W3P87-1075, Forwards Response to Violations Noted in Insp Rept 50-382/87-05.Corrective Actions:Maint Procedure ME-7-027 Will Be Revised to Allow Engineering Evaluation to Determine Acceptability of Test Results
| ML20214T802 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/03/1987 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P87-1075, NUDOCS 8706100428 | |
| Download: ML20214T802 (5) | |
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LOUISI ANA / 317 BARONNESTREET
+
P. O. BOX 60340 POWER & LIGHT NEW ORLEANS, LOUISIANA 70160 + (504) 595 3100
$20NEvsYIU June 3, 1987 W3P87-1075 A4.05 QA 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 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8705-01 which is cited in the subject Inspection Report.
If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.
Very truly yours, "N
&O' h
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W K.W. Cook Nuclear Safety and Regulatory Affairs Manager KWC:PTM:ssf Attachment cc:
R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR J.H. Wilson, hTC-NRR NRC Resident Inspectors Office g
E.L. Blake g
W.M. Stevenson g
8706100428 970603
/
PDR ADOCK 05000382
/
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PDR "AN EQUAL OPPORTUNITY EMPLOYER"
1, Attachment to W3P87-1075 Sheet 1 of 4 LP&L Response To Violation No. 8705-01 VIOLATION NO. 8705-01 Criterion 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 that structures, systems, and 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."
4 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 following valves:
o SI-506B o
SI-502B (c) Thermal overload tripped several times while testing SI-120B.
Attachment to W3P87-1075 Sheet 2 of 4 (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-502A 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 Limitorque Corporation which allowed increased l
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 l
incorporate the increased thrust ratings into the testing procedure acceptance criteria.
l Additional information concarning items (a)-(e) is discussed below:
i (a) During the period of as-found testing, in which the thrust limits recommended by Limitorque and as stated in ME-7-027 had been exceeded, the following actions took place.
l (1) Visual inspection was conducted to determine if any damage j~
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 I
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Attachm:nt to W3P87-1075 Sheet 3 of 4 (3) The results of static and differential stroking of the valves were reviewed.
Based on the a'bove actions the valves were determined to be operable.
A consultant engineering firm is being utilized to evaluate the 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.
(b) LP&L review of the MOV test data confirms that back seating occurred only once during MOVAT static testing. The back seating force of 12,400 lbs. and 6,908 lbs. applied to SI-506B and 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 131.8% for SI-226B.
SI-225A is within the acceptance criterion and SI-226B exceeds th6 criterion by 1.8%.
The results for SI-226B received an endineering review prior to placing the valve back in service. Durir4 an accident when a Safety Injection Actuation Signal is in:ltiated the torque bypass limit switch, torque switch and thertjal overloads are bypassed in the actuator circuit to force the velve open. Thus, the overcurrent concern would not affect performance of the valve safety function. The maintenance procedure ME-7-027 acceptance criteria will be l
revised to allow an engineering evaluation to determine acceptability of test results.
1 (p) Following MOV "esting, maintenance procedure ME-7-027 Rev. 0 change 1 delet$d the acceptance criteria requiring torque switch l
balancing. The valve manufacturer provides the thrust requirements for the elese 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 l
settingn.
Since the thrust for SI-502 A&B can be measured and meets the valve manu'acturer 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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Attachment to W3P87-1075 Sheet 4 of 4 (2) Corrective Action That Has Been Taken l
Maintenance Procedure ME-7-029 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.
Specify that information/ requirements relative to valves being tested are not tied to any other maintenance electrical procedure.
d.
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 criteria and the proper procedure for changing those criteria with acceptable technical justification.
As previously discussed, LP&L directed its consultant to perform analyses of the remaining useful fatigue life of those valves subject to thrust levels in excess of manufacturer's recommendations. The analyses determined that sufficient. margin to material fatigue failure existed for the seven valves in question.
Based on the analyses 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 l
replacement if required.
(3) Corrective Action To Be Taken l
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, i
(4) Date When Full Compliance Will Be Achieved Full compliance will be achieved by 7/15/87.
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