Information Notice 2013-14, Potential Design Deficiency in Motor-Operated Valve Control Circuitry: Difference between revisions

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| issue date = 08/23/2013
| issue date = 08/23/2013
| title = Potential Design Deficiency in Motor-Operated Valve Control Circuitry
| title = Potential Design Deficiency in Motor-Operated Valve Control Circuitry
| author name = Dudes L A, Kokajko L E
| author name = Dudes L, Kokajko L
| author affiliation = NRC/NRO/DCIP, NRC/NRR/DPR
| author affiliation = NRC/NRO/DCIP, NRC/NRR/DPR
| addressee name =  
| addressee name =  
Line 9: Line 9:
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = Farnan M F
| contact person = Farnan M
| document report number = IN-13-014
| document report number = IN-13-014
| document type = NRC Information Notice
| document type = NRC Information Notice
| page count = 5
| page count = 5
}}
}}
{{#Wiki_filter:ML13144A834 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION OFFICE OF NEW REACTORS WASHINGTON, DC 20555-0001 August 23, 2013   NRC INFORMATION NOTICE 2013-14: POTENTIAL DESIGN DEFICIENCY IN MOTOR-OPERATED VALVE CONTROL CIRCUITRY
{{#Wiki_filter:UNITED STATES
 
NUCLEAR REGULATORY COMMISSION
 
OFFICE OF NUCLEAR REACTOR REGULATION
 
OFFICE OF NEW REACTORS
 
WASHINGTON, DC 20555-0001 August 23, 2013 NRC INFORMATION NOTICE 2013-14:                   POTENTIAL DESIGN DEFICIENCY IN
 
MOTOR-OPERATED VALVE CONTROL
 
CIRCUITRY


==ADDRESSEES==
==ADDRESSEES==
All holders of and applicants for an operating license or construction permit for a nuclear power reactor under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," except those that have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.
All holders of and applicants for an operating license or construction permit for a nuclear power
 
reactor under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic
 
Licensing of Production and Utilization Facilities, except those that have permanently ceased
 
operations and have certified that fuel has been permanently removed from the reactor vessel.
 
All holders of and applicants for a nuclear power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under


All holders of and applicants for a nuclear power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under 10 CFR Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants.
10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.


==PURPOSE==
==PURPOSE==
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert addressees to a potential control circuit design deficiency in motor-operated valves (MOVs) that could result in incorrect valve position indication with the valve in an improper position during a loss-of-coolant accident (LOCA). The NRC expects that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert
 
addressees to a potential control circuit design deficiency in motor-operated valves (MOVs) that
 
could result in incorrect valve position indication with the valve in an improper position during a
 
loss-of-coolant accident (LOCA). The NRC expects that recipients will review the information
 
for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.
 
Suggestions contained in this IN are not NRC requirements; therefore, no specific action or


Suggestions contained in this IN are not NRC requirements; therefore, no specific action or written response is required.
written response is required.


==DESCRIPTION OF CIRCUMSTANCES==
==DESCRIPTION OF CIRCUMSTANCES==
In an event report dated September 21, 2012, Exelon Generation Company notified the NRC that several MOVs at Limerick Generating Station, Units 1 and 2 could remain partially open following the initiation of an automatic isolation signal in response to a design-basis LOCA. Specifically, when power is interrupted to the actuator of certain MOVs during the shedding of loads associated with the plant's as-designed LOCA response, the MOVs may not automatically resume operation once power was restored. Additionally, the valve position indicating lights would incorrectly indicate that the valves were fully closed when the actual valve position could be as much as 15 percent open. Multiple primary containment isolation valves (PCIVs) in different systems at Limerick, Units 1 and 2, were susceptible to this condition.
In an event report dated September 21, 2012, Exelon Generation Company notified the NRC
 
that several MOVs at Limerick Generating Station, Units 1 and 2 could remain partially open
 
following the initiation of an automatic isolation signal in response to a design-basis LOCA.
 
Specifically, when power is interrupted to the actuator of certain MOVs during the shedding of
 
loads associated with the plants as-designed LOCA response, the MOVs may not automatically
 
resume operation once power was restored. Additionally, the valve position indicating lights
 
would incorrectly indicate that the valves were fully closed when the actual valve position could
 
be as much as 15 percent open. Multiple primary containment isolation valves (PCIVs) in
 
different systems at Limerick, Units 1 and 2, were susceptible to this condition.


==BACKGROUND==
==BACKGROUND==
With IN 1985-20, "Motor-Operated Valve Failures due to Hammering Effect," the NRC staff summarized a design deficiency in which certain MOVs repeatedly cycled at the end of their operating travel.  The IN described a phenomenon-known as "hammering"-during which relaxation of the gearing within the actuator of a closed MOV could lead to repeated attempts to further close the valve as long as the MOV continued to receive a valve-close demand signal.  Such a continuing signal might occur during a sealed-in accident signal (e.g., containment isolation signal) or if a plant operator held the control switch in the closed position.  MOV hammering can lead to burn-out of the MOV motor or damage to the valve and actuator.  MOV hammering can also force the valve disc into the seat such that re-opening of the valve is difficult.  Supplement 1 to IN 1985-20 describes certain types of MOVs that are susceptible to hammering.  In particular, MOVs with low gear ratios that are commonly used in applications requiring high-speed valve actuation are susceptible to hammering.  After these MOVs are closed and their torque switch contacts open, internal forces exerted through the torque switch pinion and Belleville washer assembly within the MOV actuator can cause the torque switch to reclose and resupply power to the MOV motor because the actuator gearing does not provide sufficient resistance to motion.  Consequently, MOVs that use these gear sets are characterized as "nonlocking."  Conversely, MOVs with high gear ratios can resist the internal forces on the actuator gearing; therefore, they do not allow the torque switch to re-close and re-supply power to the motor.  MOVs with high gear ratios are not susceptible to hammering and are characterized as "locking." 
With IN 1985-20, Motor-Operated Valve Failures due to Hammering Effect, the NRC staff
IN 93-98, "Motor Brakes on Valve Actuator Motors," the NRC staff summarized an MOV issue related to motor brakes installed in MOVs to minimize the inertial loads during valve closure
 
summarized a design deficiency in which certain MOVs repeatedly cycled at the end of their


after control switch trip. Motor brakes can be used to help avoid hammering in MOVs with nonlocking gear mechanisms. However, improper sizing and operation of motor brakes might not prevent hammering, and can result in problems with the performance of the MOV as discussed in IN 93-98.
operating travel. The IN described a phenomenonknown as hammeringduring which
 
ML13144A834 relaxation of the gearing within the actuator of a closed MOV could lead to repeated attempts to
 
further close the valve as long as the MOV continued to receive a valve-close demand signal.
 
Such a continuing signal might occur during a sealed-in accident signal (e.g., containment
 
isolation signal) or if a plant operator held the control switch in the closed position. MOV
 
hammering can lead to burn-out of the MOV motor or damage to the valve and actuator. MOV
 
hammering can also force the valve disc into the seat such that re-opening of the valve is
 
difficult.
 
Supplement 1 to IN 1985-20 describes certain types of MOVs that are susceptible to
 
hammering. In particular, MOVs with low gear ratios that are commonly used in applications
 
requiring high-speed valve actuation are susceptible to hammering. After these MOVs are
 
closed and their torque switch contacts open, internal forces exerted through the torque switch
 
pinion and Belleville washer assembly within the MOV actuator can cause the torque switch to
 
reclose and resupply power to the MOV motor because the actuator gearing does not provide
 
sufficient resistance to motion. Consequently, MOVs that use these gear sets are characterized
 
as nonlocking. Conversely, MOVs with high gear ratios can resist the internal forces on the
 
actuator gearing; therefore, they do not allow the torque switch to re-close and re-supply power
 
to the motor. MOVs with high gear ratios are not susceptible to hammering and are
 
characterized as locking.
 
IN 93-98, Motor Brakes on Valve Actuator Motors, the NRC staff summarized an MOV issue
 
related to motor brakes installed in MOVs to minimize the inertial loads during valve closure
 
after control switch trip. Motor brakes can be used to help avoid hammering in MOVs with
 
nonlocking gear mechanisms. However, improper sizing and operation of motor brakes might
 
not prevent hammering, and can result in problems with the performance of the MOV as
 
discussed in IN 93-98.


==DISCUSSION==
==DISCUSSION==
Certain system designs may require high-speed valve actuation and, thus, necessitate the application of MOVs with actuator gearing that is nonlocking. In these cases, licensees or vendors may have designed features within the MOV circuitry to avoid the hammering issue.   One approach to avoid MOV hammering, such as implemented at Limerick, relies on a limit switch contact to serve as an "isolation permissive" function. When the isolation permissive limit switch contact is closed, a sealed-in signal to close the valve (e.g., containment isolation) would be allowed to energize the valve close circuit. Once the valve reaches a certain position in its travel, the isolation permissive limit switch contact opens. During the continued MOV operation, the MOV circuitry is designed to allow current to flow around the open limit switch contact. After the torque switch opens, power is interrupted to the MOV motor and the valve travel stops. If the torque switch re-closes inadvertently (such as by relaxation of the actuator gearing), the MOV circuitry does not allow the current to flow around the open limit switch contact, and power is not restored to the MOV motor. The MOV circuitry can be designed to allow power to be restored to the MOV motor when valve operation is needed, such as by use of the MOV hand switch in the control room.
Certain system designs may require high-speed valve actuation and, thus, necessitate the
 
application of MOVs with actuator gearing that is nonlocking. In these cases, licensees or
 
vendors may have designed features within the MOV circuitry to avoid the hammering issue.
 
One approach to avoid MOV hammering, such as implemented at Limerick, relies on a limit
 
switch contact to serve as an isolation permissive function. When the isolation permissive limit
 
switch contact is closed, a sealed-in signal to close the valve (e.g., containment isolation) would
 
be allowed to energize the valve close circuit. Once the valve reaches a certain position in its
 
travel, the isolation permissive limit switch contact opens. During the continued MOV operation, the MOV circuitry is designed to allow current to flow around the open limit switch contact. After
 
the torque switch opens, power is interrupted to the MOV motor and the valve travel stops.
 
If the torque switch re-closes inadvertently (such as by relaxation of the actuator gearing), the
 
MOV circuitry does not allow the current to flow around the open limit switch contact, and power
 
is not restored to the MOV motor. The MOV circuitry can be designed to allow power to be
 
restored to the MOV motor when valve operation is needed, such as by use of the MOV hand
 
switch in the control room.
 
In a recent 10 CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power
 
Reactors, event notification (EN No. 48334), Exelon reported that several MOVs at Limerick, Units 1 and 2, that used an isolation permissive limit switch could potentially remain partially
 
open during the plants designed response to a LOCA. The followup 10 CFR 50.73 License
 
Event Report System, licensee event report (LER No. 05000352-2012007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12293A100)
provides further details on the MOV vulnerability that was discovered during a licensee-led
 
evaluation of electrical system voltage that would be expected to occur during a LOCA. The
 
evaluation identified that the MOVs with an isolation permissive limit switch setting were set to a
 
value of 5 percent to 15 percent of open travel. This represents a dead zone in the valve close
 
circuitry. The licensee determined that if power is interrupted to the affected valve actuators
 
after the isolation permissive limit switch contact opened, but before the valve reached its
 
closed position, the affected PCIVs could potentially remain as much as 15 percent open. This
 
condition could occur if, during the plants designed response to a LOCA, the load shed
 
sequence occurred when a valve was within the dead zone. In this case, once power was
 
sequenced back to the MOV, it would not resume motion because the isolation permissive limit
 
switch contact would be open, thus, preventing the actuation signal from reaching the MOV
 
motor. Furthermore, the valve indicating lights would indicate fully closed because the close
 
position indicating light contacts share the same limit switch rotor as the isolation permissive
 
limit switch contacts, and the valve would indicate closed when entering the set dead zone. The
 
conditions just described could leave a valve open by as much as 15 percent, although the


In a recent 10 CFR 50.72 "Immediate Notification Requirements for Operating Nuclear Power Reactors," event notification (EN No. 48334), Exelon reported that several MOVs at Limerick, Units 1 and 2, that used an isolation permissive limit switch could potentially remain partially open during the plant's designed response to a LOCA.  The followup 10 CFR 50.73 "License Event Report System," licensee event report (LER No. 05000352-2012007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12293A100) provides further details on the MOV vulnerability that was discovered during a licensee-led evaluation of electrical system voltage that would be expected to occur during a LOCA.  The evaluation identified that the MOVs with an isolation permissive limit switch setting were set to a value of 5 percent to 15 percent of open travel.  This represents a "dead zone" in the valve close circuitry.  The licensee determined that if power is interrupted to the affected valve actuators after the isolation permissive limit switch contact opened, but before the valve reached its closed position, the affected PCIVs could potentially remain as much as 15 percent open.  This condition could occur if, during the plant's designed response to a LOCA, the load shed sequence occurred when a valve was within the dead zone.  In this case, once power was sequenced back to the MOV, it would not resume motion because the isolation permissive limit switch contact would be open, thus, preventing the actuation signal from reaching the MOV motor.  Furthermore, the valve indicating lights would indicate fully closed because the close position indicating light contacts share the same limit switch rotor as the isolation permissive
valve position indication would indicate closed.


limit switch contacts, and the valve would indicate closed when entering the set dead zone.  The conditions just described could leave a valve open by as much as 15 percent, although the valve position indication would indicate closed.
Upon discovery of this condition, the licensee declared the PCIVs inoperable and implemented


Upon discovery of this condition, the licensee declared the PCIVs inoperable and implemented design changes to remove this vulnerability in MOVs at Limerick, Units 1 and 2. The licensee's corrective actions are described in the referenced LER 05000352-2012007.  This LER provides further details on this issue and the licensee's response.  The licensee is considering long-term corrective action to modify the MOV gearing for the affected MOVs to install locking gear sets to prevent potential torque switch hammering and to allow removal of the limit switch permissive circuitry.  This would allow the MOVs to restart during a LOCA power restoration sequence to fully close the valves and to provide accurate valve position indication.  This design change would also obviate the need for the affected limit switch contacts for these valves, thereby
design changes to remove this vulnerability in MOVs at Limerick, Units 1 and 2. The licensees


eliminating the "dead zone" and the root cause of the issue.   This issue and LER were reviewed by NRC inspectors and dispositioned as a licensee-identified, non-cited violation, of very low safety significance. This LER was closed in the Limerick Generating Station NRC Integrated Inspection Report 05000352/2012005 and 05000353/2012005, dated February 5, 2013; see page 35, section 4OA3.2 and page 40, section 4OA7 of the inspection report for more details (ADAMS Accession No. ML13036A364). In this licensee's particular situation, the issue was determined to be of very low safety significance. However, similar problems at other licensees might have greater safety significance. The NRC expects that recipients will review the information, links, and references provided in this IN for applicability and consider actions, as appropriate for their facilities to avoid similar problems. However, no specific action or written response to the NRC is required for this IN.
corrective actions are described in the referenced LER 05000352-2012007. This LER provides
 
further details on this issue and the licensees response. The licensee is considering long-term
 
corrective action to modify the MOV gearing for the affected MOVs to install locking gear sets to
 
prevent potential torque switch hammering and to allow removal of the limit switch permissive
 
circuitry. This would allow the MOVs to restart during a LOCA power restoration sequence to
 
fully close the valves and to provide accurate valve position indication. This design change
 
would also obviate the need for the affected limit switch contacts for these valves, thereby
 
eliminating the dead zone and the root cause of the issue.
 
This issue and LER were reviewed by NRC inspectors and dispositioned as a licensee- identified, non-cited violation, of very low safety significance. This LER was closed in the
 
Limerick Generating Station NRC Integrated Inspection Report 05000352/2012005 and
 
05000353/2012005, dated February 5, 2013; see page 35, section 4OA3.2 and page 40,
section 4OA7 of the inspection report for more details (ADAMS Accession No. ML13036A364).
 
In this licensees particular situation, the issue was determined to be of very low safety
 
significance. However, similar problems at other licensees might have greater safety
 
significance.
 
The NRC expects that recipients will review the information, links, and references provided in
 
this IN for applicability and consider actions, as appropriate for their facilities to avoid similar
 
problems. However, no specific action or written response to the NRC is required for this IN.


==CONTACT==
==CONTACT==
This information notice does not require any specific action or written response. If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate NRC project manager. /RA/     /RA/
This information notice does not require any specific action or written response. If you have any
Laura A. Dudes, Director Lawrence E. Kokajko, Director Division of Construction Inspection Division of Policy and Rulemaking   and Operational Programs Office of Nuclear Reactor Regulation Office of New Reactors
 
questions about the information in this notice, please contact the technical contact listed below
 
or the appropriate NRC project manager.
 
/RA/                                         /RA/
Laura A. Dudes, Director                     Lawrence E. Kokajko, Director
 
Division of Construction Inspection           Division of Policy and Rulemaking
 
and Operational Programs                     Office of Nuclear Reactor Regulation
 
===Office of New Reactors===


===Technical Contact:===
===Technical Contact:===
Michael Farnan, NRR 301-415-1486 E-mail:  Michael.Farnan@nrc.gov  Note:  NRC generic communications may be found on the NRC's public Web site, http://www.nrc.gov, under NRC Library/Document Collections.


==CONTACT==
===Michael Farnan, NRR===
This information notice does not require any specific action or written response. If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate NRC project manager.   /RA/     /RA/ Laura A. Dudes, Director    Lawrence E. Kokajko, Director Division of Construction Inspection       Division of Policy and Rulemaking  and Operational Programs   Office of Nuclear Reactor Regulation  Office of New Reactors
                      301-415-1486 E-mail: Michael.Farnan@nrc.gov
 
Note: NRC generic communications may be found on the NRCs public Web
 
site, http://www.nrc.gov, under NRC Library/Document Collections.
 
ML13144A834              *via email                                  TAC 1740
                                              Region-1 OFFICE    NRR/DE/EPTB      Tech Editor                      NRR/DE/EPNB        NRR/DE        NRR/DORL
 
Limerick SRI
 
NAME        MFarnan          CHsu*          EDiPaolo*          TLupold          PHiland          MEvans
 
DATE        7/ 16 /13      7/ 19 /13        7/ 25 /13        7/ 16 /13       7/ 17 /13      7/ 23 /13 NRR/DPR/PGCB   NRR/DPR/PGCB        NRO/DCIP/ D      NRR/DPR/DD      NRR/DPR/D


===Technical Contact:===
OFFICE    NRR/DPR/PGCB
Michael Farnan, NRR 301-415-1486 E-mail: Michael.Farnan@nrc.gov


Note:  NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library/Document Collections.              ADAMS Accession No.:  ML13144A834      *via email                                                  TAC 1740 OFFICE NRR/DE/EPTB Tech Editor Region-1  Limerick SRI NRR/DE/EPNB NRR/DE NRR/DORL NAME MFarnan CHsu* EDiPaolo* TLupold PHiland MEvans DATE 7/ 16 /13 7/ 19  /13 7/ 25 /13 7/ 16 /13 7/ 17 /13 7/ 23 /13 OFFICE NRR/DPR/PGCB NRR/DPR/PGCB NRR/DPR/PGCB NRO/DCIP/ D NRR/DPR/DD NRR/DPR/D NAME CHawes MKing D Pelton LDudes SBahadur LKokajko DATE 7/ 25 /13 7/ 25 /13 8/  15  /13 8/  19  /13 8/  22  /13 8/  23  /13 OFFICIAL RECORD COPY
NAME         CHawes           MKing           D Pelton           LDudes         SBahadur         LKokajko


}}
DATE        7/ 25 /13      7/ 25 /13        8/ 15 /13        8/ 19 /13        8/ 22 /13      8/ 23 /13}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 18:38, 4 November 2019

Potential Design Deficiency in Motor-Operated Valve Control Circuitry
ML13144A834
Person / Time
Issue date: 08/23/2013
From: Laura Dudes, Kokajko L
Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking
To:
Farnan M
References
IN-13-014
Download: ML13144A834 (5)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

WASHINGTON, DC 20555-0001 August 23, 2013 NRC INFORMATION NOTICE 2013-14: POTENTIAL DESIGN DEFICIENCY IN

MOTOR-OPERATED VALVE CONTROL

CIRCUITRY

ADDRESSEES

All holders of and applicants for an operating license or construction permit for a nuclear power

reactor under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic

Licensing of Production and Utilization Facilities, except those that have permanently ceased

operations and have certified that fuel has been permanently removed from the reactor vessel.

All holders of and applicants for a nuclear power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under

10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert

addressees to a potential control circuit design deficiency in motor-operated valves (MOVs) that

could result in incorrect valve position indication with the valve in an improper position during a

loss-of-coolant accident (LOCA). The NRC expects that recipients will review the information

for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

Suggestions contained in this IN are not NRC requirements; therefore, no specific action or

written response is required.

DESCRIPTION OF CIRCUMSTANCES

In an event report dated September 21, 2012, Exelon Generation Company notified the NRC

that several MOVs at Limerick Generating Station, Units 1 and 2 could remain partially open

following the initiation of an automatic isolation signal in response to a design-basis LOCA.

Specifically, when power is interrupted to the actuator of certain MOVs during the shedding of

loads associated with the plants as-designed LOCA response, the MOVs may not automatically

resume operation once power was restored. Additionally, the valve position indicating lights

would incorrectly indicate that the valves were fully closed when the actual valve position could

be as much as 15 percent open. Multiple primary containment isolation valves (PCIVs) in

different systems at Limerick, Units 1 and 2, were susceptible to this condition.

BACKGROUND

With IN 1985-20, Motor-Operated Valve Failures due to Hammering Effect, the NRC staff

summarized a design deficiency in which certain MOVs repeatedly cycled at the end of their

operating travel. The IN described a phenomenonknown as hammeringduring which

ML13144A834 relaxation of the gearing within the actuator of a closed MOV could lead to repeated attempts to

further close the valve as long as the MOV continued to receive a valve-close demand signal.

Such a continuing signal might occur during a sealed-in accident signal (e.g., containment

isolation signal) or if a plant operator held the control switch in the closed position. MOV

hammering can lead to burn-out of the MOV motor or damage to the valve and actuator. MOV

hammering can also force the valve disc into the seat such that re-opening of the valve is

difficult.

Supplement 1 to IN 1985-20 describes certain types of MOVs that are susceptible to

hammering. In particular, MOVs with low gear ratios that are commonly used in applications

requiring high-speed valve actuation are susceptible to hammering. After these MOVs are

closed and their torque switch contacts open, internal forces exerted through the torque switch

pinion and Belleville washer assembly within the MOV actuator can cause the torque switch to

reclose and resupply power to the MOV motor because the actuator gearing does not provide

sufficient resistance to motion. Consequently, MOVs that use these gear sets are characterized

as nonlocking. Conversely, MOVs with high gear ratios can resist the internal forces on the

actuator gearing; therefore, they do not allow the torque switch to re-close and re-supply power

to the motor. MOVs with high gear ratios are not susceptible to hammering and are

characterized as locking.

IN 93-98, Motor Brakes on Valve Actuator Motors, the NRC staff summarized an MOV issue

related to motor brakes installed in MOVs to minimize the inertial loads during valve closure

after control switch trip. Motor brakes can be used to help avoid hammering in MOVs with

nonlocking gear mechanisms. However, improper sizing and operation of motor brakes might

not prevent hammering, and can result in problems with the performance of the MOV as

discussed in IN 93-98.

DISCUSSION

Certain system designs may require high-speed valve actuation and, thus, necessitate the

application of MOVs with actuator gearing that is nonlocking. In these cases, licensees or

vendors may have designed features within the MOV circuitry to avoid the hammering issue.

One approach to avoid MOV hammering, such as implemented at Limerick, relies on a limit

switch contact to serve as an isolation permissive function. When the isolation permissive limit

switch contact is closed, a sealed-in signal to close the valve (e.g., containment isolation) would

be allowed to energize the valve close circuit. Once the valve reaches a certain position in its

travel, the isolation permissive limit switch contact opens. During the continued MOV operation, the MOV circuitry is designed to allow current to flow around the open limit switch contact. After

the torque switch opens, power is interrupted to the MOV motor and the valve travel stops.

If the torque switch re-closes inadvertently (such as by relaxation of the actuator gearing), the

MOV circuitry does not allow the current to flow around the open limit switch contact, and power

is not restored to the MOV motor. The MOV circuitry can be designed to allow power to be

restored to the MOV motor when valve operation is needed, such as by use of the MOV hand

switch in the control room.

In a recent 10 CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power

Reactors, event notification (EN No. 48334), Exelon reported that several MOVs at Limerick, Units 1 and 2, that used an isolation permissive limit switch could potentially remain partially

open during the plants designed response to a LOCA. The followup 10 CFR 50.73 License

Event Report System, licensee event report (LER No. 05000352-2012007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12293A100)

provides further details on the MOV vulnerability that was discovered during a licensee-led

evaluation of electrical system voltage that would be expected to occur during a LOCA. The

evaluation identified that the MOVs with an isolation permissive limit switch setting were set to a

value of 5 percent to 15 percent of open travel. This represents a dead zone in the valve close

circuitry. The licensee determined that if power is interrupted to the affected valve actuators

after the isolation permissive limit switch contact opened, but before the valve reached its

closed position, the affected PCIVs could potentially remain as much as 15 percent open. This

condition could occur if, during the plants designed response to a LOCA, the load shed

sequence occurred when a valve was within the dead zone. In this case, once power was

sequenced back to the MOV, it would not resume motion because the isolation permissive limit

switch contact would be open, thus, preventing the actuation signal from reaching the MOV

motor. Furthermore, the valve indicating lights would indicate fully closed because the close

position indicating light contacts share the same limit switch rotor as the isolation permissive

limit switch contacts, and the valve would indicate closed when entering the set dead zone. The

conditions just described could leave a valve open by as much as 15 percent, although the

valve position indication would indicate closed.

Upon discovery of this condition, the licensee declared the PCIVs inoperable and implemented

design changes to remove this vulnerability in MOVs at Limerick, Units 1 and 2. The licensees

corrective actions are described in the referenced LER 05000352-2012007. This LER provides

further details on this issue and the licensees response. The licensee is considering long-term

corrective action to modify the MOV gearing for the affected MOVs to install locking gear sets to

prevent potential torque switch hammering and to allow removal of the limit switch permissive

circuitry. This would allow the MOVs to restart during a LOCA power restoration sequence to

fully close the valves and to provide accurate valve position indication. This design change

would also obviate the need for the affected limit switch contacts for these valves, thereby

eliminating the dead zone and the root cause of the issue.

This issue and LER were reviewed by NRC inspectors and dispositioned as a licensee- identified, non-cited violation, of very low safety significance. This LER was closed in the

Limerick Generating Station NRC Integrated Inspection Report 05000352/2012005 and

05000353/2012005, dated February 5, 2013; see page 35, section 4OA3.2 and page 40,

section 4OA7 of the inspection report for more details (ADAMS Accession No. ML13036A364).

In this licensees particular situation, the issue was determined to be of very low safety

significance. However, similar problems at other licensees might have greater safety

significance.

The NRC expects that recipients will review the information, links, and references provided in

this IN for applicability and consider actions, as appropriate for their facilities to avoid similar

problems. However, no specific action or written response to the NRC is required for this IN.

CONTACT

This information notice does not require any specific action or written response. If you have any

questions about the information in this notice, please contact the technical contact listed below

or the appropriate NRC project manager.

/RA/ /RA/

Laura A. Dudes, Director Lawrence E. Kokajko, Director

Division of Construction Inspection Division of Policy and Rulemaking

and Operational Programs Office of Nuclear Reactor Regulation

Office of New Reactors

Technical Contact:

Michael Farnan, NRR

301-415-1486 E-mail: Michael.Farnan@nrc.gov

Note: NRC generic communications may be found on the NRCs public Web

site, http://www.nrc.gov, under NRC Library/Document Collections.

ML13144A834 *via email TAC 1740

Region-1 OFFICE NRR/DE/EPTB Tech Editor NRR/DE/EPNB NRR/DE NRR/DORL

Limerick SRI

NAME MFarnan CHsu* EDiPaolo* TLupold PHiland MEvans

DATE 7/ 16 /13 7/ 19 /13 7/ 25 /13 7/ 16 /13 7/ 17 /13 7/ 23 /13 NRR/DPR/PGCB NRR/DPR/PGCB NRO/DCIP/ D NRR/DPR/DD NRR/DPR/D

OFFICE NRR/DPR/PGCB

NAME CHawes MKing D Pelton LDudes SBahadur LKokajko

DATE 7/ 25 /13 7/ 25 /13 8/ 15 /13 8/ 19 /13 8/ 22 /13 8/ 23 /13