IR 05000445/1987019
| ML20236C882 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/14/1987 |
| From: | Lyons J, Norkin D NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236C879 | List: |
| References | |
| 50-445-87-19, 50-446-87-15, NUDOCS 8710270382 | |
| Download: ML20236C882 (183) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS l
Comanche Peak Project Division l
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s Report Numbers:
50-445/87-19, 50-446/87-15 Docket Numbers:
50-445, 50-446 Licensee:
TV Electric 400 North Olive St., L.B. 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station Inspection At:
Stone and Webster, Boston, Massachusetts and Cherty Hill, New Jersey Ebasco, New York, New York Inspection Period: August 3 through September 3, 1987 Inspection Team:
NRC:
lE~P. Norkin, OSP/CPPD - Team Leader F. S. Ashe, OSP/CPPD - Electrical /I8C Contractors:
G. M. Aggarwal, Electrical A. J. Hulshizer, Civil / Structural D. M. McNulty, I&C D. A. Mehta, Civil / Structural F. R. Rosse, Mechanical Systems N. 8. Pauling, HVAC Systems
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I ( O' \\ k
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ona d P. horkin Date Team Leader Office of Special Projects
/ohV/97 Approved by:
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James E. L ons
' Ddte ssistant Di o for Technical Programs
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Table of Contents l
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Table of Contents....................................................... 2 Individuals Participating in Inspection Exit Meetings................... 3 I n t ro d u c ti o n a n d S u mma ry................................................ 4 Mecha ni cal / Fl ui d Systems - Sunnary...................................... 7 Mechanical / Fluid Systems - Evaluation of Documents Reviewed
............12 HVAC Systems - Summary................................................. 27 HVAC Systems - Evaluation of Documents Reviewed........................ 30 Instruments tion & Control s Summary................................... 41 Instrumentation & Controls - Evaluation of Documents Reviewed......... 44 Electrical - Summary................................................... 57 Electrical - Evaluation of Cocuments Reviewed.......................... 61 Civil / Structural - Summary............................................. 79 Civil / Structural - Evaluation of Documents Reviewed.................... 88 Resolution of Design Adequacy Program Open Items Appendix A - NRC Inspection Report 50-445/85-17, 50-446/85-14
......A-1 Appendix B - NUREG-0797, Supplement No. 13, Appenc.'x C.............B-1 Appendix C - NRC Inspection Report 50-445/86-17, 50-446/86-14......C-1 Appendix 0 - NRC Inspection Report 50-445/86-18, 50-446/86-15......D-1 Appendix E - NRC Inspection Report 50-445/86-19, 50-446/86-16......E-1
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Individuals Participating In Inspection / Exit Meetings NAME:
TITLE ORGANIZATION I',
L..E. Shea Assist. Project Engineer SWEC-
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H.'M. Carmichael~
Q. A. Program Manager SWEC
'J. S. Carty Project Engineer SWEC-
'C. G.. Creamer'
' ISC Engineering Manager.
'TU Electric'
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.?J.'W.LMuffett Manager Civil / Structural TU Electric.
S. L. Stann Project Engineering Manager SWEC,
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S. J.-Seiken-
- Tech. Audit Program Manager TU Electric
A. Y. C..Wong'
Lead Structural Engineer-SWEC J.:H. Lash _
Asst. QA Program Manager-SWEC
.l R.'L. Poltrino Lead-Control Engineer SWEC J
OSP/NRC i
A..Vietti-Cook Project Manager'.
SWEC'
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.M. Giglio Mechanical Coordinator'
JL Camobreco'
, Lead Mecahnical Engineer-SWEC l
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R.:W. Twigg.
i K. A. Schack 18C Coordinator-SWEC W. R.' Curtis EFE Coordinator SWEC~
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.H. J.-Boc
' Asst. Lead Electrical SWEC W. J. Parker Asst. Project Engineer (Mech)
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.l P. W. Ward-Structural Coordinator SWEC f
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H. C. Liang Lead Environmental & Geotech SWEC
.D. Graves
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Lead Nuclear Technology
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~E. F. Heneberry-Lead Electrical Engineer SWEC
- C. Workman Administrator Document Control SWEC i
. L. J. Kelly Asst.LeadEngineer(EMD)-
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.C. E. Watters Sr. Project QA Manager SWEC R. E. Foley.
Asst. Chief Engireer-Engr. Assurance..
SWEC C.'D. Nardella Asst. Project Engineer-Elec./I&C SWEC J. E. Lyons-Asst. Director, CPPD NRC-Peter Dunlop Asst. Mgr. - NY-SWEC J. H. MacKinnon Project Manager SWEC Bruce Ebbeson Principal Strectural Engineer SWEC Dave-McAffee Manager,QA TV Electric Charles Zappile EFE Program Manager SWEC W. M. Eifert Chief Engineer - EA SWEC
- Joe Padalino Project Manager - NY0 Ebasco Ram Rao-LeadEngineer(HVACSystems)
Ebasco Robert C.-Iotti Vice President & Project Gen. Mgr.
Ebasco John F. Streeter Director of QA TU Electric A. H. Saunders EA Evaluations Mgr.,
TU Electric-Owen Lowe Director of Engineering TV Electric E. J. Siskin Vice President SWEC U
W.CF. Sullivan Executive Vice President SWEC
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J..P. Lawrence Electrical Coordinates SWEC R. W. Ackley.
Project Manager SWEC R.-K. Westfahl Vice President SWEC
.G. R. Tilton Asst. Lead Engineer SWEC P. Garfinkel Director of Engineering SWEC
C. R. Horton Civil Engineering Unit Manager TV Electric J. A. Alberghini Mechanical Coordinator SWEC-3-
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Introduction and Summary
. Background
. Gibbs and Hill performed the. original architect-engineer design work for Comanche
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Peak Steam. Electric Station.
In early 1987, TV Electric initiated Design.Valida-tion Programs (DVP) involving eleven separate disciplines. This report addresses i-programs for the' mechanical, civil / structural, electrical, and instrumentation /.
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controls' disciplines.
For these disciplines, Stone and Webster and Ebasco are either validating Gibbs and Hill design documents (or other documents when they
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are the documents of record) or issuing new design documents when appropriate to
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The above effort is being performed by Stone and Webster except for two areas under Ebasco:. HVAC. systems design and the Systems Interaction Program..The Systems Interaction Program was not available for NRC review at this time.
The Engineering Functional Evaluation (EFE) program provides a Stone and Webster /
- Ebasco/Impell team which performs a vertical slice technical evaluation (an evaluation-of all design. disciplines and related systems / structures as they
- interface to a selected' system or structure) of the validated Gibbs and Hill (also THE) design documents and new SWEC/Ebasco design documents. The systems (
and structures selected by TUEC for evaluation-are the Containment. Spray and Control Room HVAC Systems and associated electrical / control systems, and the Safeguards Building. They were selected based on their complexity and nuclear grade classification and because they involve design activities which are representative of the BOP design process.
Method of Review
During the period from August 3 through September 3,1987, an NRC team, comprised of two members of the Office of Special Projects and six consultants, inspected the DVP at SWEC offices in Boston, Massachusetts and Cherry Hill, New Jersey, and the Ebasco office in New York, New York. The team inspected validated design documents as well as new SWEC and Ebasco design documents.
The inspection emphasized two aspects which were significant to the DVP effort:
1) the adequacy of the design criteria stipulated in Design Basis Documents (DBDs)orothersourcedocumentsand(2)thecomplianceofdesigndocuments to these' design criteria. The team assessed design criteria adequacy on the basis of whether the criteria were consistent with FSAR coninitments, industry
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practice and good design practices required to ensure system functionality.
I i-Up to fifty percent of the inspection sample was comprised of design documents also reviewed by EFE. The team reviewed the documents and subsequently reviewed findings by EFE on these same documents. The purpose of this was for the NRC to
. determine whether problems identified by the team were also identified by EFE and, thereby, to identify any weaknesses in the EFE program.
In this regard, the team's review of the other fifty percent, i.e., areas not reviewed by EFE, served as a i
test as to whether EFE's findings with respect to areas evaluated were represen-
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tative. Consistent with the above methodology, the team reviewed the EFE vertical slices (e.g., containment spray system), and the auxiliary feedwater system (which
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EFE did not review). Within these vertical slices, the team focused upon " generic
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technic &l issues" arising from TENERA's previous review of Gibbs and Hill's oesign documents.
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i Due to the in process status of both the DVP and EFE effort and the need for j
the team to review completed work, the team was constrained in its available
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review samples.
Although the team always reviewed completed work which was representative of the DVP process, there were the following constraints which will require a followup inspection:
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(1) areas where EFE has not completed sufficient reviews i
(2) significant areas where the DVP was not technically complete.
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For example, so little of the Systems Interaction Program was completed that the team deferred its plans to review this area.
j In other disciplines, the team concluded that additional areas needed to be reviewed for the team to reach a conclusion on the discipline as a whole.
(3) areas where confirmation is required on inputs.
For example, almost all mechanical process parameters being used in I&C setpoint calculations require confirmation.
(4) areas where interface data between disciplines require reconciliation.
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Summary of Results The remainder of this report contains a two part section for each discipline reviewed.
The initial part is a summary of the rationale for the review sample, trends, open items, assessment of EFE and additional planned reviews.
The second part documents the team's review of each design document in the J
review sample.
Item 4 in the second part discusses the design document's
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acceptability.
The discussion focuses primarily on areas where further information is needed for the inspector to conclude that the document is acceptable.
Space did not permit documentation of all areas reviewed that were found acceptable.
Open items are highlighted by number to facilitate the applicant's response and the team's follow-up.
This was an interim review in that the SWEC and Ebasco work had not been completed in major areas, and significant work remains to confirm input data and assumptions and to reconcile interfacing data between disciplines.
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this situation, EFE was limited in its ability to make progress.
Therefore, the team was unable to completely assess EFE and to measure the positive contribution that EFE could potentially make to the DVP effort.
For example, in the Civil /
Structural area, EFE planned to review 31 documents, but completed its reviews on but 7.
The team reviewed 24 documents, including these 7.
Nevertheless, it is recommended that EFE make use of Open Items identified by the team to evaluate the need for expanded EFE reviews in such areas.
One such example pertained to interfacing documents relating to battery sizing problems and their impact on associated equipment.
The team generally found the DVP effort comprehensive and effective, particularly with respect to the use of Design Basis Documents to prescribe design criteria and methodology, and the tracking system to ensure confirmation of data.
However, the following specific problems were noted in these areas:
(1) Civil /strLctural 080s are incomplete in many areas, and design work underway does not reflect consistent methodology that the DB0s would be expected to prescribe.
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. (2) HVAC' system DBDs and other design criteria documents are inconsistent i
with.each.other and/or-the FSAR concerning modes of operation, temperatures, and relative humidity.
adequately identified (pline, some items requiring confirmation were no In the electrical disci (3)
twocases).
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Most of the significant items identified by the team may be resolved on the l
l basis of additional justification and/or analysis or resolving documentation errors, as opposed to. design or hardware modifications. Some examples are:
(1) Failure to consider LOCA conditions in containment spray pump net j
. positive suction head calculation (0 pen Item F-2).
(2) Use of non-conservative heat exchanger. convection coefficient (0 pen Item F-10).
(3) Requiring use of J14 relays for switchgear close and trip contacts; they do not have the required current rating (0 pen Item E-15).
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ing-the seismic analysis assumption of rigidity for floors i
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Not justify (0 pen Item C/S-4).
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and walls
(5) Assumption of hydrostatic loads as live loads in seismic analysis (0 pen Item C/S-11).
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The, purpose of this inspection was to perform an interim assessment, not to reach final conclusions. We have attempted to bring the Open Items to the
- applicants' attention promptly so that they can be addressed and considered with regard to indications of any broader problems'which need to be addressed in the DVP. Open Items are clearly marked throughout the report.
In order
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to release the report promptly, compromises were made in providing detailed consistency in the format, notations, and editing for the documentation of each of the technical sections. The team will defer its conclusions until it completes a followup inspection which will include resolving the Open Items and addressing the above-mentioned remaining aspects of the DVP.
Resolution of Open Items from Design Adequacy Program The Comanche Peak Response Team Program Plan includes a Design Adequacy Program (DAP) covering the mechanical, civil / structural, electrical, and 180 disciplines.
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NUREG 0797, Supplement No. 13 Appendix C and various NRC inspection reports identified Open Items pertinent to the DAP. Appendices A through E of this report resolve these Open Items by indicating the NRC issue, the DAP response, and the NRC evaluation of the DAP response. All of the Open Items addressed in the appendices have been " closed"; all were closed on the basis of the responses addressing the issues in an acceptable manner.
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Mechanical / Fluid Systems - Sumary i
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i HECHANICAL/ FLUID SYSTEMS
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Inspection Sample This review was conducted to demonstrate design adequacy of safety
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related fluid systems by auditing a sample of the systems design J
documents 'and comparing these to applicable design basis requirements.
' Two systems were selected for review, one of which had been examined by the Stone and Webster Engineering Functional Evaluation (EFE) group.
This allows a parallel effort comparison to address the effectiveness
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of the EFE team'in its independent rev.iew efforts.-
i 1.1 Containment Spray System This system was selected because it is significant to providing l
for containment heat removal and control of radiological releases after the design basis Loss of Coolant Accident (LOCA). This system has also been reviewed by the EFE team.
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l 1.2 Auxiliary Feedwater System.
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This system.is important to providing for core cooting during
~ he majority of-plant upset and accident conditions.
It is talso the only system available to prevent core overheating and
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damage for the case of loss of all AC power.
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Trends l
Subject to satisfactory resolution of Open Items identified by the team and the limited scope of this review, the team concluded that these safety systems can perform their intended functions. Of the
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items questioned by the team, Stone and Webster, in most cases, presented i
documents which indicated they had raised a similar question and that
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resolution action was in progress.
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3.
Open Items 3.1 Containment Spray System l-This review was limited to addressing the fluid flowrates and
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delivery capacity of the system. Compliance with piping code pressure ratings was not evaluated in specific document reviews.
Based on our discussions with Stone and Webster, these areas appeared to be well addressed by Stone and Webster.
Several systems calculations were not available at the time of
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this review; these include spray additive tank eductor hydraulics l
and pH limits calculations.
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k 3.1.1 Containment Spray Flowrates and Pump Net Positive Suction l
Head (NPSH) Calculations, Calculation No. 16345-ME(B)-169,
Rev. O, July 1, 1987.
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The most significant issue involved implementation.of
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Regulatory Guide 1.1~which requires that the hot water.
in.the containment sump be assumed at maximum-temperature (saturated) conditions in the containment spray pump NPSH
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calculations. Conditions approaching this might occur-
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after the classical design basis accident, or loss of Coolant Accident (LOCA) which is considered at all'
commercial power reactors. The Stone & Webster calcula-
. tion utilized a water temperature which is related to the
,RWSTtemperature'(injectionphase)ratherthanthecorrect.
containment sump accident temperature. The EFE program review addressed the temperature issue, but was insensitive
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to the R.G.1.1 requirement.'
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The team' performed a cursory check and determined that the
.l requirements of R.G. 1.1 appear to be~ met, although this J
needs to be confirmed. Therefore, it appears'that the design is adequate, although the current calculations do not confirm this. Similarly, the team determined _that the. system probably.
<R can deliver required flowrates. However, additional effort is required to confirm that.the design meets its design bases,
including those addressed _by Open Items:F-1 through F-7.
LAbout.one-half of the items identified by the team were
.q addressed by EFE;.This was.the only calculation which.was audited by both the NRC team and EFE group. With respect to t
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other calculations slated.for EFE review EFE had not-completed its review at the time.of. this inspection, 3.1.2 Containment Spray Heat Exchanger Convection Coefficient Calculation No.16345-ME(B)-096, Rev. O July 15, 1937 The team questioned why the calculation assumed significantly lower heat transfer fouling factors than those for the RHR heat exchanger (both heat exchangers have the same fluids onbothsides).
If the differences-cannot be justified and the more conservative coefficient is found appropriate, then its impact on the containment pressure / temperature analysis -
needs to be assessed (0 pen Item F-10).
3.2 Auxiliary Feedwater System Based on the team's limited review, it appeared that the Design Basis Document was generally a compilation of FSAR conunf tments and FSAR systems information. The DBD should be expanded to give complete fundamentals and applicable criteria relating to system design. Stone & Webster presented a third-party review of this DBD which had already identified most of the shortcomings found by the team (0 pen Items F-12 through-F-14).
3.2.1 Instrument Setpoints, Auxiliary Feedwater CalculationNo.16345-ME(B)-006 j
Open Items F-15 and F-16 concerned calculational errors and unrealistically stringent demands of flow instrumen-
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tation; Stone & Webster indicated that the latter would be corrected by the instrumentation calculations to be performed at a later date.
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.'3.2;2 Auxiliary Feedwater System Performance Calculation No. -16345-ME(B)-053.
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- This calculation determines flowrates' for several possible system alignments. The piping hydraulic loss calculations were well: performed and clearly defined. The method used provides a complete and well-documented survey of. piping /
component friction losses. Al computer code is used to calculate system flows with various pump / steam generator /
condensate tank combinations.. Results are presented.in a
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well-ordered manner,.readily. suitable to allow addressing
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variables;and revisions to the system. The team considers this calculation, including the methodology, to be superior-
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to that for the containment spray system (see 3.1.1 above)'
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as indicated by the number of open items' identified by.the team'and EFE.
This calculation method should be used to evaluate the containment spray and other system flowrates.
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Open Item F-17' concerns. design basis items which were not.
evaluated.. However, the team considers these to be minor-and does not expect that evaluation of these items will.
impact s/ stem design.
3.2.3
' Auxiliary Feedwater Pump NPSH CalculationNo.16345-ME(B)-054 This _ calculation' determines-that sufficient suction pressure is available to assure continued pump operation. These calcu-lations were well performed in a manner.similar to the flow-rate calculations mentioned in 3.2.2.
Open Item F-18 concerns the need to evaluate more conservative flowrates.
3.2.4 Maximum Differential Pressure for Motor Operated Valves Calculation No. 16345-(ME(B)-143 This' calculation determined the maximum static differential pressure for valve operability considerations, but does not address transient pressure rise which occurs during valve closure due-to deceleration of a fluid column as the valve closes.(0 pen Item F-19).
3.2.5
. Piping Arrangements The steam pipe supplying the turbine driver for an auxiliary feedwater pump contains an undrainable pocket which allows about_120 feet of pipe to collect water.
Stone & Webster presented documentation showing that correction of this
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problem was in progress.
Temperature indicators in the auxiliary feedwater pump l
discharge piping, intended to detect back-leakage of hot J
main feedwater which could disable the auxiliary feedwater j
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system, are currently positioned too close to the normally
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hot main feedwater pipe; spurious alarms may result (0 pen j
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EFE Results
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.The team reviewed only one calculation which was also reviewed by.EFE.
As indicated in 3.0 above, many of the team's issues were also raised by-EFE. Some were not.
The most significant issue identified by the team
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but not EFE was the lack of compliance with R.G. 1.1.-
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5.
Additional Review As indicated.in the Instrumentation and. Controls section of this report.
I significant effort remains to confirm mechanical process parameters which
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are the input for I&C setpoint calculations. The team will place emphasis j
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'on this area in-the next inspection.
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Mechanical / Fluid Systems - Evaluation of Documents Reviewed
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b 1.. - Document Number: -G&H Calculation.530 Rev.' 2, Screen-Size for Containment Sump
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Related Generic Issue:
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System Design
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Desian Criteria:
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DBD-ME-232 - Regulatory Guide 1.82, dated June 1974, requires the design j
coolant velocity at the inner sump screen to be approximately 0.2 ft./sec.
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Design Document Acceptability:
. The S&W calculation validation procedure corrently.noted that the G&H calculated design coolant velocity of 0.3 ft./sec. exceeded the'0.2 ft./sec. design criteria.
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G&H had apparently considered that.the'.3 ft./sec..was close enough to
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j 0.2 ft./sec.,to be acceptable. The team agrees with S&W that the calculated
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velocity does not meet;the intent of.the design criteria.
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Engineering Functional Evaluation Results:
i EFE did not complete its review.
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Document' Number:
16345-ME(B)-169, Rev. O dated 1 July 87 Containment-Spray Flow Rates
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Related Generic Issue:
System Design yc 3.
Design Criteria:
.DBD-ME-0232.
This DBD contains design criteria for the containment spray system, including requirements for flow rates and net positive suction head.
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Design Document Acceptability:
Open Item F-1: -Calculation for NPSH in injection mode 1.
DB0 232 is used-to reference flowrates to other components (ECCS); however, the DBD,does not delineate flow assumed in this calculation.
EFE did not
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address.
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2.
120 F RWST temperature was assumed; DBD states a.100 F RWST maximum temperature.
EFE addressed.
0 pen' Item F-2':
Calculation for NPSH in recirculation mode utilizes.120*F sump suction temperature.
This violates Regulatory Guide 1.1, which requires utilization of maximum containment sump water temperature (>212*F). 'EFE was apparently insensitive.to LOCA conditions and instead addressed the RWST
- temperature as pertaining to the recirculation mode.
Open Item F-3: ' Containment Spray pump minimum flow is defined (750 GPM).
However, maximum allowable flow should also be defined for comparison to both
'th.is calculation and startup flow calculation.
EFE did not address.
Open Item F-4:
Containment Spray flow analysis neglects spray additive eductor hydraulics.
EFE did not address.
Open' Item F-5:
Ref 8, G&H calculation 2323-529, Rev. O gives minimum recircu-lation sump. elevation water level of 810 feet vs. 814.8 feet in G&H sump per-formance study.
EFE addressed this.
Open Item F-6:
Attachment B - Pipe and Fitting Losses Page B4 - Combining flow path resistances in parallel (equivalent header resistance calculations) - Calculation method given is only valid for parallel flow paths originating and discharging to the same HGL (Hydraulic Grade Line).
LSpray. header parallel flow calculations originate at the same node, but dis-charge to nodes having different HGL.
EFE addressed this.
I Page B3 - 24" suction header, CS/ECCS flow is 26,000 GPM per reference 7/page 4, but the reference does not give this flowrate.
EFE did not address.
Page B3 - RWST Sparger is not accounted for in the hydraulic resistance calcu-lations.
EFE did'not address.
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. Open' Item F-7:
Attachment C'
'Page C29:- Heat exchanger K factor of calculation.-
14.12 PSID is based on a'
i velocity of 9.5 feet /sec.
It is not clear whether this relates to pipe velocity, heat exchanger tube' velocity or.some.other basis.
This was not
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addressed by EFE.
Page C97_- Sump Suction Path L
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No containment sump recirculation screen _ pressure drop.is' accounted for;:
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- however, G&H Sump Performance Study _ assumes.4 feet head loss.
There is no piping inlet loss _ factor for the. protruding sump suction pipe.
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' The calculation refers to a 16 x 16 x 12 tee with no flow.in the run, giving
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a loss ~ factor of 0.26.
This loss factor appears low,.and it also appears'that
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there is flow in the run.
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The suction piping includes a transition involving both 16" x-3/8" wall pipe and 16".SCH 120 pipe.
The size transition expansion and contraction losses
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. Hydraulic losses for only one suction path are~given-in the calculation.
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Friction losses for the other path should be calculated.
It is noted that the_ frictional components delineated above', although indivi-
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. NPSH margin'available for the recirculation mode'(i.e., >-212 F temperature).
5.
Engineering Functional Evaluation Results:
Items addressed by EFE indicated above.
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System Design d(..Qf
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Accepted fluid systems' engineering practice recuires that air entrainmp tMr.edt
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ECCS/ Containment Spray pump suctions be precluced.
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,0 pen' Item F-8:..'The. calculation. relies heavily o yef. IN,GouldPumpManbl)-
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Figure 5.to detennine sparger submergence requirements but does not,estah ish i
the applicability of this manual to the actual sparger.configa ration Z',,(
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((Browq & Root drawing BRP-Sl-1-YD-001, R,ev. 16) do not meet this requirement.,
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Engineering Functional Evaluation Results:
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Document Number: 2323-232-14, Rev. 1 Dated 22 M' arch 1982, Setpoint Chemical Additive Tank
2.
Related' Generic Issue:
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Design Criteria:
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DBD-ME-0232,'Re K 0
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DesignDocumentAcceptabilh:
Open Item F-9: This do'cument assures 4500 gallons useable volume for the chemical additive tank; however, no basis or reference for the 4500 gallon a-requirement is provided. Without this linkage, if the 4500 gallon requirement changes, there is no assurance that the subject calculation would be updated.
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Thisd'cumentreliesonhighaccuracyinstruments(*1.5%,t.35%).
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5.
Enaineerina Functional Evaluation Results;
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DocumentMumber:
163b-ME(B)-096,Rev.O,Jdated15 July.87,' Containment
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Spray Heat Enhanger Convection Coefficient
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' keat transfer fouling allowance; has a' pronounced inhuer;ce on'the: overall heat.
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transfer coefficient for high' performance heat exchangers such as the contain-ment spray heat exchanger. - A fouling allowance corresponding to appropriate
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J' j water conditfr}n$should be assumed for the containmentyspray heat exchanger.
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Design', Document Acceptability
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Open' Item F-10:,It appears that the 80% fouling allosnce used hr'the.,
containment' spray 1 gat exchanger. calculatier.s results in 4g overall heatL o
- /rgansfer coefficient about 30% to 40% higWthan the heat : transfer. coefficient
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6btained with use of. Westinghouse.RHR syste.n design foulir }'ellowajee.
Note that:the containment spray and RHR heat exchentgirsvutilize;thesamhrhidr, m l 3 /!
Eoniboth sides.
- S&W should either justify :tde fotilirg ailmance differences
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for. the two heat exchangers or assess the jmpact of u';fng th higher fouling.
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Engineering. Fundtional Evaluation Result _s;
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Document Nunicer: DBD-0206 Design Basis Document Auxiliary Feedwater Sytem j
2.
Related Generic Issue System Design d
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Design Criteria q
Open Item F-11: Referenced Codes and Standards:
The Desion Basis Document for this system does not adequately reference applicable codes, regulatory requirements and design guidance documents applicable to this system's design. USNRC Standard Review Plans are not referenced. Further, reference to all relevant design guidance documents,
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y such as applicable NUREG documents, IE Bulletins, INP0 Experience Reports, (
etc., should be made within those sections of the Design Basis Document which derive their technical requirements from these documents. This Design Basis
'
Document references FSAR sections extensively. However, the FSAR should not-be considered as a source for system design basis, j
.
Open Item F-12: System Function:
The Design Basis Document describes the system requirement to provide a minimum flow rate to steam generators.
However, there is no discussion of
!
the anticipated variation in flow demand, and possible control valve operational deficiencies which may surface due to the character of steam generator level response during hot standby and cooldown conefitions.
The Westinghouse Steam Systems Design Manual (SIP 10-1), Appendix A, page A33 lists a criterion that auxiliary feedwater regulation "... valves be equipped with safety grade accumulators of sufficient capacity to permit operation of valves for the maximum number of anticipated cycles of operation..." While this Westinghouse manual is not currently referenced in the Design' Basis Document, it is noted that accumulators are sized to provide 5 valve cycles during a 30 minute period allotted before manual local modulation of auxiliary feedwater valves is assumed (DBD Section 4.3.2.3).
There is no documented evidence that 5 valve operating cycles is adequate for the intended service. The concern here is the anticipated large level swings which may occur in hot standby conditions when safety relief valves lift and reseat. For some plants this level swing can cause level indications off-scale high or low, which in turn may induce the operator to attempt AFW flow control actions more frequently than the installed air accumulators allow. These phenomena should be technically addressed and operational cautions established if warranted.
Open Item F-13: Operating Modes i
Section 5.2.1A of this DBD states that Auxiliary Feedwater System operation is
'
discontinued once ".. 67% steam generator level is maintained...".
,
- 19-
_ _ - _ _ _ _ _ _ _ _ _
--
It should be made clear if this statement applies to the narrow or wide range level instrumentation, and if the same values are applicable to unit 1 & 2, since level spans for each unit are different.
Section 5.2.2A indicates that the Auxiliary Feedwater System is used during LOCA "... to prevent primary to secondary leakage...".
This statement should be modified to factor in purposes presented in the Westinghouse Steam Systems Design Manual, SIP 10-1 (Heat removal and radiological concerns).
In section 5.2.2 B&C it is stated that a steam line break or feedwater line l
break is "... initiated by..."; " indicated by" are apparently the intended
,
words.
'
Section 5.2.2C implies that a feedwater line break will be indicated by low steam generator levels, although a single line break of intermediate size may not cause these conditions.
It is also noted that there is no discussion of the loss of offsite power operating condition, or station blackout considerations.
The applicable spectrum of postulated accidents and resulting indications / actions should be addressed to determine enveloping scenarios for system design.
Open Item F-14: System Reliability:
Auxiliary Feedwater System reliability has historically been a problem at function due to (a) particular this system often fails to perform its ir: tended nuclear plants.
In turbine driven pump steam supply and/or governor problems or (b) back leakage and steam binding of pump casings during normal operations.
These concerns should be addressed within the design basis document.
4.
Engineering Functional Evaluation Results EFE did not review the AFW system. However, a review of the Auxiliary Feedwater System design basis document was documented by the TV Technical Audit Program in a technical evaluation report (TSR87-28, dated 10 June 1984). About one-half of the comments delineated above were mentioned or alluded to in the report in addition to several other comments concerning this DBD.
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Document Number:
16345-ME(B)-053 Auxiliary feedwater System Performance 2.
Related Generic Issue:
System Design 3.-
Design Criteria:
DBD-ME-206. This DBD includes requirements for the auxiliary-feedwater system performance, including flow rates and net positive suction head.
4.
Design Document Acceptability:
Open Item F-17:
Several design basis items were not adequately addressed within the calculations:
For all evaluated cases of a faulted steam generator, friction of high energy piping upstream of the steam generator was included in the calculations. This causes non-conservative spill flowrates with respect to CST inventory _ require-ments and pump runout flowrates.
The DBD states that maximum runout flow of 700 GPM is precluded by flow restricting orifices within the system. This calculation indicates flowrates exceeding this value. When actual pump retesting is performed, test data should be obtained for operating points beyond all normally expected flowrates to verify acceptable pump operation, NPSH, etc.
The DBD presents pump test head / capacity acceptance criteria. This condition represents a worn pump that provides less capacity than the original new pump.
The calculations are performed with new pump test curve input data, and do not illustrate that pumps meeting the DBD acceptance criteria will meet system function criteria. Allowable pump wear margins, and pump periodic testing acceptance criteria should be factored into the subject system performance calculation.
In addition, the calculation did not account for the pressure loss due to the steam generator inlet sparger pipe.
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1.
Docunent Number: 16345-ME(B)-006 Auxiliary Feedwater System Instrument Setpoints 2.
Related Generic Issue:
System Design
'
.
3.
Design Criteria:
DBD-ME-206 includes requirements for the auxiliary feedwater system performance, inuluding pump protection under minimum flow or low suction pressure conditions.
4.
Design Document Acceptability:
Open Item F-15: A pressure switch located on the pump suction piping is used to indicate low suction pressure and trip the applicable pump to protect the pump from damage. In the calculations to determine switch setpoints, errors were found due to lack of use of appropriate units.
For example:
On page ll, suction pressure is correctly calculated as 46.11; however, units of absolute feet are omitted.
46.11 feet absolute is converted to PSIA correctly (46.11 * 61.7/144 = 19.76 PSIA). However, this value is incorrectly labeled "Ft".
The 19.76 value is incorrectly converted to "PSIG" by multiplying by 0.43.
Open Item F-16:
If pump flow approaches a minimum value, a recirculation path must be opened to avoic pump damage or undesirable vibrations within the system. Control actions for pump recirculation valves utilize flow settings which will require orifice differential pressure instrument repeatability on the order of.01 PSID, (for an instrument rated at several PSID and instrument pressure rating of thousands of PSIG). System flow latitude margins may need to be relaxed to allow less restrictive instrument requirements. The team understands that this should be resolved in the normal mechanical /I&C interface which had not been completed at the time of the review.
.
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Document Number:
16345-ME(B)-054 Auxiliary Feedwater Pump NPSH 2.
Related Generic Issue:
Systems Design 3.
Design Criteria:
Accepted engineering practice requires that the pump net positive suction head calculation account for the largest flowrates in connecting piping, in addition to maximum expected pump flowrates.
4.
Design Document Acceptability:
Open Item F-18: The calculation utilizes pump rated flows for NPSH requirements instead of maximum expected flows, such as would occur just before pressure is reached which allows use of the RHR system..
For the case of spill flow to a faulted steam generator, common suction piping would experience flowrates in excess of those assumed for this analysis (see Run 4A).
.
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Document Number:
16345-ME(B)-143
. Maximum Pressure Di ferent ai l for M0V's f
.
2..Related Generic Issue:
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System Design-3.
Design' Criteria:
'IE Bulletin 85-03: requires'that a program be implemented by licensees to i
assure acceptable operation under maximum expected valve differential pressure conditions.
4.
Design Document Acceptability:
.i Open' Item.F-19':.The calculation provides static differential pressures across l
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i the valves only.- It =does not address the transient pressure rise which occurs
~
-
during' valve closure due.to deceleration of a fluid column.
ThelBWR Owners Group Report on Operational-. Design Basis of Selected Safety
'
Related Motor Operated Valves, draft dated Aug. 1986, General Electric NEDC No. DRF-E12-00100-75 serves as an example of the type of analysis which
-
utilizes transient ~ valve differential pressure build-up methods.
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Document Number: Brown & Root Inc. Piping Isometric BRD MS-1-SB-008 Auxiliary Feed Pump Turbine Steam Supply 2.
Related Generic Issue:
System Design 3.
Design Criteria:
Accepted engineering practice precludes the incorporation of undrained low S
points within steam piping systems.
4.
Design Document Acceptability:
The auxiliary feed pump turbine steam supply has an undrainable section of piping, potentially causing a large pocket for water accumulation and partial flooding of about 120 f t. of this steam piping. This problem had been identified in the DVP and was in the process of being corrected (ECN #406, Design Mod.85-273).
.
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_ _ _.
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e 1.
Document Number:
Brown & Root Inc. Piping Isometric BRP AF 1 SB 0278 Auxiliary Feedwater 2.
Related Generic Issue:
' System Design 3.
Design Critiria:
Plant experience has demonstrated that flow from the normally pressurized main feedwater system can enter the normally unpressurized auxiliary feedwater ' system through leaking check valves, JE Bulletin 85-01 requires l
monitoring to. detect this' condition.
'
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Design Document Acceptability
!
Open Item F-20: A temperature element (TE-2472) is it. stalled to allow detection l
of back leakage of hot feedwater into the auxiliary feedwater system. This aids l'
in precluding possible steam binding or overheating of the auxiliary feedwater l
system.
However, the thermowell is placed too close (about 4 feet) to the main i
feedwater piping; therefore, it will probably give spurious high temperature readings and thus be ' ineffective in performing its intended function.
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HVAC Systems - Sumary j
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- 27-
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V HVAC SYSTEMS
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' Inspection Sample The four areas. reviewed by the: team were. Diesel Generator Area Ventilation system (DGAVS), Control Room Air Conditioning System (CRACS), Service Water.
,
-
-. Intake Structure (SWIS) Ventilation System and Uninterruptable Power Supply Air Conditioning (UPS AC) System. The team reviewed the FSAR, Design Criteria
.
Document and Design Basis Document for each of the four areas.
In all areas
~
except the SWIS Ventilation System, the team reviewed calculations. In the CRACS and l'PS AC System areas, drawings were reviewed. Comparisons between-documents within each area were made to check consistency and continuity and to evaluate the follow-through of connitments. The team reviewed'several documents, e.g., the CRACS Design Criteria Document and a CRACS calculation, which had i
been reviewed by EFE as. evidenced by EFE comments. All of the above documents
reviewed were complete and were safety-related.
,
2.
Trends In each of the areas reviewed, there was a good progression in the development I
Dof the systems as one went from the FSAR, to the Design Criteria Document, to.
l the Design Basis Document, to the calculations, etc.
In many cases, however, there were inconsistencies from one document to the next, relative to temperatures-and relative humidity requirements for the various modes of plant operation.
This_ type of inconsistency exists in all four areas reviewed.
]
3.
Open Items
'
'In addition to the above_ inconsistencies, the team identified the following concerns:
(1).the method for alarming low air flow ~may not be responsive to all situa-tions involving low air flow (0 pen Item M-3)
l (2) potential below freezing temperature transient in: diesel generator area (0penItemM-2)
(3) precautions for operating air conditioning units with low condensing water temperatures.(0penItemsM-8andM-13)
{
l (4)_ potential for air leak bypass of a Control Room charcoal filter (0 pen ItemM-10).
4.
EFE Results There were no specific areas where this review and the EFE review revealed the same problem.
5.-
Additional Reviews L
Due to the fact that Stone and Wbster interfacing effort in the electrical and l-I&C areas lagged the HVAC systems effort, the team performed no formal inter-discipline reviews in this regard. The team will address this' aspect in its subsequent electrical and I&C inspections.
Four safety-related systems were
,
.
- 28-C_ _ __
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_
_
l available but not reviewed by the team. These are Safeguards Building Venti-lation System, Safeguards Building Electrical Area HVAC System, Auxiliary The team con-Building Ventilation System and Safety Chilled Water System.
siders the above four systems which were reviewed to be representative of all l
eight systems with respect to the HVAC design process.
.
.
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HVAC Systems - Evaluation of Documents Reviewed
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-1.
- Document' Number: 'Ebasco; Design. Basis Document No. DBD-ME-302A, Rev.'0, ddted July 31,.1987, Diesel Generator Area HVAC System r?.
~ Related Generic Issue:.
t
-
.HVAC-Systems 3.- - Design Criteria:
a.
The HVAC design criteria for the subject document relative to the space
>
temperatures are in FSAR Section 9.4 and Design Criteria Document No. DC-302A.
Open Item M-1: The criterion in DC-302A Section 3.1, Page 1, is to maintain space temperatures between 40 F and 122*F during all modes.of plant operation.
The DBD-ME-302A, Section 2.2.c, Page 10 criterion is to prevent freezing in winter months. Section 4.2, Page 13 indicates the heaters operate only'during normal. plant operating conditions.
Open' Item M-2: There is'a potential functional capability problem when outdoor
.i temperature is 20'F and the diesel is started. Since all associated fans (4)
!
start automatically with the diesel there probably would be a' transient temperature condition within the area considerably below freezing.
,
Open Item M-3: Pressure Differential Indication Switches are provided to alarm air flow. Setpcints given are for pressures lower than the pressure associated l
with normal flow. These alarm switches would not alarm low air. flow conditions l
due to a closed or partially closed damper before the fan or due to a closed'or
partially closed damper after the fan. This applies to DBDs-ME-304, 312, and
,
313 as well.
)
i 4.
~ Engineering Functional Evaluation Results:
This DBD was not reviewed by EFE.
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Document Number: Ebasco; Calculation No. 1-EB-302A-1, Rev. 1, checked and verified on 4/22/87, Diesel Generator Area HVAC System 2.
Related Generic Issue:
)
'
a-HVAC Systems
3.
Design Criteria:
-a.- The appropriate design criteria for the subject calculation are in FSAR Tables 9.4-1 and 9.4-2 Design Criteria Document DC-302A and Design Basis Document
,
DBD-ME-302A.
b -The subject calculation is' based on criteria in DBD-ME-Y)2A but not DC-302A relative to maintaining space temperature as required during all modes of plant operation. See Open Item M-1.-
4.
Design Document Acceptability:
The' subject calculation does not require maintaining the space y
Open Item M-4:
temperature at'or above 40*F during all modes of operation due to the conflict
'
' The calculation demonstrates that the design criteria are met except as mentioned above.
'Open Item M-5:. The calculation refers to Calculation No. EE-11 which gives an
" estimated generator heat loss." Since the generator heat loss is a large percentage of the total heat input into the area, the estimated value requires confirmation. A -letter from the manufacturer indicates the " estimated" value is good. This letter should be referenced in the calculation.
'
5.
Engineering Functional Evaluation Results:
The subject document was not reviewed by EFE.
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Document-Number: Ebasco; Design Basis Document i
D80-ME-304, Rev. 0, dated July 31, 1987,' Control Room Air' Conditioning System j
2.
Related Generic Issue:
j
.
.
HVAC Systems
~3
Design Criteria:
.
The subject document includes appropriate criteria (concerning temperature i
i-and relative humidity) from the FSAR Section 9.4 and Design Criteria Document -
J
.
DC-304 except as noted below.
l
- Open Item M-6:' Neither the DBD nor DC-304 require maintaining the relative humidity during other than normal plant operation (Section 4.3a, Page 16).
FSAR Section 9.4.1.2, Page 9.4-8 commits to maintaining relative humidity
as (given in Table 9.4.2) in the Control Room Complex during'all modes of l
l operation.-
Open Item M-7:
Section 6.2.1, Page 36 and Section 6.2.8, Page 46 of the subject document give space thermostat setpoints at 68'F.
FSAR Table 9.4-2 commits to l
75'F + 5'F.
Both. heating and cooling thermostat setpoints should be within
' the FTAR committed range.
Open Item M-8: Section 5.4, Page 34,'of the subject document states " Precautions during low CCW temperature of 40*F is to be furnished (later)."
It is our understanding that' air conditioning manufacturers warn that special arrange-i ments must be made to accommodate condensing water temperatures below 55 F.
This document should contain evidence that the manufacturer of the purchased air conditioning units agrees that the " precautions" taken for the 40*F con-i densing water temperature will not' jeopardize the operation of the units, nor compromise their safety related performance.
4.
Engineering Functional Evaluation Results
DBD-ME-304 and 00-304 were reviewed by EFE.
However, EFE did not identify the above inconsistency with the FSAR.
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Document Number: Ebasco; Calculations _
j X-EB-304-1, Rev.'2, dated July 27, 1987, and X-EB-304-4. Rev. O, dated July.7, 1987
,
2.
Related: Generic Issue:
HVAC Systems i
3.
Design Criteria:
Design criteria concerning temperature and relative humidity are in FSAR Section I
9.4, Design Criteria Document DC-304 and Design Basis Document DBD-ME-304.
_4.
Design Document Acceptability:
x These calculations demonstrate that the above design criteria have been used, that adequate calculations were made and that proper methods and procedures were used. However, resolution of the inconsistencies between the DBD/DC and the FSAR (0 pen' Item M-6) may affect the criteria for the calculations and, therefore, necessitate revisions.
Open Item M-9:
X-FB-304-4,' Rev. O, fails to demonstrate by calculations or any other accepteole mthod that the sensible cooling requirements of the
,
Control Room Ccr.Tiplex r.an be met by the "as-built" HVAC system.
,
'
5.
Engineering Functional Evaluation Results:
Revision 1 of X-EB-304-1 was reviewed oy EFE as evidenced by the " Potential Concern / Question" in Action Item No. H04.
EFE reviewed X-EB-304-4, but did not identify any action items.
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1.
Document Number: Gibbs and Hill Drawing and Ebasco DCA Nos..
Dwg 2323-MI-0304, Re. CP-12, dated November 22, 1985
.Dwg 2323-MI-0308, Rev. CP-3, dated November 25, 1985 DCA No. 59135, Rev. 0, approved June 22, 1987 I
.
.2.
Related Generic Issue:
HVAC Systems 3.-
Design Criteria:
The HVAC design criteria for these documents' relative to air flows, equipment safety classifications, and equipment arrangements are in FSAR Section 9.4 Design Criteria Document DC-304, Design Basis Document DBD-ME-304 and Calcu-lation X-EB-304-1.
4.
Design Document Acceptability:
DCA 59135 supersedes Control Room Air Conditioning Flow Diagram 2323-MIO304 and revises Control Room Air Conditioning Mode of Operation - Flow Diagram 2323-MI-0308.
Open Item M-10: Concerning functional capability of the Control Room charcoal
?
filters, drawing 2323-MI-0308 and DCA 59135 show a fire line with an isolation valve connected to the filters. Downstream of the valve is a drip trap that
,
would collect and drain valve leakage. Of concern is that the trap could be dry as there apparently is no provision for a trap primer. Upon filter opera-
.
tion, an air leak bypass could occur.-
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The team did not review protection of outside air intake and exhaust ductwork, j
as well as HVAC equipment relative to tornado depressurization.
It is under-l" stood.that the Control Building will be vented in the event of a tornado.
,However, safety-related ductwork and HVAC equipment would have to be designed
!
to withstand whatever differential pressure did occur during a tornado de-pressurization and repressurization event.
It'is understood that these issues are being addressed by design groups other than the Ebasco HVAC systems group.
'y They will be addressed in NRC reports which assess the work of these. groups.
5.
Engineering Functional Evaluatio_n Results:
The subject documents were not reviewed by EFE.
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p-1.
Document Number:.Ebasco; Design Basis Document No.
DBD-ME-312, Rev. O, dated July 31, 1987, Service Water Intake Structure
. Ventilation. System-
'
2.
-Related Generic Issue:
'
i
.
HVAC Systems
3.
~0esign Criteria:
,
' The HVAC design criteria for the subject document relative to space ventilation,.
.;
temperatures, and combustion. air requirements are in FSAR Section 9.4 and Design l
Criteria Document 0C-312.
j
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.
uSection 2.1, Pages 8 8 9, states the Service Water Intake Structure (SWIS)
Ventilation System consists of three subsystems; Service Water Pump Area (SWPA) Exhaust System.- Intake Structure (IS) Heating System and Diesel Fire
.
.
PumpRoom(DFPR)ExhaustSystem.- Revised FSAR Table 9.4-2 comits to main-l
'
!
taining the SWIS between 122'F (Max.) and 40*F (Min.) during normal, shutdown and emergency modes of plant operation and DC-312 Section 3.1, page 1 comits to the same 122'F and 40*F, the electrical equipment. qualification temperature, under all modes of plant operation. Also, the subject' document in Section 11.1.3c, Page 37 states "The design minimum temperature of 40 F for SWIS is always met."
Open Item M-11: The team noted the following examples where sections of the.
DBD either contradicted the above requirements or indicated that the-SWIS
..
Ventilation System relied upon a non-safety component to perform a safety function.
Sections 2.2 and 2.3.2 on Page 9 and Section 4.2 on Page 12 require maintaining
'the Intake Structure Heating System operational only during normal modes of
i plant operation and state the heating system is non-nuclear safety.
Therefore, it cannot be relied upon during emergency modes, p
Sections 2.3.3 Page 10, 4.2 Page 12 and 5.2.1.3 Page 21 state the Diesel Fire Pump Room Exhaust System is required to operate only during normal modes of plant operation and then only during operation of the Electric Motor-Driven Fire Pump.
Sections 5.12 page 18 and 5.3.1 page 23 discuss situations when the Service Water Pump Area temperatures are well above 122 F and state the equipment is qualified to operate at a maximum temperature of 131.8'F.
5.
Engineering Functional Evaluation Results:
The subject document was not reviewed by EFE.
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Document Number: 'Ebasco; Design Basis Document I
_
- 08D-ME-313, Rev. O, dated July 31,.1987, Uninterruptible Power Supply Area
'
,.
= Air Conditioning System l
'
- 2.
'Related Generic Issue:-
-
]
'
- HVAC Systems
.
- 3.
. Design Criterf a:
j l
The appropriate-design criteria for the subject document. relative to space
!
_ temperatures are the FSAR Section 9.4 and Design Criteria Document DC-313, i
Lexcept as noted below.
Open Item M-12:.DC-313, in Section 3.1, page 1, states the UPS and distribution rooms shall be maintained between 40 F and 104 F during all modes of plant operation. The subject document in Sections 4.3, page 13 and ll.l.3a page 37 states that during either upset, emergency or faulted modes indoor temperatures
,
l-are required to be maintained between 122 F and 40*F.
In the subject document, Section 11.1.3, page 37, b. Sumary conflicts with
!
' Section -10.13, page 27 concerning' the static pressure developed by the fan to move air through the ductwork (1.5 vs. 3 inches). The. static pressure calcu-
- lation. document number is.not referenced in this DBD.
'Open Item M-13: The UPS refrigeration units use Component Cooling Water (CCW)
.
'
'
l for condensing purposes as does the Control Room refrigeration units; however,
'
DBD-ME-313 does not, in System limitations and Precautions, Section 5.4 page 19, mention a precaution for the low, 40*F, condensing water temperature as does DBD-ME-304page34(0penItemM-8). Section 6.2.1, page 21 states that a pneumatic flow control valve in the water cooled condenser inlet regulates flow rate of the CCW.
It is our understanding most air conditioning equipment manufacturers give precautions against using condensing water temperatures below 55 F.
The manufacturer's acceptance of this flow control method to accommodate the low condensing water temperaure should be confirmed in order to ensure that the safety related performance of these units is not compromised.
4.
Engineering Functional Evaluation Results:
This DBD was not reviewed by EFE.
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1.
Document Number: 'Ebasco; Calculation No.
X-EB-313-1 Rev. O, reviewed or approved on November 10, 1986, Uninterruptible Power. Supply Air Conditioning System-
2.
'Related Generic Issue:
HVAC Systems.
I 3.
. Design Criteria:
.The appropriate design criteria for the subject document (concerning space
.a)
temperatures) are in FSAR Section 9.4, Design Criteria Document DC-313 and Design Basis Document DBD-ME-313.
The subject document' follows the ' indoors temperature criteria contained in b)DBD-ME-313 which conflicts-with that in DC-313. (See Open Item M-12).
-
4.-
Design Document Acceptability:
The sensible cooling load calculated is about 22 tons. This Open Item M-14:
conflicts with the statement made in DBD-ME-313, Section 1.4, Item 1 on page 8
]
relative to requiring a major reduction in cooling load from 26-1/2 to 13-3/4
'
tons.
On page=24, the sensible heat gains shown do not agree with those given in (263,538and259,813BTUH l
DBD-ME-313. Section 11.1.3 paBTUH)ge 37.a. Sumary.
vs. 167,493 and'165,458 5.
Engineering Functional Evaluation Results:
The subject document was not reviewed by EFE.
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Docucent Number: Gibbs and Hill Drawing No.
Dwg. 2323-MI 0313, Rev. CP-4, dated December 8, 1984 i
2.
Related Generic Issues:
,
-HVAC Systems 3.
Design Criteria
.The HVAC design criteria for air flows and equipment arrangements are in FSAR Section_9.4, Design Criteria Document DC-313 and DBD-ME-313.
A review of. the Uninterruptible Power Supply (UPS) flow diagram portions 'of this drawino indicate that the required design criteria have been used except as noted below.
4.
Design Document Acceptability:
The subject document shows air flows for upset, emergency or faulted modes of plant operation and indicates temperatures of 40 F to 122 have been used which conflicts with DC-313.
(See Open Item M-12.)
5.
Engineering Functional Evaluation Results:
!
The subject document was not reviewed by EFE.
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F 1.-
Document. Number: : TUGC0 Calculation No.-
. TNE-CA-131, Rev. 1,. Approved on January 7, 1985.
. 2.
Related Generic Issue:
HVAC Systems-
.
3.
Design Criteria:
The HVAC design criteria for the subject document concerning temperatures and relative-humidity _of air entering charcoal filters are. in FSAR Section 9.4, ANSI /ASME. Document No. N509 and USNRC Reg. Guide 1.52.
- 4.
- Design Document Acceptability:
The ' subject' calculation demonstrates.that the appropriate design criteria have
- been used..that adequate calculations were made, and that proper methods and
procedures were used.
l-The apparent reason for making this calculation was to determine the effect of Lusing a smaller heater upon criteria compliance and potential high temperature
' alarms. There would appear to be no basic criteria violated if the 20 kw
!
heater had been retained and the alarm setpoint' raised to 190*F, or if the heater was changed to 10 kw (as shown'by the calculation) or even Skw. The team's analysis determined that any of these combinations resulted in per-i formance within the above criteria.
-5.
Engineering Functional Evaluation Results:
i The subject document was reviewed by EFE as evidenced by the " Potential
'
. Concern / Question" in Action Item No. '0, Action Item Item Response and Action to Correct.
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Instrumentation and Controls - Summary
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INSTRUMENTATION AND CONTROLS (!&C) DISCIPLINE SUMMARY 1.
Inspection Sample l
' The. team reviewed I&C portions of two 80P safety-related systems, containment spray and auxiliary feedwater, as well as parts of the control room air s-conditioning'and habitability systems. Containment spray and control room
,
heating, ventilation and air conditioning systems are being reviewed by the
- l Stone'and Webster Engineering Functional Evaluation (EFE) group.
'
For the above systems, the team reviewed the following types of items:
'
!
Design Basis Documents (DBDs),
Process Piping and Instrumentation Diagrams (P& ids)
Instrumentation and Control Diagrams (ICDS)
-
Electrical wiring schematics, Mechanical system process calculations.
'
Instrument setpoint and attendant scaling calculations,
Installation drawings, and
Interface documents
Since most of the specific numerical values and hardware items identified in 180 design documents require confirmation, the team's principal focus was on the adequacy of design methodology and criteria. The team reviewed Gibbs and Hill documents which had been validated by SWEC and new SWEC documents, the need for which had been identified by the validation process.
In this
!
manner, the team attempted to determine if concerns raised by the two generic issues, setpoint calculations and I&C separation, are being addressed. The I&C separation issue is being addressed in the Stone and Webster document DBD-EE-035, " Instrument Installation and Separation."
j The team reviewed the following items which were also reviewed by the EFE group: DBD-EE-037; Setpoint Calculation 10-032; Scaling Calculations SC-48-09, SC-48-07, and SC-48-05; and selected flow diagrams and ICDS. Other documents were reviewed for the above systems based on random selection from documents
.
which had been validated by SWEC.
]
2.
Trends The following trends were identified by the team:
l No major design or installation deficiencies were identified.
In general, the various setpoint calculations for flows, levels, pressures,
'
j and temperatures use consistent methodology and conform to the applicable
{
'
design criteria.
The EFE review has been identifying procedural non-compliance items for
the validation process.
The two generic issues are being addressed by the validation process.
,
Minor deficiencies, such as typographical and drawing errors are being
identified during the validation process by the yellow line (line by line) review method.
3.
Open Items:
Open items identified by the team either required further evaluation /
clarification or involved inconsistencies or anomalies. These were as follows:
- 42-
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<
a.
' Inconsistency between-mechanical process.and ISC input parameter L
values'(0penItemI-1)..
<
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Effect of: instrument error'in piping design or system' performance
-!
i (0 pen Item'I-2).
l
,
Location of Condensate Storage Tank level sensing tap (0 pen Item 1-3).
c.-
y d..
Issues concerning the control room complex, such as inconsistent
- nomenclature in documents (0 pen Item I-4), potential leakage. paths -
from air.' conditioning piping-(0 pen Item I-5), and the-apparent inability forfpersonnel to move from the Train A to Train B' mechanical
,
U
. equipment room without exiting-the control. room pressure boundary j
(0penItemI-6).
e.
ForL the chemical additive tank, setpoint and scaling calculations were -
inconsistent.with respect to level transmitter range (0 pen Item I-7),
-
and drawings showing physical-installation of these level transmitters q
are not adequate to ensure' proper installation-(0 pen Item I-8).
~
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y l
f.
The DBD on instrument installation and-separation does not provide adequate. guidance to minimize the potential for common mode failure of
!
instrumentation. impulse ~ lines and to ensure required separation
.(0 pen Item.I-9).
,
4.
Engineering Functional Evaluation (EFE) Results-j The team discussions with EFE I&C' personnel indicated that they are performing an.in-depth' review of the I&C aspects potentially affecting functional per-i formance of the systems. The team did not identify any specific: area' requiring l
expansion of EFE activity.
l 5..
Additional Review As' indicated above, most of the 180 setpoint and scaling calculations require confirmation of-input mechanical process parameters.
During future inspection
. activities, the team plans to review 180 calculations which reflect completion-of this confirmation process,
!
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1x ij Instrumentation and Controls - Evaluation of Documents \\ eviewed
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DOCUMENT, NUMBERS:'
&,
y 3., y m
-
'DBDQG-037hRev.O,datedJune 23, 1987
-*
iy
"ByP%fetySalatedSetpoints"
,
,
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.
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.
D 23, 1987
j Q r' p "
EE-032, Rev. 0-A, dated June l
--
logf atrols and scaling" Rt.LAQD,GEt/$HICISSUE:
P 2.
(
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-
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.q.
Setpoint' C&MIations
'
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p 3.
Y!GNCRITERIA:
i.
'
.A.
Criterion 13 " Instrumentation end Control" in 10CFR50 Appendix A requires that instrumentation be. provided to m'onitor variables and systems and that controls be arranged to maintain thoQ variables and systems within
~~
a
=j y
Oresc{ipedoperatingranges,
'A.B. 1Criter on'20 " Protection System Functions" in idCFRE0 Appendix A requires N
V that the' protection system be designed to Anitiate operation of appropriate e
[
d.1 systems to ensure that specified acceptabiff fuel design limits are not g
}aceeded.
,
\\
C.
ReviMbn 2 bf Regulatory Guide 1.105, " Instrument Setpoints," February 1986
"
It-describes'a method for complying with the Commission's regulations for
)7 ensuring that instrument setpoints in systems Important to safety are
'[of
'
H initially within and remain within the technical specification limits.
,
-
dc
D.
I$A-SO.04-19U "Setpoints for Nuclear Safety Related Instrumentation Used y
7;>1n Nucirqr Power Plants" defines minimum requirements for assuring that
,5
/j ph setpoirv:d are established and held within specific limits in nuclear
>
'
A V
U safetyhlated instruments in nuclear power plants.
&,,.
P
,0E,SJJh00CUMENTACCEPTABILITY:
.
Q
4.
/
tb<<':.
MV The subfict'DBD's reflect the above dItsign criteria. Their use of the statis-tical appruch of " square root af the sum of the squares" h similar to the apprpach utsd by Westinghouse /for the NSSS reactor protection md engineered y, safe h feehres actuation systems.
'
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. +
.
Q' These basic documents ensure that all BOP safety systems' instrumentation setpoint ar,4 scaling calculations are done in a consistent manner.
I
.
5.
ENGINEERING FUNCTIONAL EVALUATION RESULTS:
'
A)
The EFE review team has issued action item C0-3 against DBD EE-037 to correct / clarify the flow calculation procedure for tne first 20% of the signal.
.
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Document Number:
Calculation 10-028 Rev.
dated 8/26/86 " Motor Driven AFW Pump 01 Recirculation Flow "LO",_"HI-1", "HI-2" For Channel 1-FB-2456A/B.
,
!
2.
.Related Generic-Issue:
s l
' Instrument.Setpoint Calculations 3.
Design Criteria:
i The criteria set forth in RG 1.105 " Instrument Setpoints" and ISA S67.04
"Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power.
Plants"-are reflected in the calculation methodology.
'4.-
Design Document Acceptability:
I The SWEC validiation ' program-reviews each calculation for adequacy of. method.-
L The final input' data developed by the process group will be factored into the-subject calculation whan this data becomes available at some later date. The following. concern is based on preliminary data.
10 en Item I-1: Calculation IC-028 values for the input parameters for pump
!
flow 31ffer_ las shown below) from values found in process calculation 206-11..
This discrepancy in the original Gibbs & Hill calculations was not pointed out j
in the SWEC calculation validation review by either the I&C or the process group.
j 18C-028 206-11
!
l-FB-2456A E0 GPM 20 GPM
!
l-FB-2456B1-550 GPM 500 GPM l-FB-2456B2 650 GPM 650 GPM l
r 5.
Engineering Functional Evaluation Results:
This calculation is not subject t..r'E review.
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' Document Number:
. Calculation 10-032, Rev. O by Gibbs 8' Hill dated 10/9/86 " Containment Spray
- Pump 02 Discharge Header Flow" for Channel 1-FB-4773-1 A-DVP No. III.
.
T 2.
Related Generic Issue:
l Instrument Setpoint Calculations 3.-
Design Criteria:.
R.G. 1.105 " Instrument Setpoints" and ISA 567.04 "Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants" are reflected in the
. calculation methodology. The Containment Spray System DBD-ME-0232 Rev. 0, dated June 15, 1987 provides additional design criteria. Section 10.3.2. lists pump design capacity as'3000 GPM at 585 feet total dynamic head. Minimum pump flow is listed as 750 9PM. but 1C-032 uses 671 GPM for this parameter.
'i
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4.
Design Do_cannent Acceptability:
q The SWEC calculation validation record for this calculation and for the other three in this family of calculations (IC-030, IC-031 and 10-033) recognizes the
..
discrepancy in minimum flow parameters. This discrepancy could-impact the scaling calculations 5C-48-08 Rev. 2 thru SC-48-11 Rev. 2 as well as Section 6.7 of the DBD-ME-0232 and other project documents.
,
Open Item I-2: The percentage of error in the instrument channels could increase the nominal minimum flow-rate from 750 GPM to 950-1000 GPM. This higher flow
,
rate should be evaluated for potential impact on the piping design and system
performance.
5.
Engineerig Functional Evaluation Results:
The EFE review team issued.two action items CO-03 and C0-06 which challenge (1)
the basic calculation method for flows, (2) the I&C equipment list related data which is not supported by identified formal calculations, and (3) the mechanism for transmitting calculated data to plant maintenance and operations personnel.
,
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- Document Numbers:
1..
TA.
Calculations
- 1..
2323-206-5'- Reyb l
" Condensate Storage Tank Volume"
,
,2.
2323-206-11,.Rev. 0, " Auxiliary feedwater Setpoints" (2478 8.'2479)
'3.-
16345-ME(B)-006-XXX,." Auxiliary Feedwater System - Misc. Setpoints" 14.
IC-036, Rev. O, " Condensate Storage Tank Level" Channel 2478 L5.f LSC-37.-10,'" Condensate Storage Tank Levels" Channel 2479
.B.
. Drawings-l'.
- ECE-M1-0206-02, CP-3, Flow Diag. -. Auxiliary Feedwater System Yard Layout -
2.
2323-M1-2206-07_-CP-2, I&CD Auxiliary Feedwater System Channels 2478 8'2479'
-3.
- 2323-M1-2634-CP-1 " Yard Instrument Location and Air Piping" 2..
Related Generic Issue:
Setpoint. Calculations 3.
Design Criteria:
FSAR Section 10.4.9.2 commits to reserving 276.000 gallons of. water in the Condensate Storage Tank (CST) for:the Auxiliary Feedwater System. The CST level is' described in the FSAR Table 7.5-5 as a " key" function in the variable
' type D category 2 instrumentation (Ref. R.G. 1.97).
4.
Design Document Acceptability:
' Three instrument channels-2478, 2478-F, and 2479 monitor the CST level for control and indication. purposes..The associated drawing; show that the location ~
of thellevel sensing taps is 0.75 feet above the suction of the auxiliary feed-
.
water pumps. Accepted industry practice is to have the level monitoring sersing points on-tanks or vessels equal to or lower than the lowest process connection.
Open Item I-3:
Instrument channel 2479 is not capable of providing control room indication for the total CST' useable fluid. The current sensing location
~
provides indication of 267,000 gallons of the required 276,000 gallon reserve based on process setpoints (206-11). This concern also applies to loops 2478 and 2478-F. ' The process calculations are not complete at this time. A new calculation 16345-ME-187 is being developed to address level setpoints.
Scaling calculation 50-37-10, Rev. 0 (channel 2479) and the setpoint calculation for channel 2479 are being validated at different times.
In order to ensure consistency for this parameter, the team recommends that EFE review this area.
5.
Engineering Functional Evaluation Results Not reviewed by EFE team.
- 48-QL _
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Document' Number:
Control Room Habitability, DBD-ME-003, Rev. 0, (Undated).
Control Reun Air Conditioning System, DBD-ME-304, Rev.- 0. Dated July 31, 1987.
See. reference drawings below.
i 2.
<Related Generic ~ Issue:
None 3.
Design Criteria:-
The habitability of the control' room complex is addressed in Section'6.4 of the Standard Review Plan.
4.-
Design Document' Acceptability:
The reference document package is undergoing validation by both EBASCO and SWEC concurrently. The team had the following concerns:
FSAR Sections 6.4.2.1 and 9.4.1.1 and the DBDs are not consistent Open Item I-4:
in the definition of the areas called " Control Room Complex" and the nomenclature
. for the various rooms making up the control room complex.
O en Item I-5: The FSAR.Section 6.4.2 Table 6.4-4 doas not address the potential ea age paths created by piping from the supplementary air conditioning units
,
which penetrate the west wall (Col. Line A-A).
Also DBD-ME-304 does not state
!
that this piping is seismic.
O en Item I-6: The drawings in Table 1 do not provide sufficient information to cate whether personnel can pass from the Train "A" to Train "8" mechanical n
This could equipment room without exiting the control room pressure boundary.
be a problem if radiation levels are above normal.
5.
EFE Results These documents were not reviewed by EFE.
Reference drawings:
Area Drawing El. 830'-0" and 831'-6" 2323-Al-0509, Rev. 12, April 7, 1983 j
E1. 852'-6" amd 854'-4" 2323-Al-0510, Rev. 8 April 7,1983 El. 840'-6", Sections and Details 2323-Al-0512, CPI, (Date not legible)
El. 807'-0" and 810'-6" 2323-SI-0508, CP-1, November 4, 1983 Ventilation Auxiliary Building 2323-MI-0756. Rev. 9, May 12, 1982 Plan El 830'-0" and 831'-6" HVAC Supplemental Cooling for Computer 2323-MI-0770, CP-1, July 12, 1985 and Technical Support Center Area
- 49-
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, Document; Numbers:
1)10-026 Rev. 0::DVP'l-
~" Chem Add TK LO-L0 LVL" for 1-LT-4752 A/B
.
12) SC-48-07.Rev. 2: DVP l-111
-
Containment Spray Additive Tank Level"
"
3) 232-_14 Rev. 1
2.,
Related Generic' Issue:
(([
Setpoint Calculations.
3.
Desion' Criteria:
o A.
10CFR50 Appendix '"A" - Criterion 13 " Instrumentation and Controls" q
'B.
10CFR50 Appendix _ "A" - Criterion 20 " Protection System Functions"
.C._ Regulatory Guide 1.105, Rev. 2, February 1986.
..
D.
ISA-S67.04-1982L"Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants."
4.
Design Document Acceptability The: calculation methodology for setpoints is based on DBD-EE-037 which satisfies the design criteria. However, the following concerns were identified:
0)en Item I-7: Calculation 10-026 defines the range of LT-4752 as 0-112 inches,_
wille the companion scaling calculation SC-48-07 defines the range as 0-120 inches.
This requires verification of.the installed transmitters actual range. Equivalent calculations for level transmitter 4753 were not available to the team and should -
be reviewed for the same potential inconsistency.
,
The team reviewed the physical connections for the two level transmitters to determine if there were any problems relating to the generic issue on separation, and to determine how the tanx level was being measured. It was noted that-the pictorial representations on the flow diagram and the calculation are different.
!
The documents reviewed. included:
,
. Number.
Title 2323-M1-2607 CP-3, Instrument Location Drawing 2323-M1-2507-02 Rev. 7, Instrument Tabulation
,
2323-M1-2609.CP-2, Primary Connection Location
,
2323-M1-2104-06 CP-3, Instrument Detail Sheet
'Open Item I-8: _ The physical instrumentation documentation package does not reference a physical drawing defining the standpipe connections used to measure
>the level of the tank contents. The standard hook-up detatis (2323-M1-2104-06)
for flow measurements (Detail 4G) is very general for a differential pressure measurement taken on a standpipe.
Even with the supporting text in the stand-pipe " Instrument Installation & Separation" document (DBD-EE-035 Rev. 0) the detail is not adequate to insure a proper installation.
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EFE Results
' The team did not review EFE results.
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DOCUMENT NUMBER
p -t DBD-EE-035,.Rev. O, dated June 23, 1987, " Instrument Installation &
f
.Sepa ra tion" j
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2.
Related Generic Issue:
.
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I&C Separation &. Isolation
"
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3.
Design Criteria, IEEE. Standard'279-1971, " Criteria for Protection Systems for Nuclear Power.
Generating Stations,"'IEEE Standard 308-1974, " Standard Criteria for Class 1E
- Power Systems for Nuclear Power Generating. Stations," and R.G.1.75.. Rev.1,.
January 1975,." Physical Independence of Electric-Systems."
I 4..
' Design Document Acceptability:
1The subject.DBD compiles various project' documents, including the FSAR, which address criteria'for installation and separation.
The sections addressing.
' instrument installation are in accordance with industry-wide practice. Those addressing l separation in general agree with the design criteria stated above
- with the below exception.
'
Open' Item I-9: Section 5.2 of the DBD requires impulse lines for redundant 'instru-ments to have-a minimum ceparation in free air of eighteen inches in all direc-tions.
(The preferred aparation distance is five feet.) The directions for this preferred separation distance are not defined.
.l
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For impulse lines from a common tap which split into two or more lines serving
, redundant instruments, paragraph 5.2.6 of the DBD states '"There is no require-
- ment for barriers in the area between the point where the lines split and where
.the 18 inches of separation is achieved." The team considers that this. failure to provide barriers in the area where the 18 inches of separation is not met is
'not consistent with the governing criteria of IEEE Std. 279-1971 and its clari-
,
fication documents.
The DBD also states that "...the instrument tubing coming off a shared tap shall d
remain a single line as far as is convenient for field routing." The team' con-l siders that the DBD should provide more specific guidelines, e.g., restricting the length of the single line, in order to preclude comon mode failure.
i 5.
EFE Results i
This document was not reviewed by EFE.
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DOCUMENT NUMBER:
' Calculation No. SC-48-09. Rev. 2, dated July 6, 1987 " Containment Spray Pump t
02 Discharge Flow. -DVP No. 111 - Loop 1-F-4773-1 2.
Related Generic Issue:
+
Setpoint Calculations 3.
Design Criteria:
DBD-EE-0232 " Containment Spray System," Rev. 0, dated June 15, 1987, provides a. description of the functions ~, design requirements, modes of operations, arrangements, performance characteristics, and limitations of the containment j
spray system.
DED-EE-032 " Analog Controls and Scaling," Rev. 0-A, dated June. 23, 1987, describes
.
the design basis and functional requirements of the balance of plant analog l
controls, the bases for selected FSAR sections addressing functional per-formance requirements for various plant instrumentation and control systems.
and the methods for performing scaling calculations.
,
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4. -
Design Document Acceptability:
This calculation establishes the low flow alarm voltage setpoint alorig with the voltage setpoint for the interlock function associated with minimum flow recirculation control value 1-FV-4773-1.
Scaling is necessary to convert are volts direct current (Vdc) pressures and flows to analog signals whic engineering variables such as
.
The team reviewed the calculation based on the general criteria and require-The ments provided in DBD-ME-0232 and the method contained in DBD-EE-032.
low alarm and interlock voltage setpoints were calculated as 1.688 Vdc and
,
2.173 Vde, respectively.with t.025 Vdc accuracy. These values depend on The method used for this mechanical process values which require confirmation.
calculation is in agreement with design criteria and requirements provided in the DBDs.
5.
EFE RESULTS:
EFE concluded that this calculation was satisfactory. However, they questioned how the results of these calculations will be translated into documents and/or a language that operations and maintenance personnel will understand.
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~ DOCUMENT NUMBER:
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i Calculation No. SC-48-05, Rev.1, dated June 24, 1987,' " Containment Spray
. Pump 02 Discharge Pressure" - DVP-No. 111 --1-P-4775-1
.
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.2.
~Related Generic: Issue:
,
Setpoint Calculations 3.
Design Criteria:
DBD-ME-0232. and DBD-EE-032' provide a system description, functional requirements,-
performance characterization, design bases' for selected FSAR. sections, and a
.
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. scaling calculation methods.
4.-
Design Document: Acceptability:
Instrument loop 1-P-4775-1 monitors containment spray pump 02 discharge pressure,.
~
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and 'provides: indication of this; pressure.via a vertical indicator and the
<
station computer.. This calculation establishes a scaling factor for the vertical ~ indicator and the computer input card.. For both of these items,.the calculated: scaling factor is 40 psig/Vdc. Accuracy for the indicator.and computer are' provided as *2 percent and t.5 percent of span,-respectively. The method used for this calculation is in agreement with the design criteria and requirements, i
5.
.EFE Results:
.Same as for Calculation 5C-48-09, page 41.
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DOCUMENT NUM8ER:.
Calculation No. 5C-37-24, Rev. 2, Dated July 6, 1987, "MotorLDriven Auxiliary
')
Feedwater Pu:nps 1 & 2 Discharge Flow" -DVP No.11H 1-F-2456 81-F-2457.
I 2.-
Related Generic Issue:
Setpoint Calculations 3.-
Design' Criteria:
.
DBD-ME-0206 " Auxiliary Feedwater' System," Revision 0, dated March 13, 1987, and DBD-EE-032 " Analog Controls and Scaling," Revision 0-A, dated June 23 1987 contain design bases and scaling calculation methods along with specific design requirements, performance characteristics, and modes of operation for the AuxiliaryFeedwater(AFW) System.
4.-
-Design, Document Acceptability:
' Flow instrument loop.1-F-2457 monitors motor driven Auxiliary feedwater Pump 02 discharge flow and provides indication via a flow indicator and the station computer in the main control room. -In addition, this instrument loop provides
.LO, HI-1, and HI-2 control interlock functions to flow valve FV-2457. This
'
valve serves as the minimum flow recirculation valve for motor driven Auxiliary Feedwater Pump 02.
The scaling factor for the indicator'and computer was calculated to be 90 gpm/Vdc'
with an accuracy of tl.5 percent of span (900 gpm)'for the indicator and t.5 percent of span for the co:nputer. Using the numerical values from Setpoint.
. Calculation.No.10-029, the LO, HI-1, and'HI-2 voltage setpoints were calculated to be.878 Vdc, 5.789 Vde, and 6.900 Vde, respectively, with an accuracy of t.25percentofspan~(10Vde). The values appear reasonable. However, they depend upon mechanical process values, which require confirmation.
The team found that the calculation methodology-conforms to the design criteria and methods provided in the identified DB0s.
5.
EFE Results:
The AFW system is not included in the EFE scope of review.
The team addressed the EFE system selection process in the Introduction and Sumary.
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vocUMENT NUMBER:
. Calculation'No.-SC-37-22, Rev. 2. dated June 24, 1987, " Motor Driven Auxiliary c/
' Feedwater Pump _ Station Pressure," DVP.No.11H 1-P-2476
1 Y
- 2.
~Related' Generic Issue:
,,
y
,
-Setpoint' Calculations.
,
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i
- 3.
- Design Leiteria:
e
.DBD-ME-0206 " Auxiliary Feedwater System," Revision 0, dated. March 13, 1907 and DBD-EE-032 " Analog Controls and Scaling," Revision 0-A, dated June 23, 1987 Lcontain design; bases and criteria. scaling calculation methods,.and. design requirements.for this' calculation.
4 ~..
Design Document Acceptability:
'
Instrument loop 1-P-2476 monitors the process fluid pressure at motor driven -
auxiliary feeduster pump 02 suction and provides. indication via a. pressure
,
'
i indicator and station. computer in the. main control room. 'In addition, this loop provides a control interlock ~ function'for the attendant pump motor circuit breaker.-
j The calculated scaling factor for the indicator and: computer input is 2.5 psig/Vde'with an accuracy of *1.5 percent of span (25 psig) for the
~ indicator.and t.5 percent of span for the computer. The control interlock voltage setpoint was calculated to be.896 Vdc with an accuracy of t.25 percent of span (10 Vde). However, the interlock voltage value was
' calculated using.an instrument setpoint value of 2.24 psig which requires i
confirma tion.
The method used for this calculation generally conforms to the design-
,
criteria and methods contained in the DBDs.
5.
. EFE Results:
The AFW system is not included in the EFE scope of review.
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Electrical - Sumary
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I Electrical
'A..
Inspection Sample In'the electrical discipline, two generic issues have been identified:
' calculations and physical independence.
Since the validation effort for the physical independence area had not progressed.sufficiently, our review activities
.
were mostly limited to the calculation area.
At the time of our. review, EFE
had reviewed four. electrical calculations. Our review included two major calculations from these four: Class 1E Battery and Battery Charger sizing a
.'
calculation, and 480 Vac motor control center starter coil pickup voltage analyses.-
i Some of the. major electrical calculations, such as voltage regulation calcula-tions, were in.the vs'idation process.
For this reason, our selection of documents was some o t constrained. Of.the more than thirty validated calcula-
!
tions,' we selected eight major calculations for review.
-The team reviewed documents for the containment' spray and control room HVAC systems
- as a cross-check upon EFE reviews of these systems.
In the electrical discipline, there are no' separate calculations for these systems. However, the calculations we reviewed have a direct bearing on these and other safeguards systems.
j
- We also included some of th'e site calculations in our review sample. These calculations were very limited in scope since they relate mostly to cable pulling tensions and cable side wall bearing pressure. Other documents, such as. specifications and drawings, had not been validated. We reviewed these only for interfaces with-validated calculations. Our review included six Design Basis Documents (DBDs) and threo Project Procedures which were the basis for the calculations we reviewed.
B.
Trends Most of the design basis documents had been issued and provide the required
,
'
design criteria for the detailed system design and the calculations. Calcu-lations were genera 111y being.done in accordance with design basis documents (except as noted below) and were properly organized and documented.
C.
Open Items Our review resulted in a total of sixteen open items requiring action by SWEC.
These items can be grouped into the following categories with some items
. relating to more than one category.
Category Number of Items 1.
Inadequate Design Criteria
2.
Failure to Follow Design Criteria
3.
Inadequate Input Data
.
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Specific open items are' addressed below.
I.. Inadequate Design Criteria.
Open Items E-1 and E-2 relcte to' incorrect selection of the protective The relay settings.. It appears that the criteria were misinterpreted.
criteria required a-tap setting of 125%. The selected tap setting was 120%.
Since, in this case, completion of the safety function has a higher priority
.than equipment protection, the criteria should have stated a minimum of 125%.
- 0 pen' Items E-4, E-5, and E-6 related to the battery loading calculations.
Criteria need to be' established as to how to size the batteries for items such
,
. as' inverter ~ loads and diesel generator field flashing.
For the 480 Vac Motor Control Center (MCC) starter coil pickup voltage analyses,
~
Open Items E-10 and E-ll relate to significant assumptions concerning impedance These assumptions are not addressed
. tolerances. and minimum sustained voltage.
._by the design' criteria.
- 0 pen items E-13 and E-16. relate to the use _of steady-state current values,.
-rather than the in-rush currents in the direct ~ current (dc)' voltage drop The design basis document does not clearly state this require-calculations.
'For Open Item E-15, the design basis document is incorrect in requiring ment.
The contacts of use of J14 relays in;the switchgear close and trip circuits.
this_ relay do not have.the required current rating.
2.
Failure to Follow Design Criteria I
0 pen Items:E-3, E-7, and E-8 relate to high de voltage, due to battery float and equalizing requirements. The critoria document. specifies 125 Vde, whereas the actual normal de voltage will be between 130 Vdc and 135 Vdc. This con-tinuous' higher voltage can degrade connected electrical safety loads.
Open' Item E-14 addresses the fact that the voltage drop analyses have been performed for only 28 out of 290 circuits. Project procedures require that
-
all circuits be addressed.
l Open It' ems E-13 and E-16' relate to failure to address device in-rush currents
'
in the voltage drop calculations. The items were also included in the above category:because the team was uncertain as to whether lack of clarity in the
'DBD was responsible for the criteria not being followed.
3.
Inadequate Input Data Open ' Item E-12 relates to the use of incorrect input data in some of the The results of these computerized calculations for allowable wire lengths.
- calculations are used in various circuit analyses; hence the accuracy of input data is important.
Open Item E-2 relates to the motor protective relaying setting calculation, based on assumed data, when actual test data was attached to the calculation in the Appendix.
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In addition to the above broad categories, the team identified a generic concern with inadequate identification of items-requiring confirmation.(0 pen Items E-11 and E-16.) Some calculations have hundreds of items requiring confirmation.
D.
EFE Results s
Our review overlapped EFE for the 125 Vdc. battery and battery charger sizing.
calculation. Our Open Item E-3 relates to the de over-voltage problem caused i
by.a 60 cell battery. EFE, in their review, hinted at the inadequate justi-i fication in the calculation regarding selection of the number of battery cells.
j lt appears that.the EFE review was not detailed enough for interfacing documents, j
such as battery loading calculations, battery charger specifications, and' the
' 7.2 kV switt.hgear specifications. EFE did not identify our Open Items E-4 l
- through E-9, which all relate to battery sizing problems and.their impact on l
'
the associated equipment and resulted from our review of the interfacing documents.
When reviewing ~a calculation, EFE should also review its impact on the system
,,
design / equipment specifications.
q We'also' overlapped EFE effort in the area of 480Vac MCC starter coil pickup voltage analyses. Our Open Items E-11 and E-12 regarding major assumptions and data errors are similar to the items identified by EFE.
Both of our reviews found this cal:.ulation unacceptable.
. We believe the EFE effort needs to include additional important electrical calculations, such as Calculation 069 " Direct Current Voltage Drop."
q E.
Additional Review i
l-The following areas need additional team reviews:
1.
Some of the major electrical calculations, e.g., voltage regulation, which, at the time of our review, were still in the validation process.
2.
The EFE sample available for review was quite limited.
Some additional items
,
l that have gone through the EFE review need to be audited.
3.
Most of the calculations we reviewed had a large number of items requiring confirmation. The confirmation' process for those items needs to be reviewed.
4.-
At the time of this audit, SWEC had yet to address and completely document
'
the generic issue relating to physical independence / separation. This should include resolution of electrical independence and separation problems l
at the site.
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Electrical -- Evaluation of Documents Reviewed l
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Document Number:
.
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Calculation Number 16345-EE(B)-031. Rev. 0,' dated 5/19/87, Protective Relay Settings for 6.9 kV Safeguard Buses
't 2.
Related Generic' Issue:
Calculations;
'
'
3.-
Design Criteria:-
y DBD-EE-051,' Rev. 0, ' dated July 10, 1987, " Protection Philosophy" This document.provides the criteria for _ protective relay settings for the n
electrical. equipment. _ The criteria for the overcurrent relay setting for' the 6.9 kV Class lE motors:is provided in Section 5.1.3.28 which states, "The pickup ~ of time Unit 51 i~ set at 125 percent of full load current.....".
Contrary to _ industry practice, the DBD does not indicate.:that the long-time
'
~
overcurrent protection for the safeguard motors is set at a minimum of
."
.125 percent of the full load current. For the safety-related. loads, per-formance of safety function.should be given priority over motor protection.
This minimum; setting assures that the motor will support its safeguards
!
load to the extent practical.
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4.
Design Document Acceptability:
' Stone & Webster Calculation Number 16345-EE(B)-031 has been performed to supplement and to validate calculation TNE-EE-CA-0008-265 which had addressed relay settings for all the plant motors.- This calculation is-in accordance with DBD-EE-051 and addresses relay tap settings for the component cooling water pump 1,000 HP motor and the containment spray pump 700 HP motor. We l.
found that the overcurrent relay tap setting for the 700 HP motor had been
.;
E calculated properly, including addressing the load on the motor during the j
worst start condition. The tap setting of approximately 145% for this motor j
is acceptable since it exceeds 125 percent. Except for the following open j
items, this calculation is acceptable.
- ,
Open Item E-1
!
For the 1,000 HP motor, the overcurrent relay tap setting has been selected as l
'approximately 120%. This value is below the DBD value of 125%.
In order to l
eliminate'any misinterpretation, the DBD should clearly state that the l
overcurrent relay setting should be a minimum of 125% of the full load l
current. Also, the validation process should assure that this criterion is I
properly implemented for all the safeguard motors.
Open Item E-2 The calculations for both the 700 HP motor and the 1,000 HP motor are based on assumed values for the full load current and the locked rotor currents. The-test data values are available.
(SeeCalculationTNE-EECA-0008-265,Rev.O, Ref. 4.1, pages 3 & 13.) The use of assumed motor data in the calculation of final relay settings may not always provide a conservative relay setting.
The DBD should l
Calculation 031 should be updated to reflect the test data.
include a requirement to use test data where available.
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Engineering' Functional Evaluation Results:
'
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'The above calculation was.not included in the EFE review plan..
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Document Number:
Calculation Number 16345-EE(B)-053, Rev. O, dated 7/1/87, Sizing Verification -
Class IE Batteries and Battery Chargers.
2.
'Related Generic Issue:
Calculations.
3.
Design Criteria:
DBD-EE-044,'Rev. 0, dated 07/09/87, DC Power Systems Electrical Technical' Procedure, (ETP)-110.0.1-0, dated 01/30/81,
,
Verification of Lead Storage Battery. Size ETP-110.0.3-0, dated 10/05/82, Sizing of Battery Chargers These documents provide the criteria and methodology for sizing of de batteries and battery chargers'.
DBD-EE-044, Section 4.1.2.1, states that y
the de system is required to provide 125V de electric power to all Class.
l
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1E loads, with minimum and maximum system voltages of 105V de and 140V de, respectively. Further, the batteries are sized to carry the essential.
11 ads continuously, for a period of four hours in the event of a total loss of onsite and offsite alternating current (ac) power.
The battery chargers are sized to supply all the connected normal running load and to restore the battery from the design minimum charged state to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under all plant conditions. These criteria assure that the Class lE loads will be able to perform their required safety functions under all plant conditions.
>
4.-
Design Document Acceptability:
CalculationNumber16345-EE(B)-053hasbeenperformedinaccordancewith the above procedures. The battery ampere-hour capacity calculation follows IEEE Standard.485-1983. The battery charger calculation has also been performed in accordance with the required procedures.
The' calculation does not address how the number of cells required in each
~
battery were determined. The de system voltage under various battery operating modes (e.g., equalizing or float charging) is dependent on the
>
number of cells.
It appears that'the number of cells for these batteries has been based entirely on the system minimum voltage needs. Other para-meters, e.g., maximum system voltage, float voltage requirements, battery nominal voltage, equalizing voltage, and the time required to equalize, have not been adequately addressed. All these pararneters are directly
.
impacted by.the number of cells in the battery, and could have a signiff-cant impact on the operation and life of the safety-related equipment connected to the batteries.
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.0 pen Item'E-3
.
.The_ design basis document states that the battery normal voltage is 125V de, with a. range of 105V (minimum) and 140V dc (maximum)..The battery vendor l
.
manual, " Stationary Battery Installation and Operating Instructions",
requires that the battery be kept at a float charge level of 2.17 - 2.25V de per cell. :This will result in a normal de system voltage of 130.2 - 135V de
,
for a 60-cell battery. This higher voltage could lead to a loss of life
,
for the equipment designed for.the DBD required 125V dc normal voltage.
5.-
Engineering Functional Evaluation Results:
This. calculation has been reviewed by EFE. EFE~ hinted at the need for justification for a 60-cell size battery. However, no specific potential i
prob'lems associated with a 60-cell' size battery were identified.
It appears
'
that the EFE review was not detailed enough in the interfacing areas and, therefore,:did not identify) problems such as those found by the team (0 pen Items E-4-through E-9.
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- Document Number::
' Calculation Number 16345-EE(B)-037, Rev. O, dated 6/29/87, "125V de Load
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Study, Class IE"
{
2.
Related Generic' Issue: '
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i Calculations..
.
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- 3.
Design Criteria:
D60-EE-044, Rev. 0' dated 07/09/87, DC Power Systems
'This document requires;the de system to provide 125V de electric power to all Class 1E loads..No other specific-guidelines for t e. oad study have h l been' established. ' As per industry practice, Class lE batteries are sized to provide for the full rating of the NSSS inverters.
4.
Design 1 Document Acceptability:
The calculation is.well documented and comprehensive and meets the require-
- ments-of the design basis document, except as noted below:
Open Item.E-4
,
Batteries BTIE01 and BTIED2 have been sized for the calculated loads on in-
.verters'IVlPCl, IVlPC2, IVlPC3, IVIPC4, IVIEC1, and IVlEC2.. In order to allow for utilization of the full inverter rating, the batteries should be sized for the inverter rating.
In addition, it appears that the de power requirements' have been based on a 0.8 power factor load on the inverter.
The inverter load power factor can be between 0.8 and 1.0. The dc power needs should be based on the worst case power factor load (1.0) on the
~ inverter.
.Open Item E-5 Batteries BTIED1 and BTIED2 have'been sized to provide for the diesel generator.' field flashing current during the first minute of the battery
duty cycle. The battery capability should provide for the potential start j
'
of the diesel generator at any time during the duty cycle. As a worst case, sizing should provide for this load being added during the last minute of the battery cycle.
Open Item E-6
,
Batteries BTlED1 and BT1ED2 provide for a momentary load for a spring charging motor for only one 7.2 kV breaker. However, the diesel generator loading tables in the FSAR (Table 8.3-1A, Sheet 3) indicates breakers for
]
two containment spray pumps closing at the 25 second interval. Since these
'
two breakers close at the same time, the battery sizing calculation must allow for the momentary load associated with simultaneous operation of these
.
two spring charging motors.
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Engineering Functional Evaluation Results:
5.
Portions of this calculation were reviewed-by EFE during review of Calculation
.
16345-EE(B)-053.
It appears that the scope of the EFE review for this calcu-L-lation was quite. limited. EFE did.not' identify any of-the the above open
,
. items, l
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Document' Number:
Specification Number 2323-ES-88, Rev. 2, dated 11/27/86, " Battery Chargers, Isolation Transformers, and Accessories"
'2.
'Related Generic Issue:
"~
-Calculations.
,
'
3.
. Design ' Criteria :
D80-EE-044, Rev. O dated 07/09/87, "DC Power System" The battery chargers are required to supply all the connected normal running
- loads.while maintaining their. respective batteries in a fully charged state.
<
.In addition, they are required to equalize the complete-recharge of the -
)
batteries in a minimum length of time.
4.
Design' Document Acceptability:
This specification covers the design, fabrication, testing, and delivery of Class.lE and non-Class'lE battery chargers. Since this specification has
yet to be validated by Stone and Webster, we reviewed it only for compati-
!
bility with Calculation Number 1634-EE(B)-053, Rev. O dated 7/1/87, Class IE Battery and Battery Chargers Sizing Verification." The team identified the following items for the battery charger sizing and other technical data
!
concerning required voltages during float and equalizing charges:
Open Item E-7
,
The battery charger specification requires a float voltage range of 2.15 l
to 2.25 volts / cell. Since the battery need is 2.17 - 2.25 volts / cell,the specification is consistent with the battery requirements. However, the
'
,
l battery charger specification does not' indicate that the connected battery
,
L has 60 cells and, therefore, the battery requires a float voltage of
.130.2V to 135V dc (normal). The charger specification (in the Technical Data section) indicates charger de voltage regulation to be 128.6V-129.5V dc-(Item 10 on Sheet 4 of Appendix 4 to the specification).
It appears that the charger is not fully compatible with the battery needs.
Open Item E-8 The battery charger specification requires an equalizing voltage range of 2.30 to 2.50V de per cell. DBD-EE-044 requires the maximum system voltage l
to.be 140V dc, i.e., 2.33 volt / cell during equalizing, which is within the battery charger range. However, recharging the battery at this rate requires a time period of 74 to 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br />, or more. The battery vendor manual. requires, " Equalize the complete recharge of the battery in a minimum length of time....".
The charger specification (Paragraph 3.7.1.2.1) requires a 0-24 hour timer for the cell equalizing charge, which is inconsistent with the actual need
"
of,up to 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> or more.
Since the connected equipment is designed for
- 68-
_ _ _ _ _ _. _.
, _ _ _
. _ _ _ _
_
..
p Lh'~,
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I
'125V deJ(normal), keeping the equipment at the 140 volt. level for a long.
i-
'
L:
period could be detrimental.: Also, the charger specification should state l-the overall equalizing voltage requirements rather than just the per cell
,
voltage.
5.
' Engineering Functional Evaluation' Results:-
The above specification was not included in the EFE review.
!
,
-
,
i
69-
-
_ _ _ _ _ - _ - _ _ _ _ _
, _ - - _.
_
l l
1.
' Document Number:
-Specification Number 2323-ES-5, "7.2 KV Metal Clad Switchgear and Accessories" i
'2.
'Pelated Generic Issue:
i Calculations.
3.
Design Criteria:
This specification covers the design, fabrication, testing, and delivery of 7.2 kV Class lE Metal' Clad Switchgear Assemblies. Since this specifi-cation has yet to be validated by Stone and Webster, we reviewed it only
for compatibility with Calculation Number 16345EE(B)-053. The specifica-i tion requires that the de equipment be suitable for 125V (90-140 volts) dc
!
power supply.
4.
Design Document Acceptability:
Open item E-9-
'
The specification is consistent with Calculation 16345EE(B)-053 and requires However, the equipment suitable for op(eration up' to a maximum of 140V dc.Gould, Inc.)
data sent by the vendor motor is only suitable for 90-130V de operation (Ref. Calculation Number 16345-EE(B)-037. Rev. O, Appendix Page 13).
5.
Engineering Functional Evaluation Results:
The above specification was not included in the current EFE review.
'
.
- 70-
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_
--
i l
1. -
Document Number:
Calculation Number 16345-EE(B)-007, Rev. O, dated 6/10/87, 480Vac Motor i
i Control Center-(MCC) Starter Coil Pickup Analysis 2.
Related Generic Issue:
Calculations.
3..
Design Criteria:
,
DBD-EE-041 Rev. O dated 6/08/87, "480V and 120V ac Electrical Power System"
.0BD-EE-053, Rev. O dated 6/10/87, " Starter Circuit Parameters and Requirements" The starter control circuits are designed to preclude potential voltage drop l
problems at the starter. The minimum ac control voltage required at the l
Class lE MCC contactor holding coils is 75 percent of the rated voltage.for
the ' pickup voltage and 60 percent of the rated voltage for the dropout voltage.
j i'
4.-
Design Document Acceptability:
This is a well-planned and well-documented calculation. Each of the plant
'
MCC control circuits has been id6ntified as falling into one of approxi-l mately 41-different generic configurations of control power transformers, l
starter sizes, pilot lights, and auxiliary relays. A computer program calculates the maximum allowable wire length for each of the configura-tions in order to ensure that the starter coils or the interposing relays will pick up when the. bus voltage is as low as 422 Vac.
Open Item E-10 Page 4 under " Assumption and Conditions" refers to ANSI /IEEE Standard
'
C57.12.00-1980, Section 9.2. This standard is applicable to liquid-immersed distribution, power, and regulating transformers, and not to control power transformers. This reference is not applicable to this calculation-and should be deleted. The assumption of + 7.5 percent
'4 tolerance in impedance is not conservative for control power transformers.
Since these transformers are not manufactured to precise tolerances, we
'believe that the impedance tolerances should be t10 percent. However, we-do not expect this change to have significant impact on the calculation
!
results.
Open Item E-ll i
The calculation on Page 4 assumes " Minimum Sustained Voltage at an MCC Bus L
will ba 422V". This assumption is very important and forms the basis for the whole calculation. The basis of the assumption should be documented and included in the DBD. SWEC intends to confirm this assumption as well as some others in the calculation.
However, the calculation indicates that assumptions need to be verified, without identifying specific ones.
.
f
- 71-
- _ - _.
._ _
_
_
N f
-
f Open Item E-12 (-
Our. review of eight randomly selected coni'igurations' revealed problems
!
with the input data for two of those.
Configuration 7A1:
/
Page 464 of 1010 shows relay 42x as the other load.
Page 13 of 36 shows
~
this load to be R=78, X=91.19.
However, the maximum allowable circuit length calculation on Page 22 of 36 indicates the same load is R=39, Xu45.6.
Configuration 8C, On Page 32 of 36, the impedance values of the 200 VA control power transformer. are shown as R=.339 and X=1.085. Based on other data in the calculation, these values should be R=3.39, X=1.085. Even though this change will reduce the maximum allowable circuit length..it is unlikely-to require ar.y component changes.
In our random sample of eight configurations, we found input. data errors
~
in two cases. The input data for all of the configurations need to be
!
verified. There data errors. impact the maximum allowable circuit lengths
.
.which form the basis for acceptability for many circuits.
In some cases.-
e.g., the 7Al configuration, the error may have been conservative, and
some of the presently projected component changes might not be needed.
5.
Engineering Functional Evaluation Results:
The EFE evaluation had identified Open Items E-ll and E-12.
Because of the problems with the input data, they have not commented on the accept-ability of this calculation.
I
,
l
- 72-
_ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _
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1 l Document humber:
+
y
,
? Calculation' Number 16345-EE(B)-069. Rev. O dated 7/31/87, Voltage Drop Verification - Miscellaneous.DC' Control
,
,
i Sp
.2.
Related Generic Issue:
l l Calculations
!
,
3.
Design-Criteria:'
.;
,
.DBD-EE-054L Rev. 0 dated 6/10/87, " Control Circuit Parameters / Loading-Requirements"
,
DBE-EE-044, Rev. 0 dated 7/09/87, DC Power System"
.
t'
Project Procedure _PP-218, Rev. O dated 9/14/87, " Technical Procedure for Voltage Drop Calculation for AC and DC Control Circuits
"..
As' pe'r Section 7.1.2 of-DBD-EE-054, the following criteria are applicable-
-
>
to this. calculation:.
,
In order to ensure proper circuit operation, the voltage.at the device.
_
,
terminals must be above the' device's minimum operating voltage. The analysis
!
~1s based on the minimum available de voltage and the analyzed device's
.
in-rush current at its minimum pickup voltage.
In-rush currents of all the
' devices, including. indicating lights which may be energized' simultaneously, are. included in the analysis.
'
"
.
.
'4.
Design Document Acceptability:-
.
- 0 pen Item E-13:
-This calculation has been performed to verify the adequacy of available voltage at terminals for solenoids, relays, etc. On Page 4, Assumption #14,
,
states " Load currents used are rated currents, based on 125V de across the device...". The DBD requires use of device in-rush currents at its minimum pickup voltage.
It appears that the impact of this deviation from the DBD is non-conservative. The DBD needs-to be clarified because the calculation effectively assumes in-rush current to be the same as device steady state currents.
~Open Item E-14 This calculation identifies approximately 290 de schematics. Out of these, only twenty-eight were selected for specific voltage drop analysis. Pro-cedure PP-218 requires, "On:a panel-by-panel basis, the assigned circuits
. ill be addressed by length, loading, and minimum device voltage". The'
wcalculation should provide justification as to how the 28 analyzed circuits envelop all 290,.e.g., a list of circuits enveloped by each of the 28.
5.
Engineering Functional Evaluation Results:
No'EFE review was performed for this calculation.
- 73-
,
a _- = _-
_
1.
Document Number:
DBD-EE-054, Rev. O dated 6/10/87, Control Circuit Parameters / Loading Requirements, Section 7.1.5.
2.
Related Generic Issue:
None 3.
Design, Criteria:
The control circuits are required to initiate the closing and opening (tripping) of switchgear breakers. The electrical,eting of the relay contacts used in the breaker contr'l circuits is determined not only by their continuour current rating but also their make and break current capability, as upplicable.
4.
Design Document Acceptability:
Our review of the DBD was limited to the below area.
Open Itg E-15 The design basis document in Section 7.1.5 states, "The circuit breakers ure tripped via electrically resettable lock-out relays, ITE Type J14, located in the switchgear".
The contact rating for the Type J14 relays is not sufficient to trip or close 7.2 kV breakers. As per ITE, these relay contacts have a make and break rating of-1.1 amperes. The 7.2 kV breakers have a trip current of approximately 5 amperes. fherefore, the relays specified are not suitable for the application.
5.
Engineering Functional Evaluation Results:
No EFE evaluation was performed for this DBD.
l
- 74-
-_-_-____ _ _ - _ _ _ _ - _ _ _ - _ _
E
!
~
1.
Document, Number:-
Calculation ' Number 16345-EE(B)-002, Rev. O dated 1/19/87, Maximum
~
allowable conduit length-between pull points for cable pulling evaluation.
Calculation Number 16345-EE(S)-167, Rev. O datea-7/8/87, Maximum
'
allowable conduit length between pull points for multiple pull of 8 kV power cable.
J
'2.
Related Generic Issue:
!
Calculations
-
J 3.
Design Criteria:
The maximum allowable conduit length between pull points must be sucit that
'
the allowable conductor tension or the sidewall bearing pressure are not exceeded.
-,
4.
Design Document Acceptability:-
l
'The calculations are in accordance with the pull tension calculation methcd, l
per IEEE Standard 690. Charts have been developed which provide the maximum allowable. conduit _ length between pull points. The allowable' lengths shown
,
in-the charts are based on various factors, such as, coefficient of friction, j
different conduit sizes, equivalent conauit bends, different cable sizes, j
and multiple combinations.
The approach and methodology conformed to the design criteria.
5.
Engineering Functional Evaluation Results:
,
No EFE evaluation has been performed.
!
,
i o
- 75-L
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_ _ - _
- _ -
__
_
l
-Cs 1.
Document fug,t:
Calculation Number 16345-EE(S)-147. Rev. O dated.5/5/87 " Cable Sizing.
Calculation'- DC System" (Addition of de solenoid valves on' Termination Cabinet 1-TC-ll)
'
)
.2.
Related' Generic Issue:
,
Calculations.
g
-
3.;
Design Criteria:
~The voltage drop in the solenoid valve feeder cable circuits must be limited so that a minimum of 90V dc is available at solenoid valve terminals to assure their satisfactory operation.
J H
'
4.
Design Document' Acceptability:
Open Item E-16:. The approach and methodology used in this calculation conform to the design criteria. Although the results-are based on an
',
invalidated Gibbs & Hill calculation (Filing Code VII-8), the cover page i
of the subject calculation reads "no ~ confirmation required." Other site calculations should be reviewed to ensure that those which are based on
!
invalidated data are shown as requiring confirmation. Open Item E-13'
(Calculation 16345-EE(B)-069) concerning failure to. address device in-rush currents in voltage drop calculations is applicable to this calculation also.
5.
Engineering Functional Evaluation Results:
..
No EFE evaluation was performed for this calculation.
.
- 76-
- - _
._
1.
-Document Number:
Calculation Number 16345-EE(B)-049, Rev. O dated 7/1/87, "B0P SUPS
Sizing - Class 1E" l
..
l
2.
Related Generic Issue:
.;
Calculations j
3.
Design Criteria:
DBD-EE-043, Rev. O dated 7/9/87, "118Vac Uninterruptible Power Supply System" I
This DBD contains the design basis', functional description, design require-ments, modes of operation, and performance characteristics for Balance of
- Plant (B0P) Normal and Safeguards Static Uninterruptible Power Supply (SUPS) systems.
In addition, the DBD provides specific requirements and ~
performance characteristics for the 10 KVA Elgar inverter, which is the major equipment item for each of the four Class IE SUPS provided for each a'
plant (Unit 1andUnit2).
4.
Design Document Acceptability
This calculation was performed to verify that the actual Class IE B0P SUPS loads do not exceed the B0P SUPS output and protective device ratings.
Electrical one-line drawings indicate the association between inverter outputs and 118Vac instrument panel actual loads. The sums of these
instrument panel loads were used as the SUPS loads and the minimum trip I
ratings for circuit breakers were determined by multiplying full load current by 1.25.
This calculation shows that, for the present expected electrical loads (which require confirmation), each of the four Class i
1E SUPS and attendant protective devicas are adequately sized. Calculated i
spare capacities of 25%, 30%, 37%, and '40% are provided for Class IE SUPS
!
identified as IVIEC1, IVIEC2, IVIEC3, and IVIEC4, respectively.
l The calculation conforms to the design criteria and requirements provided in the DBD.
i 5.
EFE Results No CFE evaluation was performed for this calculation.
l I
i
-
<
- 77-l j
-
-
'
'
!
e 1.
Document' Number:.
(
DBD-EE-062, Rev. O. dated 6/10/87,- " Containment ~ Penetration Assemblies" f;
2 '.
'Related Generic' Issue:
'l
,
.None -
g
'l
,
,
l
- 3.-
Design Criteria:
=IEEE Standard 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations" and Regulatory Guide 1.63, Rev. 2 dated 7/78, " Electrical Penetration Assemblies in Containment Structures for Water-Cooled Nuclear
,
'
Power Plants," contain the principal design criteria-for protection of
-
containment electrical penetration assemblies.
i-4.-
Design Document Acceptability:
DBD-EE-062 provides design. basis,-functional descriptions, design require-ments, modes of operation, arrangements, and performance characteristics-
!
of containment electrical penetratio.: assemblies and protective devices.
A number of specific regulatory guides and industry standards are included
{
<
for establishing the design basis.
In general, the document indicates conformance to the applicable criteria
. -
provided in item 3) above. However, the first paragraph under Section 8.0
" Equipment' Description" on page 20. states: '
i
" Redundant penetration protective devices shall be qualified for 'their-intended purpose'and shall be ' electrically and mechanically independent. When shunt tripping is used, the redundant tripping circuits shall be independent and powered
!
from independent control power sources.
If two independent sources of control power are not available separate fused
~
branch circuits have been provided."
j s
It was not clear to the team that the last sentence of the above paragraph j
conforms to the intent of R.G. 1.63 regarding single failure. However.
!
since validated electrical schematics which show implementation of the
{
above paragraph were not available, this area will be addressed further by the team during additional inspections.
5.
EFE Results:
No EFE evaluation was performed for this design basis document.
l
l
.
1
- 78-
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_ - -. __ - _ _.
!
l.
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,
.
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Civil / Structural Sumary j
i i
(
,
- 79-
'<:
. _ _ _ _ _ _ - _ - _ _ - _ _ - _ _ _ _ - _ _ -
Ul
,
i x
.
.-
Civil / Structural t 1..
Inspection Sample The engineering and design. work being carried out for the~ Comanche Peak plant
- by Stone;& Webster Engineering Corporation (SWEC) is.to provide confirmation of'
the technical adequacy of the plant, as designed and constructed, and to..
,
provide' instructions to do remedial work if required. Under this situation,.the as-constructed structure, as identified by the design drawings and change documents, becomes.the: input for the structural analysis / design confirmation program,.11ong with'the FSAR commitments. The scope of this segment of. the structural audit' relates to the basic analysis and design of the Seismic Category I, Safety-Related Structures for overall building and member structural performance. This review does not address the analysis and design
,
of supports for pipe, HVAC ducts, conduit and cable trays, but does address-
!
i the incorporation of. equipment and component support weights and reactions as'
)
they affect the structural analysis and design, or are themselves affected by
"
. the approaches utilized in developing the building seismic responses. Basic FSAR criteria such as siting, flooding, seismicity and geological concerns were not reviewed.
The'SWEC verification work as presented is incomplete, requiring further work in two significant areas:
a..
Rework of. completed calculations to incorporate final loadings, which were
'
- not available or were approximated in the initial analysis / design phase. These
loadings are essentially those associated with subcompartment pressures and j
,
temperatures.resulting from postulated high-energy line breaks,. tornado i
' pressure drop transients-and verification of equipment and support loads, b.-
Development or completion of original verification calculations
'(calc 61ations not yet'available for review).
]
The initial thrust of this. review was directed towards confirming the transfer of.FSAR commitments into the SWEC " Design Basis Document" (DBD). The team l
considered this to be particularly important since SWEC has identified the
'
DBD's to represent a single (subject and/or building) document conveying
design basis information, technical requirements, technical descriptions on i
j how the requirements are satisfied, technical limitations and the explanation of methods for implementing the analysis and design. This was a typical DBD
" Purpose", under Section 1.0 " Document Basis". Since the bulk of the calcula-i tions require reworking, or are not yet complete, the team considered it
- important to the overall analysis / design program that the DBD's provide defini-tive direction for the continual, positive, uniform implementation of the q
analytical / design processes required to assure the proper confirmation of q
structural adequacy. The review of DBD's was coordinated with the review of J
calculations to evaluate the implementation consistency of the established analytical / design criteria.
j f
'
I
- 80-
_____ -
l The review'of calculations examined the overall analysis / design approach for l
!
consistency with the DBD requirements, application of engineering concepts and principles, incorporation of loading requirements, and interface with other supplementary calculations. Each calculation reviewed was essentially followed
,
through to track the course of analysis and/or design from the intial assumptions and references, through concepts and steps of engineering / design application,
.to the conclusions reached. -Contributing calculations were investigated to various degrees, depending on the significance of their input to the subject calculation being audited. Spot-checking of design drawings was done on a limited basis to confirm their use as calculation input. The scope of this review did not include a rigid checking of numerical results, but did include nominal numerical checks as deemed necessary to substantiate calculation steps, approaches, etc. Rigid checking of the calculations is a function of the basic
. analysis / design work and inherent in the designer's responsibility to certify the validity of the completed design.
Table 1 indicates the NRC review sample as it relates to the populations of SWEC validated documents and EFE's review sample. The team planned to review I
about 50 percent of the documents to be reviewed by EFE. However, since the
."
team only reviewed documents which were technically complete with respect to l
SWEC and EFE activities, only 7 of 31 documents in EFE's scope were available
!
for NRC review. Documents reviewed both by the team and EFE are indicated in l
the report details.
!
l The calculations reviewed by the team were selected from calculation title q
listings to achieve representative samples of dynamic and. static analysis
and design work on various structural components such as walls, slabs, roofs, l
beams, columns, foundations, and tanks.
In certain cases, two sets of calcula-tions for the same structural component type, but performed by two different l
i designers, were selected to evaluate the understanding and consistency of the design process.
l
l l
l
)
i
L
1
,
.
l l
l
- 81-
l
_ _ _ - - _ _
... -_
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i
'
Tabl'e l.'1, NRC Review Sample i
- Document.
-SWEC
___
Ty)e-
. Total Avail.
Planned Comp 1.
Plar.ned Avail.
Comp 1..
~
DB)s T
6
10
5 H.O. Cales.
Auxiliarypid_g.
12
Concrete
'31
-
-
. Steel
-
-
-
-
-
-
-
SafeguardsB3 Concrete.
23
2 13.
3
.,' ' ~
4 l
Steel
-
--
-
-
Serv. Wtr. B_Idg.
1
.
3 TnIaTe
-
-
-
Missile
'
2 Barrier
-
-
-
-
a Fuel Stor.- B,_ldg.
d
2-
-
Concrete
5-
-
-
- Steel-
1
-
-
-
-
-
Tanks-
~1 1-Concrete-
3
-
Tunnels h Sum. )-
1
-
-
-
-
-
Ductbanks-h Sum.)
1
1
-
-
>
, Reactor - Int.
Concrete-44
-
-
-
-
-
- Stee)--
_2
-
-
-
-
-
-
React. Cont.pidg.
l I
Liner
1
-
-
-
-
-
-
-
-
l
' Hatch
-
-
-
-
-
'
Shell
1
-
-
-
-
Doc. Review
1
-
-
-
-
-
Gen'1 Analy.
TATTB1das.)
13
1
4
i i
2
'
f Embedment
2
-
-
-
11'
9 Site Cales.
83
-
-
Total 273 175
7
49
-!
'
-All' Documents l
S4
)
- 82-f
- - _ _ _ _ _ _ _ -
. _.
_
{
- _______
'
,
_
2; Trends'
y'
As a whole, the SWEC design / construction verification has been approached on a systematic, detailed basis,= essentially.providi g all new-calculations to
"
demonstrate the adequacy of. the constructed plaat. Along wiO good analytical
y l methods, standard design code and DBD requirements have been well implemented in
)
' development of calculations, except for isolated situations.
l
-
l-Much of the design verification work has proceeded prior to being able to establish'the final loadings on the structures.
For these situations, loads considered to conservatively envelope the estimated final loads were used to enable the confirmation work'to proceed on an' expedient basis. The iterative process of utilizing.intorim estimated loads hat' been well-documented and a-tracking _ procedure implemented to insure that the calculations with open loading considerations will be revisited for confirmation and/or reworking.
3.,
Open Items The below paragraphs group the Open Items identified for DBDs and calculations on the basis of generic similarity. Paragraph 3.3 covers miscellaneous items not falling into a generic grouping. Table 3.1 cross-references these para-graphs with Open Items and the related calculations /DBDs..
3.1 Lack of Analysis / Design Instructions _
!
The DBD's are identified as the " single source" document for coordinating and directing the analysis and/or design covered by that particular DBD. Due to the apparent schedular pressure, DBDs are_being developed in parallel with-the design confirmation work. The DBD's presently governing some work
)
basically contain only design commitments relative to identifying standard
'
. design codes, load definitions, and loading combinations, as given in the FSAR.
'l Sections variously headed to contain design methods and philosophy have been identified to "be written prior to the completion of the Corrective Action Plan".
,
Although the design confirmation for missing loads'can be done at a later date,
<
the approaches for implementing classical engineering principles are independent of specific load values and should be established from the start to provide-uniform directions and consistency to the analysis / design process. Major segments of analysis / design work have been implemented and/or completed under DBD-CS-074,
-083, and -084, without the formal establishment of approaches to be taken, or the identification of non-code specifics unique to the design of the plant.
Under this situation, the work has proceeded under verbal instructions and/or
'the discretion of individual design teams or personnel. The major portion of calculations have yet to be completed or reworked to factor in final loadings, and no assurance can be made that the same personnel will be involved and/or that the same verbal instructions will be given. Written directions should be established promptly to ensure consistency in design methodology.
The following items represent situations where the lack of specific instruction l-has resulted in inconsistencies (though not necessarily errors) and in some
!
cases errors in analysis / design implementation.
p
>
- 83-
- - _ _ _ _ _
_ _ _
l a.-
1.5'Siesmic Factor FSAR' Section 3.7.B.3.5 identities the Regulatory Guide 1.100 requirement that
- a static coefficient of'l.5'be used for equipment analysis"..._and...
"
" verifying structural integrity" unless a different'value is' justified. The review of Auxiliary and. Safeguards Building calculations indicates that this 1.5 '
ifactor was not' utilized (nor a different value justified) in determining equip-Ement reactions used in the design of the supporting floor slab.
This is 1 typified in Calculations CS(C)-070 -074, & -078.
However, inspection of-site-generated Calculation Set CS(S)-030 indicated that this requirement was
. appropriately incorporated (0 pen Item C/S-2).
p b.
Live Load Incorporated in Seismic Analysis n
Traditionally, only 25% of the live load is used in load combinations which include earthquake factors. This approach-is so stated in the DBDs.
In addition, the DBDs classify hydrostatic bads as live loads and state " Flat roofs with continuous: parapets Mall be designed for eight inches of standing water caused by the probable a ximum precipitation. The team k.s concerned that the standing water criterion is inconsistent with treating such loads as
,
{
live loads.
Designers have implemented this load application differently.
In the case of the. Safeguards Building roof, only 25% of the hydrostatic load was used as a live load in combinations with an earthquake; Three tank designs were reviewed and it was found that the roofs of these tanks, which do not have parapets.
were designed utilizing 100% of the hydrostatic live load. Review of the Auxiliary Building calculations indicated that the roofs with parapets were interpreted to require the utilization of 100% of the hydrostatic. live load.
c.
Tornado Depressurization on Sub-Compartments
,
'DBD-CS-081, Section 7.0, establishes that " Seismic Category I Buildings (with the
'
exception of the Containment) shall be vented to the atmosphere in the event of a tornado," but does not provide directions for the analysis / design approach to account for the effects of depressurization in the building sub-compartments.
As a result of this lack of direction, the Safeguards and Auxiliary Bu4ldings were designed using two different (although satisfactory) approaches ta sub-compartment wall design (0 pen Item C/S-14).
d.
Containment Liner Design DBD-CS-074 did not supply the accident temperature criteria, which represents significant loadings in liner design (0 pen Item C/S-9).
3.2 Amplified Response Spectrum ( ARS) Implementation ARS for the various buildings have been developed for discrete structure elevations. These ARS are used in the seismic analysis of structural elements and piping systems, development of equipment reactions, etc. At present, the vertical and horizontal ARS are considered to be applicable at any location throughout the defined model elevation, assuming that the floor or wall system out-of-plane stiffnesses are such that their frequencies are in the rigid range
"
and do not further amplify the given ARS. Accordingly, the seismic analysis of
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i
equipment, piping systems, etc. is independent of the out-of-plane stiffness of the floors and walls. Justification is required to substantiate the rigid assumption for the floors and walls (0 pen Item C/S-4).
DBDs provide no direction relative to the use of ARS for steel framing systems for II/I considerations or coupling of equipment and/or piping systems, etc.
for seismic analysis (0 pen Item C/S-5).
3.3 Miscellaneous The following items are considered to be non-generic, non-trending, isiolated situations.
3.3.1 Analytical Model_ig g Hydrodynamic Loads The effects of hydrodynamic loading were incorporated in the " Reactor Make-Up Water Storage Tank" calculations (Calc. CS(B)-172) on the basis of a governing condition determined by comparing the overall effects at the bottom of the tank for two different loading approximations. The more conservative of these loading approximations was then utilized in a computer program (Shell 1) to find the design forces in the tank walls.
The means used to apply the hydrodynamic load essentially coupled the average water mass to the tank walls by increasing the wall weight and applying a
" horizontal seismic acceleration". This load modeling approach is not considered to be representative of the actual behavior of the system since it effectively causes the water to act in tension and shear on the walls on the back side of the seismic directional components.
Further, the original comparison to find the governing load approximation utilized the axial loading in the walls, whereas the horizontal effects of the hydrodynamic loading will also cause bending in the
,
'
vertical and horizontal planes, which was not evaluated.
Additional work is required to ensure that the application of the hydrodynamic loading on the tank walls has been conservatively addressed.
(0 pen Item C/S-8).
l 3.3.2 ASME Liner Code Provision Provisions of ASME Section III, Division 2, Section CC-3750 for through-the-thickness attachment design parameters have not been included in 08D-CS-074 for the attachment of the crane girder bracket (0 pen Item C/S-10).
3.3.3 Governing Stress Conditions In the calculation for Safeguards Building roof slabs, panels were selected to evaluate maximum bending and shear conditions. The panel selected for checking the critical shear stress did not represent the worst condition for shear, which was apparently on a panel with large numbers of penetrations near the faceoftheslabsupport(C/S-3).
.
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! 'k ETABLE 3.1
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tOPEN ITEM INDEX u
'Open LSect.
'
' Item. 3 para.
!
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-
- C/S-
' DBD Calc.
Subject y
.'
'CS(C)-070
.Use of ZPA for equipment reaction
'
load without' justification.
2-3.1.a CS(C)-070'
Omission of 1.5 multi-mode factor for ;
j
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seismic load estimate, j
i
-3.3.3'
CS(C)-070 Incorrect worst case slab panel
!
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'
'
investigation.for shear loads.
'
4
,3.2 CS(C)-006 Floor and Wall'ARS'Implemen-tion.
- 3.2 CS(C)-006 Structural Steel ARS Imple-
,
-
mentation.
,
. -.
EM(S)-009 Glastic partition addition i
'6 to MCC without II/I Review.
j i
EM-(S)-Oll
" Record of Confirmation" does not 7'
,
include" validation of G&H loads..
8 3.3.1
.CS(B)-172 RMW storage tank hydrodynamic 1oad ' computer input.
L
3.1.d-CS-074
. Accident temperature criteria-for liner design.
3.3.2 CS-074 Thru-the-thickness liner attacn-
ment parameter not addressed.
]
3.1.b CS-081 Direction required on handling of roof rain load.
CS-083 Attachment 2 & 4 missing, but
'[
not identified is, such.
l s
CS-085 Allowable stress increase not in
FSAR, but shown in para. 4.1 f,DBD.
3.1.c CS-081 Lack of direction regarding handling
.
of tornado depressurization.
l 115 CS(C)-006 Moment of inertia calculations for
!
the stick model require confirmation l
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- 4.
EFE Results'
EFE has scheduled. twenty-five calculation sets and six Design Basis Documents ~
!
(D8D's)'fortheir. review. Of these, EFE completed its review of only two
!
calculation sets and five D80's. The.. team reviewed these.latter documents.
(
i j
The team's review of the EFE results.and its independent review of the documents (
reviewed by:EFE indicates that EFE findings have been oriented towards documenta-
. tion comparisons, as opposed to engineering concepts, applications and completeness of technical requirements, and analysis / design instructions.
,
'
- If the.above observations are indicative of the charter of EFE's scope, then
- additional efforts should be made towards including more technical depth in.
- document examinations. However, it is noted.that the team's observations
- may not have been representative of EFE effort, due to the limited progress by EFE at the time of the team's review.
5.
Additional Review Section 1 describes the team's process to select documents for representative sampling of the. engineering design work. Approximately one-third of the identified project documents were targeted for review. Since many of the
<
targeted calculations'were selected by title reference only, the calculations identified for audit should.be re-evaluated by the team based on 0 perusal of the actual document contents, and its then known significance. The sample
!
distribution,' document avai' lability, and team completion status are given in Table 1.1.
About one-quarter of the targeted documents have been examined. Calculations for the Reactor Containment Building, containment internals, and liner were not dvailable. These and others within the targeted sample should be reviewed when available, including documents-to be reviewed by EFE.
The team will review the methods used in addressing generic open items, and the means of incorporating final loads in previously " completed" calculations, e.g. by tracking through numbers of inter-related calculations.
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Civil / Structural - Evaluation of Documents Reviewed t
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1.. -Document Number:
'
SWEC Calculation Number 16345/6-EM(S)-009 Rev. 0
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- 2. -
Related Generic Issue:
]
- (H) Miscellaneous Supports (Equipment)'
,
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3.
Design Criteria:
Regulatry Guide 1.29, Postion C2,. states in part, "Those portions of structures, systems, or components whose continued function.is not required,-
l but whose failure could reduce the functioning of any plant feature'.......
i should.be._ designed and constructed so that the.SSE would not cause such failure".
'4.
Design Document Acceptability:
j Open Item'C/S-6:
A "Glastic" material' partition was installed in the Auxiliary Relay cabinets
.,
to provide electrical. separation between wire bundles of different electrical j
. trains. The "Glastic" partitions were added as a modification after the s
original. seismic _ qualification was completed.
l (
The calculation determines whether there is any effect on the seismic qualifi-
{
cation of the cabinet due to the modification, and provides instructions for the i
handling 'of mounting screws if the "Glastic" is removed, i.e. to remain within
the seismic qualification envelope. However, the calculation neither discusses the impact of the failure'of the "Glastic" partitions.on the adjacent relays or. other components, nor provides any justification as to why the partitions would not fail.
Engineeri_n2 unctional Evaluation'Results.
n F
5.
l-Not scheduled to be reviewed by EFE.
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1.
Document Number:
SWEC Calculation Numbers 16345/6-CS(S)-030. Rev. 1, Auxiliary Building and
'
16345-CS(S)-105,Rev.O,SafeguardsBuilding 2.
Related Generic Issue:
+
(H) Miscellaneous Supports (Equipment)
3.
Design Criteria:
080-C5-085, Design Basis for Category I Structural Steel.
4.
Design Document Acceptability:
Calculation 16345/6-CS(S)-030, Rev.1, provides as-built verification of the monorail support for the filter and demineralized at Elet. 852'-6" in the Auxiliary Building.
Calculation 16345-CS(S)-105, Rev. O, documents the disposition of NCR #CM-87-8606X, Rev. O, to show that the as-built equipment weld anchorage to the embedment in the Safeguards Building is acceptaole.
Each calculation identifies the source of the loads and appropriate AISC Code i
I allowable stresses, and shows that the critical mcmber weld stresses are less than-the allowables. The calculation properly shows that final confirmation is required for the design loads obtained from Gibbs and Hill.
5.
Engineering Functional Evaluation Results:
Not scheduled for EFE review.
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Document Number:;
Calculation' Set Number 16345/6-CS(C)-006,'Rev.O,AuxiliaryBuilding
"
i 2.-
_Related Generic Issue:-
y
.
(0) Seismic _ Analysis:
3.
. Design Criteria:
FSAR Section 3.78.2.5.2 " Floor-by-Floor Response Spectra" (Pages 3.78-43 and :
-44), states "... horizontal and vertical earthquake response spectra are
' developed at.the critical locations of-each floor of all Category I buildings.
- These spectra are directly applicable to equipment at any location on the.
floors considered".-
'
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4.
' Design Document Acceptability:
' A : lumped mass or stick model of the Auxiliary and Electrical Building isi generated:in this calculation, and. seismic acceleration profiles are generated
for the design;of structural elements. One of the assumptions, on Page ll'of j
this calculation, is that the' floors'are rigid. A similar assumption is made
.{
in the ' generation of-Amplified Response Spectra -(ARS) ' presently being verified
~.
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'
by Impell under SWEC direction. Effectively the design basis Gibbs & Hill ARS.
,
and,those being verified by SWEC/Impell are at the lumped mass location, i.e.,
- l at the' junction of floors and walls.
- Open Item C/S-4:
idity assumption made in Supporting information is required to justify the rig &H for vertical response,
,
t the floor ARS development approach used by SWEC and G zThe'information should demonstrate that ARS based on this assumption will'
. envelope the " spectra developed at the critical locations of each floor" such that seismic analysis of equipment, piping systems, etc. will not fail-to account for the out-of-plane flexibility of the floor.
Similar supporting information i
is required for horizontal accelerations associated with attachments to walls.
l
Open Item C/S-5:
. Additional DBD direction is required relative to the application of floor response i
spectra to steel framing and/or platforms, specifically as it relates to II/I l
considerations or coupling of equipment and/or piping systems for seismic l
analysis.
~Open Item C/S-15:
-
The team reviewed the moment of inertia calculation and questioned whether it l
conservatively calculated bending stiffnesses.
For example, we believe it l
assumed a larger wall width than a flange effect would typically permit.
l Additional justification is required for this assumption.
j
5.
Engineering Functional Evaluation Results:
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hot schsduled for review by EFE.
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1.L. Document'Numberi-
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216345-CS(
-070' - Safeguards Building I
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'16345-CS )-074' - Partial
-[16345-CS )-078[-Partial-
,
.,
2.;
Related Generic' Issue:
.g (C) Other' Cat'egory-I Concrete Structures i
3L Design Criteria:
i
I 080-0S-081 General Structural Design Criteria.
\\
DBD-CS-084Other Seismic Category I Coacte 6 S a ctures, j
>
FSAR Section 3.78.3.5-requires' that a multi-mode fcctor'of 1.5 be used in
,
. equivalent. static analysis unless a. lower factor. is justified technically..
R.G.. l.100 oReg' latory Guide ^ for' Seisnic Qualification of Electric Equipment
.)
<
u for Nuclter Power Plants
,
4.-
Design Document Acceptability:
j Open' Item C/S-1.
The design of roof and floor slabs uses system supports and equipment loads as uniformly. distributed' attached mass. -- Additional equipment loadsLare used, as j
. required, in the design'of individual slab strips or panels. However, the..
t L--
< design approach to estimate seismic loads due to the specific equipment is not consistent.
In determining vertical seismic loads, the engineer used rigid range or zero period accelerations (IPA) in Calculation Sets CS(C)-70, Page 22.
and CS(C)-074, Page'9,6.nd peak accelerations in Calculation Set CS(C)078, Page 19.. No. justification is provided for using 'ZPA.- Similar inconsistency exists
in determining -horizontal' seismic -loads.
'
'
Open Item.C/S-2:
q q
The multi-frequency, multi-mode factor of 1.5, used in equivalent statk i
analysis in estimating seismic loads, was neglected without any justification, j
contrary to the requirement in FSAR Section 3.7B.3.5.
While it is recognized that design confirmation of seismic loads can be done later, the design approach i
to implement basic engineering principles should be consistent, and established in the early stage in the DBD's to provide uniform directions to the bsigners.
Open! Item C/S-3:
'
The design of the Safeguards-Building roof slab, at Elevation 896'-4" /905'-9",
is shown in this calculation. The entire roof slab is divided into several
,
!
areas, and design of critical slab panels in each area is performed manually.
For the area of-slab bounded by Column Lines 4.5-S to 7.5-S and D-S to the Containment Building, the worst condition (critical) panel is~ identified between
Column Lines 6-S and 7-S, and detailed calculations are performed for this panel.
It appears that the panel between Column Lines 7-S and 7.5-S should also have been investigated fcr shear loads due to substantial loss of shear resistance caused by.the penetrations.near the supporting wall.
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Engineering Functional Evaluation Results:
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Tornado and monorail loads estimated in this calculation require confirmation l
at a later date. EFE noted that this has not been so identified on the " record l
of confirmation" on Page 5 or on Pages 10 and li'of this calculation.
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Document Number:
'SWEC Calculation Set - 16345/6-CS(C)-061, Rev. 0 (Auxiliary Building)
- 2.
Related Generic Issue:.
.
l (C) Other Category I Concrete Structures j
-\\
.
'3.
' Design Criteria:
3.1 FSAR Section. 3.8.4.3 identifies.the loads and load combinations committed to for design of other Category I Structures.
3.2. 080-0S-081, Section 4.1 through 4.12 identifies the'various design loads to be used in the design of. Seismic Category I Structures, while DBD-CS-084,-
Section' 4.1.3 provides load combinations for other Category I Structures.
3.3 SRP 3.8.4 describes.the acceptance criteria used by NRC to review the structural integrity of other Category I Structures.
.
4.
Design Document Acceptability:
!
SWEC Calculation Set 16345/6-CS(C)-061, Rev.-0, shows-the design of Auxiliary:
'
and Electrical Building walls at Elev. 778'-0" and 790'-6". The walls are designed as shear walls for resisting loads from the floors above. Seismic forces and moments in the. walls are obtained from SWEC Calculations i
16345/6-CS(C)-006,' Rev. O, and 16345/6-CS(C)-054, Rev. O. The load input from j
one calculation to the other-is carried out in conformance with the DBDs.
The
!
loads and load combinations identified in the design criteria are evaluated for
]
all load combinations, except those involving pressure and temperature, since
'
~
the results of:high energy line breaks are not available at this time. These.
,
items require confirmation at a later date as identified on the calculation l
.
title page. The design meets the requirements of ACI-318-71 Code. With the l-t exception of evaluation.of confirmation items, the wall design appears to meet the design requirements.
5.
Engineering Functional Evaluation Results:
l l
EFE does not plan to review this calculation.
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Document Number:
'DBD-CS-081,.Rev. 0, dated 6/4/87.--(General Structural Design Criteria)
2.-
Related Generic' Issue:-
r Reactor. Containment Concrete Design Reactor Containment Concrete Internals-Other Seismic Category I Concrete Structures Seismic' Category Structural Steel'
3.
Design Criteria:
FSAR. Sections 3.0, 9.0, & 16.0.
,
4.
Design Document Acceptability:.
LThis document supplements DBD-CS-074. -074, -083. -084, -085, and -091.
The c
~
U Lfo11owing informational attachments are required to complete the DBD:
Attachment Number Subject
!
1-Design Operating and' Accident Temperatures
~2 Design and-Accident Pressure Loads
Pipe Rupture Restraint Loads
,
Jet Impingement' Loads i
Missile. Impacts Due to Pipe Breaks 5'
.
6.
. Seismic Acceleration Profiles
'
7-Seismic Amplified Response Spectra 8-Tornado Differential Pressure Loads on Exterior Walls, Interior Walls, and Slabs
.A consistent design approach for handling equipment seismic loads is not i'
-identified in~ the DBD. See review of individual calculation sets 'for specific examples on this subject, e.g. Open Item C/S-2 pertaining to the 1.5 multi-mode factor used in equivalent' static analysis.
Open Item C/S-11:-
(Sections 4.2&5.2)Hydrostaticloadsaredefinedasliveloads.Only25%of live loads is used in seismic design of individual members, which means that only 25% of contained fluid mass would be used in seismic design of su-090) used a 75% reduced live load, when combined with seismic forces. Justi-fication is required for treating hydrostatic loads as live loads in combination with seismic events.
Open Item C/S-14:
Section 7.0 establishes that " Seismic Category I Buildings (with the exception of the Containment) shall be vented to the atmosphere in the event of a tornado."
No' directions were found to describe the analysis / design approach to be
~taken to account for the effects of depressurization in the buf1 ding sub-compartments..
- 95-
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The absence of design direction has resulted in two approaches to sub-conapartment wall design; both methods have been satisfactory. The Safeguards Building was l
designed utilizing the full 3 psi pressure drop on sub-compartment wall design to envelop all possible conditions.
The Auxiliary Building deferred the design of sub-compartmental walls pending the receipt of actual negative pressures to be obtained from a transient analysis of the pressure drop.
5.
Engineering Functional Evaluation Results:
5.1 DBD did not reference ASTM A240-74A, referenced in FSAR Section 3.8.3.2 (504).
'5.2 DBD does not address the design of masonry walls, either to transmit tornado negative pressures or pertaining to IE Bulletin 80-11-(506).
5.3 DBD-CS-084 indicates a higher Probable Maximum Flood (PMF) of Elev. 791.3 l
. feet, whereas FSAR Section 2.4.3.6 and DBD-CS-081 gives the PMF as Elev. 789.7 feet (SIS).
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-Document'Numberi j
Calculation Numbers'16345/6-CS(C)-036, Rev. O and
.16345/6-CS(C)-037 Rev.
O,.
- Auxiliary.8: Electrical Building i-2.
Related Generic Issue:
- (C).0therseismicCategoryILConcreteStructures
3. -
Design Criteria-l DBD-CS-084, Rev. 0_ _ Design Basis for Other Seismic Category 1 Structures Paragraph.4.4 describes various loads to be used in the design of the Auxiliary
,
-and' Electrical' Building,-and Paragraph 4.1.3 shows the load combination for
-
<
validating the design.
f 4.
Design Document Acceptability:
These calculations provide the analysis and the design of the foundation mat for the Auxiliary and Electrical Building. The mat has been analyzed by
- Engineering Analysis System (ANSYS) computer program ST-384, Rev. 4.2A.
The analysis of the mat is covered by SWEC Calculation 16345/6-CS(C)-036, Rev. 0..
The loading combinations used in the mat analysis are discussed on Pages.65 and i_
76 of the calculation. Shears and moments in all elements are calculated by the computer analysis, and worst. case critical elements are extracted for-design validation.
The design of the. foundation mat is carried out in Calculation 16345/6-CS(C)-037.
The: moment and shear capacities of the critical foundation mat elements.are l
determined using reinforcing steel.shown in Gibbs & Hill drawings 2323-S-0701,
-!
Rev. 10; 2323-S-0702, Rev. 12; and 2323-S-0704, Rev. 8.
Reduction in' strength l
of the foundation mat, due to reinforcing steel damage identified by-various field documents, has been incorporated into the design. Based on the above discussion, the team concludes that the structural integrity of the Auxiliary
)
Building foundation mat has_been adequately evaluated.
5.
Engineering Functional Evaluation Results:
- j Not scheduled for EFE review.
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1.
Document flumber:
' Calculation Number 16345/6-CS(S)-185,Rev.0
. Auxiliary & Electrical Control Building 2.
Related Generic Issue:
'
(D) Seismic Category I Structural Steel 3.
Design Criteria:
DBD-CS-085, Rev. 0 - Seismic Category I Structural Steel 4.
Design Document Acceptability:
This calculation qualified four structural tube steel beams, connected to~the concrete beams in the floor at Elev. 807', in the Electrical Control Building along Column Line 5A. These beams provide anchorage for conduit supports designed by Ebasco. The loads were furnished by Ebasco, via their letter No. EB-T-1433 dated 12/3/86. Those loads not available at the time of the calculations are identified. The critical beam, connection weld, and the anchorage are properly qualified using AISC allowable stresses. The calculations conform to the DBD, pending SWEC verification of " confirmation items" identified on the title page.
5.
Engineering Functional Evaluation Results:
)
EFE does not plan to review this calculation.
...
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' Document Number _:
l CalculationNumber.16345-C5(S)-161,Rev.-0 l
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Auxiliary Building l
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V 2.
Related Generic Issue:'
.
(C) Other Seismic Category I Concrete Structures
'
3. -
Design Criteria:
- DBD-CS-019. Rev. 0
. Paragraph 2.1 states, " Designs which do not meet the separation requirements, as stated in 2.0, shall be redesigned to comply with the stated criteria, or shall be evaluated to demonstrate that the
,
non-compliance has no unacceptable safety impact on the operability of the
'
plant".
4.
Design Document Acceptability:
SWEC Site Calculation 16345-CS(S)-161 has been performed to show that the one-half inch (1/2") as-built vertical separation'between the Auxiliary and q
L Containment buildings at Elev. 805'-0" would not result in unacceptable seismic
interaction'between the two structures. The calculation uses building displacements from Gibbs & Hill calculation, 2323-A FMI-IR, Rev. O, and confirms that the as-built gap is-adequate to prevent the seismic interaction between the two' buildings. The calculation meets the intent of the 080-CS-19, Paragraph 2.1 and, therefore, is considered acceptable.
~5.
Engineering Functional Evaluation Results:
EFE does not plan.to review this calculation.
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Document Number:
I-DBD-CS-083, Rev. O, dated 6/4/87 - Containment Concrete Internals 2.
Related Generic Issue:.
]
(B) ' Reactor Containment Concrete Internals 3.
Design Criteria:
r FSAR Section 3.8.3..
~4.
Design Document Acceptability:
This DBD is not complete as issued. At present it only. identifies the design commitments relative to standard design codes, load definitions, and loading combinations as given in the FSAR. Section 5.0, " Building Design Philosophy",
the heading of which indicates that it will define the specifics of analysis and design, is currently blank and identified to be completed later. Section i
4.3.11.4, " Earthquake Loads", and 4.3.11.5, " Abnormal Loads", is also identified
.to be completed later.. Of the eight (8) attachments providing additional design definition or loading, Attachment 3, " Design Pressure and Temperature Loads for Subcompartments"; Attachment 7. " Shielding Requirements"; and Attachment 5-(intentionally blank)'are identified as missing.
The missing information is required to direct the analysis and design of the internal concrete work.
Open Item C/S-12:
Attachments 2 and 4 are missing from the document, but not identified as missing or to be supplied later.
5.
Engineering Functional Evaluation' Results:
Not scheduled to be reviewed by EFE.
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Document Number:
Calculation Number 116345-CS(B)-172, Rev. 0, dated 7/30/87
'
Reactor:Make-Up Water. Storage Tank Calculation 16345-CS(B)-133 - Seismic Category Tanks, Change Order Document Review
G&Hl Drawing 2323-S1-0317 Rev. 3 2.
Related Generic Issue:
. q (C) Other Seismic Category I Structures j
3..
Design Criteria:
DBD-CS-081 Rev. O identifies design loads for design of seismic Category 1 structures.
,
DBD-CS-084, Rev. O identifies load combinations for design of other ' Category I structures.
4.
Design Document Acceptability:
.
This calculation validates the structural adequacy of the tank and its
',
-foundation for all loading conditions, and addresses field design change items.
,
The calculation represents a thorough analytical and design evaluation of the a
tank under all defined loading conditions. Initial steps were taken to establish
{
the governing loading cases and loading parameters. Because approximate: loadings f
were used to establish the governing analysis and design parameters, it is j
required that these basic assumptions be confirmed prior to implementing the j
application of final loads.
j Two hydrodynamic loading approaches were considered and evaluated for use as input into the Shell I computer analysis. The comparison of loading values-
'
was based on comparing the shears and overturning moments produced at the base of the cylinder wall as a result of mass accelerations of the fluid within the tank. The approach of producing the higher shear and overturning moment was considered to represent the enveloping, conservative loading for use in the final computer analysis and subsequent design of the concrete.
elements.
Case 1 considered the total mass of the water uniformly applied over the height of the wall and horizontally accelerated by an approximated 'g' value of 0.45.
This loading and subsequent forces and overturning moments were developed in calculation pages 35, 36, & 37.
.
Case 2 considered hydrodynamic behavior of the fluid and utilized dynamic water loadings given on calculation pages 151 & 152 to calculate base shear and j
overturning moment at the base of the cylinder. Shear and overturning moment j
was developed on page 153. The base shear was reduced, on page 37, to remove the concrete contribution to enable a direct comparison with Case 1.
~ Case 1 and Case 2 shears and overturning moments were compared on page 37. The Case 1 Joading approach yielded the higher forces and, as such, was considered i
to represent a conservative application of loading and identified as applicable for uniform computer loading input (page 36).
- 101-i
_ - - _ - _ -
- _ - _ _
!
'
-The computer modellfor the Shell 1 analysis is shown on calculation pages 25 &
26. The input was developed for individual loading conditions to pennit combining.in the governing load equations given on page 17. The application of
-loading of input'into the computer analysis appears to be. representative _ of the j
actual. loading conditions, with the exception of the hydrodynamic loading'as
'
incorporated on'page 43.
{
. Based'on.the comparison'of the bottom of cylinder wall forces, it was considered.(as previously(described) that the application of a uniformPage'36)
i equivalent mass of water incorporating.the hydrodynamic loading effects of the internal fluid on the-cylinder' analysis. While the Case 1/ Case 2 force comparison does represent a valid evaluation at the base, the method of inputting the hydrodynamic loading using.an " equivalent mass of water", coupled to the corresponding concrete-element, does not represent the actual behavorial application of loading and may not produce enveloping or correct element forces in every region of the cylinder wall.
The hydrodynamic loadings presently represent a situation where the water is
" coupled" to the cylinder wall (by increasing the wall element weight).
Consequently, when uni-axial acceleration is applied to the system, the
hydrodynamic loading shares-the water mass loading by tension and shear, as l
.well as positive lateral pressure on the cylinder wall. The actual loading l
condition can only apply positive lateral pressure (outward) to the cylinder l
wall and that only in one direction. Thus, the actual loadin
!
cause ovaling of the circle in the'mid-region (unconstrained)g will tend to
, and produce j
horizontal and vertical bending and shears not found by the " coupled" hydro-f
!
- dynamic loading situation used.in the computer analysis.
As best can be determined by the tabulation of forces for load combinations 2,
5, and 9, given on Pages 55, 59, and 61, the hoop moments caused by other than.
l thermal loading are essentially nonexistent.
The location of the vertical
!
forces could not be determined from the tabulation to evaluate their
association with asymmetrical hydrodynamic loading of the cylinder, as compared J
to the means used to input hydrodynamic loading in this calculation.
.Since the fluid column has no shear capacity, vertical seismic force will cause the lateral liquid pressure (Page 29) to be increased by the vertical 'g' factor.
It cannot be readily determined if this effect has been included in the computer input loading.
.
0_ pen Item C/S-8:
Confirmation is required that the " coupled" loading, used from Case 1, does actually provide enveloping element forces throughout the tank structure.
Confirmation should include an evaluation based on "true" dynamic loading behavorial input to the computer analysis. The effect of vertical seismic y
. force on the fluid lateral pressure should be addressed.
5.
Engineering Functional Evaluation Resultc:
Not scheduled to be reviewed by EFE.
- 102-
__
__ _ _ _ _ _ _ _ _ _ _ _ - _ _
"
~l.
Document Number:
080-C5-074, Rev. O, dated 5/29/87L- (Containment' Liner and Penetrations)
'
2.
Related Generic Issue:
<s-(A) Reactor Containment Design.
-
3.
DesignfCriteria:
FSAR Section 3.8.1 DBD-CS-081 i
4.
Design Document Acceptability:
t The " Structural Design Methodology" (Section 5.2) and " Subject Limitations
and Precautions" (Section 5.3) have not yet been developed. This leaves the
'
implementation of analysis and design without specific uniform direction.
i Open Item C/S-9:
The load combinations given under the Factored _ Load Combinations in Section 4.3.2.2 do not include the combination of Operating Temperature (To) and
'
Accident Temerature (Ta), as tabulated in the FSAR Section 3.8.1.3.2.
080-Section 3.8.1.3.2 identifies Ta as the only temperature loading to be considered.
In addition,'the Ta maximum temperatures given in FSAR Section 3.8.1.3.4 have not been defined in the DBD.
The DBD section pertaining to ASME Section III, Division 2, Table 3200-1 (April 1974 Draft) does not include To with Ta under Factored Load Combinations.
Opg Item C/S-10:
The crane brackets shown in Figure 3.8-6 (Section 4.3.3.1) do not appear to be continuous through the liner plate.' Section CC-3750 of ASME Section III, Division 2 defines additional design pareceters for this situation which have not been defined in the DBD.
5.
Engineering Functional Evaluation Results:
ASME Section VIII, Division 1, " Code and Material Standards", referenced 5.1 in DBD, do not reflect applicable dates referenced in the FSAR (S07).
5.2 Reference to Reg. Guide 1.29 uses old revision date (Sil).
5.3 Liner anchor pattern not presented (S12).
l 5.4 Design requirements and acceptance criteria for piping, electric, and
.
'
instrument tubing penetrations not included (S13).
,
- 103-
_ - _ _ _ - _
l-1._
Document Number:
l
~ Calculation Number'16345-CS(8)-135, Rev'. 0, dated 7/8/87 Seismic Category I i
Electrical Ductbanks 2.
Related Generic Issue:
'
.(C) Other Seismic Category I. Concrete Structures
~
Design Criteria:
3.
'" General Design Criteria" of DBD 081 and 084. See page 101 for detail on the D8Ds.
4.
Design Document Acceptability:
4 The calculation represents the tabulation of review change documents to deter-
!
,
mine if the changes meet the basic design criteria.
It cannot be determined-from this document what was specifically used to evaluate the potential need to
,
!
revise original calculations, other than the engineering judgment of the.
reviewer. Based on the brief description identified with items requiring calculation confirmation, it appears that any change that was related to the
!
structural. performance of an element was identified for further review and l
confinnation on a formal basis.
As presented, it appears to accomplish the intended purpose of coordinating further action required to update calculations.
5.
Engineering Functional Evaluation Results:
Not scheduled for review by EFE.
i
!
P 104-
-
_ _ _ _ _ _
___- - - _ _ - _ - - _ - _ -
- - _.
-
.
T
- :
-
,
.I
. l..-
Document Number:
- DBD-CS-084, Rev.:0, dat'ed'.6/8/87:
l (Other.SeismicCategoryI'ConcreteStructures)'
e" O
. 2.
'Related Generic Issue:
i
. (C) :Other Seismic Category I Concrete Structures
.
-
3.
Design' Criteria:
FSAR Section 3.0 DBD-CS-081
'
)
4.-
Design Document Acceptability:
.
Information dependent on unavailable 'attactwnents to 080-C5-081 will be needed to permit full implementation of this document. The following. items are l
~
required'to complete this document:
.j
!
Item Subject q
Table L4.2.1-Fuel Building - Major Equipment: Loadings j
Figure'4.2.1-Railroad Car Wheel Loading-
.
Table ~- 4.3.1
- Safeguard Building - Major Equipment Loadings-Table'!4.4.1 Auxiliary Building -' Major Equipment Loadings Category I Tanks and Pipe Tunnel Loads
. Table 4.5.1
.
<
Table 4.6.1 Service Water Intake Structure -
Major Equipment Loadings a
Para.
5.2 Structural Design Methodology.
I I
5.
_E_ngineering. Functional Evaluation Results I
5.1 FSAR Section 3.8.4.3.2 Load Combination 1.1, for Service Load Conditions, uses.a factor of 1.0 for T. DBD utilizes a factor of 1.7 (S10).
o 5.2 This DBD does not agree with FSAR Section 2.4.3.6 and 0B0-C5-081 regarding the design water level for hydrostatic pressure resulting from the ProbableMaximum' Flood (S15).
l
,
- 105-I
.
_ _ - _
m b
k l-v.
<-
-
.ll'
l.
' Document' Number:,
'
-
I DBD-CS-085, dated 6/4/87'
..
.
Seismic' Category'I-StructuralLSteel
'
2; Related _ Generic Issue:.
.
. (D) Seismic Category I Structural Steel 3.-
' Design Criteria:
l FSAR Section 3.0-i l
' DBD-CS-081 L
4.
Design Document' Acceptability:
Information dependent on unavailable attachments'to DBD-CS-081 will be needed,
- to permit full implementation of this document.
'
gen Item C/S-13:'.
Reference Section 4.1 states that- "The allowable stresses of AISC are increased as
)
-
'
'
" defined in FSAR....". The FSAR allows no increase in allowable stresses since low probability occurrences are addresseTin factored load combinations. The
,
DBD requires clarification and/or definition of the~ FSAR approach to be used.
- Load factors are correct as stated in the DBD.
-- 5.
E,ngineering Functional Evaluation Results:
.
5.1 Load. combinations given in DBD Section 4.3.1.1 and 4.3.1.2 are not captioned, as,givenlin FSAR 3.8.3.3 (508).
5.2 DBD references later AISC supplement codes than those given in the 1969 Edition, referenced by. FSAR Section 3.8.4.2 (S14).
]
5.3 There is conflicting referencing of DBD-CS-081 regarding To and Ta, and
!
Yr,'Yj, and Ym (S14).
,
l
!
I i
l o
- 106-
__
-_
_ -_ _ - __ _ __________ - ___ _ _ -
- _ _ - _ _ ___ _____ ___-____
1 1.
Document Number:
Calculation Number 16345-CS(C)-080, Rev. O, dated 3/19/87
'
Safeguards Building 2.
Relate,d Generic Issue:
.(C) Other Seismic Category I Concrete Structures 3.
Design Criteria:
080-C5-081, Rev. O DBD-CS-084, Rev. 0 4.
Design Document Acceptability:
Reference Documents: G8H Drawings 2323-Al-0502, Rev. 11 and 2323-Al-0509,
'
Rev.9, Calculation 16345-CS(C)-009 Rev. 0 This calculation serves as the basis for determining the worst case overall loading relative to 0BE/ normal' wind and SSE/ tornado wind for the purpose of determining the critical case for structural evaluation.
Normal and tornado wind, floor shears, and moments were determined by con-servative approach. Overall shears and moments were compared for normal wind /0BE and tornado wind /SSE by relative force values. Local effects of tornado and SSE on wall panels were evaluated based on the lower bound of horizontal 'g', and the maximum tornado wind forces.
Seismic force source data given in reference calculation 16345CS(C)-009 requires confirmation to provide final acceptance of this calculation set.
Examination of relative forces substantiates the approach of checking members for overall loading effects without utilizing load combinations incorporating wind and tornado loadings.
5.
Engineering Functional Evaluation Results:
l Not scheduled for review by EFE.
l
,
- 107-
-_ _ _ _ _ __ _ _ _ _ - _ _ -
___
w.
-
-
-
y
,
'
,
!
1.
' Document Number:.
Calculation Number-16345-CS(S)-162, Rev. 0 Reactor Containment Building-
'C 2.
Related kneric-Issue:
l(D) Seismic Category I Structural Steel
'
3.
Design Criteria:
DBD-CS-019..Rev.'0 - Seismic Category ~I Structural Steel Paragraph 4.1 states, in part, "structuraT steel is required to meet the iTTowable stress limitations of AISC (American Institute of Steel Construction)....".
- 4.
. Design Document Acceptability:
This calculation-provides 'an evaluation of DCA-25414, Rev. O, for the disposition of.10 non-conformances to show that the as-built deviations of the Containment Recirculation Sump Screen framing are acceptable' for its structural integrity. The stresses in the steel framing members, welds, and connection bolts due to Gibbs & Hill design loads and the deviations, are compared to AISC'
s allowable stresses, and-found acceptable.. Gibbs & Hill design loads will-be.
validated at a later date, as shown on the SWEC " Record of Confirmation," Page 6 of this calculation. The overall calculation meets the design requirements..
5.
Engineering Functional _ Evaluation Results:
j I
'
EFE does not plan to review this calculation.
)
-
.
i o
- 108-
__ _ _ -_____- __________
_ __
k
.
]
1.
Document Number:
Calcula' tion Number 16345/6-CS(C)-043. Rev. 9
'
Auxiliary.& Electrical Building 2.
Related Generic Issue:
j (C) Other Seismic Category I~ Concrete Structures 3.
Design Criteria:
i J
DBD-CS-084, Rev. 0_: '
l Design Basis for Other Seismic Category I Concrete Structures, Section 4.1.3, l
- establishes requirements for verifying the structural adequacy of concrete
.i floors.
'
4.
Design Document Acceptability:
!
This. calculation validates the Control Room operating floor at Elev. 830'-0"
)
using manual or computer (STRUDL) analysis and design' review per ACI-318-71 Code.
All design loads are identified in accordance with the Design Basis Document.
'
Load combinations involving all loads, except accidental pressure and temperature, are evaluated in accordance with Paragraph 4.1.3 of DBD-CS-084. Where assumptions are made in load estimation the " Record of Confirmation" on the title page shows
-
these items to be verified at a later date. All floor slabs and beams are veri-fied for-structural adequacy in accordance with the requirements of ACI-318-71 Code. With the exception of " Confirmation Items", the calculations are acceptable.
+
5.
Engineering Functional Evaluation Results:
Not scheduled for EFE review.
!
i
,
i
.
- 109-
_ _
_ _ _ - _ - - _ _ _ _ _ -
__
_
b
'
1.
Document Number:
Calculation Number 16345-CS(C)-081, Rev. O Safeguards Building j
!
l 2.
Related Generic Issue:
(C) Other' Seismic Category I Concrete Structures
.
3.
Design Criteria:
i DBD-CS-081, Rev. Oi General Structural Design Criteria,- Paragraph 5.2.1, described the method o'f
,
distributing seismic loads to the building walls.
j 4..
Design Document Acceptability:
The seismic in-plane shear forces and moments ar'e distributed to the walls.
The seismic profiles showing overall accelerations, forces and moments, are analyzed in the Seismic Analysis Calculation 16345-CS(C)009, Rev. O, and serve
!
as a basis for the load distribution to the walls. The load distribution is
'
based on the relative stiffness of the walls. The torsional moments about the center of rigidity are included in the final load distribution. The computation of loads for each wall is carried out by using " Lotus 123" spread sheet program. Manual calculations are used in a few cases. Worst seismic loads from Stone & Webster or Gibbs & Hill are used to arrive at conservative forces and moments in the wall. Based on the above evaluation, the calculations are found to be acceptable.
5..
Engineering Functional Evaluation Results:
EFE accepted the calculations, without comment.
- 110-Iw _-__ _
.i
[
- l i
,
,
h
p
~
[!.
1.
Document: Number:
'
'
. Calculation Number l16345/6-EM(S)-Oll, Rev. 0 l
Auxiliary Building
L, 2.
Related Generic Issue:.
'
(E) Pipe Whip Restraints and Jet Impingement Shields
,
,
3.
Design Criteria:
L 3.1 Gibbs 8 -H111 Specification ~ 2323-SS-16B, dated 5/7/75, Paragraph 6.4 states f
" Welded construction shall conform to AISC Specification... and AWS:Dl.1".
3.2 American~ Institute of Steel Construction (AISC), 7th Edition, " Code of Standard Practice", Section 7(h), permits erection tolerance of 1:500 for vertical members..
l L
4.
Design Document Acceptability:
l
!
Open Item C/S-7:.
,
This' calculation determines -the accepttJoility of the under-sized weld
.
i identified'in Deviation Report I-S-STEi.-146-DR2, and out-of-plumb erection of a vertical. steel-member in Deviation Report 'I-S-STEL-146-DR3. The member involved.
i
!
'is a column.for a-jet shield support structure. The. design load of 260 kip (s,G&H).'
for the jet shield support column, has been obtained from Gibbs.and Hill l
Calculation Set No. SAB-13?C, Set. 2.
The G&H design load did not' appear to be
~
l validated,'and: the SWEC Calculation title-page.did not~ identify it under-
" Confirmation. Required"' item. Except for this open item, the calculation adequately justified the' structural integrity of the jet shield. support column.
5.
-Engineering Functional Evaluation Results:
EFE does not plan to review this calculation.
i
.. ;
,
f
- 111-
. _ _ _ _ _ _ _ _ _.___________.____ _ ____
_
__-_-
. _ - _ -.
. _ _ -
..
'
,
t
'l.
Document Number _:
.
Calculation Number 16345-CS(S)-l?7, Rev. O Reactor Building Internal Concrete
.'c 2.
Related Generic. Issue:
(B) Reactor' Containment Concrete Internals l
,
3.
Design Criteria:
'
,
DBD-CS-083 Rev. O,, Design Basis for Containment Concrete Internals-Paragral>h 4.1.5.1 identifies the American Concrete -Institute, ACI-318-71, as an accepta)le Code for verifying the design.of. concrete structures.
4.
Design Document Acceptability:
~
This ~ calculation provides technical justification for the disposition'of _NCR
- C-86-104273x. - It evaluates the structural integrity of the steam generator shield wall in the Reactor Building notwithstanding a damaged #7 shear reinforcing bar. The calculation.uses Gibbs & Hill calculations as source data to identify
,
- design loads, and calculates ~ the subject wall shear reinforcing requirements.
.The adequacy of the wall is confirmed without the use of entire damaged rebar using ACI Code shear reinforcing requirements.
5.
Engineering Functional Evaluation Results:
Not scheduled for EFE review.
I l
,
,
-
l l[
,
- 112-
)
(
)
..
. - _ - -
.<.
!b I;
';
i Appendix A
'
!
i Inspection ~ Report 50-445/86-17,50-446/85-14.
j Resolution of Open Items from NRC i
dated January 21. 1986-
{
(Scope of Review and Review Checklists)
.- 1
i j
.s t
_ _ _. _ _ _ _. _ _ _ -. _ _ _ _ _.. _ _ _ _ _ _ _-
- __ _ ___- ___ ____ ____-_____
_.
_
'
Inspection Report 50-445/86-17, 50-446/85-14 has twelve appendices. The following l
material is organized by appendix number and NRC comment number (where applicable)
in each appendix. DAP responses were provided during the followup inspection.
Appendix 1-Phase 3 Scope Validation Process Civil-Structural NRCComment(Closed)
The team identified potential HDAs not identified by TERA, such as the design of the annular structural steel normally inside the containment, the auxiliary building structural steel, foundation overturning design, the design of walls for tornado missiles and the effect of Category II buildings on Category I buildings.
DAP Response:
1.
Annular structural steel normally inside the containment - The CPSES internal structure is a reinforced concrete building which does not contain any major structural steel structure. This HDA is not applicable.
2.
Auxiliary Building Structural Steel - The CPSES Auxiliary Building is a reinforced concrete building which does not contain any major structural steel structure. This HDA is not applicable.
3.
Foundation Overturning Design - This item was covered and reviewed under Subtopic 7.8, HDA C099, " Static Soil Structure Interaction, Uplift, Overturning, Sliding, Stability Against Flooding."
4.
Design of walls for tornado missiles - This item was covered and reviewed under Subtopic 1.4a, HDA C010 Impact Loads--Tornado Missile Loads Subtopic 2.1.4b, HDA C028, Impact Analysis--External (Tornado)
Missiles
- Subtopic 4.3d, HDA C072, Other Structures--Exterior Walls 5.
Effect of Category II Buildings on Category I Buildings - This was to be covered under HDA C195.0, Subtopic C.14.16, "Other Special Studies." As reported in Engineering Evaluation Report (EER) DAP-E-C/S-002, " Load Determination, Load Distributions and Analysis, and Load Combinations,"
Section 7.2, the review of this subtopic has been curtailed and is identified as an open item for Project corrective action.
NRC Evaluation:
The team agreed that items 1 and 2 are not applicable and it is appropriate for item 5 to be identified for the Corrective Action Program. The team reviewed checklists which included items 3 and 4; the NRC concerns were addressed therein.
A-1
- - - _ __-____
7y, s
-
-
- - - - -
7- - -
7 = =
~ ~ ' ',
y
'
(
ey
..
,.
L
.y.
.i Electricel/ISC.
.
1.
NRC. Comment'(Closed):
m
'
HDA 1.a; for the designLof control. logic contains trip logic, trip--
.
m logic pennissives, and trip logic bypass elements. - Current check-lists cover some of these design aspects, and revised. checklists will address the remainder.
.
.DAP. Response:
i See DAP-CL-I-002, Att 4, 20, 33', 35, 37,.41-43, and 45; DAP-CL-I-001
'
2.
NRC.Coment (Closed):
]
<
HDA 1.h.7for' protection system interface design will be. revised to-
address protection system interface design aspects as well as control-l
. system interfaces.
-DAP Response:
-See DAP-CL-I-001.DAP-CL-I-002 Att 17, 24..
3.
.NRCComment'(Closed).
HDA 3.a. for local and remote ' indication circuit design will be revised to address both normal operation and accident monitoring h;
indication.
DAP Reaonse:
.DAP-CL-I-020, Att 8, 9, 17, 92; DAP-CL-I-021, Att 48,.49, 66, 92; i
DAP-CL-I-022, Atti92 and DIR D-0709; DAP-CL-I-006, R/G 1.97; DAP-CL-I-015 Normal Operations-4.
NRC Comment (Closed):
The review of vendor technical data submittals by TERA will be revised
'
to be more specific in'the checklist as tc which vendor documents will be reviewed.
DAP Response:
See DAP-CL-I-41, -42-45. -46-47, -48, -49, -50. -51, -52, -53,
-54, -55, Att #27 5.
NRCComment(Closed)
A review of interaction among protection and control systems will be added to the checklists.
DAP Response:
See DAP-CL-I-002, Att 17, 24, 45 A-2
ci. -
.;;
<
6..LNRC.CommentL(Closed)-
'The review of Regulatory Guide,1.97 accident monitoring variables will be expanded to include' Type:D qualification category 2 variables,in revised checklists.
'
'
.DAP Response:
'
See DAP-CL-I-020, Att #91; DAP-CL-I-021, Att #92; DAP-CL-I-022,
)Att #92 and DIR #D-0709; DAP-CL-I-006B,'Att'#11 7.
NRCComment'(Closed)
A review of instrument response time requirements and characteristics will be added to the revised checklists.
.DAP Response:
DAP-CL-I-002, Att #4; DAP-CL-I-037, Response Times
<
NRC Evaluation:
The team reviewed checklists indicated in the DAP Electrical /I&C responses for items'1 through 7 and found that they addressed the NRC concerns.
8'
NRCComment(Closed)
<
.A review of high pressure to low pressure system interlocks will be J
added to the revised ~ checklists.
DAP Response:
Investigation of high/ low pressure interlocks showed no AE design activity; interlocks were designed by Westinghouse and are outside
'
the scope of DAP review.-
NRC Evaluation:
The team agrees with the DAP response.
i
,
Appendix 2 - Civil / Structural 3.
NRCComment(Closed)
Forequipmentsupports(mountings)andHVACsupports,thesamplesizemay be adequate but confirmation is required during implementation that these samples are representative.
DAP Response:
For mechanical and electrical equipment supports (mountings), the sample reviewed determined that corrective action was required for the total population. The issues and acceptance criteria are summarized in Issue Resolution Report (IPR) D8f-E-C/S-508, " Supports / Anchorage Design Methods and Criteria.- For HVAC supports, the project has initiated a 100%
corrective action; hence the self-initiated review was curtailed.
A-3
--_- -_ - _ - _ -
,
a
.
.;
a LE'
- j
'
- NRC Evaluation: 5 l
'
7
~NRC<-Inspectlon Report 50-445/86-19.-50-446/86-16 dated November 4, 1986-
,
reviewed the representativeness of samples for equipment supports review:.
y
- topics,< and concluded'that the samples-were representative in complexity -
and comprehensiveness.
' Appendix-3-Mechanical Systems and Components
..l
- 112 Sump Design'(Closed).
NRC Comment: Screen-submergence has not been included as an attribute in Phase 3,'and is important for preventing debris of a specific gravity less
'
than one from affecting screen performance.
q
,
DAP Response: Review checklist DAP-CLC-M-182 Rev.-0, attribute 9 reviewed the screen submergence for.the' containment sump to. verify that the top deck will be fully submerged after safety injection.
NRC Evaluation: The DAP review scope appropriately addressed screen submer-gence.
38. Maximum Flow Velocity Limitation (Closed)
'NRC Comment: The DAP plans to. address maximum flow velocity limitations as part of the sump design, which will be handled as a " candidate given."
The= team will review the DAP " candidate given" evaluation.
DAP Response: Treating the sump design as a " candidate given" would.have resulted in sump design being excluded from DAP review scope based on DAP evaluation that it had been adequately reviewed previously, e.g., by, an IDVP.
Since DAP was unable to reach this conclusion, sump design was included in the DAP review scope. Attribute 8 of review checklist DAP-CLC-M-182 Rev 0
.
'
reviewed maximum flow velocity at the inner screen.
DIR D-1886 documented the fact that the' maximum flow velocity requirement was not met.
NRC Evaluation: The fact that sump design, including maximum flow velocity limitation, was not treated as a " candidate given" and was included-in.the DAP review scope negates the intent of the original NRC comment, i.e., reviewing the basis for not including this itta in the DAP scope.
i 46. Pump Protection Requirements (Closed)
NRC Comment: Pump protection for positive displacement pumps remains to be addressed by Phase 3.
DAP Response: There are no safety-related positive displacement pumps within the CPRT review scope, i.e., the architect-engineer's scope of responsibility.
NRC Evaluation: This response is acceptable.
<
Apoendix 4 - Instrumentation and Controls 13.
Potential for Control System Interaction (Closed)
A-4 i
...
_
_ _ - - - - _ - - _
g g
]
<
lb
.
<
,
.
'NRC: Comment: 0n the assumption that Gibbs'and Hill. analyses exist -the;
.
'
'
proposed TERA. plan to review' the impact on plant safety systems of
-
. automatic' shedding of control system loads from Class. IE busses 1s -
-
acceptable to the team.
In the event that such analyses are not-available.. TERA should perform a review of'a. sample of control system j=
loads to determine the impact on plant safety systems.
j
'
DAP Resonse: DIR D-0378 Rev. I stated that there is no analysis availa)1e.to demonstrate compliance with IEEE Standard 279-1971, paragraph 4.7.4 for postulated events resulting in the shredding of
,
,
non-Class IE: loads.which may cause conditions requiring protective action'
.I by safety equipment rendered inoperable by shedding.of the non-Class IE-loads..The-DIR resolution-indicated that. although no analysis is available,: review by.DAP:of plant drawings for approximately 10.non-Class i
'IE loads-supplied from 3 Class IE buses determined that shedding.of these i
.
- loads willinot cause conditions requiring
- protective action by safety l
equipment rendered inoperable by shedding _of the,non. Class IE loads.
NRC' Evaluation: The DIR resolution is responsive to the NRC' comment-concerning review of_a sample of control. system loads, in the event that
.
load shedding-analyses are not available.
21.
Instru:nent' Tubing Routing (Closed)
NRC Coment: On the instrumentation that CPSES criteria or project commitments relative to instrument tubing separation exist, the team agrees with the-proposed TERA' plan. -In the event that such criteria or commitments do not exist,' TERA should review a sample of instrument tubing routing to'
assure that no single postulated event, such as HELB or missiles, can cause degradation of safety-related instrument sensing lines below an
.j acceptable level.
DAP Response: Review checklist DAP-I-058, attribute 6 addresses instru-
-
ment tubing separation, including consideration of missiles and high i
energy.line break effects such as pipe ship, flooding and steam release.
NRC Evaluation: The DAP review addressed the review scope intended.by the NRC comeent.
24.
Instrument Identification Means (Closed)
NRC Comment:
The team will review Phase 3 checklists pertinent to the means used for instrument identification.
DAP Response: Attribute 25 of all component functional checklists (DAP-CL-I-19, 41 through 56) reviewed the requirements and provisions specified for equipment tagging and identification. This review encompassed 17 different I&C component types. DIRs-D-1533 and 1580 identified that specifications MS-603 and 632 did not address tagging of valves with CPSES identification numbers.
NRC Evaluation: The DAP checklists provide evidence that DAP reviews appropriately addressed instrument identification.
A-5
- _ _ - _ _ - _ - _ _ _ _ _ _ - _ _. _ _ _ _ _ _ -. _ _ _ _ _ _. _ _ _
_. _ - -
_ _ _ _ _ _
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l 25.y Loss of: Bus' Voltage-Sensors (Closed)
~
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,
,
_
.
,
l
,
-
...
NRC Comnent:l The team willl review the E-9' single? failure checklist concerning lossLof bus voltage: sensors.
>
"DAP Responsei ~ Loss of-6.9' KV bus voltag'e relays and their interlocks ~ to.
'
..
She diesel. generator control circuits were reviewed in checklist DAP-CL-I-002,.
attributes.:4, 17,:42 and 126. Loss of. voltage sensors for the 6.9 KV.. buses
.
IEEE 279-1971.(gainst the applicable. single failure requirements of1.e., re were reviewed a separate power supplies) using DAP checklist CL-I-083, attribute 13..
NRC Evaluation: The DAP review checklist appropriately addresses single-
failure requirements-for the loss of voltage sensors for-the 6.9 KV buses, j
!
Appendix 5 - Electrical ' Power (Closed)
The below items'are closed on the basis that the DAP response provides evidence
.I H
that the item is addressed in a review checklist and/or.a DIR, Issue Resolution
?
. Report, HDA, etc., as appropriate.
Item No.
Description DAP Response.
!
A.6.2-
' 6.9kv Tie Breaker-Protection / Relaying Items A.6.2 through A.6.10
'
A.6.3 DG Output Breaker-Protection / Relaying and A.8.2 through A.8.5 were A.6.4 6.9 kv-Motor Feeder Breaker-Protection / addressed.by DIR-D-2166, Relaying...
IRR-DAP-E-EIC-501, A.6.5 Unit Substation Transformer Primary IRR-DAP-E-EIC-505, and.
j l
BKRL Checklist Form DAP-E-035 A.6.6
. 480V Bus Incoming Bre'aker Protection /
'l Re1aying-i i
.A.6.7
- 480V Bus Motor Feeder Breaker Protection / Relaying
.
A.6.8-480V MCC Feeder Breaker Protection /
-l
Relaying A.6.9 MCC Motor Feeder Circuit
'
' Protection / Relaying A.6.10 MCC M0V Thermal Overload Protection A.7.2 480vPower(lrg)-PenetrationAssy.
DAP-CLC-E-013 A.7.3 480v Power (sm) Penetration Assy.
DAP-CLC-E-013 A 8.2 480v Switchgear Coordination Studies.
A.8.3 480v MCC Coordination Studies A.8.4 125 VDC Switchgear Coordination Studies A.8.5 Inverter Power Distribution Coordination Studies l
A.9 Reactor Coolant Pump Under-Frequency DAP-CL-I-060, Att. 2, 3
i I.
i l
l 1:
A-6
__ _ _ _ _ _ _
___
,
,
,
'
or; a'~
- i h#
Item No_._.
Description" DAP Response o
l'
.
tEQUIPMENT SPECIFICATION-
_
l
.
.
..
L
.B.
,
.
L B.2.2:
- 480v' Unit Substation'
DAP-CLC-E-001/002 B.2.4 125v. Switchboard DAP-CLC E-007/002
'
B.3.4
' Instrument Cable.
DAP-CLC-E-020/020-GS1 and,GS2
-
B.4.3 '
- Valve Motor Operators DAP-CLC-E-026/026-GS1 and GS2-
.B.S.2
' Low Voltage Penetrations DAP-CLC-E-01s G13-GS1 and GS2.
!
. B.6.2.
Isolation. Cabinets..
DAP-CLC-I-058 l
Deleted (not Class IE)
.B.6.3 LHeat Tracing. System..
DAP-CLC-E-034-3 B.7.1, Environmental Seal Assemblies
'
B.7.2 Fire Seals and-Barriers DAP-CLC-E-037.
,
~ B.7.3 Med. Voltage Terminations and-DAP-CLC-E-050/023/023-GS1-
",
. B.7.4'
Wire Terminals-and Splices:
DAP-CLC-E-051/023/023-GS1 q
" ~
Splices'
,
,
.
'-
C.4.1.2 Equipment Foundation Drawings DAP-CLC-E-046 1D.1.2 Remote Safe Shutdown Equipment'
DAP-CLC-E-040 through 042
)
!a
'E..
INSTALLATION DOCUMENTS
=E,1:
Installation Contract DAP-CLC-E-052/052-GS1
~
'E.2 Installation. Notes and Details DAP-CLC-E-052/052-GSI~
-E.3-Project Separation Guide DAP-CLC-E-032
.
,
'
G.-
INTERFACE-DAP-CLC-E-008/006 G.I.2 NSSS'
G.2.8 Site Engineering HDAs E014.1. 40.1, 42.1 i
through 51.1
!
Review of post-construction G.2.9 Start Up test results in lieu of i
start-up
.G.2.10 Site Construction-Interface with quality of construction program j
!
Appendix 6 - D_esign Adequacy Proaram Plan q
6.
NRCComment(Closed): With respect to review of heat removal capability, the selection of a-closed system and related checklist development are open items.
DAP Response: The CCW heat exchanger was reviewed by checklist DAP-CLC-M-005. This checklist addresses heat removal attributes as well l
as other component functional and code requirements for the heat j
l exchanger.
!
NRC Evaluation: Based on review of the DAP documentation for system i
selection (for closed system heat removal) and the review checklist for the heat CCW exchanger, the team concluded that the CCW system was a representative selection and the review checklist addressed the appropriate attributes.
A-7
__
- - - _ - _. _ __
-.
~
NRC Comment: (Closed): The development of the _HVAC checklist for the i.
- 7._-.
mechanical discipline is an ~open item.-
DAP. Response: _ To review HVAC. system performance, checklist forms j
. DAP-M-028 and 078 were developed. - The results of these reviews
identified discrepancies concerning the identification and use of heat
,
loads.. ' The issues are summarized in IRR-DAP-E-M-504.-
NRC' Evaluation: The issue with respect to checklist development is moot-since the DAP' review has resulted-in an Issue Resolution Report concerning
.
determination of heat loads for equipment sizing. This IRR will be addressed in the HVAC corrective action program and is_ included in the-HVAC Generic Issues Report dated December 15, 1986.
. Appendix 7 - Civil / Structural
.;
- 1.
NRC Connent (Closed):
The team stated that it planned to review a ' checklist concerning base plates,' anchor bolts and embedments.
DAP Response:
Checklist C/S G032 addtessed this area.
NRC Evaluation:
The team reviewed C/S G032 Rev. 1 dated May-2, 1986, which primarily
' referenced ACI-349-80 Appendix.B and ACI-318-71, AISC-1969, and found
..
that it. covered appropriate areas for review of base plates, anchor bolts and embedments.
4.
NRCComment(Closed):
The sample size and specific samples of additional embedments has not
.
'
been identified; the team will review these aspects during program implementation.
DAP Response:
The review of embedments has identified needs for corrective action. The summary of findings and acceptance criteria are presented in the following IRRs.
I DAP-E-C/S-508; Supports / Anchorage Design Methods and Criteria
-
i DAP-E-C/S-509; Penetration Sleeves / Anchorage
-
DAP-E-C/S-510; Fuel Transfer Tube Supports
-
DAP-E-C/S-511; Anchorage' Design Methods and Criteria
-
i DAP-E-C/S-502; Concrete Design--Reactor Building Internal Structures
-
(addressing Upper and Lower Lateral Restraints)
NRC Evaluation:
Since review by TENERA of samples of embedments has identified the above generic issues, the original issue of sample representativeness
,
j is moot.
A-8 l
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. _ _ _ _ -
j
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l Appendix 10 - Electrical /I&C Systems and Components
-
I Items 13 and 14 below are closed based on the team's evaluation that review I
checklist attributes or cri'iria and DIRs indicate the items were in the DAP l
review scope.
!
13. NRC Comment (Closed):
Undervoltage protection for the 120V system is not covered in any checklist.
l DAP Response:
l
}
See DAP-CL-I-020, Att 103 and DIR D-0279 14. 11RC Comment (Closed):
Checklist #25 considered coordination of relay and breaker settings, but did not factor equipment protectior. cont ?derations into the relay setting
,
calculations.
DAP Response:
See DAP-CLC-E-035 Criteria #s:
10, 11, 13, 28, 33, 34, 42, 43, 68.
!
20. NRCComment(Closed):
This pertains to identifying the components to be reviewed for seismic and envircamental qualification.
DAP Response:
Not Applicable
,
NRC Evaluation:
,
NRC Inspection Report 50-445/86-16, 50-446/86-15 dated September 9, 1986 concluded that the list of equipment selected for seismic qualification review represented a reasonable cross section and satisfied hRC concerns and commitments made by the DAP.
In addition, Impell report number 09-0210-060 dated December 1986 indicates there will be a review to address generic discrepancies found by DAP in the areas of enviro mental and seismic qualification (see DAP-E-EIC-503 and DAP-E-M-500).
'his generic action transcends the matter of the TERA review sample.
Appendix 12 - Comments on Review Checklists Mechanical Systems and Components
,
5.
Overpressure Conditions (Closed)
NRC Comment:
,
This checklist does not provide an adequate review of overpressure protection design since the AFW system is not representative of such design. TERA plans to review a more representative system and develop a checklist which l
addresses the basis for relief valve sizing relative to set pressure and oesign flow rate.
A-9
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f
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DAP Response:-
'
Overpressure protection of safety related piping and equipment is
_ generically addressed in'IRR'No.-DAP-E-M-502 and the SWEC Mechanical.
Generic Issues Report'(Appendix C) dated January 21, 1987.
f NRC Evaluation:
The IRR and Generic Issue Report indicate that TERA identified a generic
'
- issue for overpressure protection. Therefore, the issue of representa-
'
tiveness is moot.
8.-
WaterSupplies(Closed)
NRC Comment:
This checklist does not' address the requirement that the service water system (backup source) provide adequate flow to the AFW system while maintaining required flows to other safety related equipment.
DAP Response:
See DAP-CLC-M-050, Att 3 and DAP-CLC-M-048, Atts 1 through 5.
.
NRC Evaluation:
Tho team reviewed the checklists identified for this item, as well as those identified for mechanical. items 11, 23, and the NF supports item, and found that they addressed the NRC concerns.
11. Air Accumulators (Closed)
NRC Comment:
-Checklist No. 11 does not address the basis for the 30 minutes required accumulator capacity as committed in the FSAR.
DAP Response:
See DAP-CLC-M-158 and 160.
22. HELB(Closed)
NRC Comment:
This checklist did not include a review of evaluations performed on targets required for safe shutdown of the plant (considering single failures and loss of off-site power) for postulated high energy line breaks.
DAP Response:
IRR No. DAP-E-M-501 section 2.2.6 indicates ten DIRs on inadequate justi-fication for conclusions concerning safe-shutdown evaluations of targets.
l This generic issue is carried forward in Ebasco's Mechanical Generic Issues Report, Supplement A. Systems Interaction Program, Corrective Action Program (dated January 26,1987).
A-10
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________________________L
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_
,
,
,
i
~NRC Evaluation:
The NRC' concern has been addressed.by DAP and resulted in a generic issue.
-
23.
Internal Flooding (Closed)'
r NRC Comment:
Checklist #23 did not address identification of safety-related equipment required for safe shutdown which is below flood levels resulting from postulated high and moderate energy line breaks (considering loss of off-site power and single failure for the event evaluated).
DAP Response:
See DAP-CLC-M-262, Atts l'2, 2.2 and 3.2.
.
. 26. - Seismic Qualification (Closed)
NRC Comment:
The checklist should consider:
' Pressure boundary calculations.
'
Bearing load evaluations where applicable.
- Shaft deformation as it affects functional considerations.
- Nozzle' qualification calculations.
- Foundation interface load determination.
- Overall load combination check and ASME Code,Section III stress
comparisons.
DAP Response: Not applicable NRC Evaluation:
._ Implementation of DAP review che'cklists for seismic qualification was assessed by the NRC in Inspection Report 50-445/86-18, 50-446/86-15. In addition, IRR No. DAP-E-M-500 summarized a number of generic technical issues identified in the DAP review of seismic qualification. These are being addressed in Impell's generic review of equipment qualification as described in report number 09-0210-060, Rev. O dated December 1986.
i NF Supports (Closed)
l
!
NRC Comment:
l
'
There is no checklist covering NF supports (other than pipe supports) in the Civil / Structural or Mechanical areas.
]
l i
DAP Response:
i See checklist C/S S130, Fuel Transfer Tube Supports, Rev. O dated 5/2/86 which
l was implemented by DAP-CLC-C/S-068.
,
A-11 l
e
=_-- _.
__.
N 3:
f Civil / Structural I
Design /FieldChanges(Closed)
l NRC Comment:
.
.
Some additional considerations which are lacking are the impact of design.
changes, field change requests, and non-conformance reports and compatibility of the design with drawings / specifications controlling construction and procurement.
DAF Response:
For the civil / structural discipline, eight review checklists and 29 DIRs
,
address the above areas.
NRC Evaluation:
The team reviewed the above_ checklists and found that they covered the NRC Concern.
C/S-G001: StructuralSteel(Closed)
NRC Comment:
The AISC " Specification for the Design Fabrication an'd Erection of a.
Structural Steel for Buildings, AISC - 1969," does not address torsion der,1gn considerations'such as web torsion, torsion on connections, and torsion on box beam connections. This needs to be addressed.
'
b.f The design method used to consider the effects of combined loads involving axial, bending and torsional loads is not addressed.
The design method used to consider the six components of combined effects c.
at connections is not addressed.
d.
'Since the AISC Specification does not address the stability of flanges, webs and plates under combined stresses, there is a need for the aspect to be addressed.
Local stresses, such as flange bending and the associated deflections, e.
are not addressed.
J DAP Response:
See C/S G001 Rev. 2 for the following attributes:
a.
Refer to Attribute 1.1 b.
Refer to Attribute 1.2 c.
Refer to Attribute 1.4 d.
Refer to Attribute 1.3 e.
Refer to Attribute 1.5
.
A-12
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/
w s
NRC Evaluation:
The team reviewed the above checklist attributes and found that they addressed
the NRC concern.
C/S-G010: Loads-and Loao Combinations for Foundations-(Closed)
NRC C'omment:
The checklist does not address the development of the controlling-load-a.
cases considering static and dynamic responses as-well'as settlement.
b.
The actual-soil bearing pressures should be checked against the allowables.
The checklist does not address the FSAR considerations for overturning c.
or rocking effects and the margins involved, as well as the effect on bearing pressures.
DAP Response:
For.the~ Containment Mat:
"
a.
. Refer to C/S-S105, Rev. 0, Attribute 3.2
.
b.
Refer to C/S-5105, Rev. O Attribute 5.7
. Refer to C/S-S105, Rev. 0, Attributes 4.7 and 5.3; and C/S-S105, Rev.1, c.
.
Attribute 5.8.
NRC Evaluation:
For Foundations of Other Category I Structures:
The DAP review focused on the Containment Mat as being representative and a.
enveloping of Other Structures Mats (See a. above). Sections 6.2.1 and 7.2.1 of EER DAP-E-C/S-005, " Foundation and Soils," identify a number of open items-for Project corrective' action, including the confirmation of the applicability and correct implementation of ACI Committee 436 techniques for. foundations that are not analyzed by computer techniques.-
b.
Refer to C/S-S106, Rev. O. Attribute 4.4.
l c.-
Refer to C/S-S106, Rev. O Attributes 3.3.7, 3.3.8, and 4.1.
_
'
NRC Evaluation:
-q The team ' reviewed the above checklists and EER and found that they addressed
)
the NRC concern.
C/S-G031: GenericNon-ASMESupports(Closed)
NRC Comment:-
The verification of required loadings and load combinations should be a.
addressed.
.
A-13
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- _ - _ _
__
_
b.
The technical basis does not. appear to be evaluated for HELBA, MSLB and MELBA loads on components.
The reference to pipe break loads, and pipe reactions is applicable to c.
the qualification of piping penetrations only. A separate checklist is recommended for the ASME portion (flued head - temperature distribution and stress evaluation) as well as the barrel, liner plate reinforcement and shear lug (ACI, AISC evaluations).
DAP Response:.
a.
Refer to Item 1.4 of C/S-G031, Rev. 2.
This is covered in specific checklists, e.g., item 12 of C/S-5121, Rev.1 - HVAC Supports, items 2 and 5 of C/S-S122, Rev. 0,. Crane Supports, b.
In the evaluation of non-ASME supports, the C/S structural review considers all applicable loads.on the support including abnormal loads generated by the postulated.high energy pipe break and pipe break loads (attributes-2.5.and 2.6 of C/S-G031, Rev. 4). The review of the technical basis for the load definition is within the Mechanical Discipline's scope and is addressed in the EER-DAP-E-M-002, " Auxiliary Feedwater System," Appendix P, and IRR DAP-E-M-501, "High Energy Line Breaks."
The results of the reviews of penetration sleeves / anchorages are c.
summarized in IRR DAP-E-C/S-509." Penetration Sleeves / Anchorages" and EER DAP-E-C-006 " Supports and Anchorage Design Methods and Criteria."
Checklist C/S-S124 documented the reviews, the primary emphasis of which was as-built calculations for the concrete anchorage aspects of the penetration sleeve. The' review included interaction with the concrete, punching shear (Section 2.1 of the IRR) and the lugs (Sections 1.1 and 2.2.1 of the IRR). The reviews of the penetration sleeves and flued heads (Section 1.2 and 7.2 of EER DAP-E-C/S-006, Rev.1) are open items to be addressed by the Project corrective action. The review of liner reinforcing around penetrations is addressed in IRR DAP-E-C/S-506,
" Containment Liner and Attachments." DIRs 0-0991 and 0992 describe issues related to liner reinforcing around penetrations.
NRC Evaluation:
The team reviewed the above checklists, EERs, IRRs, and DIRs and found that they addressed the team's concerns.
C/S-S101: Containment Concrete Desian (Closed)
NRC Comment:
x, Items 1.2.10 and 1.7 - These items apparently refer to FSAR Section
]
a.
3.8.1.5.1.1, which interprets the ACI 359-73 document.
However, neither
-
item gives the complete list of conditions which are allowed or are necessary.
.
l
_ _-_
_ --
,
..
v I
'b.
-Items 1.2.11' and 1.6 - These items apparently refer to FSAR Section
.
i 3.8.1.5.1.1, which interprets the ACI 359-73 document. However, neither item gives the' complete requirements.
Item'1.5 - The review does not address calculations which determined'the.
"
- c.
radial. shear values, nor how the shear reinforcement was determined and
'
>
provided.- In addition, it does not cover the details, control-and results of welding the 1" x 4" plates at 45 degrees between opposite face vertical reinforcing steel.
d.
Item -1.9 - Although this relates to the value used in the calculation and not test ~ values, this check attribute is not listed under 4.0 Calculation l
Review.
Item 4.0 - There are no cross-references in this section to Checklists-e.
C/S-G-021 and G-022-which address calculations.
DAP Response:
'..
Refer to Attribute 1.4 of S101, Rev. 3
"For load combinations that a.:
include thermal gradient loads, the maximum. strain in the reinforcing steel may reach 1.5 times the yield-strain, provided that the average stress across the entire section does not exceed 0.9Fy."
b.
Refer to Attribute 1.3 of $101, Rev. 3.
The design requirements for ' radial shear are addressed in attributes c.
1.2.1 and 3.3.8 of C/S-5101, Rev. 3.
The review of the radial shear calculations and the design of reinforcing steel for radial shear has been documented in EER DAP-E-C/S-003, " Concrete Structures Design Methods and' Criteria." The EER identifies an issue related to insufficient or missing shear design calculations (DIRs.D-0934 and 0-0939). The details,.
control, and results of welding the 1" x 4" plates, as indicated in procurement' specification 2323-SS-10. " Reinforcing Steel" were reviewed using the generic checklist C/S-G061. The review is documented in EER DAP-E-C/S-009, " Structural Specifications," and resulted in DIR D-1707 concerning code requirements for tensile testing. An additional DIR
DAP-CLC-C/S-123 socuments the specification review.
d.
For calculation review purposes, the intent of Attribute 1.9 of checklist C/S-S101, Rev. O, is to verify if the specified minimum concrete strength has been used. Attribute 4.0 covers the mathematical check of Attribute 1.9 as well as other attributes.
,
.e.
References to G021 and G022 are made under attribute 3.2.
NRC Evaluation:
The team reviewed the above checklists and EERs and found that they addressed the team's concern.
C/S-S102: Other Category I Concrete Design (Closed)
,
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_
_
NRC Comment:
i Item 1.1.2 - If there are no members meeting the classification require-a.
nents of a deep flexural member under ACI 318-71, Paragraph 10.7, then another attribute should be checked in the design review, b.
Section 10.6 of ACI 318-71 should be included in the attributes to be checked since beams and 1-way slabs were no doubt utilized in the concrete structures, l
Chapter 13 of ACI 318-71 should be included in the list of attributes to c.
l be reviewed if the 2-way slab concepts were used in the design of concrete l
structeres.
DAP Response:
Attribute 1.1.2 of C/S-S102, Rev. O, has been deleted since there are no a.
deep members meeting the classification of ACI 318-71. Design of other flexural members is covered under item 1.1.3.
b.
Refer to 1.1.3 of C/S-5102, Rev. 3.
Refer to attribute 1.1.20 of C/S-5102, Rev. 3
"if two-way slab design c.
concepts are used, are they in accordance with Chapter 137" NRC Evaluation:
The team reviewed the above checklist and found that it addressed the team's concern.
C/S Sill: Spreading Room Steel Structure (Closed)
NRC Comment:
The structural steel in the containment annular space and areas in the auxiliary building framed in structural steel may represent more critical loadings (than the cable spreading room) which should be reviewed.
DAP Response:
At CPSES there is no structural steel framing in the containment annular space or in other Category I buildings, with the exception of the Cable Spreading Room.
NRC Evaluation:
The team agrees with the DAP response.
C/S-S121: HVAC Supports (Closed)
NRC Comment:
The HVAC support checklist does not address:
Duct joint capacity.
- A-16
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. _ _
. _ _ -
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l In-line components such as booster fans and turning vanes.
'
Openings in duct work.
'*
~ The treatment of duct wall buckling as it affects overall' stability-during seismic events.
'
'
The functional classification of HVAC systems and the effects on design
- -
requirements.
DAP Response: Not applicable NRC Evaluation:
The HVAC review was not performed under the DAP.
It is being performed under the Ebasco Corrective Action Program outlined in its Generic Issue Report dated December 15, 1986.
NRC Evaluation:
The team agrees that the Ebasco review obviates the need for the DAP review.
C/S-S122: Crane Supports (Closed)
'
NRC Comment:
The polar crane support evaluation should include liner plate thickening, concrete embedment and inter-discipline verification that applied crane loads are current and properly considered response spectra and design load rating.
i DAP Response:
C/S-S122, Rev. 0, Attribute 3.0 states "Is crane girder support bracket welded to a thickened section of liner plate and anchored into the containment wall?"
Refer to items 2.0 and 3.0 of C/S G-012 Rev. 3, which address seismic loads (including the reference documents).
NRC Evaluation:
)
The team reviewed the above checklist and found that it addressed the NRC Concern.
C/S-5123: Equipment Supports (Closed)
NRC Comment:
The purpose of attribute 4 is to assure that support stiffness, frequency, and
,
loading are reviewed for major equipment vendors' design requirements.
This l
should not be limited to NSSS equipment since other vendor equipment often
!
represents a greater percentage of the heavy equipment.
DAP Response:
.
-
A-17
<
-
_____ _ _-
- - _ _ - - - _ - _ _ _
Three non-NSSS equipment items were reviewed for the implementation of system / -
subsystem decoupling criteria.. These included the Polar Crane, Diesel Generator, and Boric Acid Tank.. The. review is addressed in EER DAP-E-C/S-002, " Load l
Determination. Load Distribution, and Analysis, and Load Combinations."
NRC Evaluation:
The.DAP response addresses the NRC concern.
'l
.1 C/S-S124: Penetration Sleeve Supports (Closed)
)
I NRC Comment:
CommentCforC/S-G-031(above)applieshere.
DAP Response:
Refer to response for item C of C/S G-031.
-l NRC Evaluation:-
See evaluation of comment C for C/S G-031.
f C/S-S125: Missile' Resistant Doors and Hatches (Closed)
NRC Connent:
The qualification document (s) should be compared to the procurement specifica-tion to assure that design requirements were met.
DAP Response:
Section 4.2 of EER DAP-E-C/S-009, " Structural Specifications," states that the review of specifications including Specification 2323-AS-54, " Missile Resistant Doors," was intended to address vendor and fabricator conformance to the specification requirements. These reviews were curtailed and have been identified _as open items in Section 7.2 of the EER.
NRC Evaluation:
The team considers it appropriate to identify this item in'a EER, to be addressed in the project corrective action program.
C/S-5126: Seismic Restraints for Removal Shield Walls (Closed)
NRC Comment:
j Since Checklist G-005 is referenced as the anchorage checklist for S125 and
I S126, continous anchorage for missile resistant doors, hatches and removable
,
l shield walls should be addressed.
DAP Response:
Item 3 of checklist C/S-S126, Rev.1, addresses anchorage requirements. G-005 has since been superseded by C/S-G032 which addresses the specific requirements of anchorage.
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N' RC Evaluhtion:
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3 (The team reviewed the above-checklists and found that they addressed the NRC Concern.
.' C/S-S131: Cable ~TraiSupports'(Closed)
NRC Comment:-
This checklist does not cover:
a.
Evaluation of the portions of the-plant'where overall tray system-behavior must be considered in addition to areas.where individual support:
','
qualification'is valid.-
6. The qualification of:the cable tray itself for two and three dimensional
. cable loadings'.(consider local tray buckling and yielding).
Control:of cable weight during rating and, where required,.derating of c.
the system.-
'DAP Response:
-
Refer to items 4.5.1 through 4.5.5 of C/S-S131. Rev. 2 for treatment of a.
system behavior.-
b.
Items 3.9.1, 3.9.2, 3.9.3 and 3.9.4~ address the. qualification of the tray for various load components.
-
Item 1.3.4-addresses the procedure for determining tray weight.
c.
NRC Evaluation:
The team reviewed C/S-S131 and found that it addressed the NRC concerns.
Instrumentation and Control l
[
1.
NRCComment(Closed)
{
'i The description of verification !!id not identify technical requirements to be met.
.
DAP Response:
Refer to DAP-CLC-I-019, 037, 040 through 056, and 069 for all items except: instrument repeatability and drift, trip reset constraints and
- time delay tolerances,' which were considered in the AFW system level and setpoint calculation reviews.
(DAP-CLC-I-001,016,017,and023through 033).
2.
NRCComment(Closed)
The checklist did not specify that instrument and control circuits would be reviewed from sensors through the actuated equipment or to the energy source and supporting system interfaces.
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DAP Response:-
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Refer to DAP-CLC-I-001, 0'06. 015. 040, 037,'and 058.
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3.
.NRCComment-(Closed)
. The checklists did not address confirmation of instrument taps on tank'
and piping drawings for location, elevation, azimuth orientation, and..
'
redundancy to provide a direct comparison with system requirements and
,,
. protective action'setpoints.
DAP Response:
Refer to DAP-CLC-I-025'and 026, Attributes 3.1 and 3.2; DIRs D-0096~and
.D-0898; DAP-CLC-I-058, Attribute 6; and DAP-CLC-I-040.
' 4.
NRCComment(Closed),
The' checklists'did not' address confirmation of system test, component test, and component calibration design-provisions needed to satisfy'
.
. Regulatory Guide 1.22 and IEEE Std. 338.
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DAP. Response:
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Refer to DAP-CLC-I-001, 002, 005, 006, 007, 008 and 015.
.NRC Evaluation:
The team reviewed the checklists identified in the DAP I&C responses for items 1 through 4 and found that they addressed the NRC concerns.
5.
NRCComment'(Closed)
The checklists did not address. confirmation of operator action time, provisions for Class IE indications, required valve interlocks for AFW pump suction fluid sources, and coordination with the mechanical-systems discipline for available fluid volume. to permit manual transfer from the-t condensate storage tank to the station service water system.
DAP Response:
Refer to DAP-CLC-I-001, 002 and 015.
.
NRC Evaluation NRC Inspection Report 50-445/86-19,50-446/86-16 indicated that the NRC team evaluated the implementation of review checklist DAP-CLC-I-001.
6.
.NRC Comment:
The checklists did not address AFW pump suction pressure switch setpoint trip and reset differential and resulting on AFW system availability.
A-20
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DAP Response:
Refer to DAP-CLC-I-023 for' pressure switch'setpoint.- Refer to DAP-CLC-I-003 for evaluation of reset differential. Refer to DAP-CLC-1-009 for resulting effects on AFW availability..
NRC Evaluation:
NRC. Inspection. Report 50-445/86-19. 50-445/86-16 indicated that<the team reviewed the implementation of review checklist DAP-CLC-I-023 for AFW
. pump suction pressure switches and transmitters.
In addition the area of instrument setpoint calculations is addressed as a generic issue in IRR DAP-E-EIC-502 and SWEC's Generic Issue ~ Report on I&C dated 1/5/87.
Electrical'
1.
Same as Append!x'10, NRC Comment 13.-
2.
Same as Appendix 10, NRC. Comment 14.
3.
Same as Appendix 10, NRC Comment 20.
4.
NRC Coment (Closed)
Component functional requirements checklists listed general criteria such as reference to IEEE 308 and 323, but did not include functic'ial requirements specific to the equipment being reviewed;, e.g., switchgear breaker current interrupting requirements.
DAP Response:
Equipment-specific functional requirements are included in DAP-CLC-E-011, 013, through 16, 018 through 020, 023 and 026.
5.
NRCComment(Closed):
Checklist #4, Cable Sizing," addresses cable arpacity, but does not
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address cables located inside the containment.
DAP Response:
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See DAP-CLC-E-004 criteria 47.0 and 48.0 and Table 2.
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6.
NRCComment-(Closed)
Checklist #13. " Component Functional Requirements - Penetration," does not address backup protection provisions, as described by R.G. 1.63.
j DAP Response:
See DAP-CLC-E-013, criterion 48.0.
NRC Evaluation:
The team reviewed the checklists identified in the DAP electrical responses l
for items 4 through 6 and found that they addressed the NRC concerns.
l A-21
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Appendix B I
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. Resolution of Open Items from NUREG-0797 Supplement No. 13 dated May 1986 Appendix C
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(Design Adequacy Program and Discipline Specific Action Plans)
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The staff comments are numbered to correspond to Appendix C of NUREG-0797 C
Supplement No. 13. The DAP responses were provided during the followup inspection.
C.1 -GENERAL COMMENTS
'
StaffCommentC.1(1)(closed)
The staff requires that the CPRT establish procedural direction or instruction to ensure that safety-significant evaluation of discrepancies related to the
,
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self-initiated design.or construction adequacy program and the potential for
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scope expansion _is based on final plant _ documentation._ However, this should
}
i not preclude the. fact that existing issues must be evaluated for root cause
~and generic implications.-
l DAP Response-DAP. agrees with the staff.
Procedural ' direction has been established to ensure that final safety significant evaluations are based on final plant documentation.
NRC Evaluation
,
-The DAP response was not specific as to procedural directions; therefore, the team reviewed DAP procedures. Procedure DAP-22, section 4.3, states that safety significance evaluations shall consider both documentation prior to April 1, 1985 (the review cut-off date) and the subsequent documentation.
The safety significant evaluation is required to discuss any differences in. con-clusions due to differences in such documentation. Procedure DAP-7, Figure 1 indicates that safety significance evaluations are inputs to root cause and-generic implication evaluations. Therefore, the latter evaluations will reflect
'both prior to April 1, 1985 and subsequent documentation. The team concludes
-
that DAP procedures address the staff comment.
Staff Coninent C.1(2) (closed)
Safety-significance evaluations must be performed using Code or regulatory criteria. The CPRT must provide procedural direction or instruction to ensure that the techniques used for safety significance evaluations and the extent of.
i the evaluations address each criterion that formed the basis for the original design.
DAP Response DAP agrees that when a design, corrective action, or safety significance evaluation is reviewed, the acceptance of that item should be based upon Code or regulatory criteria.
In addition, the procedures require that each 80P design criterion be evaluated at least once to detennine the acceptability of the design.
B-1 b
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NRC Evaluation Procedure DAP-2 states that deviations will be evaluated for safety significance. Deviations are defined as verified failures.to meet design
!
criteria comitments, including regulatory requirements, FSAR and other
'i licensing comitments, applicable code requirements, etc.
Therefore the team concludes that safety significance evaluations will be based upon criteria that formed the basis for the original design.
Staff Coment C.1(3) (closed)
The CPRT must define " root cause" and " generic implication" or issue
procedural direction / instruction to ensure that persons performing root
,
cause/ generic implication evaluations have a common understanding of the factors that affect the determinations. The staff anticipates that the CPRT will consider the following, as a minimum, in determining the root cause of-
' deficiencies: personnel, process, procedures, design (as it affects construction), materials,andmanagement..
DAP Response Procedure DAP-7, " Trending and Generic Implications", Rev. 1, dated August 22, 1986, provides procedural direction for the performance of root cause and generic implications evaluations. This procedure defines the terms " root cause" and " generic implications" and establishes a method for performing these evaluations.
NRC Evaluation DAP-7 Attachments A, D and E indicate that root cause evaluations will consider procedures, training and qualification of designers, management, and design process aspects (such as documentation, information transfer, technical input and use of industry codes and standards).
DAP-7 adequately addresses the staff comment.
Staff Coment C.1(4) (closed)
For issues classified as deviations in ISAPs, 000 and DAP (discrepancies that do not meet licensing criteria), the corrective action will be either (a)
.
modification to meet licensing criteria, (b) acceptance of the deviation (
throughanappropriatenonconformanceevaluationprocess,or(c) justified modification of the licensing criteria.
Item (b)abovemustbesupplementedto l
include a justification for not meeting the licensing criteria and the
,
appropriate documents must be modified if modification is required. The FSAR
'
must accurately describe the plant.
l DAP Response i
DAP agrees that the FSAR must accurately describe the design bases for the plant. The DAP will only close deviations when the FSAR or other comitment l
cocument is revised, or when a modification is performed to correct the deviation.
For those cases when the licensing comitment is changed, the change must be justified by TV Electric, concurred to by the DAP, incorporated within the FSAR, and submitted to the staff.
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NRC Evaluation The TERA response indicates that, for DAP, item (b) above, i.e., acceptance of the deviation through a nonconformance evaluation process, will not be used.
'
Modifications will either be made to meet the licensing criteria or there will be. justified changes to licensing criteria. This is an acceptable response to the staff comment.
Staff Comment C.1(5) (closed)
The staff evaluation presented in Section 3.5.2 under the heading "80P-Design Scope" is supplemented as indicated below. With respect to proven vendors, it
'
appears that Westinghouse may have design responsibility which extends beyond the standard NSSS four-loop scope which is specific to CPSES as described i
below:
Westinghouse maintains final design analysis (proof of design)
responsibility for the safety-related residual heat removal (RHR) system and the chemical and volume control system (CVCS). This responsibility requires the utilization of plant-specific data such as pipe routing, pipe size, and equipment locations.
Westinghouse maintains design responsibility for the ASME Code Class 1 auxiliary piping attached to the reactor coolant system (RCS) main coolant loop which requires plant-specific piping configuration, pipe sizes, and support locations.
During the evaluation of design interfaces for excluded vendors, if inconsistencies are identified regarding vendor exclusions, the scope of these vendors' participation in the CPRT Program Plan should be reevaluated. As part of this evaluation, a determination will be made to include in the DAP those B0P-design activities performed by Westinghouse if they are considered to be specific to CPSES.
DAP Response The " Phase 3" scope development process evaluated vendor exclusions, including that of Westinghouse. The bases for these exclusions are documented in the
" Phase 3 Summary Report", DAP-E-PM-001, Rev. 1, dated March 26, 1986. The Westinghouse scope for the RHR and CVCS systems is standard.
The design interfaces between the architect engineer's scope and excluded vendors are included within the DAP review.
For those cases where reanalysis or design modifications may impact the excluded vendor's design, these effects are documented in accordance with DAP procedures and are evaluated.
For instance, Westinghouse is revising their piping analysis to account for revised support stiffness values.
NRC Evaluation The CPRT evaluates unique vendors that have limited design experience in the nuclear field and may have supplied hardware only to CPSES. CPRT excludes proven vendors (e.g. Westinghouse) that have provided equipment over a number of years to many plants.
The apparent intent of this distinction is to focus on vendors whose design process has not been confirmed by
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previous reviews or operating history.
For the above examples, the utilization of plant specific data would not substantially affect the l
Westinghouse design process. The team agrees with DAP's position on excluding
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Staff Connent C.1(6) (closed)
The attribute for design considerations, approach, and methodology related to the homogeneous design activities (HDAs) could not be established because of a lack of information (p. 3-12).
DAP Response The HDA attribute of design considerations, approach, and methodology was validated in accordance with procedure DAP-21, Rev. O, dated December 9, 1985. Documentation supporting the grouping of design documents for each HDA is contained within the discipline Phase 3 Scope Validation engineering evaluations, memorandum, and checklists required by procedure DAP-21,
" Homogeneous Design Activity Validation and Selection of Specific Items for Review."
NRC Evaluation The NRC inspected DSAP VIII, X, and XI implementation, which addressed HDA confirmation. These inspections are documented in Inspection Reports 50-445/86-18,50-446/86-15 dated September 9, 1986 and 50-445/86-19, 50-446/86-16 dated November 4, 1986. The inspections determined that DAP-21 provided an adequate method for documenting the confirmation of homogeneity of design documents within each HDA with respect to design considerations, approach, and methodology. The inspections addressed the implementation of this method for most oi s ke HDAs reviewed by the team, and identified several open items requiring cor ective actions. This item can be considered closed with respect to SSER 13, subject to the team's follow-up on the specific inspection report open items.
Staff Comment C.1(7) (closed)
The CPRT Program Plan does not state whether closed external source issues (ESIs) may be considered by the CPRT as " givens," i.e., not reviewed under DAP. Unless justified otherwise, the staff requires that these issues not be considered as " givens" and continue to be treated as discussed in Section 3.5.1 of this SSER (pp. 3-12 and 3-13).
In general, this requires that a process exists for evaluating findings from ESIs that is the same as that for findings produced by the DAP self-initiated program.
DAP Response During the design of CPSES, design concerns and issues raised by external sources have been identified, investigated, and resolved to the satisfaction of the
,
These closed external source issues are reviewed by the CPRT as
/
source.
!
indicated in the CPRT Program Plan, Rev. 3, Appendix A, Section 11, page 7.
As such, closed external source issues are not considered as givens and will l
be treated as discussed in Section 3.5.1 of SSER 13.
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i NRC Evaluation Procedure DAP-2, " Documentation and Tracking of Issues and Discrepancies,"
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indicates that ' discrepancies" may result either from external source issues (ESIs) or issues found by TERA in the self-initiated program. Once a
[
discrepancy is identified, it is put'into the DAP-7 process which involves I
,
root cause and generic implications and trending evaluations.
TERA's I
statement that ESIs will not be treated as " givens" and the DAP-2 and DAP-7 j
processes ensure that ESIs are evaluated in the same manner as findings from
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the self-initiated program.
I Staff Comment C.1(8)(closed)
i The process for validating homogeneous design activities (HDAs) is totally based on engineering judgment and there is insufficient detailed information available at this time to permit an independent evaluation of the thought
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process-(p.3-13).
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DAP Response DAP-21,." Homogeneous Design Activity Validation and Selection of Specific Items for Review," provides procedural direction for validating HDAs. This process is documented on checklists as described under C.1(6).
-NRC Evaluation The team evaluation for C.1(6) applies to this item.
'
Staff Comment C.1(9)(closed)
During the audit of checklists, certain problems were found concerning the coverage of design activities and the amount of detail in certain review area topics (p.3-13).
DAP Response The DAP has modified selected checklists to provide greater detail as requested by the NRC staff.
NRC Evaluation NRC Inspection Report 50-445/85-17,50-446/85-14 dated January 21, 1986 identified items concerning the coverage of design activities and the amount of detail in :ertain review area topics. Most of these items involve review checklist development and were evaluated by the team in its follow-up' to the inspection report.
In addition, the NRC inspection reports referenced in C.1(6) above address the team's review of implementation of the checklists in DAP reviews.
The team will follow-up on open items with respect to these reviews.
In view of the team follow-up actions with respect to these three inspection reports, this SSER 13 item should be closed.
.
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StaffCommentC.1(10)(closed).
The CPRT Program Plan allows for specific detailed checklist reviews to be substituted with applicable results from the CPSES testing programs.
Insufficient information has been provided in the CPRT Program Plan to permit an independent evaluation of that process for allowing these substitutions
'
(p. 3-13). The staff is concerned about the ability of the DAP to extrapolate equipment test results to other design activities not selected for review.
.
-DAP Response Currently, the DAP is not using test results in. lieu of design reviews.
If this option is elected, procedures / instructions will be issued to guide these evaluations, and appropriate consideration will be given to the staff's coments.
NRC Evaluation The original NRC concern as to extrapolation.is moot because the Stone and Webster Design Validation Program is validating all safety-related documents.
Staff Coment C.1.(11) (closed)'
There is lack of specificity describing the process that governs scope expansion based on findings from the evaluation of external source issues or.
the self-initiated evaluation. Also,-the CPRT Program Plan does not describe how the ESIs, before being incorporated into the review of HDAs, will be assessed'for root causes and generic implications and how the findings will be factored into self-initiated evaluation.
(p.3-14).
DAP Response Scope expansion is governed by Attachment 4 of Appendix A of the CPRT Program Plan. The bases for scope expansion are documented in DAP engineering evaluations per DAP-8. The DAP has provisions for ensuring that ESIs are
. covered by HDAs.
NRC Evaluation Procedure DAP-3, " Development and Validation of Self-Initiated Scope," states that " scope expansion is required for identified deficiencies, one or more deviations that would be likely to' result in undetected safety-significant deficiencies if appearing elsewhere, and identified root causes that can affect design' activities outside or inside the scope of review. The scope of the review will be extended to similar designs or design processes as a minimum, and to the level. indicated by the nature of the potential root cause."
DAP-2, " Documentation and Tracking of Issues and Discrepancies," indicates that deficiencies and deviations may result from either external source issues (ESIs) or the self-initiated evaluation. Therefore either source of issues may result in scope expansion. DAP-7, " Trending and Generic Implications Evaluations," indicates that ESIs, which may result in deviations or deficiencies (based on DAP-2), will be assessed for trends, root causes and
.
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generic implications. While DAP-3 (above) describes how ESis may ultimately result in self-initiated program scope expansion, the DAP-7 evaluations impact corrective action programs, e.g. with respect to Issue Resolution Reports.
The DAP procedures adequately address the staff comment.
StaffCommentC.1(12)(closed)
Insufficient information has b' een available to the staff to permit an l
evaluation of the process to establish the initial HDAs as well as their validation. Therefore, the staff cannot make a determination at this time concerning the ability of the DAP to extrapolate results (pp. 3-14).
DAP Response SeeanswertoC.1(6)
NRC Evaluation See the team evaluation for C.1(6). The referenced inspection reports addressed the establishment and validation of HDAs as well as the ability of the DAP to extrapolate results based on sampling the HDAs. Open items pertaining to these inspections will be folicwed-up by the team; this SSER item
l may be closed out.
l StaffCommentC.1(13)(closed)
'
The applicant is required to prepare a matrix that correlates the number of discipline HDAs (gn criterion attribute has been reviewed to the associa items that a desi p. 3-18).
DAP Response DAP will develop a correlation of the number of times a design attribute associated with an HDA has been reviewed.
The data gathering associated with developing this correlation is controlled by discipline instructions.
NRC Evaluation The response adequately addresses the staff comment.
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StaffCommentC.1(14)(closed)
The process for identifying unique vendors has not been described in the CPRT program (p. 3-11).
DAP Response The DAP defines " unique vendors" as those who have never supplied safety-related equipment to nuclear plants other than CPSES. The process for identifying unique vendors is documented in the " Phase 3 Summary Report," DAP-E-FM-001, Rev. 1, dateo March 26, 1986, Appendix B.
A preliminary list of unique vendors
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was identified by each DAP discipline and documented in Revision 0 of their Phase 3 Scope Validation engineering evaluations.
This preliminary list was j
compiled based upon the knowledge of vendors by the discipline personnel and a
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h review of related industry hardware literature.
Subsequently, an information search was performed to determine if these hardware vendors provided safety-related equipment to nuclear plants other than CPSES. Based on this latter review, it was concluded that there are no unique vendors. The results of this review are documented.in Appendix B to engineering evaluation DAP-E-PM-001,
.Rev. 1.
x NRC Evaluation The' team reviewed DAP-E-PM-001 documentation and determined that it adequately TERA's conclusion that there are no " unique" vendors based on (1) greed wit documented a process for identifying unique vendors.
The team a the above i
definition of unique vendors, and 2) documentation indicating previous nuclear experience for CPSES component suppliers.
C.2 DSAP VIII - CIVIL / STRUCTURAL (INCLUDING CABLE TRAY / CONDUIT SUPPORTS)
StaffCommentC.2(1)(closed)
In order for TERA-to perform an integrated review of major concrete and steel structures in a manner consistent with its commitments referenced in-Inspection Reports 50-445/85-17 and 50-446/85-14, Appendix 2, page A-4, unique loading determinations must be performed for the referenced buildings (i.e.,
auxiliary building, fuel storage building, containment building, and other portions of selected buildings).
DSAP VIII, Section 4.3.2.1, " Load Determination," indicates that only the auxiliary / electrical buildings will be j
reviewed. This is inconsistent with TERA's commitment and, in fact, precludes
{
the performance of a thorough review. TERA should review other buildings than those listed in DSAP VIII, Section 4.3.2.1, " Load Determination."
DAP Response All loading determinations of importance are being appropriately included in the review of the individual buildings selected for review (e.g. containment, containment internal structure, Auxiliary / Electrical Building, and Fuel Building).
The " Load Determination" topic in DSAP VIII addresses areas where unique calculations were performed for the determination of specific loadings.such as seismic analysis and tornado loads. All other loads are examined as part of individual structure / component reviews being performed in the other topical areas.
NRC Evaluation TERA reviewed the two areas where unique calculations were performed for load determination, i.e. tornado and seismic. The tornado calculation was to all buildings, and the auxiliary / electrical building was selected (gen due to its complexity) as being representive of seismic analysis.
For other buildings, the load determinations were included in the building calculations reviewed by TERA, rather'than in unique calculations. The TERA response adequately addresses the staff comment.
StaffCommentC.2(2)(closed)
Thermal' loadings or expansion considerations must be considered in the
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evaluation of the reactor building internal structure since this is a B-8
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fundamental design consideration (e.g., to mitigate the effects of thermal expansion). Section 4.3.2.1 should be revised to include thermal load considerations for reactor building internal structure.-
DAP Response Thermal loadings and expansion considerations are beir; evaluated for the reactor building internal' structures and are included as checklist attributes
'
to be used for this structure. _It is not' intended to provide complete.
descriptions of all design review attributes within the general scope descriptions of the DSAP.
Results of DAP assessment are presented in issue resolution report DAP-E-C/S-502.
NRC Evaluation The response addresses the. staff comment in-that thermal loadings' and expansion considerations are being evaluated for the reactor building internal'
structures. Such detail, documented in review checklists and issue resolution reports,. need'not be explicitly. stated in the Program Plan, i.e. 'in general scope descriptions of the DAP.
Staff Comment _ C.2(3) (closed)
The NRC inspection reports (50-445/85-17 and 50-446/85-14, Appendix 7, item 4.-
page A-26) discuss embedment load tracking. The TERA response indicates that final design loads will be coordinated with the civil / structural discipline (e.g., to confirm that building designs are consistent with the final design loads). Section 4.3.2.1 should be revised to address how original building design loads are reconciled with the final design loads.
DAP Response During the review of individual structures / components in all topics, final design load reconciliation is being reviewed on a selected basis.
In addition, the generic arogram implemented by G&H to reconcile original and final design loads is )eing reviewed.
Results of the DAP~ assessments for this item are presented in issue resolution report DAP-E-C/S-516.
NRC Evaluation The TERA response addresses the staff comment.
It is nec necessary for this detail to be included in DSAP VIII.
Staff Connent C.2(4) - To be addressed in NRC review of cable' tray supports.
C.3 DSAP IX - PIPING AND PIPE SUPPORTS - to be addressed in NRC review of Piping / Pipe Supports
.C.4 DSAP X - MECHANICAL SYSTEMS AND COMPONENTS StaffComment(closed)
The CPRT should specify where in the DAP Phase 3 process the active valve issue is being eddressed. Since the Program Plan intends to provide complete coverage of all areas with safety significance, the CPRT should consider the issue of
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active valves in the Program Plan's root-cause/ generic-implication evaluation.
The CPRT's response to the staff concern did not specifically address the issue of active valves nor did it provide ar.y commitment to evaluate the significance of the errors. The CPRT should specifically review whether any procedure exists to document deficiencies in specifications detected by vendors, whether there exists any documentation of or prompt followup of deficiencies such as those identified with active valves, and why the system to control the quality
,
of design documents did not detect that the documentation had deviated from FSAR commitments.
DAP Response The overview of the TUEC review of active pumps and valves is included within Topic M43 of DSAP X.
The DAP review includes the overview of the TUEC review i
of active pumps and valves stress analysis and a self-initiated review of j
component functional requirements to ensure that specified component functional requirements have been met. Discrepancies found by DAP during its review are i
I documented within DIRs and engineering evaluation DAP-E-M-500, Rev.1, dated September 19, 1986. Generic implications and root cause evaluations perfonned in accordance with the CPRT Program Plan will investigate possible causes of safety significant deficiencies or adverse trends for use in determining
)
appropriate corrective actions. These evaluations would assess the project program addressing anomalies between specifications and vendor documentation.
This includes evaluating deviations in specifications detected by vendors, the
' resolution of these deviations, and the control of design inputs into specifi-cations. Where appropriate, information is requested from the QA/QC program regarding conformance of these procedures with the requirements of 10 CFR 50,
.
Appendix B and industry standards. Aoditional information may be found on j
pages 3, 19, 20, and 21 of DSAP X, and more generally in Appendix A of the CPRT Program Plan regarding overviews of corrective actions.
'NRC Evaluation The response adequately addresses the staff comment, i
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Appendix C~
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Resolution of Open Items from NRC: Inspection Report 50-445/86-17,'50-446/86-14 dated September 10, 1986 i
(Design Adequacy Program QA)
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The below open items from NRC Report 50-445/86-17,50-446/86-14 were addressed in TU Electric letter TXX-6082, dated November 12, 1986.
In each case, the team considers that the DAP action resolves the NRC concern. The following closeout documentation indicates the NRC original concern and the basis for NRC's conclusion that the response is acceptable.
(Closed)OpenItemQ-1:
Three completed records in the DAP QA manager's file were not in the CPRT Central File, nor did there appear to be a documented, systematic method to get such records into the CPRT Central File. TENERA
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corrective actions included a "DAP File Maintenance Guide" which assigns l
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responsibilities for file maintenance at the four main DAP work locations and provides document controls to ensure proper file coding, distribution, filing, and compliance with DAP QA records requirements.
(Closed)OpenitemQ-2: Centrary to DAP 17, four Corrective Action Reports (CARS) for which follow-up was not completed within two months were not reissued. The above CARS have been closed out. To prevent recurrence, the OAP QA Manager is now tracking CARS for items exceeding the two-month criterion.
In addition, the DAP Review Team Leader is reviewing this area quarterly.
(Closed) Open Item Q-3: Contrary to DAP-17, five CARS were not initially l
designated as a nonconformance or systcmatic deficiency. The above CARS were corrected. These omissions resulted from failure to translate this information from the handwritten to typed version and failure of the DAP QA Managers and Auditors to notice the omission.
The raised level of awareness on the part of these individuals should preclude recurrence.
(Closed) Open Item Q-4:
For approximately 50% of DAP personnel there was no documentation (as required by DAP-15) confirming that their reviews were confined'
to areas for which they had previous experience.
Subsequent to the November 12, 1986 letter, TERA informed the team that it had obtained the required documenta-tion from all of its reviewers, except for a few who were no longer involved at Comanche Peak. The team considers that it is not necessary to question the credentials of such individuals to perform the review since the present Corrective Action Program is covering at least the same areas reviewed by TERA.
(Closed) Open Item Q-5:
TENERA needed to assess whether its failure to identify
issues identified by the NRC team indicates any programmatic shortcomings in the internal audit progrm. This assessment determined that six of the 13 NRC Open Items were DAP procedural non-compliances. Of these six, two involved issues which had been previously identified by DAP QA audits. The other four were of a minor nature and had no impact on completed work. The remaining seven Open Items did not involve DAP procedural non-compliances, but were NRC/ TERA agreed upon upgrade activities.
Since the primary purpose of the internal audit program is to verify implementation of DAP procedures, the above assessment provides no evidence of internal audit programmatic shortcomings.
(Closed) Open Item Q-6: TENERA had not verified and certified that the lead auditor's education and experience met the qualification requirements of ANSI /
ASME N45.2.23.
Procedure DAP-23 Rev 0, "DAP Quality Assurance Auditor Qualifications" was issued (July 18,1986) and provides a mechanism for (
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TENERA qualification and certification of DAP lead auditors. The DAP lead auditor,was certified under DAP-23.
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l (Closed) Open Item Q-7: Some review checklist revisions were undated.
Revision 2.to DAP-14 dated August 15, 1986 included a new Attachment E, " Record Quality Requirements," which required (effective August 1,-1986) that corrections l
to all DAP records be properly annotated, initialed and dated. Corrective
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Action Report DAP-CA-QA-016 dated August 13, 1986 requests-that previously
. approved (prior to the Attachment E August 1,1986 effective date) design review checklists be reviewed for compliance with these Attachment E requirements.
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(Closed) Open Item Q-8:.The team identified two cases of misfiled DAP docouments.
A "DAP File Maintenance Guide" was issued on August 6, 1986. The guide delineates responsibilities for file maintenance, establishes a central
' distribution point in Berkeley, standardized file content log sheets, emphasizes responsibility for assigning file code numbers, and generally l
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'provides for duplication of the Berkeley files at CPSES.
l (Closed) Open Item Q-9: Contrary to DAP-5, in some cases DIRs identified with unsatisfactory-items were not identified in Type C checklists. TENERA
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internal audits had previously identified this as a generic problem (four
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CARS had been issued).
In response to CAR DAP-CA-QA-016, previously approved Type C checklists are being reviewed for compliance to DAP procedures,
including the above DIR traceability requirement.
In addition, the DAP l
Manager, on September 29, 1986, formally reminded project personnel of Type _ C
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checklist requirements that have been probhm areas (for compliance), such as DIR traceability.
(Closed) Open Item Q-10: Contrary to DAP-5, Type C checklists for Civil /
l Structural were not signed by the reviewer and/or the checker. Although the i
problem identified by the team was confined to Civil / Structural checklists,
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DAP is reviewing Type C checklists for all disciplines.
For the case identified by the NRC and any others identified in the DAP review, signatures will be obtained attesting to the specific reviews.
(Closed)OpenItemQ-11i Contrary to good practice, Civil / Structural checklists were completed in pencil.
To correct the above problem electro-static copies were made of pencil versions. Attachment E, " Record Quality Requirements" (see Open Item Q-5) to DAP-14 was issued on August 15, 1986, and prohibits future use of pencil for. record copies. A review of checklists in response to CAR DAP-CA-QA-016 will address compliance with DAP-14 requirements.
(Closed) Open Item Q-12: Although DAP procedures do not require this documentation, J
the team considers that TENERA should require justification when a Type C check-list criterion is determined to be not applicable. Revisions 3 to DAP-5 and 6, (
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both dated September 12, 1986, provide guidance for explaining non-applicability of checklist attributes when such basis is not apparent to a qualified reviewer.
This appropriately focuses on. technical decisions rather than obvious cases of non-applicability.
'n response to CAR Number DAP-CA-QA-016, checklists approved
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prior to the above revisions to DAP-5 and 6 are being reviewed with respect to the adequacy of documentation in this regard.
(Closed)'OpenItemQ-13:
DAP-21, Attachment B. " Homogeneous Design Activity (HDA) Description and Validation Checklist" requires signatures of a " preparer" and " approver" (Discipline Coordinator).
For numerous cases in the I&C discipljne, a " checked by" line was added to provide an alternate review when the " preparer" and " approver" were the same individual. However, the meaning C-2
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DAP-21
requires the approval of the Discipline Coordinator, which was accomplished for the above cases. The responsible individuals were advised that, although DAP-21.does not require so, " preparers" and " approvers" should preferably be different individuals.
No additional action was taken because (1) this was limited to the 180 discipline, (2) the HDA checklists are completed, and (3)
there is no reason to doubt the validity of the above referenced checklists, especially since the " checkers" were qualified for that function.
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Appendix 0 Resolution of Open Items from NRC Inspection Report 50-445/86-18,50-446/86-15 dated September 8, 1986
..(Hechanical Systems and Components)
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The following Open Items were identified in Inspection Report 50-445/86-18,
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50-446/86-15. The DAP responses were provided in the followup inspection.
Open Item M-1 (Closed)
For Calculation 229-9, dated January 1975, Component Cooling Water Pumps NPSH Calculation, there was no basis given for the 105 F operating temperature, which apparently reoresents normal conditions. Higher operating temperatures
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could be expected during'cooldown and startup, when initial heat rejection to this system from residual heat removal and plant sensible heat loads is hiah.
Higher temperatures would increase the vapor pressure and decrease available NPSH, but it was not clear that these modes of operation had been considered.
The calculation did not demonstrate whether the surge tank elevation used in the analysis represented the lowest anticipated level in the tank.
The friction factor assumed to calculate piping pressure drops was not sub-stantiated. The calculation states, "Specify pump as follows NPSH
i ft."
This apparent error permits the vendor to provide a pump with NPSH
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requirements which exceed the 104 feet available (per the calculation).
NPSH required should be specified as less than a specific value.
DAp Response:
DIR-D-0319, Rev. 2A addresses the NRC concern. All DIRs wili be resolved by the Project Corrective Action Program. See Open Items M-2, M-3, M-5, M-8, M-12 through M-14, M-18, and M-19 for other DIRs which address NRC concerns.
NRC Evaluation The team reviewed DIR-D-0319, Rev. 2A and found that it addressed the NRC The team plans to assess the effectiveness of the DIR resolution concern.
process on a sampling basis.
Open item M-2 (Closed)
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For Calculation 232-1, Revision 2, dated 11/22/82, Containment Spray Pumps, there is no basis given for the "K-factor" which accounts for sump charac-teristics in the computer program used to calculate line losses.
It was not clear how sump screen pressure drop, water level, and temperature had been l
accounted for in'the analysis.
q DAP Response k
DIR-D-0317, Rev. 3A addressed the NRC concern.
NRC Evaluation
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The team reviewed DIR-D- 0317, Rev. 3A and found that it addressed the NRC concern.
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Open Item M-3 Closed)
f For Calculation 311-1N, dated 4/12/78, Safety Related Chilled Water Pumps, l
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no basis is given for the 120 F water temperature or the tank level, such as whether modes of operation were evaluated to establish worst case l
conditions.
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DAP-Response'
y DIR-D-0616, Rev. 3A addresses the.NRC concern.
f NRC Evaluation'
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The team reviewed DIR-D-0616, Rev. 3A and found that it addressed the NRC concern.
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~ 0 pen Item M-4 (C'losed)
The team reviewed five calculations which were scanned and confirmed as homogeneous for HDA 159A, Water Supplies / Volume-Time Relationships.
The team concluded that three of.the_five scanned calculations, items (2) through (4)',
l differed in design methodology from the remaining two items.
Items (2)and(3)
J did not fall:within the headings of the review topic. nd HDA; i.e., water sources and water supplies.
For the two remaining scanned calculations ~
(528-2 and 229-12), it was not clear from the DAP-21 HDA checklist that the design considerations, approach, and methodology were similar. The team.
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considers that the scanning process should_be reaccomplished for HDA.159A.
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For-this HDA, and other HDAs-where the initial scanning. sample indicates methodology differences 90% of the documents should be scanned.
In addition,
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other.HDAs should be re amined for cases where Unit 2 documents, which are
- not-actual 4 calculations, are treated as calculations in the scanning process.
DAP Response
HDA:M159.0A entitled Volume / Time Relationship)s contains a total of 16 calcu.
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' lations. Each calculation assigned to.this iDA evaluates tank capacities,
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volumes ~, levels, and fill / depletion times based on system flow rates and required total system flows. The DAP HDA M159.0A checklist dated February'26, 1986 confirms.and documents-the homogeneity of the associated design activity-by scanning five calculations within the.HDA related document. population.
These were calculations 311-4, 215-12, 229-12, 238-2, and 241-10.
Each of these calculations exhibited similar criteria, and design considerations in that all were performed to determine volume / time related system parameters using standard engineering. techniques for. calculating volumes, thermal expansion and transferring fluids. The..NRC scanned calculations, 528-2, 2-215-7, 215-7, 238-2 and 229-12, also exhibit similar design considerations.
-i approach. and methodology. Several of these calculations could be deemed as
" trivial" bect.use the calculation-involves determining a volume or tank size rati;er than evaluating component performance for controlling system operating modes. Although DAP agrees that evaluating component performance is more complex and uses more of the methods and approaches defined by the HDA, it is. believed that.both documents are occupants of the same HDA.
The NRC IE audit team concluded that three of the five documents scanned by L
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the review team differed in design methodology from the remaining two.
Although the complexity of the calculational methodology may have differed (i.e., iterative process versus non-iterative calculation), similar calcu-
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lational methods and equations were used which are consistent with the HDA topic definition.
Calculations (2) and (3) reviewed by the NRC audit team deal with the Diesel L
Generator 011 Tanks. The calculations determine the minimum tank dimensions based on fuel consumption, diesel generator size and a licensing commitment.
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l This method and approach is consistent with.other calculations assigned'to.
this HDA. The difference in fluids, water versus diesel oil, was judged L
. insignificant within these technical applications and did not constitute a
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significant change. The title of HDA M159.0A is Volume-Time. Relationships,
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-and therefore, does not limit' coverage to only hydrous fluids.. Calculation 2-215-7 which is, in fact, a statement of applicability of Unit 1 Calculation
215-7:to Unit 2, belongs within the HDA because'it justifies.that the identical criteria,' methodology, design considerations, and approach is applicable.
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Because of the similarity of the two units, Gibbi & Hill used Unit I calculations-to' support the design basis.for Unit 2.
In selecting _ specific items for review (e.g... calculations, drawings, components) within HDAs for CPSES Units 1 and 2 and for selecting systems and structures for incorporation into the DAP review scope, there was a bias towards selection of more items from Unit i versus Unit 2.
Justiff.:ation is provided in engineering evaluat+ons'to support selectian of documentation for review and to address the bases for drawing the conclusicas that are applicable to both units.
Based upon the' above, DAP-does not concur in' the NRC IE audit team's recommen-dation to reperform the scanning process'for.HDA M159A for the above reasons.
Subsequent to the NRC IE inspection, DAP HDA M159.0A checklist was revised to add calculations 215-7, 528-2, and 202-22 to the list of scanned documents and to transfer calculation 311-4-to HDA M159.0B because calculation 311-4 was performed by a different.Gibbs 8 Hill design-group than the calculations assigned to HDA M159.0A.
Out.of the population of 16 calculations, calculations 206-5 and 528-2 were chosen for review of HDA M159.0A. As discussed in Apr;endix F of EER DAP-E-M-002,' calculation 206-5 was chosen for review because it calculated the Condensate Storage Tank volume which is the prfmary water source for the AFW system, and calculation 528-2 was chosen for review because it calculated
the Refueling Water Storage Tank Volume requirements.
NRC Evaluation The team agrees that the documents scanned by DAP, as well as those identified in the.NRC concern, all fall within HDA M159.0A. The differences identified by the concern appear to be matters of complexity rather than design methodology.
Open Item M-5 (Closed)
Calculation 215-11, Revision 2 dated 5/23/83, determined line losses from
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an air receiver to the diesel generator header and established the volume of
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-the receiver. The number of diesel generator starts assumed was not sub-stantiated. ' For Calculations 215-7 and 229-12, no basis was given for input.
i For 229-12, it was not clear whether operating temperatures represented worst
case operating modes.
DAP Response DIR-D-0556, Rev. 2A addresses the NRC concern.
NRC Evaluation
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The team reviewed DIR-D-0556, Rev. 2A and found that it addressed the NRC concern.
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.0 pen Item M-6 (Closed)'
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J Calculation 229-14 and Addendum 1 determined-the-CCW outlet temperature pro-
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file as a function'of time, assuming a constant overall heat transfer coef-
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ficient and' accounting for variations iis the Safe Shutdown Impoundment (SSI)
temperature.=. However, only the LOCA and cooldown_ modes of operation were evaluated. The vendor provided design data for several modes of operation
. including: regular. operation, regular operation with other unit in reactor
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cooldown, reactor cooldown at four hours, initial recirculation, recirculation
with minimum' safeguards, and design. There was no evidence that any of these modes'of operation were considered with respect to determining the most limiting
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mode of. operation, or that the calculated modes enveloped'those not considered.
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In addition; there was no apparent consideration of the effect of (1)-a " clean"
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CCW heat exchanger on containment heat removal rates during a LOCA, and (2)
higher heat loads removed from containment during a LOCA on SSI temperatures, j
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Calculation 229-14 notG that,coolipy water temperatures are glimihd by equipment within tk1Westindouse scope of supply, with a madmum allowable CCWtemperatureofabhoximately-1WF.'MaximumcalculatedCCWtuaperaturc
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is 133'F. This, the above considerations are significant with respect tc/
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potentially exceeding *the maximum allowable cooling water temperatt.res jmposed by WestinghourM.
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DAP Response u
9-14 and Addenitum 1 determine the CCho'utlet. temperature as
Calculatict.t a function cf time with an assumed constant heat transfer coefficient and-variation $intheSafeShutdownImpoundment(S3D) temperature. The DAP review h tterminea that the modes evaluated (LOCA and Cooldown) en d op
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.tendorsupi,Meddesigndatafortheothermodesihnt)fiedbytheNRCIEaudit from the vardus, review conclusion wts based on th6 fget that the heat.t team. This XP-sysfxms for the modes chosen Were thgan to produce the /
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I maximum heaf lud anoLwerel conservatively assumed to.be instantaneously y
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rejected to he heat $1nk.1 This assumption also envelops consideration cf a l
clean CCW heat-exchanger on containment heat removal rates and highertheat i
loads removed from the containment on SSI temperatures.
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However, the DAP review found that the assumption of a <;cnstant heat transfer jrate was inconsistst with data supplied by the vendy in Instrue!4n Manual l
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CP-0049-001 and in Specification 2323-MS-49, Revision' ?, Appendix 5, which indicate that the hat transfer rate could be as much as 40% lower than used
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y I-in the calculation.' The reduced heat trtnsfer rate could/ result in a LOCA CCW temperature of approximately 154'F in)teld of.133*F. DlR 0-0158 was
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written to document this concern and has twen included in the Project
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(h MC Evaluatiork
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,g HDAP statesithat heat transfer from the various dystems for the' LOCA and cooldown
'ri modes-prooucesthemaximumheatloadasdwascodervativelyassumedtobe
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fristantaneously refheted to the heat sink. The< team agreed yith DAP that this envelops the teaNs concerns as to other modes,* r. consideration of a clean CCW
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heat exchangerNnd the elfsct of higher heat loads removed from the containment
pn SSI tempWLsres.
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l Open Item M-7 (Closed)
The team reviewed Calculation 233-16, Rev. 1, 2/7/80, SSI Heat Loads, which l
served as input to the SSI hydrothermal simulation report, dated 5/80.
This calculation indicated a CCW temperature ~of 110* was assumed for the cooling
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water.to the containment spray and residual heat removei heat exchangers,
- which is lower than predicted in calculation 229-14 (13 *F) and implies the use of lower SSI temperatures.
DAP Response Calculation 233-16, Rev.1, assumes a CCW temperature of 110*F for cooling water to the containment and residual heat removal exchangers in lieu of
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the'133*F from Calculation 229-14. This variation was also discovered during
.the DAP review and was found to be acceptable, since a 110 F CCW temperature
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would result in a higher heat transfer rate from the plant systems to the SSI. Therefore, a 110"F CCW temperature is more conservative in determining heatup of the SSI than the steady state temperature of 133*F.
In addition, l
the DAP review indicates that the effect of using a 110*F CCW temperature
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on the steady state SSI heatup is negligible.
j NRC Evaluation q
more' conservative in determining SSI heatup and that the effect of using 110*
vs 133* has a negligible effect on SSI heatup.
Open Item M-8 ( Closed)
c The team noted a discrepancy in Calculation'233-16 between the heat loads at one hour after LOCA tabulated for the containment spray and residual heat removal heat exchangers in Table 3 Sht. 4 (325 E+6 Btu /hr), versus Figure 5 (370 E+6 Btu /Hr).
If' the correct heat load is 370 E+6 Btu /hr, it will affect the results of calculation 229-14 and the abovt SSI hydrothermal simulation 1'"
report which are based on 325 E+6 Btu /hr. : TERA advised the team that this j
calculation will be reviewed as part of another HDA and the discrepancy will i
be. investigated.
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DAP Response l
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Calculation 233-16 was assigned to HDA MI63.0 and was reviewed as part of
Topic M44'by the DAP. DIR-2441 has been written to document the discrepancy
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F found between the heat load values. The effect of this DIR plus the other 42 DIAS resulting from the review of this topic are included in the Project I
Corrective Action Program.
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NRC Evaluation
The team' reviewed DIR-2441 and found that it addressed the NRC concern.
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l Open Item M-9 (Closed)
The'above concerns and inconsistencies (0 pen Items M-6 through M-8). indicate the need'for.an integrated analysis of all systems-involved in the total heat
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removal train from containment to the SSI. As a related matter, the following cases should be evaluated to envelop the total effect of heat exchanger
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~ fouling on performance during a postulated LOCA.
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-(1) To maximize CCW temperature - Clean RHR and spray heat exchangers
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' and fouled CCW heat exchanger.
(2) To maximize containment sump temperature (maximum containment
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pressure) - All heat exchangers fouled.
(3) To maximize heat load to the SSI - All heat exchangers clean.
DAP Response
- The NRC IE audit team noted that a calculation is not available for the component cooling water system that includes a comprehensive model for all system-heat inputs. system components, and the ultimate heat sink. The project calculations reviewed by DAP modelled heat inputs, system components, and
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ultimate heat sink in-separate calculations with the interfaces between these models: handled as input.
This is not an unusual; approach, especially con-sidering the time when the calculation was performed.
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The DAP calcul'ational review was conducted to determine if the component cooling heat exchanger was sufficient to meet system requirements. The DAP review of
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the calculations included reviews of design inputs within the bounds of l
engineering reasonableness to determine that the proper design conditions were used and that there~is not a more limiting design condition that may have been overlooked. DIRs were prepared which identified discrepancies within the CCW heat exchanger documentation concerning the component's capability to fulfill its design requirements for the various design conditions specified. There is,
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therefore, no need for the DAP.to consider additional. evaluations in this area, although the Project is considering the cumulative effect of the DAP and NRC H
concerns.in the Project Corrective Action Program.
NRC Evaluation Resolution of DAP and NRC concerns documented in DIRs for the CCW system and pertaining to Open Items M-6 and M-8 as well as the Project Corrective Action Program should provide adequate design assurance for the system.
Open Item M-10 (Closed)
DIR D-0147 identified the absence of documentation to substantiate the sizing of the thermal relief valve on the residual heat removal heat exchanger. TERA used the Gibbs ano Hill sizing approach to determine whether this valve was properly sized. The TERA calculation indicated that the valve size (26 gpm)
was inaoequate and that a valve size of 58 gpm would be required. TERA stated that they performed the alternate calculation to determine the significance of Gibbs and Hill's calculation omission, not to bound all possible operating conditions. The DAP plans to verify that corrective action resulting from D-6 i
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this discrepancy will bound all anticipated system conditions to ensure that the component is properly sized for its intended service. The team considers that any conclusions in this regard should also be applied to valves not addressed by DIR D-0147.
DAP Response In reviewing the overpressure protection design, the DAP identified that the relief valve for the RHR heat exchanger was not included in the sizing cal-culation. Upon investigation and performance of an alternate calculation, it was determined that the valve was undersized. This discrepancy was identified l
in DIR D-0147.
No additional effort was made to ensure that the DAP calculation was bounding
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for all operating conditions, since the DAP prepared calculations are not calcu-lations of record and are used solely to assist the DAP in reaching conclusions and classifying DIRs (e.g., deviations, deficiencies).
Because of the truncation of the DAP activities (as directed by the SRT in letter CPRT-876), the DAP will l
3 not overview the project's corrective action performed to resolve this discrepancy.
DAP reviews of all other relief valve calculations determined that bounding conditions were included and that no further review is necessary.
During the DAP review, it was also determined that several components were not adequately protected against potential overpressure conditions.
The results of this review were documented in DIRs D-0124, D-0125, and D-0144 as discussed in IRR DAP-E-M-502 and EER-DAP-E-M-003.
NRC Evaluation The combination of the Project's Corrective Action Program and its actions to resolve all DIRs (including D-0147) should provide verification of corrective action on sizing the thermal relief valve for the residual heat removal heat exchanger. The DAP response indicates that relief valves not adoressed by DIR 0-0147 have since been validated by DAP with respect to bounding conditions.
Open Item M-11 (Closed)
Line 2-CCI-183-152-2 has no relief protection for the portion which is normally isolated and penetrates containment. Any coolant trapped between the isolation valves could develop excessive pressures curing temperature excursions in containment and compromise the penetration piping.
Proper relief protection should be provided for this portion of the piping, as well as for lines in other systems which can be. isolated with a trapped fluid subject to containment temperature excursions.
DAP RGsponse As discussed during the audit, some containment penetrations contain a small line with a check valve.
These are installed to relieve the pressure buildup in the isolated portion of piping between the isolation valves. These lines are routed into the containment and can accommodate thermal expansion between motor-operated isolation valves.
For those penetrations which are isolated by air-operated containment isolation valves, the pressure buildup between the D-7
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valves will cause the valve-to lift slightly providing relief..Both of these designs reflect appropriate design practices and meet the provisions of General Design Criteria 55, 56, and 57, and are consistent with Westinghouse standard
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design criteria supplied to others.
i The review of containment isolation of process piping and mechanical penetra.
tions was performed by DAP under Topic M01, HDA M057.0.
The review identified unevaluated piping arrangements, piping arrangements which were not in accordance
.with the FSAR, and piping arrangements which were indeterminate. These concerns are documented in 19 DIRs (2415-2433) documenting lack of compliance with GDCs 55, 56, and 57 which are being evaluated in the Project Corrective Action Program.
NRC Evaluation The isolation valves for line 2-CCI-183-152-2 are air operated. Based (
on the design feature (referenced by DAP) whereby the valves lift slightly to provide relief, the. team agrees with DAP that there is adequate relief
- protection in the line.
In addition, the DAP response indicates that DAP's overall review of containment isolation of process piping and mechanical penetrations has been effective in identifying needed corrective action.
Open items M-12, M-13, and M-14 (Closed)
i The eductor is required to add Na0H to sustain sump water alkalinity within a design pH range of 8.6 and 10.5.
In order to meet this FSAR commitment, NaOH flowrate must be maintained within a range during the injection phase for all possible system configurations. The checklist had an FSAR criterion-for minimum Na0H flowrate of 25 gpm, but none for the maximum flowrate. The team could not find a calculation relating the 25 gpm criterion to the pH range.
The purchase specification required the eductor to provide an Na0H flow of 45' gpm with given suction pressure and motive fluid flow characteristics.
-It was not clear how this 45 gpm requirement (which the vendor met) related to.the 25 gpm FSAR criterion or the design pH range. Assurance needs to be provided that the purchased eductor can maintain the design pH range for all system configurations.
As a result of the above concern, the team reviewed relevant calculations, l
232-16 and 232 7, which were not part of HDA M141.0 and had not yet been reviewed by TERA. Calculation 232-16, Rev. 1, dated 5/14/84 is apparently an analysis of NaOH flowrates for various system configurations. The team reviewed this calculation and found that it did not account for the Chemical Additive Tank (CAT) nitrogen blanket pressure and the effect of the eductor on the system flow rate.
The team reviewed calculation 232-7 Rev. 3, dated 5/21/84 which determined injection'and recirculation phase pH based on Na0H flowrates determined by
,
calculation 232-16. This calculation did not substantiate the aforementioned FSAR stipulated pH range and minimum Na0H flowrate. Since calculation 232-16 may be erroneous, its impact on calculation 232-7 needs to be assessed.
,
In addition, reanalysis of the Na0H flowrates may result in revised flowrates, which could affect the time assumed for fission product removal in the accident analysis and change the size of the CAT.
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'DAP Response The DAP review of G&H Specification ~2323-MS-35, Rev.'1..was performed to detennine whether the sump water alkalinity -(NaOH) eductor meets the design.
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a
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characteristics, including design codes and standards, material, operating condition, load combinations, seismic design requirements, construction
,
requirements, and testing and inspection requirements committed to in the.
FSAR. As such, the minimum Na0H flowrate of 25 gpm specified in the FSAR was assumed by the DAP. reviewer to be correct for this review. This per-formance parameter was met by the purchased eductor which was specified and -
supplied with a NaOH flow rate of 45 gpm with given suction pressure and motive fluid flow characteristics.
i DAP performed a review 'of Calculation 232-7 Rev. 3, ?nd Calculation 232-16, Rev.-1, for Topics M40 and M04, respectively. The results of the review
'
indicated that-the flow rates calculated in Calculation 232-16 did not-
'
properly reflect the correct rates for the injection and recirculation
.
phase pH values. Calculation 232-16 did not account for the pressure effects
' of the nitrogen blanket in the Chemical Additive Tank (CAT) or the effect-of the eductor on the system flow rate from the CAT. Combined, these omissions-may result in a flow. rate causing the pH value to be sufficiently different from that determined in Calculation 232-7. Therefore, the DAP review sub-stantiated the NRC audit concerns. DIR D-2208 was prepared to document the above discrepancy. The effect of this DIR and related concerns discussed
- in EER DAP-E-M-019 is-included in the Project Corrective Action Program.-
NRC Evaluation l
The DAP response resulting in DIR D-2208 addresses the NRC concerns.
I Open Items M-15 and M-21 (Closed)
TheHDA(M050.0SourceTerms-Accident / Normal)originallyhadtwelvecal-f culations, from which the following five were selected for scanning:
'
G8H Calculation 61, dated 4/21/75 G8H Calculation 75, dated 5/8/75 j
G8H Calculation 76, dated 5/8/75 G&H Calculation 239-7, Rev.1, dated 12/28/77 G8H SH-TMI1G Rev. 1, dated 2/11/82
l
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Three of the calculations were performed in 1975, one in 1977, and one in 1982.
Since the entire population covered the period from 1973 to 1982, the scanning did not represent equal time intervals, as required by DAP-21.
For example, there were calculations in the population from 1973, 1975, 1977, 1981, and 1982.
'
(There were no calculations for the years 1978, 1979, and 1980.)
For HDA-M006.0, three of the five scanned calculations were performed in 1979, one in 1980 and one in 1983. The 37 calculations in the HDA were produced between 1975 and 1984 (there were none for 1977). Therefore, the calculations scanned do not satisfy the DAP-21 requirement for equal time intervals.
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I DAP Response DAP-21 states, in part, that itemc to be scanned, "... shall be distributed -
approximately even though the period of performance of work as indicated by J
the current revision date of the documents." During the scanning process
.
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several documents were moved from one HDA to another because the original-assignment to an HDA based on a review of the document title was incorrect.
Based on these reassignments, the-scanning interval required by DAP-21 was not met at the time of the NRC audit. Subsequently, all mechanical HDAs that i
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have more than five occupants were reviewed to determine whether this require-ment was met. Based on this review, 10 HDA checklists were revised to include
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additional scans for homogeneity. As a result of this review, no HDAs were
>
required to be subdivided.
NRC Evaluation The DAP action to review all mechanical HDAs and revise 10 HDA checklists addresses the NRC concern.
Open Item M-16 (Closed)-
The original scanning of HDA-M050.0 resulted in identifying the need for a new HDA, M050.0B. The team found the new HDA included Calculation 239-7, Rev. 1, a hand calculation, together with four computer calculations (utilizing the HOMES computer code).
In this case, the team considered it inappropriate to' include the computer and hand calculations within the same HDA since they have different methodologies. TERA agreed, and plans to muve the hand cal-culation to another HDA, M050.0C.
DAP' Response I
TERA has transferred hand Calculation 239-7 to HDA M050.0C.
NRC Evaluation i
The DAP response addresses the NRC concern.
Open item M-17 (Closed)
On drawing TNE-MI-0206-02, Rev. CP-1, valve 1-LV2478 provides a break between Class 3 and Class 5 piping. This valve is an active component which provides makeup to the Condensate Storage Tank (CST). The valve is not instrumented to close upon the occurrence of a seismic event.
If at the time of an event resulting in the' loss of the Class 5 piping the valve is open to fill the CST, the single active failure of the downstream check valve (IAF-009) to close might drain the CST to below the minimum operating level needed to support the AFW system.
DAP Response The commitment by TV Electric for piping classification and barrier requirements is AhSI N18.2/ANS 51.8-1973 as contained in FSAR paragraph 3.2.2.
ANSI N18.2-1973 states that a suitable boundary between Safety Class 3 and a lower safety class can be one normally closeo valve. Valve 1-LV2478 is a normally closed, fail closed valve. As such, the DAP review of this design was found to be satisfactory.
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NRC Evaluation The team agrees that the design in question is acceptable based on the commitment to ANSI N1842-1973.
Open Items M-18 and M-M (Closed)
On drawing THE-MI-0206-01 Rev. CP-1, a normally open high point leakoff valve (1AF-120) provides the barrier between Class 3 and Class 5 piping; a 3/8 in.
flow restrictor is 'in the Class 5 portion of the line. This arrangement apparently violates ANSI N18.2/ANS-51.8, which requires that, for an open valve barrier, the loss of lower class components due to the seismic event should not prevent the system from performing its safety function.
In the current design, the 3/8 in. flow restrictor would be lost as a result of an
,
!
event, possibly resulting in an unacceptable loss of the AFW backup water supply (service water). The team was unable to find an analysis verifying the ability of the AFW system to carry out its safety function with the loss
.j of the 3/8 in, flow restrictor.
The team reviewed the pre-cutoff date flow diagram (2323-MI-0206, Rev. CP-5),
and found that the 3/8 in'. flow restrictor was located in the Class 3 portion i
of the line, thus surviving a seismic event. This design would have met the
. code requirement if an analysis had verified that the 3/8 in. flow restrictor
sufficiently minimized loss of service water. The team reviewed the Brown and Root piping isometric drawing (BRP-AF-1-58-005 Rev. 11) which indicated that the 3/8 in, flow restrictor is apparently installed in the Class 5 portion
?
of the line.
On drawing TNE-MI-0206-01, Rev. CP-1, a normally open low point leakoff valve (1AF-020) is shown to provide the barrier between Class 3 and Class 5 piping.
As in.the case for Open Item M-18, a 3/8 in. flow restrictor is in the Class 5 portion of the line, in apparent violation of ANSI-18.2/ANS-51.8. Comments for
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Open Item M-18 on the pre-cutoff date flow diagram and the Brown and Root isometric apply equally in this case.
.i DAP Response i
The DAP agrees with the findings of the NRC IE audit team. DIR D-0484 was issued on May 30, 1986 to document discrepancies for corrective action.
NRC Evaluation The team reviewed DIR D-0484 and found that it addressed the NRC concerns.
Open Item M-20 (Closed)
One of the calculations (241-2) (within HDA M 006.0, Pressure Drop) contained NPSH calculations. This calculation should also be included in an NPSH HDA.
i TERA should determine whether such inclusion affects the OAP-21 implementation j
for that HDA.
DAP Response l
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Several calculations scanned exhibited characteristics of a different HDA.
Specifically, Calculation 241-2 performed a pressure drop calculation and was j
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~ included in an NPSH evaluation. The DAP concluded that this design document I
was-primarily.a calculation of system resistance and should only be included in the most representative HDA. The attributes and methodologies involved for -
I the subject calculation were similar to the other' documents assigned to HDA M006.0 and did not require further subdivision due'to substantive differences.
]
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)
NRC Evaluation The team agrees that there is no need for Calculation-241-2'to be included in
.an NPSH HDA.
I Open Item M-22 (Closed)
I Several of the 37 documents in HDA-M006.0 were for Unit 2.
The team reviewed five of these ' covering the CCW, SSW, CT Spray, RHR and Boron Thermal-Recycle
]
systems:and found that they were not actual calculations.
Instead they stated i
that a Unit 1 calculation can be used for Unit 2 application, without providing
]
any justification with respect to physical similarity between the two units a
for the systems involved. Physical comparisons need to be made and a technical analysis of any differences should be performed.
DAP Response The need to perform a physical comparison between Unit 1 and Unit.2 to confirm applicability of Unit 1 calculation to Unit 2, although not covered in HDA
!
N006.0, was identified in the Issue Resolution Report (IRR) covering System-Design. The Project Corrective Action Program will respond to issues identi-fied in the IRR. Also' refer to the response to Open Item M-4.
l NRC Evaluation The-large number of. generic-issues and DIRs identified by the DAP, as well as the Corrective Action Program for both Units 1 and 2, resolve the team's concern that Unit I documents will be applied to Unit 2 without justification l
of physical similarity.
Open Item M-23 (Closed)
Gibbs and Hill apparently sent design information to vendors which effectively revisea design specifications, but Gibbs and Hill did not actually revise the TERA ensured that the seismic requirements imposed by design specifications.
the specification, including the effect of DCAs, were met by the vendor.
Separate reviews will be performed by TERA to ensure that the effect of design or field changes not reflected within the specification and interfaces with other disciplines were evaluated by Gibbs end Hill.
Evidence of these programs is shown in (1) DIR D-0089 and DAP-RFI-M-0002 concerning documentation to verify the as-built condition is qualified, and (2) TERA memo DAP-M-191, March 21,1986, which outlines the program for the. final as-built load evaluation.
DAP Response DAP's efforts to ensure that design or field changes not reflected in design specifications and DCAs were evaluated by Gibbs and Hill are discussed in IRR DAP-E-M-500 and EER DAP-E-M-500, Appendix R.
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l NRC Evaluation l
The team considers that the Impell equipment qualification corrective action program should address TERA generic concerns identified in the above documents.
Open Item M-24 (Closed)
A computer program (ANSYS) was used to analyze the fuel oil day tank. The computer run, which consists of the finite element representation of the component, the loadings and the results (deflections, forces, moments and stresses), was referenced in the vendor qualification report, but was not reviewed by TERA. The team considers that TERA should evaluate the computer modeling, loadings and results in order to reach a conclusion as to whether l
the vendor qualification satisfied the design specification.
DAP Response As stated in the NRC IE audit report, DAP ensured that the seismic requirements imposed by the specification, including DCAs, were met by the vendor. However, as part of the DSAP scope of review for this area, the references to the vendor qualification report were not reviewed.
Because of the number of DIRs identified during the DAP review, TU Eletric determined that they would initiate a complete and comprehensive corrective action in response to Issue Resolution Report, IRR DAP-E-M-500, Seismic Qualification. As part of this corrective action, verification of vendor seismic qualification analyses will be performed to assure that they meet all specification requirements.
NRC Evaluation The team agrees that the equipment qualification corrective action program, including verification of vendor seismic qualification analyses, obviates the need for TERA to evaluate computer modeling, loadings and results.
Open Item M_-25 (Closed)
TERA identified a generic concern during the review of motor driven chilled waar recirculation pumps that all plant valves had been assumed to be oriented slong the plant coordinate axes system for purposes of seismic qualification.
This assumption may be unconservative since there may be different actual orientations of valves that, when seismic design accelerations are applied, result in greater stresses than those based on the assumed orientation. TERA identified other generic concerns with respect to compatibility of piping analysis as-built loads with the valve qualifications packages. TERA plans to review the valve qur.lification packages after these concerns are addressed.
DAP Response The DAP review identified concerns regarding assumed valve orientation, con-sistency between assumed modeling and piping analysis package, effects of non-rigid valve assemblies, valve operator supports, and interference assessment.
These concerns are addressed in IRR DAP-E-M-500 and EER DAP-E-M-002, Appendix R.
The resolution of these concerns have been incorporated into the Project Corrective Action Program.
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NRC Evaluation
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The team considers that the equipment qualification corrective action' program l
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should address TERA ~ generic concerns documented in the IRR and ERR.
_Open Item M-26 (Closed)
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Seismic. qualification checklists did not :for all appropriate cases, address stresses.due to operating loads, nozzle load capacity verification, and code l
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required load combinations, and verification that manufacturers installation requirements (e.g., bolt torquing requirements for anchorages) are followed or differences resolved.
DAP Response The DAP seismic qualification checklist addresses stress due to operating loads, l
including' nozzle, pressure, and temperature loads. The seismic qualification
review is limited to verifying the inclusion of all applicable loading for l
comparison to allowables. Nozzle loadings are. derived from pipe stress reports
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- and verified by the piping discipline. Verification of pressure and temperature parameters were performed in the component functional requirement checklist.
j Code required load combinations were evaluated in the equipment design
- specifications checklists. Discrepancies, if found, were identified by the -
DIR prMess (refer to DIR No. D-0191).
Installation requirements are: included in the QOC scope of verification with the mechanical erection requirements revi,wed by the DAP. Where seismic qualification installation. requirements wer;J specified,' walkdowns were performed to ensure installation was in accor/ance with qualification requirements. Discrepancies (D-1217, D-1376)
were identified by the DAP process.
NRC Evaluation The DAP response adequately addresses all of the above NRC concerns.
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Appendix E
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Resolution of.0 pen items from hRC Inspection' Report 50-445/86-19,50-446/86-16.
-(Civil / Structural,ElectricalandI&C)
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I The following Open Items were identified in Inspection Report 50-445/86-19, 50-446/86-16. The DAP responses were provided in the followup inspection.
Open Item C-1 (Closed)
l Safety-related architectural items, e.g., computer room floors, interior doors, door anchors and stops, tornado gratings, tornado missile stops or deflectors and tornado wall vents, should be reviewed in two contexts:
1)
the interaction between seismic Category 1 and nonseismically designed components, and
2)
the tornado depressurization analysis where architectural details should be considered as potential missiles.
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 depressur-ization analysis review that is part of the current DAP civil / structural review scope (HDAs C004, C005, C006, C025).
DAP Response 1.
DAP confirms that the interaction between Seismic Category I and non-seismically designed components is covered under ISAPs I.c ar.d II.d.
ISAP I.c addresses the interaction between Seismic Category I component and nonseismic Train C conduits of 2-inch or smaller diameter. The balance of the interaction between Seismic Category I and nonseismically designed components is covered under ISAP II.d.
2.
Six calculations were scanned under HDAs C005, Tornado Wind Loads, and C006, Tornado Pressure Loads. Out of these, five (5) were reviewed under the following HDAs:
DMI-9C,1 (Tornado Venting Pressure on Class IE Equipment) under a.
HDA C025.0.
b.
SMI-113C,1 (Pressure Due to Tornado Venting on Concrete-f uxiliary Building, Safeguards Building, and Fuel Building) under HDA C025.0, SAB-104C,1 (Floor Elevation 873'-4" Slabs & Beams) under HDA C070.0.
c.
d.
SMI-101C,4 (Gust Factors-Reactor Building and all Buildings Taken Together, Fuel Building) under HDA C004.0.
SAB-123C1,1 (Exterior Wall Reinforcing Above Elevation 810'-6"/
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807'-0" to Roof Vertical and Horizontal Reinforcing) under HDA C072.0.
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The ret r.f ig calculation, SAB-119C2,5 (Auxiliary Building) Design of Exterior Wall at N-Height & Top of Mat to Elevation 810'6"/807'0 was transferred to HDA C072 but was not reviewed.
Calculation SAB-119C2,4 (exterior walls at I
mat elevation 778'-0"/790'-6") which was also scanned under HDA C072 was reviewed instead.
No calculations were specifically reviewed under HDA C005 and C006. These HDAs werc more appropriately reviewed together with HDA 025, Pressure Analysis--
External Pressure--Tornado Venting Analysis, since the tornado wind and pressure j
loads were selected or calculated at the same time they were used in the analysis calculations.
i DAP confirms that no documents were identified addressing tornado depressurization analysis where architectural details are considered as potential missiles.
This aspect of the design is discussed in DAP Engineering Evaluation DAP-E-C/S-002, Rev. O, " Load Determination, load Distribution and Analysis, and Load Combinations."
NRC Evaluation The DAP response addresses the NRC concerns for reviewing safety-related j
architectural items.
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Open Item C-2 (Closed)
Transfer of loads to the civil discipline, e.g., from the piping discipline, is an important interface which needs to be verified. TERA has a DIR and a related 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 for HDA C064. The TERA memorandum also applies to HDAs C058, C070, C073, 0077, C078, C080, C084, and C087.
In addition, a final load verification j
program was performed by Gibbs and Hill on a sample basis. TERA will review i
this under HDA C190 with respect to component selection basis, acceptance criteria and implementation.
DAP Response The DAP review focused on the Gibbs and Hill document " Program for Final j
Load Verification for Category I Concrete Structures for Electrical Raceway Systems, Piping Systems and Equipment Loads" including related design calcula-tions, construction drawings and Design Authorizations.
In addition, other calculations for as-built loads not included under this program were selected as part of the DAP review. These reviews were performed as part of the review activities in the following topical areas: containment liner / liner attachments, anchorages, reactor building internal structures, penetration sleeve / anchorages, structural steel and auxiliary butiding.
Based on the findings in the areas of interface and final load verification, the review of these topics was curtailed and Issue Resolution Report (IRR)
DAP-E-C/S-516, Rev. 0, As-Built Load Verification, was prepared to document findings regarding:
1.
Interfaces within the C/S discipline and between the C/S discipline and l
other disciplines.
2.
The accuracy of design documentation.
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NRC Evaluation-
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In addition to the above actions taken by DAP, the Corrective Action Program.
by Stone and Webster will address reconciliation.of loads and other interfacing
.4 information between disciplines.
s-Open Item C-3 (Closed)
i
'In the containment shell hasch design, the original analysis included the-Lstiffness 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 comitted to and requires consideration of both including and not including the liner plate, whichever represents the worst stress case.
.
DAP Response In the original review of this item, it was the judgerrent of the reviewer that the inclusion of the stiffness of the liner plate would have a minor effect and not alter the conclusions of the analysis. DAP concurs with the NRC that the calculation was'not fully in compliance with ACI/ASME 359 for this consideration and has documented this-item as DIR D-1987.
This~ DIR, together with other DAP findings of significance for this topic,
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is sumarized in IRR DAP-E-C/S-501, Rev. O.
NRC Evaluation
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The team reviewed DIR D-1987 and found that it addressed the NRC concern.
i Open Item C-4 (Closed)
In'the evaluation of the containment shell for the LOCA condition, the original
'
analysis assumed peak pressure and temperature on the containment liner and Additional uniform operating temperature gradient through the concrete shell.
justification should have been provided to show that this was, in fact, the controlling set of assumptions. Specifically, some possible combination of non-linear thermal gradient in the concrete shell and corresponding liner pressure and temperature conditions might be more significant than that assumed.
DAP Response i
In the original review of this item, it was the judgement of the reviewer, based on his past experience, that the assumptions used in the analysis would be controlling. While DAP still believes that the original assumptions
!
will control the design, the concern of the NRC reviewer has been documented in DIR D-1989.
j This DIR, together with other DAP findings of significance for this topic, J
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is summarized in IRR DAP-E-C/S-501, Rev. O.
NRC Evaluation
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1The ~ team reviewed DIR D-1989 and found that it addressed the NRC concern.
'Open Item C-5 (Closed)
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tin the containment shell design', the original analysis examined two possible
, conditions of an uncracked and a fully cracked concrete section. A partially
cracked'section should have been considered as well, i.e., as potentially the worst stress case.
This' concern also applies to the containment shell hatch design-(HDA C064).
DAP Response-In the original review of this item, it was the judgement of the reviewer, based on his past experience, that'the two conditions analyzed would adequately bound the design. While DAP still believes that this is true, the-
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concern of the NRC reviewer has been documented in DIR-D-1988.
This DIR,'together with other DAP findings of significance for this topic, is summarized in IRR DAP-E-C/S-501, Rev. O.
NRC Evaluation l
The team reviewed DIR-D-1988 and found that it addressed the NRC concern.
Open Item C-6 (Closed)
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 calculations. This finding applies to other HDAs as well; C077, C078, C080
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and C084. Specific areas of variability includes analyzing torsion, dynamic,
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amplification factors used. handling load interaction, consideration of thermal l
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 stresses.
i Due' to the above examples of variability in Gibbs and Hill methodology, the
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team is unable to reach conclusions as to the homogeneity of the specific
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HDAs.
Such conclusions are a prerequisite for assessing representativeness of the review sample.
,
DAP Response DAP agrees with the NRC that, for the above HDAs, the homogeneity requirement,
is not met due to high error rate and methodology variations in the Gibbs and Hill calculations.
In the absence of errors, the lack of homogeneity may have resulted in the need for additional reviews to allow the DAP to reach a sufficient' level of confidence for these HDAs. Had the additional reviews i
been conducted, either a sufficient set of consistent documentation would f
have been reviewed to support the homogeneity requirement at a subdivided j
HDA level or all or the relevant documentation would have been reviewed.
The additional reviews were not conducted because the number and nature of DAP findings for the HDAs'resulted in the DAP identified need and the TV Electric commitment to review all calculations associated with these HDAs.
DAP results for the listed HDAs are summarized as follows:
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HDAs 0073 and C084 in IRR DAP-E-C/S-504, Rev. 0, " Steel Design Methods and l
Criteria, Structural Steel, Monorail /Platfonns and SWIS Stop Gates."
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HDAs C077 and C080 in IRR DAP-E-C/S-506, Rev. 0, " Containment Liner and Attachments" HDA C078 in IRR DAP-E-C/S-507, Rev. O, " Spent Fuel Pool and Refueling Pool Liner and Attachments."
i NRC Evaluation The team agrees with the DAP logic that the error rate for these HDAs necessitated review of all calculations within the HDAs and thus negated the issues of homogeneity and extrapolation.
Open Item C-7 (Closed)
Question:3 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."
DAP Response The DAP review of the energy-absorbing materia! used in Pipe Whip Restraints has evolved as follows:
The design of pipe whip restraints' energy-absorbing material was originally done by G&H mechanical group and was intended by DAP to be part of the mechanical discipline review scope. At the time of the I&E audit, the mechanical review of this subtopic had not been initiated.
Prior to the
initiation of this raview, it was determined that there were a number of
'
significant f'.ndings, both on the structural design and mechanical lead definition for these restraints. Based on'this fact, the reviews of this item were not initiated but were documented as requiring review as part of
the corrective action associated with the other findings.
DAP results for both the pipe whlp restraint supports and energy-a:ssorbing material are dot.umented in Civil / Structural IRR DAP-E-C/S-505, Rev.1
" Steel Design Methods and Criteria--Pipe Whip Restraints" and Engineering Evaluation DAP-E-C/S-004, Rev. O, " Steel Design Methods and Criteria."
NRC Evaluation The DAP response states that the review of the energy-absorbing material was not initiated and would be addressed under the Corrective Action Program, lhis is acceptcble, j
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Open Items C-8 and C-9 To be addressed in NRC review of cable tray and conduit support corrective j
action programs.
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-Uping/ Pipe,S_upports.
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Open Items P-1 through P-17,
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To be. addressed in NRC review of piping / pipe supports-corrective action
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programs Electrical
!'l-Open Item E-1 (Closed)
The voltage profile checklist (DAP-CLC-E-001) did not question the verification of a Gibbs and 11111 in-house corrputer program, Voltage Program 1979, which was written for a programmable calculator.
DAP Response The issue of computer program verification was raised in other electrical-revie.vs and in other disciplines. Computer programs used for electrical
calculations have been identified in IRR DAP-E-EIC-501 as an issue.
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specifically addresses design verification of'such codes.
l NRC Evaluation J
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The IRR addresses the generic issue of computer programs used for electrical l'
. calculations and includes the design verification aspect. This resolves the team's concern as to addressing computer program design verification.
It is
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noted that the team found no error in this regard. We only questioned whether j
it would be addressed.
j Open Item E-2 Closed)
The team questioned whether TERA would review (1) the ability of the spent fuel
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pool cooling pump motor to operate at voltages below its rated voltage, and i
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(2) the adequacy of the voltage at the switchgoar close and trip coils.
i DAP Response
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Criterion 17.0 of "C" checklist DAP CLC-E-019, Rev. O dated 11/11/86, reviewed the ability of the SFP cooling pump motor to start at 70% of the rated voltage
.per the vendor documentation. DIR -D-1923 was written.under this criterion-
(D7.0) to document the incorrect minimum starting voltage specified. Lower l
voltage operation for the 250 HP SFP cooling pump motor was justified by
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Gibbs and Hill on the basis for the Service Factor of the motor as 1.15.
However, NEMA does not recomend a Service Factor more than 1.0 for motors greater than 200 HP. This has been discussed in DIR D-0293 in "C" checklist DAP-CLC-E-003,
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.Rev. O, dated 6/30/86. DAP calculation DAP-C-E-004, Rev. O, confirms starting voltage 70% (71.6% vs. G8H's 71.8%) and worst case running voltage of 90%
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(87.7% vs. G&H's 88.5%) of rated 460 volts'.
)
The checklist applicable to this subject was not complete at the time of the i
NRC review. Criterion 48.0 on C checklist DAP-CLC-E-004, Rev. O, dated 9/10/86,was used to review voltage on selected feeders including 125V DC control supply to switchgear. DIR #D-2047 was written to document insufficient voltage to 480V breaker closing coils.
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'NRC Eval'uation
The response. indicates that.the two areas identified by the NRC were reviewed by DAP.
Open Item E-3 (Closed)
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For chec'klist 0AP-E-008., the " Comments" column stated that what was described l
. in the " Description of Verification" column had been verified by the TERA L
- reviewer. The team questioned the accuracy of this verification because of errors in the references in the " Description of Verification" column that had not been iaentified in the TERA review.
In addition, the checklist listed
specific values for the undervoltage relay setpoints and the timing relay J
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setpoints. TERA stated that the review only confirmed the existence of the contacts and that verification of the acceptability of the actual values woulo be performed in topic E07; however, this distinction was not clear from the
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review checklist.
DAP Response Checklist DAP-CLC-E-008, Rev.'1, dated 12/16/86, has been revised since the audit and now has the same level of detail as other checklists that the NRC audit team reviewed.
It now indicates that the review verified the existence of the undervoltage relays and timers.
A reference has been added to indicate
.that-the setpoints.would be checked under 18C checklist DAP-CLC-I-007. The
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undervoltage relay setpoint calculations selected by DAP were' unavailable
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'for review because of an ongoing complete revision being performed by the project. However, other DAP reviews -identified numerous calculational and setpoint discrepancies, which resulted in the issuance of IRRs DAP-E-EIC-501 and -502 on electrical calculations and instrument setpoints, respectively.
NRC Evaluation The checklist revision addresses the NRC concerns.
Open Item E-4 (Closed)
i The schematic for the containment spray pump motor incorporated two separate engineering safety feature actuation relay contacts in the pump starting j
circuit, one for a safety injection signal and one for a containment spray j
signal. 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 automatica'ly open on safety injection.
l TERA stated that, based on the Westinghouse functional diagram, the valves j
would open on containment spray (not on safety injection), but they would i
verify this against the Gibbs and Hill schematic.
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DAP Responsg Containment spray initiation was subsequently reviewed in C checklist DAP-CLC-I-086 and determined to be in accordance with the FSAR description.
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NRC Evaluation The DAP review confirmed that containment spray isolation valves would automatically open on a Containment spray signal'but not on a safety injection signal,'i.e., precluding inadvertent containment spray.
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Open Item E-5 (Closed)
The remaining HDAs in topic Ell, including fire protection (50%), protective device settings,(10%), and flooding and missile protection (10%) were not available for the team's review. Additional areas which were not available for the team's review include topics E08, component functional requirements; E09, single failure / FEMA; E12, equipment installation design; and E13, emer-gency lighting.
DAP Response This NRC concern reflects the incomplete status of the Third Party review at the time of the audit.- The outstanding HDAs'in topic E11 have since been covered. Fire protection was addressed in an Issue Resolution Report (IRR)
DAP-E-EIC-505. A corrective action plan on fire protection issues was written by Impell Corporation and is identified as Generic Issue Report 01-0210-063.
Protective device settings, along with breaker coordination, were addressed by checklist DAP CLC-E-035.
Flooding and missile protection were addressed by the mechanical discipline.
Reviews of the additional topics have been performed since the audit and are documented in checklists and Engineering Evaluation Reports.
NRC Evaluation The topics identified by the NRC have now been reviewed by DAP.
Rather than review the DAP'results, the NRC plans to' review the Corrective Action Program which is intended to validate all safety-related design documents for Comanche Peak.
Open Item E-6 (Closed)
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.
i 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 incon-sistency was not noted on the TERA review checklist.
DAP Response The EQ review was cut short due to the large number of DIRs in a relatively small review scope. The DIRs represent one or more examples of the dis-crepancies cited. Had the third party review continued, additional dis-crepancies would have been identified. Due to the large number of discre-pancies identified in EQ at CPSES, the Third Party wrote Issue Resolution E-8
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iReport.-(IRR).DAPlE-EIC-503. The project has commenced a major rework /
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. upgrade program.- Impell' Corporation has prepared a corrective action plan (Generic; Issue Report 09-0210-060) for'EQ.
NRC Evaluation
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The NRC ' concerns with the TERA checklist for EQ are negated by the fact'that the DAP review has been succeeded by'the Impell corrective action pr 1 ram
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1 for EQ.
Instrumentation and Controls
' Open Item I-I (Closed)
i 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
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other. criteria in 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.
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. to assure they would be considered.
DAP Response-Criteria 49 and 100 are both beyond the Topic E06 scope of review.
(Criterion u
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' 49'was, however, reviewed in Topic E09, " Single Failure /FMEA " and documented on Design Reviewivaluation Checklist DAP-CLC-I-058. Criterion 100 involves the review of an NSSS system, which is outside the scope of the DAP review.)
l Criteria 151 and 154, although adequately covered in other criteria on the checklist, have been further examined.- This additional. review is documented i
in Revision 2 of Design Review Evaluation Checklist DAP-CLC-I-001, Attributes
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24, 27, 27.2 and Attributes 11, 12, 14, respectively.
In June 1986, the Topic E06 Criteria List DAP-CR-EIC-007 was revised to include i
the new criteria 180 through 186 and 189. These criteria had not yet been i
. incorporated into applicable checklists at the time of the NRC inspection (July 1986). All of these criteria have since been addressed as follows:
-Criteria 180 through 186--Design Review Evaluation Checklist DAP-CLC-I-001, Revision 2.
Criterion 189--Design Review Evaluation Checklist DAP-CLC-I-002, Revision 2.
NRC Evaluation
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The DAP response indicates that all of the criteria identified in the open item l
have been addressed by the DAP review, except for #100. This is acceptable
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because NSSS systems were outside the scope of the DAP review.
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Open Item I-2 (Closed)
DAP-CL-I-002 did not contain a number of applicable E06 design criteria:
numbers 15 (6.9kV control power), 31 (D/G cpability 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 surveil-lance). TERA confirmed that criterion 15 will 3e in topic E04 checklists and criteria 121 and 131 in topic E07 checklists.
Design criteria 15,110, and 111 had been recently deleted from Revision 1 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 criteria list (numbers 160 through 162) were not included in DAP-CL-I-002, and no tracking mechanism was evident to assure they would be addressed.
DAP Respor.se The NRC team inspected Design Review Evaluation Checklist DAP-CLC-I-002. The criteria of concern (numbers 15, 31, 32, 40, 107, 110, 111, 121, and 131) have all been reviewed, although not necessarily on checklist DAP-CLC-I-002, as follows (Note: When only part of a criterion is applicable to a particular review, only that part is evaluated.):
Criterion 15--covered by Topics E04, E06, and E08. This criterion is addressed by the E06 Topic in checklist DAP-CL-I-001, Rev. 1, Attribute 15. To further assure the adequacy of the review, Criterion 15 has been added to the Topic E06 i
checklist DAP-CLC-I-002, Revision 2, as Attribute 15.
Criterion 31--covered by Topics E01, E02, E03, E06, and Ell. This criterion is addressed by the E06 Topic in checklist DAP-CL-I-002, Attributes 31.1 and 31.2.
Criterion 32--covered by Topics E01, E03, E04, E06, E07, E08, and Ell. This criterion is addressed by the E06 Topic in checklist DAP-CL-I-002, Attribute 32.
Criterion 40--covered by Topics E03, E04, E06, E07, and Ell.
This criterion is addressed by the E06 Topic in checklist DAP-CL-I-002, Attribute 40.
Criterion 107--covered by Topics E06 and E07. This criterion is addressed by the E06 Topic in checklists DAP-CL-I-001 and DAP-CL-I-002, Attribute 107.
Criterion 110--beyond the Topic E06 scope of review; however, it is included in the topic E07 scope of review and is covered by checklists DAP-CL-I-016 and DAP-CL-I-023 through 034, Attribute 93.
Criterion 111--beyond the Topic E06 scope of review; however, it is included in the Topic E07 scope of review and is covered by checklists DAP-CL-I-016 and DAP-CL-I-023 through 034, Attribute 94.
Criterion 121--covered by Topics E06 and E07. This criterion is covered by the E06 Topic in checklist DAP-CL-I-002, Attribute 140.
Criterion 131--covered in the E06 Topic by checklist DAP-CL-I-002, Attribute 131.
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L Criterion 15 was deleted in error.and has been reinstated ir the Topic E06
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criteria list (DAP-CR-EIC-007,' Revision 2). This and other criteria lists have been reviewed to verify that no other criteria were deleted in error.
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I Criteria 110 'and 111 were ' deleted from the Topic'E06 criteria list because they are beyond the scope of that review topic.
Criteria 110 and 111 are covered, in depth,'in Review Topic E07 (reference Topic E07-criteria list DAP-CR-EIC-008. Criterion 93 and 94).
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. Criterion 160 is'-addressed in Eletrical checklist DAP-CLC-E-008.
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Criterion 161 is addressed in EIC Topic E01,. criteria 14, and Topic E07 check-list DAP-CLC-I-020, Attribute 33.
Criterion 162'is addressed in 18C checklist DAP-CLC-I-002, Attribute 162.
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l A final DAP correlation matrix has been developed to verify complete coverage
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of criteria for each HDA and Topic.
NRC Evaluation-The DAP response indicates that each NRC identified criterion has been addressed in.an appropriate checklist and'that design criteria lists were revised to
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address the NRC comments.
Open Item I-3 (Closed)
l For TNE HDA.IO10.1A, the documents scanned provided insufficient examples of TNE design work for the team to-reach a conclusion. The team considers that TERA should scan other documents.in the HDA reflecting TNE design work.
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DAP Response _
I We agree with the concern.. Examples of'TNE design work in the documents scanned were insufficient to reach a conclusion. This is because the TNE
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contribution to this design activity has, in general, been minimal since l
turnover from Gibbs and Hill. One area where TNE has made substantive contributions within this HDA is "AFW Alarm Systems." Documents represen-tative of this area have been scanned and sufficient examples of TNE design work were identified to verify the homogeneity of the HDA. This is documented in checklist DAP-CLC-I-014, Attribute 7.
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NRC Evaluation Action by DAP to scan TNE documents within the AFW alarm system area is re-
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sponsive to'the NRC concern.
Open item I-4 (Closed)
' TERA stated that the subject 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
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development.
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DAP Response The'resiew of continuously bypassed thermal overloads for motor-operated valves
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is addressed.in DAP-CL-I-001.
A NRC Evaluation
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L The DAP response indicates that thermal overload bypasses was addressed in j
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a' checklist.~
I Open Item-I-5 (Closed)
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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 allow-
'able setpoint values for the pump suction pressure switches and pressure transmitters ~ TERA did not specifically identify this modeling omission in their checklist.or in the related DIRs.. It is noted that the motor driven pump l
calculation was not in TERA's review sample, but the team reviewed it-for
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comparison purposes.
DAP Response We agree with the concern. The. approved (DSAP XI) EIC review scope includes, as a baseline, those design criteria to which the CPSES has committed. 'Sub-sequent expansions to this scope are made when industry design concerns are-identified which may be applicable to CPSES--such as the transient.effect of suction.line pressure drop when auxiliary feedwater pumps are started. Check-
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lists DAP-CL-I-016-and DAP-CL-I-023 through -033 were revised to include.
attributes and verification statements which examine the setpoint calculations reviewed for inclusion of process dynamic considerations.
DIR-D-0898 cites
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the general lack of documented design bases in all of the setpoint calcu-lations. The lack of' design bases and the necessity for. including process dynamics in the considerations for determining setpoint values is discussed in Issue Resolution Report DAP-E-EIC-502.
In addition, a DIR (D-2319) citing the specific omission of process dynamics for all AFW suction pressure switches has been generated.
NRC Evaluation The team reviewed DIR-D-2319 and found that it addressed the NRC concern.
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Open Item I-6 (Closed)
i HRC inspection report 50-445/85-17,50-446/85-14, pages A-42 and A-43, in-dicates 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
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(a);ESFventilation Redundancy, independence, power supplies.
l interlocks, instrumentation and control, i
and bypass status indication.
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(b) Safety chilled water Instrument-ratings,' power supply, and-bypass status' indication.
(c)Componentcoolingwater'
' Power supplies, train A and B low
. pressure interlock single fai'tre compliance and response time, end bypass status indication.
(d)Stationservicewater Power supplies, instrument ratings, CCW pump interlock, and bypass status indication.
-(e) SSW intake structure Power supplies and bypass status j
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ventilation indication
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(f)Stationairsystem Regulatory Guide 1.97 indication.
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 j
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.DAP.
DAP Response
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Only two of the six specific Topic E10 checklist reviews were available to
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the NRC team for review at the time of the audit. Subsequently, the four other checklists, incomplete at the time of the audit, have 5een completed.
The completed Topic E10 checklists are as follows.
1.
Auxilary feedwater support system (ESF vent) DAP-CL-I-017*
2.
D/G support system DAP-CL-I-018*
j 3.
Station service water system DAP-CL-I-036
4.
Component cooling water system DAP-CL-037 l
S.
Safety chilled water system DAP-CL-I-038 6.
Service water intake structure vent DAP-CL-I-039 i
- Reviewed at NRC Audit It should be noted that preliminary review of Station Air' System showed it was not essential to post-accident operations. Therefore, no further review of this system was performed.
NRC Evaluation l
l The DAP, response indicates that five of the six AFW support systems were reviewed and one did not require a review.
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'Open Item I-7 (Closed)
Design criteria list DAP-CR-EIC-Oll, Rev.1, dated 6/2/86, did not appear to l
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address the following technical subjects relevant to AFW support systems:
a Process variables to initiate and control AFW support systems
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b Capability for test and calibration (system or component level)
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c Manual initiation at the, system level
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d Interlocks with other equipment and systems e) System, level bypass indication f) Response time capability DAP Response a
The Topic lE10 criteria list specifically includes commitments made by TUGC0 l
in the CPSES-FSAR for support systems.
Review of the E&IC. criteria list a
revealed that the FSAR commitments for E10 were insufficient to properly review the listed technical subjects (1 through 6). However, the DAP has taken the.following actions:
1.
DAP-CL-I-017 Rev. O, addressed automatic and manual controls to the
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ESF vent fans and coil units under attributes 32, 33, 34, and 37..
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Although the criteria list did not discuss controls to the coil units, this wcs addressed in verification and comments column of the checklist.
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2.
This area of review was not a Topic E10 consnitment of DSAP XI, however, i
this concern was examined in Topics E06 and E07 for the AFW system, checklists'DAP-CL-I-001-005, -006, -007, -008, and -0015.
3.
Manual initiation is addressed in DAP-CL-I-017, Rev. O, for the ESF-vent fans, coil units-and pump room supply dampers and -exhaust valves. -
4.
Interlocks were discussed in DAP-CL-I-017, Rev. O, verification and comments columns. Attributes were added, however, for coil unit interlock and.ESF vent fan damper interlock.
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5.
Attribute added to address system inoperative indicators in DAP-CL-I-017,,
i Rev.1, for ESF Vent Exhaust Fans and AFW pump room coil unit fans, i
Safety systein bypass / inoperative indications were also addressed for D/G Vent System, SSWS pumps, CCWS pumps, Safety Chilled Water System Pumps, and Service Water Intake Suction Vent System fans.
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6.
The third party has reviewed the 60-second response time capability of the CCW and SSW pump starts in the E10 topic. See DAP-CL-I-037 and -038.
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NRC Evaluation
The response indicates that DAP has addressed the six AFW support system L
technical subjects identified by the NRC.
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f Open Item I-8 (Closed)
A number of criteria contained in the support systems design cri,teria list'
appeared to be applicable to the ESF ventilation system, but were not included
in the AFW support systems checklist [ numbers (7)-ventilation system indepen-
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dence, (9)-protection system failure modes,'(10)-system test capability, I
.(13)-control power for train A and B loads on batteries, (14)-associated
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circuitrequirements.(15)-RegulatoryGuide1.75 separation,(16)-circuit
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and equipment separation (17)-depiction of separation on drawings, and.
(18)-separation methods].
DAP Response
'The criteria of concern were reviewed. Several criteria, although generally applicable to Topic E10, were reviewed by other topics.
Criteria 10 and 13--Topic E06 checklists DAP-CL-I-001 and -002.
Criteria.16, 17, and 18--Topic E09 checklist DAP-CL-I-058. Three criteria were considered-
l not to be within the Topic E10 scope of review (Criteria 9, 14, 15); however,
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Criterion 9 is reviewed in checklist DAP-CL-I-083 and Criteria 14 and 15 are
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reviewed in DAP-CL-I-032.
It was concluded'that Criterion #7 should have.been included and it has since been added-(DAP-CL-I-017,devision 1, Attribute #7).
NRC Evaluation i
The DAP response indicates that all of the criteria identified by the NRC have been addressed in some phase of the DAP review. This is acceptable since the DAP intent was to review all design criteria at.least once rather than to review all design criteria that may be pertinent to each review topic.
Open ' Item I-9 (Closed)
DSAP XI, page 25, states that the review of the ESF ventilation system will
address interlocks. The TERA review of control logic and alectrical schematic
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diagrams did not address the following interlocks.
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(a) Valve limit switch interlocks with fan motor cirquits.
(b) Automatic isolation of the motor driven AFW pumptroom based on a safety injection signal.
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CAP Response The criteria related to these concerns were reviewed in checklist DAP-CL-I-017, as noted within the verification and coments columns.
In addition, an attribute
. was added to DAP-CL-I-017 for review of the ESF vent fan ' damper interlocks to ensure the adequacy of this topical review.
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NRC Evaluation 77 f(
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DAP-CL-I-017 addresses' the, interlocks eidentified by the NRC. :
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.Open Item'I-10 (Closed)c
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- TERMstated.that-the following interlocks will be covered 'in Review Topic E05:
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ElectNeal: area fan. coil unit initiation'on safety injection c
' andEstation blackout. signals as. described in FSAR Table 8.3.2.
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~ (b)l Automatic load. shedding'of saf tt-related ventilation fans based.
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on safety, injection 'and station blackout signals.
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qDAP'Responsrg
'y i; These concerns ware address d.,as.follows:
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L:,ECoveredcin DAP-CL-I-017'
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? ;2.T ) Reviewed"under DAP-CLC-E-008 as part of Load' Shedding, Sequencing, and A
<V f
j Transfer per FSAR Tables 8.3-1A, -1B, and -2.
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7: NRCs Evaluation
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The DAP response addressed the'NRC concern.
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~ Open Item'IJ11 (Closed).
L sp t14
,M Thefollowin[designcriteriaa ear to be applicable to the diesel generator-H support systems, but were.not i luded in the checklist: (6)-mechanicaland
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. electrical interactions with the diesel generators (7)-independence of venti-j f
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,lation systems, (8)-periodic test capability. (9)-single failure conformance.
N-i 10)-test and surveillance provisions,-(11)-independence of D/G accessories, l
17)-separation, (14)-associated circuit requirements eand (15)-Regulatory n
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~ Guide 1.75 separati'on conformance. -
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DAP Response
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The' third party reviewed the criteria related to this concern and added cHteria 7,11,. and 12 to the checklist DAP-CL-I-018. ~The remaining criteria are conrcidered fat to be within the Topic' E10 scope' of review.- (However, Criterim'3}cnd 10 are reviewed in DAP Checklists DAP-CGI-001, -005, -006, i-007, -008,'and W 15; Criterion 9 is reviewud'in DAP-CL-I-083; and Criteria l
14.and_15,are covered in Topic E09, DAP-CL-E-032. The criteria implemented j
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within the E10 %pyctreview addressed Criterion,No. :5.
Criterion No. 6 is J
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l a-summary commitment if all the implemented'cytteria.)
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- NRC Evaluatio,n (
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,khj The DAPhesponse is acceptable because it indicates thpt all design criteria
,idp tified by the NRC concern will be addressed in some phase of the DAP review.
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In the control logic and drcuhry for the diesel generator fuel oil day
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(Transamerica DeLeval) and Gibbs 4d Hill, the following problems not.cound
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7(a),The.Gibbs and Hill instrunat control diagram does not agree -
s with the Gibbs and Hill schematic diagrams on the connectien of diy
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tank level switches to individual fuel oil pump control' circuits.
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.he Gibbs and Hill setpoint calculations (not reviewed by TERA) did
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required from each day tank level Nitch.
Level switch pontact 1-2 operUtes at high and low fuel oil,daf tank
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levels, whereaftthat contact 4-5 orprates at'high and low-low levely. ' h The Gibbs anoTlf, calculation identtfied only the 'high and 100 lefel kl
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r DAP Response l
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The third party, reviewed the k/,G day tank pump logic, but' due to in!lufficient corroboration between deWgn cecuments, was unble to sufficiently evaluate (
specific pump logic; therefore, sthe NRC is correct that there are inconsistencies
among these documents.
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After the NRC audit, the third party re-examined the 0/G day tank logic design (
documents,includingassociatedinstrumentsetpointcalculations. These
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' documents indicate inconsistent oparation of the' day tank pumps as being in
" alternate"or"either/both" configurations. Fur:termore, the ICD and schematic
are in conflict yth, the setpoint methodology.
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U N ludes that dacument alignment Unang ICD, sche.natic, and setpoint Thereviewcordneca$sary. Additionally, inst?ument capability must be further l
calculations 1 reviewed to coordinate cont:act logic.
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There concerns have been documented in DIR D-2326, Rei. O.
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NRC Evaluation 4
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i Thetedm. reviewed 0(R0-2326,Rev.O,andfoundthatitaddressedtheNRC,
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concerns.
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inside containmeict, containment electrical penetrations, panel mounted micro-f processors, electrical < isolation' devices,' and uninterrupttble power sources.
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Hj TERA stated that the system readout indicators located on the main control boards (that de subject to separation, environmental and seismic qualification j
. requirements)irebeingreviewedunderReviewTopicE08-ComponentFunctional Requirements. ' Indicators. Based'on checklist attributes shown to the team, eg.
the main controf; board component functional review will address the qualifica-
! tion aspects of;the indicators.- TERA stated that the hydro:an monitoring
system review for separation is addressed in Review Topic E09-Single Failure /
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FMEA. ' The TERA * review did not identify hardware or software requirements applicable to the micro-processors.
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i DAP Response
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(1)- Qualification aspects of the Hydrogen Monitoring System indicators
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in the control room are addressed under attribute 13 (Accident Monit.
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Inst.--Equip. Qual.. Requirements, Reg. Guide 1.97) of checklist
DAP-CL-I-049, Component Functional Requirements--Indicators.
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(2) Review of the Hydrogen Monitoring system separation is provided in
.0AP-CL-I-05,8, Attribute #7, Verification #3.
(3)lg'inTopicE08,checklistDAP-CL-I-052.hicro-processor hardware and othe
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An attribute was added to E14 checklist DAP-CL-I-057 to review software requirements. DIR D-2451 3 ocuments identified discrepancies.
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d NRC Evaluation The DAP response' addresses all' areas of review identified by the NRC.
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