ML20137X545
| ML20137X545 | |
| Person / Time | |
|---|---|
| Site: | South Texas, 05000000 |
| Issue date: | 09/11/1981 |
| From: | Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20137X502 | List: |
| References | |
| FOIA-85-519 NUDOCS 8603100157 | |
| Download: ML20137X545 (131) | |
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MEMORANotM FOR: File
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G. L. Madten, Chief, Reactor Projects Branch W. A. Crossman, Chief, Reactor Projects Section 3 FROM:
W. G. Hubacek, Reactor Inspector
SUBJECT:
MEETING WITH HL&P MANAGEMENT RELATED TO QUADREX REVIEW 0F' SR0tM AND ROUT ENGINEERING, SOUTH TEXAS PROJECT (DN 50-498; S0-499) i On September 8,1981, a emeting was held in the Region IV office to discuss the resultr of a review of Brown and Root (84R) engineering performed by the Quadrex Corporation. The folicadng personnel ' attended the meeting:
l K. V. Seyfrit, Director, RIV J. T. Collins, Deputy Director, RIV G. L. Madsen, Chief. Projects Branch, RIV U. Potapovs. Chief, Vendor Inspection Branch (VIB), RIV W. C. Seidle, Chief. Engineering Inspection Branch, RIY W. A. Crossman, Chief. Projects Section 3. RIV C. J. Hale, Chief, Anactor Systems Section, VIB, RIV J. E. Gaglia%, Director, Investigation and Enforcement Staff RIV H. S. Phillips, Resident Reactor Inspector, RIV i
W. G. Hubacek, Reactor Inspector, RIV M. W. Peranich, DRRI, IE:HQ G. W. Oprea, Jr., Executive Vice President, HL&P J. H. Goldberg, Vice President, Nuclear Engineering & Construction HL&P Messrs. Oprea and Goldberg described the engineering review of B&R which was ccnducted by Quadrwx under contract to HLAP. The review was prompted, in part, b3 Mr. Goldberg's. recognition of the need to obtain an iM+;d-5.t evaluation of B&R's performance in that the South Texas Project was 8&R's first nuclear A/E effort. Mr. Goldberg's pmvious experience with other A/E organizations led him to suspect that 8&R engineering was not performed to current A/E levels of performance.
Quadrex performed the engineering review during the period February 1981 to April 1981. The review was based on 277 questions that wem formulated by disciplines. The review resulted in approximately 288 findings which have been evaluated by HLAP and 84R and appear to identify eleven significant
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problem areas. The problem areas are as follows:
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Computer code verification 2.
HVAC faulted condition heat loads 3.
Pipe break analysis outside of containment 4.
ALARA considerations 5.
ISI.and maintenance requirements 6.
Nuclear Analysis 7.
Vendor and subcontractor control 8.
Design verification program 9.
Integrated systems review
- 10. Interference review
- 11. Tracklog of licensing caemitments Quadrex also concluded that BAR lacked experienced engineers. Str. Goldberg agreed with this conclusion and stated that 8&R appears to be operating at the level of A/E's that existed approximately ten years ago and does not t
sufficiently understand requirements for nuclear work. He expressed concern l
over B&R's reluctance to reorganize or restructure an am of the coepany to j
enhance their nuclear capability.
Following HL&P's evaluation of the findings, thme items were reported to RIY as significant construction deficiencias in accordance with the requirements of 10 CFR 55.55(e). These items included: HVAC faulted condition heat loads, ensputer program verification, and shielding calculations.
As follow-up to problems identified in the Quadrex review. HL&P has developed an action plan with milestones that. address the problem areas. The site work l
force has been reduced and work activities wem devoted primarily to rework.
No new mechanical or electrical work will be started. Some engineering work has been subcontracted and additional subcontracting is under consideration.
Reviers are in progmss in areas such as structural design and loading.
Mr. Goldberg tamed the impact of the Quadrex findings a " disaster" for HL&P in that construction of STP will probably be set back at least 12 months.
In response to the RIY Director's request, Mr. Opera stated that HL&P would notify the NRC if the conditions identified in findings in the Quadrex report are found by further evaluation to constitute a program breakdown as defined in 10 CFR 50.55(e).
tnal Signed MRt CRossM&N8' W. G. Hubacek Reactor Inspector
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'NRC RIV QUADREX REVIEW INTEROFFICE MEMORANDUM REFERENCE DOCUMETIT
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BROWN & ROOT, INC.
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E. A. Saltare111 DATE: September 11, 1981 FROM:
F. E. Mue11ner
.GM 91311
SUBJECT:
STP HL&P/Quadrex Engineering Review
References:
1.
STP Quadrex Engineering Review of May 8,1981 2.
HL&P Letter of May 6, 1981 3.
B&R Letter ST-BR-HL-38718 of May 8,1981 4.
B&R Letter Rice to Stello of May 12, 1981 5.
B&R Letter ST-BR-HL-38566 of May 4,1981 The purpose of this memorandum is to summarize the Bmwn & Root actions takEn to date relative to the STP HL&P/Quadrex Engineering Review of May 8,1981, and to present our position relative to the "Most Serious Generic Findings" contained in the report of the above review (Reference 1).
Brown & Root performed an initial, expedited review of Reference 1 in accor-
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dance with Reference 2 and advised Houston Lighting & Power as to whether the
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"most serious" items identified in Reference 2 constitute a reportable prob-lem in accordance with 10CFR50.55(e), Reference 3.
All items were judged not reportable except for 4.4.2.1(a)/(b), which was considered potentially re-portable as described in Enclosure 1 to Reference 3.
Brown & Root subsequently reported one item in accordance with 10CFR21 in Reference 4.
In addition, Brown & Root has accelerated implementation on the following programs which, for the most part, were already in place or were planned:
1.
Computer Procrams. The computer code assessment program was initiated as a result of findings from Brown & Root internal audit performed in December 1980. These audit findings were consistent with the findings of the Quadrex review. The computer code assessment program is continu-ing. Because of the increased importance identified with this activity, the effort is being accalerated. The program includes CPVR review to judge the qualification of the codes used on STP and review of calcula-tions for appropriate application of computer codes. This is a phased program with insnediate emphasis being placed on nuclear analysis. Assis-tance for this effort by a consultant (Energy Incorporated) has been solicited.
I 2.
HVAC. Accelerated review of pertinent STP HVAC systems has been under-way with NUS and Westinghouse consulting assistance.
l 3.
Pipe Brecks Outside Containment. Efforts are being accelerated with consulting assistance being solicited from Westinghouse and NUS.
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ALARA. An ALARA program has been established with joint HL&P, NUS, and B&R participation. Phase I, Model Review, has been completed.
5.
Interference Review. An Interference Review program has been estab-lished as outlined in Reference 5.
Augmented internal review procedures are being implemented to reduce development of new interferences, and a multi-discipline interference ' review comittee has been established to accelerate interference resolution.
6.
ISI and Access / Maintenance Review. A program is being accelerated through augmented staffing of existing B&R ISI task force. Participa-tion by HL&P will be solicited.
Due to the potential licensing impact of the "Most Serious Generic Findings" discussed in Reference 1, we have performed an evaluation of these items as reported in Enclosure 1.
We have concluded that the detailed discussions in Volume II and III of Reference 1 do not support the generic findings as presented in Volume I.
Although a Quadrex Proolems Tracking System has been developed to establish a schedule to respond to all 288 " concerns" expressed in the Quadrex report, we believe these items should not be pursued on a high priority basis. The programs outlined above which are already in place will handle the " concerns" raised by Quadrex in the normal evolution of the design process. Pursuing response to the 288 items on a high-priority basis interferes with the effort being expended on the reestimate due in August 1981 and the nonnal on-going engineering work identified in the 1981 schedule. The effort expended to date (over 7,000 manhours) in participating in this design review has already significantly impacted the engineering schedule. Enclosure 2 documents our work to date in connection with the 288 detailed " concerns."
Unless directed otherwise, we do not plan to pursue these matters further, other than in the programs already established, h
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F. E. Mue11ner NRC RW QUADRIX P.EVIEW REFERENCE 300UMENT nya L
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Enclosures 1 and 2 File No.:
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C. L. Buck R. W. Peverley S. M. Dew D. L. Talley J. L. Hawks E. C. Walley i
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ENCLOSURE 1 to ST-BR-HL-38718
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GENERIC FINDING 3.1(a)
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In reviewing Quadrex Generic Finding 3.1(a), it has been noted that the response can be broken basically into five concerns. They are:
1 1.
Concern relative to effect of integration of syste design.
2.
Concern that design review process could easily overlook equipment physical arrangment and separation requirments.
3.
The discipline structure is too tightly organized on a purely discipline basis.
4.
The ability to achieve internal consistency due to high personnel j
turnover.
l The lack of a single failure criteria doceent.
5.
The following infomation is offered in response to these five areas.
1.
During the Quadrex audit, Quadrex did not review the efforts of the I
Brown & Root System Design Assurance Group. Quadrex verbally comented that the effects of this group had not yet been evident in design docu-ments; therefore, they did not consider the existence of this group.
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It should be noted that the basic reasoning in feming the System Design Assurance Group some 18 months ago was to provide an overview function within the Brown & Root design process for ensuring the effec-tiveness of our system integration process. The System Design Assurance Group has completed its first phase of this activity and has identified to the various disciplines additional items to be incorporated into the design. The workings of this group is doceented in Project Procedures and they have proven to be effective in providing the overall integration 4
l required.
2.
Similarly, it was recognized about two years ago that plant arrangements needed to be reviewed and systematically evaluated to assure that inter-ferences and other physical concerns relative to equipment layout were being adequately addressed. The Physical Design Assurance Group was l
formed comprised of two major components, physical modeling and i
computerized modeling. This group has been evaluating the major plant l
areas for interference of basic components, and accessibility for main-tenance and in-service inspection. Brown & Root does concur with the i
fact that the concentration of this group has been, to date, primarily on the physical interference aspect. We are currently in tre process of increasing the attention of this group to maintenance. ISI, ALARA, and other similar activities. Also, a series of systems hazards review drawings have been prepared which evaluate all physical areas for factors i
such as fires, missiles, pipe break, etc.
NRC RIV QUADREX REVIEW t
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3.
Quadrex expressed a concern over the fact that the technical disciplines were organized very tightly and they infer that there was not a routine follow-through with the discipline input / output -interface. It is very difficult to ascertain from any of the specific Quadrex responses the basis for this assessment. The one specific statement where Quadrex claims that the Mechanical Group tes not pemitted to review I&C logic diagrams is incorrect. There is significant evidence in the files in the Document Control Center showing review and comments from the l
Mechanical Group to the I&C Group concerning systa logics.
4.
Quadrex expressed a concem relative to the consistency of various documents due to the high turnover of personnel, particularly in the area of plant-separation. Brown & Root had previously recognized such a need and in fact, has issued a Separation Criteria TRD. The activity of the safety system hazards analysis is providing the very criteria for use by our engineers that Quadrex appeared to criticize Brown &
Root for lacking.
Quadrex expressed a concern that there was not in a controlled doctment 5.
a multi-disciplinary interpretation of single failure criteria. This is a correct statement; however, as the design demonstrates, we have adequately addressed single failure criteria and have through the System Design Assurance Group, pmvided a single activity to review all discipline interpretations to assure that the single failure criteria has been applied consistently by all the Project disciplines.
In sumary, we concur with some of the Quadrex findings; however, all have i
been previously identified and actions taken within the Project to assure that the STP design was totally adequate. It should be noted that the only specific reference given to this generic concern by Quadrex was Question H-6, which was a question regarding how the HVAC system design incorporates single failure into its separation criteria. The Quadrex response or assessment stated that we had no written criteria for physical separation to protect against postulated fires, high energy lines, and also that the fire hazards analysis perfomed by a contractor directly for HL&P had not been converted
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into a controlled document. It appears that Quadrex did not discover that we were in fact in the process of issuing the criteria document as part of our recent system hazards analysis and in fact, negotiating a contract with NUS to revise the previous fire hazards analysis and issue it as a controlled i
Project document.
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NRC RIV QUADREX REVIEW REFERENCE DOCUMEf4T U
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Encitsure a GENERICFINDIhG3.1(b) gh BROWN & ROOT REVIEW 0F ENGINEERING DATA f
Generic Finding 3.1(b) notes the following:
1.
" Input data to a technical group does not appear to be consistently reviewed by that group for its reasonableness prior to use...".
2.
" Calculations containing errors are being reviewed and verified as correct with a higher frequency than should be encountered."
3.
"B&R review of vendor submitted reports is not consistent."
As Quadrex pointed out, this generic concern can be broken into three items.
First, conarn relative to technical groups not adequately reviewing input data from other groups for its reasonableness prior to use. Secondly, the calculations.containing errors are being reviewed and verified with a higher frequency than should be encountered; and third, our review of vendor submitted
.I reports is not consistent.
1.
Quadrex appears to have a different concept on how Engineering activities are performed than does Brown & Root. Quadrex appears to think that one discipline should somehow formally be responsible for the input given to it by other disciplines. It always has been the practice on this Project that if infonnation transmitted from one group to another appears to be
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totally out of line with what that engineer is accustomed to, he will discuss his concerns with the group transmitting the data. However, the i
responsibility for the accuracy and reasonableness of such data must lie with the originating group. In reviewing the specific questions referenced relative to this finding, it is very difficult to trace the i
spe:ific concern of Quadrex to these itens. Brown & Root statements made at to Mw heat loads were assisned in the HVAC area or how input from j
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Westinghouse was utilized are totally defensable, and do not indicate or in arty way infer that infonnation is not reviewed for reasonableness prior to being used. The approach being used by Brown & Root is not inc.onsistent with good engineering practice exercised by other Architect-Enaineers.
2.
This concern alleges that subsequent to review and verification, cal-culations were found to contain errors with a higher frequency than i
should have been encountered. In reviewing the specific review ques-tions, once again, it as impossible to ascertain the degree of signi-ficance that Quadrex placed with the wording of this finding. This iten is 1Micative of the difficulty we find in responding to generalized Quadrax findings even in specific areas; for example, a review of the four questions referenced here provides the following:
Question C-16, Quadrex assessment quotes that " Brown & Root's design verification procedure appears to be adequate or above industry standards on paper." On the otherhand, they express
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a concern of how effective we have implemented the procedure NRC RIV QUADREX REVIEW i
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ERE_M NARY gs and state that there was evidence that a significant number of mistakes had passed through the verification process. However, no specific reference to any calculation or calculation number was given and 'no basis was given for the statement of "a sig-nificant number of mistakes" or how the results compare with experience at another Architectural Engineers.
Question H-15, which is referenced, basically states that we did not take into account the effects of restriction of air flow in the Reactor Cavity area. This was a potential reportable con-dition which had been identified by Brown & Root prior to the Quadrex audit, and was under evaluation. This in itself, is not an indication of significant errors in calculations.
Similarly in Question N-1, a single concern relative to a large temperature error was identified; however, in the Quadrex assessment, it stated that the occurrence of such an error is neither unconson nor a sign of 10 adequacy. Further, in their response, they stated that calculations reviewed were well organized, as were the verifica-tions. Again, this single concern does not provide.the basis for a significant large number as referenced in thier generic finding.
Finally, in referenced Question N-17 Quadrex assessment indicated that f-(
there was either an error or an inconsistency with a calculation and that this condition needed to be evaluated; however, once ag.in there was not specific reference to a significant number of mistakes as indicated by the generic finding.
3.
Quadrex indicated that they felt that our review of vendor submitted reports was not consistent. They also indicated a concern that the interface we have with such major subcontractors, as EDS and Westing-house, raise many questions regarding overall technical adequacy of the interface with these suppliers. Brown & Root again is confused as'to Quadrex's concern in this area, particularly relative to the EDS interface, in that in response to the questions on the EDS area Quadrex reported on Page 4-74, "In general. EDS in contaiment design analysis appears to be technically adequate." "There were no findings in EDS scope that are expected to seriously impact plant licensability." In addition, on Page 4-75, the following quote appears "In the EDS scope, there were no findings that pose a concern for the plant to generate reliable power." M th these findings from Quadrex, we would assume that they have conclehd 9,at the interface between Brown & Root and EDS has been adrWik.
< wn & Root interface with Westinghouse is such that we are remg Me for evaluating technical adequacy of the i
interfaces; howeve, it is not our responsibility to evaluate their internal analysis methods. In sumary, we share Quadrax concerns in some isolated areas relative to a specific review of a vendor package; 7
however, once again, we do not feel that the back-up infonnation supports the degree in which Quadrex expresses this concern.
ay NRC RIV QUADREX REVIEW-REFERENC DOOUMENT g
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PLANT OPERATING MODES AND ENVIR0tMENTAL CONDITIONS ANALYSIS Generic Finding 3.1(c) notes the following:
1.
" Thorough and consistent treatment of various plant operating modes and enviromnental conditions was not evident" and "no written design basis are provided to guide designer in combination of events and plant i
modes to be considered."
2.
" Consideration of degraded equipment not evident".
3.
" Design criteria do not adequately reflect recent developments."
4.
"As'sumed ' worst case' conditions may not properly bound the set of anticipated plant conditions." (Questions H-3 and N-17).
5.
" Assumptions regarding door and hatch positions seem unrealistic..."
- 6. " Failure to consider off-site power condition in a timely manner has led to recent studies and the need to upgrade certain safety-related HVAC systens to safety related (Question H-5)."
- 7. "The absence of postulated line cracks and breaks outside containment is inadequate (Question M-3. M-5. N-1, and N-3)."
Similarly, the inability of Nuclear Analysis to develop appropriate enviromental conditions for these areas in a timely manner is else inadequate."
The following infonnation is offered in response to these areas:
1.
Operation requirements are covered in 5D005. Engineering Procedure for Design Assurance Reviews, and the operations section of the respective Systen Design Descriptions; these requirements are defined in Appendix A to SDD 002. " Outline for Active System Design Descriptions" Opera-tional Requirements (9.2 and 9.3).
Nonnal envirorsnental conditions were covered in the system designs and are evident in Section 2. (De-sign Requirements) and Section 3. (Operating Modes and Design Features) of individual SDD's. Estimates were made for off-nonnal and accident conditions based on experience with other similar nuclear plants. There is an on-going program to review the design for envirorsnental conditions such as pipe breaks and loss of power.
- 2.. Degraded equipment perfonnance is incorporated into the plant design in the fonn of fouling factors and filter loading contributing to in-creased system pressure drop and degraded heat exchanger heat transfer capacity. Further, safety systems take such degration into account through the " single failure" design feature. Consideration of other possible equipment degradation is scheduled for review during Phase II of the Design Assurance Program.
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NRC RW QUADP.EX REVIEW Q/
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3.
The adequacy of the Brown & Root design process is acknowledged by the Quadrex statement, " Design criteria provided in issued System Design Descriptions (SDDs) and Technical Reference Doc ments (TRDs) appear to adequately reflect industry issues for the 1973-1975 time frame; however, they do not adequately address more recent developments...". It is noted that the 1973-1975 time frame is precisely when the initial STP plant design occurred.
More recent developments including TMI are being addressed as on-going programs, both within the disciplines and by the Design Assurance Group.
4.
Two cases are cited by Quadrex as examples of where assmed worst case design conditions were not bounding. Contrary to the implication that these were a " finding" by Quadrex, these cases were specifically identi-fied by Brown & Root to Quadrax and were being worked on prior to initia-tion of the Quadrex Engineering Review. These are: H-3, HVAC design, and N-17. ECP design. The HVAC design was reported in S&R letter ST-BR-HL-38718 of May 8,,1981..This was identified as a potentially reportable problem in accordance with 10CFR50.55(e) and a surmary of the problem was given in Enclosure (1) to the above letter.
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A change has been scheduled in the ECP Technical Specification Tempera-ture limits to incorporate updating of the calculation for the most I
severe plant and weather conditions. Satisfactory equipment performance under the slightly higher temperatures is being verified.
HL&P will be kept apprised of the status of the above items.
5.
This "most serious generic finding" by Quadrex that B&R's "asseptions regarding door and hatch positions seen unrealistic" is totally un-supported by the example cited (H-14). In this example, the complete Quadrex assessment reads: "B&R control room pressurization HVAC cal-culation is adequate."
6.
Contrary to the Quadrex implication, loss of off site power has been considered since the early stages of the Project dating as far back as pre-PSAR era. This requirement is periodically reviewed and updated as part of the normal design evaluation and the need for upgrading has been identified in such instances as Special Probism #16. The fact that this HVAC problem had been identified and is being worked on was pointed out to Quadrex but apparently was not considered in the "most serious generic finding" section of the report. On the other hand, in the detailed discussion of Question H-8 in Vol. II, Quadrex acknow-1 edged the following: "Quadrex was informed by HL&P that a special task is now underway to study the need for additional safety related HVAC systems."
NRC RW QUADREX REVIEW REFERENC DOCUMENT No.
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As Quadrex was infomed, the program for break analysis outside of contairunent is underway. Results for pipe breaks outside of contain-ment in the IVC are in final stages of completion. Since remaining high energy lines outside containment are minimal, work on these has been scheduled for 1981 implementation. These will form the basis for the envirorsnental conditions evaluation by Nuclear Analysis.
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NRC R1Y QUADREX REVIEW l
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SAFETY RELATED VS. NON-SAFETY RELATED DISTINCTIONS F
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Generic Finding 3.1(d) notes:
1.
"It was observed on many occasions that B&R uses a very sharp distinc-tion between S/R and non-5/R categorizations for both equipment and calculations. A non-5/R designation results in the design outputs not being subjected to design verification."
2.
"It was frequently stated during the design review that only NRC re-cuirements must be met whether or not those requirements are accurate, reasonable, or even meet the intent of the regulations."
3.
"There has been no planned effort to review new NRC requirements (excluding TMI-2 concerns) to determine their impact on STP."
The following is offered in response to these areas:
4 1.
All B&R design documents as well as supplier doceents are reviewed and checked by B&R. The sharp distinction cited deals with a project pro-cedure for formal doceentation of these reviews and the resolution of any consents generated during the reviews. The existing B&R procedures 4
and doceent designations are adequate in this regard. In the design of a nuclear power plant, it is mandatory that a sharp distinction be l
maintained between S/R and non-S/R systems from a licensing point of r
view. B&R concedes, however, that regardless of system classification.
computer codes should be verified as a matter of good engineering practice.
I This action is being taken.
2.
The statement that, "It was frequently stated during the design review that only NRC requirements must be met, whether or not those requirements are accurate, reasonable, or even meet the intent of the regulations" is a misrepresentation of the Brown & Root position. B&R endeavors to 4
satisfy regulatory requirements as a mandatory requirement. However, the B&R position is that regulations and standards are not substitutes for technical understanding, or engineering judgment. In the final analysis, engineering judgment prevails. The designer interprets the requirements and implements these requirements by placing emphasis on 1
those considered to have the most serious impact on the design. Secondary effects are considered but these cannot become overriding to the extent
,that the fundamental function of the system is compromised by a pos-tulated event with a low probability of occurrence.
3.
This statement is not correct. Brown & Root consistently reviews NRC requirements applicable to STP at both the discipline level and the licensing level.. In addition, the Special Projects Grcup will evaluate, where appropriate, the implementation of such requirements.
NRC RW QUADREX REVIEW f,
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h GENERICFINDING3.1(e) f FMEA AND SINGLE FAILURE CRITERION
\\c The Generic Finding 3.1(e) notes the following:
1.
The supporting specific "most serious finding" (4.3.2.1) to this generic finding " suggests that B&R is not sufficiently experienced in the per-fonnance of Failure Modes and Effect Analysis that crosses discipline boundaries."
2.
"No guidelines exist on what types of failures should be considered for various types of equipment." "There is no doc eented evidence that the single failure criterion has been satisfied." "One concern is the varied ' interpretation by individual disciplines that can be given to ' direct and consequential failures' resulting from a postulated event."
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3.
"An HVAC/I&C single failure criterion violation has been noted (Questions R-6 and E-15)
The following is offered in response to these areas:
1.
Brown & Root disagrees with this statement. Quadrex has used-an isolated incident to assume this conclusion. Examples of B&R
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FMEA's crossing discipline boundaries are as follows:
FSAR Table Ref.
System FMEA 7.3-12 Control Room Ventilation Isolation Actuation 7.3-13 Containment Building Purge Isolation Failure 8.3-8 D.C. Power Systems 8.3-9 Auxiliary AC Power System 8.3-13 120-Vac Vital Instrumentation Power System 9.2.1-2 Essential Cooling Water System 9.2.2-3 Component Cooling Water System 9.3-2 Air-Operated Valves 9.3-12 Chanical and Volwne Control System 9.4-5.1 Control Room & Elect. Aux. Building HVAC System 9.4-5.2 Fuel Handling Building HVAC Systen 9.4-5.3 Mechanical Aux. Building HVAC System 9.4-5.4 Turbine Generator Building HVAC System 9.4-5.5 Reactor Contaiment Building HVAC System 9.4-5.6 Diesel Generator Building HVAC System 9.4-5.7 Miscellaneous Buildings HVAC System Fire Protection System 9.5-2 Diesel Generators 9.5.5-2 10.4-3 Aux. Feedwater System 10.4-4 Turbine Bypass System (TBS)
Contrary to Quadrex statenents, the FMEA approach has also been used to ensure adequate design.
after the FSAR period where appropriate _
NRC RIV QUADREX REVIEW REFEREN DOCUMENT 9
No. --
e
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GenericFinding3.1(e)
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I pg{hh h
Page 2 Finally, updating of Failure Mode and Effects Analysis has been assigned.
to the System Design Assurance Group. This discipline was established in late 1979 to ensure that systems level integration was in fact present on the Project. The group has been assigned the responsibility of perfoming FMEA's on the components of the system the system itself.
and all interfacing systems, and will use written procedures reflecting present day FMEA practices.
2.
STP Procedure SD-002. Engineering Procedure for System Design Descrip-tions Appendix A. Section 9.3 requires that Section 4.3. " Casualty Events and Recovery Procedures" include a " list of all casualty events considered in the design such as:
o Loss of instranent air.
o Single failures.
o Operator errors, etc."
Therefore, the SDD's specifically address all failures that have been i
i considered. These documents are being reviewed by all design disciplines including the System Design Assurance Group, to ensure a consistent approach.
It is acknowledged that updating of System Design Descriptions is
{
required in certain areas to reflect design evolution. However, this was recognized well before the Quadrex review and a program ses developed l
in October of 1980. This work has been scheduled and is being incorporated into the Re-estimate Plan in the nomal conduct of the design.
Through the influence of the Design Assurance Group. B&R feels that a consistent interpretation of failure analysis will be achieved. This is borne out in the results of the Phase I reviews to date.
3.
In the alleged " single failure criterion violation" cited, the following conditions exist: Dampers to the two redundant HEPA-charcoal filter trains are held closed by air pressure. High radiation in the Fuel 4
Building actuates a three-way solenoid valve. This action both removes supply air pressure to the dampers and vents the line causing the dampers i
to open. The Quadrax contention is that a connon exhaust line may become blocked thus disabling the system with a single failure. This contention is not credible for the following reasons:
Blockage of exhaust lines is precluded by the following design a.
features:
1.
Exhaust lines to the damper actuators are larger in size than supply lines. Therefore if foreign matter were large enough to a
~
became lodged in an exhaust line it would be unable to pass
.g,,
through supply lines.
NRC Rn' QUADREX RZylEW REFERENCE DOCUMENT N
NO.
10
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i Enc 1rsure 1 Generic Finding 3.1(e) f ld k Page 3 2.
Air supply is filtered to preclude introduction of foreign matter.
3.
Instrument air driers are installed to preclude foreign matter due to corrosion.
4.
Possibility of crimping precluded by a physical barrier around the exhaust lines.
b.
If a non-mechanistic blockage of the exhaust line were assumed, damper will still open since supply air is cut off and venting would be accomplished through nomal system leakage.
c.
Finally, if a. non-mechanistic failure of the system to operate were assuned, the stack radiation monitor (albeit Non-1E) will warn the operator to take the necessary action (i.e., manually secure systen).
Besed upon the above considerations. Brown & Root does not consider the pos-tulated accident credible and does not plan to modify the design. It should be pointed out, however, that the System Design Reviews being conducted on the plant systens do encompass a systematic review of non-mechanistic
(
failures to detemine the impact of the ability of the system to function
\\
when called upon to perfom.
I NRC RIV QUADREX REVIEW REFERENC DOCUMENT NO.
11
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g35A GENERICFINDING3.1(f)
FSAR COPMITMENT TRACKING r8 This Generic Finding 3.1(f) notes the following:
1.
"There was no documented evidence for assuring that individual FSAR
- cannitments for systens equipment or calculations were being sys-tsunatically implemented into the design."
1 l
2.
"There is a potential for a lack of awareness of individual FSAR comitments by STP site personnel. This could represent a significant problem for field initiated design changes."
3.
"One group conspicuous by its absence during this design review program was Licensirg."
4.
"A consistent and documented B&R position regarding code and standards interpretations was not evident." "These interpretations are left to i
individuals or to vendor suppliers. The ASME code terpretation area appears to be particularly weak (see Question M-30)
In response to the above:
1.
Required modifications to the FSAR have been identified during the Design Assurance Review; (see 50005. Sec. 3.1.3.c and 3.2.3.e), the FSAR is scheduled for update during our upcoming systems design freeze.
In addition. Project procedures require identifying all changes that
,e
(
affect the FSAR on the Design Change Notice fonn. Also, the Vendor Control Program perfonns a complete FSAR review for safety class
~
equipment and materials to ensure any disconnects between equipnent specifications and FSAR connitments are identified and rectified.
2.
The statements made by Quadrex concerning B&R's site activities were made without the benefit of a B&R Site Engineering review. As a result. it is not clear how this conclusion was reached. STP Site l
Engineering personnel are an extension of the Home Office Engineering organization working through the same managment. All field initiated design changes must receive the same scrutiny as a change generated in i
i the Home Office.
3.
Quadrex did not review the activities of B&R's Licensing Group as a 4
special topic. There is periodic and systannatic interface between i
Licensing and the discTplines which is closely controlled.
4.
The ASME code problens identified by Quadrex are unique to specific components and will be addressed on an individual basis. The cited reference Question M-30 addresses no other codes and standards than ASME. hen:e. we assume that Quadrax's generic concerns relative to codes and standards is unfounded.
NRC RIV QUADREX REVIEW I:
REFERENCE DOCUMEtn NO. -
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GENERIC FINDING 3.1(g) h PLANT DESIGN BASIS
\\
l Generic Finding 3.1(g) notes the following:
1.
"There was very little evidence of a well-thought-out and consistent basis for design."..."A number of key front-end criteria documents are missing for STP."
2.
"No document exists that identifies the interface design infomation required by each discipline from the other technical discipline."
3.
"B&R indicated that WNES has reviewed portions of the intial STP-design, but the quality and completeness of their review is uncertain."...
"The interface between B&R, WNES, and HL&P needs to be improved."
4.
"EDS indicated that B&R drawing changes are not reviewed on a routine basis 4
~
5.
"In numerous instances WNES design bases for the nuclear island por-tion have been directly carried over to the balance-of-plant design without confiming their appropriateness for this application."
6.
"In other instances, design details have been obtained from other PWR plants and used without confiming their applicability to the STP plant."
[,
7.
"B&R has not adopted a consistent requirement for design margin to be 1
achieved by each discipline. There was ample evidence that individual engineers make the detemination of the margin to be included in the design (see Questions C-12 and H-8).
In response to the above:
1.
The need for strengthening B&R's front end criteria documentation was identified by B&R during mid-1980 as acknowledged by Quadrex and problems 4
i in this area are in the process of being rectified. As stated by Quadrex on P. 3-9 ".... a number of these documents have either been recently 1ssued or are currently undergoing review prior to initial issue....".
The absence of selected front end criteria docunentation does not pre-clude the existence of "a well-thought-out and consistent basis for design." We, therefore, consider Quadrex's comunents concerning this matter to be purely subjective.
2.
As stated previously, the handling of design interface infomation is the responsibility of the B&R Systems Engineering Group and the use 1
of preliminary infomation is for the most part due to be phased out during the upcoming design freeze of the individual plant systems.
j l
M RW quAangy ggyggW R:FEREncz OOCUMENT No.
H j
13
PRE 1J 6 Lg GenericFinding3.1(g)
Page 2 g
(
3.
Westinghouse received all B&R piping composite drawings for Westinghouse NSSS systes during 1977-78. From these drawings, they prepared PSDFTE 285, Rev. O, which is the system state point analysis for all operating l
modes of NSSS systems. They also issued Westinghouse P&ID's for con-struction. In addition, the Westinghouse design manuals are used regularly by B&R during the design process. Westinghouse has also reviewed the logic diagrams for NSSS systas. Doc eentation of this review exists in the Project files. We consider Quadrax's connents in this area to be unjustified. We do, however, agree that the current B&R, Westinghouse and HL&P interface agreement needs to be improved and we have had d,iscussions with HL&P in this regard.
4.
The results of B&R's review of the EDS work was addressed earlier and based on Quadrex's connents, seems adequate.
l 5.
B&R did evaluate the application of Westinghouse criteria throughout the design of the STP systems. Systems which interface with Westinghouse systems and which have interface criteria specified by Westinghouse were designed to meet those criteria. Other plant systems were designed to meet the presumed worst case operating criteria, e.g., plant water treatment systems.
/"
6.
B&R encourages the design engineers to factor previous experience into their designs. The Quadrex conclusion that "... design details l
\\
have been obtained from other PWR plants and use without confirming their applicability of the STP plant...." is unfounded. Experience and first-hand knowledge of the applicable material is a prerequisite.
l We have difficulty interpreting Quadrex's renarks concerning design l
7.
margins because the various design basis codes and standards include 1
We presume that Quadrex is referring to the additional margins margin.
placed upon equipment and systems during the preliminary stages of design.
These will be verified during the design freeze process and again during i
We acknowledge Quadrex's comment concerning our res-4 syster pre-ops.
ponse to Question C-12. "...some A/E's do consider this phenomenon i
similar to the manner in which Brown & Root did." We acknowledge i
Quadrax's findings relative to Question H-8, "...a quick assessment of the adequacy of margins in the HVAC system design is not possible."
i 8.. Brown & Root has 20 volumes of Design Manuals which occupy 5 ft. of a i
standard bookshelf. In retrospect, the use of engineers log books may have helped to ease some of the problems resulting from the high personnel turnover experienced by B&R during the late 1970's. The turnover situation was unanticipated and had never been experienced on previous B&R jobs.
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GENERICFINDING3.1(h) p PR EcuIrms au=Iun woulumns Generic Firling 3.1(h) notes:
" Specific reliability (requirements, such as for the ESF sequencer, have 1.
not been established seeQuestionsE-7andE-8)."
~2.
"If the ESF sequencer reliability should turn out to be incompatible with the remainder of the ESF equipment, then R&R's dependence upon meeting only the single failure criterion would be unsatisfactory from a systems viewpoint 3.
"The absence of specific reliability requirements in both mechanical and electrical equipment specifications..... casts doubt on the rigor of the safety-related evaluation process."
4.
"Throughout the design review, specifications to constrain spurious operation were absent."
~
The following is offered in response to these areas:
1.
Reliability requirements have been specifically addressed in the ESF load sequencer spec. ES-071. Section 3.4. Reliability Analysis, which requires the vendor to impleent the method of fault tree analysis, as per IEEE Std. 352.
2.
Regarding the possibility of incompatability, the vendor is required to confom to the codes and standards listed in Section 2 of the above specification. B&R feels that these requirements are sufficient to ensure compatability with the ESF equipment supplied by WNES. Additionally, the design satisfies single failure criterion. Should failure of one sequencer occur, two other safety class trains would be available.
3.
B&R does not concur with Quadrex's generalization of an -" absence of specific reliability requirements in... specifications." The requirments imposed by the codes and standards cited in our specifications are. in our judgment, sufficient to ensure adequate reliability. Evaluation of vender doctanents reflecting the implementation of the required standards is reviewed by the responsible engineer who at that time ensures the adequacy of the design. See STP Procedure STP-DC-004 for the metho-dology for approving vendor drawings and doctaments.
4.
Although the consnent regar' ding " spurious operation" is general, our response specifically addresses tne sequence. Spurious operation of the sequencer is prevented by a matrix recognition requirement of 2 out of 4 signals for undervoltage recognition (modes II or III) or 4 out of'6 tignal recognitions for safety ' injection (mode I or III).
Further details can be found in the sequencer specification in the section describing mode of operations.. Also, spurious valve movements have been considered as early as the PSAR stage. A review of the Safety Evalua-tion Report and the appropriate logic diagrams would have made this evident.
NRC REY NUADREX REVIEW HEFCRENCE DOCUMEtn N'). -
N 15
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GENERICFINDING3.1(1)
NUCLEAR-RELATED ANALYSIS st -
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PREL Nu Generic Finding 3.1(1) notes the following:
"The chosen analysis methods demonstrate a sharp paradox between the 1.
more conventional engineering work and the uniquely nuclear engineering work required for portions of the STP design." "In certain disciplines, such as Civil / Structural and Electrical, technically adequate methods have been chosen. However, for the nuclear aspects of the project.
Brown & Root has been much less adequate in its choice of analysis methods and assumptions." "In addition an abnomally high error rate was observed in these calculations. In many instances insufficient work has been accomplished for the present state of STP design, pro-curement, and construction."
"The amount of nuclear-related analysis that is subcontracted by B&R 2.
is higher than a typical A/Es practice. The technical guidance provided by some of these groups for subcontracted consultants such as EDS and Review of these subcontracted NUS, does not appear to be adequate.
~
analyses does 'not appear to be sufficient."
' ~
The following is offered in response to these areas:
1.
Changes to correct past difficulties in the Nuclear Analysis Group were implemented in 1980. Plans to complete outstanding work are evident in the Project schedules. Responses to specific concerns will be addressed on a case bases.
The work done by EDS and NUS has been shown to be of high quality and 2.
adequately coordinated and interfaced with affected disciplines.
The " amount" of analysis that is subcontracted is irrelevant with respect to this review.
1 i
l l
NRC RIV QU;D*:EX REVIEW HiFOR2 CE OU.'.lEi tT no.
16 l
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/ FINAL DESIGN VERIFICATION Generic Finding 3.1(j) notes the following:
1.
"The B&R design verification process perinits the use of preliminary data up to the point of STP fuel loading."
2.
"There are no docisnented standards regarding the mininsn qualifications required for a design verifier. Typically, the Discipline Project Engineer selects the design verifier from within the discipline, but his basis for selection is not documented."
The following is offered in response to these areas:
1.
We do not see how this finding can be consistent with Quadrex's assess-ment of B&R's response to Question C-16 which is referenced as a basis for the finding; 1.e., " Brown & Root's design verification procedure appeared to be adequate or above industry standards on paper; however.
we (Quadrex) were unable to evaluate the effectiveness of this procedure."
2.
Quadrex acknowledges in the text of the review that this approach does not violate NRC requirements.
U3DREY REVIEVI HnC F - ct DOCUMENT no.
i 17
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(
PRELIM h ARY ENCLOSURE 2 GM-91311 TO:
E. A. SALTARELLI
_{-.
FROM:
F. E. MUELLNER SEPTEPEER 11. 1981 NCC R!Y QU.iD.9EX REVIEW fiEFCr12NCE. DOCUMENT NO.
G e
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~.
ENCLOSURE'2 hk ITIM NLSSER; Quadrox: 4.1.2.1 (A)
B&R: 1-01-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
Q DISAGREE WITH FINDING:
THIS ITEM 15 CONSIDERED TO BE:
REPORTAB LE.............
O POTENTIALLY REPORTA8LE,......
INSUFFICIEhT DATA FOR ASSESSMEhT..
C NOT REPORTABLE...........
te
(-
BASIS FOR AB0VE ASSESSMEhT:
The Structural Discipline has on numerous occasions rejected input because of the unreasonableness of input data. Typical examples of this are: IVC Environment. Pressurizer Skirt Area, etc. However. no requirement exists for formal documentation of evaluation of other discipline's input.
Brown & Root's structural discipline takes exception to the connent that they do not appear to have adequate technical expertise in the nuclear industry (Question C-4). The Structural Discipline have always had engineers who acquired their nuclear experience from all the leading A/E's of the nuclear industry. The factor 1.4 has been used in structural design based on Standard Review Plan Section 6.2.1.2. Item II 7 (page 6.2.1.2-3), and Brown & Root reviewed the dynamic factor of 1.2 in the earlier stages of design and found it reasonable. The RC8 internal structures have been designed based on conservative input from Nuclear Analysis.
At present. Nuclear Analysis, and Pipe Stress are performing analysis (H-12. N-3) to assure that the input data used in the structural analysis is adequate.
NRC RIV QUADREX REVIEW agFtREtic DOOUME T 140.-
w 1
---u.
ENCLOSURE 2 PREUM C--
ITEM NUPSER:
Quadrex: 4.1.2.1 (C)
B&R: 2-01-A DISCIPLINE:
Civp/ Structural AGREE WITH FINDING:,
y DISAGREE WITH FINDING:
{
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
O P0TENTIALLY REPORTABLE....... C INSUFFICIENT DATA FOR ASSESSMEhT..
C NOT REPORTABLE...........
Q BASIS FOR ABOVE ASSESSMEhi:
The Turbine Generator Building of STP is a non-category I structure. As such, there is no comittment in the PSAR to analyze this building for the SSE; however, it is comitted that the building will not fail under extmme loads in such a manner that it would reduce the functioning of any safety related feature to an unacceptable level.
The T. G. Building was analyzed for and detemined to withstand the design basis Tornado, which exceeds the Seismic Loading calculated using the Unifom Building Code approach. There is a T. G. pedestal inside the building with a 3 inch gap separating the two structures; the T. G. pedestal concrete block can be utilized as an anchor and a back up support for the T. G. Building frame should the lateral defomation exceed 3 inches. Additional barriers
~
near the south side of the building will be added for missile protection purposes, which will significantly increase the lateral load carring capacity of this portion of the building. It was judged that the TGB will not collapse due to seisnic loading to damage the category 1 structures.
As a contingency plan, a seismic analysis of the T. G. Building will be perfomed in the N-S direction only for the SSE. Since no qualific ation of safety related equipment is involved, the seismic analysis of the i. G. Building will not be perfomed until approximately June,1982, at which time other more critical work will have been completed.
NRC RIV QUADREX REVIEW REFEREf4CE DOCUMEi:T
- tio, 2
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, ENCLOSURE 2 c{
s ITEM NUPBER:
Quadrwx: 4.1.2.1 (D)
B&R: 2-02-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
Q POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSESSMENT..
NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
1)
BAR Structural Discipline satisfies AISC Code and NRC requirement related to allowable stress criteria (Question C-5).
ii)
The RCB Seismic sedel was discussed during the audit (Question C-20).
The RCB mathematical model was originally developed by EDS and reviewed in detail by B&R. All heavy equipment such as Reactor Pressure Vessele. Steam Generator and Reactor Coolant Pumps were all included in the model. This reflects the incorporation of the decoupling criteria.
Extensive study was done by the Structural Discipline to investigate the effects of frequency variations due to decoupling.
iii) We do not agree that BAR is not aware of the existence of NUREG-0612 (QuestionC-43). However, the project cannot spend MR's to evaluate a new requirement unless authorized by NL&P.
In sunnary, B&R Structural Discipline disagrees that significant differences exist between NRC and B&R criteria.
NRC RW QUADREX REVIEW REFERENC DOOUMENT g
NO.
l p e.
ENCLOSURE 2 PREUMINAD ITEM NUMBER:
Quadrex:
4.1.2.1 (E)
B&R:
2-03-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:.
O DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORT AB LE............. g POTEhTI ALLY REPORTABLE....... C INSUFFICIENT DATA FOR ASSESSMENT..
O NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMEh7:
QUESTI ON.C-3 Brown & Root has reviewed and approved the calculations by Whiting Corprostion for the polar crane (Question C-3).
It has been detemined that all of the proper loading combinations and acceptance criteria were handled properly.
The crane manufacturer has certified that the crane is designed and manufactured in compliance with CMAA-70 specifications. Regulatory Guide 1.104 has been withdrawn by NRC from use. Our review indicates that the new NRC requirements as found in NUREG-0554 have been met in the polar crane design.
QUESTION C-35 The Quadrex assessment on C-35 implies that Brown & Root has ignored NUREG-0577. This is not correct. The part of NUREG-0577 that deals with the potential for cracking of bolting for steam generators was sent to all licensees as I&E Infomation Notice 80-36, dated 10/10/1980. This was reviewed and responded to by Brown & Root to HL&P by letter ST-BR-HL-35382, dated 12/23/1980.
The NUREG 1aregly concems Westinghouse s0pplied equipment and criteria.
All parts of the NUREG were addressed by Westinghouse in deteil with recom-mendations to HL&P per letter ST-WN-HL-1740, dated 11/26/1980. Brown &
Root concurs with Westinghouse recomendations for the limited portion of the
(,-
applicable structural supports in Brown & Root's scope of engineering.
NRC RIV QUADREX REVIEW REFEREAC DOCUMEtJT NO. -
4
_.-_..,m
.. - ~.... -
ENCLOSURE 2 P.REU W M C
ITEM NUMBER:
Quadrax: 4.1.2.1 (G)
B&R: 2-05-A DISCIPLINE:
Civ)1/Stryctural AGREE WITH FI DING:.
Dead Load
- DISAGREE WITH FINDING:
Vertical Seismic Coefficients THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
O POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSESSMENT..
O NOT REPORTABLE...........
O BASIS FOR ABOVE ASSESSMENT:
PRELIMINARY RESPONSE:
1)
B&R Structural Discipline assumptions regarding the MAB squipment dead loads are representative of the actual conditions. Further review of MAB dead loads will be conducted to confim actual loadings.
- 11) A vertical seismic coefficient of 0.05g for OBE, which is the ground level acceleration, was used in designing the structural components.
The Brown & Root Structural Discipline is in the process of revising calculations to incorporate the results of the latest seismic vertical response spectra. The frequency of the floor elements will be calculated to detemine the vertical seismic coefficients. The estimated scheduled date of completion for this item is December 1981.
i' NRC RIV QUADP.IX REVIEW REFZRE14CE DOCUV.EllT N 0. -
5
--,,-,n--.--------,,
ENCLOSURE 2
\\h\\
.s ITEM NIMiER:
Quadrox: 4.1.2.1 (H)
~~
B&R: 2-06-A DISCIPLINE:
Civil / Structural' AGREE WITH FINDING:
r DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
POTENTIALLY REPORTABLE.......
O INSUFFICIENT DATA FOR ASSESSMEhT..
O NOT REPORTABLE...........
+
BASIS FOR ABOVE ASSESSMENT:
Brown & Root Structural Discipline agrees that certain fixes may be needed in future. However, it must be realized that final verification can not be done until all the supports are designed. The method of final verification was described in detail to the Quadrex Audit team.
NRC RIV QUADREX REVIEW.
REFEREt GE DOCUMEt4T 3
6
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ENCLOSURE 2
{(k$h Quadg g Q 2 3 (!)
ITEM NWSER:
g DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREEWITHFINDING$ g THIS ITEM !$ CONSIDERED TO BE:
REPORTABLE.............
POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSES $MEhT..
O NOT REPORTABLE...........
re' BAS!$ FOR ABOVE ASSESSMENT:
See response to Quadrax Item 4.1.2.1 (A).,
NRC Ftv QU'sDRIX RIVIEW REFERitCE 000VMEl4T f40.
4 7
ENCLOSURE 2 hh ITEM NUPSER: Quadrex:
4.1.2.3 (J)
B&R: 4-02-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
Q DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTAB LE.............
Q POTENTIALLY REPORTABLE.......
O INSUFFICIENT DATA FOR ASSESSMEhT..
O NOT REPORTABLE...........
C
(
BASIS FOR ABOVE ASSESSMENT:
B&R Structural Discipline reviewed the fuel pool analisis and ascertained that the fuel rack dead load has been properly input.
The coefficient for vertical seismic loads was considered correctly in designing the Fuel Pool in FHB.
l NRC RIV QUAD'iEX REVIEW RECRENCE OJUMEt1T
~
NO.
l I
8 l
[
~ ^ " '
ENCLOSURE 2 PREugNARY C
ITEM NUPSER:
Quadraxi 4.1.2.3(K)'
B&R:
4-03-A DISCIPLINE:
Civil /Strvetural AGREE WITH FINDING:
,C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO SE:
REPORTABLE
.D POTENTI ALLY REPORTABLE._ _
INSUFFICIENT DATA FOR ASSESSMENT NOT REPORTABLE._
BASIS FOR ABOVE ASSESSMEh7:
There was no over conservatism in the determination of the level of prestressing.
It was not prudent to consider the liner themal expansion as a secondary mode,of-behavior (see Question C-12 and C-14) at a time (1975-76) when the code interpretation was changing and NRC requirements becoming more stringent.
The B&R approach in computing the amount of prestressing 11 consistent with industry practice and has been acceptable to NRC for many plants.
t47.C RtV QU
- D?.!X REVIEVI upsm.ct 0%UJEUT
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9
ENCLOSURE 2 1
f ITEM IUW ER:
Quadrex:
4.1.2.4 (N)
DISCIPLINE:
Civil / Structural
)
AGREE WITH FINDING:
[
DISAGREE WITH FINDING:
Q THIS ITEM !$ CONSIDERED TO BE:
REPORTAB LE.............
POTENTIALLY REPORTABLE.......- O INSUFFICIENT DATA FOR ASSESSMENT..
NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
i)
The purpose of the TRD on. seismic curves is to transmit response spectra curves to other disciplines. The basic concepts and instructions i
are in the General Struefural Design Criteria (Section 8-1). This document has been reviewed by all the disciplines and is also a part of the STP Design Manual. In addition, the Structural Discipline reviews documents generated by other disciplines. Therefore, we do not agree that the Structura1 Discipline does not provide instruction for proper use of information trasmitted.
- 11) Conversely, the input data received from other disciplines are in-corporated in SDD's which are reviewed by all the disciplines.
l 4
NRC CIV OU'DREX REylEW W :f; x i C a : u. n i:i fC.
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ITEM NUPSER:
Quadetx: 4.1.2.4 (0)
B&R:
5-02-A DISCIPLIE:
Civil / Structural AGREE WITH FINDING:
C DISAGREE WITH FINDING:
THIS ITEM !$ CDNSIDERED TO E:
REPORTABLE.....
.Q POTENTI ALLY REPORTABLE._ _
D INSUFFICIENT DATA FOR ASSESSMEh7D NOT EPORTABLE.-
. 85
~
SAS!$ FOR ABOVE ASSESSMEh7:
Design method for the tangential shear in the prestressed concrete containment has not been provided'even in the 1980 edition of the ASME Code (Refer CC 3421.5.*
(_
and CC 3521.1.1).
The criteria given in the 500 for. tangential shear design has been used in the industry for many years and has been accepted by NRC. Calculations also indicate that the values of tangential shear obtained from analysis does not control the containment design.
NEC RIV QU.ID?.EX REVIEW ID'.ill;.CE L3CUMI ;T tJO.
N 11
- ". - ^ ' ' -
ENCLOSURE 2 h\\
ITEM NUPSER: Quadrex: 4.1.2.4 (P)
B&R: 5-03-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
C DISAGEE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE...
PDTENTI ALLY EPORTABLE INSUFFICIENT DATA FOR ASSESSMENT NOT REPORTABLE-BASIS FOR ABOVE ASSESSMENT:
See response to Quadrax Iterc 4.2.2.1(G)
N.'C RIV OULDREX REVIEW h' F31.0K L 0. U.' lit r:0.
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49 p
12
.a_....
ENCLOSURE 2 Y
ITEM NUNBER:
Quadrax: 4.1.2.4(Q)
B&R: 5-04-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSESSMEhi..
NOT REPORTAELE...........
BASIS FOR AB0VE ASSESSMENT:
~
This item has been addressed by the Structural Discipline as part of resolution to EDD 78-62. At present. the ducts are being designed l
based on pressure loads provided by the Nuclear Analysis Disef pline.
. V ',.'
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ENCLOSURE 2 hb
+
ITEM NUPSER:
Quadrax: 4.1.2.4(R)
B&R: 5-05-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREE WITH FINDING:
g THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
g O
POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSESSMEh7..
O NOT REPORTABLE.'..........
H BASIS FOR ABOVE ASSESSMENT:
The lateral loads from the walls themselves and attached piping and equipment supports are generally small; therefore, a rigorous analysis cannot reasonably be justified.
NRC RIV QUIDREX REVIEW n,: n-i.cE LO:UMM 4
r:.
as.;.
1,jph 14
' "' ~ ~ " "
ENCLOSURE 2 h
ITEM NUPSER:
Quadrex: 4.1.2.4(S)
BAR: 5-06-A DISCIPLINE:
Civil / Structural
,7 r <
AGREE WITH FINDING:
to DISAGREE WITH FINDING:
,. THIS ITEM IS CONSIDERED TO BE:
REPORTAB LE.............
O POTENTIALLY REPORTABLE.......
O
)
INSUFFICIENT DATA FOR ASSESSMENT..
NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
Brown & Root Structural Discipline agrees with Quadrex Assessment that the equipment loads are considered properly and in many areas the loads are still preliminary. The calculations will be reviewed based on final equipment loads.
f NRC RIV QUSDREX RIVIEW REFRENCE30.U..a:I l
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ENCLOSURE 2 h
ITEM NLDSER:
Quadrex: 4.1.2.4(U)
B&R: 5-08-A DISCIPLINE:
Ciwil/ Structural AGREE WITH FI DING:.
O DISAGREE WITH FINDING:
C THIS ITEM IS CONSIDERED TO BE:
REPORTABLE............ -
O POTEhTIALLY REPORTABLE....... C INSUFFICIENT DATA FOR ASSESSMEhi..
NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
We agree with the Quadrex assessment that "there is no set standard practice in the industry of the consideration of vertical response spectra. Some A/E's appear:to consider the flexibility of slabs and other A/E's do not".
The category I structures of STP have thick floors (in general, two feet thick concrete or equivalent composite sections). Assuming rigidity and negligible local amplification for elements with natural frequency above 33 cps, a 2' thick slab could span as much as 30' before local amplification becomes significant. Floors of all STP Category I structures have spans shorter than that due to partition walls and rigid beams. Therefore, the vertical amplification effect of the flexibility of slab is negligible for STP. For heavy equipments on platforms and slabs, the structural components are analyzed on a case by case basis.
N.7C Rrv OUiDREx ggyggy hdE!?if4CE 00;UMEllT N.
No. -
7.
16
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ENCLOSURE 2 BrownFRooLinc.
INTEROFFICE MEMORANDUM TO:
J. SIGNORELLI DATE:
JUNE 4,1981 FROM:
H. S. CAMERON JOB NO.:
CR-0241
SUBJECT:
QUADREX REPORT REVIEW CORRES NO.:GM-90103 Transmitted herewith is the response to Quadrex concern 4.1.2.4.(v)
Q l 'b
&-ia-w H. S. Cameron HSC/mr File No.: A010G cc:
J. Wawrzeniak-E. Leschber J. McAdams NRC Riv QU.5D~iEX REVIEW r.;r;Ri.lCE 0%UMD;T
~
i no.
17
_ _ = _,...
ENCLOSURE 2 p
0 ex Concern 4.1.2.4 (v)
"In the area of equipment seismic evaluation, there was evidence of a lack of continuity in Brown and Root staffing. However, it was evident that Brown and Root underf.tood the nature of this activity, and their methodology is in line with industry practices.
To date, there was not much evidence of completely. cycled vendor 4
seismic analysis with Brown and Root interaction; consequently, we feel that this area will need considerable attention and man-power effort in the near future (see Question C-32 and C-33).
-Brown and Root has no criteria for detemining whether a given change in response spectra requires requalification of equipment."
Brown and Root Response During the past year, the equipment seismic qualification area has been one of considerable B&R attention noting that a sub-stantial number of vendor qualification reports have been received during this period. The receipt of these reports and B&R's intention to complete a thorough review for each has resulted in a backlog of reports needing a qualification review. Noting the criticality of completing timely reviews and the increasing report backlog, B&R augmented its seismic qualification review team by con-tracting with an independent consulting fim to perform third. party reviews. This action along with an increase in the B&R staff has provided sufficient manpower to reduce the backlog of outstanding qualification reviews and to maintain a timely review of newly
{
received reports.
The interaction between B&R and its vendors concerning qualification reviews has always been in effect and, as one would expect, has been occurring with increasing frequency.as the above reviews are being completed. The documented evidence of this interaction was available during the audit, but was not an item which the audit team requested-and consequently, was not provided.
The criteria that Brown & Root employs in detemining whether a given change in a response spectra requires the requalification of equipment is dependent upon the extent of the change. The response spectra previously employed in the seismic qualification of any equipment is compared to the revised response spectra for the corres-ponding equipment mounting location.
If the esponse spectra used in the original equipment qualification exceeds the revised response spectra over the entire frequency range of significant equipment response, the original qualification remains acceptable.
If the revised response spectra exceeds the originally-used response spectra over any frequency range of significant ecuipment response, that particular equipment must be re-evaluated for possible requalification.
N.*:C RW QU.3DREX REVIEW I
htFla_l10E. DOCUMENT NO.
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ENCLOSURE 2 gg@
Q ITEM NUPBER:
Quadrex: 4.1.2.5(BB)
B&R: 6-06-A DISCIPLINE:
AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
ENMMG.............
POTENTIALLY REPORTABLE.......
~
INSUFFICIENT DATA FOR ASSESSMENT..
O NOT REPORTABLE...........
S BASIS FOR ABOVE ASSESSMENT:
Brown & Root Structural Discipline has perfomed partial parametric analysis for tornado loading. However, a total parametric analysis approach was not done due to economic considerations.
l
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ENCLOSURE 2 k
ITEM NUPSER:
Quadrex: 4.1.2.5 (CC)
B&R: 6-07-A DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
O POTENTIALLY REPORTABLE.......
INSUFFICIENT DATA FOR ASSESSMENT..
O NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
During the design verification process, input to each computer code is thoroughly checked and verified.
If the input to a computer code is obtained from the output of another corrputer code, not only the correct transfer of data is checked but the proper use of data is also verified.
(See Project Engineering Procedums: ST-DC-008 calculations and ST-DC-015 Design Verification).
NRC RIV CUAD.9EX REVIEW RCFCrntiO; D.%UMENT HO.
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ENCLOSURE 2
\\
ITEM NUPEER:
Quadrox:
4.1.2.5 (DD)
B&R: 6-08-A DISCIPLINE:
Civil / Structure 1 AGREE WITH FINDING:
Q DISA8REE WITH FINDING:
Q
~
THI3 ITEM IS CONSIDERED TO BE:
REPORTABLE.............
POTENTIALLY REPORTABLE....... O INSUFFICIENT DATA FOR ASSESSMEhT..
O.
NOT REPORTABLE...........
BASIS FOR AB0VE ASSESSMENT:
The value of the containment minimum temperature used in structural calculations is 65'F. This is consistent with the HVAC SDD SV149006, Table 2.1-1.
Structural Discipline confinned that the HVAC discipline is also using 65'F as the containment minimum temperature.
NRC Riv QUADREX REVIEW r
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ENCLUSURE 2
~
ITEM NUPSER: Quadrex: 4.1.2.5(W) 8&R: 6-01-A
. DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
DISAGREE WITH FINDING:
O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
O POTENTIALLY REPORTABLE.......
C INSUFFICIEhT DATA FDR ASSESSMENT..
O NOT REPORTABLE...........
Q n%
BASIS FOR ABOVE ASSESSMEhT:
C Design input provided to' Structural Discipline in the fom of ION is s
identified in th'e Design Input Fom (200,73) and calculation text as
" preliminary." All final design input would be referred to an approved design document.
R NRC P.g qu.* DP.EX REVIEW n;g;ni:;E XU'EU t;O.
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ENCLOSURE 2 ITEM NUMBER:
Q0adrex: 4.1.2.5 (X)
B&R: 6-02-A DISCIPLINE:
Civi.1/ Structural AGREE WITH FINDING:.
O DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.............
O POTEhTIALLY REPORTABLE.......
INSUFFICIEhT DATA FOR ASSESSMEh7..
O NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMEh7:
('
A standard penetration anchorage design procedure has been set up and the penetrations have been classified in several groups and designed considering the size and loading of the penetrations.
During the review. B&R presented only a sample of the classified gmups of the containment penetration analysis and design.
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' ENCLOSURE 2
(
ITEM NUMBER:
Quadrex: 4.1.2.5 (Y)
BR: 6-03-A DISCIPLINE:
Civil /Str.uctural AGREE WITH FINDING:
Q DISAGREE WITH FINDING:
Q THIS ITEM IS CONSIDERED TO BE:
REPORTABLE............. O POTENTIALLY REPORTABLE.......
C INSUFFICIENT DATA FOR ASSESSMENT..
NOT REPORTABLE...........
BASIS FOR ABOVE ASSESSMENT:
('
BAR Structural Discipline is staffed with qualified engineers, who have many years of experience with the leading A/E's in the nuclear industry.
We do not agree with Quadrex observation related to inexperience in implementing nuclear power plant design.
R E
N.C Rl[ hD3E g 9 sn e._ r a ~-
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ENCLOSURE 2 Qh C,
TM NUPEER:
Quadrex: 4.1.2.5(2)
B&R:
6-04-A DISCIPLINE:
Civil / Structural
. AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
.O POTENTIALLY REPORTABLE._
D INSUFFICIENT DATA FOR ASSESSMEhTD NOT REPORTABLE- - -
._ _.Ek BASIS FOR ABOVE ASSESSMENT:
The Mononobe-Okabe method includes simplifications which renders the results less precise at some locations than obtained by the more representative FEM model incorporating the significant boundary conditions.
(
Specifically: The Mononobe-Okabe method does not include structure to structur.e interaction. This aspect is undoubtedly conservatively represented in a plan strain FEM.
Other simplifications in the Mononobe-Okabe method include: Plan failure surfaces and rigid soil behaviot plastic equilibrium; equilibrium between sliding wedge and failure plane, etc. Consideration of these simplifications clearly shows that the FEM results are more easily acceptable despite the recognized conservatism at some locations, hcwever, the overall results from two methods are compatible.
N=C mv Qu'D?.EX REVIEW L
i 25
^
~
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v ENCLOSURE 2
.q( pgguM W
ITEM NMER:
4.3.2.1 (b)
{
s.
DISCIPLIE:
Electrical /I&C" AGREE WITH FINDINE:
O DISAGREE WITH FINDIME: O THIS ITEM IS EDRSIDERED 10 BE:
.O REPORTABLE..
POTENTIALLY REPORTABLE.
D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
.U BASIS FOR ABOVE ASSESSMENT:
~
Most design criteria for STP are not found in TRD's, nor is there a licensing There are numerous requirement for that particular means of documentation. instances benefit to the project by supplementing the basic criteria found in an SDD;
(
then the TRD is published.
(
The NRC documents and other sanctioned documents are the source for the high Such documents include General Design Criteria of level design criteria.
10CFR50, Appendix A. Regulatory Guides, ASME codes and IEEE Standards, etc.
To the extent these can be used directly in the design process, together with applicable Branch Technical Positions, the Standard Review Plan and otherEach NUREG documents, the more fully should a licensable design be produced.
time an NRC criterion is rewritten, paraphrased and interpreted in an This suggests interposing document there is the risk of altering the intent.
that referencing be liberal but any rewritting of NRC criteria be limited r
to the extent necessary.
Occassionally there is a case where alternatives may be presented er there is l
Such is the a distinct need for further clarification of the NRC document.In that case IE case addressed by the Electrical Discipline in E0006.
Also Appendix R, presented certain options which needed to be selected.recently is R.G.1.75 and IEEE 384, so a written basis for applying them was needed.
\\
A licensable oesign is the product of effective management and a documentation l
structure wnich that management detemines will assure meeting the licensing We appreciate Quadrex calling a deficiency to our attention.
i l
requirements.
We have initiated corrective action. We do not agree, however, that more TRD's are necessarily the best answer.
3,W NRC RW ouAD EX REVIEW hu;nm;E COUMENT N 7. -
3
ENCLOSURE 2 h
ITEM NUPBER:
4.3.2.1 (d)
DISCIPLINE:
Electrical /I&C AEREE WITH FINDINar.
O DISAGREE WITH FINDINE:
THIS ITEM 15 CDNSIDEED TD RE:
REPORTABLE....
..Q POTENTIALLY REPDRTABtr
-D INSUFFICIENT DATA FDR ASSESSMEhTD NOT REPORTABLE
.E BASISFDRABOVEASSESSMkNT: Quadrex Coment: No formal methodology or documen-tation exists to verify adequate separation or the single failure criterion (see Questions E-1. E-8 and E-19).
Brown & Root Resoonse: B&R disagrees with Quadrex for the following reasons:
1.
Criteria document 20-003 does contain separation criteria for I&C installations 2.
Single failure criterion is identified in y, P.I.P. for safety systems proYided by 'W.
3.
DC-015 provides methodology for design verification process.
4.
5D-005 provides methodology for design assurance review.
Ref. Quadrex E-B: Regarding Quadrex comment pertaining to energizing systems where valves partially open etc., refer to 4.3.2.1 (x)
- h..
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ENCLOSURE 2 l
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PREU M
~
ITEM NUPSER:
4.3.2.1 (e)
DISCIPLIE:
Electrical /IEC AGREE WITN FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TD BE:
REPORTABLE....
..D POTENTIALLY REPORTABLE _
D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
. U
~
SA515 FOR ABOVE ASSESSMENT:
Criteria for the use and function of separation barriers is contained in (e)
Detailed barrier physical characteristics are determined by a
EQ006.
review of the specific application, considering the physical characteristics of the components to be separated and the specific hazards against which protection is to be provided.
A physical review of all plant systems is being conducted in accordance with This will determine the specific GP009, the hazards analysis procedure.
design requirements for ' external" barriers so that the final installation Based on the functional and physical will meet the criteria of EQOO6.
characteristics identified in this study, the appropriate disciplines will specify, procure and oversee installation of the barriers.
In the case of vendor-supplied panel equipment, our preferred method is to define any special functional requirements, such as " internal" barriers with necessary references to special standards or Reg. Guides as The vendor then reviews the requirements and is able to appropriate.
integrate them into his standard equipment design considering all design The completed design is subject to our review and approval. By aspects.
this method we increase the probability of receiving a more reliable product, and cause the vendor to retain complete design responsibility, I
both of these being important goals.
r 7
gq,c nty cuoOREX P.EVIEW g n;..;I rX UaENT
~~
N 3. -
g 28 Ra v'. 4/t/t!
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t.NLLUbuKt. 4 ITEM NUSER: ~4.3.2.1 (f.),
DISCIPLIE: Eleetrical AGREE WITH FINDING:
C D15AGEE WITH FINDING: O TH15 ITEM 15 CON 51EED TD E:
REPORTABLE........
POTENTIALLY REPORTABLE INSUFFICIENT DATA FOR ASSESSMENT NOT EPORTABLE.-
~
BASIS FOR AB0VE ASSESSMENT:
The top level documents used for establishing the equipment qualification list include General Design Criteria 4 and Standard Review Plan Section 7.1.
These establish the criteria which are used by the various disciplines to
(
classify each of their systems and equipments. Other internal documents are not needed for this purpose.
NEC g;y QUADREX REVIEW p,LF rC h,e.. g g M EllT r
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~
29 4
2
ENCLOSURE 2 b
ITEM NLDBER:
4.3.2.1.g (E1, E3, E4 and E14)
(
DISCIPLINE:
Electrical
" "II i
AGREE WITH FINDINE:
O O
DISA&REE WITH FINDING:
THIS ITEM 15 CONSIDERED TO BE:
.D NRC Rn QUADREX REVIEW REPORTABLE....
POTENTIALLY REPORTABLE D
REF r CE occustnr INSUFFICIENT DATA FOR ASSE t) n9, NOT REPORTABLE-BAS 15 FOR AB0VE ASSESSMENT:
The Quadrex assessment of Brown & Root's documentation and methods of assur Numerous project and that the FSAR consnittments are met is totally in error.
discipline procedures exist that fomulate specific requirements for controlling Among these procedures are the following:
{,
Procedure STP-SD-001 " Engineering Procedure for the South Texas Project the design process.
I.
Design Manual".
This procedure specifies the requirements for the contents, maintenance and control of the Design Manual for STP.
The South Texas Project Design Manual is the femal documentati design basis for the STPEGS.
design and/or construction criteria.
The distribution for the STP Design Manual as a minimum consists of resptnsible Managers, Engineers and Supervisors throughout the project str l
STP-SD-004 " Engineering Procedure for Design Review" II.
This procedure details the mechanism by which the design of structures, systems and components of the STP will be reviewed by interfacing disciplines and interfacing internal and external organizations.
This procedure af, plies to the issuance and revision of all desion documents I
for the STP except calculations.
STP-SD-005 " Engineering Precedure for System Design Assurance Reviews" III.
This procedure describes the methods and recuirements for perfoming systemll
, design assurance viviews on the STP and applies to a and Instrumentation and Control Systems.
I l
30
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'E5 CLOSURE 2
~
b( '
ITEM NUSER:
4.3.2.1 9 (Continu 'd) e DISCIPLINE:
AGREE WITH FINDING:
C DISAEREE WITH FINDING: O THis ITEN 15 CON 51ERED 10 SE:
ME.. tJ,,', NARY J o MEPORTABLE.
.Q POTENTIALLY REPORTABLE. _.M NRC RIV OUADREX REVIEW INSUFFICIENT DATA FOR ASSESSMENTQ LCF rNOE DOCUMENT NOT REPORTABLE.-
..U V
no.
BASIS FOR ABOVE ASSESSMENT:
III.
(Continued)
Section 2.3 of this procedure details in depth all items to be reviewed and the review criteria.
('
Item 2.3.h states:
"The reviewer will assure that the system design fulfills all licensing comr:ittments stated in tne Final Safety Analysis Report (FSAR), the technical specifications and other licensing related documents.
This review will require that each comittment be addressed individually to The review will also assure that assure that it has been met in the design.
FSAR/ER descriptions are consistant with design documents.
STP-DC-010 " Engineering Procedure for Codification" IV.
This procedure describes the methods for codification of design drawings, documents, calculations and other pertenient documents for the STP.
STP-DC-015 " Engineering Procedure for Design Verification" V.
This procedere defines the requirements and provides the methods for design verification of design docunents and shall apply to all nuclear safety.
related structeres, systems and components.
Numerous other project documents and procedures address the cownittments stipulated in the FSAR and expounc on the necessity to conply with the comittments contained therein.
U 31
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ENCLOSURE 2 1 TEM N M R*
4.3.2.1.g (Continued)
DISCIPLIE:
AGREE WITH FINDING:
C DISAGREE WITH FINDING:O m 5 ITra 15 = 51DE= = ===
3RELlM AARY
.D fi. C nr,' QUADREX REVIEW REPORTABLE...
POTENTIALLY REPORTABLE D
h..;:Za:,;c: occuMENT INSUFFICIENT DATA F0F, ASSESSMENTQ p
NO-NOT REPORTABLE
- - ---. W g
~
SA515 FOR ABOVE ASSESSMENT:
V.
(Continued)
Specific discipline Technical Reference Documents (TRD's) internal instructions, procedures and inherient engineering practices mandate the compliance with these comittments stated in the FSAR.
The original tone of the Quad tx questions did not specifically request an s.
indepth analysis of Brown & Root's methods implemented to assure cornplete fulfillment of the FSAR comittments. However, as detailed in numerous project documents Brown & Root has in fact provided the net.essary methods to assure that all FSAR comittments att implemented.
i l
l 32
n: w..
ENCLOSURE 2
(-
ITEM NMER:
4.3.2.1 (h)
' Page 1 of 3 DISCIPLINE:
Electrical /1&C ASEE WITH MNDINE.~.
C Disuut mN nN0in. O PRILN XARY THIS ITEM IS CDNSIDERED TO BE:
NRC RW QUADREX REVIEW EPORTABLE....
,O RLFERENCE DOCUMENT b
PDTENTIALLY REPORTABLE _
_ D g3' INSUFFICIENT DATA FOR ASSES $MZhTD i
NOT REPORTABLE
. D BASIS FOR ABDVE ASSESSP[ENT:.Quadrex Comment: No basis or procedures were provided to identify support systems neecec to assure safety system performance (see Question E-3).
Brown & Root Response: B&R disagrees with Quadrex, for the following reaso.s:
1.
SD-005 (Design assurance) deals with the " basis" and the " procedures" for all aspects to assure safety system perfonnance.
i.
For the " basis" refer to section 2.3 which covers the following:
2.3(a) Documentation 2.3(b) System Design Descriptions 2.3(c) Engineering Specifications 2.3(d) Calculations 2.3(e) Operations 2.3(f) Functions 2.3(g) Adequacy 2.3(h) Licensing Comitments 2.3(i) Integration
- 2. 3(j ) Failure Mode and Effects 11.
For the " procedures' refer to section 3.0 which covers the following:
3.1 Phase I Review including:
3.1.1 General
- ll
- i 33
-)
~- -
ENCLOSURE 2 ITEM NUMBER:
4.3.2.1 (h) [ continued]
('
Page 2 of 3 Brown & Root Resoonse: [ continued]
.J.1.2 Documents including:
o FSAR & Tech Specs o SDD's & W F.I.P. Manual
~
o Piping & Instrument Diagrams o Electrical One Line Diagrats
>}E}.'it.' NARY o Specifications A
lVi.
o TRD's (Design Criteria) o Calculations 3.1.3 Review Items including g 7.. pg.D?.EX REVIEW (a) Functional Requirements G M M M (b) Adequacy Requirements r:0.
I (c) Licensing Requirbnts (d) Integration Requirements 3.1.4 Documentation 3.1.5 Comment Resolution 3.2 Phase Il Review including:
3.2.1 General 3.2.2 Documents including:
o FSAR o Environmental Report o All design documents including Phase I review o Drawings o Calculations o Vendor Drawings 3.2.3 Review Items including:
(a) Operational Requirements (b) Testing Requirements (c) Functional Requirements (c) Adequacy Requirements (e) Licensing Requirements (f) Integration Requirements 3.2.4 Documentation 4k.~
3.2.5 Comment Resolutico l
D>,
l l
34
" ~ " ' '
ENCLOSURE 2
?
ITEM NUMBER:
4.3.2.1 (h) [ continued)
Page 3 of 3
^
Brown & Root Resoonse: [ continued]
3.3 Resolutions of Coment's Generated as the result of a System Design Review including: -
3.3.1 Document Review Coordinator h
3.3.2 Documentation Maintenance 3.4 Review of Design Changes 2.
ALL System Design Descriptions identify support systems, under the section oealing with " interfacing systems."
NRC RIV QUADREX REVIEW REFERENCE DOCUfAEi4T tC.
35
~ ~ '
ENCLOSURE 2 ITEM MUSER:
4.3.2.1 (i)
DISCIPLINE:
Electrical /IEC
==E mn nNDINan In DEUIV NARY DISAGEE WITH FINDING: O NRC RIV QUADREX REVIEW h
THIS ITEM 15 CDNSIDEED TD BE:
NO.
A EPORT ABLE.........
.O PDTENTIALLY REPORTABLE._. _. Z}
INSUFFICIENT DATA FOR ASSESSMZhi NDT EPORTABLE- -- - _ _ _ _.
Nr.C RIV QUADREX REVIEW k. liCNCE D3OUMEt.T BASIS FOR ABOVE ASSES Quadrex Comnent:
Plantryetia; ead e vironnental conditions were r.i td at least in tne desig" m 4 =ad h"t + h- ~ 4e 'o project if basis for these conditions and their use (see Que
'th E-13).
Bro [ 8 Root Response: This statement by Quadrex that there is no project-wide documentes basis for environnental conditions is incorrect.
The South Texas Project Design Manual which can be found in all discipline departments contain the HVAC System Design Descriptions for all areas of the plant.
These SDD's contain the environmental conditions throughout the plant.
Also TRD EQ004 contains detailed information dealing with environmental con-titions pertaining to the qualification of Class 1E Ecuipment. Botn nomal plant conditions and accident conditions are addressed.
l E?
~
t 36
a_...
ENCLOSURE 2 l
ITEM NUPBER:
4.3.2.1 (j), (E-S. partial)
DISCIPLINE:
Electrical AGREE WITH FINDING:
C dis =Rtt vm nNoiNG: O PELIVilNARY THIS ITEM !$ CDNSIERED TD BE:
REPORTABLE....
I POTENTI ALLY REPORTABLE INSUFFICIENT DATA FOR ASSESSMENT giRC.Riv QUADREX R l
NOT REPORTABLE._
REFERENCE DOCUME T "o -
U
~
o I
j BASIS FOR ABOVE ASSESSMENT:
Certain engineering specification provisions and requirements place the responsibility upon the vendor to adhere to applicable portions of regulations and standards. All such vendor actions and decisions are.
(
however, subject to final B&R engineering review and approval and documented in accordance with D0-004, " Foreign Document Processing and Control."
(
In reply to Quadrex's specific question regarding an acceptance criteria for The reliability analysis requested the sequencer reliability (Question E-8):
from the sequencer vendor is infonnation that was specified to be furnished because such information is readily available for this type of eautoment, and can be used to assist in establishing the testing frequency. There is no requirement to establish a numerical reliability index for sequencer acceptance.
e 37
-m-n w
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ENCLOSURE 2 s
ITEM NLMIER:
4.3.2.1 (k)
DISCIPLINE:
Electrical AGREE WITH FINDINE:
C X
L)RELMNgpy DISAEREE WITH FINDINE:
THIS ITEM IS CONSIDERED TD RE:
REPORTABLE. _. _
.D I
POTENTI ALLY REPORTABLE _
D INSUFFICIENT DATA FOR ASSESSMENTQ NRC EU' QUADRgx g VIEW 7
Ruza,.a NOT REPORTABLE-
- - ---.. U No.4
~
RASIS FOR ABOVE ASSESSMENT:
]
STP does incorporate new and old NRC requirements into design consistent with HL&P comittments and direction. Concerning the reference to I&E Circular 79-12, a 7-30-79 memo, GM-51393, from Mechanical to Licensing, states that the lubrication problem cited does not apply to our diesels which have a different design and are from a different manufacturer.
Had the concern of moist air been addressed to Mechanical, they would have explained that an air dryer has been incorporated in the cogressor design from the outset.
Not having all references we can't address the "many" TRD's and SDD's referring to superceded industry standards and NRC regulations. We can, however, address those referred to in the E-3 assessment.
The reference to IEEE 344-1971 in EQOO4, Sec. 2.3 is not an error. Note the remainder of that reference states "with BTP/EICSB-10". IEEE 344-1971, supplemented by the BTP is the PSAR and FSAR comittment for STP, IEEE-1975, meets or exceeds this comittment. Because of the purchase date, some eouipment came under this earlier revision. This position is stated in FSAR 3.10, 2nd paragraph.
The referenced footnote in EQOO2 refers to this same historical condition.
38 O
ENCLOSURE 2 4(
ITEM NIMER:
4.3.2.1 (m)
DISCIPLINE:
Electrical /I&C o'
PREL/Mgggy
.EE - n Inc.
DISAGEE WITH MNDINE: b THIS ITEM 15 CDN51 DEED TO E:
EETEEiTis&&i"."*8
~S&l2 W INSUFFICIENT DATA FOR ASSESSMENT Q gg~y-NOT EPORTABLE-
.U L
J BASIS FOR ABOVE ASSESSMENT:
Quadrex Coment: No tisis or methodology appears to exist to assure that all requirec manual operations at remote panels can be performed under various plant operating conditions (see Question E-13).
Brown & Root Resoonse: SDD's, Design Assurance, Safety Systems Kszard's Analysis will accress access for all manual operations under accident conditions.
l Basically, Souti Texas Project layout of equipment, control panels, etc., with reference to accessibility differs very little from other huclear Power Plants.
The " basis" or " methodology" employed to locate equipment does exist in the i
Brown & Root Engineering judgement and discussions with HL&P counterparts l
exercised in the past to locate equipment. There.is nothing unique about this approach.
(
Emphasis on locations and accessibility of control panels evolved as a result of TMI. This is presently under review and is outside the scope of the audit.
NOTE:
At the time of audit, B&R stated to Quadrex that the environmental cons 1tions during accidents (especially radiation) was going to be reviewed in great detail when TMI W/A's 80-47 & 80-50 would be performed. These W/A's and B&R's scoping of this work provides the basis and metnodology.
1 i
l l
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39 I
1
-.c.-~...
ENCLOSURE 2 ITEM NLMBER: 4.3.2.1(n)
Q DISCIPLIE: Electrical /IAC AGEE WITH FINDING:
C PREL//gfgAR DISAGEE WITH FINDING: a THIS ITEM 15 CONSIDEED 10 BE:
REPORTABLE......
POTENTIALLY REPORTABLE..
N. C RIV 9U;ADREX REVIEW 7
IN5UFFICIENT DATA FOR A55 h"...REf4CE DOCUMENT 2
NOT EPORTABLE-LI No.
I SA515 FOR ABOVE A55E15 MENT:
Specific applications for isolation devices are determined by individual system engineers based on the requirements outlined in Section 25 of 3E570EQ006-C, One Criteria for Electrical System Independence which is taken from IEEE 384 comon design will be used to satisfy digital isolation requirenents, but each analog isolator will be evaluated individually to verify that it satisfies
[
both circuit requirements and TRD requirements.
A study made in March,1981, identified 1025 digital and 24 analo application is necessary in a system which treats all digital isolation in the requirements.
same way and only requires 24 analog isolators.
In all cases the isolation devices are applied by an engineer who is cognizant of isolation requirements (through the TRD), they are checked by an equally competent design verifier and they will meet the requirements of all regulatory guides and industry standards applicable to isolation, separation a qualification.
outlined suitable guidelines and implemented suitable controls on isolation devices to insure a fully licenseable design.
i t
40
.4
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ENCLOSURE 2 4 3.2.1(o) and question E-18 ITEM Nt#RER:
Electrical DISCIPLIE:
AGEE WITH FINDING:
h
- 915AGEE WITH FINDING: O DR[
TH15 ITEM 15 CONSIDEED TD E:
..O REPORTABLE.
POTENTIA.LY EPORTABLE_. _ _D NRC Rry QUADREX REVIEW INSUFFICIENT DATA FOR ASSESSMENTD REFORINCE pocuugn7 NOT EPORTABLE-
.....DX No. -
L/
s I
SA515FDRABOVEASSESSNENT:
The B&R response to E-1 implied that the design verifier and checker were different individuals, because this is comonly the case. It is not a procedural requirement For es per STP-DC-015, " Design Verification", the governing project procedure.
calculations, the design verifier usually signs as checker also, since he has This evolved out of there
,e to check the calculation in order to verify it.
(
being a desire to have the Design Verifier's signature on the calculation coverand DPE.
sheet and there only being allocated sionature space for the Author, Checker,ign of Furthermore ANSI N45.2.11,1974
" Quality Assurante requirements for the des Nuclear Power Plants" does not require the design verifier and the checker to be different individuals.
i p
41
ENCLOSURE 2 ITEM NUSER:
4.3.2.3(p)'and question E-23
)
Electrical DISCIPLIE:
AGEE WITH FINDING:
C PRELIlmNARY
,15aEE wu naza: 3 l
THIS ITEM 15 CON 11 DEED 10 BE:
NRC Rtv WEW I'EFERENCE o REPORTABLE.... _ _-... -
p W
POTENT 1 ALLY EPORTABLE ng -
. INSUFFICIENT.u_TA FOR ASSESSMENTg L
DA 1 E,om BASIS FDR ABOVE ASSESSMENT:
The battery resizing study began in late 1980. not due to "the absence of adeq interdisciplinary documents, but to the finalization of bus assignment for some DC lighting loads, a decision to make use of battery packs and new I&C C load assignments.
As stated at the time of Quadrex audit, the present calculations for the DC Syst The calculations (both IE and non-IE) are under revision and reevaluation.True the data was obsolete, bu presented were for method analysis only. basic format for the calculat As to the time frame for changes to this or any other sy Changes to the DC systems are required due to the finalization of certain and an evaluation of new requirements imposed by NRC and/or industry requ such as TMI impact.
Brown & Root agrees with Quadrex in their assessm several months.
In conjunction with the finalization of the DC Systems, the Instrumentation P i
System will be finalized for both Class IE and non-Class IE items.
i H,
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42 I
w-a n>
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.x
-~
ENCLO5URE 2 ITEM NUPSER: 4.3.2.3 (q)
DISCIPLINE:
Electrical /I&C PRELIM /yggy
~
as=E = m D! n..
O X
DISA& HEE WITH FINDINE:
THIS ITEM 15 CDNSIDERED 1D BE:
NRC RIV QUADREX REVIEW REPORTABLE....
Q REFERENCE DOCUMENT POTENTIALLY REPORTABLE
.D NO.
b INSUFFIC3ENT DATA FOR ASSESSMEhTD NOT E PORTABLE -
.. E BASISFORAB0VEA33ESSM5NT: Quadrex Coment: B&R requires the vendor to interpret and implement applicaole portions of industry standards (see Question E-5).
It would be more appropriate for B&R to provide detailed guidance to vendors.
f Brown & Root Resoonse: Quadrex refers to question E-5 as a source connected with the above CorlTnent. Actually, this comment was generated from an observa-tion by Quadrex during their review of ESF Load Sequencer Specification 3N099ES971-E, not the actual questions and answers pertaining to E-5.
B&R feels that the methodology employed to cor.vey rcQuirements for vendor inter-pretation is acceptable.
With reference to a vendor supplying ESF load secuencers, the vendor would be more familf er with this specialized equipment, and therefore would be more expert'Ise
~
towarcs implementing IEEE document requirements, etc., in the design of the equipment. Brown & Root phylosophy in this area, would be to ensure that the engineering fuctional requirements are met, and thet the vendor complies with the IEEE/ Reg. guide requirements.
l Evaluation of vendor documents reflecting the implementation of the required l
standards is reviewed by the responsible engineer who would at that time l
ensure the adequacy of design. See STP procedure STP-DC-004 for the methodology for approving vendor drawings and documents.
l If the Quadrex approach to the use of approved industry standards was adopted by everyone, the whole standards program effort currently underway by IEEE, ISA, ASME, ANS and others would be in jeopardy.
43 m--
-m..
ENCLOSURE 2 ITEM NUPBER:
4.3.2.4 (r) Potential Problem Findings Page 1 of 2 DISCIPLIXE:
Electrical /I&C AGREE WITH.FINDIN&r.
D ERELIMINARY DISAGREE WITH FINDINE: O THIS ITEM IS CONSIDERED TD SE:
NRC RIV QUADREX REVIEW REPORTABLE.,....
REFERENCE DOCUMEt:T POTENTIALLY REPORTABLE _. _
N O.
p INSUFFICIENT DATA FOR ASSESSMa'T NOT REPORTABLE -
BASIS FOR ABDVE ASSESSMENT: Quadrex consnent: Technical comunication among various disciplines may require improvement (see Questions E-2 and E-16).
Brown & Root Resconse: Brown & Root generally concurrs with the above statement.
Deviously, comunication either technical or general information interface r
(
between disciplines always has a need for improvement -- regardless of the existing degree of efficiency.
However, B&R has addressed this problem area by producing probably far more design assurance requirement, procedures, documentation of design reviews, etc.,
than any other AE's currently involved with the Nuclear Industry.
With reference to Quadrex's areas of concern:
( i) Question E-2 B&R did not state in the response, "... specifications EQ-006 and ZQ-003 do not provide input to other disciplines...." EQ-006 is presently in the sign-off stage and will be incorporated in the STP Design Manual (distributed to all disciplines). 2Q-003 is currently incorporated in tne STP Design Manual (distributed to all disciplines). The reference to the use of PVC in 20-003 is applicable only to non-sefety related systems in yard areas.
(ii) Question E-16 Quadrex "Found no communication between I&C and Nuclear Analyses for calculations to determine ranges or set points." If Quadrex has re-quested documentation to substantiate this type of correspondence at the time of audit, it would have been readily produced.
Quadrex "No documentation was provided that defines bases and h_
assumptions per N.R.C. R.G.1.105.
44
. ~.
.w.m-m...
ENCLOSURE 2
(
ITEN NUMBER:
4.3.2.4 (r) Potential Problem Findings [ continued]
Page 2 of 2 g.
STP, FSAR, Table 3.12-1, Regulatory Guide Matrix, Note 28 states-
" Regulatory Guide R.G.1.105 is not discussed explicitly in the FSAR, however, instrument spans and set points are discussed in the Technical Specifications."
Regarding the process radiation monitoring system, refer to the STP calculations ref. NC311, 2C009, 2C011 and 2C014 for examples displaying both comunications interdisciplinary and basis for set point derivations.
NRC RW QUADREX REVIEW REF.*RENCF. DOCUMEliT NO.
ERELIML. iu
(
0 C.' ^]'.,
C., '
45 w
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ENCLOSURE 2
[
ITEM NUPSER:
4.3.2.4,(s)
DISCIPLIE:
Electrical AGREE WITH FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO E:
REPORTABLE...
POTENTI ALLY REPORTABLE - - - -
NRC RR' QuaDREX REVIEW INSUFFICIENT DATA FOR ASSESSMENTQ NOT EPORTABLE-
.U RERiNCE occuugny V
No.
I SASIS FOR ABOYE ASSESSMENT:
Inconsistency of fom will not be the source of error, because it is the technical content of a document which is used for system design, not its form.
It is probably better to specify environmental data directly in the spec., but whatever method is used, the vendor feeds back the data and correctness is confirmed.
The reference to IEEE 344-1971 is correct, as explained in (k) above.
When Reg. Guides are not listed as a reference in a purchase spec., the responsible engineer must assure that the special requirements igosed by the Reg. Guide, if any, are properly incorporated. However, if Reg. Guides are referenced the RE still has to assure compliance. The proper consideration hem, then, is that standardized fom, though it can aid the design process, does not assure correct design.
46
,eu*e==
a u --..
ENCLOSURE 2
[
~
ITEM NUPSER:
4.3.2.4 (t) s DISCIPLINE:
Electrical AGEE WITH FINDING:
C V XARY DISAGREE WITH FINDING:
i
/
THIS ITEM 15 CONSIDERED TD E:
REPORTABLE _
.D POTENTI ALLY REPORTABLE-. _ _D NRC RIV QUADREX REVIEW INSUFFICIENT DATA FOR ASSESSMENTD r&ER2NCE DOCUMENT NOT REPORTABLE- -- -.
..U v
BASIS FOR ABOVE ASSESSMENT:
All vendor documentation is reviewed in strict accordance with Engineering Procedures DC-004 and DC-014 The assigned Responsible Engineer has specific responsibility to see that all vendor documents are reviewed and Resources throughout the evaluated by appropriately qualified persons.
purchasing discipline, in other disciplines and including B&R staff are available
(~
6 and are applied as appropriate.
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47
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ENCLOSURE 2
(.D ITEM NMER:
4.3.2.+ (u)
DISCIPLIE:
Electrical /I&C a.EE vm nom..
D OOfLI/4/Nggy Dzs EE vrTx nNeza: m THIS ITEM 15 CONSIDEED TO E:
REPORTABLE
'.D NRC RIV QU40 REX REVIEW PDTENTI ALLY REPORTAB' r
-.D Nd2ENCE cc w.ftra INSUFFICIENT DATA FDR ASSE13MZhiQ NO-g NOT EPORTABLE-5 SA315 FOR A80VE ASSESSMENT: Quadrex Coment: B&R's position regarding use of only failsafe Class 1E solenoic valves should be re-examined (see Question E-3).
[ -
Brown & Root ResDonse: This statement by Quadrex does not reflect the infor-mation versally given to them at the time of audit. B&R feels that the fail s,afe concept use of Class 1E solenoid valves is acceptable.
During the construction permit licensing stage of STP, this design approach was presented to the N.R.C. and was implimented with their approval.
Any class 1E s'olenoid valve would be subjected to periodic testing, which includes operating, to ensure operability.
Also any class 1E solenoid valve would have redundancy to conform to the single failure criterion requirements.
The fact that all 1E solenoid valves are fail safe (de-energize to perform the ESF function) does not mean that no environmental Qualification is imposed on these valves.
All 1E equipment, including these solenoid valves, is qualified to the local environmental conditions.
48
Am.w,
ENCLOSURE 2 p
ITEM NUPSER:
4.3.2.+ (v)
DISCIPLIE:
Electrical /I&C b
b AGREI WITH FINDINE.m DISAEREE WITH FINDING: b THIS ITEM 15 CONSIDERID TV E:
NRC RIV QUADREX REVIEW qgg...
MNCE DMAENT INSUFFICIENT DATA FOR Ass NOT REPORTABLE No.
b SA515 FOR ABOVE A33E158kNTs Quadrex Coments: BAR's criteria regarding equipment and system monitoring is not sufficiently clear and may need to be re-evaluated (see Questions E-5, E-9 and E-21).
Brown & Root Response: Brown & Root disagrees with Quadrex coments as follows:
Ref. E-5 Inis comment deals with the ESF load sequencers which are still presently in the early stages of design pertaining to alam interface with the main control room. Section 1.3, ESF Monitoring of TRD 20002 provides the criteria for ESF status monitoring. There is no requirement to monitor the sequencer output signals, per se. This is an arbitrary requirement from Quadrex. What is monitored, is the fact that each ESF component has been activated to its ESF position.
Ref. E-9 Tnis coment also deals with the ESF load sequencers, i.e., Engineering in this area of the design is still in progress.
Ref. E-21 Quacrex is addressing " sequencing & hierarchy of alams." B&R feels that this is related to TMI and outside the scope of the audit. Specification 7231925090 is not a document dealing specifically with " Design Basis" for alan sequencing. This document is the specification for the Main Plant Annunciator System. The " Design Basis" for alam sequencing is discussed in this document as stated in the original B&R response to E-21.
Reference the detection of large and small breaks. Refer to the r4echanical Discipline response to item number 4.4.2.4 (x).
49 w
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ENCLOSURE 2 ITEM NUPBER:
4.3.2.4.(W)
DISCIPLINE:
Electrical AGEE WITH FINDING:
C DISAGEE WITH FINDING: O
%h THIS ITEM 15 CONSIDEED TD BE:
REPORTABLE
..D POTENTI ALLY REPORTABLE-
- _D INSUFFICIENT DATA FOR ASSESSMENT NRC RIV QUADREX REVIEW NOT EPORTABLE- - - - ---..
ncF.:azucE DOCUMEt4T N O.
BASIS FOR ABOVE ASSESSMENT:
While it is true that interface design between the load sequencers and the Westinghouse protection systems has not been completed, sufficient documentation does exist to verify Brown & Root's intended separation objectives, which are as follows:
1.
There will be one sequencer assigned to each of Trains A, B C.
Each sequencer will be Class IE, and will be located in the equipment room designated for its respective train, as shown on equipment arrangement drawings 1-E-1853,1856, and 1861.
2.
Cables connected to each sequencer will be Class IE train cables only, and only cables that have the same train designation, i.e., Train A sequencer will be connected to Train A cables. Train A cables will be run in cable trays separately from other train cables per document E0006,
" Criteria for Electric System Independence." Cables for Train B and C sequencers will be separated in the same manner. Non-train cables, such as annunciator circuits, will be isolated from each sequencer by remotely mounted isolation relays.
3.
Sequencer input circuits will be isolated from outputs; internally, by use of steel barriers (specification 3N399E5071-E, Section 3.3.3.1), and externally, by routing input circuits in instrument tray and outputs in control tray.
We concur that Quadrex's recomendation that consideration be given to an improved symbology for designation of redundant trains has merit.
50
w.wo.:.w.m.
ENCLOSURE 2 V
ITEM NUPSER:
4.3.2 A- (x)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDIN&r.
D DISA&REE WITH FINDINE: b h
THIS ITEM 15 CONSIDERED TD SE:
REPORTABLE....
PDTENTIALLY REPORTABLE NRC RIV QUADREX REVIEW INSUFFICIENT DATA FDR ASS RErcF:ENCE COOUMENT NOT REPORTABLE-BASISFORABOVEASSES3rdNT:
Quadrex Coment: Proper operation of actuation equipment, such as MOVs and pumps, should be verified for all possible transitions in operating modes of the ESF Sequencer (see Question E-8).
Brown & Root Resoon e: Ref. E-8:
[-
Mooe I followec oy 6de II has been quoted in the Quadrex Assessment.
This is essentially a plant Safety Injection followed by a loss of off-site power.
When the plar t is in an SI condition, the ESF required equipment is started up either directly from the W Solid State Protection System or via the ESF load sequencer for extremely heavy electrical load equipment.
Simultaneously, the Emergency Diesel Generators are started and remain run-ning on stand-by.
During this time, if a loss of off-site power is experienced, transfer to on-site power is almost instantaneous as far as the motor operated valves and most pumos applications connected to the 480V distribution system, due to the Diesel Generators being on stand-by condition. Heavy loads e.g. HHSI, etc.
would be stripped from the bus and then sequenced on again. Loss of ESF Safety Equipment during this transition is minimal.
Mode 11 followed by Mode I is also mentioned in the Quadrex Assessment. This is essentially a less of off-site power followed by a Safety Injection Signal.
Prior to the Safety Injection Signal, the plant is running on the Emergency Diesel Generators. Limited ESF equipment is required up to this point in i
time. Upon receipt of a Safety injection Signal, the W Solid State Protection System signals the required ESF equipment to function.. Since power is already available, transition is almost instantaneous as far as the motor operated valves and most pump applications connected to the 480V distribution system.
Heavy loads e.g. HHS!, etc. would be stripped from the bus and then sequenced on again.
In both of the above discussions, it should be apparent that operational problems do not exist pertaining to partially opened valves" or " rotating" motors.
51 y
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- a. - ~.--
LNLLUbOKZ 4 ITEM NUPRER:
4.3.2.4 (y)
DISCIPLIE:
Electrical /I&C ASREI WITH FINDINSr.
O EREJMINANY DISAGEE WITH FINDING:
THIS ITEM !$ CON 51 DEED 10 SE:
f4RC RIV QUADREX REVIEW REPORTABLE.......
POTENTI AU.Y EPORTABt t-REFER ~NCE DOCUMD:T N
INSUFFIC2ENT DATA FOR A55E11MEhi rp' '
NOT EPORTABLE-BA515FORAB3YEASSES$MbMT:
Quadrex Comnents: B&R's position regarding sensor response time testing should be verifiec (see Question E-12).
Brown & Root Resoonse: The original question E-12. referred to sensor response times within the values specified in FSAR Table 7.2-3.
Brown & Root's position is unchanged, the items listed in Table 7.2-3 are the responsibility of Westinghouse to determine response time testing.
On the STF project, the only equipment purchased by B&R that fall in the same category of the equipment listed in this Table is the Radiation Monitoring System.
B&E identified this equipment to Quadrex at during the audit, and pointed out that known methods for response time testing are presently in research and development and have not proven acceptable for use.
(Please refer to draft ISA document 567.06).
B&R is purchasing a safety grade hydrogen monitoring system. However, this system does not perform a Reactor Trip Function.
/
52
a.~.~..,
ENCLOSURE 2 r-ITEM NUPRER:
- 4. 3. 2.4 (2 )
DISCIPLINE:
Electrical /I&C I"
gh[l DISAGREE WITH FINDINE: b THIS ITEM IS CDNSI ERED 10 SE:
REPORTABLE.....
NRC RIV QUADREX REVIEW REFERENCE 000UfAEt47 POTENTI ALLY REPORTAB' r _,
INSUFFICIENT DATA FDR ASSESSMDiT
- rgo, Q
NOT REPORTABLE-BASIS FOR ABDVI ASSE13PhMT:
Quadrex connent: An analysis of the actuation logic relative to NRC requirements between the main FW and the AFW system should be performed (see Question E-15).
E Brown & Root Response: During the initial review of the Quadrex questions.
(
tnis portion pertaining to the AFW initiation was eliminated by mutual agree-ment, BR/HL&D/Quadrex, as not being applicable to the South Tex.as Project.
The STP W Solid State Protection System initiates the AFW pumps.
There is no direct actuation signal between the main FW and the AFW system. This part of the ESF actuation is part of the W design.
Refer to ji Functional Diagram #8758D22 sheet 16 or B&R logic diagram
- 1-2-3280 sheet 1.
e e
53
ENCLOSURE 2 4.3 2.4 (aa). (E-18) '
/~
ITEM NUSER:
(.
Electrical DISCIPLIE:
ASEE WITH FINDING:
O nisAsatt vrTw nanin8: G
?RELLMtNAPJ m5 ITtM 1s consioEED TD n:_...o EP==tE _.. _ _ _ E-D POTENTIALLY REPORTABL INSUFFICIENT DATA FOR ASSE55MENTQ NOT EPORTABLE-. -.
. W NRC Riv qunaggy ggy;gW W203cE D0cuMENT BASI 5 FOR ABOVE ASSES $ MENT:
N No.
N.
4.3.2.4 (aa).NE-18)
The Reference Quadrex makes to docunent fSTP-PE-005-A as a " Specification" is This document is a procedure for " Scheduling" cable and raceway in the incorrect.
The fact that various materials are shown for conduit is CARDS computer program.
purely for codification purposes in order to list all types of conduit and cable The plastic conduit referenced by Quadrex and shown in par. 3 The type of material used on STP is specified in the cablin tray.
3 of STP-PE-005-A is used only when it is encased in concrete where lack of air will not allow In all other cases the conduit and cable tray is hot-dipped galvanized conbustion.
The notes at the end of paragraphs 3.5.2.la and 3.5.2.3a of PE-005 support steel.
In order to preclude misinterpretations of this section by future this statement.
auditing agencies, PE-005 will be revised to show only the material types used on STP.
The Quadrex statement that special raceway are not defined in STP-PE-005-A is Paragraph 3.5.2.5 identifies and dimensions specific types of special inaccurate.
raceway for codification purposes. A conputer printout is presently being made to analyze all special raceway for percent cable fill. The 75% fill for special raceway only is an error in PE-005 and the cabling SDD. This will be changed to 40% fill for all raceway in the next revision of each of these documents.
Bb
~
b 54
ENCLOSURE 2
(.
ITEM NUSER:
4.3 2.4(bb) and question E-22
(-
DISCIPLIE:
Electrical AGEE WITH FINDING:
C B15ASEE WITH FINDING: O PREUMt Mi i
TH15 ITEM 15 CON 51EED 10 E:
EPORT ABLE.
POTENTIALLY EPORTABLE INSUFFICIENT DATA FOR ASSESSMENT N. C R!Y C'JoD'?EX REVIEW 7
NOT EPORTABLE
- ncE or4'ENT r._:
4 N1
~
BASIS FOR ABOVE ASSESSMENT:
B&R will reverify that no Class IE heat tracing is requimd by'any system by sending the completed SDD for review-coment. At that time all fluid system disciplines The review coment cycle for the will review the completed SDD for correctness.
completed document is required by project procedure " Engineering Procedure for
,e System Design Descriptions". 5T-5D-002.
The electrical discipline server as a service organization by virture of our assigned function to supply electrical power as requimd for other d equipment.
points apply.
The heat tracing presently is identified as non-IE and therefore no requirements presently exist for special handling of this system.
The point raised in regard to boron precipitation is not applicable to the South Texas Project as current design concepts implement boron in concentrations below i
the level at which precipitation occurs.
True, earlier W plants implemented systems that require Class IE heat tracing to preclude boron precipitation, however, the South Texas Project must be evaluated against present design parameters not past or outdated criteria.
HL&p in conjunction with W as the owner and NSSS suppliers respectively have Brown & Root as the Engineer /
assumed the responsibility for this criteria.
Constructor has in fact provided or will provide suitable design for the criteria and equipment required under the present mandate of the owner and NS$$ supplier.
If further NRC. W or HL&p changes mandate a requirement for Class IE heat tracing, Brown & Root wi1T provide design to meet these needs as they are identified.
y 55
E5 CLOSURE 2 ITEM NUPSER:
4.3.2 5,(ce) and question E-2 s.
DISCIPLIE:
Electrical AGEE WITH FINDINE:
O O
DISASREE WITH FINDING:
pagtigiNisRY TH15 ITEM 15 CDN51EED 10 E:
REPORTABLE........
POTENTI ALLY REPORTABLE.- - -.
INSUFFICIENT DATA FOR ASSESSMENT NCC RIV OUtDRIX REVIEW NOT EPORTABLE- --.
h. :n a;: Do ~u' finT N
rn BASIS FCR ABOVE ASSESSMENT:
E-2 Assessment Response:
Detailed input EQOO6 does provide generalized input to other disciplines.
based on EQ006 is transmitted by design drawings which are sent to the other
(
disciplines as they are issued.
Brown & Root inferred from the Quadrex telecopy of March 3,1981, from Mr. L. Stanley (Q) to Dr. Sumpter (HL&P) and Mr. Signorelli (B&R), mutual agreement that the request for "the design basis for barriers and their acceptability criteria for intended hazards" pertained to " electric cable penetration barriers through containment", therefore the presentation was centered around the penetrations. In view of Quadrex's assessment of the presentation, it is unclear what information Quadrex is seeking.
The slide showing the use of Flamastic was included in the presentation only The boot-assembly to show the flexibility of the attachment to the penetration.
as shown with the Flamastic is presently under test by Chemtrol, the silicon The boot is not being foam manufacturer, to establish a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.The penetration itself is a barri relied on a barrier for the penetration.
being qualified to IEEE 383.
56
~.s....
ENCLOSURE 2 ITEM NU S ER:
4.4.2.1 (a)/(b)
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X DISAGREE WITH FINDING:
fh L
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTEhTIALLY REPORTABLE........
X INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
N.*!C F!!V QU$DREX REVIEW i cr :r:40E c ;UMEt!T BASIS FOR ABOVE ASSESSMENT:
NO-
~
These items were addressed in enclosure 2 of correspondence dated 5/08/81 -
HL-38718.
/ ~
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57
m...,_.,.
ENCLOSURE 2 ITEM NUPEER:
4.4.2.1 (c)
-~.
\\
DISCIPLINE:
HVAC Systems A05 AGREE WITH FINDING:
hh DISAGREE WITH FINDING: X THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE,.......
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X ICC mv OU ADREX REVIEW i,.F.,n cruMi:riT C'
BASIS FOR ABOVE ASSESSMENT:
(1)- The Ouadrex questions H-3 and H-27 do not deal with hydrogen concentra-tions in containment. Quadrex assessment regarding hydrogen concentra-tion inside containment noted under H-3 is arbitrary since this subject was not discussed in Quadrex audit meeting.
Analysis'of hydrogen concentrations inside containment has been per-formed by B&R, based on uniform mixing by the HVAC systems. The HVAC supply and returns are located, as per engineering judgment, to provide uniform air flows as required and to prevent pocket accumulations. No reliable methodology exists at present to calculate and evaluate localized concentration of hydrogen inside containment.
(ii) B&R statement of 3% hydrogen concentration limit was incorrect. The calculations are based on 2% limit, as per B&R response to Ouadrex question N-25.
th e
e 58
ENCLOSURE 2 s
.r
/(
ITEM NUSER: 4.4.2.1 (d)
DISCIPLINEJ Mchanical/HVAC
~
AGEE WIT'M FIEDING:
D15AGEE WITH FINDING: O PREgtg g TH15 ITEM 15 CON 51EED TD BE:
REPORTABLE.
POTENTI ALLY REPORTABLE..M
, Nr.C r.E OU 'DP.EX REVIEW INSUFF]CIENT DATA FOR ASSE NOT EPORTABLE-n ; c ; ;ur.itraT k
to.
DA515 FOR AloyE A15E55M:
~
/
The effects of high energy li.ne breaks on essential HVAC components will
(
be identified as part of the pipe break analysis program currently being established.
.A logic for this effort is attached.
A detailed review of the HVAC systems'and their separation requirements in the event of a fire is being addressed as part of the Hazards Analysis Program. A lor,1c for this effort is attached.
Non-safety HVAC ductwork is seismically supported in the vicinity of safety related eqJipment. Therefore, there is no possibility of the ductwork impacting the safety related equipment.
e f'
59
._.4m-~..
ENCLOSURE 2 PIPE 8REAK ANALYSIS OUTSIDE CONTAllMENT p
2REUgNAgy GENERATE DEVELOP DEVELOP TRD 8/15/81 ESSENTIAL HIGH ENERGY 8/15/81 8/15/83 (MECHANICAL)
SAFE SHUTDOWN 1.INE LIST FLOW PATHS (MECHANICAL)
(MECHANICAL)
U U
V T
8REAK ANALYSIS 12/31/81 (STRESS) z, 1
iw t:tdRD~
DEVELOP m
Ewu'4.u'(:~t
. INTERACTION v W "'N t C F.Ac t EwA'#'Js MARIX FRm 6/30/82 E " I*
1 COMPOSITE AND fac/ab mcut tid
(.
HAZARDS ANALYSIS
--~
DRAWINGS MELE DO (MECHANICAL)
\\
REVIEW BY ALL DISCIPLINES (Natu^R b"#3 /
=
j U
NRC f:ir QUADREX REylE[
PROBLEM IO;32NO{ DOCUMD:7 RESOLUTION no.
- WHIP RESTRAINTS
- JET IMPINGEMENT ANALYSIS 12/31/82
- JET SHIELDS (MECHANICAL,STRUCTURIAL.
ST~ES$)
H PRELIMINARY PACKAGE COMPLETE - UPDATE
& FIELD VERIFICATION 12/31/82 REQUIRED PRIOR TO FINAL STRESS ANALYSIS 60
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ENCLOSURE 2 e
ITEM NUPSER:
4.4.2.1 (f)
(.'
DISCIPLIfiE:
HVAC Systems A05 AGREE WITH FINDING:
X Jh DISAGREE WITH FINDING:
I THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
Inconsistencies between the FSAR and other HVAC design documents will be resolved as a part of the design freeze process.
Each system, as completed, will be corrected as necessary in the FSAR and the SDDs.
(
Corrections will be made by the design freeze dates.
NF.C Ri\\' QU4DREX REVIEW W.RIs02 DrVMENT H
n:.
6 62
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mm.w..
ENCLOSURE 2 Page 1 of 2 ITEM NUf6ER:
4.4.2.1(g)
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
POTENTIALLY REPORTABLE.....
REPORTABLE..............
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
BASIS FOR ABOVE ASSESSMENT:
RESPONSE
The following is a listing of ANSI N45.2.11-1974 Paragraph 6.0 requirements regarding design verification by document reviews:
( *.
1.
The design verifier must be -
a.
Competent NRC RW QU ADREX R$ VIEW b.
Not the Originator nJIRact 000VI. TENT c.
Not the Supervisor L-
" 0-d.
Not Have Limited the Design 2.
Results must be documented and filed.
3.
Extent of review is a function of importance to safety, complexity, and similarity.
4.
The nineteen questions on paragraph 6.3.1 shall be addressed.
5.
All design changes must be reviewed.
All of these requirements are addressed in the following procedures (as listedabove):
1.
STP-DC-015 Section 2.3.4 Section 3.1.1.c 2.
STP-DC-015 Section 2.2.1.2.2 Section 2.4 Section 3.1.7 3.
STP-DC-015 Section2.3.[
63
r ENCLOSURE 2 Page 2 of 2 4.
STP-DC-015 Section 2.3.5 Table 1 5.
STP-DC-015 Section 2.3.6 There is no requirement that a specific written criteria (checklist, etc.)
for the selection of verifiers be provided. Judgment is acceptable. A file on the verifier's qualifications is available for review. This is sufficient.
The method used by the design verifier is defined in Engineering Procedure STP-DC-015. The procedure also requires him to certif procedures. STP-DC-015, Section 2.3.5 states (in part)y that he folicwed The verifier signs this form as his professional certification that:
o To the best of his knowledge, the document is correct and was prepared according to applicable procedures.
o The Verifier was not the author of the document being verified.
o The Verifier addressed all of the questions in Table 1.
This is sufficient.
I The findings are, therefore, not valid.
NF.C RIV QU $D.'!EX REVIEW l.cf'C.. 0C CLU /ENT in.
N U
\\Q\\\\QN 64
ENCLOSURE 2 ITEM NUPEER:
4.4.2.2 (h)
DISCIPLINE:
HVAC Systems A05 AGREE WITH FINDING:
DISAGREE WITH FINDING:
ME_m, i ARY THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
N3C RIV QU.8.DREX REVIEW NOT REPORTABLE............
X iMZl::E cocu,*.tzt:r t:0.
BASIS FOR ABOVE ASSESSMENT:
The HVAC Systems in the radioactive areas of the plant are designed and balanced for "nonnal" operating condition with the doors and hatches shut.
In case of an " abnormal" condition such as during maintenance and pre-op testing, when
[
the doors and hatches may be open, the air would still flow from clean to contaminated area as in normal condition. The only detriment will be that the face velocity will reduce across the door / hatch openings. This problem will be somewhat relieved due to the fact that more air will flow from clean i
to contaminated space with the door / hatch open. This will not affect the sys-tem balance drastically.
It is almost inpossible to balance the system exactly for various possible conditions of different number of door / hatches open. To provide higher face velocity through open doors / hatches, the system air flow capacity will have to be increased substantially, which may cause l
problems during nomal operation when doors / hatches are shut. B&R feels that it is impractical to design the system for a much higher capacity than required during nonnel operation. However, B&R understands the concern for this problem and will evaluate the HVAC systems to determine the extent of the problem and make any changes, if necessary, by the design freeze date.
When the system is finalized as per design freeze date, B&R will provide the input to HL&P for establishing administrative controls to prevent G.
inadvertent opening of certain doors, hatches, and plugs in radioactive
/
- areas, b
65 L
- ~ ~x h
There is no single documented project criteria for HVAC design in radioactive However, the items listed in the suggested criteria by Quadrex (see areas.
Quadrex assessment for H-3) have been included in the system design des-cription and/or have been addressed above in this response.
ERELIVilN ARY R
tiiC Riv QUADREX REVIEW n;; r;;t::t c30uME T b
{
- 3. --
66
_.~.
ENCLOSURE 2 ITEM NUE ER:
4.4.2.4(1)
,n.
DISCIPLINE:
HVAC System A05 AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
B&R is presently in the process of updating HVAC design in~ uts from other disciplines. The inputs will be transmitted in a controlled manner and format with records maintained in the DCC. This effort is part of the design freeze process and will be completed during the design freeze.
/
f.'.'C RIV QUADT'EX RIVIEy/
ERE1 h,\\ n* n i u r=.;1;" t. :
JMi::T m.
.l%
67
ENCLOSURE 2 s,
ITEM NUM ER:
4.4.2.4(j)
DISCIPLINE:
.HVAC AGREE WITH FINDING:
DISAGREE WITH FINDING:
X THIS ITEM IS CONSIDERED TO BE:
P.EPORTABLE..............
POTENT DtLY REPORTABLE........
INSUFFICENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
The various design an61ent conditions are detemined by the " user" require-ments. The interface is through review of the HVAC SDDs by the user dis-ciplines. The following examples were provided during the audit, but evi-dently overlooked:
SYSTEM SDD NO.
MAB HVAC System SV109VD001 EAB HVAC System SV119VD002 PHB HVAC System SV129VD003 DGB HVAC System SV139VD004 RCB HVAC System SV149VD006 TGB HVAC System 8V329VD008 Upon request, B&R will again provide examples.
NF.C RIV QUADREX REVIEW r,;rtr.:act 00:Uutr1T t:3.
D E8
i wo.ww.b.. -
ENCLOSURE 2 ITEM NUPEER:
4.4.2.4 (k)
DISCIPLINE:
HVAC AGREE WITH FINDING:
X PR':'"llV I' MARY DISAGREE WITH FINDING:
s THIS ITEM IS' CONSIDERED TO BE:
REPORTABLE..............
DOTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
This inconsistency will be corrected by July 31, 1981. Specifications and SDDs will be reviewed and inconsistencies corrected by a Design Change Notice, s
I s
SCHEDULE:
6/26/81 7/03/81 7/17/81 7/31/81 3,,,p 2 weeks 2 weeks TART A
Review SDD/ Spec d HL&P Review d
Issue DCh d
and Issue PDCN and Approval NOTE:
Interdisciplinary review not required in this case, i
tm0 P.IV QUADREX REVIEW
,,j.;;;,;4;E COCUMINT i
i a
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69
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ENCLOSURE 2 ITEM NUM ER:
4.4.2.4 (1 )
-,'5 w
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X DISAGREE WITH FINDING:
PRELLM XARY THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............ X BASIS FOR ABOVE ASSESSMENT:
HVAC will be reviewed and comply with separation criteria and/or be pro-tected as a part of the Firt Hazard Analysis Program (see 4.4.2.1 (d).
fr.C RW QUSDREX REVIEW
.. m.sc; c 0;ur/iEr4T rn.
,. n.;)
70
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,m
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ENCLOSURE 2 ITEM NutSER:
4.4.2.4 (m) er.
DISCIPLINE:
HVAC AGREE WITH FINDING:
DISAGREE WITH FINDING:
X PRE
'M. NARY THIS ITEM I.S CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
(i) HVAC design criteria is given in the various SDDs. Generating a separate, comprehensive criteria document would be duplication of effort.
(ii) The SDDs describe the requirements for surveillance and periodic test-ing. System startup testing requirements are given in the Duct Installa-f tion spec.
Equipment shop testing requirements are given in the respective equipment spec.
i N".C FJV OU # CIX REVIEW
,,,, ;,_,,cI L ;; J.*Ii:T Y.
t sn.
l l
l l
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- ,3
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l 71 1
l
7,...
ENCLOSURE 2 ITEM NUPSER:
4.4.2.4(n)
.s DISCIPLINE:
HVAC AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTEhTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
i B&R is currently finalizing HVAC calculations based on updated heat load inputs. The other disciplines are requested to include margins used in arriving at heat loads they give to the HVAC discipline. The HVAC discipline will consider other discipline margins to detemine net margins in the HVAC f- -
system capacity. The final calculations will show the-final estimated net I
margin in each HVAC system. This task will be perfomed during the design freeze.
NGC RW QU AD?.IX REVIEW g : EnINCE DO;UMENT no.
Y e
9 e 72 n
,, -. _ +
g
- %.m. -
ENCLOSURE 2 ITEM NUS ER:
4.4.2.4(o)
DISCIPLINE:
HVAC AGREE WITH FINDING:
PRELIVINARY oIS REE WITN rINDING:
x THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
Pressure drop calculations were made for the longest duct run, which has the maximum pressure drop. We do not contemplate using volume dampers-in the longest duct run. The addition of volume dampers in other branch ducts will not impact the pressure drop calculation and fan selection.
9 tcC Rg QUADREX REVIEW I
,,jn;NCE DOCUMENT no.
Y a
L-n 73
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ENCLOSURE 2 1
ITEM NUSER:
4.4.2.4 (u) i DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X PRELlivi N ARY DISAGREE WITH FINDING:
THIS ITEM.IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
.NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
The HVAC system will be protected from pipe rupture during the Pipe Break
. Analysis Program (see 4.4.2.1 (d).
s,"C Rg QU ADRgx REVIEW
' " ',, ;giuc?. DOCUMENT no.
Y o
L
,
- 4 74 w
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1 ENCLOSURE 2 ITEM NUS ER:
4,4,2,4 (y)
DISCIPLINE:
HVAC AGREE WITH FINDING:
X I
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............'
X BASIS FOR ABOVE ASSESSMENT:
Calculations for the pressure distribution in the containment will be finali; zed by July 1981. At that time, the RCFC system will be reviewed for pressure relief and a resolution will be reached by August 30, 1981.
If required, any modification to the system will be made by October 30, 1981.
SCHEDULE:
6/15/81 7/ 31 /81 8/30/81 10/30/81 START f
g g
-f Pressure Review of j
Equipment Calculation P.CFC System i
Procurement t
i I
l Ductwork 10/30/81 Change (Dwg., etc.)
l F
C RIV OU C3 o.
J L-75
...__ m,,_
ENCLOSURE 2 ITEM NUPEER:
4.4.2.4 (w)
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X E.IVINARY DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............ X BASIS FOR ABOVE ASSESSMENT:
ns As per vendor input, the tornado danpers are designed to close in 0.25 seconds for a typical tornado with the specified pressure drop rate (2 psi per second).
The outside pressure will drop - 0.5 psi (-14"wg) by the time tornado dampers r
close shut. The consequent negative pressure in the ductwork upstream of
(
tornado damper will be substantially less than - 14"wg because of the high pressure (dynamic) loss across the closing damper, and negative pre:;sure induct should be less than design negative pressure. Brown & Root will review all tornado protected HVAC duct systems to confim that they will withstand the negative pressure that may result from a tornado.
SCHEDULE:
6/05/81 7/06/81 7/20/81 7/31/81 REPORT START 4
6 d
/\\
TO HVAC SYSTEM HVAC PHYSICAC RESOLVE AND HL&P REVIEW DESIGN REVIEW CONCLUDE R
i T.C RW QU
,,,,,i::;nCE DOOUMENT N,
no.-
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y 76
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ENCLOSURE 2 ITEM NUE ER:
4.4.2.5(aa)
DISCIPLINE:
HVAC AGREE WITH FINDING:
X DISAGREE WITH FINDING:
P E _IMI NA RY-THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
The Quadrex assessment of question H-31 was:
"The Brown & Root response to this qu'estion is satisfactory. B&R selection for location of alarm appears adequate; however, the documented basis for this selection does not exist."
BAR agrees that documented basis does not exist, and B&R will not generate such a document. The alam will receive another review during the design freeze to further assure the adequacy of the alam system.
Nr.0 RW OUADnEX REVIEW pslP.2640E Do;UMENT NO.
~
77
--,.-..,.,m.,.- -.,.,.,,., ---
.-_.m......
ENCLOSURE 2 ITEM NUPEER:
4.4.2.5(bb)
DISCIPLINE:
HVAC A05 AGREE WITH FINDING:
DISAGREE WITH FINDING:
X THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
NUS calculation (N079XA034ANS, STP Containment An'alysis, Rev.1, for PSAR Sec. 6.2.13) defining ambient conditions following a LOCA was found by the Nuclear Analysis discipline following the audit.
It is true B&R was unable to find the calculation at the time it was re-ouested by QUADREX during the audit.
- c. h
,e t* E
78 t, i-w y
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v-w
ENCLOSURE 2 1
ITEM NUE ER:
4.5.3.1 (a)
C.
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X DISAGREE WITH FINDING:
PRELIMll\\A1Y THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
This will be a part of Pipe Break Analysis Program (see 4.4.2.1 (d).
,, e %#
- w. /y b
79
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m ad N
- Q g g g,
ENCLOSURE 2 ITEM NutSER:
4.5.3.3(q) h.--
DISCIPLINE:
Mechanical AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE..
INSUFFICIENT DATA FOR ASSL iMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
A program to evaluate the effects of pipe breaks will consider equipment qualification. This program is defined by a logic attached to response to finding 4.4.2.1 (d).
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80
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ENCLOSURE 2 ITEM NUS ER:
4.5.3.4 (x)
DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPO RTAB L E..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
The adequacy of separation and protective enclosure in mitigating environ-mental effects of pipe rupture will be a part of the Pipe Break Analysis Program (see 4.4.2.1 (d).
NRC RIV QUADREX REVIEW REFERENCE DOUMENT NO.
PELLMLNARY I
I l
l 81 l
ENCLOSURE 2 ITEM NUPSER:
4.5.5.1 (g)
DISCIPLINE:
Mechanical A05 AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NOT REPORTABLE............
X BASIS FOR ABOVE ASSESSMENT:
This has been identified by a B&R EDD, determined nonreportable, and resolved by PCN 3 to 20099NS054 E.
NRC RW QUADREX REVIEW REFERENCE D UMEf1T f.
NO.
D 82
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ENCLOSURE 2 1
~
ITEM NUMBER:
4.5.5.3 (j)
DISCIPLINE:
AGREEWITi< FINDING:
b DISAGREE WITH FINDING: O REL M NARY THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.....
.O NRC Rn* QU'DREX REVIEW POTENTIALLY REPORTABLE
_ D REFERENcg DOCUMENT INSUFFICIENT DATA FOR ASSESSMENTQ y
NOT REPORTABLE-.._ _
.. p no, BASIS FOR ABOVE ASSESSMENT:
The two problem penetrations (M-46 & M-48) are the two small diameter (4")
high energy penetrations that were manufactured by welding a pipe to each of the penetration flue head.
{-
In Service Inspection is required in class 2 high energy lines where no Because these penetration assemblies were not ruptures are postulate.
specified to be designed considering rupture loads and beca in a high radiation area) BAR is pursuing a redesign of these assemblies.
We are presently obtaining a quotation from the vendor (EPG) to provide This integrally forged penetrations which will meet the ISI requirement.The evaluation a quotation is scheduled for June 1.1981.
10, 1981.
the new penetration assemblies should be accorrplished by August
,.,p 83
=ahame.% % -
ENCLOSURE 2
. -- ITEM NUteER:
4.5.5.3 (k) k,I DISCIPLINE:
Mechanical (HVAC)
AGREE WITH FINDING:
DISAGREE WITH FINDING:
X ERELIMINARY THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
NRC RIV QUf.D3EX REVIEW INSUFFICIENT DATA FOR ASSESSMENT...
REF RZA DXUMENT NOT REPORTABLE............
X
- pag, BASIS FOR ABOVE ASSESSMENT:
We disagree with the statement that valve and pump design seismic loads may be overly restrictive and may result in over support and/or uneconomical pipe support systems.
[
An industry survey (undocumented) made prior to defining the loads indicated the loads specified were consistent with industry standards. STP is located in a low seismic zone, and very few problems have been encountered to do design for the loads specified.
0$
84
~_
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ENCLOSURE 2 ITEM NUN ER:
4.5.5.4 (h)
DISCIPLINE:
Mechanical AGREE WITH FINDING:
X DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..............
POTENTIALLY REPORTABLE........
INSUFFICIENT DATA FOR ASSESSMENT...
NRC RIV QUADREX REVIEW NOT REPORTABLE............
X REFERENCE OCUMENT NO.
~
BASIS FOR ABOVE ASSESSMENT:
The stress calculation in the transition region from the process pipe to the flued head is a highly stressed portion and is critical to design adequacy for the nomal through' faulted conditions.but not rupture. Stress intensities
(-
for this region were calculated and can be found in the computer printout; however, EPG do not shed these intensities in their reports.
This concern has been documented in the review coments made on the reports.
EPG has been notified (correspondence ST-BR-EG-3081) and the reports referred to EPG for rework and resubmitted. EPG will include a table in their reports showing stress intensities in the subject region.
h.e 85 a6a
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ENCLOSURE 2 k
ITEM NUPSER: 4.5.5.4.
Item /.(QuestionM-33)
DISCIPLINE: Mechanical AGREE FINDING:
h g
DISAEREE WITH FINDING: O THIS ITEM IS CONSIDERED TD BE:
REPORTABLE _....
..Q NRC RTV QUADREX R POTENTIALLY REPORTABLE D
REFERENCE DOCUMEn7 INSUFFICIENT DATA FOR ASSESSMENTQ O'
NO.
^
NOT REPORTABLE
.. W
\\
BASIS FOR ABOYE ASSESSMENT:
The h' eating of the RCB wall by the Mechanical penetrations is currently.
being perfonned by EPG in their re-analysis of the mechanical penetrations.
C-Reports for penetrations M-14 and M-46 have been mceived and show nomal Nomal operation concrete temperatures of 179'F and 125'F respectively.
operation temperatures are not to exceed 200*F.
There are a total of 11 penetration groups that require themal analysis.
The worst case will be chosen and an analysis perfomed to detemine, he t
concrete temperature due to convective heat transfer between the process pipe and sleeve inside the penetration.
This analysis should be completed by September 1,1981.
f l
86 O'pu>e -
_ _w..
~
ENCLOSURE 2 ITEM NUPSER:
4.5.5.4 (o)
DISCIPLINE:
Mechanical muE vis ninia:
ta
,15.
E mN nunio: O
?RIL MI\\ ARY.
f THIS ITEM IS CONSIDERED TO SE:
REPORT ABLE..
D POTENTI ALLY REPORTABLE-. - _ D NRC RIV QUADREX REVIEW INSUFFICIENT DATA FOR ASSESSMENT REFCRIr4CE DOCUMENT NOT REPORTABLE-O gg, BASIS FOR ABOVE ASSESSMENT:
The vendor has submitted thc design report for the RWST (Ref. ST-BM.BR-132).
This report documents completion of review by the vendor. The report wi Is be reviewed by B&R. 5 e O e w 87 .m,.. ,,_._,,_,,_,_._..,_,_-_,~,m
l me. m..s. ~._ ENCLOSURE 2 e ITEM NUS ER: 4.5.5.4 (p)/4.6.4.4'(h)/4.6.4.4 (1)/4.6.4.3 (d) Note: Answers all four questions DISCIPLINE: Mechanical AGREE WITH FINDING: X DISAGREE WITH FINDING: PRELIMINARY THIS ITEM IS CONSIDERED TO BE: REPORTABLE.............. E N.7C RIr ggj0 REX REylgw POTENTIALLY REPORTABLE........ INSUFFICIENT DATA FOR ASSESSMENT... .a~ '"k ,,a P30utatur NOT REPORTABLE............ X No. -- BASIS FOR ABOVE ASSESSMENT: The detailed assessment of B&R response to Question M-48 indNates the concern is related to ensuring valve opening and closing times meet design objectives. A dynamic analysis and a water hansner analysis of the feedwater system will be made and corrective measures taken, if required. / W C4 4' gc 88 ---~-i, -. v-- .,-,- - - _.,., - - - - - _ -, - _ _ +,
.----------w a,
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' ~~~ ~... -......... _ _ ENCLOSURE 2 k ITEM NUPRER: 4.5.5.4 (q) DISCIPLINE,: Mechanical AGREE WITH FINoING: b c15anEE mH nNoin: D PRELlin..!h3Y n THIS ITEM 15 CONSIDERED TO BE: REPORTABLE. ..O NRC Civ QU6D'oev NEVIEW POTENTIALLY REPORTABLE D c.rme'cI D;;U,in:7 INSUFFICIENT DATA FOR ASSESSMENTQ g NC' 7 NOT REPORTABLE .. U _j BASIS FOR ABOYE ASSESSMENT: Techanical licensing requirements (NUREG'5, I.E. Bulletins, etc.) as received by B&R Licensing are transmitted to the appropriate discipline for review and where response is required this action item is logged and tracked to ensure the response is made. jY ', -),
- v.,
89
-. ~,... ENCLOSURE 2 ITEM NUMBER: 4.6.2.1 (a) DISCIPLINE: NUCLEAR ANALYSIS AGEE WITH FINDING: O' DISAGREE WITH FINDING: O g-:JNBfde THIS ITEM 15 CON 31!ERED 70 BE: REPORTABLE.-.. D POTENTIALLY EPORTABLE D N*:0 gry QU 903~^v RIVIEW INSUFFICIENT DATA FOR A35E55MENTD L.g,n".-- U DR ~ ' ' NOT REPORTABLE- .U SASIS FOR ABDVE ASSE5sMENT: I. Nuclear Analysis has functioned in accordance with STP procedures regarding the use of information 'by other disciplines. Once design input data, developed by Nuclear Analysis, has been transmitted. Project ( Procedures do not establish the need for Nuclear Analysis to verify the ( design of other disciplines with respect to input data. However, Nuclear Analysis interfaces with other disciplines on a timely basis. 2. The basis for temperatt.re outside of containment used by other disciplines for purchase of, equipment is not yet fully established. Howe ve r., the data that is provided in STP document, TRD 4E010E0004-A are design verified and have analytical basis. 3. The temperature data provided in TRD 4E010E0004-A for inside containment are essentially current, accurate and adequate for qualification of equipment. These data were developed on a timely basis. 4. Additional required analyses for temperature outside of containment are currently being perfonned or scheduled to be perfomed. A plan alone with a schedule for various analyses is attached. The plan also includes assessment of high energy lines outside the containment. 5. Regarding the usage of saturation temperature (TSAT) rather than actual temperature, the statements made in the QUADREX Audit meeting were not based on assumptions. In fact, the examples of the results of tne analyses performed by B & R were presented as supporting evidence. ~ _. (cont'd) 90
--.w..- ENCLOSURE 2 c. ITEM NUMBER
- 4.6.2.1 (a) (continued)
DISCIPLINE: NUCLEAR ANALYSIS AGEE WITH MNDING: O nis.EE v1Tx n=oin: O BELll6 NARY THIS ITEM 15 CON 51 DEED TD K: EPORTABLE.........O POTENTIALLY EPORTABLE .D pEC RIV QUADREX REVIEW INSUFFICIENT DATA FOR ASSESSMENT h FGJ::0F. DDOUMENT NOT REPORTABLE gg, y u BASIS FOR ABOVE ASSESSMENT: .6. To further clarify the paragraph above, for conditions inside the containment, TSAT for design basis LOCA is applicable for almost all the equipment located inside the containment. A main steam line break (MSLB) event gives much higher temperatures in superheated steam environment. However, as was explained in the QUADREX Audit meeting, TSAT for MSLB is lower than TSAT for LOCA by a wide margin. As such, B & Ts does not expect any problem with qualification of equipment inside the containment. It is reconnended that HL & P review this response in conjunction with NUREG-0588, Category I,1.2(s). This document defines more current NRC requirements than IEEE-323 which is cited by QUADREX in its finding. 7. Although the approach described in the paragrap'h above will apply, in general, for equipment outside the containment, B & R will provide its assessment on completion of the analyses currently being perfonned or scheduled to be perfonned. 8. Environmental qualification of equipment, particularly odtside of containment, is going through an evolution of development and standard-ization. A survey of information recently gathered indicated that the t approach taken by B & R is not much different than what has been done by other AE's and plant owners. A recent survey made ANS 56.9 Cormittee on Environmental Qualification Envelopes shows such a wide range of temperatures for PWR plants as to reflect industry wide lack of satisfactory completion of environmental t' qualification of equipment program. As such, contrary to OUADREX {., findings, STP should not be considered an exception for licensability or timeliness, with respect to equipment qualification. l (cont'd) 91 -,.---,,------_,,n
Sm. ENCLOSURE 2 ITEM NUPSER: 4.6.2.1 (a) (continued) DISCIPLINE: NUCLEAR ANALYSIS AGREE WITH FINDING: O DISAGREE WITH FINDING: O EU M THIS ITEM IS CONSIDERED TD E: EPORTAB1E - - - ~ L~ ~. [B r (3 fyl$NT D( E NRC RIV QUADREX REVIEW RE ER NCE DMENT gg NOT REPORTABLE-o BASIS FOR ABDYE ASSESSMENT: 9. B & R is fully aware that use of TSAT rather than actual temperatures may not be conservative for each and every equipment. Development of [ temperature response of each individual equipment will be a tedious and time consuming activity. Equally difficult will be the task of developing several environments and of identifying as to which individual equipment to be qualified for which environment. It is noted tha't usage of an enveloping temperature profile is,a consnon practice in the industry. However, this approach will certainly not alleviate both the concerns (over qualification and underqualification of equipment) repeatedly raised by QUADREX in its findings. QUADREX should understand that optimizing qualification (neither under-nor over-Qualification) of each individual equipment 'is almost an impossible task to perform.
- 10. Attachment provides a plan and schedule for this task.
e M. ' 92 --+--w - + -. * ,-,,e-.-, -m- - -
~w cw w... ENCLOSURE 2 g ITEM MUMBEb 4.6.2.1 (b) DISCIPLINE: NUCLEAR ANALYSIS AEEE WITH FINDINE: O' dis =EE m r1NDiMa: ES PREUWN N THIS ITEM 15 CONSIDEED TD BE: REPORTABLE.. D POTENTIALLY REPORTABLE Z1 NRC RW QUADREX INSUFFICIENT DATA FOR ASSESSMENT REFERENC DW NOT EPORTABLE gg _ SA515FORARDVEASSESSNENT- ~ '1. Environmental Analysis: covered in Response (a) 2. QUADREX finding of errors in two calculations cited in its finding are wrone, as explained below: 3. B & R Calculation correctly uses a set of enthaply values around h=1180 Btullb. The value of h=1306 Btu /lb. is used only in sensitivity analysis provided in an attachment to the calculation for infomation only. QUADREX acted negligently in its assessment. For further clarificatio'n; see response (j) and attachments there of. 4 Only one " error" was assessed by QUADREX in 'an NUS analysis for inside containment (see N-1) B & R disagrees that this finding was indeed an error and also that it would seriously impact plant licensability for the following reasons: A technically correct but conservative analysis was performed by NUS for the mass and energy release due to a main steam line break.. The analysis predicted highly superheated steam conditions in the containment. At the time of the audit it was explicitly ncted that the analysis had been super-ceded by a Westinghouse calculation which also predicted a superheated steam environment due to a main steam line break. . QUADREX probably has over-reacted in its findings. 5. Contrary of QUADREX findinos, the most recent data on mass-energy release in IVC was available at the time of audit. It was also f' stated at that time that environmental analysis in IVC was in progress gj,, (see N-3 B & R response). (cont'd) 93 .~..
__ ~... ENCLOSURE 8 C ~ ITEM NUMBEh 4.6.2.1 (c) DISCIPLINE: NUCLEAR ANALYSIS AGREE WITH FINDING: C DISAGEE WITH FINDING: b NRC RIV QUADREX REVIEW THIS ITEM IS CDNSIDERED 70 SE: REFERENCE DOCUMENT NO. Y EPORTABLE, $EN!EtIT nSA A $ETs555Riitg Not=PoumE---- __.. ?REL M iiARY BASIS FOR A80VE ASSESSMENT: 1. This finding is essenti' ally a repetition of finding (b), and is based e on erroneous assessments by QUADREX. With the possible exception of ( the environmental qualification data outside of containment, addressed under response (a) B & R disagrees with the QUADREX finding. 2. Other analyses have been scoped and been perfomed on a reasonable project schedule. Calculations are being revised to alleviate deficiencies. A schedule of Nuclear Analysis activity, in suppart of STP design and construction, generated prior to the QUADREX Audit is submitted as evidence in support of this claim. HL & P was previoed with an updated version of this schedule shortly after the QUADREX review. 3. No further action required by B & R on this ' finding. 94 -._.----------...---n
.w.w e m ENCLOSURE 2 BravnTRooLinc. INTEROFFICE MEMORANDUM TO: M. J. Meyer DATE: ' January 22, 1981 FROM: R. D. Jain D .5UBJECT: Nuclear Analysis Disconnects PRE!.Nu' 'N' A / t & Recovery P1-Attachment A provides a list of tasks which have a significant effect on the construction or licensing schedules. The attachment also shows dates by which analyses are needed by various disciplines. Also in-dicated are completion dates based on the current aanpower in Nuclear Analysis Discipline and available NUS Support. shows manpower assigned to various priority tasks. The scheduled completion dates, indicated by dotted line are based on the present manpower and will require overtime (10 hrs /wk per man). This schedule does not include unplanned tasks and other contingencies. ~ Analyses to be perfonned in msponse to Audit Deficiency Reports (ADRS) and other tasks, which are not disconnects at the present time, are not shown. These tasks need to be started prior to the cogletion of disconnect items to prevent an impact on the schedule. To that extent, the manpower planning and schedule shown in Attachments A and B is op-timistic. 7 The difference between the need dates and the scheduled completion dates in Attachment A establishes the extent of disconnect for each task (see Attachment A). Attachment C shows a recovery schedule based on innediate assignment of two (2) more, experienced engineers. hn cogared to the schedule in, the recovery schedule shows a major and coglete recovery,' except for 3 tasks (task f5, 8 and 9). Task #5 is based on the NUS sche-dule and remains unchanged. The delays on tasks #8 and 9 are mduced to about 6 weeks and 4 weeks, mspectively, with respect to the need dates. Complete recovery by assigning one more engineer to the discipline does i not appear possible because of supervision considerations. Our schedule indicates a need for a third engineer around mid 1981 to start on tasks that are not presently on the critical path but need to be cogleted in late 1981. This assignment will also streamline the I Our manpower planning indicates independent design verification process. design verification could be a major constraint on task completion sche-3 dules. l Realizing that unforeseen circumstances could adversely affect the re-covery plan shown in Attachment C, a backup recovery plan is being developed. This plan includes utilizing services of outside consultants. th NRC RIV QUADREX REVIEW hc24h W REFERENCE OCUMENT R. D. Jain N O. RDJ/iyg cc: K. A. ~ o o R. B. Razmines RDJ-81-690 04 ~~
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-a-% ENCLOSURE 2 a. -.p ITEM NUPSER: 4.6.2.1 (d) DISCIPLINE: NUCLEAR ANALYSIS AEREE WITH M NDING: h' h DISAGEE WITH MNDING: b THIS ITEM 15 CONSIDEED TD BE: REPORTABLE. -. - - _- ---B POTENTIALLY REPORTABLE NOT REPORTABLE- - ---- - g INSUFFICIENT DATA FOR A55E55 MENT BASISTORABOYEASSE55fkNT: '1. This QUADREX finding is, essentially the same as findings (a) and (c). 2. Attachment to Response (c) provides adequate in'dentification of Nuclear h-- Analysis calculations needed to support other discipline. 3. Examples of analyses presented in the QUADREX Audit meeting were vivid evidence of required support to other disciplines. 4. It should be easily understandable that all themal-hydralic ana,1yses,. essential cooling pond analysis, and containment analyses are performed for the main objective of supporting other disciplines. 5. No further action required by B & R. i NRC F.IV QUAD *).EX REVIEW g;;;a;; OE' 0000 MENT. g rw. - a L 100
..~.n._.. o ENCLOSURE 2 l ITEM NUPSER: 4.6.2.1 (e) DISCIPLINE: NUCLEAR ANALYSIS AEREE WITH FINDING: O DI5AGEE WITH FINDING: O THIS ITEM 15 CONSIDERED TD BE: REPORTABLE. _-B POTENTIALLY REPORTABLE INSUFFICIENT DATA FOR ASSESSMENT NOT REPORTABLE- -- ---- -- BASISFORABOYEA55E55fdNT: '1. The NUS annulus pressurization analysis was perfonned with the RELAP3 code which was and is acceptable to the NRC, see the attached telecon note. A current reactor annulus redesign effort which does not affect the ex-f. isting concrete design will utilize the COMPARE Code in confinnatory f( reanalysis of the reactor cavity. However, the previous annulus pres- ~ surization analysis performed by NUS with RELAP3 was conservative and used a computer code and methods acceptable to the NRC. It was sub-mitted in a timely manner. 2. Thus while any reanalysis deserves licensing attention, the NUS annulus pressurization reanalysis has no potential for seriously impacting on plant licensability and this item is not considered reportable. 3. A recent inquiry by B & R seems to indicate that not more than a few plant owners have submitted analyses to NRC based on COMPARE until now. For example, Bechtel's topical report submitted to NRC does not use COMPARE. 4 QUADREX should be aware of the fact that indiscriminate change of computer codes could result in discontinuity and discrepancies in the design. A systematic approach is taken by B & R and NUS to change from RELAP-3 to COMPARE for subcompartment analysis. 5. No further action required by B & R on thu '"dia; NRC RIV OU4D3EX REVIEW hdI2 L ICE
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wwu..m. ENCLOSURE 2 1 TELECON NOTE COPY L Date: 3-6-81 Time: 9:45 am 7 {h From: Jack Kudrick Of: USNRC Steven Mirsky (NUS) Discussion: Jack stated that the NRC uses contempt Lt 028 for its audit containment calculations. Most containment analysis licensing submittals use some modified version of Contempt. Contempt 4, which has been recalled due to significant errors being discovered, will become the NRC Audit calculation code in about a year. BEACON is an advanced best estimate subcompartment code still in the early stages of development. The NRC uses COMPARE for subcompartment analyses although subcompartment analysis licensing submittals have used RELAP3, RELA *4 and COMPARE. Use of 'RELAP3 may be questioned by the NRC for low pressure subsonic flow subcompartment analysis because of its deficiencies in the area of compressibility effects and modelling the presence of air. SUBSEQUENT NUS EVALUATION: NUS RELAP3 analyses applied specific compressibility correction factors, established iteratively, to each junction in order to address compressib-ility effects concerns. In addition the NRC recomended initial condition steam model was used to model the presence of air. To date NRC has not challenged any NUS subcompartment analyses on the basis of RELAP3 utiliza-tion. } N Ul9llg EVIEW t No. _ L g g.- 102
-^ .m _ ENCLOSURE 2 ITEM NUMBER: 4.6.2.1 (f) NUCLEAR ANALYSIS AtJtEE WITH FINDING: C DISAGEE WITH FINDING: { THIS ITEM IS CONSIDEED TO RE: REPORTABLE - - - - -. - - .D POTENTIALLY REPORTABLE D INSUFFICIENT DATA FOR ASSESSMENT NOT REPORTABLE-BASIS FOR ABDVE ASSESSMENT
- During.the audit rlUADREX was repeatedly told that the specific treatment of door position in subcompartment analysis had to be considered on a case by case basis.
It had not been predetemined in a cook-book fashion for all conceivable design configurations, operating conditions, ( functional requiremnts and safety considerations. Considering the availability of engineering talent, the generation of such a manual did not appear Dractical. An example was then provided in response to question N-8 by citinQ the IVC. However, QUADREX did not appear sat-isfied with this specific response and began posing extra hypothetic{tl subcompartment conditions and requirements expecting off-the-cuff changes of model specifications which ordinarily should be established only after careful consideration of all potential vent path characteris-tics and their effect on the desion analysis objective. B & R fails to understand why, after the probing N-8 discussions, OUADREX is still under the impression that an organization, that has successfully submitted many PSAR and FSAR subcompartment analyses to the NRC, is not aware of the proper methodology for handling potential flow paths during enviro-mental analysis. I NRC Riv fiEFERil C h-W No. _ k u J 103 Lm.
..m..,,,,. ENCLOSURE ? M M M ER: 4.6.2.1 (g) DECIPLINE-NUCLEAR ANALYSIS AsREE WITH FINDINE: O g DISAGEE WITH FINDING: O pgEb,,g W THIS ITEM IS CONSIDERED TD SE: REPORTABLE. -... - - - - -Q POTENTIALLY REPORTABLE . - D INSUFFICIENT DATA FOR ASSESSMENT NOT EPORTABLE-BASIS FOR ABDVE ASSESSMENT: The specific details of modelling sources of make-up, emergency or auxiliary water supply depend on the p' articular break under consideration. In the future, as in the past, the mass and energy release analyses for STP are expected to be performed by Westinghouse or NUS. The detailed modelling / _ i considerations for make-up supplies of water for long tem environmental analysis will thus first have to be provided as planned by Westinghouse or NUS. These will then be reviewed by Nuclear Analysis. The Westinghouse model is not under consideration here. As noted in.N-11 the Westinghouse long tem analysis will be reviewed by B & R when it is available. The NUS model for make-up supplies was found to be acceptable by QUADREX for inside containment analysis. The outside of containment long tem mass and energy release calculations are in the process of being developed. The following additional scoping considerations are provided at this time to demonstrate that Nuclear Analysis is reasonably aware of the need to model make-up supplies of water for long tem environmental analysis. Long tem mass and energy release in the IVC due to an 8" feedwater bypass line break, and a 4" auxilliary feedwater pump turbine supply line break is presently being analyzed. In both of these cases, make-up supplits of water are considered in the development of the model. For the 8" feedwater bypass line break, the auxilliary feedwater make-up supply is being considered. After isolation, flow from the 500,000 gal-lon condensate storage tank via the auxilliary feedwater system is considered. There is a possibility that intmduction of this cold water will orovide a mitigating effect o6 the transient. For this reason, the possibility of conservatively neglecting auxilliary feedwater flow will be considered. NRC RIV QU.8DREX REVIEW REFCRENCE DOCUMENT NO. (cont'd) 104
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ENCLOSURE 2 ITEM NUMBER: k 4.6.2.1 (g) (continued) DISCIPLINE: NUCLEAR ANALYSIS AGREE WITH FINDING: O DISAGREE WITH FINDING: O ERE_KNARY THIS ITEM IS CONSIDERED TO SE: REPORTABLE. _... ..O POTENTI ALLY REPORTABLE . _ _D INSUFFICIENT DATA FOR ASSES $MENTp NOT REPORTABLE .... g SASIS FOR ABOYE ASSESSMENT: For the case of the 4" auxilliary feedwater pump turbine supply line break, make-up supply from the condensate storace tank is also considered, in this, analysis it is assumed that the auxilliary feedwater is initiated at the time.of isolation and continues for a period of 1/2 hour at which time operator action is assumed to isolate this system.
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No further action required by B & R on this finding. N.1C Civ QU c ?EX REVIEW RLGENCE go;g,*.iENT No. -- N ,5 A* f 105 r-r, .,--v-..,_,---_7-
- m m. ENCLOSURE 2 ITEM NUPSER: 4.6.2.1 (h) u DISCIPLINE: NUCLEAR ANALYSIS AGEE WITH FINDING: C DISAset v1TN nNnINs: G P_RElMAARY THIS ITEM 15 CONSIDERED TD BE: REPORTABLE _.. ..O POTENTI ALLY REPORTABLE D INSUFFICIENT DATA FOR ASSESSMENTD MOT REPORTABLE 5 BASIS FOR ABOVE ASSESSMENT: 1. Nuclear Analysis is fully aware of the W Engineering loaic of MSIV'S and draws specific information from oth~r disciplires which have deta,iled knowledge of logic, logic diagrams and characteristics of MSIV'S. OUADREX was told in the meeting that it was a simple matter of looking 7 i into project documents includino FSAR for infomation on W logic. Examples of what plant conditions could trip the MSIV'S dre also mentioned in the presentation. In spite of this explanation. OUADREX insisted during the Audit meeting and in its audit findine on the need for N.A. to make an oril dis-sertation of the whole set of trip signals and valve closure charac-teristics. B & R fails to understand the.usefulness of this engineer-ing exercise. 2. No further action required by B & R on this finding. However, B & R takes this findina under advice. E NRC Riv QUADRcx ngzyggy 1 REFERENCE OCCUMENT NO. _ k l_ 106 ~...... r ,,--,r-
ENCLOSURE 2 N. v. ITEM EHBER:- 4.6.2.1 (i) DISCIPLINE: NUCLEAR ANALYSIS AGEE WITH FINDING: C h d hglj g gj DISAGEE WITH FINDING: b THIS ITEM 15 CON 51 DEED TO BE: D REPORT ABLE. .. - - _ -_D POTENTIALLY REPORTABLE INSUFFICIENTDATAFORASSESSMENTp NOT REPORTABLE- -- ----..U BASIS FOR ABDVI ASSESSMENT
- B & R disagrees with the OUADREX conclusion that Nuclear Analysis is not sufficiently knowledgeable in the area of valve performance and qualifications. Nuclear Analysis is sufficiently knowledgeable to model and review system break analyses as indicated in the B & R response to Question N-12. The very detailee knowledge expected by OUADREX is appropriately assigned to the Mechanical Group.
In its own assessment in N.12 OUADREX has demonstrated that its detailed considerations of valve perfonnace and qualifications are an ex-ercise in futility, because not one consideration sugaested by QUADREX has practical application in modelina and analysis of system breaks. NRC(ny h t t",75; E R E Vjg y f40. L N [ 107
ENCLOSURE 2 ITEM NUMBER: 4.6.2.1 (j) 7 s. DISCIPLINE: NUCLEAR ANALYSIS AGREE WITH FIE!NG: C PREtfggggy D25.=E ma nEin: E THIS ITEM 15 CONSIDERED TD BE: REPORTABLE. -.. - - _- POTENTIALLY EPORTABLE INSUFFICIENT DATA FOR A55E55 MENT NOT REPORTARLE- -- - --- -. BASIS FOR A30VI ASSESSMENT: "1. The analysis for a double-ended break in lieu of a crack has*been accepted by NRC as shown in Attachment 1. The double-ended break was analyzed to meet the project schedule, because the mass and energy release data for only the double-ended break was available at the ' ( time and the analysis was conservative. The use of the RELAP3 code was also approved by NRC as indicated in. 2. A review of the input data for the analysis trade by B & R indicated that QUADREX misinterpreted the input data when it identified a high enthalpy as an obvious input error. A Copy of the short tem M & E infomation used in the compartment analysis is attached in. 3. In an effort to update the short tem IVC analysis consistent with long tem themal response requirements, the crack break will be reevaluated using the COMPARE code and appropriate short tem mass and energy release data generated in late 1980. This ana1ysis is covered in Response (a). 4. The attachment provided here were discussed with QUADREX in the Audit meeting. If OUADREX has disagreement with NRC approval of the subject . analysis, QUADREX should have expressed the concern in its finding. 5. No further action required by B & R on this finding. (I ', Attachments: 2 NRC Riv QUAD 3EX REVIEW Q: ' ' ' F.':FCR:t4CE COcur,4tt47 to. _ Y 108 ,--., -~., --,. -- -.--- -., - --,----,-m- ..av..
ENCLOSURE 2 k W4 + +'GT)
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RECEIVED BROWN & ROOT INC. 7, nucuan asouutosy commission jg3 g 1977 f .g =4a m.o.c.siens LICENSING DEPT. l
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JUN 8 EU Docket Nos. STN 50-498 and STN 50-499 I Houston Lighting and Power Company ?'R'ELIVI \\'ARY . m M: Mr. . W. Oprea, ar. Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlanen: ji I
SUBJECT:
SAFETY EVALUATION OF REPORT ' DYNAMIC EFFECTS OF POSTULATED PIPE FAILURES QUTSIDE CONTA!!etENT - SOUTH TEXA5 PROJECT. UNITS e .Q,.. I 1 Ato 2" i We have reviewed the report " Dynamic Effects of Postulated Pipe' Failures g Outside Containment - South Texas Project Units 1 and 2 and'your responses to our request for additional information dated March 16,1977, and have determined that the redesign of the main steam and feedwater valve house r I to withstand the environmental effects of a pipe break in a main steam or feedwater line is acceptable. Therefore, we have concluded that the SouthTexashainstpostulatedpipebreaksoutsidecontainmentforthe protection sa roject Units 1 and 2 is acceptable. The bases for our conclusion is presented in our " Safety Evaluation h l of the Dynamic Effects of Postulated Pipe Failure Detside Contairunent - p South Texas Project Units 1 and 2,* which is attached for your information. 7 M Sincerely. *' Nsp ggy Mitnt, f0REXREvigyy ,f yn' ~ [ D3:UMiny an v.
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W, Light Water Reactors an.. Division of Project Management (L
Enclosure:
As Stated g. cc: see next page j r. Jun o 91.977 p. f .gst 1 l ,W b Y' . jog M;"Ne* err.W.%CCEG~ MAW.EE.J.s.M<?3rcerh%d--
ENCLOSURE.2.
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Sqpston Lignting and Power Compa.y, 6..
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l cc M. T. Luke e Mr. Troy C. Wetc Project Manager, STP Assistant Attorney General Houston Lignting and Power Company Environmental Protection Div. P. O. Box 1700 P. O. Box 1254d Nouston, Texas 77001 Capitol Station Austin,~ Texas 78711 Mr. W. G. Siegelin Central Power and Light Ccapany R. Gordon Gooch, Esq. P. O. Box 2121 Baker & Roots j'. Corpus Christi, Texas 78403 1701 Pennsylvania Avenue, NW i Washington, D. C. 20006 ERlF". Mr. R. L. Hancock t *4 City of Austin Director, Governor's Budget N,., Electric Utility Department and Planning Office P. O. Box 1048 Executive Office Building Austin, Texas 78767 411 W.13th Street Austin, Texas 7d701 Mr. J. 8. Poston Assistant General Manager for Operations h-City Puolic Service Board y P. O. Box 1771 m San Antonio, Texas 78296 CW Jack R. Newan, Esq. g. Iowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N. W. Wasnington, D. C. 20036 PREL*MiJARY L Melbert Senwarz, Jr., Esq. .aer & ms c One Shell Plaza Houston, Texas 77002 Mr. G. Honmann p Westinghouse Electric Corporation [* P. O. Box 355 Pittsourgh, Pennsylvania 15230 C.::. Mr. J. A. Signorelli M ggC Rh, QU3DREX ggyggW NUS Corporation N-tCS-4 Researen Place RUCCect r-.. *M h,. p* - --- J_' b.,- Aockville, Maryland 20850 u Mr. J. T. Mooney h.- j Brown & Roots, Inc. %f P. O. Box 3 L Bouston, Texas 77001 L .e. ~ l 110 I N M D N 5 F Y I N E 4 W Y. M.M T M NdI$M W.
ENCLOSURE 2 hke)A g2) 3 4' .( ' V. SAFETY EVALUATIOt4 0F THE DYNA.MIC EFFECTS OF POSTULATED P!PE (a FAILURES OUTSIDE CONTAINMENT - SOUTH TEXAS PR0h ~ UNITS 1 AND 2 l 5 In response to our concern of routing the steam lines near safety sysse.s.' b. g{o. the applicant submitted the report ' Dynamic Effects of Postulated Pipe Failures outside Containment - South Texas Project Units 1 and 2" for our -I. review. l }
- Our review covered the protective features provided for individual systems y
tr - and a review of preliminary piping layout drawings. The applicant's original r.te. C. , ' design of the main steam and feedwater piping systems proposed a break ( exclusion area for the piping in the main steam and feedwater valve rooms. [ This was based on meeting the low stress. "superpipe" requirements of Branch Technical Position MEB 3-1. However, the report snowed that all four auxiliary feedwater pumps for the South Texas Project will be located W* P below these valve rooms. For safety, in addition to the low stress piping, up_- we. required the applicant to design the valve rooms to withstand the environ-mental effects of a main steam or feedwater line brah equi..be. t: & l s:. NRC RIV QU/DREX REVIEW h flow area of a single ended pipe rupture. nrmg;,CI 0%uMcur fly V ll~ No. 4 As a result, the applicant proposed to redesign his%'n et: - W fandwater p*. valve rooms with a vent area capable of venting the release of larger than L one equivalent single ended pipe break and provided a subcompartment pressure y , ana,1ysis to show that the rooms would withstand the environment,a1 effects of I a break in this area. m". " F I 111 q { rfI n -IsL l ~2 L-/, = a u r-M TfDW t r
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. ~ ~. ENCLOSURE 2 ~ . r.. n r,- t f *. - i g We have reviewed the results of the applicant's subcompartment pressure analysis and have also performed our own independent analysis of their 0 new valve room design and find that the proposed design is now in accordance with our tranch Technical Position APC58 3-1 and therefore acceptable. g Cu O t F- .PE_LiviAM Y E i s f. h.... W i-m. NRC R!v qu so'n$ REVIEW ~w ~' p pg".... C.'u; qs-g, -' ~ e ? No. __ U Q !'* C /. 3 g .2 A,. sn 2 .~ I >. 6'}.,2 w 112 r 'g. r 1%WP'9C*/M&~}.WAW#WM.-MSc*: 'ShsMY4M%':.w<wMREMWA* 7.4 ? _. -_ --.}}