ML20091R962

Notice Forwarding NRC Region III Re Independent Design Review.Certificate of Svc Encl.Related Correspondence

ML20091R962
Person / Time
Site:	Clinton
Issue date:	05/31/1984
From:	Fox C ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE
To:
References
OL, NUDOCS 8406150367
Download: ML20091R962 (24)

Text

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. gtoco UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION US'iRC IN THE MATTER OF ) ' 4 JW 15 A?0:24 ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, INC. ) ~-

'and WESTERN ILLINOIS POWER )

COOPERATIVE, INC. ) Docket No. 50-461 OL

)

(Operating License for Clinton )

Power Station, Unit 1) )

NOTICE TO: Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.

Washington, D.C. 20059 Dr. Oscar.H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General Environmental Control Division 160 North LaSalle Street Room 900 Chicago, Illinois 60601 Jean Foy 511 W. Nevada Urbana, Illinois 61808 8406150367 840531 'M PDR ADOCK 05000461 /

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9 9 Prairie Alliance Box 2424 Station A I Champaign, Illinois 61820 l Herbert H. Livermore U.S. Nuclear Regulatory Commission-Clinton Nuclear Power Station RR 3, Box 229A Clinton, Illinois 61727 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing.

Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE TAKE NOTICE that I have today filed with the Secretary of the United States _ Nuclear Regulatory.

Commission a letter from Donald P. Hall, Vice President, Illinois Power Company- to Mr. James G. Keppler, Regional Administrator, Region III, dated May_31, 1984 regarding the Independent Design Review for'the Clinton Power Station in the above-captioned matter. A copy of this letter is attached and hereby served upon you.

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1 One of the Attorneys for Applicants Sheldon A. Zabel Charles D. Fox IV Sara L. Johnson SCHIFF HARDIN & WAITE-7200 Sears Tower 233 South Wacker Drive

! Chicago, Illinois 60606 (312) 876-1000 l

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/LLINDIS POWER COMPANY Docket No. 50-461 iP CUNTON POW STATION.

BCRk{B. INTON. ILLINOIS 61727

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A!O:y May 31, 19 8 4 ' ~ , ..

Mr. James G. Keppler

Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect : Clinton Independent Design Review

Dear Mr. Keppler:

This letter presents for your comments and concurrence an Illinois Power Company (IP) program to provide further confirmation that the Clinton Power Station (CPS) design is consistent with the design description of the Final Safety Analysis Report (FSAR), the Safety Evaluation' Report (SER) and its supplements. In addition, this letter presents, for your information, a summary of past and current activities relating to the confirmation of the quality of design of CPS.

The Clinton Independent Design Review (IDR) proposed in this letter supplements past design reviews of the archi-tect/ engineer (AE) (Sargent & Lundy) and nuclear steam supply systen (NSSS) vendor (General Electric) for CPS.

These past reviews were either Clinton specific or associ-ated with the design and construction of other nuclear plants. They were performed by diverse organizations including IP, other utilities , other AE's , Institute of Nuclear Power Operations (INPO), Nuclear Regulatory Commis-sion (NRC), etc.

IP considers that the above reviews combined with.the results of the preoperational Clinton test programs will.

provide adequate confidence in. CPS design. However,.to j provide even greater confidence,_IP proposes an additional independent review to evaluate selected elements of'the plant design.

PAST AND CURRENT CLINTON DESIGN OVERVIEW Since the inception of CPS design'in 1972, IP has had an active program to review the activities of General i- .

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.I Jamns G. Keppler 2 May 31, 1984 Electric (GE) and Sargent & Lundy (S&L). These reviews include approvals of essential design elements such as

- criteria and specifications,-Quality Assurance (QA) auditing of the design process, independent confirmatory calculation checks, performance of supplementary independent design evaluations, etc. These reviews , some of which are de- I scribed in Attachment 1 to this letter, provide additional assurance that the Clinton design is appropriate. As described in Attachment 1, these reviews are continuing.

This overview of GE and S&L for the Clinton Project has not been limited to IP activities. GE is providing IP a nuclear power plant.that is essentially a standard product that, in one form or another, has been supplied to 37 utili-ties. This reactor plant design has been reviewed in detail by these utilities, their consultants, the NRC, and the ACRS over the 30 years it has been under development and in~use.

S&L has actively participated in the design of 14 nuclear power. plants.. These design activities have also been reviewed in detail by their clients, consultants, NRC and

others.

Because the Clinton plant is one of the latest in the i

series of plants under design by GE and S&L,.many review findings for these earlier plants have been resolved or incorporated in a planned manner in the original design, and~

will not be installed as late changes to CPS. The Clinton

design has benefited by being one of many, and one of the latest, GE and S&L products.

INDEPENDENT DESIGN REVIEU l Recently, it has become the practice of nuclear utili-ties, either on their own initiative or ae the request of NRC, to have a portion of the design of their nuclear plants 4

reviewed by an independent auditor. These design reviews have concentrated on the activities of the architect engi-

! neer and the balance of the plant effort subcontracted to

> other design organizations. These reviews have. consisted.of

what are referred to as horizontal and vertical reviews.

The hori=ontal review has been an assessment of the design system in use by the design organization.' This

. includes review of the design procedures, design. tools, staff training, records, interface controls, QA etc.;

The vertical review' consists of examining the design of-i- specific elements of a system or systems to confirm the

- design accuracy.. In this'. case, specific design details-are examined by the~ reviewer..

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Jcmes G. Keppler 3 May 31, 1984 IP has concluded that an IDR will be made for CPS. The services of an outside independent organization, Bechtel Power Corporation, will be obtained to conduct this review.

The scope of this review will be based upon the following considerations:

In the last two years, several reviews have been made of S&L's design program. These reviews include the Cygna review for Fermi, the Teledyne review for LaSalle, the NRC review for Byron, and the Bechtel review for Byron (cur-rently underway). S&L operates as a matrix organization and as such, many of its people and design methods are common to different proj ec ts . Therefore, IP considers that the results of these past reviews of S&L provide a satisfactorv data base for the evaluation of

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the adequacy of the S&L overall design system for the Clinton project.

The results of these reviews will be evaluated for applicability to the Clinton project and, based upon the results of these evaluations, IP will assure that any corrective action neces-sary to support the Clinton project has been taken. This evaluation will attempt to assure that the underlying root causes for these findings are discovered and addressed. The results of this evaluation, which will consti ,

tute a horizontal review, will be provided to the NRC. -

As there was no significant balance of plant design work performed by a subcontractor, the IDR will concentrate on S&L activitics.

Subject to satisfactory negotiations, it-is proposed that Bechtel perform the Clinton IDR as an extension of their current review for the l Commonwealth Edison Byron ~ Plant. Two Clinton l systems will be selected by IP extending the~

l B'chtel e review of the S&L design process to a i

total of five systems. As part of their

! Clinton effort, Bechtel will be asked to evaluate the applicability of any Byron find-ings to CPS. (Even though the Byron systems are different than the equivalent Clinton systems, the design methods and procedures used by S&L are expected to be similar.)

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1 Janas G..K ppler 4 May 31, 1984 i A description of the proposed Clinton IDR is attached.

Your early comments on the concepts presented in this letter and the proposed Clinton IDR is requested to enable us to proceed with an IDR that. concurrently meets both IP and NRC needs. .At your convenience, IP would be pleased to meet with you to further discuss this program. IP is submitting this letter in order to establish a base for further discussions of the program. If you have any questions, please contact me or my assistant J. D. Geier (217-424-6995).

Sincerely yours, D. P. Hall Vice President DPH/jsm cc: NRC Resident Office Director, Office of.I&E, USNRC, Washington, DC 20555 NRC Clinton Licensing Project Manager Illinois Department of Nuclear Safety Attachments:

(1) Summary of Clinton Engineering Design Control and Surveillance -

(2) Clinton Independent Design Review r v y

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SUMMARY

OF CLINTON ENGINEERING DESIGN CONTROL AND SURVEILLANCE Illinois Power Company (IP) has maintained a continuous program of design control and surveillance which dates back to the beginning of the project in late 1972. The program was executed by the combined efforts of two IP project groups -

Engineering and Quality Assurance (QA). In the early stages of the project the activities of these two groups were combined under one department, i.e., the Nuclear Station Engineering Department (NSED). In 1980 the groups were separated when QA was elevated to full department stature.

I. Early Prograns A. 0A Program In early 1973 the Clinton Power Station (CPS) design was started. IP QA recognized that CPS would require a different.OA program than Sargent & Lundy (S&L) had been using on earlier nuclear power plants. The existing S&L QA program did not address

.the complex and extensive new requirements of~the

" rainbow series" of ANSI N45.2 daughter standards.

Consequently all nuclear safety-related design and engineering activities of S&L were suspended in June 1973. -

As a prerequisite for resumption of CPS work S&L was required to develop a revised quality assurance program acceptable to IP. In March of 1974, an independent third party was retained to audit the new proposed S&L'QA program. It was found that S&L had successfully corrected prior QA program deficiencies. Subsequently, IP authorized S&L to resume nuclear safety-related design work on CPS.

B. Engineering Surveillance /QA Audit Program-Uith the resumotion of nuclear safety-related

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design activities at S&L, IP instituted a'long-range audit plan and program to maintain surveillance of S&L activities. One feature of this plan was to audit the activities at S&L at least once per year.

Between 1973 and 1983 there were approximately twenty-six major IP audits of :the design and -engi-neering activities at S&L. In addition there was-a concurrent program of surveillance _of_S&L-work by

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l both IP QA and Engineering Departments.

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. The surveillance was performed using IP re-sources, sometimes assisted by outside consulting personnel. It produced detailed challenges to S&L procedures, layouts, specifications, code and standard usage / selection, regulatory requirements interpretations, etc. These were subsequently resolved or corrected by S&L.

C. Design Reviews IP maintained continuous surveillance of S&L design engineering through the entire CPS design cycle. S&L's nuclear safety-related engineering design criteria were reviewed and accepted by IP. A majority of the specifications related to nuclear safety were reviewed. Tracking and follow-up for IP review comments was maintained and documented.

These reviews were made for technical adequacy of the work and from the standpoint of operability, maintainability, and constructability.

The quality assurance requirements to be included in all S&L specifications for nuclear safety-related work were defined by IP and approved prior to general use as " boiler plate requirements" for the specifications. These reviews and approvals were completed prior to issue of specifications for procurement. IP Engineering and QA personnel also participated in the review and coordination of S&L and Baldwin Associates (BA) procurement activities for nuclear safety-related equipment, materials, and systems.

All sections of the Preliminary Safety Analysis Report (PSAR) were systematically reviewed and-controlled by NSED prior to final issue. A formal dccumented system of review comments and follow-up was maintained to assure adequate control of input to these documents. All presentations'to the NRC staff were made or coordinated by NSED personnel to assure appropriate feedback and correction to the PSAR. All revisions to these' documents were con-trolled directly.by NSED.

II. Later Project Stages As the CPS design matured, the character of IP surveillance and control also changed. Specific aspects of the design were reviewed and challenged for end product adequacy. These activities were applied to many phases of the work including the following typical l

examples:

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. JL. Intergranular Stress Corrosion Cracking (IGSCC)

In 1979 when NUREG 0313 was published, it was

! recognized that the CPS design would be affected.

The project design (both nuclear and balance of plant) was reviewed for general adequacy and compli-

ance with the requirements of NUREG 0313. Maj or system material changes'and rework were undertaken so that there is no longer any sensitized material in the primary pressure boundary. One of the r results of this change was a significant rework of j the previously fabricated recirculating cooling

system piping, i

j B. Control Room The CPS control room is the first-of-a-kind g combination of Nuclenet and Power Generation Control Complex (PGCC). .The design of this part of CPS was

- considered to_be particularly sensitive to interface-controls. It warranted extraordinary surveillance.

and control. IP established a special task force ~to coordinate the exchange of design.information between S&L.and. General Electric.(GE). This task-force was responsible for the final stages of; i- development of the design and.for surveillance of;

manufacturing and testing to assure that the design i intent was carried through'the end product.

j Some'of.the specialLmeasures that were taken to

-assure the engineering and design included:

1. During the early design' stage, a full-scale mock-up.of the main control panels was used'to-evaluate the-layout of the controls and in-p .strumentation.

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2. -At-a critical. stage of initial implementation

i. of S&L drawings,.IPLauthorizedLsix S&L'engi-l- e neers'to temporary" assignment.in the GE1 facto-:

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ry. The' purpose was to maintainiand assistlini

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interpretation of'the-5&L~drawingsJto effec-~-

tively convey-critical information'that hadito

-be translated.to GEidrawings-Tof:the PGCC Nuclenet complex.

3. . An-IP staff engineer was designated.as, test _.

' director and:a group of.IP Engineering,

'Startup,Jand Operationsapersonnel (including.a1 resident group ofLfive'for a period ofieighteen months) were~sent to theLGEJfactoryito test,

perform ~ final. design-checkout and documentation

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' review of the control room.. These, activities

! included all=significant1 phases of testing,

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procedure preparation, supervision of test activities, review of design changes, and corrective action appropriate to completion of the control room in accordance with the required quality level.

4. After the control room equipment - preassembled and tested at the GE factory - was shipped to the site, additional surveillance and design control measures were taken. This assured that the final field details of installation check-out and testing were properly reviewed for design changes. Installation related design control was carefully reviewed and documented at all appropriate levels.

C. Equipment Qualification Regulatory requirements have been established for seismic and environmental qualification of mechanical and electrical equipment. Additional regulatory requirements also exist for pump and valve operability.

A combined engineering effort was undertaken to review the specifications and design documents to assure that requirements are net and have been properly documented. Standing organizations were set up at S&L offices and at CPS. They address these engineering and design requirements and the fulfillment of such by detailed reviews of records which are being assembled for formal NRC audit.

These activities have resulted in identifica-tion of equipment deficiencies and have identified the need for corrective action. Corrective measures have included replacement of equipment. In addition IP has established a program to properly establish qualification requirements for CPS-unique equipment and ' systems . '-

D. Safety Analyses All of the principal CPS design features are supported by appropriate safety analyses and analyt-ical studies. These demonstrate that the design concepts are properly integrated into the overall safety analyses of the plant. Safety analyses and other supporting technical information are document-

. ed in the Final Safety Analysis Report (FSAR).

NSED has maintained continuous independent surveillance of the engineering and design to establish the fundamental safety of CPS. The effort 4

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includes independent reviews of applicable analyt-ical. methods, computer programs, calculations and analyses used by the design engineer.

Specific examples of NSED analyses and indepen-dent checks of S&L's analytical and safety work include the following:

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1. Piping - Piping stresses and design. work performed by S&L have been selectively checked and verified. The NUPIPE code and other alternate methods have been used for this '

purpose. Both ASME boiler code piping and noncode work-have been sampled. Piping associ-

- ated with various plant systems has been reviewed.

2. Shielding - Various S&L radiation shielding designs have been_ checked. Independent'analy-ses using (in some cases) different methods l

have been employed. Shielding sources as well as attenuation calculations have been verified.

i A variety of shielding, both1 permanent struc-tures and block shield. walls, have been evalu-ated. Specific systems checked include 1the biological shielding',' radwaste equipment,-and various cubicle configurations.

. 3. Safe _ Shutdown Capability Following Loss of 1 j Power to Instruments and Controls - A review of i the adequacy to obtain' safe shutdown upon a loss of any Class IE on non-1E bus supplying l power to' safety or non-safety related instru-L nents and controls was perforned.

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4. Suppression Pool Dynamics - NSED calculations and analyses have_been performed using indepen-dent methods for verification-and confirmation:

of~S&L'and GE analyses of' suppression pool -

a dynamics effects. ' Checks have also been~made-

'of hydrogen releases and hydrogen effects

including local combustion and various environ-mental considerations.. Checks have'been made I on structuralLloadings inside the containment.

L Postaccident - pool temperatures .and temperature -

! distribution have also been examined.

'An IP,'(NSED) developed analytical.codefis available'to measure'the rate'of pool warm-up-

c- 'and the effectsLof 3 10wering reactor vessel' water level'under postulated'ATUS conditions.

The correlationLwith the GE analyticaljapproach' hassaiso beenLevaluated.

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5. Core Analyses - Independant NSED.. checks and.

verifications of GE nuclear physics data have been made. Programs have been run independent--

ly to evaluate core thermal hydraulics. Tran--

sient analyses are under development using both GE and EPRI source data.

III. Recent Project Stages In the last several years, CPS desi the stage where meaningful " bottom line"gnanalyses has reached and checks have become possible. NSED has examined S&L design work to independently verify selected specific parts of the overall design. This work includes the following:

j' A. Seismic Assessment Program A documented IP program was established to review the plant seismic design. The purpose of-l this program is to assure that equipment of the decay heat removal systems and their power supplies

, are adequately designed-for seismic events. The

program evaluates seismic design in three ways

(1) i small bore piping design' methods are reviewed; (2) mechanical. interaction of components (including walkdowns inithe field): and (3) determination and comparison of stress-levels from the revised seismic response spectra to the. maximum allowable stress

level for components. 'The system provides for 4

documented feedback of observed potential problems.

! S&L is required to evaluate' potential problems identified by this systen.

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B. Piping Design Review

> 1. Small bore pip'e - -On : site design' review' of small bore (2 and-under). piping systems 11s performed regularly by NSED. The review is performed according'to detailed. checklists-i developed by NSED~to assure.in-depth analysis-and verification of pi Selected-calculations for span ~ and pingsupport design. loads are i

reviewed.to. assure that technical-procedure requirements.are: met and> calculations are f

conpleted.. properly.

2.- -Large borenpipe - Design work lis reviewed by NSED'at S&L offices inLChicago using appropri-i ate piping-~and support 1 design checklists ~

l- developed-by.NSED. One subsystem is reviewed each month by a team of three NSED engineers.

The-review includes a.= check-to ensure that the <

design specificationsLmeet<ASME code c

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requirements. Checks are also made to deter-mine appropriate verification of computer input accuracy through.line-by-line comparison of

" basic data with construction and as-built drawings. Detailed review of stress reports is made to ensure that all loading combinations

! are considered. In addition, documentation is reviewed for completeness and legibility.

C. Structural Design Calculations 1

[ Approximately 5% of all S&L. civil structural L=

calculations are being checked independently by NSED. These' calculations relate to engineering analyses of soils, concrete, structural steel,

, masonry, ASME code work, etc. The checks are being performed both on a numerical comparison basis and' i by using. separate independent methods for comparison of results. -The checks are being' performed to the

computer data input level.

l ' D. General Design Control l

Stone & Webster (S&W) under contract to-IP performed a review of CPS design control _ system.- As  ;

a result of this study, S&W. proposed a set of twenty i

general topics;to be examined as part of independent ~

i in-house reviews of. engineering'and. design control.

l- These include design input informations-design change control and documentation:' procurement: change.

t feedback and control; load tracking: environmental--

qualifications compliance with NRC bulletins, .

-information notices, SER's; and other broad. design

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, . control topics. EachEsubject<has been. assigned'one

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more independent' engineers to perform a review p and documented analysis'of;the'specifically. assigned-

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[ ,subj ects . . Appropriate corrective action: based on

'the results of these reviews is anticipated..

j E.- . Interaction Analysis / Surveillance:

'As the plant systens and= equipment' reach lthc Lfinalistages of installation, it-has become possible l.

'to perform various~ inspections.to identify potentialc interactions which may.not.be:readily apparent on-the drawings. :Suchfinteractions could. occur.between i-usafety-related equipment,and nonsafety-relatedJ. ,

L 1 equipment.' These:must-not be detrimentalcto the 1 -

! continued safe performance ~of" critical' parts of the ,

plant. . Periodically,'important:partsfof-the~ plant are inspected by qualified' teams ~of S&L and1IP -

engineers.-' Suspected-interaction' conditions are .

~ documented and reported to S&L:for..further; review-and possible design changes'.: Theselactivities

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provide another level of assurance that the design intent of the drawings and specifications is in fact achieved. They also assure that conditions which are often difficult to envision from drawings and specifications are identified and properly con-trolled or corrected.

F. Licensing Certification of FSAR amendments, reviews and coordination with the NRC is controlled and docu-mented by NSED. This assures that the design configuration is maintained and is consistent with the original criteria. These activities will culminate in a final IP certification of the accura-cy and completeness of the FSAR. Certification will be completed shortly before the operating license is expected to be issued. The certification will be based on a comprehensive review of the entire FSAR including appropriate disposition of all documented commitments made in both the FSAR and PSAR.

G. Nuclear Systen Protection System (NSPS) Solid-state Design Review NSED initiated a review of the NSPS design.

This design review which was performed by Stone &

Webster included an examination of the control logic and the implementation of the logic in the solid-state design. The purpose of the review was to make a determination of the overall adequacy of the NSPS with respect to design philosophy and hardware used for implementation. Additionally, the NSPS was reviewed for conformance to applicable regulatory-guides and industry standards as outlined in Section 1.8 of the FSAR.

Miscellaneous IV.

The examples selected above are typical ofzthe-independent engineering and design control and verifica-l tion activities of IP. Many other examples could.have i been. selected including the following:

t 1. Several joint reviews with EPRI were made to - deter-mine the adequacy of the IGSCC preventive measures for the project. These reviews considered the l state-of-the-art of all available measures including material substitutions,-reworking of materials, and special processes such as stres's improvement tech-niques.

2. A safety parameter display system verification and

-validation team has been assembled to perform an

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independent review of that work. The bases for this program are the requirements of NUREG 0737, Supple-ment 1, Requirements-for Emergency Response Capabil-ity.

3. IP has played a lead role in the review and disposi-tion of the generic BWR-6 issues identified by the NRC. This was accomplished through the formation of the License Review Group-II (LRG-II). Approximately 50 issues have been resolved through generic posi-tion papers which are endorsed by each members docket and resolved through the Safety Evaluation Reports.

4. Twenty-five percent of all of the as-built documen-tation for the containment liner and reactor vessel pedestal were re-reviewed. The Hartford Steam Boiler Inspection and Insurance Company.was selected as an independent reviewer _for this purpose.

Documentation and records were reviewed from the standpoint of their acceptability to an authorized nuclear inspector on the assumption that code requirements applied except for stamping the work.

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5. A number of INPO reviews have been performed includ-ing the formalized self-evaluation, the construction assistance audit, and the operations assistance audit. These reviews were performed in accordance with established INPO procedures including pro-visions for management analysis of the findings and r formulation of acceptable corrective action pro-grams.

6. A TMI task force was assembled prior to. issue of the

NRC task action plan'in NUREG 0660.. A large number i oof potential problems were investigated. When the l final.NRC task action plan was published, this i program was transformed into a long-range ac-countability and action program based on documented consideration of each applicable lesson learned and-action-plan requirement. The task action plan has resulted in reviews of the project design. It also-provided for detailed design changes'and augmenta -

tion of the design to-include new requirements in accordance with the TMI(lessons learned and task action plan documentation.

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I 7. Analyses of off-site radiation doses resulting from bypass leakage during a design basis accident were performed. These analyses' demonstrated adequate margin for the proposed bypass leakage criteria.

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. 8. An independent review of the drywell cooling HVAC system has.been performed. This review included verifying heat load and cooling' capacity calcu-lations.

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. . l ATTACHMENT 2  !

CLINTON INDEPENDENT DESIGN REVIEW I. INTRODUCTION To provide additional assurance that the design of Illinois Power Company's (IP) Clinton Power Station (CPS) meets the requirements of the Final Safety Analysis Report (FSAR) and the Safety Evaluation Report (SER), IP is obtaining the services of an outside consultant (Bechtel Power Corporation) to conduct an Independent Design Review (IDR). The IDR will consist of a horizontal review of the design system and a vertical review of two of the Clinton systems. The consultant is to include, as part of his review, the mechanical, civil structural, control and instrumentation, electrical and fluid system aspects of the design.

II. CHARTER For the horizontal review, the consultant is to evaluate the adequacy of the Sargent & Lundy (S&L) overall design system for the Clinton project. This review should use as a data base the results of the.

Cygna review for Fermi, the Teledyne review for LaSalle, the NRC review for Byron, the Bechtel review for Byron (currently underway), and any other informa-tion from previous reviews by IP and others. In addition to evaluating the applicability of these findings to IP, the consultant should determine the adequacy of resolutions of applicable findings.

Special emphasis should be placed on determining the underlying root causes of these findings and ensuring that the resolutions adequately addressed these root causes.

4 For the vertical review, the consultant is to review the High Pressure Core Spray System and the Standby Liquid Control System:

1. Determine that the design meets the FSAR re-quirements,

2. Evaluate the adequacy of the design,

3. Evaluate the adequacy of the Sargent & Lundy (S&L) design process,

4. Evaluate the engineering judgments and as-sumptions, and the basis on which they were 1

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. exercised ant? utilized,

5. Evaluate"the)use of the standard design methods,

6. Review th'e S&L ' design interface with General

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Electric'(CE), s

7. Evaluate the adequacy of the documentation of design scalculations, and

8. ' Identify the underlydng caustis for any de-

.ficiencies identified.,

III. SCOPE OF WORK ~

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The requested revieu areas and implementidg guidance are listed below. The review of each syistem. shall ' '

include:

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1. Safety Classification t

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The independent reviewer shall review the-classi-1 fication ofithe system and' structures and:their components to verify thate they have b'een properly x- ,

classified \per 10CFR50.

2.

't(1 Design Process 5 v N1N The independent renewer shall review the design

' records to verify,the adequacy of the design' process, the1 adequacy.df design, and the consistency between ' design documents -and FSAR commitments. ' n y

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, 3. Design Change Control! ' s 1-L & @,

The. independent reviewer shall revies the. desi sh -

' change controls,' including ~the procedures for Field Change Requests (FCR's), NoneConformance4 Reports-(NCR's), and Engineering Change Notic'es (ECN's) to verify that the des,i g ha's been-properly controlled.

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4. Design Review .

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,The-independent review team sh'uld examine the

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'Hesign reviews ' performed- by SEIA for the 'two P, selected systems'. . Art assessment shouldlbe -

nEde regarding.the effectiveness of-the S&L t

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• . l design review for these systems and the review process in general.

5. Root Causes The independent reviewer shall attempt to discover the underlying causes for any identified deficiencies.

6. Construction Verification No construction verification is required, although the reviewer may visit the site if he feels it is necessary.

7. Period of Review The IDR should cover work through April 1, 1984.

IV. GENERAL General Electric is the NSSS supplier and Sargent &

Lundy (S&L) is the Architect Engineer (AE) for CPS.

S&L will open their offices to the independent. review-er and provide all documentation and calculations requested. The boundaries of the two systems to be reviewed are shown on the enclosed drawings.

The independent reviewer need not perform detailed calculations and analysis. It is sufficient that the existing calculations be reviewed; however, the independent reviewer may perform such calculations as he feels necessary.

In performing this work, the independent reviewer should become familiar with the FSAR. In addition, the independent reviewer should become familiar with S&L procedures'and instructions necessary to conduct this review.

IP recognizes that S&L documents end information reviewed.for the purpose of the.IDR are.the property of S&L and may be proprietary. Such documents shall not be used for any purpose other than' the.IDR without' the expressed approval of S&L. All S&L documents not specifically included in the report shallibe returned

.to S&L.

.V . INTERNAL REVIEW Observations (potential discrepancies) shall be subnitted in-a timely manner-to an internal review-

' committee, within the independent reviewer's"orga-nization,' composed of senior; technical personnel with l

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broad experience in technical management. This internal committee is to determine if the observation is accurate and has the potential for a safety con-cern. If the committee determines that the observa-tion'is accurate, but is not a safety concern, it j shall be properly documented, classified by the committee as an observation in the final report, and dispositioned. Dispositioning of observations may 3 involve discussionsgor additional analyses, by either IP cn: S&L, to demonstrate that required design margins are maintained. All'dispositioning shall be document-ed in the final report.

If the first level review committee determines-that observation is a potential safety. concern, the second level internal committee will review the observation

expeditiously.. IP will be' notified immediately when an item is sent to the second-level review committee.

j In the event that the second-level review committee agrees that such an item is a potential safety con-

~

cern, IP will then be notified immediately. IP will then promptly.make a determination of reportability in-accordance with NRC regulations.

VI. INDEPENDENCE All team members and all review committee members must meet the requirements of independence. All individu-als involved in this design review, including all staff shall complete Exhibit'I and shall be free of substantive interest in IP and S&L. It is recognized that Bechtel is currently reviewing S&L activities.for Commonwealth Edison. This activity;is:not considered to impair Bechtel's independence.

Examples of substantive interest are:

1. Team or staff members: any work experience in design, construction, or quality assurance of CPS with IP, with S&L or with Clinton site.

contractors currently.or within the past.five.

-years.

2.- Immediate family of-team or staff nembers enployed:

by IP,ES&L, or,a Clinton site contractor; -

or engaged-directly or indirectly'in the design and' construction of CPS.

VII. QUALIFICATIONS'

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All-team or staff. members should haveEsppropriate.

te'chnical expertise;.with background andLexperienceLin-the area they are reviewing.

E It'is expected:that the

, team will have QA/QC, engineeringi and nuclear. power 4;

plant design expertise. Qualifications of the staff shall be documented and the names of proposed staff members shall be submitted to IP for approval.

Qualifications also shall be submitted in the final report.

VIII. QUALITY ASSURANCE (OA) REOUIREMENTS The independent reviewer should implement the amplica-ble portions of his QA program for the systems being reviewed in the IDR. The applicable portions of the OA program that are used should be discussed in the final report. Plans and procedures used should also be described. IP QA will perform audits and/or surveillances of the IDR effort at S&L.

IX. SCHEDULE The schedule for completion of this IDR is to be based upon a maximum period of six months from rigning of the contract to completion of the final report. The independent reviewer is to provide a schedule for all IDR activities including the proposed start of the review, completion of the review, issuance'of con-clusions on all potential findings and issuance of-the final report.

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EXHIBIT 1 ,

- Independence Criteria l IP will utilize the answers to the following questions to evaluate the independence'of the company conducting the IDR and the individuals which the company will utilize in the review. Minimal or insignificant contacts will not neces- 4 sarily disqualify candidates for the IDR.

1. Has the company or individual involved had any

- previous involvement with the Clinton Project?

If yes, please provide.-details.

2. Has the company or individuals involved been previously hired by any of the IP, Sargent

& Lundy (S&L), or Clinton site contractors to perform similar audits? If yes, please provide details.

3. Has any individual involved been previously employed by any of_the'IP, S&L,-or-Clinton site contractors? If yes, please provide details. '

4. Does the company or any individual involved own or control stock of.any'of the IP., S&L, or Clinton site contractors? Iflyes, please

.. _ provide details.

5. Is any member of the present household of any individual-involved employed by any of_the IP, S&L, or Clinton site' contractors? If yes,

, please provide details.:

6. Is any relative 1of any individual involved-coployed by any of the IP,'S&L,=orLClinton site Contractors? - If

yes ,- please -provide details.

.7. Has"the company or1any individual been offered future employment: by .any ofE the l[P, S&L,

' or Clinten site contractors?: If yes, please provide details.-

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CERTIFICATE OF SERVICE I hereby certify that an original and two con-formed copies of the foregoing document were served upon the following:

Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C. 20555' Attention: Docketing and Service Branch and that one copy of the foregoing document was served upon each of the following:

Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University

. 2300 Sixth Street, N.W.

Washington, D.C.

Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L..Willman Assistant Attorney General 1 Environmental Control Division 160 North LaSalle Street' '

- Room 900 Chicago, Illinois 60601 Jean Foy 511 W.. Nevada.

Urbana, Illinois 61808 I (

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.o Prairie Alliance Box 2424 Station A Champaign, Illinois 61820 Herbert H. Livermore U.S. Nuclear Regulatory Commission RR 3, Box 229A Clinton, Illinois 61727 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in each case by deposit in the United States Mail, postage prepaid on June 12, 1984.

g'& ), 44d One of the Attorneys for Applicants Sheldon A. Zabel Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000

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