Part 21 Report - 1997-103
ACCESSION #: 9703070014
GENERAL INFORMATION or OTHER EVENT NUMBER: 31879
LICENSEE: ENERTECH NOTIFICATION DATE: 03/03/97
CITY: BREA REGION: 4 NOTIFICATION TIME: 16:45 (ET]
COUNTY: STATE: CA EVENT DATE: 03/03/97
LICENSE#: AGREEMENT: Y EVENT TIME: 00:00[PST]
DOCKET: LAST UPDATE DATE: 03/03/97
NOTIFICATIONS
NRC NOTIFIED BY: JOHN DEKLEINE VERN HODGE, RVIB NRR
HQ OPS OFFICER: LEIGH TROCINE
EMERGENCY CLASS: NOT APPLICABLE
10 CFR SECTION:
CCCC 21.21 UNSPECIFIED PARAGRAPH
EVENT TEXT
10 CFR PART 21 NOTIFICATION REGARDING HIGH FAILURE RATES OF BW/IP
(FORMERLY BORG-WARNER) PRESSURE SWITCHES INSTALLED ON BW/IP
ELECTRIC-
HYDRAULIC ACTUATORS USED IN THE GAS TREATMENT, SERVICE WATER, AND
HEATING
AND VENTILATION SYSTEMS AT NINE MILE POINT UNIT 2 (REFER TO EVENT
#31822
FOR ADDITIONAL INFORMATION.)
ON FEBRUARY 20, 1997, NINE MILE POINT UNIT 2 MADE A NOTIFICATION TO THE
NRC REGARDING THE EXISTENCE OF A DEVIATION OR NON-CONFORMANCE
CONDITION
IN A BASIC COMPONENT THAT WAS REPORTABLE UNDER 10 CFR PART 21
GUIDELINES.
THE BASIC COMPONENT WAS IDENTIFIED AS A SAFETY-RELATED PRESSURE
SWITCH
SUPPLIED BY BW/IP THAT MAY BE IN ONE OF FIVE PART NUMBERS, AND THE
REPORT
SITED A HIGH FAILURE RATE OF THESE PRESSURE SWITCHES.
ENERTECH AND BW/IP ARE CURRENTLY INVESTIGATING THIS ISSUE. ENERTECH
IS
ALERTING ALL POTENTIALLY AFFECTED CUSTOMERS OF A REPORTED
SAFETY-RELATED
BASIC COMPONENT THAT IS CURRENTLY BEING INVESTIGATED BY NINE MILE
POINT
UNIT 2 UNDER 10 CFR PART 21 GUIDELINES. SINCE ENERTECH WAS NOT PART OF
THE NINE MILE POINT EVALUATION PROCESS, ENERTECH HAS ALSO REQUESTED
HARDWARE AND DOCUMENTATION FROM NINE MILE POINT PERSONNEL FOR
BW/IP
EVALUATION OF THE STATED SITUATION. ADDITIONALLY, ENERTECH
REQUESTED
FEEDBACK FROM POTENTIALLY AFFECTED CUSTOMERS.
(REFER TO THE HOO LOG FOR CONTACT NAMES AND TELEPHONE NUMBERS.)
FAX TRANSMITTAL SHEET
Page 1 of 2
Date: March 3, 1997
ENERTECH
2950 Birch Street, Brea, CA 92621, USA
Telephone (714) 528-2301 / Fax (714) 528-0128
TO: Mr Greg Cwalina FROM: John DeKleine
Vendor Inspection Branch Director Quality Assurance
COMPANY: Nuclear Regulatory Comm. TELEPHONE: 301) 415-2983
Washington, DC
FAX NO.: (301) 816-5151 Receipt Confirmation Requested
[]YES []NO
SUBJECT: NRC Notification REFERENCE: Niagara Mohawk, Nine
Mile Unit 2
DER # 2-96-3145
I have enclosed a letter from Enertech for your information. Enertech is
alerting all potentially affected Customers of a reported safety related
basic component that is currently being investigated by NMPC-NM Unit 2
under 10 CFR Part 21 guidelines. Since Enertech was not part of the Nine
Mile evaluation process, We have requested hardware and documentation
from Nine Mile personnel for BW/IP evaluation of the stated situation.
Additionally we requested feedback from our potentially affected
customers from the following inquiry: "If your facility has experienced
and documented similar situations related to the statements made in the
Nine Mile report, Enertech would appreciate someone from your facility
contacting us to discuss that information".
ENERTECH
ENERTECH Solutions for Today... Standards for Tomorrow
(714) 528-2301
2950 Birch Street, Brea, CA 92821-6235
FAX (714) 528-0126
March 3, 1997
Nuclear Regulatory Commission
Operations Center
RE: Niagara Mohawk Power Corp. Nine Mile Unit #2, Part 21 Notification,
Report # DER 2-96-3145 High Failure Rates of BW/IP Pressure Switches
Installed on BW/IP (formally Borg Warner) Electric-Hydraulic
Actuators used In GTS, SWP, and HVK systems.
On February 20, 1997 Niagara Mohawk Power Corporation, Nine Mile Point
Unit #2, submitted to the NRC Operations Center their sixty (60) day
evaluation report. Whereas in that evaluation, in Nine Miles' opinion, a
deviation or non conformance condition exists in a basic component that
is reportable under Part 21 guidelines. The basic component is
identified as a Safety Related Pressure switch supplied by BW/IP that may
be any one of five (5) part numbers.
The report sites a "High Failure Rate" of the pressure switches.
Enertech and BW/IP are investigating this issue. Enertech has requested
from Nine Mile additional items for BW/IP evaluation. This evaluation
will determine specific effected part numbers, failure mechanism, and
failure history. The report will be available 30 days from receipt of
the requested Nine Mile items that will address the specific issues
raised by Niagara Mohawk Nine Mile Unit #2 Facility personnel.
In the past pressure switch issues have been crossed with reference to
maintainability, adjustability, and long term reliability. Enertech and
BW/IP have been proactive in addressing these issues by developing a new
qualified switch that is easier to set and maintain. In 1994 BW/IP and
Enertech introduced this newly qualified switch as a replacement. These
upgrade kits have been installed and the customer feedback supports the
successful mission of the new switch. Conversely some sites specifically
request the original switch as a replacement claiming they continue to
operate acceptably in their application.
If you have questions or need additional information. Please contact me
at your convenience at Enertech (714) 528-2301 extension 200.
Sincerely.
Frank U. Erlach
President
Doc #: 95351.1
POWER REACTOR EVENT NUMBER: 31822
FACILITY: NINE MILE POINT REGION: 1 NOTIFICATION DATE: 02/20/97
UNIT: [ ] [2] [ ] STATE: NY NOTIFICATION TIME: 15:13 [ET]
RX TYPE: [1] GE-2,[2] GE-5 EVENT DATE: 02/18/97
EVENT TIME: 14:30[EST]
NRC NOTIFIED BY: K. LAMPMAN, M. McCORMICK LAST UPDATE DATE: 02/20/97
HQ OPS OFFICER: LEIGH TROCINE
NOTIFICATIONS
EMERGENCY CLASS: NOT APPLICABLE
10 CFR SECTION: LARRY NICHOLSON RDO
CCCC 21.21 UNSPECIFIED PARAGRAPH
VERN HODGE, RVIB NRR
UNIT SCRAM CODE RX CRIT INIT PWR INIT RX MODE CURR PWR CURR RX MODE
2 N Y 100 POWER OPERATION 100 POWER OPERATION
EVENT TEXT
10 CFR PART 21 NOTIFICATION REGARDING THE EXCESSIVE FAILURE RATE OF
BORG-WARNER (BWIP) PRESSURE SWITCHES USED IN THE GAS TREATMENT,
SERVICE
WATER, AND HEATING AND VENTILATION SYSTEMS (REFER TO EVENT #31879
FOR
ADDITIONAL INFORMATION.)
SEVERAL BWIP PRESSURE SWITCHES FAILED DURING OPERATION AND INITIAL
CALIBRATION, AND AN EVALUATION CONCLUDED THAT THE SWITCHES ARE
UNABLE TO
MAINTAIN THE CORRECT RESET POINT WHEN THE SETPOINT IS ADJUSTED.
ACCORDING TO THE MANUFACTURER, THE SUBJECT SWITCHES DO NOT HAVE
AN
ACCURATELY ADJUSTABLE RESET VALUE. THE RELATIONSHIP BETWEEN THE
SETPOINT
OF THE SWITCHES AND THEIR RESET POINT IS NOT LINEAR NOR CONSISTENT
BETWEEN DIFFERENT SWITCHES OF THE SAME MODEL. THEY ARE DESIGNED TO
OPERATE WITH A MAXIMUM SETPOINT AND MINIMUM RESET WINDOW ONLY.
AS A
RESULT, THE SWITCHES ARE NOT CONSISTENTLY ABLE TO BE INITIALLY
CALIBRATED
TO THE DESIRED SETPOINT; AND ONCE INSTALLED AND CALIBRATED, MINOR
SETPOINT DRIFT MAY PLACE THE SWITCHES OUTSIDE THEIR ACCEPTABLE
TOLERANCES.
THERE ARE A TOTAL OF 40 QUESTIONABLE BWIP PRESSURE SWITCHES
INSTALLED IN
THE PLANT (22 IN THE GAS TREATMENT SYSTEM, 6 IN THE SERVICE WATER
SUPPLY
TO COOLERS AND CHILLERS, AND 12 IN THE CONTROL BUILDING VENTILATION
SYSTEM). EACH OF THE ASSOCIATED VALVES HAS TWO OR THREE OF THE
SWITCHES
WITHIN ITS HYDRAULIC CONTROLS. THE TYPE OF FAILURE ASSOCIATED WITH
THE
SWITCH DEPENDS ON WHICH SWITCH HAS FAILED. THE EFFECTS OF A FAILED
SWITCH CAN BE A VALVE FAILING TO OPEN AND BEING UNABLE TO CLOSE OR A
VALVE FAILING CLOSED AND BEING UNABLE TO OPEN.
THE LICENSEE PERFORMED AN OPERABILITY DETERMINATION AND CONCLUDED
THAT
THERE IS REASONABLE ASSURANCE THAT THE SWITCHES WILL OPERATE AS
REQUIRED.
(Continued on next page)
FACILITY: NINE MILE POINT PAGE # 2 OF EVENT NUMBER: 31822
THIS DETERMINATION WAS BASED ON SUCCESSFUL INITIAL CALIBRATION
TESTING,
POSITIVE TEST DATA OF INSTALLED CALIBRATIONS, AND IMPLEMENTATION OF
ADDITIONAL ADMINISTRATIVE CONTROLS TO SHORTEN THE CALIBRATION
FREQUENCY.
THE LICENSEE HAS BEEN IN CONTACT WITH ENERTECH (THE VENDOR) IN
CALIFORNIA
AND WITH BORG-WARNER (THE MANUFACTURER). THE LICENSEE ALSO
BELIEVES THAT
ENERTECH HAS BEEN IN CONTACT WITH THE NRC.
THE LICENSEE PLANS TO NOTIFY THE NRC RESIDENT INSPECTOR. (REFER TO
THE
HOO LOG FOR SITE CONTACT TELEPHONE NUMBERS.)
NIAGARA
MOHAWK
NINE MILE POINT NUCLEAR STATION
P.O. BOX 63, LYCOMING, NEW YORK 13093
FAX COVER LETTER
NINE MILE POINT UNIT 2
FROM: FAX TELEPHONE NUMBER: (315) 349-1400
NAME:
DEPARTMENT: LICENSING/ENVIRONMENTAL
TELEPHONE NUMBER:
FAX #
TO:
TOTAL NUMBER OF PAGES FAXED (INCLUDING COVER LETTER):
DATE: TIME:
MESSAGE:
ENCLOSURE 1
EVALUATION OF DEVIATION, DEFECT, FAILURE TO COMPLY FORM
PART I - REPORTING
Nine Mile Point 2 (Affected Unit) DER No. 2-96-3145
Date of Discovery 12/19/96
TYPE OF CONDITION
A. Deviation B. Defect
1. Basic Component () 1. Deviation ()
a. Structure () 2. Other Condition ()
b. System () C. Failure to Comply
c. Component () 1. Atomic Energy Act ()
d. Design () 2. Rule ()
e. Inspection () 3. Regulation ()
f. Testing () 4. Order ()
g. Consulting 5. License ()
Service
2. Other Condition ()
Description: Excessive failure rate of BWIP pressure switches used in the
GTS, SWP, and HVK systems.
PART II - EVALUATION CHECKLIST
A deviation related to a Basic Component or a failure to comply shall be
evaluated to determine if it presents a substantial safety hazard. A
condition is a substantial safety hazard if it causes a major reduction
in the degree of protection to the public. Criteria for determining
substantial safety hazards include: a) Moderate exposure to or release of
licensed material; b) Major degradation of essential safety-related
equipment; and c) Major deficiencies involving design, construction,
inspection, test or use of license facilities or materials (see NUREG-
302).
The following checklist is used to determine if a major reduction in
safety exists. If the answer is "yes" to any of the following, it may be
reportable per 10CFR part 21 and requires further evaluation.
NLAF-IRG-140
Page 10 Rev. 01
ENCLOSURE 1 (Cont)
PART II - EVALUATION CHECKLIST (Cont)
CONSEQUENCE YES NO
1. Exposures received in excess of 10CFR20
limits for immediate notification.
2. Exposure of an individual in an
unrestricted area in excess of 10CFR20
limits.
3. Release of radioactive material to an
unrestricted area in excess of 10CFR20
limits.
4. Exceeding a safety limit as defined in
the facility technical specifications.
5. A condition which could disable or prevent
operation of a system required for safe
shutdown, emergency core cooling, post
accident containment heat removal or post
accident containment atmosphere cleanup.
6. A condition which could disable or reduce
the safety margins for the reactor coolant
pressure boundary, core or reactor intervals,
functions or operation.
7. A condition which could disable or prevent
operation of the spent fuel storage pool
cooling and storage including the fuel racks.
8. A condition which could disable or prevent
operation of redundant Class 1E electrical
systems, including electric and mechanical
devices and circuitry.
9. A condition which could disable or prevent
operation of the reactivity control systems;
that is, control rods, control rod drives,
and boron injection systems.
10. A condition which could disable or prevent
operation of radioactive waste system that
could create offsite doses greater than Part
100.
11. A condition which could disable or prevent
operation of the primary and secondary
containment.
NLAP-IRG-140
Page 11 Rev. 01
ENCLOSURE 1 (Cont)
PART II - EVALUATION CHECKLIST (Cont)
CONSEQUENCE YES NO
12. A condition which could disable or
prevent operation of structures,
components, or systems whose continued
function is not required, but whose
failure could reduce or disable systems
that are required.
13. A condition involving the security
system which could cause a substantial
safety hazard.
14. Other deviations in Basic Components or
failures to comply which cause a substantial
safety hazard.
15. A condition that creates an unreviewed
safety question (10CFR50.59).
16. A condition which does not meet a rule,
regulation, license or order and crates
a substantial safety hazard.
PART III - EVALUATION (to be completed by Nuclear Licensing)
(check applicable category)
[ ] Condition does not meet criteria for a potential defect or failure
to comply because (attach additional sheets as necessary):
[ ] Condition does not involve a substantial safety hazard because
(attach additional sheets as necessary):
[x] Condition involves a potential substantial safety hazard (attach
additional sheets as necessary): See attached
[ ] Condition does not meet criteria for Potential Defect or Failure to
Comply, but is reportable under 10CFR50.9.
NLAP-IRG-140
Page 12 Rev. 01
PLANT: Nine Mile Point Unit 2 DER NO. 2-96-3145
TITLE: High Failure Rate - BWIP Pressure Switches
DESCRIPTION OF CONDITION:
Several BWIP pressure switches have failed during operation and initial
calibration. An evaluation has concluded that the switches are unable to
maintain the correct reset point when the setpoint is adjusted.
According to the manufacturer, the subject switches do not have an
accurately adjustable reset value. The relationship between the setpoint
of the switches and their reset point is not linear nor consistent
between different switches of the same model. They are designed to
operate with a maximum setpoint and minimum reset window only. As a
result, the switches are not consistently able to be initially calibrated
to the desired setpoint, and once installed and calibrated, minor
setpoint drift may place the switches outside their acceptable
tolerances.
The subject switches were supplied and recommended by the vendor as
replacement switches. The vendor is aware of the specific setpoints
associated with each switch part number ordered by Niagara Mohawk.
However, instead of providing switches designed to operate at the
specific setpoint and reset range for all switches of this type.
Each of the associated valves has 2 or 3 of the switches within its
hydraulic controls. The type of failure associated with a switch depends
on which switch has failed. The effects of a failed switch can be a
valve failing open and unable to close, or a valve failing closed and
unable to open.
For the HVK or SWP systems, due to their design and application, an
assumed switch failure would cause the associated valve to fail open.
SWP valves 2SWP*TV35A and 35B provide temperature control for the control
and relay room chillers. HVK valves 2HVK*TV21A, 21B, 22A, and 22B
provide individual temperature control for air conditioning units in both
the control room and relay rooms. If these valves were to fail,
control/relay room temperature could increase potentially beyond its
acceptable design range. Redundant air conditioning units are available
in addition to the ability to manually control cooling flow if required,
however, under design basis assumptions neither are credited as being
available.
For GTS (2GTS*MOV2A, 2B, 3A, 3B, 28A, and 2GTS*PV5A, 5B) should an
associated pressure switch fail by not actuating at the desired setpoint,
the setpoint overlap would prevent correct actuator response. Since the
subject valves are located on the entrance, exit, bypass and
recirculation lines around each Standby Gas Filter Train, the system may
not be able to perform its intended safety functions.
Notwithstanding the fact that all systems are designed redundant and the
ability exists to manually control flow around SWP valves 2SWP*TV35A and
35B, a deviation exists with the pressure switches for HVK, SWP, and GTS
systems that assuming the coincident failure of all switches or a second
unrelated single, failure (as required by the design basis and Part 21
guidelines), the presence of the switches created a substantial safety
hazard as defined by Part 21. Presently an engineering operability
determination is in place that documents reasonable assurance that the
switches will operate as required. This determination is based on having
passed initial calibration testing, positive test data trends of
installed calibrations and implementation of additional administrative
controls to shorten the calibration frequency.
This evaluation concludes that although operable at this time, under the
guidance of Part 21, the BWIP pressure switches are reportable.
NLAP-IRG-140
Page 13 Rev. 01
SWITCH PRESSURE, OPERATOR MODEL NUMBER 85430, 2GTS*MOV2A-ACT
ORIGINALLY SUPPLIED ON NMPC PURCHASE 2GTS*MOV2B-ACT
ORDER NOS. NMP2-P304Y. SPARE / REPLACEMENT 2GTS*MOV3A-ACT
PARTS ORIGINALLY SUPPLIED UNDER NMPC 2GTS*MOV3B-ACT
PURCHASE ORDER NUMBER NMP2-P304Y SHALL BE
QUALIFIED TO BORG WARNER TEST REPORT NUMBER
2125, REV B
SWITCH PRESSURE, OPERATOR MODEL NUMBERS 85960, 2GTS*MOV28A-ACT
86060, AND 86040, ORIGINALLY SUPPLIED ON 2GTS*MOV28B-ACT
NMPC PURCHASE ORDER NOS. NMP2-P304Y AND 2TCS*PCV115-ACT
NMP2-C051M, BWIP P/N 00739. SPARE / 2SWP*TV35A
REPLACEMENT PARTS ORIGINALLY SUPPLIED 2SWP*TV35B
UNDER NMPC PURCHASE ORDER NUMBERS NMP2-
P304Y AND NMP2-C051N SHALL BE QUALIFIED
TO BORG WARNER TEST REPORT NUMBERS 2125,
REV B AND 2140 REV A.
SWITCH PRESSURE, OPERATOR MODEL NUMBERS 85960, 2GTS*MOV28A-ACT
86060, 86080, AND 86040, ORIGINALLY 2GTS*MOV28B-ACT
SUPPLIED ON NMPC PURCHASE ORDER NOS. 2TCS*PCV115-ACT
NMP2-P304Y AND NMP2-C051M, BWIP P/N 2SWP*TV35A
86819. SPARE / REPLACEMENT PARTS ORIGINALLY 2SWP*TV35B
SUPPLIED UNDER NMPC PURCHASE ORDER NUMBERS
NMP2-P304Y AND NMP2-C051M SHALL BE QUALIFIED
TO BORG WARNER TEST REPORT NUMBERS 2125, REV
B AND 2140 REV A.
*** END OF DOCUMENT ***
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