ML20210H393

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Rev 3 to Procedure CPP-014, for Collective Evaluation of Const Qa/Qc Program & of Quality of Const
ML20210H393
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/03/1986
From: Jackie Jones
EVALUATION RESEARCH CORP.
To:
Shared Package
ML20210F162 List:
References
CPP-014, CPP-14, NUDOCS 8702110420
Download: ML20210H393 (14)
v • d • e


Text

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EVALUATION RESEARCH CORPORATION

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COMANCHE PEAK RESPONSE TEAM PROCEDURE NO: CPP-014 REVISION: 3 EFFECTIVE DATE: 10-03-86 FOR 4

COLLECTIVE EVALUATION OF THE CONSTRUCTION QA/QC PROGRAM AND OF THE QUALITY OF CONSTRUCTION 1

PREPARED BY: DATE: 2d Ph p /

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APPROVED B

'0N ITE Q G fATIVE DATE: d[

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APPROVED BY: ee 06/OC REVIEW TEAM' LEADER DATE: 7b' I

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CPP-014 Rev. 3 1.0 PURPOSE

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This procedure prescribes the methodology for collective evaluation of the Construction QA/QC Program and of the Quality of.

Construction at Comanche Peak Steam Electric Station (CPSES) and delineates how interface relationships with other review teams are

. accomplished.

2.0 APPLICABILITY This procedure applies to the work performed by the QA/QC Review Team during collective evaluation of the overall adequacy of the Construction QA/QC Program and of the Quality of Construction at CPSES.

3.0 REFERENCES

3.1 CPP-018, "QA/QC Interface with the Design Adequacy Program" i

3.2 PAG-08, " Policy on CPRT Interfaces for Design and Construction j Discrepancies Identified by the ISAP RTLs" 3.3 CPRT Program Plan

( 3.4 CPRT Program Plan, Appendix E 4.0 GENERAL Implementation of Collective Evaluation is based upon the results i

of the CPRT Issue Specific Action Plans (ISAPs), and input from other applicable investigatory programs. The evaluation will assess the adequacy of the Construction QA/QC Program and will determine the Quality of Construction. Improvements to the Construction QA/QC Program related to future CPSES construction activities will be identified.

4.1 QA/QC Responsibilities 4.1.1 QA/QC Review Team Leader The'QA/QC Review Team Leader (RTL) has the overall responsibility for the collective evaluation of the CPSES Construction QA/QC Program and of the CPSES Quality of Construction, the interfaces with other RTL's and the approval of the final reports.

The RTL maintains close coordination and communications O

with other RTL's on matters that impact or relate to issues concerning the Construction QA/QC Program or Quality of Construction.

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. CPP-014 i Rev. 3 t p 4.1.2 Supervisor of Collective Evaluation Q

The Supervisor of the Collective Evaluation Group (CEG) who reports to the Deputy Program Manager of External Source Issues is responsible for assuring the implementation of this procedure. He directs the work involved in the collective evaluation. For this purpose, he is assisted by technically qualified -

persennel who will be assigned responsibilities for specific activities.

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He is responsible for the overall collective evaluation of issues concerning the Construction QA/QC Program and the Quality of Construction. He maintains coordination with other teams for issues relating to the Construction QA/QC Program and the Quality of Construction. Form CPP-014.1, Attachment 6.1, is used

  • to transmit design concerns that are found during ,

collective. evaluation to the QA/QC Interface Coordinator, and to other responsible personnel.

Inputs on issues concerning Construction QA/QC Program and the Quality of Construction are received from the Design Adequacy Program (DAP) via the OA/QC Interface Coordinator (References 3.1 and 3.2).

4.2 Pelicy 4.2.1 General Principles Activities performed under this procedure shall conform to the policies contained in the latest CPRT Program Plan, Reference 3.3.

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4.2.2 Personnel Qualification Requirements ~

Personnel participating in the implementation of this procedure shall be qualified in accordance with Section III.H. of Reference 3.3.

, 4.2.3 Delegations Should an activity be designated as the responsibility of the Supervisor of the CEG, the activity may be s

delegated to an individual under his supervision.

4.3 Conflicts In case of a conflict between this procedure and documents referenced in Section 3.0 the later shall govern.

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CPP-014 .

Rev. 3 4.4 Definitions 4.4.1 . General The definitions currently in Reference 3.4. shall apply to this procedure.

4.4.2 Collective Evaluation Collective Evaluation is an across-the-project assessment of the adequacy of the Construction QA/QC Program and of the Quality of Construction at CPSES.

This assessment will correlate the findings observations and conclusions drawn from results reports and other investigative programa that may become available. Additionally, these will be evaluated collectively to ensure that potential safety-significant trends implicit in the collective data that may not be apparent from the individual investigative activities are detected and delineated.

4.4.3 a M'trix As used herein, a matrix is a listing of external

! source issues correlated in such a way that each issued may be tracked to closure. The issues are obtained O from the external source documents listed in Attachment 6.2. In the matrix, each external source issue is. ,

l correlated to the appropriate ISAP or hardware population;-the appropriate criteria from 10CFR50, Appendix B; the appropriate classifications from SSER-11, Appendix P; the status of closure; and any needed clarifying comments.

5.0 PROCEDURE 5.1 General This procedure will be implemented in two phases, Phase I and Phase II. Although the work to be accomplished in each phase is distinct there may be some overlap in timing.

Phase I is comprised of the collection, review and evaluation j of issues contained in the external source documents listed in Attachment 6.2 to obtain information applicable to'the matrix.

Also, during Phase I, the matrix shall be constructed.

Phase II consists of the collection, re'iew, v and evaluation of all ISAP Results Reports and results from other applicable investigatory programs to determine the overall adequacy of the Construction QA/QC Program and of the Quality of O Construction. Additional Construction QA/QC program or 4

. CPP-014 Rev. 3 (O) hardware' issues which are identified from these reviews and evaluations as areas of concern shall be evaluated further and the results of these evaluations included in the final conclusions.

5.2 Phase I - Development and Evaluation of Matrix Informacion.

i Each external source issue is cataloged in the matrix.-

They are listed by the issue number, subject matter and

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referenced to the associated ISAP(s), DSAP(s) and Population (s). All issues are listed even though they may have been closed.by the initiator. This allows consideration for trending items that may not appear in a results report. The status of the issues is recorded in the remarks column. As issues are addressed by results reports the remarks column will be updated to reflect the findings. The complete status of the issues and how they relate to ISAPs, DSAPs and j Populations can be tracked by this system.

5.2.1 Responsible CEG personnel shall take the following actions to construct the matrix:

a. Review each document of Attachment 6.2 and

' identify Construction QA/QC Program and hardware '

. issues and itemize each issue on the matrix,

b. Utilize Appendix "P" of the NRC's SSER-11 to help classify issues.
c. Indicate on the matrix format the criteria from i 10CFR50, Appendix B for each valid concern when j applicable.
d. Review each action plan of Attachment 6.3 and I

identify the applicability of its scope to the specific issues on the matrix. Include the ISAP 1

number on the matrix with the applicable issues.

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e. Review the matrix information to determine j whether all issues are covered by existing ISAP's.
f. Advise the Supervisor of Collective Evaluation of the results of the review indicating any issues that are not covered, or inadequately covered.

't 5.2.2 The matrix'is designed to be updated throughout the 4

implementation of Phase II. All new inputs or requirements will be reviewed for inclusion in updating l the matrix. Working copies of appropriate parts of the matrix will be distributed to Issue Coordinators (I/C's) and RTL's for assistance in completing their action plans and to form a basis for interfacing activities and communication between I/C's, RTL's and collective evaluation personnel.

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, CPP-014 Rev. 3

.() 5.2.3 The Supervisor of Collective Evaluation, shall review the issues from external sources which either have been c, overed inadequately by action plans or which have no coverage and shall determine whether:

a. Information from another source is available which clearly shows the issue to be invalid.
b. Further evaluation is required and whether that evaluation shall be specified in a new ISAP, in a revision to an existing ISAP, or by a memorandum for the' record.

The Supervisor of Collective Evaluation shall forward these recommendations to the QA/QC RTL for approval.

5.3 Phase II - Review / Evaluation of ISAP Results and Other Investigative Program Results.

5.3.1 Implementation of this phase is dependent upon completion of ISAP Results Reports as issued by the RTL's. As these reports become available, CEG personnel shall:

a. Obtain a copy of each ISAP Results Report and the

/N results from other investigative programs which -

(_-) become available and are applicable to the '

issues.

b. Review the ISAP Results Reports and the results of other investigative programs and determine that:

l Required QA/QC program and hardware adverse trends, deficiencies, and corrective actions have been identified Deviations have been discussed.

Safety significance of identified deficiencies has been specified.

Root causes and generic implications of identified deficiencies and adverse trends have been discussed.

Actions to prevent recurrence of deficiencies and adverse trends have been delineated.

Additional problems or potential problems affecting Construction QA/QC Program or the Quality of Construction from the O inter-relationships of ISAP Results Reports have been identified.

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. CPP-014 Rev. 3 j' -

External source issues applicabic t> the s- /

scope of ISAPs and other investigattve programs have been addressed.

5.3.2 If the evaluation in Section 5.3.1 above indicates less i

than complete information in the reports 'or indicates additional or potential problem areas, the Supervisor of Collective Evaluation shall notify the QA/QC RTL who shall notify the cognizant RTL and Issue Coordinator. -

The QA/QC.RTL and cognizant RTL will resolve the concerns by:

a. Recommending a new ISAP or a revision to an existing ISAP to the Senior Review Team if further evaluation is required.
b. Justifying that no further activity is required.

The primary reason that further evaluation would

, not be required would be that information is available which clearly shows the issue to be invalid.

5.3.3 When all.information from Resulta Reports and other Program data has been collected per Sections 5.3.1 through 5.3.2 the CEG will perform the collective j evaluation process by disciplines /10CFR50, Appendix B criteria so that they may cross relate the information that is common.

t The evaluations will utilize the process outlined by Attachment 6.4.

5.3.4 Issues that were identified and then subsequently addressed by the external sources that identified the issues will be considered for information during collective evaluation. .

i 5.3.5 The collective evaluations may identify potential generic implications not previously documented and may require the performance of additional inspections or

! document reviews.

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5.4 Reports 5.4.1 Three reports will be written as a result of the implementation of Phases I and II of this procedure.

These reports will encompass the following topics as delineated in Reference 3.3, Appendix B.

a. A Collective Evaluation Report related to the

' adequacy of the CPSES Construction QA/QC Program, including the identification of any necessary improvements related to future CPSES construction activities and plant operations.

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CPP-014 Rev. 3

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b. A Collective Evaluation Report related to the Quality of Construction at CPSES, including the identification of corrective actions necessary to resolve any construction deficiencies and adverse

, trends. Recommendations will be made to prevent recurrence.

c. 'A Summary Report that integrates the results of the two Collective Evaluation Reports and sets forth the CPRT conclusions.

5.4.2 Each report will summarize the following:

a. Deficiencies, adverse trends and associated root cause(s) and generic implications.
b. Corrective action required to resolve deficiencies and adverse trends and recommendations to preclude .

recurrences during the remaining work on Unit 2.

c. The adequacy of the CPSES Quality of Construction and the Construction QA/QC Program including any recommendations for improvements related to future CPSES construction.

5.5 Records The CEG will maintain files which reflect the records and documentation required to accomplish the collective evaluation tasks.

6.0 ATTACHMENTS 6.1 CPRT Data Collection Form 6.2 External Source Document List j 6.3 CPRT Action Plan Review List 6.4 Collective Evaluation Flowsheet l

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Attachm nt 6.1 CPP-014 Rev. 3 Page 1 of l' CPtf CA/OC OATA COLLECT!0N FCRM TO: TECH:

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T:Ttta REY. DATE:

ACTION RIQUESTE:

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CPP-014.1 i si s is i ii. -

Attachment 6.2 CPP-014 Rev. 3 Page 1 of 1 EXTERNAL SOURCE DOCUMENT LIST

,. 1. NRC-TRT Evaluation Letters Dated September 18, 1984 i

Dated November 29, 1984 Dated January 8, 1985 i

2. NRC' Safety Evaluation Report (NUREG 0797) Supplements SSER 7 SSER 8
SSER 10 SSER 11
3. Other Reports / Documents i NRC SIT Report - February 15, 1983 _

NRC CAT Report - April 11, 1983 l

  • i NRC Special Review Team Report - April 1984

( NRC Regica IV Inspection Reports CYGNA Independent Assessment Program Report Concerns associated with matters in contention before the ASLB for CPSES Technical Allegations raised in the NRC HITS Docket Lobbin Report - February 4, 1982 MAC Report - May 17, 1978 Teledyne Report - February 21, 1985 i.

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Attachment 6.3 CPP-014 Rev. 3

'b/"] Page 1 of.3 CPRT ACTION PLAN REVIEW LIST ISAP No. Subject Matter l I.a.1 HeatShrinkdbleSleeves I.a.2 Inspection Reports on Butt-Splices I.a.3 Butt-Splice Qualification I.a.4 Agreement Between Drawings and Field Terminations I.a.5 NCRs on Vendor Installed Amp Terminal Lugs i .

j I.b.1 Flex Conduit to Flex Conduit Separation I.b.2 Flexible Conduit to Cable Separation I.b.3 Conduit to Cable Tray Separation I.b.4 Barrier Removal I.c Electrical Conduit Supports

'I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Tests I.d.3 Craft Personnel Training

( II.a Reinforcing Steel in the Reactor Cavity i

II.b Concrete Compression Strength II.c Maintenance of Air Gap Between Concrete Structures II.d Control Room Ceiling II.e Rebar in Fuel Handling Building III.a.1 HFT Date Packages

[ III.a.2 JTG Approval of Test Data i

III.a.3 Tech Specs for Deferred Tests III.a.4 Traceability of Test Equipment III.b Conduct of CILRT III.c Prerequisite Testing i

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i Attachment 6.3 CPP-014 Rev. 3 0 .

CPRT ACTION PLAN REVIEW LIST ISAP No. Subject Matter

III.d Preoperational Testing
i. IV.a Surveillance Program for Coatings

. V.a Skewed Welds in NF Supports

V.b Shortening of Anchor Bolts V.c Piping Between Buildings '

( V.d Plug Welda l

! V.e Installation of Main Steam Piping j

VI.a- Insulation / Shield Wall Gap VI.b Polar Crane Shias i

VII.a.1 Material Traceability iO

( VII.a.2 Non-Conformance and Corrective Action Systems i

VII.a.3 Document Control VII.a.4 Audit Program and Auditor Qualification ,

VII.a.5 Periodic Review of QA Prograa .

VII.a.6 Exit Interviews VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation l

VII.a.9 Adequacy of Purchased Safety Related Equipment and Material VII.b.1 Onsite Fabrication VII.b.2 Valve Disassembly d

VII.b.3 Pipe Support Inspections VII.b.4 Hilti Anchor Bolts Installation l VII.c Construction Reinspection / Documentation Review Plan 2

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Attachment 6.3  !

CPP-014 l Rev. 3 CPRT ACTION PLAN REVIEW LIST DSAP No. Subject Matter VIII

  • Civil / Structural Discipline L

VIII.g

  • Component Design Evaluation IX
  • Piping Pipe Supports X
  • Mechanical Systems and Components DSAP XI
  • Electrical /I&C Systems and Components
  • DAP - Info only O

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O O Other 15AP Population i

l Results Reports Reports e I

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! Out-of Scope Deviation g5, gg,,

! Review Reports Reports Review +

1 (ClassiEed) (ClassiEed) Results Report I I i 1 r i r 10CFR58 Appendix 8  ; Database  ; Review items i r 1 r Evaluation Evaluation QAlQC Hardware Consolidatec A* Port Report Collective Evaluation.

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Flowsheet  !!SE Report

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