ML20238C662
| ML20238C662 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/01/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| IEB-85-003, IEB-85-3, NUDOCS 8709100287 | |
| Download: ML20238C662 (6) | |
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A B ALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TitRNAN Vice PRESIDENT NucLEAn ENER0Y September 1,1987 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Resnonse to Reauest for Additional Information on IE Bulletin 85-03 i
REFERENCES:
(a) Letter from Mr. E., C. Wenzinger (NRC) to Mr. J. A. Tiernan (BG&E),
dated July 29, 1987, Request for Additional Information.
(b) Letter from Mr. J. A. Tiernan (BG&E) to Dr. T. E. Murley (NRC),
dated May 15, 1986, IE Bulletin No. 85-03; Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings.
(c) IE Bulletin 85-03; Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings.
Gentlemen:
In Reference (a), you requested additional information regarding our response to IE Bulletin 85-03 (References b and c). Our response is provided in Enclosure (1).
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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Document Control Desk September 1,1987 Page 2 cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire E. C. Wenzinger, NRC R. A.Capra, NRC S. A. McNeil, NRC W. T. Russell, NRC
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T. Foley/D. C. Trimble, NRC R. J. Kiessel, NRC W
o ENCLOSURE (1)
IE BULLETIN 85-03; ADDITIONALINFORMATION The following responds to your request for additional information regarding IE Bulletin 85-03.
i 1.
Unlisted MOVs 614, 624, 634 and 644 in discharge lines of the safety injection tank system are shown normally open (fail as is) on Drawing 60-257-E, Sheet 2, Revision 2 (Unit.1) and Drawing 62-257-E, Sheet 2, Revision 3 (Unit 2). The possible problem that the system would be inoperable if the MOVs were left closed inadvertently should be addressed. Based on the assumption of inadvertent equip-ment operations as required by Action Item a of the bulletin, revise Enclosure (1) of the response of 05-15-86 to include these valves.
RESPONSE
An inadvertent closure of the above MOVs was not assumed since this is not within Calvert Cliffs' design basis. Even so, the likelihood of these valves being left closed inadvertently is remote due to the following Technical Specification requirements during MODES 1, 2, and 3:
o Limiting Condition for Operation (LCO) 3.5.1 requires that each reactor oolant safety injection (SI) tank be OPERABLE with the isolation valve (MOVs 614, 624, 634, 644) open, o
Surveillance Requirement 4.5.1.a.2 requires verifying, every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, that each isolation valve is open, I
o Surveillance Requirement 4.5.1.c requires verifying, every 31 days, that power to the SI tank isolation valve operator is removed when system pressure is greater than 2000 psig, Whenever pressure is greater than 300 psia, an open signal is continuously applied to the Si isolation valve control circuits (by PI-103 and PI-103-1) which prevents i
inadvertent closure of these valves. Finally, a Control Room annunciator alarm will sound if a control handswitch for the SI tank isolation valve is placed in the closed position.
2.
lias water hammer due to valve closure been considered in the determination of pressure differentials? If not, please explain.
RESPONSE
We did not explicitly consider waterhammer effects in developing the maximum differential pressure criteria for the MOVs subject to IE Bulletin 85-03.
Waterhammer effects are not significant for the MOVs subject to the bulletin because they have reasonably long stroke times (eight seconds or more) and the associated subsystems contain only subcooled water. _ _ _ _ - - - _
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.o ENCLOSURE (1) l l
'IE BULLETIN 85-03; ADDITIONAL INFORMATION i
1 i
3.
The following MOVs of the HPSI System are not included in Enclosure (1) of the response of 05-15-86. However, similarly located MOVs of some other C-E plants l
are listed for inspection in accordance with bulletin ' requirements. Please revise Enclosure (1) of the response of 05-15-86 to include these MOVs, or justify their exclusion. As required by Action item (a) of the bulletin, consider the effect of inadvertent equipment operations.
(a)
Unlisted MOVs 4142 and 4143 are shown normally open (fail as is)'in suction
-lines leading from the RWST to the HPSI pumps. Refer to zones E of Drawing 60-257-E, Sheet 1, Revision 37 (Unit 1) and Drawing 62-257-E, Sheet 1, Revision 31 (Unit 2).
(b)
Unlisted MOVs 659 and 660 are shown normally open (fail as is) in mini-flow lines leading to the RWST from discharge of the HPSI pumps. Refer to zones B-10 of the drawings identified above.
l RESPONSE (3a and bh i
An inadvertent closure of the above MOVs (4142, 4143, 659, and 660) was not assumed. since this additional active failure is not within Calvert Cliffs' design basis.
MOVs '4142. and 4143 (Refueling Water Tank Outlet Isolation Valves) were not included within ' the scope of IE Bulletin 85-03 since they are not subject to a high differential pressure. The maximum differential pressure seen by these valves during opening or closing is 16 psi. Technical. Specifications 3.5.2 and 3.5.3 require that these valves be open. Also, a Control Room annunciator alarm will sound if the control handswitch for these valves is placed in the ' closed position. Therefore, a mis-operation of these valves is unlikely.
I MOVs 659 and 660 (SI Pump Mini-flow Return Isolation Valves) are required to be
'j open, with power ' removed, per Technical Specification Surveillance ' Requirements 4.5.2.a. and ' 4.5.3.1.
Power removal for each MOV is accomplished by using a separate control handswitch labeled Safety Injection Pump Recirculation Lockout, which has two positions: ON and LOCKOUT. In the ON position, the associated MOV will shut automatically when a Recirculation Actuation Signal (RAS) is generated.
In the LOCKOUT position, the MOV is locked in its open position, and does not automatically respond to a RAS. Two separate control manipulations would be required to mis-position these valves.
4.
Please expand the proposed program for Action Items (b), (c) and (d) of the bulletin to include the following details as a minimum:
.(a) commitment _to a training program for setting switches, maintaining valve operators, using test equipment and interpreting test results, (b) commitment to justify continued operation of a valve determined to be inoperable, and (c) description of a method possibly needed to extrapolate valve stem thrust measured at less than maximum differential pressure. l
Q M.7.
ENCLOSURE (1)
IE BULLETIN 85-03; ADDITIONAL INFORMATION i
EfaSPONSD As required by Action: Item (c) of Bulletin 85-03, all MOVs subject to the bulletin (submitted in Reference b).have been tested under maximum differential pressure conditions and were found to-be OPERABLE. Therefore, neither a description of a method needed to extrapolate valve parameters at less than~. maximum differential pressure, nor an assessment 'of continued operation in accordance with applicable Technical ' Specifications was necessary. Appropriate training is 'and will continue to. be provided for correctly setting switches and maintaining these Motor-Operated Valve operators.
5.
Please submit a date for planned completion of Action item (f) of the bulletin.
The specified due date is January 15, 1988.
RESPONSE
Presently, the estimated date to accomplish Action Items (b) through (d) of IE Bulletin 85-03 is by November 15, 1987. Completion of Action Item (f) will be no later than within 60 days of completion of Items (b) through (d) (January 14, 1988).'
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