ML20204A357

Forwards Response to Six Necessary Actions to Comply W/Ie Bulletin 85-003, Motor-Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Setting

ML20204A357
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	05/02/1986
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
IEB-85-003, IEB-85-3, LAC-11577, NUDOCS 8605120116
Download: ML20204A357 (8)

Text

7//M k

OOPERAT/VE PO BOX 817

• 2615 EAST AV SOUTH LA CROSSE. WISCONSIN 54601 (608) 788-4000 May 2, 1986 In reply, please l

refer to LAC-11577 DOCKET NO. 50-409 Mr. James G. Keppler l

Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

SUBJECT:

IE BULLETIN NO. 85-03, MOTOR-OPERATED VALVE COMMON MODE FAILURE DURING PLANT TRANSIENTS DUE TO IMPROPER SWITCH SETTING l

Dear Mr. Keppler:

Dairyland Power Cooperative has reviewed IE Bulletin No. 85-03.

As a result of this review, DPC has taken all necessary actions to comply with your staff's requests. Attachment 1 individually addresses each of the six actions required by holders of operating licenses.

If you have any question in regard to this submittal, please contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE James W. Taylor Geneal Manager JWT:RMB:sks Attachment 8605120116 860502 PDR ADOCK 05000409 G

pgp WPl.4.7 I (

MAY 7m

Mr. James G. Keppler May, 2, 1986 Regional Administrator LAC-11577

.cc: Document Control NRC Resident Inspector John Stang, LACBWR Project Manager STATE OF WISCONSIN )

)

c0UNTY OF LA CROSSE )

Personally came before me this day of k

1986, the above named, James W. Taylor, to me known to be the person who executed the foregoing instrument and acknowledge the same.

Nw (

b&

te_

Notary Public, La/ Crosse County Wisconsin V

My commission expires February 21, 1988.

WPl.4.7 j

NRC Concern Actions for All Holders of Operating Licenses or Construction Pennits:

For motor-operated valves in the high pressure coolant injection / core spray and emergency feedvater systems (RCIC for BWRs) that are required to be tested for operational readiness in accordance with 10 CFR 50.55alg), develop and implement a program to ensure that valve operator suitches are selected, set and maintained properly. This should include the following components:

Review and document the design basia for the operation of each valve.

a.

This documentation should include the maximum differencial presure expected during both opening and closing the valve for both normal and abnonnat events to the extent that these valve operations and events are included in the existing, approved design basia, (i.e., the design basis documented in pertinent licensee submittats such as FSAR analyses and fully-approved operating and emergency procewives, etc). When determining the maximum differential pressure, those single equipment failures and inadvertent equipment operations such as inalvertent valve closures or openings) that are within the plant design basie should be assumed.

DPC Response There are two motor-operated valves at LACBWR that may fall within the scope of this bulletin. These valves are used in a low pressure Alternate Core Spray System and are stroke-time tested for operational readiness in accordance with 10 CFR 50.55a(g). These valves are designated 38-30-001 and 38-20-002 and are installed in parallel in the piping Alternate Core Spray system (Drawing 41-400237). For emergency core cooling purposes only one valve is required to function to fulfill reactor safety requirements. These valves are identical units designed for 1400 psi and 650*F with a 10 second stroke time and a 200 psi differential. The valve construction is a rotovalve plug cock which is lifted and then rotated 90*.

The valve opening through the circular plug orifice is equal to the opening of the adjoining pipe. The motor operators are not identical. Valve 38-30-001 is powered by 440 VAC motor and valve 38-30-002 is driven by a 125 VDC motor. Both valves are equipped with a manual handwheel. These valves are located in the Turbine Building and readily accessible from the Control Room.

The Alternate Core Spray System functional operating requirements start both the diesel-driven pumps on a containment building pressure signal of 5 psig or greater. The discharge pressure is approximately 160 psig and pump relief valve set at 170 psig.

Relief valve (38-27-001) at the suction of the ACS motor operated valves is set at 200 psig. The motor-operated valves will open on a containment building high pressure signal of 5 psig or greater and a reactor vessel narrow range level of -12 inches. The valves will automatically close if reactor water level rises above the -12 inch level. Flow to the reactor vessel will occur when the primary system pressure drops to approximately 150 psig. The ACS line downstream of the motor-operated valves is normally depressurized.

There is a relief valve (38-27-003) set at 150 psig between the motor-operated WPl.4.7 3

valves and two in-series check valves isolating the primary system pressure from the ACS line downstream of the motor-operated valves. There is no single failure that could create a greater differential than the original design value requirement.

NRC Concern 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).

DPC Response Two SMB-000 Limitorque motor-operated valve actuators are used in this application. Torque switches, torque bypass switches and position limit switches are used in the valve control circuits in both the opening and closing direction. These valve switches were orignally adjusted at the factory when the valves were manufactured in 1967. Any adjustments to date performed at LACBWR would have used the maintenance manual procedure for guidance which indicates the switch contact settings in relation to valve position. There is no record of corrective maintenance on these valves. The valves are periodically tested and lubricated. The torque switches have in addition to the normal setpoint locking screw a split pin stake that prevents the setpoint from being changed from the "1" position. LACBWR Operating Manual Procedure 17.5.2 " Refueling Shutdown Test of Alternate Core Spray System" is performed at each refueling outage. This test simulates the automatic signals to start the ACS diesel driven pumps and opening signals to the motor-operated valves. The valves are cycled one at a time to verify proper opening and closing under full system differential pressure. This test has been successfully performed 28 times since 1967. Only once has a valve failed to open and the cause was due to an auxiliary relay contact malfunction. This auxiliary relay is external to the valve operator. The valves have never failed to operate. LACBWR Operating Manual Procedure 17.5.1 "Startup Test of Alternate Core Spray System" is performed at each reactor Cold Shutdown if not performed within the last 92 days. This test has been successfully performed 42 times since 1967. The valves are functionally tested in the opening direction as part of this test procedure. Valve stroke timing was initiated on the ACS motor-operated valves in 1980. Fifteen timed tests using a revised 17.5.1 operating procedure have been conducted to date.

With 18 years of satisfactory service of these valves and periodic testing with operating differential pressure applied, these settings are considered correct.

NRC Concern c.

Individual valve eetinga shall be changed, as appropriate, to those established in item b, above. Whether the value setting is changed or not, che value vill be demonstrated to be operable by testing the value at the maximum differential pressure determined in item a above uith the exception that testing motor-operated valves under conditione simulating a break in the line containing the valves is not required. Otherwise, WPl.4.7 ;

justification should be provided for any cases where testing with the maximum differential pressure cannot p moticably be performed. This justification should include the alternate to maximum differnatial pressure testing which vill be used to verify the correct settings.

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.

DPC Response No valve torque, torque bypass or position limit switch settings require changing. The ACS valves 38-30-001 and 38-30-002 are tested with maximum system differential pressure at each refueling outage. The test simulates high containment building pressure and low reactor water level to verify automatic operation of the pumps and valves at maximum system dif ferential pressure.

NRC Concern d.

Prepare or revise procedures to ensure that correct suitch settings are determined and maintained throughout the life of the plant. Ensure that applicable industry reconenendations are considered in the prepamtion of these procedures.

DPC Response Since only two motor-operated valves with no corrective maintenance history are used in this application, the manufacturer's maintenance manual is used for guidance. No specific procedures are written. The post-maintenance test procedures as specified in the maintenance request would verify proper operation of the valve, correct operation of the position indication switches and verifies the torque switches do not actuate prematurely on a maximum system differential pressure. Both LACBWR Operating Manual Test procedures referenced in the response to Item a would be performed to assure proper valve operation after any significant maintenance activity.

NRC Concern e.

Within 160 days of the date of this bulletin, submit a uritten report to the NRC that: (1) reports the results of item a and (2) containa the program to accomplish items b through d above including a schedule for completion of these itema.

1.

For plante uith an OL, the schedule shall ensure that these itema are completed as soon as practical uithin tuo yeara from the date of this bulletin.

DPC Response This letter is intended to complete all Items a through e. Since 1967, DPC has successfully tested each of these valves at least 70 times. Twenty-eight of these tests were conducted at maximum system diffferential pressure without failure. No further action is required.

WPl.4.7 t J

NRC Concern

f. Provide a written report on completion of the above program. This report should provide (1) a verification of completion of the requested program, (2) a sumary of the findings as to value operability prior to any adjustments as a result of this bulletin, and (3) a sumary of data in accordance with Table 2, Suggested Data Sumary Format. The NRC staff intends to use this data to assist in the rasolution of Generic Issue II.E.6..

This report shall be submitted to the NRC vithin 60 days of completion of the program. Table 2 should be expanded, if appropriate, to include a sumary of all data required to evaluate the response to this bulletin.

DPC Response Data Summary Table 2 is completed and attached for your review. No additional response should be required. This letter should fully address the concerns of IE Bulletin 85-03.

WPl.4.7 1

.)

e e

s.

,m.

Data Summary Switch Settlage '

Final Switch Deelga Frior to Adjustmente Setting to Re-Talve Basle AP Test AP as a Result of Bulletta sponse to Bulletta As Found Velve Test Method' Valve Valve Operator Functies Open/Close Opea/Close Open/Close open/Close operability Description /Justifteattom 38-30-001 Limitorque Alternate 200 pots /

160 petg/

1/1 1/1 Operable Mestnum System Differen-Rotoport SMB-000 Core Spray 200 pets 160 pets tial Pressure each re-64x6 RPM 1725 Pump Die-fueltag outage.

1400 pelg 440 TAC charge (Op. Pleasel 17.5 2) 650*F 3$

leolation 60 82 Valve fleed Test in Opeatas direettee on each reactor Cold Shetdese. (Bot more eften than every 92 days)

(op. Manual 17.5.1) 38-30-002 Lietterque Alternate 200 peig/

160 pets /

1/1 1/1 operable Mestaus System Differen-Esteport SMS-000 Core Sprey 200 pets 160 pets tial Pressure each re-6:4x6 RPM 1900 Pump Dis-feettag outage.

1600 pets 125 YDC charge (Op. Manuel 17.5.2) 650*F Isolation Talve fleed Test la Opeatas direction en each reactor Cold Shutdown. (Not more of tes than every 92 days)

(Op. Menest 17.5 1)

WP1.4.7

pa q

u

m;!i r--

:)d.!'

h f;

1, w

a w

up 2

g, x

U (p ^,

{w W

yt w-

-n L.

i j

q% ~ -

g A =#g,.b

!]

ja,,

8

,, w _. _ _ _ n m

II di 1

5 f

i U I A -'Nf h

m 8

{ w ~,* b e

p.

n m.

- M.1 m

. _ _ _ %_5 m p s#y

/

m i

' b, '..

e l.

r ji A

1 H

h^. a _ r A. c.. < - - - 6, g /.,. f... '

d.

,, 4 g y r-.?

• d I.

, 6 s hq q*- (f4 U u;_

it

@a40 N,

]

9 b M 4 n.. <

- k_~.t k

? ?,

g l e:s

[

,7 m

}.3 s

}

.~

.- ~.lM,y 4

s

.S..

a

,]

7g y

'I 8

eJ... f e"s :_ __

i i' 4-1 3 '*

+

r -

a e

In

• t w.r 4 1

Q*,s. v :

"g e

o t ' ir., h,

t m f sf.,&: : -Cd IT d ad el

• i a a

?~

1.quM lI l m m,J; r,%

1 c-ah 3

5%dM' i I

H 4-i t i g

p.cM 65 N-

~"

2J.jUJ,j.d a,f

. % f[

p.

i 7

$ d-, i 9t[

s t

f 8

( m+

g i

l:

4 tmhy y s is f -

i

.c

• L 3 5 ;;.:

SL s

,1 W-- m-

g' g

,g c ;.

e r

lJi>

p.#ryh a 74'g A>b 8

t?'

si d 2 #*

m m

,____ j g

4 y 3

.___...__.q__._

c ;l x.r, +, i s r'"**

I*

.,1 6.

i YJ

.---_$-tc..

}

)

=

p a t, B 4a

& d--.

. f i J, 4s l

.g a

p r s<

m

.4 i

Q Y

-s AU~

l'" '

f

,l 4

a ~-

r a '

4 -- -

g p +,. i r. 4 3i ;;

w9

-om A -

a-s\\ W ga

-- 3 p

u M

24

'O D

I 4

- f. *A

- v i

J 7.,,

c;_

4 (p;v.

I f) 4 y s >

+-

.o

n.y y,

.2 y

=-

.,. m l

.e u

13 'e g1-I 3

p

) *)p-s ;

o

,y, M

ca f: _a + b oi o*,-.y}

g S

,.,.. O t l.

"4 1,

r. s, y a '.. '_t

'-e 7

, 2 ' ". M 3

7.

I

,A (I

N

j M

! y Ti p

• .";.; u c

. h >% s-s -

4' t

n

..e s" a,

5 a;

a?"

s a

f f

~*

ffy y

{-

~~~ ~"

' Wp.l? & N &

% -; 5 1

e

~ a

(,

7b n k *, ;. E. A. b 5 a

sa 7

g r, j'

,, n r.

K y

5 4

~

, c.,-

2-Q. !

O, so A

s j n

f-y V y - ---

m

'Un+-

l -!

q.p= y=x==

1.

t, *3M[,n.. !

Q G;;N a

4, N

l N, N, c,

~

e n-w l

m*-

e p} y l.,

} $'

3 u'

of t

cien w' 4-t.

n I

j4L s a

~

c 6,. 'e-u.. y e

c-s l

. %s q V

aaA a

~

5

-e s 1 1. _ _ _ _

,, g.,,,

s

, - =

l M

U !

4 1

4 r-a n

S.i N.

t h,

~

[

--.7..-

k 4'

I I

=.-'

k '. ' l j

-,f ;.

5 l

,, 4.

q a,

i 4

f a

s sr l

e

.f fN-I g*j

, gj l

~

l 7

. y a.

/.

. M.',

3s

)! - - - -

t?-

g

))

=

~i '

e

+ - -..r*-

. rz -- -

5,

-4.n"l uummunu

py y

9 1 s t *.

t

• y r

9_

-g.:

pc*

4

'p

.r p.

!u N

Q ' * &.-

k *I..

.A 51 T

--14 t

-:d D

4 y

.<y' _n

'a 1

e.a-i s

O.

17 i

_