IR 05000445/1987037

Design Validation Packages Insp Repts 50-445/87-37 & 50-446/87-28 on 871026-1204.No Violations Noted.Major Areas Inspected:Mechanical Sys,Civil/Structural,Electrical & Instrumentation/Controls

ML20149H813
Person / Time
Site:	Comanche Peak
Issue date:	02/04/1988
From:	Lyons J, Norkin D NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20149H802	List: IR 05000445/1987037 ML20149H798
References
50-445-87-37, 50-446-87-28, NUDOCS 8802220118
Download: ML20149H813 (129)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS

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Comanche Peak Project Division Report Numbers: 50-445/87-37, 50-446/87-28 Docket Numbers: 50-445, 50-446 Licensee: TV Electric 1 ea 75255

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Facility Name: Comanche Peak Steam Electric Station (CPSES)

Inspection At: Stone and Webster, Boston, Massachusetts and Cherry Hill, New Jersey Ebasco, CPSES Inspectior: Period: October 26 through December 4,1987 Inspection Team: NRC D. P. Norkin, OSP/CPPD - Team Leader

. F. S. Ashe, OSP/CPPD - Electrical /I&C Contractors G. M. Aggarwal, Electrical A. J. Hulshizer, Civil / Structural P. Fredricks, I&C D. A. Mehta, Civil / Structural F. R. Rosse, Mechanical Systems G. E. Tuday, Systems Interaction K. K. Niyogi, Systems Interaction J. S. Rathi, Systems Interaction N. C. Karanjia, Civil / Structural

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t-4-tt Donald P. Norkin Date Team Leader Office of Special Projects Approved By: - -

ao // 8B t for Technical Prog ams 8802220118 880208 DR ADOCK O D

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. o Introduction and Summary Background Inspection Report 50-445/87-19,50-446/87-15, dated October 15, 1987, documents the results of the NRC inspection of the Comanche Peak Design Validation Packages (DVPs) in the areas of mechanical systems, civil / structural, electrical, and instrumentation / controls. This review included some documents which were also in the Engineering Functional Evaluation (EFE) review scope in order to assess the effectiveness of EFE in identifying problem At the time of the previous NRC inspection, significant portions of the valida-tion program were not completed. The current inspection was intended to assess these portions, including the Systems Interaction Program. The current inspec-tion also included followup on Open Items identified for HVAC Systems during the previous inspection. References in the report to the "project" pertain to TV Electric's architect-engineers for specific disciplines, i.e., SWEC and Ebasc Method of Review The method of the current review was essentially identical to that of the pre-vious review because the type of product reviewed was the same in both cases, i.e., the DVPs. However, during the inspection reported herein, the team did not directly assess the EFE effectivenes In the previous inspection, the team reviewed EFE results in order to determine if problems found in the NRC review were also found by EFE. This review took an inordinate amount of time from the team's main function of reviewing design documents and was not always conclusive. For example, it would not be expected for EFE to identify each problem found by the team, especially those of lesser i significance. Nonetheless, the NRC inspection results, for both the areas i

addressed by EFE and for those not, provide insight into problems which should have been found by EFE and areas where the EFE review scope may need to be expande Both inspections focused on design criteria and their implementation. The team reviewed design criteria contained in Design Basis Documents (DBDs) and other documents, such as calculations, which demonstrated implementation of criteri Open items were identified where the team could not conclude that the criteria were: (a) consistent with the FSAR and industry standards / practice, (b) adequate to ensure system functionality, (c) clear enough to ensure adequate implementa-tion, or (d) implemented in the design.

l In each discipline, the team selected review samples considered to be represen-tative of the entire disciplin For example, see Table 1 for the civil /

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structural discipline. The review sample was limited for the electrical dis-cipline because significant work elements involving the 6.9 ky emergency power system were not complete. In the mechanical and I&C disciplines, team members coordinated their review of the component cooling water system and other systems

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reviewed. For Systems Interaction, the team reviewed DBDs for the three pro-grams; pipe rupture, seismic /non-seismic inte; action, and missile effect _ _ _ _ _ _ _

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The DVPs sampled by the team represent the safety-related design for the dis-ciplines reviewed. In addition to resolving the specific open items identified, it is necessary for the applicants to address their potential safety implica-tions and extent of conditions or situation. The team's followup will assess the applicants' effectiveness in evaluating potential safety implications and extent of condition / situatio In sumary, the following actions are required for the NRC to complete its review of Design Validation Packages and the Project Status Reports for the above areas:

(1) additional inspections for the Systems Interaction Program and selected other areas, (2) TU Electric's written response to all Open Items identified in NRC design inspections, (3) TV Electric's review of NRC results with regard to potential enhancement of the EFE program, and (4) NRC followup on items (2)

and (3). Our assessment of these actions will be reflected in the Safety Evaluation Report (s) on the respective Project Status Reports.

i Although it was intended for this inspection to address the remaining signifi-cant portions of the DVPs, several such areas were not completed and will need to be reviewed by the team in the future. These were:

! implementation of Systems Interaction Program DBDs; l electrical redesign for the 6.9 kv emergency power system; and, j certain operating modes for the component cooling water syste Summary of Results l

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s 4f this report contains a two-part section for each disciplin The c '-

x t is a sumary of (1) the rationale for the review sample and how' ...w nted that for the previous inspection of the DVPs, (2) open items, M (3) significant DVP areas that were not complete at the time of the inspection and require additional staff review. The second part documents the team's review of each design document (including DBDs) in the review sampl This part identifies open items where further information or action is necessary for the team to conclude the docume.nt is adequat For such documents, the team generally did not document all of the areas that were found acceptable; instead, the emphasis was on explaining the basis for the Open Items. For documents reviewed where no open items were identified, the report presents the team's rationale as to why the design criteria are adequate and the calculation or other design document demonstrates compliance with the design criteri As in the case of the previous inspection, the team generally found the DVP effort comprehensive and effective. Our final conclusions depend on additional inspections which will assess (1) significant areas (identified above) which were not yet completed and (2) the applicants' responses to identified open items. Some of the more significant of these open items involve:

(1) Non-conservative assumptions regarding heat exchangers which add or remove heat in the heat flow chain between the containment and the ultimate heat sink, (2) Electrical separation issues such as (a) confirmation that the worst case cable size and fault current were selected for the electrical separation verification testing and (b) the adequacy of protective wrap as barrier material equivalent to metal-enclosed raceways; (3) Method of calculating the jet attenuation factor pertaining to high  ;

energy line break . .

Mechanical / Fluid Systems - Sunnary I

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Mechanical / Fluid Systems Review Sample A broad sample of the safety-related fluid systems calculations was reviewed. Preference was given to completed calculations which required no additional confirmation data and allowed a degree of interdiscipline checking, especially with respect to systems instrumentation and control Systems reviewed included component cooling water, diesel generator, station service water, and spent fuel pool cooling and cleanup. The systems calculations addressed in this review, combined with the in-spection sample for the previous review phase (containment spray, auxiliary feedwater), allows evaluation of the major safety-related heat flow paths for accident and nonnal operating condition . Open Items Diesel Generator Exhaust System Calculation 215-10 for pressure drop in the exhaust system contains discrepancies concerning allowable pressure drop and flow performance characteristics of a vendor-supplied exhaust path valve. Actual exhaust pressure drop may exceed specified limit (0 pen Item F-21)

Component Cooling Water Surge Tank Volume Calculation 16345-ME(B)-073 does not properly address surge tank expansion volumes, and indicates that DBD criteria concerning crossover flow and thermal contraction may have been violated. Revisions to the alculation and the applicable DBD criteria to address realistic systems transients and account for liberal margins between LO, LO LO, and Empty setpoints may confirm the tank's adequacy. (0 pen Items F-23 through F-27)

i Service Water System Hydraulic Calculation 16345-ME(B)-088 indicates l that diesel generator flow is below minimum acceptable DBD requirement (0 pen Item F-28)

l Calculation 16345-ME(B)-094, Diesel Generator Starting Air, Minimum l Receiver Tank Pressure, is not based on the most conservative air i start requirements, as prescribed in the DBD and the Standard Review l Pla (0 pen Item F-29)

l Calculations 16345/6-ME(B)-228 (Spent Fuel Pool) and 16345-ME(B)-230 l (Service Water) provide setpoints for alarms which should alert the operator of potential loss of function. In several cases, the basis

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for the setpoint was either unclear or was related to a condition l which appeared to be unrelated to the system functional requiremen (0 pen Items F-30 through F-32)

Calculation 16345/6-NU(B)-023 evaluated maximum containment sump and component cooling water loop temperatures after a postulated loss of coolant acciden Systems evaluated included emergency cooling, containment heat removal, containment spray, component cooling water, service water and safe shutdown impoundtrent. Non-conservative assumptions were made regarding heat exchangers which add and remove heat and other sources of heat flow from containment-4-L

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to the ultimate heat sink (0 pen Item F-33 through F-35). These items taken together are significant due to their cumulative potential for overheating safet These items are related to Open Item F-10 (y-related equipment. previous inspection) conce containment spray heat exchanger heat transfer coefficient. Appro-priate corrections should be made to other ccntainment cooling /

ultimate heat sink evaluations (e.g., maximum containment pressure and temperature analysis).

Service Water System Design Basis Document 0233 indicates a cooling system that appears to be very limited in available margins based on the imposed cooling loads. Specific concerns involved piping and valve design temperatures being slightly exceeded, cooling water pump flowrates in excess of design values, and rated flowrate for cooled components not being obtaine (0 pen Items F-36 through F-42)

3. Additional Review Flow balance calculations for the relatively complex component cool-ing water system were incomplete at the time of this review; there-fore, evaluation of some operating modes for this system were reserved for inspection at a later dat .

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Mechanical / Fluid Systems - Evaluation of Documents Reviewed l

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Calculation 215-10, Rev. 1 Diesel Generator Exhaust Pressure Drop Applicable Design Criteria: DBD-ME-Oll, Diesel Generator Sets, Revision 0, 31 July 198 Diesel Generator Data Specification 2323-MS-034, Revision 1, requires 10 in. W.C. maximum exhaust system backpressure at the outlet flange from the D/G exhaust expansion join Delaval Diesel Drawing 09 805 76001 Rev. F, Exhaust, Intake and Crankcase Piping. This drawing specifies a maximum pressure drop of 10 in. W.C. for intake and exhaust pipin . Compliance with Design Criteria:

OPEN ITEM F-21 The calculation determines the exhaust pressure drop through the emergency relief path. Reference 9, which provides energency relief valve pressure losses, contains conflicting data, which results in the exnaust system overall pressure drop being either 13.26 in. W.C. or 15.56 in. W.C., from the D/G exhaust expansion joint outlet flange to the atmosphere. This calculation selected the least conservative Reference 9 data, and calcu-lated a pressure drop of 13.26 in. W.C.

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' In the calculation it is stated that 15 in. W.C. pressure loss is acceptable. This evidently is a misinterpretation of the diesel

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manufacturer's interface requirements (design criteria 2b and l 2c above) which require a 10 in. W.C. maximum pressure drop.

l Calculated pressure losses exceed the manufacturer's allowable by l 33 to 56 percent, depending on which Reference 9 data are use The calculations do not account for exhaust gas composition or re-duced atmospheric pressure from standard conditions.

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1. Document Number:

16345/6-ME(B)-062

"Spent Fuel Pool Cooling System Pressure Drop" Applicable Design Criteria, DBD-ME-235, Revision 0 dated 25 June 1987, Spent Fuel Pool Cooling and Cleanup System. This DBD defines flow requirements for the syste . Canpliance with Design Criteria The calculations demonstrate that the system meets required flow-rates with new pump performance data, except as noted belo OPEN ITEM F-22 The calculation incorrectly utilizes the pipe friction factor (f) for fitting form friction loss calculation The reference manual (Crane Technical Manual 4.0, dated 1981) utilizes a constant, (ft), which varies slightly from the friction factors determined within this calculation. The Crane Manual abandoned the method utilized within this calculation in 197 The calculation assumes the same resistance coefficient (K) for diaphragm valves as that for gate valves. In fact, the hydrauli:

resistance for the diaphragm valve is more than ten times higher than that for the gate valv While these discrepancies probably do not impact the results of this calculation, for certain flow alignments which may occur in the system (and are not addressed in this calculation) these discrepancies may significantly change the results. These particular flow alignments should be addressed in a calculation.

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1. Document Number 16345-ME(B)-073 Component Cooling Water Surge Tank Volume Applicable Design Criteria:

DBD-ME-0229, Component Cooling Water, Rev. 0, dated June 4, 198 Section 4.3.1.1 delineates surge tank normal liquid expansion /

contraction requirements, e.g., the liquid volume contraction resulting from a loss of all heat loads should not reduce the water level below the low water alann setpoin Section 5.4, states that crossover flow is unacceptable within the surge tank. The team has no objection to this criterion but was unable to determine its technical basis. In view of the potential for not meeting this criterion (see Open Item F-25), it may be appropriate to reassess the need for the criterio . Compliance with Design Criteria:

OPEN ITEM F-23 To detennine liquid expansion volumes, the calculation averages the cooling water supply and return temperatures, then calculates volume based on the average temperature. This is a non-conservative calcula-tion method; greater expansion volumes are calculated if actual supply and return temperatures are used because of the non-linear relationship between temperature and densit OPEN ITEM F-24 The maximum expansion volume calculated is based on a transient which begins with minimum heat loads and coldest (wintertime)

cooling water temperature, and terminates with maximum LOCA heat loads and hottest (summertime) cooling water temperatures.

L This is an unrealistic transient. Conservatism of this sort may be unacceptable in this case because the calculated value precludes meeting design criteria as stated in the DBD. See Open Item F-2 OPEN ITEM F-25

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The calculation states (pg. 41) "That there is not adequate l expansion volume between HI level and HI HI level; however, it

! is not a critical design parameter." Apparently no further action was take It is noted that the HI HI alarm setpoint is designated to l alert the operator that there is potentially as little as 16 l

seconds to determine which CCW train is experiencing inleakage, and to isolate the affected CCW loop, this conflicts with the above conclusion on page 4 The calculated liquid expansion may result in the violation of the DBD Section 5.4 criteria pro-hibiting crossover flow.

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OPEN ITEM F-26 The calculation states (pg. 40) that the volume allowance between L0 level and HI level should be sized for volume fluctuation during normal plant operations. 465 gallons is provided; however, no basis or numerical calculation justifies this volum The calculation shows (pg. 40) volume changes between L0 level, L0 LO level, and Empty setpoints as several hundred percent in excess of stated requirements. It may be possible that the liberal margins between these setpoints could be utilized between level setpoints where in-adequate capacity exists (0 pen Item F-25), i.e., by revising setpoint OPEN ITEM F-27 It is stated in the calculation (pg 41) that thermal contraction will not jeopardize the tank out-leakage volume, as makeup to the surge tank of 50 GPM is greater than the contraction rate. No basis or other justi-fication for this statement was found; indeed it appears that contraction rates exceeding 50 GPM are possibl It is also noted that the scenario within the calculation violates DBD Section 4.3.1.1 criteria, which prohibits volume contraction from reaching the low level alarm setpoint; at this level there is no makeup flow automatically provided.

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16345-ME(B)-088, Station Service Water System Steady State Hydraulic Calculations Applicable Design Criteria:

DBD-ME-0233, Station Service Water System, Revision 0, dated 4 August 198 Section 9 System Interface, gives flow requirements for various heat exchangers and other required water supplies to interfacing systems. The team found the identified water supplies to inter-facing systems to be acceptable, although we did not review each DBD for consistency of documented flow rate . Compliance with Design Criteria:

The calculations demonstrate that the system meets flow requirements, except as noted belo OpEN ITEM F-28 The calculations show the diesel generator cooling water flowrate about 9%

below DBD nominal stated flow requirements, and that there is slightly less than this amount of flow recovery available by manually throttling ("Tuning")

the system. It should be verified that the system meets or exceeds minimum required flows at the maximum anticipated supply temperatures.

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1. Document Number:

16345-ME(B)-094, Rev. O Determination of Minimum Pressure in Air Receiver Tanks to Provide 5 Diesel Starts Applicable Design Criteria:

DBD-ME-Oll, Diesel Generator Sets, Rev. O, 31 July 198 Section A.3.1.1d, Diesel Generator Air Starting System Functional Requirements, requires 5 crankin cycles for a cold diesel engine without recharging the receiver (g).

s Each cranking cycle should be (a) approximately 3 seconds each, or (b) consist of 2 to 3 engine revolutions, or (c) conform with air start requirements per engine start provided by the manufacturer. Whichever air start requirement (a, b, or c) is larger applies to the design. This requirement is from SRP 9. . _ Compliance with Design Criteria:

OPEN ITEM F-29 The calculation does not address additional air consumption that will occur during first start attempts with high inlet air pressure and resulting increased air densit The calculation is based on requirements of the manufacturer, 2.1 seconds cranking time, whereas the DBD and SRP require con-sideration of a longer cranking interval (3 seconds per start attempt). This longer interval results in a minimum initial air receiver pressure of approximately 250 psig vs. 220 psig delineated in this calculation. The calculation should use the largest air start requirement, in accordance with the SRP and DB . . Document Number:

16345/6-ME(B)-228 Spent Fuel Pool Cooling and Cleanup System Instrument Setpoint Calculation Applicable Design Criteria:

DBD-ME-235, Revision 0, dated 25 June 1987, Spent Fuel Pool Cooling and Cleanup System Section 10.2, equipment design criteria, gives heat exchanger minimum flows of 3600 GPM for the fuel pool cooling system, and 4000 GPM component cooling water flow. The team did not assess the acceptability of these criteria because they are specific to this heat exchanger design, i.e., other criteria may be acceptable for another heat exchanger desig . Compliance with Design Criteria:

OPEN ITEM F-30 The fuel pool cooling pump discharge low pressure alarm setpoint is based on the pump reaching "runout" flow discharge pressure conditions. This condition is not relevant to system functional requirements of provMing at least 3600 GPM system flow. The alarm setpoint sh - 1 based on the minimum pump discharge

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pressure which w- . , wide minimum flowrate within the syste The setpoint calculation considers only pump total dynamic head pressure. The calculation needs to consider pump inlet pressure (static head minus suction piping losses) to determine pump discharge pressur OPEN ITEM F-31 l

l The spent fuel pool cooling circuit low flow alarm setpoint is 3200 GPM, while the heat exchanger design flow is 3600 GPM. The low flow alann should be set to assure that flowrates meet or exceed minimum requirement The flowrate of 3200 GPM may rep-

! resent an unanalysed operating condition which potentially fails to meet fuel pool heat removal requirements.

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1. Document Number:

16345-ME(B)-230 Service Water System Process Setpoints (Safety Related) Applicable Design Criteria:

DBD-ME-0233, Station Service Water System A low header pressure alarm is provided. This alarm setpoint should represent the condition (somewhat degraded) where the system can still perform its intended safety function. These criteria are consistent with industry practica and, therefore, are acceptabl . Compliance with Design Criteria:

OPEN ITEM F-32 The calculation states "Set the low pressure switch to activate when the pressure in the safety related header drops to 80% of normal

, operating pressure". No basis or justification for the selection of the 80% value is give The normal pressure is determined to be 30.17 psig, (pg. 4) and the process setpoint pressure is calculated based on 60% rather than the s tated 80% (30.17 * 0.6 = 18.1 psig).

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.e 0 Document Number:

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Ultimate Heat Sink and Maximum Sump Temperature Applicable Design Criteria:

Standards of the Tubular Exchangers Manufacturer's Association (TEMA)

6th Edition 1978 TEMA NY, N This calculation is performed to maximize containment sump and com-i ponent cooling water loop temperatures after a postulated Loss of Coolant Accident. Normal practice for determination of maximum component cooling water temperature requires the consideration of maximum normal fouling / minimum flowrates for heat exchangers which remove heat from the system, and maximum nonnal flowrates and clean -

heat transfer surfaces for heat exchangers which supply heat into the system. These criteria are consistent with industry practice

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LOCA blowdown variables are evaluated in such a manner as to con-servatively maximize the containment sump temperatures For the component cooling water heat exchanger, which removes heat from the system, a fouled heat exchanger must be assumed. The heat transfer coefficient is determined on the basis of actual calculated flowrates, and credit is taken for the fact that the heat exchanger will exper-ience fluid temperatures in excess of nonnal values. The higher operating temperature results in cooling water physical properties which increase the heat transfer coefficient. This is an acceptable method to realistically represent heat exchanger performance, except as noted belo OPEN ITEM F-33 Nominal fouling conditions were assumed in accordance with the heat exchanger data sheet. The "80% cleanliness allowance" used to determine this unit's perfomance is unrealistic, and results in a non-conservative heat transfer coefficient for the component cooling

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water heat exchanger which is about 65% higher than the value obtained by use of industry accepted standard fouling factors (Section 2.3, TEMA Standards). The heat exchanger cleanliness

! dictated by the analysis will be difficult to continuously maintai It is noted that CPSES calculation 0509-2 shows a Langelier's index of 1.45 and Rynar index of 4.7, both of which indicate moderate to heavy scaling tendency in the service water system heat exchanger tubes. Even if one assumes a very minimal fouling resistance for this heat exchanger, such as the fouling resistance associated with the very clean deionized primary reactor water of the RHR heat ex-changer, the overall heat transfer coefficient obtained is lower than the heat transfer coefficient used as input to this analysi This illustrates the unrealistically high cleanliness assumed in this analysi _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ - _

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The containment spray heat exchanger inputs heat flux to the com-ponent cooling water loop. It was evaluated as a clean heat ex-changer, and the penalty of high performance due to high flowrates and high fluio temperatures was accounted for in this analysis to realistically represent the ccndition under stud OPEN ITEM F-34 For the residual heat removal heat exchanger, which also provides heat flux into the component cooling water system, the heat ex-changer is correctly assumed to be in the clean condition. However, adjustments have not been made to account for increased flowrate on the tube side of the exchange The higher operating temperature for the analysis also causes an increase in the heat transfer coefficient; this has not been ac-counted for. The heat transfer coefficient should be about 25%

higher than the value used as input for the analysis. This dis-crepancy causes results in the non-conservative directio OPEN ITEM F-35 Heat flow into the component conling water system from other mis-cellaneous sources is listed as 5.146 million Stu per hour. This value does not include pump energy input of 1000 horsepower. This load should be increased to 7 691 million Btu per hou Resolution of the above discrepancies may result in an increase of cooling supply temperr.ture to 150*F, and maximum return tempera-tures to 200*F. Such results need to be evaluated for potential overheating of safety related equipmen Open Items F-33 through F-35, taken together, are significant due to their cumulative potential for overheating safety related equip-

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ment. These items are related to Open Item F-10 (previous inspec-

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tion) concerning the containment spray heat exchanger heat transfer l coefficient. Appropriate corrections should be made to other con-l tainment cooling / ultimate heat sink evaluations (e.g., maximum con-tainment pressure and temperature analysis).

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1. Document Number:

Design Basis Document DBD 0233, Rev. O dated August 4, 1987, Station Service Water System Applicable Design Criteria: .

VPEN ITEM F-36 DBD Section 4.3, page 13. states 115'F is the maximum normal operat-ing temperature of the safe shutdown impoundment (SSI). This apparently is a typographical error and should be changed to 102* DBD Table 1, page 16 indicates 2523 gpm (minimum) flowrate to the diesel generator cooling heat exchangers. It is noted that the ac-tual minimum value occurs under nomal operating conditions and is

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listed in Table 1 as 2267 gp OPEN ITEM F-37 DBD Section 4.3, page 15, Functional Requirements, states "All com-ponents have a continuous flow...regardless of operating status."

Section 4.3.1, page 23, Mechanical Equipment Requirements, describes diesel generator cooling system isolation valves (HV 4393,4394),

which open automatically on a diesel start signal. These statements appear to conflict. No basis for the provision of these diesel cooling isolation valves is given. The DBD should discuss the reasons for their existence in addition to reasons why similar ;

motor-operated isolation valves are not provide ~d for other cooled components within the syste OPEN ITEM F-38 DBD Section 5.2, pages 37 and 38, System Modes of Operation, states that manual throttling to attain balanced flowrates is required.

I Section 5.4, page 43, System Limitations and Precautions, states l "Performance is predicated on accurate balancing of flow in all pip-ing branches," and that "off design flow distribution will limit functional ability to perform the required duty..."

l It should be assured that realistic methods which consider measure-ment errors, plus other variables or uncertainties, are available to accomplish the stated goals of flow b;1ancing. Administrative con-trols to ensure the maintenance of throttle valve set positions also should be ensure The system flow diagram (Drawing No. 2323-MI- ,

0233, Rev. CP11) does not currently indicate any intermediate posi-tions for valves and does not show any locking provisions for the valve The provision of automatically opened diesel generator cooling valves (DBD Section 4.3.1) implies that large disturbances in the system flow balance may occur if these valves are closed during l nomal operation. This is of concern due to the relatively small margin in the existing service water pumps, which are operated close to runout conditions during normal operatio __ _ _ _ _ _ _ _

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OPEN ITEM F-39 DBD Section 6.3, Service Water System Monitoring, states "the CCW heat exchanger alarms when the pressure differential between service water and component cooling water'is low enough to indicate a tube leak in the exchanger." It is not clear how a tube leak would be indicated by this alar OPEN ITEM F-40 f

DBD Section 9.0, System Interface, describes cooling water flow re-quirements for each cooled component within the system. Every flow-rate is stated to be "approximately _ gpm." However, the allowable error band for flowrates is not quantifie The minimum allowable system flowrates, as established by evaluation of system heat removal performance, should be used to define system flowrote requirements.

l The determination of minimum acceptable cooled component flowrates should consider allowable variation of input loads, variation of fluid flowrates on the cooled component subsystem, and the allowable band of heat exchanger performance permitte OPEN ITEM F-41 i

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DBD Section 10.1, Equipment List and Specifications, page 65, gives l the piping and valve design temperature of 150 F. Consideration of the flowrate (DBD Table I, page 16) and heat load (DBD Table II, page 18) gives a piping temperature of about 156*F, which exceeds the design temperature. There may be a potential for higher temper-atures after consideration of Open Items F-33,.F-34, F-35, and F-4 OPEN ITEM F-42 DBD Attachment 2, Service Water Pump Performance Curve, shows a pump best efficiency point (BEP) at 14,000 gpm. This corre ponds to the rated flowrate for the component cooling water heat exchanger onl DBD Table I, page 16 shows this pump normally operating at about 17500 gpm, and with a tolerance to allow for variation in the SSI level, plus unavoidable balancing flow tolerances, it can be expect-ed that the pump may normally operate at about 18500 gpm. This op-eration approaches the limit of pump test data and corresponds to operation at about 130 percent of BEP flowrat DBD Section 10.2, Equipment Design Criteria, lists the service water pump design flow at 17,000 gpm. It is not clear whether this pump was originally specified with the 17000 gpm design flow. If not, the currently envisioned operating flows for the pump may cause un-desirable characteristics related to vibration, cavitation, NPSH, or vortex problens, all of which could be aggravated with a worn pum . .

Instrumentation and Controls - Sumary

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INSTRUMENTATION AND CONTROLS (I&C) DISCIPLINE SUMMARY Review Sample l

The review sample consisted of selected design documen,ts for the Component Cooling Water (CCW), Diesel Generator (DG), and Station Service Water (SSW) systems. For these systems, the team reviewed {

the following types of design relatad items: '

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FSAR Section Design Basis Documents (DBDs),

Flow Diagrams,

Instrumentation and Control Diagrams (ICDS),

Electrical Circuit Diagrams, and Instrument Setpoint and Scaling Calculation The team selected these systems based on safety significance, relative complexity, and architect-engineer involvemen I Many similarities were observed between design documents and diagrams for the SSW and the CCW systems. These included: implementation of attendant automatic and manual control design features; calculation methods used to establish instrument setpoint, reset, upper setpoint and lower setpoint values; implementation of specific design criteria such as the single failure criterion; and instrumentation provisions incorporated for fluid pressures, flows, and tank levels. These similarities were also noted during the previous inspection in which the team reviewed selected design documents and diagrams for the Containment Spray, Auxiliary Feedwater, and Control Room Air-Conditioning and Habitability systems. (Results for the previous inspection are provided in Inspection Report Nos. 50-445/87-19 and 50-446/87-15 dated October 15,1987.)

The similarities observed by the team among the design documents and diagrams reviewed provide assurance that these items are repreten-tative of similar design documents and diagrams for other Comanche Peak plant systems and, as such, are representative of the total SWEC I&C design validation effor . Open Items l Items I-10 through I-12 and I-17 through I-21 concern the CCW system.

l The DBD did not address a scenario for failure of one safeguards loop, l including isolating the non-safeguards loop (Items I-10 and I-11).

l The CCW flow rate to the Spent Fuel Pool Exchanger is listed incon-sistently in DBDs 235 and 229 (Item I-12). Normal CCW system oper-l ations, which involve cross-connecting safety-related loops through the non-safeguards loop, may preclude detection of component leakage to the CCW system (Items I-17 and I-18). Items 1-20 and I-21 concern valves which the DBD indicates are required for safe shutdown, ,

although neither has redundant Train A/B actuation. However, it is l

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not clear from the DBD and implementing documents how these valves contribute to safe shutdown.

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s Item I-13 concerns the plant alarm system unnecessarily distracting the operator during critical times. Item I-22 reports a potential DBD related generic deficiency involving setpoint calculation methodology. It may require examin: tion of all safety-related setpoint calculations to determine if switch deadbands could inter-fere with the intended operation of the equipment / systems. Item I-15 concerns an inconsistency between the ICD description of a maintained memory and its application in control circuit Item I-23 concerns redundant containment isolation valves, which are not actuated from separate trains. The team also found minor dis-crepancies in setpoint calculation packages (Item I-14) and lack of tubingacceptancecriteriainaninstallationspecification(ItemI-16). Additional Review I&C modifications for the CCW system may result from mechanical system operating requirements involving a pump trip and/or signifi-cant system leakag CCW system operating scenarios involving these items were not fully developed at the time of this inspection.

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. . o Instrumentation and Controls - Evaluation of Documents Reviewed

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l Document Number:

SWEC DBD-ME-0229, Rev. O dated 06/4/87, "Component Cooling Water System" Applicable Design Criteria:

This document provides design basis and technical descriptive in-formation for the CCW system. It also describes the functions, design requirements, modes of operation, arrangement, performance characteristics and limitations of the system. In addition, Section 4.3.2 of the DBD contains specific instrumentation and control requirements including those for automatic control action In general, the team found these aesign criteria consistent with the FSAR and industry standards and adequate to ensure system func-tionality, except as noted belo OPEN ITEM I-10 The mechanical equipment requirements section lists two pumps rated at 14,700 gpm at 226 ft. TDH (Total Dynamic Head). Table 4-1 shows heat load and flow requirements of 302 million BTVs and 27,900 gpm at four hours after shutdown. At this time, the non-safeguards loop subtotal is shown as 11 700 gp Information in the DBD does not include a scenario for isolating the non-safeguards loop should one safeguards loop fail. The required flow rates for safeguards and

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non-safeguards loops with one pump in service are not given nor is there any information on required automatic or manual control operations to restore the system to adequate cooling condition OPEN ITEM I-11 Isolation of the non-safeguards loop could remove instrument air com-pressors and thermal barrier coolers from operation for a long time period. It is not clear that sufficient compressed air is available to perform safety-related functions during such a time period or if prolonged loss of thermal barrier protection will damage the eactor coolant system pump '

OPEN ITEM 1-12 The Spent Fuel Pool Cooling Heat Exchanger CCW flowrate is listed as 4000 gpm in DBD-ME-0235, Rev. O dated June 25, 1987, "Spent Fuel Pool Cooling and Cleanup System". Table 4-1 in DBD-ME-0229 (CCW DBD)

lists this flowrate as 3000 gp This inconsistency needs to be correcte .- . Document Number:

SWEC DBD-ME-Oll, Rev. O dated 6/31/87, "Diesel Generator Sets" Applicable Design Criteria:

This document provides the functions, design requirements, modes of operation, arrangement, perfonnance characteristics, and limitations of the Diesel Generator Sets. The document also addresses the auxiliary systems required to support the diesel generators, that is, fuel oil, cooling water, lube oil, air intake and exhaust, air starting and loading sequencer, and electrical components up to the connection to the electrical distribution system supply circuit breaker Section 4.3.2 of the DBD contains instrumentation and control design requirements. These requirements result in specific I&C design features provided for starting, operating, monitoring, loading, and testing the diesel generators. Conditions requiring automatic control actions as well as design provisions incorporated for manual control from local and remote locations are addresse Instrumentation providing status information for the diesel generators and support auxiliaries along with attendant abnormal condition alarms are also addresse In examining the controls, the interaction between the fuel oil drip waste tank and the fuel oil tank operation was checked. The fuel oil drip waste tank automatically empties to the fuel oil day tan The sources of inputs to the fuel oil drip waste tank have been designed to prevent the accidental introduction of water into the tank. In addition, the day tank high. level alams are sufficiently above the fuel oil transfer pump stop level to easily allow the fuel oil drip waste tank to be emptied without activating l a nuisance high level alam. It was concluded that this part of the design is sound.

l The DBD provides adequate guidance for the design of the diesel l generator system controls and instrumentation. Further, the design

! basis and functional requirements in the DBD are adequate to meet i the overall control and instrumentation requirements for emergency operation of the diesel generator.

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. . Document Number:

SWEC Calculation 16345-IC(B)-011, Rev. O dated 10/7/87, "Reactor Water Makeup Storage Tank Level Channel 1-LS-5350."

2. Applicable Design Criteria:

Regulatory Guide 1.105 "Instrument Setpoints" Rev. 2 dated February 1986, which the applicants have connitted to, provides general guidance and criteria for this calculation. This general criteria is supplemented with design requirements and methods con-tained in SWEC DBD-EE-037 "B0P Safety-Related Setpoints," Rev. 1-A dated October 19, 1987 and ISA Standard 567.04-1982 "Setpoints For Nuclear Safety Related Instrumentation Used In Nuclear Power Plants."

The latter is an industry-wide standard. DBD-EE-037 and the ISA Standard provide specific design requirements and methods for esta-blishing setpoints that account for instrument inaccuracies due to factors such as primary element accuracy, power supply variations, and expected environmental and minor calibration changes. These two documents also contain specific information relating to the opera-tional limits suggested in Regulatory Guide 1.105. The team found these criteria applicable and adequate for this calculatio . Compliance With Design Criteria:

This calculation provides the adjusted setpoint and reset point values for level switch 1-LS-5350. The low-low level signal acts to stop the reactor makeup water storage tank transfer pump, while

resetting of the low level switch signal acts to start the pump.

l These switch actions provide assurance that the transfer pump has

adequate net positive suction head.

The calculation was reviewed based upon the above applicable design l criteria and it was noted that engineering judgement was used to l establish numerical values for factors, such as radiation dose.

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temperature variations, and instrument setpoint tolerance, which l contribute to instrument inaccuracy. The team found these values to be conservative relative to those which are actually expecte Based on this and review of the method used to establish the set-point and reset point settings, this calculation was found to be in compliance with the design criteri _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ __ ___ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ ____ _ __

O O Document Numbers:

Drawing No. 2323-M1-2229, ICDS for CCW System - Nine Sheets Drawing No. 2323-M1-2230, ICDS for CCW System - Two Sheets Drawing No. 2323-M1-2231, ICDS for CCW System - Seven Sheets Applicable Design Criteria:

Section 4.3.2, "Instrumentation and Control Requirements" of DBD-EE-0229 "CCW System" and NUREG-0700, "Guidelines for Control Room Design Reviews" dated September 1981 provide design criteria for these diagrams. The NUREG-0700 requirements are referenced in NUREG-0737, "Clarification of TMI Action Plan Requirements." The

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DBD contains I&C requirements for automatic and manual control actions, indications, and alarm functions. NUREG-0700 contains guidelines for evaluating the control room workspace, instrumenta-tion, controls, and other equipment from a human factors engineering point of view that takes into account both system demands and operator capabilities. The NUREG suggests that providing the operator extraneous or meaningless information, which could create a distraction from concentrating on important information, should -

be avoide . Compliance with Design Criteria:

The ICDS show the control logic for automatic and manual control actions. These control actions include starting and stopping CCW pump maters and/or opening or closing valves. In addition, these diagrams show indications and alarms that are attendant to the the CCW system and which generally comply with the design criteria provided in the DB OPEN ITEM I-13 Instrumentation and controls are provided for the CCW system which

result in automatic isolation of the non-safeguard loop from both l safeguard loops on receipt of a containment isolation signal. The l resulting zero flows in the non-safeguards loop will activate more l than 20 alarms. The alarms will be unimportant to the operator, but they must be acknowledge The concern about operator "data overload" during critical periods is a generic one. The team was infomed that a control room design review in accordance with NUREG 0700 has been completed by TU Electric. The results of the alam system review were not available to the SWEC project team at the time of this audi These results should be evaluated pertinent to the above "data overload" exampl .

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SWEC DBD-ME-215 Rev. O, dated 6/11/87 "Diesel Generator Fuel Oil Storage and Transfer System" Applicable Design Criteria:

This DBD provides design basis and technical descriptive information for the Diesel Generator Fuel Oil Storage and Transfer (DGF0ST) syste The functions, design requirements, modes of operation, arrangement, performance characteristics and limitations of the system are also addresse The principal design criteria included are the single failure criterion and the requirements that all nuclear safety-related components required for emergency operation of the diesels are ASME Class 3 or IEEE Class 1E. In addition, specific IEEE and industry standards applicable to this system are identified in the DB The design criteria address the filtering of contaminants, but do not specifically address water as a contaminant. The DBD is cur-rently being revised to include the requirements for provisions on the storage and day tanks to test for water contaminatio The team found the design criteria in the DBD provide adequate guidance for the I&C design of the system, and that the design bases and functional requirements are adequate to meet the overall requirements in support of emergency operation of diesel generators, i

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1. Document Numbers:

SWEC Calculation 16345-IC(B)-016 Rev. O dated 10/8/87, "CCW Surge Tank Level Lo-Lo, Hi, Empty 1-LB-4500 A/B, A1/Bl" SWEC Calculation 16345-IC(B)-015, Rev. O dated 10/8/87, "CCW Surge Tank Level Lo-Lo, Hi, Empty 1-LB-4501 A/B, A1/Bl" Applicable Design Criteria:

SWEC design basis documents DBD-ME-0229 "CCW System" and DBD-EE-037,

"BOP Safety Related Setpoints" provide design criteria for these calculations. DBD-ME-0229 contains I&C functional requirements and DBD-EE-037 provides design requirements and methods for calculating setpoints which account for instrument inaccuracie In addition, SWEC Calculation 16345-ME(B)-073, Rev. I dated 10/13/87, "CCW Surge Tank Volume" provides numerical mechanical process values to be used as input values for these I&C calculations. These design requirements and methods are consistent with the FSAR and industry standards and adequate to ensure system functionalit . _ Compliance with Design Criteria:

The calculations detemine adjusted setpoints and reset points for level instmment channels 1-L-4500 and 1-L-4501. These instrument channels are provided for automatic control and alarm function When water level in the CCW surge tank decreases to the "Lo-Lo" setting, bistable 1-LB-4500 A provides a signal to open valves which will pemit the tank to fill automatically. If level decreases further and reaches the "Empty" setting, bistable 1-LB-4500-Al pro-vides a signal to close non-safeguard isolation valves and bistable 1-LB-4500 B1 causes an alam on the main control board to actuat If water level in the CCW surge tank increases to the "Hi" level setting, bistable 1-LB-4500 8 provides a signal to close valves in the tank supply line. Similar controls and alarms are attendant to level instrument channel 1-L-450 OPEN ITEM I-14 ,

i Despite the fact that both calculations had the signatures of one

preparer, two reviewers, and one independent reviewer, the following j errors were foun On pages 3 and 17 of both calculations, the descriptions of

. the reset points are incorrect for the four bistables. The l calculations show "incr" (increasing) when they should show i "decr" (decreasing) and vice versa.

l l On pages 3 and 15 of Calculation 16345-IC(8)-015, a total of l 14 tag number errors were identifie The above errors are non-substantive. As such, the team would expect them to have been identified even by a cursory revie The fact that they were not identified by several reviewers may indicate a progrannatic problen with calculation review ;

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1. Document Number:

SWEC Calculation 16345-IC(B)-032, Rev. O dated 10/19/87 "Vent Chillers CCW Flow HI Channel 1-FIS-4650" Applicable Design Criteria:

SWEC DBD-EE-037, "80P Safety Related Setpoints," contains the principal design criteria for this calculation including that portion of ISA Standard S67.04 (dated 1982) relating to the establishment of setpoints for initial operation. These documents provide design requirements and methods that are consistent with industry practice and are applicable to this calculatio . Compliance with Design Criteria:

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This calculation determines the setpoint and reset point values for flow indicating switch 4650. This flow switch provides a signal to close valves 1-FV-4650 A and B when water flow in the supply and discharge header of the vent chiller is high. The high flow condi-tion is also alarmed in the control roo The minimum reset point should be 10% of full scale less than the .

minimum actuation point. For this case, this reset point is 130" (Water Column) rather than the 168" W.C. shown. However, this is not viewed as a safety problem for this calculation since instrument actua-tion at its setpoint will result in closing valves 1-FV-4650 A and B which, in turn, causes the instrument to reset due to no flow.

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1. Document Numbers:

Drawing No. 2323-M1-2200, Sheet 1, Revision CP-2 dated 5/21/87,

"ICD Legends, Symbols, Notes & Channel No. Allocation" Drawing No. 2323-M1-2200, Sheet 3, Revision CP-3 dated 3/25/87,

"ICD Legends, Symbols, Notes & Channel No. Allocation" Applicable Design Criteria:

The "Maintained Memory" symbol is generally considered throughout the industry as a latching relay as opposed to a seal-in circui Sheet 3 above defines the operation of the memory in part as, "X (output) continues to exist regardless of the subsequent state of A (input) until the memory is reset (terminated) by logic input B existing". Therefore, on a loss of control power (electrical or ~

air), the signal to the actuated device is maintained. For a seal-in circuit, this is not the cas . Compliance with Design Criteria:

The drawings listed above include a symbol for a "Maintained Memory".

The "Maintained Memory" symbol is used on six of the ICDS for the CCW system. The use was limited to solenoid operated valve .

OPEN ITEM I-15 Wiring diagrams are intended to implement the logic shown on the ICDS. The team reviewed wiring diagrams which. implemented the above ICDS for the CCW system, including the implementation of the

"Maintained Memory" symbol. Rather than using latching relays or other bistable devices, the wiring diagrams show seal-in circuit Other ICDS should be reviewed to determine if this is a generic problem. For each identified case where seal-in circuits are used even though the ICD specifies "maintained memory," the review should determine whether the system can meet its safety functio i l'

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1. Document Number:

Drawing No. 2323-El-0050, Sheet 2, Revision CP-1 dated 9/5/87,

"Solenoid Operated Vr.lve 1-LV-4500/1 Reactor Water Makeup to CCW Surge Tank Control Valve" Applicable Design Criteria:

OBD-ME-0229, "CCW System" contains applicable I&C design requirements for automatic and manual control of this valve. The team considers these to be adequate to ensure system functionalit . Compliance with Design Criteria:

This diagram shows how the controls and indications are implemented for solenoid operated "alve 1-LV-4500/1. This valve is one of two which automatically opens when a CCW surge tank water level decreases to the "lo-lo" level settin The symbol legend for the valve limit switch incorrectly identifies contacts 33 and 33 as "closed only when valve is fully closed" and 50 be"

"closed except when valve is fully open" respectively. This should be reversed. Approximately 50 other wiring diagrams were checked with no similar error identified. This error is not viewed as programmatic.

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1.- Document Numbers:

SWEC Calculation 16345/6-IC(B)-001,Rev.Idated7/31/87"Instrument Tubing, Minimum Wall Thickness - ASME III" Specification CPES-I-1018, Rev. 1 dated 10/19/87 "Installation of Piping / Tubing and Instrumentation Class I" 2 .- Applicable Design Criteria:

ASME III Section NC-3676 states the minimum wall thickness for tubing. This document also notes that when certain requirements do not apply a smaller wall thickness may be used and provides guidance for determining the minimum wall thickness for tubing under pressur . Compliance with Design Criteria:

The calculation establishes the minimum wall thickness for instru-ment lines between the main line shutoff valve and the instrument in accordance with ASME III Section NC-3676. It follows the design criteria and applies to tubing with obvious localized damage. The ,

calculation considers the effect of internal pressure at temperatures

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up to 650*F. As stated in the calculation, seismic and thermal stresses are the subject of another calculation being prepared by Impell. The installation specification incorporates the results of the calculatio OPEN ITEM I-16

The installation specification does not define localized tubing dam-age. As a result, field installers and inspectors have no acceptance criteria for such tubing.

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i Document Number:

D80-ME-0229 Section 5.4, "System Limitations and Precautions" . Applicable Design Criteria:

. FSAR Section 9.2.2.3.2 "CCW System Leakage Detection and Control" ;

l states that leakage from any component being cooled to the CCW system can be detected as an increase in the level of a compartment ,

of the CCW surge tan Further, each CCW surge tank compartrent (two compartments) level is recorded in the control room to facili-

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tate leakage detectio :

The D80 section states that surge tank crossover flow from one side j of the surge tank to the other is unacceptabl '

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! Normal operation of the system cross connects safety-related loops 1 and 2 through the non-safeguards loop. This would likely cause ;

a one side of the surge tank to continuously spill to the other side because the pump suction pressures cannot be balanced for all load ;

Should the levels in the surge tank be below the sp111over point, t leakage into or out of the CCW system may not be detected as a t change in level of a single compartment. Rather, both compartment levels may rise and fall together. Further, it is likely a large ,

leak anywhere in the CCW system would result in the actuation of both t l surge tank compartment "empty" signals within a few seconds of each ;

other. Both of these concerns relate to the above FSAR comitment

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on leakage detectio :

i OPEN ITEM I-18 i

The total CCW system thermal contraction and expansion is on the i order of 1600 gallons. As a result, it is not clear how small leaks and their locations are to be identified when the CCW loops

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i are not isolated from each othe OPEN ITEM I-19

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i j The CCW system high-high alarm on one side of the surge tank may always t

! be on and as such result in a human factors concern.

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. . Document Numbers:

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Drawing No. 2323-M1-0231, Rev. CP8 dated 3/18/87 - Flow Diagram CCW System, Sheet 7 of 8 Drawing No. 2323-El-0050, Sh. 40, Rev. 5 dated 2/10/83 Solenoid Operated Valve 1-HV-4710 CCW to Excess Letdown and Reactor Coolant Drain Tank Hx Isolation Valve Drawing No. 2323-El-0050, Sh. 41, Rev. 5 dated 2/10/83 Solenoid Operated Valve 1-HV-4711 Excess Letdown and Reactor Coolant Drain Tank HX to CCW Isolation Valve Applicable Design Criteria:

DBD-ME-0229, lists Criterion 57 of 10CFR50 Appendix A as one of the design bases for the CCW system. Criterion 57 requires pipe pene-trations through the containment for closed systems within the con-tainment to have at least one isolation valve outside the containment as close as possible to the penetration. This valve is required to be either automatic, locked closed, or capable of remote manual operatio . Compliance with Design Criteria:

OPEN ITEM I-23:

The flow diagram shows one automatic isolation valve outside the con-tainment on the cooling water line to the in-containment excess letdown and reactor coolant drain tank heat exchangers. It also shows one automatic isolation valve outside the containment on the cooling water line from these heat exchangers. The heat exchangers and the cooling water piping form a closed system. The isolation valves form the second barrier to fission product release. Wiring diagrams for valves HV-4710 and HV-4711 show actuation from only train B. Containment isolation systems are generally built with redundant isolation valves, each actuated by a separate Engineered Safety Features Actuation System (ESFAS) train. Failure to actuate valves HV-4710 and HV-4711 from redundant trains needs to be ad-dressed in the context of meeting Criterion 57 valve operation requirements.

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. . Document Numbers:

Drawing No. 2323-EI-0050, Sb i, Rev. CP-1 dated 10/11/83 - Solenoid Operated Valve 1-FV-4650A ":,: Chillers CCW Supply Control Valve Drawing No. 2323-EI-0050

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/, Rev. CP-1 dated 10/11/83 - Solenoid Operated Valve 1-FV-46508 Ve... Chillers Supply Control Valve Drawing No. 2323-EI-0050, Sh. 47 Rev. 2 dated 2/26/80 - Solenoid Operated Valve 1-HV-4631A CCW Nonsafeguard Loop to Primary Sampling System Valve Drawing No. 2323-EI-0050, Sh. 49, Rev. 3 dated 7/06/83 - Solenoid Operated Yalve 1-HV-4631B Primary Sampling System to CCW Return Header Valve Applicable Design Criteria:

DBD-ME-0229 "CCW System" provides applicable I&C design requirements including automatic and manual control actions, indications, and alarm OPEN ITEM I-20 The DBD considers valves HV 4631A, HV 4631B, FY 4650A, and FV 4650B to be active valves. They are required to operate during the various operating modes that the system must perfonn in order to shut dcwn the plant and maintain the plant in a safe shutdown condition. The DBD gives no information as to how the valves contribute to the safe shutdown of the plant. In fact, the DBD gives conflicting informa-tion as to the required conditions for operation of the valve For example, Table 5-3, CPSES Component Cooling Water System Required Flow Rates, shows the valves open for all plant conditions including an S-signal. However, DBD Sections 6.4e and i indicate that the valves will close on an S signa . Compliance with Design Criteria:

OPEN ITEM I-21 The DBD lists Criterion 44 of 10 CFR 50 Apppendix A as part of the Design Basis. This criterion addresses cooling water systems in-cluding "... suitable redundancy in components and features....

shall be provided to ensure that ... the system safety function can be accomplished assuming a single failure."

Isolation of component cooling water to the vent chillers, while listed in the DBD as being required to operate to safely shut down the plant, is actuated only by Train B. The cooling water source is coninon to cooling water Trains A and B. A single failure coulo block the isolation functio . .

Isolation of the component cooling water to the process sampling system is also listed in the DBD as being required to operate to safely shut down the plant. It is actuated only by Train A of the ESFA The cooling water source is common to cooling water Trains A and B. A single failure could block the isolation functio As indicated in Open Item I-20, the rationale for establishing the closing of valves FV 4650A, FV46508, HV4631A, and HV4631B as required for the safe shutdown of the plant is not clearly identified. In addition, the above single failure issue needs to be addressed.

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, Document Numbers:

t SWEC Calculation SC-11-01, Rev. 3 dated 9/18/87, "Process Control -

Systems Scaling Calculation For Loop 1-T-4561"  :

SWEC Calculation 5C-11-03, Rev. 3 dated 9/18/87, "Process Control Systems Scaling Calculation For Loop 1-T-4563" l SWEC Calculation 50-11-01, Rev. 3 dated 9/18/87 "Process Control  ;

Systems Scaling Calculation For Loop 1-T-4559" i 2. Applicable Desion Criteria  :

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DBD-ME-0229, "CCW System" and DBD-EE-032, Rev. 1-A dated 10/23/87,

"Analog Controls And Scaling" contain applicable system design bases and requirements. DBD-EE-032 describes functional require- i ments of the balance of plant analog controls, the bases for addressing functional performance requirements for various plant I&C systems, and the methods for performing scaling calculation These criteria are consistent with the FSAR and industry standards and are adequate to ensure system functionalit '

3. Compliance With Desion Criteria:

Instrument Loops 1-T-4561 and 1-T-4563 monitor CCW temperature for >

containment spray heat exchangers and provide indications in the .

main control room. Instrument loop 1-T-4561 monitors CCW tempera- I ture for a residual heat removal heat exchanger and provides indica- ,

tion in the control roo !

These instrument loops use platinum resistor temperature detectors that have a calibrated range of 0 to 200"F with exact and linearized

resistance values. These instrument loops also contain converter

{ cards which are calibrated to provide a 0-10 Vdc output signal for i j the linearized resistance inputs. The resulting scaling factors

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are provided as 20'F/Vdc with an accuracy of 1.5%ofspan(200'F).

The team found these calculations to be perfomed correctly. The

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l I methods conformed to DBD-EE-032, and the results were consistent with system functional requirements.

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I Document Numbers:

SWECCalculation16345-IC(B)-029.Rev.Odated 10/19/87,"Station Service Water Supply Header Pressure Lo Channel 1-PIS-4250"

' SWEC Calculation 16345-IC(B)-030, Rev. O dated 10/19/87, "Station Service Water Supply Header Pressure lo Channel 1-PIS-4251" Applicable Design Criteria:

DBD-EE-037, "80P Safety Related Setpoints" and DBD-ME-0233 Rev. O dated 8/4/87, "Station Service Water System" contain principal design requirements for these calculations. Section 4.3.2 of DBD-ME-0233 provides specific instrumentation and control design requirements involving automatic and manual controls, indications, and alams for the SSW system. These requirements are applicable to the calculations.

' Compliance with Design Criteria:

These calculations determine the adjusted setpoint and reset point values for the pressure indicating switches. Each switch monitors supply header pressure for one train of SSW. A low pressure signal from one supply header train provides an automatic start signal to the other supply header train SSW and CCW pumps. This signal also provides a low pressure alar OPEN ITEM I-22 The maximum pressure at which the ITT Barton Switches (1-PIS-4250 and 1-PIS-4251) will reset may be above the normal service water pump discharge pressure. As a result, there may be conditions where there is satisfactory service water pressure, but the low pressure alam, the service water pump auto start signal, and the component cooling water pump auto start signal will not clear. The calcula-tions show a maximum reset point that is not a true maximum reset *

point. Rather, it is the maximum reset point when the switch has been recently calibrated. The true maximum reset point is 10%

(deadband) above the maximum calculated pressure at which the switch may actuate. For these switches, the true maximum reset point is 23.1 psig (upper setpoint limit) + 4.5 psig (total expected error) +

6 psig (maximum deadband) or 33.6 psi Normal operating pressure ,

of the system is shown as 30.2 psi DBD-EE-037 *B0P Safety-Related Setpoints" does not address reset points as affected by overall long tem inaccuracy of instrument setpoint It considers only reset points as affected by minimum and maximum adjusted setpoints. Therefore the design criteria in the DBD are deficient in this regard. For the above cases, the instruments selected may be unsuitable for the service. Previously :'

completed setpoint calculations should be rechecked to detemine if the worst case reset point could interfere with the intended opera-tion of equipment / system _ _ _ _ _ _ _ _ _ _

, . Document Numbers:

- Drawing No. 2323-MI-2234, Sheet 2. Rev. CP-3, Channel No. 4391/4408 - ICD for SSW System

- Drawing No. TNE-MI-2234-02, Sheet 1 Channel Nos. 4393 & 4394 -

ICD for SSW System

- Drawing No. 2323-MI-2233, Sheet 6 Rev. CP-1, Channel No. 4288/4291 - ICD for SSW System

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Drawing No. 2323-EI-0031, Sheet 42, Rev. CP-2, 6.9 Kv Switchgear Bus 1EA1 Station Service Water Pump 11

- Drawing No. 2323-EI-0043, Sheet 14, Rev. CP-3, Diesel Generator Package B Service Water Valve 1-HV-4394

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Drawing No. 2323-EI-0043, Sheet 10, Rev. CP-1, Traveling Screen 02

- Drawing No. 2323-EI-0043, Sheet 7 Rev. 9 Screen Wash Header Solenoid Operated Yalve X-LV-4288

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Drawing No. 2323-EI-0043, Sheet 60. Auxiliary Relays 52aX/1APSW1. 52aX/1APSW2, TD/1APSW1 TD/1APSW2, TDX/1APSW1, and TDX/1APSW2 2. Applicable Design Criteria:

DBD-ME-0233, "SSW System" contains applicable design requirements for automatic and manual controls, indications, and alams. I&C resulting design features include provisions for local and remote manual control of selected SSW system components such as valves and pump motors. Instrumentation required for automatic control actions and alarms are also included. The design criteria are consistent with the FSAR and industry standards and are adequate to ensure system functionalit . Q,mplianceWithDesignCriteria:

The diagrams show the control logic for valves and alarms. Inter-connecting wiring connections and terminations between breaker cubicles and other panels such as shutdown transfer and B0P auxi-

liary relay panels are also shown. In addition, start and stop signals, valve position indicating lights, interconnecting wiring teminations between motor control centers and motor operated valves, interlocks for control functions, indicators and auxiliary relays for alam functions are shown. Those diagrams show how design requirements are to be implemente The team reviewed these diagrams with respect to requirements iden-tified in the DBD and found no concerns or items of non-complianc . .

Electrical - Sumary

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l ELECTRICAL DISCIPLINE SUMMARY 1. Review Sasole  !

P Design document samples were selected so as to complement the [

earlier design review which covered the Class 1E de power system, motor control center starter coil pickup analyses, and protective  !

relay settings. The current review addressed cable sizing, fire- .

stop derating, the 6.9 kV power system, diesel generator loading  !

capability, electrical penetration protection, and separatio i criteria. The selection of such diverse design document samples '

during the two reviews ensures that the reviewed samples are representative of the total SWEC effort in the electrical discipline area, t 2. Open Items During this design review, a total of fourteen open items (E-17 through E-30) were identified. Six (E-17 through E-22 and E-30)

relate to DBDs and/or calculations while the other seven (E-23  ;

through E-29) relate to separation concerns. Most of the open items relate to either the scope or justification of design criteri l Inadequate Scope of Criteria

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The DBD for the cable philosophy and sizing (DBD-EE-052) does i not provide adequate criteria for insulation thickness for the  :

cables used in 480 Vac high resistance grounded systems (0 pen Item E-17). Open Item E-22 relates to the 6.9 kV system when  ;

operating on onsite diesel generators. In this mode, the system will operate as a high resistance grounded system. The i DBD does not address the 6.9 kV insulation thickness require- i ments for this mode (173 percent voltage level). Inadequate Justification for Criteria DBD EE-052 indicates that all cables are sized to carry 125 percent of the rated current, whereas the supporting calculation indicates that all cables cannot carry that -

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current simultaneously (0 pen Item E-18). The calculation for the firestop cable ampacity derating factors (Calculation '

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No. 16345-EE(B)-052) concludes that no derating is required for randomly installed cable sizes No. 4 AWG and smalle Sufficient justification for this conclusion was not apparent t (0 pen Item E-19). The DBD for the 6.9-kV electrical power system (DBD-EE-040)permitsfasttransferwhenthepreferred ,

and alternate sources are up to 40 degrees out of phas .

Assurance needs to be provided that this transfer condition I will not damage motor (0 pen;SemE-20).

The DBD for the separation criteria (DBD-EE-057) pemits 1 inch separation distance between cable trays containing control and  :

instrumentation cables, which is not in accordance with the

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applicable IEEE Standard. The team was unable to find justifi-cation for this deviation (0 pen Item E-23). Open Item E-27 concerns the adequacy of protective fire wrap as barrier material equivalent to metal-enclosed raceways. Open items E-28 and E-29 concern lack of identification of cables not meeting separation criteria and lack of analyses for circuits without an acceptable isolation device. IEEE Standard 384 and Regulatory Guide 1.75, which the applicants have committed to, require that the associated circuits be uniquely identifie DBD-EE-057 does not adequately address this requirement (0 pen Item E-24).

Open Items E-25 and E-26 indicate the need for confirmation that the worst case cable size and the worst case fault current were selected for the electrical raceway separation verifica-tion testin . Additional Review The review of all the selected design document samples was not com-pleted because of a major redesign effort involving 6.9 Ky elte-trical power system. In addition, some other items selected were not available at this time. Significant items where the review is incomplete are as follows: .9-Kv electrical power system design, drawings, and cal- ,

culations; DG loading capability verification; Electrical penetration protection; Justification for separation deviations; and l Associated circuit analyses for control and instrueenta-tion circuits.

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Electrical - Evaluation of Documents Reviewed

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. r Document Number:

SWEC DBD-EE-052 Rev. O dated 06/08/87, "Cable Philosophy and Sizing Criteria"  ; Applicable Design Criteria:

This document provides the design basis for selecting and sizing electric cables suitable for the loads and environmental conditions throughout the plant. It describes requirements and criteria for selecting the proper conductor, insulation, and jacket for power, control, lighting, and instrumentation cable The cable insulation rating and thickness are determined in ac-cordance with an indtstry standard, e.g., ICEA-S-68-516 (NEMA-WC8),

and is based on the system operating voltage and the system ground-ing metho OPEN ITEM E-17 Paragraph 5.3 in the DBD correctly states, "...with insulation thickness based on 133 percent voltage level". This is clearly stated for the 8kV cable, where the system is low resistance grounded. However, for the 480 Vac system, which is a high resistance grounded system, the DBD does not relate insulation thickness to the 173% voltage level.

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I Docuawnt Number:

SWECCalculation16345-EE(B)-052,Rev.Odated 06/29/87,"Firestop Cable Ampacity Derating Factors" Applicable Design Criteria:

D80-EE-052, Rev. O dated 06/08/87, "Cable Philosophy and Sizing Criteria" requires: For the random fill cables in open-top cable trays, the application is in accordance with IPCEA-P5-44 (DBD Section3.0) All cables are sized for 125 percent full load amperes, except for MCC feeder (DBD Section 6.6)

' A 100 percent load factor will be used for selecting con-

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ductor size. (DBD Section 6.7)

' For random installed cables sizes No. 4 AWG and smaller, noderating(DBDSection6.10.1) factor need be applied regardless of fire materia '

OPEN ITEM E-18 As per Calculation 16345-EE(B)-052, page 33, when passing through

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firestops, all cables cannot simultaneously carry 125 percent full load current. (Refer to Item b. above.) This limitation is inconsistent with the above (item b) DBD requirement.

" Compliance with Design Criteria:

Calculation 16345-EE(B)-052 identifies different configurations where cables penetrate fire rated walls and floors, thus requiring a

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firestop. The calculation utilizes an analytical technique to deter-mine appropriate derating factors for various cable configurations, which are included in DBD-EE-052.

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OPEN ITEM E-19 i The calculation on page 34 concludes that no derating is required

! for cable sizes no. 4 AWG and smaller. This conclusion is based on the assumption that it is " ... not practical to consider all cables operating at 1.25 x Ifl ...". This is not in compliance with Criterion 2b above.

! The calculation uses the following documents as the basis for the above conclusion: "Ampacity of Cables in Trays With Firestops", IEEE Trans-actions on Power Apparatus and Systems, Vol. PAS-100, No. 7. July 1981.

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.t l l "Ampacity Test of a Silicune Foam Firestop in a Cable Tray", IEEE Transactions on Power Apparatus and Systems, Vol. PAS-100, No. 11, November 198 '

The above technical papers do not appear directly applicable to Comanche Peak because:

1) The data is based on the use of much larger cables, i.e.,

4/0, 2 AWG and 6 AWG, as opposed to 4 AWG and smaller for Comanche Pea ) The cables used in test were aluminum cables, as opposed to copper for Comanche Peak. Even though the aluminum test cables have a lower thermal conductivity than copper, they utilize larger cross-sectional area for the same ampacity.

i 3) The cables were carefully placed in the tray to ensure contact between the cables and to minimize air pockets, which is not consistent with general field installation In addition these above differences, Reference a. indicates that, for a 9" to 12" thick silicone foam firestop, the temperature rise could be 12"C to 19"C higher than the temperature rise without the firestop. Reference b, states that for smaller cables the tempera-ture rise could be up to 40'C higher with these firestop Based on the above discussion, the calculations does not provide adecuate basis for the conclusion (on pages 34. and 35) that, "For rancom filled cables sizes no. 4 AWG and smaller - no derating need be applied".

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SWEC DBD EE-040, Rev. O dated 6/08/87,"6.9 kV Electrical Power System" Applicable Design Criteria:

This DBD describes the functions, design requirements, modes of operation, arrangement, performance characteristics, and limitations of the 6.9 kV normal and safeguards electrical power system, in-cluding 7.2 kV metal-clad switchgear, nonsegregated phase bus duct, system grounding, and cable The DBD provides the requirements for the short circuit ratings, voltage regulation, transfer schemes, separation, testability, protective relaying, and instrumentation and controls. These design criteria are consistant with the FSAR and industry standards and are adequate to ensure system functionality except as noted belo OPEN ITEM E-20 When discussing the fast transfer scheme, the DBD state "

... permits fast transfer if the startup source voltage is at or above 85 percent of the rited bus voltage ... and normal and startup voltages are not out of phase by more than 40 degrees."

Assurance needs to be provided that the 40 degrees out-uf-phase transfer condition will not damage any of the connected motor OPEN ITEM E-21 Section 4.3.2.1.8 of the DBD states, "A control voltage of 90 Vdc to 130 Vdc is required for the operation of the closing coil ..." This should be 90 Vdc to 140 Vdc as discussed in the Open Item E- OPEN ITEM E-22 The DBD describes the 6.9 kV electrical power system as a low re-sistance grounded system. When the system is connected to the offsite power system through the station service auxiliary trans-formers, the grounding resistors at the transformers provide a low resistance path for the ground f6 ult current. When the plant is operating in this mode, the 6.9 kV cable insulation thickness (for the 133 percent voltage level) is in accordance with the industry standar However, when the safety buses are powered by the diesel generators, i.e., on loss of offsite power, the only system grounding is through the diesel generator grounding system. In this mode, the 6.9 kV system operates as a high resistance grounded system. The 6.9 kV cable insulation thickness requirement (173 percent voltage level) '

has not been addressed in the DB _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ._________ __ -_-

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I The 6.9 Ky electrical distribution system is undergoing a major redesign effort which includes the addition of new station service auxiliary transformers. Because of the significance of this change, the following documents will be reviewed later in order to assess compliance with the design criteria.

. . .9 kV and 480 Yac one-line diagrams Elementary diagrams for 6.9 kV bus transfer schemes Statics service voltage regulation calculation  : .9 kV short circuit calculation DBD-EE-040, 6.9 kVElectricalPowerSystem(revised) Validation of diesel generator loading capability ' DBD-EE-62, Containment Electrical Penetration Protection C21culation No. 17, electrical penetration protection

, Electrical penetration protection problem resolutions

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1. Document Number:

- SWEC Calculation 16345-EE(B)-048, Rev. O dated 8/14/87, "Protection and Ampacity of Electrical Containment Penetration" Applicable Design Criteria: The penetration conductor should have primary and backup protection devices physically separated, The total short circuit clearing times of primary and backup protection devices should be less than the manu-facturer's penetration conductor thermal limit curve times over the er* m range of short circuit current The rated tection pick-up(fuses and breakers) should be less thancurients of the devices the manufacturer's penetration rated continuous current These criteria provide adequate assurance that either the primary or backup penetration protection device should actuate prior to the containment electrical penetration thermal limits being exceeded.

l Compliance with_D_esign Criteria:

The objective of this calculation is to verify the adequacy of the ampacity of the electrical penetration assemblies for nonnal, over-l load and short circuit conditions. This verification is necessary

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because the penetratioil assemblies manufactured by Arrphenol were replaced with Conax feed-through/ adapter module assemblie OPEN ITEM E-30 This calculation a S sses protection for twenty-three classes of electrical penetri un circuits. Of these twenty-three, the calcu-

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lation shows that nineteen do not meet ene or more of the three es-

! tablished criteria. Based on these results, it is stated in the

! calculation that these non-compliance circuits will be further eval-uated. However, there was no indication as to specific evaluation /

resolution plans or actions to ensure these circuits comply with the design criteria.

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1. Document Number: SWEC DBD-EE-057, Rev. O dated 7/17/87, "Separation Criteria" TUGC0 - Cable Separation Test Program, Report No. 48422-1 TUGC0 - Electrical Raceway Separation Verification Testing, Report No. 48037-02 SWEC - Electrical Separation Verification Testing for Beaver '

Valley Power Station Unit #2, Report No. 17666-02 SWEC Electrical Separation Verification Testing for the Nine ,

Mile Point Nuclear Station - Unit #2, Report No. 479606-02 i DIR-0-1599 - Lack of Isolation Requirements

' DIR-D-0304 - Train Designation Error, DIR-D-1800 - Inadequate Separation between Class 1E and Non-1E

, DIR-E-0386 - Failure to Maintain Minimum Separation

' DIR-E-0388 - Separation Criteria Analysis i DIR-E-0389 - Failure to Maintain Minimum Separation l DIR-D-1799 - E-9 Panel Separation I DIR-D-1797 - Non-Class 1E Circuits without Isolation I Specification 2323-ES-18 - Protective Relay Boards and Racks SDAR CP-85-01 - Main Control Board Cable Separation Violation SDAR CP-86-42 - I&C Cabinet Supply Breakers SIIP, CPS-386-3 - Electrical Cable Separation DCA, DCA-55667 - Separation Arrangement ISAP, I.b.2 - Results Report, Rev. 1 dated 12/10/86, "Flexible l Conduit to Cable Separation"

' Applicable Design Criteria: ,

Design criteria for physical separation of Class 1E equipment and circuits is defined in IEEE Standard 384-1974 'and is augmented in the Regulatory Guide 1.75, Revision 2 dated September, 1978, "Physi-cal Independence of Electrical Systems." (The applicants have com- -

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mitted to these documents.) However, if the required separation dis- l l tances are not met, the standard states, "In those areas where the i damage potential is limited to failures or faults internal to the electrical equipment or circuits, the minimum separation distance can be established by analysis of the proposed cable installatio This analysis shall be based on tests...." Position C6 of Regulatory Guide 1.75 states that such analyses should be submitted as part of the Safety Analysis Report and should identify those cir-cuits installed in accordance with the analyse . Compliance with the Design Criteria: j SWEC presented a large number of documents with pertinent data spread throughout, some specific to Comanche Peak Station and others to testing for other stations. There was little evidence of detailed evaluations for the applicability of specific data to justify specific criteria deviations or the applicability of the testing for the other stations to the Comanche Peak cables and installations. For the above reasons, the team was unable to review all areas of significance to physical separation, e.g., cases where Comanche Peak is justifying deviations from industry design criteri a 6 OPEN ITEM E-23 Section 6.5.1.7 of DBD-EE-057 states that the minimum separation of 1 inch between control and instrumentation cable trays is permitted in cable spreading areas. Further, Section 6.5.2.7 states that the same separation is permitted in general plant area The IEEE Standard and the Regulatory Guide require these distances to be: I ft. Horizontal x 3 ft. Vertical (Cable Spreading Room) ft. Horizontal x 5 ft. Vertical (General Plant Area)

We were unable to find adequate testing and/or analysis to justify 1" separation as stated in the DB Further, these criteria are applicable to separation between Class 1E and non-Class lE trays. In the case of non-Class 1E trays more than one cable can be carrying fault current simultaneously. This reduced clearance needs to be justified for this situatio OPEN ITEM E-24 Ser" 1 6.1 in the DBD requires color code letters as follows: "0" fo. ' din A and Associated Train A cables, and "G" for Train B and Assot ated Train B cable Section 4.5.(1) in the IEEE Standard requires that the associated circuits be uniquely identifie Regulatory Guide 1.75 endorses this requirement. The DBD does nat satisfy this requiremen OPEN ITEM E-25 Report No. 17666-02, Electrical Separation Verification Testing l Report for the Beaver Valley Power Station, indicates that tests for power cable fault testing used #6 AWG cable as the worst case heat source. We were unable to find any analyses and/or justifi-cation that #6 AWG fault cable is the worst case heat source, e.g.,

l compared to the larger cables, e.g., 2/0, 500 MCM, et OPEN ITEM E-26 Report No. 48037-02, Raceway Separation Verificatiun Testing for Comanche Peak, in part, uses 105 Amperes (A) for #12 AWG cable as the worst case fault current. In portions of tests, we found higher currents, e.g., 120A and 135A, producing higher insulation jscket temperatures. No justification was apparent for using 105A as the worst case test current, i

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OPEN ITEM E-27 The IEEE standard requires that, for reduced separation, the cir-cuits will be run in enclosed raceways that qualify as barrier Section 6.4.1 in DBD-EE-057 permits a protective wrap of woven

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silicon dioxide as equivalent to a metal enclosed raceway. It is not clear that such a protective wrap serves the same barrier func-tion as a metal enclosed raceway. When any cable is faulted and gases are generated in the insulation, the glass tape could ruptur In addition, handling during installation and time related aging may compromise the barrier. These aspects need to be addresse OPEN ITEM E-28 Position C6 in Regulatory Guide 1.75 indicates that all circuits which utilize lesser separation distances and are accepted on the basis of analyses and testing should be identified. Because of their significant demage potential, all power circuits which utilize analysis / testing for justification of lesser separation should be identified. This has not been accomplishe OPEN ITEM E-29 Section 4,1.3 in DBD-EE-057 states, "Lack of i301ation device shall be justified by analysis". We found that analyses and justifications were prepared for the pcwer level circuit Similar enalyses for the control and instrumentation circuits were not availabl We also reviewed the disposition of various field identified problems (Refer to documents listed under 1.f through 1.s.) These have been adequately dispositioned in accordance DBD-EE-05 . .

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Systems Interaction - Sunnary

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Systems Interaction Discipline Review Sample:

This phase of the team's review focused on design basis documents and design criteria for implementing the Systems Interaction Program which includes three elements: pipe break postulation and effects; seismic /non-seismic systems interaction; and missile postulation and effects. The team reviewed the three DBDs applicable to the above areas and the calculation of jet attenuation. The latter is used in jet impingement effects evaluation . Open Items:

Open Item S-1 on the D8D for missile postulation and effects concerns the basis for assuming that a wedge-shaped sector of an impeller having a 134'

sector angle yields the maximum translational missile energ Open Items S-2 through S-5 on the DBD for seismic /non-seismic interactions concern (1) clarification of items which are covered by the DBD and the implementing program and (2) the program for validating the dynamic impact eriteria.

l Open Items S-6 and S-7 on the DBD for pipe break postulation and effects I

concern incomplete criteria on the use of a matrix for moderate energy jet j spray distance and locating the pipe whip plastic hing Open Items S-9 through S-15 on the calculation of the jet attenuation factor

concern misinterpretation of terms and limitations of theory which could have l the effect of causing erroneous results if the calculation were to be im-l plemented in its present for . Additional Review

The team did not review the DBD implementation because Ebasco had not pro-ceeded sufficiently in that regard. The team will review this in the future, primarily with respect to system walkdown e O Systems Interaction - Evaluation of Documents Reviewed

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. . Document Reviewed:

Ebasco Design Basis Document DBD-ME-105, Rev. O. dated July 20, 1987,

"Missile Postulation and Effects." Applicable Design Criteria:

The objective of the Design Basis Document (DBD) is to establish the appropriate criteria to be used in the evaluation to ensure that the plant design meets the requirements of GDC-4 with regard to inter-nally generated missiles from failures of components of high pres-sure fluid systems and dynamic equipment including the main turbin Sections 3.5 of the FSAR and NUREG-0800 (Standard Review Plan) provide guidance which is referenced below. The following areas were reviewed:

Missile Types: The DBD provides criteria for the identification of various potential missile types: pressurized fluid missiles (in-cluding piston-type and jet propelled), mechanical kinetic energy missiles (rotating equipment) and stress / strain energy missiles as well as specific missile characteristics based on each type of mis-sile. These criteria are consistent with the FSAR and Standard Re-view Plans and with industry practic Missile Selection: A major aim of the criteria presented in the missile selection section is to evaluate potential missiles to de-termine if credible failure mechanisms exist that would produce a missile. Specific criteria are provided to aid in the evaluation and elimination of certain missiles based upon individual equipment i

attributes (e.g., equipment casings will contain any missiles generated.)

OPEN ITEM S-1

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Attachment A-1 Elimination Equation (Missiles from pumps, compressor

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and turbines) indicates that a realistic pump missile is assumed to be a wedge-shaped sector of the impeller having a sector angla of 134 degrees which yields the maximum translational missile energy (velocity). No justification or reference is provided for the 134 degree sector angle yielding the maximum translational missile energ Missile Trajectory: Criteria are provided in the DBD for determina-tion of trajectories of postulated missiles, based upon missile typ These criteria are consistent with the FSAR and industry practice and are presented such that they will be clearly interprete Design Bases for Targets: The DBD provides criteria for evaluation of targets, both functionally and structurally. The single failure criterion is invoked in the functional evaluation of potential mis-l sile targets. The DBD also provides guidance in evaluating both i local and overall effects of missile interactions. The criteria presented in this section are consistent with the FSAR and Standard Review Plans and conform to industry practic . ._ - .. ____ - __ _ - - __ _ __ _ _ _ _ _ _ _ _ _ - _ _ -

. o j E_ valuation Program: A program outline is provided in the DBD for evaluation of missile interactions. The program outline denotes l requirements for documentation and requires as-built verificatio l The evaluation program appears to be adequate to ensure the identi- I fication, evaluation and operability of essential systems, struc-tures and component o . Document Reviewed:

Ebasco Design Basis Document D80-ME-005, Rev. O, dated July 24, 1987,

"Seismic /Non-Seismic Systems Interaction Program." Applicable Design Criteria:

The objective of the Design Basis Document (DBD) is to provide the criteria for the review program that will evaluate the physical in-teraction between non-seismically design plant features and essen-tial structures, systems, and components to satisfy the requirements of GDC-4. The following areas were reviewed:

Identification of Non-Seismic Sources: The DBD provides criteria for the ioentification of non-nuclear safety components in Seismic Category I structures. Specific references are provided in Section 4.3.3 for identi-fication of non-seismic conduits and piping. The listing of exempt commodities in Section 4.2.3 appears reasonable and is in keeping with industry practic OPEN ITEM S-2 DBD Section 1.3.9 states that non-seismically supported conduit 2 in, diameter and under are not considered as non-seismic source In addition, this section includes as non-seismic sources 2 i diameter and under non-seismic piping with line-mounted equipment, as well as threaded fire protection piping 2 in. diameter and unde It appears that non-seismically designed, non-threaded small bore piping without line-mounted equipment is not addressed in this evaluation program. Section 4.4.3 seems to indicate that 2 i diameter, non-seismically design conduit and non-threaded piping are to be included in the interaction walkdow A discussion with the applicant indicates that non-seismic 2 in, diameter and under conduit and non-threaded piping without line-mounted equipment are, in fact, being evaluated for interactions with seismic structures, systems and components under another progra The DBD should be clarified to state which commodities are evaluated under other seismic /non-seismic interaction evaluation program Identification of Seismic Components: Criteria for determining the locations of seismic Category I equipment and components are provide OPEN ITEM S-3 DBD Section 1.3.3 defines Seismic Category II structures, systems or components as those items whose continued function is not required following a seismic event, but whose failure could reduce the func-tioning of a Seismic Category I system or component to an unacceptable safety level, and comits to design and construction of these structures, systems and components such that the SSE would not cause such failure The DBD further defines non-seismic sources as structores, systems and components that are not specifically identified as seismically designe .____ _ _ _ _ _ -_

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It is unclear from the DBD how Seismic Category II structures systems, and components are treated under the Seismic /Non-Seismic Interaction evaluation progra Interaction Evaluation Criteria: The DBD provides various criteria and the methodology for evaluating and resolving identified interaction Dynamic impact criteria are provided in Section 4.3.4. whereby an inter-action may be evaluated as acceptable by the walkdown team members, via an engineering inspection, without calculation. Seven general criteria are provided for this evaluation and the criterion used for resolution of any specific item is noted as part of the walkdown documentation. The applicant should nrure that the walkdown team members possess sufficient experience laels to allow them to properly make such determinations. To preclude misapplication, the dynamic impact criteria will be validated at the end of the interaction program via calculations performed on a random sample of interaction OPEN ITEM S-4 DBD Section 4.4.5 discusses the validation of the dynamic impact criteria via a random sampling technique and indicates in Item 2 of that section that a sample size will be calculated such that the criteria validity may be investigated to a high degree of probability. The DBD should provide some detail or reference as to how the sample size will be deter-mine OPdN ITEM S-5 DBD Section 4.4.5(5) states that "established methods of resolutions as outlined in this DBD shall be utilized if any of the criteria prove invalid." The DBD should provide additional details as to how it will be determined that a particular dynamic impact criterion is invalid and, if so, what steps will then be taken for the population of interactions that utilized the invalid criterio The use of dynamic impact criteria is recognized as a valid way to simplify the resolution of seismic /non-seismic interactions and the validation program will add control over their use. The specific impact criteria provided in the DBD are reasonable compared with current industry practice. Criterion 7 deals with sources impacting cable trays and the deleterious effect on the cables within the tray Based on its experience that cable trays cannot withstand much outside loading and stay within qualification limits, the team suggests that this area receive special emphasis in the program implementatio Other criteria for evaluating and resolving identified interactions are provided, such as detailed structural calculations, the use of industry data such as the Earthquake Experience Data Base and use of the provisions of NUREG 1030. These ethods are acceptable and con-sistent with industry practic . . The team concludes that the criteria contained within the Design Basis Document, with the exceptions noted above, fonn the basis for an evalu-ation program which, if properly implemented, will be adequate to ensure the operability of essential structures, systems, and components fol-lowing a seismic event and meet the intent of Regulatory Guide 1.29, position . . -. --.

. . Document Reviewed:

Ebasco Design Basis Document DBD-ME-007, Rev. O, dated July 20, 1987,

"Pipe Break Postulation and Effects." Applicable Design Criteria:

The objective of this Design Basis Document (DBD) is to establish the criteria for the review program that will evaluate the effects of postulated piping ruptures on essential structures, systems, and com-ponents to satisfy the requirements of GDC-4. Criteria are identified in FSAR and SRP Sections 3.6. The following areas were reviewed:

Protection Requirments: Criteria are provided for the protection re-quirements following various pipe break types. The protection require-ments are taken primarily from the Westinghouse criteria SSDC 1.19, which is the industry standard for Westinghouse plants. These criteria

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are also provided in the FSAR, Criteria for the consideration of single l

active failures are based upon the requirements of SRP 3.6.1 and other industry standards. Criteria are also provided for protection of con-tainment isolation capability which appear to be reasonable and in accordance with industry practic Scope of Interaction and Effects of Rupture: Generalized criteria are provided to define pipe whip displacement, jet impingement, environ-mental and flooding effects. These criteria are consistent with NRC guidance in the Standard Review Plans, industry standards and general industry practice. It is noted that, with the exception of selection of crack locations in moderate energy lines, this DBD does not address the determination of postulated rupture locations, as that function is perfomed by the pipe stress engineering group. In addition, the DBD does not consider in its scope the dynamic effects of primary loop breaks, as CPSES has invoked the "leak before break" criterion and also does not consider the arbitrary intermediate break as allowed in the NRC generic letter of June 19, 1987.

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Additional detailed criteria and methodology are provided in Attach-ments 1, 2, and 4 to the DBD in the areas of jet modeling, MELB spray l distance and plastic hinge formation. With the exception of some typo-i graphical errors that were clarified in a discussion with the applicant, Attachment 1 appears to be a reasonable extension of industry standard ANSI /ANS 5 It is understood that the applicants plan to comit to l this standard in Amendment 68 to the FSA The FSAR change request for

! Section 3.6B, dated October 23, 1987, provided additional justification

for the conclusions of Attachment 1, but the detailed supporting calcula-tions were not available to the team at this time.

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OpEN ITEM S-6 Attachment 2, "Moderate Energy Jet Spray Distance," provides a matrix of moderate energy jet spray distance, based on pressure in the source line and distance from the floor. Section 5.4 of the DBD references this Attachment, but does not describe what the data represents or how it is to be used. A discussion with the applicant indicates that the

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matrix provides the maximum horizontal distance from the broken pipe that could be wetted at floor level, based on a moderate energy crack oriented 45 degrees vertically. .The DBD Section 5.4 and/or Attachment 2 require additional explanation such that the data may be properly utilized for evaluating moderate energy line break Attachment 4 provides a procedure for the calculation of plastic hinge location for use in evaluating pipe whip potential. The procedure is useful in the evaluation of pipe breaks but is incomplete as discussed belo OPEN ITEM S-7 Attachment 4 provides a procedure for locating a plastic hinge (i.e.,

the point about which a pipe begins to whip) follcwing a pipe brea The team's review of the equations for plastic moment capacity and distance of plastic hinge from center line of brokeri run oatermined there were significant missing portions. The team determine'J that the missing portions could not be typed on a normal keyboard and were to be manually added by the author. The applicant advised that no evalua-tions have been completed and released that were based on this procedure.

. Shutdown Logic Diagrams: Criteria are provided for shutdown logic diagram development, which describe the functions, systems and com-ponents necessary to mitigate the consequences of a postulated pipe break and achieve plant shutdown. The spectrum of breaks has been classified into five families of break types. The classification is logical based upon systems required for mitigation and the potential effects of the breaks. Each of the five break. types was reviewed by the team and the basic systems and operations listed as required for mitigation and shutdown appear correct and complete. Loss of offsite power was assumed for all break types, even those in which a plant trip is not a direct consequence of the brea OPEN ITEM S-8 l DBD Section 6.4 discusses a matrix of systems and functional modes necessary for the mitigation of each break type and the criteria for modeling each function into the shutdown logics, and indicates that this data may be found in DBD Section 1.5, Review of the DBD indicates that this data has not been included.

r l The team concludes, based on the review of this DBD, that sufficient I

criteria are presented to form the basis of an adequate evaluation i program to review the varied effects of postulated pipe ruptures, such as pipe whip, jet impingement, flooding and environmental effects.

l subject to resolution of Open Items S-6 through S-8.

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Jet Attenuation, CPE-SI-CA-0000-645, Rev. O, August 7, 198 . Applicable Design Criteria:

Design Basis for Protection of Light Water Nuclear Power Plants Against Effects of Postulated Pipe Rupture, ANSI /ANS-58.2 - 198 . Compliance with Design Criteria This calculation studies the development of a jet from a high energy line break, and evolves an attenuation factor as a function of distance along the axis of the je OPEN ITEM S-9 The calculation claims (Pg. 2) that ANSI /ANS-58.2-1980 (Ref. 1) does not address the attenuation of the jet. The team believes that Reference 1 does address the attenuation of the jet, although it does not appear as an explicit coefficient. Any attempt to develop an additional attenuation coefficient is inappropriat OPEN ITEM S-10 The procedure uses a method recommended by Reference 1 based on jet axial velocity, pressure and temperature profiles developed in Reference 2 instead of using Eq. D-2 and D-3 as prescribed in Reference 1. However, this method is applicable to gaseous jets and can be used for steam water mixture jets, if the quality beyond the asymptotic plane is greater than 90%. The subject document, however, uses this approach without any restriction on the quality of the jet fluid. Actually, the lower quality mixture behaves very differently from perfect gas, and because of the i

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relatively higher density of the two phase fluid, the jet will attenuate at a significantly slower rate compared to the gaseous jets. This l suggests that the method used in the document is not conservative for low-quality jets. In most cases of flashing water jets (both for primary and secondary coolant systems), the quality of the jet fluid is signifi-l cantly lower than 90%. The assumption that water substantially separates out before the asymptotic plane resulting in a high quality steam beyond that plane cannot be justifie OPEN ITEM S-11 o

The postulation (on page 13) that the force that the jet can impart to a target is proportional to p +p V /2 is not correct. The impingement force should be proportional to (P - p), where P is the local stagnation l pressure and p is the local static pressure and they are related by the following expression: ,

y P= p 1+ T-1 M ( y- g

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M is the local Mach number.

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It is to be noted that beyond the asymptotic plane, local static pressure (p) remains constant and is equal to the pressure surrounding the je OPEN ITEM S-12 In a free jet the total momentum of the jet beyond the asymptotic plane remains constant along the axis of the jet. As the jet entrains more and more of the ambient fluid, its velocity and temperature profiles become flatter. But if the target is large enough to intercept the entire jet, the impingement force does not drop even though the stagna-tion pressure at the jet axis has decayed substantiall The calculation interprets Figure D.7 in Reference 1 as a plot of varia-tion of local static pressure with distance. It is actually a plot of (P - p)/p, vs. distance, where pe is the exit plane pressure of the je This figure is the same as Figure 5 of Reference 2. It is to be noted that (P - p) is measured at the jet centerline. The incorrect use of this figure in the document under review has led to the conclusion that there is an additional attenuation factor. It is suggested that Ref. 2 be consulted in case further clarification is neede The work done by the jet fluid on the surrounding air and-the exchange of molecular kinetic energy do not result in any reduction of momentum of the entire jet including the entrained fluid, and any attenuation effect resulting from the work done by the jet and energy exchange cannot be justifie OPEN ITEM S-13 Figure 6 of Reference 2 represents the decay of temperature difference ratio (ATm/ ate). The subject document uses this figure inappropriately as temperature ratio (T*) on Page 11. The error due to this might be significant for the temperature range of interes OPEN ITEM S-14 The document determines the attenuation factor " g" in somewhat arbitrary fashion. First, it claims that this factor should follow the decay of P*, and then, since the decay of P* is excessive, it considers the decay of V* as the acceptable attenuation. Since this factor has been applied to the impingement force on a target using Reference 1, the credit due to the attenuation of jet has been double-counted, and the results are unacceptabl OPEN ITEM S-15 Considering the misinterpretation of some terms (discussed in Open Items S-12 and S-13 above) derived from Reference 2, and limitations (discussed ,n Open Items S-10 and -S-11) in the theory, the results presented in the document appear to be erroneous. Hence, any con-clusions based on this document may not be acceptabl . i

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REFERENCES: "Design Basis for Protection of Light Water Nuclear Power Plants Against Effects of Postulated Pipe Rupture," ANSI /ANS 58-2-198 . Anderson, A. R. and Johns, F. R.. "Characteristics of Free Supersonic

Jets Exhausting into Quiescient Air," Jet Propulsion, January 1955.

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Civil / Structural - Sunnary

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CIVIL / STRUCTURAL 1.0 REVIEW SAMPLE The SWEC validation of the structural aspects of the plant design es-sentially tas been done by developing new calculations utilizing the Gibbs & Hill drawings as structural system input. Table 1 indicates the population of documents in the SWEC structural validation program and the team's sample covering both the current and previous inspec-tions. Sufficient numbers of documents were available to enable an adequate number of representative documents to be selected in the review sample for each significant structure except for structural steel framin The team considered the types and numbers of documents reviewed in the available areas to be sufficient to evaluate the overall adequacy of the SWEC design validation progra The calculations reviewed for the Safeguards and Auxiliary Buildings pro-vided a subpopulation sampling for other Category I concrete structures which are analysed and designed under the same standard Nonsampled calculations (including the Fuel Storage Building) were reviewed for general calculational methodology and quality and were found to be similar to the other Category I calculations reviewed. The Service Water Building calculations were not available for review but are considered to be represented by the sampling of other Category I building calculation As in the initial inspection phase, the review of calculations looked into the overall analysis / design approach for consistency with the

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DBD requirements, application of engineering concepts and principles, l incorporation of loading requirements, and interface with other supple-l mentary calculations. Each calculation reviewed was essentially followed i through to track the course of analysis and/or design from the initial assumptions and references, through concepts and steps of engineering /

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design application, to the conclusions reached. Contributing calcula-tions were investigated to various degrees, depending on the significance of their input to the subject calculation being audite Review of design drawings was done on a selected basis to confirm calculation input i and to determine the completeness of design coverage and depth. This i review did not include a rigid checking of numerical results, but did l include nominal numerical checks as deemed necessary to substantiate l calculation steps, approaches, etc.

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Table 1 NRC Review Sample SWEC EFE NRC Audit Document Selected Type Total Avai Identified Comp Population Avail. Comp DB)s 10 7 6 4 10 7 5 H.O. Cale Auxiliary Bld Concrete 39 34 2 -

14 14 4 Steel 9 2 - -

5 2 1 Safeguards Bld ~

Concrete 29 27 8 5 13 12 8 Steel 28 - 4 - 5 - -

SW Intake Struct Concrete 15 3 - -

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Steel 2 - - - 2 - -

Missile Barriers 10 10 1 -

4 4 -

Fuel Stor. Bldg.

t Concrete 11 6 - -

5 3 -

Steel 2 - - - - - -

Tanks Concrete / Steel 6 4 1 1 4 4 4 Tunnels Concrete 3 1 - - - - -

, Ductbanks/ Manholes I concrete 3 1 - - 1 1 1 l Reactor Int.

, Concrete 42 21 - -

13 8 6 l Steel 16 2 - - 3 1 1 l React. Cont. Bld Liner 6 5 2 - 4 4 2 Penetrations 3 1 2 -

2 2 1 Hatch 1 1 - -

1 1 1 Shell 6 6 - - 4 4 4 Gen'l Analy TATT B1das.) 51 36 2 1 23 14 4 Embedment 8 5 - - 2 1 -

Total H.0. Calcs 290 165 22 7 110 75 37 Site Cale Total All Documents 453 325 28 11 131 93 51

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2.0 OPEN ITEMS Consistent with the previous inspection observations, the review of addi-tional documents indicates the SWEC design verification program, as a whole, has been handled on a systematic, detailed basis, utilizing all new calculations to demonstrate the adequacy of the constructed plan Good analytical methods have been employed, and standard design code and DBD requirements have been adequately implemented in the development of calculations, except as noted in Table 2 which summarizes Open Items identified by the tea The design validation work has proceeded prior to being able to establish all of the final loadings on the structure Loads considered to conser-vatively envelope the estimated final loads were used to enable the vali-dation work to proceed on an expedient basis. The iterative process of utilizing interim es'timated loads has included a tracking procedure to ensure that the calculations with open Icading considerations will be revisited for confirmation and/or reworking. Open Items C/S 26 and C/S 29 concern failure to document all loads requiring confirmation. SWEC needs to determine whether these examples, based on the team's limited sampl l are indicative of a programmatic breakdown in this tracking procedur As a related matter, Inspection Report 50-445/87-19, 50-446/87-15 includes two electrical items requiring confirmation which were not adequately identifie (0 pen Items E-11 and E-16)

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TABLE 2 OPEN ITEM INDEX Open Items C/S DBD Cal Subject 16 CS-81, Definition of pipe reaction 83, 84, loads Ro and Ra is not consisten and 85 FSAR revision may be require CS(C)-073 Effects of two horizontal earthquakes not considered in equipment load calculatio CS(C)-073 Overturning moment due to M-G set calculated but omitted in design of sla CS(C)-121 25 psf attachment load on wall omitte CS(C)-121 Effects of wall load on beam not considere CS(C)-074 Slab strip supporting large shield wall not evaluate CS(C)-074 Horizontal seismic load due to mass of heat exchanger not considered in slab desig CS(C)-074 25 psf wall attachment load not considered in desig CS(C)-074 Effects of wall load on slab not considered in desig CS(C)-129 Calculation not identified as being incomplet CS(C)-129 Incomplete recording of con-firmation requirement CS(C)-127 Calculation not identified as being incomplet CS(C)-127 Unchecked documents used to provide significant loading in-put . o Open Items C/S DBD Cal Subject 29 CS(C)-127 Incomplete recording of con-firmation requirement CS(C)-083 Shear transfer mechanism intro-duces loads in slabs which are not addresse CS(C)-009 Referenced Design Basis Document nonexistent in project document CS(C)-009 Seismic model omits structure below groun CS(C)-128 Calculations not identified as being incomplet CS(B)-028 Confinnation scope does not cover verification of assumptions concerning concrete propertie DBD-CS-081 Equipment / system attachment load on walls not addressed properl CS(B)-178 Auxiliary Building Platfonn critical load combination must be justifie CS(B)-040 Calculation not identified as being incomplet CS(B)-180 Critical load combination needs justificatio ME-215 Confirmation required on ability of buried tank system to remain in place and perform design functio CS-074 CS(B)-025 Unauthorized ASME Code issue used. Punching shear capacity did not incorporate bi-axial tension effect CS-074 CS(B;-040 Unauthorized ASME Code issue used. Punching shear capacity did not incorporate bi-axial tension effect . .

Open Item C/S DBD Cal Subject 42 CS(B)-067 Clarification required on the use of derived moment coeffi-cient CS(B)-029 Inconsistent identification and l use of uniform attachment loa CS(C)-122 Wall attachment load of 25 psf not addressed in the design of bea CS(C)-122 Electrical switchgear load omitted in beam desig CS(C)-130 Radial shear capacity of contain-ment shell requires further justificatio CS(C)-130 Strength of apex reinforcement l anchor ring not demonstrated l nor interface performance es-tablished at liner attachment.

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48 CS(C)-130 Confirmation required that dome l hoop bars will not be split off l during expansion of the dom CS(C)-130 Acceptability of shear tie anchorage needs further detai CS(C)-130 Confirmation of assumptions l used to develop acceptability contingent on FSAR change and/

or ASME code clarificatio CS-081 CS(C)-086 System and component attachment loads not considered in the design criteria for column CS(C)-084 Soil property variations in mat analysic should be considere CS(C)-084 Dynamic soil pressure load on walls not considered in analysis of the mat of Safeguard Buildin _ _

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Open Items C/S DBD Cal Subject 54 CS(C)-084 Seismic shear distribution on floor slab should be addresse CS(C)-086 Record of confirmations does not include load combinations to be checked late CS(B)-171 Approach to computer modeling of hydrodynamic loading requires justification.

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3.0 ADDITIONAL REVIEW The following design related areas were not addressed by the team because they were not yet complete .1 Assumption Confirmation Program The SWEC design validation program develops analysis and design calcula-tions on the basis of assumed information, and a program has been esta-blished to identify the calculation assumptions needing confirmatio (Section 2.0 identifies several o tions that were not identified.) penAsitems concerning yet none required confirma-of this confirmation work has been completed. As a related matter, an interfacing system has not been established by SWEC to ensure the updating of calculations as required by revisions to source calculation .2 Load Verification Program The design of structural elements has been based upon loadings which are yet to be verified. Tracking of the use of these loads is part of the Assumption Confirmation Program. The verification of the load magnitudes and the approach to evaluating their effect on structural elements falls into three categories, which are sumarized as follows:

3.2.1 General Concrete Loading (Slabs, Beams, Columns, and Walls)

This category represents elements designed utilizing a uniform loading which was considered adequate to envelope system support loads. Large equipment and pipe whip restraint loads were added as separate load

, enti ties . A program has been proposed to verify the adequacy of the load enveloping by evaluating the actual loading of 60 statistically identi-fied sample elements with respect to the uniform loads used in the j design. Sample elements must int.lude not less than five significant sys-

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tem loads as well as all significant equipment, pipe whip, and rupture loads in the verification of the acceptability of the originally assigned i "equivalent" uniform loading.

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3.2.2 Structural Steel Framing All (100 percent) structural steel framing will be checked for final, actual loading to verify the structural adequacy of the desig .2.3 Embedments l

A procedure has been scheduled for issue to cover the transfer of all

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attachment loads. These loads will be used to evaluate the structural l

attachments to the concrete elements and their effect on the structural l

element itsel .3 Structural Steel Framing An insufficient number of structural steel framing calculations were available to enable the review of representative steel calculation :-

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Civil / Structural - Evaluation of Documents Reviewed i

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I 1. Document Number:

D8D-CS-081, Revision 0, dated 06/04/87, "General Structural Design Criteria" - Applicable Design Criteria:

FSAR Section 3.8.3, "Concrete and Steel Interr.a' Structures of Steel or Concrete Containments" and Section 3.8.4, "Other Seismic Cate-gory I Structures" describe the various loaos used in the design of structure . Compliance with Design Criteria:

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Design criteria DBD-CS-081 Section 4.8 in part states, "Additional-ly, Seismic Category I concrete walls shall be designed for a load

, of 25 psf normal to the wall to account for the effects of these

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e loads". Also, Section 5.3.3 in part states, "The inertia loads due a s to the acceleration of the structure shall be found by applying to f the structure an equivalent static load equal to the mass of the

', structural elements (including the mass frem an additional 50 psf equipment / system load on the slabs and 25 psf on walls as defined in Section 4.8) multiplied by the appropriate building acceleration at the elevation under consideratio OPEN ITEM C/S - 35 Th'e criteria for equipment /systac r.iachment loads on the walls need further clarification since the

. 4+: not applied uniformly and are apparently misunderstood in many aesign calculations. The following l matrix indicates how the wall attachment loads are used in various calculations by different designers,

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'a - a Calculation Not 25 PSF 25 PSF Seismic Inertia a Set Considered Considered Considered as Load used as:

as Vertical Horizontal Ver Hori Dead Load Dead Load l CS(C)-090 X Pages 9, 10

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CS(C)-057 X Page .

CS(C)-083 X Page 142 s

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CS(B)-022 X Page 27

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1. Document Number:

DBD-CS-083, Revision 0, dated 06/04/87, "Containment Concrete Inter-nals" 0B0-C5-084, Revision 0, dated 06/08/87, "Other Seismic Category I Concrete Structures" DBD-CS-085, Revision 0, dated 06/04/87, "Seismic Category I Struc-tural Steel". Applicable Design Criteria:

FSAR Sections 3.8.3, 3.8.4 and D80-05-081 define various loads to be used in the design of the Containment Internal Structure, Other Seismic Category I Structures and Structural Stee . Compliance with Design Criteria:

OPEN ITEM C/S-16 Each design basis document defines the loads, load combinations and codes and standards to be used in the design. The definition of pipe reaction loads Ro and Ra has been extended to include other system and component reactions. The definition of sipe reaction loads Ro and Ra should be consistent in all design aasis document An FSAR revision may be required to include the extended definition of these loads in the design basis document .

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O 4 1. Document Number: l DBD-ME-215 Rev. O date; .1 June 87, "Design Basis Document Diesel Generator Fuel Oil Storef. and Transfer System".

Gibbs & Hill drawing 2323-5-0306, Revision 2, dated 09/11/8 . Applicable Design Criteria:

General Design Criteria 2 as related to the ability of the system itself to withstand the effects of natural phenomen . Compliance with Design Criteria:

OPEN ITEM C/S-39 The criteria for the Fuel Oil Storage Tank does not list the re-quirement for the in-ground tanks to stay in place during a heavy and soaking rain which would saturate the tank backfill. The con-cern is that, in the absence of adequate drainage or anchored bal-lasting, one or both storage tanks could become buoyant thereby damaging the pipelines and preventing their transfer of fuel oi Corrosion protection or prevention for the tanks, anchor straps, saddles or anchor bolts has not been identified as a design require-ment in the DB Calculations 16345-CS(B)-073 and 16345-CS(B)-176 have been identi-fied as work underway which will substantiate the adequacy of the buried tank system to perform the required design function for the specified design life of the plan These calculat' ions and DBD-ME-215 should address the above concern _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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1. Document Number:

SWEC Calculation 16345-CS(B)-022, Revision 0, "Structural Analysis and Capacity Evaluation of Lower Pressurizer Cubicle" Applicable Design Criteria:

DBD-CS-081, Revision 0, "General Design Criteria" DBD-CS-083, Revision 0, "Containment Concrete Internal Structures" The design criteria establish loads and load combinations for the Containment Internal Concrete Structure. The criteria meet the com-mitments in the FSAR and industry practic . _ Compliance with Design Criteria:

This calculation validates the lower pressurizer cubicle. Loads from the pressurizer slab and upper pressurizer cubicle are trans-ferred to the lower cubicle. Additional loads due to the lower cubicle and pressurizer relief tank are calculated. The walls of the lower cubicle and relief tank support slab at El. 822'-9" are validated in accordance with load combinations in DBD-CS-08 The design complies with the stated design criteria and industry practic . .

1. Document Number:

Calculation number 16345-CS(B)-025. Revition 0, "Penetration Anchorage Analysis - Unit 1" Applicable Design Criteria:

DBD-CS-074, Revision 0 - Contairnent Liner and Penetrations Compliance with Design Criteria:

This calculation evaluates the structural adequacy of mechanical and electrical containment shell penetrations for the loadings de-fined in DBD-CS-074. Penetrations are checked in groups segregated by ASME Section III class, penetration anchorage types and diamete OPEN ITEM C/S - 40 The allowable punching shear stress has been calculated using 1977 ASME Section III, Div. 2, Subsection CC-3421.6 (Page 13). This is-sue of the ASME code has not been authorized by DBD-CS-074 or the current revision of the FSA In addition, the effect of biaxial tension has not been accounted for in calculating the allowable shear stress and therefore the penetration anchorage capacities have been overestimated (Page 46).

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Calculation Number 16345-CS(B)-028, "Reactor Containment Building Liner Analysis Units 1 & 2" Applicable Design Criteria:

DBD-CS-074, Revision 0 - Containment Liner and Penetrations DBD-CS-081, Revision 0 - General Structural Design Criteria The team reviewed these DBDs in the previous inspection and found that they were consistent with the FSAR and industry standards, subject to resolution of identified open item . Compliance with Design Criteria:

This calculation develops the liner stresses and strains for three locations on the liner which are considered to envelop all condi-tions of liner behavior under the loadings given in DBD-CS-07 Stresses and strains were developed in this calculation by analyses which utilized representative shell-liner properties of equivalent thickness for pure membrane loading cases and transformed or gross sectional properties for cases with flexure. Classical equations were used to detemine the stret.ses and strains for each of the conditions evaluated. Seismic stresses and strains were obtained by assuming a deflection and developing stress and strain levels in proportion to values developed for wind. Gross, uncracked concrete properties were used to detemine the shell behavior under wind and seismic loading OPEN ITEM C/S - 34 This liner calculation tion under only)

seismic (page 61requires that the be confimed assumed to validate or shell updatedeflec-the

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derived stresses and strains. As presented, the confirmation will

! be considered valid based on the direct substitution of the single location displacement valu The shell properties and resultant behaviors under the seismic l

loadings were based on gross, uncracked concrete properties which will become cracked to various degrees under the combined load cases

which include accident pressures. The actual behavior of the chell i under the combined seismic and accident pressure cases will be some-l what different than the utilized gross, uncracked concrete sections.

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i The deflection, behavioral and sectional properties assumed and l conclusions derived should be verified by comparing the behavioral l characteristics obtained from the finite element shell analyses I (cracked, uncracked, partial cracked) with, as a minimum, the three l locations used as evaluators in this calculation. The finite ele-l ment analysis results should envelop all relative values in this calculation as a contingent part of confirming of the calculation conclusions.

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1. Document Number:

Calculation 16345-CS(B)-029, Revision 0, "Analysis and Capacity Evaluation of Beams and Slabs for Floor Elevation 832'-6" (Containment Concrete Internal Structures). Applicable Design Criteria:

DBD-CS-081 (Revision 0) and DBD-CS-083 (Revision 0) define design loads, load combinations and codes and standards for designing the containment internal structures. Gibbs & Hill drawings 2323-SI-0522, 0523, 0524 and 0556 are used to define the as-constructed structural system to be validated in this calculatio . Compliance with Design Criteria:

This calculation evaluates the beam and slab framing at El. 832'-6 utilizing a general floor loading (Ro and Ra) of 50 psf. to represent interim equipment, piping, ductwork, cable trays and conduit attach-ment loads pending final load confirmation. Accumulator loading is the only specific equipment loading used in the desig Slabs and beams have been evaluated on a case by case basis using standard flexural equations to derive element forces for comparison with the structural capacity of the as-constructed member OPEN ITEM C/S 43 DBD-CS-081(Section4.8)and-083(Section 4.3.1.11.1) define Ro as a dead load to be represented by 50 psf. However, this has not been consistently implemented in the calculation. Ro is also defined on Page 13 of the calculation in equation 3 with a live load factor of 1.7. Page 19 utilizes the 50 psf as a dead load. In equation 4 Ro is not specifically identified for the 50 psf as in equation _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ _ . _ _ _ _ _ __ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _

. . Document Number:

SWEC Calculation No. 16345-CS(B)-035 Revision 0, dated 9/18/87,

"DLF Effects Associated with Cebicle Pressure Transient Pa" Applicable Design Criteria:

DBD-CS-081, Revision 0, "General Structural Design Criteria" DBD-CS-083, Revision 0, "Containment Concrete Internal Structures" FSAR Section 3.8.3.3.1 defines the requirement for pressure tran-sient loads due to high energy line break The team reviewed these DBDs in the previous inspeciton and found them consistent with the FSAR and industry standards, subject to resolution of open item . Compliance with Design Criteria:

This calculation determines equivalent static pressure in the steam generator and pressurizer compartments due to high energy line breaks. A dynamic analysis using the STRUDL-SW computer program is performed with pressure transient (pressure versus time) data as forcing function. Time history displacement response is obtained from STRUDL-SW output. This output is then used to calculate dynamic load factors for each boundary condition and equivalent static pressure for each compartment is determine The analytical approach used in this calculation is in accordance with the design criteria and the industry practice.

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1. Document Number:

Calculation Number 16345-CS(B)-040, Revision 0, Equipment Hatch, Personnel and Emergency Air Locks Anchorage and Reinforcing Plate Analysi . Applicable Design Criteria:

DBD-CS-074, Revision 0 - Containment Liner and Penetrations DBD-CS-081, Revision 0 - General Structural Design Criteria Compliance with Design Criteria:

This calculation evaluates the anchorage capacity of the large pene-trations and shell strength to resist the punching effect of the hatches unoer pressure load This issue of the calculation considers the hatch loadings as a separate effect, independent of the overall shell behavior or effects of other loadings. The combined effects of bi-axial membrane tension, seismic and thermal loadings are not addressed at this stage of the calculatio This calculation is under revision to include the influences associated with the overall behavior of the shell under the various loads and load combinations established in 080-C5-07 Influences will be detennined by a separate special effects finite element analysis of the hatch area incorporated in the revised issue of this calculation and the shell hatch analysis given in calcula-tion number 16345-CS(C)-13 OPEN ITEM C/S - 37 I The calculation conclusions and Record of Confirmation portray the l contained work as conclusive regarding the "adequacy of the penetra-tions to withstand pressure loads as per DBD-CS-074" and do not identify that the calculation requires additional analysis and design to address all required areas of loading and load combina-tions. Calculations which are partially completed or limited in scope should be adequately identified to establish the value of their use and conclusion OPEN ITEM C/S - 41 ,

The allowable punching shear stress has been calculated using 1977 ASME Section III, Div. 2, Subsection CC-3421.6 (Page 25). This is-sue of the ASME Code has not been authorized by DBD-CS-074 or the current revision of the FSA In addition, the effect of bi-axial tension has not been accounted for in calculating the allowable shear stress and therefore the pen-etration anchorage capacity has been overestimated (Page 10).

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1. Document Number:

SWECCalculation16345-CS(B)-042, Revision 0, dated 09/28/87,

"Structural Analysis and Capacity Evaluation of Pressurizer Slab at El. 853'-6". Applicable Design Criteria:

DBD-CS-081, Revision 0, "General Structural Design Criteria" DBD-CS-083, Revision 0, "Containment Concrete Internals".

Design basis document DBD-CS-081 identifies the types of loads to be considered in the design validation of the structures and 080-CS-083 provides load combinations to be used for the structural desig The load combinations are consistent with FSAR commitments'and industry practic . Compliance with Design Criteria:

This calculation validates the pressurizer support slab at E '-6" in the Containment Building. The slab is designed as a plate restrained on all four sides. The dead load, live load, seismic inertia load and pressure load due to high energy line break are assumed as uniformly distrib-uted loads and the pressurizer equip-ment load is considered as a concentrated load distributed along the perimeter of the ring base. The loads are distributed to the slab in both directions in accordance with their relative stiffnesse The pressure load due to a surge line break acting on the bottom of the slab was eliminated at the time of calculation and will be "con-firmed" at a later date as noted in the calculation "Record of Confirmation" page The bending moments, shear forces and tension in the slab are calcu-lated manually and the slab is validated based on the reinforcing shown in Gibbs & Hill Drawings identified in the calculatio Subject to "confirmation items" and load verification, the design meets the criteria and industry practice.

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O l 1. Document Number:

SWEC Calculation No. 16345-CS(B)-043 Revision 0, dated 7/01/87,

"Generic Moment-Tension and Shear-Tension Capacity Interaction Diagrams" (Containment Concrete Internal Structures)

2. Applicable Design Criteria:

DBD-CS-081, Revision 0, "General Structural Design Criteria" DBD-CS-083, Revision 0, "Containment Concrete Internal Structures" ACI-318-71, "Building Code Requirements for Reinforced Concrete"

3. Compliance with Design Concrete

This calculation provides interaction diagrams for a series of rein-forced concrete' sections for use in the design validation of Con-tainment Concrete Internal Structures. Interaction curves for moment-tension, shear force-shear stress, shear-tension and shear-compression are prepared in accordance with ACI-318-71 Code and ACI DesignHandbookPublicationSP-17(1973).

A random check of numerical values for selected concrete sections using ACI-318-71 code against the interaction diagrams in this cal-culation resulted in no deviation from design criteria and industry practice.

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1. Document Number:

16345-CS(B)-067, Revision 0, "Moment Distribution for Beams and Columns in Floors 9 El 832'-6, 860'-0, and 905'-9" (Containment Concrete Internal Structures) Applicable Design Criteria:

DBD-CS-083, Revision 0, identifies design loads, load combinations and codes and standards for designing the containment concrete in-ternal structur . Compliance with Design Criteria:

This calculation develops coefficients for distributing uniform load and moments to adjacent members based on the ACI-318 equivalent frame method of developing relative stiffnes Frames canprised of a typical beam, slab and column system were used to develop the distribution of moments to the simplified fram These moment distribution coefficients are used in other calcula-tions which check discrete structural elements for specific loading OPEN ITEM C/S - 42 The fixed end moment (FEM) moment distribution coefficients were developed for full span uniform loads only. The description of use on Page 4 and 29 indicate that the coefficients are good for any load on the span and should be clarified to state that FEM is based on a full uniform load onl Clarification is needed on page 29 to explain what is meant by the term "for simple beam" for calculating the FE If the coefficients marked with (*) are for information only, it is not clear what moments are to be used to check the member on the non-column side.

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1. Document Number:

SWEC Calculation 16345/6-CS(B)-124 Revision 0, dated 3/26/87,"ARS Peak "g" Values for Structural Steel Validation (All Buildings)" Appitcable Design Criteria:

FSAR Section 3.7B, "Seismic Design" provides the basis for generat-ing Amplified Response Spectra (ARS) for all Seismic Category I Building . Compliance with Design Criteria:

This calculation extracts peak ARS values from seismic documents for use in validation of Seismic Category I structural steel for all buildings. No deviations were observed in the team's sample review of seismic accelerations in this calculation which are based on Gibbs & Hill Design Basis ARS documents, except for the Service Water Intake Structure and Category 1 tanks which are based on SWEC Design Basis ARS documents.

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. . Document Number:

CalculationNo.16345-CS(B)-171, Revision 0,datedJuly 30, 1987, Condensate Storage Tank and Refueling Water Storage Tank Applicable Design Criteria:

DBD-CS-081, Revision 0, General Structural Design Criteria DBD-CS-084, Revision 0, Other Seismic Category I Concrete Structures Compliance with Design Criteria:

This calculation examines the structural adequacy of two safety-related concrete water storage tanks. The design validation approach in this calculation is the same as for Calculation No. 16345-CS(B)-172, Rev. O and is described and discussed in the previous Civil / Structural review contained in NRC Inspection Report 50-445/87-19,50-446/87-15 dated October 15, 1987. The use of "coupled" loadings as initiated on pages 32 and 33 does not properly represent the fluid action on the walls under seismic loading. Reference Open Item C/S- OPEN ITEM C/S-56 Confinnation is required that the "coupled" loadings used actually provide enveloping element forces throughout the tank structur Confirmation should include an evaluation based on "true" dynamic loading behavioral input to the computer analysis. The effect of vertical seismic force on the lateral pressure should be addressed.

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1. Document Number:

SWEC Calculation 16345/6-CS(B)-178. Revision 0, dated 09/30/87,

"Auxiliary Building Platform at El. 821'-6"." Applicable Design Criteria:

DBD-CS-081, Revision 0, dated 06/04/87, "General Structural Design Criteria" DBD-CS-085, Revision 0, dated 06/04/87, "Seismic Category I Struc-tural Steel" These documents set up the criteria for the design validation of structural steel in Seismic Category I structures. They were reviewed during the previous inspection and found to be consistent with the FSAR and industry standards, subject to resolution of open item . Compliance with Design Criteria:

This calculation validates the structural steel platform at El. 821'-6" in the Auxiliary Building. The platform supports con-duit and pipes as identified in Attachments 1, 2 and 3 of this calculation. Original Gibbs & Hill pipe support and conduit support loads are used pending "confirmation". Structural steel members are qualified for the load cembinations shown on page 7 of the calculatio OPEN ITEM C/S - 36 Load Combination No. 7 with the safe shutdown earthquake is considered

"not critical" on page 11 based on the comparison that 0.5 SSE > 1.0 SS U This comparison should be based on 0.5 SSE)1.5 SSE where 1.5 is the U

strength factor for load case with 0.5 SSE or Operating Basis Earthquake (References DBD-CS-085. Load Combination, Sec-tion 4.3.1.1).

Further investigation is needed to prove that Load Combination No. 7 is not the most critical combination for structural steel design.

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1. Document Number:

SWECCalculation16345-CS(B)-180, Revision 0, dated 10/20/87, Reactor Coolant Pump Access Platform at El. 833'-3".

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2. Applicable Desian Criteria: l r

DBD-CS-081, Revision 0, dated 06/04/87, "General Structural Design Criteria" DBD-CS-085, Revision 0, dated 06/04/87. "Seismic Category I - Struc-tural Steel". . Compliance with Design Criteria:

This calculation validates the design of an access platform to the Reactor Coolant Pump at E1. 833'-3" inside the Reactor Containment

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Building.

. OPEN ITEM C/S - 38 Load combination no. 10 of DBD-CS-085, Section 4.3.1.1 is the only

combination investigated in this calculatio There was no docu-mented evidence that other load combinations were addressed in determining the critical load combinatio t

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O t Document Number:

SWEC Calculation 16345-CS(C)-121 Revision 0, Beams at El. 831'-6" (Safeguards Building) Applicable Design Criteria:

080-C5-081, Revision 0, General Structural Design Criteria DBD-CS-084, Revision 0, Other Category I Concrete Structures ACI-318-71, Building Code Requirements for Reinforced Concrete Compliance with Desion Criteria:

This calculation validates concrete floor beams at El. 831'-6 in the Safeguards Building. The beams are grouped according to their size and reinforcing and the critical beam within each group is avaluate The review of beam B-15 on page 22 revealed the following omission OPEN ITEM C/S-19 Beam B-15 supports a wall 24 in, to 36 in. thick and 20-ft high. In calculating the loads on the wall, the designer did not include the 25 psf attachment loads as required by Section 4.8 of DBD-CS-08 The omission of attachment loads further reduced their seismic iner-tia load as required by Section 5.3.3 of DBD-CS-08 OPEN ITEM C/S-20 The calculation for negative moment Mu on page 22 showed that the additional external moment on the beam caused by the wall due to seismic acceleration perpendicular to the wall was also omitte Additionally, seismic inertia load parallel to the wall was not addresse DBD-CS-08, Section 5.3.3, last paragraph states, "Reac-tions from these inertia loads shall be considered in the design of the supporting structural elements."

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A sample review of other beam designs (e.g., beams B-12, B-13, B-14, B-16, B-17, etc) indicates that omissions similar to Open Items C/S-19 and C/S-20 exist throughout the calculation.

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! Document Number:

Calculation Number 16345-CS(C)-130, Rev. O Reactor Building -

Containment Shell Design Applicable Design Criteria:

0B0-C5-081, Revision 0 - General Structural Design Criteria DBD-CS-073, Revision 0 - Concrete Containment Structure ASME Section III, Division II, Proposed Standard Code for Concrete Reactor Vessels and Containment (April 1973) Compliance with Design Criteria:

Reference Documents:

Calculation 16345-CS(C)-129, Reactor Building - Unit 1 Containment Analysis, Revision 0 Gibbs & Hill Specification No. 2323-5S-10 Reinforcing Steel Drawings 2323-51-0503, Rev. 3 Containment Mat Sections & Details - Sh 2 0504, Rev. 2 Equipment Hatch Cover Details 0505, Rev. 13 Containment Wall Outline & Rein , Rev. 5 Containment Wall Outline & Rein , Rev. 3 R.B. Concrete Dome Outline & Rein This calculation covers the structural design adecuacy of the con-tainment shell pressure boundary except for the founaation mat (Cal-culation 16345-CS(C)-128) and the large openings (Calculation

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16345-CS(C)-131). Loads used in the design validation are taken l from Calculation 16345-CS(C)-12 Reinforcement and anchorage details are taken from the above Gibbs & Hill drawings.

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I OpEN ITEM C/S - 46 Horizontal shear ties (radial in the dome) have been used to develop radial shear capacity in the containment shell. ASME CC-3521. equation (11) has been used to determine reinforcement requirements (pages 137 to 143).

Since the majority of the shell experiences horizontal and vertical i membrane cracking (radial in the dome), horizontal (or radial)

shear ties will be essentially in the plane of cracking and there-fore will not offer any shear resistance by bridging of the crack Radial shear capacity of the containment shell has not been estab-lished for cases involving membrane tension crack OPEN ITEM C/S - 47 Gibbs & Hill drawings SI-0507 and SI-0514 show details for terminat-ing the meridional reinforcing at the apex of the dome. This design concept utilizes a vertical ring plate to which B" series CADWELD splice sleeves are welded to terminate the meridional bars in hoop tension. The vertical thickened (1 in thick) plate (1 1/2 section of the in, line thick) is A welded to aplate 1-in, thick is welded across the top of the ring and 1-in. thick plate, forming

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a cruciform, is welded across the center. General notes (f3, Dwg. SI-0503) indicate that all welding is to be full penetratio No details are given to describe what is acceptable full penetration welding of this closed section. This apex anchor weldment is also part of the anchorage system for the rotating platfo No calculations have been identified as being scheduled to verify the strength of this critical weldment nor has the confirmation record been used to identify this as an open item requiring further work to make the calculation complete. Page 145 does not identify the apex anchorage as requiring confirmatio Calculations to determine the adequacy of this apex reinforcement anchcrage assembly should take into account the attachment inter-face and stiffness of the liner plate with respect to imparting stresses and strains within the ASME Code allowances, i Calculations also are not identified (and are required) for the weldment anchorage shown on drawing SI-0503, Detail-14A which transfers load for a significant number (84) of fld meridional bar OPEN ITEM C/S - 48 The dome hoop bars are assembled as the outside layer of reinforce-ment. As the hoops progress up the meridional bars from the spring line, they develop a force component away from the shell surfac This component must be resisted to prevent the hoop bars from spalling(popping)offthetop. Membrane cracking of the outer con-crete surface must be considered in developing the hoop anchorag The ability of the dome hoop bars to remain in place under the pres-sure cases should be establishe OPEN ITEM C/S - 49 i

Pages 145, 146, and 148 calculate the development lengths required l for bars age not tenninating(with A factor hooks, of 1.25 +25%) has beenbends, or mechanical identified as an ASMEanchor-code requirement where biaxial tension exists in the temination zone.

l In calculating the acceptability of meridional and diagonal bar an-chorages in the foundation mat (page 146), the biaxial requirement has not been included, and the full development of a bar cannot be justified based on the actual length embedded. Specific values should be given to demonstrate the anchorage capacity based on the maximum bar stress. The termination of the added meridional bars and transfer of axial load at the base of the cylinder also should be addressed in relating the value of maximum, actual bar stresse The development of the shear items on page 148 does not include the biaxial stress factor for development length, nor are the No. 6 and No. 7 diagonal shear bars checked. A more detailed presentation should be given as to the determinntion of development ac-ceptability. The reference to "#6 ties being bent around the main rebars by means of hooks or bends" does not fit the code requirement

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of 180' bends (f6 bars have 90' bends) as a means of anchorag Even if the fabrication drawings state that the bars are to be bent around the main reinforcing, this does not ensure that bars (even 90' bars) were placed to hook behind the main bar OPEN ITEM C/S - 50 The confirmation required on page 117 entails a revision to FSAR Section 3.7.1.4.5 and/or ASME code clarification.

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1. Document Number:

Calculationnumber16345-CS(C)-131,AnalysisandDesignChecktfthe Equipment Hatch Area of the Containment Building - Unit . Applicable Design Criteria:

DBD-CS-073, Revision 0 - Concrete Containment Structure DBD-CS-081, Revision 0 - General Structural Design Criteria Compliance with Design Criteria:

This calculation develops forces around the equipment hatch as a result of the discontinuities in the shell structure due to the large opening. A section of the containment shell was modeled to represent the hatch and the thickened boss with multi-layer finite elements through the thickness. Boundary stiffness conditions were utilized to represent the remainder of the shell. Developed forces were used to check the structural adequacy based on the reinforce-ment and concrete thickness shown on the Gibbs & Hill drawin The calculation is identified as preliminary in the introduction and conclusions, pending the confirmation of loading. No deviations from the applicable design criteria were observed.

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1. Document Number:

SWEC Calculation Number 16345/6-CS(C)-002,Rev.O,datedAugust7, 1987, Calculation of Base Shears for Seismic Category I Structures

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2. Applicable Design Criteria:

FSAR Section . Compliance with Design Criteria:

Seismic base shears and moments of all Category I structures are compiled in this calculation set. The displacements in soil springs are multiplied by stiffnesses of soil to obtain forces and moments at the base of structures. The calculation also lists the weight of all structure The moments and shear calculated for the Safeguards Building by this method were compared by the team with the moments and shear obtained from the seismic analysis of the building. No deviations were observed.

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. , Document Number:

SWEC calculation 16345-CS(C)-009. Revision 0, dated July 21, 1987,

"Development of Dynamic Model and Seismic Profile for the Safeguard Building". Applicable Design Criteria:

FSAR Section DBD-CS-081, Revision 0, dated 06/04/87, "General Structural Design Criteria".

OPEN ITEM C/S - 31 DBD-CS-092. "Seismic Design Parameters," which was referenced in Section 5.0 of DBD-CS-081, was not available, and the team was verbally advised that it would not be prepared. SWEC should pro-vide an alternate means for documenting seismic design parameter . Compliance with Design Criteria:

The lumped mass seismic model is constructed for the seismic analy-sis of the structure in accordance with the procedure in the FSAR Section 3.7.2 and the seismic analysis method described on pages 7 and 8 of this calculation set. Masses are calculated at each floor elevation where node points are considered. Mass of major equipment is considered in the analysis. Nodes are joined by beam element Stiffness of beams are calculated separately in the computer program

' RIG 4'. The center of rigidity for horizontal and vertical models is accounted for in this calculation of the beam stiffness matrix in RIG 4. Soil springs are used to represent soil. Damping values for SSE and OBE are in accordance with R.G. 1.61. The structure is sup-ported by the mat which is founded on rock at eicht different eleva-tions. The lowest elevation of the mat is 767.33 feet. The structure below El. 790.5' is not considered in the seismic model. Modal damping values are considered in the analysi OPEN ITEM C/S - 32 The seismic model does not consider structure below El. 790.5'. The stiffness properties of the beam between node points 3 and 4 are not adjusted to account for omission of lower structure.

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, . Document Nurnts:

SWEC Calculation 16345-CS(C)-073, Revision 0, Floor Slab at El. 831'-6" (Safeguards Building) Applicable Design Criteria:

DBD-CS-081, Revision 0, General Structural Design Criteria

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DB0-0S-084, Revision 0, Other Category I Concrete Structures ACI-318-71, Building Code Requirements for Reinforced Concrete The DBDs define the loads and load combinations to be used in the design of "Other Category I Concrete Structures" and ACI-318-71 identifies the code requirements for the design of reinforced con-

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crete structure . Compliance with Design Criteria:

This calculation validates the design of the concrete slab at El. 831'-6. The design load combination is used in accordance with the design basis document to verify that the minimum concrete thick ~

ness and reinforcing requirements are met in accordance with the ACI-318-71 code. The concrete slab "A" between column lines 2-4 and A-H is 12 in, and the critical area is considered between beams B-7 and B-8. The slab supports two motor-generator sets, each weighing 7,580 lb. The seismic accelerations for the equipment and attached mass are assumed in the design pending confirmatio OPEN ITEM C/S-17 In determining the effects of the horizontal earthquake on the

equipment on page 12 only one horizontal direction is considered i

in calculating the overturning moment at the base of the equipmen No justification could be found for omitting the effects of the second horizontal earthquake.

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OPEN ITEM C/S-18 l The overturning roment of 50,200 ft/lb was calculated at the base of the M-G set for a single horizontal earthquake on page 11, but was subsequently omitted in actual design of slab A on pages 14 and 15. No justification could be found for omission of this load.

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. . Document Number:

SWEC Calculation 16345-CS(C)-074, Revision 0, Floor Slab 9 El.810'-6"(SafeguardsBuilding) Applicable Design Criteria,:

DBD-CS-081 Revision 0, General Structural Design Criteria DBD-CS-084, Revision 0, Other Category I Concrete Structures ACI-318-71, Building Code Requirements for Reinforced Concrete Compliance with Design Criteria:

This calculation validates the concrete flaor slab at El. 810'-6" in the Safeguards Building. The entire floor slab is divided into several areas. Critical slab within each area is evaluated for structural adequacy. The slab between column lines 45 to 55 and CS to DS' supports the letdown heat exchanger foundation and a 24-in.-thick concrete shield wal OPEN ITEM C/S-21 The slab strip supporting the portion of the shield wall spanning in the eastwest direction has not been evaluate OPEN ITEM C/S-22 The vertical seismic load due to the mass of the letdown heat ex-changer is considered in the design but horizontal seismic forces are neglecte OPEN ITEM C/S-23 Wall attachment loads of 25 psf (Section 4.8 DBD-CS-081) and their seismic inertia load (Section 5.3.3, DBD-CS-081) are not included in the design. This item is similar to Open Item C/S-19 for the beam design OPEN ITEM C/S-24 The slab moment calculation does not include additional external

moment caused by wall horizontal seismic inertia loads. A similar item was identified for beam design as Open Item C/S-20.

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1. Document Number:

SWECCalculation16345-CS(C)-083, Revision 0,datedSeptember17, 1987, "Safeguard Buildings - Unit 1 - Wall Design - East-West". Applicable Design Criteria:

DBD-CS-081, Revision 0, dated 06/04/87, "Design Basis Document -

General Structural Design Criteria" DBD-CS-084, Revision 0, dated 06/08/87, "Design Basis Document -

Other Category I Concrete Structures" Compliance with Design Criteria:

Calculations of walls were reviewed by the team to determine whether all loads were considered in the design of walls. The wall '1S'

was reviewed in detail because of the number of openings in the wal Dead load, live load, wind load, temperature load, and in-plane and

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out-of-plane seismic shear and moment are considered in the desig Seismic load distribution oa walls was obtained from SWEC Calculation i 16345-CS(C)-081, Revision 0. Dead, live and vertical seismic loads were obtained from SWEC Calculation 16345-CS(C)-079, Revision Design of walls was based on ACI 318-71. Seismic load used directly from the seismic load distribution on walls exceeded the capacity of the wall 'IS' at the openings in the wall. The alternate detail method was used to reduce conservatism in distribution of shear and torsional moment obtained from the seismic analysis of the buildin The shear distribution in the wall 'IS' was obtained using the con-tribution of shear and torsional moment in each mode and then com-bining these modal values in accordance with Regulatory Guide 1.9 No deviations were observed with the following exception:

OPEN ITEM C/S - 30 The mechanism (and resultant forces in slabs) to transfer seismic loads to walls are not addressed in this calculation 16345-CS(C)-083, Revision 0 or in calculations of slabs (16345-CS(C)-070, Revision 0 thru 16345-CS(C)-076. Revision 0).

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. . Document Number:

SWEC Calculation Number 16345-CS(C)-084, Rev. O, dated August 21, 1987, "Safeguards Building Foundation Mat Analysis." Applicable Design Criteria:

0B0-C5-084, Rev. O, "Other Seismic Category I Concrete Structures" D80-CS-081, Rev. O, "General Structural Design Criteria" ACI-318-71, "Building Code Requirements for Reinforced Concrete" Compliance with Design Criteria:

Mat analysis is performed using ANSYS computar program with rectan-gular and triangular elements. Soil is represented by soil springs based on soil properties. The model includes walls twenty-feet in height which stiffens the mat. Loads and load comt'inations of the design criteria are analyzed to obtain governing load combinations for the design. Loads which are assumed in the analysis are listed on page 7 and require confirmation. These loads are hydrostatic load, operating temperature, accident loads and equipnent reaction The water table is below El, 775'-0 thereby having no effect on the ma Both SSE and OBE seismic loads are considered in the analysi Design of the mat is based on ACI 318-71. The moment and direct loads in the mat are compared with the section apacity of the concret SWEC found that the mat is underdesign&d at the north-east

corner and is in the process of evaluating this portion of the ma OPEN ITEM C/S - 52 Soil properties used in calculating soil spring values have uncer-tainties and may vary. SWEC is performing analysis of the mat of the Safeguards Building with varying soil properties. The results of the analysis should be used to reconcile the effect of soil vari-ation on the mat desig OPEN ITEM C/S - 53 Maximum soil pressure is not calculated. SWEC is in the process of calculating soil pressure under different leading condition Dynamic soil pressure on walls of the Safeguards Building is not considered in the mat analysis. Justification is required for neglecting the dynamic soil pressure on walls.

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l The seismic force distribution on walls and columns is based on the j gross moment of inertia of all wall and column elements about the

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center of gravity of wall and column areas. This will introduce l shear and moments in floor slabs connecting all elements. This shear distribution on walls and columns has not been addresse (This item is similar to Open Item C/S-30.)

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. . Document Number:

SWEC Calculation Number 16345-CS(C)-086, Rev. O, dated 7/21/87,

"Column Design - Safeguards Building" Applicable Design Criteria:

DBD-CS-081. Revision 0, dated 6/04/87, General Structural Detign Criteria DBD-CS-084, Revision 0, dated 6/04/87, Other Seismic Category I Concrete Structures FSAR Sections 3.8.3.3 and 3.8. These DBDs establish the design requirements and codes and standards for reinforced concret OPEN ITEM C/S-51

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Unlike walls and floors, system and component attachment loads are

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not considered in the design validation of columns in DBD-CS-08 The load verification program will cover only a limited number of columns picked at random for verification. Due to the many dif-ferent columns sizes and reinforcing, many column types may remain unverified for significant attachment loads and/or pipe whip and

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rupture loads. The design criteria and lead verification program should provide assurance that each type of column is verified for its design adequacy for all load combinations such that the commit-ments made in FSAR Sections 3.8.3.3 and 3.8.4.3 are systematically me . Compliance with Design Criteria This calculation validates the reinforced concrete columns in the Safeguards Building. The columns are reinforced as a structural frame using the STRUDL computer program. Moments and forces in the column are tabluated and columns are qualified using an in-hcuse SWEC column design computer program, ST-215 dated March 198 No deviation other than the one noted below was observe OpEN ITEM C/S-55, Page No. 4f of the calculation states that load combinations 11, 12, and 13 will be checked later. The record of required confirmations on page 5 does not idenfity the work to be performed later upon the receipt of remaining loads.

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, . Document Number:

Calculation Number 16345-CS(C)-122, Rev. O, dated 5/1/87, "Beam Analysis - Floor El. 810'-6" (Safeguards Building) Applicable Design Criteria:

DBD-CS-081, Revision 0 - General Structural Design Criteria DBD-CS-084, Revision 0 - Other Category I Concrete Structures These documents identify the loads, load combinations, codes and standards to be used in the design of reinforced concrete structure . Compliance with Design Criteria:

This calculation validates the concrete beams in the floor at El. 810'-6" in the Safeguards Building. All ivcd cases, noted in DBD-CS-084, Section 4.1.3, other than those involving accidental pressure and temperature are considered in the design. Load cases involving accidental pressure and temperature will be evaluated upon receipt of high energy line break analyses. The design generally meets the criteria and industry practice except as follows:

OPEN ITEM C/S - 44 The wall attachment load of 25 psf is not addressed in the design of I beam B-29. This item is similar to Open Items C/S-19 and 23.

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l The equipment load due to electrical switchgears is omitted in the de-i sign of beams B-6 through B-13.

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l l Calculation Number 16345-CS(C)-127, Reactor Building - Mat Analysis -

l Unit 1 Applicable Design Criteria:

DBD-CS-073, Revision 0 - Concrete Containment Structure Compliance with Design Criteria:

This calculation analyzes the containment foundation for loadings and load combinations defined in DBD-CS-073. The bearing relation-ship between the mat and the ground has been modeled with soil (rock) springs. The mat has been modeled to include significant elements that reflect the overall behavior of the foundation mat, i.e. , the reactor cavity pit, the containment shell and a transi-tional haunch existing part way around the under side of the ma The analysis utilizes a finite element representation of the mat and the other interfacing elements. The thickness of all elements is represented by a single, through-the-thickness elemen Dead and live loads from the containment shell and internal struc-tures are input.at discrete locations representative cf the actual behavior of the intergrated structure. Two load combinations were selected to envelope the load combinations identified in DBD-CS-07 Forces determined from this analysis are used in Calculation 16345-CS(C)-128 to evaluate the design adequacy of the foundation ma OPEN ITEM C/S - 27 Pages 45 and 45a classify this calculation as "Preliminary". The Objective of Calculatien, Conclusions or Records of Confirmatien sections of this calculation do not qualify the limit or use of this calculation or identify that additional work is required to make it complete for final application in other calculatior.s. There is no evidence of a system to indicate the use of this type of calculation and its relationship to other calculation OPEN ITEM C/S - 28 Attachments 4 and 5 are the development of the significant contain-ment internal loads used as input into the mat analysis (Page 93).

Neither of these documents are identified as having been checke The validity of these documents should be establishe OPEN ITEM C/S - 29 Crane loads requiring confirmation (Page 48) have not been logged into the record of items requiring confirmatio .  !

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Calculation Number 16345-CS(C)-120, Revision 0, Reactor Building -

Unit 1 - Mat Design Applicable Design Criteria:

DBD-CS-073, Revision 0, Concrete Containment Structure Compliance with Design Criteria:

This calculation utilizes the forces developed in calculation 16345-CS(C)-127 and the reinforcement given on the Gibbs & Hill drawings to evalaute the design adequacy of the foundation ma OPEN ITEM C/S - 33 Page 286 indicates that this calculation is not final. The incom-pleteness of this calculation is not recorded in the Purpose, Method, Assumptions, Applicability, Conclusion or Record of Con-firmation sections of this calculation. Shear key design confirma-tion on page 286 is not listed in the record of required con-firmations list. The status of calculations should be identified

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with respect to completeness and what is required to make the con-clusions final.

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1. Document Number:

Calculation Number 16345-CS(C)-129, Revision 0, Reactor Building -

Unit 1 - Containment Analysis Applicable Design Criteria:

DBD-CS-073, Revision 0 - Concrete Containment Structure DBD-CS-081, Revision 0 - General Structural Design Criteria 3. _ Compliance with Design Criteria:

This calculation analyzes the containment shell for loadings and loading combinations defined in DBD-CS-073. The interface boundar with the foundation mat have been assumed as a fixed (no rotation)y condition and is yet to be evaluated in relationship to the mat stiffness. The foundation mat analysis (calculation 16345-CS(C)-127)

has included representative shell stiffnesses into its analytical model. The forces determined from this analysis are used in Calcu-lation 16345-CS(C)-130 to evaluate the design adequacy of the con-tainment shel The analysis utilizes a finite element representation of the shell with discrete layers through the thickness. Significant live and dead loads are modeled into the analysis representative of the application to the shell structur Selected load combinations, which envelop all conditions, were used in resolving the force OPEN ITEM C/S - 25 Pages J2 and 42 indicates that this calculation is not complete in scope (i.e. other than load verification) and states that a further phase of analysis is to take place. This requirement is not indi-cated: in the Objective of Calculation, Conclusions, or Records of i l Confimations sections of this calculation. There was no evidence I of a system to identify phased type calculations to insure that i

follow-up rework or replacement calculations are carried through and that other dependent calculations are modified as appropriate.

OPEN ITEM C/S(C)-026 Loads requiring confirmation listed on sample pages 10, 42 and 80 i have not been listed in the Record of Confinnations sheet (Page 5).

! The calculation should be checked for completeness and accuracy of

! confirmation requirement '

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O O Resolution of HVAC Open Items (NRC Inspection Report 50-445/87-19,50-446/87-15)

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The following open items were identified in NRC Inspection Report 50-445/87-19, 50-446/87-15, dated October 15, 1987. The open item is restated. The project action (i.e.,Ebasco)isindicatedintwoparts. The "response" addresses the specific concern identifie "Significance / extent" addresses the potential safety significance and existence of the concern in systems other than the four safety-related systems which were reviewed by the NRC. The project action writeups as well as referenced attachments were provided to the NRC team during the follow-up inspection. The project action writeups are reproduced in this report. The attachments were not made part of the report, but have been retained in the project files. The NRC reviewed the responses and supporting attachments and, in each case, reached a conclusion that the response to the specific concern and addressing of its significance / extent were satisfactory. The bases for con-clusions in this regard are reflected in the "NRC Evaluation" sectio TV Electric is requested to confirm the project actions in the written response to this inspection report.

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. . NRC Open Item No. M-1:

The criterion in DC-302A Section 3.1, page 1, is to maintain space temperatures between 40*F and 122*F and during all modes of plant opera-tion. The DBD-ME-302A Section 2.2.c, Page 10 criterion is to prevent freezing in winter months. Section 4.2, Page 13 indicates the heaters heaters operate only during normal plant operating condition . Project Action:

Response: All Design Criteria Documents have been superseded by the Design Basis Documents. Thus, DC-302A has been superseded by DBD-ME-302 Section 2.2.c, page 10 of DBD-ME-302A will be revised to state that temperatures of 40*FDB minimum are to be maintained in all Diesel-Generator areas during normal operation, to agree with wording in paragraph 4.3, page 13. During emergency operation, temperatures above freezing are maintained only in the Diesel Generator Room The indication in Section 4.2, page 13 of the DBD-ME-302A that heaters operate only during normal operation is consistent with the proposed revision. Temperatures above freezing are maintained in the Diesel-Generator Rooms during emergency operation by turning off three of the four ventilating fans during the winter months. Low temperatures in the Day Tank Room during diesel-generator operation are acceptable as temperature of fuel in the tank will stabilize at 55-85'F during this moce, irrespective of the room temperature (see Attachment 2).

Attachment 1 contains pages of DBD-ME-302A with the proposed changes marked as stated above. The proposed changes will be incorporated in the next revisio List of Attachments: Pages of DBD-ME-302A, Rev. O, marked with the proposed change . SWEC comments on Open Item Fa. ? of DBD-ME-302A, Rev. Signif;cance/Exte.7 Generally diesel engines can opirate sr.61sfactorily at low ambient temperatures. Therefore, low anbient temperature is not considered to be a safety concern. However, to ]revent low temperatures, Section 5.2.1.1 of the DBD pemitted the Operator to shut down some of the fans, as required, in wir.ter. To provide additional assurance, specific operating prc = cures discussed above will be included in the DB . .

Extent is limited to the Diesel Generator Area Ventilation System since the only other system with 100% unheated outside air is the Service Water Ventilation system which will always stay above freezing (see Response to Open Item M-11).

3. NRC Evaluation:

The project action adequately addresses the NRC concerns by (1) eliminating the conflict in criteria documents and (2) demonstrating that temperatures above freezing can be maintained without the use t ' eaters in diesel

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generator areas during emergency operatio a . NRCOpenItemNo.Mg:

There is a potential functional capability problem when outdoor tempera-ture is 20*F and the diesel is started. Since all associated fans (4)

start automatically with the diesel, there probably would be a transient temperature condition within the area considerably below freezin . Project Action:

Resolution:

The temperature in the Diesel Generator Rooms during the initial period after the start of diesel-generators in winter may potentially be below freezing; however, freezing will not occur as the engine jacket water is heated by the engine and is kept continuously in circulation by pumps provided for this purpose. Similarly, Service Water is circulating in pipes, and is heated by engine jacket water. Furthermore, the duration of low room temperatures will be short as operating procedures will ensure that only one ventilating fan will be operating during winte This will result in room temperature well above freezing. For details, please see the response to NRC comment M- The temperature in the Day Tank Room may remain below freezing for an extended period. This, however, is not a concern as the fuel in the Day Tank will stay at 55-85 F irrespective of the room temperatur For details, please see the vesponse to NRC comment M- Significance / Extent:

, As discussed above, and in Open Item M-1, this is not considered to be

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a safety concern. Extent is limited to the Diesel Generator Area

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Ventilation System as discussed in M-1.

l NRC Evaluation The project action adequately addresses the NRC concern since it demon-l strates that the diesel generators will function adequately notwith-standing freezing temperatures (for short periods) in the diesel genera-tor rooms.

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, . NRC Open Item No. M-3:

Pressure Differential Indication Switches are provided to alarm low air flow. Setpoints given are for pressures lower than the pressure associated with normal flow. These alarm switches would not alarm low air flow conditions due to a closed or partially closed damper before the fan or due to a closed or partially closed damper after the fan. This applies to DBDs-ME-304, 312, and 313 as wel . Project Action:

Resolution:

For the Diesel Generator Area Ventilation System, this concern is being resolved by relocating one pressure tap for the differential pressure switch to downstream of the gravity dampers (see Attachment 1, Ebasco to SWEC letter EB-T-3603, dated October 14,1987). Thus, if the gravity damper fails to open, the differential pressure switch will sense a pressure difference well below the normal, and the alarm will be acti-vated. DBD-ME-302A will be revised to include these changes as shown in Attchment Ebasco had initiated a review, prior to the NRC inspection, of all HVAC fans which are provided with gravity dampers, and have differential pressure switches across the fan Control system modifications have been developed to resolve this concern as described in Attachment Attachment 1 includes the fans of DBD-ME-304 and -31 DBD-ME-312 is for the Service Water Intake Structure Ventilation System. The fans of this system have not been provided with pressure differential switche Hence, this Open Item is not applicable to the fans of SWIS Ventiala-tion System The D80s (304 and 313) will be revised as shown in Attachments 3 and 4, respectivel List of Attachments: Ebasco to SWEC letter EB-T-3603 dated October 14, 1987 Pages of DBD-ME-302A, Rev. O, marked with the changes stated abov . Pages of DBD-ME-304, Rev. O marked with the changes stated abov . Pages of DBD-ME-313. Rev. O marked with the changes stated abov Significance / Extent:

There is no safety significance of this Open Item for the following reasons:

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During normal operation, once the gravity dampers are open due to the operating fan pressure, they can be expected to remain open. Inadvertent closure of an operating fan's gravity damper is not a credible even Also, partial opening of an operating fan's gravity damper can be ex-pected to be detected during routine inspection, and indirectly by sur-veillance for compliance with the Technical Specifications regarding area temperatur All safety related HVAC Systems are provided with redundant fans which would both start automatically during emergency. With the single failure of a gravity damper to open, the redundant fan will continue to perform its safety functio Attachment 1, which identified the modifications for the resolution of this concern, includes all HVAC Systems (safety and non-safety) in which fan differential pressure switches have been provide . NRC Evaluation:

Project action indicates that the pressure sensing device will be a pitot tube (or equivalent) and that the duct velocity pressure tap will be connected to the differential pressure switch. This should indicate low air flow in the event of fan and/or damper failure. The project action indicates that the concern has been adequately addressed for systems reviewed by the team as well as for other systems.

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1. NRC Open Item No. M-4:

The subject calculation does not require maintaining the space temperature at or above 40*F during all modes of operation due to the conflict between the DBD and D . Project Action:

Response: Design Criteria Document DC-302A has been superseded by DBD-ME-302 . The calculation is consistent with the DBD with changes as marked up in the response to NRC comment M- Significance / Extent:

There is no safety significance, and the extent is limited to the Diesel Generator Area Ventilation Syste For details, see Open Item M- . NRC Evaluation: '

The project action adequately addresses the NRC concern by eliminating the conflict between design criteria document _- --- - - - .

, . NRC Open Item No. M-5:

The calculation refers to Calculation No. EE-11 which gives an "estimated generator heat loss." Since the generator heat loss is a large percentage of the total heat input into the area, the estimated value requires con-firmation. A letter from the manufacturer indicates the "estimated" value is good. This letter should be referenced in the calculatio . Project Action:

Response:

Information regarding generator heat loss was obtained in a telephone conversation with the manufacturer. The record of this telephone conversation will be incorporated into Calculation EE-11. Pages of this calculation marked with the intended revision are attached (Attachment 1).

Significance / Extent:

There is no safety significance since the results of the calculation are correc Since the Ebasco Calculation Procedures require identifi-

, cation of all sources for inputs, missing references are believed to be isolated.

l 3. NRC Evalcation:

As requested, Ebasco has incorporated the manufacturer's information l regarding the generator heat loss. The manufacturer stated the approximate efficiency is 96% and that the 4% difference can be assumed to be heat added to the diesel generator area. This efficiency is probably based on the rated load of 7000 Kw. While the efficiency will be slightly less at the LOOP required load of 6370 Kw, the actual heat load to the diesel generator area will not be significantly dif-ferent, and is therefore acceptable. In fact, Ebasco informed the team on February 2, 1988., that specification data indicates that the above data may be overly conservative and the efficiency at 6370 Kw may actually be greater than 96%.

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. . NRC Open Item No. M-6:

Neither the DBD nor DC-304 require maintaining the relative humidity during other than normal plant operation (Section 4.3a, Page 16). FSAR Section 9.4.1.2, Page 9.4-8 coninits to maintaining relative humidity as (given in Table 9.4.2) in the Control Room Complex during all modes of operatio . Project Action:

Response:

DC-304 has been superseded by DBD-ME-304. Attachment 1 (Ebasco to Impell letter EB-T-3536, dated September 22,1987) is the proposed FSAR chang As seen therein, the proposed relative humidity limits are:

Nonnal Operation 35 to 50% RH Emergency Operation 50% RH Maximum Section 4.2 of DBD-ME-304 is in agreement regarding normal operatio The emergency operation requirement will be added to section 4.3a of DBD (see Attachment 2, proposed DBD revision).

Significance / Extent:

Since this item relates to documentation inconsistency only, there is no safety significanc Attachment 1 (proposed FSAR Change Request) addresses design relative humicities for all areas, and will be the basis for the next revision to the DBD ,. NRC Evaluation:

The project action adequately addresses the NRC concern based on the i teams's review of the proposed revisions to the FSAR and DBD.

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1. NRC Open Item No. M-7:

Section 6.2.1, Page 36 and Section 6.2.8, Page 46 of the subject document give space thermostat setpoints at 68 F. FSAR Table 9.4-2 commits to 75'F i 5'F. Both heating and cooling thermostat setpoints should be within the FSAR committed rang . Proje::t Action:

Response: Instrument and control setpoints are presently being develope Hence, the space thermostat setpoint is an open item, together with other setpoints. Marked up pages of DBD-ME-304, idenfifying this setpoint as an open item, are included as Attachment . These DBD open items will be closed after Stone & Webster furnishes instrument setpoints based on Ebasco's transmittal of design limit Significance / Extent:

Since the setpoints are currently open items in the DBDs, and also since all safety related instrument setpoints are being validated by SWEC based on Ebasco's design limit inputs, there is no safety significanc . NRC Evaluation:

Instrument and control setpoints are being developed, including the

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ones noted in Open Item ho. M-7. Their identification as "open items",

! pending Stone and Webster setpoint actions, in DBD-ME-304 adequately addresses the NRC concern. It is noted that the team has reviewed Stone l

and Webster's performance in setpoint calculations, as reflected in the I&C Section of this report.

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. < NRC Open Item No. M-8:

Section 5.4, Page 34 of the subject document states "Precautions during low CCW temperature of 40*F is to be furnished (later)".

It is our understanding that air conditioning manufacturers warn that special arrangements must be made to accomodate condensing water temperatures below 55*F. This document should contain evidence that the manufacturer of the purchased air ccnditioning units agrees that the "precautions" taken for the 40*F condensing water temperature will not jeopardize the operation of the units, nor compromise their safety related performanc . Project Actions:

Response:

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As seen in Attachment 1, the vendor of these air conditioners has confirmed that the flow control methoc: will operate satisfactorily down to the minimum expected water temperature (40*F) entering the condense Flow control ft accomplished by the modulation of the component cooling water (condenser water) flow rate in response to refrigerant head pressure. The condenser water modulating control valve (including the electric controls portion), which is furnished as a part of the safety-related air conditioning unit, is safety-related. Hence, this concern will be deleted from DBD-ME-304. Appropriately marked up pages of the DBD are in Attachment List of Attachments:

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' Stone & Webster to TV Electric letter SWTU-0755 dated February 12, 1987, Pages of DBD-ME-304, Rev. O, marked according to the changes stated in the response abov Significance / Extent:

There is no safety concern as the manufacturer of this air conditioner l has already confirmed that the control valve provided is adequate for I condenser water temperatures down to 40*F. The air conditioning unit, l

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including the control valve for flow modulation, is safety-relate Extent is limited to refrigeration equipment with water-coolea condenser All such systems have already been reviewed. See Attachment 1, and the response to Open Item M-1 . NRC Evaluation:

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The project action adequately addresses the NRC concern.

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e e NRC Open Item No. M-9:

X-EB-304-4, Rev. O, fails to demonstrate by calculations or any other acceptable method that the sensible cooling requirements of the Control Room Complex can be met by the "as-built" HVAC syste . Project Action:

Response:

Calculaton X-EB-304-4 will be revised as shown in the attachment. In this revision, it is demonstrated by explicit calculations that the sensible cooling capacity requirements are met by the air conditioners under all operating modes. This calculation will be completed by November 7, 198 Significance / Extent:

As shown in the Attachment, the air conditioners have adequate sensible cooling capacity under all operating modes. Hence, there is no safety concern. The extent is limited to this calculation since this is the only instance where determination of sensible and latent cooling loads, at off-design conditions, is performe . NRC Evaluation:

Based on the team's discussions, the project agreed to the following changes to calculation X-EB-304-4: On sheet 9, 2nd paragraph, 3rd line, add the word "thermal" (end of line); On sheet 11, line 6, the value should be 1,869,067. This minor change may affect further calculations slightl . On sheet 14, line 9, the value .0017 should be .01 Subsequent calculations are probably not affecte Subject to these changes, the project's response adequately addresses the NRC concer .

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1. NRC Open Item No. M-10:

Drawing 2323-MI-0308 and DCA 59135 show a fire line with an isolation valve connected to the Control Room charcoal filters. Downstream of the valve is a drip trap that would collect and drain valve leakage. Of concern is that the trap could be dry as there apparently is no pro-vision for a trap primer. Upon filter operation, an air leak bypass could occu . Project Action:

Response:

TU Electric will be requested to implement maintenance / surveillance procedures to ensure that the drip trap has sufficient water at all times to prevent the potential air leak path into the filtration uni Ebasco has verified, by field inspection, that the traps of the air clean-up units have provision for primin Significance / Extent:

Air leakage through a "dry" trap could potentially reduce filtration unit effectiveness. The concern will be resolved by administrative procedures indicated abov The extent is limited to air clean-up units, and the administrative procedures will address all such unit . NRC Evaluation:

The project response adequately addresses the team's concern.

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s e NRC Open Item No. M-11:

Open Item M-11: The team noted the following examples where sections of the DBD either contradicted the above requirements or indicated that the SWIS Ventilation System relied upon a non-safety component to perform a safety functio Sections 2.2 and 2.3.2 on Page 9 and Section 4.2 on Page 12 require main-taining the Intake Structure Heating System operational only during normal modes of plant operation and state the heating system is non-nuclear safety; Therefore, it cannot be relied upon during emergency mode Sections 2.3.3 Page 10, 4.2 Page 12 and 5.2.1.3 Page 21 state the Diesel Fire Pump Room Exhaust System is required to operate only during normal modes of plant operaticn and then only during operation of the Electric Motor-Driven Fire Pum Sections 5.12 Page 18 and 5.3.1 Page 23 discuss situations when the Service Water Pump Temperatures are well above 122'F and state the equip-ment is qualified to operate at a maximum temperature of 131.8 . Project Action:

Response:

Design Criteria Document DC-312 has been superseded by Design Basis Document DBD-ME-31 FSAR Table 9.4-2 is proposed to be revised as shown in Attachment 1, Ebasco to Impell letter, EB-T-3536, dated September 22, 198 It is seen in Attachment 1 that the revised SWIS space temperature limits are:

126.2'F(Max.) for normal operation, 131.8 F Ma for emergency operation, 40*F Min, for all modes The following responses to NRC coments are based on these revised comitments: During emergency operation, the non-safety heaters are not needed. Heat generated by the operating service water pumps will be enough to maintain 40*F minimum space temperatur From Calculation X-EB-312-2, Rev. 1, the heating load is 153,180 BTUH with the outdoor temperature at 20* This does not take credit for heat gains from the operating pumps. From Calculation X-EB-312-1, Rev. 2, motor heat gair from each operating pump is 155,604 BTUH. At least one pump

! per plant unit will be operatin It can be seen that the j heat from even one pump is adequate to offset the heat losses

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in winter. In yiew of these considerable heat gains, the l space temperature will still be 40*F minimum, even if the space heaters are not operatin .- -

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~ - The diesel fire pump is abandoned in place (see Attachment 2).

Hence, there is no heat load in the room under any plant operating condition. Consequently, the temperature in this room is of no concern. Subject DBD will be revised to reflect this position (see Attachment 3 for marked-up sheets).

All loads other than those of the electric motor driven fire pump (EMDFP) have been considered in Calculation X-EB-312-1, Rev. 2. Hence, the operation of diesel fire pump room (DFPR)

exhaust fan is not required for maintaining space temperature unless the EMDFP is operating. If the EMDFP operates, the DFPR exhaust system removes its heat output. Also, note that fire coincident with LOCA is not a Design Basis Event. Therefore, it is clear that SWIS Ventilation System does not rely on the non-safety DFPR Ventilation System for maintaining the space temperature As stated at the beginning of the response, the DBD supersedes the Design Critaria. Hence, the Design Criteria requirement of 122*F is no longer applicable and the contradiction noted has been eliminated. The acceptability of room temperatures up to 131.2*F has been confirmed by Impell. See Attachment List of Attachments: Ebasco to Impell letter EB-T-3536, dated September 22, 198 . Comments by Engineering Planning & Management (EPM) on DBD-ME-312, Rev. O, (Draft A) Pages of DBD-ME-312, Rev. O marked as stated in the abcVe respons . Impell to Ebasco letter IMT-1730 dated April 9,198 Significance / Extent:

The comments are being resolved by some changes to the DB No changes to equipment, systems, or procedures are needed. Hence, there is no safety significance. The extent is limited to this system since the Open Item is specific to this syste . NRC Evaluation:

Based on the team's discussions, the project agreed to change the 122 F to 126.2 F in FSAR Table 9.4-2 under "SWIS - All Areas" in the

"Cooldown Maximum" column. This will then agree with the Response above. Subject to this change, the project response is acceptabl . _ _

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• NRC Open Item No. M-12:

DC-313, in Section 3.1, page 1, states the UPS and distributor rooms shall be maintained between 40 F and 104*F during all modes of plant operation. The subject document in Sections 4.3, page 13 and 11.1.3a, page 37 states that during either upset, emergency or faulted modes indoor temperatures are required to be maintained between 122*F and 40 In the subject document, Section 11.1.3, page 37, b. Summary conflicts with Section 10.13, page 27 concerning the static pressure developed by the fan to move air through the ductwork (1.5 vs. 3 inches). The static pressure calculation document rumber is not referenced in this DB . Project Action:

Response: Design Criteria Document DC-313 is superseded by Design Basis Document DBD-ME-313. The design space temperatures shown in the subject document (DBD-ME-313, Rev. 0) are the ones that are applicable. Attachment 1, Ebasco to Impell letter EB-T-3536, dated September 22, 1987, showing the proposed FSAR changes to Table 9.4.2, "Indoor Space Design Temperatures, Humidities and Pressures During Numal Plant and Emergency Conditions", agrees with temperatures in the DB The fan static pressure of 3" WB shown in Section 10.13, page 27 of DBD-ME-313 is the vendor-provided perfomance dat Section 11.1.3b, Sumary, on page 37 of the 080 shows a fan static pressure of 1.5" WG which is taken from Gibbs & Hill Calculation No. 0305-4P, Rev. O. A reference to this calcula-tion is already provided in DBD Section 11.1.3b on pt s 3 As the available fan static pressure exceeds the calculateo required static pressure, the fan selection provides a margin of safety. The final safety margin will be determined when Ebasco completes the pressure loss calculatio Significance / Extent:

The fan static pressure is higher than the currently calculated pressure drop through the ductwork. Hence, there is no safety concer . NRC Evsluation:

The project response adequately addresses the team's concer . _

a w n NRC Open Item No. M-13:

The UPS refrigeration units use Component Cooling Water (CCW) for condensing purposes as does the control room refrigeration units; however, DBD-ME-313 does not, in Systems Limitations and Precautions, Section 5.4, page 19, mention a precaution for the low, 40*F, con-densing water temperature as does DBD-ME-304, page 34 (0 pen Item M-8).

Section 6.3.1, page 21, states that a pneumatic flow control valve in the water cooled condenser inlet regulates flow rate of the CCW. It is our understanding most air conditioning equipment manufacturers give precautions against using condensing water temperatures below 55'F. The manfacturer's acceptance of this flow control method to accommodate the low condensing water temperature thould be confinned in order to ensure that the safety related performatce of these units is not compromise . Project Action:

Response,:

As seen in Attachment 1, SWEC to TV Electric Letter, SWTU-0755, dated February 12, 1987, the vendor of these air conditioners has confirmed that the flow control method will operate satisfactorily down to the minimum expected water temperature (40*F) entering the condense Flow control is accomplished by the modulation of the component cooling water (condenser water) flow rate in response to refrigerant head pressure. The condenser water modulating control valve (including the electrical controls portion), which is furnished as a part of the safety-related air conditioning unit, is safety-related. Hence, there are no special precautions for low water temperature to be incorporated into ths DB Significance / Extent:

There is no safety significance as the manufacturer of this air con-

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ditioner has already confirmed that the control system provided is l adequate for condenser water temperatures down to 40 F. The air con-ditioning unit, including the control valve for flow modulation, is safety-related.

t Extent is limited to refrigeration equipment with water-cooled condensers.

l All such systems have already been reviewe See attachment 1 and the l

response to Open Item H- . NRC Evaluation:

The project's respcnse adequately addresses the team's concern.

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w .. NRC Open Item No. M-14:

Open Item M-14: The sensible cooling load calculated is about 22 ton This conflicts with the statement made in DBD-ME-313 Section 1.4, Item 1 on page 8 relative to requiring a major reduction in cooling load from 26-1/2 to 13-3/4 ton On page 24, the sensible heat gains shown do not agree with those given in DBD-ME-313, Section 11.1.3, pa e 37.a. Summary. (263,538 and 259,813 BTUH VS. 167,493 and 165,458 BTUH . Project Action:

Response: The statement in Section 1.4 of the DBD that the total cooling load is 13-3/4 tons, is incorrect. The actual load is indeed about 22 tons. The DBD will be corrected as shown in Attachment . The sensible load given on page 24 of the Calculation is the total, including space heat loads and the heat load from the supply and return fans. The loads given in Section 11.1.3 of the DBD on page 37 are "total space sensible heat gains"; these do not include fan heat output. Hence, there is no conflic List of Attachments: Page 8 of DBD-ME-313, Rev. O, marked with charges as

, stated in the above respons Significance / Extent:

There is no safety concern. The discrepancy between calculations and DBD is due to an error in the DBD. This will be corrected in the next revisio The extant is limited to this DBD based on our review of other similar DBD . NRC Evaluation:

The project action adequately addresses the team's concerns.

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