ML20116C703

Part 21 Rept Re Failures Identified by Waterford 3 Dedication Testing Process of 7 Commercial Grade Barksdale Pressure Switches

ML20116C703
Person / Time
Site:	Waterford
Issue date:	07/29/1996
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-96 W3F1-96-0114, W3F1-96-114, NUDOCS 9608010076
Download: ML20116C703 (4)

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h Enttrgy Operations. Inc.

Killona. LA 70066 I Tel 504 739 6242 am J. Fisicaro

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W3F1-96-0114 A4.05 )

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i July 29,1996 l U.S. Nuclear Regulatory Commission l ATTN: Document Control Desk l Washington, D.C. 20555 j

Subject:

Waterford 3 SES Docket No. 50-382 l License No. NPF-38 l Part 21 Reporting of Defects and Noncompliance Interim Report Gentlemen:

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l~ The purpose of this letter is to comply with 10CFR 21.21(a)(2) which states that if an J evaluation of an identified deviation or failure to comply potentially associated with a substantial safety hazard cannot be completed within 60 days from discovery of the deviation or failure to comply, an interim report is to be submitted describing the 4

deviation under evaluation and the date for completion of the evaluation.

Seven commercial grade Barksdale pressure switches, Model D1T-A150SS were i

purchased as quality class 3 through Alpha Process Sales. A commercial grade dedication evaluation was approved for use on accumulators for the Feed Water i isolation Valves and Component Cooling Water Isolation Valves to the Dry Cooling  !

Towers. The Feed Water and Component Cooling Water Isolation Valves are active j safety related components. The function of the pressure switch is to indicate when  !

instrument air accumulator pressure for these valves falls below an acceptable value. This indication is not a safety related function. The pressure switch interfaces with a non-safety annunciator power supply. The pressure switch forms part of the pressure boundary of the accumulator. This is a passive safety related function. Thus, the pressure switch is classified as a passive safety related component with a safety function of maintaining pressure integrity.

960801o076 960729 PDR ADOCK 05000382 S PDR

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1 Part 21 Reporting of Defects and Noncompliance Interim Report W3F1-96-0114 Page 2 July 29,1996 I

I One of the seven switches received was successfully tested by Waterford 3 for its intended use, dedicated and installed on Component Cooling Water to the Dry ,

Cooling Tower Isolation Valve during a component outage. The dedication test  !

required the switch to be connected to a clean source of instrument air and '

, pressurized to 187.8 psig. The switch was then inspected for leakage from the .

! diaphragm housing after a hold time of fifteen minutes. The test was conducted i L within the limits of the manufacturer's (Barksdale) published specification. The test was designed to demonstrate the items function of maintaining pressure boundary.

No discrepancies were identified.

A field inspection has been performed to determine in-service leakage. The switch was carefully examined along the process inlet connection, lower housing and -

conduit opening. There was no presence of leakage. Because the pressure switch  ;

l functions to detect any abnormalities in the accumulator supply for the CCW i isolation Valve, leakage of the magnitude observed when testing the defective  !

switches would likely cause an actuation of the alarm point controlled by this switch. .

l This alarm would be noted and the condition of the accumulator and pressure would  !

be investigated and evaluated. No operability concems have been posted against i this pressure switch. Also, a periodic task to calibrate this switch every 18 months .

provides a further opportunity to note failure of this switch. At this time, there is no '

evidence to dispute performance of the pressure switch installed. ,

The seismic qualification of the switch was justified by comparison to similar Barksdale pressure switches which had undergone seismic prototype testing.

However, this method has been identified as a nonconformance with the requirements of FSAR Appendix 3.10A. This switch is subject to FSAR criteria for l seismic qualification of non-nsss seismic category 1 instrument considerations. It has been determined that this dedication did not adequately address seismic considerations as set forth in the FSAR. Corrective action to address this nonconformance is in progress.

~ Unrelated to the discovery of this potential Part 21, Design Engineering has initiated documentation to replace the installed Barksdale pressure switch. This change is '

i based on Setpoint Document Change Package SPC 95-003-0 which has been  :

approved. Design Engineering is currently awaiting receipt of the new pressure  ;

switch. i I

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.. 1 Part 21 Reporting of Defects and Noncompliance interim Report W3F1-96-0114 Page 3 July 29,1996 l

While testing the remaining six switches, three of the six failed at approximately 30 psig of pressure. The test was terminated at this point and inspection showed that the leakage was along the diaphragm seam.- The failures were documented in i accordance with the Waterford 3 corrective action program. All six pressure switches were then removed from inventory and placed on hold. None of the six switches

- were dedicated nor were they installed in the plant. The dedication process did what it is designed to do.

The failures identified by the Waterford 3 dedication testing process were reviewed l for'10CFR Part 21 reportability on May 28,1996. This review was recorded as a potential Part 21 and the reportability determination was categorized as l

" indeterminate." Waterford 3 returned the six pressure switches to Barksdale Inc. on June 6,1996 and requested that a detailed failure analysis be forwarded to Waterford 3 by August 6,1996. Since the failure analysis has yet to be received, Waterford 3 is submitting this interim report. Upon receipt of the vendor's evaluation,  !

L results will be evaluated and immediately followed by a final part 21 reportability )

determination. As of July 26, the vendor was still gathering information from 4 Waterford 3. Nevertheless, we anticipate providing the necessary follow-up to this interim report by September 10,1996.

Since Waterford 3 purchased these parts as commercial grade we realize that the responsibility for assuring quality in a safety related application lies with us. Given j that the intent of part 21 was to invoke accountability primarily upon vendors and suppliers for the nuclear industry we feel that this interim report is conservative in nature. However, at this time the part 21 guidelines appear to be the most effective way of communicating this issue and in an effort to present this information in a timely manner we have chosen to apply the 60 day interim report submittal.

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4 Part 21 Reporting of Defects and Noncompliance Interim Report W3F1-96-0114 Page 4 July 29,1996 This information will be communicated to the industry through INPO's Nuclear Network Operating Experience Program. Should you have any questions please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.

Very truly yours, W

J.J. Fisicaro Director Nuclear Safety JJF/SSD/ssf cc: L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR R.B. McGehee l N.S. Reynolds I NRC Resident Inspectors Office  ;

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