ML20138J118
| ML20138J118 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/29/1985 |
| From: | Stanley L QUADREX CORP. |
| To: | Ashley R BECHTEL GROUP, INC. |
| References | |
| OL-I-CCANP-104, NUDOCS 8510290256 | |
| Download: ML20138J118 (9) | |
Text
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..yy.y Mr. Ramon L. Ashley Bechtel Power Corporation 12400 East Imperial Highway
. Norwalk, California 90650
Dear Mr. Ashley:
In response to your letter of February 12, 1982, Quadrex has reviewed the draft Bechtel Task Force Report, "An Assessment of the Findings in the Quadrex Corporation Report dated May 1981" and has prepared corrnents regarding accuracy and factual matters as reouested.
In addition, Quadrex has developed other comments for purposes of clarification where deemed important.
The Quadrex report presented the results of an engineering design review program that examined actual implementation of design criteria and licensing co-ritments into a variety of STP design output docu'nents as of March 1981.
Tne Beentel Task Force Report did not assess STP documentation; rather oral information from Quadrex, Brown and Root, and HL&P was used to develop the.
In many instances, these Bechtel assessments appear to
.Bechtel assessment.
reflect modified designs subsequently accomplished by Brown and Root rather than the actual state of design reviewed by Quadrex in March 1981.
Quadres comments regarding accuracy and factual matters are as follows:
COMMENT 1:
(a) page 1, Introduction, line 8 (b) page 1-3, Section 1.0, line 4 (c) page 1-3, Section 1.0, footnote (3) lines 6 through 10 Quadrex prepared all of the design review questions.
COV. MENT 2:
page 2-2, Section 2.1, aspect number 2 Ouadrex technical reviewers prepared their individual findings from late The Ouadrex Project Manager made an initial March through mid-April.
assignment of each individual finding into the ranking categories designated by HL&P, and reviewed these assignments with each Quadrex technical reviewer on two separate occasions in late April.
COMMENT 3:
(a) page B-1, line item 2 (b) page B-6, line item 10 (c) page B-13, line item 22 Quadrex did not see any evidence during the design review that appropriate factors were applied by B&R to account for the confidence level in the preliminary loading or environmental data.
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March 2, 1982 QUAOnEx Mr. R. Ashley page B-12, line item 20 COMMENT 4_:
Quadrex assessment for Question C-12 states that the plan for B However, Quadrex nas not analysis of the duct ring was acceptable.
reviewed the actual re-analysis itself.
page B-27, line item 4B COMMENT 5:
for The Bechtel evaluation statement contradicts a subsequent evalu line item.212 as to whether the B&R Design Assurance Group f
FMEA's prepared by the discipline groups or would prepare F i
Assignment of this responsibility within B&R appears to be stil Quadrex was concerned during the design review with the l ding FMEA's technical response from four B&R technical disciplines regarThis lack of re and postulated single failures to be considered.
h coupled with the obvious instrument line blockage postulated fai in the assessments of Questions E-15 and R-6, remains a major con page B-30, line item 53 C0". MENT 6:
Eechtel states that the B&R methodoloov is reat,onable (i.e., the irter-specifying)of general industrial staniards and allow stated in its assessment of Section 4.3.2.1(j), line item 59.
pret, etc..
page B-32, line item 57 COMMENT 7:
Quadrex t,tated that no basis or procedures were provided In the B&R response fo systems needed to assure safety system performance.
Question E-3, air-conditioning is used to illustra l
lations, and normal conditions for HVAC were not considered in the H is made.
safety classifications of HVAC systems were not traceable to Consequently, Quadrex contends that improved bases or p identified in to assure that the needed support systems will be com the E&R SDD's.
this position.
page B-32, line item 58 C0"NENT 8:
believes that the project-wide documented basis for plan design and environmental conditions should not be the FS Quadrey An HVAC example of FSAR to RCFC specification deviat In addition, the illustrated in the Quadrex assessment of Question H-11.
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i t as noted environmental conditions for component qualification were def 2 N-13, in Quadrex assessments for Questions N-1,\\ N-3, N-4 i
d assessment N-14, N-IS, N-174 and N-19.
not contain system operating temperatures as stated in the Qua Consequently, Quadrex has no evidence to s of Question P-1.
Bechtel evaluation of this line item. evaluation for line item r
QUACAEx March 2, 1982 Mr. R. Ashley C0v3.ENT 9:
(a) page B-35, line item 62 (b) page B-42, line item 76 (c) page B-50, line item 95 Quadrex questions whether the implementation of testing provisions should remain a low priority item for design.
In the Ouadrex assessment to Question H-7, testing requirements or criteria are not provided in the Quadrex cannot support B&R's statement for line item 95.
SDD's.
COMMENT 10: (a) page B-97, line item 187 (b) page B-99, line item 188 (c) page B-108, line item 204 Quadrex has major objections to the Bechtel evaluation for these items.
the quantity of analysis performed was low compared As of March 16, 1981, to the state of plant construction.
The reviewed analyses were in error Secondly, Quadrex did not and were not for currently postulated breaks.After finding errors in several re'use to review current valid analysis.
previous obsolete analyses, nothing could be gained by further review of Further valid comclete analyses outside of contain-other obsolete analyses.
Finally, on March 16, 1981, B&R Nuclear ment were not available for review.
Analysis Grouc did not identify high energy lines in the MAS or the need There ineir analysis despite considerable Quadrex verbal cuestioning.
were a number of other areas such as door positions, makeup water, M51V logic, for and control of analysis output in which the B&R Nuclear Analysis Group was not knowledgeable on March 16, 1981.
A rajor rationale in the Quadrex ass'essment was the state of analysis relative.to the degree of plant construction and the lack of a schedule for future analyses.
COMMENT 11: page B-106, line item 200 In acdition to the ouestion of initial conditions, B&R did not address At this simultaneous shutdown of both units in the reviewed analysis.
time B&R verbally dismissed this from being a safety issue.
COMMENT 12: page B-115, line item 215 Quadrex asked four separate B&R disciplines for their list of postulated No such list was single failures to be considered in FMEA evaluations.
Quadrex main-provided during or subsequent to the design review period.
tains that no such evidence was available in March 1981 to support tne present Bechtel evaluation.
In addition, the following comments are provided for clarification:
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83UAQ84 E X March 2, 1982 Mr. R. Ashley page 1-6, Section 1.0, footnote (4) lines 2 and 3 i
COMMENT 13:
No difference in the Most Serious Finding definition was intended by Quadrex.
page 2-6, Section 2.2, last item prior to Section 2.2.3
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COMMENT 14:
This Bechtel statement may be misleading to the reader of the report.
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Brown and Root did not volunteer to present their overall design philosophy to Quadrex, nor did Quadrex request such a presentation 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), M-2(B&R), M-4(B&R), P-3, R-1, and However, within the first ten days of the March 1981 design review j
program, the overall B&R design philosophy became quite evident.from R-3.
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their answers to specific questions.
1 COMMENT 15: page 3-2, Section 3.3, last paragraph The scope and extent of the Quadrex prepared question set went well beyond the scope of potential problem areas identified by HL&F to Quadrex prior to 4
A significant number of the Quadrex prepared questions January 19, 1981.
were directed toward frequently encountered problem areas observed in earlier PWR and BWR plants to see if Brown and Root had taken advantage of By mutual agreement, previously identified l
these learning experiences.
STP problem areas that were being formally addressed by B&R w'ere, for the most part, excluded from the Quadrex design review effort.
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COMMENT 16: page 3-3, Section 3.4, first haragraph It is not c15ar whether Bechtel's statement concerns the technical cb I
of the finding, its assigned ranking category, or both, Quadrex believes that it is important that differences between industry and NRC criteria be recognized and acted upon by the responsible designers (Ques-j It is also important that FSAR comitments be reflected in the tion C-5).
design output (Question C-20).
Finally, it is important that appropriate J
The Quadrex finding i
methodology be used in the analysis (Question C-43).
endeavored to convey these specific aspects.
j COMMENT 17_: page 3-3, Section 3.5 The particular technical disciplines to be reviewed were chosen by HL&P 1
Participation of the B&R as illustrated on page 1-2 of the Quadrex report.
Design Assurance Group and the B&R Licensing Group in the design review During the program was not explicitly excluded by either Quadrex or j
outputs for implementation of design criteria and FSAR comitments that would typically be the responsibility of these two B&R engineering groups.
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oumomax March 2, 1982 Mr. R. Ashley COMMENT 18: page 3-4, Section 3.6 Throughout the March 1981 design review meetings in Houston, Quadrex was never informed that other key B&R individuals were unable to participate sufficiently in the meetings.
Actual B&R participants in these meetings All 2-2, 2-5, 2-7, 2-8, and 2-10 of the Quadrex report.
are shown on pages of the individuals outlined in the B&R organization chart shown on page 2-11 of the Quadrex report attended the meetings affecting their technical disciplines.
COMMENT 19: page 3-4, Section 3.8 In a number of instances, Quadrex requested to see definitive plans and schedules for the correction of identified problem areas, but was never One pertinent example of a given any B&R plans or schedules to review.
Quadrex request is provided in the Quadrex assessrient of Ouestion N-1.
COMMENT 20: cages A-1 through A-27 Generic findings presented in Section 3 of the quadrex report are derived from the individual technical discipline assessments provided in Section 4 and Vclumes II and III of the Ouadrex report.-
In the Introduction of the Sechtel report, their assigred task was "to review the Quadrex report and prepare an assessment of the Quadrex findings.".
However, in the Bechtel evaluation of the Quadrex generic findings contained in Exhibit A, very little. information is orovided regarding Eechtel's evaluation of Brown and Root relative to the generic findings at the time of the March 1981 design review.
The majority of the Bechtel evaluaticns state how Bechtel will address these generic findings in the future.
Quadrex does not believe that this approach is responsive to the assigned task.
COMMENT 21: (a) page B-3, line item 6 (b) page B-34, line item 61 (c) page B-93, line item 181 Quadrex based its finding on how effectively the B&R procedure for addressing new NRC requirements was being imolemented into design output documents; however, Bechtel's evaluation is based solely on the fact that Evidence provided by B&R to Quadrex such a procedure exists at B&R.
indicated that the actual implementation of the B&R procedure needed considerable improvement.
COMMENT 22: (a)pageB-4,lineitem7 (b) page B-56, line item 112 Quadrex observed that B&R applied the unverified 130 Kips inout load in a different manner' than EDS had specified, and could not obtain a suitable i
l justification for the B&R approach.
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GUAD81 TEX Mr. R. Ashley March 2, 1982 COMMENT 23: page B-22, line item 40 Quadrex assessment of Questior; C/M-8 indicated that some of the five permitted options are clearly preferable to others, and that no guidance was given to the user on how this selection should be made in specific cases.
COMMENT 24: page B-29, line item 50 Bechtel's evaluation statement that B&R's approach is consistent with Bechtel's experience for identifying needed top-level documents ignores the fact that several rather important TRD's, such as safety-related classification, ISI, and environmental qualification, were stil.1 not issued for STP in March ~1981. Quadrex found no evidence to justify why these documents had not been identified and prepared at the beginning of the design effort in the mid-1970's.
COMMENT 25: page B-31, line item 54 The Quadrex finding did not suggest a single comprehensive list but rather a top level criteria document that would provide direction and guidance for tne many different lists and documents to'be generated during the design phase.
' COMMENT 26: page B-34, line item 60 B&R stated to both Bechtel and Quadrex that meeting the single failure criterion was sufficient to assure safety system performance.
Quadrex contends that this simply is not sufficient, and would expect to see either additional requirements regarding quality (as Bechtel suggests) or an acceptance criteria for the vendor reliability calculations.
Quadrex did not mean to suggest that the specifications should include reliability figures.
The specification did require that reliability calcu-lations be provided to B&R, and Quadrex was looking for the acceptance criteria by which the calculations would be judged.
COMMENT 27: page B-47, line item 89 Quadrex was informed by B&R that air flow evaluations assuming open doors, etc. were not performed at the time of the design review.
Quadrex did not obtain information from S&R that would assure that the resultant air flow direction would continue to be from clean to dirty areas.
COMMENT 28: (a) page B-59, line item 116 (b) page B-73, line item 141 At the time of the design review, a draft TRD for In-Service inspection was i
reviewed by Quadrex.
The results of this review are presented in Section 4.9 l
of the Quadrex report.
Many operational problems were identified in this section of the report.
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' March 2, 1982 Mr. R. Ashley COMMENT 29: page B-73, line item 142 Quadrex was informed that the Teledyne analyses were for the IVC, and that other pipe rupture analyses had not yet been performed by B&R.
COMMENT 30_: page B-86, line item 167 Bechtel's evaluation completely overlooks the specific Quality problems delineated by Quadrex in the B&R review of a number of vendor reports Quadrex does not agree that B&R's review methods at the time of the desian review were reasonable based on the Quadrex a and analyses.
of Questions M-30, M-41, M-49, M-50, and M-51.
COMMENT 31: page B-86, line item 168 Quadrex does not agree that preliminary non-safety-related calculations using unverified computer codes are satisfactory for sa Bechtel's evaluation appears to related and use verified computer codes.
conflict with our understanding of 10 CFR 50 Appendix B.
COMvENT 32: page B-88, line item 171 Quadrex also Quadrex, rather than B&R, initially identified this error.followed would be taken.
COMMENT 33: (a) page B-96, line item 185 -
(b) page B-109, line item 205 there was no evidence of sufficient ar,alysis to suppo-t On March 16, 1981, SDD 4E010EQ004-A.
COMMENT 34: page B-104, line item 196 A double ended break analysis (particularly one using steam with enthalpy of 1306 BTU /LB and RELAP3) in a large building has no relation to results using a crack break which is the FSAR break co=itment.
COMMENT 35: page B-108, line item 203 The Bechtel evaluation recardina cost effectiveness is impose constraints on implementation of future design requirements.
C0t* MENT 36: page B-117, line item 218 16, 1981.
"Near Break" guidelines for valves were not presented on March
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sk ps GUADAEX March 2, 1982 Mr. R. Ashley COMMENT 37: page B-128, line item 234 half cone angle approach yields conservative U
Quadrex concurs that the IO loads; however, it is not conservative from the standpoint of defining potential targets that may be impacted from sub-cooled flashing water jet effects.
COMMENT 38: page B-147, line item 262 A reviewed B&R document had used SSE SAM loads, but B&R stated to Quadrex that these loads were not to be considered.
COMM yi 39: page B-149, line item 267 1
Quadrex believes that B&R's practice of placing ALARA reviewer resumes in a file may not be adequate, and considers it prudent to define the basic qualification requirements for an ALARA reviewer in view of the importance placed on ALARA in plant design.
COMMENT 40: (a) page B-152, line item 271 (b) page B-165, line item 298 Quadrex was concerned with B&R statements during the review meetings that certain work performed by other organizations, including NUS, was considered to be " foreign data" and was presumed.to bs correct upon receipt.
C0"F,ENT 41: page B-153, line item 274 As pointed out at the time of the Quadrex review, one of the major concerns
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was correlation of radiation zones with shielding design for accident conditions.
B&R had not addressed accident conditions.
We appreciate the opportunity to assist Bechtel in its preparation of this report, and will be pleased to resoond to any questions you may have regarding our Co1ments.
Sincerely, MN Loren Stanley Group Manager Consulting Engineering LS/bjk 1
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