ML20155K102

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Forwards Description of Committed Actions,Established Parameters to Be Monitored & Appropriate Action Statements If Predetermined Threshold Values Exceeded,Per 871109 Committments
ML20155K102
Person / Time
Site: Perry, 05000000
Issue date: 11/13/1987
From: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20155K026 List:
References
FOIA-88-165 PY-CEI-OIE-0289, PY-CEI-OIE-289, NUDOCS 8806210105
Download: ML20155K102 (10)
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P.O. BOX 97 e PERRY, OHIO 44081 e TELEPHONE (216) 269 3737 e ADDRESS.1o CENTER ROAD Serving The Best Location in the Nation Murray R. Edelman PERRY NUCLEAR POWER PLANT M YK2 PM3 DENT

pIORity pegryr:g Novembe r 13, 1987 Nb'.d

' ir i PY-CEI/01E-0289 L c D

[ E'2 Mr. A. Bert Davis c2 q -

Regional Administrator, Region III "

U.S. Nuclear Regulatory Commission 799 Roosevelt Road I Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket No. 50-440 Updated Information to le tter PY-CEI/01E-0288 L Dear Mr. Davis.

This letter provides additional information regarding the commitments made in our letter, PY-CEI/01E-0288 L, dated November 9,1987. Based upon the discussions held with members of you staf f on November 10, 1987, enclosed is a description of committed actions, established parameters to be monitored and appropriate action statements if predetermined threshold values are exceeded.

Following receipt of your concurrence, we plan to restart the plant to complete the remaining tests in the Startup Test Program. If you have any questions, please feel free to call.

Very truly yours, .

Murray R. Edelman Senior Vice President Nuclear Group MRE: cab Enclosure ec: K. Connaughton T. Colburn Document Control Desk NOV 18 B87 8806210105 880613 PDR FOIA PDR MAXWELL 88-165 gv -

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Enclosure

. Page 1 of 6 The following evaluations and actions have been or vill be completed prior to plant startups i l

1. As previously stated in FY-CEI/0IE-0288 L, for the dual (fast '

closure) solenoids, the total air pack has been replaced for the i 1821-Fv28D valve, and the whole dual solenoid has been replaced on  !

the 1821-F022D valve. Additionally, the 1821-F022A solenoid valve i has been replaced due to a frayed wire at'the termination. No other {

solenoids showed significant degradation or required replacement. i All of the other MSIV dual solenoids have been rebuilt.

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2. As previously stated in FY-CEI/0IE-0288 L, the single (slow closure) solenoid was replaced on the 1821-F028D valve since the whole air pack was replaced. Additionally, the 1821-F0288 solenoid. valve has l been replaced due to a frayed wire at the termination. Based on the '

inspection results above, no other replacements were necessary.

3. As previously stated in FY-CEI/0IE-0288 L, an evaluation has been 1

i performed of other ASCO solenoid Class 1E harsh environment l applications in the plant, including those which may have been i subject to the steam leak environment which affected the MSIV solenoids. The review identified two normally deenergized solenoids which were subject to the same conditions as the MSIV solenoids.

Since the solenoids are in a normally deenergized state, no further l

action was considered necessary. The two solenoids were 1B21-F0451 (solenoid for valve IB21-F0069) and 1M14-F0063A (solenoid for valve 1M14-F0060A). Vork history review of all other applications has ,

shown no solenoid failures, indicating the ASCO solenoid degradation .l appears to be limited to the MSIV solenoid valves. Further reviews  !

are described in item 4 of the post startup actions.

The IM14-F0060A valve is a normally closed valve and has no safety function to mitigate an accident. It is associated with a Dryvell

Furge system damper that is closed during normal operation with a water seal in place for shielding purposes. The 1821-F0069 valve is -

a one inch before seat drain valve that is closed at greater than 50% main steam flov (at which time the solenoid is deenergized).

The valve was recently cycled on November 7, 1987 with no deficiencies identified. In addition, this valve vill be cycled again during this plant startup.

4. An evaluation has been performed of other equipment in the vicinity of the 1821-F022D, 1821-F028D, and 1B21-F028B valves, to assess any impact that the steam leaks may have had on other components. This evaluation revealed that there were six valve actuators.in the steam ,

tunnel and two in the dryvell that were in close proximity to the i known steam leaks. These actuators were inspected and no steam / heat degradation was observed. Viring, terminal blocks, torgae switches, limit switches, splices, gaskets, and limit svitch gear box lubri.: ants were inspected by a team that included E0 personnel.  !

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Enclosure l l Page 2 of 6 )

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There was no evidence of a thermal degradation from a steam l environment that would affect valve operability. It should be noted that the Limitorque actuators do not contain EPDM material. A  ;

review for ' alified life adjustment will be inciv'.ed in the further review described in the post startup item 4. There is no short term i concern of Limitorque motor operators qualified life in the dryvell l or steam tunnel areas. ,

5. The historical readings of the existing permanent steam tunnel and l dryvell temperature elements in the vicinity.of the MSIVs have been I reviewed, and a baseline has been determined for each element (see Attachment 1). Until the temporary temperature monitoring baseline j values have been determined, the existing permanent temperature elements will be used. It has been determined that a 10% rise above  !

these baseline values may be indicative of a localized steam leak  !

and would require investigation. This value was conservatively selected since it is approximately one half of the temperature rise expected for the Technical Specification trip value for leak l detection. It is sulliciently conservative for the interin period l until the MSIV area and surface temporary temperature element j readings have been fully baselined. This temperature rise vould j have indicated the steam leaks which impacted the inboard MSIV j (24 degrees F differential temperature) A lover threshold j temperature rise could result in unnecessary actions or reduction in  :

power operation due to minor temperature fluctuations. . l l

i (5a.) A procedure vill be established specifying necessary actions to be I taken upon exceeding the interim temperature values. The interim 1 temperature thresholds are, area temperature plus a 10% rise or a selected 225 degrees F for the temporary temperature elements in the area surrounding the MSIVs for both the steam tunnel and dryvell.

The Senior NRC Resident Inspector vill be notified if any of the -

folloving corrective actions are to be taken o Reduce power, as necessary, to perform a visual inspection to determine the equipment affected.

o Immediately repair the leakage or shield the adjacent class lE components to limit the impact until a repair is possible.

o Note components being affected and assess the thermal impact (EQ). Evaluate and determine the necessary time. frame for taking additional action, such as increasing surveillance frequency or changing replacement interval.

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1 Enclosure Page 3 of 6 i o At least 1 temporary temperature element in the area of each MSIV vill be maintained in service in Operating Conditions l 1, 2 and 3. If all temporary temperature elements fail for a l

specific MSIV, the adjacent temperature elements will be  :

utilized in an interim period not to exceed 7 days. In the  !

interin a correlation vill be established between the adjacent temperature elements and the specific MSIV without individual monitoring. After 7 days, reactor power vill be reduced in ,

order to repair / replace the failed element within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the plant vill be placed in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and ,

Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

o If the local temperature monitoring in the area of an MSIV i exceeds 284 degrees F, the affected MSIV vill be declared l inoperable in accordance with Technical Specification 3.6.4.a  ;

or cycled daily consistent with the E0 test parameters. This l remains in effect until the additional environmental testing  ;

is completed (see Attachment 2).  !

6. Additional steam tunnel temporary temperature monitoring has been  :

installed on the preselected sample points in the MSIV area 1 including on the dual and the test solenoid bodies. Baseline data i' vill be obtained on the temporary temperature elements in the steam tunnel during the next full operating period of sufficient duration to allow temperatures to stabilize. From our experience, this vill  ;

be several days after the plant is at full power. Until the baseline data is established, a value of 225 degrees F vill be utilized for the temporary temperature elements in the areas ,

surrounding the MSIV to initiate the actions described in Sa. i Inspections vill be performed during startup to assure that the -

initial temperature reading are not being effected by steam leaks. l Once it has been determined that the readings have stabilized, the  !

procedure outlined in item (Sa) above vill be revised to use the temporary temperature elements in lieu of the permanent elements.

The temporary temperature monitoring program vill continue until the

  • final analysis results of the environmental testing (see Attachment 1
2) is fully evaluated. At this time, possible design improvements vill be evaluated and a determination vill be made 'on future actions, including replacement frc- encies or correlation to permanent area temperature elements. The NRC vill be notified prior to removal of the temporary temperature elements.

Nine dryvell temporary temperature elements have been installed with at least one on each of the dual solenoids on the inboard MSIVs.

typical of what was done with the temporary steam tunnel temperature elements. A baseline vill be established after the startup following the outage as described above for the temporary steam tunnel temperature elements. These baseline values vill then be incorporated into the program, along with the respective acceptance criteria. In the interim, a selected threshold of 225 degrees F vill be used for temperature elements in the area surrounding the inboard MSIVs to initiate the actions described in Sa.

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Enclosure Page 4 of 6 j

7. A test has been performed which verified that air does not flow between the air compressor reduction gear vents and the air compressor intake. Consequently, it was determined that there vas no need for any equipment modification, or change in the intake i filter replacement frequency. l Following startup, these additional evaluations and actions vill be performed t
1. To further substantiate the high temperature root cause, laboratory  ;

analyses vill be performed to confirm the failure mechanism of the .

EPDM degradation. A review of industry experiences and discussions with various industry sources vill continue to be conducted in order to input into our analysis plan. Our preliminary analysis plan, which included these industry contacts, is completed, and a summary is provided in Attachment 2.

Ve have completed an initial evaluation of industry experience. The  !

initial industry review did not change our preliminary conclusion that the root cause of the problem was primarily localized elevated temperatures near the ASCO solenoid velves. The visual inspection of the EPDM did not exhibit the normal signs of hydrocarbon degradation (stickiness, sponginess, or svelling), however, we have not eliminated the potential of hydrocarbons having a deleterious effect. Ve plan to use data obtained from other plant experiences as described in IEN 86-57, along with our own analysis, to confirm ,

the root cause. '

i Our preliminary schedule is to have initial infrared analysis for hydrocarbon degradation by the end of January 1988 with the  ;

remaining results and analyses by end of the first quarter 1988. 1 Any further analyses required vill be determined at that time. Ve plan to use a local research laboratory, as our primary analyses ,

contractor. Results vill be provided to the NRC. Vith respect to l environmental testing, a test plan vill be provided to the NRC by November 23, 1987. Interim test.results vill be provided to the NRC ,  ;

as they become available during the 92 dsy test duration. I Following completion of the analysis program, possible design improvements, vill be evaluated and a determination vill be made on future actions, including replacement frequencies.

2. Presently, in order to minimize the potential for introducing  !

hydrocarbons to the air system, a preventive maintenance requirement i vill be established for periodic replacement of the instrument air I system prefilters. The maintenance frequency vill be consistent with replacement of the instrument air system after filters.

Additiona',1y, a generic precaution vill be added into air system work orders regarding the use of thread lubricants and sealants. If the outcome of the chemical analyses indicates the presence of hydrocarbons, ve vill immediately implement an appropriate

Enclosure

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i hydrocarbon sample and analysis program for the instrument air system. This vill include weekly sampling of the supply lines to ,

the MSIV's at the containment penetration connection as well as '

other main J-headers throughout the air supply system. The Senior NRC Resident Inspector vill be notified upon implementation of this i action. 1 i

Dev point and particulate sampling of the instrument air system vill ,

continue in accordance with the existing plant administrative ,

procedure. Any unacceptable results vill be evaluated and system j blovdowns vill be conducted until satisfactory results are obtained.

3. Until the first refueling outage, the fast closure dual solencids i vill be checked for proper operation during the monthly slow closure '

check. The existing monthly surveillance instruction vill be revised prior to startup to reflect the following test procedure. i The test vill be performed by fully closing each MSIV individually  !

utilizing the test solenoid, followed by taking the control switch ,

to close. Performance of this test vill verify the proper operation  !

of the dual solenoid, since the MSIV vill only remain closed if the >

dual solenoid deenergizes and properly repositions. If any MSIV i should reopen during the test, indicating failure of a dual i solenold, the associated MSIV vill be declared inoperable and the i plant vill be placed in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold  !

Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The NRC vill be notified I upon discovery of such a failure.

i Also during this time frame the HSIVs vill be cycled individually on l a quarterly basis regardless of plant operating conditions, and the  !

fast closure time verified. As a result of a failure of this t quarterly test due to temperature related problem with a dual  !

solenoid, or other air pack component, the plant vill be shutdovn t and the NRC vill be notified as described above. The monthly test  !

described above, vill not be performed during those months when the .

j quarterly fast closure test is performed.

Prior to exceeding a six month period an inspection vill be  ;

performed during an outage of opportunity, on the deal solenoid ~

experiencing the highest temperature profile. This inspection vill

. verify no degradation of the solenoid valve internals. If  !

accelerated heat degradation is observed, a complete investigation vill be initiated and the NRC notified. i I

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i Enclosure ,

Page 6 of 6  :

4. A review has been completed of all known steam leaks in the plant which could have affected Class 1E equipment. For all of the ,

potentially affected equipment identified, there is no configuration i vhere elastomer compression set or degradation could result in the equipment not being ab*le to perform its intended function. However, these components vill be evaluated to determine if there b.as been any affect on their long tera qualified life based on the ,

environment under which they were subjected. The results of this >

evaluation vill be completed and submitted to the NRC by November 30, 1987. A further review vill be conducted for -

potentially high temperature area environments of all Class 1E l solenoids and other equipment with EPDM subcomponents where ,

t elastomer compression set or degradation could result in equipment not being able to perform its intended function. This reviev vill  !

be completed by the end of the first quarter 1988. }

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Attachment 1 TEMPERATURE MONITORING FOR DETECTION OF STEAM LEAKS TEMPERATURE NORMAL OPERATIONAL ACTION PLAN SENSOR lMPLEMENTATION NUMBER TEMPERATURE TE RE D23 K102 A 140'F 154'F UPPER D23 K102 8 140'F 154'F DRYWELL M13 R110 2 150'F 165'F AREA M13 R11016 135'F 148'F D23 K112 A 135'F 148' F D23 K112 B 131'F 144*F MIDDLE M13 R110 3 136' F 150' F DRYWELL M13 R110 4 124'F 136*F AREA M13 R11014 136'F 150'F >

M13 R11015 127' F 140' F D23 K122 A 130*F 143'F D23 K122 B 128'F 141'F LOWER M13 R110 5 114'F 125' F DRYWELL M13 R110 7 122'F 134'F AREA M13 R110 8 122'F 134'F M13 R11011 110'F 121' F M13 R110-12 127'F 140' F E31-N604 A '

125'F ' 138'F T L E31-N604 B 134'F 147'F AREA E31 N604 C 130'F 143'F MONITORS E31 N604 D 128'F 141' F STEAM E31 N605 A 80'F 88*F TUNNEL E31 N605 8 80'F 88'F DELTA T E31 N605 C 82' F 90' F MONITORS E31-N605 D 82*F 90'F

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. ..- l Attachment 2.

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ANALYSIS PIAN FOR EPDM SOLENOID COMPONENTS 1

l I. INTRODUCTION To determine the cause for failure of solenoid pilot valves which resulted in the slow closing of MSIV's, two approaches vill i be taken. Both approaches involve analyses of the EPDM elastomer  !

gasket material. The physical properties of the elastomeric material which was in service vill be compared to new material to observe degradation, loss of material, deformation, anomolies in surface characteristics, and reduced performance. In addition, the gasket material vill be subjected to chemical analyses to discover changes from original material at the solecular level. Data obtained from the analysis regimen along with data from a similar failure experienced at Brunswick in 1985 vill be used to determine cause.

II. PERSONNEL CONTACTED Interviews with the Harris Research Personnel and NRR provided information regarding analyses performed and resulting postulations.

PNPP analyses vill include methods to confirm or deny these failure postulates. The full Brunswick Failure Analysis Report has been sent and vill be used as guidance. A meeting with Ricerca, Inc.

Personnel regarding this failure analysis program resulted in the folloving proposed course of testing.

III. ANALYSIS PROGRAM A. Samples ,

1. Unused Elastomer Gasket material
2. Used Elastomer from pilot solenoids which did not fail.
3. Used, degraded Elastomer Material from failed pilot solenoids.
4. Pilot Solenoid valve bodies with elastomer residue.

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i B. Physical Testing  ;

1. Profilimetric analysis to compare indentations in l EPDM discs (sample nos. 3, and 2)
2. Optical Microscopy to determine the presence of foreign material, or loss of material from surfaces.
3. Bardness testing to compare with original specifications.  ;
4. Compression set to compare with unused material and note 1 performance degradation. I C. Chemical Testing I
1. Infrared survey to determine carbonile content. This vill provide information about mode of attack (organic acids from the presence of hydrocarbons) and extent of oxidation.
2. Scanning Electron Microscopy /X-Ray dispersion Spectrometry I to confirm er negate copper-catalysed accelerated '

oxidation. (Vhich was a postulated Failure Mode at Brunswick)  !

D. Environmental Testing

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Six new dual coil solenoids vill be sent to a laboratory for additional environmental testing. The solenoids vill be placed in three separate environmental chambers (two per chamber) at various elevated temperatures in an energised condition. The solenoids vill remain energized for l predetermined times in an attempt to determine the temperature  !

and continuously energised time at which the solenoids do not I perform their function.

IV.

SUMMARY

The above analyses and their results vill provide evidence of failure mode and vill describe any further confirming analyses which .

may be needed. In addition, recommendations vill be made in order to preclude recurrence.

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