ML20138H817
| ML20138H817 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/31/1985 |
| From: | Ashley R BECHTEL GROUP, INC. |
| To: | Lex B BECHTEL GROUP, INC. |
| References | |
| OL-A-072, OL-A-72, NUDOCS 8510290155 | |
| Download: ML20138H817 (33) | |
Text
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g, Disposition of Brown & Root CFFL :D*?; a November 24, 1982 and Quadrex Comments on t'?lhG T SW Task Force Draft Report 3AS F R. L. Ashley Job 14926-001 SFPD-Licensing Management o,
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E" D. W. Halligan 45/10/C33 8-0259 C "**
- W. A. Homer A. L. Cahn R. P. Schmitz H. D. Palmer The attached document presents the bases for disposition of the coments on the Task Force Draft Report that were received from Brown & Root (their letter of March 2, 1982) and from Quadrex (their letter of March 2, 1982).
Please note that in the document there are numerous instances in which a discrepancy exists between the location of certain comments in the draft report and final report. Since the draft report generally is no longer available, the location of the coment in the final Task Force Report has been identified parenthetically.
The Task Force met as a whole in developing its dispositions of the comrants. A draft was prepared and circulated for review. For various reasons final changes were made by the Task Force Leader who consulted individually with those members of the Task Force who had prime responsibility for developing the specific dispositions involved.
If the Task Force can be of further assistance to you please contact me.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON THE BECHTEL TASK FORCE DRAFT REPORT
'An Assessment of the Findings in the 4
Quadrex Corporation Report' I
November 1982 L.
DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition Quadrex prepared all of the design The text was revised in three 1:
(a) page 1, Introduction, line 8 review questions.
places, as noted, to acknowled e k
this comment.
(b) page 1-3, Section 1.0, line 4 (c) page 1-3, Section 1.0, footnote (3) lines 6 through 10 2: page 2-2, Section 2.1, Quadrex technical reviewers prepared During the Task Force meeting their individual findings from late with Quadrex, the Quadrex Team aspect number 2 7
March through mid-April. The Leader stated that he alone wrote Quadrex Project Manager made an the findings and did the rankings.
1 initial assignment of each He further stated that time did individual finding into the ranking not allow for review by the other categories designated by HL&P, and members of the review team.
t reviewed these assignments with Nevertheless, the Task Force Report each Quadrex technical reviewer was changed to accommodate the i
on two separate occasions in comment since, in principle, the matter wss not relevant late April.
i to the Task Force assessment of the findings.
4 1
3:
(a) page B-1, line item 2 6
Quadrex did not see any evidence This comment relates to line (b) page B-6, line item 10 6
during the design review that items 2, 10 and 22.
The basic (c) page B-13, line item 22 6
appropriate factors were applied thrust of these Quadrex findings by B&R to account for the con-is that design and construction fidence level in the preliminary in many areas were based on pre-loading or environmental data.
liminary loads. The Task Force s
a 1
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORLE REPORT Qurdrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition had assigned these findings into 3:
(a) page B-1, line ites 2 Category 6 for the following (b) page B-6, line item 10 reasons:
(c) page B-13, line item 22 (continued) a) The approach in question is commonly used in the industry.
b) Even though the loads are preliminary, calculations related to both generation of data and design for these loads are checked and verified.
c) As a general industry practice, these data are used judiciously, with the application of appro-priate factors depending on the confidence level associated with the loads.
d) Experience indicates this approach is practical and that little or no difficulty is encountered in final verification (i.e., minimal hardware changes).
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qu:drex Comments Comaent No.
Task Force and Location Category Comment Task Force Dispoei. tion The Quadrex comment indicates 3:
(a) pr.ge B-1, line item 2 they "did not see any evidence...
(b) page B-6, line item 10 that appropriate factors were (c) page B-13, line item 22 applied by B&R..." to account for (continued) the confidence level in the pre-liminary loads or environmental data. The Task Force statements above are general; the Task Force does not know if any factor was applied since an audit was not conducted. Nevertheless, the Task Force maintains that its assessments of the findings in question are appropriate both because of the reasons cited above and that no serious problems are expected.
Based on the above, no change was made to the Task Force Report.
page B-12, line item 20 6*
Quadrex assessment for Question The wording in the Task Force t-C-12 states that the plan for assessment for line item 20 was B&R reanalysis of the duct ring revised to acknowledge this was acceptable. However, Quadrex comment.
has not reviewed the actual re-analysis itself.
- as revised; previously 7 3
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4 DISPOSITION OF BROWN & ROOT AND QUADREX CONNENTS ON DRAFT TASK FORCE REPORT Qur.drex Comments Comment No.
Task Force i
and Location Category Comment Task Force Disposition 5: page B-27, line item 48 6
The Bechtel evaluation statement The assessments for line items contradicts a subsequent evaluation 48 and 212 were revised to for line item 212 as to whether the eliminate the contradiction by B&R Design Assurance Group would indicating that the Design review FMEA's prepared by the Assurance Group both performs i
discipline groups or would prepare and reviews failure modes and FMEA's itself. Assignment of this effects analyses. This is responsibility within B&R appears consistent with what the Task i
l to be still uncertain. Quadrex Force was told during the pre-l was concerned during the design sentation made by the Systems review with the lack of effective Design Assurance Group during l
i technical response from four B&R the Task Force meeting with j
technical disciplines regarding B&R. Furthermore, the Task FMEA's and postulated single fail-Force was told that the FMEA j
J ures to be consid: red. This lack preparation / reviews were to of response, coupled with the be initiated as a Phase II l
obvious instrument line blockage activity which had not postulated failure shown in the commenced at the time of I
assessments of Questions E-15 and the Quadrex review.
R-6, remains a major concern.
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-6:
page B-30, line item 53 6
Bechtel states that the B&R The Task Force believes it is methodology is reasonable (i.e.,
preferable and more expeditious i
the specifying of general to amplify and interpret certain j
industrial standards and allowing standards and etitaria (line vendors to interpret, etc.).
Item 59) to simplify the iterative 4
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l DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qundrex Comments Comment No.
Task Force and Location Categogy Comment Task Force Disposition 5: page B-27, line item 48 6
The Bechtel evaluation statement The assessments for line items contradicts a subsequent evaluation 48 and 212 were revised to for line item 212 as to whether the eliminate the contradiction by B&R Design Assurance Group would indicating that the Design review FMEA's prepared by the Assurance Group both performs l
discipline groups or would prepare and reviews failure modes and J
FMEA's itself. Assignment of this effects analyses. This is responsibility within B&R appears consistent with what the Task to be still uncertain. Quadrex Force was told during the pre-was concerned during the design sentation made by the Systems review with the lack of effective Design Assurance Group during technical response from four B&R the Task Force meeting with technical disciplines regarding B&R, Furthermore, the Task FNEA's and postulated single fail-Force was told that the FMEA ures to be considered. This lack preparation / reviews were to of response, coupled with the be initiated as a Phase Il obvious instrument line blockage activity which had not postulated failure shown in the commenced at the time of
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assessments of Questions E-15 and the Quadrex review.
R-6, remains a major concern.
4
[: page B-30, line item 53 6
Bechtel states that the B&R The Task Force believes it is methodology is reasonable (i.e.,
preferable and more expeditious t'ue specifying of general to amplify and interpret certain industrial standards and allowing standards and criteria (line~
vendors to interpret, etc.).
item 59) to simplify the iterative I
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i DISPOSITION OF BROWN & ROOT AND QUADREX l
COMMENTS ON DRAFT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 6: page B-30, line item 53 This seems to be contradictory to buyer-seller design / procurement (continued) the Task Force opinion stated in process (line item 53), but that its assessment of Section 4.3.2.1(j),
it is not incorrect to simply i
line item 59.
specify industry standards and NRC criteria as was generally done by B&R.
i Based on the above, no change was made to the Task Force Report.
7: page B-32, line item 57 6
Quadrex stated that no basis or pro-The Task Force notes that the cedures were provided to identify Quadrex comment does not directly support systems needed to assure question the assessment in line i
safety system performance.
In the item 57.
With regard to Quadrex l
B&R response to Question E-3, air-Question E-3, the Task Force did conditioning is used to illustrate review the B&R response and believes how this identification is made, that it sufficiently explains the However, in the Quadrex assessments B&R procedures of concern to for Questions H-3 and H-5, off-normal Quadrex. In addition, Quadrex conditions for HVAC were not con-questions H-3 and H-5 were sidered in the HVAC calculations, and addressed in line items 81 safety classifications of HVAC systems and 82 and the Task Force were not traceable to " user" systems.
concurs with Quadrex. The Task Consequently, Quadrex contends that Force further notes it had improved bases or procedures are already categorized these items needed to assure that the needed as Category 1.
support systems will be completely identified in the B&R SDD's.
Further-Based on the above, no change more, Bechtel's evaluation of line was made to the Task Force item 82 supports this position.
Report.
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DISPOSh'icN OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quodrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 8: page B-32, line item 58 6
Quadrex believes that the project-wide The specific Quadrex finding documented basis for plant operating which was assessed in line and environmental conditions should item 58 addressed the lack
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not be the FSAR since it is not a of a Project-wide documented basis design document. An HVAC example for plant operating and environ-of FSAR to RCFC specification mental conditions. As noted in deviations is illustrated in the the Task Force assessment, B&R had Quadrex assessment of Question H-11.
indicated that these conditions In addition, the environmental were documented in the FSAR.
conditions for component qualifica-Although Quadrex does not agree i
tion were deficient as noted in that the FSAR is the appropriate Quadrex assessments for Questions document, the Task Force believes N-1, N-3, N-4, N-5, N-8, N-10, N-12, it is not an unacceptable approach N-13, N-14, N-15, N-17, and N-19.
to utilize the FSAR.
Furthermore, approximately 50% of the SDD's did not contain system Based on the above, no change was operating temperatures as stated made to the Task Force Report.
in the Quadrex assessment of Question P-1.
Consequently, i
Quadrex has no evidence to support the Bechtel evaluation of this line item.
It should be noted that the Bechtel evaluation for i
line item 81 supports this Quadrex l
viewpoint.
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DISPOSITION OF BROWN & ROOT AND QUADREX CONMENTS ON DRAFT TASK FORCE REPORT guadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 9:
(a) page B-35, line item 62 6
Quadrex questions whether the imple-Quadrex's assessment of B&R's (b) page B-42, line item 76 5
mentation of testing provisions should response to Question H-7 did (c) p ge B-50, line item 95 5
remain a low priority item for design.
identify that some of the designs (page B-51 in final report)
In the Quadrex assessment to have included testing provisions.
Question H-7, testing requirements However, whether SDDs did con-or criteria are not provided in tain these provisions or not the SDD's.
Quadrex cannot support still remains an open issue to B&R's statement for line item 95.
be resolved by the Bechtel STP during their detailed review of the Project status.
The Task Force did not have sufficient information upon which to make a definitive conclusion in line item 95 and notes it had assigned this finding a Category 5, which a
leaves it for the Bechtel STP to resolve.
Based on the above, no change was made to the Task Force Report.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quedrew Comments Comment No.
Task Force and Location Category Comment Task Force Dispositi.on 10:
(a) page B-97, line 4
Quadrex has major objection: to the The wording in the Task Force assess-item 187 Bechtel evaluation for these items, ment for ifne item 187 was revised (page B-98 in final report) of March 16, 1981, the quantity to indicate that lack of time and (b) page B-99, line 4
of analysis performed was low com-availability of personnel did not i
item 188 pared to the state of plant permit Quadrex to review the updated-(page B-100 in final report) construction. The reviewed analyses and the schedule for those (c) page B-108, line 4
analyses were in error and were remaining to be done. The assess-item 204 not for currently postulated ment was also revised to indicate (page B-109 in final report) breaks. Secondly, Quadrex did not that follow-up discussions were not refuse to review current valid held due to lack of time.
j analysis. After finding errors in several previous obsolete The remainder of the Quadrex analyses, nothing could be gained comment represents their opinions by further review of other obsolete or judgments and is not in basic i
analyses. Further valid complete disagreement with the Task Force analyses outside of containment but rather presents another means were not available for review.
of expressing the concern that l
Finally, on March 16, 1981, B&R there is a potential problem.
Nuclear Analysis Group did not To this end, the Task Force had identify high energy lines in assigned this finding to Category the NAB or the need for their 4,
i.e., the Bechtel STP should 1
analysis despite considerable investigate this potential Quadrex verbal questioning, problem in a timely manner.
l There were a number of other I
areas such as door positions, Based on the above, no further makeup water, MSIV logic, and change was made to the Task contrel of analysis output in Force Report.
which the B&R Nuclear Analysis Group was not knowledgeable on i
March 16, 1981.
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l DISPOSITION OF DROWN & ROOT AND QUADREX l
COMMENTS ON DRAFT TASK FORCE REPORT i
i Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 10:
(a) page B-97, line A major rationale in the Quadrex item 187 assessment was the state of analysis (page B-98 in final report) relative to the degree of plant con-(b) page B-99, line struction and the lack of a scheaule item 188 for future analyses.
(page B-100 in final report)
(c) page B-108, line item 204 (page B-109 in final report)
(continued) 11: page B-lC6, line item 200 6
In addition to the questicn of The matters of initial assumptions (page B-107 in final report) initial conditions, B&R did not and the most severe Energency address simultaneous shutdown of Cooling Pond heat load were both units in the reviewed analysis.
addressed in the Task Force assens-1 At this time B&R verbally dismissed ment of line item 210. Therefore, this from being i safety issue.
no change was made to the Task Force Report.
!?: page B-115, line item 215 6
Quadrex asked four separate B&R Since Quadrex did not interview (page B-116 in final report) disciplines for their list of the B&R System Design Assurance postulated single failures to Group, which had the responsi-be considered in FMEA evaluations.
bility for the information
.No such list was provided during requested by Quadrex, the Task or subsequent to the design review Force believes that the basis period. Quadrex maintains that no of their finding and for their such evidence was available in March comment on the Task Force assess-1981 to support the present Bechtel ments may have relied on incomplete evaluation.
information. As a result, no change was made to the Task Force Report.
9
DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition No difference in the Most Serious Although Quadrex commented that 13: page 1-6, Section 1.0, i
footnote (4) lines 2 and 3 Finding definition was intended no difference in the definition (page 1-5 in final report) by Quadrex.
of "Most Serious" was intended, two slightly different definitions do exist in their Report. There-fore, no change was made to the Task Force Report.
This Bechtel statement may be The statement in the Task Force 14: page 2-6, Section 2.2, last item prior to misleading to the reader of the Report was recast to simply Section 2.2.3 report. Brown and Root did not indicate that there was no volunteer to present their overall review meeting at which the B&R design philosophy to Quadrex, nor overall design philosophy was did Quadrex request such a presen-presented to Quadrex.
tation beyond the specific discipline requests contained in Questions C-18, C-23, C-45, E-1, E-20, G-1, H-16, H-17, M-1(B&R),
N-2(B&R), M-4(B&R), P-3, R-1, and R-3.
However, within the first ten days of the March 1981 design review prog =am, the overall B&R design philosophy became quite evident from their answers to specific questions.
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DISPOSITION OF BROWN & ROOT AND QUADREX i
i COMMENTS ON DRAFT TASK FORCE REPORT l
Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition The scope and extent of the Quadrex The wording in Section 3.3 15: page 3-2, Section 3.3, last paragraph prepared question set went well was revised to place proper beyond the scope of potential emphasis on the Task Force problem areas identified by HL&P observation, i.e., the sampling to Quadrex prior to January 19, program may have resulted in 1981. A significant number of not presenting a balanced the Quadrex prepared questions picture of the STP design.
were directed toward frequently Furthermore, it appears to encountered problem areas the Task Force that may of observed in earlier PWR and BWR the questions were directed to l
plants to see if Brown and Root STP specific problem areas rather had taken advantage of these than "... toward frequently learning experiences. By mutual enccuntered problem areas observed agreement, previously identified in earlier PWR and BWR plants...".
STP problem areas that were being i
j formally addressed by B&R were, The last sentence la the Quadrex for the most part, excluded from comment is not consistent with the Quadrex design review effort.
either what was repeatedly told to the Task Force during its meeting with B&R, or subsequent i
documentation provided by B&R.
In both instances, it was clearly stated that many of the problems referred to in the Quadrex findings were being addressed by B&R (or they planned to do so).
It is further noted that the Quadrex i
Report only identifies one general area to be excluded from the review; i
namely, B&R design work in response i
to THI-2 issues.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qu;drex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition Based on the above, no change 15: page 3.2, Section 3.3, was made in the Task Force Report
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last paragraph to accommodate the matter addressed (continued) in the last sentence of the Quadrex comment.
It is not clear whether Bechtel's The text in the Task Force Report 16: page 3-3, Section 3.4, first paragraph statement concerns the technical was revised based on the information content of the finding, its in the first paragraph of the Quadrex assigned ranking category, or both.
comment to clarify that it was both some of the Quadrex findings and Quadrex believes that it is their rankings that were not fully important that differences between supported.
industry and NRC criteria be recognized and acted upon by the The material presented by Quadrex responsible designers (Question in the second paragraph of their C-5).
It is also important that comment is addressed below:
FSAR commitments be reflected in the design output (Question C-20).
a) Question C-5: The Quadrex Finally, it is important that assessment states that the apprcpriate methodology be used B&R response is adequate.
in the analysis (Question C-45).
The Quadrex finding endeavored b) Question C-20: This question to convey these specific aspects.
relates to the decoupling i
criteria used for dynamic analysis. The Quadrex assess-ment of the B&R response indi-cates that the B&R criteria are i
appropriate; however, their use of the criteria was unclear.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qundrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition When the mathematical models
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page 3-3, Section 3.4, 16:
first paragraph used by B&R were reviewed by (continued) the Task Force, it was clear that the criteria have been followed, even if it was not explicitly stated.
c) Question C-43: The Quad-a-assessment of the B&R response indicates that..."there may be some problem with the cask drop..."
The Task Force believes this statement is speculative.
Considering the above, the Task Force observed that, in thia instance the finding was not fully supportable by the informa-tion in Volumes II and III of the Quadrex Report. Furthe rmore,
no information was obtained during the Task Force meeting with Quadrex that would indicate othe rwise.
As a result, no change was made to the Task Force Report to accommodate the material in the second paragraph of the Quadrex comment.
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DISPOSITION OF BROWN & ROOT AND QUADREX CONNENTS ON DRAFT TASK FORCE REPORT l
Quadrex C u ents i
Comment No.
Task Force and Location Category Comment Task Force Disposition 7
i The particular technical disci-This comment states why the 17: page 3-3, Section 3.5 j
plines to be reviewed were chosen Licensing and Design Assurance by HL&P as illustrated on page 1-1 Groups were not interviewed by of the Quadrex report. Participa-Quadrex. Whatever the reason, tion of the B&R Design Assurance B&R and Quadrex did not discuss Group and the B&R Licensing Group the roles and responsibilities i
in the design review program was of these groups.
not explicitly excluded by either Quadrex or NL&P. During the Based on the above, no change conduct of the design review was made to the Task Force program, Quadrex examined numerous Report.
design outputs for implementation i
of design criteria and FSAR commitments that would typically be the responsibility of these two B&R engineering groups.
I Throughout the March 1981 design As related to the Task Force by 1
18: page 3-4, Section 3.6 review meetings in Houston, Quadrex B&R, there were numerous, con-l was never informed that other key current high priority Project B&R individuals were unable to activities that limited partici-l participate sufficiently in the pation of key B&R individuals 4
meetings. Actual B&R participants in these meetings. The Task in these meetings are shown on Force's experience would indi-pages 2-2, 2-5, 2-7, 2-8, and cate that any fully developed 2-10 of the Quadrex report. All nuclear plant design effort of the individuals outlined in would not be able to spare all the B&R organization chart shown of the necessary key individuals l
on page 2-11 of the Quadrex report for all of the time required J
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT i
Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition i
attended the meetings affecting by the review meetings in which 13: page 3-4, Section 3.6 (continued) their technical disciplines.
they could contribute.
Based on the above, no change 1
was made to the Task Force Report.
In a number of instances, Quadrex The Quadrex comment focuses on 12: page 3-4, Section 3.8 requested to see definitive plans schedules for corrective action and schedules for the correction whereas the Task Force statement of identified problem areas, but in section 3.8 dealt with the was never given any B&R plans or identification of the problems.
schedules to review. One pertinent The Task Force cannot attest example of a Quadrex request is to the existance of formal j'
provided in the Quadrex assessment schedule documents. However, of Question N-1.
in discussions with both B&R and HL&P, the Task Force was told that programs were either
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underway to resolve many of these items or rians had been developed to d<> so.
Based on the above, no change was made to the Task Force Report.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT I
guadrex Comments t
Comment No.
Task Force and Location Category Comment Task Force Disposition 2
Generic findings presented in Section The Task Force's method of 20: pages A-1 through A-27 3 of the Quadrex report are derived addressing the Quadrex generic from the individual technical disci-findings is delineated on page j
pline assessments provided in A-i.
The supporting rationale l
Section 4 and Volumes II and III for this process is presented
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of the Quadrex report.
In the on pages 7, 4-2 and 4-4.
In j
Introduction of the Bechtel report, essence, the particular approach their assigned task was "to review was selected not only since it l
the Quadrex report and prepare an would highlight typical Bechtel assessment of the Quadrex findings."
practices and procedures that would allow the concerns to be However, in the Bechtel evaluation accommodated, but also it would of the Quadrex generic findings avoid the repetition which would contained in Exhibit A, very little otherwise develop since most of information is provided regarding the generic findings are based i
Bechtel's evaluation of Brown and on specific technical discipline Root relative to the generic findings already addressed in findings at the time of the March Exhibit B.
Furthermore, the i
1981 design review. The majority Task Force believed that more of the Bechtel evaluations state benefit would accrue to the STP how Bechtel will address these from the approach taken than by i
j generic findings in the future.
using the same assessment and i
Quadrex does not believe that categorization process that was I
this approach is responsive to applied to the technical discipline the assigned task.
findings.
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Since the comment does not relate j
to accuracy or factual matters, l
no action is appropriate and no change was made to the Task Force Report.
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DI POSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qurdrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 21:
(a) page B-3, line item 6 6
Quadrex based its finding on how The Quadrex comment concerns (b) page B-34, 6
effectively the B&R procedure for the matter of effective imple-line item 61 addressing new NRC requirements mentation of B&R procedures for (c) page B-93, line 6
was being implemented into design addressing new NRC requirements.
Item 181 output documents; however, Bechtel's The Quadrex conclusion that (page B-94 in final report) evaluation is based solely on the actual implementation "needed fact that such a procedure exists considerable improvement" appears at B&R. Evidence provided by B&R to be a matter of engineering to Quadrex indicated that the judgment. The B&R Licensing actual implementation of the B&R Group, based on their presenta-procedure needed considerable tion to the Task Force, appeared improvement.
to be fully cognizant of licensing requirements and
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was providing the appropriate NRC information to the discip-lines. The Licensing Group l
presentation made specific note that implementation of j
design changes to accommodate new NRC requirements could not start until HL&P requested such i
action.
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Based on the above, no change i
was made to the Task Force 1
Report.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT i
i Qundrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 22:
(a) page B-4, line item 7 6
Quadrex observed that B&R applied the The Task Force assessment for j
(b) page B-56, line 7
unverified 130 Kips input load in a line item 7 was revised to item 112 different manner than EDS had accommodate this comment.
(page B-57 in final report) specified, and could not obtain a suitable justification for the B&R
. approach.
i 23: page B-22, line item 40 7
Quadrex assessment of Question C/M-8 The Task Force believes it is indicated that some of the five per-sufficient to establish mitted options are clearly preferable appropriate options for program to others, and that no guidance was verification. The actual selec-given to the user on how this tion from among these options 4
selection should be made in specific should be left to the discretion of the responsible engineer since cases.
he probably is the individual who j
is most knowledgeable about the l
problem to be analyzed.
1' Based on the above, no change i
was made to the Task Force Report.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quedrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 24: page B-29, line item 50 7
Bechtel's evaluation statement that The Quadrex comment is different B&R's approach is consistent with than their finding which stated Bechtel's experience for identifying that B&R did not have an overall needed top-level documents ignores plan to identify and develop all the fact that several rather key top-level TRDs. The Quadrex important TRD's, such as safety-cosusent clarifies that TRDs for related classification, ISI, and safety-related classification, environmental qualification, were ISI and environmental qualifica-still not issued for STP in March tion should have been identified 1981. Quadrex found no evidence and prepared early in the design to justify why these documents had effort. Although it may have not been identified and prepared appeared to Quadrex that at least at the beginning of the design these particular documents should effort in the mid-1970's.
already have been prepared, this is a matter of engineering judgment and does not neces-sarily conflict with the Task Force assessment concerning their need.
Based on the above, no change was made to the Task Force Report.
19
DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qurdrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 25: page B-31, line item 54 6
The Quadrex finding did not suggest a The Task Force interpretation of single comprehensive list but rather the Quadrex assessment of the B&R a top level criteria document that response to Question E-3 was that would provide direction and guidance the Quadrex reviewer expected to for the many different lists and find one comprehensive document.
documents to be generated during Furthermore, the Quadrex finding the design phase, appears to substantiate the desire to have a single document.
The Task Force believes that this information is not generally available in a single document but rather is found in several i
different documents.
Based on the above, no change was made to the Task Force Report.
20
DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qurdrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition
~~26: page B-34, line item 60 7
B&R stated to both Bechtel and Quadrea The B&R statement to the Task that meeting the single failure cri-Force concerning the single terion was sufficient to assure safety failure criterion should not system performance. Quadrex contends be construed to mean that they that this simply is not sufficient, ignored other quality considera-and would expect to see either tions. The Task Force agrees additional requirements regarding with Quadrex that application quality (as Bechtel suggests) or of the single failure criterion t
an acceptance criteria for the alone is not sufficient. However, l
l vendor reliability calculations.
the Task Force also believes that obtaining quality consistent with l
Quadrex did not mean to suggest that the intended service of a component the specifications would include does not necessarily imply a need reliability figures. The specifica-for incorporation in specifications tion did require that reliability of reliability figures and associated calculations be provided to B&R, acceptance criteria.
and Quadrex was looking for the acceptance criteria by which Based on the above, no change was the calculations would be judged.
made to the Task Force Report.
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DISP 0SITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAIT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 27: page B-47, line item 89 6
Quadrex was informed by B&R that air According to information providol (page B-48 in final report) flow evaluations assuming open doors, to the Task Force at its meeting etc., were not performed at the time with B&R, air flow would always of the design review. Quadrex did remain in the proper direction not obtain information from B&R (i.e., from clean to dirty areas),
that would assure that the resultant air flow direction would continue to As a result, no change was made to be from clean to dirty areas.
the Task Force Report.
2ft:
(a) page B-59, line 6
At the time of the design review, The Quadrex comment does not alter item 116 a draft TRD for in-Service Inspection the Task Force's assessments of (page B-60 in final report) was reviewed by Quadrex. The results the noted Quadrex findings. What (b) page B-73, line of this review are presented in is important in the Task Force's item 141 Section 4.9 of the Quadrex report.
view is that the TRD for in-service (page B-74 in final report)
Many operational problems were inspection be reviewed and its identified in this section of the adequacy assured. This is, in fact, the Task Force's action item for report.
line item 141.
Based on the above, no change was made to the Task Force Report.
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l DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT
}
Quadrex Comments j
Comment No.
Task Force and Location Category Comment Task Force Disposition 29: page B-73, line item 142 6
Quadrex was informed that the Teledyne Although the Task Force agrees with (page B-74 in final report) analyses were for the IVC, and that the Quadrex consent, B&R had per-other pipe rupture analyses had not formed sufficient evaluation to yet been performed by B&R.
establish that, due to the unique design features of STP, only r
three lines need be analyzed.
I Based on this, the Task Force
[
believes that the B&R schedule l
for performing these analyses starting in May 1981 was not unreasonable.
i 1
Based on the above, no change was made to the Task Force Report.
30: page B-86, line item 167 4*
Bechtel's evaluation completely The Task Force has revised both (page B-87 in final report) overlooks the specific quality its assessment and the assigned problems delineated by Quadrex category to accommodate the in the B&R review of a number of Quadrex comment.
vendor reports and analyses.
l Quadrex does not agree that B&R's review methods at the time of the 1
i design review were reasonable based j
on the Quadrex assessments of Questions M-30, M-41, M-49, M-50, and M-51.
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT l
guadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 31: page B-86, line item 168
. 6 Quadrex does not agree that prelim-The Task Force believes that the (page B-87 in final report) inary non-safety-related calculations intent of Appendix B of 10CFR50 using unverified computer codes are and even Appendix A thereof, is satisfactory for safety-related that the structures and components applications as long as the final required for safe operation of a calculations are designated to be nuclear facility should be safety-related and use verified designed to the best available computer codes. Bechtel's industry standards, which would evaluation appears to conflict assure their intended function-with our understanding of 10CFR50 ability. As to the case in point, Appendix B.
use of the computer code VENTSTACK (a program that has been exten-sively used for fossil plants) to obtain a preliminary estimate of the design load is considered reasonable.
Based on the above, no change was made to the Task Force Report.
24
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DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Catego ry Comment Task Force Disposition 32: page B-88, line item 171 7
Quadrex, rather than B&R, The Task Force Report was revised (page B-89 in final report) initially identified this error.
to delete mention of who discovered i
Quadrex also followed-up with the error.
B&R after its discovery to assure that corrective action would be taken.
1 3.1 :
(a) page B-96, line 4
On March 16, 1981, there was no The wording of the Task Force
~
item 185 evidence of sufficient analysis assessment for line item 205 and (page B-97 in final report) to support SDD 4E010EQ004-A.
Its assigned category were revised l
(b) page B-109, line 4*
to accommodate the Quadrex comment.
No change was necessary for line I
item 205 item 185 since the Task Force (page B-110 in final report) agreed with Quadrex that supporting analyses should have been initiat 41 carlier in the plant design procera.
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DISPOSITION OF BROWN & ROOT AND QUADREX CottfENTS ON DRAFT TASK FORCE REPORT Quadrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 34: page B-104, line item 196 4
A double ended break analysis (partic-The Task Force assessment for line (page B-105 in final report) ularly one using steam with enthalpy item 196 is assigned to Category of 1306 BTU /LB and RELAP3) in a large 4, indicating that timely Project building has no relation to results action is required to investigate using a crack break which is the the problem referred to in the FSAR break commitment.
Quadrex finding. Therefore, no change was made to the Task Force Report.
35: page B-108, line item 203 7
The Bechtel evaluation regarding It is the Task Force belief that (page B-109 in final report) cost effectiveness is not understood.
properly designed supports will not Seismic support will generally necessarily reduce access or impair reduce access, impair maintain-maintainability. The fundamental ability, and impose constraints issue represents a trade-off on implementation of future between providing Seismic Category I design requirements.
supports for non-safety related lines vs. providing the necessary protective measures in the event of failure of non-seismic lines.
The Task Force experience indicates that the former approach is acceptable.
Based on the above, no change was made to the Task Force Report.
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1 DISPOSITION OF BROWN & ROOT AND QUADREX l
CotetENTS ON DRAFT TASK FORCE REPORT j
Quadrex Coassents 3
4 Comment No.
Task Force j
and I.ocation Catesory Comument Task Force Disposition 1
36: page B-117, line item 218 5
"Near Break" guidelines for valves The Task Force assessment and its l
(page B-118 in final report) were not presented on March 16, 1981.
assigned category 5 appear to be appropriate; whether the guide-f j
lines were or were not available
[
s at the time of the Quadrex review is immaterial. Therefore, no i
f change was made to the Task Force l
Report.
E: page B-128, line item 234 5
Quadrex concurs that the 10' half The Quadrex finding for line (page B-129 in final report) cone angle approach yields conser-ites 234 only addresses the con-4 vative loads; however, it is not servatism of the 10' half-conservative from the standpoint expansion (cone) angle for jet of defining potential targets that load evaluation, and Quadrex concurs i
may be impacted from sub-cooled with the Task Force assessment of flashing water jet ef fects.
this aspect. The Quadrez concern
- l that this approach is not conserva-
'r tive from the standpoint of defining j
potential targets was not mentioned i-i in finding 4.7.2.3(j), which corres-l ponds to line item 234. Rather, that aspect was the subject of finding 4.5.2.l(s), line item 111.
j Based on the above, no change was l
I made to the Task Force Report.
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DISPOSITION OF BROWN & ROOT ?JiD QUADREX j
CortfENTS ON DRAFT TASK FORCE REPORT l
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Qurdrex Comments Comment No.
Task Force j
j and Location Catesory Comment Task Force Disposition 38: page B-147, line item 262 7
A reviewed B&R document had used SSE The wording in the Task Force assess-j (page B-148 in final report)
SAM loads, but B&R stated to Quadrex sent for line item 262 has been i
j that these loads were not to be revised to improve its clarity.
considered.
As a result, the Task Force did t
not make any further change.
I 39: page B-149, line item 267 7
Quadrex believes that B&R's practice There is no regulatory requirement (page B-150 in final report) of placing ALARA reviewer resumes that either establishes minimum in a file may not be adequate, and qualification requirements for an considers it prudent to define the ALARA reviewer or requires that r
I basic qualification requirements the basic qualification require-I for an ALARA reviewer in view of ments be defined. Therefore, the importance placed on ALARA in the Task Force believes that the i
plant design.
B&R practice is acceptable and 2
the Project Engineer or his equivalent, along with the appro-l l
priate technical discipline super-
[
visors, should be the ones to determine the acceptability of an I
individual for performing ALARA reviews.
Based on the above, no change was made to the Task Force Report.
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9 DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Quadrex Coeusents Comment No.
Task Force and I.ocation Catesory Coeusent Task Force Disposition 40:
(a) page B-152, line 7
Quadrex was concerned with B&R state-The Task Force, in developing item 271 ments during the review meetings that the assessments referred to by (page B-153 in final report) certain work performed by other Quadrex, only concerned itself (b) page B-165, line organizations, including NUS, was with NUS since they were the item 298 considered to be " foreign data" only organization referred to (page B-166 in final report) and was presumed to be correct in the referenced findings and upon receipt.
Quadrex assessments. As noted in the Task Force assessments of line items 271 and 298, NUS conducted their efforts as an extension of B&R, much in the same fashion that Bechtel staff per:onnel provide support to the projects while operating under the same basic set of Engineering Department Procedures.
Based on the above, no change was made to the Task Force Report.
29
9 DISPOSITION OF BROWN & ROOT AND QUADREX COMMENTS ON DRAFT TASK FORCE REPORT Qurdrex Comments Comment No.
Task Force and Location Category Comment Task Force Disposition 41: page B-153, line item 274 6
As pointed out at the time of the Line item 274, which is referred (page B-154 in final report)
Quadrex review, one of the major to in the comment, and its concerns was correlation of radiation corresponding Quadrex finding zones with shielding design for (4.8.2.1(c)) make no mention of accident conditions. B&R had not accident conditions. However, addressed accident conditions.
that subject is addressed in line ites 275 (finding 4.8.2.l(f)).
To that end, the Task Force was told by B&R that they were evalua-ting radiation zones considering TMI-2 experience.
Based on the above, no change was made to the Task Force Report.
30
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