ML20116N482

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Provides Info Requested in NRC Re Recent Design Verification Activities.Findings of Independent Design Insp & Review Explained.Design Processes Will Meet Applicable NRC Regulations & Licensing Commitments
ML20116N482
Person / Time
Site: Byron, Braidwood, 05000000
Issue date: 04/24/1985
From: Reed C
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8505070226
Download: ML20116N482 (58)
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Text

{{#Wiki_filter:. /N Commonwealth Edison j ) One First Ntteonit Ptara, Chicago. (Hinois ( O ' Address RIply to: Post Ofhce Box 767 \\ / Chicago, liknois 60690 April 24, 1985 Mr. Harold R. Denton, Directst Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 i

Subject:

iByron Generating Station Unit 2 Braidwood Generating Station Units 1 and 2 Design Verification Activities NRC Docket Nos. 50-455, 50-456, and-50-457 References (a): January 14, 1985 letter from D. G. Eisenhut to Cordell Reed. (b): May 11, 1983,.. letter from Cordell Reed to H. R. Denton.

Dear Mr. Denton:

This letter provides the information requested in reference (a) is; regarding recent design verification activities associated with the Byron f

Unit-2 and Braidwood. Units 1 and 2~ projects. This information explains how the findings of the Byron Independent Design Inspection (IDI), the Byron Independent Design Review (IDR) and the Clinton IDR have been addressed for Byron 2 and Braidwood 1 and 2. The enclosure and the seven# attachments to this letter'contain'the . supporting details in response to the six requests in reference (a)'..Much -.of this information was reviewed with the NRC in Bethesda on April 10, 1985. The slides used in that presentation are also attached. Prior to the Byron IDI, Commonwealth Edison provided extensive information regarding the procedures and practices used in the control of design and construction of Byr.orp Reference.(b) contains. detailed information on various special internal and external reviews as well as documentation of regular desi.gn control-practices, quality assurance activities and the experience level of engineering personnel. Because Byron and Braidwood are duplicate. plants, most _of-this information is applicable. to_both plants. i i. -{i

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r; - 3 . H.:R. Denton -e2 - April 24, 1985 The information.provided in reference (b), the Byron IDI and IDR and the information_ provided with this letter form the. basis for our conclusion.that the. design processes for Byron and Braidwood plants have met the applicable NRC regulations'and our licensing commitments. We.are confident.that.these plants.can be operated safely. iPlease direct further inquiries regarding this matter to this office. ~ Very truly yours, 0 Cordell Reed Vice President' ' 1m 'cc: J. Taylor J. Keppler Enclosure- =, s

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n T' A ~ ' 4 EPCLOSURE : ' ADDITIONAL INFORMATION REQlESTED ON JANUARY 114, 1985 e, i

71... : MtC Request'

.s Summarize'the? ifferences in the' design process between Byron 1 and each d of the other three plants. . Response' 'The Byron and Braidwood plants are essentially' duplicate plants. The design processes utilized for Byron-2 and Braidwood 1 and 2 are the same as those' utilized for Byron 1.: In' addition, the Sargent & Lundy (S&L) design has been performed by the-same S&L Byron /Braidwood. project team, using the same procedures and under.the-same project supervision. A However, certain piping analysis' and support designs are being designed by a different design organization on Braidwood than on~ Byron. On Byron l'and 2,' Westinghouse (W) performed the piping analysis and r support. design for the containment' piping and selected subsystems'within the. auxiliary building. S&L'had design-responsibility for most of the remaining'majorisafety-related piping subsystems for'both units.. WS:and ~ the piping contractors had responsibility for ' selecting pipe supports on t some of= the small bore lines. The scope of work for each of these. organizations.is specifically delineated in documented' divisions of responsiblity. On Braidwood 1 and 2, S&L is performing the-safety-related piping analysis and support design 1for the two' units,-including those corresponding process. piping subsystems for which W,- W S and.the' piping contractors had responsibility on' Byron liand 2. :(Tiie responsibility for-the' reactor-coolant piping was retained by~W.) It should be'noted that S&L'was'the -focus; of the: Byron'1; Independent Design Review:(IDR).1Therefore, the S&L -design process _was subjected to an extensive, detailed review.- An additional aspect of the Braidwood piping analysis approach is that-thei l Byron piping analysiscis~being duplicated'for Braidwood, wherever.possible.

ThefBraidwood' piping and supports are. reconciled with.the' Byron analysis-throu@- a; formally
documented ^ process. (This approach enhances the ~

-uniformity of. design. between Byron and Braidwood, -and reinforces the.. duplicate plant relationshipm There are, of course, unique Byron-2 and ' Braidwood pipe; routings'that. result'in unique, analysis and support. design.: I In. summary; the' design process b51ng utilized:for Byron 2 is the'same-as. ~ thatsfor Byron 1,:and the S&L design process for Braidwood'1 and 2 1s' essentially thejsamefas Byronil.':~ m i' l ~ t 4 J.- -;-~ ~~

~:- ~ m; ' u w dc (~ g. e ~ ~ ut 2-2.'NRC~Requesb LDiscuss:the__ effectsf of. these differences on 'your confidence that the >Tdesign"proces's-for each~of the other three plants is at least equivalent ito Byron-1.>

Response

~ 4There are-basically no differences.in theldesi @ process utilized:for-Byron;2 and Braidwood l'and 2 versus those. utilized for Byron,1,'as noted

in. Response 1. uThere are no fundamental; engineering' differences' between 1

the'S&L and the W piping. analytical'and support design techniques. Bechtel, as partTof: the IDR on Byron ~1, reviewed S&L's design process in' the piping. analysis.and support design.and had no significant-_ findings. Also,: the design: guidelines-. utilized by WS and the piping contractors were developed by S&L._ Thus,'a uniform-design approach-is being applied .on_ Byron and Braidwood. There;are.some engineering and technological advances that are'being

utilized on Byron:2 and the Braidwood~ units that were not!available on

' Byron 1. ' These. advances ' involve improved design tools to enhance standardization and reflect ~ the? state-of-the-art in power plant design., They represent' enhancements -to the existing design process,f compucer.. and are reflected'primarily in greater utlization and integration o aided engineering-_and computer aided design, including-pipe suport optimization. :It is our intent:to continue:to utilize similar - enhancements. in the future. - These_ techniques, in conjunction with the replication approach _being1 utilized for Byron 2fand-Braidwood 1 and 2 piping analysis,: enhance the uniformity-of design and:more effectively implement standardization. TWe are confident;that the'desi@ process used for Byron'2 and 'Braidwood -1 and 2 is equivalentito, and reflects the same or better levelJof design and design controlias'that of Byron;1. 3.o NRC Rhauestl

Provide 1information on how Byron IDI fin' ings have.been1 addressed fos esch d

oof the other three plants.. y Response l w TheffindingsLfrom.the Byron 15IDI are bSing:a_ddressed.on. the other three! x_ -;unitsiKA: summary of:that review is" included!as Attachment'1,Eand additional. details;are-provided'in Attachment 3 and 4.2 Uniform actions .r have.been or are being taken,jas: appropriate.. ^ 4 y 1 ,4 4 h Y' [+ -.g{

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- -In addition, Commonwealth Edison Company's (CECO's) letter of December 30, 1983 from C. Reed to R. C. DeYoung, identified 15 specific findings and unresolved items from the Byron IDI that were to be addressed separately for Braidwood. An additional' commitment to specifically address Finding 2-16 on jet impingement for Byron 2 and Braidwood 1 and 2 was subsequently made at a meeting with the NRC on August 14, 1984 and formally committed in CECO's letter of August 16, 1984. The Byron 2 and Braidwood unique responses to these 16 findings and unresolved items are included herewith as Attachment 2. In the period of January 7-11, 1985, CECO Quality Assurance (QA) performed an audit at S&L and W to verify that corrective actions have been ~ implemented for the commitments made in response to the NRC IDI for Byron 1. The audit team concluded that the commitments made in response to the IDI report have been properly implemented and completed, or are in the process of being implemented. For items which were found to be in the process of being implemented, three observations and ten open items were . established. One open item dealt specifically with corrective actions remaining to be done for Braidwood units 1 and 2, and one open item dealt with Byron 2 and Braidwood 1 and 2. The open items will be tracked by CECO QA until satisfactorily completed. CECO QA is assuring that Byron 1 IDI items are being addressed for Byron 2 and the Braidwood units. 4. NRC Request Provide information on how applicable Byron 1 IDR findings have been ~ addressed on each of the other three plants.

Response

The Bechtel IDR findings were reviewed against all four units. A summary of the review of the findings for Byron 2 and Braidwood 1 and 2 is included as Attachment 5. Uniform actions are being taken, as appropriate, except for site-specific matters as indicated in Attachment 5, which are described in further detail in Attachment'6 and 7.- 5. NRC Request Provide information on how applicable Clinton IDR findings will be addressed for Byron 2 and Braidwood 1 and 2.

Response

The final report on the Clinton IDR was issued in late January 1985. S&L .has performed a' preliminary overview assessment of the findings of this report relative to their potential impact on Byron 2 and Braidwood'1 and-2. This preliminary assessment indicates that there are no major design impacts and no items from Clinton that resulted in physical plant changes 'on the Byron 2 and Braidwood units. l

maf n ~ e r g v Inlthe period January 21-25, 1985, CECO QA performed an audit to verify .that design concerns / problems: identified at other nuclear projects were being satisfactorily addressed by S&L for_ Byron and Braidwood. Foremost .in this audit was an evaluation:to assess.if items identified in the Bechtel IDR of.Clinton were being addressed for Byron /Braidwood.- As ~part of the CECoJaudit team,;four consultant-from Energy Incorporated - worked exclusively;on evaluating'how the Clinton IDR items were_being -handled for' Byron 2 and Braidwood. The objective was to make an. assessment- . to ' determine ifxthe Clinton -IDR problems existed at Byron /Braidwood and, if so, to determine if appropriate action had been taken by S&L to address the problems....Two' findings, one observation and three open' items were identified. The findings resulted because.of: 1)la lack of evidence to demonstrate that corrosion allowancesiwere.being considered during the _ equipment qualification review and 2) the FSAR stated the ACI strain limit

for non-containment concrete structures as 0.002 in/in when it should be 10.003 in/in. This latter observation'was made because checklists used by S&L for reviewing equipment seismic reports did not show actual versus allowablervalues. The three open 1tems dealt with the S&L review of vendor fabrication drawings, the need for additional information to demonstrate the adequacy of the seismic qualification of the diesel. fuel storage tanks,' and the need for S&L'to have a system to assure the FSAR continually conforms-to design changes..Other than these items, the Clinton IDR items were.being satisfactorily handled in the Byron /Braidwood deign and the audit team concluded the following:

e "The Byron /Braidwood personnel were acutely aware of the types of ' concerns (or'simila'r ones) expressed in the Clinton IDR, and have-r j,: made adequate provision to deal with them. That awareness usually j was not due to the Clinton IDR but rather was-obtained by experience ~ p' related to interfacing with the MC (such as IE Bulletins), and . roject experience such as the IDI and IDR on Byron Unit l'.. Based p upon the audit samples examined,7all the concerns expressed in the i': Clinton IDR are already'being addressed in an acceptable manner'by the. Byron /Braldwood projects." ^

6. 'NRC-Reauest--

~ Provide a description _of the aspects of your QA program related-to design-which assures,that the applicable design commitments are: implemented at

Byron 2,~Braidwood 1 and 2.

3, Response, y The CECd QA-Department.has been actively performing comprehensivetau'dits ~ .ofilts architect-engineers to_ verify the acceptability of the design.ofn l o . the. Byron and 'Braidwood units.:.Much'of;this auditing has been performed f lby. CECO QA; engineers with broad background lin design.' On. numerous: t ioccasions, consultants ~with extensiveitechnical background'in. nuclear - design have participated as: team. members on the CECO = audits.' u A1.sopthese1 -consultantshaveperformedsgrateindependentdesignanalysisl audits under the direction of CECO b-a.u ,u.-- J ~

e r lThe CECO audits of the architect-engineering organizations began in early 1974. From 1974'through 1978 the audits primarily examined programmatic . controls and-implementation. Beginning in February 1979, the CECO audits were widely expanded to include an in-depth analysis of design activities. Since 1979, 16 design analysis audits have been performed by CECO QA in the S&LLcorporate offices to verify the design of the Byron /Braidwood units. The scope of the design analysis audits covered such items as: A. technical review and evaluation of calculations; B.- implementation of FSAR commitments; C. _ computer program validation.and usage ; D. piping design and analysis; E.. controlling and processing design changes; F. ~ stress analysis; G. design support activities by other design organizations; H. verification of qualification of design and engineering personnel; I. incorporation of design criteria and parameters into design documents; J. design interface and data control with other design organizations; K. technical aspects of electrical, mechanical and structural design including instrumentation and control; L. ._ design of supports, hangers, snubbers and restraints including application of loading; M. seismic and environmental qualification of equipment N. effectiveness of _ design control and design review including _ data verification; 0. overall. design' review; P. Independent Design' Review of Byron Unit 1; Q.- verification that significant-problems identified at other nuclear projects under construction are addressed for. Byron and Braidwood units. L In addition, CECO QA has been actively involved in. assuring that concerns ~ identified in the Byron'IDI-and Clinton IDR have been fully addressed by the architect-engineers 1for Byron 2 and the Braidwood units._ Specific CECO audits.have been performed to cover these areas. 1

- --- - - - - ~ ~ - r-cr ,1, c g' ?f^ d a 6-As a supplement, and in addition to the CECO QA activities, the S&L QA Division has'beenLinvolved with the Byron 1 IDI and IDR since their inception. S&L QA personnel participated in the-review of the responses and are~well aware of the commitments and follow-up actions required. -In addition-to assisting CECO in their audits of S&L during the IDI process and subsequently-for compliance with the IDI/IDR commitments, the S&L-QA Division has also included the IDI-findings in their trend review-Eof. nonconformances. :The trend review evaluation is distributed to Byron / Braidwood departmental and Project Management personnel, as well as QA Division personnel.- Pertinent items from the trend review are included in the S&L-QA Auditor's checklists for auditing calculations and drawings. -The QA aspects of the design commitments are applied equally to' the Byron and Braidwood projects.'. The S&L QA procedures, project-instructions and standards.are used as the basis for QA. monitoring of both projects in the = administrative,~ coordination, training, auditing, and records areas. The generic corrective actions of the IDI/IDR have been applied equally to the Byron and'Braidwood projects. These actions include the following: A.- The requirement for documentation of engineering judgment has been incorporated into the revised S&L QA. Procedure GQ-3.08, " Design Calculations," and in the engineering standards on calculations:for all three engineering disciplines (mechanical, electrical and-structural). B. The transmittal of information for design. input'between project team. menbers of different divisions isithe subject of: a new S&L-QA - 3-procedure, GQ-3.17, " Design Information Transmittal." 1 C. S&L QA procedure GQ-2.05, " Departmental Training," has-been revise'd

to" apply additional emphasis on indoctrination and training of

~ personnel'in S&L administrative and~ technical ~ standards'and/or. procedures to assure that suitable proficiency is achieved'and maintained. The applicable departmental standards have.also.been, or-Lwill be revised'to enhance this training. This demonstrates'that' CECO and S&L have conducted an adequate, self-directed l engineering assurance program and have confidence' that the ? design-processes ~for Byron 2, Braidwood 1 and 2 have met NRC regulations and licensing commitments. ;The approach described herein is on-going and~ cwill continue until the_ remaining three units are licensed. i r ~ d k4 g 4 m .ip A e ..y, g, m, r ,c.,,

6. Commonwealth Edis:n Company 04-16-85 1 Byron ' Station - Unit 2 Page 1 of 1 Braidwood Station - Units 1 & 2 l ATTACHMENT 1

SUMMARY

OF APPLICABILITY OF BYRON 1 IDI FINDINGS BYRON 2 BRAIDWOOD 1 BRAIDWOOD 2 Action Completed by Byron 1

Response

66 62 60 Unique Response ReQJired* 16 16 16 Additional Action Required ** 7 7 7 s Not Applicable *** 7 11 13 Total 96 96 96 .See Attachment 2 for the Unique Responses. See Attachment 3 for a usummary of the additional actions required.

      • See Attachment 4 for a summary of the reasons that these findings

-were not applicable to Byron 2 or Braidwood 1 and 2. e N ~ J

~ Commonwealth Edison Company-04-16-85' Byron:Statien - Unit 2 Page 1 of 16 Braidwood Station - Units 18' 2 ' ATTACHMENT 2 L BYRON 2 AND BRAIDWOOD UNIQUE { ' RESPONSES'TO' BYRON'1'IDI ISSUES l l' Byron IDI Finding 2-1: 'Diese1~ Engine Air Intake 1 j;

This finding states that there was no analysis or justification for the seismic vunerability of the air intake line for the auxiliary feedwater pump 4

diesel..The finding indicates that this: conflicts with the Auxiliary Feed-water Design Criteria which states that a single active failure plus a design basis seismic event shall ~not prevent the auxiliary feedwater system from l meeting its functional requirements. N Byron 2 and Braidwood Unique' Response'to IDI Finding 1 The response provided for Byron 1 generally applies to Byron 2 and Braidwood I and 2:also. Pipe routings and relative equipment locations are essentially I the same for all four units. However, the documented walkdown of this area I that was referenced in the Byron 1 response was applicable only to Byron 1. Similar walkdowns -will be performed on Byron 2 and Braidwood 1 and 2 to - assure'that'there are no additional non-safety-related components in the f vicinity that could impair the -function of the auxiliary feedwater pump diesel ' drive air intake line. These walkdowns should all be completed by 12-31-85, and it is anticipated that they wi11' support the same conclusion of design adequacy that was reached on Byron '1. 9 + I 1 i. d. i i i I y

Commonwealth Edison Company ATTACHNENT 2 (Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 2 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Finding F2-16 Jet' Impingement Analysis The Team found that, although FSAR Section 3.6.2.2.2.1.4. indicates, for postulated breaks, how the jet impingement force will be calculated, no jet impingement analysis had been performed. The Team found that, although Sargent & Lundy personnel indicated they had intended to do the work, no documented program or procedure was in place to provide assurance that the work'would be completed.- Byron 2 and Braidwood Unique Response to IDI Finding The final response to the Byron 1 finding on jet impingement was presented to the NRC at the 08-14 meeting, at which time the NRC was presented with Commonwealth Edison Company report entitled " Byron 1 Confirmation of Design Adequacy for Jet Impingement Effects," dated August 1984. This document was formally submitted to the NRC by CECO's letter dated 08-16-84. In this letter, CECO made a commitment that similar reports would be prepared for Byron 2 and Braidwood 1 and 2 prior to fuel loading at each of these units. Therefore, the unique responses for each of the remaining three units will be provided in their own plant specific jet impingement reports.

Commonwealth Edison Company ATTACHMENT 2 (Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 3 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Finding 3-2: Functionality Criteria In summary, the memorandum defining systems to be checked for functionality was incomplete. Some of the analysis packages that had been defined as needing the check did not state that the criteria had been met and, for some of the packages that did state the criteria was met, it was not clear that valid analyses had been performed to make this determination. These items indicated systematic weaknesses in the Program for Meeting Functionality Criteria so that the licensing commitment was not being met. Byron 2 and Braidwood Unique Response to IDI Finding In general, the statements made in response to the Byron 1 finding are appli-cable to Byron 2 and Braidwood 1 and 2. However, it should be noted that the Sargent & Lundy system for identifying the subsystems requiring a functional capability check was formalized on 05-10-84, which was prior to the completion of final stress reports on Byron 2 and Braidwood I and 2. The Byron 2 and Braidwood piping stress analysis reports generated by Sargent & Lundy, will indicate that a functional capability check has been made and documentation will exist relative to this functional capability check. i

Connonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Statirn - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 4 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES i s Byron Finding 3-8: Relocation ~ of ' Support A field walkdown conducted to examine the pipe supports for the 100% as-built subsystem 1AF14 indicated the existence of two different supports having the identical designation IAF14009R. Hunter Corporation had originally requested ~ relocation and redesign of the original configuration 1AF14009R via a dis-crepancy report (Reference 3.220; see also References 3.221 and 3.222). The new support was properly designated and installed, but Hunter Corporation had no document on file that explicitly flagged the removal of the original configuration. The Team did not determine the exett cause of this error, which should be addressed in the resolution of this item. (Finding 3-8) Byron 2 and Braidwood Unique' Response to IDI Finding The Byron 1 response applies to Byron 2 also, but we believe the Byron 1 finding to be an isolated error. For Braidwood, piping supports are instal-led and removed by a controlled, proceduralized process. This process requires that if a pipe support is relocated, a contractor review of the design revision for changes to the previous revision is done. This review includes prior installation records if this revision changes the support location. If the i previous support had work accomplished on it, then a Temporary Attachment and Removal Order and/or a Field Change Order is initiated for removal. A second process to assure the change has been incorporated is the final sub-system walkdown. s 4 l l

Comonwealth Edison Company ATTACHMENT 2(Cont'd) LByron Station - Unit ~2. 04-16-85 Braidwood Station Units 1 & 2 Page 5 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES n - Byron IDI Finding'3-10: ~ Pipe' Span Length This: finding indicates that as-built dimensions that Nuclear. Power Services obtained from Hunter Corporation were incorporated into the Nuclear Power Services as-built piping isometrics. In one instance, incorporation of piping as-builts caused the span length (Ls).between supports ISX92012R and i 1SX92013R to increase to 10','7-1/8", which exceeded the maximum span length (9.5') given in Sargent & Lundy's Small Piping and Tubing procedure. The Sargent & Lundy procedure provided an installation tolerance on support locations of +6" a total of l', 0". for each span. This finding states that. - Nuclear Power 7er, vices' analysis failed to note this change in its review of the piping Subsystem'1SX92, and also states-that it is an isolated case of review error and the discrepancy will not result in support loads of pipe stress that will. exceed ASME code allowances. { Byron 2 and Braidwood' Unique' Response to IDI Finding i As noted in the finding, the variation in. the span length was identifie'd as i an isolated case and is not applicable to Byron 2 or Braidwood I and 2.- In j addition, Nuclear Power Services does not have design responsibility for this piping at Braidwood. Sargent.& Lundy'is responsible for designing piping 4 i supports for ASME Section III small bore piping at Braidwood Station.: ~ At 1 both plants, before the piping contractor installs piping and supports out-L side of the installation tolerance, the piping contractor is required to submit the condition to the design engineer for disposition.- In addition, if the out of tolerance condition is identified by the design organization, the piping contractor is required to generate a NonConformance Report to cover this condition. The mechanism by which these nonconforming conditions are t identified to CECO and the piping contractor was reinforced in revisions to t S&L Project Instructions PI-BB-27 on Byron and PI-BB-66 on Braidwood. lL 1 l I 4 I l I J .4 4 .-ew,- - y h,,', ,.-,.,.--e-, r,m-mm-., , -.. r i v- ---w.,.,. >p.-c,,.r$,-.ee% ,m ~.. ---pr--,- -,--w-<-,eiw re-e

Commonwealth Edissn Company ATTACHMENT 2(Cont'd) Byron Station - Unit 2 - 04-16-85 Braidwood Station - Units 1 & 2 Page 6 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Finding 3-13: Pipe Movements ~1n Relation to Gap Clearance The finding addresses the adequacy of the calculetf6n done to check the piping displacements at wall penetrations 1AB160B0 and IAB38 to verify modeling assumptions and concludes that the calculation failed to confirm the modeling assumption. Byron 2 'and Braidwood Unique ~ Response to 'IDI' Finding Byron 2 and Braidwood penetration sleeve clearances will.be reviewed to verify piping analysis modeling assumptions similar to the approach utilized on Byron Unit 1. For Byron Unit 2, _this review will be performed by the design organizations having responsibility for the piping subsystem. For Braidwood, Sargent & Lundy will be performing this review for all piping systems. In both instances, when engineering judgement is utilized to determine that vector addition is not required because the associated global displacements are small, this judgement will be so documented. 4 i

Commonwealth Edison Company ATTACHMENT 2 (Cont'd)- Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 7 of 16 -BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Finding 3-14: Branch'Line' Analysis The finding addresses the evaluation of the 1/2" branch lines ICS22BA and ICS22DA which were not included in the model for Subsystem ICS09, and con-cludes that the analysis does not support seismic qualification of the lines. Byron 12 and'Braidwood Unique ~ Response to IDI Finding The Byron 1 response is directly applicable to Byron 2. The response is also applicable to Braidwood 1 and 2, with the exception that Sargent & Lundy is performing the piping analysis instead of Westinghouse. Typically, instrument lines of the type identified in the finding are included as part of the main piping models. Separate hand calculations are performed in cases when they are not included with a main piping model. A i ( 9 ,n

. Commonwealth Edison Company ATTACHMENT 2 (Cont'd) ' Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 8 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI' ISSUES Byron IDI Finding 3-15: Hanger Dimension ~ There is a discrepancy between the piping isometrics and the support drawings . involving the location of two supports (M-1CS09010X and M-1CSO9014X). Byron 2 and Braidwood ~ Unique Response to IDI Finding Discrepancies between the contractor's piping isometric installation drawings and support designs do occur in the design process due to-the dynamic nature of the support design process. However, these are expected and are resolved systematically. The process that resolves discrepancies between as-built isometrics and design dimensions requires that Ceco be notified of differences in the as-built dimension. The process utilized on Byron 2 is the same as that described in the Byron 1 response. The Braidwood as-constructed piping isometric drawings will not contain as-built support dimensions which should further minimize the possibility of discrepancies. The support dimensions are speci-4 fled on the support drawings, and the installed positions will be checked against the key plan of the support drawing and documented. l i 'l n n y r -

. Commonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Station Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 9 of 16 -BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron Finding 4-8: ~ Elevation 'of ~ Conduit Support This -finding concerns the elevation of Conduit Support FC-3. The finding states that conduits were installed about two (2) feet higher than shown on electrical installation drawings. Byron 2 and'Braidwood Unique: Response to IDI' Finding Our program requires the contractor to submit a change document to the designer for approval prior to installing any item outside of the construc-tion tolerance. If an out-of-tolerance condition is identified by the contractor or design organization after installation and inspection, the contractor is required to generate a nonconformance report to disposition this condition. These control systems are in place at both sites. Furthermore, it should be noted that there are other programs of over-inspection which are performed on completed installation which will result in identifying generic construction problems.

Connonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 10 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron Finding 4-10: ' Conduit Pipe Strap This finding concerns an uninstalled conduit strap. Byron 2 and Braidwood Unique' Response to IDI Finding As pointed out in the Byron 1 response and reiterated in our Byron 2 and Braidwood response to Finding 4-8, there are systems in place within the con-struction program to identify, document, and correct deficiencies and/or inconsistencies. The general effectiveness of these controls is verified through independent inspections,.such as the unit concept inspections. In addition, as was done during the completion of Byron 1,. a final walkdown will be conducted to ensure that the conduit installation is properly installed and _no items are missing. f .m. .w

Y Commonwealth Edison Company ATTACHMENT 2 (Cont'd) Byron. Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 11 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron Finding 6-4: Calibration' Interval This finding addresses a discrepancy between the test reports (References 6.28 and 6.29) and the proposed technical specifications regarding the cali-bration test interval for the auxiliary feedwater pump suction pressure switches (IPSL-AF051 and IPSL-AF055). The test reports specify a test. inter-val of 208 weeks, while the technical specifications specify a test interval of 18 months. 1 ' Byron 2 'and Braidwood Unique ' Response to ~ IDI ~ Finding Byron 2 and Braidwood Station,as of this date,have not written a calibration test report package covering IPSL-AF051 and IPSL-AF055. However, it should be noted that the technical specifications for Byron I have now been final-ized, and the calibration test reports for all four units are being revised to agree with these specifications. e

r Commonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 12 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron Finding 6-6: Test Report The Connonwealth Edison test report for IPSL-AF055 incorrect 1y states the ~ direction of pressure change for the low suction pressure setpoint (Reference 6.29). In addition, this test report has a typographical error in the number for wire AF1BLAS in that it was listed as AFIBLA3. At the time this test report was inspected, Commonwealth Edison actions to correct the Sargent & Lundy instrument data sheet and Commonwealth Edison test reports had not been initiated using the instrument discrepancy report form. Subsequent Commonwealth Edison actions to correct the test report and the data. sheet discussed in Finding 6-5, while technically correct, appear to introduce unnecessary complexity in the designation of vacuum setpoint values. On the basis of our examination of other test reports (References 6.125, 6.126, 6.127, and 6.129), these errors did not appear to represent systematic weaknesses. Byron '2 'and Braidwood Unique Response to ~ IDI Finding This appears to be an isolated case and Byron 2 and Braidwood Instrument Data Sheets for these instruments are the same as Byron 1. The data sheets have been corrected. Byron and Braidwood have procedures for systematically cor-recting deficiencies which are identified. i 1 t l 5

Connonwealth Edison Company ATTACHMENT 2 (Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 13 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron 'IDI Unresolved Item 2-3: ' ' Pipe Tip Deflections Sargent & Lundy Project Instruction PI-BB-38 states that subsequent to pipe whip restraint design the final pipe tip deflections are transmitted to Project Management Division for review. This had not been done prior to - the inspection and criteria for this review are not stated. Byron 2 and Braidwood Unique Response to IDI Unresolved Item Sargent & Lundy Project Instruction PI-BB-38 is also applicable to Byron 2 and Braidwood. The disposition of final pipe whip tip deflections was com-pleted on Byron 1 using calculated deflections and a walkdown survey of the as-built configuration of the plant. This process is also being implemented on Byron 2 and Braidwood. PI-BB-38 is being revised to include responsibility and criteria for this disposition. The Project Instruction revision is scheduled for 06-03-85. It should also be noted that approximately 60 pipe whip restraints are being eliminated from each unit of Byron 2 and Braidwood I and 2 as a result of the NRC's recent approval of the elimination of arbitrary intermediate pipe breaks (see 01-07-85 letter to Ceco from the NRC). \\

r Commonwealth Edison Company ATTACHMENT 2(Cent'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 14 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Unresolved Item 3-5: Functional Capability Criteria Unresolved Item 3-5 addresses the difference in functional capability criteria for NSSS and BOP piping, stating that Westinghouse is using criteria approved for NSSS piping for analysis of 80P piping. Byron 2 and Braidwood Unique Response to IDI Unresolved Item FSAR Subsection 3.9.3.1.2.2 has been revised (Amendment 46, dated January 1985) to clarify the use of this criteria for Westinghouse scope of piping. In addition, thir same functional capability criteria is being utilized on Braidwood for the piping that is now under Sargent & Lundy's design respon-sibility. This c'arification will also be submitted as a change to the FSAR. A

Commonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 *

  • Page 15 of 16 BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron IDI Unresolved Item 5-1: Analysis Concerning Lack of Separation This item concerns specific open questions described in Notes 1, 2 and 3 and in Samples A. D and E of the report.

Note 1 concerns cable tray sepa-ration. Note 2 indicates that a cable touching the sidewall of a cable tray is a violation of Hatfield Procedure #10. Note 3 concerns touching of safety-related and non-safety-related conduits. Sample A concerns support of a tubing bundle in the remote shutdown panel. Sample D concerns safety-related and non-safety-related cables in ciose proximity in Panel IPA 11J. Sample E concerns safety-related and non-safety-related cables in close proximity in Switchgear Bus 141 Cubicle 16. Byron 2 and Braidwood Unique Response to IDI Unresolved Item Although these were Byron I specific findings, the following response addresses this item at Byron 2 and Braidwood. The Byron 2 response is identical to the Byron 1 respanse. The Braidwood response is identical except that the contrac-tor is different and the Braidwood procedure references are different. With respect to conduit separation, and as was done on Byron 1, a walkdown will be conducted on Byron 2 and Braidwood I and 2 to identify and assess conduit separations less than 1". Corrective actions as identified in the Byron 1 response for Samples A, D and E will be implemented on Byron 2 and Braidwood 1 and 2. i i l l t v

Connonwealth Edison Company ATTACHMENT 2(Cont'd) Byron Station - Unit 2 04-16-85 Braidwood Station - Units 1 & 2 Page 16 of 16 ~ BYRON 2 AND BRAIDWOOD UNIQUE RESPONSES TO BYRON 1 IDI ISSUES Byron Unresolved Item 6-1: 1.oss of Offsite Power Test Commonwealth Edison Byron Station personnel stated that a complete test of each automatic initiation signal was scheduled during the engineered safety features preoperational test. A number of preoperational test procedures (References 6.99, 6.100, and 6.101) and the loss of off-site power startup test procedure (Reference 6.102) were inspected at the Byron Station to determine how the engineered safety feature actuation system interface would be tested. The loss of off-site power test will automatically initiate auxiliary feedwater and numerous other engineered safety feature systems when circuit breakers are opened to simulate a loss of off-site power; how-ever, Step 9.1.20 of this procedure only requires verification "that at least one train of the above (listed) equipment is running." This may have been an inadvertent omission from the test procedure acceptance criteria as the procedure was not yet signed. Since both trains are. required to start auto-matica11y under these conditions, the licensee should ensure that the test procedure requires verification that both trains start during the test. Byron 2 and Braidwood Unique Response'to Unresolved Item The Byron 1 Station procedure (Reference 6.102) was revised prior to the final approval of the procedure to address the concern delineatedein the unresolved item. Appendix C3 in the Data Reduction section addresses'the verification of the start of both trains of the auxiliary -feedwater pumps and the verification that at least one train runs throughout the test. The Byron 2 and Braidwood 1 and 2 procedures will reflect these changes.

T' T Commonwealth Edison Company 04-16-85 Byron Station - Unit 2 Page 1 of 1 Braidwood Station - Units 1 & 2 ATTACHMENT 3 SUMMARiOF THE ADDITIONAL ACTION REQUIRED BY' BYRON'1 IDI FINDINGS FINDING OR ' ADDITIONAL UNRESOLVED ACTION REQUIRED ITEM BY 2 BR 1 BR 2 DESCRIPTION OF ACTION F2-12 x x Braidwood Overall Design Review F2-14 x x x Confirmatory Pipe Break Calculations F2-18 x x x Confirmatory Flooding Calculations F3-1 x x x Revise Response Spectra File F3-9 x* x* x* Nozzle Load Calculation F3-16 x* W U-Bolt Confirmatory Calculation F3-17 x* W Support Relocation Confirmatory falculation F6-1 x x x AF System Valve Operability During Preoperational Test U3-2 x x Evaluate Previously Issued Pipe Supports for Lateral Vibration Total 7 7 7 x - Indicates Additional Action Required.

  • - Indicates Follow-Up Action has been completed.

Commonwealth Edison Company 04-16-85 i Byron Station - Unit 2 Page 1 ef 1 Braidwood Station - Units 1 & 2 ATTACHMENT 4

SUMMARY

OF BYRON 1 IDI FINDINGS NOT APPLICABLE T0' BYRON 2~0R BRAIDWOOD 1 & 2 FINDING OR UNRESOLVED NOT APPLICABLE T0: ITEM BY 2 BR 1 BR 2 ' REASON'FOR NON-APPLICABILITY F3-4 x x Unit 1 Drawing Discrepancy Only F3-5 x x x Isolated Case of Incorrect Flange Weight in Piping Analysis. i F3-7 x x x Isolated Case of Discrepancy in CEA Edge Distance. t F3-12 x x )[ Document Control Item F3-16 x x h[ U-Bolt calculation Discrepancy F3-17 x x h[ Support Relocation Calculation i F4-6 x x x Isolated Case of Pipe Support Calcu-lation Discrepancy. F4-7 x x x Isolated Case of Pipe Support Calcu-lation Discrepancy. F4-9 x x Isolated Case Confined to Byron Drawings

Only, i

F5-1 x x No Diesel Driven SX Make-Up Pump on Braidwood. FS-5 x x x Isolated Case of Drawing Transcription Error. F6-5 x x Unit 1 Drawing Discrepancy Only. U3-6 x x W to Verify Correct Equipment Allow-able Loads. t Total 7 11 13 I x - Indicates Not Applicable. 9 m

- Commonwealth Edison Company 04-16-85 Byron Station - Unit 2 Paga 1 of 1 Braidwood Station - Units 1 & 2 y ' ATTACHMENT 5

SUMMARY

OF APPLICABILITY OF BYRON 1 IDR ISSUES w BYRON 2 'BRAIDWOOD 1 ' BRAIDWOOD 2 Action Completed by Byron 1

Response

29 21 21 Addtional Action Required

  • 4 6

6 Not Applicable ** 2 8 8 Total 35 35 35 See Attachment _6 for a summary of the additional actions required.

    • See Attachment 7 for a summary of the reasons that these issues were not applicable to Byron 2 or Braidwood I and 2.-

1 i 'f I k

y Commonwealth' Edison Company-04-16-85 Byron Station - Unit 2 Page 1 of 1 Braidwood Staticn - Units 1 & 2 f7TACHMENT 6

SUMMARY

OF ADDITIONAL ACTION ^ REQUIRED'BY' BYRON l'IDR s ADDITIONAL ACTION REQUIRED ISSUE BY 2 BR 1 BR 2 ' DESCRIPTION OF' ACTION '8.17 x* x* Revise Braidwood Pipe Support Weld Size Tolerance. 8.19 x Review NPS Pipe Support Calculations. 8.21 x*. x* Revise Braidwood Criteria' Document for Pipe Support Material Interchangeability. 8.25 x x x Support Configuration Reflected in Final Piping Stress Report. 8.29 x* x* ' x* Equipment Nozzle Load Calculation 8.44 x* x* x* Evaluate Effects on Pipe Analysis of Added Support at Center of CCW Heat Exchangers. 8.49 x x Confirm Adequacy of Flanges in Braidwood ESW System f \\ Total 4 6 '6 i k x - Indicates Additional Action Require'd.-N

  • - Indicates Additional Action has been,. Completed.

i J l O k j s

Commonwealth Edis:n Company 04-16-85 Byron Station - Unit 2 Page 1 of 1 Braidwood Station - Units 1 & 2 i l ATTACHMENT 7

SUMMARY

OF BYRON 1 IDR ISSUES NOT APPLICABLE'T0~ BYRON 2'OR'BRAIDWOOD 1 &-2 NOT APPLICABLE'TO: ISSU_E BY 2 BR 1 BR 2 ' REASON'FOR'NON-APPLICABILITY 8.2 -x x Braidwood has no River Screen House. 8.3 x x Braidwood has no Diesel Driven SX Make-up Pumps. 8.5 x x Braidwood has no River Screen House. 8.16 x. x x Code Case N-413 on Minimum Weld Size has been Approved. 8.19 x x NPS is not a Piping Design Subcontractor on Braidwood. 8.31 x x x Isolated Calculation Discrepancy on Weld Size. 8.40 x x No Manholes with Safety-Related Cables on Braidwood. 8.42 x x No Manholes with Safety-Related Cables on Braidwood. Total 2 8 8 x - Indicates Not Applicable. ~ l l .) -1

.. J :. 04-10-85 AGENDA PRESENTATION ON DESIGN VERIFICATION ACTIVITIES i FOR BYRON 2 AND BRAIDWOOD 1 & 2 I. COMMON ELEMENTS-0F BYRON /BRAIDWOOD B. R. SHELTON II. DESIGN PROCESS

SUMMARY

G. C. JONES III. BYRON 1 IDI ASSESSMENT ON BYRON 2 G. C. JONES AND BRAIDWOOD 1 & 2 IV. BYRON 1 IDR ASSESSMENT ON BYRON 2 G. C. JONES AND BRAIDWOOD 1 & 2 V. PRELIMINARY CLINTON IDR ASSESSMENT ON G. C. JONES BYRON 2 AND BRAIDWOOD 1 & 2 VI. DESCRIPTION OF GA PROGRAM ASPECTS G. F. MARCUS RELATIVE-T0 DESIGN VERIFICATION A. GENERAL DESIGN ANALYSIS AUDITS B. IDI FOLLOW-UP C. IDR FOLLOW-UP VII. CONCLUSION-B. R. SHELTON

04-10-85 PRESENTATION ON DESIGN VERIFICATION ACTIVITIES FOR BYRCN 2 AND BRAIDWOOD 1 & 2 PURPOSE o SUMMARIZE THE RESPONSE TO THE 01-14-85 NRC LETTER FROM D. EISENHUT TO C. REED, o ESTABLISH THAT NO FURTHER INDEPENDENT DESIGN REVIEWS ARE REQUIRED ON BYRON 2 OR BRAIDWOOD 1 AND 2. G0ALS o EXPLAIN THE EXTENT OF DUPLICATION BETWEEN BYRON AND BRAIDWOOD, o DEMONSTRATE THAT' BYRON 1 IDI AND IDR FINDINGS HAVE BEEN ADEQUATELY ADDRESSED FOR ALL FOUR

UNITS, o

DEMONSTRATE THAT THE CLINTON IDR FINDINGS ARE BEING APPROPRIATELY ADDRESSED FOR BYRON AND BRAIDWOOD. -o DEMONSTRATE THAT WE HAVE'A QA REVIEW TO FOLLOW j ALL ITEMS TO A PROPER CONCLUSION, i s

04-10-85 EXHIBIT I.1 COMMON ELEMENTS OF BYRON /BRAIDWOOD LICENSING BASIS IS DUPLICATION STANDARD PLANT CONCEPT COMMON PSAR COMBINED COMMON CP HEARINGS SIMULTANE0US CP ISSUE COMMON FSAR DUPLICATE PLANT ARRANGEMENTS COMMON DESIGN CRITERIA COMMON DRAWINGS FOR THE MAJOR DESIGN RELEASES (UNIQUE DRAWINGS CREATED TO REFLECT PLANT SPECIFIC FEATURES) COMMON EQUIPMENT SPECIFICATIONS COMMON VENDORS FOR ALMOST ALL THE EQUIPMENT COMMON CECO MANAGEMENT ORGANIZATION FOR ENGINEERING, CONSTRUCTION, AND-QUALITY ASSURANCE COMMON A/E r va

04-10-85 EXHIBIT I.2 DIFFERENCES IN BYRON AND BRAIDWOOD ESSENTIALLY SITE DEPENDENT DIFFERENCES 0FFSITE POWER SYSTEMS COOLING WATER HEAT REJECTION (NATURAL DRAFT COOLING TOWER VERSUS COOLING POND) ULTIMATE HEAT SINK (MECHANICAL DRAFT COOLING TOWER VERSUS AUXILIARY COOLING POND, INTEGRAL WITH THE MAIN COOLING POND) AUXILIARY SYSTEMS ASSOCIATED WITH THE PRECEDING SYSTEMS SECURITY SYSTEM LAYOUT (SITE DEPENDENT) DIFFERENT-FIELD LABOR CONTRACTORS

Sargent & Lundy Byron /Braidwood (B/B) Project Design Organization 8/8 Project Director D. L Leone a i Braidwood Project 8/8 Protect Manager Director W C. Cleft (") K. T. Mostal i I I I Byron Project Braidwood Project Manager Manager W. C. Cleff (") G. C. Jones (*) Byron Overalt Braldwood Overait Field Coordinator F6 eld Coordinator J. R. Meister D A. Gattagher I I Senior Structural Senior Electricot ( Mechanical Project Engineers Protect Engineers Project Eng6neers R. J. Netrel

8. G. Treece (")

R. Rakowski P. K. Agrawat T. 8. Thorsell T. Hottle (") 1 I K. Green Structural Electrical C. Lim Project Engineers Project Engineers J. Tenwinkle (*) H. Hitseman J. Anich S.Chen S. Wahlert M. Hill I . E senbart EMD Project CfD Project COD Project MOD Pro}ect HVAC Project D. Gaf anes 8"P'"' 8"P visor Supervisor Supervisor Supervisor g xy T. Khemment A. A. Dermenjian R. Orkfritz (") K. L. Adion R.E. Johnson Ptangery Z l -s (*) Indicates personnel who do not have previous CD O Byron exper6ence - g (**) Indicates Zion esperience H CO SARGENT S LUNDY H .': ' ~

04-10-85 EXHIBIT II.2 1 DIFFERENCES IN THE DESIGN PROCESS FROM BYRON 1 BYRON 2 BRAIDWOOD 1 & 2 CIVIL / STRUCTURAL SAME SAME ELECTRICAL SAME SAME MECHANICAL PROCESS DESIGN SAME SAME PIPING ANALYSIS AND SUPPORT DESIGN

  • SAME DIFFERENT DESIGN ORGANIZATIONS
  • BYRON 1 & 2 - A)

H RESPONSIBLE FOR ALL COMPUTER ANALYZED PIPING IN THE CONTAINMENT AND ECCS' PIPING IN THE AUXILIARY BUILDING. B) 6 u. RESPONS[BLE FOR REMAINDER OF COMPUTER ANALY-ZEL "ING (AUXILIARY BUILDING AND OUTDOOR). C) NPS CID PIPING CONTRACTOR RESPONSIBLE FOR SMALL BOP' PIPE AND INSTRUMENT LINES USING S&L GUIDE-L1;cS. BRWD.1 & 2 - A) S&L RESP (ONSIBLE FOR ALL COMPUTER ANALY PIPING EXCEPT RC PIPING, WHICH IS DONE BY H), B) S&L RESPONSIBLE FOR ALL SMALL BORE PROCESS PIPING. C) PIPING CONTRACTOR RESPONSIBLE FOR INSTRUMENT LINES USING S&L GUIDELINES.

04-10-85 EXHIBIT II.3 DUPLICATION OF THE BYRON PIPING AND SUPPORT DESIGN ON BRAIDWOOD GENERAL APPROACH: UTILIZE AN EXISTING PIPING ANALYSIS AND SUPPORT DESIGN FROM BYRON ON BRAIDWOOD, IF POSSIBLE. -RESULTS THUS FAR INDICATE THAT THIS APPROACH HAS BEEN SUCCESSFUL ON APPR0XIMATELY 80% OF THE SUBSYSTEMS. THIS INCLUDES MANY OF THE BYRON SUBSYSTEMS ANALYZED BY H. I l

04-10-85 EXHIBIT 11.4 j ENHANCED DESIGN TOOLS AT BYRON 2 AND BRAIDWOOD 1 & 2 PRIMARILY REFLECT GREATER UTILIZATION AND INTEGRATION OF COMPUTER AIDED ENGINEERING AND COMPUTER AIDED DESIGN. EXAMPLES: SMLBOR (COMPUTER AIDED APPLICATION OF GUIDELINES FOR SMALL BORE SUPPORT DESIGN) PIP 0PT (0PTIMIZATION OF SUPPORT LOCATIONS, RESULTING IN REDUCING THE NUMBER OF PIPE SUPPORTS) S&L WILL CONTINUE TO UTILIZE SIMILAR ENHANCEMENTS IN THE FUTURE ON UNIQUELY DESIGNED SYSTEMS. e

04-10-85 EXHIBIT 11.5 ~ S&L DESIGN PROCESS ENHANCEMENTS SUBSEQUENT TO THE BYRON 1 IDI AND IDR o S&L HAS INSTITUTED AN ADDITIONAL LEVEL OF REVIEW IN THE FORM OF A CALCULATION SAMPLING PROGRAM (TECHNICAL MONITORING PROGRAfD o REQUIREMENTS FOR ADEQUATE DOCUMENTATION OF ENGINEERING JUDGEMENT HAVE BEEN INCORPORATED INTO THE REVISED S&L QA PROCEDURE ON DESIGN CALCULATIONS. o DESIGN INPUT BETWEEN PROJECT TEAM MEf4BERS OF DIFFERENT DIVISIONS ARE NOW MORE RIGIDLY CONTROLLED THROUGH A NEW S&L QA PROCEDURE. o REVISED S&L QA PROCEDURE HAS PLACED ADDITIONAL EMPHASIS ON If00CTRINATION AND TRAINING 0F PERSONNEL TO ASSURE THAT A SUITABLE PROFICIENCY IS ACHIEVED AND MAINTAINED.

04-10-85 EXHIBIT III,1 1

SUMMARY

OF APPLICABILITY OF BYRON 1 IDI FINDINGS BYRON 2 BRAIDWOOD 1 BRAIDWOOD 2 ACTION COMPLETED BY BYRON 1

RESPONSE

66 62 60 UNIQUE RESPONSE REQUIRED 16 16 16 -ADDITIONAL ACTION REQUIRED 7 7 7 I NOT APPLICABLE 7 11 13 TOTAL 96 96 96 f M, f 4 9 .7 l I i l

04-10-85 EXHIBIT III.2

SUMMARY

OF BYRON 2 AND BRAIDWOOD 1 & 2 UNIQUE RESPONSES TO BYRON 1 IDI FINDINGS Ceco COMMITTED.T0 RESPOND'TO 15 FINDINGS IN THEIR 12-30-83 LETTER FROM C. REED TO R. C. DEYOUNG. PLANT UNIQUE JET IMPINGEMENT REPORTS WERE COMMITTED TO BY CECO IN THEIR 08-16-84 LETTER. COMMON APPROA0i IS BEING TAKEN AT ALL 4 UNITS. SOME OF THIS WORK IS STILL ONG0ING. I i =

04-10-85 EXHIBIT III.3 STATUS OF BYRON 2 AND BRAIDWOOD 1 & 2 UNIQUE RESPONSES TO BYRON 1 IDI FINDINGS FINDING OR UNRESOLVED COMPLETION STATUS DESCRIPTION OF ITEM BY 2 BR 1 BR 2 FINDING 0R UNRESOLVED ITEM F2-1 WALKDOWN OF AF D/G AIR INTAKE F2-16 PLANT SPECIFIC JET IMPINGEMENT REPORT F3-2 PIPING ANALYSIS FUNCTIONALITY CHECK F3-8 CONTROL OF REMOVAL OF VOIDED PIPE SUPPORTS F3-10 CONTROL OF PIPE SPAN LENGTH DEVI-ATIONS F3-13 METHOD TO ASSURE PIPE TO SLEEVE CLEARANCES ARE MET F3-14 ANALYTICAL MODELLING OF' PIPE BRANCH LINES F3-15 PIPE SUPPORT LOCATION DRAWING DISCREPANCIES F4-8 CONTROL OF CONDUIT SUPPORT INSTAL-LATION F4-10 FINAL WALKDOWN OF CONDUIT INSTAL-LATION F6-4 REVISE CALIBRATION TEST REPORTS F6-6 INSTRUMENT DISCREPANCY REPORT FORMS U2-3 FINAL PIPE TIP DEFLECTIONS U3-5 FSAR STATEMENT ON FUNCTIONAL CAPA-BILITY US-1 CONDUIT SEPARATION WALKDOWN U6-1 LOSS OF OFFSITE POWER' TEST PRO-CEDURE REVISION

  • INDICATES FOLLOW-UP ACTION HAS BEEN

. COMPLETED. l i

04-10 EXHIBIT III.4

SUMMARY

OF THE ADDITIONAL ACTION REQUIRED BY BYR0f! 1 IDI FINDINGS FINDING OR ADDITIONAL UNRESOLVED ACTION REQUIRED ITEM BY 2 BR 1 BR 2 DESCRIPTION OF ACTION F2-12 X X BRAIDWOOD OVERALL DESIGN REVIEW F2-14 x x x CONFIRMATORY PIPE BREAK CALCULATIONS F2-18 X X X CONFIRMATORY FLOODING CALCULATIONS F3-1 X X X REVISE RESPONSE SPECTRA FILE. F3-9 x* x* x* N0ZZLE LOAD CALCULATION F3-16 x* H U-BOLT CONFIRMATORY. CALCULATION F3-17 x* H SUPPORT RELOCATION CONFIRMATORY CALCULATION F6-1 X X X AF SYSTEM VALVE OPERABILITY DURING PREOPERATIONAL TEST. U3-2 X X EVALUATE PREVIOUSLY ISSUED PIPE SUPPORTS FOR LATERAL VIBRATION. TOTAL 7 7 7 X - INDICATES ADDITIONAL ACTION REQUIRED.

  • INDICATES FOLLOW-UP ACTION HAS BEEN' COMPLETED.

04-10-85 EXHIBIT III 5 L

SUMMARY

OF BYRON 1 IDI FINDINGS NOT APPLICABLE TO BYRON 2 OR BRAIDWOOD 1 & 2 FINDING OR UNRESOLVED NOT APPLICABLE TO: ITEM BY 2 BR 1 BR 2 REASCN FOR NON-APPLICABILITY F3-4 X X UNIT 1 DRAWING DISCREPANCY ONLY. F3-5 X X X ISOLATED CASE OF INCORRECT FLANGE WEIGHT IN PIPING ANALYSIS. F3-7 X X X ISOLATED CASE OF DISCREPANCY IN CEA EDGE DISTANCE. F3-12 X X H DOCUMENT CONTROL ITEM. 1 F3-16 X X' N U-BOLT CALCULATION DISCREPANCY. F3-17 X X H SUPPORT RELOCATION CALCULATION. F4-6 X X X ISOLATED CASE OF PIPE SUPPORT CAL-CULATION DISCREPANCY. F4-7 X X x ISOLATED CASE OF PIPE SUPPORT CAL-CULATION DISCREPANCY. F4-9 X X ISOLATED. CASE CONFINED TO BYRON DRAWINGS ONLY. F5-1 X X NO DIESEL DRIVEN SX MAKE-UP PUMP ON BRAIDWOOD. F5-5 X X X ISOLATED CASE OF DRAWING TRANS-CRIPTION ERROR. F6-5 X X UNIT 1 DRAWING DISCREPANCY ONLY. U3-6 X X H TO VERIFY CORRECT EQUIPMENT ALLOW-ABLE LOADS. TOTAL CF 11 13 X - INDICATES NOT APPLICABLE.

04-10-85 EXHIBIT IV.1

SUMMARY

OF APPLICABILITY OF BYRON 1 IDR ISSUES BYRON 2 BRAIDWOOD 1 BRAIDWOOD 2 ACTION COMPLETED BY BYRON 1 -RESPONSE 29 21 21 -ADDITIONAL ACTION REQUIRED 4 6 6 NOT APPLICABLE 2 8 8 r TOTAL 35 35 35 1 1 a -l ~

04-10-85 EXHIBIT IV.2 1

SUMMARY

OF ADDITIONAL ACTION REQUIRED BY BYRON 1 IDR 1 ADDITIONAL ACTION REQUIRED 1 ISSUE BY 2 BR 1 'BR 2 DESCRIPTION OF ACTION 1 8.17 X* X* REVISE BRAIDWOOD PIPE SUPPORT WELD SIZE TOLERANCE. j' 8.19 X REVIEW NPS PIPE SUPPORT CALCULATIONS. 8.21 x* x* REVISE BRAIDWOOD CRITERIA DOCUMENT FOR PIPE SUPPORT MATERIAL INTERCHANGEABILITY. 8.25 X X X SUPPORT CONFIGURATION REFLECTED IN FINAL PIPING STRESS REPORT. 8.29 x* x* x* EQUIPMENT N0ZZLE LOAD CALCULATION. 8.44 x* x* x* EVALUATE EFFECTS ON PIPE ANALYSIS OF ADDED SUPPORT AT CENTER OF CCW HEAT EXCHANGERS. 8.49 X X CONFIRM ADEQUACY OF FLANGES IN BRAIDWOOD ESW SYSTEM. TOTAL 4 '6 6 i X - INDICATES ADDITIONAL ACTION REQUIRED.

  • INDICATES ADDITIONAL ACTION HAS BEEN COMPLETED.

i

04-10-85 EXHIBIT IV.3

SUMMARY

OF BYRON 1 IDR ISSUES NOT APPLICABLE TO BYRON 2 OR BRAIDWOOD 1 & 2 NOT APPLICA3LE T0: ISSUE-BY 2 BR 1 BR 2 REASON FOR NON-APPLICABILITY 8.2-X X BRAIDWOOD HAS NO RIVER-SCREEN HOUSE. 8.3 X X BRAIDWOOD HAS NO DIESEL DRIVEN SX MAKEUP PUMPS. 8.5 X X BRAIDWOOD HAS NO RIVER SCREEN HOUSE. i 8.16 X X X CODE CASE N-413 ON MINIMUM WELD SIZE HAS BEEN APPROVED. i 8.19 X X NPS IS NOT A PIPING DESIGN SUB-l CONTRACTOR. 8.31 X' X X ISOLATED CALCULATION DISCREPANCY ON WELD SIZE. I 8.40 X X NO MANHOLES WITH SAFETY-RELATED' CABLES ON BRAIDWOOD. . 8.42 X X NO MANHOLES WITH SAFETY-RELATED CABLES ON BRAIDWOOD. l TOTAL 2-8 8 I X - INDICATES'NOT APPLICABLE. t 4 i ~ - ~, w. - ~ + - , () < ,o

04-10-85 EXHIBIT V PRELIMINARY ASSESSMENT OF CLINTON IDR ON BYRON 2 AND BRAIDWOOD 1 & 2 FINAL REPORT ON CLINTON IDR ISSUED LATE JANUARY 1985 CLOSE OUT MEETING WITH NRC HELD ON 03-07-85 PRELIMINARY ASSESSMENT BY S&L INDICATES THAT THERE ARE: o NO MAJOR DESIGN IMPACT o N0 HARDWARE CHANGES CECO QA AUDIT OF S8L ON JANUARY 21-25, 1985 INDICATED THAT ALL CONCERNS EXPRESSED IN THE CLINTON IDR ARE ALREADY BEING ADDRESSED IN AN ACCEPTABLE MANNER BY THE BYRON /BRAIDWOOD PROJECTS. L i

'~ q ~ \\ 04-10-85 EXHIBIT VI.1 i COMMONWEALTH EDISON QUALITY ASSURANCE DEPARTMENT SELF DIRECTED ENGINEERING ANALYSIS PROGRAM I. GENERAL DESIGN ANALYSIS AUDITS A. BY' CECO 0A B. BY OUTSIDE CONSULTANTS II. BYRON 1 IDI ITEMS i CECO QA AUDIT - JAN. 7 - 11, 1985 i III. CLINTON IDR ITEMS CECO QA AUDIT - JAN. 21 - 25, 1985 i Y t 4 i p .d-

04-10-85 EXHIBIT VI.2 COMMONWEALTH EDISON QUALITY ASSURANCE DEPARTMENT DESIGN ANALYSIS AUDITS o -1974 - 1978: PROGRAM AUDITS 1979 - PRESENT: DESIGN AUDITS o - AUDITORS - QUALIFIED ENGINEERS - AUDIT TEAMS - 4 OR 5 PEOPLE - AUDIT-DURATION - 1 WEEK - AUDITS COMPLETED - 16 - AUDIT SCOPE - TECHNICAL j

04-10-85 EXHIBIT VI.3 CECO 0.A. SCOPE OF DESIGN ANALYSIS AUDITS 1. REVIEW CALCULATIONS 2.- FSAR COMITMENTS 3. COMPUTER PROGRAM VALIDATION 4. PIPING DESIGN 5. DESIGN CHANGES 6. STRESS ANALYSIS '7. DESIGN CRITERIA APPLICATION l 8.- PIPE SUPPORTS, HANGERS, RESTRAINTS, SNUBBERS i

9. -EQUIPMENT QUALIFICATION 10.

CABLE TRAY LOADING i 11. BYRON IDI A). NOV. 1983 AUDIT - NRC REPORT - FACTS ADDRESSED - ADEQUATE SUPPORTING DOCUMENTS- - RESPONSE - REASONABLE - RESPONSE - TECHNICALLY ACCEPTABLE B) JAN 1985 AUDIT (7 MAN TEAM) - VERIFY lMPLEMENTATION OF CORRECTIVE ACTION - THREE OBSERVATIONS AND TEN OPEN-ITEMS. - ESSENTIALLY COMPLETE -n ,-r e

04-10-85 EXHIBIT VI,4 CECO QUALITY ASSURANCE BYRON IDI FOLLOW-UP AUDIT 07-85 OBSERVATIONS 1. COMPARE LOGIC DIAGRAMS TO SCHEMATICS 2. CALCULATION FOR BATTERY ROOM TEMPERATURE 3. CALCULATION FOR SLAB LOADING OPEN ITEMS (MOSTLY DOCUMENTATION) 1. DOCUMENT - EFFECT OF TURBINE BLDG. CRANE FAILURE 1 2. PREPARE CALCULATION - POSTULATED LONGITUDINAL BREAK 3. REV. FSAR - PRESSURIZER SPRAYLINE 4. REV. REPORT - BATTERY CHARGER EQ NOT DONE 5. REV. CALCULATION - EXCLUDE RHR-1 FROM TIP DEFLECTION 6. REV. FSAR - CLARIFY FUNCTIONAL CAPABILITY CRITERIA 7. REV./ REVIEW PROC. - LOSS-0F 0FF-SITE POWER TEST 8. COMPLETE EQ TEST - PRESSURE SWITCHES 9. REV PROC..- BRAIDWOOD FINAL LOAD CHECKS 10. PREPARE ANALYSIS - BYRON 2, BRAIDWOOD 1 & 2 F 0I L $S, LbODLEVEL l L

04-10-85 EXHIBIT VI.5 CECO QUALITY ASSURANCE BYRON IDI FOLLOW-UP AUDIT 07-85 ASSESSMENT FROM AUDIT REPORT... "THE GENERAL CONCENSUS OF THE AUDIT TEAM IS THAT S8L HAS ADDRESSED THE CONCERNS IDENTIFIED IN THE NRC IDI AND THAT THE COMMITMENTS MADE IN THE RESPONSE TO THESE CONCERNS HAVE BEEN PROPERLY IMPLEMENTED." "IN

SUMMARY

, FEW DEFICIENCIES WERE IDENTIFIED. S8L WAS ABLE TO PRESENT ADEQUATE DOCUMENTATION TO SUPPORT THEIR COMMITMENTS. IN SOME AREAS COMPREHENSIVE REVIEWS HAVE BEEN PERFORMED TO SUPPORT S8L'S POSITION." "UPON VERIFICATION OF COMPLETION OF THE AUDIT ITEMS, THE BYRON IDI ITEMS WILL BE. CONSIDERED COMPLETED."

04-10-85 EXHIBIT VI.6 DESIGN ANALYSIS AUDITS - BYROM/BRAIDWOOD BY OUTSIDE CONSULTANTS DATE SCOPE JUNE 1982 < DESIGN CRITERIA STRESS ANALYSIS ) EQUIPMENT QUALIFICATION EQUIPMENT SPECIFICATION NOV. 1982 ' COMPUTER PROGRAM VALIDATION MARCH 1983. DESIGN MODELS ADHERENCE TO CODES PIPE WHIP MODELING FLUID SYSTEM CLASSIFICATION OPERATING MODES THERMAL-HYDRAULIC OPER, ANALYSIS MARCH 1984 SEISMIC / ENVIRONMENTAL QUALIFICATION ELECTRICAL SEPARATION BYRON IDI ITEMS l JAN, 1985 CLINTON IDR ITEMS - VERIFIED FOR BYRON 2 AND BRAIDWOOD 1 & 2 - OPEN ITEMS 4 v

04-10-85 EXHIBIT VI,7 CECO QUALITY ASSURANCE CLINTON IDR APPLIED TO BYRON /BRAIDWOOD 01-21-85 FINDINGS o REVISE FSAR - CORRECT CONCRETE STRAIN LIMIT o ANALYZE NEED FOR CORROSION ALLOWANCE IN EQ FOR EQUIPMENT OBSERVATION o CHECKLIST FOR SEISMIC REVIEW DOES NOT DOCUMENT DATA (ACTUAL VS. ALLOWABLE) OPEN ITEMS o SYSTEM FOR TRACKING PENDING FSAR CHANGES o REVIEW 0F VENDOR FABRICATION DRAWINGS o ADDITIONAL DOCUMENTATION FOR SEISMIC QUALIFICATION OF DIESEL FUEL STORAGE'. TANKS

04-10-85 EXHIBIT VI.8 1 l CECO QUALITY ASSURANCE CLINTON IDR AUDIT - BYRON /BRAIDWOOD 01-21-85 ASSESSMENT FROM AUDIT REPORT... "THE BYRON /BRAIDWOOD PERSONNEL WERE ACUTELY AWARE 0F THE TYPES OF CONCERNS (OR SIMILAR ONES) EXPRESSED IN THE CLINTON IDR, AND HAVE MADE ADEQUATE PROVISIONS TO DEAL WITH THEM. THAT AWARENESS USUALLY WAS NOT DUE TO THE CLINTON IDR BUT RATHER WAS OBTAINED BY EXPERIENCE RELATED TO INTERFACING WITH THE NRC (SUCH AS IE BULLETINS), AND THE PROJECT EXPERIENCE SUCH AS THE IDI AND IDR ON BYRON UNIT 1. BASED UPON THE AUDIT SAMPLES EXAMINED, ALL THE CONCERNS EXPRESSED IN THE CLINTON IDR ARE ALREADY BEING ADDRESSED IN AN ACCEPTABLE MANNER BY THE BYRON /BRAIDWOOD PROJECTS." i i

04-10-85 EXHIBIT VI,9 COMf:0NWEALTH EDISON 0UALITY ASSURANCE DEPARTi1ENT S$LF DIRECTED ENGINEERING ANALYSIS PROGRAF] 1 BASED ON- - DESIGN ANhlYSIS AUDITS - CECO QA~ s - DESIGN ANALYSIS AUDITS - CONSULTANTS - VERIFICATION OF BYRON.1 IDI - VERIFICATION OF CLINTON.IDR CONCLUSION - NO SIGNIFICANT DESIGN PROBLEMS - Ceco 'AND S&L HAVE ADEQUATE CONTR0L OVER DESIGN - DESIGN PROCESS COMPLIES WITH.FSAR C0fitilT-MENTS AND NRC REGULATIONS

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r l 04-10-85 EXHIBIT VII CONCLUSION BYRON AND BRAIDWOOD HAVE BEEN EXTENSIVELY DUPLICATED ISSUES FROM BYRON 1 IDI AND IDR AND CLINTON IDR HAVE BEEN ADEQUATELY ADDRESSED IN THE DESIGN OF BYRON 2 AND BRAIDWOOD 1 AND 2. Ceco AND S&L QA FOLLOW-UP ACTIONS ARE ASSURING THESE ISSUES ARE BEING PURSUED TO A PROPER CONCLUSION. -WE BELIEVE THE DESIGN PROCESSES FOR BYRON 2 AND BRAIDWOOD 1 AND 2 MEET THE REGULATIONS AND LICENSING COMMITMENTS; THEREFORE, THERE IS NO NEED TO PERFORM ADDITIONAL INDEPEN-DENT DESIGN REVIEWS ON BYRON 2 OR BRAIDWOOD 1 AND 2. -}}

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