IR 05000445/1986019
| ML20215N831 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/28/1986 |
| From: | Imbro E, Norkin D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20215N784 | List: |
| References | |
| 50-445-86-19, 50-446-86-16, NUDOCS 8611070321 | |
| Download: ML20215N831 (42) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Division of Quality Assurance, Vendor, and Technical Training Center Programs Quality Assurance Branch-Report Numbers: 50-445/86-19, 50-446/86-16 Docket Numbers: 50-445, 50-446 Licensee: Texas Utilities Generating Company
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Skyway Tower 400 North Olive St., L.B.81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station Inspection At: TERA Corporation, Berkeley and San '
Jose, California (July 7-16,1986)
Inspection Team:
Team Leader: D.P. Norkin, Senior Inspection Specialist, IE Civil / Structural: K.P. Buchert, Consultant, WESTEC Services J. Blackman, Consultant, WESTEC Services P. Bezler, Consultant, Brookhaven National Laboratory Piping / Supports: D. Terao, Mechanical Engineer, NRR W.P. Chen, Consultant, WESTEC Services Electrical /I & C: G.W. Morris, Consultant, WESTEC Services L. Stanley, Consultant, Zytor, In \
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Io-27-N Donald P. Norkin Date Team Leader, IE Approved by: 8 7. M* N - 2 f-f6 Eugene V. Imbro, Chief Date Licensing Section Quality Assurance Branch 8611070321 861104 PDR ADOCK 05000445 G PDR
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. INTRODUCTION AND SUMMARY
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1.1 BACKGROUND
- The NRC's Office of Inspection and Enforcement (IE) conducted an inspection of the Comanche Peak Design Adequacy Program (DAP) during the period from October 28 to November 1, 1985. This inspection focused on DAP review scope and depth and personnel qualification The inspection report was issued on January 21, 1986. Since that-time, Revision 3 of the Comanche Peak Response Team (CPRT) Program Plan has been issued (January 27, 1986), the Phase 3 DAP
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scope expansion has been executed in order to encompass all of the design activities for safety-related systems, and TERA has expanded its review team, including the addition of about 60 Gilbert / Commonwealth personnel. IE performed an in proccss assessment of (1) TERA implementation of the self-initiated portion of.the DAP, and (2) the TERA third party reviews of Stone and Webster, Ebasco, and Impell reanalysis work. Inspection report 50-445/86-18, 50-446/86-15 dated September 9, 1986, documented this assessment for Discipline Specific Action
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Plan (DSAP) .2 ' PURPOSE Th'is inspection addressed implementation of DSAPs VIII, IX, and XI for the
, civil / structural, piping / supports and electrical /I & C disciplines, respectively. For self-initiated reviews covered by DSAPs VIII and XI, the
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inspection addressed two aspects: (1) whether TERA's reviews were -
representative, such that results of the reviews of specific design documents could be extrapolated to design documents not reviewed, and (2) whether TERA's reviews were effective in identifying discrepancies. For TERA's third part overviews of external source issue corrective action programs in DSAPs VIII and IX, the inspection addressed (1) issue identification and resolution and (2) assurance that licensing commitments, codes and standards, as well as-externally identified issues, are addressed in analysis procedure . 3 METHODOLOGY
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For the self-initiated review, the two key elements of IE's inspection were to evaluate whether: -(1) design products sampled by TERA were representative of
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the design activities being reviewed, and (2) TERA performed an adequate review of Gibbs and Hill and other design document With respect to representativeness, Appendix D of the CPRT Program Plan' states that homogeneous design activities (HDA's) include items'(e.g. calculations)
g for which a high degree of correlation (homogeneity) exists in design criteria and design considerations, approach and methodology. Accordingly, evaluation of the adequacy of each HDA can be based on evaluating a representative
- selection within each HDA. Procedure DAP-21, " Homogeneous Design Activity
! Validation and Selection of Specific Items for Review", established a process for. validating the homogeneity of each HDA by briefly reviewing (or scanning)
a minimum of five documents within the HDA population to confirm homogeneity )
relative to design criteria and design considerations, approach and l methodology. Items scanned are required to be " distributed approximately even <
through the period of performance of the work as indicated by the current revision date of the document."
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DAP-21 also established a process whereby one or more items are selected for detailed technical review within each HDA. The emphasis is on selecting items within one of the systems included in the initial self-initiated program vertical slice; e.g. , the auxiliary feedwater (AFW) system. In cases where this system is not considered to.be representative of the HDA relative to comprehensiveness and/or complexity, DAP-21 provides other bases for system selection, starting with a system having direct interfaces to the vertical slice syste IE determined that DAP-21 provided an adequite method for documenting the confirmation of homogeneity of design documents within each HDA with respect to-design criteria and design considerations, approach and methodology. DAP-21 piso provided an orderly method for documenting the bases of selection for review of design documents within specific systems. IE inspected documentation for TERA's DAP-21 scanning and selection process, as well as some of the documents scanned by TERA, in order to evaluate whether the design activities were homogeneous and the items selected for detailed review were representative of the HDA in comprehensiveness and complexity. Where TERA reviewed 100% of the documents in
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the HDA, DAP-21 was not applicabl With respect to evaluating the adequacy of TERA's detailed reviews of selected documents, IE reviewed the TERA design review evaluations and Discrepancy / Issue Resolution Reports (DIRs) which documented the reviews and the actual architect-engineer documents which TERA reviewed. The team reviewed the latter documents in order to determine whether. TERA had identified all discrepancies. IE also reviewed some documents within HDAs that were not selected by TERA for review in order to assess the appropriateness of extrapolating TERA findings on the selected documents to others in the populatio Sections 2 through 5, are organized by " review topics". For each, the team reviewed the adequacy of TERA's detailed technical review of documents and/or the scanning process by which TERA determined the representativeness of reviewed documents in an HDA. For some review topics, both elements were not reviewed because TERA had not completed the wor In addition, not all review topics were reviewed by the team, primarily because TERA had not completed work for about 25% of the review topics. Despite these limitations, the team was able to adequately sample the reviewed topics and the review proces As referred to above and under Sections 2 through 5, " scanning" (either by TERA or the team) is a brief review of the document to evaluate methodology for purposes of confirming homogeneity per DAP-21. " Reviewing" is the detailed evaluation of the document to determine if it meets design criteric commitment Stone and Webster, Ebasco, and Impell are verifying the design adequacy of piping, pipe supports, and cable tray / conduit supports in response to external source issues. TERA is performing third party overviews of this process. Due to the status of TERA's reviews, the team's inspection was limited to third party reviews to ensure that (1) appropriate issues had been identified, (2) action was being taken to resolve them, and (3) analysis procedures address licensing commitments, codes and standards, as well as external source issues. In some cases the team reviewed preliminary reports because that was the only documentation available. This was consistent with the intent of this
"in process" inspection, i.e. to identify and correct discrepancies and trends prior to issuance of the results reports. Subsequent team inspections will address the implementation of TERA third party overviews of Stone and Webster, Ebasco and Impell calculation package _ - - -- -
r s 1.4 SUMMARY
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This was an in process inspection occurring prior to completion of the DSAPs and issuance of results reports. Sections 2 through 5 identify positiva aspects, as'well as discrepancies which require corrective actions and are highlighted below. The team will make conclusions on the overall DAP after it evaluates the resolution of these discrepancies and the final results report Based on scanning the same Gibbs and Hill calculations which were scanned by TERA, the' team found discrepancies with respect to variability in the application by Gibbs and Hill of design methodology for 4 of 18 civil / structural HDAs. The team was concerned that this variability raised questions about the ability of TERA to extrapolate findings (within such HDAs) from calculations reviewed to those not reviewed. TERA stated that (1) DAP results confirm that there are variabilities in the application of methodology for certain civil /
structural HDAs, and (2) where a significant number of variabilities, adverse trends or deficiencies exist within an HDA, the corrective action program would need to address the complete scope of the HD (0 pen Item C-6)
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The team reviewed the representativeness of 25 DAP review samples, and found one example where TERA had committed to reviewing six auxiliary feedwater support systems, but only addressed one such system in its design review evaluatio (0 pen Item I-6)
The team raised several questions concerning the applicability of specific design criteria to related reviews. See Open Items P-1, I-1, I-2, I-8, and I-1 It is understood that Procedure DAP-4 allows the reviewer to select fewer than 100% of the applicable criteria, provided that the bases for such selection are documented with the Design Review Summary for These forms had not been prepared at the time of the inspection, and may resolve some of the team's concern With respect to external source issue identification in the piping / supports discipline, the team found four external source documents which were not used by TERA to identify issues, and which contained issues not addressed in other documents reviewed by TERA (0 pen Item P-3). In addition, the team found examples where an external source issue (e.g. an ASLB concern) was either not identified (DIRs are used to identify external source issues) or the issue was incorrectly characterized in the DIR. (0 pen Items P-4 through P-8). With respect to ASLB concerns, TERA stated that ASLB interpretations of issues will be included to the extent that it affects a basis for TERA's acceptance criteria in resolving the issue. This is apparently a narrower definition o.f issue identification than indicated in DSAP IX and needs to be clarifie (0 pen Item P-9).
The team reviewed three draft issue evaluation report In two cases the acceptance criteria for issue resolution were incorrect and/or did not reflect related external source issues (0 pen Items P-11 and 13). In one case, the evaluation report did not provide the basis for concluding that SWEC's procedure addressed the issue (0 pen Item P-12). The team acknowledges that these were draft evaluations, but it is important that issue evaluation reports be well prepared in order to provide the basis for subsequent SWEC and TERA action i
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t 2 The team found the following discrepancies in its review of Gibbs and Hill and
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other design documents within the scope of the DAP. These were not addressed in DIRs, in some cases because TERA had not reviewed the same document or technical are (1) In the_ c6ntainment shell design, analyses did not justify assumed worst case conditions with respect to including the stiffness of the liner plate (0 pen Item C-3), combination of thermal gradient in the shell and corresponding liner pressure and temperature (0 pen Item C-4), and examining uncracked, fully cracked, and partially cracked concrete sections (0 pen Item C-5).
(2) Setpoint calculations for AFW pump suction pressure instruments did not consider the dynamic effect of pump suction flow on the instrument (0 pen Item I-5).
(3) The control logic for the diesel generator fuel oil day tank pump has discrepancies which could prevent automatic operation of the backup fuel
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oil pump (0 pen Item I-12).
1.5 DAP PERSONNEL CONTACTED 1.5.1 MANAGEMENT NAME POSITION D. Davis President, TENERA H. Levin DAP Review Team Leader F. Dougherty DAP Manager T. Snyder Eng. Mgr., Piping / Civil R.F. Schofer System Eng. Manager J.V. Neely CPRT, 0QT Q.B. DuBois QA Manager J. Miller Site Manager C. Whitehead Management Coordinator R. Newman Deputy Site Manager 1.5.2 CIVIL / STRUCTURAL-NAME POSITION R. Alley Group Leader G. Awakeem Reviewer T. Ballard Reviewer J.L. Chameau Reviewer J. Fulton Reviewer M. Gencer Reviewer N. Gettel Reviewer A. Ghose Group Leader D. Goodyear Reviewer C. Kircher Group Leader D. Koppe Reviewer D. Krause Reviewer 3 Y. Lee Reviewer ,
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T.L. Moore Reviewer C. Mortgat- Discipline Coordinator F. Pisarck Reviewer P.Rieck Reviewer R. Sanan Site Activity Leader R. Srinivasan Group Leader J. Sturkey Reviewer R. Mauchline Reviewer D. Patterson Reviewer P. Kaul Reviewer S. Patel Reviewer Y. Bozorgnia Reviewer 1.5.3 PIPING / SUPPORTS NAME POSITION
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E. Wais Discipline Coordinator D. Witt Deputy Discipline Coordinator S.'Wrona Group Leader, Supports L. Hishiguchi Acting Group Leader, Piping 1.5.4 ELECTRICAL /I & C NAME POSITION D. Brosnan EIC Discipline Coordinator L. Bates Deputy Discipline Coordinator G. Setka Deputy Discipline Coordinator K.'Mardirosian Electrical Deputy Discipline Leader G. Reimers Electrical Reviewer C. Harnsmut Electrical Reviewer K. Majumdar Electrical Reviewer R. Miller Site Activities Leader R. Getty I&C Reviewer S. Giannini I&C Reviewer B. Hendrix I&C Reviewer H. Ilisko I&C Reviewer K. Miller Deputy Discipline Coordinator R. McCarty I&C Reviewer T. McLean I&C Reviewer M. J. Shah I&C Reviewer W. Sturtz I&C Reviewer CIVIL / STRUCTURAL Review Topic: C01.03 - Tornado Representativeness of Reviewed Documents:
TERA scanned all six calculations (as indicated below) in HDAs C005, Tornado Wind Loads, and C006, Tornado Pressure Drop Loads:
t a DMI-9C,1 (Tornado Venting Pressure on Class 1E Equipment).
. SMI-113C,1 (Pressure Due to Tornado Venting on Concrete-Auxiliary Building, Safeguards Building, and Fuel Building). SAB-104C,1 (Floor Elevation 873'-4" Slabs & Beams). SMI-101C,4 (Gust Factors-Reactor Building and all Buildings Taken Together, Fuel Building). SAB-123C1,1 (Exterior Wall Reinforcing Above Elevation 810'-6"/807'-0" to Roof Vertical and Horizonal Reinforcing) SAB-119C2,5 (Auxiliary Building Design of Exterior Wall @ Mid-Height &
Top of Mat to Elevation 810'-6"/807'-0").
The team scanned the same calculation The team understands that TERA plans to transfer some'of these calculations to other HDAs because of differences in
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methodology, and that other calculations may be transferred to HDAs C005 and C006. TERA plans to review all calculations within the latter HDAs. Based on these plans, the DAP-21 requirements for selection of representative review samples are not applicabl Review of Documents:
TERA had not yet completed its review of documents for HDAs C005 and C006; therefore the team did not evaluate this area. However, the team was concerned whether safety-related architectural items would be addressed, e.g. computer room floors, interior doors, door anchors and stops, tornado. gratings, tornado missile stops or deflectors and tornado wall vents. Architectural drawings should be reviewed in two contexts: *
1) the interaction between seismic Category 1 d nonseismically designed components, and *
2) the tornado depressurization analysis where architectural details should be considered as potential missile TERA stated that the first item is presently covered under the review of TRT Issue II.D. The_second will be considered as part of the tornado and depressurization analysis review that.is part of the current DAP civil /
structural review scope (HDAs C004, C005, C006, CO25). The team considers that these plans should effectively address architectural items, and will follow-up in this area in addition to ensuring that the above calculation transfers and reviews 'are implemented for HDAs C005 and C00 Open Item C-1 Review Topic: C01.05 - Seismic Representativeness of Reviewed Documents:
TERA scanned all calculations (as indicated below) in HDA C030, Seismic Analysis-Structural Modeling:
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~ DRB-10,1 (Reactor Building. Seismic Analysis).
- DAB-1C,1 (Auxiliary Building-Dynamic Analysis). DFB-1C (Fuel Building-Dynamic Analysi . DIS-1C,1 and DIS-1C,2-(Service Water Intake Structure-Seismic Analysis). DMI-2C,5 (Fundamental Frequencies of Nuclear Safety Related Buildings). DMI-4C,9 (Supplementary Calculations to Automation Industries Seismic Report #2462-1). DMI-4C,12 (Torsional Eccentricity in Dynamic Analysis of Category !
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8. GMI-1C (Safeguards & Auxiliary Buildings Natural Frequencies)
9. SAB-120C1,2 (Preprocessing for Auxiliary Building Dead Load Beam Mass,
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Manual Calculations).
10. SAB-120C2,3 (Auxiliary Building-Preprocessing Seismic Input Calculations).
11. KRB-1C (Stiffness & Flexibility Matrices for R.C.S. and Pressurizer Supports).
12. DSB-1C,1 (Safeguards Building - Dynamic Analysis)
The team scanned the same calculations, and agreed with TERA's conclusion
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'that the calculations were homogeneous because they had similar design considerations, approach and methodology. Calculations DRB-1C,1, DAB-1C,1, DSB-1C,1, SAB-120C2,3 and DMI-4C,9 were selected to be reviewed in detail by TERA, but the review was not yet complete. The selection criteria took into consideration TERA's commitment to review the auxiliary building as an example of a major Category I building. (Reference IE inspection report 50-445/85-17, 50-446/85-14 dated January 21, 1986, Appendix 2). The auxiliary building was .
selected by TERA for this HDA because it was. representative of design using a computer program. The reactor bui'lding and safeguards building calculations were selected because they were representative in complexity and comprehensiveness of hand calculations for the HD Review of Documents:
The team did not review this are Review Topic: C04.01 Containment Shell/ Discontinuities Representativeness of Reviewed Documents For HDA C064, Contlinment Large Openings, TERA reviewed all eight calculations: SRB-122C,1 (Reactor, Building Containment Personnel Airlock, Unit 2). SRB-122C,6 (Unit 1, Reactor Building Containment Wall in Equipment Hatch Blockout Area). SRB-160C,1 (Reactor Building #1, Equipment Hatch Area in Containment Wall). SRB-160C,3 (Unit #2, Equipment Hatch Area in Containment Wall). SRB-169C,1 (Unit 2, Containment Liner for Equipment Hatch). SRB-131C,1 (Reactor Building Containment Equipment Hatch Cover / Designs Hatch Embedments & Monorail). SRB-2C1,1 (Finite Element Analysis of Equipment Hatch). SRB-2C2,1 (Finite Element Analysis of Equipment Hatch).
Since all calculations in the HDA were reviewed, the DAP-21 requirements were not applicabl *
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. Review of Documents:
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The team reviewed all of the above HDA C064 calculations as well as the associated. review checklists and found that the checklists and attached ;
supplementary comments adequately covered key points in the calculation The team also reviewed five DIRs referenced in the checklists and found them to adequately address discrepancies in the calculation Transfer of loads to the-civil discipline, e.g. from the piping discipline, - H is an important interface which needs to be verifie TERA has a DIR and a relate'd June 4, 1986 memorandum to its reviewers covering procedures for load verification by TERA as part of the DAP reviews of calculations, such as those above. The TERA memorandum also applies to HDAs C058, C070, C073, C077, C078, C080, C084, and C087. In addition, a final load verification program was performed by Gibbs and Hill on a sample basis. TERA will review this under HDA C190 with respect to component selection basis, acceptance criteria and implementation. The team will follow-up on the results of the above programs. Open Item C-2 In the containment shell hatch design, the original analysis included the stiffness of the liner plate. Although no load was assumed to be carried by the liner plate, the load distribution might be affected by the inclusion of the liner stiffness. This is contrary to ACI/ASME 359, which is committed to and requires consideration of both including and not including the liner plate, whichever represents the worst stress cas Open Item C-3 TERA reviewed the following calculations for HDA C058, Containment Shell: SRB-110C,3 (Reactor Building Containment Wall Reinforcement). < SRB-112C,1 (Reactor Building Containment Wall Reinforcement). SRB-122C,4 (As Built Shear Reinforcement). SRB-1220,5 (As Built). SMI-106C,1 (Summary of Category I Structures). SRB-3C1,1 (Reactor Building Containment, Static Analysis). SRB-3C2 (Reactor Building Containment, Static Analysis). SRB-122C (Shell Analysis).
The team reviewed TERA review checklists and the above calculations in order to evaluate the depth of the review. TERA's review checklists (and attached supplementary comments) adequately covered key points in the calculations and appropriate design criteria. The team reviewed the forty-nine DIRs pertaining to the calculations and found them to correctly characterize the design issue In the evaluation of the containment shell for the LOCA accident condition, the original analysis assumed peak pressure and temperature on the containment liner and uniform operating temperature gradient through the concrete shel Additional justification should have been provided to show that this was, in i fact, the controlling set of assumptions. Specifically, some possible combina- '
l tion of nonlinear thermal gradient in the concrete shell and corresponding liner pressure and temperature conditions might be more significant than.that assume Open Item C-4
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Ippthecontainmentshelldesign,theoriginalanalysisexaminedtwopossible corditions of an uncracked and a fully cracked concrete section. A partially cracked section should have.been considered as well, i.e. as potentially the
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worst stress case. This concern also applies to the containment shell hatch 'I design (HDA C064). I
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Review Topic: 'C04.03 - Internal Structures Representativeaess of Reviewed Documents:
For HDA 066, Concrete Walb, TERA scanned all eight calculations:
" SRB-110C,8 (Reactor Building Internal Structure-Wall Elevation 832'-6" to Wall Elevation 860'-0"). SRB-116C,1 (Slab at Elevation 783'-7" & Elevation 808'-0", Elevation
._ s 819'-6", Elevation 822'-9", Wall Between Elevation 783'-7" & Elevation
,808'-8").
T3 SRB-118C,1 (Walls to Elevation 832'-6" (Dowells) Reactor Building Internal i [4
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SRB-119C,1 (Reactor Building Internal Structural Floor Elevation 851'-6"
& Walls).
5. SRB-120C,3 (Reactor Building Elevation Wall 905'-0" to Elevation
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933'-3", Guard Rail Beam & Support). SRB-118C,3,(Reactor Building 2-Refueling Pool Core Wall Honeycombs). SRB-119C,3!(R(actor Building-Internal Structure Elevation 905'-9"). SRB-117C,21 (Reactor Building #1-Comparison of Design and Final Loads of WE NSSS Equipment).
s The team scanne'd the same calculation's,'and concluded they were homogeneous with raspect to methodolog TERA selected (for review) calculations SRt-116C,1, SRB-120C,3, SRB-118C,1 and SRB-119C,l', b'ut the reviews were not
, (completed. The t.Eam found that these calculations were sufficiently complex an,d comprehensiv'e to be representative of the HD ,.
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Review of Documents:
The team did not review this are p Review. Topic; C04.05 - Fuel Building Representativeness of Reviewed Documents:
The team did not review this area.
N- Review of Documents:
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l For HDA C070, Fuel Building, TERA reviewed the following calculations: ' SFB-104C,1 (Fuel Building from Elevation 838'-9" to Elevation 860'-0). SFB-105C,1 (Fuel Building from Elevation 860'-0" to Elevation 918'-0"-Roof). SFB-103C,1 (Fuel Building from Ground Floor to Elevation 838'-9").
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The team reviewed the above calculations and the associated review checklists, and found that the checklists and attached supplementary comments adequately covered important aspects of the calculations. The team also reviewed the thirteen DIRs resulting from TERA's review and found that they correctly docu-mented discrepancies with the calculations. The team did not identify additional
' discrepancies in the calculation Review Topic: C05.01 - Frame of Cable Spreading Room Representativeness of Reviewed Documents:
For HDA C073, Structural Steel- Cable Spreading Room, the team found (based on scanning the same calculations which TERA scanned) discrepancies with respect to variability in the application of methodology in the Gibbs and Hill t calculations. This finding applies to other HDAs as well: C077, C078, C080 and C084. Specific areas of variability include analyzing torsion, dynamic amplification. factors used, handling load interaction, consideration of thermal
~ effects, consideration of experimental anchor results, square root of the sum of squares (SRSS) vs. direct summing of seismic loads, analyzing multicomponent load, evaluating connections, analyzing welds, checking coping of beams, and checking local stresse l TERA stated that the DAP results (DIRs) confirm that there are discrepancies l ir. the application of methodology by Gibbs and Hill for certain HDAs, and where a l significant number of discrepancies, adverse trends, or deficiencies exist within l an HDA and the extrapolation of results for the review sample to the. entire ;
HDA is likely to be negative or unmeaningful, the corrective action program would need to address the complete scope of the HDA. Under these circumstances, TERA considers that the HDA concept provides a mechanism for defining the bounds of applicability of identified discrepancie Due to the above examples of variability in Gibbs and Hill methodology, the team is unable to reach conclusions as to the homogeneity of the specific HDA Such conclusions are a prerequisite for assessing the representativeness of the review sample. The team will follow-up on corrective actions for these discrepancies to ensure that either the complete scope of the HDA is addressed or that the discrepancies are properly extrapolated to all affected calculation Open Item C-6 Review of Documents:
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For HDA C073, Structural Steel-Cable Spreading Room, TERA reviewed the following calculations: SAB-13'7C,1 (Cable Spreading Room-As Built, Verification Program Capacities). SAB-137C,7 (Auxiliary Building-Cable Spreading Room, Unit 1-As Built, Connection & Member Evaluation-Supplement "0"). SAB-137C,19 (Auxiliary Building-As Built Connection & Member Evaluation-Supple. ment 21). SAB-135C,7;(Auxiliary Building-Cable Spreading Room, Load Tabulation Elevation 821'-2").
The team reviewed the above calculations and related review checklists. The checklists and attached supplementary comments indicated that TERA adequately
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covered the most important areas of the calculations, e.g. acceptance criteria,
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loads / load combinations, and stress analysis details. The team reviewed the
/ thirty-three DIRs resulting from the reviews and found them to be consistent with discrepancies in the calculations which the team observed. The team did not identify discrepancies in the calculaticns which TERA failed to identif Review Topic: C05.08 - Containment Liner (HDA C077-Containment Liner and Liner Anchorage)
sRepresentativeness of Reviewed Documents:
TERA scanned all fifteen calculations: SRB-105C,1 (Containment Liner Anchors). SRB-110C,6 (Reactor Building Containment Spray Pipe Supports). SRB-113C,1 (Reactor Building Containment Spray Pipe Supports &
Ventilation Duct Supports).
- SRB-113C,3 (Reactor Building Containment-Checking Liner Plate &
Embedments Unit #1-ITT Pipe Hangers & Supports). SRB-113C,11 (Reactor Building #1-Attachments to Containment Liner-Details 4&6, As Built). SRB-169C,1 (Unit-2, Containment Liner for Equipment Hatch). SRB-105C1,2 (Reactor Building-Unit #1, Investigation of Embedded Plates). SRB-109C,2 (Reactor Building-Unit #1, Rotating Platform). SRB-110C,2 (Reactor Building #2, Containment-Liner Plate Pipe Support Attachments to the Liner).
10. SRB-110C,4 (Reactor Building Liner-Polar Crane).
11. SRB-110C,5 (Reactor Bui1 ding Liner-Rotating Platform).
12. SRB-110C,13 (Refueling Area Stainless Steel Liner).
13. SRB-161C,5 (Reactor Building-Pipe Support).
14. SRB-105C,1 (Reactor Building #2-Stainless Steel Liner Bowing).
15. SRB-109C,1 (Containment Liner & Equipment Hatch).
The team scanned the same calculations, and found variability in methodology as indicated above under Review Topic C05.01. Team follow-up with respect-to this matter will be addressed by Open Item C- I Review of Documents:
The team reviewed calculations reviewed by TERA (SRB-105C,1, SRB-113C,3 and SRB-109C,1) and related review checklists, and feund that the checklists and attached supplementary comments adequately covered key points in the calculations. The team reviewed the thirty-three DIRs pertaining to the calculations and found them to accurately document discrepancies in the calculations. The team found no additional discrepancie Review Topic: C05.00 Structural Steel Design Representativeness of Reviewed Documents:
The team did not review this are ,
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Review of Documents:
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For HDA C078, Refueling Pool Liner and Spent Fuel Pool Liner, the team reviewed calculations reviewed by TERA (SRB-105C1,2-Refueling Pon1 Liner and SFB-106C,2-Pipe Support Attachments to Liner) and the associated review checklists. The checklists and attached supplementary documents indicated that TERA reviewed the major areas of the calculations. The team also reviewed the twelve DIRs resulting from the reviews and found them to correctly reflect discrepancies in the calculations. The team's independent review of calculations did not identify' discrepancies not found by TERA. As indicated under Review Topic C05.01, the team found that the calculations varied with respect to methodology. Team followup with respect to this matter will be addressed by Open Item C- Review Topic: C05.08 - Containment Liner (HDA C080-Containment Liner Attachments)
Representativeness of Reviewed Documents
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TERA scanned all fourteen calculations in the HDA: SRB-105C-1,1 (Containment Liner Anchors). SRB-110C,2 (Reactor Building Liner-Unit 2). SRB-113C,2 (Containment Liner Anchors and Vent Ducts Containment Liner Attachment). SRB-113C,3, (Reactor Building Containment-Checking Liner Plate &
Embedments Unit #1-ITT Pipe Hangers & Supports). SRB-113C,4 (Reactor Building Containment Pipe Supports on Liner Plates). SRB-113C,7 (Seismic Restraints Attached to Containment Liner). SRB-113C,8 (Attachments to Containment Liner, As Built). SRB-113C,9 (Reactor Building #1-Attachments to Containment Liner, As Built General Review).
9. SRB-113C,10 (Attachments to Lontainment Liner-Computer Analysis of Liner Plate).
10. SRB-113C,11 (Reactor Building #1-Attachments to Containment Liner-Details 4&6, As Built).
11. SRB-113C,12 (Reactor Building #1-Attachments to Containment Liner-Details 8 to 11, As Built).
12. SRB-116C,1 (Slab @ Elevation.783'-7" & Elevation 808'-0", Elevation 819'-6", Elevation 822'-9", Wall Between Elevation 783'-7" & Elevation 808'-8").
13. SRB-161C,5 (Pipe Support Attachment to Penetration Assembly).
14. SMI-108C,2 (Shielding of 4" Gap Around Transfer Tube in Reactor Building The team scanned the same calculation ~
As indicated under Review Topic C05.01, the calculations varied with respect to methodology. Team followup with respect to this matter will be addressed by Open Item C- Review cf Documents:
The team reviewed calculations reviewed by. TERA (SRB-113C,4; SRB-113C,9; SRB-113C,10; SRB-113C,8; and SRB-113C,11), the related review checklists,
'and fourteen DIRs resulting from TERA's review. The review checklists and attached supplementary documents indicated that key points in the calculations were reviewed. The DIRs accurately document discrepancies in the calculation The team found no additional discrepancie ,
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Review Topic: C05.04 - Platforms / Monorails
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Representativeness of Reviewed Documents:
The team did not review this are Review of Documents:
For HDA C084, Auxiliary Building Platforms, the team reviewed calculations reviewed by TERA (SSB-105C,1-Safeguard Building, Grating Platform; SRB-11C,5-Platform at Elevation 824'-4 1/2" & Elevation 841'-0"; and SAB-113C,3-Reactor Building Recirculating Sump Pump Platform), associated review checklists and 84 DIRs resulting from TERA's review. TERA's review checklists and attached supplementary documents indicated that the major areas of the calculations were reviewed, and the DIRs. accurately documented discrepancies in the calculation The team found no additional discrepancies. As indicated under Review Topic C05.01, the calculations varied with respect to methodology. Team followup with
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respect to this matter will be addressed by Open Item C- Review Topic: .C06.01 - Containment Mat Representativeness of Reviewed Documents:
The team did not review this are .
Review of Documents:
For HDA C087, Containment Mat Analysis and Design, the team reviewed calculations reviewed by TERA (SRB-1C,2-Reactor Building Finite Element Analysis; SRB-1C1,1-Reactor Building Mat Finite Element Analysis; and SRB-104C,1-Reactor Building Mat Reinforcement), related review checklists and attached supplementary documents and the thirteen DIRs resulting from TERA's review The review checklists indicated that required design
~
criteria were addressed and the DIRs correctly reflected discrepancies in the calculations. The team found no additional discrepancie Review Topic: C05.02 Pipe. Whip Restraints Representativeness of Reviewed Documents:
This topic is covered by HDA C074 ano consists of the structural qualification of the steel framing associated with the pipe whip restraints. The team scanned the following calculations for this HDA:
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SSB-128C set 4, Rev. 2 SRB-125C set 2 SRB-126C set 3 In addition, the team reviewed two calculations indicated below under " Review of Documents." The five calculations were performed in a comparable manne Pipe break loadings were applied to the restraining energy absorbing material which, in turn, was supported by a framing system. The framing system was idealized as a simplified beam element assembly which was analyzed for the applied load component Stress and foundation anchorage loads were compared to allowable The basic design criteria and methodology were consistent for
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all five calculations. They were of equal complexity and covered all essential elements of pipe whip restraint design. Therefore, TERA's selection for detailed review of the calculations indicated below was representative of the HD Review of Documents:
TERA's review of the Gibbs and Hill calculations was based upon a review checklist that addressed design input, methodology with respect to FSAR commitments, mathematical idealization with respect to the actual structure, and accepted engineering practice; independent calculations were developed by TERA where appropriat TERA's review of Pipe Whip Restraint RB-PWR-FWI-017-910-C57W (checklist DAP-CLC-CS-014, calculation # SRB-133C set 2) resulted in several DIRs. .The most important were D-0458, which addressed neglect of base plate prying and D-0457 which indicated that design loads were not referenced and assumptions were not stated and/or justified.
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TERA's review of Pipe Whip Restraint Calculation #SSB-119C Set 1, Rev. 1 (checklist DAP-CLC-CS-012), which encompasses restraints RB-PWR-FWI-13-904-557W, FWI-14-904-557W, PWI-15-904-S57W and FWI-16-904-S57W, indicated the following DIR issues: The calculations and drawings are not consistent with each other because the calculations weren't revised to reflect field changes (0-0463). The calculations did not envelop dimensional variations between the four restraints (D-0463). The calculations specify a 3/8 inch " seal" fillet weld which .is not a strength wel However, due to the behavior of the restraint under load, the 3/8 inch " seal" fillet weld is actually required to resist load; thus it must be justified as a strength weld (D-0464).
Questions 3.5, 3.6, 3.7, and 3.8 in the Pipe Whip Restraint checklist (DAP-C/S-5112), relating to the qualifications of the energy absorbing ability of material used in the restraint, are answered with the statement that " Mechanical will handle." The team will follow-up on these item Open Item C-7 Review Topic: C05.03' Jet Shields Representativeness of Reviewed Documents:
For HDA C075, Jet Shields, TERA reviewed the following six calculations associated with the AFW system:
SAB-134C set 2 SRB-1375 set 3 SRB-157C set 24
. SRB-157C set 26 SRB-157C set 5 l SSB-134C set 1
15
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i The team scanned these calculations and found the methodology for all to be the same. The calculational approach consisted of resolving pressure loading components due to the postulated pipe break into adjacent structural steel framing members. The framing members were idealized as a system of beam elements which was analyzed for the effects of the applied loa Stresses and anchorage loads were determined and compared to allowable FSAR commitments and associated criteria were uniformly implemented. Selection of calculations associated with the AFW system was consistent with the DAP 21 requirement for maximizing the vertical slice approach (the AFW system). In this case the above calculations are also representative of the HDA in compre-hensiveness and complexit Review of Documents:
The team reviewed several calculation sets reviewed by TER Calculation SAB-134C set 2 (Design Review Evaluation DAP-CLC-CS-044) encompasses the
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design of a pipe whip restraint which is integrated with a jet shield syste DIR D-0343 noted that several members (connection designs) were not addresse DIR D-0340 covered anchorage related discrepancies, namely: The concrete cone pullout shear capacity and base plate prying had not been addresse . Although FSAR section 3.6 B.2.3. 3 states that ASTM A 588 grade 50 material is to be used, ASTM A-36 was specified in the calculatio TERA's review of SRB-157C set 24 (Design Review Evaluation DAP-CLC-CS-018),
covering the design of jet shield JS-IA-28, addressed the appropriate design criteri DIRs were written, covering the follcwing concerns: D-0286 addressed the use of a buckling factor which is inconsistent with the specified type of.end connection (fixity vs. flexibility). A larger factor should be use Although, this error, discovered by TERA, will apparently not affect the adequacy of the structural member, it indicates a weakness in the design proces . D-0284 addressed the incorrect determination of maximum base plate momen An independent analysis showed that, based on use of the correct moment, the base plate was overstresse . D-0285 dealt with the omission of base plate flexibility and pry'ng actio The review checklists addressed appropriate attributes, e.g. acceptance criteria, dynamic load factors, jet force determination, design of structural sections and connections, and code requirements. Based on this and the fact that the team did not identify discrepancies in the Gibbs and Hill calculations that TERA did not identify, the team concluded that TERA's review had proper depth and was adequat Review Topic: C08.02 - Crane Supports Representativeness of Reviewed Documents:
Since the HDA (C101) covered by the review topic contains a single item (G&H calculation SRB 109C set 3, Rev. 5), the DAP-21 procedure for homogeneity validation and selection was not applicabl _ _ - _ _ _ _ _ _
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, .
, Review of Documents:
TERA's review of the Gibbs and Hill calculation (Design Review Evaluation DAP-CLC-CS-029, dated 5/13/86) addressed load definition and~ combinations, calculation approach, code requirements, and acceptance criteria. The team found that the review covered appropriate design criteria. Discrepancies were accurately documented in DIRs. The team agreed with the basis for the DIRs and, based on its independent review of SRB 109C, found no additional discre-pancies with the calculatio DIR D-0233 dealt with the omission of loads and load combinations, specifically the critical position of the trolley on the crane rail girder and uplift from the crane in combination with other loads. In addition, the selection of the controlling load combination was not justified. DIR D-0234 addressed failure to calculate the capacity of the concrete to resist pullout of anchors, the strength and stiffness of the embedded baseplate, and the slotting of holes to accommodate thermal and load deformatio DIR D-0235 noted that some dimensions
__ chosen for free bodies were unconservative when compared to drawing details, all loads and load directions were not considered in the design of some plate ele-ments and bolts, and the transfer of horizontal seismic loads to the support bracket was not addresse Review Topic: C08.03b- Equipment Supports- Electrical Equipmen Representativeness of Reviewed Documents:
For HDA C103, Equipment Supports / Electrical Equipment, TERA selected six calculations for review that are associated with the AFW system. The AFW selection was consistent with the DAP 21~ requirement to maximize the use of
.the AFW vertical slice. In this case, it also permitted interface with the electrical discipline with respect to their review of the electrical equipmen The team scanned the following three of these calculations:
SRB-119C-set 7 SRB-112C-set 1 SSB-1342-set 3 The calculations were performed with comparable methodology. Equipment vendor anchorage loads due to seismic and dead weight (determined by analysis or testing)
were applied to the model of the anchorage. The maximum anchor bolt loads were compared to allowables based on FSAR criteri The team judged that these cal-culations were typical of the HDA in complexity and comprehensivenes Review of Documents:
TERA reviewed the equipment vendor's anchorage load (moments and shears)
development, Gibbs and Hill's modeling of the anchorage for analysis, and maximum load development in anchor bolt Calculation SRB-119-C set 7 pertains to a Neoweld power supply which is anchored to a concrete sla DIR D-0261 identifies the failure to consider base plate prying action, eccentricity of the attachment to the expansion anchor in two directions, and underestimation of foundation momen+s. DIR D-0263 noted failure to correctly consider code requirements, namely:
_ - . . _ . . . .- - - __
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' Load interaction (flexure and axial load) for angles ir, the frame and attached to the base plate (AISC 1969). The value of the stiffness. constant, K, was incorrectly estimated (AISC 1969). A capacity reduction. factor of 2.0 was not used in the qualification of a single expansion anchor and the bolt edge distance requirements for plates were not followed (ACI 349).
TERA's review of SRS-112C set 1 and SSB-1342 set 3 uncovered comparable DIR issues with respect to not considering prying action and base plate flexibility, not basing anchor bolt capacity upon an assumed cone of failure, not considering interaction effects in anchor bolt design, and improper application of seismic loadin ,
The team agreed with the technical basis for each DIR and considers that TERA's
~
review covered the appropriate design criteria. The team's independent review of the calculations reviewed by TERA did not identify discrepancies not found by TER Review Topic: C08.16 Recirculation Sump Pump Screen Support-Representativeness of Reviewed Documents:
HDA C117, covered by the review topic, contains a single item (Gibbs and Hill calculation SRB-152C-set 1); therefore the DAP-21 procedure for homogeneity validation and document selection is not applicabl Review of Documents:
The above calculation represents the design of the structural framing of a vortex breaker in the reactor building recirculation sump. TERA identified DIRs D-0393 through 0395 which involved failure to consider the stodel amplification factor (1.5), unconservative joint fixity assumptions, and failure to consider moments at the knee of the assumed rigid fram Based on its independent review of SRB-152C-Set 1, the team agreed with the technical basis for the DIRs and~found that TERA's review covered the appropriate design criteri Review Topic: Third Party Review of Cable Tray and Conduit Supports
TERA used DAP-C/S-S131, Rev. 1, dated 6/30/86, " Cable Tray Supports Design Procedure Review" to review Ebasco and Impell design procedures. The team's review found that this document adequately addressed design process items associatsd with the cable tray external source issues as well as most important design process factors. However, the team considers that the list of attributes should be expanded to address: Controls for cable weight as they relate to maximum lo'ad capacit . Design group interface concerns associated with verifying the adequacy of structural walls, slabs, steel, embedded plates and surface mounted attachments. Reverification when appropriate, e.g. due to load revision l
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3.~ Ensuring t.at when hardware capacity reductions (e.g. due to testing)
are determined that all affected calculations are reevaluate Open Item C-8 The team reviewed draft engineering evaluation DAP-E-CS-109, Rev. O, dated June 17, 1986, "DAP-8 Review of Volume 1 - Book 7, Ebasco Cable Tray Hanger Load Application Location Studies (Rev. 1, 02/19/86)". DAP-E-CS-109 evaluated the studies (Volume 1 - Book 7) which support Ebasco proce'dures for locating vertical and horizontal-longitudinal loads on tier member TERA concluded that the calculations and other technical information presented are inadequate to support the Ebasco specification for vertical lord placement (a DIR was issued), but are adequate to support the specification for horizontal-longitudinal load placement. The team agreed with TERA's conclusion The team reviewed the draft engineering evaluation report entitled "1.25
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Multimode Response Multiplier (MRM)" (not yet assigned a number). TERA performed detailed response spectrum analyses for.two cable tray systems (designated model 1 and model 3) and both response spectrum and time history analyses for a third cable tray system (designated model 2). They compared these system estimates of support stresses to estimates of support stresses developed using the equivalent static analyt,is method for single support model The systems, models and inputs used in the TERA evaluations were the same as those used by Ebasco in their verification studie Response comparisons were made for cases where both the system and static analyses modeled the same anchorages (i.e. either fixed or flexible), and for cases where the' system analysis modeled a flexible anchorage and the static analysis modeled a fixed anchorage. This was for the purpose of assessing the impact of anchorage
assumption on the adequacy of the 1.25 MRM factor used in the static analysis method. TERA concluded that the 1.25 MRM is in general conservative for cable tray systems with equally spaced supports having similar stiffnesses, provided that the flexibility of the support anchorage is realistically modeled in the single support model and the 1.25 factor is not used to qualify cable tray clip For cases where the supports have different stiffnesses and/or th spacing is not even, the use of a 1.25 MRM has not been justifie The FSAR commits tu use the 10 percent method within Regulatory Guide 1.92 for combining modal responses, which provides absolute summation between closely spaced modes in combination with the square root of the sum of the squares (SRSS) method. However, in those cases where high response ratios were found using the 10 percent rule, TDOA's response spectrum analyses developed alternate (lower) estimates of the response ratios by only using SRSS summation of modal components. TERA stated that these response spectrum estimates based only on SRSS summation provide an indication of the results which might be obtained if time history analyses were performed. The latter are more indica-tive of actual response than response spectrum analyses. TERA apparently per-formed time history evaluations with model 2 to verify this assumption but did not provide the results in the evaluation report, nor to the team. TERA needs to provide justification for neglecting the summation effects of closely spaced modes as indicated abov Open Item C-9
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' To provide background for the review of the above TERA waluation reports, the team reviewed the following Ebasco reports:
Volume I - Book 7, " Cable Tray Hanger Load Application Locations Studies" Volume I - Book 9, "Model Nos.1,2&3, Multimode Response Multiplier-Summary Report 3-D Response Spectrum Analysis and Verification of a Multimode Response Multiplier Equal to 1.25" Volume I - Book 9 (Part 1), "Model Nos. 1&2, MRM-Studies" Volume I - Book 9 (Part~2), "Model Nos. 1&2, MRM-Studies" Volume I - Book 9 (Part 3), "Model Nos. 1&2, MRM-Studies" Volume I - Book 9 (Part 4), "Model Nos lA&lB, MRM-Studies"
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Volume I - Book 9 (Part 5), "MRM at the Stress Level Studies, Model 1" :
Volume I - Book 9 (Part 6), "MRM at the Stress Level Studies, Model 1A&2 Volume'I - Book 10, "Model No. 3, MRM Studies" PIPING AND SUPPORTS
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(1) Issue Identification:
DSAP IX states that the third party (TERA) is responsible for issue identification, review, evaluation, and tracking. Piping and Support Discipline Instruction DI-P-002, " Preparation of External Source Issue Summary", lists categories of public documents which aodress technical concerns and issues associated with the adequacy of the piping analysis and -
support design at CPSES. TERA reviewed the public documents to identify these issues and concerns. An Issue Report was written in accordance with Procedure DAP-2, " Documentation and Tracking of Issues and Discrepancies,"
on each issue / concern. A Discrepancy / Issue Resolution Report (DIR) was then generated for each Issue Report to track the status, classification and resolution of the issue The DIRs were sorted into approximately 40 primary issues, as listed in DI-P-00 Primary issue binders compile all of the DIRs associated with a primary issue. An External Source Issue Summary (ESIS) was issued for each primary issue. Its purpose was to develop in one document a comprehensive summary of. each primary issue to facilitate review of the issue resolution, and to ensure that all the associated components of the issue have been adequately addresse DAP-2, section 4.1.1 states that, if an issue has both technical and programmatic components, both will be documented on separate Issue Record The team found that programmatic Issue Records have not been developed concurrent with their related technical Issue Records. TERA plans to issue programmatic Issue Records at a later date, and apparently will combine similar programmatic issues into generic issues. The team will follow-u Open Item P-1 External source documents to be reviewed by TERA are described in DI-P-002 ,
as "public documents..... generated between May 17, 1978 and February 6, 1986 l (which) address technical concerns and issues associated with the adequacy of the piping analysis and support design at CPSES." This time limitation appears to be inconsistent with the requirement of Procedure DAP-2 that the identification of issues be an ongoing proces Open Item P-2
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TERA identified 297 external source documents in seven categories:
Atomic Safety Licensing Board (ASLB), Citizens Association for Sound Energy (CASE), Independent Assessment Program, Management Audit Corporation, Nuclear Regulatory Commission, Nuclear Regulatory Commission Transcript (NRCT) and Texas Utility Generating Company (TUGCO). As an initial step in assessing TERA's issue identification, the team determined whether pertinent external source documents, such as those listed below, had been identifie . ASLB Hearing Transcript of September 15, 198 . ASLB Memorandum and Order (Quality Assurance for Design), December 28, 198 . ASLB Memorandum and Order (Reconsideration Concerning Quality Assurance for Design), February 8, 198 . ASLB Memorandum and Order (Reopening Discovery; Misleading Statement),
December 18, 198 . CASE'S Answer to Applicants' Motion for Summary Disposition,Regarding Consideration of Cinching Down of U-Bolts, October 8, 1984.
-- ASLB Partial Initial Decision (Change in Materials Properties for A500 Steel), October 6, 198 . NRC letter " Staff Response to Applicants' Response to Partial Initial
, Decision Regarding A500 Steel", May 17, 198 . Applicants' Response to Partial Initial Decision Regarding A500 Steel, April 11, 198 . NRC Region IV letter requesting information~on Level B'and Level C allowables dated December 31, 198 . Oral Deposition of Jack Doyle of August 19, 198 . Transcript of March 23, 1985 NRC Meeting to Conduct Feedback with Messrs. Walsh and Doyle Regarding Concerns About the Comanche Peak Plan Documents 1 through 5, 10 aan 11 were identified by TERA as ASLB-12, ASLB-2, ASLB-3, ASLB-6, CASE-22, CASEL2. and NRCT-17, respectively, but documents 6 through 9 were not identifie Open Item P-3 The team reviewed ASLB-6, CASE-22, CASE-2, and ASLB-2 to determine if specific external source issues were identified in DIRs and related ESIS U-bolt cinching was identified as a primary issue in ESIS-E-P-011 (draft).
The primary issue binder contained ASLB-6 and DIR E-0791, documenting the single U-bolt cinching issue. However, the following Board concerns in ASLB-6 were not identified in the above TERA documents: "the extent to which the items tested by Applicants have been representative of the steels actually employed at the plant." (p.4) "the extent to which the configurations in tha plant are the same as those tested." (pp. 5-6)
Open Itera P-4 With respect to U-bolt cinching issues, there was no DIR for Mr. Doyle's concern (CASE-22, pp. 4-5) regarding the applicability to cinched U-bolt designs of the provisions of 10CFR34 (a)(2) and (a)(8), pertaining to PSAR requirements for unique designs, nor for issues in CASE-2, pp 195-21 Open Item P-5
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Mr. Doyle's concern (CASE-22, p.2) that the design of the U-bolts should l have been based on the manufacturer's allowable loads (i.e., Design By Load ;
Rating per NF-3260 of Subsection NF of the ASME Code) and not by a stress l analysis (i.e., Design By Analysis per NF-3260 of Subsection NF of the ASME Code) was incorrectly characterized in DIR E-0604, Rev. O. The DIR stated
"TUGC0 should not assume stress relaxation (due to yielding) occurs in U-bolts l since the manufacturer's established load limits restrict loading to 1/4 yield '
versus the 1/2 yield required for this phenomenon to occur." The issue was also incorrectly summarized in the draft ESIS-P-011 as: "the question was raised the U-bolt stress may be higher than the manufacturers allowable of 1/2 yield." ;
Open Item P-6 :
The ' team reviewed the primarykssue binder and associated draft ESIS-P-023 for the A36 and A307 steel primary issue, and'found that the Board issue (ASLB-2, p. 28) regarding the improper use of SA307 U-bolts in friction 4 type, cinched U-bolt connections was not identified in'a DIR or in the ESIS.
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Open Item P-7
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CASE-2, pp. 81-86, identified a design feature of a pipe support which was in noncompliance with Section IX of the ASME Code and Gibbs & Hill Specification No. 2323-MS-46A. TERA misinterpreted this issue to relate only to the acceptability of welding attachments over girth welds and l ~ incorrectly transferred the issue to the primary issue relating to local j stresse (ESIS-E-P-002)
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t Open Item P-8 The team's review of the draft ESIS-E-P-009 for the A500 Grade B Tube Steel i primary issue found'that it did not identify the Board issue that " Applicant t
has not demonstrated that welded supports using A500 steel have been designed with adequate safety margins." This issue was contained in ASLB Partial Initial Decision (Change in Material Properties for A500 Steel),
,
October 6,1983, which, as noted for Open Item P-3, was not among the external source documents reviewed by TERA. Apparently this is' sue was not identified during TERA's review of other external source document Open Item P-9
The team identified several cases where ASLB concerns did not result in DIRs. TERA stated that ASLB interpretations of issues will be included to the extent that it affects a basis for acceptance criteria in resolving the issu Addressing the ASLB interpretation of information previously presented
is a hearing issue, not a technical issue affecting the design. The team notes
- that DSAP IX, section 4.2.1 states that issue identification " involves the
identification of all applicable issues ....." The above distinction is not reflected in DSAP IX. The team considers that this apparent difference between DSAP IX and actual practice needs to be clarified. In addition, the
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above open items pertaining to Board concerns should be resolved in a manner consistent with this clarification.
j Open Item P-10 i
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- i (2) Issue Evaluation: ;
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For each ESIS there is a related engineering evaluation. Thirteen draft evaluations were available at the time of the team's review. The team
reviewed draft issue summaries ESIS-E-P-009 (A500 Grade B Tube Steel) and ESIS-E-P-002'(Local Stresses), and draft engineering evaluations DAP-E-P-009 (A500 Grade B Tube Steel), DAP-E-P-012 (Axial / Rotational Restraints) and DAP-E-P-013 (Gaps).
,
Engineering evaluation DAP-E-P-009, Section 4.0, Acceptance Criteria, stated that the resolution of the A500, Grade B Tube Steel primary issue required
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- the identification of the design yield strength for A500, Grade B Tube Steel defined in the ASME Code 1974 through winter 1974 Addenda edition and ASME
, Code Case N-71, as adopted by Gibbs & Hill Specificataion No 2323-MS-46A.
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It was stated that Code Case 164-9 (N-71) permitted the use of 42 Ksi for
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the design yield strength for A500 Grade B. Tube Steel, but the Gibbs and Hill specification adopted pcrtions of a later revision for this Code Case (N-71-10)
j which. reduced the yield strength to 36 ksi. The~ evaluation concluded that the
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~ yield strength to be used in the qualification of supports should have been 36 ksi in accordance with Code Case N-71-10. This conclusion is incorrect 3
because the portion of the Code Case which reduced the yield strength to 36 '
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ksi was not invoked by the specification. The team notes that use of the 36 ksi design yield strength.is consistent with an ASLB concern that the more ;
conservative value should be used in order to ensure safety, but the evaluation l
report did not reflect this specific aspec ,
, Open Item P-11
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DAP-E-P-012 (Axial / Rotational Restraints) did not provide the basis for concluding that SWEC Project Procedure CPPP-7 was adequate to address the l issu Open Item P-12 i
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For DAP-E-P-013, TERA's acceptance criteria for resolving issues concerning gaps in bearing type connections were based on ASME Code Subsection NF 1983 I
through summer 1985 Addenda, which relaxed the criteria for allowable gaps i when compared to the earlier ASME Code version originally committed to.
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However, TERA has not addressed gap related concerns raised by the interveners regarding unequal load sharing, change in stiffness and natural frequency of support, effect on piping analysis, etc. In resolving this open item, TERA should determine whether these concerns are covered by DIRs and the issue
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identification / tracking syste Open Item-P-13
{ (3) Criteria and Standards:
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The third party activity in this area involves the verification that licensing commitments which establish piping and support related design criteria are
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adequately addressed in procedures and other design document Procedure DAP-1,
, " Preparation and Review of Criteria Lists" provides a systematic method for
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ensuring that all licensing commitments are identified and documented. The team ~
previously reviewed the development of the piping and supports design criteria list DAP-CR-P-001 dated 10/25/85 (Reference IE Inspection Report Nos. 50-445/85-17 j
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and 50-446/85-14). The design criteria list was used to develop the procedure review checklist for piping and support design. The' team review of this check-list is further discussed in the following section.
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(4) Review of Project /SWEC Actions:
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The third party review of Project (SWEC) actions as described in the CPRT Program Plan DSAP IX consists of four areas:
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Procedure Review
- Small Bore Selection Review
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Analysis Review l; -
Construction /As-Built' Review'
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At the time of the inspection, the third party had not initiated its review of.small bore selection, analysis implementation, and construction /
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. as-built. However, in the procedure. review, the third party had completed its review of the SWEC piping analysis / support design procedures. The SWEC
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piping analysis / support design procedures are documented in Comanche Peak Project Procedure (CPPP)-7, " Design Criteria for Pipe Stress and Pipe
- Supports", and CPPP-6, " Pipe Stress / Support Requalification Procedure-Unit No. 1". The design criteria list (DAP-CR-P-001 dated 10/25/85) as dis- '
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- cussed above was used to develop the Piping Analysis / Support Design Pro-cedure Review Checklist (DAP-CLC-P-001). This checklist, which also included external source issues identified by the third party, provided a
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systematic method for performing a review to ensure that all licensing commitments and external source issues identified in the design criteria
! list are adequately addressed in the SWEC piping analysis / support design procedures (i.e. CPPP-6 and CPPP-7). This. detailed review provides,the basis for assuring the completeness and technical adequacy.of the procedures with respect to the engineering methods and calculational techniques to be used in piping analysis and support design.
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The team reviewed'the Piping Analysis / Support Design Procedure Review
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Checklist (DAP-CLC-P-001, Revision 1, dated 3/14/86) for consistency and
' completeness with respect to the design criteria list (DAP-CR-P-001,
- Revision 0, dated 10/25/85).
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In both documents, a criterion number is assigned to each item or issu The team randomly checked the description of items / issues corresponding to criteria and identified several cases where the criterion number for the item / issue in the design criteria list did not correspond to that for
,
the apparent same item / issue in the procedure review checklist ( numbers 206, 211, 212, 243, and 312). However, in general, the items in the design criteria list were consistent with the corresponding items in the procedure review checklist with respect to criteria numbers. Tnus, the
~
'
team concluded that the inconsistencies were isolated errors. TERA agreed'
i to correct the inconsistencies and to evaluate the reasons for their occurrence in order to ensure that checklists in general reflect all appropriate criteria from design criteria list Open Ittm P-14 The team found that anproximately one-half (144 of 32E) of the total number of criteria in the design criteria list were not listed in the procedure review checklist. Procedure DAP-4, " Preparation of Checklists" (Revision 3) allows
<
the checklist preparer to select fewer than 100 percent ~ of the applicable cri-t teria provided that the bases for such selection are documented as an attachment
to the design review summary form. At the time of the inspection, the bases P
- 24
,
i n.-, ~. - - - . , - - - - - - - - - - - - - - - - - , .=~,,w r---- - - ~ - - - - ,,_-.--,,--,-w-,--w-m-.en-r-,c-- - --
.,- ,w.ny- '
O for.all excluded design criteria were being prepared and documented by the checklist prepare Open Item P-15 The team reviewed the depth and level of detail provided by the checklist item For example, under the item / issue concerning Richmond insert design, there were seven attributes liste However', based on the team review of the discrepancy / issue reports (DIR's), there appears to be many more than seven technical concerns related to Richmond inserts. The transposition of the con-cerns identified in the DIR's into the seven attributes involved a grouping of the external source issues into general categories appearently related to the resolutions of the special technical issue as described in the SWEC report.*
This grouping focuses on SWEC's resolution actions, but omits consideration of many of the sub-issues raised by the intervenor and the ASLB within each tech-nical area. The third party needs to provide a method for ensuring that these sub-Issues are addressed. See the above section on " Issue Identification" for -
related concerns.
_
Open Item P-16 TERA reviewed SVEC design criteria based on Revision 1 to CPPP- The team did not review the technical adequacy of TERA's review because Revision 2 to CPPP-7 consisted of many significant additions and modifications to the design criteri Although a draft of the third party in process comments to CPPP-7 Revision 2 was available for team review, the comments did not appear to represent a detailed review. TERA's checklist for Revision 2 was not complet The team will review the technical adequacy of the third party review of CPPP-7 Revision 2 when complete Open Item P-17 (5) Unidentified Issues:
DSAP IX states that "(the third party) review effort will provide reasonable assurance that all identified issues-are resolved.and currently unidentified issues are detected and resolved" (emphasis added). IE Inspection Reports 50-445/85-17 and 50-446/85-14, Appendix 8, NRC Comment #8,. documents that TERA stated that its identication of technical concerns which have not yet been identified would occur as a result of the following program process: continued review of external source documents, internal review of project criteria and documents that interface with the SWEC requalification effort, internal review of the SWEC requalification implementation effort, and review of the resolution of currently identified issues which may lead to identification of related concerns previously unidentifie The IE inspection report had found TERA's response to adequately address the team's concern related to detection of currently unidentified issues for piping and pipe support During the current inspection, the team conducted a follow-up
- " Generic Technical Issues Report," by Stone & Webster Engineering Corporation dated 6/27/8 . _ . . _ _ _ _ _ __ _ - _ _ _ __ -
.
.
in order to understand how the process, when implemented, would detect unidenti-fied issues within the piping and supports design discipline and those'which could extend into other design discipline The third party review process, in conjunction with the Project (SWEC) piping and support requalification program, provides reasonable assurance that there is the capability to detect and resolve currently unidentified issues within the piping and supports design discipline. Our conclusion is based on 1)
the scope of the SWEC piping and support requalification program covering all ASME Class 2 and 3 large bore piping systems and all ASME Class 1, 2, and 3 large bore pipe supports, and 2) the scope of the third party review of interface information and the SWEC program implementation. Interface information provided by SWEC to TERA (DAP-RTL), as described in Appendix F (page 22) of the CPRT Program Plan (Revision 3), includes design-related con-cerns found during SWEC document reviews. .These document reviews apparently pertain to the broad category including the SWEC piping reanalysis, support redesign, and physical hardware modifications made to existing piping and
., support designs. TERA's ability to evaluate such SWEC-identified concerns for applicability to other disciplines (covered by DSAPs VIII, X, and XI) is based on its procedures DAP-2 (which causes such concerns to be documented as DIRs) and DAP-7 (which causes the DIRs to be reviewed for trends and generic implications). ELECTRICAL
.
Review Topic: E03-Electrical Characteristics Representativeness of Reviewed Documents:
The following HDAs have been reviewed under this topic at the time of this inspection:
,
HDA . Title E038 Transients / Accidents - Startup E039 Transients / Accidents - Shutdown E073 Calculations / Analysis - Load Flow / Voltage Regulation E074 Calculations / Analysis - Offsite Voltage Swings E077 Calculations / Analysis - Short Circuit E079 D/G Grounding - System Design E081 One Line Diagrams - 6.9 kV E082 One Line Diagrams - 480 V
-
E085 Calculations / Analysis - Terminal Voltage TERA reviewed 100% of the population of the documents in these HDAs; therefore DAP-21 requirements for homogeneity validation and review sample selection were not applicabl Review of Documents:
TERA reviewed Gibbs and Hill calculations, one line diagrams and electrical distribution equipment specifications at the 6.9kV, 480V and 120V levels using the following design review evaluation checklists:
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_ _ _ _ , _ - - . - _ - - . - _ . - -- - _
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DAP-CLC-E-001 Voltage Profiles DAP-CLC-E-002 Short Circuit Currents DAP-CLC-E-003 Terminal Voltage DAP-CLC-E-005 D/G Grounding System Design DAP-CLC-E-001-GC1 6.9kV and 480V Load Study DAP-CLC-E-002-GC1 6.9kV Bus Short Circuit DAP-CLC-E-003-GC1 480 V MCC Starter Coil Pickup Voltage DAP-CLC-E-003-GC2 480/120 VAC, 125VDC Voltage Drop The team reviewed the above checklists (except for DAP-CLC-E-005) and the 35 DIRs and 7 TERA alternate calculations associated with TERA's reviews. The team's review sample covered 3 of the 4 TERA reviewers in this area. The team also reviewed the following Gibbs and Hill documents which had been reviewed by TERA and were referenced in the Type C checklists:
Drawing El-0001 Re Plant One Line Diagram Calculation VII-8 Re .9kV/480V 1E Bus Voltage
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Calculation 1V-3 Re .9kV Bus Short Circuit Calculation -1X-3 Re D C Switchboard Short Circuit Calculation X111-4 Re D C Coordination Study The team found that the depth of review, as demonstrated by the detail of the questions / comments'in the~ checklists, was sufficient to detect design errors. The checklists had detailed comments identifying exactly what was reviewe The voltage profile checklist (DAP-CLC-E-001) did not question the verification of a Gibbs and Hill in-house computer program, Voltage Program 1979, which was written for a programmable calculator. It is the team's understanding that TERA plans to address verification of computer programs on a generic leve The team will follow-up to ensure that the generic action addresses this computer progra Open Item E-1 The team questioned whether TERA would review (1) the ability of the spent fuel
.
pool ~ cooling pump motor to operate at voltages below its rated voltage, and (2)
the adequacy of the voltage at the switchgear close and trip coils. TERA stated that these items will be included in the component functional review topic and
- the cable sizing subtopic of E03, respectively. The team will follow-up on these item Open Item E-2 Review Topic
- E04 - Electrical Load Capacity Representativeness of Reviewed Documents:
For the 23 HDAs covered by this review topic, the team reviewed the following:
HDA Title E011 Component Selection / Sizing - Battery E012 Component Selection / Sizing - Inverter E013 Component Selection / Sizing - Battery Charger E037 Transient / Accidents - Station Blackout
t
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E041 Transient / Accidents - LOCA E083 One-Line Diagrams - 118 VAC E084 One-Line Diagrams - 125 VDC For the above seven HDAs, TERA reviewed 100% of the documents, and therefore the DAP-21 requirements for homogeneity confirmation and review sample selection were not applicable. The team's rationale for selecting the above seven HDAs was based on reviewing three of 13 component selection HDAs, two of six transient /
accident HDAs, and two of four one-line diagram HDAs. HDAs selected were con-sidered to be representative of work under the review topic with respect to complexit Review of Documents:
TERA reviewed Gibbs and Hill calculations, drawings, specifications, Westinghouse specifications, industry standards and regulatory guides using-the following Type C checklists:
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DAP-E-005 Diesel Generators and Transformers DAP-E-006 Inverters DAP-E-007 Batteries / Chargers DAP-E-006-GC1 UPS System Sizing DAP-E-006-GC2 UPS System Sizing - TMI DAP-E-007-GC1 Battery and Battery Charger Calculations Except for DAP-E-005, the team reviewed the above checklists,.the 30 DIRs resulting from the checklists, and the following Gibbs and Hill and Westinghouse documents relative to the class 1E batteries, battery chargers and inverter Document / Number Title Drawing El- 0018 Rev. CP8 118 VAC One Line Diagram Drawing El- 0020 125 VDC One Line Diagram Calculation 1-1X-1 Re Unit 1125V Class 1E Battery Calculation X111-2 Charger Calculation for TMI Loads Calculation V-7 Re SUPS System Sizing Specification ES8A Class 1E Batteries and Accessories Specification G676573 Re NSSS Inverter E - Spec The team reviewed the work of 2 of the 3 TERA reviewers in this area; the work of the remaining reviewer had been sampled in topic E03. The checklists indi-cated, in detail, the scope of review. The team found that this included key pertinent design criteria. The DIRs accurately reflected discrepancies in the document Review Topic: E05 - Load Sequencing, Shedding Representativeness of Reviewed Documents This review topic is comprised of the below HDAs, for which 100% of the docu-ments were reviewed by TER ,. . _ . . _ . - .
_ ._
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HDA Title l E015 Component Selection / Sizing / Specification-Sequencer l E032 Transient Analysis - Loss of Bus Voltage (6.9kV and 480V) l E036 Transient Analysis - Loss of Offsite Power E041 Transient Analysis - LOCA E081 One Line Diagram - 6. 9 kV E082 One Line Diagram - 480V These HDAs, except for E015 and E032, interface with one or more of the !
'following topics; E01, E02, E03, E04, or E0 Review of Documents-l TERA reviewed Gibbs and Hill one line diagrams, schematics, connection diagrams and the specification for the solid state safeguards sequencer using the following Type'C checklists:
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DAP-E-008 Load Shedding and Sequencing DAP-E-009 Load Transfers TERA issued three DIRs; two additional DIRs were in draft form. The team reviewed the above checklists and the three issued DIRs (all the work of one ;
reviewer), and the following related documents: l Document / Number Title FSAR Table 8.3-1A Diesel Generator Loading with LOCA-Injection Phase FSAR Table 8.3-1B Diesel Generator Loading with LOCA-Recirculation Phase FSAR Figure 8.3-3 Diesel Generator Auto Start and Sequencing FSAR Figure 8.3-6 6.9kV Safeguard Buses FSAR Figure 8.3-8 480V Safeguard Buses
.
Drawing El-0030- Sheet 21 Re Bus 1EA1 UV Relay Drawing El-0031 Sheet 29 Rev.CP1,CP2 CBS pump 11 schematic Drawing El-0031 Sheet 37 Rev.CP3 AFW Pump 11 schematic Drawing El-0031 Sheet 38 Rev.CP2 AFW Pump 11 Switch Development Drawing El-0033 Sheet 15 Rev.CP1 Containment Recirc Fan Schematic Drawing El-0038 Sheet 50 Rev.CP1 Auxiliary Relay PX/2111A Development For checklist DAP-E-008, the " Comments" column stated that what was described in the" Description of Verification" column had been verified by the TERA reviewe The team questioned the accuracy of this verification because of errors in the references in the " Description of Verification" column that had not been identi-fled during the TERA revie In addition, the checklist listed specific values for the undervoltage relay setpoints and the timing relay setpoints. TERA stated that the review only confirmed the existence of the contacts and that verification of the acceptability of the actual values would be performed in topic E07; however, this distinction was not clear from the review checklis TERA stated that the checklists in this topic were the initial effort in this discipline's review and would be revised to clarify the depth of revie Checklists for other topics were more detaile Open Item E-3
- - _ . - - - - ._- __ - _ - _ - - - -- ___
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The team questioned the timing for the application of load onto the diesel generato This review topic addressed the existence of the safety injection sequencer and blackout sequencer contacts in the equipment schematic, not the actual timing sequence of loads. The team observed, from its review of the same Gibbs and Hill documents used by TERA, that it appeared the contacts from the timing relays would close at'a predetermined time and stay closed until the end of the secuencin Other Westinghouse plants have sequencers with 5 second windows to prevent loads from coming on out of sequenc The. team looked at the schematic for the containment' spray pump motor, the most likely candidate to come on out of sequence, and found that the Comanche Peak design incorporated two separate engineering safety feature actuation relay contacts in the pump starting circuit, one for a safety injection signal and one for a containment spray signal. The team inferred that the safety injection contact was included to ensure that the motor would be ready for a start signal whe_n the correct timing sequence contact closed.
_ As indicated in Table 7.3-1 of the FSAR, not all safety injection initiations should result in containment spray initiation. The team asked TERA if they had looked at the schematic for the containment spray isolation valves to ensure that they would not automatically open on safety injection. TERA stated that, based on the Westinghouse functional diagram, the valves would open on containment spray (not on safety injection), but they would verify this against the Gibbs and Hill schemati Open Item E-4 Review Topic: Ell - Multidiscipline Considerations Representativeness of Reviewed Documents Aboat 30% of the HDAs in this topic were reviewed by the team as indicated below:
HDA Title
.
E063 Fire Protection - System Interactions E064 Environmental Qualification - Identification of Components E066 Environmental Qualification - Equipment Operating Time Requirements E067 E069 Environmental Qualification - Qualification Evaluation Criteria Environmental Qualification - Documentation Requirements E070 Environmental Qualification - Demonstration of Qualification Adequacy The remaining HDAs, including fire protection (50%), protective device settings (10%) and flooding and missile protection (10%) were not available for the team's review. The team will assess these areas as part of its corrective action follow-up. Additional areas which were not available for the team's review and are to be addressed in this manner include topics E08, component functional requirements; E09, single failure /FMEA; E12, equipment installation design; and E13, emergency lightin Open Item E-5 i
. - _ _ _ _ , .- -. -- -- --
- - -
, .. . . . -.
-. *
The TERA environmental qualification (Eq) review covered eighteen EQ
packages representative of different electrical, control and instrumentation-equipment and component The TERA review of HDA E063 was their initial review into a complex fire protection area, and represents only a small fraction of work to be performed in'the fire protection revie Review of Documents:
I The team reviewed the qualification package for the Conax penetrations,
, the associated checklist (DAP-E-034-7), and the 3 DIRs referenced in that checklist. The team could not determine from the checklist what documentation the TERA review was based upon. For example, the checklist stated that the penetrations were located above the accident flood level, but did not reference drawings or calculations which verified that statement. The team identified an inconsistency between the TUGC0 summary
, evaluation sheet regarding thermal cycle testing in accordance with IEEE 317-76 and the actual test documentation,.but confirmed that the actual test
--
documentation was correct. This inconsistency was not noted on the TERA review checklis Open Item E-6 The team was informed that the EQ review was cut short due to the number of
} DIRs (16) and generic issues that were identified and the project's decision to undertake a major EQ rework / upgrade program.
!
-The team reviewed Checklist DAP-E-036, (Fire Protection Systems Interaction)
i for HDA E063, a relatively small part of the fire protection review i
concentrating on the effect of the deluge system on surrounding component The checklist indicated that pertinent design criteria were addressed by
- TERA in adequate dept Three DIRs were~ issued; the team agreed with their technical basis.
+
5. INSTRUMENTATION AND CONTROL l Review Tcpic: E06, Control, Auxiliary Feedwater System Representativeness of Reviewed Documents:
t TERA scanned the five Gibbs and Hill instrument control diagrams listed below
,
for the homogeneity validation of control logic design activities (HDA 1001.0A),
j and concluded that the diagrams had common design methodology. The team inde-i pendently scanned each of these same diagrams, and agreed.with the TERA
- homogeneity. conclusion. TERA chose the auxiliary feedwater (AFW) system
>
instrument control diagram for detailed review, and the team concurred that this i
selection was representative of other Gibbs and Hill instrument control diagrams l in the HDA in terms of its complexity and comprehensiveness. Choice of the AFW e
system was consistent with the DAP-21 requirement to maximize the use of the j vertical-slice approach.
'
HDA Items Scanned 1001.0A G&H. Drawing M1-2206-01 through -11, AFW ICD G&H Drawing M1-2215-01 through -02, D/G Aux. Sys. ICD G&H Drawing M1-2233-02 through -09, SSW System ICD G&H Drawing M1-2232-01 and -07, Containment Spray ICD
- G&H Drawing M1-2311-02 and -03, Ventilation SCW ICD l
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l
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- -
. , ~ , . m _m-,.,- y y - ~ u _ - , , . . - . , . _ _,,,,-,.-.m,mo,.--,,m,--,,,.-,- . - - - . - - - -
-
, .
.
. Review of Documents:
TERA reviewed the AFW instrument control diagram, and a number of related AFW electrical schematic diagrams. The team reviewed a majority of these drawings and the following TERA documents related to its review:
(a) E06 design criteria, Rev. 0 (12/18/85) and Rev. 1 (6/2/86).
(b) AFW control checklist DAP-CL-I-001, Rev.1, 7/7/8 (c) Twenty seven discrepancy issue reports (DIRs).
,
The AFW control checklist and the large number of Gibbs and Hill drawing discrepancies identified by TERA demonstrated that TERA had conducted an in-depth review and addressed the important design criteria, except as noted belo Based on the attributes in DAP-CL-I-001, TERA reviewed 1) automatic initiation circuits for the AFW pumps and 2) the pump suction low pressure switch circuits
--
that automatically stop the pumps. However, this checklist did not have an attribute to confirm a prompt automatic restart of the pumps after they have been stoppe Using AFW schematic diagrams, the team cor. firmed that the Gibbs and Hill design does not require operator intervention for the restoration of AFW flow; as soon as the low pressure condition clears, the pumps will auto-matically restart. TERA stated that no FSAR criteria addresses restart, but, to confirm the restart function of the AFW pumps, the DAP will include this as ,
an additional area of review in Review Topic E0 TERA identified 47 E06 design criteria on their checklist. Four E06 design criteria, numbers 49 (control switchboards), 100 (ECCS testing), 151 (AC power source independence), and 154 (AFW testing during operation) were applicable to this system but were not identified on the checklist. The team's review of other criteria ir the checklist indicated that the technical aspects of criteria 151 and 154 had been addressed. Eight other applicable design criteria (numbers 180 through 186 and 189) that were added to the topic E06 design criteria document prior to issue of Revision 1 of the checklist were not included in Revision 1 of the checklist, and no tracking mechanism was evident to assure they would be considere Open Item 1- Review Topic: E06, Control, Standby AC System Representativeness of Reviewed Documents:
TERA scanned the Gibbs and Hill instrument control diagram, schematic diagrams, and one line diagrams listed below for the homogeneity validation of HDA 1001.08, and concluded that the Gibbs and Hill control logic design activities for the HDA had been homogeneous relative to design criteria and methodology. The team
. independently scanned these drawings and agreed with the TERA conclusion. TERA chose the diesel generator auxiliary system instrument control diagram for detailed review, and the team concurred that this selection was representative of other Gibbs and Hill instrument and control diagrams in the HDA, in terms of its complexity and comprehensivenes . _ . _ _ - - _ . . _ .
- - _ - , - _ _
.
.
HDA Items Scanned
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I001.0B G&H Drawing M1-2215-01 through -02, D/G Aux. Sys. ICD G&H Drawing El-0022, D/G Trip Protection Schematic G&H Drawing El-0030, 6.9kV Switchgear Schematic G&H Drawing El-0031, 6.9kV Switchgear Breaker Schematic-G&H Drawing El-0067, D/G Fuel Oil Transfer Schematic-G&H Drawing El-0002, Main.One Line Meter and Relay Diagram G&H Drawing El-0020, 125V DC One Line Diagram G&H Drawing El-0018, 118V AC One Line Diagram Review of Documents:
TERA reviewed the diesel generator auxiliary system instrument control diagram and used a number of electrical schematics and one line diagrams-to augment their review process. The team reviewed the same instrument control diagram, most of the other documentation used by TERA, and the following
-
TERA documents related to its review:
(a) E06 design criteria, Rev. 0 (12/18/85) and Rev. 1 (6/2/86).
(b) Standby AC control checklist DAP-CL-I-002, Rev. O, 7/3/8 (c) Approximately 10 DIR The standby AC control checklist demonstrated that TERA addressed the key design. criteria, except as noted below. The checklist and the DIRs indicated that the review had adequate dept DAP-CL-I-002 did not contain a number of applicable E06 design criteria:
numbers 15 (6.9kV control power), 31 (D/G capability without offsite power),
' 32 (IEEE 387 considerations), 40 (Regulatory Guide 1.9 criteria),107 (bypass for test during operation), 110 (setpoints), 111 (setpoint span versus range), 121 (periodic testing and surveillance), and 131 (D/G protective trip surveillance). TERA confirmed that criterion 15 will be in topic E04 ' checklists and criteria 121 and 131 in topic E07 checklist Design criteria 15,110, and 111 had been recently deleted from Revision 1 l of the topic E06 design criteria document. -The team could not determine the technical basis for these deletions. In addition, recent additions to the -
design critaria list (numbers 160 through 162) were not included in DAP-CL-I-002, and no tracking mechanism was evident to assure they would be addresse :
Open Item I-2 l Review Topic: E07, Instrumentation, AFW Class 1E 480 Vac HOV Representativeness of Reviewed Documents:
TERA scanned the five Gibbs and Hill instrument control diagrams listed below for the homogeneity validation of HDA 1010.0A (G&H) and HDA 1010.1A (TNE).
The same five documents were included in G&H and THE HDAs because they were originally G&H documents and were transferred to TNE for revisions. TERA con-cluded that both HDAs had common design methodology for motor operated valve alarms. The team scanned these control diagrams, and agreed with the TERA conclusion for the Gibbs and Hill HDA. For the TNE HDA, the documents scanned
, 33
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provided insufficielt examples of TNE design work for the team to reach a con-clusion. The team considers that TERA should scan other documents in the HDA I reflecting TNE design work.
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Open Item I-3
, For HDA 1010.0A (G&H), TERA selected the AFW instrument control diagram for
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detailed review of motor operated valve overload alarms. This selection was representative of other Gibbs and Hill instrument control diagrams in the HDA in its complexity and comprehensiveness. -Selection of the AFW example
, was consistent with the DAP-21 requirement to maximize use of the " vertical
!
slice" (AFW).
HDA Items Scanned 1010.0A G&H Drawing M1-2206-01 through~-11, AFW ICD,-and
, 'and G&H Drawing M1-2215-01 through -02, D/G Aux. Sys. ICD 1010.1A G&H Drawing M1-2233-02 through -09, SSW System ICD L_., G&H Drawing M1-2232-01 and -07, Containment Spray ICD G&H Drawing M1-2311-02 and -03, Ventilation SCW ICD (Both HDAs have the same drawings; as noted above.)
Review of Documents:
TERA reviewed the AFW instrument control diagram and other schematic
control diagram, . checklist DAP-CL-I-Oll, Rev.1 dated 6/27/86, and related DIRs. This' checklist addressed the existence of main control room alarms
for thermal overloads involving 480 volt Class 1E motor operated valves in i accordance with design criterion 13 of the E07 design criteria list. TERA j was in the process of consolidating a number of E07 topics to provide an improved scope of technical review. In particular, TERA stated that the sub-
'
ject of thermal overload bypasses in accordance with Regulatory Guide 1.106 was not intended for the DAP-CL-I-011 checklist, but that such bypasses would be evaluated by a separate checklist currently under development. The team
, will follow-up.
- Open Item I-4 Review Topic
- E07, Instrumentation, AFW System Alarms
'Representativeness of Reviewed Documents:
TERA scanned Gibbs and Hill AFW flow diagram M1-0206 and the five Gibbs and Hill instrument control diagrams listed for the above review topic (HDAs IO10.0A and.IO10.1A). In this case, TERA's focus was on instrumentation j design activities for system alarms, as opposed to design activities for 1 motor operated valve alarms for the previous topic. The team scanned these documents, and found there was insufficient information in the drawings to
). reach a conclusion on TNE design activities, as had been the case for motor i
operated valve alarms (see Open Item I-3).
,
i TERA selected the AFW instrument control diagram for detailed review of i system alarms. This was the same selection as for the previous topic (motor i
operated valve alarms),-and the team's agreement with the selection applies equally.
,
-
\
- -a
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W
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Review of Documents:
TERA reviewed system alarm aspects of the AFW instrument control diagram, the AFW flow diagram and related schematic disgrams. The team reviewed the AFW instrument control diagram, checklist DAP-CL-I-014, Rev. O dated 7/3/86 and related DIRs. This checklist addressed AFW system alarms in the main control room in accordance with design criteria 62 and 68 from the review topic E07 design criteria list. The team concluded that TERA addre'ssed appropriate design criteria in adequate dept Review Topic: E07, Instrumentation, Generic Setpoints and Accuracy Representativeness of Reviewed Documents:
'
NRC inspection report 50-445/85-17, 50-446/85-14 dated January 21, 1986, page A-14 lists 12 Gibbs and Hill setpoint. calculations to be reviewed by TER TERA scanned these setpoint calculations to validate HDA 1004.0,
-
and concluded that the Gibbs and Hill setpoint calculation design activities had been homogeneous with respect to design methodolog The team scanned seven of.these calculations, and agreed with TERA's conclusion. The team also concluded that these seven calculations are representative of other Gibbs and Hill setpoint calculations in terms of complexity and comprehensivenes The overall 12 calculation review sample provides an adequate number of calculations and mix of system Review of Documents:
TERA's review of 12 setpoint calculations was augmented by an examination of instrument data sheets from the following Gibbs and Hill instrument procurement specifications:
(a) G&H Specification MS-611A, Pressure and DP Transmitters, Rev. 2, 7/6/8 (b) G&H Specification MS-6118, Analog Control Systems for Balance of Plant, Rev. 1, 11/10/7 (c) G&H Specification MS-615, Pressure Switches, Rev. 1, 3/28/7 (d) G&H Specification MS-616, DP Indicating Switches, Rev. 1, 8/25/7 (e) G&H Specification MS-618, Flow Indicators, (Rotameters),.Rev. 1, 8/26/7 The team reviewed seven of the 12 setpoint calculations and the instrument data sheets reviewed by TERA, checklists DAP-CL-I-016 and DAP-CL-I-023 through DAP-CL-I-033, and 15 of the related DIRs. Except as noted below, the TERA documents indicated that appropriate design criteria had been addressed and a large number of discrepancies, having adequate technical basis, were identifie Setpoint calculations for turbine driven AFW pump suction pressure switches (PS-2470 A and B) and motor driven AFW pump suction pressure transmitters (PT-2475 A and B) took into account only static effects and did not consider the dynamic effect of pump suction flow on the instruments. Operating experi-ence at other PWR plants has demonstrated that the transient effect of piping pressure drops in the suction line when motor driven and turbine driven auxiliary feedwater pumps are started can have a significant effect on allowable setpoint values for the pump suction pressure switches and pressure transmitter .. . _ . . .. . . . - - . . .
_ . . . .. _ _ _ _ _ _ _. _ . _ _ .
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TERA did not specifically identify this modeling omission in their checklist or
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in the related DIRs. It is noted that the motor driven pump calculation was
,not in TERA's review sample, but the team reviewed it for comparison purpose Open' Item I-5
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Review Topic: E08, Component Functional Requirements, Transmitters Representativeness of Reviewed Documents:
TERA scanned the five Gibbs and Hill instrument procurement specifications
'
listed below for the homogeneity validation of HDA 1016.0, and concluded that the specifications had equivalent design criteria, considerations, approach,
,
and methodolog The team independently scanned these specifications, and agreed with TERA's conclusion. TERA reviewed the MS-611A specification in
detail, and the team concurred that this selection was representative of other Gibbs and Hill instrument procurement specifications in the HDA in complexity
{ and comprehensiveness.
,
HDA Items Scanned
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101 G&H Specification MS-611A, Pressure and DP Transmitters,
Rev. 2, 7/6/8 ~
I G&H Specification MS-611B, Analog Control Systems for Balance
!
of Plant, Rev. 1, 11/10/76.
- G&H Specification MS-615, Pressure Switches, Rev. 1, 3/28/7 G&H Specification MS-616, DP Indicating Switches, Rev. 1, 8/25/76.
G&H Specification MS-618, Flow Indicators, (Rotameters), Rev. 1, 8/26/7 .
Review of Documents:
TERA reviewed instrument data sheets contained in Specification MS-611A to assess whether they included functional requirements applicable to transmitter components. The team reviewed approximately six of these instrument data sheets, related drawings supplied by one transmitter vendor, design criteria list
DAP-CR-EIC-009 Rev. 1 dated 5/21/86, checklist DAP-CL-I-019 Rev. O dated 7/2/86,
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and six DIRs. These documents indicated that appropriate design criteria were addressed in adequate depth and the DIRs had adequate technical base ,
With respect to AFW flow transmitters, the TERA checklist had marked the-instru-i ment response time attribute as "not applicable" because there was no specific
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FSAR -requirement. These AFW flow transmitters (FT- 2456 and FT-2457) are used
' to control opening and closing of minimum flow bypass line valves; a safety-related function for these transmitters is to assure delivery of full AFW flow
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to the steam generators by isolating the bypass line. TERA stated that, except for critical instruments, standard industry procurement practices do not specify
'. response time, but rely on nominal (less than one second) response time of good quality transmitters. The class 1E Rosemount transmitters used to detect AFW flow are typical of this group. Also, the system response time (establish flow j in 60 seconds) for actuation of the AFW pumps was reviewed in the AFW control
- checklis The team had no further questions.
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The team noted a minor and conservative discrepancy on Rosemount drawing H34773-1104 Rev. D dated 3/3/79. The AFW flow transmitters for CPSES Unit 1 had been specified as Safety Class 2 while the Gibbs and Hill instrument data sheet specified Safety Class Review Topic: E08, Component Functional Requirements, Relays Representativeness of Reviewed Documents:
A TERA scanned five Gibbs and Hill equipment procurement specifications... involving relay components for homogeneity validation of HDA 1014.0, as listed belo For HDA 1014.1 (TNE), there was only one document, so the DAP-21 riquirements for homogeneity validation and selection were not applicable. TERA chose the Gibbs and Hill ES-18 specification for detailed review. The team did'not scan the five Gibbs and Hill specifications, and therefore reached no conclusions with respect to the representativeness of ES-1 '
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HDA Items Scanned '
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101 G&H Specification ES-18, Protective Relay Boards and ,
Racks, Rev. 1, 7/28/76 and Addendum 1, 3/29/7 .
(G&H) ' '
G&H Specification MS-611B, Analog Control Systems for Balance of Plant, Rev. 1, 11/10/7 '
G&H Specification MS-605, Control Room Panel G&H Specification MS-34, Diesel Generato G&H Specification ES-22, Solid State Sequence .1 THE Specification TNES-011G, Rev. 1, 3/26/8 (TNE) '
Review of Documents:
TERA reviewed the Gibbs and Hill ES-18 relay panel procurement specification for HDA 1014.0 and the TNE TNES-011G relay procurement specification for HDA 1014.1. The team reviewed these specifications and checklist DAP-CL-I-041 Rev. O dated 7/3/86. TERA's review of the Gibbs and Hill specification addressed appropriate design criteria. The depth of TERA's technical review was limited because the HDA focused on Gibbs and Hill design activities, but Gibbs and Hill delegated to its vendors the responsibility for most of the technical details regarding relay functional requirement Review Topic: E10, Support Systems, Auxiliary Feedwater Representativeness of Reviewed Documents:
NRC inspection report 50-445/85-17, 50-446/85-14, pages A-42 and A-43, indicates that six AFW support systems were included in the DAP. On pages 25 through 27 of DSAP XI Revision 1, the specific systems and scope of review were identified as:
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AFW Support Systems Scope of Review (a) ESF ventilation Redundancy, independence, power supplies, interlocks, instrumentation and control, and i
bypass status indication.
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( Safety chilled water Instrument ratings, power supply, and bypass
[ status indicatio , (c) Component cooling water
. Power supplies, train A and B low pressure
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interlock single failure compliance and response time, and bypass status indicatio (d) Station service water Power supplies, instrument ratings, CCW pump interlock, and bypass status indicatio (e) SSW intake structure Power supplies and bypass status ventilation indicatio .
(f) Stationfair syste Regulatory Guide 1.97 indicatio DAP-CL-I-017, the AFW support system checklist, addressed the ESF ventilation system, but not the other AFW support systems committed to be reviewed by the DA Open Item I-6 Review of Documents:
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TERA reviewed'the following Gibbs and Hill drawings, which were also examined by the team:
M1-0302, Safeguards and Elec. Area Flow Diagra M1-0303, Fuel Handling Building Ventilation Flow Diagra M1-2302, Safeguards and Elec. Area Instrument Control Diagra El-0036s Aux. Bldg. Ventilation Exhaust Fan Schematic Diagra *
El-0079,: Annunciator Lamp Cabinet Window Engravin El-0172, Termination Rack ECPRTC-01 Interconnection Diagram.
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El-0174, Ventilation Vertical Panel Interconnection Diagra In addition, the,tearr, reviewed support systems design criteria list DAP-CR-EIC-011' Rev.1 dated 6/2/85, checklist DAP-CL-I-017 Rev. ' O dated 7/7/86, and several DIRs. The design criteria list did not appear to address the.following technical subjects relevant to AFW support systems:
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(a) Process variables to initiate and control AFW support system (b) Capability for test and calibration. (system or component level)
(c) Manual initiation at the system leve (d) Interlocks with other equipment and system (e) System ' level bypass indicatio (f) Response time capabilit Open Item I-7.
, A number of criteria contained in the support systems design criteria list
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appeared to be applicable to the ESF ventilation system, but were not included in the AFW support systems checklist [ numbers (7)-ventilation system independence, (9) protection system failure modes, (10)-system test capability, (13)-control power for train A and B loads on batteries, (14)-
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associated circuit requirements, (15)-Regulatory Guide 1.75 separation, (16)-circuit and equipment separation, (17)-depiction of separation on drawings, and (18)-separation methods ].
\ Open Item I-8.
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- DSAP XI, page 25 states that th2 review of the ESF ventilation system will address interlocks. The TERA review of control logic and electrical schematic diagrams did not address the following interlocks:
(a) Valve limit switch interlocks with fan motor circuits.
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(b) Autcmatic isolation of the motor driven AFW pump room based on a safety injection signa Open Item I- TERA stated that the following interlocks will be covered in Review Topic E05:
(a) Electrical area fan coil unit initiation on safety injection ard station blackout signals as described in FSAR Table 8.3- (b) Automatic load shedding of safety-related ventilation fans
_ based on safety injection and station blackout signal The team will follow-up to confirm thi Open Item I-10 {
Review Topic: E10, Support Systems, Diesel-Generator Representativeness of Reviewed Documents:
NRC inspection report 50-445/85-17,50-446/85-14 dated January 21,1986, (pages A-13, A-14, A-39, A-41, and A-42), iists five topics for the TERA diesel generator support system review; namely, the fuel oil tank logic, I fuel oil transfer logic, diesel generator HVAC, ESF ventilation to diesel generator rooms, and diesel generator cooling water. Page 25 of DSAP XI
{
identified three diesel generator support systems for review:
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1) the ESF ventilation system, 2) the dlese] generator fuel oil transfer and storage system, and
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3) the diesel 'giverator cooling water syste The depth of review for each of these systems was stated to include redundancy, independence, assignment of power supplies, interlocks, instrumentation and control, and bypass status indication. As a result of discussions with the team, TERA stated that it plans to expand DAP scope to include the day tank room ventilation fan interlock and additional attributes for the diesel generator fuel oil pump control logi Review of Documents:
TERA reviewed Gibbs and Hill flow diagrams, electrical schematic diagrams, ,
and connection diagrams for the diesel generator support system topi The team concentrated on the fuel oil day tank control logic depicted by the Gibbs and Hill flow diagram (M1-2215-01, Rev. CP-1, 4/9/85) and related schematic diagram sheets (El-0067 sheets 27, 29, and 39, all at the CP-1 revision level). The team also reviewed the design criteria list, checklist DAP-CL-I-018 Rev. O dated 7/7/86, and several DIR i
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The following design criteria appear to be applicable to the diesel generator support systems, but were not included in the checklist: (6)-mechanical and electrical interactions with the diesel generators, (7)-independence of ventilation systems, (8) periodic test capability, (9)-single failure conformance, (10)-test and surveillance provisions, (11)-independence of D/G assessories, (12)-separation, (14)-associated circuit requirements, and (15)-Regulatory Guide 1.75 separation conformanc Open Item I-11
, In the control logic and circuitry for the diesel generator fuel oil day tank pump, which involved an interface between the diesel supplier
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(Transamerica DeLeval) and Gibbs and Hill, the following problems not found by T. ERA were identified by the team:
(a) The Gibbs and Hill instrument control diagram does not agree with the Gibbs and Hill schematic diagrams on the connection of day tank level switches to individual fuel oil pump control circuits.
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(b) The Gibbs and Hill setpoint calculations (not reviewed by TERA) did not recognize that two separate outputs (contacts 1-2 and 4-5) are required from each. day tank level switc (c) Level switch contact 1-2 operates at high and low fuel oil day tank levels, whereas contact 4-5 operates at high and low-low levels. The Gibbs and Hill calculation identified only the high and low level setpoint (d) The memory circuit provides for alternate fuel oil pump operation, but the control logic precludes switchover to the backup pum Open Item I-12 Review Topic: E14, Hydrogen Monitoring Representativeness of Reviewed Documents:
Since the MS-160A Gibbs and Hill specification is the only document in the applicable HDA (I052.0), the team did not perform a representativeness revie Review of Documents:
. TERA reviewed the containment hydrogen monitoring system specification (MS-160A Rev. 1 dated 4/1/01) and a related Gibbs and Hill solid state isolation equipment specification (ES-24, Rev. 1 dated 10/14/76). The team reviewed these specifications, design criteria list DAP-CR-E1C-015, checklist DAP-CL-I-057 Rev. O dated 7/7/86, several DIRs, and an Exo-Sensor operation and maintenance vendor manual (105-0M-021, undated).
TERA's review for the hydrogen monitoring system included the sensors located inside containment, containment electrical penetrations, panel mounted micro-processors, electrical isolation devices, and uninterruptible powtr source TERA stated that the system readout indicators located on the main control boards (that are subject to separation, environmental and seismic qualification requirements) are being reviewed under Review Topic E08-Component Functional Requirements, Indicators. Based on checklist attributes shown to the team,
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the main control board component functional review will address the qualifica-
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tion aspects of the indicators. TERA stated that the hydrogen monitoring system review for separation is addressed in Review Topic E09-Single Failure /FMEA. The TERA review did not identify hardware or software requirements applicable to the micro processors.
i Open Item I-13
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