ML20133F694
| ML20133F694 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/30/1985 |
| From: | Eifert W, Domonique Malone STONE & WEBSTER ENGINEERING CORP. |
| To: | |
| Shared Package | |
| ML20133F681 | List: |
| References | |
| EA-768, NUDOCS 8510110192 | |
| Download: ML20133F694 (60) | |
Text
EA-768 ENGINEERING ASSURANCE CORRECTIVE ACTION STATUS REPORT MILLSTONE UNIT 3 PROJECT NORTHEAST UTILITIES SERVICE COMPANY SEPTEMBER 30, 1985 sie la? M W.M.Eif(inee/
rF D.L.'Malone Chief Eng r
Audit Team Leader Engineering Assurance B510110192 051007 PDR ADOCK 050 3
TABLE OF CONTENTS PAGE 1.
INTRODUCTION 1-1 2.
STATUS
SUMMARY
2-1 3.
CONCLUSIONS 3-1 4.
RESOLUTION OF AUDIT OBSERVATIONS (A0s) AND FOLLOW-UP REVIEWS 4-1 4.1 Controls 4-1 4.2 Electrical 4-2 4.3 Engineering Mechanics 4-3 t.4 Power 4-4 4.5 Structural 4-21 4.6 Equipment Qualification 4-22 4.7 Hazards Analysis 4-30 5.
REFERENCES 5-1 i,
i
1.0 INTRODUCTION
1.1 General This report provides the status of the actions necessary to resolve the Audit Observations resulting from the Technical Audit of Millstone Unit 3 Project performed June 3 - July 30, 1985.
The results of the audit are reported in Reference 1.
Section 5 of Reference 1 presents the resulting Audit Observations.
During the NRC Inspection of the audit results, September 12 and 13, 1985, it was agreed to perform follow-up reviews in the environmental qualification area. The results of these reviews are also presented.
l l
l l
1-1
{
I 2.0 STATUS
SUMMARY
The status of each Audit Observation (AO), and the associated Action Items, is identified on Table I.
Additional discussions of each item and of follow-up reviews performed are contained in Section 4.
Action Items resulting from the follow-up review in the environmental qualification area are also included on Table 1.
l l
l 2-1
EA-733 TABLE I MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 160. Item A.1 Inconsistencies with FSAR, C-001 Closed - Actions Table 7.1-1 typographical completed. LCN issued error to amend FSAR.
160. Item A.2 Inconsistencies with FSAR, C-001 Closed - Actions Table 1.8-1 incorrect completed. LCN issued to references.
amend FSAR.
I 160, Items B.1 Editorial discrepancies C-001 Closed - Actions
& B.2 in diagrams satisfactorily completed.
160, Item C Project procedure NETM-53 C-003 Closed - Actions incompiere satisfactorily completed.
161, Item 1 Choice of Independent C-031 Response incomplete.
Review of Cales. SP-3RSS-4 Project to submit revised and SP-3SWP-2 in conflict
- response, with EAP 5.3 161 Item 2 Assumptions of setpoint C-046, Response of incomplete.
cales. not addressing Item 1 Project to submit revised requirements response.
161, Item 3 Margin requirements not C-046 Response incomplete, addressed in setpoint Item 2 Project to submit revised
- cales, response.
161. Item 4 Method used in setpoint C-046, Response incomplete.
cale. does not address Item 3 Project to cubmit revised adverse environmental response.
effects 161, Item 5 Seismic effects on C-Oll, Response incomplete.
instrument performance Item 4 Project to submit revised not used in calc. from response.
source document.
162, Item I Deviations to EMTP 9.3 J-028 Closed-Actions completed regarding ARS log and and satisfactory seismic data index identified 162. Item II,1 Sufficient detail not J-011 Closed-Actions completed provided in Stress Data and satisfactory Package for Calc. on emergency case.
2-2
EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 162, Item II,2 Hydrotest specified by J-061 Closed - Actions E6DCR F-P-35656 not used in satisfactorily completed, calc.
162 Inconsistencies identified J-008 Closed - Action complete Item III, 1 between NETH 44 and FSAR and satisfactory. LCN reg. guide compliance issued to amend the requirements.
FSAR.
162. Item III,2 Valve Accelerations -
J-034 Closed - Action completed Inconsistency between and satisfactory. NETH Practice and Procedure 49, Revision 1 issued.
163. Items 1 Various concerns J-021 Responso Accepted 8/30/85 through 8 identified with NETM 28 NETH 28 in Revision.
Scheduled completion 9/30/85.
163, Item 9 NETM 45 - Concerns with J-046 Closed - Action completed loading combinations and satisfactory. NETH 45, Rev. 1 CN6 issued.
164, Item 1 RSS Flow diagram design P-032 Closed - Actions temp - supporting completed. Calculation calculation not located.
located.
164 Item 2 Not apparent that RSS P-006, Response acceptable -
design temp. envelopes P-031 expected completion of range.
action 10/11/85.
164. Item 3 Basis for compliance with P-031 Response acceptable -
RG 1.141 not established project to provide supplemental documenting by 9/30/85.
164. Item 4 Not apparent that RSS P-011, Response acceptable -
design proenure considered P-018 actions expected to be pump shutoff pressure or complete by 9/30/85.
"as tested" pump curve.
164 Itam 5 Flow diagram not revised P-006 Response acceptable -
with Stress Data Package flow diagrams to be changed by 10/11/85.
2-3
EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECllNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 164, Item 6 Ilow project considers P-026, Closed - LCN issued to RSS to be " opened" or P-031 amend the FSAR.
" closed" system not cicar.
164, Item 7 Not apparent how SRP 6.2.4 P-026 Response acceptable -
is satisfied regarding Ictter to NUSCO to be leakage detection.
issued by 9/30/85.
164, Item 8 Initial design consideration P-026 Response acceptable -
to maintain subatmospheric awaiting project conditions for 30 days response to NRC question under failure of isolation (480.7) due to be issued valve not demonstrated.
9/30/85.
164, Item 9 Justification for not P-027 Response and action to adding relief valves to date satisfactory.
RSS because of Problem Awaiting NUSCO action.
Report PR-149 not provided.
Need further evaluation where relief valves were added when component pressure rating exceeded.
164, Item 10 Cales. prepared refer to P-033 Response not received earlier revisions of flow diagrams than specified in the Stress Data Package 164, Item 11 FSAR sections not changed P-004 Closed - Project in to reficct exception to compliance with RG 1.89 -
no exception needed.
165. Item I Pressure Drop Required P-007 Response acceptable for (Calc. 610 PCR) for 3RSS-all calculations noted.
R039A/11 Orifice No generic concern on Concerns with Calc P(R)-
P-009 technical adequacy of the 1115 Containment Rectre calculations. Project to Spray itend Calculation provide training to Power Concerns with System Design P-011 discipline during Pressure (Clac. 551P)
October, 1985 to prevent recurrence.
2-4 l
EA-733 TABLE I (con' t)
MTLLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status Concerns with Setpoints P-012 within Containment Recirc.
Pump Mainfold Recire. Calc.
659P(R) l Method of Calc. not P-012 appropriate 165, Item II E&DCR F-C-02358, Concern P-023 Response acceptable -
with the justification project to issue memo by 9/30/85 on E&DCR justifications.
166, Item 1 Thermal L torsional Loads S-051 Response Satisfactory.
on steel beams are not Awaiting results of addressed in calculation investigation.
Scheduled completion 9/30/85.
166. Item 2 Calculations not performed S-048 Response and actions to for certain doors in the date Satisfactory.
ESF Building Awaiting notification of issue of change documents. Scheduled completion 9/30/85.
166. Item 3 Inconsistencies exist in S-050 Closed - Actions bolt connection completed satisfactorily.
requirements on drawing ES-3A-10 and Specifications, FSAR commitments on Use of 7th edition of the AISC, &
allowabic stress values used for bolting.
166, item 4 Tornado effects on design S-047 Response and actions to of shield doors support date satisfactory.
not documented Awaiting responses for clarification of specifics.
166, Item 5 No evidence of impact loads S-046 Response Satisfactory -
from pipe rupture To be followed under A0 transmitted by EMD to 171, Item 10.
Structural discipline.
2-5
l EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
S ta tu s 167, Item 1.a Consideration of R-007 Response not complete.
environmental conditions Supplemental response due to pipe break in required.
MSVB - extent not determined.
167, Item 1.b No documentation for R-009 Response not complete, conclusion of not Supplemental response performing HELB/MELB in required.
ESF Building 167, Item 2 Local environments beyond P-029 Response not received.
those of NETM 26 not apparently considered for some equipment.
167, Item 3 Some Cales. revised R-008, closed - Actions and without revised copies Item 2 Response acceptable transmitted to users.
to close this issue.
Some voided cales referenced.
167, Item 4 Inadequate recording of R-008, Response of 9/5/85 superseded calculations Item la insufficient for in Project file.
corrective action.
167, Item 5 Assumptions and methodology R-004 Closed-Actions Complete in US(B)-276 for worst and Satisfactory conditions not cicar 168. Item 1 Cales marked confirmation J-014 Response Satisfactory.
required but not indicated Review by EMD to be on calc index or discipline completed by 9/30/85.
control listing.
168. Item 2 No indication could be J-014 Response not Submitted found where computer program was scheduled for qualification after program used in calc. marked
" Confirmation Required".
168. Data Equipment seismic J-055 Response Satisfactory.
Transmittals qualification concern Procedure to be with the interface issued by 9/30/85.
between disciplines 2-6
EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 169, Item 1 Table 3.10B-1.2 of FSAR J-054 Response Satisfactory, does not present data FSAR to be amended by for RSS pump motors.
10/14/85.
169 Item 2 Allowable stresses used J-052 Response Acceptable.
not in agreement with FSAR, Review to be completed Table 3.9B-7.
by 9/30/85.
169 Item 3 Loads not in agreement for J-058 Response Acceptable, embedments by the Nozzle reconciliation Structural Group. Nozzle program scheduled for load revisions not factored completion 9/30/85.
in mechanical and vendor calculations.
169, Item 4 Project practice not in J-051 Closed - Actions conformance with NETM-49 complete. NETM 49, for nozzle loads in excess Rev. 1 issued, of vendor allowables.
169 Item 5 Documentation review for J-062 Response Acceptable.
3RSS*MOV23A,B,C,D 12" Action tied with nozzle valve / torque tube / actuator reconciliation program revealed several concerns.
scheduled for 9/30/85.
169. Item 6 Expansion of the exception J-059 Closed - Actions to RG 1.48 required in the complete. LCN 701 FSAR.
issued to amend FSAR.
169, item 7 Cales. need review to assure J-025 Response Acceptable.
references to PSAS nozzle Action tied with nozzle load cales, are valid and reconciliation program current scheduled for 9/30/85.
169. Item 8 Calc. 6521Z not complete J-017 Closed - Actions complete to support licensing and Satisfactory.
response to NRC.
169, Item 9 lloiddown bolting missing J-024 Closed - Response of from accumulator mounting 9/12/85 Satisfactory associated with RSS Pump to close this item.
RSS*P1A 169, Item 10 Seismic analysis pump E-030 Closed - Actions complete calculations do not and Satisfactory.
address junction box qualifications 2-7
EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 169, Item 11 Several changes required J-009 Closed - This item to be to clarify wording in followed under A0 171 -
FSAR for jet impingement Item I.15.
effects 169, Item 12 Equipment Qualification -
J-053 Response Acceptable.
Review of Nozzle Loads on Review of cales tied with component qualification nozzle reconciliation
- basis, program scheduled for 9/30/85.
169, Item 13 Updating of design J-015 Response to IOC 9/11/85 specifications in regard not Submitted.
to seismic section requirements 170, Item 1 Hazard report lacks H-23, Closed - Action completed references to criteria IIA.1.2 satisfactorily, and design documents that support FMEA conclusions 170, Item 2 Hazard report lacks the H-23, Closed - Action completed basis of a controlled II.A.3 satisfactorily, document, no review and approval.
170, Item 3 Hazard FMEA and conclusions H-23, Closed - Action completed lack accountability from IIA.1.1 satisfactorily.
the participating Division representative.
170 Item 4 The Hazard FMEA not H-021, Closed - Action sufficiently documented H-23, satisfactorily completed.
to ensure conclusions II.A.1 are readily substantiated.
170 Item 5 Hazard report not H-022, Closed - Action integrated into project II.A.3.1 satisfactorily completed.
design control process to ensure design changes effectively evaluated.
170, Item 6 Hazard report and program H-010 Closed - Action not defined in relation satisfactorily completed.
to stress reconciliation process for final stress results.
2-8
EA-733 i
TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT No. 59 AUDIT OBSERVATION (AO) STATUS l
A.0.
Action NuTber Subject Item No.
Status 171, Item'I.1 Incomplete environmental H-015 Closed - Action effects addressed in satisfactorily completed, i
FSAR and the Hazard Report.
171, Item I.2 Fluid spray wetting effects H-017 Closed - Action inck review criteria within satisfactorily completed.
the hazard report.
1 171, Item I.3 Hazard report lacks safe-H-016 Closed - Action l
shutdown systems in the satisfactorily completed.
l criteria of essential systems subject to single action failure postulation.
171, Item I.4 Moderate and High Energy H-014 Response not Submitted Line definition inconsistencies within the hazard reports.
171, Item I.5 Hazard report interaction H-019 &
Closed - Action evaluations do not address H-023 satisfactorily completed.
missile potential hazards associated with resolutions, thermowells, etc.
171, Item I.6a Single active failure H-013, Response Acceptable.
criterion implemented by H-018 &
Need NUSCO approval the Hazard Report differs (NERM 69) of proposed from the FSAR
' electrical change to FSAR. LCN to components'.
be issued. Scheduled completion 9/30/85.
l 171 Item I.6.b Single active failure H-003 Response Acceptable.
criterion implemented by Closed.
Section 2.1 the Hazard Report differs of NERM 69 accurately from the FSAR
' dual describes " dual purpose" purpose' exclusion rule, rule.
l 171 Item I.6.c Single active failure H-023 Closed - No further criterion implemented by action required. Proj ect the Hazard Report Differs position agrees with SRP from the FSAR
' applicable
- Guidance, single active failure'.
171, Item I.7 Hazard report lacks review H-011 Closed - Action criteria to ensure only completed satisfactorily.
Seismic CAT ~I systems and components are utilized.
2-9 L.
EA-733 TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS i
A.O.
Action Number-Subject Item No.
Status 171, Item I.8 Hazard report lacks criteria H-022 Closed - Action for evaluating pressure completed satisfactorily.
integrity requirements.
171, Item I.9 Hazard report lacks review H-023, Closed - Action criteria for ensuring I.D. &
completed satisfactorily, containment isolation I.E system piping and components are protected from LOCA.
171, Item I.10 Hazards report does not S-046 &
Response Acceptable.
document structural S-052 Need Criteria (based on evaluation of HELB effects.
Topical Report 77-03) added to NERM 69.
Scheduled completion.
10/85.
171, Item I.11 Hazards interaction H-021 &
Closed - Action summaries lack analysis S-052 satisfactorily completed, summaries documenting review of-items which may be targets of
- hazards, l
171, Item I.12 Review criteria and FMEA H-002 Response Acceptable -
results for jet impingement However, LCN required to effects on systems, clarify that only.
components, etc. not environmental effects are evaluated by the Hazards to be considered.
program.
Scheduled completion 9/30/85.
171, Item I.13 Hazard evaluation of H-018 Closed - Action missiles and HELB satisfactorily completed.
effects should verify 'as maintained through the area by area review'.
171, Item I.14 Classification of dertain H-020 &
Response Acceptable -
lines as moderate energy H-021 However, project must lines alters hazards address concern that evaluation where lines incorrect pressi!re boundarier are contained
- traverse, in the Stress Data Packages for the Aux.
Feedwater System.
2-10 7
EA-733 TABLE _I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number Subject Item No.
Status 171, Item I.15 Information contained in J-009 Closed - Specific actions FSAR Section 3.6 is not completed and consistent with the Design.
satisfactory.
Several changes required to clarify wording in FSAR for jet impingement effects.
171, Item I.16 Hazard report systems H-004 Response not Submitted interaction tables have not identified all CAT I systems contained in NETM-74.
171, Item II Examples derived from H-021 &
Response under Evaluation Hazard Report and field H-023 walk supporting concerns identified in Part I to AO.
172, Item I Flooding analysis does P-015 Response satisfactory.
not identify the means Flooding calculations available to terminate to be revised by 11/85.
piping failures for flood mitigation-Hazard Report.
172, Item 2 Use of appropriate flow P-016 Response Satisfactory, coefficient for flow Revised flooding under doors should be calculations expected by evaluated.
11/85.
172, Item 3 Flooding analyses do not P-017 Response not received address flooding sources Indications are that originating from the floor flooding calc. to be drainage system, revised by 11/85.
172, Item 4 Fluid discharge rate used P-014 Response Acceptable.
in calc. inconsistent with Flooding calc. to be guidance of SRP 3.6.1.
revised by 11/85.
172, Item 5 Moderate energy pipe crate H-005 Response not received.
criterion used for all Indications are that piping systems may not be flooding calc. to be limiting for high energy revised by 11/85.
subcooled liquid systems.
2-11
L EA-733 i
TABLE I (con't)
MILLSTONE UNIT 3 TECHNICAL AUDIT AUDIT NO. 59 AUDIT OBSERVATION (AO) STATUS A.O.
Action Number-Subject Item No.
Status Action Items Resulting from Environmental Qualification Follow-up Minor discrepancies in E-043 Response acceptable.
SCEW sheets. Values Rev. 1 Action to be completed by differ from Test Reports.
11/1/85. SCEW sheets to be revised to reflect actual Test Report values.
Model No. for 3RCS*TE413C E-044 Closed. New Model No.
not indicated on vendor coincides with vendor drawing nor in specification.
drawing. Proj ect NTS Test Report does not established 100% relative indicate 100% relative humidity did exist for a humidity during tested sufficient period of test, accident conditions.
Minor discrepancies Project E-045 Response acceptable.
EQ Checklists.
Action to review checklists and update by 11/1/85 acceptable.
Reduced voltage requirements E-046 Closed - Project and for motor valve operator in Vendors have established FSAR 70% - Some suppliers equipment reduced voltage with 80% capacity.
validity.
Error shif t- (LOCA) of E-047 Verbal response 3RCS*P7403 input to acceptable. Awaiting Westinghouse setpoint documentation and action calculations.
commitments.
Discrepancies in the low E-048 Verbal response voltage splicing materials acceptable. Awaiting (type WSCF-N) noted in documentation and action SCEW sheets differing from take completed by 11/1/85.
the EQ reports were noted.
2-12
3.0 CONCLUSION
S In Reference 1 it was concluded that the audit results did not indicate any ovsrall programatic or systematic weakness and that the implementation of the design process was adequate in most areas reviewed.
Investigations and other follow-up actions performed as a result of the audit have not modified these conclusions.
(See Section 4 for additional discussions).
At the time of issue of Reference 1, most of the unresolved issues rel'ated to the Hrzards Program and system design conditions in the Power discipline.
Although corrective action, if necessary, may not be complete for all identified concerns in these areas, details of the concerns have been defined and satisfactory tetions to correct the conditions have been established.
Some of the issues in the Power discipline area involved code interpretation questions which have been resolved with no action required by the Project.
Some concerns still require Project investigation, Project response, corrective action completion or verification of corrective action.
However, the final resolution (bounding and' correcting) of the concerns is proceeding entisfactorily.
4 3-1
4.0 RESOLUTION OF AUDIT OBSERVATIONS (A03) AND FOLLOW-UP REVIEWS 4.1 Controls (A0s 12179-160 and 12179-161)
A0-12179-160 dealt mainly with random, editorial type discrepancies (Action Items C-001 and C-003) that required correction.
Each of the items have been verified as being satisfactorily corrected and the A0 has been closed.
A0 12179-161 addressed various concerns with setpoint calculations.
(Action Items C-011, C-031 and C-046). The initial response by the Project did not fully address the concerns.
The Project has reevaluated the concerns and submitted a r; vised response. The course of action to resolve the A0 appears to be adequate, but is still.under evaluation by the audit team.
4-1
4.2 Electricel Th2re were no resulting Audit Observations in the Electrical area.
One I
Elsctrical ' Action Item (E-030) required additional action by the Project.
However, this Action Item is related to seismic qualification and was included in A0 12179-169. The resolution of this A0 is discussed in Section 4.6.3.
I e
4-2
4.3 Enginzering Mtchanics 4.3.1 Pipe Stress Analysis (AO 12179-162)
Except for one instance (Action Item J-061), the items identified in A012179-162 (Pipe Stress Analysis) do not reflect technical concerns (Action Items J-028, J-011, J-008, and J-034). These items have been verified as being corrected.
Action Item J-061 addresses a concern that apparently resulted from a unique dssign configuration. An E&DCR was issued to change the hydrotest pressure that affected class 2 and class 4 piping but was not considered in the analysis bacause class 2 is normally isolated from class 4.
In order to bound this condition, the Project reviewed all E&DCRs written against specification M149 and determined that no similar cases existed.
In addition, approximately 50 large bore pipe stress calculations were reviewed for hydrotest pressure effects using actual test pressures and all were found to meet the hydrotest requirements of tha specification.
The Project is now sensitive to this condition when svaluating future E&DCRs.
The condition has been satisfactorily corrected and bounded.
Based on the above, A0 12179-162 has been closed.
4.3.2 Pipe Support Design (A0 12179-163)
A0 12179-163 dealt with needed enhancements to Project procedure on pipe support work.
There was no evidence that the procedure concerns had affected design work.
Because there are other Change Notices already written against the i
procedure, the Proj ect has decided to revise the procedure to incorporate outstanding Change Notices and the needed changes identified by this A0 rather than issuing additional Change Notices.
EA concurs with this approach since a more workable document will result.
The revised procedure is expected to be issued by October 3, 1985.
As a result of the NRC review of August 26-30, Action Item J-046 (concern with pipe support calculation loading conditions) was added to A0 12179-163 to track a rsvision to NEIM 45.
Previously, Project EMD personnel had stated that NETM 45, Rev. 1, Section 3.4 " Loading Conditions and Allowable Stresses for Pipe Supports Excluding Pressure Boundary Attachments" could be revised to provide guidance in determining critical load combinations for the applicable design conditions for each plant operating condition.
Change Notice 6 has been issued and adequately clarifies the requirements for determination of load combinations for load ccnditions which comprise dynamic loads.
No further action is required.
This itsm (Action Item J-046) is considered closed.
4-3
'4.4 Power 4.4.1 Power Design Conditions (A0 12179-164) 4.4.1.1 General Many conclusions in the original report were deferred until a review could be parformed of the proj ect responses to the eleven issues identified in A0 12179-164 of Reference 1.
Proj ect responses have been received on all eleven issues and are discussed in detail below. Although not all A0 issues are closed, tha actions necessary for closure have been resolved and will not affect the csnclusions of this report.
Based on the Project responses, actions taken and investigations performed it can be concluded that, in general:
o FSAR design commitments are supported by and consistent with project documents which establish the system design basis criteria.
Process design is in compliance with applicable code and standards and SWEC o
Power Division Technical Procedures.
o Interdiscipline interfaces with design documents have been adequately interpreted and implemented.
o Project responses to problem reports and the actions taken to implement
-design changes are adequate.
A final conclusion within the Power discipline can be made that the technical adsquacy and the implementation of the project design process are adequate to a2sure a safe and reliable operating plant.
4.4.1.2 Details Tha following is a detailed discussion of the eleven issues identified in A0 12179-164.
In addition, Action Item P-024 which was not clearly addressed in Reference 1 is included as item 12 in the following detailed discussion.
1.
"The basis for the RSS system design temperature of 235 F as shown on the flow diagram is not adequately supported (Action Item P-032)."
Action Item P-032 (System Design Temperature Justification Documentation in form of a calculation (12179-ES-100-0) was provided by the project which adequately addressed the basis for the original RSS system design temperature of 235 F.
This documentation resolved this A0 issue which is now considered closed and requires no project follow-up action.
2.
"It is not apparent that the RSS system design temperature of 235 F envelopes the temperatures to which the piping and components may be subjected (Action Items P-006 and P-031)."
Action Item P-006 (System Design Temperature)
Stated pump design temperature on the flow diagram (FSK) at the time of the audit was 235 F.
However, the proj ect was aware of the results of calculation US(B)-275 (Sump temperature vs. time) performed prior to the
+
4-4
- -. -,=.
- _ _ - _ = - - -
audit which showsd the maximum cump temperature to be 256 F and which was documented in the stress data package (SDP).
With the initial generation of the SDP an official memo (SDPC-63) was prepared prior to this audit in accordance with procedure NETM-30 to document all cases where system operating conditions were found to exceed system design conditions.
This memo was submitted to the auditors for review. The new enveloping temperature was adequately identified in the SDP memo and bounds the concern.
An E6DCR has been issued to change the design temperature on the FSKs for the RSS system supply piping to 260 F.
It is the Project's intent to change the design rating of all the af fected components to 260 F.
If required, recertification of components will be performed in accordance with code requirements.
E&DCR's changing FSK design conditions for other affected systems identified in SDPC-63 will be issued by October 11, 1985. If required, recertification of components will be performed in accordance with code requirements.
A memo will be issued by October 11, 1985 to all power discipline engineers stating that if system design changes occur, E&DCRs will be issued to change the design conditions on the FSK and related affected components documentation will be updated if required, as well as noting the changes in the SDP.
This issue was previously identified by and was being adequately resolved by the project.
The maximum sump temperature exceeds the original RSS system design by 21 F.
The SWEC equipment specialist has indicated that the RSS pump is designed such that it is not temperature limited to any temperature below 400 F.
Bingham (pump vendor) has confirmed the acceptance of the pump for these design conditions.
All other components have design temperatures which bound the new design temperature condition.
The piping system has already been stress analyzed to 256 F.
Sump temperature continually decreases over time (Ref. US(B)-275).
Within 10 minutes, sump temperature will be below 235 F.
Changes to design documents, if required, will be identified in the stress reconciliation program (NEAM-134).
This A0 issue has been adequately resolved and will be closed upon issuing the above mentioned E&DCRs and memo.
Action Item P-031 (Containment Design Temperature)
To address this issue the project was requested by the auditor to perform a sensitivity study for 2 pipe sections which the auditor believes to be piping sections which will receive the highest stresses and therefore bound the condition.
The proj ect has performed this study and an assessment of the results were reviewed.
The worse case condition using bounding conservative assumptions concludes that the allowable stress for the piping sections is within code allowables.
The project is still evaluating the results with regard to more realistic assumptions to determine if the as-analyzed piping section represents the bounding case for this service condition.
The results of this evaluation will be issued by September 30, 1985.
However, regardless of the results of this further assessment, the piping system as installed is within code allowables and therefore not a saf ety concern.
Final results and conclusions will be provided with final closure of this audit observation.
4-5
3.
"R gulatory Guida 1.141 indicates that containmsnt penetrations and isolation valves must withstand containment design temperature.
The basis for compliance with Regulatory Guide has not been provided (Action Item P-031)."
Action Item P-031 (Discharge Design Temperature)
The proj ect has indicated that it is in compliance with the design requirements of RG 1.141 with regard to the containment penetration piping and outboard isolation valve.
The project will provide additional documentation basis with regard to compliance by September 30, 1985 to allow closure of this A0 issue along with item 2 above.
4.
"It is not apparent that the basis for RSS design pressure of 275 psig considered pump shutof f pressure under test conditions or the "as tested" pump curve (Action Items P-Oll and P-018)."
Note:
Action items P-006 and P-031 will also be discussed below as they relate to discharge design pressure boundaries.
Action Item P-Oll (Discharge Design Pressure)
The original design basis of MP-3 was predicated upon RSS pumps with columns extending almost to grade elevation + 24' 6" el.
This design philosophy was established to protect the motors from any possible system flooding scenario.
This very conservative design results in a pump column in excess of 40 ft.
Prior to release for fabrication the project elected to reduce the pump column length because of prevailing industry concerns relate to shaft vibrations and inherent pump reliability.
In making this prudent decision the engineer's did not consider the impact on the systems discharge piping design conditions. The original system discharge design pressure condition predicated on pump shutoff head.
With the reduction of column length was the engineers should have addressed its impact on the design conditions previously established.
As can be understood from the explanation above, by geometric constraints this is an apparent isolated instance.
This situation was further exacerbated by the vendor supplying pumps which performed well in excess of the required design curve.
The Proj ect has reviewed 10 sets of pumps (3QSS*P3A/B, 3EGF*PlA-d, 3SWP*P3A/B, 3CCI*P1A/B, 3SWP*PlA-D, 3FWA*PlA/B, 3FWA*P2, 3CCE*PlA/B, 3SWP*P2A/B and 3HVK*PlA/B) to assure that conditions envelope prevailing design conditions.
This was confirmed in all cases.
These pumps were chosen as they represent similar instances to the RSS pump geometry issues i.e.,
elevated reservoir on the suction and the potential for elevation changes during design evolution.
(With regard to extent for shop vs. design curve usage refer to Action Item P-018 for final resolution of this concern.)
The project has written an SDP correspondence identifying the pump shutoff event as an upset condition.
The project will issue FSK E&DCR's annotating peak pressure conditions, where appropriate, by September 30, 1985.
The Lead Power Engineer has written a memo to all power engineers reminding them to use the shop test curves when establishing design conditions rather than design curves. This memo further points out the 4-6
pitfalls of using the shop curve while establishing other process parameters.
Additionally, a memo has been issued by the Lead Power Engineer that requires a note to be added to an FSK if a peak condition exceeds a stated design condition.
This issue has minor significance.
The project has reviewed all RSS components which could be subjected to the peak pressure that could be established due to the revised pump column and the stronger pump curve assuming pump shutoff conditions and has found all components and piping have allowable ratings below that of the peak pressure.
The project has just received final confirmation in writing from Bingham (pump vendor) as to the acceptability of the RSS pumps at upset service conditions of 300 psig and 260 F.
The above proj ect review was conducted to assure the following design criteria were satisfied:
1.
The pressure / temperature ratings identified - by the applicable pipe class in the piping design specification M582 are not exceeded by the conditions of maximum pressure and coincident temperature of this event.
2.
All components not included in the pipe class are designed to the maximum pressure and coincident temperature to which the system may be accidently or otherwise subjected.
3.
The allowables S-Values in ASME III, Section NC-3612.3 are not exceeded when considering the maximum expected peak pressure during the variation.
The above approach is considered acceptable and consistent with the ASME III Code requirements.
This A0 issue has been adequately resolved and will be closed upon issuing the above mentioned E&DCRs.
Action Item P-018 (Discharge Design / Service Conditions)
When selecting the transients for this system the engineer did not believe the pump shutoff conditions under a plant faulted service condition when the normally open discharge valve gets a signal to open or under test modes were credible events.
In the test mode it is easy to construe that the operator could normally start the pump during IST testing against a shutoff head.
Traditionally the upset event of a pump operating against a shutoff head is not included as one of the service conditions evaluated in system design.
It is considered, however, in establishing the peak pressure that the pump discharge piping system can achieve.
Therefore, it is the calculational basic for establishing the pump discharge piping system design pressure.
(The traditional service conditions are established based on normal and abnormal operating conditions of the plant.
System responses are then evaluated against the plant operating conditions to determine the ability of i
the system to still perform its intended design functions during these events.
If during this evaluation the system design function cannot be
- achieved due to a single f ailure, such as a pump discharge valve f ailure to then a redundant or diverse system or component is provided to assure
- open, the system design function is maintained, if the system function is required for that event.)
4-7
The Project has reviewed ten pumping applications as previously identified in response to Action Item P-ll and has ascertained that design conditions are selected as Power Division philosophy dictates, upon pump shutoff head conditions. The Project considers this an isolated instance.
The Project has initiated a stress data package correspondence in accordance with procedure NETM-30 which envelopes both the shutoff head condition under test and other modes of operation for the RSS system.
Additionally, the Proj ect will notify the client in writing by September 30, 1985 that under inservice test modes of operation the RSS pump test circuit is designed to function with the pump being started in a throttled condition rather than a shutoff head condition, to minimize the operation of the RSS system at its peak pressure.
Because of concerns on the auditor's part that the sample chosen by the project is potentially non-bounding, with regard to the use of the shop test curve, the project has agreed to review all Category I pump installations, regardless of application, to confirm that the design basis for the selection of the prevailing design pressure was predicated upon the shop test curve shutof f head.
This review will be done as an additional scope under the project calculation closecut efforts scheduled to be completed by October 11, 1985.
The Lead Power Engineer has issued memo's admonishing all Power engineers to conform to divisional standards in utilizing shutoff conditions as normal pump discharge piping design conditions and to utilize the shop test curve when establishing system design pressures.
This issue has minor significance for the same reasons delineated in Action Item P-011 above.
This A0 issue has been adequately resolved and will be closed upon issuing the above mentioned correspondence to the client and the completion of review of all Category I calculations for the use of peak shutoff head curves.
Action Item P-006 (Discharge Valve Pipe Class Boundary) f This concern involves the location of the pressure pipe class boundary at a system isolation valve.
It was an oversite on the system engineer's part, in annotating this class break on the upstream side of the isolation valve.
The project has reviewed the location of all pressure pipe class boundaries at valves for four systems (SGF, FWA, BDG, RSS) and this is the only instance of this type.
The auditor reviewed a similar arrangement in the quench spray system and found it acceptable.
The project has revised the FSK to agree with the established class change marking convention and has reviewed the valve vendor's (Pratt) stress report which indicates the acceptability of the revised design conditions.
E&DCR T-P-07040 has been issued to provide recertification of the valve to the new design conditions.
This issue has minor significance.
There is no hardware impact and the proj ect and auditors review has established that this is an isolated case.
Pratt's stress report covers system conditions commensurate with established design conditions.
This A0 issue is adequately resolved and is considered closed, requiring no project follow-up action.
4-8
Action Itsm P-031 (Diecharge Prassure - Spectacle Flange)
These flanges were added in the evolutionary process of the plant design to facilitate 10CFR50, Appendix J, Type C containment isolation valve leakage testing.
The engineer did not consider that it was a credible event to design for leaving the spectacle flange in the closed position during operation.
The Project has reviewed all containment isolation penetration designs for similar applications and has identified three other systems with spectacle flanges installed to facilitate Type C containment isolation valve leakage testing.
(RSS, DBA H Recombiner discharge, containment vacuum (suction) 2 and QSS).
With the exception of the RSS system which forms the basis of the concern, the project has reviewed all applications where spectacle flanges are used and have determined that the design conditions envelope the peak conditions resulting from pump shutoff caused by closure of the spectacle flange. The auditor reviewed the quenc spray system and determined the same pipe class and design conditions were used for the entire length of pump discharge piping, which provides concurrence to the above Project review results.
The Project will issue an FSK E&DCR change by September 30, 1985 which will add a design note stating the potential variance between prevailing design conditions and potential peak pressure conditions for the appropriate piping system upstream of and including the spectacle flanges.
The Lead Power Engineer has issued a memo admonishing all power engineers to conform to divisional standards in utilizing pump shutoff conditions as normal pump discharge piping design conditions.
This issue has minor significance.
In the RSS application the Proj ect is reviewing the components (valves, flanges, piping) which could be subjected to these peak conditions to assure that their maximum allowable working pressures envelope all coincident pressures and temperatures to which they may be subjected.
A preliminary analysis has indicated that no hardware concern exists. The final analysis will be completed by September 30, 1985.
This A0 issue has been adequately resolved and will be closed upon issuing the above mentioned E&DCR and final confirmatory analysis.
5.
"The Stress Data Package (SDP) for the RSS was changed to reflect revised design conditions (temperature) but the flow diagram was not revised to reflect this change (Action Item P-006)."
Action Item P-006 (System Desigt Temperature)
Refer to issue 2 above for Action Item P-006 which addresses this issue.
6.
"RSS Containment penetrations on the suction side of the pumps have one containment isolation valve which is enclosed in a leak tight housing. This is consistent with SRP 6.2.4 if the system portion outside containment is a closed system and meets all other requirements for a closed system.
However, it is not clear if the RSS is considered by the Project to be a
" closed" system or an "open" system (Action Items P-026 and P-031)."
Note:
Action Item P-031 was erroneously inserted as part of this issue.
However, it is discussed in other appropriate sections of this report.
4-9
+
Action Item P-026 (Clossd' System Outside Containment)
The RSS system is the only system where credit for a closed system outside containment is required to satisfy containment isolation system requireeents.
It is the Project's position that lock closed manual vent / drain valves and other branch valves have historically never been a design feature of this system.
It was not the Project's interpretation that the above mentioned valves were required to be locked closed for conformance with RG 1.141.
A licensing change notice has been initiated clarifying the project's compliance statement for RG 1.141 in Section 1.8 of the FSAR.
The significance is considered to be minor.
All vent and drain valves are shown on design drawings as normally closed while the cross over valve for hot and cold leg recirculation is under strict operator control from the Main Control Board.
It is the project's contention that locking closed the vent and drain valves would not significantly augment the containment isolation intent of the closed system designation.
Additionally locking closed the cross-over valves on the Main Board would inhibit the operator's ability to switch over from the spray to injection mode. This A0 issue has been adequately resolved with the issuance of the licensing change notice mentioned above and is considered closed.
7.
"Because the containment isolation valves are remote manual, it is not apparent how SRP 6.2.4 is satisfied regarding provisions to detect leakage from the lines outside containment in order to isolate the related lines and prevent further transfer of sump' water outside the containment (Action Item P-026)."
Action Item P-026 (Passive Failure Leakage Detection)
The Project had considered leakages consistent with breaks and cracks defined in the NRC mechanical engineering branch position, MEB 3-1.
This philosophy had been previously utilized as the basis for our flooding analysis.
This philosophy would assure detection but does not consider smaller breaks which would go undetected due to operation of the sump pumps.
The Project indicates that in striving for consistent application of criteria, they did not recognize the non-conservative position with regard to leakage detection.
This same scenario could exist in several sumps in the ESF as well as the Auxiliary and Fuel Buildings.
The Project will recommend in a letter to the client by September 30, 1985 that as part of the Emergency Operating Procedures that these sump pumps be placed in the "off" position. This would obviate the concern of unmonitored pumping while making the level switches effective in detecting all sizes of leakage paths.
A Report of a Problem (ROAP) has been written to alert other projects of this concern, and to further assess the safety significance of the issue.
This final assessment will be completed by October 31, 1985.
A memo by the Project Engineer to all project engineering personnel alerting them to situations where worst case failure analyses may not always be the 4-10
bounding case.
Erch eituation must ba evaluated on a cese by case basis to establish the appropriate bounding cases.
This issue has two potential areas of significance:
a.
For small leaks the automatic operation of the sump pump would render the leakage detection ineffective, b.
The prevailing control system for the sump pumps would allow for the potential unmonitored pumping of containment sump leakage to the waste holding tanks in the Waste Disposal Building.
This A0 issue has been adequately resolved and will be considered closed upon issuing the above mentioned letter to the client and completing the final assessment of safety significance also mentioned above.
8.
"The ability to meet the commitment to maintain subatmospheric conditions in the containment for 30 days when considering single failure of the outside isolation valve, although later demonstrated to meet this commitment, did not appear to be an initial design consideration (Action Item P-026)."
Action Item P-026 (Single Failure Consideration of CIV)
Initial concern was expressed by the auditors over the project design approach of utilizing non-spring or weight loaded check valves as the inboard containment isolation valve on several GDC 56 penetrations and their potential negative impact on containment repressurization in the long or short term.
(Containment is designed to remain subatmospheric for 30 days af ter the accident)
Additionally, concern was expressed that the project was not previously aware of this potential anomaly.
The project supplied notes of conference dated August 30 and September 29, 1977, where this design facet was actively discussed and adopted with the concurrence of the utility. What could not be presented to the auditor was documentation that a detailed analysis by penetration substantiating the statement that "a single active failure or a single passive failure cannot cause the containment to become atmospheric in either the short or long term."
A study by the project of all similar penetrations has substantiated the design as stipulated in the referenced notes of conference.
This acceptability is predicated on one of these design facets (1) existence of a static head of water on the check valve, (2) fluid backpressure on the check valve f rom a parallel source or, (3) constant inj ection flow through the valve.
This study is being verified by a systems engineer and will be completed by September 30, 1985.
There is no safety significance to this issue.
It is apparent that this was actively discussed in the design process and that given all potential single failures a negative pressure inside containment subsequent to the first hour is assured for a minimum of thirty days as supported by the above referenced study.
Concurrent with this EA Audit NUSCO received an NRC question (480.7) from the Containment Systems Branch regarding this specific topic.
The study referenced above is the basis for the intended response to this NRC 4-11
i question.
The formal project response to NRC qu2stion 480.7 will resolve j
the auditors concern and will adequately document in the FSAR the projects i
design basis for this CIV arrangement. This A0 issue is adequately resolved and will be considered closed with the project response to the NRC question due to be issued by September 30, 1985.
9.
" Problem Report PR-149 deals with overpressure protection to pump suction side when the suction pressure could be exceeded through back leakage.
For most safety related pumps, relief protection was provided.
However, relief valves were not added to the RSS.
Adequate justification for this arrangement has not been provided (Action Item P-027).
For non safety-related pumps the decision was made to add relief valves only when suction pressure through back leakage could exceed the pressure rating of any component even if the system design pressure, as indicated on the flow diagram, was exceeded.
This should be further evaluated against B31.1 (Action Item P-025)."
Each of these two above referenced Action Items will be addressed separately as follows:
Action Item P-027 (Pump Suction Overpressure - ASME)
The concern was raised as to why relief protection was not included at the suction of pumps 3RSS*P1A, B, C, D in accordance with the ASME III Code.
The Code states that relief valves are required on pump suction lines if the lines and attached equipment are not designed for the maximum pressure and temperature to which they may be accidentally or otherwise subjected.
This concern is one of code interpretation.
The project's position is that significant RSS pump suction overpressurization potential does not exist.
The basis for this position was correspondence between the Millstore Point 3 System Engineering Group during Proj ect and SWEC Boston Headquarters January 1985.
Based on the recommended corrective action provided in Proj ect Change Request (PCR) No. 890 dated Yovember 14, 1984, the RSS pumps were the only pumps that were deleted from the corrective action list per the correspondence referenced above.
Since this system is a unique ESF system in that it is normally dewatered and these are the only pumps and system effected by the January 1985 decision referenced above, this concern is considered an isolated case and no further preventive action by the project is required.
All participants involved in the January 1985 correspondence have also been involved and are informed of the resolution to this action item.
The safety significance of this issue is considered to be minor. The system normal alignment is open to the containment and empty (the system is dewatered after testing is performed). The potential for overpressurization can only exist during periodic pump or system testing when the system is water solid and under Technical Specification control.
The potential for overpressurization is further reduced based on the number of coincident conditions that would have to exist.
Potential sources of pressure could exist from either valve backleakage or system heat-up.
The potential source of valve backleakage pressure is from the residual heat removal system which in turn receives its pressure source from valve backleakage from the reactor coolant system. For this source of overpressure to occur a combination of 4-12
valva /pipa clignm:nts would have to assume tc leak and other valve / pipe alignments which could relieve the pressure are assumed not to leak.
The potential source of system heat-up pressure is from the test medium which is refueling water storage tank (RWST) water maintained at a temperature between 46-48 F.
After the performance test is completed and prior to dewatering, this RWST water in the RSS system will begin to heat-up toward the higher building ambient temperature.
Both of these sources are time dependent and only can cause overpressurization when the RSS system is water solid and isolated.
Normal operator action would be expected to take place prior to the existence of any potential overpressurization concern from either of the above sources. Also, it is believed that adequate air pockets in the system due to the piping configuration would exist to further preclude pressure buildup. Based on the above discussion it is the Trojects position that significant RSS pump suction overpressurization potential does not exist. This difference in code interpretation was reviewed by the Power Division at SWEC Boston office. Their position as well as the auditor's is that relief valves should be added to the RSS pump suction lines for strict ASME III Code compliance.
It was also their position as well as the auditors that there is no significant safety hazard involved if relief valves were not added based on the discussion provided above.
As a result of the above direction the project has recommended to NUSCO that relief valves be added to the RSS pump suction lines. This is documented in PCR S-1002.
Based on this Project action this A0 issue is adequately resolved pending NUSCO action.
Action Item P-025 (Pump Suction Overpressure - ANSI)
The Project does not utilize relief valves as it has designed the lines and attached equipment for the maximum pressure to which they may accidentally or otherwise by subjected.
For this case the maximum pressure (upset condition) is established by the relief valve set point of 50psig located on the discharge sfde of pumps, 3PGS - P2A&B.
The Project satisfies the following code requirements:
1)
The pressure / temperature ratings identified by the applicable pipe class in Piping Specification 582 are not exceeded by the maximum pressure and coincident temperature.
(All components included in the l
pipe class are designed to the pressure / temperature ratings indicated for that pipe class.)
l 2)
All components not included in the pipe class are designed to the maximum pressure and coincident temperature that the system may accidentally or otherwise be subjected.
3)
The allowable S-values in Para 102.2.4 are not exceeded when considering the maximum expected pressure during the variation.
An evaluation of the pump suction piping system for pumps (3PGS-P2A&B),
based on the above requirements has been performed by the audit team.
The results of that evaluation are the suction pipe and attached equipment are designed for the maximum pressure to which they may accidentally or otherwise be subjected.
Specific components evaluated included piping, valves, and pump suction.
Based on the above evaluation, this A0 issue is adequately resolved and is considered closed with no further project action required.
4-13 l
10.
"The SDP idsntified certain revisions of flow diagrams.
- Howsver, calculations (e.g.,
NP, NP(B)7902, NP(B)7912) prepared after the SDP was issued refer to earlier revisions than those specified in the SDP.
(Action Item P-033)"
Action Item P-033 The Project is investigating this condition and the response to this concern is forthcoming.
11.
"A Change Notice to the FSAR was generated to re-define passive failure.
However, sections 1.8 and 1.9 of the FSAR have not been changed to reflect that this is an exception to Regulatory Guide 1.89.
The acceptability of this exception needs to be evaluated further (Action Item P-004)."
Action Item P-004 (Effects of Passive Failures on the ECCS Performance)
A primary function of RG 1.89 is to provide guidance as to how plant equipment be designed to accommodate the effects of environmental conditions.
With regard to the initial concern which was to determine if environmental conditions resulting from a passive failure should be considered as a i
radiation source, a review was made of NUREG-0588, Rev. 1 " Interim Staff i
Position on Environmental Qualification of Safety-Related Electrical Equipment". A review of Appendix D " Sample Calculation and Type Methodology for Radiation Qualification Dose" of NUREG-0588 was performed. On page D-8 under " Equipment Outside Containment" two radiation sources were considered in the calculation.
One source was from within the containment and the l
other was from the fluid being circulated in the piping outside containment.
This approach is consistent with RG 1.89 requirements and the proj ect Environmental Qualification of Electrical Equipment Report Section 2.1.4, item (11). The calculation did not consider radiation sources from passive failures.
The calculation also was used to illustrate the proposed NRC model for calculating dose rates and integrated doses for equipment l
qualification purposes.
FSAR Section 3.1.1.3 describes the methodology utilized for postulating and accessing the effects of passive failures in all safety related systems.
This is intended to establish and to verify the design adequacy from a system performance perspective directly and to demonstrate adequate protection and separation of redundant trains for the postulated effects of flooding.
The licensing change notice (Request No. Am 15-26) generated and submitted in response to P-004 is intended to clarify the scope of application of single (passive) failures in safety related systems for evaluation of a I
system's ability to perform its intended safety function for enhancement purposes only.
The clarification is intended to clearly state that when performing passive component failures as part of the long-term single failure analysis, the project considers the performance effects on the system functional design requirements and the environmental effects on the system components from flooding.
4-14
With the clarification provided for enhancem:nt purposes by the licensing change notice issued by the Project it is clear as to what environmental effects (flooding) are considered with regard to passive component failures.
Based on the above additional evaluation, it is concluded that the Project is in compliance with RG 1.89 requirements with regard to consideration of radiation sources for equipment located outside containment.
Therefore, there is no need for the project to take an exception to RG 1.89.
This A0 issue is adequately resolved and is considered closed.
No additional Project action is required.
12.
Action Item P-024 (Non-seismic Instruments on Group A Tubing and Skids)
The concern was raised that instrumentation specification C943 appeared to allow the installation of non-seismic instruments in safety related systems.
A review performed by the Proj ect, identified a single instance where, because of the existing interface between flow diagrams and tubing isometrics, an administrative step could have been bypassed due to not adequately conveying the design intent which is to isolate the non-seismic instrument during all operating conditions except for testing.
Based on this review it is considered an isolated case.
This particular design interface only occurs in heating, ventilating, and air conditioning (HVAC) systems and any combination of instrument failures would not obviate the design intent of the system.
In this particular case the project knowingly procured a non-seismic instrument in order to meet RG 1.52 testing requirements but because the SWEC flow diagram standards for HVAC syste:ns does not include root valves, the design intent to isolate the instrument except during testing is not clearly conveyed.
An E6DCR has been issued against the FSK to advise that the design intent is to close the subject root valve except during testing.
The safety significance of this item is considered minor.
The failure of these low pressure HVAC instruments under a seismic event while unisolated could have resulted in an insignificant bypass flow around the ESF filtration system.
This Action Item has been adequately resolved and is considered closed.
4.4.2 Calculations (A0 12179-165)
This A0 addresses two issues.
The first involves a review of Power division calculations as part of the original audit calculation scope.
The second involves calculations required to support design data included in E&DCRs. Each of thsse issues are addressed in detail below.
A0 12179-165 identified concerns in Power calculations (Action Items P-007, P-009, F-Oli and P-012).
(Note that Action Item P-Oli has also been discussed previously under A0 12179-164).
In order to evaluate the potential extent of the concerns and bound the issue, the Proj ect selected and reviewed approximately 40 calculations for similar conditions. Additional reviews by the Project are in process. The selection was based on four sets of calculation types defined by the auditors based on the types of calculations reviewed during the audit (orifice sizing, set-points, NPSH, and system design pressure). The sample was also varied to include 4-15 4
l calculations that were prepared and reviewed by the preparers and reviewers of tha calculations identified in the A0 and to include a random selection of calculations prepared and reviewed by other project power engineers.
From their review, the Project concluded that the conclusions of the calculations era acceptable and the calculations are technically adequate.
The Proj ects review resulted in comments on four of the 40 calculations.
For example:
one comment was the calculation referenced a superseded calculation.
However, the results of the superseded calculation were not used and therefore had no impact on the reviewed calculation.
In order to verify the Proj ects conclusion, ten of the 40 calculations were celected for in-depth review by the audit team of which three related to NPSH and seven to setpoints.
Brsed on the Project's review and the review performed by the audit team there is no indication of generic concern regarding the technical adequacy of the calculations.
In reaching this determination consideration was given to the conditia. observed:
incomplete documentation in some calculations; assumptions not always stated; judgements made, although in most cases determined to be reasonable, were not always explicit; input data not always adequately documented; and instrument range setpoint overlap.
In some instances calculations were performed to obtain order of magnitude results but this intent wts not readily apparent without assessing the overall system design.
Each of the above aspects, when considering the system design function, are in general, relatively minor as is discussed in detail below.
As a result of this audit review it is recommended that the Power Division provide training in calculation preparation for the MP-3 project Power division sngineering personnel. The Power Division has agreed to implement this training program during October 1985.
The completion of the calculation review by the Proj ect and the implementation of a training program should satisfactorily resolve most of the items in this AO.
The detailed results of the 10 calculations reviewed by the audit team are as follows:
1.
Calculation 1062(R), "NPSHA to 3QSS*P3 A, B" The objective of the calculation is to verify the adequacy of the NPSH available.
The calculation satisfies all the EA requirements with respect to reviews, markings, indication on confirmation requirements, etc.
The assumptions are reasonable and justified and the inputs used are correct and justified.
The method is correct and the conclusion is in line with the objective of the calculation. Therefore, the calculation is adequate.
2.
Calculation P(T), 1027 "Cooldown of FWS Lines After a Plant Trip" The purpose of the calculation is "to determine if the steam generator cooldown rate by auxiliary feedwater is faster than the cooldown rate of a stagnant feedwater line upstream of the auxiliary feedwater inlet."
The calculation instead determined whether the rate of cooldown rate of the stagnant feedwater lines is lower than a steam generator cooldown rate of 50 F/hr. From conversations with the Project it appears that the purpose of the calculation was to determine if flashing could take place in the feedwater line as a result of a decrease in pressure in the steam generator and feedwater line due to actuation of feedwater injection.
4-16
The calculation eatisfies all the EA requiramants with respect to ravicws, 1
markings, indication of confirmation requirements.
No assumptions are spelled out in the calculation.
The method used in the calculation to determine the approximate cooldown rate of the feedwater line is correct.
However, the heat transfer coefficients used between the feedwater and pipe wall and between the outside insulation temperature and the air were not properly justified.
The results of the calculation indicates that conditions for flashing exist, a condition that required further analysis as a follow-up.
The lack of adequate documentation or the significance of the heat transfer coefficient therefore, has no negative impact.
3.
Calculation SP-3SWP-20 "3SWP-FS59A, B,
C, D Flow Switch for Service Water Supplying Containment Recirculation Cooler" The objective of the calculation is to determine setpoints for the flow switches in order to alert the operator when the amount of service water going to the containment recirculation coolers is too high or too low.
The calculation satisfies all the Engineering Assurance requirements with respect to reviews, markings, indication on confirmation requirements.
The determination of the setpoint for the high flow is based on the manufacturers limitation.
The determination of the setpoint for the low flow is made by engineering judgement which is reasonable and adequate for the system design application.
4.
Calculation SP-2RHS-4, "3RHS*RV8708A, B Relief Valve Setpoint" The calculation objective is to essentially justify the setpoint of the relief valve as provided by Westinghouse. The calculation satisfies all the Engineering Assurance requirements with respect to reviews, markings, indications on confirmation requirements, etc.
No assumptions are required to be made. The inputs are correct and justified.
The method utilized is consistant and in agreement with the code related design criteria discussed in Action Items P-011 and P-018 in Section 6.4.1.2 with regard to pump shut off being an un upset service condition is correct.
Although the relief capacity is not addressed in the calculation, documents supplied by Westinghouse have been shewn to the reviewer, justifying the adequacy of the relief capacity. The calculation is acceptable.
5.
Calculation SP-3SIL-1, " Set Pressure of 3SIL*RV8856A, 3SIL*RV8856B and 3SIL*RV8842" The calculation's objective is to determine the setpoint for the above described relief valves.
The setpoint is supplied by Westinghouse.
The calculation adjusts the setpoint for conditions on the discharge piping of the relief valves.
The calculation satisfies all the requirements of Engineering Assurance with respect to reviews, markings, indication on confirmation requirements, etc.
The inputs are correct and justified.
The method is also adequate.
6.
Calculation SP-3CCP-7, "3CCP-FSS62 A/B Actuation Point" The objective of the calculation is to initiate an alarm when flow through the RHR pump seal cooler is low.
The calculation satisfies all the Engineering Assurance requirements with respect to reviews, marking, indication of confirmation requirements. The setpoint is chosen by 4-17
engineering judgement 15% below the value recommended by the pump manufacturer for normal flow. While the judgement appears reasonable, if a setpoint below the recommended normal flow is chosen, it is appropriate to obtain the explicit consent of the pump manufacturer.
The proj ect will obtain concurrence from the manufacturer by October 31, 1985.
7.
Calculation SP-3CCP-18, "3CCP*LS25 A/B and 3CCP*LS196A/B, Reactor Plant Component Cooling System Surge Tank Low Level Actuation Point" The objective of the calculation is to determine setpoints for the level switches given above to initiate closure of various valves on low component cooling water surge tank level.
The calculation satisfies all the Engineering Assurance requirements with respect to reviews, markings, indication on confirmation requirements.
No assumptions are required to be made.
Inputs to the calculation are correct and justified.
The method described is correct and proper consideration is given to the instrument accuracy.
In the final determination of the setpoint for the level switches the setpoint is chosen at such a level (83") that the level range of actuation (setpoint and accuracy) of the instruments involved can overlap with the level range of actuation of level switch, 3CCP-LS234A/B, setpoint 112" which initiates a low level alarm. As a result, the initiation of the valves closure can be started before 3CCP-LS234A/B, can alert the operator through the low level alarm, that the level is below normal. The potential overlap, however, has no impact f rom a safety point of view, for the low level alarm is not safety relatednor does it provide any safety function.
In addition, given the accuracy used to determine the setpoint of the instruments involved is !27", an accuracy developed which takes into account the worst possible environmental conditions, the probability of overlap with level switches 3CCP-LS234A/B is considered negligible.
8.
Calculation SP-RSS-6, " Shut-off Switch for RSS Dewatering Pumps, 3RSS-P2A, B, 3RSS-PS41A, B" The objective of the calculation is to determine a setpoint for 3RSS-PS41A, B to trip dewatering pumps 3RSS-P2A, B when the RSS system piping is fully dewatered.
No assumptions are required to be made and the inputs are adequately justified.
A margin of 10% added to the friction losses of the pump suction pipe results in a setpoint to stop the dewatering pump that might not be reached.
However, the operational characteristics of the system are such that the setpoint must be field calibrated during preoperational testing.
The calculated setpoint becomes a first order approximation and is adequate for its intended purpose.
9.
Calculation P(R)-0981, "Effect of Short Radius Elbows in Suction Piping to 3RHS*RlB on NPSH" The calculations purpose is to verify adequate NPSH at the residual heat 8
removal pump, 3RES*PlB.
The calculation satisfies all requirements of Engineering Assurance with respect to reviews, markings, indications on confirmation requirements, etc.
The only assumption made is adequate and the inputs are also adequately justified.
In addition, the method for determining the NPSH is correct and the results are satisfactory.
4-18
10.
Calculation SP-3EGF-ll, "3EGF*LS40A/B High Oil Level Switch for 3EGF*TK2A/B Trips 3EGF*PlA/B" The purpose of the calculation is to provide setpoints for level switches 3EGF*LS40A/B to stop Emergency Diesel Generator Lead Fuel Oil Transfer Pump 3EGF*PlA/B on a high oil level in day tank, 3EGF*TK2AIB and to start the pumps on low fuel oil level. The calculation satisfies all the Engineering Assurance requirements with respect to reviews, marking, indications on confirmation requirements, etc.
One assumption made concerning level switch accuracy requires confirmation by the switches manufacturer.
The calculation is appropriately marked as requiring this confirmation.
The method is correct.
Pending the confirmation requirements, the conclusion supports the objective. Therefore, the calculation is adequate.
A0 12179-165 also addressed the case were a calculation was not available that determined the relief capacity of the relief valves discussed in an E&DCR (T-C-02358) (Action Item P-023).
It has been determined that an earlier E&DCR (T-P-01656) was originally issued to add a deaerated source of water to the condensate pump suction.
This included the addition of 3CWM-RV110A, B, C and 3CWM-PCV-109. The technical data sheet for PCV-109 indicates that flow is to be controlled between 10 and 15 gpm.
The required capacity for the relief valve was originally set at 15 gpm to agree with the maximum value of the control range.
With regard to E&DCR T-C-02358, the purpose for this E6DCR was only to increase the size of the relief valve from 3/4" x 1" to 1 1/2" x 2".
This was a result of the vendor determining that based on tha flow and pressure conditions of the original data sheet, a larger size valve then originally planned was required.
This is a normal and expected interface between purchaser and vendor.
Therefore, a calculation to support E&DCR T-C-02358 was not required as the change was a direct result of the vendor data.
However, a subsequent calculation requested by the auditor to substantiate the original capacity of the relief valve on E&DCR T-C-01656 indicates that with the PCV failing fully open in accordance with the code, 21.3 gpm will be required to pass through the relief valve, instead of the dati sheet value of 15gpm.
The relief valve size as revised by E&DCR T-C-02:J8 will actually pass 31.7 gpm, easily satisfying the original and subsequent calculational requirement of 15 and 21.3 gpm respectively.
A sampling of calculations were reviewed by the proiect to determine that the basis for relief valve capacity sizing is consistent with overpressure code requirements and was adequately defined on the valve technical data sheet.
The results of this project review confirmed code compliance.
In addition, the relief valve purchase specification indicates consistency between the calculated relief valve capacities and the valve technical data sheet, indicating that the above case is an isolated occurrence.
A memo will be issued from the lead Power engineer by September 30, 1985 to all power engineers stating that calculations shall be performed in sizing new relief valves and results should reflect that data submitted to the valve vendor.
The relief valve is used in a non-safety related application and the actual flow which the relief valve can pass is greater than the maximum flow it will be required to pass to satisfy code requirements, therefore, this item is of little significance.
Since the system is non-safety related and the technical requirements have been fulfilled by the purchased equipment, no corrective action 4-19
is n:ccccery.. Bae:d on this cces2Em:nt this A0 issus is conzidsrsd.to bs of t:inor significance. This A0 issue is adequately resolved and will be closed upon ti.o Project issuing the previous mentioned memo.
\\
A0.'2179-165 also addressed an instance where periodic calculation reviews, as raquired by Power Division Technical Procedure PTP 11.1, were not performed (Action Item P-007).
The Project had requested a deviation to PTP 11.1.
The Proj ect has indicated that the reviews will be performed as part of the confirmation process as outlined in the request.
This item will remain open p:nding agreement between the Project and Power Division.
b 4-20
4.5 Structural (A0 12179-166)
A0 12179-166 addresses the following concerns:
Item 1 - lack of evaluation for thtrmal effects due to welded end connections in steel framing designs (Action Item S-051); Item 2 - lack of evaluations or calculations to demonstrate doors can withstand the internal water pressure (Action Item S-048); Item 3 -
inconsistent design requiremente for structurcl rroci cert.ccticre (bccript terrte friction) (Action Item S-050); Item t. - it.c crt rte cort.r.u.tatf or. cf celculations I
to substantiate the missile shield doors design for the effect of tornado (Action Item S-047); and Item 5 - lack of review or incorporation of pipe rupture loads in building designs (Action Iter S-046).
E&DCL F-S-43527 which clarifies the rec;circt cr.ts of s teel cor.rcctict. cecitt s las bssn issued.
It has been verified that ttoc: ccr.r.cet M
(( cia t Im Ec cr.
consistently and correctly implemented by the fabricator. This determination is b2ged upon a review performed by the Project and the auditor for eight connection dssigns for various buildings.
No inconsistancies exist in the above designs.
Thsrefore, Item 3 of this Audit Observation (Action Item S-050) is considered closed.
In response to Item 4 (support design for missile shield doors)of this Audit Observation, the Project has located calculations S-13 and S-34.
A general rsview of these calculations indicates that complete documentation has been established for anchorage supports (Calculation S-34) due to tornado wind and prassure drop condition.
In addition, shield doors analysis (Calculation S-13) covers all 3 inch thick steel doors shown on design drawings for the effect of wind and missile impact due to tornado.
Also, E&DCR P-S-3545 was reviewed to varify the required modification to the four doors in the Control Building.
It win implemented satisfactorily. However, questions were raised during the review of calculation S-13 that must be addressed prior to satisfactory closure of this itam. The Project is presently addressing the questions.
In response to item 2 (doors are capable of withstanding internal water pressure) of this Audit Observation, the project indicated that the extent of condition was limited to three doors. Doors SF 21/3 and SF 21/4 are not required to withstand thz hydrostatic load and that a change to drawing EM-60B for flood boundary is in progress. Door SF 21/2 was evaluated by the project in Calculation S-44 and was found by the auditor to be adequate and complete in documentation.
This door rsquires supplemental anchorage for bottom hinge and latch as initiated by E&DCR T-S-07207.
This item will remain open until changes to EM-60B and E&DCR T-S-07207 are received and reviewed by the auditor.
In addition, the Project has bsen requested to evaluate the significance of this condition had the condition gone undetected.
The project has responded to item 1 (thermal effects on welded end connections) cnd has indicated that investigations to determine the extent of the condition will be complete by September 30, 1985..The results of the investigations will b2 provided to the auditor for review.
In regard to Item 5 (pipe rupture loads included in building design) the Project h:s indicated that all responses and Project actions will be included or part of Audit Observation 171, Item I 10.
See section 4.7 for current status of this item.
4-21
i 4.6 Equip 2 int Qualification 4.6.1 Environmental Qualification Program During the NRC review of the results of the environmental qualification portion cf the audit it was agreed that in order to better assess the Project's environmental qualification program, the selected list of equipment was expanded to include a more varied sample in a harsh environment. The following additional itsms were reviewed:
1.
3CCP*MOV48A,B - Containment isolation motor operated valves.
2.
3CCP*SOV178A,B,C,D - Solenoid valves for Reactor Coolant pump thermal barrier.
3.
3CES*AV8143 - Excess letdown volume control tank limit switch.
4.
3RCS*PT403 - RCS wide range loop 4 hot leg pressure transmitter (R.G. 1.97) 5.
3RCS*TE413C - RCS side range loop / hot let temperature RTD.
6.
Low Voltage Heat shrinkable field cable splicing system (Raychem type WCSF-N).
7.
3RCP*E7V - Electrical Penetration (vault side).
For each item the following project qualification documentation was reviewed:
1.
FSAR 2.
NETM Environmental Design Conditions 3.
Purchase Specification 4.
Vendor Test Reports 5.
Environmental Qualification Packages 6.
Vendor Drawings 7.
SWEC Drawings 8.
Installation Specifications In addition, a field walkdown was conducted to verify that the installed squipment was as specified, and traceable to the equipment identified in the test t
rsports.
Th2 audit review for the additional equipment items was conducted in the same manner as the audit review for equipment described in Section 6.6 of Reference 1.
To demonstrate that the motor operated valves 3CCP*MOV48A and B are qualified for th2 expected environment, the
- FSAR, NETM-26 and purchase specification 2362.200-164 were reviewed to identify the environmental and other specific chnracteristics of the device.
The vendor test report B0058, Appendix 6 was rsviewed to verify that the tested device envelopes the specified chsracteristics. This review was conducted using the environmental qualification 4-22
chseklist which is part of the EQ package for this specification, vendor drawings, SWEC drawings and installation specification and indicated that the dzvice was acceptable, including confirmation from vendor of minimum voltage (70%) capability of handling the required loads.
During the checklist review against the vendor test report, minor checklist discrepancies in the referenced sections and pages of the test report were identified and Action Item E-045 was issued.
The Proj ect indicated that they are in the process of reviewing and updating all checklists and agreed to complete this task by November 1, 1985.
To demonstrate that the solenoid valves 3CCP*SOV178 A, P, C and D are qualified for the expected environment, the FSAR, NETM-26 and purchase specification 2472.110-185 was reviewed to identify the environmental and other specific characteristics of the device.
The vendor test report AQR067368, Rev. 0 was reviewed to verify that the tested device envelopes the specified chsracteristics. This review was conducted using the environmental qualification chacklist which is part of the EQ package for this specification, vendor drawings, SWEC drawings and installation specification and indicated that the dsvice was acceptable.
Minor discrepancies in recorded values from the test report were identified in the SCEW sheets and Action Item E-043 was issued. The Project has agreed to conduct a review of the SCEW sheets and revise those found in error by November 1, 1985.
To demonstrate that the limit switches for the air operated valve 3CHS*AV 8143 ars qualified for the expected environment, the FSAR, NETM-26 and purchase specification 2472.110-185 was reviewed to identify the characteristics of the dsvice.
The vendor test report NAMCO QTR-105 was reviewed to verify that the tasted device envelopes the specified characteristics. This review was conducted using the environmental qualification checklist which is part of the EQ package for this specification, vendor drawings, SWEC drawings and installation epacification and indicated that the device was acceptable.
To maintain qualification the conduit connecting to the device must be sealed.
During the field walkdown, it was confirmed that a Litton Veam sealing connector was provided for sealing.
To demonstrate that the pressure transmitter 3RCS*PT403 is qualified for the expected evironment, FSAR, NETM-26 and purchase specification 2472.510-662 was reviewed to identify the environmental and other specific characteristics of the dtvice. The vendor test report D8300040, Rev. B was reviewed to verify that the tested device envelopes the specified characteristics.
This review, including accuracy requirements, was conducted using the environmental qualification chscklist which is part of the EQ package for this specification, vendor drewings, SWEC drawings and installation specification, and indicated that the dsvice was acceptable.
The device is included in a Westinghouse instrumentation loop, and the project has confirmed in their response to Action Item E-047 that tha accuracy specified as (4.5%URL & 3%of span) during LOCA/HELB was included by Wastinghouse in the setpoint calculation.
This instrument is also used and qualified for post accident monitoring (R.G. 1.97).
To maintain qualification the device must be sealed, and its 0-ring be replaced if housing cover is removed during maintenance.
This was verified during the field walkdown when a Litton VGam sealing connector was found installed for sealing.
To demonstrate that the temperature element (RTD) 3RCS*TE413C is qualified for tha expected environment, the
- FSAR, NETM-26 and purchase specification 2472.310-683 was reviewed to identify the environmental and other specific characteristics of the device.
The vendor test report 548-8854-2, Rev. B was reviewed to verify that the tested device envelopes the specified characteristics. During the review a relationship could not be established 4-23
batwssn the actual Model No. of the dtvic.e and the Model No. of the samples tasted and ' Action Item E044 was issued.
The project contacted the vendor, who provided the necessary link by indicating that a change in Model Nos. from 612 to a 9000 series t?ok place in the later part of 1983, while the qualification report was issued in 1981.
This review was conducted using the environment qualification checklist which is part of the EQ package for this specification, vendor drawings, SWEC drawings and installation specification and indicated that the device was accegtable. The accuracy drif t identified during testing would be maintained within 1 F, if the device is recalibrated after 5 years, and every 10 ysers thereafter.
In order for the device to be protected against accident conditions inside containment, an environmental seal should be installed in the conduit inlet, and the RTD terminals should be patted liberally with the sealant, During the walkdown the RTD head was not opened to observe the sealing, however this was confirmed from the inspection reports.
4 To demonstrate that the low voltages heat shrinkable field splicing system (Raychem type WCSF-N) is qualified for installation in all plant areas, NETM-26 was reviewed to identify the worst environmental requirements inside containment.
The vendor test reports EDR-2001
-5009, -5046, -5040 and -5015, as well as the i
Wyle test reports 58442-1,
-3, and 58722-2 were reviewed to verify that the tasted samples envelop the specified characteristics. The review indicated that tha splicing system (type WCSF-N) is acceptable having a qualified life of 40 yaars with cable conductors at r ntinu us rated temperatuge of 90 C.
The 8
rcdiation difference between 2.3x10 rads specified and 2.9x10 rads max. tested prasents no problem since all Category I splices are located either inside equipment or inside metal boxes as indicated on drawings, thus reducing the Sptcified radiation requirements to 7.46x10 rads.
The bolt padding material (type WCSF-U) used with certain splices, is also qualified as indicated in the vsndor test reports.
Some discrepancies were identified in the SCEW sheets, such as the referenced qualification reports on p.3 and the missing reference to the bolt pad material type WCSF-U.
In addition, the SCEW sheets for the high voltage aplicing materials Type BBlT, SCTM and HVTM were missing from the E.Q. Packages, Action Item E-048 was issued to cover these items, and the project advised that z
corrective action will take place before November 1, 1985.
To demonstrate that the electrical penetration 3RCP*E7V containing safety related circuits is qualified for the expected environment, the FSAR, NETM-26 and purchase specification 2412.100-247 was reviewod to identify the environmental and other specific characteristics of the
- Lee.
The vendor test reports IPS-927, IPS-585.3 and IPS-158 were review 1 t verify that the tested device envelopes the specified characteristice.
hir review was conducted using the snvironmental qualification checklist W m 1
- art of the EQ package for this spscification, vendor
- drawing, SWEG drawing and vendor installation sp2cification, and indicated that the device was acceptable.
The penetration rsquires only that it remains sealed by maintaining a minimum pressure of 5 psig which should be monitored peridocially, and a " lifetime record" of these readings k:pt.
During walkdown it was observed that the penetration circuit pigtails located inside the containment were butt spliced instead of using terminal blocks, and the splices enclosed in a housing.
During the audit, a review of test reports (Pacific, Pratt and Limitorque) for cartain motor operated valves (MOVs) demonstrated that MOVs will properly function under a harsh environment at normal voltage and in a mild environment at rsduced (70%) voltage.
However, follow-up review was expanded to include' MOVs furnished by other vendors to ensure that the environmental qualification of those MOVs and the supporting documentation demonstrate the MOVs will function as 4
rgquired under reduced voltage conditions consistent with the FSAR, design 4-24
commitments end specificctions.
The raview included motor operated valves furnished by Walworth (3RCS*MOV8000A and B) and Westinghouse.
The review rsvealed that the valve operators furnished by Limitorque for use with all Walworth and Westinghouse valves are sized to handle the required loads at 80% of rated voltage, in accordance with the design commitments and specifications.
Since the FSAR indicates that all motors are capable of operating at 70% volts, except where otherwise justified, Action Item E-046 was issued to request this justification.
The project indicated the certain Westinghouse valve operations rated at 80% volts will be exposed to the 70% voltage conditions for a very short psriod of time (5 seconds), and this only during a slow transfer concurrent with LOCA. This short period of dagraded voltage will cause ann additional time delay of approximately 5 seconds to the valve stroke time.
This time delay will have no impact on plant operation or safety, as indicated by Westinghouse.
In addition, exposure of the valve operator to 70% volts for 5 seconds will not drmage the electrical operator, as indicated by Limitorque.
This justification is adequate and the Action Item E-046 is closed.
The maintenance requirements to maintain qualification in addition to those specifically mentioned for each item were reviewed and found adequate.
These rsquirements were also included in the Plant Electrical Equipment Qualification Maintenance Books.
The field walkdown also confirmed that the installed squipment was as specified and was located above the flood level of (-) 10'-8".
Splices however, were tested immersed in water with all specimens passing the test, indicating that they could operate submerged.
It is, therefore, concluded that the selected additional safety related equipment items located in harsh environment are qualified to perform their intended safety function in the expected normal and accident environments and operate for the epscified time following an accident. It is also concluded that the Proj ect's Environmental Qualification Program is adequate and that the implementation of tha Program is generally satisfactory.
4.6.2 Environmental Conditions, Supporting Analyses (A0 12179-167)
Item 1A of this A0 addressed the lack of sensitivity analysis to calculate the harsh environment in the MSVB for the postulated breaks (Action Item R-007). The Project was also asked to evaluate the potential extent of the condition.
The Project has committed to evaluate a main steam line break in the roadway canopy between the main steam valve building (MSVB) and turbine building to datermine the resultant pressure and temperature in the MSVB. This evaluation is panding definition of the maximum break opening area for this break by the Engineering Mechanics group.
The calculation that evaluated the piping restraints must be reviewed to identify the piping displacements, which can then bs used to determine the break opening area.
After obtaining this area, the Nuclear Technology group will determine the razultant pressure and tenperature in the MSVB using the same method as was used to evaluate a main steam line break within the MSVB (reference calculation 12179-US(B)-256, revision 1).
The results will then be evaluated to determine any impact on the current environmental conditions in the MSVB.
Tha potential for high energy line breaks affecting plant areas adjacent to the building containing the break was reviewed by the Project in response to Problem Raport NT-2, "High Energy Line Breaks Environmental Analysis".
All cases idIntified at that time led to sealing off the potentially affected area from the break effects.
4-25
The final documsntation of Problem Raport NT-2 will include a review of l
postulated high energy line breaks for potential impact on adjacent plant areas.
('
This review will verify that the limiting high energy line break has been used to dstermine the environmental conditions for each applicable plant area.
The review is scheduled to be complete by October 7, 1985.
L' Tha bounding of the concern also involves verifying that the worst case break and break locations were analyzed in the calculation of environmental conditions in those areas ' directly subject to a HELB.
Outside of the containment building thase areas are the fuel building, main steam valve building, turbine building, and auxiliary building excluding the MCC/ Rod Drive.
The calculations for the i
environmental conditions for these areas are all indicated as " Confirmation 1
Rsquired".
Tha Project has proposed that the confirmation process include verification that ths analyzed breaks result in the most severe environmental conditions for each zone in these areas. This review and verification will be documented in'a calculation revision, if necessary, or a memorandum written to the calculation file. -Additional analysis will be performed for additional break cases, if nzcessary based on review of the calculation during the confirmation process, to ensure the limiting environmental conditions are determined for each area of the 4
plant.
Th2 proposed course of action is considered satisfactoy provided:
l 1.
The calculations are clearly marked as to why confirmation is required, and j
2.
The Project's procedure describes the necessary steps, specific to these type calculations, for carrying out this confirmation process.
A revised Project response addressing the above is required.
i i
Item lb deals with the lack of documentation available to justify lack of high or moderate energy line break analysis for the ESF building (and potentially other areas).
(Action Item R-009).
- Thz - Proj ect has indicated that the justification of lack of high or moderate ansrgy line breaks will be confirmed as part of the closecut of Nuclear Tachnology calculations which the Power Group will be involved with. The Power group will address all structures with equipment covered by NETM-26. This effort-4 will be done in parallel with the structures / system review for the closeout of ths Hazards Program. The Project does not anticipate any changes in input data.
~This approach seems-reasonable provided the closeout of Nuclear Technology calculations is clearly deacribed in Proj ect procedures.
A revised Project response is required.
Tha concern expressed in Item 2 (Action Item P-029) of the A0 was that it is not apparent how local environmental conditions for mechanical equipment are addressed since the environmental conditions given the Proj ect procedure (NETM-26) are for bulk cubicle conditions. The Project is still evaluating this f
concern. A Project response to this item is required.
Item 3 (Action Item R-008) of the A0 discussed instances where calculations had bssn revised but the revised results had not been transmitted.
A review of calculations, concentrating on Nuclear Technology calculations, was performed by
+
the Project and two additional instances were identified, indicating a limited 4-26 1
i
candition. Thn chtnges wara saatsstd and found to hava no impact. Based on the actions'taken, this item is closed.
Itsa 4 of the A0 noted that some calculations had been superseded / voided but this was not reflected in the Project files (Acticn Item R-008).
The Project found this-to be an extensive condition.
The latest copy of the Nuclear Technology csiculation index was provided to Engineering Document Control (EDC).
EDC will raview each calculation in the files against the index.
This review has apparently been completed, but verification is required by the audit team.
Item 5 addressed the one instance in the calculations reviewed where the c=umptions and methodology required clarification (Action Item R-004).
This calculation has been revised to reflect the needed clarification.
This item is closed.
4.6.3 Seismic Qualification (A0s 12179-168 and 12179-169)
A0 12179-168 addresses the following concerns:
Calculation was marked as requiring confirmation of Saismic Analysis, RWST inputs but was not so indicated on the calculation index or in the discipline centrol listing.
Additionally, the calculation was marked
" confirmation rcquired" because of the use of an unqualified (dynamic) portion of computer l
-program ST-015.
There was no indication of schedule for qualification or i
bsnchmarking (Action Item J-014).
Dnta Transmittals - A review of CCP pump documentation revealed an apparent loss of load transmittal data from EDM-Mechanical to the Structural discipline (Action Item J-055).
Tha' Project has responded to the Seismic Analysis, RWST concern regarding confirmation marking of indexes or control listings and has found it exists on other EMD mechanical calculations.
The Project is in process of performing a 100% review of mechanical calculations against the indexes to correct the j
. condition. Completion is expected by September 30, 1985.
i Tha Project has not responded to the concern of the unqualified portion of the ST-015 computer program. A response is expected by October 1, 1985.
The Project has responded to the data transmittal concern and has concluded from a substantial review, that this is an isolated case.
Project has reviewed the
-cffected structural calculation and found the equipment anchorage capable of satisfying the transmitted loads. The Structural group is preparing a procedure for.providing consistent methods of documenting reviews of final loads received
'from EMD. The proposed NETM is expected to be issued by September 30, 1985.
A0 12179-169 includes items where cause,- extent and corrective and preventive cctions were addressed with the original Action Items and are continued for coJpletion of actions or commitments for the following concerns:
Item 1 - Table 3.10B-1.2 of the FSAR does not present data for RSS pump motors (Action Item
'J-054); Item 2 - Allowable stresses used in specifications not in agreement with FSAR, Table 3.9B-7 (Action Item J-052); Item 3-loads not in agreement with these in the structural calculation and nozzle load revisions not factored in EMD-Mechanical ~ and vendor calculations (Action Item J-058); Item 4 Proj ect prcctice not in conformance with NETM 49 for nozzle loads in excess of vendor allowables (Action Item J-051); Item 5 - documentation review for 3RSS*MOV23A, B, C, D 12" valve / torque tube / actuator system, revealed concerns on calculations 4-27
supporting dssign ch:nges (Action Itsm J-062); Item 6 - en expansion to the sxception to RG 1.48 is required in the FSAR as it only address piping systems (Action -Item J-059); Item 7 - EMD Mechanical calculations need review to assure r ferences to PSAS nozzle load calculations are valid and current (Action Item J-025); Item 8 - EMD Mechanical Calculation not complete to support licensing rarponse to NRC (Action Item J-017); Item 9 - holddown bolting missing from accumulator mounting associated with RSS Pump RSS*PlA (Action Item J-024); Item seismic analysis pump calculations do not address junction box 10 qualifications (Action Item E-030); Item 11 - several changes required to clarify wording in FSAR for jet impingement effects (Action Item J-009); and Item 12 -
equipment qualification review of nozzle loads on component qualification basis (Action Item J-015). As a result of the NRC review of August 26-30, 1985, Action Itim J-015 was added to A0169 as Item 13 to track issuance of a generic E&DCR egtinst design specifications in regard to Seismic Section Requirenents for ARS
'g' values to be used.
Tha Project has satisf actorily responded to Item 1 to update tables in the FSAR by October 14, 1985.
In response to Item 2, the Project has committed to complete a review of major active pumps to assure compliance for allowable stresses.
The results of the review are expected by the first of October.
Tha Project has responded to Item 3 that the completion of local system lord / responses (seismic) analysis and RSS pump confirmation, together with final structural load development is tied to the nozzle reconciliation program and is scheduled for completion by September 30, 1985. This response is acceptable.
Tha Project response to Item 4 on nozzle loads in excess of vendor allowables was to revise procedure NETM 49.
A review of NETM 49, Rev. 1 dated September 17, 1985 indicated that wording added in paragraph 2.7.2.c now assures responsibility for revised load acceptability.
Therefore, Item 4 of this Audit Observation (Action Item J-051) is considered closed.
The response to Item 5 indicates that the calculation for the floor stand support and the confirmation of bearing loads for the torque tube interface is tied to th2 nozzle reconciliations program and is scheduled for completion by September 30, 1985. This response is acceptable.
Tha Project response to Item 6 to revise tables to the FSAR is acceptable.
It was verified that Licensing Change Notice, LCN 701 was issued to amend Table 1.9-1 to provide clarification for noncompliance with SRP 3.9.2, and 1.8-1 to provide guidance and justification for the Regulatory Guide 1.48 exemptions.
Thsrefore, Item 6 of this Audit Observation (Action Item J-059) is considered c1csed.
.In response to Item 7, the Proj ect has indicated that revised loads will be trcnsmitted to the EMD Mechanical Section for evaluation and/or revision to the cited calculation.
This effort is tied to the nozzle reconciliation program and la scheduled for completion by September 30, 1985. This response is acceptable.
Tha Project response to Item 8 to perform a review of structural calculations to datermine if all calculations generated to support NRC questions in the FSAR are f
riviewed and approved was verified satisfactory (Action Item J-017).
It was also varified that calculation 652IZ on flexibility of Category I tanks under seismic loading was completed satisfactorily as it supports a licensing response.
Thsrefore Item 8 of this Audit Observation is considered closed.
4-28
Th2 raponts to Itzm 9 by the Proj ect indicates that the observation's extent (ditermined from a NNECO QC inspection), was that the same screw was missing on two of three remaining RSS pumps (besides RSS*PlA).
Because the pumps have all bun turned over to NNECO, a MP3 Deficiency Form has been initiated to replace the missing screws.
This concern (3 of 4 pumps) appears to be attributable to c::embly at the vendors shop as these screws were out of sight and not obvious from a review of drawings.
Therefore, Item 9 of this Audit Observation (Action Itsm J-029) is considered closed.
Th3 Project response to Item 10 indicated that calculations on seismic pump entlyses addressing junction box qualifications are complete and verified. E&DCR T-E-06806 was also reviewed and found satisfactory in showing that proposed rodifications to junction boxes have no effect on seismic qualification.
Thtrefore, Item 10 of this Audit Observation (Action Item E-30) is considered closed.
In regard to Item 11 (clarification of wording in FSAR for jet impingement effects) the Proj ect has indicated that all responses and Project actions are tracked under Audit Observation 171, Item 1.15.
See section 4.7 for current evaluation status of this item.
Item 11 (Action Item J-009) is considered closed for A0 12179-169.
Project response to Item 12 indicates that a review of PSAS calculations will be psrformed to determine if they have met allowable nozzle loads and that they are consistent with calculations, SDPs, and seismic qualification reports.
This is ccceptable and will be verified upon completion of the nozzle reconciliation program scheduled by September 30, 1985 (Action Item J-053).
It:m 13 resolution is premised upon issuance of a generic E6DCR against design spscifications on Seismic Section Requirements for revised ARS 'g' values, if r quired. The Project has not yet responded.
It is understood that the E&DCR is baing prepared and that a response should be received as soon as all ep2cifications of this category are identified.
Expected completion is early October.
4-29
4.7 Hezards Anslysis (A0s 12179-170, 12179-171, and 12175-172)
Ths review of the Project's hazard program generated concerns regarding:
1.
" Programmatic" concerns relating principally to level of documentation required for referenceability, traceability, etc. (discussed in detail in A0 12179-170 and in Section 4.7.1 below).
2.
Criteria interpretation, FSAR consistency, and implementation within the program (discussed in detail in A0 12179-171 and in Section 4.7.2 below).
3.
Flooding calculations (discussed in detail in A0 12179-172 and in section 4.7.3 below).
A follow-up review was conducted September 13 through 20, 1985 to evaluate the irplementation of corrective actions. The Hazard Review Program Summary document l
(Rezards Report) was reviewed to ascertain that the review, adequately
- criteria, documentation requirements and review and approval procedures were cddressed.
The implementation of the documentation aspects of the program was avsluated by selecting four areas of the plant for review (auxiliary feedwater pump cubicle, main steam valve house, control building elevation 4' 6",
and RCP cubicle B).
The review consisted of an evaluation of the hazards sunmiary documentation package for each plant area selected and a field walk to confirm ths summary conclusions regarding hazards and target interactions.
It is concluded from this review that corrective actions required as a result of this audit are now substantially in place, and, unless otherwise reported, are baing implemented in a satisfactory manner.
It was possible to observe that cxtensive progress had been made in revising the Hazards Report (NERM-69) and in thn generation of supporting, multidisciplin documentation required to summarize each area review.
The supporting documentation packages were not complete for thn four areas evaluated during the follow-up review, however, the project is currently completing this effort including the incorporation of comments g2nerated from this review as indicated below.
At the exit meeting held 9/19/85, concluding the NRC review of the audit results in Hazards Program area, it was suggested by the NRC, and concurred with by Proj ect and audit team representatives, that additional follow-up reviews be conducted at a time when the hazards program was substantially along (over 50%).
This will allow documentation of sufficient completeness and variety (number of creas) to be developed and sampled.
4.7.1 Hazards Report Documentation (A0 12179-170)
A0 12179-170 dealt with programmatic issues of the Hazard Report which required i~ proved documentation to support the conclusions.
Four of the six items svaluated during the follow-up have been verified as being satisfactorily corrected and the A0 items have been closed.
The other items dealing with references and FMEA documentation remain open.
The following summarizes the Audit Observation corrective actions:
Itsm 1:
The Hazards Report lacks references to criteria and design documents that support the FMEA conclusions (e.g.,
flow diagrams, logic diagrams, alsctrical drawings, instrument location and tubing drawings, structural drawings, stress data packages, etc.).
(Action Item H-23, II.A.l.2).
4-30
Cerrectiva Action:
The recsntly istutd Hrzards Rsport (NERM-69) eaction 4.0 idsntifies the source material that supports the review criteria established in th2 report.
The interaction evaluation data packages for each plant review are contain the pertinent discipline reference material supporting the evaluation conclusions in accordance with Section 5.0 in the Hazards Report.
The icplementation of this requirement was evaluated during the follow-up audit and wts concluded to be satisfactory except that the divisional files for the Main Stsam Valve House (MSVH) did not contain document revision numbers for traceability on all flow diagrams and electrical diagrams used for the FMEA av21uation.
The remaining three data packages reviewed during the follow-up (FWA cubicle, Control Building, and RCP cubicle) contained appropriate reference documentation.
Cause: The level of documentation was underestimated during program inception.
Significance:
The corrective action encompasses the entire hazards program.
A rs-evaluation of all plant areas containing essential structures, systems, and components is currently underway to assess the hazard interactions based upon the rsvised criteria and documentation requirements.
Follow-up Action: The Project will confirm that documents referenced in the MSVH discipline data packages contain a revision number for traceability.
Item 2:
The report lacks the basis of a controlled document.
The criteria and procedure section should be reviewed and approved by appropriate personnel (including the Project Engineer or his designee) and controlled separately as a criteria document. The FMEA results should be a project controlled document with tha appropriate document identification number, revisions retained for historical rscord, appropriate signatures, etc.
(Action Item H-23, II.A.3).
Corrective Action: The current Hazard Report (NERM-69) is issued as a controlled project procedure, NERM-69, reviewed and approved by the appropriate proj ect parsonnel.
The FMEA results (hazards interaction evaluations) are individually signed-out by plant area and are incorporated into NERM-69 (attachment 6) as a j
ravision to the document.
l l
Cruse and Significance:
See Item 1.
Follow-up Action:
The Hazards Report (NERM-69) or Project procedure NETM-42.
Should establish procedures to control the revision process of both the criteria document and the supporting summary documentation (attachment 6 to NERM-69).
Itsm 3:
The hazard FMEA and conclusions lack accountability from the participating discipline representatives.
The current matrix evaluation lacks datss when the review was performed and signatures of personnel performing the rcview.
(Action Item H-23. II. A.l.1 and II. A.2).
Corrective Action:
The current Hazards Report (NERM-69) section 5.0 establishes procedures for a summary sheet signoff on each plant area.
The summary sheet ch211 be signed and dated by the participating discipline representatives. The implementation of this criterion was reviewed during follow-up and verified as b2ing satisfactory.
C:ure and Significance:
See Item 1.
Follow-up Action: None. This item is closed.
4-31
Itsm 4:
The hazard FMEA is not sufficiently documtntsd to ansure that the conclusions are readily substantiated.
Each participating discipline in the raview process is not (either by reference, summary, or detail evaluation) documenting the results or conclusions sufficiently.
(Action Items H-021 and H-23 II.A.1).
Corrective Action:
The current hazard report (NERM-69) section 5.0 establishes procedures for documentation of the hazards evaluation which will be incorporated in the hazard report by attachment (Attachment 6).
The implementation of this r2quirement was reviewed during follow-up and it was concluded to be satisf actory.
Enhancement to documentation packages was suggested, however, to improve understanding:
o Additional detail in the safe shutdown evaluation for the MSVB (area 161),
the RCP cubicle (area 140), and FWA cubicle (area 012) should be provided including calculation references as applicable.
A specific case is the MS drains line f ailure and the resulting time required to isolate and blowdown the affected steam generator so as access to the adjacent MSVH cubicle can be achieved.
Valve and thermowell missiles should be specifically annotated on the review o
sheets.
o The flooding evaluation should be annotated on the MSVB (area 161) review sheets.
o All of the applicable event postulation and evaluation codes should be listed on the review area summary sheets (i.e., B7 and B8).
Cause and Significance:
See Item 1.
Follow-up Action:
The auditors will confirm that the documentation packages of tha hazard report address the issues described above.
Item 5:
The hazard report is not integrated into the project design control process to ensure that design changes impacting the FMEA conclusions or that initiated changes derived from the hazard program are directed to the appropriate individuals or groups.
(Action Item H-23, II.A.3.1).
Corrective Action:
Revision of NETM 42 (Rev. 2) by adding paragraphs 3.3.4g, 3.3.6 and 3.3.7, specifically indicating how design changes are coordinated with tha hazards program resolves this item.
Cruse and Significance:
See Item 1.
Follow-up Action: None. This item is closed.
Item 6:
The hazards report, or applicable project procedures, does not define the role of the hazard program in the stress reconciliation process to ensure that the final stress results are used to:
a.
Confirm the design of mitigating hardware.
b.
Confirm no interactions with restraint hardware that is no longer required.
Transmit changes to and/or deletions from prior load transmittals.
c.
4-32
d.
Gin rats, as rtquirrd, jet irpect loads on essential structures, systems, and components.
c.
Require responses to transmittals (conclusions, further action, etc.).
f.
Generate gap (and other required) data for start-up testing, g.
Confirm exclusion zone stress limits are not exceeded.
This concern involves the specification of responsibilities and associated tasks to complete the activities identified above.
The Project has described how the entlysis and design methods are implemented but Proj ect procedures should be established to ensure that these activities are completed.
Corrective Action:
Specific Proj ect and discipline procedures were cited in raponse to most detailed technical tasks.
The preoperational testing group has b un assigned the added specific task of developing final pipe whip restraint gap data from reconciled pipe stress results.
During the follow-up it was confirmed thtt EMD is generating final break location reports and that these are generating getion within EMD (if new break locations are defined - as appears likely for the primary system surge line) and coordinated responses are being written into the hazard program (footnote to the interaction table indicated that additional interactions will be assessed for revised data).
Further, later review also disclosed inconsistencies between design calculations and drawing for a restraint beam. Discussion with the project indicated drawings end calculations to be reconciled in final design reconciliation process.
Significance:
The A0 was written to clarify the role of hazards program in the dreign completion process and to understand proj ect approach to pipe ruptures dssign completion.
It is acknowledged that prciect understands that the final dssign documentation must be consistent with the final design basis in all re:pects.
Follow-up Action: None. This item is closed.
4.7.2 Hazard Report Criteria and Interaction Evaluation (A0 12179-171)
~
A0 12179-171 dealt with hazards review criteria and interaction evaluations.
Sixteen items were identified of which five items evaluated during the follov-up heve been verified as being satisfactorily corrected and the A0 items have been closed. The other items remain open requiring follow-up action. The following eummarizes the Audit Observation corrective actions:
Itcm 1: The hazard report does not provide review criteria on the evaluation of cyatems containing radioactive liquids to ensure that 10CFR100 limits are maintained, control room habitability and access to areas required for safe chutdown or accident mitigation is assured.
The project has agreed to provide this criteria.
(Action Item H-015).
Corrective Action:
The recently issued Hazards Report (NERM-69) section 3.3 citisfactorily provides the review criteria for evaluating radioactive fluid cystem failures.
Cruse: The level of documentation was underestimated during program inception.
4-33
s i
Significenes:
The corrsctiva actica a:ncompaasso the entire hazards progrcm.
A rssvaluation of all plant areas containing essential structures, systems, and components is currently underway to assess the hazards interactions based upon tha revised criteria and documentation requirements.
J Follow-up Action: None. This item is closed.
Itsm 2': ' The Hazard Report does not provide review criteria for spray wetting effects on essential equipment' subsequent to a moderate energy pipe crack.
The-project has agreed to provide this criteria.
(Action Item H-017).
Corrective Action:
The recently issued Hazards Report (NERM-69) section 3.5
. satisfactorily provides the spray wetting review criteria and section 5.0 provides an event postulation and evaluation check list to ensure implementation during the hazards evaluation process.
'Ceuse and Sianificance: See Item 1.
4 Follow-up Action: None. This item is closed.
1 Ite:m 3: The Hazard Report does not include safe shutdown systems in the criteria of essential systems subject to the single active failure postulation.
The project has. agreed to clarify the report by adding safe shutdown systems to the
+
oingle failure criteria.- (Action item H-016).
l l
Corrective Action:
The current issue of the Hazards Report (NERM 69) sections 1.2.1 and 4.8 clarifies the application of single active failures to include safe shutdown systems.
Ceuse and Significance: See Item 1.
Follow-up Action: None. This item is closed.
l-Itam 4: The Hazard Report pipe rupture postulation criteria does not contain the words "or maintained pressurized" in the definition of high and moderate energy lines.- The project has agreed to clarify the report by adding "or maintained prassurized" to the definition of high and moderate energy lines.
(Action Item H-014).
1 Corrective Action:
Section 2.2 of the recently issued Hazards Reports (NERM-69) now addresses the above concern satisfactorily.
Cause and Significance:
See Item 1.
Follow-up Action: None. This item is closed.
Itam 5:
The Hazards Report interaction evaluations do not address missiles escociated with valve stems, thermowells, etc. as potential hazards that must be considered and dispositioned.
The missile ejection should be evaluated both as initiating events occuring during normal plant conditions and as the single pesive f ailure occuring during the long term, i.e.,
post DBA events.
(Action itcas H-019 and H-023, I.e).
Corrective Action:
The Hazards Report (NERM-69) sections 2.1, 2.4 and 3.4 cddresses this concern with technical details and bases by which such missiles
. ora (or are not) to be evaluated.
The follow-up, however, indicated that valve cnd thermowell type missiles were not described in the area summary evaluations.
4-34
l C:urt: L2 vel of documtntation was undcrastimated during program inception.
Significance: See Item 1.
Follow-up Action:
The implementation of this criteria was not complete, thsrefore, a follow-up review will be necessary to confirm adequate documentation of missile considerations within the hazards review program. FSAR changes may be nicessary to extend and uniformly apply missile evaluation criteria for all plant areas.
Itrm 6:
The single active failure criterion implemented by the Hazard Report differs from the FSAR (or Standard Review Plan) in the following manner:
A single active failure of an electrical component as implemented in the hazards program, occurs only when the essential component is required to change state while performing its mitigating or shutdown function.
Systems normally operating shall continue to operate and valves normally open (closed) remain open (closed).
Passive electrical faults and spurious operations are not considered as single active failures in the hazard FMEA.
Therefore, any postulated pipe rupture or internally generated missile (from a safety or non-safety related source) is allowed to disable one train of a safe shutdown system provided offsite power is available (i.e.,
loss of redundancy is allowed but not loss of function).
This criteria is at variance with FSAR sections 3.1.1, 3.6.1, and 8.3.1 and applicable SER sections which considers spurious actuations and passive electrical f aults as " single active failures".
(Action items H-013. H-018, and H-021).
Corrective Action:
The recently issued Hazards Report (NERM 69) section 2.1 clzrifies the single active failure criterion applicable to pipe rupture and internally generated nissile events.
A proposed licensing change has been draf ted to clarify FSA) Sections 3.1.1 and 8.3.1.
The following definition is proposed:
"A single active failure is not assumed in a dual-purpose safe shutdown system if:
The initial failure event or its direct consequences is external to the o
system, and o
The event results in the failure of one of the two redundant trains of the shutdown system, and o
The event does not result in a reactor or turbine trip, and The safe shutdown system's components are not required to be actuated o
(i.e., change state) to achieve cold shutdown.
Under these circumstances, continued operation of the plant is controlled by plant technical specifications."
Cru*e and Significance:
See Item 1.
Follow-up Action: The auditors shall confirm that the docketed licensing change rsflects the criteria outlined above.
Ittm 6.b:
The " dual purpose" exclusion rule applied in the Hazard Analysis R; port is not consistent with the FSAR.
FSAR section 3.1.1.3 applies the single 4-35
1 I'
activa failure exclusion to nodarate ansrgy systems only.
Tha htzard analysis
' report excludes both high and moderate energy systems.
(Action item H-003).
4 Corrective Action:
The current Hazards Report (NERM-69) section 2.1 accurately describes the " dual purpose" rule to apply only to moderate energy systems as per ths FSAR.
Cause and Significance: See Item 1.
Follow-up Action: None. This item is closed.
Itsm 6.c: The " dual-purpose" exclusion rule as defined in SRP 3.6.1 applies only j
to the system that has the piping f ailure.
The FSAR and the Hazard Analysis Raport extends the applicability to the failed systems' related service systems.
Thsrefore, a failure of RHS train-A is allowed to disable CCP train-A since CCP is a related service system of RHS and a single active failure of train-B RHS or j
CCP is not applicable. The SRP conformance statement in FSAR Section 1.9 should clarify this issue.
(Action item H-018).
Corrective Action:
None.
The FSAR section 3.1.1.3 is sufficiently clear to indicate that the term " System" is applicable to the failed system and its supporting subsystem.
No deviation or non-compliance with SRP section 3.6.1 is taken.
j Follow-up Action: None. This item is closed.
?
l Itsm 7:
The Hazard Report does not provide review criteria to ensure that only j
Ssismic Category I systems and components are utilized for pipe rupture / IGM event j
nitigation and to shutdown the plant.
The audit team has identified that j
non-seismic Category I equipment are utilized to (1) mitigate auxiliary steam and hot water heating line breaks in the auxiliary building and (2) provide cooling l.
water to ' the MCC/ rod control area air conditioning units as a result of a CHS mini flow line break disabling both service water trains supplying the ACU.
4 (Action item H-011).
Corrective Action:
The recently issued Hazards Report (NERM-69), section 2.3 provides the seismic requirements for mitigation and shutdown
- systems, components, or structures.
Cause and Significance:
See Item 1.
Follow-up Action:
Exceptions are noted in the hazards report (NERM-69) for the HVH/ ASS portions containing Air operated Trip Valves (ATV's).
When implemented, the Project should provide to the auditors the analysis results satisfying valve opsrability requirements. Revisions / clarification to FSAR, sections 1.9 and 3.6 chall be issued to report these special situations.
The item shall be included in the planned follow-up review.
Itsa 8:
The criteria for evaluating the pressure integrity requirements for instrument lines (safety and non-safety related) connected to safety related process lines has not been provided in the hazard report document.
The review criteria of the hazard report should address the effects on the safety systems opsrability due to the' loss of instrument tubing integrity.
Of primary importance are instrument lines connected to small diameter process lines which are susceptable to loss of (or degraded) function should these lines fail.
(Action Item H-22).
4-36
Corrsetiva Action:
The racantly issutd Hszards Raport (NERM-69) section 4.0 provides review criteria to ensure that all branch lines (including instrument lines) subject to failure from hazards interactions shall be evaluated with raepect to impact on system operability.
Cruse and Significance:
See Item 1.
Follow-up Action: None. This item is closed.
Item 9:
The Hazards Report does not provide review criteria for ensuring that ths containment isolation system piping and components are protected from LOCA induced effects and concurrent events.
A field walk indicated that the Reactor Plant component cooling water (CCP) lines to the RCP do not have protection hsrdware for LOCA missiles and jets.
These lines are containment isolation boundry lines (GDC-57) which require protection.
The Hazards Report should idsntify these lines as well as the other containment isolation boundry systems (including instrument branch lines as discussed in previous item) to ensure protection is afforded as required.
(Action Item H-23, I.D. and I.E.).
Corrective Action:
The recently issued Hazards Report (NERM-69) section 4.3 provides adequate review criteria for ensuring that the containment isolation cyatem piping and components are protected from LOCA induced effects.
The 1 plementation of this criterion was reviewed during the follow-up audit of the RCP cubicle B and it was verified that the CCP lines were identified as targets of a
pressurizer surge line rupture and require either protection or reclassification as a containment isolation boundry line as GDC-56 penetration with the appropriate design considerations.
The hazards evaluation for this cubicle was not complete at the time of the follow-up.
i Cause and Significance:
See Item 1.
Follow-up Action:
The next follow-up will reinvestigate the RCP cubicle B and varify that containment isolation boundry lines are protected.
Item 10:
The Hazard Reports' structural evaluation of HELB effects (e.g., pipe irpact, restraint reaction, cubicle pressurization, jet impingement) does not i
document the basis upon which integrity of essential structures is maintained.
Tha project has agreed to enhance the report to include a description of the bzsis on which evaluations are made and to include specific references to support that basis.
(Action items S-46 and S-52).
Corrective Action:
Revision of the Hazards Report (NERM-69) paragraph 4.4 was intended to address the concerns.
C"use and Significance:
See Item 1.
Follow-up Action:
Review of paragraph 4.4 and discussions with appropriate project personnel indicate that additonal detail in the NERM is required that provides specific references to basic methodology for structural evaluation.
Sp cific approaches for structural evaluation were briefly reviewed but are not yst incorporated into actual walkdown/ area evaluations.
Confirmation of documented implementation is anticipated to be submitted to the auditors for rcview by September 31, 1985.
Itsm 11:
The hazards interaction evaluation does not provide analysis summaries i
documenting the review of structures, control systems / components, and electrical cyatems/ components which may be targets of postulated hazards (refer to item 10 l
4-37
for additonal concerns with structural elenants). For exampic, tha htzard raport sysluation of the motor driven auxiliary feedwater pump cubicle did not identify ths door separating the two pump cubicles as a target to high energy pipe rupture sffects and evaluate spray wetting on the adjacent FWA pump motor.
(Action items H-021 and S-052).
Corrective Action:
The recently issued Hazards Report (NERM-69) section 5.0 provides the minimum documentation requirements for sensitive structures, systems, and components.
All hazard types resulting from an event do not need epscific review documentation provided the limiting types which impact sensitive targets are identified (e.g., should a pipe whip target and disable a component, jot impingement on that same component need not be addressed).
The implementation of this criterion was evaluated during the follow-up review of the Control Building West Switchgear area Main Steam Valve House, and the Auxiliary Fcidwater Pump cubicle. The hazards interaction evaluation summaries adequately d32cribes and analyzes sensitive electrical equipment and structural elements in thsse areas.
The interaction evaluation matrix, however, was not completed for the MSVH and RCH pump cubicle at the time of the follow-up review.
Cause and Significance:
See Item 1.
Follow-up Action:
The next follow-up audit will verify that the level of documentation is adequate. The Project shall complete the interaction evaluation matrix forms for each review area and attach them to the signed out documentation p2ckages.
Item 12:
Review, criteria and FMEA results for jet impingement effects on accential structures, systems, or components of postulated longitudinal breaks in tha break excluded portions of the mainstream and feedwater systems has not been svaluated by the Hazards program as required by SRP conformance statement in FSAR caction 3.6.1.
(Action item H-002).
Corrective Action:
The recently issued Hazards Report (NERM-69) section 2.2 provides the criteria for postulation of the arbitrary split in the break excluded main steam and feedwater piping systems and considers only the svaluation of environmental effects resulting.from the split, dynamic effects are not considered. The Project proposes to revise FSAR section 1.9 (SRP conformance statement) to take an exception to the jet impingement postulate.
C use:
At the time of the submittal of the SRP conformance statement, the proliminary hazards interaction evaluation concluded that there was no essential cquipment located within the mainsteam or feedwater penetration area subject to jot impingement effects and as a result an exception was not taken.
Significance:
The SRP deviation applies only to the main steam and feedwater lines in the containment penetration area.
Fellow-up Action:
The auditors will confirm that the SRP 3.6.1 conformance ctetement in FSAR section 1.9 is revised to identify an exception to the jet impingement postulate for break excluded main steam and feedwater lines.
Item 13:
The Hazards program premise is that many areas are " cleared" with the conclusion that all structures, systems, and equipment within the area are not "assential" and can be lost by definition.
Environmental and flooding 4-38
calculations ars bzced upon sp2cific, prosum bly liniting assumptions (worot cingle break, etc.).
Thsrefore, the hazard evaluation of missiles and HELB effects should verify that the design basis environmental and flooding criteria are maintained when j
parforming the area by area review.
(Action Item H-018).
Corrective Action: The recently issued Hazards Report (NERM-69) sections 3.2 and 3.3 provide review criteria to ensure that design basis environmental and flooding criteria are maintained.
The implementation of this criteria is cddressed by the event postulation and evaluation code (B8) in Attachment 2 of tha Hazards Report with references to flooding and environmental calculations.
This review shall be documented on the area summary sheets.
This evaluation, however, was not annotated on the summary review sheets evaluated during the follow-up review.
Cruse and Significance:
See Item 1.
Follow-up Action:
The project shall provide a reference to environmental and ficoding that are applicable to the review area.
The summary sheat shall indicate this review was performed by the event postulated and evaluation and code, B8.
A follow-up review shall confirm adequate evaluation and documentation of cascading effects.
Item 14:
The turbine driven auxiliary feedwater pump discharge lines are cicssified inappropriately as moderate energy lines. These lines are high energy from the pump discharge check valve to the tee connection of the motor driven pump discharge lines. This significantly alters the hazards e.aluation performed for the plant areas that these lines traverse.
Additionally, the hazard report doss not contain references documenting the source where maximum operating prcssures and temperatures were extracted.
(Action Items H-020 and H-021).
Ctrrective Action:
The recently issued Hazards Report (NERM-69) incorporates by cttachment (Attachment 6) discipline files of which contain marked-up flow dirgrams.
The current marked-up flow diagrams for the auxiliary feedwater lines correctly indicate the high energy / moderate energy boundaries for break l
c::essment.
The Hazards Report section 5.0 indicates that either the flow dicgram design conditions or the applicable Stress Data Package maximum operating conditions shall be used to establish the classifications and shall be referenced in the area summary review package.
The incorporation of the mark-up flow dirgrams provides a satisfactory means of documenting system classifications for th2 Hazards program. The original source of the error (pipe stress data package) io currently being corrected by the Project.
Cruse and Significance:
See Item 1.
Follow-up Action:
The auxiliary feedwater system Stress Data Package shall be r vised to reflect the appropriate operating pressures for the turbine driven pu p discharge lines.
The Project shall determine the extent and provide the rc:ults of this evaluation to the auditors by October 15, 1985.
Item 15:
The following infr mation contained in FSAR section 3.6 is not censistent with the design:
a.
Notes to Figure 3.6-12 (pg. 8a of 8) refer to primary coolant break 7 as a "G"
(Guillotine) type break.
Break is, in fact, a longitudinal split along the elbow intrados.
4-39
FSAR corrcction rcquir:d to chcng2 "G" to "S".
b.
Tables 3.6-12 and 13 requires analagous correction.
Also break Nos. 9, 10 and 11 are not presented.
c.
Table 3.6-14 does not address jet effects for breaks 7, 8, 9,10, and 11.
d.
Page 3.6-13 uses statement:
" Table 3.6-19 summarizes the pipe whip analysis.
Results of analysis will be provided in amendment to FSAR." This seeming contradiction appears several times.
Th3 project has agreed to update the FSAR to correct the discrepancies identified cbove (Action Item J-009).
Carrective Action:
LCNs 690 and 691 are prepared but not yet issued addressing l
tha specific comments above.
Additional FSAR revision is anticipated but will l
rccult from normal emergency completion procedures (final data, etc.).
Cause:
Certain errors were committed in constricting the Tables.
- Further, tcxtual contradictions developed as engineering neared completion.
Fallow-up Action: The Project to confirm that LCNs 690 and 691 are submitted and docketed to NRC.
It m 16: The Hazard report systems interaction tables (Jan 1985 edition) has not idcntified all Category I systems contained in NEAM 74.
The concern being that come safety-related systems may not be evaluated as targets of hazards interactions. The project has identified the following systems not identified in tha Jan. 1985 table, but shall be included in the next revision:
FWC, HVC, HVY, HVR, HVZ and LMS.
Additionally, NETM-74 incorrectly lists "SSR" and "SCL" (Action Item H-004).
Corrective Action:
Review of report matrix by the Project did indicate need for correction. NEAM-74 also was concluded to require revision.
C use and Significance:
See Item 1.
Follow-ups (1) The Project to confirm issue of revised NEAM-74 to incorporate c11 Category I systems.
(2)
Recent follow-up review indicated that, for the RCP cubicle, the interaction matrix was not yet complete (i.e., did not address all contained Category I fluid systems).
A follow-up review will be conducted to c:nfirm that interaction matricca summarizing area interactions identify all cs ential systems.
4.7.3 Flooding Calculations (A0 12179-172)
Th3 following summarizes the corrective actions agreed to by the Project on the five concerns identified in A0 12179-172:
It m 1: The flooding analysis does not identify the means available to terminate piping failures for flood mitigation.
FSAR Section 3.6.1.3.1 requires c:sumptions of a single active failure and event specific loss of offsite power for essential equipment required to mitigate each postulated pipe rupture event cnd safety shutdown the plant. Additionally, credit for mitigating the event may b3 taken for seismic Category I systems and components only.
(Action Items H-008 cnd P-015).
4-40
Correctiva Action:
The Project hzs agresd to revisw all flooding calculations end incorporate the means available to terminate flooding. The ESF Building flood calculation is currently being revised to include identification of flood tormination methods due to piping failures.
Significance:
Indeterminate at this time.
The Proj ect indicated that the ravision to all flooding calculations will be complete in November, 1985.
Follow-up Action:
The results of the Project evaluation to be provided to the cuditor for review and A0 item closeout.
Item 2:
The flooding analysis of water flowing under doors utilized a non-conservative flow coefficient. The equation used to model the flow rate and rssulting water level is an orifice equation with a flow coefficient of unity (Cv 1).
A discharge coefficient of 0.6 should have been used since it is
=
conservative for this type of analysis (i.e., minimize flow velocity to maximize w:ter level).
The project intends to reevaluate the flood levels which relied flow under doors using a discharge coefficient of 0.6.
(Action Item P-016).
Significance:
Due to the conservative method used in the original calculation, tha revised flow coefficient will not change the conclusions of the calculation.
Follow-up Action:
The auditor will review the revised ESF Building flooding calculation and confirm that conservative flow coefficients have been utilized.
Itcm 3:
The flooding analyses do not address flooding sources originating from tho floor dainage system or the sump discharges from adjacent cubicles.
The project intends to review the plant flooding analysis to ensure that the floor drcinage system and the sump discharges from adjacent areas do not result in a more severe flooding hazard and revise subject calculations as required.
(Action Itcm P-017).
Corrective Action:
Through discussions with the Project, indications are that ths ESF building flooding calculation P(R)-0962 is currently being revised to cddress flooding sources originating from the floor drainage system or sump pump diccharge lines.
A review of all flooding calculations is estimated to be co:plete in November, 1985.
Significance:
It is anticipated that the reevaluation will not alter the flooding analysis conclusions.
Fellow-up Action:
The results of the Project evaluation to be provided to the cuditor for review.
Item 4:
The ESF building flooding calculation P(R)-0962 considered the fluid diccharge rate of a postulated RWST cooling subsystem pump discharge line rupture wh:n the pump was not operating. This is not consistent with SRP 3.6.1 guidance for determination of the break and subsequent effects at system maximum operating ccnditions.
The project has agreed to revise the flooding analysis to consider th3 pump operating when evaluating the pipe rupture flow rates.
(Action Item P-014).
Corrective Action:
The Project is in the process of revising the ESF building flooding calculation (P(R)-0962) to consider the flow rate when the RWST cooling purp is operating.
A review of all flooding calculations reveal no other cases cicilar to the one described above.
4-41
Significance:
It is enticipatsd that the resvaluation will not alter the flooding analysis conclusions.
Follow-up Action:
The auditor will review the revised ESF building flooding calculation and verify that the corrective action has been satisfactorily incorporated.
It m 5:
The flooding analyses evaluate the building flood levels based on the s
moderate energy pipe crack criterion for all piping systems.
This criteria may not be Ibniting for high energy subcooled liquid systems (e.g.,
auxiliary fasdwater system) for which a complete severence is required to be postulated.
(Action Item H-005).
Corrective Action:
Through discussions with the Proj ect, indications are that the ESF building flooding calculation will be revised to address this issue.
A r view of all other flooding calculations by the Project indicates that the CVCS piping in the auxiliary building is the only other candidate for this break type.
A break in this line is less limiting than the design basis Servien Water line crack.
Significance:
It is anticipated that the reanalysis will not alter the flooding analysis conclusions.
Follow-up Action:
The auditor will review the revised ESF building flooding calculation and verify that the corrective action has been satisfactorily incorporated.
4.7.4 Follow-up Evaluation of Hazards Summary Documentation and Criteria Implementation A follow-up review was performed during September 13 through 20, 1985 in order to cycluate the implementation of the corrective actions described in sections 4.7.1 cnd 4.7.2 of this follow-up report.
Four areas of the plant were selected for rsview based upon the uniqueness of the hazards. Those areas were the Auxiliary Feedwater pump cubicle B, the RCS pump cubicle B, the MSVH steam line cubicle, cnd the control building (elevation 4'6") west switchgear cubicle.
The review included field walkdowns to verify essential equipment locations and
(
hszard/ target interactions.
Tha basic design process characteristics evaluated to provide assurance that the H:zards Report criteria and documentation requirements are properly addressed ware:
Completeness of Analysis Documentation o
Scope and Objectives defined Responsibilities of reviewers identified and assigned All documents supporting conclusion referenced Identification of postulated pipe rupture location and type.
o Identification of postulated Internally Generated Missiles (ICM).
o Establishment of zone of influence of resultant hazard.
o o
Proper identification of essential safe shutdown and accident mitigation systems, components, and structures located within the zone of influence.
4-42
o Assssament of sysnt nitigation and plant asfa shutdown capabilities as a consequence of a postulated pipe rupture or IGM with appropriate consideration of the worst case single active failure of a seismic Category I component and loss of offsite power (if a unit trip results) occurring simultaneously with the postulated event.
Appropriate methodology utilized in the FMEA.
o Definition of postulated IGM and pipe rupture effects.
o IGM impact Pipe whip impact Jet effluent impingement Environmental effects Flooding Identification of need for, and implementation of design of, mitigating o
hardware.
Tha follow-up review of the four plant areas selected indicates that the documentation packages were significantly improved and established a reference trail to the summary conclusions drawn. The scope and objectives of the hazards program are suf ficiently defined in the Project Procedure (NETM-42, rev. 2) as amended per A0 12170-171-5 resolution. The responsibilities of the participating cembers of the hazards interaction evaluation team are sufficiently described in c:ction 5.0 of the Hazards Report as amended per A0 12179-170-2 resolution. The racponsible discipline members performing the hazards interaction evaluation on thz four areas selected for the follow-up review signed and dated the hazards cvoluation summary sheets in accordance with NERM-69 procedures. The interaction svaluation data packages for each plant area contains the pertinent discipline rsference material supporting the evaluation conclusions in accordance with esction 5.0 of NERM-69 ( A0 12179-170-1).
All reference material contained the cppropriate document revision numbers for traceability except for several flow disgram and electrical diagram references contained in the MSVH area documentation package.
The Proj ect is correcting this deficiency (see A0 12179-170-1 Follow-up Action).
Tha hazards evaluation for the four plant areas accurately defines the pipe rupture locations and types in accordance with the Hazards Report (NERM-69) criteria section 2.2.
Each fluid system located in the plant area under review is classified as either high energy, moderate energy, or not pressurized and included in the supporting documentation packages (Attachment 6 to the Hazards R2 port). Break location reports are consulted and incorporated by reference into ths documentation packages as required.
Th2 identification and evaluation of all Internally Generated Missiles (IGMs) was not complete at the time of the follow-up review.
Rotating machinery (pumps) and valve stem missile ejections had been evaluated and were not concluded to be cr:dible ICMs for the components located within the four cubicles either by cugineering analysis (calculation 12179-NM(S)-685) or design (backseated stems)
(
rs:pectively.
The interaction evaluation review summaries, however, have not eddressed potential IGMs originating from valve bonnet or thermowell failures (csa A0 12179-170-4 follow-up).
Th2 establishment of the Zone-of-Influence from resultant hazards was correctly dstarmined for the hazard types identified in the four review areas.
- However, tha identification of all hazard types was not complete at the time of the 4-43
_m-
_. _. _ _ _ _ _ _ ~
j follow-up review. The Hszards Raport structural evaluation criteria lacks review cp2cifies for generic impact loads (see A0 12179-170-4, 12179-171-10 and 11 4
follow-up).
i The Hazards Report interaction evaluation matrix and summary sheets actisfactorily identifies all essential equipment located in the defined zone of j'
influence of the hazard types postulated (see above) and correctly provides a FMEA assessment of postulated event mitigation and plant safe shutdown j
capabilit'ies utilizing the appropriate assumptions (i.e., single active failure, loss-of-offsite power, and seismic).
Environmental and flooding effects associated with the postulated event are considered. in the evaluation to ensure that the design basis calculations remain valid (e.g.,
a HELB cannot damage adjacent piping if resultant failures exceed the single pipe failure criteria of l
ths flooding analysis).
This review, however, was not sufficiently documented I
l and additional detail was suggested to improve comprehension of the documentation prckages (see A0 12179-170-4 and 12179-171-13 follow-up).
I f
Ths FMEA results conclude that pipe rupture restraints, spray wetting shields, or i
IGM shields are not required to mitigate or protect safe shutdown equipment from postulated events in the Auxiliary Feedwater (FWA) pump cubicle MSVH area, or ths Control Building west switchgear area.
All postulated events occurring within FWA pump cubicle and MSVH area are contained within the area and do not affect safe shutdown system operability. Piping failures and fan missile hazards era precluded in the Control Building west switchgear area by maintaining stress j
lavals in the moderate energy piping below threshold levels (preliminary break j
location calculation 12179-773 through 776-DM) and fan missiles ejection is not crsdible by analysis (calculation 12179-NM(S)-685-DKB).
The RCS pump cubicle pipe break location reports are not complete as yet from the stress racinciliation effort and, therefore, final mitigation hardware requirements are j
not defined.
The Hazards Report initial review has concluded, however, that Racetor Plant component cooling water lines must be protected from LOCA breaks by mitigating hardware or revised the system design to change from " closed" containment isolation barrier (GDC-57) to an "open" system (GDC-56).
t 4-44
5.0 REFERENCES
1.
Engineering Assurance Technicci Audit Report, Millstone Unit 3 Proj ect,
Audit No. 59, dated August 16, 1985, including Errata dated August 22, 1985.
2.
Millstone Unit 3 Hazards Review Summary (Hazards Report), NERM-69, Revision 0, dated 9/17/85.
3.
Millstone Unit 3 Project procedure, " Hazard Review Program for the Millstone i
Nuclear Power Station - Unit 3", NETM-42, Rev. 2, dated 9/17/85.
4.
SWEC calculation " Evaluation Internally Generated Missiles from High Speed Rotating Machinery", 12179-NM(S)-685-0, dated 12/11/84.
1 J
T T
l l
5-1