ML20235U001
| ML20235U001 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/17/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8707220327 | |
| Download: ML20235U001 (2) | |
See also: IR 05000382/1987005
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JUL 17'1987
In Reply Refer To:
' Docket: 50-382/87-05.
Louisiana Power & Light Company
ATTN:
J..G. Dewease,, Senior Vice President
Nuclear Operations
317 Baronne-Street-
New Orleans,. Louisiana
70160
Gentlemen:
Thank you for your letter of June 12, 1987, in response to our letter and
Notice of Violation dated May 6, 1987. We have reviewed your reply and find it
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responsive to the conc' erns raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
,
Sincerely,
.
Original Sicned By
J. P. Jauden
J. E. Gagliardo, Chief
1
Reactor Projects Branch
cc:
Louisiana Power & Light Company
ATTN:
G. E. Wuller, Onsite
Licensing Coordinator
P. O. Box B
Killona, Louisiana
70066
Louisiana Power & Light Company
ATTN:
N. S. Carns, Plant Manager
P. O. Box B
Killona, Louisiana
70066
Middle South Services
ATTN: Mr. R. T. Lally
P. O. Box 61000
New Orleans, Louisiana
70161
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Louisiana Power & Light Company
ATTN:
K. W. Cook,~ Nuclear Safety and
Regulatory Affairs Manager
317 Baronne Street
-P. O. Box 60340
New Orleans, Louisiana
70160
Louisiana Radiation Control Program Director
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JUN I 71987
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LOUISI ANA / 347.BARONNESTREET
P. O. BOX 60340
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POWE A & LIGHT
NEW ORLEANS, LOUISIANA 70160 * (504)595 31 0
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June 12, 1987
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Subject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 87-05
Reference: LP&L letter from K.W. Cook to NRC, W3P87-1075 dated June 3,
1987.
The referenced letter transmitted the Louisiana Power and Light Company
response to Violation No. 8705-01 which was cited in the subject Inspection
Report.
It has come to our attention that the response you received was
not the response which resulted from our validation process. An earlier
version of our response was inadvertently included as an attachment to the
referenced letter. Attached please find the validated copy of our response
to the violation.
If you have any questions on the response, please contact G.E. Wuller,
Operational Licensing, at.(504) 464-3499.
.
Very truly yours,
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K.W. Cook
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Nuclear Safety and
Regulatory Affairs Manager
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Attachment
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R.D. Martin, NRC Region IV
J.a. Calvo, NRC-NRR
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J.H. Wilson, NRC-NRR
NRC Resident Inspectors Office
E.L. Blake
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W.M. Stevenson
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"AN EQUAL OPPORTUNITY EMPLOYER"
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lW3P87-1089'
Attachmant to
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Sheet 1 of 4
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LP&L Response To Violation No. 8705-01
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VIOLATION NO. 8705-01'
driterion XI of.10CFR50 Appendix B, as implemented by paragraphs 17.2.15
and 17.2.16 of the FSAR, dated December 18,.1986, states, in part, "A' test
program shall be established to assure that all testing required to
demonstrate lthat structures, systems,fand components will perform
satisfactorily'in service.is identified and performed in accordance with.
written test procedures.which incorporate the requirements and acceptance
limits. contained in applicable design documents. The test program shall
include, as appropriate, ... operational tests during nuclear power plant
... operation,.of~... components ... Test results shall be documented and~
evaluated.to' assure that test requirements have been satisfied."
. Contrary to the above. during operational testing of safety-related
Limitorque' valve operators certain acceptance limits permitted by the test-
procedures.had been exceeded and an evaluation had not been performed to
assure that test requirements had been satisfied and that the operators
would perform satisfactorily during service.
This is a Severity. Level IV violation.
RESPONSE
(1) Reason'for the Violation
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The text of-Inspection Report 87-05 contains the following inspection
summary information which is helpful in further defining the scope of
the violation and is quoted as follows:
" Acceptance Criteria Exceeded-
2.C.1 (a) As-found thrust limits recommended by Limitorque and as
stated in ME-7-027 had been exceeded on the following
operators:
o
SI-228B
o
SI-502A
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SI-121B
o
MS-401A
o
MS-401B
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SI-506B
o
SI-502B
(b) Possible backseating had occurred either during
operation or during testing of the following valves:
o
SI-506B
o
SI-502B
(c) Thermal overload tripped several times while testing
SI-120B.
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Sheet 2 of 4
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(d)' As-left motor current exceeded 130 percent of' nameplate
rated current on the following operators:
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SI-225A'
o
SI-226B
(e) Torque switch did not balance on operators:
o'
.SI-592A
o
SI-502B
The'above conditions exceeded 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)."
LP&L did exceed the acceptance criteria specified in maintenance
. procedure ME-7-027 and lacked documentation of engineering
evaluations. However, prior to returning to service the valves
identified in items (a)-(e) above, an engineering review of valve
performance,. thrust requirements and operability was performed with
acceptable results.
While MOV-testing was being conducted.during the first refueling
outage additional documentation, that could.have had an impact on test
acceptance criteria, continued.to be received by LP&L. For instance,
documentation from L-imitorque Corporation which allowed increased
thrust ratings of Limitorque operators became available during the
testing period. This information was identified in the engineering
operability reviews, however we failed, at that time, to formally
incorporate the increased thrust ratings into the testing procedure
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acceptance criteria.
Additional information concerning items (a)-(e) is discussed below:'
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(a)' During the period of as-found testing, in which the thrust limits
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recommended by Limitorque and as stated in ME-7-027 had been
exceeded, the following actions took place.
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(1) Visual inspection was conducted to determine if any damage
occurred.
(2) A review of the last maintenance record, for which the
actuator was disassembled (October 1986) reflected that no
evidence of damage existed.
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(3) The results of static and differential-stroking of.the
valves were reviewed.
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Based on the above actions the valves were determined to be
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A consultant engineering' firm is being utilized to evaluateLthe
long term effect of the as-found over thrusting and as-left
thrust setting on the fatigue' life of the valve and. operator.
This analysis will be discussed in further detail in the LP&L
response to IE Bulletin 85-03.
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(b) LP&L review of the MOV test data confirms. that back seating
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occurred only once during MOVAT static testing. The back seating-
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force of 12,400 lbs. and 6,908 lbs. applied to SI-506B and
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SI-502B,did not damage the valves. The valve manufacturer,-
Anchor Darling, has provided documentation confirming that the
amount of back seating force applied to both valves would not
cause any' damage to the valve.
'(c) Due to repeated' cycling of the valve in a short period of time
during as-left MOVAT testing, the tripping of thermal overloads
is not considered a problem.
(NOTE: The valve in question.
SI-120B, is a miniflow valve which allows the High Pressure
Safety Injection (HPSI) pump recirculation to the refueling water
storage pool. This valve is normally open and does not receive
an ESFAS actuation signal.)
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(d) The current rating for SI-225A and SI-226B are 2.1 amps and 2.5
amps, respectively. The average running current for the valves
are 2.54 amps and 3.35 amps. The average running current exceeds
the motor name plate rated current by 120.9% for SI-225A and
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134% for SI-226B. SI-225A is within the acceptance criterion and
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SI-226B exceeds'the' criterion by 4%.
The results for SI-226B
received an engineering review prior to placing the valve back in
service. During an accident when a Safety Injection Actuation
Signal is initiated the torque bypass limit switch, torque switch
and thermal overloads are bypassed in the actuator circuit to
force the valve open. Thus, the overcurrent concern would not
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affect performance of the valve safety function. The maintenance
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procedure ME-7-027 acceptance criteria will be revised to allow
an engineering evaluation to determine acceptability of test
results.
(e) Following MOV testing, maintenance procedure ME-7-027 Rev. O
change 1 deleted the acceptance criteria requiring torque switch
balancing.
The valve manufacturer provides the thrust
requirements for the close and open operation of the valve. The
MOVAT test equipment measures the opening and closing thrust.
Limitorque provides the minimum, normal and maximum torque switch
settings.
Since the thrust for SI-502 A&B can be measured and
meets the valve manufacturer requirements, torque switch
balancing is not required. It should be noted that the torque
switch settings is within the range specified by Limitorque.
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(2) C_orrective Action That Has Been Taken
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Maintenance Procedure ME-7-027 has been revised to incorporate the
following changes:
a.
Increase Limitorque operator ratings to agree with Limitorque
documentation,
b.
Specify method of determining torque bypass switch settings and
determination of percentage of bypass.
c.
Torque switch balancing is not a part of the maintenance.
procedure acceptance criteria.
In addition, those personnel associated with MOV testing have been
fully briefed on the need for strict adherence to test acceptance
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criteria and the proper procedure for changing those criteria with
acceptable technical justification.
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As previously discussed LP6L directed ite.-consultant to perform
analy'ses of the remaining useful fatigue life of those valves subject
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to thrust levels in excess of manufacturr's recommendations. The
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analyses determined that sufficient margin to material fatigue failure
existed for the seven valves in question. Based on the analyses
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results, and available margin, LP&L will develop a component
replacement schedule as needed.
Incorporating realistic test criteria into ME-7-027 combined with
personnel briefing on the need to adhere to acceptance criteria will
ensure that correct acceptance criteria are met in future MOV testing.
Similarly, the engineering analyses of those valves that exceeded
thrust criteria will ensure sufficient design margin for continued
operability and will provide a conservative schedule for component
replacement if required.
(3) Corrective Action To Be Taken
Maintenance Procedure ME-7-008 will be revised to specify that
information/ requirements relative to valves being tested are not tied
to any other maintenance electrical procedure.
As discussed in response to item (d) concerning current rating
acceptance criteria, maintenance procedure ME-7-027 will be revised to
allow an engineering evaluation to determine acceptability of test
results.
(4) Date When Full Compliance Will Be Achieved
rull coupliance will be achieved by 7/15/87.
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