NRC-87-0095, Forwards Addl Response to Remaining Actions Identified in IE Bulletin 85-003 & Clarifies Info from Insp Rept 50-341/87-35.Design Testing for Operation of 17 HPCI & 16 RCIC Sys Valves Performed

Forwards Addl Response to Remaining Actions Identified in IE Bulletin 85-003 & Clarifies Info from Insp Rept 50-341/87-35.Design Testing for Operation of 17 HPCI & 16 RCIC Sys Valves Performed

ML20236Q988
Person / Time
Site:	Fermi
Issue date:	11/17/1987
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-87-0095, CON-NRC-87-95 IEB-85-003, IEB-85-3, NUDOCS 8711230010
Download: ML20236Q988 (16)

Text

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O. R lph Sylvin Group Vice President

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Detroi! 6400 North Dixie Hi Edison =w ghway l i

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Novenber 17, 1987 NR'-87-0095 i U. S. Riclear Regulatory Commission i Attn: Document Control Desk Washington, D. C. 20555 1

i' References 1) Fermi 2 NIC Docket No. 50-341 NIC License No. NPF-43 l

2) IE Bulletin 85-03, Motor Operated Valve Common l Mode Failures During Plant Transient Due to Inproper Switch Settings

3) NEDC 31322, BWR Owner 's Group Report on the Operational Design Basis of Selected Safety-Related Motor Operated Valves, Septenber 1986

4) Detroit Illison Letter to NIC, " Motor-OperatcIl Velve Switch Settings," VP-86-0137, dated October 1,1986

5) Detroit Fdison Letter to NIC, " Supplemental Response to IE Bulletin 85-03," VP-86-0162, dated Decenber 19, 1986

6) NIC Letter to Detroit Edison, Inspection Report No. 50-341/87035 (DRS), dated Septenber 23, 1987

7) NUREG/CR-4380 " Evaluation of the Motor-Operated Valve Analysis and Test System (MOVATS) to Detect Degra3ation, Incorrect Adjustments, and Other Abnormalities in Motor-Operated Valves" dated January 1986 l 8) NIC Letter to Detroit Illison, Inspection Report l No. 50-341/87022 (DRS) , dated July 23, 1987 l 9) Detroit Edison Letter to NIC, " Readiness 'for Restart", dated October 3,1987

Subject:

Response to IE Bulletin 85 MOV Common Mode Failures During Plant Transient Due to Inproper Switch l Settings l 8711230010 071117 PDR i

0 ADOCK 05000341 1 PDR glal

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,, UStE Novenber 17, 1987 tE-87-0095 Page 2 Davis Besse and Sequoyah Unit 2 Nuclear Plants experienced an event during which motor-operated valves failed on demand due to .

improper switch settings. Bcsed on these two events and a number '

of earlier similar events, the IE issued IE Bulletin 85-03 (Reference 2) . The purpose of the. subject bulletin was to.

request licensees to develop and inplement a program to ensure i switch settings of certain safety-related stor-operated valves are selected, set and maintained correctly to accommodate the

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maximum differential pressures expected on these valves during j both normal and abnormal events within the design basis.  !

In order to accomplish this purpose,Bulletin 85-03 identified four actions to be taken by licensees. In accordance with the requirements of Item A of Reference 2, Detroit Edison informed the tE (Reference 4) that the operation of ecch valve requiring testing was reviewed in accordance with the Fermi 2 design bases.

The basic methodology set forth in the BWR Owner's Group Report on the Operational Design Basis of Selected Safety-Related Motor-Operated Valves, Reference 3, was used to calculate the maximum valve differential pressure for the opening and closure of each valve. This information was provided in Refererce. 4, Table 1 (Attached) .

Reference 4 was subsequently updated by Reference 5 by confirming- I that fifteen (15) of the thirty-three (33)' IPCI/BCIC valves listed in Table 1 (Attached) were operable based on maxinum differential pressures.

Detroit B31 son's response to the remaining actions identified in IE Bulletin 85-03 are contained in Enclosure 1 of this letter.

Enclosure 2 clarifies some information which was contained in IE Inspection Report 87-035. If you have' any questions, please contact Mr. Lewis Bregni at (313) 586-4072.

Sincerely, Ltb : J ,

1 cc: A. B. Davis  !

E. G. Greenman W. G. Rogers J. J. Stefano G. C. Wright USNIC Region III

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Enclosure 1 NIC-87-0095 Page 1 1

TE BULLETIN 85-03 ITEM A Review and document the design basis for the operation of each valve.

This documentation should include the maxinum 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 l inadvertent valve closures or openings) that are within the plant design basis should be assumed.

DNimir IDTSON'S RESPONSE TO TE BULLLTIN 85-03 IWM A The seventeen (17) HPCI and sixteen (16) ICIC system valves identified in Table 1 (Attached) are motor operated valves (MOVs) at Fermi 2 applicable to the subject bulletin. As stated in the cover letter and again in References 4 and 5, the design basis for the operation of each valve requiring testing was performed in accordance with 1(CFR50.55a(g) .

Table 1 shows the original specified differential pressure (dP), for j the selected HPCI and ICIC valves, used by the valve vendor (s) for valve selection and motor-operator sizing. This information is from i the Fermi 2 Master Valve List, and is either a specified dP or the i specified line design pressure. These values are listed for j conparison against the calculated maxinum dP's. '

The originally submitted IE Bulletin 85-03 maxinum dP's (Reference 4) were conservatively determined by an informal engineering calculation.

In aidition, Fermi 2 Nuclear Engineering perforned and formally documented Design Calculation No. 4685, Maximum Differential Pressure for Selected Safety-Related Motor Operated Valves, applying the generic methodology of Reference 3. This calculation includes the twenty-six (26) MOV's with active safety-related functions of the thirty-three (33) Fermi 2 specific valves. A calculation for the remaining MOV's will be conpleted by the Spring LLRT Outage.

The results of Design Calculation 4685 have been used in two (2) ways:

1) To review and update the Fermi 2 design base;

2) 7b obtain vendor reconfirmation or revision, as necessary of Torque Switch Settings.

The results of Design Calculation 4685 verify that the IE Bulletin 85-03 requirements for each of the twenty-six (26) MOV's evaluated are enveloped by the originally calculated dP's submitted to the NIC in

Enclosure 1 tmC-87-0095 Page 2 Reference 4. Design Calculation 4685 serves as a reconfirmation of the original Fermi 2 design base. The vendors for the selected valves (Wm. Powell and Rockwell International) were provided the results of Design Calculation 4685 to re-evaluate required thrust and reconfirm Torque Switch Settings. Ietters of confirmation have been received with revised Torque Switch Setting recommendations from both vendors.

Torque bypass switch settings were not specifically reviewed for the Bulletin, but have remained as originally established by Fermi 2 for specific valve functional requirements. For the MOV's with an active safety-related function requiring the valve to open, torque switch bypass switches have been used to inhibit the opening torque switch function. This ensures maxinum available operator capacity can be used during unseating and the initial valve stroke movenent when the valve experiences high dP conditions. The control node for each valve is found on the associate valve logic drawing arx3 schematic diagram i which are available on site for review. These docunents provide  !

guidelines for maintenance work performed on MOV's to ensure proper adjustments of the torque switch bypass and limit switch settings.

The use of backseating using the open torque switch has been a conmon ,

practice at Fermi 2 in the past. However, based on a recent '

investigation of using the torque switch for brkseating, Detroit Edison has committed to (Reference 9, E.3) rewire the safety-related valves to use a limit switch trip instead of the torque switch for bmkseating. Nominal position is set as 1/2 turn of the valve stem off the backseat with additional adjustment by field testing. Limit i switch position for valve backseating is being confirmed by post ]

modification testing separately from IE Bulletin 85-03 testing. The HPCI/FCIC System MOV's alrea3y tested were tewired prior to IE i Bulletin 85-03 testing. Testing of the subject valves for IE Bulletin l 85-03 provides redundant confirmation of the switch position.

1 As noted in Refererce 5, the thermal overloa3 sizing for MOV's was j reviewed for all 33 selected valves. This review is also docunented i

! in a Detroit Edison Design Calculation. Based on the results, no l l modifications to the thermal overloa3 sizing for the MOV's were l required. .

l l L Tt should also be noted that no limit switch trips are used for safety-related M07 close-direction functioning. Close position limit l

switches provide only operator information and motor operator trip is j by separate close torque switches.

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Enclosure 1 tmC-87-0095 Page 3 IE BULIRITN 85-03 T'ITM 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 nethods for selecting and setting all switches (i.e.,

torque, torque bypass, position limit, overload) for each valve operation (opening and closing) .

If the licensee determines that a valve is inoperable, the licensee shall also make an appropriate justification for continued operation in accordance with the applicable technical specifications.

DmunT EDTSON'S RESPONSE 'ID TE BULLETTN 85-03 I'IDI B Using revised Torque Switch Settings provided by the valve vendors, Fermi 2 engineers prepared a design change document, Potential Design Change 6557, which directed plant maintenance efforts to establish new settings to neet the IE Bulletin 85-03 criteria. Torque bypass switch settings were not altered by this effort as noted previously, i Open-direction limit switch settings have been established as a l separate issue, although some adjustment was later made due to field testing for IE Bulletin 85-03 Action C. Potential Design Change 6557, Rev. C, was fully inplenented for revised Torque Switch Settings as of ,

September 30, 1987. i Fermi 2's MOVATS program has found each MOV tested able to neet the IE Bulletin 85-03 acceptance criteria established. A brief report of j testing conducted to date was provided in Refererce 9, Item E.8. -

Additional details are provided under Item C of this enclosure. The test program did identify one of ten notor-operator assenblies functioning with a target thrust value above the operator rating.

Although the valve had met the MOVATS test criteria, this motor operator was replaced with a larger notor operator resolving this problem. The remaining twenty-three (23) MOV's to be tested were reviewed for the sane problem.

Only one (1) valve, of the remaining twenty-three (23) E5150F012, has been found to have an operator sized less than its IE Bulletin 85-03 target thrust value. This valve is not required to perform an active safety function, and is not c 10CFR50, Appendix J valve. The valve has and continues to neet its ASME XI Pump and Valve Program criteria. Based on the results of the MOV's already tested, the E5150F012 notor-operator assenbly is capable of reeting the IE Bulletin 85-03 acceptance criteria and, therefore, the valve is considered to be operable. However, based on plant-life service considerations the E5150F012 notor-operator will be replaced with a higher load rated operator during the Spring 1988 LLRT Outage.

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l Enclosure 1 NIC-87-0095 Page 4 TE BUllEPIN 85-03 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 maximm differential pressure determined in item A above with the exception that testing motor--operated valves under corditions simlating a break in the line containing the valve is not required.

Otherwise, justification should be provided for any cases where testing with the maximm 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.

Each valve shall be stroke tested, to the extent prcctical, to verify that the settings defined in Item B above have been properly implemented even if testing with differential pressure cannot be performed.

DETTIOTT ETSON imSeONSM 'IO TE BULTEPTN 85-03 TTFM C Applying the results of the generic evaluation effort reported by Beference 3, six (6) HPCI valves and four (4) BCIC valves of the Fermi 2 specific design do not require dP testing. These valves are identified in Table 1 Notes 1 and 2 (Attached) . For the remaining EPCI and BCIC system valves, Fermi 2 is performing operability testing which inposes dP's on the valves as part of system performance confirmation. This is being accomplished by plant startup test program performd to verify proper system initiation, valve sequencing, and flow and pressure capability. Operability testing of HPCI/BCIC systems will continue as required by the Fermi 2 Technical Specifications and post maintenance modification requirements. The dP's experienced by the valves during operability tests are not as high as the calculated dP's, but do represent dP's under the actual plant conditions. These operating condition dP's are conservatively bounded by the static testing program for MOV's as described below.

Fermi 2 does not believe that replication of the dP's calculated and reported in Design Calculation 4685 are practical or worthwhile test conditions. The assumptions of the calculations are conservative in that they maximize the end result. Replication testing would require altering valve logic and tutbine punp controls by tenporary modification in order to achieve the configurations modeled in Reference 3 and induce the conditions of the calculation. The risk to safety-related conponents and systems by such alterations, in order to perform the testing, do not appear to justify its use. Additionally, static testing systems are available, which have been accepted by the hTC, to test MOV switch settings. Fermi 2 will conply with the requirements of IE Bulletin Item C by using MOVATS Inc.

Enclosure 1 IGC-87-0095 Page 5 Recommendation for using MOVATS to comply with IE Bulletin 85-03 requirements is contained in both References 6 aM 7. As this system has been fully evaluated by the NRR's Engineering Technology Division, no explanation of the MOVATS technique or capabilities will be discussed in this submittal. Detroit Edison enphasizes that the testing performed against the calculated dP's is done in a i conservative manner. As stated, the calculation method in Design Calculation 4685 is conservative in that it maximizes the results.

The dP's were provided to MOVATS to determine a thrust equivalent, 90% j probability margin, and 90% confidence margin, plus an error margin l l for each selected valve's opening and closing targets. Due to significant data scatter in the MOVATS data base from field testing, the margins added can be very large. For example: for testing MOV E4150F0ll, observed during inspection (Reference 6), the opening i target thrust is 12,245 lbs. However, the calculated thrust ,

equivalent is only 5,209 lbs.; this represents a 135% margin. 1

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MOVATS testing presents fewer equipment and personnel risks than )

replicated dP testing. In addition it also provides greater )

precision, repeatability of the test corditions, and imnediate '

I retesting to check adjustments. For these reasons, Fermi 2 has chosen to apply MOVATS testing to the 33 selected valves required for the Bulletin response. Testing of valves has been conpleted on ten (10) of the thirty-three (33) selected valves. The test program for the remaining twenty-three (23) valves will be completed by the end of the the Spring 1988 ILRT Outage. Data submittal of the testa results will be provided by a supplemental report no later than 90 days after restart from the ILRT Outage.

Reference 9, Attachnent E.8, reported overall success with the testing of ten (10) MOV's. These ten (10) MOV's are identified in Ibte 3 on 1 Table 1. Ibte 4 on Table 1 identifies valve E4150F079, and Note 5 identifies valve E5150F008, both of which were discussed in the Reference 9 attachnent. Ibte 6 identifies three (3) MOV's fourd with an overthrust condition which was identified and corrected under MOVATS testing that has been conpleted to date. Ibtes 7 through 11 of Table 1 provide additional information.

MOV's E4150F079 and E5150F008 were discussed in the attachnent to Reference 9. As discussed under Item b of this enclosure MOV E5150F012 represents a like situation as that originally found with MOV E5150F008. The notor repimenent performed on MOV E4150F079 was based on an Engineering judgenent to expedite restoration of the valve's operability. Concurrence was obtained from Limitorque to use the large notor with a higher Torque Switch Setting which ha3 resulted from valve ILRT. This eliminated a potential notor stall problem without requiring repetition of the ILRT on the valve.

As detailed in Enclosure 2, the overthrust condition for MOV E4150F0ll was corrected by repacking the valve and reducing the Torque Switch 1

1

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,, Enclosure 1

~ NRC-87-0095 Page 6 1

^ Setting to an as-left value which results in ' total notor-operator ]

' thrust less than the. operator rating. The other two (2) MOV's were i corrected.in a similar manner. j J

Also, as reported in Reference 9, the opening torque switches were .

adjusted such that open Torque Switch Settings now meet the IE. 1 Bulletin 85-03 meeptance criteria.for the. ten (10) MOV's tested.

However, as previously discussed, the opening torque switches are bypassed to inhibit their function during the high dP portion of.the stroke. This ensures that valve ' opening will occur under high dP conditions for. the 23 untested MOV's. With the incorporation of limit  ;

switch position trips for valve backseating, the lesser Torque Switch i Settings are no longer critical, and the open Torque Switch Settings J of the remaining twenty-three (23) MOV's'.will be raised during MOVATS .

testing.

The ten (10) MOV's selected represent a worst-case selection of the i thirty-three (33) MOV's in the Fermi 2 IE Bulletin response program. l Based on the success of MOVATS test conducted on these initial ten I (10) MOV's Detroit Edison is confident that all thirty-three-~(33)  ;

MOV's can demonstrate performance suitable to meet the TE Bulletin 1 85-03 acceptance criteria. I l

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Enclosure 1 PEC-87-0095 Page 7 TE BULLETIN 85-03 I'IM4 D 1

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.

DETROTT EDISON RESPONSE TO TE BUIJEI'IN 85-03 I'191 D Fermi 2 Nuclear Engineering (NE) will provide program control and direction to the Nuclear Production (NP) Maintenance department for required testing. Details of each valve and actuator design, switch settings, functions, acceptance criteria, trended data and design base l

documentation will be tracked by this tabulation. Fermi 2 NP Maintenance and Engineering already has procedures in place for i controlling switch setting and field testing of MOV's, including operational dynamic testing.

To provide enhanced engineering capability, and in response to the critique of Reference 6, training of Detroit Edison personnel on the MOVATS system and the data (signature) analysis is being obtained.

, Several engineers, currently assigned responsibility for the test I program and Bulletin response, will receive training prior to any additional valve testing. Maintenance technicians will receive training on the use of the MOVATS 2150 test system prior to the LLRT outage which is schedule for Spring 1988. MOVATS has been contracted to test and report on all thirty-three (33) selected valves of the Fermi 2 IE Bulletin 85-03 response. This will provide Fermi 2 personnel sufficient experience to continue the correct and accurate application of the MOVATS technique. ,

1 An administrative procedure to provide the appropriate dircction and )

establish formal interfacing requirements between the current NE and NP procedures is being developed. This effort will also be coupletEd by the end of the 1988 LLRT Outage. This document will assign responsibility and provide the necessary interfaces between NE and IP departments for the future conduct of the program. Until the IE Bulletin 85-03 testing and reporting is conplete, a task force has been established with NE and IP participation, which is chaired by a responsible NE staff engineer also assigned as the IE Bulletin 85-03 response coordinator. This task force ensures close working contact a between NE and NP on the required valve testing. It will also develop I and test the necessary administrative interfaces and program q requirements using the thirty-three (33) selecta3 valves as the case j study. j In summary, the action commitments including those acted previously are: .

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.. Enclosure 1-13C-87-0095 l Page 8 l

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1. Complete dP calculations for seven (7) additional MOV's by the end l of the Spring 1988 ILRT Outage. I I

2. Replace the motor operator on E5150F012 during Spring 1988 LLRT .l Outage; )

3. Backseat limit switch position confirmation during MOVATS testing of the remaining twenty-three (23) MOV's; 1

4. Train engineers in signature analysis;

5. Train maintenance technicians on test system;

6. Revise NB 5.6, and revise appropriate maintenance instructions, as necessary;

7. Testing of the remaining twenty-three (23) MOP's;

8. . Establish permanent training program for engineering requirements and maintenance training requirements, and;

9. Establish MOV diagnostic test program for thirty-three (33) selected valves as part of the Fermi 2 ISI Program.

Conpletion of these action commitments will be reported in the supplemental report following the LLRT Outage.

Finally, using the initial testing of the selected valves as a baseline, NE will develop acceptance criteria and/or guidelines for predictive identification of MOV problems. One suggested method is to conpare subsequent FCC motor signature to the conbined ICC motor and valve actuator signature profiles initially recorded. This and any other methods will be evaluated and reported on in the supplemental report.

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Enclosure 2 NBC-87-0095 Page 1 {

1 l

l FOLLOWUP ON INSPECTION REPORT NO. 50-341/87035 (DRS)

IE Inspection Report 87-035 amongst other things discussed some of the MOVATS testing that was perfomed at Fermi 2. Within the Inspection Report, Item 3 paragraph a, Test Observation a couple of incorrect statements were made concerning testing of MOV E4150F0ll:

Statement 1) That "as-found open thrust (14740 lbs) did not meet the l target thrust in the static condition (25593 lbs) ."

Correction 1) The open-direction target thrust is 12, 245 lbs; this )

is under the as-found thrust, therefore this MOV passed the target thrust test.

Statement 2) That "the open target thrust desired on this valve slightly exceeds the rating of the motor operator."

Correction 2) The rating of the EMB-O motor operator is 24,000 lbs.,

well above the open target thrust of 12,245 lbs.

Statenent 3) That "In order to neet the target thrust, the as-left open torque switch setting was raised."

Correction 3) In fact, the open torque switch setting was lowered.

The initial setting was >2.75 of 3.00 (maxinum limiter plat allowable setting). The resulting total thrust at this setting was >30,000 lbs which is an overthrust i

condition relative to the operator rating. The valve was repacked, ard then the Torque Switch Setting was reduced to 1.5+. The Torque Switch Setting was subsequently raised to an as-left open Torque Switch Setting of 2.2+ during post-maintenance and for final MOVATS testing. The as-left Torque Switch Setting 1 (2.2+) reduced the total thrust below the operator 1 rating to resolve the overthrust cordition. {

These corrections will clarify the test results reported for valve E4150F0ll to correct the possible misinterpretations of the Fermi 2 testing to date, and to address the concerns expressed about Fermi 2 response to IE Bulletin 85-03. As shown by this example, in addition I to the report, Item E.8, in lotter Reference 9, Fermi 2's MOV test l program is progressing better than reported by Reference 6. Detroit 1 l Edison will ensure proper communication of the tests, problems I

observed by the MOV test program and corrective measures taken. Fermi 2's engineers are working to ensure all problems identified by the MOV test program are resolved. Emphasis has been placed on achieving and maintaining MOV configurations and Torque Switch Settings in compliance with the design bases and IE Bulletin 85-03 requirements.

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_ e e oa i p r

e

_ v v nt ye st D l l oaB v t ea I a a i l l ns iW U n ts V t V s ot a oe r o

L s s s sV iT eo g F i en en eI e t - ns n

- t c

T r T r r Th cee i si e S

E n Tt u

Tt u pl pod u s evv jll b el v r c ol V u S e S e u onl naa ucoa L F CR CR SP aF IVV TACV A .

V M

E T

S Y

S r ee

_ I vb C l m '

P au 5 8 9 H VN 6 7 L (  ! ll l

. Table 1 Notes imC-87-0095 Page 1 i

TABLE 1

1. Does not perform an active, safety-related valve function, extremely low probability of changing position; maximum dP replicate testing not required per NEDC-31322 (Reference 3) .  :

i

2. Functions to close only for isolation of line break; dP replicate testing is not required per IE Bulletin 85-03 (Reference 2) .

3. MOV tested by MOVATS, Inc. during Fermi 2 Outage 87-06.

4. MOV passed IEB 85-03 testing; motor replaced with larger size due to an increased close Torque Switch Setting to neet LLRT. Valve to be reworked and close Torque Switch Setting to be reduced during the Spring 1908 LLRT Outage.

5. MOV passed IEB 85-03 testing; target thrust exceeded operator I l rating, a larger motor-operator assembly was installed and I retested to pass IEB 85-03 criteria.

l

6. Torque Switch Settings found such that MOV operating in overthrust conditions; MOV reworked and Torque Switch Settings reduced to eliminate overthrust, MOV passed IEB 85-03 testing.

7. 107R50, Appendix J valve.

8. Actual Torque Switch Settings as documented in the Fermi 2 post-maintenance MOV testing procedure, MI-E0043. Recommended Torque Switch Settings provided by valve vendors after review of maximum calculated differential pressures from Design Calculation 4685.

9. MOV has no vendor recommended Torque Switch Settings; Torque Switch Settings determined by startup testing. Actual settings may vary depending upon maintenance performed.

10. Calculated dP's were not provided by Table 1 of Reference 4. A separate calculation to determine the IEB 85-03 dP values will be completed by Decenber 31, 1987.

11. MOV's for which the original specified dP is the design -line pressure.

NA = Not applicable, value applied only to the required saf ety-relates function.

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