ML20136G413
| ML20136G413 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/09/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20136G405 | List: |
| References | |
| NUDOCS 8508190391 | |
| Download: ML20136G413 (31) | |
Text
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m STAFF EVALUATION OF COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN REVISION 2 8508190391 850809 PDR ADOCK 050 5
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TABLE OF CONTENTS ACRONYMS
1.0 INTRODUCTION
2.0 OBJECTIVES 3.0 STAFF EVALUATION 3.1 DESIGN REVIEW BREADTH 3.2 DESIGN ORGANIZATION INTERFACES 3.3 EXTERNAL SOURCE ISSUES 3.4 CABLE TRAY / CONDUIT SUPPORTS 3.5 QA/QC CONSTRUCTION ADEQUACY 3.6 PIPING AND PIPE SUPPORTS 3.7 ACCEPTANCE CRITERIA 3.8 SAMPLING CRITERIA 3.9 CORRECTIVE ACTION 3.10 CPRT MANAGEMENT TEAM
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3.11 DESIGN RESPONSIBILITY FOR PIPING
4.0 CONCLUSION
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5.0 REFERENCES
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Atomic Safety and Licensing Board CAT -
Construction Appraisal Team CPRT -
Comanche Peak Response Team CPSES -
Comanche Peak Steam Electric Station DSAP -
Discipline Specific Action Plan FSAR -
Final Safety Analysis Report G&H -
Gibbs & Hill IAP -
Independent Assessment Program ISAP -
Issue Specific Action Plan SER -
Safety Evaluation Report SIT -
Special Inspection Team SRT -
Special Review Team SSER -
Supplemental Safety Evaluation deport e,
SWEC -
Stone & Webster Engineering Corporation TRT -
Technical Review Team I
TUEC -
Texas Utilities Electric Company QA/QC -
Quality Assurance / Quality Control g
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1.0 INTRODUCTION
In March 1984, the NRC established a program designed to assure coordinated resolution of technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities. As a means of executing its programmatic responsibilities, the NRC's Comanche Peak Project formed five Technical Review Teams (TRTs) representing the following disciplines:
o Electrical / Instrumentation o Civil / Mechanical o QA/QC o Protective Coatings o Testing Programs The TRTs initiated a series of onsite inspections and evaluations in July 1984 and documented the results of these activities in five supplements to the Comanche Peak Safety Evaluation Report, References 1-5.
In response to the concerns and issues identified by the TRTs, Texas Utilities Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the purpose of addressing all TRT concerns. The CPRT, in response to TUEC direction, submitted in October 1984 its initial Program Plan which included Issue-Specific Action Plans (ISAPs).
TUEC, in Revision 2 to the Program Plan, has expanded the CPRT scope to address all issues identified by external sources and has also committed to perform self-initiated evaluations of design adequacy and quality of construction. The expanded scope was submitted to the NRC for review on June 28, 1985.
The Comanche Peak Response Team Program Plan, Revision 2. (Plan) has the following principal objectives.
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o Evaluate and recommend solutions for all issues ~(TRT, ASLB,
SSER, CAT, SRT, SIT, Region IV Intervenors, Applicant and IAP).
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Determine root cause and generic implications of each l
safety-significant deficiency found.
o Perform self-initiated evaluations for the purpose of assuring that there are no undetected and uncorrected safety significant deficiencies at CPSES.
The CPRT's role through this Program Plan is to resolve issues and determine root cause and generic implications of each safety significant i
deficiency.
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The NRC staff has completed its initial review of the portions of the Comanche Peak Response Team Program Plan submitted to date. Our programmatic concerns are included in this report. Detailed comments on l
individual action plans will be provided in a separate report.
Comments and concerns herein do not reflect review of the umbrella QA i
effort nor comments of the intervenor CASE.
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IAcronyms are defined on page 11 of this report.
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2.0 NRC STAFF REVIEW OBJECTIVES The objective of the staff's evaluation of the CPRT Program Plan is to determine whether the approach set forth by the Applicant in the CPRT Program Plan (including scope, structure, and methodology), when implemented satisfactorily, will demonstrate that:
(1) All concerns related to design and construction adequacy identified by the NRC staff (e.g., TRT, SIT, CAT, SRT, Region IV Inspections and FSAR SERs) CYGNA IAP, ASLB, Intervenors and the Applicant have been satisfactorily resolved.
(2) Root cause and generic implications of plant deficiencies have been investigated and satisfactorily resolved, (3) Self initiated design and construction issues have been satisfactorily resolved, and (4) There is reasonable assurance that the design and construction of Comanche Peak Steam Electric Station (CPSES) in all areas of the plant complies with the requirements embodied by the regulations and meets licensing commitments.
l The staff was guided by the following principles as the basis for its assessment of the CPRT Program Plan:
(1) Scope must clearly indicate that the objectives stated above will be ret.
(2) All elements of the design process are addressed.
(3) Safety significance of specific, generic and programmatic P
deficiencies are evaluated.
I Root causes and evaluation of generic implications to determine their (4) collective significances are determined.
(5) Corrective action techniques are specified appropriately.
(6) Acceptability or exclusion of any system, structure, component, or organization from samples identified in this Program Plan is justified.
(7) Categorizing and trending of existing and new concerns, determining impact of trends and establishing a program to resolve the implications of trends are included in the Program Plan.
(8) Qualification and training requirements for the personnel involved in conducting the various review and inspection activities is specified as appropriate.
(9) The bases for the sampling methods is provided.
(10) Documentation of program activities is provided.
(11) Quality assurance of CPRT activities is appropriate.
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5 3.0 STAFF EVALUATION The NRC staff and its consultants have reviewed the programmatic aspects of those portions of the Applicants' Plan submitted to date and ffRd that the Plan is comprehensive in scope and provides a structure capable.of addressing all existing issues and any future issues identified by external sources. The Plan also contains Applicants commitment to programs intended to demonstrate the adequacy of design and construction of the CPSES. The following subsections address programmatic concerns that have resulted from the staff's review of the Program Plan. These concerns must be satisfactorily resolved prior to final staff approval to the Plan.
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' 3.1 Design Review Breadth The scope of the Plan has attempted to select areas which are representative of the safety related systems, components, and structures at CPSES. However, our review has determined that some important characteristics or features necessary for assessment of the overall design adequacy of the plant are not inherently included in the systems and components selected. Therefore, we have concluded that the Program Plan The in its present form will not provide the required breadth of review.
areas that we consider important for expanding the breadth of review are discussed below:
A.
Mechanical, Electrical & Instrumentation Systems In order to better focus on the important system elements that are judged necessary for review of the mechanical, electrical and
-instrumentation systems, we have prepared a matrix (Tables 1, 2, and
- 3) for each of the three disciplines which compares elements in various plant systems (that could determine the full breadth of review) with those inherently in the systems selected and those that we believe are identified by the Program Plan. The Applicant should provide justification for the identified differences and' confirm whether we have correctly identified the Program Plan areas of review.
B.
Civil / Structural There are a few major concerns in this discipline which are really interdependent.
First, the basis for selection of the major concrete and steel structures to be reviewed is not provided.
Another concern is that the review scope for Category I structures as proposed in the Plan is not an adequate representation of CPSES Category I structures. A number of external source issues exist on supports which range from loading to structural attachment. Based on this, it may be appropriate to select a concrete structure that is heavily loaded by supports in concentrated areas. The shield wall or a steam generator compartment structure might be an appropriate selection since they both have a significant number of attachments.
The containment liner is the largest steel structure in the plant and may be an appropriate selection as one of the structural engineering disciplines to be reviewed. Another item which may be appropriate to consider is embedded plates.
The evaluation should include various load combinations. Design information developed for use in seismic qualification of CPSES equipment should also be evaluated.
The third concern is related to the size of the sample in the areas of equipment mounting, HVAC supports, penetrations, etc. Since the overall process and control of interfaces has been raised as a concern, it would seem appropriate to increase the size of the sample in these areas. For example, in the area of equipment mounting, the Discipline Specific Action Plan (DSAP) calls for the review of one mechanical item and one electrical item. This sample size is not sufficiently large enough to reach reasonable assurance that equipment mounting, in general, is appropriate.
CPRT must reassess and augment its proposed scope for the Civil / Structural DSAP and provide the rationale for its revised scope. The revised scope and its rationale should be sufficient both in breadth and depth to allow the staff to conclude that CPSES
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7 Category I structures are designed and constructed with reasonable assurance to perform their safety functions and comply wit _h FSAR comitments.
C.
Piping and Supports The Program Plan states that the piping and supports reanalysis effort and the as-built verification will follow procedures CPPP-5, CPPP-6 and CPPP-7. The procedures are not included in the Program Plan. Thus, there is insufficient information in the Program Plan to permit an independent evaluation of the breadth and depth of review for pipe supports and small bore piping. The Program Plan should be supplemented to describe the breadth and depth of,the review for pipe supports and small bore piping or the procedures should be available for staff review. With regard to the large bore piping reanalysis by SWEC, the staff concludes that the Program Plan is sufficiently broad l
to address the major concerns associated with pipe stress provided the justification by CPRT for the exclusion of Class 1 piping is acceptable.
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Mechanical Components Normal IDVPs and IDIs have been performed on plants where concerns have not been as extensive as CPSES. This review (vertical slice) should encompass areas of concern addressed in normal IDVPs in addition to the specific concerns at CPSES. To assure sufficient breadth and depth, all external sources, including their root cause and generic implications, must also be considered in this review.
CPRT must reassess and augment its proposed scope for the mechanical components DSAP and provide the rationale for its revised scope. The revised scope and its rationale should be sufficient both in breadth and depth to allow the staff to conclude that CPSES mechanical components are designed and constructed with reasonable assurance to perform their safety functions and comply with FSAR comitments.
Recently, a new issue was raised pertaining to whether active valves t
were designed in accordance with FSAR commitments. Since the Plan intends to provide complete coverage of all areas with safety
significance, the Plan should include the consideration of the issue of active valves and the implications of the root cause af this issue on other components.
3.2 Design Organization InterfacesSection I of the CPRT Program Plan indicates that the evaluation of the design will not include those aspects of the plant designed by Westinghouse (the NSSS vendor). Our review of the Program Plan could not find the basis and rationale for excluding the design activities of the NSSS vendor from the self-initiated evaluation of the adequacy of the design for CPSES.
The CPRT should justify the exclusion of any vendor or other organization's activities from the design adequacy review for CPSES.
The justification must include the basis and rationale for the exclusions in sufficient detail to permit an independent assessment to determine whether the overall objectives of the proposed Design Adequacy Program Plan can still be met without the review of the excluded design activities.
1 In addition, the interfaces between those organizations excluded from the Plan and the related disciplines should be clearly defined in the Plan.
Design interfaces are of particular concern in the area of building structures and between disciplines. Loadings applied to the building as a result of the reanalysis effort on piping must be documented, transmitted to the civil / structural discipline, evaluated and accepted. Conversely, loadings filtered through the building structure which effect equipment (cable trays, pumps, vessels, etc.) must be evaluated and transmitted to the appropriate discipline for use.
Interfaces in the design process are an outstanding external source issue and, therefore, need to be defined and controlled for all activities covered by the Plan.
Discipline interfaces are addressed in the Collective Evaluation Report.
However, since these reports are prepared after the completion of DSAP and ISAP activities, they may be too late in the process to effectively I
implement any required modifications to the Plan to accommodate information critical to one discipline that is generated by another.
Justify the logic of this approach.
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3.3 External Source Issues One of the objectives of the CPRT is to resolve issues raised by all sources including: NRC staff (TRT, CAT, SIT, SRT, Region IV Inspection Reports and SSERs), ASLB proceedings, CYGNA Independent Assessment Program (IAP),
Intervenors and Applicant. These are referred to in the Program Plan as the " External Sources" and the specific issues they raised as the " External Source Issues." External source issues are identified as being covered in ISAPs and DSAPs. However, all external source issues are not addressed individually in the program plan and issues raised by external sources in an area covered by a DSAP in the Plan are not specifically catalogued.
Our review of the Program Plan with regara to design adequacy, quality of construction and construction QA/QC for mechanical, electrical and instru-mentation systems and their components finds that the External Source Issues addressed in the Issue-Specific Action Plans (ISAPs) and Discipline Specific Action Plans (DSAPs) are primarily those emanating from the TRT SSERs and CY6NA IAP.
The CPRT Program Plan should be augmentea to supplement existing ISAPs and/or DSAPs, as appropriate, to cover all existing unresolved External Source Issues and indicate how those that may be generated in the future will be resolved.
In order to assure that all external source issues have been properly addressed by the CPRT, the Plan must include a complete list-ing of all external source issues including the source that has generated the issue, reference the activity in the Plan which addresses the issue, how the issue will be closed, and a space should be provided for close out signature by a responsible member of the CPRT-SRT.
Additionally, the Program Plan should be augmented to include information to meet the commitment of addressing the potential root cause and generic implications associated with those issues which have been raised by an External Source and subsequently closed by that source.
3.4 Cable Tray / Conduit Supports This DSAP does not address a major engineering activity in the area of cable tray supports being performed by EBASCO. The DSAP, as presented, appears to base acceptance of trays and supports on overall functionality.
However, the CPSES FSAR defines AISC as the governing criteria for cable tray /conouit supports. The Program Plan proposes to (1) conduct tests to justify the use of higher system damping values; (2) use refined modeling methods based on experimental data to compute more realistic loads; and (3) develop new acceptance criteria based upon system performance and functionality. The Plan does not clearly define how Unit 2 cable tray /-
conduit supports are assessed and modified as needed. However, the Plan implies that the above mentioned criteria in general will not be used for Unit 2 items.
Qualification and acceptance of Unit I cable tray / conduit supports through development of acceptance criteria based on system performance and function-ality present a major concern. The approach will most likely lead to reduction of safety margins from those based on FSAR conmitments and there-fore it would be extremely difficult to receive staff acceptance. The DSAP should provide clarification regarding this concern.
3.5 QA/QC Issues The CPRT should justify the exclusion of any venoor or other organization's activities from the construction adequacy review for CPSES. The justification must include the basis and rationale for the exclusions in sufficient detail to permit an independent assessment to determine whether the overall object-ives of the proposed Construction Adequacy Program Plan can still be met without the review of the excluded activities.
Section 1, Page 4, indicates that all the results of the TRT QA/QC SSER 11 (Reference 5 ) have not yet been incorporated into the Program Plan (in particular, those presented in Appendix P of Reference 5 concerning the interrelationship of QA/QC concerns identified by all the TRT groups).
It should be noted that when the results from Reference 5 are incorporateo into the Program Plan, their impact on existing ISAPs and DSAPs should be determined before a decision can be made concerning the final acceptability of the Program Plan. The Applicant is requested to indicate how the QA/QC concerns presented in Appendix P of Reference 5 will be reflected in the appropriate ISAP and DSAP.
The self-initiated evaluation component of the CPRT Quality of Construction and Construction QA/QC Adequacy Program Plan is based on the categorizationofsafety-relatedhardwareconstructedusingsimilar safety-relateo work activities into homogeneous populations, the adequacy of which can be verified using similar reinspection techniques and/or documentation review activities. Our review of the Program Plan could not find the necessary basic information to permit an independent evaluation of how the homogeneous hardware populations are established.
The basis for establishing homogeneous hardware populations has been a subject of concern expressed on various occasions to the members of the CPRT and it still remains unexplained. The staff considers the establishing of the hardware populations as the foundation of the self-initiated Quality of Construction and Construction QA/QC Adequacy Program Plan, and it is essential that the basis for this foundation be clearly stated. The basis and rationale for establishing homogeneous hardware populations must be included in the CPRT Program Plan.
Step-by-step explanation must be provided of how a homogeneous haraware population, such as cables or instrumentation equipment, is formed based on the similarity of the construction process during the construction life of CPSES.
Additionally, the criteria for acceptability are based on the inspection of hardware using a list of attributes which are considered to be vital to assurance of safety significance. Since these attributes are not generic, vary for a given item, and must include design considerations, then the DSAP must provide a basis for attribute determination. The Applicant should supplement the USAPs accordingly.
CPRT implementation of action plans requires the use of CPSES QC inspectors and TUEC QA auditors to perform certain inspection and audit tasks. It is our concern that the implementation program found by the TRT groups regarding the CPSES inspector certifications programs has not yet been corrected, and the participants in the implementation of these action plans are being qualified against the old questionable requirements.
Justify using the CPSES quality control inspectors in view of this concern.
3.6 Piping and Supports i
The major area of concern with the piping and pipe support reanaTysis effort is that the details required for review are contained in procedures Thus, there (CPPP-5 through CPPP-7) which are not included in the Plan.
is insufficient information in the Program Plan to permit an evaluation of the criteria that will be used for the reanalysis effort. The Program Plan should be supplemented to state the reanalysis criteria, or the procedures should be made available for staff review. Furthermore, concerns have been These concerns include raised related to support / piping interdependence.
the ability to properly model the support in the piping analysis so that the piping analytical response and support loading is representative of Because the actual behavior for the uniquely designed support structures.
the staff believes these issues are not representative of standard industry practice, the DSAP (or the referenced procedures, guidelines, or design criteria) should specifically address the techniques to be used in resolving them.
It appears that the adequacy of pipe supports to comply with licensing connitments will be demonstrated by initially reviewing existing analyses rather than performing a reanalysis. A more detailed description of the approach to be used, criteria to be applied, and extent of the pipe support review effort are required.
In the area of small bore piping and supports, a sampling approach will be Since this DSAP is being used to address a significant number utilized.
of external source issues related to the piping and pipe support design and design process and interfaces between disciplines (including instal-lation), more detail should be provided on the techniques and attributes used in the sampling process. SWEC has comitted to requalify only those The CPRT should Class 1 large bore supports not designed by Westinghouse.
ensure that the interface between Westinghouse and SWEC is functioning properly. This is required to account for any effects that pipe support deficiencies have on the existing Class 1 piping analyses (e.g., reduced pipe support stiffness).
3.7 Acceptance Criteria The Program Plan indicates that further evaluations will be bated on the
" safety significance" of deficiencies. This basis may not be consistent with the licensing comitments contained in the FSAR.
When licensing comitments cannot be met, the proposed acceptance criteria must be identified for approval by the staff prior to implementation. In areas for which criteria cannot be established at this time, the Plan should identify tasks which are aimed at quickly providing the necessary input to assist in establishing criteria.
The Applicant should revise the Program Plan to identify areas where licensing comitments:
(1) will be met, (2) will not be met, or (3) acceptance criteria are not determinable at this time.
The Program Plan also states that trends of non-safety significant design deviations will be assessed. It is unclear as to what will be done with the trends identified for non-safety significant design deficiencies and what basis will be used to establish corrective action. The Applicant should clarify how such trends will be incorporated for resolution and disposition.
3.8 Sampling Criteria i
The general approach to sampling is acceptable with the following exceptions. The concern is related to increase of sample size resulting from a failure to meet criteria. In a sample size of 60, the Plan does not permit any failures to comply with criteria. This will result in a 95/5 confidence level. However, compliance with the current FSAR is not the
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criteria applied. The criteria for increasing sample size is a safety i
i significant deficiency. It is necessary to go to Attachment 5 of Appendix f
A of the Plan to determine that deviations may trigger an increase in scope. Since a deviation is a failure to meeting licensing comitments, g'
then to a degree failure to meet licensing comitments can be tracked.
However, the scope will only increase as a result of deviations if it can
i be determined that the deviation would be a deficiency if occurring elsewhere. The Plan should be modified to describe the method for making this determination, which we believe is not generic but rather j
system / location dependent.
The Program Plan indicates that if more than one safety significant deficiency is found in the initial sample, the sample size will be increased in steps up to 100% for reinspection. The Plan further indicates that if the sample size is increased, only the attribute found deficient will be addressed. We do not agree with the assumption that if there is a safety significant deficiency of one type in the initial sample, the expanded samples do not need to consider safety significant deficiencies of other types. The Applicant should either justify this aspect of the sampling program or amend the Plan to indicate that all attributes considered in the initial sample will be also considered in the expanded sample.
3.9 Corrective Actions Our review could not find criteria or guidelines that will be used by CPRT to define corrective action and to judge Texas Utilities Generating Company's (TUGCO) implementation of CPRT-recomended corrective actions.
The CPRT Program Plan should be augmented to describe the criteria or guidelines, and the overview role of the CPRT to assure that the CPSES i
project will satisfactorily implement CPRT-recomended corrective action of identified deficiencies.
The CPRT Program Plan indicates that identified deficiencies and recommended corrective action will be turned over to TUGC0 project for implementation of corrective action under the existing site program. It is our concern that the existing nonconformance reporting and corrective action systems found questionable by the TRT groups, have not yet been corrected by TUEC.
Justify using these systems in view of this concern.
3.10 CPRT/SRT Management Team The staff is concerned about the independence of the CPRT. The Applicant 1
should describe the relationship between the CPSES Project and the CPRT focusing on the protocol which exists to verify the independence of organizational decisions.
3.11 Design Responsibility for Piping In Section II, item 4, the Program Plan identifies Gibbs & Hilj (G&H) as the designer of record for piping. The Plan also states that SWEC has been retained to perform a 100% reanalysis of the Class 2 & 3 piping. The Applicant should provide more details of the interface relationship between SWEC and G&H and CPRT and G&H and demonstrate that all technical considerations involved with the reanalysis effort are addressed. The Applicant should identify the lines of responsibility for piping and pipe supports.
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4.0 CONCLUSION
The NRC staff has evaluated the programmatic aspects of those poFlions of the Applicant's Plan submitted to date, and find that the Plan is comprehensive in scope and provides a structure capable of addressing all existing issues and any future issues identified by external sources. The Plan also contains applicants commitment to a set of self-initiated programs intended to demonstrate the adequacy of design and contruction of the Comanche Peak Project. The Plan is organized to accommodate revisions that may be required during Plan implementation. The Plan provides a commitment to resolve staff concerns and demonstrate overall plant safety.
The staff's evaluation of the Plan has identified certain programmatic concerns expressed in this report. Specific questions with regard to individual issue-specific action plans and discipline-specific action plans will be provided shortly to the Applicants.
Following receipt of (1) modifications responsive to the matters expressed in this report and those detailed in the later submittal, (2) the remaining portions of the Plan and (3) any comments from the other parties and participants, the staff shall document its evaluation and findings of the finalized Plan in a future SSER.
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5.0 REFERENCES
1.
U.S. Nuclear Regulatory Comission Safety Evaluation Rep' ort Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797, Supplement No. 7, January 1985.
2.
U.S. Nuclear Regulatory Comission Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797, Supplement No. 8, February 1985.
3.
U.S. Nuclear Regulatory Comission Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797, Supplement No. 9, March 1985.
4.
U.S. Nuclear Regulatory Comission Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797, Supplement No. 10, April 1985.
5.
U.S. Nuclear Regulatory Comission Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0797, Supplement No. 11, May 1985.
TABLE 1
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MECHANICAL SYSTEMS MATRIX Plant AFW Program Design Elements Systems System Plan 1.
Pipe Sizing X
X 2.
Pipe Wall Thickness X
X 3.
Minimum Flow Requirement X
X X
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4.
Maximum Flow Requirement X
X X
5.
Balanced Flow Requirement X
X 6.
High Pressure Operation X
X X
7.
Heat Removal and Rejection X
(1) 8.
Controlled Chemical Addition X
9.
Radioactive Fluid flow X
10.
Pump Sizing X
11.
Sump Design X
12.
Storage Tank Design X
X(3)
X 13.
Vortex Prevention X
X(2) 14.
NPSH Limitation X
X(2)
X 15.
Pumped Fluid @ or near Sat.
X 4
16.
Open and Closed System Operation X
17.
Support Systems X
X X(4) 18.
High Pressure Non-Safety X
X X
Systems in the area
19 Table 1 (Cont'd)
Plant AFW Program Design Elements Systems System Plan 19.
Temperature Change (>50 F)
X During Operation 20.
Surge Tank Sizing X
21.
Long-Term Operation X
22.
Auto Startup and/or Switchover X
X X
23.
Safety Class Interfaces Within X
X X
System 24.
Single Failure Requirement X
X X
25.
Major Equipment Located in X
X X
Flood Area 26.
Series and Parallel Thermal Loads X
X 27.
Major Equipment Located in X
X X
Radiation Area 28.
Potential for Water Hammer X
X X
29.
Turbine Driven Pump X
X X
30.
Motor Driven Pump X
X X
31.
Change in Elevation (>50 ft)
X X
32.
Located in Fire Protective Zone X
X X
33.
Required for Reactivity Control X
34.
Required for Fission Product X
Removal 35.
Horizontal Centrifugal Pumps X
X X
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Vertical Centrifugal Pumps X
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37.
Positive Displacement Pumps X
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Table 1 (Cont'd)
Plant AFW Program Design Elements Systems System Plan 38.
Maximum flow Velocity Limitation X
39.
Minimum flow Velocity Limitation X
40.
Limited time for Manual Action X
X X
41.
Standby Hydraulic Requirement X
(charge or fill) 42.
Pressure / Flow Control Valve Sizing X
X 43.
Non-Seismic Class Piping in X
X X
Vicinity 44.
Pump Suction or Discharge X
X Monifolding 45.
Steam Piping X
X X
46.
Pump Protection Requirements X
X 47.
Parallel Pump Operation X
(5) 48.
Valve Arrangement and X
X Qualification for Containment Isolation Matrix Notes:
1.
The Auxiliary Feedwater System supplies make-up water to steam generators for heat removal, the system does not have heat exchangers.
2.
Vortexing and NPSH are generally reviewed when pump suction is provided by a tank or sump.
However, since this AFW system is not particularly sensitive to vortexing or NPSH, results of this review will not fully assess the designer's ability to address more complex design requirements.
3.
Tank sizing for this system considers only volume control.
Overpressuri-zation and vacuum prevention due to high flow rates in and out of the tank are not considerations for this system.
4.
The program plan addresses only the HVAC auxiliary subsystems.
5.
Although manifolding allows parallel operation, this system does not require that mode of operation in order to meet flow requirements.
TABLE 2 INSTRUMENTATION AND CONTROL MATRIX 4
I Class IE AFW Power Program Design Elements System System Plan 1.
Process variables used..............
X X
X 2.
Degree of redundancy used...........
X
.X 3.
Instrument channel separation group assignments...................
X X
4.
Instrument channel power source assignments.........................
X X
X 5.
Permissive control logic used.......
X X
6.
Bypass control logic used...........
X X
7.
Interlocks with other systems or equipment...........................
X X
8.
Protective action setpoints used (RG 1.105)..........................
X X
9.
Actuation of pumps, valves, etc.....
X X
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10.
Single failure criterion conformance (IEEE 379)..............
X X
X 11.
Capability for periodic test and calibration (RG 1.22)...............
X X
12.
Separation and isolation requirements (RG 1.75)..............
X X
X 13.
Potential for control system interaction (IEEE 279)..............
X X
14.
Manual initiation at the system level (RG 1.62).....................
X X
15.
System level bypass / inoperative indication (RG 1.47)................
X X
16.
Accident monitoring instrumentation (RG 1.97)...........................
X X
17.
Instrument response time test
' capability (RG. 1.118)................
X X
18.
Instrument environmental and seismic qualification...............
X X
19.
Instrument Procurement specification requirements..........
X X
20.
Instrument rack arrangements........
X X
21.
Instrument tubing routing...........
X 22.
Instrument cabling connections......
X X
23.
Vendor technical data results.......
X X
24.
Instrument identification means.....
X X
25.
Loss of Bus Voltage Sensors.........
X X
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TABLE 3 i
ELECTRIC POWER MATRIX
)
Class 1E AFW Power Program l
Design Elements System System Plan i
A.
Calculations / Analysis 1
A.1 Load Flow / Voltage Regulation A.1.1 Offsite voltage swings........
X X
4 A.1.2 Onsite load changes / operating modes.............
X X
X A.1.3 Voltage dips on DG loading........X A.1.4 Battery discharge voltage profile........
X X
A.1.5 Diesel generator loading voltage profile........
X X
A.2 Short Circuit A.2.1 6.9 kV SWGR........
X X
A.2.2 480V SWGR........
X A.2.3 Motor control Centers........
X A.2.5 Electrical penetration assemblies........
X X
A.3 Cable Sizing
+-
A.3.1 Ampacity........
X X
X A.3.2 Voltage Drop........
X X
X A.3.3 Short Circuit........
X X
A.4 Undervoltage Protections
.A.4.1 6.9 kV Loss of voltage / load i
shedding........
X X
A.4.2 6.9 kV Degraded grid voltage....
X X
1 A.4.3 480V Loss of voltage A.4.4 125 VDC Over/under voltage........
X 4
A.5 Equipment Sizing Calculations A.5.1 Power Supplies A.5.1.1 Diesel Generator........
X X
A.5.1.2 Batteries and Chargers........
X X
A.5.1.3 Inverters........
X X
4 A.5.2 Switchgear i
A.5.2.1 6.9 kV Switchgear Bus & Breaker size........
X I
A.S.2.2 Unit Substation Transformer i
.-,_,__--______...m.__-___
_,,,_..m,_,,-._
TABLE S (cont'd)
Class 1E AFW Power Program Design Elements System System Plan A.S.2.3 480 V Switchgear Bus &
Breaker size A.S.2.4 Motor Control Center Loading........
X A.6 Equipment Protection / Relaying A.6.1 6.9 kV Incoming Breaker / Load Transfer........
X X
A.6.2 6.9 kV Tie Breaker........
X A.6.3 DG Output Breaker........
X A.6.4 6.9 kV Motor Feeder Breaker..... X X
A.6.5 Unit Sub Transformer Primary BKR A.6.6 480 V Bus Incoming BKR A.6.7 480 V Bus Motor Feeder BKR A.6.8 480 V MCC Feeder Breaker A.6.9 MCC Motor Feeder Circuit........
X A.6.10 MCC MOV Thermal Overload........ X A.7 Electrical Penetration Assembly A.7.1 6.9 kV........
X
~~
A.7.2 480 V Power (Large)-
A.7.3 480 V Power (Smal.1)
A.8 Coordination Studies A.8.1 6.9 kV SWGR........
X X
X A.8.2 480 V SWGR A.8.3 480 V MCC........
X A.8.4 125 VDC SWGR........
X A.8.5 Inverter PWR Distribution........
X A.8.6 appendix R Studies........
X X
X A.9 Underfrequency Protection Reactor Coolant Pump (NSSS Interface)
B.
Equipment Specification Preparation B.1 ' Power Supplies B.1.1 Diesel Generator........
X X
B.1.2 Batteries & Chargers........
X X
B.1.3 Inverters........
X X
B.2 Switchgear B.2.1 6.9 kV Bus........
X B.2.2 480 V Unit Substation B.2.3 480 V MCC........
X X
B.2.4 125 V Switchboard........
X
l TABLE 3 (cont'd)
Class 1E AFW Power Program Desian Elements System System Plan B.3 Cable B.3.1 8 kV Power Cable........
X X
B.3.2 600 V Power Cable........
X X
B.3.3 Control Cable........
X X
B.3.4 Instrument Cable........
X X
B.4 Motors B.4.1 Large Frame Motors........
X X
B.4.2 NEMA Frame Motors........
X X
B.4.3 Valve Motor Operators........
X X
B.5 Containment Electrical Penetrations Assemblies B.5.1 Medium Voltage Penetrations........
X X
B.5.2 Low Voltage Penetrations B.6 Support Equipment B.6.1 Diesel Load Sequencer........
X B.6.2 Isolation Cabinets B.6.3 Heat Tracing System B.7 Support Components B.7.1 Environmental Seal Assemblies B.7.2 Fire Seals and Barriers B.7.3 Medium Voltage Terminations and Splices........
X B.7.4 Wire Terminals & Splices........
X(1)
NOTE:
(1) External Source Issue C.
Drawing Development C.1 'One Line Diagrams C.1.1 6.9 kV Bus........
X X
X C.1.2 480 V Bus C.1.3 480 V MCC........
X X
C.1.4 DC Bus........
X X
C.2 Schematic or Elementary Diagrams C.2.1 6.9 kV C.2.1.1 DG Output Breaker X
X C.2.1.2 Incoming Breaker........
X C.2.1.3 Tie Breaker........
X C.2.1.4 Large Motor Feeder Breaker........
X X
X v
3 TABLE 3 (cont'd)
..~
l Class 1E AFW Power Program Design Elements System System Plan i
C.2.2 480 V C.2.2.1 Motor Feeder Breaker...
X C.2.2.2 Non-Class IE MCC Feeder Breaker........
X C.2.2.3 MCC-Pump Motor Feeder CKT........
X X
C.2.2.4 MCC-Valve Operator CKT........
X X
C.3 Wiring Diagrams C.3.1 Control Wiring Diagram........
X X
C.3.2 Cable Block Diagram........
X X
C.3.3 Internal Wiring Diagram........
X C.4 Layout Drawings C.4.1 Equipment Arrangement Drawings C.4.1.1 General Arrangement Drawings........
X C.4.1.2 Equipment Foundation Drawings........
X C.4.2 Raceway Drawings C.4.2.1 Underground Duct Layout........
X X
X C.4.2.2 Cable Tray Plans and Sections........
X X
X C.4.2.3 Exposed Conduit Drawings........
X X
X C.4.2.4 Embedded Conduit Drawings........
X X
X D.
Desian Implementation Lists D.1 Equipment List
,D.1.1 Class 1E Equipment list........
X X
D.1.2 Remote Safe Shutdown Equipment List........
X X
X D.2 Cable Routing Schedules D.2.1 Cable Schedules........
X X
X D.2.2 Conduit Schedules X
X (Size & F111)........
Y TABLE 3 (cont'd) l Class 1E AFW Power Program Design Elements Systems System Plan E.
Installation Documents E.1 Installation Contract........
X E.2 Installation Notes & Details.
X E.3 Project Separation Guide........
X F.
Vendor Document Reviw F.1 Equipment Data F.1.1 Data Sheets........
X X
X F.1.2 Performance Curves.
X
'X X
F.1.3 Outlining / Mounting Details........
X F.1.4 Wiring Diagrams........
X F.1.5 Bills of Materials........
X F.2 Equipment Qualification Information F.2.1 Environmental Qualification.
X X
X F.2.2 Seismic Qualification........
X X
X 4
F.3 Installation, Operation & Maintenance Manuals........
X X
G.
Interface G.1 External G.1.1 Utility........
X G.1. 2 NSSS........
X G.1.3 NRC (IE Bulletin........
X X
& Info. Notices)
G.1.4 Vendor........
X X
X G.1. 5 Industry (eg-INPO)........
X G.2 Internal G.2.1 I&C........
X X
X G.2.2 Mechanical Power........
X G.2.3 HVAC........
X X
X G.2.4 Mechanical Equipment........
X X
X G.2.5 Environmental Qualification..... X X
X G.2.6 Structural........
X X
G.2.7 HELB........
X X
X G.2.8 Site Engineering........
X G.2.9 Startup........
X X
G.2.10 Site Construction........
X X
DISTRIBUTION
.DeckdTile NRCPDR LPDR NSIC PRC System LB#1 R/F MRushbrook AVietti-Cook OELD ACRS (16)
EJordan JPartlow BGrimes VNoonan R/F SBurwell CTramell CEarly STReby LChandler GMizuno TWesterman (Region IV)
HLivermore (Region III)
RKeimig(RegionI)
RDenise(RegionIV)
l t
Docket Nos.: 50-445 and 50 446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L. G. 81 Dallas, Texas 75201
Dear Mr. Counsil:
l
Subject:
NRC Staff Evaluation of the Comanche Peak Response Team Program Plan The staff has completed its initial review of the programmatic aspects of i
those portions of the Comanche Peak Response Team (CPRT) Program Plan (Plan) submitted to date and find those portions of the Plan to be comprehensive in l
scope and to provide a structure capable of addressing all existing issues and any future issues identified by external sources. The Plan also contains applicants commitment to a set of self-initiated programs intended to demonstrate the adequacy of design and construction of the Comanche Peak Project. Provided as an enclosure are the staff's comments with regard to the programatic concerns that have resulted from the staff's review of the Plan.
These comments must be satisfactorily resolved prior to final staff approval of the Plan. We will soon be providing specific comments with regard to individual issue-specific action plans and discipline-specific action plans.
The staff notes that portions of the Plan (e.g. the CPRT umbrella QA program) remain to be submitted by Texas Utilities to the staff. Upon receipt of additional portions of the Plan, the staff will promptly review them and provide you with the results of the staff's review. We had very preliminary discussitns of the enclosed staff evaluation with you and CASE on August 6, 1985. The staff expects to receive CASE's detailed comments on the Plan in the near future and intends to fully review them.
In the event our review identifies matters raised by CASE's comments which the staff finds warrant responses by Texas Utilities, the staff will advise you of such matters.
We expect to meet with both you and CASE at some appropriate time in the future to discuss the program plan.
Sincerely, Vincent S. Noonan, Director for Comanche Peak Project Division,of Licensing
Enclosure:
NRC Staff Evaluatio j
cc:
See next page i
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