IR 05000445/1985017

Insp Repts 50-445/85-17 & 50-446/85-14 on 851028-1101 Re Design Adequacy Program Scope Validation Process & Review Checklist Development.Lack of Prescriptiveness of Review Checklists & Reviewer Qualifications Noted

ML20198G922
Person / Time
Site:	Comanche Peak
Issue date:	01/09/1986
From:	Milhoan J, Norkin D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20198G920	List: IR 05000445/1985017 ML20198G916
References
50-445-85-17, 50-446-85-14, NUDOCS 8601300013
Download: ML20198G922 (69)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ,

Division of Quality Assurance Vendor, and Technical Training Center Programs Quality Assurance Branch Report Nos.: 50-445/85-17,50-446/85-14 Docket Nos.: 50-445, 50-446 Licensee: Texas Utilities Generating Company Skyway Tower 400 North Olive St., L.B.81 Dallas, Texas 75201 Facility Name: ComanchePeakSteamElectricStation(CPSES)

Inspection At: .e TERA Corporation, Bethesda, Maryland Inspection Conducted: October 28 - November 1, 1985 Inspection T.eam Members:

Team Leader D. P. Norkin, Senior Inspection Specialist IE Civil / Structural R. E. Shewmaker, Senior Civil Engineer, IE K. P. Buchert, Consultant, WESTEC Services J. Blackman, Consultant, WESTEC Services Piping / Supports D. Terao, Mechanical Engineer, NRR W. P. Chen, Consultant, ETEC - Rockwell International Mechanical Systems / S. !i. Klein, Consultant, WESTEC Services Components J. Nevshemal, Consultant, WESTEC Services Electrical /I&C G. W. Morri Consultant, WESTEC Services L. Stanley, Consultant, Zytor, In S. V. Athavale, Inspection Specialist, IE J. L. Knox, Senior Electrical Engineer, NRR ,

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Fonald P. Norkin Date Team Leader, IE O

Approved by wu '3mes L. Milhoarf w _ l[1/96 Date

'ection Chief, Quality Assurance Branch b0 00$ Ob0 5

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Table of Cont;nts Inspection of Comanche Peak Design Adequacy Program Scope Validation Process and Checklist Development

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Page Table of Contents i List of Acronyms 11 Introduction and Sumary 1-1 Personnel Contacted - Attendees at Entrance and/or Exit Meeting 2-1 Appendices 1: Phase 3 Scope Validation Process A-1 2: ResolutidiiofCommentsin8/9/85NRCLetter, A-4 Civil / Structural 3: Resolution of Coments in 8/9/85 NRC Letter, A-6 Mechanical Systems and Components 4: Resolution of Coments in 8/9/85 NRC Letter, A-13 Table 2. I&C Matrix 5: Resolution of Coments in 8/9/85 NRC Letter, A-19 Table 3. Electric Power Matrix

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6: Resolution of Coments in 9/30/85 NRC Letter, A-22 .

Design Adequacy Program Plan (Appendix A)

7: Resolution of Coments in 9/30/85 NRC Letter, A-26 .

DSAP VIII Civil / Structural 8: . Resolution of Comments in 9/30/85 NRC Letter, A-28 DSAP IX Piping and Supports 9: Resolution of Coments in 9/30/85 NRC Letter, A-31 DSAP X Mechanical Systems and Components

. 10: Resolution of Coments in 9/30/85 NRC Letter, A-34 DSAP XI Electrical /I&C Systems and Components 11: Discrepancies between Appendices 2-10 and A-45 CPRT-113 dated November 22, 1985 12: Coments on Review Checklists A-47 Table 1 Listing of Review Checklists T-1 i

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List of Acronyms ACI Am'rican e Concrete Institute -

AISC American Institute of Steel Construction

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ASME American Society of Mechanical Engineers ANSI American National Standards Institute ASTM American Society for Testing and Materials CFR Code of Federal Regulations FSAR Final Safety Analysis Report HELB High Energy Line Break HVAC Heating, Ventilation, and Air Conditioning IEEE Institute of Electrical and Electronics Engineers LOCA Loss of Coolant Accident NEMA National Electrical Manufacturers Association NPSH Net Positive Suction Head NRC U.S. Nuclear Regulatory Commission P & ID Piping and Instrumentation Diagram PSAR Preliminary Safety Analysis Report NSSS Nuclear Steam System Supplier BOP Balance of plant

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, . 1 INTRODUCTION AND SUMMARY 1.1 BACKGROUND  ;

Texas Utilities Generating Company (TUGCO) letter dated June 28, 1985 to the ,

NRC transmitted the Comanche Peak Response Team (CPRT) Program Plan, Revi- '

sion 2 dated June 28, 1985. Appendix A to the Program Plan describes the Design Adequacy Program (DAP). The DAP is comprised of four Discipline Specific Action Plans (DSAPs) covering the following design disciplines:

Civil / Structural; Piping / Supports; Mechanical Systems and Components; and Electrical / Instrumentation and Control Systems and Components. These DSAPs (VIII through XI) are to be executed by TERA Corporation, and provide for third-party reviews of CPSES architect-engineer activities performed by Gibbs and Hill, Stone and Webster, and Ebasco. NRC letters dated August 9, and September 30, 1985 from V. S. Noonan to W. G. Counsil commented on the CPRT Program Pla .2 OBJECTIVES The Office of Inspgetion and Enforcement (IE) is responsible for inspecting the third-party reviews conducted by TERA in accordance with OSAPs VIII through XI. (The scope of the DAP will be reviewed and approved by the Office of Nuclear Reactor Regulation, with input from IE). IE inspections will be phased to cover the various phases of TERA work; e.g., checklist development, DSAP implementation, final report preparation, and corrective action imple-mentation. IE inspection reports will be issued at each phase. In additio IE will prepare Safety Evaluation Report input evaluating the DAP executio This current inspection covered the Phase 1-3 TERA scope validation process, review checklists, and evaluation of the qualifications of TERA reviewer .3 SCOPE VALIDATION PROCESS >

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The DAP addresses both external source issues, such as those identified by the Cygna Independent Assessment Program, and self-initiated issues, which are identified in an expanded " vertical slice" review of areas where there -

have previously been no external source issue Identification of external source issues is accomplished by a systematic review of documents containing these issues for concerns questioning either the CPSES design or design proces TERA procedure DAP-2, " Documentation '

and Tracking of Issues and Discrepancies," covers a computer tracking system for ensuring that current and future external source issues potentially af-fecting design are resolved. One method of resolution is to investigate further through one of the DSAPs. Accordingly, the DSAP scopes cover external source issues. IE plans to review the computer tracking system during its implementation inspection to evaluate the completeness of' identified issues and the manner for ensuring that issues are resolve Except for DSAP IX, " Piping and Supports," the major portion of DSAP scope is "self-initiated," 1.e., unrelated to existing issues. This scope is determined in a four phase process. Revision 2 of CPRT Program Plan reflects completion of Phase 1 and E. Phase 1 was based on a systematic review of past Integrated Design Inspections and Independent Design Verification Programs to identify typical scopes for such reviews. Based on this, TERA selected a

" vertical slice" of the balance of plant design effort within the entire class 1E onsite electric power systen and the auxiliary feedwater (AFW) system, 1-1 . . _ - . - . ._ _ _ - . _ . ..- - - - . - - - _ - _ . -.

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including hydraulic and I&C design considerations. Additionally, a " vertical slice" of the civil / structural design was selected. Phase 2 was to confirm that the above " vertical slices" were representative of other safety-related l

systems and that conclusions drawn may be later extrapolate ,

Phase 3 involves analysis of the actual design processes, organizations, and activities in the Phase 1/2 scope versus the processes, organizations and activities in the aggregate architect-engineer design scope performed at CPSES. This step was intended to confirm the breadth of the initial scope (or identify necessary expansions) and establish the minimum depth necessary for extrapolation of the results to the entirety of the BOP design process related to safety-related systems, components and structures. As indicated below, the " generic given" concept indicates the " BOP design process" is being defined to exclude NSSS design scope and that of most equipment vendor Phase 4 involves potential scope expansion based on the results of the revicws conducted under DSAP .o*

IE focused on the methodology for executing Phase 3 because Phase 3 was in-tended to ensure that any design activity not identified in Phases 1 and 2 would be reviewed if appropriate. The TERA Phase 3 Scope Validation Sumary Report, DAP-E-PM-001 dated 10/27/85, addresses the purpose and results of the Phase 3 Scope Validation Process. Phase 3 was performed on a technical disci-pline basis. Each discipline identified " Homogeneous Design Activities" (HDAs);

each of these had homogeneity in: design criteria; design considerations, ap-proach and methodology; organization which performed the activity; design control process; and design interfaces. The attributes of criteria, design considerations, etc., and different organizations (e.g., G&H TUGC0 Nuclear Engineering) were applied to the design activities by each DAP disciplin Commonality over time within an organization / discipline and in the design control process were evaluated on a program basis. EAamples of HDAs include air change requirements for HVAC design, setpoints for control circuits, and transient analyses for loss of bus voltag ,

For each discipline, the HDAs were compared with TERA review checklists devel-oped to implement Phase 1/2 scope. Resultant matrices identified HDAs which

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were not addressed by existing checklists. For such cases, TERA took one of two actions as follows:

(1) The' scope was expanded either by expanding the AFW system t review or by reviewing another system in cases where the AFW

" vertical slice" did not contain the HDA attribute.

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(2) It was decided that the HDA was a "given." A "given" is a design activity which is considered correct and is not under question; i.e., the activit is not subject to review under the DA There ,

are two types of { givens", " generic givens" and " candidate givens."

" Generic givens" have been identified based on justification which is provided at the program level. These include internal NSSS design scope and internal design scope by equipment vendors (excluding designs unique to CPSES). " Candidate givens" are identified on a case, rather than programatic, basis and apply to design activities for which there have been previous independent reviews which were comparable in scope and depth to that which DAP would have performed.

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The Office of Nuclear Reactor Regulation will address the "given" concept in conjunction with final DAP scope approva DAP-E-PM-001 stated that there are four remaining activities to be completed to confirm / finalize the DAP self-initiated evaluation scope. These are as follows:

(1) Review the background of the preliminary unique vendors to confirm if their services were unique to CPSE (2) Complete the review of lists of recent TUGC0 Nuclear Engineering

(TNE) design to finalize the TNE scope of desig (3) Confirm, through review of G&H design control procedures, that changes did not occur over time in the design process that would create new HDA (4) Perform sufficient review to confirm or deny the " candidate given.",,,

IE will inspect these confirmatory actions in future inspections to evaluate their relevance to the defined Phase 3 scop I The IE inspection of Phase 3 focused on the validity of identified HDAs, omission of design activities which apparently should be covered by HDAS and

correspondence of Phase 1/2 checklists to the HDAs. The inspection team generally agreed with TERA conclusions that certain checklists adequately

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covered HDA Exceptions to this are addressed in Appendix 12. " Comments on Review Checklists." Team conclusions were predicated on confirming the homo-geneity of HDAs. Failure to confirm this will result in additional HDAs and

new or revised checklist ~

Appendix 1, to this report, addresses a fundamental problem with the HDA criteria for homogeneity. TERA was unable to provide to the team Gibbs and Hill docu-mentation covering guidance to designers / analysts on design considerations, .

! approach and methodology, which would be needed to substantiate the sample selection based on the HDA rationale alone. Specifically, the inspection team used the civil / structural discipline as an example. The team was unable to conclude that the problem identified for civil / structural is restricted to that discipline. It is understood that, since the inspection, TERA has identified design methodology guidance pertinent to some HDA Design criteria pertinent to the DAP were documented for Phase 2 scope in ac-cordance with procedure DAP-1, " Preparation and Review of Criteria Lists." This will be accomplished for Phase 3 scope as well. The team did not review the extent to which these have been identified with specific HDAs. Se'ction 1.4 i . indicates that design criteria are listed in review checklists.

In future inspections, IE plans to determine whether calculations and other

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design products reviewed by TERA are representative of the design process and

! the degree to which the HDAs are representative of the design process. To the degree that TEPA relies on the HDA rationale to justify that the sample selected is representative, TERA needs to confirm the validity of the HDA process with respect to its review sample, and provide a documented trail of its confirmation.

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The Office of Nuclear Reactor Regulation is further addressing the HDA develop-ment process in conjunction with final DAP scope approva '

1.4 REVIEW CHECKLISTS ,

TERA is developing review checklists to match the scope indicated in Revision 2 of the Program Plan and as expanded by the Phase 3 scope validation proces These checklists provide the basis for verifying that design criteria related to the program scope have been me TERA Procedure DAP-4 discusses preparation of checklists. Attachment C to DAP-4 prescribes the format for the checklist which was examined by IE and which is intended by the CPRT Program Plan to indicate the depth of revie The Attachment C checklists are required to list the " Attributes Reviewed,"

which are a subset of all the pertinent criteria / commitments. A " Description of Verification" column is also required to be completed to describe the method by which implementation of the criteria will be verified. As a related matter, the CPRT Program Plan states that the checklists will, "... correlate design criteria with specific documents (and associated design scope) to be reviewed."

Table 1 to this report titled, " Listing of Review Checklists," indicates the checklists that were available for our review. These are the checklists that resulted from Phase 1/2 scope validation. None of the checklists that will be developed to implement Phase 3 scope expansion were completed such as to be available to the team. In addition to evaluating checklists against HDAs, as indicated previously, we reviewed these checklists in order to:

(1) Confirm that NRC scope related comments in letters dated 8/9/85 and 9/30/85 were adequately addressed, as evidenced by demonstrated depth in checklist .

(2) Evaluate whether the checklists adequately document the depth of review and whether the depth is adequat ,

Appendices 2-11 address TERA's resolution of the aforementioned NRC scope related coments. The TERA resolution was verbally stated to the team during the inspec-tion and later confirmed formally in TUGC0 letter dated November 22, 1985. In most cases the TUGC0 letter was consistent with the information provided during

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the inspection. Exceptions are identified in Appendix 11, and in all such cases this report, rather than the TUGC0 letter, correctly reflects the TERA respons The NRC comments questioned whether the DAP scope would include specific design activities. The team evaluations of the TERA responses to the NRC comments resulted in a conclusion that the response was acceptable if it indicated that the specific design activity was enveloped by either the Phase 2 or 3 scop In all cases, either the TERA response or the team evaluation explains the extent to which the TERA response resolves the NRC commen In some cases, we have identified the need for existing checklist expansions or clarificatio The team will follow up with respect to these matters as well as review of Phase i 3 checklist . .

The t:am found that Attachment C checklists provid2 no more than a listing ,

of commitments. The " Description of Verification" column is often not l completed, and, when completed, does not indicate the various steps in confirming the design criteria are met. The team expected the checklist to be prescriptive with respect to all the desi n5 considerations that need to be addressed in ensuring the design criterion is met. While a successful review can be conducted with less prescriptive checklists, the lack of this detail puts a burden on experienced reviewers to closely follow the activities of less experienced reviewer .5 PERSONNEL QUALIFICATIONS The team evaluated TERA personnel with respect to their qualifications to perform the tasks identified by the Phase 1-3 scope and the review check-lists. The team performed this review primarily based on reviewing resumes and to a lesser extent based on our discussions with TERA personnel during the inspection. Since less than 20". of TERA personnel were available for these discussions, our review of personnel will be continued through the next phase of the IE review activities, i.e., evaluating DSAP implementatio Nevertheless, this' limited review did indicate potential problems with respect to having personnel with architect-engineer design experience in the areas covered by Phases 1-3 scop For civil / structural, there is a discipline leader and three subgroup leader Of the four, only the subgroup leader for the self-initiated review had architect-engineer nuclear experience. However, this experience is analysis rather than design oriented. Of the remaining personnel (17) who will apparently review self-initiated scope items, only four have had architect-engineer experienc In general, the 17 personnel have experience more related to analysis than design (as relevant to the DAP design review effort).

For mechanical systems and components, only two reviewers appear to,,have ~

design experience as necessary to implement the scope indicated in existing review checklists. Two additional reviewers have design experience which appears to match Phase 3 topics. Other reviewers have experience which ,

appears to be irrelevant to the design review scope, e.g. licensing, construction, maintenance, and weldin The team ' understands that the scope expansion realized by Phase 3 will be significant and will result in obtaining additional review personnel. In some cases, the review personnel on hand were never intended for some of the areas of Phase 3 scope expansions. TEPA indicated to the NRC inspection team that, for design areas unique to a nuclear power plant, reviewers will be assigned to review work which they have personally performed in a previous capacity in the design of a commercial nuclear power plant. If this co'mitment is met and the experienced reviewers include an adequate number with experience in the full A-E design process, then the team's concerns with review checklists and TERA review team qualifications should be adequately addressed. It is noted that, subsequent to the inspection, TERA took action to add approximately 25 personnel from an A-E organization (Gilbert / Commonwealth) to the DAP review tea IE will follow up during the implementation inspection to ensure that the balance between reviewer experience and the prescriptiveness of review checklists is appropriat I 1-5

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. . PERSONNEL CONTACTED

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Attendees at Entrance and/or Exit Meeting *

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Name Affiliation T. Ankrum NRC/IE A. Vietti-Cook NRC/NRR/DL C. Tramell - NRC/NRR/DL J. A. Calvo NRC/NRR/DSI S. Hou NRC/NRR/DE B. Grimes NRC/IE/DQAVT D. Davis -

TERA L. Shao NRC E. Marinos NRC/NRR V. S. Noonan NRC/ Director Comanche Peak Project J. L. Milhoan *', NRC/IE/QAB R. G. Bachmann NRC/0 ELD D. F. Landers Teledyne Eng. Services E. A. Solla - Teledyne Eng. Services J. Redding TUGC0 S. Karpyak TUGC0 H. Levin Design Adequacy RTL F. A. Dougherty DAP Manager E. B. Blackwood DAP/ Discipline Coordinator C. Mortgat DAP Civil / Structural Coordinator T. F. Snyder DAP Piping / Supports Discipline Coordinator R, F. Schofer DAP Mechanical Discipline Coordinator B. M. Rice DAP Electrical, Instrumentation & Control Design Coordinator D. C. Timins DAP Project Management Coordinator R. T. Boyd DAP/ Mechanical Engineer .

L. D. Bates DAP/I&C R. E. Levline DAP - Mechanical Support W. H. Hendrix DAP/I&C M. J. Shah DAP/I&C

, L. C. Fernandez DAP - Mechanical Support S. Wrona - DAP - Pipe Supports P. Streeter DAP - Piping Analysis R. Srinivasan DAP - Civil / Structural D. Goodyear DAP - Civil / structural G. E. Setka DAP - Electrical

, Q. R. Miller DAP - Electrical

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J. D. Voss DAP , Electrical K. C. Majumdar Delian Corporation / Electrical

• This list does not include IE team members. DAP personnel listed were contacted by the team during the inspectio ,

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APPENDIX 1 PHASE 3 SCOPE VALIDATION PROCESS

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The team reviewed the Phase 3 scope validation with respect to the validity of identified Homogeneous Design Activities (HDAs) and design activities not apparently enveloped by the HDA . Civil / Structural HDAs are required to have common design or analysis approach / methodology or me-chanics in design implementation such that meaningfully different complexities or considerations are not contained within that design activity. However, TERA had not obtained formal documentation pertinent to the Gibbs and Hill design /

analysis methodology and approach. Such documentation (instructions and pro-cedures) is normally utilized to establish design process control and thereby establish uniformity of technical approach in the execution of engineering for a projec .p'

The Civil / Structural Phase 3 Scope Validation document, including the HDAs identified within, is based on such items as the plant engineering documents available at Gibbs and Hill, TERA interviews with project personnel, and the engineering experience of TERA personnel in nuclear power plant desig DAP-E-PM-001 dated October 27, 1985 states that, on a programatic level (1)

organizational and design control process changes within Gibbs and Hill have not affected the identified HDAs and (2) there have been no changes to design methodology over time at Gibbs and Hill such as to affect the identified HDA These TERA conclusions are based on discussions with Gibbs and Hill rather than review of design control procedures, design methodology, et TERA apparently recognizes that other homogeneous design activities (HDAs) may exist and that some currently so defined may in fact not be homogeneous since it has been stated in DAP-E-C/S 001 dated October 27, 1985, " Phase 3 Scope Vali-dation, Civil / Structural" that in the review effort there will remain an open,

" ... search for substantive differences in criteria category, design considerations, approach, or methodology in the design process."

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The team identified potential HDAs not identified by TERA, such as the design of the annular structural steel normally inside the containment, the auxiliary building structural steel, foundation overturning design, the design of walls for tornado missiles and the effect of Category II buildings on Category I building Due to the above uncertainty as to documented design methodology, there is a related question on sample sizes. In the area of concrete design, TERA has indicated that for the auxiliary building and the fuel building a total of five (5) slab and five (5) wall calculations will be selected at random for design review. Then another set of ten (10) calculations will be selected either ran-domly or based on any findings from the previous ten (10). Such a sample may not be valid if all these calculations were by one individual, if there were fifteen (15) individuals doing independent designs for slabs and walls without any design process / methodology guidance beyond the FSAR criteri If there were no controls within the Gibbs and Hill organization, for establishing homogeneity in design approach and methodology, one must compare individual A-1 I

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engineers and designers completing similar tasks. For this situation, the i actual homogeneity that exists can apparently only be established as the design l review progresse*,.

To the degree that TERA relies on HDA populations as the basis.for review sample selection, the team plans to evaluate whether the review sample is I representative of the design process for that population and whether the f population is homogeneou l 1 Piping / Supports The team questioned the basis for not including a self-initiated review of the piping and pipe supports in the auxiliary feedwater (AFW) system. TERA stated

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that a portion of the AFW piping system stress analysis will be included in the i selected sample of the SWEC piping analysis to be reviewed by the third-part .

Based on the commitment by TERA to include a portion of the AFW piping and j supports in their scope of review, the team finds that the interface between '

mechanical systems and piping design, e.g., with respect to water hammer loads, i will be adequately, addressed in the third-party review of the AFW syste ,

Based on the " generic given" concept (see Section 1.3), TERA is not reviewing design work by experienced vendors who have designed hardware for plants other than CPSES. liowever, TERA is reviewing design work for " unique" vendors. These are hardware manufacturers with limited design experience in the nuclear fiel These "one-of-a-kind" manufacturers may have only supplied hardware to CPSES, :

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and therefore may not have been subject to extensive review by the nuclear industry and the NR The team questioned which (if any) unique vendors will be included in the DAP scope of review relative to the piping and pipe support area, and how these unique vendors will be identified. TERA stated that unique vendors

were evaluated as part of the Phase 3 self-initiated scope evaluation p/ocess as input to determining homogeneous design activities requiring review under the DAP. This process does not apply to the piping and support area where extensive requalification activities are taking place as a result -

of external source issues. The team concludes that the unique vendor concept evaluated as part of the Phase 3 process is not applicable to piping and pipe supports since the Phase 3 process applies to self-initiated scope and not piping and support . Electrical /I&C 1 With respect to instrumentation and control homogeneous design activities,

! (reference TERA document DAP-E-EIC-002, Rev. O, dated October 27,1985),

( the following clarifications and omissions have been noted:

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(1) HDA 1.a. for the design of control logic contains trip logic, trip logic permissives, and trip logic bypass elements. Current checklists cover some of these design aspects, and revised checklists will address the remainde (2) HDA 1.h. for protection system interface design will be revised to address protection system interface design aspects as well as control system interfaces.

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(3) HDA 3.a. for local and remote indication circuit design will be revised to address both normal operation and accident monitoring indicatio (4) The review of vendor technical data submittals by TERA will be revised to be more specific in the checklist as to which vendor documents will be reviewe (5) A review of interaction among protection and control systems will be added to the checklists, and should be identified as a unique HD (6) The review of Regulatory Guide 1.97 accident monitoring variables will be expanded to include Type D qualification category 2 vari 3bles in revised checklists, and should be identified as a unique HD (7) A review of instrument response time requirements and characteristics will be added to the revised checklists, and should be identified as a unique HD '

(8) A review'of high pressure to low pressure system interlocks will be added to the revised checklists, and should be identified as a unique HDA.

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APPENDIX 2 i

- RESOLUTION OF COMMENTS IN 8/9/85 NRC LETTER, i CIVIL / STRUCTURAL .

The following NRC comments correspond with scope related comments in the Civil /

Structural Section (3.1.B) of NRC letter dated 8/9/85. The NRC questioned whether the DAP scope would include specific design activities. The team evaluation found the TERA response acceptable if it indicated that the specific design activity was enveloped by either Phase 2 or 3 scop . NRC COMMENT: First, the basis for selection of the major concrete and steel structures to be reviewed is not provide TERA RESPONSE: No specific basis was used. The containment, the auxiliary building, and the fuel building w?re selected randomly out of the five major Category I buildings. The TERA effort will also review portions of other major Category I buildings as indicated on checklist TEAM EVALUATION: The Team believes this complement of Category I buildings provides a representative sample for review of concrete and steel structure design, based on currently available informatio . NRC COMMENT: Another concern is that the review scope for Category I structures, as proposed in the Plan, is not an adequate representation of CPSES Category I structures. A number of external source issues exist on supports which range from loading to structural attachment. Based on this, it may be appropriate to select a concrete structure that is heavily loaded by supports in concentrated areas. The shield wall or a steam generator compartment structure might be an appropriate selection since they both have a significant number of attachments. The containment liner is the largest -

steel structure in the plant and may be an appropriate selection as one of the structural engineering disciplines to be reviewed. Another item which -

may be appropriate to consider is embedded plates. The evaluation should include various load combinations. Design information developed for use in seismic qualification of CPSES equipment should also be evaluate TERA RESPONSE: As a result of the external issue on the upper steam generator lateral support, the design review has been expanded to include the concrete steam generator compartment. The containment liner will be included in the review. Embedded plates will also be included in the design review and will be part of a separate Checklist, C/S-G005, Base Plate / Anchor Bolt, which TERA has comitted to develop. A series of checklists have been developed to address all loads and load combinations defined in the FSAR. This series includes C/S-G011 through G018. A checklist has also been developed on the seismic qualification of equipment (Mechanical Checklist #26).

TEAM EVALUATION: In reviewing the checklists, the team noted there will be additional Category I structures reviewed. In Phase 3, a review of Category I outside tanks and underground structures (the asscciated piping tunnels)

will be made. However, it is limited to a review for design requirements, and does not provide review of methodology, assumptions and outpu l A-4

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In reviewing tha sample, as now defined for the structural steel design review, the team noted that the steel selected was loaded only with normal building loads and electrical systems. With respect to ircluding various load combinations, the team believes that the samples selected for evaluation of the design of structural steel should also encompass steel framing where heavy mechanical loads are supported from the steel as well as areas where combined electrical and mechanical loads are presen The team agrees with the TERA response based on the existence of the referenced checklists. However, the use of these checklists may not result in an adequate design review since the checklists represent the FSAR licensing commitments and are not prescriptive with respect to design methodology required to satisfy the commitments. In addition, the depth of the Design Adequacy Program with respect to the above concerns cannot be assessed until Phase 3 checklists are complete . NRC COMMENT: The third concern is related to the size of the sample in the areas of equipment mounting, HVAC supports, penetrations, etc. Since the overall process and control of interfaces has been raised as a concern, it would seem appropriate to increase the size of the sample in these area For example, in the area of equipment mounting, the Discipline Specific Action Plan (DSAP) calls for the review of one mechanical item and one electrical ite This sample size is not sufficiently large enough to reach reasonable assurance that equipment mounting, in general, is appropriat TERA RESPONSE: The sample size has been increased so that for equipment mounting there will be 5 mechanical mountings and 4 electrical mountings reviewed. For HVAC supports, TERA will review, (a) 20 supports which were designed on the basis of an isolated support, and (b) 20 supports which were designed on the basis of a single system analysis of a HVAC sectio TEAM EVALUATION: Based on current information, these sample sizes may be .

adequate; however, this judgement is predicated on the confirmation during

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APPENDIX 3 RESOLUTION OF COMMENTS IN 8/9/85 NRC LETTER, MECHANICAL SYSTEMS AND COMPONENTS j

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l This Appendix addresses scope related comments for Mechanical Components and i

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Systems in NRC letter dated 8/9/85. The NRC questioned whether the DAP scope would include specific design activities. The team evaluation found the TERA response acceptable if it indicated that the specific design activity was i enveloped by either Phase 2 or 3 scop Mechanical Components The comment below is in Section 3.1.D of the NRC lette NRC COMMENT: Recently, a new issue was raised pertaining to whether active valves were designed in accordance with FSAR commitment Since the Plan intends to provide complete coverage of all areas with safety significance, the Plan should include the consideration of the issue of active valves and the implications of the root cause of this issue on other component TERA RESPONSE: TUGC0 is responsible for reviewing B0P active valve and pump procurements to ensure that (1) R.G. 1.48 and pertinent FSAR commitments were invoked in valve / pump procurements and, (2) there is documented evidence that the requirements were met. This review had identified the need for corrective actions. TERA is responsible for overviewing TUGCO's program with respect to the review of procurement specifications and vendor design documentation and resultant corrective actions. TERA will develop a Phase 3 checklist to accom-plish this. Root cause implications will be addressed in accordance with Procedure DAP 2, " Documentation and Tracking of Issues and Discrepancies."

.

TEAM EVALUATION: This response a'ddresses the NRC commen Mechanical Systems

.

NRC letter dated 8/9/85, Table 1, lists design elements for a Mechanical Systems activity. The below numbered design elements from Table 1 were not addressed-in the Proaram Plan, and are addressed in this Appendix with respect to whether they will be included in the DAP. Individual design elements were not phrased as NRC comments (consistent with the NRC letter) since the NRC letter required the same response for each design element, i.e., whether it would be included in the DAP.

' Pipe Sizing TERA RESPONSE: This activity is covered in Checklist #15. The checklist did not adequately address documentation establishing system design pressure and temperature, considering all operating modes and pump shut-off head (as required by the ASME Code,Section III). It was not clear that pipe design pressure and temperature would be reviewed relative to these system design parameters. Review of documentation to establish normal, upset, emergency, and faulted conditions, as required by Section III of the ASME Code, was not indicated on checklist l A-6

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TEAM EVALUATION: TERA plans to revise Checklist #15 to address the above considerations. With these revisions, the team considers the checklist will cover pipe s1 zin , Pipe Wall Thickness -

TERA RESPONSE: No checklist addressed review to assure that calculated minimum wall thicknesses are consistent with code requirements for selected pipe / component pressure ratings. TERA plans to revise Checklist #15 to include thi TEAM EVALUATION: The team considers that this revision will provide for review of wall thickness calculation . Balanced Flow Requirement TERA RESPONSE: This design element will be reviewed as part of the checklists on System Piping Arrangement (File No. M-1) and Heat Removal Capacity (File No.,M-7).

TEAM EVALUATION: The team reviewed checklists M-1 and M-7, and found that, (1) the piping arrangement will be reviewed to evaluate whether flow can be delivered to two steam generators simultaneously, and (2) the system pressure drop and pump head will be reviewed for balanced flow. These checklists address balanced flo . Heat Removal and Rejection TERA RESPONSE: Phase 2 checklists (7 - Heat Removal Capacity; 8 - Water Supplies; and 17 - Condensate Storage Tank) address an open heat removal system, i.e., the AFW System. Phase 3 will increase scope to address heat removal by closed system, including heat exchanger design .

. TEAM EVALUATION: TERA is responsive to the NRC commen . Controlled Chemical Addition TERA RESPONSE: This has been identified as a Phase 3 scope expansion per DAP-E-M-001, Rev. The review of this design element will be covered by a checklis TEAM EVALUATION: The tum reviewed the Phase 3 scope expansion document and found two specific references for review of controlled chemical addition design activities: 33b (containment spray coverage / fission product removal)

and 41h (chemical eductors). Checklists will be developed for these activitie . Radioactive Fluid Flow TERA RESPONSE: This design element has no effect on the ability of a system to fulfill its intended safety function, and therefore is outside the score of the DA TEAM EVALUATION: The Office of Nuclear Reactor Regulation will consider TERA's response in its approval action with respect to the DAP scop A- 7

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1 Pump Sizing TERA RESPONSE: This design element is contained within checklists on Motcr Driven Pumps.1(File No. M-9) and Turbine Driven Pumps (File No. M-10).

TEAM EVALUATION: The team reviewed the above checklists and found that pump q sizing will be inspected via review of system calculations for the various I operating conditions.

1 Sump Design

_

TERA RESPONSE: Sump design is addressed in Phase 3 as a " candidate given". ,

Sump design activities not covered by the candidate given will be included j in a Phase 3 scope expansion.

TEAM EVALUATION: Screen submergence has not been included as an attribute in Phase 3, and is important for preventing debris of a specific gravity less than one from affecting screen performanc l 1 StorageTank' design TERA RESPONSE: This activity is covered in Checklist #17, Condensate Storage Tank, which indicates a review of the basis for the 276000 gallon volume restricted for safety related service. However, the checklist did not specifically indicate a review considering manual valve switchover, instrument level errors and nozzle locations to assure that the minimum required volume is available for safety related service. Pi.ase 3 will i address overpressurization and vacuum prevention pertinent to a pressure vessel, i.e., not in the AFW System.

TEAM EVALUATION: Upon incorporation of the above items, Checklist #17 will cover review of Storage Tank Desig . Vortex Prevention .

TERA RESPONSE: This design element will be reviewed as part of the checklist on Condensate Storage Tank (File No. M-17).

TEAM EVALUATION: The team reviewed the subject checklist and found it needed clarification to assure adequate review for vortex prevention. TERA plans to rewot d checklist item 4.5.4 to provide clarificatio In addition, as a Phase 3 activity, TERA is evaluating containment sump design, which is i more complex with respect to vortex prevention. The latter review is a

" candidate given" based on model testin . NPSH Limitation TERA RESPONSE: Phase 3 will address a system other than AFW in order to evaluate more complex design with respect to NPSH and pumped fluid at or near saturatio TEAM EVALUATION: This response is acceptable for evaluating the full range of NPSH design issue l

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15. Pumped Fluid at or Near Saturation TERA RESPONSE: This has been identified as a Phase 3 scope expansion (DAP-E-M-001, Rev. 0).

TEAM EVALUATION: The team inspected the Phase 3 scope expansion document and found that the design element of pumped fluid at or near saturation was included as part of the NPSH design activity (8b).

16. Open and Closed System Operation TERA RESPONSE: The hydraulic consideration of a system operating in an open and closed configuration involves maximum and minimum operating limits, changing NPSH conditions and different water supplies. Although the AFW system does not exhibit both open and closed operation, it does include the above hydraulic censiderations. See Mechanical checklists NPSH (File N M-3), Maximum / Minimum Flow (File No. M-4), Water Supplies (File No. M-8) and Component Functional Checklists (File Nos. M-9 through M-18).

TEAM EVALUATION: .The team reviewed the above checklists and found design attributes pertinent to the above hydraulic considerations. As a related matter, TERA plans to expand Checklist #3 to ensure that inlet valves supplying water from the CST and the service water system to AFW pumps cannot both be closed during pump operatio . Support Systems TERA RESPONSE: Checklist #20, " Support Systems", covers HVAC, service air, and pump bearing cooling water. Water supplies are evaluated by checklist 8, and electrical power supplies (AC & DC) are reviewed as part of DSAP X1 for AF TEAM EVALUATION: TERA is responsive to th' eNRC commen '-

19. Temperature Change During Operation

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TERA RESPONSE: This design element is covered in checklists on NPSH (File No. M-3) .and Pipe and Piping Components (File No. M-15).

TEAM EVALUATION: The team reviewed the above checklists and found that maximum and minimum operating temperature will be addressed in the M-15 checklist. The M-3 checklist will address the effect of temperature changes on NPS . Surge Tank Sizing TERA RESPONSE: This design element has not been specifically identified, and will be added to the Phase 3 scope expansion effort within the " Heat Removal and Rejection Closed System" design activit TEAM EVALUATION: This planned action is acceptabl A-9

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21. Leng Term Operation TERA RESPONSE: This design element will be covered by the electrical checklist on. Environmental Qualification (File No. E-24).

TEAM EVALUATION: The team reviewed checklist E-24 and found ths necessary attributes to ascertain the ability of a mechar.ical piece of equipment to provide long term operation.

2 Series and Parallel Thermal Loads TERA RESPONSE: This item is covered under checklist (s) to be developed in Phase 3.

TEAM EVALUATION: This response is acceptable.

3 Change in Elevation TERA RESPONSE: Elevation change pertains to specifying the head of a pump, and will be reviewed in the checklists on Heat Removal Capacity (File No.

M-7), Motor Driven Pumps (File No. M-9) and Turbine Driven Pumps (File No.

M-10). ,

TEAM EVALUATION: The team reviewed the above checklists and found the necessary attributes to satisfy this design element.

3 Required for Reactivity Control TERA RESPONSE: The boron injection system in the plant is low concentration, which does not require specialized support systems such as heat tracing, high concentration boric acid storage, or injection equipment.

Other design activities associated with this design element are covered by checklists on Condensate Storage Tank (File No. M-17), Maximum / Minimum Flow (File No. M-4) and Heat Removal Capacity (File No. M-7).

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TEAM EVALUATION: The above checklists will adequately cover the design element.

34. Requ' ired for Fission Product Removal TERA RESPONSE; This has been identified as a Phase 3 scope expansion (DAP-E-M-001, Rev. 0).

TEAM EVALUATION: There are two aspects of fission product (radioactive particulate) removal, filtration and containment spray. The Phase 3 scope expsnsion document covers both types; i.e., 33b - containment spray coverage / fission product removal and 41h - chemical eductors, and 12g -

filtration. The team considers that the scope expansion will satisfy this design elemen . Vertical Centrifugal Pumps TERA RESPONSE: TERA will review a vertical centrifugal pump in addition to the AFW horizontal pum A-10

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TEAM EV LUATION: This response is acceptabl . Positive Displacement Pumps

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TERA RESPONSE: This has been identified as a Phase 3 scope expansio (DAP-E-M-001, Rev. 0).

TEAM EVALUATION: The team agrees with the inclusion of this design element as a Phase 3 expansio . Maximum Flow Velocity Limitation TERA RESPONSE: This design element is part of the " candidate given" for sump desig TEAM EVALUATION: The team will review TERA's evaluation of the " candidate given" in future inspection . Minimum Flow Velocity Limitation r

TERA RESPONSE: One portion of this design element is the Radiation Monitoring C.hanges Corrective Action Overview. A criteria list and a checklist were used for a TUGC0 review of radiation monitoring. TERA is overviewing TUGCO's revie TEAM EVALUATION: The planned action will address this design elemen . Standby Hydraulic Requirements (charge / fill)

TERA RESPONSE: The safety systems in this plant do not require charging or fill subsystems to assure proper operation. Therefore, this design element is outside the scope of the DA TEAM EVALUATION: The Office of Nuclear Reactor Regulation will consider TERA's response in its approval of the DAP sedp .

4 Pressure / Flow Control Valve Sizing TERA RESP'NSE:

O This design element will be covered by the checklist titled

" Flow Control Valve" (File No, M-16).

TEAM EVALUATION: The team reviewed checklist M-16 and found the design element was covered.

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4 Pump Suction or Discharge Manifolding TERA RESPONSE: This design element will be covered by checklists titled

" System / Piping Arrangement" (File No. M-1) and " Pipe and Piping Components" (File No. M-15).

TEAM EVALUATION: The team reviewed the above checklists and found the design element was covere A-11

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46. 'Pu;p Protection Requirements TERA RESPONSE: The design element for centrifugal pumps is covered by checklists titled " Motor Driven Pumps" (File No. M-9) and " Turbine Driven Pump"(FileNo.M-10). For positive displacement pumps, this design element has been identified as a Phase 3 scope expansion item (DAP-E-M-001, Rev. 0).

TEAM EVALUATION: The team reviewed the above checklists and found that for centrifugal pumps the design element is covered. Pump protection for positive displacement pumps remains to be addressed by Phase . Parallel Pump Operation TERA RESPONSE: This design element is not included in the scope of the Design Adequacy Program because the safety related systems are designed for single pump operatio TEAM EVALUATION: The Office of Nuclear Reactor Regulation will consider TERA's response in its approval of the DAP scop . Valve Arranghment and Qualification for Containment Isolation TERA RESPONSE: This design element has been identified as a Phase 3 scope expansion. (DAP-E-M-001).

TEAM EVALUATION: The team reviewed the Phase 3 scope validation and verified the commitment to review the design element (22-Containment Isolation). Mechanical checklist No. 26 and Electrical checklist No. 24 will address seismic and environmental qualification, respectively for containment isolation valves.

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APPENDIX 4 RESOLUTION OF COMMENTS IN 8/9/85 NRC LETTER,

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TABLE 2, I&C MATRIX

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NRC letter dated 8/9/85, Table 2 lists design elements for an I&C activity. The below numbered design elements from Table 2 were not addressed in the Program Plan, and are addressed in this Appendix with respect to whether they will be included in the DA Individual design elements were not phrased as NRC comments (con-sistent with the NRC letter) since the NRC letter required the same response for each design element; i.e., whether it would be included in the DAP. The team evaluation found the TERA response acceptable if it indicated that the specific design activity was enveloped by either Phase 2 or 3 scop . Degree of Redundancy Used TERA RESPONSE: As a Phase 3 scope expansion, a failure mode and effects analysis (FMEA) of the auxiliary feedwater system, as well as a sample of the Texas Utilities (TNE) design modification work, will be accomplished. An examination of AFW trip bypasses, RG 1.47 bypass indications, and diesel-generator fuel oil tank logic will also be included in the Phase 3 expansion. Implementation details are provided in the AFW control and diesel-generator support system checklists, and will be provided in two other checklists still under developmen TEAM EVALUATION: The proposed TERA Phase 3 expansion to examine the implementation of system redundancy requirements by means of a failure mode and effects analysis of two plant systems and a sample of field design modification work is responsive to the NRC commen . Instrument Channel Separation Group Assignments ,

.

TERA RESPONSE: In the Phase 3 expansion, separation group assignments will be traced to the battery or inverter sources, and will include a review of separation for the AFW system and diesel-generator instrumentation and control systems. ,

Separation criteria will also be compared with its implementation in the electrical construction specification and construction detail drawings. Implementation details will be provided in the E-9 single failure checklist still under developmen .

TEAM EVALUATION: The proposed TERA plan to review separation criteria implementation in the AFW and diesel-generator instrumentation and control systems as well as in a number of construction documents is acceptable to the team.

I Permissive Control Logic Used TERA RESPONSE: In the Phase 3 expansion, a review of automatic bypasses will be added to augment the Rev. 2 plan for review of AFW pump transfer from automatic pressure control to manual flow control, the enable signal for pump level control, and the AFW pump low suction pressure measuremen Rev. 2 implementation details are provided in the AFW control checklis TEAM EVALUATION: The proposed review of AFW system permissive control logic is acceptable to the tea A-13

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, . Bypass Control Logic Used TERA RESPONSE: The Rev. 2 AFW control checklist provides fnr a review of I trip bypasses. Diesel-generator overspeed and generator differential automatic bypasses will be geviewed. As a Phase 3 expansion, the AFW motor pump low lubrication oil pressure bypass will be reviewed. Implementation :

details are provided in the AFW control and diesel-generator control and instrumentation checklist TEAM EVALUATION: The TERA plan for review of trip bypass control logic is acceptable to the tea . Interlocks with other Systems or Equipment TERA RESPONSE: Phase 3 will address the interlock between main feedwater and auxiliary feedwater systems as well as interlocks between the ESF ventilation system and the safety chilled water and component cooling water systems. Implementation details will be provided in the AFW control and AFW support systems checklists.

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TEAM EVALUATION: The proposed TERA review of interlocks among various CPSES systems is acceptable to the tea . Protective Action Setpoints Used (RG 1.105)

TERA RESPONSE: The Rev. 2 plan for review of two setpoint calculations will be expanded in Phase 3 to encompass 12 individual calculations. The list of setpoint calculations to be reviewed is:

AFW motor pump low discharge pressure AFW motor pump recirculation flow, FT-2456A AFW turbine low suction pr. essure Condensate storage tank low-low level, LT-2479A Diesel fuel oil day tank level high-high and low-low Station service water A supply header pressure low .

Component cooling water header 02 pressure low Containment elev. 864 ft. 6 in. temperature high Component cooling water heat exchanger flow to CCW coolers Instrument air after filter discharge pressure

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Vent chiller CCW supply control valve Control room differential pressure low Implementation details will be provided in the instrument setpoint checklis .

TEAM EVALUATION: The proposed TERA plan to review 12 setpoint calculations in a number of CPSES systems is acceptable to the tea . Actuation of Pumps, Valves, Et TERA RESPONSE: In the Rev. 2 plan, existing checklists provide for a review of AFW pump and valve actuation requirements, the diesel fuel oil transfer pump start at 2/3 of the day tank capacity, and ESF vent fan initiation on a diesel-generator start signal. Implementation details are provided in the AFW control and diesel-generator support system checklist A-14

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TEAM EVALUATION: The Rev. 2 TERA plan for review of pump and valve actuation control circuits is acceptable to the tea . Capability for Periodic Test and Calibration (RG 1.22)

TERA RESPONSE: Phase 3 identified reviews of AFW system instruments relative to the periodic test capability requirements of IEEE Std. 338 and the loss of offsite power sensors for test capability. Implementation details will be provided in the AFW control, AFW instrumentation, and diesel-generator control and instrumentation checklist TEAM EVALUATION: The proposed TERA plan to review the AFW system and diesel-generator LOOP signal circuits for periodic test capability is acceptable to the tea . Separation and Isolation Requirements (RG 1.75)

TERA RESPONSE: As a Phase 3 expansion, the use of optical isolators in the AFW system will be reviewed. Implementation details will be provided in a new component funi:tional requirements checklis TEAM EVALUATION: The proposed TERA plan to review optical isolators used between Class 1E and non-Class 1E circuits in the AFW system is acceptable to the tea . Potential for Control System Interaction (IEEE 279)

TERA RESPONSE: As a Phase 3 expansion, a review of available Gibbs & Hill analyses of load shedding of r.on-Class 1E loads from Class 1E busses will be performe Implementation details will be provided in the diesel-generator control and instrumentation checklist ,-

TEAM EVALUATION: On the assumption that Gibbs and Hill analyses exist, the proposed TERA * plan to review the impact on plant safety systems of automatic shedding of control system loads from Class 1E busses is acceptable to the .

team. In the event that such analyses are not available, TERA should perform a review of a sample of control system loads to determine the impact on plant safety system . Manual Initiation at the System Level (RG 1.62)

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TERA RESPONSE: The Rev. 2 plan provides for a review of AFW manual initiation at the system level and manual start of the diesel-generator Implementation details are provided in the AFW control and diesel-generator control and instrumentation checklist TEAM EVALUATION: The TERA Rev. 2 plan for review of manual initiation at the system level for the AFW and diesel-generator systems is acceptable to the tea . System level Bypass / Inoperative Indication (RG 1.47)

TERA RESPONSE: As part of the Rev. 2 plan, a review is provided for the l potential expansion of a trip bypass as well as trip bypass or inoperative indications. A review of the Class 1E diesel-generator out-of-service ;

i A-15

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indication is also provided. Implementation details are provided'in the AFW control, AFW instrumentation, and diesel-generator control and instrumentation checklist TEAM EVALUATION: The TERA plan to review bypass or inoperative. system level indications in the AFW and diesel-generator systems is acceptable to the tea . Accident Monitoring Instrumentation (RG 1.97)

As part of the Rev. 2 plan, RG 1.97, type A, category 1 variables are reviewed in the AFW instrumentation checklist. As a Phase 3 expansion, a review of the type D category 2 measurement of air supplies for the turbine driven AFW loop will be added. In Rev. 2, a review of Type D, category 2 bus voltage monitors is included in the diesel-generator control and instrumentation checklist, and Type D category 2 bus current monitors will be added as a Phase 3 expansio TEAM EVALUATION: The TERA plan for review of type A and type D accident monitoring instrumdntation variables is acceptable to the tea . Instrument Response Time Test Capability (RG 1.118)

TERA RESPONSE: In the Rev. 2 plan, the response time requirements of the loss of off-site power sensors used to initiate operation of the diesel-generators will be reviewed. As a Phase 3 expansion, response time requirements for the component cooling water header low pressure interlock will be added. Implementation details are provided in the diesel-generator control and instrumentation checklist and will be added to the AFW support systems checklis TEAM EVALUATION: The TERA plan to review LOOP and CCW h,eader pressure interlock circuits for response time requirements is acceptable to the tea . Instrument Environmental and Seismic Qualification .

The Rev. 2 plan for review of five components will be expanded. A review will be performed of 12 types of instrumentation and control components for environmental qualification and at least 10 types of instrumentation and control components for seismic qualification. The specific components to be i

reviewed have not yet been determined. Implementation details will be

> provided in the multi-discipline consideration environmental qualification and multi-discipline consideration seismic qualification checklist TEAM EVALUATION: The team agrees with the prop'osed instrumentation and control plan to review 12 component types for environmental and at least 10

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component types for seismic qualificatio . Instrument Procurement Specification Requirements t

TERA RESPONSE: The functional requirements and technical characteristics l

l stated in procurement specifications will be assessed. Instrument specifications will also be examined for those instruments involved in the review of current system requirements against instrument pressure and temperature ratings. As a Phase 3 expansion, procurement specifications l

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will be reviewed in the AFW, safety-chilled water, and station service water systems for functional requirements, ter.hnical ratings, safety class designations, hydrostatic test requirements, and seismic Category I mounting requirements'. At this time, the specific instrumentation procurement specifications to be reviewed have not been determined. Implementation details are provided in the functional requirements, AFW instrumentation, and fluid system instrument rating checklists, and will be provided in the AFW support systems checklis TEAM EVALUATION: The proposed TERA plan for review of instrument procurement specifications for a wide range of technical requirements is acceptable to the tea . Instrument Rack Arrangements TERA RESPONSE: As a Phase 3 expansion, instrument rack arrangement drawings for the AFW system will be reviewed for location and separation of individual instruments. Implementation details will be provided in the E-9 single failure checklis TEAM EVALUATION: The TERA plan for review of instrument rack arrangement drawings is acceptable to the tea . Instrument Tubing Routing TERA RESPONSE: As a Phase 3 expansion, the single failure checklist will be modified to include a review of instrument tubing separation based on CPSES design criteria or project commitments. Implementation details will be provided in the E-9 single failure checklis TEAM EVALUATION: On the assumption that CPSES criteria or project commitments relative to instrument tubing separation exist, the teain agrees *

with the proposed TERA pla In the event that such criteria or commitments do not exist, TERA should review a sample of instrument tubing routing to assure that no single postulated event, such as HELB or missiles, can cause .

degradation of safety-related instrument sensing lines below an acceptable leve '

2 Instrument Cabling Connections TERA RESPONSE: As a Phase 3 expansion, AFW instrumentation and control connection details will be reviewed on schematic and connection diagrams to assure their technical accurac Implementation details will be provided on the AFW control and AFW instrumentation checklist TEAM EVALUATION: The TERA plan to review instrumentation and control cabling connection details for the AFW system is acceptable to the tea . Vendor Technical Dota Results TERA RESPONSE: In the Rev. 2 plan and Phase 3 expansion, the procurement specifications and vendor reports used for the seismic and environmental qualification review will be assessed for component functional requirement Implementation details will be provided on the component functional A-17

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r:qufrements, multi-discipline censideration cnvironmental qualification, and multi-disciplina consideration seismic qualification ch:cklist I TEAM EVALUATION: TERA's plan for review of vendor technical data pertinent !

to seismic and environmental qualification provides a representative sample

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for this design elemen . Instrument Identification Means. '

TERA RESPONSE: In Rev. 2 and the Phase 3 expansion, the means used for instrument identification will be reviewed. Implementation details will be provided in the component functional requirements and single failure checklist TEAM EVALUATION: TERA plans to review instrument identification method In a future inspection, the team will review the pertinent Phase 3 checklist . Loss of Bus Voltage Sensors TERA RESPONSE: The loss of bus voltage sensors will be reviewed as part of the diesel-generator control and instrumentation review, and will be included in the single failure review as a Phase 3 expansio Implementation details are provided in the diesel-generator control and instrumentation checklist, and will be provided in the E-9 single failure checklis TEAM EVALUATION: TERA plans to review loss of bus voltage sensors are reflected in the diesel-generator control and instrumentation checklist. In a future inspection, the team will r view the Phase 3 checklist (E-9 single failure).

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APPENDIX 5 RESOLUTION OF COMMENTS IN 8/9/85 NRC LETTER,

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TABLE 3, ELECTRIC POWER MATRIX

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NRC letter dated 8/9/85, Table 3 lists design elements for Electric Powe .

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The below numbered design elements from Table 3 were not addressed in the Program Plan, and are addressed in this Appendix with respect to whether they will be included in the DAP. The table below indicates that all such design elements will be covered in the DA In each case, coverage will be either by an existing (Rev. 2) review checklist or a Phase 3 checklist, to be developed. Therefore, an overall team evaluation concludes that all design elements identified in NRC letter dated 8/9/85, Table 3 will be covere Specific comments on the degree of coverage and the review checklists are addressed in Appendices 6, 10, and 1 Design Elements Response from TERA

Rev. 2 Phase 3 Item No. Description Checklist Checklist

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A Calculations / Analysis A. Voltage Dips on DG Loading 1 A. Motor Control Centers - short circuit 2 A. DG Switchgear-short circuit 2 A. Short Circuit - cable sizing 4 A. V Loss of Voltage-Undervolt Pro (I&C)

A. V DC Over/Undervoltage-Undervolt Protection 3 (I&C)

A.5. .9kv Switchgear Bus and Breaker Sizing 11,14

) A.5. Unit Substation Transformer Sizing 5 ,

A.5. V Switchgear Bus and Breaker 2,5 .

Sizing A.5. Motor Control Center Loading 16 A. .6.9kv Tie Breaker-Protection / Relaying x A. DG Output Breaker-Protection / Relaying x A. .9 kv Motor Feeder Breaker-Protection / Relaying x A. Unit Substation Transformer Primary BKR x A. V Bus Incoming Breaker Protection / Relaying x A. V Bus Motor Feeder Breaker Protection / Relaying x A. V MCC Feeder Breaker Protection /

Relaying x NOTE: Number in column refers to number on TERA checklist summary (Table 1.)

All checklists are from electrical discipline, unless otherwise note A- 19

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Design Elements Rnsponse from TERA Rev. 2 Phase 3  ;

Item N Description Checklist Checklist Remark

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A. MCC Motor Feeder Circuit Protection / Relaying x ,

A.6.10 MCC MOV Thermal Overload Protection x A. .9 kv Penetration Assembly 13 '

A. v Power (1rg) Penetration Ass x A. v Power (sm) Penetration Ass x A. v Switchgear Coordination Studies x A. v MCC Coordination Studies x A. VDC Switchgear Coordination Studies x Inverter Power Distribution

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A. Coordination Studies x Reactor Coolant Pump Under- '

Frequency Protection x

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I EhUIPMENTSPECIFICATION B. .9 kv Bus 11 B. v Unit Substation x B. v Switchboard x B. kv Power Cable 3,4,15 B. v Power Cable 3,4 B. Control Cable 3,4 B. Instrument Cable x B. Valve Motor Operators x

- . Was in Ph. 2 scope B. Low Voltage Penetrations x .

B. Diesel Load Sequencer 8 B Isolation Cabinets x B. . Heat Tracing System x B. Environmental Seal Assemblies x

- B. Fire Seals and Barriers x B. Med. Voltage Terminations and Splices x B. Wire Terminals and x Splice Was in Ph. 2 scope as external source issue C DRAWING DEVELOPMENT C. v Bus - One Line 5,9 C.2. .9 kV Incoming Breaker-Ele ,9 C.2. .9 kV Tie Breaker - Ele ,9 C.2. v Motor feeder Breaker- 2,6(I&C)

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Design ' Elements Response from TERA

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Rev. 2 Phase 3 Itea N Description Checklist Checklist Remark

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C.2. v Non-1E MCC 8 (I&C)

Feeder Breaker-Ele C.2. v MCC Pump Motor Feeder- 8 (I&C)

Ele C. Control Wiring Diagrams 1 (I&C)

C. Cable Block Diagrams 3 C. Internal Wiring Diagrams 8,11,16,22 C.4. General Arrangement Drawings 9,20,21,

C.4. Equipment Foundation Drawings x C.4. Cable Tray Plans & Sections 22 Materials C.4. Exposed Conduit Drawings 22 review C.4. Embedded Conduit Drawings 22 in Ph. 3 D. Class 1E 4 quip. List-Design Implementation 24 D. Remote Safe Shutdown Equi Was in List-Design Implementation x Ph. 2 scope

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E INSTALLATION DOCUMENTS Installation Contract x Installation Notes and Details x Project Separation Guide x VENDOR DOCUMENT REVIEW F. Outlining Mounting Details Found in ,

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F. Wiring Diagwams multiple F. Bills of Materials Checklists Installation, Operation &

Maintenance Manuals 24 , INTERFACE G. . Utility 1,2 G. NSSS 8,13 x G. NRC (IE Bulletin & Info Documents Notices) pertinent G. Industry (INP0 - etc) to DAP are reviewe G. Mechanical Power 10 G. Site Engineering x G. Start Up x G.2.10 Site Construction x NOTE: Number in column refers to number on TERA checklist summary (Table 1). All checklists are from Electrical Discipline, unless otherwise note A-21

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4 APPENDIX 6

- RESOLUTION OF COMMENTS IN 9/30/85 NRC LETTER,

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1 DESIGN ADEQUACY PROGRAM PLAN (APPENDIX A)

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l TERA responses to NRC scope-related comments (as numbered below)'to Appendix i A of.the Program Plan, which covers the DAP, are provided below. The NRC

questioned whether the DAP scope would include specific design activitie !

The team evaluation found the TERA response acceptable if it indicated that the specific design activity was enveloped by either Phase 2 or 3 scop ,

! NRC COMMENT: Attachment 4, page 23, does not indicate design output i review for (1) system alignment /switchover, (2) flow requirements and, (3)

stored volum Provide justification for this omissio TERA RESPONSE: Items (2) and (3) above are to be reviewed as part of

! mechanical checklists on Heat Removal Capacity (File No. M-7) and Water i M-8 respectively. Item (1) will be reviewed as part of Supplies (File the System / Piping No.Arran)gement mechanical checklist (File No. M-1). ,

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i TEAM EVALUATION: The team reviewed the checklists involved and found that i the review items were adequately covered.

! NRC COMMENT: Attachment 4, page 23, indicates a review area on heat removal capability. However, since AFW does not include heat exchangers, design adequacy on heat removal capability can not be judged by review of

.l the water makeup supply to steam generators. Identify other provisions made for addressing this review are i TERA RESPONSE: The AFW system is an open heat removal system, the heat L removal attributes of which will be reviewed as' part of the Heat Removal l Capability Checklist (File No. M-7). The heat removal aspects of the closed

! system (heat exchangers) will be covered by reviewing another system, as identified in the Phase 3 scope validation (DAP-E-M-001). The system has -

yet to be chose ,

! TEAM EVALUATION: The team reviewed mechanical checklist File No. M-7 and l found it adequately covered an open system. The closed system selection and i related checklist development are open item ,

, NRC COMMENT: Attachment 4, page 24, does not indicate design output review for (1) single failure /FMEA, (2) class 5 piping, (3) High Energy Line Break (4) HVAC and (5) Cooling Water. Additionally, station air is not included in the review area of Support Systems. Provide justification for these omissions.

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! TERA RESPONSE: Separate Mechanical checklists have been developed for items (1), (2), (3), and (5); see checklists M-19, -21, -22 and -20. HVAC will be l

reviewed as part of a separate mechanical checklist to be developed. The l

HVAC commitment is identified in Phase 3 Scope Validation, DAP-E-M-001. The

! station air system is not included in the program plan because it is not a

! safety-related system. A safety-related air supply for post-accident l required valve operation is being reviewed as part of the mechanical I checklist on Air Accumulators (File No. M-11).

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TEAM EVALUATION: Tha team reviewed the above checklists and found that they l

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adequately covered the dasign activities. The development of the HVAC checklist is an open ite i

~ NRC COMMENT: Attachment 4, page 25, does not include transformer l characteristics revie Provide justification for this omissio i TERA RESPONSE: For the 6.9 kv and 480 volt transforners, transformer characteristics such as loading and impedances are included on TERA checklists for diesel load characteristics, and voltage and short circuit studies. Transformer characteristics of the distribution transformers will be addressed in the Phase 3 scop TEAM EVALUATION: TERA's response is acceptabl . NRC COMMENT: Attachment 4, page 26, does not indicate design output review for (1) Diesel Generator (DG) Fuel Oil Transfer, and (2) DG Cooling Water. Provide justification for this omissio TERA RESPONSE: These design activities are enveloped by design activities 2, 4, 5, 6, 7, 8, 9,10,11, 21, 36, and 41 in DAP-E-M-001, Table 1, Mechanical Matri TEAM EVALUATION: TERA's response addresses the NRC commen ,

1 NRC COMMENT: Attachment 4, page 26, does not indicate the review scope for Status Indication, as shown in Appendix C Section XI, page 25. Resolve this inconsistenc TERA RESPONSE: During rev. 2 activities, status indications will be reviewed from design input through design output documents for AFW control, AFW instrumentation, and diesel-generator instrumentation and control *

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review *

TEAM EVALUATION: This response is acceptabl .

11. NRC COMMENT: Attachment 4, page 27, does not indicate the review scope for High.and Moderate Energy Line Break, as shown in Appendix C,Section XI, page 26. Resolve this inconsistenc TERA RESPONSE: The mechanical review envelopes electrical /I&C l consideration's and is addressed in checklists 22, "HELB" and 23, " Flooding -

Internal."

TEAM EVALUATION: Based on discussions with TERA, the team understands that Moderate Energy Line Break considerations will be based on FSAR comitments

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to design the plant to meet the criteria in BTP ASB 3- This response is acceptable based on this understandin . NRC COMMENT: Attachment 4, page 28, does not include cable sizing in the Electrical Characteristics review area. The Control area does not l

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include design output review for the Control Proces Provide justification for these omission TERA RESPONSE: Cable sizing has been covered by checklist no. 4 " Electrical Characteristics - Cable Sizing," for 8 kV power, 600v power and control cables. The review will be on the basis of standards / codes committed to by the FSAR. See TERA response on the control process for question-23 (11)

pertinent to Action Plan XI. (Appendix 10 of this report.)

TEAM EVALUATION: TERA's response is acceptabl . NRC COMMENT: Attachment 4, page 29, indicates that the electrical and instrumentation support systems for the AFW are those identified for the i Power Supplies, Instrumentation and Controls System and Components Initial Review Matrix. This reference could be in error, since support systems for AFW are not those of the power supplies and their instrumentation and controls. Resolve this inconsistency.

! TERA RESPONSE: Tpg.matrixincludedintheDAPProgramPlanwasinerro The Phase 2 system validation electrical matrix indicates that the review task of " support systems" addresses only the diesel generato TEAMEVALUAi10N: TERA's response is acceptabl .a NRC COMMENT: Attachment 4 multi-discipline considerations, does not include interfaces between Civil / Structural, Mechanical, Piping, Supports, and Electrical disciplines. Justify this omissio TERA RESPONSE: Multi-discipline interfaces are covered in the individual checklists. The team reviewed electrical checklist #10 for the AFW pump motpr. This checklist references the environmental and structural l

interfaces for the motor in addition to the pump / motor interface. A Phase 3 i program will verify acceptability of environmental and seismic data. The team also reviewed mechanical checklists for flooding and HELB and found that they had appropriate multi-discipline interface .

i TEAM EVALUATION: TERA's response is acceptable.

I j 20 NRC COMMENT: Multi-discipline considerations are limited to HELB and i Seismic Qualification. Provide justification for excluding consideration of other multi-discipline items such as Category I tanks and concrete component

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supports.

l TERA RESPONSE: There was apparently some confusion over terminology in the program plan. As used in the program plan, " Multi-discipline" is a term associated with reviews of some special areas (e.g., HELB, flooding, fire protection, environmental / seismic qualification, etc.), which are performed by groups of individuals representing several technical disciplines. In addition to such reviews, there will be interfacing between disciplines I during the normal design process for items like a Category I tank and ( concrete component supports. TERA will address these interfaces such as in i questioning the technical basis for design input provided by one discipline to anothe TEAM EVALUATION: The team understands that multi-discipline interfaces will be addressed both in the above special areas and in normal design work, such as Category 1 tanks and concrete component supports, when appropriat A 24

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20.c NRC COMMENT: D: sign output review is not indicated for a nun.ber of activities for which it should be a requirement (e.g., support system, seismic qualification, etc.). Justify this omissio TERARESPONSk: Design output documents are generally documents used to purchase equipment or perform construction. Seismic qualification documents are not output documents per se. Howeyer, the review of this area involves review of both implementing and output documents (e.g. vendor reports) to assure equipment qualificatio TEAM EVALUATION: This response is acceptabl . u-

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APPENDIX 7

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RESOLUTION OF COMMENTS IN 9/30/85 NRC LETTER, DSAP VIII CIVIL / STRUCTURAL .

TERA responses to NRC scope related comments (as numbered below)'to DSAP VIII of the Program Plan are provided below. The NRC questioned whether the DAP scope would include specific design activities. The team evaluation found the TERA response acceptable if it indicated that the specific design activity was enveloped by either Phase 2 or 3 scop . NRC COMMENT: HVAC and other support designs which have been selected will only be reviewed for modeling assumptions, analysis procedure, design method-ology and interface between vendors and design organization. This portion of the civil / structural design review scope should also address the design process, including all issues raised in the cable tray / conduit support areas; e.g., choice of anchorage, design changes. Appropriately broaden the scope or provide justi-fication for the preposed scop TERA RESPONSE: Some of the Cygna cable tray / conduit support comments have been incorporated in checklists. HVAC supports were selected because of the similarity of the support types to those of cable trays, where problems have been identifie A checklist has been added on anchor bolts and base plates to broaden the scop Root cause and generic implications evaluations pertinent to identified defi-ciencies and deviations for support designs (including HVAC, other non-ASME, cable tray and conduit) may warrant evaluation of the design proces TEAM EVALUATION: Based on review of checklists, the team verified that the following Cygna issues relative to supports have been addressed: 3.H, 4.A, 5, 6.A. 7.A, 7.B. 10.A, 10.B, 10.C, 10.E 12.B. 14.A,21.C.2, 24.A, 2 .D.'1, and 24. These are contained in* Checklist C/S -S121 dated 10/28/85 -

titled, "HVAC Supports." The team identified additional items to be considered on this checklist (see Appendix 12). TERA plans to include these items as well as develop checklist C/S-G005, which will address the design adequacy of base plates / anchor bolts as well as embedments. In a future inspection, the team will review this checklist. Design process issues specific to the above technical areas will be identified by the associated checklists. The root cause and generic implications evaluations are appropriate for addressing design process issues which apply to other areas and discipline . NRC COMMENT: One area of concern not apparent in the scope of this DSAP is embedment Since many pipe, conduit, and cable tray supports are currently being reanalyzed within the current scope of the plan, the loading on the embedments, including items such as Richmond inserts, and the loading on the structure as a ;

whole must be reevaluated. Include embedmen'ts and load tracking in the scope of i the DSAP or justify its omissio TERA RESPONSE: The review scope initially included the prelocated major embedments, such as the upper lateral supports for the steam generator. Phase 3 will utilize I a larger sample of the major embedment Richmond inserts are being reviewed generically as part of the piping revie Additionally, a separate checklist will be developed C/S - G005, Base Plate / Anchor Bolt, which will address embedments also. Upon reanalysis of supported systems, the new loads will be coordinated with the civil-structural discipline, and load tracking for the structural element and the structure as a unit will be complete t A-26 l

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TEAM EVALUATION: Since the sample size or specific samples of additional embedments to be reviewed have not been identified at this time, the team will review these aspects during inspection of program implementatio In other respects, TERA's response addresses the NRC concer . NRC COMMENT: .The Containment Building consists of a concrete structure with an integrally attached liner plat Review of the containment design should also include the liner and anchorage, or the omission of these attributes justifie TERA RESPONSE: This issue will be addressed in Phase 3, but the number of review items to be included has not been determined at this time. Phase 2 includes 4 penetrations and the equipment hatch, and the resulting effects on the liner. The containment spray system and its supports are being reviewed and this will include effects of the supports on the liner. The Phase 3 work will also include a review of selected areas of the liner where attachments create additional liner loads, as well as the review of the liner anchorage syste TEAM EVALUATION: 'iheteamnotedalsothatportionsofthelinerandits anchorage design are addressed in the checklist for Containment Design (C/S - S101,- dated 10/28/85) under Attributes 1.2.2, 1.2.3, 1.2.6 and Phase 2 checklist attributes and Phase 3 plans are responsive to the NRC commen .

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APPENDIX 8 RESOLUTION OF COMMENTS IN 9/30/85 NRC LETTER,

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DSAP IX PIPING AND SUPPORTS

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TERA responses to NRC scope related comments (as numbered below).to DSAP IX of the Program Plan are provided below. Note that the NRC comments have been reworded (from the wording in the NRC letter) to focus upon TERA rather than SWEC action ; NRC COMMENT: Provide a discussion regarding the extent to which root cause and generic implication evaluations will be performed for the ASME Class 2 and 3

- piping and Class 1, 2, and 3 pipe support reanalysis. Specifically address how deviations will be identified by SWEC for the large bore piping and pipe support design. Address how root cause and generic implication evaluations will be assessed relative to the impact on (1) the final piping and support design, (2) those support designs which will be modified, and (3) other design discipline TERA RESPONSE: Root cause and generic implication evaluations will be perfonned by the third-party 3For the following items:

(a) External source issues identified from the review of the public '

record. This will include new external source issues identified during the implementation of the CPRT program pla (b) Internally identified discrepancies found by the third-party in their review of project documentation interfacing with the SWEC requalification effor (c) Internally identified discrepancies found by the third-party in their review of the SWEC requalification effor .

(d) Discrepancies identified and reported by SWED resulting from their review of existing work that is not already enveloped by previously identified issue .

Root cause and generic implication evaluations for identified discrepancies in (a), (b), and (d) above are performed only for the purpose of determining potential effects on other disciplines. Given the significant number of external source issues that currently exist, there is already a significant amount of information that will flow into the generic implication evaluation process. The third-party review process will not ignore additional items discovered in (b) and (d), but it is not expected to alter the conclusions reached by reviewing the generic implication of current external source issues with respect to potential impact on other discipline Root cause and generic implication evaluations for identified discrepancies in (c) are performed for the purpose of ensuring that the SWEC requalification efforts will result in piping and support designs that are qualified in accordance with CPSES licensing commitments and applicable codes.

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TEAM EVALUATION: The team concurs with TERA with respect to the general concept for performing a root cause and 9tneric implication evaluatio However, the team does not find a process for identifying discrepancies or deviations which are resolved by hardware modifications. The team concludes a root cause' and generic implication evaluation should be performed for all hardware modifications. The team recognizes that some hardware-modifications may not be attributed to discrepancies or deviations, but rather to reasons related to expedienc . NRC COMMENT: Provide a discussion of the methods and process to be used for identifying any technical concerns related to piping and pipe support designs which have not yet been identified in external source issues, including the role of the third-party in their identification and resolutio TERA RESPONSE: Third-party identification of technical concerns that have not yet been identified would occur as a result of the following program process: Continued. review of external source documents. This review will continue'for the duration of the program for any documents issued in the public recor Internal review of project criteria and documents that interface with the SWEC requalification effor Internal review of the SWEC requalification implementation effor Examples in this category would include walkdown discrepancies identified by SWEC or third-party identified discrepancies discovered by review of SWEC's wor Review of the resolution of currently identified issues which may lead to third-party identification of related concerns that were previously not considere The third-party role in the resolution of newly identified concerns is to ,

document the issues, track them, identify them to SWEC, review SWEC's proposed resolution, review SWEC's implementation, and ensure that they are resolve TEAM EVALUATION: The discussion provided by TERA adequately addresses the team's question regarding the process to be used to identify yet unidentified issue . NRC COMMENT: Discuss what actions will be taken to address the effects of those external issues related to pipe support design upon the validity of the existing ASME Class 1 piping analysis performed by Westinghouse (excluding the reactor coolant loop).

TERA RESPONSE: Our understanding of SWEC's scope relative to ASME Class 1 auxiliary branch lines connected to the reactor coolant loop is as follows: Requalification of all supports on these lines to ensure that the supports are qualified for the load Review the support designs with respect to the effects of external issues and the Westinghouse analyses to ensure that all support-related effects were accurately considered in the analysi A-29 l

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. . Modify support designs to achieve consistency with the assumptions and repres:ntation of the Westinghouse analysi The third-party will select one or more of these lines to review SWEC's implementation of these responsibilitie .

TEAM EVALUATION: The team concurs that the actions to be taken by SWEC and TERA will adequately address the validity of the existing ASME Class 1 piping analysis with respect to the support effects on the analysi . NRC COMMENT: Provide a discussion of the basis to be used for the acceptance of portions of the Code editions later than that listed in the FSAR as provided in the piping and pipe support design specification TERA RESPONSE: The third-party will review project /SWEC documentation for compliance to ASME Code Section III paragraph NA-1140 for the code edition of record. NA-1140 permits use of specific provisions within a later edition or addenda, provided that all related requirements are met. This applies to portions of later code editions used by the project to date and any future requesteB changes resulting from the SWEC requalification effor TEAM EVALUATION: Based on TERA's commitment to review the applicable documents for compliance with NA-1140, the team finds the concern with the authority for the use of later Code paragraphs and newly approved Code Cases is resolve .

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APPENDIX 9 RESOLUTION OF COMMENTS IN 9/30/85 NRC LETTER,

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DSAP X MECHANICAL SYSTEMS AND COMPONENTS

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TERA responses to NRC scope related comments (as numbered below) to DSAP X of the Program Plan are provided below. The NRC questioned whether the DAP scope l would include specific design activities. The team evaluation found the TERA i response acceptable if it indicated that the specific design activity was j enveloped by either Phase 2 or 3 scop l NRC COMMENT: From the discussion of Section 4.1.5.2.1, it is unclear !

whether the rated flow or runout calculations will be used for determining !

NPSH in order to verify that NPSHa is greater than NPSHr. The calculations listed in Table X-2 do not include runout conditions. Provide clarification for this area of revie TERA RESPONSE: The.NPSH checklist (File No. M-3) performs a review of the Gibbs and Hill NPSHa calculation to verify that worst case NPSHa has been analyzed. The worst case NPSHr, which is a component related parameter, is to be reviewed in the Motor Driven AFW Pump checklist (File No. M-9) and also in the Turbine Driven AFW Pump checklist (File No. M-10). Runout conditions are enveloping for both NPSHa and NPSHr calculations, and will be addressed in the checklists. The comparison of NPSHr to NPSHa will be made as part of the component functional requirement checklists (File No.s M-9 andM-10).

TEAM EVALUATION: The team reviewed the subject checklists and found that the comparison of the worst case NPSHa to the component NPSHr was not specifically described. TERA plans to cover this activity in the component

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checklist . NRC COMMENT: Table X-4 does not appear to include review of the breakdown orifices located in the motor driven pumps' minimum flow line .

Provide justification for this omissio TERA RESPONSE: The breakdown orifices are a component vendor supplied item and not an A/E design responsibility. They will be reviewed as an interface i requirement in the Motor Driven AFW Pump checklist and Turbine Driven AFW l Pump checklist (File No.'s M-9 and M-10). This review will verify that the pump specification correctly states the minimum flow requirement and that the vendor supplied data has properly interpreted this functional requirement. Table X-4 did not specifically list the breakdown orifices because they are an appurtenance to the pumps which were liste TEAM EVALUATION: The team reviewed the above checklists and found that the interface between the vendor and the A/E design responsibility will be reviewed to assure that the required minimum flow for pump protection exist . NRC COMMENT: From the discussion of Section 4.1.5.5, it is unclear whether the review will verify that the equipment functional requirements are accurately represented in the equipment purchase specification. Clarify l this aspect of the revie A-31

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TERA RESPONSE: The Component Functional Requirement checklists (File Nos.

M-9 through M-18) determine whether the functional requirements are accurately and completely represented in the equipment specification and whether the vendor supplied data is complete.

TEAM EVALUATION: The team reviewed the checklists and found these key review steps to be represented in the checklists. NRC COMMENT: Section 4.1.5.8 describes Seismic II/I systems interaction and it is unclear from the discussion in this section whether the review will consider seismic class changes within the system. Clarify this aspect of the review.

Additionally the review should include other non-seismic components and systems (i.e., fans, pumps, instrument racks, duct work, etc.) whose failure could compromise the safety function of safety-related systems.

TERA RESPONSE: The Seismic II/I interaction review is being performed by the Civil disciplirje under Issue Specific Action Plan Item No. II.d, Rev. 2, and will address non-seismic components and systems wlose failure could compromise the safety function of safety-related systems. The review of piping class ~and class breaks within the AFW system is being performed under mechanical checklist System / Piping Arrangement (File No, M-1). Class 5 piping review for the proper classification is a separate review with a separate mechanical checklist (Class 5 Piping, File No M-21). Single failure at class breaks is being reviewed with mechanical checklist Single Failure /FMEA (File No. M-19).

TEAM EVALUATION: The team reviewed the above checklists and found that the stated concerns are covered. The response with respect to the Seismic II/I interaction review is acceptabl ,

~ NRC COMMENT: This Action Plan does not set forth the objectives and procedures that must be followed to accomplish an engineering walkdown of as-built items. Justify these omission TERA RESPONSE: Selected system walkdowns will support the review of HELB, Flooding and Seismic Qualification within the Mechanical discipline. These

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walkdowns will be performed to supplement available documentation in these areas, or to verify existing project walkdown information. Areas such as HELB are often amenable to walkdowns because zones of influence may not be well documented. The walkdowns are addressed in checklists for these review See mechanical checklists HELB (File No. M-22), Flooding (File No. M-23),

and Seismic Qualification (File No. M-26).

TEAM EVALUATION: TERA's objectives and procedures for engineering walkdowns of as-built items are defined. With respect to HELB, TERA needs to provide extensive review in areas where there is limited documentation for analyses of pipe break / target interaction . NRC COMMENT: Justify the omission from Section 4.1.5.9 of those inspection activities which will check the implementation of the E/I&C criteria for HELB, flooding and missile protection as stated in Section 3.2.5.11 of Item XI of Appendix A-32

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TERA RESPONSE: M:chanical checklists 22, 23, and 25 cover HELB, internal flooding, and missile protection and address mechanical, electrical, and I&C components required to either mitigate the accident or to bring the plant to a safe shutdown condition. The checklist implementation will involve interfacing between mechanical and electrical /I&C teams with respect to damage assessment TEAM EVALUATION: This response is acceptabl . NRC COMMENT: Paragraph 4.1.5.9.5 does not clearly state that the equipment purchase specifications will be reviewed to determine whether the correct environment has been included to assure proper qualificatio Provide clarificatio TERA RESPONSE: Mechanical checklists 9-18 cover system component For each of these, TERA will verify the correctness of environmental conditions indicated in the purchase specifications. In order to accomplish this by review of calculations for temperature, radiation, humidity and pressures, additional checklists will be developed as part of Phase TEAM EVALUATION: This response is acceptabl .

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APPENDIX 10

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RESOLUTION OF COMMENTS IN 9/30/85 NRC LETTER, DSAP XI, ELECTRICAL /I&C SYSTEMS AND COMPONENTS

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TERA responses to NRC scope related comments (as numbered below)'to DSAP XI of the Program Plan are provided below. The NRC questioned whether the DAP scope would include specific design activities. The team evaluation found the TERA response acceptable if it indicated that the specific design activity was enveloped by either Phase 2 or 3 scop . NRC COMMENT: Section 2.0 makes reference to Figure XI-3 as an illustration of the scope of the initial systems selection; however, the l figure depicts only Train A of the auxiliary feedwater system. Elements of AFW Train B, and the turbine AFW loop would also appear to be necessary in order to provide a complete review of the instrumentation and control discipline. Justify these omission r TERA RESPONSE: All three AFW trains are included in the Rev. 2 scope. Major components will be covered. An identification of specific instruments to be included has~not yet been mad TEAM EVALUATION: The TERA approach is correct, pending the identification of specific AFW instruments to be include , NRC COMMENT: Section 3.1.1.2 states that site initiated and procured components, which have not been environmentally qualified for their service condition, are to be subjected to a sampling program if the number of such it' ems exceeds five. This figure is inconsistent with the sampling program

. presented i,n Appendi Resolve this inconsistenc '

TERA RESPONSE: Section 3.1.1.2 had stated that, "Not less than five such items will be reviewed presupposing that at least that number are identified."

If a much larger population is identified, TERA will sample the particular

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components using the basis provided in Appendix D, and will not limit the sample sizetof[ive(5) component TEAM EVALUATION: The TERA response to use Appendix D as the sample size basis is acceptabl . NRC COMMENT: Section 3.1.1.6 states that the scope of the Program may be expanded to include other disciplines if a sufficient number of I components are found to be functionally inadequate. Rather than expand the l program scope to include other disciplines, it appears more logical to first expand the number of systems being reviewed. If the procurement of unqualified equipment by the site is indeed a pervasive problem, the use of these unqualified components in various system applications should be a first-order priority before the examination of generic aspects involving other engineering groups is begun. Justify the logic of your approac TERA RESPONSE: Within a given discipline, if a sufficient number of components for a specific system are found to be functionally inadequate, TERA plans to expand the review to address other system TEAM EVALUATION: This response is acceptabl A-34

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. . NRC COMMENT: In regard to S:ction 3.1.1.6, confirm that at least one compon:nt representative of each identified component type will be included in the revie TERA RESPONS'E: At least one component that is representative of each identified component type will be included. These components include relays, switches, control valves, transmitters, signal modifiers, controllers, bistables, instrument switches, indicators, panels,' racks, isolation valves, meters, hydrogen analyzers, solenoid valves, temperature elements, and isolation device TEAM EVALUATION: The team concurs with the proposed TERA plan in that at least one of many types of instrumentation components will be examine . NRC COMMENT: Section 3.1.2.1 states that plant fluid systems where design changes or re-evaluation of system operating conditions may have resulted in higher pressure or temperature ratings will be identified through a review of plant flow diagrams, system descriptions or other document Rather than review flow diagrams, system descriptions or other documents, a more.gffective approach would be to compare currently required conditions for process temperature and pressure against permissible operating environmental limits stated in instrument procurement specifications. Justify the logic of your approac TERA RESPONSE: The TERA Rev. 2 plan provides for a review of mechanical piping line diagrams for current process temperature and pressure conditions and then a review of related instrument specification sheets for performance limits. The instrumentation components to be included in this review encompass those in the auxiliary feedwater, diesel-generator auxiliary, containment spray, station service water, spent fuel pool cooling and cleanup, and safety chilled water system TEAM EVALUATION: The team cpncurs with the propcsed TERA plan since current process condition requirements will be compared with existing instrumentation procurement specification value . NRC COMMENT: Section 3.1.2.2 proposes the use of an inspection sampling program to evaluate those instruments whose pressure or temperature ratings may no longer be adequate for the intended service conditions. This approach does not allow for the possibility that each affected instrument needs to be identified and then individually assessed for overall adequacy in its unique' application in the plant. Provide technical justification for the samplin TERA RESPONSE: 100% review will be used for the safety-related systems affected by temperature or pressure design changes. Each instrument which could be affected by such a change will be reviewed to determine if it meets current process temperature or pressure condition TEAM EVALUATION: This response is acceptabl . NRC COMMENT: Section 3.1.2.3 implies that each instrument (in the population where temperature or pressure ratings may not meet current process conditions) may be found acceptable if interlocks or active isolation devices exist. The test should be expanded to indicate that the A-35

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acceptability of th2 instrument will take into consideration the cons:quencEs of failure of such interlocks or active isolation devices at the same time as the instrument is subjected to the extremes of process temperature and pressure condition TERA RESPONSE: As part of the Rev. 2 TERA plan, consideration Will be given to the consequences of failure of interlocks or active isolation. devices concurrent with the presence of extreme process temperature and pressure condition TEAM EVALUATION: This response is acceptabl . NRC COMMENT: Section 3.2 indicates that only the balance-of-plant (BOP) uninterruptible power supply has been identified for revie Experience has shown that both the 80P and the NSSS uninterruptible power supply loads are not well defined; therefore, the conclusions drawn from the review of the B0P power supply may not be extrapolated to the design of the NSSS power supply. Justify not reviewing the NSSS uninterruptible power suppl TERA RESPONSE: The*NSSS inverter has been added to the scope based on Phase TEAM EVALUAT' ION: This response is acceptabl . NRC COMMENT: Justify the following omissions from the initial scope presented in Section 3.2.1:

(1) The offsite power supply review of system voltage swings and fault current contribution (2) The 480 volt unit substations review of transformer impedances and sizing and the connection of the larger Non-Class 1E motors and

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. (4) The diesel-generator fuel oil transfer and storage syste .

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(1) The offsite power voltage swings are addressed in Checklist #1,

'" Voltage Profiles." Fault current-contributions are addressed in Checklist #2, "Short Circuit Currents."

(2) The,480v transformer impedances are addressed on Checklists #1 and

1. 2 for voltage and short circuit studies. Sizing is addressed on Checklist #5 which is to be retitled, " Diesel Generator and Transformer." Non-Class 1E loads on the Class 1E system are addressed in Checklist #8 " Load Shedding."

(3) The diesel-generator room HVAC and the diesel-generator fuel oil transfer and storage systems are covered in Checklist #23

"D/G Support Systems."

TEAM EVALUATION: TERA's response is acceptabl . NRC COMMENT: It appears from Section 3.2 that the reviews of single-failure and failure mode and effects analyses are limited to the Class IE power system and its single line diagrams. Justify the omission of equivalent analyses for instrumentation and control system A-36

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TERA RESPONSE': In Rev. 2 of the plan, TERA will review the instrumentation and control aspects of the Class 1E power system for postulated single failures. As a Phase 3 scope expansion, TERA will also evaluate the instrumentation and control aspects of the auxiliary feedwater system for postulated single failure ,

TEAM EVALUATION: The inclusion of postulated single failures in.the review of instrumentation and control portions of the Class 1E power system and the auxiliary feedwater system is acceptable to the tea . NRC COMMENT: Justify the omission from Section 3.2.5.3 of short circuit analysis for the 480 volt motor control centers and the containment electrical penetration TERA RESPONSE: The short circuit analysis for the 480 volt motor control centers is covered by Checklist #2, "Short Circuit Currents." Short circuit analysis for the containment electrical penetrations will be included in the scope of work for Phase TEAM EVALUATION: . TERA's response is acceptabl . NRC COMMENT: Section 3.2.5.7 indicates that the AFW setpoint bases and calculations will be checked for at least two such calculations. This sample size is considered to be too small. In addition, the calculation methodology used for balance of plant safety-related setpoints is not show Provide justification for the sample size and for the omission of i balance-of-plant setpoints calculation methodolog TERA RESPONSE: The TERA Rev. 2 plan will be expanded in Phase 3 from two to 12 instrument setpoint calculations. The following setpoint calculations will be included: *

AFW motor pomp low discharge pressure. ' ,

-

AFW motor pump recirculation flow, FT-2456 AFW turbine low suction pressur ~

Condensate storage tank low-low level, LT-2479 Diesel fuel oil day tank level high-high and low-lo Station service water A supply header pressure lo Component cooling water header 02 pressure lo Containment elev. 864 ft. 6 in. temperature hig Component cooling water heat exchanger flow to CCW cooler Instrument air after filter discharge pressur Vent chiller CCW supply control valv Control room differential pressure low (TNE).

TEAM EVALUATION: The proposed TERA plan to review 12 instrument setpoint calculations in various Comanche Peak systems is acceptable to the tea These calculations should be sufficiently representative of setpoint calculation methodolog . NRC COMMENT: Section 3.2.5.7 indicates that the review of the bases for protective relaying will be limited to the 6.9 kv bus. The basis for undervoltage protection should extend down through the 480 volt bus to the

120 volt leve Provide justification for this omissio A-37

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TERA RESPONSE: Checklist #2 (I & C) " Control & Instrumentation D/G I & C,"

addresses undervoltage protection for the 480v syste TEAMEVALUATiON: Undervoltage protection for 480v is covered as indicated above, but undervoltage protection for the 120v system is not ~ covered in any checklist. TERA stated that this omission was an oversight,.and will be addressed as a checklist revisio . NRC COMMENT: Section 3.2.5.7 indicates that the review of the bases for protective relay coordination is limited to two loads on the 6.9 kv bu Because of the different application criteria, and often different design personnel, equipment protective relaying and coordination should also

.

include motors on the 480 volt bus and 480 volt MCC and motor operated valve protection philosophy. Provide justification for these omission TERA RESPONSE: TERA's Checklist #25, " Fire Protection - Breaker Coordination,"

addresses relay setting coordination with respect to branch circuits for all voltages, including the 480 volt bus, 480 volt MCC and motor operated valve .s-TEAM EVALUATION: Checklist #25 considered coordination of relay and breaker settings, but did not factor equipment protection considerations into the relay settinij calculations. TERA plans to revise the affected checklists to include this ite . NRC COMMENT: Review of DC system indication and alarms has been omitted from Section 3.2. Provide justification for this omissio TERA RESPONSE: Review of DC system indication and alarms is within Rev. 2 scope and is addressed on Checklist No. 3, " Control and Instrumentation -

118 V, 125 V I&C." ,

TEAM EVALUATION: This res'ponse is acceptabl *

16. NRC COMMENT: The following components have been omitted from the "

initial list of components presented in Section 3.2.5.8:

D/G Load Sequencer

• 600-Volt Cable 480-Volt Bus Unit Substation TERA RESPONSE': The D/G load sequencer has been covered by Checklist #8,

,

" Load Shedding / Sequencing." The 600 volt cable will be reviewed under l Checklist #4, " Cable Sizing," and the 480 v bus unit substation design will be reviewed under Checklists #1, " Voltage Profile," and #2, "Short Circuit Currents."

TEAM EVALUATION: TERA's response is acceptable, j 17. NRC COMMENT: Section 3.2.5.10 does not define the breadth of the l review of the HVAC supporting systems. Justify the omission from this

! section of such HVAC systems supporting the DG, switchgear, batteries, and i electrical penetrations.

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. . i TERA RESPONSE: Checklist #23, "D/G Support Systems," covers HVAC i requirements for the diesel generator. TERA will review HVAC requirements for one of the remaining components in Phase TEAM EVALUATION: TERA's response is acceptabl ,

1 NRC COMMENT: Confirm that the FMEA studies referred to in Section 3.2.5.9 include both the electrical and AFW systems or justify their omissio TERA RESPONSE The electrical review will include review of the FMEA tables of FSAR Section 8. Checklists #20, " Single Failure /FMEA-Redundancy", #21,

" Single Failure /FMEA-Independence", and #22, " Single Failure /FMEA-Separation / Cable Routing" address electrical failures for both the electrical and AFW system TEAM EVALUATION: TERA's response is acceptabl . NRC COMMENT: Confirm that Section 3.2.5.1 includes the review of:

.g*

(1) Analysis of Post-Accident Flooding Inside Containmen (2) AFW System cable in the Fire Protection Safe Shutdown Analysi TERA RESPONSE: Analysis of post-accident flooding inside the containment will be covered by electrical checklist #24, " Environmental Qualification."

Electrical will interface with the mechanical discipline with respect to establishment of flood levels. The electrical groups Phase 3 scope of work will include a complete review of fire protection (including AFW system).

The review will involve fire area identification, hazards analysis, suppression systems, safe shutdown, fire seals and barriers, ventilation '

system, lighting and communication, and fire detection, as well as system interaction .

.

,

TEAM EVALUATION: TERA's response is acceptabl ~

2 NRC COMMENT: Section 3.2.5.11 indicates that the review will be limited to five components for environmental qualification and unspecified number of components for seismic qualification. Justify the size of the sample to'be reviewed. In addition to Westinghouse supplied instrumentation and control components, confirm that the sample includes balance-of-plant safety-related components specified by Gibbs and Hill or Texas Utilities Electric Compan TERA RESPONSE: The sample size for electrical and I & C components for environmental qualification will be increased to a minimum of 25; 12 of these will be I&C components. The electrical discipline review will be performed using Checklist #24, " Environmental Qualification." Seismic qualification review will be performed by the mechanical group using mechanical Checklist #2 At least 10 I&C components will be reviewed. For both reviews, neither the specific components nor the organizations which specified them have been identifie TEAM EVALUATION: The response is acceptable with respect to increased sample size. This item remains open pending identification of specific components and organizations specifying components in the sampl In l

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additirn, TERA n:eds to identify the number of mechanical and elec~trical components to be reviewed for seismic qualificatio . NRC COMMENT: Justify the following omissions in Figures XI-1 and XI-2:

23(1): Page 23, voltage operating limits should be in design output procurement specifications to vendor TERA RESPONSE: As part of the rev. 2 plan, TERA will review voltage operating limits in Class IE power instrumentation and control procurement

,

specifications as part of the component functional requirements review activit TEAM EVALUATION: TERA's plan to review voltage operating limits in procurement specifications to vendors is acceptable to the tea (2): Page 23, frequency operating limits should be in design output procurement specifications to vendor TERA RESPONSE: As'part of the rev. 2 plan, TERA will review frequency operating limits in Class 1E power instrumentation and control procurement specifications as part of the component functional requirements review activity.

TEAM EVALUATION: TERA's plan to review frequency operating limits in

'

procurement specifications to vendors is acceptable to the tea (3): Page 23, normal / start-up/ shutdown operating modes should be presented on design cutput process flow diagram TERA RESPONSE: As part of the rev. 2 plan, TERA will review auxiliary feedwater system design output process flow diagrams for normal, start-up, and shutdown operating modes and related requirement TEAM EVALUATION: The TERA plan to review various operating modes and .

- related requirements of the auxiliary feedwater system is acceptable to the tea '

23(4): Page 23, LOCA/ Loss of Off-site Power details should be presented on design output schematic diagrams.

! TERA RESPONSE: As part of the rev. 2 plan, TERA will review design output schematic diagrams for detailed requirements for the loss of coolant accident and loss of off-site power signals to ESF loads as part of the AFW control and diesel-generator control and instrumentation review activitie TEAM EVALUATION: The team concurs with the proposed TERA plan for review of the LOCA and LOOP signals.

23(5)

Page 25, redundancy should be shown on design output schematic i diagrams and in procurement specification TERA RESPONSE: As part of the rev. 2 plan, TERA will review redundancy requirements implemented in design output schematics during the single A-40

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failure analysis review and in procurement sp:cifications during the comp:nent functional requirements rsview activit TEAM EVALUATION: The team concurs with the proposed TERA review of redundancy requirements on schematic diagrams and procurement specification (6): Page 26, diesel-generator fuel oil transfer should be shown on design output flow and schematic diagram TERA RESPONSE: As part of the rev. 2 plan, TERA will review fuel oil transfer requirements and implementation details on piping and instrument and schematic diagrams as part of the diesel-generator support systems review activitie TEAM EVALUATION: The team agrees with the TERA plan to review P&ID and schematic diagrams for fuel oil transfer requirement (7): Page 26, diesel-generator cooling water should be shown on design output flow and schematic diagram TERA RESPONSE: As part of the rev. 2 plan, the Electrical group will interface with the Mechanical group to review cooling water requirements and implementation details as part of the diesel-generator support system review activitie TEAM EVALUATION: The team agrees with the TERA plan to review cooling water details for the diesel-generator syste (8): Page 27, voltage operating limits should be in design output procurement specifications to vendor TERA RESPONSE: As part of the rev. 2 plan, TERA will review voltage operating limits in AFW instrumentation and control procurement -

specification TEAM EVALUATION: The team concurs with the TERA plan to review voltage -

operating limit (9): Page 27, frequency operating limits should be in design output procurement specifications to vendor TERA RESPONSE': As part of the rev. 2 plan, TERA will review frequency operating limits in AFW instrumentation and control procurement  !

'

specification TEAM EVALUATION: The team concurs with the TERA plan to review frequency operating limits in AFW instrumentation and control procurement specification (10): Page 27, LOCA/ Loss of Off-site Power details should be presented on design output schematic diagram TERA RESPONSE: As part of the rev. 2 plan, TERA will review implementation of LOCA/ LOOP details on AFW schematic diagram A-41

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TEAM EVALUATION: Th2 team c:ncurs with the TERA pla (11): Page 28, process control should be shown on design output schematic diagrams and in procurement specification ,

TERA RESPONSE: As part of the rev. 2 plan, process control details will be reviewed on diesel-generator support system schematic diagrams and in procurement specifications during the component functional requirements review activitie TEAM EVALUATION: The team agrees with the TERA plan for process control design detail review (12): Page 28, status indication should be provided in design input documents, such as Westinghouse criteria documents, and in design outputs such as schematic diagram TERA RESPONSE: During rev. 2 activities, status indications will be reviewed from design input though design output documents for AFW control, AFW instrumentation, and diesel-generator instrumentation and control review ,

TEAM EVALUATION: The team agrees with the TERA plan for review of status indication (13): Page 29, redundancy should be shown on design output schematic diagrams and in procurement specification TERA RESPONSE: As part of rev. 2, AFW redundancy will be reviewed on schematic diagrams and in procurement specification *

"

TEAM EVALUATION: The team agrees with the TERA plan for AFW system redundancy revie ,

I

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2 NRC COMMENT: Figure XI-2, Page 29, " Support Systems Review Area,"

makes reference to the initial scope review matrix for information regarding

upport systems. Confirm that the following support systems for the AFW identified in FSAR Chapter 7.31 will be included in the review

, ESF Ventilation System Safety Chilled Water System Component Cooling Water System Station Service Water System SSWS Intake Structure Ventilation System

.

Stction Air System TERA RESPONSE: As part of rev. 2 activities, ESF ventilation to I diesel-generator rooms will be reviewed in the diesel-generator support i system checklist. As a phase 3 expansion, ESF ventilation for the AFW pump i rooms will be added to the AFW support system checklis As part of rev. 2, instrument ratings for safety chilled water system instruments will be reviewed on Checklist #4, " Instrumentation-Fluid System Instrument Ratings." As a phase 3 expansion, instrument safety class, l

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-a .,#.= A - a _ - 4 _., * -e. =e+.i.L=-xw.._ w- -J +

--

..-~cA-*** - J e a. - -*ae. w w a+ __

a., - A ,a

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hydrostatic test, seismic mounting, and instrument power supply assignments will be reviewed for this syste ! As a phase 3 expansion for the component cooling water system, a new

'

checklist will address instrument power supply assignments, the, low pressure interlock from train A to B, the single failure analysis of this interlock, and response time of the interlock pressure switc l As part of rev. 2, instrument ratings for station service water system

!

instruments will'be reviewed as an External Source Issue. As a phase 3

.

expansion, instrument power supply assignments, the interlock with CCW pumps, safety-class, hydrostatic test, and seismic mounting of instruments

will be reviewe In a new checklist (phase 3), SSWS intake structure ventilation system power supply assignments will be reviewe In a new checklist (phase 3), the station air system will be reviewed for accident monitoring instrumentation requirements, Class 1E power supply assignments, and th6 calculation of the low pressure setpoin TEAM EVALUATION: The TERA response pertinent to the AFW supporting systems is acceptable to the team.

i 26. NRC COMMENT: Justify the following omissions in Figure XI, Page 29,

Multi-Discipline Consideration: HELB line break, missile protection, fire protection, cold shutdown, including the remote shutdown panel interfac TERA RESPONSE: HELB and missile protection are covered by the Mechanical discipline (see checklists 22 and 25). Fire protection is covered in electrical checklists 25 and 26 on a multidiscipline basis and has been expanded in Phase 3 to cover THE and outside contractors' design. (See TERA's response to NRC coment 19 above). Remote and cold shutdown are a Phase 3 expansio s TEAR EVALUATION: ,

The TERA plan is acceptable to the team.

l 2 NRCC 'OMMENT: Justify the omission of the following items not shown in j figure XI-3 from the review scope of Train "A".

i '

i o Alternate offsite power source i

'

o 6.9 kv bus tie breaker o Non-Class IE motor on Class 1E 480-volt switchgear o Non-Class IE MCCs on Class 1E 480-volt switchgear

'

o Motor operated valves on 480-volt MCC o NSSS inverters on the 125 VDC switchboard

,

)

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TERA RESPONSE: The motor operated valv;s on the 480 V MCC and the'NSSS inverters on the 125 VDC switchboard will be reviewed under the phase 3 scope of work. Review of the alternate offsite power source and the 6.9 kv bus tie breaker will be covered in Checklists #9, " Load Shedding / Sequencing

& Transfer,"-#1, " Voltage Profiles," and #2, "Short Circuit Currents."

Non-Class 1E loads on the Class 1E systems are reviewed in Checklist #8,

" Load Sequencing / Shedding."

TEAM EVALUATION:

TERA's response is acceptabl .-

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APPENDIX 11 DISCREPANCIES BETWEEN APPENDICES 2-10 AND CPRT-113

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DATED NOVEMBER 22, 1985 NRC letters dated August 9 and September 30, 1985 contain scope-related comments pertinent to Appendix A and DSAPs VIII through XI of the CPRT Program Pla During the inspection, TERA provided verbal responses to these consnents; these are recorded in Appendices 2 through 10 of this report. TUGC0 letter CPRT-113 dated November 22, 1985 provides formal responses to these same coninents. The verbal and formal responses are consistent except as noted below. For these cases, this report rather than the TUGC0 letter correctly reflects the TERA respons TERA Response CPRT-113

' tem N Design Issue During Inspection dated 11/22/85 Appendix 3, Radioactive Not in scope Phase 3 item 9 flujdflow Appendix 3, Sump design Phase 3 Not in scope item 11

-

Appendix 3, Storage tank Phase 3 No response item 12 design

~

Appendix 3 Vortex prevention Phase 3 expansion to Phase 2 item 13 address containment

+

sump Appendix 3, NPSH Limitation Phase 3 expansion to No response item 14 address more complex case than AFW system Appendix 3, Surge tank sizing Phase 3 Not in scope -

item 20 Appendix'3, Series and Phase 3 No response parallel thermal

,

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item 26 loads Appendix 3, Change in Phase 2 Not in scope item 31 elevation Appendix 3, Required for Phase 2 Not in scope, item 33 reactivity control candidate given Appendix 3 Positive Phase 3 Not in scope item 37 displacement pumps Appendix 3, Maximum flow Phase 3, Phase 2 item 38 velocity candidate given limitation

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TERA Response CPRT-113 Item N Design Issue During Inspection dated 11/22/85 Appendix 3, ' Standby hydraulic Not in scope Phase 2 item 41 requirement -

(charge or fill)

Appendix 3, Pump protection Phase 3 expansion to Phase 2 item 46 requirements positive displacement pumps Appendix 3, Parallel pump Not in scope Phase 2 i item 47 operation Appendix 5 Reactor coolant Phase 3 Not in scope item pump underfrequency protection Appendix 10, Review of safety- 100% review Sampling review item 6 reldted instruments potentially affected

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by temperature /

pressure design changes

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APPENDIX 12 COMMENTS ON REVIEW CHECKLISTS

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Table 1 to this report lists review checklists that were provided for the team's review. The team reviewed checklists as part of evaluating TERA responses to the NRC comments (see Appendices 2-10). Detailed comments are provided below with respect to necessary areas of checklist improvements and expansions. Checklist numbers indicated below correspond to those in Table _

Mechanical Systems and Components Overpressure Conditions This checklist does not provide an adequate review of overpressure protection design since the AFW system is not representative of such desig TERA plans to review a more representative system and develop a checklist which addresses the basis for relief valve sizing relative to set pressure and design flow rat . Water Su'pplies This checklist does not (nor does any other) address the requirement that the service water system (backup source) provide adequate flow to the AFW system while maintaining required flows to other safety related equipment. TERA plans to verify this as a part of its interface review of the service water syste . Air Accumulators

'

Checklist No. 11 does not address the basis for the 30 minutes required -

accumulator capacity as connitted in the FSAR. TERA plans to revise the checklist to cover thi ,

22. HELB This checklist did not include a review of evaluations performed on targets required for safe shutdown of the plant (considering single failures and loss of off-s.ite power) for postulated high energy line breaks. TERA plans to revise the c'iecklist to include thi ,

23. Internal Flooding Checklist #23 did not address identification of safety-related equipment required for safe shutdown which is below flood levels resulting from postulated high and moderate energy line breaks (considering loss of off-site power and single failure for the event evaluated). TERA plans to )

revise the checklist to include thi I

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26. Seisaic Qualificaticn This checklist generically addresses mechanical as well as electrical equipment qualification. Since mechanical equipment is subjected to pressure loading and various transients, and its internal components must be designed to resist operating mechanical loads, the checklist should +

consider:

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o Pressure boundary calculation o Bearing load evaluations where applicable, o Shaft deformation as it affects functional consideration .

'

o Nozzle qualification calculation ;

o Foundation interface load determination, o Overall load combination check and ASME Code,Section III stress comparisdn General Comment There is no checklist covering NF supports (other than pipe supports) in the Civil / Structural or Mechanical area Civil / Structural The following are general comments on the checklists:

(1) DAP-4, Attachment C checklists are limited to listing licensing *

commitments and do not address design methodology for ,.

demonstrating compliance with the commitments. As a related matter, only one of the C checklists indicated the " Description of Verification" for the listed attributes, i.e., the description of .

the method for verifying implemer,tation of the criterio (2) .DAP-4, Attachment D and B checklists provide, (a) generic design review guidance (similar to that in ANSI N45.7.11 - 1974, Section 6.3.1),and(b)documentationofthechecklistreview,respectivel (3) TERh's system assumes that the reviewer will have sufficient general design review guidance in the Attachment 0 checklist to ensure that the Attachment B checklist results in complete documentation of the review process which verifies that the commitment identified in Attachment C has been me However, this also assumes that the reviewer will have sufficient experience to extend the general design review guidance to discipline specific system and component applications, since

guidance for the applications is lacking in the checklists.

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Some e Mit' rial considerations which are lacking are consideration

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of the n e v P t of design changes, field change requests, and non-c;m.aaaance reports and compatibility of the design with drawings / specifications controlling construction and procurerent.

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The team reviewed all comp 1';ted Attachment C civil / structural checklists listed in Tabla 1, cxc;pt for C/S - 5127, "S.G. Lateral Restraints," which is tha responsibility of TRT for review. The team identified the following concerns for specific Attachment C checklists:

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C/S-G001: Structural Steel The AISC " Specification for the Design, Fabrication and Erection of Structural Steel for Buildings, AISC - 1969," does not address torsion design considerations such as web torsion, torsion on connections, and torsion on box beam connections, The design method used to consider the effects of combined loads involving axial, bending and torsional loads is not addresse The design method used to consider the six components of combined effects at connections is not addresse Since the AISC Specification does not address the stability of flanges,, webs and plates under combined stresses, there is a need for the aspect to be addresse Local stresses such as flange bending and the associated

~

deflections are net addressed. These are important since localized loads arising from piping, mechanical, electrical or control systems can cause increases in the local effects in excess of those caused by the global load ,

C/S-G018: Loads and Load Combinations for Foundations The checklist merely references other checklists to integrate the variou} load sources into the foundation loads. The checklist does not address the development of the controlling load cases considering static and dynamic responses as well as settlemen The actual soil bearing pressures should be checked against the -

allowable The checklist does not address the FSAR considerations for over-turning or rocking effects and the margins involved, as well as -

the,effect on bearing pressure C/5-G031: Generic Non-ASME Supports The determination of required loads and load combir.ations is controlled by the safety classification and functional requirements of the system and its components. This is not generally discussed in detail in the FSAR for component support The verification of required loadings and load combinations i should be addresse .

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. . Th2 technical basis does not app;ar to be evaluated for HELBA,-

MSLB and MELBA loads on component The reference to pipe break loads, and pipe reactions is applicable to the qualification of piping penetration.s onl Since pipe penetrations are very unique components and a potential homogeneous design activity, a separate checklist is recomended for the ASME portion (flued head - temperature distribution and stress evaluation) as well as the barrel, liner plate reinforcement and shear lug (ACI,AISC evaluations).

C/S-5101: Containment Concrete Design Items 1.2.10 and 1.7 - These two checklist items apparently refer to the same FSAR commitment, specifically Section 3.8.1.5.1.1, which correctly interprets the ACI 359-73 documen However, neither Item 1.2.10 nor 1.7 give the complete list of conditions which are allowed or are necessary. One method is to state these conditions as a single requirement, e.g.,

" For factored load combinations which include a thermal gradient, the maximum strain in the reinforcing steel in one face is. limited to 1.5 times the yield strain, providing the average reinforcing steel stress across the section does not exceed 0.9 times the yield strength." Items 1.2.11 and 1.6 - These two checklist items apparently refer to the same FSAR comitment, specifically Section 3.8.1.5.1.1, which correctly interprets the ACI 359-73 documen However, neither Item 1.2.11 nor 1.6 give the complete requirements. One method to state these is: "for factored load combinations the average tensile stress on reinforcing steel shall

- not exceed 0.9 times the yield strength." , Item 1.5 - The review addresses maximum radial shear,but not typical calculations which determined the radial shear values, nor how the ,

shear reinforcement.was determined and provided. In addition, it does not cover the details, control and results of welding the 1"x4" plates

. , at 45 degrees between opposite face vertical reinforcing steel. This is important since it does not appear any special requirements for weldability were imposed on the reinforcing stee Item 1.9 - Although this relates to the value used in the calculation and not test values, this check attribute is not listed under 4.0 Calculation Revie Item 4.0 - There are no cross-references in this section to Checklists C/S-G021 and G-022 which address calculation C/S-5102: Other Category I Concrete Design 7 Item 1.1.2 - If there are no members meeting the classification requirements of a deep flexural member under ACI 318-71,

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Paragraph 10.7, th:n ansth r attributa should be checked in the design revie Section 10.6 of ACI 318-71 should be included in the attributes to be checked since bear:s and one-way slabs were no doubt utilized in the concrete structure Chapter 13 of ACI 318-71 should be included in the list of attributes to be reviewed if the 2-way slab concepts were used in the design of concrete structure C/S Sill: Spreading Room Steel Structure For nuclear plants in general, the structural steel in the containment annular space and certain other areas in the auxiliary building, which are normally framed in structural steel, may represent more critical loadings (than the cable spreading room) which should be reviewed. This current sample for the design review may be too limite ,_

C/S-5121: HVACSupports The HVAC support checklist references generic checklists which require consideration of continuity of the duct system itself during design (C/S-G031,G001,G005). Major controlling parameters not addressed are:

o Duct joint capacit o In-line components such as booster fans and turning vane o Openings in duct wor o The treatment of duct wall buckling as it affects overall stability during seismic event o The functional classification of HVAC systems and the effects .

on design requirement C/5-5122:. Crane Supports The polar crane support evaluation should include liner plate thickening, concrete embedment and inter-discipline verification that applied crane loads are current and properly considered response spectra and design load ratin C/S-5123: Equipment Supports .

The purpose of attribute 4 is to assure that support stiffness, frequency,

. and loading are reviewed for major equipment vendors design requirement This should not be limited to NSSS equipment, since other vendor equipment often represents a greater percentage of the heavy equipmen C/S-5124: penetration Sleeve Supports Connent C for C/S-G031 (above) applies her !

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C/5-5125: Missilo R:sistant Do:rs and Hatch s The qualification document (s) should be compared to the procurement specification to assure that design requirements were me '

C/S-5126: Seismic Restraints for Removable Shield Walls Since Checklist G-005 is referenced as the anchorage checklist for S125 and S126, consideration of the continuous anchorage for missile resistant doors, hatches and removable shield walls should be addressed.

C/S-5131: Cable Tray Supports This checklist addresses technical concerns raised by Cygn However, it does not cover other design aspects such as:

o Evaluation of the portions of the plant where overall tray system behavior must be considered in addition to areas where individt a] support qualification is vali o The qualification of the cable tray itself for two and three dimensional cable loadings (consider local tray buckling and yielding.)

o Control of cable weight during rating and, where required, derating of the system.

piping and Supports One out of three checklists has been completed to date, that pertaining to the review of SWEC procedures. Checklists for the review of the SWEC piping analysis implementation and the support design implementation were not ,

available.

The checklist for procedure review (Checklist No. DAP-CI.-P-001, Revision 0, .

dated 10/25/85) lists all design criteria (identified in accordance with DAP-1), external source issues (identified in the computer tracking system),

and standard QA requirements (ANSI N45.2.11) in order to ensure they are addressed in design procedures.

The checklist.does not address the adequacy or completeness of the procedures with respect to the engineering methods or calculational techniques to be used for design. The team was informed that these items would be included in the checklists for the review of the piping analysis and pipe support design implementation. Thus, the team cannot reach any conclusions regarding the depth of the third-party review of the piping and support effort without reviewing the checklists for the piping analysis and support design implementation. The third-party will tentatively have these checklists available for team review by early December 198 Instrumentation and Control (1) The description of verification column did not provide or require an identification of specific technical requirements to be met, and therefore would not have provided a conclusion regarding the technical A-52

,

.

adequacy of selected instrumentation component Examples of these technical requirements include range, safety class, pressure boundary hydrostatic tests, response time, seismic capability, tolerance for anticipated variability in plant power sources, instrument repeatability and drift, trip reset constraints, time delay tolerances, and restrictions on the use of certain materials during fabricatio (2) This same column did not specify that instrument and control circuits would be reviewed from sensors through the actuated equipment or to the energy source and supporting system interface (3) The checklists did not address confirmation of instrument taps on tank and piping drawings for location, elevation, azimuth orientation, and redundancy to provide a direct comparison with system requirements and protective action setpoint (4) The checklists,did not address confirmation of system test, component test, and component calibration design provisions needed to satisfy Regulatory Guide 1.22 and IEEE Std. 33 (5) The checklists did not address confirmation of operator action time, provisions for Class 1E indications, required valve interlocks for AFW pump suction fluid sources, and coordination with the mechanical systems discipline for available fluid volume to permit manual transfer from the condensate storage tank to the station service water syste (6) The checklists did not address AFW pump suction pressure switch setpoint trip and reset differential and resulting effects on AFW system availabilit . .

Electrical

' As indicated in Appendix 10. (NRC letter dated 9/30/85, Question 13),

the TERA checklist failed to address loss of voltage detection at the 120 V leve . AsindicatedinAppendix10.(NRCletterdated9/30/85, Question 14),

the TERA. checklist failed to address electrical protective device . As indicated in Appendix 10. (NRC letter dated 9/30/85, Question 20),

TERA has not defined the scope of the environmental and seismic .

equipment qualification reviews. The checklist failed to identify types of components to be reviewed and responsible organizations for specifying the component . Many component functional requirements checklists listed general criteria such as reference to IEEE 308 and 323, but did not include functional requirements specific to the equipment being reviewed)

e.g., switchgear breaker current interrupting requirenent . Checklist #4, " Cable Sizing," addresses cable empacity, but does not address cables located inside the containmen A-53

_. _

. . Checklist #13, ' Component Functional RIquirements - Panatraticn,"

does not address backup protection provisions, as described by R.G. 1.6 .

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TABLE 1: LISTING OF REVIEW CHECKLISTS MECHANICAL SYSTEMS AND COMPONENTS CHECKLIST SUMMARY Checklist Discipline Checklist Title , Mechanical System / Piping Arrangement Mechanical System Testing Provisions Mechanical NPSH Mechanical Maximum / Minimum Flow Mechanical Overpressure Conditions Mechanical Steam Flow Mechanical Heat Removal Capacity Mechanical Water Supplies Mechanical Motor Driven AFW Pump 1 Mechanical Turbine Driven AFW Pump 1 Mechanical Air Accumulators 1 Mechanical SG Isolation Valves 1 Mechanical Steam to Turbine Driver Valves 1 Mechanical SWS Isolation Valves 1 Mechanical Pipe and Piping Components 1 Mechanical Flow Control Valve 1 Mechanical Condensate Storage Tank 1 Mechanical Flow Limiting Orifice 1 Mechanical Single Failure /FMEA 2 Mechanical Support Systems 2 Mechanical Class 5 Piping 2 Mechanical HELB 2 Mechanical Flooding - Internal 2 Mechanical Flooding - External 2 Mechanical Missile Protection 2 . Mechanical Seismic Qualification

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T-1

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TABLE 1 (Continued)

CIVIL / STRUCTURAL CHECKLIST INDEX 1.0 GENERIC' CHECKLIST Checklist N .1 Acceptance Criteria -

Structural Steel Criteria C/S- G001 Base Plate / Anchor Bolt G005(Later)

1.2 Loads / Load Combinations Containment C/S- G011 Internal Struct. Loads G012 Internal Struct. Concrete Load Combinations G013 Internal Struct. Steel Load Combinations G014 .

Other Category 1 Struct. Loads G015 Other Category.1 Struct. Concrete Load Combinations G016 Other Category 1 Struct. Steel G017 Loads and Load Combination for Foundation G018 1.3 Analysis / Design Computer Modeling C/S- G021 Hand Calculations G022 Seismic Subsystem Analysis G023 Equivalent Static Analysis G024 1.4 Generic Non-ASME Supports C/S- G031 ,

,

2.0 TOPIC SPECIFIC CHECKLIST 2.1 Concrete Design -

2. Containment C/S- S101 2. Other Category 1 Concrete Design 5102 (Aux. and Fuel Building)

2.2 Steel Design 2. Cable Spreading Room C/S- Sill 2. Pipe Rupture Restraint / Jet Shield S112 2.3 Non-ASME Supports 2. HVAC Supports C/S- S121 2. Crane Supports S122 2. Equipment Supports S123 2. Penetration Sleeve Supports S124 2. Missile Resistant Doors & Hatches 5125 2. Seismic Restraints for Removable S126 Shielding Walls T-2

- - - _ _ - . . . . -__ . . - - _ _ .

. -

TABLE 1 (Continuzd)

CIVIL / STRUCTURAL CHECKLIST INDEX S.G. Lateral Restraints C/S- S127 2.5 Cable Tray Supports C/S- S131'

'

2.6 Conduit Supports C/S-S132(Later)

2.7 Discipline Instruction for As-Built Verification Program 2. Cable Tray Supports C/S- S141 (Later)

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2. Conduit Supports C/S- S142 (Later)

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_,._ - _. . _ _ - - _ . _ _ - _ _ _ _ - _ _ _ _ _ _ _ . .

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TABLE 1 (Continued)

INSTRUMENTATION AND CONTROL CHECKLIST SUMMARY

'

Checklist Review Number Task Checklist Titla (E6) Control - AFW Control ,

(

_E6)(E7) Control & Instrumentation D/G I&C '

(E6)(E7) Control & Instrumentation 118V, 125V I&C (E7) Instrumentation - F1d. Sys. Instr. Ratings (E7) Instrumentation - AFW Inst . (E6)(E7) Control & Instrumentation AFW & D/G Inst e* Setpoints , (E9) Single Failure - D/G & AFW (E10) Support Systems - D/G & AFW (E8) Funct. Requirements - Instrumentation 1 Criteria Evaluation (Attachment A Checklist)

11- (E6-E10) Topic Checklist

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. (Attachment B Checklist)

1 (E6) Control -

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1 (E7) Instrumentation -

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(E8) Functional Requirements -

1 (E9) Single Failure -

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1 (E10) Support Systems -

T-4

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._ _ _ _ _ _ _ _ __

. .

TABLE 1 (Continued)

ELECTRICAL CHECKLIST SUMMARY

-

Checklist Review Number Task Checklist List (E3) Electrical Characteristics

- Voltage Profiles ' '(E3) Electrical Characteristics

- Short Circuit Currents (E3) Electrical Characteristics

- Terminal Voltage (E3) Electrical Characteristics

- Cable Sizing

.s- (E4) Electrical Load Capacity

,

- Diesel Generator / Transformers (E4) Electrical Load Capacity

- Inverters (E4) Electrical Load Capacity

- Batteries / Chargers (ES) Load Shedding / Sequencing (ES) Load Transfers .

.

1 (E8) Component Functional Requirements

- AFW Pump Motor .

1 (E8) Component Functional Requirements

- 6.9kV Switchgear

.

1 (E8) Component Functional Requirements

,

- Battery 1 (E8) Component Functional Requirements

- Penetration 1 (E8) Coyptaent Functional Requirements

- AFW Pump Motor Breaker ;

1 (E8) Component Functional Requirements ,

- 8kV Cable l

1 (E8) Component Functional Requirements !

- Motor Control Center T-5

'

.

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TABLE 1 (Continued)

ELECTRICAL CHECKLIST SUMMARY

.

Checklist Review Number Task Checklist Title 1 (E8) Component Functional Requirements

- Battery Charger 1 (E8) Component Functional Requirements

- BOP Inverter 1 (E8) Component Functional Requirements

- Spent Fuel Pool Cooling Pump Motor 2 (E9) Single Failure /FMEA

- Redundancy

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2 (E9) Single Failure /FMEA

-

- Independence 2 (E9) Single Failure /FMEA

- Separation / Cable Routing 2 (E10) D/G Support Systems 2 (Ell) Multi-Discipline Considerations

. - Environmental Qualification

-

2 (Ell) Multi-Discipline Considerations

'

- Fire Protection - Breaker Coordination 2 (Ell) Multi-Discipline Considerations -

- Fire Protection - Systems Interaction 2 Criteria Evaluation (Attachment A Checklist)

28- - (El-Ell) Topic Checklist 3 (AttachmentBChecklist)

l 2 (E1) - System Operating Limits 2 (E2) - Systems Operating Modes 3 (E3) - Electrical Characteristics 3 (E4) - Electrical Load Capacity 3 (ES) - Load Shedding, Transfers and Sequencing l

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ELECTRICAL CHECKLIST SUMMARY (Continued)

'

Checklist Review Checklist Title

-

Number Task 3 (E8) - Component Functional Requirements 3 (E9) - Single Failure 3 (E10) - Support Systems 3 (Ell) - Mutli-Discipline Considerations 3 General Calculation Checklist 3 General Specification Checklist t

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