IR 05000382/1987005

Insp Rept 50-382/87-05 on 870209-13.Violations Noted:Failure to Perform Evaluation to Assure Satisfaction of Test Requirements & Performance of Limitorque Valve Operators During Svcs When Test Procedure Acceptance Limits Exceeded

ML20215J466
Person / Time
Site:	Waterford
Issue date:	04/27/1987
From:	Ireland R, Norman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215J451	List: IR 05000382/1987005 ML20215J448 ML20215J461 ML20215J466
References
50-382-87-05, 50-382-87-5, IEB-85-003, IEB-85-3, NUDOCS 8705080035
Preceding documents:	ML20235U001 (17 July 1987)
Download: ML20215J466 (7)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/87-05 License: NPF-38 Docket: 50-382 Licensee: ' Louisiana Power & Light Company (LP&L)

N-80 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford 3 Inspection At: Taft, Louisiana Inspection Conducted: February 9-13, 1987 Inspector: [, 73sfem D. E. Norman, Reactor Inspector, Engineering 4M3 Date

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.Section, Reactor Safety Branch Approved: h 98 # f/F7 j R. E. Ireland, Chief, Engineering Section Date '

Reactor Safety Branc Inspection Summary Inspection Conducted February 9-13, 1987 (Report 50-382/87-05)

Areas Inspected: Routine, unannounced inspection of a followup to Waterford 3 commitments.in response to IE Bulletin 85-0 Results: Within the areas inspected, one violation was identified as a result of a failure to perform an evaluation to assure that test requirements had'been satisfied and that Limitorque valve operators would perform satisfactorily during services as a result of acceptance limits permitted by test procedures having been exceeded (paragraph 2.c(1)). Two unresolved items (paragraphs 2.c(2) and 2.(d)) which also require licensee action were also identifie S0800 5 P

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DETAILS

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, Persons Contacted-Louisia' na Power -& Light Company (LP&L) '

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• K. L. Brewster, Licensing

• R. V. Sei_dl, Nuclear Operations Engineering

• L.-L. Bass, Nuclear Operations Engineering,

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• S. K. Shete', Nuclear Operations Engineering

• E. Fields, Nuclear Operations Engineering

• R. P. Barkhurst, Nuclear Operations

• N. S. Carns, Plant Manage , *D. W. Vinci, PME

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• T. H. Smith, Maintenance

*M. I. Meyer,: Nuclear Operations Engineering

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• R. F. Burski, Nuclear Operations Engineering

• S.- Lockhart,'N0SA Manager-

- *T. F. Gerrets, Quality Assurance

• J. R.:McGaha, Operations and. Maintenance

• K. L. LeBlanc, Maintenance-G. Koehler, Operations Quality Assurance

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MOVATS Incorporated

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l K. M. Eslinger, Manager, Signature Analysis k

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- *J. G. Luehman, Senior Resident Inspector

*D. E. Norman, Reactor, Inspector

• Denotes those present=at the exit intervie . Inspection Summary '

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LIE Bulletin 85-03, " Motor. Operated' Valve Comon Mode Failure During Plant L Transients Due to , Improper Switch Settings," was issued as a result of 4

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several events during which motor operated valves (MOVs) failed on demand due to improper switch settings...The Bulletin requested that MOVs in certain systems be tested for operational ^ readiness, and that licensees

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i develop and implement a programfto ensure that valve operator switches are

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selected, set, and maintained properly to accomodate maximum differential f pressure expected during both opening and closing of the valve for both

. normal and-abnormal events within the design basis. The Bulletin requires i :that a report be submitted within 180 days of the Bulletin date l (November 15,1985) with the followin (a)documentationof design basis for each valve, and program (b) g information:

for complying with~the Bulletin and a schedule for accomplishing the program. The requested i'

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-3-submittal was made by.the licensee on May.14, 1986, and an additional submittal with information requested by the NRC was made on August 22, 198 The Bulletin requires that a written report on the completion of the. program be made within 60 days of completio Followup on the licensee's actions with respect to the Bulletin was made by performing the following inspections:

a'. Procedures Review - The following procedures, which implement the provisions of the licensee's IEB 85-03 program discussed in the submittal to the NRC, were reviewed by the NRC inspector:

ME-7-027, Revision 0, dated November 25, 1986, "Using M0 VATS 2150 System for Testing of MOV" ME-7-008, Revision 5, dated November 28, 1986, " Motor Operated Valve"

MM-6-105, Revision 2, dated October 31,1986, "Limitorque Motor Operator Maintenance" Pertinent aspects for proper setting of the switches which were covered by the procedures include:

Specific procedure for determining as-found and as-left switch setting Setting of torque switch bypass verified by handwheel turns after removal of any system backlas Setting of torque switches at valve mid-stroke position and Belleville springs in a relaxed conditio Additionally, the procedures presented certain acceptance criteria to be utilized during the valve testing.-

With the exception of items montioned later in this report, the licensee had implemented a program to~ ensure reliable operation of MOVs, utilizing the Motor Operated Valve Analysis and Test System (M0 VATS), a system which permits testing, adjusting; and setting of torque and limit switches which are part of the controls for an MO MOVATS is a portable signature analysis device designed for field us Parameters obtained by the system include:

Axial motion of the wor Actuation of torque and limit switches and the torque switch bypas *

Motor curren '

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Operatorthrust. levels (stemload).

- b.- Hardware Inspection - The valves required.to meet IEB 85-02 criteria had been tested by the MOVATS system during the first refueling-outage and the plant was back in operation at the time of,the NRC

' inspection;-therefore, no hardware inspections were performed, Data Review'- IEB 85-03 reported that valves failed to operate upon demand because torque bypass switches had not been set to remain closed long enough to provide the necessary typass function on valves opening with differential pressure conditions across the valve Switches.were reportedly set for 5 percent of full stroke. Waterford procedures require either a 5 percent setting after removal of system backlash' or a setting determined by Engineering on a valve by valve basi Twenty' valves were tested by.the licensee. . Six were tested with design differential. pressures while the remaining were tested under static conditions. A final analysis of test data had not been Lcompleted by the licensee at.the time of the NRC inspectio .

The NRC inspector reviewed both data manually collected during testing and signature data recorded by the MOVATS 2150 system. The following observations were made from that revie (1) Acceptance' Criteria Exceeded =

(a) As-found thrust limits recomended by Limitorque and as stated in ME-7-027 had been exceeded on the following operators:

SI-228B

SI-502A

SI-121B

MS-401A

MS-401B

SI-506B

SI-502B (b) Possible.backseating had occurred either during operation or during testing of following valves:

SI-506B

SI-502B (c) Thermal overload tripped several times while testing SI-120 (d) As-left motor current exceeded 130 percent of nameplate rated current on the following operators:

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SI-225A

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SI-226B (e) Torque switch did not balance on operators:

SI-502A

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SI-502B The above conditions exceed acceptance criteria for the operators, set by the licensee and vendors, and could affect valve operability; however, at the time of the NRC inspection the conditions had not been identified and analyzed by the licensee and the plant had been restarte Failure to properly document and analyze the conditions identified in paragraphs 2.c(1)(a) through 2.c(1)(e) in respect to the capability.of valve operators to complete their safety-related function is considered a violation of NRC requirements (382/8705-01).

(2) Inadequate Procedures - Paragraph 4.2.5_of ME-7-027 presents thrust limits for SMB model operators and states that those limits should not be exceeded. Limits actually in use, however, are based on Limitorque correspondence dated November 24 and 28, 1986, which states that the torque switch trip may be set as high as the published thrust rating and that the maximum thrust (inertial) can be a maximum of 10 percent above the torque switch set point. 'It was also stated in the letter that for a maximum of 100 operating cycles the operator thrust may be increased another 10 percent above the published ratings (tor switch trip point could be 110 percent of the thrust rating) queand that the final thrust (inertial) could be 120 percent of the rating. The procedure provided no means to account for the number of valve cycles which had been made or could be made in the future at the higher setting. There were, also no provisions in the procedures relative to operators which were found during M0 VATS testing to have torque switch setpoints or inertial thrusts in excess of 110 and 120 percent respectivel This item is considered unresolved (382/8705-02)-

(3) Noncompliance With Procedures '

(a) Torque Bypass Switch Settings - Torque bypass switch settings detailed in ME-7-027 and ME-7-008 were based on the ratio of handwheel turns at which the switch dropped out to the full-stroke turns, allowing for system backlas ,

Data reviewed by the NRC inspector showed a bypass switch setting calculated from the MOVATS signature. It was based on the time at which the switch dropped out and the total valve stroke time but did not consider the time prior to valve unseating (backlash). This method did not comply

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- with approved procedures and appears to result in an apparent switch setting (bypass ratio) which is25-400 percent greater than the actual setting based on the handwheel method. This could result in bypass switch settings which would permit a bypass switch trip prior to valve unseating. It was explained by the licensee that emergency actuation of certain valves is accomplished by bypassing both the torque switch _and the bypass switch; therefore, the bypass switch setting would be of no consequence during an emergency. IE Bulletin 85-03; however, addresses both normal and abnormal events; therefore, the licensee should address both conditions in his submittal to IE Bulletin 85-0 The bypass switch settings of valves MS-401A and MS-401B appear marginal (1.5 and 1.9 percent respectively based on MOVATS signature and considering system backlash) and could trip prior to valve unseating. It was explained to the NRC inspector that this. situation exists because the valve position indicator lights and the bypass switch share the same limit switch rotor, and adjusting the switch would result in an erroneous position indicatiori. This problem was solved on all other operators by replacing two rotor limit switches with four rotor switches and placing the indication lights and bypass switch on different rotor This could not be done on the above valves since four rotors were already in use and served different function The adequacy of bypass switch settings for compliance with IEB 85-03, for both normal and abnormal events, and the apparent deviation of switch setting method from established procedures will be further reviewed when the final licensee report is submitted and by a subsequent NRC inspection if necessary. This is considered an open item requiring additional NRC review (382/8705-03).

(b) Limit Switch Setting - The limit switch setting method outlined in ME-7-027 and ME-7-008 was based on the number of handwheel turns at the switch trip point and the number of full-stroke turns; however, data reviewed _by the NRC inspector based the trip point on the MOVAT,S signatur It could not be demonstrated conclusively,' fro'm the data reviewed, at what valve position the limit switch, activated; nor could it be determined whether' valves were, or had been, backseating. This item is considered an open'

item and will receive additional review when the licensee report is submitted and by a subsequent NRC inspection if necessary (382/8705-04).

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-7-Q. A. Program Implementation

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During the course of this inspection, the IEB 85-0'3 program committed to by the licensee and its implementation was reviewed. As mentioned .

previously in this report, acceptance criteria had been exceeded in

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several areas and there was no evidence that the items had been-'

reported or were to be reported and appropriate corrective action -

taken. It was also observed, during the course'of.the' inspection'," .

that Quality Assurance Program requirements of 10 CFR-50 Appendix B,J - ~

Criterion II, had not been applied to the IEB 85-03 program. This:

conclusion was reached by the NRC inspector because of a lack' evidence that verification of quality had been performed by reviewing ~

program procedures, reviewing conduction of inspection or, tests,~and reviewing test results or final as-left condition of'the valve The apparent lack of training of QA personnel in the valve testing and inspection program adds to the concerns expressed for this program and to question possible generic implications involving the QA program implementation. This is considered to be an unresolved. item

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pending further review by the NR (382/8705-02) -

3. Exit Interview The NRC inspector met with the licensee representatives denoted in paragraph 1 and Mr. J. G. Luehman, NRC senior resident inspector on February 13, 1987,- and summarized the scope and findings of the inspectio