ML20238F049
| ML20238F049 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/08/1987 |
| From: | Benecchi A, Twigg R, Zappile C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20238F024 | List: |
| References | |
| NUDOCS 8709150358 | |
| Download: ML20238F049 (91) | |
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I ENGINEERING ASSURANCE PROGRAM ENGINEERING FUNCTIONAL EVALUATION l COMANCHE PEAK STEAM ELECTRIC STATION I REVISION 3 TU EL'CTRIC September 9, 1987 ag8J A.JfBenecchi Evaluation Team Leader (Operating Plant Design Control) Cdl R..W. Twigg, JQ // / C.C. 7/appfle / Evaluation Team reader Program Manager (Design Completion) l W.M. E'ifert' Chief Engineer Engineer Assurance 8709150358 870908 PDR ADOCK 05000445 A PDR 87-EA-047/EA306
Record ~of Revision' l
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'Rev. Date .Pages'Affected-5/19/87 ' Original Issue 1 -5/29/87 Title Page, rr,'l-1, 2-1, 3-1, 3-2, 4.1-1, 4.1-2, 4'.1-10 thru 13, 4.1-17,.4.1-23, 4.1-29, 4.1-30, 4.1-32, 4.1-44, Attachment i 2 .7/31/87 Title page, rr,' Table of contents, 2-1, 1, 3-2, 4.3-1 thru 4.3-5, 4.4-l'thru a 4.4-4,L5-1, 6-1,17-1, 8-1
' NOTE: . Margin change bars have not been used in Sections'4.3 and'4.4 due to the extent of reorganization and/or revision of contents. 4 91 j 3 9/8/87 Title page, rri 1-1, 2-1, 3-1, 3-2, 4.1-1, 4.1-2, 4.1-7, 4.1-12, 4,.1-1$,
4.1-16,'4.1-20 thru 4.1-22, 4 1-31, 4.1-34, 4.1-37 thru 4.1-40, 4.1-46, 5- 1 l' 1' 87-EA-047/EA306 rr E _. _. - - . _ - - - - - - . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
Table of Contents Page, _ 1.0 Introduction 1 2.0 Background 2-1 , 1 3.0 Overall Scope and Approach 3-1 to 3-2 4.0 Evaluation Modules 4-1 4.1 Design Completion Activities 4.1-1 to 4.1 -55 I 4.2 Design Data Utilization - Testing 4.2-1 to 4.2-4 4.3 Design Data Utilization - Maintenance and Operations 4.3-1 to 4.3-5 l 4.4 Operating Plant Design Control 4.4-1 to 4.4-8 5.0 Evaluation Team 5-1 6.0 Preparation 6-1 7.0 Performance 7-1 8.0 Reporting 8-1 9.0 Schedule 9-1 Attachments
- 1. Schedule
- 2. Generation of Action Items
- 3. Guidance for Production Support
- 4. Site Walkdown Guidance for Design Module i
1 87-EA-047/EA306
1.0 INTRODUCTION
This plan describes the four part program for performance of an independent evaluation to provide additional assurance of the technical adequacy and the implementation of the Corrective Action Program (CAP) l for Comanche Peak Steam Electric Station (CPSES), ano to assess TU Electric programs for the control of engineering activities during plant operations to assure that the design basis is maintained. The technical evaluation of the validated design consists of a vertical in-depth technical- evaluation of representative portions of the Containment Spray and Control Room Area HVAC systems, the associated electrical and control systems, and the Safeguards Building. I 87-EA-047/EA306 1-1 J l
r 1 2.0 BACKCROUND' l
' TU'. Electric initiated the Comanche' Peak Response Team ,(CPRT) to
' investigate and evaluate both' design-related and construction /QA
- related issues raised by external sources.
TU Electric. evaluated.the early results coming out of the CPRT. program
. and initiated a comprehensive Corrective Action Program (CAP). The CAP
- includes a complete design and hardware validation program of the i- safety-related and selected non-safety related portions.of CPSES (with exception of .the' NSSS System and vendor hardware design for which the interface is being validated). The CAP provides a planned, integrated resolution of identified problems rather than. attempting . to resolve each issue individually, and' assures that all. issues are appropriately addressed. TU Electric contracted with industry recognized architect -
engineering firms', Stone & Webster Engineering Corporation (SWEC), EBASCO, and IMPELL, to conduct'the CAP. To overview these ongoing activities TU Electric is establishing an evaluation program which will supplement the TU Electric QA Program.- [- The Program will utilize indepth auditing techniques and provide additional confidence that corrective actions for existing work and the preventive actions for new . work are ef fectively implemented. The-program will assess compliance with licensing requirements, evaluate the technical adequacy .of the design, and verify that the validated design is ref3 ected 'in . the physical plant. This evaluation will provide the basis for un overall conclusion concerning the adequacy and implementation of the corrective action process. In addition, the program will evaluate the utilization of engineering data in the testing. . operation and maintenance organizations and the completeness of the engineering procedural system to support plant operations. The Program is being modeled af ter the Stone and Webster Engineering Corporation (SWEC) independent technical audit program. The SWEC indepth technical audit program was accepted by the NRC as an alternative to the Integrated Design Inspection (IDI) or Independent Design Verification Program (IDVP) approach on Millstone Point Unit 3, I Nine Mile Point Nuclear Station Unit 2, and Beaver Valley Power Station Unit 2.. To conduct the program, TU Electric is assembling a joint TU Electric contractor team of senior engineers and specialists under the direction of SWEC, Engineering Assurance Division. The team shall be composed of individuals who are independent of CPSES activities. g EA-047/EA306 2-1
L s 3.0 OVERALL SCOPE'AND APPROACH
'.The purpose of this Program is to. perform an independent evaluation to provide additional assurance of the technical adequacy and the implementation of-the Corrective Action Program (CAP) for CPSES and to-assess TU Electric programs for the control of engineering activities
. during plant operations to assure that the design basis is maintained.
The program shall be accomplished by.one integrated team to assure that the ints Maces between the various corrective action design
- contractors, and- testing, maintenance and operations ' organizations are addressed,- and. that the evaluation represents a comprehensive evaluation of the design from the, licensing commitment ' to operations.
The effort is divided into the following four discrete modules: l o Design Completion Activities o Design Data Utilization - Testing o Design Data Utilization - Maintenance and Operations o Operating Plant Design Control The evaluation shall (with the exception.of the Operating Plant Design Control module) consist' of a vertical indepth technical. evaluation of portions of safety related systems that have gone through the corrective action validation process. The evaluatinn will include j electrical, structural and fluid systems and related activities, The representative samples shall , be based on Design . Validation Packages (DVPs') from each discipline of corrective action design contractors. The evaluation will extend from the licensing commitments (FSAR, etc.) ~l through the chain of design to the utilization of data within the tosring, . operations, and maintenance organizations. The results of this technical review will reflect on the adequacy and implementation of the Corrective Action Program. The Operating Pitnt Design Control module evaluation will consist of a review of TU Electric Engineering and Construction procedures against l the criteria defined in this evaluation plan. The results of this review will disclose the completeness of the procedural system for supporting plant operations. i
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I I 87-EA-047/EA306 3-1 i a _ _ _ _ _ _ _ _ _ _ _ . _ _ _ j
l l SAMPLE' SELECTION
. The criteria for system selection shall include:
o . Performs safety related functions o Includes both balance 'o f plant and NSSS design responsibilities o Contains. various types of components. and is. thereby representative of other systems l' -o Interfaces with other systems o Has different modes of_ operations Selection. of the sample of documents / hardware and attributes for-evaluation will' be based on a review to determine those activities that are representative of problems identified by the CPRT reviews, known
' industry problems and that -are representative of. the- activities performed by each corrective action design contractor.
The '_ Operating' Plant Design Control module review will be limited to those;ECE procedures directly supporting the engineering activities and products required to support operations. The' scope and approach of the individual modules is addressed in sections'4.1 through 4.4. ) 87-EA-047/EA306 3-2
i j .- l: 4.0 EVALUATION MODULES Sections 4.1 through 4.4 describe the four modules of the Engineering L. Functional Evaluation. l l The Design Completion module, Section 4.1, is considered the lead module for Sections 4.2 and 4.3 because the baseline data needed for . these sections is developed in Section 4.1. l The Operating Plant Design Control module, section 4.4, will be performed independent of the other modules because of the procedural nature of the review. 87-EA-047/EA306 4-1
-4.1 DESIGN' COMPLETION ACTIVITIES PURPOSE' ~The purpose of this module is to perform an in-depth technical q evaluation of the adequacy and implementation of the design corrective l (
action activities' performed by the corrective action design { I contractors. l SCOPE AND APPROACH ~
)
This module will be implemented by evaluating representative Design Basis Documents (DBDs) and Design Validation Packages (DVPs) centered around the Containment Spray and Control Room Area HVAC Systems, the
-associated electrical and control systems, and the Safeguardts Building.
The evaluation will start.with the accumulation of baseline information-
. which describes the system's design and licensing bases. The . evaluation will determine if:
o The design is consistent with and supports the FSAR and other licensing commitments, including system function, compliance with documents committed to in the FSAR and compliance with valid design practices, design basis documents and NSSS/ vendor requirements and criteria. o Technically adequate calculations are available to support the design. Diagrams, specifications, drawings and vendor documents are technically complete and consistent with each other. o Design: changes and modifications are technically adequate and are contsistent with licensing commitments. o Implementation of resolutions to known industry problems are technically adequate. o Documentation packages are technically adequate, verifiable and support the as-constructed condition. o Inter and intra discipline interfaces are adequate. I o Post construction hardware validations adequately assess the as-installed condition. Although primary emphasis will be placed on the design and engineering of- safety systems, the areas of functional testing and system operations will be reviewed in conjunction with Modules 4.2 and 4.3 to assess the utilization of engineering data. , i Preparation for the evaluation will be done in two stages. The first ! l stage will primarily involve identification of the design basis and l . FSAR requirements for the Design Validatiot. Packages (DVPs) and systems selected for review, any TU Electric concerns to be included in the scope of the evaluation, and finalization of team members based on l l l l 87-EA-047/EA306 4.1-1 L
F f;.Y l t agreed upon scope. The team will be composed of experienced discipline personnel. The second stage of preparation'will include indoctrination and orientation of team members; accumulation of design, licensing baseline and modification information; development, by team members, of the detail checklists (Review Plans) . to be used during the ' evaluation; review and approval of the Review Plans by the ETeam . Leader . and
; finalization of the Evaluation Plan with the Program Manager approval.
The Program will ~ evaluate _ th'e effectiveness of the Project's design l .j validation programs and production support activities by assessing the technical adequacy of design document packages that have been completed and validated under these programs.' These reviews will be similar 'in nature to NRC IDI and Engineering Assurance Program (EAP) audits performed' with NRC overview.- The evaluations will address activities from all Corrective Action Program lead design contractors. l The technical design evaluations will be performed in three phases. The first phase'.will include evaluations of a representative sample of
~
Design Validation Packages (DVPs) for discrete design activities,'such ,y as the D.C. Electrical' System, Piping Design and Installation j Specifications, Containment Liner and Penetrations. The evaluation will extend from the' licensing commitments to the installation document and/or to the interface ; document with another discipline or design agency. . Design data will be checked to assure that all interface information has been transmitted to the appropriate discipline. (The ..' evaluation of the use of the transmitted data will be included . in the
. ['
second phase of the review.) These evaluations will be performed en a . continuous basis as selected DVPs are completed. Although selected reviews will be performed to assure. that previously identified design problems (e.g., Generic Issues Reports (GIRs)) have been addressed, the emphasis will be. placed on the technical adequacy of the validated design. l ! The second phase will be performed near the end of the Design Basis Consolidation Program (DBCP) at the document finalization stage of the Project and shall be system oriented. The system selection and scope of the final evaluation will be integrated with the previous technical evaluations in order to perform a complete evaluation of the design process for the validated design. Particular emphasis shall be placed on the interface between disciplines and other design organizations to assure that the interface material has been appropriately utilized by the receiving discipline. The third phase will consist of a summary analysis of all technical evaluation findings identified during this design evaluation. The findings will be summarized and grouped to determine the overall significance and impact (when reviewed as a composite) on the adequacy and implementation of the post CPRT design process. I l 4 87-EA-047/EA306 4.1-2 ,
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k 4, T In. ' addition to the validation reviews, the team will evaluate the technical adequacy. of production support. activities. Production support includes activities, such as, the preparation of Design Change
-. 0 tr Authorizations (DCAs) to addrese licensing changes, revised design inputs and field changes and the dispositions of Noaconformance Reports (NCRs) and Test Deficiency Reports (TDEs). Attachment 3 provides guidance for production support.
The team will perform site walkdowns for the purpose of facilitating i- and expediting the s'ystem and DVP reviews and for the detail review of specific programs. Attachment 4 provides guidance for site walkdowns. y e
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4.1.1 . Subject Scope and Approach '- General Thel scope' and' approaches
~
by subject, discussed in the following
' sections, describe - the ' specific activities to be performed during the evaluation.- The.Eng1neering~ Functional Evaluation concentrates'on the
. Containment . Spray- ~ System (CT) and the supporting electrical power.
sources. - control systems . and ;the~ Safeguards Building which houses and '
. provides ; support for the system. In caddition, the Control Room Area Ventilation System, which lprovides habitability for the Control' Room, is'also inc3uded in the evaluation.
.The; Subject Breakdown . Table summarizes the . breakdown of . subject F _ activities, the. extent of the evaluation, and the organization H responsible for the design.
SUBJECT BREAKDOWN TABLE EFE In-Depth Design Responsible Subject Evaluation Interfaces Only Organization Electrical X SWEC-CAP
' Equipment Qualification
- Environmental X IMPELL
- Seismic X IMPELL Engineering Mechanics Small-Bore Piping X SWEC-PSE Stress X SWEC-PSE Supports. X SWEC-PSE
- Large Bore Piping X SWEC-PSE
- Mechanical Analysis X SWEC-CAP System' Interaction X EBASCO (Hazards)
HVAC
- System X EBASCO
- Supports X EBASCO Instrumentation & Controls X SWEC-CAP Power
- Systems (Mechanical X SWEC-CAP Fluids)
- Safeguards X- SWEC-CAP
- Materials' X SWEC-CAP
- Radiation Protection X SWEC-CAP Structural
, - Building System X SWEC-CAP
- CableLTray Support X EBASCO
- Conduit Support X EBASC0/IMPELL 87-EA-047/EA306 4.1-4
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lS s 4 .1. 2 ' Electrical <-. g /. i' General.. , .f . .e y >,. Y The - Engineering . Functional- Evaluation of the electrical design aCd ,7 A\
- Comanche Peak Steam Electrir ,.,St4 tion includes the electrically diiven; j k components : and , electricalidedgn' arpects of the Containment Spray '/ y[ - i L <Controit Rel M n HVAC Systems and.their i supportin's electrical' systems. ?gnd4L -
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. Containment . Spray and Control Room HVAC Systems,,were seleeted by f'
. Vli Power I and HVAC review teams - for primary , syst ems evaluatimy at #
g, al] ? aspects of these . systems are inclur'ed j in the
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. . ,4 i b 4-The(supporting'elecr[calsystemsinclude: 7 g
' , 4 g a s -J' Preferred ~ Power System -
;0 asth /PowerSystem' ' ,' x i (6.9 YI Medium Voltage System '
] .l A80 V and 120 Vac Electrica). Power System '
Statis Uninterruptible Power Supply System y j , j
/' O ' I D Iyntem '
Ca le' and. Rac ntay . System ')[ y ' t ib , The ev',luatien a of the Containment Spray and - Centdol Room HVAC Systems L includes :'a t [etailed ? review of ' the electrical cdtponents and /<!esign- , aspactsL's#cific to :those- systems. The: suppgrting ,eystens are < eva1U4ted/t'o assurettsat=.the required amounts of poweri of thw .
'l appropria'te quality are available to support the' Corfiinment Sprc,y ards # I Control.RoomHVACsystemyunderplantoperatingconditions.' j,y [ ,I 3*.
In' heneral, the= electriddl evaluation is conducted using the following 1 .1 / outlinet' '( $ a o Perti,nent :F3AR sections and othet#Ticensing documents against
. - .6 i[ '7" approprieO 'e'ei;ulatory guide cowrit'ments.- . ,, i v -
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- }o . Applicat %,d, n tign criteria to assure technical adequacy and i consistenepwithlicensingcommitments.
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'7- Inputy tre phe . design process to assure inputs are consistent i with commitments.
, 0 t a I 'i j i i Computer, programs used to verify program validation and use o'
,- within the limits of.the programs.
T o Calculations . to assure technical adequacy and consistency with licensing connitments. 4 , [' o . Specifications and . vendor documents to assure consistency with design requirements. 1 l f ~
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h o , Design and. construction drawings to assure consistency with
-design' requirements. }fs
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.o ' Chang 6 documents-(DCAs) Land'Non-Conformance Reports (NCRs) to k[ M% ? -
assure . resolutions are . technically adequate ? and consistent hj 3 'with" licensing commitments. v 79 % &-~ ' o, Design ~ documents to .. assure that resolutions to previously
. identified concerns are adequately implemented.:
aI Lo _ V'alidated design documents are' consistent with the i y - 3 .
'as-constructed condition..
t . t y .g Specific Review Activities }% I The following specific.. items are considered in the evaluation. s: .1. ThC electrical one-lines. to assure that the. required quality of 3 power '.is provided for plant. systems, taking into. account, independence, separation, single failure, and design basis events.
- 2. Load' flow' studies to. assure that equipment is adequately sized to meet plant. operating conditions. Equipment types . evaluated include: 1 4
Preferred power source ! Onsite. power source- i 1 s o .. 31esel generator. b eteries and charger
~
s Inverter. J
' ; Transformer
, n4 cUnit' Substation j 91 Switchgear 11 MCC ,!
Panel - Cable' q Large motor 'j
..> ce r 4 Motor operated valve j 2 3 3 6 .
y The voltage profiles of the systems are also examined to assure {
. * ,.e that 'the design _ requirements are met under plant operating 'j conditions including: j r *
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,O ~F Offsite voltage swings Onsite' load' changes
'i .DG loading
. J I l Short circuit' stt. dies to assure that the electrical equipment has
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adequate interrupting 'and momentary short circuit ratings. This - .l ,~' r includes an evaluation of. the momentary and thermal withstand capabiliti'es of the containment electrical penetration assemblies.
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- 4. Relay protection, relay coordination studies and motor protection I is evaluated to assure that equipment is protected from electrical faults and overloads in accordance with the design requirements.
The relay coordination study is also evaluated to assure. that electrical problems are isolated in accordance with those requirements. This evaluation includes the undervoltage protection study and automatic starting of the diesel generators.
- 5. Motor selection is evaluated to assure that the selected ratings, enclosures, and torque availabilities are in accordance with the design requirements.
- 6. Breaker, starter, and feeder cable selection is evaluated to assure appropriate sizing for both load and voltage drop considerations.
- 7. Wiring diagrams and conduit / tray arrangements and plans are evaluated to assure that they accurately reflect the design requirements.
- 8. Power and Control power sources are evaluated to assure appropriate divisional assignments.
- 9. Power and Control cable routing is evaluated to assure separation is maintained in accordance with the design requirements, and that fire protection requirements are met, including the provision of qualified fire seals of the appropriate ratings.
1
- 10. Neutral grounding equipment sizing is evaluated to assute adequate ground protection in accordance with the design requirements.
Interface' Activities During the evaluation, attention is given to interfaces, both those concerned with the receipt of design inputs as well as the delivery of i design outputs. The evaluation assures that appropriate design inputs were received and incorporated into the electrical design, and similarly required design outputs were transmitted and appropriately 1 included in the design of the receiving disciplines. Incoming interfaces include: Offsite power source data NSSS electrical requirements Electrical equipment environmental conditions - normal / post accident Mechanical system power requirements Elementary diagrams Equipment arrangement drawings l ) 87-EA-047/EA306 4.1-7 L____------ )
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f . I ?" ' Outgoing interfaces. include: Heat losses!-~ Ventilation requirements
' Battery hydrogen generation - Ventilation requirements .
Equipment weights and dimensions - Equipment arrangements and
. Seismic. supports 1 4 Electrical Site Nalkdown In' conjunction with. the reviews ' described above, . site walkdowns are conducted to gather information needed to evaluate the following as -
. constructed items. .These walkdowns are done on a selective basis.
'l.- . Equipment locations are- consistent with the design. criteria-particularly with respect to: physical separation and equipment qualification.
- 2. Equipment is. installed consistent with the vendors' requirements.
- 3. Equipment and cables are adequately identified.
- 4. Control wiring terminations are consistent with the requirements.
'5. Equipment nameplates ~ and ratings are consistent with the' design requirements.
- 6. . Observed raceway' fills are consistent with design. values.
- 7. Ventilation surrounding electrical equipment is consistent with the design.
Electrical Evaluation Documents' The Electrical evaluation will include portions of the following Design Basis. Documents (DBD) and Design Validation Packages (DVPs). DBD No. DBD Title DBD-EE-031 Environmental Qualification of Class IE Equipment (interface review only) DBD-EE-038 Offsite Power System DBD-EE-039 Onsite Power System DBD-EE-040 6.9kV Medium Voltage' System DBD-EE-041 480V Low Voltage Distribution System DBD-EE-042 120V Low Voltage Distribution System 87-EA-047/EA306 4.1-8
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, :i Unint'erruptibl'e Power. Supply System
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' ,. ci- DBD-EE-043 _
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#' .DED-EE-044, DC' System
/j# K ' i L D DBD-EE-051' ' Motor. Protection
, 'DBD-EE-052 Cable Philosophy and Sizing Criteria
.DBD-EE-053' Starter Circuit Parameters / Requirements J
DBD-EE-054 Control Circuit Parameters /LoadingL J, Requirements-DBD-EE-057 ' Separation Criteria DBD-EE-062 Penetration Protection
.n DVP No. DVP Title 13A Preferred Power Systems ,
13B. Onsite Power ~ System-13C= . 6.9 KV Medium Volt System 139 480 V & 120 V Low Volt System 13E - Uninterruptible. Power. Systems. 13FL DC. System 13G. . Electrical Protection. System 13H Cable System 131 Lighting System 13J Electrical Independence 13K . calculations - 1E 13L Electrical Installation
. Selected'. design related issues identified by CPRT, NRC's Technical Review Team-(TRT) and CYGNA will also be included in the technical evaluation.
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_ . . _ _ _ _ _ _ ._______.___________._.____________J
4.1.3 Equipment Qualification Interface 4.1.3.1 Environmental Overall Scope and Approach The environmental qualification (EQ) process will be evaluated by reviewing the interface activities between the environmental program and other design activities. The evaluation scope will include electrical and mechanical equipment required to be-qualified for harsh and mild environments. This interface evaluation coupled with specific evaluations of the environmental qualification process by cthers, will provide adequate measures to' determine the technical adequacy of the EQ process. Selection of Components to be Evaluated A representative sample of electrical components will be selected as follows;
- a. Components.in the Containment Spray System.
- b. Components in another system which are exposed to the harsh environment of a high energy line break outside the containment.
- c. Components located in a mild environment.
- d. . Components located inside the containment.
Selections will be based on environment, input from other disciplines and generic functionality. The sample selected will cover a range of generic electrical and mechanical components, for example: o Pump motor o Motor-operated valve o Cable o Cable splice o Cable connection o Instrument o Solenoid-operated valve o Electrical termination o Electrical penetration 87-EA-047/EA306 4.1-10 l L L_____.________._____
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l' 'o ' Valve Evaluation Methodology The environmental qualification interfaces which will be evaluatedLare g .the. generation of' the EQ ' Master- List,- the . inputs required for~ environmental qualification 1 Land: the outputs from the environmental
-qualification process.
- 1. .. EQ Master List t
H This' eval'ation u will determine whether.all components within the evaluationsecpe of' review which require qualification are on the EQ Master List.
- 2. Inputs to Environmental Qualification' A. Location of' component
'B. Environmental Conditions '
- a. ' Normal Operation o- Temperature o Humidity
- o. Radiation
'b. Accident o Pressure o Temperature o Humidity or exposure.to steam o Spray a
o Submergence o Radiation l The above data will be obtained from the Safeguards and l Radiation Protection Evaluators. C. Functional requirements of the components to be qualified: i o Post-accident function of components
, o. Post-accident operating time o Instrument accuracy
=87-EA'-047/EA306. 4.1-11
q ne functional- requirements will be obtained from the Electrical and Instrumentation and Controls Evaluators. D.- -Electrical interfaces !b o Seals o Terminations o Electrical cable The' , electrical ' interfaces will be obtained from the Electrical Evaluator. E.' NRC I&E Notices and Bulletins related to environmental qualification F. As-Built Configuration Evaluations shall be performed to determine if the equipment is installed in a manner consistent- with the equipment l
. qualification requirements. The as-built configuration and -
nameplate data will be obtained from a ' field inspection. by the Mechanical, Electrical or Instrumentation and Control
, Evaluators, as applicable to the components selected for evaluation.
- 3. 0,utputs'from Environmental Qualification A. Maintenance Requirements--
B. Replacement Intervals The outputs .from environmental qualification will be identified from the environmental' qualification documentation packages. These outputs will be referred to the Maintenance and Operations Evaluators for their review as to whether the' requirements have been adequately addressed in maintenance procedures and surveillance schedules, i'
- 4. Documents to be Reviewed in the Evaluation -
The following documents are typical of those to be reviewed in the evaluation: o EQ Master List o Plant Arrangement Drawings o Environmental Conditions Document o EQ Documentation Packages o Equipment Specifications 87-EA-047/EA306 4.1-12 _ _ __m__ _____ . . _ _ _ _ _ _
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.4.1.3.2
< Seismic-The.'. seismic: qualification of equipment will be evaluated to the extent of. the' critical' interfaces, inputs to and outputs from the qualification documentation involved in the qualification process. The-interface evaluation coupled ' with ' the .. specific evaluation provides adequate ' measures to evaluate the' technical' adequacy of the seismic qualification process.'
Selection of Components to be Evaluated
' To provide 'a complete and consistent equipment review, the' components evaluated for' seismic.' considerations will be a sub-set .of the environmental sample chosen in Section 4.1.3.1 above.
Evaluation Methodology. The seismic qualification interfaces will cover the total - process, including the Design Specification requirements, the basis for. these
- l. ' requirements . and their; proper incorporation within the testing and
- analytical . hP ases of the ' equipment- . qualification process. Support 7 requirements'. established. to' maintain non-resonant behavior. of . the L component will' be verified as input .to the. support analysis.
l. Consistency- in both the seismic acceleration. levels and ' frequency'
,.. content will be verified'in all interfaces.
87-EA-047/EA306 4.1-13
T 4.1.4 Engineering Mechanics The engineering mechanics pipe stress and : support portion of the EFE will concentrate on the following major areas of. review. Small bore
- piping stress. analysis, small bore pipe support analysis and'large bore
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stress . 'and support interface. The evaluation of the small bore pipe stress and pipe support design will be performed from the licensing commitments .through the . design process including discipline interface. The large bore fstress' and . support design will be ' reviewed ' to assure 4 - consistency with validated input data and to assure outputs have been
' transfered to appropriate disciplines.
The technical evaluation will include mechanical components, supports, the ' effects of dynamic loading and ' system interaction. In general, each. technical evaluation will include reviews of: r o Pertinent FSAR sections and other licensing documents against appropriate regulatory guide connitments. o Applicable design criteria to assure technical adequacy and consistency with licensing commitments. o Inputs to the design process .to assure inputs are consitent with commitments. i o Computer programs to verify program validation and use within the limits of the validation. f o Calculations to' assure technical adequacy and consistency with licensing commitments. o Specifications ~ and: vendor documents to assure consistency with design requirements. o Design' and construction drawings to assure consistency with design requirements. o Change documents (DCAs and NCRs) to assure resolutions are technically adequate and 'consistant with licensing commitments. o Design documents to assure- that resolutions to previously identified concerns have'been adequately implemented. o Validated design documents to assure- consistency with the as-constructed condition. l: Sample Selection
- A representative sample. of pipe stress and support designs from the
- Containment Spray System will form the basis of the evaluation. ;
Selecting designs from the Containment Spray Systems yields an 87-EA-047/EA306 4.1-14
R J v; f integrated ' approach i with the interfacing discipline evaluations. Portions L of - other . systems will ' be selected. - as ' necessary, to assure that' the representative sample is sufficient to evaluate the technical
~ adequacy of various design parameters.
4.1.4.1' Pipe Stress Analysis Selection Sample-
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Sample selection will be of ' sufficient size and depth to evaluate thel following attributes: o Multiple modes of operation o' NSSS design interface o . Piping ' that. spans' between structures to review ~ orbital-motion, building settlement, independent' support motion o Fluid transient effects, relief valve discharge f o Decoupled- branch movements, equipment displacements, structural movements etc. o Free ended piping, vents,. drains, and instrumentation-
-Review Activities The ' CT system small bore piping stress and support design will be evaluated to assure technical adequacy of consistency with design basis documents. The evaluation will include selected aspects of the design process based on evaluation of a representative sample. The sample' size and scope of review will vary with the complexity, uniqueness, and safety significance of the design but will be of sufficient size and depth to' assure adequacy-of the design.
~
The following items will be reviewed with regard to piping stress design: o Inputs to the design such as temperature, pressure, modes of j operation, plant conditions, seismic response, equipment mass 1 I distribution, pipe break loads, etc. will be evaluated to assure technical adequacy and consistency with design l f requirements ' l o The mathematical model of the piping system will be evaluated l to assure consistency with as-built configuration of the system, and its supports. l' j~ o .The mathematical model of the piping system will be evaluated l to assure technical adequacy and consistency with design i criteria. i 1 l. i' 87-EA-047/EA306 4.1-15
- - _ _ _ . _ ______ - )
. _ _ _-_._ - _ _ _ _ - _ _ - - - - . _ _ _ _ .-- _ _ - - _ = _ _ _ _ _ _ _ - - _ - _ __ - _ _ - _ - _ _ _ _ . _ - - - _ - - -_
o: The design' of" the piping rystem will' be evaluated to 1 assure technical adequacy - and consistency with . licensing commitments.
- o. . Interfaces with NSSS : will ' be evaluated ' to assure system
. . requirements are met.
o Outputs from' the' piping stress design. will be evaluated to assure transfer of information ~ to other, appropriate' design l-groups.is technically adequate. EL - Pipe Support'Analyefs Selection Sample' Sample selections will be of sufficient size 'and depth to evaluate the
- following attributes:
)
o- Rigid restraint with one or more degrees; of freedom restrained ~ o ' Anchor with welded attachment and' clamp type
- o. Variable / constant support spring hangers
- > o, ' Mechanical / hydraulic snubbers l o -Seismic, non-seismic interface anchors o Integral welded attachments l Review Activities I The . following ' items will be reviewed with regard to piping support design:
o Inputs to the designs such as pipe loads and temperature, will be evaluated to assure technical adequacy and l consistency with design requirements. o The mathematical model of the support will be evaluated to l assure technical adequacy and consistency with as-built condition, . piping system model, vendor requirements and
' design criteria, o: The design of the support will be reviewed to assure l technical adequacy and consistency with licensing l
commitments. o Outputs from the support design will be evaluated to assure D transfer of information to other appropriate design groups is l technically adequate. 87-EA-047/EA306 4.1-16 L D_ _ - . . _
p L
'i Interface Activities - (Stress ~ 6' Supports)'
In general,- the '.interf ace. or the transfer of information -between 4 inter-company,: interdiscipline, and intradiscipline - will .be ; reviewed .
-for consistency with. validated: design documents.
l Ine' stresia. analysis and ; support - design inputs, will be reviewed .for parameters, such as, modes of operation, -loading conditions, fluid conditions, building L seismic structural response, building settlement ef fects,1 pipe on pipe effects such as jet ' impingement and- pipe whip-
- load s '.
~
The results of the stress analysis and support design-will be' reviewed
. for . the; following areas: piping. loads imposed . on structural steel /
-concrete; piping loads on - equipment . nozzles, . pipe stress . levels for break' postulation.
' Stress and SupportLEvaluation' Documents The Engineering Mechanics Review will include portions of the following-Design Basis Documents and Design Validation Packages:
Design Basis' Documents-1
~ Number- Title
.DBD-CS-006 ASME Class 2 & 3 Piping Analysis DLD-CS-067 ASME Class 1, 2 &-3 Pipe Support Design DBD-CS-068 Non-ASME Piping and Support Design DBD-CS-069 Hot Functional Testing and Vibration Monitoring .j DBD-ME-232 Containment Spray System DBD-ME-304 Control Room Air Conditioning System Design Validation Packages Number Title DVP-11F Piping Design I' DVP-111 Containment Spray l
o I. i 87-EA-047/EA306 4.1-17
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4.1.4.2 Large Bore Piping Stress and Supports t i Selection Sample j The parameters used for selections of samples for evaluation will be similar to those for small bore piping. Identification of Review Activities The CT system large bore piping stress and support design will be- 1 evaluated to the extent necessary to assure interfaces with other design groups are consistent with design requirements. The evaluation will determine-if: o Inputs to the design such as those listed for small bore ') piping and supports are consistent with design criteria i o Drawings of supports are. consistent with as-built conditions o Outputs such as those listed for small bore piping and supports have been transmitted to appropriate disciplines Interface Activities l The large bore pipe stress and' support interfaces are similar to those listed for ~ small bore piping. Therefore the reviews conducted of the stress analysis and support designs will be as previously discussed.
-In addition the NSSS Class 1 pipe support design interface will be 4 evaluated.
l l 1. l 1
- 87-EA-047/EA306 4.1-18
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4.1.4.3 ' Mechanical / Analysis A sample of mechanical components will be selected from the Containment Spray system and interf ace systems to provide the basis for an in-depth technical evaluation. The equipment sample will cover the following: o Components having intermediate steel supports will be reviewed as they represent a more extensive design process than floor mounted or in-line components. o Pipe break mitigating hardware will be reviewed for consideration of dynamic loadings. o Pressure vessels / tanks will be reviewed for nozzle interfaces and support design consistency. The selected sample of mechanical equipment will be subjected to a detailed evaluation of all phases of the design process. This evaluation will provide assurance of the technical adequacy of the mechanical design of components and their supports. Equipment Supports The design and analysis of equipment supports will be evaluated for its technical and functional adequacy. Component operating loads, interface requirements, and seismic behavior of the support will be evaluated for consistency between all related design documents. Interface loads, at the connection of the support to a concrete embedment, will be provided to the Structural EFE team members for evaluation of the corresponding embedment design. Hazard Related Mitigating Hardware Hardware designed to mitigate the effects of Pipe Break or Internally Generated Missiles (IGMs) will be evaluated for the following attributes: o Consideration of the amplifying effect associated with dynamically applied loads o Strain allowed in components allowed to deform plastica 11y for energy absorption o Consistency between design loads used for the hardware and its associated embedment o Penetrating capacity of IGM's when evaluating missile shields o Compatibility between and design and FSAR criteria and commitments 87-EA-047/EA306 4.1-19
t
' Pressure Vessels / Storage Tanks
,s .The evaluation' of. vessels and tanks will concentrate on the ~ areas of
- interface loads.' The approach used to calculate nozzle stiffnesses and the resulting stresses in'a tank.at the nozzle / vessel interface will be evaluated. In addition,. the manner of combining nozzle loads Land g'
seismic. effects'on the support design'will also be reviewed. Since the
~
design of. vessels is highly . controlled by code : requirements and
. inspections, this limited scope evaluation = will provide reasonable assurance of a technically. adequate design.
Mechenical Walkdown Verification-To complete and compliment the detailed technical review of design- l' criteria and documentation, a site walkdown will be conducted to verify the following design parameters: 1 o Configuration and orientation o.f installed equipment supports included in the evaluation o Connection details at interfaces of support and component and-at support and embedment o -Configuration and support . of piping connected to pressure
. vessel nozzles o : Pipe to restraint clearances and relative position lof restraint to break location >
o Support details for missile shields' or jet impingement barriers o Unique design aspects noted during the documentation review Mechanical / Analysis Evaluation Documents Equipment reviews will include portions of the following Design Basis Documents (DBDs) for technical adequacy and for consistency with the FSAR commitments and the actual design documents. DDD No. Title
.DBD-CS-088 " Pipe Whip Restraint Design" DBD-CS-092 " Seismic Design Parameters and Response Spectra Generation" l
l i L 87-EA-047/EA306 4.1-20 l
4.1.5 System Interaction I Because Nuclear Safety'Related structures, systems and components must be designed . co withstand the effects of natural phenomena associated with plant operating conditions, including postulated accidents and the resulting interaction between systems the four major subdivisions of this evaluation include: o Pipe Break Analysis o Internally Generated Missiles. (IGM's) o Internal Flooding l l o Seismically Induced Safety /Non-Seismic Interaction L The technical adequacy of the System Interaction Program will be l l evaluated using a sampling approach. The sampling criteria centers l around equipment associated with the Containment Spray System (CT) inside and outside containment and, in particular, components within the Safeguards Building. Where review attributes cannot be tested from this system and building, other safety systems will be evaluated to satisfy the scope of this review. This evaluation 'will encompass the entire process from an engineering and design perspective, beginning with commitments to NRC regulations and guidelines'and proceeding through to the completion of analyses to verify that the plant can be shutdown following the occurrence of any of these hazards, coincident with a single active f ailure and loss of off-site power. It also includes an evaluation of hardware designs necessary to mitigate the consequences of the hazards. Due to the nature of system interaction concerns, a comprehensive evaluation requires the joint efforts of technical experts from several disciplines. The project's commitments and hazard postulation methodology will be reviewed by the mechanical section representative. A sample of postulated events will be evaluated jointly by representatives from the power, electrical, controls, and structural disciplines. This joint evaluation will consider all potential consequences of the initiating event and the adequacy of any resulting analyses or mitigating hardware designs. SCOPE This evaluation will include the following activities: Pipe Break (High energy and moderate energy systems) HELB and MELB will be evaluated for the following attributes: o Selection of break location and type 87-EA-047/EA306 4.1-21
1 ce, j ! i o Forcing functions .used to; evaluate the post-break action of j S , the' broken' pipe 1
.o- Zone-of-influence'used to identify potential interactions.due
' to. resulting pipe: whip or jet impingement o; Method'of calculating impact loads o' . Type'and location.of mitigating hardware-Jo. . Break propagation criteria and'its implementation
~
Internally Generated Missiles (IGM's)
-The methodology used in identifying .and evaluating : potential missiles from-the. main turbine as well as other rotating equipment and pressure vessels will be evaluated. The zone-of-influence, separation criteria, and interaction analyses used in the evaluation of postulated missiles will be reviewed for consistency and technical adequacy..
-Internal Flooding Flooding' effects due tol plant process system failure and/or. pipe break will be evaluated. Postulated; flood . heights, ; equipment location /:
qualification for postulated . floods, and consideration. of ' cascading effects from pipe breaks will all be evaluated for technical adequacy.
' Seismically Induced Safety /Non-Seismic Interactions The . -criteria used to prevent seismically induced. interaction with Safety Related Equipment : will be evaluated. Support design and placement' of non-seismically designed ' equipment will be evaluated for
" acceptability.
1 System Interaction Interfaces Critical interf aces between EBASCO, who has overall responsibility for the System Interaction Program, and those companies which provide input l to or use the results of the interaction evaluation will be reviewed. Since the f evaluation will be conducted so as to review the entire process from postulating criteria to acceptable resolution for-a select sample- of events, the= adequacy of the interface process will be
~ demonstrated by.the consistency found during this total review.
Field Walkdown Verifications As ' a final step in evaluating the overall adequacy of the System l Interaction Program, a site walkdown will be conducted by the multi-discipline EFE team to verify the following: L o Adequate separation of safety equipment from non-seismically
. supported components
[ I l l 87-EA-047/EA306 4.1-22 e____--___ . - _
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;.G o Identification ; of '.! all' potential interactions. due. to. the ,
. selected samplesof' hazard events. .
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.of Location-and' design'of mitigating hardware is consistent with rdesign. documents and the requirements.of the initiating' event
' System Interaction Evaluation Document .
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'! In' combination with the general areas of review cited above, portions of. the following Design Basis Documents (DBDs) will- be evaluated: -
'" Seismic /Nonseismic System Interaction Program"
~
'DBD-ME-005- '
q- . DBD-ME-007 Pipe Break. Postulation Ef fects" 1
"LOCA-Accident Analysis" DBD-ME-102-' l DBD-ME-103 '"Non LOCA Accident Analysis"
... .DBD-ME-105 " Missile Postulation and Effects" 7
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.87-EA-047/EA306 4.1-23 4
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4.1.6 Heating, Ventilating and Air Conditioning (HVAC) General The engineering functional evaluation of the HVAC system design will be performed by reviewing a sample representative system (s). This system (s) will be technically reviewed from the development of the design base data, cooling / heating loads and other design inputs through the design, procurement and installation processes. In general, the . evaluation of the selected system (s) will include
. review of:
o Pertinent FSAR sections and other licensing documents against appropriate regulatory guide commitments. o Applicable design criteria to assure technical adequacy and consistency with licensing commitments. o Inputs to the design process to assure inputs are consistent with commitments, o Computer programs to verify program validation and use within the limits of the evaluation. o Calculations to assure technical adequacy and consistency with licensing commitments. o Specifications and vendor documents to assure consistency with design requirements. o Design and construction drawings to assure consistency with design requirements. o Change documents (DCAs and NCRs) to assure resolutions are technically adequate and consistent with licensing commitments. o Design documents to assure that resolutions to previously identified concerns have been adequately implemented. o Validated design documents to assure consistency with the as-constructed condition. 4.1.6.1 HVAC System In selecting an HVAC system for evaluation, several systems were identified as meeting the following criteria: o Have different modes of operation o Interface with other systems 87-EA-047/EA306 4.1-24
b o Contain various type of components and thereby are typical of other systems Of the several systems, the " Control Room Area Ventilation System" was selected for the following reasons:
- 1. Has 4 modes of operation
- 2. Has most of the components and subsystems which exist in the field of HVAC, such as: fans, cooling and heating coils, refrigeration compressors and condensers, fire dampers, motorized dampers, activated charcoal and HEPA filter trains.
- 3. Is safety related in its entirety.
- 4. Has interface with several other systems.-
An additional subsystem will be evaluated. This subsystem will be the portion of the ESF Ventilation System that relates to the Containment Spray Pump Cubicle and provides the integrated interface with the other discipline evaluations of the Containment Spray System. Specific HVAC Activities The following HVAC design activities will be reviewed as related to the selected systems:
- 1. Compliance with FSAR commitments and pertinent Regulatory Guide and governing industry standards, such as Regulatory Guides 1.52, 1.78. 1.95, 1.105 and ANSI standards N509 and 510. -
- 2. Design Inputs such as: Indoor / Outdoor design conditions, heat sources, EQ requirements.
- 3. Design calculations required for system design and equipment procurement.
Typical calculations to be reviewed will include: o Cooling / Heating loads o Cooling and ventilation air flow rates o Air pressure drop in ducts and equipment o Pressurization flow rate o Pressurization adsorption units preheat coil sizing to assure design relative humidity i l 87-EA-047/EA306 4.1-25
-o ,
I-s L < , H o fo FSetpoints of instrumentation
- { :o' l Closure time.of isolation. dampers
^
f4. Consistency with valid design practices in relation to:
'o Temperature control-o Noise and vibration attenuation o 011 return'and moisture control in refrigeration P i ping o Provision for access for inspection and maintenance
.o . Relief valves venting o 'Ductwork allowable-leakage Equipment / Components Associated with the System p In addition to: the system review as detailed in Section .4.1.6.1, .
representative equipment.and components will be selected for review. A typical-list of such equipment will include:- o Air Conditioning unit,- including cooling and heating ; coils, filter and fan
-o Adsorption filtration unit including moisture eliminator and or prefilter, HEPA filters, carbon filter, electric coil and related control-o Direct expansion refrigeration unit including compressor, condenser, expansion valve and related controls o Centrifugal fan <
o Vane axial fan o Electric modulating and/or isolation damper o Pneumatic modulating and/or' isolation damper o Gravity damper o Manual balancing damper o Turning vane o Register o' Fire damper o Access door 87-EA-047/EA306 4.1-26
.A The' review will' determine if:
- 1. The equipment' procured is consistent with the FSAR commitment
.and with the design and' calculation parameters.-
- 2. . The . required electrical, control' and structural interfaces were executed.
3._ Special Vendor requirements are met, such as: o Cooling fluid' o' Flexible connection o . Space for coil withdrawal ( 1
- o. Access for maintenance HVAC Site Walkdown' In conjunction with the reviews described above, site walkdowns will be j
conducted to gather information required to determine if: o' Validated- design documents are consistent with the as-constructed condition o _ Balancing dampers are in position depicted in balancing reports o Instrumentation- is adequately mounted and: sealed at penetration of ductwork o Restoration work after balancing and testing wrs executed o Local'and equipment. control panels are accessible o Equipment installation is consistant with vendor requirements HVAC Evaluation Documents The HVAC evaluation includes portions of the following Design Basis Documents (DBDs) and Design Validation Packages (DVPs). DBD or DVP No. Title DBD-ME-003 Control Room Habitability DBD-ME-302 Safeguard Building Ventilation System DBD-ME-304 Control Room Air Conditioning Systems DVP-11Y Control Room Habitability 4.1.6.2 HVAC Ducts and Support The discussion of HVAC ducts and supports evaluation is contained within the Structural Section 4.1.9. 87-EA-047/EA306 4.1-27
l s 4.1.7 Instrumentation-and Controls
- l. zThe scope of the Instrumentation and Controls (I & C) portion of this I technical evaluation will involve a design review of the control systems and components that are required to satisfy the safety and-operational functions . of the . Containment Spray System and supporting systems and the control room area ventilation system. .This evaluation !
. will be primarily based on a review of the design. documents listed below,- interfaces with other engineering disciplines, and a site walkdown.
In general, the evaluation of each of the items -listed below will include reviews of: o Pertinent FSAR sections and other licensing documents against appropriate Regulatory Guide commitments. o Applicable design criteria to assure technical adequacy and consistency with licensing commitments. o Inputs to the design process to assure inputs are consistent with commitments. o Computer programs to verify program validation and use within the limits of the program. o Calculations to assure technical adequacy and consistency with licensing commitments. o Specifications and vendor documents to assure consistency
'with design requirements.
g o Design and construction drawings to assure consistency with design requirements. o Change documents (DCAs and NCRs) to assure resolutions are technically ' adequate and consistent with- licensing commitments. o Design documents to assure that resolutions to previously identified concerns have been adequately implemented. o Validate design documents for consistency with the as-constructed condition. The following types of documents will be reviewed and evaluated: o Instrumentation and Control Diagrams o Electrical Elementary Diagrams o Instrument Location Drawings, Tabulation Sheets, and Installation Details 87-EA-047/EA306 4.1-28
o ) t-f.[ l o- Equipment and Installation Specifications _ i o Vendor Documents- j] L $ i o Instrument Setpoint Calculations , JA representative. sample of the above I & C documents;. and equipment' which . generally perform an automatic or manual control function (i.e. , valve operation, pump start /stop, etc.) 'for the -Containment Spray 'j System will be. selected. The documents selected'will be reviewed and j evaluated 'against ~ commitments in the FSAR, applicable codes and standards, and for consistency with other interfacing documents such as flow diagrams and electrical one-line diagrams. These commitments will' include the parameters from various Regulatory Guides as described below. RG 1.11 -. Instrument Lines Penetrating Primary Reactor Containment o Type and location.of flow restriction utilized o Accuracy and' response time of.the instrumentation are not
~
affected to an unacceptable degree by the flow restriction o Type and location of isolation valve utilized including location of valve status monitoring o If a power operat'ed valve is utilized, type of failure mode on loss of control power RG'1.22 - Periodic Testing of Protection' System Actuation Functions o How the system is tested (on line or at shutdown) and is'the testing from sensor to final device or in overlapping steps o All alarm and status indication are available during test and redundant equipment can not be tested / bypassed simultaneously o Final device is actuated or justification given for not actuating RG 1,47 - Bypassed and Inoperable Status Indication of Safety Systems o The bypass and inoperable status equipment is located appro-priately on the Main Control Board or on a separate panel o If support systems for a main system are bypassed, the main system. indicates a bypassed condition 4 RG 1.53 - Application of the Single-Failure Criterion to Protection Systems j o How on-line testing of safeguard circuits is accomplished . 87-EA-047/EA306 4.1-29
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, .o :The: . output of~-a protection channel' or,' train ~ goe's ' to:
,' completion during- on-line, testing, :and if not,, it 'is.
t: 27 0 l documented in the FSAR~ j , q $g ; o- ;If Ea' single 'switich is utilizedi o t supply signais to redundant [ channels or trains," suitable separation exists
.RG 1.62 ' Manual'. Initiation of Protective Actions! l%
A o .Means provided" and device : location .to protection' systems at: the system level manually 'a'ctuate k' - q]
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'or trains, suitable separation exists; io .' Manual actuation'once1. initiated goes to completion
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=RG 1.75.- Physical'; Independence of-Electric Systems o, ' Class .1E redundant. circuits .are - uniquely: identified ' on all. . .h documents 4< ,
, :f o Associated c circuits thatL are- utilized with one , train are- . c. M
" identified'with'thatetrain and are separated from the'redun- /t i dant train m
o Associated ' circuits that. utilize isolation devices'to down- 1 : r: grade their status from C1cssi1E to Non-1E do not again_come in contact with Class-1E ewipment , a,
> o, The requirem'ents of Sections 5.6. and 5.7 ~ of IEEE 384-1977 -
- have been ' addressed ,
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RG 1.97.-: Instrumentation to-Assess Plant Conditions During:and FS11ow-ing an Accident-o Selected parameters'11sted in Regulatory Guide RG 1.105 - Instrument Setpoints o Sufficient margin exists-to allow for' instrument' inaccuracy,, 4 i' uncertainties in calibration, and drif t .
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o The accuracy of all safety instruments is equal to or better-than theLaccuracy assumed in the FSAR ,
'RG-1.106 - Thermal-Overload Protection For Electric Motors on Motor Operated Valves
'o -How thermal overload protective devices are bypassed r.nd the .,
.,. monitoring of the bypass circuitry w
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' Thermal overload protective devices areinot bypassed.during normal ~ operation of.the valve Fire-Protection requirements will'be reviewed'and evaluated to' address.
L the-following parameters: A
.o- : Postulated fires in,the' Main Control Room have been addressed and controls are provided in an alternate ' area outside the Main Control Room to enable reactor shutdown during evac-untion of the Main Control Room o-- Controls that are located in the ~ postulated fire area are
,3
. bypassed and will not effect the controlshiu the alternate y@. . area o Controls which remove control from the Main Control Room-are alarmed and/or protected from unauthorized personok1
,o Reactor shutdown can be achieved with a postulatsd fire in 4 y- common areas such'as cable spreading areas
' b. c a sa e# o If chemicals that are toxic or harmful are utilized to I '.~ '
axtinguish* fires, that .the areas used for shutdown are
,, protected E terfaces
[< .; The interfaces (both. inter-discipline and. inter-company) where informa-efon transfer occurs'.will be reviewed and evaluated. ' Included in this.
.., rediew will be the following:
, ,.e
. I & C Interface With . Types of Documents or EqEipment to be Reviewed
! Electrical ' Electrical'one-line-diagrams f(
Eng neering, Mechanics Instrument tubing supports f . _ , . _ Pever Flow diagrame IMPELL Equinment Qualification U Site Walkdown i: A site walkdown will be' performed to evaluate items such as: jl -1. Instruments 'and instrument tubing to meet design criteria p
- i. . o . Tubing slope o- . Tubing and instrument separation o Tubing supports 4 .. 2. Instrument mark numbers are in agreement with specifications and sc ). drawings. '
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- 3. Instrument tubing is not installed on block walls.
- 4. Instruments, instrument tubing, instrument racks, and control panels are protected from missiles and falling objects. They are not subject to damage due to location or interference with other equipment.
- 5. Instruments are accessible for calibration and maintenance.
- 6. Instrument racks and control panels meet electrical and physical separation criteria.
Instrumentation and Controls Evaluation Documents The Instrumentation and Controls review will include portions of the following Design Basis Documents (DBDs) and Design Validation Packages (DVPs): DBD or DVP No. Title o DVP-15A Specifications of Control Components o DBD-EE-035 Instrument Installation DVP-15B o DBD-EE-033 Detail Control Room Design DVP-15C o DBD-EE-032 BOP Analog Control (As applicable DVP-15D to Containment Spray) o DBD-EE-004 RG 1.97 Rev.2 - Instrumentation to Assess DVP-15E Plant Conditions During and Following an Accident o DBD-EE-037 Setpoints o DBD-ME-232 Containment Spray System j DVP-llI o DBD-ME-304 control Room Air Conditioning System o DBD-ML-003 Control Room Habitability o DBD-ME-013 Containment Isolation DVP-IIE o DBD-EE-031 Environmental Qualification of Class IE Equipment l l l 87-EA-047/EA306 4.1-32 l I --___-__ -. - . . _ . . . _ )
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- The evaluation ofs chefPower. (Mechanical) Design at .Comanch'e V ak Steam Electric'Stationwil(concentrateonthefollowingareasofreview.
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, R (mi , & /'$ 1 oL A major fluid system will be reviewed from the design / /j' j development' stage through' construction / installation f V interface.
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s o.) Included in hhe review will be.the establishment of system
' 3' . -parsheters (flow, pressure, temperature, etc) and the' ,
inter (sce with related design disciplines. ; , J ( 1, : + l o ,gec@sn}vyl.componentsrequiredforfunctionalityofthe # .i g systdny,cuonen for evalution will also be ' reviewed..from verificaty np of-. inputs to the construction / installation'a
-interface.L NSSS'and BOP interCaces will be reviewed'for a application through the design stage co'the i 3
construction /f gtallation interface g The Power evaluation will' include the subsection of Systems, Materials,
;Engineere'd Safeguards- arid Radiat' ion Protectic[ j i s In general, the ' evaluation will include reviews of:
b o . Pertinent FSAR sections and other licensing documents to , assure that the'FSAR is consistent with appropriate ^ regalatory guidis and TU commitments.
/r 3
o Applicable deadgn criteria to assure technical adequacy and consistency with licensing commitments.
; , e o -Inputsto-thedesignprocesstoassurethatinputa'are[
consistent with commitments. -
/
o Computer programs to verify program validation and use. <1d . o Ca(cujntionstoassuretechnicaladequacyandconsistency witV licensing commitments. ! .
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o Specifications and vendor documents to assure consititency 3 i with desigT requirements. ! e' { e
.f c o Design aiid construction drawings to assure consistency with ..
design requirements.
' I o Change documents (DCAs and NCRs) to assure that resolutions ,
are tecnica11y adequate and consistent with licensing $ committuent s. 4 o Design documents to assure that previously identified concerns and resolutions have been adequately implemented. f ' 87-EA-047/EA306 4.1-33 < f 7 .
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$/f3 of . Validated design documents to assure consistency with the Mp , .
as-constructed conditions.
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F V The Containment Spray System (CT) was selected to form the basis for .
'
- the,EngineeringLFunctional Evaluation. This system was selected'for.
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> f .the?following reascpe:
,f
,'1. Thesystemherformsasafetyfunction
'c n 2. The system is a majorLsafety related system f
- 3. The design. requires the use of multi-discipline engineering 4 , p
- 4. The system receives actuation signals from the Reactor Protection System
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- 5. The system' interfaces with NSSS Systems
- 6. The system interfaces with other Safety.Related Systems
.7. The system contains a variety of major mechanical and types
;f of components used in other A/E designed systems f (' -
- 8. It contains components which have experienced past problems in other Nuclear Power Plants (e.g. isolation valves,
.'. ,a chemical tank concentrations).
n 9. 'The system operates in nore than one accident mode
>[ 10. The system was not the subject of previous independent evaluations
- 11. The system is located in more than one plant building
- e. ' Interf aces between the CT and other fluid systems will be evaluated, 1 for example, the CT interface with the Component Cooling Water System.
Additionally, the affect of CT operation on other design activities will be identified and evaluated, for example,.whether or not the appropriate spray and sump pH was used in the environmental qualification of electrical components located inside the containment.
.Thc[edectrical,instrumentationandcontrols,-seismic, operations /
maintenance and testirj, structural, interfaces with the CT will be ; I referred'to otherJdiscipline evaluators for evaluation as they are identified. ,For example, the manual switch over from the injection mode of containment spray to the recircula* ion mode, will be referred l to the Operations sud Maintenance Team members. ,
- ," I L , c l
The following outUr.es the evaluation plan for the Engineering p ' Functional Evaluation of the Containment Spray (CT) system. l
. 7-EA-047/EA306 4.1-34 l c
I __b . _ _ . . _ . _ _ _ .
Selection'of Components to be Evaluated A representative sample of components in.the.CT.will be selected for th'.e Engineering' Functional Evaluation.. The sample,will include key.
< components from each type of components whose failure could prevent the CT.froml performing.its safety function.- The type of components.which will'be included in the sample are:
Pumps ,. ,
. Active Valves Tanks.
Heat Exchangers Flow Elements Check Valves Relief Valves Containment Piping Penetrations Piping Eductors Spray. Headers The components selected will be.those major system components that are determined to be significant to the functional safety of the system and' will provide confidence to the evaluator that the remaining components have been-adequately designed and documented. Evaluation Methodology The following attributes will be evaluated: Pipe Sizing Heat Removal and Rejection Controlled Chemical Addition Pump Sizing Sump Design Storage Tank Design Vortex Protection NPSH Limitations Support Systems Automatic Startup Manual Switchover Safety Class Interfaces Within System Single Failure Requirement Equipment Flooding Fire Rating of Piping Penetration Seals Potential for Water Hammer Recirculation Leakage Interfaces with Other Systems Arrangement of Valves Containment Isolation Source Term from Radioactive Fluid in Recirculation Piping !- 87-EA-047/EA306 4.1-35 L____ _ _ _ _ _
y :.r. 1; ' L Site Walkdown I
, A! field'walkdown will be conducted to confirm system configuration, and
'to evaluate' parameters that cannot be reviewed from design documents.
i Typical items.that may be confirmed during the walkdown are as-follows: ! i
- o. Nameplate data are.the same as the design: requirements.
o Components are ; 1ocated as shown on . flow diagrams and j physical' drawings. - o ' Fire rated piping penetration seals are installed. o . Containment isolation valves are locatied as close to the
' Containment.as possible.
o Equipment is protected from high' energy 'line breaks and i missiles. o The configuration of the Containment' Recirculation. Sump is consistent with the design requirements. o Equipment is adequately labelled so that the chance of maintaining or operating the wrong equipment is minimized. o Insulation is adequately installed. o The Leakage Detection System is installed to meet design requirements. Documents to be Reviewed in the Evaluation The following items are typical of those to be reviewed in the Engineering Functional Evaluation: Final Safety Analysis Report Technical Specifications Calculations Specifications Design Input System Descriptions Flow Diagrams Physical Drawings Project Licensing Commitments Generic Licensing Doc ments (1 & E Notices, Bulletins, etc.) ASME Reports System interface Documents Design Basis Documents Design Validation Packages Issue Resolution Reports Issue Specific Action Plans 87-EA-047/EA306 4.1-36 _ _ _ - _ _ - _ _ _ - - _ _ _ _ _ . i
l AFFECT OF CT OPERATION ON OTHER DESIGN ACTIVITIES i
, 'I. ' Environmental Qualification of Components Inside Containment
- a. An electrical component from another system' inside the-containment, . located above - the floodup elevation l will be selected.- A review will be performed to determine whether.or not the pH was'specified in the qualification documentation, b.. An electrical, component from another system inside the. ;
containment, that will be submerged after post-LOCA, wi11 be l selected. A, review will be performed to' determine whether or not the sump.'pH was specified in the qualification
' documentation.
2.. Hydrogen Generation Inside Containment A review of _ - the , calculations will be performed . for hydrogen generation from the reaction of the. aqueous-colution in the spray and sump with .the . aluminum and' zinc- surfaces inside the containment. The review will determine whether. or not the-specified spray and sump pH were used.
- 3. Spray Impingement Restriction A review will be performed to determine if there are any' design restrictions ~ to preclude direct spray from the CT System on certain' components. The review will determine if the restriction j requirements were specified and implemented. i
- 4. Containment Recirculation Sump Floodup I
- a. The calculation of containment recirculation sump floodup l elevation versus time will be reviewed to determine whether or not adequate NPSH exists to the CT pumps at the time. of
-)
switchover from the injection mode to the recirculation mode.
- b. A review will be performed to determine if components inside the containment are required to perform their safety function prior to being submerged in the post-LOCA containment sump fluid. If there are any such components, the calculation of ;
floodup elevation versus time vill be reviewed to confirm I that these components and any required interfaces are not flooded prior to the safety function being performed (or, alternatively, that the flooded component has been environmentally qualified for floodup). , i
- 5. Containment Debris l i
A review will be performed to determine if there are any coatings inside the containment (structural or equipment) that are not qualified for the post-LOCA environment (temperature and chemistry , in the vapor space or sump fluid). ! 87-EA-047/EA306 4.1-37 _ _ _ _ _ _ - ---_____=
.. o
-The results : of the ' review will be evaluated to ' determine if the' effects of any coating debris have been specified.and evaluated in.
~ the sizing , of ' the . recirculation . sump screens, fouling of the' CT
. heat exchangers or blockage of the CT flow elements.
~
'6. Pipe' Loads-
'A' teview : will be , performed _ to . determine .if the .' system operating
. condition transients and other. loads have ' been specified . and -
transmitted to the pipe stress and support group.-
- 7. Structural A' review- will .be performed to determine if the mounting configuration and system loads have been specified and transmitted to the structural group.
- 8. ' Electrical' A- review' will be performed to . determine if' the- equipment electrical loads have been; specified for all modes of ' operation and, the electrical equipment has been adequately sized and specified.
- 9. I&C A review will be performed to determine if the system logic'has been specified for all modes of operation and the I & C equipment has been adequately sized and specified.
System Interfaces with Containment Spray System The following' systems interface with the Containment Spray System: Component Cooling Water Demineralized Water Nitrogen Gas Supply Vents and Drains Instrument Air Chemical and Volume Control Service Water Leakage Detection Portions of the following interface systems will be reviewed as part of this evaluation. .The review will be limited to selected components in the interface systems which perform the safety-related functions
. outlined below.
l- ) l
'87-EA-047/EA306 4.1-38
= _ _ _ _ - _ _ _ - _ _ _ _ .1
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'1 . ' Component Cooling Water System This .. system 'provides' cooling. . water to ' the shell side of the CT
. heat exchangers and -' to the seals of the CT pump. The CT heat exchanger .is the primary means of' removing'. heat from,fthe Containment environment following a LOCA, a main steam line break, or a feedwater line break' accident. -Seals to the CT pump must be maintained during operation of the. pump..
- 2. Service Water System This system provides cooling water to the CT pump bearing coolers.
. Bearing cooling must be maintained during CT pump operation.
- 3. Leakage Detection ~
This system limits the . leakage of radioactive products outside Containment u in ' the event of a passive failure in thel CT, and. allows . for . isolation of the leaking subsystem.- One train of CT must be . maintained operable during the recirculation mode of ' CT heat removal.
- 4. Instrument Air This system provides air to close the air-operated ' chemical
' additive . tank isolation valves. There is a motor-operated valve in series and upstream of the air-operated valve to . meet the single f ailure - criterion. . However, no credit - for single failure protection is assumed in the Engineering Functional Evaluation.
Systems Evaluation Documents The Power Systems review will include portions of the following Design Basin Documents and Design Validation Packages: A. Design ' Basis Documents , I l Number Title Portion For Review . l DBD-ME-002 Penetration Seals Fire Rating of Pipe Penetration Seals through j Concrete Walls DBD-ME-013 Pipe Break Postulation Affect of HELBs on CT Effects DBD-ME-013- Containment 1 solation Arrangement and Opening i n Time for CT Contain- l ment Isolation Valves j t DBD-ME-018 Active Pump and Valve Qualification of CT Pump Qualification Program and CT active valves h 87-EA-047/EA306 4.1-39 l l l - L. l
DBD-ME-105 Missile Postulation and Affect of Missiles on Effects CT DBD-ME-229' Component Cooling Water System Interface with CT s DBD-ME-232 Containment Spray System Complete l DBD-ME-236 Vents and Drains On CT as well as on Leakage Detection System DBD-ME-241 Demineralized and CT Interface with Reactor Makeup Water Demineralized Water System System for Spray Riser Fill DBD-ME-243 Nitrogen Gas Supply System Interface with Chemical Additive Tank B. Design Validation Packages l Number Title Portion For Review ; l DVP-11 D Manual and Motor-Operated Review of Manual and i Valves Motor-Operated Valves in CT DVP-11 E Containment Isolation Review of Containment Isolation Valves in CT DVP-11 F~ Piping Design Review of Piping in CT DVP-11 I Containment Spray System Selected for Review DVP-11 V Component Cooling Water System Interface with CT DVP-11 Z Demineralized / Reactor CT Interface with -q Water Makeup Demineralized Makeup j Water for Spray Risers The Power Systems review will also include a review of selected previously identified concerns. I l l l 87-EA-047/EA306 4.1-40 J
7 r 4.1.8.2 Safeguards Scope ! The Engineered Safeguards scope includes the evaluation of: o Containment Accident An61yses for devel(pment of containment design and environmental conditions o The Containment Spray System's ability to mitigate the accident conditions o Responses to high Energy Line Breaks (HELBs) in the Safeguards building for inputs to environmental qualifications These pressure and temperature analyses typify the work done by the Engineered Safeguards discipline and are a good basis for assessing the overall adequacy of the design analysis process of the group. The analyses for the Containment will be evaluated for selected reactor coolant system breaks (e.g., hot leg, pump suction, and cold leg). The review includes the many parameters that are input into the analyses, such as containment volume, heat sinks, blowdown release rates and spray system. characteristics. The containment encloses the reactor system and to tl:e firal barrier against the release of significant amounts of fission products in the event of an accident. The design and siting of containment systems ere largely based on the pressure and temperature conditions which result from the releases of reactor coolant following a postulated LOCA or MSLB. General Design' Criteria 16 (Containment Design) and 50 (Containment Design Basis) provide the basic functional design requirements for the containment, and provide a basis for review. The Containment Spray System will be reviewed as an integral part of the overall evaluation team emphasis on this system. The effects of the spray system on the' containment pressure and temperature analysis will be examined; this includes the capability of the spray water to remove heat . from the containment atmosphere, considering the spray drop size ( distribution and to provide uniform spray volume coverage. ' The Containment Spray System provides the dual safety function of removing fission products from the containment atmosphere for the purpose of i mitigating offsite doses after an accident. The effectiveness of the spray l droplets to remove iodine will be evaluated. The licensing basis for this evaluation will be GDC 38 (Containment Heat Removal) and 41 (Containment Atmosphere Cleanup). The pressere and temperature response to HELBs in the Safeguards Building will also be evaluated to establish environmental conditions and inputs to HVAC evaluations. HELB analysis was performed by a contractor other than the one who did the containment analysis, and the pressure and temperature ) results are used by other disciplines for the design of safety-related 1 systems, equipment, and structures. 87-EA-047/EA306 4.1-41
]
' - The^ evaluation of the HELB in the Safeguards . Building (which contains high energy blowdown and volume control . piping) forms an integrated evaluation with the ' design of the Containment Spray System located in this building and by the structural evaluation of the Safeguards Building design. lC Typical parameters of 'the . analysis that will be examined are blowdown release rates, subcompartment volumes. vent areas and loss coefficients. The licensing basis for reviewing HELBs is GDC 4 (Environmental and Missile Design Basis) as-it relates to environmental protection. Activities to be Reviewed
- 1. Containment pressure and temperature transient responses due to the pipe breaks that result in the highest pressure and temperature will g be reviewed in detail to ensure that the peak values do not exceed design values. Other pipe break analyses will be reviewed to assure
.that the worst breaks have been analyzed.
.2. Input data for the analyses will be reviewed to assure that they are consistent with input documents: Typical data include containment volume, heat sinks, spray system parameters, blowdown release rates, initial thermodynamic conditions, and spray water thermal equilibrium effectiveness.
- 3. The spray water ef festiveness calculation relative to the removal of fission product iodine will be reviewed. This calculation .provides input into the offsite radiation dose calculation.
- 4. The HELB analysis that produces the maximum pressure and temperature in the Safeguards Building will be reviewed to assure that design values are appropriately established. Aspects of the analysis that will be examined include the nodalization scheme, break types and locations, blowdown, initial conditions, volumes, vent areas, loss-coefficients, pressure and temperature response transient, break detection, isolation capabilities, and the safe shutdown capability following the accident.
- 5. -Assumptions, methodology, and computer programs are reviewed to assure that they are technically adequate and consistent with licensing commitments.
- 6. Analyses will be reviewed for consistency with licensing commitments, such as the FSAR and SERs, and General Design Criteria.
Interface Activities Instrumentation and Controls: Monitoring systems . to detect and isolate breaks, response time of systems, failure modes and effects analyses to assess single failure and safe shutdown capability. 87-EA-047/EA306 4.1-42
i!-
. Power:
1
. Containment 1 spray system data, . such as flow rate,> heat duty, pump .
NPSH, initittion time..
-Engineering Mechanica:
; Pipe break locations.
'NSSS:
Mass and~ energy blowdown. rates for LOCA and;MSLB. Walkdown Activities
- A ' site .' walkdown will' be performed to collect information to support the
.HELB modolization. model review, such as, vent areas and flow path restrictions.-
Safeguards' Evaluation Documents. The safeguards evaluation includes portions of th9 following Design Basis Documents-(DBDs) and Design Validation Packages (DVPs). DBD or DVP No.- Title
. DBD-ME-007 Pipe Break Postulation Effects DBD-ME-008 Containment Analysis.
DBD-ME-076 Postulated Environments for Equipment Qualification DBD-ME-232 Containment' Spray System DVP-11 I Containment Spray System DVP-12 G Containment LOCA and Main Steam Line Break DVP-12 H Containment Fission. Product Removal ,,1 87-EA-047/EA306 4.1-43
4.1.8.3 Materials The Materials Section of the evaluation will focus on the technical adequacy of materials of construction for their intended service. The materials to be reviewed include metallics and non-metallics, such as insulation, seals, gaskets, and protective coatings. Determination of technical adequacy is based on the following:
- 1. Materials selected are appropriate for the intended service.
- 2. Procurement requirements for materials are technically adequate.
- 3. Fabrication practices (welding, brazing, bending, etc.) are adequately specified.- I
- 4. The effects of se rvice conditions were adequately considered, such as corrosion and embrittlement due to radiation.
- 5. Adequate non-destructive examinations were specified.
- 6. Sa: isf actory ' controls over non-permanent plant items (i.e.
marking crayons, inks, lubricants, cleaning solutions) in contact with plant materials were specified.
- 7. Adequate controls were specified for cleaning of fluid systems and maintenance of cleanliness.
- 8. Procedures for fabrication are adequate to assure that technical requirements were satisfactorily implemented.
Systems and components for the evaluation will be selected from those identified for review by other disciplines comprising the evaluation team. The scope of the evaluation will be expanded beyond these systems and components, where necessary , to obtain a representative sample to evaluate the listed attributes. The evaluation will include review of design documents to determine whether the Regulatory Code (RG) positions, as presented in the CPSES FSAR, have been adequately implemented:
- 1. RG 1.31 Control of Ferrite Content in Stainless Steel Weld Metal
- 2. RG 1.36 Non-metallic Thermal Insulation for Austenitic Stainless Steel
- 3. RG 1.44 Control of the Use of Sensitized Stainless Steel
- 4. RG 1.50 Control of Preheat Temperature for Welding of Low-alloy Steel
- 5. RG 1.85 Materials Code Case Acceptability - ASME III Division 1.
87-EA-Ol7/EA306 4.1-44 y
- t. .
- l. Materials Evaluation Documents l'
( The ' Design Basis Documents (DBDs) . and Design Verification Packages (DVPs) to be reviewed will include those selected by the other team disciplines ., i which contain requirements for materials, fabrication, non-destructive examinations, installation, cleaning and/or protective coatings. I
- i 1
4 1 1 87-EA-047/EA306 4.1-45
- 4.1.8.4T Radiation Protection (Safety related design activities associated with .the Containment Spray System, Safeguards Building and Control Room HVAC' system have been selected to provide a ' comprehensive basis for the evaluation of the overall-
- radiation protection design process for CPSES. The major aspects of the radiological design evolve around the following activities: calculation of the quantity of radioactivity in the core, systems, etc.; assessment of the
. release and distribution of this radioactivity during normal operations and accidents; calculation of-the-dose impact to personnel and equipment; and determination of 'the radiation monitoring capabilities. for detecting, recording ~ and ' providing necessary control functions in response to high levels of radioactivity.
Topically, these activities are further ' broken down and will form the framework for the evaluation. The radiation protection review areas are as follows:
- 1) . Radiation Source Term Development
- 2) Offsite Radiological Accident Analysis
- 3) Control Room Habitability Analysis
- 4) Radiological Environmental Qualification
- 5) . Shielding / Dose Rate Analysis 6). Radiation Monitor Design A description . of the . type of calculation, specification or other design activity to be ' included in the EFE is provided below for each radiation .
protection review area. A summary of the evaluation plan is shown in Table
- 1. This table highlighto the major design interfaces and the important design documents. I i
l
- 1) Radiation Source Term Development This area will include an evaluation of the calculations for development of the post-accident liquid. and airborne radiation source terms and the design 3 asis source terms for normal operation, which are used for radiological environmental qualification. Westinghouse source term data as provided in the " Radiation Analysis Design Manual" will be reviewed as part of this effort. In addition, system parameters which are important to normal operation source term development, such as flow rates, filtration efficiencies, etc. will be reviewed.
- 2) Offsite Radiological Accident Analysis 1
The Containment Spray System provides iodine removal from the containment atmosphere during post-LOCA conditions. The reduction in airborne iodine I is incorporated into the radiological offsite dose analysis and will be included in the review. Also, the radiological accident assessment l methodologies will be evaluated to assure compliance with 10CFR100 offsite dose limits. lodine removal data such as containment coverage, time dependence, and removal rates, as generated by Nuclear Technology / Engineered Safeguards, will be reviewed to assure consistency with Nuclear I' l, 87-EA-047/EA306 4.1-46 l I E - 1
l V Technology / Radiation Protection evaluations. Also, the overall radiological' accident analysis will be reviewed to assure proper incorporation of meteorological and system design data. 3)- Control Room Habitability Analysis The assurance of control room habitability during design basis accidents will be reviewed. The calculations which develop the integrated doses for the duration of the accident will be evaluated to assure compliance with 1 General Design Criterion. 19. HVAC system design information will be reviewed to assure consistency of flow rate, filter efficiency, and other design data. Meteorological data will also be reviewed.
- 4) Radiological Environmental Qualification The radiological calculations which support the qualification of a selected sample of electrical and. mechanical components will - be reviewed. A representative sample of the calculations will be selected for components within the containment 'as well as for the Safeguards Building. The methodology will be evaluated to assure consistency with the source term data and accident models. Interface of the data into the EQ Program will also be reviewed.
A site walkdown may be required to verify the exact location of radiation sources and shielding structures in relation to the qualified component and to verify that all radiation sources have been considered.
- 5) Shielding / Dose Rate Analysis Dose rate analyses will be reviewed from a shielding technique / methodology standpoint and will include sufficient detail to evaluate the adequacy of the standard shielding design methods, that is, point kernel, discrete ordinates, Monte Carlo and analytical methods. A representative sample of safety related dose rate analyses, which have been performed as part of the accident analyses or EQ, will be reviewed.
This effort will also include a review of the post-accident vital area , access studies, as required by NUREG-0737, Item II.B.2, if applicable to ! the Safeguards Building. l 6)- Radiation Monitor Design The control room intake monitors will be reviewed, including the purchase specification and setpoint analyses. The monitor design will be reviewed for detection and isolation capabilities to assure consistency with the HVAC system design and with the control room habitability analyses. 87-EA-047/EA306 4.1-47
I, uaD . o o d ,- o3 G s g 1 i6 i 7 n 7 i 1 t 6 t , 32 e9 3 t2 t d n c4 p8 nri n c44 e e ,7 0 5 p 7 0 c1 e aas o S51 S 5. 19 G - 1 A1 - S& vd n i G e ne Rt . E . R . E R5 l ac A c A 6. R C A R A et i S e S5 . R 6. C S5DU R G. A G. S U S1 RSL FS F1 R . F1 CNR FR N F1 s C DH DY B A e 'P - - - - - - A - l V 2 22 2l 2 / 2 bD 1 1 1 1 I 1 N 1 a c i l 5 72 ps 2 23 3 01 3 p 0 02 0 33 2 A 'D - - - 0 00 0 B E EE - - - A' - D M MM E EE / E M EE N E s i s s i y s l y al l Y na a R Au nn A n A o M e na i M c oM t t t U a i nan S f r t n ag e me d rm 1 N S e ii i ou A S t d s A cf c A A A EL S n ae / cno / / / LP NI RD N AI D N N N B . AN TO I T A ,sm , U C L ,ye A y , A e d sgt V g l l V ne ed os H o a a E i c rrl y l c c l a s eaoS - o i i
- pf -m e ur C r r r rir r e ngorA ro ee t r e
tC c ece et i eeeV c t st nin ws oy gf t wH naeo wt oe l e w o l e& I DI PS ESMP& PM E P EI s t n n e s s s y o m mn ro n o n o n o nd ou i t u c ei i i i gi t a ,o y Tt t t t t t ntS ct sd t a na na a i a i ni f is r ni el el el l dl s gv cu d u d u u l us i oyo ii rc i c i c c ece c pl d st ul cl cl l il c et an ec oa ca ca Qa h ac pe ne DA SC AC AC EC SCA SSAV s r et i o cn s t re y e i um op l a l my l ao l n ss oi n o a S o an ot at i D s M e l cA oi cnt / y r ne i Rl i ea gl n A ov gt i s gmc na o i e eon lbi oni i n i w t D t l e oas l of dA t n ag e a i od rt y ori l i i m sii t i l iil ee i i v d r f d c nb a d va it d s e ae f ac oan anu h a ae R RT ORA CHA REQ SR RD
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1 2 3 4 5 6 l
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4
~ 4.1.9 Structural' t
The evaluation of the Civil / Structural design process! at Comanche Peak Steam Electric Station will concentrate on three major areas of. review. A building system will be reviewed from development of loads and inputs { from. the design stage through the ! installation and design control process. Structural components required to assure functionality of the -l chosen be I system (s) for . evaluation .will also evaluated- from verification . of inputs,- - through the design process, including ) discipline 'interf ace. In. addition, designs of other unique items not reviewed during the two evaluations listed above will be reviewed in q sufficient detail to assure compliance with design requirements.. Ej J In1 general, the evaluation of each of the items ' listed - below will include reviews of: o Pertinent FSAR sections and other licensing documents against- I appropriate regulatory guide o Applicable design criteria to assure inputs are consistent with commitments o ' Inputs to the design process.to assure inputs are consistent with commitments o Computer programs-to verify program validation and use within the. limits of the program o Calculations to assure technical adequacy and consistency with licensing commitments o Specifications and vendor documents to assure consistency with design requirements o Design and construction drawings - to assure consistency with design requirements o Change documents (DCAs and NCRs) to~ assure resolutions are technically adequate and consistent with licensing commitments o Design documents to assure thac resolutions to previously identified concerns have been adequately implemented BUILDING SYSTEM An in-depth evaluation of_the design of the Safeguards Building will be conducted. Selected aspects of the design process will be reviewed in detail using a representative sample. The size of the sample and the ; [' scope of the review will vary with the complexity, uniqueness, and l l importance of the design step. The size and. depth of the evaluation l ! will be sufficient to assure the analysis is performed in accordance ; with design requirements. , 87-EA-047/EA306 4.1-49
- l. ;
.l I
i The .. Saf eguards Building was chosen for . this . review because it - is representative .of. other safety-related buildings. The Safeguards Building.'is a complex non-rectangular building containing numerous j
<i: walls,, floors, columns, structural subsystems, and ' houses heavy equipment and = interf aces with adjacent structures. It.is subjected to loads identified in the FSAR such as: wind loads, tornado loads, . HELB j loads, pipe whip and jet impingement loads, hydrostatic pressure loads, )
internally generated missile loads and seismic loads and could have -{ significant. torsional response. 1 In' addition to the detailed _ review of;the Safeguards Building, selected portions of otherl building designs will be reviewed to assure. typical ; types of designs considered in nuclear plant design have -been evaluated. q l The following items will be reviewed with regard to the building ' '[
. analysis.
' Design Inputs
- o. Soil Parameters Soil parameters used in the analysis will be reviewed to assure consistency with site soil information and licensing commitments.
Soil properties such as shear wave velocity, density, and poissons ratio will be evaluated concerning appropriateness of the selected value, interpretation of the value and use of the value in design. o Seismic Input Inputs .to the seismic analysis including soil. springs and dampers from the soil-structure interaction model' and the time history used in the analysis will be reviewed. Each of these inputs will be reviewed for technical adequacy and consistency with licensing commitments. The review will include parameters such as soil damping and.embedment effects. o Other Loads Calculations of tornado pressurization loads, HELB loads, pipe whip restraint loads, and jet impingement loads will be reviewed to assure that the results of the designs are consistent with the loads applied to the structure. Loads due to selected maj or pieces -of equipment and attachments to the structure will be reviewed to assure that the loads applied to the structure are consistent with vendor documents and system calculations. Loads due to internally generated missiles and HELB will be evaluated. Building Model Calculations of building mass and stiffness will be evaluated to assure technical adequacy. In addition, any interfaces with NSSS will be reviewed. 87-EA-047/EA306 4.1-50
;i; 4 .
.]
Seismic Output- !
. Selected response spectra.will'be reviewed.for consistency with design inputi and licensing commitments. . In. addition, displacements will be ;
L . reviewed to' ensure consistency-with building gap availability. ] l^ i ! Building Design: ;
. Design calculations will be reviewed to-assure technical. adequacy and. .j consistency .w ith licensing commitments. These calculations will l include. soil bearing evaluations, design of floors, beams, slabs,' walls j
, and columns. They also include evaluations of shear walls,-concrete '
block walls, exterior walls and the roof. !
- .1 > -REVIEW OF COMPONENTS ASSOCIATED WITH SELECTED SYSTEM In, addition to L the in-depth evaluation . of the Safeguards Building, design of selected components _ associated with the systems chosen
- for review ' will ,be o evaluated. The number of . components selected will'
' depend on the . complexity of the components, the safety significance of the components, and the number' of different configurations of the component. However, in all cases the sample will be selected by.
engineering judgment in a manner which will ensure that the analysis is performed in accordance with. design requirements. The following component types associated with the chosen system will be reviewed. HVAC Duct and Supports A review of representative supports for the selected HVAC system will be conducted. In addition to the General Review, the following will be evaluated: o Response spectra for the appropriate ' location is used in the design o Damping is consistent with design requirements o Load combinations are consistent with licensing requirements and design codes o Differential floor displacements are considered when applicable o As-built drawings are consistent with validated design criteria-
'o ' Connection of the duct to the support is addressed in a manner consistent with design requirements o Structural adequacy of the duct is addressed in a manner to assure the ability of the duct to perform its intended functions 87-EA-047/EA306 4.1-51
l t 4 REVIEW OF OTHER ITEMS' Selected designs 'of other items will be evaluated for c e tstency with design criteria-and licensing commitments. These; items include designs which are typically encountered in nuclear power plant design but which Lare not; reviewed during the building or system evaluation. These items include: io Heavy Load Drop Analysis.
~oL Containment Liner Analysia o Co'tainment n Penetration Analysis o Overhead Crane Girder and Supports o -Concrete Block Walls o Embedded Steel Plates o Interfaces'with NSSS' In all cases, the items listed above will be evaluated using a sampling
-approach.as described previously.
STRUCTURAL INTERFACE ACTIVITIES The Civil / Structural Group interfaces with various functional groups in the design and analysis process. The intra and inter division activities L are usually in the form of transfer of design documents. The key . document provided by the Structural Group is ' the Amplified Response ' Spectra (ARS) for specific building locations. In return, loads developed using the ARS are supplied to the Structural Group for use in the design of.the plant structures. This process applies to the interfaces with Engineering Mechanics regarding equipment and . mechanic 61 systems and with Electrical regarding electrical systems. )
- )
In addition, other parameters are supplied by various groups to the- l Structural Group for consideration in building design. These inputs 1 locations of equipment; fire protection and separation include criteria; flood, pressurization .and. thermal transient. loads; and
)
hazards . analysis. In return, the Structural Group provides wall and floor thickness and other pertinent information about the plant , structures. The interface process will be evaluated by conducting reviews of: o Selected design inputs such as ARS, furnished by the Structural Group for use in design and equipment qualification, to assure that they are consistent with i y criteria. o Selected equipment and system loads furnished to the l Structural Group to assure they are used in the design l l process consistent with applicable requirements. 87-EA-047/EA306 4.1-52 l l _-_.m _m.m. _.--._.___s___ _ _ ..__ m m _ _ _ _ _ __
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, ' o. Other . selecte'd ~ Inputs ' supplied . to .~ the Structural Group to assure incorporat' ion- in 1the .' design process consistent with
~
~
design criteria. , x 1 I
- o. ; Selected- procedures concerning interfaces and 'information-transfer to assure consistency with design criteria.
Cable Tray and" Conduit Supports, Selected cable tray'and conduit support designs will be. reviewed to the .
- extent 'necessary to Jassure interfaces are consistent . ' with design requirements. -The evaluation will' determine if:-
.o; Inputs ' to ' the analysis,: such as response-spectra, are consistent with' design' criteria.
o' : Design documents-are consistent.with as-builts.
- o. Outputs.-(loads) have been transmitted to the civil / structural.4 discipline.
'o Seismic interaction ' evaluations such as proximity concerns and- ~
cable sla'ck concerns will be reviewed for technical adequacy and' consistency with design. criteria. Equipment Selected. equipment will be reviewed to assure seismic inputs transmitted - to the discipline performing the . equipment. qualification are. consistent with design criteria and that loads from the . equipment areLapplied in the. appropriate structural design. Hazards In conjunction .with the Hazards Evaluation, the structural discipline will review the~ evaluations of the following conditions. o Seismic ? II/I evaluations will be reviewed to ensure completeness-and technical adequacy of the review. o ' Fire barriers required for separation of redundant components will be evaluated- with regard to fire rating of the barrier including penetrations and doors. STRUCTURAL SITE WALKDOWNS In conjunction with the reviews described above, site walkdowns will be conducted to gather information required to verify the following
' items: .
o Significant equipment loads are accounted for in the building h .model. j .- l1 87-EA-047/EA306 4.1-53 _ - --__-_-_-_A
e m. - o 1 l o- Significant attachment ' loads are utilized ' in wall, floor, and-
. column design.
o Areas of openings andyflow paths.forLtornado pressurization loads-and.HELB loads are correctly modeled.
.o. _ Equipment.is protected or isolated from pipe breaks.
o : Doors' are Lin the.. positions required by fire protection and depressurization analysis.- o Penetrations and cut reinforcing are considered. o: . Equipment is installed per vendor requirements and consistent with (tested configuration.- o- Equipment anchorage is' adequate, o Cable ! tray, ' conduit and HVAC supports ' reviewed are typical of those throughout the plant. o Fire ratings of fire. barriers including doors and penetrations are as specified. o- Seismic' interaction considerations are taken into account. o . Seismic. Category II equipment is seismically supported using II/I criteria. o Openings in exterior walls or roof are covered by missile shields, o As-builts are correct and complete. The depth-of the review will be consistent with the overall scope of
.previously discussed activities.
Structural-Evaluation Documents The following is la list of Design Basis Documents (DBDs), portions of which will be evaluated for technical adequacy and consistency -with FSAR commitments. DBD No. Description DBD-CS-074' Containment Liner and Penetrations l-DBD-CS-081- General Structural Design Criteria l DBD-CS-084 Other Seismic Category I Concrete Structures
- -\
DBD-CS-085 Seismic Category I Structural Steel 4 DBD-CS-086 HVAC Support Design 87-EA-047/EA306 4.1-54 a
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- DBD-CS-087'; ' Moment'Rescraint. Design.
.DBD-CS-092; ' Seismic': Design Parameters and Response Spectra-
' Generation
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DBD-CS-094' sComputer: Programs- Used in', Dynamic and' Static Analysis
- The,. following is La .: list of Design Validation ~ Packages -(DVPs),~ portions of; which . will - be-:: evaluated f .for technical adequacy, . consistency with iFSAR commitments and/or appropriate inter-discipline interfacing. This i
.. evaluation will ;be performed ; by sampling those items identified with-the Lselected- system / structure or, special areas- of. interest - as.
previously discussed within:the evaluation plan. DVP No. Description 09D: -Safeguards Building 09H' . Seismic CAT I. Structural' Steel 09J .- . Pipe Whip Restraints.
- 09K> Containment Liner & Penetrations 09M Miscellaneous Equipment Supports
'09T- Seismic Analysis Verification (ARS) 09U- General Civil / Structural' 09WE Structural Specifications 87-EA-047/EA306 4.1-55
_a- _---- --._-_o ________-u__._. _
4.2 DESIGN DATA UTILIZATION - TESTING Purpose The purpose of this module is to perform a vertical interface eval-uation to determine if the engineering parameters generated or validated in the project Corrective Action Program (CAP) have been adequately verified in the CPSES Test Program. Scope and Approach The approach for this module will mesh closely with the approach taken by the Design Completion Activities, as described in Module 4.1. A review of Design Validation Packages (DVPs) and Design Basis Documents (DBDs) will be performed to identify those inputs to the. test program that will be verified. Applicable CPSES FSAR and other Licensing docuttents will also be reviewed for test program verification. For those selected inputs, this evaluation will determine if: o Appropriate test procedures have been developed, performed, approved or-scheduled for retesting. o The test procedures properly incorporate the acceptance I criteria, vendor requirements, and design requirements. o The test procedures satisfy FSAR and other regulatory requirements. o Test results have been clearly documented and analyzed against the acceptance criteria and that appropriate corrective / preventive action has been implemented if the results were not satisfactory. o Appropriate periodic or surveillance testing is to be performed consistent with licensing commitments or engineering data. o Tests have been performed to the latest engineering and design documentation or dispositioned as no further testing being required. o Setpoints have been properly incorporated into the surveillance and calibration reports. Documents to be reviewed for this evaluation will include the following: o Mechanical, Electrical, and Instrument and Control generic test procedures o Vendor documents o Project Specifications 87-EA-047/EA306 4.2-1
l l o FSAR and other Licensing documentation o INPO documentation o Preoperational test procedures o Test Exceptions o Test Deficiencies o Surveillance Test Procedures o Technical Specifications o Retest Schedules o Maintenance Activities l o Setpoint Programs Discussions between other Engineering Functional Evaluation (EFE) Proj ect Discipline Engineers will be held to identify other test program inputs that should be evaluated. Discussions with the Client will also be held to cover any additional concerns to be included in the evaluation. The evaluation team consists of senior start up and test engineers who have previous experience with nuclear power plant test programs and who are certified to Level III in accordance with ANSI N45.2.6. The team also includes persons with operating phase testing experience who will review . implementation of surveillance requirements. These personnel l are independent of direct Comanche Peak activities. l Preparation Phase I - DBD and DVP Evaluation The DVPs and DBDs selected by the Engineering Functional Evaluation Team Discipline Engineers will be reviewed to determine which engineering parameters or attributes, will be evaluated under Module 4.2. The most recent CPSES Test Program activity will be used to determine whether the attribute has been adequately verified. For example, the entire test program evolution from construction testing, through component testing, preoperational testing, or integrated systems testing will be reviewed as required to verify the attribute. The end of Phase I will result in a detailed checklist. of the attributes to be verified. This checklist will also list the Discipline Interface and the Group (i.e. Test or Operations and Maintenance) responsible for the attribute evaluation. Typical test program attributes are listed in Table I. 87-EA-047/EA306 4.2-2
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' Phase'II - Test Program' Review g
. IO
. Available test ' program documentation will be . reviewed?to ensure that the validated parameters have been used or will be used in the CPSES-
. te'st ' program. ; Reviews ' will; include using the available site Document Contro1L facilitses,gvendor. manuals, computer . lists, Letc. Discussions-
- will also be conducted.with ' appropriate organizations as required.
- Phase III - Summary Analysis- ),
This' phase will. summarize the' findings that.were identified'during the C , 'l test program evaluation.: Table 1 4
\
Typical' Inputs to Test Programs ; i 3 1 4
- 1. Setpoints for instrumentation i Ns l 2.- Valve. stroke times (ASME XI, Appendix J 10CFR50)
I ,,
- 3. Unique leakage' rates assigned to valves or to systems
- 4. Pump performance (rated, emergency,. recirculation, minimum performance for ASME XI concern) :n > ,
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- 5. . Particular test method per Regulatory Guide / Standard'
'I
- 6. Conformance to engineering model
- 7. Relief valve setpoint Breaker trip times and current. valves
~
- 8. !
- 9. System realignments
- I
- 10. Performance parameters for HVAC- Systems (airflows, cooling, -j humidity, and heating specifications, etc.)
- 11. Maximum-loadings on buses, diesels, etc. ,
- 12. Response time testing for instruments in protection systems. -)
Potential DBDs for Test Module ; P ME-003- Control Room Habitability EE-004 R.G. 1.97 (Operations Tie) ME-008' Containment Analysis l 87-EA-047/EA306 4.2-3 i 1 l- '. L. _ _ ~ _ ___ _ m. __.___________._______ _ _ _
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, .f ;( ME-010i Instruction:for Revision to Pipeline..Desir, nation- 1 W .,. ,
' List ~ JO f lff lq' ' T,ME-011'- R .. ,
' Emergency Diesel; Generator'~ ,
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- .ME-013- , -ContainmentoIsolation i
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y .J Active.Pumpfand' Valve Qualification (list of-
':j/ ' .ME-018 j
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/e ! components 'only).
1 o .e - .. s ee4 4i EE-021. M c. .f'v >
' Reactor Control.and.a Protection'. Problem-1.
j [ ,$
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,M'. ME -027 . '
Radiological Accident'Analysia. 'l
, p,; ; '":v, EE-035 g. Instrument'Insta11htion ,
[Ii.f 4 [" g , h :EEiO37 Setpoints-4.( W 4 . . 4 :
- Onsite Power System'
$' 'f g . EE-039 L @, cj.6. ,
n (also particular, distribution systems to'ba-
- 0\g W 'det' ermined later) .
EE7051 < Llh Motor + Protection
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O H iCS-074' "CcMsainment Liner and Penetration 1 O LME- 102 q LObAAccidentAnalysis-M[ 'O 3$.i _ . ME-103 NOW.;LOCA Accident Analysis f
, ME-232 Containment Spray S_ystem- . .
ME-30'4 ', Control Room Air Conditioning a j .'t \'
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, 4.3 , DESIGN DATA' UTILIZATION - MAINTENANCE AND OPERATIONS
-GENERAL-INTRODUCTION' Although thel scope ofLthis module =is outside the boundstof the specific corrective actions of the CPRT Program Plan, it is significant because it ? completes the' verification process with respect to. appropriate use of: engineering data.
.t
, PURPOSE-Operations Tlie purpos'e of l the Operations evaluation is to provide assurance that validated engineering data and as-built documentation have been used in
-thel development of=~ normal and off-normal operating procedures and system' alignments, .and- that plant configuration and ' accessibility o provide' plant personnel with the capability of performing operations
- assumed by engineering.
Maintenance
; The~ purpose of ~ the Maintenance evaluation is to provide. assurance that
, validated. engineering data have been used in the development of maintenance procedures, such that safety system functional capabilities.
. and readiness, as defined by Technical Specifications and engineering data, is maintained.
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.Operatiom The evaluation will be accomplished by reviewing operating activities and procedures associated with a safety system. The evaluation will start with the accumulation of baseline information which describes the system's original design, licensing bases, .and modifications. This information will be obtained - from the Design Completion Activities module and from a review of system commitments. The primary emphasis will then be placed on the evaluation of operating procedures and operator training as they relate to maintaining the functional 4
capability of the system. The evaluation will determine if: o Operating procedures (systea, general plant, abnormal and emer-gency) affecting the safe operation of the plant safety system being evaluated have included appropriate / validated . requirements from plant licensing commitments, Design Basis Documents, design
'and procurement specifications, Codes and Standardt, and manu-facturer's requirements.
o System modifications have been reflected in operator instructions and training. l 87-EA-047/EA306 4.3-1
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; TheJevaluation :will- be accomplished j by. a review and . assessments of maintenance ' requirements for .'a se?dicted: safety system. . The evaluation ~ ,
H ' willy start ; with the: accumulation . of 2 baseline information' which fdescribes o systemi maintenance requirements . and . licensing commitments, 3 the. systems' design',Jlicensing bases,cand modifications.' The, 6 imary emphasis will ~ then be' placed on maintenance'. requirements [relited > to , . . j L maintaining the afunctional capability of the . sys tem. , Thpf evalua.t(c,y , Q' ie will determine if: ,
/ 34 e
,,4: i g {' -i' o, - Maintenanc'e procedures have. been developed' utilizing . r'Jhi;ements- #
from.f licensing' commitments, Design Basis rocuments,, desigund .[ procurement specifications, Codes and Standards, and manufacturers , , requirements.
/ .L b( n d i.
o , Post maintenance' testing verifies that the system 1s capable.of E
- meeting design basis- requirements and : is thus- ready' for return tol
_ service. . l
.o System components necessary co maintain system' reliability. and operation' areL included in- the program, ' and scheduling is consistent with manufacturer's recommendations, o Spare parts meet engineering requirements.- 1 j
o, Interfaces between Engineering and Operations and Maintenance are , sufficient to assure engineering re_quirements are' retained during performance'of maintenance.
' Documents to be Reviewed in'~the Evaluation: -
The , following documents are representative of those to be g" reviewed in # the: Operations and:Maintena'nce Evaluations .t'ofdetermine if engineering data has been. utilized: .n , e .c o- Plant Startup and Shut-down Procedures - o Sy;stemOperatingFjocedures-
'/ , j o- System A1,.sgment" Checklist j . ,
o Alarm Response Procedures 1 J p e v Abnormal! Operating Procedures , I '
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'i o Emergency Op sting Procedures' o Administrative Procedures and herating Orders }
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o Station Logsq
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< <" l o Surveillance - Tes ts , including results o f, performance testrh l required by ASME XI.
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/o .d Temporary Modification Log
~o - Tag Out Log 4
W o9 Portable Instrument Issue Log (to determine that calibration and accuracy are appropriate to validate engineering data)
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i- ol Maintenance Procedures o Maintenance Schedules e o Operational Drawings N o System Descriptions i o Training Plans k s i
. APPROACH Preparation for ' the evaluation will be done in ' two stages. The first stage will primarily involve familiarization with the various types of system operating procedures and design' modifications, the plant maintenance program and any TU Electric concerns to be included in the scope of the evaluation. The team shall. be composed of personnel experienced in operations and maintenance program development and implementation. .The second stage of preparation will ~ include indoctrination and orientation of team members; accumulation of design, licensing baseline, and operating and maintenance information; development, by team members, of 'the detail checklists (Review Plans) to be used during the evaluation; and review and approval of the Review Plans by the Team Leader.
Safety system requirements identified during the Engineering evaluation or from a review of station source documents will be placed on a matrix of operations and maintenance attributes. The matrix will initially contain the source and text of the requirement. For each attribute a i plan to verify implementation will be added. This will represent the Operations and Maintenance Review Plan. The completed Plan will include the number and section of the implementing document or procedure, a description of any field verification accomplished, and a statement.of assessment for each attribute. Details of Approach to Assessment General plant . and system operating procedures will be reviewed to determine if values derived from the design review have been addressed, and that operating steps will achieve the requirements and objectives jt described in the FSAR. Off-normal and emergency procedures will be l reviewed to ensure that procedures are available for anticipated I equipment f ailures and all accidents addressed in the accident analysis requiring use of the selected system. System alignment checklists will
< be reviewed to verify that alignments assumed in the accident analysis L are implemented.
g 87-EA-047/EA306 4.3-3 1 . ([ L
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gy ) q O. , k General plant. operating' procedures will;be' reviewed'to. determine if
,' :necessary.! surveillance' requirements .needed.. to ' verify system
; availability 4during ' mode; changes, proceeding through heat-up ' to power V ,
.operationi, are identified. General operating > procedures will- also be
. reviewed to confirm that system alignment checks are complete prior to
' heat-up..
~
Equipment" turnover' to 1 maintenance will be reviewed to confirm ' that :
' system engineering;' requirements as reflected in the: Station Technical:
Specifications are maintained as. required 1for . the present operational
; , mode.'
Selected . industry . operating experience items : relating' to the selected system'will be verified.to have been processed.in accordance with NUREG 0737. This review will determine ; if ' industry j experience items which
;relatet to . Engineering data' have been addressed ' - in operations, maintenance or. training as applicable.-
Temporary Modifications. will be reviewed to' determine if the-E modifications' have been reviewed against engineering ~ requirements.
' ~
L Records will be reviewed to verify that temporary modifications'are not-L installed longer than time limits imposed- .by- the Technical Specifications. Station logs and surveillance ' tests will be' reviewed and checked , against. established engineering requirements to verify that key system h . parameters' are monitored, and alert values' are consistent ~ with l'- engineering data.- The tag out log and portable l instrument issue log will be reviewed , to
.further; verify interface programs. which maintain engineering requirements.
18 Maintenance procedures and schedules will' be reviewed to determine if system safety-related components' are included in the preventive maintenance program, Land procedures are prepared. Training plans for the selected system will be reviewed to determine if , operators are provided with sufficient information to ensure effective .j use' of procedures. System descriptions used in training will be reviewed to determine if operators are provided with sufficient information in the use of system instruments and controls. l l Following an in-depth technical review to determine implementation of ( l engineering 'and technical specification requirements, a site walk-down will be conducted to complete the verification of selected attributes.
]
. Typical items that may be confirmed during walkdown are as follows: i i
o Locked valves and power-lockouts are consistent with engineering data and station commitments. 1 o: Calibration requirements are appropriate for instruments used in system testing. 87-EA-047/EA306 4.3-4 _ _-_ _ - _A
- g. ,. . _ _ _
i l . ,j, x t - i o' Access to equipment is. adequate to provide for operations required ; by;the safety analysis. i 1 i 87-EA-047/EA306 4.3-5 i _ _ _ _ _ _ _ . _ _ _ _ _ _ 4
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4.4 OPERATING PLANT DESIGN CONTROL PURPOSE The purpose of this module is to establish confidence that TU Electric Nuclear Engineering is prepared to control design activities during plant operations, and to avoid problems with design control similar to those which occurred during design and construction of Comanche Peak or , experienced by other utilities during operation of nuclect power plants. SCOPE AND APPROACH Engineering's readiness to control design activities can be established by determining the completeness of the engineering procedural system with respect.to those activities requiring engineering involvement. As ' a basis for this assessment, SWEC has provided a list of key engineering activities which are. typically addressed in an operating plant design program (Engineering Activities List). These activities have been divided into the following two categories: o Management and Organization - those activities needed by management to control engineering. o Conduct of Engineering - those activities ' involved with control of detailed engineering. A third category, not addressing engineering activities but included in the list, is entitled General Criteria. This category is intended'to address criteria which can be applied, in a general sense, to each engineering procedure reviewed during the assessment. Conduct of the assessment will consist of review of the CPSES procedures governing each of the listed engineering activities. SWEC intends to evaluate the completeness of the CPSES engineering procedures by employing Review Criteria Documents (RCDs) prepared for each activity in the Engineering Activities List. RCDs will contain three sections as defined below: Section 1 - Review Criteria This section will contain a narrative criteria statement which identifies the goals; significant criteria; key activities; codes, standards, and regulatory guides, as necessary; expected reviews and interfaces; and any problems areas related to the activity typically present in operating plant design control programs. Section 2 - CPSES Specific Criteria This section will include criteria identified during the review implementation, which are specific to CPSES and in addition to the criteria established in Section 1. This section may also expand Section I criteria if deemed necessary by the reviewer.
<87-EA-047/EA306 4.4-1
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SecEion 3 - Procedures Reviewed ) i This.section will-include a list of all procedures. reviewed during j the assessment which govern engineering's.' role in the activity.
, - The assessmentLwill be conducted in a six step: process. Each of these .l steps is described in detail below:- '[
, 4.4.1: ' Initial' Site' Visit The ' initial site visit is' intended to discuss and finalize the scope,.
become familiar with the CPSES organization and procedural system, and .; discuss and gather information needed for'the assessment. O o 4.4.2 Review Criteria Document Section 1 Development RCDs will be prepared for each activity'and for the General Criteria in the Engineering Activities List. SWEC will prepare Section 1 of. each RCD prior to initiating detailed procedures review. It is anticipated, however, that CPSES has unique programs, design documents, etc.. which may be related to this process but are not included on this list. To. accommodate this situation, during initial stages of the assessment upper . tier TU l Electric documents will be reviewed to identify these additional activities. RCDs will be developed for each additional activity : identified based on TU Electric management policy documents, the CPSES' QA Program, . appropriate ' portions of - the FSAR, and the.
. licensing commitment list.
4.4'.3' CPRT Generic' Issues /NRC Concerts Weaknesses have. been identified- in.. implementation of design processes specifically for CPSES and generically for the nuclear industry. 'To assure TU Electric has addressed the pertinent issues in their CPSES operating plant design control program, SWEC will review-cwo specific areas. The . CPRT generic issues reports will' be reviewed to identify The second area
~
significant -generic -issues affecting design control. pertains to NRC operating . plant industry concerns. SWEC.will review NRC Safety System Functional . Inspection Reports and Safety System-Outage Modifications Inspection Reports to identify major repetitive areas of concern affecting design control. The results of this review will' be tabulated and used as additional assessment criteria. Output. from the procedures review (Section 4'.4.4) will be used to determine whether each of these items has been addressed in TU Electric engineering procedures. 4.4.4 Review Implementation The TU Electric procedures and related documents which will be part of L the review can be divided into three areas, as follows: j. Upper Tier Program / Requirements Documents - Upper tier documents provide programmatic and policy direction on ! the performance of engineering and establish many of the systems 87-EA-047/EA306 4.4-2 < a
used duringIdesign., SWEC-willireview the following documents to
- establish requirements for each activity.
o' FSAR/ Licensing Commitments
- o. Quality Assurance Program Documents o- Nuclear Engineering and Operations Nuclear Policy
.o Nuclear Engineering and Operations Policies ~and Procedures Key Engineering Procedures
' Key' procedures provide direction to' engineering'for performance of
. design activities. These procedures will be the~ central focus of this reviewi 'The.following procedural groups'will be included..
o . Nuclear Engineering and' Operations Policies and Procedures-o Engineering & . Construction Vice President Policies and
' Procedures o Engineering & Construction Engineering Procedures Supporting Procedures Supporting . procedures contain interface requirements between engineering and other CPSES; organizations. These procedures will be ; reviewed to ensure appropriate interface controls are precent and- in. agreement l , with the key procedures. The following procedures and documents are included in this group.
o Engineering & Construction Construction Procedures o Engineering & Construction Projects Procedures o Nuclear Licensing Department Procedures o TU Electric Purchasing Memos o TU Electric Nuclear Purchasing Procedures o Dallas Quality' Procedures / Instruction o Nuclear Operations Procedures o . Records Management Procedures o Configuration Management Program Description The assessment of procedures will involve four activities: ;
- 1. Review Criterie Document Section 2 development SWEC will prepare Section 2 of each RCD to supplement the Section 1 Review Criteria.- Section 2 will address policies, requirements and key interfaces that are specific to CPSES for each activity listed in the Engineering Activities List. Section 2 will also address specific areas that have been problem areas in the past either in - the industry as a whole or at CPSES. Section 2 of the RCDs will be developed in three parts.
. Upper tier documents define programmatic requirements and policies and assign organizational responsibilities for carrying out i
specific aspects ' of these require 7ents and policies. SWEC will . review the Upper Tier Program / Requirements Documents to identify
- j. requirements and policies specific to CPSES and the breakdown of i i, 1 87-EA-047/EA306 4.4-3 l WA--h-__-_m.._____m_ __ _ .
5 J. responsibility for implementing'these policies and requirements. Procedures developed. to contro1 ' activities performed by other TU' Electric organizations define areas of interface with Engineering.
, ;SWEC will review . Supporting Procedures to determine significant
. interfaces required , to ensure appropriate engineering involvement in'the. activity.
To ensure J each CFRT. generic issue and NRC' concern has been addressed by individual TU Electric engineering procedures,. SWEC will identify . on the RCD, those CPRT Generic ' 1ssues/NRC concerns (from.Section 4.4.3), associated with the RCD activity.
- 2. Procedure Reviews
' SWEC ~ will review key engineering procedures to determine whether each engineering activity is either addressed in procedures, scheduled for inclusion. in procedures, or not addressed.
. Procedures' addressing a given activity will be reviewed' based on RCD Sections 1 and 2 for the activity. The procedures reviewed will be identified in Section 3 of the RCD.
Generally. the review will be based on the latest issued procedures, however, draf t procedures may . be . reviewed in some .;' instances.' 3.. Comment Cycle Comments. will be developed throughout the review. Comments will be classified into one of the following categories. i o Response Required Comments classified with this designation address important issues which must be resolved.. CPSES must respond to these comments. SWEC will' evaluate each response to assure the resolution is acceptable, o Alterna*.e Approaches During the assessment cases may occur where the processes described in . procedures are acceptable. However, an alternate approach, or additional activities may be suggested as improvements based on SWEC's experience. Comments of this type do not require a response. o Editorial r: h This third area consists of comments identified which are not significant, but which should be corrected. l 1 Comments will be transmitted to TU Electric throughout the review - process.. As a review of a procedure is finalized associated . comments will be transmitted. However, since many activities may ] 37-EA-047/EA306 4.4-4 E_------_----- J
be addressed in more than one procedure, some camments transmitted may be subject to change as the review progresses. In some cases, several procedures may be reviewed simultaneously because of their interrelationships. In this case, comments will be transmitted upon completion of the review of all the related procedures. Comments -will be documented individually. Each comment will contain three sections: comment, rationale, and recommendations. All comments will be indexed and numbered incorporating the TU Electric procedure number'and a sequential designator.
- 4. Requests for Information A system will be established which allows requests for information to be formally documented. However, use of this system will be limited to important items needing a documented response such as interpretations of conflicting requirements.
4.4.5' Reporting At the conclusion of the procedure assessment, SWEC will' prepare a final report addressing _ assessment results. The report will follow general format outlined below:
- 1. INTRODUCTION
- 2. APPROACH
- 3.
SUMMARY
OF RESULTS AND OVERALL CONCLUSIONS This section will be broken down by activity. ATTACHMENT 1 RESPONSE REQUIRED COMMENTS This attachment will include an index of all comments grouped by procedure reviewed. Copies of all Response Required Comments will be included, with resolutions, if available at the time the report is issued. i i ATTACHMENT 2 ISSUE CORRELATION Each CPRT generic issue and NRC industry concern will be correlated to TU Electric activities / procedures. Tha final report will be reviewed and approved by the Team Leader, ; the Evaluation Team Manager, and the Chief Engineer, Engineering I J Assurance Division. l i s i l: I I I 87-EA-047/EA306 4.4-5 l l ! I i i
i 4.4.6 Implementation Review At the conclusf.on of the' procedural review, selected implementation 4 checks will be provided. Those areas selected for evaluation will be agreed upon by TU Electric and SWEC. Selection of specific activities for evaluation will be based on the availability of implemention j examples and the status of ' governing procedures. Details for the 1 implementation review process and .the associated report will be I developed at that time. 1 1 ( 1 1 1 1 l l 1 87-EA-047/EA306 4.4-6 j i - - - - - _ - _ - _ - _-- i
1
'1
. LEN'GINEERING-ACTIVITIES 2.IST l j
' MANAGEMENT'AND ORGANIZATION' Quality l Assurance Program' .q Organizational' Structure. '{
o' -Organization j
.o Charters l o- Staffing 3 o Personnel Qualification I Training Architect / Engineer' Interfaces- f J
Procedure' Control J
' Audit Program'
. Quality Assurance Records.
-Regulatory Reporting Requirements
. CONDUCT OF ENGINEERING Modification-Process Change Identification and Evaluation Conceptual' Design-Detailed Design
' Installation Requirements / Procedures
-Testing Requirements / Procedures Field Change ~ System Nonconformance System Modification Closecut u' o As-Built System
-o- Document Update System l Accelerated / Simplified Change. Systems Temporary Modifications Design Process
-Design Criteria.
System Descriptions-Functional Diagrams
- Physical' Drawings Calculations-Installation Specifications Environmental Qualification ASME (ASME;I.II, XI) o ' Stress Reports-
.o Design Specification o Overpressure Protection Reports R . Computer Software / Hardware L Special' Processes.(Welding, NDT, etc.)
.Scfeguards InfocP9 tion l-87-EA-047/EA306 4.4-7
, : R 2 1
' ENGINEERING ~ ACTIVITIES LIST 4 (Cont.)
' Reliability Data System Setpoint. Control Controlled Lists'(e.g., Q-List, Master Valve List, Master Instrument JList) ~
Corrective. Action. Systems . Engineering. Involvement in External Operations Activities (Testing,-
-Maintenance, Inspection, etc.)-
. Procurement' Process Procurement Specifications Engineering Services Vendor Drawings
~ Vendor. Document;
_ Procurement System'< Eo Engineering Evaluation of Suppliers o Engineering Evaluation of Bids o Recommended Bidders
.o- Purchase Requisitions Spare Parts Control-Reviews Design Verification Plant Operations Review Committee'(PORC)
Independent Safety' Engineering Group (ISEG) Safety Evaluations-- SpecialL Reviews (ALARA, Security, Fire Hazards,' etc.) - Licensing. L GENERAL CRITERIA Procedure Flow / Control Review' Process I i 1' t l
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f { 4 l l 87-EA-047/EA306- 4.4-8 6_ __-_ --_- _ _ _ __ l
.5.0 EVALUATION TEAM l
' The Team shall consist of a joint TU Electric contractor team of senior engineers and specialists. The team shall be composed of individuals who- are independent of CPSES activities. 'The team will include individuals from the following organizations:
SWEC j EBASCO l IMPEL I Team members for the Operating . Plant Design Control module shall int senior experienced SWEC personnel assisted, as needed, by SWEC personnel specializing in specific engineering areas. i i I I L i 1 87-EA-047/EA306 5-1 1
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, u 6.0 PREPARATION:
GENERAL-o Review applicable FSAR sections. Westinghouse (NSSS) ' documents, q
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- and related project procedures -andL technical criteria to become l f amiliar - with system function, . design - basis requirements, and 1 project specific' considerations.- Identify'.and . assemble key documents necessary for the evaluation.
J o Determine status of' design documents. o Discuss and establish means to- evaluate interface between. disciplines. o ' Refine, . scope Land- approach to indicate specific' interfacing systems, structures,'and components to be evaluated, o- : Develop task assignment ' sheets as -necessary to address general
. preparation requirements, refined ' scope, and -any additional requests by team members. -
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- o. Develop; a'~ set of marked-up, documents (drawings, diagrams), a y listing of key components and equipment, 'and any.. other requested B
material. in' order to provide appropriate ' information' among - team-members. -(Specific material required' will be identified on' task - assignment sheets. The team leader will coordinate with the team in establishing needs). , .o Using the " Base"'. Review Plans ' provided L by the '~ team leader as l; guidance ~, each team member shall develop Review Plans specific to the discipline and areas to be evaluated. The Review Plans shall reflect the scope of the . evaluation' and -' the means for reviewing - e' discipline interface. and identify the detailed attributes that are to be pursued during . the evaluation.- For example " Base" Review Plans developed for the Design Corrective Action. Overview - will '{ < !J include the following topics: Master List of References Consistency Between Design and FSAR Compliance with NSSS Criteria Calculations Drawings Diagrams Specifications Equipment Qualification , i; Vendor Documents )
& Change Documents (DCA, NCR, etc.)
Preparation requirements for the Operating Plant Design Control module are described in Section 4.4 , 1
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'87-EA-047/EA306 6-1 l
7.0 PERFORMANCE-The team members shall annotate the review plans to specifically and completely identify' the documents ' reviewed (including issue and revision identification) and to document, in detail, the results of the
- review for each : attribute. Support documentation , and: evaluator notes shall be included as an attachment to the Review Plan.
Potential concerns and requests for information will be communicated to TU Electric / Lead Contractor during the performance of ' the evaluation using Decontrolled " Action Item" Forms. TU . Electric / Lead ' Contractors will be requested to promptly respond to the Action Item providing the information requested - or, if appropriate, identify. the extend, cause, and significance of the. concern. A Status log 'will be maintained to track and account for all Action Items. (See Attachment 2 for guidance' in generating Action Items.) These communications will ass'ist in early resolution of potential concerns and provide insight into any needed' program adjustments. Attempts will.be made to " bound" all valid concerns / deficiencies during the evaluation by the use of Action Items. In: order to be bounded..the full- extent of the concerns .or deficiencies must be determined, corrective action taken and preventive action, where appropriate, implemented. The team member shall concur that the extent has been-determined and verify that appropriate corrective action has been taken j and preventive action. implemented Where appropriate. A site walkdown will be performed to facilitate the review of the
-systems:and~ evaluate activities. (See Attachment 4 for site walkdown description.)
Periodic status meetings will be held by the Team Manager / Team Leaders and the TU Electric / Lead Contractors.- The purpose of these meetings is to discuss the progress of the evaluation and the status of any open Action Items. q l Performance requirements for the Operating Plant Design Control module are described in Section 4.4. i I i l 1 i I 87-EA-047/EA306 7-1 i
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I 8.0 REPORTING , At the conclusion of the evaluation, and prior to insuance of the individual module reports, meetings will be held by the Team Manager / Team Leaders with TU Electric / Lead Contractors to discuss the results of the evaluation. The report will generally follow the outline below: 1
- 1. INTRODUCTION
- 2. PURPOSE
, 3. SCOPE
- 4.
SUMMARY
OF RESULTS AND OVERALL CONCLUSIONS
- 5. ACTION ITEMS !
- 6.
SUMMARY
BY DISCIPLINE Each team member is specifically responsible for preparing the summary ! section for the discipline evaluated. ; The report will be reviewed and approved by the Team Leader, the i Evaluation Team Manager, and the Chief Engineer, Engineering Assurance ) Division. Reporting requirements for the Operating Plant Design Control module' are described in Sect.on 4.4. I i 87-EA-047/EA306 8-1 j
9,0 SCHEDULE l 1 i The schedule for ' the Engineering Functional Evaluation is 'shown in l Attachment 1. 1 i 1 87-EA-047/EA306 9-1
O T DL YAE DOU 3 ALF E R N iI O I T A 2 U L A V iI E T LR AO 1 NP P IE U FR - N W O iI O L I L T 2 O F A 1 U L A iI I G V I N I E 1 I D 1 E N L E S R A A T N iI H P O &E I C T 0 G NN 1 . N OA C I IN N T TE S AT U iI E RN F S T EI PA 9 U E OM G T I C N A I A I TT SR E F R iI O R S E E TP CE A PT E ER H AN N B J P CI O I R E G - P C N N i1 A E 1 t R
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R E S E L ii E P I U T D I E V 6 I I H T C E C S S iI A h H 8 N c G 5 PS I AE W CD N iI E O I I V T W E A 4 E R R I E V C N S P E R O E O I I iI R N T T N E I N G T G L V G N R I I 3 S I S f f I T S R E O C E U D C A D D iI
c , ., . ry . . , , 1 3y 7 in 1 F; ATTACHMENT 2-GENERATION OF ACTION ITEMS
. An Action. Item can'be generated to identify deficiencies or to-request inf orma tion'. . It is difficult to define precise . criteria to apply in p ,
determining 'if an Action Item' should- be- generated. Three.
' considerations . are: significance of individual discrepancies, number.
. of: discrepancies, and' the urgency of information needed by the
/ evaluation-team member. 1 An Action Item is to be written when one or more -of the following needs exist: l '. 'Need to' identify a technical concern.
- 2. Need to identify a potential .. technical concern and there is no -
information readily availablex to ' substantiate or alleviate the-concern.
- 3. Need tolident1fy a significant program aspect or practice that is, or appears to be,' incorrect or inadequate.
- 4. When ' it is deemed necessary for the Project to. investigate ~ to determine cause and extent of discrepancies.
It 'is generally not necessary' to generate an Action Item if a. minor. discrepancy is observed and the discrepancy appears to be isolated or Several minor discrepancies, however, would generate.an Action
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Item. NOTES 1
- 1. Review Plans shall indicate all discrepancies observed regardless !
of significance 'o r number .even if an Action Item was not generated. The Team Leader will make the final decision for when an Action Item is written. His decision will be based on the above written guidance, as well as, objectivity and good judgement. r l 87-EA-047/EA306 1
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. ATTACHMENT 3
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GUIDANCE FOR PRODUCTION SUPPORT.
%," . The' production support : activities include Lchanges to design documents'-
. ( e .' g . drawings, . specifications : etc.) ' .Jas aL result. of _' . chang'es : in
- . licensing: commitments, ' design ' inputs, field changes , ; . - and ~ non -
, ' confors.suce s . .. l The< .. change s ; to.' design.. documents 'areD affected by-
' documents , sucht as 1
- the > generation of ' Design L Change": Authorization's:
-documents :(DCAs) f and disposition; of'; Non-Conformance . Report documents
.(NCRs)'and' Test Deficiency Reports'(TDRs).
.. c . ' Design c' changes affectingL the ; selected- systems and y structure will' be ~ ')'
, evaluated for attributes such'as:
W" ' o, . Compliance-with' Licensing Commitments
- f i, E o Compliance with Design Basis Documents o Technical Adequacy of Design Ch'ange,. including evaluation of required interfaces
- o. : Adequacy 'and Consistency of Incorporation into Affected Design Documents T, 'A representative. sample of design change documen'ts based on substantive l nature and' impact'on the design will be evaluated.
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p i p m 87-EA-047/EA306 L: 1 F A. . GZLL--_x -_- _ -_.: -
Page 1 of 2 ATTACHMENT 4 SITE WALKDOWN GUIDANCE FOR DESIGN MODULE There are two basic site walkdowns involved in evaluations:
- 1. Detail walkdowns and investigations dealing with evaluations of specific programs, such as, environmental qualification and seismic qualification. Such walkdowns are performed to Review f Plans that contain attributes that specifically require field i chec ks of installed equipment and hardware. (Attributes such as determination of identification, location, and orientation of specific, pre-selected, items of equipment).
- 2. Walkdowns associated with vertical design reviews for the purpose
*f facilitating and expediting the review which provide for:
o Familiarity with overall arrangement, location, and j configuration of design. ! o Follow-up for specific questions that arose as a result of l reviewing engineering documents. o Evaluating specific design attributes that are easier to f evaluate by seeing the installed hardware or equipment than l by document review only, o Evaluating the adequacy and clarity of engineering documents as evidenced by the implementation of the basic design ] criteria and technical requirements in the as constructed condition. A general familiarity tour can be conducted early in the i evaluation. However, a walkdown to evaluate specific items and attributes should be conducted only af ter design documents have been reviewed in sufficient detail to prepare for the walkdown. Prior to performing the walkdown, an outline will be developed. Each discipline shall provide input to the outline by preparing a scoping document (approximately 1 to 2 pages) to identify the key items and attributes from Review Plans that are to be evaluated. (The intent of the outline is to ensure team members are adequately prepared for the walkdown, but does not restrict the walkdown to only the arecs identified on the outline. In addition to the walkdown, in-plant visits may be necessary to follow up on potential concerns or questions). Items or attributes that could be included in the outline are: Electrical Separation Separation of Redundant Equipment 87-EA-047/EA306 a
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' Skop]ing f;o[Fi lines-l' , ' l Y :P A '31 @ [ h Pipe Support pacing, function Pipe Restraint. Locations
.v The Tresults of -the - walkdown- shall be documented' in the . Review -
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Plans' utilized:fortthe design review. The: Team Leader will' coordinate walkdowns with the Project to establish'
' dates'and times'andLensure appropriate personnel'ava11 ability..
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