ML20150C953

Rev 1 to Program for Independent Design & Const Assessment of Limerick - Unit 2

ML20150C953
Person / Time
Site:	Limerick
Issue date:	07/06/1988
From:	Daniels H, Fleming E, Willie D STONE & WEBSTER ENGINEERING CORP.
To:
Shared Package
ML20150C935	List: ML20150C934 ML20150C953
References
PROC-880706, NUDOCS 8807130231
Download: ML20150C953 (27)

Text

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I s 1 J.O.No. 18138.00 I

PROGRAM FOR THE INDEPENDENT DESICN AND CONSTRUCTION ASSESSMENT t

OF LIERICK - UNIT 2

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Stone & Webster Engineering Corporation

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f Revision 1 .iuly 6, 1988

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Assistant Program Manager / ,, f D./'.Wille >

) Q r Assistant Program Manager - d 3we' E. B. Flemint; /

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1 Prograe Manager a T- > . #,46/

H. E. Daniels, Jr.

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PROGRAM FOR THE INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT LIHERICK - UNIT 2 Philadelphia Electric Company (PEco)

l. SYSTEM SELECTION AND SCOPE The purpose of the Independent Design and Construction Assessment (IDCA)

, is'to evaluate the adequacy of the design and construction process for Limerick Unit 2 by examining the Containment ~ Heat Removal (CHR) mode of operation of the Residual Heat Removal (RHR) System, associated struc-tures, and interfaces. In so doing, the IDCA team will review the design t_if the RHR function of injecting water into the reactor vessel following the initiation of a postulated loss of cc lant accident condition and returning water to the RHR pump from the suppression pool. The selected j system operations will also include subsequent cooling of the RHR heat exchanger by the RHR Service Water System with heat rejection to the cooling tower or the spray pond. This will ensure that a system common to both Unir 1 and Unit 2 will be reviewed during this program. In addi-tion, thore systems directly supporting the CHR mode will also be reviewed.

The selection of the CHR mode as a combination of systems acting.together in a specific safety mode provides the basis for an in-depth review of design and construction activities while focusing the IDCA team's activi-

' ties on a limited amount of plant equipment and structures. These sys-tems, functioning during the CHR mode, will provide the basis for the in-depth assessment of the architect engineer (A/E) design process since the following activities were accomplished within the A/E scope of servicest Interface with the NSSS design process, including postulated accident conditions.

System design fer a common system, i.e., serves both Unit 1 and Unit 2.

• Service water pump specification and procurement.

• Pipe sizing, layout, and procurement.

Pipe stress analysis end suppore 'asign, including ASME III, Class 1, 2, and 3 piping.

Electrical power to pumps and valves and procurement of motor operated valves (MOV) and pump motors, including power distri-bution equipment / components.

Control logic interface with NSSS equipment.

Control system logic for operation of A/E procured valves and pumps.

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. Routing of power and control cables, including electrical sepa-  !

ration criteria.

Structural elements and support system cc.nponen t s , including-walls and floors.

Amplified Response Spectra (ARS) development and application.

• Hazards program design'and analysis.

Environmental qualification of equipment, including seismic requirements.

Supporting systems for proper operation of the CHR mode, in-cluding compartment ' cooling and pump / motor cooling systems.

• Design interface with subcontractors and component _ suppliers.

The IDCA will be performed by a team of experienced personnel divided into two groups, one to conduct the Independent Design Assessment (IDA) ,

3 and the other to conduct the Independent Construction ' Arcessment -(ICA).

2. INDEPENDENT DESIGN ASSESSMENT (IDA) OVERALL APPROACH The CHR mode systems will form the basis of the assessment. The design will be reviewed to determine if the following attributes are mett

• The design is consistent with and supports the FSAR commit-ments, including system function, is in compliance with docu- '

ments committed to in the FSAR, and is technically adequate.

• t'he design is in compliance with NSSS requirements and criteria.

• Technically adequate calculations are available to support the design.

• Diagrams, specifications, drawing:, and vendor documents are technically complete and consistent with each other.

• Inter- and intradiscipline interfaces are adequate.

The adequacy of design changes and the resolution of selected industry issues, NRC bulletins, notices, circulars, etc, will be evaluated. Em-phasis will concentrate on design changes to the system under review. '

However, design changes to other systems will be evaluated, where re-quired to obtain a reasonable sample for review. The adequacy of dispo-sitions to nonconformances/ deficiencies and design changes also will be evaluated individually and collectively.

As part of the review of the system design and to evaluate engineering activities, site walkdowns will be conducted as part of the Independent Design Assessment (IDA). These walkdowns will be coordinated with ICA site activities.

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To evaluate certain types of design activities, it is anticipated that review of other systems / components (other than those related to the CHR mode) will be necessary. Types of activities where this may be necessary aret Hazards (MELB, HELB, Flooding, Heavy Loads, Rotary Missiles, Fire (Appendix R), Seismic II/I)

• Stress reconciliation (piping)

Structural load verification

• Electrical separation e HVAC ducts and duct supports

• Raceway support design Procurement and upgrade of commercial grade equipnant and parts

3. IDA APPROACH BY DISCIPLINE 3.1 Mechanical Systems 3.1.1 System a> Component Design The scope of this technical assessment will consist of the verification of the design of systems and components that are required to satisfy the safety and operational requirements of the CHR mode, which includes some components anc equipment :ommon to both Unit I and Unit 2. This review will be based on design documents and site walkdown activities. Design changes and resolution of selected indurery issues will be evaluated.

This design review will be performed in various steps using formal review plans, which will describe the approach to be followed for the review:

• The compliance of the Final Safety Analysis Report (FSAR) with the project position on applicable Standard Review Plans and Regulatory cuides, and the compliance of the system design, including functional requirements, with commitments in the FSAR l will be verified.

• The system desiga will be reviewed to verify consistency with the NSSS interface requirements.

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• The process and instrumentation drawings (P&ID) and flow dia-l grams, where available, will be reviewed to verify process ade-l quacy and compliance with applicable codes, standards and design criteria.

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The applicable calculations will be reviewed to verify co., sis-tency of the system design with the system design bases and criteria.

Selected equipment specifications will be reviewed to verify consistency with other support documents; comprehensivenessi adequacy of technical, inspection, and construction require-ments; and compliance of the equipment test performance, when applicable, with the specification requirements.

Preoperational testing and turnover of the Unit 2 portion of the RHR service water will be reviewed.

Radiation protection and Alara implementation related to the CHR mode systems will be reviewed.

Piping and machine location drawings will be reviewed for consistency with the flow diagrams, and for operability, main-tainability, and inspectability.

Vendor documents will be reviewed for completeness and for con-sistency with the specification requirements.

The interfaces between other engineering disciplines will be reviewed to verify consistency and compatibility of design requirements.

The hazards program will be evaluated for adequacy of criteria i

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and engineering judgments during implementation, including the effect on engineered safeguards, fire protection, heavy loads, and flooding analysis.

Project positions relative to industry issues (e.g., water ham-mer) and the actions taken to implement any related design

, changes will be reviewed.

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• The systems' design changes will be reviewed for technical adequacy.

The technical adequacy of actions taken related to nonconfor-j mances and deficiencies will be evaluated.

A site walkdown will be performed as part of the IDA to facilitate l

i evaluation of certain attributes such as effect on hazard analysis, implementation of piping and component layout, and the adequacy of shielding and separation, where applicable.

3.1.2 Materials The scope of this technical assessment will consist of the l verification of the technical adequacy of the materials and fabrication requirements invoked on the CHR mode systems. The evaluation will be based on review of the material and fabrication requirements for prersure boundary materials and for related coating 7000-18138-HC2 4 Rev. 1, July 6, 1988 l

applications, including coating of the suppression pool. The review will be based primarily on the review of design documents.

The assessment will commence with a review of the applicable 'sec-tions of the FSAR and a review of applicable design specifications, drawings, and procedures used to implement the FSAR tequirements.

The materials and fabrication Regulatory Guide positions and Branch Technica; Positions committed to in the FSAR will be reviewed and a determination made if these positions were adequately addressed-in appropriate design criteria, design specifications, drawings and procedures.

Design specifications for major components and materials and select-ed drawings associated with che CHR mode will be reviewed. Based on the results of this review the invoked technical requirements for materials and fabrication will be evaluated to assure that the FSAR commitments have been interpreted correctly and consistently. Se-1seted A/E and vendor fabrication procedures utilized on this system will be reviewed to assure that these requirements have been ade-quately implemented during the fabrication / installation and erection phases. Implementation will be evaluated during inspections as part of the ICA.

Selected design changes and nonconformances/ deficiencies written against the above specifications and drawings will be reviewed to assure that the requirements remain consistent and technically ade-quate and agree with the FSAR commitments.

The project position on selected industry issues in the materials engineering area will be evaluated to verify the adequacy of project resolution.

3.2 Hechanical Components The scope of this technical assessment will consist of the verificat!on of the design process for the analysis of the CHR mode systems, piping, the seismic qualification of equipment and valves, and the design of pipe supports.

This portion of the review will assess the following areas:

• Design is consistent with the FSAR commitments.

• Calculations supporting the design are complete and technically adequate.

> e Specifications are complete and consistent with each other.

• Drawings used in the design are clear and complete.

• Inter- and intradiscipline interfaces are complete.

• Design changes and nonconformance dispositions are consistent with the design requi.rements.

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• Design complies with NSSS requirements.

• Pipe stress reconciliation.

The compliance of the appiicable sections of the Final. Safety Analysis i

Report (FSAR) with the project position on related Standard Review Plans

! and Regulatory Guides, as stated in the FSAR, will be verified. Project l technical memorandums and design calculations will be reviewed to verify that FSAR commitments are included in the design process.

Selected NSSS equipment specifications and drawings will be reviewed for requirements which impact the stress analysis. Related stress calcula-tions will then,be selected and NSSS requirements evaluated.

Calculations supporting the design of the CHR mode systems, or other sys-cems if necessary, will be chosen based on one or more of the following criteria:

• The piping includes Class 1 analysis.

The piping terminates at an equipment nozzle.

• The piping is subjected to hydrodynamic loading (e.g., water hammer).

The piping experiences large temperature changes.

• The piping spans two structures.

The piping contains an expansion joint.

The piping terminates at a penetration.

The analysis represents two or more similar lines.

Information used as input to the calculations will be reviewed for com-pleteness and to determine that input has been consistently translated from a source document. Each calculation will be evaluated for technical adequacy, compliance with project commitments and for incorporation of results in affected documents. Resolution of as-built differences will be reviewed. Calculations supporting the analysis of large bore and field-designed small bore piping will be included.

A sample of the system pipe supports will be selected for review. The selection will consist of various types of restraint designs so that a broad spectru, of pipe supports may be evaluated. Typical designs will include anchors (six-way), dynamic snubbers, frame type rigid restraints, struts, and spring hangers. Supports selected will include integral welded attachments to the run pipe, base plates with concrete anchor bolts, attachments to embedded plates and attachments to structural steel members. The pipe supports will be reviewed with emphasis on the following:

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• The pipe support design meets the stress analysis functional intent.

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• The pipe support is in compliance with the pipe support design specification and code requirements.

• The mathematical procedures and methods are correct and appli-cable, and computer codes are validated and documented.

• Justification of assumptions and/or special methods used in the calculation are clearly stated and applicable.

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• The construction drawings show all pertinent details of the i design calculations (proper members and orientation, weld types and sizes, etc.), and construction and inspection requirements

, are complete and adequate.

L j Piping location drawings (isometrics) will be selected and reviewed for l completeness, clarity, and consistency with the design requirements.

l Specifications will be reviewed for consistency with FSAR commitments and l ASME code requirements. Technical requirements for the design process-I will be checked against the specification (s) to verify that all such re-quirements are addressed.

Project positions on selected industry issues will be evaluated for ade-( quacy through the review of implementing procedures and check of relevant j calculations.

Interface requirements between various engineering and design groups will be reviewed to verify that all information is current, complete, and technically adequate. Nozzle loads, pipe support reactions, system oper-ating conditions, drawings, amplified response data, and penetration loads will be evaluated.

Transmittals of pipe support results will be reviewed to verify that they are complete and are used correctly in affected documents. The loads at the structural / concrete interface locations will be evaluated and the weld technique sheets specified on the construction drawings will be checked for proper application.

Selected design changes and nonconformances/ deficiencies written against the specifications, drawings, or equipment will be reviewed for technical adequacy and clarity of solutiens.

A review of the hazards program related to high energy lins n k, inter-nal missile generation, and seismic II/I will be conducted to verify the soundness of the program. Licensing and regulatory commitments will be assessed for consistency with current project practice. Calculations and other relevant documents will be reviewed as necessary. These reviews are intended to verify the following:

• The adequacy of criteria.

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• The adequacy of engineering judgments applied during the execu-tion of the hazards review program.

• The adequacy of pipe rupture analysis, restraint design, and shield design as implemented in conjunction with the hazards program.

It is anticipated that two areas--one inside the containment, a second outside the containment--will be reviewed to assess the adequacy of the hazards program's current conclusions. Of the two areas chosen, at least one area should identify the necessity for protection of essential sys-tems or equipment as determined by a failure modes and effects analysis.

This will verify the integrity of the pipe rupture design basis as ap-plied in the selected areas. An area which is regarded as completed by the hazards program also will be reviewed. This is intended to assess the integrity of the program's final documentation. In addition, a site walkdown will be performed to evaluate certain attributes such as seismic interaction and effect on hazards anal,ysis.

3.3 -Electrical The scope of this technical assessment will consist of the verification of electrical design of the CHR mode systems in the following areas:

• System equipment that are electrically powered.

• Power sources from the Class 1E busses supplying electrical power to that equipment.

• Cable and raceway systems carrying the electrical power from the Class 1E busses to the electrically powered system equipment.

Equipment for review will be selected from each of the above areas. The selection of specific items of electrically powered system equipment will be predetermined from the list of key equipment. Electric power source equipment for the selected electrical equipment will be identified. In l addition, the electrical distribution system and equipment supporting I these power sources will be included to verify electrical power distri-bution system adequacy. The selection of cables and raceways will in-clude those carrying the electrical power from the electrical power sources to the selected electrics 11y powered equipment.

The objective will be to determine if the design docume0ts that apply to selected equipment meet the design basis, are technically adequate and are consistent with associated documents.

Engineering and design tocuments will be compared against FSAR design basis requirements and commitments. The engineering and design documents include design criteria, diagrams, drawings, specifications, calcula-l tions, and design change documents.

Drawings and diagrams will be reviewed considering design criteria such l

an electrical independence, cables / raceways, grounding, and environmental i

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conditions. The electrical power distribution system documents will be reviewed for consistency with the main one-line diagrams. Overall design configuration, equipment, and impact on or from nearby equipment will be considered. Specifications will be reviewed for adequate electrical and environmental condition requirements. Calculat'ons supporting the system equipment and the electrical distribution system's capability of provid- -

ing the required quality of power will be reviewed for adequacy and con-sistency with the design. These calculations will include equipment sizing, voltage profile, short-circuit capacity, equipment protection, breaker coordination, and cable sizing. Vendor drawings will be reviewed for consistency with specifications, drawings, and diagrams.

The electrical equipment included in this review is Class lE and is sub-ject to the requirements of RC 1.89 for environmental and seismic quali-fication of equipment, and RG 1.75 for physical independence of redundant systems. These special needs will be included in this review to verify that the Class 1E equipment meet environmental, seismic, ar.d separation requirements.

For equipment qualification, it will be determined if the Class 1E equip-ment meet specification requirements (including environmental and seis-mic), are traceable to the qualification documentation, and are installed in S manner consistent with the engineering and equipment qualification documentation. The equipment sampled generally will be the same as that used in the above review. If necessary, equipment from other systems will be selected.

For separation, the Class 1E equipment, including cables and raceways, will be reviewed for conformance to the separation criteria of RG 1.75 and committed to in the FSAR.

I Project positions on selected industry issues will be evaluated for ade-quacy of the positions and for consistency with engineering and design documents.

Electrical interfaces for the A/E and NSSS systems will be reviewed for compatibility and consistency of engineering and design requirements, where applicable.

Recent change documents will be selected and reviewed for technical ade-i quacy. These change documents will be selected mainly from those associ-ated with the Class 1E electrical distribution systems and include resolution of nonconforming or deficiency conditions.

A site walkdown will be performed as part of the IDA to evaluate certain attributes such as compliance with the requirements of:

6 Electrical and physical separation.

• Grounding criteria.

• Equipment qualification requirements including equipment loca-l tion, position, proximity to nonsafety-related equipment and pipes carrying high-energy fluids, mounting methods, and the l consistency of the installed equipment with specifications.

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To assess the adequacy of the Class 1E ac power system and de system, specific loads from the CHR mode systems will be reviewed back to the normal - power . source and to the diesel generator and battery, including diesel generator sequencing and loading, 1E voltage drops, and de battery capacity.

3.4 Instrument and Controls The scope of this technical assessment will consist of the verification of the instrument and control design of the CHR mode systems in the following areas:

• System design including functional requirements, instrument and control (I&C) redundancy, and licensing document compliance.

• Environmental qualification adequacy. l

• Seismic qualific.t. on adequacy.

Automatic control logic, operacor controls, and hardware will be evaluat-ed for the ability of the system to meet the commitments of the FSAR.

The review will encompass locally mounted sensors, controlling devices, panel-mounted instruments and controls, and auxiliary devices such as relays.

Logic diagrams, loop diagrams, instrument schematics, elementary dia- l grams, and specifications will be reviewed for compliance with licensing I requirements as detailed in the FSAR and other applicable criteria, and for consistency with interfacing documents such as P&IDe and wiring dia-grams. Selected setpoint cale.alations will be reviewed for technical adequacy and consistency with system design criteria. The adequacy of control and interfacing with NSSS control system logics will be assessed.

Piping system interfaces for purposes of the I&C review will be deter-mined during team preparation.

Equipment for review will be selected f rom key equipment lists. Selec-tions will be based on environment, input from other disciplines, and generic functionality. Equipment characteristics will be verified for consistency with supporting calculations (or other documentation) and the acequacy of the calculations evaluated.

Field and panel-mounted equipment will be evaluated for capability of controlling and monitoring the process function. Safety-related instru-mentation will be checked for compatibility of setpoints with the antici-pated process operating conditions.

Availability and independence of power available to redundant subsystems, including proper separation, will be checked from initiating device to source of power.

Sample safety-related equipment will be reviewed for compliance with ap-propriate environmental and seismic qualification requirements. The va-lidity of the requirements will be reviewed by appropriate disciplines.

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Nonsafety-related equipment will be examined for necessity for seismic qualification of structure and mounting provisions.

Grounding of enclosures, shields, and signal wires will be examined for compliance with applicable standards, vendor requirements, and project procedures. Separation, isolation, and routing of low-level signal and control wires for control and instrumentation cabinets and panels will be reviewed during the A/E inspection and evaluated during the ICA field walkdown (such as adequate separation of wire bundles inside control boards and minimum clearance between modules).

Design thanges and nonconformances/ deficiencies resolution will be evalu-ated for technical adequacy of the problem solutions.

3.5 Civil / Structural The scope of this technical assessment of the structural engineering and design will consist of the verification of the technical adequacy of thc design, including design changes, for structures associated and related to the CHR mode systems. In addition, it will evaluate compliance with governing documents such as design criteria, FSAR, applicable codes, and other licensing commitments.

The categories or general attributes listed under Section 2, IDA Overall Approach, will be used as the basis for the structural review. Prior to initiating an examination of the building designs, a review of design basis documents used by the civil / structural groups will be performed.

The FSAR, structural design criteria, and selected key specifications and procedures will be reviewed for:

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• Consistency between the FSAR and key design basis documents.

• Consistency among design basis documents.

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Upon completion of the basic review of the design basis documents, a com-prehensive design evaluation of the structures or structural elements including materials and installation in the buildings will be initiated.

It is anticipated that the review will consist of, but not be restricted to, the following items. The sampling of these items will be based on j different types of documents and degree of importance for supporting the

! CHR mode.

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• Evaluate consistency between the FSAR and other documents such as Regulatory Guides, design criteria, procedures, and

?.rawings.

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• Evaluate calculations for the rtructural analysis and design of the buildings and/or structural elements within the buildings including items such as struct ural concrete, structural steel, floors, walls, base plates and anchor bolts for equipment and pipe supports, and containment and other penetrations. This will include appropriate seismic and hydrodynamic analysis.

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• Evaluate structural interface with other disciplines with re-spect to design data (loads, pressure, temperature, etc) transmittals for structural analysis.

• Evaluate consistency and adequacy checks between specifications such as structural treet, concrete testing services, and shield doors including associated A/E and vendor's drawings and other design documents.

• Evaluate implementation of structural load verification for structural members.

• Evaluate analysis and design of raceway supports.

• Evaluate technical adequacy of design changes.

• Evaluate project position for resolution of selected industry issues.

A site walkdown will be performed as part of the IDA to evaluate certain attributes such as nmsonry walls requirements and adequacy of seismic shakespace between buildings and between buildings and adjacent structur-al elements.

4. INDEPENDENT CONSTRUCTION ASSESSMCNT (ICA) OVERALL APPROACH The assessment will be conducted in conjunction with a technical assess-ment of the CHR mode systems design and will cover the associated Unit 2 systems, components, and structures. The systems, components, an? struc-tures will be examined to determine whether:

. The as-constructed condition reflects the design au shown on drawings and specifications including verification of equipment nameplate data with specification requirements.

• As-built documentation used for design verification purposes (e.g., as-built piping drawings / isometrics) accurately reflect the as-built conditions.

The assessment will encompass review of specific areas such as:

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• Welding and nondestructive examination

• Electrical and instrumentation construction l

• Civil / structural construction I

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• Quality assursnce and quality control

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The specific areas, equipment and components examined will be based on an appropriate sample selected from drawings, equipment lists, valve lists, and other current design documents. The samples salected will be coordi-nated with the design assessment team. Similarly, the results of the examinations, particularly deficiencies, will be provided to the IDA for evaluation of possible design implications.

The review will include verification of:

• Installation and construction of essential equipment / system characteristics

• As-built configuration utilized in design verification

• Adequacy of welded and mechanical joints *

• Location, orientation, and configuration

• Cable c- 'un. cnd termination

• Separatioc and clearances The primary focus will be on hardware installation and construction qual-ity. Hardware will be inspected to determine if it meets the installa-tion requirements in design documents. When deficiencies are identified, related program centrols will be reviewed to determi 2 if the controls are adequate. When appropriate, the assessment will be expanded horizon-tally beyond the sample system boundaries as necessary to establish the limits of the concerns.

5. ICA APPROACH BY DISCIPLINE 5.1 Mechanical Construction A sample of heat exchangers, pumps, pipe, strainers, pipe supports, and other equipment associated with the CHR mode systems will be verified for conformance to design drawings, specifications, and site procedure re-quirements. Similarly, coatings, insulation and other material which could interact with the CHR function will be verified against require-ments. Items to be verified include material traceability, identifica-tion, location, orientation, bolting, dimensions, supports, in place storage and maintenance.

5.2 Welding / Nondestructive Examination The welding and NDE programs will be reviewed. This review will include

parameters relative to weld rod control, weld procedures, welder

! qualification, NDE procedure qualifications, and NDE personnel

qualifications. An appropriate sample of CHR mode system welds will be

! visually examined. Material traceability, welder and examiner personnel qualification, and NDE records including radiographs for the welds will l

i be examined for compliance with requirements as applicable.

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I 5.3 Electrical and Instrumentation Construction A sample of electrical components, including motor-operated valves, asso-ciated with CHR mode systems beginning with the emergency diesel genera-tors through each applicable level of electrical distribution (e.g, 4 kV ac, 480 V ac, 120 V ac, 125 V de, 48/24 V de) will be reviewed to verify compliance with requirements. The components plus the cable, cable ter-minations, and raceway and raceway supports will be included. Selected actual cable lengths (documented during construction) will be verified against those used in electrical voltage calculations. Also, selected critical installations will be included. Acceptance criteria will be taken from project specifications, drawings and procedures, as well as from recognized industry practices. Such things as receipt inspections, storage, handling and installation, cable pulling, maintenance, testing, and documentation will be examined as necessary for both in process and previously installed items.

5.4 Civil / Structural Construction A sample of structural installations (structural concrete / grout, soil placements, embedments, erected structural steel, and masonry construc-tion) used to support or house the CHR mode systems will be examined for fulfillment of procurement and erection specification requirements. Com-pleted and/or in process work, and inspection activities will be reviewed to verify compliance to specifications, drawings, and industry codes and standards.

5.5 Quality Assurance and Quality Control The Quality Assurance (QA) Program applicable to the construction of CHR mode systems will be reviewed. A sample of documentation will be reviewed and personnel interviews conducted to verify useability and i technical adequacy of inspection procedures, adequacy of inspector I

training and qualification, and freedom of inspectors from harassment.

Nonconformance and design change mechanisms will be checked to verify their adequate description in procedures with resultant changes appropriately approved, effectively transmitted to the field, and '

accomplished and inspected. Corrective action systems including the atdit program will be reviewed for proper tracking and closeout, I

trinding, and upper management involvement. Finally, the construction completion process for CHR mode systems will be reviewed to verify for completion and accuracy of testing. In addition, the transition to the operational modei and appropriate transfer of design control from the construction to the operating organization will be evaluated.

5.6 Procurement / Receipt / Storage The effective integration of procurement, receipt, and storage activities will be verified. A sample of CHR mode systems hardware in receipt and

, storage areas as well as those items installed in the plant will be l assessed for adequate source control, handling / identification / trace-

! ability from fabrication through u.a t a11a t ion , upgrading of commercial grade parts, and compliance to preventive maintenance requirements.

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6. ASSESSMENT TEAM The team will function under the direction of the SWEC Quality Assurance Department with reporting authority to the SWEC Vice President, Director of Quality Assurance. .Should PEco personnel.be assigned for the assess-ment, they:will report to SWEC supervision for the duration of this as-signment. The SWEC team members will be experienced technical personnel.

Team members are identified on Attachment 1.

7. TEAM PREPARATION Review applicable FSAR sections, NSSS documents, and related project procedures and technical criteria to become familiar with _ system function, design basis requirements, and project-specific consider-ations. Identify and assemble key documents necessary for the as-sessment (e.g., P& ids, Design Criteria, etc).

Determine status of design documents (Example: Determine what pipe stress analysis problems have been stress reconciled).

• Discuss and establish means to evaluate interface between disciplines.

Refine scope and approach to indicate discipline-specific scope and approach, specific interfacing systems, and structures to be evaluated.

Prepare discipline task sheets as necessary to address general prep-aration requirements, refined scope, and any additional requests by team members.

Develop IDA review plans specific to the discipline and areas to be reviewed. The review plans are to reflect the scope of the review and the means for evaluating discipline interface and identify the detailed attributes that are to be pursued during the review. De-velop checklists as required.

Orient the team members with the Limerick 2 organization and pro-grams and the concept and scope of the assessment for general indoc-trination of assessment team members.

• Review recent NRC inspecticn reports, applicable construction and inspection procedures, and general installation snecifications and any reported assessments.

Review scoping information (system diagrams, equipment lists, iden-tification of system boundaries, components, structures, etc) and the specific applicable installation instructions to determine hard-ware requirements.

Develop ICA review plans. Attributes to be verified shall be based on installation requirements, experience of the team members and an l analysis of CAT inspection findings at other nuclear plants. Devel-l op checklists as required.

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8. PERFORMANCE OF ASSESSMENT To facilitate the assessment of the CHR mode system and evaluate engi-neering activities, site walkdowns will bs conducted. Incomplete instal-lation will be noted and controls on remaining work will be evaluated for impact on assessment results.

The team members will annotate the review plans to specifically and com-pletely identify the documents / designs reviewed or hardware inspected and to document, in detail, the review for each attribute. Any support docu-mentation and notes will be included as part of the review plan record.

Review plans shall be utilized as a guideline to ensure all necessary activities are reviewed and as the principal method of collecting the results.

Potential engineering or design concerns identified by the construction assessment group (ICA) will be forwarded to the design assessment group (IDA) for investigation and followup as appropriate. The ICA group will investigate and follow up on construction concerns received from the IDA group as appropriate.

During the performance of the assessment, SWEC will identify to Bechtel a potential concern (s) or question (s) using an Action Item (AI). The AI will be documented on a form to provide Bechtel (and other PECo contrac-tors) the opportunity to review a potential concern or question and re-spond in writing with information as to the validity of the potential concern or answer the question. Bechtel will be expected to respond to each AI promptly. All AI's will be uniquely identified and a status log will be maintained for tracking and accounting purposes. A copy of each AI initiated by SWEC will be provided to PECo and the NRC upon issuance.

A copy of the AI responses from Bachtel will be provided to PECo and the NRC by Bechtel upon issuance.

If the information in the AI response is sufficient to establish that the SWEC potential concern is invalid, or answers the question satisfactori-ly, the AI will be closed. If the information in the AI response indi-cates that a potential concern is valid, the AI will be incorporated into an Observation Report (OR). An OR may be issued to incorporate more than one AI concern, depending on their scope and natures. Traceability be-tween incorporated AI's and OR's shall be maintained. OR's will be transmitted to Bechtel for evaluation of the concern identified. In identifying the preposed action (s) to resolve the concern (s) stated in the OR, Bechtel will be expected to provide sufficient information for SWEC evaluation including causal factors, extent of condition, signifi-cance, and applicable proposed corrective action and preventative action, if required. OR's with the proposed resolution by Bechtel, will be transmitted to SWEC following review by PECo. SWEC will evaluate the adequacy of the proposed resolution. If the proposed resolution to an OR is not acceptable to SWEC, the rejected response will be transmitted to Bechtel, noting any remaining concern (s). Upon receipt of a rejected response to an OR, Bechtel may request a meeting, in accordance with pro-gram protocol regarding communications, to obtain any clarification which may be required as to the basis for the rejection of the response. A status log will be maintained to track and account for all OR's. Copies 7000-18138-HC2 16 Rev. 1, July 6, 1988 I

of all OR's initiated by SWEC will be transmitted to PEco and the NRC upon issuance. Copies of the OR responses provided by Bechtel to SWEC, will be provided to PEco and the NRC by Bechtel upon issuance. The OR, with proposed resolution and SWEC's evaluation, will be made part of the IDCA Final Report.

9. EVALUATION OF RESULTS The observations from the assessment will be categorized, grouped, and trended to determine the overall significance and impact on the adequacy and implementation of the design and construction process.

10. REPORTING At the conclusion of the assessment, an IDCA report will be prepared in the following general format:

1. Introduction

2. Purpose

3. Scope

4. Summary of Results and Overall Conclusions

5. Summary by Discipline (both IDA and ICA)

6. Observations Reports l

7000-18138-HC2 17 Rev. 1, July 6, 1988

. Pega 1 of 4 ATTACHMENT 1 LEAD PERSONNEL FOR IDCA TEAM The IDCA personnel have been organized into two groups for the IDA and ICA efforts, respectively, under the direction of the IDCA Program Manag-er. The IDCA team members and support personnel requirements are listed on page 4 of this attachment. The following provides a brief summary of the key team personnel and their related experience.

Program Manager Mr. H. E. Daniels has recent management experience at the Clinton Power Station. As a Stone & Webster employee, Mr. Daniels was loaned to Illi-nois Power Company f rom March 1984 through July 1986 and functioned as their Project Manager during the final stage of construction, startup, and operations. During this period, the Clinton Project successfully completed an NRC Construction Assessment Team (CAT) inspection and an Independent Design Review (conducted by Bechtel Power Corporation on the Clinton Power Station architect / engineer Sargent & Lundy).

IDA Croup Assistant Program Manager - Mr. D. J. Wille is a registered Professional Engineer with over 25 years of engineering, design, and management expe-rience in the nuclear power industry. Mr. Wille recently was assigned to the construction assessment programs at both Braidwood Nuclear Power Plant and Comanche Peak Steam Electric Station, providing an engineering review of the approach, results, and final reports. In the fall of 1987, he was Task Leader for an independent review of nuclear and mechanical calculations for the Watts Bar Nuclear Power Plant and Sequoyah Nuclear Plant. He was also the Lead Engineer for design verification of modifi-cations and changes to the diesel generator system for the Clinton Power Station.

Mechanical Systems Lead - Mr. G. E. Hirst is a registered Professional Engineer with over 15 years of engineering erperience, including 12 years on the River Bend Station project. Mr. Hirst also has participated in the independent review of component reclassifications in support of the equipment qualification program for the Fermi 2 Power Plant.

Mechanical Components Lead - Mr. N. S. Motiwala is a registered Profes-sional Engineer with over 20 years of engineering experience, including 10 years on BWR plants at River Bend Station and Nine Mile Point Nuclear Station. While assigned as Lead Engineer to the River Bend projec*, the NRC conducted an integrated design inspection, and Mr. Motiwala inter-faced with the NRC audit team in the engineering mechanics area.

Electrical Lead - Mr. E. F. Heneberry is a registered Professional Engi-neer with over 20 years of engineering experience, including 15 years on nuclear power plant projects. In addition, Mr. Heneberry has been the Lead Electrical Engineer on independent design verification reviews for design adequacy for the Fermi 2 Power Plant and Diablo Canyon Nuclear

7000-18138-HC2 Rev. 1, July 6, 1988 i

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• Pege 2 of 4 Power Plant. At Diablo Canyon, an onsite inspection was performed to verify selected equipment and systems. He also provided electrical re-view and assistance to the client's Readiness Review Program for engi-neering, design, and construction of the Vogtle Station.

Instrument and Controls Lead - Mr. J. C. Bisti has over 20 years of engi-neering experience, including a total of 10 years with increasing con-trols systems engineering responsibilities on the River Bend and Nine Mile projects. While assigned as Project Engineer to the River Bend pro-ject, the NRC conducted an integrated design inspection for the engineer-ing effort. Mr. Bisti represented the project at all status and final review meetings with the NRC and reviewed all written responses by the project to issues raised during the inspection. He is currently Control System Division Engineering Supervisor at the SWEC Cherry Hill Office.

Civil / Structural Lead - Mr. B. E. Ebbeson is a registered Professiona*

Engineer with over 15 years of engineering experience, including 11 years on several nuclear projects with increasing responsibilities. Mr. Ebbe-son is currently the Lead Engineer responsible for the independent and detailed technical review of all civil / structural calculations for the Browns Ferry Plant for Tennessee Valley Authority. He also participated in reverification of the final design in the civil / structural area for a nuclear power plant for the Washington Public Power Supply System.

Coordinator - Mr. J. R. Kirby is a Certified Lead Auditor and has 'over 15 years of experience in the engineering industry. For the past 5 years, Mr. Kirby has been responsible for quality assurance audits cf engineering and design activities for various Stone & Webster nuclear power plant projects. In particular, he has been an Audit Coordinator for the pipe stress / pipe support requalification effort performed by Stone & Webster for the Comanche Peak Steam Electric Station. ,

ICA Group Assistant Program Manager - Mr. E. B. Fleming has been at Stone & Webster for over 15 years. For the last 8 years, Mr. Fleming has managed the quality assurance audit program and conducted assessments for various utilities. He managed an audit at Hillstone Nuclear Power Station -

Unit 3 to provide a further evaluation of INPO construction assessment findings; managed the construction portion of a Stone & Webster "vertical slice" audit of the RCIC system at Nine Mile Point - Unit 2 conducted under NRC overview to obviate the need for an NRC IDVP; and was a member of the Niagara Mohawk Power Corporation / Stone & Webster team providing response and corrective action for the Nine Mile Point CAT inspectior..

Coordinator - Mr. R. B. Avrich has 19 years of experience at Stone &

Webster in quality assurance, shop inspection, and auditing. Mr. Avrich is a Certified Lead Auditor and is certified in NDE processes as well.

Welding and Nondestructive Examination Lead - Mr. B. C. Jersild has over 20 years of experience in quality assurance and nondestructive examina-tion. Mr. Jersild has Level III certifications in liquid penetrant, mag-netic particle, and radiographic testing and is a Certified Lead Auditor. l He is a member of the ASME B&PV Committee on radiography. At Nine Mile 7000-18138-HC2 Rev. 1, Juty 6, 1988

. j e Pegs 3 of 4 l I

Point - Unit 2, he was' responsible for preservice (ASME XI) inspection activities.

Mechanical /HVAC Lead - Mr. C. E. Cay has 32 years experience in the nu-clear industry. He has been assigned as a Superintendent and Assistant Superintendent of Quality Control at several nuclear plants under con-struction. He has been responsible for quality control of piping, weld-ing, mechanical systems and components, pre-ops and construction-testing and final system turnover. Mr. Gay was a member of a team evaluating the adequacy of the QA/QC programs at the Clinton Nuclear Power Station. He was recently a member of the QA Concerns Evaluation Group at TVA's Watts Bac plant. He has participated in replacement / spare parts evaluation programs at power plant sites and vendor facilities.

Civil / Structural Lead - Mr. J. C. Thompson has over 25 years of experi-ence in civil / structural engineering and quality assurance. He has been assigned as Superintendent of Quality Control at four nuclear power sta-tions under construction. He managed teams for design verification walk-down reinspections at Davis-Besse Nuclear Power Station, reinspection of installed and previously accepted work at Braidwood, and independent overview of the Construction Completion Program at Midland Nuclear Power Station.

Electrical / Instruments and Controls Lead - Mr. F. N. Morrissey has over 22 years of experience at Stone & Webster. During this period, Mr.

Morrissey has served as a Design and a Construction Engineer, Construc-tion Supervisor, and Assistant Project Engineer, all with responsibili-ties in the electrical area on eight nuclear and fossil power plants. He also served as QA Program Manager for Beaver Valley Power Sta-tion - Unit 2, where he was responsible for coordinating NRC inspection responses.

Piping / Piping Supports Lead - Mr. J. Crossland has over 20 years of nu-clear construction inspection experience. Currently as Inspection Super-visor, he has worked on nine nuclear power plants including a period on the construction completion team at Midland. His inspection experience has been concentrated in piping, piping supports, and associated welding.

Procurement / Receipt / Storage - Mr. F. J. Qualter has 28 years of experi-ence in the quality assurance and reliability field in the nuclear ship-building, computer, and construction industries. Mr. Qualter has developed and implemented quality assurance programs and procedures in each of these industries. He is currently assigned as Assistant Manager of Procurement Quality Assurance. He has developed audit programs and conducted audits both of construction and manufacturing quality programs.

He also has performed assessments of various utility and governmental programs.

j QA/QC Lead - Mr. R. J. Scannell has over 12 years of quality assurance experience. This experience includes inspection and testing in the civil / structural area, auditing of construction quality programs, and program reviews and surveillances for the TVA restart effort at Sequoyah.

During the latter years of construction of Millstone 3, Mr. Scannell

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served as the QA Project Manager, in which capacity he was a member of the CAT Response Team. '

IDCA TEAM MEMBERS Title No. of People IDCA Program Oversight Committee 4 J. E. Huston, Chairman Program Manager 1 H. E. Daniels, Jr.

Coordination / Administration 2 W. Baranowski Clerical 2 -

Subtotal 9 IDCA - Design Review Asst. Program Manager 1 D. J. Wille Mechanical Systems 3 C. E. Hirst Mechanical Components 3 N. S. Motivala Electrical 2 E. F. Heneberry Instrument & Controls 3 J. C. Bisti Civil / Structural 2 B. E. Ebbeson Coordinator 1 J. R. Kirby Clerical 1 -

Subtotal 16 IDCA - Construction Review Asst. Program Manager 1 E. B. Fleming Welding and NDE 2 B. C. Jersild Mechanical /HVAC 1 C. E. Gay civil / Structural 1 J. C. Thompson Electrical /I&C 2 F. N. Morrissey Piping / Pipe Supports 3 J. Crossland Procurement / Receipt / Storage 1 F. J. Qualter QA/QC 1 R. J. Scannell Coordination 1 R. B. Avrich Clerical _1 Subtotal 14 7000-18138-HC2 Rev. 1, July 6, 1988

• Pags 1 of 2 ATTACHMENT 2 PROTOCOL COVERNING CONDUCT OF INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT (IDCA) LIMERICK UNIT 2 In the conduct of the IDCA by Stone & Webster Engineering Corporation (SWEC), the following protocol chall be adhered tot

1. SWEC may request documentation material, meet with and inter-view individuals, conduct telephone conversations, or visit the Site, PECo, Bechtel, General Electric, or other contractor's offices to obtain information without prior notification of the NRC or other outside organizations. Communications and trans-

- mittals of information shall, however, be documented and such documentation shall be maintained in a location accessible for NRC examination. Communications between the SWEC and PECo, solely with respect to financial and administrative aspects of the IDCA contract, are outside the scope of this protocol.

2. Observations, reports, evaluations and all exchange of corre-spondence, including drafts, between SWEC and PEco (including its contractors and subcontractors) will be submitted to the hRC at the same time as they are submitted to PECo. In addi-tion, SWEC shall maintain IDCA files in such condition as to be prepared for NRC examination at any time throughout the assess-ment, including backup documentation in support of observa-tions, evaluation of proposed resolutions, recommendations, trend analysis, etc.

3. Action Items (AI) and Observation Reports (OR) initiated by SWEC will be transmitted to Bechtel for action. Copies of AI's and OR's initiated by SWEC will be provided to the NRC and PECo by SWEC upon issuance. Copies of responses to AI's and OR's providad by Bechtel will be provided to the NRC and PECo by Bechtel upon issuance.

4. Following the issuance of an OR, Bechtel (or other responsible PECo contractor) may discuss the observation with SWEC to ob-tain further clarification and additional information to allow a full understanding of the observation and its basis. In these instances, the NRC will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of telephone calls and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in advance of meetings. Such communications or meetings shall be documented. Copies of such documentation shall be maintained accessible for NRC examination.

5.. Following the issuance of an OR, should it be necessary for Bechtel (or other responsible PEco contractor) to discuss pos-sicle or proposed resolutions or actions with SWEC, the NRC will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of telephone calls and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in advance of scheduled meetings to allow the opportunity for participation. Such communications or meetings shall be documented. Copies of documentation shall be provided to the 7000-18138-HC2 Rev. 1, July 6, 1988

. P:ge 2 of 2 NRC and PEco in a timely manner, including copies of the Obser-varion Reports discussed.

6. To support the NRC independence criteria, each member oi the IDCA team will be required to execute an IDCA agreement and an IDCA questionnaire. Exceptions noted on the IDCA questionnaire will be evaluated by SWEC and the executed questionnaires will be available for NRC and PEco review. Copies of these agree-ments and questionnaires are included as Appendices A and B respectively to this attachment. Also, any full-time PECo em-ployees assigned to the IDCA team will be under the direction of SWEC. Such personnel will be required to execute the PEco employee IDCA assignment acknowledgement and agreement included as Appendix C to this attachment to ensure objective conclu-sions and prevent compromising the purposes of this assessment.

7. If, during the conduct of this assessment, SWEC identifies an item for which it appears that an evaluation needs to be per-formed to assess potential reportability, SWEC will issue a copy of the appropriate documentation of the item (AI or OR) directly to the PECo General Manager of Nuclear Quality Assur-ance (NQA) for evaluation and reporting as required. In addi-tion, a copy of the document will be sent to the NRC and Bechtel in lieu of the AI or OR issue process defined in Section 3 of this protocol.

7000-18138-HC2 Rev. 1, July o, 1988

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Limerick Unit 2

, IDCA Progrtm Picn

. Attachment.2 '

Appendix A ACREEMENT INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT j LIMERICK UNIT 2

{

l I (print or type name) hereby agree that:

l

1. I will notify the P-ogram Manager if during the term of this project Y, or any member of my immediate family (parents, spouse, children and grandchildren) acquire any financial in-terest in Philadelphia Electric, Bechtel, General Electric or any site contractor at the Limerick-2 Power Station.

2. If I identify what I believe to be a potential discrepancy hav-ing the potential for a significant safety impact, I will imme-diately notify the Assistant Program Manager for further evaluation.

3. I will treat all information revealed to me in the course of my work on this~ project as confidential and will not disclose it to others not involved in the project except as directed by the Assistant Program Manager.

(Signature) IDate) 7000-18138-HC2 Rev. 1, July 6, 1988

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., IDCA Progrem Plen Attachment 2 Appendix B PERSONNEL QUESTIONNAIRE INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT LIMERICK UNIT 2 After first being duly sworn hereby de-poses and sayst (print or type name)

1. I have no previous involvement with the Limerick Project, except as noted on the reverse side.

2. I have not previously been hired by PECo, Bechtel, General Electric or a Limerick 2 site contractor to perform similar audits, except as noted on the revet,e side.

3. I have not been previously employed by PEco, Bechtel, General Elec-tric, or a Limerick 2 site contractor, except as noted on the re-verse side.

4. I do not own or control stock of PECo, Bechtel, General Electric or a Limerick 2 site contractor, except as noted on the reverse side.

5. No member of my present household is employed by PEco, Bechtel, Cen-eral Electric, or a Limerick 2 site contractor, except as noted on the reverse side.

6. None of my relatives is employed by PEco, Bechtel, General Electric or a Limerick 2 site contractor, except as noted on the reverse side.

7. I have not been offered future employment by PEco, Bechtel, General l Electric or a Limerick site contractor, except as noted on the re-verse side.

I hereby affirm . that the above is true and correct to the best of my knowledge.

i

, (signature) (date) l l Subscribed and sworn to before me on this ,_ day of 1988.

l l My commission expires:

l Notary Public l 7000-18138-HC2 Rev. 1, July 6, 1988

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Linerick Unit 2

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IDCA Program Picn Attachment'2 Appendix C PECo EMPLOYEE ASSIGNMENT ACKNOWLEDCMENT AND AGREEMENT INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT LIMERICK UNIT'2 I,

, aa employee of Philadelphia Electric Company (PECo) having been assigned to the Stone & Webster Engineering Corpora-tion (SWEC) IDCA Project Team, hireby acknowledge / agree that:

1. I have accepted this assignment with full understanding of its ccopa and protocol.

2. I will perform duties and accept responsibilities as assigned by SWEC Program management / supervision related to the execution of IDCA activities as governed by .the IDCA Program Plan and implementing procedures (The Program Manual).

3. I will, while a member of the SWEC IDCA Project Team, remain totally isolated froa my normal PECo activities to ensure my total objectiv-ity during the conduct of the IDCA.

4 I will treat all information revealed to me or obtained through the executien of my responsibilities on the SWCC IDCA Project Team as confidential and will not disclose or discuss it with any PECo em-ployees (or other personnel) not involved with t.be projectl except in accordance with of established IDCA protocol and procedures.

5. I will be able to conduct administrative communications be activi-ties, not related to the IDC4 (e.g., personal matters related to PECo N

employee responsibilities, personal / social relationships with ot ar "Eco employees etc.) but will remain sensitive to the indepen-derce objective of the IDCA effort.

6. I understand the possible adverse lupact on the objectivity of con-clusions and the possibility of coerromising the purpose of the IDCA for failure to comply with the above.

(Signature) (Date)

We have jointly discussed the . .is signment to the SWEC IDCA Project Team with the above PECo employee and believe that the individual has been fully briefed and understaads the assignment. We further believe that the individual unders' ends the possible adverse impact on the objectivity of conclusions and the possibility of compromin-ing the purpose of the IDCA for failure to perform assianed activi-ties with objectivity and in accordsnee established SWEC IDCA procedures.

SWEC IDCA Program Manager (Date) ,

PECo General Manager NQA Signacure (Date) 7000-18118-HC2 Lev. 1, July 6, 1988

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