ML20211Q775
| ML20211Q775 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/18/1987 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| (NMP2L-0998), (NMP2L-998), IEB-85-003, IEB-85-3, NUDOCS 8703030180 | |
| Download: ML20211Q775 (2) | |
Text
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." P NIAGARA MOHAWK POWER CORPORATION /301 PLAINFIELD ROAD. SYRACUSE, N.Y.13212/ TELEPHONE (315) 474-1511 February 18, 1987 (NMP2L-0998)
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, D.C. 20555 Re:
Nine Mile Point Unit 2 Docket No. 50-410 Gentlemen:
Please find enclosed our response to I.
E.
Bulletin 85-03 " Motor Operated Valve Common Mode Failures During Plant Transients Due To Improper Switch Settings".
On May 12, 1986 we notified Region I that we would submit our response following our review of the Commission's appraisal of the BWR Owner's Group report on this bulletin.
Subsequently, we have reviewed the BHR Owner's Group report and find our program does not require reference to this report for justification. He are providing our response at this time.
Very truly yours, NIAGARA M0 HANK POWER CORPORATION C. V. Mangan Senior Vice President CVM/ GAG /cla (2054H)
Enclosure xc: Regional Administrator, Region I Ms. E. G. Adensam, Project Director Mr. H. A. Cook, Resident Inspector Project File (2) g30%$k h50 j0 g
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C00911SS10N In the Matter of
]
1 Niagara Mohawk Power Corporation
]
Docket No. 50-410 3
(Nine Mile Point Unit 2)
]
AFFIDAVIT C. V. Mancan
, being duly sworn, states that he is Senior Vice President of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
C=./W AAAriA O
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Subscribed and sworn to before me, a Notary Public in and for the State of New York and County of O/2fAIMA/l
, this
/8 day of hbtllDllI
,1987.
d 1
i 0b)]Db L 0//!$lN1 Notary Public in and for
____ h/?LVlflAdd_
County, New York 0
l My Commission expires:
QW15 file pumeismesun M
in Co. k hw March 30,
I 1
INITIAL REPORT ON OPERATIONAL READINESS OF MOTOR OPERATED VALVES IN THE HIGH PRESSURE CORE SPRAY AND REACTOR CORE ISOLATION COOLING SYSTEMS l
NINE MILE POINT UNIT #2 I
IN RESPONSE TO UNITED STATES NUCLEAR REGULATORY COMMISSION j
i BULLETIN 85-03 February 1987 i
i
{
j 2054H
I.
INTRODUCTION NRC I.E.
Bulletin 85-03 (Motor Operated Valve Common Mode Failure) requested that owners of boiling water reactors develop and implement a program to ensure that switch settings on selected safety-related motor-operated valves are selected, set, and maintained correctly to accommodate the maximum differential pressures expected on these valves durlag both normal and abnormal events within the design basis.
Further,Bulletin 85-03 identified the Reactor Core Isolation Cooling and High Pressure Core Spray Systems as the systems of concern.
Table 1 lists the applicable MOVs from these systems.
Bulletin 85-03 requests specific action from all holders of operating licenses or construction permits.
The action required is in six parts.
The following is Niagara Mohawk's position on each of these six parts.
II. NIAGARA M0 HAWK POSITION ON BULLETIN 85-03 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 extent 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 and inadvertent equipment operations (such as inadvertent valve closures or openings) that are within the plant design basis should be assumed."
NMPC Position:
A review was conducted which verified that all valve design criteria have been incorporated into the valve specifications.
These criteria include maximum differential pressure expected during both opening and closing the valve, for both normal and anticipated abnormal events, as applicable.
Table 1 summarizes the results.
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.;
2054H NMPC Position:
0 All valve operators were sized using the results of (a) above.
The valve operator sizing calculations were prepared, reviewed, and independently reviewed by the operator vendor (Limitorque).
All motor-operated valve data (setpoints, torque, thrust, etc.)
were tabulated on design drawing series (Stone and Webster)
EP-410 and valve elementaries.
See Table 2 for the program to review and revise, if necessary, the switch settings.
Action Item:
"If the licensee determines that a valve is inoperable, the licensee shall also nake an appropriate justification for continued operation in accordance with the applicable technical specification."
NMPC Position:
If, in the course of this program a valve is determined to be inoperable, an Occurrence Report (OR) will be generated and justification for continued operation documented per AP-10.2.2 (Ref. 10).
When repairs are required, maintenance will document the work performed on the Work Request (HR) (Refs.
2, 3,
and 5).
The Operations Department will perform post-maintenance testing and document results per Administrative Procedure (AP) AP-5.2 (Ref.
- 9) prior to returning the valve to service.
Action Item:
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 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 pressure testing which will be used to verify the correct settings."
NMPC Position:
Valves and operators were shop tested by the valve vendor at the differential pressures listed in Table 1.
At these differential pressures, a corresponding torque switch setting was recorded.
At this setting, the vendor data sheets confirm the valves opened / closed.
hith the exception of one valve (2ICS*MOVil6),
torque switch settings were less than or equal to those recommended by the operator vendor.
This is to be expected since conservative factors were used in the sizing of the valve operator.
2054H i
In the one exception, the valve vendor found that during the shop max d P testing, a higher torque switch setting was needed to open/close the valve.
In this case, the torque switch setting was set at the higher setting.
During startup and test, this setting was confirmed (Ref. 7).
MOVAT testing is being performed to confirm required thrust values are obtained and to establish a base line.
Subsequent MOVAT testing throughout the life of the plant will be performed when deemed appropriate by the maintenance / engineering staff.
Valve operability will be demonstrated by the performance of valve operability, system functional and system integrity tests at the frequencies specified in the Technical Specifications.
Valve operability tests will measure stroke times and provide ISI limits for monitoring valve performance (See References 11,12,15,
& 16).
Quarterly system integrity tests will monitor pump and valve performance at rated conditions.
(See References 13 &
14).
System functional tests will verify. pump, valve and interlock operability once per operating cycle (See References 19 and 20).
Prior to returning a containment isolation valve to service, or at least once per 18 months, a valve leakage test will be performed (See References 6,
17 & 18).
Leakage rates will be compared against ISI limits to monitor valve performance. (See Reference 21).
The performance of the above routine surveillance tests will provide adequate means for detecting valve degradation as well as providing a check on maintenance practices.
Based on the above, NMPC does not consider additional testing at maximum differential pressure necessary.
Action Item:
"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 maximum differential pressure can not be performed."
NMPC Position:
Stroke time tests will be routinely performed in accordance with Technical Specifications as described above.
Additionally, any changes in settings implemented as a result of this program will be properly validated by the performance of valve operability tests that measure stroke times.
2054H I
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."
NMPC Position:
Correct settings will be determined via the program described in (b) above.
Existing plant procedures will assure that correct switch settings are maintained throughout the life of the plant.
As a check, MOVAT (See Reference 4) capability is available to determine the overall operating condition of MOVs and also eliminate or minimize the impact of generic problems associated with motor operated valves.
The NMP2 Independent Safety Engineering Group (ISEG) assesses the operating experience of industry by the review of INP0, NRC and other industry documents.
Any pertinent recommendations are incorporated into the appropriate plant procedures or documents for implementation as approved by the Operations Experience Assessment Committee per AP-3.4.2 (See Reference 1).
This assures the incorporation of applicable industry recommendations into plant procedures.
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.
For plants with a CP, this schedule shall ensure that these items are completed before the scheduled date for OL issuance or within two years from the date of this bulletin, whichever is later."
y NMPC Position:
This report is presented to respond to (a) above, and also serve as a program to accomplish items (b) through (d).
This program will be completed by October 15, 1987.
Action Item:
f.
" Provide a written report on completion of the above program.
This report should provide (1) a verification of completi. n of o
the requested program; (2) a summary of the findings as to valve operability prior to any adjustments as a result of this bulletin and (3) a summary of data in accordance with Table 2, Suggested Data Summary Format."
i NMPC Position:
A final report will be provided by November 15, 1987.
1 2054H References 1.
NMP2 Administrative Procedure No.
AP-3.4.2,
" Operations Experience Assessment".
2.
NMP2 Electrical Preventative Maintenance Procedure No. N2-EPM-GEN-RS20, Rev. O, "' AC' Limitorque Operators (Type SMB, SB and SMC) and Associated Motor Control Center (MCC) Unit".
3.
NMP2 Electrical Preventative Maintenance Procedure No. N2-EPM-Gen-R521, Rev. O "'DC' Limitorque Operators (Type SMB, SB and SMC) and Associated Motor Control Center (MCC) Unit".
4.
NMP2 Electrical Preventative Maintenance Procedure No. N2-EPM-V3, Rev. O, "Limitorque Motor Operated Valve Testing Utilizing MOVATS-2000".
5.
NMP2 Electrical Maintenance Procedure No.
N2-EMP-114.1, "Limitorque Disassembly and Assembly of Type SMB and SB Series Operators".
6.
Niagara Mohawk Power Corporation Nine Mlle Point #2 Technical Specifications 4.6.3.1 & 4.6.3.2 7.
NMPC Procedure No. ED. GENE.014 " Motor Operated Valves".
8.
GE Design Specification Data Sheet, 22Ad967AA, Rev. 2.
9.
NMP2 Administrative Procedure No. AP-5.2 " Unit 2 Procedure for Repair".
10.
NMP2 Administrative Procedure No. AP-10.2.2,
" Procedure for Reporting Variations for Normal Plant Operation, Deficits, and Non-Compliance".
11.
N2-OSP-ICS-CS001 "RCIC Valve Operability Test (Cold Shutdown)"
- 12. N2-OSP-CSH-CS001 "HPCS Cold Shutdown Valve Operability Test and System Integrity Test"
- 13. N2-0SP-ICS-Q002 "RCIC Pump and Valve Operability Test and System Integrity Test" 14.
N2-0SP-CSHQ002 "HPCS Pump and Valve Operability Test and System Integrity Test"
- 15. N2-OSP-ICS-Q001 "RCIC Valve Operability Test"
- 16. N2-OSP-CSH-QOO1 "HPCS Valve Operability Test"
- 17. N2-0SP-ICS-R@001 "RCIC Pressure Isolation Valve Leakage Test" 18.
N2-OSP-CSH-R@001 "HPCS Pressure Isolation Valve Leakage Test" l
19.
N2-0SP-ICS-R001 "RCIC System Functional Test"
- 20. N2-0SP-CSH-R001 "HPCS System Functional Test and Response Time Test"
- 21. NMP2 ISI-025 " Trend Analysis" l
2054H l
T/BLE 1 SYSTD1 NRE - HIG1 FRESSLRE GRE SRAY (IPCS)
VALVE VALVE (PERAftR Naninal tbx.6P TestAP tiark Size Rating Pbtor Serial Open/Close Open/Close Valve tirber Manufactumr _ Type _
Ind es Psia ibnufacturw tbdel RR1 tb.
pg g
Desim Basis Function PCSf7 Andor/
Gate 14 150 Limitorgte 90- 1800 223 100 90(2)(9)
(7)
CST Suction t0/101 Darling 0 0-10 498 (E22-F001)
PGH*
Mchor/
Gate 4
900 Limitorque 90-03@0 726 1575 1575 (2)
(7)
Min. Flow IW105 Darling
-25 320 Supp. Pbol (E22-F012)
PGH*
Anchor /
Gate 12 655 Limitorque 9 0-3 3600 734 1575 1575 (2)
(7)
Injection t W 107 Darling
-150 043 (E22-F001)
FGH*
Mchor/
G1che 10 900 Limitoque 9B-1800 220 1575 1575 (2)
(7)
First Test FW110 Darling 4-200 213 Storage 1K (E22-F010) 2GH*
Mchor/
Globe 12 TO Limitorque 90- Two 221 1575 1575 (2)
(7)
Test FW111 Darling 4-150 571 Suppression (E77-F023)
Pool 2GH*
Mchor/
G1che 10 900 Limitorque 90- 1@0 220 1575 1575 (2)
(7)
Second Test FW112 Darling 4-200 214 Storage TK (E72-FD11)
PGH*
Anchor /
Gate 18 150 Limitorque SD-0 3000 223 100 100 (2)
(7)
Stopmssion tW118 Darling
-25 968 Fool Suction (E22-FD15)
TELEI(cont.)
SYSTW NME - REACT (R ORE ISOLATION COOLING (ICS)
VALVE VALE (PERA1(R Nmtinal Max.AP TestAP(1) fiark Size Rating Ntar Serial Open/Close Open/Close Valve Nrber Manufacturer Type Inches Psig Manufacturer % del Rm No.
pg g
Desim Basis Function 2IG*MOV Velan Globe 2
1500 Limitorque 9B-1900 L371059* 1350 1525 (3)
Lube 011 Cooler 116 00-5 Inlet 2ICS4tN Velan G1che 4
R)0 Limitorque 90- 1900 293289 1158 1140(9)
(4)
Steam Supply 120 00-10 2ICS4fN Velan Cete 10 900 Limitorque SB-2 3400 331411 1158 liS8 (4)
Steam Sipply 121
-8) 05 Prirery 2IG*MOV Velan Gate 12 150 Limitorge SPB-1900 2K3423 FtD 2m (6)
Exhaust 122 0-25 2I5*ffN Velan Cete 4
900 Limitonpe 9B-1900 293290 1350 1265(9)
(3)
Full Flow Test 124 00-10 Blodcing PIG *MOV Velan Gate 6
900 Limitorque SB-1900 795128 1350 1525 (3)
Ptsp Discharae 126 0-40 Rx Vessel FI5*fTN Velan Cete 10 900 Limitonse 9 B-3400 331328 1158 1140(9)
(4)
Steam Sipply Inside 128 2-60 Prirery 2IG*MOV Velan Gate 6
150 Limitorque 90- 1900 293295 155 100(10)
(8)
Punp Suction GT 129 0 0-10 ZI54TN Velan Gate 6
150 Limitorque 9B-IK10 793295 155 100(10)
(8)
Ptsp Suction Supp.
136 00-10 Pool FI5*f10V Velan G1che 2
15W Limitorque 9B-iwu LJ//UbH* 1350 1525 (3) flininum Flow I43 00-5.-
TELE 1(cont.)
SYSTDi NAE - REACTIR GRE ISOULTION COOLING (ICS)(cant.)
VALVE VALVE (PERATIR Nortinal Max.AP Test 6P(1)
Mark Size Rating Motor Serial Open/Close Open/Close Valve Mmber Manufacturer Type Inches Psig Manufacturer Model RIN No.
psi pg Desics Basis Function 21CS*MOV Velan Globe 1 1/2 1500 Limitortpe M-1900 L375498* 160 125(9)
(5)
Exhaust Vac. Breaker 148 000-2 Irboarti 2ICSMN Velan Globe 1
1500 Limitorque 96-1900 L380321* 1158 1140(9)
(5)
Bypass MN120 159 0(D-2 2ICSMN Velan Globe 1 1/2 1500 Limitorque H-1900 L375499* 160 125(9)
(4)
Exhaust Vac. Breaker 164 000-2 Outboard 2fCS*MOV Velan Globe i
1500 Limitorque 9B-1700 354997 ~ 1158 1158 (4)
Bypass NW128 170 000-2 TABLE 1 (cont.)
NOTES 1.
Maximum differential pressure test performed at manufacturer's shop using actual valve operator.
2.
Since shop operability tests against' maximum design' differential pressure were performed, motors for operators have been upgraded to conform with EQ requirements.
3.
Maximum discharge pressure of the RCIC pump, zero pressure on the other side of the valve.
(See Ref. 8).
4.
Maximum steam pressure to the RCIC turbine; zero pressure on the other side of the valve.
(See Ref. 8).
5.
Peak steam exhaust pressure from the RCIC turbine, zero pressure on the other side of the valve.
(See Ref. 8).
6.
Conservatively selected on the basis that inadvertent closure of this valve, when the RCIC system is running, will not result in damage to the valve.
(See Ref. 8).
7.**
See GE Design Specification 22A1483 "High Pressure Core Spray System" and GE HPCS Process Diagram 731E932AF.
8.**
Conservatively selected based on static height of suppression pool
- water, plus containment design pressure or static height of condensate storage tank water (whichever is higher).
See calc.
A10.1-H-21, Rev. 1.
9.
No torque switch setting change is required due to difference in max. and test differential pressures.
10.
Motor operator sized on 100 psid.
The 155 psid is the maximum differential pressure the valve could be subjected to; however, under that condition, valve operation is not required.
- Valve operators have been changed from those used in shop differential pressure tests.
- Referenced material is available upon request.
2054H e
Motor Operated Valve Review and Revision Program Table 2 Phase 1:
All calculations for thrusts, torques and torque switch settings have been obtained from Stone & Webster Engineering Corporation for all valves listed in Table 1 for review by NMPC Engineering.
Torque switch bypass, position limit and motor overload settings are also being reviewed.
Table 3 presents a summary for the torque switch bypass settings.
Phase 2:
NMPC Engineering will raiew and verify any discrepancies as required.
Special attention will be given to verifying that maximum design differential pressures listed in Table 1 are used as the basis for the calculations.
Phase 3:
EP-410 series drawings and electrical ESK elementary drawings for these valves will be revised, if necessary, based on results of (2) above.
Phase 4:
Based on the above results, NMPC electrical maintenance will field change settings, if required, per EP-410 series drawings and electrical ESK elementaries and in accordance with the applicable maintenance procedures.
(See References 2 through 5).
Thrust values can be checked using M0 VATS.
Data collection using MOVATS Inc. test equipment has been completed for the valves listed in Table 1, except for valve 2ICS*MOV121.
Phase 5:
Using the surveillance, leak test, system functional test and maintenance procedures described in the text, valve / operator performance is monitored throughout the life of the plant.
2054!1 Torque Switch Bypass Summary Table 3 MOV NO.
BYPASS PER ESK SAFETY DIRECTION Closed to Open to Open
/ Close 2ICS*MOV116 95/0 Closed /0 pen Table 3.9A-12 FSAR 120 95/0 Closed /Open 5.4-22 FSAR 121 95/95 122 95/95 124 0/95 Open/ Closed 5.4-23 FSAR 126 95/95 128 95/95 129 95/95 136 95/95 143 95/95 148 95/95 159 95/0 Closed /Open 5.4-23 FSAR 164 95/95 170 95/95 2CSH*MOV101 95/95 105 95/95 107 95/95 110 0/95 Open/ Closed Figure 6.3-1 FSAR 111 0/95 Open/ Closed Figure 6.3-1 FSAR 112 0/95 Open/ Closed Figure 6.3-1 FSAR 118 95/95 2054H