ML20209E548
| ML20209E548 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/14/1986 |
| From: | Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-85-003, IEB-85-3, NUDOCS 8609110087 | |
| Download: ML20209E548 (25) | |
Text
e
,-a Murray Selman V:co President
.y Consolidated Edison Company of New York inc.
Indian Point Station Broadway & Bleakley Avenue Buchanan. NY 10511 Telephone (914) 737 8116 August 14, 1986 Re:
Indian Point Unit No. 2 Docket No. 50-247 Dr. Thoma s E. Murley Regional Administrator - Region I U.
S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406
Dear Dr. Murley:
Transmitted as Attachment A to this letter is our response to Item e of IE Bulletin No. 85-03 " Motor Operated Valve Common Mode Failures During Plant Tran sient s Due to Improper Switch Settings" dated November 15, 1985.
The response to this item was requested within 180 days from the date of the bulletin.
By letter dated May 13, 1986) f rom Mr. John D.
O'Toole to Mr.
James M.
Taylor, Director, Office of Inspection and Enforcement, NRC was informed of our need to extend the re sponse time until August 15, 1986.
Our re spon se, is provided pu rsuant to the provisions of Section 182a, Atomic Energy Act of 1954, a s amended.
Should you or yo tr staff have any questions, please contact us.
Very truly yours, f
l'%
cc:
U. S. Nuclear Regulatory Commission Washington, D. C.
20555 AT'IN : Document Control Desk Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511 Subscribed and sworn to before me this day 8609110087 860814 of August, 1986.
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itz Canmission Expires Oct. 30.1986
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i Attachment A Response to Item e.
" Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings" i
i Consolidated Edison Company of New York, Inc.
Indian Point Unit No. 2 Docket No. 50-247 August 1986 i
E.
Actions for All Holders of Operating Licenses or Constrinct2on Permits:
For motor-operated valves in the high pre ssure coolant injection / core spray and emergency feedwater systems (RCIC for BWRs) that a re required to be tested for ope rational readine ss in accordance with 10 CFR 50.55a(g), develop and implement a program to ensure that valve operator switches are selected, set and maintained properly.
Respon se :
There a re no motor opera ted valves in the emergency (auxilia ry) feedwater system at Indian Point Unit No.
2.
Accordingly, the bulletin scope is limited to motor operated valves in the "high pressure coolant injection system" as described below.
This should include the following components:
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 extent that these valve operations and events are included in the existing, approved design basis (i.e.,
the design basis documented in pertinent licen see submittals such as FSAR analyses and fully-approved operating and emergency procedures, etc).
When determining the maximum differential pre ssu re, those single equipment failures and inadvertent equipment ope ra tion s ( such as inadvertent valve closures or openings) that are within the plant design basis should be assumed.
Respon se :
1 l
A report documenting our review to determine the specific valves subject to the bulletin requirements and the maximum operating delta-p's those valves would be expected to operate a gainst considering the criteria noted above is provided in Enclosure 1 to this Attachment.
b.
Using the results from Item a above, establish the correct switch settings.
This shall include a program to review and revise, as nece ssa ry, the methods for selecting and setting all switches (i.e.,
l torque, torque bypass, position limit, ove rload) for each valve operation (opening and closing).
t l
If the licen see determines that a valve is inoperable, the licensee shall also make an appropriate justification for continued operation in accordance with the applicable technical specification.
l I
l Page 1 of 4 l
A e
,Y
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Response :
A program for selecting correct valve switch settings has been initiated. The program consists of the following:
- 1. Verify that the delta-p specified for procurement of the valve exceeds the maximum operating delta-p determined in Item a above.
- 2. Verify with the manufacturer that the switch settings provided by that manufacturer are consistent with the maximum operating delta-p's determined in Item a and/or the delta-p's specified for procu rement.
(Note that in all instance s the delta-p specified for procurement must and doe s equal or exceed the maximum operating delta-p determined in Item a. )
- 3. Obtain a s-found switch settings.
- 4. Adjust as-found switch settings to comply with ma nuf a ctu rer's specified settings, a s necessary.
- 5. Validate manuf actu re r's switph settings through actual valve testing against the maximum operating delta-p detezuined in Item a,
whe re such testing is practical.
Where actual valve te sting a gain st maximum operating delta p is imp ra ctical, utilize MOVATS (Motor Operated Valve Analysis and Test System) or similar system to determine the actual valve actuator force developed at the attainable (i.e.,
less than maximum) differential pressure.
When MOVATS is used, switch settings will be validated by comparing the thrust developed (at any attainable test delta p ) with validated thrust / delta p correlations for similar valves obtained from other valves at Indian Point or other facilities.
Valves tested at the maximum operating delta-p determined in Item a will generally be pressurized by the associated pump on one side and be depre ssurized on the other side at or near atmospheric conditions.
Te sting in this manner will re sult in obtaining maximum operating delta-p on the valve when the valve is in the fully closed position.
As the valve moves from fully closed to open, pump discha rge pre ssure will decrea se, flow will increa se and delta-p will decrea se.
Simila rily, for a valve that is normally open maximum operating delta-p will not be obtained until the valve reaches its fully closed position.
Te sting valves in this manner adequately serves as validation of maximum operating delta-p even though maximum operating delta-p will not be applied over the full range of valve travel. This is because such testing is indicative of the conditions that would be present in an actual event requiring valve operation.
Page 2 of 4
E Item 1 above has been completed.
The remainder of the program will be completed during the next refueling outage (cycle 8/9) cu rrently scheduled to commence in late 1987.
This schedule will allow the program completion and submission of the reouired report somewhat later than two years from the bulletin-required response date.
c.
Individual valve settings shall be changed, as appropriate, to those established in Item b, above.
Whether the valve setting is changed or 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 te sting motor-ope ra ted valves under conditions simulating a break in the line containing the valve is not reauired.
Otherwise, justification should be provided for any cases where testing with the maximum differential pre ssure cannot practicably be performed.
This justification should include the alternative to maximum differential pre ssure testing which will be used to verify the correct settings.
Note:
This bulletin is not intended to establish a reauirement for valve testing for the condition simulating a break in the line containing the valve.
- However, to tc.a extent that such valve operation is relied upon in the design ba si s, 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 ve rified, 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 cannot be performed.
Re sponse :
The program described in Item b above will validate the proper switch settings.
Should the existing settings require change, the valve will undergo a retest by one of the methods described in Item b to verify the adequacy of the new switch settings.
d.
Prepa re or revise procedures to ensule that correct switch settings a re determined and maintained throughout the life of the plant.
Ensure that applicable induatry recommendations are considered in the preparation of these procedures.
Page 3 of 4
This item is intended to be completely consistent with action Item 3.2,
" Post-Maintenance Te sting (All Other Safety-Related Components)," of Generic Letter 83-28,
" Required Actions Ba sed on Generic Implications of Salem A'IWS Events."
These procedures should include provisions to monitor valve performance to ensure the switch settings are correct.
This is particularly important if the torque or torque bypass switch setting has been raised significantly above that required.
Re sponse :
Manufacturer's specified switch settings are currently maintained in Enginee ring.
The applicable MOV maintenance procedures will be revised to incorporate the manufacturer's specified switch setting s by October 15, 1986.
Should the program de scribed above require changes to the ma nufa ctu re r's specified switch settings, applicable i
procedures will be revised at that time.
Pe riodic rete sting on a refueling schedule will a ssure that prope r switch settings are maintained.
Within 180 days of the date of this bulletin, submit a written report e.
to the NRC thats (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.
For plants with an OL, the schedule shall ensure that these items are completed as soon as practical and within two years from the date of this bulletin.
Re sponse :
Refer to Items a through d above and the cover letter.
f.
Provide a written report on completion of the above program.
This report should provide (1) verification of completion of the requested program, (2) a summary of the findings as to valve operability prior to any adjustments as a recult of this bulletin, and (3) a summary of data in accordance with Table 2, Suggested Data Summary Format.
The NRC staff intends to use this data to a ssist in the re solution of Generic Issue II.E.6.1.
This report shall be submitted to the NRC within 60 days of completion of the program.
Table 2 should be expanded, if appropriate, to include a summary of all data required to evaluate the response to this bulletin.
Re sponse :
A written report will be cubmitted within 60 days of completing the above program.
Page 4 of 4
9 1
Safety-Related MOV Delta-Ps for the High Pressure Coolant Injection System Response to Item e.
" Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings" Consolidated Edison Company of New York, Inc.
Indian Point Unit No. 2 Docket No. 50-247 August 1986
TABLE OF CONTENTS PAGE I.
INTRODUCTION 2
II.
METHODOLOGY 2
A.
High Pressure Coolant Injection Definition 2
B.
General HPI Valve Selection 3
C.
Fluid Systems Evaluation 3
D.
Generic ERG Survey 4
III. APPLICATION TO INDIAN POINT 2 5
A.
hPI Valve Selection Applied to Indian Point 2 5
B.
Fluid Systems Evaluation Applied to Indian Point 2 5
C.
EOP Survey Appiled to Indian Point 2 6
Figure 1: Safety Injection System Schematic 17 Figure 2: Safety Injection System 18
)
i 1
1 i
I
s I.
INTRODUCTION Provided herein is the detailed review and documentation of the de sign ba sis differential pre ssure (DP) for the Indian Point 2 high pressure coolant injection (HPI) motor-opera ted valves.
The purpose of this review is to respond in part to Action Item (a) of I&E Bulletin 85-03.
Specifically, to review and document "the maximum differential pressure during both opening and closing the valve for both normal and abnormal events to the extent that these valve operations and events are included in the existing, approved design ba sis".
This review follows the methodology developed as pa rt of the generic We stinghouse Owners Group Safety-Related MOV p rogram.
There are two major sections in this report.
Section II discusses the methodology used in selecting the HPI MOVs and in evaluating the se MOVs to determine the maximum differential p re ssure s.
Section III is the application of this methodology to the Indian Point 2 Station.
Table 1 lists the HPI MOVs selected; Table 2 gives the maximum operating DPs and Table 3 provides the EOP survey for confirmation of the maximum operJting DPs.
II.
METHODOLOGY A.
High Pressure Coolant Injection Definition For Indian Point 2,
high pre ssure coolant injection is accomplished using only portions of the High Head Safety Injection System (HHSI).
Consequently, it is necessa ry to clea rly sepa rate the. HPI portion s of this sy stem from the non-HPI portions.
"High pressure coolant" injection is defined as:
1.
Those portions of the Safety Injection System (or Emergency Core Cooling System) not including the Accumulator Injection System or Residual Heat Removal (RHR) System.
2.
Tho se portions of the above defined HPI systems necessary to establish a flowpath(s) from the Refueling Water Storage Tank (RWST) to the Reactor Coolant System (RCS).
3.
Only those portions of the HPI (as defined in 1 and 2 above) required during the safety injection pha se, not including the transfe r to recirculation from the recirculation sump after the RWST empties.
The refore,
recirculation modes of operation (long term cold leg recirculation and hot leg recirculation) a re not included in the definition of HPI since these modes of operation require the functioning of portions of the RHR sy stem, which has been excluded from the HPI definition (in 1 above).
2
B.
General HPI Valve Selection The HPI MOVs were selected based on their function within the HPI system (defined above).
In gene ral, there
'a re two functions required to establish high pressure coolant flow to the RCS for the Indian Point 2 plant:
B.1-The SI flowpath is established from the RNST to the NHSI l
pumps to the RCS.
B.2 Hi:SI. pump miniflow MOVs should be correctly positioned to assure proper pump operation and required design flow.
The Indian Point HPI valve selection is made much simpler by the fact 'that the Chemical and Volume Control Systrem (CVCS) is not connected to the SIS during the injection phase as it was in the generic We stinghou se Owners Group (WOG) MOV i
evaluation program.
The Indian Point 2 SIS diagram is shown i
in Figures 1 and 2.
C.
Fluid Systems Evaluation i
The fluid systems evaluation determined the maximum operating i
(open/close ) DPs for the selected MOVs, given the system configuration, equipment capability, and design operating modes.
s It is important to note that the HPI system was defined based on the requirement of establishing a high pressure injection flowpath f rom the RWST to RCS for short term, high pressure, cold leg injection. Subsequently, the HPI MOVs were selected based on their required functioning in establishing this high pressure injection flowpath.
However, once the HPI system p-was defined, and MOVs selected, a different set of criteria was used to perform the evaluation.
For the HPI MOVs selected, all modes of operation were evaluated including recirculation modes.
This wa s to. ensure that for this given set of MOVs, the worst case operating DP was determined, since some of the HPI MOVs (in the suction to the HHSI pumps) are exposed to more bounding fluid conditions for these recirculation modes.
c Two different sets of single failure criteria were u sed for the fluid systems evaluation depending on whether short term operating modes or long term operating modes were being i '
con side red.
1.
Short-term op-ration - Single active failures were considered.
Pa ssive f ailure s were not a ssumed.
This means that gross check valve backleakage was not assumed
( require s a pa ssive failure of the check valve).
I Short-term operation is the safety injection pha se of operation, up to and not including the transfer to recirculation.
3 4
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2.
Long-term ope ra tion - - Both active and pa ssive failure s were considered credible.
The analysis was based on a single failure which was found to be the worst of either the active or passive failure s.
Long-term operation is the remainder of the recovery period following short-term safety injection.
Long-term operation involves bringing the plant to cold shutdown conditions.
In
- general, the fluid systems evaluation resulted in the determination of a maximum operating DP, for any system operating mode and design basis event.
Hence, these maximum operating DPs may result in a relaxation of the conservative MOV equipment specification (E-Spec) DP.
For testing purposes [IEB 85-03 action (c)], this maximum operating DP is more realistic and feasible.
The maximum operating DP represents the maximum pressure producing capability of the system equipment for the system operating modes.
Within the given system, the following eouipment and system configuration information is important to the determination of maximum operatirg DP:
1.
Pumps -
Operating /not operating, operation configuration (miniflow/no miniflow), maximum discharge head 2.
Relief Valves -
Setpoint limits system pressure 3.
Piping Losses and Elevation Changes 4.
No gross backleakage 5.
Tanks -
Elevation head, design pressure I
6.
Other MOVs -
Position (open/close,)
Outside the system, the following information is important to the 4
determination of maximum operating DP:
1.
RCS Pressure Given the above information, maximum operating MOV differential pressures were developed for both open and close operation s.
For each DP, a
justification is given ba sed on the system configuration and equipment constraints.
- Finally, these maximum operating differential pressures were compa red against.the valve design specification DP to verify adeouate design.
i D.
Generic ERG Survey a
The general methodology develope 4 as part of the Westinghouse Owners Group (WOG) MOV program incorporated a survey of the 4
l
generic ERGS to provide a check of -current ERG operations (for the subject MOVs) again st the original fluid systems design assumptions for MOV operating modes.
The ERG survey determined when the selected MOVs are reauired to function for emergency operation.
In addition, the survey identified other important cha racteristics of the system operation (pump on/off) which impact capability to function.
For each MOV, the ERG survey generated a list of ERG steps where either the given MOV is moved, or its proper alignment verified.
Many of the steps on this list were repetitive, therefore, the list was conoclidated to a few general ca se s for each valve.
Each general ca se gives the ERG operation (e.g.,
SI alignment), the required MOV operation (open or close ), and the equipment operating (pumps) during the ope ration. Two general cases were important for confirmation of the fluid systems operating assumptions:
1.
Open/close MOV with pumps on.
n 2.
Open/close MOV with pumps off.
Finally, the ERG operational general ca se s were checked against the fluid systems assumptions.
III.
APPLICATION TO INDIAN POINT 2 A.
HPI Valve Selection Applied to Indian Point 2 Using the selection criteria defined in II.B.,
the HPI valve list was generated for Indian Point 2, and is shown in Table 1.
The table lists the MOVs by function and by Indian Point 2 valve number.
In addition, valve position information is given, along with the functional selection criteria the valve l
meets (either B.1 or B.2 as defined in the " General HPI Valve Selection",Section II.B.).
l B.
Fluid Systems Evaluation Applied to Indian Point 2 The application of the fluid systems evaluation to the HPI system for Indian Point 2 is shown in Table 2.
The table gives the following information:
1.
Indian Point valve number 2.
Valve function 3.
Valve location 4.
Design E-Spec DP 5.
Maximum operating DP. (nominal) 6.
Justification for maximum operating DP 7.
EOP confirmation of operating assumptioas Following Table 2 is the applicable justifications and
(
footnotes.
5 l
l
e The maximum operating DP may result in a relaxa tion of the de sign (E-Spec) DP, based on the justification provided.
The original fluid systems de sign makes operating mode assumptions in order to determine nominal DPs for each MOV.
C.
EOP Survey Applied to Indian Point 2 The application of the ERG survey methodology to the HPI system for Indian Point is shown in Table 3.
The table provides the following information:
1.
List of EOP steps where the HPI valves are operated 2.
A summary description of valve usage 3.
Valve maximum operating DP conditions The Indian Point 2 Emergency Operating Procedures (EOPs) were reviewed to determine the maximum operating DPs ba sed upon emergency plant ope ration s.
- Finally, these re sults were compa red to fluid system MOV operating mode a ssumptions as shown in the last column of Table 2 to verify that emergency operations are bounded by the Fluid Systems evaluatu 6
Table 1. INDIAN POINT 2 HPI VALVES Indian Point rositon or MOV Valve Number
_Re-Position
- Function SI Pump 1810 Normally Open B.1 Suction From (deenergized)
RWST SI Pump 22 887A & B Normally Open B.1 Suction Valves SI Pump 22 851A & B Normally Open B.1 Discharge Valves SI Pump Miniflow 842 Normally Open B.2 Line to RWST 843 (deenerigzed)
SI Pump Cold Leg 856A,C,D,E Normally Open B.1 Injection Isolation SI Pumps 21, 23 850A & B Normally Open B.1 Discharge Valves (deenergized)
- See " General HPI Valve Selection" section (II.B) for an explanation of
" function" 7
TABLE 2. HPI VALVE DPs De sign Maximum Justification for EOP Confiz1 nation Indian Point (E-Spec) DP Operating DP Maximum of Operation MOV Valve Number Close Open Clo se Open Operating DP Assumptions SI Pump 1810 200 200 150 25 Close - 1 Ye s Suc/ tion From Open - 2 RWST SI Pump 22 887A & B 150 150 25 25 Close - 3 Yes Suction valves Open - 3 SI Pump 22 851A & B 1500 1500 1500 1500 close - 4 Yes Discharge Valves Open - 4 SI Pump Miniflow 842 2485 2485 1500 (1500)1 Close - 5 Yes Lina to RWST 843 Open - 6 SI Pump Cold 856A,C,D,E 2500 2500 0
1500 Close - 7 Ye s Leg Injection Open - 8 Isolation SI Pumps 21, 23 850A & B 1500 1500 0 (1500)1 Close - 9 N/A Discharge Valves Open - 9 i
)
8 4
4 i
i
JUSTIFICATION FOR TABLE 2 1.
Valve must be able to close to isolate the RWST from the discharge of the RHR pumps during the recirculation mcde of operation, as a precautiona ry mea su re in the event of backleakage through check valve 847.
For this scenario, the DP across valve 1810 could be as high as the RHR pump discharge head ( ev 150 psig).
2.
The valve must be able to open against a full RWST head of water.
For Indian Point 2, this is /v 25 psig.
3.
This valve must be capable of opening and closing against RWST conditions during the recirculation mode.
This would be /v25 psig to open and close the valve.
4.
These valves are normally open and close to isolate flow from pump 22 to the discharge of either pump 21 or 23 should the other fail.
They would have to close to the shutoff head of SI pump 22, /v 1500 psig.
For opening the same pressure would be seen.
5.
Valve s are normally open and close to isolate miniflow for switchover to recirculation.
DP would be O t,ecau se the SI pumps are off when they close.
6.
The valves are designed to open when the SI pumps are running, so the maximum DP is the pump discharge head, N1500 psig.
7.
The se valves are normally open and close to isolate the cold leg injection from the SI pumps.
They are closed with the pumps off, however, so that DP would be 0.
8.
Valves must open with the SI pumps running so that DP would be pump shutoff head, M 1500 psig.
9.
The se valves a re normally open and would be only close for long-term containment isolation.
The SI pumps would be off when opening and closing the valves so there would be no flow and DP=0.
9 i
e '..
FOOTNOTES TO TABLE 2 1.
Valves 842, 843 (SI Pump miniflow isolation) and 850A, 850B (SI Pump 21, 23 Discharge CIVs) are normally deenergized open.
There is no design ba sis or procedural requirement for these normally open valves to open against delta-p.
However, under the applicable Technical Specification LCO, any one of these valves may be placed in the closed position during normal plant operation for a limited time duration.
If an SI signal was generated while the valve was closed (under the LCO) the valve could be subjected to a delta-p equal to the SI pump discharge head (~1500 psig).
The RO/NPO has the capability to open these valves manually under such a
circumstance (i.e, at this point in the event exposure rates at the valve are expected to be low enough to facilitate access) however, since these valves are motorized it is considered prudent to optionally test these valves for the capability to open against pump discharge head.
Accordingly, these valves will be tested, at Con Edison's option, for their ability to open against pump discharge head.
s 10
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TABLE 3 INDIAN POINT 2 EOP SURVEY HIGli PRESSURE INJECTION VALVES l
11
l e *.
e a
=
1810 - SI Pumps Suction Valve from RWST t
E-O, Step 7 E-O, Step 17 Case 1: Verify Proper Emergency SI Valve Alignment ECA-O.2, Step 3 ES-1.3, Step 12 Case 2: Align Valves for Recirculation ES-1.3, Step 22 CONDITIONS i
Ca se 1: Open valves against full RWST conditions
{
I Close valves against RHR Pump Discharge Head Ca se 2:
i 12 L
.e
i Ca se 1: Open valves with SI pumps running Ca se 2: Close valves with SI pumpF off i
4 7
_... _ _ _ _ _... - -.. _. _ _ _ _ _ _....., _ _ _ _ -. _. _.. _.. _ _.,. ~,.. - _,, - _ -.
o ', e 887 A,B - SI Pump 22 Suction Valves E-0, Step 7 ES-1 3, Step 16 Ca se 1: Proper valve alignment (open)
ES-1 4, Step 7 ES-1.3, Step 4 Ca se 2: Close suction valves to SI pump 22 CONDITIONS Ca se 1: Open suction valves against RWST tank conditions Ca se 2: Close suction valves against RWST tank conditions (pump off) i i
e i
4 14
o *, s a
851 A,B - SI Pump 22 Discharge Valves 4
E-0, Step 7 Ca se l a Verify Proper Emergency SI Valve Alignment CONDITIONS i
Ca se 1: Open valves with pump running 1
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- p 842, 843 - SI Test Line Valves to NST ES-1.3, Step 14 Case 1: Close SI Test Line Valves to MST ES-1.3, Step 21 0
CONDITIONS Ca se 1: Close valves with SI pumps on i.
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