ML20238C543

Ack Receipt of in Response to Violations Noted in Insp Rept 50-285/87-17

ML20238C543
Person / Time
Site:	Fort Calhoun
Issue date:	09/03/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8709100188
Download: ML20238C543 (1)

See also: IR 05000285/1987017

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' r -in' Reply Refer To:

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Docket: 50-285/87-17

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Omaha Public Power District

ATTN: R.-L.'Andrews, Division Manager-

Nuclear Production

1623 Harney Street

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Omaha, Nebraska

68102

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Gentlemen:

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Thank you for your letter of July. 31,1987, .in response to our letter and

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Notice of Violdtion dated July 1,1987. We have reviewed your' reply and find

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it responsive to the concerns raised in our. Notice of Violation. We will

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review the implementation of your corrective actions during a' future inspection

to determine that full compliance has been achieved.and will be maintained.

Sincerely,

va;;inal Sicard by:

J. E. GAGLIARDO

J. E. Gagliardo, Chief

Reactor Projects Branch'

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W. G. Gates, Manager

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Fort Calnoun Station

P. O. Box 399

Fort Calhoun, Nebraska

68023

Harry H. Voigt, Esq.

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LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Avenue, NW

Washington, D. C.

20036

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Omaha Public Power District

1623 Harney Omaha, Nebraska 68102

402/536 4000

July 31, 1987

LIC-87-552

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Mr. J. E. Gagliardo, Chief

Reactor Projects Branch

U. S. Nuclear Regulatory Commission

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Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, Texas 76011

References:

1.

Docket No. 50-285

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2.

Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated

July 1, 1987

Dear Mr. Gagliardo:

SUBJECT:

Inspection Report 50-285/87-17

The subject inspection report identified one viciation. The violation

involved failure to identify and evaluate an as-found over-thrust condition

in Limitorque valve operators. Pursuant to the provisions of 10 CFR Part 2.201, please find attached the Omaha Public Power District's response to

this violation.

Sincerely,

R. L. Andrews

Division Manager

Nuclear Production

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Attachment

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LeBoeuf, Lamb, Leiby & MacRae

1333 New Hampshire Ave., N.W.

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Washington, DC 20036

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Mr. R. D. Martin, NRC Regional Administrator

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Mr. A. Bournia, NRC Project Manager

Mr. P. H. Harrell, NRC Senior Resident Inspector

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Attachment

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During an NRC inspection conducted on June 8-12, 1987, a violation of NRC

requirements was identified. The violation involved a failure to identify and

evaluate an as-found over-thrust condition in Limitorque valve operators.

In

accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed

below:

10 CFR 50, Appendix B, Criterion XV and XVI as implemented by the OPPD

Quality Assurance Manual QADP-17 states, in part, " Measures shall be

established to control materials, parts, or components which do not

conform to requirements in order to prevent their inadvertent use ...

Measures shall be established to assure that conditions adverse to

quality, such as failures, malfunctions, deficiencies, deviations,

defective material and equipment, and nonconformances are promptly

identified and corrected ...".

Contrary to the above, measures were not established to identify and

control the use of Limitorque valve operators which were found to have

thrust switches set so that thrust limits of the operators had been

exceeded.

This is a Severity Level IV violation.

(Supplement I) (285/8717-02)

OPPD's Resoonse

The Reason for the Violation if Admitted

During the 1985 refueling outage, M0 VATS, a new testing tecnnology, was

introduced at the Fort Calhoun Station. With the use of this new test

procedure, Limitorque operators could be tested for the first time to perform

in situ measurement of the conditions of a valve.

In an effort to respond to

IE Bulletin (IEB) 85-03, the HPSI valves were tested. An outcome of this test

was a finding that several operators were found with thrust settings above the

range recommended by the manufacturer's specifications.

At the time of the occurrence, OPPD personnel held several discussions

evaluating the impact and the problems associated with the as-found over-thrust

condition.

Investigation of pcst operating history of the Limitorque operators

tested had not produced any records of operator failure. After visual

inspection and MOVATS testing using the appropriate torque switch settings, the

valves exhibited normal test results with no evidence of operator performance

degradation.

MOVATS analysis reports confirmed field observations. With this

background, it was felt that the valves could be considered operational.

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With the valves testing normally, it was thought appropriate at the time that

further review or other documentation was not needed.

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Attachment (continued)

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The Corrective Steos Which Have Been Taken and the Results Achieved

Prior to inspection 87-17, the M0 VATS testing procedure had been rewritten and

implemented.

The revised procedure established criteria to help eliminate the

possibility of drastic over-thrusting of a Limitorque valve operator. Also,

the procedure further defined valve operator capacity more clearly; again, with

the goal of eliminating thrust setting errors. These actions eliminated most

of the procedural problems.

During the subject inspection, an engineering firm was contacted for a

preliminary stress analysis, based on fatigue testing of the worst case loading

conditions. The valve operators were viewed as being acceptable from a

structural and operability standpoint.

Preliminary limits are for 240 to 250

cycles of operation with the overstress condition that existed prior to the

1985 refueling outage. To date, the valves are estimated to have undergone 200

cycles.

Further analysis is ongoing to evaluate the impact on the expected

life of the over-thrusted valves.

The Corrective Steos Which Will be Taken to Avoid Further Violations

Before the 1988 refueling outage, the following actions will be completed.

a.

Additional review and revision, as required, of the MOVATS testing

procedures will be performed to clearly define and establish methods to

set valve thrusts and to ensure that the capacity of the operator or valve

will not be exceeded.

b.

A review of the processes of reporting and evaluating test results will be

performed. A'propriate actions will be taken to ensure procedures and

personnel correctly and effectively respond to adverse findings.

c.

Further evaluations will be made on over-thrusted valves to determine the

possible damage and life cycle effects on the valve operators.

The

engineering analysis 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.

The Date When Full Comoliance Will be Achieved

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OPPD is presently in full compliance.

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