ML20207K707
| ML20207K707 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/29/1986 |
| From: | Everett J, Karaan E ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| To: | |
| Shared Package | |
| ML20207K660 | List: |
| References | |
| 09-0210-060, 09-0210-060-R00, 9-210-60, 9-210-60-R, NUDOCS 8701090493 | |
| Download: ML20207K707 (29) | |
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Dh REPORT APPROVAL COVERSHEET GENERIC ~ TECHNICAL ISSUE REPORT - Evaluation and Resolution of TERA Equipment Qualification Issue Resolution Reports M
DAP-E-EIC-50_3 (Environmental) and DAP-E-M-500 (Seismic)
W.
09-0210-060 ROVISIOn:
,o g. Texas Utilities Generating Company M g 0210-062 g
Equipment Qualification RECORD OF REM 810N REVBON DATE PREPARED REVEWED APPROVED 7tgM IMfd o
12./2.9/e4 3 (%
9 8701090493 870105 DR ADOOK 05000445 PDR
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TEXAS WILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC S'tTION UNIT 1 GENERIC TECHNICAL ISSUE REPORT - EVALUATION ANT)
RESOLWION OF TERA EQUIPMENT QUALIFICATION ISSUE RESOLWION REPORTS: DAP-E-EIC-503 (ENVIRONMENTAL)
AND DAP-E-M-500 (SEISMIC)
CORRECTIVE ACTION PLAN PREPARED FOR:
TEXAS W ILITIES GENERATING COMPANY GLEN ROSE, TEXAS PREPARED BY:
IMPELL CORPORATION FORT WORTH, TX.
IMPELL REPORT NO. 09-0210-060 REV.0 FINAL ISSUE REPORT DECEMBER 1986
TEXAS ITTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECIRIC STATION TABLE OF CONTENTS E!NLe Title Page Report Approval Cover Sheet i
Table of Contents 11 Definition of Generic Technical Issues lii I.
Introduction 1
II.
Issue Resolution Process 2
III. Report Organization and Issue Process 2
IV.
Abbreviations 2
V.
References 3
Appendices t
I 11
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DEFINITION OF GENERIC TECHNICAL ISSUES
'Ihe Comanche Peak Steam Electric Station (CPSES) Design Adequacy Program (DAP) reviews associated with Topics M30 " Seismic Qualification", M43 " Balance of Plant Pump and Valve Operability" and Ell " Multi-Discipline Concerns-Environmental Qualification" have identified issues that relates to the documentation that shows the electrical and mechanical equipment can perform their required safety functions. These issues are identified in DAP-E-M-500 and DAP-E-EIC-503 for the Seismic and Environmental Qualification respectively and are grouped into the following issue categories:
SEISMIC QUALIFICATION DISCREPANCIES (DAP-E-M-500)
ISSLI SUBJECT 1
Documentation to demor. strate that all safety related equipment was identified; 2
Classification of safety related equipment as Seismic Category I active or passive components and qualification requirements; 3
Design documentation demonstrating compliance with qualification requirements including control of changes and inadequate interface control.
4 Evaluation or resolution of discrepancies in qualification test or analysis results, including justification of design changes and test anomalies; and 5
Verification of as-built conditions, including results of as-built evaluations of interfacing systems and components.
ENVIRONMENTAL QUALIFICATION DISCREPANCIES (DAP-E-EIC-503)
ISSUE SUBJECf 1
Documentation to demonstrate that all safety related equipnent was identified; 2
Calculations to determine environmental conditions such as temperature; 3
Specification of EQ requirements such as test requirements and qualification parameters; 4
Qualification test and analysis documentation for EQ parameters, analytical justification, and test sequence; iii
r ISSUE SUBJECT 5
Doctmented correlation between the installed equipnent and the corresponding EQ documentation, to doctament that test limitations have been reflected or verified in the installed condition, and to verify that the installed equipment is in the same condition as the tested equipnent; 6
Evaluate qualification test anomalies; 7
Documentation of the evaluation of generic regulatory concerns that were identified for certain equipment items such as for BIW cable, NA>KD limit switches, and ASCO solenoid valves; and 8
Verification that maintenance and surveillance requirenfents derived from EQ testing or vendor requirements have been addressed.
The above issue categories are supported by specific Discrepancy / Issue Reports (DIRs) for the Seismic and Environmental concerns as addressed in DAP-E-M-500 and DAP-E-EIC-503 respectively.
St3 MARY OF GENERIC TECHNICAL ISSUES Sunsnarization of the issues noted above has been completed in order to facilitate an integrated program response.
The Generic Technical Issues which result are listed below and are individually addressed within the appendices of this report.
ISSUE SUBJECT APPENDIX 1
Identification and classification 1
Requirements 2
Environmental Conditions and Requirements 2
3 Environmental Documentation 3
4 Seismic Documentation 4
5 Generic Regulatory Concerns 5
6 Maintenance and Surveillance 6
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V TEXAS UfILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECfRIC STATION I. INTRODLUfION The Equipment Qualification Program at Comanche Peak Steam Electric Station has been in effect for a ntnber of years and has recently been expanded to include a detailed review of all safety-related qualification requiremer.ts and documentation. This has been undertaken to ensure that the evolution of plant design requirements and industry criteria through the years of CPSES design and construction have been clearly documented and incorporated within the qualification documentation for all required equipment.
The intent of this expanded effort is to verify the qualification records for each equipnent item to ensure that current industry practices have been incorporated aryi are correctly documented.
In addition, it will also consolidate the EQ efforts that have been undertaken by several individual parties into program that foms the overall equir nent qualification basis for the entire plant. Such efforts as the Pump and Valve Operability review previously undertaken as a result of Post-TbiI requirements will be included in the overall EQ program.
An independent review was undertaken by TERA as part of the CPSES Design Adequacy Program to assess the state of the existing Equipnent Qualification Program and to identify the issues that require closure to ensure that an auditable and complete qualification program is in place.
This review is documented in two Issue Resolution Reports (IRRs) as DAP-E-M-500 AND DAP-E-EIC-503 dealing respectively with the Seismic and Environmental Qualification aspects of the program.
These two IRRs identified several specific design issues that require closure and which inturn lead to Generic Technical Issues. These issues have been previously presented in the Definition of Generic Technical Issues and based on the similarities that exist between the seismic arxi environmental issues, a grouping was completed into categories dealing with generic progransnatic items that include:
ISSUE SGJECT 1
Identification arxi classification Requirements 2
Environmental Conditions and Requirements 3
Environmental Doctmentation 4
Seismic Documentation 5
Generic Regulatory Concerns 6
Maintenance and Surveillance 1
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r This document addresses each of the above generic issues and describes the program that will resolve these issues. This program is designed to be comprehensive not only to respond to each issue previously identified but also to preclude future occurrence of similar issues. This will be accomplished by establishing the necessary interfaces and procedures to delineate the responsibilities and methodologies which will constitute the EQ Group's function at CPSES.
II. ISSUE RESOLLTION PROCESS In order to evaluate each of the concerns identified in DAP-E-M-500 and DAP-E-EIC-503 and to ensure that each issue is adequately addressed within the current EQ program, a thorough review of each IRR was completed. Following this
- review, the most recent EQ program procedures, project instructions and interfaces were reviewed to detennine if the issues have already been resolved or incorporated in the EQ program.
Additional revisions to Equ'ipment Qualification Program Developnent and Implementation (TNE-TD-IM-017) and Project Instructions have already been undertaken and/or identified to include changes resulting from the generic issues.
Specific technical or program issues identified in the individual DIRs, which have not already been incorporated into the EQ program are being isolated and appropriate changes are being made to the.
program to ensure that their resolution is appropriately considered.
'Ihe specific items identified in each DIR will be individually resolved by the appropriate lead contractor (e.g. Impell, Ebasco, SWEC).
III. REPORT CT:GANIZATION AND REVISION PRor ESS The body of this report describes the general approach taken to evaluate and resolve each cf the Generic Technical Issues identified. A description of the specific resolution of each Generic Technical Issue is contained within the appendices to this report; one appendix for each Generic Issue. Each appendix includes a summary of the issue background, Impell's understanding of the issue, the action plan to resolve the issue, a complete list of relevant documents reviewed by TERA, and Impell's implementation of the resolution.
IV. ABBREVIATIONS The following abbreviations have been used in this report:
CPSES: Comanche Peak Steam Electric Station DAP: Design Adequacy Program DIR: Discrepancy Issue Resolution EQ: Equipment Qualification E@IL: EQ Master List FSAR: Final Safety Analysis Report IRR:
Issue Resolution Report SWEC: Stone & Webster Engineering Corporation
'lVGCO: Texas Utilities Generation Company 2
<. REFERENCES 1.
Impe11 Task Description " Equipment Qualification Program Development and Implementation" 1NE-TD-IM-017.
3 2.
Comanche Peak Steam Electric Station Final Safety Analysis Report (Amendment 57 dated December 20, 1985).
3.
Impe11 EQ Program Completion Plan. Report NO. 09-0210-0057 Rev.A l
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TEXAS 17TILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELEC'IRIC STATION UNIT 1 GENERAL TECHNICAL ISSUE REPORT - EVALUATION AND RESOLITTION OF TERA EQUIPMENT QUALIFICATION ISSUE RESOLLTTION REPURT: DAP-E-EIC-503 (ENVIRONMENTAL) AND DAP-E-M-500 (SEISMIC) e APPENBIX 1 GENERIC TECHNICAL ISSUE:
IDENTIFICATION AND CLASSIFICATION REQUIREMENTS TERA GENERAL ISSLT CATEGORIES:
DAP-E-EIC-503 Issue 1 Documentation to demonstrate that all safety related equipment was identified.
DAP-E-M-500 Issue 1 Documentation to demonstrate that all safety related equipment was identified.
DAP-E-M-500 Issue 2 Clast.ification of safety related equipment as '-:eismic Category I, active or passive conponents and qualification requirements.
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APPENDIX 1 GENERIC TECHNICAL ISSUE: IDENTIFICATION AND CLASSIFICATION REQUIRDENTS
1.0 BACKGROUND
Impell perfomed a separate review as doctanented in the EQ Program completion plan (Report Ntsnber 09-0210-0057 Rev.A) of the Q-list (dated 08/04/86) to detemine its acceptability in establishing and documenting the identification of required equipnent in the EQ program at CPSES.
The review was performed to detennine whether the requirements of 10CFR50.49 (Environmental Qualification of Electrical Equipnent), FSAR, and G,eneral Design Criteria (GDC) 1, 2, 3,
14, and 30 (seismic qualification of electrical and mechanical equipment) were satisfied.
A single comprehensive document developed to specifically identify all safety-related equipment requiring environmental and/or seismic qualification does not presently exist. Although the Quality List contains a significant amount of useful data, it was not developed from an EQ standpoint.
It is a compilation of Q classified items as designated on system drawings and incorporated into system specification.
2.0 UNDERSTANDING OF THE ISSLT An acceptable EQ program requires the identification and classification of all equipnent requiring environmental and/or seismic qualification using pre-established criteria and a defined methodology.
3.0 ACTION PIAN TO RESOLVE THE ISSUE The resolution of this issue has already been initiated. An E@!L will be generated. The program to generate the E@fL includes a Lasis Report which will be a stand alone document containing the methodology and the basis for establishing the components requiring equipment qualification to meet regulatory requirements, licensing conunitanents and Al-2
current industry practices. The Basis Report is based on a review of the FSAR, applicable CPSES licensing commitments, CPSES System Design Basis Doctanents, and CPSES Emergency Operating Procedures.
The Safe Shutdown Logic Diagrams and the Essential Equipnent List generated by the Ebasco Systems Interaction Program Group are used to check the completeness of the Basis Report.
The EQML Basis Report is the cornerstone for a comprehensive review of engineering drawings of the plant (i.e., flow diagrams, vendor supplied subsystem diagrams, electrical one line dia:Jrams, elementaries, I & C diagrams and Schematics).
This review is conducted using controlled project instructions which delineate the criteria and methodology used to identify each equipment item requiring EQ doctanentation in accordance with applicable requirements.
Non-safety related equipnent whose failure cenditions could prevent satisfactory accomplishment of safety functions, 10CFR50.49 b(2), are included in the E@!L. Potential b(2) items fall into four categories:
(1) non-Safety interlocks (i.e., switches, relays, etc.)
found in safety related equipnent, without adequate physical and electrical separation (2) non-safety electrical loads which are serviced from safety buses without adequate isolation or analysis (3) non-safety control systems whose failure would have potential for interfering with the accomplishment of a safety function, and, (4) non-safety control room indicating devices whose failure would have potential for adversely affecting the performance of a plant operator involved in post accident mitigation / recovery.
These potential b(2) items are reviewed by performing failure modes and effects analysis to determine which of them could actually interfere with the successful performance of a safety function.
The equipnent segregated on this basis are identified as b(2) equipment and listed in the E@IL.
In addition, as part of the Master List effort, major subcomponents which require unique identification for EQ purposes are identified.
All tag numbers generated by this process are transmitted to TE with a reference drawing number. TE controls the assignment of tag numbers and initiates the appropriate changes to all plant design documents.
As the EGML items are identified other equipnent attributes are noted.
These attributes may include such items as equipment make and model, purchase specification number, location data, equipment serial ntsnber, a reference number identifying the environment, the required post-accident operation time, the qualification status of each item, active / passive classification, accuracy requirements, and appropriate references.
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This task is considered complete when all Seismic Category 1 and 10CFR50.49 Category b(1), b(2), and b(3) items have been identified on the E@fL, the appropriate related attributes are incorporated, and the EQ Master List is issued for general use.
4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY TERA Eighteen Qualification Documentation Packages NUREG-0588 10CER50.49 RG 1.89 RG 1.97 FSAR App.3A Tables 4-1 and 5-1 FSAR Table 7.5-7 Gibb's and Hill (Initial EQ Work)
IEEE 323-1974 GDC 1, 2, 4, 14, and 30 5.0 IMPLDIENTATION OF THE RESOLIJrION The development of the E@lb Basis Report has been initiated. This report will provide methodology, references, and results.
Impell Project Instruction IMT-EQ-01 " Equipment Qualification Master List" gives general instructions on the development of E@!L.
In Addition, the following Project Instructions are planned to detail the development of the E@IL and the detemination of b(2) equipnent and operating times.
IMT-EQ-01-1 "Developnent of Equipment Qualification Master List" DTT-EQ-01-2 "10CFR50.49(b). (2) Equipment Detemination" Dfr-EQ-01-4 " System Component Operating Time Detemination" Al-4
TEXAS UTILITIES GENERATING COMPANY CX)MANCHE PEAK STEAM ELECIRIC STATION UNIT 1 GENERAL TECHNICAL ISSUE REK)RT-EVALUATION ANT)
RESOLUTION OF TERA EQUIPMENT QUALIFICATION ISSUE RESOLUTION REPORTS: DAP-E-EIC-503 (ENVIRONMENTAL)
APPENDIX 2 J
r GENERIC TECHNICAL ISSUE:
ENVIRONMENTAL CONDITIONS AND REQUIREMENTS TERA GENERIC ISSUE CATEGORIES:
DAP-E-EIC-503 Issue 2 Calculations to detennine environmental conditions such as temperature.
DAP-E-EIC-503 Issue 3 Specification of EQ requirements such as test requirements and qualification parameters.
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APPENDIX 2 GENERIC TECHNICAL ISSUE: ENVIRONMENTAL CONDITIONS AND REQUIREMENTS 1.0 BACKGROUNT 4
Impell has conducted a separate review doctanented -in the EQ Program Completion Plan (Report No.
09-0210-0057 Rev.A) of the Equipment Qualification Program at CPSES with the objective of ensuring that the normal and accident environmental conditions used in the Equipment Qualification Program satisfy the applicable regulatory rules and requirements. The review was divided into two sections:
A.
Nonnal and Post-Accident radiation environments.
B.
Normal and Post-Accident Non-radiation environments:
- Pressure, Temperature, Relative Humidity
- Sulunergence (Flooding)
- Chemical Spray Effects Based on the above reviews, several observations have been made concerning the environmental qualification parameters defined for CPSES.
These observations are summarized into the following broad categories:
1.
There is no central document which ties together all of the environmental requirements and supporting calculations that have been perfonned for CPSES.
2.
Apparent inconsistencies and undefined a.3sumptions in the calculated values for the radiation and thermal-hydraulic parameters could not be readily resolved.
3.
It was not devious all environmental sources were considered in the evaluation of the overall environmental conditions.
As a result of this review, a general review of the environmental parameters used to define the qualified environments for each safety-related equipment was commissioned.
2.0 l'NDERSTANDING OF THE ISSUE In order to implement an effective corrective action plan to resolve the above deficiencies as well as those identified in DAP-E-EIC-503, the plan must ensure that the environmental parameters for equipment qualification comply with regulatory requirements and CPSES conunitments These requirements and commitments must be reviewed and doctanented in an auditable fonn which inturn will become the basis for detennining environmental parameters for an item.
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Any deficiencies in existing calculations and/or parameters can then be corrected.
We end product of this effort would be a Postulated Environments Design Basis Document which ties together all the environmental analyses / calculations and provides a complete set of environmental requirements for the EQ program.
3.0 ACTION PLAN TO RESOLVE THE ISSUE i
The resolution of this issue will be undertaken through the completion of four (4) major tasks which will include:
1.
Define the Normal and Post-Accident Radiological Conditions In this task SWEC reviews existing radiological evaluations and provides properly justified nomal and post-accident radiological conditions to Impell to be utilized in the CPSES EQ Program to sdtisfy-applicable regulatory rules and requirements.
j 2.
Define the Non Radiation Environmental Conditions l'
In this task EBASCO provides Impell with the nomal, abnomal and post-accident thermal-hydraulic environmental conditions (including l
temperature, pressure, chemical spray, flooding, and htaidity) to be utilized in the CPSES EQ Program to satisfy applicable regulatory q
rules and requirements.
i 3.
Update and Sumarize the EQ Documentation 4
i Using the above defined environmental conditions, the adequacy and completeness of the qualification doctmentation are reviewed. and verified for each equipment item identified on the EGHL. This data is then integrated into an auditable controlled qualification file that is sumarized using an EQ sumary fom to ensure the completeness and accuracy of the EQ evaluation ard its supporting documentation.
This task is further explained in Appendices 3, 4, 5, and 6.
4.
Update the TUGCO EQ Program The programatic elements of the TUGOO EQ Program are updated to include the Postulated Environments Design Basis Doctment (DBD-EQ-076), modifications to the EQ central file and an EQ Training Program.
The Postulated Environments DBD is organized by-area / room / zone and provides a sumary of the nomal, abnomal and post-accident environmental parameters to which equipment located in a particular area / room / zone must be qualified.
The Postulated Environments DBD is developed using existing environmental data and updating this data as information from tasks 1
&. 2 above becomes available.
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The central file of EQ documentation is defined and assembled to consolidate and package all relevant EQ infomation.
'It EQ Central File consists of new and existing docunents, such as Vendor Manuals, Specifications, Purchase Records, Qualification Data Packages, and other documents used in establishing the qualification of equipment.
Each document within the Central File is reviewed to ensure that it is an atxlitable record and will be maintained and controlled in such a manner.
The Central File is a repository of documents which outlines the history of Equipnent Qualification at CPSES, define the organization and use of the Central Files which contain the appropriate summaries, _ qualification records, and references necessary to document EQ at CPSES.
TE procedures are prepared under this task as necessary to govern the mait.tenance of the Central File as well as the EQ Group responsibilities and interfaces. This process includes upgrading existing TE procedurps and
" converting" Impell EQ Pro.iect Instructions to 'IUGCO procedures as required. Training is developed for key TE Program personnel to ensure that the EQ program is understood and remains effective.
4.0 LIST OF RELEVANT DOCLMENTS REVIEWED BY TERA Eighteen EQ Packages 10CFR50.49 NUEG 0588 IEEE 323-1974 Regulatory Guide 1.89 November 1974 CPSES FSAR Sections 3.11 and 3.11N 10 CFR50 Appendix A Significant Deficiency Analysis Report, SDAR CP-84-12, Equipment EQ after HELB Significant Deficiency Analysis Report, SDAR CP-85-144, 480V Switchgear Transfomer Cooling Qualification Significant Deficiency Analysis Report, SDAR CP-86-21, Qualification of Raychem Kit NPES02-01 IE Information Notice No. 85-39 5.0 DIPIRIENTATION OF THE RESO11 TION The development of the followine Project Instructions relating to work interfaces and to qualification documentation is planned to implement the action plan.
DTF-EQ-05
" Seismic & Environmental Qualification Documentation" Eff-EQ-06 "Equipnent Qualification Documentation Review Fom Revision" Dff-EQ-07
" Equipment Qualification Discr, mey Fom Approval" A2-4 i
Dfr-EQ-09-I " Instruction For Interfacing With Stone & Webster" Dfr-liq-09-2 " Instructions For EQ Document Control" Itfr-EQ-09-3 " Instructions For Interfacing With Engineering" I?fr-EQ-09-4 " Instructions For Interfacing With Operations" Dfr-EQ-09-5 " Instructions For Interfacing With Maintenance" Dfr-EQ-09-6 " Instructions For Interfacing With EBASCO" e
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TEXAS UTILITIES GENERATING 00MPANY COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 GENERAL TECHNICAL ISSUE REPORT-EVALUATION AND RESOLUTION OF TERA EQUIPMENT QUALIFICATION ISSUE
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RESOLUTION REPORTS: DAP-E-EIC-503 (ENVIRONMENTAL)
APPENDIX 3 GENERIC TECINICAL ISSUES:
ENVIRONNENTAL DOCLNENTATION
_ TERA GENERIC ISSUE CATEGORIES:
DAP-E-EIC-503 Issue 4 Qualification test and analysis doctanentation for EQ parameters, analytical justification, and test sequence.
DAP-E-EIC-503 Issue 5 Documented correlation between the installed equipnent and the corresponding EQ documentation, to document that test limitations have been reflected or verified in the installed condition, and to verify that the installed equipment is in the same condition as the tested equipnent.
DAP-E-EIC-503 Issue 6 Evaluate of qualification test anomalies.
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APPENDIX 3 GENERIC TECHNICAL ISSUES: ENVIRONMlWTAL DOCLMENfATION 1.0 BACKGROLND An independent review documented in the EQ Program Completion Plan (Report 4
No. 09-0210-0857 Rev.A) was conducted by Impell to assess the current state of the environmental qualification documentation packages.
Included in the review was the Vendor Test Reports, Checklists, Certificates of Confonnance and Certification of Qualification. Specific issues resulting from this review include:
Documenting similarity evaluations between the tested and installdl i
equipnent configurations.
Relationship between documentation and the equipment specified, Disposition of test anomalies referenced in the test reports, Inclusion of qualified life calculation within the packages, 1
The impact of varying electrical conditions on the operability of the equipment, The referencing of Equipment Tag numbers, and The auditability of the documentation.
2.0 LKDERSTANDING OF THE ISSUE In order to ensure that the environmental equipnent qualification is properly documented and clearly indicates that the equipment will perfonn its intended function at CPSES, the documentation including testing, analysis, evaluations, etc. must support the conclusion that the equipment is qualified. This conclusion must be based on docunented evidence that the specific installed equipment has been appropriately compared and evaluated as part of the test / analysis qualification program and that any test / analysis anomalies that may have occurred were appropriately resolved.
The documentation of these tests / analysis, its comparison to installed conditions and a definition of its installed life must be clearly documented and easily auditable.
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3.0 ACTION PIAN 'IO RESOLVE 'IEE ISSLT SWEC is performing a walkdown of selected equipment which requires seismic and/or environmental equipment qualification.
Other equipment requiring qualification will be justified or walked separately. The SWEC walkdown will result in the developnent of a walkdown checklist for each item to identify attributes critical to assessing the applicability of vendor supplied qualification documents. Examples of these attributes include electrical interfaces, mounting details, equipnent orientation, etc.
Impell is undertaking a comprehensive review of all environmental qualification reconis including walkdown checklists and updating these records into complete auditable Equipment Qualification Packages which will become part of the Central File described in Appendix 2.
This review and upgrade includes documentation of the make and model neber of,. each equipment item so that each item can be directly tied to its qualification documents by the plant identification number, as appropriate. 'Ihe review of qualification records also ensures that the perfonnance requirements of the supplied equipnent has been appropriately evaluated within the test / analysis documentation. This is completed by expanding the current checklist to include the assurance that all qualification provisions have been appropriately considered and will include such items as:
Similarity Analysis between the equipnent qualified in the test reports and installed equipment based on walkdown data and test report reviews.
Identification and evaluation when appropriate, of test Anomalies referenced in test reports for specific CPSES applications.
As a separate task, Environmental Qualification Design Basis Documents (DBDs) for Mechanical and Electric Equipment (DBD-EQ-030 and DBD-EQ-032) will be developed to include the definitions and methodologies for qualifying equipment and will establish the bases for justifying the qualification of mechanical and electric equipnent. The DBDs will include interface requirements and will establish the bases for spare and replacement parts for qualified equipnent.
4.0 LIST OF PELEVANT DOCLMENTS REVIEWED BY TERA Eighteen EQ Packages 10CFR50.49 NUREG 0588 RG 1.89 REV. 1 CPSES FSAR APPENT)IX 3A IE Infonnation Notice No. 85-39 5.0 IMPLEMEN' RATION OF THE RESOIUfION The developnent of Project Instructions relating to Qualification Documentation (listed in Appendix 2,
section 5.0) is planned to implement the action plan.
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TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECIRIC STATION UNIT 1 i
GENERAL TECHNICAL ISSUE REPORT-EVALUATION AND RESOLUTION OF TERA EQUIPMENT QUALIFICATION ISSUE RESOLUTION REPORT: DAP-E-M-500 (SEISMIC)
APPENDIX 4 l
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GENERIC TECHNICAL ISSUES:
SEISMIC DOCUMENTATION i
l t
TERA GENERIC ISSUE CATEGORIES:
DAP-E-M-500 Issue 3 Design documentation demonstrating compliance with qualification requirements including control of changes and inadequate interface control.
DAP-E-M-500 Issue 4 Evaluation or resolution of discrepancies in qualification test or analysis results, including justification of design changes and test anomalies.
DAP-E-M-500 Issue 5 Verification of as-built conditions, including results of as-built evaluations of interfaces systems and components, i
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APPENDIX 4 GENERIC TECHNICAL ISSUES: SEISMIC DOCONENTATION 1.0 BACKGROLN)
An independent review doctznented in the EQ Program Completion Plan (Report No. 09-0210-0057 Rev.A) was conducted by Impell to assess the status of the existing seismic EQ documentation with regard to regulatory requirements, CPSES licenstng commitments and current industry practices. Some of the issues resulting from this review include:
Comparing the tested / analyzed accelerations and/or. response spectr,a to that required Cross referencing qualification records a
Updating Seismic Specifications a
Validation of support /equipnent arrangement changes Equipnent classification or specification of requirements Requirements for pump and valve operability, and Resolution of test / analysis anomalies.
a Relationship between documentation and the equipment specified Documenting similarity evaluations between the tested and installed i
equipment configurations.
2.0 UNDERSTANDING THE ISSUE In order to ensure that seismic equipnent qualification is properly documented and clearly indicates. that the equipment will perfonn its intended function at CPSES, the documentation including testing, analysis, evaluations, etc. must support the conclusion that the equipnent is 3
qualified. This conclusion must be based on doctanented evidence that the specific installed equipment has been appropriately compared and evaluated as part of the test / analysis qualification program and that any test / analysis anomalies that may have occurred were appropriately resolved.
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The documentation of these tests / analysis, its comparison to installed conditions and a definition of its installed life must be clearly documented and easily auditable.
3.0 ACTION PIAN RESOLVE 'nIE ISSUE SWEC is performing a walkdown of selected equipment which requires seismic and/or environmental equipment qualification.
Other equipnent requiring qualification will be justified or walked separately. The SWEC walkdown will result in the developnent of a walkdown checklist for each item to identify attributes critical to assessing the applicability of vendor supplied qualification documents.
Examples of these attributes include electrical interfaces, adequate clearances, mounting details, and equipnent orientation. An interface will be maintained between the SWEC EQ Walkdown Group and the EQ Group to ensure that the criteria used for the wa}kdown supports the Equipment Qualification Program.
Impell is undertaking a general documentation review for each required equipn.ent item in order to ensure that the Seismic EQ doctznentation is complete, and is auditable to regulatory requirements, CPSES
- 1. 2nsing commitments, and current industry practices. This includes a review of the i
appropriate documentation such as, vendor design and qualification records,
{
walkdown checklists, purchase specification, supporting calculations as well as pertinent vendor correspondence dealing with qualification.
The piping analysis procedures are considered to ensure that valve modeling techniques are in accordance with Equipment Qualification regulatory requirements and applicable IEEE standards.
the EQ group interfaces with the Mechanical groups to ensure that values (Equipnent accelerations, applicable support loads, and nozzle loads) used in the Equipment Qualification Program are consistent and accurate.
This infonnation is integrated into Seismic Sunnnary Reports that contain a seismic review form (SQRS) for each tag number, references to all applicable qualification documentation and/or supplementary calculations, walkdown checklists and any identified discrepancies with their resolution.
Seismic qualification documentation is augmented with supplementary calculations and test reports as necessary to complete qualification and resolve deficiencies.
Replacement with qualified components is utilized if necessary to support qualification.
The File developed become the repository of all qualification information related to the equipment in each specification. The summary reports described above act as a " road map" to all required documentation. A similar summary is also prepared for NSSS equipment, referencing the appropriate NSSS Documents and their locaticn.
The number of the separate reports (and items of equipment) is based on the Equipnent Qualification Master List. The tag numbers associated with each piece is likewise on the EQ1L.
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'Ihe above EQ Documentation reviews are completed using project instructions which define the methodology, format and technical criteria to ensure that all qualification doctmentation is complete.
In addition all anomalies and design changes are appropriately resolved and doctmented.
A Design Basis Doctment (DBD-EQ-029) will be developed to provide the Design Bases for the Seismic Qualification of electric and mechanical equipment qualified to IEEE-323-1974 and to General Design Criteria (GDC) 1, 2, 3, 12, and 30. The DBD will include seismic floor response spectra for each location and will reference each calculation. The SSE, Half-SSE and their relation to equipment qualification will be defined. The DBD will include interfaces and will establish the qualification of active versus passive equipnent.
As a separate task, input will be provided to revise and upgraqe the seismic specification (SS-20) to ensure future equipnent purchases are made in accordance with current industry practices.
4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY TERA 10CFR50 Appendix A, General Design Criteria 2, 1983 R. G. 1.29 REV. 3 R. G. 1.61, October, 1973 R. G. 1.92, REV. 1 CPSES FSAR Section 3.10B CPSES FSAR Section 3.9B CPSES FSAR Section 3.7B IEEE 344-1975 Qualification Packages 5.0 IMPIEfENTATION OF RESOILTION The developnent of the following Project Instru,ctions is planned to implement the action plan.
IMr-EQ-04
" Seismic Conditions" INT-EQ-04-1 " Seismic Qualification of Mechanical Equipment" IMr-EQ-04-2 " Seismic Qualification of Electrical Equipment" INT-M-04-3 " Development of Seismic Test Plans" INT-BQ-04-4 "In-Situ Testing" INT-EQ-04-5 " Preparation of Equipment Stamary Fonns for Seismic EQ" INT-EQ-04-6 " Review & Approval of Vendor Documents for Seismic EQ" IMr-BQ-04-7 " Verification of As-Built loads on Equipment and Valves" INT-EQ-04-8 " Preparation of Seismic Qualification Packages" A4-4
TEXAS UTILITIES GENERATING 0]MPANY (XNANCHE PEAK STEAM ELECIRIC STATION UNIT 1 GENERAL TECHNICAL ISSUE REPORT-EVALUATION AND RESOLUTION OF TERA EQUIIt!ENT QUALIFICATION ISSUE RESOLUTION REPORTS: DAP-E-EIC-503 (ENVIRONMENTAL)
ANT) DAP-E-M-500 (SEISMIC)
APPENDIX 5 J
r GENERIC TECHNICAL ISSUE:
GENERIC REGULATORY CONCERNS TERA GENERIC ISSUE CATEGORY:
DAP-E-EIC-503 Issue 7 Documentation of the evaluation of Generic Regulatory concerns that were identified for certain equipment items such as for BIW cable, NAMOO limit switches, and ASCO solenoid valves.
AS-1
h APPENDIX 5 GENERIC ISSUE: GENERIC REGUL.ATORY CONCERNS
1.0 BACKGROUND
NRC guidance or action letters are processed by licensing and operations support personnel who coordinate their review and resolution process at CPSES.
The review conducted by Impell of the environmental qualification packages discussed in Appendices (2) and (3) identified that the EQ Data Packages do not docunent or reference resolution of IE Notices, Bulletins, and Circulars.
2.0 UNDERSTANT)ING OF THE ISSLT Regulatory concerns (e.g IE Notices, IE Bulletins, IE Circulars, and Generic' Letters) can impact the qualification of equipnent at CPSES.
A mechanism is required to track these items which affect Equipment Qualification and ensure that regulatory concerns are appropriately considered.
i 3.0 ACTION PLAN "IO RESOLVE THE ISSUE The equipment qualification packages described in Appendices (3) and (4) i j
include the resolution of regulatory concerns as part of the qualification process. A review will be conducted of all IE Notices, Bulletins, and Circulars from 1979 to the present to identify those which have a potential l
impact on the EQ program at CPSES. This review will be incorporated into the EQ Central File with a provision for maintaining the review activities for future NRC IE documents. Resolution of those items applicable to the CPSES EQ program will be incorporated into the individual qualification packages or handled generically as appropriate.
i 4.0 LIST OF RELEVANT DOCUMENTS REVIEWED BY TERA Eighteen EQ Packages 10CFR50.49 Section (j)
IE Infonnation Notice No. 85-39 I
AS-2 f
5.0 IMPIRENTATION OF BIE RESOLUTION The development of project instructions relating to Equipment Qualification -
Doctmentation (listed in Appendices (2) and (4), section 5.0) is planned to implement the action plan.
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TEXAS LTTILITIES GENERATING 00MPANY COMANCHE PEAK STEAM ELECIRIC STATION
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4 GENERAL TECHNICAL ISSUE REPORT-EVAIDATION AND RESOLlfrION OF TERA EQUIPMENT QUALIFICATION ISSUE RESOLLTTION REPORTS: DAP-E-EIC-503 (ENVIRONMENTAL)
AND DAP-E-M-500 (SEISMIC)
APPENDIX 6 e-GENERIC TECHNICAL ISSUE:
MAINTENANCE AND SURVEILIANCE TERA GENERIC ISSUE CATEGORY:
DAP-E-EIC-503 Issue 8 Verification that maintenance and surveillance requirements derived from EQ testing or vendor requirements have been addressed.
A6-1
r APPENDIX 6 GENERIC TECHNICAL ISSUE: MAINTENANCE AND SURVEILLANCE
1.0 BACKGROUND
During Imoell's review of the equipment qualification packages discussed in Appendices (2), ( 3 ) and ( 4 ) it was noted that the Equipment Qualification Smmary Foms contain a qualification contingency section which specifies the maintenance requirements which must be perfomed to maintain. the equipment in a qualified status.
It was determined during the review that not all of the maintenance requirements were adequately described on the summary forms. In addition, it was also noted that although these forms were issued to the maintenance group some of the specified EQ requirements were not being appropriately implemented.
2.0 LNDERSTANDING OF 1EE ISSUE In orxler to maintain the qualification of equipment, the maintenance requirements in the qualification documentation must be properly addresses.
One acceptable action plan to address maintenance requirements is one which:
1.
Identifies (either by list or by reference) and documents the proper maintenance requirements in the qualification documentation.
2.
Forwarxis these requirements to maintenance for implementation and trending.
3.
Provides for a feedback loop from maintenance to EQ on failures and trends for modification of EQ maintenance requirements.
3.0 ACTION PLAN TO RESOLVE THE ISSUE The EQ documentation discussed in Appendices 3, and 4 will specifically address maintenance requirements.
A revised form which specifies the maintenance intervals for the specific equipment item will be generated and forwarded to the maintenance group for implementation and feedback.
4.0 LIST OF RELEVANT DOCDIENTS REVIEWED BY TERA Eighteen (18) EQ Packages 10CFR50.49 (j)
Reg. Guide 189 Rev.1 Section c.5.d CPSES FSAR App. 3A Section 2.4 5.0 IMPLDfENTATION OF THE RESOLIJrION 1
The development of project instructions relating to Equipment Qualification Documentation (listed in Appendices (2) and (4), section 5.0) is planned to implement the action plan.
A6-2
.