ML17347B546

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
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)

See also: IR 05000250/1989203

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 re violations

noted in Insp Repts 50-250/89-203

&50-251/89-203.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

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

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS2 RES MORISSEAU,D

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

DEDRO NRR/DLPQ/LPEB10

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:

The determination

that the heat exchanger pedestal supports are 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 mass is considered, the fundamental

frequency of the branch line will 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 valve lineups were consistent

with approved design drawings and if lineup changes 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, 4-10-1010, 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,