ML17228A620

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Insp Repts 50-335/94-11 & 50-389/94-11 on 940502-06. Violation Noted.Major Areas Inspected:Licensee MOV Program Implementation to Meet Commitments in Response to GL 89-10, Safety-Related MOV Testing & Surveillance
ML17228A620
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 06/07/1994
From: Casto C, Girard E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17228A617 List:
References
50-335-94-11, 50-389-94-11, GL-89-10, NUDOCS 9406270262
Download: ML17228A620 (24)


See also: IR 05000335/1994011

Text

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++*++

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W., SUITE 2900

ATLANTA,GEORGIA 303234199

Licensee:

Florida Power

and Light Company

9250 West Flagler Street

Miami, FL

33102

Docket Nos.:

50-335

and 50-389

Facility Name:

St.

Lucie

1 and

2

Inspection

Conducted:

ay

2 - 6,

1994

r1

ead

Ins ector:

Vc~

L

p

~

~

+ Girar

Other Inspector:

H. Hiller

Report Nos.:

50-335/94-11

and 50-389/94-11

License Nos.:

DPR-67

and NPF-16

Date Signe

Approved by:

Other

Personnel:

H.

olbrook,

Co

ultant

(EG&G Idaho,

Incorporated)

y~!

C. Casto,

Chief

Date Signed

Test

Programs

Section

Engineering

Branch

Division of Reactor Safety

SUMMARY

Scope:

This special,

announced

inspection

examined the implementation of the

licensee's

motor-operated

valve

(HOV) program to meet

commitments in response

to Generic Letter (GL) 89-10,

"Safety-Related

Motor-Operated

Valve Testing

and

Surveillance."

The inspectors utilized the guidance

provided in Temporary

Instruction (TI) 2515/109 (Part 2), "Inspection Requirements for Generic Letter 89-10, Safety-Related

Motor-Operated

Valve Testing

and Surveillance."

As delineated

in Part

2 of TI 2515/109, this inspection

was the initial review

of the licensee's

implementation of its

GL 89-10 program.

The inspectors

conducted

interviews with licensee

personnel

and selectively

examined records,

procedures,

and hardware to evaluate

the licensee's

implementation of the

GL 89-10 program.

They also assessed

the licensee's

actions in response

to

a related

open item and other concerns identified in

previous

NRC inspections.

9406270262 9406i3

PDR

ADOCK 05000335

Q

Results:

The inspectors

concluded that the licensee

was in the process

of implementing

a generally satisfactory

GL 89-10

HOV program.

However,

a violation and two

inspector followup items (IFIs) were identified, representing

weaknesses

in

the program implementation.

The violation and IFIs are

summarized

below and

described

in detail in the indicated report sections:

(Open)

Violation 50-335, 389/94-11-01,

Inadequate

Corrective Action for

HOVs Which Stalled Ouring Surveillances.

(Section 2.5.b)

In three instances

where

HOVs stalled during surveillance tests,

the

licensee failed to document possible

damage to and corrective action

for the valves

and actuators.

There were

no recorded calculations

of the thrust

and torque

caused

by stall to determine if limits

prescribed for the actuator

by the valve manufacturers

were

exceeded.

NRC inspectors'alculations

found the thrust produced

by

stall

was about

230 percent of the actuator thrust rating and

160

percent of its torque rating.

The thrust was

125 percent of valve

limit.

(Note:

The licensee did document

and address

possible

damage

and corrective actions for motors

and overload relays.)

(Open)

IFI 50-335,

389/94-11-02,

Inadequate

Recognition of HOV Test

Pressure

and Flow. (Section 2.3)

The licensee's

design-basis

differential pressure test for valve 1-

V-3660 did not accurately

determine differential pressure

at the

valve and did not assure

representative

design-basis

flow.

(Open)

IFI 50-335, 389/94-11-03,

Lack of Instructions or Guidance for

Trending

and Periodic Evaluation of HOV Failures.

(Section 2.5.a)

There

was

no procedure

or instruction specifying

who was responsible

to perform and evaluate

trend reports,

when the reports

were to

performed,

who would initiate recommendations

and corrective

actions,

how frequently the reports

were to be issued,

etc.

The licensee's

program implementation

was scheduled

to be completed

60 days

following start-up

from Cycle

13 refueling outage

(scheduled fall 1994) for

Unit

1 and Cycle

9 refueling outage

(scheduled fall 1995) for Unit 2.

Approximately 2/3 of the gate

and globe valves

had

been set

and tested

but

a

methodology

had not been established

for verifying the capabilities of

butterfly valves.

These

and other important aspects

of the program that

had

not been fully developed

and/or

implemented will require evaluation in a

subsequent

NRC inspection.

The inspectors specifically identified the

following issues for further inspection,

together with the violation and

followup items described

previously:

(1)

Completion of the development

and implementation of post maintenance

test

requirements.

(Section 2.4)

(2)

Establishment

and implementation of criteria for determining the

capabilities of butterfly valves.

(Section 2.6)

(3)

Revision of calculations for Direct Current

(DC) powered

NOVs (pullout

efficiency to be used in place of run efficiency).

(Section 2.2)

(4)

Justification for the adequacy of the method

used to extrapolate

HOV test

results to design-basis

conditions.

(Section 2.3)

(5)

Justification for the

HOV stem friction coefficient assumed

in

thrust/torque calculations.

(Section 2.2)

(6)

Completion of the development

and implementation of criteria for periodic

verification.

(Section 2.4)

(7)

Completion of the remaining setting

and testing of valves.

(Section 2.6)

(8)

Revision of program

and test procedures

to require that thrust margins

be

adequate

to account for appropriate uncertainties

(such

as torque switch

repeatability).

(Section 2.3)

(9)

Results of internal inspection of valve 1-V-3660.

(Section 2.3)

Previously identified IFI 50-335,

389/92-25-01

was closed

by the inspectors

based

on the review, described

in Section

2. 10.a,

which identified the above

violation.

Additionally, concerns identified in the previous

NRC inspection

(50-335, 389/91-18) of the licensee's

GL 89-10 program,

were either found

adequately

resolved

or will be addressed

in the

GL 89-10 closeout

inspection

for St. Lucie performed

by Region II.

The inspectors

observed that the quality of diagnostic data

used

by the

licensee

was particularly good

and considered this

a strength.

REPORT

DETAILS

Persons

Contacted

  • L. Bearror, guality Assurance/guality

Control

  • J. Connor, Technical Staff
  • J. Cook, Electrical Haintenance
  • W. Dean,

Supervisor,

Electrical Maintenance

  • J. Hallem, Technical Staff Engineer
  • G. Madden,

Nuclear Reactor Regulation Interface,

Licensing

  • J. Hanso,

Engineer,

Mechanical

Engineering

  • L, McLaughlin, Licensing Manager
  • K. Hohindroo,

Production

Engineering

Group Manager

  • D. Sager,

Vice President

- Plant St. Lucie

  • C. White,

Commitment Tracking

and Routine Reports,

Licensing

  • R. Winnard,

Juno Licensing

  • J. Zudans,

Lead Engineer,

Mechanical

Engineering

NRC Personnel

2.0

  • S. Elrod, Senior Resident

Inspector

  • H. Hiller, Resident

Inspector

  • Denotes personnel

that attended

the exit meeting.

Acronyms

and initialisms used throughout this report are listed in the

last paragraph.

GENERIC LETTER (GL) 89-10

"SAFETY-RELATED MOTOR-OPERATED VALVE [MOV]

TESTING AND SURVEILLANCE"

(2515/109)

On June

28,

1989, the

NRC issued

GL 89-10, which requested

licensees

and

construction permit holders to establish

a program to ensure that switch

settings for safety-related

HOVs were selected,

set,

and maintained

properly.

Subsequently,

six supplements

to the

GL have

been

issued.

NRC

inspections of licensee

actions

implementing

commitments to

GL 89-10

and

its supplements

have

been

conducted

based

on guidance

provided in

Temporary Instruction (TI) 2515/109,

"Inspection Requirements

for Generic Letter 89-10, Safety-Related

Motor-Operated

Valve Testing

and

Surveillance."

TI 2515/109 is divided into Part

1,

"Program Review," and

Part 2, "Verification of Program Implementation."

The current inspection is the initial TI 2515/109 Part

2 program

implementation inspection.

The TI 2515/109 Part

1 program review for St.

Lucie was conducted

September

9 through 13,. 1991,

and .was documented

in

NRC Inspection

Report 50-335,

389/91-18,

dated

November

18,

1991.

The principal focus of this inspection

was to evaluate

in depth the

implementation of GL 89-10 for a sample of HOVs selected

from the

licensee's

program.

The

HOV sample

was chosen

from a list of valves that

had received differential pressure

(DP) testing.

The majority of the

valves selected

were gate valves with high design-basis

DP

(DBDP)

operating

requirements.

The

MOVs in the sample

were

as follows:

Valve

Number

Function

Size

Type

1-V-3480

1A Low Pressure

Safety Injection

Hot Leg Suction Valve

10 inch

Gate

1-HCV-3617

Auxiliary High Pressure

Safety

Injection Header

Flow Control

Valve to Loop IA2

2 inch

Globe

1-V-3660

2-V-3480

2-HCV-3615

High Pressure

Safety Injection

Pump Recirculation

To Refueling

Water Tank Isolation Valve

2A Low Pressure

Safety Injection

Hot Leg Suction Valve

Loop 2A2 Low Pressure

Safety

Injection Header Isolation Valve

3 inch

Gate

10 inch

Gate

6 inch

Globe

2-V-3654

High Pressure

Safety Injection

2B

Isolation Valve

6 inch

Gate

2-V-3658

2-V-3664

2-MV-08-13

Shutdown Cooling Heat Exchanger

2B Inlet Isolation Valve

2A Low Pressure

Safety Injection

Hot Leg Suction Valve

2C Auxiliary Feedwater

Pump Steam

Admission Valve

12 inch

Gate

10 inch

Gate

4 inch

Gate

2-MV-09-10

2B Auxiliary Feedwater

Discharge

Valve

4 inch

Globe

This inspection

also evaluated

actions which the licensee

had taken to

correct

a related violation and weaknesses

identified in previous

inspections,

as described

in Section

2.10 of this report.

Based

on this, the inspectors

concluded that the licensee

was

implementing

an acceptable

MOV program in response

to

GL 89-10.

However,

some weaknesses

were identified.

Additional

NRC inspection is planned to

complete the evaluation of some

areas

and to address

specific findings

identified below.

2. 1

Desi n-Basis

Reviews

For the above

sample of 10 MOVs, the inspectors

reviewed the licensee's

Generic Letter 89-10 Design-Basis Differential Pressure

(DBDP)

Calculations,

applicable operational

procedures,

system flow drawings,

pump curves,

and the design-basis

documents.

They verified that the

maximum flow and differential pressure

were determined for each

MOV.

Calculations for differential pressure,

voltage, flow, and temperature

2.2

were reviewed

and verified to be complete

and correct.

Determinations of

thrust

and torque were verified to use appropriate

inputs of the design

DP, voltage,

and temperature

corrected

motor torque capabilities.

The

inspectors verified that the licensee

completed

the

DBDP calculations for

all the safety-related

systems

and addressed

flow.

The licensee

had

been notified of the effects of elevated

temperature

on

motor torque through

a Potential

10 CFR Part 21 Notice dated

Hay 13,

1993,

and Technical

Update 93-03

(Harch

1993)

issued

by Limitorque

Corporation.

The licensee

issued Corrective Action Request

070593 dated

September

15,

1993, to initiate corrective action for the

HOV motors.

Engineering

Evaluation

JPN-SEHP-93-031

was initiated to address

the

effects of elevated

temperature

on the

HOVs and

recommend corrective

action.

The inspectors verified that the licensee

implemented

appropriate

corrective action

by revising the calculations for reduced

motor torque of the affected

HOVs.

The inspectors

concluded the licensee

had adequately

implemented the

design-basis

recommendations

of GL 89-10 for design-basis

reviews.

HOV Sizin

and Switch Settin

The inspectors

reviewed the licensee's

documentation for determination of

design-basis

thrust/torque

requirements for 5 of their selected

sample of

10 valves:

I-HCV-3617, 1-V-3660, 2-V-3654, 2-V-3664,

and 2-HV-08-13.

The licensee's

calculation of thrust requirements

was found to use

a

standard

industry thrust equation with a valve factor assumption of 0.50

for wedge gate valves

and

1. 10 for globe valves.

For determination of

actuator output thrust capability, the licensee

assumed

a stem friction

coefficient of 0.20.

Further,

a margin of approximately

10 percent

was

incorporated to address

HOV load sensitive

behavior (also

known as "rate

of loading" ).

Minimum thrust requirements for setting of actuator torque

switches

were adjusted to account for diagnostic

equipment

inaccuracy

and

torque switch repeatability.

The inspectors

noted that the licensee

had calculated

stem friction

coefficients using static test data for the purpose of justifying their

assumed

0.20 stem friction coefficient.

The inspectors

discussed

with

licensee

personnel

the importance of measuring

stem friction coefficient

under test conditions that are representative

of design-basis

conditions.

Licensee

personnel

stated this would be considered

in developing the

justification for their assumed

stem friction coefficient.

Region II

will review the licensee's justification during

a future inspection.

The licensee's

actuator manufacturer,

Limitorque, is understood

to have

recently

recommended

that pullout efficiency be used in place of run

efficiency for determination of actuator capability in the closing

direction for DC powered

HOVs.

Licensee

personnel

stated that

an

informal review of the impact of this information had

been

completed

and

that no concerns

were identified.

They indicated that use of pullout

efficiency for the closing direction for DC HOVs will be incorporated

by

2.3

revising the formal calculations.

Region II will review the result of

using pullout efficiencies during

a future inspection.

Desi n-Basis

Ca abilit

For their selected

sample of 10 valves,

the inspectors

examined

the

static test results,

dynamic test

packages,

and post-test

review

packages.

The dynamic test data

was evaluated

by the licensee

using

an

industry standard

equation,

the valves'rifice diameters,

and the

dynamic test conditions.

The evaluation indicated closing gate valve

factors

up to 1. 10 and load sensitive

behavior

as high as

6 percent.

Stem friction coefficients for the sampled

valves were

as high as 0.21

under static test conditions

(see Appendix).

Based

on this data, it did

not appear that the licensee's

0.50 valve factor assumption for gate

valves

was always bounding.

However, for those valves with high valve

factors,

the thrust margins applied to settings

had

been sufficient to

assure

satisfactory

performance.

The capabilities of sister valves

had

been demonstrated

by testing

under dynamic conditions.

To determine the operability of an

NOV, the licensee linearly

extrapolated

the thrust necessary

to overcome differential pressure

to

design-basis

conditions.

Licensee

personnel

stated that

a justification

for use of linear extrapolations

was under development.

Region II will

verify the adequacy of the justification in

a subsequent

GL 89-10

inspection.

The licensee's

Calculation

PSL-BFJH-93-029,

"NRC Generic Letter 89-10

Motor Operated

Valve Diagnostic Test Results Evaluation," issued

December

9,

1993,

documented

the method

used to extrapolate

dynamic test results

to design-basis

conditions,

where necessary.

This method stipulated that

the closing extrapolated

load is compared to the thrust measured

at

control switch trip (CST) to ensure that the torque switch is set

adequately for design-basis

conditions.

However, the inspectors

found

that the document did not specify any minimum level of margin that would

be necessary

to account for uncertainties

(e.g.,

torque switch

repeatability or degradation

in valve/actuator

performance

from one test

to the next).

Licensee

personnel

stated

they would review the guidance

on this issue provided in Supplement

6 of GL 89-10,

and that their

program

and differential pressure test procedures

would be revised to

require that thrust margins

be adequate

to account for appropriate

uncertainties

(such

as torque switch repeatability).

Region II will

review the licensee's

resolution of this issue during

a future

inspection.

The licensee's

dynamic test evaluation for valve 1-V-3660 determined that

this

3 inch Velan flex-wedge gate valve

(Low Pressure/High

Pressure

Safety Injection

Pump Recirculation to Refueling Water Tank)

had

a valve

factor of 1. 10.

The inspectors'eview

of the diagnostic force trace

taken during the dynamic test indicated that flow isolation

was marked

just prior to the point where the valve appeared

to reach

hard seat

contact.

However, they noted that the force trace

had the characteristic

of a globe valve; there

was

no closing force plateau just following flow

isolation.

Such

a plateau is expected

because

of the uniformity of force

when the disc is sliding on the gate valve's seating

surface without any

change

in DP.

The seating portion of the static force trace

showed the

same

shape

as the dynamic test,

which caused

the inspectors

to question

the licensee's

choice of flow isolation

and determination of valve

factor.

After review of the static

and dynamic traces,

licensee

personnel

agreed that flow isolation was incorrectly marked,

leading to

an incorrect determination

oF valve factor.

There

was

no clear

indication of flow isolation

and the true valve factor was indeterminant.

The inspectors'eview

of the traces for a sister valve, located in

series with 1-V-3660 and tested

under the

same

dynamic conditions,

showed

normal gate valve flow isolation, characteristics

and

a valve factor of

0.51.

A possible explanation for the unusual

seating characteristic

is

an offset or deformation of the disc guides.

Licensee

personnel

indicated that,

because

of the unusual

trace,

1-V-3660 was scheduled for

inspection of the valve internals at the next outage of adequate

duration.

The licensee's

investigation of 1-V-3660 will be examined in a

subsequent

GL 89-10 inspection.

The inspectors

review of the dynamic test lineup and test results for 1-

V-3660 raised

two issues:

1-V-3660 was located in a recirculation line which had

a restricting

orifice, check valve,

and manual

valve between

the

pumps

and the

NOV.

The licensee

used

a pump discharge

pressure

gage to determine

the upstream

pressure for the dynamic test.

Because of the pressure

drop caused

by the components

located

between

the

pump and 1-V-3660,

the true pressure

at the valve was not measured

during testing.

Additionally, no assessment

for the difference

was noted in the test

results,

such that

a satisfactory

comparison to design-basis

conditions might be made.

Two pumps would be in operation during the identified design-basis

conditions for 1-V-3660.

However, the dynamic test

was conducted

with only one

pump running, providing approximately one-half the

volumetric flow rate that would be present

during the design-basis

event.

As the effects of flow on valve performance

are not readily

quantified, test conditions should simulate design-basis

flow as

near practical to facilitate assessment.

Licensee

personnel

indicated they would consider the above

when

evaluating the results of previous dynamic tests

and when developing

future dynamic test lineups.

The licensee's

failure to account for test

pressure

drops

and to assure

design-basis

flow was considered

a weakness.

It is identified as Inspector

Followup Item 50-335,

389/94-11-02,

Inadequate

Recognition of HOV Test Pressure

and flow.

Region II will

review the licensee's

related efforts during

a future inspection.

Based

on the data

examined,

the inspectors

concluded that the licensee's

testing

program for the

GL 89-10 program

HOVs provides the assurance

that

the tested

MOVs will perform their intended safety function.

2.4

Periodic Verification of HOV Ca abilit

2.5

Recommended

action "d" of Generic Letter (GL) 89-10 requested

the

preparation

or revision of procedures

to ensure that adequate

HOV switch

settings

are determined

and maintained throughout the life of the plant.

Section "j" of GL 89-10

recommends

surveillance to confirm the adequacy

of the settings.

The interval of the surveillance is to be based

on the

safety importance of the

HOV as well as its maintenance

and performance

history, but was

recommended

not to exceed five years or three refueling

outages.

Further,

GL 89-10

recommended

that the capability of the

HOV be

verified if the

HOV was replaced,

modified, or overhauled to an extent

that the existing test results

are not representative

of the

HOV.

Licensee

personnel

informed the inspectors that development of a program

for periodic verification of the design-basis

capability of GL 89-10

HOVs

had not been

completed.

Electrical Haintenance

Hotor Operated

Valve

Program Hanual,

Section

F, indicated that periodic diagnostic testing

would be performed

on all

HOVs included in the scope of the

GL 89-10

program

on

a

5 year schedule

and that the schedule

would be developed

following full implementation of initial baseline testing.

The

inspectors

were informed that static diagnostic testing would be used for

the verifications

and responded

that this was not yet an adequately

justified method.

Region II will assess

the adequacy of the licensee's

periodic verification of design-basis

capability during

a future

inspection.

The inspectors

found that,

in accordance

with procedure

HP 0950050,

"Post

Haintenance

Testing of Limitorque Hotor Operated

Valves," the testing

criteria for specific maintenance activities were to be determined

by the

HOV Coordinator.

The inspectors

questioned

whether this provided

adequate

control.

Licensee

personnel

stated

the procedure

would be

upgraded to include testing criteria for the various maintenance

activities.

Region II will verify the implementation

and adequacy of the

post maintenance

testing during

a future inspection.

HOV Failures

Corrective Actions

and Trendin

Recommended

action "h" of the generic letter requests

that licensees

analyze

and justify each

HOV failure and corrective action.

The

documentation

should include the results

and history of each as-found

deteriorated

condition, malfunction, test,

inspection,

analysis,

repair,

or alteration.

All documentation

should. be. retained

and reported in

accordance

with plant requirements.

It was also suggested

that the

material

be periodically examined

(every two years or after each

refueling outage after program implementation)

as part of the monitoring

and feedback effort to establish

trends of HOV operability.

a.

Trendin

and Periodic Examination of Failures

and

De radation

The inspectors

assessed

the following examples of the licensee's

trending

and periodic examination of HOV degradation

and failure data:

Motor Operated

Valve Trending

Program Report for valve 2-MV-09-10

(This report contained descriptive information, manufacturers

data,

dates of testing

and preventive maintenance,

and trend data

on

parameters

such

as stroke time,

megger results,

stem factor,

peak

thrust,

and thrust at control switch trip.

The report contained

diagnostic results

from 1994;

and stroke time, current,

and megger

data

from 1992

and 1994.)

Nuclear Plant Reliability Data System

Component Failure Analysis

Report

Component Failure Comparison

(Unit 2), dated July 2,

1993.

(This report compared

the St.

Lucie and industry failure rate

and

provided brief descriptions of the valve failures,

causes,

and

corrective actions for the period from October

1,

1991 through March

31,

1993.)

Maintenance

Procedure

No. 0940069,

Rev.

11, Preventive

Maintenance

of Non-Environmentally gualified Limitorque Motor Operated

Valve

Actuators.

(This was provided

by licensee

personnel

as

an example

to show that trendable

data

was being collected through preventive

maintenance

procedures.

The inspectors

found that it required

inspections

and recording of various data that could

be used to

identify degradation

and could

be trended.

Examples of the

inspections

included

stem thread condition,

run current,

and

functioning of position indication lights.

The inspectors verified

similar data

was recorded for environmentally qualified

MOV

actuators

through Procedure

0940072,

Rev. 8.)

The inspectors

review of the above indicated that trending

and

examination of MOV failures

and degradation

had

been initiated, except

that there were

no administrative controls governing the process.

There

was

no procedure

or instruction specifying

who was responsible

to perform

and evaluate

trend reports,

when the reports

were to performed,

who would

initiate recommendations

and corrective actions,

etc.

This was

considered

a weakness.

Licensee

personnel

indicated that this finding

would be evaluated

and appropriate

action would be taken.

The matter

was

identified as Inspector

Followup Item 50-335, 389/94-11-03,

Lack of

Instructions or Guidance for Trending

and Periodic Evaluation of MOV

Failures.

b.

Documentation

Anal sis

and Corrective Actions for MOV De radation

and

Failures

The inspectors

reviewed

and assessed

the adequacy of the licensee's

documentation,

analysis,

and corrective actions for MOV degradation

and

failures through

a review of selected

licensee

maintenance

Work Orders

(WOs)

and Nonconformance

Reports

(NCRs).

The

WOs were chosen

from the

printout of summary information in the licensee's

database

for 1993 - 94

maintenance.

The NCRs, covering significant failures,

were chosen

from a

listing of all

NCRs for a like period.

Two earlier

(1991

and

1992)

WOs

were added to the review because

of their apparent relation to failures

in the initial

WO and

NCR selection.

The

WOs reviewed

by the inspectors

included the following:

WO No.

Descri tion of Maintenance

91035976

01

92001072

01

92048525

01

93003402

01

93012842

01

On November

11,

1991, valve 2-HV-08-12 failed to open

(stalled) during testing.

The motor insulation exhibited

a burnt odor and the overload heater

was found to be

damaged

by overheating.

A sustained

motor overcurrent

condition was indicated.

The cause

was not established.

The motor, overload block,

and overload heater

were

replaced.

Static

and dynamic diagnostic thrust

measurements

did not reveal

any abnormality.

This was

an inspection of the internals of valve 2-HV-08-

12 during the refueling outage following the failure

documented

in the above

Work Order.

No visible cause of

valve binding was observed,

except that there were

possibly pipe wrench marks

on the upper

4 or 5 stem

threads

and

stem runout varied from 4 to 10 mils.

The

stem was replaced.

On September

15,

1992, valve 2-HV-08-13 showed dual

indication

and

was found to have stalled.

Motor, thermal

overload,

and starter

were replaced.

(Resulted

in NCR 2-

514 - described

in next table.)

Valve 2-V-3523 showed dual indication when closed.

This

was corrected

by adjusting limit switch rotor points to

provide correct indication.

Valve 2-HCV-3647 would not open.

No maintenance

was

required.

The reactor operator

had forgotten that the

switch had to be held in position to continue

movement in

the desired direction.

94008833

01

Valve 2-HV-09-11 would not operate

from the control

room

switch.

Checked limit switch development,

control switch,

and relay.

No problem was identified and,

subsequently,

the valve operated satisfactorily.

It was speculated

that

the valve did not operate

because

of dirty contacts.

93014982

01

93030826

01

Valve 1-V-3614 torqued out and would not close (preventing

reactor heat-up

and pressurization)

until forced off back

seat.

.Investigation

and repeated

testing did not identify

a problem.

Valve 1-HV-15-1 would not close.

The cause

was determined

to be dirty torque switch contact points.

The points were

cleaned

and the valve operated satisfactorily.

93017425

01

The position indicating lights for High Pressure

Safety

Injection System Valve 1-HCV-3616 were behaving

abnormally.

Investigation

found the hypoid gear

had

several

teeth missing.

Initiated

NCR 1-831

(see below).

j

The

NCRs reviewed

by the inspectors

included the following:

NCR No.

Condition and Corrective Action

1-820

(5/25/93)

1-831

(9/28/93)

This

NCR was

used to request

an engineering

review and

approval of a modification that drilled and pinned

a key

in the stem nut of valve I-NV-08-3.

Engineering

approval

was provided.

The limit switch cartridge pinion gear shaft

had failed on

valve 1-HCV-3616, potentially resulting in development of

stall in the closing direction.

An engineering

evaluation

determined that the Limitorque actuator one-time thrust

rating had

been

exceeded.

The actuator one-time torque

rating

and the valve thrust limit had not been

exceeded.

The engineering disposition referred to Limitorque

Technical

Update

92-01

as requiring

an inspection if the

rating was exceeded

and stated that the actuator

would be

rebuilt, exceeding

the Limitorque inspection requirements.

A failure analysis

was conducted

which identified the

probable

cause

as improper alignment of the hypoid and

pinion gears,

coupled with porosity found in the hypoid

gear.

Discussions

with the actuator manufacturer

indicated that this was

an isolated occurrence.

2-600

(4/15/94)

2-514

(9/16/92)

The closing thrust determined

at control switch trip

during diagnostic testing of valve 2-NV-08-13 exceeded

the

actuator allowable thrust limit.

Engineering

evaluated

and revised the thrust

and torque limits, based

on

Limitorque Technical

Update 92-01.

The previously

obtained torque

and thrust were acceptably within the

revised limits.

The high closing thrust obtained

in the

test

was attributed to an improvement in stem factor

(reduced friction), resulting in a higher thrust for the

same torque setting.

On September

16,

1992, valve 2-HV-08-13, the isolation

valve for the

2A steam generator

supply to the

2C

auxiliary feedwater

pump. tur bine,,failed to open (stalled)

when actuated

to provide steam for a surveillance

run of

the

pump.

After opening

a sister

valve (HV-08-12), which

increased

the downstream

pressure

and decreased

the

differential pressure

across

2-NV-08-13, valve 2-NV-08-13

was again actuated

and successfully

opened.

Subsequent

investigation

found the motor and overload relay were

damaged

by overheating

and they were replaced.

The valve

opened

and closed satisfactorily after the replacement.

10

2-536

(7/20/93)

The licensee's

engineering

evaluation

concluded that the

root cause of the failure was indeterminant.

NCR 2-514

referred to subsequent

NCR 2-536, covering

a subsequent

failure of the

same valve, for additional evaluation

and

required actions.

On July 20,

1993, valve 2-HV-08-13 stalled while

attempting to open during

a surveillance test.

The stall

lasted

one to two minutes, after which the disc broke free

and traveled to full open.

No evaluation of the stall

thrust

and torque

was documented.

In a subsequent

diagnostically monitored full flow differential pressure

test,

a high unseating

load was recorded during opening of

the valve.

The actuator thrust rating was exceeded

by

approximately

30 percent.

The licensee

determined this

was acceptable

with the following actions

recommended:

a

limit of 50 complete cycles

on subsequent

valve operation,

valve surveillance

frequency increased

from every 60 days

to every 30 days,

disassembly

and inspection of the valve

and actuator at the next Unit 2 refueling outage.

Diagnostically monitored surveillance tests

in August

and

October found higher unseating thrusts

than previously

measured,

which were evaluated

and found acceptable

by the

licensee.

As

a consequence

of the October result,

the

licensee

changed

from torque to limit switch seating

control in an effort to reduce

wedging of the disc into

the valve seat.

During the next refueling outage

(February

1994) the valves were replaced with double disc

gate valves with larger actuators.

In assessing

the above

WOs and

NCRs, inspectors

found that the licensee's

documentation,

analysis,

and corrective actions for HOV degradation

and

failures

was satisfactory

except in addressing

the mechanical

overloads

experienced

by valves 2-HV-08-12 and -13.

These

are identical

HOVs and

perform redundant

safety functions.

The documented

analyses

of the stall

of valve 2-HV-08-12 on November

11,

1991,

and stalls of valve 2-HV-08-13

on September

16,

1992,

and July 20,

1993, did not determine

the torque

and thrust experienced

by the actuators

and valves (single wedge gate

type) for comparison to limits specified

by the manufacturers.

Calculations

by the

NRC inspectors

and,

subsequently,

by the licensee

indicated that the thrusts

and torques during the above stalls were

approximately

18,600 lbs

and

143 ft-lbs, respectively.

The calculated

thrust

was about

125 percent of .the valve maximum thrust limit described

in the licensee's

July 26,

1993, engineering

evaluation

JPN-PSL-93-038,

Rev. 0.

This deficiency was not identified or evaluated

in determining

the acceptability of the valves following any of the stall events.

Subsequently,

the licensee

has established

a valve thrust limit of 44,000

lbs, indicating the valve would not have

been

damaged

in the stall

events.

The calculated stall thrust

and torque were

230 and

160 percent

of the actuator

(Limitorque SHB-00) ratings, respectively.

As in the

case of valve thrust the actuator stall overthrust

and overtorque

were

not documented

or evaluated

in assessing

valve operability.

In February

1992,

Limitorque Technical

Update

92-01

was issued to notify

licensees

and others of recommendations

resulting from review of an

industry study to establish

increased

actuator ratings.

The Update

recommended

that the utility: contact Limitorque for an operability

assessment if actuator thrust exceeded

140 percent of the rating,

quantify any overthrust

by conservative

calculations

or measurements,

and

ensure

housing cover

and base fasteners

were torqued to specified

minimum

levels.

The Update also indicated that

a one-time overthrust of up to

250 percent of the actuator rating was acceptable.

Subsequently,

in

April 1992,

Limitorque issued

Naintenance

Update 92-1.

This Update

stated that if the

250 percent

one-time thrust rating was exceeded,

or if

the overload occurred

more than once,

an inspection of the actuator for

damage is recommended.

For opening overthrust, it recommended

inspection

of the drive sleeve

and lower drive sleeve

bearings.

The Haintenance

Update also stated that

a one-time torque overload of up to 200 percent

of the actuator rating was acceptable

but that, if this limit was

exceeded

or overtorque

occurred

more than once,

the gearing

and

particularly the worm should

be inspected for cracks.

Valve 2-NV-08-13 had experienced stall twice,

as stated

above,

and

may

have experienced

conditions

approaching stall at other times.

The

licensee

did not document the calculations

or inspections

recommended

by

the manufacturer to assure

the valves would perform their design safety

functions.

Instead,

the licensee relied

on diagnostic testing performed

following the stall failures.

Licensee

personnel

agreed that their documented

evaluation

was

insufficient but considered

the corrective actions they performed

adequate.

Their reasons

were

as follows:

(1)

At the time of the

1991 stall event they had

no written guidance

from Limitorque regarding evaluation of stall.

(2)

The one-time allowed actuator thrust

and torque specified

by

Limitorque were not exceeded.

(3)

Electrical Haintenance

performed

a visual inspection of the actuator

during motor replacement

following the

1992 event.

(4)

Diagnostic monitoring performed monthly following the

1993 stall did

not indicate

any damage to the actuator internals.

In addition,

visual examination of the actuator did not indicate

damage.

The use

of diagnostics

was considered

equivalent to vendor recommendations.

(5)

The valve manufacturer

indicated its thrust limit was 44,000 lbs,

which was not exceeded.

12

The inspectors'ssessments

of the reasons

given to justify the adequacy

of the licensee's

corrective actions

was

as follows:

(1)

An appropriate

engineering

evaluation

would have included

a

documented

and verified calculation of stall forces which could

be

compared with the actuator rating.

Considering that the stall

thrust calculated

during this

NRC inspection

was over twice the

actuator rating, it would have

been appropriate to seek guidance

from the manufacturer

or replace

the actuator.

(2)

The one-time actuator

allowed torque

and thrust is specified for

overloads

~u

to the stated limits. It is only for one (one-time)

overload up-to the allowable limits not multiple overloads.

The

licensee

experienced

two overloads

near the limits and at least

three additional

lower overloads

detected

during diagnostic testing.

Others,

up to stall overload levels,

may have occurred undetected.

(3)

Discussions

with licensee

personnel

indicated that this visual

examination

was not the inspection of components that Limitorque

recommends.

No documented

inspection results

were provided to the

inspectors

in support of an adequate

visual examination.

(4)

While the licensee's

diagnostics

did increase

assurance

that the

valve would perform its safety function, it would not be expected to

detect incipient failures

as assuredly

as the visual inspection

recommended

by Limitorque.

Based

on discussions

with licensee

personnel,

the licensee

performed

a visual inspection

but not the

inspection of components that Limitorque recommends.

No documented

inspection results

were provided to the inspectors

in support of an

adequate

visual examination.

(5)

The original thrust limit provided

by the valve manufacturer

was

9910 lbs.

As reported in the licensee's

1993 engineering

evaluation

(JPN-PSL-93-038)

performed following the second stall of 2-HV-08-13,

informal information from the vendor indicated the limit could

be

increased

to about

15,000 lbs.

This was below the stall thrust

calculated

during this inspection,

which is of 18,600 lbs.

The

licensee

was not aware that the limit could

be further increased

to

44,000 lbs until later.

Based

on the above,

the inspectors

consider the licensee's

actions in

response

to the valve stall failures unsatisfactory.

The licensee's

failure to document calculation

and evaluation of the" stall overload

conditions, to identify. the valve .and .actuator..overload,

and to perform

the evaluations

or inspections

recommended

by the actuator manufacturer

are considered

to represent

inadequate

corrective action.

This

inadequate

corrective action is identified as Violation 50-335,

389/94-

11-01,

Inadequate

Corrective Action for HOVs 'Which Stalled During

Surveillances.

13

2.6

Although the inspectors

determined

the licensee's

valve stall evaluations

were deficient, positive aspects

were also noted.

The application of

diagnostics

following the failures, particularly the periodic diagnostic

monitoring of valve performance instituted after the July 1993 stall,

provided increased

assurance

of valve operability.

The licensee

replaced

MOVs 2-HV-08-12 and

-13 at the first refueling outage following the

1993

stall with valves

and actuators

having improved capabilities.

However,

it appeared

to the inspectors that other actions

should

have

been taken

earlier

- either improved justifications for the continued operability or

valve replacement.

The adequacy of the licensee's

documentation,

analysis,

and corrective

actions for HOV degradation

and failures

was satisfactory with the

exception of actions of taken following stall failures.

Schedule

In GL 89-10,

the

NRC requested

that licensees

complete all design-basis

reviews,

analyses,

verifications, tests,

and inspections that were

initiated in order to satisfy the generic letter recommendations

by

June

28,

1994, or three refueling outages after December

28,

1989,

whichever is later.

In a letter dated

February

14,

1992, the licensee

proposed to change its schedular

commitment for completion to 60 days

following start-up

from Cycle

13 refueling outage

(scheduled fall 1994)

for Unit

1 and Cycle

9 refueling outage

(scheduled fall 1995) for Unit 2.

A subsequent

NRC acknowledgement letter,

dated

Harch 16,

1992, indicated

the change

was acceptable

but requested

that the more important valves

be

tested first, preferably in accordance

with the original schedule.

The inspectors

reviewed the documented

status of testing

and determined

that the licensee

had tested

approximately 2/3 of the globe

and gate

valves in the program for each unit.

In accordance

with the current

commitment,

one refueling outage

remains for each unit.

Licensee

personnel

stated that

some of the remaining valves would be tested during

operation.

Licensee

personnel

had not determined

what method that would be used to

verify the capabilities of butterfly valves but indicated that they

expect to meet the schedule

commitment.

Appropriate testing of butterfly

valves is an industry issue

and not unique to St. Lucie.

The inspectors

questioned

whether the licensee

had determined

the more

important valves to be tested

and completed testing of them first, as

requested

in the March 16,

1992,

NRC letter that acknowledged

the

licensee's

schedule

change.

They were provided copies of related letters

(dated January

29 and February

10,

1992) from the licensee's

engineering

group to the plant, which prioritized the valves for testing.

The

inspectors

reviewed the prioritization against

the licensee's list of

valves tested

and found that in some

cases

the higher priority valves

had

not been tested.

These

were discussed

with licensee

personnel.

Explanations

as to why the valves

had not tested

included: deletions

from

the program,

questions

as to whether valves were testable

at or near

2.7

design-basis

conditions, diagnostic

sensor

problems,

maintenance

problems,,

and on-going questions

regarding inclusion of certain valves in

the program.

Based

on the test data reviewed

by the inspectors

in this inspection

and

on their discussions

with licensee

personnel,

the inspectors

believe the

licensee

can meet the specified completion schedule.

The licensee's

completion of the setting

and verification of the capabilities of all

valves in the

GL 89-10 program (including butterfly valves) will be

confirmed in a subsequent

inspection.

Pressure

Lockin

and Thermal

Bindin

The Office for Analysis

and Evaluation of Operational

Data has completed

a study of pressure

locking and thermal binding of gate valves.

It

concluded that licensee's

have not taken sufficient action to provide

assurance

that pressure

locking and thermal

binding will not prevent

a

gate valve from performing its safety function.

The

NRC regulations

require that licensees

design safety-related

systems to provide assurance

that those

systems

can perform their safety functions.

In GL 89-10, the

staff requested

licensees

to review the design-basis

of their safety-

related

HOVs.

The inspectors

reviewed the licensee's

engineering report that addressed

pressure

locking and thermal binding.

Engineering Evaluation

JPN-PSL-

SEMP-93-036,

"St. Lucie Units

1

& 2 Engineering Evaluation of Pressure

Locking and Thermal

Binding of Motor Operated

Gate Valves," Rev.

0,

was

performed

by the licensee to identify safety-related

motor operated

valves that might be susceptible

to pressure

locking and/or thermal

binding.

An initial screening of the 80

HOVs in Unit

1 and the

103

HOVs

in Unit 2 was conducted to determine if the

HOVs met screening criteria

for susceptibility to pressure

locking or thermal binding.

The screening

criteria for pressure

locking susceptibility was:

(1) flexible-wedge or

double disc wedge gate design,

(2) used for incompressible fluids,

and

(3) lacking

a design feature for prevention.

The screening criteria for

susceptibility to thermal

binding was (1) flexible-wedge,

solid-wedge,

or

split-wedge gate design;

and (2)

HOV closed

under high temperature

conditions.

In Unit 1,

14 HOVs met the initial screening criteria for

pressure

locking and

19 met the initial screening criteria for thermal

binding.

In Unit 2,

12

MOVs met pressure

locking and

15 met thermal

binding initial screening criteria.

A further evaluation determined that

nine

HOVs (four in Unit

1 and five in Unit 2) were susceptible

to

pressure

locking.

Two MOVs in Unit

1 were determined to be susceptible

to thermal

binding.

The .transmittal .letter for the .above evaluation,

JPN-PSLP-94-0132,

dated

February

28,

1994, identified the

HOVs found to

be susceptible

to pressure

locking and thermal

binding as follows:

il

Pressure

Locking

Valves 1&2-V-3480, 1&2-V-3481, 1&2-V-3651, 1&2-V-3652, and 2-V-3545

Thermal binding

15

Valves 1-V-1403 and 1-V-1405

At this point the inspectors

and licensee

did not have operability

concerns with these

valves.

The licensee

has adequately

considered

valve

operability.

However, the letter indicated that

a detailed valve

specific engineering

analysis

would be performed for the

above valves to

determine

any required action.

The

NRC plans to issue additional

recommendations

to licensees

regarding

pressure

locking and thermal

binding in the future.

Subsequently,

the

NRC will assess

licensee

actions in this area.

2.8

Hotor Brakes

St. Lucie did not have motor brakes

on their HOVs.

2.9

ualit

Assurance

Pro ram

Im lementation

The inspectors

reviewed the licensee's

implementation of the quality

assurance

(QA) function for the

GL 89-10

Program

HOVs.

They found that

audits

and reviews

had

been performed

by the Nuclear Engineering

Department,

Independent

Safety Evaluation

Group (ISEG), Site

QA, and

Corporate

QA.

The inspectors

reviewed the following examples:

Nuclear Engineering

Department

self-assessment

letter JPN-ST-92-150,

"Design Review/Functional

Review

HOV - Testing," dated

June

12,

1992.

ISEG Report

ISEG-PSL-V-048,

"Evaluate Hotor Operated

Valve

Differential Pressure

Testing at St. Lucie," dated

June

22,

1993.

Corporate

QA audit,

QAS-JPN-93-3,

"Nuclear Engineering-PSL

Design

Control," dated October 29,

1993.

Site

QA contractors

audits

QSL-OPS-92-872 for the

HOVATS (HOV)

Program

and QSL-PS-92-872 for Babcock

8 Wilcox HOV Testing.

Based

on their review of the above,

the inspectors

concluded the licensee

has

implemented

an effective

QA program to address

GL 89-10

HOVs.

'2. 10 Followu

of Previous

Ins ection Findin s

The inspectors

reviewed the licensee's

actions in response

to an

inspector followup item and other concerns identified in previous

NRC

inspections.

The results of the inspectors'eview

are described

below:

16

a.

Ins ector Followu

Item

(Closed)

IFI 50-335,

389/92-25-01,

Review of Operability of Unit 2

HOV

HV-08-13 During the Period of July 20 to October

19,

1993.

This item questioned

the operability of valve 2-HV-08-13 during the

period of July 20 to October

19,

1993.

The failures experienced

by this

valve

and the licensee's

corrective actions

were examined

in detail

by

the inspectors,

as described

in Section 2.5.b of this report.

During the

period in question

the licensee

performed

a number of surveillance tests

on the subject valve and in each

instance

the valve opened

when actuated

to perform its intended safety function.

Based

on the testing results

and evaluations

discussed

in this report, the inspectors

consider the

valve to have

been operable

during that period

and this item is closed.

It should

be noted that the related review described

in Section 2.5.b,

identified that the licensee's

corrective action for stall failures of

this valve was deficient, in that the July 20,

and previous related

failures were inadequately

analyzed.

Hore complete analysis

might have

led to

a licensee

conclusion that the HOV's capabilities

were

significantly degraded

and required

immediate replacement

or further

justification for continued operation.

Note that valve 2-HV-08-13 and

its redundant sister valve were replaced

by the licensee

during

a

February

1994 outage.

b.

Concerns Identified b

Ins ection 50-335

389 91-18 for Which

a

Written Res

onse

was

Re uested

(1)

Schedule

The concern

was that the licensee

might nut meet its generic letter

schedule

commitment due to delays

caused

by its recent decision to alter

its diagnostic test method.

In a response letter to the

NRC dated

February

14,

1992, the licensee

proposed its revised

schedule.

As

discussed

in Section 2.6 above,

the inspectors

examined the licensee's

related actions

and believes that the current commitment

can

be met.

This resolves

the concern.

(2)

Valves to be Design-Basis

Tested

The concern

was that design-basis

testing

was being omitted

on HOVs that

were practical to test.

Licensee

personnel

stated that credit might be

taken for testing of 56

NRC Bulletin 85-03 valves

even though only 23 had

been tested.

Also, the. licensee's

status report, indicated testing

was

being omitted for butterfly valves that were practical to test.

In the response letter referenced

above,

the

NRC was informed that the

licensee

would test all valves practical.

The licensee's

testing of all

valves practical will be assessed

when Region II inspects

the licensee's

completion of GL 89-10 implementation.

17

c.

Concerns

Identified b

Ins ection 50-335

389 91-18 for Which No

Written Res

onse

was

Re uested

(1)

Setpoint

Window

The concern

was that the licensee

had

no procedure

or programmatic

guidance for transforming design calculation results into valve setpoint

windows.

In the current inspection the

NRC inspectors

determined that

adequate

setpoint

windows had

been established

for the valves

sampled.

This resolves

the concern.

(2)

Use of 0.5 Valve Factor to Account for Uncertainties

Such

as

Rate of Loading

The concern

was that the licensee

had not adequately

accounted for

uncertainties

such

as load sensitive

behavior in its thrust setting

determinations.

The inspectors'eview,

described

in Section 2.2 above,

found that load sensitive

behavior

and other factors originally of

concern

are being addressed.

This resolves

the concern.

(3)

Justifiable Deviations from Commitment to Test All Valves

Practicable

The concern

was that the licensee

was evaluating deviations

from the

generic letter recommendation

to design-basis

DP test all valves

practicable for valves with high margins of capabilities to design-basis

requirements.

The inspectors

reconsidered

this issue

and do not find the

deviations of concern, if adequately justified.

Such justifications will

be subject to evaluation in a subsequent

inspection.

The original

concern is resolved.

(4)

Use of Static Diagnostic Testing to Demonstrate

Continued

NOV

Capabilities

The concern

was that the licensee

planned to use static diagnostic

testing for periodic verification of HOV capabilities.

The ability of

static diagnostic testing to demonstrate

continued capabilities

has not

been justified.

In the current inspection the

NRC inspectors

were

informed that the licensee

had not completed the determination of the

method

and criteria to be used for periodic verification.

This issue

will be inspected

during program closeout.

(5)

Stem Friction Coefficient and

Stem Lubrication Frequency

This concern

involved the licensee's

use of a low stem friction

coefficient and

a stem lubrication frequency greater

than

recommended

by

the manufacturer.

A valve stem friction coefficient of 0.15 was utilized

in calculating torque switch settings for St. Lucie

GL 89-10 valves

located outside containment.

The valve actuator manufacturer

indicates

this stem friction coefficient is to be applied where good stem

lubrication is assured

and, in practice,

the manufacturer

normally uses

a

more conservative

0.20 stem friction coefficient for its own

18

calculations.

Also, the actuator manufacturer

recommended

an

18 month

preventive

maintenance

frequency for valve stem lubrication, whereas

the

licensee

permitted

a 36 month frequency

on its non-equipment

environmental qualification (Eg) valves.

In the current inspection the

NRC inspectors verified that the licensee

was

now using 0.20 stem friction coefficient.

The licensee

stated that

the valve stem lubrication frequency of 36 months applied only to non

Eg

GL 89-10

HOVs located inside the buildings.

The licensee further stated

that the 36 month valve stem lubrication frequency will be adjusted

as

needed to ensure

the stems

are properly lubricated.

The inspectors

concluded the licensee

has adequately

addressed

the valve stem friction

coefficient of 0.20

and stem lubrication.

This concern is resolved.

The

licensee's

verification that its 0.20 stem friction coefficient

assumption

and the 36 month lubrication frequency is adequate will be

subject to

NRC verification in a subsequent

inspection.

(6)

Torque Seated Butterfly Valves

The concern

was that

some butterfly valves were being seated

using torque

switch control, whereas

the actuator manufacturer

recommended limit

switch seating.

In the current inspection the

NRC inspectors verified

that the licensee

had implemented

a change to limit switch seating for

all butterfly valves.

The change

was identified

PCH 284-292

and

implementation

was verified by the inspectors

review of Work Order

examples

93027861,

93028660,

93028658,

93028659,

and 93028655.

This

concern is resolved.

(7)

Specification of Extrapolation

Method and

Use of Prototype

Testing

The licensee's

program document indicated that test results

obtained at

less than design-basis

DP would be extrapolated

to design-basis

DP and

that prototype testing would be used in some cases.

The concern

was that

no criteria were provided for use of either.

In the current inspection

the

NRC inspectors

found that the licensee

used

simple linear

extrapolation

and that there

was

no apparent

use of prototype testing.

Licensee

personnel

indicated that justification for the adequacy of

linear extrapolation

was under development

(see Section 2.3).

Any

licensee

use of prototype test results will be subject to

NRC evaluation

in establishing

the licensee's

completion of GL 89-10 implementation.

(8)

Guidance for Documenting

and Trending

MOV Failures

and

Degradation

The concern

was that the licensee

had not provided adequate

guidance for

performing the trending of HOV failures

and degradation

recommended

by

GL 89-10.

As discussed

in Section 2.5.a

above,

the current inspection

determined

there is still concern regarding the adequacy of the guidance

provided, particularly with regard to administrative controls.

19

2. 11 Walkdown

The inspectors

conducted

a walkdown of HOVs to observe

the installed yoke

thrust sensors

and the condition of the valve stems.

They observed that

the

HOVs located inside buildings were in good condition.

The valve stem

lubrication was satisfactory

and the sensors

were installed correctly.

HOVs located ou'tside,

where they were exposed to rain and salt air, were

inspected after removing the valve stem covers.

On

a previous

inspection,

an

NRC inspector

had observed that rain water

had leaked into

similarly located

HOVs and corrosion

had resulted.

The licensee

had

special

"hats"

made to cover the valves

and initially installed

them

on

two HOVs to determine if they provided protection from the environment.

The inspectors

found that the two HOVs with "hats" were in good condition

with adequate

stem lubrication and

no corrosion.

The other

HOVs located

outside

were observed to have

adequate

stem lubrication but some minor

corrosion.

The sensors

were satisfactorily attached

to the yokes of all

the

HOVs inspected.

The licensee

stated

"hats" would be installed for

all outside

GL 89-10

MOVs by the

end of 1994.

The inspectors

considered

this to be appropriate corrective action.

The inspectors

concluded that the

HOVs located inside the buildings were

well maintained.

However, the

HOVs located outside

were subject to

corrosion

from the rain water and the salt air environment

and

some form

of protection

appeared

appropriate.

EXIT INTERVIEW

The inspection

scope

and findings were summarized

on Hay 6,

1994, with

those

persons

indicated in Section

1.

The inspectors

described

the areas

inspected

and discussed

in detail the inspection results.

Three

weaknesses

were described.

The inspectors

stated that one of the

weaknesses

would be discussed

with NRC management

as

a possible violation

and that the other two would be identified as followup items.

Licensee

personnel

indicated the reasons

they did not consider the

one item

a

violation.

Their reasons

are described

in Section 2.5.b,

above.

Proprietary information is not contained in this report.

The violation

and followup items identified by the inspectors

are listed in the

summary

at the beginning of this report.

ACRONYHS AND INITIALISHS

CFR

CST

DBDP

DP

Eg

GL

IFI

ISEG

HOV

NCR

NRC

Code of Federal

Regulations

Control Switch Trip

Design Basis Differential Pressure

Differential Pressure

Equipment gualification

Generic Letter

Inspector

Followup Item

Independent

Safety Evaluation

Group

Motor Operated

Valve

Nonconformance

Report

Nuclear Regulatory

Commission

20

NRR

QA

TI

VOTES

WO

NRC Office of Nuclear Reactor Regulation

Quality Assurance

Temporary Instruction

Valve Operation Test

and Evaluation

System

Work Order 20

APPENDIX - ST. LUCIE GATE AND GLOBE VALVEDATA

Diagnostics: VOTES/VTC/LVDT

TESI'ONDIONS

(pntO

DEQGN

BAQS

DYNAMIC

VALVE

FACTOR"

STEM

FRICIION

COEmCIENTi

LOAD"

SENQTIVE

BEHAVIOR

1-V3660

3

Velan

900'lex

Wedge

Gate Valve

N/A

1200

NIA

79%

0.21

1.10

NIC'/C

-5%

1-V3480

10" Velan

1500'lex

Wedge Gate

Valve

230

NIA

84%

NIA

1.0

NIA

0.14

N/C

N/A

1-HCV-

3617

2" Vclan

1500It Globe

Valve

1280

1000

52%

76%

NIA

0.34

0.11

N/C

2-V3480

10'estinghouse

15001 Gate

Valve

248

NIA

90%

NIA

0.59

N/A

N/C

N/C

-2%

2-HCV-

3615

6'elan

15001t Globe

Valve

417

142

87%

29%

0.95

N/C

0.16

N/C

-20%

2-V3654

6r

Westinghouse

9008'ato

Valve

740

740

135%

135%

0.72

0.80

0.16

N/C

2-V3658

12

Westinghouse

300/r Gate

Valve

4I5

NIA

93%

NIA

0.44

NIA

0.21

NIC

-2%

2-V3664

2-MV-

09-10

10'estinghouse

300'ato

Valve

4'KM 6000

Globe

Valve

1380

39

80%

14%

100%

3%

0.94

N/C

N/C

N/C

0.16

0.17

N/C

NIC

-2%

2-MV-

08-13

4'nchor

Darling 600/

Parallel Disc

Gate Valve

10

89%

1%

0.54

0.31

0.19

NIC

'ha dynamic valve factors listed were calculated by tha licensee using an orifice diameter.

Stem Lubricant: FelPro N5000.

'

negative number indicates that tha thrust observed at CST during tha dynamic test was greater than the thrust obscrvcd at CST during tho static

test.

'/C ~ Not Calculated.