ML20211E437
| ML20211E437 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/02/1986 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-85-003, IEB-85-3, NUDOCS 8610220448 | |
| Download: ML20211E437 (10) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET-P.O. BOX 8699 PHILADELPHIA. PA.19101 (2151 s41-450 2 JOHN S. KEMPER
_VICE PRESIDENT ENG6Ntt RtNG AND RESE ARCM Docket Nos. 50-277 50-278 00T 0 21986 Dr. Thomas E. Murley Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Ave.
-King of Prussia, PA 19046
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 & 3 I.E.Bulletin 85-03, " Motor-Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Settings"
REFERENCE:
Letter J. M. Taylor, NRC to J. M. Fulton (BWROG), Chairman BWR Owners Group, June 8, 1986
Dear Dr. Murley:
This submittal provides Philadelphia Electric Company's (PECo) i response to I.E.Bulletin 85-03.
The reference letter granted an extension for this submittal until October 1, 1986 to participating member utilities of the Boiling Water Reactor Owners Group (BWROG) Ad Hoc Committee for I.E.Bulletin 85-03.
PECo was a full funding active participant in the BWROG effort.
In summary, this submittal contains i
the required design basis differential pressure information, scope of testing, and the schedule for completion of the remainder of the 4
program for Peach Bottom Atomic Power Station as required by item (e) of Bulletin 85-03.
PECo's program is based on the findings of the
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BWROG study chartered to develop a generic position for items required for inclusion in this submittal. The requirements of the Bulletin are restated below along with PECo's responses.
Requirements of Item (a) i Item (a) of I.E.Bulletin 85-03 stated: " Review and document the j
design basis for the operation of each valve,"(The motor-operated valves in the High Pressure Coolant Injection (HPCI) and the Reactor i
Core Isolation Cociant (RCIC) systems). This documentation should include the maximum differential pressure expected during both opening 1
and closing the valve for normal and abnormal events..."
8610220440 861002 PDR ADOCK 05000277 g
l[4 G
r Mr. Daniel R. Muller September 30, 1986 f
Page 2 Response to Item (a):
PECo used the EWROG developed methodology to calculate the maximum operating differential pressures of those subject valves which have an active safety function. For HPCI/RCIC motor operated valves
{
with no active safety function, a conservative methodology was used to calculate the maximum operating differential pressure. The attached
'j table provides the pertinent valve information related to valve safety function and maximum design basis differential pressure. The calculated i
differential pressure was less than the original specified design i
differential pressure in all cases.
~ Requirements of Item (b) i Item (b) of I.E.Bulletin 85-03 states: "Using the results from I
Item (a), establish the correct switch settings. This shall include a j
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)."
i i
Response to Item (b):
PECo identified the need for correct switch setting and overload i
protection during the startup and early operation of Peach Bottom. At that time, programs were established to determine the correct settings and selections. The results of these programs have been incorporated i
into station maintenance procedure M.9.1.
The results of these earlier programs are summarized below:
Limit Switches 1
l The closed limit switch (open torque switch-bypass) is set so the valve is off the seat before the bypass is removed. This assures the full capability of the operator is available to unseat the valve. The applicable section of Maintenance Procedure M9.1 states: "it (the i
closed limit switch) shall operate after the valve comes off the seat".
The open limit switch is set such that the valve does not strike the backseat. Maintenance Procedure M9.1 states: "The open limit i
switch shall be set so that the valve does not coast into the Bonnet (backseated position)".
i Torque Switch I
Torque switch settings were re-evaluated in conjunction with the i
valve and operator manufacturers in the early operational phase of the j
pinnt. These settings were developed using the original specified j
differential pressures which cre greater than the I.E.Bulletin 85-03 l
calculated values. The results of this earlier evaluation are referenced by Maintenance Procedure M9.1 i
i
}
l
M'r. Daniel R. Muller September 30, 1986 Page 3 Overloads PECo recognized the need for special consideration of the overload sizing method due to the intermittent duty of the motor.
In 1975, PECo, in cooperation with Limitorque, established a special procedure to size MOV overloads. The overloads have been re-sized in accordance with that procedure.
In addition, PECo has in place at PBAPS a unique MOV control scheme which provides overload protection during normal manual operation and bypasses the overload during automatic (ECCS) operation. An overload trip can be overridden during manual operation. An overload trip at any time is annunciated in the control room.
As part of its PBAPS I.E.Bulletin 85-03 program, PECo is re-evaluating the minimum required torque switch settings. With the cooperation of the valve and operator vendors, this study will use the newly developed differential pressures.
In addition, a complete reassessment of the capabilities of each valve and operator is being performed to identify the operational margin.
The need for further delineation of correct limit switch settings and overload sizes is also being reviewed. Overall completion of item (b) is scheduled for February 1987.
Requirements of Item (c)
Item'(c) of I.E.Bulletin 85-03 states: " 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) 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 practically be performed. This justification should include the alternative to maximum differential pressure testing which will be used to verify the corrective settings."
Response to Item (c):
The final method operability testing at PBAPS is under evaluation. Differential pressure testing, signature tracing, and a combination of the two are being evaluated.
Revision of system in-service test procedures to demonstrate valve operability at maximum differential pressure is being considered. Signature tracing is also being considered to assure the torque switch is set such that sufficient thrust is available to j
assure closure of the valve at the maximum differential pressure.
In addition, PECo is considering performing signature tracing on valves as they operate under pressure to demonstrate the margin available.
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M'r. Danici R. Muller September 30, 1986 Page 4 The need for operability testing of valves at their maximum differential pressure or by an acceptable alternate method is considered applicable to only those valves identified as having an active safety function. Although only HPC1/RCIC motor operated valves with active safety functions are subject to testing, all HPCI/RCIC motor-operated valves will be subject to the same torque switch setting, limit switch setting, and overload sizing procedures, as well as inservice testing pursuant to 10CFR 50.55a(g).
A decision on the type of testing to be performed is scheduled for December 31, 1986. No specific date can be given for test completion until the test method is finalized; however, it is expected that the testing will be completed for each unit during their next refuel outage.
Requirements of Item (d)
Item (d) of I.E. bulletin 85-03 states: " Prepare or revise procedures to ensure that correct switch settings are determined and maintained through out the life of the plant."
Response to Item (d):
Any necessary revisions to Maintenance Procedure M.9.1 are scheduled to be completed by the Peach Bottom staff with Engineering assistance by the end of the Peach Bottom Unit 2 refuel outage (April 1987).
Philadelphia Electric Company foresces the overall completion of the program to comply with the NRC November 15, 1987 timetable.
However, because of outage scheduling, equipment availability and the extensive modifications planned for the next Unit 3 refuel outage, some of the testing of Unit 3 valves may not be complete.
If this occurs, a program completion report will be submitted to the NRC by November 15, 1987 and a supplemental report detailing the Unit 3 findings will be submitted upon completion of valve testing.
It is expected that some of the testing may require HPCI and RCIC to be operable; if so, the valve testing will be completed upon Unit 3's return to power.
Sincerely, NM ACC/mb/09308601 Copy to:
T. P. Johnson, Resident Site Inspector USNRC, Document Control Desk
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF-PHILADELPHIA J.
S. Kemper, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; that he has read the foregoing response to I.E.
Bulletin 85-03 and knows the contents thereof; and that the statements and matters set forth therein are true..and correct to the,best of his knowledge, information and belief.
$ T,k
,l.
-- 7 g,
Subscribed and sworn to before me this day of Notary Public
'l f
MOTOR OPERATED VALVE PEACH BOTTOM APS DESIGN BASIS
SUMMARY
PHILAD ELPHI A-ELE C T RIC CO, P&ID NORMAL BW ROG SAFETY MAXIMUM SUBJECT fL DESCRIPTION POSITION REPORT DESIGN BASIS. TO TES 1
VALVE No.
SIZ E/T.iPE I D. N O.
CLASS (1) 6P (OPEN/CL.0SO@ @ MAX 6P (M-3593
-RCIC (Sys.13) 11 0-2(5)-21 INTECTION VALVE CLOSED 1
SAF(0/C)
(1191/ It97) psia YES (o* G ATE
- Mo-2.(31-27 MmNun Foov/ BYPASS C LOSE D 2.
SAF(0/c)
(I?95 /1M B)esil Yes-
!l VALVE 2.* 6 tog 6 l
Mo-2('5)-l8 CoNoeNSATE STORAGE.
OPEN 3
S AF(C)
(~ /3 I)P5M 1
66 TANM $dcTgod VALVE'
(, CRATE q
')
l f
Mo-2J5)-41Toaus Soc. Tion C LO S E D
$ AF [O/d) h3 [ 34)ps,&
NES 3
OLATION VALVES 6 GATE
^^
MO-2(5)-39 Mo-2.(5)-30 cst Test c'ose 5
NSAF
[27/1300)psil No i
RETORr4 VALVE 4* GLOBE i
8 NSAF (IRl/l197)es;a No i
'MO-2(53-20 IN:recTios VALVE CLOSED TEST VALVE (c" 6 ATE l
-o a
____ =
u IEB 85-03 MOTOR OPERATED VALVE PEACH BOTTOM APS DESIGN BASIS
SUMMARY
PHILADELPHIA ELECTRIC.CO.
P&ID NORMAL SW ROG SAFET Y MAXIMUM SUBJECT DESCRIPTION POSITION REPORT DESIGN BASIS TO TEST VALVE No.
SIZE /T YPE I D, N O.
CLASS (1)
AP (OPEN/CLOSE)@ @ MAX 6P C3)
I (M-%oT RctC j
9 SAF(0/c)
(1308 / 54)esid Yes MO-2(3)- 132 TORBINE ACCE550R'f C LOS ED
, C. colin 6 LJATCR VALVE 2 GlosE (M-359)
MO-2(31-13)
SAF(6/C) bilb/llllo)psid TES
. VALV E 4" GLo8E
. No-2(3')- 15 STERM LINE IoBoARD OPew SAF(c)
(Ill(o /Ill6)p3;a No ISOLATION VALVE 3 G ATE Mp-2(31-I(,
STEAM UNE OUTBOARD OPE N Q
9AF(C)
(l(llo/ l1llo) ps,a.
No IsoLAT(oW VALVE 3 G ATE Mo-H51244 VAcuan BRE6KER OPEW W
SAF(c)
(- / 4-l) Psid T*5 LtNE *IsothTioN NALVf.
3 AGATE I
i
MOTOR OPERATED VALVE PEACH BOTTOM APS DESIGN BASIS
SUMMARY
PHILADELPHI A ELECTRIC coo i
P&lD NORMAL BW ROG SAFETY MAXIMUM SUBJECT DESCRIPTION POSITION REPORT DESIGN BASIS TO TES l
VALVE NO.
SIZE /T YPE ID.NO.
CLASS (1) op (OPEN/CLOSE)2) @ MAX 6P M-365 H P C.I (Sys. 2.3)
MO-2(31-19 INTECTtoN VALVE C LOSED
{
ggy(o/c)
(l[7,3 / l143)ps,J YES 14 " G AT E i
l M0-2(31-25 Misinun FLowl CwS ED Q
$AF(o/c)
(1345 /iM7)esid YES BYPASS VALVE 4* globe MO-2(5)- 17 CONDENSATE STof%GE OPE W 3
339 (c}
(- / 2.9)psid M
TANK SecTtoN VALVE -
lCo
- G ATE i
. g2(3)- 5B tor 05.90cTio N C LOSED SAF(ofc)
( 9 3 / 34)P5'cl YES h
Is LATt N VALVES l(,' care Mo-2(31-57 Mo-2(M - 2.1 CST TEST RETogg Clos E D 5
NSAF (27[l350)psid.
NO NALVE lo* GLosc I
MO-2(31-24 cst Test IsotnTiou cwstD G
NshF (D/ \\350)ps;A No j
VAtv E lO"GSTE e
j e
L
MOTOR OPERATED VALVE PEACH BOTTOM' APS DESIGN BASIS
SUMMARY
PHILADELPHI A ELECTRIC CO.
~
p ID NORMAL BW ROG SAFETY MAXIMUM SUBJECT
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DESCRIPTION POSITION REPORT DESIGN BASIS TO TEST VALVE No.
SIZ E/T.YPE ID.NO.
CLASS (I)
AP (OPEN/CLOSE)@ @ MAX 6P G M-3(oS HPCI 7
NSAF (2'7/1350)p3; A No MO-3)-3)
HPCI/ RCit TEST C Los ED FLOSH VALVE 4.* GATE 8
NSAF (Il2.3/ll43) psia NO
. Mo-2(5)-Zo Iosecrew v^tVE opeg TEST VALVE g 4,.
[
SdF(0/C)
(lilb/lll(o)fsid NES
, MO-1(31-14 STEAM ADM6Slord CLOSED g'.
VALVE 10* GLosE i
110-2(3)- 15 STEM LINE INWRD OPE d
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sap (c)
( lillo[Il E) psia No l
IsoL ATiod VALVE lO' G ATE H
SAr(c')
(1116/1116)pstd No
_ Mo-2(31-16 srcAn Line oornoNw oet'4 IsoLATied VALVE lo* G ATE Mo-4(5h44A VM_00M BREAKER OPEd Yll.
SAF(c) b-~ [4I PSid I
LirJE ISotATn0N VALVE.
F GATE s
=
NOTES FOR MOTOR OPERATED VALVE-DESIGN BASIS SUffiARY - PBAPS (1) The ilsted safety classifications delineate the active safety functions, which are considered to be within the plant design basis, of all valves subject to IEB 85-03. ~These safety classifications were estabilshed as part of the BWROG effort to develop a conmon BWR methodology that Individual utilities may
. utilize in responding to the bulletin. PECo concurs with these classifications as they relate to the requirements of IEB 85-03 with the following exception. to account for a non-generic design feature:
The HPCI steam admission valve (M0-23-1f0 has an active safety i
function to close for reactor isolation.
The classifications are:
SAF(0), SAF(C), SAFCO/C) - Active safety function Identified in open, close and open/close directions, respectively. NSAF - No active safety function Identified within the plant design basis.
(2) The listed differential pressures represent the maxinun expected values which the valves would be subjected to during operation simultaneous with events considered within the plant design basis. For those valves that the BWROG considered as having an active safety function, the values were generated by methodologies developed by the BWROG. Maxinun operating differential pressures for all other valves were generated from conservative methodologies developed outside the scope of the BWROG.
In all cases, the maxinun operating differential pressures shall form the basis for establishing the mininun torque switch settings.
(3) Valves subject to maxinun differential pressure testing (or acceptable alternate) are those identified as having an activo.
safety function with the exception of those valves whose sole safety function is for Isolation of a line break. Valves falling in this category include the steam line isolation valves. These valves will be tested to the extent practical.
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TSN/pdO9158607
RECEIVED-REGION 1 1985 0CT -3 PH 3: 27 I
1 0
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