ML20197K020
| ML20197K020 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 05/15/1986 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1642K, IEB-85-003, IEB-85-3, NUDOCS 8605200234 | |
| Download: ML20197K020 (12) | |
Text
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,/O. Commonwealth Edison
~ ) One First Nitional Plaza. Chicago. Illinois (O
Address Riply to: Post Ofhce Box 767 Chicago, lilinois 60690 May 15, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Dresden Station Units 2 and 3 Quad Citics Station Units 1 and 2 Zion Station Units 1 and 2 LaSalle County Station Units 1 knd 2 Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Response to I&E Bulletin 85-03 NRC Docket Nos. 50-237/249, 50-254/265, 50-295/304. 50-373/374. 50-454/455. 50-456/457
Dear Mr. Keppler:
This bulletin focuses on motor-operated valves in high pressure coolant injection / core spray and emergency feedwater systems (RCIC for BWR's) that are tested in accordance with 10 CFR 50.55a(s). Attachment A of this letter contains a list of valves for each Commonwealth Edison station which meet the criteria above.
Coramonwealth Edison proposes to demonstrate operability of these motor-operated valves by testing them, where practicable, under the differential pressure resulting from the maximum producing capability of the system equipment for normal system operating modes. Therefore, the extent of our review under action item (a) of this bulletin was limited to determining the differential pressure expected across the valves. This determination was not made so switch settings could be analytically determined, but so it could be determined whether test conditions approximating design conditions could be attained. By testing these valves under differential pressure, we intend to demonstrate that our existing methodologies for setting switches in valve motor operators are reliable and adequate. We believe the main thrust of this bulletin is to request a demonstration of valve operability and not to mandate research to establish new analytical methods for determining switch settings.
We believe valve testing satisfies that goal.
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J. G. Keppler May 15, 1986 Attachment B of this letter contains the response to the individual action items of the bulletin.
Please direct any questions regarding this matter to this office.
Very truly yours, K. A. Ainger Nuclear Licensing Administrator bs Attachments cc:
U.S. Nuclear Regulatory Commission Document Control Deck Washington DC 20555
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ATTACHMENT A Motor-Operated Valves Within The Scope Of IE Bulletin 85-03
- Dresden Station Units 2 and 3
- Quad Cities Station Units 1 & 2
- Zion Station Units 1 and 2
- LaSalle County Station Units 1 and 2
- Byron /Braidwood Stations Units 1 and 2 1642K
4 DRESDEN STATION UNITS 2 AND 3 Valve ID Number System Description 2&3-2301-03 HPCI Turbine Steam Supply Isolation 263-2301-04 HPCI Turbine Steam Supply Inboard Isolation 2&3-2301-05 HPCI Turbine Steam Supply Outboard Isolation 2&3-2301-06 HPCI Pump Suction Isolation from Condensate Storage Tank 2&3-2301-08 HPCI Vessel Injection Isolation 2&3-2301-14 HPCI Pump Minimum Flow 2&3-2301-35 HPCI Pump Suction Isolation from Suppression Pool 2&3-2301-36 HPCI Pump Suction Isolation from Suppression Pool RCIC (THERE IE NO RCIC AT DRESDEN)
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OUAD CITIES STATION UNITS 1 AND 2 Valve ID Number System Description 142-2301-03 HPCI Turbine Steam Supply Isolation 1&2-2301-04 HPCI Turbine Steam Supply Inboard Isolation 1&2-2301-05 HPCI Turbine Steam Supply Outboard Isolation 1&2-2301-06 HPCI Pump Suction Isolation from Condensate Storar,e Tank 1&2-2301-08 HPCI Vessel Injection Isolation 1&2-2301-09 HPCI Pump Discharge Injection Line Isolation 1&2-2301-10 HPCI Pump Discharge to Condensate Storage Tank (Test Line) 1&2-2301-14 HPCI Pump Mininum Flow 1&2-2301-35 HPCI Pump Suction Isolation from Suppression Pool 1&2-2301-36 HPCI Pump Suction Isolation from Suppression Pool 1&2-1301-16 RCIC Turbine Steam Supply Inboard Isolation 1&2-1301-17 RCIC Turbine Steam Supply Outboard Isolation 1642K
I ZION STATION UNITS 1 AND 2 Valve ID Number System Description 1&2NOV-SI8800A SI Charging Pump Cold Leg Injection 1&2NOV-SI8800B SI charging Pump Cold Leg Injection 1&2NOV-SI8800C SI Charging Pump Cold Leg Injection 1&2NOV-SI8800D SI Charging Pump Cold Leg Injection 1&2NOV-SI8801A SI Boron Injection Tank Outlet Isolation 1&2NOV-SI8801B SI Boron Injection Tank Outlet Isolation 1&2NOV-SI8802 SI SI Pump Cold Leg Injection 1&2NOV-SI8803A SI Boron Injection Tank Inlet Isolation 1&2NOV-SI8803B SI Boron Injection Tank Inlet Isolation 1&2NOV-SI8806 SI Pump Suction Isolation from Refueling Water Storage Tank 1&2NOV-SI8923A SI Pump Suction Isolation from Refueling Water Storage Tank 1&2NOV-SI8923B SI Pump Suction Isolation from Refueling Water Storage Tank 1&2MOV-SI9010A SI Cold Leg SI Cross-Tie 1&2MOV-SI9010B SI Cold Leg SI Cross-Tie 1&2NOV-VC8105 CVCS Charging Pump Discharge Isolation to Regenerative Heat Exchanger 1&2NOV-VC8106 CVCS Charging Pump Discharge Isolation to Regenerative Heat Exchanger 1&2NOV-VC8110 CVCS Charging Pump Minimum Flow Isolation 1&2MOV-VC8111 CVCS Charging Pump Minimum Flow Isolation 1&2NOV-VC-LCVll2B CVCS Charging Pump Suction Isolation from Volume Control i
Tank 162NOV-VC-LCV112C CVCS Charging Pump Suction Isolation from Volume Control Tank 1&2NOV-VC-LCV112D CVCS Charging Pump Suction Isolation from Refueling Water Storage Tank 1&2NOV-VC-LCV112E CVCS Charging Pump Suction Isolation from Refueling Water Storage Tank 1&2NOV-SWO101 SW AFW Pump Suction Isolation from Service Water 1&2NOV-SWO102 SW AFW Pump Suction Isolation from Service Water 1&2NOV-SWO103 SW AFW Pump Suction Isolation from Service Water 1&2NOV-SWO104 SW AFW Pump Suction Isolation from Service Water 1642K 1
LASALLE COUNTY STATION UNITS I and 2 Valve ID Number System Description 1&2E22-F001 HPCS Pump Suction Isolation from Condensate Storage Tank 1&2E22-F004 HPCS Vessel Injection Isolation 1&2E22-F012 HPCS Pump Minimum Flow 1&2E22-F015 HPCS Pump Suction Isolation from Suppression Pool 1&2E51-F008 RCIC Steam Supply Outboard Isolation 1&2E51-F010 RCIC Pump Suction Isolation from Condensate Storage Tank 1&2E51-F013 RCIC Vessel Injection Isolation 1&2E51-F019 RCIC Pump Minimum Flow Bypass 1&2E51-F031 RCIC Pump Suction Isolation from Suppression Pool 1&2E51-F045 RCIC Turbine Stop Upstream Isolation 1&2E51-F046 RCIC Turbine Lube Oil Cooler Supply Stop 1&2E51-F063 RCIC Steam Supply Inboard Isolation 1&2E51-F064 RCIC Steam Supply to RHR Heat Exchangers 1&2E51-F068 RCIC Turbine Exhaust Isolation to Suppression Pool 1&2E51-F069 RCIC Barometric Condenser Vacuum Discharge Stop 1&2E51-F076 RCIC Steam Supply Warm-up Bypass 1&2E51-F080 RCIC Turbine Exhaust Vacuum Breaker Inlet Stop 1&2E51-F086 RCIC Turbine Exhaust Vacuum Breaker Outlet Stop 2E51-F091 RCIC Turbine Steam Supply Outboard Isolation Bypass 1642K O
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BYRON /BRAIDWOOD STATIONS UNITS 1 AND 2 Valve ID Number System Description 1&2MOV-SI8801A SI Boron Injection Tank Outlet Isolation 1&2MOV-SI8801B SI Boron Injection Tank Outlet Isolation 1&2MOV-SI8806 SI Pump Suction Isolation from RWST 1&2MOV-SI8821A SI Cold Leg Injection Cross Tie 1&2MOV-SI8821B SI Cold Leg Injection Cross Tie 1&2MOV-SI8835 SI SI Pumps Discharge to Cold Leg Injection 1&2MOV-CV112B CVCS Volume Control Tank Isolation 1&2MOV-CV112C CVCS Volume Control Tank Isolation 1&2MOV-CV112D CVCS Charging Pump Suction Isolation from Refueling Water Storage Tank 1&2MOV-CV112E CVCS Charging Pump Suction Isolation from Refueling Water Storage Tank 1&2MOV-CV8105 CVCS Charging Pump Discharge Isolation to Regenerative Heat Exchanger 1&2MOV-CV8106 CVCS Charging Pump Discharge Isolation to Regenerative Heat Exchanger 1&2MOV-AF006A AF Essential Service Water Inlet to AFW Pump Suction 1&2MOV-AF006B AF Essential Service Water Inlet to AFW Pump Suction 1&2MOV-AF017A AF Essential Service Water Inlet to AFW Pump Suction 1&2MOV-AF017B AF t Essential Service Water Inlet to AFW Pump Suction T
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ATTACHMENT B Action Item A Review and document the design basis for the operation of each valve.
This documentation should include the maximum differential pressure expected during both opening and closing the valve for both normal and abnormal events to the exten,t,that these valve operations and events are included in the existing, approved design basis, (i.e., the design basis documented in pertinent licensee submittals such as FSAR analyses and fully-approved operating and emergency procedures, etc.).
When determining the maximum differential pressure, those single equipment failures snd inadvertent equipment operations (suen as inadvertent valve closures or openings) that are within the plant design basis should be assumed.
Response
The design basis differential pressure conditions for the valves listed in Attachment A have been compiled.
Single equipment failures or inadvertent equipment operations within the design basis of the plant have been considered in the development of the design basis fluid conditions. This information regarding design basis differential pressure conditions will be used in the development of the valve test program to determine which valves can be tested at actual design basis conditions and which valves will require justification to test at less than design basis conditions.
Action Item B Using the results from item a above, establish the correct switch settings. This shall include 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).
If the licensee determines that a valve is inoperable, the licensee shall also make an appropriate justification for continued operation in accordance with the applicable technical specification.
Response
Based on current practices and operational experience, Commonwealth Edison believes the correct switch settings have been established for motor-operated valves. Nevertheless, we will review our methods for establishing the torque bypass, position limit and overload switches and make any improvements, if necessary. We expect to complete these reviews and any necessary revisions by September 1, 1986.
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. With respect to the torque switch, we believe the current method for establishing the proper setting is adequate and no further review is necessary. The following outlines the method for establishing the torque switch setting.
Limitorque calculates torque switch settings based on Commonwealth Edison specifications (including A/E and NSSS specifications, as appropriate) and valve manufacturer specifications. The Commonwealth Edison specifications include, but are not limited to, all pertinent system operating conditions, engineering requirements (materials, structural, electrical, etc.),
qualification requirements (performance, environmental, seismic, etc.) and Quality Assurance requirements. The valve manufacturer, in turn, uses this data to derive the valve design data that Limitorque needs to specify the MOV actuator. Limitorque selects the proper motor operator and specifies the torque switch setting for the motor operator.
The results of the Limitorque and valve manufacturer efforts are then sent back through the organizations involved for review, ending with Commonwealth Edison's review and eventual acceptance after resolving any discrepancies.
Since we purchase motor-operated valves which are certified under the valve supplier's Quality Assurance program to meet the design requirements established by the plant designer, our method for establishing the torque switch setting is to confirm that the certified performance of the motor-operated valve meets the design requirements of the system. Therefore, no further review of the method for establishing torque switch settings is necessary or practical.
Action Item C Individual valve settings shall be changed, as appropriate, to those i
established in item b, above. Whether the valve setting is changed or j
not, the valve will be demonstrated to be operable by testing the valve at the maximum differential pressure determined in item a above with the exception that testing motor-operated valves under conditions simulating a break in the line containing the valve is not required. Otherwise, justification should be provided for any cases where testing with the maximum differential pressure cannot practicably be performed. This justification should include the alternative to maximum differential j
pressure testing which will be used to verify the correct settings.
Note: This bulletin is not intended to establish a requirement for valve testing for the condition simulating a break in the line containing the salve. However, to the extent that such valve operation is relied upon in the design basis, a break in the line containing the valve should be considered in the analyses prescribed in items a and b above.
The resulting switch settings for pipe break conditions should be verified, to the extent practical, by the same methods that would be used to verify other settings (if any) that are not tested at the maximum differential pressure.
Each valve shall be stroke tested, to the extent practical, to verify that the settings defined in item b above have been properly implemented even if testing with differential pressure can not be performed.
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, Response i
I Commonwealth Edison is developing a test program to confirm the operability _of the valves listed in Attachment A under design basis
-conditions. However, we recognize.that certain valves cannot be tested practicably under full design basis differential pressure conditions. As a result, a program is underway to review the design basis fluid conditions discussed in the response to action item (a) and determine the extent to which these conditions can be practicably produced in the affected systems. This will include a review of existing system surveillance procedures and preoperational test procedures for units still under construction. We expect many valves to be testable under design basis fluid conditions through the use of these existing surveillance or preoperational test procedures. Beyond this, plant conditions encountered during a unit shutdown, startup, and refueling outage will be reviewed to determine conditions under which the remaining valves may be tested. If design basis differential pressure conditions can be produced during these non-operating modes, valve testing will be performed. Notwithstanding the efforts discussed above, some valves will only be testable under reduced differential pressure conditions and others under no differential pressure. For these situations, alternate justification will be provided for verifying the correct uwitch settings. To
'the extent practical, all valves on Attachment A will at least be stroke tested. The test program outlined above will be completed in accordance with the schedule provided in the bulletin.
Action Item D Prepare or revise procedures to ensure that correct switch settings are determined and maintained throughout the life of the plant. Ensure that applicable industry recommendations are considered in the preparation of these procedures.
Response
These procedures are presently under review in order to assure that switch setting procedures are effective and reflect applicable industry recommendations. This review will address post-maintenance testing practices which are required to ensure that switch settings are correct. Since documentation of field switch settings may not be complete at all stations, record keeping practices will also be reviewed and improved where necessary.
These reviews and any necessary revisions will be completed by September 1, 1986.
Action Item E Within 180 days of the date of this bulletin, submit a written report to
.the NRC that:
(1) reports the results of item a and (2) contains the program to accomplish items b through d above including a schedule for completion of these items.
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Response
The response to action items (a) through (d) has been reported above. Schedular information has been provided for items (b) through (d).
After completion of the program, a report will be submitted in accordance with action item (f).
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