b) 8" Crosby Relief Valves, Group No. 15.

IP should divide these valves into multiple groups based upon similarity, procedure the test report (or perform a valve operability test, if required) of a representative valve from each group, perform simiarity analyses for the remaining valves and submit the qualfication package to the SQRT for review and approval.

7_ .

-4 Other Equipment Specific Open Items SQRT comments to IP responses on other SQRT open issues were provide to IP during the most recent audit. A brief discussion was held on different SQRT items, especially on 80P-4, 6900 Volt switchgear. IP claimed that the SQRT form had described the safety functions, and all modifications had been implemented prior to the SQRT audit. IP submitted a version of the SQRT form in support of their statement. SQRT found this version of the form to be complete departure from what IP had identified earlier in the SQRT form submitted during the SQRT audit of August 1985 (see attachment 1). A similar inconsistency in IP's statement regarding a valve qualification status was observed during the active valve discussions (see attachment 2).

Here, an actuator was identified as installed and qualified while its support was still not in place. Based on the reviews conducted thus far, it is the SQRT's opinion that the applicant's seismic qualification program.is not supported by adequate documentation, and that the applicant continues to address only selected SQRT items. Therefore, an auditable filing system, consisting of all pertinent documentation, should be established by the applicant.

The above SQRT concerns on active valve qualification as well as on other equipment specific open items, must be satisfactorily resolved by the applicant before the staff can conclude that the Clinton seismic qualification program is acceptable.

7..

ATTACHiiENT ,1

y) .

y g y- E t;.H > #

P4 NS g f4 R 7 d M MY E .JgAGE 1 of 3 SElSMIC AND DYNAMIC QUALIFICATION

SUMMARY

OF

  • ALL CUESTIONS ARE TO BE ANSWERED (IF *
1. PLANT NAME:

Clinten Power Stetten .

1. UTILITY: -

tilinois Power Co. *

2. LOCATION:

Clinton. IL

3. TYPE: _ BWR 4
5. CAPACITY (MWe NET): __ 985 CONTAINMENT TYPE: _ M K. III 6.

T. NRC DOCKET NO.: COOLING SOURCE: _ Loke 50-46i 8. CP DOCKET DATE:

9. NSSS VENDOR: IO/30/T3 G. E. Co.
10. A/E __ Sorcent a Lundy i

II.

COMPONENT NAME: _ 6900V Switchgea$- (IAPOSE)

1. SCOPE: L_._} NSSS 2.

Ll] BOP VENDORi_ Westinghouse

3. VENDOR MODEL NO.
4. 6900V M ANUFACTURER.: Westinghouse _ 5.

i

6. MANUFACTURER MODEL NO.: _6900V PURCHASE SPEC. NO.K-2968 7.
8. TOTAL NO. IN SAFETY SYSTEMS: 1 LOCATION A. (CHOOSE THE WORST ONE WITH RESPE BUILDING: _ Auxiliary B.

C.

ENVIRONMENT: I ELEVATION AND AREA: _ 762

HARSH MILD

9. FIELD MOUNTING:

A. FLOOR WALL L } PIPE I

1. PANEL U OTHER (DESCRIBE) _ ~

B.

W BOLTED; DESCRIPTION: _6/ Cubicle 4"O SAE GR-5 imo., sut. amant. E tC. >

n WELDED; DESCRIPTION:

L _J OTHER; DESCRIPTION: (s41. Et at in. LL ECT ACDC T T Pt. (TCJ C.

MOUNTING RESTRICTION FROM THE MANUFACTURER VERTIC AL, ETC.) _

ANY: (HORIZONTAL lF NONE

  • 10.

FUNCTIONAL DESCRIPTION OF THE EQUIPMENT:

A.

SYSTEM IN WHICH LOCATED: Auxiliary Power (AP)

B. (FORITim etaes.aeovt>

TYPE: rT"1 ACTIVE ,

n PASSIVE

> S&% 0N v&y U N

tcont'd) BQP 4 Page 2 of 3 C. EculPMENT REOUIRiD FOR: I I HOT STANDBY I I COLD SHUTDOWN

, ~ . -

L2J NEIThER U D. INTENDED SAFETY FutjCTION: NONE L (

a E .' DIRECT CONSEOUENCES OF ITS FAILURE (BRIEF DESCRIPTION O EFFECT ON THE SYSTEM):

F. REDUNOANCIES, IF ANY:

n. EQUIPMENT OUALIFICATION METHOD:

IT 1 TEST I I ANALYSIS I

1 COMBINATION OF TEST 8 ANALYSIS I I OTHER (DESCRIBE )

IV LOADS AND LOAD COMBINATIONS:

1. LOADS: -

A. L_.JJ SEISMIC B. L.2] HYDRODYNAMIC C. I i FLOW INDUCED VIB. D. I I NORMAL OPERATION VIB.

E. I I OTHER DYNAMIC LOADS: ( SPECIFY )

2. COMBINATION TECHNIOUE: ABS (SRSS Required) .

3.

REQUIRED ACCELERATION IN EACH DIRECTION: See Attached RRS Curves A. I I ZPA I I OTHER;SPECIFY:

B. OBE: S/S  ; F/B:  ; V:

SSE: S/S  ; F/B:  ; V:

V CUALIFICATION BY TEST (COMPLETE THIS SECTION FOR EACH REPORT INCLUD PARTIAL TEST):

1.

TEST REPORT: (COMPANY) __ Westinghouse A.. TITLE: Dynamic Qualification of Clinton Plant 7.5kV Switch-gear Assemblies for Illinois Power Company NO.:WCAP-10328  ; REVISION: 0  ; DATE: _ October 1983 B.

REVIEWED BY! Sargent & Lundy (Qualification Report SQ-CL366)

2. QUALIFICATION REPORT: ( COMPANY ) Westinghouse A. TITLE: Dynamic Qualification of Clinton Plant 7.5kV Switch-gear Assemblies for Illinois Power Company NO. WCAP-10328 ; REVISION; O  ; DATE: October 1983 i B.

REVIEWED BYi Sargent & Lundy (Qualification Report SQ-CL366)

C;C r

mw u w.

BOP 4

- PAGE 3' of 3 l

  • r )?

(a) During several of the test runs, contact bounce was detected on the type SSC-T relays and the ITTH and SSC-T elements on the type COM-5 relays, during the relay non-operating modes. IPC and Sargent & Lundy Engineers evaluated the problem and determined that the contact bounce of the relays and the premature actuation of the DVP breaker were not safety related malfunctions and thus were considered acceptable for Clinton applications.

(b) In order to continue testing, a modification was made to the bifurcation CT's. The phase A rear CT=which had borken_locse was replaced with a new identical CT. All six of the CT's were then strapped to the CT support bracket by heavy duty flat cable ties (two per each CT).

The unit was then rotated 90 clockwise and mounted to the table.

't (c) The modifications made during the test (see Item (b) above) f need not be implemented in the field since the failure of the non-lE CT's is not a safety related failure. Thus, l the mounting modifications are only suggested by the vendor, are not required and have not been implemented.

1 i

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.7 l

  1. j _ ___ _ _

ATTACHMENT 2 ,

, ILLINOIS POWER COMPANY I/fu-CLIt. TON POWER STATION,

. DOCKET NUMBER 50-461 SEISNIC OUAL/ INST STATUS BY SYSTEM /EQUIPM NUMBEN

...=

==.......=...........................ENT .........

l SYSTEM EOUIPMENT NUMBER MANUFACTURER / MOD

.................................=.........EL EX ISXO20A(V)

NUMBER [INSTALLEDjOUALIFIED SX 1SXO23B(L)

Fshr/Cnt V1v 657NS/ES Yes Yes SW Namco/EA100 Yes 'Yes ISXO23B(0) Asco/Viv 2068323U SX No Yes 1SX023B(OS) Conax/N-11135-03 SX 1SXO23B(V) No Yes Sr 1SXO25A

- Fshr/Cnt V1v 657NS/ES Yes- Yes GrvCrp/V1v Act SX iSXO25A(V) Jmsbry/2" CU Viv -]4Y es Yes EX 1SXO25B GrvCrp/V1v Act Ws Yes SX ISEC25B(V) Yes No Jmsbry/2" Ball Viv Yes SX 1SX025C GrvCep/V1v Act Yes SX ISXO25C(V) Yes No Jmsbry/BWS 2236 Viv Yes SX iSXO27A(L) Yes SX Namco/EA180 Yes Yes iSXO27A(0) Asco/Viv 2068323U SX 1SXO27A(OS) No Yes SX Conax/N-11135-03 No Yes 1SXO27A(V) Fshr/Cnt Viv 657NS/ES SX 1SXO27B(L) Yes Yes SX Namco/EA180 Yes Yes 1S XO27B (0)

EX iSXO27B(V)

Asco/Viv 2068323U No Yes SX Fsh,r/Cnt V1v 657NS/ES Yes Yes 1SXO27C(L) Namco/EA180 SX 1SX 027C (0) Yes Yes SX 1SXO27C(OS)

Asco/Viv 2068323U No Yes SX Conax/N-11135-01 No Yes iSYO27C(V)

SX ISXO29A(L) Fshr/Cnt Viv 657NS/ES Yes Yes SX Namco/EA180 Yes Yes iSX029A(0) Asco/Viv 2068023U SX 1SXO29A(OS) No Yes SX 1SXO29A(V)

Conax/N-11135-03 No Yes SX 1SXO29B(L)

Fshr/Cnt Viv Yes Yes Namco/EA180 Yes SX ISX029B(0) Yes SX 1SXO29B(OS)

Asco/Viv 2068323U No Yes SX Conax/N-11135-03 No Yes ISX029B(V) Fshr/Cnt Viv SX 1 S XO29C (L) Yes Yes Namco/EA180 Yes SX iSXO2cC (0) Yes SX iSXO29C(OS)

Asco/V1v 2068323U No Yes SX 1SXO29C(V)

Conax/N-11135-01 No Yes SX ISXO2MA Fshr/Cnt V1v 657NS/ES Yes Yes SX iSXO2MB PathBell/6" Exo Joint Yes No PathBell/6" Exp Joint Yes SX 1SX02MC No PathBell/6" Exp Joint Yes SX iSXO32 No SX A/D/2.50 GLOBE VLV Yes No iSXO33(L) Namco/EA180 SX 1SXO30(O) Yes Yes SX Asco/V1v 2068023U No Yes 1S XO30 (OS) Conax/N-11135-01 SX ISXO33(V) No Yes SX iSXO37(L) Fshr/Cnt V1v 657NS/ES Yes Yes SX Namco/EA180 Yes Yes 1 SX O37 (O)

SX iSXO37(OS)

Asco/Viv 2060323U No Yes BX Conax/N-11135-03 No Yes 1SXO37(V) Fshr/Cnt V1v 3X ISXO3MA Yes Yes 3X PathBell/6" Exp Joint Yes Yes ISXO3MB PathBell/6" Eup Joint l 5X iSXO41A(L) Yes Yes Namco/EA180 Yes Yes ,

iT '

I d -

. o 1

J i

Since the meeting the staff has identified the additional actions required of IP to achieve final resolution of both these issues. Enclosures 3 and 4 con-tains these actions which have also been informally provided to and discussed with IP on January 20, 1986. IP has stated they understand the staff's position on these issues and will comply with the actions identified in Fnclosures 3 and

4. These positions will be sent to IP once they are officially ceceived from the technical review branch.

~

Orighud Samalby

! Byron L. Siegel, Project Manager BWR Project Directorate No. 4 i Division of BWR Licensing i

i

Enclosure:

l As stated cc: See next page 4

i T,ocket' DISTRIBUTION-File

! NRC PDR Local PDR PD#4 Reading WButler BSiegel Goddard, OELD i EJordan

)

BGrimes ACRS (10)

MTG Participants i

  • Previously concurred:

PD#4/PM PD#4/D

  • BSiegel:1b *WButler 03/11/86 03/11/86 i

1 l -. __

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