ML20202J676
| ML20202J676 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/19/1985 |
| From: | Ross G EVALUATION RESEARCH CORP. |
| To: | |
| Shared Package | |
| ML20202J051 | List:
|
| References | |
| CPP-014, CPP-14, NUDOCS 8607170126 | |
| Download: ML20202J676 (15) | |
Text
s Page 1 of 10 4
EVALUATION RESEARCH CORPORATION COWROL_ D CO?Y CONTROL N0_ DF-ool COMANCHE PEAK RESPONSE TEAM PROCEDURE NO: CPP-014 REVISION: 2 EFFECTIVE DATE: 12/19/85 FOR.
COLLECTIVE EVALUATION OF CONSTRUCTION QA/QC PROGRAM o
O PREPARED BY: MM DATE: /z//6 f$~
APPR0vED By: 8b,d DATE: /a -//- F ON-SITE Qi REPRESENTATIVE APPROVED BY: , DATE: i2.!/6 Sf Of/QC REVIEW TEAM LEADER / /
8607170126 860711 PDR ADOCK 05000445 A PDR
o a
CPP-014 s Rev. 2 1.0 PURPOSE V[ \ -
This procedure describes the methodology employed by QA/QC Review Team personnel in the Collective Evaluation of the CPSES Construction QA/QC program and how interfaces are accomplished with other review teams.
2.0 APPLICABILITY The scope of thfs procedure is to perform a collective evaluation of the overall edequacy of the CPSES Construction QA/QC program and its implementation based upon the results of the CPRT Issue Specific Action Plans and input from the CPRT Design Adequacy Program and other applicable external sources and investigatory programs. The evaluation will assess the effectiveness of the QA/QC Program in assuring the quality of construction at CPSES and will identify any necessary improvements 2o the QA/QC Program ,
related to future CPSES construction activities and to CPSES plant operations. ,
3.0 REFERENCES
d
. 3.1 CPRT Program Plan
) 3.2 CPP-004, " Project Working Files."
3.3 CPP-013. " Collective Evaluation of the Quality of Construction."
3.4 CPP-018, "QA/QC Interface with the Design Adequacy Program."
3.5 PAG-02 " Guide on Assembly of CPRT Program Central and Working Files."
3.6 DAP Attachment B & C Interface Forms 4.0 GENERAL 4.1 QA/QC Responsibilities 4.1.1 The Review Team Leader (RTL) has the overall responsibility for the collective evaluation of the CPSES QA/QC Program, interfaces with other Team Leaders and final report approval.
The RTL maintains close coordination and communications I with other RTL's on matters that impact or relate to the QA/QC Programmatic Issues. The ERC Personnel
/~'N involved in the implementation of this instruction l (m-) shall utilize the information developed by other Action Plans to the maximum extent possible.
2
s CPP-014
. Rev. 2
,m
( ) 4.1.2 Supervisor of Programmatic Issues
%J The Supervisor of Programmatic Issues is responsible for the completion of evaluation activities described in this procedure. He is assisted by Quality Engineers and other technically qualified personnel who will be assigned responsibilities for individual activities of this procedure including generation of supportive checklists and/or supplemental instructions as may be required.
He is also responsible for the overall collective evaluation of QA/QC Programmatic and Hardware concerns.
Coordination is maintained with other teams for issues relating to QA/QC Programmatic and Hardware issues.
Form CPP-014 Attachment 6.5, is used to transmit design concerns that are found during collective evaluation to the QA/QC Interface Coordinator, and to other responsible personnel. Inputs on QA/QC Programmatic and Hardware issues are received from the Design Adequacy Program on DAP, Forms B & C, Reference 3.6, via the QA/QC Interface Coordinator Reference 3.4.
4.2 Policy
/""g 4.2.1 Personnel Qualification Requirements V Personnel participating in the implementation of this procedure shall be qualified in accordance with paragraph III.H. of the CPRT Program Plan.
l 4.2.2 Procedures Development and implementation of this procedure shall be conducted in accordance with the CPRT Program Plan and the ERC Management Program Plan.
4.3 Procedure Overview 4.3.1 The collective evaluation of the CPSES Construction QA/QC program is an integral part of the " Quality of Construction and QA/QC Adequacy Plan" and will take into account input from evaluation reports of the following plans and programs:
- a. Category 1 QA/QC ISAPS These are the Plans for QA/QC issues identified by external sources and address both programmatic and hardware issues.
O l
V 3
CPP-014
- Rev. 2
- b. Category 2 QA/QC ISAP
[ )S L.
This is the plan for self-initiated evaluation of all construction work activities at CPSES and addreuses both hardware reinspections and hardware documentation reviews.
- c. Other CPRT ISAPS These are the plans for other issues with potential QA/QC implications that were established to address Electrical Testing Program, Civil / Structural Mechanical / Misc and Design Adequacy identified concerns.
- d. Other Investigative Programs This includes other TUGC0 investigatory programs whose results have been verified by the CPRT.
. 4.3.2 Reviews and Evaluations All External Source Documentation, Attachment 6.1, is
/ reviewed for CPSES construction QA/QC Program concerns.
(_,T/ Reviews and evaluations will be conducted to verify the following:
- a. External source issues regarding the QA/QC Program are addressed and resolved
- b. Adequacy of the QA/QC Program during Construction
- c. Root cause of each found safety-significant deficiency (or trend of non-safety significant hardware deviations) and analyze the generic implications of each root cause in order to determine the extent of any additional hardware that might be deficient for the same programmatic reasons and to determine if changes need to be made in ongoing programs to prevent recurrence in the future,
- d. The need to correct QA/QC program problems which might impact the remaining Unit 2 construction and other CPSES ongoing programs, b
v 4
CPP-014
- Rev. 2 ;
,r-(
NOTE: Concerns which have been raised and
'\- subsequently closed out by the External i
Source that raised the issue will be considered for information when conducting root cause and generic implication analyses.
4.3.3 Appendix "P" of SSER-11 is also utilized to identify concerns. Each concern is reviewed and entered on the matrix format. They are categorized in the same manner as described in 4.3.2 of this procedure. Again, all concerns are reviewed even though they may be closed by NRC Inspection Reports. The developed matrices will track the allegation back to the source document.
4.3.4 A report documenting the scope of the evaluation and conclusions reached regarding the QA/QC program adequacy will be issued to complete the requirements of this procedure. The key questions to be answered as a -
result of the implementation or this procedure are:
- a. Has implementation of the QA/QC program been adequate to correct the identified problems
. and prevent them from occurring again?
- b. Was the QA/QC program as implemented adequate
(~'g to ensure the correctness of the hardware and
( ,/ safety of the plant?
5.0 PROCEDURE 5.1 General This procedure will be implemented in two phases. During j Phase 1 a matrix system will be developed which will allow QA/QC Program identified concerns, existing ISAP/DSAP coverage.
of these concerns and criteria element of 10CFR50, Appendix B l relationships to be evaluated against each other for potential anomolies in addressing all QA/QC Program areas and or t identified concerns. Data input for the matrices will result from review of external source documents, existing ISAP/DSAP scopes and 10CFR50, Appendix B criteria. The matrix system developed in this phase will become the tracking vehicle for concern coverage evaluation during Phase II.
Phase II consists of the collection, review, and evaluation of all ISAP Results Reports and other applicable investigatory programs to determine the overall adequacy of the Construction QA/QC program. Additional areas of program or hardware which are identified as areas of concern shall be further evaluated
_ and the results of these evaluations included in the final conclusions.
(s}
5
CPP-014 ,
Rev. 2 5.2 Phase I - Development and Evaluation of Matrix Information.
( )
5.2.1 Identify the major QA/QC program elements of each j criterion of 10CFR50, Appendix B. They should be '
representative of the major aspects of that criterion.
The elements selected for each Criterion will be used to develop matrices for the review of all external source documents and the review of existing ISAP's.
Listings of external sources and ISAP's are shown in Attachments 6.1 and 6.2 respectively.
5.2.2 Review each document of attachment 6.1 and identify QA/QC program issues. The related Appendix B criteria association shall be indicated on the matrix with each issue.
5.2.3 Review each Action Plan of Attachment 6.2 and identify .
its scope applicability to the specific QA/QC Program issue on the matrix.
5.2.4 Cross compare the matrix information to evaluate if
. all QA/QC program issues have been covered by existing action plans.
gs 5.2.5 Advise the QA/QC RTL of the results of the cross
(,) comparison of 5.2.4 above, indicating action plan non coverage.
5.2.6 Matrices are living documents the elements of which will be updated and authenticated throughout the completion of Phase II. All new inputs or requirements will be reviewed for inclusion and updating of the matrices system. Working copies will be issued to the I/C's and RTL's for assistance in completing their action plans and to form a basis for interfacing activities and communication between I/C's, RTL's and Collective Evaluation personnel.
5.2.7 The Category 1 Programmatic Issues Supervisor, with approval of the QA/QC RTL shall review the issues relating to QA/QC from external sources which fall into the non coverage area of 5.2.5 above and determine the necessity for further evaluation of the issues. (Note:
The primary reason that further evaluation would not be required would be that information is available which clearly shows the issue to be invalid.)
- a. Where further evaluation is required, it shall be specified in a new Issue-Specific Action Plan or in a revision to an existing 1
() Issue-Specific Action Plan.
l 6 I . . _ _ _ _ _ _ _
CPP-014 Rev. 2
() b. Where no further evaluation is required, justification for this decision shall be fully documented.
Note: During implementation of Reviews / Evaluations Associated with 5.2.2, 5.2.3 & 5.2.4 above communication with other coordinators, review team leaders, authors and/or persons knowledgeable of the documents under review should be conducted as frequently as is required in order to perform a complete review / evaluation.
5.2.7 Phase I results shall be documented to provide input for the " Adequacy of QA/QC Program Collective Evaluation Results Report" to be generated upon completion of this instruction.
5.2.8 Project Work Files The project work files are initiated and maintained during the collective evaluation process as outlined in
. the Guide for Working Files, References 3.2 and 3.5.
These files should reflect the records and documentation required to accomplish the Collective Evaluation Tasks. (Note: If conflicts occur between
()N (s_ references 3.2 and 3.5, 3.5 shall take preference.)
5.3 Phase II - Review / evaluation of Issue-Specific Plan Results and other Investigative Program Results.
Implementation of this phase is dependent upon completion of other Issue-Specific Action Plans and availability of each Plan's Results Report as issued by review team leaders.
5.3.1 Obtain Issue-Specific Action Plan Results as they are issued (a listing is published as changes are made to Results Reports issued). Identify and document the l other investigative program results which are to be utilized in the overall collective evaluation.
5.3.2 Collect and review the results from applicable action plan (s) and other investigative programs which apply to the Criterion elements and concerns (indicated on
! matrices) and determine the following:
, a. Do the results reports:
l Identify deficiencies and corrective actions required?
7
CPP-014
. Rev. 2
-('~N Identify the root cause and generic N ,) implications of identified deficiencies?
Identify the safety significance of identified deficiencies?
Identify actions to prevent recurrence?
- b. Do the inter-relationships of the Action Plan Report results indicate additional problems or potential problems within the Criterion or with other Criteria?
- c. Do the Action Plan Reports, collectively or individually, indicate problems or potential problems in areas of the QA/QC program not originally identified as problem areas and/or not included within the scope of the Review Team evaluations.
. During execution of the above activities the issue coordinator (s) should maintain open lines of communication with other Review Team Leaders and Action Plan Coordinators necessary to collect additional Ir"') information required to complete the evaluation of each criterion. Such communication and their results shall become part of working fi3r documentation if they provide basis for evaluatser.3 arrived at as a result of the implementation of this procedure. The document transmittal form (Attachment 6.3) is to be used as required.
The QA/QC Review Team will review CPRT Action Plans Results Reports from other review teams to ensure that any potential concerns relating to construction QA/QC have been identified and recorded in the QA/QC reports.
5.3.3 If the evaluation in 5.3.2.a above indicates less than complete results information or 5.3.2.b and 5.3.2.c indicate additional or potential problem areas, the Issue Coordinator, with the approval of the QA/QC Review Team Leader, shall determine the necessity for further evaluation of the problem areas.
- a. Where further evaluation is required, it shall be specified in a new Issue-Specific Action Plan or in a revision to an existing Issue-Specific Action Plan.
[)
v 8
---_r- _ _ _ . - -
CPP-014 Rev. 2
[)
\- '
- b. Where no further evaluation is required, justification for this decision shall be fully documented by the Issue Coordinator.
Note: The primary reason that further evaluation would not be required would be that information is available which clearly shows the issue to be invalid.
5.3.4 When all Action Plan Results Reports and other program results have b,een evaluated per 5.3.1 through 5.3.3, collectively evaluate the results of the Criterion evaluations performed and determine the following:
- a. Is the current implemented Construction QA/QC program in compl'ance with 10CFR50, Appendix B, Criterion II? If not, specifically identify areas of QA/QC program inadequacy along with recommendatioas for improvement, particularly as they apply to Unit 2 and the Operations QA Program.
- b. Are additional hardware and/or generic issue evaluations required? If so,
(""N notify applicable Review Team Leaders, .
(_,) develop additional Action Plans as '
required, and determine, from applicable Review Team Leader assessments, the safety significance of the issues.
5.3.5 QC Inspection has been identified as a particular area of concern for the CPSES QA/QC program. A specific evaluation of the QC Inspection program which includes inspector qualifications; inspector training; inspection procedures, instructions, checklists; inspection results; and inspection records shall be conducted utilizing the results and conclusions gathered in paragraphs 5.3.1 through 5.3.4 above. This evaluation shall be included as part of the final report required by paragraph 5.3.6 below.
5.3.6 A final report shall be prepared (" Adequacy of QA/QC Program Collective Evaluation Results Report) to address the following areas:
- a. Identification of root cause(s) and generic implications of program deficiencies,
- b. The impact on the hardware and safety of
,,,s Units I and 2.
9
CPP-014
- Rev. 2 O c. Corrective action required including recommendations to preclude similar occurrences on the remaining work on Unit 2 and on the Operations QA/QC program.
- d. The adequacy of the CPSES construction QA/QC Program including any improvements related to future CPSES construction and plant operations,
- e. Justification for all conclusions.
6.0 ATTACHMENTS 6.1 External Source Document List 6.2 CPRT Action Plan Review List 6.3 CPRT Data Collection Form O
1 l
i i
O 10
Attacharnt 6.1 f a
CPP-014 ;
Rev. 2 3 Page 1 of 1 I EXTERNAL SOURCE DOCUMENT LIST [
i
- 1. NRC-TRT Evaluation Letters [
Dated September 18, 1984 !
Dated November 29, 1984 Dated January 8, 1985
- 2. NRC Safety Evaluation Report (NUREG 0797) Supplements SSER 7 SSER 8 SSER 9 SSER 10
. SSER 11
- 3. Other Reports / Documents NRC SIT Report - February 15, 1983 NRC CAT Report - April 11, 1983 NRC Special Review Team Report - April 1984 NRC Region IV Inspection Reports CYGNA Independent Assessment Program Report j Concerns associated with matters in contention before the ASLB
, for CPSES 1
Technical Allegations raised in the NRC HITS Docket Lobbin Report - February 4, 1982 MAC Report - May 17, 1978 i
Teledyne Report - February 21, 1985 O
Attechmsnt 6.2 CPP-014 Rev. 2
-, Page 1 of 3
?
\ CPRT ACTION PLAN REVIEW LIST 1.0 Category 1 ISAP's Programmatic ISAP's I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Tests VII.a.1 Material Traceability VII.a.2 Nonconformance and corrective action systems VII.a.3 Document Control VII.a.4 Audit Program and Auditor Qualification VII.a.5 Management Assessment
. VII.a.6 Exit Interviews VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation Hardware ISAP's VII.b.1 Onsite Fabrication VII.b.2 Valve Disassembly VII.b.3 Pipe Support Inspections i
VII.b.4 Hilti Anchor Bolts Installation VII.b.5 Electrical Raceway Support Inspections 2.0 Category 2 ISAP VII.c Construction Reinspection / Documentation Review Plan O
Attachmint 6.2
, CPP-014 Rev. 2
. (-~y 3.0 Other ISAP's/DSAP's I.a.1 Heat Shrinkable Sleeves I a.2 Inspection Reports on Butt Splices I.a.3 Butt Splice Qualification I.a.4 Drawings / Terminations I.a.5 NCRs on Amp Terminal Lugs I.b.1 Flex / Flex Separation I.b.2 Flex / Cable Separation I.b.3 Conduit / Cable Tray Separation I.b.4 Barrier Removal I.c Ccnduit Supports II.a Reinforcing Steel in Cavity
., II.b Concrete Compressive Strength
\ ,)
II.c Air Gap II.d Control Room Ceiling II.e Rebar in Fuel Handling Building III.a.1 HFT Date Packages III.a.2 JTG Approval of Test Data III.a.3 Tech Specs for Deferred Tests III.a.4 Traceability of Test Instruments III.b Conduct of CILRT III.c Prerequisite Testing III.d Preoperational IV.a Surveillance Program for Coatings V.a Skewed Welds in NF Supports
['l V.b Shortening of Anchor Bolts O
V.c Piping Between Buildings 2
4-Attachmant 6.2 4 .
CPP-014 Rev. 2
+
() 3.0 Other ISAP's/DSAP's (Cont'd)
V.d Plug Welds V.e Installation of Main Steam Piping VI.a Insulation / Shield Wall Gap VI.b Polar Crane Shims VIII Civil / Structural Discipline TASK VIII.a Cable Tray / Con Supp/ Critical Parameters TASK VIII.b Cable Tray / Con Supp/ Population Identification
- TASK VIII.c Cable Tray / Con Supp/ Determination of Gov Loads TASK VIII.d Cable Tray / Conduit Supports / Testing TASK VIII.e Cable Tray / Con Supp/ Comp & Sys Behavior /Modeling
. TASK VIII.f Cable Tray / Conduit Supports / System Analysis 1
TASK VIII.g Component Design Evaluation IX Piping and Supports X Mechanical Systems and Components XI Electrical, Instrumentation & Controls i
i k
1 4
O l
3
Attachatnt 6.3
- CPP-014 Rev.-2 Page 1 of 1 O
i CPRT CA/0C DATA COLLECTION FORM TO: TROM:
SUBJECT:
DATE:
REFERENCED DOCWJENT/S:
TITLE:
REV. DATE.
ACTION REQUESTED:
N
RESPONSE
RESPONSE RECEIVED: DATE CLOSED:
CPP-01*.1, REVISIO.4 0
_