ML20198H020

Nebraska Public Power District Response to Initial Requirements of IE Bulletin 85-003

ML20198H020
Person / Time
Site:	Cooper
Issue date:	05/15/1986
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20198G997	List: ML20198H020 NLS8600173, Forwards Nebraska Public Power District Response to Initial Requirements of IE Bulletin 85-003. Schedule for Completion of Switch Setting Program Described in Bulletin Also Included
References
IEB-85-003, IEB-85-3, NUDOCS 8605300082
Download: ML20198H020 (19)

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COOPER N UCLEAR STATION

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l N PPD RESPO NSE TO

; I N ITIAL REQUIREMENTS OF

i IE BU LLETI N 85-03

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, MAY 15,1986 k

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NEBRASKA PUBLIC POWER DISTRICT G PDR

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I NEBRASKA PUBLIC POWER DISTRICT I COOPER NUCLEAR STATION I

NPPD Response to Initial Requirements )

of IE Bulletin 85-03 I

MAY 15, 1986 I

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1.0 INTRODUCTION

The objective of this report is te respond to the require-ments of IE Bulletin 85-03 for Nebraska Public Power District's Cooper Nuclear Station (CNS).

IE Bulletin 85-03 pertains to motor-operated valve common mode failure resulting from improper switch settings during plant transients and accidents. The requirements of this bulletin can be broken down into two phases. Phase I requires the licensee to identify and document the design basis for all motor-cperated valves in high pressure systems, establish a tentative schedule for implementation of Phase II, and submit this information to the NRC by May 15, 1986. The second phase includes valve testing under actual design pressures or providing justification for alternate method, establishment and implementation of a switch-setting program, and preparation of a final report to be submitted to the NRC by November 15, 1987 This report is NPPD's formal response to the Phase I re-quirements of IE Bulletin 85-03 for Cooper Nuclear Station. l

1.1 Background

As a result of several events at nuclear power plants during which motor-operated valves (MOVs) failed to function on demand, IE Bulletin 85-03 was issued. The purpose of this bulletin is to l request licensees to develop and implement a program to ensure that switch settings on certain safety-related motor-operated I

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R/IE Bulletin, P263 Page 2 I valves are selected, set, and maintained correctly. These switch settings should accommodate the maximum differential pressures expected on these valves during normal as well as abnormal events within the design basis of the station.

In general, licensees are required to implement a program to ensure that torque switch, torque bypass features, position limit switches, and overload relays for active motor-operated valves of high pressure safety-related systems are selected, set, tested, and maintained properly. To achieve these objectives, the following tasks were identified as being required by IE Bulletin 85-03:

I (1) Review and document the design basis for the operation of each valve. This documentation should include the maximum differential pressure expected during opening I and closing in both normal and abnormal events.

(2) Establish the correct switch settings, including a I program to review and revise, as necessary, methods for selecting and setting of all switches.

the I (3) Change the individual valve settings as appropriate and demonstrate operability by testing the valves at the maximum differential pressure. If the maximum differential pressure cannot practicably be tested, I provide justification, including the alternative to maximum differential pressure testing. In addition, stroke test the valves, to the extent practical, to i verify proper implementation of the switch settings.

(4) Prepare or revise procedures to ensure that correct I switch settings are determined and maintained through the life of the plant. These procedures are to be consistent with the requirements of Item 3.2 of Generic Letter 83-28. These procedures should include I provisions to monitor valve performance to ensure the switch setting is correct.

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R/IE Bulletin, P263 Page 3 I (5) A written report to the NRC containing the results of Item (1) above, including a program and schedule to I accomplish Items (2) through (4) is to be submitted by May 15, 1986. Items (2) through (4) are completed by November 15, 1987, and a report submitted to be I to the NRC 60 days these activities.

subsequent to the completion of The NRC Technical contact identified in IEB 85-03 was asked to clarify several points. The following information, pertinent to CNS, was obtained verbally over the telephone:

(1) The only "high pressure" systems of concer.n at CNS are I the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems.

(2) All valves required for the system to perform its I intended safety function (s) operation of valves should including be inadvertent considered in the analysis. For example, if a valve is normally open and it has to stay open to perform its intended safety function, an inadvertant operation could result in it's closure. Therefore, valve testing has to be performed to demonstrate the capability to open this valve.

(3) For the majority of BWRs (including CNS), the torque switches in the opening circuits of HPCI and RCIC MOVs I are jumpered. In addition, the overload relays for these valves are wired for alarm only. However, the valve operability has to be tested to ensure valve operation and appropriate switch setting as necessary.

(4) All motor-operated valves, including those in the low pressure pipes of HPCI and RCIC systems (suction lines)

I are covered under IEB 85-03.

In responding to the requirements of IEB 85-03 for CNS, the above clarifications have been considered and are factored into the analysis.

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R/IE Bulletin, P263 Page 4 lI 1.2 Report Overview l

Section 2 of this report describes the methodology and i process used to identify motor-operated valves in high-pressure systems at CNS. Table 2-1 includes a list of MOVs considered in the response to IEB 85-03.

Section 3 includes a description of the valve testing pro-gram to be completed by November 1987, and a tentative schedule for this program. A bar chart depicting the schedule is also provided. Section 4 provides a list of references used in performing the analysis.

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R/IE Bulletin, P263 Page 5 2.0 ANALYSIS METHODOLOGY I The objective of this section is to describe the process used to identify motor-operated valves in response to IE Bulletin 85-03. The analysis methodology also identifies the design basis differential press"re and the maximum differential pressure ex-pected during opening and closing of each valve for both normal and abnormal events.

Nuclear Safety Operational Analysis (NSOA), NRC inputs, and CNS component classification results were utilized to identify high pressure systems and the active MOVs required to support the systems' safety functions. Vendor design documents for selected MOVs and General Electric system design specifications were then entered into a systems operational analysis to determine the design and maximum expected differential pressure.of each MOV.

2.1 Definitions The following terms have been used in the report and are defined herein for clarification:

Motor-Operated Valve (MOV) - The entire valve assembly, which includes the valve, the valve operator, and the motor; I no further distinction will be made.

High Pressure System - A system that experiences peak nuclear pressure while performing its required safety function.

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R/IE Bulletin, P263 Page 6 I Single Failure - Single equipment failure or inadvertent equipment operation such as inadvertent valve closure or opening.

Normal Event - The normal BWR operating states and planned .

operations such as power operation or refueling, from which transients, accidents, and special events are initiated.

Abnormal Event - Plant transients and accidents caused by component failure, personnel error, or design basis events (DBE).

2.2 System / Component Identification The Nuclear Safety Operational Analysis (NSOA) was used to identify the high pressure systems and their respective safety functions 'that would be used to mitigate abnormal design basis events at CNS. The MOVs required to support the system safety function (s) were then identified using the Q-List, Piping &

Instrumentation Diagrams, and System Operating Procedures. The CNS NSOA provides a methodology for establishing the plant safety requirements at the systems level. From the NSOA, a list of essential systems identified in the normal and abnormal design basis events protective sequence was compiled. Information obtained from the NRC IE Bulletin 85-03 technical contact was then utilized to select the systems of concern and their respec-tive safety functions. The High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems were identified as the focus of this response.

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R/IE Bulletin, P263 Page 7 I Based on the system level safety requirements established in the NSOA, further evaluation of the plant requirements were per-formed to identify the system's safety classification. The safety functions of the HPCI and RCIC systems are to provide reactor coolant makeup during plant accidents and transients, and to automatically isolate in the event of a steam supply line break.

For each MOV in the HPCI and RCIC system, component opera-tional requirements necessary to facilitate system safety functions were analyzed to identify the active MOVs. IE Bulletin 85-03 states that single equipment failures and inadvertent equipment operations (such as inadvertent valve closures or openings) that are within the plant design basis should be assumed. Thus, a normally open MOV, which must remain open to achieve system safety function, is considered to be an active I component in this response. The list of active MOVs along with their component description is provided in Table 2-1.

2.3 System Differential Pressure The design differential pressure and the maximum differential pressure expected during normal and abnormal operational modes were identified for each MOV. The design differential pressure was obtained from the original vendor's component design specifi-  !

cation [1] and can be found in Table 2-1.

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R/IE Bulletin, P263 Page 8 I General Electric System Specifications [2,3] and system flow diagrams [4, 5) were then utilized to derive the maximum expected differential pressure each MOV will experience during design basis events. The maximum expected differential pressure is conservatively considered to be the maximum upstream or downstream pressure, whichever is larger. No credit is taken for the ambient pressure. Thus, the maximum expected differential pressure presented in Table 2-1 will be the most conservative enveloping differential pressure that could be experienced by the MOVs during various plant operational modes.

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R/IE Bulletin, P263 Page 9 I 3.0 SCHEDULE FOR PHASE II ACTIVITIES The objective of this section is to establish a tentative schedule for implementation of Phase II activities consistent with the requirements of IE Bulletin 85-03. Tasks required to j complete the Phase II effort are identified. In addition, plant outages scheduled for 1986 - 1988 are included since valve test-ing will have to be performed during plant shutdown conditions. l l

NPPD reserves the right to deviate from requirements it imposes upon itself in this section, if required due to unforeseen operation constraints.

In order to complete Phase II activities, the following tasks must be performed:

(1) Using the results from Phase I (Table 2-1), establish l the correct switch settings. This includes a program to review and revise as necessary the methods for selecting and setting all switches for the required I valve operation (open, close).

all torque switches in It should be noted that opening circuits of valves identified in Phase I are jumpered and, therefore, are l

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not of any concern. In addition, overload relays for the valves of concern are wired for alarm only.

(2) Provide justification for continued operation (JCO) in I accordance with the CNS Technical Specifications for valves considered " inoperable" as a result of Task 1. .

1 (3) Change valve switch settings if necessary, to those i established in Task 1.

Prior to any switch setting adjustment, a summary of findings as to valve operability will be prepared.

(4) Demonstrate valve operability by testing the valve at the maximum differential pressure (MDP) identified in Phase I (see Table 2-1) or provide justification for alternate method of determining operational readiness.

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R/IE Bulletin, P263 Page 10 I (5) Stroke test each valve to the extent practical.

(6) Prepare or revise procedures, as necessary, to ensure that correct switch settings are determined and maintained.

(7) Submit a report to the NRC summarizing the results of Tasks 1 through 6 above. This report will include a verification of completion of Phase II activities consistent with the requirements of IEB 85-03.

Several Phase II

• tasks specified in the previous section must be performed during plant shutdown. The following is a list of the scheduled outages during 1986-1988:

Year Duration 1986 October 5 - December 14 1987 None 1988 February 28 - April 10 NPPD will attempt to demonstrate the operational readiness of these valves during the 1986 outage. However, because of the existing time constraints and other major plant modifications, which have been previously planned, it may not be possible to safely complete the required testing for all valves listed in Table 2-1 during this outage. Therefore, NPPD anticipates that valve testing will be completed during the following outage, scheduled for the period of February to April 1988. The final report required by Phase II will be submitted within 60 days of the completion of the required actions.

In order to comply with the requirements of IE 85-03, NPPD has prepared a tentative schedule for completion of Phase II activities. Table 3-1 includes a bar chart depicting the pro-posed schedule.

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4.0 REFERENCES

1. Anchor Equipment Company, List of MOVs and Their Respective Design Specifications. Contract No. E69-7, 1969.

2. General Electric High Pressure Coolant Injection Data Sheet.

GE Document 257HA354AN, Rev. O, Oct. 1968.

3. General Electric Reactor Core Isolation Cooling Data Sheet.

GE Document 22AI354, Rev. 4, Oct. 1968.

4. " Reactor Core Isolation Cooling System", General Electric l (APED) Drawing No. 729E719BC, Sheet 1 o f 1, Rev. O, Aug. 13, 1969.

5. "High Pressure Coolant Injection System", General Electric (APED) Drawing No. 729E720BB, Sheet 1 o f 1, Rev. O, Aug. 27, 1969.

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E E E E E En .uaure . ,

P263 ,

NPPD-CNS IED R5-03 RESPONSE TABLE J-1 Mov Data Summary Table (RCIC)

I l I I I I I l l Cumoonent l l l Design l Man. E=pected l l l

! !aentification l Component  ! Operational Requirements l Differential l Operational l Required l l

! ( mte (C!r) l Description l l Pressure i Differential l Operation l Comment l l l l l Pressure l l l r I I I I I I I -- -- 1 I I I I i ru I L -Mov- M01'i l RCIC Steam Inhoard l Aen for cor e Cnot, suppfy l 1146 psi l 1135 psia l l See Note 5 l l l Isolation l Close f or Sys. Steam L iam l l l _Open Llose l l j l l ! solation l l l l l l l l I I I I i

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l l I I l l m I( -Mov-Molb I RLIC steam out- l_Open_for ( nr e Cool. Surph l 1146 usi l 1135 psia !_Open l See Note 5 l l l t>oard Isolation l Close for sys. Steam L iem l l l Lluse l l l l Isolation l l l  ! l l l I 1 I I I

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kF:C-MOV-M01H l RCIC Supply from i Open/Close +ur Core i 50 psi i 28 psia l Active l See Note 2 l i l Emergency Conden- l Cooling Supply l l l i i i l sate Stora:je Tank l l l l l l

- I I I 1 1 I l l I I  ! I J l i Pt I( - MOV - M0 2 t i l RCIC Pump l Open for Cor e Cooling i 1925 psi l 1212 psia l Cpen l See Notes 3 &5 l 1 l oischarge i Supply i l l  !  !

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l I 1 Hilr-Mov-M021 l RCIC Injection to l Open for Core Cooling l 1925 pst i 1212 psia  ! Open l See Notes 3 & 5 l

. l Reactor l Supply i l l l l 1

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! l l I i l l RL!t -MOv-MU27 1 RCIC Pump Minimum l Close/Open for Core l 1500 psi l 1212 psia Active l See Notes 3, 4 & Sl I l Flow Recirc to l Cooling Supply l  ! l l l l Torus l l i l l I I  ! I l

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, Rf!C-MOV-M030 RCIC Test Return Close for Core Cooling l 1925 psi i 1212 psia l Close See Notes 3 4 & 51 l Root Suppiy , l l

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.' I i l l r, C I C -MOv - MQ41 . RCIC Supply from i Close/Open for Core 1 50 psi 1 17.3 psia l Acttve l l l l Turus l Cooling Suppty l l \ l l 1 ~- I I I I  ! l l l 1 I I I I I I i RLIC-MOV-M3131 l RCIC Steam Supply l Open for Cor e Cooling l 1146 psi i 1135 psia l Open l See Note 5 l 1 to RCIC Turbine l Supply l 1 l l l l l 1  ! l l l

l i I I , I i l RCIC MOV-M01.12 l Auniliary Cnoting l Open for Cor e Cocling l 1500 psi 1 1212 psia l Open l See Notes 4 L5 l i l Supply l Supp1y l l l l l

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N P PD - t r4 5 ,

IEH 85-03 RESPONSE ,

TABLE 2-1 MOV Data Summary Table (HPCI) *

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, Cor.ponent l l l Design l Man. Espected l Required l l l !aeot i f g r at ino l Component l Oper at i ona l Requirements l Differential l Operational l Operation l l l C. e (CIC) l Description l l Pressure lDif f er ent ial l l Comment l

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I sh VOv-vola 1 Steem Supply to , Open tur co< e Ctaling i 1140 psi l 1135 psia l Open l See Note 5 I

! l Torbine i Supply  ! l l l l

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l l l 5 team Supply In- l_Open for C n.r e Cool. Sopity i i 1146 psi 1135 psia l _Open l See Note 5 nr. I f.tne un t' l l

! , 1 b oa r :1 tsolatinn - 1 C l o s += f or sys, steam Li o i 1 i C i o .e l l

, i 7 l l !sulatine. l l l l l

! .} I I I I l 1 "W I %v-9016 l Steam suppt, Out- l for fnre, loot. S upp_ty.! 1146 t_ s i l 1135 psia l Open l See Note 5 l l tmar d Isolation i_Open Close t o r .. % y s . Steam _e.. l l Close l l

l  ! Isolation l  ! l l t

_ _ _ _ _ __ I i ~ i i l l l nr 1-vov- W 1/ l Pomp Soction ftom l Open/Close for Cora 1 150 psi l 2R psia l Active 1 See Note 1 l l l Emergency Londen- i C.>oling Supply I i l l l 4

l ate storaar Tana 1  ! l l l 4 l E I  ! l  ! l l '

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re 'I MOV V019 { HPL1 Injection l Open/Close for Core l 1325 psi 1 1212 psia l Active l See Note 5 l j l *l Cooling Supply l l l 1 t

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! l . i i i i I i rw>I wv-Mo2n l HPCI-P-JP i open for core Coot, supply 1925 psi l 1212 psia i Open l >ee Note 5 I

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sec!-P-up Test l Close to- Cor e Cooling i 1925 psi i Ig12, psia  ! Close I see votes 3, 4 & 5[ ,

l nypass to Emer. I soputy l l l l l l Condens, ate .. t o r a q e l ' 4

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! nrC i- MO s- Y%5 j HPCI-P-MP W i n i rr om j Closa!Open for Core l 1500 psi l 1212 psia l A c. t' i v e l See N.tts .3 , 4 & 5l l Flow Bypass Line l Coniina Supply l l l  ! l

! j ! solation l l l l .j l' I i l I i ~ l l l 1 1 I l e6o.I-MW-COSH ' HPCI Pump %c t s ort C1ose/Op+n for Core l 150 psi l 17.3 psia l Attive l j l t l tram Suppr ess ion l Cooling 5.spo l y l l l l j i i j 0001 l l l l l 1 I I I I f I l l

I l 1.<*nsoro 1 P263. T/ Table 2-1 (CONT) j Page 2 of J 4

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j NPPD-CNS IEB 85-03 RESPONSE MOV Data Summary Table (HPCI)

(continued)

I NOTE 1: The maximum pressure drop in the piping from the reactor vessel to the turbine is 15 psi.. This pressure drop has conservatively been ignored in the analysis.

I NOTE 2: The maximum expected operational pressure is considered to be the sum of elevation difference of about 30 feet between the pump suction and the emergency condensate I storage tank and ambient pressure of 14.7 psi.

NOTE 3: Pressure drop introduced by orifices has been J conservatively ignored.

i NOTE 4: The maximum expected operational pressure is considered <

to be the maximum pump discharge pressure. J l NOTE 5: Values subject to change due to plant medi-fications as i

i a result of the ATWS rule implementation. )

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Enclosure 1, P263, T/ Table 2-1 (Cont)

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COOPCR NUCLEAR STATION NKlRASKA PU'BLIC POWER D1 STRICT I IE BULLET:N 85403 RESPONSE PROPOSED SCHEDULE FCiR CCMPLETION OF PHASS II ACTIVITIES SCHEDULED OUTAGES l 1 ,1 l  ! )  ! . I _, 1 j I TASK __

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I ESTABLISH PROGRAM f, I, l_ l l l I i l _)i l i l 1 J ,

2. WRITE JCOs )

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FINDINGS AND CHANGE I I i~ } } 'l I l i I I 4.

SWITCH SETTING VALVE TEST 1tJd, l

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l i l I 1 l I I i 1 i i i l i J l l I ( l i 1 I I l_ i June Jan. Jurie J a r6 ~ June 198i, 1987 1988 I

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