ML17348B427

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Insp Repts 50-250/91-52 & 50-251/91-52 on 911228-920124. Violation Noted.Major Areas Inspected:Monthly Surveillance Observations,Monthly Maint Observations,Operational Safety & Plant Events
ML17348B427
Person / Time
Site: Turkey Point  NextEra Energy icon.png
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.:

DPR-31

and

DPR-41

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

PDR

ADOCK 05000250

8

PDR

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

4B steam generator

feedwater

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

FPL letter L-91-329 dated

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

Inoperable

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

NPS

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

INPO

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

NRC Enforcement Policy were

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,

10 CFR Part 50,

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

EDG

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

10 CFR 50.72(b)(1)

and

10 CFR 50.73(a)(2)(ii).

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

hot short,

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,

AFW Nitrogen Backup System

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

48 steam generator

feedwater

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.,

annunciator

82/5,

RCP

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

gasket

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

SW

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

feedwater

pump,

mechanical

maintenance

on

CV-2209

(one of two flow control

valves

supplying seal

water to the

4B steam generator

feedwater

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

steam generator

feedwater

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

PORV

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

PORV

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

A MSIV nitrogen backup,

and the

A NSIV

was declared

out of service

per

TS 3.7.1.5.

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

TS 3.7.1.5

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

TS 3.0.3

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

PORV

(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

10 CFR Part 50, Appendix R,

design .basis

document

(paragraph

5).

12

Acronyms

ADM

AFW

ARM

CFR

CV

EDG

ERT

FPL

FSAR

H/A

INPO

IRNI

LCO

LER

MSIV

NI S

NCR

NE

NCV

NPS

NRC

NW

ONOP

OSP

PC

PC/M

PCV

PORV

psl9

PTN

PWO

QA

QAO

QC

RCP

RCS

SE

SW

TS

URI

VIO

and Abbreviations

Administrative

Auxiliary Feedwater

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

Main Steam Isolation Valve

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:

RP

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.

Washington,

DC

20036

Mr. Jack Shreve

Office of the Public Counsel

Room 4, Holland Building

Tallahassee,

Florida

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,

Florida

33090

Intergovernmental

Coordination

and Review

Office of Planning

5 Budget

Executive Office of the Governor

The Capitol Building

Tallahassee,

Florida

32301

Administrator

Department of Environmental

Regulation

Power Plant Siting Section

State of Florida

2600 Blair Stone

Road

Tallahassee,

Florida

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,

Florida

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,

Florida

32399-0700

Distribution:

  • III-

RSIB R/F

DRIS R/F

TEMurley,

NRR

FJMiraglia,

NRR

WTRussell,

NRR

JGPartlow,

NRR

BKGrimes,

NRR

EVImbro,

NRR

DPNorkin,

NRR

HBWang,

NRR

RLSpessard,

AEOD

SAVarga,

NRR

HNBerkow,

NRR

RAuluck,

NRR

DAMilier,

NRR

LAReyes, RII

FJape,

RII

'WHMi 1 ler, RI I

RCButcher,

SRI Turkey Point

e

Regional Administrators

Regional Division Directors

Inspection

Team

LPDR

PDR

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-31

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,

NRR

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.

FPL's letter No. L-90-350,

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

CCW

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

CC

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

Westinghouse

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

EP-2-064,

"Generation of "As-Built" Piping Stress

Isometric and Pipe Support Drawings for

Safety-Related

Piping Systems,"

which is being revised (Revision 3) to incorpo-

I

0

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

SSE

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

CDR

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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p

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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

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.

I

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0