ML20148S112
| ML20148S112 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/25/1988 |
| From: | Leo R EBASCO SERVICES, INC. |
| To: | |
| Shared Package | |
| ML20148R989 | List: |
| References | |
| TAC-R00286, TAC-R00287, TAC-R00288, TAC-R286, TAC-R287, TAC-R288, NUDOCS 8802020343 | |
| Download: ML20148S112 (65) | |
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O COM ANCHE PEAK STE AM ELECTRIC STATION UNIT 1 and COMMON CORRECTIVE ACTION PROGRAM O
PROJECT STATUS REPORT V ECHANICAL SUPPLE \AENT A SYSTEMS INTERACTION
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,o TV ELECTRIC COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 AND COMMON EBASCO SERVICES INCORPORATED PROJECT STATUS REPORT SYSTEMS INTERACTION PROGRAM SUPPLEMENT A MECHANICAL PROJECT STATUS REPORT r3 U
~ f} .y',
ft l _ .i / L, Robert G. Le V lfJ
' Systems Interaction Program Manager
TABLE OF CONTENTS O Section Ilth Eagg EXECUTIVE
SUMMARY
iii ABBREVIATIONS AND ACRONYMS vi
1.0 INTRODUCTION
1-1 Figure 1-1 Corrective Action Program (CAP)
Systems Interaction 2.0 PURPOSE 2-1 3.0 SCOPE 3-1 4.0 SPECIFIC ISSUES 4-1 5.0 CORRECTIVE ACTION PROGRAM (CAP) 5-1 METHODOLOGY AND RESULTS 5.1 METHODOLOGY AND WORK PERFORMED 5-1 5.1.1 Licensing Commitments, Design Criteria 5-1 and Procedures 5.1.1.1 Verification of Design Criteria, Procedures 5-2 and Resolution of Issues 5.1.2 Design Validation Process 5-2 5.1.2.1 High Energy Line Breaks (HELBs) 5-4 5.1.2.2 Moderate Energy Line Breaks (MELBs) 5-5 5.1.2.3 Environmental and Flooding Analyses 5-5 Outside Containment 5.1.2.4 Seismic /Non-Seismic Interactions 5-6 5.1.2.5 Internally Generated Missiles 5-7 5.1.2.6 Interfaces 5-7 5.1.2.7 Final Reconciliation Process 5-8 5.1.3 Post Construction Hardware Validation 5-8 Program (PCHVP) 5.2 RESULTS 5-13 5.2.) Design Validation Results 5-13 5.2.2 Post Construction Hardware Validation 5-13 Program (PCHVP) Results i
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Section Title Eilag i O 5.3 QUALITY ASSURANCE (QA) PROGRAM 5-14 ,
5.3.1 The TV Electric Quality Assurance (QA) Program 5-14 5.3.2 Ebasco Quality Assurance (QA) Program 5-15 5.3.3 Systems Interaction Audits, Surveillances 5-16 and Inspections 5.4 CORRECTIVE Akb PREVENTIVE ACTIONS Figure 5-1 Corrective Action Program (CAP) Systems Interaction Flow Chart and Governing Procedures
, Figure 5-2 Corrective Action Program (CAP)
Interfaces-Systems Interaction Program (SIP)
Figure 5-3 Post Construction Hardware Validation Program (PCHVP)
Table 5-1 Post Construciton Hardware Validation Program (PCHVP) Systems Interaction Table 5-2 Summary of Audits and Surveillances ;
6.0 REFERENCES
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APPENDIX A COMANCHE PEAK RESPONSE TEAM (CPRT) A-1 -
ISSUES APPENDIX B ISSUES IDENTIFIED DURING THE PERFORMANCE B1 I
0F THE CORRECTIVE ACTION PROGRAM (CAP) t l !
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EXECUTIVE
SUMMARY
O The Systems interaction erc2 ram (Sie) coesists of evaiuatiees of the interactions with Comanche Peak Steam Electric Station (CPSES) components resulting from pipe breaks, internal missile generation and seismically induceu failures of non-seismic systems, structures and components.
This Project Status Report (PSR) summarizes the systematic validation processfortheSystemsInteractionProgram(SIP)implemegtedbyEbasco Services Incorporated (Ebasco) at CPSES Unit 1 and Common . This Project Status Report (PSR) presents the results of the design validation and describes the Post Construction Hardware Validation Program (PCHVP).
Ebasco's activities are governed by the TV Electric Corrective Action Program (CAP) which required Ebasco to:
- 1. Establish a consistent set of CPSES systems interaction de*,ign criteria that complies with the CPSES licensing commitments.
- 2. Produce a set of design procedures that assures compliance with the design criteria.
- 3. Evaluate interactions of systems, structures and components, and direct the corrective actions recommended by the Comanche Peak Response Team (CPRT) and those determined by the Corrective Action Program (CAP) investigations to be necesssary to demonstrate that systems, structures and components are in conformance with the design.
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I I I 1 Common refers to areas in CPSES that contain both Unit I and Unit 2 systems, structures, and components.
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- 4. Assure that thu validation resolves the systems interaction
- p. relatedissuesidentifiegbytheComanchePeakResponseTeam d (CPRT), external sources , and the Corrective Action Program (CAP).
- 5. Validate that the design of systems, structures and components
- addressed in the Systems Interaction Program (SIP) is in conformance with the licensing commitments and that.the installed hardware is in conformance with the validated -
design.
- 6. Produce a set of consistent and validated design documentation.
Consistent design criteria and engineering methodologies for CPSES Unit 1 and Common systems interaction have been developed and used by Ebasco for t the design validation process. These design criteria and engineering methodologies are in conformance with the CPSES licensing commitments.
These design criteria have been independently and extensively reviewed by the Comanche Peak Response Team (CPRT). ,
t Ebasco developed design and design control procedures to implement the design criteria and engineering methodologies and to govern the work flow and technical interfaces with other disciplines, for both the design and :
hardware validation processes. These procedures specify the validation l processes that have been implemented throughout the systems interaction portion of the Corrective Action Program (CAP).
i Ebasco has performed analyses to validate the design of CPSES Unit I and Common systems, structures and components addressed in the Systems Interaction Program (SIP). The as built hardware related to systems interaction are being validated to the design by the Post Construction ,.
Hardware Validation Program (PCHVP). ,
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2 External sources include: '
NRC Staff Special Review Team (SRT-NRC)
NRC Staff Special Inspection Team (SIT) 4 NRC Staff Construction Appraisal Team (CAT)
Atomic Safety and Licensing Board (ASLB)
NRC Region IV Inspection Reports I NRC Staff Technical Review Team (TRT) (SSERs 7-11)
CYGNA Independent Assessment Program (IAP)
Comanche Peak Response Team (CPRT) issues are identified by the following: i CPRT Design Adequacy Program (DAP) ;
CPRT Quality of Construction Program (QOC) !
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The systems interaction related design and hardware issues identified by fm the Comanche Peak Response Team (CPRT) and the Corrective Action Program iJ s'
(CAP) have been resolved by incorporation of engineering methodologies and design criteria into the Systems Interaction Program (SIP) design and design control procedures and the Post Construction Hardware Validation Program (PCHVP) implementation procedures.
The Post Construction Hardware Validation Program (PCHVP) assures that the systems, structures and components addressed in the Systems Interaction Program (SIP) are installed in conformance with the validated design. The Post Construction Hardware Validation Program (PCHVP) for the Systems Interaction Program (SIP), including engineering walkdowns and evaluations, implements the corrective actions identified by the Comanche Peak Response Team (CPRT), as well as those required by Corrective Action Program (CAP) investigations.
Ebasco will provide TU Electric with a complote set of validated design documentation for the Systems Interaction Program (SIP) including calculations, specifications and interaction evaluations. This documentation,inconjunctionwiththeSystemsInteractionPrograg(SIP) procedures, can provide the basis for CPSES configuration control to facilitate maintenance and operation throughout the life of the plant.
In-depth quality and technical audits and surveillances performed by Ebasco Quality Assurance (QA), TU Electric Quality Assurance (QA) and the independent Engineering Functional Evaluation (EFE) verified that the implementation of the validation program was in conformance with 10CFR50, O Appendix B, quality assurance requirements. These audits assure that the V systems interaction procedures, design criteria, and design comply with the licensing commitment.
The CPSES Unit I and Common systems interaction portion of the Corrective Action Program (CAP) conducted by Ebasco as part of the overall CPSES CAP validates that:
The design for interaction between systems, structures and components complies with the CPSES licensing commitments The as-built hardware configuration addressed in the Systems Interaction Program (SIP) complies with the validated design; l
The safety-related systems, structures, and components comply with the systems interaction related CPSES licensing commitments and will perform their safety-related functions.
1 3 Configuration control is a system to assure that the design and hardware remain in compliance with the licensing commitments throughout the life of the plant.
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ABBREVIATIONS AND ACRONYMS g)
( ANI Authorized Nuclear Inspection ANSI American National Standards Institute ASLB Atomic Safety and Licensing Board CAP Corrective Action Program (TV Electr.ic)
CAR Corrective Action Request CASE Citizens Association for Sound Energy CAT Construction Appraisal Team (NRC)
CFR Code of Federal Regulations CPE Comanche Peak Engineering (TV Electric)
CPRT Comanche Peak Response Team (TV Electric)
CPSES Comanche Peak Steam Electric Station CYGNA CYGNA Energy Services DAP Design Adequacy Program (CPRT)
DBD Design Basis Document DBCP Design Basis Consolidation Program DR Deficiency Report DVP Design Validation Package Ebasco Ebasco Services Incorporated ECE Engineering and Construction - Engineering (TV Electric)
EFE Engineering Functional Evaluation EME Engineering-Mechanical Engineering (TV Electric)
FSAR Final Safety Analysis Report FVM Field Verification Method GIR Generic Issues Report D HVAC Heating, Ventilation and Air Conditioning d HELB High Energy Line Break I&E Inspection and Enforcement (NRC)
IAP Independent Assessment Program (CYGNA)
Impell Impell Corporation IRR Issue Resolution Report (CPRT)
ISAP Issues Specific Action Plan (CPRT)
MELB Moderate Energy line Break NCR Nonconformance Report N0D Notice of Deviation (NRC)
NOV Notice of Violation (NRC)
NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG NRC Document OSP Office of Special Projects (NRC)
PCHVP Post Construction Hardware Validation Program PSR Project Status Report QA Quality Assurance QC Quality Control 00C Quality of Construction and QA/QC Adequacy Program (CPRT) vi
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SDAR Significant Deficiency Analysis Report c (TV Electric)
SER Safety Evaluation Report (NRC, NllREG-0797)
SIP Systems Interaction Program SIT Special Investigation Team (NRC Staff)
SRP Standard Review Plan (NRC, NUREG-75/087)
SRT Senior Review Team (CPRT)
SRT-NRC Special Review Team (NRC)
SSE Safe Shutdown Earthquake SSER Supplemental Safety Evaluation Report (NRC,NUREG-0797)
SSL Safe Shutdown Logic SWEC Stone & Webster Engineering Corporation SWEC-PSAS Stone & Webster Engineering Corporation -
Pipe Stress and Support Project TAP Technical Audit Program (TV Electric)
TERA Tenera, L.P.
TRT Technical Review Team (NRC Staff)
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1.0 INTRODUCTION
O in october 1984, Tu eiectric estebiished the Comenche eeak aesPonse Teem (CPRT) to evaluate issues that have been raised at CPSES and to prepare a plan for resolving those issues. The Comanche Peak Response Team (CPRT) program plan was developed and submitted to the NRC.
In mid-1986, TV Electric performed a qualitative and quantitative review of the preliminary results of the Comanche Peak Response Team (CPRT)
(References 1 and 2). This review identified that the Comanche Peak Response Team (CPRT) findings were broad in scope and includea each discipline. TV Electric decided that the appropriate method to correct the issues raised and to identify and correct any other issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue. TV Electric decided to initiate a comprehensive Corrective Actiog* ogram (CAP) to validate the entirety of CPSES safety-related designs The Corrective Action Program (CAP) has the following objectives:
Demonstrate that the design of safety-related systems, structures ar.d components complies with licensing commitments.
Demonstrate that the existing systems, structures and components are in compliance with the design or develop modifications which will bring systems, structures and components into compliance with design.
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Develop procedures, an organizational plan, and documentation (d to maintain compliance with licensing commitments throughout the life of CPSES.
The Corrective Action Program (CAP) is thus a comprehensive program to validate both the design and the hardware at CPSES, including resolution of specific Comanche Peak Response Team (CPRT) and external issues.
l l 1 Portions of selected non-safety-related systems, structures and I components are included in the Corrective Action Program (CAP).
! These are Seismic Category 11 systems, structures, and components, and fire protection systems.
l 2 NSSS design and vendor hardware design and their respective QA/QC l programs are reviewed by the NRC independently of CPSES and are not included in the Corrective Action Program (CAP) as noted in SSER 13; however, the design interface is validated by the CAP.
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TV Electric contracted and provided overall management to Stone & Webster Engineering Corporation (SWEC), Ebasco Services Incorporated (Ebasco), and p) u Impell Corporation (Impell) to implement the Corrective Action Program (CAP), and divided the CAP into eleven disciplines as follows:
Responsible Discipline Contractor Mechanical SWEC
- Systems Interaction Ebasco
- Fire Protection Impell Civil / Structural SWEC Electrical SWEC Instrumentation and Control SWEC Large Bore Piping and Pipe Supports SWEC-PSAS Cable Tray & Cable Tray Hangers Ebasco/Impell Conduit Supports Trains A,B,&C>2" Ebasco Conduit Supports Train C 12" Impell Small Bore Piping and Pipe Supports SWEC-PSAS Heating, Ventilation and Air Conditioning (HVAC) Ebasco Equipment Qualification Impell A Design Basis Consolidation Program (DBCP) (Reference 37) was developed to define the methodology by which Ebasco performed the design and hardware validation. The approach of this Design Basis Consolidation Program (DBCP) is consistent with other contractors' efforts and products.
/7 The design validation portion of the Corrective Action Program (CAP)
V identified the design-related licensing commitments. The design criteria were established from the licensing commitments and consolidated in the Design Basis Documents (DBDs). The DBDs identify the design criteria for the design validation effort. If the existing design did not satisfy the design criteria, it was modified to satisfy the criteria. The design validatior efforts for each of the eleven Corrective Action Program (CAP) disciplines are documented in Design Validation Packages (DVPs). The DVPs provide the documented assurance (e.g., calculations and drawings) that the validated design meets the licensing commitments, including resolution of all Comanche Peak Response Team (CPRT) and external issues.
The hardware validation portion of the Corrective Action Program (CAP) is being implemented by the Post Construction Hardware Validation Program (PCHVP), which demonstrates that existing systems, structures and components are in compliance with the validated design, or identifies l
modifications that are necessary to bring the hardware into compliance with the validated design.
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The results of the performance of the Corrective Action Program (CAP) for e each discipline are described in a Project Status Report (PSR). This PSR k) describes the results of the Corrective Action Program (CAP) for the Systems Interaction Program (SIP).
The Systems Interaction Program (SIP) portion of the Corrective Action Program (CAP) consists of activities carried out by Ebasco and is shown schematically in Figure 1-1. The Systems Interaction Program (SIP) consists of evaluations of the interactions with CPSES Unit I and Common components resulting from postulated pipe breaks, internal missile generation and seismically induced failures of non-seismic systems, structures, or components. Ebasco has performed a comprehensive design validation and is performing the hardware validation.
This Systems Interaction Program (SIP) Project Status Report (PSR) describes the validation effort from the early stages of design criteria establishment through the development and implementation of the detailed design and design control procedures. The report traces the implementation of the Post Construction Hardware Validation Program (PCHVP) to validate that the as-built systems, structures and components comply with the systems interaction related design and the completion of the CPSES Unit 1 and Common Design Validation Packages (DVPs).
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FIGURE 1-1 CORRECTIVE ACTION PROGRAM ( CAP)
O SYSTEMS INTERACTION
- FSAR IDENTIFY LICENSING y COMMITMENTS : OTHER LICENSING g DOCUMENTS 8 . v h DEVELOP DESIGN BASIS
$ DOCUMENTS ( DBDs)
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d v PERFORM DESIGN j VALIDATION EXTERNAL ISSUES o -NRC ( SRT, SIT, TRT, CAT)
-CYGN A ( I AP)
F -CASE
-ASLB
-NRC INSPECTION REPORTS IS MODIFICATICN YES _
DESIGN
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REQUIRED MODIFICATIONS O '
~o v v POST CONSTRUCTION BUILD / INSPECT HARDWARE VALIDATION :
M.0DIF D TION PROGR AM ( PCHVP)
F FINAL DESIGN RECONCILIATION P
IS
'f E S ADDITIONAL VALIDATION REQUIRED
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p NO O- FINAL DOCUMENTATIGN (DESIGN VALIDATION PACKAGES)
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2.0 PURPOSE O The purpose of this Project Status Report (PSa) is to demonstrate that the systems, structures and components of CPSES Unit 1 and Common comply with the systems interaction design criteria, are in conformance with the CPSES licensing commitments, and that safety-related systems, structures and components will satisfactorily perform their safety-related functions.
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3.0 SCOPE
'p The scope of the systems interaction portion of the Corrective Action U.
Program (CAP) includes:
- 1. The identification and protection of essential systems, structures and components (targets) which are those required to shut down the reactor and mitigate the consequences of the following postulated events:
High energy line breaks (HELBs)
Moderate energy line breaks (MEL8s)
Flooding resulting from inadvertent operation of fire suppression systems.
Internally generated missiles
- 2. The identification and protection of Seismic Category I l systems, structures and components (targets) and the protection of Control goom occupants from consequences of the failure of non-seismic systems, structures and components during a postulated earthquake as required by Regulatory Guide 1.29 (Reference 24).
Compliance with the requirements of Regulatory Guide 1.29 for Train C Conduit 2-inch diameter and less was validated by Train C Conduit 2-inch diameter and less portion of the Corrective Action Program (CAP). This validation is described in the associated Project Status Report (PSR) (Reference 46).
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1 Systems, structures and components that are designed and constructed to withstand the effects of the Safe Shutdown Earthquake (SSE) and
- remain functional are designated as Seismic Category I in accordance I
with the requirements of NRC Regulatory Guide 1.29.
2 Those portions of systems, structures, or components whose continued function is not required, and whose failure will not reduce the functioning of any Seismic Category I system, structure or component l
required to satisfy the requirements of Regulatory Guide 1.29 to an l unacceptable safety level and will not result in incapacitating l injury to occupants of the control room, are designated as non-seismic.
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Compliance with the requirement of Regulatory Guide 1.29 for p)
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clearancesbetweenSeismicCatggoryIcomponentsandSeismic Category I/ Seismic Category Il components is validated by the mechanical portion of the Corrective Action Program (CAP)
(References 38, 39 and 42).
The systems interaction portion of the Corrective Action Program (CAP) is shown schematically in Figure 1-1 and discussed below. The program required:
Establishment of systems interaction design criteria which comply with licensing commitments; Development of systems interaction Design Basis Documents (DBDs) for CPSES, which.contain the design criteria; Implementation of design and hardware validation consisting of analyses, identification and implementation of necessary modifications, and field verifications as identified in the Post Construction Hardware Validation Program (PCHVP). The as-built configuration of systems, structures and components is validated to comply with the systems interaction design criteria by engineering walkdowns and engineering evaluations. The results of the validation are documented in CPSES Unit 1 and Common Design Validation Packages (DVPs);
Resolution of the systems interaction design and hardware Q
O issues and implementation of a Corrective Action Program (CAP) for closure of these issues. These issues include Comanche Peak Response Team (CPRT) issues and issues identified during the performance of the Corrective Action Program (CAP) (See Section 4.0);
3 Those portions of structures, systems, or components whose continued function is not required, but whose failure could reduce the functioning of any Seismic Category I system, structure, or component required to satisfy the requirements of Regulatory Guide 1.29 to an unacceptable safety level or could result in incapacitating injury to occupants of the control room, are designated as Seismic Category II and are designed and constructed so that the Safe Shutdown Earthquake (SSE) would not cause such failure.
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Development of validated design documentation to form the basis for systems interaction configuration control. The dp validated design documentation and updated procedures /
specifications will be provided to TV Electric and can be utilized to facilitate operation, maintenance, and future modifications following issuance of an operating license.
Section 5.1.1 describes the methodology.by which the CPSES systems interaction licensing commitments were identified, the design criteria were established and consolidated in the Design Basis Documents (DBDs),
and the technical and design control procedures were developed.
Section 5.1.2 describes the design validation process, including the indentification of potential targets, development of calculations and determination of zones of influence.
Section 5.1.3 describes the Post Construction Hardware Validation Program (PCHVP) process and the procedures for engineering walkdowns and engineering evaluations required to be implemented to validate that the as-built systems, structures and components are in conformance with systems interaction design documentation.
Section 5.2 presents a summary of the systems interaction portion of the Corrective Action Program (CAP) results. It includes design validation I
dnd Post Construction Hardware Validation Program (PCHVP) results.
1 Section 5.3 describes the quality assurance program implemented for the validation process, including the Ebasco Quality Assurance (QA) audits,
]' TV Electric Quality Assurance (QA) audits and the Engineering Functional Evaluation (EFE) audits.
Section 5.4 describes the corrective and preventive actions.
Appendix A of this Project Status Report (PSR) describes the details of the Corrective Action Program (CAP) resolution of Comanche Peak Response Team (CPRT) issues.
Appendix B of this Project Status Report (PSR) describes the details of the resolution of issues identified during the performance of this systems interaction Corrective Action Program (CAP). These are issues that have been determined to be reportable under the provisions of 10CFR50.55(e).
These issues are identified in Significant Deficiency Analysis Reports (SDARs) initiated by TV Electric.
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4.0 SPECIFIC ISSUES
- (,o) The systems interaction portion of the Corrective Action Program (CAP) resolved all of the systems interaction related Comanche Peak Response Team (CPRT) issues and issues identified during the performance of the CAP. This section presents a listing of all systems interaction related issues addressed in this Project Status Report (PSR). Technical review, resolution, and corrective and preventive actions for all Comanche Peak Response Team (CPRT) issues are described in Appendix A. Technical review, resolution, and corrective and preventive action for all issues identified during the performance of the Corrective Action Program (CAP) are described in Appendix 8.
Issue Al came from Issue Resolution Report (IRR), DAP-E-M-501 (Reference
- 3) related to High Energy Line Breaks (HELBs). Issue A2 came from Issue Resolution Report (IRR), DAP-E-M-507 (Reference 4) related to internally generated missile evaluations. Issue A3 came from the Issue Specific Action Plan (ISAP) related to Control Room Ceiling, ISAP II.d (Reference 40). Issue A4 came from Issue Resolution Report (IRR), DAP-E-EIC-505 (Reference 44) related to Fire Protection.
Comanche Peak Response Team (CPRT) issues are listed as follows with issue numbers corresponding to the subappendix number in Appendix A which addresses the issue:
Issue No. Issue Title
/N Al High Energy Line Break Protection O A2 Missile Hazards A3 Seismic Design of Control Room Ceiling Elements A4 Fire Protection Systes Interaction Issues identified during the performance of the Corrective Action Program (CAP) which have been determined to be reportable under the provisions of 10CFR50.55(e) are listed below with issue numbers corresponding to the subappendix number in Appendix B which addresses the issue:
Issue No, Issue Title B1 SDAR CP-87-57, Computer Modeling Error: COMPARE MOD 1A 82 SDAR CP-87-58, Computer Modeling Error: RELAP-3 4-1 O
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5.0 CORRECTIVE ACTION PROGRAM (CAP) METHODOLOGY AND RESULTS h This section of the Project Status Report (PSR) addresses the methodology and results of the systems interaction portion of the Corrective Action Program-(CAP).
5.1 METHODOLOGY AND WORK PERFORMED The Systems Interaction Program (SIP) evaluates interactions between CPSES Unit 1 and Common systems, structures and components resulting from pipe breaks, internal missile generation and seismically induced failures of non-seismic CPSES Unit I and Common systems, structures and components.
'The objective of the Systems Interaction Program (SIP) activities is to assure that these postulated interactions cannot prevent saf e shutdown of the reactor nor prevent mitigation of the consequences of the event.
The validation activities of the Systems Interaction Program (SIP) are categorized into five (5) groups: high energy line break (HELB), moderate energy line break (MELB), environmental and flooding, internally generated missiles, and seismic /non-seismic interactions.
The methodology and work performed by Ebasco in implementing the systems interaction portion of the Corrective Action Program (CAP) for these five groups are discussed in Section 5.1.2.
5.1.1 Licensing Commitments, Design Criteria and Procedures N Ebasco reviewed the CPSES licensing documentation to identify licensing x -commitments related to systems interaction. The documentation reviewed included the FSAR, SER, SSERs, NRC Regulatory Guides, NRC Inspection and Enforcement (I&E) Bulletins, and TV Electric /NRC correspondence. Ebasco established design criteria to assure compliance with the identified licensing commitments. The design criteria are documented in Design Basis Documents (DBDs) (Reference 5, 6, 7 and 36). Ebasco then developed procedures which encompass the following:
Design criteria; Resolution of Comanche Peak Response Team (CPRT) issues; Ebasco's experience gained through developing and implementing systems interaction programs for several recently licensed and operating United States nuclear power
- plants; Regulatory and professional society guidance.
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The governing procedures implementing the Corrective Action Program (CAP) for systems interaction are shown in Figure 5-1. These procedures assure pd compliance with the design criteria and the resolution of the Comanche Peak Response Team (CPRT) issues. These procedures are used by the systems interaction Corrective Action Program (CAP) personnel to perform engineering walkdowns, analyses, evaluations, calculationr. and to obtain and document as-built data.
5.1.1.1 Verification of Design Criteria, Procedures and Resolution of Issues Technical audits, surveillances and Third Party review have been performed to provide additional assurance that the design criteria are technically correct and embody the systems interaction licensing commitments and that all Commanche Peak Response Team (CPRT) and systems interaction Corrective Action Program (CAP) identified issues have been resolved. To assure that the licensing commitments related to systems interaction have been identified, and appropriate design criteria have been established, the TV Electric Quality Assurance (QA) Program and the Comanche Peak Response Team (CPRT) conducted overviews. TV Electric Quality Assurance (QA) audits were performed as described in Section 5.3. The Comanche Peak Response Team (CPRT) overview is being performed by the TV Electric Engineering Functional Evaluation (EFE) and the TV Electric Technical Audit Program (TAP) as described in Section 5.3. Tenera, L. P. (TERA) is reviewing Ebasco's resolution of the Comanche Peak Response Team (CPRT) issues, resolved in Subappendix A3.
The TV Electric Technical Audit Program (TAP) is auditing the systems
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-' interaction portion of the Corrective Action Program (CAP) to assure that the design criteria are reconciled with the licensing commitments.
Ebasco's resolution of the Comanche Peak Response Team (CPRT) issues is described in Appendix A of this Project Status Report (PSR). Ebasco's resolution of issues identified during the performance of the systems interaction portion of the Corrective Action Program (CAP) is described in Appendix B of this Project Status Report (PSR).
5.1.2 Design Validation Process The Ebasco systems interaction design validation process validated that the design of systems, structures and components complies with the design criteria specified in the Design Basis Documents (DBDs) and provides assurance that the essential systems, structures and components will continue to perform their essential functions when subjected to systems interactions.
The design validation activities were 1) identify potential interaction sources, 2) identify potential interaction targets, 3) determine if the design meets the established design criteria and 4) if the design does not meet the design criteria, develop modifications so that the design conforms to the design criteria.
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n TABLE 5-1 U POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP)
SYSTEMS INTERACTION h Construction Final Acceptance PCHVP Attribute Work Cateaory Attribute Validation Method Piping Identify break location CPE-EB-FVM-SI-20, 34 (References 12 and 19)
Identify structures CPE-EB-FVM-SI-31 that can effect the (Reference 15) zone of influence Essential Identify location CPE-EB-FVM-SI-28, 67 Electrical (References 12 and 27)
Equipment Rotating Identify location CPE-EB-FVM-SI-28, 67 Equipment (Reference 12 and 27)
Identify essential CPE-EB-FVM-SI-67 components and Seismic Category I structures (7, within the zone of
\d influence Valves Identify location CPE-EB-FVM-SI-28, 67 Identify essential CPE-EB-FVM-SI-28 components and Seismic Category I structures within the zone of influence Non-Seismic Identify location CPE-EB-FVM-SI-40 Structure / Components (Reference 26)
Identify Seismic CPE-EB-FVM-SI-40 Category I components within the zone of influence Walls, Floors, Ceilings Identify rooms and CPE-EB-FVM-SI-35, 39 free volumes (References 20 and 23)
Identify vent areas CPE-EB-FVM-SI-35, 39 between rooms
The design validation process included review of original design documentation such as engineering walkdown data, calculations, design p)
(, documents and specifications and development of new documentation as required to demonstrate that the design complies with the design criteria.
The design validation process was categorized into five (5) groups and corresponding Design Validation Packages (DVPs) as identified below:
- 1. High Energy Line Breaks (HELBs)
Safe Shutdown Logics l Calculations
- 2. Moderate Energy Line Breaks (MELBs)
Safe Shutdown Logics Calculations
- 3. Environmental and Flooding Analyses Outside Containment Calculations Engineering Walkdowns for Flow Path Data
- 4. Seismic /Non-Seismic Interactions Calculations
- 5. Internally Generated Missiles Calculations Each Design Validation Package (DVP) contains or references the following items:
Design Basis Documents (DBDs) which serve as the primary basis of design validations Procedures
- 1. Safe Shutdown Logics (SSLs) are methods of modeling by sketches the various ways which a system can achieve its design function. These sketches can be utilized to determine how postulated component faults (i.e., failure or postulated malfunction of a component because of a system interaction) can be evaluated to assure the system will achieve its design function.
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l Design Documents (e.g., calculations, specifications, '
q engineering walkdowns and evaluations)
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Other related documents (e.g., Significant Deficiency Analysis Reports (SDARs))
5.1.2.1 High Energy Line Breaks (HELBs)
High energy line breaks (HELBs)2 may result in the displacement of the pipe (pipe whip) and the discharge of high pressure / temperature fluid (jet impingement). High energy line breaks (HELBs) may also result in increased area temperature, pressure and humidity and may also result in local flooding which is discussed in Section 5.1.2.3.
Safe Shutdown Loaics (SSLs)
Safe shutdown logics (SSLs) were developed for the identification of those systems, structures and components required to safely shut down the reactor and to mitigate the consequences of a postulated pipe break. Safe shutdown logics (SSLs) were reviewed and concurred with by the Corrective Action Program (CAP) organization responsible for validating the system, structure or component design. The Safe Shutdown Logics (SSLs) were developed based on the criteria in the Design Basis Document (DBD)
(Reference 6) and in accordance with Systems Interaction Program (SIP) procedure (Reference 13).
Calculations A
V The postulation of breaks in high energy lines results in systems interaction considerations due to the jet forces emanating from the break. These forces can make the pipe whip and impact objects or the jets can impact objects in their zones of influence. Postulated pipe break locations were obtained from SWEC-PSAS and the NSSS vendor. Additional postulated pipe break locations were developed based on the criteria in the Design Basis Document (DBD) (Reference 6).
Pipe whip and jet impingement zones of influence and pipe whip restraint designs were validated by developing new calculations or by validating orignal calculations to the design criteria in the Design Basis Documents (DBDs) (References 6 and 36) and in accordance with System Interaction Program (SIP) procedures (References 9, 10, 12, 13, 14 and 15).
2 A pipe break in a piping system in which the operating temperature is greater than 200'F or operating pressure is greater than 275 psig.
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5.1.2.2 Moderate Energy Line Breaks (MELBs)
O Moderate ener9y 14ne breeks (met 8s>3 mey resuit 4n the discher9e of process fluid (fluid spray). Moderate energy line breaks (MELBs) may also result in increased area temperature, humidity and local flooding which are discussed in Section 5.1.2.3.
Safe Shutdown Loaics (SSLs)
Safe shutdown logics (SSLs) were developed for the identification of the electrical equipment which is required to safely shut down the reactor and to mitigate the consequences of a postulated pipe break. Safe shutdown logics (SSLs) were reviewed and concurred with by the Corrective Action Program (CAP) organization responsible for validating the electrical equipment design. The safe shutdown logics (SSLs) were developed based on the criteria in the Design Basis Document (DBD) (Reference 6) and in accordance with Systems Interaction Program (SIP) procedures (References 8, 9, 10, 11, 12 and 13).
Calculations Fluid spray zones of influence were validated by developing new calculations to the design criteria in the Design Basis Document (DBD)
(Reference 6) in accordance with System Interaction Program (SIP) procedure (Reference 13).
5.1.2.3 Environmental and Flooding Analyses Outside Contain:nent Environmental and flooding analyses are required in those areas outside containmentsubjecttoincreasesinlogaltemperature, pressure, humidity and in those areas subject to flooding . These interactions may result from high energy line breaks (HELBs), moderate energy line breaks (MELBs),
seismic failure of non-seismic pipe and tanks and from inadvertent operation of fire suppression systems.
3 A pipe break in a piping system in which the operating temperature during normal plant conditions is less than or equal to 200*F and pressure is less than or equal to 275 psig. Those systems that operate less than 2% of their operating time above either of these limits are considered to be moderate energy systems.
4 The validation of the enviornmental and flooding analyses inside containment was performed by SWEC as part of the mechanical portion of the Corrective Action Program (CAP) (Reference 42) 5-5 0
Calculations O o#tside coat inment temPeretere. press re, hvmidity end fiood ieveis were validated by developing new calculations or by validating original calculations. The calculations were based on the design criteria in the Design Basis Document (DBD) (Reference 6) in accordance with Systems Interaction Program (SIP) procedures (References 13, 21 and 22).
Enaineerina Walkdowns for Flow Path Data Engineering walkdowns were performed to obtain as-built data used in validating environmental calculations. The as-built data was used to determine flow paths for water, heat (temperature) and pressure venting within plant areas. Engineering walkdowns were based on the design criteria in the Design Basis Document (DBD) (Reference 6) and were performed in accordance with Systems Interaction Program (SIP) procedures (References 8, 13, 20 and 23).
5.1.2.4 Seismic /Non-Seismic Interactions Seismic events may cause failures in non-seismic systems, structures and components. As a result of such failures, non-seismic systems, structures or components may interact with Seismic Category I and Seismic Category II systems, structures and components.
Calculations fq New calculations were performed to validate the zones of influence that
(./ could result from the failure of non-seismic systems, structures or components. The calculations were based on the design criteria in the Design Basis Document (DBD) (Reference 5) and were performed in accordance with the Systems Interaction Program (SIP) procedure (Reference 13).
Enaineerina Walkdowns and Evaluations Engineering walkdowns and evaluations were performed to identify potential non-seismic sources which could cause interactions with Seismic Category I and Seismic Category II systems, structures or components. These potential non-seismic sources were evaluated using historical seismic data obtained subsequent to actual earthquakes to determine if these sources will maintain their structural integrity following a Safe Shutdown Earthquake (SSE). These engineering walkdowns and evaluations were based on the design criteria in the Design Basis Document (DBD) (Reference 5) and were performed in accordance with the Systems Interaction Program (SIP) procedures (References 13, 25, and 26).
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i 5.1.2.5 Internally Generated Missiles O Internally generated missiles may be ejected from rotating equipment and components in high pressure systems. Potential sources include components such as pumps, motors, fans, valve stems and bonnets, thermowells and turbines (including the main turbine generator).
Calculations Calculations were performed on appropriate missile sources to evaluate the potential for missile ejection. These calculations were based on the design criteria in the Design Basis Document (DBD) (Reference 7) and were performed in accordance with a Systems Interaction Program (SIP) procedure (Reference 13).
5.1.2.6 Interfaces The validation process involves interfaces with TV Electric and with other organizations involved in the Corrective Action Program (CAP).
Organizational interfaces as shown in Figure 5-2 include those with SWEC, SWEC-PSAS, TV Electric, Westinghouse, Ebasco and Impell. Interfaces with these organizations are procedurally controlled to assure:
Consistency of design criteria Completeness of the information incorporated in each Design Validation Package (DVP)
O V -
Proper transfer of design data between interfacing organizations Uniform application of design control procedures Coordination of corrective and preventive actions 5.1.2.7 Final Reconciliation Process The purpose of the final reconciliation process is to consolidate design validation analyses, hardware modification and inspection documentation to assure consistency of the systems interaction design documentation with the hardware installation. The final reconciliation of the systems interaction design incorporates the following:
The Post Construction Hardware Validation Program (PCHVP) results Resolution of systems interaction related Comanche Peak Response Team (CPRT) issues 5-7 O
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I Final reconciliation includes confirmation that the interfacing 3 organizations have accepted the Systems Interaction Program (SIP) results i as compatible with their validated design. Interfacing organizations are )
depicted on Figure 5-2. j In addition, open items, observations and deviations related to the systems interaction portion of the Corrective Action Program (CAP) that were identified by the TV Electric Technical Audit Program (TAP) and the Engineering Functional Evaluation (EFE) are resolved prior to the completion of the reconciliation phase. Open items from TV Electric Significant Deficiency Analysis Reports (SDARs) (10CFR50.55(e)) are resolved during the final reconciliation process. At the conclusion of final reconciliation, the CPSES Unit 1 and Common Design Validation Packages (DVPs) are compiled.
5.1.3 Post Construction Hardware Validation Program (PCHVP)
The Post Construction Hardware Validation Program (PCHVP) (Reference 43) is the portion of TV Electric's Corrective Action Program (CAP) which validates the final acceptance attributes for safety-related hardware.
The Post Construction Hardware Validation Program (PCHVP) process is shown diagrammatically in Figure 5-3.
The input to the Post Construction Hardware Validation Program (PCHVP) for the system interaction portion of the Corr basedontheDesignBasisDocuments(DBDs)getiveActionProgram(CAP)is
.The DBDs, which were developed during the Corrective Action Program (CAP) design validation process, incorporate the licensing commitments and design criteria.
Final acceptance inspection requirements based on the Design Basis Documents (DB0s) were used to develop the Post Construction Hardware Validation Program (PCHVP) attribute matrix. This matrix will form a complete set of final acceptance attributes identified for installed hardware. The Post Construction Hardware Validation Program (PCHVP), by 5 The systems interaction discipline is responsible for validating that systems, structures and components, which are installed in accordance with other disciplines' installation specifications, can accommodate the interactions described in Section 3.0. The systems interaction discipline is not responsible for the specification of installation requirements for systems, structures or components.
Therefore, there are no systems interaction specific installation specifications. The systems interaction final acceptance attributes that are validated during the systems interaction Post Construction Hardware Validatior. Program (PCHVP) are contained in l the systems interaction Design Basis Documents (DBDs).
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either physical validations or through an engineering evaluation methodology, assures that each of the attributes defined in the attribute
()
n matrix is validated.
Physical validation of an attribute is performed by engineering walkdown, for accessible components. Engineering walkdowns are controlled by appropriate Field Verification Method (FVM) procedures (References 12, 15, 18, 19, 20, 23, 26 and 27).
The Post Construction Hardware Validation Program (PCHVP) engineering evaluation depicted in Figure 5-3 is procedurally controlled to guide the Corrective Action Program (CAP) responsible engineer through the evaluation of each item on the attribute matrix to be dispositioned by the engineering evaluation method. Disposition of each attribute will be clearly documented. If the technical disposition of the final acceptance attribute is "not acceptable" or the attribute cannot be dispositioned based on available information, an alternate plan consisting of additional evaluations, testing, inspections /walkdowns or modifications, as necessary, will be developed to demonstrate and document the acceptability of the attribute.
Recommendations from the Comanche Peak Response Team (CPRT) effort comrrise a portion of the evaluation. A major component of the Comanche Pen Response Team (CPRT) program has been the inspection of a cc.nprehensive, random sample of existing hardware using an independently derived set of inspection attributes. The inspection was performed and the results were evaluated by Third Party personnel in accordance with G Appendix E to the Comanche Peak Response Team (CPRT) Program Plan. The V scope of the inspection covered the installed safety-related hardware by segregating the hardware into homogeneous populations (by virtue of the work activities which produced the finished product). Samples of these populations were inspected to provide reasonable assurance of hardware acceptability in accordance with Appendix D to the Comanche Peak Response Team (CPRT) Program Plan.
Corrective action recommendations were made to TV Electric based on the evaluated findings when a Construction Deficiency existed, an Adverse Trend existed, or an Unclassified Trend existed as defined in accordance with Appendix E to the Comanche Peak Response Team (CPRT) Program Plan.
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The Post Construction Hardware Validation Program (PCHVP) assures that all Comanche Peak Response Team (CPRT) recommendations are properly
(- dispositioned.
Figure 5-3 illustrates that during the evaluation of a given attribute from the Post Construction Hardware Validation Program (PCHVP) attribute matrix, the initial task of the Corrective Action Program (CAP) responsible engineer is to determine if any of the following statements are true:
- a. The attribute was recommended for reinspection by the Comanche Peak Response Team (CPRT).
- b. Design validation resulted in a change to design or to a hardware final acceptance attribute that is more stringent than the orQinal acceptance attribute, or Comanche Peak Response Team (CPRT) did not inspect the attribute.
- c. Design validation resulted in new work, including modification of the existing hardware.
If the Comanche Peak Response Team (CPRT) had no recommendations and items b or c above do not apply, the attribute under consideration will be accepted. This conclusion is justified by the comprehensive coverage of the Comanche Peak Response Team (CPRT) reinspection and the consistently conservative evaluation of each finding from both a statistical and adverse trend perspective. The attribute matrix is then updated to Q
V indicate that neither the engineering walkdown nor Quality Control (QC) inspection of the attribute is necessary. A completed evaluation package is prepared and forwarded to the Comanche Peak Engineering (CPE) organization for concurrence. The evaluation package becomes part of the Design Validation Package (DVP) after Comanche Peak Engineering (CPE) concurrence is obtained.
If any of the three statements are true, it is assumed that the final acceptance attribute must be further evaluated as follows:
Determine Attribute Accessibility The Corrective Action Program (CAP) responsible engineer will determine if the attribute is accessible. If the attribute is accessible, a field validation of the item's acceptability will be performed and documented in accordance with an approved Field Verification Method (FVM).
If the Corrective Action Program (CAP) responsible engineer reaches the conclusion that the attribute is inaccessible, an engineering evaluation will be conducted by technical disposition of available information.
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After completing the attribute accessibility review, the responsible engineer will update the attribute matrix as necessary to reflect the fj t results of that review.
Technical Disposition The Corrective Action Program (CAP) responsible engineer identifies the data to be considered during the subsequent technical disposition process. Examples of such items used in this disposition may include, but are not limited to:
Historical documents (e.g., specifications, procedures, inspection results)
Comanche Peak Response Team (CPRT) and external issues Construction practices Quality records ,
Test results Audit reports Authorized Nuclear Inspection (ANI) records A -
Surveillance reports V -
NCRs, DRs, SDARs and CARS Inspections conducted to date Results of Third Party reviews Purchasing documents Construction packages Hardware receipt inspections After compiling the data identified as pertinent to the attribute, the technical disposition will be performed. The actual steps and sequence of actions required for each technical disposition may differ; however, the tangible results from each technical disposition will be consistent.
These results will include as a minimum:
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A written description of the attribute; f) A written justification by the Corrective Action Program (CAP) responsible engineer for acceptance of the. attribute; A written explanation for the logic utilized to conclude that the attribute need not be field ,
validated; A chronology demonstrating that the attribute has not been significantly altered by redesign; All documents reviewed to support the disposition; Concurrence of the acceptance of the attribute's validity by Comanche Peak Engineering (CPE).
If the Corrective Action Program (CAP) responsible engineer concluded that the data evaluated represented evidence of the attribute's acceptability, the conclusion will be documented. The documentation will be reviewed and approved by Comanche Peak Engineering (CPE) and filed in the Design Validation Package (DVP). If the Corrective Action Program (CAP) responsible engineer determines that the data reviewed does not provide evidence of the attribute's acceptability, the documentation will explain why the attribute cannot be accepted and recommend an alternative course of action. This alternative course of action may take various forms such (3 as making the attribute accessible and inspecting it, or testing to V support the attribute's acceptability. This alternative plan, after approval by Comanche Peak Engineering (CPE), will be implemented to validate the attribute.
In summary, the Post Construction Hardware Validation Program (PCHVP) is a comprehensive process by which each attribute in the PCHVP attribute matrix is validated to the validated design. The TV Electric Technical Audit Program (TAP) audits the Post Construction Hardware Validation Program (PCHVP). This audit program is complemented by the Engineering Functional Evaluation (EFE) being performed by an independent team comprised of Stone & Webster, Impell and Ebasco engineering personnel working under the Stene & Webster Quality Assurance (QA) Program and subject to direction by the Comanche Peak Response Team's (CPRT) Senior Review Team (SRT). The Post Construction Hardware Validation Program (PCHVP) provides additional assurance that the validated design has been l implemented for safety-related hardware.
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Ebasco prepared Post Construction Hardware Validation Program (PCHVP)
, implementation procedures for the systems interaction portion of the
(') Corrective Action Program (CAP). The hardware validation process includes modifications, whenever necessary, to bring the systems, structures and components into compliance with the validated design. The tabulation ~of systems interaction final acceptance attributes is presented in Table 5-1.
The Post Construction Hardware Validation Program (PCHVP) is being implemented in accordance with appropriate Field Verification Method (FVM) procedures to validate all attributes in the attribute matrix as described below.
Interactions between essential systems, structures and components and high energy line break (HELB) pipe whip and jet impingement zones of influence are being validated by engineering walkdown. Interactions with non-essential components are also considered to assure that secondary interactions do not effect essential systems, structures or components.
Where there are interactions, the targets are evaluated to assure that they continue to perform their essential functions of safely shutting down the reactor and of mitigating the consequences of the postulated pipe break. These engineering walkdowns and evaluations are based on the design criteria in the Design Basis Document (DBD) (Reference 6) and are performed in accordance with Systems Interaction Program (SIP) procedures (References 9, 10, 13, 15, 16, 17, 18 and 19).
Interactions between essential electrical equipment and fluid spray are validated by engineering walkdowns. Where there are interactions, the targets are evaluated to assure that the electric equipment can continue s to perform its essential functions of safely shutting down the reactor and of mitigating the consequences of the postulated pipe break. These engineering walkdowns and evaluations are based on the design criteria in the Design Basis Document (DBD) (Reference 6) and are performed in accordance with Systems Interaction Program (SIP) procedures (References 9, 10,11, 13, 16,.18 and 20).
Engineering walkdowns are performed to obtain as-built data used in validating flooding calculations. Where there are ficoding interactions, the targets are evaluated to assure that they can continue to perform their essential functions of safely shutting down the reactor and of mitigating the consequences of the postulated event. Engineering walkdowns are based on the design criteria in the Design Basis Document (DBD) (Reference 6) and are performed in accordance with Systems Interaction Program (SIP) procedures (References 8, 13, 20 and 23).
Engineering walkdowns and evaluations are performed to identify potential non-seismic sources which could cause interactions with Seismic Category I and Seismic Category 11 systems, structures or components. These potential non-seismic sources are evaluated using historical seismic data 5-13 O
obtained subsequent to actual earthquake to determine if these sources will maintain their structural integrity following a Safe Shutdown Earthquake (SSE). These engineering walkdowns and evaluations are based
("] on the design criteria in the Design Basis Document (DBD) (Reference 5) and are performed in accordance with the Systems Interaction Program (SIP) procedures (References 13, 25, and 26)
Engineering walkdowns and evaluations are performed to identify interactions between missiles and targets. Targets are evaluated to assure that they can continue to perform their essential functions of safely shutting down the reactor and of mitigating the consequences of a postulated missile generation event. Engineering walkdowns and evaluations are based on the design criteria in the Design Basis Document (DBD) (Reference 7) and are performed in accordance with Systems Interaction Program (SIP) procedures (References 12, 13, 16, 17 and 27).
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5.2 RESULTS
(")
v 5.2.1 Design Validation Results-The validation of the CPSES Unit I and Common systems interaction design has been completed as described in this Project Status Report (PSR). This effort included:
Development of 206 safe shutdown logics (SSLs)
Validation of 62 pipe movement calculations Validation of 41 environmental calculations Validation of 5 flooding calculations Validation of 2 missile calculations Validation of 2 procurement specifications Resolution of 148 Tenera, L.P. (TERA) Discrepancy Issue Reports (DIRs)
Development of zone of influence sketches The results of this design validation effort determined that some hardware modifications were required. These included modifications to pipe whip restraint systems and modifications to non-seismic components to meet Seismic Category Il requirements.
This design validation effort has demonstrated that CPSES Unit 1 and Cc.nmon systems interaction design and associated documentation are in conformance with CPSES licensing commitments and that the systems, structures and components are designed to perform their safety functions.
O 5.2.2 east Coastructioa serdwere veiidation ero9 rem (eCave)
Results The Post Construction Hardware Validation Program (PCHVP) is being implemented through the validation of final acceptance attributes for systems, structures and components for CPSES Unit I and Common as discussed in Section 5.1.3.
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5.3 QUAllTY ASSVRANCE (QA) PROGRAM O-d The Systems Interaction Program (SIP) is being conducted at two locations:
Ebasco's New York office, and the CPSES site. Systems interaction activities in New York are performed in accordance with the Ebasco-Quality Assurance (QA) Program and activities at the CPSES site are performed in accordance with the TV Electric Quality Assurance (QA) Prograa.
5.3.1 . TV Electric Quality Assurance (QA) Program
- TU Electric implements the Quality Assurance (QA) Program described in Chapter 17 of the CPSES FSAR which is in compliance with 10CFR50, Appendix B and has been reviewed and accepted by the NRC. Section 17.1 of the-FSAR addresses the Quality Assurance (QA) requirements for all phases of design and construction of CPSES.
TV Electric has developed and implemented procedures which meet the requirements of ANSI N45.2.ll (Reference 41) and NRC Regulatory Guide 1.64 (Reference 29) to control the Systems Interaction Program (SIP) conducted by Ebasco at the CPSES site. The TV Electric Quality Assurance (QA)
Program requires that detailed procedures covering the performance of the Systems Interaction Program (SIP) be developed and issued. These procedures are contained in the CPSES Engineering and Construction-Engineering (ECE) Procedures Manual. The ECE Procedure Manual includes procedures applicable to the validation efforts performed under TV Electric's Quality Assurance (QA) Program. These procedures also direct the organization and format of documents used to validate the design and the hardware. These procedures were distributed to System O
Interaction Program (SIP) supervisory personnel and are readily available for SIP personnel use. The issuance of these procedures was followed by detailed training programs for the applicable personnel.
TV Electric Quality Assurance (QA) has developed 0.nd implemented procedures to perform audits which meet the requirements of ANSI-N45.2.12 (Reference 34) and NRC Regulatory Guide 1.144 (Reference 31). These procedures hage been implemented by the Internal Audit, Technical Audit Program (TAP) and Engineering Surveillance Groups to assure that the
. System Interaction Program (SIP) is accomplished within the requirements
.of the TV Electric' Quality Assurance (QA) Program.
5 The TV Electric Technical Audit Program (TAP) has been in effect since January 1987. Prior to January 1987, the TV Electric Quality
- i Assurance (QA) Department performed audits of selected engineering service contractors using technical specialists as part of its vendor audit program.
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Audits to verify the implementation of design procedures and to assess the technical adequacy of the Systems Interaction Program (SIP) were performed
(] under the TV Electric Technical Audit Program (TAP). Audits to verify V compliance with programmatic aspects of the Systems Interaction Program (SIP) were periodically performed by the TV Electric Internal Audit Group.
Surveillances were conducted to verify the implementation of procedures and to assess the technical adequacy of the Systems Interaction Program (SIP) by the TV Electric Quality Assurance (QA) Engineering Surveillance Group.
5.3.2 Ebasco Quality Assurance (QA) Program Ebasco implements their Corporate Nuclear Quality Assurance (QA) Program described in Ebasco's Topical Report ETR-10ul (Reference 32), which is in conformance with 10CFR50, Appendix B, and has been approved by the NRC.
ETR-1001 addresses all phases of completion of a nuclear power plant including design, procurement and construction. ETR-1001 has been modified to make it CPSES project specific, providing additional levels of detail to make calculation preparation, criteria seiection and design interfaces consistent with the TV Electric Corrective Action Program (CAP). Ebasco's Corporate Nuclear Quality Assurance (QA) Program, as modified for CPSES, has been reviewed and approved by TV Electric's QA organization.
Ebasco developed and issued a Manual of Procedures (Reference 33) specifically related to CPSES work. This Manual of Procedures, includes specific procedures to supplement the Ebasco standard Engineering, O "ocieer. ero;ect amo erocvreme#t erocee#res seaueis. The 8 mv 1 of Procedures includes procedures applicable to the design validation efforts performed under Ebasco's Quality Assurance (QA) Program. These procedures are issued to direct the organization and format of documents used to validate the design. These procedures are issued so that calculation documentation will be prepared in a uniform and complete manner. These procedures were distributed to Systems Interaction Program (SIP) supervisory personnel and are readi1y available for SIP personnel use.
The issuance of these procedures was followed by detailed training programs for the applicable personnel.
Audits were periodically conducted by Ebasco's Quality Assurance (QA)
Engineering-Auditing Group, covering work done in New York for systems interaction. These audits were performed in accordance with procedures approved by Ebasco's Quality Assurance (QA) Department and satisfy the requirements in ANSI N45.2.12 and NRC Regulatory Guide 1.144 concerning QA auditing. These audits cover compliance with applicable procedural requirements in the Manual of Procedures. Management audits are periodically conducted to review the Quality Assurance (QA) Department's compliance with its procedures.
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Subcontractors were evaluated and qualified to provide services or products. In addition, a survey was conducted at the subcontractors' O facility to evaluate how they implement their Quality Assurance (QA)
Program.
5.3.3 Systems Interaction Audits, Surveillances and Inspections The adequacy and implementation of these Quality Assurance (QA) Programs and the technical adequacy of the work performed under these QA Programs were extensively audited and surveilled by the TV Electric Technic-1 Audit Program (TAP), TV Electric Quality Assurance (QA) Engineering Surveillance Group, the TV Electric Quality Assurance (QA), and the Ebasco Quality Assurance Engineering (QA) Audit Group.
A total of 9 audits and surveillances of the Systems Interr an Program (SIP) were performed by these organizations to date for CPSES Unit 1 and Common as shown on Table 5-2. To date, more than 2000 work hours have been expended by TV Electric Quality Assurance (QA) and Ebesco Quality Assurance (QA) in activities directly attributable to the systems interaction portion of the Corrective Action Program (CAP) (i.e.,
training, procedure development, auditing and support from the QA Director's staff).
The TV Electric Technical Audit Program (TAP) and the TV Electric Quality Assurance (QA) Engineering Surveillance Group evaluated the technical adequacy of the engineering product (e.g., Design Basis Documents (DBDs),
calculations, specifications, engineering walkdowns and evaluations).
O The foiiewing list of eudit and surveiilence sub;ects describes the depth of review that has been performed:
Adequacy of project technical and design control procedures Technical adequacy and documentation of calculations Non-Conformance Reports (NCRs)
Specification validation Calculation validation Records maintenance Generic Issue Report (GIR)
Discrepancy Issue Reports (DIRs)
Design Basis Documents (DBDs)
Indoctrination and training 5-18 O
Licensing activities
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Corrective Action Requests (CARS)
Personnel qualification and experience verification Design modifications These audits and surveillances collectively assessed the adequacy and implementation of the applicable Quality Assurance (QA) Program. These audits and surveillances have resulted in enhancements to the procedures and methods and thus contributed to the overall quality of the CPSES design.
In addition to the audits and surveillance described above, TV Electric has initiated the Engineering Functional Evaluation (EFE) (Reference 35).
The EFE began auditing the systems interaction portion of the Corrective Action Program (CAP) in May 1987. The Engineering Functional Evaluation (EFE) is an overview program which is performing an independent, in depth technical evaluation of the Corrective Action Program (CAP) to provide additional assurance that the CAP is effectively implemented. The Engineering Functional Evaluation (EFE) is conducted under the SWEC Quality Assurance (QA) Program and is directed by a Program Manager who reports to the SWEC Chief Engineer, Engineering Assurance. The Engineering Functional Evaluation (EFE) is performed by highly qualified and experienced engineers from SWEC, Impell and Ebasco who have not been involved with previous engineering and design work at CPSES. The Engineering Functional Evaluation (EFE) is performed in a formal, hm preplanned and fully documented manner to provide objective evidence of completion of the planned scope of the evaluation and to provide documentation of its results and conclusions. The Engineering Functional Evaluatica (EFE) is comparable in scope, level of effort and personnel qualifications to integrated, independent design inspections and verifications conducted at other nuclear plants.
The audits and surveillances collectively represent a very detailed and complete assessment of the following:
Adequacy of the Quality Assurance (QA) Programs.
Implementation of the Quality Assurance (QA) Programs.
Technical adequacy of the design criteria and procedures.
Implementation of the design criteria and procedures.
In some cases, these audits and surveillances identified the need for procedure modifications and specific calculation revisions to incorporate an omission or required clarification. Additional training in implementation of procedures in these cases was provided as required.
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Each item identified in the audit report was carefully reviewed and response to all items was provided. Any corrective / preventive actions determined necessary as a result of the audit findings were identified and
(] v implemented. Proper implementation of commitments made in response to the audit items are verified during subsequent audits.
The NRC Office of Special Projects (OSP) conducted inspections of the Systems Interaction Program (SIP) beginning in October 1987. The inspections involved technical evaluations of the design validation process and focused primarily on the review of calculations, procedures and Design Basis Documents (DBDs), and their compliance with licensing commitments.
In summary, an appropriate level of attention has been given to the quality of all Systems Interaction Program (SIP) activities; the TV Electric and Ebasco Quality Assurance (QA) Programs are appropriate for the scope of work; project performance has been demonstrated to be in compliance with the QA Programs; and appropriate corrective and preventive actions have been taken whenever they were required.
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5.4 CORRECTIVE AND PREVENTIVE ACTIONS O Ebasco has developed Design Basis Documents (DBDs) and procedures to implement the systems interaction portion of the Corrective Action Program (CAP). The Design Basis Documents (DBDs) contain the design criteria for validating the systems interaction design of CPSES Unit I and Common. The procedures assure compliance with the design criteria and the resolution of the Commanche Peak Response Team (CPRT) issues. As a result of the systems interaction portion of the Corrective Action Program (CAP), the CPSES Unit I and Common systems, structures and components are validated as being capable of performing their safety-related functions when subjected to systems interaction.
This validation is documented in the calculations, evaluations and specifications which are contained in the Design Validation Packages (DVPs). This validated design documentation will be provided to TV Electric at the completion of the Corrective Action Program (CAP). The Design Basis Documents (DBDs) and procedures used for validation will also be provided to Comanche Peak Engineering (CPE). The validated design documentation and Design Basis Documents (DBDs) and procedures can provide the basis for configuration control of CPSES systems, structures and components and can be utilized by TV Electric to facilitate operation, maintenance and future modifications in accordance with licensing commitments following issuance of an operating license.
Interfaces between organizations have been identified and addressed in detail within the procedures. Those systems interaction interfaces are discussed in Section 5.1.2.6.
Practical experience has been provided to Comanche Peak Engineering (CPE) engineers who have worked alongside Ebasco engineers during the ongoing validation process. Experience gained by Comanche Peak Engineering (CPE) engineers included changes in design documents, and familiarization with procedures and regulatory requirements.
TV Electric Comanche Peak Engineering (CPE) is developing a program to assure a complete and orderly transfer of the engineering and design function from Ebasco to CPE. The program provides for the identification of those tasks presently being performed by Ebasco which are to be transferred to Comanche Peak Engineering (CPE) and the identification of all procedures, programs, training and staffing requirements. The program is based upon three prerequisites: (a) the Corrective Action Program (CAP) effort to support plant completion is finished for the particular task; (b) the systams interaction Design Validation Packages (DVPs) are complete; and (c) any required preventive action taken, as discussed in Appendices A and B, is complete.
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FIGURE 5-1 CORRECTIVE ACTION PROGRAM ( CAP)
SYSTEMS INTERACTION Q FLOW CHART AND GOVERNING PROCEDURES UEVELOP DESIGN BASIS DOCUMENTS ( DBDs)
DB D-ME -005 DBD-+tE -OO 7 DBD-CS-088 g DBD-ME-105
- _ PERFORM DESIGN VALICATION CPE-ECE-2. 24 C P E -E ME -2. 2 4 -06 C P E -E ME -2. 2 4 -02 CPE-EME -2. 2 4 -07 C P E-E ME -2. 2 4 -0.$ CPE-EME-2. 2 4 {8 CPE-EME-2. 24-04 C PE-E ME-2, 2 4 -09
- CPE-EME-2. 24-05 p CPE-EME-2.24-10 b
Q o'
O IS YES DESIGN
{
g MODIFICATION L MODIFICATIONS REQUIRED
$- ?
ECE 5. 01-I3 o NO POST CON TRUCTION BUILD / NSPECT HARDWARE VALIDATION -
MODIFICATION PROGRAM ( PCHVP)
EME-2,24-01 C P E -E B-F V M-S I-35 CPE-EB-F VM-SI-2 8 CP E-E B-f VM-SI-3 9 C P E-E B -F VM-S I-31 C PE -E B-F V M-S I-40 C P E-E B -F VM-S I-3 4 C P E-E B-F VM-S I-6 7 Y
FINAL DESIGN RECONCILIATION ECE 5.01-I3 y ECE-AD-S IS YES ADDITIONAL VALIOATION EQUIRE
?
p ND FINAL DOCUMENTATION
( DESIGN VALIDATION PACK AGES)
CPE-ECE -2. 2 4 ECE-2.13
FIGURE 5-2 CORRECTIVE ACTION PROGRAM ( CAP)
O# INTERFACES SYSTEMS INTERACTION PROGRAM ( SIP)
C# SWE C-PSAS RESOLUTION OF - PIPE BREM LOC ATION TECHNICAL ISSUES - PIPE MOVEMENTS AT PIPE TU ELECTRIC RUPTURE RESTRAINT
- REVIEW RESOLUTICN OF ATIONS d CPRT ISSUES COMANCH PE AK ENGINEERING p - REVIEW PROCEDURES AND - KT ITINOEMENT, PIPE o RE SUL TS OF VALIDATION MANA0E T NT CF hHIP IMPACT AND MISSILE O PROGRAM CORGECTIVE ACTION PROGRAM , IMPACT e
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w CONDUIT SUPPCRTS TRAIN INSTRUNNTATICN AND C S 2 *. FIRE PROTECTIcm M & EQUIP 4NT OVALIFICATICN CONTROLS AND y ELECTRICAL
- FIRE PROTECTION SPR AT w ,_
FLOW RATES - 5TSTEMS AND COPPONENTS
- SEISMIC CAP ABILITY OF ESASCO REQUIRED FCR SAFE EQUIPPENT AND SUPPORTS SHUTDC W
- EQUIPMENT QUAL IFIC ATION SYSIE 6 INIERACIION - SEISMIC CAPASILITY OF b - PRESSURE AND TEMPERATURE - HIGH ENERGY LINE PROFILES OUTSIDE BREAK - DIFFERENTIAL PRESSURE CONTAINMENT - PODERATE ENERGY LINE ON WALLS CUTSIOE
- FLOOCING LEVELS OUTSIDE 3agu CONTAINTNT CONT AINME NT l - ENVIRONMENTAL ANO - FLOODING l EVEl S ON
- ESSENTIAL EQUIPMENT WALLS OUTSICE FLC00!NG ANALYSES.
CONT AINME N T OUTSICE CONTAINK NT - AT IWINOEMENT, PIPE
- SEISMIC /NON-SEISMIC INTER ACT IO'sS WIP IMPACT AND MISSILE U WN EV ALUATIONS ILE AY S E B ASCO C ASLE TRAY SUPPORTS, WESTINGHOUSE CONOUIT SUPPORTS TRAIN A. B & TRAIN C)28, HyAC
- PIPE BRE AK LCCATION
- PIPE MOYE T NTS AT PIPE -- SEISMIC C APA81 LIT Y OF RUPTURE RESTRAINT COMPONENTS AND SUPPOR TS L OC ATIONS l
- JE T IMPIN GE 4 N T, PIPF. - [M ACfIp @}%e MLE WIP IT ACT AND MISS!LE I IWhC T O
FIGURE 5-3 POST CONSTRUCTION HARDWARE VALIDATION PROGRAM ( PCHVP) : l pmTR13 Mvit0 Pette? l .
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TABLE 5-1 O eosT constauctio" "^aow^at vatto^tio" eaoca^" (ec"ve) SYSTEMS INTERACTION Construction Final Acceptance PCHVP Attribute Work Cateaorv Attribute Validation Method Piping Identify break location CPE-EB-FVM-SI-28, 34 (References 12 and 19) Identify structures CPE-EB-FVM-SI-31 that can effect the (Reference 15) zone of influence Essential Identify location CPE-EB FVM-SI-28, 67 Electrical (References 12 and 27) Equipment Rotating Identify location CPE-EB-FVM-SI-28, 67 Equipment (Reference 12 and 27) Identify essential CPE-EB-FVM-SI-67 components and Seismic Category I structures within the zone of influence J Valves Identify location CPE-EB-FVM-SI-28, 67 Identify essential CPE-EB-FVM-SI-28 components and Seismic Category I structures within the zone of influence Non-Seismic Identify location CPE-EB-FVM-SI-40 Structure / Components (Reference 26) i Identify Seismic CPE-EB-FVM-SI-40 Category I components within the zone of influence Walls, Floors, Ceilings Identify rooms and CPE-EB-FVM-SI-35, 39 free volumes (References 20 and 23) Identify vent areas CPE-EB-FVM-SI-35, 39 between rooms l l O 1
O O O TABLE 5-2
SUMMARY
OF AUDITS AND SURVEILLANCES AUDITS AUDIT AUDITING AUDIT AUDIT NUMBER ORGANIZATION LOCATION DATES OF AUDIT REPORT TRANSMITTAL RESPONSE TRANSMITTAL 2859 Ebasco QA New York Mar 24-26, 1987 Apr 1, 1987 Apr 17, 1987 2884 Ebasco QA New York Dec 22-29, 1987 In Progress ATP-87-4S TU Electric CPSES Aug 17-Sep 8, 1987 Oct 13,1987 Nov. 9, 1987 TAP ATP-87-62 10 Electric CPSES Nov 17-23, 1987 December 29, 1987 In Progress TAP SURVEILLANCES - TU ELECTRIC OUALITY ASSURANCE ENGINEERING SURVEILLANCE SURVEILLANCE SURVEILLANCE REPORT NUMBER LOCATION DATES TRANSMITTAL ES-87-008 CPSES Apr 7-23, 1987 May 6, 1987 ES-87-019 CPSES May 11-20, 1987 June 16, 1987 ES-87-020 CPSES May 22-June 3, 1987 June 18, 1987 ES-87-023 CPSES June 15-22, 1987 June 30, 1987 ES-87-047 CPSES Sep 4-23, 1987 Oct' 16, 1987
6.0 REFERENCES
O 1. TV Electric letter No. TXX-6631, W.G. Counsil to U.S. Nuclear Regulatory Commission, Comanche Peak Programs, August 20, 1987
- 2. TV Electric Letter No. TXX-6500, W.G. Counsil to U.S. Nuclear Regulatory Commission, Comanche Peak Programs, June 25, 1987
- 3. TERA - DAP E-M-501, "Evaluation of High Energy Line Breaks", Letter No. DAP-L-161, October 2, 1986
- 4. TERA - DAP-E-M-507, "Missiles Hazards", Letter No. DAP-L-157, October 1, 1986
- 5. CPSES Design Basis Document DBD-ME-005 "Seismic /Non-Seismic Systems Interaction Program", Revision 1, December 30, 1987
- 6. CPSES Design Basis Document DBD-ME-007 "Pipe Break Postulation and Effects", Revision 1, January 8, 1988
- 7. CPSES Design Basis Document DBD-ME-105 "Missile Postulation and Effects", Revision 1, December 31, 1987
- 8. Procedure EME-2.24-03 "Systems Interaction Program Essential Component Lists", Revision 1, October 19, 1987
- 9. Procedure EME-2.24-06 "Systems Interaction Program Sketches",
Revision 0, August 18, 1987
- 10. Procedure EME-2.24-07 "Systems Interaction Program Database Management", Revision 1, September 16, 1987
- 11. Procedure EME-2.24-08 "Systems Interaction Program Shutdown Analysis", Revision 0, August 18, 1987
- 12. Field Verification Method CPE-EB-FVM-DS-28 "Location Verification of Components", Revision 1, July 16, 1987
- 13. Procedure ECE 2.24, "Systems Interaction Program", Revision 0, August 18, 1987 i 14. Procedure EME-2.24-05 "Pipe Rupture Books", Revision 0, August 18, 1987
- 15. Field Verification Method CPE-EB-FVM-SI-31 "Field Review of Pipe Rupture Zone of Influence Sketches", Revision 1, July 16,1987
- 16. Procedure EME-2.24-09 "Engineering Analysis of Systems Interaction Program Secondary Effects", Revision 0, August 18, 1987 6-1 lO l
l
- 17. Procedure EME-2.24-10 "Systems Interaction Program Interaction Evaluations", Revision 0, August 18, 1987 O 18. Field Verification Method CPE-EB-FVM-SI-51 "Target Evaluation Data", Revision 0, July 16, 1987
- 19. Field Verification Method CPE-EB-FVM-SI-34 "HELB Target Identification", Revision 1, July 16, 1987
- 20. Field Verification Method CPE-EB-FVM-SI-35 "MELB Interaction Identification", Revision 0, July 16,1987
- 21. Procedure EME-2.24-02 "Flooding Analyses", Revision 1, October 6, 1987
- 22. Procedure EME-2.24-04 "Environmental Analyses", Revision 1, October 6, 1987
- 23. Field Verification Method CPE-EB-FVM-SI-39 "Environmental Analysis As-Built Walkdown Data", Revision 0, July 16,1987
- 24. Regulatory Guide 1.29, "Seismic Design Classification", Revision 2, February 1976
- 25. Procedure EME-2.24-01 "Evaluation of Seismic /Nonseismic Interactions", Revision 1, October 5, 1987
- 26. Field Verification Method CPE-EB-FVM-SI-40 "Seismic /Non-Seismic Oi Walkdown", Revision 1, October 1,1987
- 27. Field Verification Method CPE-EB-FVM-SI-67 "Missile Target Identification", Revision 0, July 16, 1987
- 28. Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Appendix D, CPRT Sampling Policy, Applications and Guidelines, Revision 1, January 31, 1986, and Appendix E, Resolution of Discrepancies Identified by the CPRT, Revision 3, June 18, 1987
- 29. NRC Regulatory Guido 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants", Revision 2, June 1976
- 30. ANSI /ANS 58.2 1980, Standard Design Basis for Protection of light Water Nuclear Power Plants Against Effects of Postulated Pipe Rupture
- 31. NRC Regulatory Guide 1.144, "Auditing of Quality Assurance Programs for Nuclear Power Plants", Revision 1, September 1980 6-2 O
- 32. Ebasco's Topical Report ETR-1001, Ebasco Nuclear' Quality Assurance Program Adapted for TV Electric CPSES, Revision 5
(} \ 33. Ebasco Manual of Procedures for CPSES, October 26, 1987
- 34. American National Standards Institute (ANSI) N45.2.12, "Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants", Revision 0
- 35. TV Electric Letter No. TXX-6676, W.G. Counsil to U.S. Nuclear Regulatory Commission Technical Audit Program and Engineering Functional Evaluation, September 8,1987
- 36. CPSES Desion Basis Document DBD CS-088 "Pipe Whip Restraints Cesign and Analysis", Revision 0, September 1, 1987
- 37. TV Electric CPSES Unit 1 & 2 "Design Basis Consolidation Program Plan", Ebasco Services, Inc., Revision 1, April 11,1987.
- 38. Comanche Peak Specification CPE-S-1021 "Commodity Clearance Specification", Revision 0, dated June 5, 1987.
- 39. Field Verification Method CPE-SWEC-FVM-CS-068, "Commodity Clearance", Revision 0, dated July 31, 1987.
- 40. Issue Specific Action Plan, Control Room Ceiling ISAP II.d.,
Revision 1, October 21, 1987 O 41. Americea "etienei Stenoards imstitute (^"si) "4s.2.11, a aiity Assurance Requirements for the Design of Nuclear Power Plants, Revision 2, May 1973
- 42. Mechanical Project Status Report (PSR), Revision 0
- 43. Engineer.ing Construction Procedure ECE-9.04, "Control of the Post Construction Hardware Validation Program Manual", dated September 1987
- 44. TERA-DAP-E-EIC-505, "Fire Protection", Letter No. DAP-L-40
- 45. Standard Review Plan 3.6.1 (NUREG-0800), Branch Technical Position ASB3-1, Revision 1, July 1981
- 46. Conduit Supports Train C 2 Inch Diameter and Less Project Status Report (PSR), Revision 0.
6-3 O
APPENDIX A
] COMANCHE PEAK RESPONSE TEAM (CPRTl ISSUES This appendix contains a comprehensive summary of the Ebasco evaluation, resolution and corrective and preventive action for all Comanche Peak Response Team (CPRT) issues which are related to the Systems Interaction Program (SIP). Specific references to the design criteria or procedures which have resolved the issues are provided.
To report the resolution of the Comanche Peak Response Team (CPRT) issues, an individual subappendix was developed for each issue. Each subappendix includes: a definition of the issue; issue resolution; and corrective and preventive action. Issue Al came from Issue Resolution Report (IRR), DAP-E-M-501 (Reference
- 3) related to High Energy Line Breaks (HELBs). Issue A2 came from Issue Resolution Report (IRR), DAP-E-M-507 (Reference 4) related to internally generated missile evaluations. Issue A3 came from the Issue Specific Action Plan (ISAP) related to Control Room Ceiling, ISAP ll.d (Reference 40). Issue A4 came from Issue Resolution Report (IRR), DAP-E-EIC-505 (Reference 44) related to Fire Protection.
The preventive action is embodied in the procedures and the Design Basis Documents (DBDs) developed and used in the systems interaction portion of the Corrective Action Program (CAP). These procedures and the Design Basis Documents (DBDs) resolve all Comanche Peak Response Team (CPRT) issues, implementation of these preventive actions can assure that the O desi 9n and hardware for CeSES unit i and Common will continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4. Comanche Peak Response Team (CPRT) issues contained in Appendix A are listed below: Issue No. Issue Title Al High Energy Line Break Protection A2 Missile Hazards A3 Seismic Design of Control Room Ceiling Elements A4 Fire Protection Systems Interaction A-1 O
SV8 APPENDIX Al O "to" e"eaov 't"e BaeAx eaotec'to" ttaa o^e-e-a-sot) 1.0 Definition of Issue 1.1 Jet Impingement Loads and Area Projections The issue was that the use of inappropriate methods of calculating jet impingement loads and area projections in the original calculations may have produced inaccurate loads. 1.2 Pipe Whip Zones of Influence The issue was that insufficient documentation existed to justify the original pipe whip zones of influence. 1.3 Identification of Safety-Related Targets The. issue was that the original design may have had incomplete identification of essential targets within the postulated pipe break jet impingement and pipe whip zones of influence. This may have been due to: Incorrect determination of jet impingement zones of influence; Incorrect determination of pipe whip zones O of infiueecei Inaccurate surveys. 1.4 Environmental Parameters The issue was that the original environmental parameters may not have been accurate because the original high energy line break (HELB) calculations were not up to date concerning changes in CPSES Unit I and Common architectural features and break locations. This issue was also raised in IRR DAP-E-EIC-503 (Reference 4.13). 1.5 Safe Shutdown Capability The issue was that insufficient documentation existed to justify the high energy line break (HELB) safe shutdown capability. Al-1 O
2.0. Issue Resolution p V 2.1 Jet Impingement Loads and Area Projections Ebasco resolved this issue by performing new calculations to validate the pipe break jet impingement loads and area projections. These calculations were performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.3 and 4.4) and were based on the design criteria in the Design Basis Document (DBD) (Reference 4.2). 2.2 Pipe Whip Zones of Influence Ebasco resolved this issue by developing a Design Basis Document (DBD) (Reference 4.2), Systems Interaction Program (SIP) procedures (References 4.1, 4.3, 4.7 and 4.8) and by performing new calculations to develop validated zones of influence calculations. These procedures require that the zone of influence calculations be documented. 2.3 Identification of Safety-Related Targets Ebasco resolved the issue by developing validated pipe whip and jet impingement zones of influence calculations based on the design criteria specified in the Design Basis Document (DBD) (Reference 4.2) and Systems Interaction Program (SIP) procedures (References 4.7, 4.8, and 4.9), References 4.7 and 4.8 provide guidance on the proper determination of jet impingement and pipe whip zones of
' C influence. Reference 4.9 provides guidance for conducting target identification surveys.
. 2.4 Environmental Parameters Ebasco resolved this issue by validating the environmental parameters by performing new high energy line break (HELB) calculations. These calculations were based on CPSES Unit I and . Common design documents and engineering walkdowns (Reference 4.6). '
, The Systems Interaction Program (SIP) procedure (Reference 4.1) provides controls for maintaining the calculations current with plant design.
2.5 Safe Shutdown Capability Ebasco resolved this issue by performing a calculation validating and documenting the safe shutdown capability of CPSES Unit I and [ Common as a result of high energy line breaks (HELBs). This calculation was performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.10 and 4.11) and was based on the criteria in the Design Basis Document (DBD) (Reference 4.2). Al-2 O t b
--,,_-._-_,-wr--.---,- _ - - , . , _ - , , m - - - _ _ ,m ----
3.0 Corrective and Preventive Action OV No additional issues were identified during review and resolution of these issues. , These issues were determined to be reportable under the provisions of 10CFR 50.55(e). It was reported as Significant Deficiencies Analysis Report (SDAR) CP-87-133 in letter number (TXX-88118), dated January 18, 1988 from TV Electric to the NRC. 3.1 Corrective Action New calculations have been performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.3, 4.4, 4.7, 4.10 and 4.11) and based on the Design Basis Document (DBD) (Reference 4.2) that validated the high energy line break (HELB) design. Engineering walkdowns are being performed during the Post Construction (PCHVP) in accordance with Systems Interaction Program (SIP) procedures (References 4.5, 4.6, 4.8, 4.9 and 4.12) to validate the hardware. 3.2 Preventive Action Systems Interaction Program (SIP) procedures (References 4.1, 4.3 and 4.4) and Design Basis Document (DBD) (Reference 4.2) were developed and used to validate the high energy line break (HELB) calculations. In addition the Systems Interaction Program (SIP) developed and implemented a design control procedure (Reference 4.1) which requires that all calculations and Os evaluations be checked and independently reviewed and that the calculations and evaluation documentation be properly controlled. , 4.0 References 4.1 Procedure ECE 2.24, "Systems Interaction Program", Rev 0. 4.2 Design Basis Document, DBD-ME-007, "Pipe Break Postulation and Effects", Rev 1. 4.3 Procedure EME 2.24-05, "Pipe Rupture Books", Rev 0. 4.4 Procedure EME 2.24-10, "Systems Interaction Program Interaction Evaluations", Rev 0. 4.5 Field Verification Method, CPE-EB-FVM-SI-51, Target Evaluation Data, Rev 0. 4.6 Field Verification Method, CPE-EB-FVM-SI-39, "Environmental Analysis As Built Walkdown Data", Rev 0. 4.7 Procedure EME 2.24-06, "Systems Interaction Program Sketches", Rev 0. 1 Al-3 O
. . . . . -. . .= - - . _ _
1 4.0 References Cont'd O 48 rie1d verific tio" "ethod, cec-tB-rva st-31. "Fieid aevie or Type Rupture Zone of Influence Sketches", Rev 1. 4.9 Field Verification Method, CPE-EB-FVM-SI-34 "High Energy Line Break Target Identification", Rev 1. j 4.10 Procedure EME 2.24 08, "Systems Interaction Program Shutdown : Analysis", Rev 0. 4.11 Procedure EME 2.24-03, "Systems Interaction Program Essential Component Lists", Rev 1. 4.12 Field Verification Method, CPE-EB-FVM-SI-28, "Location Verification of Components", Rev 1. 4.13 TERRA 1RR DAP-E-E!C-503, Environmental Qualification of Electrical and Mechanical Equipment, Letter DAP-L-161, Rev 0, October 2, 1986. , 1 b O - 1 1 i i I f Al-4 I !O l
SUBAPPENDIX A2 MISSILE HAZARDS (IRR DAP-E M-507) ! 1.0 Definition of the issue The issue was that insufficient documentation existed for the original internally generated missile analysis and therefore the protection of the essential systems, structures and components could not be demonstrated. 2.0 Issue Resolution Ebasco resolved this issue by developing a Field Verification Method (FVM) (Reference 4.3) based on the Systems Interaction Program (SIP) procedure (Reference 4.1) and on the criteria in the Design Basis Document (DBD) (Reference 4.2). This Field Verification Method (FVM) (Reference 4.3) is being used for the performance of engineering walkdowns and evaluations ! during the Post Construction Hardware Validation Program (PCHVP). These engineering walkdowns and evaluations validate and document that essential systems, structures and components will continue to perform their safety-related function to safely shutdown the reactor and mitigate the consequences of a postulated missile generation event. 3.0 Corrective and Preventive Action i
- No additional issues were identified during the review and resolution of this issue.
O - This issue was determined not to be rePortabie under the provisions of 10CFR50.55(e). 3.1 Corrective Action Engineering walkdowns (Reference 4.3) and evaluations are performed and ' documented in accordance with the Systems Interaction Program (SIP) procedures (Reference 4.1) and based on the Design Basis Document (DBD) (Reference 4.2). - 3.2 Preventive Action A Systems Interaction Program (SIP) procedure (Reference 4.1) and a Design l Basis Document (DBD) (Reference 4.2) were developed and used during the design validation process. In addition this design control procedure (Reference 4.1) requires that all calculations and evaluations be checked i and independently reviewed and that the calculations and evaluation documentation be properly controlled. i l A2-1 1
h 3 4.0 References O 4.1 Procedure ECE 2.24, "Systems Interaction Program", Rev 0. ; 4.2 Design Basis Document, DBD-ME-105, "Missile Postulation and Effects", Rev 1. ; ) 4.3 Field Verification Method, CPE-EB-FVM-SI-67 "Missile Target Identification," Rev 0. i , l 1 1 'h a
+
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_ _ _ _ _ _ _ _ . ~ _SUBAPPENDIX A3 O SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS (ISAP II.d. systems interaction Dortion) 1.0 ' Definition of Issue 1.1 Line Mounted Items on Small Bore Piping The issue was that potential interactions resulting from commodities that were line mounted on small bore piping were not identified. 1.2 Pipe / Conduit Over Cable Trays Ebasco resolved this issue by developing a Field Verification Method (FVM) (Reference 4.2) to evaluate the interactions between pipes / conduits and cable trays that were originally resolved based on inadequate criterion. This Field Verification Method (FVM) (Reference 4.2) is being used for the performance of engineering walkdowns and evaluations during the Post Construction Hardware Validation Program (PCHVP). These engineering walkdowns and evaluations are performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.2, and 4.3) and are based on the design criteria in the Design Basis Document (DBD) (Reference 4.4). 1.3 Evaluation of Architectural Features The issue was that architectural features (e.g., doors, ladders, O platforms, gratings, handrails, and sheetrock walls) were not specifically addressed in the systems interaction seismic /non seismic program. 2.0 Issue Resolution 2.1 Line Mounted Items on Small Bore Piping Ebasco resolved this issue by developing a Field Verification Method (FVM) (Reference 4.2) to identify and evaluate interactions resulting from commodities that are line mounted on small bore piping. This Field Verification Method (FVM) (Reference 4.2) is being used for the performance of engineering walkdowns and evaluations during the Post Construction Hardware Validation Program (PCHVP). These engineering walkdowns and evaluations are performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.2, and 4.3) and are based on the design criteria specified in the Design Basis Document (DBD) (Reference 4.4). A3-1 O
2.2 Pipe / Conduit Over Cable Trays Ebasco resolved this issue by developing a Field Verification Method (FVM) (V3 (Reference 4.2) to evaluate the interactions between pipes / conduits and cable trays that were originally resolved based on inadequate criterion. This Field Verification Method (FVM) (Reference 4.2) is being used for the performance of engineering walkdowns and evaluations during the Post Construction Hardware Validation Program (PCHVP). These engineering walkdowns and evaluations are performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.2, and 4.3) and are based on the design criteria specified in the Design Basis Document (DBD) (Reference 4.4). 2.3 Evaluation of Architectural Features Ebasco resolved this issue by developing a Field Verification Method (FVM) (Reference 4.2) to evaluate the effects of interactions between architectural features in the control room and safety related components. This Field Verification Method (FVM) (Reference 4.2) is being used for the performance of engineering walkdowns and evaluations during the Post Construction Hardware Validation Program (PCHVP). These engineering walkdowns and evaluations are performed in accordance with Systems Interactions Program (SIP) procedures (References 4.1, 4.2, and 4.3) and are based on the design criteria specified in the Design Basis Document (OBD) (Reference 4.4). The architectural featurer requiring modification to comply with the design criteria are being identified to SWEC ' civil / structural. The validation that these architectural features will retain their structural integrity is described in the Civil / structural O ero3ect st tus aePort (esa) (aerere#ce 4 s)- 3.0 Corrective and Preventive Action No additional issues were identified dwing review and resolution of the issues. These issues were determined to be reportable under the provisions of 10CFR 50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-86-54 in letter number - TXX-6007 dated October 31, 1986 from TV Electric to the NRC. 3.1 Corrective Action Engineering walkdowns and evaluations were performed in accordance with System Interaction Program (SIP) procedures (References 4.1, 4.2 and 4.3) and based on the Design Basis Document (DBD) (Reference 4.4). These engineering walkdowns and evaluations validated that interactions involving small bore line mounted items, pipe / conduit over cable trays and architectural features comply with the design criteria. A3-2
- O
1 3.2 Preventive Action O The System Interaction Program (SIP) procedures (References 4.1, 4.2 and 4.3) and Design Basis Documents (DBD) (Reference 4.4) were developed and used during the performance of Systems Interaction Program (SIP). y 4.0 References 4.1 Procedure ECE 2.24, "Systems Interaction Program", Rev 0, 4.2 Field Verification Method, CPE-EB-FVM-SI-40, "Seismic / Nonseismic Walkdowns", Rev 1. - 4.3 Procedure EME 2.24-01, "Evaluation of Seismic /Nonseismic Interactions", Rev 1. 4.4 Design Basis Document, DBD ME-005, "Seismic /Nonseismic Systems Interaction Program", Rev 1. 1 4.5 Civil / Structural Project Status Report (PSR), Rev 0. O ;
- i f A3-3
SUBAPPENDIX A4 Q FIRE PROTECTION SYSTEMS INTERACTION (IRR DAP-E-EIC-5051 1.0 Definition of the issue The issues were as follows: Seismic Oualification of Deluce Valves 1.1 l.l.A The issue was that diesel generator operability could be affected by inadvertent operation of the diesel generator fuel oil day tank room fire protection system due to a seismically induced failure of the deluge valve. 1.1.B This issue was that diesel generator operability could be affected by inadvertent operation of the diesel generator room fire protection system due to a seismically induced failure of the fusible link type sprinkler heads. ' l.2 Diesel Generator Room Sorav Shields The issue was that diesel generator operability could be affected by inadvertent operation of the fire suppression system resulting in damage to equipment from the effects of water sprays. 1.3 Seismic Sucoortino of Fire water Pipina in Diesel Generator Rooms O The issue was that diesel senerator oPerebii4tx couid be affected by damage due to seismically induced failure of fire suppression system piping in diesel generator rooms. 2.0 Issue Resolution 2.1 Seismic Oualification of Deluae Valves 2.1.A Ebasco resolved this issue by performing new flooding calculations to validate flood levels resulting from seismic induced inadvertent operation of the diesel generator fuel oil day tank rooms fire suppression deluge valves. The calculations were performed in accordance with Systems Interaction Program (SIP) procedures (Reference 4.1,4.2,4.3) and were based on the design criteria in the Design Basis Document (DBD) (Reference 4.4). These calculations demonstrate that the flood levels are such that the diesel generator operability is not affected. 4 A4-1 ) l
l 2.1.B The resolution of this issue is addressed in the Fire Protection Project Status Report (PSR) (Supplement B of the Mechanical PSR). 2.2 Diesel Generator Room Soray Shields The recolution of this issue is addressed in the Fire Protection Project Status Report (PSR) (Supplement B of the Mechanical PSR). 2.3 Seismic Suocortina of Fire Water Pioina in Diesel Generator Rooms Ebasco resolved this issue by reviewing the design specification (Reference 4.5) and performing new flooding calculations. This review validated that the fire suppression system piping in the diesel generator rooms is seismically supported (i.e., the piping can leak, but it will not fall). This review was performed in accordance with Systems Interaction Program Procedure (Reference 4.1) 4nd was based on the criteria in the Design Basis Document (D8D) (Reference 4.5). The flooding calculations validate the flooding levels resulting from seismically induced failure of fire , suppression system piping in the diesel generator rooms. The calculations were performed in accordance with Systems Interaction Program procedures 9 Reference 4.1, 4.2, and 4.3) and were based on the design criteria in the DBD (Reference 4.4). These calculations demonstrate that the flood levels are such that the diesel generator operability is not affected. 3.0 Corrective and Preventive Action O - no additionei issues were ideatified derine the review ead resolution of this issue. This issue was determined not to be reportable under the 3 provisions of 10CFR50.55(e). 3.1 Corrective Action New flooding calculations have been performed in accordance with Systems Interaction Program (SIP) procedures (References 4.1, 4.2, . and 4.3) and based on the design Basis Document (DBD) (Reference ' 4.4) that validated that the diesel generator operability is not affected in the event of seismically induced failure of the deluge , valves and/or fire suppression system piping. A4 2 O
i 3.2 Preventive Action Systems Interaction Program (SIP) procedures (Reference 4.1, 4.2, and 4.3) were developed to evaluate system interactions due to flooding in accordance with the design criteria specified in the Design Basis Document (DBD) (Reference 4.4) and used to validate the diesel generator systems interaction design. 4.0 References 4.1 Procedure ECE 2.24, "Systens Interaction Program", Rev 0. 1 4.2 Procedure EME 2.24-02, "Flooding Analysis", Rev 1. 4.3 Field Verification Method, CPE-EB-FVM-SI-35, "MELB Interaction Identification, Rev 0. 4.4 Design Basis Document, DBD ME-007, "Pipe Break Postulation and Effects", Rev 1. i 4.5 Design Specification 2323-MS-468, "Piping Hangers (Non nuclear)", Rev 3. 4.6 Design Basis Document - DBD-ME-005, "Seismic /Non Seismic Systems Interaction Program", Rev 1. i l \ \ A4-3 O l
( APPENDIX B Q' ISSUES IDENTIFIED DURING THE PERFORMANCE OF THE CORRECTIVE ACTION PROGRAM (CAP) This appendix describes the details of the resolutions of issues that have been determined to be reportable under the provision of 10CFR50.55(e) and ' were identified during the performance of the systems interaction portion of the Corrective Action Program (CAP). Included in this appendix are systems interaction related Significant Deficiency Analysis Report (SDARs) initiated by TV Electric. Specific references to the criteria and procedures which have resolved the issues are provided. To report the resolution of issues identified during performance of the Corrective Action Program (CAP), an individual subappendix was developed for each issue. Each subappendix includes: a definition of the issue; issue resolution; and corrective and preventive action. The preventivo action is embodied in the procedures and Design Basis Documents (DBDs) developed and used in the systems interaction portion of the Corrective Action Program (CAP). These procedures and Design Basis Documents (03Ds) resolve the systems interaction portian of the Correctivo Action Program (CAP) issues. Implementation of these preventive actions can assure that the design and hardware for CPSES Unit I and Common will continue to comply with the licensing commitments throughout the life of the plant as described in Section 5.4. 4 O Ebasco has reviewed the Sefety Eveiuatioa Report (SER) and its sePPiements (SSERs) and determined that the systems interaction design criteria, i design procedures and validated hardware are consistent with the NRC staff positions stated in the SER and its supplements (SSERs). Specific references to the criteria, procedures, engineering studies, and tests which have resolved the issue are provided. Corrective Action Program (CAP) issues contained in Appendix B are listed below: Issue No. Issue Title B1 SDAR CP 87-57, computer Modeling Error: COMPARE MOD 1A B2 SDAR CP 87-58, Computer Modeling Error: RELAP-3 B-1 O
SV APPENDIX B1 () SDAR CP-87-57. COMPUTER MODELING ERROR: COMPARE MOD 1A 1.0 Definition of the Issue The issue was that an incorrect computer model orginally used for damper operation may have resulted in miscalculation of environmental conditions due to postulated high energy line breaks (HELBs) outside containment. 2.0 Issue Resolution Ebasco resolved this issue by revising the computer model of the dampers 1 to be consistent with the operation described in vendor documentation. New outside containment high energy line break (HELB) environmental calculations were performed using the validated computer model. 3.0 Corrective and Preventive Action No additional issues were identified during the review and resolution of this issue. This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-57 by letter TXX-6929, dated 11/16/87 from TV Electric to the NRC. ! r 3.1 Corrective Aciton b) Calculations have been performed by Ebasco in accordance with Systems Interaction Program (SIP) procedures (References 4.1 and 4.2) based upon the design criteria specified in the Design Basis Document (DBD) (Reference 4.3) to validate the outside containment high energy line break (HELB) environmental conditions. These validated calculations used the revised computer model and replaced the original calculations. 3.2 Preventive Aciton The design procedure (Reference 4.1) requires the review of input data for calculations and computer models. l 4.0 References l 4.1 Procedure ECE 2.24, "Systems Interaction Program", Rev 0. 4.2 Procedure EME 2.24-04 "Systems Interaction Program Environmental Analysis", Rev 1. 4.3 Design Basis Document (DBD), DBD-ME-007 "Pipe Break Postulation and Effects", Rev 1. l l B1-1 l O l O
_Sj!BAPPENDIX B2 (] SDAR CP-87-58. COMPUTER MODELING ERROR: RELAP-3 1.0 Definition of the Issue The issue was that errors in the RELAP-3 computer code and errors in the original systems interaction model used with the RELAP-3 code resulted in miscalculation of loads applied to pipe whip restraints. 2.0 Issue Resolution Ebasco resolved this issue by using the RELAP-5 computer code and by revising the systems interaction models during the design validation process. Computer code RELAP-5 is the latest version of the RELAP series of computer codes and incorporates the resolution of deficiencies noted in RELAP-3. New pipe whip restraint load calculations were performed using RELAP-5 and the validated computer models. 3.0 Corrective and Preventive' Action No additional issues were identified during the review and resolution of this issue. This issue was determined to be reportable under the provisions of 10CFR50.55(e). It was reported as Significant Deficiency Analysis Report (SDAR) CP-87-58 by letter TXX-6951, o dated 11/16/87 from TV Electric to the NRC. U 3.1 Corrective Action Calculations have been performed by Ebasco in accordance with Systems Interaction Program (SIP) procedures (References 4.1 and 4.2) based upon the design criteria specified in the Design Basis Document (DBD) (Reference 4.3) to validate the loads applied to pipe whip restraints. These calculations used RELAP-5 and the validated computer models to replace the original calculations. 3.2 Preventive Action Design procedures (References 4.1 and 4.2) require the review of input data for calculations and computer codes and provide requirements for developing system interaction models. 82-1 /N b
l l l 4.0 References O 4.1 Procedure ECE 2.24, "Systems Interaction Program", Rev 0. p 4.2 Procedure EME 2.24-05, "Pipe Rupture Books", Rev 0. 4.3 Design Basis Document.(OBD).DBO-ME-007, "Pipe Break Postulation and Effects", Rev 1. 1 9 l f f 0 . l t 1 i e ? i i i 82-2 O . 7 m-., ...,_,---,.,,p%_, _ . . , _ _.-,-.,_,y, --}}