ML20138J166
| ML20138J166 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/11/1985 |
| From: | Saltarelli E BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| OL-A-062, OL-A-62, NUDOCS 8510290275 | |
| Download: ML20138J166 (116) | |
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_D Houston Lighting & Power Company 1.uf 8 Wdl P.O. Box 1700 Houston, Texas 77001 1 3. W.L
- W Attention:
J. H. Goldberg
Subject:
South Texas Project, Quadrex Engineering Review, dated May 8, 1981
Dear Mr. Goldberg:
/
In response to your letter of May 6,1981, Brown & Root has reviewed the
" cost serious" items identified in the subject report to advise on whether tnese constitute a potential reportable problem in accordance with 10CFR50.55(e).
f All items have been judged by Brown & Root to be not reportable under 50.55(e) except for 4.4.2.l(a)/(b). This is sumnarized in Enclosure (1). Brown & Root is also evaluating potential reportability pursuant to 10CFR21.
The results of the review of all other items, including the rationale for judgement of non-reportability, is attached as Enclosure (2).
In reviewing the report prepared by Quadrex, Brown & Root had already taken action on the significant concerns before the Design Review commenced.
Brown
& Root also has technical disagreement with some of the findings and will respond accordingly.
In general, Brown & Root has no disagreement with most of the findings since they serve to provide verification of concerns we had already identified in the course of our Design Review program. Brown & Root wishes to emphasize that we have made and will continue to r. fake every effort to provide a well ' engineered design which meets all licensing requirements, as well as those requirements which will result in a plant that meets good power plant engineering practices from an operation and maintenance point of view.
In response to your requests on Item 2 of your letter of May 6,1981, Brown
& Root will submit a plan of action and schedule for responding to each of the items in the Quadrex report by May 15, 1981.
Based upon our initial review, Brown & Root has not found any problems which would justify issuing a stop work order in any construction area. This will be evaluated further when these items are reviewed in greater detail.
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- N 'J' N h May 8,1981 L
It is clear that if we concentrate our resources to respond to all these concerns on a first priority basis, there will be an impact on cost and schedule in Engineering. Attempting to quantify this cost and schedule impact is difficult because our experience in these matters shows that the ultimate resolution could require many iterations. We also question the rationale for responding to all of these items on a first priority basis to the exclusion of proceeding with an orderly design process.
We are caught in a situation where the majority of the issues will be judgemental while others are of little significance. We recomend we discuss this in greater depth before proceeding toomuch further to ensure that the program is in the best interests of HL&P.
Sincerely O
. seitereiii Senior Vice President &
Chief Engineer Power Group EAS/rj cc:
G. W. Oprea, Jr. (HL&P)
W. B. Pieper W. M. Rice J. R. Geurts K. M. Broom C. L. Buck J. L. Hawks J. R. Sumpter (HL&P)
C.
Robertson(HL&P)
D. G. Barker (HL&P)
J. W. Briskin (HL&P)
J. L. Blau (HL&P)
J. A. Signorelli O
ENCLOSURE (2)
SUfEARY OF BROWN AND ROOT FINDINGS ON SOUTH TEXAS PROJECT QUADREX ENGINEERING REVIEW (May 1981)
ITEM 4.4.2.1 (a)/(b) i i
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SUBJECT (d
Inadequacy of the following STP HVAC Systems:
MAB Fuel Handling Building EAB DESCRIPTION OF T iENTIAL PROBLEM On April 7,1980, Houston Lighting & Power (HL&P) infomed Brown & Root of a potential problem of cooling the Radwaste Control Room in the MAB.
A B&R study group was formed (Special Problem #16) with representation from the (B&R) Mechanical, Electrical, I&C, Structural, Nuclear Analysis and HVAC Disciplines. On September 18, 1980 a preliminary assessment concerning candidate areas for additional study was released. The candi-date areas included:
the electrical penetration space in the EAB; the radwaste control room, which contains the hot shutdown panel, the reactor make-up water pump cubicle, the boric acid transfer pump cubicle, the CVCS valve cubicle at elevation 41'-0" and 10'-0" in the MAB: the spent fuel pool cooling pump cubicles in the fuel handling building (FHB) and the valve cubicles in the FHB where containment isolation valves in dis-charge lines from the High Head Safety Injection, Low Head Safety In-jection and Containment Spray pumps are located. At this time a possible need for supplemental air cooled chillers to handle additional antici-pated (based on engineering judgement) HVAC loads were discussed.
From January 7,1981 thru January 27, 1981, calculations were infomally received from the HVAC group confiming the need for additional HVAC cooling capacity. On March 12, 1981, a draft report was issued by the B&R Special Problems Group which summarized the thermal environmental data which had been received and confirmed the need for supplemental cooling of the equipment described in Table 1 (Attached).
On March 19, 1981, representatives of QUADREX, under contract to HL&P, conducted a technical audit of B&R's HVAC System design and in a report received by B&R on May 7,1981, confirmed B&R's earlier assessment that there may be insufficient HVAC cooling capacity for equipment located in the MAB and FHB.
Although we do not yet have actual heat load data, including maximum allowable operating temperature infomation, for all potentially affected systems, we believe that there is currently sufficient uncertainty con-cerning the adequacy of the HVAC Systems designed for the MAB, FHB and EAB to consider the matter to be potentially reportable at this time.
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Brown & Root.inc.
APPROACH TO RESOLUTION ON A supplemental HVAC system composed of in-room fan-coil units and air cooled chillers is currently being considered for incorporation into the STP Units. Sketches showing proposed physical arrangements are currently being prepamd for candidate locations and additional thermal operating data is being sought from all equipment vendors.
STATUS OF PORPOSED RESOLUTION A final determination concerning the need for additional safety grade HVAC capacity will be completed upon receipt of the.following evaluations: pipe breaks outside containment (QUADREX Audit Question 4.4.4.1.a); and, special problem 16 (QUADREX Audit Question 4.4.4.1.b).
These evaluations will con-sider the equipment and piping heat losses and the maximum environment for which the safety related components are qualified. Without performing these evaluations we cannot detennine the exact magnitude of the impact on plant safety.
Based on these uncertainties, we feel that this problem is potentially re-portable under 10CFR50.55(e) and is currently being investigated as a potential 10CFR21.
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REASONS FOR FINAL REPORTABILITY DELAY _
Project Engineering had not completed sufficient themal calculations to indicate a clear need for a supplemental HVAC System.
PROJECTED COMPLETION OF CORRECTIVE ACTION The projected completion date for the following Special Problem #16 acti-vities is currently June 15, 1981 to have a definition of design qualification temperatures for safety related equipment, a preliminary assessment of heat losses and ama temperatures and a conceptual design and preliminary lay-out for a supplemental HVAC system.
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TABLE rs CANDIDATES FOR Nc.
AC SERVICE LOCATION EQUIPMENT REQUIRING EQUIP. QUALIF.
POST-ACCIDENT POST-ACCIDENT EQUIPMENT-TEMP CONTROL TEMP. F TEMPERATURE w/o HVAC, HEAT LOA 0 STATUS F (1)
Btu /hr Radwaste Control Room, H M nitoring Equip.
104 184 270,000 ON SITE 2
MAB Electrical Penetration Class lE Cables 120 1st Fl: 193 211,260 (3) 2nd F.: 204 251,940 (3)
Space, EAB (2) 3rd Fl.: 185 255, 620 (3)
Reactor make-up water Reactor make-up 120 195 61,000 Pumps Cubicle, MAB Water Pumps Spent Fuel Pool SFPCCS Pumps 120 268 66,300 Pump Cubicles, FHB Boric Acid Transfer Boric Acid. Transfer 120 197 42,000 a
Pumps Cubicle, MAB Pumps (4)
Ccnt. Iso. Valve Cont. Iso. Valves (5) 120 (later) 31,800 a
Cubicles, FHB B&R Valve Nos.:
(3 cubicles)
XSI 004A, B, C XSI 018A, B, C XCS 001A, B, C Valva Cubicles in MAB CVCS Valves used for 120 El. 10'-0": 150 33,400 a
(3 cubicles) boration (4)
El. 41 '-0": 150 38,400 B&R Valve Nos.:
XCV 218 XCV ll2C XCV 1138 XCV 1128 XCV 113A Elect. Aux. Bldg.
EAB Chillers (later)
(later)
(later) a Chiller Area (located in MAB)
Footnotes (see Page 2)
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- a Page 2 TABLE 1 - CANDIDATES FOR NEW HVAC SERVICE FOOTNOTES 1.
Calcualted environmental temperature in the cubicle or area when only safety related equipment is operating, and with no HVAC service.
2.
HVAC for this area has been identified as critical concern No. 11-5 (1979).
The equipment listed requires environmental temperature control during operating conditions.
3.
During normal operation, heat loads are:
1st Floor 81,200 Btu /hr.
2nd Floor 123,350 Btu /hr.
3rd Floor 121,400 Btu /hr.
4.
Capacity for cooling this area should be included when sizing the chiller.
However, since alternative methods of boration are available, no further design toward adding coolers should be performed until Westinghouse is appraised of the calculated cubicle temperatures, and the preferred boration method is identified.
5.
Requalification or replacement of the valve actuators are possible alternatives to adding HVAC Coolers.
Capacity for cooling these cubicles should be included when sizing the chillers.
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ENCLOSURE (1)
O BROWN & ROOT REVIEW 0F SOUTH TEXAS PROJECT QUADREX ENGINEERING REVIEW (May 1981) i
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ITEM NUMBER:
4.1.2.1 (a)
O DISCIPLIi.'E:
Civil / Structural AGREE WITH FINDiM4:
O DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _
_.O POTENTIALLY REPORTABLE __
_ _D INSUFFICIENT DATA FOR ASSESSMENT NOT REPORTABLE _ _._ _ _ _ _..
BASIS FOR ABOVE ASSESSMENT:
We have on many occasions rejected design inputs as unreasonable. No re-quirement exists for fonnal documentation of evaluation of other discipline's input.-
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ITEM NUMBER:
4.1.2.1 (b)
O DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
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j DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.O POTENTIALLY REPORTABLE _
__ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE-. _ _ _ _ _ _. D i
t BASIS,FORABOVEASSESSMkNT:
Generally agree with observation. However, disagree that Civil / Structural is required to do the evaluation. Currently, no data on internal missiles have been received.
Criteria for development of internal missile parameters is now being implemented under a controlled program in conjunction with the hazards analysis pregram.
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ITEM NUMBER:
4.1.2.1 (c)
O DISCIPLINE:
Civil /3tructural AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.. -.
_.O POTENTIALLY RF. PORTABLE _. _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTAE.E- _
_. G BASIS FOR ABOVE /SSESSMENT:
Civil / Structural Discipline have met the interaction requirements by doing static i)BC analysis for earthquake and analysis for tornado loading, showing T.G. Building sustains without impact on safety related items. Tornado loads are the controlling ones for the interaction evaluation.
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ITEM NUMBER:
4.1.2.1(d)
DISCIPLINE:
Civil / Structural i
i AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _
__D POTENTIALLY REPORTABLE _. - _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._
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BASIS FOR ABOVE ASSESSMENT:
We are unable to substantiate QUADREX statement that we are.not in compliance with SAR Conunitments and approved NRC Criteria.
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4 ITEM NUMBER: 4.1.2.1 (e)
O DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
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DISAGREE WITH FINDING: O i
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.O POTENTIALLY REPORTABLE
_ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- _
_ - _. G BASIS FOR ABOVE ASSESSMENT:
The recent NUREG's are not incorporated in design until they become project criteria. The 1.4 factor useo for RCB internal design is conservative and based standard review plan.
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ITEM NUMBER: 4.1.2.1 (f)
O oIScleLINE:
civiieStrecturai AGREE WITH FINDING:
C DISAGREE WITH FINDING: b 5-THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _..- _ _ _ _ _.O POTENTI ALLY REPORTABLE _ _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE -
- _._ _ _ _. G BASIS FOR ABOVE ASSESSMENT:
B&R is currently working on pipe rupture outside containment. B&R use of in-put data from EDS for pipe rupture load is adequate.
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ITEM NUMBER:
4.1.2.1 (g)
O DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
O DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
_.O POTENTIALLY REPORTABLE
_ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ _ _ _ _ _
.IN BASIS FOR ABOVE ASSESSMENT:
MAB dead loads are representative based on Engineering Judgenent. Al so,
these loads will be verified when all hangers are designed.
The amplification factors used in MAB floors has not yet been updated based on the latest MAB seismic analysis.
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ITEM NUMBER:
4.1.2.1 (h)
O DISCIPLINE:
Civil / Structural AGREE WITH FINDING:
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DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.._ _ _ _ _
_.O POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE-
_ _ _ _ _ _. B BASIS FOR AB0VE ASSESSMENT:
The loads on structural elements are preliminary.
Final verification cannot be done until all loads are available at this time.
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ITEM NUMBER:
4.2.2.1 DISCIPLINE:
Com uter AGREE WITH FINDING:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.. _ _ _ _
_.O POTENTI ALLY REPORTABLE _. _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _.
_. E BASIS FOR ABOVE ASSESSMENT:
Taken as a whole, the issue of verification of computer prugrams addressed by QUADREX does not present a problem of " breakdown of the system" but rather an exhibition of " weakness" in adherence to the verification procedures.
We concur, in the main, with the findings of the auditors which are very similar to the observations made by the B&R audit team. The ongoing B&R O,
program in response to the audit findings requires timely response to tne findings and will provide a much more thorough review of the status of the 4
individual computer codes used on STP.
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1 ITEM NUMBER: 4.2.2.1 (a)
O DISCIPLINE:
Computer AGREE WITH FINDING:
DISAGREE WITH FINDING: O
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THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.O POTENTI ALLY REPORTABLE _. _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE-
_ _. E BASIS FOR ABOVE ASSESSMENT:
Programs used on STP Design / Engineering should be verified. The ongoing B&R Nuclear Analysis Program is addressing CPVR Status in nisponse to an intemal B&R audit. The schedule for review is available. The preliminary assessment is finding procedural problems only.
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ITEM NUMBER:
4.2.2.1(b)
O DISCIPLINE:
Computer AGREE WITH FINDING:
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DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _
_.O POTENTIALLY REPORTABLE
_ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ - _ _ _ _. G i
BASIS FOR ABOVE ASSESSMENT:
Verification of computer programs used on the project should occur regardless of designation (" safety vs non-safety related"). By maintaining a distinction, the possibility exists such that the radiological environment "seen" by safety classified systems could be calculated by non-safety-related computer codes ---
and hence not verified codes---- with subsequent " safety related" impact.
O The definition / distinction should be addressed and resolved.
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ITEM NUMBER: 4.2.2.1 (c)
DISCIPLINE:
Computer AGREE WITH FINDING:
C
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DISAGREE WITH FINDING: O i
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _._ _
_.O POTENTI ALLY REPORTABLE._
__ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
._ _. U BASIS FOR ABOVE ASSESSMENT:
It is not sufficient to test only one of a codes features / options to attest to the adequacy of the capability of the whole computer code.
If a particu-lar option is to be used, that option should be " qualified".
The procedure could be more specific.
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ITEM NUMBER:
4.2.2.1(d)
DISCIPLINE:
Computer i
AGREE WITH FINDING:
C DISAGREE WITH FINDING: O i
i THIS ITEM IS CONSIDERED TO BE:
REPORTABLE... _ _ _ _ _ _.O POTENTIALLY REPORTABLE._ _ _ _ D l
INSUFFICIENT DATA FOR ASSESSMENTQ MOT REIORTABLE._ _ _. _
_ _. U BASIS FOR ABOVE ASSESSMkNT:
i The primary licensing docurnait (FSAR) and the program status sumary (PSS) should reflect actual coc. usage. The itemization of the codes in use re-quires further review.
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ITEM NUMBER:
4.2.2.1(e)
O DISCIPLINE:
Computer AGREE WITH FINDING:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.D POTENTI ALLY REPORTABLE _. _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _
- _. U BASIS FOR ABOVE ASSESSMENT:
Errors in the verification process can reflect the perceived importance of i
the verification by the reviewer and also the quality of the verifying pro.
gram in general.
Subsequent internal review " caught" the error, however, the process at applied to computer programs needs more stringent adherence.
The impact should be judged on a case-by case basis.
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ITEM NUMBER: 4.2.2.1(f)
DISCIPLINE: Computer AGREE WITH FINDING:
D In part, see below.
DISA&REE WITH FINDING: O Z
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _
_O POTENTIALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE - _ _ _ _ _. G BASIS FOR ABOVE ASSESSMENT:
" Engineering judgement" on interpretation of "significant" changes is too easily abused. Because of the complexity of computer programs, even "cos-metic" changes should mquire reverification.
A case by case assessment is required for impact.
Five options are given for verification.
An ordered prioritj may be desirable. As it stands, the procedure does not limit the process, but allows for more flexible application if needed.
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ITEM NUMBER:
4.3.2.1(a) (R-6)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
h Note 1.
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. - - _ _ _
.O POTENTI ALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _._ _
. W BASIS FOR ABOVE ASSESSMENT:
Installation details are not prepared, hence design is incomplete and not issued for construction. See 50-55(e) (1) (ii).
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.I ITEM NUPEER:
4.3.2.1 (b)
DISCIPLINE:
Electrical /I&C
[
AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. - - _ _ _
_.O POTENTIALLY REPORTABLE _.. _ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _ _ _ _ _ _ _
13 BASIS FOR ABOVE ASSESSMENT:
Requirements are included in separation requirements TRD and safety hazards analysis TRD. Other documents which address separation criteria are Z0003 and PE-005.
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ITEM NUMBER:
4.3.2.1 (c)
/
DISCIPLINE:
Electrical /I&C j ~ t AGREE WITH FINDING:
C 2
DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _
__O
, POTENTIALLY REPORTABLE __ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE._ _ _ _
_. W i
BASIS FOR ABOVE ASSESSMENT:
Listings of required TRD's for the project appeared in early versions of PRAME and other project scheduling and planning tools. This listing is dynamic in O
nature in that additions and/or modifications to the listing are made depend-ing on changing project requirements.
It is agreed that, in any large design effort, design decisions will be made for knich no documentation exists.
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ITEM NUMBER:
4.3.2.1(d)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _._ _ _ _ _
_.O POTENTIALLY REPORTABLE._
_ _ D INSUFFICIENT DATA FOR ASSESSMENT D NOT REPORTABLE- _
_ _. E BASIS FOR ABOVE ASSESSMENT:
1.
Criteria document ZQ-003 does contain separation criteria.
2.
Single failure criterion is identified in W P.I.P. for safety systems provided by W.
3.
DC-015 provides methodology for design verification process.
4.
5D-005 provides metnodology for design assurance review.
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ITEM NUMBER:
4.3.2.1(e)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C 2
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _
_O POTENTIALLY REPORTABLE _ _._ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
_ _. U BASIS FOR ABOVE ASSESSMENT:
Separation barrier design requimments appear in the separation requirements TRD's EQ-006, ZQ-003, and the safety hazards ar.alysis TRD for use by internal B&R disignees.
.)
Separation requirements for vendor-supplied components are included in the specification by referring appropriate NRC and IEEE guidelines and standards.
Adequacy is assured by the B&R review and approval process.
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O tTra auassa:
4.5.2.1 (f)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C 2
DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_O POTENTI ALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _ _
_ _ _.Iff BASIS FOR ABOVE ASSESSMENT:
Equipment clarification requirements and identification methods appear in procedure DC-010, TRD Z0-007 and procedure PE-005.
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i ITEM NUMBER:
4.3.2.1(g)
DISCIPLINE:
Electrical /I&C h
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AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _._ _ _ _ _
_O POTENTIALLY REPORTABLE _
_ _D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _ _ __ _
_ _. G BASIS FOR ABOVE ASSESSMENT:
Project procedures; SD-005 - Design Assurance 50-004 - Design Review DC-010 - Codification O
oc-ots - oes4 a ver4 <4catio#
9 PE-005 - Electrical Cabling Scheduling provide a systematic approach to implementation of FSAR comitments and design changes.
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ITEM NUMBER:
4.3.2.1 (h)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
_.O POTENTI ALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMEfGQ NOT REPORTABLE _. _ _ _ _ _ _ _, M BASIS FOR ABOVE ASSESSMkNT:
SD-005 (design assurance) and system design descriptions identify support systems.
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O Itta auasea:
4.3.2.1 (i)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
.O POTENTIALLY REPORTABLE._ _
_D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE 5
BASIS FOR ABOVE ASSESSMENT:
PQ-005 and EQ-004 provided project-wide basis for environmental conditions with the exception of pipe break analysis.
Program for identification and O
impact assessment for high energy line breaks outside containment is in pro-gress. Review program for high energy line breaks will be accelerated.
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O ITra NUMBER: 4.3.2.1 c3)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
b
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DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _. _ _ _ _ _
_.O POTENTIALLY REPORTABLE _.
_D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
_ _. G BASIS FOR ABOVE ASSESSMENT:
Certain engineering specification provisions and requirements grant the vendor
+
the latitude to adhere to applicable portions of regulations and standards.
O All such vendor actions and decisions are, however, subject to find B&R engineer-ing review and approval and documented in accordance with DC-004, " Foreign Document Processing and Control."
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ITEM NUMBER:
4.3.2.1(k)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
O l
i DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _..
_O POTENTI ALLY REPORTABLE _. _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE - _ - _
_. G BASIS FOR ABOVE ASSESSMENT:
Licensing, both HL&P and B&R, felt that IEEE 344-1971 plus the Branch Tech.
Position was equivalent to 344-1975, which is the FSAR comitment.
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ITEM NUMBER:
4.3.2.1 (1)
DISCIPLINE:
Electrical /I&C ACREE WITH FINDING:
DISAGREE WITH FINDING:
THIS 1 TEM IS CONSIDERED TO BE:
REPORTABLE _
_O POTENTIALLY REPORTABLE
_. _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE._ _
_ _ _ _.. W BASIS FOR ABOVE ASSESSMENT:
SDD's contain operations section as a basis for operating-testing procedures.
Design-Assurance group reviews all pre-op test procedures and B&R has a representative on the J.T.G.
O O
ITEM NUMBER:
4.3.2.1 (m)
DISCIPLINE:
Electrical /I&C AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
_.O POTENTIALLY REPORTABLE- _ __ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _ __ _
_ _ _. G BASIS FOR ABOVE ASSESSMkNT:
SDD's, Design Assurance, Safety Systems Hazard's Analysis will address access for all manual operations under accident conditions.
O l
l O
l
ITEM NUMBER: 4.3.2.1 (n) l qV DISCIPLINE: Electrical /I&C AGREE WITH FINDING:
h DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _. _ _ _ _ _ _O POTENTIALLY REPORTABLE _. _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _
_. W BASIS FOR ABOVE ASSESSMkNT:
This portion of the electrical design is still in the development stages.
}
As isolation device design becomes finalized, specific instructions will be transmitted to designersby project design procedures.
O i
l O
i ITEM NUMBER:
4.3.2.1 (o) t O
DISCIPLINE:
Electrical /IEC AGREE WITH FINDING:
O DISAGREE WIlrl FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.O POTENTIALLY REPORTABLE
_ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ ___ _
_. E BASIS FOR ABOVE ASSESSMENT:
Project procedures do not prohibit one individual from performing both check-ing and design verification actions on a design document, as long as other personnel selection requirements are met.
Refer to procedure DC-015, " Pro-cedure for Design Verification."
O l
l l
l O
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ITEM NLHBER:
4.4.2.1 (a)/(b)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
_O POTENTIALLY REPORTABLE
_ _. _ E NOT REPORTABLE _. _
_. Q INSUFFICIENT DATA FOR ASSESSMENTa BASIS FOR ABOVE ASSESSMENT:
This item is addressed in enclosure 2.
O O
ITEM NUMBER:
4.4.2.1(c)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _ _.O POTENTI ALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENT l
NOT REPORTABLE _ _._ _.
BASISFORABOVEASSESSMkNT:
Pockets In RCB:
Currently, the NRC does not require other than a homcgeneous hydrogen genera-tion model. Because of the large volume of the STP containment and considering the TMI experience B&R does not feel that pocket accumulations of hydrogen O
pose a potentially reportable concern.
Battery Room Concentrations:
The QUADREX concern was an apparent inconsistency between B&R disciplines.
B&R has perfomed a design verified calculation (7A079NC786A) detemining the hydrogen concentration in the battery rooms. This calculation shows we are under a 2% concentration.
O t
ITEM NUMBER:
4.4.2.1 (d)
O DISCIPLINE:
.lechanical/HVAC AGREE WITH FINDING:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_O POTENTIALLY REPORTABLE._ _ _. _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- _ - -
- -. U BASIS FOR ABOYE ASSESSMkNT:
B&R does not consider this to be reportable as there is a program underway
~
to study this concern and no significant deficiencies have been detected thus far.
O l
O
ITEM NUMBER:
4.4.2.1(e)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
'i DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE - _.. - _ _ _ _
__O POTENTI ALLY REPORTABLE _. _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE-. _
_ _. O BASIS FOR ABOVE ASSESSMENT:
Proper administrative control on the part of HL&P operations should alleviate this problem.
"Pragram To Be Established" A review of the floor drain system will be undertaken.
It is not felt that O
seca ie kese co ie o #aeetected ic=9 eao#98 to ce#se e =4 4<4ce#t seretz s
9 hazard.
O
ITEM NUMBER:
4.4.2.1 (f)
DISCIPLINE:
Mechanical /HVAC
~
AGREE WITH FINDING:
D DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE...- _ _ _ _ __O POTENTI ALLY REPORTABLE _.. _ _ D INSUFFICIENT DATA FOR ASSESSMENTC)
NOT REPORTABLE._ _ -. _
_ _.. D BASIS FOR ABOVE ASSESSMENT:
No evitfence that inconsistencies address reportable design deficient items.
e B&R Licensing has confinned that FSAR Change Notice requests submitted h
recently are of a " component parameter correction" nature.
9 O
i f
O
ITEM NUMBER: 4.4.2.1(g)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _
_.O POTENTI ALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _._ _.__ _ _. U BASIS FOR ABOVE ASSESSMENT:
Written criteria does not establish the adequacy of a design verifier.
S&R design verification procedure STP-DC-015, does meet all regulatory reqvf rements.
i O
4 t
e 4
4 4
O J
ITEM NUMBER:
4.5.2.1 (a)
DISCIPLINE:
Stress Analysis (Piping)
AGREE WITH FINDING:
O DISAGREE WITH FINDING: O THIS ITEM IS CONSIDEFID TO BE:
REPORTABLE. -. _ _ _ _
__O POTENTI ALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _..._ _ ___ _.. m BASIS FOR ABOVE ASSESSMENT:
The change in ANSI N176 between 1978 and 1979 changed the angle of jet im-pingement effects. This may be cause for re-enalysis. This is not a reportable deficiency since the mquirements changed subsequent to design.
O I
s O
l 1
etJ
ITEM NUMBER: 4.5.2.1(b)
O' DISCIPLINE:
Stress Analysis (Piping)
AGREE WITH FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _..
_.O POTENTIALLY REPORTABLE _
_ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE.- _ _. - - _ _. G BASIS FOR ABOVE ASSESSMENT:
As indicated in ',he QUADREX assessment to M-8, the approach used-by EDS is
{
conservative.
"The simplified approach, but is prcbably not unreasonable since support from I
restraints was included".
AV O
M
ITEM NUMBER:
4.5.2.1 (c)
O DISCIPLINE:
Stress Analysis (Piping)
AGREE ETH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..._ _ _ _ _
_O POTENTI ALLY REPORTABLE _
_. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
- - _ _ _ _ _. U BASIS FOR ABOVE ASSESSMkNT:
We ass'umed that the condition whem a pipe loses a support is less severe than ttle condition where a pipe sustains an impact due to rupture of a pipe of equal or smaller size.
~
O O
i
ITEM NUMBER:
4.5.2.1 (d)
O DISCIPLINE:
Stress Analysis (Piping)
AGREE WITH FINDING:
C DISAGREE WITH FINDING: O
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.. _ _ _ _ _
__D POTENTIALLY REPORTABLE __ _
_D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _
_ _.. G BASIS FOR ABOVE ASSESSMENT:
Verification of the penetrations and much of the high energy piping is still under e~ valuation.
i O
ITEM NUMBER: 4.5.3.1(a)
O DISCIPLINE: Piping Stress Analysis AGREE WITH FINDING:
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _... _ _ _ _
_.O POTENTIALLY REPORTABLE _
._ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _.
_.. G BASIS FOR ABOVE ASSESSMENT:
This effort is presently under way. TRD addressing these concems is being developed.
o O
l O
l ITEM NUMBER:
4.5.3.1(b)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
DISAGREE WITH FINDING: O
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..
_.O POTENTIALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _
__13 BASIS FOR ABOVE ASSESSMENT:
No requirement exists for showing restraint locations on isonrtrics.
O
.lO
~
l ITEM NUMBER:
4.5.3.1 (c)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C
~
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE... - - - _ _
_.O POTENTI ALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ _ _ _ _ _. U BASIS FOR ABOVE ASSESSMENT:
Fomalization of analysis methods and procedures is underway.
O l
l
' O
ITEM NUMBER:
4.5.3.1 (d), (e)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
h DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _._ _ _ _ _
_.O POTENTIALLY REPORTABLE _ _
_ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ -. _
_. U BASIS FOR ABOVE ASSESSMENT:
Formalization of analysis methods and procedures is underway.
O I
O
ITEM NUMBER:
4.5.3.1 (f)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
_.D POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
_ _ _. G BASIS FOR ABOVE ASSESSMENT:
In our response to M-6, we will consider using dynamic analysis on a " case-by-case" basis.
i 1
O
[
~
l ITEM NUMBER:
4.5.3.1 (g)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C
~
1 DISAGPIE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
__O POTENTI ALLY REPORTABLE _. _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ _ _
_ _ _. U BASIS FOR ABOVE ASSESSMkNT:
Criter a is being developed in a fomal document to provide consistency.
O I
s 1
/'
O 3
\\
x
i i
ITEM NUMBER:
4.5.3.1 (h)
O 9
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. - _ _ _ _
O POTENTI ALLY REPORTABLE _. _ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE- -- _ _ _ _.. G BASIS FOR ABOVE ASSESSMkNT:
The EDS criteria is generic,has been appropriately applied to the specific STP design.
O f
9
- 61 O
ITEM NUMBER:
4.5.3.1 (i)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.._ _
_.O POTENTI ALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._
_ _ _. U BASIS FOR ABOVE ASSESSMENT:
All systems and/or components essential for safe shutdown will be considered in the -interaction matrix for pipe whip outside containment.
O C
lO I
L
~
ITEM NUMBER:
4.5.3.1 (j)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.. _ _ _ _
_.O POTENTIALLY REPORTABLE
- _ _D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _ _ _ _
_. E BASIS FOR ABOVE ASSESSMENT:
B&R wiki expand on its response to the bi-linear stiffness question in the formal response.
O o
O
ITEM NUMBER: 4.5.3.1(k)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
h DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
__D POTENTIALLY REPORTABLE _ _
_D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ _ _ _ _ _ _. U BASIS FOR ABOVE ASSESSMENT:
Formalization of analysis methods and procedures are underway, i
O Y
O l
l l
J
ITEM NUMBER:
4.5.5.1 (a)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C
]
+
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.._ _ _ _ _
_.O POTENTIALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTp NOT REPORTABLE
_ _. _._ _.. U BASIS FOR ABOVE ASSESSMENT:
Review of SRP 3.9.3.I.2.f, which deals with operability assurance of active components, indicates analysis may be used in lieu of testin.g.
O O
ITEM NUMBER:
4.5.5.1 (b)
O oi$cIPtINE:
secheaicai/NvAC AGREE WITH FINDING:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_O POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ _ _._ _. W BASIS FOR ABOVE ASSESSMENT:
This situation will be reviewed as time pennits.
In our opinion the current design -basis is conservative.
B&R does not consider this reportable as the NRC has accepted the STP PSAR.
Changes in their requirements relative to STP can be addressed. The current A
design considering ECCS operation to service level "D" limits meets the regulatory requirements and is considered to adequately protect the safety of the public. We consider this to be consistent with other plants near STP in Licensing status.
J O
m
ITEM NUMBER: 4.5.5.1(c)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C We need to perform our analysis prior to agreeing ~
O or disagreeing with QUADREX's conclusions.
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _. _ _ _ _ _
_O POTENTIALLY REPORTABLE __ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- _ - - _ _ _ _. O BASIS FOR ABOVE ASSESSMENT:
B&R sees no evidence that this concern impacts the safety of the public and therefore, considers it not reportable. There are programs established
=
which are verifying the seismic and 1E qualification report adequacy.
O O
~
ITEM NUMBER:
4.5.5.1(d)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORT ABLE _ _.. _ _ _ _ _
O POTENTI ALLY REPORTABLE _. _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _ _. _ _ _ _.. U BASIS FOR ABOVE ASSESSMENT:
The vent piping is non-safety related.
In any event the safety classification of the -calculation will not' be reportable. QUADREX' assessrnent of the calcu-lation shows the calculation to be adequate.
O l
0 J
ITEM NUMBER: 4.5.5.1(e)
O otscre'2"t:
"ecae#<cei/svac AGREE WITH FINDING:
C i
DISAGREE WITH FINDING:
~
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _
..O POTENTIALLY REPORTABLE _ _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ _ _ _ _ _. U BASIS FOR ABOVE ASSESSMkNT:
We disagree that there was even confusion here. Persennel training, in any event, is not a reportable deficiency.
O a
O i
J
ITEM NUMBER:
4.5.5.1 (f)
O DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C m
DISAGREE WITH FINDING:
LU
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _
.D POTENTI ALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- _
.XE BASIS FOR ABOVE ASSESSMENT:
Qualification of equipment will be subject to independent audit by NRC re-viewers. This concern is not considered reportable because, while NRC has not officially sanctioned this document, they are not expected to have signi-ficant problems with its procedures.
O O
l
ITEM NUMBER:
4.5.5.1(g)
Mechanical /HVAC DISCIPLINE:
2 AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _
__O POTENTI ALLY REPORTABLE _. _ __ _ D l
INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- _
_ _ _ _ _. D BASIS FOR ABOVE ASSESSMENT:
This was the subject of an IRC rneeting and has already been found not reportable.
O I
l O
O
ITEM NUMBER: 4.6.2.1 (a) Item 1 DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
~~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
4 REPORTABLE _. _ _ _ _
..O POTENTIALLY REPORTABLE
_._ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
_. W l
BASIS FOR ABOVE ASSESSMENT:
Nuclear Analysis has not reviewed as to how other disciplines use trans-mitted information in their design.
O J
O L
ITEM NUMBER:
4.6.2.1 (a)
Item 2 DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _
_O POTENTIALLY REPORTABLE
_ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
_.XE BASJS FOR ABOVE ASSESSMkNT:
Saturatier, temperatures are used if applicable. Otherwise, actual temperature to evaluate the equipment / structure response.
Se example provided in response.
See QUADREX question N-1, Figures N-1-F and N-1-H.
O 4
O
ITEM NUMBER:
4.6.2.1 (b) item i DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C 4
~
DISAGREE WITH FINDING:
~~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _ __O POTENTI ALLY REPORTABLE._ _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTCl NOT REPORTABLE._ _
5 BASIS FOR ABOVE ASSESSMENT:
Agree with respect to Question N-13.
Disagree with response to Question N-1, because NUS model is correct but developed to produce conservative results.
i O
t 6
I t
O t
ITEM NUMBER:
4.6.2.1 (b) Item 2 DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
ij i
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _.. _ _ _ _ _
_O POTENTI ALLY REPORTABLE
_ __ _ D INSUFFICIENT DATA FOR ASSESSMENTD NOT REPORTABLE._ _._ _
_ _.. D BASIS FOR ABOVE ASSESSMkNT:
Analyses outside containment for environment are currently being perfomed.
l No reportable deficiency because of lack of adequate information.
O I
l l
L
ITEM NUMBER:
4.6.2.1 (b) Item 3 DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
O
~
DISAGREE WITH FINDING: O THISITEMkSCONSIDEREDTOBE:
REPORTABLE _.._ _ _ _ _
.O POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTA3LE_. ___ _
_ _. Q BASIS FOR ABOVE ASSESSMENT:
Agree to the extent that some calculations have deficiencies reported in the question above. But no adverse impact on the design of safety structures or systems have been identified.
O 1
0 i
l O
l l
l s
~
)
ITEM NUMBER:
4.6.2.1 (c)
DISCIPLINE:
Nuclear Analysis l
AGREE WITH FINDING:
C DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _
_O POTENTI ALLY REPORTABLE _. _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTD NOT REPORTABLE - _ -
_._ _. 3 BASIS FOR ABOVE ASSESSMENT:
Disagree, except for environmental qualification data. Other analysis have been scoped and performed on a reasonable project schedule calculations are being revised to alleviate deficiencies.
O o
O
ITEM NUMBER:
4.6.2.1 (d)
O DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C 1
.b DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
j 1
REPORTABLE
..D POTENTIALLY REPORTABLE _ _._ _D INSUFFICIENT DATA FOR ASSESSMENTp NOT REPORTABLE _ _ _
. U BASIS FOR ABOVE ASSESSMENT:
Example is provided in response to question.N-1 figure N-1-G and N-1-H, are the evidence of support other disciplines.
e
+
O
ITEM NUMBER: 4.6.2.1 (e)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..
_D POTENTIALLY REPORTABLE _. _._ _ D INSUFFICIENT DATA FOR ASSESSMENTp NOT REPORTABLE
.. G BASIS FOR ABOVE ASSESSMENT:
For the sake of consistency with analysis perfonned at early FSAR.itage the usage of RELAP3 was continued. Current analyses are performed using COMPAR2 for subcompartment analysis. No reportable deficiency.
- O l
O
i ITEM NUMBER: 4.6.2.1 (f)
DISCIPLINE:
Nuclear Analysis AGREE WITH' FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _
_.O POTENTIALLY REPORTABLE _ _
_ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ - _ _
.. m BASIS FOR ABOVE ASSESSMENT:
Please review the response to the question N-8.
f O
i 1
s A
l h
l O
ITEM NUMBER: 4.6.2.1 (g)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
'l
..O
~
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE-.._ _ _ _ _
_.O POTENTIALLY REPORTABLE _. _
_ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
._ _ _ _ _.. G BASIS FOR ABOVE ASSESSMENT:
t No long tenn environmental analysis have been done outside containment.
Any p
impact of the make-up water supply will be evaluated.
l O
l l
1 0
ITEM NUMBER:
4.6.2.1 (h)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C
- {
DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.. _ _ _ _ _ _.O i
POTENTIALLY REPORTABLE _
__ _D INSUFFICIENT DATA FOR ASSESSMENTQ 4
NOT REPORTABLE
_. E BASIS FOR ABOVE ASSESSMkNT:
Disagree. However, we take the statement under advice.
o I
1 l
0 l
4 l
l t
O
ITEM NUMBER: 4.6.2.1(i)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: C THIS ITEM IS CONSIDERED TO BE:
REPORTABLE __...
_ _ _ _,, O POTENTI ALLY REPORTABLE _. _ __ _ D INSUFFICIENTDATAFORASSESSMENTQ NOT REPORTABLE-- -- - -_ _.. O BASIS FOR ABOVE ASSESSMENT:
See response to the question h, above.
k O
I i
[
1 l
i O
ITEM NUMBER: 4.6.2.1(j)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
O
~
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE
_.O POTENTIALLY REPORTABLE
_ _. _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _ _ _
_. W BASIS FOR ABOVE ASSESSMENT:
Agree, however double ended break was used for short tem subcompartment analysis for conservative pressure differential evaluation. Calculations are being revised using split type of breaks.
O O
~
ITEM NUMBER:
4.6.2.1 (k)
O DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..- _ _ _ _
_.O POTENTI ALLY Rf PORTABLE __ _
_ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ __ _ _ _ _.. E BASIS FOR ABOVE ASSESSMENT:
See response to question b.
a
.!O t'
O O
1
ITEM NUMBER: 4.6.2.1 (1)
DISCIPLINE: Nuclear Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.
_.O POTENTIALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
. U BASIS FOR ABOVE ASSESSMENT:
~
The data reported in S00 4E010EQOO4-A is based on analytical results.
As regards the usage of data for design of equipment, Nuclear Analysis was not directly involved.
O O
~
ITEM NUMBER: 4.6.2.1(m)
L O-DISCIPLINE:
Nuclear Analysis 1
AGREE WITH FINDING:
DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _... _ _ _ _ _
.O POTENTIALLY REPORTABLE _. _ _. D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ -. _
_ _. U BASIS FOR ABOVE ASSESSMENT:
Initial conditions for the accident analysis of the ECP are conservative in all cases and may not reflect anticipated normal operating conditions.
ECP temperatures as calculated by the CP217CMM/SAFEC00L computer codes are 30%
conservative when coi'..ed to the CW519 computer code. The LOCA case and the simultaneous safe shutdown of both units has been analyzed as required O
by Regulatory Guide' 1.27.
The worst 1-day and worst 30-day periods of me-teorological record in the region resulting in minimum heat transfer to the atmosphere were applied. These analysis are in the process of being finalized.
O 1
l
~
ITEM NUMBER: 4.6.2.1(n)
O DISCIPLINE:
Nuclear Analysis s
AGREE WITH FINDING:
h s
'j l:
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.
.O POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
_. G BASIS FOR ABOVE ASSESSMENT:
I
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ITEM NUMBER: 4.6.2.1(o)
DISCIPLINE:
Nuclear Analysis AGREE WITH FINDING:
C
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DISAGREE WIN FINCING: O THIS ITEM IS CONSIDERED TO EE:
REPORTABLE
_.O POTENTIALLY REPORTABLE D
INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
. U BASIS FOR ABOVE ASSESSMkNT:
Agree,-however we are in a process of developing a technique for analyzing localized consentration of hydrogen inside the battery room and other areas.
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ITEM NUMBER:
4.6.4.1 (a)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
~-
DISAGREL WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _
.O POTENTI ALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _..
_.. U BASIS FOR ABOVE ASSESSMENT:
We appreciate the compliment. The requested FMEA will be developed as part of the review described in SD-005.
O
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t O
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ITEM NUMPER:
4.6.4.1(b)
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
b DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _
__D POTENTIALLY REPORTABLE _ _ _. _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. ___
___ _.I3 BASIS FOR ABOVE ASSESSMENT:
The classification of the calculation will not affect results. QUADREX has confirmed the adequacy of the design so this is not reportable.
O l
I O
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l ITEM NUMBER:
4.6.4.1 (c) j O
DISCIPLINE:
Mechanical /HVAC AGREE WITH FINDING:
C
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DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
.O POTENTIALLY REPORTABLE
_D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ _. _ _ _. U BASIS FOR ABOVE ASSESSMENT:
We will prepare requisite FEMA's.
SD-005 describes the B&R program which will establish the FMEAs. Establishment of FMEA will not impact the safety of the plant.
O l
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ITEM NUMBER:
4.7.2.1(a)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
__O POTENTIALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE._ _
_ __ _ _. ID BASIS FOR ABOVE ASSESSMENT:
I FSAR will be corrected.
O h
9 O
ITEM NUMBER:
4.7.2.1(b)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.
_.O POTENTIALLY REPORTABLE _ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ -- _ _ _ _. G BASIS FOR ABOVE ASSESSMENT:
It is B&R's responsibility to change the FSAR.
Changes affecting the EDS scope of work are brought to their attention as required.
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i ITEM NUMBER:
4.7.2.1 (c)
O DISCIPLINL:
Piping Stress Analysis AGREE WITH FINDING:
C See Below.
1 DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
__O POTENTI ALLY REPORTABLE _. _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE -
_. D BASIS FOR ABOVE ASSESSM5NT:
B&R will evaluate the need for revising the FSAR.
O O
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ITEM NUMBER:
4.7.2.1 (d)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C
.'j
.b
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DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _. _ _ _ _ _
_.O POTENTIALLY REPORTABLE __ _ _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE - _ _ _
_.%3 BASIS FOR ABOVE ASSESSMENT:
The threshold stiffness valves supplied by B&R are minimum valves above which piping analysis results will not be significantly affected.
O O
1 ITEM NUMBER:
4.7.2.1(e) i O
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _
_ _ _O POTENTIALLY REPORTABLE._
_D INSUFFICIENTDATAFORASSESSMENTQ NOT REPORTABLE.-
. U BASIS FOR ABOVE ASSESSMENT:
Applic' ability of MEB-6 to the STP is under discussion.
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ITEM NUMBER:
4.7.2.1 (f)
(J3 DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C See Below.
A DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE... _ _ _ _ _
_.O POTENTIALLY REPORTABLE
_ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._
_ _.%3 BASIS FOR ABOVE ASSESSMENT:
B&R will evaluate the need for revising the FSAR.
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ITEM NUMBER:
4.7.3.1(a)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
'1 DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..
__O POTENTIALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _ _ _ _ _ _ _.. G BASIS FOR ABOVE ASSESSMkNT:
Fomalization of analysis methods and procedures are under development.
O l
i O
ITEM NUMBER:
4.7.3.1 (b)
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
1 DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
__O POTENTIALLY REPORTABLE _
_ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _
_ _.. U BASIS FOR AB0VE ASSESSMENT:
o In those instances where operating temperatures cannot be determined from the 500, the information is formally requested from the system engineer.
O l.
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ITEM NUMBER:
4.7.3.1 (c) mU DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _. _ _ _ _ _
_.O POTENTIALLY REPORTABLE._
__ _ D INSUFFICIENT DATA FOR ASSESSMENTD NOT REPORTABLE._ _ __
.____.. G BASIS FOR ABOVE ASSESSMENT:
B&R procedures agree with the FSAR and provide more detailed information.
O O
ITEM NUMBER:
4.7.3.1 (d)
DISCIPLINE:
Piping Stress Analysis ll 1
AGREE WITH FINDING:
C See Below.
~
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _...._ _ _ _ _
_O POTENTIALLY REPORTABLE _ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTCl NOT REPORTABLE._ _
_ _. 5 BASIS FOR ABOVE ASSESSMENT:
There exists new procedures to review the overall system designs.
O O
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ITEM NUMBER:
4.7.3.1 (e)
DISCIPLINE:
Licensing AGREE WITH FINDING:
C No position DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _ _ _ _ _ _
_.O POTENTIALLY REPORTABLE _
_ _I]
INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _
13 BASIS FOR ABOVE ASSESSMENT:
E qualifies equipment to " umbrella" parameters.
B&R confirms that plant-specifi-c calculated parameters for adverse environments do not exceed the E "untrella" qualification parameters.
O O
L O
- w
ITEM NUMBER:
4.7.3.1 (f)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
. j DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.. _ _ _ _ _
_.O POTENTIALLY REPORTABLE _ _ __ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE _. _
_ _ _ _ _. U BASIS FOR ABOVE ASSESSMENT:
FSAR will be corrected.
O d
e i
O
d ITEM NUMBER: 4.7.3.1(g) 1 DISCIPLINE:
Pipe Support Design AGREE WITH FINDING:
C DISAGREE WITH F NDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.
_.O POTENTIALLY REPORTABLE._ _._ _D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE _ _ _ _ _ _ _ _.II BASIS FOR ABOVE ASSESSMENT:
Decision to ignore SEE SAM loads as primary loads is in accordance with cur-rent ASME philosophy.
O i
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O
~
0 ITEM NUMBER:
4.7.3.1(h)
O h
DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C i
i DISAGREE WITH FINDING: b THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. __._ _ _ _ _ _.D POTENTI ALLY REPORTABLE _. _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABi.E._ ___ _ _ _ __ U BASIS FOR ABOVE ASSESSMENT:
Response to P-21 indicates that B AR is considering FW hammer.
O l
O P
o
ITEM NUMBER: 4.7.3.1(i)
O DISCIPLINE:
Piping Stress Analysis AGREE WITH FINDING:
C DISAGREE WITH FINDING: b
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..- _ _ _ _
__D POTENTI ALLY REPORTABLE
- _. _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE._ _ _ _ _. _.. U BASIS FOR A30VE ASSESSMENT:
CG O
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l O
ITEM NUMBER:
4.7.3.1 (j )
DISCIPLINE:
Pipe Support Design AGREE WITH FINDING:
O DISAGREE WITH FINDING: b
~'
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE..._ _ _ _ _.
__O POTENTIALLY REPORTABLE __ _ _ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE- -- -
_ _. D BASIO FOR ABOVE ASSESSMENT:
Methods and procedures are censistent with industry practice.
O O
i O
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ITEM NUMBER:
4.7.3.1 (k)
DISCIPLINE:
Pipe Support Design AGREE WITH FINDING:
O DISAGREE WITH FINDING:
THIS ITEM IS CONSIDERED TO BE:
i REPORTABLE _..._ _ _ _ _
__O POTENTIALLY REPORTABLE _
_D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORT.'.BLE._ _ _ _
_ _.. G BASIS FOR ABOVE ASSESSMENT:
Methods and procedures are consistent with industry practice.
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ITEM NUMBER:
4.8.2.I (a)
O DISCIPLINE:
Electrical /I&C i
AGREE WITH FINDING:
[
DISAGREE WITH FINDING: O
~
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _..
..O POTENTIALLY REPORTABLE
_ _D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE
.. O BASIS FOR ABOVE ASSESSMENT:
See 4.3.2.1 (a)
O F
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'i O
Q ITEM NUMBER: 4.8.2.1-(b)
DISCIPLINE: Nuclear Shielding Discipline AGREE WITH FINDING:
C see below DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _.... _ _
.O POTENTIALLY REPORTABLE _ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTD NOT REPORTABLE.- _
_ _ __ _. E BASIS FOR ABOVE ASSESSMENT:
~
This statement is partially correct. Procedure DC-016 states in Section 2.2.1,
(- (s "The EPM.....who is qualified.....to conduct the ALARA review." The procedure t
recognizes the need for qualified engineers, however, a separate procedure listing specific qualification requirements i.e. number of years of experience, levels oftrainingetc,hasnotbeendevel$ ped. The statements regarding design drawing sign-off and follow-up are partially correct. The documents, including These drawings, that require ALARA review are identified in procedure DC-016.
drawings and associated DCNs are reviewed by the B&R ALARA reviewer. Once the ALARA comments are resolved, the changes are incorporated into the drawings, however, follow-up on all comment resolutions can not be demonstrated. The revised ALARA program will address this concern. This is not reportable because it impacts ALARA not the safe operation of the plant and the health and safety of the public.
l O
SLB 5/8/81
ITEM NUMBER:
4.8.2.1 (c)
O DISCIPLINE:
Mechanical /HVAC
- 1 AGREE WITH FINDING
DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _.._ _ _ _ _
_.O POTENTIALLY REPORTABLE _.
_ _ D INSUFFICIENT DATA FOR ASSES 5MENTQ NOT REPORTABLE _ _ __
_. El BASIS FOR ABOVE ASSESSMENT:
In 5-7-81 session with HL&P, they provided basis for original decision to delete filters. On this basis they stated the finding is not potentially repo rtable. As B&R is not aware of the actual ALAP assumptions we do not disagree.
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O
ITEM NUM ER: 4.8.2.1-(d; DISCIPLINE:
Nuclear Shielding Discipline AGREE WITH FINDING: ~
C
[
see below DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _ _ _ _ _ _ _
.O POTENTIALLY REPORTABLE
_D INSUFFICIENT DATA FOR ASSESSMENTD NOT REPORTABLE._ _
_ _. G BASIS FOR ABOVE ASSESSMENT:
This statement is partially correct. The need for specifying that a shielding calculation is safety related should be evaluated on a case by case basis i.e. some calculations may support safety related equipment and therefore could be " safety related". Currently, shielding calculations are checked by another shielding engineer and reviewed by the DPE. Specifying a calculation is safety related requires a " design verifier" to verify the calculation.
The main difference between the checker and design verifier is the verifier's training. Both the verifier and checker are knowledgeable on shielding.
The calculations will impact the design of shielding which could impact ALARA. During pre-opt testing or plant operations, any areas that have excessive dose rates will be corrected by procedures, modifying shielding l
(temporary or permanent), the ALARA program or changing the need for access.
B&R has not verified all NUS shielding calculations. The models and codes l
used for the shielding analyses are being reviewed. These problems are l
being addressed as part of the "as built" analyses. This is not reportable because it does not impact the safe operation of the plant or public health and safety.
O
!O I
SLB 5/8/81 l
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O ITEM NLASER: 4.8.2.1-(e) 8 l DISCIPLINE: Nuclear Shielding Discipline AGREE WITH FI DING:
C (see below)
I DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE.
_Q POTENTIALLY REPORTABLE
_ _ _D INSUFFICIENT DATA FOR ASSESSMENTO NOT REPORTABLE- - _. _.__ _. til BASIS FOR ABOVE ASSESSMENT:
The design and analyses of the shielding This statement is partially correct.
identified in the.TRO, A509NQ005, were based on the radiation zones specified I
However, this was not a comprehensive evaluation. B&R has initiated in the TRD.
a comprehensive program for performing "as built" shielding analysis of the ISI requirements are currently being developed and will be factored into STP.
The need for temporary shielding is specified by operations the ALARA program.
and maintenance activities. As these activities are defined, temporary shielding This is not reportable because the correlation will be provided, as needed.
of shielding criteria to the shield design impacts ALARA not the safe operation of the plant and the public health and safety.
~
O SLB 5/8/81
--.-A
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ITEM NUMBER: 4.8.2.1-(f)
DISCIPLINE:
Nuclear Shielding Discipline AGREE WITH FINDING:
h DISAGREE WITH FINDING: O THIS ITEM IS CONSIDERED TO BE:
REPORTABLE. _. _ _ _ _ _
_O POTENTIALLY REPORTABLE._ _ _ _ D INSUFFICIENT DATA FOR ASSESSMENTg NOT REPORTABLE -
._ _ _ _ _. U BASIS FOR ABOVE ASSESSMENT:
~ Radiation zoning maps have not been developed for use in specifying plant accident dose rate limits. The accident limits are specified in regulatory documentation. Analyses have been performed to determine the accident dose rates relative to regulatory limits, e.g. the control room. Radiation zoning maps provide a convenient visual means of specifying limits. This is not a reportable item because the use of zoning maps does not affect the safe operation of the plant or the public health and safety.
l
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SLB 5/8/81 m
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ITEM NUMBER: 4.8.2.1-(g)
DISCIPLINE: Nuclear Shielding Discipline i
I 5GREEWITHFINDING:
h
[
DISAGREI WITH FINDING: 0 t
THIS ITEM IS CONSIDERED TO BE:
REPORTABLE _. _ _ _ _ _
__O POTENTI ALLY REPORTALLE._ _ __ _ D INSUFFICIENT DATA FOR ASSESSMENTQ NOT REPORTABLE __ ___ _
_ _.. U BASIS FOR ABOVE ASSESSMENT:
The design basis for removable concrete block walls is being developed and will be incorporated into the General Structural Design Criteria, 5/36950001. The block wall criteria impacts maintenance activities and ALARA 'not the safe operation of the plant and is therefore, not reportable.
i I
- O SLB 5/8/81 l
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ENCLOSURE (2) i SUPWARY OF BROWN AND ROOT FINDINGS ON l
j.
SOUTH TEXAS PROJECT QUADREX INGINEERING REVIEW (May 1981)
ITEM 4.4.2.1 (a)/(b) i ll k
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town & Root.hc.
O susaect Inadequacy of the following STP HVAC Systems:
MA8 Fuel Handling Building EAB l
DESCRIPTION OF POTENTIAL PROBLEM l
On April 7,1980, Houston Lighting & Power (HL&P) infonned Brown & Root of a potential problem of cooling the Radwaste Control Room in the MAB.
A B&R study group was formed (Special Problem #16) with representation from the (B&R) Mechanical, Electrical, I&C, Structural, Nuclear Analysis and HVAC Disciplines. On September 18, 1980 a preliminary assessment concerning candidate areas for additional study was released. The candi-date areas included: the electrical penetration space in the EAB; the radwaste control room, which contains the hot shutdown panel, the reactor make-up water pump cubicle, the boric acid transfer pump cubicle, the CVCS valve cubicle at elevation 41'-0" and 10'-0" in the MAB: the spent fuel pool cooling pump cubicles in the fuel handling building (FHB) and the valve cubicles in the FHB where containment isolation valves in dis-charge lines from the High Head Safety Injection, Low Head Safety In-jection and Containment Spray pumps are located. At this time a possible O
need for supplemental air cooled chillers to handle additional antici-pated (based on engineering judgement) HVAC loads were discussed.
From January 7,1981 thru January 27, 1981, calculations were informally received from the HVAC group confinning the need for additional HVAC cooling capacity. On March 12, 1981, a draft report was issued by the B&R Special Problems Group which summarized the thermal environmental data which had been received and confirmed the need for supplemental cooling of the equipment described in Table 1 (Attached).
On March 19, 1981, representatives of QUADREX, under contract to HL&P, conducted a technical audit of B&R's HVAC System design and in a report received by B&R on May 7,1981, confirmed B&R's earlier assessment that there may be insufficient HVAC cooling capacity for equipment located in the MAB and FHB.
Although we do not yet have actual heat load data, including maximum allowable operating temperature information, for all potentially affected systems, we believe that there is currently sufficient uncertainty con-cerning the adequacy of the HVAC Systems designed for the MAB, FHB and EAB to consider the matter to be potentially reportable at this time.
O
i Brownf5 Root.inc.
APPROACH TO RESOLUTION A supplemental HVAC system cogosed of in-room fan-coil units and air cooled chillers is currently being considered for incorporation into the STP Units. Sketches showing proposed physical arrangements are currently being prepared for candidate locations and additional thermal operating data is being sought from all equipment vendors.
STATUS OF PORPOSED RESOLUTION A final determination concerning the need for additional safety grade HVAC capacity will be completed upon receipt of the following evaluations: pipe breaks outside containment (QUADREX Audit Question 4.4.4.1.a); and, special problem 16 (QUADREX Audit Question 4.4.4.1.b).
These evaluations will con-sider the equipment and piping heat losses and the maximum environment for which the safety related components are qualified. Without performing these evaluations we.cannot determine the exact magnitude of the impact on plant safety.
Based on these uncertainties, we feel that this problem is potentially re-portable under 10CFR50.55(e) and is currently being investigated as a potential 10CFR21.
e-REASONS FOR FINAL REPORTABILITY DELAY
^
Project Engineering had not completed sufficient themal calculations to indicate a clear need for a supplemental HVAC System.
PROJECTED COMPLETION OF CORRECTIVE ACTION The projected completion date for the following Special Problem #16 acti-vities is currently June 15, 1981 to have a definition of design qualification temperatures for safety related equipment, a preliminary assessment of heat l
losses and area temperatures and a conceptual design and preliminary lay-l out for a supplemental HVAC system.
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CANDIDATES FOR NtW HVAC SERVICE LOCATION EQUIPMENT REQUIRING EQ'JIP. QUALIF.
POST-ACCIDENT POST-ACCIDENT EQUIPMENT TEMP CONTROL TEMP. F TEMPERATURE w/o HVAC, HEAT LOAD STATUS F (1)
Btu /hr Radwaste Coni.rol Room, H M nit ring Equip.
104 184 270,000 ON SITE 2
MAB Electrical Penetration Class lE Cables 120 1st F1: 193 211,260(3)
Space, EAB (2) 2nd F.: 204 251,940 (3) 3rd F1.: 185 255,620(3)
Reactor make-up water Reactor make-up 120 195 61.000 Pumps Cubicle, MAB Water Pumps Spent Fuel Pool SFPCCS Pumps 120 268 66,300 a
Pump Cubicles, FHB Boric Acid Transfer Boric Acid Transfer 120 197 42,000 a
Pumps Cubicle, MAB Pumps (4)
Cont. Iso. Valve Cont. Iso. Valves (5) 120
^(later) 31,800 a
Cubicles, FHB B&R Valve Nos.:
(3 cubicles)
XSI 004A, B, C XSI 018A, B, C XCS 001A, B, C Valve Cubicles in MAB CVCS Valves used for 120 El. 10 ' -0" : 150 33,400 a
(3 cubicles) boration (4)
El. 41'-0": 150 38,400 B8R Valve Nos.:
XCV 218 XCV ll2C XCV 113B XCV 1128 XCV 113A Elect. Aux. Bldg.
EAB Chillers (later)
(later)
(later)
=
Chiller Area (located in MAB)
Footnotes (see Page 2) f.
Page 2 TABLE 1 - CANDIDATES FOR NEW HVAC SERVICE FOOTNOTES 1.
Calcualted environmental temperature in the cubicle or area when only safety related equipant is operating, and with no HVAC service.
2.
HVAC for this area has been identified as critical concern No. 11-5 (1979).
j
. The equipment listed requires environmental temperature control during operating conditions.
3.
During normal operation, heat loads are:
1st Floor 81,200 Btu /hr.
2nd Floor 123,350 Btu /hr.
3rd Floor 121,400 Btu /hr.
4.
Capacity for cooling this area should be included when sizing the chiller.
However, since alternative methods of boration are available, no further design toward adding coolers should be performed until Westinghouse is appraised of the calculated cubicle temperatures, and the preferred boration method is identified.
5.
Requalification or replacement of the valve actuators are possible alternatives to adding HVAC Coolers. Capacity for cooling these cubicles should be included o
when sizing the chillers.
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