ML20147B248
| ML20147B248 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/26/1988 |
| From: | Beck J, Hansel J, Jergenson E TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20147B224 | List: |
| References | |
| TAC-R00320, TAC-R320, NUDOCS 8803020026 | |
| Download: ML20147B248 (92) | |
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COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 i
COMANCHE PEAK RESPONSE TEAM i
COLLECTIVE SIGNIFICANCE REPORT O
TEXAS UTILITIES GENERATING COMPANY A DMSION OF O
TEXAS UTILITIES ELECTRIC COMPANY
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COMANCHE PEAK RESPONSE TEAM COLLECTIVE SIGNIFICANCE REPORT REVISION O 2 88 Desh n Aliequacy Retiew Te W Leader Date D
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$LJAJ An e -ec-a s CPRT Deputy P nVDirector Date W$. dW I 26 l88 CPRT Program Director #
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_.2d4/H John f. Beck, Chairman CPRT-SRT Date O
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COLLECTIVE SIGNIFICANCE REPORT TABLE OF CONTENTS Par't - I.
EXECUTIVE
SUMMARY
1.0 INTRODUCTION
AND' PURPOSE'OF COLLECTIVE SIGNIFICANCE REPORT 2.0 PURPOSE AND CONCLUSIONS OF COLLECTIVE SIGNIFICANCE REPORT 3.0 ADDITIONAL EVALUATION INCLUDED IN THE COLLECTIVE SIGNIFICANCE REPORT 4.0 EVALUATION OF DESIGN ADEQUACY AND THE DESIGN CONTROL PROGRAM 5.0- EVALUATION OF ADDITIONAL ACTIVITIES PERTINENT TO CER CONCLUSIONS REGARDING THE QUALITY OF CONSTRUCTION 6.0 EVALUATION OF THE INTEGRATION OF CONSTRUCTION 7.0 EVALUATION OF QUALITY ASSURANCE 8.0 EVALUATION OF TESTING 9.0 OVERALL CONCLUSIONS Part II.
INTRODUCTION
1.0 BACKGROUND
2.0 PURPOSE OF THE COLLECTIVE SIGNIFICANCE REPORT 3.0 ORGANIZATION OF COLLECTIVE SIGNIFICANCE REPORT Part III. EVALUATION OF DESIGN ADEQUACY
1.0 INTRODUCTION
_.1 Purpose
1.2 Background
1.3 Organization of Part III l
2.0 DESIGN ADEQUACY PROGRAM 3.0 CAP DESIGN VALIDATION PROGRAM 3.1 Scope, Objectives and Structures
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3.2 Design Validation Process 1
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Revioicn 0 Page 11 of iv TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT (Cont'd) 4.0 OVERVIEWS OF CPSES DESIGN PROGRAMS 4.1 Quality Assurance Programs 4.2 Technical Audit Program (TAP) 4.3 TU Electric Engineering Assurance (EA) 4.4 Engineering Functional Evaluation (EFE) 4.5 CPRT Overviews 5.0 EVALUATION OF DESIGN ADEQUACY 5.1 Introduction 5.2 Evaluation of CAP Design Validation Program Scope, Controls, Organization, and Methodology 5.3 Evaluation of CAP Design Validation Program Implementation 5.3.1 CPRT Overviews 5.3.2 Evaluation of the TAP 5.3.3 Evaluation of EFE 5.3.4 Evaluation of QA and EA
6.0 CONCLUSION
S Part IV.
EVALUATION OF CONSTRUCTION QUALITY
1.0 INTRODUCTION
1.1 Purpose
1.2 Background
1.3 Organization cf Part IV 2.0 RESULTS OF EVALUATIONS OF QUALITY OF CONSTRUCTION REPORTED IN CER 3.0 RESULTS OF OTHER CPRT INVESTICATIONS RELATED.TO THE QUALITY OF CONSTRUCTION 3.1 Project Evaluation of CPRT Findings 3.2 Summary of ISAP VII.a.9 Results
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Page iii of iv TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT (Cont'd) 4.0 OVERVIEW OF PROJECT CORRECTIVE ACTIONS 5.0 CPRT EVALUATION OF CURRENT CPSES CONSTRUCTION PROCESS 6.0 CPRT CONCLUSIONS REGARDING QUALITY OF CPSES CONSTRUCTION Part V.
EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION 1.0 INTROT:UCTION 1.1 Purpose 1.2 Backs;round 1.3 Organization of Part V
2.0 DESCRIPTION
OF THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP) 2.1 Methodology 2.2 Development of the Commodity / Attribute Matrix 2.3 Attribute Evaluations 2.4 Determinations of Accessibility 2.5 Physical Validation of Accessible Attributes 2.6 Technical Disposition for Inaccessible Attributes 2.7 Hardware Modifications 2.8 Use of Results from the PCHVP 3.0 FINAL RECONCILIATION PROCESS 4.0 QA AND OVERVIEW ACTIVITIES 4.1 QA Programs 4.2 Technical Audit Program (TAP) 4.3 Engineering Functional Evaluation (EFE) l 4.4 CPRT Overview 5.0 CPRT EVALUATION l
6.0 CPRT CONCLUSIONS REGARDING THE INTEGRATION OF DESIGN AND CONSTRUCTION
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TABLE OF CONTENTS COLLECTIVE SIGNIFICANCE REPORT (Cont'd) 1 Part VI.
QUALITY ASSURANCE
1.0 INTRODUCTION
1.1 Background
1.2 Purpose 1.3 Organization of Part VI 2.0 CPRT EVALUATION OF CPSES QA PROGRAM FOR DESIGN CONTROL 3.0 RESULTS OF CPRT EVALUATION OF CPSES CONSTRUCTION QA REPORTED IN THE CER 3.1 Results Presented in the CER 3.2 Effect on CER,Results of ISAP VII.a.9 Investigations 3.3 Summary of Construction QA Results Presented in the CER and in ISAP VII.a.9
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4.0 OVERALL CONCLUSIONS WITH RESPECT TO THE CPSES QA PROGRAM Part VII. EVALUATION OF TESTING
1.0 INTRODUCTION
1.1 Baclground 1.2 Purpose 1.3 Organization of Part VII 2.0
SUMMARY
OF CPRT EVALUATION OF TESTING PRESENTED IN THE CER
3.0 DESCRIPTION
OF TESTING OF VALIDATED HARDWARE AND DESIGN 4.0 CPRT OVERALL CONCLUSIONS REGARDING THE CPSES TESTING PROGRAM Part VIII. OVERALL CONCLUSIONS
1.0 CONCLUSION
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l Rsvision 0 Pago 1 of 10 Part I - EXECUTIVE
SUMMARY
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1.0 INTRODUCTION
AND PURPOSE OF COLLECTIVE SIGNIFICANCE REPORT The Comanche Peak Response Team (CPRT) was established by TU Electric to inves-tigate various issues raised by the Nuclear Regulatory Commission Technical Review Team (TRT) regarding the Comanche Peak Steam Electric Station (CPSES).
Its scope was subsequently expanded to include major self-initiated investiga-tions of the adequacy of the design and quality of construction of CPSES.
The CPRT is comprised of third-party individuals who have had no previous involvement in the CPSES activities that they review.
The CPRT program consists of two principal types of activities.
First, the CPRT performed investigations to determine the adequacy of various aspects of the design, construction and testing of CPSES and of the associated quality assurance (QA) programs.
These investigations were performed pursuant to Tasue-Specific Action Plans (ISAPs) for the TRT-identified design, construction, QA, and testing-related issues; execution of the ISAPs resulted in recommendations for corrective action where required.
Separate investigations of the CPSES design were performed pursuant to Discipline-Specific Action Plans (DSAPs) under the Design Adequacy Program (DAP).
The DAP resulted in identification of issues that were referred to the Project for resolution.
Second, having concurred with the Project plans for addressing the CPRT recommendations, the CPRT is overviewing implementation of the corrective action that resulted from the ISAPs and resolution of the issues identified by the DAP.
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The CPRT has completed its investigations of the quality of construction, the construction QA program and testing.
The Collective Evaluation Report (CER) summarizes the results of these CPRT investigations.
Based in part on the preliminary results of the DAP, the Project developed the Corrective Action Program (CAP).
The CAP includes a comprehensive validation of the CPSES design (the design validation program) and a program of inspections, walkdowns and evaluations to validate that CPSES hardware conforms with the validated design (the Post Construction Hardware Validation Program
[PCHVP]).
The CAP encompasses the corrective actions that resulted from the ISAPs and resolution of the issues identified by the DAP.
The CPSES programs for design validation and hardware validation are overviewed by the CPRT.
The purpose of the Collective Significance Report (CSR) is to provide an I
integrated perspective of the results of the CPRT investigative and overvicw activities.
This is provided in the context of a CPRT conclusion as to whether the corrective actions encompassed by the CAP, when completed, provide l
l reasonable assurance that the CPSES structures, systems and components will be l
capable of performing their intended safety functions.
The CSR is also the vehicle through which the CPRT provides its evaluation of design adequacy and I
through which the CPRT closes out several open issues noted in the CER.
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RIvicion 0 Paga 2 of 10 Part I - EXECUTIVE
SUMMARY
(Cont'd) 2.0 PURPOSE AND CONCLUSIONS OF COLLECTIVE EVALUATION REPORT The purpose of the CER was to draw overall conclusions regarding the quality of construction, the adequacy of the current and historical construction QA programs, and the adequacy of the testing program.
The CER contained the following conclusions:
Quality of Construction The CPRT performed reinspections and documentation reviews of a sample of safety-related items at CPSES based upon the October 1985 design (or, in some cases, a later applicable design).
The results of the CPRT reinspections and documentation reviews demonstrate a high conformance rate, with 98 percent of the inspection points found to be in conformance with design requirements. Of the two percent of the inspection points and documentation review points found to deviate from design requirements, the CPRT determined that more than three fourths were insignificant. The CPRT also identified 93 findings.
Corrective and preventive action is being taken for each CPRT finding to ensure the adequscy of existing hardware and of future programs.
The corrective actions defined by the CPSES Project for CPRT findings are subject to concurrence by the CPRT_, and the CPRT conducts overviews to assure that the corrective actions are appropriately implemented.
In addition, the CAP requires appropriate resolution of each CFRT-identified deviation, whether or not the CPRT determined that the deviation was a finding.
Based upon the results of its investigations of the quality of CPSES construction and upon its collective evaluation of those results, the CPRT concluded that, upon completion of the corrective action for findings identified by the CPRT, there will be reasonable assurance that the structures, systems, and components of CPSES will meet the significant, sefety-related requirements of the October 1985 design (or later applicable design).
Quality Assurance Program During its investigations, the CPRT examined the carrent QA program for construction of CPSES under each of the 18 criteria of 10CFR50, Appendix B (except Criterion III, which pertains to Design Control).
The CPRT determined that the current CPSES construction QA program i
effectively implements 10CFR50, Appendix B.
l The CPRT also evaluated the adequacy of the historical QA program for construction of CPSES. The CPRT concluded, in general, that implementation of the historical QA program was effective and i
satisfied the applicable requirements of 10CFR50, Appendix B.
I However, the CPRT did identify weaknesses in certain areas of the I
historical QA program related to Criteria I, II, V, VII, X, XV and f
XVIII.
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Revision 0 Page 3 of 10 Part I - EXECUTIVE
SUMMARY
(Cont'd)
The CPRT has determined that appropriate preventive action to resolve the QA program-related findings noted by the CPRT has been or is being taken, and that the areas of construction that were related to these i
findings are being reinspected and/or re-evaluated and, where required, corrected.
Testing Program Eight ISAPs were initiated by the CPRT that related to various parts
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of the CPSES testing program.
In each case, the CPRT determined that the CPSES testing program was adequate and was being properly implemented. Although findings related to certain activities under the jurisdiction of Startup were identified in other ISAPs, these findings were limited in nature and had unrelated root causes.
Furthermore, corrective action was taken for each of the findings, p
including action to prevent recurrence.
Therefore, the CPRT concluded that the CPSES testing program and other acti"ities under the jurisdiction of Startup that were examined by the CPRT are generally adequate and that no additional corrective action is necessary beyond that which has been taken for the individual findings identified by the CPRT.
The overall conclusion of the CER was that, upon completion of the corrective actions
- recommended by the CPRT, including those resulting from collective evaluation, there will be reasonable assurance that the structures, systems and O
components of CPSES meet the significant., safety-related requirements of the P
October 1985 design (or later applicable design).
3.0 ADDITIONAL EVALUATIONS INCLUDED IN THE COLLECTIVE SIGNIFICANCE REPORT s
In addition to the activities discussed in the CER, the CPRT performed the following evaluations:
Evaluation of design adequacy and the design control program; Evaluation of the impact of the results of recently completed activities (Project analysis of certain CPRT findings and the results of ISAP VII.a.9 - Quality of Purchased Safety-Related Material and Equipment) on the CER conclusions regarding the quality of construction; Evaluation of the Project program for integrating the results of the CPRT evaluation of the quality of CPSES construction quality and the design validation program; l
The CPRT Program Plan, Appendix H, provides for the development and l
overview of these corrective actions; completion may be based on O
alternative responses developed by the Project and concurred in by the CPRT.
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SUMMARY
(Cont'd)
G ll Evaluation of the impacts of recently completed activities (ISAP VII.a.9, and evaluations of the current design QA program) on the CPRT conclusions regarding the CPSES QA program; and l
Review of Project program for testing of items modified or installed as a result of the CAP or otherwise requiring testing.
Each of these is discussed below.
4.0 EVALUATION OF DESIGN ADEQUACY AND THE DESIGN CONTROL PROGRAM TU Electric established a design validation program under the CAP to validate that the safety-related design and selected non-safety-related portions of the CPSES design comply with current licensing commitments and regulatory requirements.* The CPRT has evaluated the Program and concluded that:
The scope of the CAP is adequate.
First, the CAP is resolving all design issues identified by external sources and the CPRT.
- Second, the scope of the CAP addresses all CPSES safety related design disciplines on a comprehensive basis. This aspect of the CAP is designed to assure that the generic implications of known design issues and any pre.viously undetected design issues are identified and resolved by the CAP and that no undetected safety-significant design-related deficiencies will exist in the CPSES validated design.
The controls governing the implementation of the CAP are acceptable.
TU Electric has implemented a comprehensive restructuring of its corporate nuclear program and has established a hierarchical framework of procedures which is modeled after other successful industry programs.
Contractors are required to develop procedures associated with CAP implementation in accordance with the governing TU Electric procedures.
The organization of the CAP is sufficient to implement the CAP in a technically correct and objective manner.
Experienced nuclear managers have been hired for tne key TU Electric positions.
The experience and qualifications, as well as the number of professionals on the TU Electric engineering staff, are sufficient to enable TU Electric to perform and manage internal engineering activities as well as control the work of contractors and their interfaces.
The engineering contractors implementing the CAP are experienced in the design of nuclear power plants and have the requisite objectivity to review and validate the CPSES designs because they were not l
responsible for the original design and thus are not placed in the i
position of evaluating their own work.
Nuclear Steam Supply System (NSSS) design and vendor hardware design and their respective QA/QC programs are not included in the Corrective Action Program; however, the design interface is included in the CAP.
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Rsvision 0 Pcgs 5 of 10 Part I - EXi UTIVE
SUMMARY
(Cont'd)
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The-ithodology used by the CAP to validate the design is sound.
Desik -criteria are verified to comply with licensing commitments and are it orporated within Design Basis Decuments to provide a b' asis for design ralidation. Each design is reviewed and validated and any l
require modifications identified. Necessary_ modifications are identit ed based upon the design validation and hardware validations of the iP.
The CPRT has also evaluated implementation of the design validation program through a combination of overviews performed by CPRT personnel, including implementation of selected DSAPs and ISAPs, and CPRT assessments of the overviews of the CAP performed by the TU Electric QA Technical Audit Program (TAP) and the Engineering Functional Evaluation (EFE).
The results of these evaluations are as follows:
The CPRT has overviewed implementation of the design validation program. The current results of this overview indicate that:
licensing commitments have been translated into appropriate design criteria; engineering requirements have been properly translated into specifications for construction and inspection; design-related issues that were identified in ISAP Results b
Reports as requiring additional CPRT action are being reviewed and closed; and calculations, specifications, drawings, and other design documentation are being adequately prepared to support the final l
plant design conditions.
The CPRT has overviewed and is monitoring the TAP, EFE, and other audit and surveillance programs related to the CAP and has determined 3
i that:
The TAP provides a reliable and effective means to assess the technical adequacy of the CAP and its implementation. Because the L
TAP provides an objective and appropriately detailed technical assessment of tha adequacy of CAP implementation, the TAP is capable of properly identifying and classifying discrepancies during its audits. The TAP requires audited organizations to provide appropriate responses to TAP audit findings and to define and implement corrective actions in response to specific audit findings, and performs follow-up evaluations to verify the adequacy of implementation of corrective and preventive actions developed in response to TAP audit findings.
The EFE provides a reliable and effective means to assess the h
technical adequacy of the CAP and its implementation because the EFE is providing a thorough, objective, and appropriately detailed technical assessment of the adequacy of CAP
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SUMMARY
(Cont'd)
O implementation. The EFE is requit.og the CAP organizations to provide appropriate responses to EFE Action Items and to define and implement necessary corrective and preventive actions, and the EFE reviews responses to its findings to assure that the extent of any problem and the root causes are identified and bounded.
TU Electric QA and Engineering Assurance (EA) organizations have performed audits and surveillances of the CAP engineering contractors.
These activities have both technical and programmatic elements and are per.Yrmed in accordance with approved procedures. Technical and programmatic issues that are identified are required to be resolved.
Based upon review of the l
implementation of these programs, together with the organizations and procedures in place, the CPRT concludes that the TU Electric QA and EA programs are adequately structured to provide reasonable assurance of the implementation of remaining CAP i
design-related activities.
Finally, the CPRT performed an evaluation of the scope of the current design control program for CPSES to determine whether it complies with applicable criteria in 10CFR50, Appendix B, and industry standard ANSI N45.2.11, which contains requirements for design control for nuclear power plants.
In performing this evaluation, the CPRT reviewed several types of documents, including the CPSES QA Manual, the description of the CPSES QA program in Chapter 17.1 of the FSAR, relevant NEO policies and procedures, selected engineering, QA and operations procedures, and selected contractor procedures.
Additionally, the CPRT relied upon the experience and information collected during implementation of the DSAPs and CFRT overviews. As a result of its review of the CPSES design control program, the CPRT found that the CPSES design control program adequately addresses the design related criteria of 10CFR50, Appendix B and ANSI N45.2.ll.
Additionally, the CPRT determined that TU Electric has taken actions to address and correct the potential weaknesses in the past design program identified by the CPRT.
Based upon the above, the CPRT concludes that the CAP provides a sufficient means of identifying and resolving all design concerns and for validating that the CPSES design complies with current licensing. commitments and regulatory l
requirements; the current results of CPRT overviews of CAP indicate that the design validation program has been properly implemented and that the various audit and overview programs at CPSES are sufficient for assuring design validation; and the current CPSES design control program adequately addresses the design-related criteria of 10CFR50, Appendix B and ANSI N45.2.11.
5Property "ANSI code" (as page type) with input value "ANSI N45.2.11.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..0 EVALUATION OF ADDITIONAL ACTIVITIES PERTINENT TO CER CONCLUSIONS REGARDING THE QUALITY OF CONSTRUCTION Since the issuance of the CER, the Froject and CPRT have performed additional activities that supplement and confirm the results presented in the CER as follows:
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l Part I - EXECUTIVE
SUMMARY
(Cont'd)
The Project has performed en6 aeering evaluations of the findings 1
identified by the CPRT that included at least one safety-significant or unclassified hardware deviation. The Project determined that for i
more than three fourths of these findings, the found condition would not have prevented achieving or maintaining a safe plant condition (the results of the Project evaluation of the remainder of the findings were indeterminate).
Based upon its review of the Project's evaluations to date, the CPRT concludes that these evaluations confirm the conservatism inherent in the CPRT conclusions regarding the quality of CPSES constructic 3.
In ISAP VII.a.9, the CPRT examined the compliance of equipment and material procured under the TU Electric and Brown & Root procurement programs for CPSES to their applicable specifications under the October 1985 design.
ISAP VII.a.9 was not completed prior to the issuance of the CER, and the final results of that ISAP were therefore not discussed in the CER.
ISAP VII.a.9 included reinspection of samples of procured equipment and/or review of quality documentation for 62 different vendors supplying items to CPSES.
Of approximately 195,000 reinspection / review points, 94 percent were found to be acceptable.
If insignificant deviations are also counted as acceptable, then 99 percent of the reinspection / review points would be acceptable.
Seven types of findings were identified during the ISAP VII.a.9 investigation. The conditions identified in four of these types of findings had been previously identified, and Project O
corrective action for these items had been taken or was underway at the time the Results Report for ISAP VII.a.9 was issued.
The CPRT has provided the Project with recommendations for corrective action to address the remaining three types of findings.
The CPRT concludes that, in general, the historical procurement program was adequate and, that upon implementation of corrective action plans developed in response to the recommendations made by the CPRT, there will be reasonable assurance that purchased safety-related material and equipment at CPSES meet the significant, safety-related requirements of their applicable specifications under the October 1985 design.
Thus, the ISAP VII.a.9 results generally complement the results presented in the CER with respect to the quality of CPSES construction.
The CPRT is overviewing Project corrective actions related to CPSES hardware and construction processes. The corrective actions proposed by the Project in response to CPRT findings are subject to concurrence by the CPRT.
The CPRT and the Project are in the process of finalizing corrective action plans for findings from the CER and ISAP VII.a.9, and have reached agreement on corrective action plans for the remaining CPRT dings.
The TAP is examining the corrective actions undertaken by 6.. Proj ect (1) to assure that Project commitments for corrective action are captured in a formal control system; (2) to assure that the corrective actions are properly implemented; and (3) to assure that corrective actions are adequately completed and
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documented.
Additionally, the CPRT is overviewing the Project implementation of selected corrective action commitments.
This overview focuses primarily on the TAP.
The CPRT overview of TAP
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SUMMARY
(Cont'd) in 1 cates that the TAP is fulfilling its program objectives with respect to corrective actions. The CPRT overview of the TAP and verification of isr/ ementation of selected corrective actions will l
continue until the CPRT concludes that there is sufficient evidence I
that all corrective actions will be properly implemented.
Based upon the above, the CPRT concludes that, upon completion of the corrective action for findings identified by the CPRT, there will be reasonable assurance that the structures, systems, and components of CPSES will meet the significant, safety-related requirements of the October 1985 design (or later applicable design).
6.0 EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION The CPRT has evaluated the elements of the CAP for integrating the results of design validation and the evaluation of construction quality and has found that they afford an acceptsble means for assuring thct the hardware at CPSES will conform with the validated design. This conclusion is based upon the following factors:
The scope and depth of the PCHVP are extensive. The PCHVP addresses
,through physical validation or an engineering evaluation resulting in a technical disposition those attributes recommended for reinspection by the CPRT, attributes where the design validation program could potentially affect conformance of the attributes, and any final acceptance attribute not evaluated by the CPRT.
The methods of hardware validation are appropriate.
Accessible attributes are subject to physical validation by either QC inspection or engineering walkdowns, and inaccessible attributec are subject to engineering evaluation to arrive at a technical disposition of the f
acceptability of the attributes.
Appropriste controls govern the PCHVP process and the integration of the results of design validation nd the evaluation of the quality of construction. Attributes included within the scope of the PCHVP were identified on a Commodity / Attribute Matrix. The adequacy of this matrix is being overviewed by the CPRT and the TAP.
Physical validation is performed in accordance with procedures (Field Verification Methods (PVMs]) by certified QC inspectors or by trained and qualified engineering personnel. Discrepancies that are identified between the installed hardware and design requirements are subject to a reconciliation process. This process is structured to assure that the hardware is modified to comply with the validated design, or the validated hardware is determined to satisfy its intended design function and the design is reconciled with the validated hardware.
QA audits and overview programs are structured to provide assurance that the TU Electric program for integrating design and construction activities is properly implemented.
Revision 0 Page 9 of 10 Part I - EXECUTIVE
SUMMARY
(Cont'd)
Based upon the above, the CPRT finds that tha program for integrating the CPSES design and construction is adequate and that the overviews of this program are adequate for assuring the proper implementation of the program. Therefore, the CPRT concludes that the completion of tie CAP will provide reasonable assurance that the structures, systems, and components at CPSES are capable of performing their intended safety functions.
7.0 EVALUATION OF QUALITY ASSURANCE I
As discussed in Section 2.0 the CPRT evaluated the historical and current CPSES
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construction QA program. The CPRT concluded that the historical CPSES construction QA program was generally adequate, although there were problems in specific areas.
The CPRT also concluded that the current CPSES construction QA program effectively implements 10CFR50, Appendix B.
The CPRT conclusions presented in the CER did not reflect the final results of ISAP VII.a.9 relating to CPSES procurement programs. The final results of ISAP VII.a.9 did not alter the CER evaluation of the CPSES QA program. An additional recommendation was made under Criterion VII to verify that activities relating to procurement of electrical equipment, such as engineering reviews, vendor surveillance, and receipt inspections, are conducted in sufficient depth to prevent recurrence of problems noted in ISAP VII.a.9 with respect to procured electrical equipment.
Because the CPRT conclusions in the CER pertained to the CPSES construction QA program, those conclusions did not encompass to the. CPSES design control program. As discussed in Section 4.0, the CPRT has determined that the current CPSES design control program meets the requirements of ANSI N45.2.ll and adoquately addresses the potential weaknesses identified for the historical design control program. Thus, the current design control program for CPSES meets the applicable requirements of 10CFR50, Appendix B.
Based on the above, the CPRT concludes that the CPSES QA program adequately addresses each of the elements of 10CFR50, Appendix B.
8.0 EVALUATION OF TESTING The CPRT investigated the CPSES testing program during implementation of a number of ISAPs. A collective evaluation of the results of these investigations was presented in the CER.
In addition, the CPRT has reviewed the CPSES program for evaluation and testing o' components and systems that are modified or installed as a result of the design validation and PCHVP programs, or that might require additional testing for other reasons. The C?RT concludes that the CPSES testing program is capable of assuring that the as-built plant meets the safety-related requirements of the validated design that are amenable to startup and preoperational testing.
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SUMMARY
(Cont'd) 9.0 OVERAL1. CONCLUSIONS Based upon the results of its investigative and overview activities, the CPRT concludes that:
The current programs for design, construction, testing, and acaurance of quality of CPSES are adequate, and problems arising from weaknesses in the historical programs have been identified and appropriate corrective action has been defined; The CAP provides an adequate means of vat, dating the design and hardware for CPSES, and the CPSES QA program, the Technical Audit Program, the Engineering Functional Evaluation, and other audit and overview programs provide adequate means for asa.uring acceptable implementation of the CAP; and The corrective actions encompassed by the CAP provide reasonable assurance that the structures, systems, and components at CPSES will be capable of performing their intended safety functions.
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Part II - INTRODUCTION j
1.0 BACKGROUND
The Comanche Peak Response Team (CPRT) was established by TU Electric to inves-tigate various issues raised by the Nuclear Regulatory Commission Technical Review Team (TRT) regarding the Comanche Peak Steam Electric Station (CPSES).
Its scope was subsequently expanded to include major self initiated investiga-tions'of the adequacy of the design and quality of construction of.CPSES. The CPRT mission is to determine whether there is reasonable assurance that all i
design and construction defects that would have prevented CPSES from being capable of operation in conformance with NRC xegulations have been detected, and that appropriate corrective -actions for these defects have been defined. The j
CPRT is comprised of third party individuals who have had no previous
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involvement in the CPSES activities that they review.
s The CPRT program consists of two principal types of activities.
First, the CPRT performed. investigations to determine the adequacy of various aspects of the design, construction'and testing of CPSES and of the associated qualLty assur-ance (QA) programs. These investigations were performed pursuant to Issue Specific Action Plans (ISAPs) for the TRT-identified design, construction, 1
QA, and testing-related issues.
These ISAPs resulted in recomasadations for corrective action where required.
Separate investigations of the CPSES design were performed pursuant to Discipline Specific Action Plans (DSAPs) under the Design Adequacy Program (DAP).
Issues identified through the DAP were addressed i
by the CPSES Project through a comprehensive Corrective Action Program (CAP).
Second, having concurred with the Project plans for addressing the CPRT recom-mendations and developing the CAP, the CPRT is overviewing. implementation of the corrective action that resulted from the ISAPs and resolution of the issues identified by the DAP.
The Project corrective action and issue resolution
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efforts are encompassed within the CAP.
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The CPRT has completed its investigation of the quality of construction, the construction QA program, and testing. That investigation confirmed that a substantial portion of the plant has been constructed adequately, and that the current QA and testing programs are adequate.
It also identified and bounded i
those hardware and QA problems, and associated construction processes, r3 quired to be corrected to provide reasonable assurance that the CPSES structures, 3
j.
systems, and components will meet the significant, safety related requirements i
of the October 1985 design (or later applicable design).
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The Collective Evaluation Report (CER), Revision 0, incorporated by reference l
l into this report, summarizes the CPRT investigations of the quality of CPSES construction, the construction QA program, and testing. The CER references the various ISAP Results Reports that document the details of the CPRT investi-j gations. As discussed in Part IV of this report, the CER identifies acceptable l
hardware, provides bounds on the historical problems (or issues) related to the i
construction of CPSES and the associated construction QA program, and identifies necessary corrective actions to establish an acceptable construction process and to correct hardware defects.
Partially in response to preliminary findings identified by the DAP, the CPSES O.
Project developed the CAP to include comprehensive design and hardware I
validation programs.
The design issues addressed by the design validation 1
program are identified in 11 Project Status Reports (PSRs). The PSRs report on
R;visicn 0 Page 2 of 3 Part II - INTRODUCTION (Con 9'd) the design validation effort and state that the adequacy of the safety related design (and selected non s afety related portions of the design) has been substantiated in many instances and that design changes have been developed, where required, to establish a validated design that is consistent with the current licensing comattments for CPSES. As discussed in Part III of this I
report, potential weaknesses in the historical design process have also been l
identified by the CPRT and addressed in sufficient detail to assure their I
correction in the CAP and future design programs.
In r.am.arv, the CER and CPRT Results Reports demonstrate the acceptability of most of the CPSES hardware as designed and constructed. They also identify a spectrum of issues (some of which substantiate issues raised by the TRT and other external sources) with the design, the h?.rdware, the associated design and construction processes and the QA programs.
These issues, as they developed historically at CPSES, have resulted in the CAP, e comprehensive corrective action effort.
2.0 PURPOSE OF THE COLIACTIVE SIGNIFICANCE REPORT The purpose of the Collective Significance Report (CSR) is to provide an integrated perspective of the results of the CPRT investigative and overview activities. This is provided in the context of a CPRT conclusion as to whether the corrective actions encompasned by tho CAP, when completed, provide reasonable assurance that the CPSES structures, systems and components will be capable of performing their intended safety functions. The CSR is also the vehicle through which the CPRT provides its evaluation of design adequacy and through which the CPRT closes out two open issues noted in the CER.
3.0 ORGANIZATION OF COLLECTIVE SIGNIFICANCE REPORT The remainder of this report i:: comprised of the following six parts:
Part III, Evaluation of Design Adequacy, presents the CPRT evaluation of the CPSES design, including the CPRT assessment of the adequacy of the associated design control program, based on the CPRT examination of the design validation program being performed as part of the CAP.
Part IV, Evaluation of Construction Quality, presents the CPRT evaluation of the quality of CPSES construction, including vendor supplied equipment, relative to the October 1985 design (or later applicable design); this part also presents the CPRT conclusions regarding the adequacy of the current construction program.
The Project Corrective Action Program encompasses CPSES Unit 1 and areas common to Units 1 and 2.
Should Tl1 Electric decide to use equivalent procedures or processes for completing Unit 2 as are being used for Unit 1 and common areas, the conclusions stated in this report are applicable to Unit 2 as well as to Unit 1 and the common areas. The use of the term "CPSES" in this report relates either to CPSES Unit 1 and common areas or the CPSES Units 1 and 2 and common, as appropriate.
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~R3visien 0 Page 3 of 3 Part II - INTRODUCTION (Cont'd)
Part V Evaluation of the Integration of Design and Construction, presents the CPRT evaluation of the Project programs for assuring that CPSES, as constructed, conforms with the validated design.
Part VI. Evaluation of Quality Assurance, presents the CPRT evaluation of the TU Electric quality assurance program.
Part VII, Evaluation of Testing, presents the CPRT evaluation of the CPSES testing program.
Part VIII Overall Conclusions, presents the CPRT overall conclusions, based upon the investigations performed.
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'. 0 INTRODUCTION 1.1 Purpose The purpose of this evaluation of CPSES design adequacy is to present-the CPRT-
. conclusions regarding:. (1) the adequacy of the safety related design of CPSES*
and (2).the adequacy of CPSES policies, programs, and procedures related to the design.of CPSES. A summary description of the activities, results, and bases supporting these conclusions is also provided.
1.2 Background-A summary of the historical progression and evolution of issues and programs concerning CPSES design adequacy is presented below.
During the 1982-1983 hearings before the NRC Atomic Safety and Licensing Board (ASLB) on application for an operating license for CPSES, an intervenor, the Citizens Association for Sound Energy (CASE), raised issues related to design adequacy (i.e., the "Walsh Doyle concerns"). These issues were primarily associated with the adequacy of safety-related pipe stress analyses and pipe support designs.
In a partial initial decision dated December 28, 1983, the ASLB suggested actions to address the potential that similar concerns might exist in other safety-related aspects of the CPSES design.
O During this same period, Cygna Energy Services (Cygna) was conducting a
'q) two phase independent assessment of the CPSES design and design control process to provide the NRC staff with additional assurance that the plant was designed and constructed in accordance with the FSAR commitments. As a result of the ASLB decision, TU Electric contracted with Cygna in early 1984 to expand the scope of its independent assessment-to address the specific ASLB concerns related to CPSES design adequacy.
In mid-1984, the NRC established a Technical Review Team (TRT), which was responsible for assuring the overall coordination, integration, and resolution of technical issues and allegations regarding the design and construction of CPSES. Most of these concerns were related to CPSES construction practices or quality control activities; however, some were related either directly or
' indirectly to CPSES design adequacy.
In September 1984, TU Electric formed the Comanche Peak Response Team (CPRT) to develop and carry out a program to resolve issues identified by the TRT, including design concerns. The CPRT has investigated and resolved these issues Nuclear Steam Supply System (NSSS) design and vendor hardware design and their respective QA programs are not evaluated by CPRT; however, the design interface is included.
/~'s Portions of selected non safety-related systems, structures and components are evaluated by CPRT. These are Seinmic Category II systems, structures and components, and fire protection systems.
R;vicirn 0 Pcgo 2 cf 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) through a series of Issue-Specific Action Plans (ISAPs) contained in the CPRT Program Plan.
In early 1985, TU Electric expanded the scope of CPRT activities to include the evaluation and resolution of design issues identified by all "external sources" (e.g., the NRC, CASE, ASLB, Cygna).
In addition, the charter of the CPRT was expanded to include two comprehensive self-initiated evaluation programs; one concerning the quality of construction and the other concerning design adequacy.
In the design area, the CPRT established the Design Adequacy Program (DAP),
consistin5 of a series of Discipline-Specific Action Plans (DSAPs).
The DAP consisted of investigations of design related external source issues and a self-initiated investigation of the CPSES safety-related design.
The self-initiated evaluation portion of the DAP was designed to provide a comprehensive assessment of CPSES design adequacy through reviews of designs representative of the aggregate architect / engineer (A/E) design activities.
The evaluation considered design criteria, engineering disciplines, processes, and organizations involved in the design of the safety-related aspects of CPSES.
(See Section 2.0 for additional information on the DAP.)
As noted in Revision 4 of the CPRT Program Plan, TU Electric made a series of decisions in mid-1986 regarding corrective action programs for CPSES based on many considerations, including the preliminary results of the investigative phase of the DAP self-initiated evaluation.
TU Electric concluded that the appropriate method to resolve the issues identified by the CPRT and to identify and resolve any other issues that potentially existed at CPSES would be through one integrated program rather than a separate program for each issue.
Accordingly, TU Electric initiated a comprehensive Corrective Action Program (CAP) that included the validation of both the design and the hardware at CPSES, including resolution of specific CPRT and external source issues.
(See Section 3.0 for additional information on the design validation portion of CAP.)
On the basis of its review of the CAP scope, methodology, project management, and quality assurance provisions, the CPRT Senior Review Team (SRT) concurred that the CAP provided a suitable alternative means for achieving the design adequacy-related objectives of the CPRT Program Plan and obviated the need for completing all elements of the DAP.
(See Revision 4 of the CPRT Program Plan for details of the changes to the DAP as well as a discussion of the bases for these changes.)
Accordingly, the focus of CPRT activities chsnged from the evaluation of the original CPSES design to overviews intended to assess the effectiveness of the CAP execution, with particular emphasis on the achievement of CPRT Program objectives (i.e., resolution of all external source issues, identification and resolution of previously unidentified safety-significant issues, and the establishment and implementation of programmatic improvements.
In making its evaluation, the CPRT is employing a combination of direct overview of CAP programs, procedures, and products, and assesscents of CAP overview activities completed by others (e.g., the TU Electric Quality Assurance Technical Audit Program { TAP) and the Engineering Functional Evaluation (EFE)).
In addition, Cygna, through implementation of the Independent Assessment Program, is reviewing the technical
t Revisicn 0 Page 3 of 41 Part III - CVALUATION OF DESIGN ADEQUACY (Cont'd) responses to the issues it identified. Cygna has completed this review for issues related to piping and has concurred with the corresponding TU Electric technical resolutions. Cygna's review is continuing for remaining issues.
1.3 Organization of Part. III Section 2.0 presents a surmary of the DAP, as-hplemented, including a discussion of DAP results.
l Section 3.0 presents a description of the design validation portion of the CAP l
implemented by TU Electric to validate the adequacy of the CPSES design.
Section 4.0 presents a discussion of the various overview programs, including the TAP and EFE, that provide additional assurance that the design validation process was implemented as intended.
Section 5.0 presents the results of the CPRT evaluation of the CAP design validation activities. This evaluation includes the CPRT assessment of the adequacy and effectiveness of the TAP and the EFE in assuring the quality and technical adequacy of the CAP results.
Section 5.0 also presents the results of the CPRT evaluation of the CPSES design control program.
Section 6.0 presents the CPRT conclusions concerning the design adequacy of CPSES and the CPSES design control program.
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R', vision 0 Page 4 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) 2.0 DESIGN ADEQUACY PROGRAM TU Electric charged the DAP with a mission of addressing all design-related concerns raised by external parties (termed external source issues (ESIs]) and determining whether additional design-related concerns existed elsewhere in the f
same or similar form.
This program was conducted under a QA pr
- ram.
The NRC i
staff reviewed and approved the DAP and its QA program. The DAP developed two approaches, one for addressing ESIs and the other for undertaking a l
comprehensive, self-initiated, sample based evaluation of the A/E safety related l
design scope.
The combined results of the execution of these elements of the DAP yielded a consolidated listing of issues that served as input to TU Electric's decision to conduct a comprehensive design validation through the l
CAP.
DAP personnel documented specific issues, identified by external sources (e.g.,
CASE, the NRC staff, Cygna) or by DAP reviewers, on Discrepancy / Issue Resolution (DIR) reports.
In August 1986, TU Electric requested that the DAP provide discipline summartes of related DIRs to assist in TU Electric's structuring of the design validation portion of the CAP. This information was summarized in engineering evaluations termed Issue Resolution Reports, which were issued in the fall of 1986.
In areas examined by the self-initiated program, the DAP found that most of the design of CPSES was adequate; however, the level o.! design documentation, control, and verification of the original A/E designs was below current industry standards in many areas.
Compared to current day ptsetices, potential weaknesses existed in the areas of design control and procedural compliance, particularly in the translation of licensing commitments into design criteria and engineering documentation, where it appears that changing regulatory requirements and evolving industry standards created difficulties. These potential weaknesses led to instances where CPSES hardware required redesign to meet licensing commitments and current industry standards.
In order to help TU Electric in the formulation of the CAP, the CPRT provided TU Electric with a listing of causes* judgtsd to bound all design discrepancies at CPSES. This listing of causes encompar. sed the potential weaknesses identified by the DAP. The CPRT judged that if the corrective and preventive actions were structured to address these areas, then any safety-related design discrepancies l
would be identified and corrected.
TU Electric's decision to structure the CAP to include a comprehensive design validation program was based on the scope of the consolidated listing of DAP i
l issues, which included each design discipline, and the belief that the best method to address these issues was through an integrated program rather than through a separate program directed at each issue.
The CAP activities were divided into eleven topical areas, which have been termed "design disciplines,"
as discussed in Section 3.0.
Project Status Reports (PSRs) for each discipline document the resolution oi' external source and CPRT issues as well as additional
)
design issues identified in the implementation of the CAP.
9 Letter, J. Beck to W. Counsil, February 4, 1987.
Rsvieicn 0 Page 5 of 41 Part III EVALUATION OF DESICN ADEQUACY (Cont'd)
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The resolution methodology for four.of the CAP disciplines (Large Bore Piping and Pipe Supports; Cable Tray and Cable Tray Hangers; Conduit Supports, Trains A, B, & C > 2"; and Conduit Supports, Train C < 2") was evaluated by DAP and documented in DSAP Results Reports which summarize CPRT's respective conclusions. As discussed more fully in Section 4.5, in all cases, the CPRT
-endorsed the CAP resolution of issues in these four design disciplines. The CPRT conclusions in the Large Bore Piping and Pipe Supports discipline are generally applicable to Small Bore Piping and Pipe Supports because the CAP engineering procedural and technical requirements are generally similar for small bore piping and pipe supports. The other six CAP design disciplines were not evaluated by DAP; however, these disciplines were r, valuated by the CPRT through the means described in Sections 3.0 and 4.0 of this part of the report.
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R vicicn 0 Page 6 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) 3.0 CAP DESIGN VALIDATION PROGRAM As discussed in Section 1.0, TU Electric evaluated the early results from the DAP and made a decision to initiate the design validation portion of the CAP.
The CAP includes a comprehensive design validation of safety-related and
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selected non-safety-related portions of CPSES* in order to provide an integrated l
I resolution of identified issues.
Another element of the CAP is the Post Construction Hardware Validation Program I
(PCHVP).
The PCHVP is a validation of final acceptance attributes for safety related and selected non-safety-related hardware to demonstrate that the installed hardware is in conformance with the validated design.
Part V of this report addresses the PCHVP.
TU Electric contracted with Stone & Webster Engineering Corporation (SWEC),
Ebasco, and Impell to conduct the CAP. Among TU Electric's bases for the selection of these contractors was the determination th.
these organizations have the requisite objectivity to evaluate and validate tne original design because they are not evaluating their own prior work.
(These organizations are referred to as the "CAP engineering contractors" in this report).
3.1 Score, Objectives and Structures The CAP design validation program provides for the systematic validation of the safety related and selected non-safety-related portions of the CPSES design.
For the purpose of the CAP, CPSES design activities are divided into 11 disciplines.
Procedurally-controlled programs were developed for each discipline and for the interfaces between disciplines. Results of these validation efforts are presented in the 11 Project Status Reports (PSRs), one for each design discipline.
The 11 CAP design disciplines and associated PSRs are as follows:
Responsible Discipline Contractor Mechanical SWEC
-Systems Interaction Ebasco l
-Fire Protection Impell Civil / Structural SWEC Electrical SWEC Instrumentation & Control (I&C)
SWEC Large Bore Piping and Pipe Supports SVEC Nuclear Steam Supply System (NSSS) design and vendor hardware design and their respective QA programs are not included in the Corrective Action Program; however, the design interface is included in the CAP.
Portions of selected non-safety-related systems, structures and components lh are included in the CAP.
These are Seismic Category II systems, structures and components, and fire protection systems.
R visien 0 Paga 7 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) s Responsible Discipline Contractor Cable Tray and Cable Tray Hangers Ebasco/Impell Conduit Supports, Trains A, B, & C > 2" Ebasco Conduit Supports Train C < 2" Impell Small Bore Piping and Pipe Supports SWEC Heating, Ventilating, and Air Ebasco
}
Conditioning (HVAC)
Equipment Qualification (EQ)
Impell Each PSR describes how the five basic design validation requirements of the CAP are implemented. These requirements are:
1.
Establishment of design criteria that comply with licensing commitments.
2.
Development of Design Basis Documents (DBDs) for CPSES which contain the design criteria.
3.
Implementation of design and hardware validation consisting of analysis, identification and implementation of necessary modifications, and physical verifications as identified in the PCHVP (see Part V of this report).
The as-built configuration is ralidated l
rs to the design by quality control (QC) inspections, engineering l ( ).
walkdowns and engineering evaluations.
4.
Resolution of the design and hardware related CPSES issues and implementation of corrective action for closure of these issues.
These issues include external issues, CPRT issues, and issues identified during performance of the CAP.
5.
Development of validated design documentation to form the basis for configuration control. The validated design documenention (calculations, design drawings, and specifications) and DBDs will be used by TU Electric to facilitate operation, maintenance, and future modifications.
The entire CAP design validation process is subject to controls in accordance with the CPSES quality assurance (QA) program. TU Electric established a Design Basis Consolidation Program (DBCP) which provided a methodology for performing design validation in a consistent manner by all contractors and for all disciplines.
For example, TU Electric procedures required that each contractor establish task descriptions which, among other things, identify the responsibilities of organizations for various tasks, the requirements applicable to the tasks, the scope of the work to be performed, the internal and external interfaces and quality assurance controls applicable to the task.
The CAP contractors were then required to develop their own procedures to be consistent with the requirements of the TU Electric procedures.
Engineers who perform design validation are required to receive training in areas such as the
~
(s) procedures governing validation of calculations, drawings, and specifications.
R:vici"n 0 Page 8 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) 3.2 Design Validation Process The CAP design validation process consists of the following steps:
Identification of the design-related licensing commitments.
Establishment of design criteria that comply with the licensing commitznents.
Validation that the design complies with the design criteria.
Each of these steps, required by the CAP, is described below.
Identification of Licensing Commitments - Various types of licensing documentation are reviewed to identify licensing commitments related to the CPSES design.
This documentation includes the FSAR for CPSES, the NRC Safety Evaluation Report and its supplements for CPSES, NRC Regulatory Guides, NRC IE Bulletins, and TU Electric /NRC licensing correspondence.
Establishment of Design Criteria Design criteria are established based on the identified licensing commitments.
The design criteria are consolidated and documented in Design Basis Documents (D'dDs). The design criteria are then used as the basis for validating the design.
Validation of the Design - Several types of activities ar-implenented to validate the design. Those activities are as follows:
External source issues and CPRT-identified issues for each discipline are collected in a Generic Issue Report which identified a planned approach to resolve the design issues.
Design validation results in resolutien of the external source issues and CPRT-identified issues.
Design documentation (calculations, design drawings, and specifications) are reviewed and either validated to be in conformance with the design criteria or modifications are initiated to establish conformance with the design criteria.
Additionally, the installation specifications are revised as necessary to include requirements for hardware construction and inspection, and construction and inspection procedures are reviewed and updated to refler.t the requirements in the validated installation spet ifications.
Where design changes are identified as a result of validation of the design documentation, appropriate documentation is issued as necessary to authorize modifications to the associated hardware.
This design change process requires inter-disciplinary review of the design change among the engineering, construction, and quality control organizations.
As discussed in Part V, in cases where as built data are needed as input for design validation, engineering walkdowns are conducted by trained and qualified
R:visiin 0 P g3 9 ef 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
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personnel in accordance with procedures referred to as Field Verification Methods (FVMs). The process and products of design validation are documented by dividing each discipline into smaller units and preparing a Design Validation Fach ge (DVP) for each unit. The design validation packages identify the DBDs that serve as a basis for design validation of the design documents (calculations, desi n drawings, and specifications) and other related documents, 5
such as any Significant Deficiency Analysis Reports, which identify issues that are potentially reportable under 10CFR50.55(e), and resolution documents for CPRT and external issues.
The results of design validation are presented in a PSR for each discipline.
Each PSR describes the disposition of each relevant external source issue, CPRT identified issue, and other issues identified during design validation.
Additionally, each PSR describes the methodology and process for validating the design, and reports that the design for that discipline is validated to be in conformance with the applicable design criteria and licensing commitments.
Issuance of a PSR signifies a Project determination that the following activities for a discipline are completed:
Licensing commitments are identified, Design criteria are established.
DBDs are developed and issued.
External and CPRT issues are resolved, v
Calculations and drawings are validated, modified or reperformed.
Installation specifications are validated and issued, Design Change Authorizations (DCAs) are issued for design modifications required to resolve issues (including CAP-identified issues), and Controls are in place to maintain the design during execution of the PCHVP and hardware reconciliation.
As discussed more fully in Part V, the results of design validation are an input to activities that include hardware modifications initiated during design validation, development of as built data to confirm some of the inputs in design validation, validation that the as built hardware conforms tith the validated design, resolution of any nonconformances identified during hardware validation, and reconciliation that the final designs are compatible among all of the CAP disciplines.
OU
R visi:n 0 P:g7 10 cf 41 Part III EVALUATION OF DESIGN ADEQUACY (Cont'd) 4.0 OVERVIEWS OF CPSES DESIGN PROGRAMS Design activities conducted by TU Electric and its contractors are controlled by QA programs.
These programs are implemented to meet regulatory requirements and to assure the adequacy of the CPSES design.
TU Electric and the CPRT have also established overview programs to provide an additional level of assurance.
These overview programs consist of independent activities that assess the quality and technical adequacy of design activities and products within the scope of the design validation portion of the CAP. These programs are being implemented in addition to the QA programs of the CAP contractors.
Furthermore, reviews of the CAP are conducted by Cygna in the disposition of Independent Assessment Program (IAP) items on their Review Issues List.
Overview as described below includes two general categories of activities.
Sections 4.1 and 4.3 describe TU Electric's QA program and the Engineering Assurance (EA)
Program, respectively.
These programs represent normal functions that provide an overall overview cf all CPSES design programs.
Sections 4.2, 4.4 and 4.5 describe the TAP, a special group under the direction of the TU Electric QA Department, EFE, and CPRT, respectively.
These are special overview programs that are focused primarily on implementation of the CAP design validation. The following sections briefly describe the function performed by the QA organizations and by each overview group and the scope of their respective activities.
4.1 Quality Assura..ce Programs TU Electric The TU Electric QA Department performs audit: of TU Electric and its hardware suppliers and engineering services contractors.
The QA Internal Audit Program addresses on site activities of contractors and TU Electric. The QA Vendor Compliance program focuses on off site activities of contractors and suppliers.
Auditt are performed to evaluate conformance of TU Electric and contractor / vendor QA' programs with regulatory requirements and to determine whether quality-related activities are performed in compliance with these programs.
These audits of the CAP contractors, which are primarily programmatic in nature, are coordinated with the TAP audits discussed in the next section.
Programmatic audits cover areas such as qualifications and training of personnel, compliance with procedures, conformance of work with quality requirements, and records of quality related activities.
Procedural compliance reviews are based on the contractor's procedures, except for contractors working under TU Electric procedures.
In such cases, the contractor is audited for the conformance of its work to the applicable TU Electric procedures. The TU Electric QA Department also audits design work performed by TU Electric Comanche Peak Engineering (CPE) for compliance with TU Electric procedures. Table 4 1 provides a summary of the number of audits performed by the TU Electric QA Department for each CAP discipline.
The implementation of these programs is the responsibility of the TU Electric QA Director who reports to a Corporate Vice President.
This reporting relationship is to assure independence of the QA functions.
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~The QA department is staffed with approximately 20 professionals who are supplemented with an "on call" staff of 11 engineers. This staff collectively-averages over 9 years QA experience per person.
Contractors j
All CAP activities are required to be performed in accordance with the CAP-contractors' or TU Electric's QA program. The contractors'-QA programs have been established in accordance with 10c m50, Appendix B,. ANSI N45.2 and
, applicable ANSI daughter standards.
Each of the cantractor QA programs was reviewed by the W Electric Quality Assurance organization, was found to be acceptable, and was approved.
Project specific procedures have been developed by each CAP engineering contractor. The procedures address organizational, administrative and technical aspects of the CAP. The procedures are designed to assure consistent quality of the implementation of design criteria, calculations, evaluations, walkdowns, and design interfaces. The CAP engineering contractor personnel performing the work are required to be trained in the procedures and on procedure revisions. The PSRs state that approximately 300,000 work hours have been expended by contractor QA organizations for activities directly related to the CAP for training, procedure development, auditing and project QC supervision.
The adequacy and implementation of the contractors' QA programs are audited by the contractors' QA organizations, by the contractors' Engineering Assurance O
organization (if applicable) and by TU Electric (i.e., TU Electric QA TAP, and i
EA).
Table 4-1 lists the number of audits and surveillances performed by the contractors and TU Electric.
4.2 Technical Audit Program (TAP)_
TU Electric initiated the TAP to overview the CAP, including activities resulting from the CPRT ISAPs. The objectives of this program, as described in NEO QA Department Procedure NQA 3.07-1.01, are (1) to assure the technical and programmatic effectiveness of the CAP design and hardware validation efforts and (2) to provide overview of CAP actions in response to recommendations from or commitments to the CPRT as documented in ISAP Results Reports.
For the CAP I
design validation activities, TAP audits are designed to address the following:
i Availability and adequacy of CPSES specific design validation procedures, instructions and guidance documents; Adequacy of DBDs and their reconciliation with licensing commitments; Resolution of generic technical issues; Adequacy of validated design documentation (i.e., calculations, drawings, and specifications), including interface documentation; l
Resolution of CPRT DIR reports; and Proper consideration of "as built" or "as-installed" data.
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Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
The TAP scope includes provisions for evaluating these areas for all eleven CAP disciplines. The scope of TAP evaluation of the CAP excludes review of the design procedures for areas addressed in DSAP and ISAP Results Reports because these were extensively reviewed and the review results documented by the DAP.
The TAP also has responsibility for overviews of design modification implementation, PCHVP implementation, and final reconciliation as discussed in Part V.
The TAP is controlled by NEO Quality Assurance Procedure NQA 3.07 1.01, which defines the purpose, scope, organization, responsibilities, personnel qualifications, implementation methodology and reporting requirements.
The audit teams are organized by CAP discipline areas and are staffed with a qualified Audit Team Leader and experienced, degreed engineers who have not had previous involvement with the CAP activities that they are reviewing.
Team leaders are requirert to be certified as lead auditors under ANSI N45.2.23.
The TAP is staffed with 24 full time professionals.
Supplementing the full-time staff are technical specialists who participate in audits as required.
The TAP has used 89 different technical specialists in its various audits. The TAP auditors and technical specialists average over twenty years of engineering experience per person with an average of over fourteen years of power plant engineering experience.
Over eighty percent of the staff are degreed engineers, fifty percent have professional engineer registrations, and sixteen individuals are certified lead auditors.
The TAP audits are conducted in accordance with TU Electric audit requirements, including audit planning, entrance and exit meetings, and timely issuance of audit reports as defined in NQA 3.07 - 1.01.
The TAP audits are planned and scheduled to cover discrete elements or stages of each CAP engineering contractor's design validation activities from design criteria identification and validation through reconciliation of the as-b.ailt hardware with the final validated design.
Each component of the CAP has been (and is continuing to be) audited on an in process basis as the work progresses through the various stages of the program and at each location where significant activity is being accomplished.
Specific audit topics (e.g., DVPs, calculation packages) are selected based on the status of the effort, its importance to safety, the degree of internal and external interfaces and the significance of previously identified DAP issues.
The initial TAP audit efforts were focused on generic subjecto applicable to all CAP disciplines, such as validation of design criteria and incorporation of the validated criteria in DBDs; resolution of Generic Technical issues (GTIs); and calculation validation methodologies.
The TAP audit efforts are continuing to audit specific CAP elements, including design modification implementation, DIR resolution, PCHVP implementation and final as-built design reconciliation.
The TAP has been assessing the integration of the CAP effort within and among cognizant engineering contractors by performing vertical, integrated systems audits desi ned to assure that the interfaces associated with each contractor's 5
activities are properly addressed.
These audits examine the effectiveness of
i R vicion 0 Pego 13 of 41 Part III - EVALUATION OF DESIGN ADEQUACY'(Cont'd)
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CAP design validation of selected functional design criteria that reflect key Project commitments across all relevant CAP topic.a1 design disciplines where design interfaces exist. These audits are executed to provide assurance that design interfaces are properly addressed in the total CAP effort. The TAP is providing increased focus on integrated systems audits as CAP proceeds toward the final stages of hardware validation and as built design reconciliation.
Through an assessment of its integrated audits, the TAP will verify the comprehensiveness of the CAP scope.
The TAP has completed over seventy audits collectively covering each of the CAP disciplines.
For each finding identified by TAP, the audited organization is required to provide a formal response, including an evaluation of the extent of the problem and identification of corrective and preventive actions.. These responses are evaluated by the TAP for completeness and adequacy, and are followed up by the TAP to confirm the implementation of corrective and preventive actions. The TAP effort requires resolution of all ' audit findings.
and provida confirmation of the ' technical acceptability of each CAP discipline.
The TAP has been performing periodic self-assessments of its progress with respect to its stated objectives and will continue to audit CAP program elements until it has achieved adequate coverage of the scope of CAP design activities and has confirmed satisfactory implementation of actions in response to its findings.
' /3 4.3 TU Electric Engineering Assurance (EA)
U The TU Electric EA organization is responsible for review and surveillance of TU Electric engineering contractor procedures for compatibility with TU Electric programs and procedures.
Engineering Assurance is also responsible for establishing and maintaining the programs and procedures for the TU Electric Comanche Peak Engineering (CPE) Department in compliance with industry practice and NRC regulations.
The EA organization is staffed with 22 professionals who collectively average over 21 years of engineering experience per person and average over 15 years of nuclear power plant engineering experience.
Eighty-six percent of the staff are degreed engineers and 55 percent have professional engineer registrations.
Additionally, although not required, eight members of the EA staff have held certifications as nuclear lead auditors.
The scope of EA includes the following functions related to design validation:
Er.gineering Department procedure development and revision.
Engineering contractor procedure review and concurrence, Training on procedures for CPE, Coordination and review of 50.55(e) and 10CFR21 evaluations, Programmatic and technical surveillances,
l R vicien 0 Page 14 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Design conformance and design change trending, Tracking of external regulatory commitments, and Coordination, review or approval of engineering department and engineering contractor responses to Corrective Action Requests (CAR),
Deficiency Reports (DRs), Nonconformance Reports, and Test Deficiency Reports.
The EA organization conducts both programmatic and technical surveillances of engineering activities of CPE disciplines and engineering centractors and of their interfaces with other engineering organizations.
Programmatic sutveillances focus on compliance with engineering procedures. Technical surveillances are performed on selected engineering activities and selected engineering organizations to determine if ongoing engineering activities are being adequately perforned. The EA is required to review Nuclear Engineering and Operations (NEO), Engineering and Construction (EC), Engineering and Construction Engineering (ECE) procedures and it also reviews CAP engineering contractor procedures and instructions for compliance with ECE procedures.
Surveillances conducted by EA generally follow the format of QA audits, although no credit is taken for them in fulfilling the QA audit requirements.
Surveillance plans are developed quarterly.
Each surveillance is conducted using a documented checklist.
EA performed 90 surveillances in 1987. Multiple surveillances were conducted on each TU Electric design organization and on each CAP engineering contractor.
Surveillances are documented in EA surveillance reports, and each finding is responded to by the responsible organization.
Findings that represent a failure to meet technical, procedural or program requirements are reported by issuance of a DR and are reviewed, tracked, and trended by TU Electric QA.
Other observations that do not represent a failure to meet requirements, but do require corrective action, improvement, or program enhancement are identified and reviewed, and responses to the observations are evaluated by EA.
4.4 Engineering Functional Evaluation (EFE)
The EFE is an integrated independent technical evaluation of the CAP that is conducted under the SWEC QA Program. The purpose of the EFE is to evaluate CAP performance to establish that:
Design validation and completion activities are being effectively implemented, and Engineering activities during operation of the plant will be effectively implemented so that the design basis is maint,ined.
The EFE includes four modules:
1)
Design Completion Activities 2)
Design Data Utilization - Testing
y g
7 U
R victea 0 Pags 15 of 41 e
O
- Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) 3)
Design Data Utilization - Maintenance and Operations 4).
Operating Plant Design' Control The design completion activities module employs a "vertical slice" review of the
-Containment Spray and the Control Room HVAC systems. including the associated electrical and control systems, and the Safeguards Building. These safety-related systems and structures were selected because they were judged by EFE to.be complex and involve representative design activities of the CAP.
The Module 1. scope includes either an "in depth evaluation" or a "design interface only" assessment for each CAP discipline. Table 4-2 lists the eleven CAP disciplines with the corresponding EFE subject and identifies the EFE evaluation as being in-depth or design interface-only. The TAP scope has been coordinated with the EFE. The TAP has placed additional emphasis on those EFE subject areas that are design interface only.
In most of these EFE interface only areas, such as cable tray and cable tray hangers, conduit nupports, and large bore piping and supports, the DAP has performed detailed reviews, which are documented in Results Reports.
The EFE is documented in a plan that details the sample selection, scope and
^
approach, specific review activities, interface activities, the evaluation team,
-and reports to be generated. The EFE is controlled through SWEC EA and EFE procedures.
O The EFE evaluation team is organized by engineering discipline and uses senior engineers and specialists from SWEC, Ebasco, and Impell who have not had previous involvement with the CPSES activities they are reviewing.
Engineering specialties represented on the evaluation teaa' include: electrical, equipment qualification, engineering mechanics (piping systems and supports), engineering mechantes (mechanical), power, radiation protection, HVAC, I&C, mechanical systems, materials, and civil / structural.
The EFE evaluation team is staffed with approximately 34 professionals with an average of over 19 years engineering experience per person, including over 14 years of nuclear power plant engineering experience. Ninety-seven percent of the staff are degreed engineers, 65 percent have professional engineer a
registrations and 18 percent are certified lead auditors.
The EFE has prepared and implemented over 100 (multi-part) review plans involving each of the CAP disciplines. As a result of its activities, the EFE identifies Action Items. Each Action Item describes an observation made by the EFE, and the reviewed organization is required to prepare responses that include
, an evaluation of the extent to which the issue may extend beyond the vertical slice, and identification of corrective and preventive action.
This provides the EFE with a mechanism for assuring that areas similarly affected are adequately considered.
These responses are reviewed by EFE for completeness and adequacy.
The EFE will prepare a report on each module upon completion of its reviews and satisfactory acceptance of Action Items and review comments. The reports will O
document EFE results and conclusions.
R;vicien 0 Page 16 of 41 Part III - EVALUATION OF DESICN ADEQUACY (Cont'd)
O 4.5 CPRT Overviews CPRT overviews of the CAP include the overviews documented in Results Reports associated with DSAP VIII, DSAP IX, and ISAP I.c; overviews by the CPRT as specified in the ISAP Results Reports that address design-related issues; technical review of the CAP responses for ten percent of the DIRs resulting from the DAP self-initiated design reviews; and overview of the effectiveness of the TAP and EFE in assuring the overall adequacy of CAP design validation activities. Additionally, the CPRT is providing the Project with documentation of design-related comitments by the Project that were used by the CPRT as bases for issuance of Results Reports. The CPRT is folloving up with the Project to assure that these comitments are understood and incorporated into Project documentation in order to assure their implementation. The CPRT reviews and concurs with variances from these comitments to assure that there is no effect on Results Report conclusions. The CPRT has also undertaken specific technical reviews where appropriate to supplement the CPRT's understanding of the CAP and to provide confirmation relative to its implementation (see Section 5.3.1).
The overview activities performed as part of DSAP VIII, DSAP IX, and ISAP I.c addressed the four CAP disciplines listed below and are sumarized in the corresponding Results Reports.
CPRT Results CAP Discipline
_Frogram Report Cable Tray and Cable Tray DSAP VIII DAP-RR-C/S 001 Rev 1 Hangers Conduit Supports, DSAP VIII DAP RR-C/S-002 Rev 1 Trains A, B and C > 2" Large Bore Piping & Pipe DSAP IX DAP-RR-P 001 Rev 1 Supports Conduit Supports, ISAP I.c ISAP I.c Rev 1 Train C < 2" The DAP Results Reports conclude that the resolution of the external source issues associated with these CAP disciplines is adequate.
The DAP activities performed on these CAP disciplines included the following:
External Source Issues Identification - Issues that were raised by external sources regarding the original design were identified by the CPRT through the review of over 40,000 pages of NRC-docketed material.
All issues identified by the DAP were documented, controlled, and tracked.
Design Criteria /Comitments Identification - The design criteria and comitments governing the design were identified by the CPRT from a review of the FSAR, applicable Regulatory Guides and referenced industry codes and standards. The DAP used these criteria for the development of checklists and engineering evaluation acceptance criteria for the review of specific CAP program areas.
R:visien 0 P:gs 17 of 41 Part III - EVALUATION OF DESICN ADEQUACY (Cont'd) g)
(V As Built Procedures Review - The procedures governing the walkdown/as built programs were reviewed by the CPRT as necessary to support the DSAP Results Report conclusions and found acceptable.
Design Validation Procedure Review The procedures defining and controlling the design validation process, the interfaces and the l
l technical methods to be used were reviewed by the CPRT. As a result of these reviews, the CPRT concluded that the design validation procedures were in compliance with the CPSES design criteria and licensing commitments.
Special Studies and Ceneric Calculations Review - The special studies and generic calculations performed by the CAP to provide a basis for the technical methods and assumptions included in the procedures or to resolve external source issues were reviewed by the CPRT. As a result of these reviews, the CPRT concluded that the procedures were in compliance with the CPSES design criteria and licensing commitments.
Test Programs Review - Where CAP-initiated testing was used to resolve external source issues or to provide a basis for design validation procedures, the DAP reviewed test specifications, procedures, and test results. As a result of these reviews, the CPRT concluded that the tests were properly specified and performed and that the results were interpreted correctly.
Issue Resolution Review The methodologies used in the resolution of the identified external source issues were reviewed by the CPRT. The review included the special studies, test results, and portions of procedures that were related to the specific issues. As a result of these reviews, the CPRT concluded that the resolution methodologies adequately address identified issues.
j In total, the overview activities associated with these four CAP disciplines provided a comprehensive assessment of the procedural compliance with CPSES design criteria and the resolution methodology for known issues.
In addition, some of the other ISAPs addressed design-related issuus. These ISAPs included evaluation of the scope, methodology and results to date of the Project's efforts related to those specific issues. These activities are summarized in the ISAP Results Reports, including CPRT's assesnment of the Project's corrective actions.
In all cases, the CPRT has concurred that the Project's plans for corrective actions are adequate.
A number of other CPRT overviews have been and are being performed to collect information relevant to the full spectrum of CAP design related activities.
These overview activities include evaluation of the various TU Electric CAP overview programs (TAP, EA and EFE) and additional direct technical evaluations of the CAP to supplement the results and information provided by the TU Electric overview programs.
Table 4 3 identifies CPRT overview activities and how they relate to the CAP scope, objectives, methodology, and implementation of CAP design validation activities. This table also presents the relationship of these activities to the TU Electric TAP and EFE.
Re'.'ision 0 P&ge 18 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 4-1 Audits and Surveillances of CAP Contractors (3)
Number of Audits or Surveillances CAP Discipline Contractor Contractor TU Electric Total Q
Q Q
TAP M(1)
Mechanical SWEC 1
6 4
7 6
24 7
3 12 l
- Systems Interaction Ebasco 2
1 10 2
39
- Fire Protection Impe11(2) 26 Civil / Structural SWEC 1
5 4
9 7
26 Electrical SUEC 1
6 6
8 7
28 Instrumentation SWEC 1
6 6
4 6
23 l
and Control (I&C)
22 11 5
4 43 and Pipe Supports 9
4 6
31 Cable Tray and Ebasco 12 5
3 2
19 Cable Tray Hangers Impell 9
h 3
4 7
18 Conduit Supports, Ebasco 4
Trains A, B, & C > 2" 3
6 3
20 Conduit Support, Impell 8
Train C S 2" Small Bore Piping SWEC 1
16 4
1 4
26 and Pipe Supports 1
8 1
13 Heating, Ventilating Ebasco 3
and Air Conditioning (HVAC) 7 5
34 Environmental Impell 22 Qualification (EQ)
NOTES:
(1) TU Electric EA surveillances of specific CAP Disciplines are listed in the Table.
Surve111ances concerning more than one discipline are shown separately for each discipline.
In addition, TU Electric EA conducted 39 surveillances of CAP contractor programs and procedures.
(2)
TU Electric QA and TAP audits of Fire Protection include both Impell and Engineering Planning and Management, Inc. (EPM).
(3)
Source:
Project Status Reports and TU Electric EA reports:
h "1987 Surveillance Summary" and 1986 Technical Surveillance Reports #1 through #20.
c.
R;visitn 0 i
Page 19 of 41 Part III EVALUATION OF DESIGN ADEQUACY (Cont'd) s_ /
Table 4 2 CAP Discipline and EFE Subject l
CAP Discipline Related EFE Subject Design In Depth Interfaces Subject Evaluation Only Mechanical Engineering Mechanics Mechanical Analysis X
Power Systems X
Safeguards X
Materials X
Radiation Protection X
Systems Interaction Power Systems Interaction X
Fire Protection Selected Fire Protection Features X
(~N,
(
I Civil / Structural Structural Building System X
Electrical Electrical X
Instrumentation & Control Instrumentation & Control X
Large Bore Pipe Supports Engineering Mechanics Large Bore Piping X
Cable Tray Hangers Structural Cable Tray Support X
Conduit Supports, Structural Conduit Support X
Trains A, B, C > 2" Conduit Supports, Structural Conduit Support X
Trains C < 2" Small Bore Pipe Supports Engineering Mechanics Small Bore Piping X
Stress X
Supports X
System X
Supports X
ROvisien 0 Pego 20 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 4-2 (Cont'd)
CAP Discipline and EFE Subject CAP Discipline Related EFE Subiect Design In Depth Interfaces Subject Evaluation Only 1
l Equipment Qualification Equiptnent Qualification l
Environmental X
l Seismic X
i 1
1 l
l e
I l
o
R:visitn a Pcgo 21 et 41 Part III - EVALUATION OF DESICN ADEQUACY (Cont'd)
/
Table 4-3 CPRT Overview Activities for Design Related CAP Activities 10 CPRT CAP Overview Ovarview Overview Aspect Goal Method
- Activity Overview of TAP SCOPE Verify safety related TAP and selected non safety integrated audit related portions of results.
Review of PSRs.
CPSES covered.
OBJECTIVES Verify that the CAP requirements (see Section 3.1) are met:
Overview of TAP /
Assure that design criteria TAP EFE (for EFE scope and comply with licensing commitments (CAP selected procedures.
Review of TU/
Requirement 1),
systems and structures).
Contractor procedural
/~~NL requirements.
N)
Overview of TAP /
Determine that DBDs TAP EFE (for EFE scope and contain design criteria (CAP Requirement 2).
selected procedures.
Review of TU/
systems and structures).
Contractor procedural requirements.
Overview of TAP /
Assure implementation of TAP EFE (for EFE scope and design validation (CAP Requirement 3),
selected procedures.
Review of PSRs.
systems and structures).
Overview of TAP /
Assure implementation of TAP EFE EFE scope and walkdowns, final reconciliation, and procedures.
Review of TU/
other post-validation activities (CAP Contractor Requirement 3; see procedural Part V of this report).
requirements.
DSAP Results Assure resolution of TAP external issues (CAP Reports.
73 Overview of TAP
(')
Requirement 4).
scope and procedures.
J
Revision 0 Page 22 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) e Table 4 3 (Cont'd)
CPRT Overview Activities for Design Related CAP Activities TU CPRT CAP Overview Overview Overview Aspect Goal Method
- Activity Review of TU/
Contractor procedural requirements.
106 sample of Assure resolution of CPRT TAP issues (CAP Requirement 4).
DIR responses.
Overview of TAP scope and procedures.
Review of TU/
Contractor procedural requirements.
Overview of TAP /
Assure resolution of CAP TAP EFE (for EFE scope and issues (CAP Requirement 4).
sei.ected procedures, Technical j
systems and sttucturer).
overviews.
Overview of TAP /
Assure preparation of TAP EFE (for EFE scope and design documentation (CAP Requirement 5).
selected procedures.
systems and structures).
Assessment of TU STRUCTURE /
Verify that procedures TAP EFE (for QA, TAP, EFE METHODOLOGY are adequate and activities are controlled per selected findings and procedures.
systems and responses.
Review of TU structures).
programa vs.
- 10CFR50, App. B and N45.2.11.
Overview of TAP /
DESIGN Verify that DBDs are TAP EFE (for EFE implementation.
VALIDATION issued and adequate.
Review of selected PROCESS selected IMPLEMENTATION systems and DBDs.
structures).
f R;visitn 0 Pcgo 23 ef 41 Part III - EVALUATION OF DESICN ADEQUACY (Cont'd)
Table 4 3 (Cont'd)
CPRT Overview Activities for Design-Related CAP Activities TU CPRT CAP Overview Overview Overview Aspect Gsal Method
- Activity 10% DIR review, TAP Verify that CPRT, CAP, Overview of TAP /
EFE (for and external source issues are resolved, selected EFE DIRs),
implementation.
Review of implementation of selected closure of issues.
Overview of TAP /
Verify that validated TAP EFE EFE implementation.
design documentation is SRT directed adequate.
calculations technical overviews specifications drawings miscellaneous g' 'S
(,/
engineering documentation Overview of TAP Verify that installation TAP specifications are implementation, Review of selected validated including attribute lists and specifications acceptance criteria, and attributa lists.
Overview of TAP /
Determine whether TAP EFE EFE appropriate DCAs have been issued, implementation.
Selected N/A ROOT CAUSES Determine whether IDENTIFIED current programs reflect evaluation of AND corrective action Project polici s, e
CORRECTIVE appropriate for CPRT programs and ACTION identified bounding procedures.
TAKEN root causes.
TU Electric QA and EA ectivities are not identified in this column.
,-s
(
)
However, the TU Electric QA and EA organizations pe; form Ludits and surveillances of these Project activities as appropriate.
Revision 0 Page 24 of 41 j
Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) e 5.0 EVALUATION OF DESIGN ADEQUACY 5.1 Introduction The CPRT results in the design area, as well as other considerations, led TU Electric to implement a design validation program. As discussed in Sections 1.0 and 3.0, TU Electric has implemented a comprehensive design validation program within CAP to validate the safety-related design of CPSES.
In addition, TU Electric is implementing two special overview programs, the TAP and EFE, to provide additional assurance that the CAP is properly implemented.
These programs are in addition to normal QA audit and surveillance programs and the EA surveillance progra:n.
Section 5.2 presents the results of the CPRT evaluation of the adequacy of the scope, controls, organizations and approach of the CAP, Section 5.3 presents the results of the CPRT evaluation of the adequacy of the implementation of the CAP.
l 5.2 Evaluation of the CAP Design Validation Program Scope, Controls, Organization, and Methodology The CPRT evaluated the scope, controls, organization, and methodology of the CAP and found that it provides an acceptable means for resolving all identified design concerns and provides reasonable assurance that no undetected safety significant design related deficiencies exist.
The CPRT determined that:
The scope of CAP is adequate.
First, the CAP is resolving all design issues identified by other sources (i.e., external sources such as NRC, CASE, ASLB, and Cygna, and CPRT-identified issues). All of these issues are required to be resolved by the CAP (CAP requirement 4; see Section 3.1), and these CAP issue resolutions are reviewed by the CPRT through the DSAP and ISAP Results Reports and through the CPRT selective evaluation of DIR responses.
Second, the scope of the CAP addresses all CPSES safety-related design disciplines on a comprehensive basis. This aspect of the CAP is designed to assure that the generic implications of known design issues and any undetected design issues are identified and resolved by the CAP and that no undetected safety-significant design related deficiencies vill exist in the CPSES validated design.
The controls governing the implementation of the CAP are acceptable.
TU Electric has implemented a comprehensive restructuring of its corporate nuclear program.
In August 1985, the president of TU Electric issued a Corporate Nuclear Policy Statement which provided the requirements for development of Nuclear Engineering and Operations (NEO) Policies and Procedures that assure implementation of the corporate policy by major TU Electric departments. These NEO policies and procedures in turn provide the bases for development of procedures for all lover tier organizations, as necessary for these organizations to execute their respective missions. Thus, a hierarchical framework exists which is modeled after other successful industry programs.
Contractors are required to develop procedures associated with CAP
Rtvioitn 0 Pego 25 ef 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) j implementation -in accordance with the governing W Electric procedures.
The CPRT performed an evaluation of the scope of the current design control program for CPSES to determine whether it complies with applicable criteria in 10CPR50, Appendix B, and industry standard ANSI N45.2.11, which contains requirements for design control for nuclear power plants.
In performing this evaluation, the CPRT reviewed several types of documents, including the CPSES QA Manual, the description of the CPSES QA program in Chapter 17.1 of the FSAR, relevant NEO policies and procedures, selected engineering, QA and operations procedures, and selected contractor procedures.
Additionally, the CPRT relied upon the experience and information collected during implementation of the DSAPs and CPRT overviews. As a result of its review of the CPSES design control program, the CPRT found that:
TU Electric is the engineering organization ultimately responsible for plant design and for design control. TU Electric has contracted with Westinghouse for the Nuclear Steam Supply System daisign and with SWEC, Ebasco, and Impell to implement the l
CAP. TU Electric requires that each of these contractors establish and implement a QA program that satisfies the applicable tequirements of 10CFR50, Appendix B.
L TU Electric has established procedures to assure that its design activities are carried out in a planned, controlled, orderly, and correct manner. TU Electric has established procedures to control activities under the CAP. The CAP contractors are required to comply with these procedures and to establish procedures that are consistent with TU Electric's procedures, i
TU Electric requires that applicable design inputs, such as design bases, regulatory requirements, codes, and standards be identified and documented and that they be reviewed and approved.
Changes from the specified design inputs are required to be identified, approved, documented, and controlled.
Design activities are controlled by procedure to assure that applicable design inputs are correctly translated into specifications, drawings, procedures, or instructions.
For example, procedures control the preparation of engineering calculations to ensure uniformity, validity of assumptions and inputs, and accuracy of results.
Design analyses are required to be documented and to include sufficient details regarding purpose, method, assumptions, design input, references, and units.
Procedures require the review of preparation of drawings, specifications, and calculations.
In particular:
R;vici:n 0 Page 26 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Procedures require that design drawings be reviewed independently for completeness, accuracy, agreement with design concepts, and possible interferences.
Further review is provided by engineers of related disciplines who review for consistency and compatibility with related systems and design requirements. Procedures also call for supervisory review for content and compliance.
Procedures require that specifications be independently reviewed for technical accuracy, completeness, conformance with applicable regulatory requirements, and overall acceptability. Additional review is provided by related disciplines to ensure coordination and by project managers for overall project requirements.
Upon receipt from a manufacturer, vendor-supplied drawings, specifications, and procedures are routed through the applicable engineering disciplines to check compliance with engineering drawings and specifications.
Procedures define requirements for review of calculations by independent checkers and requirements for documentation of this review.
Procedures requhe that design reviews be performed using appropriate methois includin5:
Caecka to compare information presented on a drawing or other document vfth a definite figure, criterion, or design bases.
Supervisory reviews of design work by a project team mauber in that ditciplino.
Interface reviews, by personnel of one discipline, of wo:k performed by another discipline to determine that the reviewer's discipline requirements and comnitments are satisfied.
Review by QA to determine that QA requirements are included l
l as appropriate for the item being reviewed.
Design verification to review, confirm, or substantiate the design is required to be performed to provide assurance that the l
design meets the specified inputs. Methods of verification include, but are not limited to, design review, alternate l
calculations, and qualification testing.
Procedures define the j
actions necessary to report and resolve deficiencies identified during design verification.
Measures have been established to control interfaces among design organizations and interfaces within each organization.
These l
measures include identification of the interface, definition and i
l' l
Rsvisicn 0 Page 27 of 41 i
Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
. (V
\\
documentation of the responsibilities of each group, establishment of nethods for communication of design information across interfaces, and documentation of the design information transmitted across design interfaces.
Procedures require that design documents for initial issuance, and changes thereto, be reviewed for accuracy, approved for release by authorized personnel, and distributed properly.
Procedures require that design changes, including field changes, be subjected to desigr, control measures commensurate with those applied to the original design. Unless otherwise specified by TU Electric, the organization that performed the originel design must approve the design change. Approved changes are incorporated into or identified on the original design document.
Information concerning the design change is required to be transmitted to all affected persons and organizations.
Procedures provide for correction of deficiencies in the design and design process. For significant deficiencies, procedures require that the cause and extent of the deficiency be determined and that action be taken to prevent recurrence of similar deficiencies.
l q
Design documentation and records that provide evidence that the Q
design and review process was performed in accordance with applicable requirements are required to be stored in accordance with ANSI N45.2.9.
TU Electric QA conducts audits and surveillances of design and engineering activities performod by TU Electric and its contractors. Audits by TU Electric are performed to assure that the contractors' design control measures are adequate, including provisions for a clear definition of design interl.acos, a review and approval cycle for internal desip for initial design and changes or revisions, and that personnel performing design reviews be independent of those originating the design and familiar with the regulatory requirements and design bases described in the FSAR. Audits are required to be performed in accordr_nce with procedures or checklists by competent personnel who did not have direct responsibility in the areas being audited.
Based upon the above, the CPRT concludes that the current design control program fer CPSES adequately addresses the design related criteria of 10CFR50, Appendix B and ANSI N45.2.ll and this program is applicable to the design products of CAP design validation program.
The organization of the CAP is sufficient to implement the CAP in a technically correct and objective manner.
Experienced nuclear managers have been hired in the following key positions:
v
Ravicien 0 Page 28 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Executive V.P., NEO V.P., Nuclear Operations V.P.,
Engineering and Construction V.P., Nuclear Engineering Similarly, the middle management levels within many departments, particularly in Engineering and Construction are staffed with significant numbers of professionals.
Engineering and Construction currently has a professional staff of approximately 240, the majority of whom are degreed engineers. The experience and qualifications, as well as the number of resources of the TU Electric engineering staff, is sufficient to enable TU Electric to perform and manage internal engineering activities as well as control the work of contractors and their interfaces. The engineering contractors implementing the CAP have the requisite objectivity to review and validate the CPSES designs because they were not responsible for the original design and thus are not placed in the position of evaluating their own work. As evidenced by past experience, the CAP engineering contractors are technically qualified and are experienced in the design of nuclear power plants.
The methodology used by the CAP _to validate the design is souni Design criteria are verified to comply with licensing commitments and are incorporated within Design Sa=is Documents to provide a basis for design validation (CAP requirements 1 and 2; see Section 3.1).
Each design is reviewed and validatsd and e.ny required nodifications identified. Necessary modifications are identified based upon the design validation and hardware validations of the PCEVP (CAP requirement 3; s9e Section 3.1).
The technical methodologies for four of the eleven CAP disciplines were evaluated and found to be adequate by CPRT in DSAP Results Reports. A fifth CAP discipline (Small Bore Piping and Pipe Supports) uses essentially the same technical approach as the Large Bore Piping and Pipe Supports discipline used which was reviewed and evaluated by DAP. Therefore, the DAP conclusions regarding Large Bore Piping and Pipe Supports discipline are generally applicable to this CAP discipline. The design validation approaches used in the remaining six CAP disciplines are evaluated by the TAP and EFE as well as by CPRT through the evaluation of selected DIR resolutions, overviews of the TAP and EFE, and other CPRT overviews.
This process assures that all issues are resolved (CAP requirement 4; see Section 3.1).
The end products of the CAP include a complete set of validated design documentation which provides a design configuration baseline for CPSES (CAP requirement 5; see Section 3.1).
This design baseline is required to reflect the physical configuration and to demonstrate compliance with design requirements. Therefore, the CPRT concludes that the CAP methodology is adequate to provide reasonable assurance that the CPSES design meets the design criteria and appropriate licensing commitments subject to the completion of final reconciliation as described in Part V.
Rsvisicn 0
-Page 29 of 41 Part III. EVALUATION OF DESIGN ADEQUACY'(Cont'd) k Based:upon the above,' the CPRT concludes that the scope, controls,"
organization, and methodology of the' CAP provide an. adequate means'for J
. identifying and'reoolving all design concerns and for validating that the design of CPSES. complies with the' current licensing commitments and' regulatory requirements.-
l Areas of potential weakness in past design progranas were identified in-the letter from Mr. Beck to Mr. Counsil dated February 4, 1987.
In general, these potential weaknesses pertained to the areas of design control, adequacy of design products, personnel, and audits. As discussed below, the CPRT has
.j determined that the CPSES policies, programs and procedures related to design are adequate to address these potential weaknesses and to assure that CPSES will meet regulatory requirements.
Design and interface control -~ Issues in this area were related to design verification, organizational interfaces, and design changes.
As discussed above, the CPRT has evaluated the CPSES design control program and has determined that it complies with 10CFR Part 50, Appendix B.
)
Control of design inputs and adequacy of design documentation Issues in this area were related to the translation of licensing consmitments into design criteria and engineering documentation, design commitments A
control, code compliance procedures and the adequacy and level of l (t) design documentation. As discussed in Section 3.0, TU Electric has l -
established the CAP to validate the adequacy of design products.
Personnel - Issues in this area were related to compliance with procedures and training and personnel qualification. As discussed above, TU Electric has hired experienced nuclear managers and has also expanded the number of experienced engineers in its Engineerin6 Department. TU Electric has also contracted with experienced engineering contractors to implement the CAP. These personnel are required to have appropriate training and experience to implement the CAP and perform their assigned engineering duties.
l Audits - Issues in this area were related to programmatic and technical audits of design contrcl and corrective action. As discussed in Section 4.0, TU Electric has established a number of different audit and surveillance programs to assure the adequacy of l
the CAP, including design control and corrective action. As discussed l
in the next section, the audit and overview programs are adequate to assure proper implementation of the CAP.
To provide added confirmation that each of these potential weaknesses has been corrected, the CPRT performed a three part evaluation of each area to determine its adequacy.
First, the CPRT reviewed the hierarchy of procedures at CPSES to determine whether procedures exist that are intended to control the area in question. As is shown in Table 5-1, each of these areas is controlled by one or O-more procedures.
Second, the CPRT reviewed selected procedures to determine whether the content of the procedures is sufficient to provide adequate control r
over the area (e.g., whether the procedure is consistent with ANSI N45.2.11).
l l
Rsvicien 0 Pcgs 30 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Finally, the CPRT reviewed selected audit and surveillance reports and corrective action reports to determine whether the procedures are being properly implemented. Recent audits and/or surveillances performed on these procedures determined that implementation is adequate or, if findings were identified, appropriate corrective actions are required to be developed.
In combination, these actions address and correct the potential weaknesses in the past design program identified by the CPRT in design-related activities at CPSES.
5.3 Evaluation of CAP Design Validation Program Implementation The CPRT, having found the basic structure of the CAP to be acceptable, is also evaluating CAP implementation. The CPRT is using a combination of overviews performed by CPRT personnel, including implementation of selected DSAPs and
. SAPS, and CPRT assessments of the overviews performed by the TAP and EFE.
These overviews are conducted to cover the full range of design validation activities for each CAP discipline area. As part of these overviews, the CPRT reviewed each PSR to assure that the CPRT and external source issues identified by the CPRT are being resolved. The CPRT is also reviewing elements of TU Electric's QA and EA programs to assure that these important programs are being adequately implemented. These overviews and assessments are evaluated below.
5.3.1 CPRT Overviews As discussed in Section 4.5, extensive CPRT overviews were performed for the following four CAP elements:
Large Bore Piping and Pipe Supports Cable Tray and Cable Tray Hangers Conduit Supports, Train A, B, and C > 2" Conduit Supports, Train C < 2" l
For each of these CAP areas, the scope of the overview included the I
identification and evaluation of the resolution methodology for external source issues as well as an assessment of the design validation procedures for i
l compliance with the CPSES licensing commitments.
These efforts resulted in the identification of more than 1100 individual l
external source issues, which were subsequently consolidated into approximately 100 related issue groups.
For each issue group, pertinent CAP design validation procedures, special studies, generic calculations, and test program results were reviewed to assess the resolution methodology. These CAP documents were also reviewed for compliance with the CPSES licensing commitments.
Based on the results of these efforts, the CPRT concluded in the Results Reports listed in Section 4.5 that the activities associated with these four CAP disciplines are comprehensive and involve methodologies that, when applied, will resolve the known technical issues and assure that the resulting CPSES designs will comply with the CPSES licensing commitments. Overview of the implementation of these CAP disciplines is performed by the TAP and CPRT.
Rsvision 0 Page 31 of 41
-Part III
~ EVALUATION OF DESIGN ADEQUACY (Cont'd)
Section 4.5 also discussed CPRT overviews that are being conducted to supplement the, insights on CAP gained by the CPRT through the TAP and EFE.
Described below are typical CPRT overviews, their objectives, and current results:
Technical reviews of DIR responses. A review of approximately a ten percent sample of DIR responses is being performed to confirm the adequacy of technic.al resolution for the CAP disciplines _for which no DSAP Results Reports are applicable. The current results of these reviews indicate that appropriate DCAs are issued when required by a DIR resolution.
Reviews of DBDs. The current results of these reviews indicate that licensing commitments have been translated into appropriate design criteria, are documented, and are maintained in a suitable, controlled form.
Specification reviews. The current results of specification reviews indicate that engineering requirements have been properly translated into' specifications for construction and that inspection attributes related to design requirements have been identified.
ISAP reviews.
Design-related matters that were identified in ISAP Results Reports as requiring addit. ions 1 CPRT action are being reviewed and closed to confirm that all necessa g actions have been adequately performed.
Technicr.1 documentation reviews. The current results of reviews of calculations, specifications, drawings, and other design c'ocumentation indicate that the documentation is adequate to support the final plant design conditions.
Procedural reviews.
The current results of reviews of TU Electric procedures indicate that TU design control activities comply with 10CFR50 Appendix B and ANSI N45.2.11.
Programmatic reviews. The current results of programmatic reviews indicate that the current programs incorporate corrective action appropriate for potential weaknesses in the past design program.
Overviews of TAP and EFE. The current results of monitoring of TAP and EFE results indicate the adequacy of these programs and indicate the adequacy of CAP implementation.
5.3.2 Evaluation of the TAP As discussed in Section 4.2, TU Electric initiated the TAP as a special overview program, above and beyond those programmatic activities necessary to meet the requirements of the TU Electric QA Program. The purpose of this program is to provide additional assurance that the CAP is properly implemented.
This section presents the CPRT evaluation of the effectiveness of the TAP O
related to its overview of the CAP design validation activities.
A discussion of the TAP overview activities related to the PCHVP is presented in Part V of 3
this report.
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R;visien 0 Page 32 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
In addition to overview of CAP design validation activities, the TAP evaluates the CAP actions related to CPRT ISAP recommendations and Project commitments.
The CPRT evaluation of the effectiveness of the TAP in this regard is discussed in Part IV of this report.
The CPRT evaluation of the effectiveness of the TAP includes overviews and monitoring of TAP activities.
The scope and results of theso overviews are as l
follows:
l l
The scope and objectives of the TAP are acceptable.
Specifically, NEO
(
Quality Assurance Department Procedure NQA 3.07-1.01 provides an i
adequate definition of the program scope and objectives for performing audits to assess the technical adequacy of CAP design validation.
In addition, CPRT review of the TAP's internal status evaluation process provides evidence that the TAP is assessing its status with respect to its stated scope and objectives to direct the course of future audit planning activities. The TAP is documenting its current status with respect to its stated objectives for each of the CAP disciplines to determine where further audit activities are required. The scope of coverage and previous audit findings are considered in this assessment.
The CPRT considers this to be an appropriate approach to determine the required breadth and extent of future audit activities.
The structure and defined methodology of the TAP are appropriate.
Procedure NQA 2.37-1.01 definos the organization, responsibilities, personnel qualifications, audit methodology and implementing procedural requirements for TAP, snd it provides an adequate framework for implomentation of the program.
Individual audits under the TAP are baing acceptably performad.
The
- PRT reviewed selected TAP audit reports, selected audit files and audit findings.
Based on these rev'ews, it is concluded that individual auditt are being adequately performed.
The depth of the technical audits, as indicated by audit file checklists, is judged to be appropriate. The technical quality of the audits is judged to be adequate based on a review of the significance of the findings, checklist documentation, audit questions and responses, and the resulting audit reports.
Audit findings are being adequately resolved.
The CPRT is reviewing selected audit response closure correspondence between the TAP and the affected contractor (s) and supplemental TAP evaluation documentation contained in the audit files.
This documentation provides evidence that the TAP requires audited organizations to provide appropriate responses to TAP audit findings.
It also provides evidence that the TAP is evaluating the responses and confirming the implementation of the accepted corrective action.
Audit results are being considered collectively.
The TAP conducts internal collective evaluation of findings within specific CAP program elements to determine the breadth and extent of identified deficiencies, the adequacy of corrective actions, and the requirements for future audit activities.
R:visien 0 Pegs 33 of 41 i-Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd) g The CPRT is directly monitoring the TAP by continuously reviewing implementation-
'of,the TAP through the following mechanisms:
Receipt and review of TAP audit reports, responses to TAP audit reports, and TAP notifications of deficiency closure.
Receipt and review of.all TAP monthly executive summary reports, l
f Monthly meetings between the CPRT and TAP management to discuss TAP audit results and planned activities and to provide an opportunity for l
SRT input to the TAP.
Informal interactions among CPRT and TAP personnel.
l l
Based on knowledge of TAP implementation activities, gained both through l
overviews and through direct monitoring, the CPRT has concluded-that:
The TAP provides an objective and appropriately detailed technical assessment of the adequacy of CAP implementation.
I The TAP is capable of properly identifying and classifying discrepancies during its audits.
The TAP requires audited organizations to provide appropriate (N
responses to TAP audit findings and to define and implement corrective h
actions in response to specific audit findings.
The TAP performs follow-up evaluations to verify the adequacy of implementation of correctivo and preventive actions developed in response.to TAP audit findings.
TU Electric's management has demonstrated support of the TAP.
In summary, the TAP provides a reliable and effective means to assess the technical adequacy of the CAP program and its implementation.
Based upor. TAP's demonstrated performance to date, the CPRT is confident that the TAP will continue to be effective in its overview of the remaining CAP activities. The CPRT will continue to monitor TAP activities and will conduct additional overviews as necessary.
5.3.3 Evaluation of EFE As discussed in Section 4.4, TU Electric management initiated the EFE as a special overview program, above and beyond the acti.vities necessary to meet the QA programs of TU Electric and its engineering contractors, to provide an independent, in-depth technical evaluation of the CAP to ensure that it is effectively implemented. This section presents the CPRT's evaluation of the effectiveness of the EFE related to its overview of the CAP's design validation activities.
O
Rxvicicn 0 P gs 34 ef 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
The CPRT has reviewed the design and structure of the EFE.
The scope and results of these overviews are as follows:
The depth and breadth of the EFE scope of activities related to the CAP design validation provide additional means to verify the adequi2cy of the CAP implementatien. The scope of EFE is comparable in depth and breadth to Independent Design Verification Programs (IDVPs) and is modeled after previous NRC-approved IDVPs.
The areas of EFE characterized as interface-only are addressed by the TAP and CPRT overview activities.
The EFE scope includes the review of the CAP actions to address previously identified CPSES design issues.
The EFE sample selection includes the maior design elements in the CAP.
The systems, structures, and components selected for review are designed to provide the necessary design complexity to test the capability of the CAP.
The sample is multidiscipline, involving each of the technical engineering disciplines applied in the CAP.
The sample is safety-related and includes the major CAP design work processes (inputs, outputs, implementing documents and interfaces) and the major CAP end products (design basis documents, calculations, drawings, design change authorizations and specifications).
The vertical slice approach and review methodology are appropriate for an assessment of the technical adequacy of the CAP.,
The EFE Program Plan specifies the elements of the vertical slice and the methodology applied to each element.
EFE reviews are conducted using detailed, documented Review Plans. The content of the Review Plans assures that each subject area and contractor is examined.
Each completed Review Plan is signed off separately by a preparer and an approver to assure a consistent and complete review.
The EFE review of contractor respor.ses to Action Items is appropriate to assure successful CAP closure.
Contractors provide a written response to each EFE Action Item.
The response must include a determination of the cause, the extent, and the significance of the concern, the corrective actions, and the actions to prevent reoccurrence.
The EFE reviews each response for adequacy and completeness.
The status of action items issued and responses received is documented and tracked by EFE.
The CPRT is directly monitoring the implementation of the EFE through the following mechanisms:
Receipt and review of EFE Action Item status sunmaries and review comments; Receipt and review of EFE monthly progress reports; Monthly meetings between the CPRT and EFE management to discuss EF3 results and planned activities and to provide an opportunity for SRT input to EFE; and lfi Informal interactions among CPRT and EFE personnel.
R:visien 0 Page 35 of 41 Part III -' EVALUATION OF DESIGN ADEQUACY (Cont'd)
/,,\\
\\J-Based on its knowledge of EFE's activities related to the oversight of CAP design validation, the CPRT has concluded that:
The EFE is providing a thorough, objective, and appropriately detailed technical assessment of the adequacy of CAP implementation.
The EFE is requiring the CAP organizations to provide appropriate responses to EFE Action Iter.s and to define and implement necessary corrective and preventivo actions. The EFE review of responses to its findings provides a means to assure that the extent of any problem, and the root causes are identified and bounded.
TU Electric's management has demonstrated support of the EFE.
In summary, the EFE provides a reliable and effective means to assess the technical adequacy of the CAP program and its implementation.
Based upon EFE's demonstrated performance to date, the CPRT is confident that the EFE will continue to be effective in its overview of the remaining CAP activities. The CPRT will continue to monitor EFE activities and will conduct additional overviews as necessary.
5.3.4 Evaluation of QA and EA The CPRT revicaed the acope of TU Electric's QA activities, contractor QA gj activitieu, and TU Electric's EA program.
These were evaluated as integral pieces of the over.tl1 CAP and design control program in the context of assuring that applicable provisions exist addressing 10CHt50, Appendix B and industry standard ANSI N45.2.ll.
Selected audit and surveillance results were. reviewed to determine whether the programs are functioning as planned.
TU El-actric QA and FA organizations have performed audits and surveillances of the CAP engineering contractors. These activities have both technical and
-programmatic elements and are performed in accordance with approved procedures.
Technical and programmatic issues that are identified are required to be resolved. Based upon this record of implementation, together with the organizations and procedures in place, the CPRT concludes that the TU Electric QA and EA programs are adequately structured to provide reasonable assurance of the implementation of remaining CAP design-related activities.
- -,,, - - - + - - - - - -, -,,-
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R2vici:n 0 Page 36 of 41 Pcrt III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 5-1 Current CPSES Policies and Procedures Associated with Areas oi Potential Weakness in the Past Design Program j
l Applicable Nuclear Engineering Applicable Engineering and Applicable Engineering and
)
Bounding and Operations (NEO)
Construction (EC)*
Construction Engineering Cause Policy (s)/ Procedure (s)
Procedure (s)
Procedure (s) l 1.
Design Commitment NEO 4.09, "Commitment Tracking NEO 4.09, "Commitment Tracking ECE 3.03, "Preparation, Control System" System" Review and Approval of Design Modifications (DMs)"
NEO 3.03, "Preparation, Review NEO 3.03, "Preparation, Review and Disposition of Plant Design and Disposition of Plant Design ECE 5.01-03, "Design Change Modifications (DMs)"
Modifications (DMs)"
Authorizations" NEO Policy No. 3 "Design ECE-DC-17, "Preparation and Modifications" Review of Design Basis Documents 'DBDs)"
NEO Policy No. 39, "Commitment Tracking System" ECE 5.09-01, "Design Verification and Interdiscipline Review" ECE 4.09, "Commitment Tracking System" 2.
Code Compliance NEO 3.03, "Preparation, Review NEO 3.03, Review and ECE 3.03, "Preparation, Procedures and Disposition of Plant Design Disposition Plant Design Review and Approval of Modifications (DMs)"
Modifications (DMs)"
Design Modifications (DMs)"
NEO 4.09, "Commitment Tracking ECE-DC-17, "Preparation and System" Review of Design Basis Documents (DBDs)"
NEO Policy No. 3 "Design Modifications" ECE 5.01-03, "Design Change Authorizations" O
O O
O O
_D i
1 U
Rsvision 0 Page 37 of 41 -
Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 5-1 (Cont'd)
Applicable Nuclear Engineering Applicable Engineering and Applicable Engineering and Bounding and Operations (NEO)
Construction (EC)*
Construction Engineering Cause Policy (s)/ Procedure (s)
Procedure (s)
Procedure (s)
NEO Policy No. 39, "Commitment ECE.5.09-01, "Design Tracking System" Verification and Interdiscipline Review" s
ECE 4.09, "Commitment Tracking System" 3.
Organizational NEO 3.03, "Preparation, Review NEO 3.03, "Preparation, Review ECE 3.03, "Preparation, Interface Procedures and Disposition of Planc Design Disposition of Plant Design Review and Approval of internal and Modifications (DMs)"
Modifications (DMs)"
Design Modifications (DMs)"
external)
NEO Policy No. 3, "Design ECE 3.03-03, "Preparation and Modifications" Review of Design Engineering-Packages" ECE 5.01-03, "Design Change Authorizations" ECE 5.09-01, "Design Verification and Interdiscipline Review" ECE 5.19, "Review of Vendor.
Documents" ECE 8.01, "Temporary Modifications" i
Revision 0 Page 38 of 41 Pcrt III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 5-1 (Cont'd)
Applicable Nuclear Engineeting Applicable Engineering and Applicable Engineering and Bounding and Operations (NEO)
Construction (EC)*
Construction Engineering Cause Policy (s)/ Procedure (s)
Procedure (s)
Procedure (s) 4.
Design Change NEO 3.03, ' Preparation, Review NEO 3.03, "Preparation, Review ECE 3.03, Preparation, Control Procedures and Disposition of Plant Design Disposition of Plant Design Review and Approval of Modifications (DMs)"
Modifications (DMs)"
Design Modifications (DMs)"
NEO 8.01, "Temporary EC 8.01, "Temporary Modifications" Modifications" ECE 3.03-03, "Preparation and Review of Design NEO 3.17, "Initiation, Review and NEO 3.17, "Initiation, Review Engineering Packages" Approval of Plant Design and Approval of Plant Design Modification Requests (DMRs)"
Modification Requests (DMRs)"
ECE 5.01-03, "Design Change Authorizations" NEO 9.17. "Initiation, Review, NEO 9.17. "Initiation Review, and Approval of Desiga and Approval of Design ECE 5.09-01, "Design Modification Requests -
Modification Requests -
Verification and Construction Phase (DMRCs)"
Construction Phase (DMRCs)"
Interdiscipline Review" NCO Policy No. 3, "Design ECE 5.19, "Review of Vendor Modifications" Documents" ECE 8.01, "Temporary Modifications" 5.
Design Verification NEO 3.03, "Preparation, Review NEO 3.03, "Preparation, Review ECE 5.09-01, "Design Procedures and Disposition of Plant Design and Disposition of Plant Design Verification and Modifications (DMs)"
Modifications (DMs)"
Interdiscipline Review" ECE-DC-8, "Design Verification of Engineering Documents" O
O O
. p]
L R; vision 0 Page 39 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 5-1 (Cont'd)
Applicable Nuclear Engineering Applicable Engineering and Applicable Engineering and Bounding and Operations (NEO)
Construction (EC)*
Construction Engineering Cause Policy (s)/ Procedure (s)
Procedure (s)
Procedure (s) 6.
Procedure NEO 2.20, "Senior Management QA EC 2.20, "Senior Management QA ECE 3.23, "Engineering Implementation Overview Program" Overview Program" Assurance Surveillance" NEO 2.02, "Operations Review NEO 2.02, "Operations Review ECE 3.23-02, "Technical Committee" Committee" Evaluations" NEO 2.08, "Joint Utility NEO 3.14, "Evaluation and Management Audit Program" Verification of Vendor Activities" NEO 3.14, "Evaluation and Verification of Vendor Activities" NEO Policy No. 2 "Quality Assurance Program" 7.
Technical Audits NEO 2.20, "Senior Management QA EC 2.20. "Senior Management QA ECE 3.23, "Engineering of Design Control Overview Program" Overview Frogram" Assurance Surveillance" NEO 2.02, "Operations Review NEO 2.02, "Operations Review ECE 3.23-02, "Technical Committee" Committee" Evaluations" NEO 2.08, "Joint Utility NEO 3.14, "Evaluation and Management Audit Program" Verification of Vendor Activities" NEO 3.14. "Evaluation and Verification of Vendor Activities" NEO Policy No. 2, "Quality Assurance Program"
Rnvision 0 Page 40 of 41 Part III - EVALUATION OF DESIGN ADEQUACY (Cont'd)
Table 5-1 (Cont'd)
Applicable Nuclear Engineering Applicable Engineering and Applicable Engineering and Bounding and Operations (NEO)
Construction (EC)*
Construction Engineering Cause Policy (s)/ Procedure (s)
Procedure (s)
Procedure (s) 8.
Technical Audit NEO 3.01, "Corrective Action" EC 3.01, "Corrective Action" ECE 3.23, "Engineering Corrective Actions Assurance Surveillance" NEO 3.07, "Management Response to NEO 3.07, "Management Response Audit Deficiencios" Audit Deficiencies" ECE 3.23-02, "Technical Evaluations" NEO 3.06, "Reporting and Control NEO 3.06, "Reporting and of Deficiencies" Control Deficiencies" ECE 3.06, "Reporting and Control of Deficiencies" NEO Policy No. 2, "Quality Assurance Program" ECE-AD-5-7, "Processing of Corrective Action Requests" 9.
Training and NEO Policy No. 10. "Nuclear ECE 1.16. "Personnel Personnel Training Program" Indoctrination and Training" Qualification NEO Policy No. 8, "Qualified ECE 1.16-01, "Qualification Nuclear Operations Station Staff" and Training of Coatings Field Engineers" ECE 1.16-04, "Qualification of Engineering Walkdown Personnel"
- Wherever an NEO procedure is listed in this column, that procedure is the effective procedure for E&C (i.e. there is no EC procedure, and the NEO procedure is properly referenced and utilized within E&C to control activities addressing the potential weakness in the past design program).
O O
O
Rsvision 0 Page 41 of 41 cm I
t Part III - EVALUATION OF DESIGN ADEQUACY b
6.0 CONCLUSION
S l
l The CPRT has evaluated the CAP structure and is monitoring its implementation.
l The CPRT concludes that the CAP is adequately structured to achieve its I
objectives and that the CAP is progressing towards an orderly and successful l
completion. Additionally, TU Electric's management has provided appropriate I
oversight programs such as the TAP and EFE to provide additional assurance that the CAP objectives are met.
Therefore, the CPRT concludes that the design validation program and overview activities provide reasonable assurance that the design complies with CPSES current licensing commitments and NRC regulations subject to the completion of final reconciliation as described in Part V.
The CPRT has also evaluated the scope of the current design control program and the results of ongoing overview programs and concludes that the design control program adequately addresses design control-related criteria of 10CFR50 Appendix B and industry standard ANSI N45.2.11.
The CPRT is monitoring the implementation of the current design control program and the initial stages of the operations phase design control program.
Based upon the acceptable structure of the current design control program, the strength of TU Electric's management team and professional resources, and evidence of successful implementation, the CPRT has reasonable assurance that areas of potential weakness in the past design program have been corrected.
O l
l l
l
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l O
Rsvision 0
]
Page 1 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY n
I (d
1.0 INTRODUCTION
1.1 ' Purpose The. purpose of Part IV is to supplement the evaluation of the quality of construction of CPSES presented by the Comanche Peak Response Team (CPRT) in the Collective Evaluation Report (CER). That evaluation addresses the quality of CPSES construction in terms of its compliance with the October 1985 design, or later design in cases where a later design was used by the CPRT in order to evaluate hardware (for convenience, this design will be referred to as the "October 1985 design").
Extension of the CPRT results to address compliance of CPSES construction to the current validated design is covered by Part V.
1.2 Background
The CPRT investigared specific issues related to the quality of construction of CPSES raised by the NRC Technical Review Team (TRT), by the ASLB and the intervenors in the CPSES operating license proceeding, and by other external sources, and har, performed a comprehensive self-initiated evaluation of the quality of construction under Issue-Specific Action Plan (ISAP) VII.c.
The results of these CPRT investigations are reported in the various ISAP Results Reports and are collectively evaluated in the CER. Since issuance of the CER, two additional activities have been completed that provide supplemental inforination on specific aspects of CPSES construction:
r(
The Project has performed engineering analyses of safety-significant or unclassified deviations included in the CPRT hardware findings
- reported in the CER to determine whether the conditions noted by the CPRT, if uncorrected, could have precluded achievin5 or maintaining a safe plant condition.
The CPRT has completed its investigation of the quality of purchased equipment and material under ISAP VII.s.9.
The results of these activities have been analyzed to determine whether they alter the conclusions presented in the CER.
1.3 Organization of Part IV The remainder of this part is divided into five sections, as followr:
Section 2.0 summarizes the results of CPRT investigations of the quality of construction of CPSES that were described in the CER.
Hardware deviations that were or might be safety si nificant as found or 6
that might have been safety significant had they occurred in a different plant location were classified as findings by the CPRT. More specific O
definitions of particular finding types are provided in Section 2.0.
l
Ravicien 0 Page 2 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd)
Section 3.0 describes the two additional activities to assess the quality of CPSES construction:
the Project evaluations of certain deviations reported by CPRT and the ISAP VII.a.9 investigation of procured equipment and material at CPSES.
Section 4.0 describes overview activities being performed to ensure that Project actions to correct and prevent recurrence of problems identified in CPRT findings are properly defined and implemented.
Section 5.0 presents the CPRT evaluation of the CPSES construction process.
Section 6.0 presents the CPRT conclusions regarding the compliance of CPSES construction with the October 1985 design.
2.0 RESULTS OF EVALUATIONS OF QUALITY OF CONSTRUCTION REPORTED IN THE CER The CPRT was established by TU Electric to investigate various issues raised by the NRC TRT regarding the construction and testing of CPSES and the quality assurance (QA) programs associated with these activities.
The results of these investigations have been reported in 46 ISAP Results Reports.
Each ISAP was designed to ensure the identification and resolution of any safety significant problems related to an identified issue or issues and the root causes of any i
such problems.
To ensure that the ISAP Results Reports encompassed issues i
I raised by external sources (including NRC inspectors, the ASLB, and the intervenors in the CPSES operating license proceeding), the CPRT developed a list of external source issues (ESIs), compared these issues against those l
addressed by the ISAPs, and determined that the ESIs (related ';o the quality of I
construction, construction QA and testin5) were adequately covered by the CPRT program. Quality assurance and testing are addressed in Parts VI and VII respectively.
In addition, the CPRT performed a self-initinted evaluation of l
the quality of construction of CPSES, Units 1 and 2.
The results of this j
evaluation are reported in the Results Report for ISAP VII.c.
)
l Although the methodology employed by the CPRT varied somewhat from ISAP to ISAP, l
the ISAPs shared certain common features.
These features are summarized below:
l Reinspections, documentation reviews, or other evaluations were undertaken to determine whether the activity in question was performed properly; deviations were identified for attributes that did not comply with requirements of the October 1985 design.
When deviations in hardware were found, the deviations were evaluated to determine whether, if left uncorrected, they could have resulted in a failure of an item to perform its safety function. Any such deviation was classified as a construction deficiency.
In some cases, the CPRT did not or could not determine whether a deviation could result in such a failure; such deviations were designated as unclassified deviations.
Similarly, any QA program deviations identified during these reinspections and reviews were evaluated to
Rcvisien 0 Page 3 of 9 l
Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd) determine whether a substantive revision of the QA program was needed' l
to bring the program into compliance with applicable requirements or whether extensive evaluation would be required to determine the effect on the quality of construction.
If either of these ccnditions was found to exist, then the deviations were classified as a QA/QC program deficiency.
'If no deviation for an attribute was determined to be a construction deficiency, an engineering evaluation was performed of the deviations to determine whether they indicated a type of flawed construction such that it was likely that an undetected construction deficiency existed in the uninspected portion of a population.
Such deviations were classified as "adverse trends" if an undetected construction deficiency was concluded to be likely to exist, or as "unclassified trends" if it was uncertain whether a deficiency was likely to exist.
For each finding (i.e., construction deficiency, unclassified deviation, QA/QC program deficiency, adverse trend, or unclassified trend), analyses were performed to identify the root cause and generic implications of the finding.
The CPRT made recommendations for corrective action for each finding based upon the results of its root cause and generic implications analyses.
g)
(
Corrective action plans were developed by the Project in response to CPRT findings to ensure the adequacy of existing hardware and of future programs. These plans contain the corrective actions recommended by the CPRT or alternate actions proposed by the Project and are subject to review and concurrence by the CPRT. The CPRT is also overviewing the implementation of corrective action by the Project to obtain additional assurance that identified concerns will be resolved.
The above activities were (and in the last instance are) subject to the CPRT QA program. The QA program provides for the use of checklists and instructions and preparation of documentation of the results of CPRT's reinspections and reviews, and includes the performance of audits.
The process described above was designed to yield a conservative result. The CPRT adopted and TU Electric accepted this conservative approach so that the resulting corrective action programs would serve to make the quality of construction evident and acceptable prior to operation.
Examples of elements in the evaluation process that illustrate this conservatism are discussed below.
The approach taken to implement the definition of a construction deficiency resulted in the identification of construction deficiencies for items that do not meet code'-allowable limits, but that would not have failed under design loading conditions, and deviations that, if left uncorrected, would not have resulted in a failure of any structure, system or component to perform its
(
)
intended safety function.
For example, a deviation on a pipe support could be l
classified as a construction deficiency even though adjacent pipe supports would I
prevent the associated piping from becoming overstressed under the design loading conditions. Thus, the existence of a construction deficiency, l
lr
Rsvision 0 Page 4 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd) identified through such a conservativa evaluation, is not sufficient to imply that the safety of the plant would have been adversely affected if the construction deficiency had been left uncorrected.
Similarly, the definitions of an adverse trend and an unclassified trend also lead to conservative results.
Both are based upon the definition of a construction deficiency, and both involve additional conservatism in that they incorporate extrapolation from found conditions that were not construction deficiencies.
The results of the CPRT investigations into the quality of CPSES construction, and a collective evaluation of these results, were presented in the CER.
The primary purpose of the collective evaluation was to determine whether, when considered collectively, the results of the CPRT investigations indicated a need for any corrective action beyond that already being taken in response to the results of individual investigations, and to reach overall conclusions regarding the adequacy of CPSES construction quality, construction QA programs, and testing. As discussed in the CER, the results of the reinspections and documentation reviews from ISAP VII.c demonstrate a high conformance rate, with 98 percent of the inspection points found to be in conformance with design requirements. Of the two percent of the inspection points and documentation review points found to deviate from design requirements, CPRT determined that more than three-fourths were insignificant.
As a result of its reinspections and documentation reviews performed under ISAP VII.c and the other ISAPs, the CPRT identified 93 findings, which included construction deficiencies, adverse trends, and unclassified trends. As discussed above, the definition of a construction deficiency (and of the other finding types es well) is conservative, and the existence of a finding does not necessarily imply that the associated deviation would have precluded achieving or maintaining a safe shutdown condition if left uncorrected.
Nevertheless, corrective and preventive action is being taken for each CPRT finding to ensure the adequacy of existing hardware and of future programs.
Deviations noted by the CPRT during its investigations were provided to the Project for resolution, typically through the CPSES nonconformance system':.
In addition, for each construction deficiency, adverse trend, er unclassified trend identified, the CPRT provided the Project with recommendations for actions to be taken to ensure the adequacy of exiscing hardware and of future programs.
In response, the Project provided the CPRT with proposed methods for addressing the CPRT recommendations.
The CPRT has concurred with the Project corrective actions, including the preventive actions, and is overviewing their implementation.
Based upon its collective evaluation, the CPRT made certain recommendations for preventive action related to historical construction practices. The Project has reviewed these CPRT recommendations and has concluded in most instances that the construction practices of concern had been corrected by the Project through their own construction program improvements prior to receiving the recommendations from CPRT.
The Project will respond formally to each of the CPRT recommendations and will either document completed actions that resolve the CPRT concerns or will implement additional corrective action to resolve those
Rovision 0 Pogs 5 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cotit'd)
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concerns. With.one exception (historical QC inspection procedures), the
. collective. evaluation of the findings did not identify any programmatic problem potentially impacting existing hardware that was not already being addrec ed by the Project.. With respect.to historical QC inspection procedures, the CPRT recommended that a review of historical inspection procedures be performed to identify those instances of historical procedure inadequacy that warrant additional evaluation.
Based upon the results of its investigations of the quality of CFSES construction and upon its collective evaluation of those results, the CPRT.
concluded in the CER that, upon completion of the corrective action for findings identified by the CPRT, there will be reasonable assurance that the structures, systems, and components of CPSES will meet the significant, safety related requirements of the October 1985 design (or later applicable design). The bassa for this conclusion are more fully described in the CER.
3.0 RESULTS OF OTHER CPRT INVESTIGATIONS RELATED TO THE QUALITY OF CONSTRUCTION l
This section discusses the effects of the Project evaluations of certain CPRT findings and the effects of the results of ISAP VII.a.9 on the conclusions. in the CER related to the quality of construction.
3.1 Project Evaluation of CPRT Findings The CER referred to separate evaluations being performed by the Project of each construction deficiency and of each unclassified construction deviation identified by the CPRT. These evaluations addressed each identified hardware deviation evaluated under the CPRT methodology to be safety significant or unclassified. The purpose of these evaluations was to illustrate the conservatism in the CPRT methodology for the identification of findings.
The Croject evaluations were designed to determine whether the found conditions, had they remained uncorrected, could have precluded achieving or maintaining a safe plant condition. The Project evaluation criteria permitted component failure if the analysis demonstrated no adverse impact on either a system function or redundancy required to reach a safe shutdown condition.
Engineering criteria above design allowables were utilized if the criteria were sufficient to preclude failure.
In each case evaluated, the Project methodology was designed to bound the consequences of the found conditions and to illustrate that the CPRT designation of "safety-significant" does not necessarily constitute.a determination of an unsafe plant condition.
The Project has completed the engineering evaluations of the findings identified by the CPRT that included at least one safety significant or unclassified construction deviation. The Project determined that for more than three-fourths of these findings, the found condition would not have prevented achieving or l
maintaining a safe plant condition (the results of the Project evaluation of the remainder of the findings were indeterminate).
Based upon its review of the i
Project's evaluations to date, the CPRT concludes that these evaluations confirm the conservatism inherent in the CPRT conclusions regarding the quality of CPSES construction.
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Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd) 3.2 Summary of ISAP VII.a.9 Results In ISAP VII.a.9, the CPRT examined the conformance of equipment and material purchased under the TU Electric and Brown & Root procurement programs for CPSES to their applicable specifications under the October 1985 design.
ISAP VII.a.9 was not completed prior to the issuance of the CER, and the final results of that ISAP were therefore not discussed in the CER.
This section presents the CPRT evaluation of the effects of the ISAP VII.a.9 results on the CPRT conclusions presented in the CER with respect to the quality of CPSES construction.
The effect of the VII.a.9 results on the CPRT collective evaluation of the CPSES QA program is discussed in Part VI.
ISAP VII.a.9 included reinspection of samples of procured equipment and/or review of quality documentation for 62 different vendors supplying items to CPSES. The details of this evaluation and its results are described in the Results Report for ISAP VII.a.9.
Because ISAP VII.a.9 focused upon manufacturing quality, the results complement the construction quality-related conclusions presented in the CER. Of approximately 195,000 reinspection / review points, 94 percent were found to be acceptable.
If insignificant deviations are also counted as acceptable, then 99 percent of the reinspection / review points would be acceptable.
These results are censervative because the sample of items selected for evalus. tion under ISAP VII.a.9 was biased towardt vendors with a previous history of proble'ns and because the method for ecunting dr.viazions, for convenience sake, counted many accually insignificant deviationa as notable.
Seven types of findings were identified during the ISAP VII.a.9 investigation.
The conditions identified in four of thesc types cf findings had been previously identified, and Project corrective action for these items had been taken or was underway at the time tha Results Repcrt for ISA? Vll.a.0 was is.auod. The CPRT has provided the Project with recommendations for corrective action to address the remaining three types of findings. The Project and CPRT have discussed the findings and the recommendations; the Project is developing corrective action plans.
In general, CPSES material and equipment were procured from the same vendors and manufactured under the same ven6or QA programs as were equipment and material supplied to other nuclear facilities.
The findings identified during this evaluation were largely reflective of problems occurring generally in the nuclear industry.
Except for two of the types of findings identified, the i
related deviations may not have been detected by vendor surveillance and receipt inspection programs that would have been judged to be adequate and effective when compared with industry practices and requirements in effect at the time the deviations occurred. Thus, in general, the results of ISAP VII.a.9 indicate that the historical procurement program was adequate.
In the CER, a finding related to a loose electrical termination was noted.
As l
reported in ISAP VII.a.9, additional instances of loose terminals were noted.
The Project's corrective action was accordingly broadened to include both l
reinspection of terminations throughout the plant and new procedural requirements for tightness verification.
Based on this action, the CPRT concludes that the potential generic concern regarding loose terminations is I
being addressed. Thus, no further corrective action is required.
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Revisien 0 Page 7 of 9 c
Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd) c/m\\
In'the Results Report for ISAP VII.a.9, CPRT concluded that, upon implementation of the recommendations made by the CPRT, there will be reasonable assurance that procured equipment and materials at CPSES meet the significant, safety-related requirements'of their applicable specifications (under the October 1985 design).
Thus, the ISAP VII.a.9 results generally complement the results presented in the CER with. respect to the quality of CPSES construction.
4.0 OVERVIEW OF PROJECT CORRECTIVE ACTIONS A number of programs exist to assure that appropriate corrective actions, j
including preventive actions, are taken in response to findings identified by the CPRT.
First, the corrective actions proposed by the Project in response to CPRT findings are subject to concurrence by the CPRT. The CPRT and the Project are in the process of finalizing corrective action plans for findings from the CER and ISAP VII a.9, and have reached agreement on corrective action plans for the remaining CPRT findings.
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SeconA, corrective actions are performed under the applicable reo,uirements of the TU Electric QA program. This program and its implementation for J
construction activities have been investigated by the CPRT and determined to comply witP the requirements of 10CFR50, Appendix B (see Part VI).
Third, the W Electric Quality Assurance Technical Audit Program (TAP) is examining the corrective actions undertaken by the P;oject (1) to assure that
,. G Project commitments for corrective action are captured in a formal control system; (2) to assure that the corrective actions are properly implemented; and (3) to assure that corrective actions are adequately coa.pleted and documented.
The TAP performs these functions by means of forms.1 audits, including review of documentation, observation of work performance, and inspection of hardware.
To date, the TAP has completed 29 audits of specific corrective action activities and has initiated follow-up activities, where applicable, to ensure closure of audit findings.
Finallf, the CPRT is overviewing the Project implementation of selected corrective action commitments.
This overview focuses primarily on the TAP.
The CPRT overview of the TAP includes review of TAP implementing procedures and auditor qualifications to determine whether applicable ANSI and TU Electric procedural requirements have been met, review of audit records to determine the adequacy of the audit program and any associated corrective actions, and independent field checks of items reported ia the audit records.
The CPRT overviews to date have examined program descriptions and procedures, personnel qualifications, and a number of completed TAP audit reports.
In addition, members of the CPRT have attended entrance and exit meetings and participated in discussions of findings with the audited organizations for selected TAP audits.
The CPRT review of these items indicates that the TAP is fulfilling its program objectives with respect to corrective actions. The CPRT overview of the TAP and verification of implementation of selected corrective' actions will continue until the CPRT concludes that there is sufficient evidence that all corrective actions will be properly implemented.
In summary, these overview programs ensure that appropriate corrective action is implemented in response to the CPRT findings.
Rsvicien 0 Pzgs 8 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd) 5.0 CPRT EVALUATION OF CURRENT CPSES CONSTRUCTION PROCESS The results of the CPRT investigations and evaluations also provide the basis for conclusions regarding the adequacy of the current CPSES construction process. As noted above, a complete set of corrective and preventive actions is i
being implemented in response to construction-related findings identified by the
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CPRT, including findings resulting from the comprehensive review of CPSES i
construction performed under ISAP VII.c.
Further, as discussed in the CER and in Part VI of this report, the CPRT has determined that the current construction l
QA program is adequate under the requirements of 10CFR50, Appendix B.
Key elements of the current construction process, such as the provisions for developing installation procedures and the craft training requirements, were included in the QA program evaluation and found to be acceptable.
The CPRT l
concludes that, upon completion of preventive actions for the construction I
process that resulted from CPRT findings, the CPSES construction process will be l
adequate; the construction process and the construction QA program together are suitable to ensure that ongoing installations comply with applicable requirements.
The above conclusion is based in part on a separate determination by the CPRT
- that the CAP provides assurance that hardware constructed or modified prior te i
preventive action implementation, if any, will conform with the requirements of
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the applicable design.
In general, the revised installation procedures address pertinent requirements from the validated specifications and the Project is reviewing the procedures to ensure that they address the relevant concerns in the CPRT recommendations for preventative action.
Further, whenever i
installation and/or inspection procedures are changed, the CPSES program requires ; hat consideration be given to the need for backfits under the revised procedures to msure that previously installed hardware is acceptable.
This provision, a part of the construction process, assures that construction performed during CAP will be responsive to the preventive action recommendations.
6.0 CPRT CONCLUSIONS REGARDING QUALITY OF CPSES CONSTRUCTION The CPRT has performed extensive investigations of the quality of CPSES construction.
The results of these investigations sie summarized in the CER.
Since the issuance of the CER, the CPRT has performed additional activities that supplement the results presented in the CER.
First, the Project performed evaluations to determine whether the CPRT findings reflect conditions that could have precluded achieving or maintaining a safe plant condition and found that over three-foutchs would not.
These evaluations illustrate the conservatism of the CPRT methods and results.
Second, the ISAP VII.a.9 investigation of purchased equipment and material has been completed.
The results of ISAP VII.a.9 demonstrate that, in general, the historical procurement program was adequate, and, upon implementation of the recommendations made by the CPRT in the Results Report for ISAP VII.a.9, there will be reasonable assurance that purchased equipment and materials at CPSES meet the significant, safety-related requirements of their applicable specifications (under the October 1965 design).
These results do not change the CPRT concitsions with respect to the quality of CPSES construction that were reported in the CER. As reported in the CER, the
Ravicien 0 Page 9 of 9 Part IV - EVALUATION OF CONSTRUCTION QUALITY (Cont'd)
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('s-)~' CPRT concluded that issues related to CPSES quality of construction have been identified, bounded and addressed by a complete set of corrective actions. The extensive CPRT examinations of the quality of construction, coupled with the actions being taken by the Project to correct and prevent the recurrence of hardware deficiencies noted by the CPRT, provide reasonable assurance that CPSES structures, systems and components will meet the significant, safety-related requirements of the October 1985 design (or later applicable design).
The compliance of CPSES construction with the current validated design is discussed in Part V.
The results of the CPRT investigations and evaluations also provide the basis for conclusions regarding the adequacy of the current CPSES construction process. The CPRT has determined that the current construction QA program complies with 10CFR50, Appendix B, that preventive actions have been and are being implemented for the construction process related CPRT findings, and that the Project is taking appropriate corrective action for affected, completed hardware whenever the construction process is upgraded. Thus, the CPSES construction process, including the backfit provisions, provides reasonable assurance that hardware installations and modifications during CAP will comply with the validated design.
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R:visitn 0 Page 1 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION J
1.0 INTRODUCTION
1.1 Purpose The purpose of Part V is to evaluate the TU Electric programs and processes for integrating the results of the TU Electric design validation program (discussed in Part III) with the results of the Comanche Peak Response Team (CPRT) evaluation of the quality of construction (discussed in Part IV), and to determine whether these programs provide reasonable assurance that CPSES structures, systems, and components will be capable of performing their intended safety functions.
1.2 Background
As discussed in Part III, the purpose of the design validation program is to validate the design of safety-related and selected non-safety-related structures, systems, and components of CPSES.* As a result of the design validation, changes were made in the design and/or acceptance criteria for some structures, systems, and components that had already been constructed or installed.
Further, the Project identified some attributes that were not reinspected during the CPRT evaluation of the quality of construction, because they eithcr pertained to non-safety-related items (not in the CPRT scope), were established by tha design validation process, or were excluded from CPRT reinspections for various reasons.
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As discussed in Part IV, the CPRT conducted an evaluation of the quality of construction of CPSES.
In general, this evaluation was performed using the requirements of the October 1985 CPSES desi n (or later applicable design) and 5
was based upon the results of reinspections and documentation reviews of a sample of the safety-related items in the plant that had been QC accepted. As a cesult of these reinspections and documentation reviews, the CPRT found a generally high conformance rate; however, the CPRT identified findings for a number of attributes, and made recommendations for corrective action.
These recommendations usually included reinspections of the attributes affected by the findings.
TU Electric has programs and processes that serve to integrate the results from the design validation and CPRT quality of construction programs.
The primary integrating element is the Post Construction Hardware Validation Program (PCHVP), which was developed by TU Electric to demonstrate that existing structures, systems, and components are in compliance with the validated l
i installation design criteria. This objective is accomplished by requiring either physical validation or a more extensive engineering evaluation (technical disposition) of all final acceptance attributes (defined in Section 2.2) for which the CPRT recommended reinspection, the design validation resulted in changes to the design or more stringent acceptance criteria, or the CPRT program did not evaluate construction quality.
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As discussed in Part III, the NSSS design and vendor hardware design (other
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than design interface) are not included in the design validation.
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R;vici+,n 0 Page 2 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd)
The other major integrating element is the final reconciliation process, which is part of the TU Electric design control process; reconciliation will confirm that the hardware has been validated or provide resolution of any inconsistency between the installed hardware and the validated design that is detected by the PCHVP.
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Completion and QC inspection of any identified hardware modifications required to complete design and hardware validation are governed by the normal Project procedures for construction and QC inspection, even though they are considered to be part of the PCHVP.
Further, in addition to the standard CPSES QA program activities, two special programs, the TU Electric QA Technical Audit Program (TAP) and the Engineering Functional Evaluation (EFE), were created to focus specifically on assuring the adequacy of Corrective Action Program (CAP) activities, including tnose of the PCHVP and associated final reconciliation.
Finally, the established testing program discussed in Part VII is providing for retesting or any new testing, as appropriate, of structures, syrtems, or components.
1.3 Organization of PartJ The remainder of this part is divided into five sections as follows:
Section 2.0 describes the PCHVP.
Section 3.0 describes the final reconciliation process, which uses the PCHVP results to produce a validated design and validated hardware that are consistent.
Section 4.0 descrioes the variouc programs that have been established to overview the inplementation of the PCHVP and the final reconciliation pro:ess discussed in Sections 2.0 and 3.0.
Section 5.0 presents the CPRT evaluation of the TU Electric programs that integrate the results of the construction quality and design adequacy evaluation.s.
Section 6.0 presents the CPRT conclusions regarding the resulting adequacy of design and construction of CPSES.
2.0 DESCRIPTION
OF THE POST CONSTRUCTION HARDWARE VALIDATION PROGRAM (PCHVP) 2.1 Methodology The scope of the PCHVP is similar to the scope of the design validation program.
Specifically, the PCHVP encompasses the safety related structures, systems, and components at CPSES and selected non-safety related systems (i.e., the fire protection systems and seismic Category II systems).
Except for those hardware items impacted by ISAP VII.a.9 corrective actions, the scope of the PCHVP does not include hardware fabricated or supplied by the NSSS vendor, or by other
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vendors in accordance with approved vendor QA programs, but does include the installation of such hardware.
The PCHVP is being implemented by the engineering contractors (Stone & Webster Engineering Corporation [SWEC), Ebasco, and Impell) under the overall direction of TU Electric and under the TU Electric QA Program. Engineering walkdowns under the PCHVP are being performed by qualified engineering personnel from these engineering contractors. QC inspections under the PCHVP ste being performed by certified QC inspectors under the direction of TU Electric QA. The construction organization implements modifications.
The PCHVP consists of the following steps:
Based upon the results of the design validation program, a matrix (referred to as the "Commodity / Attribute Matrix") was developed that lists, for each commodity, all attributes that provide, in whole or in part, the basis for final acceptance of an item in accordance with the installation specifications related to the safety functions of the item.
An attribute evaluation is performed and documented for the attributes listed on the Cot.modity/ Attribute Matrix to determine which attributes require physical validation or engineering evaluation.
Such validaticu or evaluation of an attribute is required unless the CPRT A,
verified that the quality of construction of the attribute is C) acceptable, and the design and acceptance criteria for the 4.ttribute were not made more stringent by design validation.
For each attribute identified in the proceding step, a deteruination is trade of whether the attribute is accessible for physical validation (either by QC inspection or engineering walkdown); otherwise, an engineering evaluation (referred to as a "technical disposition") is performed.
For identified accessible attributes, procedures (entitled "Field Verification Methods" [WMs)) are prepared to control physical validation. Acceptance criteria in FVMs are required to be traceable to validated design documents.
Implementation of an FVM for a given item results in either acceptance of the attribute for the item or documentation of the condition for resolution.
For inaccessible attributes identified, existing information related to the attributes is evaluated by an engineering evaluation process resulting in a technical disposition to determine whether the attributes can be accepted based upon available information.
If an attribute is not accepted, an alternative plan (e.g., non-destructive testing or creating access for physical validation) is developed for determining the acceptability of the attribute.
p These steps are described more fully in Sections 2.2 through 2.6.
R;visicn 0 Page 4 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESICN AND CONSTRUCTION (Cont'd) 2.2 Development of the Commodity / Attribute Matrix As a part of the design validation program, validated installation specifications have been developed that include the inspection requirements for construction or installation of an item, These requirements include the final acceptance attributes that, if acceptable based on defined criteria, suffice to confirm that the installed item will meet the intent of the designer (including the capability of performing its intended safety function), and they also include in process attributes.
For the purposes of the PCHVP, the Commodity / Attribute Matrix (the "matrix") was prepared, which lists each final acceptance attribute corresponding to the inspection requirements for each crveodity.
The matrix is controlled in accordance with procedures. There ne approximately 1500 attributes in the matrix.
In addition to listing each commodity type and final acceptance attribute, the matrix also includes reference to the applicable specification, an indication of whether physical validation is required, and if so, the type of validation to be performed (i.e., engineering walkdown or QC inspection) and the applicable FVM.
The matrix was subatantially complete when issued to the NRC staff for information. Ongoing matrix activities are focused on documenting the basis for determining those attrihtes requiring further evaluation.
2.3 Attribute Evaluations In accordance with procedures controlling the PCHVP, each of the attributes in the Commodity / Attribute Matrix is evaluated to identify those for which any of the following conditions existad:
The attribute was recommended for reinspection by the CPRT.
Design validation resulted in a change to the design or to a hardware final acceptance attribute that includes more stringent criteria than the original acceptance attribute, or the CPRT did not reinspect the attribute.
Design validation resulted in new work, including modifications to existing hardware.
If the CPRT had no recommendation, and the latter two conditions do not apply, then the attribute is accepted through an engineering evaluation based on the results of the CPRT investigation.
If the evaluation concludes that the attribute has been validated, the basis for acceptance is documented.
If any of the three conditions are applicable, then a determination is made whether the attribute is accessible. 'Ihis determination and the ensuing physical validation or technical disposition for identified attributes are discussed further in Section 2.4.
2.4 Determinations of Accessibility For an attribute that 4.s identified during attribute evaluation based on one or more of the three conditions, a determination is made of whether the attribute
R;visicn 0 Page 5 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd)
L is accessible, either generically or for individual items. An attribute is "accessible" if an examination can be performed using the method delineated in the installation specification. For attributes that are accessible, a physical validation is performed, as discussed in Section 2.5.
For attributes that are not accessible, the cause of the inaccessibility is documentsd and a technical disposition is completed for each attribute, as discussed in Section 2.6.
2.5 Physical Validation of Accessible Attributes Physicci validation consisting of either QC inspection or an engineering walkdown is performed for each identified accessible attribute.
The determination of whether an accessible attribute should be validated by QC inspection or en61neering walkdown depends upon the nature of the attribute.
In general, engineering walkdowns are performed to assess the functionSlity of the hardware (e.g., systems interaction), while QC inspections are performed to document the as built condition of the plant.
The conduct of QC inspections and engineering walkdowns under the PCHVP is controlled by FVMs.
The FVMs identify the activities necessary to satisfy the requirements of the applicable validated installation specifications.
Procedures require that WMs contain information such as the organizations responsible for performing the physical validations, the methods for conducting the physical validacion, the acceptance criteria for the attributes, and requirements for documenting the results of the physical validation.
v Development of the WMs is completed.
Individuals performing QC inspections under the PCHVP are certified under the TU Electric QA program in accordance with ANSI N45.2.6.
Individuals performing engineering walkdowns under the PCHVP are required to be qualified by a combination of education, experience, training, and management assessment. All engineering walkdown personnel are required to undergo training consisting of required reading and/or classroom instruction in the details of the applicable FVM(s).
Project procedures require that FVMs contain a section that 1) references the specific training requirements for individuals who perform the TVMs, and 2) describes methods for assuring that required training is accomplished prior to performance of the FVMs.
Discrepancies identified during physical validation are documented and are subject to disposition as discussed in Section 2.7.
If an attribute for an individual item is determined to be inaccessible during physical validation, this fact is documented,and the attribute for that item is subject to technical disposition as discussed in Section 2.6.
TU Electric procedures permit physical validation of an attribute to be curtailed if sufficient confirmatory evidence has been collected to provide a vell. documented basis for determining the acceptability of the attribute.
Justification for curtailment must be documented by an engineering evaluation and is subject to review and approval by Comanche Peak Engineering (CPE),
R;visicn 0 Pcg3 6 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd) 2.6 Technical Disposition for Inaccessible Attributes For identified attributes that are inaccessible, either generically or for individual items, an engineering evaluation is performed to determine the technical disposition for the attribute.
In performing the engineering evaluation to develop a technical disposition, several types of data may be considered in accordance with the governing procedure.
Examples of such considerations include:
(1) documentation of the results of QC inspections, inspections by the Authorized Nuclear Inspector (ANI), and receipt inspections may be reviewed for direct evidence of the quality of the inaccessible attribute; (2) documentation of test results may be reviewed to identify whether the performance of the component or system containing the inaccessible attribute was adequate to confirm the function of the hardware; and (3) the results of reinspections (either by the CPRT or through the PCHVP or both) of accessible attributes may be reviewed to support inferences regarding the quality of the inaccessible attribute.
Other types of documents (such as historical specifications, construction and inspection procedures, audit reports, and surveillance reports) may also be reviewed to determine the adequacy of the process for installing items containing the attribute in order to draw inferences regarding the quality of the inaccessible attribute.
Finally, other documents may be reviewed for any additional information that relates to the quality of the inaccessible attribute.
The engineering evaluation is performed considering the appropriate data from the above sources. The resulting technical disposition is required by procedure to include, as a minimum, the following:
a written description of the attribute; a written justification for acceptance of the attribute:
a written explanation of the logic utilized to conclude that the attribute need not be physically-validated; a chronology demonstrating that the attribute has not been significantly altered by design validation; and a reference to documents reviewed to support the disposition.
If it is concluded that the data evaluated provide evidence of the acceptability of the attributa, then this conclusion is required to be documented.
If it is determined that ti.e data reviewed' do not provide evidence of the acceptability of the attribute, then documentation is prepared that explains why the attribute cannot be accepted and that recommends an alternative plan. The alternative plan may include approaches such as performing non-destructive testing or creating access to the attribute for validation.
This alternative plan, after acceptance by CPE, is then implemented to validate the attribute.
The entire engineering evaluation as documented in the technical disposition is subject to review and approval by CPE.
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2.7 Hardware Modifications During implementation of the CAP, modification to hardware may be initiated by one of two methods.
Each is discussed below.
First, as a result of the design validation process, changes in design may be made which in turn result in new hardware or in modification to existin5 hardware in order to conform the hardware with the validated design. As discussed in Part III, these hardware modifications are initiated through design change documentation.
Second, as a result of the PCHVP, discrepancies between the validated design and the as-built hardware may be identified on a nonconformance document. The dispositions of these discrepancies may require modifications to the as-built hardware to make it acceptable under the validated design.
This situation is discussed further in Section 3.0.
Regardless of whether a modification occurs as a result of design validation or disposition of a nonconformance identified during PCHVP, the modified hardware is subject to QC inspection to ensure that the hardware conforms with the validated design.
The modification process (e.g., issuance and disposition of a nonconformance report [NCR), issuance of a DCA, implementation of the modification, and QC inspection) is controlled by the normal Project procedures governing these types of activities at CPSES.
Nevertheless, these activities are considered to be part of the PCHVP.
LJ 2.8 Use of Results from the PCHVP Implementation of the PCHVP provides validated as-built data for attributes requiring further evaluation. As discussed in Section 3.0, these data are used in the final reconciliation process to ensure that the validated design and the validated hardware are consistent.
3.0 FINAL RECONCILIATION PROCESS The purpose of the final reconciliation process is to use the results of the PCHVP to determine whether the validated design and the installed hardware are consistent.
As discussed above, the CAP includes design validation and hardware validation programs. The sequence in which these activities is performed differs from discipline to discipline.
The specific sequence applicable to a given CAP discipline is presented in the applicable Project Status Report for that discipline.
In each case, the results of these activities are reconciled to produce a validated design and validated hardware that are consistent.
Two typical sequences are presented below.
Sequence 1 1.
Develop Design criteria n(t) 2.
Design Validation k
R:.visicn 0 Page 8 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd) 3.
Hardware Validation 4.
Reconciliation This sequence is straightforward and proceeds as generally discussed in Part III and in Section 2.0 of this part.
During design validation, a set of validated design drawings and installation specifications are produced which form the basis for development of FVMs. Hardware validation is performed based on the validated design using the FVMs.
Discrepancies identified during hardware validation are documented.
The discrepancies are reconciled either by designating that the hardware be corrected (e.g., by dispositioning an NCR to "rework", "repair" or "scrap") or by modifying the design (e.g., by dispositioning an NCR to "repair" or "use-as is").
Hardware validation also includes, for some attributes, the collection of as-built data that is used in the confirmation of inputs regarding as-built conditions in design calculations under the design validation program. Appropriate documentation to change either the hardware or the design is initiated when these inputs are not confirmed in order to reconcile the hardware and design.
Sequence 2 1.
Develop Design Criteria 2.
Engineering Walkdown 3.
Design Validation including Hardware Validation 4.
Reconciliation This sequence is similar to Sequence 1, except that engineering walkdowns are performed prior to design validation in order to collect as-built data for use in the design validation process.
For example, engineering walkdowns were performed for cable tray '. angers to provide as-built data for input to cable tray hanger stress calculations. The as built data were analyzed against the design criteria and, if the data were acceptable, became a basis for producing a validated design.
If the data were not acceptable, the conditions were documented and the hardware is subject to modification as discussed in Section 2.0.
Once the validated design is produced, the remaining steps in Sequence 2 are the same as those in Sequence 1.
In general, during hardware validation under the PCHVP, credit is taken for the as-built data collected during the engineering walkdowns in Step 2, and these walkdowns are not repeated under the PCHVP.
However, additional hardware validation is performed for affected i
attributes if the engineering walkdowns in Step 2 did not collect sufficient data to determine the acceptability of each of the attributes identified for validation in the Commodity / Attribute Matrix. Additionally, as discussed in Section 2.7, QC inspections are performed for any modifications resulting from design validation or disposition of nonconformances identified during hardware validation, and credit for these inspections may be taken under PCHVP.
For each hardware item, the various steps are being implemented for attributes requiring further evaluation in a sequence that ensures that sufficient as-built
R;visien 0 Pega 9 of 15 Part V. EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd)
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-information'is obtained to permit either acceptance in accordance with the validated design or definition of required modifications. Thus, in both Sequences 1 and 2,;hardwsre modifications may be implemented as a result of the
. issuance of DCAs following design validation or of the dispositioning of NCRs following hardware validation.
Though such modification activities are governed by the normal' Project procedures for these activities, they are considered to be
.part of the PCHVP.
The final reconciliation process also assures that the final validated' design is complete and consistent.
4.0 QA AND OVERVIEW ACTIVITIES The Project and its contractors are performing the integration activities discussed above under the provisions of the TU Electric QA Program.
To assure conformance with these provisions and the adequacy of the final products, TU Electric has established and is implementing several programs to overview these activities. Overview of the PCHVP and final reconciliation process is provided through CPSES QA programs, including both routine QA activities and two additional programs (TAP and EFE) focused on CAP, and through the CPRT program as described below, t
4.1 QA Programs A(')
Overview of integration activities is provided by TU Electric QA internal audits and by the QA organizations of the CAP engineering contractors. These programs, though applicable outsido the CAP as well, provide overviews of the PCHVP and final reconciliation activities that address implementation of 10CFR50, Appendix B requirements.
TU Electric Engineering Assurance (EA), while not part of the QA organization, performs surveillances of engineering and design activities of TU Electric and its contractors.
Some of these surveillances pertain to PCHVP and the integration of design and construction.
In 1987. EA conducted 90 surveillances.
Some of these surveillances covered DCAs, development of FVMS, and the implementation of the PCHVP.
In general, EA surveillances confirmed that the Engineering program adequately controlled engineering activities. Findings identified were primarily implementation problems associated with program changes and enhancements. The findings were resolved by the Project. EA has developed a surveillance plan for the first quarter of 1988 which again includes a number of surveillances related to the PCHVP and integration of design and construction. These include surveillances of the engineering contractors' NCR and DCA programs, contractor DCA/NCR training, implementation of FVMs, adequacy of construction packages, the PCHVP, and design modifications.
4.2 Technical Audit Program (TAP)
The TAP is part of the TU Electric QA Program. The organization and d
qualification of personnel for the TAP are discussed in more detail in Part III.
One of the principal purposes of the TAP is to assure the overall technical and
R;visiin 0 Paga 10 cf 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd) 9 programmatic effectiveness of the CAP. To meet this purpose with respect to the PCHVP and final reconciliation, the TAP determines, on an audit basis, whether:
the "as built" status of CPSES is considered in the design validation process; required design modifications are correctly developed and implemented and the impact of modifications on interfacing design activities is addressed; I
the PCHVP implementation demonstrates technical acceptability of existing installations in accordance with validated design requirements; and final reconciliation of existing CPSES structures, systems, and components with the validated design is accomplished.
TAP audits are intended to focus primarily on che technical adequacy of the activities; however, they address programmatic adequacy as well. The TAP utilizes independent technical personnel with sufficient relevant expertise to be capable of evaluating whether the audited programs fulfill their objectives.
As discussed in Section 2.0, field validations under the PCHVP are in progress and technical dispositions have commenced for some disciplines'. Audits of those FVMs written to govern as-built data collection have been performed and the findings have been addressed.
The TAP will conduct both horizontal audits of the PCHVP and the teconciliation process, and vertical audits that address the integration of these activities.
4.3 Engineering Functional Evaluation (EFE)
The EFE is an independent technical evaluation of the CAP, which is performed under the SWEC QA Program.
The organization and qualification of personnel for the EFE are discussed in detail in Part III.
The EFE includes vertical-slice, j
technical evaluations of representative portions of the Containment Spray and Control Room HVAC systems including the associated electrical and control systems, and the Safeguards Building. A description of these technical evaluations and the other parts of the EFE is provided in Part III.
j A portion of the EFE focuses on the PCHVP and the reconciliation process.
In
)
general, the EFE includes walkdowns to verify that the hardware installation conforms with the validated design.
Specific examples of EFE walkdowns are as follows:
verification that validated design documents in the electrical area are consistent with the as constructed condition; physical evaluations to verify that the installed configuration of equipment is consistent with equipment qualification requirements; verification that as constructed conditions in the mechanical area are consistent with design documents; I
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R vici:n 0 P ga 11 cf 15 Part V - EVALUATION OF TH'd INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd) i
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verification of adequate sept. ration.of ceismic and non-seismic components, identification of potential interactions, and location of hardware to investigate potential systems interactions; verification that validated HVAC design documents are consistent with the installed hardware; verification that instruments and instrument tubing installations meet design criteria; confirmation of electrical power system configurations; and verification that various structural elements are properly accounted for in the validated design.
The walkdowns under the EFE program are performed in accordance with review plans that document key attributes for field checks of installed equipment and hardware. The walkdowns are performed by members of the EFE team, which
~
consists of engineers and specialists from SWEC, Ebasco, and Impell who have not previously participated in the performance of CPSES activities.
Because the EFE is a "vertical slice" program and addrisses selected systems, structures, and components, any valid concerns / deficiencies identified will be evaluated to determine the extent to which the deficiencies may exis't for unevaluated areas.
x 4.4 CPRT Overview Appendix H of the CPRT Program Plan requires the CPRT to overview implementation of corrective action relevant to discrepancies identified by the CPRT.
The Program P1hn states that this overview will continue until the SRT has established confidence that the corrective actions will be properly implemented.
The forward to Revision 4 of the Program Plan also states that the SRT is reviewing the adequacy and effectiveness of TAP and EFE as implemented to ensure the quality of CAP.
In addition, it states that reviews directed by SRT are being conducted to assess the adequacy of selected end products of CAP for each of the engineering contractors.
The CPRT has conducted or is planning to conduct overviews in the areas identified in Table 4.1.
Documentation of CPRT overview activities is governed by appropriate CPRT procedures and instructions.
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R;visicn 0 Page 12 of 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd)
O Table 4.1 CPRT Overview Activities Project Activity Project Overview CPRT Overview
- Development of Commodity / TAP will conduct The CPRT will overview a Attribute Matrix (see sufficient audits to sufficient number of Section 2.2),
assure the adequacy of TAP audits to assure their the matrix, effectiveness.
Examination and TAP will audit this area The CPRT will review a justification of to assure adequacy of sufficient number of attributes not requiring justifications.
evaluations to conclude further evaluation (see that they are adequate.
Section 2.3).
Preparation of FVMs (see TAP is auditing The CPRT will overview a Section 2.5).
preparation of FVMs.
sufficient number of TAP Audits for initial FVMs, audits to assure their written to collect effectiveness. The CPRT as-built data, have has also reviewed selected identified findings.
TVMs and concludes that Following implementation they are adequate (see of correc.tive actions, Section 5.0).
TAP conducted follow up audits and determined that the initial FVMs are adequate.
EA approves each new or changed FVM prior to implementation.
Implementation of FVMs TAP is auditing The CPRT will overview a (see Section 2.5).
implementation of FVMs.
sufficient number of TAP The initial TAP audits and EFE audits to assure resulted in some findings, their effectiveness.
and follow up audits determined that effective corrective action had been taken.
EA plans to conduct surveillances of
)
the implementation of FVMs.**
TU QA is also auditing implementation of FVMs.
Technical disposition of TAP will audit this area The CPRT will review a lh inaccessible attributes to assure technical sufficient number of (see Section 2.6),
adequacy.**
evaluations to conclude that they are adequate.
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Table 4.1.
CPRT Overview Activities (Cont'd)
~
-Project Activity Project Overview CPRT Overviev*
Curtailmeat, if any, of'
~ TAP will audit. curtail-The CPRT will review a field vslidations -(see :
ment decisions, if any, sufficient number _of Sections 2.5 and 2.6)._
to assure adequacy of evaluations to conclude justifications.**
that_they are adequate.
- Disposition and resolution Will be addressed by TAP These activities are of NCRs. identified during in audits of the final conducted pursuant to the hardware validation and reconciliation process.
Project construction implementation and.
QC is required to program and controls. The inspection of hardware inspect any hardware CPRT is not.overviewing
. modifications (see modification.
these' types of activities.
Sections 2.5, 2.7, and having already determined 3.~ 0 ).
the adequacy of programs and controls.
Program interfaces and EFE vertical slice and TAP The CPRT will assess these fm overall effectiveness
-integrated audits will areas.
1 address these areas.. TU QA N}-
is performing programmatic audits that address interface and effectiveness.
l In lieu of directly reviewing these activities, the CPRT may overview TAP or EFE review (s) of these activities. CPRT overview activities will proceed / continue until the CPRT concludes that the demonstrated processes afford adequate assurance that the, programs will be properly implemented.
EFE will also review these activities in cases where they are encountered within their vertical slices, c
R;visicn 0 Pago 14 ef 15 Part V - EVALUATION OF THE INTEGRATION OF DESIGN AND CONSTRUCTION (Cont'd) 5.0 CPRT EVALUATION The CPRT has evaluated the elements of CAP for integrating the results of desi n 5 validation and the evaluation of construction quality and has found that they afford an acceptable means for assuring that the hardware at CPSES will conform with the validate.d design. This conclusion is based upon the following factors:
The scope and depth of the PCHVP are extensive.
The PCHVP encompasses safety-related and selected non safety-related structures, systems and components at CPSES. The PCHVP addresses through physical validation or an engineering evaluation resulting in a technical disposition those attributes recommended for reinspection by the CPRT, attributes where the design validation program could potentially affect conformance of the attributes, and any final acceptance attribute not reinspected by the CPRT.
The methods employed by PCHVP are appropriate for attributes requiring physical validation or a technical disposition.
Accessible attributes are subject to physical validation by either QC inspection or engineering walkdowns, and inaccessible attributes are subject to evaluation by engineers to arrive at a technical disposition of the acceptability of the attributes.
Appropriato controls govern the pCHVP process.
The identification of attributes to be included within the scope of the PCHVP was based on the validated installation specifications. The I
adequacy of this review is being overviewed by the CPRT and the TAP.
The Commodity / Attribute Matrix was developed to identify the j
validation process for attributes, including identification of the j
attributes, commodity type, applicable installation specification, j
method of validation or evaluation, and applicable FVM. The adequacy of the Commodity / Attribute Matrix is being overviewed by the CPRT, the TAP, and TU Electric EA.
l Based upon a review of representative FVMs, the CPRT has found the FVMs to be adequate for controlling the appropriate physical l
validation activities and for providing the data necessary to demonstrate hardware compliance with the validated design. The TVMs i
(or a procedure referenced from the FVM) accomplish this by providing sufficient inspection methods and scope, providing appropriate personnel training requirements, identifying the necescary inspection acceptance criteria, addressing the disposition of inaccessible attributes, specifying as built documentation and data transmittal requirements, and specifying the generation of appropriate documentation for all nonconforming conditions.
Physical validation is performed by certified QC inspectors or trained and qualified engineering walkdown personnel.
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Engineering evaluations of inaccessible attributes are required to be documented as technical dispositions and accompanied by a justification and supporting documents, and are subject to review and concurrence by CPE. These engineering evaluations will be overviewed by the CPRT. TU Electric EA and the TAP.
Discrepancies are required to be documented.
The Project programs provide for reconciliation of hardware and design.
Discrepancies that are identified between the hardware and the validated design are subject to a reconciliation process.
This process is structured to assure that either the hardware is modified to comply the validated design or the validated hardware is determined to satisfy its intended design function and the design is reconciled with the validated hardware.
TU Electric QA audits and overview programs are structured to provide assurance that the TU Electric program for integrating design and construction are properly implemented.
TU Electric QA, including the TAP, plans to perform a comprehensive set of audits and surveillances of the process and of whether the validated hardware conforms with the validated design.
EFE plans to O
perform selected walkdowns of representative systems and atructures for consistency between the hardware installation and the validated design.
TU Electric EA plans to perform surveillances of angineering related activities in the PCHVP and of the integration of design and construction.
6.0 CPRT CONCLUSIONS REGARDING THF INTEGRATION OF DESIGN AND CONSTRUCTION Based upon the above, the CPRT finds that the program for integrating design and construction is adequate and that the overviews of this program are adequate for assuring the proper implementation of the program. Therefore, the CPRT concludes that the completion of the CAP will provide reasonable assurance that the structures, systems, and components at CPSES are capable of performing their intended safety functions.
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R vicicn: O P ga 1 cf 4 Part VI - EVALUATION OF QUALITY ASSURANCE
1.0 INTRODUCTION
1.1 Background
The Comanche Peak Response Team (CPRT) has examined the CPSES quality assurance (QA) program.
The CPRT evaluation of the QA program for construction was presented in the Collective Evaluation Report (CER).
E?aluation of the QA program for design was not completed at the time the CER was issued.
Additionally, the final results of the Issue Specific Action Plan (ISAP) VII.a.9 investigation of CPSES procurement activities were not yet available at the time the CER was issued.
1.2 Purpose The purpose of Part VI is to present the CPRT evaluation of the CPSES QA program for design; to summarize the results of the evaluation of construction QA presented in the CER; to evaluate the effect that the results of ISAP VII.a.9 have on the conclusions presented in the CER with respect to the CPSES QA program; and to present the overall CPRT conclusions with respect to the CPSES QA program.
1.3 Organization of Part VI The remainder of this part is divided into three sectionc.
Section 2.0 presents 7 ';
the CPRT evaluation of the CPSES QA program for design.
Section 3.0 summarizes
(,'
the results of the CPRT evaluation of the CPSES QA program for construction, which was presented in the CER, and discusses the extent to which those results are affected by the final results from the ISAP VII.a.9 investigation.
Section 4.0 presents CPRT's overall conclusions with respect to the adequacy of the CPSES QA program.
2.0 CPRT EVALUATION OF CPSES QA PROCRAM FOR DESICN CONTROL During its examination of the Corrective Action Program (CAP) design validation activities, the CPRT evaluated the scope of the CPSFS program for design control under the applicable requirements of 10CFR50, Appendix B and ANSI N45.2.11, which set forth standards to be met by design control programs for nuclear power plants.
This evaluation and its results are presented in Section 5.2 of Part III. As concluded in that section, the CPSES design control program meets applicable requirements.
Further, as discussed in Section 5.2 of Part III, the potential weaknesses identified in the historical design program have also been addressed by the CPSES design control program.
This program contains all of the elements that will be required to complete design reconciliation and that would be required both to maintain plant design until operation and to make the transition to an operating plant design control program.
R;vici n: O Page 2 of 4 Part VI - EVALUATION OF QUALITY ASSURANCE (Cont'd) 3.0 RESULTS OF CPRT EVALUATION OF CPSES CONSTRUCTION QA REPORTED IN THE CER 3.1 Results Presented in the CER During its investigations, the CPRT examined the current and historical TU Electric, Brown & Root, and subcontractor QA programs for cont,truction of CPSES under each of the 18 criteria of 10CFR50, Appendix B (except Criterion III, which pertains to Design Control). These results are described in detail in the CER.
In each case, the CPRT has determined that the current CPSES construction QA program effectively implements 10CFR50, Appendix B.
The CPRT evaluation of the adequacy of the historical QA program for construction of CPSES concluded, in general, that implementation of the l
l historical QA program was effective and satisfied the applicable requirements of 1
13CFR50, Appendix B.
However, the CPRT did identify weaknesses in limited areas of the historical QA program related to Criteria I, II, V, VII, X, XV and XVIII.
The major areas of concern in the historical QA prograa under these Criteria l
involved instances of inadequate construction and inspection procedures as related to Criteria V and'X requirements and the lack of timely identification and correction of problems with Bahnson as related to Criterion VII. A TU l
Electric audit program that was not always effective in the detection and l
resolution of problems and a lack of a well-coordinated QA surveillance program to complement the audit program contributed to these problems.
In addition, until 1986 TU Electric did not have a formal method of regularly assessing the l
adequacy of their QA program, as required by Criterion II.
It is the conclusion of the CPRT that the primary cause of the problems in these limited areas was a lack of nuclear and quality assurance experience on the part of management and supervisory personnel.
Appropriate corrective action to resolve the QA program related findings noted by the CPRT has been or is being taken. The corrective actions include a substantial increase in the level of nuclear and quality assurance experience for TU Electric management and supervisory personnel, establishment of an I
effective method of annually evaluating the adequacy of the TU Electric QA program, improvements to increase the effectiveness of the TU Electric audit and QA surveillance programs, improvements in the methods used to monitor and control the performance of site subcontractors, and the termination of Bahnson (the heating ventilating, and air conditioning construction contractor) from further work at CPSES. TU Electric has also implemented a Specification, Procedure, and Drawing Update (SPADU) program.
Under this program, installation and inspection procedures have been reviewed for technical accuracy, clarity, and inclusion of appropriate elements. This program provides assurance that CPSES procedures are nor adequate to provide the required construction quality.
In addition, the areas of construction that were related to these findings are being reinspected and/or re evaluated and, where required, corrected.
In particular, a program for the reinspection, evaluation, and correction of problems in Bahnson work is being implemented.
In light of the extensive corrective actions taken in response to the individual findings, the CPRT concluded in the CER that only one additional corrective action that might impact existing hardware was warranted by the findings when considered collectively.
This recommendation for corrective action addressed the lack of a
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documented process for addressing the need to backfit new or modified inspection requirements to previously accepted hardware.
In summary, CPRT determined that appropriate corrective action, including action to prevent recurrence, has been identified, has been implemen*ed for programmatic improvements, and is underway to resolve hardware problems stemming from weaknesses in the historical QA program for construction of CPSES.
Therefore, the CPRT concluded in the CER that the current QA program for construction of CPSES effectively implements 10CFR50, Appendix B.
This conclusion was drawn subject to confirmation for certain procurement-related requirements to be addressed in ISAP VII.a.9.
3.2 Effect on CER Results of ISAP VII.a.9 Investigations The CPRT conclusions presented in the CER with respect to Criteria IV, VII and VIII did not reflect the final results of ISAP VII.a.9 relating to CPSES procurement programs.
In addition, some preliminary data from ISAP VII.a.9 was utilized in evaluating compliance of the CPSES program with Criterion XIII.
The final results of ISAP VII.a.9 did not alter the CER evaluation of the CPSES QA program under Criteria IV, VIII and XIII. The current program was also determined to address Criterion VII adequately.
An additional recommendation was made under Criterion VII, however, to verify that activities relating to procurement of electrical equipment, such as engineering reviewr, vendor
(~~}
surveillance, and receipt inspections, are conducted in sufficient depth to
( _j prevent recurrence of problems noted in ISAP VII.a.9 with respect to procured electrical equipment.
The Project and CPRT have diacassed this recommendation and have reached verbal agreement on a plan to address this matter.
3.3 Summary of Construction QA Results Presented in the CER and in ISAP VII.a.9 The CPRT concluded in the CER that, with specific, identified exceptions, the historical CPSES construction QA program was adequate.
For each exception, corrective action has been taken to prevent recurrence of problems and is being taken to ensure hardware adequacy. The Results Report for ISAP VII.a.9 did not alter the CER conclusions and reaches a conclusion for Criterion VII, subject to the identified corrective action. The CPRT concludes that the current CPSES construction QA program (including those requirements applicable to procurement activities) effectively implements 10CFR50, Appendix B.
4.0 OVERALL CONCLUSIONS WITH RESPECT TO THE CPSES QA PROCRAM As discussed in Section 2.0, the CPSES design control program was adequate for design validation, is adequate for the completion of design reconciliation, meets the requirements of ANSI N45.2.11, adequately addresses the potential weaknesses identified for the historical design control program, and contains all the elements that would be required for transition to an operating plant design control program.
Thus, the design control program for CPSES meets the f-~s applicable requirements of 10CFR50, Appendix B.
As discussed in Section 3.0,
(
,)
the current construction QA program (including procurement provisions) is also adequate.
In particular, appropriate corrective action to prevent recurrence has been implemented for the specific problems noted in the historical QA L_
R;vicisn: O Page 4 of 4 Part VI - EVAIVATION OF QUALITY ASSURANCE (Cont'd) 1 program for construction and is being developed for the noted concern relating to the procurement of electrical equipment.
In addition, the j
areas of construction that were possibly affected by these weaknesses prior to j
their correction are being reinspected or re-evaluated and, if necessary, l
corrected, where required by CPRT recommendations for corrective action.
Based on these results and the scope of the QA program evaluation reported in the CER, the CPRT concludes that the CPSES QA progran adequately addresses each of the criteria of 10CFR50, Appendix B.
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Part VII - EVALUATION OF TESTING l
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1.0 INTRODUCTION
1.1 Jackcround The Comanche Peak Response Team (CPRT) investigated the CPSES testing program during implementation of a number of Issue-Specific Action Plans (ISAPs). A collective evaluation of the results of these investigations was presented in the Collective Evaluation Report (CER).
In addition, the CPRT has examined available information concerning the CPSES pre-start test program.
This test program contains all the testing to be performed prior to commercial operation, including retesting and any additional testing associated with systems and components that were affected by the Corrective Action Program (CAP) in such a way as to invalidate prior testing or require additional testing.
1.2 Purpose The purpose of Part VII is to summarize the results of the CPRT evaluation of the CPSES testing program that was presented in the CER; to summarize the CPSES program for testing of items modified or installed as a result of the CAP or otherwise requiring testing; and to present the overall CPRT conclusions with respect to the CPSES testing program.
1.3 Ornanization of Part VII 7;
The remainder of this part is organized into three sections.
Section 2.0
(
)
summarizes the results of the CPRT evaluation of the CPSES testing program which was presented in the CER.
Section 3.0 describes the CPSES pre-start test program, which includes the evaluation and testing of systems and components modified or installed as a result of the CAP design validation and the Post Construction Hardware Validation Program (PCHVP) elements or otherwise requiring testing.
Section 4.0 presents the CPRT overall conclusions with respect to whether the CPSES testing program will assure that the as-built plant meets the safety-related requirements of the validated design that are amenable to startup and preoperational testing.
2.0
SUMMARY
OF CPRT EVALUATION OF TESTING PRESENTED IN THE CER The ISAP investigations performed by the CPRT indicated that the CPSES test program and other activities under the jurisdiction of the TU Electric Startup organization have generally been adequate and properly implemented.
For example:
In ISAP III.a.1, the CPRT found that the objectives of the Preoperational Test Program are being satisfied and that Test Deficiency Reports and Test Procedure Deviations were being properly dispositioned by the Joint Test Group.
In ISAP III.a.2, the CPRT determined that the CPSES procedures contain appropriate requirements for approval of the results of deferred
[- }
preoperational tests, v
In ISAP III.a.3, the CPRT determined that CPSES procedures are adequate to ensure compliance with plant Technical Specifications in cases where preoperational tests are deferred until after fuel load.
Rcvicicn: 0 Pcg2 2 of 3 Part VII - EVALUATION OF TESTING (Cont'd)
In ISAP III.a.4, the CPRT determined that measuring and test equipment used during testing is being properly controlled and traceability of this equipment is being maintained.
j l
In ISAP III.a.5, the CPRT determined that there is reasonable assurance l
that preoperational test data are being correctly evaluated.
The problems examined or identified by the CPRT were relatively few in number and generally insignificant.
In only a few cases was there any effect on the l
adequacy of any hardware or testing performed at CPSES, and theFe items were corrected.
In ISAP III.b, the CPRT concluded that there is reasonable assurance that preoperational testing commitments made in the FSAR are being met.
In ISAP III.c, the CPRT concluded that there is reasonable assurance that the manner in which Startup support personnel performed the initial conditions verifications for prerequisite test instructions was adequate to assure proper test conditions.
In ISAP III.d, the CPRT concluded that testing engineers and other personnel are provided with adequate notice of design change documents affecting testing, and that testing required after design changes is being performed after design changes are made.
In ISAP III.d and ISAP VII.c, the CPRT determined that appropriate tests were being conducted for design changes, and that Startup procedures contained appropriate provisions to assure proper orientation and restoration of components relative to flow direction.
The information discussed above, together with relevant findings from other ISAPs and ISAP VII.c, was collectively evaluated in the CER to determine whether the results of the various CPRT investigations, when considered tagether, indicate a need for corrective action that was not apparent from a review of the findings individually.
During the collective evaluation of the problems examined during its reviews, no pattern or trend of significant problems was identified by the CPRT in the area of testing.
Problems identified were limited in scope and did not have implications for activities in other areas.
The CPRT also found that appropriate corrective action for the problems l
identified in the area of testing and other activities under the jurisdiction of Startup had been or is being taken, including action to prevent recurrence of problems.
Thus, no further action is required in response to these problems.
In summary, eight ISAPs were initiated by the CPRT that related to various parts of the CPSES testing program.
In each case, it was determined that the CPSES testing program was adequate and was being properly implemented.
Although findings related to activities under the jurisdiction of Startup were identified in other ISAPs, these findings were limited in nature and had unrelated root causes.
Furthermore, corrective action was taken for each of the findings, including action to prevent recurrence. Therefore, the CPRT concludes that the CPSES testing program and other activities under the jurisdiction of Startup are generally adequate and that no additional corrective action is necessary beyond that which has been taken for the individual findings identified by the CPRT.
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,Pega 3 of 3 Part VII ' -; EVAWATION OF TESTING -.(Cont'd)-
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3.0 DESCRIPTION
OF TESTING OF VALIDATED HARDWARE AND DESIGN As discussed in Section 3.0'of Part V,'some hardware is being modified and new hardware is being installed as a result of.the CAP design and hardware
-validation process. These activities have the potential to affect the validity
=
of the results of construction,-prerequisite and preoperational tests previously.
conducted.. Also, new hardware has been added.for which new testing is required.
In addition, other factors such as storage conditions, maintenance, and construction or operations activities may have invalidated previous test results.
In order to determine whether existing tests shoul'd be reperformed, the Project is first evaluating existing test criteria and is upgrading these criteria to conform to the validated design. Prior test results are'then reviewed in light of the criteria changes to determine whether additional testing is required to demonstrate that the validated plant systems and components meet the criteria.
In each case, either retests are performed or a written justification is prepared explaining why no further testing is required.- Each justification will be based on a thorough review of design changes, maintenance, layup environment, and construction or operation activities that could have invalidated test results. The final scope of testing must be approved by the Station operations Review Committee upon recommendation of the Joint Test Group.
As a separate check of the scope of. pre start testing, a review is being.
performed under the Engineering Functional Evaluation (EFE) to assure that those O-design parameters-generated or validated in the CAP that are applicable to the "vertical slice" being investigated by EFE have been adequately used in'the CPSES testing program.
As discussed in Section 2.0 above, the CPRT has concluded that the CPSES testing program is adequate. This program will be utilized in the performance of any further testing of hardware modified as a result of the design and construction reconciliation process or otherwise requiring testing.
4.0 CPRT OVERALL CONCLUSIONS REGARDING THE CPSES TESTING PROGRAM The CPRT has evaluated the CPSES testing program and has determined that this program is capable of assuring that the as-built plant meets the safety related requirements of~the validated design that are amenable to startup and preoperational testing.
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1.0 T
CONCwSIONS based upon the results-of the investigative and overview activities described in. Parts II through VII, the CPRT concludes that:
The current programs for design, construction, testing, and assurance of quality of CPSES are adequate, and problems arising from weaknesses in the historical programs have been identified and appropriate-corrective action has been defined; The Corrective Action-Program (CAP) provides an adequate means of validating the design and hardware for CPSES, and the CPSES QA-Program, the Technical Audit Program, the Engineering Functional Evaluation, and other audit and overview programs provide adequate means for assuring acceptable implementation of the CAP; and The corrective actions encompassed by the' CAP provide reasonable l
assurance that the structures, systems, and components at CPSES will be capable of performing their intended safety functions.
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