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See also: [[see also::IR 05000250/1989203]]


=Text=
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{{#Wiki_filter:-.ACCELERATED
{{#Wiki_filter:-. ACCELERATED DISTRIBUTION                           DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION
CCESSION NBR:9002070202             DOC.DATE:   90/01/29   NOTARIZED: NO         DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C                 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C               .05000251 AUTH. NAME           AUTHOR AFFILIATION HARRIS,K.N.           Florida Power & Light Co.
DEMONSTPWTION
RECIP.NAME           RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SYSTEM REGULATORY
 
INFORMATION
==SUBJECT:==
DISTRIBUTION
Responds to .NRC       ltr 50-250/89-203 & 50-251/89-203.
SYSTEM (RIDS)CCESSION NBR:9002070202
re violations noted in Insp Repts DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR                   ENCL     SIZE:
DOC.DATE: 90/01/29 NOTARIZED:
TITLE: General (50 Dkt)-Insp Rept/Notice of VioIation Response NOTES:
NO DOCKET FACIL:50-250
RECIPIENT              COPIES            RECIPIENT         COPIES ID CODE/NAME           LTTR ENCL        ID  CODE/NAME      LTTR ENCL PD2-2 PD                     1    1      EDISON,G              1  1 INTERNAL: AEOD                           1    1      AEOD/DEIIB            1    1 AEOD/TPAD                     1    1      DEDRO                  1    1 NRR SHANKMAN,S               1    1      NRR/DLPQ/LPEB10        1  1 NRR/DOEA DIR 11               1    1      NRR/DREP/PEPB9 D       1   1 NRR/DREP/PRPB11              2    2      NRR/DRIS/DIR          1    1 NRR/DST/DIR 8E2              1    1      NRR/PMAS/ILRB12       1    1 NUDOCS-ABSTRACT              1    1      0 ErIEjBERMAN,J       1   1 OGC/HDS2                      1     1                             1   1 RES MORISSEAU,D              '1     1     RGN2    FILE  Ol      1   1 TERNAL: LPDR                          1     1     NRC PDR NSIC                          1     1 NOTE TO ALL "RIDS" RECIPIENTS:
Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C.05000251 AUTH.NAME AUTHOR AFFILIATION
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
HARRIS,K.N.
TOTAL NUMBER OF COPIES REQUIRED: LTTR               24   ENCL   24
Florida Power&Light Co.RECIP.NAME
 
RECIPIENT AFFILIATION
P.O. Box14000, Juno Beach, F1. 33408-0420 I=PL JAN 2 9 1990 L-90-36 U.S. Nuclear Regulatory Commission Attn:   Document       Control Desk Washington, D.C. 20555 Gentlemen:
Document Control Branch (Document Control Desk)SUBJECT: Responds to.NRC ltr re violations
Re:   Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Re 1 to Ins ection Re ort 89-203 Florida Power & Light Company has reviewed the subject inspection report. The response to the unresolved items identified in the report is attached.
noted in Insp Repts 50-250/89-203
Should you need any additional information, we would be glad to discuss the response with you.
&50-251/89-203.
Very truly   yours,
DISTRIBUTION
    )
CODE: IE01D COPIES RECEIVED:LTR
Vice/President Turkey Point Plant KNH/GRM/tbj Attachment cc:   Stewart D. Ebneter, Regional Administrator, Region II,                 USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9p0207ADOCK      2 900129 0 gpp0250 PDP                     @DC O
ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
an FPL Group company.
of VioIation Response NOTES: RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: AEOD AEOD/TPAD NRR SHANKMAN,S
 
NRR/DOEA DIR 11 NRR/DREP/PRPB11
Re:   Turkey Point Units 3 'and 4 Docket Nos. 50-250 and 50-251 Re 1 to Ins ection R ort 89-203 DEFICIENCY     89-203-10:   REPLACEMENT CCW HEAT EXCHANGER SHELL-SIDE NOZZLE LOAD Discussion:     . ZP&L engineering package PC/M 88-263 was written for replacement of the Unit         4 heat exchangers.         FP&L prepared purchase   order   C88658   90314   to   procure   the   replacement     heat exchangers. Appendix   C of the   purchase   order   required     that the replacement heat exchangers be qualified by the response spectrum approach for the SSE depicted in Figure 1 of that Appendix.
NRR/DST/DIR
The Bechtel calculation C-SJ-183-02 CCW Heat Exchanger Support Pedestal Load Evaluation, included an evaluation of the heat exchanger     fundamental     frequency.         The Bechtel       calculation computed a fundamental frequency greater           .than 33 Hz   for the heat exchangers, and concluded that the heat exchangers were rigid.
8E2 NUDOCS-ABSTRACT
The calculation therefore used the Zero Period Acceleration (ZPA) values of the SSE spectrum to compute the seismic reactions of the heat exchangers.         However, the Bechtel calculation did not consider   the   transverse   flexibility of the concrete pedestals supporting the heat exchangers.           If the heat exchanger and the supporting concrete pedestals             were   analyzed     as   a   single mathematical model, the fundamental frequency of the heat exchanger along its longitudinal axis drops to about 10 Hz. This would increase the magnitudes of the seismic loads for which the heat exchangers must be qualified.
OGC/HDS2 RES MORISSEAU,D
The replacement heat exchangers were qualified for piping thrust, dead loads and seismic loads by Target Technology Ltd. Bechtel recommended that Target compute the heat exchangers fundamental frequency and use ZPA loads both to qualify the heat exchangers and   to compute the heat exchanger support reaction.                       Like Bechtel, Target computed the heat exchanger fundamental frequency without considering the transverse flexibility of the concrete pedestals and concluded that the heat exchanger was rigid.
TERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1'1 1 1 1 1 1 RECIPIENT ID CODE/NAME EDISON,G AEOD/DEIIB
As a consequence,     Target qualified the replacement heat exchanger with respect to the ZPA seismic loads. Since the heat exchangers and concrete pedestal         corifiguration is flexible, the Target stress   report   does not adequately   qualify the replacement heat exchangers   for   the governing   seismic   loads.
DEDRO NRR/DLPQ/LPEB10
This item   is Unresolved (89-203-10)
NRR/DREP/PEPB9
 
D NRR/DRIS/DIR
NRR/PMAS/ILRB12
0 ErIEjBERMAN, J RGN2 FILE Ol NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24  
P.O.Box14000, Juno Beach, F1.33408-0420
I=PL JAN 2 9 1990 L-90-36 U.S.Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos.50-250 and 50-251 Re 1 to Ins ection Re ort 89-203 Florida Power&Light Company has reviewed the subject inspection
report.The response to the unresolved
items identified
in the report is attached.Should you need any additional
information, we would be glad to discuss the response with you.Very truly yours,)Vice/President
Turkey Point Plant KNH/GRM/tbj
Attachment
cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9p0207 gpp0250 2 900129 PDP ADOCK 0@DC O an FPL Group company.  
Re: Turkey Point Units 3'and 4 Docket Nos.50-250 and 50-251 Re 1 to Ins ection R ort 89-203 DEFICIENCY
89-203-10:
REPLACEMENT
CCW HEAT EXCHANGER SHELL-SIDE
NOZZLE LOAD Discussion:
.ZP&L engineering
package PC/M 88-263 was written for replacement
of the Unit 4 heat exchangers.
FP&L prepared purchase order C88658 90314 to procure the replacement
heat exchangers.
Appendix C of the purchase order required that the replacement
heat exchangers
be qualified by the response spectrum approach for the SSE depicted in Figure 1 of that Appendix.The Bechtel calculation
C-SJ-183-02
CCW Heat Exchanger Support Pedestal Load Evaluation, included an evaluation
of the heat exchanger fundamental
frequency.
The Bechtel calculation
computed a fundamental
frequency greater.than 33 Hz for the heat exchangers, and concluded that the heat exchangers
were rigid.The calculation
therefore used the Zero Period Acceleration (ZPA)values of the SSE spectrum to compute the seismic reactions of the heat exchangers.
However, the Bechtel calculation
did not consider the transverse
flexibility
of the concrete pedestals supporting
the heat exchangers.
If the heat exchanger and the supporting
concrete pedestals were analyzed as a single mathematical
model, the fundamental
frequency of the heat exchanger along its longitudinal
axis drops to about 10 Hz.This would increase the magnitudes
of the seismic loads for which the heat exchangers
must be qualified.
The replacement
heat exchangers
were qualified for piping thrust, dead loads and seismic loads by Target Technology
Ltd.Bechtel recommended
that Target compute the heat exchangers
fundamental
frequency and use ZPA loads both to qualify the heat exchangers
and to compute the heat exchanger support reaction.Like Bechtel, Target computed the heat exchanger fundamental
frequency without considering
the transverse
flexibility
of the concrete pedestals and concluded that the heat exchanger was rigid.As a consequence, Target qualified the replacement
heat exchanger with respect to the ZPA seismic loads.Since the heat exchangers
and concrete pedestal corifiguration
is flexible, the Target stress report does not adequately
qualify the replacement
heat exchangers
for the governing seismic loads.This item is Unresolved
(89-203-10)  
R88POIls8:
R88POIls8:
The determination
determination that the heat exchanger pedestal supports are The flexible (approximately 5 Hz)         "'n   the longitudinal axis affects the qualification of the         CCW   and ICW piping attached to the heat exchangers,     the heat exchangers           and the support pedestals themselves. The analyses       for each of these     components   have been revised/reviewed as described below:
that the heat exchanger pedestal supports are flexible (approximately
The piping stress analyses for both the CCW and ZCW piping have been       revised, taking into account the pedestal flexibility"'"'. The revised analyses showed that both systems, including the pipe supports, remain within Updated Final Analysis Report allowable stresses.                         New heat exchanger   nozzle     loads   were   also     determined   from these analyses.
5 Hz)"'n the longitudinal
The heat exchanger       qualification is being reviewed in order to determine the         effect of the new nozzle loads and the pedestal flexibility. With respect to nozzle loadings, no adverse     effect on heat exchanger qualification is anticipated;     a   preliminary comparison         of the   new   nozzle loads   against     the   allowable   stresses     documented in the original heat exchanger qualification               report has indicated that the increase in nozzle loads falls within the margin between actual and allowable nozzle stresses.                 Upon further review of the seismic input provided in the specification to the heat exchanger vendor"', it was found that the response spectra   used     was   a   conservatively       amplified enveloping response spectra curve.           The Zero   Period   Acceleration (ZPA) for the enveloping spectra provided in the specification is greater than the acceleration corresponding to 5 Hz on the ground response spectra which actually corresponds to the base of the 'support pedestals               (0.4 g's versus 0.37 g's respectively)   "'. Accordingly,     the   seismic loading on the heat exchangers will be reduced,               even   when the pedestal flexibility is considered.               FPL is working with Target Technologies       to obtain a revised final stress report by June 30, 1990.       This report will include a consideration of the effects of the correct pedestal flexibility, the new nozzle loads,         and the ground response               spectra which correspond to the heat exchanger location. This report will be   incorporated into the heat exchanger                     replacement engineering   documentation       package   within   60 days of receipt, but no later than August 29,           1990.
axis affects the qualification
 
of the CCW and ICW piping attached to the heat exchangers, the heat exchangers
This item   will be considered complete once the report has been incorporated into the documentation   package as discussed above.
and the support pedestals themselves.
 
The analyses for each of these components
==References:==
have been revised/reviewed
: 1)   Bechtel Calculation 18712-183-C-SJ-183-02 Revision 8, "CCW Heat Exchanger Support Pedestal Load Evaluation"
as described below: The piping stress analyses for both the CCW and ZCW piping have been revised, taking into account the pedestal flexibility"'"'.
: 2)   Teledyne Calculations 6961C-1 Revision 4, "Stress Problem 025" and. 6961C-3 Revision 6, "Stress Problem 038/CCW-24"
The revised analyses showed that both systems, including the pipe supports, remain within Updated Final Analysis Report allowable stresses.New heat exchanger nozzle loads were also determined
: 3)   Bechtel Calculations 18712-M12-183-02 Revision 5, and 18712-M12-183-04 Revision 2, "XCW Piping Stress Analysis"
from these analyses.The heat exchanger qualification
: 4)   Purchase Order No. C88658-90314 for CCW Heat Exchanger Replacement
is being reviewed in order to determine the effect of the new nozzle loads and the pedestal flexibility.
: 5)   Bechtel Calculation 18712-183-C-SJ-183-12 Revision 1,     "CCW Heat Exchanger Pedestal Stiffness Analysis"
With respect to nozzle loadings, no adverse effect on heat exchanger qualification
 
is anticipated;
DEFICIENCY   89-203-13:   REPL2KXMENT CCW HEAT EXCHANGER SHELL-S1DE NOZZLE LOAD Discussion:       FPL engineering package PC/M 88-263, was written for   replacement   of the Unit 4 heat exchangers.         The heat exchangers   were qualified   for the imposed dead loads, nozzle loads, and seismic loads in a Target Technology     report.
a preliminary
~
comparison
  'echtel     calculation M12-183-01 tabulated shell-side nozzle loads that   were   substantially higher than the nozzle loads which Bechtel originally transmitted to Target and which were used in the Target qualification report. Bechtel transmitted the revised nozzle loads to Target on November 23, 1988. Bechtel and Target discussed these nozzle loads on December 1, 1988 and Target informed Bechtel that the increased nozzle loads were acceptable.
of the new nozzle loads against the allowable stresses documented
However, Target never revised and reissued the CCW heat exchanger qualification report to document the qualification of the heat exchangers   for the revised nozzle loads.
in the original heat exchanger qualification
This item is unresolved (89-203-13).
report has indicated that the increase in nozzle loads falls within the margin between actual and allowable nozzle stresses.Upon further review of the seismic input provided in the specification
FPL Response:
to the heat exchanger vendor"', it was found that the response spectra used was a conservatively
Subsequent   to this increase in nozzle loads, the piping stress analyses for the CCW and ZCW piping have been revised. New heat exchanger nozzle loads were determined from these analyses.
amplified enveloping
FPL is working with Target Technologies to obtain a revised     final stress report by June 30, 1990,         This report will include a consideration of the effects of the newly revised nozzle loads.
response spectra curve.The Zero Period Acceleration (ZPA)for the enveloping
Since the stress report is being resubmitted to address revised nozzle loads, and is being tracked as part of Deficiency 89-203-10, this item is considered complete.
spectra provided in the specification
 
is greater than the acceleration
DEFICIENCY 89-203-14: CCN REL1EF VALVE REPLACEMEBFV Discussion:       FPL   engineering package PC/M 86-238 was written for replacement of Unit 4 relief valves RV-1423 through 1431.
corresponding
Teledyne prepared calculation 6548-1 to qualify these 1-1/2 inch or 1 inch diameter cantilever branch lines for both units.
to 5 Hz on the ground response spectra which actually corresponds
Teledyne technical report TR-5322-1 requires that safety-related piping be qualified to the appropriate loading combinations and stress limits.         However, the Teledyne calculation does not address:
to the base of the'support pedestals (0.4 g's versus 0.37 g's respectively)
o The   effects of valve thrust; o The   need to support valve RV-3-1431 with     a tieback from the 3-inch run pipe, since the branch line is not rigid; o A   stress   check   at. the root of each branch line for the combined effects of pressure, dead load, valve thrust, and seismic loads; or o The   effects of lumped mass of the branch line and relief valve. If this lumped massline is considered, the fundamental will frequency   of the branch           drop.
"'.Accordingly, the seismic loading on the heat exchangers
This item is Unresolved Item (89-203-14)       .
will be reduced, even when the pedestal flexibility
FPL Response:
is considered.
The calculation which supported the replacement of           CCW relief valves (RV-1423 through 1431) installed per PC/M             86-238 was revised to include the following:
FPL is working with Target Technologies
The effects of valve thrust A stress check at the root of each branch line The'ffects of       lumped mass   of the branch line   and relief valve During the determination for the need to support RV-3-1431, the hand calculation for the branch line containing RV-3-1431 was revised using a dynamic analysis and         it was determined that the branch line actually has a frequency greater than 33 Hz and as a result there was no need to support the valve with a tieback from the 3-inch run.
to obtain a revised final stress report by June 30, 1990.This report will include a consideration
 
of the effects of the correct pedestal flexibility, the new nozzle loads, and the ground response spectra which correspond
P, This. review determined that the existing configuration for the relief valves continues to meet the Turkey Point UPSAR stress criteria, Appendix 5A. These reviews are documented in the Teledyne calculation"'.
to the heat exchanger location.This report will be incorporated
This item is considered complete.
into the heat exchanger replacement
Reference
engineering
: 1)   Teledyne calculation 6548-1, Revision 1, associated with PC/M 86-238.
documentation
 
package within 60 days of receipt, but no later than August 29, 1990.  
DEZICIENCY     89-203-15:     COMPONENT     COOLING     WATER   OPERATING PROCEDURES Discussion:     The   inspection team reviewed operating procedure 3/4-OP-030 for the     CCW system to determine       if if valve lineups were lineup changes consistent with approved design drawings             and for various operating evolutions were properly established and restored.     The team found the following deficiencies                 when comparing the procedures to system drawings 5610-T-E-4512, Sheet 1 and 2:
This item will be considered
o   Procedure   4-OP-030,   page 25, Step     7.5.2.7, directs the operator to     makeup   the   CCW   surge tank as required by manipulating     valves   MOV-4-832,     4-711B and 4-710B.
complete once the report has been incorporated
Valve     4-737C     was   not referenced         as   requiring manipulation; however,       it is shown as a normally closed valve on the system drawing and would inhibit makeup flow if not opened.
into the documentation
o   Procedures     3-OP-030     and   4-0P-030,   page   27,   step 7.3.2.15 specify that valve .4-711B be left open although     drawing     5610-T-E-4512       indicates     normal position as closed.             Step 7.6.2.15 specifies the positions of valves 3-711A and 4-711A as being left open although the referenced drawing indicates closed as the normal position.
package as discussed above.References:
o   Procedures   3-OP-030 and 4-0P-030,       Attachments   2 and 3, for CCW valve alignment inside and outside containment, contained the following deficiencies:
1)Bechtel Calculation
Valves     3-10-681,     3-10-682, and 3-10-683 were specified as having a normal position of open in the valve lineup as opposed to closed as indicated on they system drawing.
18712-183-C-SJ-183-02
Valve 4-10-689 was specified as being closed in the valve lineup as opposed to closed and capped as indicated on the system drawing.
Revision 8,"CCW Heat Exchanger Support Pedestal Load Evaluation" 2)Teledyne Calculations
Valves 3-10-749, 4-10-692, 4-10-1009, 4-10-1010, 4-1181, 4-1182, and 4-769D were shown on the system drawings but were not included in the valve lineup.
6961C-1 Revision 4,"Stress Problem 025" and.6961C-3 Revision 6,"Stress Problem 038/CCW-24" 3)Bechtel Calculations
These   deficiencies     if not corrected, could have resulted in failure to adequately verify system integrity or could have placed the system in a condition where valves were left opened instead of closed, resulting in a loss of system integrity. With the exception of the makeup valves (4-737C, 4-711B, 3-711A, and 4-711A) the valves noted were vent and drain valves.
18712-M12-183-02
 
Revision 5, and 18712-M12-183-04
The .licensee agreed   to make the identified corrections       to the procedures.
Revision 2,"XCW Piping Stress Analysis" 4)Purchase Order No.C88658-90314
The item is unresolved (89-203-15).
for CCW Heat Exchanger Replacement
FPL Response:
5)Bechtel Calculation
Procedure Corrections have been completed as follows:
18712-183-C-SJ-183-12
                .Procedure 4-OP-030 Infrequent Operations Section
Revision 1,"CCW Heat Exchanger Pedestal Stiffness Analysis"  
: 7. 0, has been modified to indicate valve 4-737C requires manipulation for alternate CCW surge tank fill.
DEFICIENCY
Procedures     3-OP-030     and   4-0P-030,   Infrequent Operations   Section 7. 0, has been modified to indicate valve 4-711B as closed in step 7.5.2.15 and valves 3-711A and 4-711A as closed in step 7.6.2.15.
89-203-13:
Procedures   3-OP-030 and 4-OP-030       valve lineups have been modified to show:
REPL2KXMENT
Valves   3-10-681,   3-10-682,   and 3-10-683 as closed. Additionally, investigation of the improper valve positions listed in 3-OP-030 for valves 3-10-681, 3-10-682, and 3-10-683 showed incorrect positions resulted from a procedure change error and that a valve lineup had not been performed using this procedure with these         incorrect positions listed. We are confident that had a valve lineup been performed, the "On-The-Spot-Change" process       would have been used to correct this procedural error.
CCW HEAT EXCHANGER SHELL-S1DE
Way Valve 4-10-689   Q   closed and capped.
NOZZLE LOAD Discussion:
Valves 3-10-749, 4-10-692, 4-10-1009, 4                       1010, 4-1181, 4-1182, and 4-769D as shown on system drawing 5610-T-E-4512
FPL engineering
 
package PC/M 88-263, was written for replacement
An additional concern raised by the resident inspector involves 3/4-ONOP-030,   Loss of Component Cooling Water.         The area of concern involved emergency hoses and included:
of the Unit 4 heat exchangers.
: 1) Physical Fit-up of hoses   (fittings)
The heat exchangers
: 2)   Hose Length   (to allow reaching   all three pumps)
were qualified for the imposed dead loads, nozzle loads, and seismic loads in a Target Technology
: 3)   Designated storage FPL RESPONSE Item 1   Physical Fit-up has been verified and is complete.
report.~'echtel calculation
Item 2   Hose length has been verified and the length allows reaching all three pumps.
M12-183-01
Item 3   Permanently designated storage is presently being     investigated   by   the   Operations Department.
tabulated shell-side
 
nozzle loads that were substantially
DEFICIENCY 89-203-16:           CCW   PUMP   AND   SURGE   TANK   SEISMIC QUALIFICATION AND ANCHORAGE CHECK Discussion:     Westinghouse       Equipment       Specification       676428 included the   seismic   qualification   criteria   for the   CCW pumps.
higher than the nozzle loads which Bechtel originally
Section 3.2.12 of the specification stated that the pumps shall be designed to resist earthquake forces in the horizontal and vertical directions, as specified by the data sheets.                     The Westinghouse centrifugal pump data sheet APCC-532 specified a horizontal design acceleration of 1.0 g and a vertical design acceleration o& 0.67 g.           FPL could not access         the seismic qualification   documents   for   the   CCW pumps.     FPL   additionally could not access any seismic criteria fo'r the CCW surge tank, or any seismic qualification documents.
transmitted
The   equipment   anchorage   should   be checked for the         combined effects of piping thrusts,     dead load and seismic load.         However, FPL could not access the anchorage calculations for the           CCW pumps and surge tanks.
to Target and which were used in the Target qualification
The audit team was informed that an essential calculation program is planned for the facility. The licensee will determine which calculations are required and will verify that the calculations are retrievable.
report.Bechtel transmitted
This item is unresolved item (89-203-16) .
the revised nozzle loads to Target on November 23, 1988.Bechtel and Target discussed these nozzle loads on December 1, 1988 and Target informed Bechtel that the increased nozzle loads were acceptable.
. FPL Response:
However, Target never revised and reissued the CCW heat exchanger qualification
As indicated in the     above   discussion,     no seismic qualification documents have   been   found   for either   the CCW pump or the CCW surge tank. This situation is not         uncommon   for power plants of Turkey Point's vintage.     In order'o assess the need to recreate the qualification documents for this type of equipment, .FPL commissioned a review of the Turkey Point seismic design.                 This review was conducted by     Westinghouse   and   completed in July   1989.
report to document the qualification
The Westinghouse     report"'ompared the seismic capacities of equipment documented in various NUREGs and other published literature to similar, if not identical, equipment found at Turkey Point. This report concluded that the Turkey Point safety related equipment, including the CCW pumps and surge tanks, have high generic seismic capacities.             If properlyPoint's anchored, the location equipment is seismically adequate due to Turkey in a low   seismicity region.
of the heat exchangers
In addition to the Westinghouse effort discussed above, the issue of equipment seismic qualification -is being addressed under Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46". FPL has submitted a program to the NRC for resolution of this generic issue.
for the revised nozzle loads.This item is unresolved
10
(89-203-13).
 
FPL Response: Subsequent
An analysis of the CCW pump anchorage has been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'. This analysis showed that the pump anchorage is satisfactory to withstand all postulated loads.
to this increase in nozzle loads, the piping stress analyses for the CCW and ZCW piping have been revised.New heat exchanger nozzle loads were determined
Similarly, analyses of the CCW surge tank anchorages (including structural steel supporting members) have been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'. The structural members and connections have been shown in this calculation to adequately withstand all postulated loads and to remain -within UFSAR allowable stresses.             The expansion anchors used to attach the supporting members to the concrete walls have been       shown to be acceptable         for functionality; however for Unit 4, modifications       will   be required   to bring the safety factors up to the values required by current standards.
from these analyses.FPL is working with Target Technologies
The anchor modification discussed above will be implemented by the end of the next Unit 4 refueling outage, currently scheduled to start in November 1990.
to obtain a revised final stress report by June 30, 1990, This report will include a consideration
FPL is proceeding with developing an enhanced Calculation Control Program. This program includes a revised calculation procedure and a FPL mainframe computer indexing system that will accept FPL and contractor calculations. The revised calculation procedure was issued in December 1989.       The loading of the new calculation index data will be a     continuing   process and the loading of the historical data will       be   handled   through   the   normal   budget process.
of the effects of the newly revised nozzle loads.Since the stress report is being resubmitted
 
to address revised nozzle loads, and is being tracked as part of Deficiency
==References:==
89-203-10, this item is considered
: 1)   "Turkey   Point   Units   3   &   4,   Fragility Analysis     for Quantification   of   Seismic     Capabilities   of   Buildings, Structures and Equipment, WCAP-12051", Westinghouse         Electric Corporation, July 1989
complete.  
: 2)   Bechtel Calculation 18712-183-C-SJ183-11 Revision 1,           "CCW Pump Pedestal Analysis"
: 3)   Bechtel Calculation 18712-183-C-SJ183-10 Revision 1,           "CCW Surge Tank Platform Analysis" 11
DEFICIENCY
 
89-203-14:
DEFICIENCY 89-203-18:     CCW PZPE   SUPPORT CALCUI~ZONS Discussion:     The   team     reviewed     the     calculations     for approximately twenty four pipe supports which were documented in the following Teledyne stress packages:
CCN REL1EF VALVE REPLACEMEBFV
Teledyne   calculation TR-5322-93,     USNRC I&E Bulletin 79-14 Analysis,   Turkey Point Unit   4 Nuclear Power Plant, Component Cooling Water System     (Outside   Containment)/Stress     Problem CCW-14, Revision 1, dated November 21, 1984; Teledyne calculation 6961C-1, Analysis of Stress Problem 025 Unit   4,   Turkey Point,       for Replacement of CCW Heat Exchangers, Revision 3, dated November 30, 1988; and o   Teledyne calculation 6961C-3, Analysis       of Stress Problem   038
Discussion:
    -Unit 4, Turkey Point, for Replacement         of CCW, Revision     5, dated October 28, 1988.
FPL engineering
The team   compared these calculations against the applicable Teledyne   engineering procedures and identified the following calculational and procedural deficiencies:
package PC/M 86-238 was written for replacement
o   Teledyne   re-qualified   a   number   of stanchion   supports to resist uplift. However, the Teledyne baseplate procedure does not appear applicable to the qualification of these supports. Pipe support 4-ACH-267 is an example of such a stanchion support.
of Unit 4 relief valves RV-1423 through 1431.Teledyne prepared calculation
o   Some anchor   bolt tension     and shear loads,     such as for support SR-703, were     not computed in accordance with the Teledyne procedure.
6548-1 to qualify these 1-1/2 inch or 1 inch diameter cantilever
For example,   baseplate edge distance amplification factors were not applied to compute bolt tension loads, and the shear loads were distributed to all, rather than half, of the anchor bol'ts.
branch lines for both units.Teledyne technical report TR-5322-1 requires that safety-related
The allowable bolt tension used to qualify pipe support 4-ACH-211 exceeded the bolt tension allowed by the Teledyne design guide.
piping be qualified to the appropriate
Bending stresses in single-angle supplementary steel were not correctly computed. Examples included the supplementary steel for pipe supports 4-ACH-14 and 4-ACH-46.
loading combinations
o   Some supplementary steel was checked using assumed cross-sectional dimensions that were not field verified. Examples included the supplementary steel for pipe supports 4-ACH-190 and 4-ACH-191.
and stress limits.However, the Teledyne calculation
o   Spring hanger 4-ACH-207 tops and           bottoms   out, but   was accepted as-is without analysis.
does not address: o The effects of valve thrust;o The need to support valve RV-3-1431 with a tieback from the 3-inch run pipe, since the branch line is not rigid;o A stress check at.the root of each branch line for the combined effects of pressure, dead load, valve thrust, and seismic loads;or o The effects of lumped mass of the branch line and relief valve.If this lumped mass is considered, the fundamental
12
frequency of the branch line will drop.This item is Unresolved
 
Item (89-203-14)
o The Teledyne     stress packages indicated that ZPA and seismic inertia loads should be combined absolutely, however,, these values were actually calculated by the SRSS method within the stress package.
.FPL Response: The calculation
o The AISC web crippling check was not performed to determine if beam stiffeners are required.
which supported the replacement
This item   is unresolved item     (89-203-18) .
of CCW relief valves (RV-1423 through 1431)installed per PC/M 86-238 was revised to include the following:
FPL Response:
The effects of valve thrust A stress check at the root of each branch line The'ffects
The responses   to the individual deficiencies are       as follows:
of lumped mass of the branch line and relief valve During the determination
Teledyne reviewed pipe support 4-ACH-267 for uplift and determined that based on the thickness of the plate -.the prying factor is 1.0; while examples in the Teledyne base plate procedure do not represent the actual support configuration, the procedure is       still applicable.
for the need to support RV-3-1431, the hand calculation
Teledyne reviewed SR-703 and determined that the baseplate edge distance amplification factor was 1.0 and therefore the engineering procedure was not required to be used;                 The calculation. originally considered shear loading           on all four anchor bolts. Upon further review, an arithmetic error was identified in the shear load calculation. The calculation was revised to distribute the shear load to half the anchor bolts.
for the branch line containing
Teledyne reviewed support 4-ACH-211 and determined that the calculation referenced an incorrect revision to the Teledyne design guide.       The allowable bolt tension to qualify the support   was   bounded   by the bolt tension in the later revision of the design guide.
RV-3-1431 was revised using a dynamic analysis and it was determined
Teledyne revised calculations       for supports   4-ACH-14 and 4-ACH-46   to correctly   compute bending stresses     in single angle supplementary steel.
that the branch line actually has a frequency greater than 33 Hz and as a result there was no need to support the valve with a tieback from the 3-inch run.  
Supports   4-ACH-190   and   4-ACH-191   are   currently   on the punchlist       for discrepancies         identified during the development of their respective drawings.             Therefore these supports   will   be walked   down   to   verify   the   dimensional assumption in the     calculation.
P,  
Teledyne revised the     calculation for spring hanger 4-ACH-207 including the stiffness of the spring hanger in the dynamic analysis to limit seismic travel and as a result, the support did not top or bottom out.
This.review determined
13
that the existing configuration
 
for the relief valves continues to meet the Turkey Point UPSAR stress criteria, Appendix 5A.These reviews are documented
The ZPA   loads are those which result from the response of the piping system in the rigid range.               These loads are combined with the seismic inertia loads which result from the piping stress analysis.           The ZPA and seismic inertia loads are correctly combined using the square root sum of the squares (SRSS) method in the calculation. However, the computer code used to           support the       Teledyne     stress packages does       not presently       have     the   capability of combining the ZPA and seismic inertia loads using the SRSS method;   it combines them absolutely.         Therefore, Teledyne currently "per forms the SRSS combination o f the ZPA and seismic inertial loads by hand. Teledyne's computer program will be modified to perform this function.
in the Teledyne calculation"'.
Teledyne revised the affected stress packages to address the AISC'eb crippling check.
This item is considered
For     all identified deficiencies, the revised calculations resulted in confirming that the existing configuration continues to meet the Turkey Point UFSAR stress criteria, Appendix 5A..
complete.Reference 1)Teledyne calculation
This is documented in Teledyne calculations"'.
6548-1, Revision 1, associated
To   avoid recurring deficiencies,       the pipe support     criteria will be   revised to address baseplate       uplift, single     angle bending and the   AISC web crippling   check. The Teledyne   computer   code will be revised to eliminate     the need to   perform hand   calculations   using the   SRSS method. These two documents     will be revised by March 1, 1990.
with PC/M 86-238.  
 
DEZICIENCY
==Reference:==
89-203-15:
 
COMPONENT COOLING WATER OPERATING PROCEDURES
(1)   Teledyne Calculations     6961C-1,   Revision 4 "Stress Problem 025" and 6961C-3, Revision       6 "Stress Problem 038/CCW-24" 14
Discussion:
 
The inspection
DEFICIENCY   89-203-20:       CDR   VERIFICATION Discussion:         The     CDRs     for the     RPS,   CCW,   and   electrical distribution     systems were reviewed.               The CDRs   were   found to contain   erroneous     and   unnecessary     information,   as follows:
team reviewed operating procedure 3/4-OP-030
o     The CCW chemical mixing pot was           inferred to have been replaced when       it location on the system.
for the CCW system to determine if valve lineups were consistent
had only been     moved to a different o     The CCW   pump   start   sequence   description   was   incomplete.
with approved design drawings and if lineup changes for various operating evolutions
o     The CCW   containment     isolation valve stroke times         were not consistent with the         TS requirements.
were properly established
o     The   instrument       voltage     tolerances     were   improperly specified.
and restored.The team found the following deficiencies
o     The   methodology       for cable short circuit calculations was inconsistent     with   actual practice.
when comparing the procedures
o     The discharge profile was ambiguously defined.
to system drawings 5610-T-E-4512, Sheet 1 and 2: o Procedure 4-OP-030, page 25, Step 7.5.2.7, directs the operator to makeup the CCW surge tank as required by manipulating
These. concerns     led to the conclusion that the           CDR   had not been appropriately verified. The licensee has agreed to perform some additional verification of the CDR information.                     The licensee also issued a directive which restricted the use of CDR information in the design process.
valves MOV-4-832, 4-711B and 4-710B.Valve 4-737C was not referenced
This item is unresolved         (89-203-20)
as requiring manipulation;
FPL Response:
however, it is shown as a normally closed valve on the system drawing and would inhibit makeup flow if not opened.o Procedures
FPL   has   committed to perform           a Component   Design   Requirements (CDR) verification.         In the interim, a directive has been issued which restricts       the   usage of CDR information.           The verification will take place in several stages.                   First, the accuracy and reliability of     CDR   information will be improved in a "CDR Repair" project. The main objective will be to provide true component requirements in a clear, concise and verifiable format.                       Upon completion of       "CDR   Repair"     for   the   18 select   systems,   "CDR Verification" will be performed.                 This   effort   will   include   a verification/validation of CDR information. The scope of                       this verification will be finalized in procedures, and is expected to focus on key design requirements               (attributes) that demonstrate the functional capability               of the components.             The   "CDR Verification" effort is scheduled               for completion     by June   30, 1991.
3-OP-030 and 4-0P-030, page 27, step 7.3.2.15 specify that valve.4-711B be left open although drawing 5610-T-E-4512
15
indicates normal position as closed.Step 7.6.2.15 specifies the positions of valves 3-711A and 4-711A as being left open although the referenced
 
drawing indicates closed as the normal position.o Procedures
I DEFZCZENCY 89-203-23:       ACCEPTABILITY OF   THE MINIMUM BATTERY TERMINAL VOLTAGE Discussion:     The minimum end-of-service-life battery terminal voltage is 105 Volts Di,rect Current (VDC) . There is no evidence that the terminal voltage is adequate to power all safety-related devices. The licensee has performed individual voltage drop calculations for load addition or modification. The li.censee has not performed a bounding calculation to show that all devices located remotely from the battery bus will be able to operate successfully.
3-OP-030 and 4-0P-030, Attachments
While some tests have been performed, certain components were bypassed during the testing and were therefore not verified to operate at the low battery terminal voltage.
2 and 3, for CCW valve alignment inside and outside containment, contained the following deficiencies:
Adequate assurance does not exist that the combination of the minimum   battery terminal voltage and system voltage drop considerations will yield sufficient equipment voltages to maintain equipment functionality.
Valves 3-10-681, 3-10-682, and 3-10-683 were specified as having a normal position of open in the valve lineup as opposed to closed as indicated on they system drawing.Valve 4-10-689 was specified as being closed in the valve lineup as opposed to closed and capped as indicated on the system drawing.Valves 3-10-749, 4-10-692, 4-10-1009, 4-10-1010, 4-1181, 4-1182, and 4-769D were shown on the system drawings but were not included in the valve lineup.These deficiencies
This is unresolved item 89-203-23.
if not corrected, could have resulted in failure to adequately
FPL Response:
verify system integrity or could have placed the system in a condition where valves were left opened instead of closed, resulting in a loss of system integrity.
A bounding   calculation as described above is not a licensing requirement     for Turkey Point.         Individual voltage drop calculations for load additions and modifications have been performed as necessary.     However, to provide additional assurance that all equipment required to operate will do so at the minimum battery terminal voltage of 105 volts, a bounding calculation will be performed..
With the exception of the makeup valves (4-737C, 4-711B, 3-711A, and 4-711A)the valves noted were vent and drain valves.  
This calculation   will   demonstrate the acceptability of the   DC equipments'oltage     ratings of 105 volts. This work is scheduled for completion   by December 31, 1990.
The.licensee agreed to make the identified
16
corrections
 
to the procedures.
0,}}
The item is unresolved
(89-203-15).
FPL Response: Procedure Corrections
have been completed as follows:.Procedure
4-OP-030 Infrequent
Operations
Section 7.0, has been modified to indicate valve 4-737C requires manipulation
for alternate CCW surge tank fill.Procedures
3-OP-030 and 4-0P-030, Infrequent
Operations
Section 7.0, has been modified to indicate valve 4-711B as closed in step 7.5.2.15 and valves 3-711A and 4-711A as closed in step 7.6.2.15.Procedures
3-OP-030 and 4-OP-030 valve lineups have been modified to show: Valves 3-10-681, 3-10-682, and 3-10-683 as closed.Additionally, investigation
of the improper valve positions listed in 3-OP-030 for valves 3-10-681, 3-10-682, and 3-10-683 showed incorrect positions resulted from a procedure change error and that a valve lineup had not been performed using this procedure with these incorrect positions listed.We are confident that had a valve lineup been performed, the"On-The-Spot-
Change" process would have been used to correct this procedural
error.Way Valve 4-10-689 Q closed and capped.Valves 3-10-749, 4-10-692, 4-10-1009, 4-10-1010, 4-1181, 4-1182, and 4-769D as shown on system drawing 5610-T-E-4512  
An additional
concern raised by the resident inspector involves 3/4-ONOP-030, Loss of Component Cooling Water.The area of concern involved emergency hoses and included: 1)Physical Fit-up of hoses (fittings)
2)Hose Length (to allow reaching all three pumps)3)Designated
storage FPL RESPONSE Item 1-Physical Fit-up has been verified and is complete.Item 2-Hose length has been verified and the length allows reaching all three pumps.Item 3-Permanently
designated
storage is presently being investigated
by the Operations
Department.  
DEFICIENCY
89-203-16:
CCW PUMP AND SURGE TANK SEISMIC QUALIFICATION
AND ANCHORAGE CHECK Discussion:
Westinghouse
Equipment Specification
676428 included the seismic qualification
criteria for the CCW pumps.Section 3.2.12 of the specification
stated that the pumps shall be designed to resist earthquake
forces in the horizontal
and vertical directions, as specified by the data sheets.The Westinghouse
centrifugal
pump data sheet APCC-532 specified a horizontal
design acceleration
of 1.0 g and a vertical design acceleration
o&0.67 g.FPL could not access the seismic qualification
documents for the CCW pumps.FPL additionally
could not access any seismic criteria fo'r the CCW surge tank, or any seismic qualification
documents.
The equipment anchorage should be checked for the combined effects of piping thrusts, dead load and seismic load.However, FPL could not access the anchorage calculations
for the CCW pumps and surge tanks.The audit team was informed that an essential calculation
program is planned for the facility.The licensee will determine which calculations
are required and will verify that the calculations
are retrievable.
This item is unresolved
item (89-203-16)
..FPL Response: As indicated in the above discussion, no seismic qualification
documents have been found for either the CCW pump or the CCW surge tank.This situation is not uncommon for power plants of Turkey Point's vintage.In order'o assess the need to recreate the qualification
documents for this type of equipment,.FPL commissioned
a review of the Turkey Point seismic design.This review was conducted by Westinghouse
and completed in July 1989.The Westinghouse
report"'ompared
the seismic capacities
of equipment documented
in various NUREGs and other published literature
to similar, if not identical, equipment found at Turkey Point.This report concluded that the Turkey Point safety related equipment, including the CCW pumps and surge tanks, have high generic seismic capacities.
If properly anchored, the equipment is seismically
adequate due to Turkey Point's location in a low seismicity
region.In addition to the Westinghouse
effort discussed above, the issue of equipment seismic qualification-is being addressed under Generic Letter 87-02,"Verification
of Seismic Adequacy of Mechanical
and Electrical
Equipment in Operating Reactors, Unresolved
Safety Issue (USI)A-46".FPL has submitted a program to the NRC for resolution
of this generic issue.10  
An analysis of the CCW pump anchorage has been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'.This analysis showed that the pump anchorage is satisfactory
to withstand all postulated
loads.Similarly, analyses of the CCW surge tank anchorages (including
structural
steel supporting
members)have been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'.The structural
members and connections
have been shown in this calculation
to adequately
withstand all postulated
loads and to remain-within UFSAR allowable stresses.The expansion anchors used to attach the supporting
members to the concrete walls have been shown to be acceptable
for functionality;
however for Unit 4, modifications
will be required to bring the safety factors up to the values required by current standards.
The anchor modification
discussed above will be implemented
by the end of the next Unit 4 refueling outage, currently scheduled to start in November 1990.FPL is proceeding
with developing
an enhanced Calculation
Control Program.This program includes a revised calculation
procedure and a FPL mainframe computer indexing system that will accept FPL and contractor
calculations.
The revised calculation
procedure was issued in December 1989.The loading of the new calculation
index data will be a continuing
process and the loading of the historical
data will be handled through the normal budget process.References:
1)"Turkey Point Units 3&4, Fragility Analysis for Quantification
of Seismic Capabilities
of Buildings, Structures
and Equipment, WCAP-12051", Westinghouse
Electric Corporation, July 1989 2)Bechtel Calculation
18712-183-C-SJ183-11
Revision 1,"CCW Pump Pedestal Analysis" 3)Bechtel Calculation
18712-183-C-SJ183-10
Revision 1,"CCW Surge Tank Platform Analysis" 11  
DEFICIENCY
89-203-18:
CCW PZPE SUPPORT CALCUI~ZONS
Discussion:
The team reviewed the calculations
for approximately
twenty four pipe supports which were documented
in the following Teledyne stress packages: Teledyne calculation
TR-5322-93, USNRC I&E Bulletin 79-14 Analysis, Turkey Point Unit 4 Nuclear Power Plant, Component Cooling Water System (Outside Containment)/Stress
Problem CCW-14, Revision 1, dated November 21, 1984;Teledyne calculation
6961C-1, Analysis of Stress Problem 025 Unit 4, Turkey Point, for Replacement
of CCW Heat Exchangers, Revision 3, dated November 30, 1988;and o Teledyne calculation
6961C-3, Analysis of Stress Problem 038-Unit 4, Turkey Point, for Replacement
of CCW, Revision 5, dated October 28, 1988.The team compared these calculations
against the applicable
Teledyne engineering
procedures
and identified
the following calculational
and procedural
deficiencies:
o Teledyne re-qualified
a number of stanchion supports to resist uplift.However, the Teledyne baseplate procedure does not appear applicable
to the qualification
of these supports.Pipe support 4-ACH-267 is an example of such a stanchion support.o Some anchor bolt tension and shear loads, such as for support SR-703, were not computed in accordance
with the Teledyne procedure.
For example, baseplate edge distance amplification
factors were not applied to compute bolt tension loads, and the shear loads were distributed
to all, rather than half, of the anchor bol'ts.The allowable bolt tension used to qualify pipe support 4-ACH-211 exceeded the bolt tension allowed by the Teledyne design guide.Bending stresses in single-angle
supplementary
steel were not correctly computed.Examples included the supplementary
steel for pipe supports 4-ACH-14 and 4-ACH-46.o Some supplementary
steel was checked using assumed cross-sectional dimensions
that were not field verified.Examples included the supplementary
steel for pipe supports 4-ACH-190 and 4-ACH-191.
o Spring hanger 4-ACH-207 tops and bottoms out, but was accepted as-is without analysis.12  
o The Teledyne stress packages indicated that ZPA and seismic inertia loads should be combined absolutely, however,, these values were actually calculated
by the SRSS method within the stress package.o The AISC web crippling check was not performed to determine if beam stiffeners
are required.This item is unresolved
item (89-203-18)
.FPL Response: The responses to the individual
deficiencies
are as follows: Teledyne reviewed pipe support 4-ACH-267 for uplift and determined
that based on the thickness of the plate-.the prying factor is 1.0;while examples in the Teledyne base plate procedure do not represent the actual support configuration, the procedure is still applicable.
Teledyne reviewed SR-703 and determined
that the baseplate edge distance amplification
factor was 1.0 and therefore the engineering
procedure was not required to be used;The calculation.
originally
considered
shear loading on all four anchor bolts.Upon further review, an arithmetic
error was identified
in the shear load calculation.
The calculation
was revised to distribute
the shear load to half the anchor bolts.Teledyne reviewed support 4-ACH-211 and determined
that the calculation
referenced
an incorrect revision to the Teledyne design guide.The allowable bolt tension to qualify the support was bounded by the bolt tension in the later revision of the design guide.Teledyne revised calculations
for supports 4-ACH-14 and 4-ACH-46 to correctly compute bending stresses in single angle supplementary
steel.Supports 4-ACH-190 and 4-ACH-191 are currently on the punchlist for discrepancies
identified
during the development
of their respective
drawings.Therefore these supports will be walked down to verify the dimensional
assumption
in the calculation.
Teledyne revised the calculation
for spring hanger 4-ACH-207 including the stiffness of the spring hanger in the dynamic analysis to limit seismic travel and as a result, the support did not top or bottom out.13  
The ZPA loads are those which result from the response of the piping system in the rigid range.These loads are combined with the seismic inertia loads which result from the piping stress analysis.The ZPA and seismic inertia loads are correctly combined using the square root sum of the squares (SRSS)method in the calculation.
However, the computer code used to support the Teledyne stress packages does not presently have the capability
of combining the ZPA and seismic inertia loads using the SRSS method;it combines them absolutely.
Therefore, Teledyne currently"per forms the SRSS combination
o f the ZPA and seismic inertial loads by hand.Teledyne's
computer program will be modified to perform this function.Teledyne revised the affected stress packages to address the AISC'eb crippling check.For all identified
deficiencies, the revised calculations
resulted in confirming
that the existing configuration
continues to meet the Turkey Point UFSAR stress criteria, Appendix 5A..This is documented
in Teledyne calculations"'.
To avoid recurring deficiencies, the pipe support criteria will be revised to address baseplate uplift, single angle bending and the AISC web crippling check.The Teledyne computer code will be revised to eliminate the need to perform hand calculations
using the SRSS method.These two documents will be revised by March 1, 1990.Reference:
(1)Teledyne Calculations
6961C-1, Revision 4"Stress Problem 025" and 6961C-3, Revision 6"Stress Problem 038/CCW-24" 14  
DEFICIENCY
89-203-20:
CDR VERIFICATION
Discussion:
The CDRs for the RPS, CCW, and electrical
distribution
systems were reviewed.The CDRs were found to contain erroneous and unnecessary
information, as follows: o The CCW chemical mixing pot was inferred to have been replaced when it had only been moved to a different location on the system.o The CCW pump start sequence description
was incomplete.
o The CCW containment
isolation valve stroke times were not consistent
with the TS requirements.
o The instrument
voltage tolerances
were improperly
specified.
o The methodology
for cable short circuit calculations
was inconsistent
with actual practice.o The discharge profile was ambiguously
defined.These.concerns led to the conclusion
that the CDR had not been appropriately
verified.The licensee has agreed to perform some additional
verification
of the CDR information.
The licensee also issued a directive which restricted
the use of CDR information
in the design process.This item is unresolved
(89-203-20)
FPL Response: FPL has committed to perform a Component Design Requirements (CDR)verification.
In the interim, a directive has been issued which restricts the usage of CDR information.
The verification
will take place in several stages.First, the accuracy and reliability
of CDR information
will be improved in a"CDR Repair" project.The main objective will be to provide true component requirements
in a clear, concise and verifiable
format.Upon completion
of"CDR Repair" for the 18 select systems,"CDR Verification" will be performed.
This effort will include a verification/validation
of CDR information.
The scope of this verification
will be finalized in procedures, and is expected to focus on key design requirements (attributes)
that demonstrate
the functional
capability
of the components.
The"CDR Verification" effort is scheduled for completion
by June 30, 1991.15  
I DEFZCZENCY
89-203-23:
ACCEPTABILITY
OF THE MINIMUM BATTERY TERMINAL VOLTAGE Discussion:
The minimum end-of-service-life
battery terminal voltage is 105 Volts Di,rect Current (VDC).There is no evidence that the terminal voltage is adequate to power all safety-related
devices.The licensee has performed individual
voltage drop calculations
for load addition or modification.
The li.censee has not performed a bounding calculation
to show that all devices located remotely from the battery bus will be able to operate successfully.
While some tests have been performed, certain components
were bypassed during the testing and were therefore not verified to operate at the low battery terminal voltage.Adequate assurance does not exist that the combination
of the minimum battery terminal voltage and system voltage drop considerations
will yield sufficient
equipment voltages to maintain equipment functionality.
This is unresolved
item 89-203-23.
FPL Response: A bounding calculation
as described above is not a licensing requirement
for Turkey Point.Individual
voltage drop calculations
for load additions and modifications
have been performed as necessary.
However, to provide additional
assurance that all equipment required to operate will do so at the minimum battery terminal voltage of 105 volts, a bounding calculation
will be performed..
This calculation
will demonstrate
the acceptability
of the DC equipments'oltage
ratings of 105 volts.This work is scheduled for completion
by December 31, 1990.16  
0,
}}

Latest revision as of 09:13, 22 October 2019

Responds to Deficiencies 89-203-10,89-203-13,89-203-14, 89-203-15,89-203-16,89-203-18,89-203-20 & 89-203-23 Noted in Insp Repts 50-250/89-203 & 50-251/89-203.Corrective Actions: Commitment to Verify Component Design Requirements Made
ML17347B546
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 01/29/1990
From: Harris K
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-36, NUDOCS 9002070202
Download: ML17347B546 (25)


Text

-. ACCELERATED DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9002070202 DOC.DATE: 90/01/29 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C .05000251 AUTH. NAME AUTHOR AFFILIATION HARRIS,K.N. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to .NRC ltr 50-250/89-203 & 50-251/89-203.

re violations noted in Insp Repts DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of VioIation Response NOTES:

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P.O. Box14000, Juno Beach, F1. 33408-0420 I=PL JAN 2 9 1990 L-90-36 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Re 1 to Ins ection Re ort 89-203 Florida Power & Light Company has reviewed the subject inspection report. The response to the unresolved items identified in the report is attached.

Should you need any additional information, we would be glad to discuss the response with you.

Very truly yours,

)

Vice/President Turkey Point Plant KNH/GRM/tbj Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9p0207ADOCK 2 900129 0 gpp0250 PDP @DC O

an FPL Group company.

Re: Turkey Point Units 3 'and 4 Docket Nos. 50-250 and 50-251 Re 1 to Ins ection R ort 89-203 DEFICIENCY 89-203-10: REPLACEMENT CCW HEAT EXCHANGER SHELL-SIDE NOZZLE LOAD Discussion: . ZP&L engineering package PC/M 88-263 was written for replacement of the Unit 4 heat exchangers. FP&L prepared purchase order C88658 90314 to procure the replacement heat exchangers. Appendix C of the purchase order required that the replacement heat exchangers be qualified by the response spectrum approach for the SSE depicted in Figure 1 of that Appendix.

The Bechtel calculation C-SJ-183-02 CCW Heat Exchanger Support Pedestal Load Evaluation, included an evaluation of the heat exchanger fundamental frequency. The Bechtel calculation computed a fundamental frequency greater .than 33 Hz for the heat exchangers, and concluded that the heat exchangers were rigid.

The calculation therefore used the Zero Period Acceleration (ZPA) values of the SSE spectrum to compute the seismic reactions of the heat exchangers. However, the Bechtel calculation did not consider the transverse flexibility of the concrete pedestals supporting the heat exchangers. If the heat exchanger and the supporting concrete pedestals were analyzed as a single mathematical model, the fundamental frequency of the heat exchanger along its longitudinal axis drops to about 10 Hz. This would increase the magnitudes of the seismic loads for which the heat exchangers must be qualified.

The replacement heat exchangers were qualified for piping thrust, dead loads and seismic loads by Target Technology Ltd. Bechtel recommended that Target compute the heat exchangers fundamental frequency and use ZPA loads both to qualify the heat exchangers and to compute the heat exchanger support reaction. Like Bechtel, Target computed the heat exchanger fundamental frequency without considering the transverse flexibility of the concrete pedestals and concluded that the heat exchanger was rigid.

As a consequence, Target qualified the replacement heat exchanger with respect to the ZPA seismic loads. Since the heat exchangers and concrete pedestal corifiguration is flexible, the Target stress report does not adequately qualify the replacement heat exchangers for the governing seismic loads.

This item is Unresolved (89-203-10)

R88POIls8:

determination that the heat exchanger pedestal supports are The flexible (approximately 5 Hz) "'n the longitudinal axis affects the qualification of the CCW and ICW piping attached to the heat exchangers, the heat exchangers and the support pedestals themselves. The analyses for each of these components have been revised/reviewed as described below:

The piping stress analyses for both the CCW and ZCW piping have been revised, taking into account the pedestal flexibility"'"'. The revised analyses showed that both systems, including the pipe supports, remain within Updated Final Analysis Report allowable stresses. New heat exchanger nozzle loads were also determined from these analyses.

The heat exchanger qualification is being reviewed in order to determine the effect of the new nozzle loads and the pedestal flexibility. With respect to nozzle loadings, no adverse effect on heat exchanger qualification is anticipated; a preliminary comparison of the new nozzle loads against the allowable stresses documented in the original heat exchanger qualification report has indicated that the increase in nozzle loads falls within the margin between actual and allowable nozzle stresses. Upon further review of the seismic input provided in the specification to the heat exchanger vendor"', it was found that the response spectra used was a conservatively amplified enveloping response spectra curve. The Zero Period Acceleration (ZPA) for the enveloping spectra provided in the specification is greater than the acceleration corresponding to 5 Hz on the ground response spectra which actually corresponds to the base of the 'support pedestals (0.4 g's versus 0.37 g's respectively) "'. Accordingly, the seismic loading on the heat exchangers will be reduced, even when the pedestal flexibility is considered. FPL is working with Target Technologies to obtain a revised final stress report by June 30, 1990. This report will include a consideration of the effects of the correct pedestal flexibility, the new nozzle loads, and the ground response spectra which correspond to the heat exchanger location. This report will be incorporated into the heat exchanger replacement engineering documentation package within 60 days of receipt, but no later than August 29, 1990.

This item will be considered complete once the report has been incorporated into the documentation package as discussed above.

References:

1) Bechtel Calculation 18712-183-C-SJ-183-02 Revision 8, "CCW Heat Exchanger Support Pedestal Load Evaluation"
2) Teledyne Calculations 6961C-1 Revision 4, "Stress Problem 025" and. 6961C-3 Revision 6, "Stress Problem 038/CCW-24"
3) Bechtel Calculations 18712-M12-183-02 Revision 5, and 18712-M12-183-04 Revision 2, "XCW Piping Stress Analysis"
4) Purchase Order No. C88658-90314 for CCW Heat Exchanger Replacement
5) Bechtel Calculation 18712-183-C-SJ-183-12 Revision 1, "CCW Heat Exchanger Pedestal Stiffness Analysis"

DEFICIENCY 89-203-13: REPL2KXMENT CCW HEAT EXCHANGER SHELL-S1DE NOZZLE LOAD Discussion: FPL engineering package PC/M 88-263, was written for replacement of the Unit 4 heat exchangers. The heat exchangers were qualified for the imposed dead loads, nozzle loads, and seismic loads in a Target Technology report.

~

'echtel calculation M12-183-01 tabulated shell-side nozzle loads that were substantially higher than the nozzle loads which Bechtel originally transmitted to Target and which were used in the Target qualification report. Bechtel transmitted the revised nozzle loads to Target on November 23, 1988. Bechtel and Target discussed these nozzle loads on December 1, 1988 and Target informed Bechtel that the increased nozzle loads were acceptable.

However, Target never revised and reissued the CCW heat exchanger qualification report to document the qualification of the heat exchangers for the revised nozzle loads.

This item is unresolved (89-203-13).

FPL Response:

Subsequent to this increase in nozzle loads, the piping stress analyses for the CCW and ZCW piping have been revised. New heat exchanger nozzle loads were determined from these analyses.

FPL is working with Target Technologies to obtain a revised final stress report by June 30, 1990, This report will include a consideration of the effects of the newly revised nozzle loads.

Since the stress report is being resubmitted to address revised nozzle loads, and is being tracked as part of Deficiency 89-203-10, this item is considered complete.

DEFICIENCY 89-203-14: CCN REL1EF VALVE REPLACEMEBFV Discussion: FPL engineering package PC/M 86-238 was written for replacement of Unit 4 relief valves RV-1423 through 1431.

Teledyne prepared calculation 6548-1 to qualify these 1-1/2 inch or 1 inch diameter cantilever branch lines for both units.

Teledyne technical report TR-5322-1 requires that safety-related piping be qualified to the appropriate loading combinations and stress limits. However, the Teledyne calculation does not address:

o The effects of valve thrust; o The need to support valve RV-3-1431 with a tieback from the 3-inch run pipe, since the branch line is not rigid; o A stress check at. the root of each branch line for the combined effects of pressure, dead load, valve thrust, and seismic loads; or o The effects of lumped mass of the branch line and relief valve. If this lumped massline is considered, the fundamental will frequency of the branch drop.

This item is Unresolved Item (89-203-14) .

FPL Response:

The calculation which supported the replacement of CCW relief valves (RV-1423 through 1431) installed per PC/M 86-238 was revised to include the following:

The effects of valve thrust A stress check at the root of each branch line The'ffects of lumped mass of the branch line and relief valve During the determination for the need to support RV-3-1431, the hand calculation for the branch line containing RV-3-1431 was revised using a dynamic analysis and it was determined that the branch line actually has a frequency greater than 33 Hz and as a result there was no need to support the valve with a tieback from the 3-inch run.

P, This. review determined that the existing configuration for the relief valves continues to meet the Turkey Point UPSAR stress criteria, Appendix 5A. These reviews are documented in the Teledyne calculation"'.

This item is considered complete.

Reference

1) Teledyne calculation 6548-1, Revision 1, associated with PC/M 86-238.

DEZICIENCY 89-203-15: COMPONENT COOLING WATER OPERATING PROCEDURES Discussion: The inspection team reviewed operating procedure 3/4-OP-030 for the CCW system to determine if if valve lineups were lineup changes consistent with approved design drawings and for various operating evolutions were properly established and restored. The team found the following deficiencies when comparing the procedures to system drawings 5610-T-E-4512, Sheet 1 and 2:

o Procedure 4-OP-030, page 25, Step 7.5.2.7, directs the operator to makeup the CCW surge tank as required by manipulating valves MOV-4-832, 4-711B and 4-710B.

Valve 4-737C was not referenced as requiring manipulation; however, it is shown as a normally closed valve on the system drawing and would inhibit makeup flow if not opened.

o Procedures 3-OP-030 and 4-0P-030, page 27, step 7.3.2.15 specify that valve .4-711B be left open although drawing 5610-T-E-4512 indicates normal position as closed. Step 7.6.2.15 specifies the positions of valves 3-711A and 4-711A as being left open although the referenced drawing indicates closed as the normal position.

o Procedures 3-OP-030 and 4-0P-030, Attachments 2 and 3, for CCW valve alignment inside and outside containment, contained the following deficiencies:

Valves 3-10-681, 3-10-682, and 3-10-683 were specified as having a normal position of open in the valve lineup as opposed to closed as indicated on they system drawing.

Valve 4-10-689 was specified as being closed in the valve lineup as opposed to closed and capped as indicated on the system drawing.

Valves 3-10-749, 4-10-692, 4-10-1009, 4-10-1010, 4-1181, 4-1182, and 4-769D were shown on the system drawings but were not included in the valve lineup.

These deficiencies if not corrected, could have resulted in failure to adequately verify system integrity or could have placed the system in a condition where valves were left opened instead of closed, resulting in a loss of system integrity. With the exception of the makeup valves (4-737C, 4-711B, 3-711A, and 4-711A) the valves noted were vent and drain valves.

The .licensee agreed to make the identified corrections to the procedures.

The item is unresolved (89-203-15).

FPL Response:

Procedure Corrections have been completed as follows:

.Procedure 4-OP-030 Infrequent Operations Section

7. 0, has been modified to indicate valve 4-737C requires manipulation for alternate CCW surge tank fill.

Procedures 3-OP-030 and 4-0P-030, Infrequent Operations Section 7. 0, has been modified to indicate valve 4-711B as closed in step 7.5.2.15 and valves 3-711A and 4-711A as closed in step 7.6.2.15.

Procedures 3-OP-030 and 4-OP-030 valve lineups have been modified to show:

Valves 3-10-681, 3-10-682, and 3-10-683 as closed. Additionally, investigation of the improper valve positions listed in 3-OP-030 for valves 3-10-681, 3-10-682, and 3-10-683 showed incorrect positions resulted from a procedure change error and that a valve lineup had not been performed using this procedure with these incorrect positions listed. We are confident that had a valve lineup been performed, the "On-The-Spot-Change" process would have been used to correct this procedural error.

Way Valve 4-10-689 Q closed and capped.

Valves 3-10-749, 4-10-692, 4-10-1009, 4 1010, 4-1181, 4-1182, and 4-769D as shown on system drawing 5610-T-E-4512

An additional concern raised by the resident inspector involves 3/4-ONOP-030, Loss of Component Cooling Water. The area of concern involved emergency hoses and included:

1) Physical Fit-up of hoses (fittings)
2) Hose Length (to allow reaching all three pumps)
3) Designated storage FPL RESPONSE Item 1 Physical Fit-up has been verified and is complete.

Item 2 Hose length has been verified and the length allows reaching all three pumps.

Item 3 Permanently designated storage is presently being investigated by the Operations Department.

DEFICIENCY 89-203-16: CCW PUMP AND SURGE TANK SEISMIC QUALIFICATION AND ANCHORAGE CHECK Discussion: Westinghouse Equipment Specification 676428 included the seismic qualification criteria for the CCW pumps.

Section 3.2.12 of the specification stated that the pumps shall be designed to resist earthquake forces in the horizontal and vertical directions, as specified by the data sheets. The Westinghouse centrifugal pump data sheet APCC-532 specified a horizontal design acceleration of 1.0 g and a vertical design acceleration o& 0.67 g. FPL could not access the seismic qualification documents for the CCW pumps. FPL additionally could not access any seismic criteria fo'r the CCW surge tank, or any seismic qualification documents.

The equipment anchorage should be checked for the combined effects of piping thrusts, dead load and seismic load. However, FPL could not access the anchorage calculations for the CCW pumps and surge tanks.

The audit team was informed that an essential calculation program is planned for the facility. The licensee will determine which calculations are required and will verify that the calculations are retrievable.

This item is unresolved item (89-203-16) .

. FPL Response:

As indicated in the above discussion, no seismic qualification documents have been found for either the CCW pump or the CCW surge tank. This situation is not uncommon for power plants of Turkey Point's vintage. In order'o assess the need to recreate the qualification documents for this type of equipment, .FPL commissioned a review of the Turkey Point seismic design. This review was conducted by Westinghouse and completed in July 1989.

The Westinghouse report"'ompared the seismic capacities of equipment documented in various NUREGs and other published literature to similar, if not identical, equipment found at Turkey Point. This report concluded that the Turkey Point safety related equipment, including the CCW pumps and surge tanks, have high generic seismic capacities. If properlyPoint's anchored, the location equipment is seismically adequate due to Turkey in a low seismicity region.

In addition to the Westinghouse effort discussed above, the issue of equipment seismic qualification -is being addressed under Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46". FPL has submitted a program to the NRC for resolution of this generic issue.

10

An analysis of the CCW pump anchorage has been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'. This analysis showed that the pump anchorage is satisfactory to withstand all postulated loads.

Similarly, analyses of the CCW surge tank anchorages (including structural steel supporting members) have been performed to evaluate the effects of nozzle loads, dead loads, and seismic loads"'. The structural members and connections have been shown in this calculation to adequately withstand all postulated loads and to remain -within UFSAR allowable stresses. The expansion anchors used to attach the supporting members to the concrete walls have been shown to be acceptable for functionality; however for Unit 4, modifications will be required to bring the safety factors up to the values required by current standards.

The anchor modification discussed above will be implemented by the end of the next Unit 4 refueling outage, currently scheduled to start in November 1990.

FPL is proceeding with developing an enhanced Calculation Control Program. This program includes a revised calculation procedure and a FPL mainframe computer indexing system that will accept FPL and contractor calculations. The revised calculation procedure was issued in December 1989. The loading of the new calculation index data will be a continuing process and the loading of the historical data will be handled through the normal budget process.

References:

1) "Turkey Point Units 3 & 4, Fragility Analysis for Quantification of Seismic Capabilities of Buildings, Structures and Equipment, WCAP-12051", Westinghouse Electric Corporation, July 1989
2) Bechtel Calculation 18712-183-C-SJ183-11 Revision 1, "CCW Pump Pedestal Analysis"
3) Bechtel Calculation 18712-183-C-SJ183-10 Revision 1, "CCW Surge Tank Platform Analysis" 11

DEFICIENCY 89-203-18: CCW PZPE SUPPORT CALCUI~ZONS Discussion: The team reviewed the calculations for approximately twenty four pipe supports which were documented in the following Teledyne stress packages:

Teledyne calculation TR-5322-93, USNRC I&E Bulletin 79-14 Analysis, Turkey Point Unit 4 Nuclear Power Plant, Component Cooling Water System (Outside Containment)/Stress Problem CCW-14, Revision 1, dated November 21, 1984; Teledyne calculation 6961C-1, Analysis of Stress Problem 025 Unit 4, Turkey Point, for Replacement of CCW Heat Exchangers, Revision 3, dated November 30, 1988; and o Teledyne calculation 6961C-3, Analysis of Stress Problem 038

-Unit 4, Turkey Point, for Replacement of CCW, Revision 5, dated October 28, 1988.

The team compared these calculations against the applicable Teledyne engineering procedures and identified the following calculational and procedural deficiencies:

o Teledyne re-qualified a number of stanchion supports to resist uplift. However, the Teledyne baseplate procedure does not appear applicable to the qualification of these supports. Pipe support 4-ACH-267 is an example of such a stanchion support.

o Some anchor bolt tension and shear loads, such as for support SR-703, were not computed in accordance with the Teledyne procedure.

For example, baseplate edge distance amplification factors were not applied to compute bolt tension loads, and the shear loads were distributed to all, rather than half, of the anchor bol'ts.

The allowable bolt tension used to qualify pipe support 4-ACH-211 exceeded the bolt tension allowed by the Teledyne design guide.

Bending stresses in single-angle supplementary steel were not correctly computed. Examples included the supplementary steel for pipe supports 4-ACH-14 and 4-ACH-46.

o Some supplementary steel was checked using assumed cross-sectional dimensions that were not field verified. Examples included the supplementary steel for pipe supports 4-ACH-190 and 4-ACH-191.

o Spring hanger 4-ACH-207 tops and bottoms out, but was accepted as-is without analysis.

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o The Teledyne stress packages indicated that ZPA and seismic inertia loads should be combined absolutely, however,, these values were actually calculated by the SRSS method within the stress package.

o The AISC web crippling check was not performed to determine if beam stiffeners are required.

This item is unresolved item (89-203-18) .

FPL Response:

The responses to the individual deficiencies are as follows:

Teledyne reviewed pipe support 4-ACH-267 for uplift and determined that based on the thickness of the plate -.the prying factor is 1.0; while examples in the Teledyne base plate procedure do not represent the actual support configuration, the procedure is still applicable.

Teledyne reviewed SR-703 and determined that the baseplate edge distance amplification factor was 1.0 and therefore the engineering procedure was not required to be used; The calculation. originally considered shear loading on all four anchor bolts. Upon further review, an arithmetic error was identified in the shear load calculation. The calculation was revised to distribute the shear load to half the anchor bolts.

Teledyne reviewed support 4-ACH-211 and determined that the calculation referenced an incorrect revision to the Teledyne design guide. The allowable bolt tension to qualify the support was bounded by the bolt tension in the later revision of the design guide.

Teledyne revised calculations for supports 4-ACH-14 and 4-ACH-46 to correctly compute bending stresses in single angle supplementary steel.

Supports 4-ACH-190 and 4-ACH-191 are currently on the punchlist for discrepancies identified during the development of their respective drawings. Therefore these supports will be walked down to verify the dimensional assumption in the calculation.

Teledyne revised the calculation for spring hanger 4-ACH-207 including the stiffness of the spring hanger in the dynamic analysis to limit seismic travel and as a result, the support did not top or bottom out.

13

The ZPA loads are those which result from the response of the piping system in the rigid range. These loads are combined with the seismic inertia loads which result from the piping stress analysis. The ZPA and seismic inertia loads are correctly combined using the square root sum of the squares (SRSS) method in the calculation. However, the computer code used to support the Teledyne stress packages does not presently have the capability of combining the ZPA and seismic inertia loads using the SRSS method; it combines them absolutely. Therefore, Teledyne currently "per forms the SRSS combination o f the ZPA and seismic inertial loads by hand. Teledyne's computer program will be modified to perform this function.

Teledyne revised the affected stress packages to address the AISC'eb crippling check.

For all identified deficiencies, the revised calculations resulted in confirming that the existing configuration continues to meet the Turkey Point UFSAR stress criteria, Appendix 5A..

This is documented in Teledyne calculations"'.

To avoid recurring deficiencies, the pipe support criteria will be revised to address baseplate uplift, single angle bending and the AISC web crippling check. The Teledyne computer code will be revised to eliminate the need to perform hand calculations using the SRSS method. These two documents will be revised by March 1, 1990.

Reference:

(1) Teledyne Calculations 6961C-1, Revision 4 "Stress Problem 025" and 6961C-3, Revision 6 "Stress Problem 038/CCW-24" 14

DEFICIENCY 89-203-20: CDR VERIFICATION Discussion: The CDRs for the RPS, CCW, and electrical distribution systems were reviewed. The CDRs were found to contain erroneous and unnecessary information, as follows:

o The CCW chemical mixing pot was inferred to have been replaced when it location on the system.

had only been moved to a different o The CCW pump start sequence description was incomplete.

o The CCW containment isolation valve stroke times were not consistent with the TS requirements.

o The instrument voltage tolerances were improperly specified.

o The methodology for cable short circuit calculations was inconsistent with actual practice.

o The discharge profile was ambiguously defined.

These. concerns led to the conclusion that the CDR had not been appropriately verified. The licensee has agreed to perform some additional verification of the CDR information. The licensee also issued a directive which restricted the use of CDR information in the design process.

This item is unresolved (89-203-20)

FPL Response:

FPL has committed to perform a Component Design Requirements (CDR) verification. In the interim, a directive has been issued which restricts the usage of CDR information. The verification will take place in several stages. First, the accuracy and reliability of CDR information will be improved in a "CDR Repair" project. The main objective will be to provide true component requirements in a clear, concise and verifiable format. Upon completion of "CDR Repair" for the 18 select systems, "CDR Verification" will be performed. This effort will include a verification/validation of CDR information. The scope of this verification will be finalized in procedures, and is expected to focus on key design requirements (attributes) that demonstrate the functional capability of the components. The "CDR Verification" effort is scheduled for completion by June 30, 1991.

15

I DEFZCZENCY 89-203-23: ACCEPTABILITY OF THE MINIMUM BATTERY TERMINAL VOLTAGE Discussion: The minimum end-of-service-life battery terminal voltage is 105 Volts Di,rect Current (VDC) . There is no evidence that the terminal voltage is adequate to power all safety-related devices. The licensee has performed individual voltage drop calculations for load addition or modification. The li.censee has not performed a bounding calculation to show that all devices located remotely from the battery bus will be able to operate successfully.

While some tests have been performed, certain components were bypassed during the testing and were therefore not verified to operate at the low battery terminal voltage.

Adequate assurance does not exist that the combination of the minimum battery terminal voltage and system voltage drop considerations will yield sufficient equipment voltages to maintain equipment functionality.

This is unresolved item 89-203-23.

FPL Response:

A bounding calculation as described above is not a licensing requirement for Turkey Point. Individual voltage drop calculations for load additions and modifications have been performed as necessary. However, to provide additional assurance that all equipment required to operate will do so at the minimum battery terminal voltage of 105 volts, a bounding calculation will be performed..

This calculation will demonstrate the acceptability of the DC equipments'oltage ratings of 105 volts. This work is scheduled for completion by December 31, 1990.

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