ML20195C906

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Forwards Response to Action Item E of 851115 IE Bulletin 85-003 Re safety-related Motor Operated Valve Failures. Response Methodology Based on Snupps Design for Hpis & Auxiliary Feedwater Sys
ML20195C906
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/14/1986
From: Schnell D
UNION ELECTRIC CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
IEB-85-003, IEB-85-3, ULNRC-1309, NUDOCS 8606020019
Download: ML20195C906 (9)


Text

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  • saa UNION ELECTRIC COMPANY 1901 Grotiot Street. St Louis Donald F. Schnell

- Vice President May 14, 1986 Mr. James G. Keppler.

Regional Administrator USNRC Region III 799 Roosevelt Road, Glen Ellyn, IL 60137 ULNRC-13 09

Dear Mr. Keppler:

DOCKET NO. 50-483 CALLAWAY PLANT FACILITY OPERATING LICENSE NPF-30 SAFETY-RELATED_ _ MOTOR-OPERATED _ VALVE PROGRAM

Reference:

NRC I&E Bulletin No. 85-03, dated November 15, 1985 This letter provides the Union Electric response to Action Item e of the referenced NRC Bulletin concerning safety-related motor-operated valve (MOV) common mode failures.

Action Item e required holders of Operating Licenses to review and document the design basis for the operation of MOVS in the high pressure coolant injection / core spray and emergency feedwater systems that are required to be tested for operational readiness in accordance with 10 CFR 50.55a(g).

The results of this review are to be used to establish a program to review and revise, as necessary, the methods for selecting and setting all switches (i.e., torque, torque bypass, position limit, overload) for each valve operation (opening and closing).

The design basis review and the schedule for the completion of this program constitutes the required Action Item e 180 day response.

The Union Electric response is based on methodology developed by the i

Westinghouse Owners Group (WOG) for member utilities.

This methodology is based on the SNUPPS design for the high pressure injection system and auxiliary feedwater system.

The fluid systems evaluation was used to determine the maximum operating differential pressure for all system operating modes and design basis events using the maximum pressure producing capability of the system equipment.

The only exception taken with this methodology is to delete valves HV-5, 7, 9, and 11 from the auxiliary feedwater valve list (Table 2).

These valves are used for flow control purposes in the Callaway design and as such are exempted f rom this review by Paragraph INV-1200,Section XI of the ASME Code.

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Tables 1 and 2 provide information on the valves in the high pressure coolant injection system and the auxiliary feedwater system respectively.

This information consists of:

1)

The MOV as listed by valve number.

2)

The valve location.with a brief description of the valve function.

3)

The design equipment specification differential pressure for opening and closing each valve.

4)

The maximum operating differential pressure for opening and closing each valve.

5)

A.brief justification statement for.the maximum operating differential pressure for opening and closing each valve based on system configuration and equipment restraints.

6)

A survey performed on the Emergency Response Guidelines (ERGS) to confirm operating assumptions.

The ERG Survey determined when the MOVs are required to function for emergency operation.

In addition, the survey identified other important characteristics of the system operation which impact the MOVb capability to function as well as a check of current ERG operations against the original fluid system design assumptions for MOV operating modes. provides the schedule for completion of Action Items b through d of Bulletin 85-03.

Each valve will be demonstrated operable (Action Item c) at the maximum differential pressure by testing at the maximum differential pressure or by signature analysis type testing.

If signature type testing is used, justification will be developed showing how this type of testing demonstrates valve operability.

Any additional information needed to accomplish the closecut of this Bulletin will be transmitted'via the final submittal which will incorporate a summary of the data and findings as found through the completion of this program.

Very truly yours, if

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.F Donald F.

Schnell WEK/ tar Attachments

STATE OF MISSOURI )

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SS CITY OF ST. IOUIS )

Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has e.:ecuted the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By Donald F.

Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this

/M-day of

,198d.

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BARBARA J. PFAFF NOTARY PUBLIC, STATE OF MISJ00m MY COMMISSION EXPIRES APRIL 22,196J ST. LOUIS COUNTY

cc:

Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M.

Street, N.W.

Washington, D.C.

20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 C. W. Hehl Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Of fice U.S. Nuclear Regulatory Commission RR$1 Steedman, Missouri 65077 Paul O'Connor Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commicsion P.O. Box 360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

AttcchOnt 1 to ULNRC-1309 P;ga 1 of 5 TABLE 1 HIGH PRESSURE INJECTION VALVE DIFFERENTIAL PRESSURES Maximum ERG Design Operating Justification Confirmation Callaway Plant (E-SPEC) AP AP for Max of Operating MOV Valve Number Close Open Close Open Operating AP Assumptions Safety Injection 8806 A&B 200 200 200 50 Open - 2 Yes Purp Suction Close - 1 from RWST Safety Injection 8923 A&B 200 200 200 50 Open - 2 Yes Purp Suction Close - 3 from RWST CVCS Pump Suction LCV-112 D&E 200 200 200 50 Open - 4 Yes from RWST Close - 4 CVCS Pump Suction LCV-ll2 B&C 100 200 100 100 Open - 5 Yes from VCT Close - 5 SI Pump 8821 A&B 1500 1500 1500 1500 Open - 15 Yes Cross-Connect Close - 14 SI Pump Discharge 8835 0

2750 0

1750 Open - 7 Yes Isolation Close - 6 CVCS Normal 8105 2750 2750 2750 2750 Open - 8 Yes Discharge 8106 Close - 8 Isolation BIT Inlet 8803 A&B 0

2750 0

2750 Open - 9 Yes Isolation Close - 6 (See Table 1 Footnote 1)

BIT Outlet 8801 A&B 0

2750 0

2750 Open - 9 Yes Isolation Close - 6 (See Table 1 Footnote 1)

SI Pump Miniflow 8813 2750 2750 1750 1750 Open - 11 Yes 8814 A&B Close - 10

.CVCS Pump 8110 2750 2750 2750 2750 Open - 13 Yes Miniflow 8111 Close - 12 to ULNRC-1309 Page 2 of 5 JUSTIFICATIONS FOR TABLE 1 1.

This valve must be able to close to isolate the RWST from the discharge of the RHR pumps during the recirculation mode of operation, as a precautionary measure in the event of backleakage through check valve 8926A (or B).

For this scenario, the AP across 8806A (or B) could be as high as the RHR pump discharge head N200 psig.

2.

This valve is normally open, and is closed only for stroke testing and/or pump isolation for maintenance.

The valve must be able to open against a full RWST head of water.

For Callaway, this isN 50 psig.

3.

This valve must be capable of isolating (closing) one high head safety injection pump, given a passive failure in that train of ECC S.

For this scenario, the AP across 8923A, B could be as high as the RHR pump discharge head N200 psig.

4.

Same as 8806A, B (for both close and open), except these valves are in the suction of the centrifugal charging pumps and not the high head safety injection pumps.

5.

These valves must close on an "S" signal; the maximum AP across the valve is defined by the volume control tank at its design pressure (relief valve setpoint) of 75 psig plus elevation head of the VCT above the valves.

This is estimated to be N100 psig.

6.

Valve is only closed when pump is not operating; no flow - no AP.

7.

Pump testing on miniflow circuit, AP is determined by the miniflow head of high head safety injection pump N1750 psig.

8.

These valves must be able to isolate the RCS from the CVCS, with a N the shutoff head of the centrifugal maximum possible AP of charging pumps.

9.

Given a miniflow test of the centrifugal charging pumps, the DIT isolation valves must be able to open with a AP $ equal to the charging pump shutoff head.

10.

Valves must close to isolate miniflow so that high pressure i

injection switchover to recirculation may proceed.

In the worst case, the AP will be equal to the pump developed head on miniflow N1750 psig.

11.

Similar to 10, except valve must be able to open during miniflow testing of the high head safety injection pump.

12.

Valves must close to ensure adequate high pressure injection flow (on "S"

signal) against miniflow AP N2750 psig.

13.

Similar to 12, except value must be able to open during miniflow testing.

. to ULNRC-1309 Page 3 of 5 14.

Must be able to move to allow realignment to ECCS to recirculation mode, and for ECCS train separation.

Delta-P could be as high as 1500 psig s equal to miniflow head of high head safety injection pump.

15.

Must be able to open to allow train separation during the recirculation phase of ECCS operation.

Delta-P same as closing.

FOOTNOTE TO TABLE 1 1.

The ERG guidelines to terminate safety injection (isolate the BIT),

and return to normal charging are performed with the centrifugal charging pumps operating.

This termination method reduces net RCS makeup in a controlled manner and maintains continuous reactor coolant pump seal injection.

Since the charging pumps are operating, the BIT isolation valves must close against a AP.

This AP could be large for some SI termination scenarios (RCS could be as low as 200 psi - A P could be as high as 2500 psi).

I Atttch02nt -1 to; ULNRC-1309 P;ga 4 of 5 TABLE 2 AUXILIARY FEEDWATER SYSTEM VALVE DIFFERENTIAL PRESSURES i

Maximum ERG l

Design Operating Justification Confirmation l

Callaway Plant (E-SPEC) AP aP for Max of Operating l

MOV Valve Number Close Open Close Open Operating _aP Assumptions i

i Mechanical Trip HV-312 1275 1275 1220 1220 Open - 1 Yes I

and Throttle close - 1

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Suction from HV-34, 35, 36 150 150 17 17 Open - 2 Yes j

CST - All Pumps Close - 2 Suction from HV-30,31,32,33 200 200 180 180 Open - 3 Yes j

Essential Close - 3 i

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Page of 5 JUSTIFICATIONS EUR TABLE 2

,3 1.

. Lowest steam. generator, safety valve set pressure plus 3 percent a?:cumulation.

2.

Stati.c elevation head of the condensate, storage tank.

3.

Discharge head of the_ service water pumps at miniflow.

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. to ULNRC-1309 Page 1 of 1 Items Scheduled Completion Date 1.

Review and document the design 5/01/86 basis for each motor-operated valve 2.

Provide a written report satisfying 5/14/86 Action Item e 3.

Establish the correct switch settings Prior to Refuel II for : the remaining 14 motor-operated completion or 11/15/87 valves *

(whichever is first) 4.

Perform an evaluation of the current Prior to Refuel II switch settings for the remaining 14 completion or 11/15/87 motor-operated valves *

(whichever is first) 5.

Test the motor-operated valves per Prior to Refuel II the requirements of Action Item c completion or 11/15/87 (whichever is first) 6.

Prepare or revise procedures to ensure 11/15/87 that correct switch settings are determined and maintained throughout the life of the plant 7.

Provide a written report on the completion 11/15/87 of the above program 16 valves have been tested and the switch settings verified using signature analysis testing.