IR 05000353/1989201
| ML20246D577 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/08/1989 |
| From: | Imbro E, Lanning W, Parkhill R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246D568 | List: |
| References | |
| 50-353-89-201, NUDOCS 8908280192 | |
| Download: ML20246D577 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSIO FFICE OF NUCLEAR REACTOR REGULATION-Division of Reactor' Inspection and Safeguards Report No.: - 50-353/69-201
. Docket No.:' 50-353
- Licensee: Philadelphia Electric Company 2301 Market. Street Philadelphia,-Pennsylvania 19101 i Facility Name: Limerick Generating Station, Unit ,2
. Inspection at: Bechtel Engineering Corporation Offices San Francisco, California
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Inspection Conducted: April 24-28, 1989 Inspection Team Members:
'IDA Coordinator E. V. Imbro, Section Chief, RSIB, NRR IDA Team Leade R. W. Parkhill, RSIB, NRR
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IDA Vechanical Systems D. Katze, Reactor Engineer, SRXB, NRR
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N. C. Singla. Consultant IDA Electrical Power Systems S. V. Athavale.. Electrical Engineer, RSIB, NRR IDA Instrumentation / Controls- J. M. Leivo, Consultant IDA Mechanical Components M.'Plunkett, Consultant IDA Civil / Structural H. Wang, Civil Engineer, RSIB, NRR MW&
- Ronald W. Parkhill, IDA Team Leader r/ 3/t9 Date Signed
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Reviewed By: N/2 N Lugene V'. Imbro, Chief, leam Inspection t/MFf Date Signed Development Section B
' Approved By: El _ @ru d '%
Wayne D. Lanning, Chie,f Dat4@Eigned Special Inspection Bra ich NRR
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B908280192 ADOCK 090823 050g3 3(
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, TABLE OF CONTENTS
?.*L* BACAGP.0VND INFORMATION ................................. I INSPECTION SCOPE AND OBJECTIVE ......................... 1 ' INSPECTION DETAILS ..................................... 1 3.1 Mechanical Systems ................................ 2 3.2 Electric Power Systems ............................ 6 3.3 Instrumentation and Controls ...................... 9 l 3.4 Mechanical Components ............................. -13 3.5 Civil / Structural .................................. 14 CONCLUSION ............................................. 17 i
APPENDIX A - PERSONNEL CONTACTED ............................ A-1
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s , LIMERICK UNIT 2
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INDEPENDENT DESIGN ASSESSMENT (IDA)
CORRECTIVE ACTION INSPECTION, APRIL 24-28, 1989 BACKGROIND INFORMATION By letter dated July 28, 1988, the NRC informed the Philadelphia Electric Company (PiCO) that it had accepted Revision I to the " Program for the Independent Design and Construction Assessment (IDCA) of Limerick Unit 2." The intent of this program was to assess the adequacy of the design and 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 t.he residual heat removal (RHR) system. The staff viewed the scope of the program as a comprehensive review of the architect-engineer's design as well as a representative sampling of all major construction attributes, including component and system testing. PECO selected Stone and Webster Engineering Cutpany (SWEC) of Cherry Hill, New Jersey, to conduct the independent assessmen To monitor the proper application of the ICCA, the NRC decided to review both the independent design assessment (IDA) and the independent construction assessment (ICA) in three phases: (1) preparation of review plans by SWEC, (2) J implementation of the review plans and performance of the review by SWEC, and (3) review and evaluation of the SWEC's final IDCA reports, including PECO's associated corrective actions. The NRC documenteo Phase 1 in Inspection Report 50-353/88-200, including recommendations for additions and clarifications to SWEC's review plans; Phase 2 was documented in Inspection Reports 50-353/88-201 and 50-353/88-203 for the IDA and in Inspection Report 50-353/88-202 for the ICA; Phase 3 is the subject of this inspection report for the IDA and Inspection Report 50-353/89-200 for the IC ,
! INSPECTION SCOPE AND OBJECTIVE During the week of April 24, 1989, the inspection team visited the offices of J the Limerick architect-engineer, Bechtel Power Corporation, in San Francisco, i California, to evaluate the final IDA repor Included in this evaluation was l an assessment of the corrective actions irrplemented or scheduled by PECO as a consequence of the design observation reports (DORS) identified by SWE . INSPECTION DETAILS The final IDA report prepared by SWEC resulted in 118 DORS. DORS were initiated where an action item remained unresolved after SWEC reviewed the Cechtel response. The inspection team evaluated the thoroughness of the final IDA report by reviewing Bechtel's response to selected DORS as well as the SWEC cvaluation of the Bechtel response. Of the 118 DDRs, the inspection team reviewed 64 DORS which were viewed to be the more significant. The inspection team was composed of two technical reviewers in the reechanical systems discipline, and one technical reviewer each in the electric power systems,
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w L i. instrumentation and controls, mechanical' components, and civil / structural
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Before perfoming the inspection, the team read the IDA final report which l ,
l consisted' of one. loose-leaf binder entitled " Volume I y Assessment Sunnary" and ~
l four: loose-leaf: binders entitled " Volume II'- Design Assessment Report,. Books L 1.,2, 3 and 4." Based on the inspection team's review of the final. IDA report, certain. DORS were selected to be reviewed on the basis of their apparent safety
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. significance. The following. sections provide a sunenary for each discipline of l this-inspectio .1! Mechanical System The IDA utilized the " vertical slice" approach focusing on the design of sub-systems and components associated with.the containment heat removal (CHR) mode of operation of the residual heat removal (RHR) system. In addition, the structures, subsystems, and components associated with cooling of the RHR heat exchanger by the RHR service water (RHRSW) system with heat rejection to the
- spray pond were included in 9.e assessmen The mechanical system review evaluated the sizing of_the major RHR and RHRSW components and material selection to support functionality of the design, including associated specifications and calculations. In addition, the design
'was evaluated to detemine its adequacy with respect to the lifting of heavy loads, high-energy line break (HELB) temperature / pressure profiles, fire protection analysis, moderate-energy pipe break effects, and radiation exposure
- mitigation to'equipnent and personnel. When the.CHR system featurcs review would not provide, sufficient basis to draw a conclusion on the overall design and related processes, reviews of other systems / subsystems were performe These reviews included,'for example, steam piping subjected to potential water hammer, and suppression pool sparger desig SWEC founo that about 60 percent of.all mechanical system DORS were a result of a review.of calculatiores. Many' calculations were found to contain unverified inputs or assumptions, undocumented engineering judgments, untraceable inputs, or inputs inconsistent with the'as-built design. In general, further explana-tions and clarifications, sometimes including additional or revised {
calculations .were required to' demonstrate that the calculations supported the final' plant design. SWEC found, however, that the calculations were sufficiently conservative and resulted in a technically adequate design, although in some cases the calculated results overstated available design 1 margin !
The inspection team reviewed the following 21 DDRs in the mechanical systems discipline: 015, 022, 023, 029, 031, 032, 0385 043, 044, 065, 083, 084, 096, 097, 098, 099, 100, 101, 109, 110 and 112. Of these DORS, three (DORS 015, 043 and 097) were' identified as open in the IDA final report because SWEC and Bechtel did not agree on the resolution. Sunrnarized below are a few of the more significant DORS that the team reviewed in the mechanical systems disciplin ~2-
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3,1.1 DDR 01.5-Verification of Nonstandard Computer Codes (Closed)
Bechtel Procedure EDP-4.37 required that nonstandard computer programs be verified. SWEC identified a nonstandard computer program, "QAC", that was not verified for the sample problems in the instruction manual but had been used in ,
Calculation 5102.1, Revision In response to the SWEC concern, Bechtel i benchmarked the calculation with the CYLSEC (NE650) standard computer code and Calculation 5102.1, Revision 1, was issue SWEC found that this revised calculation for a plant-specific geometry did .not provioe a generic verification of QAC and concluded that the validity of QAC 1 results in other calculations in which the code may have been used should be established. During the inspection, Bechtel issued Revision 1 to 00R 015 and comitted to a verification of the QAC code by performing a calculation that compared the results of the sample problems in the QAC manual with that of computer program NE650. Before the exit meeting, Bechtel provided the inspection team with Calculation 5000.62, Revision 0, which confirmed the applicability of the QAC code for the types of applications described by the manual sample problems. Bechtel further noted that there are no other applica-tions of the QAC code in Limerick calculations. The. team founo this corrective action acceptable as the calculation covers the areas of application of the QAC code at Limeric .1.2 DDR 043 - Exponential Twperature Decay Methodology for Thermal Analysis (Closed)
SWEC's review of piping stress analysis determined that Bechtel had employed an exponential temperature decay equation for pipe near reactor pressure vessel (RpV) nozzles.that reduced the temperature in the piping dead leg. This approach was apparently unconservative and lacked technical justification. In response, Bechtel provided supplemental calculations using the 1977 ASME Code, Sumer 1979 Adcenda, without the temperature reduction for thc specific problem and indicated that the results of this alternate approach were bounded by the results of the existing calculations (using exponential temperature decay and ASME III 1974 Code). Bethtel, however, did not consider this alternative approach for other cases in which the exponential temperature decay methodology was employed. SWEC accepted the supplemented calculations for this specific case but did not close the concern raised in this DDR anc requested Bechtel to apply the alternate approach using the ASME 1977 Code, Sumer 1979 Adoenda, for all other similar cases. Bechtel provided the revised response to DDR 043 to the hRC team and stated that the exponential temperature decay approach was employed only on twu other cases; the RHR return and supply lines. Eechtel re-evaluated the stress analysis of these two lines based on the conservative approach and concluded that the original results remain vali The f4RC team discussed this DOR with Bechtel and revieved document SR 8031-2300-2, ASME Section III Class I Analysis of Low Pressure Coolant Injection Systems, Revision 0, dated April 3,1989; and document SR 8301-1200-2, ASME Secticn III, Class I Analysis of RHR Return and Supply Systems Limerick GS Unit 2 Revision 1, dated April 24, 198 The irspection team noted that for RHR supply lines, as the flow originates from a high temperature of 375 F, the application of the temperature decay-3-
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l method provides a lower temperature at the location of concern and tends to increase the magnitude of temperature step change and hence provide ;
conservative result l For the RHR return lines, the flow originates from a low temperature source and the affected comporients were re-evaluated, based on no exponential temperature decay. The revised calculation indicated that the cumulative usage factor for the affected components was slightly lower than the original value and hence the original results remain valid. The hRC team also confirmed with Bechtel that the supplemental low-pressure coolant injection (LPCI) hand calculations as part of the response to DDR 043 have been made a permanent part of the Linierick 2 Class I stress report. Based on the above justifications, as they resolve all the concerns identified by SWEC, the inspection team accepted Bechtel's response and closed this DD .1.3 D0R 084 - Incorrect Nameplate for the RHR Pump Motor (Closed)
During the IDA walkdown, SWEC identified that the nameplate on the RhR pump motor referred to the original motor rnodel rather than to the inodified, current model as noteo ir. qualification documents. This mistake could have resulted in misapplication of spare parts or incorrect snaintenance. Bechtel concurred with the observation and responded that the licensee's print files were not updated when field changes were made to General Electric (GE)-supplied equipment via field deviation disposition requests (FDDRs). Also, Bechtel stated thet the corrective action to revise the subject FDDR with the correct motor mcdel number and bearing part number had been completed. SWEC accepted Bechtel's response and agreed that the incorrect nameplates were limited to the four RHR ,
pump motors and could not have resulted in misapplication of bearing part Based on the response that PECO was investigating a program to update and maintain changes to vendor prints to ensure correct spare parts and maintenance service, SWEC closed this DO The inspection team discussed this D0R with GE and Bechtel and reviewed FDDR No. hH2-8817, Revision 2, and confirined that the correct motor model number had been provided. The inspection team agreed with SWEC's evaluation and reconundation that PECO implement a vendor print update program to ensure correct spare parts and maintenance service. In a letter dated May 16, 1989, PECO comitted to develop en action plan by June 15,19B9, and in;plement it on a schedule consistent with the overall configuration.n.anagement project schedule. This action was considered appropriate by the inspection team, and
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this item is considered close .1.4 DOR 096 - RHR Relief Valves (Closed)
SWEC identified that the RHR system steam condensing node relief valves appeared to be undersized with regard to meeting their licensing basis and the ASME Code sizing criteria. In response to this DOR, Bechtel concurred that relief valve sizing did not rneet the licensing basis in the final safety analysis report (FSAR) and th6t the piping pressure drop upstream of the relief valve was neglected. Bechtel clarified that the steam condensing mode was deleted as a system cesign basis and, therefore, the concerns relative to the relief valve sizing considering the RHR heat exchanger in the steam condensing mode were no longer applicable. Also, to provide additional confidence in the adequacy of the relief valve sizing Bechtel agreed to revi m safety-related, Bechtel-procured safety and relief valves, excluding thermal relief valve )
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.SWEC reviewed Bechtel's response to this DDR and agreed that elimination of the steam condensin3 mode would invalidate the concerns that the RHR relief valve sizing calculatinas did not demonstrate design adequacy. SWEC closed this DDR based on the commitment from Bechtel that the review of all nuclear-class, l Bechtel-precured safety and relief valves (except thermal relief valves) would be performe;.
i The inspection teans reviewed Licensing Document Change Notice (LDCN) N FS-1684 dateo March 31, 1989, and Safety Evaluation BLP-47520 (unapproved by PECO) for Unit I and confirmed that the steam condensing mode had been deleted l as a mode of plant operation. Also, the inspection team reviewed Bechtel docu- )
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ment 8031-M-2048, dated April 26, 1989, covering the preliminary review of 18 Bethtel-procured safety / relief valves. This dccument evaluated the adequacy of the design process for safety valve sizing, code compliance, accuracy of design-basis input, consistency with licensing docunients, agreement with as-built configurations, and adequacy of consideration for valve location with respect to the protected components. PECO's letter of May 16, 1989, comitted 3 that the relief valve adequacy review and corrective actions would be implemen- a ted before fuel load. Based on the above calculation and connitnent, this D0R is close .1.5 D0R 097 - Heat Load Calculations for Siting the Control Room Cooling Coil for Emergency Conditions (Closed)
SWEC's review of Calculation M-78-2 showed that only the heat loads generated during normal operation were addressed in sizing the control room heating venti-lation, and air conditioning (HVAC) cooling coil. Heat gain from the emergency fresh air supply systen, which included the charcoal filter train heater ano fan heat, was oct addressed. In response, Bechtel explained that the heater filter was not considered because the emergency fresh air supply heater was controlled via safety-related humidistats to operate when the relative hunidity was higher than 65 percent. During the emergency mode of operation, when the fresh air design temperature is 95*F CB. 78*F WB, the heater is not activated as the humidity of mixed air is less than 60 percent relative humidity. SWEC's evaluation requested Bechtel to demonstrate, based on statistical weather data, when other than design conditions exist for outside fresh air that the heater would not operate during accident condition Bechtel provided the inspection tea'n with a revised response to D0R 097 and explained that the design outside air condition of 95*F DB, 76*F WB, was >
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selected for the Philadelphia area based on Chapter 33, Table 1 (cliniatic concitions for United States and Canada), of the ASHRAE Handbook of Fundamentals
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(1972). Bechtel explained that for all the outsice air conditions bounded by 95 F l DB and 78'F WB, the filter heater would not operate during the emergency condi-l tions, and the cooling coil design was adequate. Bechtel stated that emergency fresh air supply fan motor heat was included for the cooling coil design. For the other outside air conditions that are not bounded by 95 F DB, 78'F WB, during the accident events, the peak air temperatures could occur for 1 percent of the surner and, during that time, the heater would operate and the control room air temperature would exceed the allowables. Bechtel stated that for this short dura-tion during the accident conditions, there would not be any adverse effect on the control room equipment and the operator's comfort. Bechtel provided the 1 inspection team with page 410.65-1 of the FSAR which explained that the ASHRAE l Fundamentals Handbook was the basis for establishing the design conditiors for-5-
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5- outside fresh air. - The inspection team also reviewed the other recent revisions of the .ASHRAE Fundamentals Handbook and noted that outside fresh air design conditions considered by Bechtel encompassed the data provided in the ASHRAE fundamentals Handbook. Based on the information provided, the inspection team concluded that Bechtel had provided adequate assurance that the cooling coil design had sufficient capacity for the normal and emergency conditions, and the inspection team agreed that the cooling coil design was adequate. This DDR was close .2 Electric Power Systems In the electrical discipline, the SWEC review included design criteri diagrams, drawings, specifications, calculations, test reports, and' documents relating to design-changes. Engineering and design documents were compared I against FSAR design basis requirements and commitments. Drawings and diagrams ,
were reviewed for design criteria attributes such as electrical independence, {
including cable / raceway separation, grounding, and environmental condition The distribution system documents were reviewed for consistency with single-line diagrams. Overall design configuration and its impact on nearby equipment was also reviewed. Specifications were reviewed for adequate electrical and environmental requirements. Calculations were reviewed for adequacy and consistency with the design basis. The calculations included equipment sizing, voltage profile, short-circuit capacity, ecuipment i protection, breaker coordination, and cable sizing. Vendor crawings were reviewed for consistency with specifications, drawings, and diagrams. The electrical equipment was reviewee for compliance with the guidance contained in Regulatory Guide (RG) 1.89 for environmental and seismic c, vilification of the equipment and according to requirements of RG 1.75 for physical independence and redundancy. Electrical interfaces between the architect-engineer and nuclear steam supply systems (HSSSs) were reviewed for compatibility and consistency of engineering and design requirements. Recent design change docurents were selected and reviewed for technical adequacy. In addition to the design documents review, a site walkdown inspection was performed as part of the IDA program to verify compliance of the as-built system with the criteria for electrical independence and physical separatic-n, grouncing, ;
environmental qualification, and consistency of the installation with the specification SWEC's review'resulted in 17 DORS, all of which were very comprehensive in content. For resolution of these DORS, Bechtel hed to revise several calculations, several existing station procedures, and had to incorporate a hardware change that involved the procurement and installation of new sets of Class IE undervoltage relays for the emergency buses of Limerick Units 1 and Based cn SWEC's technical assessment of the electrical c% sign samples and the HRC overview, it was concluded that the station electrical system at Limerick 2 wcs technically acceptable and met the licensing commitments. In general, with one exception, in which a hardware change was performed, design deficiencies in the electrical system were not significant in that no operability concerns were identified, and were determined to have no impact on the technical adequacy of the design. However, the nature of the deficiencies and their number indicated that the Bechtel design process either lacked the " independent design verifica-tion" as required by ANSI N45.2.11 or it was not corried out in an effective manne _ _ -_ _ ____-_-_-______-________ ______-_____- -_
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The inspection team reviewed the following 14 DORS in the electrical power-systems discipline: 018, 039, 042, 078, 079, 081, 082, 087, 088, 090, 103, Ill, 113 and 115. Of these DORS, three (DDRs 039,103and113)wereidentified as open in-SWEC's IDA final report because SWEC and Bechtel did not agree on the resolution.- Sumarized below are a few of the more significant DORS that the inspection team reviewed in the electrical power systems disciplin .2.1 DDR 039 - Sizing Themal Overload Relay Heaters (0 pen)
SWEC issued this DDR to address a concern that the methodology used for selection of heaters for thermal overload (TOL) relays of continuously running 480-volt motors could result in a spurious tripping of these motors. Spurious tripping could be a result of the terminal voltage being lower than 90 percent of the rated value, the ambient temperature being higher than 30 degrees centigrade, the negative tolerance associated with these TOL relays, or any I combination of these fcctors.. Bechtel's response indicated that automatic load
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tap changers would prevent the voltage at the motor terminals from being less than 90 percent, that the actual ambient temperatures were usually below design ambient temperatures, and in some cases that the motor sizing was.Very conservative. Based on these assumptions, Bechtel concluded that no corrective ;
action was needed. SWEC did not agree with Bechtel's response and'during a- '
telephone conference call including the inspection team, Bechtel, SWEC and the licensee, SWEC informed the team that in a few cases spurious tripping may occur at terminal voltages as high as 97 percent of the rated voltage. SWEC insisted that a case-by-case evaluation of TOL relay heater selection should be performed to ensure that spurious tripping does not occur. The inspection team concluded that an evaluation of the sizing of TOL relay heaters was needed,
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' including the effects of-low voltage, high ambient temperature, and r.egative tolerances for all continuously running nonMOV, 480-volt motors required for safe shutdown. PECO's letter of May 16, 1989, committed to perform this evaluation before exceeding 5 percent power. The results of the evaluation are to be transmitted to the hRC (NRR).
3.2.2 D0R 087 - End of Life Voltage for the Vital Batteries (0 pen)
SWEC issued this D0R to address a concern that the calculation for control l circuit maximum cable length for switchgear and de motor control centers (PCCs)
concluded that the minimum end-of-life (EOL) voltage of the batteries should have been 108 volts instead of 105 volts. Bechtel's response confirmed that although the batteries were sized using an EOL voltage of 105 volts, a separate evaluation performed by the manufacturer of the batteries indicated that enough margin existed such that 108 volts could be used as the E0L voltage. SWEC accepted this response. However, th? inspection team identified that the manufacturer's evaluation did not cocfirm that this niargin was sufficient to demonstrate that the batteries were capable of handling the design load in conjunction with an undetected high impedance fault on the load side of the inverters. PECO committed in their letter of May 16, 1989, to the NRC to perform the associated evaluation of battery capacity considering 105-percent inverter loading and 108-volt EOL voltage. The results of this evaluation are to be transmitted to the NRC (NRR).
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.s ?.2.3*D0R103-EvaluationofSafety-RelatedBusSeparationiromGrid(0 pen)
This D0R was issued because the calculation for voltage regulation contained
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incorrect information relating to inputs, assumptions, methodology, computa-tions, and conclusions. In their response to these concerns, Bechtel provided many clarifications that were acceptable to SWEC. However, SWEC's concern relating to worst-case voltage was not resolved. SWEC described a possible worst-case voltage scenario as follows: the system was lightly loaded before a LOCA [thus the transformer load tap changer (LTC) was in an unfavorable positiord and a load swing occurrec as a result of a LOCA concurrent with a voltage swing of the offsite power source. In response to this concern, PECO informed the inspection team that their review of the history of grid performance revealed thut it did not experience swings such as those suggested by SWEC. Also, Bechtel stated that enough margin existed to mitigate a voltage dip caused by any postulated event. To prove that enough margin existed and that spurious separation of onsite buses from grid would not occur as a result of a grid voltage swing when engineering safety feature (ESF) loads were sequenced following a LOCA, the inspection team requested that an analysis be i performed assuming a single offsite power source, a LOCA in one unit and shutdown of the other unit, the LTC in a most unfavorable position before this event, and a dip in the grid voltage as a result of the plant trip when voltage on the grid was at minimum as a result of a regular voltage swing. Also, if during the above-described scenario, separation between onsite system and grid occurred, a cause and effect analysis would be performed assessing the capability of the ESF systems to mitigate the event without encroaching on the design safety limits, including the effect of tripping the ESF loads and resequencing on the diesel generator. Initially, PECO objected to maintaining l in its pre-LOCA position, but later agreed as the LTC
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the status nas of the LTC a high response tap (30 seconds for initial move and 3 seconds for each time subsequent step). PECO's letter of May 16, 1909, committed to revise the voltage regulation study, including the grid voltage swing before exceeding 5 percent power. The results of this study are to be transmitted to the NRC (NRR).
3.2.4 DDR 113 - Diesel Generator (DG) Ground Fault Protection (Closed)
SWEC identified that during a LOCA the existing diesel generator (DG) grounding and associated protection schemes could allow a ground fault of 18 an> peres or less to flow anywhere in the Class 1E 4kV system (including motor feeds)
without causing a trip to isolate the fault. The existing schen.e allows a current of 40 amperes for a line-to-ground fault at the 4kV bus without causing a trip to isolate the fault for a LOCA condition concurrent with a loss of offsite power. Also, the existing schcme allows approximately 40 percent of DG winding (DG differential relay trip setting of 16 amps /40 amps maximum fault current = 40 percent) to be shorted to ground without being isolated or trippe The effects of such faults on the DG capability and the effect of DG output voltage distortion on acceleration of ESF loads have not been analyzed. Ground f ault annunciation was provided in the control room. In the absence of a ground fault trip, fault currents of 4 amperes (current transformer ratio is 10:1) would flow continuously through the relay which had been qualified for 2.6 amperes continuous rating for 8 minutes. In this situation, the relay would be destroyed-8-
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relay in Class IE switchgear may affect proper operation of nearby Class 1E cir-cuits. Bechtel responded that all of these scenarios were bounded by the single failure criteria, and therefore no design change was require j l
The inspection team agreed that credit for a single failure may be taken but >
believed the existing DG grouncing scheme and associated protection circuits to be examples of poor design practice. Existing guidelines, standards, and tech- 3 nical papers dealing with this subject state that the allowable value of grou j fault current should be limited below 10 amperes. Therefore, PECO should re evaluate the sizing of the DG ground fault resistor in light of currently accepted good engineering practic .3 Instrumentation and Controls !
The SWEC IDA review in the instrumentation and control (l&C) discipline covered a comprehensive range of design topics, including FSAR/ licensing comitments; setpoint calculations and flow element sizing; instrument location drawings, instrument installation details, and instrument tubing isometric drawings; piping and instrumentation diagrams (P&lDs), logic, loop, and elementary /
schematic diagrams; procurement and installation specifications; vendor drawings and installation / maintenance instructions; discipline / group interfaces among IEC and Mechanical, Materials, Engineering Mechanics, and Electrical Departments; design change documents; nonconformance reports, and as-built verification of select 18C drawing In addition, environmental and seismic qualification for a sample of instrumentation was assessed. As the Unit 2 environmental and seismic qualification programs were extensions and modifications to the existing programs for Unit 1, but were not completed for Unit 2, some of the basis for the assessment was necessarily supported by documentation for Unit I equipment and by commitments to completion of the Unit 2 progra SWEC identified 22 DORS in the 160 discipline. Of the 22 DORS, 9 pertained to seismic qualification concerns, 5 to environmental qualification concerns, 2 to concerns about tubing supports, 2 to apparent FSAR commitment discrepancies, end singular concerns pertained to instrument location drawing discrep6ncies, nameplate discrepancies, a vender site procedure weakness, and weaknesses in the establishment and control of balance-of-plant (BOP) Q-functional setpoints in the Bechtel/PEC0 scop SWEC concluded that, with the exception of the BOP Q-functional setpoints issue, the concerns identified were generally minor. SWEC also concluded from the IDA that the corrective actions committed to by the Limerick project were acceptable, that there was no impact on technical acequacy, that the Limerick project had satisfactorily resolved all concerns, and that the extent of the concerns beyond the imediate sample had been adequately addresse tio major safety significant findings were identified in the IDA, and no hardetare changes resulted from the DORS (a commitment to provide environmental seals for certain temperature elements was reported to have resulted from planned EQ walkdown inspection activities independent of the IDA). Some
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comparatively minor FSAR inconsistencies were identified, and comitments were made during the action item resolution to revise the FSAR accordingly. Several calculations and drawings required revision as a result of the IDA. Some new setpoint calculations and seismic analyses were perfomed to resolve concerns in these area To assess the adequacy of SWEC's review and Bechtel's corrective actions in this concluding phase of the IDA, the inspection team reviewed the disposition of the following 12 DORS: 006, 021, 041, 047, 049, 051, 056, 072, 086, 094, 102, and 105. Summarized in the sections below are a few of the more significant I&C findings that the inspection team reviewe In addition to the D0R review, the inspection team tracked the resolution of two remaining potential concerns identified by the inspection team in earlier inspections Linspection Report %-353/88-200 of September 29, 1988, Addendum I, Item 1.3.2; and Inspection Report 50-353/E8-201 of November 29, 1988, Item 3.1.3.2(2)]. The first concern about wiring installation in control room panels was addressed in the SWEC IDA report, wherein several instances of separation violations were noted for Panel 200601; however, the IDA report stated that this panel had not been accepted by Quality Control and was scheduled for rework for divisional separation. Assuming correct implementation of this scheduled rework before fuel loading, the team found this resolution acceptabl The second concern about undetected diode failures in circuit breaker control circuits was resolved by retrieval of surveillance test procedures indicating that all circuits using this diode application were covered by an 18-month surveillance that would detect an open diode. The team found it necessary to expand the sample to assure that all safety-related circuits using this diode application were covered by an appropriate surveillance. For the expanded sample, the surveillance cited by SWEC/Bechtel in the IDA report (a pump / valve interlock surveillance) did not apply, but another more general surveillance (test of the loss of safeguard buses) would detect the diode failure in all applications. On that basis, the team agreed to the closure of this concer Throughout the IDA, the inspection team was generally impressed with SWEC's technical efforts and the Limerick Project's depth of responses to potential concerns identified by SWEC. Although weaknesses were found in the Bechtel 50P Q-functional setpoint/ instrument tolerance program, supplemental calculations and data provided by Bechtel appeared to substantiate the sample of existing setpoints; moreover, the confirmatory letter requested before fuel load, followed by a timely implementation of the applicant's comitment to reconstitute the basis for all safety-related setpoints, provided reasonable assurance that this weakness woulo not have a short-term safety impact and would be eliminated as a longer-term concer The number and nature of DORS and corrective actions examined did not appear to indicate any obvious or significant wealenesses in the design process. Based on i the carlier inspections cited herein, the review of the resolution and corrective actions for the DORS sampled, the review of the resolution of the additional potential concerns identified by the inspection team early in the IDA (discussed in this and other inspection reports), and based on completion of the applicant's connitted actions and confirmatory items cited herein, the inspection team agreed with SWEC's determination that the overall instrumentation-10-l E__ _ _ _ .
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arid controls design for Limerick Unit 2' met the licensing concitments and was technically adequate, j 3.3.1 D0R 021 - Establishment of Bechtel BOP Q-Functional Instrument Setpoints and Control of Instrument Tolerances (Closed) l
SWEC identified discrepancies in setpoint calculations within the IDA sample, j As one example, a setpoint tolerance calculation for a pressure switch assumed i a calibration period of 1 year in determining drift error, whereas PECO's j preventive maintenance program indicated a recalibration period of 7 years, i This and other inconsistencies led to a concern that an effective, consistent, d proceduralized, and well-documented program to establish B0P Q-functional !
instrunent setpoints and tolerances had not been established by Bechtel. The 1 potential safety significance of this situation was that inappropriate setpoints could have been established for BOP safety functions in Bechtel's scop ,
Bechtel acknowledged absence of a formal program for documenting the basis for B0P setpoints, stating that en ad hoc process using engineering judgment and project source documentation was used in determining B0P setpoints. Instrument setpoint data sheets and loop tolerance sheets documented the results, but not necessarily the input sources, assumptions, and calculations. Bechtel performed aaditional calculations to resolve this DOR; these calculations were reviewed by SWEC, and the process tolerances adequately encompassed the instrument loop tolerances. Bechtel stated that the methodology for determining total channel error in these calculations was similar to the GE methodology of NEDC-31336 submitted by the Boiling Water Reactor Owners Group (BWROG) to the staff (e.g., the basis for independent error sources). The team noted that all error contributors were assumed independent in this approach, which was less conservative than other vendor methodologies; however, on the basis of prior NRC staff acceptance of NEDC-31336, the Bechtel approach was accepted. For the discrepancies in drift intervals, PECO agreed to evaluate any effects of extending the drift / calibration basis to 18 months, and to l address any instances in which loop tolerance exceeded process tolerance, before fuel load. The results of PECO's review were documented in a letter dated May 25, 1989, to the hRC and were reviewed and determined to be
- acceptable. Effective in 1989, changes to setpoints for safety-related instruments, technical specification and FSAR setpoints, and selected existing
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nonQ setpoints censidered important to safety and reliable operation were to be performed using formal calculations. By June 30, 1989, a formal setpoint cetemination procedure was to be developed, and a 3-year to 5-year program to formally reconstitute all such instrument setpoint calculations would be l undertaken, with priority placed on those calculations important to safet Based on the sample calculations reviewed, acceptance of NEDC-31336, consideration of the comparatively limited scope of Bechtel B0P setpoints, and discussions with PECO, the inspection team generally agreed with SWEC's conclusion that the current setpoints were acceptable and that the corrective actions were appropriate. However, the inspection team requested that the following issues be clarified in a confirmatory letter before fuel load:
(1) Confirm that all Bechtcl-established 0-functional B0P instrument and channel tolerances that support the operating basis surveillance / calibration-11-L___________
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frequericies have been reviewed and properly taken into account. This is apparently the PECO position, but it was npt obvious to the team from the DO (2).:Inlightoftheweaknessesidentifiedinthe-setpointprogramregarding identification of instrument tolerances, confirm that these types of
- weaknesses did not unduly affect the accounting for critical instrunent
. tolerances required to support preoperational acceptance testing of safety-related BOP _ equipment within Bechtel's score of suppl ' The _results of PECO's review were documented in a letter dated May 25,1989, to the NRC that adequately addressed these aforementioned-issues. This DDR is closed, u 3.3.2' DDR 047 - Basis for Using Transmitter Conduit Connections That Were !
het Totally Sealed (Closed)
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i SWEC had reviewed an environmental qualification (EQ) package for Rosemount 1153 Series B transmitters, and it had been detemined from walkdowns that a tctally: sealed conduit installation had not been used for these transmitter 'Bechtel: responded to this concern by demonstrating that the transmitters of interest were not required to function under high energy line break (HELB)
conditions in the area in which they were located. SWEC expressed further concern that moisture accumulation and entry into the teminal block cavity of the transmitter might occur under nomal fluctuating conditions of humidity and temperature, and'that the effects of_ moderate-energy line breaks (MELBs)
should also be addressed. The qualifying test report did not establish thres-hold. environmental conditions beyond which a totally sealed conduit installation-was require In response, Bechtel. indicated that no credit was taken for conduit seals for these transmitters and obtained a commitment from Rosemount that the transmitter perfomance would not be affected at the design-basis maximum nomal humidity conditions. Bechtel also inoicated that there was a low probability of signifi-cant condensation; that walkdowns-indicated that all conduit entered from below the transmitter; that the likelihood of a MELB causing an instrument failure was low, based on an assessment of the pathways available for low-energy intrusive liquid; that functionality of the instrunent during a MELB was not as important, and that the MELB would not affect more than one redundant instrument. Bechtel also stateo that seven temperature sensors used to detect steam flooding were identifieo curing EQ walkdowns as requiring conduit seals, and that installation of the seals was in progress and wculd be completed before fuel loa The team discussed this D0R with Bechtel and reviewea a sample of the photographs taken during the walkdown confirmed that conduit entry was from-below. On that basis, the inspection team agreed with SWEC's acceptance of
'this DOR- resolutio .3.3 DOR-105 - Use of Nonclass IE Fuses in Circuits for Essential Safeguards System Functions (Closed)
SWEC identified that fuses used for distribution of power for the trip units on a GE elementary diagram were classified as nonsafety-related by GE. The-12-
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.that trip'un'it performed GE. quality assurancea safety) functio (QA records ~ SWEC should providediscussions appropriate with GE had indicated documentation j regarding functional testing of nonclass IE cevices'following the seismic testing of the panel; however, SWEC could not find evidence of such functional testing of the fuses / circuits in the documents originally provided by G Supplemental documentation provided by GE confinned that the fuses of interest were installed and the circuits monitored during and after the seismic test, and the results were used to qualify the panel, its circuits, and its device SWEC then reviewed and accepted the. supplemental documentatio The inspection, team reviewed part of the supplemental documentation wherein the acceptance criteria for the seismic test state, in part, that no measurable j power interruption (in the millisecond range) shall oc:ur during or after the j test. On that basis, the inspection team agreed that the seismic tests of the i panels qualify the fuses for this application and concurred with the DDR closur .4 Fechanical Components In the mechanical components discipline, the sccpe of the IDA review included piping stress analysis, supports, hazards analysis, and seismic qualification of equipment. The piping stress analysis review consisted of ASP.E Class I, 2, and 3 piping; consideration of equipment nozzle loacir.gs; hydrodynamic loads; large temperature changes; seismic anchor movements; expansion joints, and penetration design. The support review included all types of piping, ducting, and electrical raceway supports including anchors, restraints, and hangers, as well es a review of snubbers, struts, rigid frames, spring hangers, integral welded pipe attachments, baseplates with concrete anchor bolts, attachments to embeoded plates, and attachments to structural steel. The hazards review consisted of high-energy line break analyses, internally generated missiles, and Seismic II over I. As Bechtel had not completed the system walkdown inspections associated with the hazards review at the tine of issuance of the final IDA report SWEC subsequently reviewed this area and issued a supplemental IDA hazards report. This supplemental report was not included in
'the inspection team's scope of review, but was later reviewed by the NRC staff and found acceptable.
, Generally, the issues identified were minor and had no impact on the technical adecuacy of the cosign. To resolve the issues that were identified, Bechtel performed additional reviews, revised the associated calculation, or revised the design criteria to avoid future problems. Also, Bechtel initiated the appropriate actions necessary to demonstrate that the issue was bounded when it was aetemined not to be an isolated case. The inspection team found no problems with the IDA review in the mechanical components discipline and was satisfied with the level of effort show The inspection team reviewed the following six DORS in the mechanical components discipline: 001, 003, 019, 028, 089 and 099. Surmarized below are two of these DORS that the teim reviewe >
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3.4.1 00R 089 - Local Stresses for Welded Attachment (Closed)
SWEC identifico that the local stress evaluations for trunnicns/ stanchions performed using the " Stanchion" computer program may have not adequately addressed the appropriate ASME III Code requirements. Also, SWEC stated that Bechtel had not demonstrated that the conservatism in the program was adequate for all utilized cases and consideration of pressure stresses was inappropriately omitte Bechtel's approach to integral attachnient stress analysis was to first use its standard method detailed in Specification 8031-P-403, Appendix L, " Local Stress Analysis Criteria." If that approach showed that local stresses exceeded the acceptance criteria, a more detailed approach was taken using Bechtel's ME-210 program to verify the structural integrity of both the integral attachment and local stress induced into the pressure boundary. The ME-210 computer program utilizec a Bijlaard approach in evaluating the local stresses in the process pipe pressure boundary as a result of integral attachments. Bechtel's response concurred with the finding and included identifying all calculations for Limerick Unit 2 that utilized the " Stanchion" program (a total of 12) and reanalyzing them using the ME-210 program. The inspection team independently reviewed 9 of the 12 calculations and concluded that the criteria existing in Specification 8031-P-403 was conservative ano agreed with the resolution of this DO .4.2 DDR 093 - Seismic Qualification of Panel (Closed)
SWEC identified that the as-built mounting of Limerick Panel H12-P618 was different from the documented test panel mounting, and GE's qualification document oid not provide a similarity analysis between the test configuration mounting and the as-built mountin Bechtel concurred with the observation, but indicated that the use of engineering judgment in establishing similarity between the test panels was <
deliberate and appropriate. In order to resolve the issue, however, Bechtel performed a similarity analysis utilizing finite element analysis technique The results varied by only 2 to 5 percent from the GE finite element analysis for natural frequency. The inspection team concurred with SWEC's evaluation and concluded that both the bolting configuration ano testing requirements were satisfactor .5 Civil / Structural In the civil / structural discipline the IDA reviewed the structural design of selected buildings, as well as the structural elenients within the building,
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including blockwalls, structural concrete and steel, floors, walls, and equip-l ment supports. Included in this review were assessments of the associated l seismic and hydrodynamic analyse As a result of the IDA, SWEC identified instances in which licensing cornitments were not met but the associated technical approach was adequate and FSAR changes were issued, design criteria documents were changed to remedy discrepancies, ano calculations had to be revised to correct errors or to substantiate engineering judgments. However, esen though the aforementioned actions were required to resolve observation reports, the design was proven-14-
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repeatedly to be adequate. Also, all undocumented engineering judgments were provedt'o be correct. SWEC ultimately concluded that the design of structures and structural components had been completed in a technically adequate manne The inspection team reviewed the following 11 DORS in the civil / structural J ciscipline: 002, 009, 010, 011, 012. 013, 017, 024, 037, 058, and 06 Summarized below are two of these DORS thet the team reviewe .5.1 DDR 002 - Reactor Building Mat Design Calculations (Closed)
SWEC's review of the reactor building mat calculations resulted in the following concerns: (1) not all looding combinations were evaluated; (2) an approximate method of analysis was used; (3) there were discrepancies between design calculations and drawings; and (4) the footing design of Column E-29 might not be adequat Bechtel agreed with SWEC that there were some inconsistencies. bechtel aise admitted that undocumented engineering judgments were made in the design calculations. The following summarizes the Bechtel response and corrective action, as well as the inspection team's evaluation:
(1) Bechtel acknowledged that not all loading combinations were evaluated, that the r.eactor building mat design did not evaluate hydrostatic pressure as a result of ground water levels, and that footings were not evaluated forloadingcombinationscontainingsafe-shutdownearthquake(SSE) load Bechtel performed Revision 6 of Calculation 23.4, " Reactor / Control Building Foundation Design," dated October 27, 1988, and demonstrated that the hydrostatic pressure as a result of ground water levels did not govern the mat design. In its response, Bechtel also demonstrated that the loading combination involving operating-basis earthquake (0BE) controlled i design of the footing The inspection team reviewed Calculation 23.4, Revision 6 and confimed that hydrostatic pressure from ground woter did not control the design of the reactor building mat. Also, the inspection team reviewed other Seisniic Categcry I building calculations for mat design and similarly verifico that hydrostatic loadings were not controlling the design and agreed with SWEC's closure of this issu (2) Bechtel agreed that the approximate analytical rnethod did result in a rock-bearing pressure slightly exceeding the allowables used in the calculation.. However, the FSAR provided higher allowables after the rock foundation was excavated and the calculated bearing pressure was lower than the allowables provided in the FSAR. The team reviewed Table 2.5-3A of the FSAR and agreed that it provided higher allcwables than those used in the calculation. The team also reviewed a report on
" Treatment of Fracture Zones at Lirnerick," Revision 0, July 22,1974, which described the methoo used to treat the fractured rocks and clay seams. This treatment justified use of a higher rock-bearing pressure allowable, and the team agreed with closure of this issu (3) One discrepancy involved the calculation using an effective footing width of 11 feet. Although this was inconsistent with the Bechtel drawing, even-15-
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if the drawing footing width was used in the calculation, the bearing The other pressure would have increased only an insignificant amoun discrepancy involved a change in wall thickness as a result of fi changerequest(FCR)C-93.accordance Thewith project inspection teamdesign control proce that a calculation change was not warrante determined that revisions to drawings were adequately controlled by project procedures and agreed with closure of these discrepancie SWEC was concerned that the footing for Column E-29 was sized in accordance with the similar footing of Unit I without Therefore, verifying tha design parameters were the sam less for Column E-29 than the similar column footing in Unit SWEC reasoned that the footing for Column E-29 might not be adequ designe Bechtel's response indicated that after the foundation was s were excavated it was determined that the allowable rock-bearing press the Aftersame for both unit treatment, the allowable rock-bearing pressure was higher, as li The team reviewed the Section 2.5.4.12 d of in Table 2.5-3A of the FSAR.the FSAR and the report on * Treatmen agreed with closure of this issu . DDR 009 - Seismic Load on Block Walls (Closed)
concerned that horizont41 frequencies were used f t seismic acceleration, ano that scaling factors ba camping to 2 percen The Bechtel response indicated that dengineering the occasional usejudgn.ents of were
.the conservativeness of the analytical approach an Bechtel scaling factors at regions of the spectra other than at lthe lations d this peak performed a comprehensive review of all safety-related block wall c and found that most safety-related block lwall frequenciesdesign calc app) the use of horizontal wall frequencies instead of vertical roac tical wal (1 to calculate vertical responses conservatively highly overe ,
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of increased damping showed that there were no changes for the mos loaded block walls as the adjusted peak did not chang ll The inspection team reviewed Calculation 22.2L66, 20, 1988, and found that use of the horizo Also, the
"Re-evaluat
756.57," Revision 5, December frequencies to calculate vertical responses was conservativ l ll f
desig overall spectral curves showed that seismic load changes as a resu t increased damping were in the rigid range which did not affect the wa The inspection team agreed with SWEC's closure of this ite m=~~-_-__
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4 ,~ ' CONCLUSION'
The~ inspection' team was satisfied with the level of effort and thorough
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the 10A. f This program coupled with the PECO counitments documented
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16, 1967 and May 25, 1989, provides the necessary to the.NRC dated Mayadditional design assurance that Limerick Unit 2 has m comitments and is adequately designed.
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APPENDIX A PERSONNEL CONTACTEDAffiliation DURING INSP i
Title Bechtel Name Bechtel'
Senior Engineer Bechtel B.-Acosta Civil Engineering Group Supervisor i er Bechtel
- V. Aggarwa l
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Lead Mechanical Analysis Group Eng ne A. Arastu Lead Engineer for Mechanical / Nuclear SWEC
- G. Ashley, III Staff Bechtel-Assistant Project Manager, IDCA SWEC
- W. Baronowski Lead Civil Engineer for IDCA PECO f M.-Bhatia- IDA 1&C Discipline Lead SWEC J. Bisti Mechanical Engineer Bechte .
- W. Brady IDA 18C Engineer Bechtel S. Brahma Bechtel'
R. Bulchis IDCA CoordinatorChief Civil Structural BechtelEngineer Bechtel s
- P. Chang-Lo Piping Engineer I
.h .C. Chern -Civil Engineer _ Pottstown r Bechtel l K. Clough - -
Bechtel
- J. Coughlin Lead Staff Radiation Shielding Enginee Electrical Bechte1~
D..Dexheimer Engineering Supervisor Bechtel 1. Doncow Chief Engineer,~ Control Systems Bechtel
- J.'Edlinger Electrical Engineer Bechtel Bechtel E. Fabri Mechanical EngineerChief Engineer, BechtelElectrical j W. Fair Bechtel
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S._Giusti -EQ Engineer
- C, Haynes
- D. Helwig Assistant to Executive Vice President
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i Manager of Engineer ng Bechtel Bechtel Vice President Bechtel 1
- R. Henderson Bechtel j
- H.' Hollinghaus IDA Lead Manager '
- E. Hughes Piping Engineer Bechtel Project Engineer Bechtel D. Hsu Bechtel
- M. Iyer
- W..Jon Quality AssuranceGroup Leader - Electrical Bechtel Project Engineer Bechtel A. Kar Bechtel
K. Lee Lead Civil EngineerGroup Supervisor, Bechtel Electrica/
S. Loo Bechtel
- W. Lui SystemsLimerick 2 Startup Director Bechtel i
W.t Cullough Staff Engineer Seismic PECO EQ Engineer Bechtel T . Mt onald Bechtel E. Me curio Senior Engineer
- W. Mindick Civil Engineer H. Minkonski HVAC Engineer j V. Nercessian A-1 f I
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Bechtel-Mechanical Supervisor Bechtel
- R. Nossardi Sr. Engineer -_ Mechanical Systems GE M. O' Conner Limerick Project Engineer Bechtel R. Pence Mechanical Systems Engineering Specialist Bechtel E. Purcell EQ Engineer - Environmental Bechtel U. Reider -Electrical Engineer Bechtel A. Rifai
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Piping Enginee Bechtel M. Schletd Deputy Group Supervisor. Control J. Schott Systems Bechtel Controls Engineer Bechtel R. Senior EQ Engineer Bechtel S. Shama HVAC Engineer Bechtel D. Strassman EQ Engineer - Environmental Bechtel
- J. Strohm Assistant Chief Electrical Engineer Bechtel
- T. Tam Supervisor - Mechanical Systems
'S. Yim
- Attended Exit Meeting A-2