ML20210B207
| ML20210B207 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/30/1986 |
| From: | Cragin J TELEDYNE ENGINEERING SERVICES |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20209E570 | List:
|
| References | |
| FOIA-86-657 6410-40, NUDOCS 8602030132 | |
| Download: ML20210B207 (76) | |
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- WM ENGNEERING SSWICES 130 SECONO AVENUE WALTHAM, MASSACHUSETT5 02254 (41D 800 3350 TWX17105 324 7500 January 30, 1986 6410-40 Mr. Vincent S. Noonan Project Director Comanche Pe'ak Project U.S. NRC M/S P-234 7920 Norfolk Avenue Bethesda, MD 20014 *
Dear Mr. Noonan:
Enclosed are some early inputs into the next revision of the SSER on the Comanche Peak Program Plan.
Due to late receipt of Revision 3 of the Program Plan at TES on .
1/29/86 and distribution to our internal staff this morning, the enclosures do not fully reflect our evaluation of the CPRT document.
More input will be provided when I attend the TRT meeting on Monday, February 3,1986.
Very truly yours.
TELEDYNE ENGINEERING SERVICES Q m .7 s
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J5hinQ.Cragin,P.E.
' Manager, Project Administration
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III SECTION 2.3 1/29/86 b
1-2.3.1 Steam-Generator Restraints DD AFT .
2.3.1.1 _ Introduction The overall design adequacy of both upper and lower steam-generator lateral appropriate loading conditions. restraints is to .be reviewed for all This review is due to the TRT issue concerning the improper shortening of anchor bolts generator lateral supports. in the steam-the steam-generator The TRT was informed that anchor bolts in lengths less than thatuppershown lateral on support beams were installed to authorization. the design drawings without proper This was apparently the result of the bolts being cut due to either the hole of the anchor device being e rfilled s or with d b i the threaded portion of the bolt had concrete mix stuck to it .
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The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation p .
The TRT was told that ultrasonic testing of these types was not of bolts a procedural requirement; however, TUEC was unable to provide a installation records for TRT review.
The TRT concludes that such unauthorized bolt cutting and lack of installation inspection s records a violation of QA procedures and Criterion XVII in Appendix 8 of 10CFR50.
Since the support beams are essential to provide lateral restraint for the steam generator during a LOCA or seismic event, adequate anchoring capability of the bolts has safety significance ,
as a result, appropriate measures are needed to ensure with conformance General Design Criterion 1 of 10CFR50.
l 2.3.1.2 CPRT Approach measures to be taken to ensure thatItem Vb of the CPRT Program 1
the anchor bolts in the steam-generator upper support beams meet the appropriate design requirem ,
which includes a review of similar installations to de e L
. _ _ . . . . . a TION 2.3 -- h8 issue pertains to other designs. This is addressed in 2.4.2 of Sec-tion IV of this report. In addition to this specific issue of the improper shortening of anchor bolts in the steam-generator upper lateral supports, the design of both upper and lower steam-generator lateral supports is addressed separately under Discipline Specific Action Plan (05AP) VIII, which is the Civil / Structural Design Adequacy Plan (DAP).
'k The design of all components of the upper and lower steam-generator lateral supports, which include the beams, beam anchorage to the concrete walls and the concrete wall, will' be reviewed for all load combinations. This design review includes a review of the -
development of steam-generator-to-beam forces, the validation of the appropriate load combination, evaluation of force and moment resultants on the beam wall and anchorage as a function of cracked and uncracked concrete properties, review of concrete wall and steel-beam design, and the adequacy of the bolt and plate connection..
2.3.1.3 Staff Evaluation The staff's evaluation of this section of the Program Plan is based on a review of Revision 3 of the CPRT Program Plan and Supp1 ment 8 of NUREG-0797, which addresses the specific concern, this particular issue being the improper shortening of the upper-lateral steam-generator-support anchor bolts. The plan goes beyond addressing this specific issue to review the design of both upper and lower steam-generator supports to assure that the FSAR conniitments are met.
- 2.3.1.4 Conclusions The staff concludes that the Program Plan appropriately addresses the issue and is acceptable.
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2.3.2 Design of Seismic Category II Items 2.3.2.1 Introduction ;
This review of the design of Scismic Cat-l egory II items is a result of the allegation that the field run conduit, the drywall ceiling and the lighting installed in the. area above the t control room were classified nonseismic and may fail ouring a seismic _
l event. The design adequacy of Seismic Category II items is to assess to assure that proper consideration was given to governing design criteria.
CPSES General Design Criteria No.19 rcquires
- that safe occupancy of the control room during abnormal conditions Le ,
provided for in its design. The Comanche Peak Steam Electric Station -
(CPSES) control room is in a seismic Category I structure, with carta%
seismic Category II and, nonseismic components located in the ceiling.
j Seismic Category I refers to those systems or components which must l
remain functional in the event of an earthquake. Seismic Category:II.
refers to those systems or components whose continued functioning is not l
required, but whose failure could reduce the functioning of any seismic Category I system or component (as defined in Regulatory Guids 1.29) to an unacceptable level or could result in an incapacitating injury to occupants of the control room. Seismic Category II syster.s or com-ponents are, therefore, designed and constructed so that a Safe. Shutdown Earthquake (SSE) will not cause such failure or injury.
l 2.3.2.2 CPRT Approach In assessing this allegation, the TRT ' reviewed the CPSES nonsafety-related conduit, lighting fixtures, and the sus-pended ceilings installed in the control room. Three types of suspended ceiling exist in the control room: drywall, louvered and acoustical.
Item II.d of the CPRT Program Plan contains a complete description of the actions taken to assess this allegation, along with assessing the
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design adequacy of Seismic C'ategory II items, in general, to assure that the conditions identified by the allegation are not applicable to other
, Category II and nonseismic stru'cture systems an' components d at CPSES.
The significance of Category II and nonseismic items is identified in Regulatory Guide 1.29, which states that portions of structures, systemt, or components whose continued " function is not required but whose failure could reduce the functioning of any plant feature to an unacceptable safety level should be designed and con-structed so that the SSE would not cause such failure. It is therefore the intent of the CPRT Program to assure that, in fact, the failure of '
non-Category I items will not cause damage to safety-related systems.
To achieve this, the CPRT is to conduct a third-party design verifica-tion of the Unit I Damage Study Program to address generic implications.
The review and verification of the damage study includes a project review of all architectural features to deter-( mine if there is a potential for seismic interaction with safety-related
! items.
, Any architectural features in Units 1 and 2 which have potential 3 ,
seismic interaction will be either modified or subjected to a damage study assessment. This included a review of all ' resolutions of unacceptable interactions. The third party reviewed procedures, methods for conducting the seismic damage review, along with interfaces between the damage study group and other disciplines. The populations of all non-Category I systems, structures and components which are considered l for seismic interaction with safety-related items, including selection criteria, will be identifed. The third party will review the criteria for evaluation of the consequences of interactions and methods for per-forming the damage study and will perform a comparative damage assess-1 ment in selected rooms to assess the consistency with which interactions are identified. The rooms will be chosen based on functional and phys-ical aspe:ts, importance of components, and balance of types of non-seismic items.
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III 1/29/86 SECTION 2.3 ~5-2.3.2.3 Staff Evaluation '
The staff's evaluation of this section of the Program Plan is based on a review of Revision 3 of the CPRT Program Plan and Supplement 8 of NUREG-0797, which addresses the specific concern, this particular issue being that the Seismic Category II items were not properly designed in the area above the control room. The Program Plan goes beyond the resolution of the specific issue to review the CPSES Unit 1 damage study to assure that the FSAR commitments are met.
2.3.2.4 Conclusion The staff concludes that the Program Plan appropriately addresses the issue and is acceptable.
l 2.3.3 Cable Tray Supports
! 2.3.3.1 Introduction A number of potential design concerns related to the cable tray support design have been raised due to external design reviews. Based on the number of design concerns identified, TUGC0 is performing additional reviews of the cable tray support designs. TUGC0 has retained outside contractors to perform 100% verification of the cable tray support designs (Ebasco and Impell for Unit 1, and EBASCO for Unit 2). These design verifications will be subjected to third-party overview.
2.3.3.2 CPRT Approach The project has developed a program to perfnrm l 100% verification of Unit 1 and Unit 2 cable tray supports. This pro-gram includes: the development of as-built drawings for all cable tray supports; analysis and design review of all cable tray supports to
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criteria that are responsive to External Source design concerns and in compliance with CPSES licensing comitments; testing to verify and/or establish specific component or system behavior characteristics; and hardware modifications as necessary to ensure final acceptability of all supports.
All cable tray supports in both units will be as-built verified for all accessible attributes. For Unit 2, where virtually all attributes are accessible, an as-built drawing will be developed for each support. For Unit 1, a numbe'r of the support design attributes are inaccessible as a result of congestion or the presence of
! fire-protection material. An alternate approach .will therefore be taken in developing the as-built drawings. As-designed drawings will be l developed based on the original Gibbs and Hill design plus all documented design changes. Field walkdowns will then be performed using the as-designed drawings. For all accessible supports and accessible portions of partially inaccessible supports, as-built conditions will be confirmed or differences noted. Final as-built drawings will note items that were inaccessible. The determination of span lengths will also be developed based on field inspections for Unit I supports. The basis for design review of inaccessible items for Units 1 and 2 will be addressed and documented in special studies or evaluation reports.
Two methods of dynamic analysis will be ut'ilized in the analysis / design verification of cable tray supports.
The first method is equivalent static analysis of individual supports, which is consistent with the original d sign criteria. The second method is response spectrum dynamic analysis, which provides an accurate measure of system response.
The design verification of Unit 1 supports will be performed using, as a minimum, actual cable tray fill weights and actual fire-protection-material weights. Unit 2 design verification will be performed using maximum specifiea design cable tray fill '
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weights, and conservative assumptions will be made regarding the weight of the fire-protection material.
For both units, loading combinations and stress limits will be checked in accordance with acceptance criteria, conforming to CPSES licensing comitments. For any support which fails to meet these criteria, design modifications will be prepared that result in acceptable qualification.
A testing program has been defined to support the cable tray !;upport verification effort. The objectives of these tests are to determine actual damping levels to confirm applicability of values used in the design of cable tray systems, to confirm the response of members acting primarily in tension under seismically induced compression loads, and to confirm the analytical methods and supporting design assumptions for complicated load-path geometries.
Modifications will be prepared for all cable tray supports that fail to meet specified acceptance criteria. All sup-ports will be qualified in their existing state, or required modifications will be implemented.
The planned design-verification activities for the cable tray supports will be subjected to third-party overview. In addition, the third party will review the resolution of all external source issues.
2.3.3.3 Staff Evaluation The staff has reviewed the approach and methodology of the TUGC0 expanded cable tray support review, along with the third-party overview. In addition, the staff. has reviewed all l
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identified external source issues, the original project cable tray support design criteria and licensing comitments. -
2.3.3.4 Conclusion The staff concludes that the CPRT Program Plan, as described in Revision 3, will adequately address the issues identified with the cable tray supports and will assure that these supports will meet the licensing criteria. This is predicated on the satisfactory resolution of the following coment on the CTCS subprogram.'
! The staff concern is that the . testing program may generate design and acceptance criteria which do not comply with l FSAR comitments. If licensing commitments may not be met, the proposed l acceptance criteria must be identified for approval by the staff prior to implementation.
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III 1/29/86 SECTION 3.4 DRAFT .
l 3.4 Civil and Structural Design Activities' l
3.4.1 Introduction L
l Due to the number and types of potential concerns iden-tified in the civil / structural area by previous reviews, namely, the shortening of the bolts in the steam-generator upper-lateral supports, design of seismic Category II items, along with the numerous issues l
identified with design of the cable tray, conduit, and their supports, the CPRT has developed three self-initiated evaluations to expand the review to areas which to date have received very limited reviews.
- The purpose is to expand the scope of review in the l Civil / Structural Design Area beyond the scope of the investigation of the issues identified by External. Sources to provide reasonable assur-ance that all safety-significant design deficiencies are identified.
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The Self-Initiated Evaluation of the Civil / Structural Design Activity is l outlined in Item VIII, Civil / Structural Discipline Specific Action Plan, of the CPRT Program P1an. . !
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I 3.4.2 CPRT Approach l
The approach outlined by the CPRT in Item VIII of the Program Plan involves an initial scope which consists of an overall review of the Civil / Structural Design Activity to identify either generic issues or trends in issues with a final scope based on any find-ings.
The initial scope of the Civil / Structural Self-Initiated Evaluation are Concrete Design, Structural Steel Design, HVAC Supports and Other Supports. This includes both a random and an engi-neering sample in the selected areas. HVAC supports are included because of the similar design features and methodology to the cable tray supports. All other areas are included to represent additional civil /
structural design efforts.
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In the area of concrete and structural-steel design, it is the intent of the Program Plan to achieve a comprehensive probing of the overall adequacy of the civil / structural design process. The HVAC-support design has been included within the scope of this self-initiated review because of simildrities with cable-tray supports. Random samples of the populations identified as the "Other Supports", including crane l
supports, mechanical and electrical equipment, mounting, penetration-sleeve anch'orage, missile-resistant doors, hatches and seismic restraints for removable shielding walls, will be selected for review.
l For each of the areas of review, the review process will involve the identification and review of cu.rrent criteria, review of implementing documents, drawings and specifications.
i 3.4.3 Staff Evaluation
'The staff's evaluation of the Self-Initiated Civil /
Structural Design Activities is based on a review of Revision 3 of the CPRT Program Plan, Supplement 8 of NUREG-0797, the CPSES FSAR and audits of the Comanche Peak DAP scope validation process. -
The staff audit . consisted primarily of determining whether there is an auditable trail that permits an independent evalu-ation of the elements upon which homogeneity is based.
3.4.4 Conclusion The staff concludes that the CPRT evaluation plan for l
the Self-Initiated Civil / Structural Design Activity is generally accept-able and does provide a comprehensive probe of the civil / structural i design area. However, the staff notes an apparent weakness in the l availability of information upon which one of the HDA attributes, specifically, Design Considerations, Approach and Methodology.
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Sg.F-INITIATED EVALUATION - D4.s/h / 049MCy ##
.8,/ Pipina and Supports Design Activities fiw...' '
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8, d / Introduction A number of external source issues have been raised in the area of piping analysis and pipe support design. These external source issues have resulted from several sources; the primary sources being the Cygna Independent Assessment Program, the ASLB hearings,'and the NRC staff reviews. As a result, the applicant ha's initiated a special piping and pipe support requalification program which will result in a significant level of reanalysis and reevaluation of the CPSES piping and pipe' support designs. Stone & Webster Engineering Corporation (SWEC) has been i
contracted by the applicant to perform this requalification program. In i addition, a third-party overview of this effort is being conducted by TERA
[ Corporation (TERA) to provide assurance that the ob,fectives of the Design Adequacy Program in the piping and pipe support area are being achieved.
The CPRT Program Plan describes the piping and pipe support program and overview in DSAP IX.
In this section of the SER, we will discuss the staff review and evaluation of the SWEC piping and pipe support requalification program. The staff review and evaluation of the TERA effort is provided in Appendix A. Section 4.5 of this SER.
. 8.5c2,CPRTApproach The scope of the SWEC program for the requalification of piping and pipe supports includes:
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100% of all ASME Code Class 2 and 3 piping larger than 2 inches (large bore), excluding portions within the boundary of Westinghouse Class auxiliary branch line stress problems.
- 100% 'of all ASME Code Class 1, 2, and 3 1arge bore pipe supports, small bor.e piping and pipe supports on a sampling basis, b
all Class 5 piping and pipe supports within ASME Code Class 2 and 3 stress analysis problem boundary, and ,
all Class 5 supports within the ASME Code Class I stress problems.
The CPRT Program Plan in OSAP IX Attachment 2 describes the outline of the SWEC Action Plan.
- following six elements
- The SWEC Acticn Plan consists of the 1.
Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria.
2.
f Verification of As-Built Information.
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Review and Verification of System Design Input, Seismic Acceleration and Fluid Transients.
! 4. Verification of Existing Pipe Support Design Doctments.
- 5. Resolution of Special Technical Concerns.
6.
Reanalysis of Piping Systems and Reevaluation of Pipe Support Designs.
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- (continued)
- 1. Development of Comanche Peak Pipe Stress and Pipe Se+--i, Design Criteria '
The Design criteria and procedures to be used for the pipe stress and support requalification effort by SWEC are in-cluded in procedures listed below:
l Procedure Tit'le CPPP-1 Management Plan for Project Quality, Rev. 2 CPPP-2 Project Organization Ch'rts, a Rev. O CPPP-3 ~ Document Control Procedure, Rev. 2 f CPPP-4 Project Records Management Procedure, Rev.1
'CPPP-5 Field Walk Procedure, Rev. 1 l
l CPPP-6 Pipe Stress / Support Requalification Procedure -
Unit No. 1, Rev. 1 CPPP-7 Design Criteria for Pipe Stress and Pipe Supports, Rev. 1 CPPP-8 Support System Verification Walkdown Procedure, Rev. O CPPP-9 Pipe Stress / Support As-Built Procedure - Unit No. .
2, Rev. 1 CPPP-10 Power Division Procedure for Documented Review of .
Plant Operating Mode Conditions, Rev. O CPPP-11 Administrative Control of Calculations, Rev. O CPPP-12 Cost and Schedule Control Procedure, Rev. O CPPP-13 Site Construction Support Activities, Rev. O I
CPPP-14 Procedure for the Preparation and Control of Project Procedures, Rev. 1 '-
CPPP-15 Small Bore Stress / Support Requalification Pro-cedure
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.3 f Procedure Title PM's Project Memoranda ,
PM-001 Pipe Support Computer Program Usage PM-002 Design Criteria for Pipe Stress and Pipe Supports PM-003 Design Information Request Procedure PM-004 Embedment Plate Evaluation PM-005 Valve Modeling PM-006 Use of Code Case N-411 for CPSES Stress Requalifi-cation These procedures will reflect all CPSES FSAR commitments and the ASE Section III Code of Record (with NRC approved
- changes). In the process of requalification effort, it is
! expected sodie changes to this FSAR and ASME Section III Code 'of Record will be requested by TUGCO'. For example, i
TUGC0 has requested (W.G. Counsil letter dated 11/18/85 to V. Noonan) approval for the use of Code' Case N-411 from the NRC. This request is presently under consideration at the NRC.
l In addition, Procedures CPPP-6 and -7 will include any specific methods required for the proper treatment of all external source issues which are not covered by the standard SWEC procedures and which are unique to the CPSES plant. At this time, Procedures CPPP-6 and -7 do not include all of the methods required for the resolutions of these issues.
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- 2. Verification of As-Built Information Because the as-built data will be used as input for the SWEC requalification effort, it is important to develop confidence in its accuracy.
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SECTION I E _3,g 1/15/86 b 2 %-at[ h The process being used to develop this confidence involves walkdowns performed by SWEC, a reliance on previous work i
by TUGCO, and other work by the CPRT.
The walkdowns by SWEC include:
(a) CPPP-5 Field Walkdown '
(b) CPPP-8 Walkdown (c) SWEC " Stress Reconciliation Walkdown" Previous work by TUGC0 includes their (1) " General Program for As-Built Piping Verification, and (2) " Penetration Schedule".
The activities by CPRT to be considered here include the reinspection performed under the QA/QC Construction i
Adequacy Program, specifically for those samples related to piping and supports. The various as-built walkdowns and reinspections are discussed in the following paragraphs.
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CPPP-5 Walkdown - The purpose of this walkdown by SWEC was to establish confidence in the adequacy of dimensions and functions shown on the as-built drawing to support the initiation of the piping analysis effort. This walkdown is described in SWEC pro-cedure CPPP-5 and the results will be published in a walkdown report. The walkdown procedure provides for the field verifica-tion of random samples of four attributes selected by SWEC. The
! attributes selected include . valve location, pipe support location, pipe support function and support orientation.
I CPPP-8 Walkdown - This as-built walkdown procedure requires a
!- piping and support system walkdown by experienced SWEC engineers who will perform the piping and support reanalysis. The objectives of the walkdown are:
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(1) To determine whether there are technical configuration issues, other than existing technical findings from pre-vious reviews, that should be evaluated relative to the ;
functional behavior of the system, and (2) for experienced SWEC personnel to become familiar with the physical aspects of the design and determine whether addi-tional, or . refinements of, design inputs, guidelines, or procedures are necessary for the pipe stress and supports requalification effort.
The procedure requires the walkdown for a total of 70 stress pro-blems out of the approximately 360 which are within the scope of the SWEC requalification effort.
SWEC Stress Reconciliation Walkdown - This, as in other nuclear plants, will be performed by pipe stress analysts when the piping st'ress analyses are completed. Examples of the attributes to be l
inspected during this walkdown include gaps and interferences.
l TUGC0 General Program for As-Built Piping Verification - These '
represent the walkdowns performed by TUGC0 to satisfy NRC IE t Bulletin 79-14. The TUGC0 procedures issued included CP-QP'-11.3, a Rev. 6, QI-QP-11.13-1, Rev. 8. CP-EI-4.5-1, Rev. 9 and TNE-DC 1, Rev. O.
l- Penetration Schedule - The penetration schedule is a detailed l computer listing describing all of the penetrations in the plant.
l The schedule lists the type of sealant, type of penetration, j openings and a number of other parameters. The stress analyst can obtain all required information related to peiletrations from this document.
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- 3. Review and Verification of Systems Design Input. Seismic Acceleration and Fluid Transients SWEC will review all drawings and specifications for systems within their scope. The specifications will be reviewed to assure compliance with licensing commitments and that all operating modes and conditions are identified appropriately. Existing fluid transient loads will be reviewed and, if required, new loadings generated. SWEC Procedure CPPP-10 describing the operating conditions for the plant has been prepared and includes some of the above data.
The third-party will review this activity including veri- '
fication that the SWEC procedures are adequate to perform their intended purpose. The primary focus of this review will be the definition and verification of design input.
- 4. Verification of Existine Pipe Support Design' Documents l Revision 2 of the CPRT Program Plan in DSAP IX Attachment
! 2 stated that the existing pipe support calculations would be reviewed to determine their technical adequacy. ,
SWEC originally intended to review existing large bore support calculations on a sampling basis to determine their acceptability by using a load comparison method.
- However, the approach has now been changed to evaluating all large bore pipe supports individually. SWEC Project l
Procedures CPPP-6 and CPPP-7 describe the approach to be used, the design criteria to be satisfied, and the extent of the review required for the pipe support requalifica-tion effort. Thus, this Action Plan element has been incorporated into Action Plan Element #6.
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- 5. Resolution of Special Technical Concerns The CPRT Program Plan describes the SWEC approach to be used in the resolution of special technical concerns. The j special technical concerns are those issues outside the
! , scope of the typical problems encountered in the conven-tional piping stress analysis and pipe support design and are to be addressed by a special technical group. Many of the external source issues are included in the special technical concerns and are required to be considered in the piping and pipe support reanalysis. The resolutions of the special technical concerns will be incorporated in the SWEC Project Procedure CPPP-6, " Pipe Stress / Support Requalification Procedure" and CPPP-7, " Design Criteria for Pipe Stress and Pipe Support". The approach to resol-ution and the background information for the resolution, however, are contained in supporting SWEC calculations, special studies and/or reports.
- 6. Reanalysis of Piping Systems -and Reevaluation of Pipe Support Designs Attachment 2 of DSAP IX of the CPRT Program Plan describes the reanalysis of piping systems and the reevaluation of pipe support designs. The Plan states that the pipe stress reanalysis effort will follow project procedures CPPP-6. " Pipe Stress / Support Requalification Procedure" and CPPP-7, " Design Criteria for Pipe Stress and Pipe Sup-ports". The large bore piping reanalysis will include all ASME Class 2 and 3 piping larger than 2 inche3- (nominal pipe size) excluding portions within the boundary of Wes-tinghouse Class 1 auxiliary branch line stress problems and all Class 5 piping within the ASME Class 2 and 3 stress problem boundaries. The large bore pipe
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stress analysis will utilize verified as-built data (see Action Plan Element #2 above) and verified system design input
! (see Action Plan Element #3 above). New seismic amplified response spectra using the damping values per ASME Code Case N-411 will be used_ if NRC approval is obtained. Elimination of unnecessary pipe supports (including . snubbers) to optimize system performance will
{ be performed by pipe stress engineers where judged appropriate.
The large bore piping stress reanalysis will be used as the analysis of record to qualify the
' structural integrity of the piping systems. Gibbs & Hill will remain the designer A/E of record for the piping systems with full responsibility for the system functional
{ design.
The SWEC piping stress results will also be evaluated for consistency with the ' postulated pipe b'reak locations.
l For small bore piping systems, the CPRT Program Plan states that reanalysis of small bore (2 inches and under)
! piping and supports will be performed on a sampling basis to verify adequacy. SWEC is preparing a project procedure (CPPP-15) for the requalification of small bore piping systems.
The specific approach to be used for the requal-ification effort is being developed at this time.
For large bore pipe supports, SWEC is reevaluating all ,
ASME Class 1, 2, and 3 pipe supports and Class 5 supports within the ASME Class 1, 2, and 3 piping stress analysis problem boundaries. Each pipe support calculation will be ,
reviewed for technical adequacy including the need to address those aspects of the calculation which are assoc-I iated with external source issues.
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_8,5.3 Staff Evaluation
- 1. Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria Because, the major details of the SWEC requalification effort are contained in the SWEC project procedures CPPP-5, CPPP-6, CPPP-7, and CPPP-8 and because these procedures have just been made available to the staff, evaluation has not yet been completed. During audits by the staff at SWEC and at the CPSES site, draft copies of the procedures were reviewed. Since these reviews were preliminary in l nature and of draft documents only, cpproval.is contingent upon a thorough and satisfactory review by the staff.
This review is presently in progress. Continued work by SWEC in this area is at~the risk of the licensee.
- 2. Verification of As-Built Infomation l
The resul'ts and the compilation of SWEC and QA/QC i walkdowns and previous work peformed by TUGC0 will determine the acceptability of the Plan with respect to the " Verification of As-Built Information". Therefore, at least a partial review of the implementation of these procedures is required.
- l During staff audits at the SWEC offices and at the CPSES site, the topics of CPPP-5, the CPPP-5 walkdown report, CPPP-8, the TUGC0 as-built procedures, the penetration schedule and the QA/QC piping and pipe supports samples were discussed and reviewed. In addition, the staff and its consultants performed sample walkdowns.
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.MISCIO - f 1/15/86 SECTION g,3o '
-As. a result of our review, the staff has identified several areas where additional information is required:
- a. The CPPP-5 walkdown procedure .111ows the valve and support location tolerances used by SWEC to range from +/- 3 inches to +/- 12 inches depending on the dimension used on the drawing. Typically, a toler-ance for such a dimension is a function of the dia-meter of the piping system. In this case, there is no relationship. Using this CPPP-5 approach, a valve or support could be mislocated more on a 3-inch line than on a 30-inch line and is still within the ac-ceptability limits established in CPPP-5. The lic-ensee must provide further justification for these tolerances (e.g., the 12-inch tolerance must be jus-tified by SWEC for small diameter piping.
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- b. SWEC Stress Reconciliation Walkdown Procedure CPPP-6 indicates that a final field walkdown will be per-formed at the completion of the requalification effort. The purpose of this walkdown will be to ver-ify that sufficient clearance exists between the piping systems and nearby structures. Based on the preliminary conclusions from the CPPP-8 walkdown data (observed during staff audits), the scope of the stress reconciliation walkdown should be expanded to reconcile concerns related to improper clearances t
between pipe and pipe supports and improper alignment and interferences with the rear bracket which were identified in the CPPP-8 walkdown.
- c. TUGC0 Penetration Schedule - During an audit at the CPSES site, the content of this schedule was discussed with TUGC0 -employees. It appears that the
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a MISCIO 1/15/86 .
L SECTION g 3a, .
attributes chosen by SWEC, and because this failure affects any conclusion relative to the accuracy of the as-built data, the staff requires that the applicant address this failure and its effect on the accuracy of the as-built data. The comparison of the 100% TUGC0 re-walkdown with the existing as-built data would be helpful in reaching a conclusion.
- 3. Review and Verification of Systems Design Input. Seismic Acceleration and Fluid Transients The staff has reviewed SWEC Procedure CPPP-10 and discussed all system design inputs during audits at SWEC offices. The staff feels that the approach used to assure that all operating modes and systems'l' oading conditions
( are identified is appropriate. However, prior to staff .
j approval of these, one document describing all of them, including response spectra, must be prepared and satisfac-torily reviewed by the staff.
- 4. Verification of Existing Pipe Support Design Documents The staff has reviewed and evaluated the CPRT Program Plan
! DSAP IX, Attachment 2 action plan details related to the verificaton of existing pipe support design documents.
l Based on the November 22, 1985 letter from W. Counsil to V. Noonan, the effort associated with this Action Plan i
Element has been changed. Thus, the SWEC approach to re-l qualify pipe support designs has been addressed as part of j Action Plan Element #6 and the staff evaluation is pro-L vided therein.
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MISCIO
- 1/15/86 SECTION ,K3, / ,
information required by the pipe stress analysis is available in this schedule. The. apparent lack of Yeference of this penetration schedule, however, in the SWEC Procedure CPPP-7, is of concern to the staff. Specific reference to this schedule must be included in CPPP-7 along with directions for its use by the pipe stress analysts. In addition, the staff plans a walkdown to verify the accuracy of the data in the penetration schedule in the near future.
- d. 0A/0C Construction Adequacy Program Reinspection -
During audits at the sit of the procedures being
. used, it was determined that there is a difference of tolerances used within this reinspection versus those used by SWEC in the CPPP-5 walkdown. In addition, it is not clear to the staff that the tolerances used here for gaps (e.g., on box frame supports) would be acceptable for the SWEC pipe stress requalification effort. SWEC must review all tolerances used and document their acceptance.
As described above, the total verification of the as-built drawings is a function of a compilation of a number of walkdowns and work by at least three organizations. The need for an evaluation to integrate all of this informa-tion and document the results is apparent. Without such a document, it is not clear to the staff if all of this in-formation is compatible and it is not clear that it will lead to the proper conclusions. The licensee must prepare this document and submit it to the staff for review.
In addition, because the need for the 100% walkdown of valve and strut orientation came about in CPPP-5 as a v result of the failure of one of the four
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MISCIO 1/15/86 /b SECTION y 3,[ '~
- 5. Resolution of Special Technical concerns The staff has reviewed and evaluated the CPRT Program Plan details related to the resolution of special technical
. concerns. The resolutions of the special technical con-cerns are being developed by a special SWEC technical group which is not directly involved in the piping stress analysis effort. This division of responsibility allows the resolutions to be concucted independent from the daily
- pressures involved with the production effort and, thus, assures a thoughtful and uniform resolution. The SWEC l special group has reviewed past studies, analyses, and l reports on certain technical issues in addition to the l transcripts and fi. lings associated with the CPSES hearings
! in order to understand the concerns of all parties. SWEC has developed appr'oaches for the resolution of several piping and pipe support concerns and has incorporated their resolution in SWEC Project Procedures CPPP-6 and
- CPPP-7. Based on preliminary reviews, the staff finds l
1 that the pr'ocedures allow an adequate process to exist for the resolution of the special technical concerns.
However, the staff has not yet reviewed the details of the resolutions. The staff plans to engage in a series of audits specifically to review the technical adequacy of the resolution. Thus, the staff has not yet completed its evaluation of the adequacy of the techriical resolutions.
Staff approval of this, therefore, is contingent upon sat-isfactory review by the staff of the procedures and evaluation of the technical resolutions.
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SECTION R 3./ .
- 6. Reanalysis of Pipine Systems and Reevaluation of Pipe 3
Support Designs '
The staff has reviewed and evaluated the CPRT Program Plan details associated with the reanalysis of piping systems and reevaluation of pipe support designs.
The staff review of the scope of the large bore piping stress reanalysis finds it to be adequate contingent upon l
an acceptable resolution of the following concerns.
i The scope of the large bore piping stress reanalysis in-
- cludes certain Class 5 piping. Specifically, the scope j will include only those Class 5 piping within the bound-l aries of ASME Class 2 and 3 piping stress problems. The staff requires further justification for excluding the remaining Class 5 piping from reanalysis. <
In the November 22, 1985 letter to the staff, the CPRT states that SWEC is responsible for the structural quali-fication of piping and supports. However, it is stated that Gibbs & Hill will remain the designer A/E of record l for the piping systems with full responsibility for the system functional design. The staff review of the CPRT Program Plan Appendix F (Revision 1) Secton II.F finds that interfacing information from SWEC related to design, construction, and QA/QC concerns found during walkdowns will not be provided to Gibbs & Hill. Because Gibbs &
Hill has the full responsibility for ensuring the piping system functional design, it is not clear why Gibbs & Hill would not need this information. In addition, if Gibbs &
Hill will remain the designer A/E of record for the piping systems, then the licensee should provide justification for .a lack of review of the SWEC reanalysis by Gibbs &
Hill.
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T] .~"P MISCIO- j 1/15/86 SECTION K 34 .
i The staff has reviewed the CPRT Program Plan response related to small bore piping requalification. Because the SWEC approach to be used for the requalification effort has not been completed at this time and will be addressed by SWEC Project Procedure CPPP-15, the staff has not yet completed its review and evaluation of this item. Staff approval for this is contingent upon a satisfactory review by the staff of this procedure.
The staff has reviewed and evaluated the CPRT Program Plan details related to the reevaluation of' large bore pipe supports. The staff finds the scope of the large bore
, pipe support reevaluation to be acceptable except for the following concern. Similar to concern raised by the staff i
for Class 5 piping, the licensee should provide further justification for excluding Class 5 pipe supports other than those Class 5 supports within ASME Class 1, 2, and 3 piping stress problem boundaries from the pipe support re-qualification effort.
J g g Conclusions Based upon the staff review of the CPRT Program Plan, the CPRT response to staff questions provided in its November 22, 1985 letter, and staff audits performed to date, and contingent upon acceptable resolu-tions of the items listed below, the staff concludes the following.
l The scope of the piping and pipe support requalification effort being performed by SWEC provides a comprehensive program for addressing many of the technical concerns raised in the e.v.ternal source issues related to the design adequacy of piping and pipe supports at CPSES.
However, proper implementation of the program must be conducted in order to assure that the program design criteria have been met and ifcensing commit-ments have been satisfied.
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MISCIO - 1/15/86 SECTION K g , [ d s
- a. satisfactory review of the staff of the SWEC proce-dures
- b. justification of tolerances -
- c. stress reconciliation walkdown scope expansion
- d. cross reference of penetration schedule with CPPP-7
- e. documentation of tolerance difference between QA/QC walkdowns and SWEC walkdowns
- f. preparation of a document to compile all work done to verify as-built data
. g. justification of one attribute out of four failing to meet acceptance criteria of CPPP-5
- h. preparation of a document compiling all operating modes and system loading conditions
- 1. justification for a lack of review of the SWEC re-analysis by Gibbs & Hill j - j. justification for exclusion of Class 5 pipe supports I
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J IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN l .
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!Y 1/30/86 SECTION 2.0 .
2.0' EXTERNAL SOURCE ISSUES Concerns regarding the adequacy of the CPSES construction QA/QC program and the adequacy of the constructed safety-related hardware have been raised by a number of sources external to Texas Utilities. These sources are the NRC Staff Technical Review Team reports ("TRT"), the NRC ASLB proceedings on the CPSES operating license ("ASLB"), the NRC Staff's Supplemental Safety Evaluation Reports ("SSER's"), the NRC Staff's Construction Assessment Team (" CAT") and Special Investigation Team (" SIT") reports, certain Inspection Reports issued by NRC's Region IV staff ("RIV"), and the Cygna Independent Assessment Program i
("IAP"). Collectively, these concerns are referred to as the " External Source Issues (ESI). -
[ The Quality of Construction and QA/QC Adequacy. Program (QOC) was formulated by CPRT to respond to and resolve the External Source Issues.
The QOC has two components to resolve and bound the safety-significant implications of any ESI identified or found deficiency in either the I
hardware or the CPSES construction QA/QC program. These components are:
First, the CPRT will evaluate each.of the specific hardware.and program-matic concerns raised by the ' External Source issues. It will determine the nature of any safety-significant hardware deficiencies and t'he cor-I rective actions necessary to resolve them. Second, the CPRT will deter-mine the root cause of each discovered safety-significant deficiency (or trend of nonsafety-significant hardware deviations) and will 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 program-matic reasons and to determine if changes need to be made in ongoing programs to prevent recurrence in the future.
l Implementation of the QOC program is by execution of Issue-Specific l
Action Plans (ISAPs).
< To assure that all issues / concerns from External Sources are addressed, CPRT will develop a matrix that provides a cross-reference
CTION 2.0 .
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y between each iss'ue/ concern and the action plan (s) that addresses it.
This matrix will also serve as an aid in the collective evaluation process. The matrix format will present information such that valid concern can be tracked to the appropriate criteria of 10CFR50, Appen-dix B, and/or hardware area, and tracked to the ISAP or OSAP governing the concern.
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.IV 1/29/86 SECTION 2.3 p 1 .
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2.3 Civil / Structural Issues-Six external source issues relating to construction adequacy in the civil / structural area were listed in NUREG-0797, Supplement No. 8 (Reference ).
Under the Program Plan, Appendix C, Action Plans, the CPRT developed the .following Issue Specific Action Plans (ISAP) to address
, and resolve the Civil / Structural issues relating to construction adequacyr Action Plan Title I.c Electrical Conduit Supports II.a Reinforcing Steel in the Reactor Cavity II.b Concrete Compression Strength II.c Maintenance of Air Gap Between Concrete'Structurds II.d Seismic Design of Control-Room Ceiling Elements II.e .
Rebar in Fuel-Handling Building i
! 2.3.1 ISAP II.a. Reinforcing Steel in the Reactor CEvity 2.3.1.1 Introduction This ISAP addresses a documented occurrence in which reinforcing steel was omitted from a unit I reactor cavity con-crete placement between the 812-foot and 819-foot-1/2-inch elevations.
Although the omission was documented, justification supporting the engineering conclusion to use as is was not available.
2.3.1.2 CPRT Approach -
The action plan is designed to assess the l design adequacy of the existing as-built condition of the reactor cavity
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SECTION 2.3 1/29/86 bMgi
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wall and other areas within Units 1 and 2 where rebars were omitted.
l This assessment will include an evaluation of the engineering / field design-change interface.
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All documented instances of rebar omission l
will be reviewed to assure that proper engineering evaluation and doc-
[ umentation exist in support of the disposition of each item. In addf-l tion, a random sample of 60 concrete pour cards will be reviewed to l verify that current design documents were used in construction.
Procedures governing design changes will be reviewed to verify the adequacy of methods for controlling implementa-tion of design changes into construction.
2.3.1.3 Staff Evaluation The staff has reviewed the CPRT Program Plan, ISAP II.a, Revision 2, and the CPRT response of November 22, 1985, to the staff comments (dated September 30,1985).
The staff has reviewed the standards and acceptance criteria delineated in the ISAP and has found that they are consistent with licensing comitments.
The CPRT methodology in reviewing documenta-tion and evaluation of procedures governing the eng'ineering/ field design-change interface and the review of the evaluation of the imple .
mentation of these procedures is consistent with current verificatJon practices.
2.3.1.4 Conclusions The Program Plan, Revision 3, ISAP II.a. is responsive to the concerns raised by the staff in the September 30, 1985 letter and is therefore acceptable.
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h) ON IV 1/29/86 J'=.g SECTION 2.3 .
2.3.2 ISAP'II.b. Concrete Compression Strength 2.3.2.1 Introduction This ISAP addresses civil / structural allega-tions that some concrete strength tests were falsified. The applicant's position is that the uniformity of the concrete placed appears to min-imize the likelihood that low concrete strengths werd obtained. The j staff felt that additional action by the licensee was necessary to pro-vide confirmatory evidence that the reported concrete strength test results are indeed representative of the actual strength of the concrete installed. (
2.3.2.2 CPRT Approach This action plan has been developed to verify the quality of the concrete in question. The Schmidt (Rebound) Hammer Test will'be used to compare / correlate the relative strength of concrete poured during the period in question (Concrete at Issue, CAI) and con-crate poured outside this period (Control Concrete, CC). .
All testing will be in accordance with ASTM procedures. The area for testing will be limited i:o the exposed surface area where the Schmidt Hamer Test can be performed. Concrete-cylinder test data. for the two populations will also be obtained, reviewed, and used for reference.
If, after reviewing results of the Schmidt Hamer Test, the CAI population is found to have lower strength than the CC population, core tests, calibration of the Schmidt Hamer with known concrete strength or analysis will be performed. Any such actions will
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be documented as a revision to this action plan.
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IV SECTION 2.3 1/29/86 7i N
2.3.2.3 Staff Evaluation The CPRT methodology for reviewing concrete-cylinder- strength tests and for performing Schmidt Hanmer tests on CAI and CC_ concrete pours is consistent with procedures / practices used in the concrete area. ,
The statistical correlation for the CAI versus CC rebound tests is an appropriate approach, since the same or similar
) environment (age, strength, humidity) was used for the placements.
2.3.2.4 Conclusions l The Program Plan, Revision 3, ISAP II.b, is responsive to the concerns raised by the staff in the September 30, 1985
- letter and is therefore acceptable.
2.3.3 ISAP II.C. Maintenance of Air Gap Between Concrete
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l Structure 2.3.3.1 Introduction The TRT in NUREG-0797, Supplement 8, raised a concern that TUEC had not adequately demonstrated compliance with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.8.2.8, which require separation of Seismic Category I buildings to prevent interaction during an esrth-quake.
2.3.3.2 CPRT Approach t
This ISAP will assess the current as-built condition to determine the extent and cause of the condition. An evalu-ation will be performed to determine ?.he design significance of the as-built condition. Any identified debris or rotofoam that impacts the design basis will be removed.
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IV SECTION 2.3 1./29/86 4P" eig" The final a's-built condition of all separation between Category I buildings and between Category I and non-Category I buildings will be determined as well as documentation of the design acceptability.
l Quality Control (QC) will document the final as-built conditions and a third party will overview this process.
I 2.3.3.3 Staff Evaluation l
The staff has reviewed the methodology to ba used in addressing this specific issue. The approach is a complete reinspection of the as-built condition and the verification of design acceptability for compliance with FSAR connitments. In addition, the cause of the existing condition (s) and its a'plicability p to other areas of the plant will be reviewed and evaluated.
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2.3.3.4 Conclusions l
l The action plan is responsive and .with proper implementation, including design acceptability for FSAR commitments, should resolve NRC concerns.
2.3.4 ISAP II.d. Seismic Design of Control-Room Ceiling Elements .
The seismic design of control-room ceiling elements I
issue reflected in ISAP II.d has been transferred to the CPRT Design-Adequacy Program (DSAP VIII) due to potential design implications in the Civil / Structural discipline. This was done by TUGC0 to facilitate resolution and to provide an improved focus on any generic implications and collective significance.
The staff concurs with this approach. This item and the staff's review is contained in Section III, Subsection 2.3.2, of this SER.
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- 2. *i. 5 ISAP II.e, Rebar in the Fuel-Handling Building ,
2.3.5.1 Introduction This issue-specific action plan addresses an alleged instance of unauthorized cutting of rebar in the Fuel-Handling Building due to depth of core drilling. .
2.3.5.2 CPRT Approach The CPRT action plan will address the as-built condition of the specific concrete mat in the Fuel-Handling Building, wi11 assess the work of the construction crew that could have cut addi-l tional rebar without proper authorization, and will review controls governing rebar cutting.
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! Design calculations will be generated if l
required.
l All cases where rebar cutting was requested for installation of Hilti bolts will be reviewed and comparison made between rebar pattern and embedment depth of the installad bolts.
The adequacy of the procedures and controls governing rebar cutting will be reviewed.
2.3.5.3 Staff Evaluation I
The staff has reviewed this specific action plan. The scope and methodology is acceptable for determining the adequacy of procedural controls and for locating areas where potential unauthorized rebar cutting was necessary.
If redesign is required, the requirements of ACI-318-71 and FSAR commitments will be consistent with original design criteria.
4 IV 1/29/86 SECTION 2.3 3 p ,, p L'aL' j;"
2.3.5.4 Conclusions '
The approach described in this ISAP is accept-able. Proper implementation will assure the acceptability of as-built conditions.
2.3.6 ISAP I.c, Electrical Conduft Supports 2.3.6.1 Introduction This issue-specific action plan addresses the installation of nonsafety-related conduit supports in seismic Category I areas of the plant. No evidence could be found that substantiated the adequacy of the installation, or in demonstrating that their failure
. would not adversely affect the function of safety-related components or cause injury to plant personnel.
2.3.6.2 CPRT Approach
- l . This action plan will document the basis for the CPSES Damage Study assumption that Train C nonseismic conduit, two inches in diameter or less, would fall and have a potential for inter-acting with safety-related components.
A seismic analysis will be performed that verifies stability and/or acceptable interaction during an earthquake.
I Two separate samples will be derived from the Unit 1 and comon areas.
One will be randomly selected and the other will be derived on an engineering basis.
The QA/QC Construction Adequacy for Train C 1
conduit will be addressed under CPRT Action Plans VII.a.1, " Quality Con-trol Inspection", and VII.b.4, "Hilti Bolts".
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2.3.6.3 Staff Evaluation '
The staff has reviewed the scope and meth-odology used in addressing this specific issue.
The sample size and selection is consistent with the overall approach used in the Construction Adequacy Program.-
The use of two samples,. random and engineered, should provide a reason-able review of the entire population and a lower bound on seismic per-formance.
The seismic analysis of both populations will determine whether the two-inch-and-under conduit supports meet the requirements of FSAR Section 3.7B.2.8 and Regulatory Guide 1.29.
Revision 3 of the plan is responsive to the
- concerns listed in the September 30, 1985 NRC letter to the applicant.
However, in clarifying the disposition of rejects identified within the engineering sample, the statement " expansion of the engineering sample is not contemplated" is made in Section 4.1.2.1- (page 7) and Sec-tion 4.1.2.5 (page 10). The intent of this statement relative to sample exp'ansion and compliance with Appendix D of the Plan is unclear.
i 2.3.6.4 Conclusions I
The general scope and methodology contained in this ISAP is responsive and with proper implementation, including design acceptability for FSAR connitments, should resolve NRC concerns.
l However, before this ISAP can be accepted by l the staff, clarification and/or justification of the statement in Sec-tion 4.1.2.1 and 4.1.2.5 is needed.
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IV 1/29/86 SECTION 3.3 3p 3.3 Mechanical Populations me
- The CPRT has divided the Mechanical Equipment Discipline into the following populations:
HVAC Ducts / Plenums -
HVAC Equipment Installation Large-Bore Piping Configuration Small-Bore Piping Configuration Pipe Welds / Material Piping System Bolted Joints / Material Hechanical Equipment Installation Field-Fabricated Tanks Instrumentation Tubing Welds / Material Within each population, work processes will be established.
CPRT defines each work process as a homogeneous activity and therefore must assure that similar installation procedures, craft, organization and QC inspection procedures were used in the or,fginal construction. .
Random and engineered (safe-shutdown) sample sets will be ' selected for each population.
3.3.1 Staff Evaluation The staff reviewed Revision 3 of the Program Plan and undertook audits of each of the Mechanical Populations. The[ audits f included reviews of procedures, documentation, work processes, and attributes.
l- For each of the mechanical areas. ERC has prepared a
" Population Description" addressing th'e contents and boundary of each
! category of work. In addition to the Population Dascriptions, a flow-chart describing the work processes and associated attributes for each sample population was provided. It is the attributes that provide the
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basis for the inspection checklists. The work-process attributes were reviewed in order to ver'ify that each work process would be adequately reviewed. The Specific Staff Evaluation for each of the Mechanical Pop-l ulations is provided in the subsequent paragraphs.
l l 3.3.1.1 Field-Fabricated Tanks L
This population contains eight field-fabricated tanks. All eight tanks will be reinspected. The procedures j were reviewed and contained information for all attributes given in the
( Work-Process Description.
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' 3.3.1.2 Mechanical Equipment. Installation L
The original governing construction document is the- Gibbs & Hill Mechanical Erection Specification 2323-MS-101. The implementation of this is accomplished by Erown & Root Specification
- titled " General Installation of Mechanical Equipment", CP-1. The orig-inal governing quality assurance procedure is Brown & Root QI/QAP11.1-39 .
titled " Mechanical Equipment Installation Inspection".
Qualitative results of the sampling conducted so far indicate that 20 to 25 percent of the sample drawn is from. Unit
- 2. The remainder of the sample is from Unit 1 and comon areas. The work processes associated with mechanical equipment installation are setting, anchoring, welding and, for rotating equipment only, alignment.
- The attributes of each work process were reviewed in depth. ERC per-sonnel indicated that if a particular attribute of the work processes was not addressed when the sampling activity was completed, assessment would be made as to whether or not the sample needed to be expanded to include that attribute. If a decision was made not to specifically address that attribute, the basis for this decision would be provided in the report addressing the construction adequacy evaluation of, in this instance, mechaaical equipment. Work-process homogeneity is evaluated
IV 1/29/86 . ' -, 4 p SECTION 3.3. ;.:./;. g g= 9 by checking to make sure that the same organizations are involved an'd that the procedures have remained nominally constant. Sampling is per- l formed at the work-process level. Since evaluation of equipment is made I
at the work-process level, each sample will be expanded such that sixty
- . evaluations will be made for each work process.
The ERC reinspection procedures were reviewed and compared to the original construction specifications and procedures for homogeneity of work processes and choice of generic attributes.
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j 3.3.1.3 Piping System Bolted Joints / Materials l
Two work processes comprise the piping-system bolted-joint category. They are installation preparauon and final bolt :
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l fit-up. There ar.e 7000 bolted joints at the Comanche Peak Power Sta- l l tion. The work processes and their attributes appear to adequately l I represent the bolting of piping joints. A flowchart and population description have been prepared to ' provide the basis for the sampling of bolted joints. Several of the attributes given in this population will -
require both inspection and document'ation review.
3.3.1.4 Large-Bore Piping Configuration /Small-Bore
- Piping Configuration 1 The large- and small-bore piping configuration ,
i construction adequacy reviews are addressed using 3000 Brown & Root isometric drawings. The scope of this activity is intended to assess the work process of piping installation through evaluation of attributes such as location, size, and orientation of piping and pipe components.
The Brown & Root isometric drawings provide the basis for sampling both large- and small-bore piping. Large-bore piping includes that piping which is 2-1/2 inches and larger in diameter; small-bore piping is that piping less than 2-1/2 inches in diameter. If an isometric drawing con-taining both large- and small-bore piping were to be drawn as part of a
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IV 1/29/86 SECTION 3.3 tw e- =
9 W[hil j sample, it would be used in both the large- and the small-bore work--
process review. The,in'tallation s work process and its attributes are
'the same for both large- and small-bore piping. The piping considered in this review includes all ASME Code Class piping. ERC reported that l
1 all piping of large and small bore is installed. to one procedure and by one craft, pipe fitters. Some attributes such as piping valves would obviously be included in any sample drawn for either large- or. small-bore piping. There are other attributes such a expansion joints, screw joints, and strainers which, because there are very few in the system, might not be included in any selected sample. ERC reported that, fol-lowing the sampling process, a review to assess the adequacy of the i
sample for adequate representation of attributes would be made. How-ever, a specific component, because it was not included in a sample, would not necesssarily be examined only for that reason.
. 3.3.1.5 HVAC Equipment Installation The CPRT has divided the safety-related HVAC systems into two mechanical populations. One population is HVAC Equip- .
ment Installation (active components), and the other is HVAC Ducts and Plenums (inactive components). Both the active (equipment) and inactive (ducts, plenums and appurtenances) components in these populations have been installed by'Bahnson Services Company with the exception of the pad or structural-steel-mounted equipment. This equipment was installed by Brown & Root and is not included in either of the populations. The installation of this equipment will be inspected as part of the Hechan-ical Equipment Installation population. !
The HVAC Equipment Installation population includes': fans, filters, fan-coil units, air conditioners, dampers (fire, gravity and modulating) and airflow monitoring stations. There are two Work Processes associated with the population, which are:
- 1) equipment setting and 2) equipment connection. The setting Work Process includes those activities required to position / orient the equip-e
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IV 1/29/86 SECTION 3.3 - 5-ment in the proper location. The connection Work Process includes those activities necessary to' connect equipment flanges to supporting duct flanges. There are over 600 samples (items) in this' population.
The staff undertook audits of this population.
The audits reviewed documentation, work processes, attributes and homogeneity.
! 3.3.1.6 HVAC Ducts / Plenums The HVAC Ducts and Plenums population includes fabricated . sheet-metal duct sections, plenums, flexible connections,
! fittings (elbows, transitions, tees and wyes) and appurtenances. The appurtenances include: turning vanes, access doors and volume dampers. -
There are three . Work Processes associated with the population, which >
are: 1) fabricating, 2) installing and 3) welding. The number of samples (items) in this population is over 7,100.
l The random and engineered (safe-shutdown) .
! sample set wilt be selected for each population such that each Work Process will be inspected to the 95/5 confidence level.
The staff undertook audits of this population.
These audits reviewed documentation, Work Processes, attributes and homogeneity. The Work Proccess attributes were reviewed in order to verify that each would be adequtely inspected. This entailed reviewing the installation procedures referred to in the Description Memorandum for Reinspection and Quality Instruction documents for each population.
A comparison of the distribution of component types in the sample sets (random and engineered) to the distribution in the total population set was made. This revealed that all component types were represented in the sample sets, and the distribution closely resembled that of the total population set. ,
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IV 1/29/86 SECTION 3.3 r 3.3.1.7;PipeWelds/ Material Based upon the fact that both large-bore and small-bore pipe welds were fabricated to the same procedure and by the '
- .same craft, it was decided by ERC to combine these populations together.
The staff reviewed the (LBWM and SBWM) popuation basis, description mem-orandum,- population' description, populations item list and work process -
definition. ERC indicated that only one work process was chosen, Weld-j ing. Apparently, regardless of the. possible differences in the welds
,(configuration, material type, or process), each work process involves:
(1) common erection specification requirements; (2) common installation j procedure requirements;-(3) comon craft labor performing the same basic types of operations, (4) common inspection procedure; and (Si a comon inspection organization. ,
Since basically only two welding methods were used at CPSES, Gas Tungsten ARC Welding (GTAW) and Shielded Metal Arc Welding (SMAW), ERC has connitted to two random samples of 60 welds for
~
each welding method. The staff expressed a concern for the lack of .
separation of carbon- and stainless-steel welding. ERC pointed out that l welder qualification is in compliance with B&R Specification WES-031, l which qualifies a welder to both carbon- and stainless-steel welding.
I The staff reviewed WES-.031 and B&R Procedure CP-CPM-6.90, " Welding and I
Related Processes", and found very few areas where the procedures or l
specifications-differed with regard-to carbon- and stainless-steel weld-ing. Differences were associated with the two welding methods GTAW and SMAW. ERC said that of the 120 samples already established approx-imately 505 were stainless-steel welds. In addition, an engineered sample of 60 welds for each method was picked to account for safe-
~
shutdown systems. In both <:ases, GTAW and SMAW, the original sample of 60 and the engineered sample overlapped. This necessitated increasing the original sample to achieve the engineered sample of 60 welds. In all, a. total number of approximately 180 samples will be inspected.
9
-- ~ aw . . s.4 IV 1/29/86 SECTION 3.3 hs Under the work' process identified as " Weld-ing", 24 attributes were identified,18 of which are comon to both welding methods and to all welds. The remaining six attributes will be inspected as the sample dictates. Additional samples for these six attributes will be chosen as deemed necessary, or a justification for not increasing the sample will be given at that time.
3.3.2 Conclusions In reviewing Revision 2 of the Program Plan, several concerns were raised by the NRC staff in the August 9 and September 30, 1985 evaluation letters to TUGCO. These concerns can be sumarized as follows:
Inspector Certification Program.
Basis and rationale for establishing homogeneous hardware populations.
Attribute and criterion determination.
Sample expansion criteria. , .
The staff's evaluation and conclusions on the CPRT response to the concern on the Inspector. Certification Program is dis-cussed in Section of this SER.
The t!RC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.c),
when evaluated collectively with the assemblage of procedures and check-lists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogeneous hardware populations and the method used in determining attributes / criteria.
Based on the results of the audits, the Staff has con-cluded the following relative to the Mechanicai Equipment Populations:
s
^ ~ ~~~ ^
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CTION 3.3
- 1. A documented auditable trail of the background exists.
[ 2. The samples selected for the inspections are repre-
- - sentative of the type and distribution of the com-ponents within each population.
- 3. The attributes and associated checklists adequately describe the work processes.
- 4. The Verification (inspection) packages demonstrated that the CAP inspection wil,1 produce an auditable
. results trail.
e The concern raised by the Staff on sample expansion criteria has not been resolved to the satisfaction of the Staff. The details of the concerns are given in Section of I
this SER.
A specific concern on sample selection in the Pipe Welds / Material population is as follows.
The original breakdown was for a sample of 60 LB and SO 58 welds as part of two separate populations. The two populations nave been combined to account for the similarity in the welding attri-
, butes and the welding methods. The staff questions whether the original two 60 sample sets that are now combined into a sample cf 120 will be judged as (1) a single sample of 120 or (2) two samples of 60. This discrepancy must be clarified statistically. ,
l
s .
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IV 1/29/86 SECTION 3 4 "
3.4 Civil / Structural Populations The safety-related Civil / Structural Discipline consists of the following 15 populations:
, Concrete Placement Structural Steel Liners Fuel Pool Liner Fill and Backfill Placement Grout-Cement Grout-Epoxy Large-Bore Pipe Supports - Rigid Large-Bore Pipe Supports - Nonrigid Small-Bore Pipe Supports Pipe Whip Restraints Instrument Pipe / Tube Supports
~
Category 1 Conduit Supports '
HVAC Duct Supports Equipment Supports 3.4.1 Staff Evaluation The staff evaluation, based on several audits at the CPSES and review of Revision 3 of the Program Plan, for specific popula-tions is described below.
3.4.1.1 Category I, Conduit Supports (COSP) i Procedures for reinspection of this population I was reviewed. Tolerances for the attributes of this. population were obtained from the Gibbs and Hill Specification 2323-ES-100, Revision 2, dated October 25, 1980. Paragraphs 2-36 and 4-19 of the G&H specifica- l tion state that supports' shall be installed to detail drawings
- z. .
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IV 1/29/86 SECTION 3.4 =
2323-S-910 and 2323-EI-1705. The ERC Resinspection Procedure contains this set of drawings for the reinspection.-
4 3.4.1.2 Concrete Placement Population The staff reviewed the Concrete Placement Pop-ulation. Documents were reviewed to determine if homogeneity of the i work processes and attributes had been achieved.
The concrete placement population is presently subdivided into three work processes, each work process having various -
, numbers of attributes. Some of the attributes are to be reviewed by
- means of a field reinspection; others can only be reviewed by means of a document review; and some will be reviewed utilizing both field
! reinspection and documentation review.
l l
Gibbs and Hill Specification 2323-55-9, dated January 16, 1979, was reviewed to assure that the reinspection require-ments reflect the original construction tolerances and inspection requirements.
3.4.1.3 Structural Steel l
r Procedures and documents were reviewed during l audits at CPSES to see if homogeneity of the work process and attributes had been achieved for the structural-steel population.
l The original Gibbs and Hill specifications and l TUGC0 instructions were reviewed, and the tolerances and the inspection procedures were compared with those included in the Reinspection and Documentation Review procedures to assure that the reinspection require-ments reflect the original construction requirements.
_ _ , . ~ . . _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ , . _ _ . ..~.._____._-..__.,__..m.._.._ . . - _ _ . , _ _ _ _ _ , . . , _ - . . . . - - - _ _ - . _ _ _-
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- ._ .m- m. _ d IV 1/29/86 SECTION 3.4 -3 ..
3.4.1.4 Liners - Two Populations .
The following two similar populations were reviewed:
e
- 1. Containment Liner and Tank Stainless-Steel Liner I t .
- 2. Fuel Pool Liner These two populations were reviewed together.
The tolerance and inspection instructions in the reinspection procedures were compared to the original G&H construc-tion specifications to determine if the ERC reinspection requirements i
adequately represent those of the original construction.
l 3.4.1.5 Pipe Supports
' Pipe supports were separated into the follow-ing populations:
Large-bore pipe supports - rigid.
Large-bore pipe supports - nonrigid.
Samil-bore pipe supports.
i The large-bore population of pipe supports was divided as noted in order to assure a proper sampling of rigid and non-rigid pipe supports. This is important since the majority of " standard catalog supports" are in the nonrigid category. The small-bore sampling.
was not divided because the number of nonrigid small-bore supports is very small and also because the type of support is not readily obvious from the support number (as in the case for LB supports). ERC intends .
to sample 60 supports from each of the three groups (LBSR, LBSN, and
IV 1/29/86 ,$ .""
SECTION 3.4 g
'S8PS). The 58PS population was made up of four work processes: fab-rication, installation, welding and inspection. -
The staff reviewed the various documents ,
(description memorandum, population description and basis, population items list, work-process justification, attribute descript' ion and basis.
An auditable trail existed such that all work processes and accompanying attributes could be verified. The staff noted that, under pipe-support welding, two attributes were omitted (cleanliness and base-metal defects). ERC pointed out that cleanliness was unattainable, both from an inspection standpoint (prewelding attribute) and from the point of view of document review (cleanliness was not a hold point on the Multiple Wald Data Card (MWDC)). ERC also said that they did not include base-metal defects for supports as an attribute, since it was difficult to see defects through the paint. The staff pointed out that j requirements for identifying base-metal defects existed in ASME Subsec-
! tion NF-4000 and B&R Procedure QI-QAP-ll.1-28. After some discussion,
! ERC cosmitted to put base-metal defects into the attribute list and to.
treat all instances as part of the Construction Adequacy.
3.4.2 Conclusions The NRC Staff concludes that Revision 3 of the CPRT Program Plan for the self-initiated construction program (ISAP VII.c),
when evaluated collectively with the assemblage of pre:chras aad chcck-lists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogeneous hardware populations and the method used in determining attributes / criteria. .
l Based on the results of the audits, the Staff has con-cluded the followirg. relative to the Mechanical Equipment Populations:
l 1. A documented auditable trail of the background exists.
t 6
- - - - - - - . . - ~ . , . . , . , - - . . . _ , . . . . , _ _ _ , - . _ _ . - - , . . . - - - - , , , , , , , . , - - , , , - , - , . . , , - . - .
. _ . . . _ ~
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CTION 3.4 d ,
nr
- 2. The samples selec'ed t for 'the inspections are
, representative of the type and distribution of the components within each population.
- 3. The attributes and associated checklists adequately describe the work processes.
- 4. The Verification (inspection) ' packages demon-strated that the CAP inspection will produce an auditable trail.
. The concern raised by the staff on sample expansion criteria has not been resolved to the satisfaction of the staff. The details of the concerns are given in Section of this
- SER.
It was noted that the populations which contain Hilti bolts do not require that torque (as an attribute) be reinspected.
Torque tests will be performed under ISAP VII.b.4. However, -samples from ISAP VII.C will be contained in. the ISAP VII.b.4 population. This will be reviewed by the Staff during the audits of the implementation phase of the plan.
The staff has a concern about the statistical mechanics of the overlapping of the regular sample (safety-related items) with the engineered sample (safe shutdown systems). As explained to the staff, the engineered sample is independent of the safety-related sample; how-
. ever, some of the samples may be comon to both groups. After the i
safety-related sample has reached 60 and has been identified as such, the engineered sample from the 60 items is identified. This sample is then expandd until it reaches 60. Both samples are now designed to draw two independent conclusions. The question arises, if a safety-significant deficiency is discovered in a sample item that is comon to both samples, are both samples expanded? This question has not been adequately addressed in the plan.
4
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II 1/30/86 DRAFT 9
II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PUWI C01910N ELEMENTS I
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- . gg 1/30/86 -
1.0 QA/QC OF CPRT ACTIVITIES DRAFT
- 1.1 Introduction The requirement for the development and implementation of a Quality Assurance program is covered by 10CFR50, Appendix B. The Staff noted that Revision 2 of the Plan did not include any QA Program for CPRT activities. In the interim period between Revisions 2 and 3 the CPRT investigated a number of approaches to providing QA coverage of 4 CPRT activities. The original CPRT Policy on Quality Assurance adopted the following position
- .
f "The CPRT will not perform inspections, calculations, l or designs of record. CPRT activities and results j will not form any of the bases for the design or construction of the plant nor will the CPRT activities have a direct impact on the plant as it physically exists. For this reason, the CPRT does not fall under the normal Comanche Peak QA Program established by TUGC0 as specified in the FSAR'. The l
CPRT has been set up to consist of independent, 4
third-party experts who will advise TUGC0 management
- of existing plant conditions, and who will make recommendations for the resolution of any problems l which may exist."
However, the CPRT intends to resolve external source issues, some of which are currently categorized as violations of the TUGC0 QA Program.
Resolution of these issues may result in CPRT defining, reconnending and reviewing corrective action whitn, when implemented by others, do form the bases for design or construction and would have an impact on the
! plant as it physically exists. Although the corrective action is performed by others, there is the potential that the CPRT activities could be. considered to go beyond review and audit. Once the CPRT i
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l 30/86 w
- determined that recommended corrective action was one of the CPRT L functions, it became cle'ar that a QA Program for CPRT activities would be beneficial.
1.2 CPRT Approach -
l Revision 3 of the Plan includes Appendix G entitled '"CPRT -
Third Party Quality Assurance Program." This program was developed in response to direction from the CPRT, SRT and is based on the importance and scope of the third-party review. The CPRT QAP is structured in line with the three categories. of CPRT activities. A separate program is l provided for each activity.I l
(1) Overall Responsibility l
l Overall responsibility for the quality of CPRT activities l resides with he SRT. This'is accomplished in the following manner.
SRT will ' receive the results of all audits of CPRT activities, SRT willl receive corrective action response ,
to audit findings, SRT will perform, or have performed for them, special audits or reviews of CPRT activities as deemed necessary and documentation adequacy will be determined by reviews performed by the File Review Com-mittee.
(2) Issue-Specific Actions Plans - QA Elements l
l l
It is the position of the SRT that the principles of the CPRT l Program Plan, the CPRT Policies and Guidelines and the implementation
!, requirements specified in each ISAP generally provide the QA elements
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- 30/86 .
necessary for ISAP activities. Supplemental instructions were prepare'd and issued in the civil / structural and mechanical / miscellaneous areas because of the extent of third-party activities related to engineering evaluations and calculations in these areas. The CPRT Program documents address the following criteria of 10CFR50, Appendix B, in sufficient detail to satisfy the SRT that activities performed by the third party responding to ISAPs will have adequate QA coverage.
Criteria No. ' Description CPRT Program Guidance 1 Organization CPRT Program Plant Section VIII 2 QA Program CPRT Program Plan Section III.k 5 Instructions, CPRT General Policy for Conduct of Action Procedures and Plants Section 5.3 and each ISAP .
Drawings 6 Document Control CPRT Program Plan Section III.j and Guide on Central and Working Files ,
- 10 Inspection CPRT Program Plan Section III.k and Policy on Inspection Personnel 1
15 Non-conforming CPRT Program Plan Section III.k and General Conditions Policy for Conduct of Action Plans (Section 5.5) l 16 Corrective Action CPRT Program Plan Section III.k and General Policy for Conduct of Action Plans Section 5.5 i .
17 QA Records CPRT Program Plan Section III.j and Guide on Central and Working Files l
l l
- . . . . - - - - . - . . . . an n -.
30/86 18 Audits Checks of the activities performed under TRT ISAPs are accomplished by Review Team Leader overview of activities (CPRT Program Plan Section VIII.b.3); the reviews and audits conducted by the CPRT Results Report and File Review Connittee (Attachment 4 to CPRT Third- Party QA Program); and SRT review and '
approval of Results Reports (CPRT Program Plan Section VIII.b.1)
In addition to the generically applicable guidance listed above, the direction provided by specific ISAPs implement measures of other QA ele-ments (e.g., test control) as they are appropriate to the specific issue.
(3) Quality of Construction Program A Quality Assurance Program has been developed for the QOC activities and addresses the following 10CFR50, Appendix B Criteria:
Criteria Title '
1 Organization 2 Quality Assurance Program 4 Procurement Document Control 5 Instructions, Procedures and Drawings 6 Document Control ,
7 Control of Purchased Material, Equipment and Services 10 Inspection 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 QA Records 18 Audits O
30/86 Overall responsibility for QA activities rests with the ERC Division -
) Manager of Quality Assurance who has the authority to issue Corrective Action Requests or Stop Work Orders. The Procedures and Project Assurance Group are the on-site representatives of the ERC Division 5
Manager of Quality Assurance and are responsible for identifying and reporting on the status of the quality program by conducting l surveillances of the QOC activities. The results of these surveillances ,
are documented and reported to the Manager of Quality Assurance and the Review Team Leader. In addition, the Manager of Quality Assurance conducts audits of QOC activities in accordance with ERC QA require- '
ments. The Division Manager of Quality Assurance is organizational 1y l
independent from the CPRT.
i
! (4) Design Adequacy Prooram i
i A Quality Assurance Program has been developed for the DAP ,
i activities and addresses the following 10CFR50, Appendix B Criteria:
! Criteria Title 1 Organization i
2 Quality' Assurance Program , .
. 3 Design Control l 4 Procurement Document Control l 5 Instructions, Procedures and Drawings 6- Document Control 7 Control of Purchased Material, Equipment '
l
., and Services 15 Nonconforming Materials, Parts or Comp,onents l 16 Corrective Action
(, 17 QA Records i
- 18 Audits l.
In addition, should activities in the areas of Inspection. Testing or
~
Measuring, and Test Equipment be required appropriate Quality Assurance l
1 i
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. . . . _ .. _... -2w_ -. . . _
30/86- !
i requirements will be established or subcontractors with applicable Quality Assurance Program's will perform the activity, i
l1 Responsibility for ensuring effective implementation of the DAP QA Program resides with the DAP Quality Assurance Manager who reports directly to the DAP Review Team Leader. Audits will be performed, or led, by individuals qualified to the requirements of ANSI N45.2.23, Sections 2.3.1 through 2.3.4 for Lead Auditors.
l 1.3 Staff Evaluation 4
- The Quality Assurance Program provided by Revision 3 of the Plan is a significant improvement over the original CPRT Policy on l Quality Assurance and establishes a level of program quality j' commensurate with the activities of the CPRT.
) '(1) Overall Responsibility l Overall responsibility for the quality of CPRT activities l resides with the SRT. Results of audits and corrective action in each category are provided to the SRT. The program is not s'ufficiently ;
detailed with respect to the QA audits that will be performed by (or.
for) the SRT. These . audits are important to assure SRT QA involvement '
and control that is commensurate with their responsibility. Sufficient experience in Quality Assurance requirements is available in the SRT to understand the magnitude of audit findings, to determine the impact on program quality and to properly administer their responsibility for ,
quality. .
(2) Issue-Specific Action Plans Although a formal QA Program is not provided for ISAPs, 10CFR50, Appendix 8 Criteria applicable to all ISAPs are provided in the various sections of the Program Plan and Policies. In addition, 1
,.-..,_w.,n_.- , - _, ,en,,,_._-_,_.,_,__.,,__,,_
30/86 %
individual ISAPs implement measures of other QA criteria as they ar's appropriate to the issue of concern. The one criterion that appears to ,
be missing is Criterion 12, Control of Measuring and Test Equipment.
Some of the ISAPs require field measurement and the .use of tools, gages '
l and instruments, and Criterion 12 provides assurance that instruments are properly calibrated and controlled. Since formal QA audits .are not '
being performed within the ISAP organization it is important- that the SRT assure that its audit activities sample ISAP efforts.
- (3) Quality of Construction Program l ,
A formal QA Program is provided for the QOC activities.
Eleven criteria of 10CFR50, Appendix B, are addressed in the QOC QA Pro-gram. However, Criterion 12, Control of Measuring and Test Equipment is not a part of the QOC QA Program. QOC personnel will be performing j inspections which include measurement, therefore it is important that the tools, gages and instruments used are properly calibrated and l controlled. Adoption of Criterion 12 by QOC will assure tnat this occurs.
QA activities are the responsibility of t'he ERC Division Manager of Quality Assurance who is independent of the CPRT organization. Ongoing QA surveillances of QOC activities are performed by the Procedures and Project Assurance Group. This group has two reporting responsibilities; (1)to the ERC QA Manager for QA surveillance activities and (2) to the Review Team Leader for non-QA activities. This dual reporting. responsibility could appear to create conflicts. However, since the ERC QA Manager performs independent audits and is organizational 1y removed from all CPRT activities, and the -
Project Assurance Group non-QA activities are essentially Engineering Inspection Assurance activities, QA activities are sufficiently removed from day-to-day inspection and evaluation actvities.
Since SRT retains overall responsibility for quality imple- ,
mentation of the CPRT activities, the QOC organization chart (Figure
30/86 2.1) 'should indicate' that the ERC Division Manager of QA has reporting obligations to the SRT.
(4) Design Adequacy Program A formal QA Program is provided for DAP activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the DAP QA Program. i Should inspection activities be required appropriate QA requirements ,
will be established or subcontractors with applicable QA Programs will perform this activity. Inspection activities, if required, should be covered by formal adoption of Criteria 10 and 12 of 10CFR50, Appendix B.
l DAP 0% responsibility resides with the DAP QA Manager who reports directly to the Design Adequacy Review Team Leader. Althcugh this reporting chain is not as separate as that used in the QOC Program, it is acceptable under Criterion 1 guidelines. In addition, the DAP QA Manager has reporting responsibilities to the SRT. This responsibility t'o SRT should be clearly indicated on Figure 1 of the DAP QA Program.
Since the DAP has the responsibility of reviewing and accepting activities being performed by the Comanche Peak project it is important that the DAP QA Program be structured to assure audit of these project activities. Extensive reanalyses of piping, supports and i:able trays are being performed by the Comanche Peak project. Since the organizations performing the reanalysis activities are implementing
[ their own QA Programs, subject to TUGC0 audits, it is important that the i DAP sample these QA activities. For example, an important input to this effort is the as-built configuration of hardware. In the piping and pipe support area, SWEC has performed sample walkdowns to determine the adequacy of current as-built data for elements they consider to be critical to design. In addition, SWEC will be relying on any deficiencies in piping and support as-built data reported by QOC. Based on this, it is critical that DAP assure that sufficient data is obtained l and that the quality of the data is acceptable. In the area of cable
n... --. .
II 1/30/M ,9, trays- and supports, a complete walkdown is being perfcrmed by '
Ebasco/Impell to develop as-built geometry prior to analysis. It is critical that DAP assure that the quality of this as-built data is acceptable. ;
1.4 Conclusions The CPRT QA _ Program provided in the Plan will be acceptable for the current CPRTb activities provided the following concerns are satisfactorily resolved:
(1) provide'more detail on QA audits performed by (or for) the SRT, including audits of ISAP activities, (2) revise Figures 2.1 (QOC Organization Chart) and Figure 1 (DAP Organization Chart) to indicate reporting ,
responsibility of QA manager to the SRT, and (3) describe how the DAP QA Program would be implemented to assure the quality of as-built data obtained for
! extensive re-analysis programs.
I 2.0 ACCEPTANCE CRITERIA 2.1 Introduction Staff review of Revision 2 of the CPRT Plan indicated concern > -
with the acceptance criteria contained therein. This concern had two focuses. The first was that the acceptance criteria, as defined, did not- assure that licensing connitments would be complied with. The second was that sample size increase was primarily a result of the
" safety significance" of a discrepancy. Deviations trigger scope
- > expansion only when they would be a deficiency (i.e., " safety
, significant") if occurring elsewhere. However, the criteria for determinction of whether a deviation would be a deficiency can vary from 4
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30/86 -
component to component or system to system depending upon the plan't event and the component or system function under consideration in the evaluation of the deviation. Guidelines indicating how this evaluation '
would be accomplished were not provided.
2.2 CPRT Approach .
Revision 3 of the Program Plan includes Appendix E, "CPRT Procedure for the Classiication, Evaluation and Tracking of Specific Design or Construction Discrepancies Identified by the CPRT." Appendix !
E provides requirements for the classification of items, the evaluation process to be used, discussion of a tracking system and roles and responsibilities for CPRT personnel. The classification and evaluation ,
process sections of Appendix E provide separate guidance for Design, Construction and Testing adequacy, including more detail definitions and the evaluation process used for individual and progrannatic discrepancies. The approach to adverse trending of related observations, deviations or deficiencies indicative of a pattern exhibiting a discernible commonality are provided.
Root cause and generic implications will be evaluated for all deficiencies and adverse trends. In addition, Appendix E provides root cause and generic implication evaluation for special cases. For example, when a deviation results in a substantial loss of design margin a root cause and generic implication evaluation will be performed.
Identification of special cases will be situation-specific and cannot be generically defined.
2.3 Staff Evaluation '
The approach to Acceptance Criteria defined in Revision 3 of the Plan, particularly Appendix E, is a significant improvement over the '
information contained in Revision 2 and is partially responsive to prior Staff concerns. The classification of discrepancies into separate
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30/86 i Design, Construction and Testing adequacy categories will provide a more consistent and readily auditable set of records.
The - evaluation process defined in Appendix E, though more i definitive than Revision 2 of the Plan, still does not provide sufficient detail on safety-significant evaluation. This concern is primarily related to the fact that safety-significant evaluations of discrepancies are currently underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern j are piping and cable trays and their supports.) Until this revised information becomes available as " plant record documentation" then the safety-significance evaluation process cannot be completed. Any evaluations made using existing documentation must be revisited when the
- new documentation becomes available. The major reason for this is that
, TUGC0 has elected to perform extensive reanalysis of piping, cable
, trays and their supports which could result in hardware modification related to oeimization or deficiencies or, different design documents
, and values wh h form the basis for the safety-significant evaluation.
Based on this, the staff feels that safety-significant evaluation and the potential for scope expansion must .be based on' final plant
, documentation. This position does not preclude the fact that existing issues which led to the current reanalysis of piping and cable trays
, must be evaluated for root cause and generic implication to assure that programatic deficiencies do not extend beyond the boundaries covered by the reanalysis efforts.
l A second concern is related to the fact that safety-significant evaluations must be performed using Code or Regulatory ap-proaches. This does not mean that Code or Regulatory margins must be l the criteria for safety significance, rather the techniques used and the '
extent of the evaluation must address each criteria which formed the
- basis for the original design. For example, the use of actual material properties versus Code defined material properties could be acceptable
- but does not preclude the fact that all evaluations comitted to in the
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FSAR must be addressed in order to establish margins on all segments of the acceptance criteria." Actual material properties (if higher than Code minimums) may be of value in evaluating primary stresses and functionality but do little to change the fatigue margin. This concern ;
is not limited to Design discrepancies but includes Construction discrepancies for which safety- significance is determined through the use of Design evaluations.
The staff has conducted audits of the QOC activities and reviewed the safety-significant determination process during one of those audits. The staff has a concern with the process be!ng used as it addresses safety-significant determination and subsequent sample expansion. Thqt QOC has developed a number of populations for review.
i In some cases a given population may include hardware that is covered by another population or is not considered appropriate for individual l population development. In the review of the given population, any hardware. covered by another population that is considered to be a deviation will be evaluated with respect to its safety-significance on the given population within which it is included. The fact that the piece of hardwart, if considered in the framework of its own population, may have been safety-significant is not a consideration. Further, since the piece of hardware is already a part of another population it would never be included in its own population. For example, a valve within a piping population may have a deviation which.does not effect the safety-significance of the piping. However, if the valve was part of l ,
the valve population, the deviation may be considered safety-significant.
l This indicates that the attributes within multi-hardware populations may not be sufficient to address all aspects of the hardware within the population or that the safety significant evaluation is not consistent from one population to another.
Another area of staff concern is related to Adverse Trending.
The discussion in Appendix E is general in nature and uses as set of m-,- - - - - , .- -n-- . ,-w -.-n-,--.-w-r--v--------=--esre-
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- examples to define the process by which a set of items could create a pattern for concern. 'The examples given are related to a. design process. The approach used by the CPRT is to evaluate Homogeneous
- Design Activities (HDA) rather than to review the desig1 process. The concern is that evaluation of HDAs may not provide the appropriate information for trend'ing as defined in Appendix E.
2.4 Conclusions The Acceptance Criteria is acceptable subject to the satisfactory resolution of the following staff concerns:
(1) The techniques used and the extent of the safety significant evaluation must address each criteria which formed the basis for the original design.
(2) Safety significant evaluation of discrepancies related
[ t'o the self initiated design or construction program l and the potential for scope expansion must include evaluation using final plant documentation. This.does not preclude the fact that existing issues must be l~ evaluated for root cause and generic implication. -
(3) Attributes! within multi-hardware population must be sufficient to address the safety significance of all hardware within the population.
The staff believes that the concern related to HDAs providing sufficient data on design process trending can be easily implemented and can be confirmed during the implementation phase of the Plan.
3.0 CORRECTIVE ACTI0llS 3.1 Introduction
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-The NRC Staff ,coments on Revision 2 of the Plan expresse'd concern with the failure to provide criteria and guidelines to be used by the CPRT in defining corrective action and judging implementation of the corrective action by TUGCO. Revision 2 only addressed corrective action related to external source issues and did not provide a process for addressing corrective action resulting from self-initiated activities. Further, the TUGC0 corrective action system was an item of concern to the Staff which increased the necessity for CPRT involvement in implementation activities.
. 3.2 CPRT Approach Revision 3 of the Plan includes Appendix H. "CPRT Procedure and Policy for the Development, Approval and Confirmation of Imple-mentation of Corrective Action" which describes:
l the process through which corrective action will be defined l for deviations or deficiencies identified by the CPRT, the. process through which the CPRT third-party will review and approve the definition of corrective actions for all deficiencies and for certain categories of deviations identified by the CPRT, and the nature and extent of CPRT third-party confirmatory overviews of the implementation of defined corrective actions.
(1) Corrective Action Definition Once the individual CPRT RTL classifies a discrepancy as a deviation (failure to meet a design comitment or specification) or a l deficiency (a deviation determined to be safety-significant) the CPSES Project is responsible for:
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30/86 performing 10CFR50.55(e)reportabilityevaluations,
. defining ~ appropriate corrective action, obtaining CFRT RR concurrence in the defined corrective action for a safety-significant deficiency; programmatic deviation or deficiency;- design deviation involving failure
. to meet FSAR, licensing or regulatory criteria or commitments; and a deviation reportable under 10CFR50.55(e),
i The CPRT RR is responsible for determining the adequacy of the corrective actions submitted by the CPSES Project for review. . In the event that .the RR determines the proposed corrective action is inadequate and cannot resolve the situation with the Project, the SRT is responsible for resolving the concern. The Executive Vice President of TUGC0 is responsible for responding to the SRT with the TUGC0 position.
In addition, the CPRT RTL may reconnend proposed corrective action to the CPSES Project. SRT approval is required for CPRT reconnendations for corrective actions:
that are programmatic in nature, l to resolve safety-significant deficiencies, and l to resolve design deviations that could involve a change l to existing licensing or FSAR connitments.
(2) Overview of Implementation l 'The CPRT must be satisfied that, when implemented as defined, the CPSES Project corrective action will correct the nonconforming condition identified and, if applicable, will preclude the recurrence of similar conditions (in the future. The CPRT RR will be responsible for
30/86 performing con'firmatory overviews of the implementation of corrective action for which they were responsible for reviewing and approving.
These confirmatory overviews are intended to ensure that the corrective actions have been effectively implemented for each:
programmatic deviation or deficiency, safety-significant deficiency, design deviation involving a failure to meet FSAR and licensing comitments, and specific deviation that meets reportability criteria .
of10CFR50.55(e).
In general, the overview involves a revien of documentation.
In addition, where reinspection, is required fce corrective actions related to QOC. activities, the CPRT will either witness the reinspection performed by the CPSES Project or perform independent reinspection.
3.3 Staff Evaluation Revision 3 of the Program Plan provides- a comprehensive approach to the specification and approval of corrective action l
confirmation of implementation and responsibilities of the CPRT and the CPSES Project. ' The only major comment the staff has is related to the timing of SRT approval of CPRT RTL determination of the adequacy of l corrective actions defined by the CPSES Project. Appendix H provides two alternatives, I
approval on an ongoing basis as corrective actions are developed, or approval as part of the Action Plan Results Report approval process.
l The Staff feels that the SRT should approve (or disapprove) corrective actions on an ongoing basis as they are developed. This approval should l
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1/30/86 l follow that of the CPRT ,RTL. It is felt that this would keep the SRT more in line with CPRT-CPSES Project interfaces and reduce the potential for having the RTL and the CPSES Project involved in lengthy discussions when the RTL does not agree with the proposed corrective action.
3.4 Conclusions i
The CPRT Procedure and Policy for the docuinentation, approval and confirmation of implementation of corrective actions is comprehensive and is responsive to staff coments on Revision 2.
However, final acceptability is predicated on the SRT approval of corrective action immediately following ' approval by the CPRT RTL.
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II 1/30/86 5.0 DISCIPLINE INTEAFACES k'1 '
5.1 Introduction Staff review of, Revision 2 of the Program Plan expressed a number of concerns with Organizational Interfaces. These staff concerns can be placed into two categories:
(1) Interfaces within the CPSES design process. ;
(2) Interfaces within the CPRT organization.
The design and construction process requires transmittal of proper information across a number of interfaces. Failure to have a process in place which controls the transmittal of information and assures proper reviews and approvals can result in inadequte design and construction activity. Interface control must be provided between engineering and construction disciplines and between -engineering and construction activities. The scope of the CPRT effort, including the TUGC0 profect reanalysis activity, requires 'the same kind of interface control.
.5.2 CPRT Approach
, Revision 3 of the Plan includes Appendix F. "CPRT Interfaces",
which indicates that implementation of the Plan requires the establishment, execution and control of interfaces among the partic-1 pants. The principal participants for whom interfaces are defined by i the CPRT are:
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- TUGC0 Senior Management CPRT - SRT
- CPRT - RTL
- CPRT Program Director l
- CPRT Support Staff l -
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CPSES Project, including major subcontractors, QA/QC organization and project personnel.
The participant interfaces that are defined in detail are summarized in the following matrix.
CPRT MAJOR PARTICIPANT INTERFACES SRT RTL PROGRAM DIRECTOR TUGC0 MANAGEMENT X -
ST X X RR X X PROGRAM DIRECTOR X X SUPPORT STAFF X ADVISERS X CPSES PROJECT X X X NRC X X CYGNA X SAFETEAM 'X Detailed matrices are provided for the major organizational -
interfaces within the CPRT. A list of these follows:
QOC to DAP QOC to CPSES Project DAP to QOC DAP to CPSES Project DAP to Other Design Organizations RTL to Program Director RTL to CPSES Project RTL to DAP RTL to QOC
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Other CPRT interfaces are discussed in detail with individua1 responsibilities, extent' of the interface and documentation concerns provided. In addition, matrices of interfaces between CPRT and SWEC, and SWEC and other CPSES Project Organizations, are provided.
Three levels of responsibility are applicable to each item of information transmitted across an interface. The transmitting ,
organization has the responsibility for categorizing the item of information which automatically fixes the level of responsibility as defined by the appropriate matrix. The three levels of responsibility are: (1) Information, (2) Review and Coment, and (3) Action.
5.3 Staff Evaluation The definition of' interfaces provided in Appendix F is a significant improvement over the inforraation contained in Revision 2 of l the Plan. The availability of matrices will provide each affected o'rganization the specific areas and items of information that must be executed and controlled.
l There are a number of areas where interface between various CPRT organizations and CPSES project organizations is defined. In some cases, the interface appears to be duplicative and prime responsibility is not defined. It is important that prime responsibility for interface control be defined to assure that involved crganizations understand who is responsible for establishing, executing and controlling the interface.
The following are coments on the individual matrices provided in Appendix F.
- 1. QA/QC-RTL and DAP-RTL to Unit 1 and Unit 2 APGMs. It is understood by the Staff that responsibility for 50.55(e) reportability is assigned to the TUGC0 Project per Appendix H of the Plan.
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- 2. DAP-RTL to SWEC. Information on root-cause analyses, generic implications, Evaluation reports and Results-reports is provided to SWEC for "Information" when pertaining to the SWEC scope. Since this information could impact the SWEC analysis effort, it' should be provided for " Action by SWEC". . Since DAP is auditing SWEC activity, this matrix should address those items
- associated with that effort, including Corrective Action.
- 3. DAP-RTL to Other Design Organizations. Information on l root-cause analyses, generic implications, Evaluation reports and Results reports should be provided for
" Action" to E8ASCO and Impell, who are reanalyzing cable trays and supports. The CPRT may find it more appropriate' to develop a separate matrix for the cable i tray and support effort activities of EBASCO and Impell.
- 4. RTLs to CPSES Project. Action Plans are designated as both " Info" and " Action by Project". It is the Staff's opinion that Action Plans are provided to the CPSES Project for information only.
- 5. SWEC to Interfacing Organizations. Design- and construction-related concerns found during walkdown and document reviews should require action by DAP and QOC RTLs. That action should include evaluation of the deviation in the same manner as if it were discovered as part of the CPRT self-initiated program. Loading from l the piping system should be provided to QOC through the DAP since this information may be needed for safety -
significance evaluation.
, Since GtH will be the designer of record for piping and pipe supports, significantly more interfaces must exist I
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between SWEC .and G&H. For example, all analysts
< < results'must be provided to G&H for their acceptance.
Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and DAP-RTL and, EBASCO/Impell and Interfacir)g Organizations.
i 5.4 Conclusions l
[ The CPRT. Interfaces provided in Appendix F will be acceptable l for current CPRT activities provided the' following concerns are f satisfactorily resolved: ,
t (1) Define the organization with prime responsibility for I duplicative interfaces.
, (2) Information on root-cause analyses, generic implications, Evaluation reports and Results reports should be provided to SWEC, EBASCO and Impell since it could impact their reanalysis effort.
(3) Design- and construction-related concerns found during SWEC, EBASCO or Impell walkdowns and document reviews should be provided to DAP and QOC RTLs for " Action".
(4). Loadings from the piping system to equipment, structures, ',
penetrations, etc., should be provided to QOC through the DAP for use in safety-significant evaluations.
(5) Interface details (or matrices) should be provided for Other Design Organizations and DAP-RTL and for l E8ASC0/Impell and Interfacing Organizations.
(6) The CPRT auditing of SWEC activities involves interfaces l
which should be defined.
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(7) Interface between SWEC and G&H should be representative of G&H bei'ng designer of record.
The Staff believes that the concerns related to 50.55(e) and to Action Plan responsiblity in the RTL to CPSES Project Matrix are editorial in nature and can be confirmed during the implamentation pha.se of the Plan.
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