ML17347B103

program.

Unit 3 IE Bulletin 85-03 valve testing

was completed

during

the

1987 spring/surfer refueling outage;

Unit 4 testing is still in

progress.

In order

to determine

how effective the licensee's

IE

Bulletin 85-03

program is in assuring

MOV operability, the inspector

reviewed

the

maintenance

histories

for all

14 Unit 3

IE Bulletin 85-03 valves dating

back to completion of the

1987 refueling outage

testing to present.

Plant

Work Orders

(PWOs)

were written by plant

personnel

to

document

MOV deficiencies.

Reviewing

a

valve's

maintenance

history consisted of reviewing all the

PWOs filed against

the

valve.

Review of the

valve

maintenance

histories

revealed

that

two valves

recently

experienced

failures,

root

causes

analysis

of valve failures

and other associated

MOV

problems

were not always

adequate,

and

MOVs were not being tested

following maintenance

in accordance

with administrative

requirements.

The following Unit 3 IE'ulletin 85-03 valve failures

have occurred

since the

1987 refueling outage:

Valve

PWO No.

Date

Descri tion

MOV-3-1404

63-3672

10/15/88

Valve will not

operate,

overload

tripped

MOV-6459A

69-5508

MOV-3-1404

63-2082

01/30/88

01/14/89

Actuator gear-

housing cracked

Valve will not

operate,

thermal

overloads

tripped

MOV-6459A

69-5606

02/02/89

Valve will not

operate,

thermal

overl oads tr ipped.

The cause

of the cracked

gear housing

and thermal

overloads tripping

is presently

unknown.

Because

of these

failures,

MOV-3-1404 and

MOV-6459A valve actuators

were replaced with Unit 4 valve actuators;

however,

a root cause

evaluation

was not performed

to determine

why

these

valves failed.

Root cause

determination

has to

be addressed

or

the

same

problems

may occur with the Unit 4 actuators

installed

on

the

Unit 3

valves.

Other

examples

of insufficient root

cause

determination

are

as follows:

Valve

PWO No.

Date

Descri tion

MOV-3-864B

63-502

MOV-3-864A

63-1220

MOV-3-864A

63-2675

11/21/87

05/16/87

11/30/88

Valve leaks

by seat

Water found in

actuator

grease

Small

amount of

water issued

from

actuator

when

grease

plug

removed.

Valve MOV-3-864B is the Unit 3 Refueling Water Storage

Tank to High

Head Safety Injection

Pump Suction valve which is normally open.

The

corrective action for the valve seat

leakage

was to cycle the valve

while measuring

the motor current.

The motor current readings

were

satisfactory

and

as corrective action,

the valve was manually seated

with three

hard

handwheel

turns.

This corrective

action

was

insufficient, in that, it did not determine

why the valve was leaking

by the seat.

In addition,

over torquing

an

MOV handwheel

could

result in damage to the actuator and/or valve.

Mater

has

been

found in the actuator

of valve

MOV-3-864A twice.

Corrective

action

has

involved grease

replacement

after the first

discovery of the water

in the actuator,

and inspection of grease

after the

second

discovery.

No root cause

determination

has

been

made

on how the water got into the actuator.

Administrative Procedure

190.28

provides

MOV post

maintenance

test

requirements.

One

requirement

contained

in this

procedure

is to

measure

motor starting

and

running

current if maintenance

is

per ormed

on valve packing.

During the inspection,

the inspectors

found several

instances

where valves

were repacked

wi thout obtaining

the

required

current

measurements

following maintenance.

In

November

1988, valves

MOV-3-843A and MOV-3-843B were repacked

per

PWOs

63-2558

and 63-2237.

The inspector could find no evidence of motor

current

being

measured

following this maintenance.

Measuring

motor

current

following maintenance

on

MOV

packing

is

not

an

ASME

Section

XI Code requirement;

however, it is

a procedural

requirement.

Since this is not

a code requirement,

a violation is not warranted.

However, this matter

was fully discussed. with licensee

personnel

and

they are reviewing this matter.

Based

on this review, appropriate

corrective action will be taken.

Status of IE Bulletin 85-03 Action Items

a through f.

(1)

IE Bulletin 85-03, Action Items

a and b, require that the design

basis

for the operation

of each

valve

be

reviewed

and

documented,

and

switch settings

be

reviewed

and

revised

as

necessary.

Per the licensee,

90 percent

degraded

voltage

was

a criteria for determining valve thrust values.

The

inspectors

questioned

the basis for the percent

degraded

voltage

and

was

informed

by

the

licensee

that,

after

further

investigation,

degraded

voltage values of 80 and 88 percent

were

considered

to

be applicable

and factored into thrust valves.

Since

there

appeared

to

be

a

change

in criteria for degraded

voltages

used to determined

MOV thrust values, this area will be

reviewed in more detail

during

a

subsequent

inspection.

As previously discussed,

several

valves

have failed

since

completing

the

IE Bulletin 85-03 program.

Until the root

cause

of these

failures is determined,

the

adequacy

of the

design review and switch setting policy performed

as

a result of

IE Bulletin 85-03 is questionable.

(2)

IE Bulletin'5-03, Action Item c, required that switch settings

bd changed

as appropriate,

based

on the design review performed,

and that

each

valve

be

demonstrated

operable

by testing

the

valve at the

maximum differential pressure it will see

during

the worst

case

accident.

The

licensee

utilized

the

Motor

Operated

Valve Actuator Test

System

(MOVATS) to obtain

the

as-found switch settings

and verify the as-left switch settings.

Differential pressure

testing

was accomplished

by placing all IE

Bulletin 85-03

MOVs with identical

actuators,

valves,

and

functions into

a test

group.

At least

one valve out of each

test

group

was

tested

at the

maximum achievable

differential

pressure

utilizing reactor

plant

normal

installed

equipment.

All remaining

MOV switches

in the test group were set to develop

more thrust at

torque

switch trip than the test valve.

The

inspector

considered

that the

licensee

action

response

to

IE

Bulletin 85-03 Action Item c to be acceptable.

IE Bulletin 85-03,

Action Item d,

required

procedures

to

be

prepared

or

revised

to

ensure

that

switch

settings

are

maintained

throughout

plant life,

and

provide provisions

to

monitor valve performance.

Review of the licensee's

procedures

indicated that revised

switch settings

have

been

incorporated,

and that instructions

were

provided to ensure

switches

were

correctly set.

The licensee

does not have

a program to monitor

valve performance

throughout plant life.

In order to complete

Action Item d, the licensee

has

to develop

a program that wi 11

monitor valve performance

throughout plant life and provide post

maintenance

test requirements.

Review of

the

licensee

MOV procedure

revea'1ed

that

the

electrical

maintenance

procedures

provided

the

necessary

instructions

to ensure that switch settings

are correctly set.

However,

the

licensee's

program

is

lacking in

regards

to

mechanical

maintenance

procedures.

As previously discussed,

the

actuator

for Unit 3 Valve MOV-3-1404 was

removed

and replaced

with a Unit 4 actuator.

The instructions

used to exchange

the

actuators

were written on the

PWOs

by a Job Planner,

who is an

ex-mechanic

who copied

the instructions

from an old procedure

that had expired.

Valve MOV-3-1404 is presently lying on

a shop

bench

waiting for

a

procedure

from Corporate

to provide

.

instructions

for disassembly,

which is delaying

root

cause

analysis of the crack in the actuator

body.

The licensee

does

not

have

a

station

procedure

to

remove/reinstall

or

disassemble/repair

the MOV-3-1404 actuator.

In order for a

MOV

program

to

be

considered

acceptable,

permanent

station

procedures

to perform

MOV mechanical

maintenance

are required.

In the

past,

Corporate

has

issued

temporary

procedures

to

accomplish

mechanical

maintenance,

but these

procedures

expire

after. one year.

As requested

Action Item

e of IE Bulletin 85-03, the licensee

identified

the

selected

safety-related

valves,

the

valves'aximum

differential pressures,

and the program to assure

valve

operability in their letters

dated

May 15, May'28, October

10,

and

November

18,

1986.

Review of these

responses

indicated

the

need for additional

information which was contained

in an

NRC,

Region II, letter to the licensee

dated August 18,

1987.

Review of the licensee's

September

17,

1987,

response

to this

request for additional

information indicated that the licensee's

sel ection

of

the

appl icabl e safety-rel ated

va 1 ves

to

be

addressed

and the valves'aximum differential pressures

meets

the

requirements

of IE Bulletin 85-03

and that the program to

assure

valve operability

requested

by Action Item e of

IE

Bulletin is now acceptable.

(5)

IE Bulletin 85-03, Action Item f, required that

a written report

be

issued

to

the

NRC

on

completing

the

program.

The licensee

issued

the Unit 3 report

on January

14,

1988.

The Unit 4

IE Bulletin 85-03 program is in progress

and

will be completed during the present refueling outage.

b.

IE Bulletin 86-03 Followup

(Closed)

86-BU-03, Potential

Failure of Multiple ECCS

Pumps

Due

to

Single

Failure

of Air-operated

Valve in

Minimum

Flow

Recirculation

Line.

This bulletin

required

licensees

to

determine if a single

valve failure

due

to loss

of air or

electric

power in the safety injection (SI) pumps recirculation

line would result in dead

heading

and subsequent

failure of the

SI

pumps.

The licensee

determined that this did apply and

has

completed

the corrective action.

Unit 3 valves,

3-856A and 3-856B,

and Unit 4 valves,

4-856A and

4-856B,

are installed

in series

in the

SI

pump

minimum flow

common recirculation line to the Refueling

Water Storage

Tank

(RWST).

These

valves fai I-closed

on loss of air or electrical

power resulting

in dead

heading all

SI

pumps.

Modifications

PL/M 86-181,

for Unit 3,

and 86-182, for Unit 4,

replaced air

operated

valves

856A

and

B with motor operated

valves.

The

motor

operated

valves

are

open

during

normal

operation

and

during SI injection.

On loss of electrical

power the valves

fail as is.

Isolating the

RWST will also

be available in the

event of

a single failure since

the valves

are in series

and

only one valve will be required to be closed for isolation.

Within the

areas

inspected,

no violations

or deviations

were

identified.

3.

Main

Steam

and Pressurizer

Safety

Valve

Complex Surveillance

Testing,

Inservice Testing,

and Information Notice Followup (61701)

(73756)

(92701)

The inspectors

reviewed the Unit 3 Pressurizer

Safety Valve (PSV)

and Main

Steam Safety

Valve

(MSSV) setpoint test results

obtained

during the

1987

Refueling

Outage

(RFO), the Unit 4

PSY setpoint results

obtained

during

the

1988

RFO,

and

the Unit 4

MSSV setpoint

results

obtained

during the

1986

RFO.

MSSV and

PSV test specifications

are contained

in

ASME Code

Section XI,

1980 Edition,

which invokes

ANSI/ASME-PTC-25-3-1976, Safety

Relief Valves

Performance

Test Codes.

In order to evaluate

the licensee's

NSSV and

PSV setpoint

programs,

the

inspectors

conducted

discussions

with appropriate

licensee

personnel

and

reviewed the following:

FPL Inter-office correspondence,

dated

August 12,

1986,

Site File

No: P-71,

Turkey Point Units

3

and

4 Pressurizer

Safety

Valve Ring

Settings.

Procedures

3/4-CMN-041. 1,

Pressurizer

Safety

Valve

Repair

and

Setting.

Procedures

3/4-SMM-041. 1, Pressurizer

Safety Valve Setpoint Testing.

WYLE Laboratories,

Turkey Point Unit 4,

NSSV Test

Reports

dated

April 1984

and February

1986.

WYLE Laboratories,

Turkey Point Unit 3,

MSSV Test

Reports

dated

Nay 1985 and April 1987.

Crosby Valve

and

Gauge

Company,

Unit 3,

PSV Field Service

Report

dated April 2.

1987.

a

0

MSSV Testing

Every

RFO all

12

MSSVs are

removed from the applicable Unit and sent

to

WYLE Laboratories

for seat

leakage

and setpoint testing.

The

following are the results

of the Unit 3 1987

RFO and Unit 4 1986

as-found

NSSV setpoint testing conducted

by WYLE Laboratories:

UNIT 3

Valve No.

BL0387

BL0388

BL0389

BL0391

BL0392

BL0393

BL0395

BL0396

. BL0397

BL0390

BL0394

BL0398

Setpoint

Tolerance

PSIG

1085

+ 1$

1085

+ lX

1085

+

1

1100

+

1%

1100

+ 1X

1100

+ 1X

1115

+

1%

1115

+

1'5

1115

+ lX

1130

+

1%

1130

+

1%

1130

+

1%

As-found

Setpoint

PS IG

1091

1058

1052

1122

1115

1097

1112

1141

1092

1130

1142

1114

Percent

Oeviation

From Setpoint

Tolerance

0.0

-2.5

-3.0

+2.0

+1.4

0.0

+2 '

-2.0

0.0

+1.1

-1.4

Valve No.

BL0399

BL0400

8L0401

BL0402

BL0403

BL0404

BL0405

BL0406

BL0407

BL0408

BL0409

BL0410

Setpoint

Tolerance

PSIG

1085

+

1%

1085

+

1%

1085

+

l%%d

1100

+

1%

1100

+

1%

1100

+

1%

1115

+

1%

1115

+

1%

1115

+

1%

1130

+

1%

1130

+

l%%d

1130

+

1%

UNIT 4

As-found

Setpoint

PSIG

1076

1066

1076

1091

1099

1129

1089

1074

1122

1140

1144

Percent

Deviation

From Setpoint

Tolerance

0.0

-1.8

0.0

-202

0.0

+1.3

2 ~ 3

3 ~ 7

0.0

+1.2

Following repair of Unit 3 and Unit 4

MSSVs at Wyle Laboratories all

valves

were

checked

for seat

leakage

and setpoint.

All final

setpoints

were within the allowed setpoint tolerance

range.

With the

exception

of setting

and

maintaining

MSSV ring settings,

the

inspectors

considers

that the licensee

MSSV setpoint

meets

the

ASME

Code

Section

XI requirements.

Ring settings

are

discussed

in

paragraph

3.c.

PSV Setpoint Testing

Turkey Point

PSVs,

3 per Unit, are installed

on uninsulated

loop

seals

attached

to be top of the pressurizer.

The loop seal

piping

temperature

has

been

measured

to

be approximately

110'F.

The

PSVs

are manufactured

by Crosby

and seat

leakage is not

a problem.

Each

refueling

outage all

PSVs

are

removed

and seat

leaked

and setpoint

tested

on

a test

stand

by the

licensee.

Nitrogen at

ambient

temperature

is

the test

medium

and

no

method of correlation

is

utilized.

Three consecutive lifts, within allowable tolerance,

is

required to verify the setpoint.

All Unit 3

PSV as-found setpoints

obtained

during

the

1987

RFO were within the allowable setpoint

tolerance

range of 2485

+

1 percent psig,

and all as-left setpoints

were within specifications.

The Unit 4

1988

PSV

as-found

setpoints

were initially not correctly obtained

and therefore

not

accurate.

Prior

to setpoint

testing

a

PSV,

the lower rings are

adjusted

to obtain

a "crisper pop"; the Unit 4

PSV rings were not

adjusted

properly during the as-found testing

and therefore

did not

yield an accurate

setpoint.

After discovery of this discrepancy

by

the licensee,

the lower ring settings

were then properly adjusted

to

obtain

a "crisp

pop"

and

the valves

were retested

and setpoints

adjusted

to specified

tolerances.

With the exception of setting

and

maintaining

PSV ring settings,

the

inspectors

considered

that the

licensee

PSV

setpoint

program

meets

the

ASME

Code

Section

XI

requirements.

Ring

settings

are

discussed

in

the

following

paragraph.

PSV and

MSSV ring settings

are required to be strictly controlled in

order to maintain

the valve's

design

blowdown and flow capacities.

During the

MSSV and

PSV setpoi nt program review, the inspectors

noted

the

following areas

where

PSV

and

MSSV ring settings

were

not

adequately

maintained.

(1)

During the

1985

and

1987

RFOs, all Unit 3

MSSVs were sent to

WYLE laboratories for testing.

The

1985

and

1987

HSSV HYLE Test

Reports

document

the as-found ring settings

which is determined

prior to performing any testing

and also

documents

the as-left

ring settings

which are the ring settings after all maintenance

and testing

have

been

completed.

In several

instances

the

1985

MSSV as-left

ring settings

were

not

the

same

as

the

1987

as-found ring settings.

Once adjusted,

HSSV rings are locked in

place;

therefore,

the

1985 as-left

and

1987

as-found

ring

settings

should

have

been

the

same.

Examples of Unit 3

ring setting discrepancies

are

as follows:

Valve No.

BL0398

BL0391

BL0389

BL0388

1985

As-Left

Rin

Settin

s

-6/+165

1987

As-Found

-6/+197

-6/+199

-8/+217

-7/+183

The Unit 4

1984

and

1986

WYLE Test Reports

also indicate

discrepancies

between

ring settings.

Examples of such

are

as

follows.

Valve No.

BL0399

BL0403

BL0409,

1984

As-Left

Rin

Settin

s

-6/+165

1986

IE Information Notice 86-05,

As-Found

Rin

Settin

s

-8/+203

-8/+133

-8/+223

The

reason

for the

discrepancies

between

the as-left

and

as-found

MSSV ring settings

is

unknown.

This

matter

is

identified

as

unresolved

item

250,

251/89-07-01

pending

completion of the

licensee

investigation

into why these

HSSV

ring setting discrepancies

exist.

,

10

During the Unit 3 1987

RFO, Unit 3

PSVs

551A and

B were setpoint

tested

in accordance

with Procedure

3SNM-041. 1 which requires

that

the

as-found

PSV lower ring setting

be

determined

and

documented

in

the

procedure.

After testing

completion,

Procedure

3SMM-041-1 requires

the lower

PSV ring to be returned

to the previous

as-found

recorded setting.

In lieu of returning

the

lower rings to the

as-found

setting,

the lower rings

on

valves

PSV

551A

and

B

were

set

to

the

on site

vendor

recommendations

which conflicts with the instructions contained

in Procedure

3SMM-041.1.

During the Unit 3 1987

RFO, Unit 3

PSV,

551C,

was repaired for

seat

leakage

and setpoint

tested

in accordance

with Procedure

3CNM-041. I which requires

the

as-found

upper

and

lower ring

settings

be

counted

and

documented

in the

procedure.

After

completing

the testing,

Procedure

3CMM-041. 1 required the rings

to be returned to the previously recorded

as-found settings.

In

lieu of returning

both upper

and

lower rings to the as-found

setting

as required

by the procedure,

both upper

and lower rings

were set to the

on site vendor

recommendations

which conflicts

with the instructions

contained

in Procedure

3CMM-041. 1.

Failure to adjust

PSV ring settings

following setpoint testing

and

maintenance

in accordance

with Procedures

3SMM-041. 1

and

3CNM-041. 1 is identified as Violation 250, 251/89-07-02.

FPL inter-office correspondence

dated

August 12,

1986,

File

No: P-7-1, identified a discrepancy

between

the current

PSV ring

settings

and as-shipped

from Crosby ring settings,

and requested

that procedures

be revised to require setting of PSV rings to

the original as-shipped

settings prior to the return to service

following the

or testing activity.

The

following April, during

the

1987

RFO, all Unit 3

PSVs

were

tested.

The procedures

used to test the

PSVs,

3SNM-041. 1 and

3CMM-041. 1,

had not been revised to reset

the ring settings

to

the

as-shipped

values

as

requested

in the

August

12,

1986

inter-office correspondence,

and

as

a result, the rings were not

adjusted to the as-shipped

valves.

During the Unit 4

1988

RFO,

PSV

551B

was

replaced,

and

the

replacement

valve's rings were set in accordance

with Procedure

4CMM-041.1 which specified

-5 notches for the

lower ring and

-235 notches for the upper ring.

The inspectors

requested

the

as-shipped

vendor ring settings

for the replacement

valve

and

was

informed

by the licensee

that the ring settings

were

-16

notches for the lower ring and -260 notches for the upper ring.

During replacement

of the Unit 4

PSV 551B, the licensee failed-

to revise

Procedures

4CMM-4. 11

and

4SMM-4. 11 to recognize

the

replacement

PSV ring settings.

Per telecon

on March 2,

1989,

the

licensee

committed

to adjust

PSV 551B ring settings

to

11

vendor specifications

or evaluate if the present

ring settings

are adequate

prior to Unit 4 startup

from the present

RFO.

Failure

to revise

procedures

to recognize

correct

PSV ring

settings

is identified as Violation 250, 251/89-07-03.

d.

Main Steam Valve Test Failures

and Ring

Setting Adjustments,

and Supplement

1 Followup

This Information Notice alerts

licensees

that

MSSVs

on pressurized

water reactors

may have

never

been

adequately

tested

to verify that

the valves

could

pass full rated

steam flow.

Several

examples

were

cited

where utilities had to adjust

the

MSSV ring settings

from

vendor original specifications

to

new settings

based

on full flow

testing performed

on the licensee's

MSSVs.

During the Unit 3

1987

RFO,

WYLE tested

the

MSSVs for blowdown,

and

made the required ring setting

adjustments

to obtain

a four to five

percent

blowdown for each valve.

While testing for blowdown, valve

disk lift was

measured

and verified to lift the required

amount to

pass full rated

steam flow.

Unit 4's

MSSVs, were tested

and adjusted

for blowdown during the present refueling outage at WYLE.

The Unit 4

WYLE Test

Report

was not yet available.

The following Unit 3

MSSV ring settings

were adjusted

to the following settings

in order

to obtain the desired

blowdown:

Valve No.

BL0387

8L0388

BL0389

BL0391

BL0392

BL0393

BL0395

BL0396

BL0397

BL0390

BL0394

BL0398

Name Plate

Rin

Settin

s

-6/+158

-7/+183

-6/+217

-6/+199

-8/+180

-18/+208

-6/+172

-6/+158

-6/+168

-5/+175

-8/+200

-6/+197

Ring Settings

Required for

4-5 Percent

Blowdown

-8/+160

-8/+200

-8/+160

-6/+172

-6/+162

-8/+160

-10/+180

-8/+200

-10/+280

-6/+162

-8/+170

Within the areas

inspected,

two violations were identified.

4.

TI 2515/100 - Proper

Receipt,

Storage,

and Handling of Emergency

Diesel

Generator

(EDG) Fuel Oil (25588)

The inspectors

reviewed

the

EDG fuel oil storage

and supply system, with

emphasis

on licensee

programs

to insure

adequate

Fuel Oil

(FO) quality.

This inspection

was

performed

using

the

guidance

contained

in Temporary

Instruction (TI) 2515/100,

and specific details

are included below:

The licensee

periodically recirculates

FO in the main storage

tank

using

a

temporary

setup

to

remove

accumulated

particulates.

Recirculation is performed at intervals less

than

one year.

All

FO storage

tanks

have

been

cleaned

and inspected

per approved

procedures

within the ten year minimum in accordance

with Regulatory

Guide

(RG) I. 137, Fuel-Oil Systems for Standby Diesel Generators.

Chemical

additions to the

EDG

FO to prevent oxidation

and bacterial

growth are

done using

Procedure

O-NCOP-022,

Diesel

Fuel Oil Delivery

Truck Chemical Addition.

Periodic

skid tank,

day tank,

and

main storage

tank

sampling

is

conducted

in

accordance

with

ASTM D4057-81,

Manual

Sampling

of

Petroleum

and

Petroleum

Products,

and

is

being

performed

using

approved procedures.

Samples

are analyzed

per

ASTM D975-77, Standard

Specification

for Diesel

Fuel Oils,

and

EDG vendor

Maintenance

Instruction

1750,

Rev.

H.

Main storage

tank samples

are taken from

the

FO transfer line, which is approximately

9 inches

above the tank

bottom.

Day tanks

and integral

tanks are being checked for water monthly,

and

after each

EDG operation greater

than one hour.

Accumulated water is

drained

from the main storage

tank

once every

92 days per Procedure

0-0SP-022.'6.

Filter and strainer preventative

maintenance

is being performed

per

vendor recommendations,

and is controlled by plant procedures.

In addition to the TI 2515/100,

the inspectors

also compared

the licensee

EDG

FO program with

RG 1. 137. Although the licensee

is not committed to

RG

l. 137, consideration

could result in potential

improvements

to

FO quality.

The following items were discussed

with the system engineers

and licensee

management:

RG

1. 137 requires

that prior to adding

new

FO to the main storage

tanks,

onsite

samples

should

be

taken

and

tests

should

be

conducted

to determine specific or API gravity, water

and sediment,

and viscosity.

The licensee currently samples

new fuel

and tests for

the

above

properties

(and

other properties),

but results

are not

available until after fuel is transferred

to the main storage

tank.

Licensee

management

cormitted verbally to onsite

EDG fuel oil testing

for API gravity, water

and

sediment,

and viscosity prior to adding

fuel oil to the main storage

tanks.

13

ANSI N195-1976,

Fuel Oil Systems for Standby Diesel-Generators,

which

is referenced

in

RG

1. 137,

states

the

FO system

shall

be provided

with

a strainer

of duplex design,

and

one differential

pressure

indicator for each duplex strainer.

The licensee's

system contains

a

single strainer at the

pump suction, with a pressure

indicator at the

pump discharge.

Duplex filters at

the

pump

discharge

are

run

as

dual

element.

Currently,

the

EDG is declared

inoperable

when

these filters are

replaced

per

the

quarterly

preventative

maintenance

procedure.

System

engineers

are currently planning

a special

test to determine

if operating

the

EDG fuel oil filters in a single element line up in

lieu of the current

duplex lineup is prudent.

Licensee

management

committed to conducting this test,

and implementing

a single element

filter alignment in

EDG operating

procedures

by May 26,

1989.

This

commitment is identified as

Inspector

Follow-up Item (IFI) 89-07-04.

Within this area,

no violations or deviations

were identified.

5.

Inservice

Testing

-

Primary

Containment

Isolation

Valve Stroke

Time

Testing

(73756)

The inspectors

reviewed

primary containment

isolation valve stroke time

results

obtained

from Operating

Procedure

0209. 1,

Valve

Exercising

Procedure,

dating

back to

1986.

The requirements

for performing valve

stroke

times

are contained

in the licensee's

Inservice Test

Program for

Pumps

and

Valves,

which invoke Section XI, Subsection

IWV of the

1980

American Society of Mechanical

Engineers

(ASME) Code Edition thru Winter

1981 Addenda.

Paragraph

IWV-3417(a) requires

that if a stroke

time increase

of 25

percent

or more from the previous test for valves with full-stroke times

greater

than

10 seconds

or 50 percent or more for valves with full-stroke

times less

than or equal

to

10 seconds

is observed,

test frequency shall

be increased

to once each

month until corrective action is taken, at which

time the original test

frequency shall

be

resumed.

In any case,

any

abnormality or erratic action shall

be reported.

The inspectors

reviewed testing records

and interviewed licensee

personnel

regarding

the

general

methods

used

during valve stroke testing.

The

licensee

stated that for an occasional

valve stroke time that exceeded

the

50 percent

(or 25 percent,

as appropriate)

requirement,

the corrective

action

may involve re-stroking the valve

two or three

more

times.

If

subsequent

re-stroking

results

in stroke

times

which

exceeded

the

50

percent

requirement for increased

testing frequency,

the valve is placed

in the monthly surveillance

frequency

and corrective action is taken.

However, if subsequent

re-stroking results

in stroke times which did not

appear

to be abnormal

and which would not increase

testing frequency,

no

further

action

is

taken

and

testing

frequency

remains

unchanged.

Specifically,

the following two cases

were identified by the inspectors:

14

Val ve

CV-4-2907,

tested

January

7,1988, initially opened

in 8.8

seconds,

which

was greater

than

50 percent

from the previous test.

The valve was re-stroked in 5.0 seconds

and 4.2 seconds

(less

than

50

percent

from the

previous test),

and

the surveillance

frequency

remained

unchanged.

Valve CV-3-4658A, tested

on August 7, 1988, initially closed in 1.48

'seconds,

greater

than

50 percent

from the previous test.

Subsequent

valve stroke

times

were

0.61

and

0.59

seconds,

and surveillance

frequency

remained

unchanged.

Failure to increase

testing

frequency

when valves initially exceeded

a

stroke

time increase

of 50 percent

or more for valves with full-stroke

times

less

than or equal

to

10 seconds,

and failure to take appropriate

corrective action is

a violation of the

ASME code Section

XI Paragraph

IWV

3417(a)

and is identified as Violation 250, 251/89-07-05.

In addition,

the

inspectors

also

noted

valves

CV-4-519A,

CV-3-6275C,

CV-4-6275C,

and

POV-4-2600 in which the stroke times were annotated

in the

procedure

to

be abnormally

low,

and

the licensee

has not used this low

stroke time

as

a basis for determining

subsequent

surveillance

frequency.

All stroke

times

should

be

used

in the determination

of surveillance

frequency.

Until this practice

is corrected, it will be identified as

IFI 250, 251/89-07-06.

The inspectors

did not note

any valves

where

the limiting stroke times

were

exceeded

and corrective

action

was

not initiated.

In addition,

valves

placed

on increased

surveillance

frequencies

were tested

at the

required

time intervals.

In addition to reviewing valve stroke times,

the inspectors

questioned

the

licensee

on

the

basis

for specified

ultimate

valve

stroke

times.

Paragraph

IWY-3413 of the

Code states

that the limiting value of full-

stroke

time of each

power operated

valve shall

be specified

by the owner.

A valve in which the stroke

time exceeds

the ultimate stroke

time is

declared

inoperative if not corrected

within

24

hours

as

required

by

Section

XI Paragraph

IWV-3417(b).

The ultimate valve stroke time should

be

based

on individual valve characteristics,

with consideration

given to

system

conditions.

Licensee

procedures

reviewed

by the

inspectors

revealed that ultimate valve stroke

times were specified for each valve;

however,

the

licensee

could not

a provide

an

adequate

basis

for these

times.

The

inspectors

noted

the following two valves

in which the

ultimate

stroke

time'pecified

by

procedure

was

greater

than

the

recommended

stroke time:

For

pressurizer

power

operated

relief valves,

a

Westinghouse

evaluation

requires

the

valves

to

open

in

2 seconds,

while the

licensee

specified ultimate stroke

time was

10 seconds.

This item

was previously identified by

NRC resident inspectors.

15

For steam generator

blowdown control valves,

the

recommended

actuator

name plate closing time is 2-3 seconds,

while the licensee

specified

ultimate stroke time was

15 seconds. 'alve actuation

can

be adjusted

by throttling the solenoid exhaust valve.

The licensee

commented

that ultimate stroke

times for some

valves

are

conservative,

and

were

not

necessarily

based

on

specific

valve

characteristics

but

on

system'esponse

requirements.

The

inspectors

stated

that

a

conservative

valve ultimate

stroke

time

may

not

be

representative

of the

point at

which the

valve

should

be

declared

inoperable.

Limiting values

of full-stroke times for power operated

valves will be addressed

in

a Generic Letter on Inservice testing

soon to

be issued

by the Nuclear Regulatory

Commission.

Within this area,

one violation was identified.

6.

Corrective Action Program

The

inspectors

discussed

with licensee

personnel

the effectiveness

of

quality verification activi ties for the following violations identified in

this report:

a.

Violation 250,

251/89-07-02 - Failure to adjust

PSV ring settings

following setpoint

testing

and

maintenance

in

accordance

with

Procedures

3SMM-041. 1

and

3CMM-041. 1.

The licensee

should

have

been

aware of this problems but was not.

b.

Violation 250,

251/89-07-03

- Failure

to revise

procedures

to

recognize

correct

PSV ring settings.

This violation identifies

two

examples

where procedures

were not revised to recognize correct

PSV

ring settings.

In the first example,

the licensee

recognized

that

the

procedures

needed

to

be revised,

but did not take action to

revise the procedures

in a timely manner.

In the second

example,

the

licensee

should

have

been

aware that the

procedures

needed

to

be

revised,

since

the

replacement

valve required'ifferent

ring

settings.

c ~

Violation 250,

251/89-07-05 - Failure to increase

inservice testing

frequency,

and failure to take

adequate

corrective

action.

The

licensee

stated

that

they

were

aware

that

the

valves initially

exceeded

stroke .time requirements,

but considered

the current re-

stroking practice

to

be

prudent

and sufficient corrective action.

Therefore,

increased

surveillance

frequency

was not necessary.

16

7.

Exit Interview

The inspection

scope

and findings were

summarized

on February

17,

1989,

with those

persons

indicated in paragraph

1.

The inspectors

described

the

areas

inspected

and

discussed

in detail

the

inspection

results

listed

below.

The licensee

did not identify as proprietary any of the material

provided

to or

reviewed

by the

inspectors

during this

inspection.

Dissenting

comments

were not received

from the licensee.

Item Number

250, 251/89-07-01

250, 251/89-07-02

250, 251/89-07-03

250, 251/89-07-04

250, 251/89-07-05

i'50,

251/89-07-06

Descri tion and Reference

Unresolved

Item - Discrepancies

between

as-left

and

as-found