ML20138H619

Intervenor Exhibit I-CCANP-88,consisting of Undated Viewgraphs Re Aspects of Brown & Root Design Process, Including Sys Level Integration,Review of Engineering Data & Plant Operating Modes Analysis

ML20138H619
Person / Time
Site:	South Texas
Issue date:	07/16/1985
From:	AFFILIATION NOT ASSIGNED
To:
References
OL-I-CCANP-088, OL-I-CCANP-88, NUDOCS 8510290103
Download: ML20138H619 (21)

Text

T

, gc sh as a c d . <.I' $

~

p> N  : " ~ '

1.e c n&V. (2 1l%lW cacve co i

eswc BER Systems Level Inteoration Thereisnoindicationthatasystems31tir~g'ratiIn'Snd overvl.ew function exists within the BER design process.

Plant arrangements, equipment layout, physical separation, system and equipment performance compatibility, access for maintenance and ISI, and other similar aspects can too easily be overlooked or missed with the present design review process.

(

EUCLEAR RfCULATORY COMMl3&lCN g --- fflelaf [sh, y, [ h[8

' ' ^ - ~

___Jcutlf f fD 4,, = w_

I I * '" * * * * ! _ _

,,,,,,,, 7 _

1 Cenl'g Qttr__ --~ Ril8 0Tl0 ^ - __.

St str _

.......,_rsi 8510290103 850716 PDR 0 ADOCK 05000498

( C p) d f '

[

PDR

i -

i j .

l,'

i.

!( '

! - B8R Review of Engineering Dato t

l The generic concern is in three parts; namely, i

! (1) Input data to a technical group does not appear l to be reviewed by that group for its reasonableness  !

i '

i prior to use (see Question'C-1).

i '

, (2) Calculations containing errors are being reviewed and approved as correct with a higher frequency l ,

I than should be encountered (see Question C-16) and

! (3) BsR review or vendor submitted reports is not j consistent; sometimes they are very well done, and at other times they are poorly done (see Question M-52). l l

l i

! ( -

1 i ,

)

i l

lT 4

o .

l i

l v n-.~,,- , -- n_ .._----..-,m,.,,_n n m., -,--,w.n, ,,n,. n,n.,,,,_.v.nn-,,..,.-.,,---r.-

'l

(

Plant Operatina Modes Analysis Thorough and consistent treatment of various plant operating F0 des Was not evident.

n, written design bases are provided to guide the designer in what combinations of events and plant modes must be considered. Consideration of degraded equipment performance was also not evident.

(1) HVAC outside containment was designed for normal plant operating conditions.

(2) Line crack analysis in IVC was done as a double ended break. ,

l

( (3) Pre-op test reautrements and test provisions missing, (4) Many top-level TRD documents were initiated in 1980 and 1981.

(5) Some SDD's modified in 1978 - 1979 for off-normal conditions.

. t t

Safety-Related vs Non-S/R Distinctions It was observed on many occasions that B&R uses a very sharp~ distinction between S/R and Non-S/R categorizations for both equipment and calculations.

In a number of cases, the B&R position was fe't to be .

either inaccurate or cuestionable. Examples include:

(1) No H.E. piping in the MAB (2) Shielding calculations are non-S/R (3) HVAC system upgrading I

I .

)

1 I

i o

I l

(

FEMA and Single Failure Criterion Analysis No written guidelines exist for the conduct of failure mode and effects analysis at BsR. The only FMEAs provided were those in the FSAR. The FSAR is not a design document and these FMEAs are too superfic'i'ol and are not adequate to assure a satisfactory design.

No guidelines exist on what types of failures should be considered for various types of equipment. There is no documented evidence that the single failure criterion has been satisfied. An HVAC/IEC single failure criterion violation has been noted (see Questions R-6 and E-15).

9 I

e _;

.el ,

(

FSAR Conmitment Tracking There was no evidence that individual FSAR comitments for. systems, equipment or calculations were being systematically implemented into the design.

There were many inconsistencies noted between the FSAR and other B&R design and procurement documents.

I There did not appear to be any method to asrure that timely updating of the FSAR was being accomplished.

(. .

i i

9 l

l l

l!

e f

(

4.1.2.1(a) BAR Structural Group does not appear to question the reasonableness of input data including margin (see Questions C-1 and C-4). Sor: of the environmental information that affected the Structural discipline has not become fixed even at this point in design (see Questions C-1 and N-3). .

e

(.

?

l

+

u

(

4.1.2.1(b) There was no evidence of Civil / Structural evaluation of the reasonableness of postulated

~

internal missiles or that the criteria for internal missiles presented in TRD IN209RQ013-A had bedri implemented in the design (see Question C-9).

( .

i

'l l

1 L ----- .

---

_---.------__-_.___.----_.-__._-.._--.-._--_-.___.._.-___..--._-._-_..-._._.._-.._-_-_-.--.----__._._.__.n._._. - . . _ _ . . _ _ _ _ . - _ . ,

(

14.2.2.1(a) Numerous programs are listed in the Program Status Sumory as having heavy usage on STP

- with no Comuter Program Verification Report (CPVR) in place (see Question C/M-3), .

l e

h

(

l 5

o 9

9

i i

4.2.2.1(b) Procedure STP-DC-017 does not require verification of non-safety-related programs; however, it is the project application of the code rather than the code itself that really determines whether a safety-related verification is needed. The basis used by BtR for determination of safety-related is not sufficient; for example, some safety-related calculations are not directly related

- to plant safety-related syster.s (see Question R-7). B&R's practice is not typical of industry proctice (see Question C/M-8).

(

s f

(

4.2.2.1(c) Because of the highly modular nature of most computer programs, it is not adequate to assume that an entire code is verified if a portion of that code has been verified (see Question C/M-13). The BsR CPVR does not indicate which options of a particular code have been verified.

f .

l

- t 4.3.2.1(a) The common instrument air line, as depicted in FSAR drawing 9.4.2-2 attached to Question R-6, does not meet the single failure criterion required by IEEE 279-1971 and 10 CFR 50 (see Question E-15). The occurrence of this design error in the late 1970's in concert with the B&R response to other single failure criterion questions suggests that BaR is not sufficiently experienced in the performance of a Failure Mode and Effects Analysis that crosses dis-cipline boundarles.Ill In most organizations, the IRC discipline would detect and innediately I

correct this type of design error by performing a rigorous examination of the separation provided between redundant divisions in the safety-related portions of the plant for all involved disciplines.

P I

(1) Instrument line blockage was identified as a potential I

i

concern for single failure analyses in the 1970 period when l an early BaW plant had three instruments connected to two  ;

j piping taps. Technicians repeatedly replaced the instrument connected to one top because it read differently than the 4

other two instruments connected in connon to the other tap; only later did they discover.that a blocked instrument line

! was causing the two comnon instruments to read erroneously.

-l t -

t .

4.4.2.1(a) The design bases are not well defined for safety-related HVAC systems. The plant operating modes and off-normal operating conditions of HVA_C systems were not adequately addressed (seeQuestionH-3).

L

.l (

l e

es 1

e -- - - , -

pa_p,_.,,,#-~p - , .- =,+w w-.,,. - -,epw-,wmy,,+my,,+ - - - .

~

(

i 4.4.2.1(b) The safety classification of HVAC systems is not traceable 'to " User" systems'(see

~

Question H-5). l 8

h a

i i

l l

l e

( .

4.5.3.1(a) No analyses have been completed at this time, and no moderate energy systems were

~

listed for evaluation. The proposed interaction matrix example does not oddress the essential aspect'si of potential targets or emphasize the types of interaction (see

. Questions M-3 ond M-5). A TRD is needed to identify the essential components (see Questions M-10 and M-25).

(

S I

1

i t

4.5.5.1(a) NRC Standard Review Plan criteria for active components requires that operability under

~

. simulated service conditions be demonstrated by testing or a combination of testing and analysis. Three possible concerns were noted (see Questions M-50, M-51, and M-52).

I e

U e

O

~ ' ' ' ' - - . . ,

f~

4.6.2.l(a) Nuclear Analysis did not control the use of temperature values issued for equipment design, nor is there any analytical basis for temperatures used outside of containment (see Question N-15).

The use of saturation temperatures rather than actual temperatures inside containment is not conservative in all cases as there has been no analysis performed to support the implied assumption that equipnent will not respond to actual temperatures. This approach is not in accordance with IEEE-323 which requires qualification to actual temperatures (see

(, Question N-1),

1 i

O

-- , .-, - , . - - - - , . . . , ,.,n. .. -- - , - . - -- ,.

.i .

I 4.6.2.1(b) There is an insufficient amount of environmental analysis in place, and those analyses previously done contained many errors. The only environ-mental analysis performed by~ BER contained a gross l error (see Question'A-13). Obvious errors were also discovered in an NUS analysis for inside containment (see Question N-1). The only NUS onalysis currently valid is the containment environmental analysis for a LOCA (see Question N-1).

' There is no currently valid mass energy release or environmental analysis for outside of containment (see Question N-3). The few onalyses previously performed were not for currently postulated breaks and/or contained errors (see Questions N-3 and N-13). Erown and Root was uncertain of any need to perform analyses for the high energy lines in the.ouxiliary building (see Question N-3). The failure to perfrom any valid environmental analyses outside of containment is untimely, and could possibly result in either retrofit in the auxiliary building or incorrectly designed equipment in the IVC.

f 4.6.2.1(b) continued A review of work performed by or under the

~

direction of the Nuclear Analysis Group indicates problems or the potential for problems in all areas analyzed, namely, environmental analysis, reactor-shield wall annulus pressuri-zation analysis, verification of release of environmental data, essential cooling pond analysis, and battery room hydrogen concentration.

Except for a containment heat sink surface areas analysis, and an NUS LOCA environmental analysis (see Question N-1), there were

' no analyses found that were sufficient, correct and current. Other analyses were either obsolete, insufficient in basis, or contained errors (see Questions N-1, N-2, N-8, N-10, N-11, N-12, N-13, N-15, N-17, N-19, N-23, and N-25)'.

( ,

14.7.2.1(a) BaR has not yet developed a criteria for let Iwingement protection on unbroken piping systems -(see Question P-20). A future TRD is planned.

)

e 0

i t i i

1 l

i~

\

4.8.2.1(a) The instrument air piping, between the '

valves actuated by redundant rediation monitors and the valves that divert air flow through safety-related filter trains in the i

FHB HVAC exhaust subsystem, does not meet the-single failure criterion (see Question R-6).

J 9

( -

I

c. .

e .

li  : -

. , , - . - _ , -_ - . . _- . . . _ .