IR 05000335/2022010
| ML22117A104 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/27/2022 |
| From: | James Baptist Division of Reactor Safety II |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2022010 | |
| Download: ML22117A104 (14) | |
Text
SUBJECT:
ST. LUCIE PLANT UNITS 1 AND 2 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000335/2022010 AND 05000389/2022010
Dear Mr. Coffey:
On March 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St. Lucie Plant Units 1 and 2. On April 1, 2022, the NRC inspectors discussed the results of this inspection with Mr. Dan DeBoer, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St. Lucie Plant Units 1 and 2.
April 27, 2022 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000335 and 05000389 License Nos. DPR-67 and NPF-16
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000335 and 05000389
License Numbers:
Report Numbers:
05000335/2022010 and 05000389/2022010
Enterprise Identifier:
I-2022-010-0022
Licensee:
Florida Power and Light Company
Facility:
St. Lucie Plant Units 1 and 2
Location:
Jensen Beach, FL
Inspection Dates:
February 28-March 18, 2022
Inspectors:
G. Ottenberg, Senior Reactor Inspector
K. Kirchbaum, Operations Engineer
B. Smith, Nuclear Systems Engineer
M. Yeminy, Contractor
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at St. Lucie Plant Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Consider Maximum Transmitted Torque in Motor Operated Valve Structural Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2022010-01 Open/Closed None (NPP)71111.21N.02 The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, subsection 55a(b)(3)(ii), when the licensee did not establish a motor operated valve (MOV) program that ensured the butterfly valves within the program continued to be capable of performing their function. Specifically, the licensee did not appropriately include and consider the Electric Power Research Institute (EPRI) Performance Prediction Methodology (PPM) calculated maximum transmitted torque in their MOV program instructions for evaluating the acceptability of the structural limitations of the butterfly valve weak link and the actuator ratings.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection, unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met, consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a.
Evaluated whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
Specific Guidance b.
Evaluated whether the sampled POVs are capable of performing their design-basis functions.
c.
Evaluated whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d.
Evaluated maintenance activities, including a walkdown of the sampled POVs (if accessible).
(1)2-MV-07-2A, Safety Injection Pump Containment Sump Suction Valve (2)1-HCV-3625, 1A1 Low Pressure Safety Injection Cold Leg Injection Isolation Valve (3)2-MV-08-19B, Main Steamline Atmospheric Dump Valve (4)1-2515, Primary Isolation Valve (Penetration P-26) for Reactor Coolant Loop 1B1 Letdown (5)2-MV-08-12, Auxiliary Feedwater Pump Turbine Steam Supply Valve (6)2-MV-09-12, 2C Auxiliary Feedwater Flow Control Valve (7)1-HCV-08-1A, 1A Main Steam Isolation Valve (8)2-HCV-09-2A, Main Feedwater Isolation Valve B Train at Penetration P-4
INSPECTION RESULTS
Failure to Consider Maximum Transmitted Torque in Motor Operated Valve Structural Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2022010-01 Open/Closed None (NPP)71111.21N.02 The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, subsection 55a(b)(3)(ii), when the licensee did not establish a motor operated valve (MOV) program that ensured the butterfly valves within the program continued to be capable of performing their function. Specifically, the licensee did not appropriately include and consider the Electric Power Research Institute (EPRI) Performance Prediction Methodology (PPM) calculated maximum transmitted torque in their MOV program instructions for evaluating the acceptability of the structural limitations of the butterfly valve weak link and the actuator ratings.
Description:
The inspectors reviewed the safety injection pump containment sump suction valve, 2-MV-07-2A, to evaluate its ability to open and close according to its design requirements. The valve has safety functions to open to allow flow from the containment sump to the suction of the safety injection and containment spray pumps, and to close to isolate a limited leakage passive failure that is postulated to occur downstream of the valve. To determine the torque required to open and close the valve, the licensee utilized the EPRI PPM which involves the use of computer software to perform the calculation. The EPRI PPM software also calculates the maximum transmitted torque, which is the maximum valve stem torque predicted by the model, and its magnitude is equal to the larger of the required actuation torque and the peak hydrodynamic torque. This torque is used to determine if the torque rating of the actuator will be exceeded and to evaluate the structural adequacy of the valve stem and its connections to the actuator and to the disk. The program described in TR-103237, EPRI MOV Performance Prediction Program, details that the maximum transmitted torque is the additional torque calculated by the model for use in structural evaluation of MOV components.
The inspectors identified that the valve structural limits for the 2-MV-07-2A valve were determined in evaluations, 1331762-DD-1, Weaklink Analysis for 24-Model NMKII Butterfly Valve with Limitorque H3BC / SMB-00-10 Operator Tag #: Unit 1-MV-07-2A & MV-07-2B, and in DD-99, Engineering Analysis of Torque Requirements for Nuclear Butterfly Valves-FPL P.O. #C9293491253, and that the Limitorque actuator ratings were contained in Limitorque sizing and selection documents (SELs). The inspectors determined the licensee had not compared the valve structural limits determined in 1331762-DD-1 and DD-99 and the actuator structural limits in the SELs to the maximum transmitted torque value calculated by the EPRI PPM and instead inappropriately only compared the structural limits to the less limiting calculated value of required torque. Further, the inspectors determined that the maximum transmitted torque value calculated by the EPRI PPM when evaluating the close stroke direction exceeded the calculated valve weak link torque values and the published actuator rated torque values.
Upon review of the licensees failure to compare the maximum transmitted torque to the valve weak link and the actuator ratings, the inspectors determined that STD-M-003, Engineering Guidelines for Sizing and Evaluation of Limitorque Motor Operators, did not provide guidance describing the need to compare the valve structural limitations and actuator ratings to the maximum transmitted torque, and only provided guidance to compare the valve structural limits and actuator ratings to the calculated required torque. Once it was discovered the comparison of the structural limits to the maximum transmitted torque was never completed, the licensee entered the issue into their corrective action program for evaluation.
Corrective Actions: Florida Power and Light personnel entered the issue into their corrective action program for further evaluation. During the week of March 21, 2022, the licensee re-evaluated the valve closure scenario and determined the original calculation contained system parameters (differential pressure and flow) that were overly conservative and not required by the valves design basis. The licensee reduced the assumption for expected flow in the system and re-ran the PPM software and obtained results that supported that the valve and actuator structural components would not be over-stressed. The licensee plans to complete calculations that are more reflective of the actual valve requirements and incorporate more specific instructions into their MOV program guidance to address the maximum transmitted torque for quarter turn valves.
Corrective Action References: AR 2422566
Performance Assessment:
Performance Deficiency: The licensee failed to appropriately include and consider the EPRI PPM calculated maximum transmitted torque in their MOV program instructions for evaluating the acceptability of the structural limitations of the butterfly valve weak link and the actuator ratings. The licensee should have been aware that this potentially more limiting torque value had the potential to overload valve and actuator components through their use of the EPRI PPM.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to verify the capability of the valve and actuator sub-components to withstand the applied forces that would be present during and following design basis events.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating SSC, and the SSC maintained its operability or PRA functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR 50.55a(b)(3)(ii) required, in part, OM condition: Motor-Operated Valve (MOV) testing. Licensees must comply with the provisions for testing MOVs in ASME OM Code, and must establish a program to ensure that MOVs continue to be capable of performing their design basis safety functions. Contrary to the above, the licensee did not establish a program that ensured the butterfly valves within the program continued to be capable of performing their function. Specifically, butterfly valves may experience applied torques higher than those calculated for the required torque for the valve, and the associated higher stress applied to the valve and actuator sub-components was not required to be evaluated by the MOV program instructions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 18, 2022, the inspectors presented the onsite inspection results to Mr. Carlos Santos and other members of the licensee staff.
On April 1, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. Dan DeBoer, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DC-025
Required Thrust and Weak Link Calculations-required
thrust and maximum thrust calculations
DD-99
Engineering Analysis of Torque Requirements for
Nuclear Butterfly Valves-FPL P.O. #C9293491253
01/07/1993
JPN-PSL-SEMP-
93-036
Pressure Locking and Thermal Binding of Motor
Operated Gate Valves
L-MECH-CALC-017
Evaluation of the Calculations Made by Florida Power
and Light for the Minimum and Maximum Torque
Requirements of the Butterfly Motor Operated Valves in
the Generic Letter 89-10 Program at St. Lucie Unit 2
& 17
MA-23698
Actuator Calculation Criteria and Capability Margins
E
PSL-1-FJE-90-002
GL 89-10 MOV Cable Voltage Drop, St. Lucie Unit 1
PSL-1FJM-91-011
NRC Generic Letter 89-10 MOV Design Basis
Differential Pressure Determination
PSL-1FJM-91-017
NRC Generic Letter 89-10 Gate/Globe Valve Motor-
Operator Evaluations
PSL-2-J-E-90-003
GL 89-10 MOV Cable Voltage Drop, St. Lucie Unit 2
PSL-2FJE-94-003
GL 89-10 125 VDC Motor Operated Valve Cable Voltage
Drop, St. Lucie Unit 2
PSL-2FJM-91-046
St. Lucie Unit 2 Generic Letter 89-10 Design Basis
Differential Pressures for Motor Operated Valves
PSL-2FJM-91-048
St. Lucie Unit 2 Generic Letter 89-10 Gate and Globe
Valve Required Stem Thrust and Actuator Torque
Switch Setting Evaluation
Calculations
PSL-2FJM-93-002
GL 89-10 Differential Pressure Calculation for St. Lucie
Unit 2 HPSI and AFW Motor Operated Valves
& 6
Corrective Action
Documents
ARs 02268907,
298807,
2150607,
2396453,
2006410
71111.21N.02
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
22 POV Insp-NOP Guidance for MOV Jogging
Inadequate
03/04/2022
22 POV Insp-MV-07-2A Motor Insulation
Documentation Documentation Only Issue with EQ Doc
Pac 2998-A-451-3.1
03/15/2022
NRC ISFSI MOV Inspection - MOV T-Drain Painted
Over
03/17/2022
U1 ECCS FATHOM Hydraulic Model Error, HCV-3625
K-Factor
03/17/2022
Calculation PSL-1FJM-91-01 Valve Thrust Discrepancy
03/17/2022
22 POV Insp-Eval Effects of MOV Jogging / Throttling
03/18/2022
22 POV Insp-Use of PPM When Classifying MOVs
03/18/2022
2-MV-07-2A MTR Torque Derate Not Evaluated,
Limitorque 93-03
03/22/2022
Corrective Action
Documents
Resulting from
Inspection
2-MV-07-2A MOV PPM Calc Max Torque Exceeds
03/24/2022
2998-1871
600# MO Valves Tag # I-MV-09-11&12
2998-19252
4-600 Weld Ends Carbon Steel Double Disk Gate Valve
for SMP-00-10 (D.C.) Limitorque Actuator
2998-19745
4-600 Weld Ends Carbon Steel Model 70-28-2 Globe
Control Valve W/SMP-000-5 Limitorque Actuator
2998-2236
24in M/O BFLY VL No. 1-2-MV-07-2A & 2B 8770-3820
2998-2237
Cross Section Dwg for I-MV-07-1A, 1B, 2A
2998-3847
Mot. Op. for Valve I-MV-07-2A & 2B
2998-9695
Schematic for Anchor Darling Self Contained Hydraulic
Actuator Non-Redundant
2998-B-327 Sheet
299
Control Wiring Diagram Reactor Sump Valve MV-07-2A
2998-B-327 Sheet
Control Wiring Diagram General Notes
2998-G-078 Sheet
130B
Flow Diagram Safety Injection System
Drawings
2998-G-088 Sheet
Flow Diagram Containment Spray and Refueling Water
Systems
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2998-G-125 Sheet
SI-N-I
Large Bore Piping Isometric Safety Injection
8770-1375
SI Motor Valve HCV-3615, 3625, 3635, 3645
8770-1574
Limitorque Valve Control
8770-B-327 Sheet
260
Low Press Safety Inject Flow Cont Valve HCV-3625
8770-G-078 Sheet
130A
Flow Diagram Safety Injection System
8770-G-078 Sheet
130B
Flow Diagram Safety Injection System
8770-G-078 Sheet
131B
Flow Diagram Safety Injection System
8770-G-078, Sheet
131A
Flow Diagram Safety Injection System
Replaced Motor on Limitorque Actuator on MV-07-2A
with Equivalent Motor Per IEE 76263.
10/30/2006
Engineering
Changes
PCM 200-283-16
Main Feedwater Isolation Valves Relief Orifice
Modification
1331762-00-1
WEAKLINK ANALYSIS for 24"- Model NMKII Butterfly
Valve With Limitorque H3BC / SMB-00-10 Operator Tag
- Unit 1-MV-07-2A & MV-07-2B
Document No.
2576C
St. Lucie MOV Periodic Verification Classification
JPN-PSL-SEMP-
93-031
Substantial Safety Hazard Evaluation of Limitorque
Valve Actuators with AC Motors
JPN-PSL-SEMS-
96-070
Evaluation of EPRI MOV Performance Prediction
Program Results-MPR Report 1759
MPR Report 1759,
Part 16
Evaluation of Stem Thrust Requirements for MV-07-2A
and MV-07-2B Using the EPRI MOV Globe Valve
Performance Prediction Methodology
06/17/1996
PSL-ENG-SEMS-
19-002
Evaluation of Conditions/Limitations in the NRC Safety
Evaluation Report on the EPRI MOV PPM
Engineering
Evaluations
PSL-ENG-SEMS-
97-062
GL 89-10 MOV Program Load Sensitive Behavior
Engineering Evaluation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
01855973
Root Cause Evaluation for Unit 1 Automatic Reactor Trip
due to Failure of 1B Main Steam Isolation Valve
04/23/2013
2998-4508
Henry Pratt Butterfly Valves
3332C
Kalsi Report for St. Lucie Unit 1 MSIV Redesign for EPU
Conditions Post March 2013 Event
8770-6271
VELAN VALVES AND MAINTENANCE
INSTRUCTIONS (Pl-1184-N)
CN-SEE-II-09-4
St. Lucie Unit 1 Emergency Core Cooling System
(ECCS) Delivery and Surveillance Test Requirements
DBD-CS-2
Containment Spray System
DBD-SDC-1
Low Pressure Safety Injection and Shutdown Cooling
System
EQUIPMENT
QUALIFICATION
DOCUMENTATION
PACKAGE 2998-A-
451-3.1
Limitorque Corporation Motor Operators
Inservice Testing (IST) Program
Motor Operated Valve Program
SPEC-M-188
Specification for Main Steam Isolation Valve
Replacement Actuator
Miscellaneous
STD-M-003
Engineering Guidelines for Sizing and Evaluation of
Limitorque Motor Operators
2-OSP-09.01C
2C Auxiliary Feedwater Pump Code Run
ADM-03.04
Motor Operated Valve Trending and Monitoring
ADM-29.01A
Inservice Testing (IST) Program for Pumps and Valves
Inservice Testing Procedure
ER-AA-113-1007-
10000
Preconditioning of Structures, Systems and Components
Motor Operated Valve Program
Limitorque Motor Operated Valve Testing and Actuator
Inspections
Procedures
Limitorque Motor Operated Valve Stem Lube and Full
Actuator Inspection
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
40765714-01,
37013972-01,
40568241-01,
40554564-01,
40717669-01,
40774350-01,
40641408-01,
40641408-07,
40605121-01,
40758776-01,
40773331-01,
40696151-01,
40718324-04