IR 05000498/1985026

Insp Repts 50-498/85-26 & 50-499/85-23 on 851202-06.Major Areas Inspected:Adequacy of Corrective Actions Associated W/Engineering Assurance Program Tasks 83-1,83-3,84-1,84-2 & 84-3.Tasks Acceptably Completed

ML20140E319
Person / Time
Site:	South Texas
Issue date:	03/25/1986
From:	Imbro E, Parkhill R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20140E303	List: IR 05000498/1985026 ML20140E300
References
50-498-85-26, 50-499-85-23, NUDOCS 8603270429
Download: ML20140E319 (22)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Division of Quality Assurance, Vendor, and Technical Training Center Programs Quality Assurance Branch ,.

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Report No.: 50-498/85-26, 50-499/85-23 Docket Nos.: 50-498/499 Licensee: Houston Lighting & Power Company Facility Name: South Texas Project Unit 1 Inspection At: Bechtel Energy Corporation, Houston, Texas Inspection Conducted: December 2-6, 1985 Inspection Team Members:

TeamEeader: E. V. Imbro, Section Chief, IE Eleefrical/I&C: S. V. Athavale, Inspection Specialist, IE Mechanical Systems: T. J. DelGaizo, Consultant, WESTEC Services Mechanical Components: R. Parkhill, Inspection Specialist, IE J. Blackman, Consultant, WESTEC Services Civil / Structural: A. Unsal, Consultant, HARSTEAD Engineering Prepared by: w '9// T 'l-R. W. Parkhill 'Date" d Inspection Specialist, IE

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Approved by: [ Wm -

9/2 f T E. V. Imbro ' Da t'e Section Chief Quality Assurance Branch,IE B603270429 860325 PDR ADOCM 05000498 G PDR

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SOUTH TEXAS PROJECT - UNIT 1 INSPECTION OF AUDIT RESULTS: TASKS 83-1,83-3, 84-1, 84-2 AND 84-3 DECEMBER 2, 1985 THROUGH DECEMBER 6, 1985

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1. Background -

On March 1, 1984, representatives of Houston Lighting and Power Company (HL&P) presented to the NRC the details of the Engineering Assurance Program (EAP) being conducted on the South Texas Project (STP). As a result of this meeting and additional information provided by HL&P, the NRC determined that this program, if properly implemented, could provide the additional assurances of design adequacy normally provided by an Independent Design Verification Program (IDVP). Formal acceptance of the EAP as a substitute for an IDVP was provided via letter to HL&P dated August 20, 1984.

The NRC decided to monitor-the STP Engineering Assurance Program in three phases for Task 85-1, Control Room HVAC, Task 85-2, Component Cooling Water System and Task 85-3, Offsite AC Power and Medium Voltage AC Power SSpply Systems: (1) implementation of program plan and procedures, (2) review and evaluation of audit results and (3) followup of corrective actions. The first phase of inspection was accomplished at the headquarters of the Stone and Webster Engineering Co. (SWEC) in Boston during the week of April 23, 1985. The report of this inspection (No. 50-498/85-09) was forwarded to HL&P on July 12, 1985. The second phase of inspection for Tasks 85-1 and 85-2 was accomplished at SWEC's headquarters in Boston from July 22, 1985 through July 26, 1985 and a report of this inspection (No. 50-498-85-14)

was forwarded to HL&P on August 28, 1985. The second phase of inspection for Task 85-3 was accomplished at SWEC's headquarters in Boston from October 15, 1985 through October 17, 1985. The report of that inspection (No. 50-498/85-22) was forwarded to HL&P on November 18, 1985.

2. Purpose The purpose of this inspection was to verify the adequacy of the corrective actions associated with EAP Tasks .83-1, 83-3, 84-1, 84-2 and 84-3. These tasks were completed prior to NRC involvement in the EAP and consequently an in process review was not performed by the staff. Therefore the objec-tives of the inspection were limited to: (1) verifying that the concerns developed by SWEC had been correctly implemented by HL&P as action items; (2) verifying that the action items had been satisfactorily resolved, and (3) confirming that the implementation of required corrective actions had been satisfactorily completed.

3. Personnel Contacted The following is a brief list of key personnel contacted during this inspection:

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Name Position R. A. Frazar HL&P EA Program Manager S. R. Basu HL&P EA Program Staff M. Chakravorty HL&P EA Program Staff J. Woods HL&P EA Program Staff- -

C. Allen HL&P Project Engineering -

N. Jonnejo Bechtel M. Scott Bechtel J. Shellabarger Bechtel P. Trudel Bechtel B. Woodley Bechtel L. Shipley Bechtel 0. Gurbuz Bechtel R. Singh Bechtel D. Quattrociocchi Bechtel 4. General Conclusions A substantial amount of review work was performed during the SWEC audits bised upon the scope of findings presented. Pertinent design documents reviewed were design specifications, design procedures, calculations,

-logic diagrams and equipment qualification documentation. This effort resulted in a large number of findings which were, in turn, satisfactorily implemented as action items by HL&P. The required corrective actions were reviewed in detail and found to be adequately implemented, subject to the comments contained in this report.

The t'hree previous inspection reports associated with the STP EAP, 50-498/

85-09, 50-498/85-14 and 50-498/85-22, closed various concerns based upon corrective actions implemented by SWEC. As a result of satisfactory com-pletion of these items and the results of this inspection, it is concluded that the HL&P EAP is being adequately performed and is meeting its intended purpose.

5. Discipline Summaries The following are summary descript' ions, presented in accordance with each of the disciplines involved with Tasks 83-1, 83-3, 84-1, 84-2 and 84-3.

Electrical Discipline The HLhP corrective action plan for environmental qualification associ-ated with Task 84-2 was reviewed. The documents reviewed included test reports, specifications, and other related documents.

The SWEC report for Task 84-2 was limited to a few items since most of the EQ reports were not available at the time of review. To resolve this problem, HL&P has conducted an independent review of four additional approved EQ test reports. This was performed using guidelines similar to

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those used by SWEC for Task 84-2. As a result of this review, HL&P identified a few deficiencies in one of the test reports and other related

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EQ' documents, and have developed action ites plans to track these addi-tional findings for corrective action. HL&P has further plans to conduct additional independent reviews of approved EQ test reports for equipment located in harsh environments to supplement the current sampling. ,

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Mechanical Systems Discipline In the Mechanical Systems Area, the following design assessments were reviewed: (1) Task 84-1, Containment Analysis, and (2) the systems portions of Task 84-2, Equipment Qualification. In both instances, it was concluded that the reviews had been effectively completed as follows:

a. Independent Reviewer concerns had been correctly translated into action items.

b. Satisfactory resolutions of action items were achieved.

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c. Verification of resolutions was effectively accomplished.

Of particular note is that verifications have periodically raised additional questions which indicate that verifi-cations were performed in considerable depth.

A pertinent Action Item for Task 84-1 was 84-1-4, which indicated that calculation MC5410 lacked justification for the assumption of a minimum 30 minute switchover time from the refueling water storage tank to the containment sump in calculating the NPSH of the containment spray pump.

Similarly, Action Item 84-1-5 raised questions relative to the instrument errors assumed in that calculation. The Staff reviewed the revised version of calculation MC5410 and concluded that the revisions had adequately addressed the concerns of these action items.

Action Item 84-1-6 involved the need to include a can-loss allowance in the calculation of NPSH for the containment spray pumps. BEC's initial response to this action item was that no can-less allowance was necessary.

HL&P Engineering Assurance did not accept the initial BEC determination that no allowance was necessary. Following further evaluation, a can-loss allowance was included in the calculation. The Staff reviewed the revised calculation and considers it to be acceptable.

A key Action Item related to the systems aspects of Task 84-2 was 84-2-3, which questioned the applicability of the Westinghouse model for analysis of main steam line break (MSLB) accidents. A new calculation was prepared (NC7007) which confirmed the conservatism of the the FSAR with regard to MSLB parameters. During its review of this calculation, the Staff ques-tioned the validity of feedwater isolation as assumed in the calculation. The Staff determined, through review of control logic diagrams, that feedwater.

control yalves, bypass valves, and isolation valves are all shut on high

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containment pressure signals and other safety-injection signals. The Staff

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concluded that the treatment of feedwater isolation in the calculation

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Action Item 84-2-4 concerned the design of the containment spray system j. with_ regard to the control of spray pH. The original concern was- '

related to balancing of spray pH, should one of the three containment j spray trains be unavailable.under accident conditions. Further review

, of.this matter between Project personnel and Westinghouse personnel

revealed additional questions related to'the efficiency of the spray  ;

j additive eductors following switchover to the spray recirculation mode.

l It was ultimately determined that at the elevated spray temperatures i occurring in.the recirculation mode, the eductors could not be relied upon to inject chemical additive into the spray. A 10CFR50.55e report i to the NRC was initiated by the Project and the system was subsequently l redesigned to provide for a different additive method (gravity drain from

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a tank inside containment) during the recirculation phase. The Staff ,

reviewed the documentation associated with this matter and concluded: i

, (1) the problem is unique to the containment spray system, (2) the redesign l resolves the concern, and (3) sufficient documentation is available to

demonstrate spray pH will be maintained as specified in the FSAR.

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L Action Item 84-2-8 was concerned with radiation attenuation factors j used in conjunction with various containment penetrations. As a result

of this action item,.the calculation was revised to employ a more j conservative methodology for the attenuation of radiation through the

! penetration. .Due to conservatisms inherent in the calculation of l radiation levels, there was no effect on plant designs ~as result of

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using the more conservative methodology. This calculation was reviewed ,

by the Staff and the Staff-concludes that this matter was adequately '

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resolved.

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} Mechanical Components

! The scope of review in the Mechanical Components Area consisted of l design assessment for: (1) Task 83-3, ASME III Pipe Stress Analysis of l RHR/SI System; (2) the mechanical components portion of Task 84-2, i

Equipment Qualification; and (3) Task 84-3, ASME III Pipe Support Design of the RHR/SI system.

1 Task 83-3, ASME III Pipe Stress Analysis of RHR/SI System was reviewed

by examining the overall technical depth associated with original SWEC

findings, Bechtel's response, and any required corrective actions. In

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< so doing a number of calculations, criteria documents and design procedures were examined in detail. Related action items were reviewed i as a group to examine the interrelationships between them. Based upon

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i this review, it was concluded that the required corrective actions, per-f formed by Bechtel, satisfied their intended purpose. The Action Items i reviewed during this inspection included 83-3-1,3,4,6,7,8,9,11,18,21,23, ,

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i 27,28,and 30, and their associated reference documents.

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The mechanical components aspects of Task 84-2, Equipment Qualification, were reviewed in a manner identical to Task 83-3. All of the Action Items were related to seismic qualification issues and were basically individual technical issues associated with specific hardware. Based upon this review, it was concluded that the required corrective actions, performed by Bechtel or the equipment vendor, satisfied their intended purpose. The action items reviewed during this inspection included 84-2-20.1-20.4, 20.6,21,23,24,25 and 26, and their associated reference documents.

Task 84-3, ASME III Pipe Support Design, was inspected by first examining the corrective actions associated with a selected sample of Action Items and secondly, by independently reviewing a selected sample of pipe supports to ensure that reviewers' comments were generically addressed by Project Engineering. In general, the verification plan for 84-3 was responsive to the concerns raised by Engineering Assurance, in that, Project Engineering had implemented an appropriate corrective action and Engineering Assurance had performed an acceptable verification program. The Action Items reviewed as part of this inspection included 2a,21,18,19,20,22,27,28a,28b,29,30,32, 37a,37b,49a, 55b and 62. The pipe supports and associated calculations independently reviewed included SI-9201-SH0007 Rev. 2, CL-9504-GU0012 Rev. 3, and AC-9221-HL5002. Two observations resulted due to this inspec-

. tion and are as follows:

(1) Engineering Assurance needs to review a larger sample of pipe supports for Action Items numbered 18 and 19 to ensure that the generic impact is adequately verified. Also it was noted that Engineering Assurance plans to review the verification sample size for all affected pipe support active items.

(2) Based upon discussions with HL&P Engineering Assurance, it is under-stood that all additional action items resulting from the EAP veri-fication of previous findings of potential significance, will now be formally submitted to BEC for response. In addition, action items which were closed based upon the existence of programmatic solutions will be incorporated into the project document turnover review process to ensure proper followup.

Civil / Structural Discipline The HL&P corrective action plan for Task 83-1, Soil Structure Interaction Analysis and Seismic Design, was reviewed. The technical and programmatic content of the plan was compared to the original action items to verify proper closure. The substantiating documentation for Action Items 83-1-1 through 83-1-13 was reviewed in detail and based upon this review, it was concluded that they had been addressed properly.

BEC did a complete review of the civil / structural design when they replaced Brown & Root as the architect. Therefore, this area has only been addressed by the EAP in Task 83-1. In order to be able to reach a conclusion on

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design adequacy in all technical disciplines, HL&P proposed that the BEC

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review of Brown and Root's baseline design could be used to supplement the EAP in the area of civil / structural design. In response to this_ pro-posal, the Staff reviewed the following work packages:

EC-122 Containment Internal Structural Steel EC-130 MEAB Concrete *

EC-165 Auxiliary Feedwater Storage Tank EC-186 HVAC Ducts and Duct Supports Based upon the content of the work packages reviewed, it was evident that Bechtel has done a thorough review of the work performed by Brown and Root. They identified a number of items that had to be corrected due to technical or procedural errors. Although it was evident that a credible review had been performed, an auditable path was not maintained during the review, therefore overall conclusions and verification of required remedial measures cannot be determined. In most cases, Bechtel reanalyzed the stru-ctures using different methodology and criteria than were used by Brown &

Root. Furthermore, in some cases, such as Isolation Valve Cubicle, a com-plete redesign was performed by Bechtel. Therefore, additional reviews appear to be necessary to establish the acceptability of this effort. In response to this, HL&P proposed evaluation of the following additional areas:

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1. Isolation Valve Cubicle.(IVC)

2. MEAB --Reinforced Concrete 3. RCB - Internal Structural Steel This approach is acceptable to the Staff and will be reviewed during a sub-sequent inspection when the HL&P reviews are completed. (open item 85-26-01.)

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Mr. J. Houston Lighting and Power Company South Texas Project cc: .

Brian Berwick, Esq. '

Assistant Attorney General Pesident inspector /Scuth Texas Project Environeental Protection Division P. O. Box 12548 c/o U.S. Nuclear Regulatory Commission Capitol Station P. O. Box 910 Austin, Texas 78711 Bay City, Texas 77414 Mr. J. T. Wes terceir Mr. Jonathan Davis Manager, South Texas Project Assistant City Attorney Houston Lighting and Power Company City of Austin P. O. Box 1700 P. O. Box 1088

, Houston, Texas 77001 Austin, Texas 78767 Mr. M. L. Peterson Ms. Pat Coy Mr. G. Pokorny Citizens Concerned About Nuclear City cf Austin Power P. O. Box 1088 5106 Casa Oro Austin, Texas 78767 San Antonio, Texas 78233 Mr. J. B. Poston Mr. Mark R. Wisenberg Mr. A. Von Rosenberg Manager, Nuclear Licensing City Public Service Boad Houston Lighting and Power Company P. O. Box 1771 P. O. Box 1700 San Antonio, Texas iS296 Houston, Texas 77001 Jack R. Newman, Esq. .Mr. Charles Halligan hewman & Holtzinger, P.C. Mr. Burton L. Lex 1615 L Street, Na' Bechtel Corporation Washington, D.C. 20036 P. O. Box 2166 *

Houston, Texas 77001 i Melbert Schwartz, Jr., Esq.

Baker & Botts Mr. E. R. Brooks One Shell Plaza Mr R. L. Range Houston, Texas 77002 , Central Power and Light Company P. O. Box 2122

Mrs. Peggy Buchorn Ccrpus Christi, Texas 78403 Executive Director Citizens for Equitable Utilities, Inc.

Route 1, Box 1684 Brazoria, Tesas 77422

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, Houston Lighting & Power Company -2- South Texas Project ec:

Regional Administrator Region IV I 0.5. Nuclear Regulatory Commission - , l Of fice of Executive Director

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for Operations -

611 Ryan Plaza Drive. Suite 1000 Arlington Texas 76011 Mr. Lanny Sinkin Christic Institute-1324 horth Capitol Street Washington, D.C. 20002

• • Mr. 5. Head. Representative Houston Lighting and Power Company Suite 1309 7g10 Woodmont Avenue Bethesda, Maryland 20814

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Mr. J. The NRC found that the work package reviews performed by BEC were thoroughly and comprehensively performed. However, since Bechtel did not adopt all of Brown and Root's design methodology but instead used some alternate approaches, it was agreed that additional supplements to the EAP in the civil /etructural area are appropriate. This work will be reviewed by the NRC, when completed.

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Sincerely, l

l Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement

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Enclosure: Inspection Report Distribution:

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GTAnkrum, IE NSIC EVImbro, IE NTIS RWParkhill, IE Regional Administrators JAxelrad, IE Regional Division Directors HBoulden, OIA . SECY VStello, EDO OPE TSpeis, NRR KRDenton, NRR

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Docket Nos. 50-498 50-499 Mr. J. Group Vice President - Nuclear Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 SUBJECT: SOUTH TEXAS PROJECT ENGINEERING ASSURANCE PROGRAM (EAP)

" - INSPECTION REPORT 50-498/85-26, 50-499/85-23

Dear Mr. Goldberg:

This letter conveys the results and conclusions of NRC's evaluation of the following Stone and Webster Engineering Corporation (SWEC) EAP Independent Technical Assessment Tasks: 83-1, Soil-Structure Interaction and Seismic Design Verification; 83-3, ASME III Pipe Stress Analysis of RHR/SI System; 84-1, Containment Analysis; 84-2, Environmental Qualification of Equipment; and 84-3, ASME III Pipe Support Design. The inspection was conducted by a team of personnel from the NRC's Office of Inspection an'd Enforcement and consultants at the offices of Bechtel Energy Corporation (BEC), Houston, Texas from December 2, 1985, through December 6, 1985. The objective of this inspection was threefold: (1) verify that the concerns developed by the SWEC audit team had been correctly implemented as action items; (2)

determine if the action items had been satisfactorily resolved; and (3)

verify that the appropriate corrective actions had been implemented or, if the corrective, actions were part of an ongoing resolution program, verify that proper implementation was in progress. In addition, at the request of.

Houston Lighting and Power (HL&P), four work packages in the civil / structural area were reviewed to determine if the results of these reviews, performed by BEC to validate the original engineering design work performed by Brown and l Root, could be used to supplement the scope of review in the civil / structural

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area of the EAP.

f Based upon our inspection, it was concluded that Tasks 83-1, 83-3, 84-1, 84-2 and 84-3 had been acceptably completed subject to the resolution of the NRC's comments, as described in the enclosed report. The HL&P review was comprehensive, checklists were thoroughly completed, files were in good order, backup documentation was in good order and corrective actions were

' implemented in an auditable manner.

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Mr. J. The NRC found that the work package reviews performed by BEC were thoroughly and comprehensively performed. However, since Bechtel did not adopt all.of'

Brown and Root's design methodology but instead used some alternate approaches, it was agreed that additional supplements to the EAP in the civil / structural area are appropriate. This work will be reviewed by the NRC, when completed.

Sincerely,

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Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement Enclosyre: Inspection Report

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

Division of Quality Assurance, Vendor, and

Technical Training Center Programs

Quality Assurance Branch .-

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Report No.: 50-498/85-26, 50-499/85-23 Docket Nos.: 50-498/499 i Licensee: Houston Lighting & Power Company \

l l Facility Name: South Texas Project Unit I I J

Inspection At: Bechtel Energy Corporation, Houston, Texas Inspection Conducted: December 2-6, 1985-

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Inspection Team Members:

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Team Leader: E. V.-Imbro, Section Chief, IE ElecErical/I&C: S. V. Athavale, Incpection Specialist, IE Mechanical Systems: T. J. DelGaizo, Consultant, WESTEC Services Mechanical Components: R. Parkhill, Inspection Specialist, IE J. Blackman, Consultant, WESTEC Services Civil / Structural: A. Unsal, Consultant, HARSTEAD Engineering Prepared by: w R. W. Parkhill 9[ 'Dat(

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'f7 ' Inspection Specialist, IE Approved by: [ km ~9/2 s' Z E. V. Imbro ' Da t'e Section Chief Quality Assurance Branch,IE

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SOUTH TEXAS PROJECT - UNIT 1 INSPECTION OF AUDIT RESULTS: TASKS 83-1,83-3, 84-1, 84-2 AND 84-3 DECEMBER 2, 1985 THROUGH DECEMBER 6, 1985

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1. Background -

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On March 1, 1984, representatives of Houston Lighting and Power Company (HL&P) presented to the NRC the details of the Engineering Assurance Program (EAP) being conducted on the South Texas Project (STP). As a result of this meeting and additional information provided by HL&P, the NRC determined that this program, if properly implemented, could provide the additional assurances of design adequacy normally provided by an Independent Design Verification Program (IDVP). Formal acceptance of the EAP as a substitute for an IDVP was provided via letter to HL&P dated August 20, 1984.

The NRC decided to monitor the STP Engineering Assurance Program in three phases for Task 85-1, Control Room HVAC, Task 85-2, Component Cooling Water System and Task 85-3, Offsite AC Power and Medium Voltage AC Power S5pply Syatems: (1) implementation of program plan and procedures, (2) review and evaluation of audit results and.(3) followup of corrective actions. The first phase of inspection was accomplished at the headquarters of the Stone and Webster Engineering Co. (SWEC) in Boston during the week of April 23, 1985. The report of this inspection (No. 50-498/85-09) was forwarded to HL&P on July 12, 1985. The second phase of inspection for Tasks 85-1 and 85-2 was accomplished at SWEC's headquarters in Boston from July 22, 1985 through July 26, 1985 and a report of this inspection (No. 50-498-85-14)

was forwarded to HL&P on August 28, 1985. The second phase of inspection l for Task 85-3 was accomplished at SWEC's headquarters in Boston from l October 15, 1985 through October 17, 1985. The report of that inspection (No. 50-498/85-22) was forwarded to HL&P on November 18, 1985.

2. Purpose The purpose of this inspection was to verify the adequacy of the corrective actions associated with EAP Tasks 83-1, 83-3, 84-1, 84-2 and 84-3. These tasks were completed prior to NRC involvement in the EAP and' consequently an in process review was not performed by the staff. Therefore the objec-tives of the inspection were limited to: (1) verifying that the concerns developed by SWEC had been correctly implemented by HL&P as action items; (2) verifying that the action items had been satisfactorily resolved, and (3) confirming that the implementation of required corrective actions had been satisfactorily completed.

3. Personnel Contacted The following is a brief list of key personnel contacted during this inspection:

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Name Position R. A. Frazar HL&P EA Program Manager S. R. Basu HL&P EA Program Staff M. Chakravorty HL&P EA Program Staff-J. Woods HL&P EA Program Staff C. Allen HL&P Project Engineering -

N. Jonnejo Bechtel M. Scott Bechtel J. Shellabarger Bechtel P. Trudel Bechtel B. Woodley Bechtel L. Shipley Bechtel 0. Gurbuz Bechtel R. Singh Bechtel D. Quattrociocchi Bechtel 4. General Conclusions A substantial amount of review work was performed during thr: SWEC audits based upon the scope of findings presented. Pertinent design documents reviewed were design specifications, design procedures, calculations, logie diagrams and equipment qualification documentation. This effort resulted in a large number of findings which were, in turn, satisfactorily implemented as action items by HL&P. The required corrective actions stre reviewed in detail and found to be adequately implemented, subject to the comments contained in this report.

The three previous inspection reports associated with the STP EAP, 50-498/

85-09, 50-498/85-14 and 50-498/85-22, closed various concerns based upon corrective actions implemented by SWEC. As a result of satisfactory com-pletion of these items and the results of this inspection, it is concluded that the HL&P EAP is being adequately performed and is meeting its intended purpose.

5. Discipline Summaries

~ The following are summary descriptions, presented in accordance with each of the disciplines involved with Tasks 83-1, 83-3, 84-1, 84-2 and 84-3.

Electrical Discipline The HL&P corrective action plan for environmental qualification associ-ated with Task 84-2 was reviewed. The documents reviewed included test reports, specifications, and other related documents.

The SWEC report for Task 84-2 was limited to a few items since most '

of the EQ reports were not available at the time of review. To resolve this problem, HL&P has conducted an independent review of four additional approved EQ test reports. This was performed using guidelines similar to

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those used by SWEC for Task 84-2. As a result of this review, HL&P identified a few deficiencies in one of the test reports and other related i

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EQ documents, and have developed action ites plans to track these addi-tional findings for corrective action. HL&P has further plans to conduct additional independent reviews of approved EQ test reports for equipment located in harsh environments to supplement the current sampling.

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Mechanical Systems Discipline In the Mechanical Systems Area, the following design assessments were reviewed: (1) Task 84-1, Containment Analysis, and (2) the systems portions of Task 84-2, Equipment Qualification. In both instances, it was concluded that the reviews had been effectively completed as follows:

a. Independent Reviewer concerns had been correctly translated into action items.

b. Satisfactory resolutions of action items were achieved.

" - c. Verification of resolutions was effectively accomplished.

Of particular note is that. verifications have periodically raised additional questions which indicate that verifi-cations were performed in considerable depth.

A pertinent Action Item for Task 84-1 was 84-1-4, which indicated that calculation MC5410 lacked justification for the assumption of a minimum 30 minute switchover time from the refueling water storage tank to the containment sump in calculating the NPSH of the containment spray pump.

Similarly, Action Item 84-1-5 raised questions relative to the instrument errors assumed in that calculation. The Staff reviewed the revised version of calculation MC5410 and concluded that the revisions had adequately addressed the concerns of these action items.

Action Item 84-1-6 involved the need to include a can-loss allowance in the calculation of NPSH for the containment spray pumps. BEC's initial response to this action item was that no can-loss allowance was necessary.

HL&P Engineering Assurance did not accept the initial BEC determination that no allowance was necessary. Following further evaluation, a can-loss allowance was included in the calculation. The Staff reviewed the revised calculation and considers it to be acceptable.

A key Action Item related to the systems aspects of Task 84-2 was 84-2-3, which questioned the applicability of the Westinghouse model for analysis of main steam line break (MSLB) accidents. A new calculation was prepared (NC7007) which confirmed the conservatism of the the FSAR with regard to MSLB parameters. During its review of this calculation, the Staff ques-tioned the validity of feedwater isolation as assumed in the calculation. The Staff determined, through review of control logic diagrams, that feedwater control valves, bypass valves, and isolation valves are all shut on high containment pressure signals and other safety-injection signals. The Staff

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concluded that the treatment of feedwater isolation in the calculation was proper and considers calculation NC7007 to tm acceptable.

Action Item 84-2-4 concerned the design of the containment spray system with regard to the control of spray pH. The original concern was.

related to balancing of spray pH, should one of the three containment spray trains be unavailable under accident conditions. Further review of this matter between Project personnel and Westinghouse personnel revealed additional questions related to the efficiency of the spray additive eductors following switchover to the spray recirculation mode.

It was ultimately determined that at the elevated spray temperatures occurring in the recirculation mode, the eductors could not be relied upon to inject chemical additive into the spray. A 10CFR50.55e report to the NRC was initiated by the Project and the system was subsequently redesigned to provide for a different additive method (gravity drain from a tank inside containment) during the recirculation phase. The Staff reviewed the documentation associated with this matter and concluded:

(1) the~ problem is unique to the containment spray system, (2) the redesign resolves the concern, and (3) sufficient documentation is available to demonstrate spray pH will be maintained as specified in the FSAR.

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Action Item 84-2-8 was concerned with radiation attenuation factors-used in conjunction with various containment penetrations. As a result of this action item, the calculation was revised to employ a more conservative methodology for the attenuation of radiation through the.

penetration. Due to conservatisms inherent in the calculation of radiation levels, there was no effect on plant designs as result of using the more conservative methodology. This calculation was reviewed by the Staff and the Staff concludes that this matter was adequately resolved.

Mechanical Components The scope of review in the Mechanical Components Area consisted of design assessment for: (1) Task 83-3, ASME III Pipe. Stress Analysis of RHR/SI System; (2) the mechanical components portion of Tast 84-2, Equipment Qualification; and (3) Task 84-3, ASME III Pipe Support Design of the RHR/SI system.

Task 83-3, ASME III Pipe Stress Analysis of RHR/SI System was reviewed by examining the overall technical depth associated with original SWEC findings, Bechtel's response, and any required corrective actions. In so doing a number of calculations, criteria documents and design procedures were examined in detail. Related action items were reviewed as a group to examine the interrelationships between them. Based upon this review, it was concluded that the required corrective actions, per-formed by Bechtel, satisfied their intended purpose. The Action Items reviewed during this inspectica included 83-3-1,3,4,6,7,8,9,11,18,21,23,

-27,28,and 30, and their associated reference documents.

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The mechanical components aspects of Task 84-2, Equipment Qualification, were reviewed in a manner identical to Task 83-3. All of the Action Items were related to seismic qualification issues and were basically individual technical issues associated with specific hardware. Based upon this review, it was concluded that the required corrective actions, performed by Bechtel or the equipment vendor, satisfied their intended purpose. The action items reviewed during this inspection included 84-2-20.1-20.4, 20.6,21,23,24,25 and 26, and their associated reference documents.

Task 84-3, ASME III Pipe Support Design, was inspected by first examining the corrective actions associated with a selected sample of Action Items and secondly, by independently reviewing a selected sample of pipe supports to ensure that reviewers' comments were generically addressed by Project Engineering. In general, the verification plan for 84-3 was responsive to the concerns raised by Engineering Assurance, in that, Project Engineering had implemented an appropriate cotrective action and Engineering Assurance had performed an acceptable verification program. The Action Items reviewed as part of this inspection included 2a,21,18,19,20,22,27,28a,28b,29,30,32, 37a,37b,49a, 55b and 62. The pipe supports and associated calculations independently reviewed included SI-9201-SH0007 Rev. 2, CL-9504-GU0012 Rev. 3, and AC-9221-HL5002. Two observations resulted due to this inspec-

. tion and are as follows:

(1) Engineering Assurance needs to review a larger sample of pipe supports for Action Items numbered 18 and 19 to ensure that the generic impact is adequately verified. Also it was noted that Engineering Assurance plans to review the verificatica sample size for all affected pipe support active items.

(2) Based upon discussions with HL&P Engineering Assurance, it is under-stood that all additional action items resulting from the EAP veri-fication of previous fiedings of potential significance, will now be formally submitted to BEC for response. Ir. addition, action items which were closed based upon the existence of programmatic solutions will be incorporated into the project document turnover review process to ensure proper followup.

Civil / Structural Discipline The HL&P corrective action plan for Task 83-1, Soil Structure Interaction Analysis and Seismic Design, was reviewed. The technical and programmatic content of the plan was compared to the original action items to verify proper closure. The substantiating documentation for Action Items 83-1-1 through 83-1-13 was reviewed in detail and based upon this review, it was concluded that they had been addressed properly.

BEC did a complete review of the civil / structural design when they replaced Brown & Root as the architect. Therefore, this area has only been addressed by the EAP in Task 83-1. In order to be able to reach a conclusion on

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design adequacy in all' technical disciplines, HL&P proposed that the BEC

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review of Brown and Root's baseline design could be used to sapplement the EAP in the area of civil / structural design. In' response to this pro-posal, the Staff reviewed the following work packages:

EC-122 Containment Internal Structural Steel -

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EC-130 MEAB Concrete -

EC-165 Auxiliary Feedwater Storage Tank EC-186 HVAC Ducts and Duct Supports

' Based upon the content of the work packages reviewed, it was evident that Bechtel has done a thorough review of the work performed by Brown (

and Root. They identified a number of items that had to be corrected due to technical or procedural errors. Although it was evident that a credible review had been performed, an auditable path was not maintained during the review, therefore.overall conclusions and verification of required remedial measures cannot be determined. In most cases, Bechtel reanalyzed the stru-ctures using different methodology and criteria than were used by Brown &

Root. Furthermore, in some cases, such as Isolation Valve Cubicle, a com-plete redesign was performed by Bechtel. Therefore, additional reviews appear to be necessary to establish the acceptability of this effort. In risponse to this, HL&P proposed evaluation of the following additional areas:

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1. Isolation Valve Cubicle (IVC)

2. MEAB - Reinforced Concrete 3. RCB - Internal Structural Steel This approach is acceptable to the Staff and will be reviewed during a sub-sequent inspection when the HL&P reviews are completed. (0 pen item 85-26-01.)

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Mr. J. Houston Lighting and Power Company South Texas Project Cc: .

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Brian Berwick, Esq.

Assistant Attorney General Resident inspector /Scuth Texas Project Environcental Protection Division P. O. Box 12548 c/o U.S. Nuclear Regulatory Commission Capitol Station P. O. Box 910 Austin, Texas 78711 Bay City, Texas 77414 '

Mr. J. T. Westermeir Mr. Jonathan Davis Manager, South Texas Project Assistant City Attorney Houston Lighting and Power Company City of Austin P. O. Box 1700 P. O. Box 1088

,, Houston, Texas 77001 Austin, Texas 78767 Mr. H. L. Peterson Ms. Pat Coy Mr. G.'Pokorny Citizens Concerned About Nuclear City of Austin Power P. O. Box 1088 5106 Casa Oro Austin, Texas 78767 San Antonio, Texas 78233 Mr. J. B. Poston Mr. Mark R. Wisenberg Mr. A. Von Rosenberg Manager, Nuclear Licensing City Public Service Boad Houston Lighting and Power Company P. O. Box 1771 P. O. Box 1700 San Antonio, Texas i8296 Houston, Texas 77001 Jack R. Newman, Esq. Mr. Charles Halligan hewman & Holtzinger, P.C. Mr. Burton L. Les 1615 L Street, Nd Bechtel Corporation Washington, D.C. 20036 P. O. Box 2166 *

Houston, Texas 77001 i Melbert Schwartz, Jr., Esq.

Baker & Botts Mr. E. R. Brooks One Shell Plaza Mr. R. L. Range Hcuston, Texas 77002 , Central Power and Light Company P. O. Box 2122 Mrs. Peggy Buchorn Ccrpus Christi, Texas 78403 Executive Director Citizens for Equitable Utilities, Inc.

Route 1 Box 1684 Brazoria, Tesas 77422

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, Houston Lighting & Power Company -2- South Texas Project ec:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director -

for Operations 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Mr. Lanny Sinkin Christic Institute 1324 horth Capitol Street Washington, D.C. 20002

Mr. 5. Head, Representative Houston Lighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20214

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Mr. J. The NRC found that the work package reviews performed by BEC were thoroughly and comprehensively performed. However, since Bechtel did not adopt'all of i Brown and Root's design methodology but instead used some alternate approaches, it was agreed that additional supplements to the EAP in the civil / structural area are appropriate. This work will be reviewed by the NRC, when completed.

Sincerely, l

Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement

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Enclosure: Inspection Report Distribution:

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