ML18009A360

on

the above

check valves:

ISI-203,

Rev. 6: ASME Section

NI

Pump

and Valve Program

Plan

OST-'1006,

Rev.

3, Boration System Operability Monthly Interval,

Modes 1-2-3-4-5-6

OST-1007,

Rev.

3,

CVCS/SI System Operability quarterly Interval,

Modes 1-2-3-4

. OST-1501,

Rev.

1,

ECCS Check Valve Full Flow Verification quarterly

Interval,

Mode

5

OST-1505,

Rev.

1. Boric Acid Flow Path

Check Valve ISI Test

quarterly Interval,

Mode

5

OST-1106,

Rev.

2,

CVCS/SI System Operability quarterly Interval,

Modes 4-5-6

OST-1801,

Rev.

3,

ECCS Throttle Valve CSIP

and Check Valve

Verification,

18 Month Interval,

Mode

6

Requirements

for full stroke

and reverse

flow exercising

check valves are

contained

in Section XI, Subsection

IWV-3520 of the Code.

A review of ISI-203,indicated

that

check valve

CS-525

was

not in the

licensee's

IST program,

and

thus

was

not full stroke tested.

This check

valve is located in the gravity feed flow path from the boric acid tank to

the

CSIP

suction.

In

an interoffice correspondence

dated

November

15,

1988,

the

licensee

evaluated

the

need

to forward flow test this

check

valve,

which at

that

time

was

in their

program.

The

licensee

concluded'hat

the

check

valve did not require

inclusion

in the

program,

based

on the following:

The valve/flow path is not mentioned in Chapter

15 of the

FSAR

The flow path is addressed

in TS, but requires

manual initiation

The flow path is only used

when

both boric acid transfer

pumps are

inoperable

and suction

from the

RWST is lost

Forward flow testing would be difficult

The

inspectors

noted

that

the

gravity

feed

flow path

can

be

used,

according

to procedure

OST-1006, to satisfy

TS 3. 1.2. 1.

This

TS requires

during Modes 4, 5,

and 6,

as

a minimum, that

one of the following boron

injection flow paths shall

be operable:

Boric acid tank via either boric acid transfer

pump and

a CSIP

Boric acid tank via

a gravity feed connection

and

a CSIP

Refueling water storage

tanl

via

a CSIP

The

bases

of

TS 3. 1.2. 1 are that during

modes

4,

5,

and

6,

one

boron

injection flow 'path is acceptable

without single'ailure

consideration

due

to the

stable

reactivity condition of the

reactor

and

the

additional

restrictions prohibiting core alterations

and positive reactivity changes.

The

inspectors

concluded

that

check

valve

CS-525

meets

the

scope

of

IWV-1100, which defines

IST in

terms

of valves

which are

required

to,

perform

a

specific.

function

in shutting

down

a reactor

'to the

cold

shutdown

condition

or in mitigating

the

consequences

of

an

accident.

Since

the gravity feed

flow path

can

be

used

by OST-1006 to satisfy

TS

3; 1'.2. 1, check valve CS-525 must

be included in the licensee's

IST program,

and tested

accordingly.

Failure to test

check valve CS-525 is

a violation

of, IWY-3521,

and is identified

as

Part

A to violation 50-400/89-35-01,

Failure

to

Perform

on

Check

Valve CS-525.

The licensee

initiated

prompt corr'ective

ac;ion

by reviewing

completed

OST-1006

procedures

and

verified that the gravity feed flow path

had never

been

used to satisfy

TS

3. 1.2. 1.

In addition,

OST-1006

was revised

during

the

inspection

such

that the gravity feed flow path could not be used

as

an operable

flow path

until CS-525 is adequately

tested.

The inspectors

also

noted that

CS-775

and

CS-776

were

not

included in the licensee's

IST program,

and thus were not tested.

Each of

these

check valves are located in a flow path which cross-connects

the

pump discharge

to the

CSIP suction.

Failure of these

check valves to open

would preclude

the

use

of the

CSIPs

during .the

recirculation

phase

following a

LOCA.

The inspectors

concluded

these

meet

the

scope of IWV-1100, which defines

IST in terms of valves which are required

to perform

a specific function in shutting

down

a reactor

to the cold

shutdown

condition

or in mitigating the

consequences

of

an

accident.

Failure to test

CS-775

and CS-776 is

a violation of IWV-3521,

and is identified

as

Part

A to violation 50-400/89-35-01,

Failure

to

Perform

IST on Check Valves CS-775

and CS-776.

The

inspectors

also

questioned

the

licensee

on testing

check

valves

CS-179,

CS-207,

and

CS-193.,

These

valves

are

located

in

the

CSIP

mini-flow line,

and

are full stroke exercised

by procedures

OST-1007

and

OST-1106.

The

procedure

determines

full stroking

each

check

valve

by

opening

an'OV

downstream

of the

check

valves,

and listening for

an

audible tone

change-when

the

CSIP is operating.

The inspectors

concluded

that this

method

only verifies that

an

unknown quantity of flow passes

through

the

check

valve,

and

does

not verify that

each

check

valve

full-strokes

open.

In addition,

GL 89-04 states

that

a valid full stroke

by flow requires

that the flow through

the valve

be

known.

Failure to

adequatelv

test

check

valves

CS-179,

CS-207,

and

CS-193

is

a violation

of IWV-3522,

and is identified

as

Part

B to violation 50-400/89-35-01,

Failure to Adequately Perform

IST on Check Valves CS-179,

CS-207,

and CS-193

GL 89-04

provides

guidance

in the

area

of IST, particularly for check

valve testing,

review of IST programs to ensure

adequate

scope of testing,

generic

deficiencies,

and

NRC staff positions

on

acceptable

testing

methods.

In addition,

GL 89-04 discusses

other testing

requirements,

such

as

10 CFR 50, Appendix A, Criterion 1, which requires,

among other things,

that

components

important

to

safety

be

tested

to quality

standards

commensurate

with the importance of the safety functions to be performed.

10 CFR 50, Appendix B, is also discussed

in GL 89-04,

and includes testing

for safety-related

components

as

part of

a quality

assurance

program.

Paragraph.

(g) of 10 CFR 50.55a requires

the

use of Section

XI of the

ASME

Code for inservice testing of components

covered

by the

Code.

For other

components

important to safety

but outside

the

scope

of

Section

XI

testing,

the licensee

also

has the-burden of demonstrating their continued

operability,

as required

by Appendix A and

B to

10 CFR 50.

Based

on the

multiple examples

of the

IST related violation identified in this report,

the

inspectors

concluded

the

licensee's

review of

GL 89-04 was'ot

thorough.

The inspectors

also

reviewed

check

valve reverse

flow testing,

which is

required by, the

Code for check valves which perform

a safety function in

the closed position.

Subsection

IWV-3522 requires

check valve testing in

a

manner

that verifies

the disk travels

to

the

seat

on cessation

or

reversal

of flow.

As stated

in relief request

RV-l, the licensee

performs

a

10 CFR 50,

Appendix J,

type

C local

leak rate test

for containment

isolation

check

valves

CS-344,

CS-385,

CS-426,

CS-471,

and

CS-477,

to

verify these

perform their safety

function.

The inspectors

reviewed

procedure

EST-212,

Rev.

3,

Type

C

Local

Leak

Rate

Test,

associated

results,

and verified that

analysis

of

leakage

rates

and

corrective

actions

were in conformance

with the requirements

of IWV-3426

and

IWV-3427.

Within the

areas

inspected,

two

examples

of the

IST violation were

identified.

Pump Testing

(73756)

The inspectors

reviewed

IST for three

CVCS/SI

pumps (3) and two boric acid

transfer

pumps

to

determine if periodic

testing

was

performed

in

accordance

with Section

XI, Subsection

IWP requirements.

The following

CVCS/SI

pump implementing procedures

and .test results for the previous

two

year period were reviewed:

ISI-203,

Rev.

6,

ASME Section

XI Pump

and Valve Program

Plan

ISI-800,

Rev.

2, Inservice Testing of Pumps

OST-1007,

Rev.

3,

CVCS/SI System Operability quarterly Interval,

Modes 1-2-3-4

OST-1106,

Rev.

2,

CVCS/SI System Operability Quarterly Interval,

Nodes 4-5-6

OST-1505,

Rev.

1, Boric Acid Flow Path

Check Valve ISI Test

Quarterly Interval,

Mode

5

The inspectors

verified that the

above test procedures

incorporated

ASME

Code

requirements

concerning

acceptance

criteria,

test

frequency

and

duration,

calibration

of instrumentation,

time allowed for analysis

of

test results,

and action to be taken if the measured

pump test quantities

fell within the alert or required action range.

The review of test data

indicated that

acceptance

criteria were being

met

and both the

CVCS/SI

pumps

and boric acid

pumps

measured

test quantities

remained within the-

acceptable

range.

Within the areas

inspected,

no violations or deviations

were identified.

5.

Power Operated

Valve IST (73756)

The inspectors

reviewed

IST for the following MOVs and

AOYs in the

CVCS:

CS-480

CS-9

CS-470

CS-746

CS-214

CS-217

CS-165

CS-170

CS-492

CS-341

CS-472

CS-752

CS-182

CS-218

CS-166

CS-171

CS-7

CS-11

CS-382

CS-235

CS-210

CS-219

CS-168

CS-291

CS-8

CS-238

CS 423

CS-231

CS-196

CS-220

CS-169

CS-292

The

inspectors

interviewed

licensee

personnel

regarding

the

general

methods

used

to stroke

time

power operated

valves.

The inspectors

also

reviewed

appropriate

relief

requests,

and

reviewed

the

following

implementing procedures

for IST of the previously listed valves:

ISI-801,

Rev.

2, Inservice Testing of Valves

OST-1106,

Rev.

2,

CVCS/SI System Operability Quarterly Interval,

Modes 4-5-6

OST-1072,

Rev.

0,

CVCS/SI

Remote Position Indication Test

Criteria for IST power operated

valves is contained

in Subsections

IWV

3412,

3413,

3415,

and

3417 of the

ASME Code.

These

Subsections

specify

stroke

timing, fail-safe testing,

and corrective

action

requirements.

Subsection

IWV-3300 addresses

valve position indicator verification which

requires

checking

remote

position

indication

once

every

two years

to

verify that

valve

operation

is accurately

indicated.

The

inspectors

verified that testing

was performed in accordance

with code requirements,

and that testing data

and subsequent

corrective actions

were satisfactory.

The inspectors

raised

a concern

regarding

the

performance

of the

Remote

Position

Indication Surveillance

Test

(OST-1072) prior to performing the

stroke

time testing of these

valves

(OST-1106).

This practice

has

the

r

potential

for

masking

deficiencies

in

valve

performance

and

valve

degradation.

The licensee

stated

that these

tests

are usually performed

concurrently,

thus the valve is only stroked

once to satisfy stroke timing

and position indication requirements.

However,

the inspectors

review of

noted

that

the

remote

position

indication test

was

'erformed

the

day before

the

stroke

time testing.

To correct

this

weakness

in valve stroke timing, the licensee

agreed to revi se OST-1072 to

notify operators

of the

need to perform OST-1072 concurrently or after the

performance

of OST-1106.

The inspectors

also

reviewed

the stroke time testing results for all IST

valves

in the

CVCS performed

during the

past

three

years,

as

well

as

maximum,

alert,

and

increased

test

frequency

values.

In addition,

maintenance

work requests

were

reviewed

for selected

valves,

including

post-maintenance

testing

requirements

and

acceptance

criteria.

The

results within these

areas

of review were satisfactory.

During

a review of systems

which interface with the

CVCS, the inspectors

questioned

the

licensee

on the

need

to fail-safe test

valves

RH-20

and

RH-5S.

These

valves

are

power operated

valves

(AOVs), which control

the

RHR heat exchanger

bypass

flow, and

have

a fail-safe position.

Subsection

IWV-3415 provides

the

requirements

for testing

valves

with fail-safe

actuators.

Valves

RH-20 and

RH-58 were not in the licensee's

IST Program,

thus

no

IST was

being

performed.

The

licensee

stated

that

the

normal

position .of these

valves is the failed position,

and

as

such,

do not have

to change position to fulfillthei r safety

function.

Valves that

do not

have

to

change

position

to fulfill their

function

are classified

as

passive

valves,

which have

no exercising requirements'n

addition,

the

licensee

stated that during plant conditions

where

these

valves

may

be

open

(such

as during

Mode

4 when the

RHR system is in operation),

they are

not required to mitigate the consequences

of an -accident or shut the plant

down to the cold shutdown condition.

Thus,

the licensee

considers

these

valves to be outside

the

scope of Sect'ion

XI testing.

During normal at-power operation,

the

RHR system is available

in stand-by,

and

the position

of these

valves

(closed)

is the

same

as

the fail-safe

position.

These

valves

are

opened during normal

RHR system operation,

as

stated

in procedure

OP-111,

Rev.

4,

Residual

Heat

Removal

System,

to

initially prevent thermal

shock to the

RHR heat exchangers,

and to control

and maintain

cooldown

such

as during Mode 4.

Thus,

the normal position is

not always closed.

Failure of these

valves to close

on demand

once they

are

open,

whether

as part of the

system

control

or inadvertently,

could result

in

a majority of the

pump flow bypassing

the

RHR heat

exchanger.

The heat

exchanger

would be bypassed

due to the pressure

drop

across

the vertical

U-Tube heat

exchanger,

and the fact that the bypass

line (nominal eight inch diameter)

is approximately

the

same

diameter

as

the

RHR heat

exchanger

flow path (ten inch nominal diameter).

Bypassing

the

RHR heat

exchanger

would substantially

reduce

the ability to remove

residual

heat

by the

normal

method

of utilizing the

system.

In

addition,

FSAR Table 5.4.7-3 contains

a Failure

Mode and Effects Analysis

on

the

active

components

of

the

system

during

plant

cooldown

operation.

The Table

states

that

a failure of the

RHR bypass

valve to

close, on

demand

would have

no effect

on safety for system operation,

in

that the heat

exchanger

discharge

flow control valve can

be throttled and

the redundant,

RHR train can control cooldown.

However,

since the

RHR heat

exchanger

bypass

flow control valves are

common to each train and both are

not fail-safe tested, it cannot

be assumed

that the other

RHR train could

be used to control cooldown.

The inspectors

consider

the

RHR heat exchanger

bypass

flow control valves

to

be power-operated

valves with

a fail-safe position.

IWV-1100 defines

the

scope for IST in terms of valves

which

are

required

to perform

a

specific

function

in

shutting

down

a

reactor

to

the

'cold

shutdown

condition

or

in mitigating the

consequences

of an accident., Failure of

these

valves to close

on demand

would preclude

the safety function of the

RHR system,

which is

needed

to bring the reactor

to cold

shutdown

and

mitigate

the

consequences

of

an

accident.

In addition,

GL 89-04 also

provides

guidance

specifically in the

area

of testing

the fail-safe

function of control valves,

and in the area of reviewing

IST programs to

ensure

adequate

scope.

Based

on the above,

the inspectors

concluded

that

failure to fail-safe test these

valves is

a violation of IWV-3415, and is

identified as Part

C to violation 50-400/89-35-01,

Failure to Perform

on Valves

RH-20 and

RH-58.

Within the

areas

inspected,

one

example

of

the

IST violation

was

identified.

6.

Safety

and Relief Valve IST (73756)

The inspectors

reviewed

IST for the following safety

and relief valves in

the

CVCS and

RCS systems:

RC-123

RC-125

CS-10

CS-744

CS-127

CS-310

The inspectors

interviewed

licensee

personnel

regarding

the methods

used

to test relief valves

and

reviewed

the following implementing

procedures

for IST of the previously listed valve's:

EST-211,

Rev.

4, Auxiliary Relief Valve Testing

Crosby Test Procedure

T-16548,

Rev.

0, Testing of HB-BP-86 Style

Pressurizer

Safety Valves with Flexi-Disc Seating

for Carolina

Power

and Light Company

WYLE Laboratories

Test Procedure

1032,

Rev.

A, Dresser/Crosby

Pressurizer

Safety Relief Valve Non-Elevated

Temperature

Test

The criteria for

IST of relief valves

and safety

valves is contained

in

ANSI/ASME OM-1-1981,

Requirements

for Inservice

Performance

Testing

of

Nuclear

Power Plant

Pressure

Relief Devices.

TS 3.4.2.2

specifies

a

PSV

setpoint

tolerance

of 2485

plus/minus

one

percent

PSIG.

Results of this

review indicated

that all testing

was

accomplished

in accordance

with

ANS I/ASME OM-1-1981.

SHNPP

PSVs

are installed

on unisulated

loop seals.

During the

1988

RFO

one

PSV

was

removed

and

sent

to

WYLE Laboratories

for setpoint testing,

and

a spare

PSV

was installed.

Prior to installation of the

spare

PSV,

the valve was sent to Crosby

and setpoint tested.

Crosby setpoint tested

the

PSV utilizing air at

70 plus/minus

10'F

as

the test

medium,

then

tested

with water at 250'F with ambient temperature

maintained at 130'F;

the valve was allowed to cool

and then retested

using air at 70 plus/minus

10'F.

No adjustments

were

made to change

setpoint.

The guide

and nozzle

rings were adjusted

to obtain crisper

pops.

The results

of the

Crosby

setpoint testing

were

as follows:

Test

Medium

Po

in

Pressure

PSIG

Air

Water

Air

2500

2488

2499

2469

2465

2489

2497

2483

The

PSV that was

removed

and sent to

WYLE Laboratories

during the

1988

RFO

was setpoint tested

with steam

at

650

F as

the test

medium.

During the

steam testing,

valve

body temperature

was

510'F

and

ambient

temperature

was 140'F.

Following the

steam tests

the valve

was

allowed to cool

and

then tested

with water at

130'F as the test

medium.

During this testing

ambient temperature

was maintained at

115~F.

The results

were

as follows:

Test

Medium

Steam

Water

2492

2488

2502

2509

2507

During the

1989

RFO

a

Results of this testing

Test

Medium

PSV

was

removed

and

sent to

WYLE Laboratories.

were:

Set oint PSIG

Steam

Water

2456

2453

2475

2477

2494

Both Crosby

and

>/YLE test results

indicated that higher valve temperatures

result in lower valve setpoints.

The inspectors

also

reviewed

the test

methods

and test

r'esults

of

CVCS

valves

previously

listed

at

the

beginning

of this

paragraph.

The

inspectors

suggested

that the licensee

develop

a correlation

between water

at ambient temperature

and 290'F for valve CS-10.

CS-10

was

bench tested

with water at ambient

temperature;

however,

during

nominal

oper'ation

the

valve

is

exposed

to water

at

approximately

290~F.

This

temperature

difference

may effect the setpoint.

This

item

was

discussed

with the

licensee.

Within the areas

inspected,

no violations or deviation were identified.

7..

Complex Surveillance

(61701)

TS Surveillance

Requirements

4.4.4.1.b

and 4.4.9.4.1.b

require that each

pressurizer

PORV be demonstrated

operable

at least

once every

18 months

by

performing

a

channel

calibration.

The inspectors

reviewed

the following

procedures

that accompli sh tni s surveillance

requirement:

MST-I0250,

Rev.

1,

Reactor

Coolant

System

Cold Overpressure

Protection

Loop, P-0440,

Opera.ional

Test

MST-I0248,

Rev.

2,

Reactor Coolant

System

Cold Overpressure

Protection

Loop, P-0440, Calibration

MST-I0088,

Rev.

2

Reactor

Coolant

Loop Hot Leg Temperature,

T-413,

Calibration

MST-I0109,

Rev.

1,

Pressurizer

Pressure

and

PORV Loop, P-0445,

Calibration

MST-I0092,

Rev.

1,

Reactor

Coolant

Loop

2 Cold Leg Temperature,

T-402, Protective

Set II Calibration

Pressurizer

PORV

channel

calibrations're

accomplished

by performing

a

series of overlapping procedures.

Results of the inspectors

review of the

PORV channel

calibration

procedures

was that with the exception

of the

K710 contacts

and associated

wiring, all components

in the channels

were

properly tested.

The

K710 contacts

operate

in

response

to the

safety

injection unblock pressure

signal,

P11.

Above 2000

PSIG the

K710 contacts

are closed which completes

the circuit to allow automatic

PORV operation

if a high pressurizer

pressure

condition existed.

Below 2000

PSIG,

the

K710 contacts

open to prevent

automatic

PORV actuation.

The

inspectors'oncern

was that if the

K710 'contacts

failed to close at 2000

PSIG with

increasing

pressurizer

pressure,

then

the

automatic

function

for

the

associated

PORV would be disabled.

The fact that the

K710 contacts failed

to close

and disabled

the associated

PORV automatic function, would not be

detected

unless

a high pressurizer

condition existed

and the

PORV failed

to open.

The licensee

stated that per

TS Table 4-3-2,

Engineered

Safety

Features

Actuation

System

Instrumentation

Surveillance

Requirements,

the

K710 contacts

were

not required

to

be tested.

Item 10.a of Table 4-3-2

states

that Pll actuation

logic testing,

master

relay testing,

and slave

relay testing is not required.

The licensee

stated that there is no built

10

in test circuit that would allow the

K710 contact to be easily tested.

In

order to resolve

the

issue

of the

K710 contacts

having to

be tested

as

part of a channel calibration,

Region II will request

NRR assi stance.

The

issue of testing the

K710 contacts

and associated

circuitry was identified

as

URI 50-400/89-35-02,

Testing of PORV channel.

While reviewing the

PORV channel

calibration

procedures,

the inspectors

were informed by the licensee

that the

PORVs were required to

be capable

of being

manually

opened

and closed

to

be considered

operable,

and that

the

automatic

functioning

of

these

valves

was

not

an

operability

requirement.

This policy was

documented

in

a licensee

internal

document

as

TS Interpretation

Number 89-001.

The

inspectors

disagreed

with the

licensee's

interpretation

of

TS

3'.4.4.

The

inspectors

interpreted

TS 3.4.4 to require

PORV automatic

function

be available

in order for the

valves

to

be operable.

Per

TS bases,

Section 3/4.4.4,

operation

of the

PORYs minimize the undesirable

opening of the spring-loaded

pressurizer

code

safety

valves.

The

inspectors

consider

that in order to prevent

opening

of the

PSVs,

the

PORV automatic

function is

required

to

be

operable.

If the

automatic

function

of

one

or

more

PORVs

is

not

available,

then per the licensees

interpretation

of T/S 3.4.4,

the block

valves

could

be

shut

and

the

plant

operated

indefinitely.

Per

the

inspectors

interpretation,

the plant would

be required to

be

shut

down.

The inspector's

interpreta-'.ion

is also

based

on

a

NRC memorandum

from NRR

to Region II concerning

a similar'ssue

with respect

to this

TS.

This

memorandum,

provided

as

Enclosure

3 to this report,

documents

the staff

interpretation

of

the surveillance

requirement,

and

states

that

the

automatic

function of the

PORVs

must

be

assured

except

for cases

of

excessive

PORV

seat

leakage.

At the exit interview the

licensee

was

informed that

the

inspectors

disagreed

with their

interpretation

of

TS 3.4.4.

Within the areas

inspected,

one unresolved

item was identified.

IE Bulletin Followup (92701)

(Closed)

50-400/85-BU-03,

TI 2515/73,

Motor Operated

Yal ve

Common

Mode

Failure During Plant Transients

Due to Improper Switch Settings.

The

purpose

of this Bulletin is to require

licensees

to develop

and

implement

a

program

to

ensure

that, switch settings

for high

pressure

coolant injection

and

emergency

feedwater

system

MOVs subject to testing

for operational

readiness

in accordance

with 10 CFR 50.55a(g)

are properly

set,

selected,

and maintained.

The licensee's

program

was previously discussed

in

NRC

Inspection

Report

50-400/88-10.

With the

exception

of addressing

MOV

operation

at

degraded

voltages

and re-testing

MOYs

under differential

pressure

following major maintenance,

all the findings discussed

in

NRC

Inspection

Report

50-400/88-10

were satisfactorily

completed.

However,

11

further review of the licensee's

program during this

inspection

'identified significant weaknesses

in the areas

of establishing

closed

limit switch 'ettings,

balancing

switches,

and

post

maintenance

testing.

NRC Inspection

Report

50-400/88-10

identifi'ed that operation

of

MOVs at

degraded

voltages

was

not addressed

in the

licensee's

responses

to

IE

Bulletin 85-03.

Licensee

correspondence

with Limitorque

Corporation

verified that IE Bulletin 85-03

MOVs were

sized for operation

at

reduced

voltages

of 80 percent

and

86 percent.

There

was

a conflict, in that,

Section 8.3. 1.2.3 of the

FSAR states

that the

EDGs voltage output wi 11 not

decrease

to less

than

75 percent of nominal during

sequencing

of loads.

Oper ation at degraded

voltages is still under evaluation

by the licensee.

Also discussed

in

NRC Inspection

Report

50-400/88-10

was

the

need

to

retest

MOVs at accident differential pressures

following major maintenance

in order to verify that adequate

thrust

was available.

Review of work

histories

for IE Bulletin 85-03 valves

indicated that the actuator

for

valve

CS-752

was

disassembled

and

reassembled

after it was differential

pressure

tested

to meet

requirements.

Following this

maintenance,

testing

was

not

performed

to

ensure

that,

the

actuator

developed

adequate

thrust to cycle against

accident differential pressure.

In order to assure operability, the inspectors

consider that it is prudent

to test

IE Bulle.',n

85-03 valves

following major maintenance

to verify

adequate

thrust

is

available.

Testing

at differential

pressure

or

diagnostic testing would accomplish this objective.

It was the licensee's

policy that only stroke timing, valve cycling,

and measuring

motor current

was required.

Additional

significant

weaknesses

noted

by

the

inspectors

include the following:

SHNPP

MOVs that operate

in response

to

a .containment isolation or SI

signal

have

the

thermal

overload;

switch,

and torque

switch

bypass

switches

bypassed.

Therefore,

the

open or closed limit switch

deenergizes

the actuator

motor following valve operation.

For the SI

mode of operation

the licensee

normally sets

the closed limit switch

to actuate

at 96 percent of full valve stroke.

The inspectors

were

concerned

that

96 percent of full valve stroke

may not be adequate

to

ensure

the valve is fully shut.

After the

motor

stops,

valve

and

actuator

momentum will continue

to drive the valve disk.

This is

referred to as "coastdown".

The amount of coastdown

is dependent

on

a

number

of factors

and

varies

from valve

to valve.

If, for

a

particular valve, little or no coastdown exists,

then the valve would

be four percent

open after the limi.t switch deenergizes

the motor.

In

some

instances

for the containment

isolation

mode of operation,

the

licensee

may

set

the

closed limit switch to actuate

at zero

percent

of valve

stroke.

The

inspectors

were

concerned

that

coastdown

may

overthrust

the

valve

and/or

actuator

by exerting

excessive

force

when

driving

the

valve

disk

into

the

seat.

Overthrusting

the

valve

or actuator

in this

manner

could

lead to

12

eventual

valve and/o'r actuator failure.

The concerns

involving valve

limit switch settings

not only include

IE Bulletin 85-03 valves,

but

al l

- SI

and

containment

i sol ation

valves

that

get

a

signal

to

automatically shut.

Procedure

CN-.1002,

Revision

3,

AC

Limitorque

Calibration

and

Stroking, provides instructions for replacing

switches.

This

procedure

did not require

SNB-000 torque switches to be checked for

balancing prior to ins.allation.

Balancing

a torque

switch involves

making adjustments

so that both the

open

and closed

switch contacts

open at

a given set.ing after the

same

amount of torque

switch

arm

travel.

An. unbalanced

switch

does

not

provide

a

true

correlation

between

the

selected

switch setting'nd

the

corresponding

actuator output.

SHNPP

does

not

perform diagnostic

testing.

Following packing

and

switch

maintenance

the

licensee

stroke

tests

the

NOV

and

measures

motor

current.

-Stroking

and

measuring

current

provides

useful

information regarding

valve. operability;

however,

diagnostic

testing

provides

a

significant

amount

of additional

information

regarding

valve operability.

Because

the licensee

does

not perform

diagnostic

testing

following packing

and torque

switch maintenance

the

inspect.ors

concluded

the

SHNPP

lags

behind

the

rest

of the

nuclear industry in this area.

These findings were discussed

with the licensee.

The licensee

stated that

problems currently exist with presert diagnostic test

systems

which needed

to be resolved prior to utilizing diagnostic test equipment.

The licensee

also stated that in order to satisfy Generic Letter 89-10, Safety-Related

Notor-Operated

Valve Testing

and Surveillance,

diagnostic testing would be

required,

and that after incorporation of GL 89-10 the inspector

concerns

raised during the inspection

would be resolved.

Action on Previous

Inspection

Findings (92701,

92702)

a.

(Closed)

URI 50-400/88-10-01,

Setpoint Test

Frequency of Pressurizer

Safety Valves

This item 'was discussed

in detai

1 in paragraph

6 of this Inspection

Report.

Since

one

PSV was tested

during

each of the

1988

and

1989

RFOs, all ANSI/ASME ON-1-1981 Test frequency requirements

were met.

b.

(Closed)

IFI 50-400/88-26-03,

Kerotest Valves Installed Backwards

on

Leakoff Lines for RC107

and

RC103.

This item involved inspector

concerns

for

a Kerotest

Y type globe

valve in the leak off collection

system for pressurizer

spray valve

RC-103.

The inspector

observed that the Kerotest valve was installed

in opposition

to

the

normal

direction

of

leak off flow.

The

0

~

13

inspector

was

concerned

that

the

Kerotest

valve

was

installed

improperly and with sufficient design flow above the seat,

the valve

'ould close

and cause

the collector shield to become part of the

RCS

pressure

boundary.

The

licensee

provided

the

inspector

a

copy

of design

drawing

2166-G-171

Rev.

5, Valve Stem Leakoff Piping

Containment Building

Unit 1.

The drawing included

a note "Leakoff inclined stem valves -to

be installed with flow above

seat."

The inspector

noted that this

required

the Kerotest

valves

to

be installed in opposition

to the

direction of normal

leakoff flow.

Although this demonstrated

that

the valves were installed

as designed, it still did not resolve

the

inspectors

concern regarding

the adequacy of the leak off design.

In order to address

the inspectors

concerns,

the licensee's

technical

support

group performed

several

tests

to determine

the flow required

to induce

valve closure with an identical valve connected

to

a test

setup with flow over the seat.

The test concluded that the Kerotest

valve would not exhibit flow induced closure until greater

than

18.6

gpm.

Shearon

Harris Technical Specification limit identified leal age

is

10

gpm which is less

than

the test

value

average

of 18.6

gpm.

Therefore,

the

TS value is the limiting value

of

maximum

leakage

allowed without entering

the

TS action statement.

The inspector

has

no other

concerns.

(Closed)

Inspector

Followup

Item

50-400/88-36-01,

Revision

of

Procedure

MPT-M0045 to Clarify Jacket.

Water

Heat

Exchanger

Divider

Plate Bolting Configuration

The

inspectors

reviewed

the revision of MPT-M0045,,which included

clarification for final positioning of jam nuts

on the outlet

head

flange

studs,

and

compression

of the

packed joint of the tubesheet

when

at

operating

temperatures'.

The

inspectors

consider

the

licensee's

actions to be satisfactory.

(Closed)

Inspector

Followup

Item

50-400/86-77-05,

Painting

of

Restricted

Embeds

The inspectors verified that Plant

Change

Requests

2879,

2880,

2881,

2882,

2883,

2884,

2910,

3533,

3564,

and

3565

had been

completed.

The

inspectors

,consider

the

licensee's

actions

for this

item to

be

satisfactory.

Within the areas

inspected,

no violations. or deviations

were identified.

10.

Exit Interview

The inspection

scope

and results

were

summarized

on December

8,

1989, with

those

persons

indicated

in

paragraph

1.

The

inspectors

described

the

areas

inspected

and

discussed

in detail

the

inspection

results

listed

above.

Proprietary

information

is

not

contained

in this

report.

14

Dissenting

comments

were

received

from the

li'censee

in the

areas

of

. fail-safe -esting

the

RHR heat exchanger

bypass

valves,

(RH-20 and

RH-58)

and

NRC identified

MOV weaknesses.

The licensee

stated that the

RHR heat

. exchanger

bypass

valves

were

not within the

scope of Section

XI testing,

and

as

such

IST was

not required.

With regard

to the identified

MOV

weaknesses,

the

licensee

commented

that

problems

and

inaccuracies

currently existed with present diagnostic testing

systems,

and until

such

problems

are

corrected,

only" limited usefulness

could

be

attained

in

identifying

MOV

problems.

In

addition,

the

licensee

stated

that

. implementation

of

GL 89-10

requirements

would resolve

the

MOV concerns

raised

during

the

inspection.

The

licensee

was

informed

that

their

interpretation

of

TS 3.4.4

did

not

agree

with

the

NRC position

on

operability of PORVs

when the automatic function is not available.

Item Number

Descri tion and Reference

50-400/89-35-01,

Part

A

Violation - Failure to Perform

IST on

Check

Valves

CS-775,

CS-776,

and

CS-525.

50-400/89-35-01,

Par

B

.50-400/89-35-01,

Part

C

Violation - Failure to Adequately

Perform