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1 SUPPLENFMTAL SAFETY EValil4 TION BY THE OFFICE OF MLEAR R_NTM arm
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EVaiilATION OF THE FL0arna p = a A E LIGHT Ci_idW'S l
RESPONSE 70 ammIC Lu ve.x 87-02 ST. LucIE tmIT 1 A W TURKEY POINT IMITS 3 Am 4 I
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50-335. 50-250/251 i
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1.0 INTRODUCTION
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By letter dated February 9,1995, the staff issued a safety evaluation report l
(SER) on the Florida Power and Light Company's (the licensee) implementation j
program for addressing Generic Letter 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved 4
i Safety Issue (USI) A-46."
In the SER, the staff identified several open j
items, and indicated that a site audit would be conducted to address the open items.
The audit was performed during December 4 through 8, 1995, by a team consisting of two members from NRR, one member from Region I, and one i
contractor from Brookhaven National Laboratory (BNL).
This report provides the staff's supplemental SER (SSER) documenting the results of the audit.
r 2.0 OISPOSITION OF SER OPEN ITEMS The audit was conducted in part at the licensee's corporate offices and at the Turkey Point plant site. During the visit to the corporate offices, the i
licensee presented an overview of its USI A-46 program, including details of its program for addressing concerns with electrical relays. Discussions were also held with the licensee's Seismic Review Team (SRT), consisting of three i
expert seismic consultants from the nuclear industry, who performed the equipment walkdowns.
It is noted that the SRT members were extensively 4
involved in the development and review of the equipment experience database utilized in the USI A-46 generic resolution program.
i During the site visit, the staff performed inspection walkdowns of several j
equipment items in the safe shutdown path.
Since the plant was in operation, i
extreme care was taken to avoid upsetting the equipment during the walkdowns.
Consequently, the walkdown portion of the audit was mostly limited to external visual observations. ' The audit findings relating to the previously open SER items are discussed below.
SER Item 1 Staff's review of the methods used to develop the in-structure response spectra for performing equipment evaluations.
Audit Observations and Findings The staff reviewed the in-structure spectra (IRS) developed by the licensee during its audit meeting of December 4-8, 1995.
The staff observed that the licensee had developed the IRS for the Containment, Auxiliary and the Control buildings. No specific method for developing the IRS was identified.
However, the overall amplifications of the ground motion through the buildings appeared reasonable. During discussions with the licensee's Seismic Review ATTACHMENT n op-9703140001 970301 PDR FOIA BINDER 96-485 PDR
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2 Team (SRT) members (consisting of Robert Kennedy, John Reed and John Stevenson), the staff found that because of the relatively low heights of i
i otner seismic Category I structures, the SRT used judgements to estimate the j
amplified motion.
using either the peak (irrespecPve of the frequency of the equ i
spectral accelerations of the avcilable IRS, or 1.875 times the peak ground acceleration of the ground response spectrum.
The factor 1.875 is 1.5 times 1
1.25 used for anchorage evaluation of relatively rigid equipment (frequencies above 8Hz) under GIP-2 criteria when the equipment is located within 40 feet j
above the grade elevation.
Therefore, for the equipment located in the low
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structures at the plant, for which the IRS have not been developed, the staff i
found the SRT judgement acceptable.
For the resolution of USI A-46, the staff considers the mixed use of IRS and the SRT criterion acceptable, and this item j
is closed.
SER Item 2 l
Staff's verification, by sampling, that the Turkey Point safe shutdown equipment is similar to equipment in the experience database.
a Audit Observations and Findings The staff discussed this issue with the licensee and the SRT members.
As noted previously, the SRT members are recognized seismic experts who were closely involved with the development and review of the equipment classes included in the experience database. The SRT confirmed that the safe shutdown equipment at Turkey Point ?, representative of what they observed during their review of the data base facilities.
In addition, the staff performed walkdown inspections of selected equipment items during the site audit, and found that the equipment items were procured from major nuclear equipment vendors, and were typical of those observed in any such large industrial facilities, including those in the experience data -
base.
Based on this information, the staff concluded that the Turkey Point safe shutdown equipment is representative of that in the database, and therefore, the use of the experience database criteria to establish equipment seismic adequacy is appropriate.
This item is closed.
SER Item 3 Staff's review of selected safe shutdown equipment. items and raceway systems which were excluded from the licensee's seismic verification walkdowns.
Audit Observations and Findings Equipuent Items The staff reviewed information related to selected equipment ' items that are included in the safe shutdown path, but were not included in the licensee's detailed walkdowns.
In addition, the staff inspected a sample of the excluded equipment items.
Based on the sample review, the staff determined that the excluded items were representative of the equipment found in the experience
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database, appeared to be adequately anchored, and were canerally seismic interactions.
was very G ose to other equipment._In one case, the staff noted a valve, CV 1 The staff questioned the licensee as to the potential for seismic interaction, and the impact on the safe shut path.
The licensee indicated that potential impacting or minor damage valve was acceptable not prevent achieveme,nt of safe shutdown.and that even if the valve failed to 4
Based on this sample review of and this item is closed. excluded equipment items, the staff did not id Raceways anchorages, were not evaluated by the licensee In the 1983-84 time frame, the licensee developed and implemented a comprehensive program to determine the as-built routing of i
on the raceway supports, and identify overfilled raceways. all cables, loads i
documentation of future additions and rerouting of the The information 1
i percent fill, whichever contFolled the design. supports in the c The' cable tray i
fill, or existing percent fillincluding those in the Unit 3 and Unit 4 conta 2
The remaining cable trays, i
whichever governed the design.
related raceways, as well as se,ismic Category II over I raceways wereAll evaluated for dead loads plus seismic loads.
licensee had added a new Emergency Diesel Generator Building.
In the 1990-91 time frame, the time, some of the cable trays were further loaded and some of the cab During that rerouted.
The itcensee had reevaluated the affected cable trays to assure compliance with the established criteria for filling, and seismic adequa The staff reviewed the itcensee's documentation identifying the cabl tolerable fill levels, and actual fill levels.
consultant, were also reviewed. documents containing details and tha Drawings and calculation The staff randomly picked four cable tray
-runs (1) one in the Cable Spreading room at Elevation 30 ft., (2) one in the Control Room at Elevation 42 ft., (3) one in the Auxiliary Building at Elevation 18 ft., and 4 Adequate documentation (wa)s available leading to the co one in the Turbine Building at Elevation 30 ft.
calculations packages.
The calculation packages led to the details about the supports and support anchorages.
used the 1980 edition of the AISC specification with alm acceptance criteria as those in SRP 3.8.4.
dead load with the Operating Basis Earthquake (08 However, for the combination of Fy (yield stress) rather than 0.6 Fy.
For the combination of dead load with '
the Safe Shutdown Earthquake the SRP acceptance criterion o(SSE), (SSE, PGA - 0.159), the licensee utilized f 0.9 Fy.
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This wn acceptable since the combination with the OBE loading would not control the design of the supports since the ratio between the SSE and the OBE is larger than their corresponding acceptance criteria.
The staff also reviewed the specifications and acceptance criteria for expansion bolts which were widely used in anchoring the supports to the concrete.
The installation procedure required the specific preload on the installed bolts, and the quality assurance criteria required the licensee to i
document the preload on the bolts.
During the walkdown of the four cable-tray runs, the staff reviewed the cable-tray alignments, support spacings, and anchorages to the steel and concrete structures.
The as-observed attributes were very close to the ones shown on the drawings. Many of the cable trays and conduits had sprayed-on fire proofing.
The non-sprayed supports were painted.
The anchor bolts appeared to be sufficiently tight (observed and prodded with fingers).
Overall, based on the review of the criteria, documentation, and inspection of the sampled cable trays, the staff concludes that the licensee was able to reasonably ensure that the over-fill conditions did not exist; and the cable trays, their supports and anchorages could safely withstand the postulated seismic loadings.
This item is closed.
SER Item 4 i
Staff's verification, by sampling, that the criteria in EPRI NP-5288-SL, Revision 1 has been adequately addressed, in light of the extensive use of SRT judgment for screening out equipment anchorage and the lack of documentation to support the judgements.
i Audit Observations and Findings During the audit, the SRT members, who were technical reviewers or otherwise i
knowledgeable of the EPRI anchorage criteria, confirmed that they applied the same criteria in judging anchorage adequacy for Turkey Point.
Since the plant 1
was in an operating condition at the time of the audit, the staff could not comprehensively inspect the installed anchorage.
The staff performed limited i
walkdowns, and reviewed relevant design drawings and original design calculations.
In addition, the staff reviewed the licensee's supplemental calculations used to verify the adequacy of the installed anchorage, and also reviewed calculations to support anchorage modifications.
Based on this review, the staff raised questions regarding some of the existing anchorages that the licensee previously determined were adequate, and on some of the anchorage modifications.
In one case, the staff questioned the adequacy of the upgraded anchorage for the 480 volt motor control centers (MCC).
Specifically, the staff was concerned that only the front bottom portion of the MCC was anchored to the floor, and the front top was braced to the wall with steel angles at relatively large spacings.
This concern was discussed with the licensee and the SRT.
The SRT reviewed the seismic loads on the MCC.
The MCC is mounted at grade elevation and the SRT determined that the seismic loads were small.
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5 The SRT therefore concluded that the modified anchorage was sufficient to l
carry the seismic loads.
Based on the review of the seismic loads and discussions with the SRT, the staff concurred with this conclusion.
In another case, the staff raised questions regarding the adequacy of the anchorage for the invertors and battery chargers. Specifically, it was not clear if the anchor bolts penetrated through the 2.5-inch thick grout 4
pedestals, and whether there was adequate embedment in the floor slab.
i Further investigation revealed that the anchors consisted of new Hilti ty bolts with minimum embedment lengths of 8.5 and 12 inches, respectively. peThe lengths of the bolts ensure a minimum embedment of 6 inches which the staff determined was adequate for the light equipment.
The staff noted a crack on the concrete floor in front of the Unit 4 DC Load Center.
The staff was concerned that the crack may propagate through the pedestal near the anchor bolts, and could degrade the load carrying capacity of the bolts.
Subsequent investigation by the licensee confirmed that the crack had indeed penetrated the pedestal and passed near one of the two bolts in the middle row. The licensee indicated that the remaining five bolts can safely carry the seismic loads from the cabinet. However, the staff remained concerned that the crack could worsen and further degrade the anchorage capacity.
In response to the staff's concerns, the finding was documented in the licensee's deficiency tracking system as Condition Report 95-1220 for corrective action.
The licensee's corrective action will be evaluated in the NRC resident inspector's report.
i Thus, based on confirmation by the SRT and the staff's own sample audit and inspection, the staff found that the equipment anchorages are adequate for the seismic loads at turkey Point except for the two places as noted below.
The component cooling water heat exchangers and associated support systems, and several other equipment items, all located in an area of the plant which is exposed to the outside environment, were observed to have been severely degraded by corrosion (e.g., bolt heads were split and steel plates were perforated). Although the staff did not consider this to be an immediate problem, the staff was concerned that further degradation could challenge the structural integrity of the supports.
It was also noted that in several cases, the licensee appeared to have recently painted some of the corroded structures, but that the corrosion products had not been removed.
This may not arrest further corrosion, and may require more aggressive maintenance for prolonged reliance on these items for carrying seismic (and other) loads. The staff cautioned the licensee that it would be prudent to implement a program for eliminating and controlling corrosion. The licensee documented the as-found condition of the equipment,. indicated that it would perform further evaluations of the equipment, and indicated that it would implement corrective j
actions to arrest further corrosion.
This was documented in the licensee's deficiency tracking system as Condition Report 95-1217 for corrective action.
The staff considers the licensee's action sufficient +,o close this SER's open item. The licensee's corrective action will be tracked in the NRC's resident inspector's report.
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6 SER Item 5 Staff's verification, during the site audit, of the adequacy of the licensee's implementation of the methodology for assessing seismic interactions.
Audit Observations and Findings walkdown in 1990, they specifically considered the po interaction of components due to seismic motion.
Further, the SRT members indicated that the seismic interactions assessment was consisten methodology approved for the USI A-46 generic resolution.
i consists of visual inspection of the existing clearance between adjacentThe method motion to prevent deleterious interactions. components, and assessing w During the site audit, the staff observed that the licensee's program was generally effective in identifying and resolving potential seismic interaction situations, or ensuring that an interaction concern does not exist.
the staff also noted some instances in which the potential for seismicHowever, interaction still existed.
For example, during a walkdown of the station cells and restraints, and between some interior battery c i
cross braces.
impacting the restraints and support structures.These clea.rances could re This situation was previously noted by the SRT during its equipment walkdowns, but the licensee had failed to address the concern.
The staff informed the licensee that either these gaps should be eliminated or spacer cushions should be inserted i
to eliminate the potential for impact of the brittle battery cells with the restraint's metallic material.
corrective actions to resolve the concerns with the batteries.The licensee indi This was documented in the licensee's deficiency tracking system as Condition Report 95-1217 for corrective action.
Another potential seismic interaction concern involved the medium voltage switchgear.
The staff noted that several screws cn the doors of the cabinets were either missing or loose, which could result in rattling of the doors.
These cabinets house electrical relays, and. rattling of the doors could cause chatter or relay malfunction.
The staff considers this as primarily a housekeeping issue.
Since electrical cabinet doors are frequently opened for maintenance and operational purposes, the licensee should institute and adhere to a good housekeeping program that will ensure securing all door fasteners for all cabinets.
In response to the staff's concerns, the Itcensee indicated that it would review the adequacy of its housekeeping procedures, and ensure that plant maintenance and operations staff are aware of the importance of proper housekeeping.
tracking system as Condition ReportThis was documented in the licensee's deficie 95-1217 for corrective action.
The staff finds that the licensee's implementation of the methodology for accessing seismic interactions is acceptable and considers the licensee's commitment to resolve the above concerns sufficient to close this SER's open
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l item. The licensee's corrective action will be tracked in the NRC's resident I
inspector's report.
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SER Item 6 I
L Staff's review of the capacity versus demand evaluations for selected
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equipment items to confirm the appropriateness of the licensee's method of comparing capacity and demand at the plant level rather than for each individual equipment item.
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Audit Observations and Findings 3
For the USI A-46 program, the equipment capacity is usually derived 1
generically by use of the experience data. The Senior Seismic Review and Advisory Panel (SSRAP) has developed a generic capacity spectrum (called
' reference spectrum,' having 1.2g spectral acceleration.between 3 and 8 Hz at e
a damping value of 5% with a,zero period acceleration of 0.5g) for common types of industrial equipment as long as certain inclusion and exclusion rules 4
i are satisfied. The SSRAP recommended that the seismic ground' action demand should not exceed two-thirds of this capacity spectrum (called ' bounding 3
j spectrum').
Further, the SSRAP judged that this demand vs. capacity
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comparison is valid for equipment located at an elevation equal or less than about 40 feet above the effective grade as long as the building is a typical l
Industrial structure and the equipment items possess a fundamental frequency 4
above about 8 Hz. Otherwise, the in-structure response spectrum at the equipment mounting location should be used for comparison with the capacity spectrum.
For Turkey Point, the SSE ground motion acceleration spectrum with a ZPA of 0.15g is substantially below the bounding spectrum.
Equipment items in the licensee's USI A-46 safe shutdown list (except component cooling water i
surge tanks that have been separately evaluated) are located at an elevation of 24 feet or less above the effective grade. Thus, the amplification of the i
ground motion will be such that the amplified in-structure acceleration
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response spectra at 5% damping up to this elevation will be significantly
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lower than the reference spectrum. This was confirmed during the audit by l
comparing with the in-structure spectra response available for the Control
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Building. Therefore, this item is closed.
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SER Item 7 i
i Staff's review of the licensee's evaluation of tanks and heat exchangers to verify the adequacy of the licensee's calculations, and to ensure that the program adequately resolves the outliers and concerns identified in the SER.
i The review'is for resolving the seismic adequacy of tank's in both USI A-40 i.
and USI A-46.
Audit Observations and Findings
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1.
Yard Tanks - Refuelina Water Storace Tank and Condensate Storaae Tank 4
During this audit, the staff discussed the deficiencies in the seismic capacity of the Refueling Water Storage Tank (RWST) and Condensate Storage Tank (CST) with the licensee and its consultant (Stevenson & Associates -
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As a result of the recommendation of the SRT and S&A, the licensee had j
upgraded the tops of the tank chairs.
conservative criteria With the upgrade, and using relatively The capacities are con, trolled by the capacity of the J-bolts used fo i
i anchoring the tanks to the concrete ring foundations.
Subsequent to the audit, the licensee attempted to demonstrate that the realistic high confidence of low probability of failure (HCLPF) capacities were higher than the SSE PGA By letter dated June 20, 1996, FPL indicated that the i
j seismic capac(0.15g).
ities of the CSTs and RWSTs meet the design basis seismic j.
acceleration requirement of 0.15g ground acceleration for the MHE and the tanks were no longer considered outliers.
i BNL, indicated that the formulas used by S&A could not be undisputedlyA l
substantiated, and when more conservative formulas were employed, the tanks' j
HCLPF capacities could be estimated to be 0.12g.
The staff recognizes that BNL computed HCLPF capacity values for the tanks are based on conservative design code assumptions, and that they were sufficiently close to SSE-PGA.
j Thus', the staff concludes that the tanks are capable of withstanding the postulated earthquakes without loosing their fluid content.
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Boric Acid Storaae Tanks s
The original design documentation for the Boric Acid Storage Tanks (llASTs) was
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not available.
During the SRT walkdown in 1990, the team identified the i
anchorage of vertical tank support legs welds, and the torsional load on horizontal support system as concerns.,However, in 1991, the licensee made a change in the concentration of boric acid in the tanks, and increased the 1
depth of boric acid in the tanks.
and to address the SRT's seismic concern, the licensee reanalyzed the ta and their support structures.
Corporation (the licensee's consultantThe reanalysis was performed by A88 Impell j
conditions of the tanks and their suppo)rt structures.after surveying the as-built t
The preliminary analysis indicated that the support systems required six rigid vertical struts attached at specified locations to the supporting horizontal i
members (existing 12W58 and 12W65) that are anchored to the Auxiliary Building South wall. The licensee installed the struts. ABB Impell performed the l
dynamic analysis of a tank model and the integrated support structures.
The details of this analysis was prov,ided to the staff subsequent to the site i
audit in December 1995. The staff reviewed the parameters incorporated into the dynamic analyses, their results, the way the results were incorporated in verification of the adequacy 'of the tanks, their attachments, and the support structures. The staff also performed a sample review of the calculations related to the North side columns (where struts were not added), and found them to be slightly of reasons (mainly co(maximum 7%) overstressed. A88 Impell provided a number nservative analysis-design assumptions) for accepting the
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1 minor overstress.
The staff did not completely agree with all the reasons provided,-but overall, the staff considers the small overstress acceptable.
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Based on the SRT's walkdown and the staff's review and walkdown inspection, the staff concludes that the BASTS and their support structures, as modified, are adequate to withstand the postulated seismic loadings.
This SER item is j
therefore closed.
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SER Item 8 i
i Staff's review of specific seismic qualification documents for the ' Bad Actor' relays and the ade 4
resetting relays. quacy of procedural changes and/or operator actions for j
Audit Observations and Findings j
The FPL reduced-scope relay program includes verifying relay mounting (see SER Item No. 9), and disposition of any relays on the EPRI ' Bad Actor' list that are installed in the plant. The ' Bad Actor' relays are so defined because of documented past poor performance, the basis of which varies due to several i
factors.
FPL reviewed the relays installed at Turkey Point, and found that of l
the.23 ' Bad Actor' relays on the EPRI list, the following relays are used in Turkey Point Units 3 and 4:
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GE Relays CFD, CFVB, CEH, IJD, HGA and PVD l
Sudden Pressure Switches The licensee initially indicated that it had specific seismic qualification data to qualify some of the ' Bad Actor' relays installed at Turkey Point. The staff reviewed the test data during the audit, and questioned whether the data was sufficient to demonstrate adequacy of these relays in all of the different applications. A major concern was that FPL did not fully assess the potential for different in-structure responses due to the plant elevation at which the relay was installed, and the specific mounting configuration.
Therefore, the actual in-structure response spectra for a particular relay may be higher than the test response spectra. Consequently, the staff did not accept the licensee's position that a single test report could be used to demonstrate the adequacy of one type of relay in all applications.
In response to the staff's concerns, the licensee performed additional evaluations to detemine the effect that potential seismic-induced chatter may have on the ability of the relay to perform its safe shutdown function. The licensee provided information to demonstrate that potential relay chatter of the ' Bad Actor' relays would not affect the ability to achieve safe shutdown.
The licensee determined that most of the ' Bad Actor' relays installed at Turkey Point perform annunciation functions, and have no direct safety function.. For the remaining relay types, the licensee determined that chatter can be tolerated for each particular application.
There is one ' Bad Actor' relay model (GE IJD) installed at Turkey Point for which the earthquake experience data showed a unique failure mode due to seismic loads. This is an induction disk relay and is installed at Turkey Point in the emergency diesel generator control panel. The experience data showed an instance in which the relay control spring vibrated due to seismic loads, touched ground within the relay enclosure, and short-circuited the
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li 10 relay. During discussions with the licensee, an SRT member provided information to show that this particular failure mode was not a concern if the relay included a special restraining device to prevent excessive spring vibration.
The GE IJD relays installed in the safe shutdown Point were inspected and found to contain the special device. path at Turkey Therefore, this failure mode is not applicable to this type of relay installed at Turkey Point.
Notwithstanding, the licensee performed further assessment of the possible failure of this relay, and concluded that operator actions would be j
4 sufficient to ensure that safe plant shutdown would be accomplished.
In order to provide an additional level of defense-in-depth against deleterious effects of relay chatter, the licensee indicated that its j
Emergency Plant Implementation Procedure plant operators of the possible occurrence (EPIP) would be revised to alert of relay chatter, and to provide guidance for identifying and recovering from potential relay chatter.
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staff concluded that the licensee's actions appeared adequate to resolve the i
concerns with ' Bad Actor' relays, and therefore, the ' Bad Actor' relay issue is closed.
SER Item 9 Staff's verification, by sampling of the installation adequacy of relays in 1
the safe shutdown path, i
j-Audit Observations and Findings i
In general, since the plant was at full power during the audit, electrical and j
control cabinets could not be opened for verification of relay mounting.
This subject was discussed with the SRT members who confirmed that, during their equipment walkdowns in 1990, they verified that relays were adequately mounted.
For the limited occasions when the licensee opened the cabinets l
during the audit, the staff inspected relay mountings and did not observe any mounting configurations that would contradict the SRT's observations.
1 In addition, the licensee implemented a relay inspection program which i
verified the installation adequacy of a sample population of relays in the safe shutdown path. This program included visual examination of numerous relay installations, and additional relays were selected for physical
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examination to verify that mountings were secure.
The staff reviewed the results of this program.
The licensee reported that all relays inspected were determined to be properly installed per manufacturers recommendations.
The staff concluded that the actions described above provide reasonable assurance that relays in the safe shutdown path are adequately installed, and therefore, this item is closed.
SER Item 10 Staff's review of the licensee's methods for resolving equipment outliers, including any needed revisions to plant procedures to address the several issues involving poor housekeeping.
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Staff's review of the licensee's methods for resolving equipment outliers, j
including any needed revisions to plant procedures to address the several j
issues involving poor housekeeping.
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j Audit Observations and Findings i
For many of the modifications which were implemented to resolve equipment outliers, the staff observed that.the modifications were adequate. However, i
there were also instances in which the licensee did not implement a i
modification recommended by the SRT, or in which it was not clear that.the i
modifications adequately resolved the issues.
For example, the licensee l
' failed to address the SRT's recommendation to replace a sight glass on the emergency diesel generator day tank.
The SRT's concern was that the glass may break during a seismic event and result in draining the day tank. The licensee's options were either to replace the glass with a different material (e.g., plastic) not prone to breakage, or demonstrate that the consequences of losing the sight glass are acceptable. The licensee initiated Condition Report 95-1219 to document the site glass deficiency for corrective action.
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Subsequent to the audit, the licensee indicated that the lower gage glass
' isolation valve had been replaced with an excess flow stop check valve to i
address this concern. Documentation for this modification will be reviewed by the resident inspector. The lack of spacers for batteries (SSER Item 5) presents a potential seismic interaction concern that was originally j
i identified by the SRT.
In the case of modifications made to the MCC, it was net immediately clear whether the anchorage modifications adequately addressed i
the SRT concern. During the audit, the SRT performed further calculations and
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determined that the modifications were adequate since the MCCs are located at j
the grade level.
i During the equipment walkdowns, the staff identified several examples of poor i
housekeeping and inadequate maintenance.
For example, the staff identified i
i loose fasteners and, in some cases, lack of fasteners for securing some
. electrical cabinet doors (SSER Item 4).
The staff also observed severe i
corrosion of outdoor components and cracking of the concrete floor slab near l
an electrical cabinet (SSER Item 4). The staff considers these observations l
indicative of the need for the licensee to more closely focus on improving its i'
housekeeping and equipment maintenance programs.
The licensee indicated that it would take appropriate actions to resolve the specific issues.
i The staff concluded that the licensee needs to improve its initiatives and I
l methodologies'for resolving outliers, and needs to improve its housekeeping program. The staff understands that the licensee is currently addressing all l
of the deficiencies and outliers identified during the site audit by the Condition Reports previously mentioned. On this basis, this SER item is closed. However, the above-identified staff findings and subsequent licensee's corrective actions relating to this item will be tracked by the NRC's resident inspector.
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3.0 CONCLUSION
S As described in this SSER, the staff found that, in general, FPL has implemented an adequate seismic program to address the open items described in i
the staff's SER dated February 9,1995.
However, the staff identified several items for which the licensee needs to take additional actions to resolve the 1
4 staff's concerns.
These items are summarized below.
1.
The concrete floor crack observed near the Unit 4 DC load center should be repaired (SSER Item 4).
2.
Better maintenan:e needs to be provided, especially, to steel components located outdoors, to arrest further degradation due to corrosion (SSER
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Item 4).
7 3.
Cushioning materials should be provided at t'n end and between battery 4
cells to preclude potential impacting for the station batteries (SSER Item 5).
4.
The licensee should institute and implement a strict housekeeping program to preclude the types of situations identified during the audit; e.g., electrical cabinet doors should be secured and locked with all of the fasteners provided with the equipment items (SSER Item 5, 10).
4 During the exit meeting held on December 8, 1995, the licensee's management acknowledged the items summarized above. The licensee ttated its commitment 4
to resolve these items. On the basis of the licensee's commitment to resolve these items, the original SER items are considered closed. However. "
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licensee's corrective actions will be followed and tracked by the NRC's
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resident inspector.
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4.0 CONCLUSION
S FOR ST. LUCIE UNIT 1 4
Based on the results of the Turkey Point Units 3 and 4 inspection, the staff determined that a separate inspection at the St. Lucie Unit 1 is not 4
i warranted. However, in addition to the general concerns common to these three units, the staff's February 9,1995, SER, identified two areas of concerns specific to St. Lucie Unit I namely 1) poor seismic housekeeping (Section 2.3) and 2) adequacy of safe shutdown tanks and heat exchangers (Section 2.4).
Considering that the SSE for St. Lucie Unit I is less than that for Turkey Point, and based on the resolution of the tank issue at Turkey Point, the staff considers the tank issue at St. Lucie Unit I closed.
With regard to the housekeeping issue, the licensee should institute and implement a strict housekeeping and maintenance program similar to that considered for Turkey Point Unit 3 and 4 (Items 2 and 4), to preclude the types of findings identified by the SRT and exemplified in the staff's February 9, 1995 SER. This SER item is considered closed; however,'the licensee's corrective action will be tracked by the NRC's resident inspector.
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13 On the basis of the above, all the original SER open items for St. Lucie Unit I are considered closed.
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