ML20211D967
| ML20211D967 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/17/1986 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1200 OL, NUDOCS 8610220320 | |
| Download: ML20211D967 (13) | |
Text
/A0 0 MELATED C0fiRESPONDENCr WOHSHAM, FORSYTHE, S AMPELS & WOOLDHIDGE 00CKETED TMf 4ry TWO MUNDRED.2005 3RYAN TOWER ggqp{
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.O0Lom Doc ee o N EIL D. ANDERSON
- OPP, Days 0 C. LONEROAN TELECObejlji21.) 880* 0018 JOMN W MCREVNOLD9 f MOM A S F. LILLA RD ROeERT M. WISE f f MOYMY 4. MACM RostRT M Fi LL MO R E wM STEPMEN BOYD MARN R. WASEM CMRISTORMER M. MILtENSERGER posERT R. OtavEm M A m st SCMWARf 2 RICH ARD O. MOORE U"E'Af'lu"NER October 17,1986 JOE A DAvst EmeC M PETERSON WAttER w wMsTE Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075
. Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory 881 West Outer Drive P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2): Docket Nos. 50-445 and 50-446-o'r-
Dear Administrative Judges:
Applicants have this date delivered to Mr. Vincent S. Noonan Revision 1 of the Comanche Peak Response Team Issue-Specific Action Plan (ISAP) VII.a.9, entitled " Adequacy of Purchased Safety-Related Material and Equipment,"
developed by the Comanche Peak Response Team.
As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Comanche Peak, we are enclosing four copies of such revision. This revision is not being offered into evidence at this time, and is provided for information only.
Respe fly submitted 8610220320 861017 PDR ADOCK 05000445 PDR G
Robert A. Wooldridge RAW /klw Enclosures cc:
Service List DS03 3
Log # TXX-6043 File # 10068 TEXAS UTILITIES GENERATING COMPANY
.EYWAY TOWER eSB NORTH OUVE STESWF,1.5. St. DA&MS. TEMM Mm Or.tober 17, 1986 M #".hM.U*i Director of Nuclear Reactor Regulation ATTN: Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS 50-445 AND 50-446 REVISION OF CPRT ISSUE - SPECIFIC ACTION PLAN (ISAP) VII.a.9
" ADEQUACY OF PURCHASED SAFETY-RELATED MATERIAL AND EQUIPMENT"
Dear Mr. Noonan:
Enclosed herewith is Revision 1 to ISAP VII.a.9. revision 1 is essentially a rewrite of the entire ISAP, wherein the methodology was refocused to directly provide physical verification of compliance with procurement and design requirements specified by TUGC0 and the vendor. The major tasks in revision 1 to the ISAP include the following:
Reinspection of accessible physical characteristics of selected purchased safety-related material and equipment; and Evaluation of the adequacy and implementation of the current CPSES procurement program and storage / maintenance program (warehouse only).
The results of the implementation of revision 1 to ISAP VII.a.9 will provide specific information about the quality of purchased safety-related material and equipment as well as the adequacy of the current CPSES QA/QC procurement program and storage / maintenance program.
We believe that Revision 1 directly resolves NRC concerns with Revision 0 of ISAP VII.a.9.
Should you have any questions please contact me or Mr. John W.
Bock.
Very truly yours, W. G. Counsil JCH/amb Enclosure a muum or uma vnunsa su.scumc cower
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COMANCHE PEAK RESPONSE TEAM NJ ACTION PLAN Item Number:
VII.a.9
Title:
Adequacy of Purchased Safety-Related Material and Equipment Revision No.
0 1
Revised to Description Original Issue Reflect Consnent Prepared and Recommended by:
Review Team Leader 2/n/w ghe/.x v.t.
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6 Revision:
1 Pcg2 1 of 10 U,O ISAP VII.a.9 Adequacy of Purchased Safety-Related Material and Equipment
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC This Action Plan was initiated to address two (2) concerns.
The first concern was_that the CPRT was not providing verification of material and equipment compliance with procurement / design requirements. This concern is documented on page 91, line 15 in the minutes of a public meeting held between the NRC and TUGC0 on December 19, 1985 at Arlington, Texas.
The second concern was that vendor supplied equipment may not comply with specified procurement / design requirements. This concern was based on the findings of a reinspection of safety-related electrical penetrations installed at CPSES. The reinspection was performed as a result of NRC expressed concerns with these electrical penetrations. The specifics of this concern are discussed in TUGC0 Significant Deficiency Analysis Report CP 86-10.
2.0 ACTION IDENTIFIED BY NRC v
Action was not specified by the NRC in correspondence.
3.0 BACKGROUND
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The Quality of Construction and QA/QC Adequacy Program originally covered construction activities ced in general did not cover procurement activities. One exception to this was ISAP VII.a.4,
" Audit Program and Auditor Qualification" which included TUGC0 supplier QA audits within its scope. Use will be made of information from ISAP VII.a.4 during implementation of this ISAP.
The Design Adequacy Program (DAP) covers key aspects of the CPSES design activities, including design-related aspects of the CPSES l
procurement program. The DAP evaluation will verify the adequacy of A/E furnished specifications, calculations, and drawings.
In addition the DAP will evaluate vendor documentation (e.g.,
drawings, test reports, etc.) to verify compliance with CPSES design requirements and FSAR commitments.
This ISAP as revised will verify the compliance of the physical characteristics of purchased safety-related material and equipment with procurement and design requirements specified by TUGC0 and/or the vendor. The ISAP will also assure that the current procurement 6
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Rsvicion:
1 Page 2 of 10 i
ISAP VII.a.9 (Cont'd)
3.0 BACKGROUND
(Cont'd) program and storage / maintenance program (warehouse only) contain the essential elements for controlling safety-related materials and equipment and that the current programs are being effectively j
implemented. The results of the implementation of this action plan will provide useful input to the Quality of Construction and QA/QC Adequacy Program, and will provide the basis for responding to the expressed NRC concerns in Section 1.0 of this ISAP.
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The methodology of Revision 0 of this ISAP was to perform the following:
A documentation review of current and historical program documents which address the receipt inspection and storage / maintenance (warehouse only) of safety-related material and equipment; and A documentation review of selected receipt inspection and associated storage and maintenance (warehouse only) records.
The rationale for this approach was that-if deficiencies were found in either documentation review, the root cause and generic implication analysis would reveal potential equipment and/or asterial concerns which would expand the evaluation to include a reinspection of the specific equipment and/or material.
Implementation of ISAP VII.a.9 Revision "0" was put in a hold status prior to. completion of either of the documentation review efforts. The information gathered will be used in the analysis of l
the result of Revision 1 to ISAP VII.a.9.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodolony 4.1.1 The primary objective of this action plan is to evaluate selected safety-related purchased material and equipment installed at CPSES for compliance with procurement requirements and physical design characteristics of the material or equipment specified by TUGC0 and/or the vendor.
A second objective of this action plan is to evaluate the adequacy and implementation of the current CPSES 3
i procurement system, and storage / maintenance prograa (warehouse only).
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1 Pegs 3 of 10 ISAP VII.a.9
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The completion of this action plan will provide reasonable assurance that purchased safety-related materials and equipment installed at CPSES satisfy procurement requirements and physical design ~
characteristics specified by TUGC0 and/cr the vendor.
The completion will also assure that the current QA/QC program contains the required elements for control of -
purchased materials and equipment and that the current programs are being effectively implemented.
The following tasks will be implemented to achieve these objectives:
Select procured material / equipment to be evaluated; Develop equipment and material reinspection and document review checklists based on review of the applicable procurement specification. TUGC0/ vendor design drawings and other pertinent documents; Perform field inspection of selected safety-related equipment; Evaluate selected materials by reviewing related quality records, such as certified material test reports and other tests performed during the construction activities; Develop checklists for the evaluation of the current procurement system, and storage / maintenance program (warehouse only);
Evaluate the adequacy and proper implementation of the current procurement system and storage / maintenance program (warehouse only) by review of the applicable procedures and system documentation; Identify and evaluate deviations; and Write results report.
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Rcvision:
1 Pege 4 of 10 O
ISAP VII.a.9 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Safety-related procurements range from simple consumable materials such a reinforcing steel and weld rod to complex engineered equipment such as heat exchangers and motor control centers. Consequently, the measures established to assure that the procured J
material and equipment complies with the procurement and design requirements will vary significantly. The specific types of safety-related material / equipment to' be reviewed will be selected by an approach designed to ensure that:
The materials and equipment selected for evaluation, represent a reasonable cross section. The following points will be considered in the selection of equipment and material to be evaluated:
Design Complexity; i
Method of manufacture or O
fabrication; Type of Equipment; The number of evaluation items in a given time frame is reasonably representative of the volume of l
delivery of procurred items for the same time period; CPSES identified problem vendors; ISAP VII.a.4 identified problem vendors; NRC Vendor Branch problem vendors; NRC I&E Bulletin problem vendors (10CFR50.55(e) and 10CFR21 items);
i A minimum of one (1) item will be inspected from each identified vendor.
If the vendor manufactured / fabricated the equipment or material at different times in the history of l
CPSES, the list of selected items should O
include at least two (2) items, one (1) from the early deliveries and one (1) from the L
j later deliveries.
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1 Pegs 5 of 10 ISAP VII.a.9
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The above criteria provide a reasonable qualitative basis for selecting specific equipment and material for evaluation and provide assurance that a reasonable representation of CPSES equipment and material design specifications will be provided. Similar criteria were utilized to select items for evaluation during implementation of Revision "0" of this ISAP and thirty-five (35) CPSES design specifications were identified. Approximately thirty-five design specifications will be utilized for this ISAP revision, including many of those identified during the implementation of Revision "C".
The thirty-five design specifications constitute about 20% of the total number (171) of safety-related design specifications.
The selection criteria coupled with the substantial percentage (20%) of the total number of design specifications will provide a reasonable basis for reaching conclusions on the overall adequacy of the TUGC0 procurement system for safety-related materials and equipment.
4.1.3 A reinspection checklist will be developed for each piece / type of material and equipment selected. The individual attributes to be included in each checklist will be determined by review of the applicable procurement specification and TUGCO/ vendor design drawings in effect on the date of receipt at CPSES.
The reinspection checklists will, as a minimum, assure that the following general criteria are addressed for each piece / type of equipment:
Chemical and physical properties conform to specified requirements; Important dimensions and other characteristics conform with drawings and specification; and Vendor supplied quality records are complete and acceptable for such things as major base metal repairs, etc..
Utilizing the equipment checklists, a field inspection of the selected equipment will be performed to verify compliance with procurement requirements and physical
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design characteristics specified by TUGC0 and/or the vendor.
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1 Pags 6 of 10 O
ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Identified discrepancies from the procurement specification and/or TUGCO/ vendor design drawings will be researched through available job-site records to determine:
Whether the discrepancy was the result of an authorized modification (NCR, DCA, etc.), or Whether the discrepancy can be reasonably attributed to on-site construction or testing activities, or Whether the discrepancy most likely existed at the time of receipt and was not detected and corrected during manufacturing i
inspection, vendor surveillance and receipt inspection.
Those discrepancies determined to have resulted from construction and/or testing activities occurring after O
the equipment was receipt inspected will be documented as "Out-of-Scope" in accordance with the CPRT Program Plan.
Those discrepancies which cannot be reasonably attributed to authorized modifications or construction / testing activities, will be considered to have existed prior to acceptance at CPSES and will be documented as manufacturing deviations.
Materials such as weld rod, cement, reinforcing steel, etc. are generally inaccessible for reinspection because these materials are consumed or altered in some manner during the construction process. Those
- materials selected will be evaluated utilizing the above material checklists.
A procurement program review checklist will be developed and will contain general criteria to evaluate the current QA/QC program documentation for compliance with the requirements of 10CFR50 Appendix "B" Criteria IV, VII, X, and XII and SAR section 17.1.4, 17.1.7, 17.1.10 and 17.1.13.
The CPSES documents to be reviewed are the current CPSES FSAR, TUGC0 QA Plan, B&R QA Plan and the TUGCO/B&R implementing procedures and instructions.
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1-1 Page 7 of 10 O
ISAP VII.a.9 (Cont'd) 4.0 CPRT' ACTION PLAN (Cont'd)
In addition, an evaluation of the implementation of the current procurement program activities will be performed. A checklist will be developed from the general program documents referenced above. The areas of evaluation will include:
Preparation, review and control of procurement documents; I
Evaluation and approval of suppliers; Review and approval of vendor supplied documents, such as drawings, procedures, nonconformance reports, etc.;
Manufacturing / vendor surveillance; Receiving Inspection; and Storage / Maintenance.
O The completion of this evaluation will provide a level of confidence that purchased safety-related equipment and material comply with the applicable TUGCO/ vender physical design requirements, and that the current CPSES procurement and storage / maintenance (warehouse only) programs are acceptable and are being effectively implemented.
4.1.4 Discrepancies identified as a result of the equipment reinspections, or the evaluation of the current procurement system will be documented as either manufacturing deviations or QA/QC program deviations (respectively) and evaluated in accordance with CPRT program requirements.
4.2 Participant's Role and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of work.
4.2.1 Evaluation Research Corporation (ERC) 4.2.1.1 Scope ERC is charged with the overall i
responsibility for performing this evaluation and preparation of the results.
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0-ISAP VII.a.9 (Cont'd) i 4.0 CPRT ACTION PLAN (Cont'd) 4.2.1.2 Personnel Mr. J. L. Hansel Review Team Leader Mr. C. W. Vincent Issue Coordinator 4.2.2 TUGC0 4.2.2.1 TUGC0 will assist in identifying and locating applicable information and documentation to support the Review Team activities and will coordinate field reinspections with CPSES construction and operations groups.
4.2.2.2 Personnel Mr. D. W. Snow TUGC0 QA/QC Coordinator Mr. B. C. Scott Equipment Reirspection Coordinator Mr. T. Robinson Construction Coordinator Mr. Setty Segu Engineering Coordinator Mr. R. Gentry Procurement Coordinator Others as required.
4.3 Qualifications of Personnel Inspectors certifisd to the requirements of USNRC Regulatory Guide 1.58 (Rev. 2) and ANSI N45.2.6 (1978) shall be used to perform the material and equipment inspections covered by this action plan. All other personnel associated with the analysis and evaluation of the systems and findings covered by this action plan shall be qualified in accordance with the requirements of the CPRT Program Plan.
4.4 Procedures l
4.4.1 CPRT Program Plan Appendix E to the CPRT Program Plan does not provide instructions for the classification and resolution of l
discrepancies resulting from a vendors failure to I
manufacture safety-related equipment and material in accordance with procurement and/or design requirements l
specified by TUGCO and/or the vendor.
Revision:
1 Pags 9 of 10 O-ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4 Therefore, the discrepancies identified during the implementation of this ISAP will be classified either as deviations or deficiencies, depending on the safety significance of the discrepancy.
The definitions applicable to ISAP VII.a.9 are as follows:
a)
Manufacturing Deviations Any identified discrepancy related to the manufacture of safety-related equipment and/or material that has been determined to constitute a verified failure to manufacture safety-related equipment and/or material in accordance with procurement and/or design requirements specified by TUGC0 and/or the vendor.
. b)
Manufacturing Deficiency Any identified manufacturing deviation that O
has been determined to be safety significant.
c)
Safety-Significant See B.I.(E) and associated footnote of Appendix E for definition.
d)
Programmatic Manufacturing Deficiency A set of related manufacturing deviations that has been determined to constitute an adverse trend that is programmatic in nature.
4.4.2 Instructions and checklists which address, as a minimum, the items in paragraphs 4.1.3 and 4.1.4, will j
be developed as an integral part of this evaluation.
These instructions and checklists will be retained in -
the ISAP working file.
4.5 Standards / Acceptance Criteria Applicable standards and acceptance criteria for the evaluation of the current procurement system are contained in 10CFR50 Appendix B, Criteria IV, VII, X, and XIII the SAR Sections 17.1.4, 17.1.7, 17.1.10, and 17.1.18.
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ISAP VII.a.9 (Cont'd) s_
i 4.0 CPRT ACTION PLAN (Cont'd)
Applicable acceptance criteria for the reinspection of purchased safety-related material and equipment are contained in the procurement specifications and TUGCO/ vendor design
' drawings.
4.6 Decision Criteria This action plan will be closed if no manufacturing deficiencies, QA/QC program deficiencies or adverse trends are identified.
If manufacturing deficiencies, QA/QC program deficiencies or adverse trends are identified, root cause and generic implication analyses will be conducted. Additional reviews and/or reinspections will be conducted as required based on the results of the root cause and generic implication analyses.
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