ML20138A757

Forwards RB Hubbard 850927 Analysis of Facility Idvp,Per 851001 Conversation W/Gt Ankrum & Conversation W/R Hubbard. Sargent & Lundy Audit Failed to Confirm Adequacy of Current Util Design Activities

ML20138A757
Person / Time
Site:	Hope Creek
Issue date:	10/01/1985
From:	Thurber J NEW JERSEY, STATE OF
To:	Milhoan J NRC
References
NUDOCS 8510110005
Download: ML20138A757 (10)

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. state of Netu ilersey DEPARTMENT OF THE PUBLIC ADVOCATE DIVISION OF PUBLIC INTEREST ADVOCACY CN 850 TRWON, NEW JERSEY 086M

, Alfred A. Slocum RCHARD E SHAPIAO 1 6 DIRECTOR COMMISSIONER TEL 609-292 1693 October 1, 1985 Express Mail t

i Mr. James Milhoan Mail Stop E-W-S 305B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Re: Hope Creek Generating Station Independent Design Verification Program

Dear Mr. Milhoan:

I Pursuant to my conversation today with Mr. George T.

Ankrum and your conversation with Mr. Richard Hubbard of  :

i MHB Technical Associates, enclosed is a copy of Mr. Hubbard's analysis of the Hope Creek Independent Design Verification l Program.

Sinc ely y r 1

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O N P. THURBER oistant Deputy Public Advocate Encl.

cc: Mr. George T. Ankrum (w/ encl.)

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TECHNICAL ASSOCIATES A A Q TECHNICAL CONSULTANTS ON i@99 Dale G. Bradenbaugh 1723 Hamilton Avenue-Suite K Rochard B. Hubbard San Jose, California 95125 Gregory C. Manor Phone:(408) 266-2716 September 27, 1985 FEDERAL EXPRESS John Thurber, Esq.

State of New Jersey Department of the Public Advocate Division of Public Interest Advocacy CN 850 25 Market Street Trenton, New Jersey 08625

SUBJECT:

Review of S&L Report Hope Creek Nuclear Station

Dear John:

Pursuant to your request, enclosed is a memorandum documenting my review of the S&L Report provided in response to Paragraph 17 of the Hope Creek Settlement regarding the IDVP. In summary, the S&L audit failed to confirm the adequacy of current PSE&G design activities for subject areas identified in the settlement. Rather, the requisite assurance is speculative in that S&L relies on " successful completion of the ongoing design actives" to provide reasonable assurance that the design is adequate and meets licensing requirements (p. ES-1).

Very truly yours,  ;

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$$6bclbbbv Richard B. Hubbard RBH:dg Enclosure i

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t i MEMORANDUM REGARDING

FINAL REPORT - INDEPENDENT DESIGN VERIFICATION PROGRAM I

HOPE CREEK NUCLEAR STATION 2

AUDIT BY SARGENT & LUNDY A. Background J

In Paragraph 17 of the Joint Agreement and Settlement (Agreement) between PSE&G and the Public Advocate relating to Hope Creek regarding the issues of " Management Competence" and " Environmental Qualification," it was agreed f that an Independent Design Verification Program (IDVP) would be conducted. The IDVP scope and conduct were set forth in the Agreement, as follows:

"( a) . . . .PSE&G will undertake an independent design verification program and as-built construction review (IDVP) with respect to Hope Creek. The IDVP criteria and requirements, the systems and components to be reviewed and the workscope document for the IDVP have been prepared by Multiple Dynamics Corporation, which has no previous contract relationship with PSE&G or Bechtel, and which completed the workscope document for p the IDVP as an independent consultant. The workscope document for the IDVP is attached hereto as Exhibit A and made a part hereof.

(b) The independent auditors selected to perform the IDVP are Sargent & Lundy. After evaluation of the Sargent & Lundy proposal for the IDVP, a copy of which proposal is attached hereto as Exhibit B, PSE&G agrees with the Public Advocate to have Sargent & Lundy expand the IDVP to include the Options offered by Sargent &

Lundy as approved by the NRC, with Multiple Dynamics Corporation to determine Option 2 - Sel'ection of other Systems for Verification. Sargent & Lundy will be

_ directed to emphasize new or unusual features at Hope l Creek in performing the IDVP, where appropriate. The parties agree that Sargent & Lundy will also conduct walkdowns of not less that six days to review the

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application of the PSE&G - Bechtel as-built verification program wi~hin the scope of the IDVP.

Further, Sargent & Lundy will randomly select six additional environmental qualification packages, within the scope of the IDVP, which shall be evaluated for compliance with design commitments, NRC licensing requirements, the Final Safety Analysis Report, and the document entitled " Environmental Qualification Summary Report" dated August 19, 1984. Sargent & Lundy will also review the pre-operational test procedures applicable to the systems within the scope of the IDVP.

(c) Sargent & Lundy shall provide a copy of its final report to the Public Advocate. A schedule for completing any modifications to Hope Creek that are recommended by Sargent & Lundy will be submitted by PSE&G to the NRC and the Public Advocate for modifications that PSE&G proposes not completing prior to fuel load and low power testing. The basis for proceeding without such modifications will be provided by PSE&G to the NRC for approval, and PSE&G will complete all items prior to fuel load and low power testing except for such matters as the NRC agrees need t not be completed prior to such time." j The purpose of this memorandum is to provide a brief review

of the largent & Lundy (S&L) report dated August 30, 1985 issued pursuant to Paragraph 17.

B. Conclusions And Recommendations The S&L IDVP identified a number of instances where the current design product could not be demonstrated as adequate including the hazards design and equipment qualification.

Further, the IDVP identified deficiencies in the design process in the areas of engineering calculations, design procedures, and FSAR control. However, the IDVP reviewers were willing to rely on the adequacy of numerous future activities. Such reliance may be misplaced. As fuel load approaches, as is true for the Hope Creek plant, a commitment is not sufficient. Therefore, it is imperative that S&L and the NRC develop appropriate methods to verify l

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the adequacy of the design activities planned to fulfill the commitments. Further, documents setting forth the results of such reviews should be prerided to the Public Advocate.

C. Discussion The S&L design review effort encompassed by the IDVP was extensive in that it involved a team of 120 people over a 6-month time period. The scope of the review addressed both the design process and the design product. The design product and process review addressed three safety systems as follows: high pressure coolant injection, automatic depressurization, and safety auxiliaries cooling. In addition, five common design hazard requirements were reviewed including high - and moderate - energy line break, fire protection, seismic interaction, shielding and radiological safety, and seismic analysis. While 159 valid observation reports (OR's) were issued by the IDVP, none of the OR were considered by the IDVP as safety significant and none resulted in design or hardware changes. A summary of the valid observations by design area and cause is presented in Exhibit II-3 ( attached), and a summary of the valid observations by design area and required action is presented in Exhibit II-4 (attached).

The major comments which were developed as a result of reviewing the S&L report are as follows:

1. Common Hazard Design: The IDVP reviewers concluded that "other than for radiological safety, the team was unable to draw definitive conclusions concerning design adequacy in the hazards area because work is still in process and additional documentation supporting design decisions is U

required" (p. II-8). If Hope Creek is to be ready to load fuel by the end of 1985, the preceding lack of design definition is surprising. S&L and the i

NRC should develep appropriate methods to verify the adequacy of the completed work.

2. Reliance On Future Activities: S&L placed heavy reliance on numerous future committed activities.

For example, the IDVP observed as follows (p.

II-23):

"The ongoing design activities include programs which BPC had in place prior to the IDVP or committed to as a result of the IDVP. These programs include the Load Verification Program for the structures; the As-Build Reconciliation Program for piping and pipe supports; the Reassessment Program for conduit, cable tray, and HVAC ducts and supports; the Instrument Setpoint Calculation Probram for establishing instrument setpoints; the Seismic II/I Review Program for assessing interaction of safety - and non-safety-related 1

equipment; and the Final Hazard Assessment Program for the high-and moderate-energy line break analysis. These programs cover the entire plant design and have been or will be enhanced to address all technical concerns and significant trends identified in this report."

Such confidence in activities yet to occur has not been demonstrated and, in fact, may be misplaced.

Further, S&L offerred no explanation to justify why these activities had not yet been completed (or at least complete enough to review). As for Item 1 herein, S&L and the NRC should develop appropriate methods to verify the adequacy of all future committed actions.

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3. Engineering Calculations: The IDVP identified a l

significant trend regarding "the need for

preparation of additional calculations or revisions to calculations in order to complete the analysis or substantiate the use of undocumented engineering judgement" (p. II-19). While the design appeared to S&L to be adequate, we believe that properly documented calculations are essential to establish a basis for any design activities occurring during the operating life of Hope Creek. Thus, the NRC should assure that by the time of full power operation, all design calculations must be properly documented.

4. Equipment Qualification: Records documenting the seismic and environmental qualification of safety equipment were inadequate and incomplete. For example, of 33 qualification packages reviewed, 27 valid ors were issued (p. II-5). Thus, the S&L review was not able to demonstrate the adequacy of equipment qualification efforts. Once again, future activities by GE and Bechtel are relied upon, as follows: (p. II-6)

.....the following commitments have been made by BPC or GE. GE has committed to a re-review of qualification documentation supporting the items identified in FSAR Table 3.10-3, "NSSS Essential Electrical Components and Instruments," and to a review of the adequacy of all safety-related local panel-mounted devices with respect to panel acceleration transmissibility. BPC has committed l to enhancing an ongoing program to verify that all l QF-classified electrical devices are qualified for moisture intrusion and to verify that all flange

! bolt designs are within code allowable stresses as l part of the As-Build Reconciliation Program."

5. Design Process Procedures: The IDVP concluded that "in-place procedures for implementing this design l process could be better defined to further ensure that the process is consistently and uniformly carried out" (p. II-22). We agree. S&L developed 31 valid ors based on the lack of procedures or a i lack of procedural detail (p. II-16). It is not only important that the process be formalized, as suggested by S&L, but the NRC's regulations set forth in Criterion 5 of Appendix B to 10 CPR Part 50 require such formality. Thus, the preceding

" informality" represents a regulatory violation.

6. FSAR Control: The NRC regulations require (see 10 CFR Part 50.57(a)] that a nuclear plant be incompleted in accordance with its regulations and the licensing commitments set forth in the FSAR before the NRC issues an operating license. The IDVP identified 24 ors regarding a lack of FSAR control where the design was not in agreement with the FSAR (p. II-18). An FSAR Configuration Control Program should be initiated to ensure that the FSAR and the plant design are in conformance. The results of the Configuration Control Program should be available for NRC review prior to NRC allowing the plant to become radioactive.

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Q 4 EaMbit 3 3 ValidOhmervation Resorts by Omaam Area and came Desip Area Cantees b W anemen. cal E, pment cava wt,s,.

l Cause l Svsarm s Piping Qualificatam Hazards Structural Electrical mentassen Teent I t.'noxumented Engineersng Judgment 3 (1) 3 (2) 8 (3) 13 (6) 31 (3) 6 (6) 8 (7) 67

) Design input Discrepancies 12 (8) 1 (9) 3 (IC) ii II (11) 21 (12) 10 (13) 3 (16) 63 Inaaequate Training -

6 (IS) - - -

Lack of Desagn Calculations 6 (16) 6 2 (17) 7 (18) 3 (19) 29 (2*) 6 (21) '

Inaaequate Review of Documents la (22)

- 69 7 (23) 3 (24) 3 (23) 20 (26) 7 (27)

Desyn Dxuments Tec%caib Inaceauate 5 (28) 61

13 (29) 6 ()S) 6 (31) I (32) 23 (33)

Inaaeq ate Internal Des.gn Procedures 3 (36) I (7) 55 7 (35) --

13 (36) 7 (37)

/ Non.Comphance est% intema: Proceoures 3 (38) I (7) 31 2 (39) -

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Es.n te rpre tseg Regmat.oes 3 1 (6 5)' - - -

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Eahibit 11-4 Yalid Otmervation Reports by Desesp Area and Required Action 1

Design Area Control Regaired Action and 4 and Mechanical Egaipment Civil / kutrv-l Affected Document System s Piping Qualification Hazards Structural Electrical mentation Total i

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', Reviston or Addition of Calcu:ations 10 (1) 10 (2) 10 (3) 7 (4) 43 (3) 3 (6) I (7) 39 i Revisien of Desip Criteria - - - 3 (3) -- -- -- 3 l Revision cf DITS 1 (9) -

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) Revis2on cf Specif cation 16 (23) 1 (29) - 2 (30) 1 (31) 1 (32) - 19 Revision cf Engineering List /

Data Sheet I (33) -- 1 (34) - - - - 2

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