Part 21 Report - 1997-342
ACCESSION #: 9706040214
Manufacturers of
Automatic Switch Co. DEPENDABLE CONTROL
Since 1888
FLORHAM PARK, NEW JERSEY 07932 o N.J. (201) 966-2000 / N.Y. (212)
344-3765 FAX-966-2628
May 27, 1997
U.S. Nuclear Regulatory Commission
Washington, DC 20555
ATTN: Document Control Desk
SUBJECT: Potential Safety-Related Problem with ASCO HV 266000-007J Scram
Solenoid Pilot Valves
Dear Sir:
This will provide you with additional information related to my letter of
April 29, 1997, concerning the potential safety-related problem with ASCO
HV 266000-007J scram solenoid pilot valves (SSPV's).
BACKGROUND:
During performance maintenance testing (PMT) of the SSPV's at Oyster
Creek, it was discovered that there was air leakage from some of the
SSPV's (V118 valves). The PMT was being performed after the SSPV's
had their diaphragms changed to the new diaphragm material which
addressed a slow scram insertion time issue. Upon further
evaluation of the cause of the air leakage, it was discovered that
the air leakage was from hardened core discs in the SSPV pilot
heads.
PROBLEM CAUSE:
A General Electric (GE) / Automatic Switch Company (ASCO) joint
investigation identified the cause of the problem to be the use of
incorrect core disc elastomer material. Specifically, the core disc
elastomer material should have been Fluorocarbon (Viton) but was
identified as a commercial grade Nitrite (BUNA-N). Material
examination of 261 SSPV pilot heads returned from Oyster Creek
identified that the incorrect Nitrite material was provided in 44
pilot heads while the correct Fluorocarbon material was provided in
217.
AFFECTED PLANTS:
On the basis of ASCO's investigation, we are now reasonably
confident that the total suspect population is 1000 SSPV's. GE/ASCO
identified a total of six plants that received the suspect SSPV's
with the following distribution:
Oyster Creek 300 Peach Bottom 10
Monticello 260 Brown's Ferry 5
Quad Cities 372 Fitzpatrick 53
POTENTIAL SAFETY IMPACT:
GE/ASCO identified two potential performance impacts that could
result from the hardened Nitrite (BUNA-N) core discs:
U.S. Nuclear Regulatory Commission -2- May 27, 1997
1. Disc Fragmentation - No significant impact on Control Rod Drive
(CRD) performance as a direct result of the air leakage has
been identified. However, a severely degraded disc could
fragment and pieces could restrict the air flow path and delay
the start of motion of the drive. It could be postulated that
a piece of the fragmented disc could completely block the air
flow and prevent a scram of that drive. However, this is very
unlikely because complete blockage of the air flow path by the
brittle Nitrile (BUNA-N) fragments would be very difficult to
accomplish. GE's licensing basis analyses already assumes that
one control rod does not insert. Failure of more than one CRD,
due to all causes, would have to occur before a safety concern
would exist. Even in this highly unlikely event there is scram
backup from the Backup Scram Valves and the Anticipated
Transient Without Scram Alternate Rod Injection Valves which
will insert control rods at a slower rate. However, if the
affected plants follow the recommendations provided by GE
(summarized below), replacement of the suspect pilot valve
assemblies (top halves of the SSPV's) should take place well
before disc fragmentation can occur.
2. Rod Drifting - While very unlikely, one or more CRD's might
exhibit rod drifting if air leakage becomes severe as a result
of hardened discs. On the basis of previous drifting rod
insertion events at BWR's, potential rod drifting would have
little impact on plant safety.
RECOMMENDED CORRECTIVE ACTION FOR AFFECTED PLANTS:
GE and ASCO conducted tests to characterize the aging profile for
the commercial grade Nitrile (BUNA-N) discs. Chemical, physical,
and accelerated thermal aging tests on the commercial grade Nitrile
material provided a performance capability comparison to nuclear
grade Nitrile (BUNA-N) that was used in predecessor ASCO supplied HV
90405 SSPV's for many years. The base polymer of both materials is
essentially the same and both materials have almost identical levels
of Butadiene and Acrylonitrile. On the basis of these tests, it was
conservatively determined that the incorrect core disc material
would have a predicted acceptable service life of three to four
years.
GE provided a Justification for Continued Operation (JCO) to the
affected plants which still have SSPV's from the suspect 1000 piece
lot installed. It recommended that pretested pilot valve assemblies
(top halves of SSPV's) be installed on all suspect valves before
they reach the predicted three to four year end-of-life. The JCO
also recommended augmented air leakage testing be considered by the
plants until the change-out can be completed. As the disc material
hardens, air leakage will substantially precede any significant SSPV
performance degradation. Leakage can only be identified for the VI
18 valves and not the V117 valves on each Hydraulic Control Unit
(HCU). The JCO advised that any leakage should be considered an
indication that the suspect SSPV contains a Nitrile (BUNA-N) disc
which may be approaching its end of life limit. It further advised
if leakage occurs consideration should be given to replacing all
SSPV's in the suspect population.
ASCO INVESTIGATION RESULTS:
An investigation was conducted by ASCO to determine how and when the
core assemblies were manufactured using the incorrect commercial
grade Nitrile (BUNA-N) discs. Two possible scenarios were
identified:
U.S. Nuclear Regulatory Commission -3- May 27, 1997
1. Records indicate that several orders for core assemblies
containing commercial grade Nitrile (BUNA-N) discs were being
manufactured in the core assembly area at ASCO's Aiken, South
Carolina facility at the time the suspect lot of nuclear grade
core assemblies were being manufactured. These commercial
grade core assemblies would have been produced on the same
equipment used to assemble the nuclear grade core assemblies,
making contamination of the nuclear assemblies a possibility.
2. It was found that during the time of manufacture of the core
assemblies for the suspect 1000 SSPV lot, the incorrect
commercial grade BUNA-N discs were stocked in a location
directly adjacent to the nuclear grade Fluorocarbon (Viton)
discs at ASCO's Aiken, South Carolina facility. A stockroom
pulling error could have occurred as a result of this adjacent
location.
With either scenario, the likelihood of repeat occurrences on other
nuclear lots is minimal. In the case of the possible stockroom
pulling error, the nuclear stocking area was relocated prior to
withdrawals for assembly of the next nuclear grade core assembly
lot. Additionally, inspection of 184 SSPV's from the next 1000
piece manufacturing lot of nuclear grade core assemblies showed all
to contain the proper Fluorocarbon (Viton) material.
There are a number of inspection steps in the SSPV manufacturing
process to ensure correct materials are used in SSPV's. These
include:
1. Lot/batch recording and tracking of elastomer components
including the subject core disc from receipt of the material,
through the manufacture of sub-assemblies, to the final
manufacture of the SSPV.
2. First piece sample inspection for correct materials (by color
code for the disc) at the manufacturing step where the disc is
inserted into the core.
3. Sample final inspection of the core assemblies at completion of
the manufacturing run.
4. 100% inspection of the core assemblies (for critical dimensions
and assembly color code) prior to final manufacture of the
SSPV's.
Unfortunately, none of the controls, all of which were in place at
the time of manufacture of the suspect 1000 piece SSPV lot, would
have detected the postulated stockroom pulling error.
ASCO CORRECTIVE ACTION
In order to preclude any recurrence of the above described problem
and similar problems with ASCO's SSPV's, the following corrective
actions have been taken:
1. All elastomer components are now 100% checked (by color code
and durometer) prior to the start of sub-assembly manufacture.
2. Q.C. audits are now performed at completion of sub-assembly
processes to ensure that all excess material is removed from
the area at the completion of each job.
3. An accounting process has been added as part of all nuclear
elastomer stock picks.
4. Only stockroom supervisors and lead people are now allowed to
pick components from the nuclear stockroom.
U.S. Nuclear Regulatory Commission -4- May 27, 1997
5. Destructive testing sample size has been increased from a
maximum of two pieces to five pieces during receiving
inspection (from the vendor) prior to release of nuclear
elastomer materials to stock.
It has always been ASCO's goal to maintain full compliance with all
applicable NRC rules and regulations and to provide the best possible
products to the nuclear industry. We believe the above actions are in
accordance with this goal and are more than adequate to address this and
similar problems. Please feel free to contact me at 201-966-2100 for
additional information.
Sincerely,
AUTOMATIC SWITCH COMPANY
Randy P. Smith
President
RPS/ja
CC: General Electric
GPU Nuclear - Oyster Creek
David Skeen - U.S. NRC
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