NEIL Requirements for NEIL Requirements for Testing of FWH Electrical Testing of FWH Electrical

Equipment and AOV’sEquipment and AOV’s

• 2007 - STP self-identified nonrelated NEIL 2007 - STP self-identified nonrelated NEIL issue that resulted in repeat failure of a issue that resulted in repeat failure of a critical SSC.critical SSC.

• NEIL inspection coming up NEIL inspection coming up comprehensive comprehensive review of all requirements review of all requirements found this FWH found this FWH equipment issueequipment issue

• Communicate NEIL requirements regarding Communicate NEIL requirements regarding FWH electrical equipment/AOV testingFWH electrical equipment/AOV testing– NEIL has spent beaucoup dinero on DC Cook eventNEIL has spent beaucoup dinero on DC Cook event– Have shifted focus to protecting large assets (i.e. Have shifted focus to protecting large assets (i.e.

Main Turbine)Main Turbine)– OE31559 – Reference Nine Mile Point OEOE31559 – Reference Nine Mile Point OE

PurposePurpose

RequirementsRequirementsFeedwater Heater Alarms and InterlocksFeedwater Heater Alarms and Interlocks

·         Perform observation/Test/ Inspection/Surveillance of ·         Perform observation/Test/ Inspection/Surveillance of Integrity of Electrical Circuits/Heaters. Should ‘NA’, Shall 1 Integrity of Electrical Circuits/Heaters. Should ‘NA’, Shall 1 Fuel Cycle  LCS 2.2.5.3.2 - 2 (TG/Exciter – Operating Test) Fuel Cycle  LCS 2.2.5.3.2 - 2 (TG/Exciter – Operating Test) ·         Operating and testing to be conducted:  Integrity of ·         Operating and testing to be conducted:  Integrity of electrical circuitry and power supply for heater extreme high electrical circuitry and power supply for heater extreme high level alarms, controls, switches and interlocks by testing. level alarms, controls, switches and interlocks by testing.  Should – ‘NA’, Shall – ‘1 fuel cycle’     LCS Section 2.2.5.3.2 - 2  Should – ‘NA’, Shall – ‘1 fuel cycle’     LCS Section 2.2.5.3.2 - 2

Feedwater Heater Level Control Valves Feedwater Heater Level Control Valves ·         Perform observation/Test/ Inspection/Surveillance of ·         Perform observation/Test/ Inspection/Surveillance of Integrity of Electrical Circuits/ Valves.  Should ‘NA’, Shall 1 Integrity of Electrical Circuits/ Valves.  Should ‘NA’, Shall 1 Fuel Cycle  LCS 2.2.5.3.2 -3  (TG/Exciter – Operating Test) Fuel Cycle  LCS 2.2.5.3.2 -3  (TG/Exciter – Operating Test) ·         Operating and testing to be conducted:  Integrity of ·         Operating and testing to be conducted:  Integrity of electrical circuitry and power supply of all remote operated electrical circuitry and power supply of all remote operated heater drain and bypass valves by testing.  Should – ‘NA’, heater drain and bypass valves by testing.  Should – ‘NA’, Shall – ‘1 fuel cycle’     LCS Section 2.2.5.3.2 - 3 Shall – ‘1 fuel cycle’     LCS Section 2.2.5.3.2 - 3

Typical Heater Drain SystemTypical Heater Drain System

• Normal Level Control Valve• High Level Dump• May be digital or Analogue

Typical Heater Steam Side IsolationTypical Heater Steam Side Isolation

• Level Switches that:• Shut off Extraction Steam• Shut off previous FWH flow• Shut off Blowdown flow

Typical Tube Side Isolation SystemTypical Tube Side Isolation System

• Level Switches that:• Shut off Condensate flow• Open Condensate Bypass• Shut off other sources of flow into heater

• RHDT’s / MSDT’s / Deaerator switches/AOV’s are RHDT’s / MSDT’s / Deaerator switches/AOV’s are not applicablenot applicable

• Alarms are not applicable (per our NEIL rep, Alarms are not applicable (per our NEIL rep, though you should ask your rep specifically)though you should ask your rep specifically)

• Should be done at beginning of outages to Should be done at beginning of outages to identify scopeidentify scope

• You can take credit for SU/SD actuation, PM, or You can take credit for SU/SD actuation, PM, or corrective PMT (monitor voltage at the contacts corrective PMT (monitor voltage at the contacts for large MOV’s)for large MOV’s)

• Don’t have to test all equipment at the same timeDon’t have to test all equipment at the same time• No requirement to fill level switch standpipesNo requirement to fill level switch standpipes• Ops controlled procedure is the easiest wayOps controlled procedure is the easiest way

Considerations for TestingConsiderations for Testing

DiscussionDiscussion

• NEIL standards are governed by NEIL standards are governed by representatives from each plantrepresentatives from each plant

• If a standard is too restrictive or is If a standard is too restrictive or is not effective, the board can change itnot effective, the board can change it

• What is your plant’s strategy?What is your plant’s strategy?

• What do you think?What do you think?