IR 05000353/1988203

Insp Rept 50-353/88-203 on 890103-06.No Violations Noted. Major Areas Inspected:S&W Evaluation of Closed Action Items, Observation Repts to Reflect Action Item Unresolved Issues & Status of Compliance W/Previous Insp

ML20246Q090
Person / Time
Site:	Limerick
Issue date:	03/23/1989
From:	Haughney C, Imbro E, Parkhill R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20246Q086	List: IR 05000353/1988203 ML20246Q082
References
50-353-88-203, NUDOCS 8905220362
Download: ML20246Q090 (45)

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i o U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR INSPECTION AND SAFEGUARDS Report No.: 50-353/88-203 Docket No.:' 50-353 Licensee:. Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit 2

. Inspection At: Stone and Webster Engineering Company Offices

' Cherry Hill, New Jersey-Inspection Conducted: January 3-6, 1989

' Inspection Team Members:

IDA Coordinator E. V. Imbro -Section Chief, RSIB,,NRR IDA Team Leader R. W. Parkhill.iRSIB, NRR .

IDA Mechanical Systems .D.~ Katze, Reactor Engineer, SRXB, NRR M. C. Singla, Consultant IDA Electrical Power Systems S. V. Athavale, Electrical Engineer, RSIB, NRR-

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IDA Instrumentation / Controls J. M. Leivo, Consultant

'IDA Mechanical Components V. P. Ferrarini, Consultant IDA Civil / Structural H. B. Wang', Civil. Engineer, RSIB, NRR

/f Wa,222Y 3-/7-27 Ronald W. Parkhill Date Signed

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IDA Team Leader Reviewed By: /PM & SVId Eugene V." Imbro, Chief 3-/7-F 9 Date Sign 6d j

Team Inspection Development Secti n B Approved By: . S!*5!U Date Signed Charles J. Haugf) Hey,' Chief Special InspecMon Branch,

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TABLE OF CONTENTS PAGE BACKGROUND INFORMATION'........................................... 1 2. . INSPECTION SCOPE AND OBJECTIVE .................................... 1 I N S P E CT I ON D ETAI '.S . . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . . . . . . . . 2 SWEC's fvaluation of Closed Actions Items .................. 2 3.1.1 Mechanit.a1 Systems-Discipline Action Items ................ 2 DAI-019 Shaft Seal Irradiation (Closed) . . . . . . . . . . . . . . . . . . 2 DAI-043 RHR Pump / Motor Seismic Qualification (Closed) .... 3 DAI-047 RHR Pump / Motor Qualification-Hydrodynamic Loads-(0 pen)................................... 3 DAI-067 Parallel Pump Stability (0 pen) ................... 3 ,

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DAI-096 HVAC For RHR Pump Cubical'(Closed) ............... 3 DAI-139 Pressure Loading on Vacuum Breakers (Closed) ..... 4 DAI-172 Internal Clearances for RHR Pump / Motor ,

Qualification (Closed) .......................... 4 !

DAI-176 WaterHammerDocumentation(Closed).............. 5 i DAI-180 RHRSW Pump Minimum Flow Protection and RHRSW RadiationMonitor(Closed)...................... 5 ,

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DAI-196 HVACDrawings(Closed)........................... 5 DAI-215 Spray Pond Chemistry (Closed) .................... 6 DAI-217 Drywell Temperature Discrepancy'(Closed) ......... 6 DAI-224 Equipment Qualification of Butterfly Valve (C1osed) .................................. 6 DAI-226 Equipment Qualification of Butterfly  :

Valve (Closed)..................................

DAI-264 RHR Pump Hydrostatic Test and Maximum Partial

Size (Closed) ................................... 7 i DAI-266 Data Inconsistency (Closed) ...................... 8 ;

DAI-281 RHRSW Pump Seismic Report (Closed) ............... 8 !

DAI-286 Moderate Energy Line Break (Closed) .............. 8 <

RHR Design Specification Input Data 9 DAI-311 DAI-340 Moderate Energy Line Spray (Closed) .............. (Closed) ..... 9 ;

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DAI-370 RHR Pump B Cubicle Cooling (Closed) .............. 9 DAI-381 PipingDocumentation(Closed).................... 10 DAI-411 RHRSW Piping Corrosion Allowances (Closed) ....... 10 DAI-412 Erosion / Corrosion Program (Closed) ............... 10

1 DAI-422 Mini-Flow Orifice Maximum Pressure (Closed) . . .. . .

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DAI-438 Design Pressure of the RHR System (Closed) ....... 11 3.1.2 Electrical Power Systems Action Items ..................... 11 DAI-028 Technical Bases for Sizing High Voltage Switchgear (Closed) ............................. 11 DAI-076 Unverified Assumption Used in Short Circuit  ;

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Calculation (0 pen).............................. 11 l DAI-091 Electrical Load Study (Closed) ................... 11

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DAI-119 Fire Hazard Associated With High Relay Setting (0 pen).................................. 12 l

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PAGE DAI-120 Setting of DG Overcurrent Relay (Closed) ......... 12 i DAI-143 Input Inconsistencies Between the Calculation

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for Load Study and for DG Loading (Closed) ...... 13 DAI-145 DG Loading Calculation (Closed) .................. 13 DAI-261 Battery Sizing Calculation (0 pen) ................ 13 DAI-270 DC System Short Circuit Calculation (Closed) ..... 14 DAI-322 Justification for Assumed Voltage Drop (Closed) .. 14 DAI-359 Isolation Between Non-Class 1E Load and Class 1E Bus (Closed) .................................... 14 j DAI-421 Assumed Loads Without Justification (Closed) ..... 14  !

3. Instrument and Control Action Items ....................... 14 DAI-034 Clarification of FSAR Definition and Intent Regarding Annunciation that Supports RG 1.22 Conformance (Closed) ............................ 14 DAI-049 Discrepancies in EQ Documentation for Rosemount Transmitters (Closed) ........................... 15 DAI-086 Acceptability of Not Showing NonSafety Tubing on Drawings (Closed) ............................ 15 DAI-122  ;

P&ID Discrepancies and Scope Regarding)

of Supply (Closed Signal Interface

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DAI-131 Possibility of Low Points in Instrument Flex Hoses (Closed) .................................. 16 DAI-156 Basis for Installed Qualified Life for Rosemount i Transmitters (Closed) ........................... 16 DAI-171 Basis for Equivalency of IEEE Std. 344-1971 Qualification to IEEE STD. 344-1975 (Closed) .... 16 DAI-182 Basis for EQ Data for Procurement of Certain Transmitters (Closed) ........................... 16 DAI-184 Addressing Concerns of IEN 85-100_(Zero Shift in Rosemount Transmitters)-(Closed) .............. 17 DAI-251 Basis for Installed Qualified Life for Fan t

Cabinet (Closed) ................................ 17 i

DAI-289 Conformance to RG 1.97 Regarding Identification of Instruments (Closed)............................ 17 DAI-290 Discrepancies in Installed Instrument Scale Ranges vs. FSAR (0 pen) ................................. 17 l DAI-297 Basis for Replacement of Air Solenoid Valve with

j ValveHavingSmallerOrifice(Closed)........... 18 l

DAI-367 Discrepancies Between Elementary Diagrams and FSAR Regarding Radiation Monitor Alarm / Logic Circuits (Closed)............................... 18 3.1.4 Mechanical Components Action Items ........................ 18 DAI-062 Branch Pipe Decoupling Criteria (Closed) .. .. .... . 18 DAI-105 Stiff Clamp Local Stresses (Closed) .............. 19 DAI-107 Review of Pipe Support Calculation

DLA-212-C23 (Closed) ............................ 20 DAI-127 Pipe Stress Analysis - Chugging Loads (Closed) ...

DAI-128 Pipe Stress Analysis - As-Built l Reconciliation (Closed) .......................... 20 DAI-132 Pipe Supports Attached to Building Structural Steel (Closed) .................................. 20

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r-DAI-146'-Vendor Designed Hanger Critical Pipe

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Supports (Closed) ............................... 20 DAI-147 Piping As-Built Reconciliation (Closed) ........... 21 i'

' DAI-151 L Pipe, Stress Analysis Program ~ Error (Closed) . ....... .21,

~DAI-174- Pipe Supports Attached'to Embedded

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Plates (Closed).................................. 21 b DAI-204' Equipment Nozzle Loads (Closed) .................. 21

" DAI-206 ' Pipe Stress Analysis Undocumented- '

-Discrepancies (Closed)..........................

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DAI-240 Seismic Qualification of Motor Operated Gate l Valv'e F0-47B (Closed) ...........................- 22 DAI-271 Verification of RHR Heat Exchanger Nozzle f Loadings-(Closed)............................... '22 l

DAI-308 Axial Restraint-Load Distribution and Weld Size-(Closed)................................... 23 DAI-468 Anchor Computer Program Weld Design.(Closed)'..... . 23 3.1.5 Civil / Structural Action-Items ............................. 24

'DAI-030 QA and Inspection Requirements Not in Engineering r Specifications (Closed) ......................... 24

.DAI-052 Discrepancies Between FSAR an Calculations (Closed)........................... 24 DAI-081 Requirements for Certain Materials Not Included

+ in Engineering Specifications-(Closed) .......... 25 Omission of Interior Walls in Rigidity Analysis

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DAI-095  !

Without Justification (Closed) ~ . . . . . . . . . . . . . . . . . . 25 i DAI-123 Purpose and Validity of Frequency Adjustment i

' Factors and Frequency. Variations (Closed) ....... 25 'l DAI-148 . Inconsistency Applying Seismic' Loads (Closed) .... 26 l DAI-153 Inconsistency in Design of Floor - .;

Diaphragms (Closed)............................. 26 4

' DAI-234 Inconsistency Between Engineering Drawing and

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As-BuiltCondition'(Closed).................... 26

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DAI-272.. Discrepancies Between Field Change Request (FCR) and Construction Drawing (Closed) ......... 27 DAI-299 SRV Discharge Load of One' Unit was Not Analyzed

'fortheOtherUnit(Closed)..................... 27 DAI-300 Unjustified Increase in Concrete Modulus (Closed) ................................ 27 DAI-305 Inconsistencies Between Engineering Drawing and Vendor's Fabrication Drawing (Closed) ........... 28 i DAI-341 Cadwelds in the Reactor Building Not Shown on the l As-Built Drawing (Closed)'....................... 28 DAI-350 Unjustified Reduction of Negative Moment in Concrete Design (Closed) ........................ 28 DAI-361 No Elevation of Actual Attachment Loads (Closed) .....'.............................. 29 j DAI-429 Inconsistencies and Unjustified Factors on i Box-Beam Design (Closed) ........................ 29 DAI-432 Unjustified Increase of Allowable Compressive Stress-(Closed)................................. 30 DAI-433 Biaxial Bending in Box Beam Design (Closed) ...... 30 TC-3

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'3.2- Review of Observation Reports for Proper Inclusion of Action Item Issues ...................................... 30 3.2.1 Mechanical Systems Observation Reports .................... ~

D0R-023 SRV Discharge Piping Loads (Closed) .............. 30 l DDR-025 RHRSWPumpCalculations(Closed)................. 31 00R-046 Blowdown Flow From HELB (Closed) ................. 31 3.2.2 Electrical Power Systems Observation Reports .............. 31 00R-042 DG Voltage Regulation (Closed) ................... 31 3. Instrumentation and Controls Observation Reports .......... -32 00R-021 Inadequate Basis for Balance-of-Plant Q-Functional Setpoints (Closed) ................. 32 DDR-041 QualificationofDuctMountedRTDs(Closed)...... 32

.3.2.4 Mechanical Components Observation Reports ................. 32 00R-022 MSIV Accumulator Tanks (Closed) .................. 32 D0R-028 Local' Stress Evaluation - Stanchion to Elbow (Closed).................................. 32

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3.2.5 Civil Structural Observation Reports ......................

D0R-036 Inappropriate Assumptions in Reactor Building Sei smic Analysi s (Cl osed) . . . . . . . . . . . . . . . . . . . . . . . 33 00R-040 Thermal Load was not Considered in the Design ofStructures(Closed).......................... 33 1 Status of Previous IDA Inspection Report (IR) Findings .... 34 3.3.1 Mechanical Systems Previous IR Findings ................... 34 3.3.1.1 Control Valve Sizing Review (Closed) .................... 34 3.3.1.2 RHRSWPumpNPSHReview(Closed)......................... 34 3.3.1.3 Pressure Relief Valve Sizing Review (Closed) ............. 34 ,

3.3.1.4 Air Operated Accumulator Review (0 pen) .................. 34 l 3.3.2 Electrical Power Systems Previous IR Findings ............. 35

3.3.2.1 Off-site /On-site Power Interconnection (Closed) .........

3.3.2.2 RHR Pump / Motor Overcurrent Relay Trip Setting (Closed) .. 35 3.3.3 Instrumentation and Controls - Previous IR Findings ....... 35

}- 3.3.3.1 Vital AC Instrument Power (Closed) ......................

l- 3.3.3.2 Single Failure of Schematic Diagrams (Closed) ........... 35 3.3.4 Mechanical Components Previous IR Findings ................ 36 3.3.4.1 Pipe Stress Calculation 2-10-13 (Closed) ................ 36 3.3.4.2 Piping Analysis Overlap (Closed) ........................ 36 3.3.5 Civil / Structural Previous IR Findings ...................... 36 3.3.5.1 Category I Tank Support (Closed) ........................ 36 3.3.5.2 SWEC's Review of Document Supporting Bechtel Response (Closed) ...................................... 36 SWEC Review of ICA Originated Issues ...................... 36 37 General Conclusions .......................................

3.5.1 Mechanical Systems Conclusion ............................. 37 3.5.2 Electrical Power Systems Conclusion . . . . . . . . . . . . . . . . . . . . . . . 38

3. Instrumentation and Control Conclusion .................... 39 l 3.5.4 Mechanical Components Concl usion . . . . . . . . . . . . . . . . . . . . . . . . . .

3.5.5 Ci vil / Structural Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

A-1 l ATTACHMENT A - KEY PERSONNEL CONTACTED ................................ l

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LIMERICK UNIT 2 INDEPENDENT DESIGN ASSESSMENT (IDA)

IMPLEMENTATION INSPECTION, JANUARY 3-6, 1989 BACKGROUND INFORMATION By letter dated July 28, 1988, the NRC informed the Philadelphia Electric Company (PECO) that it had accepted Revision 1 to the utility's " Program for the Independent Design and Construction Assessment (IDCA) of Limerick Unit 2."

The intent of this program is to assess the adequacy of the design end construction process used at Limerick Generating Station Unit 2 by conducting an independent review of selected plant systems, components, and structures associated with the containment heat removal mode of operation of the residual heat removal (RHR) system. The staff viewed the scope of the program to be a comprehensive review of the architect / engineer's design as well as a representative sampling of all major construction attributes including component and s PECO selected Stone & Webster Engineering Company (SWEC) ystem of Cherry testin Hill, New Jersey, to conduct the independent assess-men l To monitor the proper application of the IDCA, the NRC decided to review both the independent design assessment (IDA) and the independent construction assessment (ICA)inthreephases: (1) preparation of review plans by SWEC, (2)

implementation of the review plans and performance of the review by SWEC, and (3) review and evaluation of the SWEC's final IDCA report, including PECO's associated corrective actions. The NRC documented phase 1 of the inspection in Inspection Report 50-353/88-200, including recommendations for additions and clarifications to SWEC's review plans; Phase 2 was documented in Inspection Report 50-353/88-201 for the IDA and in Inspection Report 50-353/88-202 for the IC INSPECTION SCOPE AND OBJECTIVE During January 3 through 6, 1989, the team visited the SWEC offices to evaluation of SWEC's implementation of the IDA. This second inspection was necessary because only a few action items that resulted from IDA had been answered by Bechtel and evaluated by SWEC during the previous IDA implementa-tion inspection. The results of the second IDA implementation inspection are documented herei There were four objectives to this inspectio First, the team was to assess the adequacy of SWEC's evaluation of Bechtel Power Corporation's responses to determine if each Bechtel response had resolved the issue originally raised in the action item. Second, the team was to review an average of two observa-tion reports per discipline to ascertain that the observation report properly reflected the unresolved issues from the associated action item. Third, the team was to review one item per discipline that resulted from each of the two previous inspection reports with regard to the IDA to ensure that SWEC had complied with the previously documented N2C requests. Fourth, the team was to review SWEC's compliance with two verbal reques,s that had resulted, from the ICA inspection: One was to review the specific design of a trunnion on a pipe elbow in the mechanical components discipline and the other was to review the design adequacy of a block wall in the civil structural disciplin _ _ _ _ _ _ _ - _ - _ _ _ _ _ -

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3 INSPECTION DETAILS The inspection team's findings concerning SWEC's implementation of the IDA being conducted on Limerick Unit 2 are discussed below for each of the five disciplines. SWEC had initiated action items to resolve concerns with regard to (1) a licensing or design commitment that may not have been met or (2) the structure, system, or component that may not function as intende If,'after reviewing Bechtel's response to an action item, concerns remained unresolved, SWEC had initiated an observation repor At.the time of this inspection, SWEC had completed reviewing all of the IDA checklists. Of the 484 action items that had been written, SWEC had received Bechtel's responses to all the action items and had issued evaluations to 407 action items (83 percent). SWEC also had written 61 observation reports. At the time of the earlier IDA implementation inspection (October 3-7,1988),

only 14 action items had been. evaluated and 2 observation reports writte The following sections are organized to address the four objectives of this inspection, viz, review of (1) SWEC's evaluation of closed action items, (2)

observation reports to reflect' action item unresolved issues; (3) status of SWEC's compliance with previous IDA inspection report findings; and (4) SWEC's

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design review of two'ICA identified issue .1 SWEC's Evaluation of Closed Action Items (Als).

Before the initir. tion of this inspection, the NRC had reviewed all of the

. design action items (DAls) that SWEC had generated to date and the Bechtel responses and had prioritized the.DAls according to perceived safety signi-ficance. Those DAls that.had the Bechtel response evaluated by SWEC were sorted among the five NRC inspection team disciplines (mechanical systems, electric power systems, instrumentation and controls, mechanical components, andcivil/ structural). Approximately 15 DAls per inspection team member were reviewed to assess the adequacy of SWEC's resolution of those DAI .1.1 Mechanical Systems Discipline Action Items DAI-019 Shaft Seal Irradiation (Closed): SWEC noted that process irradiation conditions for the RhR pump 2BP202 shaft seal were greater than specified in the General Electric (GE) purchase specifications and pump drawings. Bechtel advised that the vendor shaft seal drawing data show the packing would perform its function at higher integrated radiation levels than the normal and accident conditions. This information was to be documented by equipment qualified package MEQE #23-112 for Unit 2 and would take precedence over the other documents in question. SWEC accepted this response since the packing could withstand the radiation levels of normal and accident conditions. However, the

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inspection team was concerned about the use of substitute packing. SWEC said that if other materials were used, a reevaluation of the material to the process and environmental conditions would be required as specified by the '

environmental qualification review record (EQRR), which incorporates the qualification data as part of the Mechanical Equipment Qualification Progra The. inspection team found this resolution acceptable and agreed with the closure of this ite _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ - _ _

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DAI-043 RHR Pum)/ Motor Seismic Qualification (Closed): SWEC reviewed the Ingersoll-Rand Jesign Report DR 2500-4, Revision 0, dated February 12, 1973, !

for the RHR pump and noticed that certain design input data, such as the pumping element naturai frequency and shell stresses, did not agree with an unreferenced GE computer output section attached to the report. SWEC requested Bechtel to verify the adequacy of the input data used by the vendor. Bechtel responded that the GE input / output data were revised after the vendor report was issued and the effect of the revised data was reconciled by GE without requiring a revision to the vendor design report. Bechtel further stated that the vendor calculation has since been superseded by GE's NSSS (nuclear steam supply systes) Loads Adequacy Evaluation and Seismic Qualification Review Team Programs performed in 1983-84 (reference GE documents DRF E11-00016 and DRF HH1-E11-C002, RHR Pump / Motor Dynamic Qualification Summary Report, Revision 3).

On the basis of its review of DRF E11-00016 SWEC accepted Bechtel's response and closed DAI-043. The inspection team reviewed DRF E11-00016 and verified that this document provides comprehensive analysis of the RHR pump / motor, including all current loads and criteria. The team accepted the SWEC's evaluation of Bechtel's response and agreed with closure of this ite DAI-047 RHR Pum3/ Motor Qualification-Hydrodynamic Loads (0 pen): SWEC reviewed hHR pump and RH1 pump motor specifications and determined that they did not contain hydrodynamic loading conditions and acceptance criteria used for current RHR pump / motor qualification documents. SWEC requested that Bechtel identify the documents that establish the equipment qualification for the final design of RHR pump / moto Bechtel responded that reevaluation of equipment qualification adequacy for Limerick Unit 2 RHR pump / motor was being conducted under the NSSS Loads Adequacy Evaluation Program and the Seismic Qualification Review Team (SQRT) Program. Bechtel further stated that the documents referencing this reevaluation would be issued by December 1, 1988. SWEC accepted the Bechtel response and closed this action item without reviewing the ,

NSSS Loads Adequacy Evaluation Program and SQRT program for Unit 2 RHR pump /

motor equipment qualification. However, the inspection team did not agree with the SWEC's evaluation because the RHR pump / motor equipment qualification reevaluation had not been verified. The inspection team recommended that SWEC review the Bechtel documents to ensure the adequacy of the RHR pump / motor equipment qualification. This item remained ope DAI-067 Parallel Pump Stability (0 pen): SWEC raised the issue of unstable parallel pump operation for emergency service syste water (ESW)possible Bechtel responded that the ESW pump head-capacity characteristics would prevent instabilities and that testing on the Unit 1 pump verified operation without instabilit SWEC considered the Bechtel response adequate because of the testing and estimated parallel operation time of about 10 minute However, when the inspection team requested clarification of the testing l configuration, Bechtel, during a telecommunication with SWEC, said that testing was performed for single and not parallel pump operation. SWEC l

committed to further review the pump test data for applicability to parallel

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l DAI-096 HVAC for RHR Pump Cubicle (Closed): SWEC reviewet the P&ID Drawing M-76, sheet 7 of 10, Revision 4, and identified various traceability concern For example, the RHR pump cubicle B supply and exhaust air flow path, air quantities, and dampers were not shown on the P&ID drawing and there was no-3-

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reference to engineering documents, such as flow diagrams, to support the P&ID or the design drawings. Bechtel responded that project decision was made in the mid-1970's to delete air flow diagrams and provide the same information on other project documents. Bechtel stated that typical representation of cubicles with air supply and exhaust or supply and transfer air and typical damper details were shown on the P&ID to aid in preparing HVAC layout drawing Bechtel also stated that Plant Facilities Calculation M-76-2 established air quantities for all spaces, including the RHR cubicles. The calculation was the basis for quantities given on the duct layout drawings. SWEC reviewed Project Letter PLB-2749 from PECO to Bechtel, dated November 30, 1973, to verify the project' decision to delete air flow diagrams. SWEC reviewed the P&ID and verified that sufficient information was provided to aid in preparing the layout drawings for heating, ventilation, and air conditioning (HVAC). SWEC also reviewed the procurement for unit coolers and verified that air flow capacity for the equipnent was shown on the data sheets. However, the team asked SWEC to verify that unit cooler air flow capacity provided in procurement documenta-

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tion was based on the Calculation M-76-2. SWEC verified this. The team accepted SWEC's evaluation of Bechtel's response and agreed with closure of this ite DAI-139 Pressure Loading on Vacuum Breakers (Closed): Vacuum breakers were mounted on the safety / relief valve discharge line (SRVDL) to minimize the reflooding level of water in the line after a safety / relief valve (SRV)

discharge. Numerous reports of damage to these vacuum breakers have been experienced in boiling water reactor (BWR) plants as a result of the pressure loads generated from SRV actuations. SWEC requested that Bechtel ensure that all fluid-induced loads generated from SRV actuations and pressure loads on vacuum breakers had been considered. Bechtel responded that the design loading conditions, including all applicable fluid-induced loads, for the vacuum breakers were defined in Specification 8031-M-81 and that hydrodynamic loads were consistent with the design assessment report for Limerick. Consideration of dynamic impact loads evolved as a result of problems observed with the vacuum breakers on the SRVDL at the Peach Bottom plant and issuance of IE Information Notice 83-26. Bechtel also stated that the pressure loads resulting from SRV discharge and dynamic impact loads resulting from pressure transients had been considered for vacuum breaker design. SWEC evaluated Bechtel's response and concluded that Bechtel provided a controlled, traceable document for loading conditions. Bechtel further stated that it had considered all the applicable loads, including those from the Peach Bottom operating experience and IE Information Notice 83-26. The inspection team accepted SWEC's evaluation of Bechtel's response and agreed with closure of this ite .

DAI-172 Internal Clearances for RHR Pump / Motor Qualification (Closed): SWEC

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reviewed the Ingersoll-Rand Design Report DR 2500-4, Revision 0, dated l

February 12, 1973, for RHR pump equipment qualification and could not determine I

how the internal clearances were affected when pump components, such as shift, impeller and seals were deflected by dynamic loads in order to evaluate the operab511ty of RHR pump. SWEC requested that Bechtel identify the document that demonstrates this comparison. Bechtel responded that GE documents DRF-E11-00016 and HH1-E11-C002, Revision 3, compared pump internal clearances with deflected elements. SWEC verified that these documents include a comparison of pump internal clearances with deflected elements. Although SWEC's evaluation of Bechtel's response did not clearly indicate that operability of RHR pump had-4-

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been verified, SWEC told the inspection team that it had verified the RHR pump-operability. The inspection team reviewed HH1-El-C002, Revision 3, and verified the operability of RHR pump, accepted SWEC's evaluation, and agreed with closure of this ite DAI-176 Water Hammer Documentation (Closed): SWEC requested that Bechtel provide the documentation to identify water hammer design loads and hydraulic transient calculations. Bechtel provided the information and also' identified systems where field testing was performed to verify the conclusions of the analysi This was acceptable to SWEC and the team concurred and agreed with closure of.this ite DAI-180 RHRSW Pump Minimum Flow Protection and RHRSW Radiaticn Monitor (Closed):

3WEC requested that Bechtel substantiate that there was no minimum flow bypass for the residual heat removal service water (RHRSW) pumps and provide justifi-cation as to why the process radiation monitor for RHRSW did not meet Regulatory Guide 1.26. For the minimum flow concern, Bechtel advised that operation procedures in addition to a high-pressure switch (which indicates low pump flow) would protect the pump. SWEC reviewed the pump curve and instrument setpoint data, which indicated the high-pressure switch setpoint was less than the pressure for minimum flow, and found it acceptable. The inspection team requested that the setpoint be checked to ensure it was not set low enough to adversely affect expected system operation conditions. SWEC further reviewed Bechtel Calculation M-11-15 and found the expected operating press.uas to be much lower than the pressure switch setting. The team found this acceptable. With regard to the radiation monitor, Bechtel stated that the monitor was classified as an instrument and therefore exempt from the regulatory guide. SWEC noted that this was consistent with the FSAR Table 3.2-1 and was acceptable. The inspection team concurred with SWEC and agreed with closure of this action ite DAI-196 HVAC Drawings (Closed): SWEC reviewed the HVAC equipment and duct layout drawings and notified Bechtel of its various concerns regarding design traceabilit SWEC found that fire damper FPD-502-31 was shown to be located above the floor, which was e fire barrier, when it should have been located in the floor. Bechtel stated that the installation of fire damper FPD-502-31 shown on Civil Drawing C-616, sheet 1, confirmed that the fire damper door (listed with Underwriters Laboratories, Inc. [UL]),'when closed, would be located in the floor and would maintain fire barrier integrit SWEC could not trace the fire rating fR fire damper FPD-502-27 in the Fire Protection Evaluation Report (FPER). Bechtel advised that all penetrations, including fire damper FPD-502-27, were three-hour rated, even though the floor was not UL rated because of the unrated metal blowout panel SWEC found that RHR pump cubicle B unit cooler coil drainage piping and interfaces ware not shown on the drawings and were not traceable. Bechtel advised that small bore (2" or less) nonseismic Class I piping, such as the unit cooler coil drainage piping, were shown on the isometric drawings prepared at the job site and not on the piping and mechanical drawing In its review, SWEC also found that design drawings show equal flow rates for air supply and air exhaust to the RhR pump cubicle B. This contradicted an FSAR-5-

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commitment (Section 9.4.2.1.1) to maintain the secondary containment at a negative pressure to prevent potential exfiltration of contaminated ai Bechtel stated that air supply and exhaust flow rates shown for RHR pump cubicle B were nominal values; in reality, the exhaust flow rates were slightly higher and varied as a result of continuous changes in outside and inside atmospheric conditions. In addition, pressure differential controllers located in the reactor enclosure were set to control variable pitch exhaust fan air flow rates in order to maintain the required negative pressure. SWEC reviewed Drawings SP SBD-276-ED1 and ED2 for the drain lines to RHR pump B cubicle unit coolers M 2D and 2FV 210 to verify that nonseismic Class I small bore piping isometric o.awings were prepared at the job site. SWEC also reviewed the pressure differential controllers PDC-76-161 -162, -261, and -262 on P&ID M-76, sheets 3, 4, and 9 (set to control the variable pitch blade exhaust fan air flow rates) and Specification 8031-M-69B, sheet 3 of 4 (data sheet for vane axial fans), to verify that the required negative pressure was maintained as per FSAR commitmen The inspection team verified SWEC's evaluation of Bechtel's response by reviewing typical pressure differential controller PDC-76-161 on P&ID M-76, sheet 3. The inspection team agreed with the SWEC's acceptance of Bechtel's response and closure of this ite DAI-215 Spray Pond Che istry (Closed): SWEC requested that Bechtel provide i design criteria documentation that specifies the spray pond water chemistry requirements for the 30-day period following a loss of coolant acciden Bechtel appropriately referenced the FSAR and Environmental Report. SWEC found the data to be consistent and acceptable. The inspection team concurred with SWEC and agreed to closure of this ite DAI-217 Drywell Temperature Discrepancy (Closed): SWEC reviewed Calculation 17-R-17, Revision 0, for the thermal analysis of the pipe rupture restraint supporting structure in the drywell platforms area and requested Bechtel to provide justification for using a drywell temperature of 290*F in the calculation instead of a LOCA temperature of 340 F as identified in FSAR Section 3.8.2.3.4. Bechtel responded that it had recognized in Calculation 17-R-17 that the containment is at ambient operating temperature when the peak pipe impact load resulting from the guillotine break would be achieve Bechtel further stated that a maximum containment temperature of 340'F would be the result of a smill-break accident (SBA) and pipe break reaction loads during an SBA would be negligible. SWEC accepted Bechtel's response and closed the action item. SWEC, however, did not explain clearly in its evaluation the basis far acceptance. However, SWEC did provide verbal clarification to the inspection team. Also, SWEC reviewed the temperature profiles for all modes of steady state blowdown discussed in FSAR and verified that 290 F temperature enveloped all the conditions. ine inspection team reviewed the FSAR Figures 6.2.4, 6.2-13 and 6.2-15 and accepted the SWEC's response evaluation and agreed with closure of the ite DAI-224 Equipment Qualification of Butterfly valve (Closed): SWEC reviewed equipment qualification Package D-60 for the qualification of 18-inch butterfly valve FO-488 and noted that the operability of the valve / operator assembly-6-

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'during the hydrodynamic loading was not discusse SWEC requested that Bechtel L identify the document used to confirm butterfly valve operability during hydro-dynamic loading. Bechtel responded that the assurance of valve operability during hydrodynamic loading was provided in the valve analysis report 8031-M-242.1-36-2 with the supporting arguments that tM valve calculated stresses were well:below yield stress, calculated deformations were very small and the valve had virtually no extended actuator. Bechtel also stated that Package D-60 will be revised to include these arguments. SWEC acceptea the Bechtel's response based on the supporting arguments / justifications and closed the action item. The inspection team reviewed the calculated maximum vertical and horizontal deflections in the valve assembly that would result from the combined seismic and operational loads occurring at the top of valve and judged-them to be very small. The inspection team agreed that valve analysis adequately demonstrated the operability of the valve / operator assembly and with closure of this ite DAI-226 Equipment Qualification of Butterfly Valve (Closed): SWEC reviewed the equipment qualification Package D-60 for 18-inch butterfly valve F0-48B and requested that Bechtel identify the source documents that provided the values for a set of valve accelerations and confirm whether the final loads from the as-built piping analysis and requirements for hydrodynamic loadings would be incorporated into the design specification. Bechtel stated that Unit 2 accelerations were documented in plant design Calculations 2-10-83, Revision 4, and 2A-294, Revision 0 and were in the process of being incorporated into Package D-60. Bechtel confirmed that the analyses for the procured valvet, were reviewed for compliance with as-built load and the valves were found acceptable to the current seismic / dynamic loads as well as hydrodynamic load cycles. SWEC accepted Bechtel's response on the basis that, although as-built accelerations exceeded the specification level, reconciliation of the higher loads was performed by supplementary cnalysis and the qualification for the existing valve design was maintained. Since this qualification encompassed valve replacements to the existing specification when identical valves were procured, it was not necessary to revise the specification to incorporate final loads or hydrodynamic requirements. The inspection team reviewed the SWEC's evaluation of Bechtel's response and agreed with closure of this ite DAI-264 RHR Pum) Hydrostatic Test and Maximum Particle Size (Closed): SWEC reviewed the RH1 pump specification and noticed that hydrostatic test pressure requirements for the pump were conflicting.between Specification 21A9243, Revision 0, and Data Sheet 21A9243 BV, Revision 4. SWEC requested that Bechtel

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confirm that the hydrostatic test pressure used was adequate. SWEC also reques-ted Bechtel to confirm that the cyclone dirt separator was designed to remove-solid particles having a size up to 1/16 inch from the RHR pump seal cooling water. Bechtel responded that the RHR bowl was not a pressure-retaining part because it was inside the pump suction case or can of the vertical multistage

. pump -- the bowls contain stage discharge pressure inside, and case or suction pressure on the outside. Bechtel confirmed that a hydrotest pressure of 1.5 times the design pressure met the applicable code requirements and was normally applicable to all parts tested. Bechtel also confirmed that the cyclone separator could accommodate particle sizes from 10 microns to 1/8 inc '

Particles smaller than 10 microns would be carried through without having any effect on the pump seals. SWEC's evaluation of Bechtel's response included-7-

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the review of the vendor's Hydrostatic Test Report 8031-M-1-Ell-C002-V-4 ,

The report confirmed that RHR pump casing bowl was actually hydrotested at a i

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pressure of 2000 psi, which is higher than the 1.5 times the design pressur SWEC also accepted the Bechtel response regarding maximum particle size by cyclone separator because the suction strainers were designed to handle par- 4 ticles greater than 1/16-inch; hence the control flow orifices would not be obstructed. The inspection team reviewed the vendor's Hydrostatic Test Report 8031-M-1-Ell-C002-V-48.1 and verified that RHR pump casing was actually hydrotested at 2000 psi. The inspection team agreed with SWEC's closure of this ite DAI-266 Data Inconsistency (Closed): SWEC noted four concerns in this action item, but the inspection team only considered two for review: (1) inconsistent-cies between equipment qualification (EQ) data, GE process diagrams, and GE pump specifications and (2) inconsistent ambient air temperatures between Specification M-171 and FSAR Table 9.2-11. The Bechtel response indicated that the EQ data was generated by its mechanical group based on the GE diagrams and pump specifications. SWEC found this acceptable. At the team's request, SWEC provided and explained the relationship between the vendor head-capacity curves, the GE specification 21A9243BV and the GE process diagram and the FSAR to justify this acceptance. The inspection team concurred with SWEC's conclusion. Bechtel further explained that the difference in ambient air temperatures between Specification M-171 and the FSAR table was intentiona One profile was used to obtain a conservative estimate of heat transfer in containment, and the other to maximize water consumption and minimize heat transfer for the spray pond. SWEC found this acceptable and the inspection team concurred with closure of this ite DAI-281 RHRSW Pump Seismic Re3crt (Closed): SWEC reviewed the RHRSW pump vendor document and noticed tlat vendor seismic analysis report 8031-M-12-15-4, Revision C, was not distributed to Bechtel's mechanical / stress group. SWEC requested Bechtel to confirm whether the RHRSW pump nozzle loads as specified by vendor were used for the RHRSW pump discharge piping stress analysi Bechtel responded that the last submittal of the vendor report was changed to incorporate editorial comments only and the previous submittal of vendor report was routed to mechanical / stress group. Bechtel confirmed that pump nozzle allowable loads given in the vendor report were used for the RHRSW pump discharge piping stress analysis. SWEC accepted Bechtel's response without verifying whether vendor seismic analysis report V.D. 8031-M-12-15-4, Revision C, specifying pump nozzle loads, was ever distributed to the mechanical stress group. SWEC pursued this verification with Bechtel and resolved this action item to the satisfaction of the inspection team. The team agreed with closure of this ite DAI-286 Moderate Energy Line Break (Cicsed): SWEC noted that Calculation NPB-14 for the moderate energy line break analysis did not provide adequate documentation to confirm the worst-case pipe crack in each fire zone. The Bechtel response noted that this was due to an incorrect transposing of data from Unit I to Unit 2 for fire zones and the use of yorst case equilibrium flood heights where flooding rates were questioned. Bechtel advised that the fire zone designations were planned to be corrected based on G-23 walkdown results. SWEC found this acceptable and told the inspection team that SWEC had l

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e t confirmed that the equilibrium flood heights were documented and that the calculations appeared to be reasonable. The inspection team agreed to closure of this ite DAI-311 RHR Design Specification Input Data (Closed): SWEC reviewed Specification M-551-2, Revision 0, and noticed that thermal modes and number of cycles were based on the histogram for low-pressure coolant injection (LPCI).

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SWEC, however, could not trace the source documents used to generate the load histogram and requested that Bechtel identify these documents. 'Bechtel responded that the load histogram was based on GE Drawing 761E708 and these data were also presented in tabular form in GE Design Specification 22A2919, Nuclear Boiler Systems. SWEC reviewed the validity of the histogram from a piping stress analysis perspective (normal and upset for fatigue evaluation)

- and determined that'the histogram was consistent with transient data provided in GE Specification 22A2919 and that the transient data given in this specifi-cation was for core spray and was conservative. Therefore, SWEC accepted the Bechtel's response and closed the DAI-311. The inspection team requested SWEC to verify that the transients given GE Specification 22A2919 were

- conservative. SWEC verbally explained that this was based on the comparison of transients with similar designs, engineering judgment and general industry practice. The inspection team accepted SWEC's evaluat.an of Bechtel's response and agreed with closure of this ite DAI-340 Moderate Energy Line Spray (Closed): During a walkdown of RHR cubicle B, a concern was raised about the effect of moderate energy line spray on safety-related equipment. SWEC observed that potential spray from reactor core isolation cooling (RCIC) lines could impinge on unprotected RHR pump motor Bechtel's response identified safe shutdown pathways that considered spray from the RCIC line disabling the RHR pump motor, including postulation of a single failure that would leave one RHR system operable. SWEC found this response to adequately demonstrate that system interaction between RCIC and RHR, including single-failure effects, would not prevent safe shutdown of the plant. The inspection team accepted SWEC's evaluation and agreed with closure of this ite DAI-370 RHR Pump B Cubicle Cooling (Closed): As a result of a ~ site walkdown I of the RHR B pump cubicle, SWEC expressed concern about the adequacy of cooling in the upper level. above the floor grating of the cubicle. Bechtel advised that the available cooling was adequate because the lower level coolers had large recirculation air flow rates with high. discharge velocities into a total volume of 78,000 cubic feet. The cooling capabilities, an area of 78 percent free of grating, and small upper level heating loads would allow adequate heat removal at the higher elevations. SWEC confirmed the cubicle volume, recirculation. air flow rates, discharge velocity and accepted Bechtel's response as adequate. SWEC further explained to the inspection team that it had reviewed Bechtel Calculation M-76-2 and determined that heat loads of the upper level were intermittent and extremely small compared to the loads below the grating. Also, the cooler fan discharge velocity of 2200 feet / minute was much higher than that normally provided (1200-1500 feet / minute) so that, with a large area free of grating (as observed in the walkdown), upper level cooling l would be adequat The inspection team accepted SWEC's evaluation and agreed j t

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DAI-381 Piping Documentation (Closed): SWEC noted that the spray piping in the reactor pressure vessel head was not included in Specification G-23, for separa-tion review of the high-energy system. Bechtel advised that the piping was installed in Unit 1. However, the utility decided not to install it in Unit 2 and also to remove it from Unit 1. The changes would be documented in the FSAR when completed in the plant. SWEC found that this resolved the inconsistencies in the FSAR and was acceptable. The inspection team expressed concern about the safety significance associated with removing the piping, but SWEC told them that GE had reviewed and approved removal of the piping as document FDDR HH2-847 The inspection team accepted SWEC's evaluation and agreed with closure of this ite DAI-411 RHRSW Piaing Corrosion Allowances (Closed): SWEC requested that Bechtel verify t1e range of corrosion allowances for the RHRSW system pipin SWEC accepted Bechtel's response and noted that the information was in accordance with the appropriate section of the FSAR. SWEC further explained to the inspection team that the corrosion allowances were applied in a satisfac-tory manner. The inspection team accepted SWEC's evaluation and agreed with closure of this ite DAI-412 Erosion / Corrosion Program (Closed): SWEC requested that Bechtel discuss the program to address erosion / corrosion potential for the RHR system. Bechtel advised that corrosion allowances were addressed in Specification 8031-P-300 and were based on GE recommendations for the RHR syste Erosion was based on material, pipe size, and piping layout. Bechtel further advised that as a result of IE Bulletin 87-01, Unit 2 was developing a program to monitor wall thinning that may result from erosion / corrosion. However this would not include the RHR system since it is normally not in operation. SWEC found the response acceptable because Unit 2 was developing a program for erosion / corrosion. The inspection team concurred with SWEC's evaluation and agreed to closure of this ite DAI-422 RCIC Mini-Flow Orifice Maximum Pressure (Closed): SWEC reviewed the l

l process data for sizing of the RCIC minimum flow return line orifice and noticed that the orifice Data Sheet M-229, Revision 13, had the maximum pressure as 1500 psig while the process diagram for RCIC system had a maximum pressure of 1575 psig. SWEC requested that Bechtel resolve the inconsistenc Bechtel responded that the process data for sizing the orifice was taken from GE's design specification Data Sheet 22A1354 BA, Revision 11. The maximum

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pressure of 1500 psig shown on the orifice data sheet was based on the RCIC pump Data Sheet 21A9243 BJ, Revision 4, which showed tne RCIC pump maximum l

I shutoff head and design pressure to be 1472 psig and 1500 psig, respectivel Hence the orifice design was consistent with GE requirements. SWEC accepted the Bechtel's response and closed the action item. SWEC, however, did not clarify the inconsistency between GE's process Diagram 731E769 AD, Revision 3, l

for RCIC system and GE's design specification Data Sheet 22A1354 BA, Revision 1 The inspection team requested SWEC to resolve this discrepancy. SWEC reviewed the GE Process Diagram 731E769 AD, Revision 3, and verbally confirmed that 1575 psig shown on the process diagram was " peak pressure," which was the maximum pressure anticipated during a transient period and was expected to occur less than 1 percent of system operating time; it was not the maximum pressure-10-l _ . _ _ _ _ ._ -

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anticipated during steady state operation of the system. Hence, there was no inconsistency between the GE documents. The inspection team reviewed the GE 4 design specification Data Sheet 22A1354 BA, Revision 11, and RCIC pump Data Sheet 21A9243 BJ, Revision 4, and verifi6d that 1500 psig design pressure for the orifice was adequate, the team agreed to closure of this ite j DAI-438 Design Pressure of the RHR System (Closed): SWEC told Bechtel that the a 1340 psig design pressure of the RHR system piping, which formed part of the unisolable reactor coolant pressure boundary, was below the 1375 psig maximum pressure expected during an ATWS event per GE design Data Sheet 22A2962 AB, Revision 9. SWEC requested that Bechtel confirm that the ATWS event condi-tions were considered in the piping design. Bechtel responded that when GE issued the ATWS peak pressures and peak temperatures for Limerick, the design ,

parameters for the piping and valves were reviewed to determine if any rework or additional engineering effort would be require Bechtel considered an ATWS event as an emergency condition in accordance with NUREG-0460 and concluded that 1340 psig maximum design pressure used for the piping was adequate, since it satisfied the ATWS peak pressures and temperatures for emergency condition The inspection team accepted SWEC's evaluation of the Bechtel response and agreed with closure of this ite '

3. Electrical Power Systems Action Items DAI-028 Technical Bases for Sizing High Voltage Switchgear (Closed): SWEC found that Bechtel documents were not consistent relating to the definition of high voltage switchgear and the Bechtel design did not indicate the technical bases used for sizing of the grounding cables. In its response, Bechtel provided clarification for the term "high voltage" as it applied to switchgear and referenced the standards that were used for sizing the ground conductor SWEC accepted Bechtel's response; the inspection team concurred and agreed with closure of this ite DAI-076 Unverified Assumption Used in Short Circuit Calculation (0 pen): During review of Calculation 6900.E.14 for AC penetration assembly devices, SWEC found that the Bechtel design was based on an assumption that the value of fault currents resulting from a three-phase fault would always be more than a line-to-ground fault. SWEC told Bechtel that this assumption might not be true for all instances. In its response, Bechtel proved that for the subject calculation this assumption was valid. SWEC accepted Bechtel's response and stated that, although the assumption used by Bechtel was true for the subject calculation, for a line-to-ground fault at the solidly grounded substation terminal, fault currents could generate more than the three-phase faul However, the hRC team believed that this matter needed further investigation, since equipment sized an three-phase fault currents might not be adequate. SWEC agreed to further investigate this action ite DAI-091 Electrical Load Study (Closed): SWEC noted several errors and i inconsistencies during review of Calculation 6300.E.18 for the electrical load study. As-built loads were found different than those used for the calcula-tion. It appeared that core spray pump motor of 600 hp was undersized for its calculated 660 hp application. In its response, Bechtel justified the motor  !

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rating. Bechtel further stated that continuous operation of a motor within the service factor rating was allowed per NEMA Standard MG-1, provided the voltage'and frequency were maintained at the nameplate rating. Bechtel indi-cated that the distribution system at Limerick was designed to provide precise voltage regulation. SWEC verified that the transformers associated with all three off-site power sources, were equipped with on-load tap changers designed to maintain motor terminal voltage at or above the rated value. The inspection team was concerned that operation of this motor with a load equal to service factor of 1.1 (660/600) combined with voltages lower than its rated value, would. force more current through the motor winding, raising its tempera-ture, and thus reducing the qualified life of the motor. During discussions with SWEC, the inspection team was told that since this motor would only be run intermittently for periodic testing, the terminal voltage could be maintained at or above the rated value by the voltage regulator and tap changers. Loss of any qualified life as a result of the lower operational voltage would be negligible. With regard to the concern about mismatch of load totals, the Bechtel response stated that although some as-built loads were found higher than their assumed value, some were found less; thus the total of all loads for this calculation would not change very much. SWEC verified that the total of as-built bads was within capacity of regulating transformer, safeguard transformer (using its short-term rating), and all associated equipment of ac distribution system. SWEC also verified that the as-built loads were used for diesel generator (DG) sequential loading and acceleration timing analysi On the basis of these verifications, SWEC accepted Bechtel's responses; the inspection team concurred and agreed with closure of this ite DAI-119 Fire Hazard Associated With High Relay Setting (0 pen): With regard to '

Calculation 6900E.09, Generator Protection Relays, SWEC noted that when the 4-kV buses were fed from the DG, the ground fault relay set at 18 amperes would protect only 55 percent of the connected motor windings. SWEC suggested that a 4 ampere setting might protect up to 90 percent of the windings. In its response, Bechtel stated that there was no design criterion that required a relay to protect 90 percent of the winding protection while the buses were fed from the DG and that the relays were currently set at the lowest setting; therefore, a setting of 18 amperes was appropriate. Bechtel further added that the setting of 18 amperes would make this relay very sensitive to ground faults because of the very high values of the ground fault currents when the bus was powered from the safeguard transformer. SWEC agreed with Bechtel's respons However, although the inspection team agreed that the relay would actuate almost instantaneously on a ground fault while the bus was fed from the safeguard trans-former, the inspection team was concerned that the relay might be slow and not as sensitive to ground faults while the bus was fed only from the DG. In this case, when the bus was connected only to the DG, a ground fault current up to l 18 amperes passing through the fault arc could be undetected and might become a fire hazard. SWEC agreed to pursue this matter further with Bechtel. This item remained ope DAI-120 Setting of DG Overcurrent Relay Situation (Closed): With reference to Calculation 6900.E.09, for DG protection relays, SWEC noted that DG overcurrent relays were set at 906 amperes. Under stuck regulator conditions, the relay would never operate because the generator fault contribution resulting from synchronous impedance would be limited to 605 amperes. Bechtel stated that the individual feeder overcurrent relay would clear the fault in that circuit and-12-

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if-the' fault was between the DG and the DG breaker, or at the bus, it would be -

- cleared by:the differential protection relays for these circuits. SWEC accepted Bechtel's response, and the inspection team concurred with SWEC's evaluation and agreed with closure of this ite DAI-143 Input Inconsistencies Between the Calculation for Load Study and for DG Loading (Closed): 5WEC noted inconsistencies for input sources between Calculation 6380E.07 for D3 loading and Calculation 6300E.18 for the electri-cal load study. In its response, Bechtel provided clarifications for these inconsistencies. SWEC evaluated the Bechtel response and noted that these inconsistencies did not impact the capacity of the associated equipmen The inspection team concurred with SWEC's evaluation and agreed with closure of this. ite DAI-145 DG Loading Calculation (Closed): SWEC noted that Calculation 6380E.07, Revision 2, for DG loading (steady state) did not describe methodology, did not account for losses in the load center transformers, and did not address o transient loading of the DG. In its response, Bechtel sthted that the inten-tion of this calculation was to address only the steady-state loading of the D For transient loading of the DG Bechtel had performed Calculation 6300E.08. SWEC reviewed Calculation 6300.08 and found it acceptable. For the concern about not accounting for losses of the load center transformer, Bechte stated that the DG had sufficient capacity to absorb all the added loads resulting from this error. SWEC verified the capacity of the DG and closed this action item. The inspection team concurred with SWEC's evaluation and agreed with closure of this. ite DAI-261 Battery Sizing Calculation (0)en): SWEC noted that Calculation 6600E.03, Revision 3, for sizing of t1e 125/250-V de station batteries and Calculation 6600.E.09, Revision 2, for the dc-load study, did not include loads for the ac breaker shunt trip, the'ac breaker charging motor, and the ac breaker de closing coils. In addition, the inverter load was assumed to be used at 30 percent of its rating instead of 100 percent. In its response, Bechtel stated that since all engineered' safety feature (ESF) load breakers would trip instantly on the load shed signal, loads resulting from shunt trip coils had been considered in the first-minute duty cycle of the batter However, loads resulting from closing coils and charging motors were not considered in the first-minute duty cycle because ESF load breakers close in sequential order on a loss of offsite power (LOOP) after the DG was on line; and, after each breaker was closed, the charging motor of that. breaker was energized from the DG via the battery charger. In addition, loads that result from closing coils and charging motors have been enveloped by the higher loads occurring in the duty cycle of the battery. .Section size was calculated using the highest value involved. -SWEC accepted this response and the inspection team concurred with SWEC's evaluation. For the concern about the inverter load being 30 percent rather than 100 percent of its rating in the battery sizing calculation, Bechtel explained that although it did not account for the 100 percent rating of the inverter, it had used 100 amperes as a conservative estimated load. SWEC agreed with Bechtel's response. However, the inspection '

team believed that either 100 percent rating of the inverter should have been used or controls should have been put in place to account for any future load increase. In the absence of any control, an undetected high-impedance fault-13- l L__________ !

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on the output side of the inverter might cause an unanticipated burden on the Class IE batteries. SWEC agreed to pursue this matter further with Bechte This item remained ope DAI-270 DC System Short Circuit Calculation (Closed): SWEC noted that Bechtel l did not use the industry accepted Thevenin's method for circuit analysis in ]

Calculation 6380E.10, Revision 1, for DC System Short Circuit Study. In  ;

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addition, Bechtel used 120 volts as a source voltage instead of 125 volts for calculating fault currents in the de system. In its response, Bechtel stated that the method shown in GE's Industrial Power System Data Book was used for the circuit analysis. SWEC analyzed the circuit using Thevenin's method and a source voltage equal to 125 volts and found the short circuit currents to be 15 percent higher than those calculated by Bechtel. SWEC evaluated the rating of all the associated equipment for'these higher currents and found that the ratings of the dc system equipment exceeded this higher value of the short circuit currents. Therefore, although Bechtel's calculation method was not conservative, SWEC determined that it did not adver aly effect the ratings of any installed equipment. The inspection team concurred with SWEC's evaluation and agreed with closure of this ite DAI-322 Justification for Assumed Voltage Drop (Closed): SWEC noted that in Calculation 6300.E.23, Revision 2, for the Millstone undervoltage study a voltage drop of 1.5 percent was assumed for each of the distribution sections betweenloadcenterandbranchloadstothemotorcontrolcenter(MCC).

Bechtel did not give any reference for this assumption nor did it verify this value to be the worst case. Bechtel responded stating that the voltage drop value used was the worst-case value and was a basis for cable sizing. SWEC found Bechtel's response acceptable; the inspection team concurred with the SWEC evaluation and agreed with closure of this ite DAI-359 Isolation Between NonClass 1E Load and Class 1E Bus (Closed): On the basis of its review of one line Diagram 8031-E-16, Revision 15, and FSAR Section 8.1.6.1.14a(d), SWEC requested Bechtel to justify connecting the nonClass IE dry well coolers 2AK111 and 2BK111 to the 4-kV Class IE buses without an isolation device. In its response, Bechtel indicated that the

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nonClass IE dry well chillers were connected to Class IE buses with the proper I

isolation devices. SWEC accepted Bechtel response; the inspection team concurred and agreed with closure of this item.

i DAI-421 Assumed Loads Without Justification (Closed): During its review of Calculation 6600.E09, Revision 2, for the 125/250-V de load study, SWEC noted that several load values were assumed. In its response, Bechtel provided proper references and justification for these locds. SWEC accepted Bechtel's response, and the inspection team concurred with SWEC's evaluation and agreed to closure of this item.

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3. Instrumentatit Fd CoWo1 Action Items i

DAI-034 Clarification of FSAR Definition and Intent Regarding Annunciation '

That Supports R6 1.22 Conformance (Closed): SWEC requested that Bechtel clarify conformance to Regulatory Guide (RG) 1.22 with regard to the FSAR statement: " Collective annunciation of bypassing by manual means is considered

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I to satisfy the guidelines." Bechtel explained that this statement referred to I the practice of grouping several alarm inputs from a common safety division into one alarm window and that individual status lights are provided for each alarm input. . " Bypassing by manual means" referred to the manual actions taken to bypass automatic initiation of a protection system for testing or maintenance. SWEC determined that this clarified Bechtel's position was ,

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acceptable and the inspection team concurred and agreed with closure of this ite DAI-049 Discrepancies in EQ Documentation for Rosemount Transmitters (Closed):

SWEC identified apparent discrepancies between the EQ data package provided by Bechtel to support qualification of the RHR heat exchanger outlet flow l transmitters and the EQ Master List and installed transmitters. The EQ data I package was for Rosemount 1151 series transmitters, but the installed transmitters and the Master List transmitters were identified as Rosemount 1153 series. Also, the material requisition / purchase order (MR/P0) numbers shown on j the Master List were inconsistent. In its response, Bechtel indicated that the  !

Unit 2 EQ effort was still in progress; Unit I data packages were being upgraded as required to incorporate appropriate Unit 2 documentation; Unit I data packages had been provided to SWEC in an attempt to provide preliminary information for the incomplete Unit 2 EQ program; for this application, Unit I uses 1151 series transmitters and Unit 2 uses 1153 series transmitters, so the Master List and installed instruments were correct; however, the MR/P0 reference was incorrect for one of the transmitters. Bechtel subsequently provided the proper EQ package for the Unit 2 transmitters and indicated that the Unit 2 Master List references were being corrected as a part of the overall Unit 2 EQ program. On the basis of SWEC's acceptance of the correct EQ data package and Bechtel's commitment to complete the Unit 2 EQ program to correct these and other discrepancies, the inspection team agreed this item could be closed. However, because of several similar EQ discrepancies SWEC found in the ongoing EQ program, the inspection team suggested these EQ items be summarized in SWEC's final IDA repor DAI-086 Acceptability of Not Showing NonSafety Tubing on Drawings (Closed):

SWEC identified a Bechtel instrument location drawing that did not show all tubing runs when compared to as-built isometric drawings. In its response, Bechtel indicated that the tubing runs not shown on the drawing was not safety-relatcd and that it was Bechtel's practice to show only tubing for instruments porforming an active safety-related function and thereby subject to separation requirements. SWEC confirmed that the subject drawings conformed to this practice. The inspection team agreed with SWEC that this item was closed, provided that this practice was supportable by Bechtel's hazard analysis, which would be reviewed later by SWEC when the hazard analysis was complete DAI-122 P&ID Discrepancies Regarding Signal Interface and Scope of Supply 1 l

(Closed): SWEC identified two discrepancies between the Bechtel P&ID and the GE elementary diagram. For the RHR service water flow channel, the computer  ;'

input was shown upstream of the square root extractor function on the P&ID, but downstream of the square root extractor element on the elementary diagram. In addition, the P&ID showed the transmitter to be in the GE scope of supply, but the instrument index indicated that it was in the Bechtel scop In its response, Bechtel provided two recent startup change notices and a design-15-

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change notice (DCN) to show the as-built P&ID signal interface and to update the change in scope. While not documented in the action item, the inspection team's discussions with SWEC indicated that some broadening of the P&ID sample was done to assess the extent of similar discrepancies and that SWEC had determined that Bechtel had committed to verification of " CAD converted" P& ids that had been susceptible to similar errors. On this basis, the inspection team agreed with closure of this ite DAI-131 Possibility of Low Points in Instrument Flex Hoses (Closed): SWEC was concerned that an as-built isometric showing a flex hose installation permissible by the vendor could possibly result in a low point caused by sag from the horizontal plane. In its response, Bechtel provided an additional installation instruction that covered this configuration and indicated that the hose ends were actually installed at different elevations (although this was not apparent from the isometric alone) and that sufficient slope was provided to avoid hose midspan low points. On that basis, the inspection team agreed with the SWEC closure of this ite DAI-156 Basis for Installed Qualified Life for Rosemount Transmitters (Closed):

SWEC requested that Bechtel provide documentation to support the installed qualified life for Rosemount 1153 Series B transmitters; this information had not been provided in the EQ data package. In response, Bechtel provided contemporaneous documentation and calculations using Arrhenius methodology to establish qualified life for the transmitters. On the basis of SWEC's acceptance of Bechtel's supporting documentation, the inspection team agreed with closure of this ite DAl-171 Basis for Equivalency of IEEE Std 344-1971 Qualification to IEEE Std 344-1975 (Closec ): A design record file (DRF) stated that some ofThe devices in the scope of the document were qualified to IEEE Std 344-1971 and that this was considered equivalent to IEEE 344-1975 if the tested capability was greater than the peak acceleration expected at the mounting location; however, the stated purpose of the DRF was to show seismic qualification to IEEE Std 344-1975. SWEC noted that differences in the later revision of the standard included multi-frequency, multi-axis testing and that the older single-frequency, single-axis testing would not necessarily produce maximum component response. Accordingly, SWEC asked Bechtel to identify which devices were qualified to IEEE Std 344-1971, and how they were considered qualified to the 1975 revision. In its response, Bechtel cited IEEE Std 344-1971 as the Limerick design basis (FSAR Section 3.10.2.1) and explained that the DRF of interest was provided in support of a GE response to an NRC generic concern regarding conformance to the intent of RG 1.100 and IEEE Std 344-1975. The DRF contained the results of this reassessment using the methodology of GE Topical

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Report NEDE-24788, " Seismic Qualification Review Team Technical Approach for Reevaluation of BWR 4/5 Equipment." Bechtel further cited Limerick SER Supplement 3 for NRC acceptance of the Limerick seismic and dynamic qualifica-tion program in accordance with the intent of more current NRC staff licensing criteri On the basis of this prior evaluation by the NRC staff, the inspec-tion team agreed with the closure of this ite DAI-182 Basis for EQ Data for Procurement of Certain Transmitters (Closed):

SWEC noted the absence of references to EQ data In sheets for four instruments its response, Bechtel covered by a Bechtel transmitter specification.

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indicated that two of these instruments were purchased in a supplemental l procurement under this specification by reference to a model number for an {

l instrument known to meet or exceed the EQ requirements; the remaining two l instruments were Q-passive (confirmed by SWEC) and were exempt from environ- {

mental qualification (although they are seismically qualified). In addition, l each transmitter, would be verified acceptable against the qualification test l'

results as a part of the completion of the Unit 2 EQ program. On this basis, the inspection team agreed with SWEC's closure of this ite I '

DAI-184 Addressing Concerns of IEN 85-100 (Zero Shift in Rosemount Transmitters)

(Closed): SWEC requested that Bechtel provide documentation demonstrating that the concerns of IE Information Notice 85-100, "Rosemount Differential Pressure Transmitter Zero Point Shift," had been addressed by appropriate calibration instructions or other measures to compensate for zero shift as a result of line j pressure change In responding, Bechtel indicated that PEC0 Engineering had l engaged a consulting firm to address this concern; the consultant's effort was begun in mid-1988 and was expected to be completed by February 15, 1989. On the basis of this cournitment, the inspection team agreed with SWEC that this item was closed for the purposes of the ID DAI-251 Basis for Installed Qualified Life for Fan Cabinet (Closed): SWEC requested that Bechtel provide documentation supporting the 40-year installed qualified life claimed by the EQ data package for a fan cabinet. In its response, Bechtel retrieved a supplemental vendor report providing evidence of 40-year qualification. Bechtel did not provide any additional aging calcula-tions because the vendor demonstrated qualified life and Bechtel reviewed the vendor's qualification package. On the basis of SWEC's acceptance of the supplemental qualification report, the inspection team agreed with closure of this ite l DAI-289 Conformance to RG 1.97 Regarding Identification of Instruments (Closed): SWEC was concerned about the degree of conformance to the require-ments of RG 1.97 for identification of control room instrumentation used for post-accident monitoring. SWEC asked that Bechtel explain the significance of control room instruments having yellow stripe markings. In response, Bechtel stated that to instruments designated Types A, B, and C and Categories 1 and 2 were provided with yellow striping to conform with RG 1.97 and that FSAR Table 7.5-3 identifies the instrument types and categories for post-accident monitoring instrumentation. Bechtel also indicated that there were other safety-related instruments not designated for post-accident monitoring and not l identified by yellow stripes. Although not documented in the DAI, the inspec-tion team's discussions with SWEC indicated that SWEC independently verified Bechtel's claim by reviewing RG 1.97 and hot shutdown panel instrumentatio On the basis of SWEC's verification the inspection team agreed with the closure of this ite DAI-290 Discrepancies in Installed Instrument Scale Ranges __vs. FSAR (0 en):

C During a site walkdown, SWEC noted that the indicator scale ranges for flow and core spray flow were substantially less than the ranges required by FSAR Table 7.5-3. SWEC informed Bechtel of this discrepancy and also asked that Bechtel ensure range discrepancies did not exist for other instruments-tion. In its response, Bechtel indicated that changes to these scale ranges-17-

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a had been initiated by replacement of the channel transmitters with a newer Rosemount model; GE had prepared the change notice and the ranges were deter-mined to be technically adequate during normal review of the change, but the change documentation failed to identify the need to revise the FSAR. Subse-quent to this issue, Bechtel revised its procedures for reviewing GE change notices for Unit 2 to include demonstrating that the GE changes were reviewed-against the FSAR. Also, a PEC0 audit in June 1988 of human factors enhance-ments identified the discrepancy for the cora spray flow indicators and an FSAR change notice was issued in October 1988. In response to this action item, Bechtel issued an FSAR change notice to correct the range of RCIC flow as stated in the FSAR. On this basis and on the basis of its independent verifi-cation of RG 1.97 conformance (as discussed for DAI 289), SWEC closed this action item. The inspection team agreed with closure of this specific issue but was concerned that SWEC was not keeping track of FSAR changes resulting from its comments. SWEC's procedure 12.0, " Trending of Observation Reports," !

dated September 12, 1988 had a report categorization entitled " Design /SAR Consistency." Closure of this action item prohibited SWEC from using the observation report process to track FSAR changes. SWEC must ensure that all FSAR changes would be properly identified in the final IDA report. Therefore, this action item remained open pending SWEC's confirmation that all FSAR changes will be identified in the final IDA report including a description of how that would be accomplished. Also, SWEC, was requested to verify that all changes resulting from the IDA would be documented in the final IDA repor DAI-297 Basis for Replacement of Air Solenoid Valve with Valve Having Smaller Orifice (Closed): SWEC was concerned about the possible effects of replacement of an air solenoid valve having a 1/8-inch orifice with cn equivalent valve having a 3/32-inch orifice. In its response, Bechtel indicated that the valve was a pilot solenoid in the signal air line from the I/P converter to the valve positioner; the signal line was terminated with a small volume bellows in the positioner, and the line between the solenoid and the positioner was shor The inspection team agreed with SWEC's assessment that the performance of the valve would not be significantly affected bv the change in orifice size and with closure of this ite DAI-367 Discrepancies Between Elementary Diagrams and FSAR Regarding Radiation Ronitor Alarm /_ogic Circuits (Closed): SWFC identified a discrepancy between GE elementary diagrams and the FSAR regarding the RHR service water process radiation monitor alarm and isolation logic. The Bechtel response indicated that the output circuit logic of the RHR service water radiation monitoring system was revised to properly satisfy the requirements of Technical Specifica-tion Sections 3/4.3.7.11 and 3/4.11, and that FSAR Table 11.5-2 was revised, but FSAR Section 11.5.2.1.6 had not been revised accordingl In response to this action item, licensing design change notice was being initiated to update FSAR Section 11.5.2. The inspection team agreed with SWEC that this was a !

documentation discrepancy and that this item should be close .1.4 Mechanical Components Action items DAI-062 Branch Pipe Decoup_ ling Criteria (Closed): SWEC questioned the design practice associated with the criteria used to decouple a branch pipe without consideration of a pipe support close to the branch intersection and of the-18-

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mass contribution of the brar.ch pipe. The Bechtel response stated that the decoupling criteria were based on a diameter ratio of three to one between the run and branch pipes. The criteria and engineering judgment concerning the effects of branch line support location were used to properly decouple the branch line. Bechtel also stated that it did not consider the branch line mass in the run pipe analysis since the contributory mass of the branch is relatively small compared to the overall run mass and, therefore, would have a negligible effect on the stress of the pipe ru Bechtel's approach, including not considering the branch line mass for decoupled pipe, was not common industry practice. SWEC found Bechtel's response acceptable. The in:;pection team concurred with SWEC's evaluation on the basis of experience on similar a issues and agreed with closure of this action ite (

DAI-105 Stiff Clamp Local Stresses (Closed): SWEC was concerned that tha local stresses induced into the pipe as a result of the relatively high prelot.. used ,

by stiff pipe clamps had not been addressed. Bechtel's calculation did not contain any interface between the pipe stress engineer and the pipe support analyst. Bechtel's response stated that the subject of local stress effects of stiff pipe clamps was raised by the NRC during the safety evaluation review for Limerick Unit 1 and that the results are also applicable to Unit Bechtel i stated that it had performed calculations to address the additional stresses resulting from (1) clamp preload, (2) differential thermal expansion of between the pipe and clamp, (3) constraint of pipe expansion from internal pressure, and (4) pad bearing. Bechtel stated that the NRC, after considerable review of these calculations, accepted the Limerick project's generic evaluation of the effects of clamp-induced stresses as published in Section 3.9.7 of the Safety Evaluation Report (SER), Supplement No. 3, dated October 1984. SWEC accepted this response. On the basis of its review of the SER; the inspection team agreed with closure of this ite DAI-107 Review of Pipe Support Calculation DLA-212-C23 (Closed): SWEC noted three issues as a result of the review of Calculation DLA-2I2-023, Revision 1:

(1) The use of baseplate Program ME-035 was not justified by the preparer even though differences existed between the actual installed boundary condition and the program-assumed boundary condition; (2) There was no local stress check performed; and (3) The partial penetration weld did not meet the minimum weid size requirements of the American Institute of Steel Construction (AISC)

specification. Bechtel's response to the above items was: (1) The intent of the enalysis was to calculate the plate stresses and to that end the designer used approximate modeling techniques. The results, which are considered approximate, yielded stresses considerably below the allowables (8 ksi vs. 24 ksi). Therefore, the plate was considered acceptable; (2) The configuration of the support for this calculation did not meet the limits set for the computer program developed to analyze local stresses. Since the axial and bending stresses were comparatively small, the designer and checker exercised judgment that the local stresses would be within allowables; and (3) 1h , minimum weld sizes referenced in the AISC and AWS Dl.1 codes were irtended R ure suffi-cient heat input to reduce the possibility of weld cracking. - of low j hydrogen electrodes for Limerick minimizes the possibility of nj r d l cracking and, therefore, does not requ1re adherence to the minimum weld size i requirements. SWEC accepted 3echtel's response for items 1 and 2. SWEC l

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accepted Bechtel's response to item 3, but noted that the current ASME III,

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Subsection NF, does not have the minimum weld size table but requires a 1/8-inch minimum weld size and states welding cautions (i.e., preheat) for fillet welds less than 1/4 inch. The inspection team accepted SWEC's evalua-tion and agreed with closure of this ite DAI-127 Pipe Stress Analysis - Chugging Loads (Closed): SWEC reviewed piping Calculation 2-10-13, Revision 2, which compared the latest revised chugging spectra with the existing (as-analyzed) spectra, provided justification, and concluded that the existing analysis was seismically acceptable. However, SWEC determined that the justification lacked the detailed rationale to support this conclusion. In its response, Bechtel stated that the actual chugging loads represented only 0.6 percent of the total stress at the point under considera-tion. Therefore, even if that portion of the stress were to increase by the maximum amount of 50.6 percent, the resulting stresses would increase by less than 1 percent, which is considered insignificant. On the basis of the addi-tional justification provided, SWEC agreed that the revised response spectra for the chugging load case, although higher than the analyzed response spectra would not significantly affect the results. The inspection team concurred with SWEC's evaluation and agreed with closure of this ite DAI-128 Pipe Stress Analysis - As-Built Reconciliation (Closed): Calculation 2-10-13, Revision 2, referenced drawing HBB-217-2, Revision 14, ar,d stated that the drawings were as-built except for strainers. SWEC was concerned about how Bechtel would capture such items as the strainer into its as-built verification program and properly include tne additional information into the calculatio In its response, Bechtel explained that there were specifications and proce-dures in place to control the insta11atior., QA acceptance, and as-built configuration details. Bechtel also indicated that project engineering would be sent the as-built configuration and initiate appropriate reconciliation activities including calculation revision (if required). On the basis of Bechtel's explanation and having review of the appropriate Bechtel procedures, SWEC accepted the justification. The inspection team concurred with SWEC's evaluation and agreed with closure of this ite DAI-132 Pipe Supports Attached To Building Structural Steel (Closed): SWEC found that Calculation DLA-212-C12 Revision 1, for pipe support did not address the local stresses for structural attachments. Bechtel stated that evaluation of local stresses for structural attachments was performed by the civil engineering group. A coordination print prepared by the plant design group, which summarized pipe support reactions at the structural attachment points, was used by the civil engineering group to evaluate local stresses in the building structure. SWEC reviewed the coordination print for hanger DLA-212-H12 dnd noted that it was approved by the civil group for installatio SWEC accepted Bechtel's response. The inspection team, concurred with SWEC and agreed with closure of this ite DAI-146 Vendor Designed Hanger Critical Pipe Supports (Closed): SWEC was concerned about the interpretation of Section 5.1 of Pipe Support Design Criteria 8031-P-401, which indicated that all hanger-critical pipe support designs would be qualified by Bechtel (i.e., all werk to be performed by Bechtel). Bechtel responded that Section 5.1 identified the design require-ments for proper documentation of Bechtel engineering design calculations; it-20-

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did not require all hanger-critical calculations be done by Bechtel. Vendors performing designs and calculations were governed by specific purchase and design requirements. Therefore, vendor-qualified pipe supports did exist and the vendor qualification wcs in accordance with 'the applicable contract procurement documents. SWEC closed this concern because no vendor qualified supports were based on a Bechtel stress analysis since the underlying concern in this action item was design interface. The inspection team concurred and agreed with closure of this ite DAI-147 Piping As-Built Reconciliation (Closed): SWEC was concerned because as-built reconciliation of the piping system covered in Calculation 1-21-99, j Revision 1, did not contain documentation regarding as-built verificatio i Bechtel responded that the piping and supports were complete and installed at the time. Calculation 1-21-99, Revision 1, was finalized and the installed design was in agreement with the design drawings. Bechtel provided drawing EMF 9505 and the N5 Data Report HBC-246 to SWEC for review. SWEC accepted Bechtel's response on the basis of its review of the additional supporting documentatio The inspectior, team accepted SWEC's evaluation and agreed with closure of this ite DAI-151 Pipo Stress Analysis Program Error (Closed): SWEC was concerned because Calculation 2-10-13, Revision 2, computer output results for pipe stress were manually crossed out and changed to zero as a result of an ME 101 program error. The Bechtel response stated that an error existed in its ME-101 piping program in the stress summary section that occurred when the actual stress for equation' 10 (thermal stress) was equal to zero. The error had been correr.ted and was determined to have no effect on the validity of the results-for engineering calculations since the error was conservative and only affects the program summary sheets. SWEC accepted this explanation since the program results were conservative, occurred only when equation 10 stresses were zero, and the error had been corrected in a later version of the program. The inspection' team concurred with SWEC and agreed with closure of this ite DAI-174 Pipe Supports Attached-to Embedded Plates (Closed): SWEC was concerned because pipe support Calculation GBB-212-C26, Revision 3, did not address the evaluation or acceptance of-the structural attachment to the embedment plat Bechtel_ responded that reactions from structural attachments to the embedded plates were provided to the civil engineering group via coordination prints issued by the plant design group for review and acceptance. The coordination print of pipe support GBB-218-H26 was reviewed by SWEC and determined to be in compliance with this coordination practice. The inspection team concurred with SWEC and agreed with closure of this ite DAI 204 Equipment Nozzle Loads (Closed): SWEC found that the RHR heat exchanger nozzle loads and RHR pump discharge nozzle loads exceeded the allowables identified in Calculation 2-10-83, Revision 4. Bechtel responded by providing references where GE accepted the increased loadings for the RHR heat exchanger and RHR pump nozzles. SWEC reviewed the referenced GE approvals for the increased equipment loadings and accepted Bechtel's response. The inspection team concurred with SWEC and agreed with closure of this ite _--_ - ___ - -_ _ a

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DAI-206 Pipe Stress Analysis Undocumented Discrepancies (Closed): SWEC identified the'Tcllowing issues in Calculation 2-10 83 Revision 4: (1) equa-tion 9 and 10 allowables for pipe break criterion were crossed out and replaced with new values without any explanation; (2) valve stem properties were based on unreferenced fundamental frequencies; and (3) a minimum wall thickness violation was not evaluated. Bechtel responded as follows: (1) the analyst improperly used a multiplier of 0.4 rather than 0.8 which instructed the computer program to identify crack locations based on the moderate energy criteria rather than the high encrgy criteria, and the crossed-out data was changed by the analyst to the correct allowable based on the 0.8 multiplier; (2) the calculation referenced a purchase order which contained the seismic sis report from which the values for natural frequencies were obtained; analy(3)

and the minimum well thickness per FCR LP-948 was documented in the stress calculation as 0.9 inches. This value exceeded the wall thickness in the piping analysis for this seginent and therefore was acceptable. SWEC reviewed Bechtel's response and found it to be acceptable. The inspection team concurred with SWEC's. evaluation and agreed with closure of this ite DAI-240 Seismic Qualification of Motor-0perated Gate Valve F0-47B (Closed):

SWEC reviewad the testing of motor-operated gate valve F0-47B and raised the following issues: (1) Limitorque motor-operator model for valve F0-47B was SMB-2-40, but the seismic test specimen used was model SMB-2-60 and no justi-fication Limitorquewas given for operator their (Do interchangeability)and Number 8031-E-24-11-1 the(2) during limit switchthe testing out"

" dropped of during the sine beat test as a result of abnormal spring tension, but the test was not repeated after making correction Bechtel responded as follows: (1)

Several letters from Limitorque stated that "...all of the SMB actuators listed in your letter would be considered generically qualified to the levels listed in the report" and (2) Limitorque's responce was "All actuators (SMB-000-2, SMB-1-60, SMB-2-60, SMB-4-250, and SM3-00-16/H2BC) tested in Report B0115 include the same limit switch assembly. The same construction limit switch was successfully tested in the SMB-000-2, SMB-4-250 and SMB-00-15/H2BC with proper operation." If the switch had been properly adjusted, the switch would have responded properly. In addition, the drop out occurred in the high-frequency range of 85 to 100 Hz and Limerick's design spectra high-frequency content occurred at a lower frequency range (below 80 Hz), therefore precluding the need to justify the " drop out" at these higher frequencies. SWEC reviewed the reference documents and concluded that the model SMB-2-40 was generically qualified oy the seismic testing of Model SMB-2-60. In its review of Limitorque's Report B01I5, SWEC concluded that the limit switch was identical to the switch assembly that was qualified by other tests and had the gaps been properly adjusted, the switches would have operated properly. The inspection team concurred with SWEC's evaluation and agreed with closure of this ite DAI-271 Verification of RHR Heat Exchanger Nozzle Loadings (Closed): SWEC reviewed TaTculation 2-D-55, Revision 3, for RHR heat exchanger 2BE-205 and found the following concerns: (1) nozzle allowables were compared to the wrong loadings; (2) the Unit i nozzle loadings required special approval from GE and Unit 2 loads were higher, but no justification was provided for accepting the higher loads; and (3) an unconservative numerical error was noted in the thermal ar,cher movements for a nozzle. Bechtel responded with the following explanations: (1) the nozzle allowables were inconsistently compared to the calculated loads in one portion of the report however, a correct comparison-22- l

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l-4 e was performed on calculation sheet D7; (2) GE provided maximum allowable loads for the RHR heat exchanger nozzles for qualification (Ref. 8031 .

i M-1-Ell-8001-C-2.5) and all loadings were below the allowable loadings; and (3) the displacement value used in the computer model was correct, however, a transcription error was made in the calculation. Since this value was not used in.the analysis, the design calculation was not'affected. SWEC reviewed l Bechtel's response.to these concerns and concluded that (1) although the nozzle j '

allowables were incorrectly compared to the calculated loads on page 20 of the calculation, page D7 provided the correct comparison; (2)'the validity of the response was verified against the GE vendor drawing; and (3) the actual displacement used in the computer analysis was verified as correct. Therefore, SWEC considered all these items to be closed. The inspection team verified the referenced documents contained the appropriate allowables and reviewed the -

stress analysis to ensure that the proper thermal displacement had been used in the thermal analysis. The inspection team concurred with SWEC and agreed with closure of this ite t

) DAI-308 Axial Restraint-Load Distribution and Weld Size (Closed): SWEC reviewed Calculation GBB-218-C58, Revision 2, and identified two concerns:

In the first concern SWEC questioned the load distribution between two horizon-tal struts restraining the axial displacement of the piping via attachment to trunnions. SWEC felt a particular modeling method would provide a 30 percent increase in load and was more appropriate than the Bechtel method. -In addition,-

SWEC felt that this design should be treated in the same manner as struts used to support vertical lines (i.e., strut should be designed to resist 100 percent of the load). In the second concern SWEC questioned that the weld of the trunnion to the wrapper plate did not consider the skew angle of the weld that resulted from curvature of the pipe. Bechtel responded to the first concern stating that the support designer used the appropriate method to determine the strut loads since the struts only provide an axial restraint. Additional conservatism was introduced into the design since both struts were designed for the larger loading using the normal / upset allowables with faulted loads. To the second concern Bechtel stated that the trunnion weld has a skewed weld on two sides and had a 90 degree fillet weld on the other two sides. The 90 degree fillets resisted the greatest portion of the applied loading. In addition, the actual weld length used by the designer was smaller than the length available. SWEC reviewed Bechtel's response and concluded that (1)

although the analysis method for determining strut loads was approximate, the use of faulted loads with normal / upset allowables was sufficiently conservative to demonstrate support adequacy; and (2) because of the conservatism in the calculation, the skewed weld did not compromise the structural integrity of the weld. Although the inspection team felt that the actual solution however, for the first concern, lay somewhere between the Bechtel and the SWEC  !

methods but, the conservatism present resulted in a design that was adequat i Item 2 also had sufficient conservatism to be considered adequate. Therefore, the inspection team agreed with closure of this ite DAI-468 Anchor Computer Program Weld Design (Closed): Section 4.9.8 of Specification 8031-P-401 provided guidance for the design of welds associated with the anchor computer program ME-225. SWEC noted that this section stated

that the size of the weld that would result using the plate theory should be I disregarded and that the weld size should be two times the structural theory  ;

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i value without any justification for the statement. In its response, Bechtel stated that the use of the linear structural theory for the design of welds was appropriate. The use of two times the structural value was arbitrarily chosen and provided additional conservatism to address any potential load increas SWEC accepted the fact that the structural theory was adequate for weld design and the factor of two added conservatism. The inspection team agreed that the method used would yield conservative results and agreed with closure of this ite .1.5 Civil / Structural Action Items DAI-030 Quality Assurance and Inspection Requirements Not in Engineering h edification (Closed): SWEC reviewed Specification 8031-C-36, which gave t1e requirements for forming, placing, finishing, and curing concrete. SWEC noted that the QA requirements were not specified in the specification and that the inspection program was not uniformly included in the specificatio In its response, Bechtel stated that QA requirements were specified in project quality control instructions (PQCIs) and that Specification 8031-C-36 only included-technical requirement Inspection programs were generally not covered by disciplinary technical specifications, but were normally included in the PQCIs. Occasionally, technical specifications might contain certain inspection activities that would specify minimum inspection requirements for construction. Bechtel stated that the decision to provide inspection criteria would be based on various reasons such as audit findings, NRC bulletins, .

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nonconformance reports, construction requests, conditions identified or experienced on other projects, or project engineering judgment. SWEC accepted the Bechtel response. The NRC inspection team reviewed PQCIs, 18240-C-1.20 '

(Replacement Inspection of Concrete, Rev. 16, August 4,1987),18240-C-1.30 (Concrete Placement Inspection, Rev. 13, January 9, 1987) and 8031-C-1.40 (Post-Placement Inspection of Concrete, Rev. 27, January 24,1986) and found that the QA and inspection requirements were listed in these PQCIs as indicated by Bechtel. The team concurred with SWEC and agreed with closure of this ite DAI-052, Discrepancies Between FSAR and Calculations (Closed): SWEC noted that FSAR Section 3.7 had a rock modulus of 3x106 psi, but Calculations 24.1A and 24.1B used a rock modulus of 0.67x106 psi. Also, the seismic responses (e.g., shear, moment, acceleration, and displacement) listed in the FSAR were less than the values included in Calculation 24.1E. Bechtel responded that Calculations 24.1A and 24.1B were prepared in 1971 and based on data in the Dames & Moore recommendation entitled " Foundation Investigation Report," dated October 5,.1970, which had a rock modulus of 0.7x106 psi. Subsequently, Calculations 24.1C and 24.10, prepared in 1975, used a rock modulus of 3x106 psi, which was calculated from a rock shear wave velocity of 5950 fps. This rock modulus was used together with a damper to account for the soil structure interaction (SSI). The SSI rock modulus was listed in Section 3.7 of the FSA Bechtel stated that Calculation 24.1E was prepared in 1981 to support the Mark II hydrodynamic load reassessment at Limerick and that responses from that calculation were presented in Limerick's design assessment report (DAR). Final design of the structures was based on the results of Calculations 24.1A through 24.1D as they were presented in the FSAR. SWEC accepted the Bechtel response and the inspection team concurred with closure of this action ite ___________ -

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DAI-081 Requirements for Certain Materials Not Included in Engineering l Specifications (Closed): SWEC reviewed Section 1.0 of Specification 8031-C-62, Testing of Concrete, Soil and Reinforcing Steel, stated that the testing requirements for reinforcing steel specimens and cadweld splices were included in the specification. However, Section 6.0, " sampling and testing," of the specification did not include this information. Bechtel responded that Specification 8031-C-62 merely stated that this specification covered the construction of an onsite field laboratory and provisions for qualified personnel performing various laboratory tests including testing of reinforcing steel and cadweld splices. Section 6.0 of this specification states that samples of materials should be obtained and tested as required by specifica-tions listed in Sections 4.1, 4.2, and Both Specification 8031-C-34 (Splicing Reinforcing Bars, Rev.13, February 21, 1978) and 8031-C-39 (Furnishing, Detailing, Fabricating and Delivering of Reinforcing Steel, Rev.15, April 14, 1988) were listed in Section 4.1. Therefore, the necessary informa-tion for the installation and testing of reinforcing steel and cadweld splices ;

was included in Specification 8031-C-62. SWEC accepted Bechtel's respons The inspection team reviewed Specifications 8031-C-34 and 8031-C-39 and found that the necessary information was provided as indicated in Bechtel's respons The inspection team agreed with the closure of this ite l DAI-095 Omission of Interior Walls in Rigidity Analysis Without Justification i (Closed): SWEC noted that in Calculation 70-L, during review of the rigidity analysis of spray pond pump house, six interior rib walls between elevation 237' and elevation 266' were neglected without any justification. Bechtel responded that the rib walls were considered in Calculation 70-A, Seismic Analysis of Spray Pond Pumphouse, Revision 3, June 8, 1984, as elements 13 through 18 for stiffness and as elements 12 through 17 for mass. Addi-tionally, Bechtel stated that Calculation 70-L developed the relative rigidities to distribute global seismic loads for wall design calculations and that neglecting these secondary rib walls was conservative in designing the primary walls. SWEC accepted Bechtel's response. The inspection team reviewed Calculation 70-A and concurred with Bechtel's response. The inspec-tion team agreed with closure of this ite DAI-123 Purpose and Validity of Frequency Adjustment Factors and Frequency Variations (Closed): SWEC questioned the purpose of the frequency adjustment factors and frequency variation study contained in Calculation 24.1E. SWEC also questioned the source and validity of certain numerical values. Bechtel responded that the purpose of this calculation was to determine the extent of ,

spectrum widening for piping and equipment analysis. In response to a separate

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l issue Bechtel stated that the concrete elastic modulus was obtained from field test results and the concrete modulus was discussed in detail in response to DAI-035. Also, Bechtel indicated that the validity of the ARS curve peak broadening of 15 percent was based on project study of 14 percent and civil /

structural study of 18 percent. These values showed minor variations from the NRC recommended 15 percent broadening; therefore, the t15 percent value was adopted as the project broadening criteria. SWEC found Bechtel's response acceptable. The inspection team agreed with closure of this item, but noted that the concrete modulus topics in DAI-035 had resulted in Observation Report D0R-05 l 2 !

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DAI-148 Inconsistency in Applying Seismic Loads (Closed): SWEC's review indicated that the application of seismic loads was inconsistent through ,

various designs. For example, (1) in Calculation 23.2, vertical seismic loads were only applied occasionally and no horizontal seismic loads were used and (2) for three applications in Calculation 70-N for the design of steel plat-forms one had no seismic loadings, one had only vertical, and one had both vertical and horizontal. In its response, Bechtel indicated that, for struc-tural steel, seismic load application was specified in FSAR Sections 3.7 and 3.8 and Specification C-115.- There was no specific procedure to address the methodology of analysis. With respect to the inconsistency in Calculation 23.2' q (Reactor Building Structural Steel Framing at El 201'-0", Rev.13, October 8,  !

1984) loading combination with vertical seismic loads did not control the i design and, when necessary, additional calculations for vertical seismic loads were performed. Horizontal seismic loads were not applied because they were considered negligible. In calculation 70-N (Spray Pond Pumphouse - Steel Platforms at Els 252'-6", 271'-9", and 276'-0", Rev. 2, January 31,1984),all three platform calculations were prepared by the same individual, apparently he used engineering judgment and chose the controlling loading combination to evaluate the platforms. Bechtel also stated that the adequacy of the platforms were verified by existing Calculations 102.4.1, 102.4.2, and 102.4.3 which evaluated the as-built coridition of the platform SWEC accepted Bechtel's r'esponse. The inspection team reviewed Calculations 8031-C-102.4.1 (Assessment of Platform-22 0 EL. 276-0" for Structural Integrity, Rev. O, March 8, 1984),

8031-C-102.4.2 (Assessment of Platform 23 0 El. 271'-9" for Structural Integrity, Rev. O, March 8, 1984), and 8031-C-102.4.3 (Assessment of Platform 24 0 El. 252'-6" for Structural Integrity, Rev. O, March 9,1984) and verified the evaluation of the as-built condition indicating that the platforms were technically adequate. Therefore, the inspection team concurred with closure of this ite DAI-153 Inconsistency in Design of Floor Dia)hragms (Closed): In Calculation 23.3, SWEC noted that the design of the floor diapiragm 1 evaluated the seismic loads in the N-S direction as well as those in the E-W direction. In the design of diaphragm 3, it was not clear that N-S seismic loads had been considered. In its response, Bechtel indicated that diaphragms 1 and 3 were similar in design. The N-S seismic loading was similar for the two slabs because of the symmetry of the plant. Therefore, no reanalysis of the N-S seismic loading for diaphragm 3 was required, and the reinforced steel used to resist the N-S seismic loading for the two slabs was identical. However, the E-W seismic loading differed greatly because wall 31.9 was an exterior wall subjected to earth pressure whereas wall 14.1 was not subjected to earth pressure. Each diaphragm used the same N-S seismic loading eve.luation but had unique E-W seismic loading evaluations. SWEC accepted Bechtel's response. The inspection team reviewed Calculation 8031-C-23.3 (Reactor Building Reinforced Concrete Slab Design 0 EL. 201'-0", Rev. 7, March 15, 1984) and found that the reinforcing steel used to resist the N-S seismic loading was the same; there- 4 fore no inconsistency was found. The inspection team concurred with the closure of this ite DAI-234 Inconsistency Between Engineering Drawing and As-Built Condition (Closed): SWEC noted during a walkdown that an insert plate around penetration '

X-45B was on the outside face of the containment wall; yet Drawing C-287 did not show this plate. Bechtel's response indicated that the plate was used as a-26-

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form plate to form a tight seal around the pipe sleeve for concrete placemen Details were presented on construction Drawing Z150-4.1 By reviewing the response, it was clear to the inspection team that the steel plate was not a strength bearing member. This plate did not have any adverse affect on the structure and the inspection team concurred with closure of this ite DAI-272, Discrepancies Between Field Change Request (FCR) and Construction Drawing (Closed) - SWEC noted that FCR-CS-1247 had not been fully incorporated on Drawing C-288, Sheet 2, Rev. 6. Bechtel's response indicated that FCR-CS-1247 was incorporated on Drawing C-228, Sheets 1 and 2 as required by block 15 of the FCR and not on Drawing C-288, Sheet 2 as stated in this DAI. Drawing C-228, Sheets 1 and 2 were applicable to both units and the changes per FCR-CS-1247 were only for Unit 2. Detail 4 and Sections C and D on Drawing C-228 were issued to identify changes for Unit 2. SWEC accepted Bechtel's  !

response. The inspection team reviewed FCR CS-1247 (To Use Existing Materials and Accommodate to Field Conditions, Rev. O, March 6,1987) and found that the FCR clearly indicated that the changes per this FCR were incorporated on Drawing C-228, Sheet 1. The team agreed with closure of this ite DAI-299 SRV Discharge Load of One Unit Was Not Analyzed for the Other Unit (Closed): SWEC was concerned that, with safety relief valve (SRV) discharge occurring in one containment, induced motion through the foundation would not be symmetric with regard to the reactor building, resulting in rocking and torsional type motions. This was not addressed in the associated calculation Bechtel's response stated that the SRV discharge loads were analyzed using both two dimensional (2D) and three dimensional (30) finite element approaches. The NRC conducted an audit directed at the adequacy of the 2D as opposed to the 3D analytical methodologies. The SRV load analysis method was conservative and adequate because the reactor building rocking and torsional type motions were implicitly addressed in the comparison documented in Calculations 29.12.1 and 29.12.2, the reactor building analysis calculation 29.3.3, and the NRC report of the audit. SWEC accepted Bechtel's response. The inspection team reviewed the NRC followup report of the audit 99900522/82-02 on hydrodynamic load analysis by J.R. Castello and P.T. Kuo. The report indicated that the discrepancies in horizontal motion modeling would not have a significant effect on the final design. Therefore, the inspection team agreed with closure of this ite DAI-300 Unjustified Increase in Concrete Modulus (Closed): SWEC's concern was that the concrete modulus was increased by 30 percent for the SRV asymmetric analysis without justification. Bechtel responded that the concrete modulus increase was due to concrete gaining strength through age hardening. The increase in concrete modulus also gave better frequency comparisons between the analytical response prediction and the frequencies recorded from the inplant test. Since both concrete age hardening and static / dynamic ratios would have similar effects on all stiffness calculations, the increase was uniformly applied to all analytical models used for the reactor building hydrodynamic assessmen SWEC accepted Bechtel's respons The inspection team reviewed ,

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the Bechtel response and SWEC's evaluation and considered that the 30 percent increase in concrete modulus as a result of concrete age hardening was reasonable and agreed with closure of this item.

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DAl-305 Inconsistencies Between Engineering Drawing and Vendor's Fabrication Drawing (Closed): SWEC noted that the vendor's (Bethlehem Steel) fabrication Hrawing showed reinforcing steel different than that depicted on the Bechtel design engineering drawing. Bechtel responded that, although the configura-tions shown on Bethlehem Steel Drawing 259 for bars labelled 42 and 43 did not agree with Civil Drawing C-120, Revision 19, the discrepancies have no signifi-cance. This was because replacement inspection of concrete, which included rebar installation inspection, was performed by QC using applicable civil drawings. Since the rebar shown on the subject drawing met the design require-ments as indicated in Calculation 23.3 (Reactor Building Reinforced Concrete Slab Design at El. 201'-0", Rev. 7, March 15, 1984), the rebar installation was adequate. Bechtel further stated that revisions to its civil drawings did not require coordination with the vendor, therefore, the vendor's rebar fabrica-tion drawings would not necessarily match the current revision of the civil drawings. SWEC accepted Bechtel's response. The inspection team discussed this issue with SWEC. SWEC indicated that they had talked with the SWEC ICA team to ensure that the latest civil drawings were followed during rebar installation. The inspection team agreed with closure of this ite DAI-341 Cadwelds in the Reactor Building Mat Not Shown on the As-Built Drawing (Closed): SWEC noted that cadweld inspection records were contained with the concrete placement number rather than with the as-built drawings for two concrete placements in the reactor building foundation mat. This is a violation of RG 1.10 without justification. Bechtel responded that the intent of RG 1.10 was to describe an acceptable method with regard to the testing and sampling of mechanical splices in reinforcing bars. The intent of the regulatory guide had been met because all cadwelds used in Limerick 2 were sampled and tested to the requirements described in FSAR 3.8.6.2.2.2. This requirement complied with RG 1.10. For the reactor building foundation mat, mechanical splices were used occasionally, the traceability of cadwelds to the concrete placement number was more than sufficient to meet General Design Criterion (GDC) 1 and the intent of RG 1.10. The inspection team concurred with SWEC's decision to close this item since there was traceability to the cadwelds through concrete placement members even though it would have been easier through the as-built drawing l DAI-350 Unjustified Reduction of Negative Moment in Concrete Design (Closed):

SWEC noted that the negative bending moment of a reinforced concrete wall was reduced by 10 percent without justification as indicated in Calculation 23.1.(b), " Substructure Wall Design - Reinforced Concrete Reactor Building -

Column Line D," Revision 3, January 31, 1984. Bechtel responded that the 10 percent reduction in negative moment was to take advantage of the excess reinforcement bars to resist positive moment at that particular location. The total design moment had not change SWEC concluded the action item could be closed since the design was conservative and it was an isolated case. The inspection team reviewed the subject calculation and noted that ACI-318-71 (building Code - Requirements for Reinforced Concrete); Section 8.6 allows the redistribution of negative moment for continuous elastic support members, which could be as much as 17 percent. The reduction of 10 percent was within the allowance of ACI 318-71, and the reinforcing bars provided were sufficient to

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resist the moment after redistribution. The inspection team concurred with closure of this item.

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i DAI-361 No Evaluation of Actual Attachment Loads (Closed): SWEC indicated that the 5-kip allowance for vertical attachment loads, as described in Specification 8031-C-115, might not be adequate and gave five examples to indicate that the 5-kip allowance might be inadequate. Bechtel's response indicated that the allowance of 5-kip for the vertical attachment load was for loading conditions that did not include seismic. The 5-kip load was considered to account for rigging attachments during construction. Loads for minor piping, conduit, cable tray and HVAC supports were accounted for as live loa Loads from large pipe supports were included in load verification calculations prepared as supplements to the original calculations for the main building structures. SWEC reviewed the live load assumption during a structural walk-down in accordance with Specification 8031-M-400-2, Appendix B, which evaluated cumulative effects of all types of attachments loads on selected structural member Bechtel explained all examples to SWEC's satisfaction. The inspection team reviewed Specification 8031-C-115 " Specification for Civil and Structural Design Criteria," Revision 4, October 24, 1985, which stated that

" concentrated load of 5-kip to be applied at point of maximum moment and shear on all beams, girders, and slabs. This load is not cumulative and is not carried to columns." The team also reviewed Specification 8031-M-400-2,

" Specification for Safety Impact Review and Commodity Clearance / Structural Walkdown Program," Revision 5, July 20, 1988, which was generally used for equipment qualification to ensure that the licensee's commitment to Regulatory Guide 1.29

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was met. SWEC also ensured that all supports (seismic and nonseismic) were adequately designed and would not cause safety hazard during a safe shutdown earthquake (SSE). The inspection team agreed with SWEC's closure of this ite DAI-429 Inconsistencies and Unjustified Factors on Box-Beam Design (Closed):

SWEC's reviewed a calculation for a box beam design and noted that (1) the allowable weld stress was increased by 25 percent without justification, (2)

the allowable weld stress was inconsistent, and (3) interaction formula for combined stress was greater than 1.0 and was accepted without sufficient justification. In its response, Bechtel stated for item 1 that the loading combination in Specification 8031-C-115, Section 5.2.3.3.3.c.1.b, allowed a factor of 1.25 for the allowable weld stress for drywell steel. For item 2, Bechtel stated that the weld being checked was a partial penetration weld and the allowable stress was given in Table 1.5.2.1 of the American Institute of Steel Construction. For item 3 Bechtel stated that the box beam was over-

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stressed by 10 percent and 15 percent, but the snubber loads used were a mixture of maximum capacity snubber loads and loads from the piping analysi The maximum snubber capacity load was 72 kips and preliminary piping analysis loads, in two cases, were 35 kips and 33 kips. Since the primary source of

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loads on the box beams in Calculation 17-0-7 was from snubber loads, judgment was that a 10 to'15 percent overstress was acceptable without further calcula-tion. The inspection team reviewed Calculation 8031-C-17-0-7, " Snubber Steel @

EL. 253'-0" - Box Beam 2, Unit 1," Revision 0, July 22, 1981, and found that the actual snubber loads were 35 kips and 33 kips. However, the team questioned the possibility that not all the loads on the box beam were snubber 1 l

loads, thus invalidating Bechtel's argument, SWEC discussed this question with Bechtel and was assured that all loads on the box beam were snubber relate On the basis of SWEC's evaluation and the clarification from Bechtel, the team concurred with closure of this ite !

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'DAI-432 Unjustified Increase of Allowable Compressive Stress (Closed): SWEC l indicated that an allowable stress (compressive) was increased by a factor of 0.85/0.60 without justification. 'Bechtel responded that the increase to the allowable compressive stress was for the loading combinations of design accident and extreme environmental conditions as given-in FSAR Table 3.8-1 Allowable web crippling stress for these loading combinations was determined

,by increasing the elastic working allowable (0.75 Fy) by a factor of 0.85/0.60, except that this stress was limited to the material yielded stress (Fy). This factor was based on tension stress allowables; 0.85 Fy was the allowable given in the FSAR and 0.60 Fy was the tension working stress allowable. SWEC considered the response acceptable because the maximum allowable web crippling

. stress was increased from 0.75 Fy to 1.0 Fy, a factor of 1.33, and since web crippling was a stability requirement, the allowable stress could be increased to 1.5 Fy (FSAR Table 3.8-10). The inspection team concurred with SWEC's '

analogy and agreed with closure'of.this ite DAI-433, Biaxial Bending ~in Box-Beam Design (Closed): SWEC noted that Calculation 8031 17-A-3 did not consider the interaction of two axes bending, therefore, the box beam might be under designed. Bechtel's response stated

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that the box beam, evaluated and designed by Calculation 17-A-3, was predominantly controlled by jet impingement loads. These loads were applied in horizontal and vertical directions from different postulated breaks. Only one

.line break was postulated at a time, multiple jet loads were not to be applied simultaneously. Therefore, interaction of two axes bending as a result of two

. jet loads was not considered. SWEC accepted Bechtel's response. The inspection-team reviewed Calculation 8031-C-17-A-3 (Primary Containment Building Floor Beams 0 E1. 252'-101", Revision 7, October 9, 1984), and found that the response was acceptable and agreed'with closure of this ite .2 Review of Observation Reports for proper Inclusion of Action Item Issues To ensure that the technical issues contained in the unresolved design action items were being properly incorporated into design observation reports (DORS),

the inspection team sampled a minimum of two observation reports per review

. discipline. This review did not include a review of Bechtel's response to the observation report nor did it include SWEC's evaluation of the Bechtel response, both of which would be the subject of the planned IDA corrective action inspection currently scheduled for the week of April 24, 1989. If an observation report consisted of more than one design action item, only the-item identified herein was reviewed against the observation report. The following observation reports were reviewed by the inspection team to ensure that the unresolved issues within the design action item (s) shown in parentheses were adequately incorporated. A " closed" status indicates that all action item issues have been adequately incorporated into the observation report and that there is no NRC action required of SWEC, it does not mean the observation report had been resolve .2.1 Mechanical Systems Observation Reports D0R-23 (DAI-141) SRV Discharge Piping Loads (Closed): SWEC was concerned that the Bechtel computer code RVCL(NE805) might not yield conservative results for piping in the suppression pool area as a result of steam flow from the SRV SWEC noted that false initial conditions were used to suppress predicted-30-

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I supersonic flows, which the Bechtel code could not analyze. Bechtel's response noted that the design analysis used conservative input data and the predicted forcing functions for the piping in question were compared against test data in the RVCL manual. Bechtel also stated that the supersonic flow was unlikely to occur in real situations. SWEC noted that the test comparison for loads inside the suppression chamber were inconclusive and therefore unacceptable. SWEC therefore concluded that an OR was required. The inspection team agreed with that decisio R-25 (DAI-059) RHRSW Pump Calculations (Closed): SWEC noted that the RHRSW-pump calculation (M-11-15) could lead to confusion and design problems. In action item 059, a SWEC review of the subject calculation revealed that the modes of RHRSW pump operation, run out flow, and pump total dynamics head (TDH)

were not completely addressed. In addition, the sizing for the orifice plate used in the system was not clear. The Bechtel response explained the purpose of the calculation and method of sizing the orifice. The SWEC review of the response and Calculation M-12-30 indicated that throttling of valve F-068 was not properly considered in the pump TDH. Also, the modes of operation and possible effects on emergency service water (ESW) were not clear. SWEC was in general agreement with the resulting pressure differential for the orifice; however, the method of obtaining the value is still unclear. SWEC concluded that an OR was required and the inspection team agreed. The team's review of the OR found that it represents the concerns discussed abov R-046 (DAI-197) Blowdown Flow From HELB (Closed): Calculation 2006, Revision 4, for high energy line breaks (HELB) uses a K value for the HPCI isolation valve that exceeds the K value received from the valve manufacturer. The input used in the calculation underestimates the blowdown flow and may result in nonconservative compartment pressure and temperature transients being used with K value higher than that supplied by the vendor (DAI-197). Bechtel responded that although the valve friction factor used in the calculation is higher than the value provided by the vendor, the calculation restrictors were not included and the overestimate of the K value for the valve would be off set if these effects were censidered. SWEC evaluated the Bechtel response and concluded that Bechtel had underpredicted the blowdown flow. The inspection team reviewed this observation report and found that SWEC had properly addressed the concerns regarding underestimation of blowdown flow from high-energy line break .2.2 Electrical Power Systems Observation Reports D0R-042 (DAI-114 and DAI-150) DG Voltage Regulation (Closed): SWEC described various concerns with regard to the diesel generator (DG) voltage regulation for loading during a design-basis accident (DBA). It also included concerns with regard to acceleration timings and relay settings for loads connected sequentially to the Class IE DG. The inspection team reviewed the observation report and found that SWEC had described concerns of the ascociated action items accuratel ,

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3. Instrumentation and Controls Observation Reports

> 00R-021 (DAI-054), Inadequate Basis for Balance-of-Plant 0-Functional Setpoints (Closed): SWEC identified si determination of balance-of-plant (B0P)gnificant Q-functionalconcerns setpoints. regarding SWEC requested clarification of the Bechtel program for developing setpoints and setpoint tolerances for Limerick, but determined from the responses that the B0P setpoint methodology was not described in any Bechtel or PECO proce-dure and that-the B0P setpoint program was generally poorly documente In addition, SWEC reviewed setpoints and setpoint tolerances for two B0P instruments and found several discrepancies, inconsistent methods, and absent or incomplete documentation. SWEC concluded that it was impossible to establish confidence that all B0P Q-functional setpoints for which Dechtel had responsibility were appropriately established and acceptable. The inspection team, on the basis of the information available, concurred with the need for this observation report, which adequately reflects the issues of the associated action ite D0R-041 (DAI-221) Qualification of Duct Mounted RTDs (Closed): SWEC was concerned about the use of 115'F temperature in the Arrhenius aging equation instead of the 120*F value established by the LOCA environment and about provision of suitable margins to allow for uncertainties. This calculation was used to support qualification of duct-mounted resistance temperature detector (RTD) in the RHR HVAC system. The inspection team determined that on the basis of Bechtel's response, SWEC properly concluded that use of a temperature lower than the postulated accident temperature does not conform to NUREG-0588 and cannot support qualification. The inspection team found the observation report properly included the associated action item issue .2.4 Mechanical-Components Observation Reports D0R-022 (DAI-188, 190 and 192) MSIV Accumulator Tanks _(Closed}: SWEC noted that Design Specification 8031-M-170 classifies the ASME Section III accumula-tor tank's pressure boundary as piping. The design specification paragraph 41f, invokes ASME III, NCA-1273 which allows certain miscellaneous items to have their pressure boundaries considered as piping. NCA-1273 provides examples of these miscellaneous items, and the accumulator tanks were not typical of the examples listed. The main steam isolation valve (MSIV)

accumulator tanks, according to SWEC, have ten inappropriately addressed as piping in the design report. SWEC stated that the design report contained a mix of vessel and piping equations and allowables and was remiss by the exclu-

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sion of the saddle and ring loads. The present report, therefore, is not a ,

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complete ASME III design report. The inspection team reviewed the issues identified and noted that SWEC had properly stated them in the observation repor DDR-028 (DAI-306) Local Stress Evaluation-Stanchion to Elbow (Closed):

SWEC reviewed Pipe Stress Calculation 2-10-83, Revision 4, and questioned the adequacy of pipe stress calculations when integral attachments were used. The local stress evaluation for pipe support GBG-218-H58 was performed using the ME-210 computer program. The moment term "ML" was entered into the computer program _in ft-lbs rather than the required inch-lbs, which provided unconservative results at the attachment point. No local stress evaluation was performed for the stanchion-to-elbow connection of support GBB-203-H1 e

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'As a result of these errors, the technical adequacy of the integral attachment was questioned as originally identified in the astuinted action ite .2.5 Civil / Structural Observation Reports D0R-036' (DAI-051 and 055) Ina:oropriate Assum)tions In Reactor Building

' Seismic Analysis (Closed): S EC summarized t1e unresolved portion of DAI-051-and DAI-055, both of which concerned the use of unjustified assumptions. In DAI-051, the analysis used an equivalent circular foundation mat rather than the actual rectangular foundation mat. Bechtel's response to the DAI stated that the equivalent circular formulation was appropriate. SWEC did not agree with this respense because the rocking stiffnesses were quite different in the two orthogonal directions for the actual rectangular foundation (E-W and 1 N-S)-the circular foundation was, obviously, assuming that they were the same. In DAI-055, certain interior walls were not addressed in computing stiffness of the seismic model, and justification for the omission was not ,

provided. In-its response, Bechtel indicated that the methodology used in the

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analytical modeling of the reactor building seismic stick model was based on industry practice, extensive experience, and judgment. The inspection team !

agreed that this response did not adequately address the concern, therefore,

.the observation report was appropriately issued to seek satisfactory responses from Bechte D0R-040 (DAI-213 and DAI-454) Thermal Load Was Not Considered in the Design of Structures (Closed): SWEC addressed concerns from DAI-213 and DAI-454 with regard to thermal loads not being considered in the design of structure DAI-213 dealt with concrete structures and DAI-434 with the design of steel structural members. Bechtel's response stated that the thermal loads in those instances were not significant. However, Bechtel's reply did not demonstrate that thermal loads were always negligible. SWEC indicated, that, in certain cases, the thermal loads could be significant. The team agreed that an observation report was warranted since thermal loads should be considered in design of structures when the loading combinations contained thermal load The only exceptions to this would be if-adequate documentation was provided to indicate that thermal loads were not-significant in the design or the loading combination containing thermal load did not control the desig .3 Status of Previous IDA Inspection Report (IR) Findings To ensure that SWEC had taken the action requested in its previous IDA reviews, the inspection team decided to sample SWEC's compliance with actions identified )

in NRC Inspection Reports 50-353/88-200 and 50-353/88-201. The sample of actions reviewed by the inspection team are summarized below. Note that a c1csed status next to tht. title indicates that SWEC satisfactorily complied ;

with the requested action in the previous inspection report, it does not l necessarily imply that the action item or resulting observation report has been 1 J

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l 3.3.1 Mechanical Systems Previous IR Findings 3.3. Control Valve Sizing Review (Closed)

In Inspection Report 50-353/88-200, Addendum Item 1.1.3, the NRC staff requested that SWEC review of control valve sizing, including discipline interfacing data. The licensee revised Review Plan LK-D-1909-MS to include an attribute for discipline interfacing. Also, under Review Plan LK-D-1906-C SWEC reviewed the sizing of control valve LV-C51-2F053B, using information from Bechtel specifications. At the request of the inspection team, the SWEC Mechanical Discipline verified that the valve pressure drop and flow obtained from Pechtel Data Sheet M-608, Sheet 1, and Process Diagram 5.7-14 were correct for the interface. The inspection team was satisfied with the level of review effort eventually provided for this item, but noted that the mechanical input data had not been evaluated prior to the inspection team's reques .3.1.2 RHRSW Pump NPSH Review (Closed)

In Inspection Report 50-353/88-201, addendum Item 3.1.1.5, the NRC staff requested that SWEC review the RHRSW pump vortexing and the vendor's clearance requirement between the bottom of the suction bell and the bottom of the wet pit. Under Review Plan LK-D-1903-MS, Attribute 3, SWEC evaluated the issue of pump vortexing and documented a review of Bechtel Calculation M-12-30, Revision 0, to compare the minimum available pump submergence (6 ft) with the pump vendor's minimum submergence requirements (3 ft). .SWEC concluded that because the minimum vendor submergence was exceeded, vortexing would not occur. Under Review Plan LK-D-1903-MS, Attribute 3, SWEC evaluated by verifying that Bechtel Calculation-12-30, Revision 0,fornetpositivesuctionhead(NPSH) included bottom clearances that were consistent with the pump vendors drawings. The inspection team was satisfied with SWEC's level of effort for review of these  ;

item .3.1.3 Pressure Relief Valve Sizing Review (Closed)

In Inspection Report 50-353/88-201, Addendum Item 3.1.1.1, the NRC staff requested that SWEC include a review of a pressure relief valve sizing in the IDA scope. The inspection team verified that SWEC had adequately evaluated this ite .3.1.4 Air Operated Accumulator Review (Open)

In Inspection Report 50-353/88-200, Addendum Item 1.1.8, the NRC staff requested that SWEC include a review of an air operated accumulator design in the IDA scope. SWEC had selected to review the accumulators for the automatic depres-surizationsystem(ADS). Although SWEC's review of this item was adequate, it did not consider leakage past the check valve that would be closed on loss of instrument air. Since closure of the check valve was critical to the ADS valve accumulator meeting its design objective, the inspection team recommenced that SWEC also review the actualIntest data toofensure absence the accumulator the actual test results, would SWEC perform its intended functio should review the engineering test specification considering the leakage acceptance criteria for check valves. This item remained ope ,

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3.3.2 Electrical Power Systems Previous IR Findings 3.3.2.1 Offsite/Onsite Power Interconnection (Closed)

In Inspection Report 50-353/88-200, AddendumItem1.2.1(a),theNRCstaff requested that SWEC expand its scope of review in electrical area beyond Class IE-buses. SWEC added attributes related to unit interconnections for require-ments of GDC 5 and attributes related to independence between the stations onsite and offsite power sources to its scope of IDA review. The team noted

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that SWEC's plans related to calculation review, one-line diagram review, g separation review, and FSAR review included all the required added attributes associated with offsite and onsite power interconnections. The inspection team was satisfied with SWEC's level of effort for this ite .3.2.2 RHR Pump / Motor Overcurrent Relay Trip Setting (Closed)

In Inspection. Report 50-353/88-200, Addendum Item 3.1.2.1, the NRC staff was concerned that the availability of the RHR pump during a LOCA/ LOOP condition could not be established because Bechtel did not analyze a starting voltage of 75 percent for the RHR motor overcurrent relay setting. The inspection team verified that SWEC had reviewed this item and that in pursuing resolution of this item, SWEC initiated DAI-150 and the subsequent Observation Report 4 Therefore, the team was satisfied with SWEC's level of effor . Instrumentation and Controls Previous IR Findings 3.3. Vital AC Instrument Power (Closed)

In Inspection Report 50-383/88-200 Addendum Item 1.3.1, the NRC staff identi-fied its concern that potential safety problems had not been assessed regarding interruption and restoration of vital 120-V ac instrument power without battery backup. The inspection team and SWEC at that time could find no evidence that battery-backed safety related 120-V ac power was being provided in the desig SWEC subsequently determined from Bechtel that GE had provided qualified Topaz inverters for safety-related instrumentation (per GE's design record file) and that these inverters were served from safety-related batteries. Bechtel also l provided a 125/250-V dc one-line diagram indicating acceptable isolation of L

inverters that are not safety related from the safety-related batteries. On the basis of its review, the inspection team agreed with SWEC that vital ac instrument power was available. Therefore, the team was satisfied that SWEC had adequately reviewed this ite .3.3.2 Single' Failure of Schematic Diagrams (Closed)

In Inspection Report 50-383/88-201, Addendum Item 3.1.3.2, the NRC staff questioned whether the failure modes of the diodes used in the circuit breaker j' control circuits had been' properly considered, were detectable, and presented unacceptable failure modes or consequences. The staff wanted SWEC's assurance that any resulting transient voltage stress on the diode had been addressed in the design and that failures of the diodes would not go undetected, thereby avoiding the potential for common-mode failure of safety functions such as load shedding. SWEC had requested the diode specifications and ratings and switch-gear maintenance / surveillance procedures from Bechtel; SWEC was still reviewing-35- ,

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these documents. The inspection team concluded that SWEC was pursuing this issue and encouraged further efforts toward completio .3.4 Mechanical Components Previous IR Findings 3.3. Pipe Stress Calculation 2-10-13 (Closed)

In Inspection Report 50-353/88-201, Section 3.1.4.1, the NRC staff identified a pipe stress program error and were satisfactorily addressed by SWEC. The first issue was addressed by DAI-151, which was discussed in Section 3.1.4 of this report. The second issue was addressed in DAI-152, which was closed out by SWEC. The inspection team reviewed Bechtel's response and SWEC's evaluation of the response and concluded that SWEC had adequately reviewed both issue .3.4.2 Piping Analysis Overlap (Closed)

In Inspection Report 50-353/88-200, Addendum Item 1.4.1, the NRC staff requested that SWEC include a review of the overlap technique employed in the pipe analysis in the IDA. SWEC's review of this issue resulted in DAI-062 which is discussed in Section 3.1.4 of this N port. The inspection team was satisfied that SWEC had adequately reviewed this ite .3.5 Civil / Structural Previous IR Findings 3.3. Category I Tank Support (Closed)

In Inspection Report 50-353/88-200, Addendum Item 1.5.3, the NRC staff requested that SWEC review the adequacy of the supports for a tank that had been designed to withstand seismic activit SWEC selected one of the 10 main steam relief valve (MSRV) air accumulator tanks located at elevation 279'6" of the reactor building and verified the loading and support design for this tank. The inspection team was satisfied that SWEC had adequately reviewed this ite .3.5.2 SWEC's Rev'cw of Document Supporting Bechtel Response (Closed)

2n Inspection Report 50-353/88-201, Addendum Item 3.1.5.1, the NRC staff noted ,

that SWEC had closed DAI-013 without reviewing FCR C-93, which was an integral l part of the Bechtel response. The inspection team verified that SWEC had reviewed the subject FCR and was satisfied that SWEC had completed the necessary action associated with this ite .4 SWEC Review of ICA Originated Issues As a result of the NRC inspection team's review of the independent construction assessment (ICA) implementation of two issues were identified which the SWEC design assessment was vocally requested to review during the IDA implementation inspection during the week of October 3, 1988. The issues were to review (1)

the design adequacy of pipe support GBB-203-2-H12 for RHR piping where a 1 i

trunnion provided support at a piping elbow and (2) the design adequacy of a reinforced block wall located in the common area between Units 1 and 2 where significant external loading had been supported by the wal j The inspection team verified SWEC's review of the subject pipe support, thich was documented in DOR-028 (see Section 3.2.4 of this report). l J-36-

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During the walkdown, the NRC ICA inspection team observed that there were many external attachments to block wall 63 in the common area between Units 1 and I According to the NRC ICA team, some of the attached loads were major load The SWEC IDA team had selected a different block wall for review. This block wall did not have as many major attachments as wall 63, but it did have some ,

major attachments and significant openings that would have made the wall {

weaker. The SWEC IDA team also briefly reviewed wall 63 at the inspection ]

team's request. In both instances, SWEC indicated that the attached loads were j included in the design. During a discussion with the inspection team, SWEC ,

indicated that Bechtel assumed that all attachments were considered to be L uniformly distributed loadings. The inspection team requested that SWEC verify 1 the adequacy of the Bechtel assumption that the major attachments (in the 800-900 lbs range) did not cause local damage to the wall. In response, SWEC t indicated that Bechtel Calculation 8301-C-22.2-L78, Block Wall Reevaluation, l Revision 0, January 19, 1982, demonstrated that the loads were insufficient to cause local damage to the block wall. Therefore, the block wall was adequate to resist the attached loads and the inspection team was satisfied with SWEC's review of the subject block wal .5 General Conclusions 3.5.1 Mechanical Systems Conclusion The inspection team found that SWEC's evaluation of Bechtel's response to the action items was technically adequate. In some cases, SWEC's evaluation lacked adequate documented justification and needed additional clarification and explanation. The inspectica team accepted the resolution of these action items on the basis of the technical adequacy of SWEC's evaluations; sometimes the team needed verbal clarification or further explanation from SWEC. However, two items remained open. SWEC closed DAI-047 without properly verifying or reviewing the equipment qualification information for the Unit 1 RHR pump / moto SWEC should review the Bechtel documents to ensure equipment qualification adequacy. Regarding a concern about parallel pump operation for DAI-067, SWEC closed the item without identifying that the test data supplied by Bechtel was for a single pump and not parallel pump operation. Subsequently, SWEC agreed to review the test data to ensure its acceptability for parallel pump observa-tio Of the three observation reports reviewed for proper inclusion of the unresnived portion of the associated action item, the inspection team was satisfied w SWEC's level of effor With regard to four findings from the previous inspection, two required additional action by SWEC. This additional action was viewed by the inspection team to be a resulc of a difference in technical judgment between the inspection team and SWEC and was not intended to adversely reflect upon SWEC's review. The first was associated with Inspection Report 50-353/88-200, Addendum Item 1.1.3, where SWEC did not verify the adequacy of the mechanical system's design input data for control valve sizing. Prior to the exit meeting, SWEC had performed the ,

requested review and the inspection team closed this item. The second issue <

was associated with Inspection Report 50-353/88-200, Addendum Item 1.1.8, where SWEC had not reviewed the actual test data to demonstrate functionality for the associated air-operated valve accumulator design. In absence of the actual test results, SWEC should review the engineering test specification, including-37-

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a review of the associated check valve leakage criteria. This latter item remained'ope .5.2 Electrical. Power Systems Conclusion

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The inspection team found that SWEC's IDA electrical review was very thorough and comprehensive and was technically adequate. Of the 12 items reviewed, the inspection team identified issues in 3 items that required additional review by SWE It was noted that the action items in the electrical area were very broad, including multiple issues within one action item; therefore, it should not be misconstrued that 3 out of 12 open items resulted in an unacceptable level of review. Instead, the inspection team was satisfied with the SWEC level of effort and technical depth of the electrical IDA review. DAI-076 remained I open pending a review to investigate the design impact where these phase fault

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currents would not be conservative compared to single-phase fault current DAI-119 remained open pending a review of the five hazards associated with an undetected fault, less than the relay setting of 18 amps, when the 4-kV buses were connected to the emergency diesel generators. Finally, DAI-261 remained open pending a review of the consequences on the battery capacity of an undetec-ted high-impedar:ce fault on the discharge side of the inverte The inspection team reviewed two action items that resulted in one observation report and was satisfied that SWEC had properly included all unresolved issues in the observation report. Also, two previous IDA inspection report findings were reviewed and the inspection team concluded that the associated SWEC action

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had properly resolved these item . Instrumentation and Control No significant problems were found regarding the DAls sampled after review and discussion with SWEC about their disposition. The DAIS were straightforward and were reviewed by the inspection team with minimal recourse to supporting documentation. Instead, most of the DAls were discussed with SWEC to determine the thoroughness of review and basis for acceptance of the Bechtel respons The inspection team found that SWEC exhibited high technical quality and thoroughness in its review of the DAIS in the variety of technical areas-covere The inspection team sampled observation reports and determined them to be acceptable after discussions with SWEC. The inspection team concluded that SWEC was doing a thorough evaluation in the instrumentation and control dis-ciplin The inspection team reviewed two items from previous inspections: (1)the question of potential problems regarding interruption and restoration of safety-related 120-V ac instrument power and (2) verification that the failure modes of diodes used in circuit breaker control circuits had been properly considered, were detectable, and did not present unacceptable failure modes or consequence This 1 sue of the 120-V ac instrument power had been properly addressed and resolved by SWEC. SWEC was still reviewing the diode issue to ensure that the diodes would not be susceptible to systematic common-mode failure as a result of improper application, device protection or ratings, or undetected random failures throughout the life of the plan _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _ - _ _ _ _ - _ - _ _ - _ - - _ _ _ _ _ -

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3.5.4 fechanical Components Conclusion The inspection team reviewed action items to evaluate the appropriateness of the Bechtel response and SWEC's subsequent evaluatio In addition, two obser-vation reports were selected for review to determine if the unresolved action item issues had been properly included in the associated observation repoi The review also included two items from previous IDA inspection reports and one item from a previous ICA inspectio The team found that Bechtel's responses and SWEC's evaluations, as written, I could be used to properly perform this review. However, a few of the responses and/or evaluations required additional information. SWEC was able to provide

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this additional information for all the cases reviewed. The team eventually found no area where significant improvement was required. The team determined that the two observation reports reviewed were satisfactory based on the action i items and responses provided. The three previous IDA inspection issues were also addressed satisfactorily. The inspection team concluded that the SWEC IDA effort to date was technically acceptabl .5.5 Civil / Structural The. inspection team sampled action items that had been closed by SWEC, two observation reports, two findings from previous inspections, and one item that was requested by the ICA inspection team. The team concluded that SWEC did a satisfactory review in the civil / structural area. For the action items reviewed, the inspection team found that all were appropriately closed with a sound technical basis. For the two observation reports reviewed, the team concluded that all the unresolved questions from the associated action items

.were included in the observation report. Also, the two issues from previous inspection reports and the one ICA issue had been properly reviewed by SWE .

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ATTACHMENT A KEY PERSONNEL CONTACTED D. J. Wille Assistant Prognm Manager l J. R. Kirby IDA Coordinator B. E. Ebbeson Lead Civil / Structural L. Boichot Civil / Structural G. E. Hirst Lead Mechanical Systems R. E. Petty Mechanical Systems A. F. Jafri Mechanical Systems A. Desai Mechanical /HVAC J. C. Bisti Lead Instrument and Controls S. C. Brahma Instrument and Controls E. Wlodarczyk Instrument and Controls J. S. James Environmental / Qualification E. F. Heneberry Lead Electrical E. B. Pickett Electrical R. M. Sibulkin Electrical K. J. Khunkhun Relay Specialist G. J. Nolan Electrical N. S. Motiwala Lead Mechanical Components K. K. Basu Stress  ;

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W. Dykstra Supports T. Wang Water Hammer P. Mitchell Seismic Qualification B. Niyogi Seismic Qualification i

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