W3P87-1089, Corrected 870603 Response to NRC Ltr Re Violations Noted in Insp Rept 50-382/87-05.Response Transmitted Not Response Resulting from Validation Process.Validation Response Encl
| ML20215A551 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/12/1987 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P87-1089, NUDOCS 8706160701 | |
| Download: ML20215A551 (5) | |
Text
___. _ _ _ _ _ _ _ _ _ _ _,
LOUISI AN A / 317 BARONNE STREET P. O. BOX 60340 (504) 595-3100 POWER & LIGHT NEW ORLEANS, LOUISIANA 70160 UT IIdIVsY[0 June 12, 1987 W3P87-1089 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
Reference:
LP&L Ictter 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, dI- /*1 f
0706160701 070612 PDR ADOCK 05000302 K.W. Cook O
PDR Nuclear Safety and Reguintory Affairs Manager KWC HGM:PTM:ssf Attachment cc:
R.D. Martin, NRC Region IV J.A. Cnivo NRC-NRR J.ll. Wilson, NRC-NRR NRC Resident Inspectors Office g
E.L. Blake
\\
W.M. Stevenson
{I "AN EQUAL OPPORTUNITY EMPLOYER" J
W3P87-1089 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."
Contrary to the above, during operational testing of safety-related t
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 j
would perform satisfactorily during service.
This is a Severity Level IV violation.
4
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 i
operators:
o SI-228B o
SI-502A o
SI-121B o
MS-401A o
MS-401R o
SI-506B l
o SI-502B (b) Possible backseating had occurred either during operation or during testing of the following valvest o
SI-506B o
SI-502B i
(c) Thermal overload tripped several times while testing SI-120B.
W3P87-1089 Attachm nt 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 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 l
acceptance criteria.
Additional information concerning items (a)-(e) is discussed below:
(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.
(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.
it W3P87-1089 Attachm nt to W3P87-1075 Sheet 3 of 4 (3) The results of static and differential streking of the valves were reviewed.
Based on the above 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 IS Bulletin 85-03.
(b) LP&L review of che 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 anps, respectively. The average running current for the valves aret 2.~54 amps and 3.35 amps. The aierage running current exceeds the motor name plate rated current by 120.9% for SI-225A and 134% for SI-226B.
SI-225A is within the acceptance criterion and 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 affect performance of the valve safety function.
The maintenance 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 settinrs; 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.
t
-~ _
~
W3P87-1089 Attachmint to W3P87-1075 Sheet 4 of 4 (2) Corrective Action That Has Been Taken 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 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 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 Full compliance will be achieved by 7/15/87.