ML20137X569

First Interim Deficiency Rept Re Classification of Leak Detection Sys in Safety Injection Sys (Sis)/Containment Spray Sys Pump Cubicles.Initially Reported on 820701.Next Rept Will Be Submitted by 820820.Related Info Encl

ML20137X569
Person / Time
Site:	South Texas, 05000000
Issue date:	07/29/1982
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20137X502	List: ML20137X497 ML20137X503 ML20137X511 ML20137X516 ML20137X521 ML20137X526 ML20137X532 ML20137X540 ML20137X545 ML20137X552 ML20137X563 ML20137X569 ML20137X576 ML20137X584 ML20137X589
References
FOIA-85-519 ST-HL-AE-859, NUDOCS 8603100212
Download: ML20137X569 (42)

Text

r .

--e_.....

N608529 The Light Company swiionu uns su-r m u na n-iion. rm.MMI (713)228 9211 -

July 29, 1982 ST-HL- AE-859 File Number: G12.123 SFN: V-0530 Mr. John T. Collins Regional Administrator, Region IV Nuclear Regulatory Comission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76012

Dear Mr. Collins:

South Texas Pmject Units 1 & 2 Docket Nos. STN 50-498 STN 50-499 First Interim Report Concerning the Classification of the Leak Detection System in the SIS / CSS Pump Cubicles i On July 1,1982, pursuant to 10CFR50.55(e). Houston Lighting & Power Company (HL&P) notified your office of an item concerning the classification of the leak detection system in the Safety Injection System (SIS)/ Containment Spray System (CSS) pug cubicles. This item was discovered during a review of the Radioactive Vent & Drain System. While the FSAR stated that cubicle instrumentation provided safety systems that alert the operator to problems, the design documents stated that both the pump cubicle radiation monitors and sump level switches am non-1E Instrument Class IC-2. Classifying instrirnentation as IC-2 precludes taking credit for performance following a LOCA, thus leakage resulting from an assumed passive failure in the SIS / CSS pump cubicle during ECCS recirculation would not be detected. This leakage could potentially msult in flooding of the SIS / CSS pump cubicles and render the SIS / CSS inoperable.

We have concluded that this item is potentially reportable under the requirements of 10CFR50.55(e), and that the safety impact is indeterminate at this time. The safety evaluation is still continuing and a report on this evaluation will be provided by August 20,1982.

_ Very t 1 yours, 8

RECEIVED JUL 2 91982 y .

h sPWR Exec tive President g

SSR/kr 1>

"f B 8D

.tc 0603100212 060106 PDR FOIA OARDE00-519 POR

w ,

a.

Houpon Lighting A: Power Company G. W. Oprea, Jr. July 29, 1982 cc:

J. H. Goldberg ST-ML- AE-859 J. G. Dewease File huder: G12.123 J. D. Parsons SFN: Y-0530 D. G. Barker Page 2

< ' i ,0. G. Robertson .

R, A. Frazar

, J. W. Williams J. W. Briskin J. E.' Geiger R. L. U1 rey S. M. Dew J. T. Collins D. E. Sells (I, W. M. Hill, Jr.  :

M. D. Schwarz (Baker & Botts)

R. Gordon Gooch ((Baker & Botts) i,Lowenstein, Newman, Reis, & Axelrad)

J. R. Newman STP RMS Director, Office of Inspection & Enforcement Nuclear Regt.latoiy Commission Washington, D. C. 20555 G. W. Muench/R. L. Range Charles Bechhoefer Esquirt Central Power & Light Company Chaiman, Atomic Safety & Licensing Board i

P. O. Box 2121 U. S. Nuclear Regulatory Comission

• Corpus Christi, Texas 78403 Washington, D. C. 20555 H. L. Peterson/G. Pokomy Dr. James C. Lee, III city of Austin i 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 Austin, Texas 78767 J. B. Poston/A. vonRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livemore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808, L-46 Livemore, California 94550

{

Brian E. Berwick, Esquire William 5. Jordan', !!!

l Assistant Attorney General Harmon & Weiss for the State of Texas 1725 I Street, N. W.

t P. O. Box 12548 Suite 506 l Capitol Station Washington, D. C. 20006 Austin, Texas 78711 Lenny Sinkin Citizens for Equitable Utilities. Inc.

' Citizens Concerned About Nuclear Power c/o Ms. Pegry Buchom

! 5106 Casa Oro Route 1. Box 1684 San Antonio, Texas 78233 ' Brazoria, Texas 77422 l ,.

' Jay Gutierrez, Esquire l

Hearing Attorney Office of the Executive Legal Director l U. S. Nuclear Regulatory Comission

' Washington, D. C. 20555 Revision Date 04-19 82 i .

I

JUN 2 1982 HEHORANDUM FOR: John Collins, Regional Administrator, IV FROM: James J. Cumings, Director 4 42 ,

Office of Inspector and Auditor J. 4

SUBJECT:

REGION IV INVESTIGATION REPORT RE QUADREX Reference is made to '.egion IV's investigative report (50-498/82-02; S0-499/82-02) dated April 29, 198.2 concerning the Quadrex Report.

Upon reviewing the Region IV 0~uadrex investigative report, it is sqy understanding that the NRC was apprised in April 1981 that Houston Light and Power Company (HLP) was cohducting an engineering assessment of Brown and Root Company's desigh at the South Texas Project. The company conducting this assessment was Quadrex Corporation. The NRC was further advised that the Quadrex Report would be completed in May 1981.

!!r. Donald E. Sells, the NRC P'roject fianager, was aware that the OJadrc>

Report had been completed and wa, further apprised that it contained iter 1s reportable to the NRC. Mr. J. Goldberg. HLP Vice President for Nuclear Engineering and Construction, also made inquiry to Mr. Sells as to the best method of presenting the results of the Quadrex Report to the NRC. He also offered Mr. Sells an opportunity to review the report once it had been receiv,ed by HLP.

Information contained in your investigative report clearly indicates a reasonable effort by HLP to make the existence of the report known to the NRC. Accordingly. I agree with your finding that the allegation that HLP managerrent had deliberately withheld the Quadrex Report frcza the NRC was unsubstantiated. ; .

l With regard to the inconsistencies contained in the interviews of l

fiessrs. Sells and Goldberg. I do not believe they are of t,1cnificant l innortance to the principal is' sue that was investigated to v. arrant I further OIA investigation, I, therefore, do not intend to take any j further accion in regard to the Quadrex investigation and you r.ay proceed

< uitn notification and dissemination of the Region IV investigative recort as you ceem appropriate.

~

cc: J. Fitzgerald. 01 ,

CO:lTACT: Albert E. Puglia, OIT.

• 492-4467

/,L W

A %.

c= a C>^ d R 7 / h p *= YU%/ ar- -

/

W 4

3<f In Reply Refer To:

Docket: 50-498/82-02 50-499/82-02 Houston Lighting and Power -

ATTN: G. W. Oprea , Jr. ,

Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Messrs. D. D. Driskill and J. E. Gagliardo of our staff during the period February 5, 8-12, 23 March 11 and 19, 1982 of activities authorized by NRC Construction Permit CPPR 128 and 129 for the South Texas Project, Units 1 and 2.

Areas examined during the investigation and our findings are discussed in the enclosed report. Within these areas, the investigation consisted of selective examination of records and interviews with personnel.

During the investigation, it was determined that two potential deficiencies had not been reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of their identification.

The failure to meet the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting time requirements of 10 CFR Part 50.55(e) is a violation of NRC requirements, and will be the subject of a Notice of Violation which will be sent to you under separate cover.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Docunent Room. We understand that you will conduct an expecited revies of this investigation and will notify us by telephone when we will be able to release this report to the NRC Public '

Document Room and the ASLB.

Should you have any questions concerning this investigation, we will be pleased to discuss them with you.

\

Sincerely, ,

(p% #AW ((

p G. L. Madsen, Chief f) g Reactor Project Branch 1 y.

Enclosure:

Appendix - NRC Investigation Report 50-498/82-02; 50-499/82-02 IES  % RP8 % DRRP&,5 , RA-ib g

EHJohnson/bb LMadsen JGagli do p1TCo' ii ns

_ _ , 6/4/82 6/ 3./82 6/3 /3 4 6/3 j Y2 .

y , s v a A v ag \f '

$_,.myn

l 4

The Light NE f Hnupon Lighting A Power P.O. Box 1700 Houuun Texas 77001 1713)226 021I June 9,1982 S T-H L-AE-839 v, [.dp FN C2.04/C15.01 (\

,lF

%?

Mr. John T. Collins Regional Administrator. Region IV Nuclear Regulatory Commission 611 Ryan Phrza Drive, Suite 1000 Arlington, Texas 76012

Dear Mr. Collins:

South Texas Project Dockets Nos. 50-498, 50-499 This is in response to your letter 50-498/82-02, 50-499/82-02 dated June 3,1982, relative to your investigation and resulting report pertaining to an allegation relative to the Quadrex Report.

Houston Lighting & Power Company has carefully reviewed the report and while we have no objection to NRC releasing the report to the Public Document Room and the Atomic Safety & Licensing Board, we have noted several typo-graphical errors which you may wish to correct prior to such release. These corrections will assure that the report accurately reflects the certified state-ments of the HL&P persons interviewed.

Accordingly, we request that copies of this letter with our comments-accompany distribution of the report by your office.

The following changes to the report are recommended in order to more acetrately reflect the certified statements of persons interviewed during the course of the investigation :

y 1 Page 4 - 7th line from the bottom, change the word "his" to " H L& P's ".

-- 16th and 18th lines from the bottom, change the word " timely" to " quick".

2. Page 5 -- 17th line from the bottom, the word "no" should be "NO" and in quotation marks.

-- 20th line from the bottom, change the word " view" to " review" .

lo5 7th line from the bottom of Mr. Frazar's interview, 2 3. Page 8 -

y change the word "present" to "available". $d

-- 2nd line from top of Mr. Suenpter's Interview, the word about" should be deleted.

- 2nd line from the bottom in Mr. Sumpter's interview, An

~

the word " discuss" should be changed to " review".

ogi n 4/A 7h 9 7 ffL 2 -

sn 7a i7

qu.

.pr.wy, & fue Crrrpa3 Mr. John T. Collins June 9,1982 Page 2 ST-H L- AE- 839 FN C2.04/G15.01 N Page S 2-

4. 1st line in the top of the page, the wdrd "nonengineering" should be changed to "known engineering".

N --

8th line from the top of the page, the word " description" should be " descriptions".

20th line from the top, the word " discussed" should be N

deleted.

30th line from the top, insert the word " lead" between MLsP and engineers.

35th line from the top, change the words "other repre-sentatives" to the name of " Larry Wray".

5. s Page 10 -- Line 28, insert word "not" between was and maintained.

6. s Page 11 -- 7th line from the bottom, the word " interest" should read " interests"; insert the word "not" between would and be; and delete "besta. This series of words will now read " interests would not be served".

7. Page 13 -- 2nd line from top, Dr. Key has not been identified as being a participant in the Quadrex Report, but we feel the words "Dr. Key" should be replaced with the word "he" .

Should you have any questions concerning these changes, please contact me or Mr. J. H. Goldberg.

Very uly you s,

(

k eo e .t J

/ Ex Ive Vhce sident GWO /sra l

hLs-

( %1 f . .

.. *I" 1~.*i.

' , c . .' e i T.: .; ' 7 C I , C O t.* f.'M t 6 0 '.

, F.CGhD!.ls

(*1 F) A'. PLA24 DPlVE St'!TE 100C

, ,.- ARur.GTOt.. TEX A5 76311 June 16, 19S2 Dockets: 50-498/82-02 .

50-499/52-02

~

Houston Lighting and Power Company ATTN: G. W. Oprea, Jr.

Executive Vice President P. O. Box 1700 houston, Texas 77001 Gentlemen:

Thank you for your' letter of June 9,1982, in response to our letter of June 3,1982.

We have rev'iewed the recommended changes outlined in your letter, and we agree that several typographical errors were made and should be corrected. Our position on each of your reconsnended changes is documented in Attachement A.

The errors which we believe should be corrected are documented in an errata sheet, which is enclosed as Attachment B.

This letter, with attachments, and your June 9 letter will be placed in the Public Document Room with the investigation report.

Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Sincerely, John T. Collins Regional Administrator

Enclosures:

1. Attachment A - Region IV position on recommended changes to investigation report 50-498/82-02; 50-499/82-02

2. Attachment B - Errata sheets for investigation report 50-498/82-02; 50-499/82-02 G7 Af

-W hGil

, ,-, Sr

,, _ yo,u,s 3 6 b t.-

u..

l l p

,e .-

ATTACitMENT A

^

Region IV Position on litAP Recommended Changes to investiga, tion Report 50-498/82-0'2; 50-499/H2-02 Page No. Recomend,ed Change Region IV Position 4 7th line from the bottom, change the Region IV acknowledges that Mr,. Goldberg's signed word "his" to "lILAP's." statement uses the words "IIL&P specific questions."

but his questions are included in that category. ".o we do not believe the report is inaccurate and slo not plan to change the wording.

4 16th and 18th lines from the bottom, Region IV used the word " timely" to paraphase the change the word " timely" to " quick." statement of Mr. Goldberg. We do not belicve fhat this word substitution effects the accuracy of the report, and we do not plan tn change the wordinq as recommended. .

5 17th line from the bottom, the word We do not believe that the requested chanqe is "no" should be "N0" and in quotation necessary to clarify the report. -

marks.

5 20th line from the bottom, change the We acknowledge that Mr. Goldberg's signed statement word " view" to " review." used the word " review" vice " view," but wo do not believe the recommended change is necessary to clarify the report.

8 Sth line from the bottom of Mr. Frazar's Region IV does not concur with the recomended chanqa.

- interview, change the word "present" to Mr. Frazar did not indicate where Mr. Goldberg was af "available." the time, only that he was not present. The wording will not be changed because t,he accuracy cf the res>in L is not effected.

8 2nd line from top of Mr. Sumpter's We do not plan to change this wording because the interview, the word "about" should be witness was unsure of the date of Mr. Goldberg's deleted. request.

8 2nd line from the bottom in Mr. Sumpter's Although the change is only marginally significani,

, interview, the word " discuss" should be N 11on IV will change the report (see errata sheof) p changed to " review." recomended.

a

(

, ,. p.y 1

Page 2 ,

ATTACHMENT A l Page No._ Reconenended Change, , Region IV Position 9- 1st line in the top of the page, the Region IV agrees and will make the recommended chantie word "nonengineering" should be changed (see errata sheet).  :

! to "known engineering."

< 9 8th line from the top of the page, the Although this change has only marginal significance.

word " description" should be changed to Region IV will make the reconinended change.

j

" descriptions."

9 20th line from the top, the word Region IV does not conce with the reconenended chanqn.

" discussed" should be deleted. The potential problem areas were discussed.

9 30th line from the top, insert the word We believe that the recommended change will not i " lead" between'"IIL&P" and " engineers." significantly change the meaning of the report.

The signed statement did refer to " lead engineers."

however, and Region IV will make the recommended change (see errata sheet).

9 35th line from the top, change the words Region IV agrees that Mr. Sumpter inade reference to "other representatives" to the name of only one Quadrex representative other than Mr. Stanicy I " Larry Wray." and will change the wording accordingly (see errata

( sheet).

I 10 line 28, insert word "not" between "was" Region IV agrees and will make the reconenended chanqn and " maintained." (see errata sheet).

11 7th line from the bottnm, the word Region IV agrees and will makt the reconenended chanqe

" interest" should read " interests," (see errata sheet).

insert the word "not" between "would" and "be," and delete "best." This series of words will now read " interests

- would not be served."

O -

-.J i

n . -. __ . . . .. ... _ - ..

. - ~ + - --. - .

d' f,^.

3' -

i s. .l 1

/:

Page 3 .

.A,T,!,A,C,IITNT, A, ,

Page No. Reconenended_ Change Region IV_ Position 13 2nd line from top, Dr. Key has not Region IV agrees and will maFe the rer.enowneln,I < lu ev-not been identified as being a (see errata sheet). -

participant in the Quadrex Report, but we feel the words "Dr. Key" should be replaced with the word "he."

I I

e 9

l p -

1 i u .

Errata Sheet for Investigation Report 50-495/82-02; 50-499/82-02 The following editorial corrections should be made in HRC Investigation Report 50 498/82-02; 50-499/82-02:

Page fic. Correction E In"the second line f ro- the bottom, change the wofd " discuss" to

" review.*

9 In the first line, change the word "nonengineering" to "known engineering."

.' In the eigth line, change the word "descript' ion" to " descriptions."

9 In the 14th line from the bottom of the page, insert the word

" lead" between "HL&P" and " engineers."

9 In the ninth line from the bottom of the page, change the phrase "other representatives" to "another representative."

10 In the 28th line, insert the word "not" between "was" and " maintained."

10 In the 34th line, change the word "as" to "because."

11 In the seventh line f rom the bottom of the page, change the phrase "our interest would be best served" to "our interest would not be served."

13 In the second line, change "Dr. Key" to "he."

I AU7

\

e .

. . . t wu

. i.i./ . ~~ ~

6

- hL'Ott e r r.EO.;;cor,\ COMMISSION e

% ' -s- } REGloA h

.h ',"*[,J [ Gil RYAA PLAZA DRIVE. SutTE 1000 ARLthGTON. TERA 5 76011 June 16, 1982 Dockets: 50-498/82-02 50-499/82-02 Houston Lighting and Power Company ATTN: G. W. Oprea, Jr.

Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of June 9,1982, in response to our letter of June 3,1982.

We have reviewed the recorrrnended changes outlined in your letter, and we agree that several typographical errors were made and should be corrected. Our position on each of your recornended changes is documented in Attachement A.

The errors which we believe should be corrected are documented in an errata sheet, which is enclosed as Attachment B.

This letter, with attachments, and your June 9 letter will be placed in the Public Document Room with the investigation report.

Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Sincerely, John T. Collins Regior.al Acministrator

Enclosures:

1. Attachment A - Region IV position on recormended changes to investigation report 50-493/82-02; 50-499/82-02

2. Attachment B - Errata sheets for investigation report 50-493/8?-02; 50-499/82-02 ,

GS w- $GE X ,, , , un a s 1. , i ,

5p*s.

• Q Gf I A Y f b N

I I

e

~.

' 4 A11ACllMLNT A 3

Region IV Position on Ill.AP Reconenended Changes to investigation Report 50-498fq2,,02; 5,0-499f,82,-02 l

1 4

Page ,flo. Reconnended Changp Region IV Position 4 7th line f rom the botton, change the Region IV acknowledges that Mr. Goldberg's signed l

word "his" to 111AP's." statement uses the words "IIL&P specific questions,"

but his questions are included in that category, so

' we do not believe the report is inaccurate and do not plan to change the wording.

4 16th and 10th lines frnm the bottom. Region IV used the word " timely" to paraphase the change the word " timely" to " quick." statement of Mr. Goldberg, We do not believe that this word substitution effects the accuracy of the

. report, and we do not plan to change the wording as I reconenended.

I 5 17th line from the bottom, the word We do not believe that the requested change is '

i

i "no" should le "fl0" and in quotation necessary to clarify the report.

marks.

! 5 20th line frnm the bottom, change the We acknowledge that Mr. Goldberg's signed statement word " view" to " review." used the word " review" vice " view," but we do not l helleve the recommended change is necessary to

clarify the report.

d

.I Sth line f ran the bottom of Mr. frazar's Region IV does not concur with the recommended ch uies. .

j interview, chanqe the word "present" to Mr. frazar did not indicate where Mr. Goldberg w.r. at "available." the time, only that he was not present. The wordine:

l will not be changed because the accuracy of the repoit I' is not effected.

8 2nd line from top of Mr. Sun.pter's We do not plan to change this wording because the interview, the word "about" should be witness was. unsure of the date of Mr. Goldberg's deleted. request.

I az, H 2nd line .from t he bottnm in fir. Simipt er's Although the change is only marginally significant, O Interview, the worrt " discuss" should he Region IV will change the report (see errata sheet) 90 changed to "eeview." as reconenended. .

t

i b@

Page 2 ,

MTACIIMENT A Page_ Np,.,

t Change, Rec 3mm ndef,,

Region IV position 9 1st line in the top of the page, the Region IV agrees and will make the reconsuended chan<ie word "nonengineering" should be changed (see errata sheet).

to "known engineering."

9 8th line from the top of the page, the Although this change has only marginal significanu',

word "descriptinn" should be changed to Region IV will make the reconenended change.

"descriptlons."

9 20th line from the top, the word Region IV does not concur with the reconenended chan<i".

" discussed" should be deleted. The potential problem areas were discussed.

9 30th line from the top, insert the word We believe that the recommended change will not

" lead" between *llL&P" and " engineers." significantly change the meaning of the report.

The signed statement did refer to " lead engineers." ,

however, and Region IV will make the recommended change (see errata sheet).

9 35th line from the top, change the words Region IV agrees that Mr. Sumpter maoe reference in "other representatives" to the name of only one Quadrex representative other than f1r. Stanley

" Larry Wray." and will change the wording accordingly (see errata sheer).

10 Line 28. Insert word "not" between "was" Region IV agrees and will make the reconenended chanese and " maintained." (see errata sheet).

11 7th line from the bottom, the word Region IV agrees and will make the recommended chan<ta

" interest" should read " interests," (see errata sheet),

insert the word "not" between "would" and "be," and delete "best." This series of words will now read " interests would not he served."

O 00 l

t Page 3 -

ATTACliMENT A Page_No. Recommended Change Region IV Position 13 Pnd line from top, Dr. Key has not Region IV agrees and will make the recommended champ-not been identified as being a (see errata sheet).

participant in the Quadrex Report, but we feel the words "Dr. Key" should be replaced with the word "he."

O oe

..c......

ATTACHMENT 5 Errata-Sheet for Investigation Report 50-498/82-02; 50-499/82-02 The following editorial corrections should be made in f4RC Investigation Report 50-498/82-02; 50-499/82-02:

Page No. Correction 8 In the second line from the bottom, change the word " discuss" to

" review."

9 In the first line, change the word "nonengineering" to "known engineering."

9 In the eigth line, change the word " description" to " descriptions."

9 In the 14th line from the bottom of the page, insert the word

" lead" between "HL&P" and " engineers."

9 In the ninth line from the bottom of the page, change the phrase "other representatives" to "another representative."

10 In the 28th line, insert the word "not" between "was" and " maintained."

10 In the 34th line, change the word "as" to "because."

11 In the seventh line from the bottom of the page, change the phrase "our interest would be best served" to "our interest would not be servsd."

13 In the second line, change "Dr. Key" te "he."

. , e>

t The Light mmPuy see oe u so.,,, .., eo. ... ivoo se.. e.r..a.1 ooi <>is> 228 92ii June 9,1982 ST-H L- AE-839 FN C2.04/G15.01 Mr. John T. Collins Regional Administrator, Region IV Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

Dear Mr. Collins:

South Texas Project Dockets Nos. 50-498, 50-499 This is in response to your letter 50-498/82-02, 50-499/82-02 dated June 3,1982, relative to your investigation and resulting report pertaining to an allegation relative to the Quadrex Report.

Houston Ughting & Power Company has carefully reviewed the report and while we have no objection to NRC releasing the report to the Public Document Room and the Atomic Safety & Licensing Board, we have noted several typo-graphical errors which you may wish to correct prior to such release. These corrections will assure that the report accurately reflects the certified state-ments of the HL&P persons intervies ed.

Accordingly, we request that copies of this letter with our comments accompany distribution of the report by your office.

The following changes to the report are recommended in ceder to more acetrately reflect the certified statements of persons interviewed during the course of the investigation :

1. Page 4 -- 7th line from the bottom, change the word "his" to "H L& P's".

-- 16th and 16th lines from the bottom, change the word " timely" to " quick".

2. Page 5 -- 17th line from the bottom, the word "no" should be "NO" and in quotation marks.

10th lina from the bottom, change the word " view" to " review".

3. Page 8 -- 7th line from the bottom of Mr. Frazar's interview, change the word "present" to "available".

-- 2nd line from top of Mr. Sumpter's interview, the word "about" should be deleted.

-- 2nd line f rom the bottom in .$.1r. Sumpter's interview, the word " discuss" should be changed to " review".

%R pb H d@3 ?L T

. ~ . . _ . _ .

. Houston t6 hun 5 & ID*tr ComPanv Mr. John'T. Collins June 9,1982 Page 2 ST-H L- AE- 839 FN G2.04/G15.01 4 Page 9 - 1st line in the top of the page, the word "nonengineering" should be changed to "known engineering".

8th line from the top of the page, the word " description" should be " descriptions".

20th line from the top, the word " discussed" should be deleted.

30th line from the top, insert the word " lead" between HLT,P and engineers.

35th line from the top, change the words "other repre-sentatives" to the name of " Larry Wray".

5. Page 10 -- Line 28, insert word "not" between was and maintained.

6. Page 11 -- 7th line from the bottom, the word " interest" should read " interests"; insert the word "not" between would and be; and delete "best". This series of words will now read " interests would not be served".

7. Page 13 -- 2nd line from top, Dr. Key has not been identified as being a participant in the Quadrex Report, but we feel the words "Dr. Key" should be replaced with the word "he".

Should you have any questions concerning these changes, please contact me or Mr. J. H. Goldberg.

Very truly yours,

., ,1 i y

~

o

/ eor e .

[< Ex ' tive Vice ident GWO /sra r

AM

- - - - , - - - - ,,,,,,y-- -r--. .-y .

w w -- T-- '= -'w< w --n v - + ' - - -- --+--*--

~ . . _ _ ..

. . . . . . . . . . . . ... . - . . + -. . . -- - . . . --***

Bechtel Power Corporation

. Engineers . constructors

- P. C. Box 2108 Houston, Texas 770012106 fatax;temas ST-YB-HL-1167 August 3,1982 Houston Lighting & Power Company P.O. Box 1700 Houston, Texas 77001 Attention: Mr. S. M. Dew

. Manager, Engineering

Subject:

South Texas Project Bechtel Job No. 14926-001 Quadrex Work Package EN-619 File No. G15.01

References:

(1) ST-HL-YB-0915, dated July 9,1982 (2) ST-HL-YB-0935, dated July 15,1982 (3) ST-HL-YB-0507, dated April 7,1982 (4) ST-YB-HL-0452, dated April 5,1982 Gen'tlemen:

This is in response to your letters, References (1) & (2), which documented various questions relative to our Draft Report.

The following coments are submitted in response to reference (1):

a) Suggestions for clarification relative to the body of .the sucinary report (coments 1 through 29) are included in the Draft Final Report. With regard to coment 29, the use of the B&R Assessment report (Reference C of the EN-619 report) by Bechtel is described in Section 2.1.1 of the Report. It also seemed obvious that some clarification of Section 2.1.2 (Tracking, now called Status of Quadrex Discipline Findings) was needed to assist the reader.

Therefore, additional information has been added and redesignated as Section 2.1.3.

b) As requested by the coment on Appendix A Reference (3) is now Appendix B of the EN-619 Report.

' ~

Further, the coments contained in EefeEe'nce (3) were taken into consideration in developing the EN-619 report, as was described in reference (4). Relative to the third paragraph of reference 3, your

. . attention is directed to the coment on Generic Finding 3.1g which discu:ses the interface document between HL&P, Bechtel, and

. Westingho'use. Coments are given r' elative to Bechtel review of Westinghouse design applicable to STP. In addition, Bechtel's Engineering Procedures have the necessary provisions to assure 4 adequate review of work performed by subcontractors or suppliers.

g 0426N/0C06N b

c "" W. :. .

~

. . . . .. .- . ~.

Bechtel Power Corporation

. Houston Lighting & Power Company , ST-YB-HL

__ - Attention: Mr. S. M. Dew * -

Page 2

.~ c) Based on discussions with HL&P representatives on July 13, it became clear that the format of Appendix 8 to the EN-619 Draft Report did not provide the infomation intended, i.e., consolidated data on the status of the EN-619 effort. Therefore, the information formerly contained in Appendix 8 has been reformatted.and is presented in Section 2.1.3 of the sumary report in the form of discussion and tables 2.1.3-1, -2, and -3.

d) The general coments (1 through 10) on Appendix C have been addressed. Also, the specific comments (1 through 175) on Appendix C have been addressed and additional clarification provided for these line items.

The following coments are provided in response to reference (2):

a) The general coments, I through 4, have been addressed. As requested, Appendix D has been reformatted to include all of the information on the Generic Findings. As previously mentioned applicable parts of Reference (3) were considered in the reformatting of Appendix D. ,,

~

b) In addition to our revision to the Generic Findings Sumary Sheets in Appendix D, the specific comments of reference (2) were addressed as described in the following:

3.la The typegraphical error on spatial coupling was corrected. Relative

- to the validity of the findings one can refer to the BTF assessment; of 13 related findings, only 2 are time sensitive. Line Item 49 was considered a Category 2 and is dispositioned pending issuance of the' Systems Interaction Design Guide, one of the six primary resolution actions noted in Section 2.1.3 of the Final Report, while Line Item 206-is resolved.

3.lb Quadrex Part I has been addressed in several Line Items particularly

! Line Item 1, while Line Item 189 discusses the methodology to assure that appropriate procedures are -used by 8PC.

Relative to part 2, the work package review plans of the transition

- program contain a check list-which.pr4*idas for the sampling of calculations which should identify any trend in calculational 5

errors. Corret.tive action will be taken when a trend is identified.

L .

. 1 N

e . . , . . , . . e e .,

Bechtel-Power Corporation l'

~

Houston Lighting & Power Company ST-YB-HL '

.

• Attention: Mr. S. M. Dew Page 3 .

3.lc Six of nine Line Items associated with this concern are resolved. Of

' ~

the remaining three. Line Item 82 was classified as Category 1 by the BTF, and the potential reportability of.the issue is resolved through action taken by IRC Item 95. While the normal plant conditions as applied specifically to HVAC are addressed by Line --

Items 81 and 89, the discussion on Line Item 58 indicates that normal

' plant operating conditions were considered in the designs reviewed by Quadrex.

3.1d .Bechtel's position on the need for " sharp distinction" is best covered in response to Line Item 202; and it is noted in Appendix E,

. that Bechtel procedures do not make such a distinction for

- calculations. The Bechtel Transition Team in the development of Work Package EN-615 has noted one case where B&R apparently did not properly identify a safety-related component. This has been identified as IRC item 123.

3.le Guidelines did exist and Sechtel intends to supercede them for completion of the Project. Section 7.2.2.2.3.2 of the FSAR provides documented evidence of STP intention to comply with GDC 24.

Documented evidence soley, developed to indicate that single failure criteria has been met is not required.

3.lf Design commitments from the FSAR are being listed on the Licensing Commitment Tracking System (LCTS). The procedure will then require that the implementing document for each co:mitment be located and listed. Thus, a one-to-one correlation will be possible after a certain time period. The bl&P site personnel will have a computer terminal on site through which they will be able to acces,s HL&P's portion of the LCTS. Bechtel Licensing will issue reports, as requested from the site, for the Bechtel controlled portions of the LCTS. Bechtel's SAR Change Procedure makes Licensing the central focal point of all SAR changes.

I 3.1g Bechtel's STP Project Procedure, EDP-4.37, states, "Where detailed calculations are not warranted, a calculation sheet shall be completed to clearly state the basis of how the design data was otherwise developed. Such cases may include use of recognized

,- tables, or where judgement is employed in sizing equipment".

Interdiscipline design information will be documented; the form of documentation varies from references in calculations to sections of design manuals.

$N Oa26N/0006N

w m _ .

Bechtel Power Corporation

~

s  %

Houston Lighting & Power Company ST-YB-HL

. ~ '

__- Attention: Mr. S. M. Dew -

Page 4 -

.. 3.11 A discussion of the proposed Bechtel Scope of services is contained in the draf t contract between HL&P and Bechtel, while EDP 4.25 & 4.58 provide the mechanism used to handle consultant service agreements.

3.1j As indicated in our response Transition procedure QE-001 adequately provides for the review of past design verifications and Bechtel EDP 4.27 defines how the final design will be verified. Especially note paragraph 4.2 of the procedure which discusses qualification requirements of verif ters. Refer particularly to Line Item 65.

- The Draf t Final Report for EN-619 has been revised to address your questions as outlined above, and the revised report is currently undergoing Bechtet internal review.- A copy of the revised pages of the draft report is enclosed for your information.

Very truly yours.

BECHTE POWER CORPORATION

.. j

. L. Ro ers Project Engineering Manager Attachment .

cc: L. J. Klement (HL&P), w/o Att. .

M. E. Powell (HL&P), w/o Att.

C. Robertson (HL&P), w/o Att.

J. White (HL&P), w/o Att.

STP-RMS

1. - m eme e.

' e t

n ' 98 *! /Onn4 N

Bechtel Power Corporation

~

bec J. Hurley , w/o att. . _

H. J. Gomly, w/o att. .

R. Scott. w/o att.

Project Files 1

l .

0426H/0006N M4

Dms  % .snor News Feo o A v 6//e/ez Investigation

' clears utility ~

of cover:up tlntled ?ren internationet

• HOUSTON - An investigation by the No-clear Regulatory Commission coes not support a charge that Houston Lighting & Power Co. delib.

,erstely concealed from the NRC a report that said the design of the South Texas Nuclear Project was laced with errors and deficiencies, officials said Friday, i

• Ite NRC said, however, that it is giving HL&P a violation notice for delay in reporting two defects in the project that had been cited in

. a report by the Quadrex Corp.of California. . .

. The Quadrex report was given to HL&P offi.

cials on May 7,1981, but it was not made public

• or provided in full to the NRC for five months.

Don Beeth, HIAP spokesman, said the company

did notify the regulatory agency of two " report-

. able deficiencies" within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receiving

• l thecontroversialreport. ]

"We, of course, are pleased that the NRC has I

\ .; corroborated that we Irnew to be the truth all

. along - that there was no cover.up of the re-N' ~^- l port,"Beeth said. ..

l The NRC began its investigation after Lanny

' Sinkin, an opponent to the 54.8 billion nuclear

project near Bay City, charged that HL&P's man.

. agement " deliberately withheld the Quadrex Re-l port from the NRC."

, Statements had been taken from high-rank.

ing HIAP officlas, including executive vice pres.

. ident George W. Oprea and Jerome H. Goldberg,

. lvice president for nuclear construction'. '

,l One of the deficiencies involved improper

-l engineering for heating, ventilation and aircon. .

ditioning systems. The other concerned a defee.

l .

. tive verification system for computer codes.

l The first round of NRC licensing hearing

( ': concluded Thursday after a year of meetings by

NRC officials. A Nuclear Regulatory Con mission j .. licens'ng board, which has been hearing the ,

6 case hope to have its findings made public next j i ' December. i

". Early next year the board will convene to

! dons! der the validity of the Quadrex report of i

. Whether HL&P deliberately tried to conceal the

report from the NRC.

1 . . ,

N _

.ts

/ -

~

Houston Lighting & Power Company ,

TELEPHONE MINUTES COR R ESPONDENCE 3 D. G. Barker . PROJECT MANAGER SERI AL NUMBER KT.H1 Hf.7171t 40M C G- Rnnertenn DEPTJDIVISION Nuclear Licensino Deoartment DOJECT South Tout prnjpet DATE OF dALL June 11. 1QR7 uBJECT HL&P's letter ST-HL-AE-839 THER PARTICIPANTS. ajalG[fy7gMy[cm SUBJECT FILE NUMBERS: PRIMARY J.E. Gagliardo - NRC, Region IV . SECONDARY:

PAGE I OF I Mr. Gagliardo was called and informed of a typographical error in the referenced document. At the bottom of Page 1. Item 3, Page 8, seventh line should be changed to read fifth line.

Mr. Gagliardo also informed me that NRC planned to issue a report errata sheet and our letter of June 9,1982 with the Investigation Report # 02-82 as a package to all parties on the service list.

CGR/imf cc: J.H. Goldberg J.G. Dewease J.E. Gagliardo (NRC-Region IV)

C.G. Robertson G.W. Oprea, Jr.

STP RMS 5

7 A(oG

The Light Company Houston Ughdng Hour RO. Box 1700 Houston.Texu 77001 (715)228-9211 July 9, 1982 ST-EL-YE-0915

- SFN: Z-6950 PFN: G 15.01/D 4.19.1 Mr. R. L. Rogers Project Engineering Manager Bechtel Power Corporation P. O. Box 2166 Houston, Texas -77001 Subject- Work Package EN-619 - Review of the Quadrex Report Draft Final Report SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION _

Reference:

ST-YB-HL-909 ,

Dear Mr. Rogers:

Attached is a partial sub=ittal of ce==ents on Work Package EN-619 Draft

-. Final Report. The scope of these co=ents, excluding Generic Issues, includes:

~

(1) Co=ents on the Su==ary *

(2) Cc=ents on Appendix A (3) Co=ents on Appendix B (4) Co=ents on Appendix C (Excluding Generic Issues)

Preli=inary handwritten versions of =est of these ce=ents were discussed in neetings during the week of June 28th. Our cc=ents regarding the Generic Issues in C will be issued soon.

Very truly yours.

BECHTEl. PWER COPGRATION gj(/ d k r.ECE:VED S. M. Dev JUL 16 882 xanager, engineering South Texas Project CNESTRATivE 0000WINT CONTR0t.

JGW:V Atts.cn=ents cc: C. G. Robertson J. R. Mo11 eda R. R. Herr.anf en S. Tic =araju J. N. Bailey STP Engineering File J. L. Barker STP P35 V A7o fr X

...c..... .

CO)0ENT ON SU)O'.ARY REPORT

1. Referenqe and address ST-EL-YB-0507 (Golcberg to Kalligan). In particular, your attention is directed to the last paragraph wherein Bechtel was instructed to take into account additional information and to ensure that the disposition of Quadrex Findings reflects such review has been accomplished. Your attention is also directed to the second paragraph concerning resolution of Generic Findings. Some indication of the validity of the Quadrex Generic Findings as true Generic Effects must be made. The validity assessment must be based on the results of the actual review to date.

2. A more ce=plete description of the scope and purpose of the Appendices is required in the report to include their relationship to each other.

3. The definition of " Resolved" and "Dispositioned" must be clearly stated and consistently applied. In particular Page 3 of the' report, Paragraph 8 of Appendix B, and Paragraph 10 of Appendix C cust be in co=plete agree =ent in statement and application. The following definit- i ions are offered fer your consideration:

Resolved -

Review is co=plete to establish " validity" or "non-validity" and further specific activities are not expected to be necessary to correct or change the existing design as a result of Quadrex Findings.

Final Disposition - Review is complete to establish " validity" or "non-validity" and further specific activities by Bechtel have been identified.

Identified Disposition -

Review is not co:plete with respect to " validity" but a plan of action or activities has been specifically identified.

4 Revire the use of the words resolution thrcughout the report to be consistent with either resolved or dispositioced.

5. A more coeplete discussion of the role of the transition review and its relatien to Quadrex Finding, should be provided.

A'70

a.a. n. . .

t Com:ents on Su::xnary Report Page 2

6. Page 1. Paragraph 1 - Provide the title to Reference A as part of the second sentence and change Reference C to Reference A in the last sentence.

7. Page 1 - Paragraph 3 -

Correct "of" to' "or" in the last line.

. 8. Page 2, 4th Line - Change to read ". . . therefore, such activities identified in this work package. . . "

8a. Page 2, 7th Line -

Delete "in addition".

9. Delete the sentence beginning with " revisions".

10. Page 2 Section 2.1.1, 3rd.Line - Change reference "1" to reference "B".

. 11. Page 3.-2nd Paragraph - Delete "in attempt".

12. Page 3, 3rd Paragraph, 3rd Line - Add bstveen words "providing" and

" final" the words "or i=ple=enting".

13. Page 3, 5th Paragraph, 1st Sentence - Revise to read "During a later phase of the Engineering progran".

14. Page 3. 5th Paragraph - At the end of the paragraph, add explicitly the definitions of resolved and dispositioned.

15. Following the above revision for Section 2.1.2 - Re-review and revise, as necessary. to ensure that the words " disposition", " disposition-ed", " resolved", " unresolved", etc., are consistently used. In particular, Paragraph 4 on Page 3 appears to use the terms synonomously.

16. Page 4, 4th Line - Change " proposed" to " programmed".

AD

na e. .. . . .. . . . .

e

~

Comments on Summary Report Page 3

17. Page 4, 1st Paragraph - Implies that all Findings are covered in system work packages whereas some are discussed only in this EN-619 Package. Therefore, add a sentence that explains this. Also, this work package needs to identify those actions that are exclusive commitments within this package.

18. Page 4, Section 2.1.3 - Should be revised to add a, statement on the term evaluation of Section 4.9.

19. Page 4, 4th Paragraph, 1st Lina - Change to read ". . . based on a ce=bination of the individual discipline. . .".

20. Page 4, 4th Paragraph " Is it correct to state that Generic Findings do not contain any new items not identified specifically by line item Findings? This does not appear to be consistent with the Task Force statements.

21. Page 5, 1st Paragraph, 3rd Line - Add after " applicable" the words, "with respect to required corrective action for past events".

22. Page 5, 2nd Paragraph, 1st Line - Add after " involved", the words, "with respect to corrective actions relating to Quadrex".

23. Page 6, Paragraph C - Does not appear to be consistent with the Task Force state =ents.

24. Page 7, Paragraph 7 - Add at the end of the first sentence "as justified in Appendix D".

25. Page 6 Page 10 Section 2.2, 1st Paragraph -

Add after the sentence " Tracking and closecut are to be accomplished through normal Project handling procedures for action items".

e

[70 i

cs- -

(t .

3r s

Comments on Su= mary Report Page 4

_ , 26. Page Ib - Delete Paragraph B.

27. - Page 10,' Paragraph C - Change to read ". . . provide the' closeout of . findings.for which final disposition or planned disposition has not yet been achieved. . .".

- 2 8 '. - Page 10, Section 2.3 - Delete Paragraph B, as it relates to irevising summary gheets.

29. Page 13 -

' Describe the use made by Bechtel of' Reference C.

N $

9 e.

t

• ( 1 e

f 5

m -

l 1' i

k s

0 A1o

• .sh:.b . - . . . . ,<

x 3

)

. c

~

ccmnant on W A

1. In addition to the Bechtal letter please 1:r.lude the HL&P letter that c:x mented on the Bechtel Task Force Feport (ST-F1-YB-0507) .

,3 i

4

)

I a k i

=

4

! t 1

1 s

e 9

1 I

u e

J 4

L f

f b

I f

i l

t

~

! Av l

l

~ d.&a _ i .. . ,1, ,

+

.I. '

C0!O!ENTS ON APPENDIX B

1. Since'this is only a summary level document and does not provide additional information, we prefer to have this Appendix 1 deleted from the Final Report.

kI 4

e e

lI 9

D W1o

..n- . .

CENERAL COMMENTS ON APPENDIX C (Excluding Generic Issues)

1. L'ORK PACKAGE htHEERS:

Further work activities and already completed work activities require identification of the appropriate work package numbers. Each verk package that states a position on a Quadrex issue should be referenced. An evaluation paragraph may not be necessary, but a reference is.

2. SCHEDULES FOR ACTIVITIES:

. Those items that are "Ti=ing Sensitive" should have identified schedules for the appropriate actions required to disposition the activity.

If Bechtel Project has evaluated a "Ti=ing Sensitive" item as identified by the Bechtel Task Force and finds no reason to pursue this matter expeditiously, then this evaluation should be clearly stated. When schedules are given, only the conth and year are necessary.

3. BECHTEL PROCEDURES. STANDARDS AND GUIDELINES:

An action identifying a Bechtel Procedure, Standard and Guideline must be explicit such that the reviewer can identify the document by a reference. Also, use the same term for the same type documents.

4. NUREG's:

The repcr shculd be reviewed and appropriate words utili:ed in des-cribing NURIG's to ensure that they are not being quoted as regulatory requirements except for any explicit cases wherein STP has specifically ce==itted a NUREG.

5. ONGOING ENOINEERING DESIGN ACTIVITIES:

Some of the findings have been identified as representing future engineering design activities that are normal to a nuclear project. In such cases, the rationale should identify that this activity is a normal e:gineering design activity. The su==ary statement by the Bechtel Project Team shculd lead the reader to that sane conclusion.

.Aa 9. . . . . . . . .

6. ORGANIZATIONAL PROBLEMS:

A nu=ber of Quadrex Findings relate directly to perceived Brewn &

Root organi:ational proble=s or perceived Brown & Root administrative functions. In these cases, the rationale shculd identify these as a Brown & Root organizational matter. The description in the su= mary should again describe Bechtel's organization in such a manner as to dispose of the item.

7. CROSS-

REFERENCES:

The identification of related issues should be reviewed to ensure that the appropriate cross-referencing has been accomplished.

8. BECHTEL' TASK FORCE AND BECHTEL PROJECT TEAM AGREEMENT:

The su==ary provided by the Bechtel Project Team should clearly indicate if Bechtel Project Team agrees or disagrees with the Bechtel Task Force Assessment. It is particularly important that any disagreement be identified tegether with the importance of the disagreement.

9. STATUS:

. A re-review of the " Status" of each ite should be performed to ensure consistency among the related findings. .

10. RATIONALE:

The "Raticnale" state ents should be re-reviewed to ensure that the reason for Finding being considered " Resolved" is stated clearly.

e

SPECIFIC C0ttv.ENTS ON APPENDIX C COVER SHEET

1. Item 5 is recommended to be revised as follows:

"'Quadrex Rating' indicates the ranking of the finding as given in the Quadrex Report".

2. Item 11 is recommended to be revised since we are not using terms "open" or " closed".

3. Add an Item between Numbers 7 and 8 that defines the term "BTF Assessment". It should point out that the Summary Sheet often has only a synopsis of the total Assessment statement.

O e

.o c .- m . . . , .

SECTION 4.1 4 Line Item 1 - The last sentence in the EC-103 evaluation uses the words "=any times" which may icply that a formal program is in place.

Therefore, it is reco= mended that this sentence be revised to state that this type of com=unication is informal.

5. Line Item 2 - Discusses in detail the use of 130k loading. However, this particular aspect of the original Quadrex Finding 4.1.2.1(a) that the BTF separated into Line Items 1 and 2 did not reference the Questions associated with the 130k leading. Therefore, it is recom-canded that the discussion be deleted. The last sentence of the 1st page of the summary states, "The effect" which implies that an effect is expected. If this is not the nor=al case, please revise to state "Any effect". The Rationale statement refers to EN-602 efforts. For this to be an adequate rationale, an EN-602 Evaluation Section is

. needed or a brief statement in the Rationale as to what effort is being extended.

6. Line Item 3 - Should be reviewed per our general comment concerning a review of the " Status" section.

7. Line Item 4 - Should be reviewed per our general co==ent concerning a review of the " Status" section.

8. Line Item 5 - Discusses R.G. 1.122 to which STP did not commit.

Therefore, the discussion does not appear to relate to the Finding.

Re-evaluate if this paragraph should remain in the Evaluation section. *

9. Line Item 6 - Starts ic=ediately into the evaluation based on the detailed information contained in the referenced questions. There-fore, an introductory sentence on defining the problem is needed.

The evaluation should point out that R.G. 1.104 is discussed in detail in the FSAR. A statement concerning NCREG-0577 is needed since the evaluation discusses the other example given by Quadrex in the questions. Refer to our general comment concerning the use of the term require =ent in relation to NUREG's.

10. Line Item 8 - Should be reviewed per our general co=sent concerning a review of the " Status" section. Refer to our comment on the BTF report concerning the contractual arrangenents with Teledyne.

Since EN-601 progra= addresses this concern, a brief evaluation should be provided rather than just a reference.

11. Line Item 10 - Should be revised to reference the Bechtel procedures to be used for design verification. The discussion of the last sentence would appear to more appropriately state " meaningful" instead of " major".

12. Line Item 15 - Should be reviewed per our general ec= ment concerning

. a review of the " Status"section. Work Package EN-604 on Equipnent .

Qualification should be included.

A'M

um-... . .. _ _ .

SECTION 4.1 4 Line Ites 1 - The last sentence in the EC-103 evaluation uses the words "=any ti=es" which may i= ply that a for=al program is in place.

Therefore, it is reco== ended that this sentence be revised to state that this type of cot =unication is informal.

5. LineIte$2-Discussesindetailtheuseof130kloading. However, this particular aspect of the original Quadrex Finding 4.1.2.1(a) that the BTF separated into Line Items 1 and 2 did not reference the Questions associated with the 130k loading. Therefore, it is recom-mended that the discussion be deleted. The last sentence of the 1st page of the sum =ary states, "The effect" which implies that an effect is expected. If this is not the normal case, please revise to state "Any effect". The Rationale statement refers to EN-602 efforts. For this to be an adequate rationale, an EN-602 Evaluation Section is

. needed or a brief statement in the Rationale as to what effort is being extended.

6. Line Item 3 - Should be reviewed per our general coc=ent concerning a review of the " Status" section.

7. Line Item 4 - Should be reviewed per our general ectment concerning a review cf the " Status" section.

8. Line Item 5 - Discusses R.G. 1.122 to which STP did not co=mit.

Therefore, the discussion does not appear to relate to the Finding.

Re-evaluate if this paragraph should remain in the Evaluation section.

9. Line Item 6 - Starts ic=ediately into the evaluation based on the detailed informatien contained in the referenced questions. There-fore, an introductory sentence on defining the problem is needed.

The evaluation should point out that R.G. 1.104 is discussed in detail in the FSAR. A statement cencerning NUREG-0577 is needed since the evaluation discusses the other exa:ple given by Quadrex in the questions. Refer to our general co==ent concerning the use of the term require =ent in relation to NURIG's.

10. Line Ite: 8 - Should be reviewed per our general coe=ent concerning a review of the " Status" section. Refer to our co= ment on the BTF report concerning the contractual arrange:ents with Teledyne.

Since EN-601 program addresses this concern, a brief evaluation should be provided rather than just a reference.

11. Line Item 10 - Should be revised to reference the Bechtel procedures to be used for design verification. The discussion of the last sentence would appear to more appropriately state " meaningful" instead of " major".

12. Line Ite= 15 - Should be reviewed per our general co==ent concerning a review of the " Status"section. k*ork Package E5-604 on Equip =ent -

Qualification should be included, h

. . c. + . . . .

13. Line Item 16 - Should be reviewed per our general ce==ent concerning a review of the " Status" section. A statement on the involvement of the Bechtel " materials" group should be added. In addition to reviewing the procedures, a visual examination of the fuel pool liner is requested.

14. Line It.e= 18 - Evaluation should be revised to (1) Clearly indicate that the FSAR description on tangential shear has been followed, and (2) Clearly state the problem.

15. Line Item 20 - Evaluation should be revised to clearly state the status of the calculations and, if they are in the process of being updated, confirm that the appropriate pressure load is being included.

16. Line Item 21 - Should be reviewed per our general com=ent concerning a review of the " Status" section.

17. Line Item 25 - Should be revised to state Bechtel's approach to the Quadrex cencern expressed in the last sentence of the Finding regard-ing criteria.

18. Line Item 27 - Should be revised to clearly address the Quadrex Finding on the use of a standard penetration being more efficient.

19. Line Item 28 - Rationale should also point out that the basis of the Finding involves B&R personnel, which no longer has meaning.

20. Line Item 29 - Should be revised so that the EN-619 evaluation paragraph clearly refers to Question C-26 as the basis for the state-ment.

21. Line Item 30 - Should be revised so that the EN-619 evaluation paragraph clearly refers to Question C-29 as the basis for the state-ment.

l l 4 w4+, p.s.4. - s _

?

l l

l .

~

I

! SECTION 4.2 l

i

22. Line Items 34 through 46 - Should be re-reviewed and revised, as l necessary, based on the following general comments

l l a. The CPVR and calculation review program in Appendix E F . should be referenced rather than the ION.

f

b. Several of the evaluations discuss in detail two codes used in shielding calculations. However, the Findings

~

j l- are more generic in nature so these detailed discussions appear inappropriate.

l

c. Several items are timing sensitive so a schedule should be j ,

provided.

~

23. Lin's Itta 34 - Should be revised to reference IRC #96 rather than #94.

24. Line Item 39 - References EDP-4.31, which does not appear appropriate l

since this procedure is not to be used on STP.

25. Line Item 40 - Should be revised to address 'the last sentence of the Finding on li=itations to re-verification. Also, provide a reference to Bechtel procedures to be used in the future.

26. Line Item 41 - Should be revised to address whether Bechtel will have

_, a " controlled" document.

p .

I l

l 8

O t

..m._.,_..

SECTION 4.3

27. Line Item 47 - Should be revised to clarify that:

a. The original design configuration was deter =ined, not reportable.

b .' Changes were made to the design to eliminate the arrange-ment.

28. Line Item 48 - Should be revised to state that the configuration was not a " design error" as stated in the 1st sentence of the Finding.

Also, provide a brief statement on the EN-601 FMEA ef fort rather than just a reference to Section 6.0.

29. Line Item 49 - Should be clarified to state whether a " plant-wide" cop level separation document is necessary and if one vill be used by STP.

30. Line Item 50 - Should be revised for the EE-220 evaluation to state the plan of action. It is unacceptable to only state than an item will be resolved. Also, add a state =ent on the fact that Bechtel has experience at design of nuclear plants and knows the various documents that are required. The " Controls" discussion appears to apply to all Bechtel disciplines, so this should be part of the EN-619 evaluation.

31. Line Item 52 - She ld be revised to delete the references to the NUS procedure, etc., s: 2ce these were not used extensively on the Project.

However, the Safety System Harard Analysis effort may be pertinent to discuss.

32. Line Item 53 - Should be revised to clarify whether the design spec-ifications contained basic separation requirements even though specific guidance was not givet. The EE-220 statement should be revised to state the actions to be taken. A general state =ent on the Bechtel approach of defining specific requirements to vendors appears to be needed. Note that EJ-314 also discusses this Finding.

33. Line Item 54 - Should be revised to more clearly address whether a top level document for equipment classification require =ents is necessary and/or to be developed by Bechtel. Also, the two discussions on the Q-List should flow together rather than being distinct statements with different levels of detail.

34. Line Item 56 - Should be revised to clearly state that the NRC review of this design change is progressing as per an FSAR question. Also, the rationale may imply that Bechtel does not review Westinghouse design changes, which in fact does occur.

35. Line Item 57 - Should be revised to clarify how Procedure 4.1

" options" relates to identifying support systems, etc.

36. Line Item 58 - Should be expanded to address more than just HELBA such as radiation, etc. Also, review the " Status" per our general comment.

O

m

37. Line Item 59 - Should be revised to delete the specifics on the ESF sequencer and address the general concern on how Bechtel approaches giving specific guidance to vendors en regulatory requirements and codes and standards. The evaluation of the EN-630 appears inappropr-iate in that EN-630 does not involve a review of the designs by.

vendors in meeting standards for items such as separation.

38. Line Item 61 - Should be revised to either delete the reference to "B&R Assessment" or quote the assessment since we want to minimize references to other documents.

39. Line Item 64 - Should be revised for the EE-220 evaluation to state what is being " resolved". Also, provide a schedule or state it is not timing sensitive.

~

40. Line Item 65 - Should be re-reviewed to determine if Quadrex was in erior when they said it violated B&R procedures. Also, point out that the design verifier and checker are allowed to be the same person per industry standards.

- 41. Line Item 66 - Should be expanded to include all battery systems, so Work Packages EE-207, 210 and 224 may be applicable. Also, provide a schedule or state it is not timing sensitive.

42. Line Item 67 - Should be revised to delete the EN-630 reference since that secpe of work does not appear to be directly applicable.

~ '

43. Line Item 69 - Should be revised to either delete the Architectural evaluation er provide similar statenents from each discipline or preferably just provide a description of the Bechtel team approach.

Also, discuss the Transition review effort on identifying inconsist-encies as part of checklist activity.

44 Line Item 70 - Should be revised to more clearly state whether

' specific procedures for reviewing a particular vendor document are written.

45. Line Item 73 - Should be revised to clearly state that separation is provided by physical location and that it is adequate.

46. Line Item 74 - Should be revised to state the actions to be taken per EE-220. A more general discussion should be provided since all of the details are not agreed to as yet.

47. Line Item 76 - Should be revised to include the EJ-314 evaluation also.

48. Line Item 77 - Should be revised to clearly state whether there is an

. NRC requirement or not. Since post-TMI concerns were outside the scope of Quadrex, the evaluation should put this in perspective.

49. Line Item 79 - Refers to a Boron Injection Systen. Please confirm -

that this is the proper reference.

fo

. . m . w u ....

SECTION 4.4

50. Line Item 81 - Should be revised to clarify the actions scheduled to be completed by Septecher 24, 1982.

51. Line Item 83 - Should be revised to give current status of calculat-ions. Also, address more clearly the Bechtel approach on hydrogen pocketing following a LOCA.

52. . Line Item 84 - Should be revised to delete the Seismic II/I discussion since this change in design concept has not been approved and the

.. Quadrax Finding was directed at B&R, which had only Cat. I.

~

53. Line Item 85 - Should be revised to clearly state that "the four buildings" are those which house safety-related equipment.

54 Line Item 86 - Should be revised to state whether the ECW 1eakage proble=, as identified by Quadrex, appears significant.

55. Line Item 87 - Should be revised to add a statement that Bechtel EDP's require updating of these documents to maintain consistency.

56. Line Item 89 - Should be revised to state the Bechtel approach on consideration of actual plant operating conditions.

57. Line Item 90 - Should be revised to clearly. state the status of this calculation.

58. Line Item 92 - Should state that the one example is on the action item list to be resolved and whether it is significant.

59. Line Item 94 - Should be revised to clarify whether a single document is necessary and/or is to be issued for STP.

60. Line Item 96 - Should be revised to point out that the design was the subject of a reportable deficiency.

61. Line Item 101 - Should be revised to delete a specific fire damper reference since others may be used. Also, in the last sentence, "not applicable" implies that the Finding does not relate to STP design, which is not the case.

62. Line Item 105 - Should be revised to clearly state that, although a minimum ti=e was not specified, the vendor supplies dampers with a certain closure time of .25 seconds.

63. Line Item 106 - Should be revised to include in the evaluation the statement in the rationale regarding significance or the item should be considered pending.

64 Line Item 107 - Should be revised to delete the Seisnic II/I discussion.

. 65. Line Item 110 - Should be revised since the Finding was simply that a calculatten was not available to Quadrex. ga7cy

-.wuo ~. .. .

SECTION 4.5

66. A general cc= ment on this section is that the same issue, such as "10' half cone angle", is the subject of several Findings. So it is recom= ended that only one response be written and each subsequent evaluation vould reference it.

67. Line Item 114 - Should be revised to include M-9 as a referenced question. Also, the BTF divided the Finding 4.5.21d into two line items which may be appropriate, so this should be re-reviewed.

68. Line Item 115 - Should be revised to clarify the term "unlikely" since this could imply that there are cases where this vill occur.

69. Line Item 116 - Should be revised to note that the B&R/EL&P ALARA re-reviews did not include ISI. Therefore, the Bechtel review of these items should be stated with any conclusions.

70. Line Item 117 - Should be revised to clarify that the cencern was an interface between EDS and B&R, which is no longer meaningful.

• /1. Line Item 118 - Should be revised to clarify the term " detriment".

72. Line Iten 119 - Should be re-reviewed and confirm that a U-Bar specification was not a part of a bulk material specification.

73. Line Item 121 - Should be revised to address more clearly the need for

" Specific Cuidelines" for the EDS scope of work discussed in the referenced question. -

74 Line Ite: 126 - Should be revised, for the last sentence states "should" instead of " vill".

75. Line Item 128 - Should be reviewed per our general com=ent on review of the " Status".

76. Line Item 129 - Should be revised to clearly state if a TRD is needed or not.

77. Line Item 132 - Has a typographical error in the BTF Assessment, the year should be 1981 not 1982.

78. Line Item 133 - Should be revised to delete the discussions that go beyond the scope of the Finding.

79. Line Item 135 - Should be re-reviewed to confirm that superpipe criteria is appif ed to MS and FW only.

80. Line Item 137 - Should be re-written since the evaluations appear to be contradictory.

81. Line Item 138 - Has a typographical error, the date is 1981 not 1982.

Also, the evaluations appear to be contradictory.

A7o

..c.~.

e

'82. Line Item 141 - Should be revised to reference EF-930 review for ISI. Also, the word "should" in the last sentence should be "will".

83. Line Item 142 - Should be re-reviewed to confirm that co=mitments to perform pipe rupture are part of the LCTS.

84 Line Item 143 - Should be revised to use a word other than " invalid".

85. Line Item 144 - Should be revised to point out that the concern related to the EDS and B&R interface is no longer meaningful.

86. Line Item 147 - Should be revised since "should" is used again in the last sentence.

87. Line Item 148 - Should be revised to clearly state the Bechtel approach.

88. Line Item 150 - See previous comment on the use of term "unlikely" in Item 115.

89. Line Item 152 - Should be revised to clearly state the flooding includes moderate energy line sources and can affect buildings other than MEA 3.

90. Line Item 153 - Should be reviewed to determine if the status should be the sa=e as previous EN-601 items.

91. Line Item 155 - Should be revised to delete the discussien outside the scope of the Quadrex Finding.

92. Line Item 157 - Should be revised to clearly identify the scope of work by EDS in the second sentence.

93. Line Item 159 - Should be re-revie.ed and confirm that a U-Bar specification was not a part of a bulk specificaton.

94 Line Item 161 - Sheuld be revised to clearly state whether the criteria was addressed by B8R.

95. Line Item 165 - Should be re-written, since it is presently contra-dictory.

96. Line Item 166 - Should be revised to delete the discussion of HEB-6 since this is not the Project co=mitment.

97. Line Item 169 - Should be revised to expand the scope beyond just ASME III solenoid valves.

98. Line Item 170 - Should be revised to clearly state the relation with ANSI 278.2.4 and if it is to be used by Bechtel on STP.

~

b10 1

t

~ * ~ . .:::.

99. Line Item 171 - Should be revised to state if a problem exists.' Refer to the IRC evaluations.

100. Line Item 175 - Sheuld be revised to clearly state whether there is a concern, since the EC-103 has an evaluation underway but it is

" Resolved".

101. Line Item 178 - Should be revised to point out that BAR had not reviewed the calculation that was referred to by Question M-39.

102. Line Ites 180 - Should be revised to clearly state that valve opening and closing times were specified but were based on Westinghouse i criteria and still need confirmation of adequacy based on a systes review.

1 l

6 0 e

l l .

O

a. m . . . . .. . ,

- . . . . . - . -, --. . - ~ - - . .

SECTION 4.6 103. A general co=:ent applicable to Line Items 185, 187, 188, 196, and 205 is that each is categorized as Timing Sensitive and Pending, so a schedule should be provided.

104. Line Item 187 - Should be revised to discuss more than just P/T cal-culations, since B8R's Nuclear Analysis Group had a broader scope.

Also, the 1st sentence should indicate that the calculations are currently under review.

105. Line Item 188 - Should be revised to add to the Rationale that re-analysis will be performed where appropriate.

106. Line Item 190 - Should be revised in the Rationale to substitute

" accepted" rather than " approved" unless Bechtel has received approval by some process such as Topical Report.

107. -Line Items 194 and 195 - Should be revised to add that these concerns relate to B&R personnel and are no longer meaningful.

108. Line Item 196 - Should be revised to correct the time frame of the NRC change in criteria. It occurred in 1977, not during the TSAA review (See ST-EL-AE-197). Also, the last sentence on the 1st page should state "tiRC Review Criteria".

109. Line Item 197 - Should be revised to either delete the reference to the B&R Assessment or provide a full acd complete quote so we can minimi:e the number of reference documents. Also, the Rationale shculd address the Finding of B&R awareness in addition to methodol-ogy being reasonable.

110. Line Item 198 - Should be revised to address the SDD and it is unacceptable for the review not be be performed because of a lack of transfer documents.

111. Line Item 199 - Should be updated based on the June 11 date.

112. Line Item 200 - Should be revised to address the specific concern on assumptions regarding Units 1 and 2 operational modes sad combinat-ions. A suggested re-wording of the evaluation is:

"The review of the existing analyses (and assumptions) is scheduled for completion by September 30, 1982.

Changes to the design or other engineering follow on activities resulting from the review will be accomplished as a normal engineering design activity".

f10

t J.a, . . .

113. Line Item 201 - Should be re-reviewed as to whether Bechtel can conclude by evaluation whether there is a problem with hydrogen at the top of the room.

114. Line Item 202 - Should be revised to address more clearly the Bechtel approach to calculations, since the referenced procedures provides '

codifying information rather than requirements.

115. Line Item 203 - Should be revised to delete the Seismic II/I discuss-ions. Also, Bechtel should address the concern of whether the access and maintainability has been significantly compromised.

116. Line Item 204 - Should be revised to include a reference to Appendix E.

117. Line Item 208 - Should be revised to add a statement on review of Westinghouse information during the transition is also occurring.

118. Line Item 210 - See co= ment #112.

119. Line Item 212 - Should be revised to delete the NUS ESAP discuss' ion, since the effort was not carried out.

120. Line Item 213 - Should be updated to include the recent DER on the sump pumps.

! 121. Line Item 214 - Should be revised to clarify the referenced EDP 4.33, f since it is not discussed.

• 122. Line Item 215 - See co= ment #119.  ;

l 123. Line Item 223 - Should be revised to address the " division of l

responsibility", as expressed by Quadrex.

t l

L l

l i

(

i-r l

A7o  :

t i

i 1

l i

- - ~ . - . . . .

. . . . . . . . . . . - . s. ~...

SECTION 4.7 124. Line Item 226 - Should be revised to more clearly address the Finding in that a major subcontractor (EDS) was not directly responsible for the FSAR section describing their work. The Bechtel position on their subcontractors should be given. Also, the thrust of the evaluation should be Bechtel procedures on keeping the FSAR current.

125. Line Item 231 - Should be revised to add a statement that the Finding critizing EDS and B&R interface is no longer meaningful.

126. Line Item 233 - Shovid be revised to clearly state whether the values are reasonable and acceptable in general to Bechtel.

127. Line Item 234 - Should be re-reviewed to determine if the evaluation can be 'a simple reference to the 4.5 Finding on the use of 10' Cone.

128. Line Item 235 - Should be revised to clarify whether a re-review of previous baseplate designs by the Bechtel computer program is to occur or just new work.

129. Line Item'236 - Should be revised to clarify whether the fact that EDS and B&R used different values is important (i.e., are both acceptable).

130. Line Item 243 - Should be revised to delete this level of detail, since it is not agreed to by EL&P as yet.

131. Line Item 246 - Should be revised since the EN-619 paragraph inplies that EN-601 Work Package will determine applicability of MEB-6, which is not exactly correct.

132. Line Item 250 - Should be revised to simply state that an issue on the B&R Site Review Board is no longer meaningful.

133. Line Item 251 - Should be revised to clearly state whether Bechtel agrees with the Finding.

134. Line Item 255 - Should be revised to delete the Seismic II/I plus it is not clear why an iten is being upgraded, since all were to be 4

Seismic I by BAR.

I 135. Line Item 257 - Should be revised to clearly state whether the i

- " definitive criterien" discussed by Quadrex will be in the Bechtel q documents.

l p

e_._......

SEC* ION 4.8 136. A general ce==ent is that the ALAEA Directive is referenced repeat-edly, so a schedule date for its issuance should be added to the first item in which it is referenced.

137. Line Item 266 - Should be revised to have the same response as 4.3.2.1(a) (See our Comment #27).

138. Line Item 267 - Should be revised to clarify if minimum qualificat-ions are in procedures.

139. Line Item 268 - Should be revised to add a statement concerning the Bechtel method of " proper fo11cv up".

140. Line Item 269 - Should bc revised to clarify that the current design meets Appendix I but there vill be a review of the need for filters including HEPA also. Also, provide a schedule or state it is not ticing sensitive.

141. Line Item 270 - Should be revised to clarify that all calculations receive the same review and that EDP 4.43 has codifying information.

142. Line Item 271 - Should be revised to clarify whether the NUS calcul-ations were required to be verified by B&R under their subcontract

.. arrangements.

143. Line Item 272 - Should be revised t'o add to the ratienale tha: this concern related to B&R personnel, which is no longer meaningful.

144 Line Item 273 - Should be clarified as to the scope of the " ongoing" work.

143. Line Item 274 - Should be revised to delete " spent resin transfer",

since this is an off nor=al ondition. Also, confirm the statement regarding updated zone drawings, since the FSAR has updated versions.

146. Line Item 275 - Should be revised to insert "recc==endations" after

". . . NUREG-0737".

147. Line Item 277 - Should be reviewed per our general comment on

" Status". Also, add a statement concerning the Bechtel method on selecting those areas chosen for ALARA review.

148. Line Item 279 - Shoul.d be revised to clarify that the B&R/RL&P re-tetie. did not co*;er test and inspection requirements.

149. Line Item 280 - Should be revised to clarify that the B&R/RL&P re-review did not cover electrical outlets.

A70

. . . ~ - . - . . . . . . .

l l

l 1

.150. Line Item 281 - Should be revised to discuss removable shielding in general, not just concrete block wall.

151. Line Item 282 - Should be revised to clarify the need for marked up P&ID's. If they are not required, then the item could be considered

" Resolved".

152. Line Item 284 - Should be revised to have " Design Criteria" as

" design criteria" or a reference to "in accordance with EDP 4.1".

153. 'Line Item 286 - Should be revised to include a reference to EN-604 l Work Package, if appropriate.

l 154. Line Item 287 - Should be revised to include a statement on calibrat-ion such as that made in Line Item 304 155. Line Item 288 - Should be revised to clearly state the Bechtel method i of making ALARA decisions. I 156. Line Item 289 - Should be revised to clarify the term "non-manual operational modes".

157. Line Item 290 - Should be revised to clarify whether the assumptions l are documented.

l l

158. Line Item 294 - Should be revised to clarify the "NUS Report". Also, provide a schedule or state it is not timing sensitive.

I 159. Line Item 297 - Should be updated to reflect current status of '

Westinghouse source terms.

• 160. Line Item 299 - Should be revised per Comment #152. Also, clarify whether the adequacy has been determined not acceptable or not reviewed as yet.

161. Line Item 305 - Should be revised, since the Controls writeup describes the EN-604 effort in more detail than the 604 paragraph.

162. Line Item 306 - Should be revised to include a statement that during Transition review these considerations were reviewed.

163. Line Item 307 - Should be revised to clearly state the Bechtel plan of action. Since the BTF assessed this item to be timing sensitive, the Team evaluation should either expedite the calculation review or determine that it is not timing sensitive.

164 Line Item 309 - Should be revised to clarify the 1st sentence as meaning a calculation was never done or whether it has not been transferred from B&R.

A1o

~a......

SECTION 4.9 165. The folleving general co==ents are on the format of each of these items:

a. .Since this secticn was not given unique Finding Numbers, an additional reference to page on which the item can be found should be given.

b. Place "Not applicable" after Referenced Questions, Related Findings. Quadrex Rating. BTF Category. BTF Line Item, and BIT Assessment.

c. The ISI. maintenance access, and ALARA access consider-ations should be described from a program viewpoint in the first Finding evaluation.

d. Either provide k'ork Package references or describe why they cannot be provided.

e. Com=itments to make plant changes to installed hardware should not be made unless the determination has been made that requirements cannot be met and the change has been discussed and approved by EL&P. A commitment to evaluate the need for the change is appropriate.

166. Finding 4.9.la - Should be revised to expand the Finding to a more full quote fre= Quadrex report rather than just " update". Also, note the TRD number is 4010PQ007. See Co==ent #165 c. above.

167. Finding 4.9.lb - Sheuld be revised to correct the TRD nu=ber and state what is meant by " project documents". Also, add a discussion on the concern that itens could be on both the exception list and the list that states 100% volumetric exa=ination is to be performed.

168. Finding 4.9.2a - Should be revised to differentiate between the other 4.9.2a. such as Part 1 and 2.

169. Finding 4.9.2.b - Should be re-reviewed, since it is cur understand-ing that the vertical vall plugs are for overpressure protection and were not intended for access.

170. Finding 4.9.2c - Should be re-reviewed, since it is our understand-ing that the supports were re-designed subsequent to the Quadrex review. If so, this fact should be added to the evaluation. Also, it is preferable to state that adequate aisle space is available rather than "no potential problem".

171. Tinding 4.9.2k - Should be revised per our Cec =ent #165 e.

f0

- - - _ . - ~ .

172. Finding 4.9.2n - Should be re-reviewed, since we are uncertain of the valve number provided by Quadrex (i.e., we believe the proper number is RC-047C). Also, it is our understanding that this was a model error and not a design configuration.

173. Finding 4.9.2o - Should be revised to clarify whether Bechtel criteria allow EVAC duct to be located under Radwasta piping. If it is allowed, then the iten is " Resolved".

174. Finding 4.9.2q - Should be revised to include a statement on whether Bechtel criteria are in existence to minimize this from occurring.

175. Finding 4.9.2r - Should be revised to indicate that it is a. preferred method of pulling the pump and disassembling it rather than risk

. damage to shaf t by laying it down in one piece. Thus, a taller crane is not necessary.

e t 9 A1o

DON 6% % g

• I

, p .~

bec: B. tex Bechtel Power Corporation 5a c '< c' -

5 U n'"

P.o.sonrise F. Lopez P. Trudel Houston.Teies 772s2 zies vite, ST-YB-HL-1053 July 16,1982 Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Attention: Mr. S. M. Dew Manager, Engineering

Subject:

South Texas Project Bechtel Job No. 14926-001 Interim Report Concerning Classification of Leak Detection System in the SIS / CSS Pump Cubicles -

File No. G12.123 Gentlemen:

Please find attached our interim report regarding the Classification of Leak Detection System in the $15/ CSS Pump Cubicles (IRC Item #123). We have concluded that this deficiency is potentially reportable under the requirements of 10CFR50.55(e), and 15tt the safety impact is indetermir. ate at this time. Our evaluation of the safety impact is scheduled to provide our response to HL&P by Marc" 11, 1983.

' Very truly yours, BECHTIL POWER CORPORATION R.L.Ro[s Project ngineering Manager b

RLR/PGT/WW/mh Attachment CC: L. J. Kelmeet (HL&*-), w/att. BECHTEL POWER CGPORATWN M. E. Sowc11 (HL&P), w/att. fECEIVID STP-RMS, w/ att. g m s w r m noco w ,n co n .

\

,PI 4218P/0517P

ww. .. . . ..

i 10CFR50.5S(e) INTERIM REPORT ON CLASSIFICATION OF THE LEAK DETECTION SYSTEM IN THE SIS / CSS PUMP CUBICLES

1. Potential Problem If a passive failure occurs in piping within an SIS / CSS puso cubicle, the potential exists to flood the affected. cubicle, the. overflow to the corridor area, then flood back into the other two redundant SIS / CSS cubicles. The following define the event that may result in a potential loss of ECCS capability:

A. Passive f ailure of moderate energy piping including SIS pump se'ai during ECCS recirculation is assumed to occur.

8. Pump cubicle sump level switches are non-!E Instrument Class IC-2 (FSAR 9.3.3.2.3 commits to " Seismic Category I").

Note: Instruments are not procurred at this time. IC-2 is defined as assuring structural integrity of the instrumentation is maintained after an SSE.

C. Pump cubicle radiation monitors are non-IE Instrument Class IC-2 (FSAR 3.(.1.2.3.3 commits to " Safety Related"). It is indeterminate whether radiation monitors will be able to discriminate between:

(1) 2 high source term fluid in the ECCS during recirculation -

without leake;c or (2) leakage from this system with lower source terms. Furthermore, radiation mc'.iters will not detect cooling water leaks. .

D. SIS / CSS pump cubicles do not have watertight doors to prevent 1-flow or outflow of water from corridors. Iten C above leads to the conclusion that the only reliable method of Cetecting leakage is the 1990 level switches; but Item E shows that crecit cannot be taken

' r these switches following a LOCA or SSE. Not defined at this

ime is the quantity of floodwater necessary to unacceptably degrade ether trains of SIS / CSS pumps, nor the flow rates from the various pipe breaks leading to the flooding conditior. B&R performed a calculation (7Q069NC100-C approved February 26,1978) that reviewed the consequences of flooding within a cubicle but did not evaluate flow into the corridor and subsequent flooding of other cubicles.

The extent and duration of the flooding cannot readily be determined fecm existing calculations and new flooding analyses must be performed. Therefore, the safety impact of the flooding is indeterminate.

All 4218P/0517P 1

. ...m.... .

1 , J .

l , .

l i

• I. Approach to Problem Resolution A. Since the sump level switches have not been procured at this time, a

" hold" will be placed on the level instruments (P&lD and instrument index) to ensure that the instruments are not procured until resolution of the flooding problem.

B. The flooding analyses of the SIS / CSS pump cubicles and adjacent -

areas will be performed as part of BPC's normal systems interaction analysis effort (hazards anal The results of this analysis will be available by March83, 1$ysis).

and will determine if unacceptable consequences could occur. Should unacceptable consequences be predicted, appropriate corrective action will be taken to correct the deficiency.

III. Status of Proposed Resolution l

The Radioactive Vent and Drain System P&lD is being reissued by BPC. The level switches will be pi.ced on hold. The instrument index will be revised prior to issue to place the switches on hold.

IV. Status of Corrective Action , ,

l The need for corrective action cannot be determined at tnis time. A final report with the conclusions of the safety analysis and a description of the corrective action, if any, will be submitted to HL&P by March 11, 1983.

l l

l I

i 1

4218P/0517P 2

~

\e adai [ i g, g hg 'a p ,

g . - .

9 The Light .

CompMy sou, ion tignting s: romer i:o. sox ivoo souiton,Texa,77001 (713)228-9211 SECHTEL POWER CORPORAir0N CECEIVED July 15, 1982

. ST-IceYB-0935 JUL 191982 Sni: z-6950 Pni t hrn/D4.19.1 *

• • tSTWfvt Docwon como' ,

Mr. R. L. Bogers Project Engineerirzy Manager Bechtel Power Corporation P. O. Bcx 2166 Ilouston, 'Ibxas 77001

Subject:

Werk Padage Ei-619 - Pcview of Draft Pe;crt Sotml TD%S P7nTrr FmlC GriEPlaTC 5"I'Icti Rat ST-YB-IEe0909 ST-lHeYB-0915

Dear Mr. Bogers:

Attached are ccrre.ts en the Generic Issues as presented in Appeniix C arxi Appendix D of W:rk Padage El-619, Draft Re;crt.

On July 13, 1982, prelir.inary versions cf these w i uts were diseassed with your representatives.

We again m-#.asi o our instru: . ions given verbally at all the rcetings on El-619 that our caments are to b3 censidered as "Tacstions" regardless of the phraseology used. ':he ragnitudo cf the revics coupled with a short tu:mround tiro precluded refining the cor. rents into prtrper gaestiens in all cases.

You are also requested to provide mi: rates of all reetings between F.IAP and BPO wherein 124P ccrments on Ei-619 were diseassed.

We understarri that you are considering reiscaing the Draft Tinal Pcpert for ICAP review. If it is reissuod, we will ensure that our review occars in a tirely ruiner.

Very truly yours, b

S. H. Dew Manager, Engineering South Texas Project

'7 b h2.

$ Attachmnt W

.. c.1.ca . .>. ..

GE:NTRAL CCMEW CN GETRIC ISSLTS

1) S e possible bpressica in reading the Generic Issues section is that the Generic finding is " resolved" sclely because Bechtel has procedares in place that will either resolve now or renedy cr preclude the alleged deficiency. mis does net appear to be sufficient. 2 e report should sW.ze, in scr:e fashicm, the results of the actual review that has .

taken place to date and the plans for the otr:pleting such review. In addition, repart itens should rake clear how Bechtel has hardled any

, problens er suggesions identified in the Task Force Assessment. For exanple, under Sneric Finding 3.lb, the Task Ibree observed that the Quadrex ocmaern egarding tne frequency of errors in calealations "is bassi upcm a saall sanpling of cMculations; therefore, further analyses would be regaired to assess the seriousness of this finding." It is not possible to dete=ine fran the report what Bechtel has done omn-carning this subject and any conclusicns thereon. Bechtel shcrald provide such infomatica as described abcne, anf at least briefly c=:rnarize what has been fourd with respect to the Generic Finding to date and what will be done in the continuing effort.

2) me applicable part of ST-lCrY3-0507 (Fe;crt Ccrmant) should be addressed.

3) M:ve Generic Strmaries frun ige:xiix C to Appendix D.

4) Pcview "Fationale" to ensure that all a e iate r Disciplira Findings are referenced.

t 6er.2.;121C C3fC?TS CU GWJC FUCHES APPECIX C Finding 3.la Is spatial couplL% diseassed twice?

Mdress specifically the level of review ard validity of the findi.g.

Finding 3.1b: Iddress Oaad:cx Part 1 cf 3.1B. Address A calational errers (Oaairex Part 2) of 3.lb. Address the overall philosophy en verder report review and guidance to verxier.

De Bechtel project tea:n did rot address the Oaadrcx finding in a meaningful rnanner.

Finding 3.le Address remal plant cgerations design basis.

Finding 3.1d: Maress the deficiency if any of a sharp distinc* don of safety zulated verras non-safety related. Has Bechtel identi.fied any design features that were reqaired to be safety-related that BliR had not so identified.

Finding 3.le: Were written guidaHnes required? Was dCCJmented evidence that single failure critaria had knen satisfied reqaired? If so, in what fcnn?

Finding 3.lf: Was documented evidenco...FSAR c:rimitnants...being im-bL

.W

, a s ,

4

.g piemented in design regaired?' If so, what for:n? Was B&R deficient in i plsnantation? ' Was FSAR out cf date with respect to a) out of control, b) too sicw, c) unsatisfactc2.y (unacceptable)?

r -

Finding 3.lg - Was docater.tation of rationale of engineering j$. d.

used in establishing plant' design basis necessary or required? Was inter-discipline docurrentation ofinterface design information recuired to be

• doctanented in design manuals or individual log books?

Finding 3.1I - Bechtel's scope of service naast be described in short form to address the "majcr subenntractor. interface" a:noern.

3.1j - A&'. mss er referarce the resolution of the " design verificaticn".

1

\

s. i t 3 v

\

J J

6

\

6 I

I l

. N72.

s

. _ _ _ - - .~

h...

p ' * *' 7 .., UNiitD stalts

[' .1 ..

• NUCLEAR REGULATORY COMMISSION

. 748 GION IV

• ** ** Y ,f

- (,11 RV AN PL AFA OfilVI Sullt 1000 k, ,/ AHLING10N.1t X AS 7(01)

August 11,1982 Dockets: 50-498/82-02 50-499/82-02 Houston Lighting and Power Company ATTN: G. W. Oprea , Jr. ,

Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Messrs. D. D. Driskill and J. E. Gagliardo of our staff during the period February 5, 8-12, March 11 and 19, 1982, of activities authorized by NRC Construction Permit CPPR-128 and 129 for the South Texas Project, Units 1 and 2.

Areas examined during the investigation and our findings are discussed in the investigation report transmitted with my letter of June 3,1982. In my June 3,1982, letter it was noted that two potential violations of 10 CFR Part 50.55(e) had been identified during the investigation. The letter further stated that a Notice of Violation would be sent under separate cover addressing the apparent violations.

The enclosed Notice of Violation identifies the apparent violation discussed above. You are required to respond to this violation, in writing, in accord-ance with the provisions of Section 2.201 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the enclosed Notice of Violation.

The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

In accordance with 10.CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold infonnation contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1)., .

Q hs-k*5 ,,,,,m

-z# *

~. _

r-Houston Ligh' ting and Power Company August 11, 1982 i

Should you have any questions concerning this investigation, we will be pleased to discuss them with you.

Sincerely, J192W G. L. Madsen, Chief Reactor Project Branch 1

Enclosure:

Appendix A - Notice of Violation

)

l t

e'-

4 APPENDIX A NOTICE OF VIOLATION Houston Lighting and Power Company Dockets: 50-498/82-02 South Texas Project 50-499/82-02 Based on the results of an NRC investigation conducted during the period of February 5 through March 19, 1982, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C). 47 FR 9987, dated March 9,1982, the following violation was identified:

10 CFR 50.55(e) requires that the holder of a construction permit shall notify the Commission of each deficiency found in design and construction, which, if uncorrected could adversely affect the safety of plant operations. The regulation further requires that the holder of the construction permit shall notify the appropriate NRC regional office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the deficiency is found.

The following deficiencies were identified and reported by the applicant:

Date Initial Date of First Title Notification Interim Report

" Computer Program Verification" May 8, 1981 June 5, 1981

" Heating, Ventilation and Air Conditionino Design" May 8, 1981 June 9, 1981 Contrary to the above, these deficiencies which were found by the applicant on or about November 1980 and January 1981, respectively, were not reported to the Region IV office within the required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This is a Severity Level IV Violation (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, Houston Lighting and Power Company is hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Date: August 11, 1982 P. Als

. av ,2 nsu-ci i DA %9 -

_ _ _ . _ _ _ _ _ _ _ _ _ _ _ ._