ML20210S804

Marked-up SER Re Rev 3 to Comanche Peak Response Team Program Plan

ML20210S804
Person / Time
Site:	Comanche Peak
Issue date:	02/18/1986
From:	NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20209F938	List: ML20209F931 ML20209F978 ML20209G009 ML20210S689 ML20210S767 ML20210S785 ML20210S804
References
FOIA-86-657 NUDOCS 8610080232
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Text

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SAFETY EVALUATION REPORT RELATED TO COMANCHE PEAK RESPONSE TEAM (CPRT)

PROGRAM PLAN, REVISION 3 g OO g 2 860924 QARDE86-657 PDR 02/18/86 h00797 TC AP

i TABLE OF CONTENTS E9Let

ABSTRACT .............................................................

CONTRIBUTORS .........................................................

AC RONYMS AND ABB REVI ATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 I. EXECUTIVE

SUMMARY

II. DESIGN ADEQUACY AND CONSTRUCTION ADEQUACY COMMON ELEMENTS .......

III. STAFF EVALUATION OF DESIGN ADEQUACY PLAN ........................

IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN ..................

j V. REFERENCES ......................................................

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ABSTRACT

@i-The Safety Evaluation Report on the Comanche Peak Response Team (CPRT) Program Plan for the Texas Utilities Generating Company application for a license to operate Comanche Peak, Unit 1 and 2 (Docket Nos. 50-445, 50-446), 1ccated in Somervell County, Texas, has been prepared by the Office of Nuclear Reactor Regulation and the Comanche Peak Technical Review Team (TRT) of the U.S. Nuclear Regulatory Commission (NRC). Subject to acceptable resolution of the areas '

! identified in the subject evaluation, the staff concludes that the CPRT Program Plan, if adequately implemented, will provide an acceptable assessment of the Plant's design and construction adequacy. M 02/18/86 NUO797 TC

I. EXECUTIVE SUMARY TABLE OF CONTENTS Pag 1.0 Introduction ....................................................

2.0 CPRT Program Plan Description ...................................

2.1 Design Adequacy Plan (DAP) ................ ................

2.2 ConstructionAdequacyPlan(CAP)...d/N...b.C............

b 3.0 Summary Evaluation ..............................................

4, .. .r 3.1 Design Adequacy Plan .......................................

3.2 Construction Adequacy Plan .................................

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p. 3 4.0 Summary Conclusions .............................................

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)/ 4.1 Design Adequacy Plan .......................................

) 4.2 Construction Adequacy Plan .................................

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+st , 5. 0 Outstanding Issues ..............................................

5.1 Design Adequacy Plan .......................................

hg! Construction Adequacy Plan .................................

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) 5.2 Confirmatory Issues .............................................

[h , p, l I.0 6.1 Design Adequacy Plan .......................................

6.2 Construction Adequacy Plan .................................

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1. EXECUTIVE

SUMMARY

1. 0 Introduction The U.S. Nuclear Regulatory Commission's (NRC's) Executive Director for Operations established on March 12, 1984, a program to assure that technical concerns and allegations related to Comanche Peak Steam Electric Station (CPSES) design and construction activities would be p-addressed in a coordinated and integrated manner by the NRC staff. As a '

means of executing its programmatic responsibilities, the NRC W mche; .

-Py' "a t t n, h TechnicalReviewTeamf(TRT)representingthe N following disciplines: 9 Electrical / Instrumentation Civil / Mechanical QA/QC Protective Coatings Testing Programs Miscellaneous The TRTs initiated a series of onsite inspections and evaluations in July 1984, and documented the rrcults of these activities in five supplements to the Comanche Peak Safety Evaluation Report.

In response to the concerns and issues identified by the TRTs. Texas Utilities Electric Company (TUEC) formed the Comanche Peak Response Team (CPRT) for the purpose of addressing all TRT concerns. The CPRT, in response to TUEC direction, submitted if, October 1984, its initial Program Plan which included Issue-Specific Action Plans (ISAPs). TUEC, in Revision 2 to the Program Plan, h expanded the CPRT scope to address all issues identified by external sources and has also committed to perform self-initiated evaluations of design adequacy and quality of construction. Specifically, Revision 2 of the CPRT Program Plan 4 %

intended to address all NRC concerns and demonstrate the quality of design and construction. The Program-Plan s -esWsed, he Uie foiiowing principal objectiven .

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Evaluate and recommend solutions for all issues raised by the TRT, ASLB, SSER, CAT, SRT, SIT, Region IV, Intervenors, Applicant and CYGNA IAP.*

Determine root cause and generic implications of each found safety significant deviations or trend of non-safety significant deviations.

-deviations. .'

Perform self-initiated evaluations for the purpose of assuring that gg there are no undetected a'nd uncorrected safety significant

.\ s deficiencies at CPSES.

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The CPRT's role through this Program Plan is to develcp and implement a program designed to resolve issues and determine root cause and generic implications of each safety significant deficiency and trends of non-safety significant deviations and for the self-initiated evaluation of the quality of construction and adequacy of design. CPRT is also charged with advising TUEC management as to that CPSES has been designed, constructed, and tested in a manner which assures it can be operated without undue risk to public health and safety.

The NRC staff reviewed the Comanche Peak Response Team Program Plan, rammatic and detailed concerns provided TUEC in Revision Augus 2, with and Septemb prog ,$respectively.

1985 TUEC responded to the staff's concerns by letter dated November 22, 1985, and by Revision 3 to theCPRTProgramPlag Since the completion of its review of Revision 2 to the CPRT Program Plan, the staff continued its evaluation with numerous audits and concluded this review phase with detailed examination of Revision 3 to the Plan. This-SSER describes the staff's evaluation of the CPRT Program Plan through Revision 3. It addresses the scope, approach, and evaluation aspects of the plan.

Region IV will inspect and audit the implementation of the Plan for those areas related to construction quality and reflect any finding it may have ,

in periodic inspection reports. Self-initiated design aspects of the Plan

• Acronyms are defined on page iii of this report.

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will be inspected and audited by the Office of Inspection and Enforcement with the results also documented in periodic inspection reports. .NRC N U-will continue its effort by reviewing and auditing the root cause and generic implication evaluations, the conclusions drawn from these evalu-ations and adherence by CPRT to implementation of the overall process described in the Program Plan.

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2.0 CPRT Program Plan Description The CPRT Program Plan, Revision 3, is the TUEC document which describes the scope and method of operation of the Comanche Peak Response Team. The responsibilities of the Comanche Peak Response Team include the resolution of all open issues, the identification of the root cause of each found safety significant deficiency or trend of non-safety significant deviations and the completion of a self-initiated evaluation of the design adequacy

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aaMonstruction cuality of CPSES.VThe Program Plan itself includes the CPRT charter, program principles, structure, methodology, process and organization. Three appendices form the nucleus of the Program Plan.

Appendix A addresses the design adequacy aspects of the Program Plan. The quality of construction and the adequacy of the QA/QC program are addressed in Appendix B. All individual issue and discipline specific action plans are included in Appendix C. ,

=dn - - '- =r All evaluatio~ns are performed using a similar process regardless of whether itisadesign,constructionoraveryfocusedisshevaluation. This process is initiated by defining the scope and methodology for the topic or issue to be evaluated. Procedures and checklists are then developed as guidance for the reinspection effort and document review. All relevant standards and applicable acceptance criteria are reflected in the develop-ment of checklists. Any discrepancy identified during the reinspection reevaluation or document review process are evaluated for their safety significance. Further, root cause evaluations are performed and a deter-mination regarding potential generic implications is made for each identi-fied discrepancy. Finally, corrective actions are identified as are actions designed to preclude recurrence in the future.

While the process for evaluation is identified in each issue 4 pecific or discipline-specific action plan, the output from this effort will be docu-mented in individual results reports. Each results report will identify any found deficiencies along with the evaluation of these deficiencies.

The results of individual issue specific evaluations are collectively evaluated within the construction quality and design adequacy programs.

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A Summary Report for each discipline area will be prepared summarizing the results of the effort and fulfillment with the objectives of the CPRT Program.

2.1 CPRT Design Adequacy Program Plan The Design Adequacy Program Plan (DAP) is the CPRT's approach for evaluating and resolving a number of concerns regarding the adequacy of

. the CPSES design and design process. Its objective is to provide assurance that there are no undetected safety significant errors in the CPSES design. The CPRT intends to accomplish this objective by performing the following three activities:

a. Evaluation of specific design and programmatic designs process issues raised by external sources.

b. Investigation of the the root cause of each found safety significant deficiency.

c. Performance of a self-initiated evaluation of selected additional design areas.

External source issues are addressed by an independent documentation review of the design methodology and process related to each issue. This includes drawings, calculations, specifications, acceptance criteria, and procedures.

The self-initiated evaluation is performed by categorizing the design activities into the following specific disciplines:

a. Electrical, Instrumentation and Control Systems and Components.

b. Mechanical Systems and Components.

c. Civil and Structural

d. Piping and Supports.

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A Discipline Specific Action Plan (DSAP) describes the scope of each discipline and the approach for evaluating each discipline. Each DSAP includes the categorization of design activities within each discipline and the refinement of these groupings into homogeneous design activity groupings. Items from each homogeneous design activity (HDA) will be evaluated. The auxiliary feedwater system is the focus of this review activity but items from other systems will be selected to assure that all design activities are reviewed and represent a level of complexity typical of the design process. Results of specific reviews provide the basis for conclusions made regarding the design process. The basis for extrapolation of specific reviews to other systems is the homogeneous nature of the design activities and the level of complexity of the activities selected for review. Results reports and a final design adequacy program report will document the implementation of the DAP and the resulting conclusions.

Piping and pipe supports design are not addressed by the DAP in the manner described above because a complete reevaluation of this area is being performed by Stone and Webster Engineering Corporation (SWEC). The work of SWEC and other outside organizations performing in a similar manner will be reviewed by the CPRT.

All identified deficiencies will be evaluated individually for its safety significance as will trends of nonsafety significant findings.

Summary reports will be prepared for each discipline. An evaluation of the overall adequacy of the-CPSES design and design process will be made by integrating the results of the individual discipline specific action plans. This evaluation will be reported in the final design adequacy program report.

2.2 CPRT Construction Adequacy Program Plan The adequacy of the construction QA/QC program and the quality of con-struction performed within scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC with responding to and resolving these concerns. The CPRT's 03/10/86 I-6 NUO797 SEC I

4 construction adequacy program is designed to evaluate questions concerning construction QA/QC and the adequacy of installed hardware.

Specifically, the CPRT's objectives' for the construction adequacy program are to fully resolve all of the external source issues, assess in an inte-grated fashion all identified safety significant deficiencies and to make a statement about both the adequacy and quality of construction at CPSES.

The CPRT's program has the following three components:

a. Evaluation of external source issues,

b. Root cause evaluation and generic implication assessment for each ,

i identified safety significant deficiency or trend of nonsafety sig-l nificant deviations, and

! c. Self-initiated reinspection of a sample of the balance of the hardware within the scope of the QA/QC program.

Issue-specific action plans (ISAP) document the CPRT plan for resolving each external source issue. All construction QA/QC issues,whether of a hardware nature or a QA/QC programmatic concern, will be the subject of an j issue-specific action plan. A single ISAP describes the process and methodology for the CPRT's self-initiated hardware reinspection and docu-mentation review. A matrix is then developed to provide a cross reference between each issue or concern and the respective action plan which addresses

! it. This matrix provides assurance that all external source issues have been addressed by the CPRT.

3 The self-initiated construction reinspection / documentation review program is designed to collect information on the quality of construction work activities at the Comanche Peak Steam Electric Station. Construction activities are divided into the following three areas:

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This program consists of a sample reinspection of QC-accepted safety related construction work supplemented by review of. related quality documentation for nonrecreatable in process inspections. Both units and the common areas are being addressed by this program. The methodology used for const"ruction evaluation is to first categorize the installed safety related hardware into populations made up of homogeneous work activities. Samples will be selected from these populations and the work activities evaluated for the quality of construction. Two samples will be selected from each r,opulation for evaluation. First, a purely random selection will be made from the complete population. Then, engineered samples will be selected at random by expanding the initial sample to ensure evaluation of a like number of items located in systems required for safe shutdown. Items will be evaluated using checklists and inspec-tion procedures developed from the original installation documents. All deviations will be identified and evaluated to determine their safety significance. The totality of the information will be evaluated for adverse trends. Results will be documented in results reports which will document the inspections of individual populations and well as the overall results of the construction adequacy evaluation effort.

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l II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PLAN COMON ELEMENTS

II. CPRT DESIGN AND CONSTRUCTION ADEQUACY PLAN COMMON ELEMENTS TABLE OF CONTENTS PaSe

1. QA/QC Activities ................................................

1.1 Introduction ...............................................

1.2 CPRT Approach ..............................................

1.3 Staff Evaluation ...........................................

1.4 Conclusions ................................................

2. Acceptance Criteria ............. ...............................

2.1 Introduction ...............................................

2.2 CPRT Approach ..............................................

2.3 Staff Evaluation ...........................................

2.4 Conclusions ................................................

3. Corrective Actions .... .........................................

3.1 Introduction ............ . ...............................

3.2 CPRT Approach ..............................................

3.3 Staff Evaluation ...........................................

3.4 Conclusions ......... ......................................

4. CPRT/SRT Independence ...........................................

4.1 Introduction ...............................................

4.2 CPRT Approach ..............................................

4.3 Staff Evaluation ...........................................

4.4 Conclusions ................................................

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TABLE OF CONTENTS (Continued) fagg a

5. Interfaces:......................................................

, 5.1 ' Introduction ...............................................

5.2 CPRT Approach ..............................................

1 5.3 Staff Evaluation ...........................................

5.4 Conclusions ................................................

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1.0 QA/QC 0F CPRT ACTIVITIES 1.1 Introduction "The CPRT has been organized to consist of independent, third party experts who will advise TUGC0 of existing plant conditions, and who will make recommendations for the resolution of any problems which may exist." ^

The Program Plan, Revision 3, Appendix G entitled "CPRT-Third Party Quality Qy .0 '

Assurance Program" was developed in response to direction from the CPRT, Se:nior  !

Review Team (SRT) and is founded on the importance and scope of the third party Q\\ * (-

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1.2 CPRT Approach The CPRT QAP is structured in line with the three categories of CPRT activities.

A separate program is provided for each activity.

(1) Overall Responsibility Overall responsibility for the quality of CPRT activities resides with the SRT. ,~,

This is accomplished in the following manner: f 3 .

- SRT will receive the results of all audits of CPRT activities, d

- SRT will 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 Committee.

(2) Issue-Specific Actions Plans - QA Elements .

It is the position of the SRT that the principles of the CPRT Program Plan, the CPRT Policies and Guidelines and the implementation requirements specified in each ISAP generally provioe the QA elements

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necessary for ISAP activities. Supplemental instructions were prepared 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 10 CFR 50, 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 Procedures and of Action Plants Section 5.3 and Drawings each ISAP 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 15 Non-conforming CPRT Program Plan Section III.k Conditions and Policy for Conduct of Action Plans (Section 5.5) 16 Corrective Action CPRT Program Plan Section III.k and General Policy for Conduct of Action Plans Section 5.5 17 QA Records CPRT Program Plan Section III.j and Guide on Central and Working Files 18 Audits Checks of the activities per-formad under TRT ISAPs are accom-plished by Review Team Leader overview of activities (CPRT Pro-gram Plan Section VIII.b.3); the reviews and audits conducted by the CPRT Results Report and File Review Committee (Attachment 4 to CPRT Third-Party QA Program);

and SRT review and approval of Results Reports (CPRT Program Plan Section VIII.b.1) 03/10/86 II-2 NUO797 SEC II

In addition to the generically applicable guidance listed above, the direction provided by specific ISAPs implement measures of other QA elements (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 Quality of Construction (QOC) activities and addresses the following 10 CFR 50, 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 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 Manager of Quality Assurance and are respon-sible for identifying and reporting on the status of the quality program by conducting surveillances of the QOC activities. The results of these surveil-lances 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 requirements. The Division Manager of Quality Assurance is organizationally independent from the CPRT.

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(4) Design Adequacy Program A Quality Assurance Program has been developed for the DAP activities and ad-dresses the following 10CFR50, Appendix B Criteria:

Criteria Title 1 Organization 2 Quality Assurance Program 3 Design Control 4 Procurement Document Control 5 Instructions, Procedures and Drawings 6 Document Control 7 Control of Purchased Material, Equipment and Services 15 Nonconforming Materials, Parts or Components 16 Corrective Action 17 , QA Records 18 Audits In addition, should activities in the areas of Inspection, Testing or Measuring, and Test Equipment be required appropriate Quality Assurance requirements will be established or subcontractors with applicable Quality Assurance Programs will perform the activity.

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.

1.3 Staff Evaluation The Quality Assurance Program provided by Revision 3 of the Plan establishes a level of program quality commensurate with the activities of the CPRT.

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(1) Overall Responsibility

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Overall responsibility for the quality of CPRT activities is with the SRT.

Results of audits and corrective action in each category are provided to the SRT. The program for implementation of audits needs to be detailed with re-spect to frequency, type, areas, technical assistance, reporting and distribu-tion for those QA audits that will be performed by (or for) the SRT. These audits are important to assure SRT QA involvement and control that is commen-surate with their responsibility. Sufficient experience in Quality Assurance requirements is available in the SRT to understand the magnitude of audit find-ings, 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 B Criteria applicable to all ISAPs are provided in the various sections of the Program Plan and Policies. In addition, individual ISAPs implement measures of other QA criteria as they are 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 and instruments, and Criterion 12 provides assurance that instru-ments 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 A formal QA Program is provided for the QOC activities. Eleven criteria of 10CFR50, Appendix B, are addressed in the QOC QA Program. However, Criterion 12, Control of Measuring and Test Equipment is not a part of the QOC QA Program.

QOC personnel will be performing inspections which include measurement, there-fore it is important that the tools, gages and instruments used are properly calibrated and controlled. Adoption of, Criterion 12 by QOC will assure that

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this occurs. ~

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l QA activities are the responsibility of the 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 organizationally removed from all CPRT activities, and the Project Assurance Group non-QA activi-ties are essentially Engineering Inspection Assurance activities, QA activities are sufficiently removed from day-to-day inspection and evaluation activities.

Since SRT retains overall responsibility for quality implementation of the CPRT t n

activities, the QOC organization chart (Figure 2.1) should indicate that the t/ 1 ERC Division Manager of QA has reporting obligations to the SRT.

(4) Design Adequacy Program -

S5 A formal QA Program is provided for DAP activities. Eleven criteria of 10CFR50, 3~

Appendix B, are addressed in the DAP QA Program. 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 10 CFR 50, Appendix B.

DAP QA responsibility resides with the DAP QA Manager who reports directly to the Design Adequacy Review Team Leader. Although 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 to 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 cable trays are being performed by the Comanche Peak project. Since the organizations performing the reanalysis activities are 03/10/86 II-6 NUO797 SEC II

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I' implementing their own QA Programs, subject to TUGC0 audits, it is important that the 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 sdeple 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 suffi-cient data is obtained and that the quality of the data is acceptable. In the area of cable trays and supports, a complete walkdown is being performed by Ebasco/Impell to develop as-built geometry prior to analysis. It is critical 4

that DAP assure that the quality of this as-built data is acceptable.

1.4 Conclusions l The CPRT QA Program provided in the Program Plan is acceptable for the current CPRT activities. During implementation of the Program Plan the staff will confirm that the following staff requirements have been satisfactorily resolved:

(1) Details as to frequency, type, areas, technical assistance, reporting and distribution of QA audits, including audits of ISAP activities, must be provided.

(2) Revise Figures 2.1 (QOC Organization Chart) and Figure 1 (DAP Organization ,

Chart) to indicate reporting responsibility of the QA manager to the SRT.

(3) Describe how the DAP QA Program is to be implemented to assure the quality I

of as-built data obtained for extensive reanalysis programs.

(4) The Program Plan must address how 10 CFR 50, Appendix B, Criteria 10 and 12 will be implemented for those activities in 1 SAPS, QOC and DAP where applicable.

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2.0 ACCEPTANCE CRITERIA -

2.1 Introduction As the CPRT Program Plan is implemented, discrepancies will be identified between the intended and actual design or construction details of the CPRT. These dis-crepancies will vary widely in importance. It is essential to a vertification or reinspection program to be effective that a systematic procedure be estab-lished and implemented to assure that they are all properly evaluated, both individually and collectively, to identify safety signifiance, root causes, generic implications and corrective action.

2.2 CPRT Approach f, Revision 3 of the Program Plan includes Appendix E, "CPRT Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Dis-crepancies 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 classi-fication 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 programmatic discrepancies.

The approach to adverse trending of related observations, deviations or defici-encies indicative of a pattern exhibiting a discernible commonality Ar6 provided.

13 Root cause and generic implications will be evaluated for all deficiencies and adverse trends. In addition, Appendix E provides root cause and generic impli-cation evaluation for special cases. For example, when a deviation results in a substantial loss of design margin a root cause and generic implication evalua-tion will be performed. Identification of special cases will be situation-spec-ific and canr.ot be generically defined.

2.3 Staff Evaluation The evaluation process defined in Appendix E does not provide sufficient de-tail on safety-significant evaluation. This concern is primarily related to the fact that safety-significant evaluations of discrepancies are currently 03/10/86 II-8 NUO797 SEC II

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underway using information, in some cases, that is being revised by the CPSES Project. (Two areas of major concern 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 optimization or deficiencies or, different design documents and values which 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 exist-ing issues which led to the current reanalysis of piping and cable trays must be evaluated for root cause and generic implication to assure that programmatic deficiencies do not extend beyond the boundaries covered by the reanalysis efforts.

,A second concern is related to the fact that safety- significant evaluations must be performed using Code or Regulatory approaches. That is, 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 committed to in the FSAR must be

addressed in order to establish margins on all segments of the acceptance cri-teria. Act.ual 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 is of the opinion that there the lack of discussion in the Plan on the approach to be used in root cause and generic implication determination. In order to understand any CPRT proposed evaluation, the Plan needs to define the terms " root cause" and " generic implication." This is critical, since the depth and breadth of the root cause evaluation will be a function of the CPRT understanding of these terms. The staff anticipates that the CPRT will consider the following, as a minimum, in determining the root cause of deficiencies:

03/10/86 II-9 NUO797 SEC II

Personnel Process Procedures Design (as it effects construction)

Materials Management Another area of staff concern is related to Adverse Trending. The discussion in Appendix E is general in nature and uses a set of examples to define the pro-cess 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 design process. The concern is that evaluation of HDAs may not provide the appropriate information for trending as defined in Appendix E.

2.4 Conclusions The Acceptance Criteria is acceptable and during the implementation phase of the Program Plan the staff will confirm that the following staff concerns have been satisfactorily resolved.

(1) The techniques used and the extent of the safety significant evaluation must address each criteriu which formed the basis for the original design.

(2) Safety significant evaluation of discrepancies related to the self initiated design or construction program and the potential for scope expansion must include evaluation using final plant documentation. This does not preclude the fact that existing issues must be evaluated for root cause and generic implication.

l (3) The Plan must define the terms " root cause" and " generic implications" including those items to be considered in making these evaluations.

(4) The Program Plan must provide that design process as well as Homogenous Design Activities will be reviewed to determine an adverse trend.

03/10/86 11-10 NUO797 SEC II

3. 0 CORRECTIVE ACTIONS 3.1 Introduction The CPRT Program Plan provides for appropriate corrective action for all deviations or deficiencies identified during-the CPRT's verification and reinspection program. Corrective actions will be implemented by the CPSES Project. The extent of third party overview depends upon the nature of the 4

corrective actions and the third party's assurance that such activities are being properly implemented.

3.2 CPRT Approach Revision 3 of the Plan includes Appendix H, "CPRT Procedure and Policy for the Development, Approval and Confirmation of Implementation of Corrective Action" which describes:

the process through which corrective action will be defined for deviations or deficiencies identified by the CPRT, the process through shich 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 Review Team Leader (RTL) classifies a discrepancy as a deviation (failure to meet a design commitment or specification) or a deficiency (a deviation determined to be safety-significant) the CPSES Project is responsible for:

I performing 10CFR50.55(e) reportability evaluations, 1 defining appropriate corrective action, 03/10/86 II-11 NUO79'7 SEC II l

obtaining CPRT RTL concurrence in the defined corrective action for a safety-significant deficiency; programmatic deviation or deficiency; design deviation involving failure to meet FSAR, licens-ing or regulatory criteria or commitments; and a deviation reportable under 10 CFR 50.55(e).

The CPRT RTL is responsible for determining the adequacy of the corrective actions submitted by the CPSES Project for review. In the event that the RTL 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 recommend proposed corrective action to the CPSES Project. SRT approval is required for CPRT recommendations for corrective actions that:

a. Are programmatic in nature,

b. Resolve safety-significant deficiencies, and

c. Resolve design deviations that could involve a change to existing licensing or FSAR commitments.

(2) Overview of Implementation The CPRT must be satisfied that, when implemented as defined, the CPSES Project corrective action will correct the nonconforming condition identified and, will preclude the recurrence of similar conditions in the future. The CPRT RTL will be responsible for performing confirmatory 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:

a. Programmatic deviation or deficiency,

b. Safety-significant deficiency, 03/10/86 11-12 NUO797 SEC II

3. Design deviation involving a failure to meet FSAR and licensing commitments, and

4. Specific deviation that meets reportability criteria of 10 CFR 50.55(e).

In general, the overview involves a review of documentation. In addition, where reinspection is required for corrective actions related to QOC activities, the CPRT will either witness the reinspection performed by the CPSES Project or perform independent reinspection.

i 3.3 Staff Evaluation Revision 3 of the Program Plan provides a comprehensive approach to the specification and approval of corrective action confirmation of implementa-tion 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 corrective actions defined by the CPSES Project. Appendix H provides two alternatives, arproval on an ongoing basis as corrective actions are developed, or approval as part of the Action Plan Results Report approval process.

The Stafi feels that the SRT should approve (or disapprove) corrective actions on an ongoing basis as they are developed. This approval should 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 The CPRT Procedure and Policy for the documentation, approval and confirma-tion of implementation of corrective actions is acceptable. However, we require that the SRT approve corrective actions on an ongoing basis subsequent to approval by the CPRT RTL.

03/10/86 11-13 NUO797 SEC II l

1

4.4 Independence of the CPRT/SRT Organization 4.4.1 Introduction The Comanche Peak Response Team (CPRT) Program Plan, Revision 3, was initiated by the Texas Utilities Generating Company (TUGCO) to address concerns and issues raised by allegers, the NRC Technical Review Team's (TRT) inspection of the Comanche Peak Steam Electric Station (CPSES) and other external sources. The verification and corrective action program is a comprehensive, detailed and fully documented effort to determine the adequacy of the plant's design, con-struction, quality assurance and pre-operational testing.

An essential part of a verification program requires that the persons and organizations implementing the plan should have sufficient authority, organiza-tional freedom, independence, and objectivity to identify quality problems and to verify the implementation of solutions. Such persons and organizations per-forming quality assurance functions should report to a management level such that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations are provided as delineated in 10 CFR 50, Appendix B. In addition, the individuals assigned the responsibility for assuring any portion of a verification program should have direct access to such levels of management as may be necessary to perform their functions.

4.4.2 CPRT Approach The Applicant recognized the necessity for the objectivity of verification per-sonnel to implement a credible CPRT program. In this regard CPRT personnel had to meet specific requirements such as knowledge and experience, integrity, objectivity, no financial interest, and no previous involvement in the Comanche Peak Steam Electric Station (CPSES) project activities related to their CPRT activities. To meet this objective the CPRT developed a "CPRT Objectivity Questionnaire" that all personnel, except for clerical att certain administra-tive personnel were required to answer and sign. In the few cases where these objectivity criteria were not met, they would be promptly identified by the CPRT and provided to the NRC along with any necessary justification.

03/10/86 II-14 NUO791SECII

The organization for the CPRT effort is essentially all third party personnel except for the Senior Review Team (SRT) Chairman'and the CPRT Program Director.

These two individuals, while they are TUGC0 employees do not have any responsi-bility for the construction cost and schedule of the CPSES.

To further assure the objectivity, independence, and credibility of this effort I all the verification and corrective action activities will be performed under CPRT quality assurance programs that meet the requirements of 10 CFR 50, Appendix B.

In addition to the quality assurance program, the applicant has established an Overview Quality Team (0QT) to assure senior T'JGC0 management that the CPRT meets the objectives established for this verification program. The 0QT will not have any active part in the implementation of the CPRT program but will function as an independent audit group. The OQT will review the elements of I

the program to a depth and frequency as necessary to assure management that all the program directives are met. All necessary documents will be available to the 0QT as needed. The necessary auditors / inspectors and assistance will be provided to enable them to evaluate the implementation of the effort.

4 The CPRT program will be fully documented effort. In addition, public monthly

, progress meetings are held in the Arlington, Texas vicinity so that interested parties may review the progress of the verification effort. The applicant has committed, when the final Issue Specific Results Reports are filed with the NRC, to make them available at the site for public review along with the sup-porting documentation.

4.4.3 Staff Evaluation To determine that the independence of the CPRT effort met the requirements of 10 CFR 50, Appendix B and that there existed the required authority and organi-zational freedom, including sufficient independence from cost and schedule the NRC Staff reviewed the TUGC0 and CPRT organization charts and position descrip-tions, interviewed the managers and key personnel of the TUGCO, CPRT, SRT, Review Team Leaders and 0QT. In addition, the staff reviewed the work and experience resumes and the "CPRT Objectivity Questionnaires" of the managers, engineers and inspectors associated with the CPRT effort.

03/10/86 11-15 NUO79~7 SEC II l

i

A principal objective of these interviews and reviews, in the case of the CPRT managers and key personnel was to determine their attitude towards Quality Assurance, the necessity for it, and if there was any reason that they could not perform an independent and objective review.

4.4.3.1 Organization The overall charge to the CPRT is to advise TUGC0 management whether there is reasonable assurance that the Comanche Peak Steam Electric Station can be opera-ted without undue risk to the public. The organizational structure of the CPRT is a functional type organization that consists of a Senior Review Team which formulates policy and directs the activities of five Review Team Leaders for issue specific and discipline specific action plans.

The Chairman of the SRT is a TUGC0 employee, Mr. John Beck, a Vice President and Manager of Licensing. The five other members of the SRT are experienced senior engineers who are not,TUGC0 employees but are associated with independent consultant firms. The CPRT Program Director and an ex-officio member of the SRT is Mr. Terry Tyler, a TUGC0 employee. Both Messrs. Beck and Tyler were interviewed by the NRC staff, their position descriptions reviewed, and neither were found to have any responsibility for the project's construction cost and schedule. The interviews also indicated that both individuals were committed to perform a quality verification, were of the opinion that they could perform their duties objectively and independently and had direct access to senior levels of TUGC0 management if problems arose.

The Review Team Leader's duties are a critical component of the CPRT effort.

Each Review Team Leader is responsible tu ensure that the action plans within their areas are properly implemented an't results reports prepared in addition to their corollary administrative dutier,.

In addition to the umbrella Quality Assurance Program discussed in Section II, Item 1 of this report, which will be used for surveillances and audits of the CPRT effort, there is an Overview Quality Team consisting of four senior members who will periodically review, audit and comment to the*TPRPttnrmuun on activ- )b ,I ities, results and programs of the CPRT effort. The NRC staff interviewed the 03/10/86 11-16 NUO797 SEC II

CPRT Chairman, Review Team Leaders, SRT members and the Chairman of the OQT in order to determine their qualifications, experience and commitment to quality assurance, and their understanding of the functioning of the organization and were all committed to performing their duties in an objective and responsible manner. A series of five 1-week inspections was carried out by the NRC staff in the latter half of 1985. The CPRT organization was found to be functioning in an objective and sufficiently independent manner.

In addition to the interviews and reviews of the CPRT organization, the TUGC0 site construction organization was reviewed to determine whether responsibility for proj nt construction cost and schedule was not an area of responsibility for any members of the CPRT. The responsibility for cost and schedule was found to be directly vested in Mr. J. George, the Vice President and General Manager of the Comanche Peak Station Electric Project. Reporting directly to Mr. George are a Mr. R. Camp, Project Manager for Unit #1 and Mr. J. Merritt, Project Manager for Unit #2. These three individuals are directly responsible for the cost and schedule of the project and interviews with them indicated that they did not have any influence or impact on the CPRT verification effort.

These individuals are involved in the corrective action process only after the ,

CPRT recommends corrective action that requires modification or replacement of physical construction work. [

4.4.3.2 CPRT-Site Personnel Each site individual participating in the CPRT program was required by TUGC0 to answer and sign a "CPRT Objectivity Questionnaire." The purpose of the ques-tionnaire was to ascertain if the individual had any financial, previous employ-ment, or other interest in TUGC0 or Texas Utilities Electric Company subsidairies that would inhibit the individual from being completely objective and indepen-dent in the performance of the tasks assigned to him in the CPRT program. The NRC staff reviewed essentially all of the inspector objectivity questionnaires on file at the time of the inspection and the related work experience resumes.

In general, these were considered to be satisfactory. Three inspectors were identified who had previously worked for Brown & Root at the South Texas Project.

The NRC staff opinion in these three cases was that there was no apparent loss of objectivity or independence as a result of their previous employment and their current work assignments for the CPRT.

03/10/86 II-17 NUO797 SEC II

In addition to the reviews of inspector questionnaires and work resumes, the objectivity questionnaires and work reviews of essentially all CPRT managerial and key personnel were also reviewed. These personnel files were found to be satisfactory except for two members of the SRT and three key members of the '

CPRT. These individuals had previous contractural involvement with CPSES. ,f' Additional NRC staff review of this condition was made and the NRC staff deter , j" 7 mined that their prior employment would not result in any loss of objectivity ,61' or independence in the performance of their current assignments. k!)' i 4.4.3.3 TERA Personnel U ,

y In addition to the site personnel, TERA offsite personnel engaged in CPRT design verification activities were also required to answer and sign the objectivity questionnaires as previously described. The questionnaires and work experience resumes of TERA personnel were reviewed by the NRC staff and with one exception were found to be satisfactory. The staff was of the opinion that some of the TERA Civil / Structural and Mechanical Engineering personnel had limited or no commercial nuclear power plant design experience. This weakness was identified to TERA management and subsequent to the inspection the necessary corrective action was taken and 25 additional, experienced nuclear design engineers were added to satisfactorily reinforce those personnel performing the design verifi-cation activities.

4.4.4 Conclusion On the basis of its evaluation, the staff concludes that the persons and organi-zations performing the CPRT verification, evaluation and corrective action activities have sufficient authority and organizational freedom to identify quality problems and to initiate or recommend corrective actions. The indi-viduals and organizations performing the CPRT functions report to a management level such that there exists a required authority and organizational freedom, including sufficient independence from cost and schedule of construction of the project when opposed to safety considerations. The staff concludes that the persons and organizations implementing the CPRT program have sufficient authority and independence from cost and schedule and meet the requirements of Criterion I of 10 CFR 50, Appendix B.

l 03/10/86 11-18 NUO79'7 SEC II

Over and above the inherent independence and objectivity in the CPRT effort, the NRC has established a large overview team (approximately 40 engineers) that will conduct surveillances, inspections, over-inspections, design reviews, calculation reviews and audits of a significant sample of all CPRT activities. '

This NRC overview effort will assure that the verification effort is independent,

objective, and credible.

To date, numerous overview activities have occurred and have been documented and have been included in the monthly Region IV Comanche Peak inspection reports.

These reports are available for review in the public document rooms established for the Comanche Peak Steam Electric Station. It is the intent of the NRC staff to maintain a documented, verifiable, and auaitable trail of the CPRT activities.

While the present CPRT program is found to meet the requirements of 10 CFR 50, Appendix B, Criterion I, the applicant shall notify the NRC staff of any pro-posed changes in managerial or key personnel in the CPRT effort prior to its implementation, unless the changes are a result of work completion.

03/10/86 II-19 NUO797 SEC II

5.0 DISCIPLINE INTERFACES 5.1 Introduction 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 engineer-ing and construction activities. The scope of the CPRT effort, including the TUGC0 project 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 con-trol of interfaces among the participants. The principal participants for whom interfaces are defined by the CPRT are:

TUGC0 Senior Management CPRT - SRT CPRT - RTL CPRT Program Director CPRT Support Staff CPRT Advisers 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.

03/10/86 11-20 NUO797 SEC II

CPRT MAJOR PARTICIPANT INTERFACES SRT RTL PROGRAM DIRECTOR TUGC0 MANAGEMENT X SRT X X RTL 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 Other CPRT interfaces are discussed in detail with individual responsibilities, extent of the interface and documentation concerns provided. In addition, matrices of interfaces between CPRT and Stone and Webster Engineering Corpora-tion (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 re-sponsibility for categorizing the item of information which automatically 03/10/86 11-21 NUO79'7 SEC II

fixes the level of responsibility as defined by the appropriate matrix. The three levels of responsibility are: (1) Information, (2) Review and Comment, and (3) Action.

5.3 Staff Evaluation The definition of interfaces provided in Appendix F establishes measures for the identification and control of design and construction interfaces and for coordination among the CPRT participant organizations. The availability of matrices will provide each affected organization the specific areas and items of information that must be executed and controlled.

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 organizations, understand who is responsible for establishing, executing and controlling the interface.

The following are staff observations on the individual matrices provided in Appendix F.

1. QA/QC-RTL and DAP-RTL to Unit 1 and Unit 2 APGMs. Responsibility for 50.55(e) reportability is assigned to the TUGC0 Project per Appendix H of the Plan.

2. DAP-RTL to SWEC. Information on root-cause analyses, generic implications, Evaluation reports and Results reports is provided to SWEC for "Informa-tion" 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.

4

3. DAP-RTL to Other Design Organizations. Information on root-cause analyses, generic implications, Evaluation reports and Results reports should be 03/10/86 II-22 NUO797 SEC II

provided for " Action" to EBASCO and Impell, who are reanalyzing cable trays and supports. The CPRT may find it more appropriate to develop a separate matrix for the cable 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 understanding 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 the piping system should be provided to QOC through the DAP since this information may be needed for safety-significance evaluation.

6. Interface details (or matrices) could not be found for the interface activities between Other Design Organizations and DAP-RTL and EBASC0/

Impell and Interfacing Organizations.

5.4 Conclusions The CPRT Interfaces provided in Appendix F will be acceptable for current CPRT activities provided the following concerns are satisfactorily resolved:

(1) Define the organization with prime responsibility for 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".

03/10/86 11-23 NUO797 SEC II

(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 EBASC0/ Impell and Interfacing Organizations.

(6) The CPRT auditing of SWEC activities involves interfaces which should be defined.

(7) Define more clearly CPSES project responsibility for action plans and 50.55(e) reportability.

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III. STAFF EVALUATION OF DESIGN ADEQUACY PLAN l

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TABLE OF CONTENTS fa2!!

1. 0 INTRODUCTION ....................................................

2.0 EXTERNAL SOURCE ISSUES ..........................................

2.1 Methodology for Identifying and Resolving New External Source Issues ..............................................

2.1.1 Introduction ........................................

2.1.2 CPRT Approach .......................................

2.1.2.1 Identification of Issues ...................

2.1.2.2 Definition of Issues .......................

2.1.2.3 Development of the Action Plan .............

2.1.2.4 Implementation of Action Plan ..............

2.1.2.5 Corrective Actions .........................

2.1.2.6 Results Reports ............................

2.1.3 Staff Evaluation .............................. .....

2.1.4 Conclusion ..........................................

2.2 Electrical, Instrumentation and Control Systems and Component Issues ...........................................

2.2.1 Introduction ........................................

2.2.2 CPRT Approach .......................................

2.2.3 Staff Evaluation ....................................

2.2.4 Conclusion ..........................................

1

TABLE OF CONTENTS (Continued)

Page 2.3 Mechanical Systems and Components Issues ...................

2.3.1 Introduction ........................................

2.3.2 CPRT Approach .......................................

2.3.3 Staff Evaluation ....................................

2.3.4 Conclusion ..........................................

! 2.4 Civil and Structural .......................................

i 2.4.1 Steam Generator Restraints ..........................

2.4.1.1 Introduction ...............................

2.4.1.2 CPRT Approach ..............................

2.4.1.3 St'aff Evaluation ...........................

2.4.1.4 Conclusion .................................

2.4.2 Design of Seismic Category II Items .................

2.4.2.1 Introduction ...............................

2.4.2.2 CPRT Approach ..............................

2.4.2.3 Staff Evaluation ...........................

2.4.2.4 Conclusion .................................

r 2.4.3 Cable Tray Supports .................................

1 2.4.3.1 Introduction ...............................

2.4.3.2 CPRT Approach ..............................

2.4.3.3 Staff Evaluation ...........................

3 2.4.3.4 Conclusion .................................

ii

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TABLE OF CONTENTS (Continued)

Pag 2.4.4 Conduit Supports ....................................

2.4.4.1 Introduction ...............................

2.4.4.2 CPRT Approach ..............................

2.4.4.3 Staff Evaluation ...........................

2.4.4.4 Conclusion .................................

2.5 Piping and Supports ........................................

2.5.1 Piping Isolation (ISAP VC) ..........................

2.5.2 Third-Party Overview ......... ......................

2.5.2.1 Introduction ...............................

2.5.2.2 CPRT Approach ..............................

2.5.2.3 Staff Evaluation ...........................

2.5.2.4 Conclusion .................................

2.6 Evaluation of Closed External Source Issues ................

2.6.1 Introduction ........................................

2.6.2 CPRT Approach .......................................

2.6.3 Staff Evaluation ....................................

2.6.4 Conclusion ..........................................

3.0 SELF-INITIATED EVALUATION .......................................

3.1 Design Activi ties Evaluation Process . . . . . . . . . . . . . . . . . . . . . . .

3.1.1 Introduction ........................................

3.1.2 CPRT Approach .......................................

iii

TABLE OF CONTENTS (Continued)

Page 3.1.3 Staff Evaluation ....................................

3.1.4 Conclusion ..........................................

3.2 Electrical, Instrumentation and Control Systems and Component's Design Activities ..............................

3.2.1 Introduction ........................................

3.2.2 CPRT Approach .......................................

3.2.3 Staff Evaluation ....................................

3.2.4 Conclusion ..........................................

3.3 Mechanical Systems and Component's Design Activities .......

3.3.1 Introduction ........................................

3.3.2 CPRT Approach .......................................

3.3.3 Staff Evaluation ....................................

3.3.4 Conclusion ..........................................

3.4 Civil and Structural Design Activities .....................

3.4.1 Introduction ........................................

3.4.2 CPRT Approach .......................................

3.4.3 Staff Evaluation ....................................

3.4.4 Conclusion ..........................................

3.5 Piping and Pipe Supports Design Activities .................

3.5.1 Introduction ........................................

3.5.2 CPRT Approach .......................................

3.5.3 Staff Evaluation ....................................

3.5.4 Conclusion ..........................................

iv

TABLE OF CONTENTS (Continued)

P.a21 4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW ...........................

4.1 Introduction ...............................................

4.2 CPRT Approach ..............................................

4.3 Staff Evaluation ...........................................

4.4 Conclusion .................................................

5.0 OVERALL SlM4ARY AND CONCLUSION ..................................

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1.0 INTRODUCTION

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The U.S. Nuclear Regulatory Commission (NRC) Executive rector for Operations issued a directive on March 12, 1984, establishin program for assuring the overall coordination, integration, and resolu n of technical concerns and allegations prior to the NRC staff licens decision on Comanche Peak. In response to this directive, the NRC f d a Technical Review Team (TRT). The applicant, in order to respond to stions, concerns, and issues identified by TRT and others, established t Comanche Peak Review Team (CPRT) and charged them with the responsibili of resolving outstanding issues and determining l that there is reasonab assurance that the Comanche Peak plant can operate without undue risk to the public. Some of the issues identified by TRT and others broughtA nto question the adequacy of the Comanche Peak design and/or ,

design p The CPRT, in order to fulfill their responsibility for resolv ;

1 6 sign related issues, developed the Design Adequacy Program (DAP). The \

DAP has three components. .j The first component consists of evaluation of the nature or implication of each ,

specific design related issue identified by TRT and others. Issues identified

- by TRT and others have been defined in Section 1 of the DAP plan as External Source Issues. A further definition of each external source issue along with its associated staff evaluation (of the DAP approach for determining its impli-cation on an issue specific basis) is presented below in section 2.0 of this

-report. In addition, the staff evaluation of the DAP plan acceptance criteria and corrective actions for identified issues is presented in Part II, sections 2 and 3 of this report.

i-

The second component of the DAP plan in* Ives investigation of root cause or adverse trends so that generic implication to other safety systems can be i

determined. The staff evaluation of the DAP approach for determining generic r

! implication of identified issues is presented in Part II section 3.0 of this I.

j report.

1 The third component of the DAP plan consists of the evaluation of selected

$ additional design areas such that all significant design disciplines, activities, j and processes employed during the design of the Comanche Peak Plant will have l

03/10/86 111-1 NUO797 SEC III

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been covered with the exception of vendor supplied standard equipment and systems. The staff evaluation of the DAP approach for selection of design areas such that all significant areas are covered is presented below in section 3.0.

The staff evaluation for exclusion of vendor supplied standard equipment and systems is addressed in section 4.0 below.

I J

e 03/10/86 III-2 NUO797 SEC III

2.0 EXTERNAL SOURCE ISSUES

/

The program plan defines podurv%e external source issues as being those issues identified by the following sources: The NRC Technical Review Team (TRT), the NRC Atomic Safety Licensing Board (ASLB), NRC Supplemental Safety Evaluation Reports (SSER's), NRC Construction Assessment Team (CAT), NRC Special Investiga-tion Team (SIT), NRC Region IV (RIV), and Cygna Independent Assessment Program (IAP). The design implication of each issue identified by these sources, will be evaluated by the CPRT to assure that all design deficiencies are corrected.

The CPRT program plan has identified a six-step methodology to respond to ex-ternal source issues. The staff's evaluation of this six-step methodology, and j evaluation of each external source issue identified by the CPRT in the program j plan, is presented below. New issues, that may be identified during the imple-mentation phase of the CPRT program plan, will be reviewed by the staff when they are identified by the CPRT. The results of the staff evaluation of new issues will be contained in future reports.

2.1 Methodology For Identifying and Resolving New External Source Issues 2.1.1 Introduction External Source Issues are those design concerns identified by past and ongoing review, inspections and audit activities outside the DAP. These activities include SIT, SRT, CAT, TRT, open SSER issues, RIV, IAP and ASLB proceedings.

In order for the DAP to be complete in the External Source Issues must be in-cluded in the review. The CRPT includes a program for identifying and resolving new external source issues.

2.1.2 CPRT Approach The CRPT has developed a six-step methodology (ref. CPRT Program Plan, Appendix A Section II para. 1, pages 6 thru 9, Rev. 1) for identifying issues, and provide resolution. The process will be continuous throughout the implementation of ,

the DAP and the following steps will assure adequate disposition of the issue:

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i

1) Identification of Issue,

/)2 Development of Issue,

3) Development of Action Plan,

4) Implementation of Action Plan,

5) Corrective Action, and i 6) Results Report.

The approach associated with each of these steps will be discussed in the j following sections of the report.

2.1.2.1 IdenLification of Issue This step in the methodology is accomplished by a review of the various documents and reports associated with the audits, reviews and inspections that had been performed outside the DAP. The review is intended to gather the necessary back-l ground information about an issue, as well as, identify any other issues that may be associated with it. Issues that have been resolved will also be re- -

evaluated to assure adequate resolution. All the issues identified will be entered into tae DAP Tracking System (DAPTS) by means of an Issue Record (IR) and issues will be assigned to either an ISAP or are appropriate DSAP.

4 2.1.2.2 Definition of Issue The IR is used for defining an issue. Using the information on the IR, the following three determinations are made; 1) adequacy of available documentation,

2) identification of potentially affected hardware and 3) nature of programmatic issues. This will determine if additional evaluation of the issue is required.

At this point a Discrepancy / Issue Report (DIR) is completed which assigns the issue to a particular DSAP or requires a separate Issue-Specific Action Plan (ISAP).

2.1.2.3 Development of the Action Plan Once the issue has been assigned an ISAP or to a DSAP, the next step is to develop the tasks associated with the required investigations and evaluation.

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In developing the details of either type of action plan, two approaches will be considered:

1) the cumulative effect of the issue on other issues,

2) proceed directly to corrective action without further engineering evaluation.

2.1.2.4 Implementation of Action Plan The approach to implementation of an action plan (either ISAP or DSAP) will involve one or more of the following initiatives:

1) Verification of project evaluations,

2) Engineering evaluations,

3) Engineering walkdowns,

4) Hardware inspections,

5) Special studies,

6) Testing,

7) Direct hardware modification,

8) Reanalysis on a sampling basis, and

9) Complete reanalysis of affected design.

This step in the methodology will include an investigation of root cause and generic implication. The results of the aforementioned initiatives will be tracked by revisions tc the issue specific DIR.

2.1.2.5 Corrective Action There are three possible approaches to corrective action which dependent on the final classification of the issue:

1) If the issue is deemed to be an Observation (error without design impact) no hardware corrective action is required.

2) If the issue is deemed a Deviation (non-safety-significant with design impact) either a hardware change will be made or the deviation is accepted only after a non-conformance evaluation had been completed.

III-5 NUO797 SEC III 03/10/86

3) If the issue is deemed a Deficiency (safety-significant Deviation) a hard-ware change will be made to bring the design into conformance with the original commitment. The corrective action taken will be documented on the final revision of the issue specific DIR.

2.1.2.6 Results Report

. The issue will be further documented in the end products of the DAP. These include

1) Individual DSAP (except, Pipe and Piping Supports) Results Report in which all tasks performed will be discussed.

I

2) The third part CPRT Results Report which will address only the Piping and Pipe Supports DSAP tasks in a manner to concur with criteria, process used and implementation.

3) Final DAP Results Report which documents the collective evaluation of the adequacy of the CPSES design and identifies any necessary improvements in either CPSES design process, plant operation or hardware modifications.

2.1.3 Staff Evaluation The staff evaluated the six-step methodology (process) for identifying External Source Issues on the basis of whether or not:

1) The process would be continuous throughout the implementation of the DAP,

2) The issues identified would be evaluated equally with concerns produced directly by the Self-Initiated portion of the DAP,

3) The issues identified would be addressed individually, through resolution, and

4) The issues identified would be evaluated for root cause and potential generic implication and be included in the overall trend analysis.

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2.1.4 Conclusions The staff has concluded that the methodology for identifying new External Source Issues meets the basis for their evaluation with the exception of continuous review of external documents. The staff will confirm the continuous review of External Source documentation for new issues as part of their inspection of the i DAP implementation.

2.2 Electrical Instrumentation and Control Systems and Components Issues 2.2.1 Introduction The applicant in the Program Plan, Appendix C (DSAPS), item I Section 3-1 has identified for resolution issues that have been previously identified by the NRC TRT and the CYGNA Independent Assessment Program (IAP) of the Component Cooling Water System (CCWS).

The NRC TRT issues relate to:

1. Qualification of splicer for the expected service conditions and

2. Qualification of SERVICAIR flexible metallic conduit as an acceptable barrier for the purposes of electrical separation.

The CYGNA IAP deficiencies relate to:

1. Temperature / Pressure Rating of Instruments

2. System Short Circuit Currents

3. AC Distribution Voltages

4. Overcurrent Protection

5. Cable Signing, and

6. CCW Pump Motor Sizing 2.2.2 CPRT Approach With regard to the issues identified by the NRC TRT the Program Plan proposes:

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1. Identification of all site-initiated procurement of safety-related electrical components.

2. Review of Qualification Documentation of all identified components.

3. Ident*fication and evaluation of acceptance criteria.

4. Evaluation of components capability to perform its intended function, and

5. Development of Corrective Action for identification deviations.

For the Temperature / Pressure Ratings of Instruments deficiency identified by CYGNA the plan requires that all instruments in other plant safety related fluid systems, where design changes or re-evaluation of system operating conditions by the A/E may have resulted in higher pressure or temperature process conditions, be checked for adequacy of the component ratings. Any deviations will be used to determine the root cause and generic implications as described in the Design Adequacy Program.

For the remaining deficiencies identified by CYGNA the plan proposes DSAP review i of similar issues in the electrical system selected for review by CPRT, and any deficiencies identified to be resolved in that review.

4 2.2.3 Staff Evaluation The review proposed by the applicant for addressing the design related concerns identified by the NRC TRT on qualification of Amp but-splices and SERVICAIR conduit has been evaluated by the staff. The proposed review is sufficiently comprehensive to identify and correct any deficiencies in the site initiated procurement of safety related electrical components.

The review proposed by the applicant for addressing the deficiencies identified by CYGNA, regarding Temperature / Pressure Rating of instruments has also been evaluated by the staff. The applicant's commitment to review all instruments i

in other plant safety related fluid systems will reveal the adequacy of all

such instruments to meet their functional requirements.

1 I

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The review proposed by the applicant for addressing the remaining deficiencies identified by CYGNA is unclear as to how generic implications will be assessed prior to review of an equivalent issue in the self initiated program (DSAP).

Results of review of an item similar to that focus deficient will not provide meaningful data for assessing overall design adequacy, particularly when generic implications and root causes of the initial deficiency have not been assessed to determine whether one or more similar items should be reviewed.

2.2.4 Conclusions Based on our evaluation of the applicant's proposed plan for addressing integral source issues / deficiencies we have concluded that:

1. For the NRC TRT related concerns, on qualification of amp but-splices and SERVICAIR conduits, the proposed review is comprehensive and therefore acceptable.

2. For the CYGNA identified deficiencies regarding Temperature / Pressure Ratings of instruments, the proposed review is comprehensive and therefore acceptable.

3. For the remaining deficiencies identified by CYGNA above, the breadth of the proposed review appears inadequate. Therefore, we require that during implementation of their program plan a generic implications and root cause assessment must be conducted for each identified deficiency in order to determine the breadth of review that must be conducted for a given design activity.

2.3 Mechanical Systems and Components Issues 2.3.1 Introduction The applicant in the program plan Appendix C (DSAPS), item X Section 3.0 has identified for resolution issues that have been previously identified by the CYGNA Independent Assessment Program (IAP) of the Component Cooling Water System )

(CCWS). l l

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The CYGNA issues relate to:

1. CCW System Maximum Temperature-Pressure - incorrectly specified ratings.

2. Class 5 piping inadequately designed to retain pressure integrity during and after an SSE.

3. Potential release of reactor coolant outside containment following single failure in temperature controlled isolation valve.

4. CCW Surge Tank Isolation on High Radiation Signal - Removal of isolation signal may result in releases to exceed 10 CFR 100 limits.

5. Valve Sizing Calculations - Pressure drop and flow calculations have not been provided for certain CCW equivalent.

6. CCW Surge Tank Sizing - Design did not include sizing calculations to account for potential leakage from higher pressure systems.

7. CCW Pump Sizing - Motor sizing calculations may not have included most limiting conditions.

8. Loss of CCW tank vent-relief due to failure in single vent-relief / vacuum breaker.

2.3.2 CPRT Approach With regard to issues 1, 2, 3, 5, 6, 7 & 8 identified in the introduction sec-tion 2.3.1 above the program plan proposes DSAP review of similar issues in the AFWS or another system to ascertain whether similar situations exist 'in other similar designs.

For issue 4 identified in the introduction section 2.3.1 above the program plan proposes documentation review of all Westinghouse-supplied process radiation monitors to assure that all radiation instrumentation requirements identified l 03/10/86 III-10 NUO797 SEC III i

+ . _ , _ _ . - - - , - - - - - - , _ _ ,

f by Westinghouse, FSAR and regulations have been met. Deviations from criteria will be reviewed to determine adequacy of basis for exceptions.

2.3.3 Staff Evaluation The review proposed by the applicant for addressing issues 1, 2, 3, 5, 6, 7 &

8, identified in the CPRT Approach section 2.2.2 above, is unclear as to how generic implications will be assessed prior to review of an equivalent issue in the self initiated program (DSAP). Results of review of an item similar to that found deficient will not provide meaningful data for assessing overall design adequacy, particularly when generic implications and root causes of the

' initial deficiency have not been assessed'to determine whether one or more similar items should be reviewed.

The review proposed by the applicant for addressing issue 4, identified in sec-tion 2.2.2 above has been evaluated by the staff. The proposed review is suf-ficiently comprehensive to identify and correct any deficiencies in the radiation

- monitoring instrumentation.

2.3.4 Conclusions Based on our evaluation of the applicant's proposed plan for addressing external source issues / deficiencies we have concluded that:

1. For issues 1, 2, 3, 5, 6, 7 & 8 identified in section 2.3.3 above, the breadth of the proposed review appears inadequate. Therefore, we require that during implementation of this program plan a generic implications and root cause assessment must be conducted for each identified deficiency in order to determine the breadth review that must be conducted for a given design activity.

2. For issue 4 identified in section 2.2.3 above, the proposed review by the applicant is comprehensive and therefore is acceptable.

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2.4 Civil and Structural 2.4.1 Steam-Generator Restraints 2.4.1.1 Introduction The overall design adequacy of both upper and lower steam generator lateral restraints is to be reviewed for all appropriate loading conditions. This review is due to the TRT issue concerning the improper shortening of anchor bolts in the steam generator lateral supports. The TRT was informed that anchor bolts in the steam generator upper lateral support beams were installed to lengths less than that shown on the design drawings without proper authorization. This was apparently the result of the bolts being cut due to either the hole of the anchor device being filled with debris or concrete mix stuck to the threaded portion of the bolt.

The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation practices. The TRT was told that ultrasonic testing of these types of bolts was not a procedural requirement; however, TUEC was unable to provide any other installation records pertaining to length of anchor bolt thread components for TRT review. The TRT concluded that such unauthorized bolt cutting and lack of installation inspection records was a violation of QA procedures and Criterion XVII in Appendix B 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 and, as a result, appropriate measures are needed to ensure conformance with General Design Criterion 1 of 10CFR50.

2.4.1.2 CPRT Approach Item Vb of the CPRT Program Plan outlines the measures to be taken to ensure that the anchor bolts in the steam generator upper support beams meet the appro-priate design requirements. Also included is a review of similar installations to determine if the issue pertains to other designs. The concern that the anchor bolts in the steam generator upper-lateral support were improperly shortened is addressed in paragraph 2.4.2 of Section IV of this report. In addition to the 03/10/86 III-12 NUO797 SEC III

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 under Discipline Specific Action Plan (DSAP) VIII, which is the Civil / Structural Design Adequacy Plan (DAP).

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 achorage 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.

2.4.1.3 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 Supplement 10 of NUREG-0797, which address the specific concern of improper shortening of the upper-lateral steam-generator-support anchor bolts. The plan in DSAP VIII goes beyond addressing this specific issue and includes a review of the design of both upper and lower steam generator supports to assure that the FSAR commitments are met.

2.4.1.4 Conclusions The staff concludes that the Program Plan appropriately addresses the issue and is acceptable.

2.4.2 Design of Seismic Category II Items Design considerations related to Seismic Category II items is addressed Para-graph 2.3.4 of Section IV of this SSER which addresses ISAP II.d. This is a design identified by the TRT. As noted by the CPRT in their Program Plan there are a number of civil / structural design issues identified by the TRT that are being addressed by previously established ISAPs. These ISAPs will document the specific TRT issue and its resolution. However, design-related technical or 03/10/86 III-13 NUO797 SEC III

programmatic conclusions will be included in the civil / structural root cause and generic implication evaluation.

2.4.3 Cable Tray Supports ,

2.4.3.1 Introduction A number of potential design concerns related to.the cable tray support design have been raised due to the CYGNA IAP. Some examples of these concerns include:

the controlling load case of support designs, seismic response combination, anchor-bolt design, design of compression and flexural members, accounting for support weight, dynamic amplification factor, design of angle sections, reduc-tion of channel capacity due to bolt holes, weld design, and the cumulative effedcts of all concerns.

2.4.3.2 CPRT Approach Based on the number of desig'n concerns identified, TUGC0 is performing additional reviews of the cable tray support designs and has retained outside contractors to perform 100% verification. All Unit 2 analysis / design verification work will be performed by Ebasco. Unit I work will be divided with Impell performing the verification for the Safeguard Building and Ebasco performing the verifica-tion for all other buildings. These design verifications will be subjected to third party overview. This program includes: the development of as-built draw-ings for all cable tray supports; analysis and design review of all cable tray supports to criteria that are responsive to External Source design concerns and in compliance with CPSES licensing commitments; testing to verify and/or establ-ish 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 access-ible attributes. For Unit 2, where virtually all attributes are accessible, an as-built drawing will be developed for each support. For Unit 1, a number 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 03/10/86 III-14 - NUO797 SEC III

taken in developing the as-built drawings. As-designed drawings will be devel-oped 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 1 sup-ports. 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 utilized in the analysis / design verifi-cation of cable tray supports. The first method is equivalent static analysis of individual supports, which is consistent with the criteria used in the devel-opment of the original support designs. The second method is response spectrum dynamic analysis, which is considered to provide a more accurate measure of system response. Both Ebasco and Impell will utilize their own design procedures for performing the work; however, design methods and criteria will be consistent.

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 specified design cable tray fill weights, and conservative assumptions regarding the weight of the fire protection material.

For both units, loading combinations and stress limits will be checked in accord-ance with acceptance criteria conforming to CPSES licensing commitments. 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 support verification effort. The objectives of these tests are to determine actual damping levels to verify applicability of values used in the design of cable tray syste.r.5, to confirm the respc.nse 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.

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Modifications will be prepared for all cable tray scpports that fail to meet specified acceptance criteria. All supports 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.

2.4.3.3 Staff Evaluation The staff has reviewed the approach and methodology of the TUGC0 expanded cable tray support review, along with the third party overview as described in DSAP VIII. In addition, the staff has reviewed all identified external source issues, the original project cable tray support design criteria and licensing commitments. Staff audits of walkdowns, test procedures, tests, design criteria and instructions, analysis methods verification and sample analyses have also been performed.

2.4.3.4 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 pred-icated on the satisfactory resolution of the following comment on the CTCS subprogram.

A concern is that the testing program may generate design and acceptance criteria  ;

which do not comply with FSAR commitments. If licensing commitments are met, lI the proposed acceptance criteria must be identified for approval by the staff prior to implementation.

Another staff concern is the observation that inconsistencies exist between the

,( DAP, DSAP VII and Imprell-Ebasco project instructions. The inconsistencies

' involve the statements describing the methodologies that may be used to evaluate j -\ the cable tray support. In the DAP it is stated that the established Ebasco 03/10/86 III-16 NUO797 SEC III

methodologies will be used while the DSAP allows the use of Impe11 and Ebasco design procedures. Further in the DSAP it is stated that only two methods of dynamic analysis will be used in analysis / design verification of cable tray supports. The Impell project instructions, however, advance the use of time history methods, overlap methods and multi level response spectrum methods in addition to the two methods referred to in the DSAP. These inconsistencies must be resolved and the appropriateness of the above methodology demonstrated to the staff.

2.4.4 Conduit Supports 2.4.4.1 Introduction A number of design concerns with conduit supports were identified as a result of the CYGNA IAP. Examples of these issues include: controlling load case for design, design amplification factor, combination of loads, expansion anchor design and embedments, installation tolerances, increasing conduit spans without justification, improper enveloping of design configurations, which resulted in the installation of support with an unacceptable unistrut configuration.

2.4.4.2 CPRT Approach The TUGC0 project has developed a program to perform a review of the conduit supports. Under this program THE will sample the design of existing Unit 1 and common conduit support to evaluate design adequacy. TUGC0 has retained Ebasco to fully engineer all Unit 2 conduit supports. It is the intent of the project that all conduit supports meet existing CPSES licensing commitments.

i A two-step approach to verifying the design adequacy of Unit 1 and common conduit supports will be implemented. First, all supports, (including unistruts) with unacceptable configurations will be identified and modified to be in compliance with appropriate criteria. Second, a verification of the as-built Unit 1 and i common design conduit runs will be performed using random sampling consisting of two subpopulations: one population being lighting conduits, which typically have long runs of single conduits, and the other, power / control conduits, which 03/10/86 III-17 NUO797 SEC III

typically have shorter runs of grouped conduits. For each subpopulation, a random sample of 60 conduit runs will be selected.

Each sample conduit run will be as-built verified by field inspection to produce conduit-run isometrics and individual support drawings. The design of each selected conduit run and associated supports will be evaluated to determine compliance with specified CPSES acceptance criteria. If all sampled conduit runs and associated supports are found to be in compliance with appropriate criteria, no further action will be taken.

If one or more conduit runs or associated supports do not meet the appropriate criteria, the results will be reviewed to determine the most appropriate form of sample expansion required to ensure complete coverage of the population and to isolate identified problems and/or to take corrective action to meet CPSES acceptance criteria.

All conduit supports that were installed in Unit 2 the original design spec-ification, S-910, have been design verified by Ebasco to the revised Specifica-tion S2-910, which addresses known external source issues and complies with CPSES design criteria commitments. Installation of all remaining Unit 2 con-duit supports has been, and will continue to be, performed in accordance with S2-910. This includes, determining the permissible conduit spans and support designs directly from 52-910, Ebasco Engineering review of all deviations on a case by case basis prior to installation, creation of individual support drawings for any special nonstandards design that is not included in S2-910 and the as building of all conduit runs recording the data on individual isometric drawings with clear identification of each support type.

Deviations are reviewed by Ebasco engineering on a case-by-case basis prior to installation.

Individual support drawings are created for any specific nonstandard design that is not included in S2-910. These supports are designed individually.

All conduit runs are as-built and are recorded on individual isometric drawings with clear identification of each support type.  !

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Testing will be employed to establish capacities and allowables for certain conduit support hardware (e.g., clamps and certain Unit 1 unistrut members).

TNE has developed the required testing specifications.

This review of both Units 1 and 2 conduit support designs will be subjected to third party overview for additional assurance of resolution of external source issues and compliance to CPSES licensing commitments.

2.4.4.3 Staff Evaluation The staff has reviewed the approach and methodology of the TUGC0 revised designs and expanded conduit support review as described in DSAP VIII. In addition, the staff has reviewed all identified external source issues, the original project conduit support design criteria and licensing commitments.

2.4.4.4 Conclusion /

gqtf4%

The staff concludes that the CPRT Program Plan, as described n Revision 3, will adequately address the issues identified with the ce W t ny e"nnn4s and will assure that these supports will meet the licensing criteria.

2.5 Piping and Supports Issues -

ly I 2.5.1 Piping Isolation (ISAP V.c) i /

The design consideration for piping systems between seismic Category I and non-seismic Category I buildings is addressed in detail in IV. Staff Evaluation of Construction Adequacy Plan, Section 2.4.3.

The implementation of this ISAP will be performed under the Project Piping and Supports Program by Stone & Webster Engineering Corporation (SWEC). In addition, a third party overview under the Design Adequacy Program by TERA Corporation will be performed in the implementation of the ISAP. The staff evaluation of the implementation of'this ISAP (V.c) will be discussed in a supplement to this SER.

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k, 2.5.2 Third party (TERA) Overview 2.[2.1 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 (Phases 1-4), the ASLB hearings and related filings, and the NRC staff reviews. As a result, the CPRT initiated a special piping and pipe support requalification program under the direction of TUGC0 projects which has resulted in a significant level of reanalysis and reevaluation of the CPSES piping and pipe support designs. Stone & Webster Engineering Corporation (SWEC) has been retained by the applicant to perform this requalification program. In addition, a third party overview of this effort is being conducted by TERA Corporation (TERA) to provide assurance that the objectives of the Design Adequacy Program in the piping and pipe support area are being achieved. The discipline specific action plan (DSAP) for the piping and pipe support requalification and overview program is described in the "CPRT Program Plan in Item Number IX.

In this section of the SER, we will discuss the staff review and evaluation of the TERA overview effort. The staff review and evaluation of the SWEC piping and pipe support requalification program is provided in III. Staff Evaluation of design Adequacy Plan, Section 3.5 of this SER.

The staff has reviewed the CPRT Program Plan DSAP IX and the applicable portion of Appendices E and F pertaining to piping and pipe support issues. In addition, the staff has performed several audits at the TERA offices to further understand the scope of the TERA effort. Our review focused on the adequacy of the scope and the completeness of the CPRT Program Plan details in addressing the technical concerns associated with piping and pipe support design which have been raised by external sources and self-initiated reviews.

2.5.2.2 CPRT Approach i

j The scope of the TERA third party review is described in the CPRT Program Plan l DSAP IX and Appendices E and F and consists of three major activities:

03/10/86 III-20 NUO797 SEC III

(1) identification, review, and tracking of all external source and self-initiated issues; (2) verification that all design criteria and applicable standards are addressed in project procedures; and, (3) overview of SWEC piping and pipe support requalification program.

(1) Identification Review, and Tracking of Issues Tne CPRT Program Plan describes the third party area of review related to the identification, review, and tracking of external source and self-initiated issues. The process includes not only issues related to the piping and pipe support discipline but also issues related to mechanical systems and components, electrical and instrumentation / control, and civil /

structural disciplines. In identifying the external source issues, the third party is reviewing related documents such as the Cygna Independent Assessment Program (Phases 1-4), including related meeting transcripts, the ASLB hearing transcripts and related filings, the NRC staff reviews including inspections performed by Region IV, the Special Inspection Team (SIT),'the Construction Appraisal Team (CAT), the Special Review Team (SRT), and the Technical Review Team (TRT), and the INPO Self-Initiated Evaluation.

The third party is reviewing each identified issue and determines its significance with respect to the requalification program. Upon resolution of the issue by the responsible organization, the third party reviews and evaluates the resolution and performs an investigation of root cause and generic implication.

The issues and their status are tracked by the third party on a computer system. The computer also tracks the applicable activity for each issue under the requalification program which addresses the resolution.

03/10/86 III-21 NUO797 SEC III

i l

(2) Verification of Criteria and Standards The third party has verified that the commitments used to establish the piping and support design criteria and standards are adequately addressed in procedures and project documents. The commitments include satisfying FSAR, design specifications, and ASME Code requirements. For each criteria source and star.dard identified, the affected scope within the piping analysis / support design requalification program was delineated. The cri-teria was used in the development of checklists for the review of specific program areas.

(3) Overview of SWEC Requalification Effort The third party overview of the SWEC piping and supports requalification program consists of three major activities.

First, the third party will be involved in a review of the SWEC project procedures to be used for the performance of the six major activities described in Section 5.5.2 of this SER. The third party will verify that the procedures are adequate to achieve their intended purpose.

Second, the third party will be involved in a review of selected piping analysis and support designs performed by SWEC. The third party review will use written procedures and checklists to assure compliance with established requirements.

Third, the third party will review the SWEC activities associated with the

! verification of as-built information to be used in the piping and supports requalification program.

2.5.3 Staff Evaluation (1) Identification, Review, and Tracking of Issues The staff has reviewed and evaluated the third party involvement in the

! identification, review, and tracking of issues. The CPRT stated in their l

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, . .-_, . ._ , _ _ .- . , ~ . ._ -

November 22, 1985 letter that the third party will provide reasonable assurance that all identified issues are resolved by reviewing SVEC pro-cedures and selected implementation documentation in conjunction with identification, review, and tracking of all issues until closure. SWEC procedures and implementing work will be reviewed to checklists which explicitly identify the issues in order to assure that they are adequately addressed. For yet unidentified issues, the third party will review scope and depth of the SWEC piping and supports requalification effort to ensure their comprehensiveness. The third party role in the resolution of newly identified issues is to document the issues, track them, identify them to SWEC, review SWEC's proposed resolution, review SWEC's implementation, and ensure that they are resolved.

Based on our review of the scope of the third party issues, the staff finds an adequate process exists to identify all external source issues. The issues as they are identified are logged into a computer and their status is tracked based on a periodic updating of the issue evaluation. The identification of external and internal issues is an on going process.

Based on the sccpe of the external source issues including all issues identified by Cygna, the ASLB, the intervenor, and the NRC staff irrespec-tive of their previous disposition, the staff concludes that the scope is all-encompassing and, thus, acceptable. The staff will continue to monitor the issue tracking system to assure all external source issues are identi-fied. The staff considers this to be a confirmatory issue and will report our findings in a supplement to the SER.

The staff reviewed the extent to which root cause and generic implication evaluations will be performed. Root cause and generic implication evalua-tions will be performed on:

(a) external source issues, (b) TERA - identified discrepancies in SWEC interfaces (c) TERA - identified discrepancies in the SWEC overview, and (d) SWEC - identified discrepancies from yet unidentified issues.

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Based on our review, it was not evident that a process existed for identi-fying discrepancies (or deviations) in external source issues by SWEC.

The SWEC requalification effort will assure that ASME Code requirements will ultimately be satisfied for all piping and supports although it is recognized that modifications can be made to existing hardware. It is not clear to the staff that a root cause and generic implication evaluation can be adequately performed for external source issues without input from SWEC regarding the impact of such issues on hardware design. Although the staff recognizes that not all hardware modifications will be attributed to discrepancies or deviations, the staff requires that a root cause and generic implication evaluation be performed for all hardware modifications in order to document the reasons for such modifications. The staff con-siders this to be an open issue and will report our findings in a supple-ment to the SER.

(2) Verification of Criteria and Standards The staff reviewed the procedure used by TERA for the design criteria and 5

standards verification. The staff finds a sufficient process exists to I assure that all relevant design criteria and standards are addressed in design procedures. The TERA process involved a review of FSAR commitments, design specifications, ASME Code requirements, and other industry standards (e.g., ANSI, AISC, and MSS) in accordanca with design adequacy procedure DAP-1.

In conjunction with a staff audit of the TERA scope, the staff raised a concern regarding the TERA acceptance of certain design criteria. The staff found that several design criteria are based on paragraphs from an edition of the ASME Code later than the edition stated in the FSAR.

Recently, the staff stipulated certain requirements for the use of later Code editions and new ASME Code Cases (e.g., Code Case N-411). The staff discussed with TERA the basis to be used for the acceptance of portions of later Code editions. TERA responded by committing to review Project /SWEC documentation for compliance with ASME Section III paragraph NA-1140 for the Code edition of record. Because the FSAR states that conditionally approved Code Cases will show justification for their use in the design 03/10/86 III-24 NUO797 SEC III

specification or the Brown & Root QA Manual, the commitment by TERA to review the applicable documents for compliance with NA-1140 is appropriate. .

Thus, the staff finds the scope of review for the design criteria to be acceptable contingent upon a satisfactory finding by TERA in its implement-ing review of the project documents. The staff considers this to be a confirmatory issue and will report our findings in a supplement to the SER.

(3) Overview of SWEC Requalification Effort The staff reviewed the checklists to be used by TERA in their overview of the SWEC piping and pipe support requalification effort. The staff found the development of only one out of three checklists have been completed to date. The completed checklist pertained to the review of SWEC procedures.

The checklists to be used for the review of piping analysis implementation and support design implementation were not available for staff review.

The staff review of the checklist for procedure review (Checklist Number DAP-CL-P-001, Revision 0, dated 10-25-85) found the checklist to be a suf-ficient method to assure that the design criteria (identified in accordance with DAP-1), external source issues (identified in the computer tracking system), and standard QA requirements (ANSI N45.2.11) are addressed in design procedures. However, unlike typical checklists (e.g. , Cygna check-lists) which are used to verify the adequacy and completeness of the design documents being reviewed, the procedure review checklist was found to be more of an inventory checklist which is used to assure that all design criteria, external source issues, and standard QA requirements are being )

l addressed by at least one of several procedures. The procedure review l 1

checklist does not address the adequacy or completeness of the procedures l with respect to the engineering assumptions and design input to be used for analysis. The staff was informed that these items would be included i in the checklists for the review of the implementation of piping analysis )

I and pipe support design. Thus, the staff cannot reach any conclusion regarding the depth of the TERA review of the SWEC piping and support re-qualification effort without reviewing the applicable checklists. The J

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l 4

staff considers this to be an open item and will report our findings in a supplement to the SER.

The staff review of the third party overview of the SWEC construction /

as-built review finds that no TERA procedures were available at the time of the staff audit. Thus, it is not clear to the staff what actions are being planned by TERA for their overview of the SWEC construction /as-built review. The staff considers this to be an open item and will report on this item further in a supplement to the SER.

The DAP scope of work under DSAP X, " Mechanical Systems and Components,"

and DSAP XI, " Electrical /I&C Systems and Components Discipline," will include a self-initiated review of the auxiliary feedwater (AFW) system.

However, the scope of work did not include piping and pipe support design.

The basis for excluding piping and pipe support design from the self-initiated review of the AFW system was that the SWEC reanalysis effort included all ASME Class 2 and 3 piping systems (including the AFW system).

Furthermore, the basis " included a TERA review of a s' elected sample of the SWEC piping stress analysis. Although the SWEC reanalysis of the AFW piping system will adequately address the concerns associated with the previous Gibbs & Hill analyses, the scope of the self-initiated review of the AFW system under DSAP X and DSAP XI does not fully address the adequacy of the implementation of the interface requirements between the mechanical systems and the SWEC piping reanalysis (e.g., design considerations for water-hammer evaluation). The staff noted that the TERA review of a sample of the SWEC piping reanalysis did not specifically include the AFW piping l system. During the staff audit, TERA committed to include a portion of the AFW piping system in their selected sample of the SWEC piping re-analysis review. Contingent upon the inclusion of a portion of the AFW piping and supports in'the TERA scope of review, the staff finds that the scope of the TERA overview of the SWEC piping and supports requalification effort is acceptable. The staff considers this item to be confirmatory and will report their findings in a supplement to the SER.

1 03/10/86 III-26 NUO797 SEC III

2.5.2.4 Conclusions Based upon the staff review of the CPRT Program Plan, the staff review of the CPRT response to staff questions provided in the November 22, 1985 letter, and staff audits performed to date, and contingent upon acceptable resolutions of the above open and confirmatory items, the staff concludes the following.

The scope and depth of the third party (TERA) effort provides an adequate pro-gram for the resolution of the identified external source issues and for the identification and resolution of yet unidentified issues which would result from self-initiated reviews. The staff finds the CPRT Program Plan in DSAP IX and Appendices E and F provides reasonable assurance that all safety significant piping and pipe support deficiencies have been identified and resolved. However, proper implementation of the program must be conducted in order to conclude that the objective of the Plan has been achieved. The staff review and evalua-tion of the implementation of the program will be addressed in a supplement to the SER.

2.6 Evaluation of Closed External Source Issues 2.6.1 Introduction Closed external ~ source issues are those concerns identified by sources other than the CPRT (e.g., R IV Inspection Reports CAT, SIT, etc.) which are evaluated and resolved by activities performed outside of the CPRT. For example, the NRC's acceptance of the Applicant's corrective actions responding to notices of violations.

2.6.2 CPRT Approach The Program Plan Appendix A describes that the CPRT will identify the issues by a systematic review of the documents containing the external source issues for concerns implicating either the CPSES design or design process. The documents reviewed include:

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NRC Special Inspection TEAM (SIT) Report NRC Special Review Team (SRT) Report NRC Construction Appraisal Team (CAT) Report NRC Technical Review Team (TRT) Reports NRC Supplemental Safety Evaluation Reports (SSERs)

NRC Region IV Inspection Reports Cygna Independent Assessment Program (IAP) Documents ASLB proceeding documents including transcripts, exhibits, motions, filings and Board Orders.

Transcripts of meetings involving the NRC, CASE, Cygna and TUEC.

Other documents referenced from the above documents that have relevance to design or the design process.

Where a review of the document by a member of the Design Adequacy Review Team reveals a potential design concern, the concern is entered in the DAP Tracking System. This process is controlled by procedures and ensures thoroughness in the issues screening process, control over the issue resolution process and the sorting of related issues for efficient resolution.

Where during the review of external source documents described above, an identi-fied issue has previously been resolved to the satisfaction of the source, the Design Adequacy Review Team will review the resolution. The issue will be con-sidered resolved with no further initiatives if determined to be consistent with existing knowledge including consideration of generic implications. How-ever, relevant information will be retained for use in trending and generic implications evaluations.

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l As potential issues are identified, the Design Adequacy Review Team will review I documentation pertinent to the issue. The Design Adequacy Review Team may also make a preliminary evaluation of available documentation, including engineering walkdowns, to qualify potential issues and to identify those issues requiring further review.

The objective of this effort is to define the issue sufficiently to allow a determination of whether additional evaluations are required or whether direct corrective action is warranted based on the available information. The data obtained in this effort are also used as input into root cause and generic implications evaluations.

An Action Plan is generated when an issue has been sufficiently defined. Where an issue appears to be isolated, an Issue-Specific Action Plan (ISAP), or addi-tional tasks within a DSAP may be devoted to that issue alone. Where the issue appears to have a potentially cumulative effect with other issues, tasks will be developed that permit an integrated solution to the set of potentially cumu-lative issues. Where identified, apparent or suspected root causes may be em-ployed in determining the scope of an ISAP or DSAP. Implementation of DSAPs that address specific CPSES design issues will also provide input into the collective evaluations of design a CPSES and the design process employed.

2.6.3 Staff Evaluation Evaluation of the Plan, Revision 3, finds that the CPRT's review of documenta-tion to identify issues includes the appropriate sources and describes how the issues will be tracked and evaluated in the DAP. Additionally, CPRT activities performed during implementation will determine the impact on construction ade-quacy, safety significance, root cause and generic implications, collective significance and programmatic implications.

This evaluation finds that the Plan adequately describes how the CPRT will handle the closed external source issues; and is responsive to the NRC's concern.

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2.6.4 Conclusion Based on its evaluation that found that the closed external source issues related to design are now adequately addressed in the Plan, the staff concludes that the Plan is acceptable in this regard.

3 e

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3.0 SELF-INITIATED EVALUATION 3.1 Design Activities Evaluation Process 3.1.1 Introduction A self-initiated evaluation of selected design areas has been proposed by tne CPRT in the design adequacy program plan (DAP) in order to increase confidence in the adequacy of the CPSES design and design process. The results of this evaluation and the results of the internal source issues review will determine the adequacy of the overall balance of plant (BOP) design and design process at CPSES.

The implementation of the DAP is divided into Discipline Specific Action Plans (DSAPS) related Civil / Structural, Piping / Supports, Mechanical Systems and Components, and Electrical / Instrumentation and Control systems.

3.1.2 CPRT Approach The initial scope identification was conducted through review of Independent DesignVerificationPrograms(IDVP[)andIntegratedDesignInspections(IDIS) conducted at other nuclear power plants. Design areas addressed in the IDVPS and IDIS were compared against previous services conducted in behalf of CPSES (such as CYGNA, SIT, SRT, CAT, TRT, etc) to determine the depth and breadth of the review required under the new self-initiated program. A list of safety-significant system design characteristics were compared against the AFW system and a portion of the Class 1E electric system to determine whether their design adequacy could extrapolate the adequacy of the over all CPSES BOP design.

The CPRT program plan states that an engineering process validation has deter-mined that the selected systems for evaluation (i.e. AFW and portion of Class 1E Electric) are representative of the safety-related systems, structures and components at the plant.

In order to assure that evaluation results could be used to extrapolate the adequacy of the remainder of the A/E safety-related scope of design, the CPRT 03/10/86 III-31 NUO797 SEC III l

DAT identifies a finite number of homogeneous design activities (HDA) that are used to ensure that the DAP has adequate breadth and the evaluation is carried to sufficient depth. The elements that are important for determining homogeneity of design activities are the following:

Criteria Design consideration, approach and methodology Organization / discipline Design control process Design interfaces Homogeneous design activities identified in the DSAPS matrices present the review scope for each discipline. The HDSAS have been grouped into topical areas within which review checklists will be developed.

3.1.3 Staff Evaluation The staff has evaluated the proposed design adequacy review scope to determine whether review of sufficient number of safety systems and components are being considered in the review to reach a reasonable assurance that all safety systems and components in CPSES are adequately designed.

Our evaluation has revealed that the initial scope of review of the Auxiliary Feedwater System and the portion of the Electrical System did not include suf-ficient number of design activities to allow an assessment of the overall plant BOP design adequacy. However, the augmented scope of review identified in the DSAPS homogeneous design activity matrices and the potential for scope expansion during implementation of the review can provide the reasonable assurance that all safety systems and components are adequately designed.

3.1.4 Conclusions Based on our evaluation of the revC2w scope proposed in the CPRT program plan for determining the overall design adequacy of the plant, we conclude that homo-geneous design activities w1il provide adequate basis for determining the breadth of that review.

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3.2 Electrical Instrumentation and Control Systems and Components Desian Activities 3.2.1 Introduction The self-initiated evaluation of selected design areas of electrical, instrumen-tation and control systems, and components has been proposed by the CPRT in the design adequacy program plan (DAP) in order to increase confidence in the ade-quacy of the CPSES design and design process. The results of this evaluation and the results of the internal source issues review will dettraine the adequacy of the overall plant design and design process in these areas.

3.2.2 CPRT Approach The CPRT program plan has identified for review design activities from the Standby Power, Auxiliary Feedwater, Ventilation Safety Chilled Water, Component Cooling Water, Station Service Water, and Station Service Water Intake Structure Ventilation Systems.

The Homogeneous Design Activity matrices associated with the E/I&C system, iden-tify the areas that will be selected'for review. The technical characteristics required to be reviewed for assuring adequate depth of review, will be contained in technical review check lists. Overall design adequacy (breadth) will be determined by the cumulative assessment of the design adequacy of the homogeneous design activities and the external source issues.

3.2.3 Staff Evaluation The staff has evaluated the proposed design adequacy review scope for the Elec-

, trical Instrumentation and Control Systems (E/I&C) and Components, to determine whether sufficient number of safety related areas are being considered in the review to reach a reasonable assurance that all safety systems and components in the CPSES are adequately designed.

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l _ _ _ _ _ -

Our evaluation hcs revealed that the scope has been significantly augmented, as indicated in the homogeneous design activity matrices, with the potential for scope expansion during implementation of the review.

3.2.4 Conclusions

,y Based on our evaluation of the review scope proposed in the CPRT program plan for determining the overall design adequacy of E/I&C systems and components, we conclude that homogeneous design activities will provide adequate basis for determining the breadth of that review.

3.3 Mechanical Systems and Components Design Activities 3.3.1 Introduction Normally, the technical areas of A/E design responsibility assigned to the Mechanical Discipline involves fluid systems, hydraulics, HVAC, process, nuclear and operational considerations. In the capacity the Mechanical Discipline pro-duces implementing design documents such as; flow diagrams, P and ID's, piping drawings, equipment (installation, bid and purchase) specifications and calcula-tions. The calculations involve entire system revaluation as well as sizing of individual pieces of equipment. The result of these calculations are made part of the specifications and the various drawings. The Mechanical Discipline also produces and receives design requirements from other disciplines (internal inter-faces). These interfaces usually involve the disciplines of Instrumentation and Control, Electrical and Structural. Also, the equipment vendors provide the Mechanical Discipline with equipment design data and requirements (external interfaces).

Therefore, the evaluation of the adequacy of the design produced by the Mechani-cal Discipline will focus on both the implementing design documents and the various interfaces.

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3.3.2 CPRT Approach The CPRT through the Scope Development Process of the DAP plan intends to inspect I the various implementing design documents produced by the Mechanical Discipline and its various interfaces. The Mechanical Discipline design effort has been divided into Review Areas. The Review Areas have been further broken down into Homogeneous Design Activities (HDA's). A Review Area is a general category of design effort, whereas, a HDA is a particular aspect of the area. An example of a Mechanical Systems HDA under the Design Area of Auxiliary Feedwater and Fluid Systems would be Steam System Pressure Drop. Other examples of Mechanical Systems HDS's are Open System Heat Removal and Closed System Heat Removal which are also part of the Auxiliary Feedwater and Fluid Systems Review Area. An example of a HDA associated with Mechanical Component in the same Review Area is Control Valves.

In the DAP plan there are five Review Areas assigned to the Mechanical DSAP.

These are broken down into 126 HDA's. Each HDA will be reviewed via the imple-mentation of technical checklists. An individual checklist covers what is termed a Review Topic. In some cases it is necessary to complete several checklists before a particular HDA has been fully inspected, conversely a single checklist may apply to more than one HDA. An example of this in the Mechanical DSAP is the HDA; System Fluid Temperature-Minimum / Maximum (M026). This HDA requires the completion of three checklists. These checklists are: 1) System Operating Modes, 2) System Maximum Conditions and 3) Heat Removal Capacity. An example 4

of a checklist apply to more than one HDA is the one associated with the Review Topic of System Maximum / Minimum Conditions. This checklist applies to the HDA's of Flow Requirements (M014), Pressure Conditions (M015), System Fluid Temperature (M026) and Expected Loss of Cooling Transient (M027).

3.3.3 Staff Evaluation v The staff performed two audits specifically aimed at reviewing the scope of the

,[ DAP plan are represented by the HDA's. The initial audit addressed the scope of Revision 2 of the program plan. The staff had several comments on the scope

) 'g, , which included a listing of Mechanical Discipline design elements. This listing 1

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--- _- _.__~_ _ _ -.._- ._- _ -..- - . - . .

indicated which of the design elements were contained in the Mechanical DSAP and which apparently needed to be added.

At a subsequent audit, the staff reviewed an intended scope expansion. The expansion was in the form of additional HDA's. At this audit a generic master logic diagram was presented as the basis for the composite list of HDA's for the Mechanical DSAP. Documentation relating (application of the logic diagram to the Mechanical Discipline A/E design responsibility was not presented. Based on their background and experience the staff did evaluate the composite list of HDA's with respect to whether or not the totality of the Mechanical Discipline A/E design responsibility was substantially represented.

Recently, TUEC raised a concern regarding an issue pertaining to whether active valves were designed in accordance with FSAR commitments. The staff reviewed the TUEC response of November 22, 1985 concerning the issue of active valves g :./

and considers the response to be too general. -

1 L (P The CPRT should specify where in Section 3.1.A Paragraph 1 this issue is being y addressed. Because the Plan intends to provide complete coverage of all areas with safety significance, the CPRT should consider the issue of r,ctive valves in the Plan's root cause/ generic implication evaluation. The CPRT's response to the staff concern did not specifically address the issue of active valves nor did it provide any commitment to evaluate the significance of the errors.

The CPRT should specifically review whether there exists any procedure to docu-ment deficiencies in specifications detected by vendors, whether there exists any documentation of or prompt follow-up of such deficiencies such as those identified with active valves, and why the system to control the quality of design documents did not detect that the specifications had deviated from FSAR commitments. The staff considers this to be an open item.

3.3.4 Conclusions The staff has concluded that the composite list of HDA's substantially represents the A/E design responsibility for the Mechanical Discipline.

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During implementation, the staff will verify that documented justification exists for the development of the HDA breakdown of the Mechanical Discipline.

Concerning active valves, the staff requires the CPRT to consider the root cause and generic implications of inadequacies in specifications identified by vendors. This evaluation also should include a review to determine why the system to control the quality of design documents did not detect the incorrect specification and provide corrective action.

3.4 Civil and Structural Design Activities 3.4.1 Introduction Due to the number and types of potential concerns identified 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 identified with the design of the cable trays, conduits, and their supports, the CPRT has expanded the scope to include self-initiated reviews.

The purpose of this self-initiated action is to expand the scope of review in the Civil / Structural Design Area beyond that of the investigation of the External Source Issues to provide an additional level of assurance that all safety-significant design deficiencies are identified. The Self-Initiated Evaluation of the Civil / Structural Design Activity is outlined in Item VIII, Civil / Structural Discipline Spe:ific Action Plan, of the CPRT Program Plan.

3.4.2 CPRT Approach 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 findings.

The scope of the Civil / Structural Self-Initiated Evaluation is intended to encom-pass all safety-related civil / structural design processes not covered by the 03/10/86 III-37 NUO797 SEC III

TRT-related reviews. The review areas are established through the identification of associated homogeneous design activities from which the designs for review will be selected.

Designs representative of HDAs will be selected for review. HDAs have been grouped into topical areas to facilitate the design review process. The follow-ing sections summarize the scope of the CPRT review for each of the topics.

The review scope is more fully discussed in Section 4.3.2 of DSAP VIII.

Load Determination s Where unique calculations have been perfomed (separate from individual structural design calculations) to determine and distribute specific loads on structures, representative calculations will be selected for review. These unique calcula-tions are expected to address pressure, wind, tornado, impact and seismic loads.

The review of pressure, wind, tornado and impact load determinations will be performed on selected repres'ntative e calculation packages. The determination of seismic loads will be reviewed for the auxiliary / electrical building, which has been selected due to its relative complexity. The procedure for developing floor response spectra, considering the three components of earthquake motion, closely spaced modes, peak broadening, torsional effects, etc., will be reviewed.

Concrete Design Three buildings have been selected for review: the reactor, auxiliary / electrical, and fuel buildings. For the reactor building, the method of analysis will be reviewed as well as one set of calculations dealing with the shell wall and -

three others with discontinuities in the g wall. The liner plate and its anchorage system will be included in the review along with a set of calculations addressing the radiological shield wall in the internal structure. In the two other buildings, approximately ten slab and ten wall calculations will initially be selected. Based on the results of this review, additional selections may be made. The treatment of exterior walls as missile barriers will be reviewed and their design verified. Several concrete equipment foundations will also be reviewed.

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Structural-Steel Design l The use of structural steel is limited in the CPSES plant, with essentially no major steel framework in any of the Category I buildings. Selected portions of the structural-steel frame of the cable-spreading room will be reviewed.

In addition, several structural-steel components related to pipe-rupture protec-tion will be selected for review including pipe whip restraint supports and jet shields.

A set of calculations related to the design of platforms, monorails and miscell-aneous Catregory I steel will be selected for review along with the design of the stop gates for the Service Water Intake Structure.

Foundation Design The design of building foundations will be verified by reviewing the design of the containment mat. In addition, a representative retaining wall will be reviewed along with a review of the foundation design of a Category I tank.

HVAC Supports HVAC support design has been included within the scope because of similarities with the cable-tray supports. The systems analysis for the control room HVAC will be reviewed in its entirety. Approximately 20 supports from the remaining population and 20 supports from the control room HVAC system will be reviewed.

The results of the review will either: 1) indicate the need to expand the scope of the review, 2) identify a subpopulation for further investigation, or 3) pro-vide reasonable assurance that the HVAC support systems will meet their specified design requirements.

Crane Supports The containment polar crane has been selected for review in this category due to its importance and its critical location in the plant.

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Equipment Mounting Equipment can be divided into two catagories: mechanical equipment and elec-trical equipment. A minimum of five pieces of equipment from each category will be selected for review.

Penetration Sleeve Anchorage The population of penetrations through the containment wall will be identified and several penetration sleeves, both mechanical and electrical, will be selected for review.

Missile-Resistant Doors and Hatches These components can be sorted into two categories, one in which the doors are designed by the manufacturer with the anchorage designed by the A/E design organization and the other where the entire component including the anchorage is designed by the A/E design organization. A minimum of five items from each category will be selected for review.

Seismic Restraints for Removable Shielding Walls The population of these components will be identified, and a minimum of five items will be selected for review.

Recirculation Sump Pump Screen Support - Crossover Leg Support - Control Rod Drive Mechanism Supplemental Steel Support - RPVRI_ Support These four supports have been selected bers44 cT .1eir uniqueness in design and their importance to safety. All strL:t aa? a siderations related to their design will be reviewed.

I&C Tubing Supports The methodology used to analyze and design these systems will be identified and reviewed. Supports and/or systems will be selected to verify the implemention of the design.

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l l

Fuel Transfer Tube Support This item has been selected since it is a nonpiping-related support designed by thecivil/structuralgrouptotheA.SMEgode. It is unique in the plant, and its design will be reviewed.

Other Structures Desian The design of the following miscellaneous structures will be verified:

A selected number of seismically designed secondary concrete walls and firewalls will be reviewed for load requirements and design.

One of the three outdoor seismic Category I tanks. "

=

The design methodology for underground tanks, underground tunnels and underground electrical duct banks.

The analysis and design of the safe shutdown impoundment dam. Mg

- Thecontainment%gd*t uipment hatch cover and another building roof hatch cover. -

A Fuel Pool Re-Racking A review of the following will be performed: 1) new requirements resulting from the high-density racking, 2) subsequent analysis including dynamic analysis and impact on floor response spectra and local loads, and 3) design details.

Heavy Load Drop The general methodology, load path and energy-dissipation assumptions of heavy d##-

p load drops.

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Development of Specifications Selected specifications prepared by the civil / structural group.

Testing programs providing backup for design-basis criteria.

Other confirmatory tests, such as the Containment Structure Integrity Test assessment.

Special Studies Special studies that validate design assumptions, nonconforming conditions, analytical approaches, etc. '

For each of the areas of review, the review process will involve the identifi-cation and review of design criteria, implementing documents, drawings and specifications.

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, the CPSES FSAR and audits of the Comanche Peak DAP scope validation process and HDA methodology which established the breadth of the review.

As part of its continuing review, the staff will audit further the implementation of the DAP scope validation process and HDA methodology to determine whether the design activities included within selected HDAs are indeed homogeneous and that the review scope includes an adequate sample from each identified HDA.

3.4.4 Conclusion The staff concludes that the CPRT evaluation plan for the Self-Initiated Civil /

Structural Design Activity is generally acceptable and does provide a comprehen-sive probe of the civil / structural design area. The breadth of the review is 03/10/86 III-42 NUO797 SEC III

established through the identification of associated HDA's from which the design reviews will be selected. The staff intends to audit further the implementation of the DAP scope validation process and HDA methodology to confirm the adequacy of the program.

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SELF-INITIATED EVALUATION - DESIGN ADEQUACY PLAN 3.5 Piping and Supports Design Activities 3.5.1 Introduction A number of external source issues have been raised in the area of piping analy-sis and pipe support design. These external source issues originated from several sources; the primary sources being the Cygna Independent Assessment Program, the ASLB hearings, and the NRC staff reviews. As a result, the appli-cant has 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 con tracted by the applicant to perform this requalification program. In addition, a third party overview of this effort is being conducted by TERA Corporation (TERA) to provide assurance that the objectives 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 over-view 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 Section III paragraph 2.4 of this SER.

3.5.2 CPRT Approach The scope of the SWEC program for the requalification of piping and pipe supports '

includes:

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, l 1

100% of all ASME Code Class 1, 2, and 3 large bore pipe supports, 03/10/86 III-44 NUO797 SEC III

small bore piping and pipe supports on a sampling basis, 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 1 stress problems.

The CPRT Program Plan in DSAP IX Attachment 2 describes the outline of the SWEC Action Plan. The SWEC Action Plan consists of the following six elements:

1. Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria.

2. Verification of Existing As-Built Information.

3. Review and Verification of System Design Input, Seismic Acceleration and Fluid Transients.

4. Verification of Existing Pipe Support Design Documents.

5. Resolution of Special Technical Concerns.

6. Reanalysis of Piping Systems and Reevaluation of Pipe Support Designs.

1. Development of Comanche Peak Pipe Stress and Pipe Support Design Criteria The Design criteria and procedures to be used for the pipe stress and support requalification effort by SWEC are included in procedures listed below:

Procedure Title CPPP-1 Management Plan for Project Quality, Rev. 2 CPPP-2 Project Organization Charts, Rev. O CPPP-3 Document Control Procedure, Rev. 2 CPPP-4 Project Records Management Procedure, Rev. 1 CPPP-5 Field Walk Procedure, Rev. 1 CPPP-6 Pipe Stress / Support Requalification Procedure - Unit No. 1, Rev. 1 03/10/86 III-45 NUO797 SEC III

Procedure Title CPPP-7 CPPP-8 Design Criteria for Pipe Stress and Pipe Supports Support , Rev. 1 CPPP-9 System Verification Walkdown Procedure, Rev. O CPPP-10 Pipe Stress / Support As-Built Procedure - Unit No 2, Rev. 1 Power Division Procedure for Documented Review of CPPP-11 Plant Operating Mode Conditions, Rev. O CPPP-12 Administrative Control of Calculations, Rev. O CPPP-13 Cost and Schedule Control Procedure, Rev. O CPPP-14 Site Construction Support Activities, Rev. O Procedure for the Preparation and Control of Project Procedures, Rev. 1

' CPPP-15 PM's Small Bore Stress / Support Requalification Procedure Project Memoranda PM-001 PM-002 Pipe Support Computer Program Usage PM-003 Design Criteria for Pipe Stress and Pipe Supports PM-004 Design Information Request Procedure PM-005 Embedment Plate Evaluation Valve Modeling PM-006 Use of Code Case N-411 for CPSES Stress Requalification l These procedures will reflect all CPSES FSAR commitments tion III Code of Record (with HRC and the ASME Sec-approved changes).

In the process of re-qualification, it is expected some changes to this FSAR and ASME S Code of Record will be requested by TUGCO. For example ection III (W.G. Counsil letter dated 11/18/85 , TUGC0 has requested to V. Noonan)

Case N-411 from the NRC. approval for the use of Code Stafi. This request is presently under consideration by the In addition, Procedures CPPP-6 required for the proper treatment of all external source issuand -

es which are not covered by the standard SWEC procedures and which are unique to th e CPSES plant.

At this time, Procedures CPPP-6 and -7 do not include all for the resolutions of these issues. of the methods required 03/10/86 III-46 NUO797 SEC III

2. Verification of Existing As-Built Information Because the existing as-built data will be used as input for the SWEC requalifi-cation effort, it is important to develop confidence in its accuracy.

The process being used to develop this confidence involves walkdowns performed by SWEC, a reliance on previous work 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 Adequacy Program, specifically for those samples related to piping and supports. The various as-built walkdowns and reinspec-tions are discussed in the following paragraphs.

CPPP-5 Walkdown - The purpose of this walkdown by SWEC was to establish con-fidence in the adequacy of dimensions and functions shown on the existing as-built drawing to support the initiation of the piping analysis effort. This walkdown is described in SWEC procedure 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, which represent ,

those attributes most likely to affect piping analysis. The attributes selected /,

include valve location, pipe support location, pipe support function and support !flI orientation. ' l /f., f o j; ft~..

CPPP 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:

03/10/86 III-47 NUO797 SEC III

T=

(1) To determine whether there are technical configuration issues, other than existing technical findings from previous 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 additional, or refinements of, design inputs, guidelines, or procedures are necessary for the pipe stress and supports requalification effort.

The procedure requires the walkdown of 70 stress problems out of 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 stress analyses are completed.

Examples of the attributes to be inspected during this walkdown include gaps and interferences.

TUGC0 General Pro @ ram for As-Built Pipina Verification - These activities repre-sent the walkdowns performed by TUGC0 to satisfy NRC IE Bulletin 79-14. The TUGC0 procedures issued included CP-QP-11.3, Rev. 6, QI-QP-11.13-1, Rev. 8, CP-EI-4.5-1, Rev. 9 and TNE-DC-24-1, Rev. O.

.M Penetration Schedule - The penetration schedule is a detailed computer listing y describing all of the penetrations in the plant. The schedule lists the type I of sealant, type of penetration, openings and a number of other parameters. The stress analyst can obtain all required information related to penetrations frorr this document.

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 commit-ments 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.

03/10/86 III-48 NUO797 SEC III

The third party will review this activity including verification 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 Existing Pipe Support Design Documents 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 tech-nical 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 reused to include evaluation of all large bore pipe supports individually. SWEC Project 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 requalification effort.

Thus, this Action Plan element has been incorporated into Action Plan Element #6.

i

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 special technical concerns are those issues outside the scope of the typical problems encountered in the conventional 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 Requali-fication Procedure" and CPPP-7, " Design Criteria for Pipe Stress and Pipe Support". The approach to resolution 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 03/10/86 III-49 NUO797 SEC III 1

1

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 Supports". The large bore piping reanalysis will in-clude all ASME Class 2 and 3 piping larger than 2 inches (nominal pipe size) excluding portions within the boundary of Westinghouse Class auxiliary branch line stress problems and all Class 5 piping within the ASME Class 2 and 3 stress problem boundaries. The large bore pipe 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 F 1 full responsibility for the system functional design. The SWEC piping stress results will also be evaluated for consistency with the postulated pipe break

'[ ,

locations.

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 requalification 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 re-viewed for technical adequacy including the need to address those aspects of the calculation which are associated with external source issues.

03/10/86 III-50 NUO797 SEC III

3.5.3 Staff Evaluation

1. Development of Comanche Peck Pipe Stress and Pipe Support Desian 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 prelim-inary in nature and of draft documents only, approval 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 Information The results and the compilation of SWEC and QA/QC walkdowns and previous work peformed by TUGC0 will determine the acceptability of the Plan with respect to the " Verification of As-Built Information". Therefore, a review of the imple-mentation of these procedures is required.

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 dis-cussed and reviewed. In addition, the staff and its consultants performed sample walkdowns.

As a result of our review, the staff has identified several areas where addi-tional information is required:

a. The CPPP-5 walkdown procedure allows the valve and support location toler-ances used by SWEC to range from +/- 3 inches to +/- 12 inches depending on the dimension used on the drawing. Typically, a tolerance for such a dimension is a function of the diameter of the piping system. In this case, there is no relationship *.o pipe size. 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 acceptability limits established in 03/10/86 III-51 NUO797 SEC III l

CPPP-5. The licensee must provide further justification for these toler-ances (e.g., the 12-inch tolerance must be justified by SWEC for small diameter piping.

b. SWEC Stress Reconciliation Walkdown Procedure CPPP-6 indicates that a final field walkdown will be performed at the completion of the requalification effort. The purpose of this walkdown will be to verify 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 clear-ances between pipe and pipe supports and improper alignment and inter-ferences with the snubber / strut 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 information required by the pipe stress analysis is available in this sche-dule. The apparent lack of reference of this penetration schedule, however, in the SWEC Procedure CPPP-7, is of concern to the staff. Specific refer-ence 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 walk-down to verify the accuracy of the data in the penetration schedule in the near future.

d. QA/QC Construction Adequacy Program Reinspection - During audits at the site 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 organiza-tions. The need for an evaluation to integrate all of this information and 03/10/86 111-52 NUO797 SEC III

document the results is apparent. Without such a document, it is not clear to the staff if all of this information 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 orienta-tion came about in CPPP-5 as a result of the failure of one of the four attri-butes 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 loading conditions are identi-fled is appropriate. However, prior to staff approval of these, one document describing all of them, including response spectra, must be prepared and satisfactorily reviewed by the staff.

4. Verification of Existing Pipe Support Design Documents The staff has reviewed and evaluated the CPRT Program Plan Revision 3 DSAP IX, Attachment 2 action plan details related to the verificaton of existing pipe support design documents, and was determined that the effort associated with this Action Plan Element has been changed. Thus, the SWEC approach to requalify pipe support designs has been addressed as part of Action Plan Element #6 and the staff evaluation is provided therein.

5. Resolution of Special Technical Concerns 4 The staff has reviewed and evaluated the CPRT Program Plan details related to I'

the resolution of special technical con cerns, which are being developed by a 03/10/86 III-53 NUO797 SEC III

special SWEC technical group not directly involved in the piping stress analysis effort. This division of responsibility allows the resolutions to be conducted independent from the daily pressures involved with the production effort and, thus, assures a thoughtful and uniform resolution. The SWEC special group has reviewed past studies, analyses, and reports on certain technical issues in addition to'the transcripts and filings associated with the CPSES hearings in order to understand the concerns of all parties. SWEC has developed approaches for the resolution of several piping and pipe support con-cerns and has incor-porated their resolution in SWEC Project Procedures CPPP-6 and CPPP-7. Based on preliminary reviews, the staff finds that the procedures 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 technical resolutions. Staff approval of this, therefore, is contin gent upon satisfactory review by the staff of the procedures and evalua-tion of the technical resolutions.

6. Reanalysis of Pipine Systems and Reevaluation of Pipe Support Desians The staff has reviewed and evaluated the CPRT Program Plan details associated with the reanalys'is of piping systems and reevaluation of pipe support designs.

The staff review of the scope of the large bore and small bore piping stress reanalysis finds it to be adequate contingent upon an acceptable resolution of the following concerns.

(a) The scope of the large bore piping stress reanalysis includes certain Class 5 piping. Specifically, the scope will include only those Class 5 piping within the boundaries of ASME Class 2 and 3 piping stress problems.

The staff requires further justification for excluding the remaining Class 5 piping from reanalysis.

(b) In Revision 3 of the Program Plan the CPRT states that SWEC is responsible for the structural qualification of piping and supports. However, it is also stated that Gibbs & Hill will remain the designer A/E of record for 03/10/86 III-54 NUO797 SEC III

_ _ _ _ _ _ _ . _ _ . . _ _ _ _ _. _ ..._._ . .~._. .. . . _ . _ _

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 pro-vided 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.

(c) The staff has reviewed the CPRT Program Plan response related to small bore piping and support 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.

(d) 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 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 requali-fication effort.

3.5.4 Conclusions Based upon the staff review of the CPRT Program Plan Revision 3, and staff audits performed to date, and contingent upon acceptable resolutions of the items listed below, the staff concludes the following.

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 external source issues related to the design adequacy of 03/10/86 111-55 NUO797 SEC III

piping and pipe supports at CPSES. However, proper implementation of the pro-gram must be conducted in order to assure that the program design criteria have

.,V been met and licensing commitments have been satisfied.

.-(d v "p" a. satisfactory review by the staff of the SWEC procedures

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 reanalysis by Gibbs & Hill

j. justification for exclusion of Class 5 piping and pipe supports

k. Satisfactory review by the staff of the small bore piping and support procedure CPPP-15.

03/10/86 III-56 NUO797 SEC III

4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW 4.1 Introduction The staff in an earlier evaluation of Revision 2 of the program plan (submitted to the applicant by letter dated 8/9/85) requested additional information to justify the exclusion from the design adequacy review program the design activ-ities provided by Westinghouse, the NSSS supplier.

The applicant in response to the staff's request on November 22, 1985 trans-mitted for staff review their justification for the exclusion of Westinghouse from the design adequacy review program.

4.2 CPRT Approach The applicant has stated that Westinghouse designs are included from the design adequacy review of the CPRT because Westinghouse has been subjected to numerous reviews and audits by the NRC and other utilities. However, interface require-ments proposed by the A-E to Westinghouse will be reviewed to assure that the requirements were properly communicated and that hardware comply with those requirements. Additionally, wherever Westinghouse imposes conditions on the A-E, the design adequacy program will review A-E documentation to determine whether the plant design complies with those conditions.

With regard to vendors and design organizations that may have limited nuclear experience and/or have only supplied hardware or designs to CPSES, the design adequacy program will evaluate the scope of work performed to determine the extent of the review required of those organizations' product.

4.3 Staff Evaluation The staff has evaluated the applicant's basis for excluding Westinghouse plant design activities from the design adequacy review plan and has confirmed that Westinghouse NSSS designs are sufficiently standard and have been subjected to numerous reviews and operational tests by other utilities and by the NRC.

03/10/86 III-57 NUO797 SEC III

However, it is unclear whether other design services non-NSSS performed by Westinghouse for CPSES have been subjected to the same rigor of review as the NSSS designs and whether such non-NSSS designs are performed by the same disci-pline design departments within Westinghouse.

4.4 Conclusions On the basis of our evaluation of the CPRT scope of design adequacy review plan we have concluded that excluding from review the Westinghouse supplied NSSS designs services is acceptable. However, we required that during implementation of the design adequacy review program the applicant confirm that other non-NSSS design services provided by Westinghouse are performed by the same organizations that designed the NSSS systems or that the non-NSSS designs are not unique to CPSES.

Furthermore, we have concluded that design adequacy review of services performed by organizations that may have limited nuclear experience and/or have only sup-plied hardware or designs to CPSES, is acceptable.

t 03/10/86 111-58 NUO797 SEC III

l Document Name:

hT0797 SEC IV TC Requestor's ID:

LO Author's Name:

Pe88Y Document Comments:

PH-303 keep this sheet with document

IV. STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN TABLE OF CONTENTS 1.0 Introduction 2.0 External Source Issues 2.1 Electrical, Instrumentation and Control Systems and Component Issues 2.1.1 Heat Shrinkable Insulation Sleeves (1.a.1) 2.1.1.1 Introduction 2.1.1.2 CPRT Approach 2.1.1.3 Staff Evaluation 2.1.1.4 Conclusion 2.1.2 Butt Splice Inspection Reports (1.a.2) 2.1.2.1 Introduction 2.1.2.2 CPRT Approach 2.1.2.3 Staff Evaluation 2.1.2.4 Conclusion 2.1.3 Butt Splice Qualification (I.a.3) 2.1.3.1 Introduction 2.1.3.2 CPRT Approach 2.1.3.3 Staff Evaluation 2.1.3.4 Conclusion 2.1.4 Field Terminations - Comparison of Drawings With As-Built Configuration (I.a.4) 2.1.4.1 Introduction 2.1.4.2 CPRT Approach 2.1.4.3 Staff Evaluation 2.1.4.4 Conclusion ,

2.1.5 Vendor Installed Amp Terminal Lug NCRs (1.a.5) 2.1.5.1 Introduction 2.1.5.2 CPRT Approach 2.1.5.3 Staff Evaluation 2.1.5.4 Conclusion 2.1.6 Flexible Conduit Separation (1.b.1) 2.1.6.1 Introduction 2.1.6.2 CPRT Approach

2.1.6.3 Staff Evaluation 2.1.6.4 Conclusion 2.1.7 Flexible Conduit - Cable Separation (1.b.2) 2.1.7.1 Introduction 2.1.7.2 CPRT Approach 2.1.7.3 Staff Evaluation 2.1.7.4 Conclusion 2.1.8 Conduit to Cable Trmy Separation (I.b.3) 2.1.8.1 Introduction 2.1.8.2 CPRT Approach 2.1.8.3 Staff Evaluation 2.1.8.4 Conclusion 2.1.9 Barrier Removal (1.b.4) i 2.1.9.1 Introduction 2.1.9.2 CPRT Approach 2.1.9.3 Staff Evaluation 2.1.9.4 Conclusion l 2.2 QA/QC Issues

! 2.2.1 QC Inspector Qualifications (I.d.1)

. 2.2.1.1 Introduction 2.2.1.2 CPRT Approach 2.2.1.3 Staff Evaluation 2.2.1.4 Conclusion 2.2.2 QC Inspector Test Administration (I.d.2) 2.2.2.1 Introduction 2.2.2.2 CPRT Approach 2.2.2.3 Staff Evaluation 2.2.2.4 Conclusion

! 2.2.3 Craf t Personnel Training (I.d.3) 2.2.3.1 Introduction 2.2.3.2 CPRT Approach 2.2.3.3 Staff Evaluation 2.2.3.4 Conclusion 2.2.4 Material Traceability (VII.a.1) 2.2.4.1 Introduction 2.2.4.2 CPRT Approach

2.2.4.3 Staff Evaluation

2.2.4.4 Conclusion i

i

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2.2.5 Corrective Action System (VII.a.2) 2.2.5.1 Introduction 2.2.5.2 CPRT Approach 2.2.5.3 Staff Evaluation 2.2.5.4 Conclusion 2.2.6 Document Control (VII.a.3) 2.2.6.1 Introduction 2.2.6.2 CPRT Approach 2.2.6.3 Staff Evaluation 2.2.6.4 Conclusion 2.2.7 Audit Program and Auditor Qualification (VII.a.4) 2.2.7.1 Introduction 2.2.7.2 CPRT Approach 2.2.7.3 Staff Evaluation 2.2.7.4 Conclusion 2.2.8 Management Assessment (VII.a.5) 2.2.8.1 Introduction 2.2.8.2 CPRT Approach 2.2.8.3 Staff Evaluation .

2.2.8.4 Conclusion 2.2.9 Exit Interviews (VII.a.6) 2.2.9.1 Introduction 2.2.9.2 CPRT Approach 2.2.9.3 Staff Evaluation 2.2.9.4 Conclusion 2.2.10 Cleanliness (VII.a7) 2.2.10.1 Introduction 2.2.10.2 CPRT Approach 2.2.10.3 Staff Evaluation 2.2.10.4 Conclusion 2.2.11 Fuel Pool Liner (VII.a.8) 2.2.11.1 Introduction 2.2.11.2 CPRT Approach 2.2.11.3 Staff Evaluation j 2.2.11.4 Conclusion 2.2.12 Onsite Fabrication (VIIb.1) - {'$$,/ l; 2.2.12.1 Introduction 2.2.12.2 CPRT Approach 2.2.12.3 Staff Evaluation 2.2:12.4 Conclusion 4

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2.2.13 Valve Disassembly (VII.b.2) 2.2.13.1 Introduction 2.2.13.2 CPRT Approach 2.2.13.3 Staff Evaluation 2.2.13.4 Conclusion 2.2.14 Pipe Support Inspections (VII.b.3) 2.2.14.1 Introduction 2.2.14.2 CPRT Approach 2.2.14.3 Staff Evaluation 2.2.14.4 Conclusion 2.2.15 Hilti Anchor Bolt Installation (VII.b.4) 2.2.15.1 Introduction 2.2.15.2 CPRT Approach 2.2.15.3 Staff Evaluation 2.2.15.4 Conclusion 2.2.16 Cable Tray Raceway Support Inspections (VII.b.5) 2.2.16.1 Introduction 2.2.16.2 CPRT Approach 2.2.16.3 Staff Evaluation 2.2.16.4 Conclusion 2.3 Civil / Structural Issues 2.3.1 Reactor Cavity Reinforcing Steel (II.a) 2.3.1.1 Introductior 2.3.1.2 CPRT Approach 2.3.1.3 Staff Evaluation 2.3.1.4 Conclusion 2.3.2 Concrete Compression Strength (II,b) 2.3.2.1 Introduction 2.3.2.2 CPRT Approach 2.3.2.3 Staff Evaluation 2.3.2.4 Conclusion 2.3.3 Concrete Structure Air Gaps (II.c) 2.3.3.1 Introduction 2.3.3.2 CPRT Approach 2.3.3.3 Staff Evaluation 2.3.3.4 Conclusion 2.3.4 Control Room Seismic Design (II.d) 2.3.4.1 Introduction 2.3.4.2 CPRT Approach

2.3.4.3 Staff Evaluation 2.3.4.4 Conclusion 2.3.5 Fuel Handling Building Rebar (11.e) d' 2.3.5.1 Introduction 2.3.5.2 CPRT Approach 2.3.5.3 Staff Evaluation 2.3.5.4 Conclusion 2.3.6 Electrical Conduit Supports (1.c) $[ Gb 2.3.6.1 Introduction 2.3.6.2 CPRT Approa-h 2.3.6.3 Staff Evaluation 2.3.6.4 Conclusion 2.4 Mechanical / Piping Issues 2.4.1 NF Support Skewed Weld Inspection (V.a) 2.2.4.1 Introduction 2.2.4.2 CPRT Approach 2.2.4.3 Staff Evaluation 2.2.4.4 Conclusion 2.4.2 Improper Shortening Of Anchor Bolts in S.G. Upper Lateral Support (V.b) 2.4.2.1 Introduction 2.4.2.2 CPRT Approach 2.4.2.3 Staff Evaluation 2.4.2.4 Conclusion 2.4.3 Piping System Design Between Seismic and Non-seismic Category 1 Buildings (V.c) 2.4.3.1 Introduction 2.4.3.2 CPRT Approach 2.4.3.3 Staff Evaluation 2.4.3.4 Conclusion 2.4.4 Non-seismic Category 1 Buildings (V.d) 2.4.4.1 Introduction 2.4.4.2 CPRT Approach 2.4.4.3 Staff Evaluation 2.4.4.4 Conclusion 2.4.5 Main Steam Pipe Installation (V.e) 2.4.5.1 Introduction 2.4.5.2 CPRT Approach 2.4.5.3 Staff Evaluation 2.4.5.4 Conclusion

2.4.6 RPV to Biological Shield Gap (VI.a) 2.4.6.2 Introduction 2.4.6.2 CPRT Approach 2.4.6.3 Staff Evaluation 2.4.6.4 Conclusions 2.4.7 Polar Crane Shimming (VI.b) 2.4.7.1 Introduction 2.4.7.2 CPRT Approach 2.4.7.3 Staff Evaluation 2.4.7.4 Conclusions 2.5 Testing Program Issues 2.5.1 Hot Functional Testing Data Packages (III.a.1) 2.5.1.1 Introduction 2.5.1.2 CPRT Approach 2.5.1.3 Staff Evaluation 2.5.1.4 Conclusion 2.5.2 Test Data Approval (III.a.2) 2.5.2.1 Introduction 2.5.2.2 CPRT Approach 2.5.2.3 Staff Evaluation 2.5.2.4 Conclusion 2.5.3 Deferred Test Technical Specifications (III.a.3) 2.5.3.1 Introduction 2.5.3.2 CPRT Approach 2.5.3.3 Staff Evaluation 2.5.3.4 Conclusion 2.5.4 Test Equipment Traceability (III.a.4) 2.5.4.1 Introduction 2.5.4.2 CPRT Approach 2.5.4.3 Staff Evaluation 2.5.4.4 Conclusion 2.5.5 CILRT (III.b) 2.5.5.1 Introduction 2.5.5.2 CPRT Approach 2.5.5.3 Staff Evaluation 2.5.5.4 Conclusion

2.5.6 Prerequisite Testing (III.c) 2.5.6.1 Introduction 2.5.6.2 CPRT Approach 2.5.6.3 Staff Evaluation 2.5.6.4 Conclusion 2.5.7 Preoperational Testing (III.d) 2.5.7.1 Introduction 2.5.7.2 CPRT Approach

• 2.5.7.3 Staff Evaluation 2.5.7.4 Conclusion 2.6 Methodology for Resolving New External Source Issues 2.7 Evaluation of Closed External Source Issues 3.0 Self-Initiated Evaluation 3.1 Construction Activity Evaluation Process 3.1.1 Introduction 3.1.2 CPRT Approach 3.1.3 Staff Evaluation 3.1.4 Conclusions 3.2 Electrical Populations 3.2.1 Staff Evaluation 3.2.2 Conclusions 3.3 Mechanical Populations 3.3.1 Staff Evaluation 3.3.2 Conclusions 3.4 Civil and Structural Populations 3.4.1 Staff Evaluation 3.4.2 Conclusions 4.0 Exclusion of Vendors from CPRT Review 4.1 Introduction 4.2 CPRT Justification 4.3 Staff Evaluation 4.4 Conclusions 5.0 Overall Summary Conclusions 4

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l Document Name:

NUO797 SEC IV Requestor's ID:

LO Author's Name:

Document Comments:

CRESS PH-303 KEEP THIS SHEET WITH DOCUMENT i

SECTION IV - STAFF EVALUATION OF CONSTRUCTION ADEQUACY PLAN - Draft 1 - 1/28/86 1.0 Introduction The adequacy of the construction QA/QC program and the quality of construction performed within scope of that program have been questioned by a number of sources external to TUEC. The CPRT has been charged by TUEC with responding to and ,

resolving these concerns. This section of the SSER documents the staff evalua-tion of the CPRT formulated program to evaluate questions concerning construc-tion QA/QC and the adequacy of installed hardware.

The CPRT's objectives for the construction adequacy program are to fully resolve all of the external source issues, assess in an integrated fashion all identified safety significant deficiencies and to make a statement about both the adequacy and quality of construction at CPSES. The CPRT's program has the following three components:

a. Evaluation of external source issues,

b. Root cause evaluation and generic implication assessment for each identi-fied safety significant deficiency or trend of nonsafety significant deviations, and

c. Self-initiated reinspection of a sample of the balance of the hardware within the scope of the QA/QC program.

The objective of the staff's evaluation is to ascertain if the CPRT Program Plan describes the framework and process for performing a meaningful reinspection of the QA/QC and the construction activities performed within the scope of that program. The staff's evaluation has consisted of document reviews and audits; the scope of the review has ranged from a review of the Program Plan to the docu-mentation characteristic of the evaluation prepared for assessment of specific hardware populations. Subsequent sections of this SSER section address both the CPRT proposed process and the staff's evaluation of this process. The staff's 03/10/86 IV-1 NUO797 SEC IV

• Y' evaluation addresses both the CPRT's plan for addressing external source issues 4-as well as their self-initiated evaluation. Issue-specific action plans (ISAP) ,

are key elements.in the CPRT's process for evaluating construction adequacy.

l The ISAPs document the CPRT plan for resolving external issues. All construc-tion QA/QC issu hether of a hardware nature or a QA/QC programmatic concern, will be the sub'jerct of an issue-specific action plan. A single ISAP describes the process and methodology for the CPRT's self-initiated hardware reinspection and documentation review. A matrix is then developed to provide a cross refer-ence between each issue or concern and the respective action plan which addresses it. This matrix provides assurance that all external source issues have been addressed by the CPRT.

The ISAPs, which are prepared to address specific external source issues, describe the process for evaluation of these issues. This process may include reinspection of hardware, documentation review, engineering analysis and evalua-tion, assessment of TUEC corrective action programs and an evaluation of data collected from other CPRT review team action plans. The results report prepared for each ISAP documents each individual issue evaluation.

The self-initiated hardware reinspection and documentation review program addresses all safety related construction work activities at CPSES. This program will ensure that areas not addressed by the external source evaluation are evaluated. The self-initiated program also provides additional confidence that any currently unidentified concerns related to construction quality are identi-fied, evaluated, and resolved. The process for accomplishing this self-initiated program is to evaluate the work activities required to construct the Comanche Peak plants. This evaluation will be performed on a sampling basis primarily i through reinspections of safety significant attributes. Documentation reviews will be used to assess inaccessible or nonrecreatable attributes. As with other l ISAPs, a results report will be prepared documenting the results of the total l

self-initiated evaluation program.

CPRT proposes to integrate and collectively evaluate the findings from their external source issue evaluations with the results of the self-initiated program in order to make a statement about construction quality at the Comanche Peak Steam Electric Station. Three reports will be prepared it, addition to the in-dividual action plans results reports to document the results of the integrated 03/10/86 IV-2 NUO797 SEC IV

evaluation. Two collective evaluation reports will be prepared to address the adequacy of the construction QA/QC program and the quality of installed hardware.

. . , Finally, a summary report which integrates the results of the two collective evaluation reports, and state the CPRT's conclusions regarding the quality of yh E, p construction and the QA/QC program at Comanche Peak plant.

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The staff's review of the Program Plan has included a review of each individual ISAP including the ISAP describing the self-initiated evaluation program. In ad-dition to the review of each individual ISAP, a number of onsite audits of the documentation being prepared in support of the self-initiated evaluation have been performed. The purpose of these audits was for the staff to develop an in-depth understanding of the CPRT process for resolution of external issues and the scope of its self-initiated evaluation program. These audits also served to es-tablish that the Applicant was documenting construction adequacy evaluation ac-tivities in sufficient detail to permit audit now or in the future. The staff's evaluation addressed not only the framework and process of the construction ade-quacy review program but the degree of documentation to be provided by the applicant.

Review of the construction adequacy program plan has been accomplished by teams of NRC staff and consultants. External source issue review teams have been i organized in a manner similar to the technical review teams and include the following disciplines:

a. Electrical and instrumentation issues

b. Test program issues

c. Mechanical and piping issues

d. Civil and structural issues

e. QA/QC issues <

f. Miscellaneous issues i Many of the individuals responsible for reviewing the scope methodology and implementation of the external source ISAPs were members of NRC's Technical Review Team. Review of the self-initiated evaluation program is accomplished by multidisciplinary team compassing most of the disciplines addressing external source issues. This team has reviewed the methodology for the self-initiated program and performed an audit of each of the categories of safety related ,

hardware.

03/10/86 IV-3 NUO797 SEC IV

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In summary, the staff's review and evaluation of the program plan has included an assessment of the scope, methodology, and process for resolution of external source issues and a self-initiated evaluation of the construction adequacy and quality at Comanche Peak. This review has been broad in scope in that it has encompassed all disciplines being addressed by the CPRT program plan. In addi-tion, it has been deep inasmuch as the staff has audited a number of the pro-cesses down to level of inspection checklist preparation. In addition, the staff required the CPRT to document the scope, methodology, implementation, results, and evaluation of each ISAP in sufficient detail to permit audit now and in the future.

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03/10/86 IV-4 NUO797 SEC IV L

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 Tech-nical Review Team reports ("TRT"), the NRC ASLB proceedings on the CPSES operat-ing license ( 1SLB"), 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 (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 hardware or the CPSES construction QA/QC program. These components are: First, the CPRT will evaluate each of the specific hardware and programmatic concerns raised by the External Source issues.

It will determine the nature of any safety-significant hardware deficiencies and the corrective actions necessary to resolve them. Second, the CPRT will determine 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 addi-tional hardware that might be deficient for the same programmatic reasons and to determine if changes need to be made in ongoing programs to prevent recurrence in the future.

Implementation of the QOC program is by execution of Issue-Specific Action Plans (ISAPs).

To assure that all issues / concerns from External Sources are addressed, CPRT will develop a matrix that provides a cross-reference between each issue / 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 03/10/86 IV-5 NUO797 SEC IV

such that valid concern can be tracked to the appropriate criteria of 10CFR50, Appendix B, and/or hardware area, and tracked to the ISAP or DSAP governing the l concern. j 2.1 Electrical Instrumentation, and Control Systems and Component Issues The following External Source Issue items have been identified in the Electrical and Instrumentation and Control area:

1.A.1 Class 1E Heat Shrinkable Cable Insulation Sleeves 1.A.2 Inspection Reports on Butt Splices 1.A.3 AMP Butt Splice Qualification 1.A.4 Agreement Between Drawings and Class 1E Field Terminations 1.A.5 Nonconformance Reports on Vendor Installed AMP Terminal Lugs 1.B.1 Flexible Conduit to Flexible Conduit Separation 1.B.2 Flexible Conduit to Cable Separation 1.B.3 Conduit to Cable Tray Separation 1.B.4 Separation Barrier Material Removal The CPRT Program Plan states that a portion of the External Source Issues are currently identified by ISAPs and DSAPs, and that the Plan must include a com-plete listing of all External Source Issues to assure that the CPRT properly addresses each item [1]. In addition, an interface has been established between the design and construction QA/QC adequacy programs to assure that the construc-tion issues are identified in the design adequacy program document review pro-cess [2]. To assure that all External Source Issues are captured, a cross-reference matrix will link each issue with a specific action plan.

These CPRT Program Plan commitments appear sufficient to assure that each Exter-nal Source Issue will be identified, tracked, and evaluated. The staff will monitor the implementation phase to assure that each External Source Issue has been captured by the program.

Other issues that may be identified during the implementation phases of the program plan will be pursued, and the results of the staff evaluation will be reported in a future report. Similarly, the results of in.plementation of the 03/10/86 IV-6 NUO797 SEC IV

CPRT Action Plan for the listed items will be documented in a future results report. The staff will evaluate the implementation results as they become available.

The CPRT Program Plan commitments should provide for the identification and disposition of each External Source Issue during the implementation phase of the program.

2.1.1 Class 1E Heat Shrinkable Cable Insulation Sleeves (I.a.1) 2.1.1.1 Introduction Heat-shrinkable insulation sleeves are required for uninsulated butt splices, 480 volt and 6.9kv motor terminations, at cable reduction splices, and at elec-trical penetration assembly cable connections. The NRC concern centered on the .

lack of awareness by craft and inspection personnel as to where the sleeves should be installed and the high percentage of missed or improperly documented inspections requiring witnessing. One specific action recommended was addi-tional QC inspector training to ensure that heat shrinkable sleeves were in-stalled where required.

2.1.1.2 CPRT Approach ISAP 1.A.1 revision 4 was issued on January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-003. Two activities have been committed; namely, (1) retraining of TUGC0 craft and QC inspectors after revisions have been made to construction installation procedure EEI-8 and inspection procedure QI-QP-11.3-28, and (2) initiation of a records review sampling program to provide reasonable assurance that heat shrinkable sleeves are installed where required. This records review sampling program will include systems important to safety.

Each hardware installation requiring the installation of a heat shrinkable sleeve will be visually inspected if the records review does not indicate that it was installed. In plant areas where cable reduction splices were not required but may nevertheless have been used for electrical terminations, 7 cables and 03/10/86 IV-7 .NUO797 SEC IV W --- - ' ' - ' ' -- - -- - +-

26 equipment components will be visually inspected to confirm that reduction splices were not used. Should any cable splices be detected from this examina-tion, the corresponding records will be reviewed to confirm the adequacy of installation documentation. Decision criteria regarding expansion of the records review ~ sample size are described in the Action Plan.

2.1.1.3 Staff Evaluation Based on the two activities committed in the Action Plan to provide retraining after the applicable procedures are revised and to review a sample of heat shrinkable sleeve installations, the staff believes that the Action Plan is adequate to resolve this External Source issue insofar as applies to construc-tion complete items. The Action Plan does not, however, address the adequacy of the revised procedures and additional training as it relates to future con-struction. The Action Plan should include provisions for continued inspection of completed items to ensure the adequacy of the revised procedures and additional training. NRC personnel will review the implementation of the Action Plan and procedure QI-003 to assure their adequacy.

2.1.1.4 Conclusions The proposed Action Plan is adequate to establish the accuracy and completeness of documentation records for the heat shrinkable sleeve External Source issue with respect to completed construction items. However, since the cause of the concern has been identified as inadequate personnel training, additional train-ing along with revised procedures must be provided and the Action Plan should be expanded to include provisions for inspecting future electrical construction to ensure the effectiveness of the additional training and procedure revision.

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2.1.2.1 Inspection Reports on Butt Splice Inspection Reports (I.a.2) ',

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yd QC inspection reports for 12 butt splices were found to be deficient in one or s

more respects. Nine reports used a post-installation inspection form instead of a witnessing-type inspection form. Six of these nine reports did indicate that installation of the heat shrinkable sleeves had been witnessed, but did not indicate that such witnessing was required. The other three of these nine l

! 03/10/86 IV-8 NUO797 SEC IV l

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i forms did not indicate that installation of the splices had been witnessed.  !

The remaining three reports using the correct form indicated that witnessing of the installations of heat shrinkable sleeves was not applicable (or required). .

l The NRC recommendation was that all QC inspections requiring witnessing for '

splices be performed and properly documented, and that all butt splices be iden-tified on design drawings and physically identified within the appropriate ,

panels.

2.1.2.2 CPRT Approach ISAP 1.A.2 revision 4 was issued on January 24, 1986 to address this concern, 11 and the evaluation process will use quality instruction procedure QI-002. A TUGC0 phase 1 program confirmed the validity of the documentation problems noted by the NRC. The Action Plan provides a second phase commitment to determine

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whether the installed butt splices are technically acceptable, and if not, a third phase commitment will expand the inspection to all Class IE and associated / ,r - <

circuits.

f In the second phase, a review of all drawings and design change documents in-volving butt splices will be performed to assure that the splices are shown in design documents. From this document review, each affected cable will be in-spected for cable splices relative to the FSAR Amendment 44 commitment and the requirements of the Safety Evaluation Report. Pullout tests will be performed on those butt splices rejected and replaced during the phase 2 evaluation. To assure completeness, the population of Class IE control room cabinets will be inspected on a sample basis for the absence of butt splices.

If two or more butt splices from the phase 2 inspection are found to be improp-t'g erly installed, a phase 3 program will be initiated to identify and inspect all J' other essential circuits where AMP insulated butt splices may have been used.

1 V

2.1.2.3 Staff Evaluation The proposed Action Plan fails to make the connection between the phase 1 con-firmation of documentation report deficiencies and the phase 2 review of design documentation in conjunction with an inspection of a sample of butt splices. ,

.The Action Plan implicitly suggests that:

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(1) if none of the inspected butt splices are rejected, pullout tests will not be performed, and the population of butt splices will be presumed to be satisfactory. The documentation records will not be corrected for installation and witnessing aspects; (2) if one butt splice is rejected, it will be subjected to a pullout test. If this test is satisfactory, the population will be presumed to be acceptable. The documentation records will not be corrected for installation and witnessing, and (3) if more than one butt splice is rejected, each will be subjected to pullout testing, but the documentation records will not be corrected for installation and witnessing.

In addition, the Action Plan does not commit to phyrically identify butt splices within the panels.

The staff's preference is that butt splices not be used in Class 1E or asso-ciated circuits except where absolutely necessary. If butt splices are used, the documented procedures and installation records should be correct and suffi-ciently detailed to permit any independent review to confirm the technical ade-quacy of their use. Since the existing documentation records have been unable to confirm their adequacy, the staff's position is that the acceptability of butt splices must be demonstrated by other means. A sufficient amount of addi-tional inspection and testing must be performed to clearly demonstrate the tech-nical adequacy of the butt splices in order to overcome the present inadequacy of the documentation records.

The proposed Action Plan does not take this approach; rather, it presumes that the butt splices are satisfactory regardless of the state of the documentation records. The Action Plan simply does not contain sufficient rigor to clearly demonstrate the adequacy of installed butt splices. To overcome this weakness, the Action Plan should be revised to explicitly state how many butt splices will be inspected and pullout tested, and how the documentation deficiencies will be corrected. In addition, the physical identification of butt splices must be addressed.

03/10/86 IV-10 NUO797 SEC IV

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/ ly 2.1.2.4 Conclusions y

Mf The proposed Action Plan for this External Source Issue is unsatisfactory both in its approach and in the lack of quantitative commitments for inspection and

\(([ pullout testing of existing butt splices.

2.1.3 Butt Splice Qualification (I.a.3) 2.1.3.1 Introduction On a limited basis as described in FSAR Amendment 44, the practice of butt splic-ing cable conductors in panels has been permitted subject to: (1) adequate pro-visions in installation procedures to verify the operability of circuits using butt splices; (2) qualification of the wire splices for anticipated service conditions, and (3) staggering of the splices so that they are not adjacent to or pressing against one another in the same wire bundle. In addition, reinspec-tion of all existing butt splices was to be accomplished using adequate instal-lation and inspection procedures. Circuits containing butt splices were to be tested, and retested if reworked, during plant preoperational and startup tests to assure their operability.

2.1.3.2 CPRT Approach g[ ISAP 1.A.3 revision 4 was issued January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-002. In revi-sion 3 of the CPRT Program Plan, the ISAP was to be revised to reflect construc-tion and inspection procedures, a craft training lesson plan, and formal class-room training.

Construction procedure EEI-8 will be revised to require a continuity check of all circuits containing butt splices and an inspection of butt splices to assure that they are staggered or separated. Inspection procedure QI-QP-11.3-28 will be revised to require that the circuit continuity checks be made and that the splices be inspected for adequate separation. Inspection of adjacent butt splices within panels is included as a part of ISAP 1.A.2. The acceptance criteria M.d requires that no splice touch another splice, and the configuration of wire 03/10/86 IV-11 NUO797 SEC IV

bundles will be corrected where splices are pressing on one another. A qualifi-cation data package will be assembled, reviewed, and approved for the butt splices used in the panels.

2.1.3.3 Staff Evaluation The Program Plan commitment to inspect all butt splices in various panels to assure that no butt splice touches another one within a wire bundle, and to rework splices in nonconforming wire bundles is responsive to the butt splice separation concern. Preparation and issue of a qualification data package for the butt splices for their service conditions is deemed to be adequate. Except for its proposed method of testing butt splice circuits, the plan to revise construction and inspection procedures and conduct training sessions for craft and inspection personnel is appropriate.

Circuit continuity checks proposed in the Action Plan to test butt splice cir-cuits use a very small current value that is unlikely to be representative of actual circuit current value's when system functional tests are performed. Hence, the Action Plan should either justify the use of circuit continuity tests in lieu of actual circuit current values or should be modified to use actual cir-cuit values that would be present during preoperational and startup tests.

2.1.3.4 Conclusions The proposed Action Plan for butt splice qualification is adequate to address this External Source Issue provided that functional operability of those circuits containing butt splices can be demonstrated by the proposed use of circuit con-tinuity checks.

! 2.1.4 Agreement Between Drawings and Field Terminations (I.a.4) 2.1.4.1 Introduction Detailed inspection was performed of 380 selected cables within various panels for correct conductor terminations. Five safety-related cables and one non-safety-related cable were found to be not terminated in accordance with current 03/10/86 IV-12 NUO797 SEC IV

design drawings. NRC requested that a reinspection be performed of all safety-rela WJ and associated terminations in the control room and in the cable spread-ing room termination cabinets to verify that their locations agree with current design documents. If this reinspection revealed an unacceptable level of nonconformance, the scope was to be expanded to all safety-related and associated terminations in the plant.

2.1.4.1 CPRT Approach

g. ISAP 1.A.4 revision 4 was issued January 14, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-001. The six cables identified by NRC were reinspected with the following results:

(1) three cables were correctly terminated, but the drawings were in error regarding conductor color code details. All three drawing errors were subsequently corrected; (2) one cable had two conductors interchanged, but this would not affect proper circuit operation. The conductors have now been changed to conform to the current drawing; (3) one cable was designated as a spare, but the design change authoriza-tion was found to be incomplete. This cable was subsequently deleted from the interconnection drawing, and (4) one cable had spare conductors terminated even though wiring on the vendor side of the terminal blocks had been removed. These spare conductors have been removed from the terminal blocks.

The Action Plan states that a sampling inspection will be developed to reinspect l cable terminations versus current drawing requirements in Class 1E safe shutdown circuits that interface with the alternate shutdown panel in the Unit 1 control room and cable spreading room. Safe shutdown circuits comprise approximately 27% of all Class IE terminations in these rooms, and a random sample of 300 ter-minations will be reinspected to an acceptance criteria of zero errors. Expan-sion of the sample size up to a maximum of 3812 terminations will result if one 03/10/86 IV-13 .NUO797 SEC IV

or more termination errors are identified. Should more than fourteen errors be detected, all Class IE and associated terminations in Unit 1, Unit 2, and common will be reinspected.

2.1.4.3 Staff Evaluation TUGC0 has provided reinspection results of the conductor termination errors for six cables identified by the NRC staff. The proposed Action Plan for a reinspection sample of 300 terminations in Class 1E circuits with an acceptance criteria of no errors is responsive to the NRC concern. Expansion of the sample to all safe shutdown terminations, and to all Class IE terminations at the Comanche Peak Station is also provided by this plan.

2.1.4.4 Conclusions The TUGC0 reinspection results of conductor termination errors for six cables identified by the NRC staff are satisfactory. The proposed Action Plan to rein-spect a minimum of 300 terminations for conformance to current drawing require-ments is adequate for this External Source Issue. The proposed acceptance criteria for sample size expansion appear satisfactory for this concern.

2.1.5 Nonconformance Reports on Vendor Installed AMP Terminal Lugs (I.a.5) 2.1.5.1 Introduction Sixteen nonconformance reports issued in early April 1984 documented a condition described by allegation AQE-36 involving vendor installed AMP terminal lugs in ITT Gould-Brown Boveri 6.9 Kv switchgear. Terminal lugs described by these non-conformance reports were bent in the area between the ring and barrel either in excess of 60 degrees or were twisted.

The initial acceptance criteria for bending of the terminal lugs was 60 degrees, and was modified by the terminal lug manufacturer to permit a one time bend up to 90 degrees and that lugs bent to 120 degrees might be acceptable depending on an end user engineering evaluation. These acceptance criteria were subse-quently changed by the manufacturer to be two bends up to 45 degrees, one bend 7 y 4o 90*b fuu, Q , Ch/ 1[hc[ch y 03/10/86 IV-14 NUO797 SEC IV JF

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4 O suitability of twisted terminal lugs had not been addressed. A reevaluation and redisposition of each nonconformance report was requested taking into account }.

both bent and twisted terminal lugs and the documentation of engineering analyses to justify any "as-is" dispositions.

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2.1.5.2 CPRT Approach i ISAP 1.A.5 revision 4 was issued on January 24, 1986 to address this concern. j

%O.- An examination was made of the terminal lugs identified in the nonconformance reports, and it was determined that the bend angle ranged between 60 and 90 de-

\f grees. These r.onconformance reports were dispositioned relative to the manufac-turer's revised criteria, and did not require an engineering evaluation.  !

The proposed Action Plan makes a commitment that the nonconformance reports will be redispositioned to more clearly state the actual terminal lug bend and j twist condition and will provide an engineering justification for any "use-as-is" I dispositions. In addition, AMP will be requested to provide a documented analysis to support the change from the initial 60 degree bend to the present 90 degrees '

bend acceptance criteria, and will include an evaluation of twisted terminal lugs. Any lugs that cannot be justified based on AMP criteria will be replaced.

The action plan also identifies Mil. Spec MIL-T-79286 as a source of acceptance criteria for both bent and twisted terminal lugs.

2.1.5.3 Staff Evaluation The proposed action plan commits to a final reevaluation and redisposition of l i

the nonconformance reports for the previously identified terminal lugs using acceptance criteria for bending and twisting to be developed by the manufacturer.

Improved detail regarding the condition of each tenninal lug and justification f for "use-as-is" dispositions will be provided. The manufacturer's analysis of I acceptable bend and twist values will be reviewed and approved by the Electrical Review Team. The action plan acceptance criteria states that conformance with ,

an applicable Military Specification will also be accomplished. Any terminal lugs not in conformance with these criteria will be replaced.

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Plan includes a review of Gibbs and Hill separation criteria and inspection

/ procedures for conduit installation.

Physical tests will be conducted on the SERVICAIR flexible conduit used in the panels to evaluate its adequacy as a barrier under design basis short circuit or overload conditions. A detailed separation analysis will be performed of the main control room panels and vertical panels, and will include cables to control switch modules, instrument controllers, meters, indicators, recorders, cathode ray tubes, indicating lights, and the annunciator. Inspections of these panels will be performed to ensure that required separation distances have been attained, and that barriers have been installed where required. If the tests and analysis results do not qualify SERVICAIR conduit as a barrier, the cable l

l installation within the panels will be modified either to achieve acceptable i separation distances or to install appropriate barriers, and the affected draw-1 i ings will be revised to reflect the final configuration.

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j The proposed Action Plan contains acceptance criteria for the qualification I tests on SERVICAIR conduit and for the inspection of installed conduit relative to the final separation criteria to be developed by Gibbs and Hill.

2.1.6 Flexible Conduit Separation (I.b.1) 2.1.6.1 Introduction Industry criteria, such as IEEE Std. 384-1974, have established minimum separa-tion distances to be maintained between redundant safety-related cables and between safety-related and non-safety-related cables within control room panels and cable spreading room termination cabinets. Lesser separation distances may be justified if supported with engineering analyses of the involved circuits and components. The Technical Review Team observed that flexible conduits con-taining safety and non-safety cables within these panels were in direct physical contact, and could not find evidence that analyses had been performed to justify this deviation from requirements in the industry stand;.rds.

Within main control room panels, for example, flexible conduit identified with one separation division (orange color) has been bundled together with flexible 03/10/86 IV-16 NUO797 SEC IV

conduit identified with the redundant separation division (green color). In this instance, a technical justification for the lack of one inch separation distance between redundant conduits containing safety-related circuits has not been provided.

A reinspection of all panels containing redundant safety-related conduits or both safety-related and non-safety-related conduits was required to either correct each violation of the separation criteria or to demonstrate by analysis the acceptability of the conduit as a barrier.

2.1.6.2 CPRT Approach g h.IM ISAP 1.B.1 revision 4 was issued June 4, 1986 to address this concern, and the

• • evaluation process will use quality instruction procedure QI-004 [8]. The Action 1, -

2.1.6.3 Staff Evaluation The proposed Action Plan requires conformance of internal panel cables and con-duits to applicable industry separation criteria by achievement of minimum separation distances, installed barriers, or by appropriate engineering analyses of the actual installation to justify lesser separation distances.

Qualification testing of SERVICAIR flexible metal conduit as a suitable barrier for redundant safety-related cables and for safety to non-safety cables will be performed. Detailed analysis of the separation provisions installed in main control room and vertical panels, and inspection of installed SERVICAIR conduits relative to final separation criteria is committed. If the installed conduits do not satisfy the final separation criteria, the installed cables and conduits will be modified to assure the achievement of minimum separation distances or the installation of barriers. Drawings will be revised to reflect the final configuration.

2.1.6.4 Conclusions The proposed Action Plan is responsive to the External Source Issue of adequate separation of flexible conduits in main control room panels and vertical panels.

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However, the Action Plan does not specifically address the issue of SERVICAIR flex in areas outside the main control room. In 53ctions 3.0 and 4.1.5 of the Action P.lan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installa-tions outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be determined on a casa by case basis. The staff will find this acceptable and responsive to the actions items stated in SSER 7 on confirmation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc. containing two or more Class IE circuits, or Class 1E and non-Class 1E circuits.

2.1.7 Flexible Conduit to Cable Separation (I.b.2) 2.1.7.1 Introduction This particular NRC concern is similar in many respects to External Source h Issue 1.B.1 regarding the accomplishment of minimum separation distances between flexible conduits within mai*n control room panels and vertical panels. In Ex-

, j , 1 ternal Source Issue 1.B.2, the Tecnnical Review Team identified twenty-one cables

• • within four panels where the minimum separation distance of 6 inches specified in industry standards had not been maintained relative to SERVICAIR flexible metal conduits containing safety-related cables.

J NRC required that a reinspection be performed of main control room panels, other

' panels located in the control room, and panels located in other areas of the plant where cables and flexible conduit had been used. TUGC0 was requested to a

either correct any separation criteria violations in these panels or demonstrate that the flexible metal conduit was an adequate barrier in accordance with IEEE Std. 384-1974. If the flexible conduit could not be shown to be a suitable barrier, a minimum separation distance of 6 inches was to be maintained between cables and flexible conduit within the panels. In addition, drawings and related

!- documents were to be revised to indicate the revised minimum separation distances.

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2.1.7.2 CPRT Approach k- ISAP 1.B.2 revision 4 was issued January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-004. The Action Plan states that SERVICAIR flexible metal conduit will be qualified as a barrier by test and analysis and that Unit 1 separation deficiencies will be corrected through inspection nonconformance reports. Unit 2 installation procedures and the post construction inspection program will ensure that separation requirements are met for this plant. The Action Plan provides acceptance criteria for the qualification tests on SERVICAIR flex conduit and for the inspection of installed conduit relative to the final separation criteria to be developed by Gibbs and Hill.

2.1.7.3 Staff Evaluation The proposed Action Plan requires conformance of internal panel cables and con-duits to applicable industry separation criteria by achievement of minimum separation distances, installed barriers, or by appropriate engineering analyses of the actual installation to justify lesser separation distances.

Qualification testing of SERVICAIR flexible metal conduit as a suitable barrier will be performed. Detailed analysis of the separation provisions installed in main control room and vertical panels, and inspection of installed SERVICAIR conduits relative to final separation criteria is committed. If the installed conduits do not satisfy the final separation criteria, the installed cables and conduits will be modified to assure the achievement of minimum separation dis-tances or the installation of barriers. Drawings will be revised to reflect the final configuration.

, 2.1.7.4 Conclusions The proposed Action Plan is adequate for assuring compliance with minimum separation requirements for main control room panels and vertical panels.

This Action Plan, however, does not explicitly address the issue of SERVICAIR flex in areas outside the main control room. In Sections 3.0 and 4.1.5 of the 03/10/86 IV-19 NUO797 SEC IV

Action Plan the applicant states that all panels with two or more trains will be inspected for any additional SERVICAIR flex installations. For any installa-tions outside the control room the applicability of the separation criteria developed for the control boards and vertical panels will be determined on a case by case basis. The staff will find this acceptable and responsive to the action items stated in SSER 7 on confirmation that "two or more trains" is interpreted to mean any panel, termination cabinet, etc. containing two or more Class 1E circuits, or Class 1E and non-Class 1E circuits. Also, in Sec-tion 4.5.1 of the Action Plan, the acceptance criteria is stated as " testing and/or analysis." This is inconsistent with the other sections of the plan which describe testing and analysis, combined, as the means of demonstrating the adequacy of SERVICAIR flex as a barrier, and is therefore not acceptable.

2.1.8 Conduit to Cable Tray Separation (I.b.3) 2.1.8.1 Introduction A minimum separation distance of one inch between an enclosed rigid conduit and open ladder type cable trays was established by Gibbs and Hill in specifica-tion 2323-ES-100; however, the Gibbs and Hill analysis supporting this separation criterion was neither referenced in the FSAR nor reviewed by the NRC for accept-ability. IEEE Std. 384-1974 requires the installation of a barrier between a conduit and an open cable tray unless greater minimum separation distances are maintained or are otherwise justified by an engineering analysis. The Technical Review Team requested that the Gibbs and Hill analysis supporting the one inch separation distance be submitted for NRC review in sufficient detail to permit an independent evaluation of the establishment of this criterion.

2.1.8.2 CPRT Approach h,) ISAP 1.B.3 revision 4 was issued January 24, 1986 to address this concern. The proposed Action Plan commits to a review of the Gibbs and Hill analysis of this separation criterion in conjunction with a supporting Sandia report on Cable Tray Fire Tests (SAND 77-1125C), and its submittal to NRC following approval by the Review Team Leader and a third party consultant. In addition, the Electrical Review Team will review nonconformance reports and inspection reports applicable 03/10/86 IV-20 NUO797 SEC IV

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to this External Source Issue. If compliance with IEEE Std. 384-1974 cannot be demonstrated, conduits and cable trays will be modified to assure compliance-with the standard.

2.1.8.3 Staff Evaluation The proposed Action Plan commits to compilation, review, and approval of the applicable documentation to support the one inch minimum separation distance between rigid conduits and open cable trays, and submittal of this material for NRC independent review. Compliance with the separation requirements of IEEE Std. 384-1974 is committed either by this engineering justification analy-sis or by physical modification of the conduit and cable tray installations.

2.1.8.4 Conclusions The proposed Action Plan is responsive to this External Source Issue and the action item stated in SSER 7. The plan is therefore acceptable. Final resolu-tion of this issue, however, is contingent on the staff review and acceptance of the engineering justification analysis. In the event the justification is found not acceptable, the Action Plan will have to be expanded to cover conduit and cable tray modifications committed to in Section 4.6 of this + D A Pg 2.1.9 Barrier Removal (I.b.4) 2.1.9.1 Introduction During the Technical Review Team inspection of auxiliary feedwater panel CP1-EC-PRCB-09, two barriers used to separate redundant devices and cables were found to be missing. Within panel CP1-EC-PRCB-03, field wiring was not separated by the minimum separation distance of 6 inches.

NRC required that a barrier be installed in panel CB-09 to separate redundant flow and pressure instruments, and that field wiring in panel CB-03 be separated by the minimum distance or by an installed barrier.

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2.1.9.2 CPRT Approach

b. ISAP 1.B.4 revision 4 was issued January 24, 1986 to address this concern, and the evaluation process will use quality instruction procedure QI-004. The Action Plan commits to the re-installation of the barrier material in the auxiliary feedwater panel and the reworking of field cables in the other panel to resolve the identified separation violations. Nonconformance reports will be issued for these violations, and maintenance procedures will be revised to ensure that separation requirements are met following modification or maintenance activities.

4.#' 1 As a part of Action Plan 1.B.1, physical inspection of other main control room panels and vertical panels will be performed to identify any other undetected separation violations.

2.1.9.3 Staff Evaluation The proposed Action Plan commits to correction of two identified separation vio-lations, revision of maintenance procedures to ensure compliance with separation requirements, and the physical inspection of other control room panels for undetected separation violations. The Action Plan states that compliance with applicable industry separation criteria will be achieved.

2.1.9.4 Conclusions The proposed Action Plan is responsive to this External Source Issue for main control room panels. To assure that existing separation violations have been detected in a timely manner, the physical inspection portion of the Action Plan should be expanded to include the cable spreading room termination cabinets and safety-related instrument racks located throughout the plant. In addition, Section 4.5 of the plan is not acceptable. The applicant should explain what is meant by meeting "the intent" of IEEE-384 and Regulatory Guide 1.75 require-ments, and why this is acceptable. In the absence of an adequate explanation, the applicant should commit to " meet" the requirements of the above documents.

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2.2 QA/QC Issues The QA/QC issues are the identified concerns which resulted from the TRT QA/QC group's assessments of allegations pertaining to the QA/QC Program at Comanche Peak. These issues were initially presented to the Applicant by letter from the NRC dated January 8, 1985 and the detailed assessments were published in NUREG 0797 Safety Evaluation Report Supplement ($$ER) 11 that was issued in May 1985 (reference Appendix 0, Pages 0-277 through 0-303).

Additionally SSER 11 contains an Appendix P (reference Pages P-1 through P-56) which presents the result of the TRT QA/QC Group's integrated evaluation of the QA/QC issues identified in Appendix 0, together with those QA/QC issues which were either; specifically referred to the QA/QC Group by other TRT groups or, implied in each of the assessments presented in the Appendices to the SSER Supplements 7, 8, 9 and 10.

Since the QA/QC issues arose from sources other than the CPRT (e.g., SSERs, CAT, SIT, R IV inspection reports, etc.) it has become common terminology to refer to them as external source issues.

Under the Program Plan, Appendix B, Quality of Construction and QA/QC Adequacy Program Plan, the CPRT developed issue specific action plans to address and resolve the QA/QC issues related to construction adequacy. (Reference Appendix B Attachment 1). As the CPRT determines it appropriate to the specific issue being considered, each of the listed ISAPS will employ one or more of the fol-lowing evaluative approaches: re-inspection of hardware, review of hardware documentation, walkdown inspections, data collected from other CPRT review team action plans, engineering review and analysis, and review and verification of TUGC0 corrective action plans.

Also under Appendix B, the CPRT issued a self initiated Issue Specific Action Plan (ISAP) VII.c, construction reinspection and documentation review plan.

l The Program Plan defines the interaction of the results of the implementation of this Plan (VII.c) to assist in the resolution of QA/QC issues addressed in other action plans. The Program Plan further states that to ensure that all issues are identified including these listed in SSER-11 Appendix P, the CPRT, 03/10/86 IV-23 NUO797 SEC IV

in an ongoing activity, is reviewing external source documents and developing issues tracking matrices that provide a cross reference between each issue /

concern and the action plan (s) that address it. During implementation of the Program Plan, the Staff will review these matrices to ensure compliance with the Plan, that any required interfaces have been performed, and that the issues identified in SSER-11, Appendix P, are identified and listed in the matrices.

The staff's evaluations of each of the action plans that address the QA/QC issue, related to the construction adequacy program are presented in the fol-lowing sections of this report.

2.2.1 QC Inspector Qualification (I.d.1) 2.2.1.1 Introduction This ISAP addresses the validity of the training, qualification, certification and recertification in accordance with project procedure and FSAR commitments for all electrical QA inspec' tors, all current ASME inspectors and current non-ASME inspectors.

2.2.1.2 CPRT Approach The Program Plan defines a three phased approach which will review inspector qualification documentation for compliance with project documents, Codes, and standards which were in place at the time of the inspector's certification.

This review will be conducted by an audit groep using prepared checklists and the results overviewed by a special evaluation team. The Plan provides for reinspection of a sample of work completed by those inspectors whose qualifi-cations could net be verified. The Plan identifies implementing procedures, standards and acceptance criteria and describes its interface with ISAP I.d.2

" Guidelines for Administration of QC Inspector Tests" and ISAP VII.c "Construc-tion Reinspection / Documentation Review Plan." The action plan results report will contain a conclusion regarding the impact of the remaining work on Unit 2 and the operations QA/QC program.

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2.2.1.3 Staff Evaluation The staff has evalcated the Plan methodology, reviewed the checklists to be used in its implementation and verified the accuracy of the interface require-ments with other identified action plans. The Plan addresses a review of the qualifications of all current inspectors and by its interface with the results ,

of ISAP VII.c will provide a conclusion regarding the impact of the quality of construction which ray have resulted from the work of inspectors whose quali-fications were foun.1 to be questionable.

This evaluation finds that the Plan will determine the acceptability of QC inspector qualifications in compliance with standards and acceptance criteria in place at the time of certification of the inspector. The FSAR commitment includes: CPSES QA Program Requirements, Regulatory Guide 1.58, Rev. 1, ANSI N45.2.6-1978 and ASME/ANS,I Code requirements.

2.2.1.4 Conclusion The Plan adequately addresses the NRC's concern pertaining to QC inspector 4

qualifications and adequately describes the evaluation process that will resolve the issue and enable a conclusion regarding inspector qualifications in compliance with the stated FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable.

2.2.2 QC Inspector Test Administration (I.d.2) 2.2.2.1 Introduction This ISAP addresses guidelines and procedural requirements for the testing and certifying of electrical QC inspectors.

2.2.2.2 CPRT Approach Although the specific issue primarily addressed the training and certification of electrical inspectors, the CPRT increased the scope of this Plan to include all QC inspectors. The Plan describes a three-step approach as follows:

03/10/86 IV-25 NUO797 SEC IV

(a) Step 1: A Special Evaluation Team (SET) will evaluate the adequacy and acceptability of the project procedures that control the structuring and administration of tests and provide recommendations for improvement of the procedures.

(b) Step 2: The CPRT will forward the SET's findings to TUEC for pro-cedure revisions in accordance with the SET recommendations. All inspector certification exams currently in use will be reviewed and revised, as appropriate, to comply with the revised procedures.

(c) Step 3: The CPRT will conduct a review to determine whether other l improvements should be made to the training program. Utilizing the results of implementation of this Plan, ISAP I.d.1 and VII.c will enable the QA/QC Review Team Leader (RTL) to reach a conclusion regarding QC inspector testing practices.

2.2.2.3 Staff Evaluation This evaluation finds that the Plan methodology describes the process whereby the CPRT will assure that TUGC0 has provided adequate procedures to implement and control the training and testing program for QC inspectors. Additionally, this evaluation verified the existence of an interface with ISAPs I.d.1 and VII.c.

2.2.2.4 Conclusion The Plan methodology adequately describes the evaluation process that will ensure that the QC inspector testing program is in compliance with project procedures, regulatory requirements and FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable.

2.2.3 Craft Personnel Training (I.d.3) 2.2.3.1 Introduction The objective of this ISAP is to evaluate the Craft Training Program to deter-mine if it was adequate in the past, and also to evaluate the current program.

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2.2.3.2 CPRT Approach The requirements of ANSI N45.2-1571, set forth in part, that personnel perform-ing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. To determine that these require-ments are implemented, this ISAP has formulated a Special Evaluation Team (SET),

comprised of individuals with no direct responsibility to CPSES, who will per-form the evaluation of the Craft Training Program including the craft personnel selection, training, assignment and retraining. The following items will be considered during the SET review:

How requirements for craft skill levels are established.

How craft personnel (when selected and while on assignment) are determined to meet the skill and performance requirements.

How craft personnel classifications are established for crew loading.

How craft personnel become aware of changes in design and construction require-ments and how retraining occurs.

How craft personnel are informed and become knowledgeable of QA/QC require-ments/ criteria and changes to those requirements / criteria.

How management is assured that the craft personnel selection, training, assignment and retraining program complies with project requirements.

How supervisory personnel are selected and trained.

How background of education and experience of craft personnel is verified and documented.

The SET evaluation will be accomplished through reviewing those craft procedures that were in existence, interviewing craft personnel, and observing training and field activities.

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Craft personnel will be interviewed, from the general superintendent / building manager level to the craft level including the following disciplines: mechanical, civil coatings, electrical and paper-flow group to determine how craft personnel were selected and trained.

Training and field activities will be observed to determine if adequate training is provided and to evaluate how well the craft personnel performed in the field after training has taken place.

Based on this review, conclusions will be drawn by the QA/CC Review Team Leader as to the adequacy of both past and current practices used for craft selection and training. If current procedures are determined to be inadequate, recommenda-tions for improvement will be provided to TUGC0 prior to the closure of this action plan.

The decision criteria detailed in the Plan provide that the results of inspect-ions conducted during the implementation ISAP VII.c will provide an indication of the adequacy of hardware construction. This information will be categorized by major discipline, e.g, civil, mechanical, electrical and structural. This information can then be compared to the results of this ISAP during the collective evaluation phase.

If craft training was determined to be a root cause, recommendation will be provided to TUGCO.

2.2.3.3 Staff Evaluation This evaluation finds that the CPRT approach will provide a broad-scope in-depth evaluation of the essential elements of the training program and will determine the effectivness of both past and current training and its impact on the con-struction of the physical plant, and compliance with ANSI N45.2.6 and 10CFR50, Appendix B, Criterion II, as committed to in the FSAR.

The staff finds, however, that Section 4.4, Procedures, does not comply with the Program Plan, Attachment 3, ISAP format, which requires that existing proce-dures be referenced.

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. 2.2.3.4 Conclusion The staff's evaluation finds that the ISAP adequately addresses the NRC's con-cern pertaining to craft training, and implementation of the plan will determine compliance with FSAR commitments. Accordingly, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished. l 2.2.4 Material Traceability (VII.a.1) 2.2.4.1 Introduction This ISAP assesses the adequacy of the material traceability control systems implemented during construction. It also evaluates all NRC, TRT and SSER find-ings relating to material traceability that are not covered in other action plans.

2.2.4.2 CPRT Approach The Plan methodology describes a seven step approach to resolution of the issue as follows:

(a) Interface with ISAP VII.c to ensure that reinspections verify material traceability.

(b) Review material control procedures to determine if requirements of 10 CFR 50 Appendix B, criterion VIII and the FSAR are met.

(c) Evaluate the TRT's findings regarding failure to maintain material traceability as identified in the October 1981 ASME Code survey.

(d) Review and identify all SSER findings (including Appendix P) relating to material traceability and verify that action is being taken to resolve the finding. Develop action plans if necessary.

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(e) ' Review the results of ISAPs VII.b.3 and VII.b.1 to verify that material traceability concerns for pipe supports and site fabrication shop activities have been addressed.

(f) Review the results of Action Plan VII.c as they apply to material traceability and review the results of the remainder of the action plans for any impact on the overall evaluation.

(g) Collectively evaluate the results of the above to identify program-matic deviations which require correction of procedures for Unit 2 and operations and areas of hardware which require further evaluation because of programmatic weakness. Prepare an Action Plan Results Report which addresses the overall adequacy of current and historical material traceability controls.

2.2.4.3 Staff Evalua .'on The staff's evaluation finds'that the descriptive methodology will adequately address the resolution of concerns regarding material traceability. In addition, to assure the identification of all issues, Appendix B of the Program Plan describes the development and utilization of issue tracking matrices that identify the issue, the source of the issue and the action plan that addresses it.

2.2.4.4 Conclusion A review of the Plan's methodology that describes the evaluation process and the interface with other action plans finds that the implementation of this Plan adequately addresses resolution of the NRC's concerns with material traceability. Therefore the staff concludes that this ISAP is acceptable.

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2.2.5 Corrective Action System (VII.a.2) 2.2.5.1 Introduction This ISAP evaluates individual NRC, TRT and SSER findings and provides a com-prehensive evaluation of the CPSES construction site nonconformance corrective action and 10CFR50.55(e) reporting system. Because of the close interrelatior.-

ship of TRT concerns involving the nonconformance systems, the corrective action systems, and the 10 CFR 50.50(e) reportability system, all identified issues will be addressed under this one Issue-Specific Action Plan.

2.2.5.2 CPRT Approach Because of the differing complexity of the thret systems being evaluated, the methodology for the evaluation of each will vary somewhat. For the nonconfor-mance systems, all the various methods (populations) of documenting nonconfor-mances will be identified. Populations will be reviewed to determine if non-conformances were properly processed and resolved. In addition, the procedures applicable to the selected nonconformance will be reviewed for compliance with 10 CFR 50, Appendix B and PSAR/FSAR requirements.

For corrective action systems, applicable site procedures will be reviewed for adequacy. This procedural review will be followed by a review of the implemen-tation of the site corrective action systems. Also, a detailed review of the trending system, both procedures and implementation, will be conducted as part of this evaluation.

The approach for evaluating the 10 CFR 50.55(e) reporting system is similar to that for corrective action. Applicable procedures will be reviewed for adequacy followed by a review of the implementation of the 10 CFR 50.55(e) reportability system.

The results of the evaluation of the nonconformance system shall be utilized in the evaluations of the corrective action and 10 CFR 50.55(e) systems. The results of the evaluation of the corrective system will be considered in the evaluation of the 10CFR50.55(e) system.

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2.2.5.3 Staff Evaluation The staff has evaluated the Plan methodology with respect to the standards and acceptance criteria applicable to the issues addressed. These criteria are contained in 10 CFR 50 Appendix B criteria XV and XVI, 10 CFR 50.55(e) and the FSAR. Additionally, Appendix B of the Program Plan describes the development and utilization of issues tracking matrices to ensure that all issues are identified and resolved.

2.2.5.4 Conclusion The staff's evaluation finds that the Plan adequately addresses the NRC's con-cerns and proper implementation of the Plan will resolve the issues in com-pliance with the FSAR commitments. Accordingly, the staff conicudes that this ISAP is acceptable.

2.2.6 Document Control (VII.a.3) 2.2.6.1 Introduction Problems were identified over a period of time in the implementation of the Document Control Program during the construction phase of CPSES. The scope of this Action Plan is to provide confidence that Document Control Program problems did not impact the installation and testing of hardware and that current design requirement are satisfied.

2.2.6.2 CFRT Approach The concerns identified in this Plan are addressed by review and evaluation of the results of the implementation of ISAP III.d "Preoperational Testing" and ISAP VII.c " Construction Reinspection / Documentation Review Plan" to determine if deficiencies identified under those plans are attributable to Document Control problems. Implementation of the action plans requires verification that the latest design information (e.g., drawings, design change authoriza-tions and component modification cards) is used in the preparation of checklists 03/10/86 IV-32 NUO797 SEC IV

used in the reinspections and documentation reviews. Programs and procedures will be evaluated for adequacy against the applicable sections of the FSAR and 10 CFR 50 Appendix B Criterion VI.

2.2.6.3 Staff Evaluation The staff's evaluation finds that implementation will determine the adequacy of the document control system in compliance with 10 CFR 50, Appendix B, Criterion VI, and will identify the impact of Document Control problems in the physical plant. However, the staff finds that Section 4.4 procedures refers to Program Plan and Issue Specific Action Plans instead of identifying the existing project procedures applicable to implementation of the Plan. This does not comply with the Program Plan Attachment 3 ISAP format which requires identification of existing procedures.

2.2.6.4 Conclusion This evaluation finds that the methodology and interface with other action plans adequately addresses the NRC's concerns regarding document control. However, Section 4.4 must be revised to comply with the Program Plan Attachment 3. During implementation of the Plan the staff will confirm that the revision has been accomplished.

2.2.7 ISAP VII.a.4, Audit Program and Auditor Qualification 2.2.7.1 Introduction This ISAP addresses the NRC's concern regarding the adequacy of the TUGC0 Audit Program from its inception to the present and will evaluate the program to determine the effect of any identified inadequacies on the Quality Assurance Program and/or the physical plant, and to recommend appropriate corrections and/or improvements to the current program. This evaluation will be accom-plished through a review which will address audit planning and scheduling, preparation, performance, reporting, follow-up and closecut, and audit per-4 sonnel qualification.

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2.2.7.2 CPRT Approach All revisions of the program and procedures pertaining to the QA Audit Program that have been in effect at CPSES will be evaluated to identify commitments and the degree to which the written program conformed to these commitments.

Included in this evaluation will be the CPSES PSAR/FSAR (Appendices IA(N) and 1A(B), Chapter 17.1), and NRC QA branch questions and answers); TUGC0 Corporate Quality Assurance Program; CPSES Project Quality Assurance Plan (Design and Construction); Dallas Quality Procedures / Instructions Manual.

Reports, documentation, and data generated during the implementation of the program will be reviewed on a selective basis to evaluate the effectiveness of implementation. The selection of specific items to be reviewed will be based on concerns identified by the NRC; significant revisions to commitments, program description, and/or organization; and to pursue questionable areas identified during the review. Specific topics to be addressed include the following:

Audit Planning Criteria Published and as-run Schedules Audit Plans and Checklists Audit Reports Audit Deficiency Follow-up Audit Team Members, Including Qualifications and Staffing Levels

- Organizations Performing Audit Activities

- Application of Audit Activities to Hardware versus Program Procedures 03/10/86 IV-34 NUO797 SEC IV

The object of this evaluation is to reach a conclusion concerning the adequacy of program assessment provided by the Audit Program. This information will be used as an input for recommendations for revision of the current program, as appropriate.

Should audit program deficiencies or weaknesses related to construction activities be identified, they will be evaluated to determine whether action beyond that specified in ISAP VII.c is required to identify potential areas of concern regarding construction quality.

2.2.7.3 Staff Evaluation The staff evaluation has considered that the source documents (e.g., SSERs, R IV Inspection Reports, CAT, etc.) that identified the issue have reported the ineffectiveness of the TUGC0 QA Audit Program for a time frame that covers the period from 1978 through 1984. Since this period covered almost all of the construction activity, the staff wishes to emphasize its understanding of the ISAP that the CPRT's evaluations will include the PSAR/FSAR and all revisions, and the TUGC0 QA Audit Program and Procedures and all revisions thereto; and that the CPRT's evaluations will detemine and report compliance / noncompliance with each of the documents as' applicable from inception of the TUGC0 QA Audit Program to the present period of activity covered by this ISAP. During implementation of the Plan the staff will confirm the CPRT's documented objective evidence in this regard.

The staff finds that the FSAR commitments are identified in this plan and that the plan methodology is of adequate scope and depth to determine compliance with those commitments. This evaluation also finds that this plan's interac-  !

tion with ISAP VII.c will assist in the identification and the determination of j the impact of audit program deficiencies on construction quality. However, the staff finds that Section 4.4 Procedures; refers to Program Plan and Issue Specific Action Plans instead of identifying the existing project procedures I applicable to implementation of the plan. This does not comply with the i Program Plan, Attachment 3, ISAP format, which requires tentification of existing procedures.

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2.2.7.4 Conclusion Based on the staff evaluation that FSAR commitments are identified in the plan, and that implementation of the plan will cover sufficient scope and depth to determine compliance with those commitments and any resultant impact on con-struction quality, the staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3.

During implementation of the plan, the staff will confirm that the revision has been accomplished, and the staff will also confirm that the CPRT's evalua-tions have considered all revisions of the PSAR/FSAR and the TUGCO-QA Audit Program and Procedures.

2.2.8 ISAP VII.a.5, Management Assessment 2.2.8.1 Introduction This plan addresses the NRC's concern regarding the TUGC0 management assessment of the effectiveness-of impl'ementation of their QA Program during construction of CPSES. The issue arose because of TUGCO's failure to implement periodic nanagement review of QA Programs in compliance with 10 CFR 50, Appendix B, Criterion II, QA Program, which states in part: The applicant shall regularly review the status and adequacy of the Quality Assurance Program.

2.2.8.2 CPRT Approach The purpose of this action plan is to assess the adequacy of the current CPSES Periodic Review of the QA Program against criteria to be developed as part of this plan. The Review Team will review in place Periodic Review of QA Programs in other organizations and will consult with INPO to define criteria for an adequate and an effective Periodic Review of the QA Program. The Review Team will then evaluate the current CPSES Periodic Review of the QA Program against the criteria developed above and will recommend appropriate revisions to the CPSES Program.

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Utilizing the information gathered, a set of criteria will be developed to define an effective Periodic Review of the QA Program for CPSES which addresses, among others, the following:

- Scheduling and performance of reviews at least annually.

/

- Reports directed to, and responses received from, a sufficiently high (j level of management to ensure effective correction action.

Ongoing contact by management with program status.

Identification of corrective action.

Tracking and follow-up.

The current TUGC0 program will be evaluated against the criteria developed above, and, if appropriate, revisions to the TUGC0 written program will be pro-posed to assure that an effective Periodic Review of the QA Program is in effect for the remaining construction phase of Unit 2 and for the operations phase.

Copies of the Results Report for this ISAP will be provided to TUGC0 for their consideration in responding to the NRC Notice of Violation (445/8432-02; 446/8411-02) (detailed below).

Background information detailed in this plan states:

4

- The intent of this Issue-Specific Action Plan (ISAP) is to ensure that, for the remaining construction phase for Unit 2 and for operations, a Periodic Review of the QA Program is developed which will provide corporate management with data concerning the adequacy and effectiveness of the overall QA Program and which provides for the evaluation, by management, of adverse findings and subsequent corrective action follow-up.

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}

This ISAP is not intended to perform evaluations which would result in conclusions regarding the installed hardware. The quality of hardware and any potential safety implications will be assessed from other hardware and programmatic ISAPs and the self-initiated Reverification Program, ISAP VII.c.

- In addition to the TRT issue, the NRC issued a notice of violation (445/8432-02; 446/8411-02): Contrary to the requirements, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the con-struction quality assurance program.

2.2.8.3 Staff Evaluation

]

l The staff's evaluation of the CPRT's stated intent finds that this plan is responsive to the action identified by the NRC, which requested that the appli-cant propose an action plan that will ensure that such problems (lack of a management assessment program) do not occur in the future. The plan methodology adequately describes a viable approach to establishing a management review program.

With regard to additional action identified by the NRC that the applicant evaluate the TRT's findings and address potential safety significance, root cause, generic implications and collective significance, this plan states that these factors are addressed in other hardware and programmatic ISAPs and the self-initiated ISAP VII.c. The staff finds that this is a satisfactory response to the action identified.

The staff finds that Section 4.4.1 procedures refers to the Program Plan and l Issue Specific Action Plans instead of identifying the existing project procedures applicable to implementation of the plan. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires identification of existing pro-cedures.

4 I

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2.2.8.4 Conclusion Based on the evaluation, and the plan's determination of compliance with 10 CFR 50, Appendix B, Criterion II, the staff concludes that this ISAP is acceptable. However, Section 4.4.1 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished.

2.2.9 ISAP VII.a.6, Exit Interviews 2.2.9.1 Introduction This ISAP addresses the NRC's concerns regarding the Exit Interview Program.

The purpose of this action plan is to rietermine if TUGC0 management has now established an effective program which encourages employees to voice concerns regarding safety and which seriously evaluates these concerns.

2.2.9.2 CPRT Approach The CPRT will determine if TUGC0 has an effective program in place by evalua-tion of the adequacy of the policies, procedures and activities of the CPSES Ombudsman and the CPSES SAFETEAM in identifying and resolving site personnel concerns which have potential safety implications. The scope includes the evaluation of the Ombudsman's activities associated with employee concerns brought before him, including those uncompleted actions transferred by him to TUGCO. However, due to the time frame within which this plan will be conducted related to the time of transfer of responsibilities from the Ombudsman, the majority of review and evaluation will center upon the activities and program of the SAFETEAM as implemented through December 1985. The implementation of this plan will develop a set of attributes derived from TUGC0 commitments and 1

industry guidelines which will be utilized in the preparation of the checklists to be used in the review of established policies / procedures in place governing the activities of the Ombudsman /SAFETEAM interviews of employees. Evaluations will then be made as to the effectivness of the Ombudsman /SAFETEAM's handling of employees' concerns including the evaluation for potential safety implications.

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Any specific technical issues or concerns found during this review shall be coordinated with QA/QC RTL and other cognizant RTLs to determine additional evaluation, as required.

The results of reviews and evaluations conducted in the implementation of this plan will provide a basis for determining whether the Ombudsman's interview program and implementation was adequate and effective in identifying employee concerns, as well as determining whether the existing SAFETEAM program as implemented is effective in identifying and evaluating employee concerns regard-ing potential safety implications. The results of this action plan will provide input for the overall evaluation of the adequacy of the QA program being con-ducted by the QA/QC Review Team as well as providing recommendations for improve-ment for future program implementation as required.

2.2.9.3 Staff Evaluation This evaluation finds that the plan is responsive to the NRC's concern, and that implementation of the plan will evaluate past concerns, identify potential safety implications, and determine the effectiveness of the performance of the Ombudsman /SAFETEAM. Implementation will also ensure that TUGC0 management has now established an effective program which encourages employees to voice concerns regarding safety and which seriously evaluates these concerns.

The plan, Section 4.1.2.5, states that reviews and evaluations shall be con-ducted of, and limited to, past items of concern brought before the Ombudsman or identified through employee interviews with the SAFETEAM. This statement can be interpreted to mean that the CPRT will do evaluations of either the Ombudsman or the SAFETEAM. The staff wishes to clarify its understanding that this paragraph means that the CPRT will evaluate both. During implementation of the plan, the staff will confirm that the CPRT has done both evalutions. In addition, the staff finds that Section 4.4, Procedures, refers to the Program Plan and Issue Specific Action Plans instead of identifying the existing project procedures applicable to implementation of the plan. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires identification of existing procedures.

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2.2.9.4 Conclusion The staff notes that there is no regulatory position that requires the applicant to have a formal exit interview program; therefore, there is no standard to e enable a comparison of the applicants program for compliance. However, the staff has determined that implementation of this plan will establish adequate measures to address and resolve employees' concerns and to identify quality and safety implications. The staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3.

During isolementation of the plan, the staff will confirm that the revision has been accomplished.

2.2.10 ISAP VII.a.7, Cleanliness 2.2.10.1 Introduction This ISAP addresses the NRC's concern pertaining to housekeeping and system cleanliness and will determine the validity of the current housekeeping system and system cleanliness program for Units 1 and 2. Results of other action plans, procedural requirements, surveys, etc., will be analyzed to determine any impact on hardware and programmatic implications.

2.2.10.2 CPRT Approach The CPRT assesses the adequacy of the housekeeping and system cleanliness pro-gram at CPSES by implementation of the following tasks:

Review the results of ISAPs II.c and VI.a for adverse trends related to housekeeping and system cleanliness.

- Review TUGC0 and Brown & Root procedures for establishment of housekeeping and cleanliness measures (including surveillance requirements).

- Evaluate implementation of Flush Procedure (FP) 55-08 for Reactor Vessel cleanliness.

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Review and evaluate implementation of TUGC0 and Brown & Root Surveillance Programs.

The procedural controls that are in effect for housekeeping and system clean 11-ness shall include the requirements of 10CFR50, Appendix B, Criterion XIII, and the FSAR. Housekeeping and system cleanliness procedures will be reviewed to determine if these requirements are included. Procedural controls for site and plant surveillance will also be reviewed.

The TUGC0 flu-r. procedures for verifying cleanliness of the Reactor Coolant Loops, including FP 55-08, as referenced in Item 9A of the NRC-TRT letter dated January 8, 1985, will be reviewed to determine the adequqacy of swipe testing performed in accordance with the Westinghouse guidelines.

2.2.10.3 Staff Evaluation This evaluation finds that the NRC's concerns are identified correctly and are adequately addressed. Imple* mentation by the methodology described will deter-mine compliance with the requirements of 10CFR50, Appendix B, Criterion XIII, which is the FSAR commitment. The standards and acceptance criteria defined in the plan are approp iate for the evaluation to determine that compliance.

mm. ._ _ _ _ . . . , ever, Section 4.4, Procedures, contains a narrative

,/ statement regarding the retention of checklists, guidelines..., etc., instead

/ of referencing existing procedures. This does not comply with the Program Plan, Attachment 3, ISAP format, which requires identification of existing procedures.

2.2.10.4 Conclusion Based on the evaluati e NRC staff finds the NRC's concern is adequately I addressed and that i mentation of the plan will evaluate and resolve the issue and determine compliance with the FSA e staff concludes that this ISAP is acceptable. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During implementation of the plan, the staff will confirm that the revision has been accomplished.

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t 2.2.11 ISAP VII.a.8, Fuel Pool Liner 2.2.11.1 Introduction t

This ISAP addresses the NRC's concern regarding the applicants' inability to i maintain an effective and controlled QC Program for fuel pool liner fabrication, installation and inspection. This is ch was reported in SSER 11 Appendix 0, pertains principally to operatio avelers and related documentation.

> Reinspection of welds in the fuel pool liner will be performed under the self-initiated ISAP VII.c.

2.2.11.2 CPRT Approach 1

Background information in the Plan states that SSER #10 (which reported on fuel pool welds and welding practices) states that the fuel pool liners are not re-quired by FSAR to meet 10CFR50 or ASME B&PV Code requirements (although G&H Speci-j fication 2323-55-18 does impose 10 CFR 50 Appendix B QA Progra requirements).

The fuel pool liners also are not required to be designed and erected to meet Seismic Category I criteria.

Additionally, the background states that the observations of SSER #10 notwith-

. standing, G&H Specification 2323-55-18, Revision April 15, 1985, Paragraph 1.1 does identify the stainless steel liner systems (except the Unit 1 and Unit 2 Reactor Building Refueling Cavities) as Nuclear Safety Related. This includes the spent fuel storage pools, transfer canals, and cask loading pits.

The CPRT will evaluate irregularities in the fuel pool liner travelers and re-lated documentation by a review of liner specifications, drawings and procedures l

to determine the erection, inspection and testing cequirements. A sample of j travelers will be randomly selected from a list of all the spent fuel pool, trans-fer canal, and cask loading pit travelers used during erection of the liner and associated components. The sample will be selected to provide at least a 95/5 I screen. A minimum random sample size of 60 is required to meet this condition l in accordance with CPRT Program Plan, Appendix D, Table 1.

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l

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A sample review is considered a reasonable approach for the following reasons:

No programmatic deficiencies have been identified in this population to date, and the population of travelers is homogeneous in that all the work was accom-plished by the same crafts using the same procedures.

The CPRT will review the sample travelers to determine if all the required inspections were performed to the applicable design and procedure requirements and that the travelers were properly completed. The review will be conducted using a documentation data sheet and will include, but is not limited to, veri-fication of date entries and authorized inspection sign-offs.

2.2.11.3 Staff Evaluation The staff's evaluation finds that this ISAP correctly identifies the issue as:

the Applicant's inability to maintain an effective and controlled QC Inspection Program for fuel pool liner fabrication and installation. This ISAP addresses this issue based on the same premise that the TRT used for their assessment, namely, that the G&H specification imposed the requirement for a QA Program in accordance with 10CFR50 Appendix B, although this was not an FSAR commitment.

Additionally, this evaluation finds that the plan adequately addresses the NRC's concern and that implementation of the methodology described in the plan will evaluate and resolve the issue. The plan describes that fuel pool liner inspection records shall be in compliance with the inspection record require-ments of 10CFR50, Appendix B, Criterion X, " Inspection", and Criterion XVII,

" Quality Assurance Records", and the associated commitments of CPSES/FSAR, paragraphs 17.1.10 and 17.1.17, respectively. The staff finds these criteria to be appropriate.

m a . " -----

'

• Section 4.4, Procedures, contains a narrative pertaining to the development of matrices, checklists and data sheets instead of referencing existing procedures which are applicable to implementation of the plan. This is not in compliance with the Program Plan, Attachment 3, ISAP format, which requires referencing existing procedures.

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2.2.11.4 Conclusion

'f5 /

The staff concludes that this plan is acceptable, based on evaluation that implementation of the plan will evaluate and resolve the issue and that appropriate criteria are used to determine compliance with 10CFR50 Appendix B even though these criteria are not an FSAR commitment. However, Section 4.4 must be revised to comply with the Program Plan, Attachment 3. During imple-mentation of the plan, the staff will confirm that the revision has been accom-p11shed.

2.2.12 Onsite Fabrication (VII.b.1) 2.2.12.1 Introduction This ISAP will assess and resolve the NRC's concern regarding the procedural and management control of the fabrication shop work activities at CPSES.

2.2.12.2 CPRT Approach The CPRT will implement this Plan in a two-step approach, the fi t of which will address concerns that may be evaluated by review of sa ty-r ated fabrica-tion document packages. This evaluation will assess the proper completion of material requisitions, fabricated threads conformance and shop fabrication to memos and sketches. Additionally, this step will identify populations of ASME and non-ASME saf ated fabricated pieces, and evaluate a random sample of at least 60 fabricated pieces each for both ASME and non-ASME safety related fabricated items in accordance with the CPRT Program Plan, Appendix D, CPRT Sampling Approach, Applications and Guidelines. If documentation discrepancies are identified, the CPRT will perform reinspections of items using checklists of appropriate attributes developed under this Plan and the self-initiated ISAP VII.c.

The second step will address concerns which may be evaluated by review of pro-cedures, survey, surveillance, and audit records to identify trends and correc-tive action effectiveness in: scrap and salvage control; safety, non-safety and bulk material segregation; and site surveillance of material storage.

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The data derived from the implementation of the two steps described above will be analyzed to determine if the shop fabrication activities have met the re-quirements of 10CFR50, Appendix B, Criteria V, IX and X and the FSAR.

The Plan also describes its interaction with ISAP VII.a. ich addresses material traceability, and also clarifies that a craft training concern, a part of the site fabrication issue, is addressed in ISAP I.d.3.

2.2.12.3 Staff Evaluation This evaluation assessed that the Plan identified the issue correctly and finds that the methodology when implemented will address the NRC's concern, and will determine compliance with the applicable criteria of 10CFR50, Appendix B.

Section 4.3 states in part: "All personnel associated with the analysis and evaluation of findings ... " Since the Program Plan, Appendix E, applies to the classification of discrepancies, the staff finds that the word findings is not an appropriate classification, and does not comply with Appendix E.

Additionally, this evaluation finds that Sections 4.4 procedures and 4.5 Standards / Acceptance criteria contain narrative descriptions of checklists, guidelines, etc., and a vague description of what the criteria will be based on, instead of identification of the procedures and criteria. The two sections do not comply with the Program Plan Attachment 3 ISAP format which requires identification of existing procedures and the Standards / Acceptance criteria.

2.2.12.4 Conclusion The staff's evaluation found that implementation of the plan will adequately address and resolve the issue and determine FSAR compliance. The staff concludes that this ISAP is acceptable. However, Sections 4.3, 4.4 and 4.5 must be revised to comply with the Program Plan, Appendix E, and Attachment 3 respectively.

During implementation of the Plan the staff will confirm that the revision has been accomplished.

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2.2.13 Valve Disassembly (VII.b.2) 2.2.13.1 Introduction This ISAP addresses the NRC's concern regarding valve assembly / disassembly and evaluation of the adequacy of procedures that controlled the disassembly /

reassembly process and determines if valves that required disassembly were pro-perly reassembled; and, if not, whether an improperly reassembled valve could result in a Code violation or have a safety consequence.

2.2.13.2 CPRT Approach

In implementing this Plan to evaluate and resolve the issue, the CPRT will

Identify all valves which have been disassembled and reassembled.

Conduct a procedure review to determine adequacy of control of valve com-ponents during disassembly and reassembly.

Perform a safety consequence analysis to determine if valve component parts from one valve are physically capable of fitting up to another valve of the same type but having a lower pressure / temperature rating or Code class and identify potential risks if such reassembly occurred.

A reinspection of valves which have been disassembled and reassembled to establish confidence that valves were properly reassembled.

~

'i' u j eview applicable procedures, for both construction and QC, to determine if they provided adequate controls of materials during valve disassembly and re-assembly. In addition to proper matching of components, the procedures will be reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process.

In parallel with the procedure review, an analysis will be made to determine the safety consequences of improperly assembled valves. The analysis will include potential failure modes resulting from improper reassembly of the generic 1

l 03/10/86 IV-47 NUO797 SEC IV i

valves in question. Generic valves are those which required disassembly of all valves of that type. This analysis will be performed on a case basis for non-generic valve types pending the results of reinspections.

In addition, an evaluation will be made to define potentiai Code violations which could result from improperly assembly valves.

A reinspection of valves which have been disassembled will be performed to provide assurance that the valves were reassembled using the correct components.

A sample of valves from the population of all valves which have been disassembled will be reinspected and an additional sample of valves from the population comprised of the valves identified in the TRT issues will be reinspected. Both samples will be in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection is considered to be a reasonable approach for the following reasons:

No programmatic deficiencies have been identified in this population to date.

The population of valves which have been disassembled is homogeneous. Speci-fically, all the valves were disassembled by the same craft under the same procedures. Therefore, sampling in accordance with Appendix D will detect, with a high level of accuracy, programmatic errors associated with the pro-cess of disassembling and reassembling valves.

Manufacturers drawings and disassembly procedures will be reviewed and docu-mentation packages will be assembled for those valves selected in the random sample. Inspection procedure will be predicated on the results of this review.

If review of the documentation for a specific valve indicates probable improper reassembly, reinspection will include a verification of internal parts. Pro-bable improper reassembly will be indicated by an inconsistency in internal component serial numbers from one Operation Traveler to another for a particular valve.

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2.2.13.3 Staff Evaluation This evaluation finds that the concern is identified correctly and that imple-mentation of the methodology will evaluate and resolve the issue. The staff is concerned however that the emphasis of the Plan appears to be directed towards valve internal parts. It is acknowledged that the tracking of valve internal parts is_a critical essential element in the CPRT's evaluations. The staff wishes to further identify that the TRT's issue also identified the loss damage and interchange of valve external parts, namely bonnets. This was particularly true in the case of the hand wheel operated diaphragm valves in the spent fuel cooling, boron recycle and chemical volume control systems. Section 4.1.5 states in part: " Probable improper assembly will be indicated by an inconsistency in internal component serial numbers." The CPRT's evaluations must also consider inspection attributes that provide for a check of all valve parts that are traceable by physical part marking (not limited to serial numbers), operations travellers, and in the case of Code class valves, the manufacturers Code Data Report Form NV-1.

Section 4.1 states in part: A safety consequence analysis to determine if valve component parts from one valve are physically capable of fitting up to another valve of the same type but having a lower pressure / temperature rating or code class and identify potential risks if such reassembly occurred. The staff is concerned that the analysis may be limited only to those cases involving lower pressure / temperature ratings when in fact the same potential risks may ensue in cases of higher pressure /tempersture ratings. The staff finds that the concern can be clarified by use of phraseology: " ... different pressure /

temperature ... ". Accordingly, the ISAP must be revised to so state.

Additionally, Section 4.2 procedures does not identify existing procedures and therefore does not comply with the Program Plan Attachment 3 which requires identification of existing proceoures. Also, in Section 4.6 the applicable Ct. des and Standards and FSAR commitments if any are not identified.

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2.2.13.4 Conclusion The staff evaluation finds that implementation of the Plan's methodology will address and resolve the issues, however, the Plan must contain provisions to inspect for the interchange of critical valve external parts (e.g., bonnets) as well as internal parts. Additionally, Sections 4.2 and 4.6 must be revised to comply with the Program Plan Attachment 3.

Based on the evaluation of the Plan's methodology the staff concludes that this ISAP is conditionally acceptable. Final acceptance is pending the staff's confirmation during implementation, that Sections 4.2 and 4.6 have been revised to comply with the Program Plan Attachment 3 and that inspection checklist attributes provide for the inspection of valve externals. Also, during imple-mentation the staff will confirm that Section 4.1 has been revised to state "different pressure / temperature ratings" and that the analysis does in fact address the differences in both cases.

2.2.14 Pipe Support Inspections (VII.b.3) 2.2.14.1 Introduction This ISAP addresses the NRC's concern regarding the adequacy of QC as-built inspections of pipe supports.

t 2.2.14.2 CPRT Approach The Plan scope and methodology describes that the objective of this action plan is to assure the construction quality of pipe supports, by validating the TRT findings and by reinspecting randomly selected samples.

The following tasks are required to accomplish the stated objective:

- Reinspect the TRT sample to validate the TRT identified discrepancies.

Reinspect randomly selected samples of pipe supports. (Note: this rein-spection is performed under the ISAP VII.c program.)

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Evaluate valid discrepancies for safety significance and perform trend analysis.

Determine the root cause, generic implications and programmatic concerns for any construction deficiencies and adverse trends.

Identify / develop procedures required to accomplish the tasks outlined above.

This action plan covers safety related Class 1, 2 and 3 pipe supports in Units 1, 2 and common areas. .

(ib The CPRT will review the documentation used by the TRT in thetr inspections (e.g., specifications, procedures, drawings etc.), prepare reinspection packages and perform reinspections of the items that the TRT initially inspected. The CPRT will compare their inspection results with the TRT's findings and identify the differences or results that cannot be reconciled.

Under this ISAP, the CPRT will assure that the populations of supports to be random sample reinspected include the attributes and instructions required to verify the TRT identified discrepancies in the Action Plan VII.c reinspection checklists and quality instructions for each population identified. (Note:

The required inspections will be performed under Action Plan VII.c.)

Review VII.c inspection results for pipe support populations and identify valid discrepancies.

In addition, the CPRT will evaluate all valid discrepancies for safety signi-ficance and perform trend analysis for all valid deviations. Both of these activities will be performed in accordance with the requirements of the Program Plan, Appendix E, Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Discrepancies Identified by CPRT.

2.2.14.3 Staff Evaluation The Staff's evaluation finds that the NRC's concern is identified correctly and complete identification of the TRT's findings are tabulated in the Plan. Imple-mentation of the Plan's methodology, whicn addresses evaluation of the TRT 03/10/86 IV-51 NUO797 SEC IV

issue combined with the defined interaction with ISAP VII.c, adequately addresses evaluation of the issue. This evaluation finds that existing procedures appli-cable to plan implementation are identified. However, Section 4.5 Acceptance Criteria describes activities performed by the CPRT instead of identifying the Codes / Standards and FSAR commitment. The section does not comply with the Program Plan, Attachment 3, ISAP format which requires identification of stand-ards/ acceptance criteria.

2.2.14.4 Conclusion The staff evaluation finds that the NRC's concern is correctly identified and that implementation of the Plan will adequately evaluate the issue. The staff finds however that although the Plan contains sufficient information to deter-mine acceptability /non-acceptability of the items reinspected, the Plan lacks identification of the Codes / Standards and FSAR commitment which are used as comparisons to resolve the issue (e.g., inadequacy of QC inspections) and to determine compliance. Accordingly, the staff concludes that this ISAP is con-ditionally accepted. During implementation, the staff will confirm that the ISAP Section 4.5 has been revised to comply with the Program Plan Attachment 3 in the identification of Standards / Acceptance criteria.

2.2.15 Hilti Anchor Bolt Inspections (VII.b.4) 2.2.15.1 Introduction This ISAP addresses the NRC's concern regarding Hilti anchor bolt installation on pipe supports and electrical raceway supports.

2.2.15.2 CPRT Approach The objective of this action plan is to assure the construction quality with respect to Hilti anchor bolt installation. Implications resulting from the TRT findings will be resolved by reinspection for safety-significant attributes of Hilti bolts.

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The following tasks will be implemented to achieve these objectives:

Review for safety-significant attributes.

Insure inclusion of safety-significant attributes in Action Plan VII.c.

Review for commonality in requirements among various project (discipline) documents.

Evaluate sample size.

Initiate a Hilti torque verification program that correlates the documentation being reviewed fer setting of Hilti's with actual field results.

Report programmatic implications with specific action plan tasks to react to these implications.

Under this Plan the CPRT will review specifications and procedures and identify safety significant attri%tes that are in accordance with those attributes applicable to inspection performed under the self-initiated ISAP VII.c.

Thespecificatiokprocedures,QCinspections,andtrainingproceduresand records for Craft installing Hilti bolts for various items, i.e., electrical raceway supports, pipe supports, HVAC supports, conduit supports, equipment supports, etc., on Units 1, 2 and common will be reviewed to determine whether they are the same. If so, M e results of inspection of these items will \e be considered applicable to all Hilti bolt installations. If not, samples from other populations of Hilti bolts in Units 1, 2 and common will be inspected. .

Reinspections be performed in accordance with Action Plan VII.c andW' include a) sample reinspection of Hilti bolt installations as a reinspection attribute and b) documentation reviews to conclude that appropriate surveillance attributes had been properly noted. This action plan for Hilti bolt installations will utilize the results of tne above inspections as well as additional inspec-tions to resolve the Hilti bcit concerns.

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To provide additional assurance in the results from the document review for the non-recreatable attribute of " setting" of Hilti bolts, the physical condition of these bolts will be checked by a torque verification program. This program willconsistoftorquecheckinganumberofHiltiboltsfrom[lectricalgaceway

/upports,pipesupports,andHVACductsupports. Based on engineering evaluation of this pragram, further pull-tests of questionable samples will be considered.

Pull-tests, if required, will be based on determining the Hilti bolts resistance to the service load required of the bolt.

Programmatic implications will be reported to the Manager - QA/QC - Programmatic Issues, and those with potential impact on other action plans will be provided to the affected Issue Plan Coordinator for any necessary action.

2.2.15.3 Staff Evaluation The staff's evaluation finds that the issue is identified correctly in the Plan, and the Plan is sufficient in scope and depth to adequately address the issue. This evaluation find's that the CPRT's review of applicable documentation will identify the inspection attributes. Evaluation of physical torque tests and p -t ts performed under this Plan combined with evaluation of the results of ins ctions performed under ISAP VII.c will provide sufficient information to enable a conclusion regarding the Hilti-bolt installations.

7 it.;t ; LTT ;; x-----^d ^ tt Section 4.6 Acceptance Criteria contains a narrative description of what the CPRT will do to establish the acceptance criteria instead of specific identification of the documents that yield the criteria. This does not comply with the Program Plan Attachment 3 ISAP Format which requires the identification of Standards / Acceptance criteria. Accordingly, Section 4.6 must be revised to comply with Attachment 3.

The staff notes that the torque verification program will be accomplished by reinspecting for nut rotation resistance to a percentage of the original torque setting value defined by engineering evaluation. Since the amount of torque used is critical to verifigation of proper seating of the Hilti in the concrete, the staff will review this Iletail.

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2.2.15.4 Conclusion n

'T h In its evaluation of this ISAP, the staff Jeemd that the issue is identified correctly and the Plan's methodology is adequately descriptive of the activity that is essential to evaluation and resolution of the issue. The percentage of torque used in the torque verification program is an issue of concern that will be subject to staff review during implementation. Accporgly, the staff con-cludes that this ISAP is acceptable. Section 4.6 doesg3ccurately identify the type of document from which the acceptance criteria will be derived. Those

specific documents, of necessity, were used to establish the inspection attributes.

Therefore, discrete identification is known. Accordingly, during implementation of the Plan the staff will confirm that Section 4.6 has been revised to comply with t.he Program Plan, Attachment 3.

2.2.16 Cable Tray Raceway Supports Inspection (VII.b.5)

This ISAP was deleted from the CPRT Program Plan, Revision 3, Appendix C.

This ISAP was initially developed to respond to QA/QC issues that were identified in the NRC letter to the Applicant January 8, 1983. These were subsequently published in May 1985 in NUREG 0797 Safety Evaluation Report Supplement 11, Appendix 0, Reference Pages 0-295 through 0-298, and addressed electrical raceway support inspections. The areas of concern were related to the following:

1. Undersized welds

2. Misplaced welds

3. Unauthorized configuration changes

4. Hilti anchor bolt installation deficiencies

5. Undersize nuts These QA/QC issues arose from sources other than the CPRT, (in this case the SER Supplement 11), therefore are classified as external source issues.

The staff's evaluation of CPRT Program Documentation finds that the concern will be addressed in ISAPs I.c, VII.b.4, VII.c and DSAP XI.

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The staff has evaluated the CPRT's Program Plan methodology that will ensure that all of the external source issues (inrnlud n QA/QC issues) will be identi-fied, evaluated and resolved. The staff [ he Program Pla- to be acceptable in this regard. The staff is confident that the issue of concern that was to be addressed in ISAP VII.b.5 (deleted) will be satisfactorily addressed by the CPRT under the Plan's methodology for resolving the external source issues.

During implementation of the Program Plan, the CPRT shall offer a reasonable explanation for the deletion of ISAP VII.b.5 and identify the action plan (s) that address this issue, and the staff will confirm the CRPT's action.

2.3 Civil / Structural Issues Five external source issues relating to construction adequacy in the civil /

structural area were identified in NUREG-0797, Supplement No. 8 (Reference ).

One additional external source issue (I.c) was identified in NUREG-0797, Supple-ment No. 7, which is now included as part of the civil / structural issues.

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 adequacy:

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 Structures II.d Seismic Design of Control-Room Ceiling Elements II.e Rebar in Fuel-Handling Building 2.3.1 ISAP II.a, Reinforcing Steel in the Reactor Cavity 2.3.1.1 Introduction This ISAP addresses a documented occurrence in which reinforcing steel was omitted from a unit 1 reactor cavity concrete placement between the 812-foot and 819-foot-1/2-inch elevations. Although the omission was documented, justifi-Cdtion supporting the engineering conclusioa to s was not available.

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2.3.1.2 CPRT Approach The action plan is designed to assess the design adequacy of the existing as-built condition of the reactor cavity wall and other areas within Units 1 and 2 where rebars were omitted. This assessment will include an evaluation of the engineering / field design-change interface.

All documented instances of rebar omission will be reviewed to assure that proper engineering evaluation and documentation exist in support of the dispo-sition of each item. I;,cddition, a random sample of 60 concrete pour cards will be reviewed to verify that current design documents were used in construction.

Procrdures governing design changes will be reviewed to verify the adequacy of methods for controlling implementation 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 commitments.

The CPRT methodology in reviewing documentation and evaluation of procedures governing the engineering / field design-change interface and the review of the evaluation of the implementation of these procedures is consistent with current verification practices.

However, the plan should recognize the possibility that some structural members may be deficient when reinforcing steel was omitted. Furthermore, the logic diagram in the attachment to the ISAP is incorrect.

The second vertical branch at the lef t and the s-shaped branch .aar the upper right hand corner should be deleted.

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l 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, with the qualification that deficient structural members needs to be addressed for-mally in the plan and the logic diagram corrected.

2.1.2 ISAP II.b, Concrete Compression Strength 2.3.2.1 Introduction This ISAP addresses civl's/ structural allegations that some concrete strength tests were falsified. The applicant's position is that the uniformity of the concrete placed appears to minimize the likelihood that low concrete strengths were obtained. The staff felt that additional action by the licensee was neces-sary to provide 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 (Con-crete at Issue, CAI) and concrete poured outside this period (Control Concrete, CC).

All testing will be in accordance with ASTM procedures. The area for testing l will be limited to the exposed surface area where the Schmidt Hammer Test can be performed. Concrete-cylinder test data for the two populations will also be l obtained, reviewed, and used for reference.

2 If, after reviewing results of the Schmidt Hammer Test, the CAI population is 1

found to have lower strength than the CC population, core tests, calibration of the Schmidt Hammer with known concrete strength or analysis will be performed.

Any such actions will be documented as a revision to this action plan.

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2.3.2.3 Staff Evaluation The CPRT methodology for reviewing concrete-cylinder strength tests and for performing Schmidt Hammer 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 Conclusion 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.

2.3.2 ISAP II.C, Maintenance of Air Gap Between Concrete Structure 2.3.3.1 Introduction The TRT in NUREG-0797, Supplement 8, raised a concern that TUEC had not ade-Quately 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 earthquake.

2.3.3.2 CPRT Approach This ISAP will assess the current as-built condition to determine the extent and cause of the condition. An evaluation will be performed to determine the design significance of the as-built condition. Any identified debris or roto-l foam that impacts the design basis will be removed.

The final as-built condition of all separation between Category I buildings r.nd between Category I and non-Category I tuildings will be determined as well as documentation of the design acceptability.

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Quality Control (QC) will document the final as-built conditions and a third party will overview this process.

2.3.3.3 Staff Evaluation The staff has reviewed the methodology to be 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 commitments.

In addition, the cause of the existing condition (s) and its applicability to other areas of the plant will be reviewed and evaluated. However, the flow diagram given in the ISAP is not correct. There is no indication where item A is generated and item C serves no purpose.

2.3.3.4 Conclusions The action plan is responsive and with proper implementation, including design acceptability for FSAR commitments, should resolve NRC concerns with the qualifi-cation that the flow diagram"be corrected.

2.3.4 ISAP II.d Seismic Design of Control Room Ceiling Elements 2.3.4.1 Introduction This review of the design of Seismic Category II items is a result of the allega-tion that the field run conduit, the drywall ceiling and the lighting installed in the area above the control room were classified nonseismic and may fail during a seismic event. This review is to assure that proper consideration was given to governing design criteria in the design of Seismic Category II items.

CPSES General Design Criteria No. 19 requires that safe occupancy of the control room during abnormal conditions be provided for in the design. The Comanche Peak Steam Electric Station (CPSES) control room is in a seismic Category I structure, with certain seismic Category II and nonseismic components located in the ceiling. Seismic Category I refers to those systems or components which must remain functional in the event of an earthquake. Seismic Category II refers to those systems or components whose continued functioning is not required, but whose failure could reduce the functioning of any seismic Category I system 03/10/86 IV-60 NUO797 SEC IV

or component (as defined in Regulatory Guide 1.29) to an unacceptable level or could result in an incapacitating injury to occupants of the control room.

Seismic Category II systems or components are, therefore, designed and constructed so that a Safe Shutdown Earthquake (SSE) will not cause such failure or injury.

2.3.4.2 CPRT Approach In assessing this allegation, the TRT reviewed the CPSES nonsafety-related conduit, lighting fixtures, and the suspended ceilings installed in the control room. Three types of suspended ceiling exist in the control room; drywall, louvered and acoustical. Item II.d, of Appendix C (Civil / Structural ISAPs) of the CPRT Program Plan contains a complete description of the actions taken to assess this allegation, along with assessing the design adequacy of Seismic Category II items, in general, to assure that the conditions identified by the allegation are not applicable tc other Category II and nonseismic structure systems and components at CPSES.

The significance of Category II and nonseismic items is identified in Regulatory Guide 1.29, which states that portions of structures, systems, 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 constructed 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 verification 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 determine if there is a potential for seismic interaction with safety-related items. Any architectural features in Units 1 and 2 which have potential seismic interaction will be either modified or sub-jected to a damage study assessment. This includes a review of all resolutions of unacceptable interactions. The third party will review procedures, methods for conducting the seinic 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 for seismic interaction with safety-related items, including selection criteria, will be identifed.

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The third party will review the criteria for evaluation of the consequences of interactions and methods for performing the damage study and will perform a comparative damage assessment in selected rooms to assess the consistency with which interactions are identified. The rooms will be chosen based on functional and physical aspects, importance of components, and balance of types of non-seismic items.

2.3.4.3 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 address the specific concern that Seismic Category II items were not properly designed in the area above tt.e 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.

However, the flow charts in Figures II.d-1 and II.d-2 do not reflect the in-tended use of third party review. In Fig. II.d-1 it is indicated that the new ceiling will be installed without regard to the results of the third party review. The installation should be made contingent on a successful third party review and the arrowhead between " Design New Ceiling" and "A" should be revised.

In Fig II.d.2 implementation of design should also be made contingent on a successful third party review.

2.3.4.4 Conclusion The staff concludes that the Program Plan appropriately addresses the staff concerns and is acceptable with the qualification that Figures IId-1 and II.d-2 be corrected.

2.3.5 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.

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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, will assess the work of the construction crew that could hve cut additional rebar without proper authorization, and will review controls governing rebar cutting.

Design calculations will be generated if required.

All caes where rebar cutting was requested for installation of Hilti bolts will be reviewed and comparison made between rebar pattern and embedment depth of the intalled bolts.

The adequacy of the procedures and controls governing rebar cutting will be reviewed.

2.3.5.3 Staff Evaluation 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 reanalysis is required, the requirments of ACI-318-71 and FSAR commitments will be consistent with original design criteria. However, the plan does not mention corrective actions to be undertaken if cut rebar produce an unacceptable

. structural member. Furthermore, the logic diagram given in the ISAP is incorrect, a in that there are no arrcws connected to the lower right-hand box.

Nk ( 2.3.5.4 Conclusions The approach described in this ISAP is acceptable. Proper implementation will

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assure the acceptability of as-built conditions with the qualification that the possibility of structural deficiencies must be addressed and the logic diagram corrected.

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2.3.6 ISAP I.c, Electrical Conduit Supports 2.3.6.1 Introduction This issue-specific action plan addresses the installation of nonsafety-related conduit supports for conduit two inches in diameter or less 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 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 interacting with safety-related components.

A seismic analysis will be performed that verifies stability and/or acceptable interaction during an earthquake. Two separate samples will be derived from the Unit I and common areas. One will be randomly selected and the other will be derived on an engineering basis.

1 The QA/QC Construction Adequacy for Train C conduit will be addressed under CPRT Action Plans VII.a.1, " Quality Control Inspection", and VII.b.4, "Hilti Bolts".

2.3.6.3 Staff Evaluation The staff has reviewed the scope and methodology 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 reasonable review of the entire population and a lower bound on seismic performance.

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The seismic analysis of both populations will determine whether the two-inch-and-under conduit supports meet the requirements of FSAR Section 3.78.2.8 and Regula-tory 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 Section 4.1.2.5 (page 10). The intent of this statement relative to sample expansion and compliance with Appendix 0 of the Plan is unclear.

2.3.6.4 Conclusions The general scope and methodology contained in this ISAP is responsive and with proper implementation, including design acceptability for FSAR commitments, should resolve NRC concerns.

However, before this ISAP can be accepted by the staff, clarification and/or justification of the statement in Section 4.1.2.1 and 4.1.2.5 is needed.

2.4 Mechanical & Piping Issues The mechanical / piping issues evolved from the TRT's assessment of allegations pertaining to the mechanical / piping area at CPSES. These issues were initially presented to the applicant by letter from the NRC dated November 29, 1984 and the detailed assessments were published in NUREG-0797 Safety Evaluation Report Supplement 10 issued in April 1985.

Also included in this section are concerns identified as miscellaneous issues which arose from the TRT's investigations of allegations in the Civil / Structural area. These issues were initially presented to the applicant by letter from the NRC dated November 29, 1984, and the detailed assessments were published in NUREG-0797 Safety Evaluation Report Supplement 8 issued in February 1985.

Under the Program Plan, Appendix B, Quality of Construction and QA/QC Adequacy Program Plan, the CPRT developed ISAPs to address and resolve the mechanical /

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piping and miscellaneous issues related to construction adequacy. As determined by the CPRT, the ISAPs may employ one or more of the following approaches:

hardware reinspection, documentation review, walkdown inspections, engineering review and analysis, and review and verification of TUGC0 corrective actions plans.

The CPRT Program has also addressed the design-related aspects of two of the M/P ISAPs (V.b and V.c) in the Design Adequacy Plan. I'" ..b is evaluated in Civil / Structural DSAP VIII, and ISAP V.c is addressed in Piping / Supports DSAP IX.

The staff's evaluation of each of the action plans that address the M/P and miscellaneous issues related to the Construction Adequi.cy Program are presented in the following sections.

2.4.1 Inspection of Certain Types of Skewed Welds in hF Supports (V.a).

2.4.1.1 Introduction During the CPSES ASLB hearings an allegation was made that Brown & Root (B&R)

QC inspectors did not have adequate instructions or training to properly measure the size of skewed fillet welds during the inspection of pipe supports. NRC Region IV inspection reports 50-445/82-14 and 50-445/84-08 substantiated the allegations and reviewed corrective action proposed by TUEC and the results of its i:nplementation.

The TRT assessed the same allegation during its July-September 1984 onsite investigation and concluded that TUEC could not provide documentation that certain types of skewed fillet welds were reinspected correctly (welds that exhibited a skewed condition; i.e., interfaces of curved sections). Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety significant condition.

2.4.1.2 CPRT Approach In response to the November 29, 1984 NRC letter, TUEC developed the CPRT Program Plan to include ISAP Va. This ISAP addressed the concerns of the TRT by 03/10/86 IV-66 NUO797 SEC IV l l

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establishing a scope and methodology, Sections 4.1.1 through 4.1.6, for the action plan that is responsive to the issue. The action plan included a review of a documented chronology of inspection methods involving skewed welds to cor-relate the period of time and specific procedure revisions for the inspection of Type 2 skewed welds. Procedures QI-QAP-11.1-26, QI-QAP-11.1-28, and CP-QAP-12.1 will be reviewed to determine if the method of inspection for Type 2 skewed welds was adequate to address the unique aspects of skewed weld dimen-sional configurations and revised if necessary.

TUEC also committed to assess the adequacy of the implementation of the appro-priate inspection procedures by establishing a random sample of Type 2 skewed welds to be reinspected. The sample plan is based on achieving a 95% confidence level that less than 5% of Type 2 skewed welds were not inspected properly and

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may result in a ty significant condition. The reinspections will be con-ducted by a th- rty using the revised procedures.

I Finally, the results of the procedure review and physical reinspections will be evaluated to assess root cause and generic implications. Corrective action will be taken whenever modifications and prccedural changes are required. A results report will be written to document the results of all procedure reviews, physical modifications, trend analysis and corrective actions.

2.4.1.3 Staff Evaluation The staff has reviewed the CPRT Program Plan, ISAP V.a and has the following observations.

The plan had identified chronology of inspection methods and its relationship to procedure revisions to be the proper starting point. The plan also addresses the adequacy of implementation of the appropriate inspection procedures by means of the proposed sampling plan. The staff believes that this aspect of the plan will identify the root cause of the skewed weld inspection problem.

The staff expects the root cause and subsequent generic implications of this issue to be positively identified, since this issue had been previously identi-fled in the ASLB hearings and addressed by TUEC. The fact that a procedure interpretation problem existed after action by TUEC is suggestive that there 03/10/86 IV-67 NUO797 SEC IV

w could be generic implications with respect to procedure revision and implementat-ion in other areas of the plant.

The staff also reviewed the CPRT response to the staff comments (dated Septem-ber 30, 1985) on ISAP Va. In Revision 3 of the Program Plan, the responses for Items 2-4 are acceptable since they are mainly clarifying in nature. However, the response to Item I requires additional explanation. The staff could not find where both Type 1 and Type 2 skewed welds were addressed by B&R procedure QI-QAP-11.1-28. If this were the case, then " stanchion welds" would have been inspected using the skewed weld inspection methods and marked as such on the QC checklist.

2.4.1.4 Conclusions hou/

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The staffAconducted an evaluation of the CPRT Program Plan for ISAP V.a and h the action rian to be generally responsive to the issues raised since the plan addressed inspection methods, procedure revisions, and reinspections. The staff, however, requires assurance that the root cause of the issue and its generic implications are properly addressed in the action. The CPRT TR1 issues manager should assure the staff that both items will be addressed in the results report. The staff perceives the root cause and generic implication aspect of this issue as important, since the inspection techniques for skewed welds had been addressed previously by TUEC.

In addition, the response by the CPRT to Item 1 of the staff letter of Septem-ber 30, 1985 concerning ISAP V.a is unacceptable. The staff requires further explanation concerning the intent of procedure QI-QAP-11.1-28 with respect to skewed welds.

2.4.2 Improper Shortening of Anchor Bolts in Steam Generator (SG) Upper Lateral Supports (V.b).

2.4.2.1 Introduction During the July-September 1984 investigation, the TRT was informed that some of the anchor bolts in the steam generator upper lateral support were shortened ouring installation without proper authorization to less than the length shown 03/10/86 IV-68 NUO797 SEC IV

on the design drawings. Based on the results of its investigation, the TRT requested that TUEC provide evidence, such as ultrasonic measureme hat would verify the actual installed bolt lengths.

The TRT requested that should the bolts be determined to have been installed to engagements less than that shown of design drawings, TUEC shall:

Replace shortened bolts with bolts of the proper length or provide analysis to justify the adequacy of the installed bolts.

Provide justification or propose measures to ensure that no similar concern exists for other bolting.

TUEC performed reinspection of the anchor bolts and determined that insufficient thread engagement existed in specific locations. This deficiency was reported on January 17, 1985 in accordance with 10 CFR 50.55(e). In addition, an evalua-tion of the design of the connection by the third party determined that the existing design is not adequate for the specified loading conditions.

2.4.2.2 CPRT Approach The CPRT Plan describes the measures that will be used to ensure that the steam generator upper lateral support beams meet design requirements and to review similar installations to determine if this issue pertains to other designs.

As stated in Section 4.1.1 of ISAP V.b, thread engagement of the SG upper lateral restraint anchor bolts was determined to be less than required by design on the basis of inspections performed in Unit 1.

A reevaluation of the current design and loading conditions will be performed.

Revisions to the design or analysis will be reviewed by the third party and will provide the basis for reinspection and rework. A similar inspection will be performed for Unit 2 and appropriate action taken. Section 4.1.2 provides for examination of.the bolts and blind threaded holes during the bolt replace-ment to aid in the root cause assessment. This will include review of dimensional tolerance of assembly parts.

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As part of the CPRT effort on this issue the Plan in Section 4.1.3 of ISAP V.b provides for the assessment of the potential generic applicability of the bolt thread engagement issue for two other populations:

Richmond Inserts - Richmond inserts used in ASME pipe supports will be randomly sampled to determine that bolt engagement meets design requirements.

If any cases of inadequate bolt engagement are identified, an assessment will be made to determine the ability of the component to carry its design load. If it is determined that the component cannot carry its design load increased sampling up to 100% reinspection will be utilized. If it is determined that the component can still carry its design load for all observed cases of less than design thread engagement, the need for additional inspection will be based on an evaluation of trends in the inspection data.

Bolted Connections - Blind hole bolted connections where thread engagement is important will be identified by an engineering review of structural /

mechanical 2.4.2 drawings. The blind holes identified will form a second sample population and any cases of inadequate bolt engagement in the in-spected sample will be evaluated as described above for Richmond inserts.

l In Sections 4.1.4 and 4.1.5 of ISAP V.b, the CPRT commits to a third party review of the process by which critical attributes of bolted connections were

.!g . specified and the definition of their associated inspection criteria and docu-

y. eentation requirements. This will include an evaluation of the apparent lack h' of installation records for the SG upper lateral restraint. A third party

, overview of all aspects of the Action Plan will also be completed. This will include the inspection plans for the UT of installed bolts as defined in 4.1.3, design calculations required for the evaluation of shortened bolts, and visual inspection of bolts and threaded holes during bolt replacement. Finally, based upon the methods described in Sections 4.1.2 through 4.1.5 and their results, the root cause and generic implications will be determined. The adequacy of the design of the upper lateral support itself will be addressed separately under DSAP VIII.

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l 2.4.2.3 Staff Evaluation The staff, since it first identified this issue in its November 8, 1984 letter to TUEC, has been actively following the activities concerning this subject. l The staff feels that the CPRT Program Plan has the ability to address all staff concerns relating to the specific issue based on the following observations.

The Plan addresses possible generic implications by reviewing other designs that have the potential for similar thread engagement deviations. The Plan provides for performing random inspections of Richmond inserts and other blind bolt installations. The staff, however, still has a concern that when it is determined that a component can still carry its design load for all observed cases of less than adequate engagement, the need for additional inspection will be based on an evaluation of the trends in the inspection data. The staff must look at the basis for this evaluation case-by-case to determine if the trends l do or do not require additional inspections.

The CPRT response to the three questions raised in the NRC Staff Evaluation dated September 30, 1985 have been responded to in a manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan.

2.4.2.4 Conclusions The staff concludes that if ISAP V.b is implemented as stated in the Plan the areas related to the original concern will be identified and resolved based on sound engineering practice, FSAR commitments and NRC guidelines. However, the staff has raised a concern that the use of trends of inspection data to deter-mine the need for additional inspections must be reviewed on a case-by-case basis.

2.4.3 Design Consideration for Piping Systems Between Seismic Category I and Nonseismic Category I Buildings (V.c).

2.4.3.1 Introduction The TRT in reviewing the Comanche Peak Special Review Team Report determined that certain piping systems are routed from the Electrical Control Building (seismic Category I) to the Turbine Building (nonseismic Category I) without 03/10/86 IV-71 NUO797 SEC IV

any isolation. Since the FSAR postulates Turbine Building failure during a safe shutdown earthquake (SSE) the effect of Turbine Building failures on any nonisolated piping routed from any seismic Category I building to the Turbine Building must be considered.

In addition, for nonseismic Category I piping connected to seismic Category I piping, the dynamic effects of the nonseismic Category I piping must be considered in the seismic design of the seismic Category I piping and supports, unless it can be shown that the dynamic effects of the nonseismit Category I piping are isolated by anchors or restraints designed to carry the combined loadings from both piping systems.

2.4.3.2 CPRT Approach Since the Project Piping and Supports Program (PPSP) together with the Design Adequacy Program (DAP) includes provisions for significant piping reanalysis and associated support requalification, tl.e CPRT will address the major concerns of this issue within the PPSP and DAP. The scope of this specific action plan will be limited to the following activities as outlined in Sections 4.1.1 through 4.1.3 of ISAP V.c:

Identification of all Unit 1, 2 and common, piping which has a seismic /

nonseismic interface. This includes:

Category I piping entering a non-Category I Building.

Piping with a class change from Category I to non-Category I.

Piping runs with attached piping which have a class change.

NNS piping runs which have a portion which is seismically analyzed to postulate breaks.

A review and dicussion of the events related to and the reasons for the auxiliary steam pipe situation on which this issue is based.

Recommendations to the PPSP and/or the DAP based on the results of the two items above. Any potential implications which should be considered during the PPSP and DAP implementation will be highlighted.

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2.4.3.3 Staff Evaluation The staff has reviewed the action plan for ISAP V.c, and is satisfied that the CPRT Plan understands the original concern and has the potential to identify items similar to the original concern. In addition, the NRC staff has performed an c dat at Stone & Webster Engineering Corporation (SWEC) offices. The purpose of this audit was to discuss with SWEC their scope and methodology for addressing this concern. The SWEC method has been determined by the staff to have the potential to identify and address this concern.

The CPRT response to the four questions raised in the NRC Staff Evaluation dated September 30, 1985 have been responded to in a manner acceptable to the NRC staff in Revision 3 of the CPRT Program Plan.

2.4.3.4 Conclusions The staff concludes that if ISAP V.c is implemented as stated in the Plan all areas related to the original concern will be identified and resolved in a manner consistent with sound engineering practice, FSAR commitments and NRC guidelines.

2.4.4 Plug Welds (V.d).

2.4.4.1 Introduction The TRT investigated allegations that incorrectly located bolt holes in base-plates, pipe supports, and cable tray supports were " plug welfed" without authori-zation, with undocumented weld filler metal and without Quality Control inspect-ion. The TRT concluod thac the repair of misdrilled holes by welding was not prohibited by the appropriate stditions of the applicable CcJes. .The TRT review of Brown & Root specifications established that misdrillPJ holes were regarded as base material defects and were required to be dispr itioned by NCR action or enginee-ing evaluation.

The TRT concluded that the identification of undocumented " plug welds" and the difficulty in detecting them raised a generic concern as to the potential exist-ence of an unknown number of unauthorized " plug welds" of questionable quality.

Potentially defective welds in highly stressed areas could have safety significance.

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The TRT required that the Applicant modify a plan of action already proposed to NRC Region IV with respect to specific items or perform a bounding analysis to assess the generic effects of undocumented " plug welds" on the ability of pipe supports, cable tray supports, and baseplates to perform their intended function.

2.4.4.2 CPRT Approach Section 4.1 of ISAP V.d defines the following two CPRT Action Plan objectives:

1. Confirmation of the presence or absence of undocumented " plug welds" in ASME pipe supports and baseplate, and the subsequent assessment of their safety significance.

2. Assessment of the quality of cable tray supports containing undocumented plug welds.

These objectives were to be accomplished by a combination of third party (Engi-neering Research Corp. [ERC]) sample inspections and third party overview of TUEC engineering evaluations. The sample inspections were to be used to charac-terize the frequency of occurrence and location of plug welds to be evaluated; and the engineering evaluations were to be used to assess the significance of incontrolled plug welds identified during the inspections.

Relative to the first of the above stated objectives, two random samples of ASME Code pipe supports and baseplates were to be inspected. One of these samples was to be drawn from the Unit 1 and Common Areas population, and the second from the Unit 2 population. The use of two samples was stated to be based not on any expected difference between the two populations but on the intent to increase the inspectica coverage in anticipation of a low frequency of occurrence of unauthorized or undocumented plug welds. Sampling was to be consistent with Appendix D of the Program Plan with a minimum sample size of 60 and a detection number'of zero. However, the confidence level achievable by this sampling inspection was stated to be less than that described in Appendix D. The Action Plan recognized that, based on the results of test inspections of painted mockup supports containing plug welds, the inspection technique would only detect about 85% of unauthorized or undocumented plug welds.

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ERC field inspectors to be utilized in the sampling inspections were to be selected based on their performance in detecting plug welds in the mockups- .

Unauthorized plug welds identified in ASME Code pipe supports and baseplates were to be identified in nonconformance reports (NCRs) and engineering evalu-ations performed to determine the effects of these welds on the structural integrity of the affected supports and baseplates.

If no undocumented plug welds were found in the samples inspected, it would be cor.cluded that there is reasonable assurance that the structural integrity of the pipe supports and baseplates had not been degraded by the presence of un-authorized plug welds. Further, if all unauthorized or undocumented welds found were determined by inspection or engineering evaluation not to affect the quality of the affected pipe supports or baseplates, it was proposed that the need for additional inspection be based on the observed trends in the sampling inspection. However, if one or more supports or baseplates were found to lack structural integrity due to unauthorized or undocumented plug welds, it was proposed that the sample size be expanded, stratified sampling be utilized or a 100% inspection be performed.

Additionally, a third party review of the existing QC inspection and documen-tation procedures was to be conducted and changes recommended as necessary.

With respect to the second of the above stated objectives, two random samples of cable tray supports were to be inspected. The populations for these samples were to be similar to those for the pipe support and baseplate samples. Addi-tionally, the steps involved in the Action Plan to achieve this second objective pertaining to cable tray supports were to parallel those previously described relating to pipe supports and baseplates. Third party reviews were to be conducted of: (1) Design Change Authorization (DCA) 5347; and (2) the history of the programmatic procedures for QC documentation relating to plug welds. These reviews were stated to be intended to: (1) ascertain if a sufficient basis for the DCA existed at the time of issuance; and (2) assess compliance of the docu-mentation with the QA program and FSAR licensing commitments, respectively.

Furthermore, third party reviews of the results of the sample inspections were to be conducted to assess the root cause and possible generic implications of unauthorized and undocumented plug welds in cable tray supports.

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f 2.4.4.3 Staff Evaluation Based on its review of the CPRT Action Plan relating to unauthorized and un-documented plug welds in ASME pipe supports and baseplates and AISC cable tray supports, the staff found that the plan as currently proposed was unacceptable

, for the following reasons:

(1) The confidence level achievable by the proposed sampling plan was less than that described in Appendix D of the Program Plan. The obtainable confidence level was not quantified and not justified.

(2) As currently proposed, the Action Plan will provide as a minimum assessments of the effects of unauthorized and undocumented plug welds identified in the samples. Additionally, in view of the lack of a fully effective in-spection method for plug welds, it appeared that even a 100% reinspection program would still not provide reasonable assurance that the structural integrity of ASME Code pipe supports and baseplates and AISC cable tray supports have not been compromised by the presence of unauthorized and undocumented plug welds.

(3) Based on the previous two reasons, it further appears that the first alter-i .:tive offered by the staff in its assessment of unauthorized and undocu-mented plug welds is not achievable. Consequently, it appears that only the second of the two staff alternatives is currently available to TUEC.

This second alternative required that bounding analyses be performed to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, cable tray supports and baseplates to serve their intended function.

(4) Details of the third party overview of TUEC engineering evaluations of uncontrolled plug welds identified during the sampling inspections were not provided in the Action Plan. -

l (5) Criteria to determine if the structural integrity of ASME Code pipe supports and baseplates had been degraded by the presence of unauthorized plug welds were not provided in the Action Plan.

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, (6) Criteria to determine if: (a) the samples of ASME Code pipe supports and baseplates were to be expanded, (b) stratified sampling be utilized, or (c) a 100% reinspection be performed were not provided in the Action Plan.

(7) In March of 1985 at the CPRT action plan presentation at CPSES, the TRT stated its position that volumetric examination of any unauthorized plug welds found should be made since the welder, who was trying to avoid QC cognizance, would be inclined to rush the job and may, therefore, have used poor welding techniques. The CPRT has not responded directly to this request.

(8) The sample plan (Paragraph 4.1) and the definition of a reject were stated by the TRT as incomoatible as currently written. CPRT's response references paragraph of 3.4 ISAP V.a, Item 1. This reference was reviewed but does not appear to address the incompatibility noted. Further explanation is required.

(9) In NRC Staff Evaluation of the Comanche Peak Response Team Prograa Plan -

Detailed Comments (Beard Notification No.85-087), identification was requested of the procedure referred to in paragraph 4.1.4. In TUGC0 letter CPRT-113 (previously referenced) responding to the above document, the procedure was identified as QI-QP-11.10-2. However, the procedure identity was not added to paragraph 4.1.4.

2.4.4 Conclusions Based on its evaluation of ISAP V.d, the staff concluded that the CPRT Action Plan was unacceptable. The staff found that the proposed combination of third-party sampling inspections and third party overview of TUEC engineering evalu-ation of uncontrolled plug welds identified during the inspections would not provide reasonable assurance that the structural adequacy of CPSES pipe supports, baseplates and cable tray supports would not be compromised by un:ontrolled plug welds since: (1) the proposed inspection technique was not fully effective and consequently, (2) the confidence level achievable by the Action Plan was less than the designed 95/5 level.

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It appears that the first alternative offered by the staff in its assessment of the significance of uncontrolled plug welds is not achievable and that only the second alternative is currently available. This second alternative required

> that bounding analyses be performed to assess the generic effects of uncontrolled plug welds on the ability of pipe supports, baseplates and cable tray supports to serv: their intended function.

2.4.5 Repositioning of the Main Steam Line (V.e).

2.4.5.1 Introduction The TRT investigated an allegation that the 32-inch MS line was forced into position by the polar crane and 3-ton come-alongs and that " tension" induced in the line as a result of movement during the alleged incident was still present in the line.

The TRT determined that repositioning of the Unit I loop 1 MS line had been performed due to settlement of temporary supports. The TRT learned that the partially installed line had sagged due to settlement of temporary supports during flushing of the system and/or construction. The TRT also determined that the TUEC piping analysis performed 1 year after the alleged incident did not adequately address the full sequence of events involved in the incident.

Accordingly, the TRT on November 29, 1984, informed TUEC that action was required to resolve this potentially safety-significant condition.

2.4.5.2 CPRT Approach The CPRT approach to resolve the TRT concerns resulting from the TRT investigation of the allegations regarding forced movement of the MS line and improper welding of temporary supports is described in Section 4.0 of ISAP V.e. A review of Sections 4.1 and 4.2 of the CPRT plan indicates that specific engineering evalua-tions of the MS line incident and a generic study of possible damage to other piping will be implemented.

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The specific engineering evaluation includes: reviews of procedures for pipe erection and placement of temporary and permanent pipe supports; interviews of personnel involved in the MS line incident; evaluations of procedures and prac-tices; analytical evaluations of full parametric variations of the line move-ment inputs for the MS line incident; significance of stresses and support loads resulting from the analytical evaluations; reviews of existing UT examin-ations and hydrostatic test data for the affected MS line; and a possible rein-spection program.

The generic study for possible damage in other piping, including the Unit 1, Loop 4, MS line includes: reviews of procedures and specifications for pipe erection and placement of temporary and permanent pipe supports; reviews of Nonconformance Reports (NCRs) and Piping Deviation Request Forms (PDRFs) for

! circumstances similar to the MS line incident; interviews of pipe installation personnel to determine piping subjected to adjustments during fitup; review of all other sources of residual stresses in piping systems; evaluations of the significance of residual stresses due to fitup; possible additional pipe fitup evaluations; and possible modifications to Gibbs & Hill (G&H) specifications and/or related procedures to ensure that piping and associated equipment are not adversely affected during flushing activities and/or by the use of temporary supports.

Section 4.3, " Responsibilities," of ISAP V.e indicates that all activities are to be performed by third party (including a verification of previous work done by RLCA) except for the modification (if required) of procedures and specifi-cations for the control of pipe erection, temporary supports and hydrostatic testing and flushing which was to be a Comanche Peak Project Engineering re-sponsibility.

2.4.5.3 Staff Evaluation The staff review of ISAP V.e determined that the details of the specific engineering evaluation and the generic study of possible damage to other than the Unit 1, Loop 1, MS piping was responsive to the actions required of TUEC by <

the TRT. These actions are given in SSER No. 10, P. N-110, Items 1 through 8.

A comparison of items in the action plan and the actions required of TUEC by 03/10/86 IV-79 .NUO797 SEC IV 1

the TRT found that ISAP V.e was sufficient to unbrella the actions required to resolve the issue, based on an engineering evaluation by the staff.

However, the staff has concerns that:

(1) The third party review of the RCLA work should not be limited to a veri-fication only. Provisions for additional third party investigations should be provided, particularly since RCLA participation has ended.

(2) Although the CPRT has indicated that its investigations performed as part of ISAP V.e, Revision 3, have concluded that the sequence of events de-scribed in SSER No. 10 relating to MS line incident is not correct, the generic implications of settlements of supports and stresses due to hydro-static testing and flushing activities will still be required to be evaluated by TUEC, since the sequence of events described by the TRT could have occur-red elsewhere.

2.4.5.4 Conclusions For the issue concerning the repositioning of the main steam line, the specific engineering evaluation and generic study described in ISAP V.e, Revision 3, of the CPRT Program Plan provides an acceptable basis for resolution of the issues and concerns resulting from the TRT investigations of allegations regarding forced movement of the main steam line and improper welding of temporary supports.

However, final acceptability by the staff is contingent upon verification by the CPRT of proper implementation of the details of the specific engineering evaluations of the main steam line incident and the generic study of possible damage to other piping.

NOTE: This ISAP is now listed by CPRT as a Mechanical ISAP.

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03/10/86 IV-80 NUO797 SEC IV l

2.4.6 ISAP VI.a. Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall 2.4.6.1 Introduction The Gap Between the Reactor Pressure Vessel Reflective Insulation (RPVRI) and the Biological Shield Wall was listed as a miscellaneous issue ira NUREG-0797, Supplement No. 8. The concern arose from the TRT's investigaticns of allegations in the civil / structural area.

2.4.6.2 CPRT Approach This action plan defines the scope and methodology for evaluating the adequacy of the testing and analysis to confirm that adequate airflow is provided in the annulus between the RPVRI and the shield wall for both units.

CPRT will review design changes to non-nuclear safety-related items to assure that these changes do not adversely affect safety-related systems. This will be accomplished by reviewing the programs, procedures and related criteria to determine if the ways in which nonsafety-related items could have significant influence on plant safety are adequately addressed. The implementation of these procedures and programs will also be reviewed.

The Action Plan also addresses the issue of critical clearances by describing a program to identify potential areas and a review of housekeeping methods. Spaces where physical separation is essential to the function of items in close proxi-mity will be identified as subsequently inspected. In addition QC inspection priority fuel load will be made to verify that the critical spaces are free of debris.

2.4.6.3 Staff Evaluation The approach incudes a review of the analysis and test data of annulus cooling flow.

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The staff has reviewed the methodology to be used in addressing this specific issue. The results of the review will be compared with the FSAR criteria for compliance with licensing commitments.

2.4.6.4 Conclusions This action plan is responsive to the issues addressed in NUREG-0797, Supple-ment No. 8, and with proper implementation, including review of analysis, test data, procedures and programs, should resolve NRC staff concerns.

NOTE: This ISAP is now listed by CPRT as a Mechanical ISAP.

2.4.7 ISAP-VI.b, Polar Crane Shimming 2.4.7.1 Introduction The TRT investigated the installation of the polar-crane rail-support system.

-The result of the investigation was described in NUREG-0797, Supplement No. 8, as a miscellaneous issue. The concern arose from the TRT's investigation of allegations in the civil / structural area.

2.4.7.2 CPRT Approach CPRT will review the history of the crane-support system during construction and its performance during construction.

An inspection of the polar-crane rail girder seat-to-Dracket connection will be performed as well as a general inspection of the rail and rail-support system.

A measurement program for determining polar-crane movement will be developed and implemented. The existing maintenance and surveillance programs will also be reviewed.

i A historical review of the Crane Support System during construction and opera-tion will be conducted. The design requirements established by both Gibbs LARC and the Crane vendor will be reviewed with respect to performance and function.

Also, an inspection of the RMC and its support system will be conducted to 03/10/86 IV-82 NUO797 SEC IV

identify deviations that may be safety significant. Finally, all design changes and modifications will be reviewed by a third party.

The results of the reviews and inspections will be used to identify'any devia-tions of safety significance and corrective actions required.

2.4.7.3 Staff Evaluation The staff has reviewed the methodology to be used in addressing this specific issue. The approach includes a general inspection of the polar-crane rail ~and rail-support system and will perform an analysis which will determine whether existing gaps are acceptable or require corrective action in accordance with FSAR commitments.

2.4.7.4 Conclusion This action plan is responsive to the issues addressed in NUREG-0797, Supple-ment No. 8, and with proper implementation, including design review and accept-ability for FSAR commitments, should resolve NRC staff concerns.

2.5 Testing Program Issues Revision 3 of the Program Plan does not contain the ISAPs covering the testing A' area (the III series). The cover letter to Revision 3 states that these ISAPs #)

will be supplied on or before March 1, 1986.

Therefore, this section cannot be reviewed and evaluated by the staff at this time and will be covered in a revision to this SER.

2.6 Methodology for Resolving New External Source Issues At the present time it is uncertain how the new issues will be presented to the Applicant, or how the Applicant proposes to address them.

Currently, the CPRT is charged with responding to and resolving the external source issues.

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TV 3/11/86

[ g- hj SECTION 2.5 ( -

2.5 Testing Program Issues The Testing Program Issues are the identified concerns which resulted from the TRT Electrical Group's assessments of technical issues and allegations in the areas of Electrical / Instrumentation and Test Pro-grams regarding construction and plant readiness testing practices at CP.

These issues were presented to the Applicant by letter from the NRC dated September 18, 1984 and the detailed assessments were published in NUREG 0797 Safety Evaluation Report, Supplement 7, issued in January 1985 (Reference Appendix J, Pages J-116 through J-119).

The CPRT formulated seven Issue Specific Action Plans (ISAP) that address the testing program issues. The staff evaluations of each ISAP are contained in the following sections 2.5.1 through 2.5.7 Although there are seven ISAPs that address the testing program, the staff is concerned as to whether the ISAPs collectively provide sufficient breadth and depth coverage of the entire testing program to provide reasonable assurance that all testing was conducted in accordance with the FSAR commitments. During implementation of the program plan, the CPRT must consider the results of all ISAPs, on an individual basis and collectively, to assure the adequate breadth and depth that will enable the CPRT to provide a conclusion regarding the adequacy of the conduct of the CPSES testing program.

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3/11/86 TV SECTION 2.5.1  :

I 2.5.1 Hot Functional Testing (III.a.1)

Revision 3 of this ISAP has not been supplied by the CPRT. CPRT anticipates submittal of this ISAP by the end of March.

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IV 3/11/86 SECTION 2.5.2 2.5.2 Test Data Approval (III.a.2) 2.5.2.1 Introduction This ISAP addresses the NRC's concern that the TRT noted during a review of Hot Functional Test (HFT) completed test data that the Joint Test Group (JTG) did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling deferred preoperational HFT, the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing that TUEC is committed to do this.

2.5.2.2 CPRT Approach The Action Plan in it's current revision contains an excerpt from NUREG-0747 CPSES Safety Evaluation Report Supplement 7 Page J-77 which states in part:

TUEC saall amend the FSAR to reflect their commitment to the TRT that the Station Operation Review Committee (SORC) and not the JTG will perform these reviews. This requirement, not included in the September 18, 1984 letter to TUEC, is necessary because the current version of the FSAR states that the JTG is responsible for reviewing preoperational test data.

In this ISAP the CPRT reported that FSAR Amendment 54 dated January 21, 1985 responded to the issue and that this action plan is completed.

IV 3/11/86 SECTION 2.5.2 2.5.2.3 Staff Evaluation The staff's evaluation of this ISAP found that the issue was identified correctly, and by the FSAR Amendment 54, TUGC0 has responded to the NRC's concern.

The current revision of this ISAP deleted the participants roles and responsibilities and the qualifications of personnel. The program plan requires that all revisions of the ISAP will be retained in the Action Plan Files. The staff wishes to clarify it's understanding that if any documentation for evaluation and resolution of the issue was prepared by the CPRT under previous revisions of the ISAP, that documentation will also be retained in the Action Plan Files. A specific example is: ISAP Revision 2 Section 4.2.2.2 RTL - Overview and Concur with Startup Group Scope. The retention of documentation is not limited to the- specific example. During implementation the staff will confirm that applicable documentation has been retained by the CPRT.

2.5.2.4 Conclusion The staff's evaluation found that the issue was identified correctly, and Amendment 54 of the FSAR addressed the NRC's concern. Accordingly, the staff concludes that this ISAP is acceptable, however, acceptance of completion of the ISAP is not included in this conclusion.

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IV 3/11/86 SECTION 2.5.3 2.5.3 Deferred Test Technical Specifications (III.s.3) 2.5.3.1 Introduction This ISAP addresses an NRC concern that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel loak, certain limiting conditions of the proposed technical specifications cannot be met, e.g., all snubbers will not be operable since some will not have been tested.

2.5.3.2 CPRT Approach This ISAP was initially prepared on October 5, 1985 as a result of the NRC letter to TUEC dated September 18, 1985 which identified : number of NRC concerns related to the CPSES testing programs. nuREG-0797-CPSES Safety Evaluation Report Supplement 7, January 1985 Page J-18 reported that this (issue) is no longer applicable since the TRT has been infc,rmed by TUEC that these tests will be conducted prior to fuel load.

2.5.3.3 Staff Evaluation The staff verified that the SSER reported that the issue is no longer applicable.

Since the item is no longer an issue the plan does not detail the CPRT's scope and methodology for evaluation and resolution of the issue.

IV 3/11/86 SECTIO:: 2.5.3 2.5.3.4 Conclusion The staff's evaluation found that the issue was correctly identified in the plan and verified that the issue is no longer applicable. Accordingly, the staff concludes that the ISAP is acceptable.

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IV 3/11/86 SECTION 2.5,4 2.5.4 Test Equipment Traceability (III.a.4) 2.5.4.1 Introduction 9 This ISAP addresses the NRC's concern that data for the thermal expansion tests (which have not yet been approved by the JTG) did not provide for traceability between the calibration of the measuring instruments and the monitored locations, as required by Startup Administrative Procedure-CP-SAP-7. The information was separately available in a personal log held by Engineering.

2.5.4.2 CPRT Approach The CPRT's evaluation of the detail of this issue found it an isolated case. The Plan's methodology described the activity that corrected the questionable data package and provides in-structions to Startup Personnel regarding instrument traceability and test procedure deviations. Additionally, the CPRT will determine the adequacy of training and startup procedures to assure that the administrative con-trols for documentation of traceability of test equipment are established for the Initial Startup Test Program and also for operations and main-tenance activities. The Plan also addresses the processing of identified discrepancies in accordance with Appendix E, and Corrective Actions in accordance with Appendix H.

2.5.4.3 Staff Evaluation This evluation finds that the issue is identified correctly and that the CPRT's action will correct the deficient data package. The Plan's methodology is sufficiently broad in scope and depth to evaluate all aspects and inferences of this issue, identify potential programmatic problems and initiate actions to prevent recurrence. Accordingly, this Plan adequately addresses the issue and is responsive to the NRC's concern.

IV 3/11/86 SECTION 2.5.4  !

' The staff finds however that although the exist-ing procedures applicable to implementation of the Plan are identified in various paragraphs, the Plan does not comply with the Program Plan Attach-ment 3 ISAP format ~which implies that there is a section dedicated to the identification of existing procedures. The staff acknowledges that the previous revision of the ISAP has reported that this ISAP is complete, accordingly, revising the Plan solely to include a discrete section to identify the procedures will serve no purpose.

2.5.4.4 Conclusion The staff's evaluation found that the Plan adequately addresses the NRC's concern and implementation of the Plan will establish the administrative and procedural controls that will assure pre-vention of recurrence of deficiencies pertaining to those which the issue identified. The staff concludes that this ISAP is acceptable. Accept-ability of resolution of the issue is not included in this conclusion.

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TV 3/11/86 SECTION 2.5.5 2.5.5 Containment Integrated Leak Rate Test (III.b) 2.5.5.1 Introduction This ISAP addresses an NRC concern with the manner of conducting the Containment Integrated Leak Rate Test (CILRT).

The leakage rate was calculated by a method different than that committed in the FSAR and the FSAR was not amended to reflect the change. The TRT questioned the TUEC procedures for documenting and identifying FSAR deviations to the NRC, and that the test was conducted with three isolated penetrations which would not be the containment configuration during normal operations.

2.5.5.2 CPRT Approach Background information in the ISAP stated that the concerns related to the calculation method and penetration isolation were resolved and are documented by NRC-NRR in CPSES Safety Evaluation Report Supplement 12 Page 6-1, Item 6.2.5. These two concerns were resolved by FSAR Amendment 54.

The CPRT will address the concern pertaining to TUEC's procedures for identifying and reporting FSAR deviations under ISAP III.a.l.

2.5.5.3 Staff Evaluation This evaluation found that the issue was identified correctly, and that the closure of the two concerns as reported in SSER 12 was stated accurately in the plan. The staff's evaluation of ISAP III.a.1 Hot Functional Testing is presented in this report Part IV Section 2.5.3.

TV 3/11/86 SECTION 2.5.5 Note: Revised ISAP III.a.1 has not been evaluated by the staff as of 3/12/86.

The ISAP won't be submitted to the NRC until late March, 86.

2.5.5.2 Conclusion The staff verified the accuracy of the plan's reporting the NRC's closure of the concerns related to the calculation method and penetration isolation. Since the remaining concern pertaining to TUEC's reporting of FSAR deviations will be addressed in ISAP III.a.1, the staff concludes that this ISAP adequately addressed the issue and the plan is acceptable. The staff's acceptance of completion of the plan is not included in this conclusion.

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IV 3/11/86 SECTIDH 2.5.6 2.5.6 Prerequisite Testing (III.c) 2.5.6.1 Introduction This ISAP addresses an NRC concern that craft personnel signed test records to verify initial conditions for tests in violation of Start-up Administrative Procedure CP-SAP-21. The procedure required this functior. to be performed by startup test engineers (STE).

Startup Management issued a memorandum that improperly authorized craft personnel to perform the verifications on a selected basis.

2.5.6.2 CFRT Approach The CPRT will evaluate and resolve the concern by implementing methodology that will rescind the memo and instruct STE's that it has been rescinded, and instruct the electrical test group (ETG) (craft) personnel regarding the STE responsibilities for validation of test prerequisites, and the conduct of tests under the supervision of the STE.

The CPRT will review all startup interoffice memos to ensure that no directives were issued in conflict with procedure CP-SAP-21. Additionally, all prerequisite test records will be reviewed to identify other cases that were . signed by craft and evaluate the ,

results of the memo and record reviews for any impact on subsequent testing activities. Identified discrepancies will be processed in accordance with Appendix E and corrective actions if required will be implemented according to Appendix H.

TV 3/11/86 SECTION 2.5.6 2.5.6.3 Staff Evaluation This evaluation found that the issue was identified correctly and the implementation of the plan is sufficiently broad in scope and depth to adequately address the NRC's concern. The plan defined appropriate acceptance criteria to determine compliance of the prerequisite testing with the FSAR commitment.

2.5.6.4 Conclusion The staff's evaluation found that the issue was identified correctly and that implementation of the plans methodology will resolve the concern, identify and implement any required corrective action and will determine compliance with the FSAR commitment. Accordingly, the staff concludes that the ISAP is acceptable.

IV 3/11/86 SECTION 2.5.7 2.5.7 Preoperational Testing (III.d) 2.5.7.1 Introduction This ISAP addresses an NRC concern that the TRT found that systems test engineers were not on controlled distribution for design changes, therefore, there is not reasonable assurance that previously identified (by the NRC) problems in the document control system (DCC) had no adverse effect on testing activities.

2.5.7.2 CPRT Approach The CPRT will review the applicable procedures to determine the adequacy of the measures that ensure that startup test engineers (STE) and other test personnel are effectively provided with the current design documents for use in testing activities. In addition, a review of the Startup/DCC interface and interviews with STEs will enable a determination of the adequacy of past and present practices in meeting the requirements of testing programs.

An evaluation program will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which resulted in a testing error. This evaluation will be implemented by sampling of design drawing revisions and change documentation for homogeneous populations of prerequisite tests and preoperational tests. Identified discrepancies will be processed according to Appendix E and any required corrective action will be implemented in accordance with Appendix H.

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i IV 2/11/86 SECTION 2.5.7 2.5.7.3 Staff Evaluation The staff's evaluation found that the issue was identified correctly and that the plan's methodology is sufficiently broad in scope and depth to address the concern. The plan appropriately identifies the areas of activity, the procedures, the types of documents that must be reviewed, and the acceptance and decision criteria that are necessary to evaluate and resolve the issue.

The staff's evaluation of the CPRT program sampling methodology is presented in this report, Section .

2.5.7.4 Conclusion The staff's evaluation found that the issue is identified correctly, and under this Plan the CPRT is reviewing the appropriate documentation that may identify deficiencies which will be evaluated to determine the effect of DCC problems on the testing program.

Accordingly, the staff concludes that this ISAP is acceptable.

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Assuming that the issues will be evaluated and resolved under the present structure and methodology of the CPRT Program Plan, the staff's evaluations, of the adequacy and acceptability of the CPRT's capabilities to resolve these issues, are presented in a number of sections throughout this report. Part IV, Staff Evaluation of Construction Adequacy Plan, Section 2.0 and all Subsec-tions 2.1.1 through 2.5.7 present the staff's evaluations of all of the ISAPs pertaining to these issues. In addition, Section 3.0 and Subsections 3 1 through 3.4 present the staff's evaluation of the self-initiated ISAP under which certain of these issues may be resolved, or, the results of which, when combined with the results of other ISAPs, may enable resolution of the issue.

Based on its evaluation of Revision 3 of the Program Plan the staff concludes that the Plan structure and methodology is adequate to address and resolve new issues. This evaluation also considers that new action plan (s) may need to be developed and implemented.

The Program Plan in its current Revision 3 lists a number of sources that iden-tified the existing issues,'and may be the sources of new issues. The staff is concerned however: that new issues may emanate from sources other than those that are currently listed, and that the Program Plan does not address the manner of the CPRT's receipt of issues from new sources nor how the issues will be validated and entered into the CPRT tracking system for evaluation and resolu-tion. Accordingly, the Program Plan must be amended to describe the CPRT's methodology that will ensure that concerns from new sources are identified and tracked and that the specific source is identified in the Plan. During imple-mentation, the staff will confirm the adequacy of the CPRT's action implemented to resolve this concern.

2.7 Evaluation of closed External Source Issues Tr.3 staff's evaluation of the Program Plan, Revision 2, raised a concern that the Plan should be augmented to include information to meet the commitment of ad-dressing the potential root cause and generic implications associated with those issues which have been raised by an external source and subsequently closed by that source. The CPRT has responded to this concern by revision to Appendix B,

" Quality of Construction /QA/QC Program." The revised Plan states that concerns 03/10/86 IV-84 NUO797 SEC IV

which have been raised and subsequently closed by the external source that raises the issue will be considered for information when conducted root cause and generic implication analyses.

The Staff's evaluation of the Plan, Revision 3, finds that the CPRT has responded to the NRC concern and that the CAP adequately addresses the root cause and generic implications analyses of the closed external source issues. Accordingly, the staff concludes that the response is acceptable. However, the Staff is concerned that, although the action plan results report format (Program Plan, ) infers that closure of the issue will be reported, there is no clear statement in that format that requires reporting that each issue addressed in the action plan is closed. Therefore, Attachment 5 should be revised to include a requirement to identify each closed issue. During implementation of the Program Plan, the Staff will confirm that this action has been satisfactorily implemented.

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3.0 SELF-INITIATED EVALUATION 3.1 Scope 3.1.1 Introduction The construction adequacy program plan is described in ISAP VII.C. This action plan describe he proposed CP reinspection and documentation review of com-pleted and C cepted saf ated construction work activities performed at Comanche P . The areas essed by this program include those which have not been identified as areas of concern by external sources. The objective of this rt is to provide additional confidence that there are no unidentified safe gnificant concerns related to the quality of construction of the hard-were Companche Peak in areas not addressed by ext al source issues. The CPRT's Plan consists of a sampled reinspection of cepted, safety-related construction work, supplemented by a review of rel ed documentation for non-recreatable processes. The scope of the Plan includes Units 1, 2 and their common areas. Construction activities are organized into three disciplines as follows:

Civil / Structural Electrical, and Mechanical.

The NRC staff has reviewed the scope, methodology, and process of this ISAP.

This has been accomplished through document reviews and onsite audits. All aspects of this program have been examined from the categorization of installed safety-related hardware into population to the development of inspection lists from work process attributes. In addition to the presentation made by CPRT personnel at public meetings, the staff and its consultants have performed onsite audits of the construction reinspection and documentation review pro-gram. These audits have enabled the staff to understand and evaluate the frame-work and process for implementation of this plan.

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7 3.1.2 CPRT Approach The methodology for CPRT construction adequacy review program consists of establishing reasonably homogeneous populations which are then sampled, evaluated, and the results of these evaluations with conclusions drawn documented in an action plan results report. The approach is to first categorize all installed safety-related hardware into populations made up of homogenous work processes for which statistical samples can be drawn for evaluation. Population and work process descriptions are prepared for each construction category. The popula-tion description describes the boundaries of the population while the work pro-cess describes the activities required to install or construct a certain category of hardware. Attributes associated with each work process are developed from the installation and inspection, procedures and/or specifications used for installation of the subject hardware. For each population, two random samples will be selected using established statistical techniques. The first sample provides information about the total population while the second sample, which is essentially an expansion of the first, provides information about that ,

portion of the total population which is required to safely shut down the plant. ,

In parallel with the sample selection, checklists and inspection procedures are /,  ;

developed from the attributes used to characterize each work process. Both (

inspection and documentation review checklists are developed documents from the Quality Instructions. Verification packages are then assembled for each sample item to facilitate an inspection or documentation review. Any deviations identified as a result of a reinspection or a documentation review are docu-mented in a Deviation Report which will then be evaluated to determine the safety significance of the deviation. In addition, all deviations are collec-tively evaluated for adverse trends. An action plan results report documenting the overall results of the inspections for all populations is the vehicle for documenting the results and evaluations of this ISAP.

The sample size for each population which is part of the construction adequacy review program is targeted to meet a 95/5 confidence level. This is interpreted to mean that the sample size is sufficiently large such that one has 95 percent confidence that 95 percent of the attributes in the work process do not have any safety significant deviations. The CPRT approach to sampling as described in Appendix D of the Program Plan identifies the sample size required to achieve 03/10/86 IV-87 NU0797 SEC IV

the targeted 95/5 assurance. For each work process of interest, a sample of size 60 is taken. If no safety significant deviations are found in the sample, the work process is accepted. If a deviant is found, the sample is expanded.

Details of sample expansion (s) based on the number of deviations found are included in Appendix D of the Program Plan. The addition sample from the safe shutdown systems referred to as the " engineered sample," may include items from the first random selection. The augmented sample size for each work process, hence, may vary between 60 and 120.

The 95/5 confidence level was selected as a criterion to allow a quantification of the quality of the work process without having to reinspect each and every individual item in a work process. This confidence level is a targeted, rather than an exact, confidence level. For most applications, the actual confidence may easily be higher than the targeted level.

3.1.3 Staff Evaluation The staff has reviewed the Construction Reinspection and Documentation Review Plan proposed by the CPRT and has conducted plant audits to evaluate tracea-bility of re-inspection documentation. The review of the Program Plan and by CPRT presentations at public meetings has provided the staff with an understand-ing of the process being used for this construction adequacy evaluation program.

The staff's review of the construction adequacy program focused on the sampling process proposed by the CPRT for use in evaluating the various work processes.

Review of work processes enabled the staff to determine whether similar methodology was being applied for all disciplines. The staff has determined that similar methodology was being applied regardless of discipline and work process. Additionally, the staff reviewed some inspection and documentation checklists that were being generated for the re-inspection effort.

The sampling procedure is based on assumptions that characterize a binomial population which include: (1) homogeneity of items within a work process; (2) random selection of sample items from a work process; (3) ability to clas-sify an item as acceptable or as deviant with certainty; (4) the number of items in the work process is essentially infinite.

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However, since the number of items in each work process is finite the sample size, will generally be larger than required to meet the 95/5 confidence level, hence increasing that level of confidence above 95/5. There are additional factors that could further enhance this assurance, even though no attempt is ma.!e to quantify this enhancement. Some of these factors are given below:

(1) The assurance increases with sample size, provided no additional deviations are found.

(2) The sampling assurance is increased when a deviant is identified and repaired.

For small work processes this increase may be very significant.

(3) When a deviation is identified, it serves to identify a potential error l path, which leads to further sampling. This activity increases the sample size, generally giving a still greater assurance.

The emphasis of the staff audits of work processes was to ensure that they were homogeneous, that an auditable trail existed, and to ensure that key attributes 3

of the work processes were defined. The audits did not address implementation of the reinspections and document reviews. The staff audited the majority of the populations and found the documentation to be complete and the development of the inspection checklists consistent for all populations.

3.1.4 Conclusions Based on audits described above, the staff concludes that the program proposed by the CPRT in ISAP VII.c for evaluating the adequacy of construction at Comanche Peak is acceptable. The staff finds the CPRT approach to reinspection to be based on sound statistical principles. The staff believes that this program will provide a significant contribution to the overall assessment of the design and construction adequacy of the Comanche Peak steam electric station. Imple-mentation of this program will continue to be audited by the staff. The CPRT's documentation of findings, collective evaluations, and documentation of results

will also be evaluated by the staff.

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3.2 Electrical Populations 3.2.1 Staff Evaluation The electrical discipline is divided into seven populations which are:

(a) Instrument Equipment (b) Cable Trays (c) Electrical Equipment (d) Conduit (e) Cables (f) Lighting (g) NIS Cable Terminations The staff's review of the program was augmented by onsite audit review of docu-mentation the staff related to Population Description which addresses the con-tents of each population, the boundaries, and any specific interfaces germane to the population. In addit' ion to the Population Descriptions, flow charts de-scribing the work processes were reviewed. The flow charts contain attributes associated with each work process. The attributes provide the basis for check-lists which are being developed for re-inspection of electrical systems and components.

Individual population descriptions are discussed below:

(a) Instrumentation Equipment. The instrumentation equipment population has two work processes associated with the equipment installation: (1) tubing /

piping and component installation, and (2) instrument installation. Each of the above work processes are supported by several attributes. Documents reviewed during the audit include: (1) Gibbs and Hill Procedures and Spe-cifications, (2) Work Process Descriptions and Flow Diagrams, and (3) pop-ulation items list for instrumentation equipment.

(b) Cable Trays. This population has one work process in cable tray

! installation.

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The cable tray installation work process is supported by several attributes.

One of these attributes, welding, has twelve contributing sub-attributes.

During the audit the work process and attributes were evaluated to determine how each was derived and approved. The staff also reviewed the following docu-ments: (1) cable tray population description, and (2) cable tray installation work process and flow diagram.

(c) Electrical Equipment. The electrical equipment population is made up of two work processes: (1) electrical equipment installation, and (2) field assembly and field modifications. Both work processes are supported by several attributes. The population includes electrical equipment of var-ious sizes and unique configurations such as electrical penetrations.

The above work processes, attributes, and documentation were reviewed during the audits. The documentation included (1) electrical equipment population description, and (2) electrical equipment work processes and flow charts.

(d) Conduit. This population is made up of three work processes: (1) selection, (2) preparation, and (3) installation. Each work process is supported by several attributes. The work processes apply to both rigid and flex conduit.

The above work processes, attributes, and documentation were reviewed during the audit.

(e) Cables. This population is made up of three work processes which include cables of all sizes. The work processes associated with the cable popula-tion are: (1) prepull, (2) pull, and (3) terminations. Each of the above work processes are supported by several attributes.

Each work process and its associated attributes were evaluated to determine how each was derived and considered adequate. The staff also reviewed documen-tation covering (1) cable population description, and (2) cable population work processes and flow diagrams.

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l 3.2.2 Conclusions Based on our review of the Self Initiated Construction Adequacy Program for Comanche Peak we have concluded that:

(a) This program, combined with the review of the external source issues, will adequately cover all plant electrical construction activities.

(b) Individual electrical population boundaries are clearly defined.

(c) The attributes within each work process are representative of the individual activities which cumulatively encompass a complete installation.

(d) The program has provisions for expanding at the attribute level to meet new requirements.

3.3 Mechanical Populations 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 Mechanical Equipment Installation Field-Fabricated Tanks Instrumentation Tubing Welds / Material Within each population, work processes will be established. The CPRT program plan 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 original construction. Random and engineered (safe-shutdown) samples will be selected for each population.

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3.3.1 Staff Evaluation The staff reviewed Revision 3 of the Program Plan and undertook audits of each of the Mechanical Populations. These audits included reviews of procedures, documentation, work processes, and attributes.

For each of the mechanical areas, ERC has prepared a " Population Description" addressing the contents and boundary of each category of work. In addition to the Population Descriptions, a flowchart describing the work processes and associated attributes for each sample population was provided. It is the attri-butes that provide the basis for the inspection checklists. The work process attributes were reviewed in order to verify that each work process would be adequately reviewed. The Specific Staff Evaluation for each of the Mechanical Populations is provided in the subsequent paragraphs.

3.3.1.1 Field-Fabricated Tanks This population contains eight fiela-fabricated tanks. All eight tanks will be reinspected. The prccedures were reviewed ar.d contained information for all attributes given in the Work-Process Description.

3.3.1.2 Mechanical Equipment Installation The original governing construction document is Gibbs & Hill Mechanical Erec-tion Specification 2323-MS-101 and its implementation is accomplished by Brown &

Root Specification titled " General Installation of Mechanical Equipment", CP-1.

The original governing quality assurance procedure is Brown & Root QI-QAP-11.1-39 titled " Mechanical Equipment Installation Inspection".

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Qualitative results of the sampling conducted so far indicate that 20 to .'u 25 percent of the sample drawn is from Unit 2. The remainder of the sample is c' from Unit 1 and common areas. The work processes associated with mechanical ,

equipment installation are setting, anchoring, welding and, for rotating equip-ment only, alignment. The attributes of each work process were reviewed in depth. 7 ERC personnel indicated that if a particular attribute of the work processes was not addressed when the sampling activity was completed, an assessment would 03/10/86 IV-93 .NUO797 SEC IV

be made to determine whether 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 con-struction adequacy evaluation of, in this instance, mechanical equipment. Work-process homogeneity is evaluated by assuring that the same organizations are involved in the activity and that the procedures have remained nominally con-stant. Since both sampling and evaluation of equipment is made at the work process level, each sample will include sixty evaluations 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.

3.3.1.3 Piping System Bolted Joints / Materials Two work processes corrprise the piping-system bolted-joint category. They are installation preparation and final bolt fit-up. There are approximately 7000 bolted joints at the Comanche Peak Power Station. The work processes and their attributes appear to adequately 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 documentation review.

3.3.1.4 Large-Bore Piping Configuration /Small-Bore Piping Configuration The large- and small-bore piping configurat n 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 containing both large- and small-bore piping were to be drawn as part of a sample, it would be used in both the large- and the small-bore work process review. The 03/10/86 IV-94 NUO797 SEC IV

installation 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 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 as 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, following the samp1-ing process, a review to assess the adequacy of the sample for adequate repre-sentation of attributes would be made. However, 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 popu-lations. One population is HVAC Equipment 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 Mechanical Equipment Installa-tion 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 equipment in the proper location. The connection Work Prncess 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 documenta-tion, work processes, attributes and homogeneity.

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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.

The random and engineered (safe-shutdown) sample set will 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 documenta-tion, Work Processes, attributes and homogeneity. The Work Process attributes were reviewed in order to verify that each would be adequately inspected. This entailed reviewing the installation procedures referred to in the Description Memorandum for Reinspection a 'nd Quality Instruction documents for each population.

A comparison of the distribution of component types in the sample sets (ranoom 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.

3.3.1.7 Pipe Welds / Material Based upon the fact that both large-bore and small-bore pipe welds were fabri-cated to the same procedure and by the same craft, it was decided by ERC to combine these populations. The staff reviewed the (L8WM and SBWM) popuation basis, description memorandum, population description, populations item list and work process definition. ERC indicated that only one work process was chosen, Welding. Apparently, regardless of the possible differences in the welds (configuration, material type, or process), each work process involves:

(1) common erection specirication requirements; (2) common installation pro-cedure requirements; (3) common craft labor performing the same basic types of operations, (4) common inspection procedure; and (5) a common inspection organization.

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Since basically only two welding methods were used at CPSES, Gas Tungsten ARC Welding (GTAW) and Shielded Metal Arc Welding (SMAW), ERC has committed 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 welder qualification is in compliance with B&R Specifica-tion WES-031, which qualifies a welder to both carbon- and stainless-steel weld-ing. The staff reviewed WES-031 and B&R Procedure CP-CPM-6.9D, " Welding and Related Processes", and found very few areas where the procedures or specifica-tions differed with regard to carbon- and stainless-steel welding. Differences were associated with the two welding methods, GTAW and SMAW. ERC said that of the 120 samples already established approximately 50% were stainless-steel welds.

In addition, an engineered sample of 60 welds for each method was chosen to account for safe shutdown systems. In both cases, 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.

Under the work process identified as " Welding", 24 attributes were identified, 18 of which are common 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 summarized as follows:

Inspector Certification Program.

Basis and rationale for establishing homogeneous hardware populations.

Attribt.te 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 discussed in Section of this SER.

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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 procedures and checklists for the populations, adequately addresses the concerns raised en the basis / rationale for establishing homogene-ous hardware populations and the method used in determining attributes / criteria.

Based on the results of the audits, the Staff has concluded the following re-lative to the Mechanical Equipment Populations:

1. A. documented auditable trail of the background exists.

2. The samples selected 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.

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4. The Verification (inspection) packages demonstrated that the CAP inspection will produce an auditable results trail.

The concern raised by the Staff on sample expansion criteria has not been re-solved to the satisfaction of the Staff. The details of the concerns are given in Section of this SER.

A specific concern on sample selection in the Pipe Welds / Material population is as follows.

The original breakdown consists of a sample of 60 LB and 60 SB welds as part of two separate populations. The two populations have been combined to account for the similarity in the welding attributes and the welding methods. The staff questions whether the original two 60 sample sets that are now combined into a sample of 120 will be judged as (1) a single sample of 120 or (2) two samples of 60. This discrepancy must be clarified statistically.

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3.4 Civil / Structural Populations The safety-related Civil / Structural Discipline consists of the following 15 populations:

Concrete Placement Structural Steel Liners M Fuel Pool Liner {g j. ./

Fill and Backfill Placement , ,

Grout-Cement -

Grout-Epoxy b 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 Revi-sion 3 of the Program Plan, for specific populations is described below.

3.4.1.1 Category I, Conduit Supports (COSP)

Procedtres for reinspection of this population was reviesed. Tolerances for the attributes of this population were obtained from the Gibbs and Hill Speci-fication 2323-ES-100, Revision 2, dated October 25, 1980. Paragraphs 2-36 and 4-19 of the G&H specification state that supports shall be installed to detail drawings 2323-5-910 and 2323-El-1705. The ERC Reinspection Procedure contains this set of drawings for the reinspection. ,e l > -

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3.4.1.2 Concrete Placement Population The staff reviewed the Concrete Placement Population. Documents were reviewed to determine if homogeneity of the work processes and attributes had been achieved.

The concrete placement population is presently subdivided into three work pro-cesses, 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.

Gibbs and Hill Specification 2323-55-9, dated January 16, 1979, was reviewed to /

assure that the reinspection requirements reflect the original construction tolerances and inspection requirements. (, N, 3.4.1.3 Structural Steel Procedures and documents were reviewed during audits at CPSES to see if homo- '{

geneity of the work process and attributes had been achieved for the structural g/ f" steel population.

The original Gibbs and Hill specifications and 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 rein-spection requirements reflect the original construction requirements.

3.4.1.4 Liners-Two Populations The following two similar populations were reviewed:

1. Containment Liner and Tank Stainless-Steel Liner

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 construction specifications to determine if the 03/10/86 IV-100 NUO797 SEC IV

ERC reinspection requirements adequately represent those of the original construction. .

3.4.1.5 Pipe Supports Pipe supports were separated into the following populations:

Large-bore pipe supports - rigid.

Large-bore pipe supports - nonrigid.

Samil-bore pipe supports.

The large-bore population of pipe supports was divided as noted in order to assure a proper sampling of rigid and nonrigid 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 SBPS).

The SBPS population was made up of four work processes: fabrication, installation, welding and inspection.

The staff reviewed the various documents (description memorandum, population description and basis, population items list, work process justification, attri-bute description and basis. An auditable trail existed such that all work pro-cesses 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 I

an inspection standpoint (prewelding attribute) and from the point of view of document review (cleanliness was not a hold point on the Multiple Weld 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 requirements for identifying base-metal de-fects existed in ASME Subsection NF-4000 and B&R Procedure QI-QAP-11.1-28. 1 After some discussion, ERC committed to put base-metal defects into the attri-bute list and to treat all instances as part of the Construction Adequacy.

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I 3.4.2 Conclusions l

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 procedures and checklists for the populations, adequately addresses the concerns raised on the basis / rationale for establishing homogene-ous hardware populations and the method used in determining attributes / criteria.

Based on the results of the audits, the Staff has concluded the following, relative to the Mechanical Equipment Populations:

1. A documented auditable trail of the background exists.

2. The samples selected for the 1.spections 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 demonstrated that the CAP inspec-tion will produce an auditable trail.

The concern raised by the staff on sample expansion criteria has not been re-solved 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 inde-pendent of the safety-related sample; however, some of the samples may be common 03/10/86 IV-102 NUO797 SEC IV

to both groups. After the 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 expanded 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 common to both samples, are both samples expanded? This question has not been adequately ad-dressed in the plan.

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4.0 EXCLUSION OF VENDORS FROM CPRT REVIEW 4.1 Introduction I During the construction of CPSES, there were a number of contractor and hardware suppliers. Since it is an objective of the Program Plan to assure the quality of construction in addition to the quality of the installed hardware, it is imperative that the Program Plan does not exclude the work performed by all con-tractors unless there is adequate justifica' tion.

4.2 CPRT Approach (Justification)

The Program Plan, Appendix C, ISAP VII.C, " Construction Reinspection / Documentation Review Plan," Section 4.2, states "The scope of this action plan includes all safety-related construction work which has been inspected and accepted by CPSES QC."

This scope, in conjunction with the scope and methodology described in Appen-dix B, " Quality of Construction and QA/QC Adequacy Program Plan," for External Source Issues and self-initiated evaluation, defines and describes the mechanism to identify and evaluate construction deficiencies or weaknesses and, if required, to expand the scope beyond that specified in the plan.

4.3 Staff Evaluation The Quality and Construction and QA/QC Adequacy Program Plan (QOC) does not exclude the review of any safety-related construction work which has been accepted by CPSES QC from its scope.

The plan does contain the scope and methodology for expansion of hardware inspec-tions and evaluation. This is described in the Appendix B, Introduction, pages 2 and 3.

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' 4.4 Conclusions The staff concludes that the QOC plan adequately defines the scope and ::vethodology for the inclusion of all safety-related construction activities and is therefore acceptable.

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