ML20205T084
| ML20205T084 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/30/1987 |
| From: | HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20205T066 | List: |
| References | |
| NUDOCS 8704070210 | |
| Download: ML20205T084 (129) | |
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Attcchment i ST-HL-AE-2008 File No.: G4.02 SOUTH TEXAS PROJECT ENGINEERING ASSURANCE PROGRAM HOUSTON LIGHTING & POWER COMPANY
SUMMARY
REPORT MARCH 30, 1987 l
8704070210 870331 PDR ADOCK 05000498 A PDR
ss . .
Table of Contents fate Executive Summary Introduction i Scope of the EA program i
~ Methodology and results of the engineering assurance program 111 Conclusions vi Structure of the engineering assurance program summary report vi 1.0 Engineering assurance program assessments and conclusions 1 1.1 Introduction 1 1.2 Engineering assurance program objective and policy 1 1.3 General 2 1.4 Approach 4 2.0 Assessments and reviews 10 2.1 Soil-structure interaction analysis and seismic design 10 2.2 Design process review 15 2.3 ASME III pipe stress analysis 19 2.4 ASME III pipe support design 26 2.5 Containment pressure / temperature / radiation 29 analysis 2.6 Equipment qualification 32.
2.7 Separation and fire protection criteria 38-2.8 Control room HVAC system 42 2.9 Component cooling water system 46 i i
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P_ age 2.10 Off-site and medium-voltage AC power supply systems 52 2.11 High energy line break analysis 61 2.12 Field walkdowns 68 3.0 Categorization and analysis of findings 78 4.0 Conclusions 82 4.1 Adequacy of the overall design process 82 4.2 Adequacy of the design of the systems reviewed 84 4.3 Categorization and analysis of findings 86 4.4 Technical adequacy of the overall plant design 86 5.0 Exhibits 88 5.1 Houston Lighting & Power Company engineering assurance program policy 89 5.2 Nuclear Regulatory Commission approval of the engineering assurance program policy 100 5.3 Interface agreement - Bechtel/ Project Engineering Team / Engineering Assurance 104 5.4 HL&P/ Stone & Vebster Engineering Corporation memorandum of understanding 110 5.5 Independent Oversight Committee charter 113 5.6 Action item cross reference 114 5.6.1 Action items resulting in FSAR changes 114.
5.6.2 Action items evaluated for reportability_
under 10CFR50.55(e) 115 5.6.3 Action items with design change implications 116 1
5.7 Independent oversight committee review of the engineering assurance program and summary report 118 ,
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SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION ENGINEERING ASSURANCE PROGRAM
SUMMARY
REPORT Executive Summary Introduction This report documents the results of the engineering assurance (EA) program developed and implemented by the Engineering Assurance Department of Houston Lighting & Power Company (HL&P) with the assistance of Stone &
Vebster Engineering Corporation (SWEC) to provide additional assurance that the design of the South Texas Project (STP) Electric Generating Station is technically adequate and meets applicable licensing commitments and requirements. The EA program consisted of a detailed review of the technical adequacy of the design of representative STP systems and other design features, as well as the design process utilized by Bechtel Energy Corporation (Bechtel), the architect-engineer for FTP. The results of the EA program demonstrate that the portions of STP design reviewed in i connection with this program are technically adequate and-comply.vith applicable licensing requirements. The results of the program, coupled with ongoing STP design finalization activities, including the design document turnover program, give reasonable assurance that the STP design process and overall STP design are technically adequate and comply with applicable licensing requirements.
Scope of the EA program The EA program was an independent, comprehensive, and well-documented design reviev, which in scope and depth'of analysis exceeded many of the Independent Design Verification Programs (IDVPs) conducted at-other nuclear power plant projects and was accepted by the NRC for use at STP in lieu of a separate IDVP. The program was conducted in accordance with an NRC-endorsed program policy, which incorporated internal HL&P engineering assurance procedures,~a formal interface agreement governing communications among HL&P's Engineering Assurance team, HL&P's South Texas i
Project Engineering Department, and Bechtel, and a memorandum of understanding between HL&P and SVEC to assure the independence and objectivity of the technical reviews and assessments performed as part of the EA program. An Independent Oversight Committee composed of outside experts reviewed the major EA program activities and developments.
Each assessment was performed by a dedicated team composed of qualified Engineering Assurance Department and SWEC personnel experienced in the design of nuclear power plants. The EA program was conducted over a four-year period during which more than 13 different aspects of the STP design were subjected to in-depth review.
The results of prior design reviews of other nuclear power plants and prior STP design reviews, including the design work packages prepared by Bechtel when it assumed the responsibilities of principal architect-engineer for STP, were considered in selecting the systems and design features to be reviewed in the EA program. The program included both vertical and subject-specific design reviews of representative STP systems and design features in each of the principal engineering disciplines (i.e.
mechanical, civil / structural, electrical and control, nuclear, pipe stress / pipe support, instrumentation, and system interactions). The scope and diversity of systems and features reviewed and the depth of analysis assured that any systematic process errors would be discovered.-
Vertical reviews consisted of detailed assessments of the entire design 1 process for certain STP systems in each of the engineering disciplines from development of initial design criteria through the completed design.
The residual heat removal / safety injection system, control room HVAC system, component cooling water system, and off-site and medium-voltage AC and DC power supply systems underwent vertical reviews.
Subject-specific reviews included detailed evaluations of certain design requirements and features common to systems and structures throughout STP.
These included soil-structure interaction and STP seismic design analysis, ASME III pipe stress and pipe support design (including Class 1 pipe stress analysis), containment pressure / temperature / radiation analysis, the.
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equipment qualification program, high energy line break and moderate energy line crack analyses, and separation and fire protection programs.
A detailed review of the overall Bechtel design process and a series of field walkdowns of the plant were also conducted on a sample basis to assure that design controls and' procedures were adequate and that the various STP systems and other design features reviewed as part of the EA program were generally configured as designed.
In accordance with the program policy, both vertical and subject-specific reviews focused on the identification and resolution of technical concerns related to the adequacy of the STP design and the Bechtel design process; the program was not intended to highlight favorable aspects of STP design or the Bechtel design process. Upon completion of the reviews, the Engineering Assurance Department and SVEC evaluated the individual and collective significance of the various concerns that had been identified during the course of the EA program, and SVEC' performed a rigorous I
categorization and trending analysis to determine whether any possible generic implications were associated with these concerns. Based upon the results'of the individual reviews and the categorization program, conclusions were drawn regarding the design adequacy of both the systems and other design features reviewed, as well as the overall plant and design process.
2 Methodology and results of the engineering assurance program
- Once a given area of STP derign was selected to undergo assessment, a detailed " scope and schedulrP document was prepared, outlining the various tasks and activities to be undertaken, the various methodologies to be
- employed in the review (e.g., sampling or additional calculations), the personnel and other resources required to conduct the assessment,-and the schedule of activities.
- Upon approval of the assessment scope and schedule, a more detailed plan and the related document review plans (DRPs) were developed by the EA team, drawing upon their experience and expertise and extensively using 111 1
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checklists to ensure that the DRPs vould enable the team to verify design compliance with applicable design codes, standards, and licensing commitments (e.g., SAR and SER commitments and criteria, NRC standard review plans, Bechtel design guides, and ASME Code provisions). As a result, DRPs listed all design documents the team proposed to review in connection with the assessment and generally included the implementing 4
design criteria, calculations, schematics, design drawings, specifications, analyses, and other design documents related to the area undergoing review.
Bechtel and the STP project organization then supplied the EA team with available design documentation and information relating to the area under consideration, and a pre-assessment meeting was held in which the DRPs were refined, additional design information was exchanged, contact points were established, and the assessment plan was discussed in greater detail.
As the assessment progressed, the EA team held a series of technical discussions and meetings with the cognizant design personnel from Bechtel and the STP project organization to address questions that arose during f
the course of the assessment, clarify the design methodology employed in any given area, request additional supporting calculations or justification for the use of engineering judgment in connection with certain design assumptions or analyses.
In assessing technical adequacy of the design of any given system or feature, the EA team relied primarily on design results set forth in output documents. Instead of attempting to go back and reverify each step of.the design, the team reviewed the accuracy and reasonableness of input-and output and the adequacy of the design techniques that were used. Any condition identified by the EA team during the course of the assessment that raised a concern about the technical adequacy of the design or the design process employed in connection with the design area undergoing review was classified as a review item. These items were then compiled in a draft report and forwarded to Bechtel and STP Engineering for review and comment; Bechtel and STP responded to each of the items. l iv
l A post-assessment meeting was then held to review the draft. Many concerns were resolved to the satisfaction of the EA team and closed out on the basis of additional information supplied in Bechtel and STP Engineering comments. This additional information was included as_part of the final report.
In the final report, findings and review items that were not completely closed out on the basis of the Bechtel/STP Engineering comments were classified as unacceptable items, significant concerns, minor concerns, or observations, depending upon the significance of the item and the sufficiency of the Bechtel/STP Engineering response. Items not closed out at this point were considered to be action items (except for minor enhancement or administrative items, which were classified as observations), requiring further follow-up by the EA team to ensure that appropriate preventive or corrective action was taken. In most instances, preventive or corrective actions taken were based upon recommendations made by the EA team in the final report, and in every instance, the corrective or preventive actions taken were required to be satisfactory-to the manager of the Engineering Assurance Department and the EA team.
Action implementation was verified by the FA team.
Action items were evaluated individually and collectively (i.e.
categorized) by SVEC to deteruine if any possible generic implications were applicable to the system or STP design feature to which they were related, the Bechtel overall design prpeess, or the design of other STP systems or structures. The possible generic concerns identified in the various individual assessments and confirmed by the SWEC categorization program were (1) the need to resolve inconsistencies among design documents, (2) the need to better document the basis for engineering judgment, and (3) the need to finalize preliminary calculational data.
None of these concerns had a significant effect on the technical adequacy of the design, because valid engineering judgments had been made and design margins were conservative. No noteworthy hardware changes were required.
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Bechtel and STP Engineering have implemented a series of programs to check and finalize calculations related to safety-significant systems and design features and to resolve inconsistencies among design documents.
Conclusions Based on the EA program assessments, STP responses, and the verification of project commitments, as well as the categorization and analysis of findings and ongoing design finalization activities, the EA team has concluded: (1) that the Bechtel design process is adequate, (2) that the design of systems and features reviewed is adequate, and (3) that a systematic analysis of all action items reveals no concerns not previously recognized and addressed. Therefore, the results of the EA program provide reasonable assurance that the overall design of STP is adequate and complies with applicable licensing commitments.
Structure of the engineering assurance program summary report This summary report is divided into five sections. Section 1 describes objective, scope, and overall approach of the engineering assurance program. Section 2 contains a detailed discussion of the scope, principal action items identified, corrective actions, and Engineering Assurance Department conclusion concerning adequacy of the technical aspects of STP design reviewed during each of the reviews or assessments undertaken as part of the EA program. Section 3 summarizes the purpose, scope, methodology, and results of the categorization and analysis of findings performed by SVEC. Section 4 presents the conclusions of the program concerning adequacy of (1) the Bechtel design process, (2) the aspects of STP design reviewed under the program, (3) the categorization analysis, and (4) the overall STP design. Section 5 lists pertinent EA program documents.
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1.0 Engineering Assurance Program Assessments and Conclusions 1.1 Introduction f
i The engineering assurance (EA) program consisted of an independent design review of the South Texas Project (STP)
, Electric Generating Station conducted by the Engineering l Assurance Department of Houston Lighting & Power Company (HL&P) with the assistance of-Stone & Vebster Engineering Corporation (SVEC).
a 1.2 Engineering assurance program objective and policy The objective of the EA program was to provide additional assurance that the STP design is technically adequate and meets applicable licensing commitments and requirements imposed by-the United States Nuclear Regulatory Commission (NRC). The program consisted of a detailed review of the technical adequacy of the design of selected systems and other design- j features representative of overall STP design, as well as the adequacy of the design process utilized by Bechtel Energy Corporation (Bechtel), the principal architect-engineer on STP.
l The EA program was conducted in accordance with an internal 1 HL&P engineering assurance program policy that was approved August 20, 1984, in a letter to HL&P from the Director of the Division of Licensing of the NRC Office of Nuclear Reactor
) Regulation. Approval was subject to certain conditions, nhich j vere fulfilled by HL&P. The EA program was also conducted in accordance with formal Engineering Assurance Department
! procedures, a formal interface agreement governing communications among HL&P's Engineering Assurance team, South
- Texas Project Engineering, and Bechtel, and a separate ;
memorandum of understanding between HL&P and SWEC to assure the-i 1
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1 independence and objectivity of the technical reviews and assessments performed as.part of the EA program.
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- The EA program was conducted by a team of engineers with extensive experience in nuclear plant design under the direction and leadership of the manager of the Engineering Assurance Department. The Engineering Assurance Department
! manager reported directly to HL&P's Vice President, Nuclear-
[ Engineering & Construction, from 1982 to 1985 and subsequently i
to the Group Vice President, Nuclear, from 1985 to 1987. An
! Independent Oversight Committee, consisting of Mr. R. V. Laney, Dr. H. H. Woodson, and Dr. J. M. Hendrie, vas established to periodically oversee the functioning of the engineering j assurance program to assure its independence and viability; i.e. that the program was organized and executed effectively and that conclusions were objectively treated by responsible j management.
None of the engineering personnel who performed the EA
, assessments had any prior direct involvement in STP engineering l or design activities, and none'of'the SVEC personnel assigned to the engineering assurance program had-any significant financial interest. in STP, HL&P, the other project owners, Bechtel, or other major STP contractors. The EA program policy, NRC approval letter, interface agreement, HL&P/SWEC memorandum of understanding, and Independent Oversight i
Committee charter are included as Exhibits 5.1 to 5.5 of this l report.
i 1.3 General i
The EA program included both vertical and subject-specific reviews of representative STP systems and design features
! involving each of the principal engineering disciplines (i.e.
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mechanical, civil / structural, electrical and control, nuclear, pipe stress / pipe support, and instrumentation), as well as design process reviews assessing the adequacy of Bechtel engineering practices and design controls in each of these disciplines.
The vertical reviews consisted of detailed assessments of the entire design and design process employed in each of the engineering disciplines in connection with certain representative STP systems from development of the initial design criteria through the completed design. The residual heat removal / safety injection system, the component cooling water system, control room HVAC system, and off-site and medium-voltage AC and DC power systems underwent vertical reviews.
Subject-specific reviews included detailed evaluations of certain design requirements, features, and analyses common to systems and structures throughout STP, including the systems undergoing separate vertical reviews. These design requirements, features, and analyses included soil-structure interaction and STP seismic design analysis, ASME III pipe stress and pipe support design (including Class 1 pipe stress analysis), containment pressure / temperature / radiation analysis, the equipment qualification program, high energy line break and medium energy line crack analysis, and separation and fire protection criteria.
The EA team also conducted detailed reviews of the overall Bechtel design process within the various engineering disciplines ano a series of-field walkdowns of the plant itself in order to assure the adequacy of design controls and procedures and to assure that the various STP systera, design 3
features, and requirements reviewed as part of the EA program were configured and/or implemented as designed.
Upon completion of the EA program, the EA team evaluated the individual and collective significance of the various design concerns identified during the course of the program, and SWEC performed a rigorous categorization analysis to determine whether any possible generic implications were associated with these concerns. Based upon the results of the individual vertical and subject-specific reviews, design process reviews, field walkdowns, and categorization program, the EA team
' formulated conclusjons regarding the technical adequacy of system design and other design features and requirements reviewed during the course of the program, as well as the adequacy of overall plant design and the design process employed by Bechtel.
1.4 Approach The various vertical and subject-specific reviews conducted under the EA program consisted of independent technical assessments (performed by the EA team augmented by additional engineering personnel supplied by SWEC as required) or, when the EA team did not possess the requisite level of expertise ,
relating to the area undergoing review, third-party design assessments (performed by SWEC personnel and coordinated by the EA team). The one design process review was performed by Engineering Assurance Department personnel, again augmented by SVEC personnel as required.
Rather than simply taking a " snapshot" of the STP design as it existed at a certain point in time, the EA program was structured so that additional design assessments could be incorporated into the program as STP design evolved and the EA 4
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program progressed. Between three and five separate independent technical assessments and third-party design assessments were conducted each year over a four-year period.
Before the beginning of each year _ specific design areas to be covered in the assessments scheduled for that year were selected by the manager of the Engineering Assurance Department and approved by HL&P's senior executive management. Later in the program, each proposed review area was also discussed with the Independent Oversight Committee and the NRC staff before the assessment was begun. Selection of systems and design features and requirements to be evaluated was based upon selection criteria set forth in the EA program policy. In general, these criteria included the following:
- The design areas reviewed should include systems and features where known technical problems existed at other plants.
- The design areas reviewed should include systems and design features that are representative of other systems and features throughout the overall STP design.
- The design a*eas reviewed should include areas involving new design features unique to STP.
- The design oceas reviewed should be of typical complexity and involve a cross section of engineering and design disciplines and a significant interface with other STP vendors and suppliers.
- The design areas reviewed should include areas of known contractor difficulties and management concern at HL&P.
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- The design areas reviewed should include systems and i
features where design is essentially complete.
a In selection of areas to be reviewed, the following were also
- considered: (1) the results of independent design verification programs (IDVPs) previously conducted at other Bechtel-designed 3
plants, (2) prior STP design reviews, and (3) independent review of the Brown & Root STP design work that was performed by Bechtel_before they assumed the responsibilities of
, principal architect-engineer for STP. While each of the design areas selected for review by the EA program did not individually satisfy all of the selection criteria, the systems and features that were selected, as a whole, met all of the selection criteria.
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The design process review focused on the manner in which design
) activities were conducted and th'e process by which the design l developed. Unlike a quality assurance audit, which focuses i
i primarily on procedural compliance, the design process review also included reviews of the technical substance of the design j'
process to assure that the design resulting from the use of l this process was consistent with sound engineering practice and
! applicable licensing commitments. The design process reviev l enabled the EA team to assess the adequacy of Bechtel design
- controls and procedures by evaluating whether (1) correct and current design inputs were being utilized by the various ,
Bechtel engineering groups in connection with STP design
- activities and (2) design changes were being properly evaluated, coordinated between design disciplines, and incorporated into STP design.
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4 Once a given area of STP design vas selected to undergo assessment, a detailed " scope and schedule" document vas-j prepared, outlining the various tasks and activities to be undertaken, the various methodologies to be employed in the review (e.g., sampling or additional calculations), the personnel and other' resources required to conduet the l assessment, and the schedule of activities.
I Upon approval of the asssessment scope and schedule, a more i detailed plan an'd the related document review plans (DRPs) were
! developed by the EA team, drawing upon their experience and
! expertise and extensively using checklists to ensure that the DRPs would enable the team to verify design compliance with
- applicable design codes, standards, and licensing commitments-(e.g., SAR and SER commitments and criteria, NRC standard-i review plans, Bechtel design guides, and ASME. Code provisions).
As a result, DRPs listed design documents the team proposed to review in connection with the assessment and generally included' the implementing design criteria, calculations, schematics, design drawings, specifications, analyses, and other design-
- documents related to the area undergoing review.
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l Bechtel and HL&P's STP Engineering organization then supplied i the EA team with available design documentation and information relating to the area under consideration, and a pre-assessment meeting was held in which the DRPs were refined,. additional
- design information was exchanged, contact points were established, and the assessment plan was discussed in greater detail.
t As the assessment progressed, the EA team held a series of I. technical discussions and meetings with-the cognizant design-I personnel from Bechtel and STP Engineering to address questions that arose during the course of the assessment, clarify the i
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a i design methodology employed in any given area, and request additional supporting calculations or justification for the use j of engineering judgment in connection with certain design assumptions or analyses.
In assessing technical adequacy of the design of any given system or feature, the EA team relied primarily on design results set forth in output documents. -The team reviewed the j accuracy and reasonableness of input and output and the i adequacy of the design techniques that were used. Any condition identified by the EA team during the course of the
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assessment that raised a concern about the technical adequacy of the design or the design process employed in connection with the design area undergoing review was classified as a reviev '
item. These items were then compiled in a draft report and forwarded to Bechtel and STP Engineering for reviet and comment; Bechtel and STP responded to each of the items.
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l A post-assessment meeting was then held to review the draft.
j Hany concerns were resolved to the satisfaction of the EA team 1 and closed out on the basis of additional information supplied i
in Bechtel and STP Engine ring cor.ments. This additional a
i informat'.on was included as part of the final report.
- In the final report, findings and review items that were not completely closed out on the basis of the Bechtel/STP f
Engineering comments were classified as unacceptable' items, significant concerns, minor concerns, or observations, depending upon the significance'of the item and the sufficiency of the Bechtel/STP Engineering response. Items not closed out at this point were considered to be action items (except for l
minor enhancement or administrative items, which were-classified as observations), requiring further follow-up by the i
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j EA team to ensure that' appropriate preventive or corrective action was taken. In mo7t instances, preventive or corrective actions taken were based upon recommendations made by the EA team in the final report, and in every instance, the corrective or preventive actions taken vere required to-be satisfactory to the manager of the Engineering Assurance Department and the EA j team. Action implementation was verified by the EA team.
) When the reports on all reviews and assessments were completed, including field walkdowns conducted to ensure that the systems j and design features reviewed were' configured as designed, the EA team evaluated the individual and collective significance of the design concerns identified during-the course of the entire program, both on a system-by-system and engineering discipline-by-discipline basis. The EA team also evaluated.the nature and j extent of corrective and preventive actions taken by Bechtel and STP Engineering and the commitments made both by Bechtel j and STP Engineering to undertake additional design verification and completion activities related to the design concerns identified by the EA t,eam.
In addition, SWEC performed a rigorous categorization analysis to determine whether any possible generic implications existed i
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in association.with these concerns that might have a bearing on the design adequacy of other STP systems and design features that were not reviewed as part of the program.
A detailed description of each EA assessment, including a discussion of the principal review items and preventive and corrective actions related to these' items, is set forth in Section 2 of the report. Section 3 contains a description of the SVEC categorization and' trending analysis and the results of this analysis and summarizes the results'and conclusions-of-the engineering assurance program.
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2.0 Assessments and Reviews The following part of this report discusses the various reviews and assessments performed during the course of the EA program. Included in the discussion of each assessment is a description of action items that vere judged by the EA team to be noteworthy for this report; i.e. the action items presented resulted in substantive action by Bechtel to assess significance and assure design adequacy and/or compliance with licensing commitments. Other action items were of minor consequenci to the conclusions drawn in each assessment and, therefore, are not discussed in detail in this report.
Exhibit 5.6 lists action items that (1) resulted in FSAR changes, (2) were evaluated for reportability under 10CFR50.55(e), and (3) were notesorthy for discussion in this section of the report because of design change implications.
2.1 Soil-structure interaction analysis and seismic design Independent Technical Assessment 83-1 and supplement 2.1.1 Purpose and scope The objective of this assessment was to independently verify that seismic analysis and design of STP safety-related structures is technically adequate and conforms to STP FSAR commitments. The assessment evaluated the soil-structure interaction (SSI) analysis of STP safety-related structures. As a sample, the seismic analysis of the mechanical-electrical auxiliary building (MEAB) was selected for a detailed review because it houses a number of safety-related mechanical and electrical components and encompassed the significant attributes of an SSI analysis.
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In order to verify the adequacy of STP design-basis seismic floor response spectra, the assessment was primarily directed toward review of the confirmatory seismic analysis performed by Bechtel. The rationale for this approach was that if the seismic response from the Bechtel confirmatory study were bounded by the STP design-basis seismic response, then the STP seismic design basis should be considered conservative and acceptable. The effort consisted of a detailed review of seismic. design criteria, seismic input in terms of response spectra and time histories,-STP licensing commitments, SSI analysis, seismic model and analysis of the HEAB, development of structural response and floor response spectra curves, and provisions for seismic load transfer by major structural-components of the MEAB. This effort also involved developing an independent HEAB dynamic model, based on present building layout, and performing an independent seismic analysis for the HEAB.
Subsequent to completion of the assessment, the EA team conducted additional reviews of concrete and steel design performed by Bechtel to supplement the original assessment. The supplement consisted of an independent assessment of the technical adequacy of civil /
structural design in three sample areas selected from the reactor containment building (RCB) internal steel structure, MEAB concrete floor at elevation 60 ft.; and concrete isolation valve cubicles (IVC). Selected calculations and design drawings for these areas were reviewed to verify that the design is in conformance with STP FSAR commitments, design criteria, industry 11
codes and standards, and accepted engineering principles. The review also verified that major loads and load combinations were considered in the design.
2.1.2 Assessment The assessment found that, overall,-the confirmatory SSI analysis was well documented, the methodology was appropriate to meet regulatory requirements, and the results of the analysis were reasonable.
The analysis confirmed that use of STP design-basis seismic response spectra developed by Brown & Root is, in general, conservative with a few exceptions at low frequencies (less than 4 cps) for some buildings. FSAR Section 3.7 and STP design criteria S01001 were updated to incorporate the current seismic design basis.
Bechtel issued interdisciplinary criteria S01004 for verification of seismic adequacy for syster.s, components, and equipment at very low frequencies where the design basis spectra did not envelop the confirmatory spectra.
The assessment supplement found that, overall, the designs of the RCB steel internal structure, MEAC concrete floor at elevation 60 ft.; and concrete IVC structures were adequate and met the requirements of the FSAR and design criteria. The design calculations utilized member sizes, dimensions, and structural configuration that were consistent with design drawings. The review identified a few instances where the calculation did not fully document the basis for engineering judgments / assumptions used. Subsequently, Bechtel either provided a new calculation to 12 i
demonstrate the adequacy of engineering judgment or revised the calculation to-document the basis for engineering assumptions.
i-A discussion of noteworthy action items and their resolutions follows:
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- The FSAR was not clear as to how three directional earthquakes were combined, as required by Reg. Guide 1.122, nor did it note that Reg.-Guide 1.60 spectra 4
were not enveloped at very lov frequencies. (Action items 83-1-1, 83-1-2, and 83-1-3)
These concerns were resolved by revising the FSAR to clarify how three directional earthquakes were
-+ combined; Reg. Guide 1.122 was properly applied in the design. The FSAR was also revised to note that a minor deviation from the Reg. Guide spectra at very lov frequency does not impact the seismic adequacy of the design.
- Design documents pertaining to calculations of seismic shear stress did not use the latest seismic loads and configuration of the MEAB..The results and l conclusions of the calculations were not affected by
} the new input data. (Action item 83-1-8)
In response, Bechtel revised the seismic load j distribution calculations for safety-related structures, using the appropriate seismic loads-and I j configuratior of the MEAB. The EA team reviewed some of the revised calculations and verified that !
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- STP actions were implemented as committed.
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- Design basis vertical floor response spectra curves did not include local effects of floor flexibility.
(Action item 83-1-10)
In response, Bechtel committed to perform the analysis to establish floor subsystem frequency limits above which the floor response spectra curves can be'used directly without amplification, for the seismic qualification of items mounted on floor subsystem.
The EA team reviewed the parametric study that established the structural subsystem minimum frequency for safety-related power block buildings and found the study acceptable, as well as the Bechtel action taken to resolve the issue.
- The effect of thermal growth of steel column within the RCB internal structure under abnormal conditions was not addressed in the calculation. (Action item 83-15-6)
In response, Bechtel performed a supplementary analysis to demonstrate that loads due to thermal growth of the column are not significant.
The EA team reviewed the supplementary calculation and is satisfied that thermal loads are adequately addressed. No significant increases exist in either
, the column axial load stresses or the local bending moment stresses due to beam fixity.
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2.1.3 Conclusions Based on the assessment and its supplement, the STP response, and Engineering Assurance Department verification of project commitments, the EA team has concluded that the confirmatory soil-structure interaction analysis and the civil / structural design are adequate to meet applicable STP licensing commitments.
2.2 Design process review Design Process Reviev 83-2 2.2.1 Purpose and scope The objective of this review was to evaluate adequacy _
of design process controls by examining design development of the safety injection portion of the RHR/ safety injection (SI) system. The review concentrated on confirmation of adequate control in the following areas of the design process:
- design inputs
- design interfaces
- design process, including tracking process for commitment control
- design outputs
- design changes The review concentrated on evaluating the design l process control of the part of the system in the Bechtel scope of supply. Implementation of 15
Vestinghouse Nuclear Energy Services (VNES) system design input and other system requirements and criteria by Bechtel in further development of the total system was evaluated.
Interfaces between Bechtel and other external organizations (e.g., equipment vendor and constructor) were also considered during the review process.
The mechanical, electrical, and instrumentation and control (I&C) portions of the system were reviewed, as well as the methodology and criteria followed to develop the pipe stress analysis and pipe support for the system. SI system requirements for support systems such as electrical, I&C, etc., were reviewed.
Specifications for selected components (e.g., valves,.
pumps, instrument tubing, level switches, flow transmitters, circuit breakers, and pipe stress analyses) were reviewed to verify that:
- Design documents contain proper design inputs consistent with established criteria and commitments.
- Design calculations and analyses have been systematic and performed in such a way that objectives of calculations, design assumptions, design inputs, and pertinent references are clearly specified.
- Procurement documents clearly specify applicable codes, regulatory commitments, and the extent of applicability.
16
- Use of design inputs'and outputs have been controlled by procedures.
- Flov of design information between internal and external organizations has been controlled and adequate.
I 2.2.2 Review In the review of the controls for design inputs, interfaces, outputs, and changes, the design process
! vas evaluated as adequate in the mechanical, I&C, and pipe stress analysis portions or the RHR/SI system. In view of the significant electri.al design development in progress, the electrical system design process review was combined with assessment 85-3, Off-site-AC Power and Medium-voltage AC Power Supply Systems. - _
The noteworthy action items and their resolutions follow:
- The responsible system engineer was not informing the stress analyst of all possible significant system i operating modes so that the stress analyst could
- determine which of the modes to consider for stress '
f analysis. (Action item 83-2-1)
To resolve this concern, Bechtel issued Project 1
Engineering Directive 022 (PED-022), System Design Data Packages for Stress Analysis, requiring the mechanical discipline to inform the pipe stress and.
support disciplines of system operating modes.
i
(
i i
17
_ . . _. ~ . .- - - . . . . . . - . -
- A concern regarding nozzle loads arose from this design review. When allowable nozzle loads were not available, the stress group had no guideline for verifying from the vendor whether the nozzle load had been exceeded. (Action item 83-2-3) i- To resolve this concern, Bechtel revised Engineering Department Procedure 2.16'(EDP 2.16), project design group functions, adding guidelines for reconciliation of nozzle loads for equipment and components.
1
- General Project. Requirement 1.3 (Nuclear Steam Supply i System interface and interface between entities) required that selected design documents generated by Bechtel be sent to WNES for review and confirmation i
1 that interface requirements were fulfilled. At the.
i
- time of the design process review, the list of j selected documents requiring verification by VNES, i including identification of areas of a document to be i reviewed after selection, was not available. (Action item 83-2-2) i
} To resolve the concern, Bechtel developed the significant interface review program (SIRP) to identify the interface criteria that had to be reviewed to confirm that Bechtel design practices adequately accounted for WNES requirements.
- The Bechtel calculation procedure did not require the calculation purpose, objective, scope, conclusions, ,
etc., to be explicitly identified. (Action item 83-2-6) i e
f 18
1 In response to this concern, Bechtel included each of these calculation attributes in-its revised procedure ,
for controlling design calculations, EDP 4.37 (Design Calculations). In the course of the project, ,~
calculations were evaluated with respect to the (~)
attributes of the new procedure and revised where appropriate.
The Engineering Assurance Department reviewed PED-022, EDP 2.16 regarding nozzle load reconciliation, the SIRP effort, and EDP 4.37 and is satisfied that these procedures provide the required guidance in each of the identified areas of concern.
2.2.3 Conclusions Based on the review, the STP response, and Engineering Assurance Department verification of the response, the EA team has concluded that the design process in the mechanical, I&C, and pipe stress analysis portions of the RHR/SI system is adequate to ensure that design inputs, codes, and criteria are systematically identified and applied, so that the resulting design vill meet licensing commitments.
2.3 ASME III pipe stress analysis Third-party Design Assessments 83-3 and 85-5 2.3.1 Purpose and scope The objective of these assessments was to evaluate the technical adequacy of the Bechtel piping analysis and piping analysis methods and the effectiveness of the 19
process for controlling the interdisciplinary activities in this area. The piping analysis was also evaluated for compliance with the AShE III Boiler and Pressure Vessel Code and with licensing commitments.
The scope covered ASME III Class 1, 2, and 3 piping.
system analyses. The reviews were completed using a representative sample of piping subsystens, consisting of large-bore piping systems subjected to a number of different analysis conditions.
Piping subsystems were selected from the residual heat removal / safety injection (RHR/SI) system and the letdown portion of the chemical and volume control system.
2.3.2 Assessment In the review of the piping stress analysis calculations, criteria, specifications, and implementing procedures, the assessments found that, overall, the piping stress L.;alysis was consistent with the design rules of the ASME Code and with licensing commitments.
The assessment of ASME III Class 1 pipe stress analysis identified some technice.1 concerns involving the portion of the piping analysis that is performed only on ASME III Class 1 piping.
l The noteworthy observations resulting from this assessment and their resolutions were: l l l
- 20 i
- Thermal movements at certain reactor coolant loop branch connections were misapplied, due to incorrect transformation from Westinghouse to Bechtel coordinate systems for the input movements supplied by Westinghouse.
To resolve this concern, Bechtel performed a complete review of other affected calculations and specified a standard procedure for coordinate transformation in
. PED-023. (Action item 85-5-11)
The EA team reviewed the PED and the revised calculations and is satisfied that Westinghouse
- design inputs are being correctly transformed by Bech t<.T..
- In instances in which use of alternate materials was permitted, the actual material used was not always identified. In its response to this item, Bechtel.
committed to a complete review of Class 1 calculations for this item, noting that the lover stress allowables would be used for ASME III Class 2 and 3 systems and that the pertinent calculations vould document the actual pipe materials used.
(Action item 85-5-15)
The EA team reviewed some of the revised calculations and is satisfied that the proper pipe materials are being identified and the appropriate stress I allowables used.
- Pipe support attachment weights were not systematically included in the pipe stress analyses.
(Action item 85-5-21) 21 I
I In order to resolve this concern, Bechtel reviewed all Class 1 calculations and Class 2 and 3 calculations in which damped seismic spectra were used and the upset or faulted stress ratios exceeded 90% of the code allowable value. The EA team reviewed the results of the Bechtel effort and found it to be acceptable.
-.The location in the piping system at which the maximum combined stress occurs was not conservatively established for cases in which stresses were manually combined. (Action item 85-5-25)
Bechtel resolved this condition by requiring the combination of peak stresses within the piping system in a conservative manner.
l The resulting additional or clarified technical requirements were incorporated into PED-023 (Guidelines For Pipe Stress Analysis and Support Design).
The EA team reviewed additional calculations and the revised procedure during the verification process and is satisfied that the program is adequate'to ensure successful completion of the ASME III Class-1 pipe stress analysis effort.
The assessment of ASME III Class 2 and 3 pipe stress -
analysis identified some technical concerns that are listed belov vith their resolutions: l 22 -
i l
l g - - ,, - ~r - -
- The assessment concluded that no effective program existed to identify and track preliminary design inputs and assumptions requiring confirmation. This included calculated nozzle loads that exceeded vendor allowables and consequently required approval.
(Action items 83-3-23 and 83-3-27)
The response to this concern was comprehensive. Pipe
-stress and support calculations were completely.
reviewed to identify preliminary information requiring confirmation.
l PED-023 was revised to provide additional direction regarding identification of items that require confirmation or finalization in cr.lculations.
Related attributes were incorpora.ted into the PED calculation checklist.
In the revised PED, Bechtel established a computerized open items list (OIL) to monitor outstanding items pertaining to each calculation.
Once this was initiated, Bechtel effectively used the OIL as an administrative tool to ensure that new-commitments that could potentially affect a calculation vere considered when the calculation was to be revised.
During verification, the EA team reviewed the new s procedure, a sample set of calculations, and the related OILS and is satisfied that the program is.
successfully controlling confirmation of open items.
- Examples of technical concerns identified during the assessment are the misapplication of stress 23
~ _ _
intensification factors (SIFs) to various piping fittings and connections and the lack of documentation that jet impingement loads on piping had been evaluated. (Action items 83-3-30 and 83-3-32)
In order to address these issues, Bechtel reviewed the application of SIFs in the stress calculations and identified inappropriate SIFs in the OIL for correction during the next revision of the calculations.
i For recurrence control, Bechtel revised its piping stress analysis criteria (PSAC), PED, and the pipe stress analysis checklist to give analysts additional guidance.
l To show that jet impingement loads are considered 1 whsn applicable, Bechtel identified jet impingement loads as an open item in the OIL for each calculation, pending completion of the analysis that generates jet impingement loads.
The EA team reviewed the procedures revised to address technical concerns raised during the assessment, such as application of SIFs and jet impingement load documentation, and a sample set of calculations pertaining to each technical concern and is satisfied that the issues raised have been fully resolved.
- The assessment also identified a weakness in the method of defining systems design input information such as pressures, temperatures, and transient l 24
~
. pressure / temperature profiles. Bechtel strengthened this aspect of its design effort by issuing PED-022-(System Design Data Packages for Stress Analysis),
. requiring the mechanical and nuclear disciplines to develop system design data packages for use by the pipe stress discipline in performing pipe stress analysis for ASME III lines. (Action item 83-3-26)'
The EA team reviewed PED-022, the~ schedule for issuing system design data packages, and several design data packages and associated calculations and is satisfied that system design input is being properly defined and controlled. .The content of these system design data packages was reviewed in subsequent assessments.
- Discrepancies were discovered between the pipe stress analysis and the function, location, or stiffness of pipe supports. (Action item 83-3-31) l As a result of this corcern, Bechtel revised PED-023 to designate a consistent criterion as the basis for i
.; approval of pipe support deviation requests.- The PED
~
! also requires deviation requests to be tracked
- against the affected stress calculation in the OIL.
j The EA team reviewed PED-023, the OIL, a sample set
- of pipe support deviation request forms, and affected pipe stress analysis calculations and is satisfied that pipe support deviations from the as-analyzed i j locations are properly approved and controlled in a manner that permits straightforward reconciliation of stress calculations.
25 1 i l
- Another concern raised during the assessment was the large number of administrative items identified in the calculations, such as incomplete preprinted and illegible pages and the lack of explicitly-stated conclusions. (Action item 83-3-22)
Bechtel addressed this issue by formalizing and expanding the pipe stress and support calculations forms, as well as the calculation checklist contained in PED-023. Bechtel conducted training lectures on calculation preparation and checking, emphasizing the items identified during the assessment.
The EA team reviewed many calculations during the verification process and is satisfied that the calculations are being performed and checked in a thorough manner.
2.3.3 conclusions Based on the assessments, the STP response, and verification of the project commitments, the EA team has concluded that the overall design process for piping analysis is adequate to ensure that ASME III class 1, 2, and 3 piping vill meet applicable design code requirements and licensing commitments.
2.4 ASME III pipe sup' port design Third-party Design Assessment 84-3 2.4.1 Purpose and scope The objective of this assessment was to evaluate the technical adequacy of the design cf piping supports and 26
pipe support design methods as well as the process of' controlling the interdisciplinary activities in this area. The pipe support design was also evaluated for compliance with licensing commitments.
4 The scope' covered ASME III Class 2 and 3 piping system-supports. The reviev was completed using a representative sample of pipe supports used on the residual heat removal / safety injection system, to produce continuity with the pipe stress analysis assessment (83-3).
Consideration was.given to the complexity of the support, support type,. function, impact on pipe stress analysis, importance to protection of equipment, supports susceptible to installation problems, and pipe support stiffness.
2.4.2 Assessment In the review of pipe support calculations, criteria, specifications, and implementing procedures, the assessment fr..nd that, overall, the pipe support design was consistent with ASME Code design rules and STP licensing commitments.
The noteworthy action' items and their resolutions follow:
- Some technical concerns were identified relating to the support installation tolerance requirements l
(e.g., tolerances for clamp bearing, veld transverse relocation tolerance, and pipe-undersupport gap).
(Action items'84-3-9, 84-3-10, and 84-3-11) 27 l
. - - , . - r - ----y.. , - e w - , , . . . - - --
- - , , -r
= . . . ._ . - - .
4 d
4 Bechtel evaluated each issue raised, either. clarified the. tolerance requirements or designated specific allowable clearances in the pipe support field fabrication and installation specification, and initiated a complete reinspection of all affected pipe supports to the revised specification requirements.
- FSAR amendment 41 included a reference-to'ASME III,
! Summer 1979 Addenda, for pipe stress. analysis; however, no specific references for pipe supports.
] vere made. -(Action item 84-3-21) j
- The concern was resolved by an FSAR change notice stating the code edition and addenda for pipe i
1 supports. The EA team verified that the FASR. change reflected the correct speicification' requirement.
- The method by which the civil / structural group was notified of pipe support loads did not require positive communication regarding load acceptability.
(Action items 84-3-24 and 84-3-26)
Bechtel addressed this concern by upgrading PED-027, the civil / structural directive for the review of pipe support drawings, to require the civil / structural-approved interface load sheet to be included in all pipe support design calculations before they are issued as final.
- The assessment identified several calculations in-which'the veld used to qualify all other velds was l
not governing, a condition attributed to an i
- .i 28 l l
l 1
unverified assumption during the design process.
(Action item 84-3-28)
In response to this concern, a pipe support reviev team was established, which evaluated all 1
previously-issued calculations to assure'that the pipe support veld selected as the governing veld configuration actually enveloped the remaining veld
- designs.
All pipe support design personnel were trained in qualification of pipe support velds. A dedicated PSSG review team was formed to evaluate all future designs for this attribute as well as the other essential aspects of the pipe support design listed on the review team checklist.
L 4 2.4.3 Conclusions Based on the assessment, the STP response, and i verification of the response, the EA team has concluded that the overall design process,-including the control j of related interdisciplinary activities for ASME III pipe support systems, will meet applicable design code requirements and licensing commitments.
2.5 Containment pressure / temperature / radiation analysis Third-party Design Assessment 84-1 i
2.5.1 Purpose and scope i
4 The objective of this assessment was to evaluate the technical adequacy of the containment analysis for pressure, temperature, and radiation dose parameters 29
-my 4-+e v -ry - w w -- w -+p-t- w=e-. i -r + e-e' -a -
e v- - - - - -w--p" - .
for systems and equipment located within the containment.
The scope of the review included the containment temperature / pressure calculations performed by Bechtel, selected calculations that yield plant-specific input or support the containment analysis (such as free volume, heat sinks, and design specifications for major components such as heat exchangers and fan coolers),
and the Westinghouse design interface information used as input to its containment design calculations.
Review of the containment radiation dose analysis included airborne, plate-out, and liquid gamma and beta dose calculations for equipment qualification. As a confirmatory measure, SWEC performed an independent beta and gamma dose calculation for one case in the containment building. In addition, referenced supporting calculations were reviewed for consistency of information.
2.5.2 Assessment In the review of the containment analysis for pressure, temperature, and radiation dose parameters, the assessment found the containment analysis technically adequate and the supporting calculation information consistent. Analysis methods, assumptions, and documentation are consistent with STP licensing commitments.
The noteworthy action items and their resolutions were:
30
{ - The calculations reviewed contained discrepancies in
. identification of design-basis parameters requiring-confirmation, which led to a concern regarding control of confirmation of open-items. (Action item
! 84-1-2)
In. response to this concern, Bechtel reviewed project calculations. Those that contained open items.or items requiring confirmation were specifically identified within the body of the calculation and-were reclassified as " committed"; an auditable i
calculation log was used to control the closeout of these items and achieve a " final" status for calculations.
Bechtel revised EDP 4.37 (design calculation.
processing requirements) to incorporate the new calculation control guidance.
J
- The calculation for net positive suction head (NPSH) of containment spray pumps during recirculation calculation did not include pump can losses in the
~
I available NPSH determination.'(Action items 84-1-4 and 84-1-6) i i
! The calculation was revised during the' verification process to include a two-foot allowance for pump can j head losses, in addition to the NPSH requirements of VNES and the pump vendor. The emergency core cooling I system pumps NPSH calculation, which was similar, was revised in the same manner.-
The EA team has reviewed the new calculations and is A
satisfied that the containment design vill provide 31 1
adequate NPSH to the containment spray pump under the limiting design conditions.
2.5.3 Conclusions Based on the assessment, the STP response, and verification of the response, the EA team has concluded that the containment analysis for pressure, temperature, and radiation dose parameters is a technically-adequate basis for the containment design.
The major design of systems and equipment within the containment is technically adequate to allow them to perform their design functions.
The EA team has also concluded that the current design process, including the project procedure for control of design calculations, is adequate to ensure that the containment design vill meet licensing commitments.
2.6 Equipment qualification Independent Technical Assessment 84-2 2.6.1 Purpose and scope The objective of this assessment was to evaluate the adequacy of the STP equipment qualification program and to determine if the program met the requirements of IEEE Standards 323 and 344, Regulatory Guides, and/or other NRC guidelines. The scope of the review included-balance-of-plant safety-related equipment.
The assessment focused primarily on the methodolcay used to qualify selected safety-related equipment to meet applicable industry standards and regulatory 32
requirements. In addition, the following items were i
reviewed in light of the total equipment qualification program:
- Identification of safety class equipment needed to achieve safe shutdown
- Methodology used to derive the service environment'to which the safety-related equipment is exposed during normal and accident conditions
- Conformance of the equipment qualification plan for the selected equipment to the appropriate licensing commitment
- Adequacy of post-accident operability period as specified in the equipment qualification program
- Installation drawing, to verify that equipment mounting during type test is representative of actual or proposed installation
- Content of seismic and environmental qualification central file to determine its adequacy 2.6.2 Assessment The assessment found that, in general, the equipment
, qualification program was acceptable to meet the stated project commitments. The assessment focus ed on the design criteria and equipment qualification plans for-selected equipment. The equipment qualification plan was reviewed to determine whether:
l 33
- Design documents contain proper design inputs consistent with established criteria and commitments
- Equipment as designed is capable of performing its design safety functions under all normal, abnormal, accident, and post-accident environments and~for the length of time for which its function is required
- The criteria for qualification, methodology (i.e.
test or analysis), and considerations in defining seismic and other relevant dynamic load input motions have been properly established
- Methods and procedures, including tests and analyses, used to assure that structural integrity and operability of mechanical and electrical. equipment in the event of a safety shutdown earthquake (SSE),
after a number of postulated occurrences of the operating basis earthquake (0BE) and in combination with other relevant dynamic and static loads, are adequate
- Methods and procedures for analysis or testing of supports for safety-related equipment and procedures used to account for possible amplification of vibratory motion (amplitude and frequency content) under seismic and dynamic conditions are adequate Noteworthy action items and their resolutions are discussed below:
FSAR Table 8.3-3, " Emergency Electrical Loading Requirements," was found to differ in content from i the standby diesel generator specification (MS0034) 34 l
L
.1
and from calculation EC5017 for emergency electrical-load requirements. (Action item 84-2-1)
To resolve the concern, the FSAR and specification were updated for consistency with vendor step-loading.
test data. The calculation was voided, as it was superseded by the vendor test data report. The design was determined to be adequate and the concern limited to consistency.
- The containment spray pH centrol was identified as potentially inadequate. Variations in flow from a i
caustic addition tank to an eductor could cause containment spray pH transients outside the range to which safety-related equipment inside containment was being qualified. (Action item 84-2-4)
Subsequent system review by the project and Vestinghouse shoved that the containment spray pH vould remain within the design range without caustic addition; the caustic addition tank vas deleted from the design.
. - A radiation transport calculation, performed to establish radiation values outside containment resulting from radiation streaming through containment penetrations, used an incorrect computer code, resulting in a conservative but unreasonable dose calculation for the isolation valve cubicle.
(Action item 84-2-8) l l
To resolve the concern, the calculation was revised ;
using the proper code. The levels of radiation vere low when compared to the level of radiation used in 35 l
l 1
~- - - . . ... , . .
equipment qualification. A review of project radiation dose calculations showed that this use of the radiation transport procedure was an isolated case.
l: - A review of equipment specifications and engineering
- documents showed inconsistent use of the room locations / environmental designators required by l
project procedure. This limited the ability to f
establish or identify specific environmental requirements for safety-related equipment. (Action items 84-2-18 and 84-2-27) 1 j Corrective action by Bechtel included revision of l instrument and equipment lists'to define specific 1
locations of equipment. Bulk material such as j- gaskets, lubricants, sealants, etc., was being-j reviewed for seismic and environmental adequacy with j specification revisions to exclude material from j
applications where material suitability could'not be d
i demonstrated. Confidence in this procedure was l established by random sampling and review of l qualification documents for equipment and materials used in safety-related systems.
4
- Several safety-related equipment specifications did not identify the requirement for National Bureau of Standards (NBS) traceability for calibration of test equipment used in the equipment qualification tests.
(Action item 84-2-32)
I These cases were resolved by obtaining the required i
NBS traceability from the vendor or by repeating the test utilizing NBS-traceable equipment. The I
- 36 t
- _. _ _ . _ ~ - _ _ , _ _ , . _ , - _ _ _
requirement for documentation of NBS traceability was formalized in the project equipment qualification checklist, and the EA-team confirmed the implementation of this requirement by randomly sampling E0 packages.
- Criteria for application of electrical conduit seal assemblies (ECSAs) was not formalized, resulting in inconsistent application of these devices. .(Action item 84-2-40)
The environmental design criteria document was revised to define the requirement for.ECSAs to ensure i that they are specified in cases where an instrument was qualified with an ECSA and the device is located i in a harsh environment.
. - Because of a shared process tap, non-qualified instrumentation was found to have the_ potential to degrade the function of safety-related instruments.
(Action item 84-2-42) 4 To resolve this concern, Bechtel documented instrument environmental and seismic adequacy, or in some cases, shoved by analysis that the failure of I the non-qualified component would not adversely l
l affect the system function required for safe shutdown.
. 2.6.3 Conclusions Based on the assessment, the STP response, and verification of the project commitments, the EA team i
has concluded that the equipment qualification program
, is adequate and complies with licensing commitments.
37
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2.7 Separation and fire protection criteria Independent Technical Assessment 84-4 2.7.1 Purpose and scope The objective of this assessment was to evaluate the technical adequacy of (1) the fire protection and detection features to protect the plant capability to-achieve and maintain safe shutdown under postulated' fire conditions and (2) fluid system layouts and separation of redundant electrical raceways to provide for availability of components and systems required to
. shot the plant down safely under postulated fire conditions.
The assessment concentrated on the following aspects of plant design:
- The fire protection water supply subsystem,;to confirm that a single failure would not prevent at least one of the redundant water supplies from functioning
- The capability of the fire protection system to deliver water from manual hose stations to areas containing safe shutdown equipment
- The method and location of the fire detection system alarm and annunciation plus the type of power supply i provided for the fire detection system
- Documentation necessary to confirm.the systems and components within each system required to achieve and 38
4 maintain safe shutdown conditions as required by 10CFR50 Appendix R
- Provisions made to physically separate redundant safety division components and raceways, such as I barriers, and the method used to qualify fire i barriers 1
- Plant design features for removing products of f combustion from safety-related equipment areas
- Operator actions required for safe shutdown, including those required to terminate spurious actions resulting from the fire t
}
- Coordination of circuit protective devices l 2.7.2 Assessment In the review of separation and fire protection criteria calculations, drawings, specifications, i
analyses, and implementing procedures, the assessment found that (1) the fluid system layouts and electrical separation of redundant raceways provide for the i
availability of components and systems required to shut
- the plant down safely under fire conditions and (2) the fire protection and detection features were adequate to protect that capability.
The separation and fire protection criteria vere found to be consistent with STP licensing commitments.
39 i
The noteworthy action items and their resolutions were:-
- Some technical issues associated with the. smoke removal methodology were not addressed: replacement air volume / source, fan motor power source, and availability of ducts / fans. (Action items 84-4-4 and 84-4-5)
STP Enginscring, the responsible design organization for this effort, performed a comprehensive study, addressing each of the technical issues identified.
The EA team reviewed the preliminary study and is satisfied that the smoke removal methodology supporting analysis addresses the relevant technical issues.
- Spurious action evaluation (1) did not consider the possible adverse effects of spurious actions that could occur even af ter the diesel generator sequencer panel was de-energfzed and (2) required operators to reenter the postulated fire area a short time after detection of the fire to perform functions manually in order to mitigate possible spurious actions and complete the safe shutdown of the plant. (Action item 84-4-10)
As part of its continuing development of the fire protection analysis, Bechtel added a requirement to protect the viring associated with the affected
~~
diesel sequencer panel circuits. .The following design considerations were imposed on the analysis (1) No operator action in a fire area vill be required sooner than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the fire; (2) the analysis shall state the basis for assuming 40
mechanical operability of components in the postulated fire area to be operated post-fire; (3) the analysis shall confirm the plant's ability to sustain the postulated spurious operation until mitigating operator action can be taken.
The EA team reviewed the updated analysis and is satisfied that it has properly addressed the technical issues and identified plant protection requirements.
- No methodology had been developed to evaluate design changes issued after the analysis data base was established or to reconcile differences between Unit 1 and Unit 2 plant designs. (Action item 84-4-5)
Bechtel issued PED-041 to provide a method for assuring that changes made subsequent to completion of the fire protection analysis data base would be evaluated to determine if revisions to the analysis are required to maintain its validity. Bechtel committed to revise PED-041 to address design-differences between Unit 1 and Unit 2 and the effects on the Fire Hazards Analysis Report.
The EA team reviewed the design reconciliation effort and design control procedures and is satisfied that with implementation of the revised PED-041 the fire protection analysis vill reflect actual design.
2.7.3 Conclusions Based on the assessment, the STP response, and Engineering Assurance Department verification of 41
project commitments, the EA team has concluded that separation and fire protection criteria, the supporting analysis, and implementing procedures are adequate to meet regulatory requirements, codes, and STP licensing
- commitments.
2.8 Control room HVAC system Third-party Design Assessment 85-1 2.8.1 Purpose and scope The objective of this assessment was to independently verify (1) the technical adequacy of the system design to heat, ventilate, and air condition the control room under normal and accident conditions and (2) conformance of the system to STP licensing commitments.
- The assessment focused on determining the technical adequacy of the following aspects of the control room HVAC designs (1) supporting systems (electrical system and I&C associated with the control room HVAC system) and (2) interfacing systems (essential chilled water system, essential cooling water system, potable _ vater 4
system, fire protection system, halon system, control room isolation requirements, and single failure design).
2.8.2 Assessment In the review of the control room HVAC system, including the suppcrting and interfacing systems, the assessment t'ound that, overall, the control room HVAC system design and the design processes used to 4
42
- - . - -_= - ~ . , . _ . - _,. , _ . , ,,. . . . e -- -
implement it were technically adequate and consistent with STP licensing commitments.
The noteworthy action items and their resolutions were:
- FSAR Table 6.5-1, " Comparison of ESF Filter System with Reg. Guide 1.52," did not address Reg. Guide
, items 2I and 2L. Additionally, the comparison with
, item 2J was listed as item 2I. (Action item 85-1-1)
To resolve this concern, the FSAR was revised, correcting the inaccurate comparison with Reg. Guide 1.52 item 2J. The missing comparison with items 2I and 2L was then completed to correspond with the design.
- PSAR Table 9.4-2.1, " Design Data for Control Room, Electrical Auxiliary Building (EAB) and TSC HVAC System," showed some fan speeds based on the motor data fan curves under operating conditions, while others showed synchronous speed. (Action item 85-1-3)
).
This inconsistency was caused by a misunderstanding of which horsepower value was required in the table.
The table was revised to consistently show motor synchronous speed, and engineering personnel vere.
! trained on the subject. This resolved the concern.
I a
) - Non-qualified electric duct heaters, unit heaters,
! and associated controls equipment served areas with
- safety-related HVAC and equipment. The effect of the failure of these heaters to shut off or to be 43 l
i l
i l
energized as a result of a common mode event had not been considered in the design of the safety-related HVAC system. (Action items 85-1-9 and 85-1-72) f To resolve this concern Bechtel performed an analysis of the affected areas and determined that duct I heaters serving the relay rooms could be permanently disconnected. In this case, Bechtel revised the design, permanently disabling these duct heaters.
Unit heaters are nov seasonally shut down. Duct heaters serving the control room were shown to be capable of being manually de-energized before the space ambient temperature could exceed the equipment qualification design temperature. The FSAR was revised to clarify the design with respect to the classification of equipment used in the failure modes analysis.
- Smoke and toxic gas detectors were identified as Class 1E in the FSAR, when in fact these devices are not commercially available with certification to other than mine safety and Underwriters Laboratory standards. (Action items 85-1-4, 85-1-42, and 85-1-62)
The FSAR was revised to clarify this point, resolving the concern.
- The control room breathing air system required by Reg. Guide 1.78 was not adequately described in the FSAR, nor was system design information available to I substantiate compliance with the Reg. Guide. (Action item 85-1-5) 44
To resolve this concern, a description of the breathing air system was established, defining its type (self-contained breathing apparatus),
quantities, spares, and locations for storage to meet the Reg. Guide requirement. The FSAR was also revised to reflect this design in section 6,
" Habitability Systems."
- A chiller control circuit was found to contain extra l contacts that performed no function but further complicated the circuit. (Action item 85-1-67)
This concern was resolved by deletion of the contact from the circuit.
- Consideration of voltage drop in control circuits based on actual cable length was not included in the cable sizing calculation. This attribute is important because voltage drop from long control cables where combined with degraded bus voltage conditions may jeopardize operation of some safety-related equipment. (Action item 85-1-10)
To resolve this concern Bechtel provided a calculation for voltage drop based on actual cable icngth. The EA team reviewed the calculation and is saticfied that the cable-sizing calculation reflects actual plant design.
- Large-bore non-safety class potable water piping was installed in the relay room and control room envelope and had neither seismic supports nor restraints. In addition, the floors in the relay room and control 45
room envelope did not have floor drains. No spray or flooding analysis had been performed to justify the design. (Action item 85-1-55)
The EA team verified inclusion of both flooding and spray analyses for these lines in the hazards analysis work list. The hazards walkdown was also found to be an integral part of the II/I seismic support design effort.
f 2.8.3 Conclusions 1
}
Based on the assessment, the STP response, and Engineering Assurance Department verification of l project commitments, the EA team has concluded that the i design of the control room HVAC system and its supporting and interfacing systems is technically adequate and meets applicable code requirements and STP licensing commitments.
2.9 Component cooling water system i Independent Technical Assessment 85-2 and supplement 1
i 2.9.1 Purpose and scope The objective of this assessment was to independently verify the technical adequacy of the system design to cool safety- and non-safety-related auxiliary system components under various plant operating conditions and to verify that the system design conforms to STP ,
licensing commitments. !
46
-- , , . , , ., , - . , . , . . . , - - - , . . . , - - - -, - , , - , - , ,.----,------.----..,,---n. - - - - , - ,-
The assessment focused on determining the technical adequacy of the following aspects of the component cooling water (CCW) system design
- Systen functional requirements to provide for heat removal from the specified auxiliary systems components during design basis accident and non-accident plant conditions
- Compliance with ASME Code classification criteria in the specification of component and system safety-related boundaries
- Mechanical and electrical separation requirements to permit the CCW system to accomplish its safety functions, given a single failure of any one mechanical or electrical component
- System safety /non-safety and engineered safety features (ESF)/non-ESF isolation design to isolate the non-safety /non-ESP portions of the system when required
- System layout and general arrangement to accommodate design requirements such as pump net positive suction head, surge tank capacity for fluid contraction and expansion, component allowable nozzle loads, and appropriate location of system instrumentation in areas with compatible environmental conditions
- Interfacing support systems (e.g., electrical, control, instrumentation, flVAC, and pipe supports) to l
meet CCV system design requirements j 47 l
._ ._ _ _ ~ ,
t i
- - Radiation monitoring of the system to permit
- individual and multiple-train monitoring
- The design change process to control design changes
! in the field and in the home office in the same manner (i.e. same levels of approval) as for the original design and to require due consideration of the impact of proposed changes on other parts of the system or on other areas of the plant 2.9.2 Assessment ,
}
In the review of CCW system design drawings, calculations, criteria, specifications, and implementing procedures, the assessment found that,
[ overall, the CCW system design and the design processes used to implement the design vere technically adequate and consistent with STP licensing commitments.
1 l
i The noteworthy action items and their resolutions were l
- The CCW surge tank design calculation did not contain the most limiting condition for thermal expansion vithin the tank. In addition, the surge tank relief valve (associated with the nitrogen blanket design i feature) design calculation used an overly-simplified assumption concerning design pressure without considering the effect of relief valve pressure on
]
CCW system pressure under the limiting conditions for the system. (Action items 85-2-4, 85-2-9, and 85-2-11)
! 48 '
I l
I
_ _ _ - - - , . . _ . , . . _ . . _ . . , , . - . _ . - - . _ . . . _ _ _ . , _ . _ _ . _ - - . . . . _ . . . , _ _ - . . ,. .m.~... . _ _ _ . . .
Bechtel addressed the various concerns regarding the CCV surge tank and system pressure by consolidating several calculations and performing a complete surge tank design calculation, with full consideration given to its effect on the rest of the CCV system.
At the same time, an unrelated decision regarding the corrosion inhibitor to be used resulted in elimination of the surge tank nitrogen blanket and relief valve, replaced by a 4-inch overflow pipe.
The EA team reviewed the calculations and is satisfied that the CCV surge tank and system calculations properly demonstrate the adequacy of system design. As part of assessment 85-1 on the control roon HVAC system (Section 2.8), the EA team reviewed the other safety-related closed-loop cooling system but did not identify similar findings.
- Several calculations contained references and assumptions that were incomplete or not current.
(Action item 85-2-12)
Bechtel revised the calculations in which concerns were identified. In addition, the mechanical discipline developed an open item tracking system to collect minor changes affecting calculations, pending calculation revision. By the time this assessment was complete, Bechtel had extensively revised its procedures regarding control of design calculations.
Design calculations were classified according to the state of design completion (preliminary, committed, and final); EDP 4.37, Design Calculations, then required calculations to achieve a status of " final." l 49 l
- - - -_. - - - - .-- -- _- =. . -_ , . .
As a further measure, Bechtel issued PED-042 to identify and require for those calculations not otherwise proven to be " final" (such as by startup
, test) a review of calculation assumptions, references, results, and conclusions to assure that s
the calculation reflects actual plant design.
7
- The CCW pumps low-lov surge tank-level and lov flov 4
trip functions were initiated by non-qualified i
equipment, without an analysis to demonstrate that j the safety system would not be adversely affected.
l The system design relied on the surge tank level trip l to protect the pumps from cavitating or running dry 1'
and the lov flow trip to prevent pump operation with i less than vendor-required minimum flow. (Action l items 85-2-46, 85-2-63, and 85-2-67)
I I
d In the process of resolving these concerns, Bechtel '
determined that the circuits could not be upgraded due to lack of separation from non-lE cable.
l Consequently, the automatic trip features were l disabled to prevent a possible common-mode failure 1
from tripping all CCV pumps. Trip of a pump on i
j low-lov surge tank level or low flow now relies on
! operator action, aided by safety-grade alarms. The
satisfied that no credible single failure could cause
- loss of more than one CCV pump due to piping rupture or other system leakage. l 1
1 I
1
)
50 i
t
--..,.._...-,~.,,_._,_.,__._,,_m-mm.,,._m-. .,, ,,,m .m, m c,,,- - . _ , . . .,g, ,,,,.,,,,~.,.,,_,--.m._..-,e,.cr. , - - . .
i I
- Sleeve clearances were not being systematically evaluated by the appropriate disciplines. (Action item 85-2-45) 1 i Bechtel resolved this concern by revising PED-023
- (Guidelines for Pipe Stress Analysis and Support Design) to require positive communication regarding sleeve clearance information between the pipe stress and support group and the affected disciplines. The EA team has reviewed the PgD and a sample of revised i calculations and is satisfied that adequate sleeve i clearance is being achieved. ,
i I In the review of CCV system design change documents 1
! generated in the field, the assessment found that, ,
overall, field design changes and the implementing f, procedures were technically adequate and consistent i with STP licensing commitments.
] The noteworthy action items and their resolutions were:
I 3
l - Technical justification was not required for changes
! issued by Field Change Requests (FCRs). (Action
! items 85-2S-1) l l
} As an enhancement to the design change control i
j program and to facilitate understanding of the plant l design basis by HL&P, Bechtel revised its FCR procedure to require identification of any design calculations affected by the change or performed in I support of the change. In e.ddition, the procedure [
l now requires documentation of technical justification f for changes to a safety-related specification.
I 51 l
)
i
_- ~ _ . . -. . , . - . . ._
5 3
- In some cases, FCR dispositions were not coordinated with all disciplines that had the potential to be l affected by the proposed design change. (Action item 85-2S-2) t In order to resolve this concern, Bechtel included in
)
i, the revised FCR procedure a requirement for
! interfacing disciplines to document their review of i
proposed design changes on the FCR.
The EA team reviewed the revised procedures and is satisfied that the field design change control l
program is adequate to meet STP licensing commitments.
d 2.9.3 Conclusions i
l
! Based on the assessment, the STP response, and f Engineering Assurance Department verification of the
- response, the EA team has concluded that the design of the component cooling water system and the implementing
- l. procedures are adequate to meet applicable code l requirements and STP licensing commitments.
l l 2.10 Off-site and medium-voltage AC power supply systems !
Independent Technical Assessment 85-3
- i 2.10.1 Purpose and scope The objective of this assessment was to evaluate the technical adequacy of the off-site and medium voltage
-i AC power supply system design.
i i
i 1 52 4
i The assessment of the off-site AC power supply system reviewed adequacy of the two preferred power supplies from the grid, including switchyard breakers and transformers used to supply preferred power to the '
station services from distant sources.
The assessment of the medium-voltage AC power supply system also evaluated the adequacy of the 13.8-kv and 4.16-kv auxiliary power supply systems, with special emphasis on the 4.16-kv Class lE power supply system.
Additionally, the independence and redundancy of the 4.16-kv Class lE AC power supply system, including on-site standby power sources and portions of the DC i supply system, were reviewed.
The primary focus of the assessment was on the following topics:
- Routing of transmission lines near the switchyard, to verify that at least two independent circuits from the off-site grid to the on-site distribution buses are provided and that a single event will not i eliminate both circuits Electrical schematics of the switchyard breaker ,
control system, power supply to the breakers, and breaker arrangement, to determine that no possibility exists for simultaneous failure of both preferred circuits from a single event 53
r l
l
- The adequacy of the surge arrestors for the l
switchyard and for the main, standby, unit auxiliary, l and emergency transformers
- The grounding method as well as the means of limiting ground current for the turbine generator and main transformers
- The type of status indicators located in the control room for the switchyard facility, as well as the control interlocks provided in the control room for safe operation of switchyard equipment
- The calculations for sizing switchyard circuit breakers, station main transformers, and other switchyard electrical equipment, including unit auxiliary transformer, standby transformer, and their secondary neutral grounding equipment
- The fault duty on the 13.8-kv and 4.16-kv buses, and selected 480-v load centers, under different plant loading conditions, as well as fault current at selected electrical penetrations
- Calculations performed for sizing 13.8-ky, 4.16-ky, and selected 480-v feeder cables; tests performed to derive the de-rating of feeder cable when wrapped with fire-retardant vraps and the applications of the flame-retardant vrap de-rating factors to derive the resultant feeder ampacity
- The control logic for transferring loads from one off-site source to the other and from normal source 54
to standby diesel generator, including diesel generator sequencer input and output logic
- Protective relaying for the switchyard and its interface with the plant protection systems also protection provided to safeguard motors and other equipment against continuous degraded voltage conditions and loss of voltage
- Melaying, including relay setting for backup protection for selected equipment supplying power inside containment suitability of relays for different functions in the medium- and low-voltage AC systems and selected devices in the DC systems, including settings 2.10.2 Assessment The assessment found that the off-site and medium-voltage AC power systems are adequate to meet project design commitments.
The assessment consisted of reviewing the established design criteria as well as existing design documents and performing alternate calculations as necessary.
Criteria established for the assessment were:
- Design documents contain proper design inputs consistent with established criteria and commitments.
- The system as designed is capable of performing its function under the conditions stipulated in the STP FSAI.
55
I
- Installation parameters of the system, structure, and components are clearly identified on pertinent design documents.
The noteworthy action items and their resolutions were:
- Two of the eight circuits connecting to the STP switchyard are installed such that the distance between two tower lines in one right-of-way is less than their height, creating a potential for interaction between them in the event of failure of one of the towers. This was contrary to the pertinent descriptive section in Chapter 8 of the FSAR. (Action item 85-3-1)
The concern was resolved by a stability analysis demonstrating that interaction between the affected towers vill not jeopardize the stability of the entire transmission system and that at least two other distant power sources are available. The FSAR has also been revised to clearly delineate the existing tower arrangement and the analysis results.
- FSAR sections 8.1 and 8.2 were noted to have minor inconsistencies with regard to the in-service dates of several 345-kv transmission lines. (Action item 85-3-4)
To resolve this concern, the FSAR electrical section text and figures were revised to be cor.sistent with the most current information, including the high-voltage DC line.
56
- PSAR section 8.1.4.1 (utility grid, design basis for off-site power) was noted to be inconsistent with section 8.2.1.1 (off-site power, transmission lines) in describing the effect on generation output caused by a loss of any independent right-of-way or outage of any two circuits. (Action item 85-3-5)
To resolve this concern, FSAR section 8.1.4.1 was revised to state that the loss of an independent right-of-vay may necessitate some reduction in generation output, making section 8.1.4.1 consistent with section 8.2.1.1.
- The FSAR section on substations (8.2.1.2) and the electrical bill of material stated that 2000-amp I
circuit switches are used to connect the 150-HVAR 4
reactors to the north and south buses. The purchase order for this equipment shows these switches to be rated at 1600 amps, which is adequate for the application but is inconsistent with the FSAR.
(Action item 85-3-6) 4 To resolve this concern, the FSAR and bill of materials were revised for consistency with the technically-correct material purchased.
- The FSAR switchyard and relaying one-line diagram (figure 8.2-3A) did not include relay KD3/Z2 on the primary and secondary of circuit 39, as described in the FSAR text and used on similar circuits 18, 27, and 44. Also, the FSAR text was found to be inconsistent with figure 8.2-3A on the types of relays for circuit 89. (Action item 85-3-8) i 57
To resolve the concern, FSAR figure 8.2-3A was revised to include relay KD3/22 in circuit 39, and the text was revised to show the correct protective relays in the figure for circuit 89. In both cases the actual design was correct, and the concern was limited to consistency within the FSAR.
- Various discrepancies were noted between descriptions
- of equipment on vendor drawings and the corresponding j
engineering documents. (Action item 85-3-30) l
- This concern was resolved by revision of project 1
i electrical drawings for consistency with the vendor drawing.
i
- - The FSAR was noted to be missing some applicable i '
l branch technical positions (BTFs) and general design 1 criteria. (Action items 85-3-9 and 85-3-39)
! This concern is considered minor, as the BTFs and general design criteria vere being applied. The FSAR was revised accordingly, l
- The FSAR description of the 4.16-kv electrical system protection rclays was inconsistent with viring drawings. (Action item 85-3-32)
To resolve this concern, the FSAR vas updated to delete the statements that vere inconsistent with the design drawingst the viring drawings were correct.
l l
a 58 l
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- The FSAR did not describe requirements to protect l safety-related circuits from pipe failure ha::ards and missile hazards, as required by general design criteria (GDC) 2 and 4. (Action item 85-3-35)
FSAR sections 8.3.1.4.4.8 and 8.3.1.4.4.9 vere 1
i revised to include a description of the design requirements being applied to protect safety-related circuits from pipe failure and missile hazards: the design requirements were adequate to meet the GDC requirements.
- Coincident (2 out of 3) logic for lov lube oil pressure trip of the diesel generator required by NRC l
Regulatory Guide 1.9 was not described in the FSAR.
(Action item 85-3-37)
To resolve this concern, the FSAR was revised to describe this feature. Appropriate changes were also made to logic diagrams to reflect the design shown on elementary viring diagrams.
- The FSAR text states that motor nameplate ratings were used in determining standby power source loadings however, FSAR table 8.3-3 gave motor horsepover ratings less than the nameplate rating.
(Action item 85-3-49)
To resolve this concern, FSAR section 8.3.1.1.4.2,
" Equipment Capacities and Loading Basis," vas revised to state that the loads were determined on the basis of motor brake horsepover ratings. The design documents were cortcet and the concern limited to inconsistencies in the FSAR.
59
- Calculated settings for overcurrent relays on 13.8-kv switchgear were based on incorrect connections to current-sensing devices (vye connected current transformers as opposed to delta). The result of this situation would be incorrect trip setpoints for such major equipment as the main transformer and 345-kv kreakers. (Action item 85-3-60)
This concern was resolved by revision of the setpoint calculation and corresponding setpoint list for these protective relays.
- The engineering requirements for minimum conduit bend radius were not defined in site installation procedures. This requirement was considered necessary to ensure that cable pulled would not have less than the minimum bend radius. (Action item 85-3-77)
To resolve this concern, the site procedure was revised to include the conduit minimum bend requirement.
- The re-sequencing start requirement of the essential chilled water chillers was not identified in FSAR table 8.3, " Emergency Electrical Loading Requirements." This is of importance because of time delays associated with chiller " auto start" operational modes. (Action item 85-3-81)
To resolve the concern, the PSAR was revised to reflect the re-sequencing start requirement. The 60
i l 4
effect of the time delays was considered in the
- loading sequence, although this was not stated in the i FSAR table. '
1 ;
l
- Several discrepancies between logic and elementary diagrams were noted. (Action itene 85-3-85, 85-3-90, 85-3-92, and 85-3-100) !
] In each case the incorrect document was revised to i resolve the specific concern. The general issue of i
) assuring document consistency is discussed in Section i j 3 of this report.
1 t i I l 2.10.3 Conclusions !
l I i Based on the assessment, the STP response, and
) subsequent verification of project commitments, the EA j team has concluded that the off-site and medium-voltage ,
- AC power supply systems are technically adequate to l meet applicable code requirements and STP licensing i i- commitments. i 1 !
i :
2.11 High energy line break analysis Third-party Design Assessment 85-4 2.11.1 Furpose and scope s .
The objective of this assessment was to verify that (1)
- in the event of postulated high and moderate energy I pipe failures, protection is adequate to prevent i l
adverse effects on essential structures, systems, and >
1 4
components and (2) the plant can safely be shut down.
I !
l l 1 i t
i I
i 61 :
} !
1 1
This assessment focused on portions of nuclear safety-related systems located in the isolation valve !
cubicle (IVC) building and in cubicles B and C of the ,
reactor containment building. Fostulated high energy pipe breaks were evaluated to verify that required plant safety functions were maintained following a high energy line break postulated in conjunction with a single active failure and loss of off-site power. The t assessment focused on the following topics:
^
- Licensing commitments FSAR commitments that establish the general design [
snd acceptance criteria applicable to all high energy ;
line break analysis / moderate energy line crack i
analysis (MLBA/MgLCA) activities l i
The design and analysis process, to verify conformance of the detailed work to the established licensing commitments
- Pipe break postulation Implementation of the criteria governing postulated ,
high energy pipe breaks, to determine the proper selection of pipe break location and orientation j The criteria and methodology used to meet FSAR ;
requirements for establishing the break exclusion f sone !
t 62 6
i f
- Target identification Zones of influence of postulated pipe whip and jet impingement, for interaction with safety-related structures, systems, and components; movement of the jet centerline due to unrestrained pipe movement Methodology used to identify safety-related equipment, piping, conduit, tubing, and cable tray as potential targets of pipe whip or jet impingement
- Safe-shutdown analysis The methodology by which systems and components, including instruments, were evaluated for the consequence of postulated high energy pipe breaks on the plant ability to achieve safe shutdown Those essential systems, structures, and components targeted by pipe whip / jet impingement, to verify that they were identified for qualification against the effects of pipo whip / jet impingement loadings or vere protected by virtue of relocation or by proposed pipe rupture restraints or jet impingement shields
- Qualification of essential equipment The methodology used to demonstrate adequacy of essential equipment subject to the mechanistic offacts of postulated piping failures, including an assessment of selected detailed calculations dealing with the offacts of unrestrained pipe whip impact and jet impingement ptennure and temperature within the detined zones of intluence 63
- Rupture restraint / jet impingement shield design The location and design of rupture restraint and/or jet shields, to verify the adequacy of protection, as well as the methodology used to determine jet thrust and impingement forces
- Interface / change control i
The control of interfaces between design disciplines and Vestinghouse, on a selective basis In addition, a field walkdown of selected areas, to evaluate the as-installed condition of commodities for consistency with the HELBA/MELCA programs 2.11.2 Assessment In general, the technical aspects of the HELBA/MELCA program (which include postulation of pipe break / crack, development of jet impingement and pipe whip zones of influence, calculation of jet impingement and pipe whip loading, and identification and qualification of objects of impact) vore found acceptable. Building design achieved physical separation between redundant mechanical and electrical / control systems. In the IVC, no safe-shutdown systems or components were identified as targets of postulated high energy lina breaks that required evaluation. The review also found that the detailed llELBA/MELCA calculations and STp verification valkdowns are being implemented in accordance with entablished design criteria and guidelines. ,
i At the time of this assessment, the STp llELBA procuss included regularly-ncheduled llRLBA coordination 64
l l
l meetings that produced continuity between various stages of the interdisciplinary activities.
l Subsequently, the process was revised to consolidate these efforts within a single group tepresenting all disciplines, with a full-time group supervisor. The EA team reviewed the revised process and confirmed that l formation of this group has resulted in a significant enhancement of interdisciplinary aspects of the HELBA process.
A large number of the concerns identified vere not considered significant, based upon additional clarification from STP and the minor nature of the corrective action required.
Several concerns involved inconsistencies between the FSAR and various design documents. A nus.ber of others involved drafting errors or minor inconsistencies between related documents. In a follow-up verification, the EA team verified that such problems were corrected and that the inconsistencies did not impact lower-tier design documents.
A few concerns identified involved clarification of PED-016 and justification of the technical basis for the acceptance criteria specified. To address this concern, Bechtel revised PED-016, and the EA team verified that it was acceptable.
The EA team also verified STP HELDA/HELCA valkdown results in selected areas by conducting a fleid walkdown, the results of which indicate general acceptability of IICLBA/MELCA valkdown activities.
65 1
Some discrepancies were noted in the implementation of
, PED-043-4 for the HELBA valkdown, involving some additional safety-related objects of impact that were not identified and a lack of justification for deleting other objects of impact. To enhance the HELBA valkdown program, STP committed to the following improvements:
(1) Specific reasons vill be recorded to substantiate 1
deletion of essential objects of impacts (2) all
.l
-l safety-related objects of impact not previously l identified vill be recorded on valkdown " addition sheets," even if the walkdown engineer knows by ;
f j
familiarity that they are nonessential, and the walkdown results evaluation vill verify and document their nonessential natures (3) STP will give walkdown i engineers more specific training to eliminate r
inconsistencies in identification of objects of impact.
The EA team considers these enhancements to the STP
]
HELBA valkdown program acceptable to eliminate the type
! of inconsistencies observed during verification.
I !
A discussion of noteworthy action items and their l resolutions follows:
I - The pressure stress term of ASME III Equation 9 was j not considered in the calculation of stresses in the break exclusion region for a pipe rupture event.
(Action item 85-4-22) i As a corrective measure, Bechtel revised the i
- calculations to include the full operating pressure i
j in the stress analysis of the break exclusion region.
l The EA team reviewed the revised calculations and confirmed that stressos between the isolation valve i
1 i l
and the penetration are still within ASME III allovable stress limits.
- PED-016 gave conflicting guidelines for the value of the dynamic load factor (DLF) associated with pipe l
l break loads. (Action item 85-4-45) l l
In reviewing this concern, Bechtel discovered that confusion relating to the requirements in PED-016 had led to misapplication of DLFs on pipe whip restraint structural steel members under compression loading.
As a corrective measure, Bechtel revised PED-016 to require confirmation of plastic behavior when ductility ratios are used to reduce the DLF belov 2.0. Bechtel also revised the affected civil / structural calculations. No changes were required in the structural member sizes as shown on the drawing. The verification found that the measures taken by Bechtel vere acceptable to address the issue and resolve the concern.
2.11.3 Conclusions Dased on the assessment, the STP response, and verification of project commitments, the EA team has concluded that the STP design is adequate to prevent adverse effects on essential structures, systems, and components and that the plant can be safely shut down, given a postulated high or medium energy pipe failure.
67 l _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - . . _ _ - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _
i 2.12 Field walkdowns l Independent Technical Assessment 86-1 1
2.12.1 Purpose and scope The objective of this assessment was to review specific items that arose in the review of design documents during earlier assessments and to evaluate specific design attributes that are easier to evaluate by observing as-installed conditions.
The field walkdown consisted of an assessment of the as-installed condition of selected equipment and components of previously-reviewed systems (e.g., CCV and control room HVAC) with regard to their consistency with the applicable design basis and licensing commitments.
The assessment focused primarily on the following topics:
- Seismic II/I interaction Seismic interaction between nonnuclear safety-related (NNS) systems (e.g., fire protection and drain piping) or structures and components (e.g.,
platforms, unit heaters, and lighting fixtures) and nuclear safety-related systems and components, to verify that design of NNS systems vould not jeopardize the functional and structural integrity of safety-related systems and components during seismic events 68
1
! In selected areas, physical arrangement of systems /
components, to determine the extent of compliance i with STP seismic II/I separation criteria l
Support of field-routed components such as instrumentation tubing, conduit, small valves, etc.,
i for interaction with safety-related systems
- Clearance check The as-constructed condition of selected systems and components, to verify that sufficient clearance exists between them to accommodate free movement during plant operating / design conditions
- Electrical separation cable routing and raceway arrangement for electrical components associated with the CVCS and CCW system, I to verify correspondence between the design and as-built conditions and to confirm that the sampled redundant electrical trains are physically separated l
from one another and from non-safety trains, per STP l
criteria l
t Panel internal viring, to verify that within the l cabinets each safety train is separated from other l safety trains and from non-safety trains, per STP l licensing commitments l
l l - Miscellaneous As-built locations of radiation detectors and the sample nozzles for the control room / technical support 69
- j. center outside air intake, to verify that the basis
- . for the control room isolation calculation (reviewed I
in assessment 85-1) had been maintained j Also (1) overall spatial configuration of piping,
- tubing, conduit, and cable trays, (2) function, location, and orientation of pipe supports, and (3) ;
i location and types of piping components, for consistency between as-constructed and design documents
- Moderate energy line crack analysis i Flooding calculations, to assess the criteria and i methodology used in determining the effects of postulated line cracks on flood levels in the MEAB and the IVC buildings 2.12.2 Assessment
- Based on the field walkdown, review of STP design basis documents, and the follow-up verification of STP commitments, the following conclusions were reached:
- Seismic II/I interaction In general, STP's seismic II/I design criteria and design guide PED-043-7 provide acceptable guidance for conduct of the seismic II/I review program.
- Approximately 40 separate rooms within the MEAB and diesel generator building vere sampled for potential seismic II/I interactions. Considering the total number of adequately supported / separated NNS 70
components viewed compared to the number of potential seismic II/I interactions recorded, the project's implementation of its stated seismic II/I design criteria is adequate.
With regard to the potential seismic II/I interactions recorded during the review, STP indicated that implementation of STP II/I seismic requirements was ongoing. The EA team performed additional walkdowns in areas where Bechtel had implemented the seismic II/I requirements.
Verification confirmed that Bechtel implementation of the seismic II/I interaction valkdown plan is adequate in the selected areas. Based on verification of the results of completed areas and
! the project commitment to perform seismic II/I walkdowns for the remaining areas, the EA team considers resolution of this issue acceptable.
- Clearance check The as-built reconciliation (ABR) program for safety-related piping states clear criteria for consideration of installed clearances between piping and its supports and all other commodities.
A field'valkdown of selected stress problems confirmed that STP implementation of the clearance criteria is adequate.
- Electrical separation In general, the STP electrical separation program as implemented by site engineering reflects FSAR 71
commitments, and the field documents reviewed clearly direct the construction forces. Except for a few minor items, panel internal wiring was found to be satisfactory.
During walkdown, liquid-tight flexible conduit jacketed with PVC was noted in use in the plant.
Since the spatial separation specified in IEEE 384-1974 is predicated on the basis that raceways are flame retardant, the basig for using PVC-jacketed flexible conduit was not apparent. In response, STP f
committed to perform a test to demonstrate the capability of the PVC-jacketed flexible conduit to meet separation requirements. In addition, during verification of assessment 84-4 (on separation and fire protection criteria), the EA team reviewed the combustible loading calculation to confirm that fire loading contributed by PVC flexible conduit was considered. Based on the Bechtel commitment to perform the test, as well as the verification of the combustible loading calculation, resolution of this issue is considered acceptable.
- Miscellaneous The ABR program for piping has two stages. All configurations reviewed were at Phase 1 (i.e. 80%
complete). The' piping layout for the selected systems was reviewed for overall spatial consistency with as-built drawings, and configurations were all found to be consistent. ,
l 72 l
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- - . - -,n - -r- , - - , , ,
e The control room HVAC isolation calculation and the installed duct configuration vere reviewed to compare as-built conditions to the assumed locations for radiation detector and sample nozzles indicated in the calculation. This review identified some minor concerns in (1) establishing proper design input / assumptions to define RVAC isolation time, (2) discrepancies between specification requirements and upstream design input calculations, and (3) inadequate dimensions for locating radiation ~ monitor sample nozzles.
As a corrective measure Bechtel revised the pertinent calculations and drawings, which the EA team subsequently verified to be adequate.
- Moderate energy line crack analysis Flooding calculations were reviewed for the MEAB and isolation valve cubicle areas. In most cases the calculations produced a well-defined and -documented analysis. In general, criteria and methods used were reasonable and technically justified. Minor inconsistencies and items requiring justification were identified. The clarification and follow-up justification by Bechtel vere determined to be acceptable.
The noteworthy action items are discussed below:
- The basis was not apparent for the 1-inch minimum clearance requirement between hot pipes and conduits to avoid exceeding the cable maximum temperature rating. (Action item 86-1-10) 73
t In response Bechtel performed heat transfer
- calculations to verify that the 1-inch spacing specified is, in most cases, adequate to keep the maximum cable temperature within its rating. For the reactor containment building only, the surface emissivity of non-jacketed insulated pipes is such that in some instances spacing of greater than 1 inch is required between conduit and hot pipe to limit the conductor temperature within its rating when pipe and conduit are run parallel to each other.
As a corrective measure, Bechtel revised the hot pipe separation drawing defining the new criteria and, through a valkdown, ensured compliance of all
! potential occurrences with this new criterion. The EA team reviewed the calculation that formed the
! basis for hot pipe separation as well as the corrective measure taken and is satisfied that plant hot-pipe-to-conduit clearances and the relevant.
criteria are adequate to maintain the design rating of cables routed in conduit near hot pipes.
- The basis was not apparent for designating the system safety-class boundary at the instrumentation root value for instrument lines connected to
! safety-related lines. (Action item 86-1-22) i In response Bechtel indicated that the instrument tubing is designed in accordance with the ANSI B31.1 code and supplementary seismic design provisions: (1) tubing is supported on approximately 3-foot spans by seismic supports; (2) flexibility is provided in the l
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tubing system fer piping movements, and (3) instrument and instrument valving are mounted on seismically-designed mounting structures.
Additionally, non-ASME flex hoses are rated at a substantially higher pressure than the system pressure and provided with sufficient flexibility to accommodate any piping movements expected during a seismic event. For further assurance that non-ASME flex hoses connected to ASME III process systems are acceptable for the applicable process piping displacements, Bechtel performed a 100% inspection of installed non-ASME flex hoses and revised the installation requirements of flexible hose to clarify the installation requirements. Regarding non-safety l instruments connected to a safety system, Bechtel demonstrated by analysis, test, and similarity to qualified instruments that non-safety instruments vill withstand the STP design seismic and environmental conditions or alternately demonstrated that their failure vould not jeopardize safety system function.
The EA team evaluated the basis for demonstrating pressure boundary integrity adequacy for non-safety instruments and the non-ASME-III instrument tubing system and is satisfied that this issue is appropriately resolved.
- A concern was identified regarding the structural integrity during a seismic event of the last tray rung of the cable trays. In particular, the basis was not apparent for the maximum free air length.of unsupported cable to be supported by the last tray rung. (Action items 86-1-29, 86-1-30, and 86-1-31) 75 i
1
In response, Bechtel revised the cable installation drawing, requiring additional cable supports keyed to actual cable size.
- In addition, a calculation was performed to verify that existing project requirements for cables leaving a cantilevered tray end would not cause an overload condition to occur. The calculation indicates that while the last tray rung may have some localized
, yielding, the corresponding deformation is still within the limits of the ductility ratio of p-10. On this basis, the EA team considers the resolution of this issue to be acceptable.
- A concern was identified regarding the use of PVC-jacketed liquid-tight flexible conduit in plant circuits where separation is required. This is inconsistent vith the FSAR commitment that states that only seamless flexible metal conduit vill be
)
allowed. (Action item 86-1-7) 4 In response to this concern, Bechtel revised the i
FSAR, deleting reference to use of only stainless steel seamless corrugated metal hose. In addition, liquid-tight flexible conduit has been added to the 4
list of raceway items considered acceptable as totally-enclosed racevay. On this basis, the EA team considers the resolution of this issue to be
- acceptable.
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n 2.12.3 Conclusions Based on the assessment, the STP response, and verification of project commitments, the EA team has concluded that the field-designed attributra reviewed were consistent with applicable design criteria and STP licensing commitments.
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l 3.0 Categorization and Analysis of Findings SWEC performed a comprehensive categorization and analysis of the action items stemming from the EA program assessments to determine if any generic weaknesses exist in the STP design or in the design process. .The SVEC categorization analysis results also contributed to HL&P's determination of whether the specific conclusions reached I
for the systems reviewed could justifiably be extended to the overall plant design.
1 The categorization and evaluation program initially involved approximately 1220 separate action items. Upon further reviev, 550 of these action items were determined to be invalid (i.e.~, items that, for various reasons, did not require any corrective or preventive actions), and another 116 vere editorial / administrative in nature and had no effect on the STP design or design process. This I
left 554 action items for further evaluation based on their potential significance with respect to the adequacy of the design of other STP systems and structures that were not reviewed as part of the EA program and the adequacy of the overall engineering and design process employed by STP. These action items were then sorted into various categories so that the type,19ause, and significance of the action items could be evaluated on a collective basis.
The EA program focused on review of the key design documents relating to the STP systems and design features included in the various
- technical assessments. Predictably, the categorization and 1
> evaluation program confirmed that the majority of action items involved the adequacy of documents, primarily calculations and diagrams.
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i As a result, most of the actions items fell into the " design document adequacy" category, the first of seven major categories into which action items were sorted. The mechanical and pipe stress and supports groups were the engineering disciplines that had the most action items involving calculations. The instrumentation and controls group had the most action items involving diagrams. This was expected, since most documents reviewed during the assessments were calculations and diagrams prepared by these groups.
The majority of design document deficiencies fell into two subcategories of the design document adequacy category; i.e.
miscellaneous design document errors and design documents that are not finalized or current. The most prevalent cause of the first type of deficiency appeared to be inadvertent error, while the latter appeared to result primarily because the documents involved were not updated on a timely basis.
Design document deficiencies of a more important technical nature, although fever in number,' included action items in the following design document adequacy subcategories: definition of design. inputs or assumptions, definition of design document interfaces, documentation of engineering judgment, and implementation of FSAR l commitments or design requirements.
Five of the remaining six major categories accounted for significantly fever action items than did design document adequacy.
Atranged in order of decreasing frequency, the categories are:
- Design process and methods, involving the adequacy of technical guidance and design procedures primarily in the mechanical, nuclear, and pipe stress and supports groups 79
- FSAR control, involving inconsistencies within the FSAR and
! instances in which the FSAR text had not been kept up to date with f the latest design changes
. - Communications of design requirements, involving the design interface with the Nuclear Steam System supplier and other vendor-supplied designs and equipment I
- Design change control, involving the adequacy of design change analysis and documentation described on nonconformance reports, f field change requests, design change notices, and supplier document.
deviation requests i
- Miscellaneous site-related construction activities, involving construction procedures, installation, and inspection requirements, all of which were identified during the field walkdown assessment
! (No des ~ign documents were involved in this category.)
3 No action items were found in the last major category, design document control.
I Evaluation of the categorization program results confirmed that no
) significant design concerns exist beyond those previously identified in the individual assessment action items.
i The design process concerns identified during the course of the EA program involved the need to (1) reconcile inconsistencies among the various types of design documents and keep them current, (2) develop 2 and implement calculation finalization procedures, and (3) provide
! appropriate documentation for the use of engineering judgment. The significant design process improvements implemented to address these concerns are presented in Section 4.1. [
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No additional trends or generic concerns were detected that had not
' been previously recognized and resolved by the corrective and preventive measures undertaken to close out individual action items
- and the possible generic implications associated with those items.
- Exhibit 5.6 consists of three parts, each including references to i
! sections of the text where the specific action items are discussed. .
Exhibit 5.6.1 lists significant action items resulting in FSAR c
changes; Exhibit 5.6.2 lists action items evaluated for reportability in accordance with 10CFR50.55(e), and Exhibit 5.6.3 lists action items with design change implications.
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4.0 Conclusions 4.1 Adequacy of the overall design process i
The adequacy of the design process was evaluated either l
indirectly or directly in each of the assessments conducted
' during the EA program, j In responding to the assessments, the project addressed each action item with respect to the following questions:
1
- Is the problem valid?
4
- Has the cause of the problem been specifically identified? ;
- Has the immediate effect been corrected or addressed?
- Has impact on other works been addressed?
4
- Is the proposed action sufficient to eliminate the cause?
l.
- Is the schedule for corrective' action reasonable?
Each of the assessments was held open until the specific technical findings and discipline or project-wide implications J
vere addressed to the satisfaction of the EA team.
Additionally, all of the action items initiated in response to the final reports were evaluated individually and collectively (i.e. categorized and analyzed) by SWEC to determine if any generic implications, technical or design-process related, were present.
82 i
The sequence of topics assested and the duration of the EA program allowed for early identification of trends, corrective
' action, and implementation of corrective action by Bechtel.
Each of the assessments in which a trend was identified was
} held open until the specific findings and trends identified 1
vere resolved.
This approach yielded significant design process improvements that were implemented before the plant design had achieved a
" final" status. The resulting completed design product
- reflects the benefits of the design process improvements in all I aspects of the plant.
j Significant design process improvements that vere implemented I are presented in the section discussing the assessment in which the finding was initiated and are summarized below:
I
- Control of calculations i The relevant project calculation procedures were upgraded to I require:
! Classification regarding status (i.e. committed, final, etc.)
Identification of open items that required confirmation Establishment of a positive system for tracking outstanding design-related open items Documentation of the basis for engineering judgment l
83
j
- Finalization (reconciliation of design inputs with current revisions of the documents)
- Interdiscipline coordination J
PED-022 was issued to formalize the communication of fluid system design conditions from the mechanical to the pipe stress and supports group'(PSSG).
- PED-027 was issued to establish a positive interface between the civil / structural and PSSG disciplines.
l The pertinent field design change procedures were upgraded to i
! require documentation of interdiscipline review of proposed changes.
1 i - Consistency between documents j PED-042 was issued to provide detailed checklists vith specific consistency attributes for each discipline to use
{
during the design finalization and turnover process.
l
)i Based on the EA program assessments and on-going implementation of these design process improvements, the EA l
team has concluded that no adverse implications exist
- regarding the Bechtel design process.
1 I
4.2 Adequacy of the design of the systems reviewed j
- The technical adequacy of the STP systems and structures reviewed was evaluated during each of the assessments conducted during the EA program. Each action item initiated was i
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t evaluated by the project and by the EA team for possible discipline and project-wide implications. The SVEC categorization analysis also considered possible generic technical weaknesses.
Significant technical findings and resolutions are presented in the section discussing the assessment in which the finding was initiated.
The major findings and their resolutions are summarized below:
- The pipe support field fabrication and installation spec,fication was revised to include the requirements for cold load positions of spring hangers.
- The pipe stress analysis criteria were revised, and PED-023 was issued to provide guidelines for the application of stress intensification factors, friction forces, transformation of NSSS coordinates, and loading conditions regarding pipe sleeve clearances.
- Pipe stress and supports group analysts were given guidance regarding the proper method for manually combining maximum stresses in order to meet ASME III Code requirements.
- Field design change procedures were revised to require documentation of the basis for design change approval.
- Break exclusion zone analysis calculations were revised to include the stress terms required by the ASME III Code.
- HELBA design criteria were revised to provide consistent, 85 l
technically-adequate criteria for location of plastic hinge formation in ruptured piping and to justify use of dynamic load factors of less than 2.0.
Based on the assessments, the STP responses, the verification of project commitments, and the successful implementation of the ongoing as-built reconciliation program, the EA team has concluded that the design of.the STP systems reviewed is technically adequate and complies with applicable licensing requirements.
4.3 Categorization and analysis of findings The categorization and evaluation of action items stemming from the EA program assessments identified no significant design concerns beyond those previously identified and corrected during the individual assessments. The categorization program confirmed the design process concerns previously identified during the course of the EA program and addressed programmatically. No additional trends or generic concerns were detected.
1 4.4 Technical adequacy of the overall plant design f
i i
Based on the EA program assessments, STP responses, and the verification of project commitments, as well as the categorization and analysis of findings and ongoing design finalization activities, the following conclusions have been dravn:
(1) that the Bechtel design process is adequate, (2) that the design of systems and features reviewed is adequate, and (3) 86
that a systematic analysis of all actions items reveals no concerns not previously recognized. Therefore, the results of-the EA program provide reasonable assurance that the overall design of STP is adequate and complies with applicable licensing commitments.
87
5.0 Exhibits 5.1 Houston Lighting & Power Company engineering assurance program policy ,
5.2 Nuclear Regulatory Commission approval of the engineering assurance program policy 5.3 Interface agreement - Bechtel/ Project Engineering Team / Engineering Assurance 5.4 HL&P/ Stone & Vebster Engineering Corporation memorandum of understanding 5.5 Independent oversight Committee charter 5.6 Action item cross reference 5.6.1 Action items resulting in FSAR changes 5.6.2 Action items evaluated for reportability under 10CFR50.55(e) 5.6.3 Action items with design change implications 5.7 Independent Oversight committee review of the engineering assurance progra:s and summary report 88
MLap ec e42, Exhibit 5.1 HOUSTON LIGHTING & POWER COMPANY TEXT Nuclear Engineering & Construction = =aa 201 2 TITLE POLICIES AND PRACTICES ,,,,,, 1 ,,11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY ,,,,, 3-15-84 INDICATES CHANGE OR ADDITION I
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ENGINEERING ASSURANCE STATEMINT OF POLICY l
The technical adeqJacy of the engineering and design of the South Texas Project (STP) is of paramount importance to the executive manage-ment of Houston Lighting & Power Company. To provide maximum confidence that the project's engireering and design activities are being carried '
out consistent with our licensing cormitments to the NRC as well as i industry good engineering practices, we have established the Engineering Assurance Department.
The Engineering Assurance Department is directed to undertake appropriate objective reviews of the STP engineering and design activities. Engineering Assurance can best serve the interests of our company and the project by identifying in a forthright manner any con.
cerns with the activities reviewed. All reports generated containing findings relative to these reviews will be provided expeditiously to oar ,
1 cognizant management and the NRC Region IV Resident Inspector's office. l 1 My office shall be lept infonned of concerns identified by the Engineering Assurance Department, complete with actions required, action .
party designation (s), and required corrective action completion dates. '
. . .e .President Execut we V huclear Group i
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HL&P N10(Sa2)
HOUSTON UGHTING & POWEQCOMPANY TEXT Nuclear Engineering & Construction - ~
201 2 TITLE POLICIES AND PRACTICES ,,,,,,
2 ,,
11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY ,, 3-15-84 INDICATES CHANGE OR ADDITION 1.0 Purpose The purpose of the engineering assurance program is to provide confidence in the technical adequacy of the engineering and design work performed by HL&P and its major contractors.
3.0 Introduction The HL&P engineering assurance program consists of activities specifically directed at assessing the adequacy of the technical aspects, as well as the methods of control, of the engineering and design activities of HL&P and its major contractors in producing a quality engineering product. This is accom-plished by independently sampling the design activities and products for confir-mation by analytical techniques. Accordingly, the engineering assurance program functions independently of the HL&P nuclear quality assurance program.
3.0 Organization The engineering assurance program is established and implemented by the Engi-i neering Assurance Department. The organization of Engineering Assurance is shown in Figure 1. The Manager. Engineering Assurance Department, reports directly to the Vice President. Nuclear Engineering & Construction, to provide an independent overview of the technical activities of the organizations per-forming engineering and design functions. The Vice President Nuclear Er.gineer-ing & Construction, oversees the engineering assurance program to ensure that it l
is adequately defined and that it is being properly implemented. Engineering Assurance is staffed by personnel having extensive engineering and design expe-
! rience in their assigned disciplines and, in order to ensure technical indepen-dence, no prior involvement in design or engineering work for the South Texas Project.
4.0 Program Procedures The engineering assurance program procedures are approved by the Manager Engi-neering Assurance Department. These procedures describe the various Engineering
! Assurance activities, including assignment of responsibilities, methods of implementation, and methods of coordinating activities with other organizations.
5.0 Program Activities The activities of the engineering assurance program include design process reviews, independent technical assessments, and third-party design assessments described below. Engineering Assurance in effect will verify that plant equip-ment, structures, and systems assessed will perform to design criteria and per-formance requirements established for the plant. Effort will not be made to 90
HL&P64C(sah HOUSTON LIGHTING & POWER COMPANY TEXT Nuclear Engineering & Construction y y TITLE POLICIES AND PRACTICES 3 11 suaJECT ENGINEERING ASSURANCE PROGRAM POLICY , , , ,
3-15-84 INDICATES CHANGE OR ADDITION identify modifications or improvements of the features assessed, unless the design will not perform its intended function or satisfy the design criteria.
The technical subjects and design features will be evaluated against good engi-neering practice and the commitments contained in the FSAR. As a minimum, the specific elements of the design process as listed in the Appendix vill be verified.
Selection of review / assessment topics is based on the followir.3 general guidelines:
- Select areas of review that represent known technical problem areas in the industry.
- Select areas that represent of known or suspected HL&P and/or contractor difficulties.
- Select representative samples from systems, the design and engineering of which are essentially complete, to determine that design of these systems f rom conception to final acceptance has been carried out in a controlled manner and that the system design meets its intended purpose.
- Select activities that require significant interface with the NSSS supplier and other major vendors.
- Select topics for design process review in a manner that addresses the various aspects of the design process (i.e., design input, interface, process, output, and changes) and provides a reasonable data base by which to judge the ade-quacy of the design process.
- Select any other topics of management concern.
5.1 Design Process Reviews Desige process reviews are performed by personnel assigned to Engineering Assurance. The objective of these reviews is to develop information by which to judge the adequacy of design controls on the basis of whether the results of the design activities of HL&P and its major contractors are correct and consistent with licensing commitments and represent good engi-neerina practice. These reviews are conducted on a sampling basis and are direct.d at the technical substance of the design process, in contrast to quality assurance audits, which examine procedural compliance. Design
, process reviews are conducted by experienced engineers who, by examining the technical aspects of the design, can evaluate whether design activities are being properly conducted. For example, such reviews can evaluate whether correct and current design inputs are used by affected design 91
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HOUSTON UGHTING & POWE2 COMIANY TEXT Nuclear Engineering & Construction - -
201 2 TITLE POLICIES AND PRACTICES ,,,,,,
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11 susJECT ENGINEERING ASSURANCE PROGRAM POLICY ,,
3-15-84 lNDICATES CHANGE OR ADDITION organizations and whether design changes are properly evaluated and incor-porated into the design. As a result of these reviews, judgments can be made as to how well the design activities are controlled by the organiza-tions involved. The HL&P Engineering Manager coordinates any necessary corrective action related to concerns identified as a result of these reviews.
5.2 Independent Technical Assessments Independent technical assessments are performed by personnel assigned to Engineering Assurance. These assessments are designed to be independent verifications of designs. They do not take the place of norn.1 design verification activities performed by the organizations responsible for the design, but are done to provide additional confidence in the technical adequacy of the design. Independent technical assessments are conducted on a sampling basis and are directed at critical and complex design features as well as areas of known or suspected HL&P, contractor, or industry problems. These assessments ar2 conducted by experienced engineers who evaluate and verify the design through a review of the design, using alter-nate analyses as needed. Where additional manpower is required to perform a comprehensive technical assessment, additional engineering personnel will be contracted from outside HL&P to work under the supervision and direction of the HL&P Engineering Assurance discipline leader (s). Engineering Assur-ance will verify that appropriate corrective action related to concerns identified as a result of these assessments is undertaken in a timely fash-ion by the project.
5.3 Third-party Design Assessments Third-party design assessments are coordinated by personnel assigned to Engineering Assurance but are actually performed by an independent outside engineering organization. These assessments are designed to provide a completely independent assessment of the adequacy of design work performed by HL&P and its major engineering and design contractors. Topics for third-party design assessment are designated by the Manager Engineering Assurance Department, and approved for implementation by the Vice Presi-dent Nuclear Engineering & Construction. The design assessment approach (i.e., sampling or complete verification) and the specific design features that are reviewed are jointly selected by Engineering Assurance and the third-party engineering organization. The design assessment methods used (e.g., use of alternate calculations) are determined by the third-party engineering organization.
92
HL&P 6410 Saa HOUSTON LIGHTING & POWEl COMPANY TEXT Nuclear Engineering & Construction ~~ ~~
201 2 TITLE POLICIES AND PRACTICES ,,,,, 5 ,, 11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY ,,,, 3-15-84 INDICATES CHANGE OR ADDITION 5.4 Results of Reviews and Assessments The results of these reviews and assessments are reported directly to the Manager, Engineering Assurance Department, and include all concerns identi-fled, an assessment of the significance of the concerns, and specific recommendations for further assessment of any concerns judged to have potentially significant implications.
6.0 Program Implementation Engineering Assurance plans and develops schedules for design process reviews, independent technical assessments, and third-party design assessments.
6.1 Design Process Reviews Design process reviews are implemented as follows:
- A review plan is prepared that defines the purpose, scope, special con-cerns, checklists to be utilized, and any other information pertinent to conducting the review.
- Persennel and organizations to be assessed are notified of the schedule and scope of the review a reasonabic time in advance of the review.
- Review checklists are prepared and utilized that identify the procedures governing the activities being assessed and the specific attributes to be evaluated for those activities.
- A pre-review meeting is held with the management of the organization being reviewed to identify key personnel contacts, discuss the scope of the review, and determine the level of activity in the areas to be reviewed.
- A post-review meeting is held with the management and personnel of the reviewed organization to present and clarify review results.
- A formal review report is prepared, which includes the purpose and scope of the review, results, identification of review participants, and spe-cific observations. Any necessary corrective action is requested from the reviewed organization. The report is approved by the Vice President, Nuclear Engineering & Construction, prior to transmittal to the reviewed organization.
- Responses to review observations describing the extent of problems noted ,
and corrective action are submitted to Engineering Assurance by the j 93 ,
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HOUSTON LIGHTING & POWEQCOMPANY TEXT Nuclear Engineering & Construction - -
201 2 TITLE POLICIES AND PRACTICES ,,,,,, 6 ,, 11 susJECT ENGINEERING ASSURANCE PROGRAM POLICY , , , , 3-15-84 INDICATES CHANGE OR AC0tTION reviewed organization. Engineering Assurance evaluates each response to ascertain whether the committed actions are commensurate with the review results. If the response is considered unsatisfactory, it is returned tc the reviewed crganization for revision.
l
- Engineering Assurance reviews committed action to verify that such action has been taken.
6.2 Independent Technical Assessments Independent technical assessments are implemented as follows:
- An assessment plan is prepared defining the purpose, scope, special con-cerns, and areas to be covered in the assessment.
- The project team is notified of the schedule and scope in advance of the assessment time and provides current design information and documentation to the assessment team.
- A pre-assessment meeting is held between Engineering Assurance and the project team (and contractor as necessary) for information exchange, identification of personnel contacts, and definition of level of activity anticipated in the assessment.
- Clarification of design philosophies, misunderstandings, system opera-tional philosophy, questions, etc., between assessment and project teams may take place as design verification proceeds.
- A post-assessment meeting is held between the assessment team and project team (and contractor as necessary) to discuss results of the review.
- A formal report is prepared, which includes the purpose and scope of the assessment and results and identification of observations. Also, the report includes a list of documents reviewed and alternate calculations performed in addition to the elements outlined above for a design process review report.
- Engineering Assurance reports to t:e HL&P Engineering Manager the need for further evaluation of the extent of the conditions found. He deter-l mines any necessary corrective action (i.e., design changes) and directs and coordinates the necessary actions with all affected organizations.
- Engineering Assurance reassesses the design when the corrective action has been completed.
94 j
MLaPsuofeet HOUSTON LIGHTING & POWER COMPANY TEXT Nuclear Engineering & Construction ==== ~
201 2 TITLE 1 POLICIES AND PRACTICES ,,,,, 7 ,, 11 SusJECT ENGINEERING ASSURANCE PROGRAM POLICY ,,, 3-15-84 INDICATES CHANGE OR ADDITION 6.3 Third-party Design Assessments Third-party design assessments are implemented as follows:
- Engineering Assurance selects and obtains the services of an outside engineering organization to perform a particular assessment. Approval of the organization selected is obtained from the Vice President Nuclear Engineering & Construction.
- Engineering Assurance provides a description of the topic to be assessed 4
and defines the purpose of the assessment.
- Engineering Assurance selects and obtained copies of the specific design
- documents needed to perform the assessment. In conjunction with Engi-neering Assurance, the outside organization determines the design assess-ment approach (e.g., sampling methods) and the specific design features to be assessed, based on the complexity of the design, importance to safety, degree of standardization and similarity to previously proven l
designs, and degree of design completion shown by the documents being reviewed.
- The outside organization selects the specific design assessment methods (e.g., design review, use of alternate calculations) to be used and pre-pares an assessment plan defining the scope, methods to be used, special i
concerns, and other information pertinent to the assessment. A copy of the assessment plan is sent to Engineering Assurance for approval.
- A pre-assessment meeting is held to identify key personnel contacts, discuss the scope of the assessment, and determine the level of activity in the areas to be assessed.
- The outside organization performs the design assessment and documents the results.
- A post-assessment meeting of Engineering Assurance, the outside organiza-tion performing the assessment, and any other organizations as determined by HL&P is held to present and clarify assessment results.
- The outside organization prepares and transmits an assessment report to the Manager Engineering Assurance Department, which includes the purpose and scope of the assessment, results, including comments as appropriate on the significance of the results, identification of assessment parti-cipants, and a list of documents reviewed and alternate calculations performed.
95
msruzean HOUSTON LIGHTING & POWE2 COMPANY TEXT Nuclear Engineering & Construction - '=*
201 2 TITLE POLICIES AND PRACTICES ,,,,, 8 o, 11 susJECT ENGINEERING ASSURANCE PROGRAM POLICY . , , , 3-15-84 INDICATES CHANGE OR ADDITION
- Engineering Assurance reviews the report, determines if corrective action is necessary, and reports the results to the Vice President, Nuclear Engineering & Construction.
- Engineering Assurance reports to the HL&P Engineering Manager the need for further evaluation of the extent of the conditions found. He deter-mines any necessary corrective action (i.e., design changes) and directs and coordinates the necessary actions with all affected organizations.
- Engineering Assurance reviews corrective action and performs a reassess-ment of the design upon completion of the corrective action.
7.0 Records Engineering Assurance maintains sufficient records to demonstrate compliance with this program. In this regard, the following records will be retained:
- Keview checklists, review reports, and corrective action recommendations and follow-ups
- Correspondence pertaining to reviews and assessments performed
- Procurement-related correspondence and documents and invoices for engineering services provided by others
- Assessment reports, documents reviewed, corrective action reports, and re-assessment records
- Calculations, analyses, and other technical documents used or derived during the performance of an assessment that contributed substantially to conclusions reached 6.0 Appendix Criteria for Engineering Assurance evaluations are as follows:
8.1 Design Commitment Control Periodic reviews shall be conducted to ensure consistency between design activities and commitments made in technical specifications, licensing ;
documents, or other regulatory requirements. Also Engineering Assurance I shall verify that an effective system exists for updating design commit-ments as changes occur due to design evolution, management decisions, or regulatory changes.
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ML&P64101942)
HOUSTCN L11HTING & POWER COMPANY TEXT Nuclear Engineering & Construction ygp 7 TITLE POLICIES AND PRACTICES ,,,,,, 9 ,, 11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY , 3-15-84 INDICATES CHANGE OR ADDITION 8.2 Design Inputs Measures shall be established to verify the basis, use, and reasonableness of design inputs. Emphasis shall be placed on confirming the validity and applicability of input information for selected design features. Sources of the input data shall be identified. Calculations that produce results to be utilized as input data shall be verified. Engineering Assurance j shall confirm that design input assumptions are technically valid and
- reasonable.
)
j 8.3 Design Methods 1
i Measures shall be established to verify that the analytical methods used I
for design calculations are consistent with sound engineering practice and
- industry codes and standards identified in project licensing commitments. *2 Confirmation shall be made that computer programs, including subroutines, have been verified, prior to their use, as acceptable. Analytical modeling techniques shall be examined for reasonableness.
) 8.4 Design Control 1
j Measures shall be established to verify that plant system interfaces and l interactions have been properly addressed in the design process. Technical i
review shall verify that the system and components are designed to perform i in normal, transient, and accident modes in accordance with the design *2
, criteria. Review of the flow and documentation of selected design informa-tion shall be performed to assure that output to input between organiza-tions is consistent with applicable design control requirements.
8.5 Design Verification Measures shall be established to verify that design and design verification performed by others are technically adequate. Particular attention shall be given to assessing the adequacy of methods used for design verification i
and the qualifications of personnel performing design verification.
8.6 Design Changes i
1 Measures shall be established for verifying the basis, necessity, and i implementation of design changes. Particular emphasis will be placed on
, evaluating the system for control of design changes, proper coordination by l . affected disciplines, and incorporation into affected design documents.
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ML&P N10(s4M l HOUSTON UGHTING & POWER COMPANY l TEXT Nuclear Engineering & Construction gp =p TITLE POLICIES AND PRACTICES ,,,,,
1O o, 11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY OAYED 3-15-84 INDICATES CHANGE OR ADDITION f., . 7 Design Records Measures shall be established to verify the adequacy of the system for identifying, collecting, storing, and retrieving design records. Consider-ation shall be given to ensuring that the design record system provides both adequate documentation and the ability to store and retrieve documen-tation during design activities. Careful attention shall be given to veri-fying that a system exists for creating an appropriate and accurate record of the as-built design configuration, l
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9 ML&P 8410(D42)
HOUSTON UGHTING & POWER COMPANY TEXT Nuclear Engineering & Construction 31 o
='3-TITLE POLICIES AND PRACTICES ,,,,, 11 ,, 11 SUBJECT ENGINEERING ASSURANCE PROGRAM POLICY DaTE D 3-15-84 lNDICATES CHANGE OR ADDITION FIGURE I
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Vice President Nuclear Engineering a Construction Manager Engineering Assurance I I I I Mechanical / Civil / I"#"******I"" 'I'
Muelaar S tructural Electthal
& Control Analysis
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Exhibit 5.2
/ %, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION E .I wasmuoton.o. c.nosss August 20, 1984 k.....
Docket Nos. 50-498 and 50-499 Mr. J. H. Goldberg Vice President - Nuclear Engineering and Construction Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001
Dear Mr. Goldberg:
SUBJECT:
HOUSTON LIGHTING AND POWER (HL&P) COMPANY - ENGINEERING ASSURANCEPROGRAM(EAP)
On September 14, 1983 Houston Lighting and Power (HL&P) Company met with members of the NRC staff in Bethesda, Maryland, to discuss the South Texas Project Engineering Assurance Program (STP-EAP). The EAP was described as an ongoing independent review of the STP design to confirm the adequacy of the engineering work performed. Per the staff's request and via letter dated November 29, 1983, HL&P provided documentation describing the EAP and reports generated by the program. A meeting was arranged with HL&P at their Houston office on March 1, 1984 to discuss EAP details. As a result of that meeting. l the staff requested HL&P to document the meeting results and forward a copy of all EAP procedures. HL&P complied with the letter request via their letter I dated March 29, 1984. !
In its March 29, 1984 and November 29, 1983 letters HL&P requested that the ongoing EAP be accepted as serving the purpose of an IDVP. The staff has reviewed this information and accepts the EAP as a substitute for an IDVP for Unit 1 providing:
(a) the qualifications and independence of the members of the comittee performing linnual oversight reviews are submitted to the staff for review.
(b) HL&P determines that the physical installation of the components, systems, and structures reviewed in the EAP confonn to the requirements of design
- drawings and specifications. j l
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Mr. J. H. Goldberg As a clarification of your letter dated March 29, 1984 regarding ownership of stock / bonds, the staff understands " independent third party reviewers" to be HL&P contractors working on independent technical assessments, third party design assessments or the oversight comittee. Also, none of these '
individuals should own nominal amounts of stocks or bonds of STP owners, the architect engineer or the constructor.
It is understood that the scope of review for third party design assessments would be comparable, where applicable, to the combined scope of review for design process reviews and independent technical assessments as defined by the sample checklists, Attachments 7.1 and 7.2, of engineering assurance department procedure EAD-3, revision 4. If this is not the case, please clarify the scope i of review for the third party design assessments.
Acceptance of the STP-EAP as an acceptable alternative for the IDVP does not necessarily exclude the possibility of the NRC conducting direct inspections of the design process on the South Texas Project. As a minimum, the staff plans to periodically inspect HL&P's implementation and progress associated with its EAP.
Sincerely, o
l eh r . ise u, ir or f
Division of Licensing Office of P clear Reactor Regulation ec: See next page i
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- l South Texas Mr. 6. W. Oprea , Jr.
Executive Vice President Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 Mr. J. H. Goldberg William S. Jordan III, Esq.
Vice President - Nuclear Engineering Hamon & Weiss and Construction 1725 I Street, N.W.
Houston Lighting and Fower Company Suite 506 P. O. Box 1700 Washington, DC 20006 Houston, Texas 77001 Brian Berwick, Esq.
Mr. J. T. Westenneir Assistant Attorney General
! Manager, South Texas Project Environmental Protection Division Houston Lighting and Power Company P. O. Box 12548 P. O. Box 1700 Capitol Station Houston, Texas 77001 Austin, Texas 78711 j
Mr. E. R. Brooks Mr. D. P. Tomlinson, Resident Mr. R. L. Range Inspector / South Texas Project Central Power and Light Company c/o U. S. NRC i P. O. Box 2121 P. O. Box 910 Corpus Christi, Texas 78403 Bay City, Texas 77414 Mr. H. L. Peterson Mr. Jonathan Davis Mr. G. Pokorny Assistant City Attorney City of Austin City of Austin P. O. Box 1088 P. O. Box 1088 Austin, Texas 78767 Austin, Texas 78767 Mr. J. B. Poston Mr. A. Von Rosenberg Ms. Pat Coy City Public Service Board Citizens Concerned About Nuclear P. O. Box 1771 Power San Antonio, Texas 78296 5106 Casa Oro San Antonio, Texas 78233 Jack R. Newman, Esq.
Newman & Holtzinger, P.C. Mr. Mark R. Wisenberg 1025 Connecticut Avenue, NW Manager, Nuclear Licensing i
Washington, DC 20036 Houston Lighting and Power Company P. O. Box 1700 Melbert Schwartz,Jr., Esq. Houston, Texas 77001
! Baker & Botts One Shell Plaza Mr. Charles Halligan Houston, Texas 77002 Mr. Burton L. Lex 4 . Bechtel Corporation i
Mrs. Peggy Buchorn P. O. Box 2166
- Executive Director Houston, Texas 77001
! Citizens for Equitable Utilities, Inc.
Route 1. Box 1684 Brazoria, Texas 77422 j
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Regional Administrator - Region IV U. S. Nuclear Regulatory Comission 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Mr. Lanny Sinkin 114 West 7th, Suite 220 Austin, Texas 78701 i
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Exhibit 5.3 4
STP Engineering - Engineering Assurance - Bechtel Interface Procedure in Support of Independent Reviews / Assessments I
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The undersigned have reviewed and agreed to provide the management direction and support for their respective organization to accomplish the Engineering Assurance Department's Independent Reviews / Assessments.
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I Man ger STP Engineering - HL&P 7 lI[fth R. L. Rogers t
Project Engineering Manager - BEC
/ /M 88 R. A. Frazar Q Manager, Engineering Assurance - HL&P s
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Y' 1.0 Purpose This document specifies responsibilities of HL&P South Texas Project (STP) Engineering, HL&P Engineering Assurance (EA), and Bechtel Energy Corporation (BEC) in support of independent reviews of STP engineering by EA and/or a third party. This document also establishes the methods of handling interorganizational communications and resolving interface problems.
2.0 Scope This procedure applies to all design process reviews and assessments performed by the Engineering Assurance Department and/or any third party.
3.0 References None 4.0 Definitions 4.1 Design process reviews Design process reviews are performed by personnel assigned to Engi-neering Assurance. The objective of these reviews is to develop .
information by which to judge the adequacy of design controls. The reviews are conducted on a sampling basis and are directed at the technical substance of the design process.
4.2 Independent technical assessments Independent technical assessments are led by personnel assigned to Engineering Assurance. These assessments are designed to provide additional confidence in the technical adequacy of the design. They do not take the place of normal design verification activities per-formed by the organizations responsible for the design.
4.3 Third-party design assessments Third-party design assessments are coordinated by personnel assigned to Engineering Assurance but are actually performed by an indepen-dent outside engineering organization. These assessments are designed to provide a completely independent assessment of the ade-quacy of design work performed by HL&P and its major engineering and design contractors.
4.4 Action items Any concerns identified as a result of design process reviews, inde-pendent technical assessments, and third-party design assessments, which require disposition 0
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5.0 Procedures 4
5.1 Annual schedule i By November 1 of each year, the Manager, Engineering Assurance. l shall provide to the Manager, STP Engineering, a schedule of the i
, reviews / assessments to be conducted by EA the following year. The J
4 annual schedule shall contain a description of review / assessment subjects, extent of reviews / assessments, and start and completion
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dates for reviews / assessments.
I By November 15 of each year, the Manager, STP Engineering, or his 4
designee shall re, view the annual schedule with BEC and inform EA of the feasibility of supporting the reviews / assessments listed.
By December 1 of each year, EA shall issue the annual schedule, i having obtained the approval of the Vice President, Nuclear Engi-neering & Construction.
- 5.2 Detailed scope and schedule, document collection l
l A meeting of Engineering Assurance, STP Engineering, and BEC will be !
i held to have BEC present the status of design and engineering and to i
discuss the availability of documentation. At this meeting, the
- schedule for document reproduction will be discussed with Records
- Management.
A sufficient time before a review or assessment begins, the Manager, EA, or his designee shall provide to STP Engineering a detailed scope and schedule of the specific topic to be reviewed, including the type of documentation required.
l STP Engineering shall forward the detailed scope and schedule to BEC.
STP and BEC shall review the sc'hedule and documentation requirements '
1 and resolve any problems with EA regarding the schedule or documen-i tation requirements.
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STP Engineering shall direct BEC to prepare a package containing all documentation required to support the review.
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BEC shall supply STP Engineering with any necessary documents not available in RMS as well as a list of documents that are available
! directly from RMS. BEC shall certify in writing that all documents
! are correct and represent the current design (as of the date of the
! submittal). BEC shall also identify any features of the design that
! are in the process of being changed or that are known likely to be i changed.
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STP Engineering shall provide the completed documentation package to EA 15 days prior to the start of the review / assessment. A transmit-l tal memo shall accompany the package and shall identify the specific documents being transmitted.
l 5.3 Review / assessment process
- Each organization shall designate one person to be responsible for-l coordinating the organization's participation in the review /
- assessment.
Upon receipt of the requested documentation from STP Engineering, EA or a third party 'shall perform a cursory review of the documents and
! shall as soon as possible notify STP Engineering of the need for any additional documentation.
A pre-assessment meeting shall be scheduled to discuss the scope of the review / assessment. !
STP Engineering shall arrange to obtain from BEC, within a reason-4 able time that supports the schedule of the review / assessment, any additional documentation required by EA during the course of the
, review / assessment.
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4 EA shall keep STP Engineering advised of any potential findings as 1 they occur during the review / assessment. When questions needing clarification arise during the review process, EA will arrange a i
meeting or a teleconference with STP Engineering and BEC.
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BEC and STP Engineering shall support any clarifications required
- during the review / assessment.
t i A post-assessment meeting will be held at the completion of the
! review / assessment to apprise BEC and STP Engineering of any i findings. Items needing review for potential reportability will be j identified, and action will be taken in accordance with Project Licensing Procedure PLP-02.
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Statements of potential findings will be made available one week i before the post-assessment meeting.
- In accordance with Engineering Assurance Department procedure EAD-7, EA shall issue a final report at the conclusion of the review /
assessment identifying action items.
l 5.4 Disposition of action items I
Upon review of the report and the action items, STP Engineering shall determine the extent to which BEC shall be involved in resolv-ing the action items and shall inform BEC accordingly. STP l i 2
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Engineering shall also forward a copy of the report and action items to BEC.
- l 1 BEC shall determine what actions are necessary to resolve the iden-i tified items and shall coordinate implementation of the required actions.
i Findings that result in action items shall clearly state the basis for the finding.
STP Engineering and BEC shall assure that responses address the following, as applicable:
- Is the problem valid?
- Has the cause of the problem been specifically identified?
- Has the immediate effect been corrected or addressed?
- Has impact on other works been addressed?
- Is the proposed action sufficient to eliminate the cause?
4 - Is the schedule for corrective action reasonable?
The Manager, STP Engineering, shall inform EA of proposed actions.
1 EA shall review the response and close out action items. This shall l include any necessary follow-up review of actions before closeout.
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Exhibit 5.4 MEMORANDUM 0F UNDERSTANDING BETWEEN HOUSTON LIGHTING & POWER COMPANY AND STONE & WEBSTER ENGINEERING CORPORATION REGARDING CONDUCT OF INDEPENDENT TECHNICAL REVIEWS j OF THE SOUTH TEXAS PROJECT BACKGROUND The South Texas Project is a two-unit (1250 MW each) Westinghouse pressurized
) water nuclear-powered electric generating station. The project is being designed by Bechtel Energy Corporation, constructed by Ebasco Services Inc.,
and managed overall by Houston Lighting & Power Company (HL&P) acting as pro-ject manager for itself, the City of San Antonio, the City of Austin, and Central Power & Light Company. The project schedule currently projects com-pletion dates (fuel load) of December 1986 and December 1988 for Units 1 and 2, respectively.
HL&P as project manager maintains a project staff of engineers and construc-tors to provide programatic direction and oversee the activities of its contractors, Bechtel and Ebasco. Additionally, HL&P has established an Engineering Assurance Department staffed with experienced and qualified spe-cialists to perform independent technical reviews of project engineering activities of Bechtel and other design contractors. HL&P's Engineering Assur-ance Department will from time to time supplement its resources from outside sources to conduct the independent technical reviews. Stone & Webster Engi-neering Corporation (SWEC) is one of the organizations that will participate in this endeavor. Independent technical reviews may consist of reviews of i design process, assessments of design, which will be under the direction of
'; HL&P Engineering Assurance Department, or third-party design assessments, which shall be under SWEC direction. In some instances, SWEC may provide HL&P with personnel to work under HL&P Engineering Assurance Department supervision during performance of a technical review or technical assessment.
POLICY The independent technical reviews shall be conducted by personnel not pre-viously involved with the design or engineering activities of the South Texas Project. ,
Independent technical review teams will be staffed predominantly with engi-neers having prior proven records of related industry experience who are able to provide an objective, dispassionate technical review and make judgments on the basis of technical merit.
When selecting any SWEC individual for an independent technical review, the ;
following shall be considered: 1 1
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- 1) The individual shall not have participated in design or engineering activity for the South Texas Project.
- 2) The individual shall neither control nor own more than 10,000 shares of the stock or $100,000 in bonds of Houston Industries. ENSEARCH Corporation, or Central and South West Corporation nor more than
$100,000 in bonds of the City of Austin or the City of San Antonio.
- 3) The individual shall not have a relative employed by Houston Indus-tries, Central and South West Corporation, or subsidiaries thereof, the City of Austin, the City of San Antonio, Bechtel, or Ebasco in a senior management capacity or other position that could lead to a direct conflict of interest.
SWEC's obligation to fulfill this requirement shall be considered satisfied by its obtaining a signed statement, in the format of the attachment, from each individual assigned to independent technical review.
The conclusion of all reports, including interim reports, generated by a review team that deal with safety-related matters will be shared by HL&P with the Nuclear Regulatory Connission.
When SWEC personnel work under the supervision of HL&P Engineering Assurance Department in the performance of reviews of design process or assessment of design, HL&P will maintain total control and responsibility for these activities. In all cases, SWEC, consistent with its technical views and inde-pendent role, shall report such conclusions as its personnel may develop dur '
ing the course of their work, including instances in which such views may differ from those of HL&P.
M P. A. Wild Senior Vice President Director of Engineering Stone & Webster Engineering Corporation GA.8,fA<e J. H. Goldberg y Vice President, Nuclear Engineering & Construction Houston Lighting & Power Company 111 Rev. 1
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INDEPENDENT TECHNICAL REVIEW SOUTH TEXAS PROJECT HOUSTON LIGHTING & PCWER COMPANY Statement Regarding Potential or Apparent Conflicts of Interest T0: Stone & Webster Engineering Corporation Whereas, the undersigned employee (" Employee") understands that he or she is assigned as a participant to provide services to Houston Lighting & Power Company with respect to independent technical review of the South Texas Project; and Whereas. Employee understands that it is necessary that the participants be screened for any potential or apparent conflicts of interest with respect to this assignment; Therefore, for the above-stated purposes Employee makes the following repre-sentations to Stone & Webster Engineering Corporation:
- 1) The Employee has not participated in design or engineering activity for the South Texas Project.
- 2) The Employee neither controls nor owns more than 10,000 shares of the stock or $100,000 in bonds of Houston Industries, ENSEARCH Corporation, or Central and South West Corporation nor more than
$100,000 in bonds of the City of Austin or the City of San Antonio.
3)TheEmployeedoesnothavearelativeemployedbyHoustonIndustries or Central and South West Corporation or subsidiaries thereof, the City of Austin, the City of San Antonio, Bechtel, or Ebasco in a senior management capacity or other position that could lead to a direct conflict of interest.
Dated Signature Print name Rev. 1 112
.. . . u. . n Exh M t 5.5 Houston Lighting & Pbwer Company orrict MEMORANDUM March 5. 1984 To G. W. Oprea. Jr. $T-HL-31146 e h.: DU nom J. H. Goldber
- s. eject Engineering Assurance Review Panel i During our .ecent meetirg with NRC representatives, we discussed establishing a three-member panel to periodically oversee the functioning of the engineering assurance program to assure its independence and viability.
Such a panel would enhance the presentation of the engineering assurance program during future OL hearings.
We reccennend establishment of an oversight panel consisting of:
- one outside director of Houston Industries who has an engineering i management background
- one panelist from the academic consnunity such as Dr. Normar, d
Rasmussen or a nuclear engineering department head from the Univer-sity of Texas or Texas A&M University
- one panelist who resides in the vicinity of $TP and who has an engineering management background This panel would annually review the scope and results of the program to ensure that it is effectively organized and executed and that conclusions are objectively treated by responsible management.
An honorarium similar to that paid to directors should be established to compensate the panelists for the time they spend in this role.
, We should endeavor to organize the panel so that they can initially review the program this sunner. vith follow-ups in summer 1985 and 1986.
It seems appropriate for you to establish initial contacts with pan-elists and charter the function from your office. We will assist in devel-opment as required.
! JHG: jog cc: R. A. Frazar STP RMS j 1
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Exhibit 5.6.1 ACTION ITEMS RESULTING IN FSAR CHANGES Action Item Reference in Section 2 83-1-1 2.1.2 83-1-2 2.1.2 83-1-3 2.1.2 84-2-1 2.6.2 84-3-21.1 2.4.2 85-1-1 2.8.2 85-1-3 2.8.2 85-1-4 2.8.2 85-1-5 2.8.2 85-1-9 2.8.2 85-1-42 2.8.2 85-1-62 2.8.2 85-1-72 2.8.2 85-2-46 2.9.2 85-2-63 2.9.2 l 85-2-67 2.9.2 85-3-1 2.10.2 85-3-4 2.10.2 85-3-5 2.10.2 85-3-6 2.10.2 85-3-8 2.10.2
) 85-3-9 2.10.2 85-3-32 2.10.2 85-3-35 2.10.2 85-3-37 2.10.2 85-3-39 2.10.2 85-3-49 2.10.2 85-3-81 2.10.2 86-1-7 2.12.2 114
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! Exhibit 5.6.2 ACTION ITEMS EVALUATED FOR REPORTABILITY l
10CFR50.5.5(c) l l
l l Action Item Reference in Section 2 83-3-32 2.3.2 84-2-42 2.6.2 84-3-9 2.4.2 84-3-10 2.4.2 84-3-11 2.4.2 85-1-9 2.8.2 85-1-55 2.8.2 85-2-4 2.9.2 85-2-9 2.9.2 85-2-11 2.9.2 85-2-46 2.9.2 85-2-63 2.9.2 85-2-67 2.9.2 85-5-11 2.3.2 86-1-22 2.12.2 86-1-29 2.12.2 86-1-30 2.12.2 86-1-31 2.12.2 l
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Exhibit 5.6.3 ACTION ITEMS VITH DESIGN CHANGE IMPLICATIONS Action Item Reference in Section 2 83-1-8 2.1.2 83-1-10 2.1.2 83-1S-6 2.1.2 83-2-1 2.2.2 83-2-2 2.2.2 83-2-3 2.2.2 83-2-6 2.2.3 83-3-22 2.3.2 83-3-23 2.3.2 83-3-26 2.3.2 83-3-27 2.3.2 83-3-31 2.3.2 84-1-2 2.5.2 84-1-4 2.5.2 84-1-6 2.5.2 84-2-4 2.6.2 84-2-8 2.6.2 84-2-18 2.6.2 84-2-27 2.6.2 84-2-32 2.6.2 1 84-2-40 2.6.2 84-3-24 2.4.2 84-3-26 2.4.2 84-3-28 2.4.2 84-4-4 2.7.2 84-4-5 2.7.2 84-4-10 2.7.2 85-1-10 2.8.2 85-1-67 2.8.2 85-2-12 2.9.2 116
Action Item Reference in Section 2 85-2-45 2.9.2 85-25-1 2.9.2 85-2S-2 2.9.2 85-3-30 2.10.2 85-3-60 2.10.2 85-3-77 2.10.2 85-3-85 2.10.2 85-3-90 2.10.2 i
85-3-92 2.10.2 ,
- 85-3-100 2.10.2 85-4-22 2.11.2 84-4-45 2.11.2 85-5-15 2.3.2 85-5-21 2.3.2 85-5-25 2.3.2 86-1-10 2.12.2 1
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Exhibit 5.7 Robert V. Laney Consuhant 24 Trout Farne Lane Energy Project Management Dutbury. Massachusetts 02332 Phone (617) $83 8912 March 23, 1987 Mr. J. H. Goldberg Vice President Houston Lighting and Power P. O. Box 1700 Houston, TX 77001
Dear Mr. Goldberg:
This is the final report of the Independent Oversight Committee which the Houston Lighting and Power Company formed to observe and evaluate the conduct of the Engineering Assuranco Program for the South Texas Project. The committee was given full access to those individuals who performed the engineering and design, those who made the assurance reviews, as well as those on the EA staff who directed the program.
As they became available, we were furnished all of the program documents which we required for our review and for discussion during review mootings. These included review plans, assessment reports, action item reports, verification plans, and verification closure memorarda, as well as internal policios and procedures, correspondence, and NRC audit reports.
In the course of each of our savon review meetings at the Project Engincoring Officos in Houston we discussed our observations directly with you, and followed each meeting with a written report. Thoso mootings gave us ample opportun-ity to form independent judgements on the professional qual-ifications and performance of principal participants from the South Texas Project and Bechtel and to discuss with them any questions we had concerning assessments, action items, and responses to action items. Two additional visits to the Stone and Webster officos in Doston allowed us to observe and ovaluato directly the manner in which they conducted third party design ansonsmants.
In this final report the Committoo takes particular noto of two subjects which are contral to any design review process.
The first is to assuro'that any generic process weaknossen are identified and corrected. The second is to assure adoquate 118
Mr. J.11. Goldb3rg Page 2 March 23, 1987 design closure and configuration baseline documentation.
The EA program addressed both of these.
With respect to the first, the Committee found the South Texas Project Categorization Report, containing an analysis of all action items, to be a particularly important feature of the EA process. Since this collective review revealed no problems which had not been already identified by the system and process assessments, the EA staff can justifiably conclude that, with these earlier improvements implemented, the design process is adequate for the total design.
As to the second, in several of its assessments the EA program revealed a need for a more structured design closing program. In its December, 1986 meeting, the Committee re-viewed the procedures which had been developed by the South Texas Project and Bechtel to assure both timely design closure and the phased turnover to IIL&P of design information packages suitable for use as a configuration control baseline.
These procedures clearly address the need which the EA program identified. Their effective implementation by the Project will complete the required action.
From document reviews, on-site reviews and discussions with participants, and its own deliberations, the committee has reached several conclusions:
The EA program was soundly designed and adequately documented for its purpose.
It was conducted in a thorough, professional manner, and in compliance with IIL&P's governing policios and procedures.
. It provides substantial additional confidence that South Texas Project's engineering and design is technically adequate.
A number of the design process improvements for which the EA program revealed a need have already been implemented in Project and Bechtel programs. Others are in process of being incorporated. Assuming the successful completion of these remaining improvements, including the design document ,
finalization and turnover program, the Committee believes I
that the EA program provides reasonable annurance that: 1 119
Mr. J. H. Goldberg March 23, 1987 Page 3 The Bechtel design process is adequater The design of the system and features assessed is adequate; The overall design of the South Texas Plant is adequate and complies with applicable licensing commitments.
i We point out that fulfilling the assumptions stated j above is a vital part of assuring that the EA program meets
- its objectives.
We understand that the Nuclear Assurance Department will track these remaining actions to completion.
Committee members J. M. Hendrie and H. H. Woodson concur in this report. .
We wish to express our appreciation for the courtesies j
I we received from you and from all with whom we worked in the course of this review. We are available to discuss any j questions you may have concerning this report.
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Sincerely, M
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Robert V. Lancy, Chairman RVLipb cc: R. A. Frazar J. M. Hendrie H. H. Woodson I
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