ML20215J466

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
Download: ML20215J466 (7)

See also: IR 05000382/1987005

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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

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.Section, Reactor Safety Branch

Approved: h 98 # f/F7

j R. E. Ireland, Chief, Engineering Section Date '

Reactor Safety Branch.

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 85-03.

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

identified.

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DETAILS

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, 1. 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 Manager.

, *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

• A. 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

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- *J. G. Luehman, Senior Resident Inspector

*D. E. Norman, Reactor, Inspector

• Denotes those present=at the exit interview.

2. 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

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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,

1986. The Bulletin requires that a written report on the completion of

the. program be made within 60 days of completion.

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

settings.

Setting of torque switch bypass verified by handwheel turns

after removal of any system backlash.

Setting of torque switches at valve mid-stroke position and

Belleville springs in a relaxed condition.

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 MOV. MOVATS is a portable signature analysis device designed

for field use. Parameters obtained by the system include:

Axial motion of the worm.

Actuation of torque and limit switches and the torque switch

bypass.

Motor current.

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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,

c. 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 valves.

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

basis.

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 inspection.

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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 review.

-(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-120B.

(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 restarted.

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 respectively.

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 backlash. ,

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 85-03.

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 rotors.

This could not be done on the above valves since four

rotors were already in use and served different functions.

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 signature. 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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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'o.f.

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 valves. 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 NRC. (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

inspection.

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