Text

Forwards Previously Withheld Documents Per ASLB 850226 Memorandum & Order Releasing Documents Listed in Attachment B to .Certificate of Svc Encl.Related Correspondence
	ML20116P131
Person / Time
Site:	South Texas
Issue date:	05/03/1985
From:	Axelrad M; HOUSTON LIGHTING & POWER CO., NEWMAN & HOLTZINGER
To:	Bechhoefer C, Eva Hill, John Lamb; Atomic Safety and Licensing Board Panel
References
	CON-#285-886 OL, NUDOCS 8505070506
	Download: ML20116P131 (60)
	v • d • e

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pTED o NawxAN & HoLTzzwoza, P. C ISIS L STREET, N. W.

WASHINGTON, D. C. aC O3e wituAu s.narn,sst s.Aca es. n.newmAn Lu .un,s= *****"'***""

DOCHETE

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-S m _.A., ,NS EAAOL LTN NtweeaN AUSON LaseASTER*

'EIS7AYS S'"' 0FFiCE OF SECRtIA5 ? E'='.I$" SYN mienA 6 & SAU a 00CKETING & SEWW **v'* * = "'"

ALYe00 M.SUTTEm"esAN KEVlts P,GALLE0s gg . 00sALD JANE J. LRYAN SILVSfHsAN TeeOseAS A.SCMaeUT3 geeCoeAEL F. DetALy JACOL.YN JOSE A.SsMMO908 M LSTUSGS a==. va.

.T i.wes,7c SeOS$RT Li>dENSTEIN ' L seOnesAfe A.FLAmassomse OF C0weestk t Charles Bechhoefer, Esq.

y Chairman, Administrative Judge '

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission .

Washington, D.C. 20555 Dr. James C. Lamb, III Administrative Judge 313 Woodhaven Road ,

Chapel Hill, NC 27514 ,

Ernest E. Hill Administrative Judge Hill Associates 210 Montego Drive Danville, CA 94526 ,

Re: Houston Lighting & Power Co., et al.

South Texas Project, Units 1 &"7 -

Docket Nos. STN 50-498, STN 50-499%

Dear Members of the Board:

Applicants' motion filed in the Houston Lighting &

Power Co. , et al. v. Brown & Root, Inc., et al., litiga-tion, applyEg for the release of the proEcEd documents listed in Attachment B to Applicants' April 19, 1985 letter to the Board and the parties has been granted, and an appropriate order was executed on May 1, 1985. Accordingly, the documents previously withheld pursuant to the court's 8505070506 050503 PDR ADOCK 05000498 SDS Q PDR

NawwAx & Hor.rzawomm,P. C.

.s Charles Bechhoefer, Esq.

Dr. James C. Lamb, III Ernest E. Hill May 3, 1985 Page Two protective order are being provided to the Board and the parties pursuant to the Board's February 26, 1985 Memorandum and Order.

Respectfully submitted, I _- : -

Jack R. Newman Maurice Axelrad 4 Alvin H. Gutterman

. Steven P. Frantz -

Donald J. Silverman 1615 L Street, N.W.

Washington, D.C. 20036 Finis E. Cowan 3000 One Shell Plaza Houston, Texas ATTORNEYS FOR HOUSTON LIGHTING NEWMAN & HOLTZINGER, P.C. & POWER COMPANY, Project Manager 1615 L Street, N.W. of the South Texas Project acting Washington, D.C. 20036 herein on behalf of itself and the other Applicants, THE CITY BAKER & BOTTS OF SAN ANTONIO, TEXAS, acting by 3000 One Shell Plaza and through the City Public Houston, Texas 77002 Service Board of the City.of San Antonio, CENTRAL POWER AND l

LIGHT COMPANY, and CITY OF AUSTIN, TEXAS cc: Service List l

1 ,

l l . - - _ - - - - . . . . . - . - - - . - _ - _ . - , . . _ . - - - _ .. - -.. l

UNITED STATES OF AMERICA DOCKETED

. NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOAq 85 MY -7 20 :25 In the Matter of )

0FFICE OF SECRt.iAk r'

) EmCKETING & SE8V!Cl' HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 BGANCH COMPANY, ET--

AL. ) 50-499 OL

.. )

(South Texas Project, Units 1 )

and 2) )

$~ CERTIFICATE OF SERVICE

$ I hereby certify that a copy of Applicants' letter to the h Atomic Safety and Licensing Board dated May 3, 1985 (including attachments where designated by (*)) has been served on the following individuals and entities by. deposit in the United States mail, first class, postage prepaid, on this 3rd day of May, 1985. -

Charles Bechhoefer, Esq.* Brian Berwick, Esq.*

Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U. S. Nuclear Regulatory Commission Division Washington, D.C. 20555 P. O. Box 12548, Capitol Station Austin, TX 78711 Dr. James C. Lamb, III* ~

Administrative Judge Kim Eastman, Co-coordinator

313 Woodhaven Road ' Barbara A. Miller Chapel Hill, NC 27514 Pat Coy Citizens Concerned About Ernest E. Hill

Nuclear Power i

Administrative Judge 5106 Casa Oro -

Hill Associates San Antonio, TX 78233 210 Montego Drive Danville, California 94526 Lanny Alan Sinkin*

3022 Porter St. N.W., #304 Mrs. Peggy Buchorn* Washington, D.C. 20008 Executive Director Citizens for Equitable Ray Goldstein, Esq.

Utilities, Inc. Gray, Allison & Becker Route 1, Box 1684 100 Vaughn Building Brazoria, TX 77422 807 Brazos Austin, Texas 78701-2553

(_ .

Oreste Russ Pirfo, Esq.*

Robert G. Perlis, Esq.

Office of the Executive Legal Director u.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section*

Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i 1-hw

,1-i

5

} BrownCTRoot.ine.

9 INTEROFFICE MEMORANDUM T0: -

D. Pmlewicz DATE: May 8, 1981 FROM: J. A. Signomili

SUBJECT:

QdADREXSTPReview Per our telecon this morning, please advise on responses to the attached Nuclear Analysis questions as soon as possible. HL&P has been asked that rJ&R respond by noon today whether these items constitute a potentially re-portable problem in accordance with 10CFR50.55(e).

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/y.,t J; A. Signorelli t -k i

?? JAS/iyg cc: J. N. Sorenson S. M. Mirsky W. Gallagher P. D. Arrowsmith l

i ^ F. E. Muellner J. L. Renehan R. D. Jain J. F. Pinto

. *J. L. Hawks N

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,' . l (a) Nuclear Analysis did not control the use of temperature values issued for equi,pment design, nor is there any analytical basis

. for temperatures used outside of containment (see Question N-15).

The use of saturation tesperatures rather than actual temperatures inside containment is not conservative in all cases as there !

has been no analysis performed to support the implied assumption that equipment will not respond to actual temperatures. This approach is not in accordance with IEEE-323 which requires qualification to actual temperatures (see Question N-1).

H (b) There is an insufficient number of environmental analyses in ;

place, and those analyses previously done contained many errors. The only environmental analysis performed by B&R

_ contained.a gross error (see Question N-13). Obvious errors were also discovered in an NUS analysis for inside containment

~~

. (see Question N-1). The only MUS analysis currently valid is

~~

the containment environmental analysis for a LOCA (see Question N-1).

a.

There is no currently valid mass energy release or environmental anplysis for outside of containment (see Question N-3). The few analyses previously performed were not for currently N postulated breaks and/or contained errors (see Questions N-3

! and M-13). Brown and Root was uncertain of any need to perform analyses for the high energy lines in the MAB (see Question N-3).

l The failure to perform any valid environmental analyses outside

" of containment is untimely, and could possibly result in either retrofit in the MAB or incorrectly designed equipment in the IVC.

(

A review of work performed by or under the direction of the Nuclear Analysis Group indicates problems or the potential for problems'in all areas analyzed, namely, environmental analysis, l

l reacto--shield wall annulus pressurization analysis, verification of release of environmental data, essential cooling pond

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4-59

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L analysis, and battery room hydrogen concentration. Except for

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a containment heat sink surface areas analysis, and an NUS LOCA environmental analysis (see Question N-1), there were no analyses found that were sufficient, correct and current.

'Other analyses were either obsolete, insufficient in basis, or contained errors (see Questions N-1, N-2, N-8, N-10, N-11, N-12, Pt-15, N-17, and N-25).

The following findings may have a serious impact on plant licensability or deserve licensing attention:

(c) Nuclear Analysis has failed to scope, perfom, or have analyses perfomed that should have been completed (including correction '

~ -

of reports containing obsolete or erroneous analysis) given

. . the present state of STP design and construction.

(d) An identification of Nuclear Analysis calculations needed to ,,

support other disciplines was not evident (see Question N-1).

,5 ..

~

. (e) The annulus pressurization analysis performed by NUS was well

, ,- modeled but used an inappropriate computer program (RELAP3).

They should have used COMPARE as they had done earlier for another plant. Brown and Root should have pursued-re-analysis . .

N as the annulus pressurization analysis as an input to structural ,

analyses. Both of these analyses require consiv>r ble elapsed ,,

, time, as does NRC approval of the results. The failure to ,- !

submit such an analysis in a timely manne could cause licensing delays or retrofits. B&R does not appear ts, be sufficiently concerned about the timeliness of analysis in relation to '

construction schedules or licensing (see Question N-2).

]

l (f) Awareness of the proper methodology for handling potential

flow paths during environmental analysis was not evident (see i

Question N-8), j i

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(g) Awareness of the need to model makeup supplies of water for long ters environmental analysis was not evident (see Question N-10).

(h) Awareness of W trip logic for MSIVs appeared weak (see Question N-11).

(i) Nuclear Analysis did not appear to be sufficently knowledgeable in the area of valve performance and qualifications (see

, Question N-12).

(j) Analysis for a double ended break rather than a crack break disagrees with a FSAR commitment (see Question N-13).

f*

g. (k) B&R does not appear to be sufficiently aware of high energy lines in the MAB (see Question N-13).

(1) B&R stated that documents are not issued without verified o analysis. However, SDD 4E010EQ004-A, " Qualification of Class 1E Equipment," was issued without any reasonable analytical basis

. (see Question N-15). Only a fortunate series of coincidences will prevent a situation in which some equipment is overdesigned N and other equipment is underdesigned.

,-. (m) Differences in ECP initial temperature assumptions were observed between Nuclear Analysis and Heavy Civil (see Question N-17).

(n) Asstamptions regarding the availability of various heat sinks under varying plant conditions should be re-examined (see

, Question N-17).

(o) The battery room hydrogen analysis did not address the true problem of hydrogen concentration near the top of the room.

This analysis was not properly classified as safety related (see Question N-25).

4-61 0919 0100518

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DCLOSURE (2) g O

l sueur or snows AND Root rino!Nas on P SOUTH TEKA5 PROJECT QUADRIX ENGIhEERING REVIEW (nty 1981)

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SUBRCT Inadequay of the folloufag STp afvAC Systass 3:43 hlf{ i Fuel Mandlfag Suf f, ding And e

%4. ce mesle/ B(R reptens Q m fe clays M(C

' DEsta19110N OF POTENTIAL plettDi f1rghtremidt h $ gM th Aprf) 7.1980 of a potential pr. Nouston Lighting & power (NL&p) Informed Brown 8 agot oblem of cooling the Radmaste Control Room in the MAB A B&R stub group was formd (Special problem fil) with representation, '

from and the Otsciplines.

HVAC (B&R) flechanical. Electrical.14C.

h Septeeer 18. 1980 Structural.

MA if lF T

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concerning candidate areas for additional stu@ was released.a preliminary assessment A date areas included: The candf.

reeneste control room, which contains the hotthe shutdown reacter panelthe electric sake.up water pump cubicle the boric acid transfer pwp cubicle the 1

CVCs valve cubfcle at elevation 41'.0* and 10'-0* In the MAS: the spent fuel pool cooling pump cubicles in the fuel band 11ag butidfas M) and

$ the ' valve charge Ifnes from cubicles in the the Nigh Need FMS where containment fselation eelve(s la d jection and Containment $ pray pur$afety Injectionou ' gLiatety In-es are 1ecated.

need for supplemental air cooled chf11ers to handle additional S antici.t this ti pated (based en engineering judgesent) IIVAC leads were discussed. .

feed gr f ing cooling pacity. r ad a rch l 344 $ fel 1 2.

fch )sS81. edraft s by I t Pg f6ta fch ad vi ^t 2 }

cool e of the pqui i d and con rue thefeed m. ~

t scribed /a Tap e IAAt .

. th fierch 19. 1981. representatives of GUADIIEX. under centract to IE8p

conducted a technical audit. of B&R's MVAC Systes design and fa a repor. t received by S&R on lley 7,1981, confirmed 84R's earlier assessment that there may be insufficient IfvAC cooling capacity for eqvfysent located fa the M48 and M.

Although we do not yet have actual heat lead data, factudfas manfeum allowable operating temperature informetton, for all potentfally affected systens, we believe that there is currently sufficient uncertainty con-cerning the adequay of the MVAC System destysed for the MAB. m and EAR to consider the matter to be potentf ally reportable at this tfee, t

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APPROACM TO RESOLUTION l

A supplerental HVAC system coeposed of in room fan-cell units and afr cooled chillers is currently being considered for incorporation into the l

' $ip Units. Sketches showing proposed physical arrancesents are currently "

/ being prepared for candidate locations and additional theresl operettag data is being sought from S equfpaent vendors.

STATUS OF p0RP05t0 RESOLUTION A final determination concerning the need for additional safety grade HVAC '

capacity will be corpleted upon receipt of the following evaluations pipe breaks outside containsent (QUADREI Audit Question 4.4.4.1.a)s end. Special probles 16 (QUADR 11 Audit Question 4.4.4.1.b). These evolvations will een- >

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- sider the equipnent and piping heat losses and the mentmum environment for r d

/ which the safety related cosponents are quaitfled. Without performing these evaluations we cannot determine the saact acgnitude of the tapact

/ en plant safety. I Based on these uncertaintfes. me feel that this problem is potentfally rea portable under 10CFA50.55(e) and is currently being investigated as a potential 10Clatt.

MASONS FOR FINAL REPORTABILITY DELAY i

project Engineering had not cospleted sufficient thermal calculattens go indicate a clea need for a plesental MVAC 5[. stem. w)ercawe(sv.ntdelerauff in,ce=plch=ie

= st cahm seas avu 6 r r:g e. ee, m ema/res ukse.L csm onew er est'l fr*h it h he s t .% tLs NVAC. >

- PROJtcTED COMPLETION OF CORRICTIVE ACTION an.4 //c su7 kmes A Wire l m1 The projected corpletion date for the following Special probles #16 actf- _

vjijst is currently June 15. 1981 to have a definition of deste qualificatten

- testeratures fo3setety-se&eted equipment. a preliminary assesssent of heat losses and area torperatures and a conceptual desty and pre 11stnery lar bs44d.

out for a supplesental NVAC system. Aleyc. [ hata, ac43v 8 feeg is A

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related equipment is operating and with no NVAC service.Calcual ,

f, 2.

,' MAC for this area has been identiffed as critical concern No.

11-5(1979).

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,/ conditions M Ifa*f $* 3e jThe equipnent Ifsted requires environmental tem y psf 4 4 g

,. 3. During normal operation. heat loads are:

,' "I '4*r mas,

/ 1st Floor 81.200 Stu/hr.

4

,/ 2nd Floor 123.350 Stu/hr.

3rd Floor 121.400 Stu/hr. ,

4. r Capacity for cooling this area should be included when statng the chiller.

,- However. since alternative methods of boration are available, no fur ;

calculated cubicle temperatures, and the preferred toratfos sethod is identiflod. t

5. Requalification er replacement of the valve actanters are possf61e alternettses (

! to adding MVAC Coolers. Capacity fo

' when sizing the chillers, y,w,ec,r no cooling hb Jegtthese cubicles should be laclused

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NUS COAPORATION '@7~ INTERNAL CORRESPONDENCE l

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CD-SA-627 TO: J. A. Signorelli g_blh , DATE: May 11, 1981

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MOM: D. A. Prelewic: COPES: P. D. Arrowsmith W. J. Gallagher

SUBJECT:

NUS Responses to S. M. Mirsky QUADREX STP Review F. E. Muellner J. L. Renchan H. Renner f

, J. N. Sorensen i

I In response to our telephone conversations and your telecopied j QUADREX Design Review Comments of May 8,1981, we have prepared j i; the following NUS responses to those design review comments a which are applicable to NUS:

l a) Analyses have been performed by B&R to support the implied !

- i assumption that equipment will respond to saturation tem-perature instead of superheat temperature because of con-densation heat transfer. However, it is noted that not all j equipment has been checked. Since this will be done, and !

no problen is currently expected because of the large mar . !

gin between LOCA Tsat and MSLB Tsat, NRC need not be ad- %

vised of a potential problem at this time. l I

b) A technically correct but conservative analysis was per- -

formed by NUS for the mass and energy release due to a

, main steam line break. The analysis predicted highly

. . t superheated steam conditions in the containment. At the

. , time of the audit, the analysis had been superceded by a

,i ..y Westinghouse calculation which also predicted a super- !

.t- .,

heated steam environment due to a main steam line break. I i

- . , At the time of the audit, valid mass and energy releaso j

, calculstiens were in place for both main feedwater line and main stes= line break in the IVC. In general, the analyses of breaks outside containment is a recent re-quirement. Many operating plants do not have such analy-ses in place.

e) The NUS annulus pressurization analysis was previously per-

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formed with the RELAP3 code which was and is acceptable to the NRC. A current reactor ar.nulus redesign ef fort, when j completed, will be used to provide new reactor annulus de-sign input for a revised analysis with the COMPARE code.

' Hewever, the previous annulus pressuritation analysis per-formed by NUS with RELAP3 was conservative and used a com-puter code and methods acceptable to the NRC.

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J. A. Signorelli CD-SA-627 May 11, 1981 Page two

. f) NUS is aware of the methods for handling doors, blowout panels and vents in environmental analyses and has per- *

, formed such analyses for other clients.

s j) Analyses for a split break short term mass and energy re-1easo of the main steam and main feed water lines, both insid.e containment and in the I.V.C., were performed by

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' NUS for B&R last year. These analyses were verified, done to CA Ipvel 1, and transmitted to B&R last year. .

l k) BER in.in the process of examining high energy line breaks

= - and th4ir environmental impact outside of containment and

is addressing this subject on as timely a basis as many j other power plants in the construction phase. t

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BROWN & ROOT, INC.

INTEROFFICE MEMORANDUM

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8 DATE; May 11, 1981 T0: J. L. Hawks FROM: E. A. Saltarelli

SUBJECT:

Quadrex Design Review N

Knox Broom and I discussed with Jerry Goldberg the potentially reportable items U resulting from the subject Design Review on May 8,1981. Mr. Goldberg had no

-- problem with our assessment of items 4.;.2.1 (a)/(b). However, he will report two other items as "potentially reportable" under 10CFR 50.55 (e); namely, veri-fication of computer codes in the nuclear analyses area, and verification of shielding codes. In his opinion, all shielding is safety-related. Broom and 1 O had no problem with his position on nuclear analyses since one cannot be sure

. that there is a problem until all the codes are verified. However, we did not agree with his position on shielding sodes. It was explcined to him that we

-. intended to verify shielding codes but we did not agree that all shielding is safety-related.

.. In a'ddition to the above, Mr. Goldberg did not agree with three other items. These are not considered "rer.ortable" but he does not agree with our assessment. It is n therefore necessary that the following items be pursued with HL&P for resolution:

~3 Item 4.4.2.1 (g)

Although cur design verification process meets the NRC require-ments, he wants to see a complete list of criteria which qualifics verifiers in each specific discipline. We need to discuss this since this approach has been resisted by the industry for years.

Item 4.5.5.1 (a)

There is a question whether the Standard Review Plan allows analysis in lieu of testing to determine operability of active components. I would like to review this one with you. There may be some confusion in llL&P's mind on qualification of com-ponents versus operability in a system when called upon to perform.

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-J. L. Hawks Quadrex Design Review '

May 11, 1981 Pagd 2 i

Item 4.5.2.1 (c)' - Secondary Effects of Pipe Break Mr. Goldberg does not agree to our response and believes secondary E effects from the pipe rupture event should be considered. We

!" made a generic statement. It probably necds some specific ex-a.ples to prove the point.

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INTDOFFICE EMOBNCLrt i 1 01 m . l f w- w 8L l 3 RTE:

1981 10: E. A. Saltarellt l M311 FXpt: F. E. Nellner t u

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$TP MLAP/Quadrex testmeerias Revise

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1. STP Quadrez tagineerine a rview of say c.1981

References:

2. R&P Letter of fisy 4.1981 3.

4.

84A Letter ST-4A-E-34718 ef Itty 8 1981BAA Le

5. &&A Letter ST-44-E-38544 ef Itsy 4.1981 enten The purpsse of tat: memorandas is to swassrire the tram 4 best acti 1981 to date relative to the STP KAP /Quedrex Ingtseerlag Bevia of Ilay S.

and to presont our pas 1 tion relattwe to me "Ibat Serices Generic F contatand in the report of the above revise (Refersace 1).

the trova & Root performed an taittal, expottted blrevfes h pre- of Reference 1 dsace with Asforence 2 aad adytSed Itousten Ltght1as met 8 poner as to "sost ser1ous* 1taas identifled ia Refarence Reference 3. All items sortI censtitute re- a reporta e les ta accordance with 10CTR50.55{e[. etch was ceasidered potest ty reportabletaceptfor4.4.2.1(a)/(b,. Brea 4 Rest j to Reference 3. reported see itoo 1a accordsecs vith 1 portable as described to teclosure In adtttime trama 4 toet has accelersted toplementaties en to progress dick. fte the east port. enre alren% to piece er more ;

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The conoster code assessmeet protrum d to uns 1sttletes l i

1. Ceasaster Proeripot.

Tes a result of fladtags from tram & Reetee-toterus) actit p ced **= ====t propres is Socseher 1900.

of the Quadrea rerter.

The tance $dentified wtth St activity. '

. tag, locause of the 1acreased ffort ts betas eccelerated, ne progree teclades tput rettee to d

Judge the e the qualificatfoe of the codes usedAusto-times fer apprepctate appitcatise of cemester t en SW and revin codes. Dis is a ph t se progree vtta tamedtate emphesis hetas placed e peltcited. d 7'

8. EM. Accelersted rovfes of portiment SW IreAC systes has wey wIth 185 and Westiaghowse coesaltias essisteace.

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3. c6asalttee Ptse legats Orts 1de Comtatanset. Ifferts are hetas accele asststnace nelas selktted free Westtagfensa and aus l

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June 2 1961 h- - --:-

gM.g131 An ALARA program has been established with , joint ML&P. RUS.

4. ALARA. Phase 1. Model Review, has been completed.

a I'ItR participation.

An Intarference Aeview program has been estab

5. Interference Review.

Tished as outlined in Aeference 5. Augmented internal review proce&tes are being implemented to reduce development of new interfereNes, and a .

multi-discipline interference review comalttee has been estabitshed to accelerate interference resolution.

A program is being accelerstod perticipe-111 and Access / Maintenance Review.

6. Drough augrented staf fing of extsting B&R 151 task force.

tion by HLar will be solictted.

Due to the potential licensing impact of the "Most Serious Generic Fin discussed in Reference 1 we have perforned an evaluation of these iten.s We have concluded that the detailed discussion reported ir. Enclosure 1.in Volume !! and III of Reference 1 do not support th presented in Voiwe I.

f Although a Quadren problemsity basis. h Tracking The m"

Systes has we believe these itses should not be pursued on a h19 prior prograss outlined above which are alrea# inpursuing place ff twill handle the "co reised by Quadrex in the normal evolution of the design process. i response to the 288 items on a high-priority basis interferes with the e

> being expended on the reestimate due in expended The effo.t Augustto l 1961 6 and the norsel o engineering work identified in the 1981 Enclosure schedule.

2 documents mer data (over 7.

significantly impacted the engineering schedule.

wert to data in connection with the 288 detailed her;;.'

Unless directed othenrise, we do not plan to pursue these matters fiert ether than in the progrees 41re4% estabitsbed.

I F. E.Ibe11ner

- svs Enclosures 1 and 2 A0106 File me.:

cc: C. L. Buck '

S. M. Dow J. L. Newks W. M. Rice 0509953 J. A. 51gnovelli n= " ,

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JELO5M 1 to ST-8R-HL-38718 r

eDERIC F12!aE 3.1(a) r-In reviewing tudrea Generic Finding 3.1(s). it has been noted that the response can be broken bestes11y lato five concerns. They are:

1. Concern relative to effect of integretten of System dest p .

2. Concern that design review process could easily overleot optpment pfysical arrangtrat and separetten requirements.

3. The discip11pe structure is tco tightly organtaed en a purely discipline basis. ,

4. The abiltty to achieve internal consistency he to high personnel tursover.

5. The lack of a single failure criteria doceent.

I The following information is effered in response to these five areas, the Sadrom endit. Omdrax did not review the efforts of theSadras so f 1. During&

tromm Root Systm Design Assarance Groep.

l seats; therefore, they did not consider the existence It should be noted that the basic ressentag in foretag the System Design Assurance Gmp some 18 months ego ens to provide an overv .

functten within ik Proom & Root deste process for ensuring the effet-ttveness of our systna integration process. The System Desty Assurane Group hea completed ita f1rst phase of thts activity and has tdantifle to the tarious disciplines additional itms to be incorporated fate me, desty.

The scritags of this group 1s doceented ta preJact procesares and they have proven to be effective la providtag the evere11 tot 1 required.

2. Similarly. it ses recognised about tuo years age' foreves and other plysical concerns The physical Destyrelattve assuranceto seisment troup as tastet were beteg adequately addressed. r fbmed comprised This of tuo major group hascomponents, been evalenties pethesical modnitas major plant and computettaed modeling.

areas for laterference of basic Econs camponents.

& heet does teacur and uteaccesstklitty the for a tenance assi te-service taspectice. fact lie are currently that la the the concentratten of process en the physical laterference aspect.

of 1screestag the attention of this group to estatenance.113. EAA and other steller activities. Also. a sortes of sys such as fires, missiles, pipe break. etc.

4509954 1

$'5 GeEericFinding3.1(a)

/ Pe~9e a Vl I

f 3. Quadres expressed a concern ever the fact that the technical discipitees were organized very tightly and they infer that Itthere uns est a routtee is very follow-through with the discip1tne input / output interface.

difficult to ascertain from Theany of the statament one specific specificit:ere Guadron Sandrenresponses the bests clates for that this assessment.

the Mechanical Group mas not in permitted th f ties te to review IK logic 4

e There is aignifIcant avidonce d1agrams 1s incorrect.

l-. the Doceent Control Center showing review and coments fra the i

' Mechanical Group to the IK Group concerning system logics.

I

d. Quadrex expressed a concern relative to the consistency in the of various doc eents due to the high Brownturnover

& hoot hadofpreviously personnel, particularl and such activity i

t-ares of plant separation.

4 a need and in fact, has issued a separation Criteria TRD.

of the safety systen hasards analysts is providing the very criteria

! for use by our engineers that Quadron appeared to critic 13e Brom &

Root for lacking.

9msnt l

5. Quadrex expressed a concern that there ins not in a contro11ec da:

l a multi-discipifnery interpretation of single failure criterta. This is a correct statewnt; however, as the design demonstrates, we teve .

adequately addressed single fattere critaria to reviseandall have through the Syst le fatture criteria I

Design Assurance Group, provided a single activtdiscipline incipitees.

has been oppited consistently by all the Project In summary, we concur with some of the Quadren findtags; bouever.

been previously identtfted and actions talten withts the Project to assureI that the STp design was totally adegate.

specific reference given to this generic concern by Saadron wa l shich uns a question regarding how the IfvAC systas design tacorp fativre into its separation criteria. The Quadren response er assessme stated that me had no written criteria for physical separetten to protec .'

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egainst postulated It appears fires, high that Omdrez energy did met discover thatlines, and a f

fato awere we controlled doc einent.

in fact the process of tasving the triteria deceent as part o

d .

eve recent system hLsards analysis and in fact, n Projectdoceent.

0509955

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GEERIC FINDIE 3.1(b) e S30fM & ROOT R0flDi b

OF ENGIEttinG~ DATA .

3 Genericfinding3.1(b)notesthefollowing:

" Input data to a technical group does not appear to be consistently

1. revtwed h that group for its reasonableness prior to ese...'.

reviewed and verified as

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2. " Calculations containing errors are bei Id be encountered.'

correct with a higher frequency than th y

3. *BAR review of vendor submitted regorts is not consistent.' $

As Quadrez pointed out, this generic concern cany,the input be broken into three item j First, concern relative to technical groups act adequately revievi data from other groups for its reasonableness prioritted to use. Secerrors (are calentations containt encountered; and third, our review of vendor ,

frequency than should reports is not consistent. y

1. Quadron appears to have aQuadron different concept appears to think thaton enehow Engineering 3 ac era performed than does Brown & Root. _

discipline should somehow formally be responsible for the input ;

it by other disciplines.that if information transmitted from one group to an -

totally out of line with what that engineer isMomever, accustomed the to. he will 5 discuss his concerns with the group transmitting the data. 3 responsibility for the accuracy and reasonableness of such data sustI

_a si lie with the originating group. referenced as to how heat loads were assumed in the NVAC area er bow isqwt from relative i t Westinghouse tas utilised are totally defensa*>1e. a

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prior to being esed. The approach being used b Brow tagineers. 3

2. This concern nd toallhes that subsequent a higher fregaencyto revier and verifica G

contain errors with thea tulations were f In reviewing the specific review gues- 3 should have been in itencountered.

tes tapossible to ascertain the degree of signi- a f.fons, ence a drez placed with the wording of this finding. Tnts j ficance itan isthat indicative of the difficulty me le. find in responding to genereltz 2

a review of the }4 dren firwitngs even in specific areas; for as:

r traestions referenced mere provides the fell 2

_I 1pestion C-18. ikedrex assessment epsotes gtha j isesstry standards en pepr.'

a concern of how effective we beve implemented the procchere 1

f 0509956 l

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Enclosare 1 8E Generic Finding 3.1(b)

Page 2 -

t g and state that there was evidence that a significant ember of However, af states had passed through the verification Irocess.

no specific reference to any calculation or calculation samber was given and no basis was given for the statement of "a sig-6 nificant tunber of wistakes or how the results compere with j expertence at another Architectural Egineers.

Question H-15. which is referenced. bestcally states that wedid not take into acco the Reactor Cavi ares. This was a potential reportable con-identified by grown & Root prior to the dition which had Quadrex audit, and was under evaluation. This in itseif is not an indication of significant errors in calculatieas.

51m11erly in (Nestion bl. a single concern relative to a large tamperature error ens identified; however in the Quadrez assessment.

11 stated that the occurrence of such an error is neither uncommonFurther. in their response, the nor a sign of 10 adequacy.

that calculations reviewed were well organized, as were the verifica-tirms. Again, this single concern does not provide the basis for a significant large runber as referenced ta thier generic finding.

Finally in referenced thestion W17,4 adren assessment indicated that there was either an error or an inconsistency with a calculation and that this condition needed to be evaluated; however, once again there was not specific reference to a significant sunber of mistakes as indicated by the generic finding.

3. Quadrex indicated that they felt that our review of eendor submittad reports was not consistent. They also indicated a concern that the interface we have with such major subcontractors, as EDS and Westing-house, reise anfty questicas regarding overal) technical adequsty of the interface with these suppliers. Brown & Root again is confused as te (badrex's concern in this ares, particularly relative to the EDS interface. in that in response to the questions on the EDS area. thedre reported on Page 4 74. "In seneral. EDS in containment design analysts appears to be tsehntcally a3 equate.* 'There were ao f1ndInos In in EDS l

scope that are expected to striously impact plant licensablitty,*

addition. on Page 4-75, the following ete appears. "In the EU5 scope.

there were no findings that pose a concern for the plant to generateWith these find reliable power.'

they have concluded that the interface between troe & tact and ID5Broe & Root int has been adequate.

that we are responsible for evaluettag technical adegacy of theinterfaces; In summary, we share bedren concerns internal analysis methods.in some isolated areas relative to a specific review of a vendor package however. ence again, we do not feel that the beck-ep information supports the degree in which bedrex empresses thf s concers.

4 0509957

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EEMERIC FINDING 3.1(c) -

PLANT OPERATING N00E5 AND ENVIROWNTAL CONDITIONS ANALYSIS GenericFinding3.1(c)notesthefollowing:

1. " Thorough and consistent treatment of various plant operating modes and envirornental conditions was not evident" and "no writ modes to be considered."

2. "Consideretion of degraded equipment not evident *,

3. " Design criteria do not adequately reflect recent developments.*

~

4. 'As'smed ' worst case' conditions may not properly bound the set of anticipated plant conditions." (Questions M-3 and b17).

l L

5.

"Asseptions regarding door and hatch posittoes seen unrealistic...' [

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6. " Failure to consider off-site power condition in a timely HVAC systems to safety related ((Nestion H-5)."

J j

7. "The absence of postulated Ifne cracts and breaks outside contairment

'Similarly,the iB= > is inadequate (Question M-3. M-5. bl. and b3).*inablity of Acl

_ conditions for these areas in a timely manner is also inadegate."

The following information is offered in response to these aress:

1. Operation regatronents are covered in 3D005. Enstneering Procedvre Design Assurance Reviews, and the operations se r

A to 500 002. %tline for ActiveNormal System Design Descriptions' Opere-emironmental conditions q tional Requirenents (9.2 and 9.3).

were covered in the system designs and are evident in Section 2. (De-I l =

sigu Requirements) and Section 3. (OperatingThere kdes and Design

__-- * -M of individual SD0's. Estimates were made for off.-normal and accident conditions based on experience with other similar auc l

M such as pipe breeks and loss of power.

2. Degraded equipment performance is incorporated into the plant de in the form of fouling factors and filter loading contributleg to 1.n-creased capaciV.

system pressure drop and degraded heat exc Consideration of other possitte the " single failure

design feature. equipment degradation is sched Design Assurance Program.

0509959 N

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Generic Finding 3 l(C) _ ,

page 2 d by the

3. The adequacy Descriptions ($D0s) and Technical of the grown 13731975Reference

& Root

) appear time frame; however.

to design process Documents (TRDs adequately reflect industry issues for the

" It is initial STP they do not adequately address time frame more is precisely whenrecent the developments... .

g noted that the 1973 1975 plant design occurred. d as on-going Assursnce Group.

More recent developments including TMI are bef ag addresse programs, both within the disciplines and byt case the Design 4.

Two cases are cited by 4adrtz as examples of eAere assmed seesC design conditions were not bounding. initia-these fled by wert a *f fnding* by Quadetx.

These are: these cases were spe tion of the 4adetz TheEngineering HVACReview.

design was reported in BAR letter ST-Ba-t-I W17. ECP design. This was identified as a potenttally f the problenreportable

? 38718 cf May 8.1981.

'j problem in accordance with 10CTR50.55(e) and a summary o

ens given in Enclosure (1) to the above letter. tion Tempers- ;

j A change has been scheduled inl tion theforECP the mest Technical Specifica l i

ture limits to incorporate updating of the ified. calcu a5atisfactory equipment perform severe plant and weather conditions.

under the slightly higher temperatures bis being items.

ver NLLP will be kept apprised of the status4A's of the a ove "assweettees This "most serious generic finding

by bedres i ti ' is totally en- that 3 J

5. regarding door and hatch positions seen unreal s cIn this example. the lc AC cal-a supported by the example cited (M-14).

Quadrta asses: ment reads: "S&R control room petssurizatio tutstion is adequate.' has been i as far back as 6.

Contrar;> to the Quadrsx implication, iets of off site poser considered pince the early stages of thetasProject dat ngThi d for nogending ,

pre-PSAR era. (14. The fact ]

as part of the normal designidered evaluation in the " mast and the neeb l that this WAC problem had been identified aM h.d.

- pointed out to 4 adren sectionbut apparently of the report.

On the other head.

was not cons [

serious generic finding

ion of Westion 85 3 ta Vol.11. Quadrsa actmoe. /

in the detailed discuss *4adess us informed by R&P that a specialition l

1 edged the following: tass is now vMerwaty to study the need for edd ,

HY AC systems."

0509959 1

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Encion=re 1 .

Generic Findfrg 3.1(c) h_

7. As Quadrez mes informed, the program for breet analysts outside of contatnner,t is bnderney. Results for pipe breaks outside of contain-r.

'* ment in the IVC are in finsi stages of cowletion. St u e rematntag high energy lines outside contatraent are stataal, tort en theseThese will fem the basis has been scheduled for 1981 implementation.

for the enviromental conditions evaluetton ny absclear Analysts.

, 0509960 l _. ._ .

Enclosum 1 8E GENERIC FINDING 3.1(d)

$METY RELATED V5. IION-SMETY RELATED DISTINCTIORS b

GenericFinding3.1(d) notes:

1. "It was observed on many occasions that B&R uses a very sharp distinc-tion between 5/R and non-5/R categorizations for both equiprent and calculations.

being subjected to design verification."

T. "It was frequently stated during the design review that enir WC reasonable, or even meet the intent of the regulations."

3. "There has been no planned effort to review new EC requirements (excluding TM1-2 concerns) to deterstne their impact on STP."

The following is offered in response to thwse areas:

1. All R&R design doceents as well as supplier doceents are reviewed and checked by 86R.

The sharp distinction cited deals with a projut pro-cedure for formal documentation of these reviews and the resolution ofThe exist any carewnts generated during the reviews. In the design and docrent designations are adequate in this regard.of a nuclea maintained between 5/R and non-5/R systans from a licensing point of view.

R&R corcedes, however, that regardless of systs classification, computer codes should be verified as a matter of good engineering practice.

This action is being taken.

j 2.

The statement that. "It ins frequently stated during the design review that only NRC__requirerients must be met, whether or not those requirements ,

are accurate, reasonable, or even meet the R&R intent endeavors oftothe regulations" is a misrepresentation of the Brown & Root position. However, satisfy regulatory reqJirenents as a j mandatory In the final requirwent.the for technical understanding, or engineering udgment.The designer interprett the analysis, engineering judpent prevails. emphasis en requirements and ir.plenents these requirements by ign. plactSecondary those considered to have the most serious impact on the effects are considereo but these cannot beetse overriding to the exteet that the fundmental function of the system is compreised by a pos-i tulated event with a low probability of occurrence.

Brown & Root consistently reviews 1stC

3. This statment is not correct.

requirements Ifeensing level.

applicable to STP at both the discipitne levet and th i where appropriate, the toplamentation of such reg 4irements.

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0509961 9

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b 9C I GENERICTINDING3.1(e) l;,

FMEA AMD 51NELE FAllURE . CRITERION The Generic Finding 3.1(e) notes the following:

1. The supporting specific *nost serious finding" (4.3.2.1) to this teneric finding " suggests that S&R is not sufficiently experienced in the per-formance of Failure Ibde, and Effect Analysis that crosses discipline boundaries."

2. *ho guidelines exist on what typs of failures should be considered "There is no docmented'cvidence

) for various types of equipment. 'One concern that the single failure criterion has been satisfied." 1 is the varied ' interpretation by individual disciplines that can be 9 ren to ' direct and consequential failures' resulting fra a postulated event."

3.

"An HVAC/1&C single failure criterion violation has been noted (bestions R-6 and E-15)." -

The following is offered in response to these areas:

Wadrex has used

1. Brown & Root disagrees with this statment. Examples of B&R an isolated incident to ansee this conclusion.FMEA's crossing dis 4

Syst e F E A F5AR Table Ref.

7.3-12 Control toca Ventilation Isolation Actuation Containment Building Purge Isolation Fativre 7.3-13 D.C. Power Systems 8.3- 8 Auxiliary AC Power Syste 4.3- 9 l j >

8.3-13 120-Vac Vital Instroentation Power System Essential Cooling Water Systan

3. 2.1-2 Component Cooling Water System 9.2.2-3 Air-Operated Valves 9.3- 2 Choical and Volume Control Systm 9.3-12 Control Room & Elect. Aux. Su11 ding HVAC Syste 9.4- 5.1 Fuel Handling Building HVAC Systm 9.4- 5.2 Mechanical Aux. Su11 ding HVAC.5ystem l 9.4- 5.3 Turbine Generator lutiding WAC Systan 9.4- 5.4 Reactor Containment lutiding HVAC Syste ,

9.4- 5.5 Diesel Generator lutiding M1AC Systm e

9.4- 5.6 Miscellaneous 3stidings NYAC Systm 9.4- 5.7 Fire Protection Systan 9.5 2 Diesel Generators 9.5.5-2 Aux. Feeduster Systen 10.4- 3 Turbine typass System (fts) 10.4 4 Contrary to Quadrex statenents. the FNEA to ensure adegateapproach desite. has also been us af ter the FSAR period where appropriate I

0509962

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m 9j Genert finding 3.1(e)

- GD, Page 2 _ _

d Finally. updating of FailureThis Mode andwas discipline Effects estabitsbed Analysis les been assign to the System Design Assurance Group.

in late 1979 to ensure thet systans level integration lf, was in factTh presentontheProject.of perfoming FMEA s on the co present day FMEA practices.

2.

STP Procedure 50-002. Engineering Procedure C alty for Systan Design tions Appendix A. Section 9.3. requires that Section 4 considered in the design such as:

o Loss of offstte power.

{ o Loss of instrument air, i e Single failures.

j e Operator errors. etc." been Therefore, the SDD's specifically address istent all failures that h considered.

including the System Design Assurance Group, to ensure a cons j approach.

It is acknowledged that updating of System evolution. However, a s developed this Design Descriptions

- required in certain areas to reflect designwas recognize in intoOctober the ofRe-estirete 1980. Plan in the normal conduct of the destge.

1 l that a l This l Through the influence of the Design Assurance G is borne out in the results of the Phase I reviews following to date, 3.

In the alleged 'stngletofailure Dampers the t=e criterion redundant violation HEPA-charcoal

cited, filteethe High radiation in thehFuel rooves b conditions exist:

trains are held closed by air pressure. the demoors But1 ding actuates a three-way so'enoid valve. This action bot W

supply air pressure to the dampers and vents Tt the 1tne caustag becene blocked thus disabling the system wtth l

to open.

f '

) contention is not credible for the following reasons: des 198 Blockage of exhaust lines is precluded by the follosist W 'l a.

j features:

1. Exhaust lines to the damper actuators are lar becone ic4ged in an ashaust Ifne. it aevid be unable to paas I through surpfy ifnes.

j 0509961 10

j/,; . Enclosure 1 ,

[ GenericFinding3.1(e) i

se > .. _

2. Air supply is flitered to preclude introduction of foreign matter.

/' 3. Instnament air driers are installed to preclude foreign setter due to corrosion.

4. possibility of crimping precluded by a physical barrier around the exhaust lines.

b. If a non sechanistic blockage of the exhaust line were assmed, damper v111 still open since supply air is cut off and venting would be accomplished through normal system leakage.

c. Finally if a non-sechanistic failure of the system to operste were assmed, the stack radiation montter (albeit hon.1E) will earn the

eperator to take the necessary action (i.e.. manually secure system).

Based upon the above considerations. Brown & Root does not consider the pos-tulated accident credible and does not plan to modify the design. It should be pointed out however, that the System Design Reviews being conducted on 3 the plant systems do encompass a systematic review of non sechanistic l

failures to detemine the impact of the ability of the system to function when called upon to perf m .

I I.

u 0509964 i

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Enclosure 1 t- SE

/ .

SMRIC Fielm 3.1(f) s F5AR COIMIMNT TRACKim i

This Generic Finding 3.1(f) notes the following:

1. 'There ens no doceented evidence for assuring that fadtvidual F5AR comitments for sys'es equipment er calculations mere being sys-f tematica11y imp 1mer.ted into the design."

2. "There is a potential for a lack of awareness of individual F5AR camattments.by STP site personnel. This could represent a significant problem for field initiated design changes."

3. *0ne group conspicuous by its absence during this design review program uns Licensing.*

4. "A corststent and doceented g&R posttten regarding code and standards interpretations uns not evident.* *These interpretations are lef t to individuals or to vendor suppiters. Tne AM code interpretation eres appears to be particularly weak (see Question N-30)."

In response to the above:

h I 1. Required modifications to the F3AR have been identified eart1e the .the Design Assurance Review; (see 50005. Sec. 3.1.3.c and 3.2.3.F In addition. Project procedures require identifyingAlso, all changes the Vendorthat affect the F5AR on the Design Change notice form.

Control Program performs a complete FSAR review for safety class specifications and FSAR commitments are identified and

2. The statements ande by bedren conceretng B&R's site activities As a were, ande without the benefit of a BAR Site Engineerlag revias.STP Site result it is not clear how this concluston as reached.

Engineering personnel are an extension of the Home Office EngineeringA11 fie organisation working through the same management. design cha the Name Office.

3. @adron did not review the activities of g&R's Licensing Licensing and the discTplines which is clessly centrolled. j l

4. The AM code problems identified by @adron are entgue to specific components and will be addressed on an individual test l ASPE. hence, we assee that @adrea's generic tencerns relative te' codes and standards is unfounded.

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e Enclosure 1 $4 GENERICFim1NG3.1(g) g i PLANT DE51GN BA515 Generic Finding 3.1(g) notes the fo11 ewing:

1. *There was very little evidence of a well-thought-out and consistent basis for design."..."A neber of &ey front-end criteria doceents are missing for STP."

2. "No doceent mists that identifies the interface design information required by each discipline from the other technical discipline."

3. '8&R indicated that WNES has reviewed portions of the intial STP design, but the quality and completeness of their review is uncertain.*...

"The interface between B4R. WNES, and NL&P needs to be improved.*

4. *ED5 indicated that S&R drawing changes are not reviewed on a routine basis.*

h- 5. "In neerous instances. WNES design bases for the nuclear island por*

tion have been directly carried over to the balance-of-plant design without confirming their appropriateness for this application.' I

5. "In other instances, design detafis have been obtainl '

7. *B&R has not adopted a consistent requirement for design margin to achieved by each discipline. engineers aske the determination of the m! ,

design (see Questions C-12 and N.8)."

In response to the above:

1. The need for strengthening B&R's front end criteria doc in this area are in the process of being rectified.

on p. 3-9. ".... a neber of these doceents have either been recently issw! or are currently undergoing review prior to initial issue....*.

The absence of selected front end criteria doceentation does not pre-c19de design."

the existence of *a well-thought-out and consistent matter to be purely subjective, d

' 2. As stated previously. the handling of design interface information is the responsibility of the B&R Systems Engineering Group and the use of preliminary information is for the most part he to be phased out during the upcoming design freeze of the individual plant systems.

h l

0509966 13 l .

Enclosure 1 bnericFinding3.1(g)

Page 2 95 -

i

3. Westinghouse received Frtue all S&R these piping drawings,composite they prepareddrawings P5DFTE for Westinghous lis55 systes during 1977-78.

- modes of 18555 systems. They also issued Westingh In addition, the Westinghouse design sanuals are used struction.

" regularly by SAR durleg the design process. Westinghouse has alsoDoc reviewed the logic diagrams for stS55 systas.

review eatsts in the Project We do. files. We however, consider agree bedrez's comments in ;

that the current this ares to be unjustified.B&R. Westinghouse and ML&P interface ag we have had discussions with NL&P in this regard.

' 4. based Theonresults of 84R's review of the EDS wrk was addres Quadrez's comments. seems adequate.

5. t&R did evaluate the application of Westinghouse criteria throug the design of the STP systas.

I systes and which have interface criteria Other plant systes were specified designed to by Westinghouse w designed to meet those criteria.

meet the presumed worst case operating critaria. e.g.. plant water

' l treatment systas.

p 6.

S&R encourages the design engineers to factar previous experience into their designs. The Quadres conclusion that "... design details have been ettained fromisother pWR unfounded. giants Experience andand first- use without con applicability of the STP plant.... hand knowledge of the appitcable ast i

7. We have difficulty interpreting Quadrea's remarks concerning des l I

margins because the verlows design basis codesi and standards We presme that @sdrex is referring to the additions) margins i

margin.

placed upon equipment and systes during the preliminary stag These will be verified during the design freeze process and agai syste pre-ops. We acknowledge Quadrea's connent concerning o ponie to Question C-12. "...some A/E's do E consider this t =

steiler to the stanner in which Brown *...a & Root did." We ac nowledge quick assuement of Guadrex's findings relative to Question M-8.

the adequacy of margins in the MVAC syste design is not possib 8.. Brown & Root has 20 volmes of Design Mar.uals dich l standard helpedbookshelf.

to esse some of the problems resulting from the high pers turnover emperienced by 84R during the late Ig70 SAA jobs.

0509967 14

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- GEMERIC f!NDING 3.1(h) l EQUIMENT RELIAg!LITY REQUIRDENTS l - .

Generic Finding 3.1(h) notes

1. " Specific relfability(requirments, such as for the ESF seque not wn established seeQuestionsE-7andE-4)

2. *1f the ESF sequencer reliability should turn out to be incompatible with the emainder of the ESF equipment, then S&R's dependence upon meeting only the single failure criterfun would be unsatisfactory from a systems vieupoint

3. "The absence of specific reliability requirments in both sechanical and electrical equipment specifications..... casts doubt on the rigor of the safety-related evaluation process."

4. 'Throughout the design review, specifications to constrain spurious operation were absent.' ,

The following is offered in response to these areas:

1. Reliability requirments have ten specifically addressed in the ESF load sequencer spec. ES-071. Section 3.4. Re11 4 per IEEE 5td. 352.

l the vendor is rewired to

2. Regarding the possibility of incompatability,Section 2 of the above conform to the codes and standards Itsted inBAR feels that these req specification.

ensure compatability with the ESF equipment supplied by imES.

the design satisfies single failure criterion. Should fatture of one sequencer occur, two other safety class trains would be available.

3. 84R does not concur with Quadren's generalization of an " absence specific reliability requirements in... specifications." The rewirme i

imposed by the codes and standards cited in ourofspecifications Evaivation our judpnent, i sufficient to ensure adequate reliability.d tandards l wendor doceents reflecting the (aplementation of the require s is reviewed ty the responsible engineer who at that time en adequacy of the design.dology for approving vendor drawings and doce

4. Although the coment regarding " spurious operation" is generel, errS response specifically addresses the sequencer.

l the sequencer is prevented by a matria recognition requirement o of 4 si nals for undervoltage recognition modes !! er !!!),)or 4 out l

of 4 si nel recognitions for safety inject on (mode I er III . Further

' details can be found in the sequencer specification in tie sectio describing mode of operations. A review of the Safety twelue-l i

' cons 11ered as early as the PSAA stage. tion Report and the ap avfdoet.

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9 t.- GENERICFIIWING3.1(1) h NUCLEAR-RELATIO ANALYSIS

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I Generic Finding 3.1(1) notes the follering: the ing 1.

"The chosen analysts methods eemonstrate a sharp i parados between

/ more conventional engineering work and the entpely nuclear eng neer i lines,

' work required for portions of the $Tp design." "In certain disc p such as CivilHowever,/ Structural for theand nuclear Electrical, technically aspects of the project. adequate method have been chosen.

Brown & Root has been auchinsufficient In anny instances. less adegatta in its cho was observed in these calculations. work has been accomplished for th curement, and construction."

ided

2. "The amount of nuclear-related analysts that d is subcontracted c is higher than a typical Review A/Es practice. The technic of these ambteatracted NUS does not appear to be adequate. analyses does isot appear t -

j The following is offered in response to these areas:

1. Changes to correct post diff tev1 ties in the lheleer Analysts troup were implemented in 1960, plans to complete outstanding wort areResponses t evident in the Project schedules.

be addressed on a case bases. 11ty and

2. The werk done by EDS and 1815 has been shown h to be of btgh gas adequately coordfrated and interfaced with affected respect to this review.

i as A

0509969 16 h

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Generic Finding 3.1(j) notes the following:

<- 1. "The SAR design verification process permits the use of pre 11 misery data up to the point of STP fuel loading.'

2. "There are no doceented standards regarding Typically. the sinimum the Discipline Project apalifications required for a design veriffer. Engineer selects the design verifier from withi his basis for selection is not documentad."

The following is offered in response to these areas: ,

1. We do not see how this finding can be consistent with Quadrex's assess-

! ment of 54R's respome to Question C-15 which is referenced as a hesis '

1.e..

Brown & Root's design verification procedure for the finding;dequate appeared to be a or above industry standards on papar; homever.

) we (Quadrax) were unable to evaluate the effectiveness of 151s prue6r e."

2. Quadrex acknowledges in the text of the review that this approach does not violate IWtc requirements.

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ENCLOSURE 1 e *bA he, ,. Qr GENERIC FINDING 3.1(a) in reviewing Quadrex Generic Finding 3.i(aj. it has been noted that the response can be broken basically into five concerns. They are:

1. Concern relative to effect of integration of system design.

2. Concern that design review process could easily overlook equipment physical arrangenent and separation requirenents.

? 3. The discipline structure is too tightly organized on a purely discipline basis.

4. The ability to achieve internal consistency due to high personnel turnover.

5. The lack of a single failure criteria docunent.

The following information is offered in response to these five areas.

1. During the Quadrex audit. Quadrex did not review the efforts of the Brown & Root Systen Design Assurance Group. Quadres verbally commented k that the effects of this group had not yet been evident in design docu-ments; therefore, they did not consider the eAlstence of this group.

.tg It should be noted that the basic reasoning in forming the Systen Design Assurance Group some 18 months ago was to provide an overview function within the Brown & Root design process for ensuring the effec-tiveness of our system integration process. The Systen Design Assurance Group has completed its first phase of this activity and has identified j to the various disciplines aJdittor.a1 itens to be incorporated into the 9 design. The workings of this group is docr.ented in Project Procedures j

a and they have proven to be effective in providing the overall integration required.

2. Similarly. it was recognized about two years ago that plant arrangenents needed to be reviewed and systematically evaluated to assure that inter-ferences and other physical concerns relative to equipnent layout were being adequately addressed. The Physical Design Assurance Group was formed cortprised of two major components, physical modeling and corputertred modeling. This group has been evaluating the major plant areas for interference of basic components, and accessibilly for main-tenance and in. service inspection. Brown & Root does concur with the fact that the concentration of this group has been, to date, primarley on the physical interference aspect. We are currently in the process of increasing the attention of this group to maintenance.151'. ALARA.

and other simi.ar activities. Also, a series of systens hazards review-drawings have been prepared dich evaluate all physical areas for factors such as fires, missiles, pipe break, etc.

j , 0509973 1

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Gener'c Finding 3.1(a)

Page 2

3. Quadres expressed a concern c,ver the fact that the technical i discipilnes were organized very tightly and they infer that there was It isnot verya rout ne follow-through with the discipline input / output interface.

difficult to ascertain from The anyoneof specific the specific Quadres statement responses the where Quadren basis claims for that this assessment.

the Mechanical There is Group was not permitted to in review 1&C logic significant evidence in the files diagrams is incorrect.the Doceent Control Center showing review and coments from Mechanical Group to the 1&C Group concerning system logics.

4. Quadrex expressed a concern relative to the constssency of various doceents due to the high turnover of personnel, particularly in thegrown &

The activity area of plant separation.

a need and in fact, has issued a separation Criteria TRD.

b of the safety system hazards analysis is providing the very criteria for use by our engineers that Quadrex appeared to criticize Brown &

Root for lacking.

5. Quadrex expressed a concern that there was not inThis a cont 311ed document

- a multi-disciplinary interpretation of single failure cr.teria.

is a correct statement; however, as the design demonstrates, we have adequately addressed single failure criteria and have through the System Design Assurance Group, provided a single activity to r i

s

' has been appifed consistently by all the Project disciplines.

In sumary, we concur with some of the Quadrex findings; however, all have been previously identified and actions taken within the Project to assureIt shoul

. that the STP design was totally adequate.

specific reference given to this generic concern byi Quadren l was Ques which was a question regarding Thehow theresponse Quadrex NVACorsysten assessmentdesign incorporates s ng failure into its separation criteria.

stated that we had no written criterla for physical separation to protect against postulated fires, high energy lines, and also that the fire hazard analysis performed tyI'. a contractor appears directly that Quadrez did notfor ML&P discover that had not been cenv into awere we controlled in factdoc e inent.

the process of issuing the criteria document as part of our recent tystem hazards analysis and in fact, negoti l

Projectdocument'.

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GENERIC Flh3thG 3.1(b)

SROWN & ROOT REylEW OF ENGINEERING DATA '

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GenerteFinding3.1(b)notesthefollowing:

1. " Input data to a technical group does not appear to be consistently reviewed by that group for its reasonableness prior to use...".

2. " Calculations containing errors are being reviewed and verified as correct with a higher frequency than should be encountered."

3. "B&R review of vendor ssbmitted reports is .not consistent."

As Quadrex pointed out, this generic concern can be broken into three itens.

First, concern relative to technical groups not adequately reviewing input Secondly,the data from other groups for its reasonableness prior to use.

calculations containing errors are being reviewed and vert reports is not consistent.

1. Quadrex appears to have a different concept Quadrea on to 4ppears how thi.*Engineering that one activittes are performed than does Brown & Root.

discipline should sonehow formally be responsible for the input given to it by other disciplines. .

that if information transmitted from one group to another appears to be

~

totally out of line with what that engineer is accustomed to,the However, he will discuss his concerns with the group transmitting the data.

responsibility for the accuracyInand reasonableness reviewing of such data must the specific questions lie with the originating group.

referenced relative to this finding it is very difficult to tra as to how heat loads were assmed in the HVAC area or how input from a

< Westinghouse was uttltzed are totally defensable, and do The approach being ustd by Brown & Root is not I

prior to being used. inconsistent with good engineering practice exercised by other A Engineers.

J

2. This concern alleges that sebsequent to review and vertffcation, cal.

culations were found to contain errors with In reviewing a higherreview the specific frequency ques- than f

M should have ueen encountered.tions, orce again itThis was lepossible to ascertai

( ficance that Quadren placed with the worting of this finding.ita Quadren findings even in specific arees; for example, a restew of the four questions referenced here provides the following:

Question C-16. Quadrex assessment quotes that '8rown & Root's design vertf tcation procedure appears to be adequate or above industry standards on paper." On the ott.erhand, they empress j a con:ern of how effective we have taplemented the procedure j

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Inclosure 1 105 h etc Finding 3.1(b) page 2 I

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and state that there was evidence that a significant number However, of I

~, mistakes had passed through the verification process.

no specific referer.ce to any calculation or calculation neber was given and no basis was given for the state 9ent of "a sig-af ficant neber of mistakes or how the results compare with

, , expertence at another Architectural Engineers.

1 Question H-15, which is referenced, basically states that wed This was a potential reportable con- ]

r the Reactor Cavity area.

dition which had been identified by Brown This & Root prior to the j in itself, is i

!* Quadrex audit, and was under evaluation.not an indication of sign 51stlarly in Question N-1, a single concern relative to a large 1 i

temperature error was identified; however, in the Quad en assessment, ,

it stated that the occurrence oftheir Further, in such an error response, theyis stated neither urcormn I nor a sign of inadequacy.that calculations reviewed were well organized, as wer tions. Again, this single concern does not provide the basis for a significant large neber as referenced in thier generic finding.

Finally, in referenced Question N-17, badren assessment indicated that I there was either an error or an inconsistency with a calculation and 1

that this condition needed to be evaluated; however, once again there

.' was not specific reference to a significant numoer of mistakes as indicated by the generic finding.

j ,

3. Quadrex indicated that they Theyfelt alsothat our review indicated a concern of that vendor the submitted reports was not centistent.

interface we have with such major subcontractors, as EDS and Westing-house, raise marty questionsBrown regarding

& Root overall technicalasadequacy again is confused to of th-interface with these suppliers.

8 Quadrex's concern in this area, particularly relative to the EDS i' I reported on Paga 4-74, "In general, EDS in contatra

{ appears to be technically adequate." "There were no findtrgs In in EDS scope that are expected to seriously tapact plant licensability."

addition, on Page 4-75, the following quote appears, "In the EDS scope,

' there were no findings that pose a conc 2rn for the plant to gen reliable power."

I

' they have concluced that the interface between gro.n & Racc has been adequate.

- that we are responsible for evaluating technical adequa In swmary, we share Quadres conceans internal analysts methods.

in tre isolated areas relative to a specific review of a ve*r pe;kage; hcwever, once again, we do not feel that the back up infomatice supports the degree in which Quadrea empresses this concern, i 0509974 .

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- GENERIC FINDING 3.1(c)

PLANT OPERATING MODES AND _

ENVIRO

ENTAL CONDIT1OMCANALYS15 4

Generte Finding 3.1(c) notes the following:

1. " Thorough and consistent treatment of varfous plant operating modes

- and enviromental conditions was not evident" and "no written s

sodes to be considered

2. " Consideration of degraded equipment not evident *,

3. " Design criteria do not adequately reflect recent developments.'

4. 'Assmed ' worst case' conditions may not properly bound the set of anticipated plant conditions." (QuestionsH-3andM-17).

5.

' Assumptions regarding door and hatch positions seen unrealistic...'

6. " Failure to consider off-site power condition in a timely man HVAC systens to safety related (Question H-5).

7. "The absence of postulated line cracks and breaks outside "Similarly, the containment y

. is inadequate (Question M-3. M-5, M 1, and M-3)." inability of N

, conditions for these areas in a timely manner is also inadequate."

The following information is offered in response to these areas:

1. Operation requirements are covered in 50005. Engineering Procedure for Design Assurance Reviews, ard the operations section of the respecti System Design Descriptions; Active System Design Descriptions" Opera-A to 500 002. ' Outline for Normal envircreental coMitions tional covered Retuirements (De-in the(9.2 and 9.3).

l were system designs and are evident in Section 2.

sign Requi-ements) and Section 3. (0perating Modes and Design feat l of individual 500's. Estimates were made for off-normalThere and accident conditions based on experience with other stellar accitar such as pipe breaks and loss of power.

Degraded etuipment performance is tecorporated into t*ie elaat destga t to in-2.

l in the form of fouling factors and filter loading contr%t ng creased capac ity.

systen pressure drop andother degraded possfale heat enchang Consideration of the " single failure

design feature.

equipnent degradation fs scheduled for review during Phase 11 of tne Design Assurance Program.

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Page 2

3. The adequacy of the Brown & Root design process is acknowledged by the ,

Quadrex staterent. " Design1973-1975 criteria provided in issued Systers Cesi '

adequately reflect industry issues for the It is they do not adequately address more recent developments...". time frame is precise noted that the 1973-1975 plant design occurred.

More recent developments including TMI are being addressed as on-going programs. both within the disciplines and by the Ossign Assurance Group.

4. Two cases are cited by Quadrex as examples of where assmed worst caseContrary to th design conditions were not bounding.

these were a " finding" by Quadrez, these cases were spec

) tion of the Quadrex Engineering Review.The HVAC design was reported in 81R letter ST-BR M 17. ECP design.

38718 of May 8.1981.

This was identified as a potentially reportable problem in accordance with 10CFR50.55(e) and a surriary of the problem was given in Enclosure (1) to the above letter.

A change has been scheduled in the ECP Technical Specification Tampera-ture limits to incorporate updating of the calculation for the mostSatisfactory equipent severe plant and weather conditions.

under the slightly higher temperatures is being verifiad.

HL&p will be kept apprised of the status of the above iten .

5.

This "most serious generic finding" by Quadres that R&R's "asseptions regarding door and hatch positions seers unrealistic

is totally un-In this essmple, th I supported by the exwple cited (H 14). !

Quadres assesseent reads: '8&R control room pressurtration HVAC cal. !

[ culation is adequate."

6. f.ontrary to the Quadren lep1(cation. loss of off site power has twen i considered since the early stages of the Project dating as far back as This requirement is pe todically reviewed and updated ,

pre PSAR era. l' as part of the normal design evaluation and the need for upgradirq has The fact been identified in such instances as Special Problem #16. i that this HVAC problem had been identified ard is being worked on was /

pointed out to Quadren but apparently was ** t* not e e t5considered ee h4 N . in the "most I serio.s ge tai: fie.dirg" sectf 3n of the re,crt. !!. Quadren acknow. ,

in the detailed discussion of Question H-8 in Vol."Quadren was informed by HL '

ledged the following: task is now underway to study the need for additional safety related HVAC systects." \

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Enclosure 1 GenericFinding3.1(c) ftge 3 I 7. As Quadren was informed, the program for break analysts outside contalment is underway. Since renatning ment in the IVC are in final stages of completion.

r 96 sp emen ti n ese 1 Nrnthebasis b n he u for the enviroment41 conditions evaluation by helear Analysts.

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Encloswee 1 l GENERIC FIN 0!NG 3.1(d)

SAFETY RELATED VS. 18hN-5AFET) RELATED DISTINCTIONS GenericFinding3.1(d) notes:

1. "it was observed on many occasions that B&R uses a very sharp distinc.

tion between 5/R and ron-5/R categortrations for both equipen calculations.

being subjected to design verification."

~

2. "It was frequently stated during the design review that o reasonable, or even meet the intent of the regulations.'

3. "There has been na planned effort to review new NRC requirerents (excluding 1MI-2 concerns) to determine their lepact on STP.*

The following is offeied in response to these areas:

~

1. All B&R design doceents as well as supplier doceents are reviewed and The sharp distinction cited deals with a project pro-i f checked by B&R.

i cedure for formal documentation of these reviews and the resolution ofT g arty coments generated during the reviews. In the design and doceent designations are adequate in this regard.

l } of a nuclear power plant. it is mandatory that a sharp distinction be 4 maintained between 5/R and non-5/R systens from a Itcensing point of

, view.

SLR concedes, however, that regardless of systen classification,

,, computer codes should be vertfled as a matter of good engineering This action is being taken. v

] The statement that "It was frequently stated during the design re iew

2. that &MRC requirrents must be met, whether or not those requirem are accurate, reasonable, or even meet the intent

$1A endeavors to of the regulations a misrepresentation of the Brown & Root position. However.

~

Satisfy regulatory requirements as In LPea fina?

mandatory require for technic.) understanding, or engineering judgment.The designer interprets tse t analysis, engineering judgment prevails.

. . j*

requirsments and implements these requireneetsSeccade*y by placinq monasts those considered to have the most serious impact on the eestgi.

effects are considered but these cannot become overrt.ing to the ente that the fundaments) function of the system 15 compromised by a tys-tulated event with a low probability of occurrence.

a l acet teeststeatle reviews 98:

3. Dig statere.: 15 rot correct. l'ow .s.

req.irrents apple:431e to STP 4 c s**In at uto swthe addition Ji.eit.Special ire ; i Projects Group w licensing level.

j wh ere ap;ropriate, the taptemeetattea of suc% re@tre** eats.

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050997' N ;

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l GENERIC FINDING 3.1(e)

FMEA AND SINGLE FAILURE CRITERION The Generic Finding 3.1(e) notes the following:

1.

The supporting specific 'most serious finding" (4.3.2.1) to this generic finding " suggests that B&R is not sufficiently experienced in the per.

formance of Failure Modes and Effect Analysis that crosses discipline boundaries.*

2. "No guidelines exist on what "There typesisofnofailures should be considered doceented evidence for various types of equf p ent." 'One concern that the single failure criterion has been satisfied.'

is the varied interpretation by individual disciplines that can be given to ' direct and consequential failures' resulting from a postulated event."

I 3.

'An HVAC/l&C single failure criterion violation has been noted (Questions R-6 and E-15)

The folicwing is of fered in response to these areas:

Quadrex has used

1. Brown & Root disagrees with this statement. Examples of B&R an isolated incident to assee this conclusion.

FMEA's crossing discipline boundaries are as follows:

j Syst m FMEA FSAR Table Ref.

7.3-12 Control Room Ventilation Isolation Actuation Cor.taiment Building Purge Isolation Failure 7.3 13 D.C. Power Systes 8.3 8 Auxiliary AC Power System 8.3 9 120-Vac Vital instreentation Power System 8.3 13 Essential Cooling Vater System 8.2.1-2 Component Cooling Water System 9.2.2-3 Air 0perated Yalves 9.3 2 Chemical and Volme Control Systert 9.3 12 Control Room & Elect. Aux. Building HVAC Systen 9.4- 5.1 Fuel Handling Building HVAC System 9.4- 5.2 Mechanical Aux. Building HVAC System 9.4- 5.3 Turbine Generator Building HVAC System 9.4- 5.4 Reactor Contalment Building HVAC System l 9.4 5.5 Diesel enerator Bal1 Jing hiAC Syste I

9.4 5.6 Miscellaecous Buildings HVAC System i

9.45.7 Fire Protection System l

9.5 2 Diesel Generators 9.5.5 2 Aus. Feed ater Systen 10.4 3 Turbine Bypass System (TBS) 10.4 4

(

Contrary to 4afrei statements, the FPIAadequate to ensu'e approach design. has also beec used af ter the F5AR period wPere appropriate 0509979

--- .- _ - - . _ _ _ e_ _ __ __ _ _ _ ___ _ _ _ _ _ __ _ _ _ _ _

1OL M

GenericFinding3.1(e)

Page 2 i has been assigned Finally, updating of Failure Mode and Effects in factAnalysisThis discipline was e to the System Design Assuraxe Group.

in late 1979 to ensure that syster.s level integration wasThe group has

present on the Project. d res reflecting of performing FMEA's on the components of the systen Design Descrip.

present day FMEA practices.

f I

2.

STP Procedure 50-002, Engineering llProcedure casualty events for SystemSection 4.3, ' C tions Appendix A, Section 9.3, requires thatEvents and Re considered in the destga such as:

o Loss of offsite powe*.

I o Loss of instrant air.

o Single failures.

o Operator errors, etc." h t have been i lines Therefore, the 500's specificallya consistent address all failures t aThe considered.

including the Systee Design Assurance Group, to ensure approach. i tions is

,! However, this It is acknowledged that updating evolutfon. of System Design Descr pie d

required was recognizedin certain well before the areas Quadrex rev to reflect design. designThis work has

?

l in October of 1980.into the Re 82 estimate feels that a Plan in the norm Through the influence of the Design to Assurance date. Group,ll be achieved. Th consistent interpretation of failure ited, the following analysis wiis borne 3.

In the allegedDa " single pers tofailure the two criterion Highredundant violation" radiation in theHEPA-charcoal Fuel c filter i both removes condittor.s exist:traf ns are held closed by lineair pressure.

causing the dampers i

Sullding actuates a three-way solenoidlinevalve. may This act on i supply air pressure to the danpers single failure. and vents theit.e Quadre This to open, s:

become blocked thus disabling llowingthe designsysten with aconte a.

Blochge of enhaust Ilnes is precluded by the fo features: i than large enoug* to 1,

Enhasst lines to the daeper actuators ble to pass are larger in s ze supply 11ees. Tnerefore, if foreign matter werebe th ovg% supply lines.

050996f)

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GenericFinding3.1(e)

Page 3 l t

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2. Air supply is filtered to preclude introduction of foreign matter.

3. Instrument air driers are installed to preclude foreign matter I due to corroston.

4. Pcssiblitty of crisping precluded by a phsteal barrier around the exhaust lines.

b. If a non.eechanistic blockage of the exhaust line were assumed.

damper will still open since supply air is cut off and venting would be accomplished through nomat system leakage.

c. Finally, if a non-sechanistic failure of the systen to operate were assmed. the stack radiation monitor (albett hon.1E) v11) warn the operator to take the necessary action (i.e.. manually secure systen).

-f.

Based upon the above considerations. Orown & Root does not Itconsider . should the ses.

tulated accident credible and does not plan to modify the design' d be pointed out, however, that the System Design Reviews being con 6cted on J

y the plant systens do enconpass a systematic review of non sec when called upon to perfom.

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V N Enclosure}

GENERICFINDING3.1(f)

FSAR COP 9t!TMENT TRACKING

}

This Generic Finding 3.1(f) notes the following:

o

1. "There was no decernced evidence for assurlog that individual F5AR comitments for systems, equipment or calculations were batng sys-

tematica11y implemented into the desig.1."

r i

2. "There is a potential for a lack of awareness of individual F5ARThis c i M comnitments by STP site personnel.

l I problen for field inttf ated design changss."

) 3. "One group conspicuous by its absence during this design restew prog sns Licensing."

4.

"A censistent and docunented 88R "These position regarding interpretations are lef t to code and stan interpretations was not evident." torpretation area individuals or to vendor suppliers. The A5ME code appears to te particularly weak (see Question M 30)

In response to the above:

1. Required modifications to the F$AR have been identified during the Design Assurance Review; (see 50005. Sec. 3.1.3.c and 3.2.3.e),

F5AR is scheduled for update during our upcoming systems design f

> In addition, project procedures require Identifying Also, the Vendor all changes that l affect the F5AR on the Design Change Notice form. '

Control Program performs a complete FSAR review for safety class equipnent and materials to ensure ary disconnects between equ l

specifications and F5AA coettpoets are identitled and rectif ted.

j 2.

The statsents made by 4adres concerntag S&R's As a site activttles wer made without the benefit of a BAR Site (ngineering STPreview.

Site result, it is not clear trow thisAllconcluston field initisted was rea l

V ergantastion working through the same minagement.

) the Home Offtee.

3. Quadre did not revtew the actiettles of S&A's Licensin f -] w,,, , special topic.

Licensing and the disciplines which is closely controlled.

a 3,P !:* taecific 4,

the fM) t ..', pe abt.= s idrat tilail f p Q e sitree a*

w l: cited Tne '

comoonents and will be addressed en an individual tests.l

)

I ASMI, nonce, we astee that Oi.edren's geaert I

~ codes sad standards is wafounded j

0509952

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GENERICFINDlhG3.1(g) l PLANT DESIGN BA515 l l

l Generic Finding 3.1(g) notes the following:

1. "There was very little evidence of a well-thought out and co missing for STP."

2.

"No doccert exists that identifies the interface design information required by each discipline from the other technical discipline."

3.

'81R indicated that WHE5 has reviewed portions of the intf al STP design, but the quality and completeness of their review is uncertain."...

'The interface between 84R. WNES. and HL&P needs to be improved."

4.

EDS indicated that B&R drawing charges are not reviewed on a routine basis.'

l C

S.

"In numerous instances. WNES design bases for the nuclear island por-I without confirming their appropriateness for this appiteat

6. "In other instances, design details have been obtaine I

7. "S&R has not adopted a consistent requirement for design margin to b achieved by each discipline. engineers sake the determination of the marg design (see Questfons C 12 and H 8).

In response to the above:

1. The need for strengthening B&R's As statedfront end criteria docu by Quadrez in this area are in the process of being rectified.

en P. 3 8. ".... e neber of these docments have either been recently issued or are currently undergelng review prior to initial issue....".

The absence of selected front end criteria doceentation dues not pre-

" clude design.*

the entstence of "a well-thought-out and consistent matter to be purely subjective.

7.

As stat-d previously, the handling of design interf ace in'arnation is the responsiblitty of the SAR Systems Engineering Group and the use of pre 11elnary information is for the most part due to be phased out during the upcoming design freeze of the individual plant systests.

0509983

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' N Enclosure 1 lik GenericFindtrJ3.1(g)

Page 2 l

3. mestinghouse received all B&R piptog coposite drawings for Westinghouse 1977-78. From these draw;ngs, they prepared P50ffE M555 systens during285, Rev. O, which is the system state point analysts fur all operating They also issued Westinghouse P&lD's for con.

modes of M555 systems.In addition, the Westinghouse design unuals are used struc*(on. Westinghouse has also regularly by S&R during the design process. Documentation of this reviewed the logic diagrams for M555 systems.We consider Quadren's coments in review exists in the Project flies.We do, however, agree that the current this area to t;a unjustified.

R&R, WestingMuse and HL&P interface agreement needs to be improved and we have had discussions with HL&P in this regard.

4. The results of S&R's review of the EDS work was addressed earlier and based on Quadren's corvnents, seems adequate.

5. B&R did evaluate the application of Westinghouse criteria throughoutSystems whic the design of the STF systems.

systems and which have interface Other criteria plant specified by Westinghouse systems were designed to were designed to meet those criteria. meet the pressed worst case operating criteria, e.g., plan treatment systems.

6 6. SLR encourages the design engineers to factor previous expertenceThe Quadren into their designs.

have beeri obtained from other PWR plants andExperience use withoct andconfirming first- their appitcabtitty of the STP plant...." is unfounded. hand knowledge of the appitcab

7. We have difficulty interpreting Quadren's reruirks concerning design margins margin.

because the various design basis code 2 and standards includ placed upon equipnent and systems during the preliminary stages of design.

These will te vertfled during the design freeze process and again during We acknowledge Quadren's coment concerning our res-system pre. ops.

ponse to Question C-12. "...same A/E's do considerWe this acknowledge phenomenon stellar to the manner in which Brown & Root "...adid."

quick assessment of Quadren's findings relative to Question H.8, the adequacy of margins in the HVAC systen design is not possible."

8. Brown & Root has 20 volumes of Design Manuals which :::vpv 5 f t. of aIn retr standard bookshelf.

helped tv ea,e some uf the probie's resultity from the hi;5 personnel turnover expertenced by B&R during the late 1970's. The turnover situation was unanticipated and had never been empertenced on prestous B&R jobs.

0509984 f ee

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Enclosure 1 ;

i GENERICFINDING3.1(h) ;

g EQUIPMENT RELIABILITY REQUIREMENTS $

Generic Finding 3.1(h) notes:

i

1. " Specific reliability requirenents, such as for the ESF sequencer, have not been established (see Questions E-7 and E-8)." 's l

(

2. "If the ESF sequencer reliability should turn out to be incompatible A r with the rerainder of the ESF equfpnent, then B&R's dependence upon =

meeting only the single fatture criterton would be unsatisfactory fran -

a systems viewpoint." -;

1

3. "The absence of specific reliability requirments *In both sechanical -

l and electrical equipment specifications..... casts doubt on the rigor of -

5 i

the safety-related evaluation process." ;

l , 4. "Throughout the design review. specifications to constrain spurtoos 2 operation were absent." -

\

r

' The following is offered in response to these areas:

+

1. Reliability requirments have been specifically addressed in the E5F load sequencer spec. ES-071. Section 3.4. Reliability Analysis, which g y requires the vendor to impleent the method of fault tree analysis, as per IEEE Std. 352.

2. Regarding the possibility of incompatability. the vendor is required to -

conform to the t. odes and standards Itsted in Section 2 of the above ;

specification. B&R feels that these requirements are sufficient to --

ensure compatability with the E5F equipment supplied by WNES. Additionally.

the design satisfies single failure criterton. Should failure of one 3 sequencer occor. two other safety class trains wuld be available.

g

3. B&R does not concur with "Juadren's genera 11:ation of an " absence of '

specific reliability requirments in... specifications." The requirements l imposed by the codes and standards cited in our specifications are, in d l

5.

our judgment. suffletent to er.sure adequate reliability. Evaluation of . T l

' vendor doceents reflecting the implementation of the required standards c" is reviewed by the responsible engineer who at that time ensures the l adequacy of the design. See STP Procedure STP-DC-004 for the metho- =

dology for approving ver. dor drawings and doceents.

l ,

El 4. Althoue the corrent regarding " spurious operation" is general, our U response specifically addresses the seyencer. 5;s'ic. c;e-s tion o' is the sequencer is prevented by a matria recognition requiremer.t of 2 out ;

of 4 signals for undervoltage recognition (modes !! or !!!). or 4 out of 6 signal recognitions for safety injection (ecde ! or Ill). Furtne-details can be found in the se@encer specification in the section -d describ'ng mode of operations. Also, spurious valve movencets have been E considered as early as the PSAR stage. A revle of the Safety Eve 1w- ai tion Report and the appropriate logic diagrams weutd ha.e made this i evident. 2-inam m.s

. a. ,

Enclosure 1 GENERICFINDING3.1(1)

MUCLEAR-RELATED ANALYSIS GenericFinding3.1(1)notesthefollowing:

1. 'The chosen analysis methods denonstrate a sharp radox between the more conventional engineering work and the unique nuclear engineering work required for portions of the STP design." "In certain disciplines.

such as Civil / Structural and Electrical. technically adequate methods have been chosen. However, for the nuclear aspects of the project.

Brown & Root has been much less adequate in its choice of analysis methods and assumptions." "In addition, an abnormally high error rate

/ was observed in these calculations. In many instances. insufficient work has been accomplished for the present state of STP design, pro-curenent, and construction."

2. "The amount of nuclear-rel ted analysis that is subcontracted by B&R is higher than a typical A/Es practice. The technical guidance provided by some of these groups for subcontracted consultants, such as EDS and MUS. does not appear to be adequate. Review of these subcontracted analyses does not appear to be sufficient."

The following is offered in response to these areas:

1. Changes to correct past difficulties in the Nuclear Analysis Group were implemented in 196C. Plans to complete outstanding work are evident in the Project schedules. Responses to specific concerns will be rddressed on a case bases.

2. The work' done by EDS and MUS has been shown to be of high quality and adequately coordinated and interfaced with affected disciplines.

The " amount

of analysis that is subcontracted is irrelevent with respect to this review.

?

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M Enclosure 1 GENERICFINDING3.1(j) s- FINAL DESIGN VERIFICATION l

l Generte Finding 3.1(j) notes the following:

, 1. "The B&R design vertf tcation process perutts the use of pretteinery data up to the point of STP fuel loading."

2. "There are no doceented standards regarding the mintsus qualtf tcations required for a design verifier. Typically, the Discipline Troject

~

g Engineer selects the design verif ter from within the discipline, but his basis for selection is not doceented."

The following is offered in response to these areas:

1. We do not see how this finding can be consistent with Quadren's assess-5 ment of B&R's response to Question C-16 which is referenced as a basis

for the finding; 1.e., "8rown & Root's design vertf tcation procedure appeared to be adequate or above industry standards on paper; however, we (Quadrex) were unable to evaluate the effectiveness of this procedure."

2. Quadrex acknowledges in the text of the review that this approach does not violate NRC requirements.

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Septaber 25,1981 E' L* M pd specific MR taput: ;

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ML20116P131

Contents

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Dear Members of the Board:

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ML20116P131

Text

Dear Members of the Board:

SUBJECT:

SUBJECT:

SUBJECT:

References:

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