ML15211A497

Part 21 - Mounting Bracket Seismic Qualification

ML15211A497
Person / Time
Site:	Pilgrim
Issue date:	07/24/2015
From:	Roy M Flowserve Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
51262
Download: ML15211A497 (10)

Text

0712412015 072/05US. Nuclear Reguiatnrv Commission Oneratians Center Event Renort Pnae 1 Part 21 (PAR) Event# 51262 Rep Org: FLOWSERVE CORPORATION Notification Date I Time: 07/2412015 17:05 (ýDT)

Supplier: FLOWSERVE CORPORATION Event Date / Time: 07/24/2015 .(EDT)

Last Modification: 07/24/2015 Region: 1 Docket #:

City: RALEIGH Agreement State: Yes County: License #:

State: NC NRC Notified by: MICHAEL ROY Notifications: SILAS KENNEDY R1DO HQ Ops Officer: JEFF ROTTON PART 21/50.55 REACTORS EMAIL Emergency Class: NON EMERGENCY 10 CFR Section:

21.21(d)(3)(i) DEFECTS AND NONCOMPLIANCE PART 21 - MOUNTING BRACKET SEISMIC QUALIFICATION The following information was excerpted from a facsimile from FLOWSERVE:

"In accordance with the provisions of 10CFR Part 21, [Flowserve] has identified a potential issue and is submitting our evaluation of the event.

"DESCRIPTION: Entergy Design Specification, SPEC-09-0001-P, paragraph 3.1.1 a, requires that position indicators remain operable during a seismic event. The seismic analysis performed [for installation at Pilgrim Station] did not include mounting brackets for the position indicators. Later review of these brackets found them to be inadequate for the application.

"SCOPE: The engineering evaluation searched all instances of the use of safety related Topworx C7 position indicators, base part number 04126889, by the Flowserve, Raleigh facility.

"PROPOSED ACTION: Flowserve will provide seismically analyzed replacement mounting brackets to Entergy Pilgrim Station at no charge. To prevent reoccurrence of this situation, additional training on the use of nuclear order checklists will be performed.

manr~'lri ividrK[irlmy i*1our Uý:Uý1:40 P.M. U/-Z4-ZU1t) I1 /1 Flow Control Division Anchor/Darling Valves FLOWSERVE BW/IP Valves Edward Valves Valtek Control Products Worcester Valves July 24, 2015 US Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike

,Rockville, MD 20852-2746

'

Subject:

Entergy Pilgrim - Mounting Bracket Seismic Qualification This is to notify the US Nuclear Regulatory Commission that, in accordance with the provisions of 1OCFR Part 21, we have identified a potential issue and are submitting our evaluation of the

,event.

I DESCRIPTION: Entergy Design Specification, SPEC-09-0001-P, paragraph 3.1.1a, requires that position indicators remain operable during a seismic event. The seismic analysis performed did not include mounting brackets for the position indicators. Later review of these brackets found them to be inadequate for the application.

SCOPE: The engineering evaluation searched all instances of the use of safety related Topworx C7 position indicators, base part number 04126889, by the Flowserve, Raleigh facility.

See attached Part 21 evaluation report.

PROPOSED ACTION: Flowserve will provide seismically analyzed replacement mounting brackets to Entergy Pilgrim station at no charge. To prevent reoccurrence of this situation, additional training on the use of nuclear order checklists will be performed, see attached CAR.

Please do not hesitate to contact me if you have any questions or require additional information.

Respectfully submitted, 1/4.ý Michael V. Roy Quality Assurance Manager Flowserve Corporation

1900 S Saunders St.

Raleigh, NC 27603

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Flowserve US Inc Raleigh Operations TolOFree: 1-800-225-6989 Flow Control Division PO Box 1961 Phohe: 1-919-832-D525 1900 South Saunders Street Facsirnmle: 1.919-831-3369 Ralpinh. NC 27603 vf..lowserve.com

VIlJ03l.110 ramlril~l ivlarKeLirly ImuorL Uý-:60:-11 P.m U/-24-ZU15 11 /!1 FLOWSE RVE Page 1 of 2 PART 21 EVALUATION FOR FLOWSERVE CAR 1384 This evaluation was a search of all instances of the use of the safety related Topworx C7 position indicators, base part number 04126889, by the Flowserve, Raleigh facility. Where these position indicators have been used, determination was made whether appropriate analysis was performed.

Summary: No other situation described in CAR 1384 was discovered with other orders involving Yopworx C7 position indicators, base part number 04126889.

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D te:f "0~nthan Andeso

!Flowserve Sr. Product Engineer

PART 21 EVALUATION FOR CAR 1384 Page 2 of 2 ORDERS UTILIZING TOPWORX C7 POSITION INDICATORS, BASE P/N 04126889

. ..... N/A Internal 08 N/A Qualification Testing

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73561 78470 01, 02, 03, 04, 05, 06, 07, 08 N/A - Customer Material Entergy - Pilgrim 91131 02, 04, 06, 07, 12, 13, 14, 15, 16, YES Westinghouse - Sanmen & Haiyang 17, 19, 20, 22, 24, 26, 27, 32, 33, 34 35, 36, 37, 39, 40, 55, 56, 57, 58, 59, 60, 67, 68 91139 06, 07, 20, 35, 36, 49, 65, 66 YES Westinghouse - Sanmen & Haiyang 91154 10, 17, 18, 26 YES Westinghouse - VC Summer 91170 02, 04, 05, 07, 08, 13, 14, 15, 16, YES Westinghouse - VC Summer 17, 19, 20, 21, 22, 24, 26, 27, 29, 30, 35, 36, 37, 38, 39, 41, 42, 43, 44, 51, 52, 53, 54, 55, 56, 57, 58, 91175 02, 04, 05, 07, 08, 13, 14, 15, 16, YES Westinghouse - Vogtle 17, 19, 20, 21, 22, 24, 26, 27, 29, 30, 35, 36, 37, 38, 39, 41, 42, 43, 44, 51, 52, 53, 54, 56, 57, 58, 91176 06,08,24,71,76 YES Westinghouse SNPEC - Sanmen

-Vogtle YES 91213 01, 03, 05, 06, 11, 12, 13, 14, 15, 21, 79, 80, 81 16, 18, 19, 20, 91214 01, 03, 05, 06, 11, 12, 13, 14, 15, YES SNPEC - Haiyang 16, 18, 19, 20, 21, 48, 49, 50 91215 01,02 YES SNPEC SNPEC -- Sanmen Haiyang 01,02 YES 91216

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DATE INITIATED: 5/11/15 ~ PROPOSAL DUE: 6/11/15 CORRECTIVE MANAGER/SUPERVISOR OR VENDOR: Jonathan Anderson ACTION PART, RT# OR OTHER IDENTIFIER: Pilgrim Station Limit Switch R E ST Mounting Bracket R 1OCFR21 EVALUATION REQUIRED? YM N [ ý*II INTERNAL E EXTERNAL LI HOW IDENTIFIED: Review of Order CAR# 1384 INITIATED BY: Kerri Madden CODE MATERIAL? Y -N - . IF CODE, ANI REVIEW:

PROBLEM STATEMENT-( to be completed by QA or responsible department):

Contrary to the customer P.O. requirements, the limit switch bracket was not seismically analyzed.

BELOW DESCRIBE THE CONDITION OR CIRCUMSTANCE VIOLATING THE ABOVE LISTED REQUIREMENT ACKNOWLEDGEMENT OF RECEIPT OF THIS REQUEST SI T (BUYER ACKNOWLEDGES EXTERNAL REQUESTS) I/(/

ROOT CAUSE AND PROPOSED ACTION (to be completed byeponsibe manager or designee)

Root Cause: Requirement from design specification for position indicators to remain operable during seismic event, §3.1.1a, was missed when performing seismic analysis.

Proposed Action: Provide Pilgrim with new limit switch brackets which will be analyzed in revised seismic reports, also to be provided. Provide training to engineers responsible for performing analyses to reinforce specification review and understanding of requirements for analysis of components such as brackets.

ACTIONS WILLIBE COMPLETED BY (DATE): -71 CORRECTIVE ACTION TAKEN TO PRECLUDE RECURRENCE: (a04ch evidence of actions taken)

Provide training to engineers responsible for performing analyses to reinforce specification review and understanding of requirements for analysis of components such as brackets.

...

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SUMITE BYri (pine name)L i._.._

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CONFIRMATION OF CORRECTIVE ACTIO /AKEN (To be completed by Flowserve QA after review of evidence)

EVDNC-E uFF/C, E-N-TTO CL----OSE?-Y- N'-D "- FURTH-E'R F-OL'LO-W UP R--EQUI-RED?'Y-"N'-

CRRECT IVE ACTION REVIEWED Q 4, - SIGNATURE 2 BY (QA Manager or Deigne /'f' FORM Q-985 REV. 2 Form No. Q-985 Rev. 2

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FLOWSE RVE 2

Training for Engineers Performing Design Analysis CAR 1384 Closeout UC "C

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1

I CAR 1384

• Customer design specification required that position indicators were to remain operable during seismic event.

Position indicator mounting brackets were not considered in seismic analysis.

Subsequent review found that the provided brackets were not adequate to maintain seismic qua lifaon of the position indicators.

In Context While the position indicators themselves were suitable for the application and qualified by the manufacturer, the mounting brackets used were not seismically sufficient and consequently nullified the qualification.

• Attachment of accessories to the valve is critical for component operation.

Prevent Reoccurrence 9 Thorough review and understanding of all customer purchase order and specification requirements.

o Appropriate analysis to substantiate compliance with customer requirements.

• Do not neglect accessories and mounting hardware when applicable.

• ' =.,,..,, u r* I IidiAMIly I*uI L 1*,*IWI  :

U.:U :4U p.m. U/-24-2U' b 9/9 FLOWSERVE, RALEIGH TRAINING RECORD Department: Engineering Date: 7M7/15

Subject:

CAR 1384 Closeout-,Training for Engineers Performing Desiin Analysis Na e(s) Initials'

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____ ____ __:54

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Length of session 20____m___nutes _____

Signature of Instructor