ML20207P810

Rev 0 to Instrumentation & Control Generic Issue Rept, Comanche Peak Steam Electric Station

ML20207P810
Person / Time
Site:	Comanche Peak
Issue date:	01/05/1987
From:	Carty J, Stamm S, Weston W STONE & WEBSTER ENGINEERING CORP.
To:
Shared Package
ML20207P804	List: ML20207P810 TXX-6217, Forwards S&W Rev 0 to Instrumentation & Control Generic Issue Rept,Comanche Peak Steam Electric Station, for Resolution of Specific Design Issues Per Design Basis Consolidation Program
References
TASK-***, TASK-OR NUDOCS 8701200269
Download: ML20207P810 (16)

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I g TEXAS UTILITIES GENERATING CO.

COMANCHE PEAK STEAM ELECTRIC STATION i

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!I i INSTRUMENTATION AND CONTROL

I GENERIC ISSUE l

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Revision 0 January 5, 1987 TEXAS UTILITIES GENERATING COMPANY (TUGCO)

COMANCHE PEAK STEAM ELECTRIC STATION UllITS 1 AND 2 STONE & WEBSTER ENGINEERING CORPORATION'S INSTRUMENTATION AND CONTROL GENERIC ISSUE REPORT I

I Amst-W. C. Weston Chief Engineer Control Systems Division I

.'Carty I

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1 3]' ] Ten._ik j g S. L. Stamm l g Project Engineering Manager

~'ffo 1 I R. W. Ackley, Jf. Project Manager I lI l 6684-1634503-B2

l . Revision 0 E January 5, 1987 Table of Contents Page Title Page Table of Contents i Index of Instrumentation and Control Generic Issue Report 11

1.0 INTRODUCTION

1 2.0 SCOPE 1 3.0 CORRECTIVE ACTION METHODOLOGY 1 4.0 ORGANIZATION OF THE GENERIC ISSUE REPORT 3 Table 1 Instrumentation and Control Corrective Action Plans 4 j APPENDIX A - SETPOINT CALCULATIONS A-1 APPENDIX B - I&C SEPARATION AND ISOLATION B-1 I I I I lI l I 6684-1634503-B2 i I i

I . Revision 0 January 5, 1987 I INDEX OF INSTRUMENTATION AND CONTROL GENERIC ISSUE REPORT COMANCHE PEAK STEAM ELECTRIC STATION Interim Revision Date of Issue Document Title No. Issue Date Plan Generic Issue Report 0 01/05/87 Instrumentation and Control Appendix A Setpoint Calculations 0 01/05/87 Appendix B I&C Separation and Isolation 0 01/05/87 I I I I I i 1 lI 6684-1634503-B2 ii ) - - - -. ---- -. ..-.- . - ____ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ __ _ __

l I R;vizion 0 l Janusry 5, 1987  ; I INSTRUMENTATION AND CONTROL GENERIC ISSUE REPORT I I.0 INTRODUCTION Stone & Webster Engineering Corporation (SWEC) has been retained by Texas Utilities Generating Company (TUGCO) to develop and implement a Corrective Action Plan (CAP) for the Comanche Peak Steam Electric I Station (CPSES) Instrumentation and Control (I&C) systems and components in response to the Comanche Peak Response Team (CPRT) findings identified prior to the issuance of the final I&C Generic I Issue Report (GIR) and other identified findings and observations. The CPRT findings, known as Discrepancy Issue Reports (DIRs), have been identified by TERA Corporation, the third-party reviewer, and by I external sources. responding -to This GIR defines the methodology and procedures for these above design issues with the objective of demonstrating adequacy of plant I&C design relative to the Final Safety I Analysis Report (FSAR) and other licensing commitments. Both technical and programmatic requirements are addressed by this plan. In formulating this program, SWEC has reviewed the TERA DIRs pertinent I to I&C design, Issue Specific Action Plans (ISAPs), design issues raised by the Evaluation Research Corporation (ERC) review, Corrective Action Reports (CARS), Significant Deficiency Analysis Reports (SDARs), I Supplemental Safety Evaluation Reports (SSERs), and other similar reports. In conducting this review of issues, SWEC assumed that each issue, as written, was factual, complete and correct. No effort was made to ascertain the accuracy of each issue in order to quickly determine the magnitude of probable corrective action requirements. Subsequent reviews may determine that the number of issues may be reduced. This review has provided an indication of the types of I&C I design issues which this I&C GIR addresses. 2.0 SCOPE I The CAP to be implemented by SWEC consists of two individual corrective action plans identified in Table 1. These plans address all DIRs identified in Issue Resolution Reports (IRR) DAP-E-EIC-502 and 504 (except as noted in specific CAP). In addition other related DIRs, TRT Issue Specific Action Plans (ISAPs), and Quality of Construction (QOC) design issues will be incorporated into the individual plans where I applicable. Any I&C DIR not addressed by the GIR will be reviewed under the overall Design Verification Program. 3.0 CORRECTIVE ACTION METHODOLOGY The corrective action presented in this section will be performed in j g accordance with (1) the SWEC management plan for plant quality and (2) l 3 project procedures including the following: l l I

Revisien 0 January 5, 1987 I Project Procedure Number Title PP-004 Preparation, Review, and Approval of Design Basis Documents (DBDs) PP-005 Processing TNE Design Deviation Reports (TDDRs) PP-009 Preparation and Control of Manual and Computerized Calculations PP-018 Design Verification PP-029 Review and Update of CPSES Design Calculations PP-031 Configuration Control - Preparation and Issue of Design Change Packages (DCPs) Associated with CAPS PP-038 Calculation Validation Procedure PP-046 Corrective Action Plan Interface The corrective action methodology will be as follows: 3.1 The FSAR and other licensing commitments will be reviewed for the I Instrumentation and Control design criteria. 3.2 Based on the criteria review and review of other pertinent I&C I documents such as standards, calculations, and specifications, the DBDs will be developed. Additionally, there will be an ongoing review of the I&C design basis during the implementation of the corrective action plans and the Design Verification Program. 3.3 Instrumentation and Control design documents applicable to the IRRs listed below will be reviewed to ensure consistency with the plant I licensing design basis in regard to instrument setpoint calculations (reference IRR DAP-E-EIC-502) and instrument and tubing separation (reference IRR DAP-E-EIC-504). Any inconsistencies identified will be corrected. Design documents will include, as a minimum: Flow Diagrams I Instrumentation and Control Diagrams Elementary Diagrams Wiring Diagrams Instrument Location Drawings and Tabulation Sheets Vendor Drawings Calculations Test Reports Equipment and Installation Specifications 3.4 This evaluation will consider the individual and collective l significance of other design review activities, such as Nonconformance 1 6684-1634503-B2 2

Revision 0 January 5, 1987 Reports (NCRs), TDDRs, and third party observations, as they pertain to the identified CPRT issues. 3.5 After review and finalization of the detailed design requirements necessary to resolve each CPRT issue, SWEC will issue a report describing all activities which when collectively applied to the CPSE3 plant configuration will close the issue. 3.6 SWEC will interface with other design organizations to exchange information on DIJs, results of SWEC reviews (3.1 above), and planned I corrective actions in accordance with project procedures. organizations with which SWEC will interface include TUGCO, EBASCO, The ERC, and TERA. Others will be included as required. 3.7 Each corrective action plan addresses a specific area of concern. The final TERA IRRs, NCRs, TDDRs, and other documents will be reviewed to I ensure that this GIR considers each finding relative to the issues identified in the above IRRs. 4.0 ORGANIZATION OF THE GENERIC ISSUE REPORT The main body of this report contains an overview of the scope and corrective action methodology. Table 1 lists the I&C corrective action plans and the appendices present the individual corrective action plans. I I I l l lI l l I 6684-1634503-B2 3

l Revision 0 January 5, 1987

 'E                                                 TABLE 1 INSTRUMENTATION AND CONTROL CORRECTIVE ACTION PLANS APPENDIX A - Setpoint Calculations APPENDIX B - I&C Separation and Isolation l

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i Revicien 0 Janu2ry 5, 1987 I APPENDIX A - CORRECTIVE ACTION PLAN SETPOINT CALCULATIONS l

1.0 BACKGROUND

I TERA reviewed selected setpoint calculations for the instrumentation and control systems with the intent of identifying any calculation  ; I deficiencies. Numerous Discrepancy Issue Reports (DIRs) were generated against the calculations. categorized as follows: The calculation discrepancies can be l

1. The absence of a documented and verifiable design basis

2. Technical and methodology errors in calculations

3. Inconsistencies between calculations, drawings, specifications, and/or Design Change Authorizations

4. Typographical errors in calculations

5. Incorrect, missing, or unverified input data

6. Calculations not consistent with licensine, commitments I 7. Calculations conditions.

not accounting for environmental or upset I The issues with the calculations can be grouped into the following categories:

1. Calculation missing

2. Calculation input data missing, incorrect, or unrelated

3. Calculation setpoint impractical

4. Calculation not complying with licensing commitments

5. Calculation based on wrong instrument

6. Calculation not required.

The DIRs are listed and described in Attachment A-1. 2.0 SWEC'S UNDERSTANDING OF THE ISSUES The setpoint calculations for the instrumentation and control systems contain inadequacies, are inconsistent when compared to other documents I and do not consistently meet licensing commitments. Design inputs, sources of input, and assumptions for these calculations are either inadequately documented or unavailable. ' l 6684-1634503-B2 A-1 l t

5 I . Rivizien 0 Jtnuary 5, 1987 Calculations for the instrumentation and control systems must be reviewed and updated to ensure they reflect confirmed and controlled design inputs and assumptions, are properly classified as to safety I significance, are technically licensing commitments'. correct, and are consistent with I 3.0 SWEC ACTION PLAN TO RESOLVE THE ISSUES 3.1 Review setpoint calculations for the safety related instrumentation and control systems and interfaces for consistency with design Lasis I documents (DBDs) and design documents with respect to technical adequacy. This review shall be documented using the following steps. 3.1.1 Proj ect Procedure PP-009 contains acceptance criteria for review and validation of existing engineering and design calculations. Determination will be made as to the need for supplementing existing calculations and/or preparation of new toluulacions. 3.1.2 Permanent plant drawings and related unincarporated Design Change Authorizations (DCAs), DBDs, and specifications will be used to ensure complete reviews in accordance with the above pu,cedure. The review for technical adequt.cy will address calculation inputs, operational limits, assumptions, methodology, accuracy, outputs, and conclusions. Input will be reviewed I for applicability, accuracy, and source. Methodology will be reviewed for compliance with licensing commitments and to ensure that it is appropriate for the calculation's I objectives. Outputs will be reviewed to confirm that they are reasonable in consideration of the inputs, methodology, and objective of the calculation. The review will verify that calculation assumptions, inputs, and references are correct and current, the sources are uniquely identified, and any inputs that require future I confirmation have been identified. (Note: Any input not deemed final will be marked " Confirmation Required.") 3.1.3 A calculation index will be developed to provide documentation of status (e.g., Confirmation Required, Superseded, Supplemented by, etc). 3.1.4 Where necessary, field walkdowns will be performed to verify as-built conditions and nameplate data. 3.2 Based on the review of the DIRs and calculations covered by Section 3.1, the documents will be sorted into the following categories in order to determine the magnitude of corrective action required, and to I ensure that the necessary calculations have been prepared and completed to support the design:

• Valid calculations (no additional work required)

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• Calculations requiring supplementing
• Calculations requiring confirmation (existing calculation to be replaced by a confirmation calculation with supporting controlled documentation as required)
• New calculation required (no calculation presently exists or existing calculation to be voided and superseded by new calculation).

3.3 Modifications of existing hardware (including recalibration) or addition of new hardware will be identified, if required. I 3.4 Closeout of calculation input, identified under Section 3.1 as requiring confirmation, shall be by revision to the calculation to identify final source, addition of supporting documentation such as calculation attachments, and revision of analysis / design where necessary or by other means as provided in Project Procedures.

4.0 REFERENCES

4.1 Comanche Peak Design Adequacy Program, Issue / Discrepancy List, dated (later). 4.2 IRR DAP-E-EIC-502, Instrument Setpcint Calculations 4.3 DBD-EE-037, B0P Safety-Related Set %oints 5.0 CLOSURE I 5.1 The completed setpoint calculations from the instrumentation and control corrective action plan will be the permanent documents of record for the plant and will provide assurance of the technical adequacy of the design of the instrumentation and control systems in accordance with CPSES licensing commitments. 5.2 A report will be prepared addressing the extcrnal source, and self I initiated concerns resolved as a result of the corrective action plan. I I I

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R vision 0 3 Janusry 5, 1987 ATTACHMENT A-1 DIRs written against setpoint calculations are classified into six (6) general categories as described and listed in this attachment. Changes to this classification may be required as additional DIRs are issued or existing ones are resolved.

1. Calculation missing DIR D-0375 D-0734

• Safety-related instrument calculation missing
• No calculations for Diesel Generator Setpoints

2. Calculation methodology incorrect and/or input data missing, incorrect, or unrelated including inconsistencies with Regulatory Guide 1.105 DIR D-0868 D-0875 D-0899 D-0869 D-0876 D-0900 D-0870 D-0877 D-0966 I D-0873 D-0898 D-0994 D-0996

• Calibration method not related to process design
• Instrument range not included for certain items
• Incorrect Westinghouse data used in setpoint calculation
• Use of incorrect data
• Incorrect model numbers and loop drawings
• Error in setpoint calculation input
• Misstatement of safety limit in setpoint calculation
• Omissions of information in setpoint calculations i
• Setpoint calculation based on wrong flow element accuracy
• Flow setpoint calculation input
• Accident effects not considered in setpoint calculations I
• Setpoint calculation based on wrong instrument range
• Tank dimensions not verified for setpoint

3. Calculation setpoint impractical 6684A-1634503-B2 A-4

            -                                                        Revision 0 January 5, 1987 DIR D-0874

• Impractical alarm setpoint

4. Calculation not complying with Regulatory Guide 1.105 DIR D-0897 D-0995

• Noncompliance with Regulatory Guide
• Installation details not referenced or verified

5. Calculation based on wrong instrument DIR D-0998

• Setpoint calculation based on wrong instrument

6. Calculation not required DIR D-0997 Setpoint function deleted from control diagram I

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APPENDIX B - CORRECTIVE ACTION PIAN I&C SEPARATION AND ISOLATION I

1.0 BACKGROUND

1.1 TERA reviewed the physical independence of the redundant Instrumenta-tion and Control (I&C) systems for compliance with IEEE 384. Two DIRs were generated relating to I&C separation violations. l N 1.2 The CPRT has issued an Issue Specific Action Plan (ISAP) addressing a similar concern. 1.3 Attachment B-1 lists and summarizes the DIRs and ISAP by category. 1.4 IEEE 384 provides a design basis to ensure the physical independence of I&C equipment and systems. Deviations from the requirements of IEEE 384 may be established by analysis based on test. Such analysis must be submitted as part of FSAR. 2.0 SWEC'S UNDERSTANDING OF THE ISSUE I Separation related DIRs and associated ISAP findings that have been identified potentially to have inadequate criteria (i.e., criteria is not sufficiently detailed) or contain violations of existing criteria must be reviewed and analyzed. The separation criteria will be revised I and/or updated :o ensure adequate detail and compliance to current licensing commitments. I 3.0 SWEC ACTION PLAN TO RESOLVE THE ISSUES 3.1 Review of Existing Separation Criteria A review of existing criteria (installation specifications, installation drawings, etc) will be conducted to determine whether or not the criteria (1) reflect current licensing commitments and (2) provide adequate and sufficient detail. 3.2 Review of Implementation of Existing Separation Criteria Implementat' ion of the existing separation program will be reviewed for:

• Adequate separation of redundant sensor and sensor to process connections
• Adequate separation of safety-related instruments i
• Adequate separation of safety-related sensing and control I tubing
• Identification of separation barriers for instruments and

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• Implementation of procedures / criteria.

As-built I&C configurations will be compared with existing separation criteria to establish the extent of any discrepancies. In addition, each DIR and ISAP will be resolved to close the issue. I Where sensor and sensor to process connections do not agree to the criteria as stated in IEEE 384, or where other deviations occur, the technical adequacy of supporting analysis will be reviewed. 3.3 Identification of Separation Issues Based on the results of the reviews discussed in Sections 3.1 and 3.2, I separation issues not addressed or addressed without supporting analysis identified. or without adequate technical justification will be 3.4 Resolution of Separation Issues After determination of the safety significance, each identified separation issue will be resolved by providing adequate technical justification based upon analysis and/or test as warranted, by providing barriers, or by relocation of affected components. Separation criteria and associated documents will be revised based upon resolved separation issues.

4.0 REFERENCES

4.1 Comanche Peak Design Adequacy Program, Issue / Discrepancy List, dated (later). 4.2 IRR DAP-E-EIC-504, Electrical Separation (Inadequate Sensor / Tap Separation Requirements Only) 4.3 DBD-EE-035, Instrument Installation 5.0 CLOSURE A report will be prepared addressing external source and self initiated concerns resolved as a result of the corrective action plan. This effort will result in finalized criteria which will be used to maintain physical separation of the redundant I&C systems throughout the life of the plant. l 6684B-1634503-B2 B-2 l

E Revision o l 3 January 5, 1987 l t l W ATTACHMENT B-1 DIRs and the ISAP written against I&C Separation and Isolation are classified in the general category as described and listed in this attachment. Changes to this classification may be required as additional DIRs are issued or existing ones are resolved.

1. Separation Violations DIR D-1855 D-1857 ISAP VII.c

• Separation problems with instrument installation.
• Lack of instrument separation criteria.
• Redundant tubing separation violation.

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