ML17348B427
| ML17348B427 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point |
| Issue date: | 02/20/1992 |
| From: | Butcher R, Landis K, Schnebli G, Trocine L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348B425 | List: |
| References | |
| 50-250-91-52, 50-251-91-52, NUDOCS 9203180153 | |
| Download: ML17348B427 (51) | |
See also: IR 05000250/1991052
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/91-52
and 50-251/91-52
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL
33102
Docket Nos.:
50-250
and 50-251
Facility Name:
Turkey Point Units
3 and
4
License Nos.:
and
Inspection
Conducted:
December
28,
1991, through January
24,
1992
Inspector
. C. Butcher, Senior Resident
Inspector
ned
. A. Schnebli,
Residen
Inspector
D te
ig ed
M. Trocine,
Resi
nt Inspector
Da
e
S gned
Approved
by:
K. D. Lan as,
hief
Reactor Projects
Section
2B
Division of Reactor Projects
Da
e Signed
SUMMARY
Scope:
This routine resident
inspector
inspection
entailed direct inspection at the
site in the areas
of monthly surveillance
observations,
monthly maintenance
observations,
operational
safety,
and plant events.
Results:
Within the
scope
of this
inspection,
the
inspectors
determined
that
the
licensee
continued to demonstrate
satisfactory
performance
to ensure
safe plant
operations.
One violation and
one weakness
were identified.
In addition, the
licensee,
through self assessment,
took prompt action to correct the following
non-cited violations:
50-250,251/91-52-01,
Non-Cited Violation.
Failure to follow the requirements
of Technical Specification 6.8.1 resulting in Unit
3 excore detector
cables
being disconnected
during
a startup
(paragraph
4).
9203180153
920220
ADOCK 05000250
8
50-250,251/91-52-02,
Non-Cited Violation.
Operation
without
a
procedure
~
~
~
describing
necessary
manual
action
to ensure
safe
shutdown
equipment
is
adequately
isolated
as required
by 10 CFR Part 50, Appendix
R (paragraph
5).
50-250,251/91-52-03,
Violation.
Failure to conduct
an
adequate
evolution
briefing resulting in the inadvertent
opening of a power operated relief valve
(paragraph 9.d).
Weakness
- Failure of an engineering
safety evaluation
to recognize
that
a
postulated
spurious
actuation of the
B train emergency
diesel
generator
output
breaker
would make it technically inoperable
per the
10 CFR Part 50, Appendix
R, design
basis
document
(paragraph
5).
REPORT
DETAILS
1.
Persons
Contacted
Licensee
Employees
T. V. Abbatiello, guality Assurance
Supervisor
L. W. Bladow, Site guality Manager
R. J. Gianfrencesco,
Support Services
Supervisor
S. T. Hale, Engineering
Manager
K. N. Harris, Senior Vice President - Nuclear Operations
E.
F. Hayes,
Instrumentation
and Controls Maintenance
Supervisor
R.
G. Heisterman,
Mechanical
Maintenance
Supervisor
D.
E. Jernigan,
Technical
Manager
H. H. Johnson,
Operations
Supervisor
V. A. Kaminskas,
Operations
Manager
J.
E. Knorr, Regulatory Compliance Analyst
J.
D. Lindsay, Health Physics
Supervisor
G. L. Marsh, Reactor Engineering Supervisor
L.
W. Pearce,
Plant General
Manager
M. 0. Pearce,
Electrical Maintenance
Supervisor
T. F. Plunkett, Site Vice President
D.
R. Powell, Services
Manager
R. N. Steinke,
Chemistry Supervisor
F.
R. Timmons, Security Supervisor
M. B. Wayland, Maintenance
Manager
J.
D. Webb,
Outage
Manager (acting)
E. J. Weinkam, Licensing Manager
Other
licensee
employees
contacted
included
construction
craftsman,
engineers,
technicians,
operators,
mechanics,
and electricians.
NRC Resident
Inspectors
- R.
C. Butcher, Senior Resident
Inspector
- G. A. Schnebli,
Resident
Inspector
- L. Trocine, Resident
Inspector
- Attended exit interview on January
24,
1992
Note:
An alphabetical
tabulation of acronyms
used in this report is
listed in the last paragraph
in this report.
2.
Plant Status
Unit 3
"
At the beginning of this reporting period, Unit 3 was operating at
lOOX
power
and
had
been
on line since
October
4,
1991.
The following
evolutions occurred
on this unit during this assessment
period:
On January 3, 1992, at 9:07 p.m., the Unit 3 main turbine
was
tripped,
and the uni t was taken off line for a pre-planned
short notice outage.
(Refer to paragraph
9.b for additional
information.)
On January 3, 1992, at 9:30 p.m., all control rods were inserted,
and Unit 3 entered
Mode 3.
On January 4,
1992, at 4:35 p.m., reactor startup
was
commenced.
On January
4, 1992, at 8:05 p.m., Unit 3 entered
Mode l.
On January 4,
1992, at 8:55 p.m., the turbine was put back
on
line.
On January
5, 1992, at 2:45 p.m., reactor
power reached
100K.
On January
8, 1992, at 10:15 p.m.
a planned
power reduction
was
comnenced
in order to perform flux mapping for an incore/excore
NIS calibration.
On January 8,
1992, at 10:58 p.m., reactor
power reached
85K.
On January 9,
1992, at ll:15 a.m.,
power ascension
was
commenced.
On January
9,
1992, at 12:48 p.m., reactor
power reached
100K.
On January
21,
1992, at 7:45 p.m.,
a power reduction to
95K was
commenced
as
a precaution to obtain
a greater
margin
during troubleshooting of the Channel III overpower
and
overtemperature
delta temperature
protection circuitry.
On January
21,
1992, at 8:10 p.m., Unit 3 reactor
power was
stable at 95%.
On January
23,
1992, at 12:00 a.m.,
power ascension
was
commenced.
On January
23,
1992, at 12:54 a.m., reactor
power reached
100K.
Unit 4
At the beginning of this reporting period, Unit 4 was operating at
100K
power
and
had
been
on line since
December
19,
1991.
The following
evolutions occurred
on this unit during this assessment
period:
On January
12, 1992, at 8:30 p.m.,
a planned
power reduction
was
commenced
in order to perform work on the
pump, the 4A waterboxes,
and the heater drain pumps.
(Refer to paragraph
9.c for additional information.)
On January
12, 1992, at 9:40 p.m., reactor
power reached
60K.
On January
14, 1992, at 5:32 p.m.,
power ascension
was
commenced.
On January
15,
1992, at 1:30 a.m., reactor
power reached
100K.
3.
Followup on Items of Noncompliance
(92702)
A review
was
conducted
of the following noncompliance
to assure
that
corrective actions
were adequately
implemented
and resulted
in conformance
with regulatory
requirements.
Verification of corrective
action
was
achieved
through
record
reviews,
observation,
and
discussions
with
licensee
personnel.
Licensee
correspondence
was evaluated
to ensure
the
responses
were timely and corrective actions
were implemented within the
time periods specified in the reply.
(Closed)
YIO 50-250,251/91-42-03,
Failure
to Maintain Axial Flux
Difference
Within TS Limits.
The licensee
responded
to this violation in
December
18,
1991.
The inspectors
reviewed
the licensee's
corrective
actions
discussed
in this letter
and found
them to
be adequate.
This
issue is closed.
Followup on Inspector
Followup Items
(92701)
Actions taken
by the licensee
on the item listed below was verified by the
inspectors.
(Closed)
URI 50-250,251/91-37-04,
Unit 3 Entry into
Mode
2 With
an
Intermediate
Range Detector.
This
event
occurred
on
September
25,
1991,
during
the dilution to
criticality on Unit 3.
IRNI channel
N-35 was declared
out of service
because it did not respond
to the increasing
neutron flux.
The operating
crew
commenced
3-ONOP-059. 7,
the
I RNI
malfunction
procedure,
and
determined
that
N-35
had failed.
The
then
ordered
the unit to be
shutdown
and
an
evaluation
of the failure to
be
performed prior to
recommencing
the startup.
Initial troubleshooting
identified that the
signal,
compensating,
and high voltage
cables
were disconnected
at the
back of the instrumentation
drawer.
At ERT was formed to analyze
the event.
The root cause
of the event
was personnel
error
by non-licensed utility
personnel
in that inadequate
control of the lifted leads
between
the N-35
drawer
and the detector
occurred.
The licensee
took prompt corrective
actions
to prevent
recurrence.
The cables for all other Unit 3 excore
detectors
were
checked to ensure
that
no other cables
were disconnected.
The maintenance
procedure
was revised to include lifted lead documentation
and
independent
verification.
Outstanding
PWOs involving mode-deferred
testing
were
reviewed to ensure
that similar concerns
for other systems
did not exist.
Maintenance
personnel
were trained
on the significance of
the event.
A policy letter
was
issued
requiring the
use of lifted lead
control procedures
for work involving lifted leads
when the leads
are not
specified
and
independently verified in
a procedure.
The licensee
also
reviewed its lifted lead controls
against
and
standard
industry
practices.
TS 6.8.1 requires that written procedures
be established,
implemented,
and maintained
covering activities
recomnended
in Appendix
A of Regulatory
Guide 1.33,
Revision 2,
February
1978.
Section 9.a of this
Appendix
recommends
that
maintenance
that
can
affect
the
performance
of
safety-related
equipment
be
properly
preplanned
and
performed
in
accordance
with written procedures,
documented
instructions,
or drawings
appropriate
to the circumstances.
The recommendations
stated
above
were
not followed in that maintenance
accomplished
on Unit 3 IRNI N-35 was not
properly
performed
causing
the detector
cables
to remain
disconnected.
This oversight
required
the unit to be shut
down while a startup
was in
progress
on September
25,
1991.
This violation is not being cited because
the criteria specified in Section
V.G.1 of the
satisfied.
This item will be tracked
as
NCV 50-250,251/91-52-01,
failure
to follow the requirements
of TS 6.8.1 resulting in N-35 excore detector
cables
being disconnected
during
a Unit 3 startup.
5.
Onsite
Followup
and In-Office Review of Written Reports of Nonroutine
Events
and
10 CFR Part 21 Reviews
(90712/90713/92700)
The Licensee
Event Reports
and/or
10 CFR Part 21 Reports
discussed
below
were reviewed.
The inspectors
verified that reporting requirements
had
been
met, root cause
analysis
was performed, corrective actions
appeared
appropriate,
and generic applicability had
been considered.
Additionally,
the inspectors
verified the licensee
had reviewed
each event, corrective
actions
were
implemented,
responsibility for corrective actions not fully
completed
was clearly assigned,
safety questions
had
been
evaluated
and
resolved,
and
violations of regulations
or
TS conditions
had
been
identified.
When applicable,
the criteria of 10 CFR Part 2, Appendix C,
were applied.
(Closed)
LER 50-250/91-011,
Appendix R,
Safe
Shutdown
Analysis Design Inadequacy.
On
October ll, 1991,
at
7:00 a.m.,
the
licensee
identified
a
10 CFR Part 50, Appendix R, safe
shutdown analysis
design
inadequacy.
Unit 3 was
in
Node
1 at
45% reactor
power,
and Unit 4
was in Mode 6.
Unit 3
had
started
up from the dual unit outage
on September
26,
1991.
The
NCR that
identified
the
potential
design
inadequacy
provided
two potential
corrective actions,
both procedural,
which were
implemented
immediately.
Procedure
0-ONOP-105
was revised
on October ll, 1991, to manually
remove
two fuses
to prevent
the postulated
spurious actuation of the
B train
output
breaker.
A change
request
notice
was
issued
to correct
the
Appendix
R safe
shutdown analysis
manual
action list and
was
approved
on
October 11,
1991.
The licensee
took prompt
and appropriate
corrective
action.
However, the engineering disposition of the
NCR stated that there
was
no plant operability concern resulting
from the
NCR,
and therefore,
this
condition
was
not
immediately
reported.
Subsequently,
on
November 23,
1991,
the licensee
determined
the condition
was reportable
under
and
The
inspectors
consider
the failure of the engineering
safety evaluation
to recognize
that the postulated
spurious
actuation of the
B train
EDG output breaker
would
make it technically inoperable
per the
Appendix
R design
basis
document
as
a weakness
in the safety evaluation
program.
10 CFR Part 50, Appendix
R,
paragraph III.L.3, states
in part that the
alternative
shutdown capability shall
be independent of the specific fire
area(s)
and shall
accommodate
post fire conditions
where offsite power is
available
and
where offsite
power
is
not available for
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Procedures
shall
be in effect to implement this capability.
Paragraph
III.L.7 also states
in part that the safe
shutdown
equipment
and systems
for each fire
area
shall
be
known to
be
isolated
from associated
non-safety circuits in the fire area
so that hot shorts,
open circuits, or
shorts
to ground in the associated
circuits will not prevent operation of
the safe
shutdown
equipment.
No exceptions
to the noted
paragraphs
were
approved
by the
NRC.
As stated
in the
FSAR,
Appendix 9.6A,
paragraph
5.2.1,
Safety
Design
Basis, fire induced
spurious
actuation of systems
and
components
due to
open circuit, or short to ground shall
be
assumed
to render
equipment
unusable
or place it in
an undesirable
mode.
Unit 3 went
critical
on September
26,
1991,
and operated until October
11,
1991, at
which
time
the
licensee
revised
procedure
0-ONOP-105
to require
the
necessary
manual
actions
to prevent
the spurious
actuation of the
3B or
4B
EDG output breakers.
Operation
of Unit 3 without procedures
describing
the necessary
manual
actions
to
ensure
safe
shutdown
equipment
was
adequately
isolated
to
prevent inadvertent
operation
due to hot shorts,
open circuits,
or shorts
to ground is
a violation of 10 CFR Part 50, Appendix
R.
This violation is
not being cited because
the criteria specified in Section
V.G. 1 of the
NRC
Enforcement
Policy were satisfied.
This
item will
be
tracked
as
NCV 50-250,251/91-52-02,
operation
without
a
procedure
describing
necessary
manual
action to ensure
safe
shutdown
equipment is adequately
isolated
as required
by 10 CFR Part 50, Appendix
R.
This item is closed.
Monthly Surveillance Observations
(61726)
The inspectors
observed
TS required surveillance testing
and verified that
the test
procedures
conformed to the requirements
of the TSs; testing
was
performed in accordance
with adequate
procedures;
test instrumentation
was
calibrated;
limiting conditions for operation
were met; test results
met
acceptance
criteria requirements
and were reviewed
by personnel
other than
the
individual directing
the test;
deficiencies
were identified,
as
appropriate,
and
were
properly
reviewed
and
resolved
by
management
personnel;
and system restoration
was adequate.
For completed tests,
the
inspectors
verified testing frequencies
were met and tests
were performed
by qualified individuals.
The
inspectors
witnessed/reviewed
portions
of
the
following test
activities:
3-0SP-049.1,
Reactor Protection
System Logic Test;
O-OSP-024.2,
Emergency
Bus
Load
Sequencers
Manual Test, for the
3A
sequencer;
and
3-0SP-075.3,
Low Pressure
Alarm Setpoint
Verification.
The inspectors
determined that the above testing activities were performed
in a satisfactory
manner
and met the requirements
of the TSs.
Violations
or deviations
were not identified.
7.
Honthly Maintenance
Observations
(62703)
Station
maintenance
activities of safety-related
systems
and
components
were observed
and reviewed to ascertain
they were conducted
in accordance
with approved
procedures,
regulatory guides,
industry codes
and standards,
and in conformance with the TSs.
The following items
were considered
during this review,
as appropriate:
LCOs were
met while components
or systems
were
removed
from service;
approvals
were
obtained
prior to initiating work; activities
were
accomplished
using
approved
procedures
and were inspected
as applicable;
procedures
used
were
adequate
to control
the activity; troubleshooting
activities
were controlled
and repair records
accurately
reflected
the
maintenance
performed;
functional
testing
and/or
calibrations
were
performed prior to returning
components
or systems
to service;
gC records
were maintained;
activities
were
accomplished
by qualified personnel;
parts
and materials
used
were properly certified; radiological controls
were properly implemented;
gC hold points
were established
and observed
where
required;
fire prevention
controls
were
implemented;
outside
contractor
force activities
were
controlled
in
accordance
with the
approved
gA program;
and housekeeping
was actively pursued.
The inspectors
witnessed/reviewed
portions of the following maintenance
activities in progress:
repair of a base
plate leak on the
4B heater drain
pump,
weld r epair of a leaking manway
on the
4A north waterbox,
and
repair of one of two flow control valves supplying seal
water to the
pump's shaft seals
(CV-2209).
For those
maintenance
activities observed,
the inspectors
determined that
the activities were conducted
in
a satisfactory
manner
and that the work
was
properly
performed
in accordance
with approved
maintenance
work
orders.
Violations or deviations
were not identified.
8.
Operational
Safety Verification (71707)
The inspectors
observed control
room operations,
reviewed applicable logs,
conducted
discussions
with control
room
operators,
observed
shift
turnovers,
and monitored instrumentation.
The inspectors verified proper
valve/switch alignment of selected
emergency
systems,
verified maintenance
work orders
had
been
submitted
as required,
and verified followup and
prioritization of work was accomplished.
The inspectors
reviewed tagout
records,
verified compliance
with
TS
LCOs,
and verified the return to
service of affected
components.
By observation
and direct interviews, verification was
made that the
physical
security
plan
was
being
implemented.
The
implementation
of
radiological
controls
and plant housekeeping/cleanliness
conditions
were
also observed.
Tours of the intake structure
and diesel, auxiliary, control,
and turbine
buildings
were
conducted
to observe plant equipment conditions including
potential fire hazards, fluid leaks,
and excessive vibrations.
The
inspectors
walked
down
accessible
portions
of the
following
safety-related
systems/structures
to verify proper valve/switch alignment:
A and
B emergency
diesel generators,
control
room vertical panels
and safeguards
racks,
intake cooling water structure,
4160-volt buses
and 480-volt load and motor control centers,
Unit 3 and
4 feedwater platforms,
Unit 3 and
4 condensate
storage
tank area,
auxiliary feedwater area,
Unit 3 and 4 main steam platforms,
and
auxiliary building.
The licensee
routinely performs
QA/QC audits/surveillances
of activities
required
under its
QA program
and
as
requested
by management.
To assess
the effectiveness
of these
licensee
audits,
the inspectors
examined
the
status,
scope,
and findings of the following audit reports:
Audit Number
QAO-PTN-91-061
QAO-PTN-91-063
QAO-PTN-91-070
QAO-PTN-91-072
QAO-PTN-91-077
QAO-PTN-91-078
Number of
~Findin
s
T
e of Audit
Multi-Amp Services
Material
and Services
Control
Programs
Engineering
Planning
and
Management,
Inc.
TS 6.5.2.8(c), Corrective Action
November Performance
Monitoring
Audit
TSs 6.6, 6.9, 6.13.2, 6.14.2,
and
6.15 Reports
No additional
NRC followup actions will
be
taken
on
the
findings
referenced
above
because
they were identified by the licensee's
QA program
audits
and corrective actions
have either
been
completed or are currently
underway.
Plant management
has also
been
made
aware of these
issues.
As
a result of routine plant tours
and various operational
observations,
the
inspectors
determined
that the
general
plant
and
system material
conditions
were satisfactorily maintained,
the plant security program
was
effective,
and
the overall
performance
of plant operations
was
good.
Violations or deviations
were not identified.
9.
Plant Events
(93702)
The following plant events
were reviewed to determine facility status
and
the
need for further followup action.
Plant
parameters
were evaluated
during transient
response.
The significance of the event
was evaluated
along with the
performance
of the appropriate
safety
systems
and
the
actions
taken
by the licensee.
The inspectors
verified that required
notifications were
made to the
NRC.
Evaluations
were performed relative
to the
need for additional
NRC response
to the event.
Additionally, the
following issues
were
examined,
as appropriate:
details
regarding
the
cause
of the event;
event chronology; safety
system performance;
licensee
compliance
with approved
procedures;
radiological
consequences, if any;
and proposed corrective actions.
a 0
b'.
As stated
in
NRC Inspecti'on
Report
No. 50-250,251/91-50,
all five
blackstart
diesel
generators
were taken out of service at 9:00 p.m.
on December
25, 1991, in order to facilitate repairs to the roof over
the cranking diesel
switchgear
enclosure.
Following completion of
these
planned
repairs,
the
No. 1,
3,
and
5 blackstart
diesel
generators
were
tested
and
returned
to service
at
9:05 a.m.
on
December
31,
1991,
and
the
No.
2 blackstart
diesel
generator
was
returned
to service
at
12:40 p.m.
on
the
same
day.
The
No.
4
blackstart
diesel
generator
was returned
to service at 2:06 p.m.
on
January
5, 1992.
On January
3, 1992, at 9:30 p.m., Unit 3 was shut
down for a short
outage
due to
a low oil level alarm
on the
38 RCP.
On December
13,
1991,
at
12: 10 p.m.,
82/5,
38 Oil Reservoir
Hi/Lo
Level,
came in.
The licensee's
investigation
showed that the signal
indicated
low oil level in the
38
RCP lower bearing oil reservoir.
The oil collection tank inside containment
was not showing
a level
increase,
and the licensee
monitored the
38
RCP bearing temperatures
which were steady.
The licensee
decided
to shut
down on January
3,
1992,
to determine
the exact status
of the oil reservoir
on the
38
RCP and to perform other selected
corrective maintenance
items.
An
oil film was
found
on the lower part of the
38
RCP motor,
and the
bolts
were re-torqued
to 65 + 5 ft.-lbs.
Approximately two
quarts of oil were
added to the reservoir.
Visual inspection of the
3A
and
3C
RCP did not indicate
any oil leakage.
Some
other
maintenance/repair
items accomplished
were as follows:
control oil piping unions to the
NE,
NW, SE,
and
intercept valves
were tightened;
various packing
and fitting leaks
were repaired;
three
ARNs were updated
per PC/N 91-167;
internal
pipe supports
to the control oil piping were added
to the intercept valves to reduce vibration; and
work was performed
on the
3A heater drain pump.
Unit 3 went critical again at 5: 17 p.m.,
on January 4, 1992,
and was
put back
on line at 8:55 p.m.
on the
same
day.
Unit 3 reached
100%
reactor
power at 2:45 p.m.
on January
5,
1992.
c.
At 8:30 p.m.
on January
12, 1991, the licensee
reduced
load
on Unit 4
for planned repairs.
Reactor
power reached
60K at 9:40 p.m.
on the
same
day,
and the following major work items were performed:
weld repair of a leaking manway
on the
4A north water box,
furmanite repair of
a casing
leak
on the
4B steam
generator
pump,
mechanical
maintenance
on
CV-2209
(one of two flow control
valves
supplying seal
water to the
pump's shaft seals),
calibration of valve positioner
H/A-2208 for CV-2208 (the
second of two flow control valves supplying seal
water to the
4B
pump's shaft seals),
repair of
a
base
plate leak
on the
4B heater
drain
pump
and
removal of the
pump motor for mechanical
maintenance,
and
repair of the top hat weld
and
a union leak
on the
4A heater
drain
pump.
Power
ascension
was
commenced
at
5:32 p.m.
on
January
14, 1992,
following completion of the
planned
secondary
work items.
Reactor
power reached
100% again at 1:30 a.m.
on the following day.
d.
At 1:37 a.m.
on January
14, 1992, with Unit 3 at
100K reactor
power,
PORV PCV-3-455C
was
inadvertently
cycled
due to excessive
demand
on controller PC-3-444J
during the investigation of a possible
malfunction of the pressurizer
control
group heaters.
In order to
determine if
the
pressurizer
control
group
heaters
were
malfunctioning,
the
control
group
heaters
were to
be
exercised
through their full range,
and
heater
output
response
was to
be
observed
as indicated
by the heater
watt meter.
This was
done
by,
placing
the
pressurizer
pressure
control
system's
auto/manual
setpoint
station
(PC-3-444J)
in
manual
and,
after
placing
the
pressurizer
spray controllers in manual
to prevent their operation in
response
to
a high pressure
response
from PC-3-444J,
by increasing
the output
on
PC-3-444J
to drive the control
group pressurizer
10
heaters
from maximum to minimum output.
During performance
of this
action,
the output of PC-3-444J
was
increased
too far,
and
PCV-3-455C
cycled
open
due
to excessive
demand
and/or
rate of
increase.
RCS pressure
was immediately verified to be less
than the
PORV liftsetpoint,
the
PORV was manually closed within approximately
20 seconds,
and
RCS pressure
was stabilized.
RCS pressure
decreased
to approximately
2172 psig
and
was
below 2210 psig (the setpoint for
the
backup
heaters)
for approximately
3 minutes.
The
licensee
attributed this event to personnel
error and considered
an inadequate
job briefing to be
a contributing factor.
TS 6.8.1 requires that written procedures
and administrative policies
be established,
implemented,
and maintained
in accordance
with the
requirements
and
recommendations
of Appendix A of
Regulatory
Guide 1.33,
Revision
2,
dated
February
1978.
Appendix
A of this
Regulatory
Guide
recommends
that written procedures
be established
for typical
safety-related
activities
carried
out
during
the
operation
of nuclear
power plants.
Section
1.b of this Appendix
recommends
administrative
procedures
which include authorities
and
responsibilities for safe operation
and shutdown.
Paragraph
5.6.16.1
of
procedure
O-ADM-200,
Conduct
of Operations,
requires
that
evolution briefings
be
conducted
for individuals
involved in
an
evolution that is to be performed
and that the detail of the briefing
is dependent
on the
degree
and complexity of the evolution and the
number of individuals involved.
The failure to conduct
an adequate
evolution
briefing prior to
the
investigation
of
a
possible
malfunction of the
Unit 3 pressurizer
control
group
heaters
per
paragraph
5.6.16.1
of procedure
O-ADM-200, Conduct of Operations,
which resulted
in the
inadvertent
opening
of
PCV-3-455C,
constitutes
a violation of TS 6.8. 1.
This item will be tracked
as
VIO 50-250,251/91-52-03,
failure to conduct
an
adequate
evolution
briefing resulting in the inadvertent
opening of a
PORV.
At ll:40 p.m.
on January
15, 1992,
the licensee
received
a low
pressure
alarm
on the Unit 3
and the
A NSIV
was declared
out of service
per
The
A nitrogen bottle
was
replaced,
and
the
24-hour
action
statement
was
exited
at
2:05 a.m.
on January
16,
1992.
During
a subsequent
verification of
system line up,
the
licensee
identified that the pressure
on the
Unit 3
B
and
C
NSIV nitrogen
backup
bottles
was
less
than
the
acceptance
criteria.
As
a result of this low nitrogen pressure,
the
licensee
declared
both
the
B
and
C
MSIVs out of service
per
and entered
TS 3.0.3 at 5:25 a.m.
At 5:35 a.m.,
when one
of the nitrogen
backup bottles
was replaced with a spare
and nitrogen
pressure
was verified to be within acceptable limits; the
B NSIV was
declared
back
in service,
and
was exited.
Following
replacement
of the
second
low pressure
bottle with
a spare,
the
C NSIV was declared
back in service,
and
TS 3.7. 1.5
was exited at
5:40 a.m.
The
decrease
in nitrogen
pressure
was attributed to
a
significant decrease
in temperature
while
a cold front was passing
through.
11
f.
At 2:30 a.m.
on January
23,
1992,
the inservice blackstart
diesel
generators
(No.
1, 3,
and 5) were declared
out of service
due to
a
blown
30A fuse in the blackstart
diesel
generator
common starting
circuitry.
The
No.
2
and
4 blackstart
diesel
generators
had
previously been
taken out of service for other reasons.
The fuse
was
replaced
and
the
No. 1, 3, and
5 blackstart
diesel
generators
were
tested
and returned to service at 10:55 a.m.
on the
same
day.
One violation was identified.
10.
Exit Interview (30703)
The
inspection
scope
and
findings
were
summarized
during
management
interviews
held throughout
the reporting period with the Plant
General
Manager
and selected
members of his staff.
An exit meeting
was conducted
on January
24,
1992.
The
areas
requiring
management
attention
were
reviewed.
The
licensee
did not identify as proprietary
any of the
materials
provided
to
or
reviewed
by
the
inspectors
during this
inspection.
Dissenting
comments
were not received
from the licensee.
The
inspectors
had the following findings:
Item Number
Descri tion and Reference
50-250,251/91-52-01
50-250,251/91-52-02
50-250,251/91-52-03
Weakness
NCV - Failure to follow the
requirements
of TS 6.8. 1 resulting
in N-35 excore detector
cables
being
disconnected
during
a Unit 3 startup
(paragraph
4).
NCV - Operation without a procedure
describing
necessary
manual
action
to ensure
safe
shutdown
equipment is
adequately
isolated
as required
by
10 CFR Part 50, Appendix
R
(paragraph
5).
VIO - Failure to conduct
an adequate
evolution briefing res ul ting in the
inadvertent
opening of a
(paragraph
9.d).
Failure of an engineering
safety
evaluation to recognize that
a
postulated
spurious actuation of the
B train
EDG output breaker
would
make it technically inoperable
per
the
design .basis
document
(paragraph
5).
12
ADM
CFR
CV
ERT
H/A
IRNI
LCO
LER
NI S
NE
NRC
NW
ONOP
PC
PC/M
psl9
PTN
PWO
QAO
TS
and Abbreviations
Administrative
Area Radiation Monitor
Code of Federal
Regulations
Control Valve
Emergency Diesel
Generator
Event Response
Team
Florida Power
5 Light
Final Safety Analysis Report
Hand/Automatic
Institute for Nuclear Power Operations
Intermediate
Range Nuclear Instrumentation
Limiting Condition for Operation
Licensee
Event Report
Nuclear
Instrumentation
System
Non-conformance
Report
Northeast
Non-Cited Violation
Nuclear Plant Supervisor
Nuclear Regulatory Commission
Northwest
Off Normal Operating
Procedure
Operations
Surveillance
Procedure
Pressure
Controller
Plant Change/Modification
Pressure
Control Valve
Power Operated Relief Valve
pounds
per square
inch gauge
Plant Turkey Nuclear
Plant Work Order
Quality Assurance
Quality Assurance
Organization
Quality Control
Reactor
Coolant
Pump
Reactor
Coolant System
Southeast
Southwest
Technical Specification
Unresolved
Item
Violation
0
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
April 9,
1991
Docket Nos:
50-250
and 50-251
Nr. J.
H. Goldberg
President - Nuclear Division
Florida Power and Light Company
P.O.
Box 14000
Juno Beach, Florida
33408-0420
Dear Nr. Goldberg:
SUBJECT:
TURKEY POINT DESIGN VALIDATION INSPECTION
FOLLOWUP (50-.250/91-201;
50-251/91-201)
e
This letter conveys
the results
and conclusions of the followup to the design
validation inspection of the Turkey Point Nuclear Power Plant, Units
3 and 4.
The original inspection
was conducted
by the U.S. Nuclear Regulatory
Commis-
sion in October
1989
as
documented
by Inspection
Report 50-250
and 251/89-203.
The followup inspection
was performed at the Florida Power
and Light (FPL)
Company's offices at Juno
Beach, Florida, during the week of February 25, 1991.
The inspection report is enclosed.
The purpose of this inspection
was to assess
the status of corrective actions
for eight deficiencies
from the
1989 inspection.
All other deficiencies
and
inspector followup items were addressed
by other
NRC inspections,
as indicated
in Sections
1.0 and 2.0 of the enclosed
report.
The team closed
seven of the eight deficiencies.
Deficiency 89-203-12,
which
concerned
the adequacy
of the component cooling water
(CCW) heat exchanger
support pedestal,
remains
open.
The calculation prepared to resolve this
deficiency did not use the most current
loads to check the adequacy
of the
pedestal
even though the
new loads were about twice the magnitude of the
original loads.
Deficiency 89-203-16
was closed
based
on the team's
under-
standing that
FPL will install the Unit 4 portion of a modification package to
strengthen
the
CCW surge tank supporting platform to meet Bulletin 79-02 program
commitments.
The team designated
Deficiencies 89-203-12
and 89-203-16
as items
which should
be resolved prior to the restart of the units.
t
The team found that, irI response
to Deficiency 89-203-20,
FPL had extended
the
Design Basis Documentation verification effort to the component level.
The team
found that good initial progress
had been
made regarding the component
design
requirements
package for the safety injection system.
April 9,
1991
- 2-
There were
a substantial
number of errors present
in the calculations
reviewed.
While your staff and contractors
were able to correct these errors during the
inspection to the team's satisfaction,
the team was concerned with the quality
of contractor work products
and your lack of review of these
products.
During
the previous inspection,
oversight of contracted
engineering
was also identified
as
a weakness.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosure will
be placed in the Public Document
Room.
Should you have
any questions
concerning this inspection,
please
contact
me or
Mr. Hai-Boh Wang at (301) 492-0958.
ORIGINAL SIGNED BY STEVEN A. VARGA
Steven
A. Varga, Director
Division of Reactor Projects I/II
Office of Nuclear Reactor Regulation
Enclosure:
t<RC Inspection Report 50-250/91-201;
50-251/91-201
cc:
See
page
3
Distribution:
See
page
4
- See previous
concurrence
RSIB:DRIS
SC:RSIB:DRIS
AC:RSIB:DRIS
D:DRIS
HWang:sf
DPNorkin
EVImbro
BKGrimes
04/03/91
04/05/91
04/03/91
04/05/91
0:
SAVar a
'4/
q /91
~
I
Mr. J.
H. Goldberg
Florida Power and Light Company
3
Turkey Point Plant
Harold F. Reis, Esquire
Newman and Holtzinger, P.C.
1615
L Street,
N.W.
20036
Mr. Jack Shreve
Office of the Public Counsel
Room 4, Holland Building
Tallahassee,
32304
John T. Butler, Esquire
Steel,
Hector and Davis
4000 Southeast
Financial
Center
Miami, Florida
33131-2398
Mr. Thomas
F. Plunkett, Site
Vice President
.Turkey Point Nuclear Plant
Florida Power and Light Company
P.O.
Box 029100
Miami, Florida
33102
Joaquin Avino
County Manager of Metropolitan
Dade County
Ill NW 1st Street,
29th Floor
Miami, Florida
33128
Senior Resident
Inspector
Turkey Point Nuclear Generating Station
U.S. Nuclear Regulatory
Commission
Post Office Box 1448
Homestead,
33090
Intergovernmental
Coordination
and Review
Office of Planning
5 Budget
Executive Office of the Governor
The Capitol Building
Tallahassee,
32301
Administrator
Department of Environmental
Regulation
Power Plant Siting Section
State of Florida
2600 Blair Stone
Road
Tallahassee,
32301
Regional Administrator, Region II
U.S. Nuclear Regulatory
Commission
101 Marietta Street,
N.W. Suite 2900
Atlanta, Georgia
30323
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee,
32304
Plant Manager
Turkey Point Nuclear Plant
Florida Power
and Light Company
P.O.
Box 029100
Miami, Florida
33102
Mr. J.
H. Goldberg
President - Nuclear Division
Florida Power and Light Company
P.O.
Box 14000
Juno
Beach, Florida
33408-0420
Mr. Jacob
Daniel
Nash
Office of Radiation Control
Department of Health and
Rehabilitative
Services
1317 Winewood Blvd.
Tallahassee,
32399-0700
Distribution:
- III-
RSIB R/F
DRIS R/F
TEMurley,
FJMiraglia,
WTRussell,
JGPartlow,
BKGrimes,
EVImbro,
DPNorkin,
HBWang,
RLSpessard,
SAVarga,
HNBerkow,
RAuluck,
DAMilier,
LAReyes, RII
FJape,
RII
'WHMi 1 ler, RI I
RCButcher,
SRI Turkey Point
e
Regional Administrators
Regional Division Directors
Inspection
Team
LPDR
ACRS (3)
OGC (3)
1S Distribution
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE
OF NUCLEAR REACTOR REGULATION
Division of Reactor Inspection
and Safeguards
NRC Inspection Report:
50-250/91-201
50-251/91-201
License No.:
DPR-41
Docket Nos.:
50-250
50-251
Licensee:
Florida Power and Light Company
Facility Name:
Turkey Point Nuclear Power Plant, Units 3 and 4
Inspection
Conducted:
February
25 through Harch 1,
1991
Inspection
Team:
Hai-Boh Wang,
Team Leader,
A. V. duBouchet,
Consultant
Prepared
by:
)ai-Bo
Wang,
e
m Lea er
Team Inspection
Development Section
A
Special
Inspection
Branch
ivision of Reactor Inspection
and Safeguards
fice of Nuclear Reactor Regulation
ate
Reviewed by:
Approved by:
ona
.
aor
>n,
le
Team Inspection
Development Section
A
Special
Inspection
Branch
Division of Reactor Inspection
and Safeguards
Office of Nuclear Reactor Regulation
ugene
.
m ro,
ctsng
se
Special
Inspection
Branch
Division of Reactor Inspection
and Safeguards
Office of Nuclear Reactor Regulation
a
e
ate
EXECUTIVE SUYilNRY
Inspection Report 50-250/91-201;
50-251/91-201
Florida Power and Light Company
Turkey Point Nuclear Power Plant,
Units'
and
4
The U.S. Nuclear Regulatory
Commission
conducted
a Design Validation Inspection
in October
1989 to assess
the effectiveness
of the Turkey Point Performance
Enhancement
Program
on configuration control.
The inspection
was documented
in
NRC Inspection
Report 50-250
and 50-251/89-203.
During the week of February 25,
1991,
a Design Validation Inspection followup was conducted at the licensee's
nuclear engineering offices at Juno Beach, Florida.
The 1989 inspection
had
identified 14 deficiencies
and
9 inspector followup items.
Six of the
deficiencies
and all of the followup items have
been
closed in other
NRC
inspections.
This inspection
closed
seven of the remaining eight deficiercies.
Deficiency 89-203-12
remained
open
due to the fact that the calculation gener-
ated to resolve this deficiency
was itself deficient.
The calculation
computed
new loads but did not use these
loads to check the adequacy of the supporting
concrete
pedestal
of the component cooling water
(CCW) heat exchanger,
even
'though the
new loads
appeared
to be about twice the magnitude of the original
loads.
The team requested
that the licensee
resolve this item prior to restart.
~
~
~
~
~
~
~
~
~
~
~
~
S
Deficiency 89-203-16
concerned
the seismic qualification of the
CCW pump, surge
tank,
and their an'chorages.
The licensee
was
implementing modification packages
to strengthen
the anchorages.
Since the Unit 4 surge tank supporting platform
needed
the modification to meet Bulletin 79-02 program commitments,
the licensee
stated that the Unit 4 portion of the modification would be completed prior to
restart.
This item was closed
by the team based
on that understanding.
The original inspection
had identified problems in the quality of contractor
work products
and the licensee's
lack of rev-iew of these
products.
The
licensee
presented
to the followup team a.program to correct these
problems.
However, the team questioned
the effectiveness
of this program in light of the
number of errors found in the contracted
engineering
products
r'eviewed during
this inspection.
The team determined that the licensee's
component
design
requirement verifi-
cation program had
made
good initial progress.
Although the verification was
only partially completed, it appeared
that this program,
when completely
implemented,
would make
a positive contribution'o the design basis
documen-
tation reconstitution
program.
lr
TABLE OF CONTENTS
~Pa
e
EXECUTIVE SUMMARY......................................
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ i ~ ~ ~ ~ ~ ~ o 1
1.0 INTRODUCTION.........................................................1
2.0
INSPECTION DETAILS...................................................1
3.0
MANAGEMENT EXIT MEETING..............................................8
4.0
PERSONNEL CONTACTED.................
~ ........
~ .......................8
1.0
INTRODUCTION
The U.S. Nuclear Regulatory
Commission
(NRC) performed
a design validation
inspection
(DVI) of the Turkey Point Nuclear Plant to assess
the actions that
the Florida Power and Light Company
(FPL, the licensee)
had taken in the
Performance.
Enhancement
Program
(PEP)
on configuration control.
The
NRC staff
performed the
DYI using the safety
system functional inspection
methodology
on
three plant systems
(NRC Inspection
Report (IR) 50-250
and 50-251/89-203)
and
identified 14 deficiencies
in the design
and operation of the three
systems
and
9 inspector followup (IFU) items
on the
PEP program.
dated October 9, 1990, to
NRC provided the status
of the corrective actions for
those deficiencies
and IFUs.
The nine inspector followup items involving the
PEP program were closed
by Region II.
The purpose of this followup inspection
was to assess
the status of FPL's corrective actions
and to close out the
previously identified deficiencies
as appropriate.
The team closed out all deficiencies
but one.
The team requested
that this item
be resolved before restart.
2.0
INSPECTION DETAILS
The
14 deficiencies
on the design
and operational
aspects
of the three
systems
Were resolved
in several
inspection reports.
Deficiencies 89-203-14,
89-203-15,
and 89-203-18
were reissued
as violations
and subsequently
were closed
by
NRC
Inspection
Reports
50-250
and 50-251/90-19
and 91-07.
Deficiencies
89-203-21,89-203.-22,
and 89-203-23 were reviewed
and closed
by Inspection
Report 50-250
and 50-251/91-03.
The status of the remaining eight deficiencies is discussed
below.
(Closed) - Deficienc
89-203-10:
CCW Heat Exchan er Fundamental
Fre uenc
FPL's purchase
order for the
CCW replacement
heat
exchangers
specified that the
replacement
heat exchangers
be qualified by the response
spectrum
approach for
the safe
shutdown earthquake
(SSE)
as specified in Appendix
C of the purchase
order.
The
SSE spectrum in the purchase
order specified
a maximum value of
1.0
g and
a zero period acceleration
(ZPA) value of 0.4 g.
These g-values
were
more conservative
than the maximum value of 0.5
g and
ZPA value of 0.15
g as
specified for the one-percent
damped
SSE ground response
spectrum in Figure
5A-I of the
FSAR.
Bechtel Calculation C-SJ-183-02,
CCM Heat Exchanger
Support
Pedestal
Load Evaluation,
included
an evaluation of the heat exchanger
funda-
mental frequency which was
computed to be greater
than
33
Hz and concluded that
the heat
exchangers
were rigid.
Therefore,
the calculation
used the
ZPA values
of the
SSE spectrum to generate
the seismically
induced reaction
loads of the
heat exchangers.
Subsequently,
Target Technology
used the
ZPA loads together
with other loads to qualify the heat exchanger shell,
as indicated in Stress
Report "Stress Analysis of
CCW Heat Exchanger
Replacement/Turkey
Point, Unit 4,"
Revision 2, October 4, 1988.
However, the Bechtel calculation failed to
consider the transverse flexibility of the concrete
pedestals
supporting the
heat exchangers.
If the flexibilityof the supporting
concrete
pedestals
was
considered
in the analysis,
the seismic
loads required to qualify the heat
exchanger shell might increase;
therefore, Target's
stress
report might not
adequately
qualify the replacement
heat exchangers.
0
1t
In its response,
the licensee
indicated that the heat exchanger
pedestal
supports
were determined to be flexible with fundamental
frequency of approxi-
mately
5
Hz in the longitudinal axis and concluded that the qualification of
the replacement
heat
exchangers
had to be reviewed
and revised.
The heat
exchanger qualification was reviewed in order to determine
the effect of the
new nozzle
loads
and the pedestal flexibility.
The licensee
found that the
nozzle
loadings did not adversely affect the qualification of the exchanger.
Upon further review of the seismic input provided in the specification to the
heat exchanger
vendor, it was found that the response
spectrum
used
was
a
conservatively amplified enveloping
response
spectrum
curve.
The
ZPA for the
enveloping spectra
provided in the purchase
specification
was greater
than the
acceleration
corresponding
to
5 Hz on the ground response
spectra,
which
corresponded
to the base of i,he support pedestals
(0.4
g versus
0.37
g respect-
ively).
Accordingly, the seismic loading
on the heat exchangers
would be
reduced,
even
when the pedestal flexibilitywas considered.
Target Technolo-
gies provided
FPL 'with a revised final stress
report that considered
the effects
of the correct pedestal flexibility, the
new nozzle loads,
and the ground
response
spectra that correspond
to the heat exchanger
location.
The licensee
incorporated this report into the heat exchanger
replacement
engineering
docu-
mentation
package.
The followup team reviewed Bechtel's
revised Calculation C-SJ183-12
"CCW Heat
Exchanger
Pedestal
Stiffness Analysis," Revision 2, January
27, 1990, which
documented
a fundamental
frequency of 5.3
Hz for the concrete
pedestals
along
the longitudinal axis of the heat exchanger
shell.
This calculation indicated
that the heat exchanger
shell should
have
been qualified for the maximum value
(1.0 g) rather than the
ZPA value (0.4 g} of the response
spectrum specified in
the purchase
order for the heat exchanger.
Bechtel transmitted
the magnitude
of the transverse
pedestal
stiffness to Target for insertion into Target's
mathematical
model of the heat exchanger
shell
and also instructed Target to
use the one-perce>)t
damped
response
spectrum in the
FSAR instead of the response
spectrum stated
in the purchase
order.
This spectrum
curve reduced
the maximum
design 9-value from 1.0
g to 0.5 g, but met the
FSAR requirements.
The .team's
review revealed that Target did not completely incorporate the revised
nozzle
loads into the revised stress
report (Revision 3, dated April 14, l990).
In order to resolve this concern,
Bechtel
prepared
Calculation C-SJ-183-07
"Design Verification Report for Upgrading
CCM Heat Exchanger
to a Seismically
gualified Component,"
Revision 1, February 27, 1991, during the inspection.
This calculation multiplied the heat exchanger
component stresses
in the Target
stress
report by a worst-case ratio of 1.53 to account for the revised
loads
that the Target report tabulated but did not completely address.
Bechtel's
calculation demonstrated
that the stresses,
even after the multiplication of the
worst-case ratio, still remained
below the allowable stresses
for the components
of the heat exchanger shell.
Therefore, Deficiency 89-203-10 is closed.
(Closed) - Deficienc
89-203-11:
Shell-Side
Nozzle Loads for Re lacement
Heat
xc an ers
Teledyne Calculation 6961C-1, Analysis of Stress
Problem
025 Unit 4, Turkey
Point, for Replacement
of
CCW Heat Exchangers,
included the qualification of
the
CCW piping attached
to the
CCW heat exchanger shell-side
nozzles.
In order
to reduce the shell-side
nozzle loads, Teledyne
used circumferential
and
longitudinal rotational spring constants
at the pipe-nozzle interfaces
instead
of modeling these
interfaces
as rigid anchors.
However, Teledyne's
piping
analysis did not account for the transverse flexibilityof the concrete
pedes-
tals that support the heat exchanger.
The addition of a translational
spring
constant to the piping mathematical
model to account for the transverse flexi-
bility of the concrete
pedestals
might change
the frequency
response
of the
attached
piping, and might increase
the magnitudes
of the piping stresses
and
the
CCW heat exchanger shell-side
nozzle loads.
The licensee
responded that, in order to resolve this deficiency, Bechtel
and
Teledyne
had revised the four piping stress
analyses
that address
the piping on
the shell
and tube sides of the
CCW heat exchanger to incorporate
the trans-
verse flexibilityof the concrete
pedestals
which was
computed
by Bechtel
Calculation C-SJ183-12,
"CCW Heat Exchanger
Pedestal
Stiffness Analysis,"
Revision 2, January
27, 1990.
The revised analyses
showed that the pipe
stresses
and pipe support
loads were all within the
FSAR allowable stresses.
Bechtel
arid Teledyne incorporated
the pedestal
spring constant in the following
pipe stress
analyses.
1.
Bechtel Calculation N-12-183-02, "Intake Cooling Mater Piping From the
Component
Cooling Water Heat Exchangers (Inlet)," Revision 6, Harch 16,
1990.
2.
Bechtel Calculation N-12-183-04, "Intake Cooling Mater Piping From the
Component Cooling Water Heat Exchangers
(Outlet)," Revision 2,
November 28,
1989.
3.
Teledyne Calculation 6961C-3, "Analysis of Stress
Problem 038, Unit 4
Turkey Point, for Replacement of CCM Heat Exchangers,"
Revisicn 6,
December 7, 1989.
4.
Teledyne Technical
Report TR-5322-120,
"Turkey Point Nuclear Unit 4
Auxiliary Coolant System
(Outside Containment),"
Revision 2, July 27,
1990.
The followup team reviewed the referenced
piping analyses
and confirmed that
the pedestal
spring constants
had been inserted into the piping analyses,
and
that pipe stresses,
pipe support loads,
and nozzle loads
had been appropriately
reviewed.
Therefore, Deficiency 89-203-11 is closed.
(0 en) - Deficienc
89-203-12:
uglification of the Concrete
Pedestals
for the
Re
acement
eat
xc an ers
0
Bechtel Calculation C-SJ-183-02,
"Heat Exchanger
Support Pedestal
Load Evalua-
tion," included
a check of the heat exchanger
concrete
pedestals
to determine
their ability to resist the seismic reactions of the replacement
heat exchanger.
However, the Bechtel calculation
computed the heat exchanger
seismic reactions
using the
ZPA load of 0.4
g originally specified in FPL's purchase
order, which
did not consider the transverse flexibilityof the concrete
pedestals.
Moreover,
as noted in the Bechtel calculation,
Bechtel did not access
the concrete
pedestal
detail drawing.
Without the civil drawing for the concrete
pedestal,
the load
transfer
between
the heat exchanger
and the top of the pedestal
through the
pedestal
anchor bolts, the structural
capacity of the pedestal itself, and the
load transfer
between
the base of the pedestal
and the building concrete
slab
could not be adequately
checked.
The Bechtel calculation
had to make assump-
tions regarding the amount of pedestal
steel
reinforcement to perform the
analysis.
Therefore,
Calculation C-SJ-183-02
contained
several
undocumented
engineering
judgements.
In its response,
the licensee
indicated that Bechtel Calculation C-SJ-183-02,
"Heat Exchanger Support Pedestal
Load Evaluation,"
had been revised to recompute
the pedestal
reactions
to account for the transverse flexibilityof the con-
crete pedestals.
Bechtel prepared
a
STAAD mathematical
model of the heat
exchanger
shell to address
the revised nozzle
loads from the piping analyses
that Bechtel
and Teledyne revised to address
Deficiency 89-203-11.
The mathe-
matical
model of the heat exchanger shell also incorporated
the tranverse
pedestal
spring constant at the south pedestal
and released
the transverse
restraint at the north pedestal
to account for the expansion joint in the heat
exchanger
support at that location.
The fundamental
frequency of the heat
exchanger
along its longitudinal axis of 5.3
Hz (see Deficiency &9-203-10)
engaged
the maximum g-value of the design
response
spectrum.
The maximum
g-value would have
been 1.0
g if the original seismic requirements
of FPL's
purchase
order had been
implemented.
However, Bechtel
used the maximum value
'of 0.37
g specified for the two-percent
damped
SSE ground response
spectrum in
Figure 5A-I"of the
FSAR, which the team determined to be the licensing
commitment.
The followup team reviewed Calculation C-SJ-183-02,
"Heat Exchanger
Support
Pedestal
Load Evaluation," Revision 9, January
23, 1990,
and concluded that
Bechtel
had not verified the adequacy
of the pedestals
in resisting the revised
loads.
This is significant because
the revised
loads
appeared
to be about twice
the magnitude of the loads originally used to check the pedestals.
Furthermore,
the 'original pedestal
check also incorrectly reduced
the design
shear at the
south pedestal
by deducting
the magnitudes of the minimum friction forces
induced at both the north and south pedestals,
rather than deducting
the
magnitude 'of the friction force induced at the north pedestal
alone.
In
addition,
FPL's civil engineering
group identified an error in the formulation
of the pedestal
moment of inertia in the original pedestal
check.
FPL has tasked
Bechtel to perform a reanalysis of the heat exchanger
pedestals,
which will incorporate the actual
pedestal
reinforcement that
FPL identified
during the week of the followup inspection.
Deficiency 89-203-12
remains
open
pending the NRC's receipt
and review of FPL's revised pedestal
calculation.
The
team requested
that this deficiency be resolved prior to the restart of the units.
(Closed) - Deficienc
89-203-13:
Re lacement
CCW Heat Exchan er Shell-Side
hozz
e Loa
s
The heat exchangers
were qualified to the original imposed
dead loads,
nozzle
loads
and seismic
loads in a Target Technology Ltd. report.
Bechtel Calculation
H-12-183-01 tabulated shell-side
nozzle loads that were substantially higher
than the nozzle
loads that Bechtel originally transmitted to Target and that
0
Target used in the qualification report.
On November 23, 1988, Bechtel trans-
mitted the revised nozzle
loads to Target.
On December
1, 1988, Bechtel
and
Target discussed
these
nozzle loads,
and Target informed Bechtel that the
increased
nozzle
loads were acceptable
as noted in Bechtel letter V-738,
December 2, 1988.
However, Target never revised
and reissued
the
CCW heat
exchanger qualification report to document the qualification of the heat
exchangers
for the revised nozzle loads.
FPL responded that, after the piping analysis
had been revised,
Bechtel trans-
mitted the revised nozzle
loads to Target in requisition and purchasing
authorization
(RPA) order
358314401,
December 3, 1989.
This document also
transmitted the pedestal
spring constant
and revised required response
spectra
to Target.
Target traiismitted
a revised final stress
report to FPL.
This
report included
a consideration of the effects of the newly revised nozzle
loads.
The followup team confirmed that Target's
revised
(Revision 3) stress
report
tabulated
the revised nozzle loads, but did not.completely
implement the revised
nozzle
loads in the analysis.
However,, as noted in Deficiency 89-203-10,
Bechtel
prepared
a calculation to demo~>strate
that the adjusted
stresses
for the
heat exchanger shell
components
due to the revised nozzle loads were lower than
the allowable stresses.
Therefore,
Deficiency 89-203-13 is closed.
Closed} - Deficienc
89-203-16:
CCW Pum
and Sur
e Tank Seismic
ualification
and
Anc
>ora
e
C ec
Equipment Specification
676428 included the seismic qualification
criteria for the
CCW pumps.
Section 3.2.12 of the specification stated that
the
pumps were to be designed
to resist earthquake
forces in the horizontal
and
vertical directions,
as specified
by the
pump data sheets.
The Westinghouse
centrifugal
pump, data
sheet
APCC-532 specified
a horizontal design acceleration
of 1.0
g and
a vertical design acceleration
of 0.67 g.
FPL could not access
the seismic qualification documents for the
CCW pumps,
any seismic criteria for
the
CCW surge tank, or any seismic qualification documents.
The equipment
anchorage
should have
been
checked for the combined effects of piping thrust,
deadload,
and seismic load.
However,
FPL could riot access
the anchorage
calculations for the
CCW pumps
and surge tanks.
The license<<'s
response
indicated that this situation
was not uncommon for power
plants of Turkey Point's vintage.
The issue of equipment seismic qualification
was being addressed
under Generic Letter 87-02, "Verification of Seismic Ade-
quacy of Hechanical
and Electrical Equipment in Operating Reactors,
Unresolved
Safety Issue A-46."
FPL had submitted
a program to
NRC for resolution.
In
addition, Westinghouse
performed
a review of the Turkey Point seismic design
in July 1989, which was
documented
in WCAP-12051,
"Turkey Point Units 3 and 4,
Fragility Analysis for gualification of Seismic Capabilities of Buildings,
Structures,
and Equipments."
The Westinghouse
report concluded that the Turkey
Point safety-related
equipment,
including the
CCW pumps
and surge tanks,
have
high generic seismic capacities
and, if properly anchored,
the equipment
was
seismically
adequate
due to Turkey Point's location in a low seismicity .regioii.
The team did not review the Westinghouse
report,
since this document
formed part
of FPL's program to address
Unresolved Safety Issue A-46.
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FPL indicated that Bechtel
had analyzed
the
CCW pump anchorage
to evaluate
the
= effects of nozzle loads,
dead
loads,
and seismic loads.
This analysis
showed
that'he
pump was satisfactori ly anchored to withstand all postulated
loads.
Bechtel also analyzed
the
CCW surge tank anchorages
(including steel
supportin9
members)
to evaluate
the effects of nozzle loads,
dead loads,
and seismic
loads.
The analysis
showed that the structural
members
and connections
would
adequately
withstand all postulated
loads
and would remain within FSAR allow-
ables.
The analysis
showed that the expansion
anchors
used to attach the
supporting
members to the concrete walls could function properly.
However, the
analysis
indicated that Unit 4 would need modification to qualify the existing
expansion
anchors
which support the surge tank platform to the factors of safety
required for long term operation
by the Bulletin 79-02 program.
The followup team reviewed Bechtel Calculation C-SJ183-11,
"CCW Pump Pedestal
Analysis," Revision I, December 4, 1989,
and identified an error in the compu-
tation of the
maximum pedestal
bolt load.
Bechtel revised the Calculation
(Revision 2, dated
February 27, 1991) to correct the error, which the team
accepted.
FPL also prepared modification packages
PC/ll 90-471
and 90-472,
"Component
Cooling Water Surge
Tank Rigidity Upgrade," Revisions 0, dated January
25,
1991, to strengthen
the Unit 3 and Unit 4
CCW surge tank/platform configurations
by adding longitudinal and transverse
bracing to the
CCW surge tanks.
The team
reviewed Bechtel Calculation C-SJ394-01,
"CCM Surge Tank Rigidity Upgrade,"
Revision 0, January 24, 1991, which qualified the revised tank/platform config-
urations
and found the calculations to be acceptable.
The team requested
that
FPL install the Unit 4 portion of the modification package
during the current
refueling outage.
Deficiency. 89-203-16 is closed
based
on the team's
under-
standing that
FPL will modify the Unit 4
CCW surge tank anchorage prior to
restart.
(Closed) - Deficienc
Item 89-203-17:
Auditabilit of the
CCW Stress
Packa
es
Teledyne
reviewed the safety-related
large-bore piping systems,
equipment,
and
supports
associated
with the
CCW system in Units 3 and
4 for conformance with
the
FSAR criteria.
Bechtel previously reviewed these piping sy'stems for
functionality.
The DYI team reviewed the Teledyne Calculations
6961C-1
and
6961C-3
and revealed that the Teledyne stress
packages
could not be audited
as
independent
documents.
The Teledyne calculations
used information that Bechtel
originally prepared without clear reference
to the originating Bechtel
documen-
tation.
Examples of such unreferenced
information included equipment
nozzle
thermal
displacements
and valve weights
and offsets.
The Teledyne stress
packages
did not appear to incorporate, either directly or by reference,
the
Bechtel information required to make these stress
packages
auditable.
The licensee
responded that, in order to support auditability of these stress
packages,
FPL had planned to reference
the Bechtel input documents
on the
isometric drawings supporting
each stress
package.
This isometric drawing
program is scheduled
to be completed
by December
31,
1992.
Teledyne will
revise the drawings in accordance
with Teledyne engineering
procedure
"Generation of "As-Built" Piping Stress
Isometric and Pipe Support Drawings for
Safety-Related
Piping Systems,"
which is being revised (Revision 3) to incorpo-
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rate this activity.
The team considers that the planned corrective action is
acceptable;
therefore,
Deficiency 89-203-17 is closed.
(Closed) - Deficienc
89-203-19:
Small-Bore Pi
e Oualification
The DVI team reviewed Bechtel
Walkdown Package
CCW-3-111-1
and backup Bechtel
Calculation C-499-167
and assessed
the qualification of the branch lines to the
governing criteria of Bechtel Specification 5177-PS-21,
"Project Implementation
of User's
Hanual H-18 for Routing and Supporting 2-inch and Under Piping for
Hodification to Turkey Point Units 3 and 4."
The calculation accepted
two
branch lines with frequencies of 22-24
Hz without requiring tieback supports to
the piping run.
The tieback supports
were required
by the Bechtel specifica-
tion for branch lines with fundamental
frequencies
less than 33 Hz.
The licensee's
response
indicated that, although
the branch lines
had fundamen-
tal frequencies
less
than
33 Hz, the stress
levels of these
two branch lines
were determined
to be within the allowable ranges for both
OBE and
and
were considered
acceptable.
To avoid misinterpretation
in future application
of these criteria, Bechtel
had revised the acceptance
criteria in its design
specification to permit alternative
methods of assessing
the
need of tieback
supports for branch lines.
The team reviewed the revised User's
Hanual
and agreed that these
methods
satisfied
the licensing
commitment of piping Code 031.1.
Therefore, Deficiency
89-203-19 is closed.
Closed) - Deficienc
89-203-20:
Com onent Desi
n
Re uirements
(CDRs)
The
CDRs for the reactor protection systems,
CCW, and electrical distribution
systems
contained
erroneous
and unnecessary
information.
These
concerns
led
the
DVI team to the conclusion that the
CDR had not been appropriately veri-
fied.
The licensee
had agreed to perform additional verification of the
information and issued
a directive which restricted
the use of CDR information
in the design process.
FPL's response
letter to the
NRC indicated that the
CDR verification would take
place in several
stages.
First, the accuracy
and reliability of CDR informa-
tion would be improved in a
"CDR Repair" project which would provide the
component
requirements
in a clear,
concise,
and verifiable form.
Upon comple-
tion of "CDR Repair" for the selected
systems,
"CDR Verification" then would be
performed.
This effort would include verification and validation of CDR
information.
The scope of this verification would be finalized in procedures
and would be expected
to focus
on key design requirements
that demonstrated
the
functional capability of the components.
The licensee will complete this
effort by June
30, 1991.
The followup team reviewed the
"CDR Repair"
package for the components
in the
safety injection system
and found
CDR information was well prepared,
and that
every
component
was addressed
in detail.
Although, certain design attributes
of some
components
were unavailable,
the licensee
had identified them and
planned to obtain them through other utilities, manufacturers,
and vendors.
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The team also reviewed the
FPL training plan for the
CDR verification program
and found it to be acceptable.
Based
on the satisfactory initial progress
of
the
CDR repair package,
the acceptable
training plan for CDR verification and
FPL's stated intent of completing the program, Deficiency 89-203-20 is
considered
closed.
3.0
MANAGEMENT EXIT MEETING
The inspection
team conducted
an exit meeting at FPL's engineering offices on
March I, 1991.
The team discussed
the status of the deficiencies
addressed
during the followup inspection,
including actions required to resolve the
remaining unresolved
dei'iciency.
Mr. E.
V. Imbro of NRR was at the exit
meeting.
After the exit meeting,
the licensee
presented
to the followup team
a program
to overview their contractor's
design products.
This program resulted
from the
original DVI team's
comment regarding
FPL's technical
overview of its contrac-
tors.
FPL considered that this program was successful
in that calculations
submitted to FPL by its vendors after the implementation of this program showed
a significant improvement over those submitted before this program.
The team
questioned
the effectiveness
of this program in light of the nuoher of errors
.found in the contracted
engineering
products
reviewed during this inspection.
t
4.0
PERSONNEL
CONTACTED
R. Noble
M. Oswald
- M. Moran
- S. Cornell
- K. Greene
- F. Schiffley
C. Weaver
J.
Ivany
- R. Gil
- H. Paduano
- S. Yerduci
L. Pabst
- R. Wade
G. Adams
- D. Powell
- E. Weinkam
- W. Harris
- J. Hosmer
Engineer I, PEG-FPL
L<<ad Senior Engineer,
ABB Impell/ABB C-E
Engineer,
PEG-FPL
Lead Mechanical
Engineer,
PTP Site,
JPNS/FPL
Civil Engineering Supervisor,
JPN/FPL
FPL, Engineering
Bechtel
Bechtel
FPL,JPN
FPL, Licensing
Design Basis Manager - FPL
FPL,
NAS
FPL, Engineer
PTN, Licensing
FPL, Nuclear Licensing
FPL,
JPN
Projects
FPL, Director
+ Designates
licensee
personnel
who attended
the exit meeting
on
March I, 1991.
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