ML20199E486
| ML20199E486 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/03/1986 |
| From: | Ward D Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20199E404 | List:
|
| References | |
| FOIA-85-729 NUDOCS 8603270241 | |
| Download: ML20199E486 (56) | |
Text
UB64TED STATE 8 m3An REGuuTORY cOedtstm4088 4888081 Il 101 bdAABETTA STREEY* "'N' ATLANTA.880#88A3E3BB oerrissak suseossas DEfeAb7V POR PRIVATE 'O E' l
Honorable Nunzio J. Palladino l Chairman .-
U. S. Nuclear Regulatory Connission )
Washington, D. C. 20555 i
Dear Dr. Palladino:
SUBJECT:
ACRS COMMENTS ON TURKEY POINT NUCLEAR GENERATING PLANT, UNIT 3 AUXILIARY FEEDWATER FAILURE During its 305th meeting, September 12-14, 1985, the ACRS was briefed about the recent post-trip failures in the auxiliary feedwater system at Turkey Point, Unit 3. This plant has three supposedly independent and redundant auxiliary feedwater pumps. Nonetheless, during the event, two of these pumps failed and the third experienced a near-disabling com-ponent failure. . Clearly, the provision of auxiliary feedwater is a critical safety function.
Whatever the ultimate determination of the proximate causes of these multiple failures (and we acknowledge that the facts are not yet in),
this compromise of a major safety system is extremely disturbing. The event may well reflect, in the last analysis, a significant breakdown of the regulatory system.
We hope that exploration of the deeper implications of this event will be given very high priority. While we do not wish to prejudge the outcome, we do wish to convey our lively concern.
Sincerely, I
David A. Ward 8603270241 860106 Chairman PDR FOIA WEISS85-729 PDR
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}IST OF ARIILIARY FR uttATNI @
O .T.1Ed ' 72-25 Replace Ausilis,ry Few3 water Pumpe steam Supply Isolation Velves Descriptions Remove existing " Steam Supply to Auxiliary Feedwater Pump Turbine Drives" stop Valves 3-10 82, 84 & 86 and 4-10 82, 44 & 86. Replace with double valves (12 required) of suitable type, class and manufacturer other than Valan. Exteting Velas valves do not hold pressure thus cannot perform their isolation function. Implemented Yes i 73-73 Assiliary Feedwater Pump Steam Supply Valves Replacement Description Provides instructions for replacing the manual gate valves in the steam lines of the auxiliary feedwater pumps with globe non-return valves (3-10-094, 095 & 096). Impicaented Yes . 73-76 Auxiliary Teodwater Flow to #3 Condensate Storage Tank Descriptions This PC/M installs flanges, orifice and static differential l flow indicator in the, auxiliary feedwater pump recire. line l to Unit 3 condensate water storage tank. This is needed to ) perform performance testing on the auxiliary feedwater pumps and their auxiliary systems. 2 I.a.plemented e Yes
't 73-85 Ausiliary Feedwater Pump Auto Start Fuse Failure Alara Descriptions This change is proposed to add the Auxiliary Feedwater Fuay Auto Start circuit fuse failure to the exieting " Containment Isolation Cabinet A & B Fuse Failure" annuncistor circuit.
This will enable early htection of a power failurs ~ condition in the Auxiliary Feedwater Pump Auto Start Circuit, Implemented: Yes l OAs
aus 2a es asst: aae era p.a3 Pcsa 2 cf 10 LIST OF ADIILIARY FERDWATER PC/M's PC/M 30. TIEE 74-43 Auxiliary Feedwater Control - Installation of Check Valve in N2 388kuP system
Description:
Install check valves in each of the nitrogen headers of the nitrogen backup system for Auxiliary .Feedwater Control. Installing check valves on the headore, upstream of the N2 bottles header inlets, would prevent refilling of the spent N2 bottles in the opposite header and provide an uninterrupted' flow of N2 f8T C'#Cf81' Implemented Yes 78-104 Anziliary Feedwater Pump I.ube Oil Cooler
Description:
This PC/M provided a permanent fix to supply cooling water to the safety related auxiliary feed pump lube oil coolers from the second stage of the auxiliary feed pump and route the lube oil cooler discharge flow to the condensate storage tanks. Implemented: Yes 79-12 Removal of Auxiliary Feedwater Pumpa Recirculation Test Lines and Yalves Descriptions The Auxiliary Feedwater Syaces was provided with full flow recirculation test lines for pre-operational testing. These lines were causing water hammers due to valve leakages and since they were no longer needed, they were removed. Implemented: Yes i
QuG 20 '95 93.814 @@@ PTP p.@4 Page 3 of 10 LIST OF AUIILIARY FERDWATRE PC/N'e PC/m m.. .IIga 79-13 Esplace Auxiliary Feodwater check valves (downstream of control valve station) - (Unit No. 3) Description Replace ' existing auxiliary feedwater check valves (#140, 240, 340) due to degradation beyond repair and uncertainty of valve QC documentation. Implemented Yes 79-60 Auxiliary Feedwater Turbine Drain Modifiestion s Description This change / modification required the installation of orifices on ATW turbine drain lines: Casing drain and exhaust line drain. The change was necessary to allow removal of condensation during shutdown and to limit the steam flow during turbine operation. Implemented: Yes 79-68 AFW to Unit M Gate Yalve Replacement Description Replace the valves listed below with a more dependable valve. 4-141 4-139 4-241 - 4-239 4-341 4-339 . Implemented: Yes l
AUG 2a '85 033to 600 pTP .P.05 Pag') 4 of 10 LIsf 0F ABIILIARY FREDWATER PC/M's 7. 79-112 Modification of the Auxiltery Feedwater Flow Indication (Control Grade) - (Unit Bo, 3) Descriptions i This modification consista of connecting the existing auxiliary flow indication instrument loop into the nitrogen system back-up to the instrument air supply used for the auxiliary feedwater control valve instrument loop. On completion, the nitrogen system will have been expanded to back-up both instrument loops' air supplies. This expansion i of the nitrogen supply system will not cause any degradation ! of the-system integrity. Implemented: Yes l 79-113 Modification 'of the Auxiliary Feedwater Flow Indication '(Control Grade) - (Unit No. 4) Description On completion, the nitrogen system will have been expanded to back-up both instrument loops' air supplines. This expansion of the nitrogen supply system will not cause any degradation of the system integrity. Implemented: 'Yes , 79-122 Auxiliary Feed Pusp I3I Fressure Cage Isotallation
Description:
' ' This modification consisted 'in the installation of ISI pressures gages on the suction side of the auxiliary feed pumps. This was needed in order to perform monthly auxiliary feed pump tests.. Stainless steel pipe was installed from bottom of suction-line to the I8I gages.
Implemented: Yes
AUS 20 '95 03: 15 000 pip P.06 Fase 5 et 10 LIST OF AUIILIARY FREDWATER Fc/N's ec/w no. ILtl5, 79-124 Availiary Feedwater Pump Control Modification
Description:
This PC/M Hodified the Auxiliary Peedwater pump control circuit so that the pumps can be defeated from auto starting by overriding the pressure switch signal that actuates the pressure regulator. This will give the capability of running one pump-at a time since it is necessary, at times, to run only one auxiliary feedwater pump. This has been accomplished in ' the past by using the manual trip valves. However, these valves are not of the positive seal type and steam will leak through and slowly rotate the turbine. In the past this has caused the failure of turbine hearings due to inadequate tube oil pressure when rotating at slow speed. Implemented: Yes l l I 80-35 Auxiliary Feedwater Line Support Modifications - Unit 3 l Descriptions Pipe supports were modified for greater seismic load and thermal stress load capacity. This was done 'in re'sponse' to USNRC IE Bulletin 79-14. Implemented: Yes . l 80-55 Upgrade of Auxiliary Feedveter System Flow Control and Initiation (Unit No. 3) Description This FC/M provides redundancy for Auxiliakry Feedwater- Flow Indication, initiation and Control in accordance with the requirements of USNRC NUREG 0573. Redundant measurement and indication is provided for each auxiliary feedwater line. Automatic or manual initiation of the auxiliary feedwater system will initiate the flow control system. Implemented: Yes s
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;* Page 6 of 10 LIST OF ABIILIARY FIEDWATER PC/M's O E 80-56 UpSrade of Auxiliary Feedwater System Flow Control and Initiation Unit 4 Descriptions ; This PC/M provides redundancy for Auxiliary Feedwater Flow Indication, initiation and control in accordance with the requirements of USNRC-NUREC ~ 0578. Redundant measurament and indication is provided for each auxiliary- feedwater line.
Automatic or manual initiation of the auxiliary feedwater system will initiate the flow control system. Implemented: Yes 80-78 Modification of Feedwater Turbine Steesa Supply Valve D3scriptions Auxiliary feedwater steam supply valves NOV-3-1403 and MOV-3-1405 A.C. Motor Actuators were replaced by D.C. Motor Actuators. I The actuator shall consist of a actor driver, reduction gearing, handwheel drive and electrical terminal compartment housing the necessary torque and limit switches, a space heater, and a terminal block. l Implemented: Yes 80-79 Modification of Aux. Feedwater Turbine St. Supp. Valves, Description Auxiliary feedwater steam supply valves MOV-4-1403 and MOV-4-1405 A.C. Motor Actuators were replaced by D.C. Motor Actuators. The actuator shall consist-of a motor driver, reduction gearing, handwheel drive and electrical terminal compartment housing the ~ necessary torque and limit switches, a space heater, and a terminal block. Implemented: Yes 80-105 Auxiliary Feedwater Pump Turbiais Modification Descriptions This modification replaces the auxiliary feedwater low pressure turbines with high pressure turbines. Included with the turbines are the governor valves, trip, and throttle valves and associated instrumentation. t _ _
AUS 28 '89 03: 16 000 PTP P.08 Page 7 of 10 LIRY OF ABIILIARY FREDWATES PC/N'e FC/M 30. M 80-117 Upgrade auxiliary Feedwater Sustion. Discharge and steam supply
-Piping Descriptions This modification consisted of adding redundant steam supplies to the AFW turbines. The modification also replaced the auxiliary feedwater control valves and removed the following lines from the condensate storage tank discharge lines condensate make-up reject line, condensate recovery eyeten discharge line and condensate transfer pump.line.
Impleasateds Yes 82-57 Auxiliary Feedwater Pump "A" Turbine R41d-down Device Macription: 4 The hold-down stud on the southwest foot to base place support sheared during slignment. A hold-down device will be designed. to temporarily replace this stud. This device will consist of a welded bracket affixed to the pump base plate. 1 i Implemented Yes 82-85 Auxiliary Feedwater Pump "B" Governor Speed Increase Descriptions This FC/M temporarily increases the maximum speed of the pump from 5900 to 6100 RPM. r Implemented: Yes 82-198 Spare Auxiliary Feedwater Pump Rotating Element Descriptions Per N 2 request, JP1 will review spec for Spare Fusp Rotating Element to disposition subsititute asteriale proposed by
. Ingersoll land.
Implementeds NO
AUG ag *gg 33:17 000 p n> P,00 Page 8 of 10 LIST OF ABIILIARY FREDUATER PCht's PC/M 30. TI_Est 82-199 Ausiliary .Feedwater to Condensate Storage Tank Support Nodification Descriptiour Support modification for Auxiliary Feedwater to Condensate Storage Tank. Performed by Teledyne Engineering as per IEB 79-14 criteria.
- Implementeds Yes 82-230 Auxiliary Feedwater System Support . Modification Stresa Probles
# 057 Descriptions Support modification # 057 for the Auxiliary Feedvater System.
Performed by Teledyne Engineering as per IES 79-14 criteria. Implemented Yes 82-311 ) Replacement of. Ausiliary Feedwater Puay Turbine Steam Supply Stop Check Valves (Unit No. 3) Descriptions The Auxiliary Feedwater Pump Turbine Steam Supply stop check valves (numbers 10 119, 10-120, 10-219, 10 220, 10 319 and 10-320) are to be replaced by Pacific 3" valves. The original vendor (Walworth) was unable to provide a replacement valve that met the specifications; Implemented Yes 82-312 Replacement of Auxiliary Feedwater Pump Turbine Steaa. Supply Stop Check Valves - (Unit Wo; 4) Descriptions The Auxiliary Feedwater Pump turbine Steam Supply stop check valves (numbers 10 119, 10-120, 10-219, 16-220, 10-319~ and
' 10-320) are to be replaced by Pacific 3" valvee. The original l vendor (Walworth) was unable to provide a replacement valve '
that met the specifications., ' Implementeda Yes
l aus :s *89 esitP ese P T P- *.to Page 9 of 10 LIST OF ABIft'_A8T FREDWATER PC/It's PC/M 30. M , 83-049 AFU Piusp Turbine Governor Control 51ay11fication - Unite 3M l Descriptions This modification provides for the disconnection of the air supply s18nal to the Auxiliary Feedwater Fuay Turbine Covernors (Also called DFI valves). removal of the N2 back-up station l No. 2 and the removal of associated instrumentation. ) Implemented N0 l l l 83-067 Auxiliary Feedwater System Control Penel Descriptions l 1 This PC/M is a CPWO (Controlled Plant Work Order) which provides l for the replacement of the existing 6 1/4 AMP fuses with 10 l AMP time delay fuses. the original fuse is being upgraded to accomodata higher amperage and time delay action. l Implemented Yes l 85-045 Anni 11ary Feedvater CT Instrument Air Filtration Modification i (Unit No. 3)
Description:
This PC/M will provide modification for the Unit 3 instrument air supply to Auxiliary Feedwater Centrol Valves,' so as to add canister type filters in the supply line. Implementeds NO I 45-086 Auxiliary Feedwater CT Instrument Air Filtration Modification (Unit No. 4) Descriptions
. This PC/M provides the modification for Unit 4 instrument air supply to Auxiliary Feedwater Control Valves, so as to add canister type filters in the supply line. I Implementede No j
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aus 2a 'es asite aos era p.tt Page 10 of 10-LIST OF ADI!LIA1.T FEIDWATER PC/N'e PC/M 30. .T,jgg 85-110 Installation of Chainvbeste on AFW Discharge valves Description Modification provides for installation of chainwheels on the AFW (Auxiliary Feedwater) discharge valves (AFFD-006.- 007 008, and 3-141.- 241 -341). The addition of chainwheels on the discharge valves w!.11 allow the valves to be operated from the around level (valves are located 13' off the ground). Implemented NO - Design in progrees.
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Pcge 1 Ef 11 LIST OF PC/N's TEAT AFFSCT AFW SUPPORT SYSTEMS I.~ M E 73-9 Add New Battery Inverters
Description:
PC/M adds 2 new battery buses. 8 new inverters, 3 battery chargers. 2 DC Load Centers, 4 manual transfer switches new cabis, new inverter room. This change will preclude l unintentional safety injection of both units from occuring thereby, enhancing the safety of the system. Implemented: Yes 74-39 Power Feed Relocation on AC Vital Bus ) l
Description:
This PC/M involves the removal of non-vital loads from the vital bus and to reduce the maximum current of any feed to approximately 5A. All safety channels continue to receive pouer from that bus of original design. Implemented: Yes 77-453 Domineralised Water Storage Tank Foundations and Retaining Wall . Descriptions This PC/M s tovided a domineralised water storage and dameration system to espply the steam generator with deserated water during start up, shutdown, and hot standby operations. This included a water storage tank with a N2 blanket to prevent reabsorption. > Implemented: Yes l ! 78-87 Instrument Air Modification Descriptions This PC/M replaced existing instrument air dryers and filters which had less capacity than the existing compressors with new dryers and filters having greater capacity. The PC/M also added a new filter for the service ~ air system,> and relocated the connection of the normally closed contingency instrument air supply to a location downstream of the new service air filter. Implemented: Yes D /12.
, au3 23 '35 33:19 aaa ATA P.13 Fa33 2 ef 11 1
LIST OF PC/N's TRAT AFFECT AFU SUFFORT SYSTEMS _ j- ) PC/M No. TITIE l 79-543 Fire Protection System Upgrade (Civil) l Descriptions. This PC/M allowed upgrading of the fire protection system by installing curbs around auxiliary feedwater pumps, curbs underm ath the doors, fire doors, frames, and pertaining
-hardware.
Implemented: Yes 79-55 Access control for Auxiliary Feedvetor System Descriptione This FC/M added a phygigel berrier and a centrolled acetas poing to the Auxiliary Feedwater System. The purpose was - to ensure compliance with 10CFE 73.79(2). Implemented: Yes 79 89 Optional Connection For Unit 3 & 4 Instrument Air I
Description:
This FC/M consist of connecting a temporary ' a ckup compressor l to an existing outlet in the instrument air system. The original ; systes design provides the capability of such conneccion. Implenostede Yes a 80-77 Addition of Condensate Storage Tank Redundant Level Alarms
Description:
Redundant level alarus were installed in the condensate storage tank in accordance with the requirkenents of U8. NRC - NUREG 0578. Implementeda Yes e ,- ._, _ y- + . .-
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LIST OF FC/M's TEAT AFFECT AFU SUPPORT SYSTEMS FC/M No. M 40-121 Condensate storage Tank F1 pins and Structural Modification (Unit No. 3) Descriptions This modification consisted in converting the condensate storage tank to a covered gas tight tank. The reasons for the modification are as follows: i
- 1. Nitrosen blanketing and vent tank seal to keep water dearated and protect the condensate storage tank.
- 2. Structural base ring addition to withstand vacuus and vent tank nossle and dead weight loads..
- 3. Make-up water piping to vent tank and inside immersed overflow piping installation to maintain seal over nitrogen cap.
Implemented: Yes 80-122 Condensate Storage Tank Piping and Structural Modification (Unit No. 4) Descriptions This PC/M converts the C8T to a covered gas tight tank. To minimise aeration. the CST will utilise a N2 blanket. See PC/M 80-121 above. Implementeds Yes 81-034 Installaties of Nuclear Data Accounting System Descriptions This PC/M moved the Nuclear Data 6620 and 6685 computers into the new computer room and provided for their installation and interconnection with display unite, printers and detectors in the Chemistry lab and the AIMS cabinet which is part of the Post Accident Sampling System (PASS). Implemented: Yee i
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LIST OF PC/M'e TRAT AFFROT AFW SUPPORT SYSTEMS .- PC/M Wo. M 81-157 Addition of the Safety Assessenat System - Unit 3
Description:
Due to an NRC requirement, FPL purchased a safety assessment display system (SADS). This PC/M is issued to install the equipment which will provide the control room with a display of plant papaseters from which the safety status of operation may be determined las the control roais. The Technical Aupport Center (TSC) and Emergency Operating Facility (EOF). The display wo..d give advance warning to the operator of potential hasards. Impleasated Yes 81-138 Addition of Safety Asseassent system - Unit 4
Description:
Due to an NRC requirement, FFL purchased a safety assessment display system (SADS). This PC/M is issued to install the equipment which will provide the control room with a display of plant papameters from which the safety status of operation may be determined in the control room. The Technical Support i Center (TSC) and Emergency operating Facility (EOF). The display would give advance warning to the operator of potential hasards. Implementeds Partial 82-095 Fisher & Forter Transmitter Replacemost Descriptions . All Fisher 6 Forter. transmitters are being replaced by Rosemount transmitters. This is a generic change. Fisher 6 Porter no longer supplies instruments or spara parts for nuclear applications. Implemented: Yes
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LIST OF PC/M's TE&T AFFECT AFW SUPPORT SYSTEMS - M/H to. ,UE& 82-104 Mais steam System support Nodification outside containment (NS0)
Description:
Support modification (M80) for the Main Steam System outside containment. Performed by Telodyne Engineering as per IEB l 14 criteria. l I Implemented Yes l 82-125 Mein Feedseter System Streen Problem f(FW-7) ' j Descriptions Support modification #FW-7 for the Main Feedwater System. Performed by Teledyne Engineering as per IRB 79-14 criteria. Implementedi Yes 82-136 Main Steam System. Strese problem M 30. Descriptions Support modification IP M 30 for the Main steam System. Performed by Telodyne as per I.E. Bulletin 79-14. J Implemented Yes 1 82-186 Fisher & Forter Transmitter Replacement j I Descriptions i All Fisher & Forter transmitters are being replaced by Rosemount transmitters. This is a generic chan8e. Fisher & Porter no longer supplies instruments or spare parts for nuclear applications. Implemented: Yes 42-200 Main Steam System support Nodification Stress Problem $1C-11 Inside Costoimanat Descriptions . l l Support modification #1C 11 for the Main Steam System. Forformed ! by Teledyne Engineering as per 185 79-14 criteria. Implemented: Yes
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LIST OF PC/M's TEAT AFFSOT AFU SUP70sT ST31Bl3 PC/M Es. M 32-221 Main Feedwater System Support leodificaties Inside Containment stress Problem i FW-6 Description Support modification # FW-6 for the Main Steam System inside containment. Performed by Teledyne Engineering as per IEB 79 14 criterie. Implemented's Yes 42-223 Main Steam System Support Modification Inside Containment Stress Problem # IC-12 i i Descriptions Support modification # IC-12 for the Main Steam System inside containment. Performed by Teledyne Engineering as per IER 79-14 criteria. Impleasated: Yes i 82-282 Main Steam System Support Modification Outside Containment , Stress Problem i ks-1 Description l Support modification # MS-1 for the Main 8 team Systen outside containment. Performed by Teledyne Engineering as per IRB 79-14 criteria. 4 Implementeds Yes 42-296 , Standby Steen Cenerator Feedveter Pumping System
Description:
This modification will add piping, valves and pumps to function i as a backup emergency feedwater supply to the auxiliary feedwater - j ' pumpe. This' addition is based on Appendix R Fire Protection ! considerations. The location of the Standby Steam Generator Feedwater System will be south of the Unit 4 condensate Storage Tank. Implemented: Yes
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', Page 7 of 11 LIST OF PC/N's TEAT AFFECT AFW 80FFORT SYSTEMS 70/u Be. M 82-317 Additional Instr e t Air Compresser Descriptions A fourth Instrument Air Compressor (500 CFM In8erso11-Rand) 1 will be added to the existing systes. )
Implementeds Yes l 43-107 Isotrument Air Eseder Drain Trap
, i Deecriptions Hodification will install an automatic drain trap in the ~ common instrument air header upstrees of the air dryers. This provision !
will replace the existing manual valve no. 40-548. Implementeds No j 83-117 Replacement of 120V Vital AC Flant Inverters l Descriptions Twelve (12) 120V AC inverters will be replaced with qualified 7.5 EVA inverters and 8-10 KVA re8ulated transformers. This-modification is due to repeated failures of the inverters for the 120V AC vital instrumentation. Implemented No 83-123 Replacement of Safety Related Electrical Equipment (Unit No. 3) Descriptions This modification provides for replacement of unqualified
! electrical devices, solenoid valves, and position (Limit) switches with fully qualified devices as required by the environmental qualification rule 10CFR50.49. 1
. l Implementeds No l
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, ,aus :a as esi:: aaa are Fese 8 of 11 LIST W PChl's TEAT AFFECT AFW SUPPORT SYSTEMS PC/M 30. M 43-124 Replacement of Safety Related Electrical Equipment .(Unit i No. 4)
Descriptions
- Modification will provide for replacement of unqualified electrical devices, solenoid valves, and position (limit switches) with fully qualified devices as required by the environmental qualification rule 10CFILSO.49.
Implemmated Yee . 83-163 Auxiliary Feedwater UpSrade - Valve Maintenance Platforma j (Wait No. 3) l Descriptions This modification will provide for a permanent platform with access ladder from ground level. The platform design will include ramoval grating and a monorail system with hoist (supportet from the new platform) for ease in accessibility and mansaverability of the subject valves and associated instrumercation during periodic maintenance and calibration. Implemented: No 83-177 Domineralised Water and Deseration System Modification Descriptions Installation of a differential pressure (level) transmitter on the Dominera11:ed Water Storage Tank (DWBT) with level indication is to be provided on the main control board in the l Control Room. The PC/M provides necessary increased availability /realiability of the pleant in support of Units i 3 & 4 operation. Implemented No 84-001 . Modificatione to Qualify Limit switches per 1.97, Rev. 3. Descriptions Modifications will include addition of new qualified limit switches and/or replacement of existing limit switches (one for one) on the containment isolation valves. The new switches will meet the requirementa of NRC Regulatory Guide 1.97. Revision 3.
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} aus 2a e9 asias Page 9 of 11 LIST OF DC/N's TRAT AFFRcT AFW SUB9 ORT _ SYSTEMS MlM Emi .11E4 44-039 Service Water to Instrument Air compressor 4D Descriptions Insta11stion of service water supply itne to the new 500 SCFM l (standard cubic foot per minute) instrument air compressor '
to be used as an emergency back-up water supply. Implemented: Yes 84-047 Auxiliary Feedwater Isolation Velve Access Platform - (Unit Ee. 4)
Description:
Modification involves installation of a new platform to work hand wheels on the isolation valves. The platform was omitted in che originsi design. Plant maintenance has requested the platform be provided. Implementeds Yes 64-040 Feedwater Line Esducer Espair - Unit 4
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Descriptions Modification to provide for the methodology to correct the defect in the feedwater line reducer of steam generator 4A. Under this FC/M the 80 nosale extension is to be reduced in length to remove the counter bore region and 18" OD spool piece is to be inserted between the nossle and the new reducer the 6" spool piece will be used to provide smooth transition between nossle ID di the reducer ID and allow the elimination of standard counter-bores. Implenested Yes l 84-112 Instrument Air Noisture Trap
- Descriptions FC/M is a CPWO providing installation of a moisture trap just upstream of the Unit 3 blowdown instrumentation on the instrument air line. A manual drain is to be supplied with the moisture, traps if deemed necessary, en automatic drain can be provided later. A sight glass is to be provided on the trap to monitor any moisture accumulation which could cause inoperability of the affected equipment.
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LIST OF FC/M's TEAT AFFROT AFW SUFFORT ST87 ENS M85-009 M Addittom of FW Control Velves Direct Poettion ladication (Unit No. 3) Descriptions This modification allows for addition of qualified limit-switches and indicating lights for the main and bypass feedwater control valves to comply with NRC Reg. Guide 1.97. Implemented: Yes 85-010 Addition of FW Control Valves Direct Position Indication (Unit No. 4)
Description:
This modification allows for addition of qualified limit evitches and indicating lights for the main and bypass feedwater control valves to comply with NRC Reg. Guide 1.97. 1 Implemented No 85-033 AFW Fesp Area Fire Suppression System Addition i Descriptions - . l I This modification provides for the addition of a water
- suppression system to protect the Auxiliary Feedwater Pump area for compliance with Appendia R Fire Protection requirec.ents.
Impleasated: No - Design in progress. 85-075 Instr e nt Air Compressor Regulator Drain Traps Description PC/M is a controlled plant work order (CPwo) which will allow for installation of automatic water drain traps in the 48 instrument air compressor regulator inlet air lines to' enhance
. performance and reliability of the compressor and the regulator.
The drain trape are necessary to ensure dry operation of the regulator. Implemented: No - Design in progress. I .! \
aua :a se a:::s aae era p.22 l Pasa 11 cf 11 )
. . l LIST OF PC/M's TEAT AFFECT APW SUPPORT SYSTEMS i
i PC/M 3e. TITLE l 85-122 Safe Shutdown Modifications - Appendia R - (Unit No. 3) l l Descriptions This PC/M will provida circuit and equipment modifications for the changes identified as a result of safe shutdown system i analysis. l Impleasated: No - Design in progress. 85-123 Safe Shutdown Modifications - Appendia R = (Unit No. 4)
Description:
This PC/M -will provide circuit and equipment modifications for the changes identified as a result of safe shutdown systes analysis (Unit 4 and common). Implemasted: No - Design in progress.
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L4 Response to NRC Findings Auxiliary Feedwater System Turkey point Point l Finding III.C.1 l PCM 80-77 was reviewed by the team. This modification package ' installed redundant instrument strings to provide safety related condensate storage tank level indication and as alare 20 slautes prior i
- to needing another source of water for the ausiliary feedwater pumps, i The team determined- that the implementation of this design change failed to ensure that it met the single failure criteria.
i specifically, the level tranaeltters for redundant level indication are , connected to a common lastrument tap from the condensate storage tank. ! The common instrument tap has a normally open isolation valve (Valve ' 428) which could be mistakenly closed by an operator causing common mode failure of the level instruments. No valve position indication was provided to alert the operator of incorrect valve position and no administrative controls (such as locking the valve opes) were applied to ensure that the valve remained opea. As a result of the inspection concern, the licensee checked opes isolation Valve 428 and installed a locking device. Revision of !l appropriate valve lineup sheets and plant drawings will also be required. This ites will remain an inspector followup item (50- ' 4 250/8531-83 50-251/8532-8). l j Resposises , The failure to note the valve to be locked open resulted from aa assumption on the part of the designer that the valve, which was
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existing and had to be open to ensure the functionality of the original' level treaseitter, had been previously administratively controlled. The root cause of the problem was a failure to review the operating procedure and coordinate the design with plant operations. Since the time this design was performed, engineering has established se i Operations Coordinator position to assist in coordinating design
- modifications with the plant operations group and is now on distri-bution for operating procedures. Additionally, a PCM review process is l now in use which includes plant operations review of PCNa prior to I
I their issue. This process will provide an additional check that this type of error will not occur. The associated design documents for the valve are in the process of being updated t:o show the locked opea valve, and the valve has been physically locked open. i l FOR IN 0RMA"ON ON.Y. l , b/12
Response to NRC Findings Auxliary Feedwater System i Turkey Point Project i i l Finding III.C.2.as ! PCM 80-117 was reviewed.- The Laplementation of the design control l process for this modification did not produce a documented analysia l substantiating the design adequacy of the nitrogen system. The team i found that a design analysis was not performed by techtel to confire that the design change was acceptable. The team was informed that 3sentel reviewed the original design analysis and-confirmed that the asw design was bounded by that calculation in lieu of a new design analysis. No evidence existed documenting this engineering judgment. The team was informed that the existing calculation was considered bounding because the new components had a lower nitrogen consumption rate. The original design analysis was performed la 1972 and had l consumption rates for components which entsted in the original control ! scheme and which were subsequently replaced with new components by PCN : 80-117. The calculation had no indication of a check or verifiestion. Likewise, the sources and nature of the consumption rates were not , identified. During the faspection, Bechtel could not determine if the 1 values in the 1972 calculation represented steady-state conditione or . consumption rates reflecting sees assumption for valve modulation and '. I l component leakages. Rechtel cited information from a vendor technical 1 manual which indicated that the new valve actuators have a lower
- steady-state air usage value of 0.26 scfe per valve, rather than the !
! 1.0 ocfm per valve used in the enf ating calculation. The valve
- j actuators are diaphrase actuators with a balance positioner constantly
! exhausting air through a detecting nossle. Sechtel pointed out that * [ only three actuators are being supplied by the one nitrogen cylinder on line instead of six per the original design. Thus, techtel j concluded that the original design analysis bounded the new design. l By inspection, the tese could not arrive at the same conclusion for l the following reasonas
! o The taas destrained that the steady-state air usage value of 0.26 ocfm was based upon a vendor test of a eleitar, but not i identical valve positioner. The vendor test wee conducted with i
an air supply pressure of 60 poi instead of the einimum nitrogen supply pressure of 80 psi furnished by the installed nitrogen system regulators at Turkey Point. As a consequence, the
; steady-state air usage value can be espected to increase. , During the inspection, Sechtel indicated that a linear entrapolation wee a reasonable assumption. Therefore, the ,
I steady-state consumption rate approachee 0.36 safe (i.e., Increased by a factor of 80 psi /60 psi). 0R .N:0RMATl0N ON.Y s
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- Finding III.C.2.a page 2 of 3 o The assumption of instantaneous steady-state operatione does not appear to be consistent with the aa-designed valve response (i.e., upon actuation the valve cycles full opes and then closes
! towards the 125 spe flow setpoint). H e vendor's technical literature indicates that high operating speed is achieved with vi'rtually no overshoot uhen approaching the final plus position. ) Although a designer eight choose to assues a leak tight system with periodic testing to confirm thle assumption, it appears unreasonable to conclude that no valve modulation la required and that a steady-state condition is reached immediately. The team was informed that the operatore typically take the flow control valves out of automatic control and place them in remote ! manual control immediately after en availlary feedwater flow to } malatain steam generator level. The team wee informed that thie ) operator action resulte la elimination of control valve modula- /. tion except for the initial valve cycle. Bowever, the team f determined that the operators were not required by procedure to take remote manual control nor were the operatore directed to do so by existing management guidelines or training. Consequently, the team concluded that the licensee's assumption that operatore , would immediately take remote manual control of the flow control
- l valves (and thereby reduce the valves' air usage rate) was
! unjustified. In addition, the tese found no periodie testing performed on the nitrogen systes to confirm its leak tightness and instead observed a ayeten with significant leakage rates. o The minimum available volume of nitrogen is higher in the original design analysis than prescribed in the systes design description. Specifically, the original design calculation uses a minimum values based upon 1005 pois in the cylinder, and the , system description indicates a minimum volume based upoa 500
- peig. This reduction can, in part, be explained by the reduc-tion in the assumed time the operator has available to valve in a new nitrogen cylinder. The original analysis was performed
- with a design basis of operator action within 15 minutes of l receiving a low nitrogen pressure alarm, wheroes, the current systes description specifies 10 minutes. This time reduction i
does not appear to be based on a documented analysis of the actione required of the operator to recognise the alarm, analyse the appropriate response, send another plant operator to the ; j nitrogen cylinder and valve in a second nitrogen cylinder. (See l , operations and surveillance observation 1 for further l i discueston.)
- 0R IN 0RNA"ON ON.Y l
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1 l*. I Finding III.C.2.s Fase 3 of 3 o The original altrogen system design bases included a requirement , that the stored volume of nitrogen be able to permit system i operation for 2 hours assuming that all five altrogen cylinders
- were full.' A similar requirement for the current system does not appear to be addressed. This does not appear to be coa-I sistent with the licensee's commitment to have at least one AFW i systes pump and its associated flow path and essential instru-maatation capable of being operated independent of any AC power i
source for at least two hours (SER related to Amendment No. 75 to operating License No. DPR-31 and Aasadesat No. 69 to facility operating license No. DPR-41). l Easponset , A cateulation for the nitrogen consumption rates for the nitroges
; back-up supply system have been completed and revised setpoints for l the low pressure alarms have been developed. The plant is now in the I
process of impleasating the revised setpoints. The setpoints are considered as interim since once the valve oscillation problem is resolved, the nitrogen consumption rates will decline. Recommenda- 5 tions,for the number of nitrogen bottles to be perussently lasta11ed to support 2 hours of operation have been developed based on a l calculation, and are under review. It is important to note that the j design process which split the altrogen bottles into separate traine l would have been adequate had the Auniliary Feedwater flow control ' valves not developed an oscillation problem, whose root cause was not - associated with the original modifications under PCN 80-117. l l
! FOR IN!0RMA"10N ON.Y 1
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l Response to NRC Findings ) Auxliary Feedwater Systen Turkey Point Project l Finding III.C.2.b ' The team found that a design analysis did not exist to document the setpoint selection for pressure switches used to alert the operator via control room annunciation that ten sinutes of nitrogen remained before loss of motive and control power to the AFW flow control valves. Instead the team was informed that the setpoint reduction from 1005 pois to 500 pois for the pressure switches was established by testing performed under Temporary Procedure 045 on Natch 1,1934. This test appeared to have been performed prior to the splitting of , nitrogen system into two redundant trains but after addition of the new flow control valves and actuators. The test was performed with one nitrogen control cylinder supplying all six flow control valves with the valves in a full open position. Placing the valves in a full open position causes the air usage to be in a steady-state condition. Because the nitrogen pressure decayed the last 500 peig in 15 minutes, the low pressure alars was set at 500 peig. This setpoint was selected based upon a steady-state test without consideration of instrument error and without compensation for that pressure at which the flow control valve can no longer modulate (approxiestely 30 pais I per manufacturer information). The issue is safety significant because incorrect setpoint selection could result in the premature loss of nitrogen pressure and closure of all auxiliary flow control valves. Responset As noted previously in response to Findings III.C.2.4 and III.C.3, a reenalysis of the nitrogen back-up systen has been made, based on conservative assumptions, which has revised the low pressure setpoint to 1350 poi in order to ellow a minimum of ten sinutes of automatic operation without operator action. The low pressure alarm will be reset in the field based on this revised setpoint, and the appropriate design documents are being revised. I t FOR IFORMA"LON ONiY. l
j Response to NRC Findings
- Aus11ery Feedwater Systee i Turkey Point Project i
Finding 111.C.2.cs T The design verification process failed to ensure that appropriate l quality assurance requirements were specified for nitrogen system { components. Riectrical and 16C equipment associated with the nitrogen
, system were not identified as safety-related in FPL's Q-List. As a
{ consequence, the pressure switches used to alert the control room
- operator of low altrogen pressure and the need for fusediate operator
; action were not being treated as safety-related by the site 1&C group.
The AFW system design description Identifies the AFW eystes as sa j emergency safeguards 'systes to prevent core damage la the event of transiosta such as a loss of normal feedvater or a main steam line { i break. The nitrogea systes is essential to operation of the availlary - feedwater flow control valves and, as such, the altrogen system serves l j a safety-related function. FFL quality Instruction JF5-q1-2.3A, l
! "Claselfication of Structures, Systems and Components", indicated ther.
the mechanical equipment but not the electrical and instruenuation asA l control equipment associated with the nitrogen system were a=*etv- ) related. The team was informed that a more detailed component level !l Q-List was being developed and that this list indicated the pressure i , switches were safety-related; however, this list had not been issued ) by engineering at the time of the inspection, and the 1&C group was i unaware that the safety classification for the pressure switches had j changed.
- 1 l It appears that, contrary to the requirements of ANSI N45.2.1 section 6.3, the design verification process for the Q-List and the design modification did not ensure that equipment performing a safety-related !
function were designed, specified, and maintained commensurate with ) that function. This ites will reasin unresolved pending followup by l the Region II Office (50-250/8532-93 50-251/8532-9). ! l i Reaponse l t i FPL recognises the concerns raised by the NRC regarding the esfety l classification of the nitrogen system components. However, the desiga ) modifications for the Ausliary Feedwater System utilised the pressure switches and annunciation system installed under the original plant l 4 construction, which were neither designed nor maintained as nuclear I safety related. As a result, the classification of these eesponents was not changed from the original design basis of the plant. The - elassification of these components is currently under review by FPL, l and will be reflected in the updated Q-List. l E0R JN:0RMATl0N ON Y
Response to Ntc Findings Ausliary Feedwater System Turkey Point Project Finding 111.C.2.d Implementation of the design change process for this modifiestion did not produce a design analyses to confirm that non-safety composesta of l a systes do not adversely affect the safety function of the system. Although not identified in the system design description and desiga bases documsat for the auxiliary system, steem vent valves were provided to vent steem when the system is not operatias. The valves are sisaaled to close on increasing steen pressure (laeressing steam ! pressure indicates that ausiliary feedwater system has initiated) and to open upon decreasing pressure to vent the steam lines between the steam admission valve and the auxiliary feedwater pump turbines. The steen vent valves are outside of the seismic boundary and are treated as non-safety related. In reviewing PCN 80-117 this doissa feature was enemined and the fo11oving observations were made. 1 o Design analysis does not eniet to document the cosaequence of a failure of the vent valves to shut and the ability of the auxiliary feedwater pump to supply sufficient feedwater flow at , l reduced steam generator pressures to reach the point of Residual
- j Rest Removal System operation.
o Design analysis does not exist to document the setpoint selection for pressure switches and the error band used to
- control the operation of solenoid-operated steam vent valves.
l The setpoint was verified to be at 150 paig which would pernic
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the valve to opea automatically before the cooldown has been transferred to the Residual Reat Removal System. The lack of a design analysis in the cases cited above in subpara-graphs a, b, and e appears to be contrary to the requirements of ANSI l j M45.2.11 sections 4.1 and 4.2 which requires that design analyses be l performed in a planned, controlled and correct aanner and that there
- exist traceability from design input through to design output. This item will remain unresolved pending followup by the Region 11 office
- (50-250/8532-10s 50-251/8532- .10). . _ _ . _ _ _ _ ,
- Raeposses
- An analysis was performed of the effects of a toes of the steam vent valve at low pressure conditions which verified the operability of the Austiary Feedwater system. This confirmatory analysis substantiates the original engineering judgement used as a basis for the design.
4 E0R N 0RMATION ONLY e
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n, I . \ l Finding III.C.2.4 Page 2 of 2 The engineering procedurse will be revised to provide better guidance on the use and documentation of engineering judgement. The setpoint for the opening of the steen vent velve is also being reviewed, however, it is important to note that the present setpoint will not result in a loss of function of the Auxiliary Feedwater System. 4 i 9 l i FOR N 0RMATON OLY
Response to NRC Findings Avaliary Feedwater System Turkey Point project Finding III*C.38 ' During the review of PCN 80-117, the team observed nitrogen system tubius which did not appear to be seismically supported and instances of broken supports. This tubing was routed from the nitrogen cylinder racks to the flow control valves and included origine1 tubing as well as new tubing. The team was informed that this lack of adequate seismic supports was known by the licensee as documented la REA TpW. 85-30. In a March 7,1985 letter, the licensee directed Rechtel to walk down the system in the field and determine if the tubing ~was actually supported in accordance with Bechtel's desiga specification for seismia Class I tubing supporte or la accordance with the original aeismic design specification. Da July 19, 1985, in response to this request, Bechtel reported that most of the 3/8-inch tubing wee lastalled la accordance with techtet specificatione but with two tube spans greater than that allowed. found to be acceptable as installed.These deviations were evaluated and With respect to the old tubing in the rest of the system, techtel identified that the configuration was ditforent than origlaally accepted by project Engineering. Bechtel evaluated the configuration using the functionality criteria I developed to justify continued operation in response to IR Bulletin 79-014. The sechtel analysis determined that the tubing must Se supported at 27 inch maximum intervals to meet final design require-ments for long ters operation. The licensee Informed the tems that correction of this nonconforming condition will be performed during the next refueling oucase. This ites will remain an inspector fellow-up ites (50-250/8532-11; 50-231/8532-11). Reepense: All instrument tubing associated with the nitrogen system was walked down by Bechtel in July 1985 in response to concerna raised by plant personnel. An engineering evaluation of the existing tubing configuration and supports has identified the need to repair certain supports which were not installed in accordance with the accepted standards, as documented in NCE 341-85. These repairs are currently in progress during the mini-outage on Unit 3 and will be made during the next available outage on Unit 4. E0R INF.0RMALON ONLY. I
Response to NRC Findings Austlary Feedvater Systen Turkey Point Project Finding III.C.48 The tese found that design calculations were not being updated by FPL to reflect current modifications. The taan was informed that design inputs were maintained so that, if required, the calculations could be recreated. The team found that design criteria docuesses did not exist and that design bases were, in many instances, difficult to retrieve. This condition was further compilcated by the controls Bechtet maintains over calculations performed by Sechtet. The team found that Bechtet had a set of original project design calculations which were used for reference purposes but not updated. For current design activities, Bechtet maintained design calculations and updated those calculatiosa as plant modifications were assigned to their design resonsiblity by FFL. As a conseguence, it was difficult for a Bechtel or FFL engineer to know wher's applicable design analyses were to be found. Further, the team observed a lack of attention to documenting assumptions, justification for their use, and confirmation that the assumptions were accurate af ter the design had proceeded. Likewise, the team found that the source of input data was not consistently design documents but the FSAR or uncontrolled Flant Data e looks. l l Responset Both 3echtel and FPL have recognised the need to maintain control of design calculations for references by both organisations in support of system analyses or design modifications performed by either group. This issue is not unique to Turkey Point, and in fact, has been dicussed on a generic basis on several occasions between Bechtel and the NRC. In recognition of the NRC's concerna as raised specifically to Turkey Foint, FPL and Bechtel have initiated an in-depth review of the existing quality progrees relating to the preparation and control of design calculations. Revisons to these programs will be imple-mented to ensure that current design analyses and calculations are controlled and available to both organisations.
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IOR N 0RMA"ON ONL1
Response to NRC Findings
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Aux 11ery Feedwater System Turkey Point Project Finding III.C.4.at During the inspection the tese observed errors in design documents (e.g., calculations, drawing and. specifications) which do not represent, in themselves, inadequate designs but reflect a need for more attention to design traceability. For example: Seehtel calculation M-08-093-02, Ausiliary Feedwater System Control Valve Sising, Rev. 1, July 31, 1931 did not identify the source of assumptions and input data such as main steam safety valve setpoints, relief valve accumulation . auxiliary feedwater pump flow, and pump discharge pressure. The calculation made a general reference to FFL's Turkey Point. Unit 3 and & Plant Data Book, Volume 1. Although this document is not a design document, it appears that it was used-as a source document for design input.
Response
The use of the Plant Data Book was inappropriate as noted in the ' finding. The Plant Data look was referenced as a matter of l convenience even though the design inputs had been verified through - the use of appropriate design input sources.. However, there was a failure to doeveent these additional sources. Calculation M08493-02 is presently being revised to reference the correct design input - sources. Also, it is important to note that the design inputs have been verified to be correct and the conclusions of the calculation are - valid. In recognition of the NRC concerne in this area, the engineering procedures are currently being revised to emphasiae the use of proper design inputs when performing calculatione, and to provide proper reference to all design input documents. E0R LN!0RMATON ONLV. l
Response to NRC Findings Auxtlary Feedwater Systen
, Turkey Point Project Finding III.C.4.br - Sechtel Drawing 5610-F-151, Piping Isometric Auxiliary Feedwater Systen Fump Discharge, Rev. O, November 1,1981, had incorrect valve weights shown for AFW valves CV-3-2818, CV-3-2816, and CV-2-2817. The team confirmed that the valve weights identified on the vendor velve drawing were on Bechtel Drawing 5177-162-F-323, Rev. 1, dated May 16, t
1983, and that these weights were used in the piping stress analysis. [ During the inspection, FFL initiated an guternal Request for As-guilt Verification and Document Review to correct the identified discrepaa-cies in the Bechtel isometric drawings.
Response
We have reviewed the design process by which the velve weight for the original valve was accidentally left on the drawing. The procedures for document updating and turnover have been revised since the time of this modification and we are confident that the present design process , would prevent the recurrence of this type of error. The stresa > analysis was performed originally with the correct valve weights, therefors, the' error was limited to an administrative update of the ' drawing. 1 FOR LN:0RMA"'ON ON_Y
Response to NRC Findings Auxliary Feedwater System Turkey Point Project Finding III.C.4.cs
- Sechtel calculation M-48-093-03, [uniliary Feedwater Flow at Minfaus Steam conditions, Rev. O, May 4,1982, references FFL Flant Data look, sections 5.6 and $.7, for pump performance ratings. As stated above-(subparagraph a), the Plant Data Book is an uncontrolled document and is not considered a suitable source for design input.
Responses As stated in the response to Finding III.C.4.a, the Flant Data Book was not an appropriate design input source and Cateulation M08 093-03 is presently being revised to note the correct desiga laput documents. It should be noted that the inputs referenced to the Flant Data look were independently verified through other controlled design documents when the calculation was originally performed, and the results of the esiculation are considered valid. Also, as stated previously, the use of proper design input documents will be clarified through revision of the appropriate engineering procedures. $ 20R N:0RMATl0N ONiY.
Response to NRC Findings Aux 11ary feedwater Systes Turkey Point Project Finding III.C.4.dt FFL calculation, Low Level Alarm on condensate Storage Tank, dated ) November 15, 1979, does not identify all of the assumptions and design ) inputs used to perfore the calculation. The calculation was performed j to establish the alarm setpoint alerting the operator in the control j room of the need to provide makeup water or transfer to an alternate j water supply in order to prevent a low pump suction pressure condition from occurring. The toes found no evidence in the calculation that the properor considered the NFSR required to maintain AFW pump operation. Instead, the preparer appeared to have' assumed that the minimum NFS5 would be below the instrueest tap, because the analysis l calculated the height above the instrument tap which corresponds to 20 i sinutes of water at a usage rate of 600 gym with a 10% factor for conservaties. The team independently confirmed that the NFSR is well below the instrument tap sad the design is not deficient. Wowever, the calculttien did not document assumptions nor identified those assumptions that required verification as the design proceeded. The 1 calculation did not define the design bases and their sources. FFL , procedu'res in place at the time this calculation was performed ' required a design analysis to contain this information (quality Instruction 3FF-QI-3.1, Control of RFF Design, Rev. 2, October 9, l 1979). Reaponse: Engineering has found evidence on the microfilm records which indicates that NFSB was considered in the original calculation. However, this consideration for NFSE was not documented in the FFL calculation dated November 15, 1979. A calculation was recently performed _to confirm that the required NFSR water level is below the instrument tap level as assumed in the original calculation. 0R LNFORMATION ONLY . 1
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Response to NRC Findings Aux 11ery Feedwater System Turkey Point Project , finding III.C.4.e techtel Drawing 5410-N-339 sheet 1 of 1, Rev. 15, incorrectly shows ' that the nitrogen system pressure Control Valves FC-3-1706, PC-3-1704, PC4-1705, and PC4-1709 were set to provide 55 peig. These_ pressure control valves were set for 80 pais. l I
Response
The pressure control valves were originally set at 55 pais based on the original design in PCN 80-117. Although this setpoint was acceptable based on vendor confirmation, FPL revised the setpoint to 80 peig to agree with the normal specified operating range for the valve as defined on the control valve data sheet. Due to as administrative error, this change was not incorporated on the refer-enced deswing. However, it should be noted that the change in the control valve setpoint does not have any impact on the systes desiga or operability. The referenced drawing will be revised. i l l 1 20R INFORMAT ON ONLY.
1 Response to NRC Findings Aux 11ery Feedwater System Turkey Point Projecte Finding III.C.4.ft The AFW System Description and. Design Bases document dated January 31, 1965 had the following errors. o The system description stated that an air signal is supplied by a differential pressure controller which is set to maintain a , minimum pump discharge pressure approximately 120 poi higher than the steam supply pressure. As observed during the inspection, this design feature had been disconnected (see Operations and Surveillance Observation 8).
/
o The systes description in' correctly stated that when instrument air pressure drops beled 55 pois (nitrogen regulator valve outlet pressure), check valves open to automatically supply backup nitrogen. As stated previously, the pressure control valves were set at 80 peig. o The systes description incorrectly stated that the low pressure , nitrogen alarm will allow about 10* ainutes for the operator to - get to the station, close off the first bottle and cut in Bottles 2, 3, and 4, which will each provide about a 30 minute supply to the flow control valves. This description appeared to refer to the intended operation of the nitrogen station before the station was divided into two trains with three bottles in Train 1 and two bottles in Train 2. The described action would violate the single failure criterion. Responset o A review of the design basis document indicates the acknowledge-sent that the differential pressure controllers have been removed (Fase 4, Paragraph 4). o The system description and design basis document will be revised by October 31, 1985 to reflect this correction. o The bottles in the nitrogen racks are labelled 1 through 5 with Bottles 1 and 5 normally valved in (oaa per train) and Bottles 2, 3, and 4 as. standby. Traia separation remains in effect when the standby bottles are valved in. FOR INFORMATION ONLY
4 Response to NRC Findings Avallery feedwater Systes
, Turkey Point Project Finding 111.C.S.at PCMs 80-78 and 80-79 vere reviewed. These PCMs addressed the diversity of the power supplies to the steam admission valves of the auxiliary feedwater systes. . The stees supply for the musiliary feedwater pump turbines is developed in the steam generators and fed to the station common auniliary feedwater turbine pumps through six steam lines associated with the six steam generators (three stone generators per unit). 8ach stema generator is isolated from the steam header with a normally closed motor-operated gata valve. These valves are powered from a safety-related power supply (two motor-operators per unit are DC powered and one is'AC powered) and will automatically i open upon an . auxiliary feedvater initiation signal. Downstream of these stesa admission valves, steam vents are provided to vent off steen that may leak past the isolation valves. The following observations were made during the review.of the modification packages
- a. The modification of the motor-operators on the steen supply valves involved the purchase of new DC motor starters. These motor starters were specified and purchased by Material !
Requisition 3177-56-E-818-4. These starters were to be suppplied complete with motor overload heaters compatible with Limitorque operators. The team reviewed the motor starter vendor's drawings to determine the overload heater size supplied and to verify that the type of overload heater installed agreed with the drawing. In response to a teen ' request for criteria and the calculation used to determine the sine of the actor overload heater needed to protect the steam supply valve motors, the licensee produced a preliminary, calculation 5177-462-3-02, prepared on September 6, 1985 (i.e., prepared during the inspection), to demonstrate that the as-installed motor overload protection would not trip the valve motor for continuous currents below 9.19 amperes. From inspection of the actor nameplate data, the team determined that these DC actors are $ ainute duty rated motors and the full load current is 6.5 asperes. This results in a trip point 140 percent of full load current. The team independently determined that the setting of the overload devices provided inadequate overload o'r stall protaciton for the motor-operatore. The team also confirmed this conclusion with the motor-operator vendor's engineering department. FOR N:0RMATON ONLY
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. l Finding III.C.5.at Fage 2 of 2 The team's'concere,was that the motor insulation could be damaged during normal plant operations or periodic testing because of inadequate overload protection. This could result in the inability of the DCbasis design motor-operated event. valves to perform their safety function during a In an attempt to determine the generic implications of this issue, the team requested the techtel criteria used to determine the overload protection supply line.for No the existing AC motor-operated valve on the third steaa ~
basis for selection of the overload protection of ,
' these motor-operated valves at Turkey Point was provided during the inspection. l' The failure of the design organisation to verify the adequacy of the overload protection specified for the DC motor-operated valves is .
contrary to ANSI N43.2.11-1974 Section 6.3 which requires that specified parts and equipment be suitable for the required appli-cation. This ites will rossin unresolved pending followup by the Region II Office (50-250/8332-12; 50-251/8532-12). Response ! 1 An independent evaluation of the overload heater size has been performed by the electrical department technical staff. The Overload Reater Calculation 5177-462-E02 will be revised to incorporate the technical staf f coassents with a subsequent review and approval cycle.
' The present position, based on Turkey point Plant original design, and problema inherent with overload heaters as described in NRC Regulatory Guide 1.106, is that the overload heaters are acceptable as presently installed.
EOR IN!0RMA1N ONLt.
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' Response to NRC Findings Aux 11ary Feedwater System Turkey Point Project i Finding III.C.5.b:
1 Implementation' of the design change process failed to verify that the design change did not violate the original design function. The proposed cable routing for Motor Cable 4D0123Q from Motor Starter 3N1403 to steas Valve M0V-3-1403, as shown in the cable and raceway schedule, was 73 feet of 5 conductor AWG ~12 wire. The team requested the sising critaria and supporting calculations that would indicate that the conductor sise was sufficient. During the'second week of the , l inspection the licensee produced a calculation, dated geptember 10, l 1935, with no calculation number file identification. The calculation was prepared during the inspection and appears to have been performed in response to the team's concerns about the adequacy of the wire j sise. j No earlier calculation could be located at techtel's offices i either on site or in Gaithersburg, Maryland. The esiculation used as-insta11ed cable lengths obtained froe sechtel's 5177-t-45C glectrical Circuit Schedule and motor data from the Limitorque data sheet. Although this motor data did not agree with the motor namepiste full load current, its appilcation in this calculation was judged to be conservative by the team. The calculation demonstrated that the cable's ampacity and short circuit withstand espebility were adeguate. However, the calculation stated that the cable resistance was ~ sufficiently low so that the voltsgo drop was not a concern because voltage at the worst case valve (MOV-4-1403) would remain above 96 volts DC. The team questioned this conclusion because Bechtet had failed to consider starting current. The team contacted the actuator manufacturer directly and confirmed that starting current and the resulting voltage drop to the motor must be considered because the valve was tested with only 90 volts DC as the minimus starting voltage. To assess the effect of starting current, the team substituted the published 53 asperes lockad rotor current obtained from the Limitorque data sheet for the 3.caperes full load current used in the 3echtel calculation. The team determined that the of voltage voltage 90 volts would for Mov-4-1403.be less than the required minimum starting The team is concerned that during a loss of of fsite power and the resulting DC-systaa voltage drop, inadqueste voltage would be available at the motor terminals resulting in a stall condition and a failure of the DC actor-operated valves to perfore their safety function. E0R LNE0RMAT10N ON Y. j 1 l l .l l l 1 l
Finding III.C.S.b Page 2 of 2 The failure to adequately understand the requirements of the original design and to confirm that those requirements were met with the new . design is contrary to ANSI M4$.2.11 Section 6.3 and 8.2. This itse ' will reasin unresolved pending followup by the Region II Office (50-250/85-32-13: 50-251/s532-13). ' i Rasponses j e : Calculation 5177-462-201 has been prepared by the project desigs teen / and reviewed by the home office electrical department staff. This / i calculation concludes that the presently installed cable size is ' adequate. The calculation will be revised in accordance with the f electrical staffs coments to more adequately demonstrate the cable's acceptability for use. After revision by the project design team, j
/ t another review and approval cycle will be obtained through the home l office technical staff. '
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Response to NRC Findings Aus11ary Feedwater Systes Turkey Point Project Finding III.C.5.c The control circuit schematic for the DC and AC actor-operated steam isolation valves shows that the control switch used in the cirucit is a assentary open/ closed return to normal control switch. As a consequence, this switch will not stop the valve from automatically reopening following an operator's attempt to shut the valve as long sa e auxiliary feedwater initiation signal is present. The licensee had not ecognised this design feature (see Operations and surveillance Observation 1.d for further discussion).
Response
Emergency Operating Procedure 20003, Steam Generator Tube Rupture, is. being revised to provide correct operator guidance for the isolation of the steam supply from the affected steen generator. It la ihportant i to note that control logic for the motor operators was sa original plant design feature and was not modified'by the PCNs for the ,, Ausiliary Peedwater Systes. The error occurred due to a misinterpre- i tation of the control logic for the motor operator by the procedure writer. - 1 l 1 i 20R NFORMATION ONLY
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Response to NRC Findings Austiary Feedwater system Turkey Point Project Finding III.C.5.de FCN 80-117 added a second steam vent valve between the steen admission valves .and the ausiliary feedveter pump turbines. The original header desiga contained an air-operated, DC solenoid controlled steam vent valve whose purpose was to vent steam that any leak by the no.mally - closed steam admission valves. The vent is normally open and closes when the DC solesold is energised through a pressure interlock. ifhen the steam supply header was separated into two headers, an additional vent valve was added. The solenoid for this new valve must be energised to close the valves however, the valve was powered from an AC source. The team is concerned that on a loss of AC power the open vent on the Train 2 steam header will result in a path for steam loss.
Response
The design basis for the new vent valve was non-safety related and the design was consistent with the design basis. As discussed in the response to- Finding III.C.2.4, a detailed analysis was performed which ,i verified the ability of the esiliary Feedwater System to operata at low steen pressure conditic.>s with the loss of the vent valve. . I 1 i
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Response to NRC Findings Auxliary Feedwater. System Turkey Point Froject Finding III.C.6: The design of the nitrogen system faile'd to provide the required separation la the low nitrogen pressure alarm circuit. Alarms are provided on the redundant nitrogen system to worn the operator that he must take action to maintain the nitorgen systems's ability to post-tion the ausiliary feedvater flow control valves. The team determined that the low pressure signals from Fressure Switches Ps-3-2322 (Nitrogen Traio 1) and FS-3-2323 (Nitrogen Train 2) feed adjacent control room annunciator windows. Associated pressure switch contacts must close to alare. The team determined that the two signals share a common field wire (Cable 3R38/3C05-T33414/1 is a 3 conduceer cable with wire AN38 common to both alare circuits). The team is concerned that a single failure, such as a loose or disconnected wire could result la the co m o mode failure of all low pressure alarms for the redundant altrogen system. Further, this design appears to be contrary to the redundancy and spearation requirements of ANSI N45.2.11, Section 3.2. This item will reesia ,. unresolved pending follovup by the Region II office (50-250/8532-14; > 50-251/8332-14). gesponset The design modifications for the Ausliary Feedwater Systes utilised the pressure switches and annunciation system installed under the - original plaat construction, which were neither designed nor main-tained as nuclear safety related. As a result, the classification of these components was not changed from the original design basis of the plaat. 1 FOR INFORMAT ON ONLY i
l Response to NRC Findings l Aux 11ary Feedwater System Turkey Point Project Finding III.C.7.at The safety-related battery system which existed before PCN 83-05 consisted of four batteries, two per unit. Unit 3 had one C&D battery i i rated at 1885 ampere-hours and an EXIDE battery rated at 648 aspere- ' hours. Unit 4 had one C&D battery rated at 2175 aspere-hours and an EXIDE battery rated at 648 aspero hours. With FCM 83-05, the 1885 aspere-hour and 2175 aspere-hour C4D batteries were replaced with emeller Could-CNB 1800 ampere-hour cells. The 644 ampere-hour EXIDE batteries were replaced with larger could-CWS 1200 asper-hour es11s. These new batteries were purchased using Bechtel Specification 5177-272-E-850.1, Rev. 0, dated January 18, 1983. This document contained a one-hour battery load profile and required corrections for a minimum electrolyte temperature of 55' F and an 80 percent end-of-life compensation in accordance with IEEE Standard 485. This specified load profile did not agree with that given in FSAR Table 4.2.4 The tese noted that the DC loads listed in this table did not include the auxiliary feedwater DC actor-operated valves. In an attempt to determine if all DC loads were accounted for in the sising of the new replacement batteries, the taas requested the battery sising calcu- ' lations. The licensee was unable to produce an analysis or calculation'which was used to develop the load profile used in the procurement specifi-cation. However, the licensee did exhibit a DC systes capability study, Calculation 5177-399-E-01, which was performed by 5echtel during the first half of 1985. The purpose of this study was to determine the capability of the DC system to respond to the unavail- l ability of selected batteries under different operating conditions. In Case 1 of this study, each battery was checked with its own t emersoney loads. This calculation did include loads for the auxiliary feedwater DC motor-operated valves; however, it assumed data based upon a preliminary 1980 calculation and not on manufacturer's data or the equipment nameplate data. This calculation included inappropriate assumptions for the steady-state load by basing this load on battery charger readings under normal operating plant conditions. The calcu-lation did not ldentify"these-ee -easumptions requiring verification. This cateulation also did not include design margin correction factors for te sperature or inadequate saintenance as required by IEEE Standard 445. Responses A sensitivity study has been performed by the electrical department technical staff to determine the available margin in the new plant 20R IN:0RMAT ON ON.Y e w -- - -
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-Finding III.C.7.a page 2 of 2 batteries. This study consisted of a review of calculation 5177-399-301, design drawings, assumed full load on the vital inverters, and worst case temperature correction and aging factors. The results of this study indicate a margin in excess of 20. percent on the most loaded battey. In parallel with this effort, a detailed project J bettery loading calculation has been initiated based os review of plant design drawings. This calculation will be parformed and checked on project and forwarded for technical staff review and will then become a permanent Turkey Point calculation.
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Response to NRC Findings Auntiary Feedwater System Turkey Point Project Finding III.C.7.b The design modification process failed to include adequate acceptance criteria and verification testing for the new batteries. The purchasing documents specified required testing by the battery manufacturer. Gould-GWB performed a standard eight hour capacity test which ebowed that the betteries would deliver at least their eight hour rated capacity. This i test stopped short of determining any margin above rating (Ihapection 1 Report 43779 dated May 5, 1983). The manufacturer also performed a load duty cycle test on selected cells in accordance with the specified load profile but failed to correct the discharge rates for the specified ) minimum temperature condition. The post-modifiestion testing performed ! on the Unit 3 3 Sattery (Plant Work order 354333) tested the new bettery ' using the FSAR half hour profile, not the one hour duty cycle of the specification. Again, no temperature correction was made to the dia-charge rate as indicated on the July 12, 1983 data sheets. Because of the lack of an acceptable load analysis combined with inade-quate existingtesting, in thethe newteam was unable to determine the degree of margin batteries. , Responses A review of the department batterystaff. technical test reports has been conducted by the electrical The battery testing performed by the manufacturer has been determined to be adequate in regard to establishing initial battery capacity and its ability to meet the speci,fied load profile. These preliminary conclusions will be reconfirmed following completion of the battery calculations. i FOR FORMATION ON.Y
- = Response to NRC Findings Auxliary Feedwater Systes Turkey Point Project Finding III.C.7.cs he plant operating procedures for the DC System failed to reference
' the specific periodic testing requirements for the new Gould-CNE batteries. Plant Operating Procedure 96041.1, dated June 19, 1945, specified the requirements for the monthly equalising charge. However, the new Geuld-GNB batteries are composed of lead calcium cells, and this type of battery cell should not be given monthly equalising charges. Iustead, they should only be given an equalising charge when required in accordance with the manufacturer's recommendation. Further, this operating procedure references the instruction manuals for the old batteries and does not reference the new Could-GNB NCE type cells and should have the same charging voltages. Plant Operating Procedures 9654.1 and 9654.2, dated November 8, 1984, describe the the load test procedures for all four safety-related batteries. Again, these procedures only refer to the C4D Batteries i taatruction Manual (even though batteries 35 and 4A were originally , EXIDE batteries) and do not reference the new Gould-CNB lastructions. Additionally, the description of the battery load test profile used la these procedures use the 30 minute FSAR profile also without coepeaa sation for minimum electrolyte toeperature requirements. The taas could not find plant operating procedures describing a battery performance test to determine acutal battery capaci;y compared to rated capacity (as recommended by IEEE 5tandard 450). - The apparent failure to establish and implement technically adequate procedures for the new station batteries will rammin unresolved pending followup by the Region II Office (50-250/8532-15g 50-251/8532-15). Responset The failure to update the operating procedures for the DC Systee was due, in part, to a lack of procedural guidance requiring engineerin personnel to identify the necessary changes in the operating proce g dures as part of the FCK for plant modifications. This need has been recognised since the battery modifications 'were designed, and the engineering procedures now include requirements to identify the affected operating and maintenance procedures in each PCM. FFL is currently revising the operating procedures for the new batteries.
- 0R N!0RMAT ON ON.Y.
Response to NRC Findings Aux 11ery Feedwater System Turkey Point Project Finding III.C.88 The team had a significant concern that excessive reliance was placed on operator action'instead of design features to ensure the proper function-i ing of the auxiliary feedwater system. Specifically, the team wee concerned that immediate operator action may be required upon initiation of the auxiliary feedwater system following a loss of main feedwater and reactor air trip with a concomitant loss of the non-safety related instrument supply. Although the auxiliary feedwater system is ' designed to auto-matica11y initiate, design calculations do not exist which demonstrate that the system will continue to run for a period of time without immedi-ate operator action. This concern is, in part, based upon the lack of design analyses to support nitrogen system design details and the need for immediate operator action inherent la the design of the nitrogen systes. This concern is based upon the following observations ~s o tack of design analysis based upon the as-installed systes to docu-ment the setpoint selection for pressure switches used to alert the operator that ten minutes of nitrogen remain before loss of motive , air control pressure (i.e., closure of flow control valves and loss ' of all feedwater). o Lack of design criterion to define how long the auxiliary feedwater system has to operate without operator action. Consequently, no guidance was provided to establish operating limits on available nitrogen supply before reaching the low level setpoint. o Lack of engineering direction with respect to postWificat' ion testing requirements to confirm the adequacy of the installation to design bases.
Response
FPL recognises the NRC's concerns related to the reliance placed on operator action to ensure proper functioning of the Auxiliary Feedwater System.
'A reanalysis of the nitrogen system, based on a revised setpoTat ----
of 1350 poi, has confirmed that a siniana of ten minutes is available for the operator to switch bottles upon reaching the low pressure setpoint based on a conservative assumption on valve oscillation and with no credit taken for placing the valves in the manual. mode. The low pressure alara will be reset in the field based on this revised setpoint, and the appropriate design documents are being revised. l IOR LNJ0RMAZON ON Y. f l e l
Finding III.C.8 Page 2 of 2 The need to identify post-sodification testins requiremente to confria the adequacy of new installations to the established design bases has ateo been more nodifications clearly were understood designed since the Auxiliary Feedwater Systes in 1933. angineering procedures goverains the preparation of design modification package were revised during the poet year to require the identification of post 1 modification testing. In addition, Bechtel and FFL are currently reviewing existing procedures as ' well as operations and startup needs, to identify additional improveme,nts In the interface between these departments. l l
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