ML20246H479
| ML20246H479 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/06/1989 |
| From: | Williams N Citizens Association for Sound Energy |
| To: | Ellis J CYGNA ENERGY SERVICES |
| References | |
| NUDOCS 8903200223 | |
| Download: ML20246H479 (16) | |
Text
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2121 N Cahfornia Blvd, Suite 390. Walnut Creek. CA 94596 415/934 5733 March 6,1989 M056.160 Mrs. Juanita Ellis President, CASE 1426 S. Polk l
Dallas, TX 75224
Subject:
Communications Report Transmittal No. 48 Independent Assessment Program - All Phases Comanche Peak Independent Assessment Program TU Electric Job No. 84056
Dear Mrs. Ellis:
Enclosed are communications reports associated with corrective action programs underway at CPSES. A list of the enclosed communications reports appears in Attachment L The enclosed transmittals have been delayed because of personnel changes in our organization. This resulted in these reports being inadvertently mislaid.
Very truly yours, N.H. Williams Project Manager Enclosures cc:
Mr. J. Redding (TU Electric)
Mr. J. Muffett Electric)
/Mr. C. Grinie4 USNRC) P "Mr. D. Terao'( SNRC)
Mr. J. Wilson (USNRC)
Mr. E. Siskin (SWEC)
Mr. D. Pigott (Orrick, Herrington & Sutcliffe) l V
A Boston Chicago Houston Parsippany Toledo Walnut Creek i
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t 5ffYlCf5 ATTACHMENT 1 1.
March 22-23,1988 - Meetings on responsibilities of the Engineering Assurance Organization.
2.
March 22-23,1988 - Meetings on responsibilities and functions of the TU Electric Quality Assurance Organization.
3.
May 9,1988 - Meeting on Technical Audit Program (TAP).
4.
May 9,1988 - Meeting to develop understanding of activities during Post Construction Hardware Validation Program (PCHVP).
5.
May 10,1988 - Meeting on organization responsibilities for PCHVP.
6.
May 10,1988 - Meeting on surveillance program of the Engineering Assurance Organization.
7.
May 10,1988 - Meeting to discuss treatment of Hidden Attributes in the PCHVP.
)
8.
May 10,1988 - Meeting on understandings regarding the Ebasco System Interaction Program (SIP).
9.
May 11,1988 - Telecon regarding pre-CAP organization functions.
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Report 4L t i q-llllll1llllllll1llll1lllll1111 TU Electric 0 Teiecen centereece ne e,i CPSES Job No. 84056 3/22 & 23/88 Subject-'
Engineering Assurance Duties TUE Eng. Bid.
Participants:
of E. Dotson, D. Smedley Cygna j
J. Barker TUE Eng.
]
I Required Comments Action By The Comanche Peak response team began in the spring of 1985.
Revision 2 of the CPRT plan was issued in late 1985. Stone &
Webster, PSAS was initiated late 1985. Around February 1986, large and small bore pipe was added to their scope. It is estimated that there was about 50-60% rework and about 100% redesign by the Fall of 1986. A significant change for TU Electric occurred in the Spring' of 1986 when Larry Nace was brought aboard. He was the chief engineer with the Engineering Assurance section of Stone &
Webster (SWEC) prior to joining TU Electric.
The Engineering Assurance Department had approximately 18 people in 1986 and was built up to 60 by late 1987. They had been small and most of their work was concentrated on revismg procedures, particularly in design control. Procedures were completely revised by February,1988. Documenting engineering judgment was a key function of the Engineering Assurance group. As that effort neared completion, they moved into a surveillance mode and tightened control of contractors through the use of surveillance. The Engineering Assurance organization is preparing a " lessons learned" document due to be published in the June. July 1988 time frame.
They expect to have a configuration control program with design basis documentation completed by August 1988.
l In a discussion of the Corrective Action Program (CAP), the new contractors have responsibility for all safety related work. This is accomplished by validation by the contractor; with the exception of the Westinghouse nuclear steam supply system. There have been extensive design modifications in large and small borc pipe supports, Signed Page of D'stnbuuon: SEI ATTACHED DISTRIBUTION SHEET.
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[Eo$*ey nem comments HVAC supports and conduit supports. Comanche Peak Engineering has not performed any validation work. All previous TU Electric work by TNE has been validated by other contractors. In other words, all previous Gibbs & Hill design work has been validated or redone by other contractors. The work was begun by the contractors in accord with Task Descriptions issued by TU Electric.
Approximately seven hundred FSAR changes have resulted from the validation process. All safety related design, except Westinghouse work, has been validated. Westinghouse work interfaces have been validated. Everything in the validation process is put in the design record either as validation or as changes in the design. Gibbs &
Hill is not now the engineer of record.
The completion of the design validation effort is found in Project Status Reports which were begun in November 1987. The final report was issued in February 1988. The second phase of the Corrective Action Program covers the modifications and inspections.
The Post Construction Hardware Validation Program (PCHVP) consists of engineering walkdowns and QC inspections; and, includes all accessible safety related as-built hardware. Hidden or inaccessible attributes are addressed by engineering documentation.
The PCHVP did not rely on previous QC inspection reports, however, they may be used for engineering evaluation of hidden attributes.
Design modification packages are issued for construction with Design Change Authorizations. Field Change Requests (FCRs) and Nonconformance Reports (NCRs) require approval by the design engineering contractor. The production engineering activities have been conducted in the fashion of normal nuclear processes.
Therefore, this program resembles the other design control processes and design programs in accordance with ANSI standards. The NRC has approved the CPRT.
I The PCHVP should be completed in October 1988 and will take i
credit for CPRT inspections and Field Verification Methods (FVMs).
Modifications are inspected in normal fashion by Quality Control and are not part of the PCHVP. A programmatic change from the Gibbs
& Hillfl'U Electric design era is that engineering now specifies acceptance criteria where acceptance criteria was specified by QC.
Each contractor will produce design basis documentation and, base i
line for configuration management will be in place.
t TU Electric engineering has over 200 TU Electric personnel within the total of more than 350 people. TU Electric disciplines and the Engineering Assurance group comment on contractors' procedures.
Contractors must implement TU requirements. There is no Gibbs &
Hill role. Gibbs & Hill people on the project are not associated with safety related work. The engineering functional evaluation SEE ATTACHED DISTRIBUTION SHEET Page 2
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Required f
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conducted by SWEC Engineering Assurance takes the place of the IDI or IDVP. There is precedence for this at Beaver Valley and has been accepted by the NRC.
With Larry Nace, the new Vice President and Director of Engineering, new Directors of Projects and Construction have been brought aboard, as well as many of the managers under the Directors. Brown and Root's role has changed so that they have only the ASME code requirements, where before, they had all of Quality Control. The various contractor interface procedures require approval by TU Electric, as well as the Task Descriptions. TU Electric controls the FSAR and makes changes based on contractor recommendations. Each contractor has been delegated responsibility i
for complying with the entire FSAR.
In general, statistical or sampling techniques are not being used as part of the PCHVP for QC inspections. Design changes must identify any backfit requirements and, Engineering drafts memos to QC to close loop. The responsibility to the contractors was transferred by letter, including the FSAR requirements, design criteria, and licensing basis. Design Basis Documents (DBDs) were initiated in late 1985. For all Engineering assurance surveillance, answers are required for corrective action and generic implication, as well as statements related to preventing future occurrences. The EAS tracks observations. Anyone can write a Deficiency Report and Quality Assurance validates the reports. Engineering Assurance closes all of their surveillance.s They also perform surveillance on design control, including trend reporting and codes. QA trends closeout for all outstanding DRs and NCRs.
Project Status Meetings, chaired by TU Electric Executive Vice President Bill Council, are attended by TU Electric's upper management and contractors' vice presidents. Most senior TU management is at the site at least three (3) days each week.
Engineering judgement is not allowed for any closeout; alternate calculations, design reviews, etc., are the only accepted closcout methods. Very few validated Gibbs & Hill records still remain. The remainder have ben obsoleted or superseded.
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CPSES Job No. 84056 March 22 and 23,1988 Subject-Quality Assurance Duties TUE QA Building Participants.
E. W. Dotson i
Cygna D. Smedley Cygna l
J. Streeter TUE QA i
Requred Comments Action By l
The Quality Assurance Overview Committee was initiated September
- October 1985. It consists of a regular meeting of senior officers who are directly responsible for functions to collectively focus attention on issues. It is also a forum for collectively considering these issues. For example, trending is looked at, including the changes in the trending approach. There is an annual assessment by the Executive Vice President. There was a Corrective Action Request indicating that more interface controls were needed at the time of the Correction Action Program initiation. All contractors were tied together by interface controit in December 1986.
Streeter was appainted Director of Quality Assurance in February 1986, shortly after joining TU Electric. The Quality Assurance i
organization moved to the site, starting in the summer of 1986 and, the move was completed in April 1987. The efficiency realized by the move was a key element in reducing travel time and effectively increasing work days to about 5 days a week from about 3.5. QA was brought closer to the project with better real time effort.
They became more a part of the team with better attendance at project meetings, less exchange of paper, and less bureaucracy.
Streeter also consolidated all Quality Assurance functions under one head in the summer of 1986. The organization is staffing with a baseline of permanent TU Electric QA people, with additional contracting personnel. Different from the Gibbs & Hill program in that, Gibbs & Hill performed vendor audits. Now, TU Electric Distribution:
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Communications AMJA Report 1111111111ll11111!!I1llllllll1 Required item Comments Action By performs vendor audits. There has been a significant turnover of QA personnel, particularly during the move. The type of QC people are considered different today. Previously there were very few TU Electric people in QC. Now, QC is predominately manned by TU Electric personnel. TU Electric began a Technical Audit Program (TAP) of the Corrective Action Program in February 1987. As of March 1988, about 100 audits have been conducted. Many of the personnel in the TAP are contractors since they are responsible for temporary assignments.
Several programs were initiated in the 1984-1985 timeframe to escalate concerns up the management chain. The SAFETEAM program was initiated in 1985. This is a program that encourages employees to address their concerns to an " independent" organization. The SAFETEAM conducts interviews whenever any employee from either TU Electric or the contractors leave. Also, a
" hot line" number was set up to Texas Utilities Corporate Security.
A procedure was set up around 1984 for a QA allegation reporting mechanism, but any means of contacting QA is acceptable. Policy statements, and letters, in addition to a video tape were presented to every new person employed. These and other activities are found in letters from Council to Denton, February 1986, in response to November 1985 NRC letter on allegations of harassment and intimidation.
General comments: engineering surveillance is conducted in QA and there has been an upgrade of experience and engineering capability in the people hired into QA. QA's approach is according to the process and not to the organizations. Task Descriptions describe the interfaces. Comanche Peak engineering does not perform design work. The new organization was established in the summer of 1986.
All previous Gibbs & Hill and TU Electric work has been superseded by either validation or redesign modifications by the contractors:
Impell, Ebasco, and Stone & Webster.
TUE\\032288-A. CON SEE ATTACHED DISTRIBUTION SHEET Page 2
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1' Communications Repod e4 L i i 11ll11llllll11llllllllllllll11 company; TUE Telecon conference neport Project ~
CPSES Job No.
840'6 5/09/88 I
subject:
Technical Audit Program (TAP)
N/A Place:
TUE QA Offices D. McAffee - Manager of QA TUE 1 Redding TUE N. Williams; E. Dotson; D. Smedicy Cygna Required Comments Action By The Technical Audit Program (TAP) was begun in the February.
March 1987 time frame. TAP was originally staffed by twenty-four (24) engineers from various consulting engineering companies. It was separated from all other QA activities. There was a vendor compliance program before the Technical Audit Program (TAP). In the present time frame, TAP has about 75 part-time consultants, more than 90% of vtich have four year degrees, about 40% have Master's degrees, and 18 people have PHd's. About 65% have professional engineering licenses. TAP has conducted about 90 audits. It is different in function from EFE of SWEC, in that it looks real time at engineering activities and not necessarily at completed design processes.
j Audit scopes swinde each of the eleven (11) project status reports, flow charts, design basis documentation, calculations, specifications, validations, design item reports by the CPRT, and the as-built design modifications. TAP has not looked into the final reconciliation from the PCHVP because not that much as yet has been done. The TAP performs alternate calculations and therefore, the audits are more like an independent design revier,.
l If TAP finds problems, they identify root cause back to the contractor and require a response. Packages are completed when the responses are generated and TAP closes them out. Their schedule is to complete their activities in October 1988. TAP does not take programmatic looks, but they do pass on observations to other organizations within the CPSES QA Department. TAP is an Signed Page
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stem comments enhancement program and is not a requirement of the QA program.
Of 450 findings, they still have about 399 open. Since there was some redundancy of effort, the Engineering Assurance arm of Comanche Peak Engineering has recently moved out of the Corrective Action Program, and now looks over the design control process itself.
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Communications AL ci Report llll1111fllllllll1lllllll11111 Company:
TUE Telecon Conference Report Project.
CPSES Job No.
84056 5/09/88
Subject:
post Construction Hardware Validation N/A Program (PCHVP)
TUE Engineer Building
Participants:
peter Stevens TUE Dave Smedley Cygna Erroll Dotson Cygna Required Comments Action By The PCHVP has nothing to do with design. Its purpose is to assure that the hardware meets the licensing / design commitments. The computer SPADU is utilized, it includes specifications, procedures, installation, QC and drawing update for information only. These are specifications and drawings developed by the three (3) contractors; Stone & Webster, Ebasco, and Impell who identified the inspection attributes for QC. QC previously identified inspection attributes.
Also, during CPRT, final acceptance attributes were determined (see the attached flow chart for the PCHVP program). To date, they have not truncated any of the inspections.
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I Final Inspection Attributes i
V CPRT Yes Accessible Yes Hardware I
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V V No No Design Change Technical Disposition or Acceptance-
> Yes Criteria Changes or CPRT Did Not Look At y
Yes ongoing Modification
)! No 8f Acceptable Comanche Peak By Sampling
> Engineering (Approved by NRC)
Approval V
Vault (
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CPSES Job N 84056 5/10/88 subject:
Post Construction Hardware Validation N/A Program (PCHVP) pi,c, TUE Engineer Building Participants' of p
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Erroll Dotson TUE Dave Smedley Cygna Required Comments Action By No credit is being taken for the Gibbs & Hill or Brown & Root work. As-built drawings will be validated by the new contractors:
Stone & Webster, Ebasco, and Impell.1150 of the 1650 attributes will be inspected, about 70%. The CPRT is a third party effort conducted by several contractors. It has been accepted by the NRC with a Supplemental Safety Evaluation Report (SSER). CPRT relies on a statistical random sampling basis, described in the program as basically a 95/5 sampling of defects. CPRT is continuing to inspect the results and unresolved items are closed out by CPRT staff. Itis based on an infinite population and there are five (5) categories of trending. The program is considered very conservative and CPRT must agree on any truncation. They also perform assessment of the PCHVP. Therefore, the CPRT is an overview program but they do not perform audits of the PCHVP.
The new design is a new configuration and is inspected in typical QA fashion. The old design is considered a validation by random sampling, physical verification, or engineering validation. Appendix D to the CPRT plan explains the sampling process.
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TUE Teiecon conference Report P'ol'c' CPSES Job No. 84056 5/10/88 Subject-Engineering Assurance Surveillance (EAS)
Tim
- N/A Place.
TUE Engineer Building
Participants:
Jimmy Barker TUE Erroll Dotson Cygna Required Comments Action By EAS is continuing on-going surveillance with trending. There have been twenty (20) surveillance with about 100 deficiency reports. In some cases, the Design Change Authorizations were incorrect and in others, NRC's were incorrectly dispositioned. In each case, they evaluate the DCA's as to whether or not a DR should be written.
Each EAS surveillance is sent to QA; however, QA only determines trends on NCR's and DR's. Cygna has verified that contractors are writing NCR's and DR's on themselves.
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CPSES Job No. g40%
5/10/88 Subject-Hidden or Inaccessible Inspection Attributes N/A l
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Place:
TUE Engineer Building Participants Scott Harris TUE Dave Kissincer TUE Dave Smedley Cygna Erroll Dotson Cygna Required Comments Action By There will be 100% inspection on cable tray hangers and supports, HVAC hangers and supports, conduit hangers and supports, as well as piping hangers and supports. Therefore, for attributes of these commodities, it will be relatively simple to statistically extrapolate from the visible to the hidden attribute, based on those previous inspections. In other cases such as welding, testing or evaluation is in process.
There are various programs for verification. For example, past history and review of photographs allow a qualitative assessment.
For the Post Construction Hardware verification Program (PCHVP) contractors are responsible for the technical disposition. Previous QC inspections will provide backup information. Procedures have been developed for an evaluation by testing, statistical analysis, and various layers of confidence with a check of previous inspections.
The entire PCHVP is considered a complete revalidation.
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conspany: - TUE-Telecon conference Report P oject:
PSES Job No-84056 5/10/88 subject:
System Interaction Program (SIP)
""* N/A Place:
TUE Engineer Building Dave Lowry, Mike Osterman, Delip Patankri TUE Herman Kunis, Dave West, Tom Flynn, Bob Leo Ebasco Craig Hardy QUE Linda Garriott, Erroll Dotson, Dave Smedley Cygna l
Required Comments Action By SIP began as a damage study. SIP has been within Ebasco responsibility, with EQE as a subcontractor through Ebasco procurement. In mid to late 1985, the program was removed from the Ebasco Quality Assurance Program. Within the SIP, specific tasks have been assigned to Ebasco's Applied Physics group which works under Ebasco QA procedures. " Legally", Ebasco is responsible for the program. There is no Ebasco Quality Assurance Program used on SIP except tasks by Applied Physics. There is no interface procedure between the SIP and Applied Physics. SIP is under TU Electric procedures and Quality Assurance Program; and, Ebasco has legal responsibility for SIP. EQE performs seismic /non-seismic work to onsite TU Electric programs. The work in California, home office of EQE, is to EQE's program. They deal primarily with the anchorage of seismic II equipment. The Ebasco/EQE interface is i
defined by Ebasco Task Description TD-007. EQE is considered an Ebasco subcontractor and therefore is not in the interface or correspondence procedure. Ebasco QA does not audit the SIP function even though it is entirely one (1) audit on the SIP.
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Signed.
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[ Teieu. n conference Report Project CPSES Job No. 84056 cat ~ -
05/11/88 Subject-Design Responsibility 10:00 a.m. C.D.T.
Tim *:
Place:
Walnut Creek, CA
Participants:
of TU Engineering Building E. Dotson Cygna l
J. Muffett TUE Required Comments Action By In the Gibbs & Hill era, TUE Engineering was " embedded" in various design groups. First, TUE decided to obtain a major A/E firm for pipe support design responsibilities. Then, TUE was to perform overview and not participate in the design. At that time TUE would review and concur with procedures. Then, all design responsibilities 1
were placed with contractors. All design is validated by contractors.
If any designs were to be performed by TUE, procedures required that a contractor validate the design. Dave Smedley to confirm that procedures exists.
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