ML20196B878

Forwards Util Comments on Draft in Re Inservice Testing of A-4 Multimatic Deluge Valves at Plant

ML20196B878
Person / Time
Site:	Farley
Issue date:	11/20/1998
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	Berkow H NRC
References
NUDOCS 9812010204
Download: ML20196B878 (4)

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'4 Dave Morey Southern Nucl:ar :

Vice President Op: rating Company Fatley Project

RO. Box 1295 Birmingham. Alabama 35201 Tel 205.992.5131 SOUTHERN h November 20, 1998 COMPANY Energy to ServekrWort.P j

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Docket Nos.: 50-348 50-364 i

Mr. Herbert N. Berkow, Director Division ofReactor Projects U.S. Nuclear Regulatory Commission Mail Stop 14H25 PD II-2/NRR i

Washington, DC 20555-0001 1

Joseph M. FarleyNuclear Plant Comments on DraA Information Notice Regarding In=arvice Tastino of the A-4 Multimafir Delnaa Valve i

Dear Sir.

Southern Nuclear Operating C====y has reviewed the draA Information Notice (IN) regarding our experiences with the Model A-4 Multimatic Deluge Valves at Farley i

Nuclear Plant. Our comments are attached. It is our understanding that this dran IN has j

also been provided to the valve manufacturer for review.

If you have any questions, please advise.

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Respectfully submitted,

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i Dave Morey l

LLB/ cit: comments. doc At*=ehmant 0

cc: ' Mr. L. A. Reyes, Region II Administrator

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Mr. J. I. Zimmerman, NRR Project Manager Mr. T. P. Johnson, FNP Plant Sr. Resident faMar 9812010204 481120/~

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.1 ATTACHMENT 4

Southern Nuclear Operating Company Comments on Draft Information Notice Regarding Inservice Testing of the A-4 Multimatic Deluge Valve i

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ATTACHhENT l

Southern Nuclear Operating Company Comments on Draft Information Notice Regarding Inservice Testing of the A-4 Multimatic Deluge Valve

1. In the third paragraph on page 2, it is stated that "the [soleno:d] valves may not be able to open against this pressure." While this has been hypothesized, testing has not been conducted by either Farley Nuclear Plant or Grinnell to prove or disprove this hypothesis.

2. The third paragraph on page 2 states that the team found that the diaphragm and retainer were being lubricated to keep the retainer from sticking. This is not correct. The team considered recommending this, but the valve manufacturer did not support it and the licensee did not lubricate the diaphragm and retainer. The A-4 manufacturer recommends that the valve not be lubricated in any manner.

3. The fourth paragraph of page 2 states that "This condition.. could prevent the clapper from opening." This hypothesis has not been proved or disproved by either Farley Nuclear Plant testing or Grinnell testing.

4. The last sentence of the fourth paragraph states that "The licensee used its own trim.

i The design and installation of the sprinkler system at Farley, including the control valve, trim, and drain lines were performed by Grinnell.

5. To be consistent with the time-line of events, the last paragraph on page 2 should be moved to after the third paragraph (switch the last two paragraphs on the page).

6. The first paragraph on page 3 states that one valve "was manually tripped by forcing the j

push rod back." This is not technically correct in that the main isolation valve is closed and the valve faceplate is removed before the push rod can be moved manually.

Therefore, the valve does not " trip." The following statement would be more accurate:

"One valve failed to trip, and the push rod had to be manually (by hand) forced back after:

completely isolating and draining the diaphragm chamber, closing the main isolation valve, opening the main drain, and opening the valve faceplate."

7. The first paragraph on page 3 states that "the pushrod was misaligned in the retainer ring.

" This was by visual observation, not direct measurement; replacing "was" with

" appeared to be" would be more accurate.

8. The first paragraph on page 3 refers to "The licensee's description of the diaphragm problems..." in the attachments. These were interim hypotheses that have not been proved or disproved by FNP or Grinnell testing. SNC recommends removal of these unproven hypotheses from the IN.

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ATTACHMENT i

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9. A paragraph similar to the following should be considered for addition after the second paragraph on page 3:

The team commissioned by the licensee to study the problems with the A-4 valves i

concluded that, while the cause and effect are not known, it appears that the l

l phenomena occurred within a pressurized valve, which over time caused the valve to fail. The team noted that leaving the valves pressurized for a significant length of time is not recommended by the manufacturer.

10. In the first paragraph under Discussion on page 3, it should be clarified that the following statements have not been proved or disproved by FNP or Grinnell testing:

"the diaphragm could bond..., "

e "the diaphragm may remain partially bonded..., " and e

" bonding may be particularly pronounced in systems using well water or raw river e

water. "

11. The first paragraph of page 4 is not clear and is incorrect regarding water trapped in the diaphragm chamber supply line. SNC recommends the following be inserted in place of the existing paragraph:

l While reviewing this event, the staff noted that the licensee performs full flow testing.

It is the staffs understanding that many plants isolate the deluge valves from the main water supply during valve testing This practice may mask the actuation problems identified herein. Note that National Fire Protection Association Standard 25,

" Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems," 1995 editions, section 9-4.3.2.2 states: "Each deluge or preaction valve shall be trip tested annually at full flow [ emphasis added] in warm weather and in accordance with the manufacturer's instructions." The valve manufacturer may also have special requirements for inservice testing. The A-4 valve manufacturer recommends partial flow testing where full flow testing is undesirable.

12. The second paragraph on page 4 begins "A similar event...." The event involved a different model of valve and may be unrelated to the event at FNP.

13. The last paragraph on page 4 discusses " repeated failures" of a Star Model *D" valve.

This event involved a valve with a different manufacturer and may be unrelated to the event at FNP.

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