ML20235U001

Ack Receipt of 870612 Response to Violations Noted in Insp Rept 50-382/87-05 & Notice of Violation . Implementation of Corrective Actions Will Be Reviewed During Future Insp

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

Text

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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 i

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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• RRI R. D. Martin, RA

• SectionChief(RPB/A) DRSP

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• MIS System * Project Inspector, RPB

• RSTS Operator *R. Hall

• RIV File *J. Wilson, NRR Project Manager

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JUN I 71987

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NEW ORLEANS, LOUISIANA 70160 * (504)595 31 0 --

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June 12, 1987 .l

W3P87-1089

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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 {

Nuclear Safety and

Regulatory Affairs Manager j

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KWC:BGM:PTM:ssf

Attachment

cc: R.D. Martin, NRC Region IV

J.a. Calvo, NRC-NRR l

J.H. Wilson, NRC-NRR

NRC Resident Inspectors Office

E.L. Blake

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LP&L Response To Violation No. 8705-01

.

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

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

o SI-121B

o MS-401A

o MS-401B

o 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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(d)' As-left motor current exceeded 130 percent of' nameplate

rated current on the following operators:

o 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:'

)

(a)' During the period of as-found testing, in which the thrust limits i

recommended by Limitorque and as stated in ME-7-027 had been

exceeded, the following actions took place. -

(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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L (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

j. < operable.

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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l: (b) LP&L review of the MOV test data confirms. that back seating

l. occurred only once during MOVAT static testing. The back seating-

L force of 12,400 lbs. and 6,908 lbs. applied to SI-506B and

i 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.)

(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

j 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

L affect performance of the valve safety function. The maintenance

I 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 -i

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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.

1

As previously discussed LP6L directed ite.-consultant to perform

analy'ses of the remaining useful fatigue life of those valves subject  !

to thrust levels in excess of manufacturr's

e recommendations. The l

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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