ML20054H333

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Proposed Agenda for 810303-05 Onsite Audit of Facilities Re Sys Interaction Program.Related Info Encl
ML20054H333
Person / Time
Site: 05000000, San Onofre
Issue date: 03/05/1981
From:
NRC
To:
NRC
Shared Package
ML20049A511 List:
References
FOIA-82-176 NUDOCS 8206230261
Download: ML20054H333 (5)


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{{#Wiki_filter:. 7' PP0 POSED AGENDA r [ [' ,o " MARCH 3-5,1981 ONSITE AUDIT OF SAN ONOFRE SEISMIC SYSTEMS INTERACTION PROGRAM ~ Tuesday, March 3 Opening Meeting M ntroduction of participants ~ scussion of purpose of audit, proposed accomplishments and proposed agenda g A iscussion of guidelines and criteria for upgrading equipment-supports ~ Mview of representative examples of design drawings and specifications ssion of status of program, results to date and any outstanding matters associated with program-Plant tour (conducted by SCE/Bechtel personnel) ,u Timiliarization with major plant features f, -CBservation of SCE's walkthrough technique ~ ervation of representative examples of upgraded equipment supports y0bservation of equipment identified for potential upgrading during SCE's walkthroughs nesday, March 4 gIdependent NRC walkthroughs/walkdowns of selected plarit areas / equipment' j (accompanied by SCE/Bechtel personnel). Plant areas / equipment to be identified during the audit. Thursday, March 5 Completion of NRC independent walkthroughs/walkdowns (accompanied by SCE/ Bechtel personnel) 2. Closing meeting . Discussion of results of audit . Discussion of any outstanding matters associated with NRC's review of program B206230261 820429 PDR FDIA MCMURR A82-176 PDR

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i wuty uwo w rms muxaaf f Sen Onofra 263 i /* 4 Question 510-1 Your response to Question 112.40 indicates that you have undertaken a program to ensure that non-seismic Category I syste=s will not interact with seismic Category I systems. In order for us to evaluate your pro-gram, additional information is required. This infor=ation should be provided in the form of a systems interaction program description which addresses the following matters: (1) The objective of the program. The primary. objective of the program as well as any secondary or corollary objectives, e.g., maintenance of the ability of safety-related systems to accommodate single failures, should be stated. (2) The scope of the program. The equipment, i.e., structures, systems and components, to be protected against potentially adverse inter-actions as well as the types of interactions to be considered in the ' program, e.g., physical, functional, direct, indirect, should be 1 disussed. l (3) The organization established to imolement the program. The organi-zation established to implement the program, including the elements of the organization, their responsibilities and their reporting relationships, should be described. The description should address the corporate management positions responsible for the_i=plementation of the program, the team used to postulate the interactions, any l independent audit or review organizations and any consultants used in the program. (4) The methodology used in the program. The methodology used in the program should be described. The description should address the preparation of the criteria used to postulate the interactions,' the preparation and maintenance of a documentation data base, the performance of the walkdowns by the interaction team, the evaluation of the findings and reco=mendations of the interaction team, the implementation of modifications, the means for ensuring that the modifications themselves will not contribute to adverse interactions and any provisions for independent audit or review of the program. (5) The criteria used to postulate the interactions. The criteria used' to postulate potentially adverse interactions and ths bases for the criteria should be described, e.g., failure criteria for various types.of non-safety systems.

Response

(1) Objective The San Onofre 263 Station has been designed to provide protection for safety-related equipment from seismic events. This protection is provided to ensur'e that recovery from the seismic event is possibl to ensure the integrity of the reactor coolant pressure 3) i l 1/81 A=endment 23

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SEISMIC UPGRADING OF PIPIEC -Besically,Iere are two types of piping to be upgraded: 1. Part of the pipe is seismic category I and part is not. A dynamic analysis is done for the whole line out to the first anchor in the non-seismic category I portion. Stressg + StressDW OBE h N4 H bi % ; 5. Q ( S ress 2. Piping is all non-seismic categoty I a. Small bore (2-inch diameter and less) was analyzed the same as seismic category I. g g Wrv0 h D Q f Stress p + StressDW + OBE h M MM ress 4 b. Nearly all (approx. 95%) of large bore was done the same as seismic category I. c. Remaining large bore (approx. 5%) meets the non-category I equation: Mg pg g Stress ress g + StressDW + UBC h* ~ ~ However, the pipe supports are designed for a load derived by using a static seismic analysis to the maximum span to estimate the seismic load'during the SSE. The piping is - designed to the UBC seismic using static analysis. L c M O r A 26 - The static seismic analysis is very conservative. A dynamic seismic analysis would show that the seismic category I requirements are met as follows: Stress p + StressDW + 0BE h* ress SEISMIC UPGRADING OF MISC. STEEL ~ All gratings, handrails, staircases and platforms in e=4e'ft_ Sgdff4 - q / M P,/# 8 eategory T are designed to remain elastic during an e*--" SSE. [ '[ a-1au M, 3,5 { 5 ~C, i l

o Southern California Eclison Company $3 P O 80K 800 2 2 44 W ALNUT GROVE AVENUC R O S E M E AD. C A LIFORNI A 91770 K. P. B A S KIN , g L g,,,,,, ~~"::,:;:."::::.'.::::::"'"- ~ ~... January 20, 1981 Si 5 A a .c h Director, Office of Nuclear Reactor Regulation E; ,E ro N _.- N,-, '. Attentioni Mr. Frank Miraglia, Branch Chief [ ff A fg Licensing Branch No. 3 gs U. S. Nuclear Regulatory Commission Washington, D.C. 20555 7 D, d. sf .-x s. Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 Enclosed are sixty-three (63) copies of responses to numerous NRC Open items and questions identified in the NRC letter dated November 7,1980, and meetings with the NRC staff during the week of December 15, 1980 is a list of the responses which are included in Enclosure 2. Direct distribution of these responses will be made as part of the Amendment 23 distribution and will be in accordance with the service list provided by SCE's letter of October 29, 1979. An affidavit attesting to the fact that distribution has been completed will be provided within ten (10) days of docketing of Amendment 23. Please let me know if you have any questions or need any additional information. Very truly.yours,, pp k L-Enclosures M.' .'/,' s l Q10 3 F

~. ENCLOSURE 1 RESPONSES TO NRC OPEN ITEMS San Onofre Nuclear Generating Station Units 2 and 3 January 20, 1981. Open Item No. Open Item 7 Reactor Internals Analyses 11 PSI /ISI Pumps and Valves 19 ISI/ PSI 27 Subcomp. Nodalization 29 Sump Vortex Test 50 Snubber Inspection 51 ESF and AFW Fracture Toughness 52 Describe Systems Interaction Study Miscellaneous Fuel Mechanical Design Parameters e G O e s .. >-,-.m._..

52. Sy' stems Interaction Study e e 9 m 9 e 9 e

( v u Scn Onofre 2&3 ( d. Question 510-1 Your response to Question 112.40 indicates that you have undertaken a program to ensure that non-seismic Category : syste=,s will not interact with seismic Category I syste=s. In order for us to evaluate your pro-gram, additional'information is required. This information should be provided in the form of a systems interaction program description which addresses the following matters: (1) The objective of the program. The primary objective of the program as well as any secondary or corollary objectives, e.g., maintenance of the ability of safety-related systems to acco=modate single failures, should be stated. (2) The scope of the program. The equipment, i.e., structures, systems and components, to be protected against potentially adverse inter-actions as well as the, types of interactions to be considered in the

program, e.g.,

physical, functional, direct, indirect, should be disussed. (3) The organization established to implement the program. The organi-zation established to implement the program, including the elements of the organization, their responsibilities and their reporting relationships, should be described. The description should address the corporate management positions responsible for the implementation of the program, the team used to postulate the interactions, any independent audit or review organizations and any consultants used in the program. (4) The methodology used in the program. The methodology used ;, the program should be described. The description should address ti.e preparation of the criteria used to postulate the interactions, the preparation and maintenance of a documentation data base, the performance of the walkdowns by the interaction team, the evaluation of the findings and recommendations of the interaction team, the implementation of modifications, the means for ensuring that the modifications themselves will not contribute to adverse interactions and any provisions for independent audit or review of the program. (5) The criteria used to postulate the interactions. The criteria used to postulate potentially adverse interactions and the bases for the criteria should be described, e.g., failure criteria for various types.of non-safety systems.

Response

(1) Objective The San Onofre 2&3 Station has been designed to provide protection for safety-related equipment from seismic events. This protection is provided to ensure that recovery from the seismic event is possible, to ensure the integrity of.the reactor coolant pressure 1/81 Amendment 23 l

,ResponsuauoNRCQu_sgi(- t Scn Onofra 2&3 boundary, to minicize the release of radioactivity, and to enable the plant to be placed in a safe condition. The systems interaction program for San Onofre 263 assures that those portions of structures, systems, or components whose continued function is not required but whose failure could reduce the func-tioning of any safety-related plant feature (including redundancy for single failure protection) to an unacceptable level, are designed and constructed so that the SSE will not cause a failure. (2) Scope The San Onofre 263 program scope prevides for physical and functional pro,tection of all safety-related ccmponents, syste=s, and structures to meet the objectives stated above. As discussed under methodology (below), the conservative approach of seismically designing essentially all non-safety-related components, of significant mass, located within all SCI buildings inherently ~ reduces the probability of not only direct, but also indirect system interactions, due to the occurance of an SSE. (3) organization The Seismic II/I systems interaction program is implemented by the A/E and has been accomplished within the Bechtel project engineering team. The project organization chart is shown in figure 510.1.-l. An interdiscipline task force was established under the direction of the Project Engineer. The members were qualified engineers from all discipline, and were headed by the Nuclear EGS and the Codes Group. Interactions between source and target equipment were identified by the tasks force using established guidance and criteria. The task force also recommended resolutions to the identified interactions. The decisions were reviewed by the Project Engineer and appropriate APE. Final closecut action by the responsible discipline is reviewed and documented by the task force. This also ensures that new inter-actions are not created. Methods for seismic design of non-saf ety-related items, and the guidelines and criteria were established by the various EGS's and were approved by the appropriate discipline chief engineers. The final phase of the San Onofre Seismic II/I interaction program was a field walkdown of the safety-related systems by a team of home office engineers. The team's findings were reported to the Closeout action Project Engineer and the interactions task force. was the same as described above. Amendment 23 1/81

( r ~ Rasponzen to NRC Qusstions Sen Onofra 263 The entire program was subject to the normal prcject practices implemented by the Project Internal Procedures Manual as well as the Project Quality Procedures Manual. Design and design. control are carried out in a similar manner as that for ite=s directly important to safety. This includes the perfer=ance of appropriate design reviews. Field work is performed under the direction of experienced field construction superintendents and is inspected by the staff of field engineers stationed at the site. The field engineers.are respon-sible for verifying that construction is performed in accordance with the design drawings and specifications and with applicable standard codes and specifications. SCE employed an independent consultant to review the Bechtel Seismic II/I interaction program and its results. The consultant reported directly to SCE. (4) Methodology For the San Onofre 2&3 Station a conservative design approach was taken to eliminate the numerous Seismic II/I situations that other- [ wise could occur by: ( Arrangement of the plant layout was based on maximizing the a. physical separation of redundant or diverse safety-related co=ponents and systems from each other and from non safety-related items. Items which are not associated with or support the main safety-related components within each area are generally restricted from those areas. b. Several classes of components located within safety-related structures were seismically designed and constructed, even though they were non safety-related. Typical items include: o Conduit and cable tray Fire protection sprinkler systems o o Permanent and temporary maintenance cranes o HVAC equipment (within the containment only) o HVAC ductwork o Control room panels o Instrumentation supports o Control room ceiling lighting The turbine building and several critical components within it c. were seismically designed and constructed. Amendment 23 1/81

m_. Scn Onofra 263 o As a result of the.above design philosophy, the activities of the i task force could be effectively focused on the limited number of Seismic II/I situations that remained. The review identified the i remaining items that required seismic upgrading. Note that the l early stages of the review caused certain items to be added to item b above. The majority of the ite=s evaluated were large and small piping, large mass equipment, and lighting. Seismic design of upgraded non safety-related components is generally based on use of equivalent stati.c analysis for SSE loads. For exa=ple, for non safety-related piping the primary stress in i the pipe a limited to less than 1.25 for static seismic loadings ~ 3 of 0.2g horizontal and 0.13g verticaI. Piping support design loads are. based on SSE g loading using the applic'able floor response apectrum. All piping supports are designed per AISC requirement, I with a few exception shere for SSE conditions up to 1.5 times the AISC allowable is used, which provides an elastic solution.. Items that are seismically designed on a generic basis or that are uniquely identified, are so indicated on appropriate design drawings and specifications. These documents are subject to all of the review and approvals specified in the Project Internal Procedures Manual. The design drawings serve to document the upgrading of non safety-related items to withstand seismic loads. Decisions and actions resulting from the program are documented by conference notes, letters, design criteria manuals, action items, etc., in accordance with the Project Internal Procedure Manual. (5) Criteria used for Interaction accessment. A conservatively simplistic approach was taken to assume that any non-safety-related item, that is not seismically upgraded, and is located in the vicinity of a safety-related ite= will non-mechanistically cause the loss of function or pressure boundary. Because a seismic event affects the entire plant, the redundant or diverse system would be similarly affected; therefore all such II/I situations must be corrected to assure the safety of the plant assuming the los's of offsite power and a single failure (i.e., the evaluation does not take credit for redundancy). Reference See response to Question 112.40. Amendment 23 1/81

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ResponsestoNRCQuastions( San Onofre 263 e Question 510.1 Your response to Question 112.40 indicates that you have undertaken a 5 program to ensure that non-seismic Category I systems will not interact with seismic Category I syste=s. In order for us to evaluate your pro-gra=, additional information is required. This inforcation should be provided in the for= of a syste=s interaction program description which addresses the following matters: (1) The objective of the progra=. The pri=ary objective of the program as well as any secondary or corollary objectives, e.g., maintenance of the ability of safety-related syste=s to acce=modate single failures, should be stated. (2) The scope of the program. The equipment, i.e., structures, systems and components, to be-protec.ted against potentially adverse inter-actions as well as the types of interactions to be considered in the

program, e.g.,

physical, functional, direct, indirect, should be disussed. (3) The organization established to implement the program. The organi-zation established to implement the progrs=, including the elements of the organization, their* responsibilities and their reporting relationships, should be described. The description should address the corporate canagement positions responsible for the implementation of the program, the team used to postulate the interactions, any independent audit or review organizations and any consultants used in the program. ~ (4) The methodology used in the program. The methodology used in the program should be described. The description should address'the preparation of the criteria used to postulate the interactions, the preparation and maintenance of a docu=entation data base, the performance of the walkdowns by the interaction team, the evaluation of the findings and reco=mendations of the interaction team, the implementation of modifications, the means for, ensuring that the modifications themselves will not contribute to adverse interactions and any provisions for independent audit or review of the program. (5) The criteria used to nostulate the interactions. The criteria used i to postulate potentially adverse interactions and'the bases for the criteria should be described, e.g., failure criteria for various i types of non-safety systems. l

Response

(1) Objective The San Onofre 263 Station has been designed to protect safety-related equipment from seis=ic events. This protection is provided to ensure the integrity of the reactor coolant pressure boundary, 2/81 Amendment 23

( R&sponsestoNRCQuestions( San Onofre 263 to minitize the release of radioactivity, and to enable the plant to be placed in a safe condition, by preventing non-seis=ic items frca interacting with safety-related itets. The seiscic systems interaction program for San Onofre 2&3 assures that those portions of structures, systess, or co=ponents whose continued function is not required but whose; structural failure could reduce the functioning of any safety-related plant feature (including redundancy for single failure protection) to an unaccept-able level are designed and construct-so that the SSE will not cause a failure. (2) Scope The San On'fre 2&3 program scope provides for physical and functional o protection of all safety-related components, systems, and structures to meet the objectives stated above. The program, scope does not ' include seismic qualification of individual components (i.e., vents for valve operators) or control grade / protection grade instru=en-tation interactions. The conservative approach of seistically designing essentially all non-safety-related co=ponents inherently reduces the probability of not only direct, but also indirect system interactions due to the occurrence of an SSE. This approach is applied to all co=ponents of significant mass,whose failure could adversel>I affe t safety-related equipment I ated within all SCl buildings. gg Sc.g

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M- ~ (3) Orcanization The seismic systems interaction progra= is icple=ented by the A/E and has been acco:plished within the Bechtel project engineerinE-team. The project orEanization chart is shown in figure 510.1.-l. An interdiscipline task force was established under the direction of the Project Engineer. The me=bers were qualified engineers from all disciplines, (nuclear, control systems, mechanical, electrical,. plant design, civil, and architectural) and were headed by the Nuclear Engineer Group Supervisor (EGS) and the Codes ~ Group. Potential interactions between source (non-seismically designed items) and target (safety-related) equip =ent were postulated by the task force using established project practices. The task fore _e also recommended resolutions to the identified interactions. The decisions were reviewed by the Project Engineer and appropriate ' Assistant Project Engineer, (APE). Final closeout action by the responsible discipline is reviewed and docu=ented by the task force. This also ensures that new inter-actions are not created. 2/81 Amendment 23

f f Responses to NP.C Questions s [,' San Onofre 263 Methods for seistic design of non-safety-related ite=s, and the guidelines and criteria were established by the various EGS's and were approved by the appropriate discipline chief ent,ineers. The guidelines and criteria are incorporated into ' applicable project desiEn drawings and specifications. This includes details for field routed or located items such as s=all pipe. This ensures that field personnel h etheproperguidelinesandcriteria. g '$ w: ra-:,-W e qI i n %WV. g./>u,.rsglpW~ bpb'ase of (the San Onofre Seistic interaction program was a& N L M g r The fi {N. ' field walkthrotgh cif the safety-related areas by a team of Bechtel . -Pt v/;:2.Y office engineers /The tea ='s' findings were reported to the Project ~ ~ 7,. / ngineer and the interactions task force. The responsible discipline E / resolves the interaction and closecut action is the same as described above. The entire program was subject to the normal project practices ~ implemented by the Pro' ject Internal Procedures Manual as well as 'the Project Quality Procedures Manual. Design and design control are carried out in the same manner as that for safety-related items. 3 This includes the performance of appropriate design reviews. ko Field work is performed under the direction of experienced fie'ld 8> construction superintendents and is inspected by the staff of fiel VC engineers stationed at the site. The field engineers are respon-sible for verifying that construction is performed in accordance with the design drawings and specifications and with applicable standard codes and specifications. SCE e= ployed an independent cons,ultant (Robert, Cloud Associates) l S 9 to review the J: ' n1 seismic int,e'r'setion program"and its results g '" *-2<*A.) The consultant rep ted directly to SCE management. (4) Methodology b p For the San Onofre 263 Station a conservative design approach was Mo taken to eliminate the numerous seismic interaction situations that g otherwise could occur by: gag Arrangement of th'e plant layout was originally based on maximi- ~ a. zing the physical separation of redundant or diverse safety-related components and systems from each other and from non safety-related ite=s. Items which are not associated-with or do not support the main safety-related components within each area are generally restricted from those areas. b. Several classes of co:ponents located within safety-related structures were seis=fcally designed and constructed for structural integrity, even though they were non safety-related. Typigal items include: o Conduit and cable tray o Fire protection sprinkler systems 2/81 Amendment 23 J

~ Rbsponses to IGC Questions ( / San onofre 263 a o Percanent and terporary =aintenance cranes o FNAC equipment (within the containment only) o m'AC ductwork o Control room panels o Instrumentation supports o Control room ceiling lighting c. The turbine building and several critical cceponents within it were seismically designed and constructed. The reactor pro-tection system loss of load input signals which'are generated in the turbine building are protected as discussed in question response 032.10. As'a result of the above design philosophy, the activities of the task force could be effectively focused on the limited number of seismic interaction situations that remained. The review identified the remaining items that required seismic _ upgrading. _The majority of the items evaluated were large and small piping, large mass 1 Me g equipment, and lighting. 4g['4 r N-The final phase of thid p& kn ef'Ece.h Az) $x nrogram consists of a fie safety-related areas.I The purpose of this phase is to determine that the project objectives to seismically upgrade non safety-related items in safety-related areas have been implemented.- The seismic interaction program is an ongoing pro' gram which will consider current and future modifications to the plant.' The above three phases will be followed. The nature of the situation may 3 result in an emphasize on the field review of the changes. Seismic design of upgraded non safety-related components is' based' ~ on the installation'of adequate supports. For example, piping ~ support design loads are based on SSE g loading using the applicable floor response spectrum. All piping supports are designed per AISC requirement, with a few exceptions in which under SSE conditions up to 1.5 times the AISC allowable is used which rovides an elastic EO!lM;vld,

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.47 6-solution. Ite=s that are seismically designed on a generic basis or that are uniquely identified, are so indicated on appropriate design drawings and specifications. These documents are subject to all of the r.eview and approvals specified in the Project Internal Procedures Manual. The design drawings serve to document the upgrading of non safety-related items to withstand seismic loads. Decisions and actions resulting fro = the program are documented by conference notes, letters, design criteria manuals, action items, etc., in accordance with the Project Internal Procedure Manual. 2/81 Amendment 23

~ 4 ( Responses to NRC Questions San Onofre 263 - lb Mw q_ l M/d?;#-> (5) Criteria used for Interaction accessment. A conservatively simplistic approach was ta en to assu=e that any non-safety-related item of significant mais, that is not seismically willnon-mechanisticallycausetheloss[offunctionorpressure upgraded, and is located in the vicinity of a safety-related item, boundary. Engineering judgement is used to ascertain that the small mass items are not a problem based on conservative standard project bolting details. y [,, g.,/ g b f ) Because a seismic event affects the entire plan I'r oY * [ diversa system would be similarly affected; therefore all such situations must be corrected to assure the safety of the plant assu=ing the loss of of fsite power and a single failure (i.e., the evaluation does not take credit for redundancy). Reference See response to Questions 112.40 and 032.10. h]9/Mm:.?m.Jsn+, o' jw k ds, g d'&q -> ks - , C.O& i l-i l 2/81 Amendment 23 l

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( ( )JE"CT JNEER I PHYSICAL ASSISTANT PROJECT ENGINEER 4 l 11 i TRfCAL PLANT DESIGN CIVIL / STRUCTURAL ARCHITECTURAL WEERING ENGINEERING ENGINEERING GROUP 'JPE R VISO R G RO UP SUPERVISO R G RO UP SUPERVISO R CUPERVISOR PIPING ENGINEERING AND CODES LEADER wra. bx ) 0 e' ( SAN ONOFRE ~ NUCLEAR GENERATING STATION ~ Units 2 & 3 SDiPLIFIED BECHTEL PROJEC7 ENGINEERING ORGAN?.ZATION CHART 3,?,, Figure 510.1-1 2/81 Amendment 23

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I. J, -- 0 px. ,p.c. (* - h*.' h f s....- .:Q y boundary, to minimize the release ofg)adioactivity, and to enable the plant to be placed in a safe condition. The systenc Interaction program for San Onofre 263 assures that-7 f? of structures, systgns, or co=ponents whose_ M in_ued %.,[Q 3 those portions function is not required but whose failure could reduce the u - f, } ' O,-,. tioning of any safety-related plant feature (including redundancy ' 6. ~%: for single failure protection) to an unacceptable level, are designed %2 _b C,, and constructed so that the SSE will not cause a failure. D / m %\\ (2). Scope The San onofre 263 program scope provides for physical and functional protection of all safety-related components, syste=s, and structures gigesstatedabove, g ,g g, to meet t o C6'M:%?d ?NEc # e conservative approach.s 'I~g; M;" & 'J ~- ' of C., As discussed under thodology (below) A seismically designing essentially all%on-safety-related components, 6 6 Z~ Cug k significant mass, located within all SCI buildingshinherently 3 oreduces the probability of.not only direct, but also indirect system interactions, due to the occurance of an SSE. 5 (3) Organization / // n.m m The Seismic II/I systens-intera_c.tjin_. program.ts i=plemented by the A/E and has been accceplished within the Bechtel project engineering team. The project organization chart is shown in figure 510 l.-l. 'SccL,hwI PE,' An intardiscipline task orce was established under the direction of the Project Engineert The me=bers were qualified engineers from all discipline, and'were hea'ded by the Nuclear EGS and the Codes ..; ~~~ ~ Group. $ gS ,C % $i.g&:eWhg #Y / d 1& Q,;-4.. vift- [ S@E equipme) were (.'4.ntifiD by' N # b /. ; Interactions between (source and target thetask)forceusing established guidance and criteria. The tisF. 9J

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._4_ c/, E ." " M3' force aldo recommended resolutions to the identifiednteractions. , b The decisions were reviewed by the Project Engineer a.d appropriate APE. 9e. & - b 4 k Q..d gg ',h C W S-M 2.,2 C - Final closecut action by the responsible div4M 4 ~ is-reriftwed and ated_hy_.the task-for C This also ensures that new inter-actions are not created. - /.jpe,,, 7 N \\ Methods for seismic design of non-safety-related items,'and the f4.:.___ g'~. f g ,liereQpproved by the appropriate' disc ~i~pline chief engineers. /an .y::r #' guidelines and criteria were stablished by the various EGS's ~ "T f, '5.,. \\ w* Q; y The final phase of the San Onofre Seismic.II/I interaction, program ,.., q was a field walkdown of the safety-related systems by a team.pf ' Q, ) -_ _? home office engineers. The team's. findings were reported to the L../.:., N Project Engineer and the interactions task force. CloseouE action c._~h P, was the same as described above. g g p L Y'*- f.yy-D% ~'., c., 4'k:* S / k,, w - C [ W - ' :.~ l~

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c Responses to NRC Questions San Onofre 263 g4eff $GE & f5 The entire program was subject to the normal project practices ProjectQualityProceduresManual./roceduresManualaswellasthe implemented by the Project Internal Design and design control are carried out in a similar manner as that for ite=s directly important S^c:'p .t_o safety. This includes the performance of appropriate design 9 Cos - 3 7 b I reviews. w, g - x. Field work is performed under the direction of experienced field construction superintendents and is inspected by the staff of field engineers stationed at the site. The field engineers are respon-sible for verifying that construction is performed in accordance with the design drawings and specifications and with applicable E standard codes and specifications. Jh & hh'.$ fid*-g- -j SCEemployed.qkn penhntconsQtanttoreviewtheBechtel a D

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) Methodolocy 7 m- %Q 3 pjtyp -p Wh- ~% ~ 5O For the San Onofre 2&3 Station a conservative design app each was taken to eliminate the numerous Seismic II/I situations that other-wise could occur by: g$y Arrangement of the plant layout was based on maximizing the a. physical separation of redundant or diverse safety-related co=ponents and systems from each other and from non' safety-related items. Items which are not associated with or support the main safety-related components within each area are generally restricted from those areas. b. Several. classes of components located within safety-related structures were seismicallvj.ejligne.d and constructed, even though they were~ non safety-related. Typical items include: ff o Conduit and cable trays A#. 6 -- Fire protection sprinkler systems y o Permanent and temporary maintenance' cranes o o HVAC equipment (within the containment only) o HVAC ductwork o Control room panels o Instrumentation supports o Control room ceiling lighting The turbine building and several critical components within it c. were seismically designed anc' ce-structed. hCN Endt 4.g//z.4 -mewc-

nesponses to nnt yeestions ,.) g 7 ',' / [ [ b t S / San Onofra 263 P r,- ~ Q 7 As a result of the above design philosophy, the activities of the gg gc Thereviewidentifiedthey,D.,3,J task force could be effectively focused on the limited number of Seismic II/I situations that remained. egaininc items that required seismic upgrading. Note that the~ ~~ '~d-227 arly stages of the review caused certain ite=s to be added to C7 gd'y (itembabove. The majority of the items evaluated were large and small piping, large mass equipment, and lighting. 9 Seismic design of upgraded non safety-related co=ponents is i generally based on use of equivalent static analysis for SSE loads. ] 4.;;. =a safety related piping--the--pricau n ns's-in g'"'~k , Tor exampler-f m .%.d the pipe _a_. limited--to-less-thatr-1--2Spfer-stat-ic-seismic-loadings O kee :.:r-. b Lof 0.2g_hnrizontal ana n 13g_verH eaI. Piping support design loads are based on SSE g loading using the applicable floor response :,, ' f spectrum. All pipingjs sgre designed per AISC requirement, Qk 4,k j 'G. b vith a few exception vb,up4o or SSE conditions up to 1.5 ti=es the N.,, ere j - 'c3( AISC allowal(le is used, hich.provides an elastic solution. j<.,g c J-7

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p 4 q_rg_. Items that are seismically designed on a generic basis or that are g g . uniquely identified, are so indicated on appropriate design drawings p and specifications. These documents are subject to all of the " review and approvals specified in the Project Internal Procedures Manual. The design drawings serve to document the upgrading of ,,__non safety-related items to Vithstand seismic loads. Decisions and actions resulting from the program are documented by conference I notes, letters, design criteria manuals, action ite=s, etc., in ( accordance with the Project Internal Procedure Manual. 55 (5) Criteria used for Interaction a'egessment. servatively simplistic app' roach M tak_en)to assume that any-k -A ./ non-safety-related item, that is not seismically upgraded, and'is <Q / /,~ located in the vicinity of a safety-related item will non-Q.., 'f. " s j% Ig,,,Y'%,,,: mechanistical ause the loss of function or pressure boundary. I ' 4 ea DQ C;' %,"' k because a seismic event affects the entire plant, the redundant or M diverse system would be similarly affected; therefore all such -2'N~$11/I situations must be corrected to assure the safety of the plant % ) 'y~ : assuming the loss of offsite power and a single failure (i.e., the Y evaluation does not take credit for redundancy). Y [o & & $4: fad-T -ll74'k"A.( l p,m gD,h,4: & Reference Dr/0 ?y;- y, $.3,'hm j.p. ' p. 3.a.. Mm a

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