TXX-4901, Forwards Response to IE Bulletin 85-003, Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings, Per 860430 Request for 2 Month Extension to Response Deadline

Forwards Response to IE Bulletin 85-003, Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings, Per 860430 Request for 2 Month Extension to Response Deadline

ML20203D971
Person / Time
Site:	Comanche Peak
Issue date:	07/14/1986
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
IEB-85-003, IEB-85-3, TXX-4901, NUDOCS 8607240029
Download: ML20203D971 (18)

Text

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Log # TXX-4901 File # 10115 IEB 85-03 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER. 400 NORTH OLIVE STREET. I.Is. at. DALLAS, TEXAN 75201 July 14, 1986

.E?ffA.*3fE*A Mr. Robert D. Martin

/

Y. /S> h ly Regional Administrator, Region IV V. S. Nuclear Regulatory Commission g/

611 Ryan Plaza Drive, Suite 1000 77 Arlington, TX 76011 g

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

/

DOCKET NOS. 50-445 AND 50-446 IE BULLETIN 85-03 MOTOR OPERATED VALVE SWITCH SETTINGS

REFERENCE:

(1). IE BULLETIN NO. 85-03: MOTOR-0PERATED VALVE COMMON MODE FAILURES DURING PLANT TRANSIENTS DUE TO IMPROPER SWITCH SETTINGS dated November 15, 1986.

(2). TUGCo letter (W. G. Counsil to R. D. Martin) of April 30, 1986, Log No. TXX-4781.

Dear Mr. Martin:

Reference (1), item (e), required a response from all holders of operating licenses and construction permits by May 16, 1986.

Reference (2) requested a two month extension to this deadline for Texas Utilities Generating Company (TUGCo).

Attached is the TUGCo response to Reference (1), item (e).

Very truly yours, W. G. Counsil 8607240029 860714 PDR ADOCK 05000445 By

( 1_

G PDR n Beck Vice President THE STATE OF TEXAS :

COUNTY OF DALLAS There personally appeared before me J. W. Beck, who, being duly sworn, did state that he is Vice President of Texas Utilities Generating Company, a division of Texas Utilities Electric Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to IE Bulletin 85-03 that he is familiar with the content thereof; and that the matters of fact set forth therein are true and correct to the best of his knowledge, information, and belief.

A mvision or rexas vriuries er.ecruic courasr wm

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Notary Public d NO /

My commission Expires:

? f S$

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BSD/arh Attachment c-U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.

20502 (40 copies)

Mr. Vince S. Noonan I

i

b l

Atta.chment to TXX-4901 e

g COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 RESPONSE TO NRC IE BULLETIN 85-03 i

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.

CPSES Response The purpose of this response is to provide maximum fluid differential pressure during valve opening and closing for both normal and abnormal events to the extent that these valve operations and events are included in the existing, approved design basis.

It should be noted that this response is applicable to both Unit I and Unit 2.

Unit 2 valve numbers are the same as Unit 1, except for the prefix.

Systems included in the review are:

1. Auxiliary Feedwater System

2. Main Steam, Reheat and Steam Dump System

3. Emergency Core Cooling System (CVCS and High Head Safety Injection portions only)

A brief description of each system and methodology used in selection of Motor-Operated Valves (MOVs) in each particular system it provided as follows:

AUXILIARY FEEDWATER SYSTEM (AF)

The Auxiliary Feedwater System is designed to provide a supply of high pressure feedwater to the secondary side of the steam generators for reactor coolant heat removal during periods when normal feedwater is unavailable.

In general, Auxiliary Feedwater System MOVs function to establish a flowpath from the safety grade water source (or its backup) to the steam generators.

(See Figure 1).

There are two general locations for motor-operated valves within the auxiliary feedwater system.

These are:

a) Suction of AFW pumps from service water system.

b) Discharge of AFW pumps to steam generators.

For motor-operated valves selected, all modes of operation were evaluated including Feedwater Line Break Accident (See Main Steam, Reheat and Steam Dump i

System). This was done to ensure that for this given set of MOVs, the most severe case operating delta-P was determined.

l l

j e

1 For motor-operated valves in the pump suction the maximum open and close o

delta-Ps are determined by condensate storage tank static elevation head or by service water system design pressure.

For motor-operated valves in the pump discharge, the maximum open and close delta-P's are based on the auxiliary I

feed *ater pump (turbine driven) discharge head at minimum flow rate with turbines operating at rated speed.

MAIN STEAM. REHEAT AND STEAM DUMP SYSTEM (MS)

This evaluation considered the steam generator blowdown portion of main steam system only.

Each blowdown line is provided with a motor-operated valve to assure that during a feedwater line break accident sufficient water is being fed into the intact steam generator from the auxiliary feedwater system (See Figure 2). This valve is normally open and is designed to fail-as-is. The maximum delta-P expected during the closing of the valve is based on steam generator safety valve setpoint plus accumulation.

EMERGENCY CORE COOLING SYSTEM (ECCSi The primary function of the ECCS following a loss of coolant accident is to remove the fission product and decay heat from the reactor core so that fuel rod damage is prevented.

The emergency core cooling following a LOCA is divided into three phases:

1) i short term core cooling or cold leg injection phase, 2) long term core cooling / cold leg recirculation phase, and 3) long term core cooling / hot leg recirculation phase. This evaluation considered high pressure injection portions of ECCS which are defined below:

1. Those portions of the safety injection system not including the accumulator injection system or residual heat removal system (RHR) i which includes portions of the CVCS and the high head safety

]

injection (See Figure 3A, 3B, and 3C).

2. Those portions of the above defined as High Pressure Injection (HPI) systems necessary to establish a flowpath(s) from the refueling water 1

l storage tank (RWST) to the reactor coolant system (RCS).

1 i

3. Only those portions of the HPI (as defined in I and 2 above) required during the safety injection phase, not including the manual / partial l

auto transfer to recirculation from the containment sump after RWST empties. Therefore, recirculation modes of operation (long term cold leg recirculation and hot leg circulation) are not included in the 1

definition of HPI since these modes of operation require the l

functioning of the RHR system.

}

The HPI motor-operated valves were selected based on their required function in establishing the high pressure injection flowpath.

For the valves selected, i

all modes of operation were evaluated including recirculation modes. This was i

done to ensure that for the given set of MOVs, the worst case operating delta-P was determined.

Table 1 lists all motor-cperated valves selected for the scope of item (a) of IEB-85-03. The table provides both the design delta-Ps and maximum operating l

delta-Ps. Also included is the justification for each maximum operating delta-P.

l. --- - - - - - - - - -

The maximum cperating dalta-P represents the maximum pressure producing capability of the system operating moties including single failures and inadvertent equipment operations, hse maximum operating delta-Ps are less

, than or equal to that specified in the MOV specifications.

It is important to note that since the maximum operating delta-Ps are selected based on very conservative assumptions, it may be impossible to achieve these delta-Ps during testing of these valves using installed equipment.

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

CPSES Response A program for selecting correct valve switch settings consisting of the following will be initiated:

1. CPSES has relied upon valve and motor-operator manufacturers to specify torque switch settings based on their calculated valve actuating force. These vendor recommended switch settings will be tabulated for review and evaluated against values obtained from differential pressure testing.

Final (as left) torque switch settings will be determined by testing described in item (c).

2. Position and torque bypass limit switch logic and switch development will be reviewed and revised (if required) using the design bases.

3. Thermal overloads for all c;::: 1E M0V's are wired for " Alarm only" in response to NRC Regulatory Guide 1.106.

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 l

maximum differential pressure determined in item (a) above with tim 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.

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 differential pressure can not be performed.

CPSES Response To the extent practical, maximum operating differential pressure testing will be conducted on at least one valve in each group of similar valves.

In situations where testing at maximum operating differential pressure is not practical a lower test differential pressure may be used.

In some cases test data obtained from similar valves in systems other than those in Table 1 may be

used. CPSES will test at least one valve from each group at maximum operating differential pressure (or as near as practical) and monitor the operator parameters using valvo analysis test equipment.

Following evaluation of data from the valve analysis test equipment, adjustments and retesting of the valve

' will'be performed as required. The same valve will be retested at static system test conditions and the same actuator parameters measured.

Subsequently, the remaining valves in each group of similar valves will be tested at static system test conditions while monitoring the operator parameters. Analysis of the monitored operating parameters provided by the Valve Analysis and Test System will dictate required switch adjustments for the remaining valves of the valve group. This approach will assure all similar valves have similar operating parameters and therefore provide a high degree of confidence the valves will operate properly at the differential pressure conditions. Actual settings required to achieve the appropriate operating parameters will be compared to vendor specified settings to identify discrepancies that require additional evaluation.

(Static system test conditions will be chosen to allow testing at a plant condition that can be readily duplicated without major disruption to operation).

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.

CPSES Response Comanche Peak has a preventative maintenance program in place which requires an operability test of the valve and associated actuator on a periodic basis.

This program ensures that this equipment is configured in accordance with design documents and operationally tested, in accordance with maintenance procedures.

A motor operated valve setpoint manual, which will incorporate the results from item (c), will be established to document test differential pressures, control torque switch settings, control torque switch bypass settings, and control limit switches.

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.

CPSES Response Refer to CPSES response to item (a) for the results of the design basis review.

Refer to CPSES response to items (b) through (d) for the program to accomplish these items.

For linit 1, items (b) through (d) will be completed prior to Fuel Load.

For Unit 2, upon completion of items (a) and (b), Start-up will incorporate the testing requirements of item (c) into the pre-operational test program. Testing will be conducted in accordance with the Unit 2 Start-up schedule. For Unit 2, item (d) will be accomplished under the same program as Unit 1..

Item (f)

Provide a written report on completion of the above program. This report should provide 1) a verification of completion of the requested program, 2) a

' summ'ary 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. The NRC staff intends to use this data to assist in the resolution of Generic Issue II.E.6.1.

This report shall be submitted to the NRC within 60 days of completion of the program. Table 2 should be expanded, if appropriate, to include a summary of all data required to evaluate the response to this bulletin.

CPSES Response A written report will be submitted within sixty (60) days after completion of the program for items (b) through (d).

+

Pcae No.

1 03/30/86 19 TABLE 1 CPSES UNIT 1 MOV FROGRAM (IEB 65-03)

~

ANS DESIGN DESIGN MAX OF MAX OP JUSTIFICATION F(E **

RECORD VALVE OPERATOR DRAWING /

SAFETY DELTA P DELTA P DELTA P DELTA P MAXI 9EBt OPERATING DELTA P NO NO.

TYPE SYSTD4 SIZE CLASS FUNCTION (PSID) OPEN (PSID) C14SE (PSID) OPEN (PSID) CLOSE OPEN CIAME

=-

1 1HV-2491A LIMITORQUE 2323-M1-206/AF 4

2 AFW CONT. ISO.

2250 2250 1512 1512 1

2 I

(IAF-079)

SMB-O 2 1HV-2491B LIMITORQUE 2323-M1-206/AF 4

2 AFW CONT. ISO.

2250 2250 1512 1512 1

2 (1AF-076)

SMB-O r

3 1HV-2492A LIMITORQUE 2323-M1-206/AF 4

2 AEW CONT. ISO.

2250 2250 1512 1512 1

2 (IAF-087)

SMB-O 4 1HV-2492B LIMITORQUE 2323-M1-206/AF 4

2 AFW CONT ISO.

2250 2250 1512 1512 1

2 (1AF-084)

SMB-O 5 1HV-2493A LIMITORQUE 2323-M1-206/AF 4

2 AFW CONT. ISO.

2250 2250 1512 1512 1

2 (IAF-094)

SMB-O 6 1HV-24938 LIMITORQUE 2323-M1-206/AF 4

2 APW CONT. ISO.

2250 2250 1512 1512 1

2 (IAF-099)

SMB-O 7 1HV-2494A LIMITORQUE 2323-M1-206/AF 4

2 AIW CONT. ISO.

2250 2250 1512 1512 1

2 (1AF-102)

SMB-O 8 1HV-2494B LIMITORQUE 2323-M1-206/AF 4

2 AfW CONT. ISO.

2250 2250 1512 1512 1

2 (1AF-107)

SMB-O 9 1HV-2480 LIMITORQUE TNE-M1-0206-01/AF 6

3 AfW PUMP (MOTOR 150 150 150 150 5

5 (IAF-019)

SB-OO DRIVEN) SUCT. ISO.

10 1HV-2481 LIMITORQUE TNE-M1-0206-01/AF 6

3 AIW PUMP (MOTOR 150 150 150 150 5

5 (1AF-022)

SB-OO DRIVEN) SUCT. ISO.

-s

P:se No.

2 06/30/86 TABLE 1 CPSES UNIT 1 MOV PROGRAM (IEB 85-03)

ANS DESIGN DESIGN MAX OF MAX OF JUSTIFICATION P M **

RECORD VALVE OPERATOR DRAWING /

SAFETY DELTA P DELTA P DELTA P DELTA P MAXIDESI OPERATING DELTA P NO NO.

TYPE SYSTEM SIZE CLASS FUNCTION (PSID) OPEN (PSID) CLOSE (PSID) OPEN (PSID) C1DSE OPEp.

CIAME

---

------------..=

11 1HV-2482 LIMITCAQUE TNE-M1-0206-01/AF 8

3 A W PUMP (TURBINE 150 150 150 150 5

5 I

(IAF-030)

SB-OO DRIVEN) SUCT. ISO.

1 12 1HV-2400A LIMITORQUE TNE-M1-0202-02/MS 3

2 ST. GEN. BLOW DN 1225 1225 0

1225 4

3 (IMS-149)

SMB-OO ISO.

13 1HV-2397A LIMITORQUE TNE-M1-0202-02/MS 3

2 ST. GEN. BLOW DN 1225 1225 0

1225 4

3 (IMS-151)

SMB-OO ISO.

14 1HV-2398A LIMITORQUE TNE-M1-0202-02/te 3

2 ST. GEN. BLOW DN 1225 1225 0

1225 4

3 4

(IMS-153)

SMB-OO ISO.

15 13V-2399A LIMITORQUE TNE-M1-0202-02/MS 3

2 ST. GEN. BLOW DN 1225 1225 0

1225 4

3 (IMS-155)

SMB-OO ISO.

16 111V-4395 LIMITORQUE 2323-M1-0234/SW 10 3

SW TO AW PUMP 150 150 150 150 5

5 SMB-OOO SUCTION ISOLATION 9

17 1HV-4396 LIMITORQUE 2323-M1-0234/SW 10 3

SW TO AFW PUMP 150 150 150 150 5

5 SMB-OOO SUCTION ISOLATION 18 1-8806 LIMITORQUE 2323-M1-263/SI 8

2 SI PUMP SUCTION FROM 200 200 50 200 6

7 SB-OO RWST j

19 1-8923A LIMITORQUE 2323-M1-263/SI 6

2 SI PUMP SUCTION FROM 200 200 50 200 6

8 SB-OO RWST 20 1-8923B LIMITORQUE 2323-M1-263/SI 6

2 SI PUMP SUCTION FROM 200 200 50 200 6

8 S8-00 RWST t

Page No.

3 06/3e/36 TABLE 1 CPSES UNIT 1 MOV PROGRAM (IEB 85-03)

AMS DESIGN DESIGN MAX OF MAX OP JUSTIFICATION MR **

RECORD VALVE OPERATOR DRAWING /

SAFETY DELTA P DELTA P DELTA P DELTA P MAXDest OPERATING BELTA P NO NO.

TYPE SYSTEM SIZE CLASS FUNCTION (PSID) OPEN (PSID) CIDSE (PSID) OPEN (PSID) CIASE OPEN CMIEE

.................=

4 1

21 1-8835 LIMITORQUE 2323-M1-263/SI 4

2 SI PUMP DISCHARGE 2750 0

1500 0

0 10 SBD-OO ISOLATION a

22 1-8813 LIMITORQUE 2323-M1-263/SI 2

2 SI PUMP MINI FLOW 2750 2750 1500 1500 12 11 SMB-OO 23 1-8814A LIMITORQUE 2323-M1-263/SI 1 1/2 2

SI PUMP MINI FLOW 2750 2750 1500 1500 12 11 SMd-OO 24 1-8814B LIMITORQUE 2323-M1-263/SI 1 1/2 2

SI PtEP MINI FLOW 2750 2750 1500 1500 12 11 SMS-OO 25 1-8105 LIMITORQUE TNE-M1-255-01/CVCS 3

2 CHG. PM DISCH. ISO.

2750 2750 2750 2750 13 13 S8-00 (CJCS NORMAL DISC.)

26 1-8106 LIMITORQUE TNE-M1-255-01/CVCS 3

2 CBG.1H DISCH. ISO.

2750 2750 2750 2750 13 13 SB-OO (CVCS NORMAL DISC.)

27 1-8801A lit!ITORQUE 2323-M1-261/SI 4

2 CENTRIFUGAL CHARGING 2750 0

2750 0

14 10 SBD-OO PUMP DISCHARGE ISO.

2d 1-8801B LIMITORQUE 2323-M1-261/SI 4

2 CENTRIFUGAL CHARGING 2750 0

2750 0

14 10 SBD-OO PUMP DISCHARGE ISO.

i 29 1-8821A LIMITORQUE 2323-M1-263/SI 4

2 SI PUMP CROSS CONN.

1500 1500 1500 1500 15 18 SB-OO CONT. ISO.

30 1-8821B LIMITORQUE 2323-M1-263/SI 4

2 SI PUMP CROSS CONN.

1500 1500 1500 1500 15 14 SB-OO CONT. ISO.

e Prge No.

4 06/30/86 TABLE 1 CPSES UNIT 1 MOV PROGRAM (IEB 85-03)

ANS DESIGN DESIGN MAX OP MAX OP JUSTIFICATION FtR **

RECORD VALVE OPERATOR DRAWING /

SAFETY DELTA P DELTA P DELTA P DELTA P MAXI 9EM OPERATING IELTA P NO NO.

TYPE SYSTEM SIZE CLASS FUNCTION (PSID) OPEN (PSID) CLOSE (PSID) OPEN (PSID) CIASE OPEN CIAEE

... =-

-==..

)

l 31 1-8110 LIMITORQUE 2323-M1-255/CVCS 2

2 CVCS PUMP MINI FLOW 2750 2750 2750 2750 18 17 SMB-00 32 1-8111 LIMITORQUE 2323-M1-255/CVCS 2

2 CVCS PUMP MINI FLOW 2750 2750 2750 2750 18 17 SMB-OO 33 1-LCV-112B LIMITORQUE 2323-M1-255/CVCS 4

2 VCT DISCHARGE 200 100 100 100 19 10 SB-CO ISOLATION 34 1-LCV-112C LIMITORQUE 2323-M1-255/CVCS 4

2 VCT DISCHARGE 200 100 100 100 19 19 SB-00 ISOLATION l

l 35 1-LCV-112D LIMITORQUE 2323-M1-255-02/CVCS 8

2 RWST DISCHARGE 200 200 50 200 20 21 SB-OO ISOLATION 36 1-LCV-112E LIMITORQUE 2323-M1-255-02/CVCS 8

2 RWST DISCHARGE 200 200 50 200 20 21 SB-OO ISOLATION 1

s 9

1

i' JUSTIFICATION FOR VALVE DIFFERENTIAL PRESSURE SPECIFIED IN TABLE 1

1. This valve is normally open and fail-as-is. The valve must be able to open against the auxiliary feedwater pump (turbine driven) discharge head (See Figure 1).

2. This valve is closed for stroke testing and/or Steam Generator isolation for secondary pipe breaks (See Figure 1). The valve must be able to close against the Auxiliary Feedwater Pump discharge head.

3. This valve is normally open and fail-as-is. The function of this valve is to isolate the steam generator blowdown line in the event of secondary i

line break. The valve must be able to close against staam generator lowest safety valve setpoint pressure plus accumulation (See Figure 2).

4. This valve is normally open and should open for stroke testing assuming that the steam blowdown system is operating. However, there is no safety requirement to open with delta-P.

5. These valves are normally closed and fail-as-is. These valves provide an alternate water supply to the auxiliary feedwater system in the event of J

depletion of the normal water supply. The maximum open and close differential pressure across the valve.is based on the service water system design pressure.

6. This valve is normally open, and is closed only for stroke testing and/or pump isolation for maintenance. The valve must be able to open against a full Refueling Water Storage Tank (RWST) static head of water.

For Comanche Peak, this is approximately 50 psig.

7. This valve must be able to close to isolate the RWST from the discharge of the RHR pumps during the recirculation mode of operation, as a precautionary measure in the event of back leakage through check valve 1-8926.

For this scenario, the delta-P across 1-8806 could be as high as the RHR pump discharge head, approximately 200 psig.

8. This valve must be capable of isolating-(closing) one high head safety injection pump, given c passive failure in that train of the ECCS.

For i

this scenario, the delta-P across 1-8923A, B could be as high as the RHR l

pump discharge head, approximately 200 psig.

9. Pump testing on miniflow circuit, delta-P is determined by the miniflow head of high head safety injection pump, approximately 1500 psig.

10. This valve is only closed when pump is not operating; no flow - no delta-P.

4 i

11. The valves must be closed to isolate miniflow so that high pressure injection switchover to recirculation may proceed.

In the most serious case, the delta-P will be equal to the pump developed head on the miniflow, approximately 1500 psig, i

l

12. Similar to 11, except that the valve must be able to open during miniflow testing of the high head safety injection pump.

~

~

JUSTIFICATION FOR VALVE DIFFERENTIAL PRESSURE SPECIFIED IN TABLE 1 (Continued)

13. These valves must be able to isolate the RCS from the CVCS, with a maximum possible delta-P equal to the shutoff head of the centrifugal. charging pumps.

14. Given a miniflow test of the centrifugal charging pumps, the cold leg injection isolation valves must be able to open with a delta-P approximately equal to the charging pump shutoff head.

15. The valve must be able to open to allow train separation during the recirculation phase or the ECCS operation. The delta-P opening is the same as the closing.(See number 16).

16. Must be able to open to allow realignment of ECCS to recirculation mode and for ECCS train separation. Delta-P could be as high as 1500 psig (approximately equal to a miniflow head of high head safety injection pump).

17. Valves must close to ensure adequate high pressure injection flow (on "S" signal) against miniflow, delta-P = 2750 psig.

18. Similar to 17, except that the valve must be able to open during miniflow testing.

19. These valves must close on "S" signal; the maximum delta-P across the valve is defined by the volume control tank at its design pressure (relief valve setpoint) of 75 psig plus elevation head of the VCT above the valves.

This is estimated to be equal to 100 psig.

20. This valve is normally closed and must be able to open against a full RWST static head of water.

21. This valve must be able to close to isolate the RWST from the discharge of the RHR pumps during the recirculation mode of operation, as a l

precautionary measure in the event of back leakage through check valve.

For this scenario the delta-P across this valve could be as high as RHR pump discharge head, approximately 200 psig.

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