ML20238C543
| 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
,
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
Kansas Radiation Control Program Directcr
Nebraska Radiation Control Program Director
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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
,
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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