TXX-6631, Forwards Description of Comanche Peak Response Team & Corrective Action Program & Util Position Re How Programs Interrelate.Illustration Also Encl

Forwards Description of Comanche Peak Response Team & Corrective Action Program & Util Position Re How Programs Interrelate.Illustration Also Encl

ML20237H218
Person / Time
Site:	Comanche Peak
Issue date:	08/20/1987
From:	Counsil W, Nace L TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6631, NUDOCS 8708240396
Download: ML20237H218 (10)

Text

-.

o M Log # TXX-6631 F9 File # 10004

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NELECTRIC August 20, 1987 WWism G Counsil Executsve Vice Presuk'est U. S. Nuclear-Regulatory Commission ATTN: Document Control Desk j Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) l DOCKET NOS. 50-445 AND 50-446' COMANCHE PEAK PROGRAMS Gentlemen:

TV Electric hereby provides, in the attachments to this letter, a description of the Comanche Peak Response Team (CPRT) and Corrective Action Program (CAP),

and TU. Electric's position on how the two programs interrelate. The two programs will collectively be referred to as the Comanche Peak Programs {

throughout this letter.

Attachment I provides a written description of the Comanche Peak Programs to be used with the illustration of these Programs provided in Attachment 2. The  ;

drawing in Attachment 2 is simplified for illustration purposes and does not i show each individual feedback loop between CPRT and CAP.

Very truly yours,

().G. w W. G. Counsil

~

By: me-< %

87082 PDR g g[$$$k45 L. D. Nace A

PDR Vice President, Engineering and Construction RSB/grr Attachments c - Mr. C. I. Grimes (1 letter w/ 1 figure attached) i Mr..H. E. Schierling (1 letter w/ 20 figures attached) i Mr. R. D. Martin, Region IV Resident Inspectors CPSES (3 letters w/10 figures attached)

A 9 ') \

j 400 North Olive Street LB 81 Dallas, Texas 75201

. Attachment I to TXX-6631 August 20, 1987 Page 1 of 6 i

COMANCHE PEAK PROGRAMS The genesis of the current Comanche Peak Programs was the external source issues identified by the following:

o NRC Staff Special Review Team (NRC-SRT) o NRC Staff Special Inspection Team (SIT) o NRC Staff Construction Appraisal Team (CAT) o Citizens Association for Sound Energy (CASE) o Atomic Safety & Licensing Board (ASLB) o NRC Region IV Inspection Reports (RIV-IR) o NRC Staff Technical Review Team (TRT) [SSER 7-11]

o Cygna Independent Assessment Program (IAP)

These external source issues, particularly those identified by the TRT, resulted in TU Electric's initiation of the Comanche Peak Response Team (CPRT). The Comanche Peak Response Team consisted of two basic elements:

o Design Adequacy Program (DAP); and o Quality of Construction (QOC) Program, including Issue Specific Action Plans (ISAPs) for each discrete TRT issue.

These two elements investigated and evaluated both design-related and construction /QA-related issues.

Desian Adeauacy Procram The Design Adequacy Program o conducted investigations of the adequacy of design; o identified individual deviations in the form of Discrepancy Issue Reports (DIRs) for project resolution; 3 o grouped related DIRs into Issue Resolution Reports (IRRs) for project evaluation; and o provided overview of project corrective action for the identified deficiencies in the pipe and pipe support, cable tray hanger and conduit support programs at CPSES.

A qualitative and quantitative review by TV Electric of the preliminary results of the DAP investigative phase revealed that the findings identified were very broad in scope and included most disciplines. The significance of these preliminary findings prompted TU Electric to initiate a comprehensive ,

Corrective Action Program (CAP). DAP findings, in the form of IRRs and DIRs, were inputs to the CAP. The CAP utilized industry recognized architect-engineering firms to conduct a complete validation of all safety-related and selected non-safety related design aspects of CPSES with the following exceptions:

o NSSS System (~nterface being validated) o Vendor hardware design (Interface being validated)

)

> Attachment I to TXX-6631 August 20, 1987 Page 2 of 6 This complete design validation is being conducted in eleven disciplines as will be further discussed later in this submittal. TU Electric's commitment to conduct this complete validation of the safety-related design obviated the necessity to continue the evaluation phase of the CPRT Design Adequacy '

Program. In particular, this early TV Electric decision obviated the need for the DAP evaluation'of identified design discrepancies per the CPRT Program Plan, Appendix E. However, the DAP continued its overview activities for certain project corrective actions. The DAP overview activities will be documented in the following three Discipline Specific Action Plan (DSAP)

Results Reports which are scheduled to be submitted to the NRC Staff by October 1987:

o Large Bore Pipe Supports; o Cable Tray Hangers; and o Conduit Supports.

The r, significance of the findings identified by the DAP and the effectiveness of the TV Electric CAP in resolving those findings will be addressed in the CPRI Senior Review Team Collective Significance Report which is scheduled to be submitted to the NRC Staff in December 1987.

Quality of Construction Proaram The CPRT Quality of Construction (Q0C) Program was conducted in two parts:

o investigation and evaluation of Issue Specific Action Plans which addressed discrete NRC Staff Technical Review Team (TRT) issues; and o a self-initiated investigation and evaluation of the quality of construction of the completed hardware.

During the investigation phase, CPRT, through its sampling reinspection program, identified findings to the project in the form of Deviation Reports (DRs) and Out of Scope Observations (00S0s). These DRs and 00S0s were converted to project Nonconformance Reports (NCRs) for project resolution.

Separately and in parallel, findings from the QOC Program were evaluated by )

CPRT in accordance with the CPRT Program Plan, Appendix E, for: I o Safety Significance Evaluation as defined in the CPRT Program Plan (to determine the necessity for sample expansion);

l o Trend Evaluation; i o Root Cause Analysis; and '

o Generic Implications.

The results of the investigation and evaluation will be published in 46 Issue Specific Action Plan Results Reports. All of these reports are scheduled for submittal to the NRC Staff by October 1987. In addition, the ISAP VII.c Results Report for the self-initiated evaluation of construction quality is scheduled for submittal to the NRC Staff by October 1987.

Additionally, the results of the QOC program are inputs to the CPRT QA/QC Program Collective. Evaluation Report and the CPRT Senior Review Team Collective Significance Report, scheduled for submittal to the NRC Staff by October 1987 and December 1987, respectively.

Attachment 1 to TXX-6631 August 20, 1987 Page 3 of.6 Deficiencies and recommendations identified in the QOC results reports and Collective Evaluation Report are provided to the project in the form of:

o Results Report Recommendations (RRRs); and o Program Deficiency Reports (PDRs).

Those RRRs'and PDRs resulting from deficiencies which CPRT determined to be

" safety significant" (as defined in the CPRT Program Plan) are addressed in project Corrective Action Reports (CARS). The CPRT must concur with project resolution of those recommendations. Other recommendations, RRRs resultinc from deficiencies determined by CPRT to be not safety significant, are provided as direct input to the project for. consideration in the post-construction hardware validation phase to be discussed later in this letter.

At this time, the CPRT investigation and evaluation is essentially complete and has identified those issues which must be resolved by the project. This i investigation and evaluation of findings was a necessary step to determine the nature and extent of corrective actions at CPSES, and it served as a vital input to the formulation of the CAP.

TV Electric Corrective Action Proaram TV Electric evaluated the early results coming out of the CPRT program, as discussed earlier, and made a decision to initiate the CAP. The CAP includes a complete design and hardware validation program of the safety-related and selected non-safety related portions of CPSES (with exceptions noted earlier) and provides a planned, integrated resolution of identified problems rather than attempting to resolve each issue individually. This methodology assures that all issues are appropriately addressed. TU Electric contracted Stone &

Webster Engineering Corporation, Ebasco, and Impe11 to conduct the CAP.

CAP Scope The CAP. scope was divided into eleven disciplines as follows-DISCIPLINE RESPONSIBLE CONTRACTOR Mechanical SWEC Systems Interaction EBASCO Fire Protection IMPELL Civil / Structural SWEC Electrical SWEC Instruments > ion & Control SWEC Large Bore Pipe Supports SWEC PSAS Cable Tray Hangers EBASC0/IMPELL Conduit Supports Trains A, B, and C > 2" EBASCO l Conduit Supports Train C s 2" IMPELL I Small Bore Pipe Supports SWEC PSAS HVAC EBASCO Equipment Qualification IMPELL

Attachment I to TXX-6631 August 20, 1987 Page 4 of 6 Generic Issue Reports All external issues known at the time of issuance, including DIRs and IRRs issued from the DAP, were collected in Generic Issue Reports (GIRs). A GIR was developed for each of the 11 disciplines by the responsible CAP contractor. All of the GIRs have been submitted to the NRC Staff. These GIRs collected known issues and identified the planned approach to resolve these issues. The GIRs are not being updated for additional input data, but are being revised as the methodology to resolve issues changes. Additional data are input directly to the CAP design and hardware validation phases where they are evaluated and resolved.

Desian Validation The GIRs, as well as available, applicable historical design data such as calculations, drawings, specifications, change documentation, deficiency paper, licensing commitments, FSAR commitments, and correspondence were reviewed by the responsible contractor. Design-related licensing commitments are captured in Design Basis Documents (DBDs) which were developed to clearly identify the bases for the Design Validation effort. Design documentation, and identified design problems, are then reviewed to the design bases to ensure that the design satisfies the licensing commitments. The design documentation is either validated as being acceptable, or it is revised to be acceptable. The design validation effort within each of the eleven CAP disciplines is being accomplished and documented in smaller workable packages, design validation packages (DVPs). The Design Validation provides assurance that the design meets all licensing commitments. One of the major activities in the design validation effort is to revise the Engineering specifications to reflect the validated design, and to include hardware inspection requirements in the specification. This validated design, with required changes identified, is the " final design" with respect to the CPRT program, in that it resolves all CPRT design issues.

Post Construction Hardware Validation The Post Construction Hardware Validation Program (PCHVP) is a complete validation of final acceptance inspection attributes for safety-related and selected non-safety related hardware. The revised (validated) erection specifications include hardware inspection requirements for new installations and form the bases for the PCHVP Attribute Matrix. Using input from the QOC program in the form of CARS, NCRs, and CPRT recommendations, and changes identified as a result of the CAP design validation activities, the Engineers will challenge (i.e., evaluate) each final acceptance attribute for acceptability and determine the method to be used to validate that attribute.

This evaluation is procedurally controlled, and if the disposition is

" acceptable", the results will be clearly documented. If the technical assessment of the attribute is dispositioned "not acceptable" (or cannot be dispositioned based on available information), then measures such as  !

inspection, walkdown, or alternative testing to validate the attribute will be  !

performed. As mentioned at our public meeting the procedures to guide the  !

Engineer on these evaluations should be completed by the end of August.

l I

L ,

i Attachment 1 to TXX-6631 q August 20, 1987 '

Page 5 of 6 Physical validation of an attribute by quality control reinspection or engineering walkdown will be performed, for accessible components, when any of j the following pertains:

o CPRT recommendation to reinspect; o Design Validation results in change to design or acceptance attribute; or o Design Validation results in new work, including modification to existing hardware.

The PCHVP provides assurance that the as-installed hardware meets the validated design.

Desian Reconciliation The as-installed condition is compared to the validated design and any design data which have been identified as subject to confirmation are confirmed, thereby ensuring that the final installation satisfies final design requirements. The design reconciliation provides the documented data base which establishes that the as-constructed plant meets the design basis. The documentation is then vaulted.

Proiect Status Reports The results of the CAP are reported in eleven Project Status Reports (PSRs),

one for each of the eleven disciplines. The PSRs identify and describe the resolution of issues (including IRRs, IAP findings, SDARs), describe the design and hardware validation activities, and report how the issues were resolved such that licensing commitments have been satisfied. The methodology and results of the corrective action taken are discussed in detail.

Appendices to the PSR specifically address:

Appendix A - External Source and CPRT Issue Specific Resolution; Appendix B - Self-initiated Issue Specific Resolutions; and Appendix C - Preventive Action Taken.

Overview ,

I The CPRT has essentially completed its investigation and evaluation phases, as )

described earlier, and is now preparing their results reports and conducting l overview of the corrective action phase. The overview is the responsibility '

of the CPRT Senior Review Team. The Senior Review Team exercises their overview through the following methods:

1 o selected CPRT overview; o monitoring of the implementation and results of the TU Electric QA Program Technical Audit Program; and o monitoring of the implementation and results of the Engineering Functional Evaluation.

(More details on the Technical Audit Program and the Engineering Functional Evaluation program will be provided in separate submittals.)

i

. Attachment I to TXX-6631 August 20, 1987 Page 6 of 6 The implementation and results of these overviews will be discussed in the CPRT Collective Significance Report.

Summary .

The CPRT investigation of issues and evaluation of findings is essentially

- complete, and has identified those issues which must be resolved by the project. This investigation and evaluation of findings was a necessary step to determine the nature and extent of problems at CPSES, and it served as vital input to the formulation of the CAP.

The CAP was formulated to address CPRT and other open external source issues. ,

The CAP has three elements; validation of design to licensing commitments, '

validation of hardware to the validated design, and design reconciliation.

TV Electric is confident that the CAP, when implemented, will provide assurance that the design satisfies licensing commitments, and the hardware complies with the validated design. This in turn provides assurance that structures, systems and components with a safety-related function will perform satisfactorily in service.

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.- Attachment 2 to TXX-6631 August 20, 1987 Page 2 of 3 l

FOOTNOTES:

LEGEND:

BLUE - Raw Data Input I GREEN - CPRT Program BLACK - Corrective Action Program RED - End Product Reports Arrows indicate the flow of information. Double ended arrow head means CPRT concurrence is required on corrective actions that CPSES Project takes to resolve CPRT Results Report Recommendations and Program Deviation Reports which stemmed from CPRT Safety Significant findings.

Similiary, the double ended arrow between the Corrective Action Program Block and the Overview Block means that the appropriate Overview Group must concur with resolution of identified concerns.

1) IRRs are a grouping of related DIRs.

2) DAP did not perform evaluations of findings per CPRT Program Plan, Appendix E, because of TV Electric decision to conduct CAP.

3) The DAP Discipline Specific Action Plan Results Reports document CPRT overview of TV Electric Corrective Action Programs for these topics.

4) ISAPs address discrete TRT issues.

5) At time of issuance GIRs input raw data and describe approach to resolve related issues. GIRs are not being updated for additional input data.

They are being updated as methodology to resolve the issues changes.

6) Includes, but is not limited to, applicable calculations, drawings, specifications, change documentation, deficiency paper, licensing commitments, FSAR commitments, procedures, records, correspondence.

I

4 Attachment 2 to TXX-6631 l August 20, 1987 l Page 3 of 3 i ACRONYMS: l ASLB Atomic Safety and Licensing Board CAT Construction Appraisal Team CAR Corrective Action Request CASE Citizens Association for Sound Energy CPRT Comanche Peak Response Team )

DAP Design Adequacy Program DIR Discrepancy Issue Report DR Deviation (CPRT)/ Deficiency (TV) Report DSAP Discipline Specific Action Plan DVP Design Validation Program EFE Engineering Functional Evaluation (SWEC) l FSAR Final Safety Analysis Report 1 GIR Generic Issues Report IAP Independent Assessment Program (CYGNA) i IRR Issue Resolution Report ISAP Issue Specific Action Plan NCR Nonconformance Report NRC-SRT NRC Special Review Team 00S0 Out-of-Scope Observation PDR Program Deviation Report PSR Project Status Report QOC Quality of Construction (ERC)

RIV-IR Region IV Inspection Report RRR Results Report Recommendation SDAR Significant Deficiency Analysis Report SIT Special Inspection Team SRT Special Review Team TAP Technical Audit Program (TV)

TRT Technical Review Team (SSERs 7-11)