ML18066A592
| ML18066A592 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/30/1999 |
| From: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9908090115 | |
| Download: ML18066A592 (33) | |
Text
A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 3265 Covert, Ml 49043 Nathan L. Haskell Director, Licensing July 30, 1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REVIEW AND COMMENTS ON DRAFT REPORT, "EVALUATION OF AIR-OPERATED VALVES AT U.S. LIGHT-WATER REACTORS" This submittal provides the results of a review by Consumers Energy of the two NRC draft reports entitled, "Evaluation of Air-Operated Valves at U.S. Light-Water Reactors,"
and "A Study of Air-Operated Valves in U.S. Nuclear Power Plants." Consumers Energy requests serious consideration of the comments provided herein prior to the upcoming publication of the above two reports .. provides comments on the "Evaluation of Air-Operated Valves at U.S.
Light-Water Reactors" report. Attachments 2 provides comments on the INEEL Report, "A Study of Air-Operated Valves in U.S. Nuclear Power Plants". Attachment 3 provides comments and corrections on the INEEL Report in the form of redlin_e/strikeout for the specific Trip # 3 Report covering Palisades. Attachment 4 provides additional supporting information on activities conducted over the last 20 years which have dramatically improved both the air quality and the performance of the Instrument Air System.
The information contained in the draft report entitled "Evaluation of Air~Operated Valves at U.S. Light-Water Reactors" has been presented numerous times by Dr. Harold Ornstein including the 7th International Conference on Nuclear Engineering in Tokyo, Japan (April 19-23, 1999) and the 2nd Joint Meeting of the Air Operated Valve and Motor Operated Valve Users' Groups in Orlando, Florida (December 7-11, 1998).
Consumers Energy is especially concerned about the releases made in this paper and
- 2 at these conferences because the information was made public without allowing the licensee to comment on and/or verify the accuracy of the information.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades HLOrnstein, RES, USNRC JRiley, NEI 4 Attachments
ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVIEW AND COMMENTS ON DRAFT REPORT "EVALUATION OF AIR-OPERATED VALVES AT U.S. LIGHT-WATER REACTORS" 1 Page
~ "- ,.
REVIEW COMMENTS ON 19 PAGE DRAFT REPORT
. "EVALUATION OF AIR-OPERATED VALVES AT U.S. LIGHT-WATER REACTORS" The following comments apply to the 19 page report entitled "Evaluation of Air-Operated Valves at US Light-Water Reactors" -
- 1. Table 1 (Page 2), under the "Safety Related AOVs" column, the paper indicates that the total number of safety related AOVs was not provided. That number was available at the time of the site visit but may not have 'been specifically requested. -The number of safety related AOVs is 19-1.
- 2. Table 1 (Page 2), under the "Category 2 AOVs" column, the paper indicates that there are 403 AOVs in Category 2. This is apparently a typographical error as
.. 42 .
the correct number at the time of the site visit was_
- 3. Table 1 (Page 2), under the "Category 3 AOVs" column, the paper i_n_dicated that there were approximately 586 AOVs in this category. The correct number should be 561.
- 4. Under Section 3, "Operating Experience" (Page 4), the paper describes an event at Palisades in 1978 and 1981. The paper uses the terminology of a "residual heat removal heat exchanger." This is not the correct terminology for Palisades.
These components are correctly described as "Shutdown Cooling System" components in the Technical Specifications and the FSAR. Also in this paragraph, it discusses an AOV which was prevented from going to its "fail safe,"
open position. The valve described is CV-3025, the common outlet valve from the Shutdown Cooling Heat Exchangers. This valve's "fail safe" position, which presumably means its failure mode on loss of Instrument Air, is in the closed position - not tlie open position. CV-3025 is a direct acting valve with a reverse acting actuator. The valve performs both a shutdown cooling function as well as the Low Pressure Safety Injection and Containment Spray Isolation function.
From a design basis perspective this valve does need to fail closed on loss of air.
Lastly, this paragraph states that "poor quality air conditions that led to these events existed at the plant at the time of our site visit." Palisades disagrees with this statement and believes that the air quality of the instrument air system has been improved. See Attachment 4 of this letter for a listing of improvements.
- 5. Under Section 4, "Site Visits," (Page 9 - Table 3), the paper describes the diagnostic testing being performed at the various sites visited. The paper erroneously states that dynamic testing was beirig planned at Palisades. At the time of the site visit, Palisades had performed both dynamic and static testing.
1
ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVIEW AND COMMENTS ON DRAFT REPORT "EVALUATION OF AIR-OPERATED VALVES AT U.S. LIGHT-WATER REACTORS"
("A STUDY OF AIR-OPERATED VALVES :1N U.S. NUCLEAR POWER PLANTS")
3 Pages
REVIEW COMMENTS ON INEEL REPORT "A STUDY OF AIR-OPERATED VALVES IN U:S. NUCLEAR POWER PLANTS" The following comments apply to "A Study of Air-Operated Valves in U. S. Nuclear Power Plants." This document was transmitted from INEEL to the NRC on April 26, 1999.
Section 8.3.1 (Page 17)
The-report states that 9 of 22 air regulators were~found to be blocked.
Significant amounts of material were found in only three regulators. The restriction orifice was partially blocked on these *regulators. The only regulator that was totally blocked was the identified failure of PCV-3018. This was the only high pressure regulator that failed to perform its function. Also, we disagree with the statement that this event was a common-cause failure condition.
Section 8.3.2 (Page 18)
Contrary to the description of the valve function in the report, CV-3025 does not have a design basis function to open after a small break LOCA. The scenario that is discussed is not part of the design basis of the plant.
The condition of the Instrument Air System serving CV-3025 has been significantly improved since the reported failures while on Shutdown Cooling.
See Attachment 4.
RHR should be renamed Shutdown Cooling.
Section 10.1 (Page 39)
CV-3025 does not have a design basis function to open after a small break LOCA. Its safety-related function to close is to isolate LPSI from Containment Spray.
The report also describes a recent NRC Regional inspection thatidentified several gallons of water found at a low point in the air line. Contrary to this statement, the referenced Inspection Report, No. 50-255/97018(DRP), did not identify any collection of water.
A .great deal of discussion is made with respect to the condition of the Palisades Instrument Air System. A discussion of the improvements made to the system is
- included in Attachment 4. Palisades takes exception to the comment that, "All of 1
REVIEW COMMENTS ON INEEL REPORT "A STUDY OF AIR-OPERATED VALVES IN U.S. NUCLEAR POWER PLANTS" the plants visited, except Palisades, improved the performance of their air systems in response to in-plant events and in response to Generic Letter 88-14."
Palisades has significantly improved the performance of the Instrument Air System.
Section 12.2 (Page 50)
This section, and several other sections throughout the report, mentions the Utilities Service Alliance Group (USA) and adds that Palisades "withdrew" from the USA Group. This is not accurate. Palisades was, and continues to be, an active USA Group participant in the AOV initiative. At one time, Palisades performed the leadership role for this initiative. 'After further evaluation, and a realization that Palisades was significantly further ahead of other USA Plants in AOV Program development, Palisades decided to suspend their leadership role.
Section 12.3 (Page 50)
In the early part of this section, the report contrasts the AOV and MOV Programs. Under the "Design Basis" discussion the report states that "The design bases for MOVs (were) found to contain incomplete information and/or non-conservative assumptions in a riumber of cases." This sentence could easily be taken out of context. It should be clarified that this condition existed prior to the NRC Generic Letter 89-10 Program. (Palisades has closed out each ofthe Generic Letters.,on MOVs including NRC GENERIC LETIER 89-10, 95-07 and 96-05.) The design 'bases of the MOVs were acceptable at the time of Dr.
Ornstein's site visit.
Section 15.3.1 (Page 63)
Consumers Energy suggests that the PRA techniques used at Fermi 2 be verified. Palisades used the PRA techniques that are described in the paragraph for Fermi 2. Also, there are a total of 84 AOVs modeled as active in the PSA, 75 which are active and 9 which are not active in the lnservice Testing Program.
Section 16.2 (Page 77)
The report discusses an EPRI sponsored AOV program where Palisades and Fermi were the lead plants. The report indicates that the effort is restricted to high risk AOVs. This is not an accurate statement. The Palisades AOV Program was established to develop design basis information and perform testing for all active safety related valves. This included many low risk significant AOVs.
2
. REVIEW COMMENTS ON INEEL REPORT "A STUDY OF AIR-OPERATED VALVES IN U.S. NUCLEAR POWER PLANTS" Section 16.4 (Page 78)
This section states that - "Every plant visited had experienced major problems with air quality and all but one plant visited had taken actions, some quite extensive, and mostly in response to Generic Letter 88-14, to address their air quality problems." Earlier in the report Palisades was singled out as the exception. C~nsumers is very concerned about-this-characterization and does not feel it is representative of the true condition of the Instrument Air System.
(See Comment from Section 10.1 and Attachment 4.)
Table 1-3 "Population of Air-Operated Valves in Plants:Visited" The numbers listed in this table are not correct. This is the same table used in the report entitled, "Evaluation of Air-Operated Valves at U.S. Light-Water Reactors". See Attachment 1 for the proper numbers.
Appendix C - Trip No. 3 Report Because of the large number of inaccuracies in the Trip Report, the Palisades comments are being provided as a red lined mark up with the more accurate information. This can be found in Attachment 3.
3
r.*
ATTACHMENT 3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVIEW AND COMMENTS ON DRAFT REPORT "EVALUATION OF AIR-OPERA TED VALVES AT U.S. LIGHT-WATER REACTORS" (TRIP No. 3 REPORT - STUDY OF AIR-OPERA TED VALVES PALISADES, NOVEMBER 18 AND 19, 1997) 20 Pages
TRIP No. 3 REPORT STUDY OF AIR-OPERA TED VALVES PALISADES, NOVEMBER 18 AND 19, 1997 We had two days of meetings with the engineers and technicians at Palisades concerned with the air system and air-operated valves.* We did not have an opportunity to view equipment in the plant, however we did tour the diagnostic facilities that were used to evaluate power operated valves at Palisades.
Palisades has a dedicated AOV Program Engineer under the Manager of System Engineering Pr1:1:>"g:r.<m:J~. At the time of the visit Palisades was a member of a group of utilities that pool their resources to devise integrated solutions to problems and concerns. This group of utilities is known as the Utilities Service Alliance, USA, and was made up of Fermi 2, WNP2, Palisades, Ft. Calhoun, Clinton, Cooper, and Wolf Creek. Tl=le Palisades AOV Program was part of tl=lis group effort, l=lo*we*ver, it 'iVas receAtly leamed tl=lat Palisades is AO loAger a member of tl=le USA group. m~
P~lisact~N.©,StBrogr~m~is;~till*f:2~f:tici~ti~itlfl!Ji~:gJQ,u~::J).uftQiafle.ss~(~e~ept P-e,cause:oftt1e~comP-letiOffilQfltfiei r:.aesiQ1Pt5asi~i~
The engineers at Palisades provided us with a notebook, prepared for our visit, that described their program and some of the pertinent problems regarding AOVs. The contents of the notebook also included a description of the Palisades organization, a document entitled "Air Operated Valve Program" (that specifically excludes HVAC dampers from :its scope), and several lists of AOVs, as well as lists of AOV failures and deficiencies that have occurred. We were provided with several summary charts to indicate the pertinent Probabilistic Safety Assessment (PSA) results for Palisades. We were provided with a copy of an engineering analysis entitled "System Level Design Bi:i§is Review for Air Operated Valves (AOV) in the Engineered Safeguards System (ESS)." Also, copies of the hand-written logs associat~d wi.th the 1978 and 1981 incidents involving failure of AOV CV-3025 in the shutdown cooling mode were also provided.
We were provided with a summary of the results and goals associated with the Maintenance Rule review. The primary goal is to implement an action plan for the improvement of the high pressure air system. A closeout memo for the previously implemented plan for improvement of instrument air compressors, summarizing what had been accomplished, was also provided. In addition, we were provided with a copy
'Of.~nother action plan for improvement of the plant air system that was not associated
'With actions required by the Maintenance Rule. The reason for the distinction was not clear.
In early December the plant engineers forwarded a document entitled "Compressed Air System Safety System Design Confirmation Report," (SSDC) dated November 21, 1997. This report was prepared by the plant for the purpose of an internal review and INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 1 DRAFT April 26,1999
--.----- was mentioned during our visit.
The cooperation, courtesy, and knowledgeable responses from the members of the Palisades staff was noted and appreciated by those of us who are involved in this study of AOVs.
Prior to the visit the NRC TM provided us with a description of the Palisades .
compressed air (service and instrument air), high-pressure air, and nitrogen backup systems from the FSAR. Service and instrument air is provided by three compressors, each with a separate receiver. The receivers are connected to the compressed air neadek; wliicn brancties* to"an-*instrument air header and a seivice -air~header:. The~. _
instrument air header is equipped with a single desiccant dryer and 1w;~;;,~09n&S!~ti!~W§1 a f-ilter. jnn*~re:tare~1tWffiaPCiiti(ffiijlfc0111gr~ssors*;.tffl'at~l3e:r~QnAectea0t(5".ttle§iffis.'.tp:Jmenti ains~s'ffi High pressure compressed air is provided by three high-pressure compressors, each with its own refrigeration type dryer and air receiver.
- Nitrogen is supplied from bottles or in bulk as a back-up. Two banks of 2000 psig nitrogen bottles provide limited back-up for the auxiliary feedwater system valves. Four other nitrogen back-up stations, each consisting of 2000 psig nitrogen bottles, are located in the auxiliary and turbine buildings to provide for operation of certain safety-related AOVs. A bulk nitrogen back-up system of the instrument air system provides for the operation of the atmospheric dump valves (ADVs).
The instrument air system and the high pressure air system have m@. significant design and operational weaknesses, which ~[f~havef.1ect ir1 Ute past (suet=t as loss of st=tutdo*wr1 eoolir1g ir1 1978 ar1d 1981 due to tt=te f-ailure of tt=te sir1gle CV 3025 AOV), ar1d ear1, ifl tt=te future, leao to safety-significant events and common-cause and/or common-mode failures of AOVs and other pneumatic equipment[(SliCh~IOs'S]Of:::Snufcf0,Wn
~1*~~1~(;'1. 7 8.......,._,,~ ..-g*a-..
~op mg;1Qr,, :.:,111'. ,t,ar:k.1 1\H. o; '"~-~;1.a1 ure+P. :: ue;:s1n,g e;~ "",; /
- _ *. t90~1;* Th ose :.:ie:s1gn
- : ; : i - .t,......t~~...,.1==t*t~-1"""'C.,~,..".3*0*2*5'°"'/\"'""m
.. .1f';,9,ae1 r.::I""""" *..,.........
issq~§ weakr1esses includeS!;
lack of redundant dryers for the instrument air system. The dryer was being.
bypassed when serviced and the system was left without drying capability during that time.
use of refrigerant dryers on the high pressure air system. These dryers lack the
- capability to lower the dew point sufficiently to ensure that a supply of sufficiently dry air is provided.
misplacement of filters. Several filters were noted to have been placed downstream of the pressure regulators that they are intended to serve.
deterioration of piping and equipment served by the filgffi~~resst:m~ air system.
pqe, clogged fil_glf.i:ern§s8re, air regulators and corroded piping were reported.
A bank of air bottles provides 1800 psig air to back-up the high pressure air system for INEEL/EXT-98-00383 Appendix C, Trip #3, Page 2 DRAFT April 26, 1999
- *the operation of AOV CV-3018, to meet the fire protection requirements of Appendix R
- of 10 CAR.
The condensate demineralizer building compressed air needs are supplied by either of two air compressors, each with an integral intercooler and separate aftercooler and receiver. Service air is piped directly from the receivers, while instrument air is routed from the receivers to a dryer and then to the instruments. [FAj~tem~,ean.11trQ~Jq~
pacRiij21Jcrrt!W]'fir;na~0air: ,eom~~es's'drs~
The operation and control of th~ _air ~nd _nitr~gen systems is described in the FSAR.
The AOVs at Palisades are classified as Category 1, 2, or 3. Category 1 valves include safety-related AOVs with an active safety function, AOVs that are important to safety based on their PSA risk significance, or AOVs designated by an Expert Panel.
Category 2 valves may be safety-related and of low risk-significance or non-safety related and used in critical applications that could affect plant availability, capacity factor, heat rate, or maintenance costs. The remaining AOVs are included in Category
- 3. There are 111 Category 1 AOVs, and-4W ~ Category 2 AOVs. There are approximately-4499 i1~1T4~AOVs, total, in the Palisades plant. For comparison, there are 54 motor-operated valves (MOVs) in the plant, 30 of which are covered by NRC Generic Letter 89-10.
Palisades is now involved in efforts in response to the requirements of the Maintenance RtJle, 10 CAR 50.65, and those efforts complement their AOV program. Specifically the Palisades staff is reviewing the importance of their AOVs from several different perspectives, including PRA and Expert Panel :insights. Palisades has a formal AOV maintenance program and is in the early stages *of implementing a plan for .
- improvement of the performance of AOVs similar to that previously invoked and accomplished for motor-operated valves (MOVs), and based on experience with MOVs.
Palisades is also part of an EPRI pilot program on AOVs similar to the one described to us in more detail at Fermi 2, f:i'f:fcfo/i~ing~t~ based OA EPRl's Performance Prediction Program devised for motor-operated valves. Palisaae.s1ar;ra~B~Rl~irwol~~i~
Mlla:O'Qi'.ativ~(agreem:ennf9!cfe~~lqB.:ctesi§1V:.Pa.sJ$,\l~r~Y-~l~lafiQi'.j51 EP R1. is prov id iAg fuAdiAg for aAalyses of the AO\/s at Palisades.
Implementation of the Maintenance Rule made the plant engineers consider each AOV and rank the valves in terms of risk-significance, in accordance with industry guidelines.
The ranking process resulted in about 11 of *13~jactive AOVs in the PSA model being categorized as "high safety significance". Those 11 AOVs are listed in item 21 in the table that follows.
INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 3 DRAFT April 26,1999
The plant engineers were !Q!1y~_qpgr;ii~OftAU~i~t~e:si[i;llJiffiitiiliO,os1ana,
'Sf~f@~ie'$&'.an-CJ~We.r:e;ilp,,9r.~.Cli~tiyiti~$~lo--:-iij;l'~rov.~ not particularly concerned about the quality of the air supplied by their air systems. TAey believed it to be acceptable altAougA it is not monitored on a continuous basis((l'.jewJ5~ti~t]ai~te:mFi~
g99e~fi;i6lfiloecaµse~0,f::tr,reJc<;ir(E(cti~raC,ti~t"ijK0Mi~f9:8::1~and tAe quality is judged subjectively (i.e., direct observation to detect droplets during blowdown). The air system engineer .t'i)~l?1,c:fi?.er:i~f.~ti~l~t'Q7im~rov,~~ai.~tem,p:ef:fo:rmanpe~:1 Br.og_r;el):s 1 :of.~t~tionJRTaijWile:5te>neSJi$lo$e.l~mo1;1it~. indicated tAat Ae Aad not received management support to modify tAe system to attain tAe air system quality levels noted in ISA 87, "Quality Standard for Instrument Air." After reviewing their program and-the air system~ includingt~recent incidents (CV-3018), wemade several observations about the air quality and the failures that they had experienced. ffi.tm l~$.q~*§:;_qrn'.G;~i3J~):2*9;\wa$z,a9?J~e~$~ffifi?~lJ ~~;GW21?;.S~~ra~t~:EW;n;a'$ 1a:aa re.S"$eC:t1tfie,
!QO't*c~.Lt~e11ofi:;tiji.§+t~s.,UJ_e,,;::1NOJf~ilur,e.s;,,qfgor;p~onent$lnJITefi1;1,str:ument~ir;".§~$t~m(~
P1cqyrr.ea,~.siq~~:;1~9l3'1~,f'la1iStt'f'S:t.ill~Ri!igrlo.r;ii,99rre.c.ti~ti~f~tn*e:re.cen~
JneiQ_Wjt~f}$1Z;3-q;rs1 Our comments on the Palisades'AOVs and air system, as well as those of the other plants that we visited, are summarized in the table that follows.
The following tabular summary was prepared to describe the information gathered during the subject visit. The NRC, with assistance from the INEEL, is studying the performance of air-operated valves (AOVs) in commercial nuclear power plants. The information was collected in accordance with the Program Plan dated 10/22/97 (INEEL Letter to H. Ornstein, NRC, from J. Bryce, 10/23/97, Job Code E8238, Task Order 15 -
JHB-167-97).
INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 4 DRAFT April 26, 1999
TOPICS TO REVIEW FOR AIR OPERATED VALVE STUDY SITE VISIT TO THE PALISADES NUCLEAR PLANT ITEM INFORMATION RESPONSE OR INFORMATION No.
1 Date. November 18 and 19, 1997 2 Name of Interviewer. Owen Rothberg, INEEULMITCO, 301/816-7773 John Watkins, INE~L/~_MIT<;;O, 208/526-0567 Hal Ornstein, NRC/AEOD, 301/415-7574 .
Gerry Weidenhamer, NRC/RES, 301/415-6015 3 Plant Name & Docket Palisades Nuclear Plant, 50-255 No.
INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 5 DRAFT April 26, 1999
TOPICS TO REVIEW FOR AIR OPERATED VALVE STUDY SITE VISIT TO THE PALISADES NUCLEAR PLANT ITEM INFORMATION RESPONSE OR INFORMATION
~o.
4 Person(s) Interviewed, Plant address is Palisades Nuclear Plant, 27780 Blue Star Title(s), Phone Memorial Highway, Covert, Michigan (Ml), 49043. (See the Number(s), E-Mail phone listing in the materials provided for phones not shown.)
address, short ..
description of Philip *D. Flenner, Senior Licensing Engineer, 6161764-25~4-;-E-organization(s) and Mail fln@aol.com duties. Gary W. Foster, Component Engineer, 616/j?iJ)~~-2684, E Mail gvdfoste r@-ovorld net. atfnet Robert A. Gambrill Ill, Component Engineering Supervisor, CE, Engineering Programs;: 616@6~~-2497 Thomas E. Bordine, Licensing Manager, CE Daniel Mauck, Crane-Movats, Component Engineer Chet Cynaski, CYNCAM~~no,s!{i, g~f:!~JU.fY1,, Consulting Engineer Leslie Bradshaw, Valttejflal~ Engineer, CE Ronald Penna, Alpine Enterprises, AOV Technical Specialist Judy K. Ford, Manager of Engineering Programs, Engineering Programs Dept., CE, 616/764-2340 Kerry A Toner, Licensing Supervisor, CE Ken T. Speicher, Systems Engineer CAS, CE Robert A. White, Reliability Engineering Supervisor, CE, 616/764-2860
.. Paul F. Prescot, NRC Resident Inspector, 616/764-2741
.. Eric Grindahl, Diesel Generator Engineer, CE R. A. Fenech, Sr. V.P. Generation, CE
.. '~
T. J. Palmisano, Site V.P., Palisades, CE
$ Bill Beach, NRC, Region Ill Melvin Leach, NRC, Region Ill Gregory B. SzeozotkaS.?;.q,?:,Q,,t~. Manager NAPDJiU'.~.~g. CE Kurt Haas, Director ofEngineering (Acting), CE Rob Mccaleb, NAPD!~I~miq, CE Phillip Young, Project Engineer, GE-',fi!F,&:S.
Ken Squibbs, System Engineer Supervisor, CE Paul Fitton, System Engineer Manager, CE R. A. Vincent, Licensing Supervisor, CE Daniel G. Malone, Operations Supt., CE INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 6 DRAFT April 26, 1999
- -- ~
TOPICS TO REVIEW FOR AIR OPERATED VALVE STUDY SITE VISIT TO THE PALISADES NUCLEAR PLANT ITEM INFORMATION RESPONSE OR INFORMATION No.
5 If necessary, and if We were given the following materials when we arrived and person(s) interviewed during the course of the discussions:
can do so, obtain any 1. A notebook containing organization charts, the Air-
~issirig information not Operated Valve Program Plan, an analysis of the AOV provided prior tO the site Program scope, a list ofMaintenance Rule (1_0 C~R visit, as described in the 50.65) evaluations, and several valve lists.
outline for Task 4 above. 2. A design basis review of AOVs in the Engineered Note what information Safeguards System.
was provided. 3. Action plans for air systems improvements and instrument air compressor improvements.
INEEL/EXT-98-00383 Appendix C, Trip #3, Page 7 DRAFT April 26,1999
TOPICS TO REVIEW FOR AIR OPERATED VALVE STUDY SITE VISIT TO THE PALISADES NUCLEAR PLANT ITEM INFORMATION RESPONSE OR INFORMATION No.
6 Describe plant events LERs 25578003 and 25581030 were concerned with the involving AOVs and significant 1978 and 1981 failure-to-open of a particular provide reference shutdown cooling system AOV (CV-3025) when activated at information, if possible.
. shutdown. Tne valve is also requir:ed to opeA to mitigate tne effetts of"a small .break LOGA.- The sing.le ~9Jiv~ fa!!u_r~ of the Recent: valve on each occasion resulted in a rise in core tem-perature and apparent boiling or near-boiling conditions in the core. We Recurring: do not know the exact amount of time that it would take to uncover the core, but it is believed to be only a few hours.
Significant: foll0i.&in'g*1t~ia.§e;;e.ventstmo'aific'lti~r;is1y.t.e're.:r:i.~iif0r;me_!\J~to,tO:e~~iifi
§..i$te.rJ1;1t0~imJiro.V'e"Tciir.*,guali~:\Jifir,dpgra;tfl'E:f~.e'.ars"'.follqwi0g1ttles.~
~,V;er)'tS!tQe,{e,;navea1soi:Beenr0~¢rafionalrefiianges~to:~enst1rerl.~
e}".StE;!m'{;B,roMiaes::cl~r;M*taij)]
Although the valve had not failed when called to open at shutdown during the* last 16 years, we became concerned that the quality of the air provided by the instrument air system is such that the event could occur again. We expressed our concerns at the exit meeting -Pl11T1qweveu,'iR:8lisaaes;tt5el_i~ve's1:ttlta~
J~irn~ro~er:n~nts~rnap'.eHs11:1;9~;;.1;Ql3,i1rf,ta~,e;1r:es~i:i,1te.c:t1ir;i,f~:go:ali!Yt\~iij
~~st~
Another significant and recent event of interest was the commoA cause/commoA mode failure of pm~ ~high-pressure air regulators caused by contamination from rust in the !li'§Jl B~e_s_s_u,(~ air lines. This situation was originally reported to AEOD in April 1997 but was not covered by an LER. (Palisades Condition Report C-PAL-97-0404, dated p"WI8Zai~ 4122197 ~r,fe.
~E:!8*3*3*5:qatear:4'ffil$:'lj refers to this event.) ~ll;*ofi~tljlep.zalveS, p9Ju1~e,te.a~t~::tn~~J5igf:j.:~re,§_sµ~e;1~Jirs~~lern;rtffi~t:tlgMe1..90:9qtJ~
tar:ictR>111~!J'.~rve1saJ~l.lil~filt~rs£iJ)sJall~~fre;iro,.~~f::t~1re'g,C!lat0r~
AAfiav~e:l'!litr:qgen~ordi}Strcin;iei;if,1air!kBa*cisl'.11!~Jli'.at~t~tGQnn'~~t~P.
f:iir~ct!Y,49~lf;)~~y~l¥g_~j Tne coAclusioA was that the nigh pr:essure air system, whicn serves maAy EGGS compeAeAts has Aot beeA operatiAg iA accordaAce with iAdustry staAdards. As a result, tne r:meumatic equipmeAt (iAcludiAg AOVs) serviAg the EGGS is nignly susceptible to commoA cause>(commoA mode failur:es.
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7 Describe AOV or air- In discussions with the plant staff in charge of the air system, it system actual or became clear that the quality of the air delivered by the detected potential instrument air and high pressure air systems at Palisades W.~.1!
_~failures'at---the plant? e.revJe:us1t1istQ!Y:Pf<PQ~rC1titlg'.rl5elpvv.~oelimalTalr:;:.guaU~*-sta0,qar;ps Provide reference was suspect In aaaition to~the-prot>lems noted in_it~m 6, above, information, if possible. we were told that the instrument air system has only one -d*ry~er -
and it is frequeAtly bypassed wn.~par~g.uirea~l5~H;~Jarrit>.Oj2?.e~ati0n§ I~icall~less':fnar;t~one~a.ei~Q-~r:*}f~.ar~. We were also informed that the high-pressure air system's refrigerant dr;yers do not work
~:s~~W.E;llt~-~:;ar,ae'$iccanJ1'~~~r~ properly er reliably, ~fili~,fff;fl~:§ re'st'.Jltea~in?Qasti resultiAg ifl frequeAt instances of air system contamination (water and/or rust). In addition, several filters in the high pressure air system had been installed downstream of pressure regulators served by the air system rather than upstream. As .a result, corrosion products have produced eeffm'lefl eause P,m~ pressure regulator malfunctions.
- a Describe actions taken The plant has focused on the high-pressure air system as part of after events or failures its Maintenance RUie reviews. The plant conducted-a review of involving AOVs or the air their air systems and have added several goals under th.e*
system. Provide Maintenance Rule, some of which are still in the process of being reference information, if implemented. fU~ta'igfl!Qressar~Jai~:§~ste'.r;rri;twas::emUi.e':a~J'.!f)!li'Sl possible. ~~e:Jo'f,¢or:l~er;nsra.Bo:utiilqr:rgjtjte~m2~ef:f.oo;uanJ 9ur additieAal eemmeAts prompted plaAt maAagemeAt te ass_ure us ef reAewed aAd additieAal atteAtieA te tt=1e quality ef air.
'- - , .. -* *- **~ - ..- ---
9 Were there any actual or Yes See item 6, above*for past failures. f£ti~r;f:?~tQ'?i~rce.~~n!~
potential common mode reo~cct'i'~r.e:r;f<;:~~fia~e~'~taR"erf:l or common cause failures in the air system or AOVs at the plant?
Describe and provide reference information, if possible.
10 Describe root cause Not described.
i analysis procedures for the plant. Provide reference information, if possible.
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11 Describe root-cause Not described. Based on our observations of plant e*vents and analyses performed for LERs, root cause analyses regarding tl=le air systems and AOVs air system or AOV do not appear to be complete.
failures at Jhe_ pl~nt.
Provide reference information, if possible.
12 Describe maintenance Maintenance and operating practices for the air system were procedures for the air discussed at length. The air system, including AOVs served by it, system. Provide is maintained by an engineer and ~Jatl¢r:i'lm'.a'.iO:tE;q'.~Jil'qe,,:~,e,r;$,QJllff~.!
reference information, if tecl=lnicians dedicated to this system. fliWStaJi~.OC0Xli8rq*g~~'raj possible. i$~Jnax1ag~o!Q:W-'.~eSJ.Ei£alWa'lve.'.e1Jgipee.rs7,tec:l1nici~Dampers for ventilation and diesel generator ~lr:;,s¥~Jei;n, AOVs are maintained by others. Maintenance oftl=le air system appears to be substandard. See items 6 and 7, above.
Air quality with respect to water ~:ff\l]J~iAAl~t~ content is monitored "periodically." ffi~lfre'.OQime,ersN11er;.eJ(ill~
~gnizant~nt~ip:sys:t~esigm,"lunitatio_l]ls~ana"1!efi:Cien;¢i~
~~wete;~~~rsCJi~ti'lities'le"imi2r<:>ve'.1tlil~~g.aalj~fr.t~ifi
~g.r~lieCi~~t~ir:ai~t~ Tl=le plant engineers do not appear to be particularly concerned about tl=le quality. of higl=l pressure air and instrument air and believe tl=lem to be acceptable.
13 Describe maintenance Palisades has a formal AOV maintenance program and is in the procedures for AOVs. early stages of implementing a plan for improvement of the Provide reference performance of AOVs similar to that previously invoked and information, if possible. accomplished for motor.;.operated valves (MOVs), and based on experience with MOVs. (See the material in the notebook Safety-related: provided by the plant engineers.) Diagnostic testing (equipment -
specifically adapted to AOVs is being ~v.atuated. il:fu.e Important non-safety- prioritization of AOV importance *is ,being ;established'Jrom related: studies implemented to meet the requirements of the "Maintenance rule. It appears that the AOVs are getting thew Non-safety-related: deserved attention.-~nd tl=le same sl=lould be done for tl=le air systems tl=lat serve tl=lem.
14 Describe IST procedures ~:s1;1~~~t.fte-.reg1;J*i~f~$JYtEfet~T:2~~3.
for the air system. ~~onents:;*:Tnisrexelua~s~mucoofi"ttre"':instrtimeAt:anoH:iig]
Provide reference B~eS.s.9re.0 aJr;tsy~J~ No periodic IST is done on tl=le air system.
information, if possible. Post-maintenance testing is done on components and portions of the- system affected by repairs or maintenance.
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15 Describe IST procedures Periodic testing of AOVs is done on Category 1 AOVs and for AOVs. Provide consists of ASME stroke/time testing (no load).
reference information, if possible. DiaglJQSti~J~sting and bench testing are done op f.\QVs, <. " .
although apparentlyffot=p~rfodieally~d2~l~G9£ib1U:llief,t~~jngi;Q!
Safety-related: ~QX/~i~rfP!fne<t~.~1!le~XJgg:t~iffit~tWQY'~X;Qa.n~gerlfQfi!!'
tneir:tae.sJgngf~tiQiU Important non-safety-related:
Non-safety-related:
16 Describe diagnostic Palisades uses a MOVATSrn!iniversal §iagnostic §ystem for systems, if any, used for ~QY'~ MOVs and is trying to adapt t~ Liberty Technologies-tteW AOVs. Provide Ea~t~ilio.r,gue7ill~K~S]If9Js~r:i,so.n system for AOVs. mJ~tfiij reference information, if ~mJQ.e~TheGffi*nologi~Y;al~~isienf~~t~iS-Jtsei!'l9~l\ls~~Jf)fQO possible. Jes!in9t~~1\Z'§E]Th*ey have become quite adept at diagnostic testing because of their MOV experience and believe that they Description of system: can determine margins using such tools.
Specifications: The new AOV diagnostic system is in the early stages of evolution and Palisades is evaluating the software. See Data collected and Palisades AOV Program, Procedure EM-28-03, which was frequency of collection: included in the notebook provided to us, for further discussion.
Vendor assistance provided, if any:
17 Describe design (and We were provided with a copy of a document entitled "System analysis) procedures for Level Design Basis Review for Air Operated Valves (AOV) in the AOVs. Describe how Engineered Safeguards System (ESS)." Similar documents for design basis is other systems were observed during the visit. Palisades is estaplished and reviewing their design bases for AOVs to ensure that it is maintained for AOVs. accurate and complete. As part of that process, they are Provide referenc~ reviewing or revising the original calculations for the valves. m information, if possible. 130me 1 e.a~e~:*1tl.ap:t~l~l~ttons~a.re;}~ing1ge.r;leratfilf~f~t~fif8t Jime] Palisades is conducting system and component level design basis reviews of their AOVs, as described in their Program Plan.
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18 Describe analyses and/or Analyses are described in item 17, above. No specific test testing for verification of program is in place for verifying design-basis operability of AOVs, operab.il.ity d~ring other than §.Y-nami,C'ldiagnostic testing and comparisons with the postulated transient or EPRIR P-M=m~Jbg~<;!_9JC?~~l1~11'.liC::te.s,tiogl~i§;~Q.~[fqn:pecriHtffi3.
accident conditions. ~c:11)1es,:{QP1f)Qf):~Xra'il5it~ . ,*. uate,~11'.l~arg iA~Se'e;ci~.1£t~sJ~f2,!;0G~~CJ~e~
Provide reference fi.r~1R!:~Q~f~o~fC?.n'.i\Q~';.p,¥1J1*fl*rnie1tfJ§t§IJq;~ltov./t,Qge.~ctti()!7Js~1-q '
information, if possible. man*i~late'.tne~~larffitQI'r:!l~.~iO)iZe;Jpiffe.,re,~tj~l'."r2l~S:~.lJ~~:~~~~n~X1 19 Describe training for Training for . valve disassembly, diagnostic testing, and valve .
installation, maintenance, maintenance is provided. We viewed part of the Palisades and testing of AOVs. facility for diagnostic testing and the procedure was Provide reference demonstrated. The engineers appear to be quite knowledgeable information, if possible. about the various diagnostic systems. available afld afe ifl H;t:e pmeess ef eReesiAg ameAg tRem fef use at tRe plaflt.
Palisades personnel made presentations regarding diagnostic testing at the AUG aA*e iAternatieAal (ICONE) meetings, to the
,1 benefit of other plants.
20 Describe databases used Palisades maintains a number of computerized, on-line to track maintenance, databases to track failures and events. These can be sorted for failures, and events particular valves and valve types. Engineers and technicians are regarding AOVs. Provide familiar with the operation and performance of equipment in the reference information if plant on a detailed level.
possible.
On site:
Company wide:
Industry:
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21 Describe the impact of Implementation of the Maintenance Rule made the plant the Maintenance Rule, engineers consider each AOV and rank the valves in terms of
-10 CAR50.65 on AQV risk-significance, in accordance with industry guidelines. The and air system rankingcprocess,resLJlt~d in about 11 of-1-5~&~ active AOVs in the maintenance and testing. PSA model being categorizeff as-"high safety significanc~".
Provide reference Those 11 AOVs are:
information if possible. - CV-3006, LPSI Shutdown Cooling HX Bypass
- CV-2010, Condensate T-2 Inlet
- CV-05228, Normal Steam to P-88 from SG "A"
- CV-3025, Shutdown Cooling HX to LPSI
- CV-3029, Containment Sump Isolation to ESS Pumps
- CV-3030, Containment Sump Isolation to ESS Pumps
- CV-0779, SG E-508 Steam Dump Control
- CV-0780, SG E-508 Steam Dump Control
- CV-0781, SG E-50A Steam Dump Control
- CV-0782, SG E-50A Steam Dump Control
- CV-3055, Shutdown Cooling Inlet to Shutdown HX.
22 Is PRA data used for .!?~~7i$;r,ec~i¥iifg-;;1imitemus.e;as~a'nnir:ig,am~eterro!ra:ei~re:qi~ti~
predictive maintenance Predictive maintenance ~tiVitl~sCQQ'-ef AOVsg was Rot a eurreflt or replacement of AOVs? maiflteflaflee praetiee. SerFeeti:ie maif'lteflaflee appears te be If so, how? tl=le Rerm. It is afltieipated tl=lat full implemefltatiefl of tl=le MaiFtteFtaFtee Rt:1le will el=laFtge tl=lis.
23 Are AOVs serviced on No standard service process is used. Maintenance, repair, or site, serviced off site, or replacement methods depend on the circumstances. p:e1gct~
replaced as piece-parts if ~©~.Rlita:av..e'.~r:naintenar;, ...... ,.. ......~\"' ....;_. *iat~Is~e_os~s,;.o,Y._er:.lita1:1ls found to require service? ~ r;i:ijggi:e.(.f):Qti~~2ma,ii}te,f61a. rn.c~~cf;fe~c.&$1 INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 13 DRAFT April 26,1999
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24 Identify and describe the ffil}e?;f()JIQW.ir.ag,:are'a~QfiTrEilatea~ip_sae*$:.n'.qt':cPoom~n J~:c~ rriog most common recurring ~inte11c:lnce1.erq~lerr.f@~~fci!lu.re$J'il?,ali~e:S:}li'as::.n:9t
.maint~nc:lnc;;e .problem(s) ~i~ea**anyJr:;Qr:n,1;ri'om:r:e_curri@*g'.m'aintena1?1ce~iQrol5'I~
and failures regarding* ..'a*$."StS""'a*te*::iir=w*ta;;'""ti;;;*e"'*n*st" m "'t~a*~s.t.,......_,,,,_e g ..:.1 .. u~ .J..1i1;;.1J ,1, : ,;~~!.~.-~~~** "' *~*trg*a--t".:l
- ~ J12\ ~s . mt-Slfil~t*: ?1z; AOVs and the air ' - --
system. What did you There is only one dryer for the instrument air system. As a see? Provide reference result, when the dryer must be taken off line for any reason, J,~
information if possible. p*omeress.or;1ta_fter::.cp~le8i~liech(JP-"¢m#f0ijaiir7C:f!Yin'gj no air drying is available. This resulted in contamination of the air system from moisture and corre'sion products, and elevates the risk of ..
common cause/common mode failures. A backup dryer is a*1ailable but, because of the expense, had yet to be installed.
Air quality was monitored infrequently.
The high.,.pressure air system serves ~safety-related ECCS equipment ~J.rn'.0.n~~ate~latea~ifirrt"~riJ'itl Refrigerant dryers for the r.(0r~K$a.fe~l~~.ihigh pressure air system tenda to freeze up and so it.iS:'l1.eP~$§~ry to cycle the compressors to prevent that. ~J;i9a:ojlJ$.ijT!gf:lt::was(ma.a:ett~tti~ffl'i.~lv.e:ti~t~
~n*~µr;e111;:1p1§~~qe*s~nol"remain:;i111*1t~rfiCf~2efe':'~tla.1:1g~
jrtJ'i~t5J~f:lc:is.:r:iot7ioe~en1exeeri~rc>iWt~fe~latea
~ui§rft'~ij}] Recently,~i] several regulators(~~§ were-found to have failed f;t~tq because corrosion products in the air, W,fflie~
B!Qg_gee;;m:e:*;$mcill~l:a'.t~if,i@l which IDL1:erGO:m~'siom1r2,1;0CfuetS.
were caused by moisture in the air system. , plugged th~- small orifices in the components. In addition, several filters RP%12~.ssi~
fl.81'10§ are installed downstream of the air regulators in the high pressure air system rather than upstream. of them.
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~
24 Identify and describe the One valve CV-3025 (high risk-significance AOV, see item 21),
con.t'd. most common recurring used for shutdown cooling, failed in 1978 and again in 1981 in
- maintenance problem(s). single-failure incidents that led to boiling, or near-boiling and failures regarding conditions in the reactor. 9.usiQg shutdown. Altl=leugl=I tl=le fr~
AOVs and the air valve ~fta:sjbeen modified\p.rovided with a hand. wb~en. and system. (Continued) has not failed since 1981 U. tl=le quality eHl=le aiF ifl tl=le aiF system is suspect, afld tl=leFef.eFe, se is tl=le petefltial peFfmmaflce ef tl=lis
'o"alve. This AOV is .rnP~ ettty-stroked g,l:lciftID'.l~to1,sati5,W~SfVl~4
~r-:.rsr©rv1-r9*a*a.,...._,.....,..
, . I w:. . at,. , *. 1.reg rnr:em.~n
- t~ s*. duFiFIQ sl=lutdewfl wl=lefl it is called upeFI te epeFate:;;gr;eY,!Pll,S!~©\¥~3;e,~~&;1wc:1s;;strQJ<~~or12CJ
§9'lo7iS'n]ftaowrn~fre'g1rJen'cy:.:i]See item 6 in this table for additional information concerning the history of this AOV.
The Compressed Air System SSDC provides detailed information on the *licens.ee's assessment of the Palisades air systems. tr~s:swJ~J'\reQ~r:,t:v~;:is1;Cife,:5ig Q~'qrier:tte'.Cf;;ancts.w,<:>1;11a~,rn()t fiave?ii1CluaecJ~tlie-'.@Xli::3:0~5;:eyent~
,.,,.,r;i;d *~!-*'iin'>--- '** ~*- ,. * ""* ;o;o:"i* 1 *,,,,, **on***i**.*;:;;; *,, .. ""I It was F1eted tl=lat tl=le CV 3025
- ~*a Ive ~ttas Flot meF1tieF1ed ifl Attacl=lmeflt B ef tl=lat FepeFt, wl=licl=I descFibes aiF system fuF1ctieF1al r=equiFemeF1ts.
(Continued on next page.)
~ . - *'* .. .
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24 Identify and describe the Several SOV related events have occurred. One event of cont'd. most common recurring interest, documented in LER 25592007, occurred on February 5, maintenanee-probl~m( s) 1992 while the plant was operating at 100% power. As a result of and failures regarding an ongoing EquipmentJ;l~~-~ification (Q-list) review program it AOVs and the air was determined that the marn-slearfi"isolationvalve,(MSIV) system. (Continued) actuator solenoid valves could be rendered inoperable by a main steam line break outside of containment. There were several contributing factors related to the cause of the MS IVs solenoids not meeting the EQ rule (10 CAR 50.49) requirements regarding 1
electrical isolation: -
- The redundant set of solenoid valves were installed in a non-harsh environment to ensure that the main steam isolation valves would still close in the event of a main steam line break outside of containment. This modification, however, used the same power source as the original SOVs without ensuring appropriate isolation of non-qualified equipment on the power circuit. This resulted in the second set of solenoid valves not being completely redundant.
- In 1981 the plant environmental qualification (EQ) project evaluators believed the FSAR to be correct. They failed to realize that the FSAR was incorrect and that the non-harsh environment solenoid valves were truly not redundant. Based on the erroneous information the MSIV solenoids were removed from the EQ list.
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24 Identify and describe the Another event that described inadequate environmental cont'd. . _most common recurring qualification of SOVs which are piece-parts of AOVs is mairftenance problem(s) documented in LER 25592016. SOVs and position switches for and failures regarding the* confrbl'valves*Which.,CQIJtrol the service water flow from the AOVs and the air CCW Heat Exchangers were not *environmentally.. qu~llfie_d in system. (Continued) accordance with 10 CAR 50.49. SOVs SV-0823A, SV-OB23E(.
SV-0826A, SV-08268, .and position switches POS-0823 and POS-0826 provide control and indication for control valves CV-0823 and CV-0826 which control the service water flow from, the CCW Water Heat Exchangers E-54A and E-548, respectively. These components were not qualified for a high- **
energy line break outside containment and were not on the EQ . \
list. Furthermore, they were not electrically isolated from environmentally qualified. instruments*in the same electrical scheme.
The root cause for this event was attributed an inadequate engineering analysis.
25 Interviewer comments We did not have time to view specific AOVs in the plant itself, regarding actual valves however, we saw several AOVs in a tesUtraining facility and viewed during the visit, in viewed diagnostic testing devices that the plant uses.
the plant, undergoing maintenance or replacement, or in the plant stock system, if applicable to this interview.
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26 Has the plant made In the specific case of CV-3025, a handwheel was added as an changes to valves or emergency operation measure.
systems-that include.
AOVs, or replaced AOVs Based on poor performClnc~ o~ the original valves 'c;lr;t'(;IA~S;.a_~r¢sult with different models of ~{itl}e,i;@.Uj~~DP~~(~Q!lJ!,f~VJJ~~:g;B:-211?;?;:~'.';~lfP,~, several solenoid AOVs or different valves valves throughout the plant were replaced with different models.
that are not AOVs? If ffialisaaes' fias**maae~'cna*n*ges**f0 tlie'8if 1S~SfemasdCfeserilDe'aFiij so, describe the changes r'{ . . . ' .. , t;:,', z~:' > ,f,",.,;, e* f: ,?*_/;,': . .,} ;:_~--~'-: <'ij,~-:-,, . . :~*~& k ** ~ ;,,.<',.~;;~.,>,
and the circumstances. ~ftaeflment~4~
I' i,' ' 1- . . . '~ -\1' "f What prompted the change?
Was the change made -
for this plant only?
27 Does the plant follow Industry guidance, including EPRl/NMAC guidelines, are EPRl/NMAC guidelines consulted when formulating plant* procedures. Explicit for maintaining AOVs compliance with industry guidance could not be determined.
and the air system(s)? If Palisades is part of an EPRI pilot program on AOVs similar to the not, describe differences one described to us in more detail at Fermi 2, and i[-su~irng~Jfji'g and reasons for the based etl EPRl's Performance Prediction Program devised for differences. Provide motor-operated valves. l?t?Us~~~s;'ana~~RBl~arn~ir;ivl:>l~eo:~1o;;;a reference information, if pp11~-~2r~tiye::~~r~em.e.1";1t<tq;~e-g~1,e,m,\:<;t~gm.Jllei~.i$C~q),!4 possible. cal ti:. cu latio.nsJ
~, .~~I *~;tlli**~
EPRI is previditlg futlditlg fer atlalyses ef tne desigtl ef A9Vs at Palis,~des.
28 What is the plant doing See item 27.
or planning to do in response to the recent Industry correspondence on AOVs. Provide reference information, if possible.
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29 Do you have any Plant engineers discussed several updates to the air system that sugg~st!_c;ms for had been proposed to management to improve air quality and improving the the.~ubsequent performance of air-operated equipment. Among performance of AOVs, those-wenfinstallation,,ofa m!ilaCelJleAti FeduAdaAt dryer forthe particularly in the areas instrument air system and relocatiorroffilters"in"the-high _
of surveillance, testing, or pressure air system. He~te~eF, plaAt maAa~emeAt rejeeted t~e -
maintenance? pmpesal te add a FeduAdaAt dl)'eF. The licensee has still Aet relocated BJQSJ~qn]the high-pressure air system filters. tl:'lat Were feuAd te be downstream of the air regulators ~fl~~U:te;~te!Jl~ifliM mtef'11r,elo<<~ati()ns;!~_ret,s,~.~JJJ~q~t~~.~:;:~o-r:rP-'l~te*a~t5.e(Qr,~2t~~1 t1i~:a9](see item 24).
30 Provide a list of 1O CAR None provided beyond the LERs previously found by 50.59 and 10 CAR 50.72 AEOD/INEEL.
reports on AOVs and AOV support systems (air or inert gas supply, etc.) that have been issued for this plant.
31 What thrust or torque A number of "20%" was discussed as an acceptable margin.
margins are expected for Details on existing margins for AOVs were not provided.
AOVs? Are different margins used for safety- Note: This question was asked to get an idea of what engineers related, important non- considered to be an acceptable margin. There was no attempt to safety-related, or non- establish any sort of commitment to a particular value.
safety-related AOVs? --
32 What maintenance or Sarweillance"omcontaimmentiiisolatidntivalve.~a*cearrn'eilato'rsra'r:e
~'>* ;:);i;:i-.- ~ .* ;l:i * * > 'we'***~""- ~'~ :;.,;-. ,._, ';:; N"<Pr*~"~ ;j "';;:i:""* <-v =w<".<'jO ' " ,,.-. * ,.,,,.,,,*,,,,, "*"'*.:O ';;,'~ *~::;:; "> *"'""_,.,,;,, .~** *;i ""°" /._,_ ..,_,~ .,,,..,.,..,.,~
surveillance is done to P-enQ'r:m*e-~r.eve'!lYJ:q_Otf)ge: 111,~ccem'l!Jlator:+l~R\ag~~.is;_i;n9r:uto.r,~at~a111a;*-
AOV accumulators to JrerJ'Cf~!;~~~fffie~t¢_$t1ngrva1iaates;,Jffi_at~tffie#ac_cl!lmCJlatorf'¢pnm:iairataim~
ensure air/nitrogen Jti~-~MaJve.4,efo~eQ£{or~t,1P,.~t~;iffip_u[s:.! Ne suFveillaAee. Seismic quality and pressure? design is in accordance with the- design basis and FSAR Were seismic commitments.
considerations and size verified?
INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 19 DRAFT April 26,1999
TOPICS TO REVIEW FOR AIR OPERATED VALVE STUDY SITE VISIT TO THE PALISADES NUCLEAR PLANT ITEM INFORMATION RESPONSE OR INFORMATION No.
~
33 Describe pro~lems with A significant and recent event of interest was the eemmeR pressure regulators, if eausefeemmeR made failure of pri~ flffle-high-pressure air any. regulat_()[~ caused by contaminationfrom rust in the air lines.
This situation -w-a-s~-originally=reR,q_r:t~Q to AEOD in April 1997 but was not covered by an LER. The conclusibnwas thaUh~=high pressure air system ~Q.!:Jl~t_o,rs,;w~,r~LQPt~t[~iQgqt!ll.9i,IDtaineQ1:~_ril~.
~J~:neq~1ger~t~y~r;ltt~.r~~:)recor:nmeJ1~i,tior:rs!,]was -,,,et deliveFiRS*
eleaR aRd df}' aif te u,e .equi13meRt it serves. >/'le belie*'e tf:lat tf:lis is a sisRifieaRt eemmeR eause failufe aRd iRdieates tf:le 13reseRee ef eeFrnsieR pl=eduets iR tf:le aif system.
34 Describe problems with Not discussed.
feedwater regulating valves, if any.
35 What, if any, is your Gary Foster and Bob Gambrill are active participants in the AOV involvement with the Users Group.
AOV Users Group?
Describe. Palisades personnel made presentations regardi_ng diagnostic t esf1nIQ at th e AUG . ""'""'
__ ,,.,,_, ..... , meef 1nIQ s*..
INEEL/EXT-98-003 83 Appendix C, Trip #3, Page 20 DRAFT April 26, 1999
ATTACHMENT 4 CONSUMERS ENERGY COMPANY PAllSADES PLANT DOCKET 50~255- -.*
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REVIEW AND COMMENlS ON DRAFT iREP.PR1f "EVALUATION OF AIR-OPERATED VALVES AT U.S. LIGHT.:WATER 'REACTORS" ADDITIONAL SUPPORTING INFORMATION ON IMPROVEMENTS TO THE AIR SYSTEM 3 Pages
ADDITIONAL SUPPORTING INFORMATION ON IMPROVEMENTS TO THE AIR SYSTEM Significant improvements have been made to the Instrument Air System since 1978. A chronology of enhancements and list of operational improvements is provided below.
The Instrument Air System is currently rated as satisfactory and stable on the most recent Palisades System Health Report.
- 1. Reversed the Inlet and Outlet piping to the Air Receiver Tanks to place the Outlets at the top of the tanks (1978 Specificatio"n Field °Change ~FC-78-100).
- 2. Installed air line blowdowns to remove accumulated moisture and foreign particles (1979 Specification Field Change SFC-79-046). Air Receiver Tanks were supplied with auto drain traps.
- 3. Replaced Instrument Air Dryer (M-2) with a neaFlike for like purge replacement (1981 Specification Field Change SFC-81-130).
- 4. In 1986, FC-684 installed a new larger (300 scfm capacity) electrical desiccant heater air dryer. The new dryer has almost twice the capacity of the normal plant air flow. This FC also installed pre and post filters with the pre filter being a coalescing filter with drain valves on a timer.
- 6. In 1986, FC-694 installed blowdown taps at selected low points on the Instrument Air lines.
- 7. In 1987, FC-722 installed 5 Nitrogen Stations as backup to Instrument and High Pressure Air Systems.
- 8. In 1988, FC-801 replaced one of the three Instrument Air Compressors with a high capacity compressor to supply-full plant load. This provided a second train of Instrument Air. Previously, two of three compressors were required to be in operation. *
- 9. In 1996 Palisades replaced the Instrument Air After Coolers and Separators (E-18 A and C) and initiated an annual preventive maintenance cleaning activity on the after coolers associated with Instrument Air Compressors C-2A and C-2C.
These repairs/replacements have resulted in much better moisture removal. The after coolers are maintained in continuous service when C-2A or C-2C is in operation.
- 10. In 1996, C-2A and C-2C were placed in continuous operation to take advantage of the moisture reduction of the Instrument Air Aftercoolers (E18A & C).
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ADDITIONAL SUPPORTING INFORMATION ON IMPROVEMENTS TO THE AIR SYSTEM
- 11. In 1996 the piping was sloped to ensure moisture would accumulate in the air receiver tanks where an auto drain system was previously installed to facilitate moisture removal. Hanger adjustments and pipe modifications were performed.
- 12. lnstrumef)t Air dew point is checked once per year by PPAC X-CHEM208. At atmospheric -pres-sure the dew poi_nt is -95° F. When adjusted for line pressure, the dew point is approximately 0° F. Palisades is very comfortpbl_e with the dew point for the very limited amount of time that the Instrument Air Dryer (M~2) is out of service for maintenance. During winter months Service Water temperatures are low (32° F to 40° F) keeping the aftercoolers air discharge temperature below 40° F, this condition will provide drier air to the plant instruments. This is the best time to perform annual M-2 maintenance, provided Instrument Air Aftercoolers E-18A and E-18C are in service. *
- 13. The M-2 Instrument Air. Dryer crystals are inspected daily by Operations I Systems. The crystals color (blue or pink) indicate dryer performance.
- 14. Instrument Air System low points are blown down monthly. No moisture has been observed during these activities.
- 15. New after coolers initially produced more particulate material entering the prefilters. This is now trending down. This was an initial result of sending drier air from the compressors to the M-2 Air Dryer.
- 16. lnstrum~ntAii\ System leakage/usage since 1995 has been drastically reduced.
The systenJ tl¢jW rate went from 260 scfm to a total flow of 190 scfm.
- 17. Particulate size and moisture content of Instrument Air are well within specifications. Redundant coalescing prefilters with drain timers and redundant one micron post filters (one pre and post filter) are always in service.
- 18. We do not presently have a dual air dryer. Palisades understands the limitations of this design and maintenance is scheduled during periods of drier/cooler weather and cooler lake temperature.
- 19. Instrument Air Aftercoolers E-18A and E-18C are cleaned every year during annual PMs on the compressors. This has resulted in cleaner and drier service air to the Instrument Air Dryer (M-2). Palisades also observed improvements in M-2 performance and reliability and a reduction in maintenance of the M-2 switching valves.
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ADDITIONAL SUPPORTING INFORMATION ON IMPROVEMENTS TO THE AIR SYSTEM Summary The Palisades Instrument Air System is significantly improved from the Instrument Air System of the early 1980's. Since these operational changes, the monthly blow downs of-Instrument Air have resulted in less moisture being seen in the system. Instrument air low points have not generated any trapped moisture and measured dew points are exceptional. -
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